REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Evaluation report of the Union programme to support specific activities enhancing the involvement of consumers and other financial services end-users in Union policy-making in the area of financial services for the period of 2017-2020 pursuant to Regulation (EU) 2017/826 of the European Parliament and of the Council
Date: 2020-12-17
Institutions: Directorate-General for Financial Stability, Financial Services and Capital Markets Union, European Commission
Subjects: EU aid, EU policy, EU programme, consumer information, financial market, financial services, non-profit organisation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.12.2020  COM(2020) 820 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Evaluation report of the Union programme to support specific activities enhancing the involvement of consumers and other financial services end-users in Union policy-making in the area of financial services for the period of 2017-2020 pursuant to Regulation (EU) 2017/826 of the European Parliament and of the Council   
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE 
COUNCIL 

Evaluation report of the Union programme to support specific activities enhancing the 
involvement of consumers and other financial services end-users in Union policy-making in 
the area of financial services for the period of 2017-2020 pursuant to Regulation (EU) 
2017/826 of the European Parliament and of the Council 

1.  Executive Summary  

End-users  (in  particular  consumers)  and  organisations  representing  end-user  interests  do  not 
manage to participate in EU policy making to the same extent as industry. An important reason 
for  this  is  the  scarcity  of  resources  and  lack  of  specialised  expertise  among  financial  services 
end-users and non-industry stakeholders. After the 2008 crisis, a number of initiatives were taken 
to  increase  the  active  participation  and  involvement  of  consumers  and  other  financial  services 
end-users in EU policy-making.  

Following an initiative of the European Parliament, the Commission initiated, at the end of 2011, 
a pilot-project to provide grants to support the development of a financial expertise centre. The 
aim was for this centre to benefit consumers and other end-users by representing their interests 
and  increasing  their  ability  to  participate  in  Union  policy-making  in  the  area  of  financial 
services.  Following  an  open  call  for  proposals,  the  Commission  awarded,  between  2012  and 
2015,  ‘operating  grants’  to  two  organisations:  Finance  Watch  and  BETTER  FINANCE  (first 
under a pilot project and later in the form of a preparatory action). Since 2016, these grants have 
been provided as ‘action grants’.  

The 2015 evaluation of both the pilot project and the successive preparatory actions showed that 
the  action  generally  succeeded  in  its  objective.  As  a  result,  Regulation  (EU)  2017/8261  was 
adopted.  This  Regulation  sets  up  a  Union  programme  for  the  period  from  1 May 2017  to 
31 December 2020  to  continue  to  support  the  activities  of  BETTER  FINANCE  and  Finance 
Watch. The aim of the present evaluation report is to comply with the obligation under Article 9 
of this Regulation and evaluate whether the programme achieved its objectives of: (i) increasing 
the participation of consumers in Union policy-making in the area of financial services; and (ii) 
informing them about issues at stake in the regulation of the financial sector.  

The Commission launched in 2019 a study which evaluated: (i) the activities of Finance Watch 
and BETTER FINANCE in 2017 and 2018; and (ii) the overall execution of the programme (see 

1 Regulation (EU) 2017/826 of the European Parliament and Council of 17 May 2017 on establishing a Union programme to support specific 
activities enhancing the involvement of consumers and other financial services end-users in Union policy-making in the area of financial services 
for the period of 2017-2020  
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R0826&from=EN 

1 

 
 
 
 
                                                           
 
annex  of  this  report).  The  study  was  based  on  a  review  of  literature,  online  surveys,  and 
interviews with  experts. The study was an important source of input for this  evaluation report. 
The Commission complemented the study by analysing the two beneficiaries’ activities and the 
execution of the programme in 2019. 

This evaluation report concludes that the objectives of the programme have generally been met. 
The  objective  of  further  enhancing  the  involvement  of  consumers  and  financial-services  end-
users  in  Union  policy-making  in  the  area  of  financial  services  was  achieved.  The  work  of 
Finance Watch and BETTER FINANCE has enriched the policy debates and both organisations 
offered  an  alternative  point  of  view  that  policy-makers  might  have  otherwise  missed  or 
neglected.  The  two  organisations  delivered  important  expertise  through  their  contributions  to 
public  consultations  and  their  participation  in  many  important  Commission  and  European 
Supervisory Authorities (ESAs) expert groups. They also presented their views to policy-makers 
in other ways, including hearings, meetings, papers, workshops, roundtables and conferences etc. 
The  objective  of  informing  consumers  and  other  financial-services  end-users  about  issues  at 
stake in the regulation of the financial sector was also generally achieved. Both Finance Watch 
and BETTER FINANCE have informed consumers through campaigns, press releases etc.  

The two organisations have complementary areas of expertise and audiences that only partially 
overlap.  BETTER  FINANCE  addresses  issues  of  concern  to  financial  services  users  with  a 
strong focus on investors and pension savers as well as sustainable and digital finance. Finance 
Watch  addresses  retail  financial  services  in  general,  sustainable  finance  but  also  other  topics, 
such as prudential issues. 

In 2017-2019, Finance Watch received EUR 2 686 957 in EU grants. It also obtained additional 
third-party funding, in particular from one organisation (the MAVA Foundation). Since 2015, it 
has gained new members in other Member States, but it still has a weaker membership base in 
Eastern  Europe  than  in  Western  Europe.  Finance  Watch  covers  technical  topics  from  the 
perspective of consumers in a way that is easy to understand. Its cost-to-output ratio (the outputs 
include  reports,  briefings,  papers,  videos,  events,  and  press  releases)  was  relatively  stable 
between 2017 and 2019. The organisation is considered as very effective in using social media. It 
also increased its communication potential through a new website. 

During the same period, BETTER FINANCE received EUR 1 092 947 in EU grants. BETTER 
FINANCE did not obtain much third-party funding. It covered a significant share of its budget 
(the  share  that  was  not  covered  by  Commission  grants)  by  membership  fees.  Like  Finance 
Watch,  BETTER  FINANCE  also  has  a  weaker  membership  base  in  Eastern  Europe  than  in 
Western Europe. The organisation is considered to be particularly effective in providing input for 
policy-making  at  EU  level.  BETTER  FINANCE  provided  consultation  responses  to  a  high 
number  of  EU  consultations,  and  presented  its  policy  inputs  through  events,  publications,  and 
meetings.  It  also  delivered  high-quality  outputs  and  is  considered  to  be  very  efficient  in  using 
resources and producing outputs at low cost. Its social media presence was assessed as relatively 

2 

 
 
 
low,  albeit  increasing.  BETTER  FINANCE  also  launched  a  new  webpage  improving  its 
accessibility and user-friendliness.  

Advocacy  at  EU  level  on  behalf  of  non-industry  stakeholders  continues  to  be  indispensable  to 
ensure that the perspective of consumers and end-users is taken into consideration. Given their 
dependence on EU funding, Finance Watch and BETTER FINANCE would be unable to provide 
the same level of support for the interests of users of financial services without EU funding, and 
would  thus  be  unable  to  represent  consumer  interests  in  the  same  way.  Similarly,  without  EU 
grants to these two organisations, it is likely that other EU organisations would also be unable to 
fill  the  gap.  EU  funding  therefore  continues  to  be  necessary  to  increase  the  participation  of 
consumers in EU policy-making in the area of financial services.  

Besides Finance Watch and BETTER FINANCE, there are currently no alternative organisations 
at EU level covering a similar range of topics in financial services and in the same depth.  

2.  Introduction  

End-users  (in  particular  consumers)  and  organisations  representing  end-user  interests  do  not 
manage to participate in EU policy making to the same extent as industry. An important reason 
for this is the scarcity of resources and the lack of specialised expertise among financial services 
end-users and non-industry stakeholders. After the 2008 crisis, a number of initiatives were taken 
to  increase  the  level  of  active  participation  and  involvement  of  consumers  and  other  financial 
services end-users in EU policy-making.  

Following an initiative of the European Parliament, the Commission launched a pilot project at 
the end of 2011 to provide grants to support the development of a financial expertise centre. As a 
result,  between  2012  and  2015,  and  following  an  open  call  for  proposals,  the  Commission 
awarded  operating  grants  to  two  non-profit  entities:  Finance  Watch  and  BETTER  FINANCE. 
Those grants were first awarded under a pilot project lasting 2 years, and were then awarded in 
the form of a preparatory action.  

Based on a positive evaluation of the programme in 2015, the Commission tabled a legislative 
proposal  in  June  2016  to  set  up  a  Union  programme  to  continue  supporting  these  two 
organisations  from  1 May 2017  to  31 December 2020.  Regulation  (EU)  2017/826,  which 
established  this  programme,  was  adopted  by  the  co-legislators  in  May  2017.  It  identified 
BETTER FINANCE and Finance Watch as beneficiaries of the programme.  

The overall budget of the capacity-building programme is shared between the two organisations 
in light of their grant applications analysed by the Commission. On this basis, they received from 
the Commission the sums set out in the table below.  

3 

 
 
 
 
 
From  1 May 2017  
until 
31 December 2017 

2018 

2019 

Finance Watch 

EUR 629 058.56 

BETTER 
FINANCE 
* Pre-financing 

EUR 292 393.80 

EUR 
1 100 000.00 
EUR 390 552.84  EUR 

EUR 
957 898.54 

410 000.00 

January 
From 
2020 
until 
9 September 2020* 

EUR 618 750 

EUR 205 000 

For 2020, the final sum paid to both beneficiaries will likely be quite similar to previous years. 
The grant agreement allows for the payment of a maximum of EUR 1 043 048 to Finance Watch 
and EUR 410 000 to BETTER FINANCE, if the conditions are met.  

According to Article 7 of Regulation (EU) 2017/826, the maximum rate of direct co-financing is 
60% of eligible costs.  

Article 1 of the Regulation provides a basis for financing the following actions:  

a)  research  activities,  including  production  of  own  research  and  data,  and  development  of 

expertise; 

b)  engaging with consumers and other financial-services end-users by liaising with existing 
consumer networks and helplines in Member States to identify issues relevant for Union 
policy-making for protecting the interests of consumers in the area of financial services; 
c)  activities  to  raise  awareness,  dissemination  activities,  and  providing  financial  education 
and training – directly or through their national members – including to a wide audience 
of consumers, other financial-services end-users and non-experts; 

d)  activities reinforcing interactions between the members of the organisations referred to in 
Article  3(1),  as  well  as  advocacy  and  policy-advice  activities  fostering  the  positions  of 
those  members  at  Union  level  and  fostering  the  public  and  general  interest  in  financial 
and Union regulation. 

Article  9  of  Regulation  (EU)  2017/826  requires  the  Commission  to  submit  to  the  European 
Parliament  and  to  the  Council  a  report  evaluating  the  achievement  of  the  programme’s 
objectives. This is what the current report aims to provide.  

3.  Objectives of the evaluation and its methodology  

According to  Article 9 of Regulation  (EU) 2017/826,  the evaluation  report must assess:  (i) the 
overall relevance and added-value of the programme; (ii) the effectiveness and efficiency of its 
execution; and (iii) the overall and individual effectiveness of the beneficiaries’ performance in 
meeting the programme’s objectives. 

As set out in Article 2 of the Regulation, the objectives of the programme are: 

4 

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

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

To help with the assessment, the Commission commissioned a study (annexed to this report) on 
whether  the  grants  awarded  to  Finance  Watch  and  BETTER  FINANCE  had  achieved  the 
programme’s  objectives.  The  study  included  a  comprehensive  in-depth  analysis  of  the 
beneficiaries’  operations  as  co-financed  under  the  grant  agreements  for  2017  and  2018.  The 
study  is  based  on  several  sources,  collected  and  assessed  via  different  data-collection  streams: 
desk research, online surveys and stakeholder interviews. 

Desk research 

The  Commission’s  contractor  assessed  primary  sources,  such  as  annual  reports,  work 
programmes,  membership  surveys,  and  other  relevant  documents  demonstrating  key 
performance indicators.  This  was supplemented,  where  appropriate, with  EU, international  and 
national-level literature – including media articles – to provide further context to the analysis.  

Online survey 

The  contractor  conducted  online  surveys  on  BETTER  FINANCE  and  Finance  Watch.  The 
surveys  contained  a  specifically  tailored  set  of  questions  by  stakeholder  type.  There  were  five 
stakeholder  groups:  member  organisations,  banking  associations,  consumer  organisations, 
national  public  authorities  and  EU  public  bodies.  Both  surveys  were  open  for  responses  from 
7 October until 3 December 2019. The surveys were shared with 309 stakeholders and there were 
179 participants in total (58% participation).  

Interviews 

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

The  Commission  complemented  the  consultant’s  study,  in  particular  by  analysing  the  two 
beneficiaries’ activities and the execution of the programme in 2019. 

One of the key limitations for the evaluation was that only a very limited number of references to 
both  beneficiaries  can  be  found  in  secondary  literature.  The  desk  research  was  thus  largely 

5 

 
 
 
limited to information from the beneficiaries themselves (e.g. their annual reports). The surveys 
and interviews aimed to address this limitation.  

4.  Results of the evaluation  

a)  General presentation of the work of the beneficiaries between 2017 and 2019 

FINANCE WATCH  

Finance  Watch  is  an  international  non-profit  association  under  Belgian  law,  registered  on 
28 April 2011. The association currently has 13 staff members, slightly fewer than in 2017. It is 
structured  into  three  interlinked  divisions:  research  and  advocacy;  communications  and 
networks;  and  finance  and  operations.  All  departments  are  overseen  by  the  Secretary  General, 
the  board  and  the  members.  The  organisation  was  created  to  act  as  a  counterweight  to  the 
financial  industry’s  influence  by  representing  the  views  of  the  general  public  and  financial 
services end-users. Its mission is to defend the interests of civil society in the financial sector.  

Finance Watch’s membership has slightly increased since 2017. The organisation now has 110 
members:  78  full  members  (45  organisations  and  33  individual  members)  and  32  associate 
members  (among  which  are  22  organisations  and  10  individual  members).  The  members  are  a 
diverse  group  representing  academia,  labour  unions,  national  Finance  Watch  networks,  NGOs, 
and  charities  with  an  interest  in  consumer  empowerment.  Members  come  from  17  Member 
States (with a weaker membership base in Eastern Europe than in Western Europe) and 3 non-
EU countries.  

Finance  Watch  covers  a  wide  range  of  financial  topics,  including  retail  financial  services, 
banking,  non-performing  loans,  sustainable  finance,  fintech,  financial  markets,  financial 
supervision, capital markets union (CMU) and financial inclusion.  

Finance  Watch  is  largely  dependent  on  EU  funding:  in  2017-2019,  the  beneficiary  received 
EUR 2 686 957  from  the  Commission.  The  rest  of  its  funding  is  essentially  covered  through 
funding from third parties, which accounted for 39.4% of its total funding for eligible funds in 
2019 (with the MAVA Foundation2 being the main donor). 

BETTER FINANCE  

BETTER  FINANCE  (its  full  name  is  the  European  Federation  of  Investors  and  Financial 
Services  Users)  is  a  registered  public-interest  organisation  created  in  2009  in  Belgium.  The 
organisation  currently  has  8  staff  members  (2  more  than  in  2017)  BETTER  FINANCE  has  37 
member organisations. Its members include shareholder associations, national NGOs focusing on 

2  MAVA  Foundation  is  a  philanthropic  foundation  focusing  on:  (i)  the  conservation  of  biodiversity  in  the  Mediterranean,  West  Africa  & 
Switzerland; and (ii) promoting a sustainable economy. Until the end of 2019, Finance Watch was part of a MAVA Programme (Economics for 
Nature - E4N) focused on approaches to restoring and preserving natural capital. 
https://mava-foundation.org/ 

6 

 
 
 
 
 
                                                           
private  investors  or  consumer  protection,  retirement  funds,  and  consumer  associations.  Their 
members come from 18 EU Member States (with a weaker membership base in Eastern Europe 
than in Western Europe) and 5 non-EU countries. 

Given its membership structure, the policy focus of BETTER FINANCE covers a wide arrav of 
topics  that  are  relevant  to  retail  investors,  such  as:  investor  protection,  supervision  and 
enforcement,  financial  products  topics  (PRIIPs3,  UCITS4,  MiFID5,  etc.),  pension  topics  (IDD6, 
PEPP7,  IORPs  etc.),  transparency  of  cost  and  performance,  pre-contractual  disclosures,  advice, 
and distribution of retail investment products, shareholder rights, sustainable and digital finance 
etc. 

In 2017-2019, the beneficiary received EUR 1 092 947 from the Commission. For the share of its 
funding not covered by Commission grants,  BETTER FINANCE relies mainly on membership 
fees  and  partnership  contributions  (which  accounted  for  approximatively  37  %  of  its  total 
revenues in 2018-2019).  

b)  Evaluation according to the criteria  

Overall relevance and EU added value of the programme 

Advocacy at EU level on behalf of non-industry stakeholders continues to be necessary to ensure 
that  the  perspective  of  consumers  and  end-users  is  taken  into  consideration.  Given  that  a 
significant share of financial services legislation is adopted at EU level, organisations to defend 
consumer  interests  should  also  be  active  at  EU  level.  These  organisations  should  also  be 
supported by a broad membership base in the Member States.  

The Union programme allows these organisations to ensure they have the necessary expertise to 
effectively represent the interests of consumers and end-users in financial policy-making. Given 
their dependence on EU funding,  Finance Watch and  BETTER FINANCE  would be unable to 
provide the same level of support for the interests of users of financial services in the absence of 
EU  grants.  In  addition,  attracting  additional  funding  for  consumer  topics  remains  structurally 
difficult.  This  is  partly  due  to  the  wide  dispersion  of  the  interest  groups  and  the  marginal 
incentives for each individual. This is the case for BETTER FINANCE and Finance Watch, as it 
is for other organisations representing consumers. Without EU grants to these two organisations, 
it is unlikely that other EU organisations would be able to fill the gap.  

3 Packaged retail investment and insurance products (PRIIPs) 
4 Undertakings for collective investment in transferable securities (UCITS) 
5 Markets in Financial Instruments Directive (MiFID) 
6 Insurance distribution Directive (IDD) 
7 Pan-European Personal Pension Product (PEPP) 

7 

 
 
 
 
 
                                                           
In  order  to  ensure  the  active  participation  and  involvement  of  these  groups  in  EU  and  other 
multilateral  policy-making  in  the  area  of  financial  services,  it  is  necessary  to  continue  to  give 
these grants. 

BETTER FINANCE and Finance Watch have both been successful in positioning themselves as 
an important  voice for consumers in  the  area of  financial services, an  area in  which they have 
built up significant expertise. As the study showed, BETTER FINANCE and Finance Watch are 
largely  appreciated  by  stakeholders,  and  their  input  is  considered  to  be  of  high  quality.  Their 
activities  are  complementary  and  only  partially  overlap.  BETTER  FINANCE  focuses  on 
financial services users’ issues with a strong emphasis on investors and pension savers as well as 
on  sustainable  finance  and  digital  finance.  Finance  Watch  addresses  retail  financial  services 
more generally, but also other topics such as sustainable finance and prudential issues. Together, 
these  two  organisations  covered  most  of  the  consumer  or  user-related  topics  in  the  EU  policy 
debate on financial services in 2017-2019. 

Apart  from  Finance  Watch  and  BETTER  FINANCE,  there  are  currently  no  alternative 
organisations at EU level covering a similar range of financial-services topics in the same depth. 
Other  organisations  (e.g.  BEUC8,  COFACE9  or  AGE  Europe10)  represent  consumers,  but  their 
focus  is  not  exclusively  on  financial  services  and  they  may  not  have  the  same  level  of 
specialisation and expertise on the topic. Given the complexity and technical nature of financial 
services  legislation,  this  in-depth  knowledge  of  a  wide  range  of  financial  topics  is  required  to 
ensure that the interests of consumers can be adequately represented. 

The effectiveness and efficiency of the execution of the programme  

Due to the complexity of the legislative process, one cannot attribute an agreed legislative text, 
or  elements  thereof,  to  the  advocacy  of  a  single  organisation.  However,  it  is  clear  that  some 
amendments suggested by the beneficiaries during legislative negotiations were taken up by the 
legislator. For instance, some of the amendments suggested by BETTER FINANCE and Finance 
Watch  on  the  PEPP  proposal  were  adopted  by  the  legislators.  The  stakeholders  interviewed 
during the study considered that financial policy-making had been improved  as  a result of this 
programme. These stakeholders also indicated that policy-makers felt better informed as a result 
of the beneficiaries’ work.  

8 BEUC (Bureau Européen des Unions de Consommateurs) is the umbrella group for 44 independent consumer organisations from 32 countries. 
Their role is to represent them to the EU institutions and defend the interests of European consumers. 
https://www.beuc.eu/ 
9  COFACE  Families Europe  promotes  the  well-being,  health and  security  of  families and  their  members in a changing  society  and serve  as  a 
trusted entity for family mainstreaming and for the voice/needs of families in the EU and beyond. 
http://www.coface-eu.org/ 
10 AGE Platform Europe is a European network of non-profit organisations for people aged 50 and over, which aims to voice and promote the 
interests of EU citizens aged 50 and over and raise awareness on the issues that concern them most. 
https://www.age-platform.eu/about-age 

8 

 
 
 
 
                                                           
Finance Watch and BETTER FINANCE have provided important input to the financial policy-
making process, in particular through their contributions to public consultations, participation in 
important  Commission  and  ESA  expert  groups,  and  additional  publications.  Based  on  their 
research activities, the beneficiaries could  help  fill gaps in  the overall understanding of certain 
financial phenomena.  

Together, the beneficiaries have worked on most of the consumer- or user-related topics in the 
EU policy debate on financial services. BETTER FINANCE has typically covered work streams 
related to financial services users’ issues with a strong focus on investors and pension savers as 
well  as  sustainable  and  digital  finance.  Finance  Watch  has  covered  retail  financial  services, 
sustainable  finance  and  prudential  topics.  However,  some  stakeholders  argued  that  the 
beneficiaries could have covered certain topics in greater depth, e.g. the ESA review and credit 
assessment. 

To  inform  consumers,  raise  awareness  and  contribute  to  financial  education,  the  beneficiaries 
have made significant efforts to engage with consumers, including through the use of innovative 
tools, social media and campaigns.  

Overall  and  individual  effectiveness  and  efficiency  of  the  beneficiaries’  performance  in 
meeting the objectives 

FINANCE WATCH 

Effectiveness 

During  the  evaluation  period,  Finance  Watch  engaged  in  the  major  debates  and  policy 
developments in financial regulation. It covered a very broad array of topics including insurance, 
financial inclusion, sustainable finance and fintech. In particular, in 2017 Finance Watch worked 
on  topics  such  as  fintech,  MiFID  II,  non-performing  loans,  motor  insurance,  and  cross-border 
payments. In 2018 and in 2019, sustainable finance was a significant focus of the organisation. 
Other topics included financial inclusion and the Solvency II. Some stakeholders mentioned that 
Finance Watch could also have addressed additional topics such as corporate culture in financial 
institutions.  

Finance  Watch  also  provided  expertise  to  the  policy-making  process  in  different  ways,  in 
particular  through  replies  to  public  consultations  and  participation  in  Commission  and  ESA 
expert groups. In 2017-2019, Finance Watch responded to important consultations in its areas of 
expertise. It responded to 33 public consultations on financial policy. By way of illustration, in 
2017  the  organisation  provided  input  to  the  Commission  consultations  on  Fintech  and  on 
transparency and fees in cross-border transactions, to the REFIT review on motor insurance, to 
ESMA11  consultation  on  guidelines  for  suitability  requirements  under  MiFID  II.  In  2018,  it 

11 European Securities and Markets Authority (ESMA) 

9 

 
 
 
 
 
                                                           
responded  to  the  Commission  consultation  on  the  establishment  of  a  framework  to  facilitate 
sustainable investment and to a proposal for a directive on a new deal for consumers. In 2019, it 
for instance replied to consultations under the EU action plan on sustainable finance, to ESMA’s 
consultation on integrating sustainability risk and factors in MiFID and AIFMD/UCITS. It also 
provided input to the evaluation of the Consumer Credit Directive and to the EIOPA consultation 
on sustainability in the Solvency II. The consultant’s study provided evidence that the quality of 
these consultation responses was high.  

Finance Watch also continued to actively participate in the work of Commission and ESA expert 
groups through such as the EC Financial Services User Group, the EC Technical Expert Group 
on  Sustainable  Finance,  and  the  European  Insurance  and  Occupational  Pensions  Authority 
(EIOPA)  Consultative  Expert  Group  on  Digital  Ethics.  Its  participation  in  expert  groups12  has 
slightly increased during the period. Finance Watch held 5 positions in expert groups in 2017 and 
7 in 2018 and 2019.  

In addition, Finance Watch has been publishing briefings and papers at an increasing rate (4 in 
2017, 9 in 2018 and 13 in 2019) on different topics. For example, it published the briefing paper 
‘ESMA’s role in sustainable finance’ (in 2017), a policy brief on remittances (in 2018), and the 
policy brief ‘Insurance and discrimination’ (in 2019). During the European Parliament elections, 
Finance  Watch  prepared  briefings  for  candidates,  and  engaged  with  newly  elected  MEPs  to 
prepare  for  the  future  parliamentary  term.  During  2017-2019,  Finance  Watch  produced  24 
publications including several policy notes and discussion papers but also some comprehensive 
research  reports.  For  instance,  in  2018  it  published  the  second  edition  of  the  Global  green 
finance  index  (GGFI  2)  based  on  a  worldwide  survey  of  finance  professionals’  views  on  the 
quality and depth of green-finance offerings across 110 international financial centres.  

The  objective  of  engaging  end-users  and  non-industry  stakeholders  was  addressed  through 
campaigns, community events, videos, cartoons, etc. The number of events organised by Finance 
Watch increased in 2017-2019 (on average twelve events per year). It for instance organised the 
Change Finance Forum in 2018 (bringing together different experts to debate a variety of topics) 
which  was  particularly  effective  at  engaging  consumers.  Another  action  that  attracted 
considerable attention in 2019 was a campaign launched by Finance Watch on Facebook’s plans 
to introduce Libra, its own payment system/coin. The campaign sought to inform policy-makers 
and  the  public  about  risks  to  the  stability  of  the  financial  system,  and  gave  the  public  the 
opportunity to voice their concerns through a petition.  It has also produced a number of videos 
(49 videos during 2017-2019) to increase citizens understanding of financial issues. For example, 
in  2018  the  beneficiary  launched  several  short  videos  on  different  topics  such  as  capital 
requirements, sustainable finance, traders’ bonuses and excessive risk incentives. Finance Watch 

12 This figure only includes the participation in expert groups of Finance Watch representatives. It does not include the possible participation of 
experts belonging to Finance Watch member organisations, unless they would sit on the Group as Finance Watch representatives. 

10 

 
 
 
                                                           
was  also  able  to  increase  its  communication  potential  through  a  new  cartoons  tool,  which  was 
effective in targeting a wider public and non-expert stakeholders.  

Finance Watch informed the public about  issues at  stake in  the regulation of financial markets 
through its members and coordinated actions at national level. As highlighted by the interviewed 
stakeholders,  the  expertise  provided  by  Finance  Watch  was  used  in  stakeholders’  national 
debates.  In  a  few  cases,  these  stakeholders  translated  Finance  Watch  publications  into  their 
national language.  

The survey respondents rated the quality of Finance Watch’s communications activities as high, 
and  its  newsletter  was  particularly  valued  as  effective.  During  the  period,  Finance  Watch 
published  51  press  releases.  The  respondents  of  the  survey  considered  the  press  releases  as 
effective  in  informing  consumers.  Through  social  media,  Finance  Watch  shared  content  and 
reacted to various topics, such as climate change and the COVID-19 outbreak. It was evaluated 
as  particularly  effective  in  using  social  and  online  media,  and  achieved  greater  exposure  than 
other  similar  organisations.  Its  number  of  followers  on  social  media  significantly  increased  in 
2017-2019  and  Finance  Watch  currently  has  a  high  number  of  followers  compared  to  other 
similar organisations (it has 21 000 followers on Facebook, and 10 750 followers on Twitter). It 
also  increased  its  communication  potential  through  a  new  website.  In  addition,  Finance  Watch 
enjoys  very  widespread  international  media  coverage,  being  mentioned  in  374  articles  in  the 
international press from 2017 to 2019. 

Overall, the study showed that Finance Watch’s outputs are generally considered of high quality, 
including  by  officials  of  the  European  institutions,  Finance  Watch’s  members,  and  other 
stakeholders. 

Efficiency  
The study showed that,  during the evaluation  period, Finance Watch’s cost-to-output ratio was 
relatively stable.  From 2017 to  2018, the increase of expenditure on  expertise, policy analysis, 
advocacy  and  public  affairs  led  to  an  increase  in  the  number  of  outputs  (for  example  reports, 
briefings,  papers,  public  hearings,  public  interventions  and  videos).  In  other  areas  such  as 
communications, the cost-to-output ratio was also relatively stable, which indicates that the same 
level of efficiency was maintained.  

From  2018  to  2019,  expenditure  in  the  area  of  communications  marginally  increased.  The 
increase  in  the  number  of  communication  outputs  in  2019  compared  to  2018  (such  as  events, 
press releases, and the launch of a new website) indicated greater efficiency in  communication 
outputs.  

BETTER FINANCE 

11 

 
 
 
 
Effectiveness 
BETTER  FINANCE  provided  policy-makers  with  the  views  of  financial  services  end-users 
through its responses to public consultations, participation in expert groups, position papers, and 
discussions with different interest groups. Over the years, BETTER FINANCE covered a wide 
array  of  topics  relevant  for  financial  consumers.  In  2017,  a  significant  focus  of  BETTER 
FINANCE  was  on  pension  savings  and  ‘robo-investing’13.  In  2018,  it  inter  alia  focused  on 
topics involving the protection of investors and financial-services users and on compliance with 
the pre-contractual disclosure rules for packaged retail investment products.  In 2019, BETTER 
FINANCE  worked  on  topics  such  as  Collective  Redress,  MiFID  II,  PEPP,  PRIIPs,  UCITS, 
Solvency II, IDD, IORP, Capital Markets Union, Sustainable finance (taxonomy, ecolabel) and 
Digital Finance. 

In these 3 years, BETTER FINANCE was particularly effective. For instance, it replied to almost 
70  consultations.  The  public  consultations  covered  a  wide  range  of  topics,  in  particular  topics 
relevant  for  investors.  For  instance,  in  2017  BETTER  FINANCE  provided  input  to  ESMA’s 
consultation  on  MiFID  governance  requirements  and  to  the  consultation  on  the  format  and 
content  of  the  prospectus.  In  2018,  BETTER  FINANCE  inter  alia  replied  to  the  ESA’s  joint 
consultation  paper  on  amendments  to  the  PRIIPs  KID14  and  to  the  Commission’s  suitability 
questionnaire on environmental, social and governance (ESG) disclosure. In 2019, it responded 
to the ESMA consultation on integrating sustainability risks and factors in the UCITS Directive 
and AIFMD15. Beyond that, BETTER FINANCE also responded to consultations in the area of 
sustainable  and  digital  finance,  for  instance  the  Commission’s  consultation  on  rules  on  digital 
solutions  and  efficient  cross-border  operations,  as  well  EBA16's  consultation  on  the  Discussion 
Paper  on  its  approach  to  financial  technology  (fintech),  and  to  the  questionnaire  by  the  High-
Level Expert Group on sustainable finance. The respondents indicated that BETTER FINANCE 
covers  technical  areas  in  a  way  that  is  easy  for  consumers  and  end-users  to  understand.  In 
addition, BETTER FINANCE produced more than 15 position papers during the 3 years.  

BETTER  FINANCE  also  continued  to  participate  in  and  provide  input  to  expert  group 
discussions, for example the European Commission Financial Services User Group, the Banking 
Stakeholder Group (EBA), and the High Level Forum on Capital Markets Union and the PEPP 
Expert  Group  (EIOPA).  Its  participation  in  expert  groups17  has  slightly  increased  during  the 
period. BETTER FINANCE held 8 positions in expert groups in 2017, 8 in 2018 and 10 in 2019. 
BETTER  FINANCE  was  also  invited  to  speak  at  a  number  of  hearings,  for  example  in  the 
European Parliament on the PEPP proposal. 

13 investing according to advice given by a computer programme based on customer information such as their age, salary and risk tolerance 
14 Key information documents (KID) for packaged retail and insurance-based investment products (PRIIPs) 
15 Alternative investment fund managers Directive (AIFMD) 
16 European Banking Authority 
17 This figure only includes the participation in expert groups of Better Finance representatives. It does not include the possible participation of 
experts belonging to BETTER FINANCE member organisations, unless they would sit on the Group as Better Finance representatives. 

12 

 
 
 
                                                           
 
In  addition  to  policy  notes  and  discussion  papers,  BETTER  FINANCE  produced  a  number  of  
comprehensive research reports (4 in 2017, 7 in 2018 and 6 in 2019), identifying current issues 
that were relevant for consumer and financial services end-users. For instance, in 2017 it issued 
publications on ‘robo-advice’18 and pension savings. Moreover, it published reports on investor 
protection topics – that benefited from a follow-up by the European Parliament – in particular the 
Mis-selling  of  Financial  Products  Paper.  In  2018,  BETTER  FINANCE  published  the  research 
report Fund Benchmark Disclosure Compliance, which verified the compliance of key investor 
information documents (KIIDs) of selected UCITS funds investing in equities.  

The  objective  to  better  inform  consumers  was  addressed  through  campaigns,  events  and  press 
releases.  Between  2017  and  2019,  BETTER  FINANCE  published  more  than  70  press  releases 
providing  information  on  policy  and  regulatory  developments  at  the  European  level  affecting 
investors and financial services end-users. Through an increasing number of press releases in a 
variety of languages, the beneficiary ensured connection with the financial and general press. 

In  these  3  years,  BETTER  FINANCE  organised  an  average  of  eight  events  per  year  (such  as 
international  conferences and press  conferences), with  participation at  the events  growing each 
year.  For  example,  in  2019,  BETTER  FINANCE  and  the  CFA  Institute  jointly  organised  an 
international  conference  on  Sustainable  Value  for  Money.  BETTER  FINANCE  enjoys 
widespread  international  media  coverage,  being  mentioned  in  296  articles  in  the  international 
press from 2017 to 2019. 

BETTER FINANCE launched its new website at the beginning of 2019, giving visitors a more 
user-friendly interface and easier access to the most important information.  It also informed its 
members and stakeholders of the latest legislative and regulatory developments via a newsletter.  

The study indicated that the social media presence of BETTER FINANCE is relatively low (as 
compared to similar organisations). BETTER FINANCE social media accounts have  a limited, 
albeit  increasing,  number  of  followers  (452  followers  on  Facebook,  and  1  340  followers  on 
Twitter).  

Efficiency 
The study also analysed the organisations’ outputs, assessing them in quantitative and qualitative 
terms,  and  concluded  that  BETTER  FINANCE  produced  a  stable  level  of  output.  In  general, 
across the 3 years, there was an overall increase in activity in raising awareness, dissemination, 
financial  education  and  training.  Between  2017  and  2019,  BETTER  FINANCE  improved  its 
cost-to-output ratio in its other activities (for example research and advocacy).  

From  2018  to  2019,  expenditure  increased  in  raising  awareness,  dissemination,  financial 
education  and  training.  The  increase  in  the  number  of  outputs  (for  example  events  and  press 
releases) indicated that efficiency in this area was relatively stable.  

18 Financial advice given by a computer programme based on customer information such as their age, salary and risk tolerance 

13 

 
 
 
                                                           
5.   

Conclusion  

The evaluation shows that the objectives of the programme have generally been met.  

The  objective  of  further  enhancing  the  involvement  of  consumers  and  financial  services  end-
users  in  Union  policy-making  in  the  area  of  financial  services  was  achieved.  The  work  of 
Finance  Watch  and  BETTER  FINANCE  has  enriched  the  policy  debates.  These  two 
organisations  offered  an  alternative  point  of  view  that  policy-makers  could  have  otherwise 
missed  or  neglected.  Both  delivered  important  expertise  through  contributions  to  public 
consultations  and  participation  in  many  Commission  and  ESA  expert  groups.  They  presented 
their views to policy-makers in a variety of ways (including hearings, meetings, papers etc.).  

The objective of informing consumers and other financial-services end-users on issues at stake in 
the regulation of the financial sector has generally been achieved. Both beneficiaries have kept 
consumers informed, e.g. through campaigns, press releases, etc.  

In order to defend the interests of consumers and end-users, advocacy at EU level on behalf of 
non-industry stakeholders continues to be necessary.  

Given  their  dependence  on  EU  funding,  Finance  Watch  and  BETTER  FINANCE  would  be 
unable to provide the same level of support for the interests of users of financial services without 
EU funding and would thus be unable to represent consumer interests in the same way. Without 
EU grants to these two organisations, other EU organisations would also be unable to fill the gap. 
EU  funding  therefore  continues  to  be  necessary  in  order  to  increase  the  participation  of 
consumers in EU policy-making in the area of financial services.  

Besides Finance Watch and BETTER FINANCE, there are currently no alternative organisations 
at EU level covering a similar range of topics in financial services and in the same depth.  

14