EU support to Morocco : limited results so far. Special report No 09, 2019.
Date: 2020-02-11
Institutions: European Court of Auditors
Subjects: EU aid, Morocco, association agreement, audit, bilateral relations, development aid, economic aid, economic development, financial aid, health care, human rights, report, social development, sustainable development

EN 

2019 

1 

NO 09 

Special Report  EU support to Morocco - Limited 

results so far 

 
Contents 

Executive summary 

Introduction 

An important partner 

A major recipient of ENI funding 

Bilateral relations challenged 

Audit scope and approach 

Observations 

Focus and design of the support were sub-optimal 

Budget support spread too widely to maximise results 

Budget support programmes not designed to maximise impact 

Difficulties in implementing support 

Delays affected implementation 

Poor results assessment by Commission 

No significant impact for budget support programmes 

Budget support objectives only partially achieved 

Limited progress on key challenges 

2 

Paragraph 

I-VII 

01-13 

01-06 

07-11 

12-13 

14-18 

19-98 

19-48 

19-38 

39-48 

49-64 

49-56 

57-64 

65-98 

65-90 

91-98 

Conclusions and recommendations 

99-107 

 
3 

Annexes 

Annex I – Important EU-Morocco cooperation phases 

Annex II – Budget support programme decisions, contracts and 
payments (2014 to 2018) 

Annex III – Funding by other EU instruments (2014-2018) 

Annex IV – Overview of contracts/projects audited 

Annex V – Budget support programme objectives 

Annex VI – Variable tranche disbursement issues 

Annex VII – Evolution of key indicators 

Annex VIII – Budget support contract ratings by sector 

Acronyms and abbreviations 

Replies of the Commission and the EEAS 

Audit team 

Timeline 

 
 
 
4 

Executive summary 

I Morocco is a North-African country with steady growth and a stable political 
environment. The association agreement signed in 1996 strengthened the cooperation 
between Morocco and the European Union (EU). With the launch of the European 
Neighbourhood Policy (ENP) in 2004, Morocco gradually became a privileged partner 
of the EU in terms of political and economic cooperation as well as in trade, technical 
and development cooperation. 

II We assessed the effectiveness of EU budget support (BS) in Morocco from 2014 
to 2018. The EU BS in Morocco totalled over that period about 0.37 % of the country’s 
total budgetary expenditure. We examined the Commission’s management and the 
degree to which the EU budget support objectives had been achieved. The sectors 
covered were health, social protection, justice and private sector development. During 
the period under review, contracts for all sectors covered by BS totalled €562 million 
and payments €206 million. 

III Based on an appropriate risk analysis and needs assessment, the Commission 
considered BS to be the right choice of aid delivery instrument. However, we 
concluded that its added value and ability to support reforms has been limited due to a 
sub-optimal focus, weaknesses in design and insufficient monitoring. In addition, 
donor coordination was uneven amongst the sectors. 

IV After the judgement of the General Court of the EU in December 2015 on Western 
Sahara, Morocco suspended political dialogue from December 2015 until January 
2019. The Commission did not use this standstill period to develop a clear strategy for 
its relations with Morocco. Although policy dialogue took place, it was not sufficient 
for all sectors. Furthermore, the Commission had not formalised strategies for policy 
dialogues. 

V BS had not sufficiently supported reforms and progress on key challenges was 
limited. The Commission’s management was hampered by weaknesses in the design of 
the BS programmes and their indicators. We also found shortcomings in the 
monitoring procedures and the Commission’s results assessment. 

VI EU support targeted cross-cutting issues such as gender and human rights. 
Despite this targeting, limited improvement could be observed for the period under 
review. 

 
5 

VII We made a number of recommendations for the Commission to strengthen the 
EU approach and the political and policy dialogue, improve the design of the indicators 
and the monitoring procedures, enhance the verification procedures for 
disbursements and increase the visibility of EU support. 

 
 
 
6 

Introduction 

An important partner 
01 The Kingdom of Morocco is geographically Europe’s closest neighbour in North 
Africa (see Figure 1). Morocco was ranked 123rd out of 189 countries in the 2018 
United Nations Human Development Index list and its human development is 
therefore considered medium. With an annual gross domestic product of around 
€101 billion (2018) and approximately 35 million inhabitants, Morocco is the fifth 
largest African economy and an important political and economic partner for the EU. 
Reciprocally, the EU is Morocco’s most important trading partner, representing around 
65 % of its exports and 57 % of its imports1. 

Figure 1 – Morocco 

Source: Eurostat. 

1  Source: Commission figures for 2017 (DG Trade). 

 
 
                                                       
7 

02 Morocco is benefiting from its prudent macroeconomic management and the 
structural reforms undertaken in recent years. Growth has continued at a relatively 
steady pace and inflation is low. The external deficit of the current account and the 
budget deficit have continued to decrease in recent years. 

03 Set against the background of the unrest in the region in the aftermath of the 
2011 Arab Spring, Morocco enjoys a stable political environment. With its new 
constitution, adopted in July 2011, Morocco took important steps towards political 
modernisation and an open economy. 

04 This constitutional reform emphasised the importance of fundamental rights and 
gender equality. However, the national legislation is not yet fully aligned with the 
United Nations conventions on human rights. For example, the United Nations Human 
Rights Committee recommended abolishing the death penalty, combating violence 
against women, increasing gender equality, improving the protection of children’s 
rights, ratifying the Rome statute establishing the International Criminal Court and 
eliminating the criminalisation of homosexuals. Morocco rejected most 
recommendations linked to women’s rights2. 

05 The EU and Morocco have had a stable relationship since their first trade 
agreement was signed in 1969. The partnership has developed and matured over the 
years (see Annex I), leading to the signature of a general association agreement in 
19963. This association agreement, which entered into force in 2000, represents the 
legal basis for EU-Morocco relations. Since the launch of the European Neighbourhood 
Policy in 2004, Morocco has gradually become a privileged partner of the EU in the 
field of political and economic cooperation as well as in trade, technical and 
development cooperation. 

2  United Nations Human Rights Council – Universal Periodic Review Morocco May 2017. 

3  "Euro-Mediterranean Agreement establishing an association between the European 

Communities and their Member States, of the one part, and the Kingdom of Morocco, of 
the other part" – OJ L 70, 18.3.2000, p. 2. 

 
                                                      
8 

06 In the context of the European-Mediterranean partnership, the association 
agreement took a turning with Morocco acceding to advanced status4 in 2008, 
underpinning the special nature of its relationship with the EU. This provided a 
framework for high-level political cooperation in order to bring Moroccan legislation 
further into line with EU legislation and gradually integrate the Moroccan economy 
into the EU internal market. 

A major recipient of ENI funding 

07 Morocco receives more EU development support than any other North-African 
country, except Tunisia, and is one of the main beneficiaries of international 
development aid. The EU is its biggest donor, providing 25.2 % of official development 
assistance (see Figure 2). 

Figure 2 – Official Development Assistance (ODA) in Morocco in 2017, 
main donors ($ million) 

EU

240

471

France

170

368

United Arab Emirates

434

35

Germany

71

389

Kuwait

150

36

Japan

18

141

Arab Fund

127

United States

52

0

200

400

600

800

ODA grants

ODA loans

Source: Organisation for Economic Cooperation and Development. 

4  Document conjoint UE-Maroc sur le renforcement des relations bilatérales/ Statut Avancé 

(13653/08). 

 
 
                                                      
9 

08 In addition to official development assistance, other development actors are also 
active in Morocco. The official statistics of the Organisation for Economic Cooperation 
and Development show for example that the World Bank (WB) and the African 
Development Bank (ADB) are important donors in the sectors of infrastructure projects 
and good governance, health and social protection. 

09 The European Neighbourhood Instrument (ENI) is the key financial instrument 
supporting the Commission’s cooperation with Morocco. The Commission 
programmes the EU’s bilateral support for a period of seven years. The overall amount 
committed fell from €1 431 million for 2007-2013 to €1 399 million for 2014-2020 (see 
Figure 3). The main priority sectors stated in the Single Support Framework (SSF) for 
2014-2017 were equitable access to basic social services, support for democratic 
governance, the rule of law and mobility, and jobs, sustainable, inclusive growth. 

Figure 3 – Bilateral assistance commitments in North Africa 

EN(P)I min. commitments
in € billion

2,0

1,5

1,0

0,5

0,0

Libya

Algeria

Egypt

Morocco

Tunisia

ENPI 2007-2013

ENI 2014-2020

Source: European Commission. 

10 Morocco is one of the biggest beneficiaries of bilateral ENI programmes in North 
Africa. From 2014 to 2018, the allocation for BS (see Box 1) resulted in contracts 
totalling €562 million and payments totalling almost €206 million (see Annex II). On 
average,  BS constitutes 75 % of annual EU expenditure for Morocco. Morocco also 
receives additional funding under several thematic programmes and instruments (see 
Annex III) and EU support is also channelled via financial institutions and trust funds. 

 
 
10 

Box 1 

The budget support modality 

According to the Commission, BS is an effective means of delivering aid to support 
reforms and sustainable development goals. The Commission considers it to be a 
vector of change for improving public financial management, macroeconomic 
stability, sustainable and inclusive growth and the fight against corruption and fraud, 
and promoting sector reforms, human rights, democratic values and gender 
equality.  

BS involves dialogue, financial transfers to the national treasury account of the 
partner country, performance assessment and capacity development, based on 
partnership and mutual accountability. The funds transferred are not earmarked for 
a specific purpose; it is therefore not possible to follow where and how they are 
used. Once the funds have been transferred, the partner country can use them in its 
normal budgetary process. 

BS is not provided to every country. Eligibility criteria have to be met before and 
during the programme and conditions need to be fulfilled before payments are 
made. 

To be eligible for BS, a country must have: 

o 

o 

o 

o 

 relevant, credible sectoral/national development strategies; 

a stability-oriented macroeconomic policy; 

a relevant, credible public financial management reform programme and 

budget transparency and oversight (budget information must be made publicly 
available). 

In addition, a fundamental values assessment needs to be undertaken when BS 
contracts are proposed. 

BS is paid in fixed and variable tranches. Fixed tranches have a fixed value, specified 
in advance within the financing agreement (contract between the beneficiary 
country and the Commission). They are disbursed in full (when all conditions are 
met) or not at all (if one or more conditions are not met). Variable tranches have a 
maximum value specified in advance in the financing agreement. They are either 
disbursed in full or in part with the amount disbursed being based on the perfor-
mance achieved in relation to pre-specified targets or designated performance 
indicators (provided that at the same time the general conditions are all met). This 
performance assessment is based on data to be provided by the beneficiary country 
defined in the financing agreement (sources of verification). 

Source: The Commission’s Budget Support Guidelines, September 2017. 

 
11 

11 The EU Delegation in Rabat and the Directorate General for Neighbourhood and 
Enlargement negotiations are managing and implementing the programmes. The 
European External Action Service (EEAS) and the EU Head of Delegation are 
responsible for the political dialogue. 

Bilateral relations challenged 

12 The EU and Morocco have enjoyed long-standing good relations. However, the 
EU-Morocco partnership had been strained since 2015, when the General Court of the 
EU made the first series of rulings that Western Sahara was not a part of Morocco. This 
meant that Western Sahara was not part of the fisheries and agriculture agreement 
between the EU and Morocco and could not benefit from the same tariff preferences. 
The Western Sahara issue (see Box 2) put the EU-Morocco partnership under stress 
and Morocco suspended political dialogue. 

 
12 

Box 2 

Summary Judgments of the Court of Justice of the European Union 
(CJEU) 

10 December 2015: The judgment of the General Court of the EU5 annulled the 
Decision6 on the implementation of the agricultural agreement in the territory of 
Western Sahara. The judgment established that the agricultural agreement applied 
to Western Sahara, but that Western Sahara was not a part of Morocco, and that the 
Kingdom of Morocco was not the administering power. Before adopting the 
Decision, the Council should have ensured that the natural resources of the territory 
would not be exploited to the detriment of its inhabitants and their fundamental 
rights. 

21 December 20167: The CJEU annulled the judgment of 2015 and ruled that no 
trade or association agreement with Morocco could apply to the territory of 
Western Sahara, since Western Sahara was not part of Morocco. Accordingly, the 
CJEU stated that the people of Western Sahara should be viewed as a third party to 
the EU's relations with Morocco. Therefore, as for any bilateral arrangement, the 
express consent of the people of the territory should be obtained. 

February 20188: The CJEU held that, as Western Sahara did not form part of the 
Kingdom of Morocco, the waters adjacent to Western Sahara were not part of the 
Moroccan fishing zone referred to in the Fisheries Agreement. 

First quarter 2019: The European Parliament and the Council approved an 
amendment to two protocols, for fisheries and agriculture. The aim was to foster 
economic development in Western Sahara by treating its exports to the EU in the 
same way as exports from Morocco. 

13 Political dialogue is held at the level of the EEAS, the EU Head of Delegation and 
the Ministry of Foreign Affairs in Morocco.The policy dialogue is held at sectoral level 
between the EU Delegation staff and the Moroccan authorities. Figure 4 explains the 
difference between political and policy dialogue. 

5 

Judgment by the General Court of the EU of 10 December 2015 (Case T-512/12). 

6  2012/497/EU: Council Decision, (OJ L 241, 7.9.2012, p. 2). 

7 

8 

Judgment by the CJEU of 21 December 2016 (Case C-104/16 P). 

Judgment of the CJEU of 27 February 2018 (Case C-266/16). 

 
                                                      
13 

Figure 4 – Political and policy dialogue 

Political Dialogue 

Covers all EU external policies: development policy, trade, foreign and security 
policy 

In line with the EU treaties, European External Action or other legal bases 

In all countries, political dialogue usually takes place between the EU Head of 
Delegation and Ministerial level 

Covers the specific sectors of EU cooperation 

Policy Dialogue 

Should support the general and specific objectives of budget support contracts 

Support the partner’s country’s efforts to achieve the objectives laid down in their 
strategies. May carry a political dimension (e.g. when difficult reforms are politically 
costly). 

Source: DEVCO Academy. 

 
 
 
14 

Audit scope and approach 

14 This audit assessed the effectiveness of EU BS to Morocco for 2014-2018. We 
asked the following questions: 

o  Did the Commission and the EEAS choose the priority sectors appropriately and 

design the programmes well? 

o  Did the Commission  implement EU support appropriately in Morocco? 

o  Were the objectives of EU support to Morocco achieved? 

15 The audit covered the period from the official decision setting up the European 
Neighbourhood Instrument (1 January 2014) up to the end of 2018. The audit focused 
on this period, as an external evaluation on BS to Morocco had already been carried 
out for the period 2005 to 2012 (published in 2014). Furthermore, this period is in line 
with the ENI-programming period. Amounts contracted and paid for this period are 
material. In addition, the Commission has not yet carried out a country evaluation 
covering support to Morocco. 

16 The audit was carried out from September 2018 to February 2019, covering 
health, social protection, justice and private sector development (PACC: ‘programme 
d’appui à la croissance verte et la compétitivité au Maroc’). The majority of the ENI 
expenditure in Morocco between 2014 and 2018 was in these sectors (see Annex II)9. 
In addition to the BS programmes in these four sectors, we reviewed the 10 projects 
relating to the corresponding financing decisions (see Annex IV). We examined 
whether gender and human rights were addressed as cross-cutting issues in these BS 
programmes. Annex V summarises the objectives of the BS programmes audited and 
Annex VII provides an assessment by sector. 

9  65 % of allocated expenditure and 72 % of payments. 

 
                                                      
15 

17 Our audit work consisted of a desk review, interviews with staff from the 
Commission Headquarters and the EEAS, and an on-the-spot visit. The visit enabled us 
to collect further information and interview representatives of the national authorities 
and staff at the EU Delegation and representations of EU Member States in Morocco 
(Spanish and French representations). We also interviewed international organisations 
and other donors, such as the World Bank, the ADB, Unicef and the Deutsche 
Gesellschaft für Internationale Zusammenarbeit. In addition, we visited beneficiaries 
including a detention centre for girls, a social protection centre and private companies 
that had received investment subsidies. 

18 As one of the EU’s largest beneficiaries of external aid, Morocco is a strategic 
partner in key policy areas. The Commission can benefit from the conclusions and 
recommendations of this report by taking them into account for the next programming 
period (as from 2021). The relevance and potential impact of this report are therefore 
high. 

 
 
 
16 

Observations 

Focus and design of the support were sub-optimal 

Budget support spread too widely to maximise results 

19 We looked at whether the Commission and the EEAS had consistently prioritised 
sectors for BS based on Morocco’s main needs. We checked whether an adequate 
needs assessment had been carried out. We also considered whether the Commission 
had coordinated its approach appropriately with other donors active in Morocco.  

Budget support was based on an appropriate risk/needs assessment 

20 The Commission considered BS to be the most appropriate instrument for 
supporting and sustaining the implementation of national and sectoral reforms. The 
Commission performs an annual risk analysis for the following categories: political 
governance, macroeconomic stability, development, public financial management and 
corruption/fraud. The eligibility criteria were clearly met at the design phase, and the 
fundamental values were not considered high risk. Morocco’s risk level was assessed 
as moderate. 

21 According to the Commission’s risk analysis, however, one of the main residual 
risks concerned corruption. In the absence of an anti-corruption body, the Commission 
was not able to address corruption through this avenue. This meant that the 
Commission addressed corruption through some of its BS programmes. For example, 
the digitalisation of procedures in the PACC programme is contributing to reducing 
corruption as well as measures and indicators in the health and social protection BS 
programmes. In the justice programme, the organic law contains measures aimed at 
reducing corruption. However, some of these, such as the code of ethics for judges, 
had not yet been adopted. 

22 The country reports of the International Monetary Fund and the Public 
Expenditure and Financial Accountability assessment of 2016 did not reveal major 
deficiencies and were in line with the Commission’s risk assessment. 

 
17 

23 The Commission had carried out a detailed needs assessment for the specific BS 
programmes in cooperation with the national authorities and consulted a wide range 
of stakeholders during programme formulation. The EU Delegation had also met with 
civil society organisations. However, the Moroccan Court of Auditors (which is an 
important stakeholder) was not consulted during the needs assessment for the sectors 
audited. 

24 The BS programmes were complementary to other EU support, and coordination, 
in the form of bilateral and thematic programmes, was good. Technical assistance was 
included in the design of all BS programmes. The total proportion of complementary 
cooperation instruments (technical assistance, twinning, etc.) supplementing BS in 
Morocco had increased over time, from 5 % (2007-2010) to 13 % (2011-2013), then to 
16 % (2014-2016) and then further to 18 % (2017-2018). 

Important needs addressed but funding covered many areas 

25 When programming bilateral support for Morocco, the Commission had 
addressed numerous priority areas. These areas responded to needs covered by 
sectoral strategies and reflected in both the national government plan and the EU 
action plan. In the programming documents, the Commission had demonstrated 
clearly why sectors required funding. The priority sectors remained the same for 2007-
2013 and 2014-2020 (see Figure 5). 

Figure 5 – Overview of priority sectors 2007-2020 

Sector 1 

Sector 2 

2007-2013 

2014-2020  

Social policy development 
€412 million 

Equitable access to basic social services 
€441 million 

Governance/Human rights 
€115 million 

Support to democratic governance, the rule of 
law and mobility 
€337.5 million 

Sector 3  Modernisation of the economy 

€298 million 

Jobs, sustainable and inclusive growth 
€367.5 million 

Capacity 
building 

Institutional support (incl. Réussir 
le Statut Avancé) 
€272 million 

Complementary support for capacity 
development and civil society 
€294 million 

Other 

Environment 
€137 million 

Total 

€1 234 million 

€1 470 million 

Source: Indicative programmes 2007-2010, 2011-2013 and SSF 2014-2020. 

 
 
 
18 

26 The Commission had defined the three priority sectors too broadly, as they 
consisted of 13 sub-sectors10, many of which could be considered as standalone 
sectors. There was therefore scope for reducing aid fragmentation. In addition, 
focusing on too many sectors reduces the potential impact of EU support. The agenda 
for change11 states that the EU shall engage in no more than three sectors per partner 
country to increase the impact and leverage of its assistance. 

27 The amount allocated to each programme depended on a number of 
parameters12. Amounts allocated were based on negotiations, which were not 
documented. Therefore, the Commission was unable to demonstrate that the amounts 
had been allocated using a transparent method. 

The Commission had not developed a clear strategy for future relations with 
Morocco during suspension of political dialogue 

28 The CJEU judgment and institutional blocking after the parliamentary elections 
had a limited but noticeable impact on cooperation (see Box 2). 

29 The initial CJEU judgment was issued in December 2015. The negotiations relating 
to the Deep and Comprehensive Free Trade Agreement, the Migration and Mobility 
Partnership and Security/Counter Terrorism cooperation had not progressed since 
then. 

10  Single Support Framework 2014-2017. The sub-sectors include for example health, 

education, justice and rural development. 

11  Increasing the impact of EU Development Policy: an Agenda for Change 

(COM(2011) 637 final). 

12  The indicative allocations provided for in the SSF, the level of funding at which the EU can 
ensure sufficient policy leverage, additional funding required for strategy implementation, 
absorption capacity and other stakeholder interventions. 

 
                                                      
19 

30 The Association Council13 is meant to meet annually to review bilateral relations 
and evaluate the progress of the implementation of the association agreement. 
However, there were no meetings between December 2015 and June 2019. Therefore, 
the last available progress report drafted by the EEAS related to 2014 activities. 
However, the EU Delegation continued to provide regular political reporting. 

31  Morocco’s advanced status had been extended to the end of 2018 and a further 
extension to the end of 2020 was being considered. In addition, Morocco had 
requested a complete review of bilateral relations with the EU, with a new, tailor-
made framework going beyond the advanced status. 

32 In the absence of a formal political dialogue, the Commission had not addressed 
new priorities and/or challenges, anticipating the expiry of the SSF. In recent years, the 
EU Delegation had reacted to requests from the Moroccan Government on the basis of 
the existing SSF instead of using the political standstill to re-assess its operational 
priorities with Morocco and develop a clear, forward-looking strategy. The 
Commisssion and the Member States considered that the SSF priorities were still 
relevant and thus extended the 2014-2017 SSF to 2018. For 2019-2020 there would be 
no new partnership priorities. Instead, there would simply be a short-term framework 
similar to the current SSF which can serve as a legal basis for 2019-2020 programming. 

33 The Commission did not suspend BS as the EU financial regulation, the BS 
guidelines, and the provisions of the financing agreements do not provide for the 
suspension of BS in the absence of political dialogue. Payments relating to BS 
continued as programmed and were higher in 2016 and 2017 than in the two 
preceding years (see Figure 6). 

13  Meeting between the Moroccan authorities led by the Minister of Foreign Affairs, the EU 
High Representative for Common Foreign Security and Policy, the EU Commissioner for 
European Neighbourhood Policy and enlargement negotiations and the Member States’ 
representatives. 

 
                                                      
Figure 6 – BS payments for Morocco during 2011-2018 

Disbursements  Budget Support

20 

o
r
u
e

n
o

i
l
l
i

M

180

160

140

120

100

80

60

40

20

0

2011

2012

2013

2014

2015

2016

2017

2018

Year

Source: DEVCO Data Warehouse. 

Donor coordination was uneven 

34 During the identification phase, the EU assesses which other projects are ongoing 
in the sector and holds meetings with the technical and financial partners to ascertain 
ongoing/planned financing in the sector. The ‘Groupe Principal des Partenaires’ had 
met every two months since 2016 to discuss sectoral issues at strategic level. However, 
not all donors in Morocco had met regularly (e.g. China and India). 

35 In Morocco, there was a wide range of donors in most sectors. However, there 
was a lack of consistency between Member States’ objectives/priorities and those of 
the EU. Although the process of joint programming was introduced in 2014, Member 
States did not implement it until 2017, when agreement was reached over how to 
implement it in three sectors (migration, gender and vocational training). This was 
because Member States were keen to maintain their own visibility. The large number 
of sectors and donors involved did not contribute towards aid effectiveness. 

36 Some sectors had effectively established arrangements for donors, particularly 
the health sector where objectives and performance assessment frameworks were 
shared. The Commission chaired the financial and technical partner group for health 
and social protection. For the PACC, there was no formal donor meeting group, but 
there was one coordination platform: the G20 Compact with Africa. 

 
 
 
 
21 

37 In the justice sector,  formal meetings did not take place between the donors 
between 2015 and 2017. As the Ministry of Justice has ensured coordination of this 
sector since 2017, meetings have been organised with the technical and financial 
partners but only once a year, even though partners had expressed a wish to meet at 
least twice a year in order to avoid overlaps. There was little documentation of these 
meetings. The steering committee required by the financing agreement to ensure 
coordination between the ministries and the programme partners, had not been 
created. 

38 For the sectors audited where both the EU and other donors were providing 
support, there were very few joint indicators. While in the health sector 11 of the 18 
indicators were similar to those used by the World Bank, in the PACC programme there 
were seven similar and in the social protection programme, there was only one. 
Annual assessments and evaluations were not shared systematically for the sectors 
audited. 

Budget support programmes not designed to maximise impact 

39 We verified if the BS targets and indicators were aimed at supporting reforms. 

A number of budget support targets not ambitious enough to support reforms 

40 Although BS programmes were aligned with the country’s sectoral strategies, not 
all strategies had quantified targets for specific objectives or action plans. 
Consequently, it was not always possible to compare the targets of the BS programmes 
with national sectoral targets. However, as from 2019, the Budget Law requires 
ministries to accompany budget projections with performance targets set against their 
main strategic policy objectives. 

41 The indicators related to the creation of institutions, drafting legislation and 
national plans did not focus on outcomes. 

42 We found that 25 of the 86 BS targets were not ambitious enough to support 
reforms. For example, in the health sector, the main problems were insufficient 
medical staff and disparities between urban and rural areas. However, the BS 
programme focused mainly on reducing disparities between rural and urban areas and 
addressed the lack of human resources through only one target of the variable tranche 
which was not very ambitiousaiming to train just 13 doctors as “family doctors” over a 
period of two years. 

 
22 

43 Some of the challenges identified by various stakeholders (Ministry of Health, 
World Bank, etc.) in the health sector had not been  directly addressed in the design of 
the BS programme: high staff absenteeism, low attractiveness of remote areas for 
medical staff and the structural underuse of hospital infrastructure. 

44 In the social protection sector the target of bringing 25 % of social protection 
centers into line with the new law was not ambitious since it had already been 
achieved, as a higher percentage than this already met the stricter requirements of the 
previous law. 

45 In the justice sector, the objectives, although broad, were in line with the 
objectives of the reform, for instance aiming for an independent sector and the judicial 
protection of rights and freedoms. 

46 The PACC was built on three strategies, two of which were lacking time-bound 
objectives, making it difficult to define the most important/urgent needs. The 
programme covered too many sectors, providing support for small and medium-sized 
enterprises (SMEs), start-ups, land tenure, trade, sustainable development and energy. 

Indicator design did not enable objective performance measurement 

47 The Commission assessed Morocco’s monitoring and evaluation systems when 
designing BS programmes. In the absence of a framework assessment for evaluating 
sectoral progress, it applied existing guidelines. With the exception of the health 
sector, sectoral strategies were not always accompanied by a fully-fledged action plan, 
with baseline data, results indicators and pre-defined targets. 

 
23 

48 We noted the following weaknesses in the selection and use of indicators: 

(a) 

Indicators of the variable tranches were not appropriate to monitor progress of 
the specific objectives. 

(b)  Nearly all indicators related to outputs or process (e.g. the proposal to draft a 

law), not to outcomes.  

(c)  Two indicators were not sufficiently relevant as they did not measure the BS 

programme objectives. In the health sector, two indicators were related to the 
expected result ‘reduce disparities between urban and rural environments’. Both 
indicators reflected an absolute value, i.e. ‘increase in diabetic patients treated in 
rural areas’ and ‘increase in hypertensive patients treated in rural areas’. While an 
increase could mean that more patients in need were being treated (positive 
increase), it could also mean that the two conditions had become more prevalent 
in Morocco (negative increase). In any case, the indicators were not oriented 
towards measuring  a decrease in disparity. 

(d) 

(e) 

Indicators frequently had inaccurate baselines or none at all14. An accurate 
starting point is necessary for measuring progress and assessing whether targets 
are both realistic and sufficiently ambitious. 

Indicators had outdated baselines and targets15. The programming process took 
about a year, so baselines no longer reflected reality and targets had sometimes 
already been achieved or were nearing achievement when the financing 
agreement was signed16. Failing to update baselines and targets when signing the 
financing agreement resulted in payments being made where development had 
deteriorated instead of improved. 

14  Of the 54 targets considered for disbursement, 24 should have had an appropriate baseline. 
However, a baseline was set for only seven targets. Eight targets had an inaccurate baseline 
or none at all, and nine targets had an outdated baseline. 

15  Of the 24 targets that should have had a baseline, nine had an outdated baseline. Of the 54 
targets considered for disbursement, eight had already been achieved before the financing 
agreement was signed. 

16  The design phase is time-consuming (about a year) and is subject to various levels of 

approval. The Commission does not have the flexibility to change the targets or indicators 
at the end of the negotiation procedure.  

 
                                                      
24 

Difficulties in implementing support 

Delays affected implementation 

49 We examined whether the activities had been implemented as planned and 
outputs delivered as intended. 

Outputs and complementary support not always delivered on time 

50 Overall,  implementation of reforms did not always take place as planned in the 
sectors audited. Delays were mainly due to legislative proposals not being approved in 
time (social protection), the fact that Parliament had not yet adopted the penal law 
and penal procedure code (justice), the lack of a dedicated action plan (health) and the 
limited policy dialogue with the private sector (PACC). 

51 As the implementation of reforms was delayed in the justice and PACC sectors, 
several of the disbursements were also later than originally planned. Despite the delay 
in social protection activities during the first year of implementation, the Commission 
did not consider it necessary to take corrective action as technical assistance was in 
place from previous BS programmes. The Commission had extended the PACC 
programme by one year and the justice programme by two years. The initial duration 
of the programmes was four years (and five for the justice programme). 

52 In the sectors audited, the BS programmes were complemented by technical 
assistance and twinning (between 2 % and 13 % of the BS amount). Although this 
complementary support provided in the sectors audited was in line with the objectives 
of the BS programmes, it frequently started two to three years after the financing 
agreements were signed. Consequently, it did not reinforce BS appropriately. 

Limited evidence of sector policy dialogue 

53 We checked whether the Commission had a structured approach to policy 
dialogue that included setting clear objectives, interacting frequently with the 
Moroccan authorities and keeping progress logs. 

54 Policy dialogue is an essential activity under BS. It is one of the main components 
of BS contracts, alongside the transfer of funds and capacity strengthening. It is 
expected to contribute towards achieving the objectives of BS programmes. 

 
25 

55 Despite the suspension of the political dialogue, the sectoral (policy) dialogue had 
continued between the EU Delegation and some ministries (e.g. Health and Social 
Development). However, the EU Delegation did not have a formalised policy dialogue 
strategy with clear objectives. There was no evidence that the dialogue addressed 
adherence to national sectoral strategies and documentation of the meetings held was 
poor. Meetings took place on an ad-hoc basis, taking into account the needs of both 
sides. For justice and PACC, the dialogue was minimal. 

56 The Ministry of Foreign Affairs had advised the other ministries not to 
communicate openly about any EU support. Contacts between the ministries and the 
EU Delegation did not always take place at the appropriate level. 

Poor results assessment by Commission 

57 We examined whether the Commission had monitored the implementation and 
performance of the programmes appropriately and whether the conditions for 
disbursements had been met. 

Variable tranches often paid when conditions were neither met nor verified 

58 The disbursement of the variable tranches17 was based on sources of verification 
stipulated in the financing agreement and agreed at design stage between the 
Commission and the ministries, as well as other official sources provided by the 
government. Nevertheless, several sources18 of verification stated in the financing 
agreement did not exist or the ministries did not provide them. 

17  See Box 1. 

18  Twelve out of the 42 targets for which this was applicable (i.e. 29%). 

 
                                                      
26 

59 In our sample of 54 targets, the Commission considered 33 of them to have been 
achieved. We looked at how the Commission assessed whether indicators had been 
achieved before making payments and observed that19: 

(a)  The Commission made payments based on the achievement of 10 targets without 
checking the reliability of the data used for verifying this. For example, two 
disbursements under the PACC were made on the basis of the number of self-
employed people, although the EU Delegation had not checked the accuracy of 
the database used. The main criterion used was self-employed people declaring 
themselves as such, but this was not sufficient, since this declaration is voluntary. 
Ministry of Finance data showed that the number of self-declared self-employed 
people was roughly double the number of self-employed individuals who declared 
their income for taxation. 

(b)  The Commission made payments for seven targets achieved on the basis of 

baselines which were not up to date. For example, the baseline for an indicator 
relating to childbirth used for payments made in 2017 took 2012 figures as the 
baseline for a BS programme signed in 2015. However, had 2014 been used as a 
baseline, as childbirth was higher, it would have been clear that the situation had 
deteriorated, and BS payments would have been lower. 

(c)  The Commission paid for five targets without having set an initial baseline to 

compare progress to. In a further six cases, disbursements were made based on 
inappropriate calculations. For example, the number of diabetic patients treated 
was calculated without adjusting for the situation before EU support began. 

(d) 

In 15 cases, the Commission paid for targets on which no progress had been made 
or when targets were not achieved. For example, one target was to increase the 
number of general practitioners in rural primary healthcare centres. Although the 
number decreased, the Commission paid the support. As a consequence of the 
Court’s audit, for two of these targets, the Commission has however initiated the 
necessary steps to recover the amount paid. 

19  A target can belong to one or more of the following sub-headings. 

 
                                                      
27 

60 A total of around €88 million was paid in relation to variable tranches for the 
sectors audited. However, the lack of rigorous controls when assessing results had a 
financial impact of €6.79 million. Furthermore, regular payments amounted to 
€19.9 million, although the corresponding indicators were not contributing to the 
objectives of the BS programme. In addition, an amount of €15.28 million was paid 
out, although no sufficient checks were performed or inappropriate sources of 
verification were taken into account. Annex VI contains a detailed overview by sector. 

61 In addition, €14.64 million was carried over although the conditions for carry-
over stated in the financing agreement were not met. The Ministries of Social 
Development and Justice had asked to carry over to the following year the evaluation 
of five indicators (representing €10 million) and three indicators (representing 
€4.64 million), respectively. However, the Ministries did not provide any written 
justification for this, nor was the delay related to external factors. 

The Commission did not always monitor progress thoroughly 

62 The advanced status granted to Morocco is of high political importance and 
constitutes an overarching framework for EU-Morocco relations. Its aim is to reinforce 
the relationship. However, there was no formal evaluation of the results achieved or 
areas covered.The Commission plans to perform a country evaluation in 2019 on the 
‘EU support/assistance in Morocco’. 

63 External experts paid by the Commission carry out field visits for each BS 
programme twice yearly and at the end of each BS programme. The follow-up of the 
recommendations is not systematically reflected in their reports. 

64 The EU Delegation monitored programmes mainly when making payments 
related to the achievement of indicators. This was often too late to allow for the 
necessary corrections to be made when there were delays. However, in the justice 
sector, the EU Delegation did not carry out sufficient monitoring at operational level, 
which had an effect on the payment of the variable tranche (see Box 3). 

 
28 

Box 3 

Weaknesses in the Commission’s monitoring procedures 

As part of our audit of the justice sector, we planned to visit three locations funded 
through indicator three of the BS programme, which aims at the rationalisation of 
the judicial map: the Court of Appeal in Guelmim, the Court of First Instance in Sidi 
Ifni and the Judicial Centre in Taghjijt. 

The targets related to the disbursement for this indicator at the end of 2017 were 
the adoption of a law proposal on the rationalisation of the judicial map20 and the 
implementation of 60 % of this reform as regards the judicial centres21. 

The objective of our on-the spot visit in January 2019 was to check the effective 
implementation of the law and of the decision on the judicial centres. Six weeks 
after we had informed the EU Delegation of our planned visit, we were informed 
that none of the three buildings were operational. 

This indicates that the EU Delegation had not carried out field visits and had made 
payments solely on the basis of a legislative proposal and a ministerial decision. 

No significant impact for budget support programmes 

Budget support objectives only partially achieved 

65 At the time of our audit, the BS programmes and related technical assistance 
contracts were still ongoing. We examined the extent to which the targets set for the 
BS programmes had been achieved. We assessed progress towards achieving the 
objectives of BS in the four sectors we examined for our audit as well as any links 
between this progress and EU support. 

20  Which included the creation of a Court of Appeal in Guelmim and 13 Courts of First Instance 
(through the creation of a Court of First Instance in Tahenaout and the transformation of 
12 judicial centres into Courts of First Instance, including Sidi Ifni). 

21  According to the expert mission report (November 2017) approved by the European 

Commission, this implementation rate of 60 % results from the reduction of the number of 
judicial centres from 120 to 72 (eight of which had to be activated) as provided by a 
ministerial decision. 

 
                                                      
29 

Less than half of budget support targets met 

66 A majority of the targets of the BS programmes had not yet been achieved, but 
the BS programmes and related technical assistance contracts were still ongoing. Our 
assessment differs from that of the EU Delegation with regard to the achievement of 
targets. According to the EU Delegation, out of 54 targets, 62 % had been achieved by 
the end of December 2018, whereas we found the achievement rate to be 40 % (see 
Figure 7). The Commission had assessed several of the unachieved targets as low risk 
during the design phase. 

Figure 7 – Achievement of targets 

BS Sector 

Targets 

Targets achieved – 
EU Delegation 

Targets achieved – 
European Court of 
Auditors 

Health – first variable 
tranche 

Health – second variable 
tranche 

Social Protection – first 
variable tranche 

Justice – first variable 
tranche 

PACC – first variable 
tranche 

PACC – second variable 
tranche 

Achievement rate 
Source: European Court of Auditors. 

11 

10 

9 

9 

10 

5 

54 

7 

5 

3 

6 

8 

4 

5 

4 

1 

3.5 

5 

3 

62 % 

40 % 

67 Despite some improvements in the health sector (see paragraph 76), some 
important indicators of the BS programme had not yet been achieved: better access to 
health centres for the rural population, increase in the number of women giving birth 
in these centres, improved availability of medicines in health centres and health 
inspectors in every region. 

 
30 

68 For the social protection sector, five out of nine were process indicators and 
hence affected by the legislative delays (see paragraph 50). With regard to the results 
indicators, the following crucial targets had not yet been achieved: three-year budget 
plan for the social services sector, global medical coverage for employees and medical 
coverage for non-salaried workers. 

69 For the justice sector, two process indicators were affected by the delay in the 
approval of the penal code. With regard to the results indicators, only one of the eight 
judicial centres to be activated was operational. It is impossible to assess whether or 
not the target relating to judicial assistance had been achieved, as the source of 
verification used to identify the beneficiaries (RAMED cardholders) was not 
appropriate. 

70 According to the EU Delegation, most of the PACC targets had been achieved. 
However, due to a lack of documentation or the absence of checks by the 
EU Delegation, there was no proof of the achievement of five indicators at the time of 
payment (see Annex VI). 

71 Despite the extensions for indicator assessment granted by the EU Delegation 
(see paragraph 51), target achievement was still low. In addition, in 2018, the 
Commission set less ambitious targets for five indicators in the justice sector, dropped 
one PACC indicator and reduced the targets of two others. As such, the Commission 
reduced the conditions for achievement. 

Budget support had not sufficiently supported reforms 

72 BS funds in Morocco are not linked to a specific budget line. According to the 
Commission22, this had generated growing discontent in some ministries due to the 
feeling that their efforts were not (or not always) rewarded with additional budgetary 
outlays. Although the national authorities favour BS as an aid delivery method, the 
sectoral ministries do not notice its added value, preferring to receive technical 
assistance as this is more tangible. Furthermore, up until 2018 there had been no 
multiannual budgetary forecasts. As from 2019, there is a three-year budget plan, 
which could be aligned with the multiannual BS programmes. 

22  European Commission - Issues Paper: a review of the budget support instrument in 

Morocco, March 2015 and October 2018. 

 
                                                      
31 

73 Although the budgetary executions rates were satisfactory, significant amounts 
remained to be spent in the budgets of the ministries audited for 2014-2016, and also 
for 2017 in the case of the Ministry of Industry (see Figure 8). The ministries’ annual 
budgets had not substantially increased, and had even fallen in the case of the Ministry 
of Energy (see Figure 9). This puts the added value of BS into question. 

Figure 8 – Yearly unspent budget 

)

m
a
h
r
i

d
n
o

i
l
l
i

m

(

t
e
g
d
u
b
t
n
e
p
s
n
u
y
l
r
a
e
y

1 000

800

600

400

200

0

-200

-400

2014

2015

2016

2017

Ministry of Health Ministry of Social Development Ministry of Justice Ministry of Energy Ministry of Industry

Source: EU Delegation. 

 
 
 
 
 
 
Figure 9 – Ministerial budgets 2014-2018 

32 

)

m
a
h
r
i
d
n
o

i
l
l
i

m

l

(
n
o
i
t
u
o
v
e
y
r
a
t
e
g
d
u
B

16 000

14 000

12 000

10 000

8 000

6 000

4 000

2 000

0

2014

2015

2016

2017

2018

Ministry of Health

Ministry of Social Development

Ministry of Justice

Ministry of Energy

Ministry of Industry

Source: European Court of Auditors. 

74 Moreover, EU BS only represents a fraction of the country’s gross domestic 
product, thereby limiting its overall leverage (see Figure 10). 

Figure 10 – Budget support as % of Moroccan GDP and budgetary 
expenditure 

Morocco’s 
nominal 
GDP 
(million 
euro) 

Morocco’s 
general 
budgetary 
expenditure 
(million euro) 

EU BS 
(million 
euro) 

 % EU BS/ 
Morocco’s 
GDP 

 % EU BS/ 
Morocco’s 
budgetary 
expenditure 

33 970 

65.0 

35 400 

115.98 

35 980 

36 800 

37 680 

163.9 

164.2 

153.3 

0.08 

0.13 

0.18 

0.17 

0.15 

0.19 

0.32 

0.46 

0.47 

0.41 

Period 

2014 

2015 

2016 

2017 

82 800 

91 200 

93 300 

97 300 

2018 

100 500 

Source: EU Delegation. 

 
 
 
 
 
33 

75 For the PACC programme, only little statistical data for Morocco is publicly 
available. The reports provided by the national authorities do not allow sectoral 
progress to be monitored appropriately. For instance, the EU Delegation lacked annual 
statistics for a number of key figures to monitor the industrial acceleration plan. 
Consequently, it is difficult to determine the added value of the programme. 

Health 

76 Limited progress had been made towards the objectives of the health 
programme. Access to primary healthcare was still not equal as the differing conditions 
between the public and private sector, and between urban and rural environments, 
had not been addressed sufficiently via the indicators in the BS programme. 

77 There was not sufficient emphasis on improving the skills of healthcare workers 
or attracting more medical students in the health sector. Furthermore, the specific 
objective of setting up an integrated, accessible electronic healthcare information 
system had not been achieved. BS can better address the main root causes (i.e. ratio of 
medical staff per inhabitant and disparities between urban and rural environments) in 
the long term, whereas its short term impact will remain limited. 

Social Protection 

78 EU support had prompted reforms in the social protection sector, but, given the 
early stage of the BS programme it was too early to see an overall impact. The BS led 
to the formulation of a single sector policy on social protection. However, policy 
implementation was affected by legislative delays. 

79 A positive effect of the BS programme is that the introduction of individual social 
security numbers will be linked to an impact evaluation concerning the Tayssir23, 
Régime d’assistance Médicale and DAAM24 programmes. Thanks to this individual 
social security number, only eligible beneficiaries will benefit from these programmes, 
which will have a significant effect on programme costs. In addition, the social security 
number will be the starting point for all social services. In the near future, an anti-fraud 
component will be added to the individual social security number (via technical 
assistance provided by the EU). 

23  National programme for learning support. 

24  National programme for direct support to widows with children. 

 
                                                      
34 

Justice 

80 The Moroccan government had already initiated reforms in 2011, but given the 
complexity of these reforms, implementation was slow, especially for the penal code, 
which has been under parliament scrutiny for over two years. The reforms are 
however particularly important as regards the protection of human rights (detention 
conditions, etc.). According to Freedom House25 reports26, the justice sector is not yet 
considered independent. 

81 The International Commission of Jurists pointed out in one of its reports27 that 
investigative judges and prosecutors routinely disregard provisions of the Code of 
Criminal Procedure that provide for pre-trial detention to be used only in exceptional 
cases. In 2017, 42 % of prisoners were held under preventive detention. It also 
confirms the reports by Freedom House, stating that police custody procedures fail to 
comply with Morocco’s obligations under international law. 

82 Overall, there had been limited progress towards the achievement of the 
objectives of the BS programme: an independent justice sector, improved access to 
rights and justice, increased judicial protection of rights and freedoms and an increase 
in the effectiveness and efficiency of the justice sector. 

PACC 

83 In general, Morocco’s competitiveness was improving, with an increase in 
exports, GDP growth, an increase in foreign direct investment and a reduction in the 
current account balance deficit. Morocco had also risen 27 places in the World Bank’s 
‘Doing Business’ index between 2014 and 2019 (see Annex VII). Box 4 shows a positive 
achievement linked to the PACC programme. 

25  Freedom House is a non-governmental organisation that conducts research and provides 

advocacy regarding democracy, political freedom and human rights. 

26  E.g., https://freedomhouse.org/report/freedom-world/2018/morocco. 

27  International Commission of Jurists, ‘Reform the criminal justice system in Morocco: 

strengthen pre-trial rights, guarantees and procedures’ (April 2017). 

 
                                                      
35 

Box 4 

PACC: Promoting paperless procedures 

Morocco’s aim is to achieve a paperless trade system by 2021. A solely digital supply 
chain will make stakeholder procedures clearer, reducing time and costs. 

o 

The PACC programme is supporting the digitalisation of trade procedures 
via six indicators and the reform process. 

o  Online communication and digital document exchange have contributed to 
customs efficiency. Since 1 January 2019, the customs clearance system has 
been entirely paperless.  

o 

In the past year, Morocco has moved up nine places in the World Bank’s 
‘Doing Business’ index. 

84 There was also a strong political will to implement the industrial acceleration 
plan28. According to the Organisation for Economic Cooperation and Development, 
despite the high number of reforms and the support for start-up and innovation, more 
international companies than SMEs had been set up in Morocco. 

85 The informal sector is extensive in Morocco (around 2.38 million business 
units29). Consequently, even if the PACC were to formalise 45 000, this would not be 
significant. Nor is there any guarantee that ‘auto-entrepreneurs’ officially register their 
activities after obtaining the relevant card (see paragraph 59, point (a)). PACC support 
is limited to 250 SMEs, whereas there are about 735 000 SMEs in Morocco. 

86 In addition, only 100 export companies with a turnover below 5 million dirham 
(approximatively €460 000) received support. The current ceiling (5 million dirham) 
meant that 4 260 companies were potentially eligible (i.e. 69 % of the export 
companies). As the goal was to support smaller companies and funds allowed to 
support only 100 companies, it would have been sensible to set a lower ceiling. 

28  It is one of the Moroccan Government’s major strategies aimed at (i) increasing the number 
of jobs in the industrial sector, (ii) changing the structure of the Moroccan economy by 
increasing the share of industry in the GDP, (iii) increasing exports of industrial products, 
(iv) increasing foreign direct investments in industry and (v) improving the productivity of 
the sector. 

29  Based on a survey by the General Confederation of Companies in Morocco in 2014. 

 
                                                      
36 

Acknowledgement of EU support not sufficiently visible 

87 Visibility of the EU’s financial cooperation, in particular as regards the results 
achieved, was insufficient. For example, no joint press releases were issued and there 
were no signs acknowledging EU support. While the political dialogue was suspended, 
the Ministry of Foreign Affairs had asked the other ministries not to communicate 
openly about any EU support received. 

88 The social protection programme had a condition in the financing agreement 
relating to communication and visibility. The health programme had a specific budget 
line dedicated to visibility. However, events in the health sector were only organised as 
from 2019. An additional indicator, ‘Reinforce communication on the reform of the 
justice sector and the visibility of EU support’, had been added to the justice 
programme via an addendum on 20 December 2018, with a deadline for achievement 
of 31 December 2018. However, the conferences on the reform of the justice sector 
had already been organised before the addendum was signed, and it was mainly the 
Ministry of Justice that benefited from the increased visibility. 

89 The PACC financing agreement included a communication and visibility condition. 
The ministry was required to draft and submit a communication plan as a condition for 
disbursement of the first variable tranche. The ministry also had to provide a report on 
the implementation of the communication plan before or upon submitting its request 
for disbursement of the next variable tranche. The ministry had provided a plan, which 
was approved by the Commission, but none of the proposed actions was implemented 
by the end of December 2018. This did not entail any financial consequences for the 
ministries. 

90 The EU logo did not appear on beneficiary websites for the programmes audited. 
Consequently, the visibility of EU support to Morocco did not reflect its presence as 
one of the biggest donors. 

Limited progress on key challenges 

91 We examined whether the BS programmes made a positive contribution to cross-
cutting issues and regional disparities. 

 
37 

There is evidence that poverty reduced but not social disparities  

92 The poverty level30 in Morocco had decreased significantly since 2001 (see 
Figure 11), although no data was available beyond 2014. Despite this reduction, there 
was no evidence that social disparities had improved, neither at national, urban or 
rural level. 

Figure 11 – Evolution of poverty level in Morocco during 2001-2014 (in %) 

30

25

20

15

10

5

0

25.1

14.4

9.5

15.3

8.9

4.8

7.6

4.9

1.6

National

Urban

Rural

2001

2007

2014

Source: World Bank. 

93 A comparison of the Gini coefficient31 (2010-2017) for Morocco and all other 
middle-income countries for which data was available, as well as other recent studies, 
such as the one carried out by the Organisation for Economic Cooperation and 
Development and the African Union32 indicates that social disparities in Morocco 
remained high. However, Morocco’s performance was average compared to other 
middle-income countries (see Figure 12). 

30  All individuals whose consumption expenditure is below the national poverty line ($2.15 

per day) are considered poor (World Bank country diagnostics June 2018). 

31  The Gini coefficient is used to measure income distribution across percentiles in a 

population. The higher the Gini coefficient, the greater the country’s inequality, with high-
income individuals receiving much larger percentages of the total income of the population 
than the average percentage per capita. 

32  African Development Dynamics 2018 (11 July 2018). 

 
 
 
                                                      
Figure 12 – Gini coefficient - Morocco and middle-income countries 

38 

Average Gini coefficient 2010-2017 in middle-income countries
(Gini coefficient:  100 = max. inequality)

Egypt, Arab Rep.; 31.0

Algeria; 27.6

Tunisia;  34.3

Morocco;  39.5

Gini

70.0

60.0

50.0

40.0

30.0

20.0

10.0

0.0

MIC- Countries

Source: World Bank. 

Limited improvement in gender equality and human rights 

94 Although Morocco has made advancements in women’s rights over the last two 
decades, it still ranks 137th out of 149 countries according to the 2018 World 
Economic Forum’s Global Gender Gap Report. Morocco’s 2011 constitutional reforms 
included several proposals to increase women’s political and economic participation. 
Despite these pronouncements, women remain underrepresented in managerial 
positions, leave school at younger ages than male students, and are still an 
underutilized economic resource in Morocco. 

 
 
39 

95 EU support targeted cross-cutting issues such as gender and human rights as 
follows: 

(a)  The EU action plan (advanced status) had a strong focus on gender equality, as did 
the SSF. The Commission monitored the expected results through the annual 
reporting exercise on the Gender Action Plan. 

(b)  Morocco is the only country that benefits form a dedicated BS programme on 

gender equality. Despite the mixed results of the 2012-2016 BS programme, with 
only 48 % disbursed, a new programme was launched for 2018-2020. The 
evaluation of the first gender-related BS programme revealed that, due to the 
lack of results indicators, the gender programme had  a limited effect on other 
sectors. In addition, gender mainstreaming could have been carried out more 
effectively and gender-based economic disparities had not decreased. 

(c)  Gender had been taken into account in BS for social protection (two out of 
15 indicators), justice (two out of 10 indicators) and health (three out of 
18 indicators). For the PACC programme, the EU Delegation had not managed to 
have it included, as the ministry was against including it. 

(d)  Human rights had only been specifically addressed in the justice sector (three out 

of 10 indicators), but none of these targets had been achieved so far. 

96 Despite this targeting, no improvement could be observed for the period under 
review. Moreover, the EU’s assessment of fundamental rights indicated that the 
situation had not improved since 2014. 

97 The limited progress in gender equality is confirmed by data from the United 
Nations Development Programme with regard to the gender inequality index33 and the 
human development index (HDI)34 for men and women (see Figure 13). 

33  A composite index reflecting inequality between women and men in three dimensions of 

achievement: reproductive health, empowerment and the labour market; 100 % = 
inequality and 0 % = equality. 

34  A composite index measuring average achievement in three basic dimensions of human 
development — a long and healthy life, knowledge and a decent standard of living. 

 
                                                      
40 

Figure 13 – Gender inequality in Morocco 

UNDP Gender inequality and HDI index

0.8

0.7

0.6

0.5

0.4

0.3

0.2

0.1

0.0

2014

2015

2016

2017

Gender inequality

HDI female

HDI male

Source: United Nations Development Programme 

98 Freedom House also confirms the negative situation in Morocco with regard to 
human rights (see Figure 14). The main issues they mention are the restrictive press 
laws, lack of internet freedom, failure to allow free assembly, and the lack of 
independence of the justice sector. In 2018, the score for Morocco’s civil liberties 
declined due to harsh state responses to major demonstrations throughout the year. 
Morocco is considered ‘partially free’ (see Figure 15). 

Figure 14 – Freedom House Index in Morocco 

Political Rights
Civil Liberties
Freedom rating
Political rights; Civil Liberties; Freedom Rating: 1 = best / 7 = worst

2015
5
4
4.5

2016
5
4
4.5

2014
5
4
4.5

2017
5
4
4.5

2018
5
5
5.0

Source: Freedom House. 

 
 
 
 
Figure 15 – Human Rights in Morocco 

Aggregate score Human Rights 2014-2018

41 

43

42

42

41

41

40

40

39

39

38

38

2014

2015

2016

2017

2018

Aggregate score: 0 = least free / 100 = most free 

Source: Freedom House. 

 
 
 
 
42 

Conclusions and recommendations 

99 The audit examined the effectiveness of EU BS to priority sectors in Morocco. 
Based on an appropriate risk analysis and needs assessment, the Commission 
considered BS to be the right choice of aid delivery instrument. However, we 
concluded that its added value and ability to support reforms was limited due to sub-
optimal focus, weak implementation and insufficient monitoring.The main weaknesses 
related to indicator design and results assessment. Not all expected outputs were 
delivered, nor were disbursements always based on the achievement of targets. Donor 
coordination was uneven. Moreover, there was no evidence that BS had supported the 
effective implementation of reforms. 

100 The Commission addressed needs identified in national and EU strategies. 
However, we found that the three priority sectors were too broadly defined, meaning 
BS was distributed across too many areas. This could weaken its impact (see 
paragraphs 25 and 26). The Commission had not used a transparent method to 
allocate amounts to sectoral BS programmes (see paragraph 27). The Commission had 
not used the political standstill to reassess its operational priorities for Morocco and 
develop a clear strategy (see paragraphs 32 and 33). With regard to donor 
coordination, Member States were keen to maintain their own visibility instead of 
aligning their objectives with those of the EU (see paragraph 35). Furthermore, very 
few joint indicators, missions or evaluations were in place between the EU and other 
donors for the sectors audited (see paragraph 38). 

Recommendation 1 – Strengthen the focus of EU budget 
support in Morocco 

For the next single support framework, the Commission and the EEAS should: 

(i) 

(ii) 

reduce the number of sectors and prioritise them in order to take into account 
the objective of maximising the impact of EU assistance; 

apply a more transparent and better documented method to allocate amounts 
to sectoral BS programmes; 

(iii) 

reinforce joint programming with Member States to increase aid coordination 
and effectiveness. 

Timeframe: June 2021 

 
43 

101 The Commission had not developed fully-fledged action plans with baseline 
data, results indicators and pre-defined targets. We noted weaknesses in the selection 
and use of indicators, as well as the use of output instead of outcome/impact 
indicators and outdated or missing baselines (see paragraphs 47 and 48). 

Recommendation 2 – Improve design of targets and 
performance indicators 

The Commission and the EEAS should strengthen its use of conditionality by: 

(i) 

defining specific and relevant performance indicators with ambitious targets to 
support reforms and demonstrate progress/results; 

(ii)  making greater use of outcome-oriented indicators; 

(iii) 

setting clearer, more relevant and more up-to-date baselines for all indicators. 

Timeframe: December 2020 

102 The EU Delegation had not formalised policy dialogue strategies with clear 
objectives, nor were the meetings with the ministries systematically documented. 
Contacts between the ministries and the EU Delegation did not always take place at 
the appropriate level (see paragraphs 54–56). 

Recommendation 3 – Strengthen policy dialogue 

The Commission and the EEAS should strengthen their policy dialogue framework by 
adopting a policy dialogue strategy for all areas in which the EU provides support. This 
requires: 

(i) 

a clear and appropriate definition of the objectives and expected results of the 
dialogue;  

(ii)  minutes should be drafted; 

(iii)  assessments of the achievements of the policy dialogue strategy.  

Timeframe: December 2020 

 
44 

103 The Commission’s assessment of the achievement of indicator-related targets 
was hampered by weaknesses such as payments made without verifying the reliability 
of the data, inappropriate calculations, payments made when targets had not been 
achieved and disbursements made despite a lack of progress. In addition, € 14.64 
million was carried over to the next financial year, although the conditions stipulated 
in the financing agreement were not met (see paragraphs 58–61). 

Recommendation 4 – Enhance disbursement verification 
procedures 

The Commission should enhance its payment verification procedures by: 

(i)  applying appropriate calculation methods (where relevant); 

(ii)  disbursing funds only when there is reliable evidence that the target has actually 

been achieved; 

(iii)  carrying over targets and related payments to another period only when 

beneficiaries have provided justification that the delays were due to external 
factors. 

Timeframe: December 2020 

104 We found weaknesses in the Commission’s monitoring of BS operations. For 
example, the Commission monitored programmes mainly when making payments 
related to the achievement of indicators, which was often too late to allow corrections 
to be made when there were delays (see paragraphs 47 and 62–64). 

 
45 

Recommendation 5 – Improve monitoring procedures 

The Commission should improve the monitoring of its BS operations by: 

(i)  making greater use of field visits when monitoring programmes; 

(ii)  strengthening assessments of sectoral strategies and monitoring their 

implementation using the indicators of the sectoral strategies; 

(iii)  formally following up recommendations made by external experts and 

implementing those that are considered relevant. 

Timeframe: December 2020 

105 Less than half of the BS targets had been achieved (see paragraphs 66–71). 
Although progress had been made towards the objectives of the BS programmes in the 
sectors audited, it was limited (see paragraphs 72–86). The implementation of 
ministries’ budgets had improved, but significant amounts remained to be spent. This 
puts the added value of BS into question (see paragraphs 73–74). 

106 Visibility of EU support in Morocco was insufficient. The social protection BS 
programme had a general condition relating to visibility. The required action plan 
stipulated in the PACC financing agreement had been drafted, but not implemented. In 
the justice sector, an indicator relating to visibility had been added at a later stage, but 
targets had already been achieved when the addendum was signed. In the health 
programme, a budget was provided for visibility, but events only took place as from 
2019 (see paragraphs 87–90). 

Recommendation 6 – Increase visibility of EU support 

The Commission and the EEAS should stipulate visibility conditions or indicators in its 
BS programmes in order to ensure that the EU support provided in Morocco is 
publicised. This should be a mandatory condition for disbursement in the financing 
agreement. 

Timeframe: June 2020 

 
107 EU support targeted cross-cutting issues such as gender and human rights. 
Despite this targeting, only limited improvement could be observed for the period 
under review. (see paragraphs 94-98). 

46 

This Report was adopted by the Court of Auditors in Luxembourg at its meeting of 
14 November 2019. 

For the Court of Auditors 

Klaus-Heiner Lehne 
President 

 
 
 
 
 
Annexes 

Annex I – Important EU-Morocco cooperation phases 

47 

Source: European Court of Auditors. 

 
 
48 

Annex II – Budget support programme decisions, contracts and payments (2014 to 2018) 

[European Neighbourhood Instrument – budget line 22 04] 

Sector and Decision year

Programme

Allocated 
(million euro)

Contracted 
(million euro)

Paid    
(million euro)

2014
Health  
Justice
General budget support-related aid
2015
Health  
Justice
Public sector policy 
PACC
PACC
Vocational Training
2016
Public sector policy 
Social Protection
Vocational Training
2017
Basic life skills for youth and adults
Forestry policy 
Social Protection
Women's equality organisations and institutions
General budget support-related aid
2018
Basic life skills for youth and adults
Public sector policy 
Justice
Rural development
General budget support-related aid

Source: European Court of Auditors. 

Programme d'appui sectoriel à la réforme de système de santé
Programme d'appui sectoriel à la réforme de la justice
Reussir le Statut Avancé (phase II) top-up Dec 2013/24-875

Programme d'appui sectoriel à la réforme de système de santé II
Programme d'appui à la réforme du secteur de la Justice 
Financement additionnel 2015 au programme ''Hakama'' Gouvernance  
Financement additionnel n°1 (2015) au Programme Croissance Compétitivité
Programme d'apppui à la croissance et la compétitivité au Maroc - PACC
Formation professionnelle: développement du capital humain au Maroc

Programme d'appui aux politiques migratoires du Maroc 
Programme d'appui à la Protection sociale au Maroc
Formation professionnelle: développement du capital humain au Maroc 

Programme d'appui à la stratégie nationale d'alphabétisation au Maroc - 3ème phase
Forestry policy and administrative management Programme additionnel au PAPFM
Multisector aid for basic social services Top up au programme d'appui à la Protection sociale
Women's equality organisations and institutions Egalité- Moussawat
Top-up au Programme Réussir le Statut Avancé phase II (RSA II)  

Programme d'appui à la Jeunesse au Maroc
Programme d'appui aux réformes de gouvernance publique - HAKAMA 2
Top up convention justice 
Programme d'Appui au Développement Territorial au Maroc (PADT)
Top up au programme ''Réussir le Statut Avancé II'' (RSA II)
Total
Covered in the audit scope

170.00
90.00
70.00
10.00
175.00
10.00
5.50
9.50
5.00
100.00
45.00
150.00
35.00
100.00
15.00
116.20
50.00
12.50
9.20
35.00
9.50
199.20
35.00
62.00
2.20
50.00
50.00
810.40
391.90
48.36 %

163.75
89.73
69.85
4.18
165.60
8.80
5.50
5.24
5.00
96.06
45.00
137.51
33.00
91.41
13.10
45.00
45.00
0.00
0.00
0.00
0.00
50.11
0.00
0.00
0.11
0.00
50.00
561.98
366.46
65.21 %

73.26
47.93
24.25
1.08
69.19
0.26
0.00
1.32
5.00
47.84
14.77
33.23
7.85
22.51
2.88
0.00
0.00
0.00
0.00
0.00
0.00
30.00
0.00
0.00
0.00
0.00
30.00
205.69
147.78
71.85 %

 
 
49 

Annex III – Funding by other EU instruments (2014-2018) 

Domain of EU support (contract portfolio 2014 – 2018)

Contracted amount 
(euro)

1) NIF – Neighbourhood Investment Facility

2) EUTF – EU Trust Fund projects for Morocco

3) EIDHR – European Instrument for Democracy and Human Rights

4) ENI Global allocation for Morocco

5) CSO – GENR- LA – Civil Society, Gender and Local authorities

6) HUM – Human development

Source: European Commission. 

Total

199 966 000

40 800 000

4 750 288

4 905 834

3 732 747

1 586 000

255 740 869

 
 
Annex IV – Overview of contracts/projects audited 

Sector

Health

Type

BS

Contrat pour le versement des différentes tranches de l'appui 
budgétaire du programme PASS II

Contract title

Health

Project

Assistance Technique pour l'accompagnement du programme 
d'Appui à la réforme du secteur de la santé-Phase II (PASS II)

Health

Project

Projet d’appui à la réforme des Soins de Santé Primaires-Contrat 
PAGODA UE/OMS

Health

Project

Appui au développement des capacités de l'Ecole Nationale de 
Santé Publique (ENSP) pour un meilleur accompagnement des 
réformes de santé et des gestionnaires des structures de soins.

Health - Total
Social Protection

BS

Contrat pour le versement des 4 tranches de l'appui budgétaire du 
programme d'appui à la Protection Sociale

Social Protection

Project

Contrat PAGODA UE/UNICEF - Programme d'appui à une protection 
sociale intégrée et sensible aux enfants au Maroc

Social Protection - Total
Justice

BS

Contrat pour le versement des différentes tranches de l'appui 
budgétaire du programme Justice

Justice

Project

Assistance technique pour le programme d'appui sectoriel à la 
réforme de la justice au Maroc

Justice

Project

Accès des enfants à une justice adaptée et respectueuse de leurs 
droits - projet UNICEF

Justice

Project

Amélioration du fonctionnement de la justice au Maroc sur la base 
des outils dévelopés par la Commission européenne pour 
l’efficacité de la justice (CEPEJ)”

Justice

Project

Appui pour la réforme institutionnelle et le renforcement des 
capacités de l’Institut Supérieur de la Magistrature

Justice - Total
PACC

BS

Contrat d'appui budgétaire pour l'appui à la croissance verte et à la 
compétitivité du Maroc.

PACC

PACC

Project

Project

Subvention à la GIZ pour l'opérationnalisation de la stratégie des 
Très Petites, Petites et Moyennes entreprises au Maroc

Organisation du séminaire EIP (European External Plan of 
Investment) au Maroc

50 

Committed amount
million €
94.00

Paid amount
million €
46.57

3.30

0.80

0.03

98.13
90.00

1.10

91.10
65.50

3.29

2.80

1.60

1.20

74.39
99.00

1.80

0.02

1.15

0.16

0.01

47.89
22.00

0.44

22.44
19.60

0.64

1.74

1.58

0.59

24.14
51.80

0.88

0.02

PACC - TOTAL

Source: ABAC. 

100.82

52.70

 
 
51 

Annex V – Budget support programme objectives 

BS Sector 

Overall objective 

Specific Objectives 

Health 

Increase equal access to qualitative 
healthcare. 

Social 
Protection 

Contribute to reducing inequality, 
improving social cohesion and 
tangibly improving human 
development in Moroccan society 
by promoting equal access to social 
and basic services. 

Justice 

PACC 

Reinforce the rule of law through 
an accessible, independent judicial 
system that meets international 
standards. 

Support the competitiveness and 
growth of Morocco, with the 
ultimate aim of supporting the 
country in its ambition of 
sustainable development and the 
creation of decent jobs. 

Source: European Commission. 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

equal access to primary healthcare; 

improved management and skills of healthcare personnel; 

improved governance; and 

development of an integrated, computerized, accessible healthcare information system. 

implementation of an integrated, unified social protection policy;  

extension of basic medical coverage to all socio-professional categories and improved coverage of 

disadvantaged populations; 

development of social assistance by better targeting populations in precarious situations; and  

development of social services through accredited social protection centres.  

independent justice sector;  

improved access to rights and justice;  

increased judicial protection of rights and liberties; and 

increased effectiveness and efficiency of justice. 

increased competitiveness through reinforced implementation of national industrial policy; 

increased Moroccan export potential; and 

support for transition towards a greener economy and industry. 

 
Annex VI – Variable tranche disbursement issues 

Sector
Health

Tranche
1st variable

Indicator
I.1 Number of contacts of curative medical consultations 
by the rural primary health care system per capita per 
year

Health

1st variable

I.11 Number of general practitioners in
post in the primary health centers "ESSP" in rural areas

Health

1st variable

I.7 Number of diabetic patients monitored in public health 
facilities in rural areas

Issue
Overestimation of result due to 
inappropriate calculation 
method
Payment for 'results', although 
the situation worsened
Outdated baseline

Payment for 'results', although 
the situation worsened
Overestimation of result due to 
inappropriate calculation 
method
Overestimation of result due to 
inappropriate calculation 
method
No impact on the specific 
objective

Health

2nd variable

I.7 Number of diabetic patients monitored in public health 
facilities in rural areas

No impact on the specific 
objective

Health

1st variable

I.8 Number of hypertensive patients in public health 
facilities in rural areas

No impact on the specific 
objective

Health

2nd variable

I.8 Number of hypertensive patients in public health 
facilities in rural areas

No impact on the specific 
objective

Health

2nd variable

I.6 Availability of essential drugs in public primary health 
structures (ESSPs)

Health

Health

1st variable

1st variable

I.9 Existence and implementation of a national health 
plan for the disabled

I.3 Proportion of births (assisted by qualified personnel) in 
rural areas in public health structures

No baseline
Payment for 'results', although 
the situation worsened

Already achieved before signing 
the financing agreement
Outdated baseline
Outdated baseline
Payment for 'results', although 
the situation worsened

52 

Regular payment. 
However, not 
contributing to the 
budget support 
programme 
objective

Weak control 
procedures

Facts
Baseline (2012): 36 ; (2014) 38  - Target (2015): 40 - Achievement: 37

Financial Impact 
(incorrectly paid)*
2 394 000 €

(1) Outdated baseline, as data from 2012 were used.
(2) Inappropriate calculation method. Progress should be measured (37-36) / (40-36) = 25 %. 
NB.: With the method of the EC (37/40 = 93 %), "progress" would be paid even if the baseline 
stays the same. (36/40 = 90 %). 
(3) Performance: The balance is declining since the BS started
Baseline: 1066  - Target: 1300 - Achievement: 1057

1 197 000 €

(1) There is no progress, the balance is declining.
(2) Inappropriate calculation method by the Commission (1057/1300 = 81 % of progress)

Baseline: 183 962 (2013) - Target: 225 000 - Achievement: 215 464
(1) The progress (2015) is overestimated by EC using an inappropriate calculation method:  
(215.464/225.000) = 96% leading to a 100% paiment. However, the  progress is at best (215094-
183 962)/(225 000-183 962)= 77%. This should have led to a 50% paiment only. (Starting point of 
measuring progres is the baseline)
(2) Using the updated baseline (2014) the real progress is in reality only: (215 464 - 191 250) / (225 
000 - 191 250)  =71 % (Leading to the same result: a 50 % payment)
(3) The objective was to improve the urban/rural disparity. However, the indicator does not 
measure this and in addition there is no progress towards this objective. The expert report 
states: "The proportion .. (urban and  rural)...remained stable".  
Target: 235 000 - Achievement: 235 094
The specific objective was to improve the urban/rural disparity. However, the indicator does not 
measure this and there is no progress towards this objective. The situation worsened despite a 
nominal increase in figures. The expert report states: "The majority of this increase stems from 
the urban area...".  
Target: 300.000 - Achievement: 328.579
The objective was to improve the urban/rural disparity . However, the indicator does not 
measure this and there is no progress towards this objective. The situation worsened (despite a 
nominal increase in figures). The expert report states: "..the relative proportion of the rural area 
shows a small decrease .."
Target: 250.000 - Achievement: 281.677
The objective was to improve the urban/rural disparity.  However, the indicator does not 
measure this and there is no progress towards this objective. The situation worsened (despite a 
nominal increase in figures). The expert report states: "The increase observed in 2016 stems for 
56,6% out of the urban area..."
Declining balance since start of the programme: Wheras availability was 82.71 % in 2016, for 2017 
it is 79.71 %.

The plan was published in October 2015, after a consultation process starting already back in 
2014. The BS was signed in November 2015.

Baseline (2012): 71 %; (2014): 86 % - Target (2015): 75 % - Achievement: 85.6 %
No real progress: Declining balance in 2015 compared to 2014 (outdated baseline/target)

1 197 000 €

1 197 000 €

3 291 667 €

2 394 000 €

3 291 667 €

1 645 833 €

2 394 000 €

2 394 000 €

3 291 667 €

4 788 000 €

19 899 834 €

Health

2nd variable

I.3 Proportion of births (assisted by qualified personnel) in 
rural areas in public health structures

Outdated baseline
Payment for 'results', although 
the situation worsened

Baseline (2012): 71 %; (2014): 86 % - Target (2015): 75 %; (2016)  - Achievement (2015): 85.6 %; 
(2016): 85 %
No real progress: declining balance since BS start. 

 
  
 
Sector
Social Protection

Tranche
1st variable

Indicator
1.2. There is a three year budget programming for the 
social sectors

Issue
Not achieved / Inappropriate 
source of verification

Facts
A three-year budgetary plan for the social services sector was required for the period 2017-
2020 in order for the indicator to be achieved, but the EU Delegation was satisfied with 
‘sufficient progress in investments in the social sector’. The EU Delegation based its 
opinion on historical figures of 2017 and 2018 and the forecast of 2019.The Ministry of 
Economy and Finance acknowledged that no such plan was in place. Furthermore, the 
ministry requested technical assistance, as it did not have the necessary expertise in place 
to develop this type of three-year budgetary plan for the social sector. 

53 

Regular payment. 
However, not 
contributing to the 
budget support 
programme 
objective

Weak control 
procedures

Financial Impact 
(incorrectly paid)
2 000 000 €

Social Protection

1st variable

2.4. Global medical coverage of the population

Inappropriate source of 
verification / Contradiction 
with other sources of 
verification (achievement 
cannot be guaranteed)

The ANAM provided an Excel table with data by population category of people insured. The 
data could not be traced back to their annual report, nor did the EU Delegation crosscheck 
the data with other sources. In addition, the 2017 data was compared to the 2014 
population (which was lower than the 2017 population) to calculate coverage of the 
Moroccan population. According to reports by the National Statistics Office and ‘Office 
National du Développement Humain’, the total medical coverage was only 46.6 % and 53.8 
% respectively in 2017, which is even lower than the baseline situation.

The data of ANAM was based on cards distributed (RAMED), and the results of the National 
Statistics Office given orally by the sample of households when asked whether they had a 
RAMED card. Another study of the National Statistics Office found that only 30 % of 
cardholders had the actual right to have a RAMED card. The other cardholders had 
sufficient income to cover a regular medical insurance. As such, the ANAM figurescannot 
really be considered reliable.

Justice

1st variable

3: Rationalisation of the judicial map

Justice

1st variable

4: Availability of judicial assistance

Justice

1st variable

9: Digitalisation of the jurisdictions

Not achieved/Inappropriate 
source of verification

Target b of indicator 3 was not achieved.  A total of 72 judicial centres were supposed to 
be operational by end of 2017. 64 had already been active before and 8 judicial centers 
had to be activated. Only 1 out of those 8 was activated (Tarfaya) by December 2018, i.e. 
one year after the disbursement was decided.

2 000 000 €

Not achieved/Inappropriate 
source of verification

The source of verification used (RAMED) is not an appropriate means to measure the 
achievement of this indicator and was not provided as source of verification in the 
financing agreement. In addition, the RAMED card cannot be considered as  a reliable 
source, given the focus on the improvement of its reliability in the budget support 
programme on social protection.

Inappropriate source of 
verification

The verification source "annual report of the Ministry of Justice" was not provided. A 
verification mission was carried out in January 2018, whereas the payment already took 
place in December 2017.

2 000 000 €

2 000 000 €
800 000 €

1 280 000 €

1 600 000 €

3 680 000 €

 
 
Sector
PACC

Tranche
1st variable

Indicator
T1D1: Number of registered auto-entrepreneurs and 
cardholders

Issue
Inappropriate source of 
verification

54 

Regular payment. 
However, not 
contributing to the 
budget support 
programme 
objective

Financial Impact 
(incorrectly paid)

Facts
The number of auto-entrepreneurs (indicators T1D1 to T1D4) is based on reports by Maroc 
PME. The database is managed by Maroc Poste; no checks were carried out by the EU 
Delegation or the experts to check the accuracy of the information. The number of cardholders 
does not guarantee that these people actually have a formal activity as auto-entrepreneurs. A 
sample of ‘auto-entrepreneurs’ tested during our visit to Morocco confirmed that the database 
was not accurate. In addition, there is a significant discrepancy between the number of 
cardholders and those declaring taxes.
Studies were launched for economic activity zones and not for integrated industrial parks, as 
provided for in the industrial acceleration plan.

Weak control 
procedures
2 400 000 €

2 400 000 €

2 400 000 €

2 400 000 €

9 600 000 €
15 280 000 €

PACC

PACC

PACC

1st variable

T1D3: Two feasibility studies for industrial parks

Inappropriate source of 
verification / Not achieved

1st variable

2nd variable

T1D6: Evaluation of the national plan of the 
simplification of procedures
T2D1: Number of registered auto-entrepreneurs and 
cardholders

Not achieved

Inappropriate source of 
verification

The evaluation was not presented in due time (only 1 year later). Consequently, T1D5 could not 
be verified either.
See T1D1

* On 31st May 2019, the Commission informed the Ministry of Economy and Finance that the amounts related to indicators one and eleven are going to be offset against the payment of the next variable tranche.
Source: European Court of Auditors. 

6 788 000 €

19 899 834 €

 
 
 
 
Annex VII – Evolution of key indicators 

Population

2014
33.85 million

2018
35.22 million

Source: Ministry  of Economy and  Finance

Activity rates by gender

2014

25.2%

72.4%

•

•

2018
22.2 %

70.9 %

•

•

Source: Ministry  of Economy and  Finance

Gender  inequality  index
2017
0.482
Ranks 119 out  of 160

2013
0.525
Ranks 131 out  of 187

Source: United  Nations  Development  Programme

%
2014
+2.6 %

GDP growth

2016
+1.2 %

2018
+3.5 %

Source: Ministry of Economy and Finance

Trade

2016

2018

Imports
409 billion  Dirham

Imports
479 billion  Dirham

Exports
224 billion  Dirham

Exports
274 billion  Dirham

Foreign Direct 
Investment net 
inflows
21.2 billion  Dirham

Foreign Direct 
Investment net 
inflows
33.5 billion  Dirham

Source: Haut Commissariat  au Plan  and  Office des  changes

Current  account  balance  (% of GDP)
2016
-4.2 %

2014
-5.7 %

2017
-3.6 %

Share of the industry in GDP

Human development  index

2014
14%

2017
15.7 %

Source: Plan d’Accélération Industrielle and Haut Commissariat 
au Plan

2014
126 out  of 188

2018
123 out  of 189

Source: United  Nations  Development  Programme

Industrial exports

2014
188 billion  Dirham

2017
228 billion 
Dirham

10O: inequality

O: equality

Gini index

2014
39.5

2018
Not available

Source: Office des Changes

Source: Haut Commissariat  au  Plan

Informal  production  entities

2013
1.68 million

2014
2.38 million

Source: Haut 
Commissariat  au  Plan

Source: Confédération 
Générale des entreprises 
Maroc

2017
Not 
available

Doing Business index
2014
2019
87 out  of 189
60 out  of 190

CNSS

Declared salaries

2013
2.87 million 
Coverage of retired people

2016
3.28 million 

2013
452313

2016
518940

Source: Caisse  Nationale  de Sécurité Sociale

Environmental  performance 
index

2014
81 out  of 178

2018
54 out  of 180

Source: Ministry  of Economy and  Finance and  Office des  changes

Source: World  Bank

Source: Yale  University 

Source: European Court of Auditors. 

55 

Life expectancy at birth

2010
74

2014
75.31

2017
76.1

Source: United  Nations  Development programme

Child  mortality rate

2011
28.8 for 1000 births

2018
18 for 1000 births

Source: Ministry  of Health  and Haut  Commissariat  au  Plan

Freedom house  index

2014
42 out  of 100

2018
39 out  of 100

Source: Freedom house (0=Least  Free, 100=Most Free) 

Rule of law index

2014
0.51

2017
0.51

Source: World Justice project  (1= strongest adherence to rule of law) 

Corruption  perception  index

2014
39 out  of 100

2018
43 out  of 100

Source: Transparency  international  (0=highly    corrupt, 100= very clean) 

 
 
Annex VIII – Budget support contract ratings by sector 

56 

Source: European Court of Auditors. 

 
 
 
57 

Acronyms and abbreviations 

ADB 

BS 

CJEU 

EEAS 

ENI 

ENP 

EU 

PACC 

SME 

SSF 

WB 

African Development Bank 

Budget Support 

Court of Justice of the European Union 

European External Action Service 

European Neighbourhood Instrument 

European Neighbourhood Policy 

European Union 

Programme d’appui à la croissance verte et la compétitivité du 
Maroc 

Small- and Medium-sized Enterprise 

Single Support Framework 

World Bank 

 
 
REPLIES OF THE COMMISSION AND OF THE EUROPEAN EXTERNAL ACTION 
SERVICE TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS 

“EU SUPPORT TO MOROCCO: LIMITED RESULTS SO FAR” 

EXECUTIVE SUMMARY 

I. Morocco is a key partner for the EU, with whom we share borders, values and aspirations. 
Since the adoption of its new Constitution in 2011, Morocco has embarked on an ambitious 
reform  process  that  aims  to  bring  greater  freedom,  democracy  and  prosperity  to  Moroccan 
citizens.  As  part  of  its  Neighbourhood  Policy,  the  EU  stands  firmly  behind  Morocco  as  it 
works towards these goals. 

Despite  the  challenging  political  climate  in  which  EU/Morocco  relations  have  operated  in 
recent years, EU cooperation has contributed to Morocco’s considerable economic, social and 
institutional progress. 

For example: 

-  Maternal mortality in Morocco decreased by 35% between 2012 and 2016, and access to 
health centres for the rural  population has increased. Access to medicines has improved 
significantly  with  39%  increase  in  the  sale  of  generic  medicines.  The  EU  has  been 
supporting Health sector reforms since 2009. 

-  Morocco's  ranking  in  the  World  Bank  Doing  Business  Report  has  gone  from  128th  in 
2010  to  60th  in  2018.  The  EU  has  been  supporting  Morocco’s  efforts  to  improve  their 
business climate since 2009. 

-  Through support to the Justice sector, the EU has witnessed the establishment of the High 
Judicial Council, a Constitutional Authority, entrusted with preserving the independence 
of the judiciary and magistrates. This is a major achievement in the institutional context 
of North Africa. 

-  EU  support  in  the  domain  of  social  protection  has  accompanied  reforms  and  led  to  the 
formulation of a single sector policy. An individual social security number is now being 
introduced,  in  line  with  EU’s  policy  recommendations.  This  will  improve  access  for 
vulnerable people, and stimulate efficiencies. 

The  Commission  and  the  EEAS  are  of  the  opinion  that  assessing  the  wide  range  of 
conditionalities and other EU-funded complementary activities, going beyond budget support 
(BS) variable tranche payments, provides a more comprehensive picture of the effectiveness 

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and impact of EU cooperation in Morocco and conveys a more accurate understanding of the 
BS instrument. 

Impact  level  indicators  depend  on  a  variety  of  contributing  factors,  and  take  more  time  to 
change than the time span of BS programmes.  

Finally,  the  Commission  and  the  EEAS  note  that  the  2018  OECD  Peer  Review  on  EU 
Development  Cooperation  states  that  the  use  of  budget  support  enhances  ownership  and 
inclusiveness  in  partner  countries.  Programmes  aligned  with  national  policies  and  delivery 
structures increase domestic accountability and ensure sustainability of reforms. BS thereby 
encourages national capacity development to deliver reforms for lasting impact. In Morocco, 
it  has  provided  significant  leverage  to  engage  with  the  authorities  in  meaningful  policy 
dialogue  for  reform.  The  general  conditions  for  BS  stimulate  transparency,  sound  financial 
management and prudent macroeconomic policies. 

II The figures indicated correspond to all BS contracts and payments in all sectors contracted 
in  2014-2018,  not  only  to  the  4  audited  sectors.    More  importantly,  the  figure  of  payments 
can be misleading as they give the impression that the execution of payment is low compared 
to the amount committed, as the period covered by the audit (2014-2018) does not cover the 
whole period of implementation of BS programmes. 

BS contracts  signed  during the period under review, for all sectors  covered by  BS, totalled 
€562 million  and  payments  €206 million.  Payments  on  several  of  these  BS  contracts  are 
ongoing.  Given  the  large  share  of  recurrent  expenditure  and  the  nature  of  EU  support,  BS 
allocations  should  be  compared  with  the  investment  budget.  Over  the  period  audited,  BS 
represented some 2.0 % of the overall national investment budget.  

III BS programmes are designed according to the BS Guidelines, taking into account country-
specific conditions and with formal, structured monitoring processes. 

The Commission ensures open dialogue and continuous coordination with EU Member States 
through  thematic  groups,  regular  coordination  meetings  and  joint  programming.  However, 
whilst  the  European  Commission  and  the  European  External  Action  Service  make  every 
effort to facilitate donor coordination in partner countries, it is ultimately the responsibility of 
the host government. 

IV The Commission has a clear strategy for its relations with Morocco which is embedded in 
the Single Support Framework (SSF) itself based on the Association Agreement. 

As  policy  dialogue  was  never  suspended  during  the  period  of  difficult  political  relations 
between the EU and Morocco, the Commission considers there were no grounds to develop 
an alternative strategy. 

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Guidance  on  policy  dialogue  in  the  framework  of  BS  as  laid  out  in  the  BS  guidelines  has 
been adhered to.  The outcomes of policy dialogue are and will be an important part of any 
evaluation. Nevertheless, the Commission would like to stress the political sensitivity of the 
reforms and political objectives and therefore maintains that dialogue strategies will continue 
to be formulated protecting the Commission's interests. 

Regarding policy dialogue, it was ensured for the whole period through coordination with the 
Ministry of Economy and Finance (National Coordinator – global dialogue framework); and 
for  specific  projects/programs,  it  is  enshrined  in  the  financing  agreements  through  the 
compulsory steering committees with the MEF and beneficiaries. 

V  The  BS  programmes  audited  have  been  in  place  for  less  than  four  years,  and  the 
Commission  is  of  the  opinion  that  satisfactory  progress  has  been  made.  The  complex  and 
sensitive  nature  of  the  reforms  that  Morocco  is  undertaking  with  EU  support,  and  the 
timescale necessary for their full realisation, need to be taken into account. 

These  programmes  aim  to  support  national  reforms  and  their  indicators  reflect  the  level  of 
ambition of the partner country’s reform agenda. 

Monitoring  procedures  and  the  methodology  for  assessing  results  are  clearly  established  in 
the Guidelines for BS, and have been adhered to. 

VI Over the period audited, some improvements have been noted in the area of Gender and 
Human  Rights.  However,  deep-rooted  sustainable  social  change  is  a  gradual  long  term 
process. Measuring progress in these areas over a short time span by using indicators of long-
term trends cannot give an accurate picture of the situation. Further detailed explanations of 
the  Commission  position  are  given  in  the  comments  to  the  relevant  paragraphs  (see 
Commission replies to paragraphs 96 to 100). 

VII See Commission replies to recommendations. 

INTRODUCTION 

Box 2 - Summary Judgments of the Court of Justice of the European Union (CJEU) 

The Commission notes that: 1) other relevant Court of Justice decisions exist (orders in cases 
T-180/14 and T-275/18), 2) the implication from C-104/16P that a consent is legally required 
is not necessarily following from the Court of Justice’s reasoning on the inapplicability of the 
Association Agreement, 3) the new fisheries agreement was a new agreement and not just a 
revised  agreement  and  4)  following  the  Exchange  of  Letters,  products  originating  from  the 
Western Sahara are treated in  the same way  with regard to  the benefit from  the same tariff 
preferences as products from Morocco, which should not be understood as if they should be 
considered as assimilated.  

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OBSERVATIONS 

21 Anti-corruption is also dealt with through other avenues such as regular policy dialogue, 
twinning, regional programmes, support to civil society and the general eligibility criteria on 
public finance management and transparency.  

23  The  ECA  annual  reports  are  regularly  used  as  a  source  of  information  for  many  of  the 
sectors supported by the Commission whenever relevant. 

26  The  Single  Support  Framework  is  the  implementation  tool  of  the  Action  Plan  of  the 
Advanced  Status.  The  priority  sectors  identified  derive  from  the  Moroccan  reform  agenda 
itself issued from the 2011 Constitution.  

While  there  is  scope  for  some  consolidation  and  concentration,  the  limitation  to  only  three 
(traditional) sectors would have reduced the Commission policy leverage and would have run 
against the spirit of the Advanced Status’ Action Plan. Given the importance of the reforms 
carried  out  by  Morocco  it  was  politically  opportune  to  support  those  ones  which  were  i) in 
line with the SSF and ii) important for Moroccan development. 

27 Following the information provided to the Delegation by headquarters on the amount of 
the  AAP,  the  indicative  financial  allocation  for  each  programme  is  discussed  between  the 
Delegation and the Moroccan partners. Delegation proposals are then formalised in a note by 
DG  NEAR  to  the  Commissioner  proposing  the  breakdown  into  programmes  of  the  AAP 
envelope. This is then adopted by the Commission following the opinion of Member States in 
the  comitology  procedure.  The  Commission  considers  that  the  preparation  dossier  for  each 
intervention is comprehensive and fully documented. 

32  Given  Morocco’s  longstanding  strategic  relevance  for  the  European  Union,  the 
Commission,  together  with  the  EEAS  and  the  Member  States,  considered  that  the  first 
priority was to re-establish ties and to pursue cooperation with Morocco, including technical 
and  financial  cooperation  and,  therefore,  BS.  Member  States  strongly  endorsed  the 
Commission’s  approach  to  continue  programming  2016  cooperation  activities  whilst 
approving the Commission’s approach to future programming. Furthermore, in October 2018, 
Member  States  in  the  framework  of  the  ENI  Committee  concluded  that  the  Single  Support 
Framework (SSF) priorities were still pertinent, and unanimously endorsed the Commission 
proposal to extend the SSF for 2018. The same conclusions and endorsements were reiterated 
for the period 2019-2020 during the ENI Committee meeting of 03/07/2019. 

The current SSF covered the period up to the end of 2017, hence there was no need to review 
priorities  in  2015.  The  fact  that  in  2017  the  Commission  decided  to  extend  the  Advanced 
Status  and  the  SSF  to  2018  instead  of  discussing  new  “Partnership  Priorities”  in  no  way 
undermined the programming of the ENI for the 2018 – 2020 period. The priorities identified 
in  the  2014  –  2017  SSF  remained  valid  and  allowed  the  Commission  to  programme  ENI 
resources accordingly and to guarantee continuity and coherence in the cooperation activities. 

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The continued relevance of the sectors identified in the initial 2014-2017 SSF is confirmed by 
the “new” priorities identified during the EU-Morocco Association Council held on June 27th 
2019,  which  were  thoroughly  discussed  with  Member  States  and  with  Morocco  as  the 
guidelines for the future of the partnership. 

33  During  the  standstill  period,  the  Commission  adopted  a  pragmatic  approach  to 
cooperation,  continuing  BS  as  well  as  cooperation  in  areas  covered  by  the  SSF.  This 
approach  was  endorsed  by  the  Member  States  in  the  Council.   Whilst  formal  Political 
Dialogue as stipulated in the Association Agreement did not take place during this standstill 
period,  high  level  political  dialogue  continued,  for  example  the  meeting  between  Deputy 
Foreign Minister Bourita and President Juncker and the HRVP on 07/02/2017. 

34  As  India  and  China  are  not  OECD/DAC  members  they  are  less  bound  by  international 
commitments to coordinate. 

39 The Commission would like to underline that impact is the medium to long-term product 
of reforms which are implemented in stages. When BS programmes come in at the beginning 
of the reform, impact will not be measurable before some time and very likely after the end of 
the 3-year BS programme. 

While  the  indicators  for  disbursing  the  variable  tranches  are  only  one  element,  the  level  of 
disbursement  can  be  a  proxy  of  the  ambition  (or  at  least  difficulty,  which  should  be 
correlated) of the indicators. Figures for the EU’s overall BS operations show a decline in the 
share of disbursements over the potential that could be disbursed, which suggests an increase 
in  ambition  or  at  least  a  toughening  of  the  conditions  and/or  an  increased  difficulty  for  the 
Government to implement its reform agenda. 

41 The choice of the nature of indicators in the programmes audited, more oriented towards 
output  and  process,  is  due  to  the  degree  of  maturity  of  the  reforms  targeted.  Output  and 
process indicators are just as relevant and important during the implementation of a reform as 
outcome  indicators.  In  this  respect,  the  Commission  appropriately  applied  the  2017  BS 
guidelines  on  indicators  to  be  used  for  the  disbursement  of  variable  tranches  (section  4.4.3 
and Annex VIII). 

As outcomes are measured over a longer period of time, it would not have been appropriate 
to expand further the use of outcome indicators in this case. 

Moreover,  in  compliance  with  the  ownership  principle,  disbursement  indicators  should  be 
selected  mainly  among  those  that  were  identified  in  the  reform  indicators’  passport  of  the 
beneficiary country. 

42 It is the Commission’s assessment that only 6 targets out of 86 may be considered as not 
sufficiently ambitious and the Commission is in the process of reviewing them. 

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Concerning the general level of ambition of targets, the Commission is of the opinion that the 
overwhelming majority of indicators were sufficiently ambitious and allowed BS to fully play 
its role. Budget financing supports the reform efforts of the Government. The assessment of 
the eligibility criteria for each payment and the achievement of indicators prove that there has 
been  sufficient  progress  in  reforms  during  the  implementation  of  the  BS  programmes. 
Evaluation  findings  consistently  underline  that  ’budget  support  cannot  buy  reforms’  –  and 
this is not its aim. 

The Health Sector Programme is based on the Ministry’s Health Sector Strategy 2012 – 2016. 
In  the  Programme,  the  development  of  human  resources  is  addressed  through  the  general 
conditions of the BS, variable tranche indicators and through activities of technical assistance 
components.    Indicator  12  (training  “just”  13  doctors)  was  in  fact  aimed  at  establishing 
a specific training for general practitioners targeting practitioners residing in rural areas. The 
13 doctors alluded to by the ECA constitute the first batch of graduates. 

43 The challenges quoted by the ECA are indeed important and have been addressed by the 
Commission in several ways both through BS indicators, technical assistance activities and a 
WHO  programme financed  by  the  EU  aimed  at  improving  the  quality  of  health  services  in 
rural areas. In particular:  

High staff absenteeism is addressed by empowering hospital managers in the regions through 
TA  activities  (see  reply  to  paragraph  42  above)  and  the  WHO  programme  (developing 
management capacity and improving management of the PHCs). 

Low  attractiveness  of  remote  areas  is  addressed  through  an indicator  of  the  BS  programme 
(Indicator  12  establishing  a  Masters  for  general  practitioners),  TA  to  improve  the  service 
orientation  of  PHCs  staff,  and  the  WHO  programme  aimed  at  improving  services  in  rural 
areas. 

Structural  underuse  of  hospital  infrastructure  is  addressed  through  TA  activities  aimed  at 
improving  public-private  partnerships  and  improving  hospital  governance.  In  addition,  this 
issue is central to the Social Protection reform Programme, which aims at universal medical 
coverage,  hence  the  Commission  rightly  avoided  overlapping  activities  in  the  Health 
programme. 

44 The Ministry decided in 2018 to apply the new laws to all the social protection centres. In 
recognition  of  this,  in  2019  the  Commission  will  review  the  indicator  target  which  is 
scheduled for payment in 2020. 

47  Efforts  are  underway  to  improve  the  sectoral  strategies’  monitoring  frameworks.  The 
quality  of  the  sector  strategies  and  the  accompanying  monitoring  systems  is  being 
strengthened  under  the  PFM  reform  programme  supported  by  the  EU.  This  work  aims  at 

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introducing performance elements into the budgetary process, and will be emphasised under 
all new BS operations. 

48  a)  Specific  objectives  relate  to  the  wider  objectives  of  the  policy  reform  process  whose 
progress is monitored holistically through the general conditions. The annual variable tranche 
performance indicators audited are not designed to track this progress. 

c)  The  Commission  considers  that  these  two  indicators  were  relevant  as  they  were 
contributing  to  the  BS  programme  objectives.  The  Commission  used  the  increase  in  the 
absolute number of patients treated in rural areas as a good proxy for reduced disparities in 
access  to  treatment.  As  the  reduction  of  disparities  cannot  be  measured  through  a  variable 
tranche indicator year on year, the indicator measures provision of services instead: ensuring 
that patients with two of the most common chronic non-transmissible diseases receive regular 
treatment is a good functional measurement of the improvement in health service provision in 
rural areas. 

d) As indicated in the footnote, baselines were not needed for all indicators. The Commission 
set baselines when deemed necessary to adequately achieve the measurement of targets. The 
baselines referred to as ‘outdated’ mainly concern the health programme where figures used 
as  baselines  were  the  latest  available  official  figures  at  the  time  of  the  signature  of  the 
financing  agreement.  The  Commission  does  not  consider  it  appropriate  to  judge  them 
outdated a posteriori. 

e)  A  twelve-month  period  to  finalise  the  financing  agreement  is  provided  for  during  the 
programming process according to the Commission’s rules. 

In this context, some targets were indeed met before the signature of the financing agreement 
(e.g.  the  submission  of  the  “Plan  Handicap”  21/10/2015,  or  the  finalisation  of  the 
Sustainable  Development  Strategy).  This  is,  in  fact,  proof  of  commitment  from  the 
government and the result of continuous policy dialogue during negotiations. The prospect of 
a forthcoming BS programme and the continuing policy dialogue contribute in no small way 
to  driving  momentum  for  these  reforms.  When  assessing  the  achievements  of  the  BS 
programme,  it  is  therefore  appropriate  to  take  into  account  efforts  made  during  the 
negotiation  period.  To  do  otherwise,  the  Commission  considers,  would  be  to  penalise  the 
partner government for making progress during the negotiation period. 

50  Though  implementation  of  reforms  may  have  faced  delays,  the  Commission  took  the 
necessary  steps  to  adjust  its  programmes  to  maintain  the  focus  and  the  ambition  of  the 
support. 

Delays in implementation of reforms do occur in BS programmes. This is evidence of i) the 
pertinence  and  ambition  of  BS  targets,  ii) the  complexity  of  the  reforms  being  supported 
requiring more time than initially planned for their deployment, and iii) the relevance of BS 
as a tool to flexibly support the process. 

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51  The  extension  of  duration  of  the  Financing  Agreements  in  the  Justice  and  PACC 
programmes  has  been  agreed  to  expand  the  technical  assistance  activities  (justice)  or  to 
include new strategic indicators (Financial inclusion strategy for the PACC). 

52  The  Commission  considers  that  the  available  complementary  support  was  a  suitable 
reinforcement  to  the  BS  programme,  and  the  time  required  to  contract  complementary 
support is factored in  when the Commission  drafts an Action Document.  In the case of the 
justice  and  the  health  programmes  contracts  with  international  organisations  (UNICEF, 
Council  of  Europe  and  WHO)  were  signed  within  three  months  from  the  signature  of  the 
Financing Agreement. 

Furthermore complementary support is provided through other programmes already ongoing 
such  as  the  “Réussir  le  Statut  Avancé”  financing  institutional  strengthening  and  legislative 
approximation with EU standards through twinnings and technical  assistance for the PACC 
and Health programmes or the “Couverture Médicale de Base III” for the Social Protection 
programme. 

55 In line with guidance contained in the BS guidelines, all independent monitoring missions 
were carried out as scheduled. 

The  EU  Delegation  maintained  sectoral  dialogue  at  all  levels  in  all  sectors  of  intervention 
aiming  at  monitoring  that  reforms  laid  out  in  national  sectoral  strategies  progressed  as 
planned.  In  conclusion,  the  Commission  considers  that  the  policy  dialogue  with  Moroccan 
authorities was sufficient for the realisation of the objectives of the programmes audited. 

58 Sources of information indicated in FAs are indicative, in as much as delegations and HQ 
services are mandated by the EU Budget  Support  guidelines to  use all relevant  information 
available to reach a judgement on eligibility, specific conditions, as well as variable tranche 
indicators. 

One  of  the  reasons  for  this  relates  to  the  fact  that  the  value  of  an  indicator  needs  to  be 
assessed  in  context.  If,  for  example,  a  clearly  exogenous  factor,  which  can  be  ascertained, 
influenced  the  indicator's  performance,  this  can  be  factored  in  the  final  judgement.  The 
information on such exogenous factor may come from any source. 

59 a) The Commission considers that the sources of verification used were appropriate when 
disbursements  were  made.  Performance  assessment  was  carried  out  in  accordance  with  the 
budget  support  guidelines  (section  4.4.4),  which  promote  a  process  led  by  the  government 
and based on country's monitoring framework, whenever possible. In line with international 
commitments  on  aid  effectiveness  and  with  the  European  Consensus  on  Development,  the 
use  of  country  systems  aims  at  strengthening  these,  making  them  more  inclusive  and 
enhancing domestic accountability. 

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The checks made by the Commission to verify the number of auto-entrepreneurs (AE) were 
reasonable and proportionate as due consideration had been given to the monitoring system 
and official reporting provided by the Government. 

In this context, the Commission has no reason - and no evidence - to doubt the accuracy of 
the database in determining the achievement of the indicators which aimed at evaluating the 
attractiveness of the AE scheme, the adherence of the target population (including both active 
and currently inactive self-employed) and the strength of sensitisation measures. It does not 
measure an increase in the level of activity of self-employed as this is a medium-term higher 
level objective. 

b) Baselines were not outdated as the Commission used the most recent data available when 
negotiating  the  Financing  Agreements  (FA).  Disbursements  were  made  in  accordance  with 
the provisions of the FA. 

As  concerns  the  indicator  on  child  birth  in  rural  areas,  this  indicator  measures  the  share  of 
deliveries  attended  in  rural  health  centres.  Both  baselines  and  targets  were  in  line  with  the 
Government strategy and its commitment to achieve MDGs by 2015. 

As  the  objective  is  to  support  a  trend,  a  slight  decrease  of  0.2%  in  a  given  year  cannot  be 
considered  significant  when  comparing  with  the  trend  over  the  last  5  years  when  maternal 
mortality  has  decreased  by  14%.  In  this  context  the  rate  of  85%  of  birth  attended  is  the 
evidence that the programme implemented by the Government to reduce maternal mortality is 
protracted over time and successful. 

c) The Commission set baselines when deemed necessary to adequately measure the targets. 

As concerns the target on the number of diabetic patients treated, the calculation was correct 
and  reflected  the  increasing  coverage  of  patients  in  rural  areas.  Diabetes  being  a  chronical 
disease  it  is  important  that  the  baseline  of  patients  continue  to  be  treated.  Adopting  a 
calculation  method  that  would  only  pay  in  case  of  an  increase  in  the  number  of  patients 
would not reward efforts by the Government to maintain an adequate treatment of the disease 
in rural areas. 

d)  The  Commission  considers  that  for  thirteen  targets  progress  was  sufficient  and  targets 
were achieved to justify disbursements, which were made in compliance with the provisions 
of the Financing Agreements and the objectives pursued in the BS programme. 

For  the  target  concerning  the  number  of  general  practitioners  as  well  as  another  target, 
progress  was  wrongly  calculated,  and  the  Commission  has  initiated  the  recovery  of  the 
amounts paid.  

60 The Commission does not share the conclusion regarding the disbursement issues raised 
by ECA in Annex VI of the report. 

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A total of €147 million was paid for the programmes audited of which €140 million for the 
BS  component  (including  €88  million  of  variable  tranches  payments).    The  Commission 
considers that all indicators selected are relevant to the objectives of the BS programme and 
the sectoral reforms they are supporting. The Commission considers that all payments were 
appropriately  checked  and  appropriate  sources  of  verification  used  in  line  with  existing  BS 
guidelines,  except  for  two  targets  in  the  health  programme  where  €3.59  million  are  in  the 
process  of  being  recovered.  Hence  regular  payments  for  the  BS  component  amounted  to 
€136.41 million. 

Concerning  the  two  other  indicators  identified  by  the  ECA  as  inappropriately  paid:  i)  the 
payment  of  Indicator 7 in the health sector was  paid  according to the provisions of the  FA 
and  the  Commission  maintains  that  the  calculation  method  applied  is  appropriate  for  the 
objective  pursued,  and  ii)  the  payment  of  indicator  1.2  in  the  Social  Protection  programme 
was made in line with the provisions of the FA as the mid-term financing framework (2017 – 
2020)  of  the  social  sector  ministries  was  publicly  available  through  the  ministries’ 
Performance  Projects  required  by  the  Finance  Law,  validated  by  the  Budget  department  of 
the  Ministry  of  Finance  and  submitted  to  the  Parliament.  In  addition,  the  Commission 
received from the Ministry of Finance the 2017-2019 budgetary allocations proving that the 
budgetary allocations to these Ministries was steadily increasing year on year. 

61  The  Commission  appropriately  applied  the  flexibility  foreseen  in  the  Financing 
Agreement to carry over the evaluation of indicators when external circumstances so justify 
and  when  the  carry-over  has  the  potential  to  maintain  the  incentive  for  Government  to 
implement important reforms. 

The  carry-over  of  some  indicators  was  assessed  following  a  formal  request  by  the 
Government on the grounds of arguments advanced by the respective Ministry during official 
meetings supported by the assessment of the external monitoring missions. A formal rider to 
the  Financing  Agreement  was  signed  between  the  Government  and  the  Commission 
following an internal validation process supported by a detailed justification note. 

64. Monitoring activities are carried out throughout the year. They include regular policy and 
technical dialogue between Delegation staff, the Authorities, and other relevant stakeholders. 
Moreover, monitoring is carried out through bi-annual field visits and an annual mission to 
prepare  the  disbursement  file,  which  includes  a  section  on  the  progress  made  in  the 
implementation of the sectoral policy. 

Box 3 - Weaknesses in the Commission’s monitoring procedures  

The  Justice  programme  does  not  provide  funding  to  the  construction  of  any  jurisdiction  in 
particular, but provides incentives for reforming some aspects of the judicial map. 

The Financing Agreement states that the reform of the Centres for Resident Judges (CRJs) is 
equivalent  to  at  least  60%  of  the  judicial  map.  Hence  the  target  was  achieved  with  the 

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adoption by the Council of government of the judicial map and the reform and redeployment 
of the CRJs. 

The  second  sub-target  N+2  of  indicator  3  does  not  measure  whether  the  CRJs  are  or  not 
operational. 

66 Concerning the level of risk in achieving targets, the risk assessment is carried out twice a 
year by the Commission. Indeed, as circumstances evolve it is good administrative practice to 
review the likeliness of achieving the targets set. 

67 The Commission considers that, whilst  some indicators have not  been reached, progress 
has been remarkable and further progress is expected. Access to health services in rural areas 
has  improved  during  the  life  of  the  programme  as  shown  by  the  increase  in  number  of 
diabetic and hypertensive patients treated/ monitored. From 2012 to 2016, improved access to 
primary health care centres has resulted in a 35 % reduction in maternal mortality. 81.2% of 
pregnant women in rural areas had a prenatal consultation in a public health structure in 2017, 
(rising from 71.2% in 2015). Prices have dropped for 3600 medicines and generic medicine 
sales have risen by 39 %, thereby increasing  access.  Lastly,  as  of  2019, regional inspectors 
have been appointed in all regions. 

68 The Commission considers that out of the three targets of results indicators only the one 
relating  to  medical  coverage  for  non-salaried  workers  still  remains  to  be  achieved.  The 
legislative instruments for this indicator should be adopted in the near future. 

69  The  Commission  took  appropriate  measures  to  mitigate  the  impact  of  the  delay  in  the 
approval of the penal code on the programme within the limit of the flexibility allowed by the 
Financing Agreement. 

The target on the judicial map aimed at supporting the redeployment of Centres for Resident 
Judges. The adoption of the regulatory act has therefore implemented the new judicial map at 
60%, as foreseen in the Financing Agreement. 

Concerning the target aiming at facilitating judicial assistance, this was a process target. The 
use of the RAMED card to grant vulnerable people access to judicial assistance corresponds 
to  the  target  set  in  the  Financing  agreement  which  foresees  the  unification  and  the 
simplification of the documents required for having access to judicial assistance. 

70 The Commission considers that all payments are justified. Its assessment is supported by 
i) the  evidences  provided  by  the  administration,  ii) the  Commission  verification  of  the 
supporting documents, and iii) the results of the independent monitoring mission. 

In  particular,  all  sources  of  verification  were  in  conformity  with  the  prescriptions  of  the 
Financing Agreement. The statistics used are the public statistics available; the same data are 
used by the Ministry of Finance. 

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71  The  modifications  of  the  Financing  Agreement  granting  an  extension  and/or  a 
modification of some indicators was granted by the Commission in line with the provisions of 
the BS guidelines and in compliance with applicable rules and procedures. 

When  relevant,  the  Commission  has  adjusted  the  programmes’  indicator  to  maximize  the 
positive  leverage  of  the  SRPC  and  the  effectiveness  of  EU  financing,  adjusting  it  to  the 
evolution of the institutional context.  

Finally, it is important to note that it is not the BS programme, which achieves its targets, but 
the Government, which, by implementing the reform it has launched, achieves its objectives. 
Carrying over the evaluation of indicators/ targets when justified is the most effective way to 
maximize the effectiveness of EU support.  

72 The Commission’s BS policy provides for targeted BS in some specific cases, for example 
with  state  and  resilience  building  contracts.  These  contracts  are  commonly  used  in  post-
conflict situations. BS supports reform but it does not and cannot buy them. The success and 
the sustainability of any reform depend greatly on the ownership by the government and the 
people of the country. 

The objective of BS is not to provide higher budgets to sectoral ministries but to ensure that 
the  budget  is  adequate  with  respect  to  the  objectives  of  the  national  strategy  and/or  the 
programme.  BS  can  ensure  i)  that  the  reform  is  implemented  as  swiftly  as  it  is  politically 
feasible, ii) that the reform is of a sufficient “quality”, matches best international practice and 
receive top quality professional expertise. 

73  The  Commission  considers  that  implementation  of  reforms  is  not  dependent  on  sectoral 
budget  line  execution.  This  notwithstanding,  the  Commission  points  out  that  the  budgetary 
execution  rates  for  both  the  Justice  and  Health  Ministries  are  respectively  above  90%  and 
95% over the 2014-2016 periods and above 100% in 2017. 

74 Though the amount of BS funding may be limited in terms of share of GDP, its nature as a 
grant as well as the rigorous assessment and the complementary support that accompanies EU 
programmes provides a greater leverage than that enjoyed by most other donors. 

75 The EU Delegation receives and uses the public statistics available, the same data are used 
by the Ministry of Finance. The data sets identified can indeed provide useful information on 
the  implementation  of  sectoral  policies.  The  Commission  is  currently  discussing  with  the 
Ministry of Finance the possibility of supporting the departments to produce more complete 
sets of statistical data. 

The Moroccan statistical system is very well advanced – better than in many other countries – 
as indicated by the World Bank Statistical Capacity Index. Hence it provides sufficient basis 
for  the  monitoring  and  analysis  of  sectoral  progresses.  In  addition  to  statistical  data,  other 
sources of information are used by the Commission to crosscheck the information provided 
and validate the level of achievements. 

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76 The Commission refers to its replies to paragraph 69. 

77 The issue of medical staff has been consistently addressed by the Government. A score of 
medical faculties have been opened by the Government throughout the country. Furthermore, 
since the adoption of the law on  Public Private Partnerships  (2015), private sector faculties 
have  opened  in  Morocco,  which  provide  a  variety  of  complementary  curricula  in  medical 
professions for different types of medical workers. This issue was addressed by the EU in its 
policy dialogue. 

With  funding  from  the  World  Bank,  an  electronic  healthcare  information  system  was 
expected to be designed.  Unfortunately, the World Bank support did not materialise in time. 
A master plan  for its  deployment has now been  validated by the Ministry  of Health.  There 
was no need for the EU to duplicate this activity.  

80  Progress  of  sensitive  and  difficult  reforms  is  sometimes  slower  than  expected,  but  the 
quality of achievements and the ownership by the Administration and the population are vital 
for its success. 

81 As an acknowledgment of the importance of reducing pre-trial detention, the Government 
has removed the relevant articles from the penal code, and has recently submitted them as a 
separate law to accelerate their reform. 

The  Commission  in  the  Financing  Agreement  indicated  this  issue  as  a  key  one  to  be 
addressed in the BS programme. Three indicators have been developed to this purpose. 

Encouraging results have been achieved with a reduction to 39 % of the number of prisoners 
held under preventive detention in 2018. 

82 Deep and profound reforms such as those in the justice sector (aiming at an independent 
justice  sector,  improved  access  to  rights  and  justice,  increased  judicial  protection  of  rights 
and  freedoms  and  an  increase  in  the  effectiveness  and  efficiency  of  the  judiciary),  cannot 
provide evidence of impact in such a short period of time particularly as such reforms need to 
gather support from within the administration, the magistrates and the population at large. 

The progress being made in the different strands of the reform (albeit limited as concerns the 
penal code) is significant and impact will be measured in the coming years. 

85 The aim of PACC was to show that a new set of regulations and specific advantages could 
provide the necessary incentives for one-man businesses to emerge. The added value of the 
programme is to ensure the quality and sustainability of the arrangements put in place for the 
auto-entrepreneur. The programme is not aimed at forcing a reform, or to significantly reduce 
the  national  percentage  of  informal  business  units  in  three  years,  but  aims  at  exploring 
innovative ways to win the reticence of AEs to formalise their activity. 

Given its size and scope the PACC programme supports the most promising of the processes 
set up by the Moroccan government to increase the degree of formalisation of the economy 
and  encourage  job  creation  (i.e.  establishing  the  auto-entrepreneur  status).  Similarly,  in  the 

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case  of  investment  programmes,  the  PACC  project  is  accompanying  the  increase  in  the 
portfolio of projects supported by the Moroccan Agency for SME's. 

86 The Commission considers that the primo-exporter programme is targeting an important 
increase in the number of regular exporters. 

87  The  Commission  agrees  that  visibility  was  limited  during  the  period  when  the  political 
relations were suspended; however, since 2017 EU visibility has greatly improved. 

88 The Commission confirms that official high level events with the participation of the EU 
Delegation were organised and attended as of 2017. 

89  For  the  PACC  Programme,  since  mid-2018,  visibility  has  greatly  increased,  including 
through comprehensive press coverage. 

90  No  logos  of  other  Technical  and  Financial  partners  appear  on  the  websites  of  the 
Ministries. 

92 The Commission considers that although disparities remain, since 2012  there has been a 
notable  improvement  in  access  to  the  public  hospital,  which  has  increased  by  80 %  and 
specialised public consultations have increased by 78 %. 

93 The Commission would like to underline that  data concerning the prevalence of poverty 
and  inequality  in  Morocco  date  back  to  2013  and  2014,  using  2010  data.  The  same  data  is 
used by more recent publications such as the African Development Dynamics 2018. As more 
recent  data  are  not  available,  the  Commission  questions  the  conclusions  by  ECA  that  BS 
programmes  implemented  between  2014  and  2018  had  no  significant  impact  on  these  two 
indicators.  Furthermore,  it  is  not  methodologically  correct  to  assess  the  impact  of  BS 
programmes on the basis of data pertaining to  periods prior to  the implementation of those 
programmes. 

94 The Commission considers that, although advancements in women rights have not taken 
place  in  all  areas,  there  has  been  a  notable  improvement  in  women’s  political  participation 
both at national and at local level. Morocco ranks 123 out of 189 in the UN Gender Equality 
Index 2017. 

95 b) The Commission considers that the previous Gender equality BS programme has been 
key for the institutionalisation of gender issues in key sectoral policies. 

While the need to reinforce the coordination between the different institutional stakeholders 
is recognised, effectively mainstreaming gender issues remains a challenge. 

In recognition of this, the Commission, to ensure a stronger gender focus in the more recent 
BS programmes, while maintaining attention to the disaggregation of data in sectoral BS, has 
complemented  the  programmes  by  adding  at  least  one  specific  dedicated  gender-related 
indicator based on sectorial gender analyses. 

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c) As women economic empowerment is a major challenge, the Commission is setting up a 
proper strategy through different instruments (not only BS) as for example through a specific 
programme "Women in Business" financed via the NIP. 

Due  to  a  continuous  sectorial  dialogue  in  this  area,  the  second  gender  programme  has  a 
specific indicator focusing on women economic empowerment. 

As  a  complement  to  PACC,  in  order  to  have  specific  activities  aiming  at  women 
entrepreneurs,  the  Commission  has  provided  grants  through  the  NIF  to  a  specific  private 
sector support programme implemented by the EBRD. 

d)  The  Commission  would  like  to  point  out  that  human  rights  issues  are  also  addressed 
through  different  political  and  cooperation  channels.  In  the  four  audited  programmes,  three 
indicators in the justice sector directly related to human rights were not achieved due to the 
delay in the approval of the penal code. 

However, it should be noted that both the Health and the Social Protection programmes, by 
aiming to improve access to social services directly contribute to the realisation of social and 
economic rights. 

96  During  this  period  there  were  some  positive  landmarks  (setting  up  of  the  Authority  for 
Equality  and  Fight  against  Discrimination  in  2017,   adoption  of  law  103.13  on  violence 
against women and girls in 2018), even if there has been uneven progress so far. According to 
the  EU's  Annual  Reports  on  Human  Rights  and  Democracy  covering  the  years  2015-2018, 
despite  positive  trends  in  some  areas,  including  the  Justice  system,  the  institutional  Human 
Rights Framework and corruption, significant human rights challenges remain in Morocco. 

98 Freedom House considers Morocco a ‘partly free’ country, scoring 39/100 in its Freedom 
in the World Report of 2019 (see Figure 15). The main issues mentioned in this report are the 
restrictions on freedom  of press and freedom of assembly, lack of internet freedom  and the 
lack  of  independence  of  the  justice  sector.  In  2018,  the  score  for  Morocco’s  civil  liberties 
declined from 4'5 to 5 out of 7 due to the state responses to major demonstrations throughout 
the year (see Figure 14). 

CONCLUSIONS AND RECOMMENDATIONS 

99  In  view  of  the  elements  set  out  in  its  replies,  the  Commission  concludes  that  EU 
cooperation  has  contributed  to  the  implementation  of  reforms  in  Morocco.  This  has  had  a 
positive  impact  on  the  country’s  socio-economic  development,  and  has  been  consistently 
illustrated  by  Commission  monitoring:  both  internal  and  external  independent  annual 
evaluations have assessed the steady reform process favourably. 

100  The  priority  sectors  identified  derive  from  the  Moroccan  reform  agenda  itself  issued 
from  the  2011  Constitution.  While  there  may  be  scope  for  some  consolidation  and 
concentration, the limitation to only three sectors would have been contrary to the spirit of the 
Advanced  Status’  Action  Plan  and  reduced  the  Commission’s  policy  leverage.  The 

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Commission considers that amounts are allocated to sector BS programmes in a transparent 
and methodological process which is fully documented (see Commission reply to paragraph 
27). The political  standstill was discussed in  depth  in  the European Council working  group 
with  Member  States  who  endorsed  the  Commission’s  strategy  (see  Commission  reply  to 
paragraph 32).   

Recommendation 1 – Strengthen the focus of EU BS in Morocco 

First indent: The Commission and the EEAS partially accept the recommendation. 

As called for in the EU’s Agenda for Change and programming guidelines, the Commission 
and  the  EEAS  agree  to  concentrate  on  a  more  limited  number  of  sectors.  However, 
prioritising these sectors would be counter to current guidelines. 

Second indent: The Commission and the EEAS accept the recommendation and consider 
that it is already being implemented. 

The  Commission  and  the  EEAS  are  regularly  adjusting  the  methodology  in  the  light  of 
experience gained. 

The Commission and the EEAS take account of the ECA’s recommendations as part of their 
regular reviews of methodology and the way in which it is implemented. 

Third indent: The Commission and the EEAS accept the recommendation. 

The Joint Programming  (JP) process  was launched in  2015 and the EU and Member States 
completed  a  joint  analysis  of  the  country’s  main  development  challenges.  In  2017,  it  was 
decided to  concentrate JP in three main sectors (gender, migration and vocational training). 
These three sectors were outside the scope of the audit. Substantial efforts have been made in 
the  implementation  of  joint  programming  in  Morocco  during  the  present  programming 
period. The Commission and the EEAS will pursue these efforts even more vigorously in the 
new programming exercise. 

101 Budget Support Financing Agreement and its annexes contain all the targets, indicators 
and  baselines  necessary  for  the  implementation  of  the  programme.  The  Budget  Support 
Guidelines do not call for the development of an action plan. 

See Commission replies to paragraphs 47 and 48. 

Recommendation 2 – Improve design of targets and performance indicators 

First indent: The Commission and the EEAS do not accept the recommendation. 

The  Commission  points  out  that  defining  specific  and  relevant  performance  indicators  is 
already standard practice, in line with Budget Support Guidelines. 

The  Commission  considers  that  the  targets  and  performance  indicators  used  in  the 
programmes audited were appropriately calibrated to the Moroccan context. The reasoning is 
outlined  in  each  programme’s  intervention  logic,  which  is  part  of  the  action  document 

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validated by Commission services and the Member States. It should be noted that BS is not 
limited to performance indicators. 

Second indent: The Commission and the EEAS accept the recommendation and make use 
of outcome-oriented indicators wherever appropriate. 

Third indent: The Commission and the EEAS accept the recommendation and make use 
of baselines wherever pertinent. 

102 The Commission points out that policy dialogue is conducted daily and at all levels. Key 
issues are raised systematically when necessary  at  the appropriate level.  Fully documenting 
this process in its entirety would entail huge administrative costs and may have implications 
for sensitive  and sometimes confidential  discussions. Annual  meetings  are documented  and 
minutes have been transmitted to the ECA. 

The Commission adheres to the Budget Support Guidelines on policy dialogue in the context 
of BS. The outcomes of policy dialogue are and will be an important part of any evaluation. 
Nevertheless, the Commission would like to draw attention on the political sensitivity of the 
reforms and political objectives and therefore maintains that dialogue strategies will continue 
to be formulated protecting the Commission's interests. 

Contacts  with  the  Moroccan  administration  are  maintained  at  all  levels  and  issues  are 
addressed at the appropriate level in accordance with sound management principles, and with 
respect to diplomatic protocol, and operational necessity. 

See also Commission replies to paragraphs 56 and 57. 

Recommendation 3 – Strengthen policy dialogue 

Policy dialogue is a core part of development aid practice and BS programmes' identification, 
formulation, implementation, monitoring and assessment in Morocco. It is not only linked to 
funding but covers all areas of the Advanced Status Action Plan. 

The Commission could consider, as advised, reporting more formally and regularly on policy 
dialogue.  However,  informal  policy  dialogue  remains  pertinent  and  effective  in  certain 
circumstances  (as  confirmed  during  the  period  of  political  standstill  in  EU-Morocco 
relations). 

First indent: The Commission and the EEAS accept the recommendation. 

Better guidance on policy dialogue in the framework of BS is integrated in the updated BS 
guidelines. 

Nevertheless,  the Commission  would like to  stress  the political  sensitivity  of some reforms 
and  political  objectives  and  therefore  maintains  that  dialogue  strategies  will  be  formulated 
protecting the Commission's interests. 

Second indent: The Commission and the EEAS partially accept the recommendation. 

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Minutes of all key meetings are drafted and  followed up as  required. The Commission  and 
the EEAS will endeavour to document the policy dialogue more systematically. 

Third indent: The Commission and the EEAS partially accept the recommendation. 

Regular  reporting  on  the  policy  dialogue  is  ensured  within  the  External  Aid  Management 
Reports  reporting  framework  and  the  disbursement  notes.  The  Commission  and  the  EEAS 
will endeavour to document the policy dialogue more systematically. 

103 See Commission replies to paragraphs 59 to 63. 

The Commission considers that: 

- 

the sources of verification used are considered appropriate. 

-  sources of verification were absent only for one indicator and one target as they were to be 

provided by Government before payment. 

- 

the quality and reliability of data were verified whenever deemed necessary as, in line with 
international best practice, the Commission relies on national statistical systems. 

-    errors in payments only affected the payment of two targets and a recovery procedure has 

been initiated. 

-  all other disbursements were made in line with the provision of the FA. 

-   the carry-over of targets was done regularly on request by the relevant Ministry following 
the appraisal by both the independent monitoring missions and Commission services.  

Recommendation 4 – Enhance disbursement verification procedures 

First  indent:  The  Commission  does  not  accept  the  recommendation  as  it  is  based  on 
observations and conclusions that the Commission does not share. 

The  Commission  points out  that,  in  accordance  with  sound  financial  management  practices 
and the Budget Support Guidelines, appropriate calculation methods are used and explicitly 
described in the annexes to the financing agreement. On the rare occasions where errors have 
been made, these are corrected in a timely manner. 

Second  indent:  The  Commission  does  not  accept  the  recommendation  as  it  is  based  on 
observations and conclusions that the Commission does not share. 

The  Commission  points  out  that  this  is  already  standard  practice.  According  to  the  Budget 
Support Guidelines, funds are disbursed only when there is reliable evidence that targets have 
been achieved. 

The  reliability  and  consistency  of  the  sources  of  verification  are  thoroughly  verified  by  the 
Commission throughout the programme lifecycle. 

The  national  data  collection  system  in  the  sectors  audited  was  assessed  as  reliable  during 
programme  formulation.  This  assessment  is  supported  by  Morocco’s  standing  in  the  World 

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Bank  Statistical  Capacity  Index  (SCI)  where  the  country  scores  well  above  the  regional 
average for the quality of its statistical data. 

In line with international commitments on aid effectiveness and with the European Consensus 
on Development, the use of country systems aims at strengthening these, making them more 
inclusive and enhancing domestic accountability. Therefore, when assessing the performance 
of  variable  tranche  indicators,  the  Commission  uses  all  official,  relevant  and  reliable 
information as long as it provides sufficient assurance on the level of achievement. 

Where serious doubts exist about the quality of the data provided, verification exercises are 
carried out to guide payment decisions. 

Third  indent:  The  Commission  does  not  accept  the  recommendation  as  it  is  based  on 
observations and conclusions which the Commission does not share.  

The  Delegation  assesses  the  pertinence  of  the  request  for  carry  over  on  the  basis  of  the 
arguments presented by the partner country. This assessment is double-checked and validated 
by  HQ  services.  These  arguments  may  be  contained  in  a  letter  from  the  Government  or 
reflected in minutes of meetings and/or reports of independent monitoring missions. 

Detailed explanations are given in the relevant paragraphs of the report. 

104 Formal and detailed progress monitoring for each BS reform programme takes place on 
an annual basis, typically with the aid of independent, external  consultants, when preparing 
the disbursement file. This monitoring includes a section on progress in the sectoral policy. A 
constant  policy  dialogue,  visits  and  working  groups  constitute  regular  monitoring  which 
allows for early warning in case deviations occur (see Commission replies to paragraphs 64 
to 66 for specific programme-related comments). 

Recommendation 5 – Improve monitoring procedures 

First indent: The Commission partially accepts the recommendation. 

However, not all programmes justify field visits. 

Second indent: The Commission accepts the recommendation. 

Third indent: The Commission accepts the recommendation. 

105 The Commission considers that 62% of the targets were achieved. 

Ministries’  budgetary  execution  rates  for  both  the  Justice  and  Health  Ministries  are 
respectively above 90% and 95% over the 2014-2016 period and above 100% in 2017. It is 
therefore incorrect to state that “significant amounts remain to be spent”. 

BS’s added value is to support the implementation of local reforms and action plans, which 
are real, credible and relevant reform programmes, with long term transformative benefits for 
partner countries’ societies. 

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106  Visibility  is  the  result  of  a  continuous  process  of  communication  and  calls  for  a 
differentiated approach according to the context. The financing agreements for BS and other 
external actions already include provisions requiring visibility. 

Visibility was minimal only in 2016. Since 2017 the visibility of EU support has considerably 
strengthened. 

Like for the signature of the initial financing agreement, the incentive for performance does 
not  start  with  the  signature  of  an  addendum.  The  addendum  is  the  result  of  dialogue  and 
negotiations, which have been carried out for months before the addendum is actually signed. 

Further detailed explanations  of the Commission position are  given in  the comments  to  the 
relevant paragraphs (see Commission replies to paragraphs 89 to 92). 

Recommendation 6 – Increase visibility of EU support 

The Commission and the EEAS partially accept the recommendation. 

Introducing  specific  disbursement  conditions  regarding  visibility  would  not  be  appropriate 
and  might  prove  counter-productive  in  some  cases,  such  as  during  the  period  of  difficult 
relations between Morocco and the EU. 

107  The  Commission  considers  that  Gender  and  Human  Rights  are  complex  entrenched 
societal challenges that require time to bring about progress. 

Using  highly  integrated  long-term  impact  indicators  (such  as  HDI  or  Gender  Inequality 
Index) is inappropriate to measure impact of a BS programme over such a short time period.  
Moreover, it should be noted that both HDI and the Gender Equality Index are improving in 
Morocco. 

Further detailed explanations  of the Commission position are  given in  the comments  to  the 
relevant paragraphs (see Commission replies to paragraphs 96 to 100). 

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Audit team 

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

This performance audit was carried out by Audit Chamber III, External actions/Security 
and justice, headed by ECA Member Bettina Jakobsen. The audit was led by ECA 
Member Hannu Takkula, supported by Turo Hentila, Head of Private Office; Helka 
Nykaenen, Private Office Attaché; Kim Hublé, Head of Task; and Aurélia Petliza and 
Dirk Neumeister, Auditors. 

 
Timeline 

Event 

Date 

Adoption of Audit Planning Memorandum (APM) / Start of audit  25.9.2018 

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

3.6.2019 

Adoption of the final report after the adversarial procedure 

14.11.2019 

Official replies of the Commission and the EEAS received in all 
languages 

5.12.2019 

 
 
 
 
 
 
 
 
 
© European Union, 2019. 
Reproduction is authorised provided the source is acknowledged. 

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

PDF
HTML

ISBN 978-92-847-4012-3
ISBN 978-92-847-4016-1

ISSN 1977-5679
ISSN 1977-5679

doi:10.2865/749032
doi:10.2865/314136

QJ-AB-19-022-EN-N
QJ-AB-19-022-EN-Q

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
This audit assessed the effectiveness of EU budget support to 
Morocco from 2014 to 2018. It covered budget support in the 
sectors in the health, social protection, justice and private sector 
development, looking at management by the Commission and 
evaluating the achievement of objectives. The Commission 
considered budget support to be the right choice of aid delivery 
instrument. However, we concluded that its added value and 
ability to support reforms was limited due to sub-optimal focus, 
weak implementation and insufficient monitoring. The main 
weaknesses related to indicator design and results assessment. 
We have therefore made recommendations on focusing support 
in fewer sectors, improving indicator design, enhancing the 
control procedures for disbursement and strengthening the policy 
dialogue. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU.