Evaluation of the union programme to support specific activities enhancing the involvement of consumers and other financial services end-users in Union policy-making in the area of financial services for the period of 2017-2020 : final report.
Date: 2020-01-04
Institutions: Directorate-General for Financial Stability, Financial Services and Capital Markets Union
Subjects: EU policy, EU programme, consumer, financial services, policymaking, report

Evaluation of the Union 
Programme to support specific 
activities enhancing the 
involvement of consumers and 
other financial services end-users 
in Union policy-making in the area 
of financial services for the period 
of 2017-2020  

Final Report 

June – 2020  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Authors: 

VVA: Julia Rzepecka, Frithjof Michaelsen, Aneta Sadlik, Jordan Hill 

Milieu: Tony Zamparutti, Valentina Cilli, Ana Silva 

EUROPEAN COMMISSION 

Directorate-General for Financial Stability, Financial Services and Capital Markets Union 
Directorate B — Horizontal policies 
Unit B.3 — Retail financial services 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Evaluation of the Union Programme to 
support specific activities enhancing the 
involvement of consumers and other 
financial services end-users in Union 
policy-making in the area of financial 
services for the period of 2017-2020  

Final Report 

Directorate General for DG Financial Stability, Financial Services and Capital Markets Union 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
LEGAL NOTICE 

This  document  has been  prepared for  the  European  Commission  however  it  reflects  the views only of  the 
authors, and the Commission cannot be held responsible for any use which may be made of the information 
contained therein. 

The European Commission is not liable for any consequence stemming from the reuse of this publication.  

Luxembourg: Publications Office of the European Union, 2020. 

© European Union, 2020 
Reuse is authorised provided the source is acknowledged.  The reuse policy of European Commission 
documents is regulated by Decision 2011/833/EU (OJ L 330, 14.12.2011, p. 39). 

For any use or reproduction of photos or other material that is not under the copyright of the 
European Union (*), permission must be sought directly from the copyright holders. 

ISBN: 978-92-76-08881-3 

DOI: 10.2874/257865 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

Executive summary ........................................................................................ 8 

1 

Introduction ........................................................................................... 15 

1.1  Objectives .......................................................................................... 15 

1.2  Scope ................................................................................................ 15 

1.3  Overview of the beneficiaries ................................................................ 16 

1.3.1 

Better Finance .............................................................................. 16 

1.3.2 

Finance Watch .............................................................................. 16 

2  Evaluation methodology ......................................................................... 18 

2.1 

2.2 

Intervention logic ................................................................................ 18 

Information sources ............................................................................ 20 

2.3  Comparison with other organisations ..................................................... 23 

3  Findings of the evaluation ...................................................................... 25 

3.1 

3.2 

3.3 

3.4 

Evaluation of Better Finance: effectiveness, efficiency and relevance ......... 25 

Evaluation of Finance Watch: effectiveness, efficiency and relevance ......... 51 

Evaluation of coherence of both beneficiaries.......................................... 80 

Evaluation of EU added value of both beneficiaries .................................. 93 

4  Conclusions ............................................................................................ 99 

4.1  Better Finance’s effectiveness, efficiency and relevance ........................... 99 

4.2 

Finance Watch’s effectiveness, efficiency and relevance ......................... 100 

4.3  Coherence ....................................................................................... 101 

4.4 

EU added value................................................................................. 102 

5  Annexes ............................................................................................... 103 

 
 
 
 
 
List of Tables 

Table 1: Number of interviews by stakeholder group ............................................ 23 
Table 2: Comparison between the beneficiaries and comparator organisations ........ 24 
Table 3: Costs and main quantifiable outputs of Better Finance ............................. 40 
Table 4: Outputs of COFACE, AGE Platform Europe, BEUC (2017) .......................... 41 
Table 5: Funding sources of consumer organisations* .......................................... 45 
Table 6: Costs and main quantifiable outputs of Finance Watch ............................. 67 
Table 7: Output of consumer organisations (2017) .............................................. 68 
Table 8: Funding Sources of consumer organisations* ......................................... 72 
Table 9: Other Union measures ......................................................................... 82 
Table 10: Overview of publications which meet EU or international policy objectives 90 

List of Figures 

Figure 1: Intervention logic of the Union Programme ........................................... 19 
Figure 2: Intervention logic with evaluation criteria ............................................. 20 
Figure 3: Responses to Better Finance Survey (N=69) ......................................... 22 
Figure 4: Responses to Finance Watch Survey (N=110) ....................................... 22 
Figure 5: Better Finance’s contribution to enhancing the active participation of various 
stakeholder groups in financial services (N=30) .................................................. 26 
Figure 6: Influence of Better Finance’s activities on the level of involvement of members 
and national consumers (N=21) ........................................................................ 27 
Figure 7: Impact of Better Finance on decision-making within financial services; left: at 
EU level, right: at national level (N=17, 16) ....................................................... 29 
Figure 8: Level of awareness of the communication activities of Better Finance (N=30)
 .................................................................................................................... 31 
Figure 9: Better Finance’s communication activities to expert and non-expert audiences 
(N=22) .......................................................................................................... 31 
Figure  10: Knowledge  of  Better  Finance's  position/perspective  on  European  issues  in 
the area of financial services (N=16) ................................................................. 32 
Figure 11: Level of usefulness  of Better Finance’s research work and  position papers 
(N=31) .......................................................................................................... 34 
Figure 12: Degree to which Better Finance's research work, policy papers, responses to 
consultations, studies, served the needs of the stakeholders (N=32) ..................... 34 
Figure 13: Evaluation of Better Finance’s position papers (N=14) .......................... 35 
Figure 14: Evaluation of Better Finance’s responses to consultations (N=26) .......... 35 
Figure 15: Potential obstacles for Better Finance in reaching set objectives (N=33) . 37 
Figure 16: Alignment of objectives of Better Finance with the current issues and needs 
of consumers and financial end-users (N=26) ..................................................... 47 
Figure 17: Finance Watch’s contribution to enhancing the active participation of various 
stakeholder groups in financial services (N=73) .................................................. 52 
Figure  18:  Influence  of  Finance  Watch’s  activities  on  the  level  of  involvement  of 
members and national consumers (N=62) .......................................................... 52 
Figure  19:  Level  of  awareness  of  the  needs  of  the  financial  end-users  as  a  result  of 
Finance Watch’s work (N=32) ........................................................................... 54 
Figure  20:  Impact  of  Finance  Watch  on  EU  decision-making  within  financial  services 
(N=32) .......................................................................................................... 55 
Figure 21: Level of awareness of the communication activities of Finance Watch (N=71)
 .................................................................................................................... 58 
Figure 22: Finance Watch communication activities to expert and non-expert audiences 
(N=65) .......................................................................................................... 58 
Figure 23: Conferences organised by Finance Watch (N=64) ................................ 59 

 
 
Figure 24: Knowledge of Finance Watch position/perspective on European issues in the 
area of financial services (N=31) ...................................................................... 60 
Figure 25: Evaluation of Finance Watch’s responses to consultations (N=69) .......... 61 
Figure 26: Evaluation of Finance Watch’s own research work (N=25) ..................... 62 
Figure 27:  Level of usefulness  of Finance  Watch’s  research  work and  position papers 
(N=71) .......................................................................................................... 62 
Figure 28: Obstacles hindering Finance Watch from achieving its objectives (N=71) 64 
Figure  29:  Relevance  of  Finance  Watch  activities  for  enhancing  the  involvement  of 
consumers and financial end-users (N=71) ........................................................ 75 
Figure 30: Relevance of Finance Watch activities for informing consumers and financial 
end-users (N=71) ........................................................................................... 75 
Figure 31: Coherence of Better Finance with other EU measures (N=24) ................ 80 
Figure 32: Coherence of Finance Watch with other EU measures (N=65) ................ 81 
Figure 33: Coherence  of Better Finance events with EU policy objectives for financial 
services (N=8) ................................................................................................ 87 
Figure 34: Coherence  of Finance Watch events with EU policy objectives for  financial 
services (N=24) .............................................................................................. 87 
Figure  35:  Coherence  of  Better  Finance  publications  with  EU  policy  objectives  for 
financial services (N=8) ................................................................................... 88 
Figure  36:  Coherence  of  Finance  Watch  publications  with  EU  policy  objectives  for 
financial services (N=25) ................................................................................. 88 
Figure 37: Added value brought by Better Finance to EU consumer policy in financial 
services since 2017 (N=26) .............................................................................. 94 
Figure 38: Added value brought by Finance Watch to EU consumer policy in financial 
services since 2017 (N=69) .............................................................................. 94 
Figure 39: Potential negative impact of stopping the measure on consumer and financial 
services  end-user  awareness  and  participation  in  policy-making  –  Better  Finance 
(N=13) .......................................................................................................... 96 
Figure 40: Potential negative impact of stopping the measure on consumer and financial 
services  end-user  awareness  and  participation  in  policy-making  –  Finance  Watch 
(N=29) .......................................................................................................... 97 

 
 
 
 
Executive summary 

Objectives and scope 

The  objective  of  this  evaluation  is  to  make  an  analysis  of  the  activities  of  Better 
Finance and Finance Watch – the two beneficiaries of the Union Programme to support 
specific  activities  enhancing  the  involvement  of  consumers  and  other  financial  services 
end-users  in  Union  policy-making  in  the  area  of  financial  services1  (hereafter  the  Union 
Programme) – and an assessment of the impacts of these activities.  

Following the Better Regulation Guidelines, the evaluation assesses the beneficiaries’ 
activities  and  impacts  in  terms  of  their  effectiveness,  efficiency,  relevance, 
coherence and EU added value.  

•  Effectiveness:  the  evaluation  identifies  the  extent  to  which  the  activities  of  the 
beneficiaries  were  effective  in  achieving  their  objectives  and  the  extent  to  which 
their overall performance was effective; 

•  Efficiency:  the  costs,  outputs  and  overall  resource  use  of  the  beneficiaries  are 
assessed to evaluate the cost efficiency of their operations and whether the benefits 
are achieved at a reasonable cost; 

•  Relevance: the analysis establishes the extent to which the original objectives for 
the financing of the beneficiaries still correspond to current needs or whether there 
are new challenges for financial end-users that remain unaddressed; 

•  Coherence:  complementarities  between  the  various  tasks  and  activities  of  the 
beneficiaries are assessed against their overall consistency with relevant EU policies; 
•  EU added value: the extent to which the intervention at EU level provides additional 

value is assessed against what could have been achieved at national level. 

Methods 

Primary and secondary desk research  

In  the  initial  step  of  the  evaluation,  a  variety  of  primary  and  secondary  sources  were 
reviewed.  Primary  sources,  such  as  annual  reports,  work  programmes, 
membership  surveys  and  other  relevant  documents  were  obtained  from  the 
beneficiaries  themselves.  These  were  supplemented,  where  applicable,  with  EU  and 
national-level literature, including media articles, to provide further context for analysis. 
The results of the previous evaluation in 2015 were also used to contextualise the activities 
of the beneficiaries. As the majority of the secondary literature does not specifically refer 
to  the  two  beneficiaries,  the  primary  literature  provided  by  the  beneficiaries  was 
the main source for the desk research. The risk in using self-reported information is 
that the information may not be presented in an objective way. To counteract this risk, the 
desk  research  was  complemented  with  online  surveys  and  stakeholder 
interviews. 

Online surveys  

Two online surveys were launched (one for Better Finance and one for Finance Watch) 
to  gather  in-depth  opinions  from  a  wide  pool  of  external  stakeholders.  The  aim  of  the 
surveys  was  to  gain  more  detailed  insights  into  the  experiences  and  impacts  of  the 
beneficiaries’ activities. The questions were tailored  to stakeholder type and covered the 
following  five  groups:  member  organisations  (of  each  beneficiary),  banking 
associations, consumer organisations, national public  authorities and EU  public 

1  Regulation  (EU)  2017/826  of  the  European  Parliament  and  of  the  Council.  Available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R0826&from=EN  

8 

 
 
bodies. The surveys were shared with 309 stakeholders. For Better Finance, there were 
69 survey participants and for Finance Watch, there were 110 survey participants.  

Interviews with EU-level and national stakeholders  

Stakeholder interviews were based on a semi-structured format and were directed to the 
same stakeholder groups as the survey questionnaire. The interview questions aimed to 
complement information received from the desk research and online surveys and 
to fill remaining data or information gaps. In total, 25 interviews were conducted. 

Overview of Better Finance and Finance Watch activities 

Better Finance, the European Federation of Investors and Financial Services Users, acts 
to  promote  research,  information  and  training  on  investments,  savings  and  personal 
finances.  It  is  a  European-level  organisation  dedicated  to  the  representation  of 
individual investors, savers and other financial services users. Better Finance has 
nearly 50 independent national and international member and sub-member organisations, 
mainly from EU Member States, including financial consumer associations and several trade 
unions. In 2017, Better Finance received EUR 292,394 and, in 2018, EUR 400,000 
from the Union Programme action grant. 

Finance Watch has been providing technical expertise, as well as lobbying and research, 
to  the  European  Commission  and  European  Parliament  since  its  establishment  in  2011. 
The organisation was created to act as a counterweight to the financial industry’s 
lobby  by  representing  the  views  of  the  general  public  and  financial  services  end-users. 
Finance Watch’s focus and membership are very broad; its members include civil society 
organisations and expert individuals. In 2017, Finance Watch received EUR 993,010 
and, in 2018, EUR 1,100,000 from the Union Programme action grant. 

Findings  of  the  evaluation  of  Better  Finance’s  effectiveness, 
efficiency and relevance  

Effectiveness 

Overall, the work carried out by Better Finance during the evaluation period was 
effective in enhancing the involvement of stakeholders outside the banking and finance 
sector  and  raising  issues  that  might  otherwise  have  been  missed  in  debates  on  future 
financial regulation. Better Finance’s campaigns and reports were timely and relevant, with 
many  national  member  organisations  recognising  a  higher  level  of  involvement  of  end 
users/consumers at national level as a direct result of the action. While it is difficult at any 
level of policy-making to pinpoint exactly where lobbying has had an effect, there is clear 
evidence from the surveys and interviews that policy makers feel better informed 
as a direct result of the work of Better Finance. According to the results of the survey 
and  interviews,  Better  Finance  contributed  considerable  qualitative  and  quantitative 
expertise  in  relevant  areas  during  the  evaluation  period,  often  in  overlooked  areas,  for 
example closet indexing of funds. Nevertheless, there does seem to be a lack of knowledge 
among national authorities with regards to the work of Better Finance, although considering 
the organisation’s EU focus and limited resources, prioritising communications to EU level 
stakeholders  is  an  understandable  strategy.  Moreover,  there  is  a  high  level  of 
satisfaction among stakeholders with the quality of outputs.  

A  large  increase  in  the  number  of  speaking  engagements  and  media  citations 
during the evaluation period is also a strong indicator that Better Finance performed well 
and that its inputs and interventions were valued by policy makers and stakeholders alike.  

One  area  of  concern  is  the  number  of  report  downloads,  which  showed  a 
significant  decrease  in  2018  compared  with  2017.  This  suggests  that  Better  Finance 
could improve its dissemination activities after the initial communication of publications. 

9 

 
Moreover, Better Finance’s online and social media performance was poor compared 
to similar organisations and there is clearly room for improvement in this area. 

Efficiency 

Between  2017  and  2018,  Better  Finance’s  expenditure  and  outputs  did  not  change 
significantly.  Better  Finance  thus  maintained  a  rather  stable  cost-output  ratio 
during the two evaluation years, as seen in the following table of costs and outputs. 

2017 

2018 

Activity area 

Direct 
costs in 
EUR2 

Direct 
costs 
scaled3 

Output description 

Direct 
costs in 
EUR 

Output description 

Research 

92,501 

138,752  Research reports: 4 

164,278  Research reports: 7 

97,758 

146,637  Responses to public 

169,674  Responses to public 

Advocacy 

Raising 
awareness, 
dissemination, 
financial 
education and 
training 

Reinforcement 
of interaction 
between 
member 
organisations 

consultations: 24 
Position papers: 5 
Public debates: 13 
Expert groups: 14 
Members in expert 
groups: 27  

consultations: 30 
Position papers: 8 
Public debates: 38 
Expert groups: 13 
Members in expert 
groups: 26 

171,119 

256,679  Events: 7 

164,143  Events: 8 

Event attendees: 460 
Media participants: 
20 
High-level speakers: 
10 
Press releases: 22 

Event attendees: 1321 
Media participants: 204 
High-level speakers: 14 
Press releases: 24 

96,064 

144,096  Board meetings: 5 

135,500  Board meetings: 4 

Action committee 
meetings: 3 
General Assemblies: 
2 
Conferences: 2 
Legal committee 
meetings: 1 
Events organised by 
members: 4 

Action committee 
meetings: 3 
General Assemblies: 2 
Conferences: 2 
Legal committee 
meetings: 1 
Workshops: 1 

TOTAL 

457,442 

686,163 

633,595 

When compared to the expenditure and outputs of similar organisations at EU level, namely 
COFACE, AGE Platform Europe, Bureau Européen des Unions de Consommateurs (BEUC) 
and Finance Watch, Better Finance appears to work more efficiently, producing high-
quality  output  with  comparatively  fewer  resources.  These  findings  are  corroborated  by 
interviews, which found a consensus among stakeholders that, given the resources 
Better Finance has at its disposal, the organisation delivers very good value.  

In addition to the EU grant (which forms 59% of its income), Better Finance relies mainly 
on membership fees. The income from membership fees (25%) is significantly higher than 
other  income  sources  (e.g.  partnerships  or  donations  provide  13%).  No  significant 
diversification of funding occurred during the evaluation period – in fact, the share 
of income from other sources slightly decreased. 

2 Reported figures for the relevant grant period (1 May 2017 to 31 December 2017). 
3 While the reported figures  for 2017 cover eight months, the reported figures for 2018  cover 12  months. To allow  for easier 
comparison between the two years, the costs presented in this column are calculated by scaling the reported 2017 costs by 1.5.  

10 

 
 
 
 
Relevance 

The objectives of Better Finance are in line with the Union Programme 2017-2020 and the 
thematic coverage of Better Finance, as well as its membership, is highly relevant 
for  the  policies  addressing  financial  services.  The  activities  carried  out  by  Better 
Finance  in  2017  and  2018  are  seen  as  very  relevant  for  enhancing  the 
involvement  of  consumers  and  financial  services  end-users.  In  interviews  and 
surveys, member organisations indicated that the work of Better Finance complements 
their own work at both national and international levels. Similarly, interviewees in 
EU  bodies  reported  that  Better  Finance  is  needed  to  counterbalance  the  voice  of  the 
financial services industry.  

On  the  other  hand,  most  respondents  expressed  the  view  that  there  is  still  a  gap  in 
terms  of  the  needs  of  consumers  and  financial  end-users  that  needs  to  be 
addressed,  for  instance  regarding  manipulation  of  the  financial  system,  FinTech 
development  or  the  need  for  actively  managed  funds.  According  to  the  stakeholders 
consulted, it is crucial that the work of Better Finance continues.  

One issue, however, is that the membership of Better Finance does not cover all EU 
Member States: this is an area for improvement. 

Findings  of  the  evaluation  of  Finance  Watch’s  effectiveness, 
efficiency and relevance  

Effectiveness 

Overall, Finance Watch’s work during the evaluation period was effective in engaging end-
users  and  non-industry  stakeholders.  Finance  Watch’s  contributions  are  valued  by 
others  working  on  financial  regulation,  and  it  performs  a  coordinating  role  for 
national  activities  which  in  turn  involve  end-users  through  campaigns,  community 
events,  art,  rallies  and  street  actions.  Finance  Watch  responded  to  18  of  about  40 
relevant public consultations across both evaluation years, so there is potential to 
increase the organisation’s work in this area.  

Its publications are valued highly, as are its campaigns and events. Members and 
stakeholders  alike  considered  Finance  Watch’s  outputs  to  be  of  high  quality  and  its 
expertise  strong. Work done by  Finance Watch  was reported  by media outlets in 
both EU and non-EU countries.  

While the readability and understandability of  Finance Watch’s communications activities 
were rated highly, stakeholders expressed some reservations regarding the degree to 
which Finance Watch followed up after events, workshops and seminars. Overall, 
however, members and stakeholders valued its communications, especially its newsletters 
and cartoons. Finance Watch is also highly effective at using social media compared 
to similar organisations, even much larger organisations such as BEUC. 

Efficiency 

Finance Watch increased  its expenditure from  2017 to 2018 by about one-fifth, and the 
number of outputs reported in their annual reports also generally increased, as seen in the 
following table.  

11 

 
2017 

2018 

Activity area 

Direct 
costs in 
EUR4 

Direct 
costs 
scaled5 

Output description 

Direct 
costs in 
EUR 

Output description 

425,386 

638,079  Expert groups: 4 

832,665  Expert groups: 6 

Expertise and 
policy analysis; 
advocacy and 
public affairs 

Communi-
cations 

Membership 
coordination 
and 
development  

Strategic 
development 

Campaign6 

Reports: 2 
Briefings and papers: 
4 
Responses to public 
consultations: 7 
Public hearings: 3 
Public interventions: 
14 
Videos: 19 

Reports: 5 
Briefings and papers: 
9 
Responses to public 
consultations: 6 
Public hearings: 12 
Public interventions: 
48 
Videos: 20 
Cartoons and 
animations: 15 

196,495 

294,743  Events: 10 

299,418  Events: 10 

Press releases: 13 
Journalist 
interactions: 75 
Press coverage 
(unique articles): 81 
Newsletters: 5 
Blog posts: 4 
Webinars: 2 

Press releases: 17 
Journalist 
interactions: 92 
Press coverage 
(unique articles): 129 
Newsletters: 10 
Blog posts: 20 
Webinars: 2 
New website launched 

130,843 

196,265  Working groups: 1 

218,492  Working groups: 7 

Member updates: 22 
General assemblies: 2 
New members: 8 
Member surveys 

Member updates: 30 
General assemblies: 2 
New full members: 4 
New associate 
members: 16 
Membership surveys 

227,119 

340,679  Dialogue with existing 

99,666  Dialogue with existing 

donors 
New funding 
obtained: EUR 
303,657 
Various strategic 
activities for the ‘10 
years on’ campaign 

donors 
New funding 
obtained: EUR 
650,000 

N/A 

N/A 

307,942  Various strategic 

activities for the ‘10 
years on’ campaign 
Working group 
meetings: 143 
Campaign activities: 
136 

TOTAL 

979,843 

1,469,765 

1,758,183 

Overall, Finance Watch seems to operate as efficiently as most other comparable 
organisations. Some stakeholders raised concerns about costs related to moving offices 
and paying rent for two locations simultaneously for part of the evaluation period; another 

4 Reported figures for the relevant grant period (1 May 2017 to 31 December 2017). 
5 While the reported figures  for 2017 cover eight months, the reported figures for  2018  cover 12  months. To allow  for easier 
comparison between the two years, the costs presented in this column are calculated by scaling the reported 2017 costs by 1.5.  
6 The activity area ‘Campaign’ was introduced in 2018, incorporating  certain activities that were previously running under the 
activity area ‘Strategic development’. 

12 

 
 
 
 
 
 
issue mentioned was the organisation’s reliance on external consultants (although others 
highlighted  the  value  of  these  consultants  in  relation  to  the  quality  of  Finance  Watch’s 
research outputs).  

In  addition  to  the  EU  grant,  by  far  the  main  contribution  to  Finance  Watch’s  resources 
comes from third-party donors (over 90% of total non-EU resources). Finance Watch’s 
income  from  third-party  sources  is  significantly  higher  than  other  comparable 
organisations (including Better Finance). From 2017 to 2018, Finance Watch increased 
its funding from third parties by 19% while its overall budget only rose by 13% – thus the 
share  of  third-party  funding  increased.  Nevertheless,  diversification  of  funding  sources 
remains an ongoing challenge for Finance Watch, as the total number of its current donors 
is  small  and  the  share  of  income  from  membership  fees  is  lower  than  comparable 
organisations. 

Relevance 

The  objectives  of  Finance  Watch  are  in  line  with  the  objectives  of  the  Union 
Programme  2017-2020 and the thematic coverage of  Finance Watch,  as well  as 
its  membership,  is  highly  relevant  for  policy  discussions  on  financial  services. 
Stakeholders indicated that the work of Finance Watch remains crucial as few organisations 
represent  the  consumers’  voice  in  this  policy  area.  Stakeholders  also  recognised  the 
relevance of Finance Watch’s work to provide information on technical topics to non-
expert citizens in a transparent and understandable manner.  

However,  stakeholders  also  expressed  the  view  that  there  remain  some  areas  that 
should be addressed in greater depth in the future, such as new technologies and their 
impact on financial services, credit assessment or promoting the development of employee 
share ownership across Europe. On the other hand, there was a generally shared opinion 
among  stakeholders  that  in  order  to  remain  relevant  in  the  future  and  to  maintain  its 
unique role, Finance Watch should focus its activities to a greater extent in the coming 
years. This could be achieved by prioritising areas where it has strong expertise.  

The composition of Finance Watch’s membership was seen as relevant, as it brings together 
a large variety of civil society organisations. 

Findings on coherence for both beneficiaries 

The  Union  Programme  and  the  activities  of  Better  Finance  and  Finance  Watch  are 
coherent with and complementary to other EU measures, and the evaluation did not 
identify  major  overlaps  with  other  EU  initiatives.  Other  organisations,  such  as  BEUC 
COFACE and AGE Platform, support consumers’ rights and advocacy at EU level (also with 
EU financial support), but stakeholders agree that the work of Better Finance, Finance 
Watch  and  the  Union  Programme  is  unique.  Indeed,  the  two  organisations  balance 
the interests of large financial organisations, which are well represented at EU level, and 
this is coherent with overall EU policy principles.  

There  are  no  major  overlaps  between  the  actions  of  the  two  beneficiaries: 
stakeholders  perceive  that  the  two  beneficiaries  have  complementary  areas  of 
specialisation, with Better Finance focusing on issues such as pensions and investors and 
Finance Watch paying attention to financial inclusion, sustainable finance and FinTech.  

At national level, while some consumer organisations also work on financial matters, there 
are no examples of organisations with the same goals as Better Finance or Finance 
Watch: informing the development of finance  policies (in particular at EU level) from an 
end-user  and  consumer  perspective.  Stakeholders  agreed  that  similar  initiatives  are  not 
found at international level.  

13 

 
Findings on EU added value for both beneficiaries 

The  findings  show  that  there  is  added  value  from  the  activities  of  Better  Finance  and 
Finance Watch. Both have established and are maintaining an EU-level network, which is 
needed  to  coordinate  national  level  activities.  There  is  a  consensus  among 
stakeholders  that  the  issues  addressed  by  Better  Finance  and  Finance  Watch 
continue  to  require  action  at  EU  level.  Moreover,  there  are  numerous  topics  and 
emerging  issues  that  are  important  to  consumers  and  that  require  further  action  and 
visibility  at  the  EU-level,  for  instance  related  to  the  development  of  FinTech, 
technological innovation and sustainable finance. Given the growing number of EU 
legislative  instruments  that  address  retail  financial  services  and  directly  impact 
consumers and small investors, the two organisations could play an even greater role in 
the future.  

If  financial  support  for  the  two  organisations  were  withdrawn,  stakeholders 
expect that there would be negative consequences, in particular for consumers and 
financial  end-users.  Given  the  high  level  of  financial  dependence  of  Better  Finance  and 
Finance Watch on the grant from the Commission, withdrawing this support would severely 
limit their activities. As a result, the stakeholders consulted for this study expect that the 
consumer’s voice would be heard less and that this would create a significant gap in EU-
level policy discussions on financial services. 

14 

 
 
 
1  Introduction 

This  document  provides  the  final  report  of  the  ‘Evaluation  of  the  Union  Programme  to 
support  specific  activities  enhancing  the  involvement  of  consumers  and  other  financial 
services end-users in Union policy-making in the area of financial services for the period of 
2017-2020 (FISMA/2019/004/B)’, commissioned by the Directorate-General for Financial 
Stability, Financial Services and Capital Markets Union (DG FISMA) in July 2019.  

The report presents an overview of the results of the evaluation – structured by the five 
criteria of effectiveness, efficiency, relevance, coherence and EU added value – for the two 
beneficiaries of the Union Programme, Better Finance and Finance Watch.  

The report is structured as follows: 

•  This chapter presents the structure of  the  report, the  objectives and  scope  of the 

study, and an overview of the beneficiaries; 

•  Chapter 2 presents the evaluation methodology, including the intervention logic and 

the three data collection streams; 

•  Chapter  3  presents  the  findings  of  the  evaluation  of  Better  Finance  and  Finance 

Watch;  

•  Chapter 4 presents the conclusions of the study; 
•  The annexes contain: 

-  List of evaluation questions; 
-  Survey results for Better Finance and Finance Watch; 
-  List of reviewed sources; 
-  List of consulted stakeholders; 
-  List of publications linked to EU policy objectives.  

1.1  Objectives 

This evaluation analyses the activities of the two beneficiary organisations – Better Finance 
and  Finance  Watch  –  under  the  Union  Programme  and  assesses  the  impacts  of  these 
activities.  The  evaluation  establishes  the  extent  to  which  the  beneficiary 
organisations  met  the  objectives  foreseen  in  Regulation  2017/8267  governing  the 
Union Programme. The evaluation provides the European Commission with external input 
for an assessment of the activities carried out by the beneficiaries in 2017 and 2018 under 
the action grant agreements. 

1.2  Scope 

Following the Better Regulation Guidelines, the evaluation assesses the beneficiaries’ 
activities  and  impacts  in  terms  of  their  effectiveness,  efficiency,  relevance, 
coherence  and  EU  added  value.  The  evaluation  of  the  two  beneficiaries  supports  an 
assessment  of  the  overall  relevance  and  added  value  of  the  Union  Programme,  the 
effectiveness and efficiency of its execution, and the overall and individual effectiveness of 
the beneficiaries' performance, as required by the Regulation.  

•  Effectiveness:  the  evaluation  identifies  the  extent  to  which  the  activities  of  the 
beneficiaries  were  effective  in  achieving  their  objectives  and  the  extent  to  which 
their overall performance was effective; 

7  Regulation  (EU)  2017/826  of  the  European  Parliament  and  of  the  Council.  Available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R0826&from=EN  

15 

 
 
•  Efficiency:  the  costs,  outputs  and  overall  resource  use  of  the  beneficiaries  are 
assessed to evaluate cost efficiency of their operations and whether the benefits are 
achieved at a reasonable cost; 

•  Relevance: the analysis establishes the extent to which the original objectives for 
the financing of the beneficiaries still correspond to current needs or whether there 
are new challenges for financial end-users that remain unaddressed; 

•  Coherence:  complementarities  between  the  various  tasks  and  activities  of  the 
beneficiaries are assessed against their overall consistency with relevant EU policies; 
•  EU added value: the extent to which the intervention at EU level provides additional 

value is assessed against what could have been achieved at national level. 

1.3  Overview of the beneficiaries 

1.3.1  Better Finance 

Better Finance, the European Federation of Investors and Financial Services Users, is the 
product  of  successive  reorganisations  and  rebranding  of  pre-existing  European 
federations of investors and shareholders. Better Finance acts with the aim of promoting 
research, information and training on investments, savings and personal finances. It is a 
European-level organisation dedicated to the representation of individual investors, 
savers and other financial services users. Better Finance has nearly 50 independent, 
national  and  international  member  and  sub-member  organisations,  mainly  from  EU 
Member States, including financial consumer associations and several trade unions. Better 
Finance  provides  support  and  expertise  to  its  members,  advocacy  for  financial  users  to 
enhance  their  position  in  policy-making  and  promotes  awareness  to  enhance  financial 
literacy. 

Better  Finance  grew  from  an  initiative  of  Euroshareholders  and  the  Federation  of 
Independent Associations of Pension Savers (FAIDER), who in 2009 set up the European 
Federation  of  Investors,  with  the  name  EuroInvestors.  On  31  December  2012, 
EuroInvestors and Euroshareholders merged into EuroFinUse to reflect a wider scope and 
membership base. 2013 saw the motto of the organisation change to Better Finance for 
All, and finally after a General Assembly, the legal and working names were  changed to 
the  European  Federation  of  Investors  and  Financial  Services  Users  and  Better  Finance, 
respectively.  

Better Finance is a registered public interest organisation, located in Rue d’Arenberg 44, 
Brussels. The organisation has eight staff, organised into Executive, Research and Policy, 
and Finance and Administration areas, all overseen by the Managing Director, a board and 
the members.  

In 2017, Better Finance received EUR 292,394 and, in 2018, EUR 400,000 from the 
Union Programme action grant. 

1.3.2  Finance Watch 

In 2010, a number of Members of the European Parliament (MEPs) noted the increasing 
imbalance after the financial crisis, which made balanced policy-making more difficult and 
which, they feared, could threaten the democratic process in the longer term.  

Finance Watch was originally created as a counterweight to the financial industry 
lobby by representing the views of the general public and financial services end-users. It 
has  been  providing  core  technical  expertise,  as  well  as  lobbying  and  research,  to  the 
Commission and Parliament since its establishment.  

Finance Watch is an international non-profit association under Belgian law, first registered 
on 28 April 2011. It held its founding general assembly in Brussels on 30 June 2011. It is 
currently located in Rue Ducale 67, Brussels and has 12 members of staff.  

16 

 
Finance Watch’s core mission is ‘to strengthen the voice of society in the reform 
of financial regulation by conducting advocacy and presenting public interest arguments 
to  lawmakers  and  citizens.  Its  members  include  civil  society  organisations  and  experts. 
According to the most recent Strategic Plan 2017-2019, Finance Watch aims to carry out 
more national level activities through a network of national members (e.g. the recent 
creation of a Finance Watch entity in Germany and France). 

Finance  Watch  underwent  an  organisational  change  in  2017  and  is  currently  structured 
across  four  interlinked  divisions:  Research  and  Advocacy,  Campaigns  and  Projects, 
Communications and Networks, and Finance and Operations. Each division has at least one 
cross-cutting role (for example Research and Campaign Officer), intended to avoid siloed 
activity.  All  departments  are  overseen  by  the  Secretary  General,  the  board  and 
membership. 

In 2017, Finance Watch received EUR 993,010 and, in 2018, EUR 1,100,000 from 
the  Union  Programme  action  grant,  thus  almost  three  times  as  much  funding  as  Better 
Finance. 

17 

 
2  Evaluation methodology 

This section presents the evaluation methodology, including the intervention logic, desk 
research, online surveys and interviews. 

2.1  Intervention logic 

Figure 1 below presents the intervention logic of the Union Programme, showing the 
logical link between the problems identified, the objectives of the Union Programme, the 
EU intervention (input) and activities implemented (output), the expected results and long-
term impacts. The full list of evaluation questions is presented in Annex 5.1.

18 

 
Figure 1: Intervention logic of the Union Programme 

19 

 
Figure  2  presents  the  link  between  the  evaluation  criteria  and  the  needs, 
objectives, inputs, outputs, results and impacts. It served as an analysis tool and 
guidance throughout the evaluation process of the beneficiaries. 

Figure 2: Intervention logic with evaluation criteria  

2.2  Information sources 

This  evaluation  is  based  on  three  types  of  sources,  collected  and  assessed  via  three 
different  data  collection  streams:  desk  research,  online  surveys  and  stakeholder 
interviews.  These  data  collection  streams  were  included  in  this  methodology  to 
complement each other as each type of source had a slightly different focus.  

Desk research sources focussed mainly on the outputs of the beneficiaries. Stakeholder 
interviews  focussed  mainly  on  the  impact  of  the  beneficiaries’  outputs  and  the 
qualitative  perception  of  stakeholders.  The  surveys  focussed  on  both  outputs  and 
impacts in a quantitative manner. Using the three data  collection  streams allowed to 
triangulate and confirm findings from one source with findings from at least one of the 
other two sources. 

2.2.1  Desk research 

To evaluate the beneficiaries in a balanced way, a wide variety of sources  were used. 
Desk research started in July 2019 and continued for the full duration of the project. 
The primary sources, such as annual reports, work programmes, membership 
survey and other relevant documents demonstrating KPIs, were obtained from 
the  beneficiaries  themselves.  This  was  supplemented,  where  appropriate,  with  EU, 
international  and  national-level  literature,  including  media  articles,  to  provide 
further context to the analysis. The results of the previous evaluation in 2015 were also 
used  to  contextualise  the  activities  of  the  beneficiaries.  Almost  50  sources  were 
reviewed for this evaluation; the complete list of reviewed sources is listed in the 
Annex.  

It should be noted that despite efforts to broaden the scope of the review and asking 
stakeholders for suggestions of relevant sources, few references to both beneficiaries 
were  found  in  the  secondary  literature,  making  the  primary  literature  the  main 
source for the desk research. One potential risk of the heavy use of self-reported 

20 

 
 
information provided by beneficiaries, such as annual reports and grant reports, is that 
the  information  may  not  be  presented  in  an  objective  fashion.  Therefore,  these 
sources were supported with the online survey and stakeholder interviews to 
contextualise the information and facilitate independent analysis. 

2.2.2  Online survey 

Two online questionnaires were used to gather in-depth opinions from a wide pool of 
external stakeholders, one for Better Finance and another for Finance Watch. The aim 
of  the  survey  was  to  complement  the  information  collected  through  the  desk 
research and to gain more detailed insights into the experiences and perceived impacts 
of the beneficiaries’ activities.  

Both surveys were available for stakeholders to complete during an eight-week period, 
from  7  October  until  3  December  2019.  The  questions  were  tailored  by  stakeholder 
type,  with  the  following  five  groups  distinguished  within  the  survey:  member 
organisation  of  beneficiary,  banking  association,  consumer  organisation, 
national public authority, and EU public body. A major part of the survey questions 
was  routed,  meaning  that  each  stakeholder  group  was  presented  with  a  different, 
specifically tailored set of questions. As agreed with the European Commission and to 
facilitate  the  response  rate,  there  were  no  compulsory  questions  other  than  the 
identification question about the type  of  stakeholder represented.  This setup allowed 
respondents  to  skip  certain  questions  and  still  complete  the  survey.  Therefore,  the 
number of completed questionnaires does not correspond to the number of responses 
per  question:  each  figure  and  table  in  this  report  shows  the  number  of 
respondents for the specific question.  

Two separate online survey links were shared with different stakeholder groups. As set 
out in the project inception report, the target number for responses was 50. In a first 
step,  the  questionnaires  were  shared  with  309  different  stakeholders:  39 
member  organisations  of  Better  Finance,  84  member  organisations  and  individual 
members  of  Finance  Watch  (of  which  72  members  with  voting  rights,  the  remaining 
members being associate members without voting rights), 42 banking associations at 
national and European level, 77 consumer organisations, 35 national public authorities 
and 32 representatives of EU bodies. The target group of stakeholders was composed 
with the objective to have a balanced representation of all stakeholder groups in 
the responses.  

In order to mitigate the risk of a low number of responses, regular reminders were sent 
to stakeholders to increase the response rate and ensure input from each stakeholder 
group.  There  were  in  total  1798  participants  in  the  survey,  setting  a  participation 
rate  of  58%  and  surpassing  the  targeted  number  of  50  responses.  The 
responses  received  were  not  balanced  between  the  two  organisations,  however.  For 
Better  Finance,  there  were  69  survey  participants  (Figure  3).  As  for  the 
stakeholder  type  represented  by  the  participants,  there  were  18  responses  from 
national public authorities, 14 from member organisations of Better Finance, 10 from 
EU  public  bodies,  7  from  banking  associations  and  5  from  consumer  organisations. 
There were also 15 responses provided by stakeholders who identified themselves as 
‘other’ stakeholders, among them representatives from asset management companies, 
NGOs, citizens’ networks, and users of Better Finance studies. 

8 The total number of participants encompasses 89 complete responses and 90 partial responses – that is survey participants 
who identified themselves and/or only responded to some of the survey questions.  

21 

 
 
Figure 3: Responses to Better Finance Survey (N=69)9 

22%

20%

10%

7%

15%

26%

Member organisation of Better Finance

Banking / Finance Association 

Consumer Organisation 

National public authority 

EU public body

Other

For  Finance  Watch,  there  were  110  survey  participants  (Figure  4).  As  for  the 
stakeholder  type  represented  by  the  participants,  there  were  11  responses  from 
national public authorities, 81 from member organisations of Finance Watch, two from 
banking associations, one from consumer organisations and one from EU public bodies. 
There were also 14 responses provided by stakeholders who identified themselves as 
‘other’ stakeholders, among them partners of Finance Watch.  

The response rate from Finance Watch’s members was initially lower than that of Better 
Finance’s  Members.  One  potential  reason  for  this  initial  difference  is  that,  although 
Finance  Watch  has  more  members  than  Better  Finance,  the  structure  of  their 
membership is different. Better Finance is composed mainly of national shareholder and 
saver  organisations  which  specialise  in  the  same  topics  as  Better  Finance.  Finance 
Watch’s  membership  on  the  other  hand  is  looser,  counting  also  general  civil  society 
organisations  (such  as  trade  unions  or  international  NGOs  like  Transparency 
International  or  Oxfam)  with  lower  focus  on  the  financial  topics  covered  by  Finance 
Watch’s work. In addition, part of the membership are associate members that do not 
have rights to vote or take part in the general assemblies and are thus less involved in 
Finance Watch’s activity. In order to mitigate the initial low response rate from Finance 
Watch  members,  the  survey  was  reopened  for  a  limited  amount  of  time  (one  week) 
after the main period, and members of Finance Watch were approached with targeted 
reminders to participate in the survey. This increased the number of survey participants 
who are members of Finance Watch from 12 to 81. 

Figure 4: Responses to Finance Watch Survey (N=110) 

13%

1%
10%

1%

2%

74%

Member organisation of Finance Watch

Banking / Finance Association 

Consumer Organisation 

National public authority 

EU public body (EC, EP, ESAs) 

Other - Write In 

9 The survey did not contain information about the different amounts of grants received by Better Finance and Finance Watch. 
This could be seen as a limitation of the survey given that the grant amount is higher for one beneficiary than for the other. 
It  might  lead  to  a  certain  bias  in  terms  of  perceived  effectiveness  and  efficiency  of  beneficiaries.  Based  on  the  survey 
responses, this bias is not reflected in the answers provided by the respondents. In addition, the survey was complemented 
by the findings of the desk research and stakeholder interviews in the triangulation of findings. 

22 

 
 
 
 
2.2.3  Interviews 

Stakeholder interviews were based on a semi-structured format and they were directed 
to the same stakeholder groups as the targeted questionnaire, but with more focus on 
EU-level  stakeholders.  The  interview  questions  aimed  to  complement  information 
received  from  the  desk-based  research  and  online  survey,  as  well  as  to  fill 
remaining data or information gaps identified in the previous steps. 

The target number for interviews was 25. The interview process began in early October 
2019,  with  mapping  of  stakeholders  and  invitations  sent  to  stakeholders.  Most 
interviews, however, were carried out at the finalisation stage of the online survey, from 
the  end  of  November  until  the  middle  of  January  2020.  This  allowed  the  project 
team  to  adjust  the  interview  guide  to  address  any  gaps  in  information.  The 
team  reached  out  to  some  of  the  stakeholders  who  completed  the  survey  to  collect 
more  qualitative  feedback  about  the  perceptions  of  the  activities  carried  out  by  the 
beneficiaries.  One  challenge  was  in  identifying  suitable  interviewees  from  national 
public  authorities,  which  was  mitigated  by  asking  the  beneficiaries  for  support  with 
finding  the  right  contacts  from  national  public  authorities.  This  limitation  was  also 
encountered  with  EU  authorities  (European  Banking  Authority  (EBA)  and  European 
Securities  and  Markets  Authority  (ESMA)  for  example)  and  mitigated  by  thoroughly 
following up on email enquiries with telephone calls.  

In terms of the membership of both organisations, there was a risk that there would be 
limited knowledge within the member organisations regarding the internal processes of 
the  beneficiaries.  To  mitigate  this,  additional  follow-up  interviews  with  both 
beneficiaries were conducted in January 2020 to fill data gaps. 

A further  challenge stemmed from the  fact that the initially identified  national public 
authorities were not interested in participating in the study. In an attempt to mitigate 
the  effect  of  this,  the  aims  of  the  study  were  clearly  explained  to  the  authorities. 
Following the decision of some Member States not to collaborate, new Member States 
were selected for interview requests. In the end, the feedback was collected from two 
national  public  authorities  (Estonia  and  Italy).  Table  1  presents  the  number  of 
interviews by type of stakeholder. 

Table 1: Number of interviews by stakeholder group 

Stakeholder group 

Number of 
interviews 

EU bodies 

Banking / finance association 

Consumer organisation 

Member organisation (Finance Watch) 

Member organisation (Better Finance) 

Beneficiary 

National public authorities 

6 

3 

3 

3 

4 

4 

2 

Overall, 25 interviews were conducted with various stakeholders. The full list of 
interviewed stakeholders is provided in Annex 5.4.  

2.3  Comparison with other organisations 

Where  appropriate,  comparisons  are  drawn  between  the  two  beneficiaries,  or 
between  the  beneficiaries  and  comparable  consumer-focused  organisations. 
There are three organisations that are active at EU level and suitable for comparison 

23 

 
with  the  beneficiaries:  Bureau  Européen  des  Unions  de  Consommateurs  (BEUC)10, 
COFACE Families Europe11 and AGE Platform Europe12. These three organisations do not 
focus specifically on financial topics like Better Finance or Finance Watch, but they all 
cover  financial  topics  as  part  of  their  own  topical  focus,  which  makes  them  suitable 
comparators.  However,  they  also  differ  in  many  respects  from  the  two  Union 
Programme beneficiaries, for example in terms of type of funding (action grant vs. 
operating grant), total available budget, and size. These differences limit the extent to 
which the organisations can be compared and are taken into account throughout the 
report.  Table  2  presents  the  main  similarities  and  differences  between  the 
organisations,  based  on  publicly  available  sources  and  input  collected  from  the 
organisations themselves. 

Table 2: Comparison between the beneficiaries and comparator organisations 

Indicators 

Better 
Finance 

Finance 
Watch 

COFACE13, 14 

AGE 
Platform15 

BEUC16 

No. of employees 

6 full-time 
1-2 interns 

12 full-time 
4 consultants 

Around 6-7 

15 

Around 40 
(4 
financial 
services team) 

within 

No. of members 

Nearly 50 

85 

58 

104 

45 

Member 
coverage 

State 

35  (EU,  EEA, 
outside Europe) 

16 (Europe) 

23 (EU) 

Around  30  (EU, 
EFTA, 
outside 
Europe) 

32  (EU,  EEA, 
applicant 
countries) 

Funding 
programme 
policy work 

for 

Union 
Programme 
2017-2020 

Union 
Programme 
2017-2020 

Social 

Employment 
and 
Innovation 
(EaSI) 
2014-2017 

Rights,  Equality 
and  Citizenship 
(REC) 
Programme 

Consumer 
Programme 
2014-2020 

Co-financing 
rate of the grant 

60% 

60% 

80% 

80% 

N/A 

Source  of 
main grant 

the 

DG FISMA 

DG FISMA 

DG EMPL 

DG JUST 

DG JUST 

Type of EU grant  Action grant 

Action grant 

Operating grant  Operating grant  Operating grant 

EU grant amount 
/ EU funds (EUR) 

EUR 
(EU grant) 

400,000 

EUR  1.1  million 
(EU grant)  

EUR 
462,954 
(EU grant under 
VP/2015/010)17 

EUR  1.2  million 
(EU funds) 

EUR  1.6  million 
(EU 
grant) 
EUR  1  million  
(EU funds) 

Total  budget  in 
2018 (EUR) 

Around 
660,000 

EUR 

Around 
2 million 

EUR 

N/A 

Around 
1.4 million 

EUR 

Around 
5.5 million 

EUR 

10 BEUC, Official Website. Available at: https://www.beuc.eu/about-beuc/who-we-are  
11  COFACE  Families  Europe,  official  website.  Available  at:  http://www.coface-eu.org/about-2/what-is-coface-families-
europe/  
12 AGE Platform Europe, official website. Available at: https://www.age-platform.eu/about-age  
13 European Commission, Projects and organisations funded by the European Union – Programme for Employment and Social 
Innovation, 2016. Available at: http://ec.europa.eu/social/BlobServlet?docId=16922&langId=en  
14  European  Commission,  EU  Programme  for  employment  and  social  innovation  –  EaSI  (2014-2020).  Available  at: 
https://ec.europa.eu/social/main.jsp?catId=632&langId=en  
15 Based on stakeholder feedback and AGE Platform Europe website for 2018. 
16 BEUC, Financial Information for 2018. Available at: http://www.beuc.eu/about-beuc/financial-information 
17  European  Commission,  EU  Programme  for  employment  and  social  innovation  –  EaSI  (2014-2020).  Available  at: 
https://ec.europa.eu/social/main.jsp?catId=632&langId=en  

24 

 
 
 
3  Findings of the evaluation 

In this chapter, the findings of the evaluation of the two beneficiaries  are presented. 
The chapter starts with the findings for Better Finance, structured along the 
following  evaluation  criteria:  effectiveness,  efficiency  and  relevance.  Within 
each criterion, the findings for each evaluation question are discussed by demonstrating 
the combined results from the three data streams: desk research, online survey 
and interviews. Within  each  criterion, the  findings from the three data streams were 
analysed and triangulated to provide robust results. A similar approach is used in the 
presentation  of  findings  for  Finance  Watch,  described  in  the  second  section  of  this 
chapter.  In  sections  3  and  4  of  this  chapter,  the  combined  findings  for  both 
beneficiaries  are  presented  for  coherence  and  for  EU  added  value.  Given  the 
similarity of the input collected within data streams for coherence and EU added value 
for the beneficiaries, this approach was taken to avoid repetition in the presentation of 
findings. 

3.1  Evaluation of Better Finance: effectiveness, 

efficiency and relevance 

3.1.1  Effectiveness 

This subsection evaluates the effectiveness of Better Finance. It covers the following 
key topics: the effects of Better Finance’s work on end-users, stakeholders outside the 
financial  industry  and  policy  makers;  the  effects  of  Better  Finance’s  communication 
activities  and  research  outputs;  Better  Finance’s  approach  to  prioritisation  and 
monitoring; and any obstacles hindering Better Finance’s effectiveness (see Annex 5.1 
for further detail on the evaluation questions).  

3.1.1.1 

Better Finance is a highly effective vehicle for enhancing the 
involvement of those outside the financial services industry in the EU 
policy debate 

Better  Finance  has  supported  the  active  participation  of  stakeholders  in  the  financial 
services sector through research outputs, events and contributions to EU policy-making 
processes.  Due  to  the  composition  of  their  membership,  the  beneficiary  focuses  its 
attention  on  specific  types  of  end-users  (for  example,  individual  shareholders)  rather 
than  the  general  public.  The  majority  of  stakeholders  think  that  Better  Finance 
contributes  highly  to  involving  and  enhancing  the  participation  of  end-users  and  non-
industry stakeholders. 

The  desk  research  for  Better  Finance  showed  consistent  delivery  in  terms of  the 
number of campaigns and projects across the two evaluated years, with four 
in 2017 and four in 201818. The types of activities covered by Better Finance included 
conferences, European Supervisory Authority (ESA) meetings, consultation responses 
and  research  reports,  all  of  which  were  open  to  end-users  and  non-industry 
stakeholders.  In  2018,  for  example,  Better  Finance  recorded  nine  individual 
contributions from member organisations to positions, consultations and amendments 
to  legislation19.  In  terms  of  the  numbers  and  types  of  end-users  or  stakeholders 
involved in Better Finance activities, in 2017 and 2018, the membership covered 20 EU 

18 Better Finance website.  
19 Better Finance, Final Report, 2018, pp. 65-66. 

25 

 
 
countries  and  six  non-EU  countries  (Lebanon,  Cameroon,  Norway,  Iceland,  Turkey, 
Russia)20.  The  types  of  members  are  mainly  small  shareholder  and  investment 
associations, as well as  organisations looking at pensions from the  end-user side. In 
addition  to  its  membership,  Better  Finance  maintains  a  database  of  over  3,000 
journalists and other stakeholders.21  

Better  Finance  membership  composition  means  that  there  is  less  attention  to 
general  citizens  and  more  to  specific  types  of  end-users  and  other  non-
industry stakeholders (the membership, for example, contains many shareholders’ 
associations  whose  members  are  individual  shareholders),  although  each  of  the 
projects or campaigns did still have elements that involved a broader base of end-users 
or non-industry stakeholders to a certain extent. 

The  survey  results,  shown  in  Figure  5  and  Figure  6  indicate  that  the  majority  of 
respondents positively evaluated the contribution  of  Better Finance towards 
enhancing  active  participation  of  consumers,  other  financial  services  end-
users, as well as representatives within the EU policy area. Twenty-five out of 
30  respondents  (almost  85%)  perceive  Better  Finance’s  influence  as  ‘very  high’  or 
‘high’. When it comes to national stakeholders, about two thirds of respondents reported 
slightly or noticeably higher involvement as a direct link to Better Finance’s activities. 
The  other  third  of  respondents  was  however  neutral  to  this  question,  indicating  that 
they could not evaluate a direct link between Better Finance’s activities and involvement 
of  members  organisations/national  consumers.  Although  this  share  is  rather  high,  it 
can  be  explained  by  the  fact  that  Better  Finance  is  mainly  active  at  EU  level  and  its 
impact on national stakeholder consequently less direct. 

Figure 5: Better Finance’s contribution to enhancing the active participation of 
various stakeholder groups in financial services (N=30) 

3%

7%

7%

27%

57%

Very high 

High 

Medium 

Low 

I do not know 

20 Better Finance, Annual Report, 2017, p. 32; Better Finance, Annual Report, 2018, p. 32.  
21 Better Finance, Final Report, 2018, p. 31. 

26 

 
  
 
Figure 6: Influence of Better Finance’s activities on the level of involvement of 
members and national consumers (N=21) 

48%

5%

24%

24%

Noticeably lower involvement 

Neutral 

Slightly higher involvement 

Noticeably higher involvement 

Among the top three activities that contributed most to increased involvement of the 
various stakeholders within the financial services area the respondents mentioned the 
following:  participation  in  stakeholder  groups  of  EU  bodies,  events  and 
campaigns, and publications. On the other hand, the financial education tools were 
not seen as a strong contributor.  

Overall, the evidence shows that Better Finance has delivered outputs that have 
positively  affected  the 
involvement  of  end-users  and  non-industry 
stakeholders.  It  is  also  important  to  note  that  the  activities  of  Better  Finance  have 
ensured that non-industry stakeholders feel as though they are involved in the policy 
process, which is an important aspect of good policymaking. Naturally, the direct impact 
on EU level stakeholders is higher than on national stakeholders. 

3.1.1.2 

Better Finance is effective in providing policy makers with views 

of financial end-users 

During the evaluation period, Better Finance consistently participated in major relevant 
regulatory debates at European  level, by way of  consultation responses, key meetings 
and interventions, events, discussions and amendments to specific legislation. 

The  organisation  prepared  24  consultation  responses  in  2017  and  30  responses  in 
201822.  When  looking  at  the  total  number  of  potential  consultations  to  which  Better 
Finance could have  responded, the coverage of relevant consultations appears good. 
DG FISMA, for example, had 15 consultations across the two years, while ESMA had 25 
across 2017 and 2018.  

Better  Finance  was  also  heavily  involved  in  the  ESA  and  European  Commission’s 
advisory  groups  looking  at  financial  regulation,  with  20  individuals  representing  14 
organisations  and  having  25  seats  in  13  ESA/Commission  forums  in  201723.  This 
number decreased slightly in 2018, with 17 individuals representing 12 organisations. 

22 Better Finance, Final Report, 2017, p. 12.  
23  Full  list:  Financial  Services  User  Group  (FSUG),  Expert  Group  on  Automatic  Exchange  of  Information  (DG  TAXUD), 
European  Finance  Reporting  Advisory  Group  (EFRAG),  Corporate  Bond  Market  Liquidity  Expert  Group,  European 
Crowdfunding Stakeholder Forum, Expert  Group on Technical Aspects of Corporate  governance Processes, Securities and 
Markets  Stakeholder  Group  (ESMA),  Secondary  Markets  Standing  Committee  Consultative  Working  Group  (ESMA), 
Investment  Management  Standing  Committee  Consultative  Working  Group  (ESMA),  Corporate  Reporting  Standing 
Committee Consultative Working Group (ESMA), Banking Stakeholder Group(EBA), Insurance and Reinsurance Stakeholder 
Group (EIOPA) and Occupational Pensions Stakeholder Group (EIOPA. Better Finance, Annual Report, 2017, p. 22. Available 
at: https://betterfinance.eu/publications/annual-reports/ 

27 

 
 
 
However, the number of seats held went up by one, to 26, and one further vice-chair 
position in the Occupational Pensions Stakeholder Group of the European Insurance and 
Occupational  Pensions  Authority  (EIOPA)24.  Better  Finance  also  negotiated  observer 
status  with  speaking  rights  for  the  European  Financial  Reporting  Advisory  Group 
(EFRAG) from 2017-2020. In addition to consultation responses and sitting on advisory 
boards, Better Finance represented its views to policy makers by speaking at various 
events  in  2017  and  2018,  with  a  total  of  50  speaking  engagements  for  a  variety  of 
organisations,  such  as  think  tanks,  the  European  Parliamentary  Research  Service 
(EPRS), banks, financial services companies and NGOs. The topics addressed included 
financial literacy, consumer protection, insurance and pensions25. In terms of legislative 
outcomes, Better Finance reported that in 2018, amendments to the Packaged Retail 
and Insurance-based Investment Products (PRIIPs) and Pan European Pension Product 
(PEPP) Regulations were adopted in at least seven instances26.  

The  desk  research  found  that  Better  Finance  took  positions  on  a  number  of 
relevant issues, predominantly at EU level. In 2018, for example, Better Finance 
spoke  at  two  European  Parliament  committee  hearings  and  three  events  of  the 
European  Parliamentary  Financial  Services  Forum  (EPFSF)27.  It  should  be  repeated 
though  that  Better  Finance  sits  on  the  FSUG,  and  so  its  presence  at  this  particular 
hearing  is  not  unexpected.  Additionally,  Better  Finance  spoke  at  one  hearing  in  the 
French Parliament. It was also invited to speak at a number of hearings in 2017, for 
example  in  the  European  Parliament  on  the  PEPP  proposal28.  These  meetings  and 
hearings  were  supported  by  research  and  evaluation  from  Better  Finance’s 
reports and consultation responses29. Better Finance has been able to demonstrate 
clear  impact  from  these  activities,  for  example  its  2017  Pension  Report  triggered  a 
specific Capital Market Union (CMU) Action from the European Commission, which was 
formally launched in October 201730. A briefing paper, ‘A major enforcement issue: the 
mis-selling  of  financial  products’,  had  sufficient  impact  to  trigger  the  European 
Parliament’s Committee on Economic and Monetary Affairs (ECON Committee) to launch 
a series of five studies on the topic31. This activity also triggered proposed amendments 
to  the  European  Market  Infrastructure  Regulation  (EMIR),  ESA  review,  PEPP  and  a 
number of other pieces of financial regulation. 

Regarding the impact of these activities on policy makers, the survey results indicate 
that 90% of the respondents confirm that Better Finance is effective in providing policy 
makers with information. The majority of respondents (12 out of 17) confirmed 
that they became more informed of the perspective and needs of financial end-
users.  The  stakeholders  valued  most  the  responses  to  EU  public  consultations, 
publications and participation in stakeholder groups of EU bodies. These activities, as 
well as events and campaigns organised by Better Finance, were mentioned among the 
activities that had the highest impact on the EU decision-making process.  

According  to  the  survey  respondents  (Figure  7),  the  impact  of  Better  Finance  on  EU 
decision  making  was  much  higher  than  at  the  national  level  –  three  quarters  of  the 
respondents saw noticeable impact at EU level, but only half of the respondents said 
the same for the national level. This is not surprising though given the fact that Better 
Finance is mainly active at European level. 

24 Better Finance, Final Report, 2017, p. 16; Better Finance, Final Report, 2018, p. 23. 
25 Better Finance, Final Report, 2017, p. 15; Better Finance, Final Report, 2018, pp. 31-32. 
26 Better Finance, Final Report, 2018, pp. 22-35. 
27 Better Finance, Final Report, 2018, pp. 30-32. 
28 Better Finance, Final Report, 2017, p. 6. 
29 As previously mentioned, a total of 10 reports and 59 consultation responses were published across the two years. 
30 Better Finance, Final Report, 2017, pp. 4-10. 
31 One example of this series of studies is: Kern, A., Marketing, Sale and Distribution: Mis-selling of Financial Products, Study 
for the European Parliament, 2018. 

28 

 
 
Figure 7: Impact of Better Finance on decision-making within financial services; left: 
at EU level, right: at national level (N=17, 16) 

12%

6%

6%

35%

41%

25%

25%

19%

25%

6%

High impact 

Medium 
impact 

Some 
impact 

No impact 

I do not 
know 

These results do come with the caveat that only six to eight (depending on the question) 
responses  to  these  survey  questions  came  from  policy  makers.  Therefore,  these 
responses  are  to  some  extent  the  outside  perception  of  stakeholders  not  directly 
involved in the decision-making process. The responses are however similar between 
the  different  stakeholder  groups,  hinting  that  the  outside  perceptions  are  generally 
realistic.  In  addition,  interviewed  policy  makers  also  confirmed  that  work  of  Better 
Finance has had a noticeable impact on legislation and forms a key part of the overall 
narrative since 2008 in this policy area. However, it should be noted that the majority 
of  interviewed  stakeholders  recognised  that  improvements  in  financial  policy-making 
during  the  evaluation  period  was  due  to  the  collective  efforts  of  multiple 
organisations,  including  Better  Finance,  Finance  Watch,  BEUC,  COFACE  and  AGE 
Platform Europe, and singling out contributions of individual organisations is often not 
possible due to the complexity of the decision-making process. 

3.1.1.3 

Overall, Better Finance has been effective in its communication 

activities; however, 2017 was a stronger year than 2018 for some 
indicators 

During  the  two  years  of  the  evaluation  period,  the  reach  of  Better  Finance’s 
communication  activities  varied.  Certain  communication  activities  declined  between 
2017 and 2018. Stakeholders nonetheless feel that they are very aware of the activities 
and the communication work is highly valued. 

Better  Finance  has  a  communications  strategy  and  uses  social  media  and  online 
websites to share information with its member organisations and the wider public. For 
external  communications,  Better  Finance  produces  various  videos,  policy  papers, 
organises  events  and  press  conferences  and  regularly  shares  a  newsletter.  This  is 
demonstrated by the following:  

•  The number of events was consistent across the two evaluation years, with seven 

in 2017 and seven in 201832;  

•  Three events in each year were outside Brussels (Sofia, London, Malta in 2017 

and Sofia, London, Wiesbaden in 2018)33;  

32  Better  Finance,  Annual  Report,  2017,  p.  24;  Better  Finance,  Annual  Report,  2018,  p.  24.  Available  at: 
https://betterfinance.eu/publications/annual-reports/ 
33  Better  Finance,  Annual  Report,  2017,  p.  23;  Better  Finance,  Annual  Report  p.  24.  Available  at: 
https://betterfinance.eu/publications/annual-reports/ 

29 

 
 
 
•  Attendee numbers at Better Finance events showed a large increase, from 460 

in 2017 to 1,321 in 201834; 

•  Over 200 media attendees came to events in 2018; 
•  171 media articles in 2017, this declined by over 50% to about 80 media articles 

in 201835;  

•  The  number  of  research  reports  downloaded  from  the  Better  Finance  website 
declined by 45% between 2017 and 2018 – this steep decline is an issue that 
should require Better Finance to assess the underlying reasons and take 
steps to increase download numbers36;  

•  Declines can also be seen when looking at the website hits and newsletter mailing 
list,  with  a  2%  decrease  in  the  size  of  the  mailing  list  in  2018,  which  Better 
Finance  attributes  to  the  entry  into  force  of  the  General  Data  Protection 
Regulation (GDPR), and a 19% decline in website hits37.  

• 

•  Social  media  followers  saw  an  increase  across  the  board  in  2018  compared  to 
2017, with a 42% rise in LinkedIn followers and 27% in Twitter followers38.  
In  terms  of  better  informing  the  wider  public,  meetings  with  national  member 
organisations are  seen by Better Finance as  crucial because they are  the  ones 
who have direct contact with this audience. Better Finance therefore held regular 
meetings with these organisations (13 such meetings in 2018)39. 

In  general,  Better  Finance  makes  very  little  use  of  online  and  social  media 
compared  to  other  organisations.  For  example  COFACE,  which  is  comparable  to 
Better  Finance  in  terms  of  size  and  funding,  has  about  six  times  as  many  Facebook 
followers,  three  times  as  many  Twitter  followers  and  three  times  as  many  YouTube 
subscribers.40  During  the  evaluation  period,  Better  Finance  has  only  published  three 
videos on YouTube, which on average received only nine views. There is clearly large 
room for improving communication via social media. 

Stakeholders  are  aware  of  these  communication  activities,  according  to  the 
survey  (Figure  8)  where  63%  of  respondents  reported  high  awareness  and  another 
20% reported medium awareness. Only two out of 30 respondents said they are not 
aware.  Noticeable differences  in  terms  of  the  level  of  awareness  were  present  for 
different  stakeholders,  with  consumer  organisations  and  banking  associations  having 
the  strongest  knowledge  and  Member  State  public  bodies  having  the  least 
understanding of the work carried out by Better Finance.  

34 Better Finance, Final Report, 2017, p. 24; Better Finance, Final Report, 2018, pp. 40-44. 
35 Better Finance, Final Report, 2018, pp. 25, 41-46; Better Finance, Final Report, 2017, p. 25. 
36  Better  Finance,  Annual  Report,  2017,  p.  25;  Better  Finance,  Annual  Report,  2018,  p.  25.  Available  at: 
https://betterfinance.eu/publications/annual-reports/ 
37 Better Finance, Final Report, 2018, pp. 37-50. 
38 Better Finance, Final Report, 2018, pp. 37-50. 
39 Better Finance, Final Report, 2018, pp. 56-57. 
40 Comparison drawn based on official follower/subscriber numbers available in the organisations’ social media accounts. 

30 

 
 
Figure 8: Level of awareness of the communication activities of Better Finance 
(N=30) 

3%

7%

7%

20%

63%

High awareness 

Medium awareness 

Some awareness 

No awareness 

I do not know 

In particular the communication in the area of press releases, newsletters and website 
is valued (Figure 9).  

Figure 9: Better Finance’s communication activities to expert and non-expert 
audiences (N=22) 

Very low  

Somewhat 
low  

Neutral  

Somewhat 
high  

Very high  

Press 
releases  

Social media 
posts  

0% 

0% 

4.5%  

31.8%  

63.6%  

4.8%  

0% 

14.3%  

66.7%  

14.3%  

Website  

4.8%  

4.8%  

4.8%  

42.9%  

42.9%  

Newsletters  

0% 

4.8%  

14.3%  

33.3%  

47.6%  

Videos  

5.3%  

10.5%  

26.3%  

21.1%  

36.8%  

Cartoons  

11.1%  

11.1%  

22.2%  

27.8%  

27.8%  

The quality of events organised by Better Finance was rated overall as ‘very high’ by 
the respondents,  referring to both the panellists  present and to the  relevance of the 
topics discussed. The same accounts for the performance of Better Finance as speaker 
at  events  organised  by  third  parties.  The  quality  of  the  follow-up  was  described  as 
‘somewhat  high’  by  45%  of  the  respondents,  indicating  some  minor  room  for 
improvement. The stakeholders mentioned the following events as being most useful 
for  them:  A  New  Deal  for  European  and  Romanian  Financial  Services  Users  Better 
Finance 10th Year Anniversary Event, International Conference Investor empowerment 
in  the  digital  age,  conferences  on  CMU  and  shareholder  rights,  annual  networking 
events. 

In addition to simple awareness, the vast majority of stakeholders (20 out of 22) also 
indicated  that  they  consider  the  content  of  Better  Finance’s  communication  activities 
‘useful’  or  ‘very  useful’  with  regard  to  their  information  needs.  Nearly  75%  of  the 
respondents  (20  out  of  27)  took  the  communication  activities  of  Better 

31 

 
 
 
 
 
 
 
 
 
Finance into consideration as part of their policymaking and implementation 
efforts. Another 5 respondents remained neutral to this question. 

Consumer  organisations who  are not members  of Better Finance  expressed the view 
that they are satisfied with external communication, i.e. that the content is well 
presented in terms of design and graphics and the message is transparent to external 
users. They value the regular updates about events and press releases as it allows them 
to  stay  up to  date  with the industry trends.  Similarly,  member  organisations  are 
satisfied with the internal communication of Better Finance and highlighted that they 
receive regular updates via email, as well as social media channels. The members also 
noted the high level of responsiveness of Better Finance and they normally receive 
responses to their emails within a day.  

Survey results show that Better Finance effectively communicated its position to 
EU  institutions  (according  to  19  out  of  32  responses  very  effectively,  and  to  6 
responses effectively). This is corroborated by responses collected from the interviews, 
which  indicate  that  Better  Finance  played  an  important  role  in  key  EU-level 
bodies,  such  as  the  European  Parliament  and  ESAs.  They  actively  participated  in 
informal coalitions involved in drafting European Parliament reports and amendments 
on ESA reform, for example. The feedback collected is that Better Finance campaigns 
were  efficient  and  simplified  complex  topics  into  transparent  messages  from  the 
consumer  perspective.  One  of  the  stakeholders  consulted  indicated  that  Better 
Finance’s impact is particularly visible in the European Parliament. Many stakeholders 
pointed out that the technical knowledge of Better Finance is viewed as an important 
counterweight  to  the  opinions  of  industry.  Nevertheless,  one  interviewed  policy 
stakeholder  noted  that  there  is  still  an  imbalance  of  representation  –  and  therefore 
effectiveness – of the beneficiary compared to industry stakeholders, who have much 
more resources at their disposal. 

Stakeholder views regarding the impact of Better Finance on national institutions was 
more  muted.  Fewer  survey  respondents,  compared  to  the  similar  question  about  EU 
institutions,  agreed  that  Better  Finance  communicated  effectively  to  national 
institutions (according to 7 out of 28 responses very effectively, and to 11 responses 
effectively). Similarly, nearly one-third of survey respondents (5 out of 16 responses) 
stated that had only some or no knowledge of Better Finance’s position on European 
issues (Figure 10) – with four of these five responses coming from national authorities.  

Figure 10: Knowledge of Better Finance's position/perspective on European issues in 
the area of financial services (N=16) 

6%

31%

25%

37%

I have no knowledge on the 
beneficiary's stance on this topic 

I have some knowledge on the 
beneficiary's stance on this topic 

I have good level of knowledge 
on the beneficiary's stance on 
this topic 

I am fully aware of the 
beneficiary's stance on this topic 

As already mentioned in the previous  sections, Better Finance is mainly active at  EU 
level,  which  is  why  the  lower  impact  on  national  authorities  is  per  se  not  surprising. 

32 

 
 
Nevertheless,  Better  Finance  might  want  to  assess  whether  their  communication 
activities to national authorities (also by using their national member organisations as 
multiplicators) is sufficient. One of Better Finance’s member organisations reported that 
the  activity  of  the  beneficiary  did  help  them  in  some  cases  at  the  national  level. 
This stakeholder described how they attended a meeting with the UK government about 
the  Shareholder’s  Rights  Directive.  They  were  better  prepared  for  this  national-level 
meeting as they had already collected insights from Better Finance about the topic. 

3.1.1.4 

Better Finance delivered both quantitative and qualitative 
expertise during the evaluation period, which was overwhelmingly 
considered useful 

Better Finance’s outputs rose slightly in 2018 compared to 2017, delivering significant 
expertise in the area of financial services across the two evaluation years. The expertise 
provided by Better Finance is frequently used by policy makers and other stakeholders, 
such  as  other  EU-level  consumer  organisations  or  the  beneficiary’s  member 
organisations. 

In  addition  to  10  full  research  reports  and  59  consultation  responses  across  the  two 
years, Better Finance published five position papers in 2017 and eight in 201841. The 
14  events42  organised  across  the  two  years  provided  the  following  qualitative  and 
quantitative expertise:  

•  A conference on regulatory and insurance technology;  
•  A press conference for its annual pensions reports;  
•  A conference for the EU Shareholders’ Rights Directive and a private meeting on 

the Financial Reporting Council;  

•  A conference on financial services in Europe;  
•  A  financial  advice  seminar  and  a  conference  on  Equity  Financing  of  the  EU 

economy; 

•  A workshop on the Insurance Distribution Directive;  
•  A workshop on investor education;  
•  A conference on digitalisation and investor empowerment;  
•  A pension report launch;  
•  A private meeting on the Financial Reporting Council;  
•  A conference on European CMU;  
•  A conference on the future of European Capital Markets43. 

The desk research showed that the expertise provided by Better Finance is frequently 
used  by  policy  makers  and  other  stakeholders.  In  2018,  there  was  a  284% 
increase in the number of speaking engagements to which Better Finance was invited 
(and  accepted)  compared  to  201744.  This  was  combined  with  more  than  251  media 
citations  across  the  two  years,  in  a  variety  of  languages  and  with  national  and 
international  readership45.  More  specifically,  legislative  impact  can  be  seen  in  the 
number of amendments to specific proposals for legislation, for example in 2017 on the 
topic  of  the  CMU,  Better  Finance  reported  that  its  work  led  to  amendments  on 
transparency  of  costs  and  performance,  Investment  Savings  Account  best  practice, 
employee  share  ownership  schemes  best  practice,  and  five-year  past  performance 
mandatory disclosure in the PEPP Regulation proposal46. Similar impact can be seen in 

41 Better Finance, Final Report, 2017, p. 14; Better Finance, Final Report, 2018, p. 22. 
42 See page 20 for locations of events.  
43  Better  Finance,  Annual  Report,  2017,  p.  23;  Better  Finance,  Annual  Report,  2018,  p.  24.  Available  at: 
https://betterfinance.eu/publications/annual-reports/ 
44 Better Finance, Final Report, 2017, p. 15; Better Finance, Final Report, 2018, pp. 31-32. 
45 Better Finance, Annual Report, 2017, p. 23; Better Finance, Annual Report, 2018, p. 25. 
46 Better Finance, Final Report, 2017, p. 19.  

33 

 
 
2018, for example the ECON Committee included a collective redress provision and an 
annual fee cap of 1% for the basic PEPP47.  

A 2018 survey conducted by Better Finance among its members reported that 84% of 
respondents rated Better Finance’s output as 'Excellent', with the remaining 16% rating 
their  performance  as  'Good'48.  The  survey  results  from  this  study  corroborate  Better 
Finance’s  own  member  survey,  showing  that  the  majority  of  stakeholders  find  the 
research work and position papers of Better Finance useful (Figure 11) and that Better 
Finance’s  research  work,  policy  papers,  responses  to  consultations  and  studies 
completely their needs at time of release completely or somewhat (Figure 12).  

Figure 11: Level of usefulness of Better Finance’s research work and position papers 
(N=31) 

6%

6%

13%

19%

55%

Very high 

High 

Medium 

Low 

I do not know 

Figure 12: Degree to which Better Finance's research work, policy papers, responses 
to consultations, studies, served the needs of the stakeholders (N=32) 

34%

3%

13%

50%

Irrelevant for serving needs at 
time of release 

Neutral for serving needs at 
time of release 

Somewhat fulfilling needs at 
time of release 

Completely fulfilling needs at 
time of release 

The  survey  responses  assessing  the  position  papers  of  Better  Finance  indicate  the 
general high level of satisfaction from the respondents (Figure 13, Figure 14). The 
stakeholders  described  the  papers  as  easy  to  understand  (7  out  of  14  responses  for 

47  Eatock,  D.,  Framework  for  a  pan-European  personal  pension  product  (PEPP),  European  Parliament  Research  Service 
at: 
Briefing, 
http://www.europarl.europa.eu/RegData/etudes/BRIE/2017/608740/EPRS_BRI%282017%29608740_EN.pdf 
48 Better Finance, Annual Membership Survey, 2018, p. 11. 

Available 

2018. 

34 

 
 
 
 
very  high  and  4  responses  for  somewhat  high)  and  useful  during  negotiations  (5 
responses for very high and somewhat high each). In terms of usefulness of the papers 
to base amendments on, 9 out of 14 respondents described them as somewhat high or 
very high. The responses to consultations by Better Finance were highly appreciated by 
the respondents, with the vast majority describing them as very high or somewhat high 
in  terms  of  being  understandable,  reflecting  points  of  view  of  the  members,  and 
providing relevant input for policy makers. Only one respondent rated the usefulness 
of the output as low/very low. 

Figure 13: Evaluation of Better Finance’s position papers (N=14) 

Very low   Somewhat 

Neutral  

low  

Somewhat 
high  

Very high  

Understandable 

0% 

  0% 

 21.4% 

 28.6% 

 50.0% 

Useful during 
negotiations 

Useful to base 
amendments 
on 

7.1% 

  0% 

 21.4% 

 35.7% 

 35.7% 

7.1% 

  0% 

 28.6% 

 35.7% 

 28.6% 

Figure 14: Evaluation of Better Finance’s responses to consultations (N=26) 

Very low  

Somewhat 
low  

Neutral  

Somewhat 
high  

Very high  

Understandable    

0%  

   0%  

  16.0%  

  32.0%  

  52.0%  

Reflecting 
points  of  view 
of the members 
to represent an 
in-depth view  

Providing 
relevant 
for 
makers  

input 
policy 

3.8%  

   0%  

  15.4%  

  26.9%  

  53.8%  

0%  

  4.0%  

  12.0%  

  28.0%  

  56.0%  

All  of  the  stakeholders  interviewed  agreed  that  Better  Finance  delivered  high  quality 
expertise through its research work, policy papers and other analytical work in the area 
of  financial  services  in  2017  and  2018.  Among  the  specific  topics  mentioned  as 
particularly  useful  were  pension  returns  and  investments  (an  annual  report 
which  some  referred  to  as  a  staple  of  the  financial  policy  calendar),  pan-
European pensions products, closet indexing of funds and robo-advice.  

It was mentioned by some consumer organisations that the real added value for them 
is the work of Better Finance in areas where consumer organisations are not 
extensively involved. That allows them to gain expert knowledge and share workload 
between various organisations, as well as directly reuse Better Finance’s output without 
a significant vetting process. The stakeholders indicated that they have a high level 
of  confidence  in  the  research  work  delivered  by  Better  Finance  and  that  the 
dissemination  of  expertise  between  them  and  Better  Finance  is  very  important.  One 
member particularly valued Better Finance for its strong position in raising awareness 
of negative market practice in the area of closet indexing.  

Member  organisations  and  consumer  organisations  mentioned  that  they  use  the 
research output of Better Finance for lobbying purposes and their own advocacy work 

35 

 
 
 
 
 
 
  
  
by either directly  reusing  its research papers,  graphics and campaigns or by quoting 
Better Finance during their discussions with industry. One of the member organisations 
stated that it used the PEPP research for its own analysis and recommendations at 
national  level.  Several  stakeholders,  including  from  the  European  Commission, 
emphasised that they rely heavily on Better Finance’s work on pensions funds, and the 
annual report was also quoted in the Financial Times. Member organisations also value 
the  numerous  events  organised  by  Better  Finance,  which  are  useful  for  networking 
purposes. The work of Better Finance is also a good reference point for stakeholders 
to stay up to date with industry trends.  

There  was  a  point  raised  that  Better  Finance  relies  heavily  on  its  member 
associations  to  deliver  research  work,  which  could  be  perceived  as  a  weakness. 
They  tend  to  appoint  experts  from  national  associations  that  then  act  on  its  behalf. 
However, given  its limited staff, such an approach is understandable and in line with 
efficient  budgeting  principles.  Overall  Better  Finance  has  maintained  a  consistent 
delivery of expertise across the evaluation period and produced a slight increase in 
published  expertise,  which  contributed  to  its  strong  overall  effectiveness  when 
measured against the purpose of the grant. 

3.1.1.5 

During the evaluation period, Better Finance had set 
prioritisation methods and a performance monitoring system 

Better  Finance  has  a  framework  of  decision-making  that  supports  the  prioritisation  of 
activities and involves contributions from a variety of levels. The performance monitoring 
system should be further formalised and more frequently applied, and the organisation 
is already moving in this direction. 

During  the  evaluation  period,  priorities  and  activities  were  put  to  members  via  an 
annual  plan  at  the  General  Assembly  organised  on  annual  basis;  the  plans  also  go 
through the Board and the Action Committee. These annual priorities are devolved from 
a larger five-year strategy, which is also approved by the Board and General Assembly. 
During  the  year,  more  concrete  steps  are  taken  for  planning  within  specific  areas  of 
their activity. As a member of many high-level expert groups, Better Finance also sets 
priorities in line with the most pressing issues raised in these groups. In general, the 
members reported that they are satisfied with such an approach and indicated that 
the activities and priorities are  often adjusted  on an ad hoc basis by  Better Finance, 
depending  on  the  needs  of  the  members.  This  approach  was  confirmed  by  Better 
Finance during interviews. The members see Better Finance as proactive and flexible 
in adjusting  its annual planning if, for instance, it believes that an issue in a specific 
Member  State  is  growing  and  becoming  an  EU-level  problem.  In  such  cases,  Better 
Finance strives to react quickly and raise these points in the European debate.  

In contrast to feedback from the majority of member organisations, one member did 
say  that,  although  members’  input  is  collected,  their  actual  involvement  in  certain 
decisions, for example the choice of where events are held, is rather limited. This is 
to be  expected, however,  considering the number of members  of Better Finance and 
the diversity of countries in which those members are based.  

The stakeholders representing member organisations indicated in the interviews that 
there is a well-developed feedback and performance monitoring system in place. 
There is a formal feedback channel, organised via survey (since 2018), board meetings 
and general meetings and an ad hoc channel of tailored emails after certain events and 
campaigns. There is also an informal method of communication, which allows members 
to provide their feedback via email or phone without issue. In general, the members 
of  Better  Finance  expressed  the  view  that  they  are  routinely  asked  if  Better  Finance 
should focus more on certain topics and that their input was included in the majority 
of cases.  

36 

 
3.1.1.6 

The obstacles hindering Better Finance’s effectiveness are 

typical of an organisation of its nature 

Perceived obstacles to Better Finance’s effectiveness were a lack of funding, expertise, 
scoping areas, advocacy and research work. However, aside from funding, none of these 
other obstacles were strong enough to cause concerns about effectiveness. They should 
be kept in mind and monitored, although they appear to be largely associated with Better 
Finance’s size and policy area. 

Based  on  the  survey  results  (Figure  15),  lack  of  funding  was  identified  as  the  key 
obstacle  for  Better  Finance  in  reaching  its  set  objectives.  It  was  indicated  by  one 
stakeholder that a small budget means that Better Finance has very limited resources 
to promote itself and to reach out to Member State organisations. The level of expertise, 
scoping  area,  advocacy  work  and  research  work  were  not  perceived  by  most  as 
potential obstacles. However, it should be noted that this was not universal and there 
were minority views that saw these areas as potential obstacles to effectiveness, but 
these views were largely contained to two organisations.  

Figure 15: Potential obstacles for Better Finance in reaching set objectives (N=33) 

Very low 

Somewhat 
low  

Neutral  

Somewhat 
high  

Very high  

Lack 
funding  

Lack 
expertise  

of 

of 

Poor 
scoping/focus 
areas  

Poor 
advocacy 
work  

Poor research 
work  

15.2%  

3.0%  

18.2%  

24.2%  

39.4%  

29.6%  

29.6%  

25.9%  

3.7%  

11.1%  

25.9%  

25.9%  

25.9%  

14.8%  

7.4%  

29.6%  

25.9%  

18.5%  

7.4%  

18.5%  

38.5%  

15.4%  

26.9%  

3.8%  

15.4%  

Better  Finance’s  delay  in  committing  budget  to  projects  was  reported  by  the 
stakeholders in the interviews as the main external obstacle to reaching set objectives. 
This,  in  turn,  was  linked  to  Better  Finance’s  high  dependence  on  the  European 
Commission  and  the  Commission’s  delay  in  paying  the  grant  during  the  evaluation 
period. Even though the delays were linked to the process within the Commission, this 
had  an  impact  on  the  members  of  Better  Finance,  with  one  interviewee  saying  that 
Better Finance had temporarily put certain projects on hold due to the delay in funding.  

Another obstacle reported by several stakeholders is the limited human resources of 
Better Finance compared to the wide scope of their activities. Better Finance sometimes 
struggles to divide its resources between lobbying, research work and reporting to the 
European Commission. For example, EFRAG commented during interviews that it would 
like Better Finance to be more involved in the group so it could include retail sector 
opinions in its work. However, it understood that this does not form the core of Better 
Finance’s role and full membership of the group is too expensive for Better Finance’s 
limited  budget.  Better  Finance  is  therefore  only  occupying  an  observer  seat  in  the 
group.  

37 

 
 
It  was  mentioned  that  Better  Finance  originally  had  a  top-down  decision-making 
process  but  during  the  evaluation  period  crucial  work  was  increasingly  delegated  to 
newer staff, which helped with internal efficiency. One stakeholder highlighted that it is 
difficult for Better Finance to find experts who have in-depth knowledge on consumer-
related topics and attract them to work with them. Industry can attract such experts 
more easily by offering higher salaries. This view was supported in discussions with 
Better Finance itself.  

In a team of eight people, the absence of one team member has a very large impact 
on capacity. Having said that, the high level of expertise and valuable research input 
for the financial services sector is an internal factor that makes the work more effective. 
Given  that  Better  Finance  has  gained  clear  recognition  within  the  industry,  it  is 
often  invited  to  participate  in  high-level  groups  and  panel  discussions  where 
consumer  issues  within  financial  services  can  be  highlighted.  Through  that,  Better 
Finance’s work gains more visibility and the message can be spread more effectively to 
industry stakeholders.  

3.1.1.7 

Key findings 

Overall,  the  work  carried  out  by  Better  Finance  during  the  evaluation  period 
was effective in enhancing the involvement of stakeholders outside the banking and 
finance sector and in raising issues that could otherwise have been missed in debates 
around  future  financial  regulation.  The  evidence  from  the  survey  showed  that 
campaigns  and  reports  were  timely  and  relevant,  with  many  national  member 
organisations  recognising  a  higher  level  of  involvement  of  end-user/consumer 
involvement at national level as a direct result of the action.  

The result of these campaigns, reports and publications is, according to the interviews, 
that policy makers have come to count  on  contributions from  Better  Finance 
that they might otherwise lack when shaping policy. The beneficiary has provided 
consultation responses  to all relevant proposals and furthermore presented its policy 
inputs and perspectives in publications, meetings and events. While it is difficult at any 
level of policy-making to pinpoint exactly where lobbying has had effect, there is clear 
evidence  from  the  surveys  and  interviews  that  policy  makers  feel  better-
informed as a direct result of the work of Better Finance. This applies in particular 
to policy makers at EU level, whereas the effect of Better Finance activities on national 
policy  makers  is  lower  –  not  least  due  to  the  fact  that  Better  Finance  is  a  European 
organisation focussing its work on the EU level. 

Better  Finance  contributed  considerable  qualitative  and  quantitative  expertise  in 
relevant areas during the evaluation period, and often in overlooked areas such as, for 
example,  closet  indexing  of  funds.  This  view  was  corroborated  by  interviews  with 
stakeholders  from  various  groups,  and  the  survey  data  indicate  a  high  level  of 
satisfaction  with  the  quality  of  outputs.  Communication  resources  and  activities 
that received high praise from members and  other stakeholders  include the website, 
newsletters and press releases. Similarly, Better Finance’s event performance was rated 
highly. One area of concern is the number of report downloads, which showed 
a significant decrease in 2018 compared to 2017. This suggests that better follow-
up  is  needed  after  the  initial  announcements  of  publications  to  secure  a  wider 
readership of Better Finance’s research outputs. 

The primary audience for Better Finance’s work is investors, savers and consumers of 
financial  products.  To  this  end,  much  of  its  public  engagement  is  done  through  its 
member organisations, which include mainly financial consumer associations at national 
level.  By  keeping  them  informed  of  policy  developments  at  EU  level,  Better  Finance 
relies  on  its  membership  to  pass  on  the  relevant  information  to  end-users.  In  2018, 
Better  Finance  carried  out  a  membership  survey  for  the  first  time.  This  promising 
initiative,  however,  had  a  gap  in  that  the  membership  survey  did  not  include 

38 

 
questions  regarding  the  value  of  Better  Finance’s  work  at  national  and 
grassroots levels.  

It should also be noted that, in addition to Better Finance’s work being available online 
through a dedicated website,  it has a growing  presence  on in the press and through 
events across Europe and selected forums internationally, not just in Brussels. However, 
while  social  media  presence  has  grown,  Better  Finance’s  performance  on  social 
media  such  as  Facebook,  Twitter  and  YouTube  was  poor  in  comparison  to 
similar organisations, and there is clearly large room for improvement in this area. 

The large increase in the number of speaking engagements and media citations 
during the evaluation period is a strong indicator that Better Finance is performing well 
in its role and its inputs and interventions are valued by policy makers and stakeholders 
alike.  The  media  citations  reviewed  are  overwhelmingly  positive  when  mentioning 
Better Finance and quoting its employees. In more concrete terms, the analysis showed 
that it had a clear impact on the outcome of specific dossiers. One example is the PEPP 
Regulation, where  amendments were adopted  on at least  seven occasions in 201849. 
Furthermore, it was recognised by those interviewed that the positions Better Finance 
takes on issues is recognised and appreciated by others involved in shaping financial 
regulation.  Specific  areas  where  its  input  was  appreciated  that  came  out  during 
interviews  were  the  Markets  in  Financial  Instruments  Directive  (MIFID),  Consumer 
Credit Directive and the PRIIPs Regulation. 

The  members  of  Better  Finance  value  the  organisation’s  methods  of  selecting  and 
prioritising topics it will focus on. Moreover, Better Finance is seen as quick to react 
to member questions and suggestions, while providing a good forum at the Annual 
General Meeting for an overall strategic overview and discussion of proposed activities. 
In this context, the member survey introduced in 2018 provides a useful further channel 
for input.  

The stakeholders interviewed indicated that the obstacles to Better Finance achieving 
its goals are not unlike those of many NGOs working in advocacy. Its size relative to 
that  of  the  financial  sector  lobby  means  that  it  is  under-resourced.  This 
manifests itself not only in a smaller team than would be optimal and smaller budgets 
for activities, but also an over-reliance on a few key donors and funders, which means 
that its liquidity is vulnerable to payment delays and other external factors: all these 
factors hinder its overall effectiveness.  

3.1.2  Efficiency 

This  subsection  evaluates  the  efficiency  of  Better  Finance.  It  covers  the  following 
key topics: Better Finance’s use of resources in relation to its outputs; feedback and 
monitoring  systems  put  in  place  by  Better  Finance;  and  Better  Finance’s  sources  of 
funding (see Annex 5.1 for further detail on the evaluation questions). 

49 This is out of a total of 2,085 proposed amendments between 2017 and 2019. Source: European Commission, Framework 
for  an  EU  personal  pension  product  (Pan-European  personal  pension  –  PEPP),  Legislative  Train  Schedule.  Available  at: 
http://www.europarl.europa.eu/legislative-train/theme-deeper-and-fairer-internal-market-with-a-strengthened-industrial-
base-financial-services/file-pepp-pan-eu-personal-pension-product  

39 

 
 
3.1.2.1 

Better Finance uses its resources more efficiently than similar 

organisations  

Better Finance’s expenditure and main outputs were fairly stable during the evaluation 
period. Compared to other organisations, Better Finance seems to use its resources very 
efficiently. 

Table 3 provides an overview of the costs and main quantifiable outputs of Better 
Finance  in  the  period  2017-2018.  The  data  are  based  on  Better  Finance’s  annual 
reports and final reports.  

Table 3: Costs and main quantifiable outputs of Better Finance 

2017 

2018 

Activity area 

Direct 
costs in 
EUR50 

Direct 
costs 
scaled51 

Output description 

Direct 
costs in 
EUR 

Output description 

Research 

92,501 

138,752  Research reports: 4 

164,278  Research reports: 7 

97,758 

146,637  Responses to public 

169,674  Responses to public 

Advocacy 

Raising 
awareness, 
dissemination, 
financial 
education and 
training 

Reinforcement 
of interaction 
between 
member 
organisations 

consultations: 24 
Position papers: 5 
Public debates: 13 
Expert groups: 14 
Members in expert 
groups: 27  

consultations: 30 
Position papers: 8 
Public debates: 38 
Expert groups: 13 
Members in expert 
groups: 26 

171,119 

256,679  Events: 7 

164,143  Events: 8 

Event attendees: 460 
Media participants: 
20 
High-level speakers: 
10 
Press releases: 22 

Event attendees: 1321 
Media participants: 204 
High-level speakers: 14 
Press releases: 24 

96,064 

144,096  Board meetings: 5 

135,500  Board meetings: 4 

Action committee 
meetings: 3 
General Assemblies: 
2 
Conferences: 2 
Legal committee 
meetings: 1 
Events organised by 
member: 4 

Action committee 
meetings: 3 
General Assemblies: 2 
Conferences: 2 
Legal committee 
meetings: 1 
Workshops: 1 

TOTAL 

457,442 

686,163 

633,595 

Between  2017  and  2018,  Better  Finance’s  total  expenditure  and  the  related 
outputs were rather stable. While a greater share of the expenditure in 2017 was 
on  one  area  –  activities  in  the  area  of  ‘Raising  awareness,  dissemination,  financial 
education  and  training’  –  in  2018,  expenditure  was  more  balanced  between  the  four 
activity  areas.  The  output  numbers  did  not  significantly  change  between  the  two 
evaluated years. The most notable change was in the area of ‘Raising awareness’, where 
the  outreach  of  organised  events  (number  of  participants,  etc.)  increased  in  2018. 
Given the relative decrease of expenditure in that activity area compared to 2017, there 
is an indication that efficiency increased in that area. The activity areas ‘Research’ and 

50 Reported figures for the relevant grant period (1 May 2017 to 31 December 2017). 
51 While the reported figures for 2017 cover eight months, the reported figures for 2018 cover 12 months. To allow for easier 
comparison between the two years, the costs presented in this column are calculated by scaling the reported costs by 1.5.  

40 

 
 
 
 
‘Advocacy’  experienced  a  slight  increase  in  2018  in  expenditure  and  outputs  alike, 
indicating  that  efficiency  in  this  area  was  rather  stable.  In  the  activity  area 
‘Reinforcement  of  interaction  between  member  organisations’,  in  2018,  the  output 
slightly decreased while the expenditure increased, indicating less efficiency in this area 
than during the previous year. 

Table 4 presents the output of the three comparator organisations active in the 
area  of  financial  services  in  2017,  based  on  publicly  available  sources  and  input 
collected from the organisations themselves.  

Table 4: Outputs of COFACE, AGE Platform Europe, BEUC (2017) 

Activities 

Better Finance 

COFACE52 

AGE Platform53 

BEUC54 

Communication output 

16 press releases 
within financial 
services55 
28 publications 
within financial 
services56 

6,500 

70 

27 

Press releases / 
newsflashes 

22 

Monthly 
newsletters 

Social media 
campaigns 

Videos 

Press quotes 

Press interviews 

Blogs 

Reports and EU 
projects 

Working groups 

Events 

Statutory 
meetings 

Position papers 
and policy 
briefings 

EU or global 
consultations 

Consultative 
groups / 
workshops 

EP reports with 
amendments 

4 

7 

11 

5 

24 

14 

16 

11 

6 

3 

Policy output 

3 research projects 
3 EU assessments 
6 policy updates 

20 

11 

19 

9 

Speaker at over 30 
events 

4 (co-organised) 
140 (contributed to) 

8 

10 

4 

9 

21 

13 

33 

6 

52  COFACE  Families  Europe,  2017  Annual  Report,  2017.  Available  at:  http://www.coface-eu.org/resources/annual-
reports/2017-annual-report/ 
53 AGE Platform Europe, AGE Annual Report 2017. Available at: https://age-platform.eu/content/age-annual-report-2017  
54 BEUC, Annual report 2018. Available at: https://annualreport.beuc.eu/ 
55 BEUC, Press releases financial services. Available at: http://www.beuc.eu/press-media/press-
releases/financial%20services/54?tid%5B0%5D=5&tid%5B1%5D=6&page=3 
56 BEUC, Financial services, Publications. Available at: http://www.beuc.eu/financial-services?page=6#publications 

41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Activities 

Better Finance 

COFACE52 

AGE Platform53 

BEUC54 

Lectures/training  

Joint statements 
with European 
NGOs 

Website views 

European 
parliamentary 
blog views 

Twitter followers 

No. tweets 

Fb followers 

No. Fb posts 

LinkedIn 
followers 

% ratio 

10 

12 

Online traffic 

+119,195 

+1,292 

3,316 

510 

1,070 

47 

Spending breakdown 

Advocacy: 21% 
Research: 20% 
Communications: 
38% 
Membership 
coordination: 21% 

Advocacy: 40% 
Research: 10% 
Communications: 
20% 
Networking: 30%57 

Ratio on average is: 
60-70% policy work 
40-30% project 
work. 
Budget is not 
divided per types of 
activities but per 
types of spending58 

8,500 

1,573 

1,345 

N/A 

The  differences  between  these  organisations  need  to  be  taken  into  account  when 
drawing comparisons (see also page 24). Of the three comparator organisations, 
COFACE is most comparable to Better Finance, as both organisations have a similar 
number of employees (six to eight) and members (50-60) and receive a  comparable 
amount of EU grant funding (around EUR 400,000). AGE Platform Europe is more than 
twice  as  large  as  Better  Finance  in  terms  of  membership,  employees  and  available 
budget. BEUC has a wider variety of consumer topics on its agenda but has a dedicated 
team of four employees focusing on financial services. Overall though, the organisation 
is significantly larger than Better Finance in terms of staff (around 40) and available 
budget (EUR 5.5 million). In addition, the organisations do not count their outputs in 
the same way, so direct comparisons need to be interpreted with care. 

When  compared  to  the  expenditure  and  output  of  these  three  organisations,  Better 
Finance  is  found  to  use  its  resources  for  related  outputs  very  efficiently, 
achieving  comparable  output  numbers  at  notably  lower  expense.  Comparing  Better 
Finance to Finance Watch leads to the same conclusion (see Section 3.2.2.1 for costs 
and  outputs  of  Finance  Watch),  in  particular  in  view  of  the  fact  that  Finance  Watch 
receives almost three times as much funding from the Union Programme. 

57 Based on feedback from a stakeholder from COFACE. 
58 Based on feedback from a stakeholder from AGE Platform Europe. In its 2018 final accounts, the total expenditures were 
divided as follows: EUR 1,389,623, of which EUR 798,164 was for REC Programme and EUR 600,459 for projects.  

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.1.2.2 

Stakeholders perceive Better Finance as an efficient 

organisation 

The feedback from the stakeholders in the interviews regarding the fund management of 
Better  Finance  was  positive.  It  was  stressed  that  with  very  limited  resources,  Better 
Finance managed in 2017 and 2018 to deliver high quality events and research output 
and built a high profile in the media. 

Based on the impressions of stakeholders, Better Finance ensured very good value 
for  money  in  carrying  out  its  work  programme.  There  were  no  areas  of  savings 
identified by the interviewees. The consumer organisations interviewed stated that they 
have the same approach to spending money as Better Finance and no specific advice 
was provided as to how to improve offering best value for money in the future. 

In  an  interview,  the  beneficiary  itself  provided  information  about  its  organisational 
structure, saying that its resources are very limited and that efficiency is thus especially 
important to them.  Better Finance  explained that  it has one person in charge of  HR, 
office management, finance and the grant application process. However, Better Finance 
also noted that  it  is  subject to high  staff turnover due to higher wages in  the 
industry, which generates additional costs. Currently, the share of grant received 
by Better Finance is lower than the share received by Finance Watch. Additionally, some 
KPIs of qualitative nature are rather difficult to monitor, such as being invited to some 
key EU working groups on finance. For example, Better Finance is invited to ESAs level 
two discussions, which is a recognition of  its expertise in the given technical topic at 
European level.  

3.1.2.3 

Better Finance established several budget monitoring tools and 

a feedback system to ensure the efficient use of resources 

In  order  to  ensure  the  efficient  allocation  and  use  of  resources,  Better  Finance 
established some monitoring tools and a feedback system. Among the tools mentioned 
by Better Finance are annual reporting, the external auditing report required by Belgian 
law, and budget submission to the General Assembly. 

According  to  the  interview  conducted  with  Better  Finance,  its  costs  and 
spending are budgeted in line with the Union Programme objectives, and they 
are  reviewed  and  approved  by  the  organisation’s  General  Assembly.  The  resources 
are  assigned  within  the  preliminary  budget  after  the  approval  of  the  Action 
Committee59,  the  Board  of  Directors  and  General  Assembly.  Then,  the  final 
budget is submitted to the European Commission with the corrections. Every quarter, 
Better Finance completes the financial statement of expenses and the Action Committee 
approves any project above EUR 5,000. The beneficiary put this procedure in place after 
it received the first grant under the Union Programme; the internal control system was 
then developed further.  

In general, Better Finance said that its activities and priorities are derived from their 
mission60,  therefore  it  tries  to  get  involved  as  much  as  possible  in  relevant 
consumer topics. It discusses these topics with members within the federation. Since 

59 The Action Committee of the Board is a permanent committee set up by the General Assembly, who also approves the 
committee members (currently the President and to Vice-presidents of Better Finance). The Action Committee is responsible 
for monitoring closely, on a quarterly basis, the execution of the EU Action in the framework of the Action Grant  received 
from the EU. The Committee reviews the progress of the execution and checks key documents (especially documents related 
to the finances of the organisation like the annual budget and accounts or quarterly budget fulfilment updates) before they 
are put up for approval at a full board meeting.  
60 “Better Finance believes that the financial system exists to serve the real economy and citizens by ensuring the optimal 
allocation  of  capital and  providing other financial services in the most efficient way. In order to restore trust in  financial 
services,  the  current  dominance  of  financial  institutions  over  the  real  economy  must  be  curbed  and  the  primacy  of  a 
sustainable real economy promoted.’’ Available at: https://betterfinance.eu/organisation/about-us/mission/ 

43 

 
 
2019 (which is outside the period evaluated in this report), it also sends the planned 
activities to the organisation’s scientific council for review. As member of many high-
level expert groups, it sets its priorities in line with the most pressing issues to 
users  and  strives  to  respond  to  all  consultations  at  least  partially. 
Communication and media strategy are also updated regularly. Better Finance managed 
to develop partnering agreements for activities directly linked to the programme, should 
it try to incentivise it through contributing to the costs. Since 2018, there is an annual 
membership survey organised, as well as some topical surveys, e.g. on MIFID II, during 
the evaluated period. 

3.1.2.4 

There was no diversification of Better Finance’s funding 

between 2017 and 2018  

From  2017  to  2018,  there  was  a  12%  decrease  in  partnering  income,  donations  and 
conference  revenue,  covered  by  a  13%  increase  in  membership  fee  income.  Better 
Finance sought advice from its members on options to diversify its funding sources but 
did not succeed in finding new sources during the evaluation period. 

Stakeholders confirmed in the interviews that finding initiatives aimed at diversification 
of  its  funding  sources  is  on  the  agenda  of  Better  Finance.  However,  the  business 
model of Better Finance currently relies heavily on membership contributions, 
while there are ongoing discussions with the members to seek their input and advice 
on  finding  alternative  funding  sources.  Members  of  Better  Finance  have  put  forward 
some suggestions as to how Better Finance could maximise its revenue streams. Among 
the  suggested  options  the  members  mentioned:  setting  up  a  centre  of  excellence, 
setting up a label, seeking corporate sponsorship, etc. Some of the suggested options 
might,  however,  raise  questions  about  the  future  independence  and  level  of 
objectiveness of Better Finance, such as in the case of corporate sponsorship.  

A  representative  from  the  European  Commission  highlighted  the  importance  of 
focusing on the viability of  Better Finance and  its business model, so that  it 
can  become  financially  independent.  At  this  stage,  it  is  too  much  linked  to  the 
funding from the Commission, which poses a high existential risk for the beneficiary. 
This  opinion  was  shared  by  other  EU  bodies,  who  would  like  both  beneficiaries  to 
continue their work in the future and therefore would like to ensure that public funding 
is  dedicated  to  their  activities.  Another  alternative  mentioned  was  receiving  funding 
from the financial sector by both beneficiaries; however, such a solution would clearly 
raise the issue of their independence. 

From 2018, Better Finance has sought to find partners for research projects and events 
and to submit joint offers to different projects and tenders, but as yet these have not 
been a significant new financing source. Since 2018, Better Finance has become more 
visible and recognised as an organisation providing expertise in the area of consumer 
financial services.  

When comparing the income structure of the comparator organisations active 
in the area of financial services, it was noted that BEUC (although having a much 
larger operating income than Better Finance) also relies heavily on membership fees, 
whereas  AGE  Platform  Europe  and  COFACE  are  mostly  financed  from  EU  funds 
(operating  grants),  with  limited  own  funds  and  third-party  funding.  Table  5  gives  an 
overview of the funding sources of Better Finance and other consumer organisations.  

44 

 
Table 5: Funding sources of consumer organisations* 

Type of funding 

Better 
Finance61 

Finance 
Watch62 

COFACE63 

AGE 
Platform 
Europe64 

BEUC65 

1.  Own funding 

38% 

2.5% 

10% 

11% 

49% 

Membership fees 

25% 

2.3% 

10% 

Donations, registrations 

13% 

0.2% 

N/A 

8% 

3% 

36% 

13% 

2.  Third  party  funding/ 

other 

3% 

41% 

10% 

2% 

2% 

3.  EU funding 

59% 

57% 

80% 

87% 

49% 

EU 
grant 

operating/action 

institution  funded 

EU 
projects 

59% 

57% 

80% 

N/A 

30% 

N/A 

N/A 

N/A 

N/A 

19% 

*Funding sources in 2018 expressed as percentage of total resources 

The  table  shows  that  Better  Finance  has  a  comparatively  high  level  of  own  funding, 
exceeded only by BEUC, but a low level of third-party funding (where Finance Watch 
has  been  more  successful).  While  more  than  half  of  Better  Finance’s  funding  comes 
from  EU  sources,  this  level  of  EU  financing  is  still  lower  than  for  COFACE  and  AGE 
Platform Europe. 

Overall, although all five organisations vary in size, activity level and specific expertise, 
they are all heavily dependent on EU grants, which raises the issue of sustainability of 
the funding model. Better Finance was not able to diversify its funding during 
the  evaluation period. A comparison with Finance Watch, but also COFACE,  shows 
that Better Finance income from third-party donors is particularly low, which could be 
an area to target for future diversification. 

3.1.2.5 

Key findings 

From  2017  to  2018,  Better  Finance’s  expenditure  and  output  did  not  change 
significantly.  There  was  a  shift  between  its  four  activity  areas  (Research;  Advocacy; 
Raising  awareness,  dissemination,  financial  education  and  training;  Reinforcement  of 
interaction between member organisations). The expenditure for raising awareness was 
slightly decreased in favour of the other three activity areas, but this did not affect the 
overall output. Better Finance thus maintained a rather stable cost-output ratio 
during the two evaluation years. When compared to the expenditure and output of 
similar  organisations  at  EU  level,  namely  COFACE,  AGE  Platform  Europe,  BEUC  and 
Finance Watch, Better Finance produces a high level of output with comparably 
little resources and works very efficiently.  

These  findings  are  corroborated  by  interviews,  as  there  was  a  consensus  among 
stakeholders that for the resources that Better Finance has at its disposal, the 
organisation  delivers  very  good  value.  The  high  quality  and  relevance  of  Better 
Finance’s  outputs  was  stressed  explicitly  in  connection  to  its  resource  use.  Many 
stakeholders interviewed for this study were also aware that Better Finance has fewer 
resources than comparable organisations.  

61 Based on Better Finance Grant Report 2018. 
62 Based on Finance Watch Grant Report 2018. 
63 Based on the input provided by the stakeholder from COFACE. 
64 AGE Platform Europe, Financial Resources, 2018. Available at: https://www.age-platform.eu/financial-resources  
65 BEUC, Financial Information, 2018. Available at: https://www.beuc.eu/about-beuc/financial-information 

45 

 
 
Regarding the sources of funding, Better Finance relies (besides the EU grant) mainly 
on  membership  fees.  The  income  from  membership  fees  is  significantly  higher  than 
other income (i.e. from partnerships or donations). No significant diversification of 
funding  occurred  between  2017  and  2018  –  the  share  of  income  from  sources 
other  than  membership  fees  in  fact  slightly  decreased.  Stakeholders  confirmed  that 
Better Finance has had the diversification of funding sources on its agenda. However, 
as of 2018, diversification had not been achieved, and Better Finance is advised to 
intensify its efforts to seek additional sources of funding. 

3.1.3  Relevance 

This  subsection  evaluates  the  relevance of  Better Finance.  It  covers  the  following 
key  topics:  whether  Better  Finance’s  objectives  still  meet  the  current  needs  of 
stakeholders;  to  what  extent  Better  Finance’s  work  still  meets  the  objectives  of  the 
Union Programme; whether the topics covered by Better Finance are relevant; and the 
relevance  of  Better  Finance’s  membership  (see  Annex  5.1  for  further  detail  on  the 
evaluation questions). 

3.1.3.1 

The objectives of Better Finance meet the European-level needs 

of financial services’ users  

Stakeholders  confirmed  that  the  objectives  of  Better  Finance  correspond  to  current 
European-level  needs  of  financial  services  users,  and  that  the  organisation  forms  a 
valuable  counterweight  to  the  financial  services  industry.  However,  stakeholders  also 
identified several areas where their needs were not addressed. 

Better  Finance  aims  to  promote  research,  information  and  training  on  investments, 
savings and personal finances to defend the interests of European citizens as financial 
services users at European level. During the evaluation period, Better Finance’s specific 
priorities were:66 

1.  Unified, transparent, liquid, fair and accessible capital markets to the benefit of 

end-investors and the real economy 

2.  Improved and more consistent investor and consumer protection across all retail 
financial products in the EU underpinned by effective redress for all EU citizens 

3.  Better  governance  of  publicly  listed  companies  and  pension  and  investment 
funds  by  facilitating  the  engagement  of  minority  shareholders  and  fund 
participants. 

4.  A Capital Markets Union that will restore retail equity investments to their proper 
place, whilst improving the long-term net returns of intermediated investment 
products 

All stakeholder groups stated during the interviews that the work of Better Finance is 
in  general  very  valued  and  relevant  for  the  financial  services  industry.  One  of  the 
banking associations highlighted the importance of passing on the voice of consumers 
to  the  EU-level  as  a  counterbalance  to  the  industry  perspective  and  appreciated  the 
work  delivered  by  Better  Finance.  Survey  results  also  indicate  that  the  objectives  of 
Better  Finance  continue  to  be  relevant  to  the  current  issues  and  needs  of 
consumers and financial end-users (Figure 16). The three stakeholders (out of 26) 
that  found  Better  Finance’s  objectives  not  very  relevant  or  irrelevant  are  all  national 
authorities, which is in line with the previous observation that Better Finance’s impact 
at national level is lower than at EU level.  

66 Better Finance, Annual Report, 2017, p. 6. Available at: https://betterfinance.eu/publications/annual-reports/  
These priorities have been updated and expanded in 2019. See Better Finance, Key Priorities for the Next Five Years 2019-
2024, 2019. Available at: https://betterfinance.eu/organisation/about-us/key-priorities/ 

46 

 
 
 
Figure 16: Alignment of objectives of Better Finance with the current issues and 
needs of consumers and financial end-users (N=26) 

8%

4%

12%

19%

58%

Irrelevant 

Not very relevant 

Neutral 

Relevant 

Highly relevant 

The relevance of the work of Better Finance was as well recognised in terms of the high 
level  of  expertise  that  it  provides  to  consumer  organisations  and  EU  bodies.  The 
stakeholders  mentioned  that  there  is  a  very  limited  representation  of  the  consumer 
perspective  in  the  area  of  financial  services.  Additionally,  the  topics  Better  Finance 
covers are very technical, and it requires time and effort for any organisation to reach 
such high level of expertise, especially from the consumer perspective.  

Better Finance is also considered adaptable to high or medium extent in terms of 
the  activities  addressing  the  needs  of  consumers  and  financial  end-users, 
according to the vast majority of stakeholders (25 out of 28 survey responses). Both 
member organisations and consumer organisations indicated also in the interviews the 
high  level  of  responsiveness  of  Better  Finance  to  the  changing  landscape  of  the 
industry.  They  reported  that  they  are  satisfied  with  how  the  work  of  Better  Finance 
complements their individual work at both national and international level. 

However,  when  asked  if  there  are  current  needs  of  consumers  and  financial  end-
users  that  remain  unaddressed  in  some  specific  areas,  both  interviewees  and 
82%  of  the  survey  respondents  (23  out  of  28)  responded  with  yes.  The  following 
examples of needs gaps were mentioned:  

Issues raised by FinTech developments;  

•  Manipulations of the financial system for wealth extortion;  
• 
•  Matching local legal frameworks to the requirements of the EU Directives; 
•  Financial needs of persons with low and very low incomes; 
•  Payments and over-indebtedness; 
•  Non-life insurance issues; 
•  Development of employee share ownership; 
•  Financial education;  
•  Review of national financial authorities’ work. 

Moreover,  notwithstanding  the  limited  resources  available  to  the  beneficiary, 
stakeholders said that it would be important for Better Finance to be present in 
those  international  forums  where  international  standards  are  discussed  and 
defined,  as  it  could  bring  a  consumer  focus  to  the  international  scene,  given  the 
European values and perspective they can offer. For example, within the area of digital 
data and digital participation, international standards are now being developed and it 
would be important to have a (European) consumer voice in these discussions.  

47 

 
 
3.1.3.2 

Better Finance’s work is relevant for the Union Programme  

Stakeholders  perceived  that  the  research  and  communications  work  of  Better  Finance 
was highly relevant for informing consumers and financial end-users. 

The Union Programme has the following objectives67:  

A) To enhance further the active participation and involvement of consumers and other 
financial  services  end-users,  as  well  as  stakeholders  representing  the  interests  of 
consumers  and  other  financial  services  end-users,  in  Union  and  in  other  relevant 
multilateral policy-making in the area of financial services;  

B) To inform consumers and other financial services end-users, as well as stakeholders 
representing  their  interests,  about  issues  at  stake  in  the  regulation  of  the  financial 
sector.  

Both  of  the  abovementioned  objectives  are  met  by  Better  Finance,  according  to  the 
feedback collected via survey and interviews.  

The survey results indicate that the activities carried out by Better Finance are relevant 
for enhancing the involvement of consumers and financial services end-users, 
as well as stakeholders representing their interests, in EU policy-making in the area of 
financial  services.  In  their  survey  responses,  64%  of  stakeholders  (18  out  of  28) 
perceived that providing expertise through research work and position papers 
is highly relevant, 57% (16) that communication and education activities is highly 
relevant  and  50%  (14)  that  advocacy  work  at  EU  and  national  level  is  highly 
relevant. Similarly, the abovementioned types of activities are perceived by the majority 
of  stakeholders  as  highly relevant for  informing consumers  and financial end-
users of issues at stake in financial regulation. 

The feedback among member organisations and some other stakeholders was limited 
to this aspect. According to one representative from the Commission, Better Finance is 
fully aligned with the objectives of the Union Programme and it is closely monitored by 
the Commission through KPIs and regular reporting. 

3.1.3.3 

Financial topics covered by Better Finance are highly relevant 

The majority of stakeholders agreed that the financial topics covered by Better Finance 
are  highly  relevant  for  consumer  and  financial  end-users  and  there  were  no  relevant 
topics missing, based on the EU political agenda. 

Better Finance indicated that their topic selection is closely aligned with the EU financial 
political  agenda,  as  well  as  the  ad  hoc  needs  that  are  raised  by  the  member 
organisations  throughout  the  year.  The  reviewed  sources  outline  the  key  topics 
researched by Better Finance in 2017 and 2018. Research  reports in 2017 and 2018 
considered  pensions  (this  is  an  annual  report),  robo-advice  and  investing  (also  an 
annual  report),  closet  indexed  funds,  benchmark  disclosure  compliance,  pension 
lifecycles and risk mitigation techniques, various CMU reports and commentary, and the 
EU Citizens Barometer68.  

67  Regulation  (EU)  2017/826  of  the  European  Parliament  and  of  the  Council  of  17  May  2017  on  establishing  a  Union 
programme to support specific activities enhancing the involvement of consumers and other financial services end-users in 
Union policy-making in the area of financial services for the period of 2017-2020, OJ 19.5.2017 L 129/17, Article II, p. 4. 
Available at: https://eur-lex.europa.eu/eli/reg/2017/826/oj  
68 Better Finance, Final Report, 2017, p. 24; Better Finance, Final Report, 2018, pp. 24-25. 

48 

 
 
In  2017,  Better  Finance  responded  to  seven69  consultation  topics  addressed  on  29 
occasions70.  In  2018,  Better  Finance  looked  at  1971  consultation  topics  on  30 
occasions72. When comparing the two years, although the number of occasions on which 
Better  Finance  responded  to  consultation  topics  is  almost  the  same,  the  diversity  of 
topics covered in 2017 and 2018 differs substantially.  

Based  on the analysis  of the  survey and interviews, the topics  selected by  Better 
Finance  within  the  evaluation  period  were  perceived  as  relevant  to  a  high 
extent. Among the most relevant topics the respondents mentioned:  

•  Pension savings;  
•  Efficient portfolio management techniques;  
•  The real return 2018 – country by country;  
•  PRIIPs Regulation;  
•  PEPP Regulation;  
• 
•  MIFID II;  
Investors’ protection of retail investors;  
• 
•  AGM participation to foster CMU goals.  

Insurance Distribution Directive (IDD);  

In  general,  the  feedback  collected  from  stakeholders  via  interviews  is  that  Better 
Finance  is  very  responsive  to  the  needs  of  stakeholders  and  that  the  work 
delivered meets these needs. The respondents indicated that Better Finance covers 
essential  technical  areas  of  consumers  and  end-users  in  an  understandable  and 
transparent  manner,  with  the  specific  focus  on  pensions  and  insurance.  One 
stakeholder particularly praised the constructive and supportive attitude of Better 
Finance in its work on MIFID II. 

A  representative  from  a  banking  association  mentioned  that  although  the  activity  of 
Better  Finance  meets  their  needs,  there  are  certainly  some  areas  of  missed 
opportunities,  which  is  related  to  the  limited  capacity  of  the  organisation  and 
consequently the limited impact that Better Finance can have. One topic mentioned by 
a stakeholder from an EU body as not fully covered was the ESAs review.  

3.1.3.4 

The membership of Better Finance is considered relevant for its 

objectives 

Members of Better Finance are considered relevant by all stakeholder groups (including 
the  members  themselves).  According  to  feedback  collected  from  Better  Finance 
members,  their  task  allocation  is  a  flexible  process  linked  to  the  expertise  of  each 
member and current needs. 

Better  Finance  is  a  European  federation  of  mostly  national  organisations  that 
represent  financial  service  end-users  at  national  level.  In  2018,  there  were  43 
members, of which 16 were associate members73. The types of members represented 
were  shareholder  associations,  national  NGOs,  retirement  funds  and  consumer 
associations.  All  members  are  invited  to  take  part  in  policy  and  communication 
activities, e.g. consultation responses, position papers, research and advocacy projects 

69  The  topics  covered  in  2017:  ESAs,  FinTech,  sustainable  finance,  suitability  requirements  guidelines  under  MiFID  II, 
secondary markets for Non-Performing Loans (NPLs), motor insurance, transparency and fees in cross-border transactions.  
70 Better Finance, Final Report, 2017, p. 3. 
71 The topics covered in 2018: institutional investors and asset managers’ duties  regarding sustainability, EBA relocation, 
review of the ESAs, potential product intervention measures on contracts for differences and binary options to retail clients, 
insurance  distribution,  fitness  check  roadmap  on  public  reporting  by  companies,  sustainable  finance,  investments  and 
sustainability risks, regulatory technical standards, consumer trends, Alternative Investment Fund Managers Directive, MiFID 
II,  crowdfunding  service  providers  (ECSP),  shareholders  rights,  cross-border  distribution  of  investment  funds,  simplified 
prospectus for companies, new deal for consumers, insurance-based investment products, Multiannual Financial Framework 
(MFF), carbon impact benchmarks, , PRIIPs Regulation. 
72 Better Finance, Final report, 2018, pp. 40-45.  
73 Better Finance, Final Report, 2018, pp. 54-56. 

49 

 
 
and  working  groups.  There  are  also  currently  six  member  working  groups  on  the 
following 
Packaged 
Pensions, 
topics:  Shareholders/Corporate  Governance, 
Investments, Insurance, Investor Education, Audit & Financial Reporting. 

According to the survey, the majority of respondents consider the membership of Better 
Finance  relevant  for  the  objectives  of  the  beneficiary’s  activities.  The  input  collected 
from  the  interview  with  a  European  Commission  representative  confirmed  that  the 
members  of  Better  Finance  are  relevant  considering  the  mission  of  the 
beneficiary. The feedback from other stakeholder interviews was, however, limited in 
this  area.  One  of  the  member  organisations  indicated  that  Better  Finance  had 
diversified  its  membership  types  to  include  EEA  members,  which  is  important 
given the EU’s close financial connections to these countries.  

The stakeholders mentioned that there is no formal demarcation in task allocation 
between Better Finance and the members and that such an approach is necessary 
in  this  type  of  work.  One  of  the  consumer  organisations  interviewed  indicated  that 
Better  Finance’s  membership  does  not  provide  full  coverage  of  Europe  as  it 
does  not  have  representatives  from  every  Member  State.  Therefore,  some 
smaller  Member  States  might  be  under-represented  in  EU-level  discussions  about 
consumers within financial services.  

3.1.3.5 

Key findings 

Stakeholder responses indicated that the objectives of Better Finance are in line with 
those  of  the  Union  Programme  2017-2020  and  the  thematic  coverage  of  the 
beneficiary’s activities, as well as its membership, are highly relevant for the 
financial services sector. The activities carried out by Better Finance in 2017 and 2018 
were seen as very relevant for enhancing the involvement of consumers and financial 
services end-users and other stakeholders in the area of financial services.  

Better Finance is seen as an adaptable and responsive organisation, aiming to address 
the  needs  of  the  consumer  and  financial  end-users.  Member  organisations  indicated 
that  the  work  of  Better  Finance  complements  their  work  at  both  national  and 
international  levels.  Similarly,  representatives  of  EU  bodies  reported  that  the 
existence  of  Better  Finance  is  relevant  to  counterbalance  the  voice  of  the  financial 
services industry.  

The  stakeholders perceived  that the topics  selected by Better Finance  for its work in 
2017 and 2018 were relevant to consumers and financial end-users. In general, Better 
Finance’s  main  focus  is  on  private  investors,  shareholders  and  insurance  pension 
holders. On the other hand, some respondents expressed the view that there are still 
gaps in terms of the needs of consumers and financial end-users, for instance 
in  the  area  of  problems  of  manipulating  the  financial  system  for  wealth  extortion, 
FinTech development or the need for actively managed funds. Other topics mentioned 
as  missing  from  Better  Finance’s  agenda  were  financial  education,  disclosure  to 
investors, review of national financial authorities works, and payments. Within the area 
of the EU financial policy agenda, a topic that was not fully covered, according to one 
representative from the EU bodies, was the ESA review.  

The membership of Better Finance, mostly national organisations representing financial 
services  end-users,  was  evaluated  both  by  the  members  themselves  and  by  other 
stakeholders interviewed  as highly relevant and in line with the beneficiary’s  mission 
and objectives.  The work and  cooperation between Better Finance and the members 
was  perceived  as  flexible  and  proactive,  with  a  high  involvement  of  members  in  the 
organisation’s research output. However, it was mentioned that its membership does 
not cover all EU Member States, and country coverage could be improved. 

50 

 
 
3.2  Evaluation of Finance Watch: effectiveness, 

efficiency and relevance 

3.2.1  Effectiveness 

This subsection evaluates the effectiveness of Finance Watch. It covers the following 
key topics: the effects of Finance Watch’s work on end-users, stakeholders outside the 
financial  industry  and  policy  makers;  the  effects  of  Finance  Watch’s  communication 
activities  and  research  outputs;  Finance  Watch’s  approach  to  prioritisation  and 
monitoring; and any obstacles hindering Finance Watch’s effectiveness (see Annex 5.1 
for further detail on the evaluation questions). 

3.2.1.1 

Finance Watch acts as a counterbalance to industry on key 

issues such as sustainable finance in the area of finance services 

Finance  Watch’s  focus  improved  in  2018,  which  means  it  is  an  effective  organisation 
overall and, considering its size, is successful in increasing the involvement of end-users 
and non-industry stakeholders. 

The desk research shows that Finance Watch carried out a number of activities which 
target  end-users  to  varying  degrees.  The  national  networks  are  perhaps  the 
strongest  end-user-facing  activity  and  Finance  Watch  takes  a  coordination 
role in these. In 2017, through the Action Networks, it coordinated 136 actions 
and  events  in  18  countries74.  In  addition,  Finance  Watch  also  runs  events,  writes 
reports and publishes cartoons and short articles aimed at a broad audience75. Finance 
Watch also created a number of tools and ran workshops and campaigns, including for 
example  a  webinar  for  members  to  coordinate  responses  to  the  High-Level  Expert 
Groups (HLEGs) on Sustainable Finance76 as well as training materials for its members. 
Finance  Watch  also  created  a  citizens’  mobilisation  platform  in  English  and  French, 
launched in June 201877. Among the activities coordinated with end-users were rallies, 
creative  street  actions,  community  events,  conferences,  and  events  at  national 
parliament and congress.  

With the aim of involving users  of financial  services in policy-making, Finance Watch 
connects through the FSUG, a crucial voice to counterbalance the industry lobby, and 
various  other  groups.  The  other  members  of  this  group  agreed  that  Finance  Watch 
frequently makes useful interventions and valuable inputs.  

The  survey  results  indicate  that  a  large  share  of  the  respondents  positively 
evaluated  the  contribution  of  Finance  Watch  towards  enhancing  active 
participation  of  consumers,  other 
financial  services  end-users  and 
representatives  within  the  EU  policy  area.  Almost  three  quarters  of  the 
respondents  perceived  Finance  Watch’s  influence  as  very  high  or  high  (Figure  17). 
However, it is worth noting that 10% of those surveyed reported that they either did 
not know what contribution Finance Watch made, or that it was low/very low. While this 
is a low percentage relative to those who responded positively, it does point to certain 
groups (banks and national ministries on the whole) rating Finance Watch’s impact as 
poor in this area.  

74 Finance Watch, Final Report, 2017, p. 12. 
75 Finance Watch, Work Programme 2017-2020, 2016, p. 5. 
76 Finance Watch, We must change our perception on what ‘returns’ mean, 2018, Webinar. Available at: https://www.finance-
watch.org/uf/sustainable-finance-we-must-change-our-perception-on-what-returns-mean/  
77 http://www.lafinanceauxcitoyens.org/  

51 

 
 
Figure 17: Finance Watch’s contribution to enhancing the active participation of 
various stakeholder groups in financial services (N=73) 

3%

6%

1%

18%

30%

43%

Very high 

High 

Medium 

Low 

Very low 

I do not know 

Among the top activities that contributed most to increased involvement of the various 
stakeholders  within  the  financial  services  area,  the  respondents  mentioned  the 
following: events and campaigns, responses to EU public consultations, participation in 
stakeholder groups of EU bodies, and publications.  

While  two  thirds  of  survey  respondents  perceived  a  slightly  or  noticeably  higher 
involvement of member organisations and national consumers as a direct link to Finance 
Watch’s activities, almost one third of the respondents did not express a decided opinion 
(Figure 18). This indicates a certain lack of engagement with the Finance Watch 
agenda.  It  appears  that  Finance  Watch  faces  some  challenges  around  effective 
engagement of all its members and stakeholders with regards to dissemination of the 
results of its activities.  

Figure 18: Influence of Finance Watch’s activities on the level of involvement of 
members and national consumers (N=62) 

2%

31%

29%

39%

Slightly lower involvement 

Neutral 

Slightly higher involvement 

Noticeably higher involvement 

The  interviews  supported  the  rationale  that  Finance  Watch  existed  to  be  a 
counterweight  to  the  banks  and  agreed  that  they  largely  fulfilled  this  role.  As  a 
federation,  it  does  not  have  direct  contact  with  end-users  but  reaches  end-users  via 
member  organisations,  who  also  contribute  to  its  studies  (for  example  on  financial 
inclusion).  

52 

 
 
 
The interviews outlined a marked difference between 2017 and 2018 in terms of Finance 
Watch having a clear agenda. For example, in 2018, Finance Watch had a strong focus 
on sustainable finance and contributed to the development of the sustainable finance 
taxonomy,  which  resulted  in  an  April  action  plan.  In  2017,  by  comparison, 
interviewees  said  that  Finance  Watch  lacked  the  same  clarity  of  focus  and 
interviewees from the European Commission noted that this may have been due to a 
marked decline in legislative proposals for financial regulation in 2017. In addition to 
this,  internal  factors  around  management  and  human  resources  negatively  impacted 
the ability of key employees to focus on the areas where they were needed. This was 
largely  remedied  in  2018;  for  example,  the  increase  in  financial  inclusion-related 
outputs was a consequence of the appointment of a new Senior Research and Advocacy 
Officer,  with  expertise  in  financial  inclusion.  Interviews  noted  how  this  individual 
brought their expertise and personal networks to the organisation, which made Finance 
Watch more effective in achieving its aims.  

3.2.1.2 

Finance Watch is effective in providing views to policy makers 
but faces a challenge when communicating the high quality of its work 

During the evaluation period, Finance Watch provided views to policy makers in a number 
of  ways.  However,  a  notable  share  of  those  surveyed  and  interviewed  were  unable  to 
provide an answer when asked if they were aware of specific impacts or activities. 

During the evaluation period, Finance Watch was engaged in the major debates 
and  policy  developments  in  financial  regulation.  It  responded  to  nine 
consultations  in  2017  on  topics  including  the  ESA  review,  MiFID  suitability 
requirements, sustainable finance, investment dispute resolution, motor insurance, and 
cross-border transactions78. In 2018, the number of  consultation  responses was also 
nine. Topics included asset managers and institutional investors’ duties, framework to 
facilitate sustainable investment, low carbon benchmarks and positive carbon impact 
benchmarks,  as  well  as  issues  around  public  reporting  by  companies,  crowdfunding 
regulation and insurance recovery resolution79. The total consultations open in the area 
of financial services was around 40 for DG FISMA and ESMA alone across the two years. 
With this figure in mind, Finance Watch could consider reviewing its approach to 
consultations  to  assess  if  increasing  its  responses  would  better  support  its 
goals.  The  quality  of  these  consultation  responses,  however,  was  regarded  as  high, 
and interviewees noted that Finance Watch served as an effective bridge between civil 
society  knowledge  and  expert  financial  knowledge  bases,  raising  questions  in  a 
technical way that would be impossible for other civil society organisations.  

Finance Watch complemented its responses to relevant consultations with positions on 
ESA and Commission groups. The desk research showed that, in 2017, there were three 
advisory  groups  on  which  Finance  Watch  sat:  ESMA’s  Securities  and  Markets 
Stakeholder  Group,  European  Commission  Expert  Group  on  Corporate  Bond  Market 
Liquidity (EGCBML) (observer status) and the FSUG80. This grew to six groups in 2018, 
with its exit from the EGCBML and addition of four new groups:  the EBA stakeholder 
group,  EIOPA  Insurance  and  Reinsurance  Stakeholder  Group,  EIOPA  Costs  and 
Performance  Expert  Group  and  European  Commission  Technical  Expert  Group  on 
Sustainable  Finance  (TEG)81.  Finance  Watch  staff  also  regularly  speak  at  events 
organised  by  partners  and  members  –  in  2018,  they  have  spoken  on  more  than  90 
occasions82.  

78 Finance Watch, Annual Report, 2017, pp. 4, 11, 14, 18, 27. Available at: https://www.finance-watch.org/publications/  
79 Finance Watch, Final Report, 2018, p. 57. 
80 Finance Watch, Annual Report, 2017, p. 18; Finance Watch, Final Report, 2017, p. 5. 
81 Finance Watch, Final Report, 2018, Annex I. 
82 Finance Watch, Final Report, 2018, p. 11. 

53 

 
 
In  addition,  Finance  Watch  also  proposed  a  number  of  amendments  to  legislative 
proposals. In 2018, for example, it put forward 14 amendments to financial regulation 
proposals, four on the banking package, two on the ESA review, two on FinTech, two 
on  an  insurance  portfolio,  one  on  pensions,  two  on  retail  legislation,  and  one  on 
sustainable  finance83.  There  is  no  clear  evidence  to  what  extent  these  proposed 
amendments  actually  influenced  the  legislation.  Several  interviewed  stakeholders 
(including European Commission officials) have however pointed out that, due to the 
generally high number of amendments, is in often not possible to establish a direct link 
between individual amendments and any modification to the legislation. 

The survey results indicate that Finance Watch performs well in terms of its ability 
to  provide  policy  makers  with  views  other  than  those  expressed  by  the 
financial sector industry. Over half of the stakeholders (36 out of 71) responded that 
Finance Watch had a high impact, and another 28 stakeholders responded that Finance 
Watch had medium or some impact. The majority of respondents also confirmed that 
they  felt  better  informed  with  regard  to  the  perspective  and  needs  of  financial  end-
users as a result of the work of Finance Watch (Figure 19). However, there remain 21% 
of  respondents  with  a  neutral  or  negative  response,  emphasising  the  need  for  more 
effective communication of the work undertaken.  

Figure 19: Level of awareness of the needs of the financial end-users as a result of 
Finance Watch’s work (N=32) 

6%

16%

34%

44%

No additional insight into the 
perspectives of financial end-users 
derived from  
Neutral 

Increased awareness on some 
perspectives and needs of financial 
end-users based  
Fully aware of the perspectives and 
needs of financial end-users based on 
the wo 

The impact of Finance Watch on EU decision-making during the evaluation period was 
seen as overall positive (Figure 20), with 23 out of 32 respondents signifying that they 
had an impact. Again, around a quarter of respondents felt unable to comment or felt 
there was no impact. This is potentially due to the fact that direct influence on decision-
making  is  generally  hard  to  establish  in  view  of  the  complexity  and  length  of  the 
decision-making  process.  Nevertheless,  there  is  room  for  Finance  Watch  to  establish 
and  communicate  clearer  links  between  their  lobbying  activities  and  their  effect  on 
decision-making.  

83 Finance Watch, Final Report, 2018, p. 25.  

54 

 
 
 
Figure 20: Impact of Finance Watch on EU decision-making within financial services 
(N=32) 

22%

16%

6%

19%

37%

High impact 

Medium impact 

Some impact 

No impact 

I do not know 

Member organisations also noted in interviews that Finance Watch’s effectiveness 
in taking positions on European issues varied across the institutions it worked 
with.  One  member  organisation  of  Finance  Watch  stated  that  for  members  of  the 
European Parliament for example, Finance Watch’s views are well-received and taken 
on  board.  This  is  indicated  by  Finance  Watch  representatives  being  regularly  invited 
back to hearings, groups and other policy forums during the evaluation period, which 
shows  that  they  made  useful  contributions.  Some  interviewees  noted  that  they 
were not sure of the extent to which Finance Watch had the capacity to lobby 
the  European  Council.  In  interviews,  Finance  Watch  managers  acknowledged  this 
issue and explained that this was part of the reason behind them focusing on national 
networks,  to  lobby  Member  States  directly.  Some  noted  that  Finance  Watch’s  role  in 
representing civil society as a whole in forums could be intensified, rather than their 
efforts  to  lobby  individual  policy  makers.  Overall,  the  view  of  interviewees  was  that 
Finance Watch was  effective in providing views to policy makers but less  effective at 
communicating its activities in this regard to members and other stakeholders. 

Some  banking  associations  have  a  good  working  relationship  with  Finance  Watch, 
exchanging  documents  and  sharing  information.  Others  see  Finance  Watch’s  role  as 
more about raising awareness than actual influence. The rationale behind this thinking 
was  down  to  the  relatively  small  size  of  the  organisation  when  compared  to 
banks  and  other  larger  stakeholders  with  more  resources.  Corporate  Europe 
Observatory,  for  example,  states  that  the  financial  sector  spends  more  than 
EUR 120 million on lobbying, with over 1,700 employees in Brussels84.  

84 Corporate Europe Observatory, The firepower of the financial lobby. Available at: https://corporateeurope.org/en/financial-
lobby/2014/04/fire-power-financial-lobby 

55 

 
 
 
3.2.1.3 

Finance Watch engaged in a variety of communication activities 

aimed at a broad spectrum of relevant groups and these were more 
effective in 2018 than 2017 

2018  saw  modest  growth 
in  terms  of  the  effectiveness  of  Finance  Watch’s 
communications. Moreover, the organisation used new media to a greater extent in 2018; 
compared to other organisations, Finance Watch is particularly effective in using social 
and  online  media.  Throughout  the  evaluation  period,  Finance  Watch  was  generally 
effective  in  engaging  the  wider  public,  policy  makers  and  industry  stakeholders. 
Nevertheless, there remains a certain share of stakeholders who are unsure about the 
effect  of  Finance  Watch’s  communication  activities,  indicating  potential  for  the 
communication to be clearer and more targeted. 

The wider public are largely engaged at a national level through the various 
national  networks  Finance  Watch  coordinates.  For  example,  as  previously 
mentioned, through the Action Network there were 136 member-led actions and events 
in 18 countries during  2017. In addition to this, Finance  Watch also holds numerous 
events throughout the year. In 2017, it held 10 events: five workshops, two webinars, 
two conferences and one forum85. In 2018, it also held 10 events, and the desk research 
revealed that the total number of attendees for these events was 477, plus 71 speakers 
and three artists86. This was a similar figure to 201787. 

The  topics  of  these  events  include  civil  society  forums,  training,  green  finance 
workshops  and  report  launches.  2017  saw  104  items  of  press  coverage  for  all 
campaigns88.  In  2018,  the  desk  research  did  not  reveal  international  media  citations 
across the board for all workstreams, however it did provide information for the flagship 
Change Finance Forum in that year, which saw 197 instances of media coverage in a 
variety  of  languages  for  this  workstream89.  In  2017,  there  were  75  interactions  with 
journalists, ranging from enquiries for comment to interviews and full article coverage 
of activities90. In 2018, there were 92 journalist interactions91. This suggests that 2018 
saw a marginally increased press awareness of the organisation, potentially due to  a 
new website. Although at present this has not yielded extra website hits, it does appear 
to have made the site  more user-friendly and statistics show that the length of time 
users  spend  on  the  site  has  gone  up  almost  30%92.  The  number  of  social  media 
interactions  has  also  gone  up:  In  terms  of  social  media,  in  2017,  the  desk  research 
showed that the number of Facebook and Twitter followers increased from 2016 by 3% 
and 10%, respectively. For 2017/2018, there was a 7% rise in Twitter followers but no 
marked increase in Facebook followers93. When looked at in relation to other groups, 
Finance Watch has more followers than COFACE, but fewer than BEUC. BEUC, however, 
is  a  much  larger  organisation  and  so  it  is  a  fair  assessment  to  say  Finance  Watch  is 
performing well in terms of its social media presence. 

Finance Watch held ‘The Crisis Anniversary Party’ in 2018 as part of the ’#10yearson’ 
campaign and launched six short videos of 1 to 2 minutes which gained 8,350 views in 

85 Finance Watch, Agenda. Available at: https://www.finance-watch.org/agenda/  
86 Finance Watch,  Agenda. Available at: https://www.finance-watch.org/agenda/; Finance  Watch,  Final Report,  2018, pp. 
30, 31, 33, 34, 58. 
87 Finance Watch, Final Report, 2017, p. 11. 
88 Finance Watch, Annual Report, 2017, p. 29. Available at: https://www.finance-watch.org/publications/ 
89 Finance Watch, Annual Report, 2017, p. 38. Available at: https://www.finance-watch.org/publications/ 
90 One example of the type of coverage can be found here: Glover, J. and Brush, S., MiFID Bond-Price Rules a Gift for Traders 
as  Just  1%  Covered,  Bloomberg,  15  December  2017.  Available  at:  https://www.bloomberg.com/news/articles/2017-12-
15/mifid-s-cautious-start-on-bond-price-rules-shows-lobbying-impact 
91 One example of the type of coverage can be found here: Donceel, H., 1EU Countries Fail to Address Banking Risk Reduction, 
EURANET  Plus  News  Agency,  4  March  2018.  Available  at:  https://euranetplus-inside.eu/eu-countries-fail-to-address-
banking-risk-reduction/  
92 Finance Watch, Final Report, 2018, pp. 42, 43, 45, 46. 
93 Finance Watch, Annual Report, 2017, p. 28; Finance Watch, Final Report, 2018, p. 42. 

56 

 
 
total94. Separate to the ‘#10yearson’ campaign, Finance Watch created videos and other 
media on educational topics. In 2017, for example, it created 19 videos, which were 
watched over 40,000 times in total on several platforms95. At over 100 views per day, 
this  makes  Finance  Watch’s  contribution  to  raising  awareness  substantial.  Generally 
speaking, Finance Watch’s YouTube videos had a higher number of average views than 
comparable  organisations,  such  as  BEUC  (which  has  a  significantly  higher  overall 
budget)96.  Finance  Watch  also  has  a  far  higher  number  of  YouTube  subscribers  than 
BEUC (1,220 and 179, respectively). Also on other social media, Finance Watch clearly 
excels and has higher number of followers on Facebook, Twitter and LinkedIn than any 
of the comparator organisations (sometimes more than 50 times higher). This suggests 
that  Finance  Watch  is  highly  effective  at  online  and  social  communication, 
which is in line with Finance Watch’s aim to target a wide public. 

During the evaluation period, Finance Watch deployed several types of media to target 
the wider public and non-expert stakeholders. One clear example is the use of cartoons. 
Although  survey  respondents  were  partly  neutral  towards  the  effect  of  the  cartoons, 
interviewees  were  far  more  positive.  Indeed,  one  of  the  banking  associations 
interviewed noted how it had recently started to create cartoons for its own 
work, after seeing how successful Finance Watch had been in this area. Finance 
Watch produced nine cartoons in 2018 and none in 2017. This form of communication 
was  mentioned  by  a  variety  of  stakeholders  as  being  very  effective  in  reaching 
audiences. The cartoons were used on social media, in reports and during the national 
network actions. For 2018, Finance Watch also initiated new methods of communication 
activities, for  example the use of livestreaming.  Its ‘Ethical Banking  Works!’  event in 
March  2018  was  the  first  Finance  Watch  event  available  through  livestream  and  484 
people followed it  on YouTube. Subsequent  events, such  as the  webinar  ‘Will finance 
save  the  planet?’  and  an  event  on  monetary  and  financial  reform  in  Barcelona  were 
livestreamed  by  around  50  people  each  time97.  This  Barcelona  event  also  had  750 
followers on YouTube. Overall, as a consequence of a dip in 2017, it appears Finance 
Watch responded with innovative communication methods in 2018.  

Use of internal and external newsletters was noted as very effective in communicating 
activities  to  stakeholders  and  members  alike.  Some  members  indicated  that  it 
allows  them  to  plan  their  time  and  when  they  can  respond  to  deadlines  for 
consultations  and  other  calls  for  input.  There  were  some  remarks  that  the 
newsletter could be adjusted and clearer, however this was couched in the context of 
small resources and deemed largely acceptable as a result.  

Responses  to  the  survey  indicated  a  high  level  of  awareness  of  the  communication 
activities of Finance Watch. The vast majority of the respondents evaluated the level of 
awareness as high or medium (61% and 27% out of 71 responses, respectively), while 
only five respondents said they had no awareness or were unable to provide an answer 
(Figure 21).  

94 Finance Watch, Final Report, 2018, pp. 38, 43, 46 47. 
95 Finance Watch, Final Report, 2018, p. 14. 
96 List of videos for BEUC available here: https://www.youtube.com/user/BEUCandTRACEvideo/videos and for Finance Watch 
here:  https://www.youtube.com/user/financewatcheurope/videos?view=0&sort=dd&flow=grid.  Finance  Watch  has,  on 
average, 821 views per video, BEUC has, on average, 249 views per video (not including one extraordinarily successful video 
of BEUC’s which attained over 210,000 views by itself). These average numbers are calculated as of February 2020 and for 
the whole period since the launch of the organisations’ YouTube channels, i.e. since 2011. 
97 Finance Watch, Final Report, 2018, p. 42. 

57 

 
 
Figure 21: Level of awareness of the communication activities of Finance Watch 
(N=71) 

3%

6%

4%

27%

61%

High awareness 

Medium awareness 

Some awareness 

No awareness 

I do not know 

Over three quarters  of  respondents stated that Finance  Watch’s work  has fulfilled its 
objective  to  inform  consumers  and  other  financial  services  end-users,  as  well  as 
stakeholders representing their interests, about issues at stake in the regulation of the 
financial sector to a very high or to a high degree. Only 5% of the respondents had a 
negative  assessment  of  Finance  Watch’s  work  in  informing  consumers  and  other 
financial services end-users and stakeholders representing their interests.  

Finance  Watch  communication  activities  to  both  expert  and  non-expert 
audiences were seen as effective in  conveying the views and perspectives  of the 
organisation’s constituency and in providing expertise. Its press releases, website and 
newsletters are considered especially effective by the respondents to the survey (Figure 
22).  

Figure 22: Finance Watch communication activities to expert and non-expert 
audiences (N=65) 

Very low 

Somewhat 
low 

Neutral 

Somewhat 
high  

Very high 

Press releases  

3.1%  

3.1%  

9.2%  

33.8%  

50.8%  

Social media 
outings  

3.2%  

3.2%  

22.6%  

48.4%  

22.6%  

Website  

1.5%  

1.5%  

12.3%  

35.4%  

49.2%  

Newsletters  

Videos  

Cartoons  

4.6%  

6.5%  

4.8%  

%  

%  

%  

12.3%  

36.9%  

46.2%  

38.7%  

38.7%  

16.1%  

47.6%  

25.4%  

22.2%  

At  an  organisational  level,  Finance  Watch  took  part  in  12  hearings  and  high-level 
roundtables in 201898. This was a change from the previous year, where Finance Watch 
took  part  in  only  three  hearings  and  14  conferences99.  The  2017  examples  include 
speaking at the HLG on Sustainable Finance and co-hosting a meeting in the European 

98 Finance Watch, Final Report, 2018, p. 54. 
99 Finance Watch, Final Report, 2017, p. 9.  

58 

 
 
 
 
Parliament  on  6  June  2017  with  seven  other  civil  society  groups,  where  DG  FISMA 
Commissioner,  Valdis  Dombrovskis,  spoke  on  the  topic  of  sustainable  finance100.  In 
2018, Finance Watch spoke twice at meetings in Paris, including the Organisation for 
Economic  Co-operation  and  Development  (OECD)  expert  meeting  on  sustainable 
finance101. The positions it presented  at these meetings and legislative  engagements 
were  complemented  and  informed  by  research  and  reports  on  the  following  topics: 
financial  supervision,  banking,  FinTech,  retail  and  financial  inclusion,  sustainable 
finance, financial markets, trade, pensions and insurance. Finance Watch’s performance 
at conference as well as their own conferences were overall viewed positively by the 
respondents to the survey (Figure 23). The majority of the respondents considered 
the  topics  discussed  at  the  conferences  as  relevant  and  the  quality  of  the 
panellists as high. The quality of follow-up,  however,  was met with a more neutral 
assessment,  indicating  room  for  improvement  in  this  area.  The  survey  also  revealed 
that 90% of respondents rated Finance Watch’s contributions when speaking on panels 
at conferences organised by third parties as ‘very high’ or ‘somewhat high.’ 

Figure 23: Conferences organised by Finance Watch (N=64) 

Very low 

Somewhat 
low 

Neutral 

Somewhat 
high  

Very high 

Relevance of the 
topic(s) discussed  

Quality of the 
panelist present  

Quality of follow-
up  

3.1%  

1.6%  

7.8%  

25.0%  

62.5%  

1.6%  

1.6%  

10.9%  

28.1%  

57.8%  

4.7%  

3.1%  

35.9%  

32.8%  

23.4%  

The majority of stakeholders (over 80%) indicated that they considered the content of 
Finance Watch communication activities useful to a quite or very high degree, and only 
three  stakeholders  said  the  activities  were  useful  only  to  a  low  degree.  Nearly  three 
quarters  of  respondents  took  the  communication  activities  of  Finance  Watch  into 
consideration as part of their policy-making and implementation efforts, to a very high 
degree or quite a high degree. However, 11 out of the 69 respondents remained neutral 
to this question, indicating that the effect of Finance Watch’s communication activities 
also has certain limits. 

Survey  results  showed  that  70%  of  respondents  regarded  Finance  Watch  as 
communicating  their  positions  to  EU  institutions  ‘very  effectively’  or  ‘effectively’. 
Another 20% of the respondents, though, replied ‘I don’t know’ to this question. This 
shows  that  there  is  still  a  significant  share  of  stakeholders  who  are  unsure 
about the effect of Finance Watch’s communication activities, and that there is 
potential for the communication to be clearer and more targeted.  

With regard to national institutions, the picture is even less clear, although 21% said 
they were unable to comment. Almost 60% of respondents did not have a clear 
view of how effectively Finance Watch communicated its positions to national 
institutions, while the remaining stakeholders assessed this communication as  very 
effective  (10%)  or  effective  (30%).  The  fact  that  the  communication  to  national 
institutions is seen as less effective is not per se surprising, as Finance Watch is mainly 

100 European Commission, Annual Activity Report 2017: Directorate-General for Financial Stability, Financial Services and 
Capital  Markets  Union,  2017.  Available  at:  https://ec.europa.eu/info/sites/info/files/file_import/fisma_aar_2017_final.pdf 
and Finance Watch, Annual Report, 2017, pp. 14-15. Available at: https://www.finance-watch.org/publications/ 
101 Finance Watch, Final Report, 2018, Annex I.  

59 

 
 
 
active  at  EU  level.  Finance  Watch  has  recently  also  expanded  its  activity  at  national 
level, for example by establishing national entities in Germany and France. 

At the European level, Figure 24 shows that three quarters of the survey respondents 
stated  that  they  have  a  good  or  even  full  awareness  of  Finance  Watch’s  position  on 
European issues in the area of financial services. Finance Watch can thus be seen as on 
the  whole  very  effective  in  this  area.  They  should  however,  as  with  other  areas, 
concentrate greater resources on discovering why the 10% who have no or only limited 
awareness – mostly national authorities – are harder to reach and, if viable, remedying 
this. 

Figure 24: Knowledge of Finance Watch position/perspective on European issues in 
the area of financial services (N=31) 

7%

3%

32%

16%

42%

I have no knowledge on the 
beneficiary's stance on this topic 

I have limited knowledge on the 
beneficiary's stance on this topic 

I have some knowledge on the 
beneficiary's stance on this topic 

I have good level of knowledge 
on the beneficiary's stance on 
this topic 
I am fully aware of the 
beneficiary's stance on this topic 

3.2.1.4 

Finance Watch effectively delivered expertise in the area of 

financial services and the organisation is seen as useful by policy makers 

During  the  evaluation  period  there  were  strong  qualitative  and  quantitative  outputs, 
which resulted in the organisation being well-regarded by policy makers, as well as being 
understandable to a wider public and providing fresh and relevant information. There has 
been a tendency to produce shorter outputs in favour of a higher publication rate, which 
comes  with  the  risk  that  the  outputs  do  not  have  sufficient  substance  for  expert 
audiences.  

Finance Watch delivered relevant expertise in the area of financial services in 2017 and 
2018.  In  2017,  Finance  Watch  published  21  items.  This  included  eight  briefings  and 
papers, one open letter, and three speeches given at public hearings102. In 2018, the 
publication  number  increased  to  23.  Topics  included  for  instance  a  policy  brief  on 
remittances,  two  global  green  finance  index  reports  and  reports  on  non-performing 
loans and Brexit.  

The number of events, as previously mentioned, remained steady at 10 per year across 
the evaluation period, the only contrast was that in 2018 Finance Watch also held 25 
network  meeting  events  to  develop  its  networks  across  Europe.  This  activity  was 
well-received  by  members  and  other  audiences,  with  over  90  speakers  at 
member  events  since  January  2018103.  Among  the  different  events  organised  by 
Finance Watch, the Change Finance Forum 2018 was indicated as particularly relevant 
by  the  survey  respondents.  The  event  was  singled  out  not  only  for  the  networking 
opportunities,  but  for  bringing  together  organisations  and  stakeholders  beyond  the 

102 Finance Watch, Annual Report, 2017, p. 27. Available at: https://www.finance-watch.org/publications/ 
103 Finance Watch, Final Report, 2018, p. 30. 

60 

 
 
 
‘usual suspects’, providing different perspectives on a shared agenda (e.g. organisations 
working  on  climate  change  and  biodiversity).  Several  interviewees  pointed  out  that 
Finance Watch played a very effective role in creating and expanding networks. 

The  review  of  sources  outlined  some  key  statistics  with  regard  to  the  usefulness  of 
Finance  Watch’s  expertise  to  members,  policy  makers  and  other  stakeholders.  When 
comparing press coverage between the two evaluation years, there was a 60% rise in 
unique  articles  referencing  Finance  Watch’s  work104.  A  further  breakdown  of  2018 
reveals  that  this  was  formed  of  21  different  EU  media  outlets,  99  references  in  EU 
countries and nine mentions in non-EU countries105. This shows that the work being 
done  by  Finance  Watch  is  internationally  used  and  widely  regarded  as 
important. Topics on which Finance Watch has been asked for comment by journalists 
include  Bitcoin,  ethical  banking,  robo-advising,  insurance  and  pensions.  This  was 
complimented by 49 speaking invitations at external events in 2018 alone106. Indeed, 
the  overall  picture  is  one  where  the  ecosystem  values  Finance  Watch’s  contributions 
increasingly across the two evaluation years.  

Stakeholders  reported  appreciation  for  the  work  of  Finance  Watch  in  replying  to  EU 
public  consultations  (Figure  25).  Almost  half  of  stakeholders  considered  the 
responses themselves to be understandable to a ‘very high’ degree. The vast 
majority (86%) also saw the responses as reflecting the points of view of the members 
and providing relevant input to policy makers.  

Figure 25: Evaluation of Finance Watch’s responses to consultations (N=69) 

Very low  Somewhat 

Neutral  

low 

Somewhat 
high 

Very high 

Understandable  

1.4%  

2.9%  

10.1%  

36.2%  

49.3%  

Reflecting points 
of view of the 
members to 
represent an in-
depth view  

Providing relevant 
input for policy 
makers  

1.4%  

2.9%  

8.7%  

46.4%  

40.6%  

1.4%  

2.9%  

10.1%  

27.5%  

58.0%  

In terms of the quality of research output, the stakeholders surveyed reported a strong 
appreciation for the research work carried out by Finance Watch (Figure 26). Over three 
quarters of stakeholders considered the work understandable to the wider public and 
almost 80% considered the work properly timed to support the needs of policy makers 
and the wider public when it emerges. 

104 Finance Watch, Final Report, 2017, p. 11; Finance Watch, Final Report, 2018, p. 59. 
105 Finance Watch, Final Report, 2018, p. 43.  
106 Finance Watch, Final Report, 2018, pp. 47, 58. 

61 

 
 
 
Figure 26: Evaluation of Finance Watch’s own research work (N=25) 

Very low 

Somewhat 
low 

Neutral 

Somewhat 
high  

Very high 

4.0%  

8.0%  

12.0%  

36.0%  

40.0%  

4.0%  

4.0%  

4.0%  

32.0%  

56.0%  

4.2%  

4.2%  

12.5%  

29.2%  

50.0%  

Is 
understandable 
to a wider public  

Provided 
additional 
information to 
existing views  

Is properly timed 
(serve the 
current needs of 
policy makers 
and the wider 
public).  

Coupled with the survey results, individual interviewees remarked that the quality 
of research reports and papers was very high. Among Finance Watch’s publications 
and papers, respondents pointed to some as particularly helpful, namely:  

•  Review of the Consumer Credit Directive;  
•  All of the consultation papers on capital markets;  
•  Responses  to  ESMA  consultation  papers  on  suitability  requirements  guidelines 
under MiFID II and on integrating sustainability risks and factors in MiFID II;  

•  The publication, ‘How to make finance serve society’.  

The survey results (Figure 27) show that more than two thirds of the respondents found 
the research work and position papers of Finance Watch useful to a high or very high 
degree.  There  were  nonetheless  also  10%  of  respondents  who  did  not  find  Finance 
Watch’s publications very useful (including two of their own members). 

Figure 27: Level of usefulness of Finance Watch’s research work and position papers 
(N=71)  

Very high 

High 

Medium 

Low 

Very low 

I do not know 

4%

4%

3%

18%

31%

39%

62 

 
 
 
Furthermore,  83%  of the  respondents indicated that  Finance Watch’s  research work, 
policy papers, responses to consultations and studies fulfilled their needs at the time of 
release,  at  least  to  some  extent.  Additionally,  less  than  3%  of  respondents  found  it 
irrelevant to their needs at the time of release.  

Many of the stakeholders highlighted how the expertise provided by Finance Watch 
was  used  in  their  national  debate,  in  a  few  cases  even  translating  Finance 
Watch publications into their national language. Most  of those interviewed  said 
that they relay the information contained in Finance Watch reports and papers to their 
own members or stakeholders. Respondents also stressed how the expertise provided 
by Finance Watch made it possible for them to acquire in-depth knowledge and form 
opinions, in a way that would not have been possible otherwise. However, stakeholders 
also noted that the type of information delivered during the evaluation period 
was  perceived  by  those  interviewed  as  generally  shorter  and  less  in-depth 
than in the years before the evaluation period. Some members commented that 
while  these  compact  reports  are  still  useful,  they  do  not  provide  enough  insight.  As 
Finance Watch has a broad target audience  ranging from the wider public to  experts 
and policy makers, it makes somewhat sense to create easily accessible publications, 
but the risk of losing expert audiences should not be neglected in the future. 

It is clear that all stakeholders contacted – including Finance Watch members, policy 
makers and industry stakeholders – see a place for Finance Watch in the financial policy 
ecosystem.  One  interviewee  representing  a  banking  association  described  Finance 
Watch as ‘part of the ecosystem’, providing the crucial consumer element that would 
otherwise be missing. Although there are some small disagreements regarding specific 
workstreams and style of publications, there is broad agreement that Finance Watch is 
an effective and crucial addition to the policy mix. 

3.2.1.5 

Finance Watch has clear prioritisation methods for selecting 

activities and has an open performance monitoring system 

During  the  evaluation  period,  Finance  Watch  had  clear  methods  for  the  selection  of 
activities,  at  a  variety  of  appropriate  levels  (Board,  members  etc.).  The  performance 
monitoring  system  could  have  been  more  structured  and  consistently  applied  at  key 
intervals. However, across the two years, developments appear to have already moved 
in this direction. 

A General Assembly occurs twice a year, where input is given by the membership into 
strategic planning, including the selection of relevant activities. This was seen by the 
membership to be a very transparent process, with lots of authority given to 
members to shape the process. One tension between members and the Secretariat 
comes from the difficulty in reconciling what is possible and where an impact can be 
made with what is needed. Further tensions arise where members wish to look at topics 
of importance at national level, but Finance Watch has a mandate to look at EU level. 
In these circumstances, members prioritisation methods are circumvented and internal 
Finance Watch prioritisation methods decide how to allocate resources. 

In  terms  of  performance  monitoring,  throughout  the  years  of  the  evaluation  Finance 
Watch organised at least one membership survey so it could provide feedback and vote 
on  proposed  key  action  priorities  for  the  year.  This  is  in  addition  to  the  General 
Assemblies,  where  members  review  progress.  On  occasion,  Finance  Watch  also  held 
workshops to leverage the expertise of the membership. Generally speaking, members 
felt there was an ‘open door policy’ to providing input on certain topics. Finance 
Watch was largely described as open, forthcoming and constructive. The main challenge 
raised was to ensure that Finance Watch applies these performance  monitoring tools 
consistently.  

63 

 
3.2.1.6 

A number of internal and external factors limited the 

effectiveness of Finance Watch during the evaluation period 

Perceptions  of  obstacles  were  related  to  funding,  organisational  changes  of  Finance 
Watch and high reliance on the political agenda. However, none of these other obstacles 
are strong enough to cause concerns regarding effectiveness. 

The  desk  research  provided  some  clear  context  for  the  evaluation  of  effectiveness 
across the two years. There was wide support for the multi-year strategy approved at 
the 2016 AGM, with a renewed Board and leadership. However, this was in the context 
of financial difficulties in 2015/2016, with a decrease in human resources and income 
ahead  of  the  beginning  of  the  evaluation  period  in  2017107.  As  a  consequence  the 
organisation  moved  from  a  function-led  approach  to  a  project-led  approach  in  2017, 
with the additional support of an Executive Director to support the Secretary General 
and the merging of their Public Affairs Team and Policy Analysis Team into a Research 
and  Advocacy  Team.  Similarly,  the  Communications  Team  was  merged  with  the 
Membership Team into a combined Outreach division. These changes were intended 
to facilitate better coordination, but interviews with Finance Watch revealed 
that at least one of the initiatives, the Executive Director role, is regarded as 
unsuccessful by the organisation itself. According to the interviews, though, these 
organisational challenges had been largely overcome by 2018. 

Almost all of the interviewees corroborated the literature and pointed to the leadership 
and internal human resource challenges of 2017 as a factor negatively affecting overall 
effectiveness  in  the  evaluation  period.  The  largest  external  factor  was  noted  as  the 
general  slowdown  in  the  policy  agenda  in  the  area  of  financial  services  by  the 
Commission in 2017/2018 compared to previous years. In this area, Finance Watch 
was deemed to be slightly too reliant on reacting to legislative proposals and 
when these decreased, its activities dropped off.  

The question of overall funding and budgets was naturally mentioned as a key obstacle. 
Based on the survey results, the lack of funding was identified as the  main challenge 
for Finance Watch in reaching its set objectives (Figure 28). Member organisations also 
felt  that  with  more  than  half  of  the  funding  coming  from  the  Commission,  Finance 
Watch relies heavily on the grant and therefore does not have a wide enough 
financial base. Furthermore, the administrative burden placed on the Secretariat by 
Commission  reporting  standards  was  deemed  a  factor  in  decreasing  the  overall 
availability of resources for actual advocacy and research.  

Figure 28: Obstacles hindering Finance Watch from achieving its objectives (N=71) 

Very low  Somewhat 

Neutral 

low 

Somewhat 
high 

Very high 

Lack of funding  

4.2%  

4.2%  

14.1%  

35.2%  

42.3%  

Lack of expertise  

48.6%  

20.0%  

17.1%  

7.1%  

7.1%  

Poor scoping/focus 
areas  

Poor advocacy 
work  

35.7%  

24.3%  

25.7%  

11.4%  

2.9%  

35.7%  

32.9%  

25.7%  

4.3%  

1.4%  

Poor research work  

50.0%  

24.3%  

17.1%  

4.3%  

4.3%  

107 Finance Watch, Final Report, 2017, p. 4. 

64 

 
 
 
Outside  of  the  financial  challenges,  the  main  issue  that  came  through  from  the 
interviews was the general fatigue among policy makers, and indeed the public, 
on  tackling  issues  in  the  area  of  financial  reform.  The  feeling  among  the 
interviewees  was  that  momentum  gained  after  the  2008  crisis  has  now  gone  and 
political will to reform the system is waning. 

3.2.1.7 

Key findings 

Based on survey results and interviews, the work carried out by Finance Watch during 
the evaluation period was overall very effective in engaging end-users and non-industry 
stakeholders.  Finance  Watch’s  contributions  are  valued  by  others  in  financial 
regulation, and it performs a coordinating role for national activities to involve 
end-users through campaigns, community events, art, rallies and street actions. So far, 
however, members contacted have not noted much greater involvement of end-users 
in the policy-making process as a result of these actions. 

Finance Watch responded to 18 EU consultations across both evaluation years, 
providing  input  into  the  policy  making  process,  but  as  there  were  at  least  40 
potentially relevant public consultations  on financial policy  Finance Watch could have 
been more active in this area. Finance Watch participated in European advisory groups, 
with the number of positions on these groups increasing in 2018 compared to 2017. 
Finance Watch became more involved in the policy-making process as a result, and in 
different areas.  

Its  publications  are  valued  highly,  as  are  its  campaigns  and  events.  Desk 
research revealed an increase in the overall number of publications in 2018 compared 
to 2017. The majority of those interviewed, however, stated that during the evaluation 
period, the type of research being delivered was not as substantial as in previous years, 
instead being shorter and less in-depth: this shift has both a positive side (making the 
documents  more  accessible)  and  a  negative  side  (providing  less  detailed  expertise). 
This  can  be  partly  explained  by  the  strategic  plan  for  2017-2018,  which  mentions 
Finance  Watch  moving  to  become  a  ‘spider  in  the  web’  rather  than  a  ‘do  it  yourself’ 
approach  to  research  and  in  the  process  increasing  the  involvement  of  its 
membership108.  Finance  Watch  thus  needs  to  be  attentive  to  maintaining  the  right 
balance between serving the wider public and expert audiences alike. Overall, however, 
members and stakeholders alike still considered the quality and usefulness of Finance 
Watch’s outputs and expertise as high.  

The  national  networks  are  also  an  effective  feature  of  Finance  Watch.  Its 
members act as information multipliers, meaning that their members in turn are better 
equipped to engage in policy discussions at national and European level.  

Finance Watch informed the public about issues at stake in the regulation  of financial 
markets through its members and coordinated actions at national level. The events it 
ran  were  a  key  element  of  this  outreach,  although  it  was  difficult  to  assess  the 
effectiveness of these events in terms of engaging consumers. Some key outputs, such 
as the Change Finance Forum in 2018, attracted good media coverage and appeared to 
be effective at engaging consumers.  

One area to be improved is that Finance Watch could better capitalise on engagements 
with journalists or more effectively record the outcomes of engagement with the media. 
Having said this, the desk research shows that work being done by Finance Watch 
is  picked  up  and  promoted  internationally  by  media  outlets  in  both  EU  and 
non-EU  countries.  The  organisation  overall  became  more  effective  in  raising 
awareness  among  a  broader  audience,  and  media  mentions  increased  in  2018 
compared  to  2017.  Members  and  stakeholders  alike  found  its  expertise  relevant  and 
often used its materials to inform national debates.  

108 Finance Watch, Strategic Plan 2017-2019, 2016, p.6.  

65 

 
 
Overall, Finance Watch took positions on the main European issues related to financial 
services. It covered a very broad number of topics and was a reference point for many 
stakeholders and members. However, it has become clear that those surveyed were 
not always fully aware of Finance Watch’s positions on certain issues, indicating 
that  communication  tools  could  have  been  applied  in  a  more  consistent  fashion  or 
tailored  to  specific  stakeholders.  Members  and  stakeholders  generally  see  Finance 
Watch  as  good  at  raising  awareness,  but  were  unable  to  pinpoint  its  influence  on 
legislation due to the lengthy EU legislative process.  

Finance Watch deployed new communication tools in 2018, for example livestreaming 
workshops  and  seminars.  Compared  to  other  organisations,  Finance  Watch  is 
very adept at using online and social media and achieves very high exposure. 
However,  while  the  readability  and  understandability  of  its  communication  activities 
were rated highly, stakeholders expressed some reservations regarding the degree to 
which  Finance  Watch  followed  up  after  events,  workshops  and  seminars.  Overall, 
though,  members  and  stakeholders  valued  the  communications,  especially  the 
newsletters and cartoons.  

Finance  Watch  is  perceived  by  its  members  to  be  open  to  suggestions 
regarding the focus of its work. The members interviewed generally acknowledged 
that  a  membership  organisation  must  reconcile  different  perspectives.  The  Annual 
General  Meeting,  workshops  and  strategy  sessions  were  all  seen  as  transparent  and 
democratic  methods  of  agreeing  priorities.  The  members  felt  that  the  surveys  that 
Finance Watch runs throughout the year could be implemented more consistently and 
regularly, although they were highly valued. 

Lack of funding was identified as the main obstacle to effectiveness, along with 
several  human  resources  changes  that  required  a  rebuilding  of  expertise  during  the 
evaluation  period.  The  creation  and  failure  of  the  Executive  Director  role  was  one 
setback that hindered the organisation’s effectiveness during the evaluation period. 

3.2.2  Efficiency 

This  subsection  evaluates  the  efficiency of Finance Watch.  It  covers  the  following 
key topics: Finance Watch’s use of resources in relation to  its outputs; feedback and 
monitoring  systems  put  in  place  by  Finance  Watch;  and  Finance  Watch’s  sources  of 
funding (see Annex 5.1 for further detail on the evaluation questions). 

3.2.2.1 

Finance Watch’s level of efficiency is similar to comparable 

organisations 

Between 2017 and 2018, Finance Watch slightly increased its expenditure and also its 
main  outputs,  thus  maintaining  a  stable  level  of  efficiency.  Overall,  Finance  Watch 
achieved a level of efficiency comparable to other organisations. 

Table  6  below  presents  the  costs  and  main  outputs  of  Finance  Watch  during  the 
evaluation period, based on data taken from its annual reports.  

66 

 
Table 6: Costs and main quantifiable outputs of Finance Watch 

2017 

2018 

Activity area 

Direct 
costs in 
EUR109 

Direct 
costs 
scaled110 

Output description 

Direct 
costs in 
EUR 

Output description 

425,386 

638,079  Expert groups: 4 

832,665  Expert groups: 6 

Expertise and 
policy analysis; 
advocacy and 
public 
affairs111 

Communi-
cations 

Membership 
coordination 
and 
development  

Strategic 
development 

Campaign112 

Reports: 2 
Briefings and papers: 
4 
Responses to public 
consultations: 7 
Public hearings: 3 
Public interventions: 
14 
Videos: 19 

Reports: 5 
Briefings and papers: 
9 
Responses to public 
consultations: 6 
Public hearings: 12 
Public interventions: 
48 
Videos: 20 
Cartoons and 
animations: 15 

196,495 

294,743  Events: 10 

299,418  Events: 10 

Press releases: 13 
Journalist 
interactions: 75 
Press coverage 
(unique articles): 81 
Newsletters: 5 
Blog posts: 4 
Webinars: 2 

Press releases: 17 
Journalist 
interactions: 92 
Press coverage 
(unique articles): 129 
Newsletters: 10 
Blog posts: 20 
Webinars: 2 
New website launched 

130,843 

196,265  Working groups: 1 

218,492  Working groups: 7 

Member updates: 22 
General Assemblies: 
2 
New members: 8 
Member surveys 

Member updates: 30 
General Assemblies: 2 
New full members: 4 
New associate 
members: 16 
Membership surveys 

227,119 

340,679  Dialogue with existing 

99,666  Dialogue with existing 

donors 
New funding 
obtained: EUR 
303,657 
Various strategic 
activities for the ‘10 
years on’ campaign 

donors 
New funding 
obtained: EUR 
650,000 

N/A 

N/A 

307,942  Various strategic 

activities for the ‘10 
years on’ campaign 
Working group 
meetings: 143 
Campaign activities: 
136 

TOTAL 

979,843 

1,469,765 

1,758,183 

109 Reported figures for the relevant grant period (1 May 2017 to 31 December 2017). 
110 While the reported figures  for 2017 cover eight  months, the reported figures  for 2018 cover 12  months. To allow for 
easier comparison between the two years, the costs in this column are calculated by scaling the reported costs by 1.5.  
111 The activity areas ‘Expertise and policy analysis’ and ‘Advocacy and public affairs’ were merged in 2017. 
112 The activity area ‘Campaign’ was introduced in 2018, incorporating certain activities that were previously run under the 
activity area ‘Strategic development’. 

67 

 
 
 
 
 
 
From 2017 to 2018, Finance Watch’s expenditure saw an increase by about one-
fifth, from EUR 1,469,765 (scaled) to EUR 1,758,183. Most of this increase went into 
the activity area ‘Expertise and policy analysis, advocacy and public affairs’. The main 
output  in  this  area  increased  even  beyond  a  simple  extrapolation  of  the 
increased  expenditure,  which  indicates  an  efficiency  increase  in  terms  of 
number  of  outputs  (although  stakeholders  also  pointed  out  that  the  reports  have 
become  less  in-depth).  In  the  other  activity  areas,  the  cost-output  rate  was  rather 
stable between 2017 and 2018, which indicates that the same level of efficiency  was 
maintained.  The  activity  area  ‘Strategic  development’  included  a  large  campaigning 
element in 2017, which was separated into a specific ‘Campaign’ activity area in 2018. 
In general, in 2017, Finance Watch faced problems with funding, followed by 
some staff turnover, change of Secretary General etc., all of which negatively affected 
efficiency. In 2018, its activity picked up again, which is reflected in its KPIs.  

Table 7 presents the output of the three comparator organisations active in the 
area  of  financial  services  in  2017,  based  on  publicly  available  sources  and  input 
collected from the organisations themselves. 

Table 7: Output of consumer organisations (2017) 

Activities 

Finance Watch 

COFACE113 

AGE Platform 
Europe114 

BEUC115 

Communication output 

16 press releases 
within financial 
services116 
28 publications 
within financial 
services117 

6,500 

70 

27 

Press releases / 
newsflashes 

Monthly 
newsletters 

Social media 
campaigns 

Videos 

Press quotes 

Press interviews 

Blogs 

Reports and EU 
projects 

Working groups 

Events 

Statutory 
meetings 

13 

5 

19 

81 

75 

4 

2 

1 

10 

2 

16 

11 

6 

30 

Policy output 

3 research projects 
3 EU assessments 
6 policy updates 

20 

11 

19 

9 

Speaker at over 30 
events 

4 (co-organised) 
140 (contributed to) 

9 

113  COFACE  Families  Europe,  2017  Annual  Report,  2017.  Available  at:  http://www.coface-eu.org/resources/annual-
reports/2017-annual-report/ 
114 AGE Platform Europe, AGE Annual Report 2017. Available at: https://age-platform.eu/content/age-annual-report-2017 
115 BEUC, Annual report 2018. Available at: https://annualreport.beuc.eu/ 
116 BEUC, Press releases financial services. Available at: http://www.beuc.eu/press-media/press-
releases/financial%20services/54?tid%5B0%5D=5&tid%5B1%5D=6&page=3 
117 BEUC, Financial services, Publications. Available at: http://www.beuc.eu/financial-services?page=6#publications 

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Activities 

Finance Watch 

COFACE113 

AGE Platform 
Europe114 

BEUC115 

Position papers 
and policy 
briefings 

EU or global 
consultations 

Consultative 
groups/ 
workshops 

EP reports with 
amendments 

Lectures/training  

Joint statements 
with European 
NGOs 

Website views 

European 
parliamentary 
blog views 

Twitter followers 

No. tweets 

Fb followers 

No. Fb posts 

LinkedIn 
followers 

% ratio 

4 

7 

4 

21 

13 

33 

6 

8 

10 

4 

10 

12 

Online traffic 

+119,195 

+1,292 

3,316 

510 

1,070 

47 

Spending breakdown 

Advocacy and 
research: 44% 
Communications: 
20% 
Membership 
coordination: 13% 
Strategic 
development: 23% 

Advocacy: 40% 
Research: 10% 
Communications: 
20% 
Networking: 30%118 

Ratio on average is: 
60-70% policy work 
40-30% project 
work. 
Budget is not 
divided per types of 
activities but per 
types of spending119 

8,500 

1,573 

1,345 

N/A 

As pointed out before, when drawing comparisons between these organisations, their 
differences  need  to  be  taken  into  account  (see  also  page  24).  Of  the  three 
comparator  organisations,  AGE  Platform  Europe  is  most  comparable  to 
Finance  Watch,  as  both  organisations  have  a  similar  number  of  employees 
(around 12-15) and members (80-100) and receive a comparable amount of EU grant 
funding  (around  EUR  1.1 million).  COFACE  is  only  half  as  large  as  Finance  Watch  in 
terms  of  membership,  employees  and  available  budget.  BEUC  has  a  wider  variety  of 
consumer topics on its agenda but has a dedicated team of four employees focusing on 
financial services. Overall, the organisation is significantly larger than Finance Watch in 
terms  of  staff  (around  40)  and  available  budget  (EUR  5.5 million).  In  addition,  the 
organisations do not count their outputs in the same way, so direct comparisons need 
to be interpreted with care. 

118 Based on feedback from a stakeholder from COFACE. 
119 Based on feedback from a stakeholder from AGE Platform Europe. In its 2018 final accounts, the total expenditures are 
divided as follows: EUR 1,389,623, of which EUR 798,164 was for the REC Programme and EUR 600,459 for projects.  

69 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
When  comparing  expenditure  and  output  of  these  organisation,  Finance  Watch 
appears to achieve a similar level of efficiency by producing rather similar outputs 
at rather similar levels of spending. In direct comparison with Better Finance (see 
Section 3.1.2.1), Finance Watch seems less efficient, particularly in view of the 
fact that Finance Watch receives almost three times as much funding from the Union 
Programme. 

3.2.2.2 

Stakeholders perceive Finance Watch as an efficient 

organisation  

Stakeholders  agreed  that  Finance  Watch  works  efficiently  and,  overall,  ensures  good 
value  for  money.  Some  minor  improvement  points  were  nevertheless  raised,  linked  to 
Finance Watch’s move between offices and its use of external consultants. 

One minor issue was brought up on several occasions during the interviews: for a short 
period while moving offices, Finance Watch ended up paying double rent due 
to  administrative  inefficiencies.  Furthermore,  there  were  complaints  from  some 
members in the past that Finance Watch is too reliant on consultants, although others 
in  the  membership  state  that  this  actually  allows  the  greater  flexibility  needed  in  an 
organisation with only annual funding streams. Overall, all interviewees agreed that 
these issues were minor when discussing value for money and that Finance Watch 
delivered very high-level results when looking at its resources and delivery timeframe 
during the evaluated period.  

In  terms  of  similar  benchmarks,  the  interviews,  including  with  other  consumer 
organisations,  did  not  offer  any  examples  of  superior/more  formal  or  sophisticated 
systems for ensuring value for money than those of Finance Watch. They agreed that 
they  themselves  follow  a  similar  system  to  Finance  Watch  in  ensuring  best  value  for 
money and agreed with the overall strategic approach followed by Finance Watch.  

3.2.2.3 

Finance Watch has established budget monitoring tools and a 

feedback system to allocate resources efficiently 

Finance Watch established monitoring tools and a feedback system to efficiently use its 
resources. However, there is no analytical accounting that would allow it to establish a 
direct link between costs and outputs within the specific activity areas. 

Among  the  tools  mentioned  by  Finance  Watch  are  annual  reporting,  monthly  team 
meetings, quarterly meetings with the  Board, and regular project reviews. Regarding 
setting  the  priorities  of  Finance  Watch,  the  process  of  planning  starts  with  a  multi-
annual  strategic  plan  –  there  was  one  established  for  2017-2019.  The  Secretariat 
proposes the basis of the strategy to its members, which is followed by discussions with 
the Board. Research and advocacy strategic plans are very linked to the EU agenda and 
therefore follow their objectives. The Board approves the agenda on an annual basis. 
The agenda is flexible and strives to remain in line with EU political changes and needs 
of the members. Finance Watch also follows up on requests from MEPs to check their 
work, provide opinions on the specific topics, etc. This type of work is organised on an 
ad hoc basis. 

During  the  evaluation  period,  Finance  Watch  tended  to  collect  feedback  from 
participants at conferences and events in a rather informal manner, via email, 
etc. Starting from 2019 (outside the evaluation period), regular surveys are organised 
to  increase  the  response  rate.  Certain  KPIs  related  to  media  are  also  an  important 
monitoring  tool  for  Finance  Watch,  such  as  press  clippings  (mentions  in  the  press), 
quotes  of  Finance  Watch  in  media,  engagement  rate  in  social  media  (commenting, 
linking, retweeting).  

70 

 
3.2.2.4 

Finance Watch made some attempts during the evaluation 
period to diversify its sources of funding but it continues to look for 
other solutions in this regard 

Finance  Watch  actively  sought  financing  sources  to  diversify  its  income.  Its  share  of 
income from third-party donors (41%) is very high compared to similar organisations. 

In  2017,  substantial  new  funding  commitments  were  received  from  the  MAVA 
Foundation for two projects of 12 and 18 months, respectively. This drew in a total of 
EUR 303,657 across the year. For 2018, a new funding stream was secured from the 
European Climate Foundation in Berlin for a six-month grant, totalling EUR 60,000. 

Between  2017  and  2018,  funding  from  third-party  donors  slightly  increased,  while 
funding  from  members  slightly  decreased.  The  share  of  Finance Watch’s  income 
not coming from EU funding thus only increased slightly, by one percentage 
point.  

In 2018, efforts to secure new funding were also actioned through meetings and calls 
with  potential  donors,  and  the  Secretary  General  also  participated  in  a  three-day 
workshop  in  Portugal  with  a  consortium  of  potential  donors,  although  it  was  unclear 
from  the  reviewed  sources  the  extent  to  which  this  was  successful120.  In  terms  of 
maintaining existing funding, the organisation holds regular meetings, conference calls 
and workshops with those who have already supported Finance Watch with donations. 
One external factor noted in the reviewed sources was the delay in the renewal of the 
Open  Society  Initiative  for  Europe  (OSIFE)  contract,  which  ended  in  July  2018,  until 
2019, as  a result of a  review  of  its strategy. This funding represented around 6%  of 
Finance  Watch’s  total  yearly  funding121.  In  more  qualitative  terms,  the  reports  and 
reviews all noted that 2018 was a difficult period financially, as the Secretary 
General, who carries the responsibility for fundraising, suffered from a lack of 
time to perform proactive fundraising. This was linked to an increased workload as 
a consequence of a lack of seniority among newly recruited staff and the failure of the 
newly created Executive Director role in 2017122. 

The interviewees  emphasised that issues around diversifying income  are faced by all 
NGOs  and  networks.  There  was  concern  from  the  members  and  stakeholders 
interviewed that Finance Watch has been spending quite a lot of time trying to diversify 
income recently, which has led to outputs elsewhere decreasing, for example research. 
However,  the  general  impression  is  that,  despite  efforts,  the  income 
diversification  plan  could  be  improved.  The  majority  of  those  interviewed  also 
admitted, though, that the topic of financial regulation is not the easiest to raise money 
for.  

Like  for  Better  Finance,  a  representative  from  the  European  Commission  highlighted 
the importance of the viability of Finance Watch and its business model. According to 
the  interviewee,  it  is  crucial  to  ensure  the  financial  independence  of  the 
beneficiary in the long run. 

In interviews, Finance Watch itself confirmed that 2017 was more focused on finding 
donors and funding, as well as ongoing recruitment. Therefore, capacity was stretched, 
and an insufficient amount of time was dedicated to the topic of fund diversification. In 
2018 and afterwards, this point has become a priority of the Secretary General, who 
has more staff support and is looking for new solutions. According to interviewees, the 
rise  of  the  sustainable  finance  agenda  helps  Finance  Watch  with  finding 
donors.  NGOs  in  general  do  not  know  the  topic  of  finance  well  enough  to  work 

120 Finance Watch, Final Report, 2017, p. 47. 
121 Finance Watch, Final Report, 2017, p. 50. 
122 Finance Watch, Final Report, 2017, p. 49. 

71 

 
 
independently and therefore need to rely on Finance Watch. It was also mentioned that 
Finance Watch sometimes receives small donations from other organisations, but this 
is not very systematic. 

When  comparing  the  income  structure  of  other  consumer  organisations  active  in  the 
area of financial services, similar income streams are noted. However, unlike Finance 
Watch,  some  organisations  –  such  as  BEUC  or  Better  Finance  –  rely  heavily  on 
membership  fees  (36%  and  25%  of  funding  sources  in  2018,  respectively).  AGE 
Platform  Europe  and  COFACE  are  mostly  financed  from  EU  funds  with  limited  own 
funding and third-party funding. BEUC is a larger organisation whose operating income 
is significantly higher than that of Finance Watch123. AGE Platform Europe, as a smaller 
organisation, is more comparable to Finance Watch in terms of income, but EU funds 
remain the main funding source of  its activities (based on financial information  from 
2018)124.  

Table 8 shows an overview of the funding sources of Finance Watch and the consumer 
organisations that were selected for comparison.  

Table 8: Funding Sources of consumer organisations* 

Type of funding 

Finance 
Watch125 

Better 
Finance126 

COFACE127 

AGE 
Platform 
Europe 

BEUC 

1.  Own funding 

2.5% 

38% 

10% 

11% 

49% 

Membership 
fees 

Donations, 
registrations 

2.  Third-party 
funding/ 
other 

2.3% 

25% 

10% 

0.2% 

13% 

N/A 

8% 

3% 

36% 

13% 

41% 

3% 

10% 

2% 

2% 

3.  EU funding 

57% 

59% 

80% 

87% 

57% 

59% 

80% 

N/A 

49% 

30% 

N/A 

N/A 

N/A 

N/A 

19% 

*Funding sources in 2018 expressed as percentage of total resources 

Overall, although all five organisations vary in size, activity level and specific expertise, 
they are all heavily dependent on EU grants, which raises the issue of sustainability of 
such a funding model. Having said that, Finance Watch took some steps to diversify its 
funding  streams,  with  over  40%  of  resources  in  2018  coming  from  third  parties, 
including  foundations  and  private  donations.  COFACE  as  a  comparable  organisation, 
obtains 10% of funds through third parties, whereas results from the remaining three 
organisations  in  this  category  remain  even  lower  (between  2-3%  of  total  funding 
sources).  Finance  Watch’s  share  of  third-party  funding  is  by  far  the  highest 
among  the  comparator  organisation,  showing  that  Finance  Watch  is  more 
successful in obtaining this type of funding. At the same time, since Finance Watch 
has the lowest income share from membership fees (which is also linked to its specific 
membership structure), there is a higher necessity to find alternative funding sources.  

123 BEUC, Financial Information, 2018. Available at: https://www.beuc.eu/about-beuc/financial-information 
124 AGE Platform Europe, Financial Resources, 2018. Available at: https://www.age-platform.eu/financial-resources  
125 Based on Finance Watch Grant Report 2018. 
126 Based on Better Finance Grant Report 2018. 
127 Based on input provided by the stakeholder from COFACE. 

72 

operating/ 

EU 
action grant 

EU 
institution 
funded projects 

 
 
3.2.2.5 

Key findings 

Finance  Watch  increased  its  spending  from  2017  to  2018  by  about  one-fifth.  The 
outputs  reported  in  its  annual  reports  also  generally  increased;  however,  from  the 
sources it is not always clear the extent to which the report provides comprehensive 
information.  Overall,  Finance  Watch  seems  to  operate  as  efficiently  as  most 
other comparable organisations but appears to be less efficient than Better Finance 
(though  direct  comparisons  are  difficult,  given  the  different  activities  of  these 
organisations). 

Two  minor  points  were  mentioned  by  stakeholders  where  the  use  of  resources  was 
potentially  not  optimal.  One,  for  a  certain  period,  Finance  Watch  was  moving  offices 
and had to pay rent for two locations simultaneously. Two, some stakeholders criticised 
its  reliance  on  external  consultants  (but  others  highlighted  the  value  of  these 
consultants for Finance Watch’s research outputs). 

Besides  funding  from  the  EU  grant,  by  far  the  main  contribution  to  Finance  Watch’s 
resources  came  from  third-party  donors128  (over  90%  of  its  resources  not  from  EU 
funding).  Finance  Watch’s  income  from  third-party  sources  is  significantly 
higher than any of its comparator organisations. Funding from membership fees 
accounts  for  less  than  10%  of  total  resources  and  thus  shows  the  potential  to  be 
increased. Stakeholders pointed out that diversification of funding has been a priority 
of Finance Watch. From 2017 to 2018, Finance Watch managed to increase its funding 
from third parties by 19%, while the overall budget only increased by 13% – thus the 
share  of  third-party  funding  increased.  Nevertheless,  stakeholders  interviewed  also 
mentioned  that  efforts  to  diversify  funding  takes  resources  from  research  and  other 
activities. 

3.2.3  Relevance 

This subsection  evaluates the  relevance of Finance Watch. It covers the following 
key  topics:  whether  Finance  Watch’s  objectives  still  meet  the  current  needs  of 
stakeholders; the extent to which Finance Watch’s work still meets the objectives of the 
Union Programme; whether the topics covered by Finance Watch are relevant; and the 
relevance  of  Finance  Watch’s  membership  (see  Annex  5.1  for  further  detail  on  the 
evaluation questions). 

3.2.3.1 

The objectives of Finance Watch in the evaluation period 

addressed the needs of the financial services sector 

Stakeholders  overwhelmingly  perceived  that  the  objectives  of  Finance  Watch 
corresponded to the needs of  consumers and end-users of  financial services, although 
some respondents identified topics of relevance that were not addressed or could have 
been addressed to a greater extent. 

The current objectives of Finance Watch were drawn from the multiannual plan covering 
the years 2017-2019129. This plan rested on four pillars:  

•  Maintaining credibility and excellence; 
•  Becoming popular, an agenda setter and an opinion leader; 
•  Membership quantity and quality; 
•  Sustainable funding. 

In terms of its vision, Finance Watch wishes to ensure that regulation is introduced to 
ensure that society benefits from a responsible financial sector that does not privatise 

128  Fondation  pour  le  progrès  de  l'Homme,  MAVA  NatCap,  MAVA  Index,  European  Climate  Foundation,  OSIFE  Capacity-
building project. 
129 Finance Watch, Finance Watch’s Strategic Plan 2017- 2019, 2017.  

73 

 
 
gains  and  engage  in  harmful  rent-seeking  activities.  Finance  Watch  also  hopes  to 
address issues around inequality stemming from the current financial system, as well 
as  raising  awareness  of  the  link  between  climate  change  and  finance.  To  do  this,  it 
proposes  reforms  around  four  pillars,  ‘stabilise’,  ‘democratise’,  ‘redirect’  and  prepare’ 
130. 

The survey results indicated that the overwhelming majority of the respondents 
(90% of 69 total responses) considered that the objectives of Finance Watch 
were  still  aligned  with  the  current  issues  and  needs  of  consumers  and  end-
users  of  financial  services.  More  specifically,  58%  of  the  survey  respondents 
considered the objectives of Finance Watch highly relevant to the needs of consumers 
and  end-users,  and  another  32%  considered  them  relevant.  Similarly,  89%  of  the 
respondents to the survey stated that Finance Watch adapted its activities to the 
current  issues  and  needs  of  consumers  and  financial  end-users,  62%  to  a  high 
degree, 27% to a certain degree at least.  

About  half  of  the  survey  respondents  (52%)  however  considered  that  there  are  still 
needs and issues relevant to consumers and end-users of financial services that 
should  be  addressed  by  Finance  Watch,  or  addressed  to  a  larger  extent.  Such 
issues include: 

•  New  technologies  and  their  impact  on  financial  services,  e.g.  artificial 

intelligence, use of Big Data in Finance, FinTech, cybersecurity; 

•  Credit assessment; 
•  Banking regulation; 
•  Promoting the development of employee share ownership across Europe;  
•  Directive (EU) 2015/2366 on payment services (PSD2);  
•  Conflict of interest in financial services intermediation (commissions);  
•  SMEs’ finance; 
•  Corporate culture in financial institutions; 
•  Money-laundering;  
•  Long-term investments; 
•  Encashment. 

Findings from the interviews were in line with the survey results and confirmed that the 
work of Finance Watch remains relevant to a high extent for industry, as there are very 
few organisations that represent consumers’ voices within financial services. Finance 
Watch  covers  technical  topics  from  the  perspective  of  consumers  in  a 
transparent and comprehensive manner and therefore it is crucial to continue and 
expand its level of expertise. It has been developing its expertise for a while now and 
it takes time for any other organisation to reach that level. The topics it covered were 
related  to  FinTech,  insurance  issues  and  financial  inclusion  and  it  started  focusing 
strongly  on  sustainable  finance.  There  is  no  other  organisation,  according  to  various 
stakeholders, that covers such a wide range of topics as Finance Watch.  

Finance  Watch  members  who  were  interviewed  perceived  that  the  beneficiary  is 
performing well in terms of keeping up with the trends and focusing on technical 
and regulatory issues that are very complex for citizens to follow. The members 
interviewed  also  felt  that  the  variety  of  civil  society  organisations  that  the 
beneficiary brings together demonstrates its high relevance.  

One  stakeholder  from  a  consumer  organisation  commented  that  in  order  to  remain 
relevant in the market, Finance Watch should focus on topics and areas where 
its main expertise lies, as oppose to expanding into other areas where it might still 
lack  some  experience.  Similarly,  a  representative  from  the  European  Commission 
mentioned that given the broad focus of the financial topics covered by Finance Watch, 
it  was  sometimes  more  challenging  for  it  to  remain  entirely  focused  on  the  topics 

130 Finance Watch, How to make Finance Serve Society, 2019. Available at: https://www.finance-watch.org/our-vision/ 

74 

 
 
specifically relevant for consumers during the evaluated period. It was mentioned that, 
on  some  occasions,  Finance  Watch  followed  topics  that  were  high  on  the  policy  and 
public  agenda  at  the  time,  e.g.  Brexit  or  the  Transatlantic  Trade  and  Investment 
Partnership (TTIP) (which might not have been of very high relevance for consumers) 
by creating working groups that eventually discontinued their work.  

3.2.3.2 

The activities of Finance Watch in the evaluation period were 

relevant for the Union Programme 

Stakeholders  perceived  the  activities  of  Finance  Watch  as  relevant  to  achieve  the 
objectives of the Union Programme 2017-2020. 

The survey results indicated that the respondents consider the activities carried out by 
Finance Watch as relevant for informing and enhancing the involvement of consumers 
and end-users of financial services, as well as stakeholders representing their interests, 
in EU policy-making in the area of financial services (Figure 29, Figure 30). There was 
a high level of agreement (around 90%) among stakeholders about the relevance of all 
of the main type of activities carried out by Finance Watch, namely research work and 
position papers, advocacy work and communication and education activities. It is worth 
noting  though  that  for  each  of  these  categories  there  was  a  certain  percentage  of 
responses  indicating  that  the  work  of  Finance  Watch  was  either  neutral  or  not  very 
relevant  (between  7%-16%).  This  was  noticeable  in  reference  advocacy  and  to 
communication and education activities. 

Figure 29: Relevance of Finance Watch activities for enhancing the involvement of 
consumers and financial end-users (N=71) 

Irrelevant  Not very 
relevant 

Neutral  

Relevant   Highly 

relevant 

Provide  expertise 
through 
research 
work  and  position 
papers  

Carry out advocacy 
work  at  EU  and 
national level  

out 

Carry 
communication 
and 
activities  

education 

0%  

5.6%  

1.4%  

33.8%  

59.2%  

0%  

4.2%  

4.2%  

29.6%  

62.0%  

0%  

4.3%  

11.4%  

31.4%  

52.9%  

Figure 30: Relevance of Finance Watch activities for informing consumers and 
financial end-users (N=71) 

Irrelevant   Not very 
relevant  

Neutral  

Relevant   Highly 

relevant  

Provide  expertise 
research 
through 
work  and  position 
papers  

Carry out advocacy 
work  at  EU  and 
national level  

1.4%  

5.6%  

5.6%  

38.0%  

49.3%  

1.4%  

1.4%  

12.9%  

41.4%  

42.9%  

75 

 
 
 
Irrelevant   Not very 
relevant  

Neutral  

Relevant   Highly 

relevant  

out 

0%  

1.4%  

4.3%  

35.7%  

58.6%  

Carry 
communication 
and 
activities  

education 

Based  on  the  feedback  from  Finance  Watch,  resources  are  allocated  within  the 
organisation  in  line  with  the  approved  strategic  plan,  which  is  discussed  with 
member  organisations  and  approved  by  the  Board  of  Directors.  The  working  agenda 
and  resource  allocation  are  flexible  and  can  be  adjusted  on  an  ad  hoc  basis,  e.g. 
following  requests often received by MEPs. According to one representative  from the 
European Commission, Finance Watch is fully aligned with the objectives of the 
Union  Programme  and  is  closely  monitored  by  the  Commission  through  KPIs  and 
regular reporting. 

3.2.3.3 

Financial topics covered by Finance Watch are highly relevant 

The majority of stakeholders agreed that the financial topics covered by Finance Watch 
are highly relevant for consumer and financial end-users, yet there are suggestions for 
topics to be considered further in the future. It was suggested that Finance Watch could 
focus on fewer issues more in-depth, by developing more concrete priorities. 

Finance  Watch  indicated  that  topic  selection  is  closely  aligned  with  the  EU  financial 
political  agenda,  as  well  as  the  ad  hoc  needs  that  are  raised  by  the  member 
organisations  and  representatives  from  the  EU  (e.g.  MEPs)  throughout  the  year.  The 
desk research revealed that a large number of topics were examined across the 
two evaluation years. In 2017 and 2018, broad topics were:  financial supervision, 
banking,  FinTech,  retail  and  financial  inclusion,  sustainable  finance,  non-performing 
loans, Brexit, law-making, financial markets, trade, consumer financial services action 
plan, CMU, pensions and insurance131.  

Specific  examples  of  files  that  Finance  Watch  studied  in  2017  were:  asking  the 
Commission to close loopholes in the rules for dealing with failing banks, continuing to 
warn of the dangers with certain kinds of CMU securitisation, urging caution to boosting 
liquidity in the corporate bond market, calling for non-performing loans to be dealt with 
by banks without simply passing the risks on to consumers, communicating the need 
for diversity of bank business models, calling on the Commission to resist deregulatory 
pressures132. For 2018, the reviewed  sources were less clear  on specific  examples of 
topics,  however  it  did  reveal  more  emphasis  on  new  communications  tools  –  for 
example, over 20 blogs were written in 2018 alone133. 

The  consultation  topics  that  Finance  Watch  looked  at  in  2017  were:  the  ESA  review, 
ESMA  consultation  on  MiFID  suitability  requirements,  HLEG  on  sustainable  finance, 
multilateral  reform  of  the  investment  dispute  resolution,  consumer  financial  services 
action  plan,  REFIT  review  on  motor  insurance,  and  transparency  and  fees  in  cross-
border transactions in the EU. 

In 2018, Finance Watch  responded to  consultations on the following topics: proposal 
for the establishment of a framework to facilitate sustainable investment, proposal for 
low  carbon  benchmarks  and  positive  carbon  impact  benchmarks,  public  reporting  by 

131 Finance Watch, Final Report, 2017, p. 7. 
132 Finance Watch, Annual Report, 2017, p. 8. Available at: https://www.finance-watch.org/publications/ 
133 Finance Watch, Final Report, pp. 60-64. 

76 

 
 
 
companies, regulation on crowdfunding, insurance recovery and resolution, investment 
advice regarding Environmental, Social and Governance (ESG ) preferences. 

Looking  at  the  survey  results,  the  overwhelming  majority  of  the  respondents 
agreed that the financial topics covered by Finance Watch  were relevant for 
consumers and financial end-users – 60% found them ‘highly relevant’ and  35% 
‘relevant’.  

The respondents to the survey highlighted some of the topics covered by Finance Watch 
in the time period covered by this evaluation (2017-2018) as particularly relevant to 
them. These included:  

•  Stability  of  the  financial  system,  including  the  possibility  to  make  the  financial 
system  sustainable  and  useful  for  the  real  economy  (impact  on  jobs,  housing, 
social  services,  etc.),  governance  of  financial  institutions  (banks,  pensions, 
funds, etc.); 

•  Employee aspects of financial regulation;  
•  High-frequency trading;  
•  Credit assessment, advocacy for consumer protection;  
•  Sustainable finance,  banking regulation,  cryptocurrencies (Libra, in particular), 
topics  were  mentioned  by  several 

inclusion,  FinTech  (these 

financial 
respondents);  

•  EU Action Plan on Sustainable Finance;  
•  Consumer credit;  
•  Banking sector stability, retail and financial inclusion;  
•  Financial stability of the banking sector.  

The survey respondents also mentioned some of the topics treated by Finance Watch 
that were not very relevant to them. These included:  

•  Natural capital research/financial value of nature;  
•  Brexit, international trade agreements; 
• 

Insurance-related issues.  

Similarly, several stakeholders mentioned during the interviews that some topics were 
not  fully  covered  during  the  evaluated  period.  One  of  the  areas  was  banking 
legislation and employees and workers in the financial services industry. It was 
also mentioned that there might be some bias towards the topic of sustainable finance 
in the activity of Finance Watch. Another topic that did not receive complete coverage 
was the ESA review. 

However, the general feedback from the interviewees was positive and indicated that 
Finance Watch meets the needs of the stakeholders and their work was highly 
valued. It was mentioned that Finance Watch provides a valuable input for its members 
and  consumer  organisations.  One  of  the  members  reported  that  as  they  work  on 
sustainable  finance,  the  work  delivered  by  Finance  Watch  is  an  important  source  of 
information. Stakeholders pointed out how important it would be for Finance Watch 
to be present in those international forums where international standards are 
discussed and defined. 

77 

 
3.2.3.4 

The membership of Finance Watch is appropriate for its 

objectives 

Most stakeholders perceived that the members of Finance Watch are highly relevant for 
its objectives. 

During the evaluation period, Finance Watch was composed of 50 organisations and 35 
expert individuals, of which 69 were full members and 16 were associate members134. 
The  types  of  sectors  represented  by  the  membership  were  academia,  labour  unions, 
networks,  NGOs  and  charities  either  focused  on,  or  with  an  interest  in,  consumer 
empowerment135.  

The  survey  results  showed  a  common  agreement  among  respondents  (both 
members  of  Finance  Watch  and  non-members)  about  the  relevance  of  the 
membership  of  Finance  Watch.  Members  were  deemed  relevant  by  12  out  of  29 
respondents  and  very  relevant  also  by  12  respondents,  taking  into  account  the 
objectives of Finance Watch to inform financial consumers on issues at stake in financial 
regulation and enhance their involvement in EU policy-making in the financial services 
area. The interview results were in line with the survey outcome. The overall impression 
from the stakeholders interviewed was that the members of Finance Watch are relevant 
to a high extent. However, given the broad scope of the membership, it was mentioned 
that  some  individual  members  are  not  particularly  focused  on  financial 
services. 

It was mentioned that the level of involvement and allocation of tasks between Finance 
Watch  and  its  members  depends  on  the  topic  and  case-by-case  situation.  One 
stakeholder  mentioned  that  for  financial  inclusion,  Finance  Watch  reached  out  to  all 
members for their input. On the other hand, for very technical topics, Finance Watch 
tended to ask internal  experts to conduct more  research and then the final  research 
paper was circulated to members. In this regard, the breadth of the membership can 
be seen as a strength. Finance Watch communicates well with its members about work 
planned, by sending reminders and follow-up systems to receive members contribution. 

The  beneficiary  highlighted  that,  as  an  organisation,  it  is  an  extensive  network  of 
various  stakeholder  types  that  support  its  objectives.  It  brings  together 
organisations  and  individuals  that  have  expertise  in  respect  of  specific  topics  within 
financial services with the European institutions. It co-signs positions and attends high-
level meetings together with its members, such as BEUC or COFACE. 

3.2.3.5 

Key findings 

The results confirm that the objectives of Finance Watch as an organisation are 
in line with the objectives of the Union Programme 2017-2020 and the thematic 
coverage of the beneficiary, as well as its membership, are highly relevant for 
policy discussions on financial services. The activities carried out by Finance Watch in 
2017  and  2018  were  seen  as  highly  relevant  for  enhancing  the  involvement  of 
consumers  and  financial  services  end-users  as  well  as  other  stakeholders.  It  was 
indicated that the work of Finance Watch remains crucial as few organisations represent 
the consumers’ perspective within the area of financial services. 

Stakeholders recognised the relevance of Finance Watch’s work within the evaluation 
period as it provides information on technical topics to non-expert citizens in a 
transparent and understandable manner. This is seen in its research work, position 
papers, communication and education activities, and advocacy work. Among the topics 
mentioned as particularly relevant among stakeholders were the following: stability of 

134 Finance Watch, Annual Report, 2017, p. 24; Finance Watch, Annual report, 2018, p. 5. Available at: https://www.finance-
watch.org/publications/ 
135 Finance Watch, Annual report, 2018, p. 5. Available at: https://www.finance-watch.org/publications/. 

78 

 
 
the  financial  system,  employee  aspect  of  financial  regulation,  high-frequency  trading 
and sustainable finance. 

While  the  contribution  of  Finance  Watch  is  highly  appreciated  and  relevant  for  the 
sector, the respondents expressed the view that there remain some areas of interest 
to consumers and financial end-users that should be addressed more in-depth 
in the future, such as new technologies and their impact on financial services, 
credit assessment and the development of employee share ownership. Other 
topics  mentioned  as  needing  greater  attention  are:  corporate  culture  in  financial 
institutions,  money-laundering  and  long-term  investments,  encashment  and 
employee share ownership.  

The  high  relevance  of  Finance  Watch  was  reflected  by  the  variety  of  civil  society 
organisations that the beneficiary brings together. However, a view was expressed that 
some  individual  members  are  not  focused  on  financial  services,  with  several 
trade  unions  as  well  as  international  NGOs  such  as  Oxfam  among  the  members. 
Similarly,  there  was  a  shared  opinion  among  stakeholders  that  in  order  to  remain 
relevant in the future and maintain its unique role, Finance Watch should prioritise 
its activities more in the coming years, narrowing the focus to those areas where 
it has the strongest expertise.  

79 

 
3.3  Evaluation of the coherence of the two beneficiaries 

This subsection evaluates the coherence of Better Finance and Finance Watch, given 
the similarity of the input collected for the two organisations. It covers the following key 
topics:  overlaps  or  complementarities  between  the  Union  Programme  and  other  Union 
measures; between the activities of Better Finance and Finance Watch; with measures or 
activities at national or international level; and whether the activities of Better Finance and 
Finance Watch are in line with financial services policy objectives (see Annex 5.1 for further 
detail on the evaluation questions). 

3.3.1  The Union Programme does not overlap with other Union 

measures  

The  results  of  the  literature  review  and  stakeholder  consultations  revealed  that  the 
mandates of Better Finance and Finance Watch are unique and do not present an overlap in 
relation to other Union Programmes or organisations. Other entities act within similar policy 
areas  but  carry  out  different  activities,  and  thus  the  work  of  Better  Finance  and  Finance 
Watch is largely complementary rather than overlapping. 

The Union Programme was created by Regulation 2017/826. The Regulation states that the 
main  objective  of  the  measure  is  to  enhance  the  involvement  of  consumers  and  other 
financial services end-users in policy-making in the area of financial services. The preamble 
to  the  Regulation  does  not  mention  any  other  EU  measure  that  might  overlap  or 
complement the objectives of the Programme. 

The survey results show that the respondents found both Better Finance and Finance 
Watch coherent with and complementary to other EU measures (48% and 46% of 
the  respondents,  respectively,  for  Better  Finance;  47%  and  56%  of  the  respondents, 
respectively,  for  Finance  Watch),  and  do  not  identify  major  overlaps  with  other  EU 
measures (43% of the respondents for Better Finance; 49% for Finance Watch) (Figure 31 
and Figure 32).  Nonetheless, a higher share of respondents  indicated  ‘Don’t know’.  This 
may reflect a lack of knowledge of EU measures, as many of these respondents were based 
outside Brussels.  

Figure 31: Coherence of Better Finance with other EU measures (N=24) 

80 

 
 
Figure 32: Coherence of Finance Watch with other EU measures (N=65) 

Many of the survey respondents highlighted the complementarity of the action of Finance 
Watch – as made possible by the Union Programme – with the actions of other consumer 
organisations  at  EU  level.  They  pointed  out  that  Finance  Watch  conveys  the  needs  and 
perspectives of citizens and end-users of financial services and enhances their involvement 
in EU policy-making, which is separate from the interests of large financial organisations, 
which  are  already  well  represented  at  EU  level.  Such  broadening  of  inputs  into  policy-
making to take into account the views of a diverse range of stakeholders is coherent with 
overall EU policy principles.  

Nevertheless,  desk  research  and  stakeholder  consultations 
that  other 
organisations  could  be  considered  to  develop  similar  work  to  that  of  Better 
Finance  and  Finance  Watch,  both  at  EU  and  national  level.  A  few  respondents 
stressed some overlaps of Finance Watch actions with the work of consumer organisations, 
and they considered that Finance Watch should focus more on macro-financial topics that 
have only an indirect effect on consumers.  

found 

Some  stakeholders  pointed  out  that  organisations  like  BEUC  (mentioned  by  consumer 
organisations,  members  of  Finance  Watch,  banking  associations,  EU  bodies  and  EU 
authorities), COFACE, AGE Platform Europe, or the European Federation of Older Persons 
(EURAG) (mentioned by members of Finance Watch and EU bodies) act within similar policy 
areas  but  carry  out  different  activities.  These  organisations  are  complementary  to  each 
other, and both members of Finance Watch and the EU authorities reported having good 
cooperation experiences with them. Two of these complementary organisations went so 
far as to express their satisfaction in working with the beneficiaries and how  – given the 
lack  of  financial  and  human  resources  experienced  by  all  these  organisations  –  the 
existence  of  Better  Finance  and  Finance  Watch  supports  and  improves  their  work  by 
researching topics that would otherwise be overlooked by other organisations that are not 
as specialised in financial issues. 

Members of the banking associations also mentioned that UniEuropa has covered financial 
issues  in  recent  years  but  recognised  that  its  research  presents  the  perspective  of  the 
workers within the financial sector rather than that of consumers. Reference was made to 
the  fact  that  all  of  the  mentioned  organisations  receive  diversified  funding,  limiting  the 
competition  between  them  and  encouraging  cooperation.  One  of  the  consumer 
organisations  mentioned  nevertheless  that  the  requirements  of  the  2017-2020  Union 
Programme (in terms of type of activities to be funded) led Finance Watch to start working 
in areas overlapping with the existing consumer organisations more than in the previous 
funding period. Finance Watch members, however, added that, if in some topics  it is not 
the  only  player  producing  consumer-oriented  content  (e.g.  green  finance),  in  what 
concerns their core mission – financial stability – its work is unique. They also mentioned 
that Finance Watch added sustainable finance to its topic coverage and even though this 

81 

5%48%49%20%16%19%31%2%3%45%34%29%0%10%20%30%40%50%60%70%80%90%100%OverlappingComplementaryCoherentYesPartiallyNoDon't know 
 
is  covered  by  other  organisations  as  well,  it  was  the  interviewees’  opinion  that  Finance 
Watch brings a different voice to the discussion. 

Many  of  the  organisations  mentioned  by  stakeholders  also  receive  European  funding 
through  other  measures  and  programmes.  However,  the  analysis  shows  that  in  spite  of 
some similarities, there are no overlaps with the beneficiaries. Table 9 presents an overview 
of  the  most  relevant  measures  or  programmes  and  their  areas  of  complementarity  and 
overlap with the Union Programme.  

Table 9: Other Union measures 

Measure  

Main content 

Areas of complementarity/overlap 

Consumer  Programme 
2014-2020 (DG JUST) 

One  of  the  objectives  of  the 
Consumer  Programme  is  to 
improve  consumer  education, 
information  and  awareness  of 
their  rights,  to  develop  the 
evidence  base  for  consumer 
policy and to provide support to 
organisations, 
consumer 
including  taking  into  account 
the specific needs of vulnerable 
consumers.  

BEUC  received  funding  from 
this programme.  

Programme 
for 
Employment  and  Social 
Innovation  (EaSI)  (DG 
EMPL) 

The EaSI Programme is divided 
into  three  axes:  PROGRESS; 
EURES; Microfinance and Social 
Entrepreneurship.  

increase 

It  is  a  goal  of  this  programme 
to 
to 
information and microfinance of 
to 
vulnerable  groups  and 
support social enterprises.  

the  access 

Rights,  Equality  and 
Citizenship 
(REC) 
Programme (DG JUST) 

COFACE  receives  funding  from 
EaSI. 

The  REC  Programme  aims  to 
protect 
rights, 
citizens’ 
including  rights  of  vulnerable 
groups,  and  the  fight  against 
discrimination.  

The  AGE  Platform  Europe  – 
voicing  people  aged  over  50  – 
receives  funding  from  the  REC 
Programme. 

82 

Areas of complementarity: 
Consumer 
2014-2020 
Programme 
promotes  initiatives  that  aim  to  protect 
consumers’ rights. However, the Consumer 
Programme  targets  consumers’  rights  at 
large  and  is  not  directed  at  consumer 
rights’  in  relation  to  financial  services  in 
particular.  The  Consumer  Programme 
provides 
an 
organisation (BEUC) focusing on consumer 
protection in general.  

financial 

support 

to 

it  supports  measures 

Areas of overlap: 
As 
to  protect 
consumers’ rights in general, the Consumer 
Programme  could  also 
fund  activities 
related  to  the  protection  of  consumers’ 
rights  in  relation  to  financial  services. 
However, to date, no overlapping activities 
have been identified.  

Areas of complementarity 
The  EaSI  Programme  promotes  initiatives 
that aim to increase the access to financial 
information for vulnerable groups (financial 
inclusion).  However,  the  EaSI  Programme 
is  not  directed  at  promoting  the  rights  of 
consumers  at  large  in  relation  to  financial 
services.  The  EaSI  Programme  provides 
to  an  organisation 
financial  support 
(COFACE)  that  represents  the  interests  of 
families in the EU sphere.  

Areas of overlap: 
This  measure  provides  funding  to  an 
organisation defending the rights of one of 
the main groups of financial services users 
(families).  However,  it  does  not  have  a 
specific  consumer  rights  angle.  Therefore, 
no specific overlaps were found.  

Areas of complementarity 
The  REC  Programme  –  among  other 
activities  –  promotes 
rights  of 
vulnerable  groups.  However,  it  is  not 
directed  at  the  protection  of  consumer 
rights  in  particular,  nor  the  protection  of 
consumers of financial services.  

the 

The  REC  Programme  provides  financial 
support  to  AGE  Platform  Europe,  an 

 
  
  
  
  
  
  
  
  
Measure  

Main content 

Areas of complementarity/overlap 

organisation promoting the rights of people 
aged over 50.  

Areas of overlap 
This  measure  provides  funding  to  an 
organisation defending the rights of one of 
the main users of financial services (people 
aged over 50). However, it does not have 
a specific consumers’ rights angle, nor does 
it  represent  all  financial  services’  users. 
Therefore, no specific overlaps were found.  

Areas of complementarity 
The  Action  Plan  does  not  provide  the 
financial services end-users’ perspective. 

approach 

This  Action  Plan  sets  out  the 
Union 
to 
strengthening  the  EU  single 
market 
financial 
services. There is a strong focus 
on  consumer  trust,  removing 
cross-border  obstacles  and 
harnessing digital technologies.  

retail 

for 

This  Action  Plan  focuses  on 
three  main  goals:  reorienting 
capital 
towards 
flows 
investments; 
sustainable 
managing the risks rising from 
climate  change;  and  fostering 
transparency.  

The  European  Commission 
aimed  to  provide  the  financial 
industry  with  a  clear  overview 
of how to make use of emerging 
technologies  such  as  block 
chain and other IT applications.  

Areas of complementarity 
The  Action  Plan  does  not  provide  the 
financial services end-users’ perspective.  

Areas of complementarity 
The  Action  Plan  does  not  provide  the 
financial services end-users’ perspective. 

As  it  is  targeted  at  the  financial  industry, 
there is room for the opinion of end-users 
on the Action Plan’s topics. 

Consumer 
Financial 
Services  Action  Plan 
(COM(2017)  139,  from 
March 2017) 

Action  Plan:  Financing 
Sustainable 
Growth 
(COM(2018)  97,  from 
March 2018) 

FinTech Action Plan 

3.3.2  Better Finance and Finance Watch complement one another  

The  two  organisations,  even  if  acting  within  the same  large  thematic  area,  have  different 
audiences (and members) and do not produce the same type of work. 

Regulation  2017/826,  that  created  the  Union  Programme,  awards  grants  to  both  Better 
Finance  and  Finance  Watch,  acknowledging  the  complementarities  between  the  two 
organisations, as well as their different audiences. 

Most of the stakeholders interviewed either said that there is no real overlap between 
the two organisations or that this is minimal. Indeed, it was often expressed that the 
two organisations are complementary. 

The  EU  authorities  and  some  of  the  EU  bodies  interviewed  confirmed  that,  even  if  both 
organisations  have  looked  at  the  same  topics  at  times  (like  sustainable  finance  or 
pensions), they usually act independently and there is no overlap between them. One EU 
body mentioned that – considering the strength of the finance industry and their lobbying 
capacity – even when the beneficiaries overlap, they still reinforce the consumer 
perspective in the financial policy-making process.  

It was added that the  beneficiaries offer different viewpoints (Better Finance being 
associated  with  small  finance  services’  end-users,  and  Finance  Watch  with  citizens). 
Members of Finance Watch pointed out the difference in topic  coverage between the two 
beneficiaries:  while  Better  Finance  has  unique  knowledge  on  pensions  and  investors, 
Finance Watch has technical knowledge of themes such as prudential regulation, reserve 

83 

 
  
  
ratios  and  Basel  III,  and  its  members  believe  that  no  other  organisation  has  conducted 
similar work. 

These findings were confirmed by the results of the surveys. Respondents deemed 
Better Finance internally consistent (i.e. absence of contradictions between the various 
components  of  the  measure):  33%  of  the  respondents  considered  it  ‘neutral’,  while  the 
remaining  66%  considered  it  internally  consistent  to  a  high  (33%)  or  very  high  degree 
(33%). Respondents to the survey for Finance Watch expressed similar considerations: 
50%  of  the  respondents  expressed  a  ‘neutral’  opinion,  while  25%  deemed  it  internally 
consistent to a very high degree, and only 8% did not consider it consistent.  

Similarly, the survey results show that respondents did not identify major overlaps between 
the  activities  of  the  two  beneficiaries  of  the  Union  Programme  (i.e.  Better  Finance  and 
Finance Watch). Although a higher share of respondents (38% for Better Finance and 50% 
for Finance Watch, respectively) did not express an opinion on this issue,  most of those 
who did saw little or no overlap (38% of all responses for Better Finance and 27% of those 
for  Finance  Watch,  respectively).  A  (limited)  overlap  between  the  work  of  the  two 
beneficiaries  was  highlighted  in  the  area  of  sustainable  finance,  an  area  where  several 
consumers’ organisations also provided inputs to policy-making.  

On the topic of gaps left by the beneficiaries, particularly regarding areas that have been 
less researched, EU authorities mentioned deposit insurance and ESA reform. Members of 
EU  bodies  mentioned  climate  change  and  its  impact  on  the  financial  sector,  the  pension 
gap,  and  the  impact  of  the  digital  transformation  in  the  financial  sector  as  topics  that 
deserve consideration from consumers (hence the attention of the beneficiaries). EU bodies 
also mentioned the need for a consumer opinion on the topics of financial market regulation 
and enforcement and monitoring of legislation.  The results of the desk research showed 
that  –  despite  the  limited  awareness  among  stakeholders  –  Finance  Watch  has  been 
progressively  working  on  topics  related  to  climate  change  (mainly  with  its  sustainable 
finance  work)  and  digital  transformation  (with  some  publications  on  FinTech).  Better 
Finance also chose Sustainable Finance as one of its priority topics.  

Overall, then, the two beneficiaries have worked to some extent on less researched and 
emerging  areas,  which  are  consistent  with  those  identified  by  the  EU  policy  agenda  for 
financial services and with other key EU policy issues, such as sustainability. The inclusion 
of additional areas in the work of the beneficiaries shows their attention to the evolution 
of the external policy context, and their ability to align their agendas without losing their 
main traditional focus. However, the limited awareness of  some of their work among the 
key  institutional  stakeholders  could  be  considered  a  warning  sign  of  their  ability  to 
communicate effectively in all circumstances. In addition, there is the risk that maintaining 
a  strong  focus  on  emerging  and  rapidly  changing  topics  could  strain  the  availability  of 
resources and allow the beneficiaries to produce only superficial analysis of some topics, 
reducing the perceived reliability of their work.  

3.3.3  No identical measures can be found at national or 

international level 

There were no identical measures found in the Member States. Similarly, the beneficiaries 
were  not  considered  to  overlap  with  any  international  measure  or  organisation  and  their 
involvement  in  international  discussions  was  deemed  necessary  and  to  be  further 
encouraged. 

None  of  the  sources  of  evidence  used  for  this  study  (desk  research,  surveys  and 
interviews) identified organisations at national level with the same goals as Better 
Finance and Finance Watch, i.e. informing the development of finance policies from the 
perspective of end-users and consumers of financial services.  

The  consulted  stakeholders  mentioned  a  few  examples  of  initiatives  and  national 
organisations  carrying  out  activities  that  are  similar  to  those  of  the  beneficiaries.  These 

84 

 
included national banks that provide periodic analyses of financial products, and national 
consumers’ organisations providing the consumers’ perspective to national policy-making 
process, as in the case of EEKE136 sitting as member of advisory group of Secretariat for 
Private Debt Management of the Ministry of Finance in Greece. Other examples referred to 
financial  education,  such  as  the  financial  curriculum  introduced  and  made  mandatory  in 
secondary  school  in  Flanders,  as  well  as  that  region’s  support  of  teachers’  professional 
education programmes on financial education137. However, the possible overlap is minimal, 
as financial education is not part of the core activities of the beneficiaries, which mostly 
provide support to their national members in that respect.  

Even in the presence of similar initiatives in Member States, respondents considered the 
beneficiaries’  initiatives  coherent  with  the  Union  Programme,  complementary  and  not 
overlapping  with  each  other  or  other  initiatives,  either  at  national  or  international  level. 
This assessment is, however, based on only two survey responses and therefore needs to 
be interpreted with care  

During the interviews, members of Finance Watch pointed out the work that some of the 
national  members  carry  out  (e.g.  Germany,  France,  Belgium,  the  Netherlands)  as  an 
example  of  similar  measures  at  Member  State  level.  However,  members  of  consumer 
organisations at EU level expressed the view that the national counterparts are not as 
impactful,  have  not  enough  visibility  and  are  not  as  closely  followed  as  the 
beneficiaries. The banking associations mentioned that although Better Finance is unique 
in  its  area  of  activity,  its  local  members  carry  out  similar  activities  (examples  being  the 
German VSB or the Dutch VB). However, the scope of the activities of those organisations 
is  limited  to  national  policies,  while  one  of  the  recognised  characteristics  of  the  work  of 
Better Finance is cross-country analysis, providing a genuine European perspective.  

A  few  respondents  pointed  to  the  work  of  international  organisations,  such  as  the 
International Monetary Fund (IMF) and the World Bank, and, to a greater extent, the OECD. 
In particular, the OECD ‘Pensions at a Glance’ study was mentioned, as it provides data on 
pension returns. In addition, respondents indicated that EIOPA analyses past performances 
of pensions. However, none of these works took into account all of the costs and charges 
related to pension instruments (including inflation effects) in the same way that the Better 
Finance  report  did.  The  other  reports  mentioned  had  more  limited  coverage  of  Member 
States (OECD report) and market products (EIPOA report) compared to the Better Finance 
report, and a different perspective, less focused on users of pension products and more on 
policy makers. Given the different objectives of those three organisations (Better Finance, 
OECD and EIOPA), it is unlikely that their respective work on pensions will overlap in the 
future.  In  the  international  sphere,  the  OECD  stands  out  for  its  research  on  financial 
education. In 2005, it published a recommendation on Principles and Good Practices for 
Financial Education and Awareness, and, in 2013, together with Russia’s G20 Presidency, 
the OECD published the report Advancing National Strategies for Financial Education. In 
2018, the OECD published a report on financial inclusion and consumer empowerment in 
Southeast Asia. The OECD also has an extensive list of publications on consumer protection 
that  try  to  gather  consumers’  concerns  on  an  array  of  current  issues.  Nevertheless,  the 
OECD’s work is not centred on financial services and it has an international public policy 
angle  rather  than  offering  the  consumer  perspective.  Other  international  organisations 
such as the IMF, the World Economic Forum (WEF) or the World Bank have only general 
principles to contribute, to which the EU is aligned. Only one EU body mentioned the active 
role  of European Investors138 (a stakeholder comparable to Better Finance, according to 
this  EU  body)  in  international  forums.  European  Investors  represents  the  points  of  view 
and interests of investors in regulatory discussions – and actively in court, initiating class 
actions  –  and  having  more  of  a  lobbying  function.  While  it  works  on  some  of  the  same 
policy areas as the beneficiaries (such as the MiFID II) and comments on some of the same 

136 Union of Working Consumers of Greece, see: https://eeke.gr/en/structure/representation/  
137 Bruegel, Financial literacy and inclusive growth in the European Union, 2018. Available at: https://bruegel.org/wp-
content/uploads/2018/05/PC-08_2018.pdf 
138 https://europeaninvestors.eu/  

85 

 
 
Commission  consultations,  European  Investors  seems  to  have  a  more  limited  reach. 
Indeed, only one of the stakeholders interviewed mentioned its activities.  

3.3.4  The beneficiaries’ publications and events are in line with 

the EU and international policy objectives for financial 
services 

The  beneficiaries  have  prepared  content  (publications  and  events)  that  supports  the  EU 
financial  services  policy  objectives  (and  is  up  to  date  with  the  EU  agenda)  as  well  as  the 
most recent policies of the relevant international organisations.  

Regarding the coherence of the beneficiaries with EU policy objectives, the research found 
the  importance  of  the  work  of  both  beneficiaries  in  improving  consumer  trust  and 
empowering  consumers  when  buying  financial  services  in  the  domestic  market  or  from 
other  Member States. This  was confirmed  for both their  events and publications, by the 
results  of  the  desk  research  and  by  the  opinions  of  the  stakeholders  interviewed  and 
surveyed.  

The EU authorities also mentioned the importance of the beneficiaries’ work in removing 
legal or regulatory obstacles affecting businesses and in supporting the development of an 
innovative  digital  world.  The  role  in  building  trust  was  mentioned  by  EU  body 
representatives.  

The results of the surveys confirmed that the work of the beneficiaries is perceived 
as coherent with the EU financial services policy objectives as expressed in the 
Commission’s Consumer Financial Services Action Plan139: 

• 

Increasing consumer trust and empower consumers when buying services at home 
or from other Member States;  

•  Reducing  legal  and  regulatory  obstacles  affecting  businesses  when  providing 

financial services abroad;  

•  Supporting  the  development  of  an  innovative  digital  world  which  can  overcome 

some of the existing barriers of the Digital Single Market.  

The results of the surveys show that respondents deemed the events organised by both 
beneficiaries consistent  overall  with the EU financial services objectives (Figure 
33 and Figure 34; low responses figures can be attributed to the fact that those questions 
were only addressed to EU institutions).  

139 European Commission, Consumer Financial Services Action Plan: Better Products, More Choice, COM(2017) 139 final. Available 
at:  

https://eur-lex.europa.eu/resource.html?uri=cellar:055353bd-0fba-11e7-8a35-01aa75ed71a1.0003.02/DOC_1&format=PDF 

86 

 
 
Figure 33: Coherence of Better Finance events with EU policy objectives for financial 
services (N=8)  

Figure 34: Coherence of Finance Watch events with EU policy objectives for financial 
services (N=24) 

There is a general consensus about the consistency of the beneficiaries’ events with 
the  objective  of  increasing  consumer  trust  and  empowering  consumers  when 
buying services at home or from other Member States (38% of the respondents for 
both  organisations  considered  it  consistent  ‘to  a  high  degree’,  25%  of  respondents  for 
Better Finance – 2 respondents – and 38% for Finance Watch ‘to a very high degree’).  

A  large  number  of  the  respondents  to  the  survey  considered  Better  Finance  events 
consistent with the objective of reducing legal and regulatory obstacles affecting 
businesses  when  providing  financial  services  abroad  (38%  of  the  respondents 
considered it consistent ‘to a very high degree’). However, a small share of the respondents 
(13% – 1 respondent) expressed a ‘neutral’ opinion about the consistency of Better Finance 
events with this objective and another limited share (25% – 2 respondents) expressed a 
slightly negative appraisal. About half of the respondents to the survey (42%) considered 
Finance Watch events consistent  with  the  objective  of  reducing  legal  and  regulatory 
obstacles  affecting  businesses  when  providing  financial  services  abroad  (25%  of  the 
respondents considered it consistent ‘to a high degree’, 17% ‘to a very high degree’).  

Finally, 75% of the respondents (6 respondents) to the survey considered Better Finance 
events  consistent  with  the  objective  of  supporting  the  development  of  an 
innovative digital world, which can overcome some of the existing barriers of the Digital 

87 

0%13%0%13%25%13%25%13%25%38%0%38%25%38%25%0%10%20%30%40%50%60%70%80%90%100%Support the development of an innovative digitalworld which can overcome some of the existingbarriers to the Single Market.Reduce legal and regulatory obstacles affectingbusinesses when providing financial services abroadIncrease consumer trust and empower consumerswhen buying services at home or from other MemberStatesTo a very low degreeTo some degreeNeutralTo a high degreeTo a very high degree17%8%8%8%4%0%25%46%17%29%25%38%21%17%38%0%10%20%30%40%50%60%70%80%90%100%Support the development of an innovative digitalworld which can overcome some of the existingbarriers to the Single Market.Reduce legal and regulatory obstacles affectingbusinesses when providing financial services abroadIncrease consumer trust and empower consumerswhen buying services at home or from other MemberStatesTo a very low degreeTo some degreeNeutralTo a high degreeTo a very high degree 
 
 
Single Market (50% – 4 respondents –considered it consistent ‘to a high degree’, 25% – 2 
respondents  –  ‘to  a  very  high  degree’),  while  another  13%  of  the  respondents 
(1 respondent) expressed a ‘neutral’ opinion. Half of the respondents to the survey (50%) 
considered  Finance  Watch  events  consistent  with  the  objective  of  supporting  the 
development  of  an  innovative  digital  world  which  can  overcome  some  of  the  existing 
barriers of the Digital Single Market (21% of the respondents considered it consistent ‘to 
a high degree’, 29% ‘to a very high degree’).  

The  results  of  the  surveys  also  show  that  the  respondents  deemed  publications  from 
both  beneficiaries  overall  consistent  with  the  EU  financial  services  objectives, 
even if opinions are less positive for Finance Watch (Figure 35 and Figure 36; low responses 
figures  can  be  attributed  to  the  fact  that  those  questions  were  only  addressed  to  EU 
institutions).  

Figure 35: Coherence of Better Finance publications with EU policy objectives for 
financial services (N=8) 

Figure 36: Coherence of Finance Watch publications with EU policy objectives for 
financial services (N=25)  

The  consensus  is  particularly  strong  about  the  coherence  of  the  beneficiaries’ 
publications  with  the  objective  of  increasing  consumer  trust  and  empowering 
consumers  when  buying  services  at  home  or  from  other  Member  States  (50%  of  the 
respondents for Better Finance – 4 respondents – and 32% of the respondents for Finance 
Watch  considered  it  consistent  ‘to  a  high  degree’,  13%  of  the  respondents  for  Better 

88 

12%8%8%12%4%4%28%40%12%28%36%44%20%12%32%0%10%20%30%40%50%60%70%80%90%100%Support the development of an innovative digitalworld which can overcome some of the existingbarriers to the Single Market.Reduce legal and regulatory obstacles affectingbusinesses when providing financial services abroadIncrease consumer trust and empower consumerswhen buying services at home or from other MemberStatesTo a very low degreeTo some degreeNeutralTo a high degreeTo a very high degree 
 
 
Finance – 1 respondent – and 44% of the respondents for Finance Watch ‘to a very high 
degree’).  

A good share of the respondents to the survey (38% – 3 respondents) considered Better 
Finance  publications  consistent  with  the  objective  of  reducing  legal  and 
regulatory  obstacles  affecting  businesses  when  providing  financial  services 
abroad  (25%  of  the  respondents  –  2  respondents  –  considered  it  consistent  ‘to  a  high 
degree’,  13%  –  1  respondent  –  ‘to  a  very  high  degree’).  However,  consensus  about 
Finance Watch publications is less decided. Similarly, a good share of the respondents 
to the survey considered Finance Watch events consistent with the objective of reducing 
legal  and  regulatory  obstacles  affecting  businesses  when  providing  financial  services 
abroad (36% of the respondents considered it consistent ‘to a high degree’, 12% ‘to a very 
high degree’). A non-negligible number of respondents (40%) expressed a ‘neutral’ opinion 
about the consistency of Finance Watch events with this objective. 

Finally,  the  vast  majority  of  the  respondents  to  the  survey  (75%  –  6  respondents) 
considered Better Finance publications consistent with the objective of supporting 
the development of an innovative digital world, which can overcome some of the 
existing  barriers  of  the  Digital  Single  Market  (50%  –  4  respondents  –  of  the 
respondents considered it consistent ‘to a high degree’, 25% – 2 respondents – ‘to a very 
high  degree’).  On  the  other  hand,  about  50%  of  the  respondents  to  the  survey 
considered  Finance  Watch  events  consistent  with  the  objective  of  supporting  the 
development  of  an  innovative  digital  world  which  can  overcome  some  of  the  existing 
barriers of the Digital Single Market (28% of the respondents considered it consistent ‘to 
a  high  degree’,  20%  ‘to  a  very  high  degree’),  while  another  28%  of  the  respondents 
expressed a ‘neutral’ opinion.  

Most of the concerns for both beneficiaries were expressed with respect to the objective of 
reducing  legal  and  regulatory  obstacles  affecting  businesses  when  providing  financial 
services abroad. This result reflects the limited activity of both organisations on the topic. 
During the period covered by the evaluation, Better Finance did not issue any publication 
related to this, while Finance Watch issued six (out of 21) publications related to EU policy 
objectives (Table 10).  

Representatives  of  the  European  institutions  pointed  out  the  high  quality  of  the 
publications prepared by the beneficiaries, both in the surveys and in the interviews. 
The work of both beneficiaries on FinTech and active involvement in the different discussion 
groups  debating  this  topic  was  particularly  praised.  Consumer  organisations  referred  to 
Finance  Watch’s  work  on  financial  inclusion,  in  particular  the  links  between  retail  and 
financial  inclusion,  and  pensions  and  insurance.  Both  were  considered  very  useful. 
However, members of the EU bodies pointed out that consumer organisations should be 
further involved in the FinTech discussion, as their opinion needs to be considered from the 
start  (when  developing  the  rules  and  standards)  and  not  only  when  a  problem  occurs, 
which could reflect possible late action of the beneficiaries on the topic.  

Overall,  the  quality  of  the  publications  of  both  beneficiaries  was  considered  very  good. 
However,  some  of  the  stakeholders  warned  that  the  beneficiaries  should  not  focus 
excessive attention on ‘sexy topics’ (such as Brexit or the TTIP) as these tend to fade away 
in  the  policy  discussion  after  a  comparatively  short  time.  They  advised  that  such  topics 
should be included in their other research subjects, as secondary elements, when relevant.  

Regarding  global  policy  objectives,  representatives  of  the  European  Commission 
mentioned  the  interest  of  Finance  Watch  in  the  G20  agenda,  and  its  general  interest  in 
global discussions, for example in the ‘too big to fail’ reforms. Its networking with the UN 
was also referenced, in particular in connection with the funding Finance Watch received 
for the organisation of its ‘Changed Finance’ campaign, where it developed a benchmark 
in relation to sustainable finance. 

Members of Better Finance mentioned its collaboration with the World Federation 
of  Investors  and  the  input  received  from  Asia  on  topics  relevant  to  Europe. 
Representatives of the European Commission made reference to the conference organised 

89 

 
by  Better  Finance  in  Beirut,  even  though  it  was  stressed  that  maybe  not  all  relevant 
stakeholders were involved (for example insurance networks).  

Members  of  Finance  Watch  mentioned  that  it  is  not  part  of  its  mandate  to  act  in  the 
international forum. Nevertheless, it cooperates with the UN. It believes that given Finance 
Watch’s  limited  resources,  the  best  value  for  money  is  to  focus  on  European  policy. 
Regardless, it pointed out that international forums are going in a similar direction 
as Finance Watch, with examples being the WEF, G20, and the Financial Stability Board 
(FSB). Members noted that the OECD acts more like a think-tank providing topical opinions 
and they reported that OECD representatives are present at Finance Watch events. One 
member, however, pointed out that compared to the G20 conclusions, Finance Watch work 
is a better representation of citizens’ perspectives.  

To offer a picture of the work of the beneficiaries during the evaluation period,  Table 10 
provides an overview of the number of publications of the beneficiaries that meet EU or 
international objectives (see Annex 5.5 for more detail).  

Table 10: Overview of publications which meet EU or international policy objectives 

EU financial services objectives  

Better Finance 

Finance Watch 

Number of publications 

Increase consumer trust and empower consumers when 
buying services at home or from other Member States 

Reduce legal and regulatory obstacles affecting business 
when providing financial services abroad 

Support the development of an innovative digital world 
which can overcome some of the existing barriers to the 
single market 

6 

0 

2 

11 

6 

4 

Global financial objectives and publications 

Better Finance 

Finance Watch 

IMF – Report on FinTech 

WEF – Report on AI 

World Bank – Financial inclusion and financial education 

OECD – Financial consumer protection in the digital age 

2 

2 

6 

2 

1 

2 

9 

2 

Source: reviewers’ assessment of beneficiaries’ publication 

In 2017, Better Finance published 29 press releases and four research reports. Its ‘Pension 
Savings – The real return’ report was probably one of the most relevant for EU financial 
services  policy,  according  to  the  stakeholders  consulted.  Finance  Watch  published  eight 
research  or  opinion  outputs,  including  ‘the  Capital  Markets  Union  and  sustainability: 
recommendations for the mid-term review’; the ‘Policy brief on the EU’s banking package 
“One step forward, two steps back"’, and a White paper ‘New pathways: Building blocks for 
a  sustainable  finance  future  for  Europe’.  In  2017,  Better  Finance  organised  or  attended 
seven events, and Finance Watch organised 10 events, including the first FinTech workshop 
(on block chain) and a conference on sustainable finance. 

In  2018,  Better  Finance  published  six  research  reports,  five  newsletters  on  EU  financial 
policy news and 24 press releases. Among its publications was the report, ‘The dispersion 
of risk mitigation techniques in lifecycle pensions’ and the 2018 edition of ‘Pension savings 
–  the  real  return’.  Finance  Watch  published  12  different  research  or  opinion  outputs 
(excluding consultation responses). Among the most relevant were the second edition of 
the global green finance index, Finance Watch’s recommendations for a PEPP proposal and 
a briefing note on the FinTech Action Plan (‘Dinosaurs in the sandbox’). 

In  2018,  Better  Finance  attended  or  organised  eight  events  and  conferences  across  the 
EU. Finance Watch organised 10 events, including the presentation of the first edition of 
the global green finance index, a webinar on the role of finance in saving the planet and 
the second edition of the Change Finance Forum.  

90 

 
 
3.3.5  Key findings 

The  desk  research  and  stakeholder  inputs  both  highlight  that  the  activities  of  Better 
Finance  and  Finance  Watch  are  coherent  with  and  complementary  to  other  EU 
measures:  major  overlaps  with  other  EU  initiatives  were  not  identified  or  cited.  Other 
organisations and EU measures support consumers’ rights and advocacy, such as BEUC, 
COFACE and AGE Platform Europe, and receive funding from the EU (such as the Consumer 
Programme  2014-2020,  managed  by  DG  JUST;  the  EaSI  Programme,  managed  by  DG 
EMPL; and the REC Programme, managed by  DG JUST). However, the sources  reviewed 
and  the  stakeholder  consultation  (both  via  survey  and  interviews)  all  suggest  that  the 
work of Better Finance and Finance Watch is unique, as these organisations convey 
the  needs  and  perspectives  of  citizens  and  end-users  of  financial  services  in  EU  policy 
discussions. This function balances the interests of large financial organisations, which are 
well  represented  at  EU  level,  and  it  is  coherent  with  overall  EU  policy  principles. 
Nonetheless, the two beneficiaries  could be  encouraged to continue to ensure that their 
activities are complementarity to those of other organisations and initiatives that receive 
EU funding, in particular those for consumers’ rights and advocacy.  

Similarly, results from the desk research and the stakeholder consultation found no major 
overlaps between the actions of the two beneficiaries of the Union Programme. In 
the  interviews  and  surveys,  there  was  a  general  consensus  among  stakeholders  on  the 
complementarity  of  the  beneficiaries,  which  specialise  in  different  topics,  with  Better 
Finance  focusing  on  issues  such  as  pensions  and  investors  and  Finance  Watch  paying 
greater attention to financial inclusion, sustainable finance and FinTech. Stakeholders also 
said that even in cases where both organisations at times looked at the same topics (e.g. 
sustainable finance or pensions), they usually acted independently and there was no major 
overlap  between  their  work.  Some  stakeholders  went  so  far  as  to  consider  such  cases 
beneficial as they amplify the opinions of consumers, which are less known than those of 
the financial industry. Although the overlaps are few, better coordination and differentiation 
in the work of the two beneficiaries could be valuable to ensure that the Union Programme 
overall is efficient.  

While some consumers’ organisations active at Member State level also work on financial 
matters,  no  examples  of  organisations  with  the  same  goals  as  Better  Finance  or 
Finance Watch – informing the development of EU finance policies from an end-users’ and 
consumers’ perspective – were identified in the information gathered. Stakeholders agreed 
that  no  similar  initiatives  were  carried  out  at  international  level,  for  example  by 
international organisations.  

The  analysis  of  the  information  collected  showed  that  both  the  publications  and  the 
events  produced  by  Better  Finance  and  Finance  Watch  over  the  evaluation  period  were 
consistent with the EU financial services objectives140. Publications and events were 
considered  particularly  relevant  to  the  objectives  of  increasing  consumer  trust  and 
empowering  consumers  when  buying  financial  services  at  home  or  from  other  Member 
States, and to the objective of supporting the development of an innovative digital world 
which can overcome some of the existing barriers of the Digital Single Market, while less 
relevant with regard to the objective of reducing legal and regulatory obstacles affecting 
businesses  when  providing  financial  services  abroad.  Representatives  of  the  European 
Commission  pointed  to  the  importance  of  the  work  of  both  beneficiaries  in  improving 
consumer trust and empowering consumers when buying services at home or from other 
Member States.  

The work of Better Finance on pensions was mentioned by stakeholders as an example of 
a unique initiative: this was the case in particular for its work on pension returns (which 
was noted as being of high quality and very relevant), as stakeholders were not aware of 

140 European Commission, Consumer Financial Services Action Plan: Better Products, More Choice, COM(2017) 139 final. Available 
at:  

https://eur-lex.europa.eu/resource.html?uri=cellar:055353bd-0fba-11e7-8a35-01aa75ed71a1.0003.02/DOC_1&format=PDF  

91 

 
 
other reports showing the calculation of real returns after taxes, inflation and other factors. 
Finance Watch’s work on sustainable finance was positively assessed by stakeholders.  

On the other hand, deposit insurance, ESA reform, climate change and its impact on the 
financial sector, and the pension gap were mentioned among the topics that deserve more 
attention from the beneficiaries. The impact of the digital transformation in the financial 
sector – to which both beneficiaries have been paying attention, in particular in the area 
of FinTech – should remain a priority topic in the coming years.  

In  the  period  covered  by  the  evaluation,  Better  Finance  and  Finance  Watch  carried  out 
some  work  beyond  the  EU  level,  such  as  Better  Finance’s  cooperation  with  the  World 
Federation  of  Investors  for  input  from  Asia  on  topics  relevant  to  Europe,  and  Finance 
Watch’s presentation of the first edition of the global green finance index, its webinar on 
the  role  of  finance  in  saving  the  planet  and  the  second  edition  of  the  Change  Finance 
Forum. This work is coherent with the organisations’ objectives and with EU policies. For 
instance, the issue of sustainable finance, which is an important element of the EU policy 
agenda, also has a relevant international dimension that both beneficiaries have supported 
to some extent.  

92 

 
 
 
3.4  Evaluation of EU added value of both beneficiaries 

This section evaluates the EU added value of Better Finance and Finance Watch: the 
two  organisations  are  addressed  together,  given  the  similarity  of  the  input  collected  for 
each.  The  section  covers  the  following  key  topics:  the  additional  value  of  the  two 
organisations compared to what could be achieved at national level; whether the need for 
activity at EU level continues to exist; and the potential consequences if the organisations 
ceased their activity (see Annex 5.1 for further detail on the evaluation questions). 

3.4.1  The added value resulting from the activities of Better 

Finance and Finance Watch is recognised 

Stakeholders confirmed the added value resulting from the activities of Better Finance and 
Finance Watch, compared to what could be achieved at national level. 

The  desk  research  revealed  that  the  European  Commission  operates  on  the  assumption 
that  there  are  no  equivalent  benchmarks  for  Better  Finance  and  Finance  Watch,  and  no 
competing  organisations.  Furthermore,  the  Commission  has  emphasised  that  national 
consumer  organisations  do  not  have  the  skills  and  expertise  required  to  operate  at 
European level in the same way that both beneficiaries do141. This view was supported by 
the previous evaluation142 conducted in 2015, and, as described in this section, the results 
of the current evaluation confirm this. 

In terms of the sources of financial regulation, the main relevant bodies are the G20 and 
international bodies,  the FSB, the Basel Committee  on Banking Supervision (for banks), 
International Organization of Securities Commissions (IOSCO) (for financial markets) and 
the International Association of Insurance Supervisors (IAIS) (for insurance). The work of 
these bodies in turn influences actions at EU level and then at national level143.  

The  majority  of  survey  respondents  recognised  the  medium  or  high  level  of  added 
value to EU consumer policy in financial services by work carried out by Better 
Finance since 2017 (Figure 37). Similarly, 82% of stakeholders perceived to a very high 
or high degree the work of the beneficiary as an EU umbrella organisation strengthening 
the  voice  of  consumers  in  Europe,  compared  to  a  situation  in  which  only  national 
organisations would be active. 

141 European Commission, Commission Staff Working Document: Evaluation of a pilot project and preparatory action on enhancing 
the involvement of end-users and non-industry stakeholders in EU policy making in the financial services, 2015. Available at: 
https://ec.europa.eu/info/sites/info/files/staff-working-document-22122015_en.pdf 
142 PricewaterhouseCoopers, Evaluation of grants awarded to Finance Watch and Better Finance, 2015, p. 21. 
143 Finance Watch, Work Programmes 2017-2020, 2016, p. 7. 

93 

 
 
Figure 37: Added value brought by Better Finance to EU consumer policy in financial 
services since 2017 (N=26) 

4%

4%

8%

23%

62%

High 

Medium 

Little 

Not 

I do not know 

The  survey  results  also  show  that  the  vast  majority  of  the  respondents  considered  the 
work carried out by Finance Watch in the time period covered by this evaluation 
to have brought added value to consumers and end-users of financial services at 
EU level (Figure 38). The survey results showed similar agreement about the added value 
brought by Finance Watch in strengthening the voice of consumers in Europe, compared 
to a situation in which only national organisations would be active. In particular,  51% of 
the respondents deemed that the work of Finance Watch brought added value ‘to a very 
high degree’, while 30% agreed ‘to a high degree’. Nearly 12% described the added value 
of Finance Watch in this area as neutral.  

Figure 38: Added value brought by Finance Watch to EU consumer policy in financial 
services since 2017 (N=69) 

6%

3%

4%

32%

55%

High 

Medium 

Little 

Not 

I do not know 

In line with the survey results, interviews conducted with various stakeholders confirmed 
that there is very little coverage of consumer interests within financial services at 
the  national  level,  and  they  fully  recognised  the  additional  value  resulting  from  the 
activity of Better Finance and Finance Watch. It was mentioned that financial education is 
–  to  some  extent  –  delivered  at  national  level;  however,  consumer  protection  certainly 
requires action at EU level, given that European financial regulations are often initiated in 
Brussels. Additionally, one consumer organisation mentioned that an EU-level network is 
needed  to  coordinate  national  level  activities,  therefore  the  role  of  the  beneficiaries  is 

94 

 
 
 
crucial. Actions at national level were generally considered too isolated to provide the work 
and results that Better Finance and Finance Watch deliver. 

One stakeholder representing a consumer organisation mentioned that the added value 
is  strongest  for  the  newer  EU  Member  States  (e.g.  Poland,  Romania)  where 
consumer protection might not yet be as well developed as in other Member States. 
Being part of the European network gives national organisations in newer Member States 
much more visibility, e.g. a small organisation from Romania  that is a member of Better 
Finance’s network with  FSUG, BEUC and COFACE can put more political pressure on the 
national government to solve national-level problems (e.g. Swiss franc loan affair, reform 
of the insolvency regime in Romania). For other countries, where national legislation is well 
established and consumers are better represented, the need for European representation 
might be less pressing. Having said that, European level comparisons between countries 
are also very useful for every Member State. They allow the transfer of good practices and 
tools  from  one  country  to  another:  in  this  way,  the  two  beneficiaries  foster  a  ‘cross-
fertilisation of good practices’ in Europe.  

3.4.2  Issues addressed by Better Finance and Finance Watch 

continue to require action at EU level 

There  was  a  strongly  united  view  from  stakeholders  that  the  issues  addressed  by  the 
activities of Better Finance and Finance Watch continue to require action at EU level. 

The  existence  of  EU-level  financial  policy  issues  demonstrates  the  need  to  have  the 
beneficiaries working at EU level. Financial stability is a cross-border matter and relies on 
a multitude of interrelated factors occurring in symbiosis within all countries. The measure 
therefore  could  only  be  useful  at  EU  level,  not  least  because  individual  national 
organisations  that  are  part  of  the  beneficiaries’  memberships  lack  a  sufficient  birds-eye 
view of the issues at EU level. 

The  stakeholders  interviewed  all  agreed  that  the  issues  addressed  by  the  measure 
continue to require action at EU level. Given that there are many issues that cannot 
be  solved  at  national  level,  the  EU’s  role  in  legislation  and  policy  on  financial 
services is likely to continue to grow in the coming years. The interviews referred to 
the need for more action at supra-national level in the legislative area, such as within the 
CMU  action  plan144,  as  well  as  within  the  technological  area,  such  as  crypto-assets145  – 
particularly in light of the new financial topics developing within the sphere of consumer 
finance,  such  as  the  emergence  of  FinTech,  progressing  role  of  digitalisation  in  retail 
financial  services  and  sustainable  finance146.  There  is  a  further  drive  needed  to  involve 
consumers  more  in  policy-making  for  financial  services.  Looking  at  the  retail  financial 
services, a growing proportion of legislation is adopted at EU level (e.g. mortgage credit – 
Mortgage Credit Directive, payment accounts – PSD2, investment products – MiFID II and 
PRIIPs, insurance products – IDD).147 Consequently, national advocacy remains important 
and cannot be replaced with the EU. 

One of the barriers mentioned is users’ understanding of how finance works: consequently, 
financial  education  is  important.  It  was  also  mentioned  that  there  is  a  need  for  better 
defined standards at the level of EU policy and more analysis of the demand side of the 
market (the supply side is already well covered and represented). 

144  European  Commission,  Capital  markets  union  action  plan.  Available  at:  https://ec.europa.eu/info/business-economy-
euro/growth-and-investment/capital-markets-union/capital-markets-union-action-plan_en 
145 European Commission, Financial services – EU regulatory framework for crypto-assets. Available at: 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12089-Directive-regulation-establishing-a-European-
framework-for-markets-in-crypto-assets/public-consultation 
146  European  Commission,  Consumer  financial  services  policy.  Available  at:  https://ec.europa.eu/info/business-economy-
euro/banking-and-finance/consumer-finance-and-payments/retail-financial-services/consumer-financial-services-policy_en 
147 European Commission, Retail Finance: Green Paper – Q&A, 2015. Available at: 
https://ec.europa.eu/commission/presscorner/detail/fr/MEMO_15_6287 

95 

 
 
Additionally, given that the financial services industry is trans-national it is important for 
EU-level  action  to  complement  national  initiatives,  especially  in  areas  such  as  employee 
protection and money laundering. One of the member organisations highlighted the need 
for  both  financial  education  (targeted  to  help  people  make  more  informed  personal 
decisions)  and  education  about  finance  (explaining  how  the  financial  system  works  and 
current policy issues). 

3.4.3  Potential gaps within policy discussion are expected if the 

measure were withdrawn 

Stakeholders  stated  that  they  expect  negative  consequences  should  the  measure  be 
withdrawn  or  stopped  and  highlighted  the  potential  gap  in  policy  discussions,  as  the 
consumer voice would become limited. 

If Better Finance and Finance Watch were stopped or support for them from the European 
Commission were withdrawn, there is a strong case to say that European consumers would 
be less empowered and have less information regarding financial regulation and markets. 
The  desk  research  revealed  that  significant  gaps  exist  in  data  and  analysis  at 
European and international levels, leaving consumers with insufficient information. For 
example, Eurostat data on rates of returns from pension plans was incomplete, although 
it was informing Commission reports148. At the international level, organisations such as 
the OECD also lack a comprehensive overview of retail financial products149. On the specific 
case of closet index funds, the ESA would not disclose significant information on the names 
of  these  funds.  This  was  directly  to  the  detriment  of  consumers150.  In  response  to  this, 
Better Finance released its closet funds reports, using the same methodology but disclosing 
the names of funds.  

Similar  findings  were  drawn  from  the  survey  and  interviews  responses.  In  the  survey, 
respondents  from  various  stakeholder  groups  expected  negative  consequences 
in  case  of  the  withdrawal  of  the measure.  Ten  out  of  13  respondents  to  the  Better 
Finance survey indicated that stopping the measure would negatively impact – to a very 
high degree or to a high degree – consumer and financial services end-users’ awareness 
and participation in policy-making (Figure 39). 

Figure 39: Potential negative impact of stopping the measure on consumer and financial 
services end-user awareness and participation in policy-making – Better Finance (N=13) 

46%

15%

8%

31%

To a very low degree 

To some degree 

To a high degree 

To a very high degree 

148 Better Finance, Final Report, 2018, p. 66. 
149 OECD, Financial Consumer Protection Approaches in the Digital Age, G20/OECD Policy Guidance, 2018. 
150 Better Finance, Final Report, 2017, p. 8. 

96 

 
 
 
For  Finance  Watch,  the  great  majority  of  survey  respondents  were  of  the  opinion  that 
stopping the Union Programme would negatively impact consumers and financial services 
end-users’  awareness  and  participation  in  policy-making:  15  out  of  29  respondents 
indicated that this would be the case  ‘to a high degree’ while 10 respondents believed it 
would be ‘to a very high degree’ (Figure 40). 

Figure 40: Potential negative impact of stopping the measure on consumer and financial 
services end-user awareness and participation in policy-making – Finance Watch (N=29) 

7% 3%

3%

35%

52%

To a very low degree 

To some degree 

Neutral 

To a high degree 

To a very high degree 

All stakeholders interviewed agreed that stopping the measure would most likely limit 
or end the activity of Better Finance and Finance Watch. It would disintegrate the 
valuable network between national members and the EU level that has been created with 
the Union Programme. The exchange of information flow would be restricted without the 
beneficiaries, and the two organisations provide central points of communication with EU 
policy  makers,  a  role  that  is  crucial  for  consumers,  end-users  and  industry.  The 
stakeholders  indicated  that  without  the  beneficiaries  there  would  be  a  gap  and  a  clear 
imbalance in terms of lobbying activity, as the need for a counter-voice to the banking 
industry’s  influence  on  policy-making  remains.  The  interviewees  called  for  the 
continuing development of support for end-users and consumers. 

3.4.4  Key findings 

The  findings  from  the  literature  review,  survey  and  interviews  confirmed  that  there  is 
additional  value  resulting  from  the  activities  of  Better  Finance  and  Finance 
Watch. No alternative organisations at European or national level cover such a wide range 
of  activities,  and  the  EU-level  networks  of  the  two  beneficiaries  are  needed  to 
coordinate national level activities. Consequently, Better Finance and Finance Watch 
continue to have crucial roles. 

The EU added value of the activities of the beneficiaries is important in particular for EU 
Member  States  where  consumer  financial  protection  is  still  developing.  In  addition,  the 
existence of the two EU-level organisations fosters knowledge transfer and sharing of good 
practices in financial services among Member States. 

There  was  a  consensus  among  the  stakeholders  that  the  issues  addressed  by  Better 
Finance and Finance Watch continue to require action at EU level.  There are  still 
numerous topics and emerging issues important for consumers that require further action 
and  visibility  at  EU  level,  for  instance  related  to  the  development  of  FinTech  and 
technological innovation and sustainable finance. Given the growing number of EU 
legislative instruments within retail financial services that directly impact consumers 
and small investors, the role of the beneficiaries in the future will be even more necessary. 
There is a need for ongoing action at EU level in the legislative area (e.g. within the CMU 

97 

 
 
action  plan)  and  the  technological  area  (e.g.  crypto-assets).  The  stakeholder  interviews 
indicated that support for the beneficiaries should be enhanced at EU level.  

If EU financial support were withdrawn, the stakeholders stated that they expect 
negative consequences for the sector, in particular for consumers and financial end-
users. Given the high level of financial dependence of Better Finance and Finance Watch 
on the grants from the European Commission, their activities would be greatly restricted 
without this support. The stakeholders expected that the consumers’ voice would be less 
visible, leaving a gap in EU-level policy discussions within financial services. 

98 

 
 
4  Conclusions 

The evaluation of Better Finance and Finance Watch for the period 2017-2018 came to the 
following conclusions. 

4.1  Better Finance’s effectiveness, efficiency and 

relevance  

4.1.1  Effectiveness 

Overall, the work carried out by Better Finance during the evaluation period was 
effective in enhancing the involvement of stakeholders outside the banking and finance 
sector and raising issues that might otherwise have been missed in debates around future 
financial regulation. Better Finance’s campaigns and reports were timely and relevant, with 
many  national  member  organisations  recognising  a  higher  level  of  involvement  of  end-
users/consumers at national level as a direct result of the action.  

While it is difficult at any level of policy-making to pinpoint exactly where lobbying has had 
effect, there is clear evidence from the surveys and interviews that policy makers 
feel better informed as a direct result of the work of Better Finance. According to 
the results of the survey and interviews, Better Finance contributed considerable qualitative 
and  quantitative  expertise  in  relevant  areas  during  the  evaluation  period,  often  in 
overlooked areas, for example closet indexing of funds. Nevertheless, there does seem to 
be  a  lack  of  knowledge  among  national  authorities  with  regards  to  the  work  of  Better 
Finance,  although  considering  the  organisation’s  EU  focus  and  its  limited  resources, 
prioritising communications to EU level stakeholders is an understandable strategy.  

There  is  a  high  level  of  satisfaction  with  the  quality  of  outputs  among 
stakeholders. This result, together with the large increase in the number of speaking 
engagements and media citations during the  evaluation period, is  a strong indicator 
that Better Finance is performing well in its role and its inputs and interventions are valued 
by policy makers and stakeholders alike.  

One  area  of  concern  is  the  number  of  report  downloads,  which  showed  a 
significant decrease in 2018 compared to 2017. This suggests that better dissemination 
activities  would  be  valuable  to  secure  a  wider  readership  of  Better  Finance’s  research 
outputs  in  the  coming  years.  Moreover,  Better  Finance’s  online  and  social  media 
performance was poor compared to similar organisations and there is clearly room for 
improvement in this area.  

4.1.2  Efficiency 

Between  2017  and  2018,  Better  Finance’s  expenditure  and  outputs  did  not  change 
significantly.  Better  Finance  thus  maintained  a  rather  stable  cost-output  ratio 
during the two evaluation years. 

When compared to the expenditure and output of similar organisations at EU level, namely 
COFACE, AGE Platform Europe, BEUC and Finance Watch,  Better Finance works more 
efficiently,  producing  high-quality  outputs  with  comparably  fewer  resources.  These 
findings  were  corroborated  by 
found  a  consensus  among 
interviews,  which 
stakeholders that for the resources at its disposal,  Better Finance delivers very 
good value.  

In addition to the EU grant (which forms 59% of its income), Better Finance relies mainly 
on membership fees. The income from membership fees (25%) is about twice as high as 

99 

 
the  next  source  (partnerships  or  donations,  13%).  No  significant  diversification  of 
funding  occurred  during  the  evaluation  period  –  in  fact,  the  share  of  income  from 
sources other than membership fees slightly decreased. 

4.1.3  Relevance 

The initial objectives of Better Finance are in line with the Union Programme 2017-2020 
and the thematic coverage of Better Finance, as well as its membership, are highly 
relevant for the financial services sector. The activities carried out by Better Finance 
in 2017 and 2018 were seen as very relevant for enhancing the involvement of 
consumers  and  financial  services  end-users.  In  interviews  and  surveys,  member 
organisations indicated that the work of Better Finance complements their own 
work  at both national and international levels. Similarly, interviewees in EU bodies 
reported that Better Finance is needed to counterbalance the voice of the financial services 
industry.  

On  the  other  hand,  most  respondents  expressed  the  view  that  there  is  still  a  gap  in 
terms  of  the  needs  of  consumers  and  financial  end-users  to  be  addressed,  for 
instance regarding manipulation of the financial system, FinTech development or the need 
for actively managed funds. Therefore, according to the stakeholders consulted, it is crucial 
that  the  work  of  Better  Finance  continues.  Better  Finance’s  membership  does  not 
cover all EU Member States, and this should be an area for improvement in the future. 

4.2  Finance Watch’s effectiveness, efficiency and 

relevance  

4.2.1  Effectiveness 

Finance Watch’s work during the evaluation period was effective in engaging end-users and 
non-industry  stakeholders.  Finance  Watch’s  contributions  are  valued  by  others 
working on financial regulation, and it performs a coordinating role for national 
activities, which in turn work to involve end-users through campaigns, community events, 
art, rallies and street actions. Finance Watch responded to 18 of about 40 relevant 
public consultations across both evaluation years, so there is potential to increase 
the organisation’s actions here.  

Its publications were valued highly, as were its campaigns and events. Members 
and  stakeholders  alike  considered  Finance  Watch’s  outputs  to  be  of  high  quality  and  its 
expertise strong. The work done by Finance Watch was reported by media outlets 
in both EU and non-EU countries.  

The quality, readability and understandability of Finance Watch’s communications activities 
were  all  rated  highly,  especially  its  newsletters  and  cartoons.  Finance  Watch  is  also 
highly effective at using social media compared to similar organisations, even larger 
organisations such as BEUC. Stakeholders had some reservations, however, regarding the 
effectiveness with which Finance Watch followed up after events, workshops and seminars. 

Roughly 10% of stakeholders responding to the survey (mainly national authorities 
and EU institutions) indicated less knowledge regarding the positions and activities 
of  Finance  Watch.  To  the  extent  its  resources  allow,  Finance  Watch  should  seek  to 
communicate more consistently and effectively to these groups.  

4.2.2  Efficiency 

Finance Watch increased  its expenditure from  2017 to 2018 by about one-fifth, and the 
number of outputs listed in its annual reports increased in most categories. 

100 

 
Finance  Watch  seems  to  operate  as  efficiently  as  most  other  comparable 
organisations.  Two  minor  points  were  mentioned  by  stakeholders  where  the  use  of 
resources could be improved. First, for a period Finance Watch was moving offices and had 
to pay rent for two locations simultaneously.  Second, some stakeholders questioned the 
organisation’s reliance on external consultants (at the same time, others highlighted the 
value of those consultants for the quality of Finance Watch’s research outputs).  

Besides  the  EU  grant,  by  far  the  main  contribution  to  Finance  Watch’s  resources  comes 
from third-party donors (over 90% of total non-EU resources). Finance Watch’s income 
is  significantly  higher  than  other  comparable 
from  third-party  sources 
organisations (including Better Finance). From 2017 to 2018, Finance Watch increased 
its funding from third parties by 19%, while the overall budget only increased by 13% – 
thus  the  share  of  third-party  funding  rose.  Nevertheless,  the  diversification  of  funding 
sources remains a constant challenge for Finance Watch as the total number of donors has 
been low; moreover, it receives a low share of income from membership fees compared to 
other organisations. 

4.2.3  Relevance 

The  objectives  of  Finance  Watch  are  in  line  with  the  objectives  of  the  Union 
Programme  2017-2020 and the thematic coverage of  Finance Watch, as well  as 
its  membership,  are  highly  relevant  for  policy  discussions  on  financial  services. 
Stakeholders indicated that the work of Finance Watch remains crucial for the industry, as 
there are very few organisations that represent  the consumers’  voice within the area  of 
financial services. Stakeholders also recognised the relevance of Finance Watch’s work in 
terms  of  providing  information  on  technical  topics  to  non-expert  citizens  in  a 
transparent and understandable manner.  

Stakeholders also expressed the view that some areas should be addressed in greater 
depth in the future, such as new technologies and their impact on financial services, credit 
assessment or promoting the development of employee share ownership across Europe. 
On  the  other  hand,  there  was  a  generally  shared  opinion  among  stakeholders  that  to 
remain  relevant  in  the  future  and  to  maintain  its  unique  role,  Finance  Watch  should 
focus  its  activities  to  a  greater  extent  in  the  coming  years.  This  could  be  achieved 
through prioritising areas where it has strong expertise.  

The membership of Finance Watch was considered relevant, as it brings together a large 
variety of civil society organisations. 

4.3  Coherence  

The  Union  Programme  and  the  activities  of  Better  Finance  and  Finance  Watch  are 
coherent  with  and  complementary  to  other  EU  measures:  the  evaluation  did  not 
identify  major  overlaps  with  other  EU  initiatives.  Other  organisations,  such  as  BEUC 
COFACE and AGE  Platform Europe, support consumers’  rights and advocacy at EU level, 
but  stakeholders  agreed  that  the  work  of  Better  Finance,  Finance  Watch  and  the 
Union  Programme  is  unique.  Indeed,  the  two  organisations  balance  the  interests  of 
large financial organisations, which are well represented at EU level, and this is coherent 
with overall EU policy principles.  

There  are  also  no  major  overlaps  between  the  actions  of  the  two  beneficiaries. 
There is a general consensus among the stakeholders contacted that the two beneficiaries 
have complementary areas of specialisation, with Better Finance focusing on issues such 
as pensions and investors and Finance Watch paying greater attention to financial inclusion, 
sustainable  finance  and  FinTech.  Nonetheless,  coordination  between  the  two  could  be 
valuable to ensure that their work does not overlap.  

At national level, while some consumer organisations also work on financial matters, there 
are no examples of organisations with the same goals as Better Finance or Finance 

101 

 
Watch: informing the development of finance  policies  – in particular those at EU level  – 
from  an  end-user  and  consumer  perspective.  Stakeholders  agreed  that  the  Union 
Programme is a unique initiative at international level.  

4.4  EU added value  

The findings confirmed that there is additional value from the activities of Better Finance 
and  Finance  Watch.  Their  EU-level  networks  coordinate  national-level  activities. 
Moreover,  there  was  a  consensus  among  stakeholders  that  the  issues  addressed  by 
Better Finance and Finance Watch continue to require action at EU level. Indeed, 
there are still numerous topics and emerging issues important for consumers that require 
further action and visibility at the EU level, for instance related to the development of 
FinTech,  technological  innovation  and  sustainable  finance.  Given  the  growing 
number of EU legislative instruments within retail financial services that directly 
impact  consumers  and  small  investors,  the  two  organisations  could  play  an  even  larger 
role in the future.  

Stakeholders  stated  that  they  expected  negative  consequences  if  financial  support 
for the two organisations were withdrawn, in particular for consumers and financial 
end-users.  Given  the  high  level  of  financial  dependence  of  Better  Finance  and  Finance 
Watch on the grant from the Commission,  withdrawing this support  would severely limit 
their activities. As a result, the stakeholders consulted for this study said that they would 
expect the consumer voice to be heard less and that this would create a significant gap in 
EU-level policy discussions within financial services. 

102 

 
5  Annexes 

5.1  Evaluation questions 

Evaluation 
criterion 

Effective-
ness 

Evaluation question 

To what extent has the work carried out since 2017 by the 
beneficiaries under the action grants been effective in 
terms of: Enhancing the involvement of end-users and 
non-industry stakeholders in EU policy in the financial 
services area?  

To what extent has the work carried out since 2017 by the 
beneficiaries under the action grants been effective in 
terms of: Providing policy makers with views other than 
those expressed by the financial services sector industry?  

To what extent has the work carried out since 2017 by the 
beneficiaries under the action grants been effective in 
terms of: Better informing the wider public about issues at 
stake in the regulation of financial markets for consumers, 
end-users and retail investors?  

Did the beneficiaries manage to deliver both quantitative 
and qualitative expertise in the area of financial services in 
2017 and 2018 (research work, policy papers, responses 
to consultations, studies...)?  

Has the expertise delivered by the beneficiaries been 
found useful and used by their members, by policy makers 
and other stakeholders during that period, and if yes, how 
has it been used? Was the expertise made available used 
both at EU and national level?  

Did the beneficiaries manage to take an active stance on 
European issues in the area of financial services both 
towards EU institutions and national institutions?  

To what extent have the communication activities 
(including press releases, conferences, social media) 
carried out been effective? Have these communication 
activities been found useful and used by members, policy 
makers, and other stakeholders?  

What are the prioritisation methods and criteria used by 
the beneficiaries for the selection of their respective 
activities?  

What is the performance monitoring system of the 
beneficiaries? How did the beneficiaries evaluate their 
results?  

What kind of obstacles hindered or could have hindered 
reaching the set objectives?  

Are there any factors rendering certain aspects of the 
measure more or less effective than others, and what 
lessons can be drawn from them?  

Are there any unintended effects of the measure?  

Efficiency  What should be the optimal level of resource (inputs) 
required to produce outputs and generate the results 
delivered?  

103 

Section in the 
report 
(Better 
Finance) 

Section in the 
report 
(Finance 
Watch) 

3.1.1.1 

3.2.1.1 

3.1.1.1 

3.2.1.2 

3.1.1.2 

3.2.1.2 

3.1.1.4 

3.2.1.4 

3.1.1.2 

3.2.1.4 

3.1.1.2 

3.2.1.2 

3.1.1.3 

3.2.1.3 

3.1.1.5 

3.2.1.5 

3.1.1.5 

3.1.1.5 

3.1.1.6 

3.2.1.6 

3.1.1.6 

3.2.1.6 

3.1.1.6 

3.1.2.1 

3.2.1.6 

3.2.2.1 

 
Evaluation 
criterion 

Evaluation question 

In order to carry out its work programme, did the 
beneficiary manage its funds with efficiency, ensuring best 
value for money?  

What are the criteria used to allocate resources? Are there 
overlaps?  

Has there been a diversification of funding sources since 
2017? Did the beneficiaries engage in initiatives aimed at 
diversifying their funding sources?  

Section in the 
report 
(Better 
Finance) 

Section in the 
report 
(Finance 
Watch) 

3.1.2.2 

3.2.2.2 

3.1.2.3 

3.2.2.3 

3.1.2.4 

3.2.2.4 

Relevance  To what extent do the initial objectives still correspond to 

3.1.3.1 

3.2.3.1 

current needs/issues? 

Are the activities carried out by the beneficiaries relevant 
to achieving the objectives of the Union Programme 2017-
2020? How have the resources of the organisations been 
allocated to the different activities carried out in 2017 and 
2018?  

What topics/files were looked at by each organisation in 
2017 and 2018 in the financial services sector? How were 
these themes been selected? What were the most relevant 
factors in selecting topics of interest? Based on the EU 
political agenda in the financial services during that period, 
were some essential areas missing?  

Who are the members of each beneficiary? Are these 
members relevant, considering the mission of each 
beneficiary? What is the exact role of these members? 
How are tasks and responsibilities shared between the 
organisations and their respective members when carrying 
out the work programme?  

3.1.3.2 

3.2.3.2 

3.1.3.3 

3.2.3.3 

3.1.3.4 

3.2.3.4 

Coherence  Are there overlaps or complementarities between the 
measure and any other Union measure?  

Is there any issue of internal coherence for the measure 
(i.e. between the various components of the measure)? 

To what extent is the measure coherent with similar 
measures at Member State or international level?  

To what extent do publications and events of the 
beneficiaries connect to key EU financial services policy 
objectives?  

To what extent do the publications and events of the 
beneficiaries connect to future global financial services 
policy objectives as foreseen by relevant international 
organisations, e.g. the OECD?  

EU added 
value 

Is there any additional value resulting from the measure, 
compared to what could be achieved at national level?  

To what extent do the issues addressed by the measure 
continue to require action at EU level?  

What would be the most likely consequences of stopping 
or withdrawing the measure?  

3.3.1 

3.3.2 

3.3.3 

3.3.4 

3.3.4 

3.4.1 

3.4.2 

3.4.3 

104 

 
 
 
5.2  Survey responses 

This annex includes the results of the two online surveys. 

105 

 
 
 
5.3  Sources reviewed 

Desk-based research 

Documentation of Better Finance 

Annual Membership Survey 2018 

Annual Reports 2017 – 2018 

Better Finance KPIs 

Better  Finance,  Key  Priorities 
https://betterfinance.eu/organisation/about-us/key-priorities/ 

for  the  Next  Five  Years  2019-2024,  2019.  Available  at: 

Final Reports 2017 – 2018 

Work Programmes 2017 – 2018 

Documentation of Finance Watch 

Annual Reports 2017 – 2018 

Final Reports 2017 – 2018 

Finance Watch Strategic Plan 2017-2018 

Finance Watch, Publications. Available at: https://www.finance-watch.org/policy-regulation/  

Finance Watch, We must change our perception on what ‘returns’ mean, 2018, Webinar. Available at: 
https://www.finance-watch.org/uf/sustainable-finance-we-must-change-our-perception-on-what-
returns-mean/ 

Finance  Watch,  How  to  make  Finance  Serve  Society,  2019.  Available  at:  https://www.finance-
watch.org/our-vision/ 

Finance Watch, Agenda. Available at: https://www.finance-watch.org/agenda/  

EU-level literature and national sources 

AGE Platform Europe, AGE Annual Report 2017. Available at: https://age-platform.eu/content/age-
annual-report-2017 

AGE Platform Europe, Financial Resources, 2018. Available at: https://www.age-platform.eu/financial-
resources 

BEUC, Financial information, 2018. Available at: https://www.beuc.eu/about-beuc/financial-
information 

Bruegel: EU financial services policy since 2007: crisis, responses and prospects 

COFACE Families Europe, 2017 Annual Report, 2017. Available at: http://www.coface-
eu.org/resources/annual-reports/2017-annual-report/ 

Communication on strengthening the Union framework for prudential and anti-money laundering 
supervision, 2018 

Commission Action Plan on Sustainable Finance, 2018 

Donceel, H., ‘EU countries fail to address banking risk reduction’, EURANET Plus News Agency, 14 
March 2018. Available at: https://euranetplus-inside.eu/eu-countries-fail-to-address-banking-risk-
reduction/ 

Eatock, D., Framework for a pan-European personal pension product (PEPP), European Parliament 
Research Service Briefing, 2018. Available at: 
http://www.europarl.europa.eu/RegData/etudes/BRIE/2017/608740/EPRS_BRI%282017%29608740_
EN.pdf 

EU Consumer Financial Services Action Plan, 2017 

EU FSUG: opinions and studies 

European Payments Council: A German SEPA instant credit transfer scheme experience 

European Commission, Commission Staff Working Document: Evaluation of a pilot project and 
preparatory action on enhancing the involvement of end-users and non-industry stakeholders in EU 
policy making in the financial services, 2015 

106 

 
European Commission, Annual Activity Report 2017: Directorate-General for Financial Stability, 
Financial Services and Capital Markets Union, 2017. Available at: 
https://ec.europa.eu/info/sites/info/files/file_import/fisma_aar_2017_final.pdf 

European Commission, Framework for an EU Personal Pension Product (Pan-European Personal 
Pension – PEPP), Legislative Train Schedule. Available at: http://www.europarl.europa.eu/legislative-
train/theme-deeper-and-fairer-internal-market-with-a-strengthened-industrial-base-financial-
services/file-pepp-pan-eu-personal-pension-product  

European Commission, Consumer financial services policy. Available at: 
https://ec.europa.eu/info/business-economy-euro/banking-and-finance/consumer-finance-and-
payments/retail-financial-services/consumer-financial-services-policy_en 

European Commission (2015), Retail Finance Green Paper – Q&A. Available at: 
https://ec.europa.eu/commission/presscorner/detail/fr/MEMO_15_6287 

European Commission, Capital markets union action plan. Available at: 
https://ec.europa.eu/info/business-economy-euro/growth-and-investment/capital-markets-
union/capital-markets-union-action-plan_en 

European Commission, Financial services – EU regulatory framework for crypto-assets. Available at: 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12089-Directive-regulation-
establishing-a-European-framework-for-markets-in-crypto-assets/public-consultation 

G20 High-level principles of financial consumer protection 

Global Partnership for Financial Inclusion (GPFI), New G20 high-level principles for digital financial 
inclusion, 2016 

Glover, J. and Brush, S., ‘MiFID Bond-Price Rules a Gift for Traders as Just 1% Covered’, Bloomberg, 
15 December 2017. Available at: https://www.bloomberg.com/news/articles/2017-12-15/mifid-s-
cautious-start-on-bond-price-rules-shows-lobbying-impact. 

Kern, A., Marketing, Sale and Distribution: Mis-selling of Financial Products, Study for the European 
Parliament, 2018 

OECD Draft Revised Recommendation on consumer protection in the field of consumer credit 

OECD, G20/OECD Policy guidance on financial consumer protection approaches in the digital age, 
2018 

Publications of the OECD Task Force on financial consumer protection 

PWC (2015): Evaluation of grants awarded to Finance Watch and Better Finance 

Regulation 2017/826 

Transparency International 2020 Strategy 

World Bank, Financial education programmes and strategies: approaches and available resources, 
2014 

World Bank, Financial inclusion: financial inclusion is a key enabler to reducing poverty and boosting 
prosperity, 2018 

World Economic Forum, The new physics of financial services, 2018 

World Economic Forum, UFA2020 Overview: universal financial access by 2020, 2018. 

107 

 
 
 
5.4  Stakeholders consulted 

Stakeholder group 

Organisation 

EU bodies 

EU bodies 

EU bodies 

EU bodies 

EU bodies 

EU bodies 

DG FISMA 

DG JUST 

EIOPA 

MEP member of ECON Committee 

Representative of organisation member of the Financial 
Services User Group (FSUG)  

European Financial Reporting Advisory Group (EFRAG) 

Banking/finance association 

European Savings and Retail Banking Group (ESBG) 

Banking/finance association 

Federation of European Stock Exchanges (FESE) 

Banking/finance association 

European Banking Federation (EBF) 

Consumer organisation 

AGE Platform Europe 

Consumer organisation/member 
organisation (Finance Watch) 

COFACE Families Europe 

Consumer organisation/member 
organisation (Finance Watch) 

Bureau Européen des Unions de Consommateurs 
(BEUC) 

Member organisation (Finance Watch) 

Nordic Financial Unions 

Member organisation (Finance Watch) 

UNI Europa 

Member organisation (Finance Watch) 

Weltwirtschaft Ökologie & Entwicklung 

Member organisation (Better Finance) 

ShareAction 

Member organisation (Better Finance) 

UKSA (United Kingdom Shareholders Association) 

Member organisation (Better Finance) 

FinTech Guardian 

Member organisation (Better Finance) 

Bund der Versicherten 

Beneficiary 

Beneficiary 

Better Finance151 

Finance Watch152 

National public authorities 

Estonia Ministry of Finance 

National public authorities 

CONSOB (Commissione Nazionale per le Società e la 
Borsa) Italy 

151 Better Finance was interviewed twice. 
152 Finance Watch was interviewed twice. 

108 

 
 
5.5  Analysis of beneficiary publications and EU policy objectives 

Better Finance publications (2017 and 2018) 

Publication title 

Pension savings: the real 
return – 2018 edition 

The dispersion of risk 
mitigation techniques in 
lifecycle pensions 

Robo-advice: European 
individual investors take a 
look under the hood 

At least 619 UCITs equity 
funds found in breach of key 
EU disclosure rules as poor 
enforcement prospers in 
several key countries 

Pension savings: the real 
return – 2017 edition 

Robo-investing: cyborgs vs 
robots – competing to 
attract European citizens’ 
money 

EU objective: 
Increase 
consumer 
trust and 
empower 
consumers 
when buying 
services at 
home or from 
other Member 
States 

EU objective: 
Reduce legal 
and regulatory 
obstacles 
affecting 
business when 
providing 
financial 
services 
abroad 

EU objective: 
Support the 
development 
of an 
innovative 
digital world 
which can 
overcome 
some of the 
existing 
barriers to the 
Digital Single 
Market 





































109 

IMF – Report 
on FinTech 

World 
Economic 
Forum – 
Report on AI 

World Bank – 
Financial 
inclusion and 
financial 
education 

OECD – 
Financial 
consumer 
protection in 
the digital age 

















































 
Publication title 

EU objective: 
Increase 
consumer 
trust and 
empower 
consumers 
when buying 
services at 
home or from 
other Member 
States 

EU objective: 
Reduce legal 
and regulatory 
obstacles 
affecting 
business when 
providing 
financial 
services 
abroad 

EU objective: 
Support the 
development 
of an 
innovative 
digital world 
which can 
overcome 
some of the 
existing 
barriers to the 
Digital Single 
Market 

IMF – Report 
on FinTech 

World 
Economic 
Forum – 
Report on AI 

World Bank – 
Financial 
inclusion and 
financial 
education 

OECD – 
Financial 
consumer 
protection in 
the digital age 

Mis-selling of financial 
products in the EU – briefing 
paper 2017 

Pension savings: the real 
return – 2016 edition 





























110 

 
 
 
 
Finance Watch publications (2017 and 2018) 

Publication title 

EU objective: 
Increase 
consumer 
trust and 
empower 
consumers 
when buying 
services at 
home or from 
other Member 
States 

EU objective: 
Reduce legal 
and regulatory 
obstacles 
affecting 
business when 
providing 
financial 
services 
abroad 

EU objective: 
Support the 
development 
of an 
innovative 
digital world 
which can 
overcome 
some of the 
existing 
barriers to the 
Digital Single 
Market  

IMF – Report 
on FinTech  

World 
Economic 
Forum – 
Report on AI 

World Bank – 
financial 
inclusion and 
financial 
education 

OECD – 
Financial 
consumer 
protection in 
the digital age  

Financial regulation 
challenged by European 
trade policy 

Global green finance index 2 

Report: ‘#10yearson – back 
to business as usual’ 

‘Dinosaurs in the sandbox’ – 
Briefing note on the FinTech 
Action Plan 

Financial inclusion – 
bibliography 

’”Would you mind holding 
this for me?” the 
(increasingly desperate) 
search for an answer to 
Europe’s NPL problem’ 

Finance Watch 
recommendations for a Pan-
European Personal Pension 
Product 

Finance Watch Policy brief 
on remittances 

















Global green finance index 1  













































































































111 

 
Publication title 

EU objective: 
Increase 
consumer 
trust and 
empower 
consumers 
when buying 
services at 
home or from 
other Member 
States 

EU objective: 
Reduce legal 
and regulatory 
obstacles 
affecting 
business when 
providing 
financial 
services 
abroad 

EU objective: 
Support the 
development 
of an 
innovative 
digital world 
which can 
overcome 
some of the 
existing 
barriers to the 
Digital Single 
Market  

IMF – Report 
on FinTech  

World 
Economic 
Forum – 
Report on AI 

World Bank – 
financial 
inclusion and 
financial 
education 

OECD – 
Financial 
consumer 
protection in 
the digital age  

Finance Watch analysis of 
the HLEG recommendations 
on sustainable finance 

New pathways: building 
blocks for a sustainable 
finance future for Europe 

A pot of gold at the end of 
the rainbow (future of 
pensions) 

Policy brief – ‘One step 
forward, two steps back’ 

Briefing paper – ‘ESMA’s 
role in sustainable finance’ 

The Capital Markets Union 
and sustainability: 
recommendations for the 
mid-term review 

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112 

 
GETTING IN TOUCH WITH THE EU 

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