COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document PROPOSAL FOR A DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on combating violence against women and domestic violence
Date: 2022-03-08
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: access to the courts, domestic violence, fight against crime, gender equality, help for victims, human rights, sexual discrimination, sexual violence, woman, women's rights

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 8.3.2022  SWD(2022) 62 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document PROPOSAL FOR A DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  on combating violence against women and domestic violence {COM(2022) 105 final} - {SEC(2022) 150 final} - {SWD(2022) 60 final} - {SWD(2022) 61 final} - {SWD(2022) 63 final}  
 
 
Contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................................................... 6 

PROBLEM DEFINITION ............................................................................................................................. 7 

2.1. 

WHAT ARE THE PROBLEMS? ........................................................................................................................ 7 
2.1.1 
Scope ............................................................................................................................................... 7 
2.1.2 Problem description ............................................................................................................................ 10 
2.1.3.  Who is affected? ............................................................................................................................ 24 
2.1.4.  Why is violence against women and domestic violence a problem? ............................................. 26 
WHAT ARE THE DRIVERS? ......................................................................................................................... 27 
Structural gender inequality and gender stereotypes ................................................................... 27 
Failure to recognise the specificities of crimes and offences relating to violence against women 

2.2.1 
2.2.2. 
and domestic violence ................................................................................................................................. 28 
HOW WILL THE PROBLEM EVOLVE? ............................................................................................................. 30 

2.2. 

2.3. 

3.  WHY SHOULD THE EU ACT? ................................................................................................................... 31 

3.1. 
3.2. 
3.3. 

LEGAL BASIS ........................................................................................................................................... 31 
SUBSIDIARITY: NECESSITY OF EU ACTION ..................................................................................................... 32 
SUBSIDIARITY: ADDED VALUE OF EU ACTION ................................................................................................ 33 

4. 

OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................................... 35 

4.1. 
4.2. 

GENERAL OBJECTIVES ............................................................................................................................... 35 
SPECIFIC OBJECTIVES ................................................................................................................................ 35 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ...................................................................................... 36 

5.1. 

WHAT IS THE BASELINE FROM WHICH OPTIONS ARE ASSESSED? ........................................................................ 36 
5.1.1.  Dynamic baseline: EU level measures ........................................................................................... 36 
Dynamic baseline: Member States measures ................................................................................ 38 
5.1.2 
OPTIONS DISCARDED AT AN EARLY STAGE ..................................................................................................... 39 
DESCRIPTION OF THE POLICY OPTIONS ......................................................................................................... 40 

5.2. 
5.3. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................................. 45 

6.1. 
6.2. 
6.3. 

6.3.1 
6.3.2 
6.3.3 

FUNDAMENTAL RIGHTS ............................................................................................................................ 46 
SOCIAL IMPACTS ..................................................................................................................................... 50 
ECONOMIC IMPACT ................................................................................................................................. 51 
Estimated benefits: reduction of costs of violence ........................................................................ 52 
Administrative and compliance costs for Member States and employers .................................... 54 
Summary of costs and economic benefits ..................................................................................... 58 

7. 

HOW DO THE OPTIONS COMPARE?....................................................................................................... 59 

7.1. 
7.2. 
7.3. 
7.4. 

EFFECTIVENESS ....................................................................................................................................... 60 
EFFICIENCY ............................................................................................................................................ 65 
COHERENCE ........................................................................................................................................... 66 
PREFERRED OPTION ................................................................................................................................. 66 

8. 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ......................................................... 67 

1 

 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

Asylum-seeking women and 
girls 

A woman or a girl who has left her country of origin to 
seek international protection. 

Child 

Coercive control 

Domestic violence 

Any person below 18 years of age. 

Oppressive  conduct  that  is  typically  characterised  by 
tactics  to  intimidate,  degrade,  isolate  and  control  the 
victim. Can be combined with physical abuse and sexual 
coercion. 

All acts of physical, sexual, psychological or economic 
violence that occur within the family or domestic unit, or 
between former or current spouses or partners, 
regardless of whether the perpetrator shares or has 
shared the same residence with the victim. Domestic 
violence can target anyone in the family unit and covers 
for instance women, men, children, older people and 
same-sex partners. 

Female genital mutilation 
(FGM) 

Procedures that involve partial or total removal of the 
external female genitalia, or other injury to the female 
genital organs for non-medical reasons. 

Forced abortion 

Gender 

Gender bias 

Gender stereotype 

Gender-sensitive policies 

Intentional termination of a pregnancy without the prior 
and informed consent of the victim (woman or girl). 

Socially constructed roles, behaviours, activities and 
attributes that a given society considers appropriate for 
women, men, girls and boys. This includes the 
relationship among and between these socially 
constructed norms, behaviours and roles.  

Prejudiced actions or thoughts based on the perception 
that women are not equal to men in rights and dignity. 

A generalised view about attributes or characteristics, or 
the roles that should be performed by women and men in 
a given society. A gender stereotype is harmful when it 
limits 
to  develop  personal 
abilities, pursue careers or make other life choices. 

individuals’  capacities 

that 

take 

the  particularities 
into  account 
Policies 
pertaining  to  the  lives  of  women  and  men,  in  all  their 
diversity,  while  aiming  to  eliminate  inequalities  and 
promote gender equality, including an equal distribution 
of  resources,  thus  taking  into  account  the  gender 
dimension. 

General support services 

Help offered through for instance social services, health 

2 

 
 
 
 
 
 
 
 
Secondary victimisation 

Sexual harassment 

So-called 
against women and girls 

“honour 

crimes” 

Specialist support services 

Trafficking in human beings 

services  and  employment  services.  General  support 
services  provide  short  and  long-term  help  and  are  not 
exclusively  designed  for  victims  of  violence  against 
women  or  domestic  violence,  but  serve  the  public  at 
large. 

When the victim suffers further harm due to the manner 
in  which  institutions  and  individuals  approach  the 
victim.  Secondary  victimisation  may  be  caused,  for 
instance,  by  repeated  exposure  of  the  victim  to  the 
perpetrator,  repeated  interrogation  about  the  same  facts 
or  the  use  of  inappropriate  or  insensitive  language  by 
those who come into contact with the victim. 

Any  form  of  unwanted  verbal,  non-verbal  or  physical 
conduct of a sexual nature, with the purpose or effect of 
violating  the  dignity  of  a  person,  in  particular  when 
creating  an  intimidating,  hostile,  degrading,  humiliating 
or offensive environment. 

Acts  of violence that are disproportionately,  though not 
exclusively,  committed  against  girls  and  women, 
because family members consider that certain suspected, 
perceived  or  actual  behaviours  bring  dishonour  to  the 
family or community. 

Support  services  targeted  to  victims  of  violence  against 
women  and  domestic  violence.  Specialist  support 
services can include social, emotional, psychological and 
financial support, as well as practical and legal support. 

the 

crime  which 

recruitment, 
consists  of 
A 
transportation,  transfer,  harbouring  or  reception  of 
persons. Control over the victim is  attained through the 
threat of force or use of force or other forms of coercion, 
of  abduction,  of  fraud,  of  deception,  of  the  abuse  of 
power or of a position of vulnerability, or of the giving 
or  receiving  of  payments  or  benefits  to  achieve  the 
consent of a person having control over another person. 
The purpose is the exploitation of the trafficked person. 
Exploitation includes, as a minimum, the exploitation of 
the  prostitution  of  others  or  other  forms  of  sexual 
exploitation. 

Victim 

Violence against women 

A  natural  person  who  has  suffered  harm,  including 
physical, mental or emotional harm or economic loss, as 
a result of violence against women or domestic violence, 
including child witnesses of such violence.   

is  a  woman  or 

All  acts  of  violence  that  are  directed  against  a  woman 
that  affect  women 
because  she 
disproportionately, which result or are likely to result in 
physical,  sexual,  psychological  or  economic  harm  or 
suffering  to  women,  including  threats  of  such  acts, 

3 

 
 
 
 
 
 
 
 
Women 

coercion  or  arbitrary  deprivation  of  liberty,  whether 
occurring in public or in private life. 

Women  and  girls  under  the  age  of  18,  in  all  their 
diversity. 

Term or acronym 

Meaning or definition 

CEDAW 

CFR 

CJEU 

DSA 

DV 

ECHR 

Convention  on  the  Elimination  of  Discrimination 
against Women 

Charter of Fundamental Rights 

Court of Justice of the European Union 

Digital Services Act 

Domestic violence 

European  Convention  for  the  Protection  of  Human 
Rights and  Fundamental Freedoms 

ECtHR 

European Court of Human Rights 

EIGE 

EPRS 

FGM 

FRA 

GREVIO 

Istanbul Convention 

TEU 

TFEU 

UNCRPD 

European Institute for Gender equality 

European Parliamentary Research Service 

Female genital mutilation 

Fundamental Rights Agency of the European Union 

Council of Europe’s Group of Experts on Action 
against Violence Against Women and Domestic 
Violence 

Council  of  Europe  Convention  on  preventing  and 
combating  violence  against  women  and  domestic 
violence 

Treaty on European Union  

Treaty on the Functioning of the European Union  

United  Nations  Convention  on  the  Rights  of  Persons 
with Disabilities 

VaW 

Violence against women 

4 

 
 
 
 
 
 
 
 
 
VRD 

WHO 

Victims’ Rights Directive 

World Health Organization 

5 

 
 
 
 
 
1.  1. 

Introduction: Political and legal context 

Violence  against  women  and  domestic  violence  are  widespread  across  the  European  Union 
and worldwide. When taking office, Commission President von der Leyen announced that the 
EU  should  do  all  it  can  to  prevent  violence  against  women  and  domestic  violence,  protect 
victims  and  punish  offenders.1  The  EU  Gender  Equality  Strategy  2020-20252  announces 
key actions for preventing and combatting violence against women and domestic violence in 
Europe  and,  in  particular,  a  legislative  proposal  tackling  such  violence.  The  need  to  tackle 
violence against women and domestic violence also figures prominently in the EU Strategy 
on the Rights of the Child (2021-2024)3, the EU Strategy on Victims’ Rights (2020-2025)4, 
the  LGBTIQ  Equality  Strategy  2020-20255,  and  the  Strategy  for  the  Rights  of  Persons 
with Disabilities 2021-20306.  The Gender Action Plan III7 makes the fight against gender-
based violence one of the priorities of the Union’s external action. Gender equality is also the 
second principle of the European Pillar of Social Rights8, which aims to ensure and foster 
equality of treatment and opportunities between women and men in all areas. 

At  international  level,  measures  to  counter  violence  against  women  and  domestic  violence 
have  been  called  for  since  the  1990s,  including  in  the  framework  of  the  United  Nations 
Convention on the Elimination of All Forms of Discrimination against Women (‘CEDAW’). 
The Council of Europe Convention on preventing and combating violence against women and 
domestic  violence  (‘Istanbul  Convention’)  is  the  first  instrument  in  Europe  to  set  binding 
standards  on  the  matter.  While  all  Member  States  have  signed  the  Convention,  to  date,  21 
Member States have become parties to it.9 This means that the remaining six Member States 
are not bound by the Convention’s standards.  

1 European Commission, A Union that strives for more. My agenda for Europe – By candidate for President of the European 
Commission, Ursula von der Leyen, 2019.  
2  European  Commission,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions. A Union of Equality: Gender Equality Strategy 2020-
2025, COM(2020) 152 final, 5 March 2020. 
3  European  Commission,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions. EU strategy on the rights of the child, COM(2021) 142 
final, 24 March 2021. 
4  European  Commission,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions. EU Strategy on victims’ rights (2020-2025), COM(2020) 
258 final, 24 June 2020.  
5  European  Commission,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions.  Union  of  Equality:  LGBTIQ  Equality  Strategy  2020-
2025, COM(2020) 698  final, 12 November 2020.  
6  European  Commission,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions. Union of Equality: Strategy for the Rights of Persons 
with  Disabilities  2021-2030,  COM(2021)  101  final,  3  March  2021.  Gender  equality  is  also  the  second  principle  of  the 
European Pillar of Social Rights, which aims to ensure and foster equality of treatment and opportunities between women and 
men  in  all  areas,  including  in  tackling  gender-based  violence.  See  European  Commission,  Communication  from  the 
Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of 
the Regions. The European Pillar of Social Rights Action Plan, COM/2021/102 final, 4 March 2021, at 19, 21. 
7 European Commission, Joint Communication to the European Parliament and the Council. EU Gender Action Plan (GAP) 
III – An ambitious agenda for gender equality and women’s empowerment in EU external action, JOIN(2020) 17 final, 25 
November 2020.  
8 https://ec.europa.eu/info/strategy/priorities-2019-2024/economy-works-people/jobs-growth-and-investment/european-pillar-
social-rights/european-pillar-social-rights-20-principles_en. 
9 All Member States have signed the Convention at the latest following the adoption of the Council Decision on the signing 
the Convention on behalf of the EU, COM/2016/0111 final. 

6 

 
 
 
 
                                                 
The Commission proposed in 2016 the EU’s accession to the Convention10, but this proposal 
has not yet been adopted by the Council and the accession negotiations have been blocked for 
several years. The EU’s accession is opposed by the six Member States that have not ratified 
the  Convention  due  to  a  political  backlash  against  it,  which  is  partly  caused  by 
misunderstandings of certain provisions and exacerbated by disinformation campaigns.11 On 6 
October 2021, the Court of Justice of the European Union (CJEU) issued its opinion on the 
EU accession to the Istanbul Convention.12 The CJEU clarified that the EU can accede to the 
Convention even if not all Member States have ratified it, but grants the Council discretion to 
wait with a vote until consensus has been reached. It is therefore not possible to predict when 
the  EU’s  accession  to  the  Istanbul  Convention  might  take  place,  and  how  many  Member 
States would eventually ratify the Convention. While finalisation of the EU’s accession to the 
Convention remains a key priority for the Commission, the measures of the present initiative 
are aimed at achieving the objectives  of the Convention within the areas  of EU competence 
until such accession has  taken place. Once the EU accedes to the Convention, this initiative 
will implement its provisions within such areas. 

This  initiative  builds  on  the  Istanbul  Convention  and  the  Commission’s  continued 
commitment  to  finalising  the  EU’s  accession.  To  reach  the  objectives  of  the  Istanbul 
Convention in the areas of EU competence, this initiative aims to fill in the gaps identified in 
the  EU  acquis  in  the  areas  covered  by  the  Convention.  It  aims  at  setting  up  minimum 
standards concerning the rights of this group of crime victims, binding on the Member States 
and  enforceable  by  the  Commission.  This  initiative  also  takes  into  account  recent 
developments  such  as  the  digital  transformation  and  lessons  learnt  from  the  COVID-19 
pandemic.  

The European Parliament has repeatedly called on the Commission to propose legislation on 
violence against women and domestic violence.13 In January 2021, it underlined the need for 
measures to address the disparities in laws and policies between Member States and called for 
an  EU  framework  directive  on  the  matter.14  The  Parliament  has  adopted  two  own-initiative 
reports, on adding gender-based violence as a new Euro-crime15 and on combatting gender–
based cyber violence.16  

2.  2. 

Problem definition 

2.1. 2.1. What are the problems? 

2.1.1 

Scope 

10 European Commission, Proposal for a Council Decision on the signing, on behalf of the European Union, of the council of 
Europe Convention on preventing and combating violence against women and domestic violence, COM(2016) 111 final, 4 
March 2016. 
11 In Bulgaria, the Constitutional Court considered in 2018 the Convention not to be compatible with the Constitution. 
12 Court of Justice of the European Union (Grand Chamber); opinion A-1/19 of 6 October 2021. 
13 See, for example: European Parliament, Resolution on the EU’s accession to the Istanbul Convention and other measures 
to combat gender-based violence, 2019/2855(RSP), 28 November 2019.  
14  European  Parliament,  Resolution  on  the  EU  Strategy  for  Gender  Equality,  2019/2169(INI),  21  January  2021.  For  more 
information on the relevant activities of the European Parliament, see: EPRS, Gender-based violence as a new area of crime 
listed in Article 83(1) TFEU – European added value assessment, 2021, p. 19. 
15 Resolution of 16 September 2021 with recommendations to the Commission on identifying gender-based violence as a new 
area of crime listed in Article 83(1) TFEU, (2021/2035(INL)). 
16 Combating Gender based Violence: Cyber Violence, 2020/2035(INL), to be voted in December plenary.   

7 

 
 
 
 
                                                 
This initiative covers violence against women, and domestic violence against any person. This 
corresponds to the scope of the Istanbul Convention.  Violence against women and domestic 
violence  are  commonly  addressed  together  both  in  the  Member  States  and  at  international 
level. This is due to their common features, as explained in detail under section 2.1.2 below. 

The key concepts used in this Impact Assessment follow established international definitions, 
which  have  been  incorporated  in  the  21  Member  States’  national  laws,  in  order  to  ensure 
consistency once the EU accession to the Istanbul Convention takes place. Violence against 
women hence  covers all acts of gender-based violence resulting in,  or likely to  result in, or 
threatening  physical,  sexual,  psychological  or  economic  harm  or  suffering  to  women, 
irrespective of whether they occur in public or in private.17 The term gender-based violence 
is  commonly  used  to  highlight  the  dynamics  and  drivers  behind  this  type  of  violence.  The 
terms gender-based violence and violence against women are often used interchangeably, as 
most violence against women is inflicted due to their gender. This Impact Assessment follows 
the approach of the Istanbul Convention and uses the term ‘violence against women’. 

Domestic  violence  occurs  within  the  household  either  between  intimate  partners  (intimate-
partner  violence)  or  between  other  household  members,  including  inter-generationally 
between  parents  and  children.  Thus,  domestic  violence  covers  not  only  women,  but  any 
person  living  in  the  household,  including  men,  older  people,  same-sex  partners,  non-binary 
persons18, and children.  
Most  forms  of  violence  against  women  and  domestic  violence  are  criminal  acts19  under 
national  law  and  such  violence,  when  targeted  at  women,  is  a  form  of  sex-based 
discrimination.  

In order to meet the objective of the Istanbul Convention effectively, this initiative takes into 
account the fast pace of the current digital transformation; it further deals with cyber-violence 
and  sexual  harassment,  in  particular  at  work.  Although  such  types  of  violence  are  not 
explicitly covered by the Istanbul Convention, cyber violence against women and intimate 
partner cyber violence have become increasingly common in recent years.20 Cyber violence 
against women refers to  online content or activity  which targets  the victim because she is  a 

17 United Nations, Declaration on the Elimination of Violence against Women, Proclaimed by General Assembly resolution 
48/104 of 20 December 1993, Article 1; CEDAW, General Recommendation No. 19: Violence against women – Background, 
1992;  CEDAW,  General  Recommendation  No.  35  on  gender-based  violence  against  women,  updating  general 
recommendation No. 19, CEDAW/C/GC/35, 26 July 2017, at 1-2; Istanbul Convention Article 3(1)(a).  
18 While most people – including most transgender people – are either male or female, some people do not neatly fit into 
these categories. They use different terms to describe themselves, with non-binary being one of the most common, see 
National Center for Transgender Equality; https://transequality.org/issues/resources/understanding-non-binary-people-how-
to-be-respectful-and-supportive. 
19 For relevant national criminalisations, see  European network of legal experts in gender equality and non-discrimination. 
Criminalisation of gender-based violence  against  women  in European States,  including  ICT-facilitated  violence.  A  special 
report,  2021,  available  at  https://www.equalitylaw.eu/downloads/5535-criminalisation-of-gender-based-violence-against-
women-in-european-states-including-ict-facilitated-violence-1-97-mb (EELN 2021). 
20  HRC,  Report  of  the  Special  Rapporteur  on  Violence  against  Women,  Its  Causes  and  Consequences  on  online  violence 
against  women  and  girls  from  a  human  rights  perspective,  A/HRC/38/47,  14  June  2018,  p.  12;  NATO  Strategic 
Communications  Centre  of  Excellence  2020.  Abuse  of  power:  coordinated  online  harassment  of  Finnish  Government 
Ministers, p. 10.  

8 

 
 
 
 
 
                                                 
woman or targets women victims disproportionately.21 Cyber violence can also be perpetrated 
between  current  or  former  intimate  partners.22  Cyber  violence  can  take  a  variety  of  forms, 
ranging  from  cyber  stalking  and  non-consensual  sharing  of  private  and  intimate  images  or 
personal  data  to  sexual  cyber  harassment.23  Experiences  of  online  and  offline  violence  are 
often interlinked. Cyber violence against women is a part of the continuum of the violence 
victims  experience  offline.  Sexual  harassment  is  included  as  it  is  currently  covered  by  a 
number of gender equality directives which have proven not to be effective in preventing and 
combatting this type of violence against women (see gap analysis, Annex 8). 

Violence  against  women  and  girls  is  a  specific  phenomenon  in  that  its  drivers  are  different 
from  other  types  of  violence  (see  section  2.2  below).  Gender-based  violence  may  affect 
both  women  and  men,  but  women  are  disproportionately  affected  (see  section  2.1.3. 
‘Who  is  affected’  for  details).  This  is  the  case  in  particular  for  sexual  violence.24  Violence 
against  women  is  rooted  in  structural  inequalities  between  women  and  men  and  is  the 
manifestation  of  historically  unequal  power  relations,  which  have  led  to  discrimination 
against women.25 Violence against women is often driven by misogyny. As explained in more 
detail in section 2.2.2, violence against women entails certain specificities, such as taking 
place  in  the  private  sphere,  suffering  from  systemic  under-reporting,  disrupted  criminal 
proceedings, the commonly sexual nature of crimes and/or a high prevalence of elements of 
coercive  control.26  These  elements  are  different  compared  to  most  violence  experienced  by 
men. For instance, violence against men usually occurs in public settings, is not usually of a 
sexual nature, and is generally perpetrated by other men.27 Men are also frequently victims of 
other types of violence, but are much less often victims of violence targeting them because of 
their  gender.28  Also  the  consequences  of  violence  against  women  include  specificities, 
especially in regard to social consequences, which requires targeted action. Violence against 
women  negatively  impacts  the  physical  health  of  the  victims.  Sexual  violence  exposes 
women to sexually-transmitted diseases, unintended pregnancies, abortions and miscarriages, 
and  lowers  women’s  control  over  their  reproductive  health.29  Violence  against  women  and 

is 

for 

online 

innovation 

international 

gender-based 

21  See  HRC,  Report  of  the  Special  Rapporteur  on  online  violence  against  women  and  girls,  at  23.  European  Parliament 
Research Centre, Combating gender-based violence: cyber violence. European added value assessment, 2021, at 4-7. Also 
Centre 
violence, 
(CIG),  What 
governance 
https://www.cigionline.org/multimedia/what-is-online-gender-based-violence/. 
22 CyberSafe. Cyber violence against women and girls. Final report 2021, pp. 29- 34.   
23 Council of Europe Cybercrime Convention Committee (C-TY) 2017, Mapping study on cyber violence (T-CY (2017)10), 
at  6.  European  Institute  for  Gender  Equality  (EIGE),  Cyber  violence  against  women  and  girls,  2017.  GenPol  Gender  & 
Policy Insights 2019. When technology meets misogyny. Multi-level, intersectional solutions to digital gender-based violence, 
p. 16. 
24  More than 9 in 10 rape victims and more than 8 in 10 sexual assault victims were girls and women, while nearly all those 
imprisoned for such crimes were male (99%). Eurostat, Violent sexual crimes recorded in the EU, 2018. See 
https://ec.europa.eu/eurostat/web/products-eurostat-news/-/EDN-20171123-1. 
25 Council of Europe, Explanatory Report to the Council of Europe Convention on preventing and combating violence against 
women and domestic violence, 2011. 
26 FRA, Violence against women: an EU-wide survey. Main results report, 2014; EPRS, Combating gender-based violence: 
Cyberviolence, European added value assessment, 2021 
27 FRA, Crime, Safety and Victims’ Rights, 2021. 
28 FRA, Crime, Safety and Victims’ Rights, 2021. 
29 World Health Organization, London School of Hygiene and Tropical Medicine, South African Medical Research Council. 
‘Global and regional estimates of violence against women: Prevalence and health effects of intimate partner violence and 
non-partner sexual violence’. Geneva, Switzerland: World Health Organization, 2013. 

9 

 
 
 
 
 
                                                 
domestic violence also increase the probability of mental health problems,30 linking to higher 
rates  of  depression,  post-traumatic  stress  disorder,  anxiety,  alcohol  and  drug  abuse,  and 
suicidal ideation.31 In light of the above, the scope of the initiative focuses on violence against 
women,  as  this  manifestation  of  structural  gender  inequality  with  its  specific  consequences 
requires  a  targeted  approach,  but  includes,  in  relation  to  domestic  violence,  also  men.  Male 
victims  of  other  types  of  violence  than  domestic  violence  are  covered  under  the  Victims’ 
Rights Directive that is applicable to all victims of crime and the Gender Equality Directives 
as regards harassment.  

Violence on the basis of other grounds of discrimination than sex is not part of the primary 
scope  of  the  current  initiative.  This  does  not  mean  that  such  violence  does  not  merit 
addressing. However, as set out above the dynamics and consequences of violence against 
women  and  domestic  violence  require  a  specific  approach.32  Nevertheless,  special 
measures address the intersection of sex with other grounds of discrimination included in the 
Treaties, such as racial or ethnic origin, disability, religion or belief, age or sexual orientation. 
Also, the provisions regarding domestic violence include victims of such violence in all their 
diversity, 
tackle  violence  and 
discrimination based on other grounds than sex are included in relevant sectoral EU initiatives 
and  legislation.33  However,  while  this  initiative  would  oblige  Member  States  to  implement 
minimum  standards  concerning  violence  against  women  only  in  relation  to  this  group  of 
victims, Member States would be encouraged to extend all measures to men and non-binary 
people. 

including  non-binary  people.  Specific  measures 

to 

2.1.2 Problem description 

a)  High prevalence of violence against women and domestic violence in the EU 

Violence  against  women  and  domestic  violence  are  widespread  across  the  EU.  Their 
prevalence  and  scale  have  been  examined  most  comprehensively  in  the  2014  survey  on 
violence against women34 of the Fundamental Rights Agency of the European Union (FRA), 
and  confirmed  in  multiple  studies  and  surveys  carried  out  since  then.35  These  include  the 

30 Magnusson Hanson, Nyberg, Mittendorfer-Rutz, Bondestam, Madsen: ‘Work related sexual harassment and risk of suicide 
and suicide attempts: prospective cohort study’, 2020, BMJ2020;370:m2984.  
31  J.  Mannel  & S.  Hawkes,  ‘Decriminalisation of  gender-based  violence  is  a  global health  problem’,  Journal  BMJ  Global 
Health, Vol. 2(3), 2017, pp. 1-3. 
32 For example, while violence against women is most often perpetrated by a family member or relative (Supra 16), victims 
of violence motivated by racism usually do not know the perpetrators (FRA, Being Black in the EU: Second European Union 
Minorities and Discrimination Survey – Summary, 2019).  
33 E.g. Council Directive 2000/78 of 27 November 2000 establishing a general framework for equal treatment in employment 
and occupation; Council Directive 2000/43 of 29 June 2000 implementing the principle of equal treatment between persons 
irrespective of racial or ethnic origin. 
34 FRA, Violence against women: an EU-wide survey. Main results report, 2014; EPRS, Combating gender-based violence: 
Cyberviolence, European added value assessment, 2021. The FRA survey on violence against women is based on face-to-face 
interviews with 42,000 women across the EU. The survey presents the most comprehensive survey worldwide on women’s 
experiences of violence. 
35 An overview of the most recently available data is included in Annex 6. 

10 

 
 
 
 
 
 
                                                 
recent  FRA survey on crime victims published in  February 202136 and  administrative data 
gathered by the European Institute for Gender Equality (EIGE) from national authorities.37  

According  to  the  2014  FRA  survey,  one  woman  in  three  aged  15  or  above  reported  having 
experienced  some  form  of  physical  and/or  sexual  violence  in  the  EU.  One  in  10  women 
reported having been victim to some form of sexual violence, and one in 20 had been raped. 
Just  over  one  in  five  women  have  suffered  physical  and/or  sexual  violence  from  either  a 
current  or  previous  partner,  whilst  43%  of  women  have  experienced  some  form  of 
psychologically  abusive  and/or  controlling  behaviour  when  in  a  relationship.  While  both 
women  and  men  experience  cyber  violence  and  harassment,  women  are  overrepresented 
among victims of  cyber  violence perpetrated  based on the victim’s sex, in  particular  sexual 
forms  of  cyber  violence.38  In  addition,  women  and  girls  more  often  report  serious  and 
disturbing  forms  of  such  violence,  and  report  feeling  more  vulnerable  after  such  violence 
and  more  harshly  judged  as  victims.39  Usage  of  the  internet  and  social  media  increases  the 
risk  of  cyber  violence.40  In  a  global  2017  survey  on  online  abuse  in  eight  countries,  on 
average 23% of women reported having experienced abuse or harassment online.41 The 2014 
FRA  survey  suggested  that  20%  of  women  aged  18–29  years  old  had  experienced  cyber 
violence since the age of 15.42 In 2020, the World Wide Web Foundation found that 52% of 
young  women  were  affected  and  over  80%  were  of  the  opinion  the  phenomenon  was 
increasing.43  In  a  recent  study,  more  than  50%  of  all  respondents  replied  they  did  not  dare 
express political opinions due to fear of online targeting.44 Data from 2017 illustrate that 70% 
of  women  victims  of  cyber  stalking  also  experienced  at  least  one  form  of  physical  or/and 
sexual  violence  from  an  intimate  partner  (see  section  2.1.1  above).45  Experiences  of  online 
and offline violence are often interlinked, showing that it is important to tackle them together. 

Women  also  experience  violence  at  work.  About  a third  of  women  who  have  faced  sexual 
harassment  in  the  EU  experienced  it  at work. According  to  the  FRA  survey,  32%  of 
perpetrators  of  sexual  harassment  faced  by  women  since  they  were  15  were  from  the 
employment  context  such  as  colleagues,  supervisors  or  clients.46  When  asked  whether  the 

36 FRA, Crime, Safety and Victims’ Rights, 2021. This survey collected data from 35,000 people and focuses on respondents’ 
experiences as victims of selected types of crime, including violence and harassment. 
37 EIGE, Gender Statistics Database, available at: (https://eige.europa.eu/gender-statistics/dgs). 
38 GenPol Gender & Policy Insights 2019, p. 14. CyberSafe 2021, pp. 30-33, 72, referring to the DeShame project on online 
sexual harassment and violence, https://www.childnet.com/our-projects/project-deshame.  
39 CyberSafe 2021, pp. 38-39,  
40 CyberSafe 2021, p. 24.  
41 CyberSafe. Cyber violence against women and girls. Final report 2021, pp. 30-33. See however also EPRS 2021, pp. 7-8, 
where EU-level estimates of 1% to 7% were obtained for women’s experiences of cyber harassment and cyber stalking in 
EU-27.  
42 Supra 34, p. 104; EPRS, Gender-based violence as a new area of crime listed in Article 83(1) TFEU  – European added 
value assessment, 2021, p. 19.  
43 Web Foundation, “The online crisis facing women and girls threatens global progress on gender equality”, World Wide 
Web Foundation Blog, 12 March 2020. 
44  IDZ,  #Hass  im  Netz  –  der  schleichende  Angriff  auf  die  Demokratie,  2019,  pp.  6,  22,  23.  Women  respondents  reported 
expressing their political opinions less often than men (54% and 47%).  
45 EIGE, Cyber violence against women and girls, 2017, according to which 1044 women have suffered one or more of the 
three forms of cyber stalking and out of those  women, 727 have experienced at least one or more forms of physical or/and 
sexual violence from an intimate partner. As part cyber harassment, out of 677 women who stated having suffered at least 
one of the three forms identified as cyber harassment, 518 (77 %) have also experienced at least one form of physical or/and 
sexual violence from an intimate partner. 
46 FRA, 2014, p. 113. 

11 

 
 
 
 
 
                                                 
perpetrator  of  sexual  harassment  was  male  or  female,  71%  of  victims  indicated  that  the 
perpetrator of an incident since the age of 15 was a man, 2% indicated a female perpetrator 
and 21% pointed to both male and female harassers. The results reflect that, although the sex 
of many perpetrators is unknown because of the nature of harassment  – such as through the 
internet – this form of violence against women is perpetrated mostly by men.47  

The  administrative  data  collected  by  EIGE  shows  that  the  prevalence  of  violence  against 
women  and  domestic  violence  may  be  estimated  at  21.2%  (2019  figures),  i.e.  one  in  five 
women  in  the  EU  experienced  violence  against  women  or  domestic  violence.  This  figure  is 
based on administrative data and only includes acts reported to the authorities. The severity, 
i.e. the percentage of women who experienced health consequences of physical and/or sexual 
violence, was estimated at 46.9%. The rate of disclosure to anyone of this kind of violence 
was  estimated  at  14.3%.  It  follows  that  almost  half  of  these  incidences  cause  health 
consequences for the victims but less than one in seven of them is reported.  

Since  the  outbreak  of  the  COVID-19  pandemic,  violence  against  women  and  children, 
particularly domestic violence, has increased.48 Stakeholders noted an increase in contact to 
helplines for victims of violence against women and domestic violence during the pandemic; 
an  increase  in  the  demand  for  specialised  support  services  (emergency  accommodation, 
counselling services); an increase of reports to law enforcement and in numbers of emergency 
protection  orders  issued  in  cases  of  such  violence,  while  support  services  were  required  to 
reduce or temporarily stop work; an increase in risk factors for violence due to the pandemic 
(e.g. isolation, stress, working from home), coupled with a decrease in accessibility of victim 
support. Even if measures were taken to address this rise in violence, many victims were not 
in  a  position  to  look  for  help.  This  was  often  because  victims  were  forbidden  from  leaving 
their  homes,  but  also  subject  to  technological  control  such  as  webcams,  smart  locks  or  a 
control via social media.49 Pending the end of the pandemic and the full manifestation of its 
social  and  economic  consequences,  it  is  still  unclear  whether  this  increase  in  incidence  is 
temporary (e.g. an increase in intensity) or indicative of a trend. Although both the EU and 
its Member States, have taken measures to prevent and combat violence against women 
and  domestic  violence,  significant  gaps  remain,  both  at  the  level  of  legislation  and  its 
implementation. 

b)  Gaps at national level 

The studies carried out in support of this impact assessment50 show the fragmentation of the 
national  regulatory  frameworks.  The  heterogeneity  of  the  existing  measures  correlates  with 
different legal, historical and political traditions of the Member States. Standards of protection 

47 Ibid.   
48 EIGE, The Covid-19 pandemic and intimate partner violence against women in the EU, 2021; WHO, “The rise and rise of 
interpersonal  violence  –  an  unintended 
the  COVID-19  response  on  families”,  2020,  available  at: 
(https://www.euro.who.int/en/health-topics/disease-prevention/violence-and-injuries/news/news/2020/6/the-rise-and-rise-of-
interpersonal-violence-an-unintended-impact-of-the-covid-19-response-on-families).  
49 See: E. Arenas-Arroyo, D. Fernandez Kranz & N. Nollenberger, “Intimate Partner Violence under Forced Coexistence and 
Economic Stress: Evidence from the COVID-19 Pandemic”, Journal of Public Economics, Vol. 194, 2020.  
50 See EELN 2021 and the supporting study conducted in support of this initiative. 

impact  of 

12 

 
 
 
 
 
  
                                                 
vary  significantly  between  the  Member  States  and  the  rights  of  victims  of  violence  against 
women  and  domestic  violence  are  not  always  enforced  in  practice.  This  leads  to  unequal 
protection depending on where in  the EU violence against women  and domestic violence  is 
experienced.  It  is  also  problematic  in  situations  where  the  victim  moves  or  otherwise 
exercises their right to free movement in the EU. The gap analysis in Annex  8 provides a 
detailed  assessment  of  gaps  in  the  relevant  EU  and  national  legislation  as  well  as  the 
shortcomings  in  its  implementation.  The  main  gaps  at  national  level  are  presented  below, 
structured into the five problem areas which have been identified as relevant by the Istanbul 
Convention: prevention, protection, access to justice, victim support and policy coordination. 
Gaps at EU-level are set out in section c) below. 

 Ineffective prevention of violence 

All  Member  States  have  introduced  prevention  measures.  In  response  to  the  targeted 
consultation,  23  Member  States  reported  having  organised  awareness  raising  campaigns51 
on  violence  against  women  and/or  domestic  violence.  This  is  supported  by  the  public 
consultation.  In-country  research,  however,  highlights  a  number  of  shortcomings  with  the 
existing  campaigns,  namely  that  they  do  not  reach  target  groups  meaningfully,  with  little 
emphasis on the right to be protected against violence against women and domestic violence. 
The Council of  Europe’s Group of Experts on Action against Violence  against Women and 
Domestic  Violence  (‘GREVIO’)  has  also  noted  challenges  related  to  awareness-raising 
programmes.52  Although  there  are  some  good  measures  in  place,  they  tend  to  focus  on 
domestic  violence,  are  too  short-term  and  do  not  sufficiently  target  the  problem  of 
intersectionality.  According  to  the  gap  analysis  (see  Annex  8),  there  is  also  a  lack  of 
awareness-raising initiatives to tackle underlying stereotypical attitudes (BE, IT, NL, PT)53 as 
well as insufficient teaching material on gender equality (FI, IT, MT, SE)54. 

Training  is  important  to  increase  professionals’  skills  to  recognise  victims.  While  general 
training is widely available to professionals,55 targeted violence against women and domestic 
violence  trainings,  particularly  concerning  the  interactions  of  police  and  judicial  authorities 
with victims, are lacking. Moreover, trainings are not compulsory in most Member States for 
several categories of professionals. They are also not institutionalised and not available in the 
same manner and frequency for all categories. While police, judges, lawyers, and prosecutors 
are the most likely to receive training, few Member States provide  other personnel in public 
administration who come into contact with victims with training.56 Lack of training of social 
workers and relevant court appointed professionals has been identified as insufficient in some 
Member  States  (FR,  IT,  MT,  PT).57  Many  Member  States  have  insufficient  initial  and  in-
service trainings and lack of guidelines based on a gendered understanding of violence against 

51 Also research evidence supports the effectiveness of awareness campaigns in inducing victims of violence to seeking help. 
See: M. Colagrossi, C. Deiana, A. Geraci & L. Giua, “Hang Up on Stereotypes: Domestic Violence and Anti-Abuse Helpline 
Campaign”, HEDG Working Paper Series, 2020. 
52  GREVIO,  Mid-term  Horizontal  Review  of  GREVIO  baseline  reports,  2021,  pp.  54-57,  available  at: 
(https://rm.coe.int/horizontal-review-study-2021/1680a26325).  
53 Gap Analysis in Annex 8, GREVIO submission targeted consultation, p. 2.  
54 GREVIO submission targeted consultation, at para. 3  
55 Targeted consultation to Member States, question 11. 
56 Supra 52, p. 65. GREVIO highlights the need for initial and in-service training for all relevant professions to be systematic 
and compulsory.  
57 Gap Analysis in Annex 8, GREVIO submission targeted consultation, para. 11, 79. 

13 

 
 
 
 
                                                 
women  and  domestic  violence  (AT,  BE,  DK,  FI,  FR,  IT,  MT,  NL,  PT,  ES,  SE58).  Staff  of 
relevant  services  should  likewise  be  aware  of  the  effects  of  domestic  violence  on  children, 
including of witnessing domestic violence (FR, IT). 

Work with perpetrators to prevent re-offending, as well as with men and boys at risk of 
offending,  has  a  positive  impact  on  combating  violence  against  women  and  domestic 
violence.59  While  all  but  one  Member  State  (HU)  have  set  up  support  programmes  for 
perpetrators  of  violence  against  women  and  domestic  violence,  these  programmes  are  often 
not  structured, primarily targeting domestic violence and not  always compulsory.60  In many 
Member States, programmes for perpetrators are not sufficiently available or suffer from low 
attendance (DK, IT, PT, AT, FI, MT, NL).61 

Regarding  sexual  harassment  at  work,  the  gap  analysis  identified  shortcomings  in  the 
effectiveness  of  the  implementation  of  the  Gender  Equality  Directives,62  which  require 
Member States to take measures to prevent all forms of sex-based discrimination in the areas 
of  employment  and  access  to  and  supply  of  goods  and  services.63    They  however  do  not 
contain  explicit  provisions  on  preventing  such  harassment.  Gaps  identified  in  the  Member 
States  include  insufficient  knowledge  of  the  issue  by  relevant  professionals.64  EU  law  does 
not include explicit obligations on the prevention of cyber violence against women either.65  

 Ineffective protection from violence  

Many  Member  States  have  made  efforts  to  put  measures  in  place  to  protect  victims  of 
violence  against  women  and  domestic  violence,  including  against  intimidation  or 
retaliation  by  the  perpetrator,  but  these  are  insufficient  in  some  Member  States.66  While 
mid- and long-term protection orders are available in all Member States, these orders are not 
always effective. In addition, emergency protection or barring orders where the police are 
allowed to prevent an alleged or potential perpetrator of violence from entering the victim’s 
apartment  and  its  immediate  surroundings,  are  available  only  in  18  Member  States.67  Even 
where protection orders are available, their practical application remains low. Factors which 
might contribute to this are notably the length of proceedings and the limited enforcement of 

58 Gap Analysis in Annex 8. 
, GREVIO submission targeted consultation, para. 11, 78-79. 
59  Audra  J.  Bowlus  and  Shannon  Seitz,  2006,  ‘Domestic  Violence,  Employment,  And  Divorce’,  International  Economic 
Review, vol. 47(4), pp. 1113-1149. 
60  More  perpetrator  programmes  are  available  in  prisons.  Interview  with  European  Network  for  Work  with Perpetrators 
(WWP EN), 2 July 2021.  
61 Gap Analysis in Annex 8, GREVIO submission targeted consultation, para. 22. 
62 See also: Council Directive 2004/113/EC implementing the principle of equal treatment between men and women in the 
access to and supply of goods and services, 13 December 2004; Directive 2010/41/EU on the application of the principle of 
equal  treatment  between  men  and  women  engaged  in  an  activity  in  a  self-employed  capacity,  7  July  2010.  Also  Council 
Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health 
of workers at work, OJ L 183, 29.6.1989, pp.1-8. 
63 EELN, ‘Criminalisation of gender-based violence against women in European States’, 2021, p. 82; EELN, ‘Harassment 
related 
at: 
33  European  Countries’, 
in 
https://op.europa.eu/en/publication-detail/-/publication/e06dcc86-b7bf-459e-8241-47502ef379c4.  
64 EELN 2021, p. 77. 
65 EPRS, ’Combatting gender-based violence: cyber violence’, 2021, pp. 12-13.  
66 In the 2001 British Crime Survey, 36% of women and 31% of men who had fallen victim to domestic violence reported 
being intimidated, e.g. not to report the violence. 
67 AT, BE, BC, CZ, DE, DK, FI, HR, HU, IE, IT, LV, LU, NL, PO, RO, SI, SK. In most other Member States, protection 
orders could be applicable in some emergency situations, but legislation does not cover all situations of this kind of violence, 
e.g. FR, PT. 

Sexual  Harassment  Law 

available 

2011, 

and 

Sex 

to 

14 

 
 
 
 
 
                                                 
the  measures,  in  particular  insufficient  sanctions  for  breaches  of  the  orders  and  a  lack  of 
awareness  on  their  availability.  In  some  Member  States,  there  is  a  lack  of  effective  and 
immediate protection after reporting (AT, EE, DE, NL, PL, PT).68 Also, victims who move or 
travel abroad risk losing protection, since the wide divergence of national measures remain 
an  obstacle  to  the  recognition  of  measures  issued  in  their  home  country  in  other  Member 
States.  

As set out in detail in the gap analysis (Annex 8), an individual assessment of the specific 
protection  needs  of  victims  of  violence  against  women  and  domestic  violence  is  absent  in 
eight  Member States (CZ,  BE, EE,  LU, MT, RO, SI and SK).69  Measures ensuring  specific 
protection of child victims or witnesses of  violence against women  and domestic violence 
also remain insufficient. Relevant professionals lack appropriate training to provide protection 
and  support  in  a  child-friendly  manner  (FR,  IT),  sufficient  psychological  counselling  is  not 
provided for child witnesses (AT, FI, FR, ES) and child witnesses are not always considered 
victims of violence.70 Reporting of violence by children should be child-friendly71, and there 
should be a possibility for visits  with  family members suspected of this  kind  of violence to 
take  place  in  a  safe,  surveyed  place  and  in  the  best  interest  of  the  child72  (arrangements  in 
place e.g. in ES, FI, DE, MT).73 

 Ineffective access to justice for victims of violence  

Several  shortcomings  limit  access  to  justice  for  victims  of  violence  against  women  and 
domestic  violence.74  While  the  majority  of  violence  against  women  and  domestic  violence 
offences are criminalised in all Member States, gaps and divergences in national criminal 
law remain.75 Large gaps exist with respect to cyber violence against women and intimate 
partner cyber violence, such as ICT-facilitated stalking and non-consensual dissemination of 
private images. In 17 Member States, non-consensual dissemination of intimate/private/sexual 
images online has  not  been criminalised (AT,  BG, HR, CY, CZ, DK, EE, FI, DE,  EL, HU, 
LV,  LT,  LU,  RO,  SK,  SI).76  Gaps  in  criminalisation  also  exist  in  the  area  of  domestic 
violence, because the majority of national definitions require repetition of violent acts in order 
for  them  to  fall  under  the  criminal  offence  of  domestic  violence.  Such  a  requirement  of  re-
victimisation  can  pose  challenges  for  prosecution,  as  well  as  reinforce  secondary 
victimisation. Also, sexual violence within intimate relationships is not always recognised 
as domestic violence.77 

https://ec.europa.eu/info/sites/default/files/child-friendly_justice_20180625-26_background_paper_final.pdf, 

68 Infra 157, pp. 36-39. 
69 Victim Support Europe, Victims of Crime Implementation Analysis of Rights in Europe: Synthesis Report, 2019, p. 154, 
available at: (https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-web.pdf). 
70 EELN 2021, pp. 47-49, 154. Gap Analysis in Annex 8. Also European Commission 2013; Interview with Victim Support 
Europe, 9 July 2021.  
71 
3. 
Concerning  judicial  cooperation  in  matters  of  parental  responsibility  for  the  benefit  of  the  children  concerned  in  cases  of 
suspicions of domestic violence, see Gap Analysis in Annex 8 at p. 17.  
72  Also  European  Court  of  Human  Rights,  O.C.I.  and  Others  v.  Romania,  application  no.  49450/17,  judgment  of  21  May 
2019, §§ 43-46 concerning the return of children between two Member States. 
73 Information gathered in October 2021 from the European Judicial Network. 
74 ICJ, ‘Women’s Access to Justice for Gender-Based Violence – A Practitioners’ Guide’, 2016. 
75 Supra 35.  
76 European network of legal experts in gender equality and non-discrimination, Thematic Report on the Criminalisation of 
gender-based violence against women in European States, including ICT-facilitated violence, Chapter 8. 
77 EELN 2021 at 11, 75. 

p. 

15 

 
 
 
 
 
 
                                                 
The use of force or threats as an essential element of rape is required in 16 Member States 
instead  of  focusing  on  lack  of  consent,  as  recommended  by  human  rights  bodies.78  This 
results in  unequal  protection and  an important  gap in  access  to  justice  for victims  of sexual 
violence across the EU. Gaps also exist with respect to other forms of violence against women 
and  domestic  violence,  which  may  negatively  affect  access  to  justice:  female  genital 
mutilation (FGM) is not a specific criminal offence in 9 Member States, forced marriages 
are  not  explicitly  criminalised  in  7  Member  States79  and  while  all  Member  States  have 
criminalised forced abortion, forced sterilization has been introduced as a specific criminal 
offense only in France, Malta, Portugal and Spain. 

The  lack  of  targeted  training  on  violence  against  women  and  domestic  violence  for  law 
enforcement  and  judicial  authorities  can  lead  to  insufficiencies  in  the  investigation  and  the 
judicial process. The majority of Member States have established  ex officio prosecution for 
some  violence  against  women  and  domestic  violence  crimes,  yet  a  small  minority  have 
dedicated  guidelines  for  the  prosecution  to  ensure  that  this  is  done  effectively  in  a  manner 
taking into consideration the specificities of this kind of crime.  

Difficulties  in  evidencing  violence  during  judicial  proceedings  can  also  form  a  barrier  to 
accessing justice. In particular in cases of sexual violence, there are typically no witnesses and 
there may be no physical signs left by the time the victim has a medical examination. It is also 
often  not  clear  who  (the  police,  medical  professionals,  support  organisations)  should  be 
responsible  for  providing  information  and  support.  The  prospect  of  investigation  and 
prosecution can hinder a victim from reporting a crime and initiating judicial proceedings, as 
victims  may  want  to  avoid  secondary  victimisation  by  not  repeating  the  original  trauma 
during the proceedings.80  Lack of measures protecting victims against retaliation and repeat 
victimization  has  been  identified  as  a  gap  in  some  Member  States  (AT,  FR,  DE,  NL,  PL, 
PT).81  Lack  of  reporting  was  highlighted  by  six  Member  State  authorities  in  the  targeted 
consultation as one of the main challenges in the prosecution of cases of GBV (BE, BG, CY, 
DE, IE, RO).82 

Furthermore, access to compensation has not been effective with regard to victims of gender-
based  violence,  including  violence  against  women  and  domestic  violence.83  The  amount  of 

78 See ECtHR, M.C. v. Bulgaria, application no. 39272/98, judgment of 4 December 2003, paras. 154-166, 185-187. 
79  Fourteen  countries  (Belgium,  Bulgaria,  Croatia,  Cyprus,  France,  Germany,  Ireland,  Italy,  Luxembourg,  Malta,  Portugal, 
Slovenia,  Spain  and  Sweden)  have  specific  provisions  on  forced  marriages.  Six  countries  (Denmark,  Estonia,  Greece, 
Iceland, the Netherlands, and Slovakia), despite not having introduced a specific provision on forced marriages, address this 
specific behaviour under other general criminal provisions (such as an aggravating circumstance, or as one of the purposes of 
human trafficking, for example). Child marriages are not per se generally criminalised, except in Sweden, but the commission 
of the crime  against a  minor has been considered as an aggravating circumstance. Nine countries went beyond the idea of 
marriage, to include civil unions and extrajudicial marriages. In the latter case, the concept combines the prohibition of forced 
marriages with the prohibition of justifications based on honour. Czechia, Finland, Hungary, Latvia, Lithuania, Poland and 
Romania rely on civil law or on general provisions of criminal law without explicit reference to forced marriages. 
80 Secondary victimisation may result from e.g. invasive questioning, including on the victim’s sexual history, repetitive 
interviews or unnecessary confrontation with the offender. 
81 Infra 157, pp.34-35. 
82 Submission for the Member State targeted consultation question no. 43. 
83 Infra 114; Faircom, ‘Fair and Appropriate? Compensation of Victims of Sexual Violence in EU Member States: Greece, 
Italy,  Latvia,  the  Netherlands  and  Spain’,  2020,  available  at:  (https://nscr.nl/app/uploads/2020/11/2020-11-01-Fair-and-
Appropriate-FAIRCOM-Report-Part-II.pdf). In regard to state compensation, in Presidenza del Consiglio dei Ministri, which 

16 

 
 
 
 
 
                                                 
 
compensation is very low, which may have particularly damaging consequences for victims of 
VAW/DV  as  they  often  need  to  re-build  an  independent  and  violence-free  life  of  dignity, 
especially  as  domestic  violence  can  often  occur  in  situations  of  economic  dependence.84  In 
addition,  victims  may  have  to  go  through  both  criminal  and  civil  proceedings  to  claim 
compensation, which exposes them to a high risk of revictimisation.85 Some Member States 
have  restricted  time  limits  to  apply  for  state  compensation  (AT,  CY,  HR,  HU86,  EL87). 
Finally, victims are not aware of their rights (see gap analysis, Annex 8).  

Regarding  sex-based,  including  sexual,  harassment,  reporting  and  dispute  resolution 
mechanisms  are  often  not  readily  accessible  or  gender-sensitive,  and  involve  lengthy 
proceedings.88  The  Gender  Equality  Directives  require  Member  States  to  prohibit  sex-based 
and sexual harassment and provide effective remedies in the areas of employment and access 
to and supply of goods and services. Lacking criminalisation of sexual harassment (see also 
Section 3.1.1), retaliation  measures  towards complainants,  lack of case-law, and insufficient 
knowledge  of  the  issue  by  relevant  professionals  are  identified  as  gaps  in  the  Member 
States.89 

Stakeholders indicate that victims of cyber violence against women and intimate partner 
cyber violence often struggle in accessing remedies. Law enforcement is often not adequately 
aware  or  equipped  to  address  the  specificities  of  the  digital  dimension  of  violence  against 
women and domestic violence. In particular, there are often no facilities to report incidents 
online  and  cyber  violence  may  be  harder  to  prosecute  for  non-specialised  authorities.90 
Insufficient information on what constitutes cyber violence and on the reporting options also 
leads to underreporting.91  

The  role  of  national  equality  bodies  to  deal  with  cases  of  violence  against  women  beyond 
sexual harassment is limited in the majority of the Member States, which equally limits access 
to justice (BG, HR, CY, CZ, DK, FI, FR, EL, HU, IE, IT, LT, LV, LU, MT, NL, PL, RO, SK, 
ES.92 

concerned a victim of sexual violence, the CJEU held that Member States must grant fair and appropriate state compensation 
to all victims of violent intentional crime under Council Directive 2004/80. 
84  European  Commission,  Strengthening  Victims’  Rights:  from  compensation  to  reparation.  For  a new  EU  Victims’  rights 
strategy 2020-2025. Report of the Special Adviser, J. Milquet, to the President of the European Commission, Jean-Claude 
Juncker,  2019,  available  at:  (https://ec.europa.eu/info/files/summary-report-strengthening-victims-rights-compensation-
reparation_en), p. 32. 
85 Victim Support Europe, Victims of Crime Implementation Analysis of Rights in Europe: Synthesis Report, 
2019, p. 56, available at: (https://victimsupport.eu/activeapp/wp-
content/uploads/2019/08/VOCIARE_Synthesis_Report-web.pdf), p. 121.  
86 Infra 114, p. 23. 
87 
Domestic 
(https://resourcehub.bakermckenzie.com/en/resources/fighting-domestic-violence/europe/greece). 
88 EELN 2021, at 97. 
89 EELN 2021, p. 97. 
90  Hate  Aid,  ‘Statement:  General  Recommendation  on  the  Digital  Dimension  of  Women’,  2021,  available  at: 
(https://hateaid.org/wp-content/uploads/2021/05/Protection-of-women-against-digital-violence.pdf). 
91 EPRS, ‘Gender-based violence: cyber violence’, 2021, pp. 12-13. 
92 Supra 76, Table 30. 

Baker  McKenzie, 

Violence: 

available 

Fighting 

Greece, 

4.2.4., 

2021, 

at: 

at 

17 

 
 
 
 
                                                                                                                                                         
 Ineffective support to victims of violence  

Support services, such as counselling and shelters for victims, are fundamental in ensuring the 
well-being of victims, need to be based on an understanding of the victim’s specific needs and 
be available for all victims in a manner that ensures confidentiality and privacy.  

While all Member States have general support services in place, i.e. service provision to the 
public  at  large,  including  social  services,  health  services  and  employment  services, 
stakeholders93 identified an insufficient number of specialist support services for victims of 
violence against women  and domestic violence,  which  can cover targeted social, emotional, 
psychological  and  financial  support,  as  well  as  practical  and  legal  support  specifically 
designed for victims of violence against women and of domestic violence. For example, there 
is a gap in specialised support services dealing with forms of violence against women other 
than  domestic  violence,  such  as  sexual  violence  (AT,  BE,  FR,  MT,  PT,  ES).94  There  is,  in 
particular,  an  insufficient  number  of  shelters  available  to  victims  of  violence  against 
women and domestic violence. GREVIO refers to discrepancies in the information provided 
by  Member  State  authorities  and  civil  society  organisations  on  the  numbers  of  shelters  and 
observes  that,  with  the  exception  of  Austria  and  Malta,  Member  States  are  not  close  to 
reaching  the  target  put  forward  by  the  Council  of  Europe  to  set  up  one  family  place  per 
10,000 heads of population.95 

There are furthermore limitations to accessing the existing support due to conditions related 
to citizenship, residency, economic means, or dependents (children). In some Member States, 
women with children have more difficulties to be accepted to support services or supported. 
In the majority of Member States, access to shelters is  particularly difficult for women with 
disabilities  and  mothers  of  children  with  disabilities.  In  several  Member  States,  specialised 
support  services  are  available  only  to  citizens  of  the  country  or  even  to  residents  of  the 
respective area/region/municipality. The gap analysis shows that there are significant barriers 
for  migrant and asylum seeking women to access general and/or specialised support services 
(BE, DK, IT, NL,ES, SE).96 There are also problems of access to support services depending 
on geographical  location. Access  to  support may also  depend on the victim’s willingness  to 
bring charges against the perpetrator. 

While  several  Member  States  have  developed  a  wider  and  stronger  network  of  specialist 
support  services  that  assists  victims  of  domestic  violence,  a  gap  has  been  identified 
concerning  specialised  support  to  children,  including  child  witnesses  of  violence  against 
women  and  domestic  violence,  especially  of  psycho-social  counselling  and  other  child-
sensitive support.97 Such support needs to be provided with regard to the best interests of the 
child  and  their  needs,  which  may  exclude  shelters  as  the  primary  temporary  housing 

93 Women against Violence Europe (WAVE) collects data and reports on the availability of support services in the EU. These 
data are presented every two years.  
94 Supra 52, p. 90. 
95 Supra 52, p. 92. The information was also provided in the targeted consultation of international organisations. 
96 See more in the Gap Analysis in Annex 8. GREVIO submission targeted consultation p. para 75. 
97  See  more  in  the  gap  analysis  annex  8.  In  the  targeted  consultation,  13  Member  States  said  specialist  support  services 
systematically  take  into  account  the  needs  of  child  victims  and  witnesses  of  domestic  violence  based  on  a  child-sensitive 
approach. Eight said they do, but not systematically.  

18 

 
 
 
 
 
                                                 
solution.98 The gap analysis also identified a lack or insufficiency of national state-wide, 24/7 
and free of charge helplines to women victims of violence (BE, BG, HR, CY, CZ, FI, FR, EL, 
HU,  IE,  LV,  LT,  LU, MT, NL, PL, PT, SI).99 There is  also  lack of multilingual  support on 
national women’s helplines (BE, HR, CZ, HU, LV, LT, MT, NL, PL, PT, SI).100 

There  are  also  gaps  in  support  for  victims  of  cyber  violence  against  women.  The  gap 
analysis  identified  a  lack  of  measures  tackling  this  kind  of  violence  and  the  related  support 
services in the majority of the Member States (AT, BE, BG, HR, CY, CZ, DK, EE, FI, DE, 
FR, HU, IE, IT, LV, LT, MT, NL, PL, PT, RO, SK, SI, ES, SE).101 

Service  provision  is  commonly  ensured  by  victims’  rights  and  women’s  organisations, 
which are staffed with experienced specialists. These organisations report a lack of sufficient 
resources for staff, professional training and financial assistance to run the services as well as 
a lack of recognition of their work by national governments.  

 Insufficient policy coordination  

Due  to  the  involvement  of  various  public  and  possibly  private  sector  actors  in  cases  of 
violence against women and domestic violence, coordination is required to ensure concerted 
action.  Coordination  at  national  level  can  be  substantiated  by  national  plans  of  action  that 
assign each actor a particular role. In addition, due to the high prevalence of violence against 
women  and  domestic  violence  across  Europe  and  globally,  Member  States  participate  in 
international  coordination  efforts.102  According  to  national  and  desk  research,  however,  the 
implementation of the legislative and policy framework shows gaps in most Member States. 
The  realities  are  diverse  and  complex  in  each  Member  State,  but  commonly  identified 
problems  are  lack  of  coordination  between  different  institutions  with  mandates  in  the  area; 
differences in resources and in quality of the service delivery between urban and rural/remote 
or more and less developed areas.  

There  are  also  shortcomings  in  the  collection  of  data  on  violence  against  women  and 
domestic  violence,  as  noted  by  GREVIO  in  a  recent  report  on  the  implementation  of  the 
Istanbul  Convention.103  High  quality  data  is  a  crucial  basis  for  effective  policy-making  and 
these  shortcomings  make  it  challenging  to  form  an  accurate  overview  of  the  prevalence  of 
violence against women and domestic violence in the EU. Data on the prevalence of violence 
against women and domestic violence is gathered through administrative data collection and 
survey  data.  Data  collected  from  administrative  sources  is  not  adequately  disaggregated. 
For example, data on perpetrators are typically not disaggregated by sex, which is an obstacle 

98  See  Council  of  Europe,  Convention  on  preventing  and  combatting  violence  against  women  and  domestic  violence 
(‘Istanbul Convention’). Children’s rights. FRA, Child-friendly justice. Perspectives and experiences of children involved in 
judicial  proceedings  as  victims,  witnesses  or  parties  in  nine  EU  Member  States,  2017,  at  99-100,  on  the  importance  of 
maintaining the confidentiality of a child’s housing arrangements when children access support services to avoid secondary 
victimization. 
99 See more in the Gap Analysis in Annex 8. WAVE, WAVE Report 2015 on the role of specialist women’s support services 
in Europe, 2015, p. 90. 
100  See  more  in  the  Gap  Analysis  in  Annex  8.  WAVE  Report  2015  on  the  role  of  specialist  women’s  support  services  in 
Europe, 2015, p. 90. 
101 Gap Analysis in Annex 8. EPRS, ‘Gender-based violence: cyber violence’, 2021, pp. 12-13. 
102 This is the case in particular for the 21 Member States parties to the Istanbul Convention, Article 10 of which requires the 
establishment of national coordination bodies. 
103 Supra 52, pp. 44-47, 51-52. 

19 

 
 
 
 
 
 
                                                 
to  the  visibility  of  violence  against  women  and  domestic  violence  in  their  different  forms. 
Data also does not systematically cover the sex and age of the victim or the relationship with 
the  perpetrator.  The  lack  of  sex  disaggregated  data  on  victims/perpetrators  of  violence 
collected by the criminal justice system has been identified as problem also in the gap analysis 
in Annex 8 (BE, DK, MT, NL).104 Moreover, data collection between public bodies is not 
harmonised. The gap analysis identified this as a problem in several Member States (AT, BE, 
DK,  FI,  FR,  IT,  MT,  SE).105  The  lack  of  co-ordination  and  comparability  of  the  data 
(including  a  lack  of  common  definitions  and  units  of  measurement)  makes  it  impossible  to 
track cases at all stages of the law-enforcement and judicial proceedings, and during support. 
It  impedes  an  assessment  of  conviction,  attrition,  and  recidivism  rates,  as  well  as  the 
identification  of  gaps  in  the  responses  of  institutions.  An  estimated  2/3  of  victims  do  not 
report violence, and therefore, official criminal  justice data only record a limited number of 
cases. This is why it is important to be able to rely on population survey additionally to police 
statistics.  

The only available, comparable data at the EU level is the FRA survey from 2014. Currently, 
Eurostat  is  coordinating  an  EU  survey  on  gender-based  violence  and  other  forms  of 
interpersonal  violence.    18  Member  States  will  carry  out  the  survey  (which  is  supported  by 
EU funds) while others declined to participate mostly because of human resources constraints. 
FRA and EIGE are stepping in to complete the results for these Member States. Results for all 
countries are expected in 2023. To monitor developments, it would be necessary to carry out 
the survey on a regular basis by all Member States in the future.  

c)  Gaps at EU level  

There  is  currently  no  specific  EU  legal  instrument  addressing  violence  against  women  and 
domestic violence. The topic falls, however, in the scope of application of several directives 
and regulations, in particular in the areas of criminal justice, gender equality and asylum. The 
existing  EU  legal  framework  for  addressing  violence  against  women  and  domestic  violence 
was  assessed  for  the  purposes  of  this  initiative;  this  assessment  concludes  that  the  current 
legal framework has significant gaps and shortcomings with regard to this group of victims, 
which  has  come  to  the  forefront  particularly  due  to  the  increased  risk  of  domestic  violence 
following the confinement measures of the COVID-19 pandemic (see Annex 8 for details).  

The  gap  analysis  in  Annex  8  also  shows  that  the  relevant  EU  legislation  has  been 
ineffective in preventing and combatting violence against women and domestic violence. 
While there is no EU legislation dedicated to such violence, the gap analysis identified 14 EU 
law  instruments  which  are  relevant  for  victims  of  violence  against  women  and  domestic 
violence  as  they  either  establish general rules  applicable also  to this category  of victims,  or 
establish  specific  rules  on  certain  forms  of  such  violence.  For  example,  the  provisions  on 
protection  and  access  to  justice  in  the  Victims’  Rights  Directive  and  the  European 
Protection  Orders  (‘EPO’)  apply  to  all  victims  of  crime,  whereas  the  Directives  on  child 
sexual  abuse  or  trafficking  in  human  beings  establish  sectoral  rules  on  these  forms  of 

104 See more in the Gap Analysis in Annex 8; Supra 52, pp. 42-46. On cyber violence, EPRS, ‘Gender-based violence: cyber 
violence’, 2021, pp. 12-13. 
105 See more in Annex 8; Supra 52, p. 46. 

20 

 
 
 
 
                                                 
violence.  In  addition,  the  Gender  Equality  Directives  include  provisions  on  sexual 
harassment. The assessment supplements and builds on the on-going general evaluations of 
some  of  these  instruments,  in  particular  those  concerning  the  Victims’  Rights,  the  Child 
Sexual Abuse and the Anti-Trafficking Directives.106 

With  regard  to  prevention,  the  EU  framework  includes  some  obligations  on  awareness-
raising, but these either concern victims’ rights in general107, or are limited to specific forms 
of violence, such as trafficking in human beings, child sexual abuse or  sexual harassment at 
work.  As  to  training  for  professionals,  EU  legislation  provides  some  obligations  for  the 
Member  States108,  but  such  provisions  are  not  specific  to  violence  against  women  and 
domestic violence. 

When  it  comes  to  protection  of  victims,  the  instruments  on  the  mutual  recognition  of 
protection orders provide for cross-border recognition of criminal and civil protection orders. 
However,  the  take-up  of  the  EPO  instruments  is  very  low  which  limits  their  effectiveness. 
Moreover,  the  instruments  do  not  ensure  that  effective  emergency  barring  orders  and 
protection  orders  are  available  and  effective  in  all  Member  States.  As  set  out  above, 
emergency  protection  orders  do  not  exist  in  all  Member  States  and  the  modalities  for  their 
issuance vary.109 Lack of efficiency of the protection orders at the national level results in a 
poor  take-up  of  protection  orders  in  cross-border  cases  and  as  a  consequence  in  a  very  low 
application of the EU EPO instruments.110 

The  insufficient  and  unequal  criminalization  of  different  forms  of  violence  against  women 
and  of  domestic  violence  makes  it  more  difficult  for  victims  to  access  justice.  EU-level 
criminalisations  of  specific  forms  of  violence  against  women  with  harmonised  definitions 
and  sanctions  are  currently  included  in  the  Anti-Trafficking  and  the  Child  Sexual  Abuse 
Directives.111  While  most  conduct  of  violence  against  women  and  domestic  violence  is 
criminalised  at  national  level,  the  situation  at  EU  level  leaves  important  gaps,  in  particular 
with regard to sexual harassment and cyber violence against women and intimate partners (see 
above, Section 2.1.2).  This  directly impacts  the  victims’ access  to  justice.  In  cases of cyber 
violence,  if  national  law  enforcement  mechanisms  are  unavailable,  victims  can  complain  to 
the  online  platform.  Effective  means  of  redress  are  however  not  always  provided  by  the 
platform, which is particularly problematic for serious forms of cyber violence.112 Similarly, 
with  regard  to  sexual  harassment,  EU  law  obliges  Member  States  to  prohibit  sexual 
harassment as a form of discrimination and impose sanctions. They however do not require, 

106  See    ‘Combating  child  sexual  abuse  –  review  of  EU  rules’,  available  at:  (https://ec.europa.eu/info/law/better-
the  first 
regulation/have-your-say/initiatives/13073-Combating-child-sexual-abuse-review-of-EU-rules_en),  planned  for 
quarter  of  2022;  ‘Fighting  human  trafficking  –  review  of  EU  rules’,  available  at:  (https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13106-Fighting-human-trafficking-review-of-EU-rules_en), open until 22 March 2022. 
107 Art. 26 the Victims’ Rights Directive. 
108 Such as Art. 25 the Victims’ Rights Directive. 
109 EELN 2021, p. 11. 
110 European Commission, Report from the Commission to the European Parliament and the Council on the implementation 
of Directive 2011/99/EU of the European Parliament and of the Council of 13 December 2011 on the European protection 
order, 2020. 
111  The  Gender  Equality  Directives  require  Member  States  to  sanction  sex-based  work  harassment,  but  do  not  necessarily 
require criminalisation. 
112 EELN 2021, at 137-138. 

21 

 
 
 
 
                                                 
for  most  serious  cases,  criminal  sanctions.113  Lack  of  adequate  compensation  remains  a 
challenge  and  obstacle  for  this  group  of  victims  in  accessing  justice,  despite  the  minimum 
standards  of  the  Compensation  Directive  and,  for  sexual  harassment,  the  Gender  Equality 
Directives.114  The  amount  of  compensation  attributed  in  violence  against  women  and 
domestic violence cases is often very low and compensation is not granted in adequate time. 

Concerning access to support for this group of victims, the Victims’ Rights Directive has not 
reached  its  full  potential:  implementation  remains  dissatisfactory.115  The  complexity  and 
broad  formulations  in  the  Victims’  Rights  Directive  often  cause  obstacles  in  its  practical 
application.  The  broad  formulation  of  the  provisions  concerning  support  to  victims  of 
violence  against  women  and  domestic  violence  further  effects  the  quality  of  the  non-
legislative measures taken pursuant to the Directive. Implementation issues were identified in 
several  Member  States  on  access  to  shelters,  including  their  availability  and  numbers.  Such 
shortcomings  tend  to  particularly  affect  victims  of  violence  against  women  and  domestic 
violence.  Moreover,  only  13  Member  States  reported  that  their  specialist  support  services 
systematically take into account the special needs of child victims and witnesses in cases of 
domestic violence  and  ten additional Member States applied  a child sensitive approach in  a 
non-systematic  manner.  Courts  also  regularly  categorise  child  witnesses  as  indirect  victims, 
despite  it  being  standard  practice  in  child  protection  to  consider  child  witnesses  as  direct 
victims due to the psychological harm inflicted. This can hinder children’s access to services, 
such as counselling.  

Regarding  cyber  violence  against  women  and  between  intimate  partners,  the  existing  EU 
legal  framework  does  not  include  specific  obligations  in  this  regard.  The  Victims’  Rights 
Directive applies to all criminalised conduct, but forms of cyber violence against women are 
only criminalised in 11 Member States. Hence, victims of such violence are often not eligible 
for protection and support measures under the Directive.  

The Gender Equality Directives116 establish that sex-based and sexual harassment at work and 
in  the access  to  goods and services are contrary  to  the principle of equal  treatment  between 
men  and  women,  and  oblige  Member  States  to  prohibit  such  conduct,  ensure  remedies  and 
enforcement, including compensation, and provide for effective, proportionate and dissuasive 

113  EELN  2021,  at 88, 93-94,  finding  that the  existing  criminalisations of  sexual  harassment  in  the Member  States  are  not 
uniform and do not correspond to the requirements of the main international obligations in this field.  
114 European Commission, Strengthening Victims’ Rights: from compensation to reparation. For a new EU Victims’ rights 
strategy 2020-2025. Report of the Special Adviser, J. Milquet, to the President of the European  Commission, Jean-Claude 
Juncker, 2019,  
available at: (https://ec.europa.eu/info/sites/default/files/strengthening_victims_rights_-
_from_compensation_to_reparation_rev.pdf).  
115 Report from the Commission to the European Parliament and the Council on the implementation of Directive 2012/29/EU 
of the European Parliament and of the Council of 25 October 2012, COM/2020/188 final, pp. 3, 6-7, stating that ‘victims of 
domestic  violence  do  not  receive  effective  support  and  protection  in  several  Member  States.  Furthermore,  not  all  Member 
State provide for a right to support services for victims’ family members’.  
116 Directive 2006/54/EC of 5 July 2006 on the implementation of the principle of equal opportunities and equal treatment of 
men  and  women  in  matters  of  employment  and  occupation;  Council  Directive  2004/113/EC  of  13  December  2004 
implementing the principle of equal treatment between men and women in the access to and supply of goods and services; 
Directive 2010/41/EU of 7 July 2010 on the application of the principle of equal treatment between men and women engaged 
in an activity in a self-employed capacity. 

22 

 
 
 
 
                                                 
penalties.  However,  these  provisions  have  not  been  effective  in  reducing  the  prevalence  of 
sexual harassment (see Section 2.1.2 (b) at 1 and 3). 

More  generally,  the  gap  analysis  shows  that  the  relevant  EU  legislation  has  been 
ineffective  in  ensuring  the  rights  of  victims  of  violence  against  women  and  domestic 
violence. The EU-level measures do not explicitly address victims of violence against women 
and  domestic  violence.  The  relevant  obligations  are  not  specific  enough  with  regard  to 
victims  of  violence  against  women  and  domestic  violence  or  leave  wide  discretion  to  the 
Member States. The relevant EU legislation is not up to date; it is on average over ten years 
old  and  the  international  obligations  have  evolved  considerably  in  the  area  of  violence 
against women and domestic violence in the meantime (see below).  

Finally, EU law is  no longer coherent  with  the  international  legal and policy framework. 
Concerning violence against women and domestic violence generally, EU law remains below 
the standards of the Istanbul Convention and the CEDAW Convention with regard to this 
group  of  victims.  The  relevant  provisions  of  EU  law  are  mainly  formulated  in  a  gender-
neutral manner and do not require Member States to take into account the specific needs of 
women  victims  of  violence  and  victims  of  domestic  violence.  In  addition,  EU  law  includes 
few provisions on targeted preventive measures, and fails to address the protection needs of 
these victims with the specificity required in Chapter VI of the Istanbul Convention. With the 
exceptions of child sexual abuse and trafficking in human beings for the purposes of sexual 
exploitation, EU law does not establish harmonised definitions and sanctions of most of the 
forms  of  violence  against  women  and  domestic  violence  enumerated  in  the  Istanbul 
Convention.117  The  framework  does  not  address  the  rights  of  witnesses,  particularly  child 
witnesses,  of  such  violence.  All  Member  States  have  ratified  the  UN  Convention  on  the 
Rights  of  the  Child,  which  in  its  Article  19  includes  provisions  on  prevention,  protection, 
support  and  access  to  justice  to  children  affected  by  violence.  General  and  specific  support 
services to this group of victims are regulated in the Victims’ Rights Directive, but the lack of 
detail in the provisions has led to ineffective implementation by the Member States. There is 
currently no obligation on the Member States to collect data specifically on violence against 
women and domestic violence, and no specific EU-level coordination structures exist on this 
kind of violence. The gap analysis further finds that action at national level is likely to have 
resulted from the implementation of the Istanbul Convention in those Member States that are 
parties. 

Since  the  adoption  of  the  directives,  the  international  #MeToo  movement  has  raised  the 
visibility of sexual harassment against women, potentially encouraging more victims, but also 
governments,  social  partners  and  employers,  to  take  action.118  In  2019,  the  International 
Labour  Organization  adopted  the  Violence  and  Harassment  Convention  No.  190,  which 
requires  parties  to  prohibit  gender-based  violence  and  harassment  at  work  and  provides  a 

117 On the division of competence between Member States and the EU for the envisaged agreement to conclude the Istanbul 
Convention, see CJEU, Opinion A1/19, from §278 onwards.  
118  European  sectoral  social  partners  have  been  active  in  this  area:  e.g.  European  social  partners  from  the  railway  sector 
negotiated in June 2021 a new autonomous agreement on gender equality, which also covers the prevention of violence and 
the 
harassment,  available  at  https://ec.europa.eu/social/main.jsp?catId=521&langId=en&agreementId=5745.  See  also 
Communication  from  the  Commission  to  the  Council  and  the  European  Parliament  transmitting  the  European  framework 
agreement on harassment and violence at work (COM(2007) 686 final)). 

23 

 
 
 
 
                                                 
comprehensive protection, prevention, and support framework for victims. EU law does not 
ensure  the  criminalisation  of  serious  forms  of  sexual  harassment;  the  applicability  of  the 
protection  and  support  measures  of  the  Victims’  Rights  Directive  therefore  depends  on 
whether  harassment  is  criminalised  under  national  law.  The  prevention,  protection  and 
support measures  concerning sexual  harassment  are also  not  as developed as in Convention 
no. 190.   

Finally, the current EU legislation has not led to effective monitoring and enforcement of 
the relevant EU rules with regard to violence against women and domestic violence. This 
is  due  to  the  absence  of  a  focus  on  such  violence  and  the  ambiguous  drafting  of  the  legal 
obligations,  which has not  enabled targeted  enforcement measures in  the key problem  areas 
relating to violence against women and domestic violence. 

2.1.3.  Who is affected? 

Gender-based violence is disproportionately perpetrated against women. In the majority of 
cases of physical violence, the perpetrator is a man or a group of men.119  

Although women and girls account for a far smaller share of total victims of homicides than 
men, they are overrepresented among victims of intimate partner/family-related homicide, and 
intimate  partner  homicide.  Victim/perpetrator  disaggregations  reveal  a  large  disparity  in  the 
shares attributable to male and female victims of homicides committed by intimate partners or 
family members: 36 per cent male versus 64 per cent female victims.120 These findings show 
that even though men are the principal victims of homicide globally, women continue to bear 
the heaviest burden of lethal victimization as a result of gender stereotypes and inequality.  In 
particular sexual violence is strongly gendered with more than 9 in 10 rape victims and more 
than 8 in 10 sexual assault victims being women and girls, while nearly all those imprisoned 
for such crimes are male (99%).121 Research also suggests that more women than men become 
victims of sexual harassment or sex discrimination.122 Incidents of physical violence against 
women (excluding specifically  sexual  violence)  most often take place at home (37%). Such 
violence also often involves a family member or a relative as the perpetrator. Thus, although 
men and non-binary people can also be victims of  gender-based violence123, the majority of 
victims are women in all their diversity.  

Cyber violence against women has been found to target in particular young women124 and 
women visible in public life. Women in public positions, such as journalists and politicians, 
experience  cyber  violence  targeting  them  because  they  are  women  and  seeking  to  question 

119 Supra 34; Supra 36. 
120 United Nations Office on Drugs and Crime, 2018, Global Study On Homicide - Gender-related killing of women and girls, 
pp. 9-11.  
121  Eurostat  crime  statistics:  (https://ec.europa.eu/eurostat/web/products-eurostat-news/-/EDN-20171123-1),  last  visited 
19/08/2021. 
122 Heather Antecol, Vaness Barcus, Deborah Cobb-Clark, 2009, ‘Gender-biased behavior at work: Exploring the 
relationship between sexual harassment and sex discrimination’, Journal of Economic Psychology, Vol. 30(5).    
123 FRA, Report - A long way to go for LGBTI equality, 2020. 
124  EIGE  2017,  p.  1,  finding  that  particularly  young  women  disproportionately  experience  severe  forms,  namely  cyber 
stalking and online sexual harassment. FRA 2014. LGBTI in the past 5 years. In the case of trans men, the figure was 16%, 
and for non-binary persons 13%. 

24 

 
 
 
 
 
                                                 
their entitlement to participate in societal discussions. This can have a silencing effect on the 
victims and negatively affect democratic decision-making processes.125  

Similarly,  while  both  women  and  men  experience  harassment,  women  face  more 
harassment of a sexual nature. In a 2012 survey, up to 55% of women in the EU-28 (ages 
18–74) reported having experienced sexual harassment since the age of 15. One in five (21%) 
had experienced at least one form of sexual harassment in the 12 months before the survey. 
Such harassment consists of forms such as unwanted touching, hugging or kissing, or sexually 
suggestive,  unwanted  comments  or  cyber  harassment.126  In  2021,  18%  of  women  described 
the most recent incident of harassment as of a sexual nature, compared with 6% of men. 

Women and girls in vulnerable situations, such as women with disabilities, women victims 
of trafficking in human beings, women prisoners, women migrants and asylum seekers, non-
heterosexual women and women sex workers, are at a higher risk of violence. For example, 
exposure  to  physical  or  sexual  partner  violence  differs  between  women  with  and  without 
disabilities  (34%  vs  19%)  and  non-heterosexual  and  heterosexual  women  (48%  vs  21%).127 
Human  traffickers  exploit  the  particular  vulnerabilities  of  persons  with  disabilities  for  the 
purpose of sexual exploitation128. 

Children  are  often  seriously  affected  by  violence  against  women  and  domestic  violence. 
They  can  be  themselves  victims  or  witnesses  of  such  violence;  both  experiences  are 
considered  to  be  equally  traumatizing.129  Exposure  to  violence  at  an  early  age  can  cause 
impairments  to  the  brain  and  nervous  system  development,  as  well  as  result  in  life-long 
negative  coping  and  health  risk  behaviours.130  Children  who  witness  or  are  victims  of 
emotional,  physical,  or  sexual  abuse  are  also  at  higher  risk  for  health  problems  as  adults. 
These can include mental health conditions, such as depression and anxiety.131 

While the exact  prevalence of  violence against  women and domestic violence  varies among 
Member  States,  it  is  widespread  in  every  Member  State  regardless  of  socio-economic 
boundaries.132  

125 Nato StratCom 2020, p. 10. Inter-Parliamentary Union, Sexism, harassment and violence against women in parliaments in 
Europe, Issue Brief, 2018; M.L. Krook, Violence against women in politics, Oxford University Press, 2020; HRC, Report of 
the  Special  Rapporteur  on  Violence  against  Women,  Its  Causes  and  Consequences  on  violence  against  women  in  politics, 
A/73/301, 6 August 2018; HRC, Report of the Special Rapporteur on Violence against Women, Its Causes and Consequences 
on violence against women journalists, A/HRC/44/52, 6 May 2020; UNESCO, The Chilling: Global trends in online violence 
against women journalists – Research Discussion Paper, 2021. See also:  European Commission, Communication from the 
Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of 
the  Regions.  On  the  European  democracy  action  plan,  COM(2020)  790  final,  3  December  2020;  European    Commission, 
Recommendation on ensuring safety of journalists in the European Union. 
126 FRA, Violence against women survey, 2014, p. 95. 
127  Supra  34.  The  risk  is  further  augmented  for  women  in  segregated  settings  and  closed  institutions,  such  as  specialist 
institutions for persons with disabilities. 
128 Commission (COM(2020) 661 final): Third Report on the progress made in the fight against trafficking in human beings 
and its Staff Working Document, SWD(2020)226 final). 
129 For a recent systematic review see, among others, Petruccelli K, Davis J, Berman T. Adverse childhood experiences and 
associated health outcomes: A systematic review and meta-analysis. Child Abuse Negl. 2019 Nov;97:104127. doi: 
10.1016/j.chiabu.2019.104127. Epub 2019 Aug 24. PMID: 31454589;  
130  E.  Kimball,  “Edleson  Revisited:  Reviewing  Children’s  Witnessing  of  Domestic  Violence  15  Years  Later”,  Journal  of 
Family Violence, Vol. 31(5), 2016, pp. 1-13. 
131 Monnat, S.M., Chandler, R.F., Long Term Physical Health Consequences of Adverse Childhood Experiences. The 
Sociologist Quarterly; 56(4), 2015: 723-752. 
132 For more information on Member State-specific prevalence, see Annex 6. 

25 

 
 
 
 
 
                                                 
2.1.4.  Why is violence against women and domestic violence a problem? 

Violence against women and domestic violence can violate a number of fundamental rights, 
including  the  right  to  life  and  to  equality  between  women  and  men  (see  Section  6.1).  They 
cause pain and suffering to the victims and result in large costs on the economy and society as 
a whole. They negatively impact the physical health of the victims. Sexual violence exposes 
women to sexually-transmitted diseases, unintended pregnancies, abortions and miscarriages, 
and  lowers  women's  control  over  their  reproductive  health.133  Violence  against  women  and 
domestic  violence  also  increase  the  probability  of  mental  health  problems134,  linking  to 
higher rates of depression, post-traumatic stress disorder, anxiety, alcohol and drug abuse, and 
suicidal ideation.135 

Some of the social and health impacts of violence against women and domestic violence can 
be quantified in terms of costs and/or economic consequences. For the EU, EIGE has carried 
out two studies on the costs of violence in 2014 and 2021.136 The 2021 study considers three 
main sources of costs: direct cost of services (to victims or to public providers); lost economic 
output; and physical and emotional impacts measured as a reduction in the quality of life.  

Direct cost of services consists of the use of services provided by various sectors to mitigate 
the harm caused by violence. This includes the use of health services to treat the physical and 
mental  harms;  social  services;  the  criminal  justice  system  involved  in  the  investigation, 
prosecution and adjudication of cases of violence against women and domestic violence; the 
civil justice system to e.g. disentangle from a violent partner; and specialist services for the 
prevention and/or mitigation of the impacts, such as protection and support services. Victims 
of intimate partner violence may  incur costs not  covered by the  state, notably  judicial costs 
and the costs of a new home. 

Violence  against  women  and  domestic  violence  also  result  in  lost  economic  output,  as  a 
result of the victim’s decreased ability to look for a job or productivity on the job and the time 
taken off work to handle the consequences of the crime. According to a European Parliament 
Research Service (‘EPRS’) study137, research conducted in Belgium found that 73% of those 
subjected to domestic violence reported an effect on the ability to work. Another recent EPRS 
study138  estimates  the  lost  economic  output  due  to  mental  health  impairments  caused  by 
cyber-violence on women, both in terms of lost work days and lower productivity. A study on 
the costs of violence against women in  Italy  calculates the costs of work  days lost, reduced 

133 World Health Organization, London School of Hygiene and Tropical Medicine, South African Medical Research Council. 
‘Global and regional estimates of violence against women: Prevalence and health effects of intimate partner violence and 
non-partner sexual violence’. Geneva, Switzerland: World Health Organization, 2013. 
134  Magnusson  Hanson,  Nyberg,  Mittendorfer-Rutz,  Bondestam,  Madsen:  ‘Work  related  sexual  harassment  and  risk  of 
suicide and suicide attempts: prospective cohort study’, 2020, BMJ2020;370:m2984.  
135 J. Mannel & S. Hawkes, ‘Decriminalisation of gender-based violence is a global health problem’, Journal BMJ Global 
Health, Vol. 2(3), 2017, pp. 1-3. 
136 EIGE, Estimating the costs of gender based violence in the European Union: Report, Publications Office of the European 
(https://eige.europa.eu/publications/estimating-costs-gender-based-violence-european-union-
Union,  Luxembourg,  2014 
report); 
at 
in 
EIGE, 
https://eige.europa.eu/sites/default/files/documents/20213229_mh0921238enn_pdf.pdf.  See  also  Annex  2:  Mutual  learning 
seminar on ‘Methodologies and good practices on assessing the costs of violence against women’, 7-8 July 2021.  
137 EPRS, Equality and the Fight against Racism and Xenophobia: Cost of Non-Europe Report, 2018. 
138 EPRS, Combating gender-based violence: Cyberviolence, European added value assessment, 2021, p. 8. 

gender-based 

available 

violence 

2021; 

costs 

EU’, 

The 

the 

of 

26 

 
 
 
 
                                                 
productivity,  and the  cost  of replacing  absent  workers.  It furthermore calculates the lost tax 
income and the multiplier effect of households' lost incomes.139  

The third cost category in the EIGE study is the physical and emotional impact on victims, 
measuring  the  loss  of  healthy  life  years.140  This  allows  a  monetary  value  to  be  attached  to 
health conditions to translate losses usually not measured in money into economic losses. The 
greatest source of economic loss due to violence against women and domestic violence is the 
loss in quality of life that monetises the physical and emotional impacts of violence. 

On  this  basis,  the  2021  EIGE  study  estimates  that  total  yearly  costs  of  gender-based 
violence against women in the EU-27 stand at €290 billion141 and almost €152 billion for 
domestic violence. These costs, consist in large part of physical/emotional impacts (55.57%), 
criminal  justice  system  (20.43%)  and  lost  economic  output  (13.93%)  (see  Annexes  3  and 
5).142  

2.2. 2.2. What are the drivers? 

2.2.1 

Structural gender inequality and gender stereotypes  

Whilst there is  no single cause for  violence  against  women and domestic violence, some of 
the  most  consistent  drivers  are  harmful  social  norms  and  stereotypes  that  contribute  to 
gender inequality.143 Such social norms concern the roles of women and men; harmful gender 
stereotypes include ideals linking masculinity to the provider role, macho behaviour, as well 
as  ideals  linking  femininity  to  chastity,  submission  and  victimhood.144  The  WHO  has 
identified community norms that ascribe higher status to men, low levels of women’s access 
to paid employment, and low level of gender equality as factors increasing the risk of violence 
against women and domestic violence.145  

Societal  norms  affect  perpetrators’  and  bystanders’  behaviours.  Perpetrators  may  not 
consider  their  act  of  violence  as  morally  reproachable.146  Gender  roles  and  stress  over 
masculine  gender  roles  have  been  found  to  strengthen  tolerance  toward  violence  against 
women147,  which  may,  in  turn,  be  caused  by  factors  such  as  negative  stereotypes  towards 

139  G.  Vingelli,  et  al.,  Quanto  costa  il  silenzio?  Indagine  nazionale  sui  costi  economici  e  sociali  della  violenza  contro  le 
donne, Intervita, Grafica Aelle snc, 2013. 
140These estimates are based on the Home Office 2018 study which computed unit cost for all crimes. This lack of specificity 
means that the potential differences in the long term psychological impact of the relationship between victims and perpetrator 
is not taken into account with a potential underestimation of costs.  
141  This  represents  an  increase  with  respect  to  the  2014  estimates  (€225  billion)  which  were  however  based  on  a  slightly 
different methodology. See EIGE (2014) for details.  
142 These estimates demonstrate the direct costs of gender-based violence against women to the victims and to the state public 
services, as well as a larger component in terms of long term indirect impact (long term health conditions, lost production and 
replication effects). 
143 Council of Europe, ‘What causes gender-based violence?’ UN Women (2020), Stereotypes. 
144 L. Kelly & N. Westmarland, ‘It’s a work in progress’: men’s accounts of gender and change in their use of coercive 
control”, Journal of Gender-Based Violence, 2019. 
145 https://www.who.int/news-room/fact-sheets/detail/violence-against-women, last visited 19/08/2021.  
146  ‘JRC  Science  for  Policy  Report  -  Insights  from  behavioural  sciences  to  prevent  and  combat  violence  against  women’, 
cited above. For more, please also see Joint Research Center, ‘Literature references on gender-based violence and domestic 
violence prepared for the Gender-based violence and domestic violence initiative’, cited above. 
147  M.  Jakupcak,  D.  Lisak  &  L.  Roemer,  ‘The  role  of  masculine  ideology  and  masculine  gender  role  stress  in  men’s 
perpetration of relationship violence’, Psychology of Men & Masculinity, Vol. 3(2), 2002, pp. 97–106. 

27 

 
 
 
 
                                                 
women. Tolerant attitudes towards violence against women may be further encouraged by the 
social environment, leading to a circle of violence.148 

Another  key  cause  of  attitudes  and  behaviour  is  the  lack  of  a  common  understanding  of 
violence against women.149 The 2016 special Eurobarometer on gender-based violence depicts 
these problematic assumptions, as 27% of the respondents said that sexual intercourse without 
consent may be justified in at least some situations.150 Although most people would agree that 
rape is morally wrong (i.e. negative attitude), not all would agree on what constitutes rape.  

Tolerant  attitudes  towards  violence  against  women  have  also  been  observed  with  respect  to 
some  forms  of  sex-based  harassment.  In  some  Member  States,  tackling  sex  harassment  at 
work  was  not  considered  a  real  issue.151  Some  forms  of  violence  against  women  and 
domestic  violence  are  sometimes  considered  a  private  matter.  Thus,  in  the  2016 
Eurobarometer,  one  in  six  respondents  believed  that  domestic  violence  should  be  handled 
within the family. About one in five expressed victim-blaming views, agreeing that women 
make up or exaggerate claims. Just under one in five (17%) held that violence against women 
is often provoked by the victim, with respondents in the Eastern European Member States the 
most likely to agree. 152 

2.2.2.  Failure  to  recognise  the  specificities  of  crimes  and  offences  relating  to  violence 

against women and domestic violence 

Criminal acts of violence against women and domestic violence have specific characteristics, 
such  as  systemic  under-reporting,  disrupted  criminal  proceedings153,  the  commonly  sexual 
nature  of  crimes  and  a  high  prevalence  of  elements  of  coercive  control.  Rates  of  reporting 
violence against women and domestic violence to the police are low.154 According to the FRA 
2014 survey, victims reported the most serious incident of partner violence to the police 
only  in  14%  of  cases  and  the  most  serious  incident  of  non-partner  violence  in  13%  of 
cases.155  In 2021,  FRA  confirmed  that reporting of violence  and harassment  in  general was 
less common than that of other crime, and that reporting crime to the police was less common 

148 A. Bandura, Aggression: A social learning analysis, Prentice Hall, 1973. 
149 G. Bohner, et al., ‘Rape myth acceptance: Cognitive, affective and behavioural effects of beliefs that blame the victim and 
exonerate the perpetrator’, in M. Horvath & J. Brown (eds.), Rape: Challenging contemporary thinking, 2009, pp. 17-45. 
150  Respondents  were  most  likely  to  say  this  about  being drunk  or on drugs  (12%),  voluntarily  going  home  with  someone 
(11%), wearing revealing, provocative or sexy clothing or not clearly saying no or physically fighting back (both 10%). 
151 EELN, Harassment related to Sex and Sexual Harassment Law in 33 European Countries, 2011. 
152 Research shows that misreporting of GBV/DV remains marginal. The rate of false reporting for sexual assault has been 
estimated  to  remain  in  the  range  of  2-8%  (Lonsway,  Archambault,  Lisak,  ‘False  Reports:  Moving  Beyond  the  Issue  to 
Successfully Investigate and Prosecute Non-Stranger Sexual Assault’, The National Center for the Prosecution of Violence 
Against  Women,  2009).  Women  and  men  have  been  found  to  provide  differing  accounts  of  violence,  controlling  behavior 
and  injuries,  which  highlights  the  need  to  take  into  account  both  parties’  accounts  of  the  violent  behaviour  (Dobash  RP, 
Dobash RE, Cavanagh K, Lewis R., ‘Separate and Intersecting Realities: A Comparison of Men’s and Women’s Accounts of 
Violence Against Women’, Violence Against Women. 1998; 4(4):382-414). 
153 See FRA, Women as victims of partner violence, 2019, at 39, referring to the risk for victims to withdraw their complaint 
due to difficulties in reporting and at 45, referring to discontinuance due to lack of evidence.   
154 Supra 34; Supra 36; E. Gracia, ‘Unreported cases of domestic violence against women: towards an epidemiology of social 
silence, tolerance, and inhibition’, Journal of Epidemiology & Community Health, Vol. 58(7), 2004, pp. 536-537. 
155 GBV/DV can typically consist of several violent incidents. See ECtHR, Eremia and others v. The Republic of Moldova, 
application no. 3564/11, judgment of 28 August 2013, §54, where the Court acknowledged that ‘the fear of further assaults 
was sufficiently serious to cause the first applicant to experience suffering and anxiety amounting to inhuman treatment’. 

28 

 
 
 
 
                                                 
when  the  perpetrator  was  a  family  member  or  a  relative  (only  22%  of  incidents  were 
reported).156  

The reasons for not reporting violence against women and domestic violence are multiple. 
They  include  the  trouble  involved  in  reporting  an  incident  if  the  victim  perceives  that  the 
police  will  not  take  her  seriously  or  will  be  unwilling  to  do  anything  about  the  crime. 
Furthermore, for around one quarter of victims of sexual violence by a partner or non-partner, 
feeling  ashamed  or  embarrassed  about  what  happened  was  the  reason  for  not  reporting  the 
incident  to  the  police  or  a  support  organisation.  Victims  may  also  fear  retaliation  from  the 
perpetrator or  consider the violence a private matter.157  In addition,  they may  be hesitant  to 
report  an  incident  perpetrated  by  a  family  member  or,  in  cases  of  sex-based  or  sexual 
harassment at work, a hierarchical superior or a colleague. 

their  experience  or  withdraw  statements  and  discontinue  participation 

The above  specificities  hamper efforts to effectively  address  violence against women and 
domestic violence. Incidents may be difficult for authorities to address, since victims may not 
in 
disclose 
investigations  or  court  proceedings.  These  dynamics  interfere  with  efforts  to  ensure  an 
appropriate  follow-up  within  the  judicial  system  or  through  support  mechanisms.  They  also 
underline the need to ensure the accessibility of support regardless of whether the victim has 
officially reported the violence. 

Due  to  the  specificities  of  crimes  and  offences  relating  to  violence  against  women  and 
domestic  violence,  gender-sensitive  measures  are  needed.  In  their  Evaluation  Report  on 
Finland,  GREVIO  noted  that  gender-neutral  approach  in  policy  making  and  service 
provision  is  not  sufficient  and  does  not  provide  women  victims  of  violence  and  domestic 
violence  effective  protection,  support  and  access  to  justice.  GREVIO  notes  that  this  may 
not  always  do  justice  to  the  particular  experiences  of  women  as  victims  of  domestic 
violence,  who  are  more  frequently  and  more  severely  impacted.158  Moreover,  the 
European  Court  of  Human  Rights  also  requires  Member  States  to  adopt  a  gender-sensitive 
approach in their measures to prevent and combat such violence (see Section 6.1 for details).  

156 Supra 36. 
157 FRA, Women as victims of partner violence – Justice for victims of violent crime, Part IV, 2019, p. 33. 
158 GREVIO, Baseline Evaluation Report: Finland, 2019, p. 6, available at: (https://rm.coe.int/grevio-report-on-
finland/168097129d).  

29 

 
 
 
 
                                                 
Figure 1 - Problem tree 

2.3. 2.3.  How will the problem evolve? 

Based on the evolution of the situation in the past decades, it is unlikely that the prevalence of 
all  forms  of  violence  against  women  and  domestic  violence,  as  measured  through 
administrative  and  survey  data,  will  decrease  significantly  without  additional  policy 
intervention. All Member States have adopted policy and legislative measures on this kind of 
violence, and 21 Member States have taken measures pursuant to their obligations under the 
Istanbul  Convention.  The  gaps  concerning  prevention,  protection,  access  to  justice,  support 
and coordination can however be expected to persist (see Section 3.1.3).159 Stakeholders, such 
as  non-governmental  and  international  organisations,  note  that  without  further  action  at  EU 
level,  national  legislation  and  practice  are  unlikely  to  develop  sufficiently  and  in  a 
coordinated manner in line with international standards to ensure that the needs of victims of 
violence against women and domestic violence are sufficiently addressed throughout the EU 
(see Annex 2).  

159 As indicated in EPRS, Combating gender-based violence: Cyber violence, 2021.  

30 

 
 
 
 
 
 
                                                 
3.  3. 

Why should the EU act? 

3.1. 3.1.  Legal basis 

The  initiative  pursues  the  general  objective  of  preventing  and  combatting  violence  against 
women and domestic violence. As confirmed in Declaration No. 19 on Article 8 of the TFEU, 
combatting ‘all kinds of domestic violence’ is part of the Union’s general efforts to eliminate 
inequalities between women and men and Member States should take all necessary measures 
to prevent and punish these criminal acts and to support and protect the victims. 

The initiative would build on the Victims’ Rights Directive and establish minimum standards 
on  the  rights  of  victims  of  all  forms  of  violence  against  women  and  domestic  violence, 
constituting  a  lex  specialis  to  this  Directive,  in  the  same  way  as  victims  of  terrorism  and 
trafficking have been addressed through specific legislation. It would include measures aimed 
at  preventing  this  kind  of  violence,  and  ensuring  adequate  protection,  access  to  justice, 
support  and  coordination  before,  during  or  after  criminal  proceedings  by  responding  to  the 
specific  needs  of  victims  of  violence  against  women  and  domestic  violence.  The  relevant 
legal  basis,  in  line  with  the  Victims’  Rights  Directive,  would  be  Article  82(2)  TFEU.  This 
provision provides for the establishment of minimum rules concerning the rights of victims of 
crime,  to  the  extent  necessary  to  facilitate  mutual  recognition  of  judgments  and  judicial 
decisions  and  police  and  judicial  cooperation  in  criminal  matters  having  a  cross-border 
dimension.  

In  addition,  the  initiative  would  introduce  minimum  standards  on  the  definition  of  criminal 
offences in the areas of crime set out in Art. 83(1) relating to sexual exploitation of women 
and  children  and  computer  crime.  Article  83(1)  TFEU  allows  for  the  establishment  of 
minimum  rules  concerning  the  definition  of  criminal  offences  and  sanctions  in  the  areas  of 
particularly serious crime with a cross-border dimension resulting from the nature or impact 
of such offences or from a special need to combat them on a common basis.  

It would further introduce, on the basis of Art. 83(2), minimum rules concerning the definition 
of serious forms of sexual harassment to ensure effective application of the Gender Equality 
Directives, which regulate this matter by providing definitions and requiring prohibitions and 
sanctions for sex-based and sexual harassment.160 Article 83(2) provides for the establishment 
of minimum rules with regard to the definition of criminal offences and sanctions in an area 
which  has  been  subject  to  harmonisation  measures,  if  the  approximation proves  essential  to 
ensure  the  effective  implementation  of  the  Union’s  policy  in  this  area.  The  background 
studies  conducted  for  the  initiative  show  that  the  implementation  of  the  relevant  provisions 
has  not  been  effective,  and  sexual  harassment  continues  to  remain  common  in  the  Member 
States.161  In order to  ensure effective implementation  of the policy, harmonisation  measures 
with regard to the definition and sanctions of serious forms of sexual harassment are essential 
to ensure the effective implementation of the Union’s policy.  

160  Directives  2006/54  and 2010/41  are  based on  the  current  Article  157(3)  TFEU.  Directive  2004/113  is based  on  Article 
13(1)  TEC  (currently  Article  19  TFEU).  The  inclusion  of  sex-based  harassment  in  these  instruments  may  be  considered 
ancillary to their respective main objectives. 
161 See above, Section 2.1.2 at p. 12 concerning the prevalence and at p. 26 concerning the effects on access to justice.  

31 

 
 
 
 
                                                 
When proposing EU accession to the Istanbul Convention, the Commission took the view that 
the appropriate legal bases for action in regard to the matters covered by the Convention are 
the  Treaty  provisions  in  the  fields  of  judicial  cooperation  in  criminal  matters  and  crime 
prevention. In its Opinion on the EU accession of 6 October 2021162, the CJEU confirmed that 
view.  The  Court  takes  a  broad  view  on  the  types  of  measures  that  can  be  adopted  on  these 
legal bases, in particular in the areas of prevention, protection, victim support, and access to 
justice163, as  envisaged in  this  initiative. The Court  also  clarified  that  aspects of substantive 
criminal law remain the primary responsibility of Member States and that criminalisation of 
specific types of conduct remains to a great extent subject to national law. The initiative 
takes  this  into  account  by  proposing  criminalisation  only  to  a  very  limited  extent.  It  would 
thus  be  based  on  the  combined  legal  basis  of  Art.  82(2)  and  83(1)164  and  83(2)  TFEU165. 
These  provisions  provide  for  the  adoption  of  directives  in  accordance  with  the  ordinary 
legislative procedure as the appropriate instrument. 

3.2. 3.2.  Subsidiarity: Necessity of EU action 

The  continuous  EU-wide  prevalence  of  violence  against  women  and  domestic  violence  and 
the  serious  harm  caused  to  individual  victims  and  societies  create  a  special  need  to  combat 
such violence on a common basis in the EU. In light of prevalence data and cost estimations, 
the impact on European societies is considerable. Millions of EU citizens and persons residing 
in  the  EU  are  concerned.  Violence  against  women  and  domestic  violence  violate  the 
fundamental rights of citizens and affects  gender equality, one of the fundamental values of 
the EU. 

In addition, cyber violence against women and in intimate partnerships has emerged as a new 
form  of  violence  against  women  and  domestic  violence,  spreading  and  amplifying  beyond 
individual  Member  States.  The  internet  is  inherently  a  cross-border  environment,  where 
content hosted in one Member State can be accessed from another Member State. As noted in 
the  DSA  proposal,  interventions  by  one  Member  State  will  be  insufficient  to  solve  the 
issue.166  

In  some  cases,  violence  against  women  and  domestic  violence  includes  a  physical  cross-
border element. On average 8% of women in the EU-27 report having experienced physical 

162 Opinion 1/19 of the Court of Justice of the European Union (Grand Chamber); 6 October 2021; A-1/19. 
163 See, in particular, points 295 and 297 of the Court’s opinion. The Court further clarifies that EU accession to the Istanbul 
Convention would require additional legal bases than those proposed by the Commission, in particular Art. 78(2) TFEU on 
asylum  and  Art.  336  TFEU  on  the  EU’s  staff  regulations  and  that  the  existing  legal  bases  of  sexual  exploitation  and 
trafficking  of  human  beings  in  Art.  83(1)  only  offer  room  for  criminalisation  at  EU  level  to  a  very  limited  extent.  This 
assessment is conducted against the scope of the concluding decisions. 
164  See  Directive  2011/36  of  5  April  2011  on  preventing  and  combating  trafficking  in  human  beings  and  protecting  its 
victims; Directive 2011/93 of 13 December 2011 on combating the sexual abuse and sexual exploitation of children and child 
pornography, and replacing Council Framework Decision 2004/68/JHA. 
165  The  required  prior  harmonization  in  the  area  of  harassment  was  effected  by  Directive  2006/54  of  5  July  2006  on  the 
implementation of the principle of equal opportunities and equal treatment of men and women in matters of employment and 
occupation; Council Directive 2004/113 of 13 December 2004 implementing the principle of equal treatment between men 
and women in the access to and supply of goods and services; Directive 2010/41 of 7 July 2010 on the application of the 
principle of equal treatment between men and women engaged in an activity in a self-employed capacity.  
166  European  Commission,  Commission  Staff  Working  Document:  Impact  Assessment  accompanying  the  Proposal  for  a 
Regulation of the European Parliament and of the Council on a Single Market for Digital Services (Digital Services Act) and 
amending Directive 2000/31/EC, SWD(2020) 348 final, 15 December 2020, pp. 35-36.  

32 

 
 
 
 
                                                 
violence in the past five years.167 This corresponds to more than 19 million women in the EU-
27. On average 3% of women victims of all physical violence reported the violence to have 
taken  place  abroad.168  Although  it  is  not  possible  to  establish  the  precise  share,  women 
victims of violence against women and domestic violence in cross-border situations are likely 
to  be  in  the  order  of  several  hundreds  of  thousands  in  Europe  annually,  also  taking  into 
account possible underreporting. 

In  other  cases,  the  cross-border  nature  may  arise  at  a  certain  point  during  proceedings,  for 
instance,  if  a  suspect  flees  or  a  victim  moves  to  another  country.  Even  after  criminal 
proceedings have concluded with  a final  judgment  imposing a sentence  on the defendant  in 
the  Member  State  of  nationality,  the  case  can  necessitate  judicial  cooperation  between 
Member  States.169  Cross-border  elements  may  equally  arise  when  criminal  cases  are 
transferred to another Member State.170  

The  current  initiative  not  only  covers  physical  cross-border  dimensions  of  violence  against 
women  and  domestic  violence,  but  the  rights  of  victims  of  these  crimes  in  general.  In  its 
opinion of 6 October 2021, the Court broadly lists the measures in the Convention related to 
victims’  rights  (prevention,  protection,  support,  access  to  justice)  for  which  the  EU  has 
competence,  not  presupposing  the  existence  of  a  physical  cross-border  element  in  all 
respects of the problem considered.  

Within the limits of EU competence as indicated by the CJEU, the issue should be addressed 
at  EU  level  in  order  to  ensure  a  minimum  level  of  protection  of  victims’  rights  and 
fundamental rights. The objective is not to achieve harmonised, equal protection everywhere 
in  the  EU,  but  to  establish  minimum  standards  for  rights  from  which  all  victims  of  such 
violence in the EU should benefit. The existence of minimum standards would also facilitate 
the mutual recognition of protection orders and judicial decisions concerning violence across 
the EU, thereby supporting a better application of the existing acquis in this area (see section 
2.1.2).   

3.3. 3.3.  Subsidiarity: Added value of EU action 

All  Member  States  have  addressed  violence  against  women  and  domestic  violence  in 
legislation  and  policies,  as  explained  in  Section  2.1.2.  Some  Member  States  have 
demonstrated  strong  commitment  to  address  such  violence  through  innovative  and  effective 
measuring,  including  during  the  Covid-19  pandemic.171  Over  the  last  decades,  the 
acknowledgement  of  this  kind  of  crime  has  led  to  the  adoption  of  specialised  national  and 

167 Supra 36.  
168 Supra 36, p. 27.  
169  European Commission, Commission Staff Working Paper: Impact Assessment accompanying the Proposal for a Directive 
on the rights of access to a lawyer and of notification of custody to a third person in criminal proceedings, SEC(2011) 687 
final, p. 23. 
170 European Commission, Commission Staff Working Paper: Impact Assessment accompanying the Proposal for a Directive 
establishing minimum standards on the rights, support and protection of victims of crime, SEC(2011) 580 final), p. 18.  
171  See  e.g.  European  Network  on  Victims'  Rights.  Specific  measures  during  COVID-19  crisis,  available  at 
https://envr.eu/specific-measures-during-covid-19-crisis/.  For  instance,  IE  has  developed  an  inter-agency  plan  to  address 
domestic  abuse  during  this  period  and  ran  various  awareness-raising  campaign,  as  well  as  directly  contacting  victims  who 
have reported domestic abuse in the past. In MT, law enforcement authorities use social media to share information on how 
to act in cases of cyber violence. In PT, channels for victims to seek help were strengthened and diversified. 

33 

 
 
 
 
                                                 
international frameworks. While these measures testify to the existence of the problem, they 
have not led to an observable decrease in this kind of violent crime in the EU.  

As discussed under Section 2.1.2, the approaches taken by Member States have also not been 
sufficiently  effective  in  guaranteeing  the  safety  and  protection  of  victims.  The  multitude  of 
national  approaches  creates  legal  uncertainty  on  the  rights  of  victims  of  violence  against 
women  and  domestic  violence.  The  fragmentation  is  more  substantial  at  regional  and  local 
levels, where differences in access to protection and support services are observed.  

The  EU  already  supports  the  Member  States  in  addressing  this  kind  of  violence,  but  EU-
action  has  been  limited  to  non-legislative  measures  (see  Section  5.1.1).  The  funding  and 
awareness-raising efforts have not been sufficiently effective in decreasing the prevalence of 
violence against women and domestic violence as criminal acts. Thus, legislative measures 
are  necessary  for  addressing  this  kind  of  violent  crime  in  an  effective  and  sustainable 
manner.   

While the effectiveness of national measures ultimately depends on Member States’ resources 
and  efforts,  EU  level  action  can  increase  their  effectiveness  by  specifying  minimum 
standards  and  adding  value  in  line  with  good  practices  and  recommendations  of 
international monitoring bodies and research. EU-legislation on violence against women and 
domestic violence would further align the EU legal framework with internationally recognised 
norms  and  permit  coordinated  action  at  EU  level.  It  would  enable  the  EU  to  enact  more 
specific  obligations  (see  Section  5.3  –  description  of  the  policy  options)  and  be  a  standard-
setter  in  preventing  and  combatting  violence  against  women  and  domestic  violence.172 
Through  the  approximation  of  criminal  definitions  and  sanctions,  it  would  ensure  victims’ 
access to justice in areas where specific gaps have been identified.173 

The  initiative  would  oblige  the  six  Member  States  who  have  not  ratified  the  Istanbul 
Convention  to  undertake,  to  the  extent  not  yet  done  on  their  own  initiative,  measures  that 
correspond to the minimum level of protection needed to tackle this kind of violence. For the 
21  Member  States  who  are  parties,  the  new  EU  measures  fill  identified  gaps  in 
implementation  and  effectiveness  and  enable  further  measures  to  be  taken  in  a  coordinated 
manner. 

While  the  initiative  would  be  adopted  by  qualified  majority,  it  would  feature  a  number  of 
mitigating measures that  it could make it acceptable to the six Member States that have not 
ratified the Istanbul Convention: in particular, the initiative would be limited in scope to areas 
of EU competence, and could clarify concepts prone to misconceptions.174  

Further EU action would allow the EU to support Member States in their efforts to implement 
their fundamental rights obligations in this field. It would enhance legal certainty by setting 

172 For information on measures taken globally, see OECD at https://www.oecd.org/development/sigi-2019-global-report-
bc56d212-en.htm. For recent legislative initiatives outside the EU, see e.g., 
https://www.legislation.gov.uk/ukpga/2021/17/introduction/enacted; https://fas.org/sgp/crs/misc/R46742.pdf; 
https://www.congress.gov/bill/117th-congress/house-bill/1620/text.  
173 See Section 2.1.2 at p. 26, Section 3.1.1. 
174 With regard to the misconceptions concerning same-sex marriage, education and reporting by professionals, see European 
Commission for Democracy through Law (Venice Commission), Opinion No. 961 / 2019, pp. 75-87, available at 
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2019)018-e.  

34 

 
 
 
 
                                                 
minimum  standards  to  ensure  that  all  Member  States  take  measures  in  all  policy  areas 
regardless of where in the EU the victims find themselves, and that national measures reach 
the level that is considered necessary for effectively addressing such violence.  

Targeted EU action would create added value in particular by enabling effective monitoring 
and enforcement. This is a decisive advantage of EU law, since international human rights 
bodies  do  not  have  the  possibility  to  launch  infringement  proceedings  against  a  Member  in 
cases  of  non-compliance  with  the  Convention.  While  Member  States  may  take  further 
measures  to  comply  with  international  obligations  (notably  following  periodic  reporting  to 
GREVIO and the CEDAW Committee), the added value of corresponding EU law obligations 
would be to  ensure compliance more swiftly and effectively. EU-level measures would also 
allow  for  comprehensive  EU-level  data  collection  and  contribute  to  a  more  nuanced 
understanding on this kind of violence.  

4.  4. 

Objectives: What is to be achieved? 

4.1. 4.1.  General objectives 

The general objective of the initiative is to prevent and combat violence against women and 
domestic violence as criminal acts and a form of discrimination between women and men as 
part of the European Area of Freedom, Security and Justice foreseen in Title V TFEU.  

4.2. 4.2.  Specific objectives 

The initiative pursues a number of specific objectives aimed at responding to the needs of this 
group of victims:   

-  Ensuring  effective  prevention  of  violence  against  women  and  domestic  violence: 
ensuring  that  effective  measures  are  in  place  to  prevent  violence  against  women  and 
domestic violence, including awareness-raising and information provision, training, work 
with perpetrators and the involvement of men and boys. 

-  Ensuring  effective  protection  of  victims  of  violence  against  women  and  domestic 
violence: ensuring that effective measures are in place to protect victims from violence 
online or offline, at work or in private. 

-  Ensuring effective access  to justice  in  cases  of violence against women  and domestic 
violence:  improving  access  to  justice  for  victims  of  violence  against  women  and 
domestic violence including through EU-level approximation of criminal definitions and 
sanctions  related  to  specifically  serious  forms  of  violence  against  women;  effective 
remedies  for  all  forms  of  such  violence;  as  well  as  by  ensuring  gender-sensitivity  and 
respect for the rights of child victims and witnesses. 

-  Ensuring  effective  victim  support  in  cases  of  violence  against  women  and  domestic 
violence:  ensuring  the  availability  of  general  and  specialised  support  services,  in 
sufficient  numbers  and  of  a  high  quality,  including  those  addressing  the  effects  of 
violence on physical and mental health.  

-  Ensuring strengthened  coordination in preventing and combatting  violence against 
women  and  domestic  violence:  ensuring  effective  and  efficient  coordination  and 
cooperation, including through multi-agency  approach and improved data collection on 
violence against women and domestic violence.  

The intervention logic of the initiative is summarised in Figure 2: 

35 

 
 
 
 
Figure 2 - Intervention logic 

5.  5. 

What are the available policy options? 

5.1. 5.1. What is the baseline from which options are assessed? 

5.1.1.  Dynamic baseline: EU level measures 

Under the baseline scenario, the EU would continue to address  violence against women and 
domestic  violence  through  the  existing  EU  legislative  instruments  described  in  Section 
2.1.2.  As  regards  cyber  violence  against  women  and  between  intimate  partners,  this 
framework  would  be  updated  by  the  DSA175  which  addresses  emerging  risks  in  the  online 
space,  including  to  women’s  safety  online,  by  setting  out  a  horizontal  framework  for 
regulatory oversight,  accountability  and transparency of intermediary service providers.  The 
DSA would notably oblige service providers to notify suspicions of serious criminal offences 
involving  a  threat  to  the  life  or  safety  of  persons;  this  would  be  likely  to  include  content 
inciting  to  serious  physical  and  sexual  violence  against  women,  including  gender-based 
killings  of  women.  The  DSA  would  also  oblige  very  large  platforms  to  undertake  risk 
assessments concerning fundamental rights, including risks related to non-discrimination. The 
DSA,  however,  does  not  define  what  is  illegal  or  criminal.  The  effectiveness  of  the 
obligations in the DSA thus depends on whether gender-based cyber violence is clearly illegal 
in  either  Member  State  or  in  EU  law.  The  Commission  would  continue  to  monitor  the 
implementation  of  the  relevant  legislation  and,  whenever  possible,  enforce  it  with  regard  to 
victims of violence against women and domestic violence.  

175 European Commission, Proposal for a Regulation of the European Parliament and of the Council on a Single Market For 
Digital Services (Digital Services Act) and amending Directive 2000/31/EC, COM(2020) 825 final, 15 December 2020. 

36 

 
 
 
 
 
 
                                                 
The  Commission  would  further  implement  the  non-legislative  measures  announced  in  the 
EU Gender Equality Strategy: It would launch an EU network on the prevention of violence 
against women and domestic violence, issue a Recommendation on the prevention of harmful 
practices  against  women  and  girls176  and  develop  a  Code  of  Conduct  between  online 
platforms  and  stakeholders  to  better  protect  women’s  safety  online.  The  Code  of  Conduct 
would  provide  for  self-regulatory  measures  for  service  providers  to  counter  illegal  and 
harmful  content  which  is  not  always  illegal,  thus  complementing  the  DSA  with  non-
legislative measures.  

In  addition,  the  Commission  would  continue  to  provide  funding  under  the  Citizens, 
Equality,  Rights  and  Values  Programme  (CERV)177  to  Member  States  and  non-
governmental  organisations  to  prevent  and  combat  violence  against  women  and  domestic 
violence  and  conduct  communication  activities  on  the  issue.178  The  Commission  has  been 
taking policy actions and funding national activities in this field, including on prevention and 
support  services  since  1997.179  Initially,  the  Commission  has  funded  organisations  and 
projects  tackling  violence  against  women  and  children  through  the  Daphne  funding 
programme,  which  was  later  integrated  as  a  funding  stream  into  the  Rights,  Equality  and 
Citizenship  (REC)  Programme  and  the  Citizens,  Equality,  Rights  and  Values  (CERV) 
Programme.  Based  on  rough  estimates,  the  Commission  has  funded  over  800  projects  to 
combat violence  against  women and children with more than 250 million  euros since 1997. 
Under the CERV programme, the Commission expects to spend approximately €150 million 
through  the  Daphne  strand  to  tackle  violence  against  women  and  children  throughout  the 
course  of  the  programme.  This  represents  almost  10%  of  the  total  budget  of  CERV  (€1.55 
billion). 

The  EU-level  actions  of  the  baseline  are  likely  to  remain  limited  in  effect,  since  they 
would  constitute  a  continuation  of  the  policy  actions  taken  by  the  Commission  for 
several  decades.  While  important,  the  baseline  policy  actions  would  not  suffice  to  prompt 
Member  States  to  step  up  their  national  measures  on  violence  against  women  and  domestic 
violence and to adequately prevent such violence, protect and support victims, ensure access 
to justice and establish better policy coordination. In the absence of further legislation in this 
area,  the  possibilities  to  enforce  the  existing  EU-level  legal  measures  would  remain  limited 
given  the  shortcomings  outlined  above.  EU  funding  under  the  Daphne  strand  of  the 
Citizenship, Equality, Rights and Values programme is essential to support organisations and 
projects  working  on  preventing  and  combatting  violence  against  women  and  domestic 
violence  on  the  ground.  However,  despite  a  significant  increase  in  the  programme’s  budget 
and  an  increased  focus  on  sustainability,  the  financing  of  projects  and  organisations  has 
inherent  limits  and  cannot  replace  structural  changes  in  national  legislation  and  state 
institutions. The interim evaluation report of the Rights, Equality and Citizenship Programme 

176  In  this  context,  the  Commission  would  also  continue  to  follow  the  take-up  of  the  Communication  on  female  genital 
mutilation. COM/2013/0833 final.  
177 https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/programmes/cerv.  
178 These measures would be supplemented by those outlined in the EU Strategy on victims’ rights and the EU Strategy on 
the Rights of the Child, respectively, to empower victims of GBV/DV and raise awareness about child victims and witnesses 
of such violence. 
179(https://ec.europa.eu/justice/grants/results/daphne-toolkit/daphne-toolkit-%E2%80%93-active-resource-daphne-
programme_en, last visited (19/08/2021)). For a description of the upcoming non-legislative measures, see Supra 2.4. 

37 

 
 
 
 
                                                 
shows  that  in  general,  the  Programme  activities  are  contributing  to  the  achievement  of  its 
objectives, but the impact on specific objectives such as gender equality is quite moderate, as 
more structural societal changes are needed.180 

5.1.2  Dynamic baseline: Member States measures 

The baseline takes into account the evolving situation in the Member States and the national 
measures  taken  to  prevent  and  combat  violence  against  women  and  domestic  violence.181 
The gap analysis covers the relevant national measures regardless of whether taken as a direct 
consequence of the country’s ratification of the Istanbul Convention or any other international 
obligation, as a result of the applicable EU acquis, or as purely national measures. As set out 
in  detail  in  Section  2.1.2  above,  there  are  significant  gaps  in  the  legislative  and 
implementation framework at national level.  

While  some  Member  States  have  demonstrated  significant  political  will  and  put  in  place 
ambitious  measures  to  prevent  and  combat  violence  against  women  and  domestic  violence, 
others are lagging behind. Even in Member States where the relevant measures are on a good 
level overall, GREVIO has identified room for further development (see the gap analysis in 
Annex  8).  The  studies  referred  to  above  confirm  that  the  national  measures  remain  uneven. 
This is the situation between those Member States that have ratified Istanbul Convention and 
those that have not, but also between the Member States that are parties to it.  

As explained above, EU accession to the Istanbul Convention remains uncertain; without it, 
there  is  little  incentive  for  those  Member  States  that  have  not  yet  acceded  to  step  up  their 
national  policy  response.  Member  States  that  are  parties  to  the  Convention  are  required  to 
improve their legal and policy frameworks following GREVIO’s assessment. However, this is 
a  lengthy  process:  Since  2016,  GREVIO  has  completed  baseline  assessments  of  10  EU 
Member  States  and  plans  to  evaluate  all  states  parties  by  2027.182  Subsequently,  a  further 
rounds of reporting are foreseen to evaluate the new measures and remaining gaps. GREVIO 
reports do not set a timeline for Member States to implement the recommendations; the EU 
Member  States 
implemented  all 
that  have  been  evaluated  so  far  have  not  yet 
recommendations. Furthermore, as with all international conventions, the Istanbul Convention 
does not have an enforcement mechanism that is comparable to the enforcement mechanisms 
under  EU  law.  Thus,  while  Member  States  may  eventually  achieve  full  compliance  with 
Istanbul Convention, this is unlikely to cover all EU Member States in the medium term and 
would take a lot longer than when supported by the envisaged initiative. 

180 Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee and 
the Committee of the Regions on the Interim Evaluation of the Implementation of the Rights, Equality and Citizenship 
Programme 2014-2020. 2018. https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52018DC0508  
COM/2018/508 final. 
181 In particular, the comparative study conducted by the European network of legal experts analysed the existing legislative 
and policy measures taken in each Member State. The national measures were also taken into account in the national research 
conducted  for  the  supporting  study  by  the  external  contractor.  Further  information  was  gathered  in  the  written  targeted 
consultation of the Member States, as well as from other stakeholders. 
182 https://www.coe.int/en/web/istanbul-convention/about-monitoring1.  

38 

 
 
 
 
                                                 
5.2. 5.2.  Options discarded at an early stage 

In  a  potential  non-legislative  option,  the  Commission  would  have  pursued  the  non-
legislative  measures  of  the  baseline  and  supplement  them  with  a  Recommendation  on  a 
gender-sensitive  application  of  the  relevant  EU  law  to  this  group  of  crime  victims.  This 
would  have  supported  the  Member  States  in  implementing  the  relevant  EU  obligations  in  a 
manner that is aligned with EU and international best practice from this field. This option was 
discarded  for  reasons  of  effectiveness.  Whereas  non-legislative  action  continues  to  be  an 
important element of addressing violence against women and domestic violence, it has limited 
effectiveness  in  terms  of  affecting  the  high  prevalence  of  this  violent  crime  in  the  EU  (see 
also Sections 3 and 7).  

An alternative policy option could have consisted of  legislative measures in one or two of 
the  problem  areas.  For  instance,  the  initiative  could  have  supplemented  the  existing 
legislative  framework  and  national  measures  with  EU-level  legislative  measures  on 
prevention.  Prevention  measures  are  vital  in  addressing  the  drivers  of  this  kind  of  violence, 
and  they  are  relatively  inexpensive  in  comparison  to  interventions  in  other  problem  areas. 
Similarly,  additional  obligations  could  be  envisaged  solely  in  the  area  of  victim  support 
and/or  coordination,  where  the  Victims’  Rights  Directive  already  includes  broad  legislative 
obligations. Such limited intervention to some problem areas only has equally been discarded 
for reasons of effectiveness. Since gaps have been identified in all five problem areas and it is 
internationally  recommended  to  adopt  a  holistic  approach  to  addressing  these  problems, 
action  on  one  or  more  of  the  problem  areas  alone  would  not  be  effective  in  addressing 
violence against women and domestic violence.  

Yet  another  policy  option  would  be  to  amend  the  relevant  14  instruments  of  EU  law. 
However, this would maintain the existing legal fragmentation at EU level and could not fill 
the  gaps  which  would  not  fit  under  any  of  those  instruments.  It  would  not  bring  about  the 
recommended holistic approach. In addition, amendments to the 14 instruments would need to 
be  embedded  in  a  more  general  evaluation  of  those  instruments  and  would  be  adopted  at 
different points in time, thus preventing a coordinated and consistent approach. In contrast, a 
targeted  EU-level  instrument  dedicated  to  this  group  of  victims  would  supplement  and 
support  the  application  of  the  above  EU  standards  and  lead  to  improved  efficiency  of  the 
current framework. It would create simplification for the benefit of the relevant professionals 
and  victims  by  focusing  the  relevant  EU  rules  in  a  single  instrument  in  a  transparent 
manner.  In  so  doing  the  initiative  would  follow  the  approach  of  other  policy  areas,  where 
general EU rules and international obligations have been supplemented by a targeted EU legal 
instrument such as on child sexual abuse and trafficking in human beings. 

A further policy option could have consisted of a proposal to request the Council to include 
gender-based  violence  as  an  area  of  crime  that  meets  the  criteria  specified  in  Article  83(1) 
TFEU (so-called ‘EU crime’). If adopted with unanimity at the Council, this proposal would 
establish  a  new  legal  base,  which  the  Commission  could  subsequently  use  to  propose  a 
directive to prevent and combat all forms of gender-based violence. The new legal base would 
enable  the  EU  to  approximate  criminal  definitions  and  sanctions  related  to  all  forms  of 
violence against women and domestic violence, and more broadly of gender-based violence. 
The  establishment  of  a  new  EU  crime  has  been  assessed  as  a  possible  measure  under  the 
access to justice problem area of policy option 2B, because it would differ from the current 

39 

 
 
 
 
directive by creating a legal bases for more extensive measures in that problem area. This is 
where the report discusses whether a new legal base would create added value or amount to 
unnecessary  duplication  of  Member  State  efforts  in  comparison  to  the  existing  legal  bases, 
which  leave  considerable  scope  for  supplementary  EU-level  criminalisations  and  allow  the 
current initiative to fill gaps in this problem area without a new EU crime.   

5.3. 5.3. Description of the policy options 

In line with the political mandate to propose legislative measures with the same aims as the 
Istanbul Convention (within the limits of EU competence), the Convention’s standards have 
been used as the point of departure for the development of the policy options.   

Two policy options are retained for assessment, both of which include a package of minimum 
standards aimed at addressing the gaps identified in the prevention and combatting of violence 
against women and domestic violence: 

  Policy option 1 (moderate).  This option consists of targeted measures to fill gaps in 
the  prevention  and  combatting  of  violence  against  women  and  domestic  violence 
based on the level of protection required by the Istanbul Convention (in the areas 
of EU competence).  

  Policy option 2 (comprehensive): This policy option builds on the measures outlined 
in the moderate option and introduces more comprehensive and detailed measures to 
ensure  higher  minimum  standards  and  facilitate  their  enforceability  and  to  address 
additional  gaps,  including  on  cyber  violence  against  women  and  sexual  harassment. 
The  distinction  between  sub-option  2A  and  sub-option  2B  consists  of  further-
reaching obligations, in the latter sub-option, on sexual harassment, access to justice, 
victim protection and data collection.   

The policy options are built around the five problem areas of prevention, protection from 
violence,  access  to  justice,  victim  support  and  coordination.  This  is  in  line  with  the 
approach  followed  by  the  Council  of  Europe  and  the  United  Nations183,  as  well  as  various 
Member States184, and is based on the expert view that coordinated action in these five areas 
is necessary to effectively tackle this kind of violence and safeguard the fundamental rights of 
victims.  The  specific  measures  included  in  the  five  problem  areas  have  been  chosen  in 
response to the gaps identified in the various studies and consultations and narrowed down to 
those where EU could add value.  

Policy  option  1  implements  the  policy  measures  of  the  Istanbul  Convention  at  EU  level, 
ensuring application of its standards (insofar as within EU competence) in all Member States 
and addressing gaps identified in existing Member State measures. In the field of prevention, 
it requires the Member States to conduct awareness-raising and research towards the general 
public and provide information on violence against women and domestic violence;  it further 

183  See  in  particular  CEDAW,  General  Recommendations  no.  19  and  35;  Istanbul  Convention,  https://rm.coe.int/coe-
istanbulconvention-brochure-en-r03-v01/1680a06d4f.  

184 EELN 2021, at 12, 156. The targeted consultation with Member States shows that up to 25 Member States have national 
action plans or similar policy instruments in place that apply to violence against women and domestic violence (see Annex 
2). Several cover measures from several problem areas (AT, BE, CY, CZ, EE, FI, HR, FR, IE, IT, PT, RO, SE, SI, ES). 

40 

 
 
 
 
                                                 
 
obliges  Member  States  to  set  up  or  maintain  perpetrator  programmes  for  participation  on  a 
voluntary  basis.  Member  States  would  be  required  to  provide  specialised  training  and 
information to professionals likely to come into contact with victims of such violence. In the 
area  of  protection,  it  aims  to  increase  the  effectiveness  of  the  cross-border  protection 
instruments  by  increasing  the  effectiveness  of  national  protection  measures.  To  this  end,  it 
includes  minimum  standards  on  the  availability  of  emergency  barring  orders  and  protection 
orders  and  supplements  the  Victims’  Rights  Directive’s  individual  needs  assessment  by 
requiring the authorities to assess the seriousness of the threat posed by a reported perpetrator 
on a victim’s health and safety. Concerning children, this option requires the Member States 
to  take  into  account  the  best  interest  of  child  victims  and  witnesses  in  cases  of  violence 
against  women  and  domestic  violence,  in  particular  by  providing  psychosocial  counselling, 
thus being more explicit than the Victims’ Rights Directive. With regard to  the reporting of 
violent  episodes  to  the  authorities,  policy  option  1  enhances  third  party  reporting  of  such 
violence  and  reporting  by  the  relevant  professionals.  In  the  area  of  victim  support,  policy 
option 1 supplements Articles 8 and 9 of the Victims’ Rights Directive by requiring Member 
States to provide comprehensive specialised support to this group of victims. It requires them 
to establish rape crisis centres to victims of sexual violence, provide for shelters and establish 
and  maintain  a  national  helpline  for  victims  of  violence  against  women.  As  regards 
coordination, policy option 1 encourages Member States to participate in regular survey data 
collection at EU-level following up on the FRA 2014 violence against women survey and the 
ongoing  Eurostat  survey  on  gender-based  violence.  It  likewise  obliges  them  to  regularly 
collect relevant administrative data. Finally, policy option 1 encourages cooperation between 
and multi-agency service provision by the relevant national authorities and non-governmental 
organisations. 

Policy  option  2A  includes  the  measures  of  policy  option  1,  but  goes  further  in  introducing 
obligations in the area of cyber violence against women and in intimate partnerships, which is 
not explicitly covered by the Convention’s wording. It additionally introduces further rules on 
sexual  harassment, thus aligning EU law also with the standards set by the ILO Violence and 
Harassment Convention.  

Sub-option 2A additionally  strengthens some of  the obligations and enables political  choice 
exceeding  the  level  of  the  Istanbul  Convention.  In  particular,  policy  option  2A  makes 
perpetrator programmes mandatory for reoffenders. It makes the targeted training of relevant 
categories  of  professionals  mandatory,  and  requires  Member  States  to  ensure  that  managers 
undergo  training  on  preventing  and  combatting  sexual  harassment  at  work.  They  would 
likewise be obliged to ensure that such harassment is addressed in national policies and risk 
assessments. Sub-option 2A strengthens the efficiency of the standards by including minimum 
standards  on  the  issuance,  conditions  and  enforcement  of  emergency  barring  orders  and 
protection  orders,  aimed  at  enhancing  their  effectiveness  at  national  level.  With  regard  to 
ensuring  the  safety  of  children  in  situations  of  violence,  policy  option  2A  requires  Member 
States to establish specific safe places where meetings can be organised between a child and a 
family member with regard to whom allegations of this kind of violence have been made. The 
option strengthens the reporting measures by requiring Member States to  establish easy  and 
accessible  reporting  mechanisms,  including  in  an  online  format  and  in  a  child-friendly 
manner.  In  the  area  of  access  to  justice,  the  option  builds  on  the  procedural  rights  of  the 

41 

 
 
 
 
 
 
Victims’  Rights  Directive  and  establishes  the  right  of  victims  to  obtain  full  compensation 
from the perpetrator in a single procedure.   

Concerning support services, policy option 2A requires Member States to facilitate access to 
specialised  support  for  groups  at  a  higher  risk  of  such  violence,  such  as  victims  with 
disabilities and migrant and asylum seeking victims, as well as to organise support in a child-
friendly  manner.  It  likewise  contains  obligations  on  victim  support  in  cases  of  sexual 
harassment  at  work  and  cyber  violence  against  women.  Policy  option  2A  deepens  the  data 
collection  obligations  by  making  participation  into  regular  EU-level  survey  data  collection 
obligatory,  and  introducing  minimum  requirements  on  harmonised  administrative  data 
collection.  In  the  field  of  coordination,  policy  option  2A  requires  coordinated  one-stop 
information provision on the relevant services.  

Lastly, policy option 2B further builds on the previous policy options and supplements some 
of the previous measures with a view to reaching utmost effectiveness. In the area of access to 
justice, the policy option aims to create a new legal base for minimum rules with regard to the 
definition of offences and sanctions by proposing to add gender-based violence on the list of 
the  so-called  EU  crimes  in  Article  83(1)  TFEU.  It  would  moreover  strengthen  the  existing 
obligations  on  state  compensation  to  victims,  establish  a  binding  threshold  for  shelter 
provision  and  oblige  Member  States  to  provide  the  relevant  services  through  a  one-stop 
mechanism. 

The main policy measures contained in each option are set out in more detail below.  

42 

 
 
 
 
 
 
 
 
Table 5.1.: Summary of options considered in addition to the baseline, with main measures 

Problem 
area 

Option 1 – Moderate measures 

Option 2 – Comprehensive measures 
N.B. All measures come in addition to the baseline and the measures under 
option 1 

Sub-option 2A 

Sub-option 2B 

/

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Measures 

Obligation on MS to provide 
targeted information to and raise 
awareness of the general public. 

Obligation on MS to provide targeted 
information to and raise the awareness of 
groups at risk185. 

Same as 2A 

Obligation on MS to have 
perpetrator programmes in place. 

Obligation on MS to make available 
voluntary perpetrator programmes to all 
those at risk of offending and mandatory 
programmes for re-offenders. 

Obligation on MS to make available 
voluntary perpetrator programmes to 
all those at risk of offending and 
mandatory programmes for all 
offenders. 

Obligation on MS to provide 
specialised training and targeted 
information to professionals 
likely to come into contact with 
victims and managers.  

Obligation on MS to ensure 
availability of emergency barring 
orders and protection orders. 

Obligation on MS to provide - 
specialised, regular and mandatory 
training to professionals likely to come 
into contact with victims; and - 
mandatory training to managers on 
sexual harassment at work and the 
effects of domestic violence on the 
workplace. 

Obligation on MS to ensure that sexual 
harassment at work is addressed in 
national policies.  Obligation on MS to 
ensure that company risk assessments 
cover sexual harassment at work. 

Obligation on MS to ensure efficiency 
through minimum standards on the 
issuance, conditions and enforcement  
of emergency barring orders and 
protection orders. 

Same as 2A 

Same as 2A 

Same as 2A 

Obligation on MS to conduct risk 
assessments on the seriousness of 
the threat of violence to victims. 

Obligation on MS to conduct risk 
assessments speedily and in cooperation 
with support services.  

Same as 2A 

Obligation to provide age-
appropriate psychosocial 
counselling to child victims and 
witnesses of domestic violence 

Obligation on MS to ensure the 
protection of children by providing for 
surveyed safe places for visits in case of 
allegations of domestic violence. 

Same as 2A 

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185 As defined in Section 2.2.1. 

EU-level criminalisations: 
Additional approximation of criminal 
definitions and sanctions on the basis of 
the legal bases of computer crime (ICT-
facilitated cyber violence), sexual 
exploitation (certain forms of sexual 
violence), and serious forms of sexual 
harassment. 

EU level criminalisations: 
Introduction of violence against 
women and domestic violence as a 
new EU crime. 

43 

 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Obligation on MS to encourage 
reporting of violence by third 
parties 

Obligation on MS to ensure easy and 
accessible reporting, including child 
friendly reporting mechanisms and 
online reporting. 

Same as 2A 

Right of victims to obtain full 
compensation from the perpetrator in one 
single procedure and within adequate 
time limits. 

Suboption A + Obligation on MS to 
provide state compensation in cases 
where victims cannot obtain 
compensation from the perpetrator or 
other sources.  

Beside general support services, 
obligation on MS to ensure a 
comprehensive and holistic 
specialised support to victims 
(including rape crisis centres, 
shelters and national helpline). 

Obligation on MS to facilitate access to 
specialised support services to groups at 
risk, such as children, migrant and 
asylum seeking women and women with 
disabilities. Connect national helplines to 
EU-level helpline 

Suboption A + Obligation on MS to 
provide 1 shelter space for 10,000 
inhabitants. 

Obligation on MS to provide specific 
support to victims of sexual harassment 
at work (including medical care and 
complaint mechanisms). 

Suboption A + obligation on MS 
special compensated leave for 
workers victim of violence against 
women or domestic violence. 

Obligation on MS to establish both on- 
and offline support for victims of cyber 
violence against women.  

Same as 2A 

Obligation to provide one-stop online 
access to relevant protection and 
support services. Encouragement to 
locate support services in the same 
premises. 

Obligation on MS to locate multi-
agency support services for victims 
in the same premises.   

Obligatory participation in surveys 
coordinated at EU-level 

Same as 2A 

/

agency cooperation. 

  Measures strengthening multi-
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Voluntary participation in surveys 
coordinated at EU-level. 

Obligation to regularly collect 
disaggregated relevant 
administrative data. 

Data collection: 
Obligation to regularly collect 
disaggregated relevant administrative 
data in line with a number of harmonised 
minimum requirements. 

Data collection: 
Integrated centralised data collection 
system at national level. 

/

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While option 1 would limit EU action to implementing Istanbul Convention standards through 
EU law, in matters relating to EU competence, the added value of option 2 (under both sub-
options  2A  and  2B)  is  double.  First  of  all,  option  2  contains  targeted  measures  on  cyber 
violence  against  women  and  sexual  harassment  at  work,  which  are  not  specifically 
addressed  in  the  Istanbul  Convention.  Secondly,  the  measures  under  option  2  have  been 
developed  in  comparison  to  the  standards  of  the  Istanbul  Convention  in  order  to  ensure  a 
better  implementation  in  line  with  good  practices  and  recommendations  recognized  by 
international experts in the field and international bodies such as GREVIO and in the UN.  

With  respect  to  the  first  main  added  value,  since  the  drafting  of  the  Istanbul  Convention, 
cyber  violence  against  women  and  in  intimate  partnerships  has  become  a  common 
phenomenon which  requires targeted action. Such violence is  also  an area where legal  gaps 
have been identified in the legal network study. Finally, action in this area is needed to ensure 
effective  implementation  of  the  future  DSA.  While  the  DSA  regulates  online  platforms’ 
responsibilities, including with  regard to  illegal  content, it does not  define such content.  By 

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
including a definition of cyber violence against women and between intimate partners at EU 
level186,  including  of  offences  concerning  non-consensual  sharing  of  intimate  or  private 
images, content and cyber stalking, the initiative would ensure that the requirements foreseen 
by the DSA can be fully applied to this kind of illegal content across the EU.    

With respect to sexual harassment at work, a more targeted action than that contained in the 
Istanbul  Convention  is  triggered  by  the  adoption,  in  2019,  of  the  ILO  Convention  no.  190. 
The inclusion of specific measures on this matter therefore aim at bringing EU law more in 
line with recent international standards.  

Regarding  the second main  added value, i.e.  a better implementation of the standards of 
the Istanbul Convention in line with  good practices and recommendations identified by 
experts and expert bodies from the Council of Europe (GREVIO) and the United Nations, the 
measures have been designed in the five problem areas because of two main reasons. Firstly, 
gaps  have  been  identified  in  all  five  areas,  going  from  a  lack  of  effective  prevention 
measures  such  as  targeted  information  provision  and  access  to  perpetrator  programmes,  to 
prosecutorial guidelines on this kind of violence for judges or access to shelters. Secondly, as 
recognized in the Istanbul Convention and all stakeholders, all five areas must be addressed to 
ensure  a  comprehensive  approach  to  tackle  gender-based  violence  against  women  and 
domestic violence, as well as to protect and support the victims and survivors.  

In light of the above, the presented policy packages present the most relevant, comprehensive 
and coherent approach to address violence against women and domestic violence in areas of 
EU  competence  and  with  regard  to  identified  gaps.  They  present  the  political  choice  of 
adopting in EU law the level of the standards of the Istanbul Convention (defined by what has 
been  feasible  at  the  international  level  in  2010)  or  deciding  to  take  into  account  recent 
developments in the areas of cyber violence against women and in intimate partner relations 
and  sexual  harassment  as  well  as  good  practices  and  recommendations  resulting  from  a 
review of the existing implementations. Within this latter option, the two sub-options present 
the choice between less or more far-reaching measures. 

6.  6. 

What are the impacts of the policy options? 

This chapter assesses the impacts of the two policy options (and sub-options) in terms of their 
fundamental rights impact, social impact and economic impact. Some tangible impacts can be 
assessed quantitatively, but the central aspect of this initiative is to strengthen the fundamental 
rights of those affected by violence against women and domestic violence, some elements of 
which cannot  be monetised.  The  aim of the initiative is  not only  to reduce prevalence of 
violence through prevention, but also to ensure fundamental rights of the women victims 
of  violence  and  victims  of  domestic  violence  and  to  diminish  negative  societal  impacts  and 
improve victims’ quality of life.  

186 The envisaged definition would refer to any act of gender-based violence against women that is committed in part or fully 
by  the  use  of  information  and  communication  technologies,  such  as  mobile  phones  and  smartphones,  the  internet,  social 
media platforms or e-mail. It draws on the upcoming General Recommendation on the digital dimension of violence against 
women of GREVIO, to be issued later this year and is based on the work of the Council of Europe Cybercrime Convention 
Committee “Working Group on cyberbullying and other forms of online violence, especially against women and children”. 

45 

 
 
 
 
 
                                                 
6.1. 6.1.  Fundamental rights 

Violence against women and domestic violence have been recognised to impact negatively a 
number  of  human  rights.187  Pursuant  to  Article  6(3)  of  the  TEU,  fundamental  rights,  as 
guaranteed  by  the  ECHR,  constitute  part  of  EU  law  as  general  principles;188  moreover,  the 
European  Court  of  Human  Rights’  (‘ECtHR’)  jurisprudence  is  taken  into  account  in 
interpreting corresponding rights of the Charter of Fundamental Rights (‘CFR’). The ECtHR 
has established comprehensive obligations on states parties to prevent, investigate and punish 
this kind of violence and effectively protect victims. 

All  policy  options  are  expected  to  strengthen  the  protection  of  fundamental  rights,  but  to  a 
different  degree.  Negative  fundamental  rights  impacts  have  not  been  identified  for  either 
option or sub-option.  

Option  1  builds  on  the  rights  provided  to  crime  victims  under  EU  law  and  specifies  their 
modalities of application to victims of violence against women and domestic violence in line 
with  international  obligations.  Option  2  sets  out  more  extensive  obligations,  thus  providing 
more extensive protection to victims. It includes specific measures against cyber-violence and 
sexual harassment, in particular at work. Sub-option 2B foresees further-reaching obligations 
as  for  victims  compensation  and  support  that  increase  the  positive  impact  on  fundamental 
rights. The impact of the two options and the sub-options on individual fundamental rights is 
summarised in  the table below, with  ‘(+)’ pointing to  a slightly better performance than the 
baseline, and ‘+++’ pointing to the the best performance among the options.  

Fundamental Rights  

Policy 
option 1 

Policy option 2 

integrity/prohibition  of  degrading 

to 

Right to life 
Right 
treatment; right to private and family life 
Rights of the child 
Prohibition of discrimination  
Rights of older people and people with 
disabilities 
Right to social assistance and healthcare 
Right to an effective remedy and a fair trial 
Right to fair and just working conditions 

+ 
+ 

+ 
+ 
+ 

+ 
+ 
+ 

Sub-option A  Sub-option B 
++ 
++ 

++(+) 
+++ 

++ 
++ 
++ 

++ 
++ 
++ 

++ 
++ 
++ 

++ 
+++ 
+++ 

Right  to  life  (Article  2  CFR),  right  to  integrity  (Article  3  CFR)  and  prohibition  of 
inhuman  or  degrading  treatment  (Article  4  CFR),  right  to  private  and  family  life 

187 The United Nations consider violence against women as a form of gender-based discrimination and invited UN Member 
States to exercise ‘due diligence to prevent, investigate and, in accordance with national legislation, punish acts of violence 
against women, cf Declaration on the Elimination of Violence against Women. Proclaimed by General Assembly resolution 
48/104 
at: 
(https://www.ohchr.org/en/professionalinterest/pages/violenceagainstwomen.aspx); R.J.A. McQuigg, “Domestic Violence as 
a  Human  Rights  issue:  Rumor  v.  Italy”,  European  Journal  of  International  Law,  Vol.  26(4),  2016,  pp.  1010-1012,  1016, 
1021. 
188 Articles 51(1), 52(3) of the Fundamental Rights Charter. 

December 

available 

1993, 

20 

of 

46 

 
 
 
 
 
 
 
 
 
 
                                                 
(Article  7  CFR):  These  rights  are  particularly  relevant  for  acts  of  this  kind  of  violence,  in 
particular in cases of physical VaW/DV which,  at most serious, can lead to the death of the 
victim. Both policy options would have a positive impact on these rights because they foresee 
measures  to  strengthen  the  protection  of  persons  at  risk  of  violence  against  women  and 
domestic violence. Both options would require Member States to conduct a risk assessment of 
the seriousness of the threat posed by a prospective perpetrator to the potential victim, taking 
into  account  all  relevant  circumstances,  e.g.  if  the  perpetrator  owns  weapons.  Both  options 
also oblige Member States to ensure the availability of protection orders for all forms of this 
kind  of  violence.189  Option  2  would  further  improve  the  efficiency  of  national  protection 
orders  by  establishing  minimum  standards  for  the  issuance,  conditions  and  enforcement  of 
emergency  barring  orders  in  case  of  imminent  threats  to  the  victim’s  life  or  integrity.  Both 
options  would  likewise  contribute  to  establishing  effective  criminal  law  provisions  on 
violence against women  and domestic violence, thereby  deterring offences and  allowing for 
effective  punishment;  the  ECtHR  considers  that  this  is  a  key  part  of  Member  States’ 
obligations  to  ensure  protection  of  the  above-mentioned  rights.190  Option  2A  would 
criminalise  at  EU  level  certain  forms  of  violence  against  women  and  domestic  violence  on 
existing legal bases.  Option  2B  would  also  introduce  violence against women and domestic 
violence as a new area of EU crime under Article 83 TFEU, which can be expected to have a 
deterrent  effect  on  potential  perpetrators  of  violence  against  women  and  domestic  violence. 
Moreover,  both  options  include  training  for  professionals  likely  to  come  into  contact  with 
victims of violence against women and domestic violence, thereby increasing their ability to 
recognise this kind of violence and to respond with diligence.191 Option 2 would go further 
by making the training mandatory and regular. Both options would facilitate the reporting of 
violence against women and domestic violence by encouraging reporting by third parties.  

Rights  of  the  child  (Article  24  CFR):  Article  24  CFR  grants  children  the  right  to  such 
protection  and  care  as  is  necessary  for  their  well-being,  and  provides  that  the  child's  best 
interests have to be a primary consideration in all actions relating to children, as well as the 
right  of the child to  be  heard and to  maintain on a regular basis a personal  relationship  and 
direct contact with both parents, unless that is contrary to the child’s interests.192 Both options 
can be expected to have a positive impact on these rights by imposing  specific measures to 
protect and support child victims  and witnesses of violence against women and domestic 
violence. Both options require Member States to handle cases of violence against women and 
domestic violence in a manner that ensures the best interest of the child, to recognise child 

189 The ECtHR found violations of the right to life in cases of domestic violence, when the authorities knew or ought to have 
known of the existence of a real and immediate risk to the life of an identified individual, and failed to take measures within 
their  powers  which,  judged  reasonably,  might  have  avoided  that  risk,  see:  ECtHR,  Opuz  v.  Turkey,  Application  No. 
33401/02,  Judgment,  9  June  2009,  §128;  ECtHR,  Rantsev  v.  Cyprus  and  Russia,  Application  No.  25965/04,  Judgment,  7 
January 2010, §§218-219; ECtHR, Branko Tomašić and Others v. Croatia, Application No. 46598/06, Judgment, 15 January 
2009, §§ 49-51. 
190  ECtHR,  Buturugă  v.  Romania,  application  No.  56967/15,  judgment  of  11  February  2020.  Also  ECtHR,  Volodina    v. 
Russia (no. 2), application  no. 40419/19, judgment of 14 September 2021, at 50, 56-58, 68, finding e.g. that certain acts of 
cyberviolence can be sufficiently serious to require a criminal-law response.  
191  ECtHR,  Opuz  v.  Turkey,  Application  No.  33401/02,  Judgment,  9  June  2009,  §200;  ECtHR,  Tërshana  v.  Albania, 
Application No. 48756/14, Judgment, 4 August 2020, §160; ECtHR,  Kurt v. Austria, Application No. 62903/15, Judgment, 
15 June 2021 (Grand Chamber), §172. 
192 Also Article 19 of the United Nations Convention on the Rights of the Child. 

47 

 
 
 
 
                                                 
witnesses as victims of violence against women and domestic violence and to provide age-
appropriate psychosocial counselling, which will positively impact on the right of the child to 
be  heard.  Option  2  additionally  obliges  authorities  to  ensure  that  visits  of  children  can  take 
place in surveyed safe spaces outside the home of an alleged perpetrator. Such arrangements 
would have a strong positive impact on safeguarding the best interests of the child. 

Right to an effective remedy and a fair trial (Article 47 CFR): Both options strengthen the 
right to an effective remedy for victims of violence against women and domestic violence. In 
addition  to  introducing  EU-level  criminalisations  as  discussed  above,  both  options  foresee 
measures  to  ensure more effective investigation and prosecution of  violence against women 
and domestic violence. Both options provide, for EU-level criminalisations, that prosecuting 
authorities should pursue certain offences of violence against women and domestic violence 
on  their  own  motion  and  as  a  matter  of  public  interest,  even  if  the  victim  does  not  lodge  a 
complaint  or  withdraws  the  initial  complaint  in  the  course  of  the  proceedings.193  Together 
with  the  protection  measures,  these  can  be  expected  to  further  tackle  the  delays  in 
investigation, prosecution and adjudication of violence against women and domestic violence 
cases.  In  addition,  option  2  obliges  Member  States  to  issue  guidelines  on  violence  against 
women and domestic violence to law enforcement and judicial authorities, which would help 
them  to  more  effectively  address  it,  apply  consistent  procedures  and  strengthen  cooperation 
with  other  agencies  to  ensure  safety  and  offender  accountability.  Together  with  the  training 
for professionals, these measures can be expected to facilitate victims’ access to justice.  

Both options likewise improve the availability of compensation to victims. Option 1 requires 
Member  States  to  provide  information  on  how  compensation  may  be  accessed.  Option  2A 
would  strengthen  the  right  by  establishing  a  right  to  full  compensation  from  the  perpetrator 
and ensure that victims can obtain compensation in one single procedure (avoiding secondary 
victimisation).  Option  2B  would  ensure  access  to  compensation  by  the  state  where  no 
compensation  can  be  obtained  from  the  perpetrator  or  other  sources,  beyond  what  currently 
exists  in  EU  law.  Option  2  also  introduces  low-threshold  online  reporting  of  incidents  of 
violence  against  women  and  domestic  violence,  which  would  facilitate  the  reporting  by 
victims.  

Non-discrimination  and  equality  between  women  and  men  (Articles  21  and  23  CFR): 
Both  options  acknowledge  violence  against  women  and  domestic  violence  as  prohibited 
discrimination  between  women  and  men,  thereby  aligning  EU  law  with  international 
standards,194 and expanding victim’s access to anti-discrimination law remedies. Both options 
would also have a positive impact in mitigating the risk of this kind of violence for persons in 
vulnerable  situations  and  groups  at  a  heightened  risk195  through  the  improved  protection, 
support  and  access  to  justice.  Additionally,  option  2  obliges  authorities  to  conduct  targeted 
awareness-raising  and  information  provision  activities  to  reach  out  to  groups  at  risk  and  to 

193 See ECtHR, cf Opuz v. Turkey, §145. 
194 CEDAW, General Recommendation No. 19; CEDAW, General Recommendation No. 35; ECtHR, Opuz v. Turkey, cited 
above, §200.  
195  Such  as  women  from  ethnic  minorities,  women  living  in  rural  areas,  women  migrants  and  asylum  seekers,  women  sex 
workers  and  women  detainees,  see  e.g.  Council  of  Europe,  Combating  violence  against  women:  minimum  standards  for 
support services, 2008, pp. 8-13. 

48 

 
 
 
 
                                                 
facilitate their access to support services.  It would therefore have a more positive impact on 
the right to non-discrimination. In the same way, both options would strengthen, for example, 
the rights of older persons in cases of intergenerational domestic violence (Article 25 CFR), 
and  the  integration  of  persons  with  disabilities  (Article  26  CFR),  again  with  option  2 
having a more positive impact for the reason set out just above.  

Rights  to  social  assistance  and  health  care  (Article  34  and  35  CFR):  Option  1  requires 
Member  States  to  provide  specialist  services  to  women  victims  of  violence  against  women 
and domestic violence such as immediate medical support, the collection of forensic medical 
evidence  in  cases  of  rape  and  sexual  assault,  short  and  long-term  psychological  counselling 
and trauma care. This reinforcement of specialist services would have high positive impacts 
on  the  rights  to  social  assistance  and  health  care.  Both  options  require  Member  States  to 
provide  specialist  support  services  to  victims  of  sexual  violence,  which  can  be  expected  to 
significantly contribute to the effective access to these services by victims of violence against 
women.  The  effectiveness  of  the  measures  would  be  further  enhanced  by  the  guidelines  to 
health  and  social  service  providers  foreseen  in  option  2.  In  response  to  the  widely  noted 
shortage  of  shelters,  particularly  in  remote  and  rural  areas,  option  1  and  option  2A  oblige 
Member States to provide shelters in sufficient numbers and in an accessible manner, without 
imposing  a  minimum  threshold.  Option  2B  specifies  that  Member  States  shall  provide  1 
shelter space per 10,000 inhabitants (as recommended by the Council of Europe). Since the 
provision of shelters plays a vital role to protect victims from (further) acts of violence, option 
2B, to the extent that Member States would not have voluntarily reached the threshold, would 
provide  higher  protection  for  victims  in  this  regard.  Option  2B  would  also  have  a  higher 
impact on access to social assistance and health care by granting special compensated leave 
from  work  for  victims  of  violence  against  women  and  domestic  violence  and  ensuring  that 
victims can access all relevant services in the same premises.   

Right to fair and just working conditions (Article 31 CFR): Both sub-options of option 2 
would reinforce the victims’ right to fair and just working conditions by introducing specific 
provisions on sexual harassment at work. The combination of awareness raising and Member 
State  obligations  on reporting  would encourage  more victims  to  report harassment  and seek 
redress, thereby discouraging such behaviour in the long-term. 

Other rights: The measures on access to justice elements would carefully take into account 
the  presumption  of  innocence  and  right  of  defense  (Article  48  FRC),  in  particular 
regarding the approximation of definitions and sanctions at EU-level. Both options take into 
account the perspective of suspected and accused persons and do not affect the application of 
defense  rights  by  national  courts.196  Both  options  are  likewise  in  line  with  the  principles  of 
legality and proportionality of criminal offences and penalties (Article 49 FRC).  

196 See Council of Europe, Guide on Article 6 of the European Convention on Human Rights. Right to a fair trial (criminal 
limb), available at https://www.echr.coe.int/Documents/Guide_Art_6_criminal_ENG.pdf, at 525-529, finding that while a fair 
balance must be struck between the parties, in criminal proceedings concerning sexual offences, rights of the defense do not 
prevent  measures  being  taken  for  the protection  of  victims  as  regards  in  particular  the  examination  of  witnesses  and other 
victim protection measures. 

49 

 
 
 
 
                                                 
6.2. 6.2.  Social impacts 

All policy options contribute to alleviating the social impacts of violence against women and 
domestic violence described in Chapter 2 to a different degree. These positive impacts affect 
various stakeholders, namely victims, witnesses, perpetrators, companies, national authorities 
and  the  wider  society.  Social  impacts  are  assessed  in  this  section  only  qualitatively  by 
stakeholder.  A  detailed  description  by  measure  is  in  Annex  5.  Estimates  of  some  of  these 
outcomes are included in the next section on the economic impacts, where the benefits of the 
options  are  quantified  as  the  induced  reduction  of  the  current  socio-economic  costs  of 
violence against women and domestic violence (see section 6.3.1).   

Both options would improve the baseline and improve victims’ health, safety and quality of 
life  (especially  through  the  measures  on  protection  and  support),  while  contributing  to 
changing  harmful  social  norms  and  behaviors  through  prevention.  This  would  result  for 
instance  in  a  reduction  of  psychological  trauma  for  victims  and  better  psychological, 
behavioural  and  physical  consequences  for  survivors,  since  violence  against  women  and 
domestic  violence  victimisation  is  associated  with  increased  smoking,  substance  use,  and 
risky sexual behaviours. It can also lead to depression, post-traumatic stress and other anxiety 
disorders,  sleep  difficulties,  eating  disorders,  and  suicide  attempts.  Finally,  intimate  partner 
violence in pregnancy also increases the likelihood of miscarriage, stillbirth, pre-term delivery 
and low birth weight of babies.197  

All  options  would  increase  victims’  and  witnesses’  awareness  of  and  access  to  relevant 
information on the available protection and support, and facilitate more active participation in 
society, including in the labour market, including entrepreneurship. This could be particularly 
beneficial  for  people  from  disadvantaged  socio-economic  backgrounds  or  victims  at  risk  of 
intersectional  discrimination,  e.g.  due  to  migrant  background  or  disability.  Targeted 
protection  measures  and  support  services  to  child  victims  and  witnesses  are  expected  to 
decrease violence against women and domestic violence against these groups.198  

All options would ensure that support services provided to victims of violence against women 
and  domestic  violence  be  based  on  an  understanding  of  the  victim’s  specific  needs  and  be 
available  and  accessible  for  all  victims.  Measures,  such  as  specialist  support  services  for 
survivors  of  sexual  violence  and  ensuring  a  sufficient  amount  of  beds  in  shelters,  may  be 
expected to have significant social impact. Option 2B would have the greatest impact in that it 
would set a mandatory standard on shelter availability. 

Measures  on  intervention  programmes  for  perpetrators  are  expected  to  have  a  positive 
impact on the latter’s attitudes and behaviour. Also more appropriate sanctions against illegal 
behaviour  would  act  as  a  deterrent  to  those  at  risk  of  offending.  Option  2  would  have  a 
stronger  impact  on  perpetrators,  because  it  would  foresee  not  only  voluntary  treatment 
programmes  but  also  mandatory  participation  for  repeated  offenders  or  (option  2B)  all 

197  Research  and  Statistics  Division  Department  of  Justice  Canada,  Nadine  Wathen,  2012,  “Health  Impacts  of  Violent 
Victimization  on  Women  and  their  Children”.  A.  Morrison,  M.  Ellsberg  &  S.  Bott  (2007),  Addressing  Gender-Based 
Violence: A Critical Review of Interventions.  
198 UNODC, INSPIRE: Seven Strategies for Ending Violence Against Children.  

50 

 
 
 
 
                                                 
offenders.  In  addition,  it  would  specifically  address  the  growing  phenomenon  of  cyber 
violence, as well as sexual harassment, thus providing a more targeted approach than option 1.   

Measures on sexual harassment, in particular at work (option 2) would increase awareness, 
better understanding and support for workers who are victims of harassment and abuse. This 
would  allow  developing  a  safe  work  environment  and  therefore  have  positive  impact  on 
productivity, also linked to lower sick leaves. These benefits are expected to be higher than 
the limited costs linked to the implementation of the envisaged measures (see section 6.3.2). 
Even  already  functional  and  respectful  workplaces  would  benefit  from  recognition  of  a 
broader support offered to employees and a better work environment.  

Finally,  both  options  are  likely  to  have  a  positive  impact  for  national  authorities.  They 
would bring about clear political messaging concerning the social unacceptability of violence 
against  women  and  domestic  violence  and  address  the  problem  of  legal  fragmentation  and 
uncertainties.  They  would  ensure  a  strong  policy  framework,  based  on  strengthened 
coordination and cooperation between the law enforcement, the judiciary and the social and 
health services. The expected benefits largely offset the costs linked to the implementation of 
some of these measures (see section 6.3). Option 1 is likely to have stronger political support, 
even  if  some  reluctance  because  of  the  cost  implications  and  political  discourse  around 
gender-related  matters  could  be  expected,  particularly  in  the  countries  that  have  not  ratified 
the  Istanbul  Convention.  This  applies  even  more  to  option  2,  ,  as  it  goes,  on  some  points, 
beyond  the  standards  set  out  in  the  Istanbul  Convention  and  may  therefore  require  higher 
investments in some Member States (see point 6.3 below).  

Both options are also expected to have a positive impact on society as a whole, as they would 
increase  the  recognition  of  abusive  behaviour  and  reduce  the  acceptance  of  such  behaviour 
among  the  general  public,  thus  contributing  to  a  safer  environment  for  women  and  other 
potential victims, as well as improving public health.  Both policy options are also expected to 
lead  to  an  increase  in  cases  detected,  reported,  prosecuted  and  sanctioned,  leading  to 
improved justice across society.  

6.3. 6.3.  Economic impact 

The current cost to society of violence against women and domestic violence amounts to €290 
billion  per  year.199  EIGE  computed  these  costs  by  extrapolating  the  costs  computed  by  the 
Home  Office  for  UK.  The  extrapolation  of  costs  to  the  EU  is  impacted  by  differences  in 
prevalence rates across Member States, both in surveys and in reported cases, and differences 
in government expenditures and in the cost of services (and so implicitly by their efficiency) 
compared to the UK system. However, the largest part of these costs (around 56%) are due to 

199 EIGE, Report on the costs of gender-based violence in the EU,  
EIGE (2021), The costs of gender based violence in the European Union: Report, Publications Office of the European Union, 
Luxembourg.  These  costs  do  not  include  the  societal  costs  of  gender-based  cyber-violence,  which  have  been  estimated  at 
€49-89 billion (N. Lomba, C. Navarra, M. Fernandes, Combating Gender-based Violence: Cyber Violence, briefing, EPRS, 
European Parliament, 2021) as well as other broader not quantifiable indirect social costs e.g. lack of trust in institutions, fear 
of crime,… 

51 

 
 
 
 
                                                 
psychological, emotional and physical damage that are comparable across Member States.200 
Moreover, a sensitivity check, based on the relative prevalence of violence against women in 
the  EU  and  where  Member  States  are  compared  to  the  UK  (on  which  the  calculations  are 
based)  allows  to  verify  the  overall  magnitude  of  the  costs  of  violence  against  women. 
Weighing  the  costs  of  violence  against  women  based  on  FRA  (2014)  data,  we  obtain  an 
overall cost of €278 billion.  

Similar studies have been conducted in single countries. For example, a study on the cost of 
violence against women in Italy201 placed this cost at €24.5 billion. Direct costs for healthcare 
are relatively bigger than in the UK study, but overall the loss due to emotional and physical 
damages  represents  a  bigger  share  of  the  total  costs  (86%).  An  earlier  study  on  Sweden 
(2006), focusing on intimate-partner violence (and not considering loss in the quality of life), 
placed the costs at about €330 million.  

Both  options  are  expected  to  reduce  the  cost  of  violence  by  inducing  a  reduction  in  the 
prevalence of violence against women and domestic violence in the EU through prevention, 
protection, access to justice, support and inter-agency coordination. The related cost reduction 
is the expected benefit of the intervention and is  analysed in the following sections. Further 
sections analyse the direct cost implications.   

6.3.1 

Estimated benefits: reduction of costs of violence  

The support study estimates the economic benefits of policy options 1 and 2 (and sub-options) 
by  assessing  the  reduction  of  the  different  items  which  make  up  the  overall  cost  to 
society  of  violence  against  women  and  domestic  violence:  direct  cost  of  services  (to 
victims  or  to  public  service  providers);  lost  economic  output;  and  the  physical  and 
emotional  impacts  measured  as  a  reduction  in  the  quality  of  life  under  two  different 
scenarios of decrease of violence against women and domestic violence. The expected impact 
of  the  two  policy  options  depends  mainly  on  their  potential  to  reduce  the  prevalence  of 
violence against women and domestic violence in the short and the long run.  

This  approach  is  aligned  with  research202  conducted  by  the  European  Parliament  Research 
Service  (EPRS).  However,  other  than  the  EPRS  research  which  focuses  on  establishing 
gender-based  violence  as  a  new  EU  crime,  the  proposed  policy  options  take  a  holistic 
approach, as advocated by stakeholders,203 and foresee a comprehensive set of measures in the 

200 The computation of the unit cost of crimes in 2018 Home office study (Heeks, M., Reed, S., Tafsiri, M. and Prince, S. 
(2018), The Economic and Social Costs of Crime – Second edition, Research report 99, Home Office, London) is carried out 
for all types of crimes. This lack of specificity means that the relationship between victim and perpetrator is not taken into 
account. Since this could be an important element, particularly as for the long term consequences of domestic violence, the 
emotional and psychological impact is likely to be underestimated. Moreover, the study computes the loss of productivity of 
victims as the value of hours of work lost by employed victims, taking into account the likelihood of them suffering specific 
injuries. As a consequence, the long term impact in terms of labour market efficiency is not taken into account.  
201 (How much does silence cost? National survey on economic and social costs of violence against women) Quanto costa il 
silenzio? Indagine nazionale sui costi economici e sociali della violenza contro le donne, Intervita, 2013. 
202  “Gender-based  violence  as  a  new  area  of  crime  listed  in  Article  83(1)  TFEU  -  European  added  value  assessment”, 
European Parliament Research Service, 2021. The report computes the possible impact of introducing GBV as a new area of 
crime  listed  in  Article  83(1)  TFEU  as  the  expected  yearly  economic  benefits  in  the  short  and  in  the  long  run  due  to  a 
reduction on the social cost of violence against women. The EPRS report assumes that a policy intervention would decrease 
GBV/DV prevalence by 10% in the short run (after about five years from the start of implementation) and 20-30% after about 
10 years. The reduction is estimated at about €25.1 billion and in the long run of a reduction between €54.4 and €83.9 billion.  
203 Various stakeholders from Member States, international organisations, NGOs to social partners were consulted through 
targeted consultation during May-July 2021. See Annex 2. 

52 

 
 
 
 
                                                 
areas  of  prevention,  protection,  access  to  justice,  support  and  coordination.  They  should 
therefore  in  principle  lead  to  a  higher  reduction  of  prevalence  compared  to  the  option 
examined  by  the  EPRS.  Nevertheless,  this  assessment  takes  a  conservative  approach  due  to 
the  limited  research  on  the  impact  of  legislation  on  reduction  of  prevalence  of  violence 
against  women  and  domestic  violence.  In  addition,  this  approach  considers  that,  due  to 
underreporting, there is likely to be an increase in reported prevalence rates in the beginning 
and therefore lower net benefits. This initial increase in costs is, however, actually a positive 
effect of the initiative. To sum up, in order to provide a more realistic assessment, this impact 
assessment  assumes  that  the  expected  impact  of  the  initiative  would  not  exceed  the  EP’s 
estimated  overall  reduction  of  violence  against  women  and  domestic  violence  linked  to  its 
potential introduction as a new area of crime.  

Given  the  low  number  of  impact  assessments  of  measures  against  violence  against  women 
and domestic violence overall and in particular for the EU context, reference is made mostly 
to  examples  from  the  USA.  According  to  WHO  estimates  for  2018,  the  intimate-partner 
violence  prevalence  rates  for  the  US  are  slightly  higher  than  in  the  EU27:  26%  against  an 
average  for  the  EU27  countries  of  around  18%  for  intimate-partner  violence  lifetime 
prevalence and 6% against 4.4 % for 12 month intimate-partner violence. This suggests that 
referring to US outcomes does not overestimate the results for the EU. 

The (5-year) short-term impact assumption is based on estimated impact204 of the introduction 
of the US Violence Against Women Act of 1994 on annual rates of criminal victimisation of 
women.  Moreover,  protection  measures,  such  as  the  availability  of  protection  orders  and 
enhanced  reporting  opportunities  of  violence  against  women  and  domestic  violence,  have 
been  shown  to  be  associated  with  a  34%205  and  40%206  reduction  in  the  risk  of  repeated 
victimisation  through,  for  example,  continuing  domestic  violence.  Similarly,  based  on  an 
assessment  of  the  US  National  Crime  Victimization  Survey,  the  use  of  victim  services  was 
shown to be associated with a 40% reduction in the risk of repeated victimisation.207  

The (10 years) long-term assumption is based on an assessment of two main studies: 

  Analysis based on Demographic and Health Surveys data for selected countries in the 
global south finds that each additional year that a country has had domestic violence 
legislation in place208 is correlated with a 2% decrease in prevalence.  

  Analysis based on FRA data for 2014 finds that women living in EU Member States 
that  undertook  legislative  action  before  2005  had  a  40%  lower  probability  of 

204 Clark, K. A., Biddle, A. K., & Martin, S. L. (2002), 'A cost-benefit analysis of the Violence Against Women Act of 1994', 
Violence Against Women, 8(4), pp. 417-428. 
205  Protection  Orders  Protect  Against  Assault  and  Injury:  A  Longitudinal  Study  of  Police-Involved  Women  Victims  of 
Intimate Partner Violence: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4151113/   
206  The  Effects  of  Arrest,  Reporting 
https://journals.sagepub.com/doi/pdf/10.1177/0022427816678035  
207 Ibid.  
208 Klugman et al, Voice and Agency: Empowering Women and Girls for Shared Prosperity, The World Bank, 2014.  

the  Police,  and  Victim  Services  on 

Intimate  Partner  Violence: 

to 

53 

 
 
 
 
                                                 
victimisation  compared  to  women  living  in  EU  Member  States  that  took  legislative 
action more recently.209 

Due  to  lack  of  evidence  quantifying  the  causal  link  between  the  full  set  of  measures  under 
both policy options, different long-term and short-term impacts were tested.  

a)  Benefits of option 1 

Based on a reduction rate of 15% (short-term) and 20% (long-term) respectively, the expected 
total economic benefit of option 1 is estimated to be in the short-term €39.6 billion per year 
and €53.1 billion in the long-term (see Annex 5 for more information).  

b)  Benefits of option 2 – Sub-options 2A and 2B 

Option 2A envisages more specific measures on prevention, protection, access to justice and 
support,  but  also  more  targeted  measures  on  specific  types  of  violence  (including  cyber 
violence and sexual harassment at work) compared to option 1. The expected impact of option 
2A  (on  prevalence)  is  therefore  expected  to  be  higher  than  the  more  moderate  option  1. 
Assuming  a  decrease  in  prevalence  rates  of  20%  (short-term)  and  30%  (long-term) 
respectively,  the  estimated  total  economic  benefit  of  option  2A  amounts to  €53.1  billion  in 
the short term and to €82.7 billion in the long term (see Annex 5 for more information). 

Option 2B would include a targeted criminalisations, extended measures for Member States, 
the  provision  of  a  high  number  of  shelters  and  centralised  services  for  victims,  as  well  as 
special  leave  from  work  compensated  at  the  level  of  sick  leave  for  all  victims  of  violence 
against  women  and  domestic  violence  and  centralized  administrative  data  collection.  These 
measures are expected to bring an even higher reduction of prevalence, which is assumed to 
be 22% (short-term) and 33% (long-term) respectively. The estimated total economic benefit 
is therefore €57.8 billion in the short term and €87.6 billion in the long term (see Annex 5 
for more information).  

6.3.2 

Administrative and compliance costs for Member States and employers 

Both  options  imply  costs  for  national  authorities  and  some  costs  for  employers.  The  total 
compliance costs of each of the (sub-)options are summarised in the three tables below. Costs 
are  presented  by  problem  area  and  distinguished  between  one-off  development  costs  and 
annual running costs for Member States and employers. These costs are overall significantly 
lower  than  the  cost  to  society  currently  incurred  under  the  present  prevalence  of  violence 
against women and domestic violence. 

Table 6.1 Total compliance costs of option 1 by problem area 

Problem area 

Prevention 
Protection 
Access to justice  

One-off development cost 
(Millions of euros) 
 0.6  
negligible 
negligible 

Running cost per annum 
(Millions of euros) 
 20.1 – 22,4 
645.5 – 1,684.4 
negligible 

209  Sanz-Barbero  B.,  Corradi  C.,  Otero-García  L.,  Ayala  A.,  and  Vives-Cases  C.,  'The  effect  of  macrosocial  policies  on 
violence against women: a multilevel study in 28 European countries', International journal of public health, 63(8), 2018, pp. 
901- 911. 

54 

 
 
 
 
                                                 
Victim support 
Coordination 
TOTAL 

25.3 
negligible 
25.9 

127.9-491.4 
negligible 
 793.5-2,198.1 

Table 6.2 Total compliance costs of option 2A by problem area 

Problem area 

Prevention 
Protection 
Access to justice  
Victim support 
Coordination 
TOTAL 

One-off development cost 
(Millions of euros) 
2.4  
negligible 
negligible 
13.6 
0.2 
16.1 

Running cost per annum 
(Millions of euros) 
1923.9-1928.5  
769.4 – 2,014.0 
328.5 
1,925.2 - 2,288.7 
21.1 
4,968.3 – 6,581.4 

Table 6.3 Total compliance costs of option 2B by problem area 

Problem area 

Prevention 
Protection 
Access to justice  
Victim support 
Coordination 
TOTAL 

One-off development cost 
(Millions of euros) 
2.4 
negligible 
negligible 
136.2 
0.2 
138.7 

Running cost per annum 
(Millions of euros) 
1,924.6–1,929.1 
769.5 – 2,014.6 
1,897.6 
2,438.0 – 8,335.7 
24.3 
7,054.1 – 14,201.4  

Below is  an assessment  of the compliance costs  caused by the different  policy measures by 
problem area.  

Prevention 

Under option 1, it is assumed that all Member States would incur additional costs compared to 
the  baseline  for  information  provision,  awareness-raising  and  training  measures,  as  the 
existing  measures  in  place  are  not  sufficiently  targeted  to  violence  against  women  and 
domestic  violence.  The  maximum  costs  of  awareness-raising  and  providing  information  are 
estimated  to  be  around  €4  million  for  the  EU-27.  Training  on  violence  against  women  and 
domestic violence  to  professionals  dealing with  victims  or perpetrators is  expected to  cause 
maximum  costs  of  around  €19  million.  Finally,  this  option  envisages  to  make  available 
voluntary  programmes  for  convicted  perpetrators.  Given  their  low  overall  number  and  an 
expected low take up rate, the additional cost for this measure is estimated in the order of €40 
thousand.    The  supporting  study  and  consultations  show  that  no  Member  State  currently 
provides  sufficient  perpetrator  intervention  and  treatment  programmes,  though  almost  all 
countries already have some programs in place. 

Under  option  2A,  the  Member  States  would  provide  targeted  information  to  groups  at 
heightened risk of violence against women and domestic violence. The total maximum cost is 
estimated  to  be  €4.4  million.  Option  2A  also  requires  mandatory  and  regular  training  to 
professionals on online violence against women, which is estimated to cost €2 million. Under 
this  option,  the  perpetrator  programme  is  also  made  mandatory  for  repeated  offenders,  with 

55 

 
 
 
 
 
 
consequently higher costs of around €100 thousand. This compares to the cost of mandatory 
training for all convicted offenders included under option 2B that has a cost of around €750 
thousand.  

Finally, the biggest ticket in the prevention area comes from prevention of sexual harassment 
at work and it is only foreseen for Option 2. It is related to mandatory training of managers 
and an obligation to set up anti-harassment policies. This would be a two hour online training 
to be attended once per year.  For a single employer, the cost corresponds to two working time 
hours for each manager and the total cost per employer will therefore depend on the number 
of managers attending the training. The overall cost of training for all employers is estimated 
at  around  €1.9  billion210.  Member  States  would  cover  the  costs  for  the  development  of  the 
training  itself  (a  cost  of  €600  thousand).  The  possible  costs  for  updating  the  existing  risk 
assessments has not been included as costs of this initiative since the obligation to have such 
assessments  in  place  is  already  provided  under  existing  EU  health  and  safety  legislation, 
which covers sexual harassment at work even though this is not expressly spelled out.   

Protection 

In the consultation phase, over half of the Member States (See annex 2) and all international 
organisations highlighted the need for further protection measures, especially of children and 
child witnesses of violence against women and domestic violence. The assessment of the gap 
analysis  concerning  the  current  measures  relating  to  protection  orders,  risk  assessments  and 
child-friendly measures showed that all Member States have some measures in place, so there 
are  no  expected  set-up  costs  under  neither  policy  option.  As  the  supporting  study  and 
consultations  show  that  current  protection  measures  are  not  sufficient211,  all  Member  States 
would incur additional costs under both policy options. 

As for protection orders, they are available in all Member States, however evidence suggests 
that women victims of violence against women and domestic violence do not have sufficient 
access to such orders in any Member State. Under option 1, Member States would therefore 
need to ensure that protection orders are available for all types of violence against women and 
domestic  violence.  This  implies  additional  costs  between  €3.3  and  22.8  million  for  the 
EU27212 (see Annex 5 for details). Under option 2, the increased effectiveness and enhanced 
access  to  protection  orders  may  be  expected  to  lead  to  an  increase  in  the  request  for  such 
orders. Costs may arise on the side of the judiciary and law enforcement (issuing/enforcement 
of the order).  The total cost for this option would then be between around €4 and 25 million. 

Under option 1, countries that have services in place for the protection and support of child 
victims and witnesses would improve such services, which is expected to lead to an increase 
of  support  to  50%  more  children  compared  to  the  baseline.  Countries  that  need  to  make 
substantial improvements may be expected to have an even higher number of children seeking 
support,  thus  incurring  higher  costs.  Overall  costs  for  this  measure  is  estimated  to  be  a 
maximum of €1.6 billion. Under option 2, Member States would ensure that visits of children 

210 See Annex 4, 2.13 and Annex 5, measure 1.5 for further details on specific methodology and assessment. 
211 See more in Annex 2. 
212 Data were not available for Italy and Malta, which are therefore excluded from the computations. 

56 

 
 
 
 
                                                 
can  take  place  in  surveyed  safe  places  in  cases  involving  allegations  of  violence  against 
women  and  domestic  violence.  Such  visits  could  take  place  in  the  context  of  existing 
protection and support services. The total maximum costs of protection and support of child 
victims and witnesses under this option is therefore estimated to be €1.9 billion.  

As for risk assessment measures under option 1, it may be expected that Member State will 
provide between 50 and 100% more risk assessments to victims, and that 25% of them will 
qualify as high risk and therefore receive an in-depth assessment. The total cost for the EU-27 
is  approximately  €43  million.  Under  option  2  (both  sub-options)  additional  working  time  is 
considered to manage cases in a timely manner in cooperation with support services. The total 
cost is therefore higher at around €47 million. 

Access to justice 

Costs  for  access  to  justice  measures  fall  entirely  on  public  authorities.  Based  on  the 
supporting  study,  under  option  1  costs  would  somewhat  increase  for  law  enforcement,  the 
justice  sector  and  equality  bodies,  as  they  would  have  to  deal  with  more  cases  of  violence 
against women and domestic violence, but these costs are expected to be negligible.  

Under option 2, compliance costs for access to justice measures would be higher. Concerning 
compensation,  under  option  2A,  victims  of  violence  against  women  and  domestic  violence 
would  have  the  right  to  full  compensation  from  the  perpetrator.  As  this  concerns 
compensation for harm resulting from illegal behavior, this should however not be considered 
a  proper  cost  and  it  is  therefore  not  included  as  such  in  the  computation.  Under  Option  2B 
however  the  State  would  intervene  to  pay  for  victims  that  cannot  be  compensated  by  the 
perpetrators. It is estimated that improved access to compensation could lead to 10% increase 
of  demand  and  granting  of  compensation  ,  50%  of  which  would  not  be  recovered  from  the 
perpetrator or other sources. Member states would then need to cover such compensation with  
an additional overall cost for Member States of €1.6 billion.   

Finally,  for  both  options,  costs  relating  to  prosecution  pro-active  information  of  victims 
regarding their right to compensation, and ensuring low-threshold reporting are estimated to 
be negligible. 

Victim support 

Under  both  policy  options,  it  is  expected  that  all  Member  States  will  require  additional 
expenditure,  especially  to  meet  the  demand  for  missing  specialist  services  for  survivors  of 
sexual  violence  and  the  missing  number  of  beds  in  shelters.  As  for  services,  the  Member 
States that do not currently have (i.e. BE, HR, CZ, FR, HU, LV, LU, MT, NL, PL, PT, SI) a 
24/7  free  helpline  for  women  victims  of  violence  against  women  and  domestic  violence 
would incur additional costs to set-up and run such helplines. The total expected expenditure 
of  such  measures  is  estimated  at  between  €1.4  and  €5.6  million  for  both  options,  as  the 
obligation to connect national helplines to the EU-harmonised number is estimated to have a 
negligible  cost.  Concerning  specialised  support  services  under  option  1,  the  costs  are 
estimated  to  be  around  €107  million.  Under  option  2,  it  is  expected  that  all  Member  States 
will  need  to  step  up  their  specialised  services  to  support  groups  at  a  heightened  risk  of 
violence. The costs of this measure is estimated at €118 million.  

57 

 
 
 
 
As  for  shelter  provision,  option  1  requires  the  Member  States  to  provide  shelters  in  an 
accessible manner and in sufficient numbers. Based on information of the average current cost 
of a shelter bed space for a woman (with or without child) in Member States, the  estimated 
total  cost  is  between  €33.1  million  and  392.4  million,  same  as  for  Option  2A.  Option  2B 
specifies  the  obligation  to  provide  at  least  1  shelter  space  for  10,000  inhabitants,  which  is 
estimated  to  cause  a  maximum  total  costs  of  around  €3.9  billion.  This  is  by  far  the  highest 
cost per single measure. 

In  addition,  under  option  2,  the  requirement  for  Member  States  to  provide  on-  and  offline 
support  for  victims  of  cyber  violence  against  women  and  in  intimate  partnerships  (incl. 
equipping  support  services  with  financial  and  human  resources  for  knowledge-development 
and the necessary technology) is estimated to cost around €1.2 billion. 

Finally, under option 2B, Member States would also provide for 3 days of special leave for 
employees  victims  of violence  against women  and domestic violence, to  be compensated  at 
the  level  of  current  sick  pay  compensation  under  national  law.  The  costs  of  the  measure  is 
estimated  to  be  between  €0.3  and  2.6  billion  depending  on  whether  only  victims  of  sexual 
violence  are  covered  or  all  victims  of  physical  violence  against  women  and  domestic 
violence. 

Coordination 

This  area  includes  measures  regarding  data  collection  and  provision  of  integrated  services.  
Option 1 is not expected to trigger substantial costs: most Member States already collect some 
disaggregated  administrative  data  on  violence  against  women  and  domestic  violence. 
Moreover,  participation  in  the  survey  coordinated  at  EU  level  would  be  voluntary.  Finally, 
most Member States already provide for some minimum coordination at national level. 

Option  2  is  expected  to  trigger  limited  costs  for  Member  States.  This  option  includes  the 
provision  of  a  one-stop  online  access  to  relevant  protection  and  support  services  and  of 
voluntary on-site support services. As for the data collection, it makes the participation in the 
EU  survey  mandatory,  as  well  as  the  regular  collection  of  administrative  data  through  an 
integrated centralized data collection system. Overall, these measures would trigger costs for 
€20.9  million.  The  largest  cost  is  for  the  regular  mandatory  survey:  each  data  collection  is 
costed, based on a sample of on average 5,000 interviews per Member State at a cost of €100 
per interview, at €16.8 million. Option 2 would also involve locating services for victims in 
the same premises (with a maximum estimated costs when upon obligation in sub-option 2B, 
of  €3.6  million)  and  a  centralized  integrated  system  of  administrative  data  collection  on 
violence  against  women  and  domestic  violence,  which  would  have  a  negligible  cost,  as 
several Member States have already introduced integrated systems for data processing in the 
area.213  

6.3.3 

Summary of costs and economic benefits 

213  This  is  for  instance  the  case  for  Spain  where  since  2006  the  State  Observatory  on  Violence  against  Women  collects, 
analyses  and  disseminates  periodic,  homogeneous  and  systematic  information  on  gender-based  violence  from  public 
administrations,  other  State  bodies  with  competence  in  this  area  and  private  entities  through  a  reference  database  with  a 
system of standardized indicators.  

58 

 
 
 
 
                                                 
 Policy options 

)
e
t
a
r
e
d
o
M

(

1
n
o
i
t
p
O

)
e
v
i
s
n
e
h
e
r
p
m
o
c
(

2
n
o
i
t
p
O

n
o
i
t
p
o
-
b
u
S

n
o
i
t
p
o
-
b
u
S

A

B

Assumed 
reduction in 
prevalence 

Short-term  
(15%) 

Long-term  
(20%) 

Short-term  
(20%) 

Long-term 
(30%) 
Short-term  
(22%) 

Long-term 
(35%) 

Economic 
benefits 

Recurring cost 
min 

Recurring 
cost max 

One-off cost 

€ 39.6 billion  

€ 0.8 billion  

€ 2.2 billion 

€ 0.01 billion  

€ 53.1 billion  

€ 0.8 billion   

€ 2.2 billion  

€ 0.01billion  

€ 53.1 billion  

€ 5.0 billion  

€ 6.6 billion 

€ 0.02 billion 

€ 82.7 billion  

€ 5.0 billion  

€ 6.6 billion  

€ 0.02 billion 

€  57.8 billion  

€ 7.2 billion  

€ 14.3 billion   € 0.14 billion 

€ 87.6 billion 

€ 7.2 billion 

€ 14.3 billion 

€ 0.14 billion 

The total compliance costs of option 1 range between € 0.8 billion to 2.2 billion, with some 
additional one-off development costs in the first year of implementation. The estimated total 
economic  benefits  of  this  option  range  between  a  cost  reduction  of  €  39.6  billion  (short-
term) to € 53.1 billion (long-term). 

The  total  compliance  costs  of  option  2A  range  between  €  5.0  billion  and  6.6  billion  with 
some additional one-off development costs in the first year of implementation. The estimated 
total  economic benefits  of this sub-option range  between a  cost reduction  of € 53.1 billion 
and € 82.7 billion.  

The total compliance costs of option 2B range between € 7.2 billion and € 14.3 billion with 
some additional one-off development costs in the first year of implementation. The estimated 
total  economic benefits  of this  sub-option range  between a  cost reduction of € 57.8 billion 
and € 87.6 billion.   

7.  7. 

How do the options compare? 

Table 7.1  below summarises  the  comparison of  options against the  criteria of  effectiveness, 
efficiency  and  coherence.  The  comparisons  also  takes  into  account  the  criteria  of 
proportionality  and  the  risk  of  cost  deviation,  which  is  measured  by  the  range  of  minimum 
and maximum costs. Scores are assigned on a scale from 1 to 3, as no option is expected to 
have negative impacts.  

Table 7.1.: Summary of comparison of policy options  

1 - Effectiveness  

Effectiveness in achieving the objectives 
(including impact of fundamental rights) 

Specific objective 1: Prevention  

Specific objective 2: Protection  

Specific objective 3: Access to justice  

Legislative Options 

Poliy Option 1 

Poliy Option 2 
Sub-option A 

Policy Option 2 
Sub-option B 

1.75 

2.50 

1.75 

1 

1 

1 

1 

2 

2 

2 

2 

2.5 

2.5 

2 

3 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
Specific objective 4: Victim support  

Specific objective 5. Coordination  

Proportionality 

2 - Efficiency  

Total average cost (in billion Euros/year) 

Minimum costs 

Maximum costs 

1 

1 

2.5 

1.75 
€1.5 
€0.8 
€2.2 

2 

2 

3 

2.5 

2.5 

1 

2.75 
€5.8 
€5.0 
€6.6 

2.13 
€10.8 
€7.2 
€14.3 

Risk of cost deviation (max-min costs) 

€1.4 

€1.6 

€7.1 

Net benefit short term 

Net benefit long term 

Total net benefits 

Figures translated to qualitative scale 

Risk of cost deviation (difference max-min costs) 

Total net benefits 

Social impacts (not quantifiable benefits) 
- victims of VaW/DV and particular groups of victims  
- wider society (including perpetrators and national 
authorities) 

3 - Coherence  

Internal coherence 

External coherence 

TOTAL UNWEIGHTED SCORE 

€38.8 
€50.9 
€89.7 

€48.1 
€76.1 
€124.2 

2 
3 
1 

1,5 

2 

1,8 

2 

1 

2 
2 

3 
3 
3 

2,5 

2,5 

2,6 

2.5 

2.5 

2 
3 

€50.6 
€73.3 
€123.9 
1,75 
0.5 
3 

2,5 

2.5 

2.5 

2 
3 

2,5 

2,1 

Across the board, all options have a positive impact. Option 2 has the strongest effect in terms 
of achievement of the policy objectives, impacts on fundamental rights, internal and external 
coherence, and net economic benefits.  Compared to sub-option 2B, sub-option 2A scores 
better  on  all  three  assessment  criteria  -  effectiveness,  efficiency  and  coherence.  The 
comparative  analysis  below  discusses  these  differences  in  further  detail.    A  sensitivity 
analysis confirms this result under different weights assigned to the three criteria (See Annex 
3.4). 

7.1. 7.1.  Effectiveness  

All  options  will  contribute  to  achieving  the  policy  objectives  of  the  initiative.  A  single 
legislative instrument based on the most effective practices from different Member States and 
on  the  most  effective  measures  already  applied  at  the  EU  level  in  the  neighboring  policies, 
will  contribute  to  a  focused,  coordinated  approach  targeting  violence  against  women  and 
domestic  violence  in  all  Member  States..  Compared  against  the  current  regulatory 
fragmentation,  evaluated  as  ineffective  in  the  gap  analysis,  this  is  in  itself  an  improvement 
and a positive contributing factor to the effectiveness of both options. Both options will also 
contribute to the effectiveness of safeguarding fundamental rights.  To the extent that similar 
measures  are  already  applied  in  the  Member  States,  the  effects  of  the  measures  will  vary 
across the Union. 

a

) 
Preventi
on  

60 

 
 
 
 
 
 
The prevention measures proposed under  option 1 would contribute to  challenging negative 
gender stereotypes and attitudes towards women and men, as well as raising the awareness of 
the general population and relevant professionals, and contributing to the specific knowledge 
of  the  latter.  Option  2  is  expected  to  make  a  greater  contribution  to  ensuring  effective 
prevention of violence against women and domestic violence, as it adds prevention measures 
targeting groups at risk, and opens up treatment programmes to those at risk of offending.  

Moreover, while option 1 does not focus on victims of sexual harassment and cyber violence 
against women, option 2 goes a step further by introducing specific standards, thus providing 
more comprehensive and effective measures to address those specific types of violence.  

The measures of option  2 are  built on good practices in  the Member States.  In its baseline 
evaluation report on Austria, GREVIO commended that the two-year basic initial training of 
law-enforcement  officers  encompassed  the  issue  of  domestic  violence,  including  its  gender-
based dimension and that the specific nature of this type of violence and the relevant police 
measures are an important  element  of  this  training.214 Another promising practice identified 
by GREVIO in its baseline evaluation report on Denmark is the awareness-raising campaigns 
on stalking and rape, which included components that specifically targeted professionals such 
as law enforcement agents and social workers.215 This approach has led to improvements in 
the  professionals’  response  to  such  violence  and  demonstrates  the  importance  of  such 
measures.  Stakeholder  views:  Expanding  prevention  measures  is  supported  by  various 
stakeholders,  such  as  NGOs  and  Member  States.216  Particularly  measures  on  tackling  cyber 
violence  and  sexual  harassment  at  work  are  supported  by  social  partners,  international 
organisations  and  employer  associations  respectively.  NGOs  highlighted  the  need  for 
trainings for professionals across sectors to provide effective support to victims, particularly 
with police and judicial authorities.217  

b

)

Pro

tection 

The measures in option 1 on the availability of protection orders, risk assessments and better 
protection of child victims and witnesses are expected to address significant shortcomings in 
the area of protection of victims from violence against women and domestic violence. While 
these measures are expected to have positive effects, they however remain very close to the 
baseline and do not effectively address some of the legal  and practical barriers for effective 
protection.   

Option 2 adds several valuable elements in the area of protection that address these remaining 
barriers,  thus  enhancing  its  effectiveness  compared  to  option  1.  In  particular  the  measure 
introducing harmonised minimum standards regarding emergency barring orders is expected 

214 See GREVIO's baseline evaluation report on Austria, paragraph 76. 
215 See GREVIO's baseline evaluation report on Denmark, paragraphs 65-66 
216 Various stakeholders from Member States, international organisations, NGOs to social partners were consulted through 
targeted consultation during May-July 2021. See more in Annex 2. 
217 Ibid. 

61 

 
 
 
 
 
                                                 
to  improve  their  timeliness  (within  24  hours)  and  effectiveness  in  terms  of  access  and 
enforcement. Minimum harmonized standards may be expected to facilitate their cross-border 
effect,  thus  improving  the  mechanism  set  out  in  the  existing  mutual  recognition 
instruments.218  Option  2  also  foresees  measures  specifically  aimed  at  child  witnesses, 
including surveyed safe places where children can continue to meet their parents particularly 
in cases of domestic violence, thereby preventing repeated victimisation. 

These  measures  build  on  good  practices  in  the  area  of  protection  in  Member  States.  For 
example,  in  Portugal  risk  assessment  is  mandatory  in  cases  of  domestic  violence,  and  it  is 
based on standardised forms. After the risk assessment has been  completed, a safety plan is 
developed for the victim, an application for protective measures is made, and the seizure of 
weapons is also provided.219  

Stakeholder views: The need for further protection measures was supported by over half of 
the  Member  States  with  the  international  organisations  highlighting  the  need  for  further 
protection  measures,  especially  of  children  and  child  witnesses  of  violence  against  women 
and domestic violence. NGOs stressed the need to increase resources for issuing emergency 
barring orders. 14 Member States have responded that further measures would be useful to 
make national protection orders more effective in practice. 

c

) 
Access  to 
justice 

Measures  proposed  under  option  1  will  improve  access  to  justice  by  introducing 
approximation of criminal definitions and sanctions at EU-level of certain forms of violence 
against  women  and  domestic  violence,  access  to  compensation  and  improved  reporting  by 
third  parties.  The  positive  effects  are  expected  to  be  the  strongest  in  the six  Member  States 
which have not  yet ratified the Istanbul Convention. Nevertheless, they may not sufficiently 
address arising problems in all Member States, such as access to justice for victims of cyber 
violence against women and in intimate partnerships. 

Sub-option  2A  includes  additional  elements  to  address  the  gaps.  Concerning  compensation, 
under  option  2A  the  right  of  victims  of  violence  against  women  and  domestic  violence  to 
claim  full  compensation  from  the  perpetrator  does  not  cause  costs  to  the  Member  State;  it 
ensures  compensation  for  harm  by  the  perpetrator  caused  by  illegal  behaviour.  On  the 
contrary, under option 2B the obligation on Member States to provide state compensation in 
cases where victims cannot obtain compensation from the perpetrator or other sources, would 
create further costs; in addition, it would require an additional legal basis incompatible with 
that  of  this  initiative.  Policy  option  2A  further  ensures  the  approximation  of  criminal 
definitions  and  sanctions  at  EU-level,  within  the  existing  legal  bases,  of  conduct  relating  to 
serious forms of sexual violence, cyber violence against women and in intimate partnerships, 

218 Directive 2011/99/EU of the European Parliament and of the Council of 13 December 2011 on the European Protection 
Order; Regulation (EU) No 606/2013 of the European Parliament and of The Council of 12 June 2013 on mutual recognition 
of protection measures in civil matters. 
219 See more in the Gap Analysis in Annex 8. 

62 

 
 
 
 
 
                                                 
and  sexual  harassment  at  work.  It  also  lowers  the  threshold  for  reporting  violence  against 
women  and  domestic  violence,  which  is  expected  to  increase  prosecutions  and  convictions. 
Importantly, the expansion of the offences will ensure that a wider group of victims is eligible 
for  protection.  Sub-option  2B  would  go  the  furthest  in  terms  of  approximation  of  criminal 
definitions and sanctions, ensuring that in the future all forms of gender-based violence could 
be approximated by EU legislation by defining gender-based violence as a new area of crime 
under Article 83(1) TFEU. While this would ensure the most effective combatting of this kind 
large  extent  overlap  with  national 
of  violence,  such  approximation  would 
criminalisations, which already cover the overwhelming majority of forms of violence against 
women and domestic violence. This sub-option is therefore considered disproportionate at this 
time.  

to  a 

The  measures  build  on  good  practices  in  the  area  of  access  to  justice  implemented  in  the 
Member  States.  For  example  in  Finland,  in  2015,  the  law  was  amended  to  allow 
professionals,  who  had  previously  been  bound  by  confidentiality  rules,  to  notify  statutory 
agencies where they suspect a risk to the life of a woman or child in the context of domestic 
violence.  

Stakeholder views: All measures on access to justice have been supported by stakeholders. 
NGOs  have  highlighted  the  need  to  improve  in  particular  prosecution  and  compensation 
measures.  This  is  supported  by  research  highlighting  that  training  of  the  police  and  the 
judiciary on violence against women and domestic violence is likely to increase the number of 
prosecutions  and  convictions.220  Measures  to  address  sexual  harassment  are  aligned  with 
views  of  the  social  partners,  which  highlighted  the  need  for  further  action.  Employer 
associations underlined the need to take into the consideration the different capacity of large 
employers and SMEs, which has been taken into consideration with the proposed measures. 
They also stated that an understanding of the challenges posed by sex-based harassment and 
the  illegal  nature  of  it  is  well  established  and  understood,  but  practical  implementation 
remains a challenge (see Annex 2). 

d

)

Vict

im 
support  

Both policy options are expected to increase the availability and access to support for victims 
of  violence  against  women  and  domestic  violence.  The  measures  proposed  under  option  1, 
such  as  the  obligation  on  Member  States  to  ensure  availability  and  adequate  resourcing  of 
general  support  services  and  specialised  support  services  with  adequate  geographical 
coverage, including shelters in an accessible manner and sufficient numbers, are expected to 
increase  the  support  for  victims  at  a  moderate  rate.  Specifications  of  the  content  of  general 
and  specialist  support  services  are  expected  to  enhance  the  quality  and  capacity  of  existing 
services and further expand them, thus also increasing overall accessibility. The same applies 

220 UNODC (2014), Handbook on effective prosecution responses to violence against women and girls. Council of Europe & 
EU, Training Manual for judges and prosecutors on ensuring women’s access to justice. 

63 

 
 
 
 
 
                                                 
for the helplines, as they will be able to offer assistance to those who want to seek advice on 
violence  against  women  and  domestic  violence,  including  those  who  may  be  hesitant  to 
identify  themselves  as  victims.  Although  the  impact  of  the  measures  will  depend  on  the 
current level of services offered in Member States, the study shows that the measures may be 
expected  to  have  effect  in  all  Member  States,  also  in  those  that  have  ratified  the  Istanbul 
Convention.  Nevertheless,  under  this  option,  some  categories  of  victims  may  not  be 
sufficiently protected, namely groups at a heightened risk of violence and victims of  sexual 
harassment especially at work. Also, much discretion is left to Member States in interpreting 
the rules, for example, to provide shelters ‘in sufficient numbers’.  

Option  2  is  expected  to  ensure  more  effectively  the  availability  and  accessibility  of  support 
measures,  boost  the  quality  and  capacity  of  existing  services,  further  expand  them  to  cover 
specific groups of victims with a higher risk of violence. It  would ensure the availability of 
such services also for victims experiencing sexual harassment at work. Sub-option 2B brings 
added  value  with  a  mandatory  amount  of  available  shelter  space  and  compensated  special 
leave  for  workers  victim  of  violence  against  women  and  domestic  violence.  However,  both 
options are very expensive, and thus suggest a disproportionate solution.  

The measures build on good practices identified in the area of victim support. For example, in 
Greece,  a special    innovative, coordinated,  and  gender-sensitive network  offers services  for 
vulnerable refugee women who are victims of violence against women and domestic violence 
and  their  children..221   In  Denmark,  guidelines  have  been  developed  for  social  workers  on 
how  to  assist  victims  of  domestic  violence.  For  a  woman  seeking  refuge  at  a  shelter,  the 
municipality is  obliged to provide initial and coordinated counselling to  identify their needs 
and offer solutions.222 This shows how improving general and specialist support measures is 
needed  to  support  victims  of  violence  against  women  and  domestic  violence,  particularly 
concerning vulnerable groups.  

Stakeholder views: Improving victim support services has been seen as a key area of action 
by various stakeholders, with  especially NGOs highlighting the need to  estimate the cost  of 
violence and benefits achieved through support measures.  NGOs stressed the importance of 
Member States providing both general and specialised support services. 

e

)

Coo

rdination  

Both  policy  options  are  assessed to  be effective  in  improving coordination structures across 
the  Member  States.  Option  1  would  be  moderately  effective.  Training  and  information 
provision  to  professionals  is  expected  to  enhance  cooperation  between  agencies.  Data 
collection would be somewhat improved, but participation in the EU-level survey would not 
be  ensured  (currently  only  18  Member  States  participate).  Administrative  data  collection 
would be ensured, but further convergence towards the production of comparable data across 

221 https://ec.europa.eu/info/publications/mlp-gender-equality-seminar-support-services-victims-violence-asylum-and-
migration-february-2018-greece_en. 
222 Ibid. 

64 

 
 
 
 
 
                                                 
the EU would not happen as no harmonised minimum  standards of data  disaggregation and 
collection would be set.  

Option 2 is expected to be more effective in ensuring more robust coordination structures in 
relation  to  violence  against  women  and  domestic  violence,  including  on  multi-agency 
cooperation.  Participation  in  the  EU-level  survey  would  be  mandatory  ensuring  comparable 
EU-level data on the prevalence of violence against women and domestic violence. Minimum 
standards on administrative data collection would ensure progress toward comparability at EU 
level. Sub-option 2B could be more effective in ensuring the centralization of administrative 
data  of  all  services  at  national  level  (police,  judiciary,  health,  social),  but  this  measure  is 
operationally  complex,  putting  a  burden  on  the  public  authorities  which  may  be 
disproportionate particularly at this time.  

The  measures  build  on  good  practices  concerning  coordination.  For  example,  Spain  has 
created  and  implemented  an  Integrated  Monitoring  System  for  cases  of  Gender-based 
Violence (VioGen). In Portugal, data from law-enforcement bodies and the judiciary must be 
collated throughout the entire criminal proceedings chain, from the filing of the complaint to 
the delivery of the judgment. A standard form is used to record domestic violence.. 

Stakeholder  views:  The  need  for  comparable  and  comprehensive  disaggregated  data 
collection has been highlighted by  all stakeholders as crucial for better policy development. 
Member  States  also  recognised  in  the  consultations  the  value  of  multi-agency  cooperation 
with  14  Member  States  stating  it could  be  strengthened.  Research  also  shows  that  effective 
multi-agency  service  provision  and  coordination  can  help  professionals  respond  to  violence 
against  women  and  domestic  violence  due  to  more  effective  use  of  resources,  increased 
awareness  and  understanding  of  violence  against  women  and  domestic  violence,  and  peer 
support.223  

7.2. 7.2.  Efficiency 

Both  policy  options  are  expected  to  incur  substantial  compliance  costs,  but  these  costs  are 
always exceeded by the potential economic benefits (measured in terms of reduction in costs 
of  violence  against  women  and  domestic  violence).  The  compliance  costs  for  each  problem 
area are higher in  option 2A (see Table 6.2) compared to  option 1  (Table 6.1). Overall, the 
total administrative and compliance costs for option 2A are between €4.2 – €4.4 billion higher 
than for option 1. The total administrative and compliance costs for option 2B (Table 6.3) are 
between €2.2 and 7.7 billion higher than option 2A. 

The difference in costs is largely driven by the running costs per year of the various measures. 
In particular, the most substantial differences are observed in the running costs for measures 
related to access to justice and victim support. In addition, the cost of new measures against 
cyber  violence  against  women  and  in  intimate  partnerships,  effective  remedies  in  case  of 
sexual  harassment  at  work  and  public  prosecution  of  the  new  EU-crimes  increases  the 
compliance costs of this option. The costs for victim support of  option 2A are around up to 

223  M.  Naudi,  M.  Clark  &  H.  Saliba,  2018,  Full  Cooperation:  Zero  Violence  –  Barriers  to  help-seeking  in  gender-  based 
violence against women: a research study. Also NSW Ombudsman 2006, Domestic violence: improving police practice. 

65 

 
 
 
 
                                                 
 
€4.0 billion higher than in option 1, which is mainly driven by the cost of measures to support 
victims  of  cyber  violence  against  women  or  in  intimate  partnerships  or  victims  of  sexual 
harassment at work.  

In  conclusion,  Option  1  offers  the  best  cost  to  benefit  ratio,  but  having  also  much  lower 
benefits, choosing this option would result  in missing out on net benefits compared to both 
option  2A  and  2B  (around  €9  and  over  20  billion  respectively  in  the  short  and  in  the  long 
period). Option 2A is preferable to Option 2B as it offers the highest net benefit in the long 
term and, although it has slightly lower net benefits in the short term, it achieves the benefits 
at much lower costs.  

Efficiency (in billion Euro)  

Total average, and minimum and maximum costs  

Of which one off costs  
Average running costs per year  
Benefits: Reduction in costs of violence  
Short term benefits (up to 5y) 
Long term benefits (10 y +)  

Overall economic impact/Net benefit  

Short term net benefit  

Long term net benefit  

7.3. 7.3.  Coherence 

 Option 1 
1.5  
(0.8-2.2) 
0.014 
1.5 

 Option 2A  Option 2B 
10.8  
(7.2-14.3) 
0.138 
10.8 

5.8  
(5.0-6.6) 
0.016 
5.8 

39.6 
53.1 

38.8 

50.9 

53.1 
82.7 

48.1 

76.1 

57.8 
87.6 

50.6 

73.3 

The  coherence  of  both  policy  options  (and  sub-options)  is  assessed  positively,  as  they  are 
expected to address some of the key problems identified, namely the highly fragmented nature 
of  the  current  EU  legal  framework,  the  lack  of  systematic,  focused  measures  on  violence 
against women and domestic violence and a number of the gaps in the framework identified in 
the  gap  analysis  (Annex  8).  Option  2  has  a  more  positive  impact  on  coherence  as  it  sets 
specific  standards  in  areas  not  specifically  addressed  by  the  Istanbul  Convention  (e.g. 
measures against cyber violence and sexual harassment).  

Both  options  would  be  fully  internally  coherent  with  other  actions  at  EU  level,  in 
particular  the  Victims’  Rights  Strategy  and  the  Rights  of  the  Child  Strategy  by  introducing 
detailed standards on victims’ rights and the rights of the child. Option 2 would also increase 
coherence  with  the  DSA  proposal  because  the  minimum  harmonisation  of  what  constitutes 
criminal and illegal forms of cyber violence will ensure that the obligations in the DSA will 
be  applicable  to  these  forms  of  violence  (for  example  orders,  notice  and  action,  trusted 
flaggers,  risk  assessments  etc.).  Also,  Option  2  will  supplement  the  DSA  on  prevention, 
protection, and support for victims of such cyber violence.With regard to the Victims’ Rights 
Strategy,  the  initiative  will  introduce  specialised  violence  against  women  and  domestic 
violence measures which will supplement the existing general victims’ rights standards at 
EU  level,  in  the  same  way  as  specific  measures  have  been  adopted  in  regard  to  victims  of 
terrorism and trafficking. 

Similarly,  both  policy  options  will  contribute  to  enhancing  external  coherence  by  aligning 
EU law to the standards of the Istanbul Convention, but option 2 will in addition align EU law 

66 

 
 
 
 
 
 
 
 
 
 
 
 
to  the  standards  of  the  ILO  Violence  and  Harassment  Convention  no.  190.  Both  policy 
options will also enhance coherence with the UN Convention on the Rights of the Child.  

7.4. 7.4.  Preferred option 

Following  the  comparative  assessment  of  the  effectiveness,  efficiency  and  coherence  of  the 
policy  options,  the  preferred  option  proposed  for  political  endorsement  is  option  2A.  The 
superiority  of  this  option  comes  from  its  better  performance  in  contributing  to  enforcing 
fundamental rights and improving social impact compared to option 1 and providing a higher 
net benefit in the long term compared to sub-option 2B (and to Option 1) while having lower 
costs.  

Most  importantly,  option  2A  is  expected  to  provide  extensive  protection  of  fundamental 
rights and improve the social situation of victims and society at large compared to option 1 
due  to  its  comprehensive  set  of  obligations.  It  follows  the  principle  of  proportionality  and 
necessity  of  an  intervention  at  EU  level:  it  will  remove  the  fragmented  approach  across 
Member States, enhance legal certainty and effective enforcement and protection of victims.  
It  establishes,  for  the  first  time  at  EU  level,  a  targeted  and  coordinated  approach  to  tackle 
violence  against  women  and  domestic  violence  through  a  set  of  harmonised  standards.  The 
effectiveness and proportionality of the option in reaching the objectives is superior, not only 
in  light  of  strengthening  the  fundamental  rights,  but  also  in  tackling  gaps  such  as  on  cyber 
violence against women and in intimate partnerships and sexual harassment.  

In economic terms, Option 2A is expected to achieve, through reduced prevalence of violence 
against  women  and  domestic  violence,  economic  benefits  of  around  €53.1  billion  with 
potential  to  reach  to  around  €82.7  billion  in  the  longer-term  with  a  net  benefit 
respectively of €48.1 and 76.1 billion. 

Option  2A  best  meets  the  objectives  of  the  intervention  in  a  proportionate  manner  and  it  is 
therefore likely to receive better political acceptance overall.  

8.  8. 

How will actual impacts be monitored and evaluated? 

The  main  objective  of  the  initiative  is  the  enforcement  of  fundamental  rights.  The 
achievement  of  this  objective  would  be  reflected  in  a  decrease  of  prevalence  rates  and  a 
decrease  of  the  needs  for  protection  and  support.  i.e.  in  the  number  of  people  who  do  not 
enjoy their fundamental rights.  

The  lack  of  monitoring  and  insufficient  enforceability  with  regard  to  victims  of  violence 
against  women  and  domestic  violence  is  one  of  the  key  weaknesses  identified  in  the 
application of the EU legal framework. Even though data indicate that this kind of violence is 
prevalent in all Member States, more comparable data, including on underreporting of these 
crimes, is needed to assess changes in prevalence rates and the effectiveness of the proposed 
measures.  

Considering that prevalence rates reflect structural data that tend to change very slowly over 
time, it is likely that in the short term, this first evaluation will show progress mostly as for 
the  implementation  and  setting  up  of  processes.  These  could  be  monitored  through  the 
number  of  requests  for  victim  support  measures,  number  of  prevention  measures  (e.g. 
awareness  campaigns),  VAW  and  DV  cases  registered  by  domestic  law  enforcement  and 
judicial  authorities  and  reported  coordination  efforts.  Most  data  in  this  respect  will  be 

67 

 
 
 
 
provided to the European Commission by Member States through the implementation reports 
which will feed into an evaluation to be carried out in about 5 years’ time.   

A  visible  impact  in  terms  of  a  reduction  in  prevalence  rates  in  the  previous  years  can 
realistically be expected only in the long run. An increased reporting, and therefore apparently 
higher  prevalence  rates,  could  actually  be  considered  an  indicator  of  success  in  the  shorter 
term.  

In this respect the provision regarding data collection will offer regular, comparable and, as 
for administrative data, also timely data.   

The  preferred  policy  option  will  introduce  further  harmonisation  in  the  collection  of 
disaggregated  administrative  data  (including  from  law  enforcement  agencies,  the  judiciary, 
social and health services) at regular intervals based on the ongoing work by EIGE, and  the 
obligatory regular survey coordinated at EU-level (following up on the EU survey on violence 
against  women  and  domestic  violence  coordinated  by  Eurostat).  These  strengthened  data 
collection requirements form the basis for the monitoring and evaluation of the impact of the 
initiative against its specific objectives. 

The monitoring will be based on a series of measurable outcomes (see Annex 7). With a view 
to  avoiding  unnecessary  duplication  of  efforts,  monitoring  will  in  as  much  as  possible  be 
based  on  the  harmonised  indicators  already  developed.224  The  most important  indicator,  but 
not  the  only,  for  successful  implementation  are  the  prevalence  rates  of  violence  against 
women and domestic violence.  

The  need  for  a  policy  review  will  be  assessed  following  the  first  round  of  Member  State 
reporting on the directive’s implementation, foreseen to take place about five years after the 
entry  into  force  of  the  directive.  Reporting  would  be  carried  out  at  regular  intervals  in  the 
form of a questionnaire to the Member States. The details will be described in a monitoring 
and enforcement plan. 

Member States would be able to draw on the information they provide to international human 
rights bodies under periodic reporting obligations. This would ensure that overlap in reporting 
and additional administrative burden is avoided. Unnecessary duplication will also be avoided 
by  drawing  on  data  already  available  under  other  relevant  policy  areas,  such  as  on  victims’ 
rights. Future synergies may be identified with the implementation of the EU strategies on the 
rights of the child, the rights of persons with disabilities and LGBTIQ equality, as well as the 
hate speech and hate crime initiative.  Additional information on the implementation measures 
and their effectiveness is expected to be received from stakeholders, such as EIGE, FRA and 
NGOs. 

224 Key outcomes are published by EIGE as well as in the monitoring tool developed for the Gender Equality Strategy, see 
https://composite-indicators.jrc.ec.europa.eu/ges-monitor/maps. 

68 

 
 
 
 
 
 
                                                 
ANNEXES 

ANNEX 1: Procedural information 

 LEAD DG, DECIDE PLANNING/CWP REFERENCES 

This Staff Working Document was prepared by the Directorate-General for Justice and 
Consumers (DG JUST). 

The Decide reference of this initiative is PLAN/2020/9290. 

This document includes annexes to the Impact Assessment Report. 

 ORGANISATION AND TIMING 

The Impact Assessment Report was prepared by DG JUST as the lead Directorate-General. 

The Inter-Service Steering Group on preventing and combatting violence against women and 
domestic violence established for the work was associated and consulted in the process, under 
the coordination of the Secretariat-General, including the following services: DG CONNECT 
(DG for Communications Networks, Content and Technology), DG EAC (DG for Education, 
Youth, Sport and Culture), DG EMPL (DG Employment, Social Affairs and Inclusion), DG 
ESTAT  (Statistical  Office  of  the  European  Union),  DG  HOME  (DG  Migration  and  Home 
Affairs), DG SANTE (DG for Health and Food Safety) and SJ (Legal Service). In addition, 
the  equality  coordinators  from  the  European  Commission’s  Equality  Task  Force  from  each 
DG  were  invited  to  follow  the  meetings  to  facilitate  equality  mainstreaming  work  in  their 
policy areas. 

The  last  meeting  of  the  ISSG  on  the  draft  Impact  Assessment  Report,  chaired  by  the 
Secretariat-General of the European Commission was held on 1 September 2021. Finally, the 
ISSG was consulted on the revised version of the impact assessment on 26 November 2021. 

CONSULTATION OF THE RSB 

The  Regulatory  Scrutiny  Board  gave  a  negative  opinion  on  the  draft  Impact  Assessment 
Report  submitted on 15 September 2021 and discussed in  the hearing that  took  place on 13 
October 2021. To address the feedback given by the Regulatory Scrutiny Board, the following 
changes were made in the Impact Assessment Report and its annexes: 

Findings of the Board 
1. The report is not 
sufficiently clear on what 
categories of victims and 
types of violence would 
be covered by the 
initiative, and what 
would justify limiting the 
application of certain 
measures specifically to 

Main modifications made in the report to address them 
The  problem  definition  chapter  of  the  impact  assessment  now 
clarifies upfront  the scope of the initiative, i.e.  violence against 
women and domestic  violence  against any  person.  This  reflects 
the  intention  to  pursue  the  same  objective  as  the  Istanbul 
Convention  -  to  ensure  that  EU  Member  States  have  effective 
measures  in  place  to  prevent  and  combat  violence  against 
women and domestic violence. 
The  report  better  explains  the  choice  of  scope:  while  violence 
may  affect  both  women  and  men,  violence  against  women  is  a 

69 

 
 
 
 
 
women. It does not 
sufficiently justify and 
substantiate with 
evidence the problems 
related to cyber-based 
violence and harassment 
in the workplace.  

specific phenomenon in that its drivers are different as explained 
in  the  Explanatory  Report  to  the  Istanbul  Convention225  and  it 
has  specific  consequences.  Furthermore,  the  large  majority  of 
acts of gender-based violence are perpetrated against women and 
girls.  Domestic  violence  additionally  covers  not  only  women, 
but any person living in the household, including men and boys.  

The  report  justifies  why  specific  measures  are  required  for  the 
protection of these particular groups of victims. 

The report also explains why violence based on other grounds of 
discrimination  is  excluded  from  the  scope,  while  taking  into 
account  the  intersection  with  other  grounds  of  discrimination: 
special  measures  are  foreseen,  within  the  group  of  victims  of 
violence  against  women  and  domestic  violence,  for  especially 
vulnerable  groups,  such  as  women  with  racial  or  ethnic  origin, 
disability or sexual orientation.  
The  problems  related  to  cyber  violence  against  women  and 
sexual harassment have been better justified and substantiated.  
The report now reflects better the evolving legislative context in 
Sections 3 and 5.1.  
In particular, the report was updated and aligned with the CJEU 
opinion  on  the  modalities  of  EU  accession  of  6  October  2021, 
taking  this  opinion  into  account  as  regards  the  possible 
developments in relation to the EU’s accession (see, in particular 
the  dynamic  baseline  (see  point  3)  and  as  regards 
the 
competence to act in the areas covered by the initiative.  
The  report  clarifies  that  the  baseline  takes  into  account  the 
legislative  and  policy  measures  taken  by  Member  States,  as 
gathered through  the studies conducted to support the initiative 
–  in  particular  the  study  from  the  European  Network  of  Legal 
Experts and the  ICF study  - and subsequently in the evaluation 
of gaps, as well the targeted consultation of stakeholders. A key 
source of information concerning the measures taken by the 21 
Member  States  in  the  field  of  preventing  and  combatting  this 
kind  of  violence  is  the  periodic  reporting  these  countries 
conduct  to  the  Council  of  Europe’s  monitoring  body 
GREVIO, and GREVIO’s ensuing baseline reports.  

All  this  information  has  been  distilled  into  a  new  annex  8, 
which  (in  its  section  2)  analyses  the  remaining  gaps  in  the 
Member States and highlights good practices in this area.   

Moreover,  a  dedicated  section  has  been  added  in  chapter  5 
setting  out  a  dynamic  baseline  for  the  Member  States.  The 
report acknowledges that Member States are likely to take some 
additional  measures  on  violence  against  women  and  domestic 
violence, in particular following recommendations by GREVIO. 
The  section  also  explains,  however,  why  these  measures  are 

70 

2. The report does not 
sufficiently reflect the 
evolving legislative 
context, in particular the 
recent Court of Justice 
Opinion on the legal 
base and modalities of 
the Istanbul Convention. 
3. The report does not 
present a complete 
baseline. It is not 
sufficiently clear on the 
future effects of more 
recent measures taken 
by the Member States. It 
does not assess the 
impacts that would 
result from further 
Member State 
implementation efforts 
of the Istanbul 
Convention obligations 
in the absence of further 
EU action. The 
remaining scale of the 
problems and the need 
for further EU action is 
not sufficiently clear. 

225 https://rm.coe.int/16800d383a 

 
 
 
 
 
 
 
                                                 
4. The report does not 
bring out clearly enough 
the available policy 
choices, the rationale 
behind options and the 
content of the measures. 

likely  to  be  insufficient  to  meet  the  objective  in  the  short  and 
medium  term  for two main reasons.  First,  GREVIO monitoring 
is  a  lengthy  and  reiterative  process,  which  does  not  cover  all 
parties  at  a  single  point  in  time;  moreover,  there  is  no  sanction 
for  non-compliance  with  recommendations,  since  international 
law like the Istanbul convention lacks the effective enforcement 
mechanisms of European law; second, not all Member States are 
parties to the Istanbul Convention. 

In  light  of  the  above,  in  order  to  define  the  scale  of  the 
problem, the report more clearly  explains the magnitude of the 
problem.  While  the  report  can  acknowledge  that  the  Istanbul 
Convention  and  the  #MeToo  movement  have  raised  awareness 
of the problem and triggered action, there is no evidence that this 
has translated into a reduction of prevalence. Therefore, without 
further action, limited progress over time is expected.  

The  description  of  policy  options  and  discarded  policy  options 
now  better  explains  the  available  policy  choices.  The  impact 
assessment  now  also  clarifies  the  rationale  behind  the  options 
and  the  content  of  the  measures,  presented  in  a  more  concise 
way.  

While option 1 would limit EU action to implementing Istanbul 
Convention standards through EU law, in matters relating to EU 
competence,  the  added  value  of  option  2  (under  both  sub-
options 2A and 2B) is double. First, option 2 contains targeted 
measures  on  cyber  violence  against  women  and  sexual 
harassment.  Secondly,  the  measures  under  option  2  have  been 
developed  in  comparison  to  the  standards  of  the  Istanbul 
Convention in order to ensure a better implementation in line 
with  best  practices  and  recommendations  recognized  by 
international experts in the field and international bodies such as 
GREVIO and in the UN.  

With respect to the first main added value, since the drafting of 
the  Istanbul  Convention,  cyber  violence  against  women  has 
become  a  common  and  growing  phenomenon  which  requires 
targeted  action.  Such  violence  is  also  an  area  where  legal  gaps 
have been identified in the legal network study. Finally, action in 
this area is needed to ensure a more effective implementation of 
the EU’s future Digital Services Act. While the DSA proposes to 
regulate  responsibilities  of  all  intermediary  service  providers 
regarding  illegal  online  content,  it  does  provide  definition  of 
such  content  but  relies  on  definitions  in  national  and  EU  laws. 
By including  a  definition of  cyber violence  against  women and 
in  intimate  partner  relations  at  EU  level226,  including  offences 

226 The envisaged definition would refer to any act of gender-based violence against women that is committed in part or fully 
by  the  use  of  information  and  communication  technologies,  such  as  mobile  phones  and  smartphones,  the  internet,  social 
media platforms or e-mail. It draws on the upcoming General Recommendation on the digital dimension of violence against 
women of GREVIO, to be issued later this year and is based on the work of the Council of Europe Cybercrime Convention 
Committee “Working Group on cyberbullying and other forms of online violence, especially against women and children”. 

71 

 
 
 
 
                                                 
concerning  non-consensual  sharing  of  images  and  content  and 
cyber  stalking  of  women,  the  initiative  ensures  that  the 
requirements  foreseen  by  the  DSA  can  be  fully  applied  to  this 
kind of illegal content across the EU.    

With respect to sexual harassment, a more targeted action than 
that  contained  in  the  Istanbul  Convention  is  triggered  in 
particular  by  the  adoption,  in  2019,  of  the  ILO  Convention  no. 
190. The report clarifies that the inclusion of specific measures 
on  this  matter  aim  at  bringing  EU  law  in  line  with  recent 
international standards.  

the  additional  added  value, 

Regarding 
i.e.  a  better 
implementation of the standards of the Istanbul Convention 
in line with best practices and recommendations identified by 
experts  and  expert  bodies  from 
the  Council  of  Europe 
(GREVIO)  and  the  United  Nations,  the  report  better  explains 
that the measures have been designed in  the five problem areas 
of  prevention,  protection,  access 
justice,  support  and 
coordination (as in the Istanbul Convention) because gaps have 
been  identified  in  all  five  areas  and  all  five  areas  must  be 
addressed  to  ensure  a  comprehensive  approach  to  tackle 
violence  against  women  and  domestic  violence,  as  well  as  to 
protect  and  support  the  victims  and  survivors.  The  report 
explains  that  the  aim  of  the  initiative  is  not  only  to  reduce 
prevalence of violence through prevention, but also to ensure 
fundamental  rights  of  the  women  victims  of  violence  against 
women  and  victims  of  domestic  violence  and  to  diminish 
negative societal impacts and improve victims’ quality of life.  

to 

5. The report is not 
sufficiently clear on the 
costs and benefits of the 
option packages. The 
presentation of the 
limitations and 
uncertainties in assessing 
these and the resulting 
benefit-to-cost ratios is 
underdeveloped. 

The report better explains that the cost and benefits have been 
estimated  on  the  basis  of  the  real  cost  for  similar  measures 
introduced in other areas (e.g. awareness raising campaigns and 
training) when available and best estimates for those specific to 
this initiative. The detailed methodology is presented in annex 4. 
The  report  further  clarifies  that  the  estimates  of  the  economic 
impact  have  been  assessed  based  on  the  reduction  of  the 
different  items  which  make  up  the  overall  cost  of  violence 
against  women  and  domestic  violence  to  society.  These  items 
have  been  divided  into  direct  cost  of  services  to  victims  or  to 
public service providers; lost economic output; and the physical 
and emotional impacts measured as a reduction in the quality of 
life. The expected impact  of the policy options depends mainly 
on  their  potential  to  reduce  the  prevalence  of  VaW/DV  in  the 
short  and  long-term.  This  approach  is  aligned  with  research 
conducted by the European Parliament Research Service.  
The  report  better  highlights  the  challenges  in  estimating  the 
economic  impact  of  the  proposed  measures  due  to  the  low 
number  of  impact  assessments  of  measures  against  this  kind  of 
violence  in  the  EU  context  and  the  need,  therefore  to  refer 
mostly  to  examples  from  the  United  States.  It  explains  why 
referring to US outcomes should not cause an overestimation of 
the results for the EU. 
The  report  better  explains  the  apparent  contradiction  that 

72 

 
 
 
 
6. The report does not 
sufficiently assess the 
effectiveness and 
proportionality of the 
preferred option. It is 
not clear why only a 
small part of the 
investments is foreseen 
for prevention measures 
and why the option with 
the best benefit-to-cost 
ratio is not selected. 

this 

that 

initiative  aims 

measures developed and implemented in the Member States are 
considered  to  have  been  insufficient  while  at  the  same  time 
similar  measures  are  proposed  at  EU  level.  It  clarifies  that 
national  measures  have  lacked  the  integrated  framework  and 
minimum  standards 
to  provide. 
Minimum  standards  and  guidance  set  by  EU  level  legislation 
enables  the  coverage  of  remaining  gaps  and  ensures  EU  level 
implementation  of  the  measures  in  line  with  best  practices  and 
recommendations  of  experts  and  international  expert  bodies.  In 
addition, it ensures monitoring and enforcement at a level which 
is impossible by international bodies. 
Concerning the costs for business and national authorities, 
including substantive compliance costs and administrative 
costs, the relevant tables in the Impact Assessment itself and the 
accompanying annexes have been revised to make those clear. 
The report clarifies that the effectiveness of the initiative  is not 
only measured in terms of reducing the number of victims of 
violence,  but  also,  and  mainly, 
to  protect  victims’ 
fundamental rights.  
The  report  better  explains  that,  while  the  most  costly  measures 
included under the comprehensive options are not in the area of 
prevention,  a  number  of  measures  under  other  areas  e.g. 
guidelines to health and social services providers to be issued in 
the  victims  support  area,  training  of  relevant  professionals  and 
risk assessments, can also have a preventative effect, particularly 
on  secondary  victimisation.  Moreover,  the  larger  benefits  are 
expected in terms of reduced cost on current victims. While the 
initiative  targets  also  potential  (future)  victims  of  violence,  the 
aim  of  prevention  measures  is  also  to  increase  awareness  on 
abusive  behaviours  that  might  go  unreported  and  to  encourage 
victims  to  look  for  support.    Finally,  effectiveness  (in  terms  of 
cost reductions) is not necessarily proportional to costs: the most 
severe  cases  require  higher  costs  for  treatment  and  might  not 
yield proportional benefits.  
For  the  same  reason,  prevention  measures  can  still  be  effective 
even  with  only  a  5%  of  total  investment  costs.  Prevention 
measures  like  training  and  awareness-raising  activities  tend  to 
cost  less  than,  for  example,  specialised  support  services  for 
victims of sexual violence or increasing capacity of shelters due 
to  a  lighter  burden  on  human  resources.  In  the  long-term,  the 
impact of prevention measures can have a significant impact on 
changing  harmful  norms,  stereotypes  and  behaviour.  Effective 
prevention measures therefore offer  a  good cost-benefit ratio to 
address  gender-based  violence  against  women  and  domestic 
violence. 
Longitudinal studies show that  protection measures, such as  on 
protection  orders  and  enhanced  reporting  opportunities,  are 
associated  with  a  34%  and  40%  reduction  in  the  risk  of  re-
victimisation due to, for example, continuing domestic violence. 
Similarly,  based  on  an  assessment  of  the  US  National  Crime 
Victimization Survey, the use of victim services has been shown 
to  be  associated  with  a  40%  reduction  in  the  risk  of  re-

73 

 
 
 
 
victimisation. 
For a long time, violence against women and domestic violence 
have been tacitly accepted in the society. Legislation in this area 
gives a message to the society that gender-based violence against 
women and domestic violence is  a  criminal  act  and will not  go 
unpunished.  Evidence  (e.g.  FRA)  supports  the  estimation  that 
legislation  in  this  area  has  a  long-term  impact  on  reducing  this 
type of violence.  
The moderate option has very low costs compared to its benefits 
(though the expected benefits are largely lower than in the other 
options).  It  leaves  however  out  important  areas  of  intervention 
and  offers  a  more  limited  strategic  framework.  For  instance,  it 
does  not  include  specific  measures  on  cyber  violence  against 
women  or  sexual  harassment,  thus  failing  to  take  into  account 
the gaps and recent developments in these areas. In addition, the 
moderate option  remains at  the level  of  broad  and rather vague 
obligations which could be agreed on at international level, thus 
leaving aside the opportunity for a more robust framework based 
on stronger minimum standards at EU level. This is why option 
2,  and  more  specifically  option  2A  is  the  preferred  option.  The 
contribution  of  the  different  criteria  to  the  overall  score  is  now 
better  illustrated  in  the  table  comparing  the  options,  including 
with reference to proportionality. 

 EVIDENCE, SOURCES AND QUALITY 

1.3.1. Studies commissioned or supported by the European Commission 

European  network  of  legal  experts  in  gender  equality  and  non-discrimination  (2021). 
Criminalisation of gender-based violence against women in European States, including ICT-
facilitated violence. A special report, available at: 

https://www.equalitylaw.eu/downloads/5535-criminalisation-of-gender-based-violence-
against-women-in-european-states-including-ict-facilitated-violence-1-97-mb. 

European  Institute  for  Gender  Equality  (2021).  The  costs  of  gender-based  violence  in  the 
European  Union,  available  at:  https://eige.europa.eu/publications/costs-gender-based-
violence-european-union.  

ICF (2021). Study conducted in support of the impact assessment report [upcoming, reference 
to be added]. 

Eurobarometer - TNS. (2016). Special Eurobarometer 449: Gender-based violence.  

1.3.2. Selective list of relevant case law 

CJEU, Case C-105/03 – Maria Pupino, ECLI:EU:C:2005:386, 16 June 2005. 

CJEU, Case C-467/05 – Dell’Orto, ECLI:EU:C:2007:395, 28 June 2007. 

CJEU, Case C-404/07 – Katz, ECLI:EU:C:2008:553, 9 October 2008. 

CJEU, Case C-205/09 – Eredics and Sápi, ECLI:EU:C:2010:623, 21 October 2010. 

CJEU, Joined Cases C-483/09 and C-1/10 – Magatte Gueye and Valentín Salmerón Sánchez, 

ECLI:EU:C:2011:583, 15 September 2011. 

74 

 
 
 
 
 
 
CJEU, Case C-348/09 – P.I. v. Oberbürgermeisterin, ECLI:EU:C:2012:300, 22 May 2012. 

CJEU, Case C-115/15 – Secretary of State for the Home Department v. NA, 

ECLI:EU:C:2016:487, 30 June 2016. 

CJEU, Joined Cases C-511/18, C-512/18 and C-520/18 – La Quadrature du Net and Others 

v. Premier Ministre and Others, ECLI:EU:C:2020:791, 6 October 2020. 

ECtHR, X and Y v. the Netherlands, Application No. 8978/80, Judgment, 26 March 1985. 

ECtHR, M.C. v. Bulgaria, Application No. 39272/98, Judgment, 4 December 2003. 

ECtHR, Kontrová v. Slovakia, Application No. 7510/04, Judgment, 31 May 2007. 

ECtHR, Bevacqua and S. v. Bulgaria, Application No. 71127/01, Judgment, 12 June 2008. 

ECtHR, Branko Tomaşić and Others v. Croatia, Application No. 46598/06, Judgment, 15 

January 2009. 

ECtHR, Opuz v. Turkey, Application No. 33401/02, Judgment, 9 June 2009.  

ECtHR, E.S. and Others v. Slovakia, Application No. 8227/04, Judgment, 15 September 2009. 

ECtHR, Rantsev v. Cyprus and Russia, Application No. 25965/04, Judgment, 7 January 2010. 

ECtHR, A. v. Croatia, Application No. 55164/08, Judgment, 14 October 2010. 

ECtHR, Hajduová v. Slovakia, Application No. 2660/03, Judgment, 30 November 2010. 

ECtHR, V.C. v. Slovakia, Application No. 18968/07, Judgment, 8 November 2011. 

ECtHR, P.M. v. Bulgaria, Application No. 49669/07, Judgment, 24 January 2012. 

ECtHR, Kalucza v. Hungary, Application No. 57693/10, Judgment, 24 April 2012. 

ECtHR, A.A. and Others v. Sweden, Application No. 14499/09, Judgment, 28 June 2012. 

ECtHR, D.J. v. Croatia, Application No. 42418/10, Judgment, 24 July 2012. 

ECtHR, Valiuliene v. Lithuania, Application No. 33234/07, Judgment, 26 March 2013. 

ECtHR, Eremia and Others v. the Republic of Moldova, Application No. 3564/11, Judgment, 

28 May 2013. 

ECtHR, Mudric v. the Republic of Moldova, Application No. 74839/10, Judgment, 16 July 

2013. 

ECtHR, B. v. the Republic of Moldova, Application No. 61382/09, Judgment, 16 July 2013. 

ECtHR, N.A. v. the Republic of Moldova, Application No. 13424/06, Judgment, 24 September 

2013. 

ECtHR, W. v. Slovenia, Application No. 24125/06, Judgment, 23 January 2014. 

ECtHR, T.M. and C.M. v. the Republic of Moldova, Application No. 26608/11, Judgment, 28 

January 2014. 

ECtHR, O’Keeffe v. Ireland, Application No. 35810/09, Judgment, 28 January 2014. 

ECtHR, Durmaz v. Turkey, Application No. 3621/07, Judgment, 13 November 2014. 

ECtHR, W.H. v. Sweden, Application No. 49341/10, Judgment, 8 April 2015. 

ECtHR, Y. v. Slovenia, Application No. 41107/10, Judgment, 28 May 2015. 

ECtHR, R.H. v. Sweden¸ Application No. 4601/14, Judgment 10 September 2015. 

ECtHR, I.C. v. Romania, Application No. 36934/08, Judgment, 24 May 2016. 

ECtHR, Halime Kiliç v. Turkey, Application No. 63034/11, Judgment, 28 June 2016. 

75 

 
 
 
 
ECtHR, J. and Others v. Austria, Application No. 58246/12, Judgment, 17 January 2017. 

ECtHR, Talpis v. Italy, Application No. 41237/14, Judgment, 2 March 2017. 

ECtHR, B.V. v. Belgium, Application No. 61030/08, Judgment, 2 May 2017. 

ECtHR, Bălşan v. Romania, Application No. 49645/09, Judgment, 23 May 2017. 

ECtHR, E.B. v. Romania, Application No. 49089/10, Judgment, 10 March 2019. 

ECtHR, Kurt v. Austria, Application No. 62903/15, Judgment, 4 July 2019. 

ECtHR, Volodina v. Russia, Application No. 41261/17, Judgment, 9 July 2019. 

ECtHR, Buturugă v. Romania, Application No. 56867/15, Judgment, 11 February 2020. 

ECtHR, S.M. v. Croatia, Application No. 60561/14, Judgment, 25 June 2020. 

ECtHR, X and others v. Bulgaria, Application No. 22457/16, Judgment, 2 February 2021. 

ECtHR, E.G. v. Moldova, Application No. 37882/13, Judgment, 13 April 2021. 

ECtHR, J.L. v. Italy, Application No. 5671/16, Judgment, 27 May 2021. 

ECtHR, Volodina v. Russia (no. 2), Application No. 40419/19, Judgment, 14 September 2021. 

1.3.3. Selective bibliography 

EU legal acts 

Council Directive 89/391/EEC on the introduction of measures to encourage improvements in 

the safety and health of workers at work; 

Council Directive 2000/78/EC establishing a general framework for equal treatment in 

employment and occupation and the European framework agreement on harassment 
and violence at work; 

Council Directive 2004/80/EC relating to compensation to crime victims; 

Council Directive 2004/81/EC on the residence permit issued to third-country nationals who 

are victims of trafficking in human beings; 

Council Directive 2004/113/EC implementing the principle of equal treatment between men 

and women in the access to and supply of goods and services; 

Council Regulation (EC) No 2201/2003 concerning jurisdiction and the recognition and 

enforcement of judgments in matrimonial matters and the matters of parental 
responsibility, repealing Regulation (EC) No 1347/2000; 

Council Regulation (EU) 2019/1111 on jurisdiction, the recognition and enforcement of 

decisions in matrimonial matters and the matters of parental responsibility, and on 
international child abduction; 

Directive 2003/86/EC on the right to family reunification; 

Directive 2004/38/EC on the right of citizens of the Union and of their family members to 

move and reside freely within the territory of the Member States; 

Directive 2006/54/EC on the implementation of the principle of equal opportunities and equal 
treatment of men and women in matters of employment and occupation (recast); 

Directive 2008/115/EC on common standards and procedures in Member States for returning 

illegally staying third-country nationals; 

76 

 
 
 
 
 
Directive 2009/52/EC providing for minimum standards on sanctions and measures against 

employers of illegally staying third-country nationals; 

Directive 2010/41/EU on the application of the principle of equal treatment between men and 

women engaged in an activity in a self-employed capacity; 

Directive 2011/36/EU on preventing and combating trafficking in human beings and 

protecting its victims; 

Directive 2011/93/EU on combating the sexual abuse and sexual exploitation of children and 

child pornography; 

Directive 2011/95/EU on standards for the qualification of third-country nationals or stateless 
persons as beneficiaries of international protection, for a uniform status for refugees or 
for persons eligible for subsidiary protection, and for the content of the protection 
granted; 

Directive 2011/99/EU on the European protection order; 

Directive 2012/29/EU establishing minimum standards on the rights, support and protection 

of victims of crime; 

Directive 2013/32/EU on common procedures for granting and withdrawing international 

protection (recast) asylum procedures directive; 

Directive 2013/33/EU laying down standards for the reception of applicants for international 

protection (recast). 

Directive (EU) 2016/800 of the European Parliament and of the Council on procedural 

safeguards for children who are suspects or accused persons in criminal proceedings; 

Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 
2018 amending Directive 2010/13/EU on the coordination of certain provisions laid 
down by law, regulation or administrative action in Member States concerning the 
provision of audiovisual media services (Audiovisual Media Services Directive) in 
view of changing market realities; 

European framework agreement on harassment and violence at work (COM(2007) 686 final). 

Regulation (EU) No 606/2013 on mutual recognition of protection measures in civil matters. 

Commission documents 

European Commission, Guidance Document related to the transposition and implementation 

of Directive 2012/29/EU of the European Parliament and of the Council of 25 October 
2012 establishing minimum standards on the rights, support and protection of victims 
of crime, and replacing Council Framework Decision 2001/220/JHA, 19 December 
2013, available at: 
(https://ec.europa.eu/info/sites/default/files/13_12_19_3763804_guidance_victims_rig
hts_directive_eu_en.pdf).  

European Commission, Proposal for a Council Decision on the signing, on behalf of the 

European Union, of the Council of Europe Convention on preventing and combating 
violence against women and domestic violence, COM(2016) 111 final, 4 March 2016, 
available at: (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52016PC0111). 

European Commission, Communication from the Commission to the European Parliament 
and the Council. Reporting on the follow-up to the EU Strategy towards the 
Eradication of trafficking in human beings and identifying further concrete actions, 

77 

 
 
 
 
 
COM(2017) 728 final, 4 December 2017, available at: (https://ec.europa.eu/anti-
trafficking/sites/antitrafficking/files/20171204_communication_reporting_on_follow-
up_to_the_eu_strategy_towards_the_eradication_of_trafficking_in_human_beings.pdf
).  

European Commission, Communication from the Commission to the European Parliament, 
the Council, the European economic and Social Committee and the Committee of the 
Regions on the EU Strategy on Combatting Trafficking in Human Beings 2021- 2025, 
final 14 April 2021, available at: (https://ec.europa.eu/home-
affairs/sites/default/files/pdf/14042021_eu_strategy_on_combatting_trafficking_in_hu
man_beings_2021-2025_com-2021-171-1_en.pdf) 

European Commission, Communication from the Commission to the European Parliament, 

the Council, the European Economic and Social Committee and the Committee of the 
Regions. A Union of Equality: Gender Equality Strategy 2020-2025, COM(2020) 152 
final, 5 March 2020, available at: (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM:2020:152:FIN).  

European Commission, Communication from the Commission to the European Parliament, 

the Council, the European Economic and Social Committee and the Committee of the 
Regions. EU Strategy on victims’ rights (2020-2025), COM(2020) 258 final, 24 June 
2020, available at: 
(https://ec.europa.eu/info/sites/default/files/law/2_en_act_part1_v10.pdf). 

European Commission, Communication from the Commission to the European Parliament, 

the Council, the European Economic and Social Committee and the Committee of the 
Regions. EU strategy for a more effective fight against child sexual abuse, 
COM(2020) 607 final, 24 July 2020, available at: (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM:2020:607:FIN).  

European Commission, Communication from the Commission to the European Parliament, 

the Council, the European Economic and Social Committee and the Committee of the 
Regions on achieving the European Education Area by 2025, COM(2020) 625 final, 
30 September 2020, available at: (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52020DC0625). 

European Commission, Report on the progress made in the fight against trafficking in human 

beings (2016) as required under Article 20 of Directive 2011/36/EU on preventing 
and combating trafficking in human beings and protecting its victims, COM(2016) 
267 final {SWD(2016) 159 final}, 19 May 2016, available at: 
(https://ec.europa.eu/anti-
trafficking/sites/antitrafficking/files/report_on_the_progress_made_in_the_fight_again
st_trafficking_in_human_beings_2016.pdf).  

European Commission, Second report on the progress made in the fight against trafficking in 
human beings (2018) as required under Article 20 of Directive 2011/36/EU on 
preventing and combating trafficking in human beings and protecting its victims, 
COM(2018) 777 final {SWD(2018) 473 final}, 3  December 2018, available at: 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=COM%3A2018%3A777%3AFIN).   

European Commission, Third report on the progress made in the fight against trafficking in 
human beings (2020) as required under Article 20 of Directive 2011/36/EU on 
preventing and combating trafficking in human beings and protecting its victims, 
COM(2020) 661 final {SWD(2020) 226 final}, 20 October 2020, available at: 
(https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0661). 

78 

 
 
 
 
European Commission, Report on the implementation of Directive 2012/29/EU of the 

European Parliament and of the Council of 25 October 2012 establishing minimum 
standards on the rights, support and protection of victims of crime, and replacing 
Council Framework Decision 2001/220/JHA, COM(2020) 188 final, 11 May 2020, 
available at: (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A188%3AFIN).  

European Commission, Report on the implementation of Directive 2011/99/EU of the 

European Parliament and of the Council of 13 December 2011 on the European 
protection order, COM(2020) 187 final, 11 May 2020, available at: 
(https://op.europa.eu/en/publication-detail/-/publication/770f93b9-9369-11ea-aac4-
01aa75ed71a1/language-en). 

European Commission, Communication from the Commission to the European Parliament, 

the Council, the European Economic and Social Committee and the Committee of the 
Regions. On the European democracy action plan, COM(2020) 790 final, 3 December 
2020, available at: (https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52020DC0790&from=EN). 

European Commission, Communication from the Commission to the European Parliament, 

the Council, the European Economic and Social Committee and the Committee of the 
Regions on the EU  Strategy on the Rights of the Child, COM/2021/142 final, 24 
March 2021, available at: https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A52021DC0142 

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Arenas-Arroyo,  E.,  Fernández-Kranz,  D.  &  Nollenberger,  N.,  “Can’t  Leave  You  Now! 
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Bohner,  G.,  et  al.,  “Rape  myth  acceptance:  Cognitive,  affective  and  behavioural  effects  of 
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Bowlus,  A.J.  &  Seitz,  S.,  “Domestic  Violence,  Employment,  And  Divorce”,  International 

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87 

 
 
 
 
ANNEX 2: Stakeholder consultation 

 The stakeholder consultation strategy 

To inform the preparations of the legislative initiative, the Commission consulted extensively 
with  stakeholders  to  gather  up-to-date  information  and  expertise  and  to  develop  effective 
measures  to  counter  gender-based  violence  against  women  and  domestic  violence,  as 
indicated  in  the  stakeholder  strategy  developed  in  support  of  the  initiative.  Relevant  results 
from  previous  consultations  have  also  been  taken  into  account227.  In  addition,  in  2016,  the 
Commission  also  conducted  a  specialised  Eurobarometer  survey  on  gender-based  violence 
with  a  sample  of  over  27,000  respondents  form  all  EU  Member  States228.  These  activities 
have  contributed  to  the  design  and  testing  of  the  policy  options.  Details  on  the  individual 
consultations are provided in the following. 

 Open  public  consultation  on  ‘Combating  gender-based  violence  –  protecting 

victims and punishing offenders’ (8 February 2021 – 10 May 2021) 

Objectives of the public consultation 

The European Commission conducted an open public consultation to gather the views of the 
public on measures to address gender-based violence against women and domestic violence. 
The purpose of the consultation was to assess the existing legal framework at EU level insofar 
as relevant for matters of gender-based violence and domestic violence as well as to inform 
the  Commission’s  work  on  further  measures  for  improved,  coordinated  prevention  of  and 
protection against this kind  of violence. This  public consultation  forms  part of the evidence 
gathering  carried  out  in  support  of  the  impact  assessment  conducted  in  preparation  for  a 
legislative initiative to prevent and combat violence against women and domestic violence.  

Approach to the public consultation 

Open  public  consultations  are  not,  by  nature,  statistically  representative  of  the  population 
(unlike, e.g., public opinion polls). Therefore, their purpose is not to find answers that could 
be generalised, but rather to gain in-depth insights to shed new light on a range of issues. 

The  public  consultation  was  open  from 8  February  2021  to  10  May  2021. It  included  66 
questions across five sections. Two of the questions were exclusively open-ended and 11 were 
multiple choice, which permitted the selection of multiple response options. 47 of the closed-

227 See ‘Open public consultation on gender equality in the EU: Current situation and priorities for the future’ (8 
March  2019  –  31  May  2019),  where  46%  of  all  respondents  held  that  strengthening  the  rights  of  victims  of 
gender-based  violence,  including  on  specific  support,  protection  measures  and  compensation  was  crucial. 
Prevention  work,  including  by  tackling  gender  stereotypes  and  promoting  non-violent  conflict  resolution  was 
selected by 40% of all respondents and 67% of employers’ organisations. In addition, developing  measures to 
tackle online hate speech, abuse and violence against women and girls (36% of all respondents),  data collection 
and  research  on  root  causes,  prevalence,  consequences  or  costs  (31%  of  all  respondents),  and  ensuring  that 
gender-based  violence  is  addressed  within  relevant  EU  policies  and  strategies  (education,  humanitarian  aid, 
digital  agenda,  etc.)  (31%  of  all  respondents)  were  identified  as  further  key  actions  to  be  considered  by  the 
Commission in combating gender-based violence. 
228  European  Commission,  Eurobarometer 
at: 
(https://europa.eu/eurobarometer/surveys/detail/2115). Also European Commission, Eurobarometer 428: Gender 
Equality,  2015,  available  at:  (https://europa.eu/eurobarometer/surveys/detail/2048),  where  violence  against 
women (especially sexual violence),  was considered one of the two areas that the EU  should address the  most 
urgently. 

449:  Gender-based 

violence, 

available 

2016, 

88 

 
 
 
 
                                                 
ended  questions  also  provided  the  opportunity  to  include  an  open  text  response.  The 
consultation gathered  input  from  a  range  of  stakeholders,  including  individual  citizens,  civil 
society organisations, social partners, equality bodies, Member States and national authorities. 
The questionnaire was uploaded on the Have Your Say portal of the European Commission.  

Overview of the respondents 

There were 767 respondents to the open public consultation from across the Member States, 
Hungary was the most represented with  371 respondents  (48%), followed by  Italy  with  126 
(16%) and Germany with 87 (11%) (see Figure 1). The replies showed no organised campaign 
or similar attempt to influence outcomes. The high number of responses in Hungary resulted 
from publicity of the consultation in national media. There were much fewer responses from 
other EU countries, varying between 37 (Spain, Belgium) and one (Luxembourg); only Latvia 
had none. There were four responses from non-EU citizens, one from Albania and three from 
citizens who nevertheless indicated residence in EU Member States. 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Overview of responses 

The questionnaire allowed respondents to reply to one, several, or all of the sections. Whilst 
the  total  number  of  respondents  was  767,  this  was  not  the  total  response  rate  for  each 
question. As can be seen in Figure 2, which shows the number of responses received for each 
question,  Question  1  received  the  highest  number  of  responses  (758),  and  Question  19  the 
fewest (287). Of the five sections, Section I received the highest average number of responses 
(751), followed by Section III (711). Section IV received the fewest (664) (see Figure 3). 

Section I: How to effectively prevent gender-based violence and domestic violence? 

In  response  to  the  first,  and  most  responded  to,  question,  the  overwhelming  majority  (725 
respondents, 96%) believe it is ‘Very important’ that their Member State takes  measures to 
prevent violence against women (VAW/DV) (Figure 4).  

The measures considered as the most frequently taken to prevent VAW/DV in Member States 
are  awareness-raising  among  the  general  public  (435  respondents,  59%)  and  training  of 
relevant professionals (274 respondents, 37%). No knowledge of measures taken is the third 
most selected option (233 respondents, 32%) and is chosen almost exclusively by respondents 
from  Hungary.  The  predominant  reasons  given  for  measures  being  ineffective  are  that  the 

90 

 
 
 
 
 
 
 
public  is  not  sufficiently  aware  of  this  kind  of  violence  or  see  it  as  a  private  matter  (579 
respondents,  79%) and that  there  are not  enough services  and activities offered to  empower 
survivors and encourage them to break the silence (538 respondents, 73%).  

37%  (272)  of  respondents  are  aware  of  prevention  programmes  at  national  or  local  levels 
for  perpetrators  of  VAW/DV.  Among  respondents  from  Hungary,  however,  this  is 
substantially lower (55 respondents, 15%) and among respondents from Italy and Germany it 
is higher (58% (73) and 73% (55) respectively).  Respondents recognize that the media (336 
respondents,  46%)  and  the  cultural  and  creative  (270  respondents,  37%)  sectors  have  in 
particular made efforts to support prevention of VAW/DV in their Member States.  

Regarding training, almost half of all respondents (340 respondents, 48%) do not believe that 
professionals  are  adequately  trained  to  work  with  victims  of  VAW  or  perpetrators.  This  is 
echoed  in  the  responses  from  Hungary  and  Italy  whereas  43%  (33)  of  respondents  from 
Germany  believe  they  are.  As  to  whether  NGOs  provide  training,  almost  half  of  the 
respondents  indicated  they  do  not  know  (346  respondents,  49%),  against  38%  (264)  who 
indicated that they do so. 

Concerning  possible  further  prevention  measures,  most  respondents  (672  respondents, 
90%)  deem  very  important  that  harmful  gender  stereotypes  be  challenged  to  prevent 
VAW/DV.  Measures  that  teach  non-discrimination,  gender  equality  and  non-violent 
communication topics in schools are viewed as most needed to better prevent VAW/DV (687 
respondents, 94%), followed by further measures to raise awareness about VAW/DV among 
the general public (605 respondents, 82%).  

Section II: Protection from further violence and access to justice, including compensation  

The  question  in  this  section  with  the  highest  response  rate  (734)  was  whether  victims  of 
VAW/DV are provided with information on their rights, the services they can turn to and 
the  follow  up  given  to  their  complaints,  to  which  60%  (439)  of  respondents  selected 
‘Partially’  (see  Figure  5).  Moreover,  in  terms  of  the  timeliness  of  this  information  and  its 
accessibility,  respondents  predominantly  found  that  information  is  not  provided  quickly 
enough (292 respondents, 43%), is difficult to find (283 respondents, 42%) and is inconsistent 
and spread over different sources (281 respondents, 42%).  

91 

 
 
 
 
 
For questions concerning the conduct of authorities, the majority (543 respondents, 75%) of 
respondents do not consider that relevant authorities or services ensure that  risk factors are 
sufficiently considered at all stages of investigation and court proceedings. Additionally, 56% 
(404)  of  respondents  do  not  believe  that  law  enforcement  and  judicial  authorities  in  their 
Member  State  ensure  appropriate  follow-up  of  VAW/DV  reports.  Over  half  of  the 
respondents (420 respondents, 57%) do not believe that these authorities treat victims, as well 
as child witnesses, in a gender-sensitive and child friendly manner. Open text commentary 
detailed that the treatment of victims is at the discretion of the officials involved and shows 
biases  and  re-victimization  (victims  being  blamed  or  not  believed).  In  countries  such  as 
Belgium,  Germany,  and  Italy,  however,  where  special  processes  or  staff  training  have  been 
implemented,  some  described  a  positive  environment.  The  prevalent  view  across  all 
respondents  is  that  sanctions  for  gender-based  and  domestic  violence  offences  are  not 
sufficient (548 respondents, 75%). Many respondents raised issues related to sanctions, such 
as low rates of conviction, light or suspended sentences, and a lack of enforcement.    

Regarding compensation for victims, almost half of the respondents (354 respondents, 49%) 
do not believe that information on how victims can obtain compensation (from the offender 
and/or the state) is available in their Member State. Whilst this view was echoed by two of the 
most represented countries (Hungary and Italy), 59% (42) of respondents from Germany (the 
third  most  represented  country)  do  deem  this  information  to  be  available.  A  minority  of 
respondents  (108  respondents,  15%)  believe  that  victims  do  receive  compensation  from  the 
offender, although 39% (279) do not know. The final question on compensation (question 19) 
received  the  fewest  responses  across  all  questions  (286).  It  asked  respondents  to 
hypothetically  describe  the  process  of  pursuing  compensation,  should  they  be  entitled  to  it, 
which the overwhelming majority (241 respondents, 84%) described as difficult and long. 

The  final  question  of  this  section  asked  whether  further  measures  to  improve  access  to 
justice in  matters of VAW/DV could  improve the situation of victims, to which 73% (516) 
responded they believe that they could at both national and EU level.  

Section III: Supporting victims of violence against women and domestic violence 

The first question in this section asked whether support services (either general or specialist) 
are  available  to  victims  of  gender-based  and  domestic  violence  in  respondents’  Member 
States.  Across  all  respondents,  64%  (464)  do  understand  these  services  to  be  available. 
However,  for  two  of  the  most  represented  countries,  Germany  and  Italy,  this  proportion  is 
substantially higher, at over 82% (see Figure 6). 

92 

 
 
 
 
 
Regarding general support services, three quarters of respondents (526, 75%) selected that 
neither  they  nor  those  with  whom  they  have  a  close  relation  have  used  them.  Those  who 
replied that they had used these services (11 respondents, 17%), frequently mentioned social 
services,  followed  by  employment  services,  health  services,  psychological  or  counselling 
services,  and  anti-violence  centres.  In  response  to  whether  general  support  services 
systemically account for the needs of victims of VAW/DV, most (344 of respondents, 48%) 
do not believe they do, against 17% (123) who believe they do, while the remainder do not 
know  (251  respondents,  35%).  Further  open  text  responses  focused  on  the  limited  scope  of 
support,  with  a  frequent  lack  of  financial  support  and  provision  of  counselling  to  victims. 
Similarly, 46% (330) of respondents believe general support services do not take systematic 
account  of  the  special  needs  of  child  victims/witnesses  of  domestic  violence,  against  19% 
(139) who believe they do, while others (250 respondents, 35%) do not know. 

The following support services questions relate to specialist support services. 39% (283) of 
respondents  believe  that  general  support  services  refer  victims  to  appropriate  specialist 
services in their Member State. The proportion, however, is higher among respondents from 
Italy and Germany and  accounts for over 60% in  both  cases.    In terms  of specialist support 
services that are accessible only to women victims of gender-based or domestic violence, 54% 
(385) of respondents believe that these are available. However, knowledge of services that are 
accessible to male victims is much lower (141 respondents, 20%).  For the special needs of 
child victims and child witnesses of domestic violence, almost 50% (332) of respondents do 
not know whether these specialist services systematically take children’s needs into account, 
and supplementary open-text responses suggest this is inadequate. 

Three questions in this section address the availability of support services that account for the 
needs of different groups of victims. Firstly, the accessibility of support services for persons 
with disabilities is unknown to half of the respondents (356 respondents, 51%). Secondly, the 
availability of services without discrimination, such as that based on racial or ethnic origin, is 
split across respondents 32% (225) believe they are, 35% (247) believe they are not and 33% 
(233) do not know). Thirdly, responses as to whether victims receive information on support 
services in a timely manner and in a language they understand is also split but with a higher 
proportion of people not knowing (292 respondents, 41%). 

As  to  whether  further  measures  should  be  taken  to  improve  the  support  to  victims  of 
VAW/DV, the majority (553 respondents, 77%) believe they should, at national and EU level. 

Section IV: Specific forms of violence against women 

Concerning specific forms of violence against women, as shown in Figure 7, the majority of 
respondents  understand  that  the  primary  gaps  in  protection  against  sex-based  and  sexual 
harassment result from the perception that it is not considered a real problem by the general 
public  (431  respondents,  66%),  that  sanctions  are  insufficient  (430  respondents,  66%),  and 
that provisions are ineffectively enforced (406 respondents, 62%).  

93 

 
 
 
 
 
 
 
Over half of respondents (355 respondents, 52%) are not aware of anti-harassment policies or 
guidelines  developed  by  government  or  social  partners  on  tackling  sex-based  harassment  at 
work. 48% (324) are aware of these policies/guidelines either by both government and social 
partners or by one of them (see Figure 8). 

60%  (391)  of  respondents  are  unaware  of  a  workplace  policy  on  sex-based  harassment. 
Similarly, over three quarters of respondents (515 respondents, 78%) are not aware of training 
of  employer  representatives  in  their  Member  State.  In  further  open-text  responses,  among 
respondents  aware of training provided by their  Member State, most stated that the  training 
offered is not mandatory, and therefore whether employees have to follow it depends largely 
on  the  commitment  of  employers.  Finally,  59%  (394)  of  respondents  do  not  know  which 
national  authorities  or  other  bodies  they  can  contact  in  their  Member  State  in  cases  of  sex-

94 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
based harassment at work. However, for respondents from Italy and Germany, over half (54% 
and 62% respectively) do know who to contact.  

The  second  category  covered  is  gender-based  cyber  violence.  68%  (470)  of  respondents 
believe that it has become more common in recent years in their Member State; and the most 
common forms of illegal gendered online content are believed to be gender-based hate speech 
(566 respondents, 84%), illegal sharing of private photos (492 respondents, 73%), and cyber-
stalking  (471  respondents,  70%).  In  further  open-text  commentary,  respondents  mentioned 
that  the  spread  of  the  internet  is  one  of  the  main  problems,  as  abusers  benefit  from  its 
anonymity  when  engaging  in  abusive  behaviour.  In  response  to  whether  perpetrators 
explicitly  indicate  that  their  behaviour  is  based  on  a  victim’s  gender,  there  is  no  consensus 
(40% (270) said that they do, 23% (154) that they do not and 37% (255) do not know). The 
supplementary open-text commentary explains that although gender may not be clearly stated, 
the vocabulary and content reveal the gendered nature of the abuse. 

In terms of measures that respondents believe online platforms should take to combat illegal 
and harmful gendered online content, the primary option selected is maintaining an effective 
‘notice and action’ system for users to report content (545 respondents, 81%), followed by the 
establishment  of  policies  in  this  area  and  informing  users  of  these  policies  including  the 
effects  of  breaches  (493  respondents,  73%).  In  the  event  that  online  platforms  establish 
specific policies on illegal and harmful gendered content, most respondents believe that they 
should  inform  users  on  how  to  seek  assistance  from  the  platform  and  explain  the  available 
complaint mechanisms (573 respondents, 88%). If equality bodies in the EU Member States 
had powers to address this kind of content, the main power respondents indicated they should 
have is the provision of legal advice to victims (543 respondents, 83%).  

The third category is  harmful practices, and the first question asks whether measures were 
taken  in  Member  States  to  prevent  harmful  practices  targeting  women.  Across  respondents, 
40% (268) indicated that they were, and further open-text responses predominantly mentioned 
criminal laws of their Member State. As regards protection or support programmes for victims 
of  these  practices,  36%  (242)  of  respondents  are  not  aware  of  them  and  34%  (229)  do  not 
know, whilst almost half of respondents (327 respondents, 49%) do not believe that existing 
preventive,  intervention  or  support  measures  are  effective.  More  than  half  the  respondents 
(372  respondents,  56%)  do  not  know  whether  psychological  and  gynecological  care  are 
available in their Member State for victims of female genital mutilation. For respondents from 
Germany, however, the majority are aware of care available (50 respondents, 74%).  

On the issue of trafficking in human beings, the final  category, 42% (277) of respondents 
are  aware  of  prevention  measures  in  their  Member  State.  For  respondents  from  Italy  and 
Germany,  this  is  more  pronounced  (56%  and  68%  respectively).  42%  (268)  of  respondents 
believe that other aspects of sexual exploitation of women and girls than trafficking should 
be addressed in EU law - with the most occurring theme being prohibition of buying sexual 
services. 

Section V: other aspects related to violence against women and domestic violence 

Responses  as  to  whether  data  on  gender-based  violence  and  domestic  violence  is  being 
regularly collected at national level are split (43% (293) selected that it is, 31% (210) do not 
know and 26% (176) believe it is not).  

95 

 
 
 
 
As to specific aspects of gender-based or domestic violence, 65% (428) of respondents do not 
know  whether  violence  targeting  women  with  disabilities  are  addressed  by  general 
measures.  In  open  text  responses,  respondents  remarked  on  the  general  lack  of  attention  to 
women with mental  and physical disabilities. Similarly, specific aspects  of intergenerational 
violence, not addressed by general measures, are also unknown (367 respondents, 56%). 

On measures to address psychological violence, 55% (371) of respondents are not aware of 
specific measures. This is similar for measures to address  economic violence, where almost 
half  (310  respondents,  46%)  are  not  aware  of  them.  57%    (382)  of  respondents  deemed 
measures  to  tackle  sexual  violence  to  be  ineffective.  This  is  echoed  by  respondents  from 
Hungary  and  Italy,  while  42%  (28)  of  respondents  from  Germany  believe  that  measures  in 
their  country  have  been  effective.  Across  all  respondents,  57%    (385)  think  that  there  are 
specialised support services available for victims of sexual violence.  

63% (427) of respondents believe that regional differences in the availability of preventative, 
protection,  and  support  services  regarding  gender-based  violence  and  domestic  violence  do 
exist.  Most  respondents  indicated  strong  differences  between  rural  and  urban  areas  in  the 
availability of support services, with rural areas more at risk as most services are city-based. 

Almost 70% (453 respondents, 67%) of respondents believe that NGOs encounter issues in 
their work on gender-based violence and domestic violence. The final question addresses the 
extent  to  which  COVID-19  had  impacts  on  gender-based  and  domestic  violence.  The 
majority of respondents  believe that there has been an impact  (567 respondents, 83%), with 
almost  70%  (470  respondents,  69%)  believing  that  this  impact  is  severe  (see  Figure  9).  In 
open text responses, respondents mostly reported that they perceived a considerable increase 
in domestic violence in the context of COVID-19.  

Finally, 23 written submissions were made to the European Commission in connection with 
the  open  public  consultation.  These  include  inputs  and  recommendations  from  the  United 
Nations agencies (1), European agencies (1) social partners (2) and NGOs (19). 

 Feedback to the Inception Impact Assessment  

A total of 63 contributions were submitted. The replies present broadly the whole stakeholder 
spectrum:  NGOs,  individual  citizens,  international  organisations,  social  partners,  academics 

96 

 
 
 
 
 
and  research  institutions,  equality  bodies,  the  private  sector,  foundations,  company  and 
business  organisations  and  trade  unions.  Most  stakeholders  agreed  with  the  need  for  a 
comprehensive,  holistic  legislative  initiative  on  GBV,  NGOs  underlining  the  need  for  an 
intersectional approach.  

 Targeted consultations and engagement activities 

1.4.1. Targeted consultation for the Member States  

The European Commission organised a targeted consultation with Member States. The online 
survey gathered views and information on the measures taken to prevent and combat violence 
against  women  and  domestic  violence.  Responses  were  received  from  all  Member  States 
except for Malta, although response rates varied for each country, with Croatia not responding 
to most questions. 

Section 1: coordination and data collection 

For  section  one,  all  Member  States  that  answered  have  reported  some  form  of  a  policy 
framework  to  address  violence  against  women  and  domestic  violence,  with  the  most 
common challenge being to find consensus among the different actors, and  challenges with 
inter-agency cooperation, budgetary restraints and lack of political will. 

Most  (24)  reported  that  they  have  an  official  mechanism  is  in  place  for  coordinating 
measures  and  sharing  good  practices  on  tackling  violence  against  women  and  domestic 
violence, and an equal number reported that the coordination of measures and the sharing of 
good practices on preventing and combatting violence against women and domestic violence 
is ensured among the regional and/or local authorities in their Member State.  

Authorities  representing  25  Member  States  responded  that  data  is  regularly  collected  on 
violence  against  women  and  domestic  violence,  and  although  there  were  significant 
variations,  the  most  common  answer  was  that  data  is  collected  by  the  police  and  published 
annually.  Most  make  the  data  public.  Disaggregation  of  data  varies  considerably.  All  had 
some  level  of  disaggregation  of  data,  mostly  by  sex  and  age.  Only  some  disaggregated  by 
geographical  location  and  very  few  by  disability.  For  most  member  States,  the  level  of 
disaggregation  depends  on  the  crime.  Other  disaggregation  were  also  used,  such  as 
relationship to the perpetrator.  

Concerning  data  collection  to  measure  the  impact  of  the  Covid-19  crisis  on  violence 
against  women  and  domestic  violence,  21  Member  States  responded  that  data  has  been 
collected  (PL,  RO,  IE  and  BG  answered  in  the  negative).  The  most  common  challenge  for 
data collection  was  ensuring harmonised data collection between different institutions  along 
with challenges collecting the data.  

Section 2: prevention of violence against women and domestic violence 

25 Member States responded that awareness-raising campaigns on violence against women 
and  domestic  violence  have  been  organised.  26  Member  States  responded  that  training  to 
professionals  working  with  victims  of  violence  against  women  and  domestic  violence,  or 
with perpetrators, is available.  

24 Member States responded that this training follows a child-sensitive approach. Only DK 
responded in the negative (no response from MT and DE). 22 MS responded that this training 
follows a gender-sensitive approach. NL and CZ responded in the negative; no response was 
received from MT, DE and SE.  

97 

 
 
 
 
Member States listed wide range of challenges in preventing violence against women and 
domestic violence. These included embedded negative social attitudes and the need for more 
awareness-raising,  particularly  with  men  and  perpetrators,  to  change  them.  Capacity 
challenges were also raised around a lack of training, funding and inter-agency cooperation. A 
lack of reporting and lack of understanding of prevalence was also noted as making it harder 
to identify and support victims. 

Section 3: protection and support 

All  Member  States,  excluding  LV  and  MT,  responded  that  national  protection  orders  are 
used in cases of violence against women and domestic violence. Regarding the consequences 
of  breaching  national  protection  orders,  21  Member  States  replied  there  are  criminal 
sanctions,  9  Member  States  that  there  are  civil  sanctions,  and  in  2  there  are  other 
consequences. In only one there are no consequences.  

14 Member States have responded that further measures would be useful to make national 
protection orders more effective in practice. Six Member States (22%) (NL, SI, FR, CZ, LU 
and AT) responded in  the negative and no response was provided by seven  Member States.  
52%  of  Member  States  (14)  have  responded  that  foreign  protection  orders  have  been 
recognised and enforced in their Member State. Three authorities responded in the negative 
(NL, DE and CZ) and ten did not provide a response. 

Regarding  challenges  in  the  use  of  the  EU  rules  on  mutual  recognition  of  protection 
orders  (in  civil  or  in  criminal  matters)  BE,  CZ  and  FI  said  the  problem  is  a  ‘Lack  of 
awareness  about  the  possibility  of  mutual  recognition  of  foreign  protection  orders  (by  the 
relevant  authorities  or  the  parties  involved)’.  BG  and  RO  said  ‘Divergence  of  sanctions  in 
different  Member  States  for  similar  types  of  protection  orders’.  DK  and  EE  said  ‘other 
issues’. PL, LV and EE said there are have been very few cases so they could not report on 
any issues. EE and FR said there are no known problems. Other MS did not respond.  

In response to whether law enforcement authorities are empowered or obliged to inform a 
support  service  of  cases  of  violence  against  women  and  domestic  violence,  12  Member 
States  (44%)  selected  the  latter  (obliged)  and  13  (48%)  selected  the  former  (empowered). 
Only  EL  responded  that  they  may  not  do  so.    25  Member  States  responded  that  support 
services  (general  or  specialised)  are  available  to  victims  of  violence  against  women  and 
domestic violence in their Member States. Only BG responded that they are available only in 
some parts/regions of the country. 

In  regard  to  whether  general  support  services  systematically  take  into  account  the  special 
needs  of  child  victims  and  witnesses  of  domestic  violence  based  on  a  child-sensitive 
approach,  18  Member  States  responded  that  they  do.  Seven  Member  States  responded  that 
they  do,  but  not  systematically,  and  two  Member  States  (FR  and  MT)  did  not  provide  a 
response.  All  26  Member  States  responded  that  general  support  services  refer  victims  to 
appropriate specialist services in their Member State. 

The below table indicates the available support services referred to. 23 Member States refer 
to  legal  counselling  services,  21  to  psychological  support,  21  to  health  services,  21  to 
helplines for victims, 18 to housing services and 14 to financial support services.   

22  Member  States  responded  that  there  are  specialist  support  services  accessible  only  to 
women victims of gender-based and/or domestic violence in their Member State (LV, ES, HU 
and  PL  answered  in  the  negative).  16  Member  States  responded  that  there  are  specialist 
support services  accessible to  male victims of domestic violence while eight responded that 
specialist  support  services  are  not  accessible  to  male  victims  in  their  Member  State.  IT,  PL 

98 

 
 
 
 
and  MT  did  not  provide  a  response.  56%  (15)  Member  States  responded  that  specialist 
support  services  do  systematically  take  into  account  the  special  needs  of  child  victims  and 
child  witnesses  of  domestic  violence  based  on  a  child-sensitive  approach.  Eight  (30%) 
responded that they do, but not systematically.  

All 23 Member States that provided a response responded in the affirmative, that victims of 
VAW/DV are  informed of their rights, of  the services they  can turn to, and the follow-up 
given to their complaint. CZ, HR and MT did not provide a response. 

16 Member States said the above-mentioned information is easily available. One said that the 
information is inconsistent and spread over different sources (PL). Four said the information 
is not available in all languages needed. One said the information is difficult to find (LU).  

22 Member States responded in the affirmative to the question whether support programmes 
for perpetrators of violence  against women  and domestic violence have been set  up.  Only 
HU  responded  that  support  programmes  for  perpetrators  have  not  been  set  up  (four  did  not 
provide a response). 18 Member States responded in the positive to the question whether there 
are measures within these perpetrator programmes to ensure the safety of, support for and the 
respect of human rights of women victims. PT and LV responded in the negative and seven 
did not provide a response. 

Just over half of the Member States (14) responded that there are support services for victims 
of violence  accessible to persons with disabilities.  10 Member States responded that there 
are  partly  (in  terms  of  geographical  accessibility  and/or  in  terms  of  services).  25  Member 
States  provided  a  response  to  this  question,  and  all  state  that  that  support  services  are 
available to all women victims of violence without discrimination on grounds such as racial or 
ethnic  origin,  religion  or  belief,  disability,  age  or  sexual  orientation.  HR  and  MT  did  not 
provide  a  response.  52%  (14)  Member  States  responded  that  the  availability  of  support 
services is not conditional upon the victim’s residence status for migrant women victims of 
violence. Five did not provide a response and eight responded that it is conditional.  

25  Member  States  responded  that  measures  have  been  taken  to  ensure  the  regional 
availability of preventive, protection and support services regarding violence against women 
and domestic violence. BG answered in the negative. 26 Member States responded that NGOs 
or other non-governmental actors that provide victim support services receive funding 
and  /  or  other  support  from  the  government.  24  Member  States  responded  that  the  national 
laws transposing the Victims’ Rights Directive foresee specific measures addressing the needs 
of  victims  of  violence  against  women  and  domestic  violence  (three  did  not  provide  a 
response). 

Member  State  authorities  raised  a  very  wide  range  of  challenges  in  protecting  and 
supporting victims of violence against women and domestic violence, including challenges 
with criminalisation, lack of support services, insufficient training and funding, hesitancy of 
victims  to  report  and  engage  with  authorities,  lack  of  inter-agency  cooperation,  the  need  to 
increase public awareness of the phenomenon,  

Section 4: Access to justice, including prosecution 

24  Member  States  have  reported  that  arrangements  have  been  put  in  place  to  facilitate 
women’s and children’s access to justice. BG and RO stated that some of these arrangements 
have been put in place.  

All  26  Member  States  that  provided  a  response  responded  that  measures  have  been  put  in 
place to protect victims of VAW/DV, and/or their families and witnesses, from intimidation, 

99 

 
 
 
 
 
retaliation  and  repeat  victimisation during investigations and  court proceedings. 22 Member 
States responded that legal aid is available in cases of violence against women and domestic 
violence in the same way as it is for victims of other violence. BG and EL responded that it is 
available but is limited. IE responded that it is not available. 

25  Member  States  responded  that  arrangements  have  been  put  in  place  to  ensure  the  best 
interests  of  child  victims  and  witnesses  during  criminal  investigations  and  court 
proceedings. RO responded that some of these arrangements have been put in place.  

One  of  the  major  challenges  identified  by  Member  States  in  the  prosecution  of  cases  on 
violence against women and domestic violence is a lack of evidence, which makes conviction 
very  challenging  (AT,  CY,  DE,  DK,  FI,  RO,  SE,  SK,  SL).  The  most  common  challenges 
which  women  victims  of  violence  against  women  and  domestic  violence  face  in  accessing 
justice  was  a  lack  of  reporting  which  was  highlighted  by  six  MS  as  one  of  the  main 
challenges in the prosecution of cases of GBV (BE, BG, CY, DE, IE, RO). 

Section 5: Harmful practices against women and girls 

44% (12) Member State responded that there is no data collection system in place to record 
asylum requested and/or granted on grounds of harmful practices against women while 
33% (9) of MS responded that there is a data collection system in place in their Member State.  

With regard to whether there are measures in place to ensure that custom, religion, tradition or 
so-called honour cannot be regarded as a justification for harmful practices against women, 
13 MS responded that this is specified by law. BE and HU responded that this is specified in 
government guidelines and seven Member State responded that this is not specified.  

In response to whether harmful practices against women and girls perpetrated abroad can 
be investigated, prosecuted and adjudicated, 19 Member State responded that this is the case. 
Only CZ responded in the negative. 

1.4.2. Targeted  consultation  workshop  with  non-governmental  organisations,  6  May 

2021 

The European Commission  organized an ad hoc meeting of the Victims’ Rights Platform229 
and NGOs working in the area of violence against women.  Eight individual interviews with 
NGOs were additionally conducted.  

NGOs  identified  a  range  of  protection  and  support  gaps  across  the  EU  for  victims  of 
violence  against  women  and  domestic  violence.  Victims  face  significant  challenges  in 
accessing justice. NGOs indicated that significantly more action was needed  at national and 
EU  levels  to  effectively  tackle  such  violence.  They  did  not  articulate  challenges  with  the 
current  EU  legislation,  but  felt  the  main  challenge  is  the  need  for  more  comprehensive 
legislation  to  tackle  the  issue  of  VAW/DV  specifically,  particularly  in  Member  States  that 
have not ratified the Istanbul Convention.  

NGOs had largely consistent and complementary views in this area and articulated a range of 
views, focusing on the challenges to be addressed:   

229 https://ec.europa.eu/info/policies/justice-and-fundamental-rights/criminal-justice/protecting-victims-
rights/victims-rights-platform_en.  

100 

 
 
 
 
                                                 
■  Participants  noted  that  in  order  to  effectively  address  violence  against  women  and 
domestic violence, minimum standards on prevention and protection measures are 
needed at EU level, including on  work with perpetrators, more awareness of  violence 
against  women  and  domestic  violence  and  information  provision  to  victims  on 
accessing  support  and  protection.  Addressing  harmful  gender  stereotypes  as  one  of 
the  main  root  causes  of  gender-based  violence  and  the  education  sector  has  a  pivotal 
role in addressing them. 

■  Targeted trainings for professionals across sectors were broadly considered essential 
to  providing  effective  support  to  victims,  particularly  with  police  and  judicial 
authorities.  

■  They  noted  the  important  of  covering  a  wide  range  of  forms  of  violence,  including 
cyber violence. Some NGOs stressed that sexual exploitation and trafficking should not 
be conflated with sex work. 

■  NGOs  underlined  the  importance  of  inclusive  and  intersectional  approaches  to 
violence  against  women  and  domestic  violence  that  include  transgender,  lesbian, 
intersex  people,  migrants  (including  undocumented  migrants)  and  people  with 
disabilities. 

■  Generally,  all  participants  agreed  on  the  need  to  increase  resources  for  issuing 
emergency  barring  orders  in  order  to  ensure  more  effective  police  interventions,  as 
well  as  highlighted 
long-term  and  multiagency 
coordination and cooperation for the protection of victims. 

the  need  for  comprehensive 

■  The  participants  noted  the  need  for  more  action  to  address  barriers  to  access  to 

justice and the low rate of reporting. 

■  Most  participants  stressed  the  lack  of  general  and  specialised  support  services  for 
victims  and  stressed  the  importance  of  Member  States  providing  both  general  and 
specialised support services. They identified as a key challenge the lack of funding for 
victim support services.  

■  Most participants stressed the lack of comparable and comprehensive disaggregated 
data to understand the scale of the problem and better identify victims. They also noted 
the need to estimate the cost of violence and the relevant benefits. 

■  Multiagency  coordination  was  considered  essential  both  at  the  national  level  and  at 
regional  /  local  levels  to  ensure  geographical  availability  of  services  and 
coordinated, holistic support and protection measures. Participants also highlighted 
the need for Member States to establish a coordination mechanism, as well as called for 
an EU level coordination mechanism. 

1.4.3. Workshop with social partners, 29 June 2021 

The  European  Commission  and  ICF  co-organised  a  targeted  workshop  meeting  with  social 
partners on 29 June 2021230.  The meeting focused on two aspects: 1) exchange of views on 
the effectiveness and relevance of the EU framework on preventing and combatting violence 

230    The  invitation  was  sent  to  the  social  partners’  representatives    in    the    Advisory    Committee    on    equal  
opportunities  for  women  and  men and to sectoral social partners that have expressed interest in the subject in  
the  context  of  their  Sectoral  Social  Dialogue  Committee  meetings.  An  identical  workshop  was  organised  for 
employer associations the following day. 

101 

 
 
 
 
 
                                                 
against women at work, and 2) and on the possible measures for increased prevention of sex-
based work harassment and protection of victims. 

Overall, the EU legislative framework was not seen as lacking although there were mentions 
that it was not sufficiently implemented. EU legislation was seen as only one factor affecting 
the work of social partners with many participants noting the important role of other factors, 
including the ILO Convention no.190 and the MeToo movement. One participant said there 
needs to be a more proactive approach. The current approach is largely reactive and requires 
litigation to claim those rights.  

Collective  bargaining  was  highlighted  by  some  participants as  the  best  root  to  proactive 
measures.  Collective  bargaining  was  described  as  having  led  to  negotiation of  collective 
agreements,  policy  commitments,  workplace  support  structures  and  trainings,  about  zero 
tolerance to harassment.  

One  participant  noted  that  to  prevent sexual  harassment, a  gender  equal  environment  in 
the workplace 
to  decision  making, and 
including  equal  pay, equal access 
an inclusive and just environment.  

is  needed, 

Risk assessments were discussed as having an important in preventing and combatting VAW. 
However it was raised that risk assessments are not gender responsive. It was also noted that 
very few risk assessments are carried out and when they are, they do not include psychosocial 
risks.  

Addressing  violence  against  women  and  domestic  violence  and  its  impacts  on  work 
environments  was  discussed.  Examples  of  concrete  measures,  including  10  days’  leave  for 
victims were mentioned. Some participants stressed that what happens at home has an impact 
on the work. This is not about encouraging into employees’ private lives but workplaces must 
be inclusive places so issues can be raised. Victims need insurance that they will not lose their 
job. It was also noted that violence in the workplace can also lead to domestic violence.  

One  participant  raised 
around absenteeism and other costs that would make it in companies interest to address it.  

the  costs to  companies included 

is  evidence  of 

there 

that 

One  participant  raised  that  home-working  and  the increase of  domestic  violence has led  to 
debate among companies about a duty of care to ensure safe and secure working places.   

Concerning  access  to  justice,  including  collective  action,  one  participant  discussed  the 
important  of  collective  interventions  by trade unions as  it  is a  safer  and  cheaper  option. 
Another  participant  noted  that  collective  action can  have  a  role  in  protecting victims from 
exposure,  especially  in  high  profile  cases.  It  was  noted  that  in  individual  cases, access  to 
justice can  be  difficult,  cumbersome,  and  lengthy.  Another  participant  noted  that  the  shift 
of the burden of proof onto employers is very important in securing access to justice.   

It  was  noted  that  online  harassment  is  increasing,  also  in  work  contexts,  and  taking  new 
forms. Certain professions are more at risk, such as female journalists. It was considered 
that  more  action  is  needed  including  training  and  encouragement  to  report cyber  violence, 
user friendly tools to report and flag online content, a national media regulatory.  

1.4.4. Workshop with employer associations, 30 June 2021 

The  European  Commission  organised  a  targeted  workshop  meeting  with  four  employer 
associations  on  30 June  2021  with  the  same  agenda  as  for  the  social  partner’s  workshop 
described above.  

102 

 
 
 
 
Regarding  current  EU  legislation  and  policy,  social  partners  noted  that  the  social  partners’ 
framework  agreement  was  the  main  source  guiding  their  action  in  this  area  at  EU  level. 
Although adopted in 2007, it is still producing a range of actions231.  

ILO Convention no. 190 has a significant role for the work of employer associations. A focus 
of  the  discussion  was  on  domestic  violence.  Participants  felt  that  it  is  important  that 
employers are not  made responsible or have obligations related to  domestic violence as it is 
beyond their control. There are also issues of privacy that victims may not want discussed at 
work.  One  participant  drew  an  analogy  with  health  and  safety  whereby  employers  are  not 
responsible for health and safety issues when an employee has left the workplace. Participants 
felt  that  there  is  a  clear  separation  between  the  public/work  sphere  and  the  private  sphere. 
Another  employer  noted  that  there  are  challenges  implementing  existing  legislation  and 
adding  domestic  violence  might  make  it  more  complicated  and  would  lead  to  difficult 
negotiations.  

Participants  were  largely  resistant  to  more  obligations  relating  to  the  effects  of  violence 
against  women  and  domestic  violence  at  work.  One  noted  that  that  soft  measures,  such  as 
EIGE’s Handbook on Sexism, was a better route and more training.   

Regarding  current  activities,  one  participant  said  there  are  projects  ongoing  on  third  party 
violence, which will include gender dimension, including domestic violence and the impacts 
of  COVID-19.  They  are  looking  at  risk  assessments,  including  psychosocial  risk,  and 
developing  an  agreement  on  training  of  HR  managers  in  this  regard.    Another  participant 
noted there has been challenges implementing risk assessments because they include sensitive 
issues and employers need support and guidance to do it.   

One participant noted that understanding of the challenge and illegality sexual harassment is 
very well establish and understood but the challenge is practical implementation. 

Two participants noted that the issue of tackling sexual harassment varies considerably on the 
size of the company. In small companies, it can be hard to maintain confidentiality. Smaller 
companies may also not have a comprehensive HR structure or trainings in place.  

1.4.5. Targeted consultation workshop with the Member States, 1 July 2021 

The  objective  of  the  workshop  was  twofold:  (1)  to  provide  Member  States  with  the 
preliminary  results  from  the  evaluation  and  the  existing  criminal  law  provisions  applied  to 
violence  against  women  and  domestic  violence,  and  (2)  to  gather  Member  States’  views  on 
the options considered by the Commission for the legislative initiative. 

Dr. Lorena Sosa, Assistant Professor at Utrecht University, presented the main findings of the 
upcoming  thematic  report  on  ‘Criminalisation  of  gender-based  violence  against  women  in 
European States, including ICT-facilitated violence’ of the European network of legal experts 
in the field of gender equality, and explained how the Member States are addressing violence 
against women and domestic violence from a comparative legal  perspective. She elaborated 
on  the  persisting  gaps  in  coverage  and  protection  –  especially  when  assessed  against  the 
benchmarks in the Istanbul Convention – and the need for more action.  

Member States were invited to engage in discussion on the different policy options to address 
the identified gaps. Italy welcomed the comprehensive approach of the upcoming legislative 

231 Communication from the Commission to the Council and the European Parliament transmitting the European 
framework agreement on harassment and violence at work (COM(2007) 686 final)). 

103 

 
 
 
 
 
                                                 
proposal and emphasised the importance of taking into account the pending legal opinions on 
the  Istanbul  Convention  and  on  the  ILO  Violence  and  Harassment  Convention  no.  190. 
France  recalled  its  commitment  to  tackle  gender  based  violence  and  asked  about  the  legal 
bases of the directive. Slovakia referred to differing state practices concerning consent in the 
field of sexual violence.  Portugal underlined the relationship between the criminal nature of 
gender-based violence and discrimination, as well as emphasized that the proposal should take 
into  account  the  needs  of  children.  Latvia  had  questions  about  the  relationship  between  the 
legislative proposal and the proposal on hate speech and hate crime.  

1.4.6. Targeted consultation workshop with international organisations, 8 July 2021 

A  targeted  consultation  workshop  was  organised  by  the  European  Commission  to  gather 
international  organisations’  views  on  possible  minimum  standards  concerning  effective 
prevention,  protection,  support  and  access  to  justice  for  victims  of  all  forms  of  violence 
against  women  and  domestic  violence  in  the  EU,  and  gather  input  to  ensure  the 
complementarity of the upcoming proposal with the international obligations of the Member 
States.  

Concerning  prevention  of  violence  against  women  and  domestic  violence,  participants 
highlighted  the  need  for  early  intervention  and  prevention  programmes.  A  range  of 
measures  were  necessary  to  ensure  better  prevention  measures,  including  integrated  service 
delivery;  psychosocial  risk;  awareness-raising  measures  that  include  harassment,  stalking, 
online violence, FGM, forced marriage, etc. forms of violence against women and domestic 
violence,  which  are  not  currently  covered.  They  emphasized  the  need  for  large-scale 
awareness-raising campaigns that cover these forms of gender-based violence. Similarly, the 
need  to  combat  societal  prejudices,  assumptions  and  gender  stereotypes  was  also  noted. 
Prevention  initiatives  must  be  inclusive,  integrated  and  gender-sensitive,  meaning  that  all 
stakeholders  must  be  directly  involved  in  the  drafting,  monitoring  and  evaluation  of  the 
prevention programmes. Some participants noted the importance of engaging men and boys 
in  prevention  measures.  To  this  regard,  the  participants  discussed  the  importance  of 
providing  teaching  material  on  gender  issues  –  in  both  formal  curricula  and  informal 
education  –  as  well  as  providing  appropriate  training  for  relevant  professionals  (e.g. 
doctors, nurses, midwives, lawyers, judges, etc.). Training should be continuous and be based 
on  clear  guidelines,  as  well  as  mandatory.  Relevant  professionals  should  be  encouraged  to 
follow in-service trainings throughout their career.  

As  regards  protection  and  support  services,  participants  identified  a  lack  of  gendered 
understanding  of  violence,  which  can  lead  to  secondary  and  repeat  victimization, 
intimidation and retaliation. One-stop-shop approaches to seek assistance were highlighted as 
best practice. It was also noted there is a need to dissociate access to support services from 
the willingness to report or pursue the criminal process. There is a need to invest more in 
services  for  child witnesses. More  generally, protection and support services are negatively 
affected  by  inadequate  infrastructure,  long  waiting  periods,  insufficient  funding  or 
geographical  coverage,  and  lack  of  specialised  personnel.  Some  countries  are  overcoming 
access barriers by setting up specialist shelters for women who cannot access regular shelters, 
like women with substance abuse or mental disabilities. COVID has negatively impacted the 
services provided and the number of shelters in general is insufficient in the EU.  

Participants  suggested  specific  support  services  to  assist  victims  in  (re-)entering  the  labour 
market,  as  economic  empowerment  is  central  to  realising  gender  equality.  In  addition, 
victims should be ensured paid leave, dismissal protection and flexible working arrangements 
so as to allow them to make use of the available services. 

104 

 
 
 
 
 
In work settings, challenges with access to justice were noted. Clear reporting mechanisms 
and  anonymous  reporting  can  help.  External  complaint  mechanisms,  such  as  courts  with 
sufficient knowledge, are necessary. Legal advice should be available for free. Guidance and 
information  on  accessible  resources,  also  in  languages  different  from  the  main  one  in  the 
country.  One  participant  noted  that  the  shift  on  the  burden  of  proof  as  in  EU  anti-
discrimination legislation is beneficial.  Concerning access to compensation from the state or 
the  perpetrator,  shortcomings  have  been  identified  in  particular  regarding  too  short 
timeframes to claim compensation, limitations concerning claims for moral damages (only 
for  certain  types  of  crimes  but  not  all),  high  court  fees  or  excessively  high  thresholds  for 
proof.  

Gender-based  cyber  violence  was  considered  a  new  field  that  is  not  explicitly  covered  in 
current legislation at EU and international levels. One participant said that more regulation of 
the media and internet service providers is needed – in balance with the freedom of expression 
- and more reporting procedures both online and to the police.  

Participants  discussed  the  need  to  require  online  platforms  to  offer  reporting  procedures 
and ensure effective follow-up. Participants emphasized the need to balance the protection of 
women and children against cyber violence with the rights to freedom of expression and data 
protection.  Platforms  and  internet  intermediaries  should  receive  more  guidance  on  these 
aspects. 

To  improve  policy  coordination,  several  participants  noted  the  need  for  improve  data 
collection,  including  better  disaggregated  data  and  for  it  to  be  published.  It  was  noted  that 
there  are  not  enough  population  surveys  to  truly  understand  prevalence.  Participants  also 
mentioned  the  need  for  a  unified  (statistical)  definition  of  violence  against  women  and 
domestic  violence  to  ensure  smooth  and  consistent  data  collection.  This  data  should  be 
disaggregated, collected on a regular basis, and made available to the public. 

Participants highlighted the need for an intersectional approach, meaning that policies on 
gender-based violence and domestic violence should take account of the particular challenges 
that  certain  groups  (e.g.  minorities,  refugees,  rural  women,  members  of  the  LGBTQ+ 
community, etc.) face in regard to violence against women and domestic violence. 

 Events and expert group meetings 

1.5.1. Meetings  of  the  High-Level  Group  on  Gender  Equality,  25-26  January  2021 

and 8-9 September 2021 

During the meetings, the state of play concerning the preparation of the legislative initiative 
on  preventing  and  combatting  gender-based  violence  against  women  and  domestic  violence 
was presented. In January, the Member States were encouraged to take part in the upcoming 
targeted  consultation.  In  September  2021,  Member  States  were  further  informed  of  the 
progress  and  thanked  for  their  extensive  contributions  to  the  written  consultation,  and  for 
participation in the workshop. 

1.5.2. Mutual  learning  seminar  on  ‘Methodologies  and  good  practices  on  assessing 

the costs of violence against women’, 7-8 July 2021 

The European Commission organised a Mutual Learning Seminar on methodologies and good 
practices on assessing the costs of violence against women for the EU Member States under 

105 

 
 
 
 
its Mutual Learning Programme in Gender Equality.232 There were 16 participating Member 
States:  Finland  (host  country),  Belgium,  Croatia,  Czech  Republic,  Denmark,  Estonia, 
Germany,  Italy,  Malta,  the  Netherlands,  Poland,  Portugal,  Romania,  Slovakia,  Spain  and 
Sweden.  

Participants  welcomed  the  opportunity  for  exchange  and  dialogue.  While  noting  substantial 
data  gaps  and  limitations  in  some  country  contexts  they  considered  that  the  Finnish 
methodology  for  measuring  the  costs  of  such  violence,  presented  by  experts  from  the  host 
country, offered an important model that could either be replicated or else used as a reference.   

Most  countries  indicated  that  they  had  conducted  some  form  of  cost  analysis:  they 
referred to empirical studies or GDP-based cost estimates carried out as part of the 2014 EIGE 
study, local or regional studies, studies of the costs of a specific service and national studies 
using administrative data or surveys. However, some studies were conducted a few years ago 
and  need  to  be  updated  taking  into  account  new  methodologies.  Participants  also 
highlighted  the  fragmented  nature  of  administrative  data  and  the  difficulty  in  linking 
different registers such as health care and legal services or the lack of compatibility between 
police  and  justice  sectors.  Other  obstacles  faced  included  poorly  developed  national 
administrative  records,  or  difficulties  in  accessing  information  because  of  devolved 
government structures, or because external funding received by NGOs for shelters was hard to 
identify. Many participants noted that the visible costs were just the tip of the iceberg. There 
are many hidden and indirect costs, and many victims fail to identify as such, and thus, do 
not  seek  help.  Victims  must  often  pay  privately  for  various  health-related  services  and 
prescriptions, which are not included in cost calculations. Furthermore, many professionals do 
not record cases adequately. This demonstrates the difficulty and complexity of estimating the 
costs  of  violence,  as  there  is  no  one  gold  standard  methodology.  The  Member  State 
representatives highlighted the urgent need for better administrative data on costs and use 
of services and better survey data on prevalence. 

Participants  recommended  that  the  EU  together  with  EIGE  could  play  an  important  role  in 
developing: 

  a common legal definition of what  constitutes  violence against women and domestic 

violence; 

  a common methodology or operational framework for assessing costs; 
  cross–country collaborative studies with harmonised procedures; 
  guidelines  on  how  to  monitor  and  assess  the  impact  of  interventions  in  order  to 

 

advocate for greater resource allocation to prevention services; 
further networking opportunities to build upon existing expertise and to facilitate new 
ideas on research and policy.  

1.5.3. Workshop on online violence against women, 8 September 2020 

In September 2020, DG JUST in cooperation with DG CNECT organised an online workshop 
with a panel of six academics as well as representatives from the Commission to discuss the 
issue  of  violence  against  women  in  the  online  environment.  Academics  agreed  that  Digital 
Services  Act  could  be  an  opportunity  to  overcome  the  existing  fragmentation,  and  agree  on 
common  definition/standards.  An  opinion  resonated  among  the  academics  that  parts  of  the 
Digital  Services  Act  package  should  be  perceived  as  complementary  to  tackling  the  issue 
together  with  supplementing  sectoral  initiatives.  As  the  problem  is  structural,  the  solution 

232  Mutual  Learning  Programme  in  gender  equality,  summary  report.  https://ec.europa.eu/info/policies/justice-and-
fundamental-rights/gender-equality/who-we-work-gender-equality/mutual-learning-programme-gender-equality_en. 

106 

 
 
 
 
                                                 
should be based on complex market approach, so the users can switch to other platform that 
provides  for  different  moderation  may  it  be  their  wish.  Some  academics  further  concluded 
that  an  amplification  element  is  important  to  distinguish  harmful  content  and  illegality,  and 
that  the  horizontal  solutions  included  in  the  Digital  Services  Act  should  cover  all  users  in 
vulnerable situations, including women users, users with minority backgrounds and children. 
They also reported that the decision between the self- and co-regulatory approach on one side 
and “hard” regulation on the other should not be taken. At the same time, they acknowledged 
that here are clear positives and negatives of self- and co-regulatory approach, and its success 
depends  a  lot  on  the  Member  States’  as  well  on  platforms’  approach.  In  this  regard,  an 
agreement  was  reached  that  scope  for  existing  authorities  to  develop  their  role  concerning 
privacy  and  different  forms  of  cyber  violence  might  be  created  by  the  new  regulation.  The 
academics also summarised that there is a need to adapt obligations according to the layers of 
the internet, as well as to ensure redress and support to individuals when considering illegal 
acts according to the existing rules. 

107 

 
 
 
 
ANNEX 3: Who is affected and how? 

 Who is affected? 

The main target and beneficiaries of this initiative are victims of violence against women and 
domestic  violence,  i.e.  one  woman  out  of  3  according  to  the  FRA  2014  survey,  i.e.  overall 
around 75 millions of women. These acts of violence also affects witnesses, family members 
and  other  close  relations,  as  well  as  bystanders  and  perpetrators.  The  initiative  also  has 
implications  for  national  administrations,  including  those  in  charge  for  the  organisation  and 
effectiveness of the law enforcement, judicial, health and social services involved; employers 
and social partners as for the consequences for labour market participation and implementing 
and  managing  anti-harassment  procedures;  as  well  as  NGOs  and  practitioners  working  with 
victims, witnesses and perpetrators. 

 Summary of affected stakeholders 

Main problems  

For whom is this a problem? 

Affected stakeholders 

Forms of violence concerned 

High  prevalence  of  violence 
against women and domestic 
violence across the EU 

Individual stakeholders:  

  Victims of violence 
against women and 
domestic 
violence(women, 
children, men; the 
elderly, LGBTIQ) 

  Perpetrators of 

violence 
  Witnesses 
  Family members and 

other close relations of 
victims 

Other stakeholders: 

  Governments, regional 
and local authorities  

  National authorities, 

private support service 
providers and NGOs 

 

IT platforms 

108 

All forms of violence against 
domestic 
and 
women 
violence 

All forms of violence against 
women and domestic 
violence 

All forms of violence against 
women and domestic 
violence 

Cyber violence against 
women and in intimate 
partnerships 

Sex-based work harassment;  
indirect effects from violence 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  Social partners and 

employers, including 
companies of all sizes 

against women and domestic 
violence experienced outside 
of work 

Ineffective prevention 
measures 

Individuals at risk of / victims 
of violence against women 
and domestic violence 

All forms of violence against 
women and domestic 
violence 

General public 

Perpetrators and potential 
perpetrators 

IT platforms 

Media 

Governments, national, 
regional and local authorities 
(esp. education providers, 
social and health services) 

Equality bodies 

Social partners and 
employers, including 
companies 

Law enforcement 

Support 
service  providers 
(social  and  health  service 
providers, NGOs) 

109 

Cyber violence against 
women and in intimate 
partnerships, (platforms can 
be used to advocate for/incite 
to all forms of violence 
against women and domestic 
violence, but can also 
promote mutual respect, 
equality and non-
discrimination)  

All forms of violence against 
women and domestic 
violence 

All forms of violence against 
women 
domestic 
and 
violence 

All forms of violence against 
women 
domestic 
and 
violence 

Sex-based work harassment  

All forms of violence against 
women 
domestic 
and 
violence 

Ineffective protection 
measures 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
violence 
Cyber 
women 
in 
and 
partnerships, 
on-platform 
measures) 

against 
intimate 
(provision  of 
protection 

Sex-based work harassment 
(provision of company-
internal protection) 

All forms of violence against 
domestic 
and 
women 
violence 

All forms of violence against 
domestic 
and 
women 
violence 

All forms of violence against 
women 
domestic 
and 
violence 

Judicial authorities  

IT platforms 

Social partners and 
employers, including 
companies 

Ineffective access to justice 

Victims 

Witnesses  

Law enforcement 

Judicial authorities 

Equality bodies 

Ineffective support measures  Victims 

Ineffective coordination 

Witnesses, incl. children 

Support 
service  providers 
(social  and  health  service 
providers, NGOs) 

Law enforcement 

Judicial authorities 

Family  members  and  other 
close relations of victims 

International 
CoE) 

actors 

(UN, 

EU-level coordination 

National authorities 

Local and regional authorities 

Equality bodies 

110 

 
 
 
 
 
 
 
 
 
 
 
 
 
 Summary of costs and benefits 

The tables below present the costs and benefits associated with the preferred Policy Option, 
Policy Option 2A ("comprehensive policy option"). Benefits are mainly in the form of direct 
costs savings across MS national authorities and individual victims. On the other hand, costs 
were mainly identified for national authorities and include one-off and recurring costs. 

I. Overview of benefits (total for all provisions) of the preferred option 

Description 
Direct benefits 
Reduction in costs of 
violence against 
women and domestic 
violence 
(Lost economic 
output) 

Amount 

Comments 

Cost reductions are estimated to 
be EUR 8.1 billion in the shorter-
term i.e. 5 years after 
implementation and EUR 12.2 
billion in the longer-term i.e. 10 
years after implementation.  

These reductions in costs would 
accrue to individual victims of 
violence against women and 
domestic violence as a result of a 
reduction in lost earnings and 
productivity due to lower prevalence 
of GBV. 

Reduction in costs of 
violence against 
women and domestic 
violence 
(Health services) 

Cost reductions are estimated to 
be EUR 2.5 billion in the shorter-
term i.e. 5 years after 
implementation and EUR 3.8 
billion in the longer-term i.e. 10 
years after implementation.  

These reduction in costs would accrue 
to national authorities as a result of 
a reduction in healthcare costs due to 
lower prevalence of violence against 
women and domestic violence and 
hence, cases that require 
services/treatment. 

Reduction in costs of 
violence against 
women and domestic 
violence 
(Criminal justice 
system) 

Cost reductions are estimated to 
be EUR 7.2 billion  in the shorter-
term i.e. 5 years after 
implementation and EUR 13.7 
billion in the longer-term i.e. 10 
years after implementation.  

These reductions in costs would 
accrue to national authorities as a 
result of a reduction in criminal 
justice system costs due to lower 
prevalence of violence against women 
and domestic violence. 

Reduction in costs of 
violence against 
women and domestic 
violence 
(Civil justice system) 

Cost reductions are estimated to 
be EUR 0.2 billion in the shorter-
term i.e. 5 years after 
implementation and EUR 0.4 
billion in the longer-term i.e. 10 
years after implementation.  

These reductions in costs would 
accrue to national authorities as a 
result of a reduction in civil justice 
system costs due to lower prevalence 
of violence against women and 
domestic violence. 

Reduction in costs of 
violence against 
women and domestic 
violence 
(Social welfare) 

Cost reductions are estimated to 
be EUR 2.1 billion in the shorter-
term i.e. 5 years after 
implementation and EUR 3.1 
billion in the longer-term i.e. 10 
years after implementation.  

These reductions in costs would 
accrue to national authorities as a 
result of a reduction in social welfare 
costs due to lower prevalence of 
violence against women and domestic 
violence 

111 

 
 
 
 
 
 
 
 
 
 
 
 
Reduction in costs of 
Gender-based violence 
(Personal costs) 

Cost reductions are estimated to 
be EUR 0.6 billion in the shorter-
term i.e. 5 years after 
implementation and EUR 1.0 
billion in the longer-term i.e. 10 
years after implementation.  

These reductions in costs would 
accrue to individual victims of 
violence against women and 
domestic violence as a result of a 
reduction in personal costs  due to 
lower prevalence of violence against 
women and domestic violence. 

Reduction in costs of 
Gender-based violence 
(Physical/emotional 
impacts) 

Cost reductions are estimated to 
be EUR 32.2 billion in the 
shorter-term i.e. 5 years after 
implementation and EUR 48.4 
billion in the longer-term i.e. 10 
years after implementation.  

These reductions in costs would 
accrue to individual victims of 
violence against women and 
domestic violence as a result of a 
reduction in physical and emotional 
harms of crime due to lower 
prevalence of violence against women 
and domestic violence. 

Indirect benefits 
None quantified 

112 

 
 
 
 
 
 
 
 
 
 
 
 
II. Overview of direct costs of the preferred option  

Measure 

Recurring 

One-off 

1.1 Awareness-raising, provision of 
information and training of professionals 

1.2 OVAW - Self-regulatory standards 

1.4 Work with perpetrators 

2.1 Protection orders, emergency barring 
orders 

2.2 Violence reporting and transmission 
of personal data between services 

2.3 Special measures for the protection 
of children in the context of domestic 
violence 

Minimum 

Maximum 

€29,862,000 

€34,403,000 

€1,816,000 

negligible 

€134,000 

negligible 

€134,000 

€3,696,000 

€25,175,000 

negligible 

0 

0 

negligible 

negligible 

negligible 

€718,971,000 

€1,942,604,000 

2.4 Risk assessment and management 

€46,855,000 

€46,855,000 

3.1 Criminalisation  

n/a 

n/a 

3.2 Measures against illegal gender-
based content online 

3.3 National coordination 

4.1 Specialised support 

€326,459,000 

€326,459,000 

€2,027,000 

€2,027,000 

€117,643,000 

€117,643,000 

4.2 Support to victims of OVAW 

€1,159,566,000 

€1,159,566,000 

4.3 Support to victims of gender-based 
work harassment 

€627,091,000 

€ 627,091,000 

0 

0 

n/a 

0 

0 

0 

0 

0 

4.4 Shelters 

4.5 Helplines 

4.7 Coordination of measures against 
gender-based work harassment 

€20,486,000 

€379,746,000 

€12,630,000 

€461,000 

€4,656,000 

€ 946,000 

n/a 

n/a 

n/a 

5.1 Monitoring, incl. data collection   

€20,769,000 

€20,769,000 

€152,000 

5.2 One-stop-shop information access  

€357,000 

€357,000 

n/a 

(Cost for employers) 
1.3 Specific prevention measures against 
gender-based work harassment  

€1,893,919,000 

€1,893,919,000 

€605,000 

Total costs for preferred policy option 

€4,968,296,000 

€6,581,404,000 

€16,149,000 

113 

 
 
 
 
  
 
 
 
 
 Sensitivity Analysis 

The table below summaries the variation in  the comparison  of the scores of the different 
policy options when assigning different weights to the three criteria of effectiveness (which 
includes proportionality), efficiency and coherence.   

Option 1 is always dominated by each suboptions of Option 2. Suboption 2A maintains its 
advantage in all the different weighting scenarios. 

Sensitivity analysis 

Effectiveness: 40%; Efficiency: 40%; Coherence: 20%  
Effectiveness: 50%; Efficiency: 30%; Coherence: 20% 
Effectiveness: 50%; Efficiency: 40%; Coherence: 10% 
Effectiveness: 40%; Efficiency: 50%; Coherence: 10% 

1.80 
1.80 
1.78 
1.78 

2.60 
2.58 
2.60 
2.63 

2.05 
2.01 
1.98 
2.01 

Unweighted score 

1.83 

2.58 

2.13 

114 

 
 
 
 
 
 
 
ANNEX 4: Analytical methods 
For  the  assessment  of  the  policy  options  and  policy  measures,  the  following  main  baseline 
assumption has been made: 

1)  No actions are taking place at the moment, where there is no robust evidence of them233; 
2)  For the purposes of administrative costing, it is assumed that the costs incurred due to the policy 
option are additional to the baseline. 

 Analytical methods applied to estimate costs and cost reductions (economic benefits) 

The overall approach to the estimation of costs and cost reductions (economic benefits) consisted of 
the following key steps: 

1.  Firstly, the cost items associated with each policy measure were assessed, considering the type 
of cost (i.e. one-off or recurring), and the already existing measures in the Member States. 

2.  For each cost item, estimates for the value of the cost were developed. Further details on how 
each  type  of  cost  item  was  estimated  are  set  out  below.  Overall,  estimates  and  assumptions  were 
based on a combination of factors, including publicly available data (see each measure for details on 
sources) and the study team members’ experience of conducting similar quantification exercises.  

3.  The  administrative  and  compliance  costs  for  each  cost  item  and  policy  measure  were  then 
aggregated across Member States. This enabled aggregate costs across all relevant Member States to 
account  for  differences  in  costs  across  Member  States  (e.g.  salaries  of  relevant  professionals, 
prevalence rates, reporting rates etc.). In addition, to estimate aggregate costs for the implementation 
of  each  policy  measure  across  Member  States,  where  relevant  and  possible,  the  specific  costs  per 
Member  State  were  estimated,  considering  evidence  on  whether  policy  measures  were  currently 
being implemented or partially implemented. 

4.  For cost reductions (economic benefits), estimations were based on figures on the overall cost of 
violence  against  women  and  domestic  violence234  (i.e.  the  overall  potential  for  cost  reduction  of 
violence  against  women  and  domestic  violence  associated  with  all  policy  measures  under  each 
policy option). This is because there is a lack of evidence and available data on the potential for cost 
reduction thought to be associated with each policy measure. On the basis of a review of studies on 
the economic impact of policy measures on combatting and preventing violence against women and 
domestic violence, economic benefits of the policy options were considered to be generated due to a 
decrease in the prevalence of violence against women and domestic violence. Moreover, due to lack 
of evidence quantifying the causal link between prevalence and the full set of measures under each 
policy option, two hypothetical scenarios were assumed. 

233 Evidence for current actions was available for the following measures: 1.4 Work with perpetrators; 2.1 Protection orders; 
emergency barring orders; 2.3 Special measures for the protection of children in the context of domestic violence; 2.4 Risk 
assessment and management; 3.4 Victim compensation; 3.6 National coordination; 4.2 Specialised support; 4.5 Shelters; 4.6 
Helplines. 
234 EIGE, The costs of gender-based violence in the European Union (2021). 

115 

 
 
 
 
 
 
 
                                                 
  Estimation of compliance costs 

1.2.1. Estimation of costs of prevention 

a. Awareness-raising, provision of information and training of professionals 

The estimation of this measure is based on the cost of:  

1)  general and targeted awareness raising campaign 

2)  online training on violence against women and domestic violence violence against women and 

domestic violence to professionals dealing with victims or perpetrators & professionals working 
with victims of violence against women and domestic violence 

3)  equipment of law enforcement and judicial authorities with specialized resources/training to 

prosecute OVAW 

For awareness raising, the following calculations are used, for each Member State: 

𝑪𝒐𝒔𝒕  = 𝑡𝑤𝑖𝑐𝑒 𝑦𝑒𝑎𝑟𝑙𝑦235 × (𝑏𝑢𝑑𝑔𝑒𝑡 𝑓𝑜𝑟 𝑔𝑒𝑛𝑒𝑟𝑎𝑙 𝑎𝑤𝑎𝑟𝑒𝑛𝑒𝑠𝑠 𝑟𝑎𝑖𝑠𝑖𝑛𝑔236

+ 𝑏𝑢𝑑𝑔𝑒𝑡 𝑓𝑜𝑟 𝑡𝑎𝑟𝑔𝑒𝑡𝑒𝑑 𝑎𝑤𝑎𝑟𝑒𝑛𝑒𝑠𝑠 𝑟𝑎𝑖𝑠𝑖𝑛𝑔 𝑐𝑎𝑚𝑝𝑎𝑖𝑔𝑛237)  

For training on violence against women and domestic violence, the following approach is used, for 
each Member State: 

𝑪𝒐𝒔𝒕  = 𝑡𝑤𝑜 ℎ𝑜𝑢𝑟𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟238

× (𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑝𝑜𝑙𝑖𝑐𝑒 𝑜𝑓𝑓𝑖𝑐𝑒𝑟𝑠239 × %𝑎𝑡𝑡𝑒𝑛𝑑240 
× 𝑝𝑜𝑙𝑖𝑐𝑒 𝑜𝑓𝑓𝑖𝑐𝑒𝑟 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟241 +  𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑝𝑟𝑜𝑠𝑒𝑐𝑢𝑡𝑜𝑟𝑠242  ×  %𝑎𝑡𝑡𝑒𝑛𝑑243 
× 𝑝𝑟𝑜𝑠𝑒𝑐𝑢𝑡𝑜𝑟′𝑠 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟244 + 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑙𝑎𝑤𝑦𝑒𝑟𝑠245 × %𝑎𝑡𝑡𝑒𝑛𝑑246 
× 𝑙𝑎𝑤𝑦𝑒𝑟𝑠′𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟247 + 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑗𝑢𝑑𝑔𝑒𝑠248  × %𝑎𝑡𝑡𝑒𝑛𝑑249 
× 𝑗𝑢𝑑𝑔𝑒′𝑠 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟250) + 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑑𝑒𝑣𝑒𝑙𝑜𝑝𝑖𝑛𝑔 𝑡𝑤𝑜 𝑡𝑟𝑎𝑖𝑛𝑖𝑛𝑔 𝑠𝑒𝑠𝑠𝑖𝑜𝑛𝑠251 

235 Assumes every country needs to implement at least 2  awareness raising campaigns in a year 
236 Examples from Belgium, Estonia, Italy and Poland used to provide estimates for the minimum and maximum budget 
needed for one campaign 
237 Grevio reports EE (2021) Targeted Campaign:  Campaign to encourage victims to reach out for help with the title “Hero 
of our time”. Budget: 10 000 euros. 
238 Attending a 2-hour course in a year. 
239 Eurostat data (2016) - https://ec.europa.eu/eurostat/databrowser/view/crim_just_job/default/table?lang=en; No data for 
IE: average across all countries used (57528) 
240 Assuming 15% attend training on dealing with victims or perpetrators and an additional 5% attend training on GBV/DV 
victims specifically. 
241 Eurostat, [earn_ses18_13] (Public administration and defence salary > 10 employees or more). No data for AT, BE, EL, 
PT: average across all countries used (€16.4) 
242 CEPEJ studies no.26 - 2018 (2016 data).  
243 See footnote 8. 
244 CEPEJ studies no.26- 2018 (2016 data):  
245 CEPEJ studies no.26 - 2018 (2016 data) 
246 See footnote 8. 
247 assume same as prosecutors’ salary 
248 CEPEJ studies no.26 - 2018 (2016 data) 
249 See footnote 8. 
250 CEPEJ studies no.26 - 2018 (2016 data). No data for CZ: average across all countries used (€35.2) 

116 

 
 
                                                 
For training on OVAW, the following approach is used, for each Member State: 

𝑪𝒐𝒔𝒕  = 𝑡𝑤𝑜 ℎ𝑜𝑢𝑟𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟252 × (

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑝𝑒𝑟 𝑜𝑓𝑓𝑖𝑐𝑖𝑎𝑙253 ×

𝑝𝑜𝑙𝑖𝑐𝑒 𝑜𝑓𝑓𝑖𝑐𝑒𝑟 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟254 +  𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑝𝑟𝑜𝑠𝑒𝑐𝑢𝑡𝑜𝑟𝑠 𝑟𝑒𝑞𝑢𝑖𝑟𝑒𝑑255  ×
 𝑝𝑟𝑜𝑠𝑒𝑐𝑢𝑡𝑜𝑟′𝑠 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟256 + 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑗𝑢𝑑𝑔𝑒𝑠 𝑟𝑒𝑞𝑢𝑖𝑟𝑒𝑑257  ×
𝑗𝑢𝑑𝑔𝑒′𝑠 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟258) + 𝑓𝑖𝑥𝑒𝑑 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑑𝑒𝑣𝑒𝑙𝑜𝑝𝑖𝑛𝑔 𝑎 𝑡𝑟𝑎𝑖𝑛𝑖𝑛𝑔 𝑠𝑒𝑠𝑠𝑖𝑜𝑛259  

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64260
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑤𝑖𝑡ℎ 𝑝𝑒𝑟𝑠𝑜𝑛𝑎𝑙 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑤𝑖𝑡ℎ 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒261 
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑠𝑢𝑐ℎ 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑡𝑜 𝑎𝑛 𝑜𝑛𝑙𝑖𝑛𝑒 𝑝𝑙𝑎𝑡𝑓𝑜𝑟𝑚262 

  Assumptions used: 

- 

the assessment of the baseline finds that all Member States have some form of awareness-
raising in place. Therefore, we assume an additional 2 general campaigns and 2 additional 
targeted campaigns are needed per year needed to ensure regular campaigns 

- 

selected officials attend a 2-hour training sessions 

- 

- 

the assessment of the baseline did not find information hours of trainings provided or the 
presence of tailored training on violence against women and domestic violenceor 
OVAW, therefore assume all Member States incur additional costs 

the cost for the provision of information to victims of violence against women and 
domestic violencewill be fulfilled through awareness-raising campaigns and training of 
professionals 

251 Assuming one 2-hour training is needed for all relevant professionals and one 2-hour tailored training is needed for 
professionals working with GBV/DV victims. Estimated cost of developing an online training session obtained from: 
European Commission (2019) Skills for Industry Strategy: Promoting Online Training Opportunities for the Workforce in 
Europe based on findings from https://raccoongang.com/blog/how-much-does-it-cost-create-online-course/  
252 attending a 2-hour course in a year 
253 1350 cases is used - Internet Watch Foundation (2020), 299,619 reports assessed by 330 employees. We assume that 2/3 
(220 employees) work on the reports, as the IF also carries out other secondary functions. Available at: 
https://annualreport2020.iwf.org.uk/trends  
254 Eurostat, [earn_ses18_13] (Public administration and defence salary > 10 employees or more) 
255 CEPEJ studies no.26 - 2018 (2016 data). Assuming 15% attend. 
256  CEPEJ studies no.26- 2018 (2016 data): Annual salary to hourly wage is converted using the following: ($50000 per 
year / 52 weeks) / 40 hours per week = $24.04 per hour. No data for CZ: average across all countries used (35.21 
257 see number of prosecutors required above. 
258 see prosecutor’s salary above 
259 Estimate of the cost of developing an online training session obtained from: European Commission (2019) Skills for 
Industry Strategy: Promoting Online Training Opportunities for the Workforce in Europe based on findings from 
https://raccoongang.com/blog/how-much-does-it-cost-create-online-course/  
260 Eurostat Population on 1st January 2020, [demo_pjanbroad]  
261 38% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 
262 25% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 

117 

 
 
                                                                                                                                                                        
b. Gender-based cyber violence - self-regulatory standards 

The total investment required is assumed to be negligible as large online platforms provide codes of 
conduct that are stricter in nature in identifying illegal content online to be removed than national 
law263. 

c. Specific prevention measures against gender-based work harassment 

The  estimation  of  this  measure  is  based  on  the  cost  to  train  managers  on  sexual  harassment  in  the 
workplace. This cost falls mostly on employers. 

The following calculation is used, for each Member State: 

𝑪𝒐𝒔𝒕  =  𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑚𝑎𝑛𝑎𝑔𝑒𝑟𝑠 (𝑝𝑒𝑟 𝑙𝑎𝑟𝑔𝑒 𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑟 𝑎𝑛𝑑 𝑆𝑀𝐸)

× ( ℎ𝑜𝑢𝑟𝑙𝑦 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑓𝑜𝑟 𝑚𝑎𝑛𝑎𝑔𝑒𝑟𝑠264  × 2 ℎ𝑜𝑢𝑟𝑠 𝑎𝑡𝑡𝑒𝑛𝑑𝑒𝑑 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟)  
× (𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑆𝑀𝐸𝑠 𝑎𝑛𝑑 𝑙𝑎𝑟𝑔𝑒 𝑒𝑛𝑡𝑒𝑟𝑝𝑟𝑖𝑠𝑒𝑠265)
+ 𝐶𝑜𝑠𝑡 𝑜𝑓 𝑑𝑒𝑣𝑒𝑙𝑜𝑝𝑖𝑛𝑔 𝑜𝑛𝑒 𝑜𝑛𝑙𝑖𝑛𝑒 𝑡𝑟𝑎𝑖𝑛𝑖𝑛𝑔 𝑠𝑒𝑠𝑠𝑖𝑜𝑛266 

  Assumptions used: 

-  all managers attend a 2-hour training session  

-  one manager per 10 employees 

-  costs of awareness-raising and information provision on sexual harassment in the workplace at 
governmental, social partners’ and company levels would already be covered by 1.1b and 1.1c 

- 

- 

the cost of development of policies on anti-harassment and risk assessments at governmental, 
social partners’ and/or employer level is already included under existing EU health and safety 
legislation 

there is no comparable training for managers in the baseline and therefore all Member States 
incur full costs 

d. Work with perpetrators 

The estimation of this measure is based on the cost providing a series of sessions (online or face-to-
face) to all perpetrators (2B), only to repeated offenders (2A) or voluntary (assumed 5% of 
perpetrators). 

The following approach is used, for each Member State: 

263 See: https://www.europarl.europa.eu/RegData/etudes/STUD/2020/652718/IPOL_STU(2020)652718_EN.pdf  
264 Eurostat, [earn_ses18_14] 
265 Eurostat, Structural Business Statistics (2018) [SBS_SC_SCA_R2] 
266 Estimate of the cost of developing a training session obtained from: European Commission (2019) Skills for Industry 
Strategy: Promoting Online Training Opportunities for the Workforce in Europe based on findings from 
https://raccoongang.com/blog/how-much-does-it-cost-create-online-course/  

118 

 
 
                                                 
𝑪𝒐𝒔𝒕  =  𝑅𝑒𝑙𝑒𝑣𝑎𝑛𝑡 𝑠ℎ𝑎𝑟𝑒 𝑜𝑓 𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑝𝑒𝑟𝑝𝑒𝑡𝑟𝑎𝑡𝑜𝑟𝑠267 

×   ( ℎ𝑜𝑢𝑟𝑙𝑦 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑓𝑜𝑟 ℎ𝑒𝑎𝑙𝑡ℎ 𝑎𝑛𝑑 𝑠𝑜𝑐𝑖𝑎𝑙 𝑤𝑜𝑟𝑘𝑒𝑟268 
× 6 𝑠𝑒𝑠𝑠𝑖𝑜𝑛𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟) 

It is important to note that costs were not calculated for five Member States (BE, CY, EL, IE, IT) with 
missing data on total number of convicted persons and therefore, costs might be higher than estimated. 

 Assumptions used: 

-  6 one-on-one sessions of 1 hour of health and social worker support provided per perpetrator 

with no set-up costs 

- 

the compensation of social and health workers equals the European average for Member States 
with missing data 

-  no Member State currently provides sufficient perpetrator intervention and treatment 

programme, but the costs would be lower for countries that have a programme in place. The 
total cost is discounted by 50% for Member States that have a perpetrator programme in place in 
the baseline269 

- 

for Member States (LT, MT) with no information on baseline, it is assumed that no programmes 
are in place and therefore full costs would be incurred. 

1.2.2. Estimation of costs of protection 

a. Protection orders, emergency barring orders 

The estimation of this measure is based on the cost of adopting minimum standards in relation to the 
issuance and conditions of national emergency barring orders and ensuring effective enforcement of the 
order. 

The following approach is used, for each Member State: 

𝑪𝒐𝒔𝒕  = (𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑠𝑒𝑥𝑢𝑎𝑙/𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒  ×   𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒270)  

× (𝑐𝑜𝑠𝑡 𝑜𝑓 𝑎 𝑃𝑂 𝑡𝑜 𝑝𝑜𝑙𝑖𝑐𝑒 𝑎𝑛𝑑 𝑗𝑢𝑠𝑡𝑖𝑐𝑒 𝑠𝑒𝑐𝑡𝑜𝑟271) × 1.1 

267 Number of convicted persons for sexual assault or rape from: Joint Eurostat and UNODC data; Eurostat’s online code 
crim_hom_soff  
268 Eurostat, [earn_ses18_13] 
269 Based on the study's mapping of baseline situation  
270 Application rate is estimated from UK crime statistics Appendix tables on number of victims of domestic abuse divided 
by number of domestic violence protection orders. Available at: 
https://www.ons.gov.uk/file?uri=%2fpeoplepopulationandcommunity%2fcrimeandjustice%2fdatasets%2fdomesticabuseine
nglandandwalesappendixtables%2fyearendingmarch2018/da2018appendixtablesfinalv8.xlsx  
271 Unit cost of a protection order to the police and justice sector estimated to be €1,185 and €213 in UK prices, adjusted for 
each Member State's price level using PPP GDP/capita. Estimates based on Evaluation of the Pilot of Domestic Violence 
Protection Orders in England (2013): 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/260897/horr76.pdf  

119 

 
                                                 
𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑠𝑒𝑥𝑢𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64272
× 𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑎𝑔𝑎𝑖𝑛𝑠𝑡 𝑎 𝑤𝑜𝑚𝑎𝑛273 
×   𝑟𝑎𝑡𝑒 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑡ℎ𝑎𝑡 𝑤𝑎𝑠 𝑜𝑓 𝑠𝑒𝑥𝑢𝑎𝑙 𝑛𝑎𝑡𝑢𝑟𝑒274  

𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒

= (𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64275
× 𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑎𝑔𝑎𝑖𝑛𝑠𝑡 𝑎 𝑤𝑜𝑚𝑎𝑛276)
−   𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑠𝑒𝑥𝑢𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒  

Note that costs were not estimated for two Member States (IT, MT) with missing data on prevalence 
and therefore the total costs might be higher than estimated. 

 Assumptions used: 

-  due to lack of comparable data on the number of women victims of violence against women and 
domestic violence by Member State, a minimum and maximum estimate of women victims of 
violence against women and domestic violence is used based on FRA 2014 survey results  

- 

for  the  minimum  cost  estimate,  only  physical  violence  of  a  sexual  nature  against  women  is 
considered and for the maximum cost estimate, all types of physical violence against women are 
considered 

-  application rate is constant across Member States  

- 

relative unit costs of a protection order is constant across Member States and there are no set-up 
costs 

-  no  Member  State  issues  a  sufficient  number  of  protection  orders  on  violence  against 
women and domestic violence but costs would be lower for Member States that already 
have the possibility to apply for protection orders. Therefore, the total cost is discounted 
by  50%  for  Member  States  where  emergency  protection  orders  are  available  in  the 
baseline,  and  by  25%  for  Member  States  where  they  are  partially  available  in  the 
baseline277  

-  each  Member  State  incurs  an  additional  10%  of  total  costs  to  increase  efficiency  and  ensure 

timely issuance and more effective enforcement. 

b. Violence reporting and transmission of personal data between services 

The total investment required is assumed to be negligible as costs to encourage reporting of  violence 
against  women  and  domestic  violence  would  be  covered  in  training  of  relevant  professionals  and 
awareness-raising campaigns.  

272 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
273 Based on FRA 2020 survey results: https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  
274 Based on FRA 2020 survey results: https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  
275 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
276 Based on FRA 2020 survey results: https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  
277 Based on study's mapping of baseline situation  

120 

 
                                                 
c. Special measures for the protection of children in the context of domestic violence 

The estimation of this measure is based on the cost of providing support services to child witnesses of 
domestic violence and maintaining contact with the child in a surveyed safe place outside the alleged 
perpetrator’s home.  

The following approach is used, for each Member State: 

𝑪𝒐𝒔𝒕  = 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐ℎ𝑖𝑑 𝑤𝑖𝑡𝑛𝑒𝑠𝑠𝑒𝑠  ×   29 ℎ𝑜𝑢𝑟𝑠 

× ℎ𝑜𝑢𝑟𝑙𝑦 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 ℎ𝑒𝑎𝑙𝑡ℎ 𝑎𝑛𝑑 𝑠𝑜𝑐𝑖𝑎𝑙 𝑤𝑜𝑟𝑘𝑒𝑟𝑠278 

𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐ℎ𝑖𝑙𝑑 𝑤𝑖𝑡𝑛𝑒𝑠𝑠𝑒𝑠

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑢𝑛𝑑𝑒𝑟 15 𝑦𝑒𝑎𝑟𝑠279 ×  𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒 𝑜𝑓 𝑐ℎ𝑖𝑙𝑑 𝑚𝑎𝑙𝑡𝑟𝑒𝑎𝑡𝑚𝑒𝑛𝑡280
×   𝑟𝑎𝑡𝑒 𝑜𝑓 𝑐𝑜 𝑜𝑐𝑐𝑢𝑟𝑟𝑒𝑛𝑐𝑒 𝑜𝑓 𝑐ℎ𝑖𝑙𝑑 𝑎𝑏𝑢𝑠𝑒 𝑎𝑛𝑑 𝑑𝑜𝑚𝑒𝑠𝑡𝑖𝑐 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒281  

 Assumptions used: 

-  based  on  2-hours  of  health  and  social  worker  support  per  child/  week  for  3  months,  and  an 
additional hour per month for three months to maintain contact. The total is 29 hours per case282 

- 

rate of co-occurrence of child abuse and domestic violence is constant across Member States 

-  no set-up costs 

-  no  Member  State  provides  sufficient  levels  of  support  to  child  witnesses,  but  costs  would  be 
lower for Member States that have support services in place to account for the special needs of 
child  witnesses  of  domestic  violence.  Therefore,  the  cost  of  support  for  Member  States  is 
discounted by 50% for Member States where such services are available in the baseline, and by 
25% for Member States where such services are partially available283. For Member States (FR, 
HU, LI, MT) with no information available on the baseline, partially availability is assumed. 

-  no Member State provides services for maintaining contact  with child witnesses and therefore 

all Member States incur full costs to provide this service. 

d. Risk assessment and management 

The  estimation  of  this  measure  is  based  on  the  cost  for  law  enforcement  authorities  to  conduct 
individual  risk  assessments  and  risk  management  in  a  timely  manner  in  cooperation  with  support 
services.  

The following approach is used, for each Member State: 

278 Eurostat, [earn_ses18_13] 
279 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
280Country profiles, European Status report on preventing child maltreatment (2018): 
https://www.euro.who.int/__data/assets/pdf_file/0017/381140/wh12-ecm-rep-eng.pdf Note: The prevalence rates vary 
considerably by country and may reflect reporting rates rather than actual rates. Therefore, a potential range of child 
maltreatment prevalence is used instead with Min value of 10.4% and Max value of 28.1%  
281 Most reliable estimate of child abuse and domestic violence co-occurrence is 40%, as estimated by Walby (2004) and 
used in EIGE (2021). 
282 2 hours per week x 4.345 weeks per month x 3 months) + (1 session a month x 3 months) = 29 hours per case 
283 Based on study's mapping of baseline situation  

121 

 
 
 
                                                 
𝑪𝒐𝒔𝒕  = 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑡ℎ𝑒 𝑐𝑟𝑖𝑚𝑒

× ℎ𝑜𝑢𝑟𝑙𝑦 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑝𝑜𝑙𝑖𝑐𝑦 𝑜𝑓𝑓𝑖𝑐𝑒𝑟284  × (𝑜𝑛𝑒 ℎ𝑜𝑢𝑟 𝑓𝑜𝑟 𝑠𝑐𝑟𝑒𝑒𝑛𝑖𝑛𝑔 + 25% 
× (𝑡𝑤𝑜 ℎ𝑜𝑢𝑟𝑠 𝑓𝑜𝑟 𝑖𝑛 𝑑𝑒𝑝𝑡ℎ 𝑎𝑠𝑠𝑒𝑠𝑠𝑚𝑒𝑛𝑡
+ ℎ𝑎𝑙𝑓 𝑎𝑛 ℎ𝑜𝑢𝑟 𝑡𝑜 𝑐𝑜𝑜𝑝𝑒𝑟𝑎𝑡𝑒 𝑤𝑖𝑡ℎ 𝑠𝑢𝑝𝑝𝑜𝑟𝑡 𝑠𝑒𝑟𝑣𝑖𝑐𝑒𝑠)) 

 𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑡ℎ𝑒 𝑐𝑟𝑖𝑚𝑒

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64285
× 𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑎𝑔𝑎𝑖𝑛𝑠𝑡 𝑎 𝑤𝑜𝑚𝑎𝑛286 
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡 𝑡ℎ𝑒 𝑐𝑟𝑖𝑚𝑒 𝑡𝑜 𝑡ℎ𝑒 𝑝𝑜𝑙𝑖𝑐𝑒287  

Note that costs where not estimated for two Member States (IT, MT) with missing data on prevalence 
and therefore the total costs might be higher than estimated. 

 Assumptions used: 

-  due to lack of comparable data on the number of women victims of violence against women and 
domestic violence by Member State, the estimate of victims eligible for risk assessment is based 
on the broader category of all women victims of physical violence 

-  screening  requires  one  hour,    in-depth  assessment  requires  two-hours  and  cooperation  with 

victim support services required half an hour  

-  25% of women victims qualify  as high risk i.e.  for in-depth  assessment  and referral  to  victim 

support services 

-  no set-up costs 

-  no Member State provides sufficient levels of individual risk assessment, but the cost is lower 
for Member States that carry out such assessments. Therefore, the total cost for Member States 
is  discounted  by  50%  for  Member  States  that  carry  out  individual  risk  assessments  in  the 
baseline,  and  by  25%  for  Member  States  that  partially  carry  out  such  assessments  in  the 
baseline288. 

1.2.3. Estimation of costs of access to justice 

a. Criminalisation  

The total investment required is assumed  to be negligible as there are likely to be low administrative 
costs  to  change  national  and  EU  legislation  and  several  Member  States  already  have  laws  in  place 
criminalising various forms of violence against women and domestic violence. 

b. Measures against gender-based cyber violence 

The  estimation  of  this  measure  is  based  on  the  cost  for  Member  States  to  allow  online/other  low-
threshold reporting of incidents of OVAW to national law enforcement or other authorities.  

284 Eurostat, [earn_ses18_13] (Public administration and defence salary > 10 employees or more) 
285 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
286 Based on FRA 2020 survey results: https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  
287 Ibid. 
288 Based on study's mapping of baseline situation  

122 

 
 
 
                                                 
The following calculation is used, for each Member State: 

𝑪𝒐𝒔𝒕  =

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑢𝑛𝑑𝑒𝑟 𝑎 𝑙𝑜𝑤 𝑡ℎ𝑟𝑒𝑠ℎ𝑜𝑙𝑑

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑝𝑒𝑟 𝑜𝑓𝑓𝑖𝑐𝑖𝑎𝑙289

× 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑓𝑜𝑟 𝑝𝑜𝑙𝑖𝑐𝑒 𝑜𝑓𝑓𝑖𝑐𝑒𝑟𝑠 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟290 
× 2080 ℎ𝑜𝑢𝑟𝑠 𝑖𝑛 𝑎 𝑤𝑜𝑟𝑘𝑖𝑛𝑔 𝑦𝑒𝑎𝑟. 

 𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑢𝑛𝑑𝑒𝑟 𝑎 𝑙𝑜𝑤 𝑡ℎ𝑟𝑒𝑠ℎ𝑜𝑙𝑑
=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64291
× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑤𝑖𝑡ℎ 𝑝𝑒𝑟𝑠𝑜𝑛𝑎𝑙 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑤𝑖𝑡ℎ 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒292 
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑖𝑜𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑠𝑢𝑐ℎ 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑡𝑜 𝑎𝑛 𝑜𝑛𝑙𝑖𝑛𝑒 𝑝𝑙𝑎𝑡𝑓𝑜𝑟𝑚293  

 Assumptions used: 

-  constant reporting and prevalence of OVAW across Member States 

- 

low threshold would translate into reporting of OVAW to police instead of platforms 

-  no set-up costs 

-  cost of training covered by [1.1 Training OVAW] 

-  cost of investigation covered by [3.5 Public prosecution] 

- 

the assessment of the baseline did not find information on comparable measures in place, 
therefore it is assumed that all Member States incur full costs 

c. Victim compensation 

The estimation of this measure is based on the cost of providing access to compensation for victims of 
online serious gender based harassment. It is assumed that bodily injury and impairment of health and 
meaningful compensation to violence against women and domestic violence victims are covered by the 
baseline scenario, as current EU law already requires States to provide such compensation for violent 
intentional crimes. 

The following approach is used, for each Member State: 

289 1350 cases is used - Internet Watch Foudnation (2020), 299,619 reports assessed in a year. Available at: 
https://annualreport2020.iwf.org.uk/trends  
290 Eurostat, [earn_ses18_13] (Public administration and defence salary > 10 employees or more) 
291 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
292 38% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 
293 25% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 

123 

 
 
 
                                                 
𝑪𝒐𝒔𝒕  = (𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒

+ 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑔𝑒𝑛𝑑𝑒𝑟 𝑏𝑎𝑠𝑒𝑑 ℎ𝑎𝑟𝑎𝑠𝑠𝑚𝑒𝑛𝑡)  
×   𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑡ℎ𝑎𝑡 𝑎𝑝𝑝𝑙𝑦 𝑓𝑜𝑟 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛294  × 50%295
× 𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑠𝑡𝑎𝑡𝑒 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑎𝑤𝑎𝑟𝑑𝑒𝑑296) 

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64297
× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑤ℎ𝑜 𝑝𝑒𝑟𝑠𝑜𝑛𝑎𝑙𝑙𝑦 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒𝑑 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒298 
×   𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑡𝑜 𝑜𝑛𝑙𝑖𝑛𝑒 𝑝𝑙𝑎𝑡𝑓𝑜𝑟𝑚299  

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑔𝑒𝑛𝑑𝑒𝑟 𝑏𝑎𝑠𝑒𝑑 ℎ𝑎𝑟𝑎𝑠𝑠𝑚𝑒𝑛𝑡

= (𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64300
× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑤ℎ𝑜 𝑝𝑒𝑟𝑠𝑜𝑛𝑎𝑙𝑙𝑦 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒𝑑 ℎ𝑎𝑟𝑎𝑠𝑠𝑚𝑒𝑛𝑡301
× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 ℎ𝑎𝑟𝑎𝑠𝑠𝑚𝑒𝑛𝑡 𝑖𝑛𝑐𝑖𝑑𝑒𝑛𝑡𝑠302)  

Note that costs were not  estimated for two Member States (IT, MT)  with  missing data on prevalence 
and therefore the total costs might be higher than estimated. 

Assumptions used: 

- 

the number of women experiencing harassment or discrimination is used as an estimate of the 
number of victims serious gender based harassment. 

-  no set-up costs 

- 

limited  to  costs  for  the  state.  Obligation  of  the  future  directive  would  put  on  States  to  pay 
compensation  in  those  situations  where  the  victim  is  not  able  to  recover  such  compensation 
from the perpetrator or other sources. It is assumed the state pays in 50% of the cases. 

-  negligible  costs  are  incurred  to  inform  victims  of  violence  against  women  and  domestic 
violence  about  the  possibility  to  request  compensation  from  the  perpetrator  and  to  provide  a 
decision in a reasonable time. 

294 Based on FRA 2020 survey results on percentage of respondents that reported contacting legal service/lawyers after the 
incidence of  violence: https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  
295 Assumed in half the cases costs are not covered by the perpetrator but the state 
296  Most suitable compensation is chosen from table on compensation costs provided.  
When that is not available, we use 2.5 times the minimum monthly wage. 
No amount found for AT, DK and SE, therefore the average cost for the Netherlands was used  
297 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
298 Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ .  
299 Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ .  
300 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
301 Eurobarometer - In the past 12 months have you personally felt discriminated against or harassed on the basis of one or 
more of the following grounds? (Gender) (Percentage of respondents who mentioned each ground of discrimination)  
302 FRA (2019) - Women reporting the incident of harassment. Available at: https://fra.europa.eu/en/data-and-maps/2021/frs 

124 

 
                                                 
d. Public prosecution 

The estimation of this measure is based on the cost of  investigation and prosecution  ex officio of the 
new EU-crimes (on online violence). 

The following approach is used, for each Member State: 

𝑪𝒐𝒔𝒕  = ( 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑜𝑓 𝑂𝑉𝐴𝑊 −  𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑜𝑓 𝑂𝑉𝐴𝑊 𝑠𝑒𝑒𝑘𝑖𝑛𝑔 𝑙𝑒𝑔𝑎𝑙 𝑟𝑒𝑐𝑜𝑢𝑟𝑠𝑒 )

×  𝑢𝑛𝑖𝑡 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑝𝑟𝑜𝑠𝑒𝑐𝑢𝑡𝑖𝑜𝑛303 × 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑜𝑓 𝑐𝑎𝑠𝑒 𝑝𝑢𝑟𝑠𝑢𝑒𝑑 𝑒𝑥 𝑜𝑓𝑓𝑖𝑐𝑖𝑜304 

 𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑜𝑓 𝑂𝑉𝐴𝑊 𝑠𝑒𝑒𝑘𝑖𝑛𝑔 𝑙𝑒𝑔𝑎𝑙 𝑟𝑒𝑐𝑜𝑢𝑟𝑠𝑒

=  𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑜𝑓 𝑂𝑉𝐴𝑊
× 𝑝𝑒𝑟𝑒𝑛𝑡𝑎𝑔𝑒 𝑜𝑓 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑡ℎ𝑎𝑡 𝑠𝑒𝑒𝑘 𝑙𝑒𝑔𝑎𝑙 𝑟𝑒𝑐𝑜𝑢𝑟𝑠𝑒305 

𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑜𝑓 𝑂𝑉𝐴𝑊 

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64306
× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑤𝑖𝑡ℎ 𝑝𝑒𝑟𝑠𝑜𝑛𝑎𝑙 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑤𝑖𝑡ℎ 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒307  

 Assumptions used: 

-  due to lack of data available on the proportion of cases that are pursued ex officio, it is assumed 
that  20%  of  remaining  of  OVAW  cases  (i.e.  cases  not  pursued  by  individual  victims)  are 
pursued ex officio for all Member States 

-  no set-up costs 

- 

the  assessment  of  the  baseline  did  not  find  information  on  comparable  measures  in  place, 
therefore it is assumed that all Member States incur full costs. 

e. National coordination 

The  estimation  of  this  measure  is  based  on  the  cost  of  ensuring  legal  standing  to  equality  bodies  to 
assist and represent violence against women and domestic violence, incl. OVAW, victims in line with 
COM Rec on equality. 

The following approach is used, for each Member State: 

𝑪𝒐𝒔𝒕  = (𝑎𝑑𝑑𝑖𝑡𝑖𝑜𝑛𝑎𝑙 𝐹𝑇𝐸𝑠 𝑟𝑒𝑞𝑢𝑖𝑟𝑒𝑑  ×   𝑚𝑒𝑎𝑛 𝑒𝑎𝑟𝑛𝑖𝑛𝑔𝑠 𝑜𝑓 𝑠𝑡𝑎𝑓𝑓 𝑖𝑛 𝑒𝑞𝑢𝑎𝑙𝑖𝑡𝑦 𝑏𝑜𝑑𝑖𝑒𝑠308)  

303 The UK costs of crime report estimates the average prosecution cost of "sexual offences"  to be £30 in 2015/2016: 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/954485/the-economic-
and-social-costs-of-crime-horr99.pdf  

adjusted for each country’s price level using PPP GDP/capita 

- 
-  UK- EUR conversion rate of 1 GBP = 1.35503 EUR in Month 1 of 2016 

304 Assumed 20% due to lack of available information. 
305 5% - A resent EPRS study assumed that 5% of victims of both cyber-harassment and cyber-stalking seek legal recourse 
p.210. Available at : 
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662621/EPRS_STU(2021)662621_EN.pdf  
306 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
307 38% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 

125 

 
 
                                                 
 Assumptions used: 

-  2 additional FTEs required per Member State to assist and represent victims of violence against 

women and domestic violence including OVAW 

-  no set-up costs 

-  For countries with no data, assume average salary across 23 countries with data  

-  no costs for Member States where equality bodies already have a legal standing to receive GBV 

complaints or claims or sexual harassment and harassment based on sex 

- 

for  Member  States  where  either  equality  bodies  cannot  receive  GBV  complaints  or  cannot 
receive  claims  of  harassment,  additional  FTE's  are  needed.  For  Member  State  with  no 
information on the baseline (SI), it is assumed that equality bodies have no legal standing and 
hence, full costs are incurred. 

1.2.4. Estimated costs of victim support 

a. General support – Special leave 

The  total  investment  required  is  negligible  as  general  support  services  to  victims  of  violence  against 
women and domestic violence are covered in the baseline from a cost perspective. Additional costs are 
covered by 4.2 Specialist support, 4.3 Support to victims of OVAW, 4.4 Support to victims of gender-
based  harassment  at  work  and  4.5  Access  to  shelters.  Moreover,  the  cost  if  issuing  guidelines  is 
assumed to be minimal.  

The estimation of this measure is based on the cost of the obligation for MS to provide three days of 
special  leave  compensated  at  the  level  of  sick  leave  for  all  victims  of  violence  against  women  and 
domestic  violence.  The  cost  falls  on  companies.  The  following  approach  is  used,  for  each  Member 
State: 

𝑪𝒐𝒔𝒕  = 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑡ℎ𝑒 𝑐𝑟𝑖𝑚𝑒

× 𝑚𝑒𝑎𝑛 𝑑𝑎𝑖𝑙𝑦 𝑐𝑜𝑚𝑝𝑒𝑛𝑠𝑎𝑡𝑖𝑜𝑛 𝑜𝑓𝑓𝑒𝑚𝑎𝑙𝑒𝑠 𝑎𝑔𝑒𝑑 16 𝑡𝑜 64309  × 𝑡ℎ𝑟𝑒𝑒 𝑑𝑎𝑦𝑠 𝑜𝑓 𝑙𝑒𝑎𝑣𝑒  

 𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑣𝑖𝑐𝑡𝑖𝑚𝑠 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑 𝑡ℎ𝑒 𝑐𝑟𝑖𝑚𝑒

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64310
× 𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒 𝑜𝑓 𝑝ℎ𝑦𝑠𝑖𝑐𝑎𝑙 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑎𝑔𝑎𝑖𝑛𝑠𝑡 𝑎 𝑤𝑜𝑚𝑎𝑛311 
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑤𝑜𝑚𝑒𝑛 𝑡ℎ𝑎𝑡 𝑟𝑒𝑝𝑜𝑟𝑡 𝑡ℎ𝑒 𝑐𝑟𝑖𝑚𝑒 𝑡𝑜 𝑡ℎ𝑒 𝑝𝑜𝑙𝑖𝑐𝑒312  

Note that costs where not estimated for two Member States (IT, MT) with missing data on prevalence 
and therefore the total costs might be higher than estimated. 

 Assumptions used: 

308 Eurostat, [earn_ses18_17] (Public administration and defence; compulsory social security; education; human health and 
social work activities; arts, entertainment and recreation; other service activities > 10 employees or more) 
309 Eurostat mean income by age and sex - EU-SILC and ECHP surveys. online data code: ILC_DI03  
310 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
311 Based on FRA 2020 survey results: https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  
312 Ibid. 

126 

 
 
 
                                                                                                                                                                        
-  due to lack of comparable data on the number of women victims of violence against women and 
domestic  violence  by  Member  State,  the  estimate  of  victims  eligible  is  based  on  the  broader 
category of all women victims of physical violence  

-  Three-day leave is implemented in all MSs 

-  Level of sick leave compensation set at 100% of pay 

-  negligible cost of issuing guidelines 

-  no set-up costs. 

b. Specialised support 

The  estimation  of  this  measure  is  based  on  the  cost  of  ensuring  availability  of  specialist  women's 
support services to all women victims of violence and their children and groups at a heightened risk of 
violence  (such  as  migrant  women,  victims  from  minority  communities,  women  with  disabilities, 
women working in the sex industry and women prisoners).  

The following calculation is used, for each Member State: 

𝑪𝒐𝒔𝒕  = (𝑎𝑛𝑛𝑢𝑎𝑙 𝑔𝑜𝑣𝑒𝑟𝑛𝑚𝑒𝑛𝑡 𝑒𝑥𝑝𝑒𝑛𝑑𝑖𝑡𝑢𝑟𝑒 𝑓𝑜𝑟 𝑠𝑝𝑒𝑐𝑖𝑎𝑙𝑖𝑠𝑡 𝑠𝑒𝑟𝑣𝑖𝑐𝑒𝑠 𝑓𝑜𝑟 𝑠𝑒𝑥𝑢𝑎𝑙𝑖𝑠𝑒𝑑 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒313

× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑜𝑓 𝑚𝑖𝑠𝑠𝑖𝑛𝑔 𝑠𝑒𝑟𝑣𝑖𝑐𝑒𝑠 𝑓𝑜𝑟 𝑠𝑢𝑟𝑣𝑖𝑣𝑜𝑟𝑠 𝑜𝑓 𝑠𝑒𝑥𝑢𝑎𝑙𝑖𝑠𝑒𝑑 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒314)
× 1.1  

Note  that  costs  where  not  estimated  for  three  Member  States  (RO,  SI,  SE)  with  missing  data  on  the 
proportion of missing services and therefore the total costs might be higher than estimated. 

 Assumptions used: 

-  due  to  lack  of  data  available  on  Member  State  expenditure  on  specialist  support  services  for 
women victims of violence against women and domestic violence and their children, the annual 
UK expenditure adjusted by relative population size of UK and each EU Member State is used 

-  no set-up costs 

- 

- 

the expenditure needed is  a function of the percentage of missing expenditure on survivors of 
sexualised violence 

all Member States need an additional 10% of total expenditure to ensure availability of services 
to groups at heightened risk. 

c. Support to victims of gender-based cyber violence 

The estimation of this measure is based on the cost of providing on- and offline support for victims of 
gender-based cyber violence against women. 

The following approach is used, for each Member State: 

313 EIGE (2021) - annual UK government expenditure on specialist support services for women victims of GBV: EUR 
19,653,064. MS expenditure is then adjusted by relative population size of UK and each EU MS. 
314 Specialised services for sexualized violence in EU Member States (2018) - WAVE annual report 

127 

 
                                                 
𝑪𝒐𝒔𝒕  = 𝑠𝑖𝑥 ℎ𝑜𝑢𝑟𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟315

× (𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑
× ℎ𝑒𝑎𝑙𝑡ℎ 𝑎𝑛𝑑 𝑠𝑜𝑐𝑖𝑎𝑙 𝑤𝑜𝑟𝑘𝑒𝑟 𝑠𝑡𝑎𝑓𝑓 𝑠𝑎𝑙𝑎𝑟𝑦 𝑝𝑒𝑟 ℎ𝑜𝑢𝑟316) 

𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑎𝑠𝑒𝑠 𝑟𝑒𝑝𝑜𝑟𝑡𝑒𝑑

=  𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 15 𝑡𝑜 64317
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑤𝑖𝑡ℎ 𝑝𝑒𝑟𝑠𝑜𝑛𝑎𝑙 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑤𝑖𝑡ℎ 𝑜𝑛𝑙𝑖𝑛𝑒 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒318 
× 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔 𝑠𝑢𝑐ℎ 𝑒𝑥𝑝𝑒𝑟𝑖𝑒𝑛𝑐𝑒 𝑡𝑜 𝑎𝑛 𝑜𝑛𝑙𝑖𝑛𝑒 𝑝𝑙𝑎𝑡𝑓𝑜𝑟𝑚319 

  Assumptions used: 

-  no set-up costs 

-  each reported case of OVAW is dealt with 6 one-hour sessions 

-  on-line support is already covered under the helplines [4.6] 

- 

the assessment of the baseline did not find information on comparable measures in place, 
therefore it is assumed that all Member States incur full costs 

d. Support to victims of gender-based work harassment 

The  estimation  of  this  measure  is  based  on  the  cost  to  all  employers  including  SMEs    of  providing 
support  to  victims  of  gender-based  work  harassment  through  one-to-one  sessions  (online  or  face-to-
face).  

The following calculation is used, for each Member State:  

𝑪𝒐𝒔𝒕  = ℎ𝑒𝑎𝑙𝑡ℎ 𝑠𝑡𝑎𝑓𝑓 𝑡𝑖𝑚𝑒 𝑛𝑒𝑒𝑑𝑒𝑑 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟 𝑝𝑒𝑟 𝑙𝑎𝑟𝑔𝑒 𝑒𝑛𝑡𝑒𝑟𝑝𝑟𝑖𝑠𝑒 𝑎𝑛𝑑 𝑆𝑀𝐸

× 𝐻𝑜𝑢𝑟𝑙𝑦 𝑒𝑎𝑟𝑛𝑖𝑛𝑔𝑠 𝑓𝑜𝑟 ℎ𝑒𝑎𝑙𝑡ℎ 𝑠𝑡𝑎𝑓𝑓320 
× 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑙𝑎𝑟𝑔𝑒 𝑒𝑛𝑡𝑒𝑟𝑝𝑟𝑖𝑠𝑒𝑠 𝑎𝑛𝑑 𝑆𝑀𝐸𝑠321 

315 assuming each case is dealt with 6 one-hour sessions for the whole year. 
316 Eurostat, [earn_ses18_13] (Human health and social work activities salary; compulsory social security > 10 employees or 
more) 
317 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
318 38% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 
319 25% - Economist Intelligence Unit (2020) -Measuring the prevalence of online violence against women. Available at:  
https://onlineviolencewomen.eiu.com/ . 
320 Eurostat, [earn_ses18_13] (Human health and social work activities salary; compulsory social security > 10 employees or 
more) 
321 Eurostat, Structural Business Statistics (2018) [SBS_SC_SCA_R2] 

128 

 
                                                 
ℎ𝑒𝑎𝑙𝑡ℎ 𝑠𝑡𝑎𝑓𝑓 𝑡𝑖𝑚𝑒 𝑛𝑒𝑒𝑑𝑒𝑑 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟 𝑝𝑒𝑟 𝑙𝑎𝑟𝑔𝑒 𝑒𝑛𝑡𝑒𝑟𝑝𝑟𝑖𝑠𝑒 𝑎𝑛𝑑 𝑆𝑀𝐸
=  𝑒𝑚𝑝𝑙𝑜𝑦𝑚𝑒𝑛𝑡 𝑝𝑒𝑟 𝑙𝑎𝑟𝑔𝑒 𝑒𝑛𝑡𝑒𝑟𝑝𝑟𝑖𝑠𝑒 𝑎𝑛𝑑 𝑆𝑀𝐸322 
× 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒𝑠 𝑖𝑛 𝑡𝑜𝑡𝑎𝑙 𝑒𝑚𝑝𝑙𝑜𝑦𝑚𝑒𝑛𝑡323 
× 𝑜𝑓 𝑓𝑒𝑚𝑎𝑙𝑒 𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 𝑠𝑢𝑏𝑗𝑒𝑐𝑡 𝑡𝑜 𝑤𝑜𝑟𝑘 𝑏𝑎𝑠𝑒𝑑 ℎ𝑎𝑟𝑎𝑠𝑠𝑚𝑒𝑛𝑡 𝑖𝑛 𝑡ℎ𝑒 𝑝𝑎𝑠𝑡 12 𝑚𝑜𝑛𝑡ℎ𝑠324  × 2
− ℎ𝑜𝑢𝑟𝑠  

Assumptions used: 

-  no set-up costs 

- 

- 

- 

for  countries  with  0%  prevalence  reported  i.e.  BG  &  RO,  assume  prevalence  rate  of  EU-27 
average 

each reported case of gender-based work harassment is dealt with two-hour sessions 

the  assessment  of  the  baseline  did  not  find  information  on  comparable  measures  in  place, 
therefore it is assumed that all Member States incur full costs. 

e. Shelters 

The estimation  of this  measure is  based on the cost  of providing  an additional  10% of refuge spaces 
needed options 1 and 2A) and all spaces needed i.e. one refuge space per 10,000 population (2B) for 
women victims of violence against women and domestic violence and their children.  

The following calculation is used, for each Member States: 

𝑪𝒐𝒔𝒕  = (𝐴𝑑𝑑𝑖𝑡𝑖𝑜𝑛𝑎𝑙 𝑏𝑒𝑑𝑠 𝑛𝑒𝑒𝑑𝑒𝑑  × (0.1325)   × 𝑢𝑛𝑖𝑡 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑎 𝑟𝑒𝑓𝑢𝑔𝑒 𝑠𝑝𝑎𝑐𝑒 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟326)

+ (

𝐴𝑑𝑑𝑖𝑡𝑖𝑜𝑛𝑎𝑙 𝑏𝑒𝑑𝑠 𝑛𝑒𝑒𝑑𝑒𝑑

𝐴𝑣𝑒𝑟𝑎𝑔𝑒 𝑐𝑎𝑝𝑎𝑐𝑖𝑡𝑦 𝑝𝑒𝑟 𝑠ℎ𝑒𝑙𝑡𝑒𝑟327

× 𝑒𝑥𝑝𝑒𝑛𝑑𝑖𝑡𝑢𝑟𝑒 𝑛𝑒𝑒𝑑𝑒𝑑 𝑡𝑜 𝑒𝑠𝑡𝑎𝑏𝑙𝑖𝑠ℎ 𝑎 𝑠ℎ𝑒𝑙𝑡𝑒𝑟328) 

322 Eurostat, Structural Business Statistics (2018). [SBS_SC_SCA_R2]. 
Data for Austria, Italy and Portugal are estimated based on EU average share of employment in large enterprises to 
population aged 15-74. i.e.: Employees in large enterprises in Austria = Austrian population 15-74*EU share of the 
population employed in large enterprises (~14%). 
323 Eurostat, [lfsq_egan2]. 
324 Eurofound (2015). “Over the last 12 months, during the course of your work have you been subjected to harassment?” 
(% of respondents, 15+ workers, total is for EU-28. Available at: https://eige.europa.eu/gender-
statistics/dgs/indicator/genvio_sex_harass_sur__ewcs_harassment  
325 Assume 10% of additional beds are provided under 2A. 
326 Cost estimation received from WAVE on the average cost of a shelter bedspace for a woman (with or without child) for 
four MS (AT, MT, SI, SE). Note: due to considerable differences across Member States, minimum and maximum estimates 
were used. 
327 Assuming an average 125-person capacity/shelter based on estimated capacity from WAVE annual report (2018) data on 
number of accessible shelters and number of spaces available.  
328 Based on a project example where Cyprus’ first purpose-built shelter to accommodate women and children received 
€742,920 in grants. See: https://eeagrants.org/sites/default/files/resources/Gender-based%2Bviolence_Updated092014.pdf  

129 

 
                                                 
𝐴𝑑𝑑𝑖𝑡𝑖𝑜𝑛𝑎𝑙 𝑏𝑒𝑑𝑠 𝑛𝑒𝑒𝑑𝑒𝑑 

= (

𝑃𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑜𝑛 1𝑠𝑡 𝐽𝑎𝑢𝑎𝑟𝑦 2020329
10,000

− 𝑒𝑥𝑖𝑠𝑡𝑖𝑛𝑔 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑏𝑒𝑑𝑠 𝑖𝑛 𝑠ℎ𝑒𝑙𝑡𝑒𝑟𝑠330)  

Assumptions used: 

-  due to lack of available data, it is assumed that the expenditure needed to establish a shelter is 

the same across all Member States 

- 

- 

- 

the encouragement of shelter provision (option 1 and 2A) would lead to 10% of additional beds 
provided and obligation to provide one refuge space for 10,000 population (2B) would lead to 
all additional beds provided 

the  requirement  for  1  space  per  10,000  population  would  be  sufficient  to  provide  safe 
accommodation  to  all  women  victims  of  violence  against  women  and  domestic  violence  and 
their children that need it 

for Member States (CY, EE, LV, LU, MT, SI) that already exceed or meet the requirement for 1 
space per 10,000 population in the baseline, no costs are incurred. 

f. Helplines 

The estimation of this measure is based on the cost of setting-up and operating state-wide 24/7 helpline 
free of charge for victims of violence against women and domestic violence. 

The following calculation is used, for each Member State: 

𝑪𝒐𝒔𝒕  = (𝑏𝑢𝑑𝑔𝑒𝑡 𝑛𝑒𝑒𝑑𝑒𝑑 𝑡𝑜 𝑒𝑠𝑡𝑎𝑏𝑙𝑖𝑠ℎ 𝑎 ℎ𝑒𝑙𝑝𝑙𝑖𝑛𝑒331 +
𝑏𝑢𝑑𝑔𝑒𝑡 𝑛𝑒𝑒𝑑𝑒𝑑 𝑡𝑜 𝑜𝑝𝑒𝑟𝑎𝑡𝑒 𝑎 ℎ𝑒𝑙𝑝𝑙𝑖𝑛𝑒 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟332)  

Assumptions used: 

-  due to lack of available data, it is assumed that the budget needed to establish a helpline is the 

same across all Member States 

- 

for Member States (AT, BG, CY, DK, EE, FI, DE, EL, IE, IT, LT, RO, SK, ES, SE) that have 
24/7 toll free helpline in place for victims of violence against women and domestic violence333, 
no additional costs are incurred to set-up and operate the national helpline 

-  negligible cost of setting-up a harmonised EU helplines and no costs to run a harmonised EU 

helpline. 

329 Eurostat [DEMO_PJAN] 
330 WAVE annual report 2018, Table 7.  
331 Estimated based on GREVIO report for Poland (2018) where the state expenditure for the establishment of a 24-hour toll 
free hotline for victims of GBV.DV was €78,822. 
332 Cost estimation received from WAVE on how much it costs per year to operate a women's helpline which runs 24/7 for 
free for three MS (AT, EL, MT,). Note: due to considerable differences across Member States, minimum and maximum 
estimates were used. 
333 Based on information available from WAVE annual report (2018) on national women's helplines in EU MS meeting the 
standard of the Istanbul Convention.  

130 

 
                                                 
g. Coordination of measures against gender-based work harassment 

The total investment required to discuss measures against gender-based harassment with social partners 
is assumed to be minimal.  

1.2.5. Estimated costs of coordination 

a. Monitoring, incl. data collection  

The estimation of this measure is based on the cost of participating in a survey coordinated at the EU-
level  on  violence  against  women  and  domestic  violence  and  of  conducting  administrative  data 
collections at regular intervals meeting ICCS standards.  

The following calculation is used, for each Member State: 

𝑪𝒐𝒔𝒕  = 𝐶𝑜𝑠𝑡𝑠 𝑡𝑜 𝑝𝑎𝑟𝑡𝑖𝑐𝑖𝑝𝑎𝑡𝑒 𝑖𝑛 𝑎𝑛 𝐸𝑈

− violence against women and domestic violence  𝑠𝑢𝑟𝑣𝑒𝑦 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟
+ 𝑐𝑜𝑠𝑡𝑠 𝑡𝑜 𝑓𝑖𝑙𝑙 𝑛𝑎𝑡𝑖𝑜𝑛𝑎𝑙 𝑞𝑢𝑒𝑠𝑡𝑖𝑜𝑛𝑛𝑎𝑖𝑟𝑒𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟
+ 𝑐𝑜𝑠𝑡𝑠 𝑜𝑓 𝑐ℎ𝑎𝑛𝑔𝑖𝑛𝑔 𝑡ℎ𝑒 𝑛𝑎𝑡𝑖𝑜𝑛𝑎𝑙 𝑑𝑎𝑡𝑎 𝑐𝑜𝑙𝑙𝑒𝑐𝑡𝑖𝑜𝑛 𝑠𝑦𝑠𝑡𝑒𝑚334
+ 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑚𝑎𝑖𝑛𝑡𝑎𝑖𝑛𝑖𝑛𝑔 𝑐𝑒𝑛𝑡𝑟𝑎𝑙 𝑑𝑎𝑡𝑎𝑏𝑎𝑠𝑒 𝑜𝑛 𝑎𝑑𝑚𝑖𝑛 𝑑𝑎𝑡𝑎335 

𝐶𝑜𝑠𝑡𝑠 𝑡𝑜 𝑝𝑎𝑟𝑡𝑖𝑐𝑖𝑝𝑎𝑡𝑒 𝑖𝑛 𝑎𝑛 𝐸𝑈

− violence against women and domestic violence  𝑠𝑢𝑟𝑣𝑒𝑦 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟
= 𝑐𝑜𝑠𝑡 𝑝𝑒𝑟 𝑖𝑛𝑡𝑒𝑟𝑣𝑖𝑒𝑤𝑒𝑒336  × 𝑠𝑎𝑚𝑝𝑙𝑒 𝑠𝑖𝑧𝑒 𝑜𝑓 𝑠𝑢𝑟𝑣𝑒𝑦337 

𝐶𝑜𝑠𝑡𝑠 𝑡𝑜 𝑓𝑖𝑙𝑙 𝑛𝑎𝑡𝑖𝑜𝑛𝑎𝑙 𝑞𝑢𝑒𝑠𝑡𝑖𝑜𝑛𝑛𝑎𝑖𝑟𝑒𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟 

= ℎ𝑜𝑢𝑟𝑙𝑦 𝑐𝑜𝑠𝑡 𝑡𝑜 𝑓𝑖𝑙𝑙 𝑞𝑢𝑒𝑠𝑡𝑖𝑜𝑛𝑛𝑎𝑖𝑟𝑒338  × 360339 

Assumptions used: 

- 

the assessment of the baseline did  not find information  national  administrative data collection 
based on ICCS standards, therefore it is assumed that all Member States would incur this cost. 
Moreover,  the  costs  to  participate  in  an  EU-level  survey  on  violence  against  women  and 
domestic violence represents a new cost to all Member States and therefore, all Member States 
would incur costs every two-years. 

- 

assumed cost of €100 cost per interviewee includes all costs that would need to be incurred by 
Member States 

334 Based on the estimated hourly cost of a database developer (see: https://www.approvedindex.co.uk/database-
developers/database-prices) converted to EUR based on 2021 mid-year conversation rates, assuming 120 hours are required 
to change the data collection system. 
335 Cost of updating and maintaining EIGE's Gender Statistics Database is used as a proxy of yearly maintenance cost. 
336 Assumed €100 cost per interviewee 
337 Based on information obtained on ESTAT on estimated sample size for countries currently implementing the EU-GBV 
survey 
338 Mean hourly earnings by sex, age and economic activity [EARN_SES18_13] of public administration and defence; 
compulsory social security; education; human health and social work activities; arts, entertainment and recreation; other 
service activities. EU-27 average used for countries with missing data (AT, BE, EL, PT) 
339 Assuming 120 hours are required per admin data collection, assuming three such collections in a year (police, judiciary, 
support services) 

131 

 
                                                 
- 

for countries with no data on sample size it is assumed that, an average across all countries is 
assumed 

-  due to lack of available data on number of hours required to change a data collection system and 
to  complete  questionnaires  on  administrative  data,  it  is  assumed  that  they  require  120  hours 
each and that three administrative data collections would be required in a year. 

b. Multi-agency service provision  

The estimation of this measure is based on the cost of the obligation for MS to provide multi-agency 
and multi-disciplinary one-stop access to relevant protection and support services in the same premises. 
The following approach is used, for each Member State: 

 𝑪𝒐𝒔𝒕 = 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 𝑛𝑒𝑒𝑑𝑒𝑑  × 𝑎𝑛𝑛𝑢𝑎𝑙 𝑠𝑎𝑙𝑎𝑟𝑦 𝑜𝑓 ℎ𝑒𝑎𝑙𝑡ℎ 𝑎𝑛𝑑 𝑜𝑐𝑖𝑎𝑙 𝑤𝑜𝑟𝑘𝑒𝑟𝑠340  

𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 = 4 𝑏𝑦 𝑑𝑒𝑓𝑎𝑢𝑙𝑡.  

To match population differences, this is increased by 1 employee for every 2 million females aged 15 
to 64341 (when the female population is above 10 million) 

 Assumptions used: 

-  Minimum of four staff members needed for information centre 

-  employees compensated at the level of “health and social workers” 

-  Assuming 52 times 40-hour weeks every year 

-  no set-up costs 

 Estimation of cost reductions (economic benefits) 

The  overall  costs  of  violence  against  women  and  domestic  violence  estimated  to  be  €290  billion  by 
EIGE were used for the costs in the status quo. The estimated reduction in costs was calculated for each 
of the cost categories measured by EIGE, which includes342: 

-  Lost economic output to individual victims measured in lost earnings due to time taken off work 

and lost productivity 

-  Health  services  costs  to  national  authorities  as  victims  of  gender-based  violence  make  use  of 

health services for treatment of physical and mental harms 

-  Criminal  justice  system  costs  to  national  authorities  due  to  involvement  in  investigations  and 

prosecutions of gender-based violence 

-  Civil justice system costs to national authorities to provide legal aid to victims of gender-based 

violence to separate from a violent partner 

340 Eurostat Mean hourly earnings for human health and social work activities > 10 employees or more - Eurostat (online 
code EARN_SES18_13). For countries with no data average of countries with available data (10.2) was used 
341 Eurostat, Population on 1st January 2020 [demo_pjanbroad]  
342 Estimation of the costs of gender-based violence in the UK case study and extrapolation to EU Member States 
(forthcoming EIGE paper, 2021). 

132 

 
 
 
 
                                                 
-  Social  welfare  costs  to  national  authorities  to  provide  housing  aid  and  child  protection  to 

victims of gender-based violence 

-  Personal  costs  to  individual  victims  of  moving  homes  due  to  divorce  related  to  gender-based 

violence and to self-fund legal proceedings for separation from a violent partner 

-  Physical  and emotional impacts to individual victims due to negative impacts of the crime on 

quality of life 

The calculation of cost reductions were made using the formula below: 

𝑪𝒐𝒔𝒕 𝒓𝒆𝒅𝒖𝒄𝒕𝒊𝒐𝒏

= 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒 𝑎𝑔𝑎𝑖𝑛𝑠𝑡 𝑤𝑜𝑚𝑒𝑛 𝑎𝑛𝑑 𝑑𝑜𝑚𝑒𝑠𝑡𝑖𝑐 𝑣𝑖𝑜𝑙𝑒𝑛𝑐𝑒  𝑏𝑦 𝑐𝑜𝑠𝑡 𝑐𝑎𝑡𝑒𝑔𝑜𝑟𝑦
× % 𝑟𝑒𝑑𝑢𝑐𝑡𝑖𝑜𝑛 𝑖𝑛 𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒 

The following assumptions were made for the calculation: 

-  Two  scenarios,  short  and  long  term,  for  each  of  the  (sub-)  options,  were  considered  for  the 
percentage reduction in prevalence: 15% and 20% reduction (option 1); 20% reduction and 30% 
reduction (2a) and 22% reduction and 32% reduction (2b). The scenario's build on the European 
Parliament's  assessment  of  the  added  value  of  Gender-based  violence  as  a  new  area  of  crime 
listed in Article 83(1) TFEU343. The assessment assumed that the prevalence of violence against 
women  and  domestic  violence  will  decrease  by  10%  in  the  short-term  (about  five  years)  and 
20% – 30% in the long-term (about 10 years) after an EU–wide legislation is introduced.  

-  Given  that  policy  option  2b  includes  additional  measures  for  support  to  victims  of  violence 
against  women  and  domestic  violence  and  for  prevention,  the  reduction  in  prevalence  was 
assumed  to  be  greater  than  that  estimated  by  the  European  Parliament's  assessment.    This  is 
consistent with e.g. an assessment of the US National Crime Victimization Survey (NVCS) that 
found that the use of victim services was associated with a 40 percent reduction in the risk of 
repeat victimisation344.    

-  The reduction in costs is proportionate to the decrease in prevalence of gender-based violence 

under each scenario.  

-  For the criminal and civil justice system, there are counteracting economic impacts of an 

increase in costs due to increased reporting of gender-based or domestic violence and a decrease 
in costs due to the reduction in prevalence. The assumed change is therefore a lower proportion 
compared to the other cost categories.  

To estimate the percentage reduction for the criminal justice system and civil justice system, 
calculations were made using the formula below which is used by the European Parliament's 
assessment345: 

% 𝒓𝒆𝒅𝒖𝒄𝒕𝒊𝒐𝒏 𝒊𝒏 𝒑𝒓𝒆𝒗𝒂𝒍𝒆𝒏𝒄𝒆

= (1 + %𝑐ℎ𝑎𝑛𝑔𝑒 𝑖𝑛 𝑝𝑟𝑒𝑣𝑎𝑙𝑒𝑛𝑐𝑒)   × (1 + % 𝑐ℎ𝑎𝑛𝑔𝑒 𝑖𝑛 𝑟𝑒𝑝𝑜𝑟𝑡𝑖𝑛𝑔) − 1 

The following sources and assumption were used for the above calculation: 

343 https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662640/EPRS_STU(2021)662640_EN.pdf  
344 Ibid.  
345 https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662640/EPRS_STU(2021)662640_EN.pdf based on 
approach by N. Lomba, C. Navarra, M. Fernandes, Combating Gender-based Violence: Cyber Violence, briefing, EPRS, European Parliament, 
2021.   

133 

 
                                                 
-  The  measures  under  this  policy  option  (e.g.  criminalisation,  awareness-raising,  information 
provision  to  victims  of  violence  against women  and domestic violence and encouragement  of 
reporting of violence against women and domestic violence by witnesses and professionals) is 
likely  to  lead  to  an  increase  in  reporting  of  violence  against  women  and  domestic  violence 
violence  against  women  and  domestic  violencecases.  This  change  in  reporting  rates  would 
likely lead to higher costs for the criminal and civil justice system.  

-  The change in reporting rates is assumed to be 10% for option 2a. This assumption is based on a 
European  Parliament  study346  which  estimates  that  an  EU  Directive  on  gender-based 
cyberviolence  could  increase  reporting  rates  by  5%  to  10%.  Given  that  this  policy  option 
includes measures beyond EU-level criminalisation, the higher bound of 10% is used.  

-  Given that reporting rates might increase further due to additional support measures in 2b, the 

reporting rate is assumed to be 12.5% for option 2b. 

-  The increase in reporting rates is assumed to be the same in the two scenarios for option 2a and 

2b.

346 N. Lomba, C. Navarra, M. Fernandes, Combating Gender-based Violence: Cyber Violence, briefing, EPRS, European Parliament, 2021.   

134 

 
                                                 
ANNEX 5: Assessment of measures 

 Problem area: prevention of violence against women and domestic violence 

1.1.1. Assessment of measure 1.1.b Awareness raising, provision of information and 

training of professionals 

Measure 1.1.b will include: 

■  Right to information: Obligation of MS to provide information to victims of 

violence against women and domestic violence (IC art. 19).  

■  Awareness raising: Obligation of MS to conduct regular awareness-raising and 

provide information to the general public (Art. 13 IC, 14 IC) 

■  Awareness raising (online VAW): N/A 

■  Training: Obligation of MS to provide training on violence against women and 
domestic violenceto relevant professionals dealing with victims or perpetrators 
(IC 15): 

–  voluntary to participants; 

–  at intervals determined by the MS 

■  Training (online VAW): N/A 

Assessment criterion 

Assessment  

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

The measure will have some impact in relation to achieving this policy objective. First, it will put in place, 
across the EU, in a comprehensive manner, a set of prevention measures aimed at raising awareness of the 
general public and specific target groups.  
Currently, all 27 EU Member States operate awareness raising campaigns, mostly directly towards victims 
of DV/VAW to guide them towards dedicated helplines and information provision. However, their quality, 
coverage and frequency differ to a great extent. It would therefore be important for this measure to set some 
minimum standards as to the substance, type and scape of campaigns. Based on available evidence, larger, 
well-targeted campaigns using appropriate communication tools seem to have most impact. For example, in 
the last few years, due to a strong EU emphasis on the awareness raising part concerning prevention of 
VAW, many MS joined the EU campaign of ‘Orange the World’ carried out on 25 November – the 
international day of violence against women; the UN campaigns of 16 Days of Activist against VAW and 
White Ribbon Campaign and by organising and participating in visible, public events on 25th November 
where the situation of VAW is presented, discussed, political statements formulated and some new actions 
or plans announced. 
The main impacts anticipated from awareness raising measures will be related to behavioural changes 
amongst victims, their immediate social environment, specific target groups, perpetrators and wider society. 
However, as they are aimed at the general public and not targeted, they may not engage with those who are 
harder to reach and potentially at heightened risk of violence. Such campaigns are also non-existent in the 
Member States.  
The measure also includes an obligation to produce training to professionals dealing with victims and 
perpetrators. This would improve the nature and quality of support provided to victims. Training of police 
has also, for example, has been shown to result in stronger prosecution.347 Although training is available in 
all Member States, it is does not include all relevant professionals.  

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

No impact on this objective  

347 Violence Against Women Act (VAWA) Funding A Nationwide Assessment of Effects on Rape and Assault: 
https://journals.sagepub.com/doi/pdf/10.1177/1077801208329146  

135 

 
                                                 
Assessment criterion 

Assessment  

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

The right to information will support women in obtaining better access to justice, as they will gain a better 
understanding of the legal process and relevant organisations to support them. 
The training of professionals will, to a similar extent, ensure that relevant practitioners are able to better 
detect and respond to acts of violence. They will also be better able to cooperate with other relevant 
agencies. This is expected to improve overall access to justice for victims.  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

The right to information will improve access to support services for women, as they will be better informed 
about services and organisations available.   
The training of professionals may also, to some extent, contribute to this objective as professionals, as part 
of their increased knowledge of cooperation structures, may also be able to refer victims to relevant support 
services.  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

No impact on this objective 

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

No impact on this objective 

Social impacts 

If implemented, this measure is expected to have a limited extent of social impacts on the following 
groups.  

Victims of violence against women or domestic violence  
Awareness raising measures can be expected to lead to behavioural changes in terms of victims more willing 
to report such violence to the authorities, understand their rights to be free from violence, and seek help. The 
training of professionals and right to information will improve their access to justice and to support services. 
Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The training of professionals may lead to an improvement in the detection and handling of particular groups 
of victims.  

Perpetrators of violence against women or domestic violence 
Behavioural changes impacts from awareness raising measures can be expected in terms of perpetrators 
recognising their acts of violence, coming forward, and asking for help. For this, however, campaigns would 
need to be tailored to men. 

Wider society   
Positive impacts from awareness raising measures can be expected in terms of better understanding of such 
violence and changing social norms, raising the issue to the public attention, and increasing the public 
awareness of its extent and scale across society. Ultimately, they can help the wider public to take such 
violence more seriously and considerately and approaching it as an all-society problem. Transformative 
changes in social attitudes and acceptance  take however relatively long time to spread into society. 
In the more immediate environment of the victims (friends, relatives, neighbours), awareness raising 
measures can encourage the willingness to support victims in reporting and taking other actions, directly 
intervene, and help to address such violence. This should encourage the target groups to take action, 
intervene and help the victims by contacting the authorities and getting help.  
Awareness raising measures aimed at children and young people can help to decrease the likelihood of such 
violence at a later life stage and increase the likelihood of reporting such violence when witnessed in their 
environment. 

National authorities 
Overall, political acceptance of the measure is likely to be high, considering that most already have similar 
ones in place.  

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
-  Rights of the elderly (Article 25) 
- 
Integration of persons with disabilities (Article 26) 
-  Right to an effective remedy and to a fair trial (Article 47) 

136 

 
 
Assessment criterion 

Assessment  

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Administrative and compliance costs  The costs of the measures are expected to be born by the EC, Member State authorities and support of other 

organisations (if running awareness-raising campaigns). More specifically: 
The EC is expected to incur costs for the development of the Directive, and for providing additional 
guidance and organising consultation during transposition. It will also incur costs for monitoring and 
reporting on the implementation of the Directive.  
Possibly, the EC may also co-fund awareness raising campaigns, but the costs of these are presented below 
and relate to public authorities.  
Public authorities will incur costs for running the awareness-raising campaigns and developing and 
organising training to relevant professionals that are shown below.  

One-off development 
cost 

Running cost per 
annum 

Total EU cost (Millions of 
euros) 

Awareness-
raising  

Training  

0.5 

0.6 

1.7 – 4.0 

1.7 – 4.0 

18.4  

19.0 

Costs for awareness-raising are based on minimum and maximum estimates for conducting one awareness-
raising for the general public on violence against women and domestic violence. Costings assume that 
Member States would conduct an additional two such campaigns in a year compared to the baseline. 
Therefore, all Member States are assumed to incur the same costs for awareness-raising. While it is likely 
that a group of Member States that currently meet the IC standards would incur lower or close to zero costs 
and hence the total EU cost might be lower, information is not available to the number of campaigns 
conducted in these Member States in the baseline.  
Training costs are based on the cost of developing a 2-hour online training session and the cost of attending 
a 2-hour training session for police officers, lawyers, prosecutors, and judges. The cost of attending a 
training session is based on number of police officers, lawyers, prosecutors, and judges (assuming 15% of 
the total number in each group attend the training session) and their hourly national wages. Costings assume 
that no Member States conduct training for relevant professionals dealing with victims or perpetrators in the 
baseline. Although details are not available on hours of training provided, Member States already provide 
training to relevant professionals on victims' rights in the baseline which means total EU costs might be 
lower. However, since existing trainings to do necessarily target violence against women and domestic 
violence victims, it is assumed that all Member States would incur additional costs. 
The cost for the provision of information to victims of violence against women and domestic violence will 
be fulfilled through awareness-raising campaigns and training of professionals and therefore, costs are 
assumed to be zero. 

Overall assessment 

Overall, introducing a legal obligation and setting regular and mandatory awareness-raising, training and the right to information in a single 
legislative instrument specifically aimed at violence against women and domestic violence is expected to strengthen the implementation of relevant 
measures and improve their quality in many Member States, in particular in those which have not ratified the IC and those in which current 
measures are found to be lacking or insufficient in scale or scope. These measures are crucial are tackling embedded negative gender stereotypes 
and norms that are at the heart of violence against women. The training is not however mandatory which may mean gaps in the provision of 
training remain. It will bring benefits to victims and wider society, and may also help potential and actual perpetrators to change their behaviour.   
The total investment required amount to Million Euros 20.7 – 22.9.  
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

1.1.2. Assessment  of measure 1.1.c Awareness  raising, provision of information and 

training of professionals 

■  Right to information:  

–  Obligation of MS to provide information to victims of violence against women and 

domestic violence (IC art. 19).  

137 

 
 
 
■  Awareness raising:  

–  Obligation of MS to conduct regular awareness-raising and provide information to the 

general public (Art. 13 IC, 14 IC) 

–  Targeted awareness-raising and provision of information for groups at a heightened 

risk of violence against women and domestic violence 

■  Awareness raising (online VAW):  

■ 

Information provision on OVAW to the general public and relevant professionals (incl. 
media literacy). 

■  Training:  

–  Obligation of MS to provide mandatory and regular training on violence against 
women and domestic violence to relevant professionals dealing with victims or 
perpetrators (IC 15): 

○  voluntary to participants; 
○  at intervals determined by the MS 

■  Training (online VAW):  

–  Equipment of law enforcement and judicial authorities with specialized 

resources/training to prosecute OVAW. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

The measure will have some impact in relation to achieving this policy objective. First, as with 
measure 1.1.b, it will put in place, across the EU, in a comprehensive manner, a set of prevention 
measures aimed at raising awareness of the general public.  
Currently, all 27 EU Member States operate awareness raising campaigns, mostly directly 
towards victims of violence against women and domestic violenceto guide them towards 
dedicated helplines and information provision. However, their quality, coverage and frequency 
differ to a great extent. It would therefore be important for this measure to set some minimum 
standards as to the substance, type and scape of campaigns. Based on available evidence, larger, 
well-targeted campaigns using appropriate communication tools seem to have most impact. For 
example, in the last few years, due to a strong EU emphasis on the awareness raising part 
concerning prevention of VAW, many MS joined the EU campaign of ‘Orange the World’ carried 
out on 25 November – the international day of violence against women; the UN campaigns of 16 
Days of Activist against VAW and White Ribbon Campaign and by organising and participating 
in visible, public events on 25th November where the situation of VAW is presented, discussed, 
political statements formulated and some new actions or plans announced.  
The main impacts anticipated from awareness raising measures will be related to behavioural 
changes amongst victims, their immediate social environment, specific target groups, perpetrators 
and wider society. The measure will also implement targeted awareness-raising and provision of 
information for groups at a heightened risk of violence against women and domestic violence, 
which will engage with those who are harder to reach and potentially at heightened risk of 
violence. Such campaigns are also non-existent in the Member States.  
Finally, the measure will add provisions on online violence against women. Information will be 
provided to the general public and relevant professionals specifically on this topic, including on 
media literacy. This will help prevent this form of violence, and will educate victims and the 
wider public about their rights related to online violence. Further, including this type of targeted 
information provision in a legal instrument about gender-based violence and violence against 
women will send the message that this form of gendered violence is unacceptable and must be 
addressed. The measure will also equip law enforcement and judicial authorities with specialized 
resources and training to prosecute online violence against women, which will increase 
investigation, prosecution and sanctioning of such perpetrators. 
The training of professionals is also expected to positively impact on this objective, as it will 
help professionals on how to prevent secondary victimisation. This measure will implement 
mandatory and regular training, which will enhance prevention through ensuring consistency in 
professional conduct. Training professionals in a mandatory and regular way will also send the 

138 

 
 
 
Assessment criterion 

Score 

Assessment  

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

message that it is crucial to appropriately and adequately help victims of gender-based violence 
and violence against women. While in place in all Member States, it is not mandatory in all 
Member States (see Mapping in Annex) and the new Directive will add important value in terms 
of setting out the minimum standards for such training, based on the IC.  

No impact on this objective  

As with measure 1.1.b, the right to information will support women in obtaining better access to 
justice, as they will gain a better understanding of the legal process and relevant organisations to 
support them. 
The regular and mandatory training of professionals will, to a similar extent, ensure that 
relevant practitioners are able to better detect and respond to acts of violence. They will also be 
better able to cooperate with other relevant agencies. This is expected to improve overall access to 
justice for victims.  
The measure will also equip law enforcement and judicial authorities with specialized resources 
and training to prosecute online violence against women, which will increase investigation, 
prosecution and sanctioning of such perpetrators. 

As with measure 1.1.b, the right to information will improve access to support services for 
women, as they will be better informed about services and organisations available.   
The regular and mandatory training of professionals may also, to some extent, contribute to this 
objective as professionals, as part of their increased knowledge of cooperation structures, may 
also be able to refer victims to relevant support services.  

No impact on this objective 

No impact on this objective 

If implemented, this measure is expected to have a limited extent of social impacts on the 
following groups.  

Victims of violence against women and domestic violence  
Awareness raising measures can be expected to lead to behavioural changes in terms of victims 
more willing to report such violence to the authorities, understand their rights to be free from 
violence, and seek help, including specifically related to online violence against women. The 
training of professionals and right to information will improve their access to justice and to 
support services. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The regular and mandatory training of professionals may lead to an improvement in the detection 
and handling of particular groups of victims. Awareness-raising and provision of information will 
also be targeted for groups at a heightened risk of gender-based violence and domestic violence, 
which will ensure particular groups of victims (including those at risk of intersectional 
discrimination) will receive information about their rights which is specific and sensitive to their 
needs. 

Perpetrators of violence against women and domestic violence  
Behavioural changes impacts from awareness raising measures can be expected in terms of 
perpetrators recognising their acts of violence, coming forward, and asking for help. For this, 
however, campaigns would need to be tailored to men.  
The measure will equip law enforcement and judicial authorities with specialized resources and 
training to prosecute online violence against women, which will increase investigation, 
prosecution and sanctioning of such perpetrators. 

139 

 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Wider society   
Positive impacts from awareness raising measures can be expected in terms of better 
understanding of such violence and changing social norms, raising the issue to the public 
attention, and increasing the public awareness of its extent and scale across society. The 
information provision in this measure will also include specific information about online violence 
against women, and ultimately, they can help the wider public to take such violence more 
seriously and considerately and approaching it as an all-society problem.   
In the more immediate environment of the victims (friends, relatives, neighbours), awareness 
raising measures can encourage the willingness to support victims in reporting and taking other 
actions, directly intervene, and help to address such violence. This should encourage the target 
groups to take action, intervene and help the victims by contacting the authorities and getting 
help.  
Awareness raising measures aimed at children and young people can help to decrease the 
likelihood of such violence at a later life stage and increase the likelihood of reporting such 
violence when witnessed in their environment. 

National authorities 
Overall, political acceptance of the measure is likely to be high, considering that most already 
have similar ones in place.  

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
-  Rights of the elderly (Article 25) 
- 
Integration of persons with disabilities (Article 26) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

This option requires that Member States conducted targeted awareness-raising campaigns 
providing information to groups at heightened risk of violence against women and domestic 
violence and provide regular and mandatory training to professionals working with violence 
against women and domestic violence. Therefore, in addition to the costs estimated under 1.1b, 
public authorities will incur costs for running more targeted awareness-raising campaigns and 
developing and organising tailored trainings for relevant professionals.  

One-off development 
cost 

Running cost per 
annum 

Total EU cost (Millions of 
euros) 

Awareness-
raising  

Training  

- 

1.2 

2.2 – 4.4 

2.2 – 4.4 

24.5  

25.7 

Costs for awareness raising are based on the unit cost of a campaign that targets groups at 
heightened risk of violence against women and domestic violence. Costings assume that Member 
States would conduct two such campaigns in a year in addition to two campaigns in a for the 
general public on violence against women and domestic violence year compared to the baseline  
Training costs are based on the cost of developing an additional 2-hour online training session 
tailored to violence against women and domestic violence victims and the cost of attending a 2-
hour training session for police officers, lawyers, prosecutors, and judges that work with victims 
of violence against women and domestic violence. The cost of attending a training session is 
based on number of police officers, lawyers, prosecutors, and judges (assuming an additional 5% 
of the total number in each group attend the training session) and their hourly national wages. 
Costings assume that no Member States conduct regular training for professionals working with 
victims of violence against women and domestic violence in the baseline. 
The approach to right to information is the same as the second policy option and therefore no 
additional costs are incurred.  

Overall assessment 

140 

 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Overall, introducing a legal obligation and setting regular and mandatory awareness-raising, training and the right to information in a single 
legislative instrument specifically aimed at violence against women and domestic violence is expected to strengthen the implementation of relevant 
measures and improve their quality in many Member States, in particular in those which have not ratified the IC and those in which current 
measures are found to be lacking or insufficient in scale or scope. This measure improves upon measure 1.1.b as it adds targeted awareness-
raising and provision of information for groups at a heightened risk, information provision on OVAW to the general public and relevant 
professionals (including media literacy), equipment of law enforcement and judicial authorities with specialized resources/training to prosecute 
online violence against women, and makes the training of professionals regular and mandatory. 
The measure will contribute to meeting three policy objectives by bringing positive changes in terms of a greater awareness, better understanding, 
etc. It will bring benefits to victims and wider society, and may also help perpetrators to change their behaviour and seek help. In comparison to 
measure 1.1.b, the measure will additionally include targeted awareness-raising and provision of information for groups at a heightened risk, 
improving vulnerable groups’ awareness about their rights. 
The total investment required amount to 31.7 – 36.2 Million Euros.  
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

1.1.3. Assessment of measure 1.2.b gender-based cyber violence against women - self-

regulatory standards  

■  Self-regulatory standards: Encouragement of MS to encourage IT platforms and the 
media to establish self-regulatory standards to address violence against women and 
domestic violence and the root causes of such violence (Art. 17 IC). 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

This measure will encourage Member States to incentivise the private sector, the information and 
communication technology sector, and the media to implement self-regulatory standards. These 
standards will prevent online violence against women and domestic violence and will enhance 
respect for the dignity of such victims, an area which has been severely lacking in regulation and 
monitoring. Guidelines and standards brought in by the sector will limit the sharing of violent or 
abusive content, therefore reducing the capacity of perpetrators to conduct online abuse. 
Victims of gender-based online violence against women have benefitted somewhat from the 
general EU provisions applicable to all victims, for example Art. 21(2) of the Victims Rights 
Directives requires Member States to encourage the media to take self-regulatory measures to 
protect the privacy of victims. However, a strength of this measure will be to specifically address 
online violence against women which will more effectively and comprehensively contribute to 
effective protection and support. 
Currently, no countries, except Romania, have a specific definition of online violence in law. 
Eleven states (BE, FR, IE, IT, MT, NL, PL, PT, ES, SE) have criminalised or are about to 
criminalise non-consensual dissemination of intimate/private/sexual images specifically. A clear 
definition and/or criminalisation would facilitate the establishment of self-regulatory standards, as 
the latter could be based on principles in the law. However, for Member States without a 
definition or criminalisation, the standards will not have such a basis. Industry’s own self-
regulatory standards brought in by this measure should nevertheless reduce the availability of 
online violence, including non-consensual dissemination of intimate/private/sexual images. 
The self-regulatory standards could include measures recommended by GREVIO, including 
offering easily accessible effective complaint mechanisms for users to report harmful content, 
incentivising commercial online activities that incorporate a human rights perspective at all stages 
of their activity, and making legal information and information about requesting the removal of 
non-consensual content, including images or videos, available on their platforms. Another 
standard could be to ensure that spy software or stalkerware cannot do harm.   
However, the measure is self-regulatory and therefore will have less impact and harmonisation 
than a binding measure. Further, the effects of this measure will be dependent on the content of 
the guidelines and measures the industry chooses to bring in. GREIVO baseline evaluation reports 
for some Member States noted that existing self-regulatory instruments did not address the 
representation of women in a stereotyped and sexualised manner and/or address the reporting on 
violence against women and the harm caused by violence to child witnesses.  

141 

 
 
 
 
Assessment criterion 

Score 

Assessment  

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

The measure will help protect victims of gender-based violence against women and domestic 
violence from further violence if the repeated violence is occurring online, as the industry’s self-
regulatory standards may prohibit certain materials and images being used. 

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

If implemented, this measure is expected to have a limited extent of social impacts on the 
following groups.  

Victims of violence against women and domestic violence  
Self-regulatory standards can enhance the dignity and safety of the victims of online violence 
against women and domestic violence as the sector will limit the opportunity for perpetrators to 
share violent or abusive content. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on particular groups will depend on the content of the standards and guidelines; the 
standards could for example include specific rules related to content of children. 

Perpetrators of violence against women and domestic violence 
The measure is expected to impact perpetrators as sharing violent or abusive content would 
violate platforms’ guidelines or standards, and therefore perpetrators would be expected to be less 
likely to share such content. The measure may also have an impact on the freedom of expression 
rights of perpetrators if their content is (unjustly) removed for violating self-regulatory standards. 

Wider society   
The measure would improve the experience of all users of online platforms, as all users will be 
less likely to encounter violent or abusive content. 
It will also clearly impact the private and ICT sector as they will be creating and implementing 
the self-regulatory standards. 

National authorities 
This will likely find political acceptance as it will not require Member States to enact binding or 
obligatory measures. 

Fundamental rights 

The measure is expected to enhance in particular the following fundamental rights. 
Victims of online violence against women  

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to the integrity of the person (Article 3) 
- 
-  Respect for private and family life (Article 7) 
-  Non-discrimination (Article 21)  
- 
- 
- 

Equality between women and men (Article 23) 
Protection of personal data (Article 8) 
Freedom of expression and information (Article 11) 

Child victims /witnesses 

142 

 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

N/A 

Overall assessment 

Overall, encouraging Member States to encourage the online sector to establish self-regulatory standards to address violence against women and 
domestic violence and the root causes of such violence is expected to prevent online violence against women and domestic violence to some extent 
in many Member States, in particular in those which have not ratified the IC and those in which current measures are found to be lacking or 
insufficient in scale or scope. As the measures will be self-regulatory, they may not be as strong or effective as binding rules. 
The total investment required is negligible as large online platforms provide codes of conduct that are stricter in nature in identifying illegal content 
online to be removed than national law. 
This measure is likely find political acceptance as it will not require Member States to enact binding or obligatory measures. 

1.1.4. Assessment of measure 1.2.c gender-based cyber violence against women - self-

regulatory standards 

■  Self-regulatory standards: Obligation for MS to oblige very large platforms to 

implement Codes of Conduct to mitigate risk of OVAW. 

■  Measures directed at intermediary service providers: Measures obliging to: 

–  Act on or inform law enforcement upon request in cases of OVAW (see Art. 8, 9 

DSA)  

–  Process data for the voluntary detection, reporting or removal of criminalized ICT-
facilitated gender-based violence as defined, in particular on the basis of a central 
repository of hashes. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

This measure will oblige Member States to require very large online platforms to implement 
Codes of Conduct. For smaller stakeholders in the private sector, the information and 
communication technology sector, and the media, Member States will be encouraged to 
incentivise self-regulatory standards, as in measure 1.2.b.  
Both the Codes (for large platforms) and the self-regulatory standards (for smaller stakeholders) 
will mitigate risk and prevent online violence against women and domestic violence and will 
enhance respect for the dignity of such victims, an area which has been severely lacking in 
regulation and monitoring. Codes of Conduct (for large platforms) and self-regulatory standards 
(for smaller stakeholders) brought in by the sector will limit the sharing of violent or abusive 
content, therefore reducing the capacity of perpetrators to conduct online abuse. The Codes of 
Conduct and self-regulatory standards could include measures recommended by GREVIO, 
including offering easily accessible effective complaint mechanisms for users to report harmful 
content, incentivising commercial online activities that incorporate a human rights perspective at 
all stages of their activity, and making legal information and information about requesting the 
removal of non-consensual content, including images or videos, available on their platforms. 
Another preventative action which could be in the Codes and standards is to ensure that spy 
software or stalkerware cannot do harm.   
The measure will also oblige the large platforms to act on or inform law enforcement upon 
request in cases of online violence against women, and to process data for the voluntary 
detection, reporting or removal of criminalized ICT-facilitated gender-based violence as defined, 
in particular on the basis of a central repository of hashes.  
As with measure 1.2.b., a clear definition and/or criminalisation in a Member State will facilitate 
the establishment of Codes of Conduct and self-regulatory standards in the Member States which 
have them (only RO has a specific definition of online violence in law; the following have 
criminalised or are about to criminalize non-consensual dissemination of intimate/private/sexual 

143 

 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

images: BE, FR, IE, IT, MT, NL, PL, PT, ES, SE), as the standards could be based on principles 
in the law. However, for Member States without a definition or criminalisation, the Codes will not 
have such a basis. Nevertheless, the Codes of Conduct and standards brought in by this measure 
will reduce the availability of online violence, and the involvement of the online platforms in 
detecting and processing data related to online violence against women will reduce ICT-
facilitated gender-based violence. 
Victims of gender-based online violence against women have benefitted somewhat from the 
general EU provisions applicable to all victims, for example Art. 21(2) of the Victims Rights 
Directives requires Member States to encourage the media to take self-regulatory measures to 
protect the privacy of victims. However, a strength of this measure (as with measure 1.2.b) will be 
to specifically address online violence against women which will more effectively and 
comprehensively contribute to effective protection and support. 
Compared to measure 1.2.b, this measure will be more effective as large platforms will be 
obliged to implement Codes of Conduct, rather than encouraged to implement self-regulatory 
standards. This will be more effective as they will be mandatory, and there will be more scope for 
controlling the content of the Codes. However, proportionality will be ensured as smaller 
platforms and providers will simply be encouraged to implement self-regulatory standards. 

The measure will help protect victims of gender-based violence against women and domestic 
violence from further violence if the repeated violence is occurring online, as the Codes of 
Conduct (for large platforms) and self-regulatory standards (for smaller stakeholders) will 
prohibit certain materials and images being used. 
The obligation for platforms to report and process data relating to online violence against women 
on their platforms will facilitate the removal of content and potential prosecution of perpetrators, 
therefore protecting victims from potential further online violence. 

The obligation for platforms to report and process data relating to online violence against women 
on their platforms will facilitate the work of law enforcement, enabling faster and more effective 
removal of content and prosecution of perpetrators. 

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

If implemented, this measure is expected to have a limited extent of social impacts on the 
following groups.  

Victims of violence against women and domestic violenceGBVviolence against women and 
domestic violence  
Codes of Conduct (for large platforms) and self-regulatory standards (for smaller stakeholders) 
can be expected to enhance the safety and dignity of the victims of online violence against women 
and domestic violence, as the sector will limit the opportunity for perpetrators to share violent or 
abusive content. The participation of large platforms in informing law enforcement and 
processing data related to online violence against women will also facilitate justice for victims 
through punitive measures. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on particular groups will depend on the content of the Codes of Conduct and 
standards; they could for example include specific rules related to content of children. 

Perpetrators of violence against women and domestic violenceGBVviolence against women 
and domestic violence 

144 

 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

The measure is expected to impact perpetrators as sharing violent or abusive content would 
violate platforms’ Codes of Conduct (for large platforms) and self-regulatory standards (for 
smaller stakeholders), and therefore perpetrators would be expected to be less likely to share such 
content. When platforms act or inform law enforcement in cases of online violence against 
women, this will facilitate investigation, prosecution and sanctioning of perpetrators. The measure 
may also have an impact on the freedom of expression and data protection rights of perpetrators if 
their content is (unjustly) removed for violating self-regulatory standards or Codes of Conduct, 
and if personal information is shared with law enforcement. 

Wider society   
The measure would improve the experience of all users of online platforms, as all users will be 
less likely to encounter violent or abusive content. 
It will also clearly impact the private and ICT sector as they will need to implement the Codes of 
Conduct and self-regulatory standards, and monitor and act on cases of online violence against 
women. 

National authorities 
Political acceptance of this measure may be somewhat lower, as it would require Member States 
to monitor and enforce implementation, and law enforcement to act upon reporting. As mentioned 
earlier, Member States which do not have a definition in law, or a working definition in practice, 
will have to introduce one and criminalise this type of offence. On the other hand, several 
Member States may consider the measure a welcome EU action, providing the opportunity for a 
more harmonised approach, given the high cross-border dimension of online abuse.  

Fundamental rights 

The measure is expected to enhance in particular the following fundamental rights. 
Victims of online violence against women and domestic violence 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to the integrity of the person (Article 3) 
- 
-  Respect for private and family life (Article 7) 
-  Non-discrimination (Article 21)  
- 
- 
- 

Equality between women and men (Article 23) 
Protection of personal data (Article 8) 
Freedom of expression and information (Article 11) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

The measure may have a somewhat negative impact on: 
Perpetrators of online violence against women and domestic violence 

- 
- 

Freedom of expression and information (Article 11) 
Protection of personal data (Article 8) 

Especially if the latter are unjustly identified and investigated. 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

N/A 

Overall assessment 

Overall, obliging large platforms to implement Codes of Conduct (for large platforms) and self-regulatory standards (for smaller stakeholders) 
related to online violence against women is expected to prevent online violence against women to some extent in many Member States, in 
particular in those which have not ratified the IC and those in which current measures are found to be lacking or insufficient in scale or scope. 
Requiring large platforms to act on, inform law enforcement, and process data when acts of violence against women are conducted on their 
platforms will facilitate the removal of such violent material and assist law enforcement to act swiftly in such cases. This will contribute to 
increased safety for women and enhanced prosecution of perpetrators, which may have a deterrent effect.  
The total investment required is negligible as large online platforms provide codes of conduct that are stricter in nature in identifying illegal content 
online to be removed than national law. 
Political acceptance of this measure may be somewhat lower, as it would require Member States to monitor and enforce implementation, and law 
enforcement to act upon reporting. 

145 

 
 
 
 
 
 
 
146 

 
 
 
1.1.5. Assessment  of  measure  1.3.c.I  -  specific  prevention  measures  against  gender-

based work harassment 

■  Obligation on MS and employers to provide information and raise awareness 
■  Obligation on all employers to provide training of managers, develop anti-

harassment policies and risk assessments 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

The EELN report highlights shortcomings in the implementation of the EU directives in terms of 
effectiveness, including insufficient prevention measures.348 In the majority of baseline evaluation 
reports, (including those on AT, DK, IT, and SE), GREVIO called on the authorities to ensure 
that the private sector/employers take an active part in the prevention of violence against women, 
for example, by engaging them actively in policy development processes or by encouraging them 
to develop self regulatory standards, or, more generally, to take an active part in preventing and 
combating violence against women in all its forms. More specifically, in some Member States 
these actions do not appear to be implemented or its implementation is difficult to assess. 
This measure would improve these shortcomings by implementing awareness-raising and 
information provision on gender-based work harassment; mandatory training of managers, and 
mandatory policies and risk assessments on gender-based harassment at work. These actions are 
crucial for preventing violence against women and gender-based violence and harassment in the 
workplace, and further building awareness in this way can limit gender based behaviours which, 
while not reaching the threshold of severity that would allow them to be qualified as violence 
under the Istanbul Convention, are often the precursors of violence and/or promote its 
emergence or minimise it, as a manifestation of the structural inequalities that persist between 
women and men in the world of employment. 
See the row below on addressing the harassment of women at work for a more specific 
assessment related to workplace harassment. 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

Ensuring that gender based 
harassment of women at work is 

In its baseline evaluation reports, GREVIO highlights some current examples of good practice 
related to harassment at work, including in Portugal, France, and Malta, as described in measure 

348 EELN report p.82  

147 

 
 
 
  
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

1.3.b. Further, social partners have engaged in a wide range of measures and successfully 
provided assistance, particularly through collective bargaining.349 However, as described in 
measure 1.3.b, there are many described shortcomings with the current state of affairs in Europe. 
Social partners cited ILO Violence and Harassment Convention, 2019 (No.190) as guiding their 
work in this area because they provide far more comprehensive and specific provisions,350 and 
this measure is based on ILO-190.  
The measure will implement awareness-raising and information provision on gender-based work 
harassment; training of managers; and mandatory policies and risk assessments on gender-based 
harassment at work. This will ensure that when work-based harassment occurs, a victim’s 
colleagues and managers, as well as the government and social partners, will be informed and 
prepared to help support the victim and address the harassment swiftly and effectively. 
Currently, sexual harassment is defined in gender-neutral terms across Directive 2006/54/EC, 
2004/113/EC and 2010/41/EU, and the EELN report highlights fragmentation of the provisions 
across different legal instruments as shortcomings in the implementation of the EU directives.351 
Bringing in a comprehensive and specific legal framework on violence against women and 
domestic violence will emphasize the experience of women at work, sending a powerful message 
of zero tolerance towards gender based violence in the work environment, and will harmonise 
fragmented provisions. The measure will also clearly reference harassment on the basis of gender 
rather than sex. Having a strong legal framework is also essential to enabling unions to negotiate 
concrete sectoral and workplace measures. 
Further, there has been a ‘slow transition’ from an understanding of sexual harassment at work 
from a health and safety approach that views it as an issue of ‘dignity’, to an approach that 
recognises sexual harassment as due to discrimination and rooted in gender equality and thus a 
form of gender based violence.352 The ETUC found that, as violence and harassment have become 
a part of mainstream safety and health and wellbeing at work policies, they are not gender-
sensitive and ‘not seen as a structural gender equality issue’.353 GREVIO has also identified the 
provision of training to relevant stakeholders including a component on the recognition of 
gendered dynamics, and the impact and consequences of violence on victims as a necessary 
pathway to ensure service provision based on a gendered understanding. The awareness-raising, 
information provision, and mandatory training brought in by this measure would accelerate 
this shift in understanding as employers, employees, and officials gain understanding. 
The mandatory policies and risk assessments on gender-based harassment at work will ensure 
structures are in place to punish perpetrators and address situations of violence and harassment 
effectively and quickly. 
Finally, there will be benefits to bringing in a comprehensive and specific legal framework on 
violence against women and domestic violence through this measure. It will emphasize the 
experience of women at work, sending a powerful message of zero tolerance towards gender-
based violence in the work environment, and will harmonise fragmented provisions. Another key 
impact will be a focus on gender rather than sex when referring to discrimination, which will 
more appropriately address the underlying causes of gender discrimination and structural 
obstacles that women face due to socially constructed roles, behaviours, expressions and identities 
rather than biological attributes. 

No impact on this objective. 

349 ETUC (2017) ‘Safe at home, safe at work: trade union strategy to prevent, manage and eliminate work-place 
harassment and violence against’. https://www.etuc.org/sites/default/files/document/files/en_-_brochure_-
_safe_at_home_1.pdf 
350 DG Just meeting with employer associations, 30 June 2021; DG Just/ICF meeting with social partners 29 
June 2021.  
351 EELN report p.82  
352 Petroglou, P., (2019) Sexual Harassment and harassment related to sex at work: time for a new directive 
building on the EU gender equality acquis’, European Equality Law Review, Issue 2.  
353 Ibid 

148 

 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Social impacts 

Victims of violence against women and domestic violence  
Awareness-raising, information provision, and mandatory training will ensure all relevant actors 
are primed and prepared to recognise and prevent violence and harassment in the workplace, to 
reduce the number of victims and ensure justice when violence and harassment occurs. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on particular groups will depend on the content of the training and awareness raising; 
for example they could cover employees at risk of intersectional discrimination in the workplace, 
including potential victims of both gender-based and race-based harassment. 

Perpetrators of violence against women or domestic violence  
The measure is expected to impact perpetrators as harassment would violate the mandatory 
policies, and therefore perpetrators would be expected to be less likely to engage in harassment 
and violence. When other actors are trained and prepared to recognise instances of violence and 
harassment, this will facilitate investigation, prosecution and sanctioning of perpetrators. 

Wider society   
There will be an impact on government (as awareness-raising, information provision, and 
mandatory policies are brought in), social partners (awareness-raising, information provision, and 
mandatory policies), companies (awareness-raising, information provision, and mandatory 
policies), managers (mandatory training), and staff (voluntary training). 
Importantly, this will be mandatory only for large employers, as SMEs will only need to offer 
training on a voluntary basis and are encouraged to develop anti-harassment policies and risk 
assessments. 

National authorities 
The measure could encounter some resistance by some Member States, due to the sensibilities 
around the gender versus sex debate also in relation to the IC 

Fundamental rights 

The measure is expected to enhance in particular the following fundamental rights. 
Victims of violence against women or domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
- 

Equality between women and men (Article 23) 

Victims of sex-based harassment 

-  Right to fair and just working conditions (Article 31) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs are expected to be borne by employers and  Member State authorities. More 
specifically: 
Public authorities may develop their own training on violence against women or domestic 
violence in the workplace that can be used across Member States.  
This  policy  option  requires  mandatory  training  of  all  managers  in  all  companies  on  violence 
against women or domestic violence in the workplace. Employers will incur costs for developing 
and organising trainings for all managers on violence against women or domestic violence.  

One-off development 
cost 

Running cost per 
annum 

Total EU cost (Millions of 
euros) 

Training  

0.6 

1893.9 

1894.5 

Training costs are based on the cost of developing a 2-hour online training session on violence 
against women or domestic violence in the workplace and the cost of attending a 2-hour training 
session for managers. The cost of attending a training session is based on an estimate of the 
number of managers per employer, assuming an average of one manager per 10 employees, and 
their hourly national wages. Costings assume that no Member States conduct such trainings in the 
baseline. 

Overall assessment 

Overall, this measure would represent a large improvement over the current baseline situation (and therefore over measure 1.3.b). The introduction 

149 

 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

of awareness-raising and information provision; mandatory of managers on violence against women and domestic violence; and mandatory policies 
and risk assessments on gender-based harassment at work will ensure awareness and preparedness of relevant stakeholders to prevent and deal with 
gender-based violence and harassment when it occurs. It will also formalise and harmonise provisions at the EU level, sending a powerful message 
of zero tolerance towards gender-based violence in the work environment, harmonising fragmented provisions.  
The measure will bring benefits to victims and wider society, and will impact perpetrators by facilitating investigation, prosecution and sanctioning 
of perpetrators. Depending on the content of the implemented provisions, the measure may be able to reach more vulnerable groups as well. 
The total investment required amount to 1,894.5 Million Euros. 
The measure could encounter some resistance by some Member States, due to the sensibilities around the gender versus sex debate also in relation 
to the IC 

150 

 
 
 
 
 
 
 
1.1.6. Assessment of measure 1.4.b - work with perpetrators 

■  Perpetrator intervention and treatment programmes: 

–  Obligation of MS to have perpetrator intervention and treatment programmes 
in place for those sentenced for perpetrating violence against women and 
domestic violence (IC Art. 16); mandatory participation for re-offenders or 
mandatory participation for all offenders. 

–  Leaving flexibility to MS as to programme availability, format (online or in 

person) etc. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

The measure will oblige Member States to have perpetrator intervention and treatment 
programmes in place for those sentenced for perpetrating gender-based violence and violence 
against women, whilst leaving flexibility to Member States regarding programme availability and 
format (online or in person). By engaging and working with perpetrators, this will reduce the 
chances that a  previous perpetrator will engage in violence against women or domestic violence 
in the future. 
At present, the EU provisions do not regulate treatment of perpetrators as such. The European 
Network for Work with Perpetrators (WWP EN) said that most countries do not have structured 
programmes in place for perpetrators, although there are more in prison.354 Although all but one 
country (HU) reported having set up support programmes for perpetrators of VAW/DV, 
attribution cannot be made to the directives.355 Similarly, WWP EN said that the directives had 
limited relevance to their work. The measure will bring in mandatory perpetrator intervention 
and treatment programmes at the EU level, expanding the present provision of such programmes. 
WWP EN stated that at present, the Istanbul Convention is the main driver of change across the 
EU;356 the measure corresponds to Art 16 of the Istanbul Convention and will therefore expand 
provisions already existing in Member States which have ratified and implemented the Istanbul 
Convention to other Member States. 
GREVIO has called on the authorities to increase the number of available programmes for 
perpetrators of domestic violence in its baseline evaluation reports on several countries. In the 
Member States with programmes in place, description of the existing measures show that most 
target domestic violence and not all are compulsory. At present, there are mandatory programmes 
for perpetrators in seven Member States (BE, CZ, ES, LV, PL, PT, FR for those in prison, and 
HR as part of probation service), and programmes are voluntary in ten Member States (DK, EE, 
FI, IE, IT, LU, NL, RO, SE, SI). Making the programme compulsory for those sentenced for 
perpetrating gender-based violence and violence against women will therefore have the largest 
impact on prevention in these ten Member States. In its baseline evaluation reports for some 
countries (including AT, DK, FI, IT, MT, NL, PT), GREVIO also called on the authorities to 
increase the levels of attendance of perpetrator programmes for domestic violence. The 
introduction of mandatory programmes would clearly have an impact on increasing attendance 
and accordingly more effectively preventing future violence. 
Further, gender is included and considered in the present programmes in most Member States 
(AT, BE, BG, CY, DE, DK, EE, FR, IE, IT, LU, NL, RO, SE, SI), although it is not included in 
three (CZ, LV, PT) therefore the inclusion of these mandatory programmes in a gender-focused 
instrument will bring the most impact in these countries. 
The effectiveness of the programmes will depend somewhat on their content. The programmes 
would be expected to have a larger preventative effect if they are designed to encourage 
perpetrators to take responsibility for their actions, examine their attitudes and beliefs towards 
women and incorporate a gendered understanding of violence against women, as recommended 
by GREVIO. GREVIO also recommends that authorities ensure that the programmes incorporate 

354 Interview with European Network for Work with Perpetrators (WWP EN), 2 July 2021.  
355 Targeted Consultation q. 29. No response: PL, HR, LT 
356 Interview with European Network for Work with Perpetrators (WWP EN), 2 July 2021.  

151 

 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

a uniform gendered approach and deconstruction of sexist stereotypes. The programmes could 
also take an approach such as that taken in Andorra, whereby a programme is aimed at boys who 
reproduce violent patterns of behaviour to which they were exposed or of which they were direct 
victims.  
Further, details of the programmes such as their availability and format (online or in person) in 
this measure would be left as flexible to the Member States. If programmes have limited 
availability this will clearly limit participation and therefore effectiveness in preventing violence 
and abuse. If programmes are online, this would increase accessibility but may be less impactful 
than in person. The policy measure should, where possible, include some minimum standards for 
the programmes, in relation to reach, duration, elements to be covered, etc. 

The measure will ensure that sentenced perpetrators undergo programmes to reduce the likelihood 
they re-victimise the same victims, for the same reasons described above. 

GREVIO has expressed concerns that in Austria and Portugal, perpetrator programmes were 
ordered to replace prosecution, conviction or sentencing. Therefore, these programmes will be 
most effective if authorities ensure that the interplay between perpetrator programmes and 
criminal proceedings does not work against the principle of victims’ access to fair and just legal 
processes. 

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women or domestic violenceviolence against women or domestic 
violence  
Introducing mandatory perpetrator programmes will protect victims and potential victims of 
gender-based violence and violence against women as they will reduce the likelihood that 
previous perpetrators will offend again. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact of the perpetrator programmes will depend on the content of the programmes; they 
could include for example learnings on intersectionality and child victims as well. 

Perpetrators of violence against women or domestic violenceviolence against women or 
domestic violence  
The programmes will clearly impact perpetrators most directly, as they will be the attendees at the 
programmes and will therefore be less likely to engage in violence against women or domestic 
violence again. The presence of certain measures in the programmes, such as encouraging 
perpetrators to take responsibility for their actions, examine their attitudes and beliefs towards 
women and incorporating a gendered understanding of violence against women, will increase the 
effectiveness of the programmes. However, the measure will only address those sentenced for 
perpetrating gender-based violence and domestic violence, and will not consider those in the 
population who are at risk of offending. 

Wider society   
The existence and publicization of the programmes could raise awareness among the general 
population about the severity of gender based violence and violence against women, as well as the 
importance of reducing re-occurrence of violence. 

152 

 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Fundamental rights 

National authorities 
All but one country (HU) reported having set up support programmes for perpetrators of 
VAW/DV. However, the compulsoriness and inclusion of gender varies across Member States. 
Programmes are mandatory for perpetrators in seven Member States (BE, CZ, ES, LV, PL, PT, 
FR for those in prison, and HR as part of probation service), and voluntary in ten Member States 
(DK, EE, FI, IE, IT, LU, NL, RO, SE, SI). Gender is included and considered in the present 
programmes in most Member States (AT, BE, BG, CY, DE, DK, EE, FR, IE, IT, LU, NL, RO, 
SE, SI), and not included in three (CZ, LV, PT). Therefore, the scale of impact will be largest in 
those with voluntary rather than mandatory programmes, and those which do not include gender 
as a consideration. 

The measure is expected to enhance in particular the following fundamental rights. 
Victims of violence against women or domestic violenceviolence against women or domestic 
violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Right to an effective remedy and to a fair trial (Article 47) 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

Victims of sex-based harassment 

-  Right to an effective remedy and to a fair trial (Article 47) 

Perpetrators of violence against women or domestic violenceviolence against women or domestic 
violence: 

-  Right to an effective remedy and to a fair trial (Article 47) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs of the measures are expected to be borne by the EC, Member State authorities and 
support of other organisations (if running intervention and treatment programmes). More 
specifically:  
Possibly, the EC may co-fund intervention and treatment programmes, but the costs presented 
relate to public authorities.  
Public authorities will incur costs for running treatment and intervention programmes for 
perpetrators of violence against women or domestic violenceviolence against women or domestic 
violence that are shown below.  

Perpetrator intervention and treatment 
(running cost per annum) 

Max Total EU cost (Millions of euros) 

0.7 

Costs are based on the estimated costs of providing 6 sessions of 1 hour health and social worker 
support per perpetrator of violence against women or domestic violenceviolence against women 
or domestic violence. The total costs are based on the total number of convicted persons under 
sexual offences (including sexual assault and rape) and the hourly national wages of health and 
social workers. The costs assume that no Member State currently provides sufficient perpetrator 
intervention and treatment programmes. Therefore, countries that have a programme in place in 
the baseline need reach provide support to 50% more perpetrators and countries that do not have a 
programme in place need to provide support to all perpetrators. For countries with no data on 
baseline, it is assumed no programmes in place. Furthermore, costs are not estimated for five MS 
(BE, CY, EL, IE, IT) due to lack of data on number of convictions and hence, total costs might be 
higher. 

Overall assessment 

Overall, introducing perpetrator intervention and treatment programmes for those sentenced for perpetrating violence against women or domestic 
violenceviolence against women and domestic violence in a single legislative instrument specifically aimed at violence against women and 
domestic violence is expected to strengthen the implementation of relevant measures and improve their quality in many Member States, in 
particular in those which have not ratified the IC and those in which current measures are found to be lacking or insufficient in scale or scope.  
The measure will contribute to meeting three policy objectives by bringing positive changes by reducing the likelihood that perpetrators will re-
offend. It will bring benefits to victims and wider society, and will also help perpetrators to change their behaviour. However, a limitation of the 
measure is its focus on those sentenced for perpetrating gender-based violence and domestic violence, and it does not consider those in the 
population who are at risk of offending. 

153 

 
 
 
 
 
Assessment criterion 

Score 

Assessment  

The total maximum investment required amount to 0.7 Million Euros. 
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up. Notably, this measure leaves flexibility to MS as to programme availability and format, which on one hand will 
improve political acceptance, yet on the other hand may limit the effectiveness if programmes are not widely available in all Member States. 

violence against women and domestic violenceviolence against women and domestic 
violenceviolence against women and domestic violenceviolence against women and domestic violenceviolence 
against women and domestic violenceviolence against women and domestic violence 

 Problem area: protection from violence against women and domestic violence 

1.2.1. Assessment of measure 2.1.a - protection orders, emergency barring orders 

  Obligation for MS of protection orders (emergency barring orders, restraining or 

protection orders at national level of violence against women or domestic 
violenceviolence against women or domestic violence in all cases. 

  Art. 4(1)(c) VRD: information on available protection measures upon first contact 

with the authorities. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

No impact on this objective  

Protection order and emergency protection/barring orders are a crucial method to ensure victims 
of violence against women or domestic violence are effectively protected from further violence. 
The availability in law of protection orders is high and therefore the measure is unlikely to 
have a significant impact.  Mid and long-term protection orders are available in all Member 
States. Emergency protection orders, according to the 'Austrian model', are available in 18 states 
(AT, BE, BC, CZ, DE, DK, FI, HR, HU, IE, IT, LV, LU, NL, PO, RO, SI, SK). In all other 
Member States (CY, LT, EL, FR, EE, PT, ES), the laws suggest that protection orders could be 
applicable in emergency situations, yet there are many difficulties in accessing protection in 
practice.  
The obligation to have protection orders available 'in all cases' could have more impact in France 
and Portugal as protection orders are only available for victims of domestic violence, rather than 
all types of violence.  
Information about protection orders is important as victims may not be aware of the possibility 
of this measure, which can negatively impact uptake which is overall low. As the measure is the 
same as the baseline, little impact is expected. Detailed mapping is not available about if 
information is available for victims about available protection measures upon first contract with 
authorities (rather than later in the process). However, it is noted that information is not always 
available in suitable languages which may create particular challenges for migrant women and in 
cross-border cases.  
The measure however does not address some of the core challenges in accessing emergency 
protection orders such as lengthy proceedings which delay access at a critical time (for example in 
Malta, Spain and Sweden). Similarly, enforcement can be lacking, particularly because of 
insufficient sanctions for breaching protection orders. A lack of minimum standards and 
conditions also hinders mutual recognition of protection orders in cross-border cases.  

Protection orders will help victims feel protected against the perpetrator which may make them 
more willing to press charges, especially as fear of reprisal attack and further violence may be 
higher if such a step is taken. This measure may therefore increase victims’ access to justice.  

Ensuring the effective availability of 

No impact on this objective 

154 

 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective 

No impact on this objective 

If implemented, this measure is expected to have a limited extent of social impacts on the 
following groups.  

Victims of violence against women or domestic violence 
Protection orders can provide a high level of physical protection for victims of violence against 
women or domestic violence from further violence. However as there is already a high legal 
availability of protection and emergency barring orders, this measure will have limited impact. 
Information about protection orders is important for ensuring uptake but the measure is the same 
as the baseline 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The availability of protection orders to victims of all types of violence could have particular 
impact for victims of VAW that are not domestic violence related e.g. FGM, forced marriage and 
stalking.  

Perpetrators of violence against women or domestic violence  
The measure will impose legal restrictions on perpetrators. The focus of the measure is on the 
protection of the victim, rather than behavioural/attitudinal change of the perpetrator.  

Wider society   
The focus of the measure is on the victim so any impact on wider society will be indirect.  

National authorities 
There may be impact on national authorities in France and Portugal as this measure would likely 
require legal changes to make protection orders available for all victims of GBV, as well as 
potentially an increase in issuance of protection orders.  

Fundamental rights 

Victims of violence against women or domestic violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Public authorities will incur costs for providing decisions and enforcing protection orders for 
cases of violence against women or domestic violence that are shown below.  

Availability of protection orders 
(running cost per annum) 

Total EU cost (Millions of euros) 

3.3 – 22.8 

Protection order costs are based on the estimated unit costs of a protection order to the police and 
justice sector per application. The total costs are calculated by multiplying the unit costs with 
minimum and maximum estimates of the total number of applications filed. The total number of 

155 

 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

applications are estimated using an estimation of application rates and an estimated number of 
women victims of violence against women or domestic violence. Due to lack of comparable data 
on the number of women victims of violence against women or domestic violence by Member 
State, a minimum and maximum estimate of women victims of violence against women or 
domestic violence is based on FRA 2020357 survey results on percentage of women respondents 
that reported experiencing a physical incident of sexual nature and percentage of women 
respondents that reported experiencing any type of physical violence, respectively. The costs 
assume that no Member State has issued a sufficient number of protection orders for women 
victims of violence against women or domestic violence in the baseline. It is assumed that 
countries that have availability of emergency protection orders in the baseline need to issue 50% 
more PO's and countries that have partial availability need to issue 75% more PO's. Furthermore, 
costs are not calculated for two MS (IT, MT) due to lack of data to estimate the number of women 
victims of violence against women or domestic violence and therefore, costs might be higher.  

The costs for provision of information are the same as the baseline and therefore, costs are 
assumed to be zero. 

Overall assessment 

The impact of this measure will be low as availability of protection orders and emergency baring orders is already high across Member States. The 
main impact will be ensuring protection orders are available for all forms of violence, not just domestic violence, in Portugal and France. This 
could improve protection for victims of FGM, forced, marriage and stalking. Recognition of protection orders across Member States is likely to 
remain low as there are not minimum standards in place. Similarly, although information about protection orders is very important for ensuring 
uptake, the measures is the same as the baseline so limited change is expected.  
The total investment required amount to 3.3 – 22.8 Million Euros. 
The measure will probably find political acceptance as little change is required.    

1.2.2. Assessment of measure 2.1.b - protection orders, emergency barring orders 

Obligation for Member States to increase the efficiency of national emergency barring orders 
in violence against women and domestic violence cases, in particular by: 

- 

- 
- 

adopting minimum standards in relation to the issuance and conditions of national 
emergency barring orders; 
requiring them to be issued within 24 hours 
ensuring effective enforcement of the order. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

No impact on this objective 

Protection order and emergency protection/barring orders are a crucial method to ensure victims 
of GBVAW/DV are effectively protected from further violence. Mid and long-term protection 
orders are available in all Member States. Emergency protection orders, according to the 
'Austrian model', are available in 18 states (AT, BE, BG, CZ, DE, DK, FI, HR, HU, IE, IT, LV, 
LU, NL, PO, RO, SI, SK). In all other Member States (CY, LT, EL, CY, FR, EE, PT, ES), the 
laws suggest that protection orders could be applicable in emergency situations, yet there are 

357 https://fra.europa.eu/en/data-and-maps/2021/frs?mdq1=theme&mdq2=982  

156 

 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

many difficulties in accessing protection in practice.  
The obligation to have protection orders available 'in all cases' could have more impact in France 
and Portugal as protection orders are only available for victims of domestic violence, rather than 
all types of violence.  
Information about protection orders is important as victims may not be aware of the possibility 
this measure, which can impact uptake. As the measure is the same as the baseline, little impact is 
expected. Detailed mapping is not available about if information is available for victims about 
available protection measures upon first contract with authorities (rather than later in the process). 
However, it is noted that information is not always available in suitable languages which may 
create particular challenges for migrant women and cross-border cases. 
The measure addresses some of the core challenges in accessing emergency protection orders. 
Lengthy proceedings (for example in Malta, Spain and Sweden) leave victims without protection 
at a time when they are often most needed. Requiring that they are issued within 24 hours will 
significantly contribute to achieve effective physical protection for victims.  
Similarly, ensuring effective enforcement will improve the effectiveness of protection orders. 
Measures across Member States currently varies. Best practice is demonstrated in Spain, for 
example, where the system for ensuring compliance with protection orders entails monitoring of 
perpetrators through GPS tracking, as well as systematic analysis of violations of protective 
orders that is also factored into ongoing risk assessments. Enforcement will also require effective 
sanctions for breaching protection orders, which currently vary significant across member states. 
Minimum standards and conditions are important for addressing the currently low recognition 
and enforcement of foreign protection orders which Member State authorities attributed to a 
divergence of sanctions in different Member States for similar types of protection orders (NL, 
BG) and divergence among the protection measures in the EU Member States (NL, RO). 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Efficient protection orders will help victims feel protected against the perpetrator which may 
make them more willing to press charges, especially as fear of reprisal attack and further violence 
may be higher if such a step is taken. This measure may therefore increase victims’ access to 
justice.  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective 

No impact on this objective 

No impact on this objective 

If implemented, this measure is expected to have a limited extent of social impacts on the 
following groups.  

Victims of violence against women or domestic violence 
Protection orders can provide a high level of physical protection for victims of violence against 
women or domestic violence from further violence. Increasing the effectiveness and timeliness of 
the issuance of emergency protection orders will significantly increase physical protection for 
victims at a time when they are most needed. Similarly, the measure stands to improve the 
effectiveness of protection through ensuring they protection orders are enforced.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The availability of protection orders to victims of all types of violence could have particular 
impact for victims of VAW that are not domestic violence e.g. FGM, forced marriage and 
stalking.  
Similarly, challenges with mutual recognition across Member States will be better addressed 
through minimum standards and conditions which will particularly benefit victims in cross-border 

157 

 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

situations.  

Perpetrators of violence against women or domestic violence  
The measures will impose legal restrictions on perpetrators. The focus of the measure is on the 
protection of the victim, rather than behavioural/attitudinal change of the perpetrator to prevent 
future incidents.  

Wider society   
The focus of the measure is on the victim so the impacts on wider society will only be indirect.  

National authorities 
Measures will likely involve procedural and legal changes to ensure the efficiency of protection 
orders, as well as possibly training with police to enforce changes.  

Fundamental rights 

Victims of violence against women or domestic violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

In addition to the costs incurred under 2.1b, public authorities will incur additional costs to 
increase the efficiency of national protection orders in violence against women or domestic 
violence to ensure timely issuance and more effective enforcement.  

Availability of protection orders 
(running cost per annum) 

Total EU cost (Millions of euros) 

3.7 – 25.2 

It is assumed that costs under 2.1b would need to increase by 10% under this option. 

The costs for provision of information are the same as the baseline and therefore, costs are 
assumed to be zero. 

Overall assessment 

The impact of this measure will be high, especially compared to the baseline and policy option 'Istanbul light'. It addresses core issues around the 
speed with which emergency baring orders, ensuring physical protection is available when it is often most needed, the measure ensures minimum 
standards which will help address the low recognition of foreign protection orders across Member States, and better enforcement of them as 
sanctions for breaching them are currently viewed as insufficient and inconsistency in sanctions further hinder recognition of foreign protection 
orders. It also ensures protection orders are available for all forms of violence, not just domestic violence, in Portugal and France. This could 
improve protection for victims of FGM, forced, marriage and stalking in those countries.  
The total investment required amount to 3.7 – 25.2 Million Euros 
The measure may struggle to find political acceptance because of the significant changes that will be required in some Member States.   

158 

 
 
 
 
 
 
 
 
 
1.2.3. Assessment of measure 2.2.b - violence reporting and transmission of personal 

data between services 

The policy measures entail an obligation on Member States to encourage reporting 
of violence against women or domestic violenceviolence against women and 
domestic violence by witnesses and professionals. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Reporting can increase the number of perpetrators who are brought to justice and tackle impunity 
which can act as a deterrent to perpetrators and thus help prevent further violence against women 
or domestic violence. 

Reporting a crime can bring victims into contact with professionals who can provide information 
about protection available to victims which may reduce further incidents of violence.    

Reporting of crimes is crucial in ensuring effective access to justice. Rates of underreporting are, 
naturally, difficult to obtain but they are widely viewed as low. A survey conducted by FRA in 
2021 shows that most incidents of violence and harassment are not reported to the authorities; 
only 30% of incidents involving physical violence, and 11% of those involving harassment were 
reported.358 Rates of reporting of physical violence vary between countries, from 40% to 9%. It is 
important to note that these statistics are not specific to gender-based violence. Given the 
increased stigma and lack of awareness of GBV, it is likely that statistics related to such crimes 
may be even lower. Moreover, in cases of domestic violence, the close proximity of the 
perpetrator may further hinder reporting.  
An obligation on Member States to encourage witnesses and professionals would likely help to 
increase reporting. Training of professionals is also important but is not included in this measure 
which could reduce effective access to justice: the very low number of reports of cases of 
violence made by professionals indicates that this may be related to the need to improve training 
of professionals in the identification of victims of violence and of the links between intimate 
partner violence and violence against children.  

Impact may also be limited because some professionals may be hesitant to report incidents of 
violence against women or domestic violence if they think it breaches confidentiality rules in 
domestic law. EU legislation provides specific measures to remove obstacles related to 
confidentiality regarding reporting of child sexual exploitation in Article 16 of CSAMD but not 
violence against women or domestic violence more generally. As this obligation is in place under 
the Istanbul Convention, this measure could have more impact on countries who have not ratified 
it (BG, CZ, LV, LT, SK), although comprehensive mapping on implementation is not available.    

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Reporting a crime can bring victims into contact with professionals who can provide information 
about support available to victims which may increase access to support. Unlike Istanbul Plus, 
this measure does not include an obligation on witnesses and professionals to report which could 
raise issues around the provision of victim centred and gender-sensitive support services.     

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Reporting obligations would apply to witnesses and professionals in work environments so it 
could increase reporting of gender based harassment at work and thus help ensure it is effectively 
addressed.  

358 FRA (2021) ‘Crime, safety and victims’ rights: Fundamental rights survey’. 
https://fra.europa.eu/sites/default/files/fra_uploads/fra-2021-crime-safety-victims-rights_en.pdf 

159 

 
 
 
 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impacts expected. 

Victims of violence against women or domestic violence   
The measure will increase the right of victims of violence against women or domestic violence, 
including in the workplace, to access to justice, which is a fundamental right. The measures may 
also increase access to support and protection through contact with relevant professionals and 
authorities.   

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The measure might have particular impact on victims of violence against women or domestic 
violencewho currently least likely to report a crime. Such groups are often the most marginalised 
and may face intersectional discrimination, such as women living with a disability.  

Perpetrators of violence against women or domestic violence 
An increase in reporting would help ensure perpetrators are brought to justice.  

Wider society   
The measure would have an impact on wider society as member of the public and professionals 
would be encouraged to report incidents of VAW/DV. 

National authorities 
The measure may impact national authorities because of potentially increased reporting rates that 
would need to be responded to and investigated. 

Fundamental rights 

Victims of violence against women or domestic violence: 

-  Right to an effective remedy and to a fair trial (Article 47) 

Victims of sex-based harassment 

-  Right to an effective remedy and to a fair trial (Article 47) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Zero – costs to encourage reporting of violence against women or domestic violence would be 
covered in training of relevant professionals and awareness-raising campaigns 

Overall assessment 

Overall, the measure could increase reporting by members of the public and professionals. Creating on obligation specific to GBV could help focus 
efforts and increase the currently low rates of reporting of this type of crime. However, the measure does not address some of the barriers to 
reporting that mean some individuals do not understand their obligations, such as a lack of training or barriers  (perceived or real) about 
confidentiality rules.   
The total investment required amount to zero. 
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

160 

 
 
 
 
 
 
 
 
 
 
1.2.4. Assessment of measure 2.2.c - violence reporting and transmission of personal 

data between services 

  The policy measures entail an obligation on MS to ensure that confidentiality rules 
do not prevent the reporting of violence against women or domestic violence by 
witnesses and professionals to the competent services.  

  Obligation on MS to ensure that staff likely to receive complaints are trained to 

facilitate the reporting.  

  Obligation on MS to permit the transmission of personal data between law 
enforcement authorities and support services in accordance with GDPR. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Reporting can increase the number of perpetrators who are brought to justice and tackle impunity 
which can act as a deterrent to perpetrators and thus help prevent further GBVAW/DV. This 
measure takes away a further obstacle to reporting – confidentiality rules -  and adds training of 
relevant staff, thus having an even more positive effect on this objective. 

Reporting a crime can bring victims into contact with professionals who can provide information 
about protection and support available to victims, which in turn may reduce further incidents of 
violence.    

Reporting of crimes is crucial in ensuring effective access to justice. Rates of underreporting are, 
naturally, difficult to obtain but they are widely viewed as low. A survey conducted by FRA in 
2021 shows that most incidents of violence and harassment are not reported to the authorities; 
only 30% of incidents involving physical violence, and 11% of those involving harassment were 
reported.359 Rates of reporting of physical violence vary between countries, from 40% to 9%. It is 
important to note that these statistics are not specific to gender-based violence. Given the 
increased stigma and lack of awareness of violence against women or domestic violence, it is 
likely that statistics related to such crimes may be even lower. Moreover, in cases of domestic 
violence, the close proximity of the perpetrator may further hinder reporting.  

An obligation on Member States to encourage witnesses and professionals would likely 
help to increase reporting, although it would depend on the mechanisms to encourage 
reporting. Measures would need to target the general public through awareness-raising 
campaigns to increase knowledge of support and protection available, information about 
the rights of victims. Training of professionals is also important as a very low number of 
reports of cases of violence made by professionals indicates that this may be related to 
the need to improve training of professionals in the identification of victims of violence 
and of the links between intimate partner violence and violence against children. 
Ensuring confidentiality rules do not preventing third-party reporting, including training on this, 
as well as the permission to transfer personal data, will help remove barriers to reporting. This is 
important as it is often the most vulnerable who are unable to report a crime and access justice, 
such as children or victims living with a cognitive disability. Mapping is not available of whether 
Member States have measures in place to ensure ensure that confidentiality rules do not prevent 
the reporting of violence against women or domestic violence by witnesses and professionals to 
the competent services, if training is available and if there are obstacle to the transfer of personal 
data.  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 

The inclusion of actions to ensure that confidentiality rules do not prevent the reporting of 
violence against women or domestic violence by witnesses and professionals and an obligation to 
permit the transmission of personal data between law enforcement authorities and support 
services in accordance with GDPR could negatively impact the support available for victims for 

359 FRA (2021) ‘Crime, safety and victims’ rights: Fundamental rights survey’. 
https://fra.europa.eu/sites/default/files/fra_uploads/fra-2021-crime-safety-victims-rights_en.pdf 

161 

 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

and domestic violence  

certain victims (discussed below) however many more victims are likely to be able to access 
justice and receive support because of increased reporting. Similarly, the transfer of data could 
facilitate greater multi-agency cooperation and provision of more coordinated and comprehensive 
support services.  

Blanket reporting obligations may raise issues around the provision of victim-centred and gender-
sensitive support services, as has been noted in Italy, Malta, the Netherlands and Spain. Maltese 
authorities have specified that, other than in situations in which there are reasonable grounds to 
believe that a serious act of violence covered by the scope of the convention has been committed 
and further serious acts are to be expected, the obligation to report should be contingent upon the 
prior consent of the victim, unless the victim is a child or is unable to protect her/himself due to a 
disability. 

Making support contingent on reporting may restrict access to support from irregularly-staying 
migrant victims who may fear any contact with law enforcement officials because of a fear of 
deportation.  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Reporting obligations would apply to witnesses and professionals in work environments so it 
could increase reporting of gender based harassment at work and thus help ensure incidents are 
effectively addressed. 

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impacts expected. 

Victims of violence against women or domestic violence   
The measure will increase victims of violence against women or domestic violence, including in 
the workplace, access to justice, which is a fundamental right, through encouraging witnesses and 
professionals to report instances and removing obstacles related to confidentiality. Similarly, 
removing obstacle to the transmission of data could facilitate greater multi-agency cooperation 
and provision of more coordinated and comprehensive support services.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The measure might have particularly positive impact on victims of violence against women or 
domestic violence who are currently least likely to report a crime. Such groups are often the most 
marginalised or victimised / fearful of their perpetrator. Irregularly staying women victims 
however may be particularly negatively disadvantages by this measure as compulsory reporting 
may deter victims from seeking support for fear of contract with law enforcement authorities and 
ultimately deportation.   

Perpetrators of violence against women or domestic violence 
An increase in reporting would help ensure perpetrators are brought to justice.  

Wider society   
The measure would have an impact on wider society as member of the public would be 
encouraged to report incidents of VAW/DV that they witness. 

National authorities 
The measure may impact national authorities because of potentially increased reporting rates that 
would need to be responded to and investigated. 

Fundamental rights 

Victims of violence against women or domestic violence: 

-  Right to an effective remedy and to a fair trial (Article 47) 

Victims of sex-based harassment 

-  Right to an effective remedy and to a fair trial (Article 47) 

Victims of online GBV 

- 

Protection of personal data (Article 8) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

162 

 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Administrative and compliance costs 

Zero – costs to encourage reporting of violence against women or domestic violence would be 
covered in training of professionals likely to work with victims of violence against women or 
domestic violence and awareness-raising campaigns 

Overall assessment 

Overall, the measure could increase reporting by members of the public and professionals. Creating on obligation specific to GBV could help focus 
efforts and increase the currently low rates of reporting of this type of crime. The measure will increase victims of violence against women or 
domestic violence, including in the workplace, access to justice, which is a fundamental right, through encouraging witnesses and professionals to 
report instances and removing obstacles related to confidentiality. Similarly, removing obstacle to the transmission of data could facilitate greater 
multi-agency cooperation and provision of more coordinated and comprehensive support services. This will have particularly benefits to vulnerable 
victims, although irregularly staying migrants may have restricted access to services if there are blanket reporting obligations.  
The total investment required amount to zero. 
The likelihood of political acceptance is difficult to assess as mapping is not available of current measures in place and thus the changes required 
but as reporting crimes is foundational to a functioning judicial system and a fundamental right, it may be likely to find political acceptance.  

163 

 
 
 
 
 
 
1.2.5. Assessment of measure 2.3.b - special measures for the protection of children in 

the context of domestic violence 

  The policy measures involves an obligation to ensure that due account is taken of 
the rights and needs of child victims and witnesses in the provision of protection 
and  support  services,  including  an  obligation  to  provide  age-appropriate 
psychosocial counselling. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impacts expected. 

No impacts expected. 

If child victims and witnesses are protected and supported, they might be more willing to 
act as witnesses in judicial proceedings and press charges. Children’s effective 
participation in judicial proceedings is vital for improving the operation of justice, and 
European and international human rights instruments recognise the importance of their 
participation.  

Availability of age-appropriate psychosocial counselling is an important measure to help address 
the long-term harm potentially inflicted on children who witness domestic violence. The 
obligation to provide these services could have a significant impact as specific services for the 
children are not currently systematically available across Member States. In 13 Member States 
specialist support services systematically take into account the special needs of child victims and 
child witnesses of domestic violence based on a child-sensitive approach (DE, IE, NL, AT, PL, 
LV, BG, LU, DK, ES, BE, HR, IT) and eight said they do but not systematically (EE, CZ, FI, PT, 
EL, SK, RO, CY). 
The provision of services also face a range of more specific access barriers that this measure 
could address: in Austria and Finland, for example, services are provided in shelters only; in the 
Netherlands, Portugal, and Sweden, shelters support children accompanying their mothers, but 
such services are not specialised and tailored to address their specific needs; in Belgium, 
provision of services for children relies on the initiative of individual shelters, with no structural 
support from the state. Access to counselling services outside of shelters is even more limited.  
The promptness and sustainability of services can however be affected by insufficient funding 
(Austria, Finland, France, and Spain). The impact of this measure could therefore be limited if the 
services made available lack the funding needed to provide quality services.   

No impacts expected. 

No impacts expected. 

Victims of violence against women and domestic violence  
The measure has limited impact of victims of violence against women and domestic violence as 
the focus is on children who are witnesses (not direct victims).  

164 

 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The measures has a significant impact on child witnesses as it addresses gaps in the provision of 
services that are specific to children to ensure they have services that are tailored to their needs 
and psychosocial counselling that could reduce long-term harm.  

Perpetrators of violence against women and domestic violence  
No impact.  

Wider society   
No impact.  

National authorities 
The measure would impact authorities as they would be obliged to increase availability of support 
services.  

Fundamental rights 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs of the measure are expected to be borne by the EC, Member State authorities and 
support of other organisations (if providing support services to children). More specifically: 
Possibly, the EC may co-fund support services for children who witness domestic violence, but 
the costs of these are presented below and relate to public authorities.  
Public authorities will incur costs for protection and provision of support to child witnesses 
including age-appropriate psychosocial counselling as shown below.  

Minimum Total EU 
cost (Millions of euros) 

Maximum Total EU 
cost (Millions of 
euros) 

Protection and support of children 
(running cost per annum) 

599 

1,618 

Costs for protection and support to child witnesses are based on minimum and maximum 
estimates for the prevalence of child maltreatment (which includes abuse and neglect) combined 
with an estimate of the concurrence of child abuse and domestic violence to obtain an estimate of 
the number of child witnesses of domestic violence. Total cost calculations are based on the cost 
of 2-hours of health and social worker support per child witness for a period of 3-months and the 
hourly national wage of health and social workers. The costs assume that Member States do not 
provide sufficient protection and support to child witnesses in the baseline. Therefore, it is 
assumed that countries that have a programme in place need provide support to 50% more child 
witnesses and countries that have a partial programme in place need to provide support to 75% 
more child witnesses. For countries with no data on baseline, it is assumed that partial 
programmes are in place.  

Overall assessment 

Overall, this measure addresses significant gaps in services provisions. Availability of age-appropriate psychosocial counselling is an important 
measure to help address the long-term harm potentially inflicted on children who witness domestic violence and could increase their willingness to 
act as witnesses in judicial proceedings. Currently, some Member States do not systematically ensure the special needs of child victims and child 
witnesses are taken into account or only available in shelters and overall provision is low.  
The total investment required amount to 599 – 1,618 Million Euros. 
The measure may struggle to find political acceptance because significant funds will be needed to ensure that due account is taken of the rights and 
needs of child witnesses in the provision of protection and support services and to provide age-appropriate psychosocial counselling.  

1.2.6. Assessment of measure 2.3.c –special measures for the protection of children in 

the context of domestic violence 

  Obligation on Member States to ensure that, in custody and access rights matters 
in situations of domestic violence, competent authorities can ensure maintaining 

165 

 
 
 
 
 
 
 
contact  with  the child in  a surveyed safe place outside the alleged perpetrator’s 
home. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

No impact.  

The measure includes an obligation on Member State authorities to ensure maintaining contact 
with the child in a surveyed safe place outside the alleged perpetrator’s home. Supervised 
visitations are way for parents of a child to maintain contact but in an environment that is safe for 
the child and ensures the location of the child is not identifiable by the perpetrator. It is therefore 
important to effectively protect children from further violence. This measure would improve 
protection as some Member States lack the necessary resources/infrastructure to ensure safe 
supervised visitation. In France such meeting spaces are more equipped to deal with conflictual 
relationships than cases involving violence; in Malta a lack of adequate infrastructure meant that 
victims had to wait in the same waiting area as the perpetrator. There are also shortcoming in in 
regards to sufficient trained personnel for supervised visitation in Austria, Malta, and Spain. 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

If child witnesses are protected and supported, they might be more willing to act as witnesses in 
judicial proceedings and press charges. Children’s effective participation in judicial proceedings 
is vital for improving the operation of justice, and European and international human rights 
instruments recognise the importance of their participation.  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

Availability of age-appropriate psychosocial counselling is an important measure to help address 
the long-term harm potentially inflicted on children who witness or are victim of domestic 
violence. The obligation to provide these services could have a significant impact as specific 
services for the children are not currently systematically available across Member States. In 13 
Member States specialist support services systematically take into account the special needs of 
child victims and child witnesses of domestic violence based on a child-sensitive approach (DE, 
IE, NL, AT, PL, LV, BG, LU, DK, ES, BE, HR, IT) and eight said they do but not systematically 
(EE, CZ, FI, PT, EL, SK, RO, CY). 
Provision of services also face a range of more specific access barriers that this measure could 
address: in Austria and Finland services are provided in shelters only; in the Netherlands, 
Portugal, and Sweden, shelters support children accompanying their mothers, but such services 
are not specialised and tailored to address their specific needs; in Belgium, provision of services 
for children relies on the initiative of individual shelters, with no structural support from the state. 
Access to counselling services outside of shelters is even more limited.  
The promptness and sustainability of services can however be affected by insufficient funding 
(Austria, Finland, France, and Spain). The impact of this measure could therefore be limited if the 
services made available lack the funding needed to provide quality services.   

No impacts expected. 

No impacts expected. 

Victims of violence against women or domestic violence 
The measure has limited impact of victims of violence against women or domestic violence as the 
focus is on children who are witnesses (not direct victims).  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The measures has a significant impact on child witnesses as it address gaps in the provision of 
services that are specific to children and in the provision of safe spaces for maintaining parent 

166 

 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

contact with children.  

Perpetrators of violence against women or domestic violence 
The measure would enable perpetrators to main contact with their child, as applicable, but in an 
environment where further violence cannot be inflicted both during the visitation and prevents the 
identification of the location of the child.  

Wider society   
No impact.  

National authorities 
The measure would impact authorities as they would be obliged to increase availability of support 
services and safe spaces for visitations.  

Fundamental rights 

-  Respect for private and family life (Article 7) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

This policy option would incur additional costs from under 2.3b to ensure authorities maintain 
contact with the child in a surveyed safe place.  

Minimum Total EU 
cost (Millions of euros) 

Maximum Total EU 
cost (Millions of 
euros) 

Protection and support of children 
(running cost per annum) 

719 

1,942.6 

Costs for additional protection and support to child witnesses are based on minimum and 
maximum estimates for the prevalence of child maltreatment (which includes abuse and neglect) 
combined with an estimate of the concurrence of child abuse and domestic violence to obtain an 
estimate of the number of child witnesses of domestic violence. Total cost calculations are based 
on cost of 1 hour of health and social worker support (to maintain contact) per child witness for a 
period of 3-months and the hourly national wage of health and social workers in addition to costs 
estimated under 2.3b. No information is available on the availability of existing measures to 
maintain safe contact with children in the baseline and therefore, it is assumed that all Member 
States incur the additional cost. 

Overall assessment 

Overall, this measure addresses significant gaps in services provisions. Availability of age-appropriate psychosocial counselling is an important 
measure to help address the long-term harm potentially inflicted on children who witness domestic violence and could increase their willingness to 
act as witnesses in judicial proceedings. Currently, some Member States do not systematically ensure the special needs of child victims and child 
witnesses are taken into account or only available in shelters and overall provision is low. Providing a surveyed safe place outside the alleged 
perpetrator’s home could provide important protection for children from further violence. This measure would improve protection as some Member 
States lack the necessary resources/infrastructure to ensure safe supervised visitation such as France, Malta, Austria and Spain. 

The total investment required amount to 120.1 – 324.4 Million Euros. 
The measure may struggle to find political acceptance because significant funds will be needed to ensure that due account is taken of the rights and 
needs of child witnesses in the provision of protection and support services and to provide age-appropriate psychosocial counselling, and a suitable 
surveyed safe place for visitations.  

1.2.7. Assessment of measure 2.4.b - risk assessment and management 

  Obligation on MS to ensure an assessment of the lethality risk, the seriousness of 
the  situation  and  the  risk  of  repeated  violence,  is  carried  out  by  relevant 
authorities. The assessment to duly take into account if perpetrators have access 
to firearms. 

167 

 
 
 
 
 
  
 
 
 
 
Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective 

Member States are currently encouraged, but not obligated, as they would be under this policy 
measure, to conduct an individual/risk assessment of victims to identify specific protection needs. 
Currently, implementation of individual assessments is weak across Member States, hence this 
measure could increase use of individual assessments and thus individuals' protection from further 
violence. 
Individual assessment are absent in eight Member States (CZ, BE, EE, LU, MT, RO, SI and SK). 
In three Member States, protection needs are assessed only for some types of crimes, such as 
domestic violence or human trafficking (BE, SI, SK). There are also concerned, even if individual 
assessments are in place in law, they are conducted regularly and/or adequately. In Finland and 
France concerns have been raised about whether proper efforts have been made to assess the 
perpetrator’s access to firearms when carrying out risk assessments. 
Existing provisions also do not include an assessment about if the perpetrator has access to 
firearms, which, if included, could help prevent extreme harm, intimidation and potentially 
femicide. Information is not available about how widely this is currently carried out. However, in 
Finland and France concerns have been raised about whether proper efforts have been made to 
assess the perpetrator’s access to firearms when carrying out risk assessments. 

Although victims of gender based violence are specifically indicated as requiring ‘particular 
attention’ in the Victims Rights Directive, the inclusion of an individual assessment in the context 
of a single EU instrument tailored to GBV could ensure it is always carried out in a gender-
sensitive manner and tailored to the needs of victims of GBV.    

The measure does not include obligations for the enforcement authorities to conduct individual 
risk assessments and risk management in a timely manner, potentially delaying access to 
protection. 

No impact on this objective 

No impacts expected, although individual risk assessment may be done in cooperation with 
support services and facilitate access to support available.  

No impact on this objective 

No impact on this objective 

Victims of violence against women and domestic violence / Particular groups of victims 
(child victims and witnesses, victims at risk of intersectional discrimination)  
The measure will provide increase protection for victims through an individual assessment, 
especially those who are most vulnerable or at risk of future violence.   

Perpetrators of violence against women and domestic violence  
Individual assessment may lead to measures taken against the perpetrator, such as a protection 
order or removal of firearm. 

168 

 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Wider society   
No impacts expected. 

National authorities 
The measure will require some Member State authorities to implement individual assessments 
and a few Member State authorities to improve the comprehensiveness of the assessment to 
include all types of violence and a full assessment of perpetrators’ access to firearms.  

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs of the measure are expected to be borne by public authorities to ensure assessment of 
lethality risk and seriousness of the situation and risk of repeated violence.  

Total EU cost (Millions of euros) 

Risk assessment (running cost per annum) 

43.3 

Costs are based on the estimated number of women victims of physical violence that reported the 
crime to the police multiplied by the unit costs of screening for risk (i.e. completing a risk 
assessment form) and for conducting an in-depth assessment which are based on the national 
wages for police officers. Costings assume that police officers need to spend 1-hour on screening 
for risk and 2-hours for an in-depth assessment (assuming 25% of women victims qualify as high 
risk i.e. for in-depth assessment). It is further assumed that no Member States provides sufficient 
individual assessment in the baseline. For countries that that have assessment in place in the 
baseline, it is assumed that 50% more victims would need to be assessed, for countries that have a 
partial assessment in the baseline, 75% more victims would need to be assessed and for countries 
that have no assessment in place in the baseline, all victims would need to be assessed. Further, 
costs were not estimated for two countries (IT, MT) that lacked data for the estimation of number 
of women victims of physical violence and hence, costs might be higher. 

Overall assessment 

Overall, the measure will provide increase protection for victims through an individual assessment, especially those who are most vulnerable or at 
risk of future violence.  The measures will ensure individual assessments are in place in all Member States (they are currently missing eight) and 
increase the language from encouraged to ‘obligated’. It would also help improve the quality of assessment, for example that to assess the 
perpetrator’s access to firearms when carrying out risk assessments. 
The measure does not include obligations for the enforcement authorities to conduct individual risk assessments and risk management in a timely 
manner, potentially delaying access to protection. 
The total investment required amount to 43.3 Million Euros. 
The measure may struggle to find political acceptance as not all Member States carry out individual assessments and thus require legal changes. 
The measure would also obligate relevant professionals to carry out the assessment for GBV victims specifically which could significantly increase 
professional workloads.  

1.2.8. Assessment of measure 2.4.c - risk assessment and management 

  Obligation for law enforcement authorities to conduct individual risk assessments 
and risk management in a timely manner in cooperation with support services. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 

No impact on this objective 

169 

 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

Member States are currently encouraged, but not obligated, as they would be under this policy 
measure, to conduct an individual/risk assessment of victims to identify specific protection needs. 
Currently, implementation of individual assessments is weak across Member States so this 
measure could increase use of individual assessment and thus individuals' protection from further 
violence. 
Individual assessment are absent in eight countries (CZ, BE, EE, LU, MT, RO, SI and SK). In 
three countries, protection needs are assessed only for some types of crimes, such as domestic 
violence or human trafficking (BE, SI, SK). There are also concerned, even if individual 
assessments are in place in law, they are conducted regularly and/or adequately.  

Existing provisions also do not include an assessment about if the perpetrator has access to 
firearms, which, if included, could help prevent extreme harm, intimidation and potentially 
femicide. Information is not available about how widely this is currently carried out. However, in 
Finland and France concerns have been raised about whether proper efforts have been made to 
assess the perpetrator’s access to firearms when carrying out risk assessments. 

The measure further ensures effective protection by obligating law enforcement authorities to 
conduct individual risk assessment in a timely matter. This is important as individual assessments 
can identify victims in need of an emergency protection order and other protection measures 
needed in a quick timeframe that provide crucial physical protection for victims from further 
violence.  

Although victims of gender based violence are specifically indicated as requiring ‘particular 
attention’ in the Victims Rights Directive, the inclusion of an individual assessment in the context 
of a single EU instrument tailored to GBV could ensure it is always carried out in a gender-
sensitive manner and tailored to the needs of victims of GBV.    

No impact on this objective 

The measure could lead to increased access to support for victims as there is an obligation that the 
individual risk assessment is done in cooperation with support services and thus ensure they 
access the support they need during the judicial process and a coordinated approach to the 
victim’s safety. No mapping is available about whether risk assessments are done in cooperation 
with support services. 

No impact on this objective 

No impact on this objective 

Victims of violence against women and domestic violence / Particular groups of victims 
(child victims and witnesses, victims at risk of intersectional discrimination)  
The measure will provide increase protection and support for victims through an individual 
assessment, especially those who are most vulnerable or at risk of future violence.   

Perpetrators of violence against women and domestic violence  
Individual assessment may lead to measures taken against the perpetrator, such as protection 
orders or removal of firearm. 

Wider society   
No impacts expected. 

170 

 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

National authorities 
The measure will require some Member State authorities to implement individual assessments 
and a few Member State authorities to improve the comprehensiveness of the assessment to 
include all types of violence and a full assessment of perpetrators’ access to firearms.   

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

This policy measure would incur additional costs from 2.4b to ensure that individual risk 
assessments are completed in cooperation with support services. 

Total EU cost (Millions of euros) 

Risk assessment (running cost per annum) 

46.9 

Total cost calculations are on the cost of 30 minutes of police time needed to corporate with 
support services in addition to costs from 2.4b. Similar to measure 2.4b, it is assumed that no 
Member States provides sufficient individual assessment and hence, cooperation with support 
services in the baseline. For countries that that have assessment in place in the baseline, it is 
assumed that 50% more victims would need to be assessed with cooperation with support 
services, for countries that have a partial assessment in the baseline, 75% more victims would 
need to be assessed with cooperation with support services and for countries that have no 
assessment in place in the baseline, all victims would need to be assessed with cooperation with 
support services. Further, costs were not estimated for two countries (IT, MT) that lacked data for 
the estimation of number of women victims of physical violence and hence, costs might be 
higher. 

Overall assessment 

Overall, the measure will provide increase protection for victims through an individual assessment, especially those who are most vulnerable or at 
risk of future violence.  The measures will ensure individual assessments are in place in all Member States (they are currently missing in eight), 
tailored to GBV victims, and ensure professionals are not just encouraged but ‘obligated’. It would also help improve the quality of assessment, for 
example that to assess the perpetrator’s access to firearms. This measure also ensures these assessments are carried out in a timely manner which is 
crucial as this can be critical for accessing time-sensitive protection measures such as emergency barring orders.  
The total investment required amount to 46.9 Million Euros. 
The measure may struggle to find political acceptance as not all Member States carry out individual assessments and thus require legal changes. 
The measure would also obligate relevant professionals to carry out the assessment for GBV victims specifically which could significantly increase 
professional workloads 

 Problem  area:  access  to  justice  in  cases  of  violence  against  women  or  domestic 

violence 

1.3.1. Assessment of measure 3.1b – additional criminalisation 

EU-level criminalisations of certain forms of violence against women or domestic 
violence.  

Assessment criterion 

Score  Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention) 

Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 

No direct impact on this objective, although criminalisation of a type of violence may mean 
it is included in prevention activities. The impact is however low as most states have 
already criminalised these types of violence (see row 3).  

Criminalisation will increase the availability of protection measures for the specific type of 
violence. The degree to which the measure will ensure victims are effectively protected 
from (further violence) is overall low because most states have already criminalised these 

171 

 
 
 
 
 
 
 
 
 
 
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Score  Assessment  

protected from (further) violence 

types of violence (see row 3).  

Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence 

Ensuring the effective availability of 
support for victims of all forms of gender-
based violence against women and 
domestic violence  

Ensuring that gender based harassment of 
women at work is effectively addressed 

Overall, the majority Member States criminalise psychological violence, stalking, physical 
violence, sexual violence, forced marriage, FGM, forced abortion and forced sterilization. 
This means the impact of this measure across all policy objectives is low. The only form of 
violence where this is significant variation among Member States is psychological violence 
so the greatest impact would be achieved in this regard. Member States tend to vary, 
instead, in how these forms of violence are criminalised and the exact definition. Of note, 
most are criminalised in a gender-neutral manner, except for FGM, and forced marriage is 
not widely considered a form of GBV.  

Psychological violence is addressed in divergent ways in Member States: in 13 Member 
States it is a specific element of a crime in domestic violence definitions (Belgium, 
Bulgaria, Croatia, Cyprus, Greece, Lithuania, Luxembourg, Malta, Poland, Portugal, 
Romania, Spain, Slovakia), in others it through other offences such as insults, threats or 
coercion, and others as an aggravating factor.  

Stalking  is  specifically  criminalised  in  24  countries  (AT,  BE,  BG,  HR,  CZ,  EE,  FI,  FR, 
DE,  EL,  HU,  IE,  IT,  LV,  LU,  MT,  NL,  PL,  PT,  RO,  SI,  SV,  ES,  SW).  Lithuania  and 
Cyprus have other criminal law provisions that are related but not specific to stalking. Only 
Denmark has no criminal provisions applicable to stalking and has opted for non-criminal 
sanctions.  Aggregated  factors  for  stalking  and  penalties  vary  across  Member  States.  Of 
note, all definitions of stalking are gender-neutral.  

Physical  violence  is  typically  criminalised  under  a  range  of  provisions  so  is  difficult  to 
map  by  itself.  However,  in  16  countries,  offences  of  domestic  violence  allow  for  the 
crimination of physical violence (AT, BE, BG, HR, CY, CZ, HU, LT, MT, PL, PT, RO, SI, 
ES, SE).  

Sexual  violence:  Rape  is  criminalised  in  all  countries  although  the  definitions  used  to 
criminalise  rape  vary  across  Member  States,  some  focusing  on  the  lack  of  consent,  as 
recommended by human rights norms, and some relying on the element of force or threats. 
Nine  states  have  adopted  purely  consent-based  definitions  of  rape  (Belgium,  Croatia, 
Cyprus, Denmark, Germany, Ireland, Luxembourg, Malta, Sweden). Definitions of sexual 
violence  and  rape  are  consistently  gender  neutral.  Twenty-two  states  criminalise  other 
forms of sexual violence, in addition to rape (Austria, Belgium, Bulgaria, Croatia, Cyprus, 
Czechia, Denmark, Estonia, Finland, France, Germany, Hungary, Italy, Latvia, Lithuania, 
Luxembourg,  Netherlands,  Poland,  Portugal,  Romania,  Slovakia,  Sweden).  The 
differentiation between rape and other sexual offences is not consistent between states.  

Forced  marriage is criminalised in some form in all Member States.   16 have a specific 
provision  on  forced  marriage  (Austria,  Belgium,  Bulgaria,  Croatia,  Cyprus,  France, 
Germany,  Ireland,  Italy,  Luxembourg,  Malta,  Norway,  Portugal,  Slovenia,  Spain  and 
Spain).  Almost  all  countries  have  incorporated  the  definition  of  the  Istanbul  Convention. 
The crime of forced marriage is described in a gender-neutral way and is not considered as 
a form of violence against women.  

Regarding FGM, all Member States have offences dealing with bodily injury, mutilation, 
and crimes against health that are applicable to the practice of FGM and may be a basis for 
criminal prosecution. 18 Member States have a specific criminal law on FGM. At least half 
of the specific offences refer explicitly to women and girls.  

All  of  the  reviewed  parties  have  criminalised  forced  abortion.  Conversely,  forced 
sterilisation  has  been  introduced  as  a  specific  criminal  offence  only  in  France,  Malta, 
Portugal and Spain. In Belgium and Italy, forced sterilisation can be prosecuted under other 
offences such as aggravated personal injury, grievous bodily harm or assault. 

Criminalization would increase the availability of support for victims of these specific 
forms of violence, although, as criminalisation is already high, the impact on this policy 
objective will be low (see row 3).  

Criminalization would help ensure gender-based harassment of women at work is 
effectively addressed, although, as criminalisation is already high, the impact on this policy 
objective will be low (see row 3).  

Ensuring more effective governance 
structures in relation to gender-based 

No impact on this objective. 

172 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

Victims of violence against women or domestic violence/ Particular groups of victims 
(child victims and witnesses, victims at risk of intersectional discrimination)  
Criminalisation of criminalise psychological violence, stalking, physical violence, sexual 
violence, forced marriage, FGM, forced abortion and forced sterilization would have 
limited impact on victims of violence against women or domestic violence as these types of 
violence are already criminalised in nearly all Member States. The main benefit would be 
for victims of psychological violence as this is most inconsistently criminalised. 
Criminalisation could lead to more support and protection, as well as access to justice, but 
again the impact would be low as there are strong existing measures in place.  
Perpetrators of violence against women and domestic violence  
The impact on perpetrators would be limited except for perpetrators of psychological 
violence whose actions would be criminalised.   
Wider society   
No impact.  
National authorities 
A few national authorities would need to make legal amendments to criminalise all forms 
of violence, with potentially a knock-on effect to ensure protection and support is also 
available to previously unrecognised victims.  

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
- 
-  Rights of the elderly (Article 25)Right to an effective remedy and to a fair trial 

Equality between women and men (Article 23) 

Environmental impacts 

(Article 47) 

- 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

N/A  

Overall assessment 

Overall, the majority Member States criminalise psychological violence, stalking, physical violence, sexual violence, forced marriage, FGM, 
forced abortion and forced sterilization. This means the impact of this measure across all policy objectives is low. The only form of violence 
where this is significant variation among Member States is psychological violence so the greatest impact would be achieved in this regard. 
Member States tend to vary, instead, in how these forms of violence are criminalised and the exact definition. Of note, most are criminalised in a 
gender-neutral manner, except for FGM, and forced marriage is not widely considered a form of GBV.  

The total investment required is negligible there are likely to be low administrative costs to change legislation and several MS already have laws 
in place criminalising various forms of violence against women and domestic violence. 

The measure is likely to find political acceptance, as Member States overall already have the legal measures in place.  

1.3.2. Assessment of measure 3.1.c.I – additional criminalisations 

EU-level criminalisations of certain forms of violence against women and domestic 
violence.  

Additional EU-level criminalisations of certain forms of ICT-facilitated online 
violence  

Assessment criterion 

Score  Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence against 
women and domestic violence (in line 

No direct impact on this objective, although criminalisation of a type of violence may mean 
it is included in prevention activities. The impact is however low as most states have 
already criminalised these types of violence (see row 3).  

173 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

with Chapter III of the Istanbul 
Convention) 

Ensuring that victims and potential 
victims of gender-based violence against 
women and domestic violence are 
effectively protected from (further) 
violence 

Ensuring the effective access to justice 
for victims of all forms of gender-based 
violence against women and domestic 
violence 

Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

Criminalisation will increase the availability of protection measures for the specific type of 
violence. The degree to which the measure will ensure victims are effectively protected 
from (further violence) is overall low because most states have already criminalised these 
types of violence (see row 3).  
Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

Overall, the majority Member States criminalise psychological violence, stalking, physical 
violence, sexual violence, forced marriage, FGM, forced abortion and forced sterilization. 
This means the impact of this measure across all policy objectives is low, although its 
potential impact on access to justice is highest. The only form of violence where this is 
significant variation among Member States is psychological violence so the greatest impact 
would be achieved in this regard. Member States tend to vary, instead, in how these forms 
of violence are criminalised and the exact definition. Of note, most are criminalised in a 
gender-neutral manner, except for FGM, and forced marriage is not widely considered a 
form of GBV.  

Of note, most are criminalised in a gender-neutral manner, with the exception of FGM, and 
forced marriage is not widely considered a form of GBV. The framing of these forms of 
violence as types of violence against women or domestic violence, through being part of an 
EU legislative instrument on GBV, under Article 83(1) TFEU could lead to a 
reinterpretation of the meaning of these forms of violence and recognition of them as forms 
of gender discrimination.  

Psychological violence is addressed in divergent ways in Member States: in 13 Member 
States it is a specific element of a crime in domestic violence definitions (Belgium, 
Bulgaria, Croatia, Cyprus, Greece, Lithuania, Luxembourg, Malta, Poland, Portugal, 
Romania, Spain, Slovakia), in others it through other offences such as insults, threats or 
coercion, and others as an aggravating factor.  

Stalking is specifically criminalised in 24 countries (AT, BE, BG, HR, CZ, EE, FI, FR, 
DE, EL, HU, IE, IT, LV, LU, MT, NL, PL, PT, RO, SI, SV, ES, SW). Current legal 
provisions on online stalking are uncertain because it is unclear if it is included under 
existing stalking provisions. Some countries have language that could include online 
stalking such as stalking ‘by any means’ (Slovenia, Ireland, Malta, Slovakia, Estonia, 
Hungary, Bulgaria). In Italy and France the online dimension of stalking is an aggravating 
circumstance.360  

Physical violence is typically criminalised under a range of provisions so is difficult to 
map by itself. However, in 16 countries, offences of domestic violence allow for the 
crimination of physical violence (AT, BE, BG, HR, CY, CZ, HU, LT, MT, PL, PT, RO, SI, 
ES, SE).  

Sexual violence: Rape is criminalised in all countries although the definitions used to 
criminalise rape vary across Member States, some focusing on the lack of consent, as 
recommended by human rights norms, and some relying on the element of force or threats. 
Nine states have adopted purely consent-based definitions of rape (Belgium, Croatia, 
Cyprus, Denmark, Germany, Ireland, Luxembourg, Malta, Sweden). Definitions of sexual 
violence and rape are consistently gender neutral. Twenty-two states criminalise other 
forms of sexual violence, in addition to rape (Austria, Belgium, Bulgaria, Croatia, Cyprus, 
Czechia, Denmark, Estonia, Finland, France, Germany, Hungary, Italy, Latvia, Lithuania, 
Luxembourg, Netherlands, Poland, Portugal, Romania, Slovakia, Sweden). The 
differentiation between rape and other sexual offences is not consistent between states.  

Forced marriage is criminalised in some form in all Member States.  16 have a specific 
provision on forced marriage (Austria, Belgium, Bulgaria, Croatia, Cyprus, France, 
Germany, Ireland, Italy, Luxembourg, Malta, Norway, Portugal, Slovenia, Spain and 

360 EELN report.  

174 

 
 
 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score  Assessment  

Spain). Almost all countries have incorporated the definition of the Istanbul Convention. 
The crime of forced marriage is described in a gender-neutral way and is not considered as 
a form of violence against women.  

Regarding FGM, all Member States have offences dealing with bodily injury, mutilation, 
and crimes against health that are applicable to the practice of FGM and may be a basis for 
criminal prosecution. 18 Member States have a specific criminal law on FGM. At least half 
of the specific offences refer explicitly to women and girls.  

All of the reviewed parties have criminalised forced abortion. Conversely, forced 
sterilisation has been introduced as a specific criminal offence only in France, Malta, 
Portugal and Spain. In Belgium and Italy, forced sterilisation can be prosecuted under other 
offences such as aggravated personal injury, grievous bodily harm or assault. 

Ten Member States (Belgium, France, Ireland, Italy, Malta, Netherlands, Poland, Portugal, 
Spain, Sweden) have specifically criminalised the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images. Only France, 
Lithuania, Malta and Spain consider whether the offence has been committed on the 
grounds of the victim's gender as an aggravating factor. Criminalisation and inclusion of it 
as a form GBV may have more impact, compared to other criminalisations proposed in this 
measure, due to low rates of criminalisation and lack of gender-sensitivity.  

Current legal provisions on online stalking are uncertain because it is unclear if is included 
under existing stalking provisions. Some countries have language that could include online 
stalking such as stalking ‘by any means’ (Slovenia, Ireland, Malta, Slovakia, Estonia, 
Hungary, Bulgaria). In Italy and France the online dimension of stalking is an aggravating 
circumstance.  
Criminalization would increase the availability of support for victims of these specific 
forms of violence, although, as criminalisation is already high, the impact on this policy 
objective will be low (see row 3).  

Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

Criminalization would help ensure gender-based harassment of women at work is 
effectively addressed, although, as criminalisation is already high, the impact on this policy 
objective will be low (see row 3).  

Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

No impact on this objective. 

Victims of violence against women and domestic violence / Particular groups of 
victims (child victims and witnesses, victims at risk of intersectional discrimination)  

Ensuring the effective availability of 
support for victims of all forms of gender-
based violence against women and 
domestic violence  

Ensuring that gender based harassment of 
women at work is effectively addressed 

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

1.3.3. Criminalisation of most forms of violence would have 
limited  impact  on  victims  of  violence  against  women  and 
domestic violence as they are criminalised in nearly all Member 
States.  The  main  benefit  would  be  for  victims  of  psychological 
violence, 
non-consensual 
dissemination/publication/disclosure  of  intimate/private/sexual 
images 
criminalised. 
Criminalisation  would  lead  to  more  support  and  protection,  as 
well as access to justice for these victims.  

inconsistently 

is  most 

stalking 

online 

and 

this 

the 

as 

Perpetrators of violence against women and domestic violence  
The impact on perpetrators would be limited except for perpetrators of psychological 

175 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

violence, online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images whose 
actions would be criminalised.   
Wider society   
No impact.  
National authorities 
A few national authorities would need to make legal amendments to criminalise all forms 
of violence, with potentially a knock-on effect to ensure protection and support is also 
available to previously unrecognised victims.  

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
- 
-  Rights of the elderly (Article 25) 
-  Right to an effective remedy and to a fair trial (Article 47) 
- 

Equality between women and men (Article 23) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

N/A 

Overall assessment 

Overall, the majority Member States criminalise psychological violence, stalking, physical violence, sexual violence, forced marriage, FGM, 
forced abortion and forced sterilization. This means the impact of this measure across all policy objectives is low. The only form of violence 
where this is significant variation among Member States is psychological violence so the greatest impact would be achieved in this regard. Of 
note, most are criminalised in a gender-neutral manner, except for FGM, and forced marriage is not widely considered a form of GBV. The 
framing of these forms of violence as types of GBV, through being part of an EU legislative instrument on GBV, under Article 83(1) TFEU 
could lead to a reinterpretation of the meaning of these forms of violence as GBV. This could lead to much increased and stronger prosecution 
as these acts of violence are investigated and prosecuted in ways that recognise the specificity of GBV crimes.   

The total investment required is negligible there are likely to be low administrative costs to change legislation and several MS already have 
laws in place criminalising various forms of violence against women and domestic violence. 

The measure is likely to find political acceptance, as Member States overall already have the legal measures in place.  

1.3.4. Assessment of measure 3.1.c.II – additional criminalisations 

  EU-level criminalisations of certain forms of violence against women and 

domestic violence.  

  Additional EU-level criminalisations of certain forms of ICT-facilitated online 

violence  
Introduction of violence against women and domestic violence as a Eurocrime.  

 

Assessment criterion 

Score  Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence against 
women and domestic violence (in line 
with Chapter III of the Istanbul 
Convention) 

No direct impact on this objective, although criminalisation of all types of violence may 
mean it is included in prevention activities. The impact is however low as most states have 
already criminalised these types of violence (see row 3).  
Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

Ensuring that victims and potential 
victims of gender-based violence against 
women and domestic violence are 

Criminalisation will increase the availability of protection measures for the specific type of 
violence. The degree to which the measure will ensure victims are effectively protected 
from (further violence) is overall low because most states have already criminalised these 

176 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

effectively protected from (further) 
violence 

Ensuring the effective access to justice 
for victims of all forms of gender-based 
violence against women and domestic 
violence 

types of violence (see row 3).  
Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

Overall, the majority Member States criminalise psychological violence, stalking, physical 
violence, sexual violence, forced marriage, FGM, forced abortion and forced sterilization. 
This means the impact of this measure across all policy objectives is low, although its 
potential impact on access to justice is highest. The only form of violence where this is 
significant variation among Member States is psychological violence so the greatest impact 
would be achieved in this regard. Member States tend to vary, instead, in how these forms 
of violence are criminalised and the exact definition. Of note, most are criminalised in a 
gender-neutral manner, except for FGM, and forced marriage is not widely considered a 
form of GBV.  

Of note, most are criminalised in a gender-neutral manner, with the exception of FGM, and 
forced marriage is not widely considered a form of GBV. The framing of these forms of 
violence as types of GBV, through being part of an EU legislative instrument on GBV, 
under Article 83(1) TFEU could lead to a reinterpretation of the meaning of these 
forms of violence and recognition of them as forms of gender discrimination.  

Psychological violence is addressed in divergent ways in Member States: in 13 Member 
States it is a specific element of a crime in domestic violence definitions (Belgium, 
Bulgaria, Croatia, Cyprus, Greece, Lithuania, Luxembourg, Malta, Poland, Portugal, 
Romania, Spain, Slovakia), in others it through other offences such as insults, threats or 
coercion, and others as an aggravating factor.  

Stalking is specifically criminalised in 24 countries (AT, BE, BG, HR, CZ, EE, FI, 
FR, DE, EL, HU, IE, IT, LV, LU, MT, NL, PL, PT, RO, SI, SV, ES, SW). Current 
legal provisions on online stalking are uncertain because it is unclear if it 
is included under existing stalking provisions. Some countries have 
language that could include online stalking such as stalking ‘by any 
means’ (Slovenia, Ireland, Malta, Slovakia, Estonia, Hungary, Bulgaria). 
In Italy and France the online dimension of stalking is an aggravating 
circumstance.361  

Physical violence is typically criminalised under a range of provisions so is 
difficult to map by itself. However, in 16 countries, offences of domestic violence 
allow for the crimination of physical violence (AT, BE, BG, HR, CY, CZ, HU, LT, 
MT, PL, PT, RO, SI, ES, SE).  

Sexual violence: Rape is criminalised in all countries although the definitions 
used to criminalise rape vary across Member States, some focusing on the lack of 
consent, as recommended by human rights norms, and some relying on the 
element of force or threats. Nine states have adopted purely consent-based 
definitions of rape (Belgium, Croatia, Cyprus, Denmark, Germany, Ireland, 
Luxembourg, Malta, Sweden). Definitions of sexual violence and rape are 
consistently gender neutral. Twenty-two states criminalise other forms of sexual 
violence, in addition to rape (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, 
Denmark, Estonia, Finland, France, Germany, Hungary, Italy, Latvia, Lithuania, 
Luxembourg, Netherlands, Poland, Portugal, Romania, Slovakia, Sweden). The 
differentiation between rape and other sexual offences is not consistent between 
states.  

Forced marriage is criminalised in some form in all Member States.  16 have a 
specific provision on forced marriage (Austria, Belgium, Bulgaria, Croatia, Cyprus, 
France, Germany, Ireland, Italy, Luxembourg, Malta, Norway, Portugal, Slovenia, 
Spain and Spain). Almost all countries have incorporated the definition of the 
Istanbul Convention. The crime of forced marriage is described in a gender-neutral 
way and is not considered as a form of violence against women.  

361 EELN report.  

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Assessment criterion 

Score  Assessment  

Regarding FGM, all Member States have offences dealing with bodily injury, 
mutilation, and crimes against health that are applicable to the practice of FGM 
and may be a basis for criminal prosecution. 18 Member States have a specific 
criminal law on FGM. At least half of the specific offences refer explicitly to women 
and girls.  

All of the reviewed parties have criminalised forced abortion. Conversely, forced 
sterilisation has been introduced as a specific criminal offence only in France, 
Malta, Portugal and Spain. In Belgium and Italy, forced sterilisation can be 
prosecuted under other offences such as aggravated personal injury, grievous 
bodily harm or assault. 

Ten Member States (Belgium, France, Ireland, Italy, Malta, Netherlands, Poland, Portugal, 
Spain, Sweden) have specifically criminalised the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images. Only France, 
Lithuania, Malta and Spain consider whether the offence has been committed on the 
grounds of the victim's gender as an aggravating factor. Criminalisation and inclusion of it 
as a form GBV may have more impact, compared to other criminalisations proposed in this 
measure, due to low rates of criminalisation and lack of gender-sensitivity.  

Current legal provisions on online stalking are uncertain because it is unclear if is included 
under existing stalking provisions. Some countries have language that could include online 
stalking such as stalking ‘by any means’ (Slovenia, Ireland, Malta, Slovakia, Estonia, 
Hungary, Bulgaria). In Italy and France the online dimension of stalking is an aggravating 
circumstance.  
Criminalization would increase the availability of support for victims of these specific 
forms of violence, although, as criminalisation is already high, the impact on this policy 
objective will be low (see row 3).  

Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

Criminalization would help ensure gender-based harassment of women at work is 
effectively addressed, although, as criminalisation is already high, the impact on this policy 
objective will be low (see row 3).  

Criminalisation of online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images could have more 
impact as criminalisation is lower across Member States (see row 3).  

No impact on this objective. 

Victims of violence against women and domestic violence / Particular groups of 
victims (child victims and witnesses, victims at risk of intersectional discrimination)  
Criminalisation of most forms of violence would have limited impact on victims of 
violence against women and domestic violence as they are criminalised in nearly all 
Member States. The main benefit would be for victims of psychological violence, online 
stalking and the non-consensual dissemination/publication/disclosure of 
intimate/private/sexual images as this is most inconsistently criminalised. Criminalisation 
would lead to more support and protection, as well as access to justice for these victims.  
Perpetrators of violence against women and domestic violence  
The impact on perpetrators would be limited except for perpetrators of psychological 
violence, online stalking and the non-consensual 
dissemination/publication/disclosure of intimate/private/sexual images whose 
actions would be criminalised.   
Wider society   
No impact.  
National authorities 
A few national authorities would need to make legal amendments to criminalise all forms 
of violence, with potentially a knock-on effect to ensure protection and support is also 
available to previously unrecognised victims.  

Ensuring the effective availability of 
support for victims of all forms of gender-
based violence against women and 
domestic violence  

Ensuring that gender based harassment of 
women at work is effectively addressed 

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

Fundamental rights 

Victims of violence against women and domestic violence: 

178 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
- 
-  Rights of the elderly (Article 25) 
-  Right to an effective remedy and to a fair trial (Article 47) 
- 

Equality between women and men (Article 23) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

N/A 

Overall assessment 

Overall, the majority Member States criminalise psychological violence, stalking, physical violence, sexual violence, forced marriage, FGM, 
forced abortion and forced sterilization. This means the impact of this measure across all policy objectives is low. The only form of violence 
where this is significant variation among Member States is psychological violence so the greatest impact would be achieved in this regard. Of 
note, most are criminalised in a gender-neutral manner, except for FGM, and forced marriage is not widely considered a form of GBV. The 
framing of these forms of violence as types of GBV, through being part of an EU legislative instrument on GBV, under Article 83(1) TFEU 
could lead to a reinterpretation of the meaning of these forms of violence as GBV. This could lead to much increased and stronger prosecution 
as these acts of violence are investigated and prosecuted in ways that recognise the specificity of GBV crimes.   

The total investment required is negligible there are likely to be low administrative costs to change legislation and several MS already have 
laws in place criminalising various forms of violence against women and domestic violence. 

The measure is likely to find political acceptance, as Member States overall already have the legal measures in place.  

1.3.5. Assessment  of  measure  3.2.b  -  measures  against  gender-based  cyber  violence 

against women 

Same as the baseline. 

1.3.6. Assessment  of  measure  3.2.c  -  measures  against  gender-based  cyber  violence 

against women 

Encourage/oblige member states to allow online/other low-threshold reporting of incidents of 
online violence against women to national law enforcement or other authorities. 

In an increase in reporting, if it leads to prosecution and ultimately ending impunity, could 
act as deterrence to potential perpetrators and thus prevent further incidents.  

Assessment criterion  
Score   Assessment   
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the Istanbul 
Convention)  
Ensuring that victims and potential 
victims of gender-based violence against 
women and domestic violence are 
effectively protected from (further) 
violence  
Ensuring the effective access to justice 
for victims of all forms of gender-based 
violence against women and domestic 
violence  

No impact on this objective   

Overall, as reporting of online violence against women is low, even compared to other 
forms of VAW, low-threshold reporting options – that make is easier for victims to report 
crimes – would likely help overcome barriers rooted in the perception that the process is 
difficult. This would help ensure effective access to justice for victims.  

The extent of the impact would however depend on how reports are responded to and 
prosecuted. The measure’s impact may be limited if prosecutors are not clear how the law 
applies to online crimes and if investigation is not tailored to the specificities on online 
crime and frequently cross-border nature.  

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Reporting of measures across forms of online violence is low, often as an extension of the 
same challenges offline. These challenges include the tendency for victims to believe their 
experiences will not be taken seriously by law enforcement. The fact that law enforcement 
often does not have the tools or training to properly handle such cases can worsen these 
problems. Fear of stigma, shame and victim-blaming, embedded in wider societal norms, 
further deter women from reporting. An additional factor is the absence of a legal 
definition covering gender-based online violence in all EU Member States. This leads to 
incidents not being possible to investigate and prosecute. A number of cases in which 
victims do report to social media platforms or law enforcement, only a small percentage 
are pursued, sometimes perceived to be because authorities do not understand the severity 
of harm caused by online violence. Low reporting rates can be also due in part to a lack of 
awareness among victims that their experiences qualify as violence and is a crime.   

No impact on this objective  

No impact on this objective  

No impact on this objective  

Victims of violence against women and domestic violence  / Particular groups of 
victims (child victims and witnesses, victims at risk of intersectional discrimination)   
The measure would have an impact on victims of online violence against women. It would 
reduce barriers to reporting and improve access to justice for victims. There would be a 
significant impact as current reporting is very low.  
Perpetrators of violence against women and domestic violence   
The measure would ensure more perpetrators are brought to justice. This would address a 
high level of impunity for perpetrators operating online, as it often enables individuals to 
act with perceived anonymity.  

Wider society    
No impact.  

National authorities  
 The measure would likely increase reporting and thus increased number of cases to be 
handled by authorities.   
Victims of violence against women and domestic violence:  

  Right to an effective remedy and to a fair trial (Article 47)  

No impacts expected.  

The costs of the measure are expected to be borne by public authorities to assess reports of 
illegal gender-based content online. 

Measures against illegal gender-based 
content online (running cost per annum) 

Total EU cost (Millions of euros) 

326.5 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence   
Ensuring that gender based harassment 
of women at work is effectively 
addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  
Effectiveness – other impacts  
Social impacts  

Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

Costs are based on the estimated number of women victims of online violence that report 
the incident to an online platform and the number of police officers required to assess the 
reports. Total costs are calculated by multiplying the number of police officers required to 
assess reports of illegal gender-based content online and the hourly national wage of police 
officers. No information is available on Member States that allow online/other low 
threshold reporting of incidents of OVAW in the baseline and therefore it assumed that all 
Member States would incur costs to assess reports.  

Overall assessment  
Overall, the measure could have a significant impact on the online sphere which is increasingly embedded in all women’s personal and 

180 

 
 
 
 
  
  
  
  
 
 
  
  
  
 
 
professional lives. Currently, levels of reporting are low and perpetrators often act knowing they can do so with anonymity and impunity. 
Reporting is very low because some victims do not know the violence inflicted is a crime and, like crimes committed offline, fear victim-
blaming and stigma if they report the crime to authorities. The measure’s impact may however be limited if prosecutors are not clear how the 
law applies to online crimes and if investigation is not tailored to the specificities on online crime, for example its frequent cross-border 
element.  

The total investment required amount to 326.5 Million Euros.  

The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have 
to significantly scale them up.   

1.3.7. Assessment of measure 3.4.b - victim compensation   

  Obligation for judges and prosecutors to inform victims of violence against 

women and domestic violence about the possibility to request compensation from 
the perpetrator and the steps needed.  

  Obligation for MS to ensure access to state compensation to those who have 

sustained serious bodily injury or impairment of health when the damage is not 
covered by other sources. 

  Obligation for MS to provide victims of violence against women and domestic 

violence with a right to a compensation decision in a reasonable time. 

No impact on this objective   

No impact on this objective   

Assessment criterion  
Score   Assessment   
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the Istanbul 
Convention)  
Ensuring that victims and potential 
victims of gender-based violence against 
women and domestic violence are 
effectively protected from (further) 
violence  
Ensuring the effective access to justice 
for victims of all forms of gender-based 
violence against women and domestic 
violence  

Information: Member States use various way to provide information to victims about 
compensation. The most common way is for victims to be informed by the police (orally 
and by leaflets), or they are informed via information online. An online application form 
for compensation is now available in 17 Member States (AT, BE, BG, CY, CZ, DE, EL, 
ES, FI, FR, HR, HU, IE, NL, PT, SE, SK). However, it is widely noted by stakeholders 
that victims often do not obtain information about how to claim compensation and, if 
they do, it is from victims support organisations. Information provided by judges and 
prosecutors would help ensure women access the information.  

Access: Victims of crime can claim compensation from the perpetrator in all states. 
State-funded compensation is not widely available in the EU. In 21 states, in line with 
Council Directive 2004/80/EC, (BE, BG, HR, CZ, DE, EE, FI, EL, IE, IT, LV, LT, LU, 
MT, NL, PL, PT, RO, SI, SK, SE) state compensation is in most cases provided only to 
victims of violent crimes. In 11 Member States (BE, CZ, DE, HU, LU, MT, NL, PL, PT 
RO, ES) it is also available if victims have sustained serious bodily injury or impairment 
of health. In the majority of states, state-funded compensation is available subsidiarily, 
thus only when the victim cannot procure payment from the perpetrator, either because 
they have not been identified, cannot afford the compensation, or compensation was 
denied in the criminal or civil proceedings.  

Time: The time taken to receive compensation is widely seen as ‘long and difficult’. 
Victims often receive their compensation several years after the crime was committed. In 
some Member States, there are no concrete deadlines to be compensated and, when there 
are deadlines, they are not always respected. Only a few cases are closed and 
compensated in a state compensation scheme within the first 12 months and 50% after 24 
months. The measure may be limited in impact without clear definitions of ‘timely’ or 
deadlines.  
The measure may provide complementary to support services who often provide 

181 

Ensuring the effective availability of 

 
 
 
  
 
 
 
  
  
  
 
 
  
support for victims of all forms of 
gender-based violence against women 
and domestic violence   
Ensuring that gender based harassment 
of women at work is effectively 
addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  
Effectiveness – other impacts  
Social impacts  

Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

information to victims about access to information.  

No impact on this objective  

No impact on this objective  

Victims of violence against women and domestic violence   
The measure could have a significant impact on victims as many do not currently obtain 
compensation. Compensation is part of their right to access effective remedy, recognition 
of the harm they have suffered and may help victims obtain the economic resources they 
need to move forward. Obligating judges and prosecutors to inform victims about their 
rights would help victims to access compensation, ensure it is available for serious 
bodily injury or impairment of health (which is only available in 11 Member States) and 
in a more timely manner.   
Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   
No impact on particular groups. 
Perpetrators of violence against women and domestic violence   
More perpetrators may be expected to pay compensation to their victims, including 
because state compensation is only available subsidiarily if a perpetrator is unable to pay. 
Wider society 
No impact.     
National authorities  
National authorities may have to handle more compensation cases, instil measures to 
handle them more quickly, and pay compensation.  
Victims of violence against women and domestic violence:  

  Right to an effective remedy and to a fair trial (Article 47)  

No impacts expected.  

The costs of the measures are expected to be borne Member State authorities or 
individual perpetrators (if compensation is paid by the perpetrator). Public authorities or 
individual perpetrators will incur costs due to the provision of compensation to women 
victims that have sustained serous bodily injury or impairment.  
The costs provided below are for public authorities, assuming compensation is provided 
by the state. 

Minimum Total EU 
cost (Millions of 
euros) 

Maximum Total EU 
cost (Millions of 
euros) 

Compensation to women 
victims (costs per annum)  

Baseline 

Baseline 

Costs for compensation to women victims are based on minimum and maximum 
estimates for the average amount of state compensation awarded to women victims 
physical violence (which is broader than violence against women and domestic violence 
victims) that apply for compensation. The estimated number of women victims of 
physical violence is used as an estimate of the number of victims of bodily injury or 
impairment of health due to lack of data on the latter. The total costs are calculated by 
multiplying the total number of women victims of physical violence with the proportion 
of women victims that apply for state compensation with the estimates for average state 
compensation awarded. It is assumed that no Member States provides access to 
compensation to all women victims. Countries that have state compensation for violent 
crimes in the baseline would need to pay 50% more victims and countries that do not 
have state compensation for violent crimes would need to pay all victims. For countries 
with no information available on the baseline, it is assumed that no compensation is 
available for violence crime and therefore, all victims would need to be paid. Further, 
costs are not estimated for 2 MS (IT, MT) with missing information on the number of 
women victims of physical violence and therefore, costs might be higher. 
Little to zero costs are incurred to inform victims of violence against women and 
domestic violence about the possibility to request compensation from the perpetrator and 

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to reach a decision in a reasonable time. 

Overall assessment  
Overall, the measure could have a significant impact on victims and their access to justice and effective remedy. Victims have a right to 
compensation but this often is not realised in cases of VAW/DV. The measures will make significant changes to ensure compensation is 
available to victims through providing information, which is currently a major barrier, make sure it is available from the state, as 
perpetrators often cannot or do not pay, and make sure it is available in a timely manner, as current timeframes are very long.  
The total investment required amount to 769 – 6,353 Million Euros. 
The measure may struggle to find political acceptance because it could result in major changes and costs to the state in terms of 
implementing the obligation on judges and prosecutors to provide information, pay compensation subsidiary, and changes to the judicial 
process to ensure compensation is paid in a timely manner.  

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1.3.8. Assessment of measure 3.4.c - victim compensation   

  Obligation  for  judges  and  prosecutors  to  inform  victims  of  violence  against 
women and domestic violence about the possibility to request compensation from 
the perpetrator and the steps needed.  

  Right  to  meaningful  compensation  for  violence  against  women  or  domestic 

violence victims in criminal proceedings in line with CJEU C-129/19 

  Art.  30  IC:  Obligation  for  MS  to  ensure  access  to  state  compensation  to  those 
who have sustained serious bodily injury or impairment of health, or impairment 
of health, when the damage is not covered by other sources.  

  Obligation  for  MS  to  provide  victims  of  violence  against  women  and  domestic 

violence with a right to a compensation decision in a reasonable time. 

No impact on this objective   

No impact on this objective   

Score   Assessment   
Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the Istanbul 
Convention)  
Ensuring that victims and potential 
victims of gender-based violence against 
women and domestic violence are 
effectively protected from (further) 
violence  
Ensuring the effective access to justice 
for victims of all forms of gender-based 
violence against women and domestic 
violence  

Information: Member States use various way to provide information to victims about 
compensation. The most common way is for victims to be informed by the police (orally 
and by leaflets), or they are informed via information online. An online application form 
for compensation is now available in 17 Member States (AT, BE, BG, CY, CZ, DE, EL, 
ES, FI, FR, HR, HU, IE, NL, PT, SE, SK). However, it is widely noted by stakeholders 
that victims often do not obtain information about how to claim compensation and, if 
they do, it is from victims support organisations. Information provided by judges and 
prosecutors would help ensure women access the information.  

Access: Victims of crime can claim compensation from the perpetrator in all states. 
State-funded compensation is not widely available in the EU. In 21 states, in line with 
Council Directive 2004/80/EC, (BE, BG, HR, CZ, DE, EE, FI, EL, IE, IT, LV, LT, LU, 
MT, NL, PL, PT, RO, SI, SK, SE) state compensation is in most cases provided only to 
victims of violent crimes. In 11 Member States (BE, CZ, DE, HU, LU, MT, NL, PL, PT 
RO, ES) it is also available if victims have sustained serious bodily injury or impairment 
of health. In the majority of states, state-funded compensation is available subsidiarily, 
thus only when the victim cannot procure payment from the perpetrator, either because 
they have not been identified, cannot afford the compensation, or compensation was 
denied in the criminal or civil proceedings.  

Time: The time taken to receive compensation is widely seen as ‘long and difficult’. 
Victims often receive their compensation several years after the crime was committed. In 
some Member States, there are no concrete deadlines to be compensated and, when there 
are deadlines, they are not always respected. Only a few cases are closed and 
compensated in a state compensation scheme within the first 12 months and 50% after 24 
months. The measure may be limited in impact without clear definitions of ‘timely’ or 
deadlines.   

Meaningful compensation: The amount of compensation attributed in gender-based 
violence cases is often very low.  For example, in Spain, the average compensation is 
around €150. CJEU in C-129/19 doubted that the fixed rate of €4800 for a case of sexual 
violence in Italy was “not manifestly insufficient,” because “sexual violence…gives rise 
to the most serious consequences of violent intentional crime”. Low compensation rates 
can be particularly damaging for victims of domestic violence which can often occur in 
situations of economic dependence and because it signals to the public and the victim 
that such crimes are not viewed as having serious consequences to the victim.  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 

The measure may provide complementary to support services who often provide 
information to victims about access to information.  

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and domestic violence   
Ensuring that gender based harassment 
of women at work is effectively 
addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  
Effectiveness – other impacts  
Social impacts  

Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

No impact on this objective  

No impact on this objective  

Victims of violence against women and domestic violence   
The measure could have a significant impact on victims as many do not currently obtain 
compensation. Compensation is part of their right to access effective remedy, recognition 
of the harm they have suffered and may help victims obtain the economic resources they 
need to move forward. Obligating judges and prosecutors to inform victims about their 
rights would help victims to access meaningful compensation, ensure it is available for 
serious bodily injury or impairment of health (which is only available in 11 Member 
States) and in a more timely manner.   
Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   
No impact on particular groups. 
Perpetrators of violence against women and domestic violence   
More perpetrators may be expected to pay compensation to their victims, including 
because state compensation is only available subsidiarily if a perpetrator is unable to pay. 
Wider society 
No impact.     
National authorities  
National authorities may have to handle more compensation cases, instil measures to 
handle them more quickly, and pay more, and higher amounts, of compensation.  
Victims of violence against women and domestic violence:  

  Right to an effective remedy and to a fair trial (Article 47)  

No impacts expected.  

This policy measure would incur additional costs from 3.4b to ensure meaningful 
compensation for violence against women and domestic violence victims. 

Compensation to women 
victims (costs per annum)  

Total Min EU cost 
(Millions of euros) 

Total Max EU cost 
(Millions of euros) 

1,569.1 

1,569.1 

Costs for compensation to women victims are based on estimated number of women 
victims of sexual violence that apply for compensation and the maximum estimate for 
the average amount of state compensation of EUR 35,000. Due to lack of available 
information on women victims of violence against women and domestic violence, the 
estimated number of women victims of sexual violence is used instead.  
The total costs are calculated based on the number of women victims of sexual violence 
that again access to state compensation in addition to women victims of physical 
violence (3.4b). It is assumed that no Member States provide meaningful compensation 
specifically to women victims of sexual violence in the baseline and hence, all Member 
States incur costs.  

Overall assessment  
Overall, the measure could have a significant impact on victims and their access to justice and effective remedy. Victims have a right to 
compensation but this often is not realised in cases of VAW/DV. The measures will make significant changes to ensure meaningful levels 
of compensation are available to victims through providing information, which is currently a major barrier, make sure it is available from 
the state, as perpetrators often cannot or do not pay, and make sure it is available in a timely manner, as current timeframes are very long.  

The total investment required amount to 1,569.1 Million Euros. 

The measure may struggle to find political acceptance because it could result in major changes and costs to the state in terms of 
implementing the obligation on judges and prosecutors to provide information, pay compensation subsidiary, including at potentially 
higher amounts, and changes to the judicial process to ensure compensation is paid in a timely manner  

185 

 
  
  
  
  
 
  
  
 
 
 
 
 
1.3.9. violence  against  women  and  domestic  violenceAssessment  of  measure  3.6.b  - 

national coordination   

Same as baseline.  

1.3.10. Assessment of measure 3.6.c - national coordination   

  Legal standing to equality bodies to assist and represent victims of violence against 

women and domestic violence, including online violence against women. 

  Obligation for MS to ensure equality bodies are mandated to provide information and 
conduct awareness raising on violence against women and domestic violence/OVAW. 

Information and awareness-raising measures could focus, for example, on challenging 
negative gender stereotypes which could act as a preventative measure.   

Score   Assessment   
Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the Istanbul 
Convention)  
Ensuring that victims and potential 
victims of gender-based violence against 
women and domestic violence are 
effectively protected from (further) 
violence  
Ensuring the effective access to justice 
for victims of all forms of gender-based 
violence against women and domestic 
violence  

No impact on this objective   

Only six equality bodies have the capacity to receive gender-based violence related 
complaints (AT, BE, EE, IT, PT, SL). 19 Member States report that national equality 
bodies can receive claims of sexual harassment and harassment based on sex (BE, BG, 
HR, CY, DK, EE, FR, DE, EL, IE, LT, MT, NL, PL, PT, RO, SI, SK, SE).  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence   
Ensuring that gender based harassment 
of women at work is effectively 
addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  
Effectiveness – other impacts  
Social impacts  

Equality bodies currently provide information and support and carry out awareness 
raising on GBV, focusing on discrimination and sexual harassment in the workplace, for 
example through webpages, written materials, training, guidance and targeted 
campaigns. There is however no obligation on Member States to ensure that equality 
bodies to provide information and conduct awareness raising on violence against women 
and domestic violence. This measure will likely contribute to systematising efforts which 
are currently ad hoc and varied across Member States.   
Equality bodies as part of assisting and representing victims of violence against women 
and domestic violence would provide support to victims through legal proceedings. 
Information can also help victims access support.   

The equality directives set out provisions on the role of equality bodies in combatting 
sex-based discrimination, including harassment. They therefore have a core role in 
ensuring that gender based harassment of women at work is effectively addressed. This 
measure would ensure they can support victims of all forms of gender-based violence.  
No impact on this objective  

Victims of violence against women and domestic violence   
Victims in 21 Member States would have the option to be assisted and represented by 
equality bodies, where previously this was unavailable. Victims would receive 
information with more consistency about support available. 

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   
Victims of gender based harassment at work would be particularly supported by this 
measure.  

Perpetrators of violence against women and domestic violence   
No specific measures target perpetrators, although awareness raising campaigns may 
change the behaviour or attitude of potential perpetrators.  

186 

 
 
 
 
  
  
  
 
  
  
  
  
 
 
 
Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

Wider society    
Wider society could be impacted by awareness-raising campaigns.  

National authorities  
National authorities would be obliged to ensure equality bodies are mandated to provide 
information and conduct awareness raising on violence against women and domestic 
violence/OVAW. This would have an impact in 21 Member States where this is not 
currently the case.  
Victims of violence against women and domestic violence:  

  Right to an effective remedy and to a fair trial (Article 47)  

No impacts expected.  

Public authorities will incur costs to hire additional staff in equality bodies to assist and 
represent victims of violence against women and domestic violence.   

Equality bodies (running cost per 
annum) 

Total EU cost (Millions of euros) 

2.0 

Costs are based on the number of additional FTE's needed in equality bodies to assist and 
represent victims of violence against women and domestic violence and their national 
mean annual earnings. It is assumed that there are no costs for Member States where 
equality bodies already have a legal standing to receive complaints and to receive claims 
of sexual harassment in the baseline. For countries where either equality bodies cannot 
receive GBV complaints or receive claims of harassment, it is assumed that an additional 
2 FTEs are needed. For countries (SI) with no information available on the baseline, it is 
assumed no legal standing is in place and hence, an additional 2 FTEs would be needed. 

Overall assessment  
Overall, this measure would mean victims in 21 Member States would have the option to be assisted and represented by equality bodies, 
where previously this was unavailable. This would greatly strengthen their access to justice and effective remedy. Victims would receive 
information with more consistency about support available, further enforcing their ability to access justice and the support needed.  

The total investment required amount to 2.0 Million Euros. 

The measure may struggle to find political acceptance as it would involve significant changes in most Member States. 

 Problem area: support to violence against women and domestic violence victims 

1.4.1. Assessment of measure 4.1.b - support to violence against women and domestic 

violence victims 

■  Obligation on MS to ensure availability and adequate resourcing of general 

support services.  

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 

No impact on this objective. 

187 

 
 
  
 
  
  
 
 
 
 
  
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

No impact on this objective. 

The measure is focused on providing support to victims rather than legal recourse, however a 
consideration which should be taken into account is that access to services should not be 
dependent on a victim’s willingness to press charges or testify against the perpetrator. For 
example, in some parts of Spain, women’s access to domestic violence shelters will depend on 
official recognition of her as a victim of intimate partner violence, with women’s access barred to 
such shelters where protection orders are denied. This rooted practice may determine women’s 
decisions to seek support from these services, affecting their rights to receive protection and 
support regardless of her willingness to press charges. For this reason, GREVIO strongly 
encouraged the authorities to develop, within and/or in addition to state-run services, alternative, 
low threshold specialist support services acting in the interest of victims and giving them the 
choice to decide whether or not to press charges against the perpetrator. This will favour access 
to justice, as it will support victims through support services so that they are encouraged to seek 
justice and participate in the proceedings on their own terms. 

The measure will oblige Member States to ensure general support services are available to victims 
of gender-based violence and domestic violence, including an obligation to ensure access to 
general health care and social services.  
At present, Art. 8(1) of the Victims Rights Directive requires access to general victim support 
services (confidential, free of charge, acting in the interest of the victim) for all victims of all 
crime. 23 Member States who responded to the targeted consultation stated that support services 
(general or specialised) are available to victims of gender-based and domestic violence. 64% of 
all respondents to the public consultation believe that support services are available to victims of 
gender-based and domestic violence, and among respondents from Germany and Italy, the 
proportion is higher at over 82%.362  
However, 50% of respondents to the public consultation do not believe that general support 
services systematically take into account the needs of victims of VAW/DV in their Member 
State.363 The measure will address this as inclusion of this measure in an instrument specific to 
gender-based violence will emphasise the importance of making these services available to and 
considerate of such victims. 
GREVIO noted that many general support services have insufficient funding and/or human 
resources; this measure will require that general services are adequately resourced in order to 
reach and support as many victims as possible. 
In terms of referrals, all 24 Member States who responded stated that that general support services 
refer victims to appropriate specialist services. And all but one (EL) said that law enforcement 
authorities ‘can do’ (11) or ‘have to’ (12) inform a support service of cases of VAW/DV, 
although this discretion may be leading to gaps as professionals of ‘an overall lack of knowledge 
among professionals about the different services victims need contact with’.364 In some baseline 
reports (including for BE and IT), GREVIO identified issues with regard to the training of the 
relevant professionals that are directly involved in the provision of social services in relation to 
the gendered dynamics of violence. GREVIO also noted issues with training of professionals in 
the health sector, for example, in the reports on Finland and Spain. Lack of such training hinders 
their ability to properly address victims’ needs and support them. Another benefit of the measure 
will be it will require that professionals are trained to assist victims and refer them to the 
appropriate services. However, a limitation of the measure is that it will not provide guidelines to 
relevant health care and social services professionals, for example on how to identify and refer 
victims to support services.  
GREVIO has further noted that tailored support is lacking for groups including ethnic minorities 

362 Public consultation q.21. 
363 Public consultation q.23. 
364 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 57. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 

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Assessment criterion 

Score 

Assessment  

(such as Sami and Roma women), migrant women, and women with disabilities, as these women 
experience cultural, language or other barriers when turning to social and health care services. 
GREVIO recommended that parties ensure that service provision pay particular attention to the 
needs of women victims who are or may be exposed to intersectional discrimination. The extent 
to which this issue will be addressed by this measure will depend on the content of the training. 

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of general support to victims of violence against 
women and domestic violence, as when they access general services such as general health care 
and social services, the services will be adequately resourced and the professionals they interact 
with will be trained to assist victims and refer them to the appropriate services. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on ethnic minorities (such as Sami and Roma women), migrant women, and women 
with disabilities will depend on the content of the professionals’ training. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
Professionals working in general support services such as health and social care will receive 
training to help them assist victims and refer them to the appropriate services. This will raise 
awareness among such professionals. 

National authorities 
The Victims Rights Directive requires access to general victim support services for all victims of 
all crime, and nearly all Member States reported that support services are available to victims of 
gender-based and domestic violence. However, the measure is still expected to have an impact, as 
sufficient training and funding will need to be provided. The measure is likely to find political 
acceptance, as Member States overall already have similar activities in place, although some may 
have to significantly scale them up.  

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Rights to social assistance and health care (Article 34 and 35) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

N/A  

Overall assessment 

Overall, introducing a legal obligation for ensuring general support services such as health and social services are available to victims of gender-
based violence and domestic violence and ensuring such services are resourced and trained in a single legislative instrument specifically aimed at 
violence against women and domestic violence is expected to strengthen the implementation of relevant measures and improve their quality in 
many Member States. It would be important to ensure that the new legislative instrument would also set some requirements in relation to sufficient 
resources, and that training pay particular attention to the needs of women victims who are or may be exposed to intersectional discrimination.  
The measure will bring benefits to victims and wider society, however its ability to fully reach more vulnerable group will depend on the content 
provided to the professionals, which could for example include information on ethnic minorities (such as Sami and Roma women), migrant 
women, and women with disabilities, as these women experience cultural, language or other barriers when turning to social and health care services 
The total investment required is negligible as general support services to victims of violence against women and domestic violence are covered in 
the baseline from a costs perspective. Additional costs are derived from specialist support, support to victims of OVAW, gender-based harassment 
at work and access to shelters. 

189 

 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

1.4.2. Assessment  of  measure  4.1.c.I  -  support  to  violence  against  women  and 

domestic violence victims 

■  Obligation on MS to ensure availability and adequate resourcing of general 

support services.  

■  Obligation on MS to issue guidelines to health care and social service 

professionals on violence against women or domestic. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

No impact on this objective. 

No impact on this objective. 

As with measure 4.1.b, authorities should develop, within and/or in addition to state-run services, 
alternative, low threshold specialist support services acting in the interest of victims and giving 
them the choice to decide whether or not to press charges against the perpetrator. As with 
measure 4.1.b, this will favour access to justice as it will support victims through support services 
so that they are encouraged to seek justice and participate in the proceedings on their own terms. 

As with measure 4.1.b, the measure will oblige Member States to ensure general support services 
are available to victims of gender-based violence and domestic violence, including an obligation 
to ensure access to general health care and social services. This measure will also introduce an 
obligation on Member States to issue guidelines to health care and social service professionals on 
gender-based violence and domestic violence. 
At present, Art. 8(1) of the Victims Rights Directive requires access to general victim support 
services (confidential, free of charge, acting in the interest of the victim) for all victims of all 
crime. 23 Member States who responded to the targeted consultation stated that support services 
(general or specialised) are available to victims of gender-based and domestic violence. 64% of 
all respondents to the public consultation believe that support services are available to victims of 
gender-based and domestic violence, and among respondents from Germany and Italy, the 
proportion is higher at over 82%.365  
However, 50% of respondents to the public consultation do not believe that general support 
services systematically take into account the needs of victims of VAW/DV in their Member 
State.366 The measure will address this, as it will be part of a legislative instrument specific to 
gender-based violence, thus emphasising the importance of making these services available to 
and considerate of such victims. 

365 Public consultation q.21. 
366 Public consultation q.23. 

190 

 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

GREVIO noted that many general support services have insufficient funding and/or human 
resources; this measure will require that general services are adequately resourced in order to 
reach and support as many victims as possible. 
In terms of referrals, all 24 Member States who responded stated that that general support services 
refer victims to appropriate specialist services. And all but one (EL) said that law enforcement 
authorities ‘can do’ (11) or ‘have to’ (12) inform a support service of cases of VAW/DV, 
although this discretion may be leading to gaps as professionals of ‘an overall lack of knowledge 
among professionals about the different services victims need contact with’.367 In some baseline 
reports (including for BE and IT), GREVIO identified some issues with regards to the training of 
the relevant professionals that are directly involved in the provision of social services in relation 
to the gendered dynamics of violence. GREVIO also noted issues with training of professionals in 
the health sector, for example, in the reports on Finland and Spain. Lack of such training hinders 
their ability to properly address victims’ needs and support them. Another benefit of the measure 
will be it will require that professionals are trained to assist victims and refer them to the 
appropriate services.  
Further, at present, only a few Member States (DE, IT, PT, SE) have in place guidelines to health 
care and social service professionals on violence against women and domestic violence or more 
detailed minimum standards on the availability and quality of health care and social services, 
including counselling, in cases of violence against women and domestic violence. A strength of 
this measure over measure 4.1.b is that it will also introduce guidelines to health care and social 
service professionals on gender-based violence and domestic violence, which will further enhance 
the provision for such victims. Assuming that guidelines will set out how to identify and refer 
victims to support services, this will enhance referrals and therefore support received by victims. 
GREVIO has noted tailored support is lacking for groups including ethnic minorities (such as 
Sami and Roma women), migrant women, and women with disabilities, as these women 
experience cultural, language or other barriers when turning to social and health care services. 
GREVIO recommended that parties ensure that service provision pay particular attention to the 
needs of women victims who are or may be exposed to intersectional discrimination. The extent 
to which this issue will be addressed by this measure will depend on the content of the training 
and guidelines; guidelines should provide information allowing professionals to provide tailored 
support and referrals for victims in vulnerable groups. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of general support to victims of violence against 
women and domestic violence, as when they access general services such as general health care 
and social services, the services will be adequately resourced and the professionals they interact 
with will be trained to assist victims and refer them to the appropriate services. Guidelines in 
place for the services will also ensure victims receive the best possible support and referrals. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on ethnic minorities (such as Sami and Roma women), migrant women, and women 
with disabilities will depend on the content of the professionals’ training and the guidelines. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

367 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 57. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 

191 

 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Wider society  
Professionals working in general support services such as health and social care will receive 
training and guidelines to help them assist victims and refer them to the appropriate services. This 
will raise the awareness among such professionals and likely have a multiplier effect amongst 
their organisations. 

National authorities 
The Victims Rights Directive requires access to general victim support services for all victims of 
all crime, and nearly all Member States reported that support services are available to victims of 
gender-based and domestic violence. However, the measure is still expected to have an impact, as 
sufficient training, guidelines, and funding will need to be provided. The measure is likely to find 
political acceptance, as Member States overall already have similar activities in place, although 
some may have to significantly scale them up.  

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Rights to social assistance and health care (Article 34 and 35) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Overall assessment 

The total cost is estimated between € 328,418,000 and € 2,629,770,000. The minimum is 
estimated based on special leave for victims of sexual physical violence, whereas the maximum 
assumes all women victims of physical violence are entitled to the three-day leave. 

Overall, introducing a legal obligation for ensuring general support services such as health and social services are available to victims of gender-
based violence and domestic violence and ensuring such services are resourced and trained in a single legislative instrument specifically aimed at 
violence against women and domestic violence is expected to strengthen the implementation of relevant measures and improve their quality in 
many Member States. The measure introduces benefits over and above measure 4.1.b, as guidelines will be produced for the general services 
related to gender-based violence and domestic violence, so that they are able to better identify, refer and assist victims. 
The measure will bring benefits to victims and wider society, however its ability to fully reach more vulnerable group will depend on the content of 
the guidelines and information provided to the professionals, which could for example include information on ethnic minorities (such as Sami and 
Roma women), migrant women, and women with disabilities, as these women experience cultural, language or other barriers when turning to social 
and health care services. 
The total investment required amount to zero. 
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

1.4.3. Assessment  of  measure  4.1.c.II  support  to  violence  against  women  and 

domestic violence victims  

Obligation on MS to ensure availability and adequate resourcing of general support services.  
Obligation on MS to issue guidelines to health care and social service professionals on 
violence against women and domestic violence. 
Obligation for MS to provide three days of special leave compensated at the level of sick 
leave for all victims of violence against women and domestic violence. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

No impact on this objective. 

192 

 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

No impact on this objective. 

As with measure 4.1.b, authorities should develop, within and/or in addition to state-run services, 
alternative, low threshold specialist support services acting in the interest of victims and giving 
them the choice to decide whether or not to press charges against the perpetrator. As with 
measure 4.1.b, this will favour access to justice as it will support victims through support services 
so that they are encouraged to seek justice and participate in the proceedings on their own terms. 

As with measure 4.1.b, the measure will oblige Member States to ensure general support services 
are available to victims of gender-based violence and domestic violence, including an obligation 
to ensure access to general health care and social services. This measure will also introduce an 
obligation on Member States to issue guidelines to health care and social service professionals on 
gender-based violence and domestic violence. 
At present, Art. 8(1) of the Victims Rights Directive requires access to general victim support 
services (confidential, free of charge, acting in the interest of the victim) for all victims of all 
crime. 23 Member States who responded to the targeted consultation stated that support services 
(general or specialised) are available to victims of gender-based and domestic violence. 64% of 
all respondents to the public consultation believe that support services are available to victims of 
gender-based and domestic violence, and among respondents from Germany and Italy, the 
proportion is higher at over 82%.368  
However, 50% of respondents to the public consultation do not believe that general support 
services systematically take into account the needs of victims of VAW/DV in their Member 
State.369 The measure will address this, as it will be part of a legislative instrument specific to 
gender-based violence, thus emphasising the importance of making these services available to 
and considerate of such victims. 
GREVIO noted that many general support services have insufficient funding and/or human 
resources; this measure will require that general services are adequately resourced in order to 
reach and support as many victims as possible. 
In terms of referrals, all 24 Member States who responded stated that that general support services 
refer victims to appropriate specialist services. And all but one (EL) said that law enforcement 
authorities ‘can do’ (11) or ‘have to’ (12) inform a support service of cases of VAW/DV, 
although this discretion may be leading to gaps as professionals of ‘an overall lack of knowledge 
among professionals about the different services victims need contact with’.370 In some baseline 
reports (including for BE and IT), GREVIO identified some issues with regards to the training of 
the relevant professionals that are directly involved in the provision of social services in relation 
to the gendered dynamics of violence. GREVIO also noted issues with training of professionals in 
the health sector, for example, in the reports on Finland and Spain. Lack of such training hinders 
their ability to properly address victims’ needs and support them. Another benefit of the measure 
will be it will require that professionals are trained to assist victims and refer them to the 
appropriate services.  
Further, at present, only a few Member States (DE, IT, PT, SE) have in place guidelines to health 
care and social service professionals on violence against women and domestic violence or more 
detailed minimum standards on the availability and quality of health care and social services, 
including counselling, in cases of  violence against women and domestic violence. A strength of 
this measure over measure 4.1.b is that it will also introduce guidelines to health care and social 
service professionals on gender-based violence and domestic violence, which will further enhance 
the provision for such victims. Assuming that guidelines will set out how to identify and refer 
victims to support services, this will enhance referrals and therefore support received by victims. 
The final type of support offered by this measure will be the obligation for MS to provide three 
days of special leave compensated at the level of sick leave for all victims of violence against 

368 Public consultation q.21. 
369 Public consultation q.23. 
370 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 57. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 

193 

 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

women and domestic violence. This will ensure psychological, physical, and emotional space 
from the workplace when a victim has experienced violence against women and domestic 
violence and may help with the victim’s recover. 
GREVIO has noted tailored support is lacking for groups including ethnic minorities (such as 
Sami and Roma women), migrant women, and women with disabilities, as these women 
experience cultural, language or other barriers when turning to social and health care services. 
GREVIO recommended that parties ensure that service provision pay particular attention to the 
needs of women victims who are or may be exposed to intersectional discrimination. The extent 
to which this issue will be addressed by this measure will depend on the content of the training 
and guidelines; guidelines should provide information allowing professionals to provide tailored 
support and referrals for victims in vulnerable groups. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of general support to victims of violence against 
women and domestic violence, as when they access general services such as general health care 
and social services, the services will be adequately resourced and the professionals they interact 
with will be trained to assist victims and refer them to the appropriate services. Guidelines in 
place for the services will also ensure victims receive the best possible support and referrals. 
Finally, all victims will be able to take three days of special leave compensated at the level of sick 
leave which will further support victims. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on ethnic minorities (such as Sami and Roma women), migrant women, and women 
with disabilities will depend on the content of the professionals’ training and the guidelines. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
Professionals working in general support services such as health and social care will receive 
training and guidelines to help them assist victims and refer them to the appropriate services. This 
will raise the awareness among such professionals and likely have a multiplier effect amongst 
their organisations. 

National authorities 
The Victims Rights Directive requires access to general victim support services for all victims of 
all crime, and nearly all Member States reported that support services are available to victims of 
gender-based and domestic violence. However, the measure is still expected to have an impact, as 
sufficient training, guidelines, and funding will need to be provided. The measure is likely to find 
political acceptance, as Member States overall already have similar activities in place, although 
some may have to significantly scale them up.  

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Rights to social assistance and health care (Article 34 and 35) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The total cost is estimated between € 328,418,000 and € 2,629,770,000. The minimum is 
estimated based on special leave for victims of sexual physical violence, whereas the maximum 
assumes all women victims of physical violence are entitled to the three-day leave. 

Negligible cost of guidelines to health and social care professionals 

194 

 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Overall assessment 

Overall, introducing a legal obligation for ensuring general support services such as health and social services are available to victims of gender-
based violence and domestic violence and ensuring such services are resourced and trained in a single legislative instrument specifically aimed at 
violence against women and domestic violence is expected to strengthen the implementation of relevant measures and improve their quality in 
many Member States. The measure introduces benefits over and above measure 4.1.b, as guidelines will be produced for the general services 
related to gender-based violence and domestic violence, so that they are able to better identify, refer and assist victims. 
The measure will bring benefits to victims and wider society, however its ability to fully reach more vulnerable group will depend on the content of 
the guidelines and information provided to the professionals, which could for example include information on ethnic minorities (such as Sami and 
Roma women), migrant women, and women with disabilities, as these women experience cultural, language or other barriers when turning to social 
and health care services. 
The total investment required amount to zero. 
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

195 

 
 
 
 
1.4.4. Assessment of measure 4.2.b - specialised support 

Specialist support:  

–  Obligation  for  MS  to  provide  or  arrange  for  immediate,  short-  and  long-term 
specialist support services in an adequate  geographical distribution to victims of all 
forms of violence against women and domestic violence (Art. 22(1) IC). 

–  Obligation to arrange  for specialist women’s support services to all women victims 

of violence and their children. (Art. 22(2) IC). 

–  Obligation for MS to ensure adequate regional availability of protection and support: 

primarily in physical format and if not possible, through online provision. 

–  Obligation  for  MS  to  provide  appropriate,  easily  accessible  rape  crisis  or  sexual 
violence  referral  centres  for  victims  in  sufficient  numbers.  These  provide:  medical 
and forensic examination and trauma support and counselling for victims throughout 
the geographical area of the MS (Art. 25 IC). 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

No impact on this objective. 

No impact on this objective. 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

A part of the measure will include ensuring appropriate, easily accessible rape crisis or sexual 
violence referral centres for victims in sufficient numbers, to provide, amongst other services, 
medical and forensic examination. This will facilitate more effective access to justice and 
punishment for perpetrators of rape and sexual violence. 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

The measure will broadly improve the offer and quality of specialist support services for victims 
of domestic violence and violence against women through provision of support in an adequate 
geographical distribution to victims of all forms of gender-based violence and domestic violence. 
Currently, Art. 8(2) of the Victims Rights Directive requires Member States to take measures to 
establish specialist support services in addition to, or as an integrated part of, general victim 
support services. As discussed under measure 4.1, 23 Member States who responded to the 
targeted consultation stated that support services (general or specialised) were available to victims 
of gender-based and domestic violence, of which 20 said there were specialist support services 
accessible only to women victims. According to the targeted consultation, nearly all Member 
States (AT, BE, BG, CY, CZ, DE, DK, EE, ES, FI, FR, HR, HU, IE, IT, LT, LU, LV, NL, PL, 
PT, RO, SE, SK, SL) ensure adequate funding to specialised support services. 
However, in practice, the availability of support services is widely noted to be lacking. GREVIO 
noted that there are widespread specialist support services that assist victims of domestic 
violence, yet inadequacies have been identified in terms of the number, distribution, and type of 
such services. For example, counselling and trauma care were scarce in countries including 
Denmark and Sweden. There is also a need to set up specialist support services for forms of 
violence other than domestic violence such as sexual violence, FGM, forced marriage, forced 
abortion and sterilisation or sexual harassment. 64% of all respondents to the public consultation 

196 

 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

believe that support services are available to victims of gender-based and domestic violence, 
although respondents from Germany and Italy, the proportion is higher at over 82%.371 50% of 
respondents do not believe that general support services systematically take into account the 
needs of victims of VAW/DV in their Member State.372 The measure will address these problems 
by obliging Member States to provide or arrange for immediate, short- and long-term specialist 
support services to victims of all forms of gender-based violence and domestic violence, as well 
as specialist women’s support services to all women victims of violence and their children. This 
will ensure services are not solely focused on domestic violence, allowing victims of other forms 
of violence to receive the support they need. 
The measure will oblige Member States to provide appropriate, easily accessible rape crisis or 
sexual violence referral centres for victims in sufficient numbers, to provide medical and 
forensic examination and trauma support and counselling for victims throughout the Member 
State. This will ensure victims of rape and sexual violence are medically, forensically, and 
emotionally supported to the full extent. 
Victim Support Europe notes that there is insufficient geographical coverage for services in 
certain countries (BG, HR, CY, EL, ES, IT, LT, LU, RO, SK).373 The measure will ensure victims 
across the EU will be able to access services which have an adequate geographical distribution, 
and this will be further enhanced as the measure will oblige Member States to ensure adequate 
regional availability of protection and support: primarily in physical format and if not possible, 
through online provision. 
A limitation of the measure will be its general nature and lack of focus on specific vulnerable 
groups. Specific access barriers for children, migrant women and women living with a disability 
have been noted by Victim Support Europe374. GREVIO baseline evaluation reports in Member 
States including Austria, Belgium, Italy, Portugal, and Sweden have shortcomings in the 
provision of specialist support services catered to the needs of specific groups of victims such as 
children and women at the intersection of discrimination, notably, women with mental health 
issues, victims with a history of substance abuse, women with intellectual or physical disabilities, 
irregular migrant women and women from ethnic minorities, in particular Roma women and Sami 
women. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of specialist support to victims of violence 
against women and domestic violence. An approach which is victim-centred and based on a 
gendered understanding of violence against women will facilitate empowering victims through 
assistance catered to their specific needs, including the needs of women in rural areas.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The measure is not expected to impact particular groups in a specific way, as it is aimed at women 
victims of violence and domestic violence victims in general. 

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

371 Public consultation q.21. 
372 Public consultation q.23. 
373 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 56. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 
374 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 56. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 

197 

 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Perpetrators of violence against women and domestic violence  
The measure could impact perpetrators, as when forensic capabilities are strengthened in rape 
crisis or sexual violence referral centres, this will facilitate investigation, prosecution and 
sanctioning of perpetrators.  

Wider society  
The measure is not expected to impact wider society. 

National authorities 
National authorities are required by the Victims Rights Directive to have specialist services in 
place, therefore the measure will represent an expansion and improvement on existing provision. 
The measure is likely to find political acceptance, as Member States overall already have similar 
activities in place, although some may have to significantly scale them up.  

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2( 
-  Right to the integrity of the person (Article 3) 
- 
-  Respect for private and family life (Article 7) 
-  Non-discrimination (Article 21)  
- 
-  Rights of the elderly (Article 25) 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Integration of persons with disabilities (Article 26) 

Equality between women and men (Article 23) 

Victims of online GBV 

- 
- 

Protection of personal data (Article 8) 
Freedom of expression and information (Article 11) 

Victims of sex-based harassment 

-  Right to fair and just working conditions (Article 31) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Child victims /witnesses 
Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs are expected to be borne by the EC, Member State authorities and support of other 
organisations (if running specialist services). More specifically:  
The EC may co-fund specialist services for victims of violence against women and domestic 
violence, but the costs of these are presented below and relate to public authorities.  
Public authorities will incur costs for running specialist support services that are shown below.  

Specialist support to women victims of 
violence against women and domestic 
violence (running cost per annum) 

Total EU cost (Millions of euros) 

106.9 

Costs are based on an estimation of the additional government expenditure needed in each 
Member State to fulfil the demand for services for survivors on sexualised violence compared to 
the baseline. These costs were calculated based on an estimate of the existing total government 
expenditure per annum on specialised support services for women victims of GBV and the 
percentage of missing services for survivors of sexualised violence. The calculated total costs 
assume that all Member States require additional expenditure on specialist support that are 
proportionate to number of missing services for survivors of sexualised violence. 

Overall assessment 

Overall, introducing a legal obligation for ensuring specialist support services are widely available to victims of gender-based violence and 
domestic violence in a single legislative instrument specifically aimed at violence against women and domestic violence is expected to strengthen 
the implementation of relevant measures and improve their quality in many Member States. An approach which is victim-centred and based on a 
gendered understanding of violence against women will facilitate empowering victims through assistance catered to their specific needs, including 
the needs of women in rural areas.  

198 

 
 
 
 
 
Assessment criterion 

Score 

Assessment  

The measure will bring benefits to victims, however due to its rather general nature, it may not be able to fully reach more vulnerable groups. 
The total investment required amount to 106.9 Million Euros. 
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

1.4.5. Assessment of measure 4.2.c - specialised support 

■  Specialist support:  

–  Obligation  for  MS  to  provide  or  arrange  for  immediate,  short-  and  long-term 
specialist support services in an adequate geographical distribution to victims of all 
forms of violence against women and domestic violence (Art. 22(1) IC). 

–  Obligation to arrange for specialist women’s support services to all women victims 

of violence and their children. (Art. 22(2) IC). 

–  Obligation for MS to ensure adequate regional availability of protection and support: 

primarily in physical format and if not possible, through online provision. 

–  Obligation  for  MS  to  provide  appropriate,  easily  accessible  rape  crisis  or  sexual 
violence  referral  centres  for  victims  in  sufficient  numbers.  These  provide:  medical 
and forensic examination and trauma support and counselling for victims throughout 
the geographical area of the MS (Art. 25 IC). 

–  Obligation for MS to ensure availability of support services to groups at a heightened 
risk  of  violence  (such  as  migrant  women,  victims  from  minority  communities, 
women with disabilities, women working in the sex industry and women prisoners). 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

No impact on this objective. 

No impact on this objective. 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

A part of the measure will include ensuring appropriate, easily accessible rape crisis or sexual 
violence referral centres for victims in sufficient numbers, to provide, amongst other services, 
medical and forensic examination. This will facilitate more effective access to justice and 
punishment for perpetrators of rape and sexual violence. 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

As with measure 4.2.b, the measure will broadly improve the offer and quality of specialist 
support services for victims of domestic violence and violence against women through provision 
of support in an adequate geographical distribution to victims of all forms of gender-based 
violence and domestic violence. This measure will additionally oblige Member States to ensure 
availability of support services to groups at a heightened risk of violence such as migrant 
women, victims from minority communities, women with disabilities, women working in the sex 
industry and women prisoners. 
Currently, Art. 8(2) of the Victims Rights Directive requires Member States to take measures to 
establish specialist support services in addition to, or as an integrated part of, general victim 
support services. As discussed under measure 4.1, 23 Member States who responded to the 
targeted consultation stated that support services (general or specialised) were available to victims 

199 

 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

of gender-based and domestic violence, of which 20 said there were specialist support services 
accessible only to women victims. According to the targeted consultation, nearly all Member 
States (AT, BE, BG, CY, CZ, DE, DK, EE, ES, FI, FR, HR, HU, IE, IT, LT, LU, LV, NL, PL, 
PT, RO, SE, SK, SL) ensure adequate funding to specialised support services. 
However, in practice, the availability of support services is widely noted to be lacking. GREVIO 
noted that there are widespread specialist support services that assist victims of domestic 
violence, yet inadequacies have been identified in terms of the number, distribution, and type of 
such services. There is also a need to set up specialist support services for forms of violence other 
than domestic violence such as sexual violence, FGM, forced marriage, forced abortion and 
sterilisation or sexual harassment. 64% of all respondents to the public consultation believe that 
support services are available to victims of gender-based and domestic violence, although 
respondents from Germany and Italy, the proportion is higher at over 82%.375 50% of respondents 
do not believe that general support services systematically take into account the needs of victims 
of VAW/DV in their Member State.376 The measure will address these problems by obliging 
Member States to provide or arrange for immediate, short- and long-term specialist support 
services to victims of all forms of gender-based violence and domestic violence, as well as 
specialist women’s support services to all women victims of violence and their children. This will 
ensure services are not solely focused on domestic violence, allowing victims of other forms of 
violence to receive the support they need. 
The measure will oblige Member States to provide appropriate, easily accessible rape crisis or 
sexual violence referral centres for victims in sufficient numbers, to provide medical and 
forensic examination and trauma support and counselling for victims throughout the Member 
State. This will ensure victims of rape and sexual violence are medically, forensically, and 
emotionally supported to the full extent. 
Victim Support Europe notes that there is insufficient geographical coverage for services in 
certain countries (BG, HR, CY, EL, ES, IT, LT, LU, RO, SK).377 The measure will ensure victims 
across the EU will be able to access services which have an adequate geographical distribution, 
and this will be further enhanced as the measure will oblige Member States to ensure adequate 
regional availability of protection and support: primarily in physical format and if not possible, 
through online provision. 
Specific access barriers for children, migrant women and women living with a disability have 
been noted by Victim Support Europe378. GREVIO baseline evaluation reports in Member States 
including Austria, Belgium, Italy, Portugal, and Sweden have shortcomings in the provision of 
specialist support services catered to the needs of specific groups of victims such as children and 
women at the intersection of discrimination, notably, women with mental health issues, victims 
with a history of substance abuse, women with intellectual or physical disabilities, irregular 
migrant women and women from ethnic minorities, in particular Roma women and Sami women. 
A strong benefit of this measure will be its obligation for Member States to ensure availability of 
support services to groups at a heightened risk of violence such as migrant women, victims 
from minority communities, women with disabilities, women working in the sex industry and 
women prisoners. 

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

No impact on this objective. 

No impact on this objective. 

375 Public consultation q.21. 
376 Public consultation q.23. 
377 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 56. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 
378 Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis 
report’ p. 56. https://victimsupport.eu/activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-
web.pdf. 

200 

 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Effectiveness – other impacts 

Social impacts 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of specialist support to victims of violence 
against women and domestic violence. An approach which is victim-centred and based on a 
gendered understanding of violence against women will facilitate empowering victims including 
women in rural areas.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
A benefit of this measure compared to measure 4.2.b will be its obligation for Member States to 
ensure availability of support services to groups at a heightened risk of violence such as 
migrant women, victims from minority communities, women with disabilities, women working in 
the sex industry and women prisoners. This will ensure services cater to the specific needs of 
these groups and women who are subject to multiple discrimination  

Perpetrators of violence against women and domestic violence  
The measure could impact perpetrators, as investigations and prosecutions will be facilitated 
when forensic capabilities are strengthened in rape crisis or sexual violence referral centres.  

Wider society  
The measure is not expected to impact wider society. 

National authorities 
National authorities are required by the Victims Rights Directive to have specialist services in 
place, therefore the measure will represent an expansion and improvement on existing provision. 
The measure is likely to find political acceptance, as Member States overall already have similar 
activities in place, although some may have to significantly scale them up.  

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Respect for private and family life (Article 7) 
-  Non-discrimination (Article 21)  
- 
-  Rights of the elderly (Article 25) 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Integration of persons with disabilities (Article 26) 

Equality between women and men (Article 23) 

Victims of online violence against women and domestic violence  

- 
- 

Protection of personal data (Article 8) 
Freedom of expression and information (Article 11) 

Victims of sex-based harassment 

-  Right to fair and just working conditions (Article 31) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Child victims /witnesses 
Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

This policy option requires availability of support services to groups at heightened risk of 
violence. Public authorities will incur additional costs from 4.2b to provide specialist support 
services that target certain groups at heightened risk.  

Specialist support to women victims of 
GBV (running cost per annum) 

Total EU cost (Millions of euros) 

117.6 

Costs assume that an additional 10% of total expenditure estimated under the 4.2b is needed to 
support groups at heightened risk.  

Overall assessment 

201 

 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

Overall, introducing a legal obligation for ensuring specialist support services are widely available to victims of gender-based violence and 
domestic violence in a single legislative instrument specifically aimed at violence against women and domestic violence is expected to strengthen 
the implementation of relevant measures and improve their quality in many Member States. An approach which is victim-centred and based on a 
gendered understanding of violence against women will facilitate empowering victims through assistance catered to their specific needs, including 
the needs of women who are subject to multiple discrimination and women in rural areas.  
The measure will bring benefits to victims, including victims who are in vulnerable groups such as migrant women, victims from minority 
communities, women with disabilities, women working in the sex industry and women prisoners. 
The total investment required amount to 117.6 Million Euros. 
The measure is likely to find political acceptance, as Member States overall already have similar activities in place, although some may have to 
significantly scale them up.  

202 

 
 
 
 
1.4.6. Assessment of measure 4.3.c - support to victims of gender-based cyber violence 

■  Support for victims of victims of gender-based cyber violence: On- and offline support 
for  victims  (incl.  equipping  support  services  with  financial  and  human  resources  for 
knowledge-development). 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

Victims of gender-based online violence against women have benefitted somewhat from the 
general EU provisions applicable to all victims. However, since these provisions do not 
specifically regulate victims of gender-based online violence against women, they are unlikely to 
have directly contributed to effective protection and support. GREVIO noted that despite a 
growing incidence of digital violence against women, including in the context of domestic 
violence, they have seen very little dedicated support services that comprehensively address the 
complex issues involved. Many Member States reported a lack of support or knowledge about the 
prevalence and existence of online violence against women379. For example, in Germany, the 
Federal Association of Rape Crisis Centres and Women’s Counselling Centres identified a need 
for more specialist support and an integrated strategy to prevent online violence380. 
This measure will introduce on- and offline support for victims of online violence against women, 
including equipping support services with financial and human resources for knowledge-
development. This will ensure that victims of such crimes are supported in a specialised and 
considerate manner. Including this in a wider instrument about violence against women and 
domestic violence will emphasise the importance of supporting victims of online violence.  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

No impact on this objective. 

No impact on this objective. 

379 EP Study (2021): Combating gender-based violence: Cyber violence, pp 109 – 110 – SE example; the 
issues/problems in general. FC – Q8 
380 https://www.frauen-gegen-gewalt.de/de/aktionen-themen/bff-aktiv-gegen-digitale-gewalt/aktuelle-studien-
und-veroeffentlichungen.html  

203 

 
 
 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

Social impacts 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of support to victims of online violence against 
women, as when they access services such as general health care and social services, the services 
will have developed knowledge on the topic through financial and human resources. Victims will 
also be able to access online support. 

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on particular groups will depend on the nature of the support services. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
Professionals working in support services will develop knowledge on online violence against 
women. This will raise awareness among such professionals. 

National authorities 
As discussed in other measures for victim support, the Victims Rights Directive does require the 
existence of general and specialised support services. However, this measure will signal the 
importance of the issue of online violence against women, and will integrate online violence 
considerations into support services which currently exist in Member States. 

Fundamental rights 

Victims of violence against women and domestic violence: 
Rights to social assistance and health care (Article 34 and 35) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs are expected to be borne by the EC, Member State authorities and support of other 
organisations (if running support services). More specifically:  
The EC may co-fund support services for victims of violence against women and domestic 
violence, but the costs of these are presented below and relate to public authorities.  
Public authorities will incur costs for running support services for victims of OVAW that are 
shown below.  

Support to victims of OVAW (running 
cost per annum) 

Total EU cost (Millions of euros) 

1,159.6 

Costs are based on the estimated number of women victims of online violence that report the 
incident to an online platform multiplied by the number of hours of support provided and hourly 
national wages of health and social workers. It is assumed that each case requires 6 sessions of 1-
hour health and social worker support each. Sufficient information is not available on the 
presence of such measures in the baseline and therefore it is assumed that all Member States incur 
costs.  

Additional measures include provision of online support to women victims of OVAW, it is 
assumed that these measured are already covered through helplines (4.6). 

Overall assessment 

Overall, introducing a legal obligation for on- and offline support for victims of online violence against women, including equipping support 
services with financial and human resources for knowledge-development in a single legislative instrument specifically aimed at violence against 
women and domestic violence is expected to strengthen the implementation of relevant measures and improve their quality in many Member 
States.  
The measure will bring benefits to victims as it will allow victims of online violence to access support which is informed about their needs. 
The total investment required amount to 1,159.6 Million Euros. 
The measure is likely to find political acceptance, as it will involved incorporating online considerations into existing activities in Member States. 

1.4.7. Assessment  of  measure  4.4.c  -  support  to  victims  of  gender-based  work 

harassment 

204 

 
 
 
 
 
 
 
■  Obligation for MS to ensure that medical care and counselling services are available to 
all  victims  of  work-based  harassment  and  that  victims  are  informed  about  the  relevant 
services.  Such  services  could  be  made  available  by  the  Government,  social  partners  or 
individual employers. In implementing this provision, MS need to take into account the 
situation of SME’s/employers with less than 10 employees. 

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

No impact on this objective. 

No impact on this objective. 

No impact on this objective. 

The measure will oblige Member States to ensure that medical care and counselling services are 
available to all victims of work-based harassment and that victims are informed about the relevant 
services. Such services could be made available by the Government, social partners or individual 
employers.  
Currently, sexual harassment is defined in gender-neutral terms across Directive 2006/54/EC, 
2004/113/EC and 2010/41/EU, and the EELN report highlights fragmentation of the provisions 
across different legal instruments as shortcomings in the implementation of the EU directives.381 
Bringing in a comprehensive and specific legal framework on violence against women and 
domestic violence will emphasise the experience of women at work, sending a powerful message 
of zero tolerance towards gender-based violence in the work environment, and will harmonise 
fragmented provisions. The measure will also clearly reference harassment on the basis of gender 
rather than sex.  
The EELN report states that sexual harassment and harassment related to sex are generally 
prohibited at national level as a response to the EU directives on gender equality382. It notes that 
in most Member States, the scope of prohibition on sex-based harassment and sexual harassment 
has been broader than in EU law and in some countries harassment and sexual harassment are 
prohibited in all spheres of life. The report says ‘This seems to indicate that states considered the 
current EU legal framework as insufficient to address the phenomena’ and highlights insufficient 
support measures as a shortcoming in the implementation of the EU directives in terms of 
effectiveness383. Similarly, social partners consider that the directives to have contributed very 
little to the assistance and support they provide.  
As discussed in measure 1.3.c in prevention, there are some ongoing cases of good practice which 
should continue as this measure is introduced. In its baseline evaluation reports, GREVIO 
highlights some examples of good practice related to harassment at work, including in Portugal, 
whereby the Working Conditions Authority (i.a.) offers face-to-face counselling and a national 
telephone information service, and gives attention to vulnerable groups of workers, including 
immigrant workers. Also in Portugal, the Commission for Equality in Labour and Employment 
provides legal support to victims. Further, social partners have engaged in a wide range of 
measures and successfully provided assistance, particularly through collective bargaining.  

381 EELN report p.82  
382 EELN report p.82  
383 EELN report p.82  

205 

 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

The measure will ensure the availability of support for victims of workplace harassment through 
provision of medical care and counselling services to all victims of work-based harassment, and 
the measure will also ensure victims are informed about the relevant services. 
Finally, Member States will be required to take into account the situation of SMEs and employers 
with fewer than 10 employees when implementing the measure. This will ensure a greater degree 
of proportionality, and limit the burden on micro enterprises. 

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

By providing the support described in the box above, this measure will ensure that gender-based 
harassment of women at work is effectively addressed. An approach which is victim-centred and 
based on a gendered understanding of violence against women will facilitate empowering victims 
through assistance catered to their specific needs. 

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective. 

Victims of violence against women and domestic violence  
Providing medical care and counselling services to all victims of work-based harassment and 
informing victims about relevant services will support victims following incidents of workplace 
harassment.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
The impact on particular groups will depend on the content of the support services; for example, 
they could include provisions to support employees at risk of intersectional discrimination in the 
workplace, including potential victims of both gender-based and race-based harassment. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
The providers of the support services, whether they be the Government, social partners or 
individual employers, will be impacted through delivering the support. Importantly, there will be 
mitigated measures for SMEs / companies of less than 10 employees to ensure proportionality. 

National authorities 
The impact on national authorities would depend on who provided the services (could be social 
partners, employees or national authorities).    

Fundamental rights 

The measure is expected to enhance in particular the following fundamental rights. 
Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

-  Right to the integrity of the person (Article 3) 
- 
-  Non-discrimination (Article 21)  
- 

Equality between women and men (Article 23) 

Environmental impacts 

No impacts expected. 

Victims of sex-based harassment 

-  Right to fair and just working conditions (Article 31) 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs are expected to be borne by employers and Member State authorities (if providing the 
services). More specifically:  
Public authorities will incur costs for running support services for victims of OVAW that are 
shown below.  

Support to victims of gender-based 
work harassment (running cost per 
annum) 

Total EU cost (Millions of euros) 

198.5-627.1 

Costs are based on the estimated number of estimated incidents of gender-based work harassment 

206 

 
 
 
 
 
 
 
 
 
Assessment criterion 

Score 

Assessment  

multiplied by the number of hours of support provided and hourly national wages of health and 
social workers. It is assumed that each case requires 6 sessions of 1-hour health and social worker 
support each. Sufficient information is not available on the presence of such measures in the 
baseline and therefore it is assumed that all Member States incur costs.  

Overall assessment 

Overall, this measure would represent a large improvement over the current baseline situation. The introduction of medical care and counselling 
services to all victims of work-based harassment, and the provision of information to victims about relevant services will support victims following 
incidents of workplace harassment, and will ensure that victims are properly supported in all cases of workplace harassment. It will also formalise 
and harmonise provisions at the EU level, sending a powerful message of zero tolerance towards gender-based violence in the work environment, 
harmonising fragmented provisions.  
The measure will bring benefits to victims and wider society. Depending on the content of the implemented provisions, the measure may be able to 
reach more vulnerable groups as well. 
The total investment required amount to 75 Million Euros. 
As Member States have already taken steps beyond the content of the Directives may indicate that there is appetite for further harmonisation of 
measures and action at EU level. The proportionality of the measure, as it does not apply to SMEs, may increase political acceptance from national 
authorities.  

207 

 
 
 
 
 
1.4.8. Assessment of measure 4.5.b Shelters 

Provision of shelters in an accessible manner and sufficient numbers.  

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective. 

Victims of violence against women and domestic violence who access shelters will be protected 
from perpetrators during their time in the shelter, particularly if the perpetrator is someone they 
live with. Ensuring shelters are easily accessible will allow a larger number of victims to be 
protected in this way.  

No impact on this objective. 

According to the WAVE Report (2019), the number of women’s shelters in Member States varies 
from zero (LT and NL) to 360 (DK), with an average of 57 shelters. The report shows that only 
three Member States (LU, MT, SL) fulfil the requested number of specialised women’s shelters 
per 10,000 of population recommended by the CoE.384 51% of beds needed are missing according 
to this standard.385  
This measure will improve upon the lack of shelters by requiring appropriate, easily accessible 
shelters in sufficient numbers to provide safe accommodation for and to reach out pro-actively to 
victims, especially women and their children. This will support victims as it will allow them to 
access a safe space away from perpetrators as they recover from instances of violence against 
women and domestic violence. However, the measure does only require “sufficient” numbers of 
shelters, therefore without a clear obligation to provide a set proportionate number of spaces, 
Member States would have discretion over the number of places. This could lead to sub-optimal 
coverage in some areas. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of general support to victims of violence against 
women and domestic violence, as sufficient numbers of appropriate, easy to access shelters will 
be available to them to ensure victims receive the best possible support. The measure will also 
require shelters to reach out proactively to victims, especially women and their children, therefore 
victims will not be unaware or confused about where they can turn. Being able to offer shelter to a 

384 WAVE (2019) Wave Country Report 2019. https://www.wave-network.org/2019/12/30/wave-country-report-
2019. 
385 Ibid.  

208 

 
 
 
 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

larger cohort of victims will also enhance their protection, as they are out of harm’s way.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
Due to its rather general nature, the measure may not be able to fully reach more vulnerable 
groups, although the increased availability of places and the proactive approach to outreach are 
likely to also cover more vulnerable groups. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
The measure is not expected to impact wider society. 

National authorities 
Some Member States do have adequate shelter capacity in their countries, for example 11 
Member States reported fewer than 20 shelters in their Member State (LT, NL, CY, CZ, MT, SK, 
LU, BG, LV, EE, HR) therefore this measure will have the largest impact on those without a 
sufficient number of shelters / shelter places. Member States which have not ratified the Istanbul 
Convention will likely need to invest the most in shelter spaces. 

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 
Equality between women and men (Article 23) 

- 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs for this measure are expected to be borne by the EC, Member State authorities and 
support of other organisations (if running shelters). More specifically:  
The EC may co-fund shelter services for women victims of violence against women and domestic 
violence, but the costs of these are presented below and relate to public authorities.  
Public authorities will incur costs for setting-up and running accessible shelters in sufficient 
numbers for victims. 

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of euros) 

Shelters 

147.8 

20.49-379.8 

33.12-392.4 

Running costs are based on minimum and maximum estimates of the cost of maintaining one 
refuge space multiplied by the estimated number of missing beds in shelters in each Member 
State in the baseline.  
The one-off development costs are based on the average expenditure needed to set up the missing 
shelters, assuming an additional an average 125-person capacity/shelter.  

Overall assessment 

Overall, introducing a legal obligation for appropriate, easily accessible shelters in sufficient numbers to provide safe accommodation for and to 
reach out proactively to victims, especially women and their children in a single legislative instrument specifically aimed at violence against 
women and domestic violence is expected to increase the number of shelters in most Member States. The measure will bring benefits to victims 
who are seeking a safe space following an episode of violence, and protect them from revictimization. Due to its rather general nature, it may not 
be able to fully reach more vulnerable groups. Further, the measure only requires “sufficient” numbers of shelters, therefore without a clear 
obligation to provide a set proportionate number of spaces, Member States would have discretion over the number of places. This could lead to 
sub-optimal coverage in some areas. 
The total investment required amount to 369 – 4,225 Million Euros. 
Most Member States have at least some shelters, therefore the measure is likely to find political acceptance as it will represent scaling-up of 
existing provisions. 

1.4.9. Assessment of measure 4.5.c.I - shelters 

209 

 
 
 
 
 
 
■  Shelters:  

–  Provision of shelters in an accessible manner and sufficient numbers.  
–  Encouragement for shelter provision in line with CoE recommendation.  

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

386 Ibid.  

No impact on this objective. 

Victims of violence against women and domestic violence who access shelters will be protected 
from perpetrators during their time in the shelter, particularly if the perpetrator is someone they 
live with. As with measure 4.5.b, ensuring shelters are easily accessible will allow a larger 
number of victims to be protected in this way.  

No impact on this objective. 

As described in measure 4.5.b, there are insufficient numbers of shelters in the EU. According to 
the WAVE Report (2019), the number of women’s shelters in Member States varies from zero 
(LT and NL) to 360 (DK), with an average of 57 shelters.  
This measure will improve upon the lack of shelters by requiring appropriate, easily accessible 
shelters in sufficient numbers and in every region in a manner which corresponds to actual 
need, encouraging the threshold of one family place per 10,000 of population, as recommended 
by the CoE. The WAVE report shows that to date only three Member States (LU, MT, SL) fulfil 
the requested number of specialised women’s shelters and that 51% of beds needed are missing 
according to this standard.386  
Encouraging this threshold will strongly support victims as it will ensure there are adequate 
spaces available and reduce the risk of victims not being able to access a shelter when they need 
one. This will remove the scope for Member State discretion present in measure 4.5.b, as Member 
States will be obliged to meet a proportionate standard for the number of spaces in shelters. As 
with measure 4.5.b, the measure will also require shelters to reach out proactively to victims, 
especially women and their children, which further enhances the effect on this objective. 
However, the CoE threshold will only be encouraged rather than required, which will leave some 
discretion to Member States. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of general support to victims of violence against 
women and domestic violence, as needs-based numbers of appropriate, easy to access shelters 

210 

 
 
 
 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

will be encouraged to be available to them to ensure victims receive the best possible support. The 
measure will also require shelters to reach out proactively to victims, especially women and their 
children, therefore victims will not be unaware or confused about where they can turn. Being able 
to offer shelter to a larger cohort of victims will also enhance their protection, as they are out of 
harm’s way.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
Due to its rather general nature, the measure may not be able to fully reach more vulnerable 
groups, although the increased availability of places and the proactive approach to outreach are 
likely to also cover more vulnerable groups. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
The measure is not expected to impact wider society. 

National authorities 
Some Member States do have adequate shelters in their countries, however 51% of beds needed 
will need to be added to the current shelter provision therefore this measure will represent 
significant scaling-up in many countries. However note that in this measure the CoE threshold is 
encouraged rather than required. 

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 
Equality between women and men (Article 23) 

- 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Public authorities will incur costs for setting up and running spaces in shelters in additional to 
4.5b. 

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of euros) 

Shelters 

147.8 

20.49-379.8 

33.12-392.4 

Running costs are based on minimum and maximum estimates of the cost of maintaining one 
refuge space multiplied by the estimated number of an additional spaces needed in each Member 
State to ensure one space per 10,000 population compared to the baseline. 
The one-off development costs are based on the average cost of setting up a shelter to ensure one 
space per 10,000 population compared to the baseline, assuming an average 125-person 
capacity/shelter. 

Overall assessment 

This measure will encourage a legal obligation for appropriate, easily accessible shelters in every region in a manner which corresponds to 
actual need, for example providing one family place in a specialised women’s shelters per 10,000 of population (as recommended by CoE). Doing 
this in a single legislative instrument specifically aimed at violence against women and domestic violence is expected to increase the number of 
shelters in most Member States. The measure will bring benefits to victims who are seeking a safe space following an episode of violence, thus also 
enhancing their protection, as they are out of harm’s way. Due to its rather general nature, it may not be able to fully reach more vulnerable groups, 
although the increased availability of places and the proactive approach to outreach are likely to also cover more vulnerable groups. 
The total investment required amount to 159 – 1,832 Million Euros. 
Most Member States have at least some shelters, therefore the measure is likely to find political acceptance as it will represent scaling-up of 
existing provisions. 

1.4.10. Assessment of measure 4.5.c.II - shelters 

■  Shelters:  

211 

 
 
 
 
 
 
–  Provision of shelters in an accessible manner and sufficient numbers.  
–  Obligation to provide shelters in line with CoE recommendation (1 

space/10,000 inhabitants).  

Assessment criterion 

Score 

Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the 
Istanbul Convention) 

Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from 
(further) violence 

Ensuring the effective access to 
justice for victims of all forms of 
gender-based violence against women 
and domestic violence 

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence  

Ensuring that gender based 
harassment of women at work is 
effectively addressed  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

387 Ibid.  

No impact on this objective. 

Victims of violence against women and domestic violence who access shelters will be protected 
from perpetrators during their time in the shelter, particularly if the perpetrator is someone they 
live with. As with measure 4.5.b, ensuring shelters are easily accessible will allow a larger 
number of victims to be protected in this way.  

No impact on this objective. 

As described in measure 4.5.b, there are insufficient numbers of shelters in the EU. According to 
the WAVE Report (2019), the number of women’s shelters in Member States varies from zero 
(LT and NL) to 360 (DK), with an average of 57 shelters.  
This measure will improve upon the lack of shelters by requiring appropriate, easily accessible 
shelters in sufficient numbers and in every region in a manner which corresponds to actual 
need, adding the threshold of one family place per 10,000 of population, as recommended by the 
CoE. The WAVE report shows that to date only three Member States (LU, MT, SI) fulfil the 
requested number of specialised women’s shelters and that 51% of beds needed are missing 
according to this standard.387  
Adding this threshold will strongly support victims, as it will ensure there are adequate spaces 
available and reduce the risk of victims not being able to access a shelter when they need one. 
This will remove the scope for Member State discretion present in measure 4.5.b, as Member 
States will be obliged to meet a proportionate standard for the number of spaces in shelters. As 
with measure 4.5.b, the measure will also require shelters to reach out proactively to victims, 
especially women and their children, which further enhances the effect on this objective. 

No impact on this objective. 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will clearly improve the provision of general support to victims of violence against 
women and domestic violence, as needs-based numbers of appropriate, easy to access shelters 
will be available to them to ensure victims receive the best possible support. The measure will 
also require shelters to reach out proactively to victims, especially women and their children, 
therefore victims will not be unaware or confused about where they can turn. Being able to offer 

212 

 
 
 
 
 
 
 
 
 
 
                                                 
Assessment criterion 

Score 

Assessment  

shelter to a larger cohort of victims will also enhance their protection, as they are out of harm’s 
way.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)  
Due to its rather general nature, the measure may not be able to fully reach more vulnerable 
groups, although the increased availability of places and the proactive approach to outreach are 
likely to also cover more vulnerable groups. 

Perpetrators of violence against women and domestic violence  
The measure is not expected to impact perpetrators. 

Wider society  
The measure is not expected to impact wider society. 

National authorities 
Some Member States do have adequate shelters in their countries, however 51% of beds needed 
will need to be added to the current shelter provision therefore this measure will represent 
significant scaling-up in many countries. 

Fundamental rights 

Victims of violence against women and domestic violence: 

Prohibition of torture and inhuman or degrading treatment (Article 4) 
Equality between women and men (Article 23) 

- 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Public authorities will incur costs for setting up and running spaces in shelters in additional to 
4.5b. 

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of euros) 

Shelters 

135.21 

204.83-3,796.98 

340-3,932.2 

Running costs are based on minimum and maximum estimates of the cost of maintaining one 
refuge space multiplied by the estimated number of an additional spaces needed in each Member 
State to ensure one space per 10,000 population compared to the baseline. 
The one-off development costs are based on the average cost of setting up a shelter to ensure one 
space per 10,000 population compared to the baseline, assuming an average 125-person 
capacity/shelter. 

Overall assessment 

This measure will introduce a legal obligation for appropriate, easily accessible shelters in every region in a manner which corresponds to 
actual need, for example providing one family place in a specialised women’s shelters per 10,000 of population (as recommended by CoE). Doing 
this in a single legislative instrument specifically aimed at violence against women and domestic violence is expected to increase the number of 
shelters in most Member States. The measure will bring benefits to victims who are seeking a safe space following an episode of violence, thus also 
enhancing their protection, as they are out of harm’s way. Due to its rather general nature, it may not be able to fully reach more vulnerable groups, 
although the increased availability of places and the proactive approach to outreach are likely to also cover more vulnerable groups. 
The total investment required amount to 159 – 1,832 Million Euros. 
Most Member States have at least some shelters, therefore the measure is likely to find political acceptance as it will represent scaling-up of 
existing provisions. 

1.4.11. Assessment of measure 4.6.b - helplines  

  Obligation  to  set  up  state‐wide  24/7  telephone  helplines  free  of  charge  to  provide 
advice to callers, confidentially or with due regard for their anonymity, in relation to 
all forms of GBVAW and DV.  

213 

 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention) 

Helplines can provide information that may help callers to identify ways to prevent 
themselves or others from violence. As most Member States have this a helpline in place the 
main impact of this measure would be ensuring the consistency and quality of the helpline 
available across Member States, such as that it is available 24 hours a day and staffed by 
professionals trained in GBV specifically (see row 4).  

Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence 

Helplines can provide information that might assist victims to access protection measures 
which would protection them from further violence. As most Member States have this a 
helpline in place the main impact of this measure would be ensuring the consistency and 
quality of the helpline available across Member States, such as that it is available 24 hours a 
day and staffed by professionals trained in GBV specifically (see row 4).  

Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence 

Ensuring the effective availability of 
support for victims of all forms of gender-
based violence against women and 
domestic violence  

Helplines can provide information about support and protection available to victims and 
information their rights. This might encourage victims to report a crime and/or remained 
engaged in the judicial processes which would improve access to justice. As most Member 
States have this a helpline in place the main impact of this measure would be ensuring the 
consistency and quality of the helpline available across Member States, such as that it is 
available 24 hours a day and staffed by professionals trained in GBV specifically (see row 4).  

The impact of this measure on Member States will be limited as the majority already have a 
helpline in place, although there is variation in the scope and availability of the helpline 
which this measure could help to address.  
While all Member States have set up a helpline that can, to various degrees, provide women 
victims of gender-based violence support and information, many do not fully meet the terms 
of measure. In Malta, the Netherlands and Portugal, helplines were not dedicated to the needs 
of women victims of violence, nor specialised in providing advice on the different forms of 
gender-based violence against women with qualified staff. Similarly, in Belgium and France, 
helplines were not available 24 hours a day, and in Portugal, outside of office hours, they 
were not serviced by staff that are not sufficiently trained on violence against women. In 
Finland, Malta, Portugal and Spain helplines only provide support to victims of domestic 
violence.  

Ensuring that gender based harassment of 
women at work is effectively addressed 

The helpline would provide information relevant to gender based harassment of women at 
work – as a form of GBV - so it could help victims access information they need to report 
such crimes, increasing the likelihood they are effectively addressed.  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

No impact on this objective. 

Victims of violence against women and domestic violence  
This measure will support victims of violence against women and domestic violence by 
providing information which could include information about support and protection 
available and their rights, which could have benefits across a range of policy objectives, 
including prevention, protection, support and access to justice. As most Member States have 
this a helpline in place the main impact for victims this measure would be ensuring the 
consistency and quality of the helpline available across Member States.  

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)  
As the information is available confidentially it may be used by victims who are not willing 
to engage with the authorities, such as irregularly staying migrants, or victims who are 
hesitant about speaking out because of shame or stigma associated with the crime. As the 
helpline is free of charge it will help ensure the measure can be accessed by all victims 
regardless of economic status.  

Perpetrators of violence against women and domestic violence  
The helpline could be used by perpetrators who want to change their behaviour. If the 
measure leads to more reporting of crimes, it could ensure more perpetrators are brought to 
justice.  

214 

 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

Wider society  
The measure is not expected to impact wider society, although the helpline would be 
available to anyone in society. 

National authorities 
Member State authorities would be obliged to set up helplines, although most already have 
these in place so the impact would be limited and in a minority of cases adjusting how the 
helpline operates.  

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

The costs for this measure are expected to be borne by the EC, Member State authorities and 
support of other organisations (if running helplines). More specifically:  
The EC may co-fund helplines women victims of violence against women and domestic 
violence, but the costs of these are presented below and relate to public authorities.  
Public authorities will incur costs for setting-up and running helplines.  

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of 
euros) 

Helplines 

0.9 

0.5 – 4.7 

1.4 – 5.6 

The one-off development costs are based an estimate of the budget needed to establish one 
24/7 toll free helpline for women victims of violence against women and domestic violence. 
It is assumed that 12 Member States that do not meet the IC standards would incur these 
costs compared to the baseline. 
Running costs are based on an estimated minimum and maximum budget needed to run one 
helpline per annum. It is assumed that 12 Member States that do not meet the IC standards 
would incur these cost compared to the baseline. 

Overall assessment 

Overall, a helpline will support victims of violence against women and domestic violence by providing information which could include 
information about support and protection available and their rights, which could have benefits across a range of policy objectives, including 
prevention, protection, support and access to justice. As most Member States have this a helpline in place the main impact of this measure would 
be ensuring the consistency and quality of the helpline available across Member States, such as that it is available 24 hours a day and staffed by 
professionals trained in GBV specifically.  
The total investment required amount to 1.4 – 5.6 Million Euros. 
Most Member States have a helpline, therefore the measure is very likely to find political acceptance as it will represent adjusting existing 
provisions. 

1.4.12. Assessment of measure 4.6.c - helplines  

  Obligation to ensure access to a service operating a harmonised European helpline for 
victims  of  gender-based  violence  against  women.  The  helpline  shall  be  available  on 
the number “116 016”.  

  Obligation  to  make  efforts  to  provide  service  also  through  applications  and  by  text 

message. 

Assessment criterion 

Score  Assessment  

215 

 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention) 

Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence 

Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence 

Ensuring the effective availability of 
support for victims of all forms of gender-
based violence against women and 
domestic violence  

Helplines can provide information that may help callers to identify ways to prevent 
themselves or others from violence. As most Member States have this a helpline in place the 
main impact of this measure would be ensuring the consistency and quality of the helpline 
available across Member States, such as that it is available 24 hours a day and staffed by 
professionals trained in GBV specifically (see row 4). A harmonised helpline will help 
increase access for victims outside their normal country of residency who may not know the 
number.    

Helplines can provide information that might assist victims to access protection measures 
which would protection them from further violence. As most Member States have this a 
helpline in place the main impact of this measure would be ensuring the consistency and 
quality of the helpline available across Member States, such as that it is available 24 hours a 
day and staffed by professionals trained in GBV specifically (see row 4). A harmonised 
helpline will help increase access for victims outside their normal country of residency who 
may not know the number.    

Helplines can provide information about support and protection available to victims and 
information their rights. This might encourage victims to report a crime and/or remained 
engaged in the judicial processes which would improve access to justice. As most Member 
States have this a helpline in place the main impact of this measure would be ensuring the 
consistency and quality of the helpline available across Member States, such as that it is 
available 24 hours a day and staffed by professionals trained in GBV specifically (see row 4). 
A harmonised helpline will help increase access for victims outside their normal country of 
residency who may not know the number.    

The impact of this measure on Member States may be limited as the majority already have a 
helpline in place, although there is variation in the scope and availability of the helpline 
which this measure could help to address.  
While all Member States have set up a helpline that can, to various degrees, provide women 
victims of gender-based violence support and information, many do not fully meet the terms 
of measure. In Malta, the Netherlands and Portugal, helplines were not dedicated to the needs 
of women victims of violence, nor specialised in providing advice on the different forms of 
gender-based violence against women with qualified staff. Similarly, in Belgium and France, 
helplines were not available 24 hours a day, and in Portugal, outside of office hours, they 
were not serviced by staff that are not sufficiently trained on violence against women. In 
Finland, Malta, Portugal and Spain helplines only provide support to victims of domestic 
violence.  
A harmonised helpline could help increase ease of access to helplines, especially for 
victims who are not in their normal country of residency and thus might not know the 
helpline number. Similarly, making the service available through smart phone applications 
could increase usage among young people especially. The use of texts messages may be 
more suitable for victims of domestic violence who fear the perpetrator could hear them 
make a call. As this is a completely new measure (no harmonised helpline currently exists) 
its exact impact is hard to anticipate.  
Any harmonised helpline may also have financial and operational benefits for Member 
State authorities as they do not need to run their own helplines but instead can pool resources 
and knowledge. 
A harmonised helpline will also help ensure the quality of the helpline is consistent across 
Member States, ensuring all victims receive the same, high level of support.  

Ensuring that gender based harassment of 
women at work is effectively addressed 

The helpline would provide information relevant to gender based harassment of women at 
work – as a form of GBV - so it could help victims access information they need to report 
such crimes, increasing the likelihood they are effectively addressed.  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

No impact on this objective. 

216 

 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

Social impacts 

Victims of violence against women and domestic violence  
This measure will support victims of violence against women and domestic violence by 
providing information which could include information about support and protection 
available and their rights, which could have benefits across a range of policy objectives, 
including prevention, protection, support and access to justice. As most Member States have 
this a helpline in place the main impact for victims this measure would be ensuring the 
consistency and quality of the helpline available across Member States. 

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)  
The measure will have particular benefit for victims who are outside of their normal country 
of origin as they may not otherwise know the number to call. As the information is available 
confidentially it may be used by victims who are not willing to engage with the authorities, 
such as irregularly staying migrants, or victims who are hesitant about speaking out because 
of shame or stigma associated with the crime. As the helpline is free of charge it will help 
ensure the measure can be accessed by all victims regardless of economic status.  

Perpetrators of violence against women and domestic violence  
The helpline could be used by perpetrators who want to change their behaviour. If the 
measure leads to more reporting of crimes, it could ensure more perpetrators are brought to 
justice.  

Wider society  
The measure is not expected to impact wider society, although the helpline would be 
available to anyone in society. 

National authorities 
Member State authorities would be obliged to set up helplines. 

Fundamental rights 

Victims of violence against women and domestic violence: 

-  Right to life (Article 2) 
-  Right to the integrity of the person (Article 3) 
- 
-  Rights to social assistance and health care (Article 34 and 35) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Prohibition of torture and inhuman or degrading treatment (Article 4) 

Child victims /witnesses 

- 

Protection of the rights of the child (Article 24). 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Public authorities will incur costs in addition to 4.6b in order to set-up and run a 
harmonisation national helpline.  

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of 
euros) 

Helplines 

0.9 

0.5-4.7 

1.4-5.6 

It is assumed 10% more budget is needed in addition to 4.6b to set-up and run a harmonised 
national helpline. 

Overall assessment 

Overall, a helpline will support victims of violence against women and domestic violence by providing information which could include 
information about support and protection available and their rights, which could have benefits across a range of policy objectives, including 
prevention, protection, support and access to justice. As most Member States have this a helpline in place the main impact of this measure would 
be ensuring the consistency and quality of the helpline available across Member States, such as that it is available 24 hours a day and staffed by 
professionals trained in GBV specifically. A harmonised helpline will improve access, especially for victims who are outside of their normal 
country of residency, and help pool resources across Member States.   
The total investment required amount to 2.3 – 12.7 Million Euros. 
Most Member States have a helpline, therefore the measure is likely to find political acceptance as it will represent adjusting existing provisions. 
Having a harmonised helpline may increase the likelihood of political acceptance as resources and knowledge can be pooled.   

217 

 
 
 
 
 
 
 
Assessment of measure 4.7.c - coordination of measures against gender-based 
work harassment  

  Obligation for Member States to ensure that measures against gender-based 

harassment (prevention, support and remedies) are discussed with social partners. 

Assessment criterion 

Score  Assessment  

Effectiveness: contributing to achieving the policy objectives 

Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention) 

As discussions would include measures to prevent gender-based harassment, impact could be 
achieved in this policy objective, although as the content and parameters of the discussions is 
not specified, and the measures does not include an obligations on social partners, the exact 
impact of this measure on prevention is difficult to assess.   

Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence 

As discussions could include protection measures (although this is not specified) impact 
could be achieved in this policy objective, although as the content and parameters of the 
discussions is not specified, and the measures does not include an obligations on social 
partners, the exact impact of this measure on prevention is difficult to assess.   

Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence 

Ensuring the effective availability of 
support for victims of all forms of gender-
based violence against women and 
domestic violence  

Ensuring that gender based harassment of 
women at work is effectively addressed 

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence 

Effectiveness – other impacts 

Social impacts 

As discussions would include measures remedies, for example effective complaint and 
dispute resolution mechanisms and remedies, impact could be achieved in this policy 
objective, although as the content and parameters of the discussions is not specified, and the 
measures does not include an obligations on social partners, the exact impact of this measure 
on prevention is difficult to assess.   

As discussions would include measures to support gender-based harassment, impact could be 
achieved in this policy objective, although as the content and parameters of the discussions is 
not specified, and the measures does not include an obligations on social partners, the exact 
impact of this measure on prevention is difficult to assess.   

It is important that measures against gender based harassment are discussed with social 
partners as they play a potentially crucial role in tackling gender based harassment of women 
at work.  
Discussions may bring greater systematisation and coordination to efforts. Currently, social 
partners engage in a wide range of measures such as through collective bargaining but these 
are carried out on ad hoc basis.  
Specific discussions on GBV could also lead to a shift in current thinking away from 
understanding violence and harassment as a safety and health and wellbeing at work issue 
towards understanding it as an issue of discrimination and gender equality rooted in unequal 
power relations. The Framework Agreement on Harassment and Violence at Work, which is 
described as leading to measures in this area, for example, does not cover GBV.  
As the content and parameters of the discussions is not specified, and the measures does not 
include an obligations on social partners, its impact on effectively addressing gender based 
harassment of women at work is hard to assess.  

Coordination between social partners and Member State authorities is vital for ensuring 
effective governance structures for addressing gender based harassment of women at work as 
social partners are key stakeholders in this issue.   

Victims of violence against women and domestic violence  
Discussions could lead to measures and a more coordinated approach between Member State 
authorities and social partners for victims of gender-based harassment at work, although 
exact measures are not clear from this measure.  

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)  
The measure as the potential impact on victims of gender based harassment at work.  

Perpetrators of violence against women and domestic violence  
The measure could include preventative actions to prevent actions by potential perpetrators 

218 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment criterion 

Score  Assessment  

or remedial actions to bring perpetrators to justice.    

Wider society  
No impact. 

National authorities 
The measure includes an obligation on Member State authorities to engage in discussion with 
social partners about GBV which is not currently widely in place so could have a significant 
impact on them.  

Fundamental rights 

Victims of sex-based harassment 

-  Right to fair and just working conditions (Article 31) 
-  Right to an effective remedy and to a fair trial (Article 47) 

Environmental impacts 

No impacts expected. 

Efficiency: comparison of benefits and costs  

Administrative and compliance costs 

Low to zero – negligible costs of discussion of measures with social partners. 

Overall assessment 

Overall, discussions are a crucial first step in ensuring a coordinated approach between key stakeholders to prevent and tackle gender-based 
harassment at work, as such discussions are not widely in place at the moment, and social partners largely engage in their own ad hoc measures 
which often are not gender-sensitive. However, the extent of the impact on victims will depend on whether the discussion lead to concrete actions 
by social partners.  
The total investment required is negilble. 
The measures will probably find political acceptance among Member States as it only requires discussion with social partners, not to 
oblige/encourage social partners to take particular actions.  

 Problem area: coordination of measures on violence against women and domestic 

violence 

1.5.1. Assessment of measure 5.1.b - monitoring, including data collection   

  Voluntary participation in EU-level surveys. 
  Obligation to regularly collect disaggregated relevant data. 

Score   Assessment   

Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention)  
Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence  
Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence  

Data could offer information about the current need for prevention measures (such as high 
prevalence) and be used as an indicator of the effectiveness of prevention measures in place 
(see row 6).    

Data could offer information to assess whether current protection measures effectively 
protect victims from further violence, particularly if data includes number of emergency 
barring orders/protection orders (see row 6) 

Data collection about prosecution and conviction can provide clear indicators of whether 
victims have effective access to justice. Harmonisation of data across EU countries would 
have a particular impact in this regard, however note that for this measure participation in 
EU-level surveys is voluntary. 
Currently, data is rarely disaggregated on the basis of all of the categories mentioned in 
this measure, for example it is not always sex disaggregated, only includes the 
perpetrator and not the victim, or does not include the type of relationship between the 
perpetrator and the victim (see row 6). 
Data collected may help support services understand the scale and need of victims and thus 
better tailor their services (see row 6). 

Ensuring the effective availability of support 
for victims of all forms of gender-based 
violence against women and domestic 
violence   

219 

 
 
 
 
 
 
  
  
  
  
Ensuring that gender based harassment of 
women at work is effectively addressed    

Data could offer information about a range of issue relevant to ensuring gender based 
harassment of women at work is effectively addressed, including data about prevalence, 
persecution and conviction related to cases in work environments (see row 6).  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  

Effectiveness – other impacts  
Social impacts  

Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

This measure will implement voluntary participation in EU-level surveys and an 
obligation to regularly collect disaggregated relevant data. 

Data collection is important to plan and coordinate measures effectively. Collecting 
data at regular intervals allows tracking of progress over time and can form part of 
monitoring and evaluating the effectiveness of measures in place.  

Stakeholders widely perceive that there is not sufficient data about VAW/DV. Under this 
measure Member States should be obliged to collect data on victims and perpetrators 
disaggregated by sex, age, type of violence, the relationship of the victim to the perpetrator 
and geographical location. Recorded data should also contain information on conviction rates 
of perpetrators of all forms of violence against women. 

Population surveys about prevalence is also important to understand prevalence, 
as low reporting meaning the true prevalence is often not captured. Although 
countries do carry them out at a national level, participation in EU level surveys is 
important for providing an EU-wide picture. The Fundamental Rights Agency survey 
in 2014, for example, had a significant impact on the field and is widely cited so EU 
Member State participation is very important. However, note that in this measure 
participation in EU-level surveys is voluntary. 

Victims of violence against women and domestic violence   
Improved data collection could improve a wide range of measures in place for victims.  

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   
Data collection should aim to collect data from all victims to ensure it captures the needs and 
experiences of all victims.  

Perpetrators of violence against women and domestic violence   
Data collection could include perpetrators, for example, their relationship to the victim and 
their gender. Data could inform measures that target perpetrators such as prevention 
measures and increased prosecution.  

Wider society    
Wider society would be included in population surveys.  

National authorities  
The measure would have a significant impact on national authorities who would be 
encouraged/obligated to collect data.  

The measure in itself would not have an impact on fundamental rights (with the exception of 
the fact that data protection needs to be taken into account), but it would contribute to 
evidence-based policy making that could enhance all fundamental rights considered.  
No impacts expected.  

Overall assessment  
Overall, this measure could address the significant lack of data on GBV, particularly in comparative form across EU Member States, and provide 
crucial information to inform a wide range of measures across the policy objectives. The lack of data on prevalence in particular means the scale of 
the problem is not understood. Data is crucial for monitoring of the situation and assessment of the successful of measures in place.  

Low to zero – Member States have already mapped alignment with ICCS crime statistics and 
therefore, no additional costs are expected 

The total investment required is negligible.   

The measure may struggle to find political acceptance because it would require a large administrative exercise by Member State authorities, across 
different government bodies, to collect the data as data is not readily available and not in compliance with EU standards. Similarly, population 
surveys involve significant resources to carry out.  

1.5.2. Assessment of measure 5.1.c.I Data collection   

  Obligatory participation in EU-level GBV-surveys. 

220 

 
  
  
  
 
 
 
 
  
  
  
  
 
 
 
  Obligation to regularly collect disaggregated relevant data in line with harmonised 

minimum requirements. 

Score   Assessment   

Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the Istanbul 
Convention)  
Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from (further) 
violence  
Ensuring the effective access to justice 
for victims of all forms of gender-
based violence against women and 
domestic violence  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence   
Ensuring that gender based harassment 
of women at work is effectively 
addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  

Effectiveness – other impacts  
Social impacts  

Data could offer information about the current need for prevention measures (such as high 
prevalence) and be used as an indicator of the effectiveness of prevention measures in place (see 
row 6).    

Data could offer information to assess whether current protection measures effectively protect 
victims from further violence, particularly if data includes number of emergency barring 
orders/protection orders (see row 6) 

Data collection about prosecution and conviction can provide clear indicators of whether victims 
have effective access to justice. Harmonisation of data across EU countries would have a particular 
impact in this regard.  
Currently, data is rarely disaggregated on the basis of all of the categories mentioned in this 
measure, for example it is not always sex disaggregated, only includes the perpetrator and not 
the victim, or does not include the type of relationship between the perpetrator and the victim 
(see row 6). 
Data collected from NGOs, such as victim support services, could provide crucial information to 
assess the availability of support for victims.  

Data could offer information about a range of issue relevant to ensuring gender based harassment of 
women at work is effectively addressed, including data about prevalence, persecution and 
conviction related to cases in work environments (see row 6).  

This measure will introduce obligatory participation in EU-level GBV-surveys and an 
obligation to regularly collect disaggregated relevant data in line with harmonised minimum 
requirements. 

Data collection is important to plan and coordinate measures effectively. Collecting data at 
regular intervals allows tracking of progress over time and can form part of monitoring and 
evaluating the effectiveness of measures in place.  

Stakeholders widely perceive that there is not sufficient data about VAW/DV. Under this measure 
Member States should be obliged to collect data on victims and perpetrators disaggregated by sex, 
age, type of violence, the relationship of the victim to the perpetrator and geographical location. 
Recorded data should also contain information on conviction rates of perpetrators of all forms of 
violence against women. 

Uniform EU-level standards for administrative data collection are not in place, such as 
according to ISSC standards, which hampers the ability to understand trends across 
Member States. There are differences in the legal and operational definitions of the crimes 
used for data collection purposes in Member States, the methods used for recording 
incidents of violence vary making comparisons between countries impossible and 
availability of national administrative data is limited. The measure will introduce an 
Obligation to regularly collect disaggregated relevant data in line with harmonised minimum 
requirements, which will improve on the issues described.   

Population surveys about prevalence is also important to understand prevalence, as low 
reporting meaning the true prevalence is often not captured. Although countries do carry 
them out at a national level, participation in EU level surveys is important for providing an 
EU-wide picture. The Fundamental Rights Agency survey in 2014, for example, had a 
significant impact on the field and is widely cited so EU Member State participation is very 
important. The measure will introduce obligatory participation in EU-level GBV-surveys 
which will greatly enhance understanding. 

Victims of violence against women and domestic violence   
Improved data collection could improve a wide range of measures in place for victims.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)   
Data collection should aim to collect data from all victims to ensure it captures the needs and 

221 

 
 
  
  
  
  
  
  
  
 
experiences of all victims.  

Perpetrators of violence against women and domestic violence   
Data collection could include perpetrators, for example, their relationship to the victim and their 
gender. Data could inform measures that target perpetrators such as prevention measures and 
increased prosecution.  

Wider society    
Wider society would be included in population surveys.  

National authorities  
The measure would have a significant impact on national authorities who would be 
encouraged/obligated to collect data.  

Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs    

The measure in itself would not have an impact on fundamental rights (with the exception of the fact 
that data protection needs to be taken into account), but it would contribute to evidence-based policy 
making that could enhance all fundamental rights considered.  
No impacts expected.  

Public authorities will incur costs for participating in centralisation surveys at the EU-level and to 
collect disaggregated statistical data meeting ICCS standards. 

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of 
euros) 

0.1 

 3.7 

3.8 

Monitoring and 
data collection 

The one-off development costs are based on the estimated cost changing the national data collection 
system to record by ICCS standard. This is measured by the estimated hourly rate of web developed 
assuming that 100 hours of web-development are needed to change to data collection system.  
Running costs are based on estimated costs to fill questionnaires both for a centralised survey at the 
EU-level and the national administrative collection. For the former, costs are calculated by 
multiplying the expected hours needed to complete data for one respondent in the sample (approx.1-
hour) with the estimated sample size of EU-surveys with the national hourly wage of public 
administrators. For the latter, costs are calculated by multiplying the hours needed to complete data 
for three administrative data collections (approx.100-hours each) with the national hourly wage of 
public administration. Furthermore, maintenance costs of estimated for the administrative data 
collections. The baseline assessment finds that no MS collects data with ICCS standards so all MS 
would costs.  

Overall assessment  
Overall, this measure could address the significant lack of data on GBV, particularly in comparative form across EU Member States, and provide 
crucial information to inform a wide range of measures across the policy objectives. The lack of data on prevalence in particular means the scale of 
the problem is not understood. Data is crucial for monitoring of the situation and assessment of the successful of measures in place.  

The total investment required amount to 3.8 Million Euros. 

The measure may struggle to find political acceptance because it would require a large administrative exercise by Member State authorities, across 
different government bodies, to collect the data as data is not readily available and not in compliance with EU standards. Similarly, population 
surveys involve significant resources to carry out.  

1.5.3. Assessment of measure 5.1.c.II - data collection   

  Obligatory participation in EU-level GBV-surveys. 
  Full harmonisation of administrative data collection on violence against women and 

domestic violence. 

Score   Assessment   

Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for 
preventing gender-based violence 
against women and domestic violence 
(in line with Chapter III of the Istanbul 
Convention)  

Data could offer information about the current need for prevention measures (such as high 
prevalence) and be used as an indicator of the effectiveness of prevention measures in place (see 
row 6).    

222 

 
 
 
 
  
  
  
 
 
 
 
 
 
  
Ensuring that victims and potential 
victims of gender-based violence 
against women and domestic violence 
are effectively protected from (further) 
violence  
Ensuring the effective access to justice 
for victims of all forms of gender-
based violence against women and 
domestic violence  

Ensuring the effective availability of 
support for victims of all forms of 
gender-based violence against women 
and domestic violence   
Ensuring that gender based harassment 
of women at work is effectively 
addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  

Effectiveness – other impacts  
Social impacts  

Data could offer information to assess whether current protection measures effectively protect 
victims from further violence, particularly if data includes number of emergency barring 
orders/protection orders (see row 6) 

Data collection about prosecution and conviction can provide clear indicators of whether victims 
have effective access to justice. Harmonisation of data across EU countries would have a particular 
impact in this regard.  
Currently, data is rarely disaggregated on the basis of all of the categories mentioned in this 
measure, for example it is not always sex disaggregated, only includes the perpetrator and not 
the victim, or does not include the type of relationship between the perpetrator and the victim 
(see row 6). 
Data collected from NGOs, such as victim support services, could provide crucial information to 
assess the availability of support for victims.  

Data could offer information about a range of issue relevant to ensuring gender based harassment of 
women at work is effectively addressed, including data about prevalence, persecution and 
conviction related to cases in work environments (see row 6).  

This measure will introduce obligatory participation in EU-level GBV-surveys and full 
harmonisation of administrative data collection on violence against women and domestic 
violence, which will greatly improve data collection. 

Data collection is important to plan and coordinate measures effectively. Collecting data at 
regular intervals allows tracking of progress over time and can form part of monitoring and 
evaluating the effectiveness of measures in place.  

Stakeholders widely perceive that there is not sufficient data about VAW/DV. Under this measure 
Member States should be obliged to collect fully harmonised data on victims and perpetrators 
disaggregated by sex, age, type of violence, the relationship of the victim to the perpetrator and 
geographical location. Recorded data should also contain information on conviction rates of 
perpetrators of all forms of violence against women. 

Uniform EU-level standards for administrative data collection are not in place, such as 
according to ISSC standards, which hampers the ability to understand trends across 
Member States. There are differences in the legal and operational definitions of the crimes 
used for data collection purposes in Member States, the methods used for recording 
incidents of violence vary making comparisons between countries impossible and 
availability of national administrative data is limited. The measure will introduce full 
harmonisation of administrative data collection on violence against women and domestic 
violence, which will greatly improve data collection. 

Population surveys about prevalence is also important to understand prevalence, as low 
reporting meaning the true prevalence is often not captured. Although countries do carry 
them out at a national level, participation in EU level surveys is important for providing an 
EU-wide picture. The Fundamental Rights Agency survey in 2014, for example, had a 
significant impact on the field and is widely cited so EU Member State participation is very 
important. The measure will introduce obligatory participation in EU-level GBV-surveys 
which will greatly enhance understanding. 

Victims of violence against women and domestic violence   
Improved data collection could improve a wide range of measures in place for victims.  

Particular groups of victims (child victims and witnesses, victims at risk of intersectional 
discrimination)   
Data collection should aim to collect data from all victims to ensure it captures the needs and 
experiences of all victims.  

Perpetrators of violence against women and domestic violence   
Data collection could include perpetrators, for example, their relationship to the victim and their 
gender. Data could inform measures that target perpetrators such as prevention measures and 
increased prosecution.  

Wider society    
Wider society would be included in population surveys.  

National authorities  

223 

 
  
  
  
  
  
  
 
 
 
 
Fundamental rights  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs    

The measure would have a significant impact on national authorities who would be 
encouraged/obligated to collect data.  

The measure in itself would not have an impact on fundamental rights (with the exception of the fact 
that data protection needs to be taken into account), but it would contribute to evidence-based policy 
making that could enhance all fundamental rights considered.  
No impacts expected.  

Public authorities will incur costs for participating in centralisation surveys at the EU-level and to 
collect disaggregated statistical data meeting ICCS standards. 

One-off 
development cost 

Running cost per 
annum 

Total EU cost 
(Millions of 
euros) 

0.1 

 3.7 

3.8 

Monitoring and 
data collection 

The one-off development costs are based on the estimated cost changing the national data collection 
system to record by ICCS standard. This is measured by the estimated hourly rate of web developed 
assuming that 100 hours of web-development are needed to change to data collection system.  
Running costs are based on estimated costs to fill questionnaires both for a centralised survey at the 
EU-level and the national administrative collection. For the former, costs are calculated by 
multiplying the expected hours needed to complete data for one respondent in the sample (approx.1-
hour) with the estimated sample size of EU-surveys with the national hourly wage of public 
administrators. For the latter, costs are calculated by multiplying the hours needed to complete data 
for three administrative data collections (approx.100-hours each) with the national hourly wage of 
public administration. Furthermore, maintenance costs of estimated for the administrative data 
collections. The baseline assessment finds that no MS collects data with ICCS standards so all MS 
would costs.  

Overall assessment  
Overall, this measure could address the significant lack of data on GBV, particularly in comparative form across EU Member States, and provide 
crucial information to inform a wide range of measures across the policy objectives. The lack of data on prevalence in particular means the scale of 
the problem is not understood. Data is crucial for monitoring of the situation and assessment of the successful of measures in place.  

The total investment required amount to 3.8 Million Euros. 

The measure may struggle to find political acceptance because it would require a large administrative exercise by Member State authorities, across 
different government bodies, to collect the data as data is not readily available and not in compliance with EU standards. Similarly, population 
surveys involve significant resources to carry out.  

1.5.4. Assessment of measure 5.2.b – multi-agency service provision 

Measures strengthening multi-agency cooperation between law enforcement, judiciary, social 
and health services by coordinated referral mechanisms. 

Score   Assessment   

Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention)  
Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence  
Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence  
Ensuring the effective availability of support 
for victims of all forms of gender-based 
violence against women and domestic 
violence   

No impact on this objective.  

No impact on this objective.  

No impact on this objective.  

Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms may particularly help referrals 
to support agencies and improve access to support for victims.  

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Ensuring that gender based harassment of 
women at work is effectively addressed    

No impact on this objective.  

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  

Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms is important to allow for a 
comprehensive and appropriate handling of referrals of cases of GBVVAW between 
different actors involved in the governance structures of GBVAW.  

Effectiveness – other impacts  
Social impacts  

Fundamental rights  

Victims of violence against women and domestic violence   
The measure could improve referrals between actors who make up the governance structure 
related to GBVAW and ensure victims can access support and protection available.   

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   
No impact.  

Perpetrators of violence against women and domestic violence   
No impact.  

Wider society    
No impact.  

National authorities  
Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms will help ensure the smooth 
referral of cases between different actors involved in the governance structures of GBVAW 
and thus shape the functioning of national authorities.  
Victims of violence against women and domestic violence:  

  Right to life (Article 2(  
  Right to the integrity of the person (Article 3)  
 

Prohibition of torture and inhuman or degrading treatment (Article 4)  

Child victims /witnesses  

 
No impacts expected.  

Protection of the rights of the child (Article 24).  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  
Overall assessment  
Overall, Measures strengthening multi-agency cooperation between law enforcement, judiciary, social and health services by coordinated referral 
mechanisms is important to allow for a comprehensive and appropriate handling of referrals of cases of GBVVAW between different actors 
involved in the governance structures of GBVAW. It can help improve the overall governance structure and ensure victims access support and 
protection available.  

Zero – costs covered in training of relevant professionals as part of prevention measures.  

The total investment required is negligible.   

It is difficult to determine whether political acceptance of this measure. 

1.5.5. Assessment of measure 5.2.c.I – multi-agency service provision 

Measures strengthening multi-agency cooperation between law enforcement, judiciary, social 
and health services by coordinated referral mechanisms. 

Obligation  to  provide  one-stop  online  access  to  relevant  protection  and  support  services. 
Encouragement to locate a number of services in the same premises. 

Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for preventing 
gender-based violence against women and 

Score   Assessment   

No impact on this objective.  

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domestic violence (in line with Chapter III 
of the Istanbul Convention)  
Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence  
Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence  
Ensuring the effective availability of support 
for victims of all forms of gender-based 
violence against women and domestic 
violence   

Ensuring that gender based harassment of 
women at work is effectively addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  

Effectiveness – other impacts  
Social impacts  

Fundamental rights  

No impact on this objective.  

No impact on this objective.  

Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms may particularly help referrals 
to support agencies and improve access to support for victims.  

Victims will also be more able to locate and access support through the obligation to provide 
one-stop online access to relevant protection and support services, and the location of a 
number of services in the same premises. However, co-locating relevant services will only be 
encouraged, rather than required. 
No impact on this objective.  

Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms, as well as a one-stop online 
access to relevant protection and support services, and the location of a number of services in 
the same premises is clearly important to allow for a comprehensive and appropriate 
handling of referrals of cases of GBVVAW between different actors involved in the 
governance structures of GBVAW.  

Victims of violence against women and domestic violence   
The measure could improve referrals between actors who make up the governance structure 
related to GBVAW and ensure victims can access support and protection available.   
One-stop online access to relevant protection and support services, and the location of a 
number of services in the same premises will also help victims locate and access varied 
support services much more easily. 

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   
No impact.  

Perpetrators of violence against women and domestic violence   
No impact.  

Wider society    
No impact.  

National authorities  
Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms will help ensure the smooth 
referral of cases between different actors involved in the governance structures of GBVAW 
and thus shape the functioning of national authorities.  
National authorities will also be required to provide one-stop online access to relevant 
protection and support services, and will be encouraged to locate a number of services in the 
same premises. 
Victims of violence against women and domestic violence:  

  Right to life (Article 2(  
  Right to the integrity of the person (Article 3)  
 

Prohibition of torture and inhuman or degrading treatment (Article 4)  

Child victims /witnesses  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

 
No impacts expected.  

Protection of the rights of the child (Article 24).  

An annual cost of € 3,571,651 to run the information centres. This is based on a minimum of 
four employees per country, increased for larger countries. 

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Overall assessment  
Overall, measures strengthening multi-agency cooperation between law enforcement, judiciary, social and health services by coordinated referral 
mechanisms is important to allow for a comprehensive and appropriate handling of referrals of cases of GBVVAW between different actors 
involved in the governance structures of GBVAW. The obligation to provide one-stop online access to relevant protection and support services and 
the encouragement to locate a number of services in the same premises will also help achieve this aim and will make it easier for victims to locate 
appropriate support. It can help improve the overall governance structure and ensure victims access support and protection available.  

The total investment required is negligible.   

It is difficult to determine political acceptance of this measure. 

1.5.6. Assessment of measure 5.2.c.II – multi-agency service provision 

Measures strengthening multi-agency cooperation between law enforcement, judiciary, social 
and health services by coordinated referral mechanisms. 

Obligation for MS to provide multi-agency and multi-disciplinary one-stop access to relevant 
protection and support services in the same premises. 

Score   Assessment   

Assessment criterion  
Effectiveness: contributing to achieving the policy objectives  
Ensuring effective measures for preventing 
gender-based violence against women and 
domestic violence (in line with Chapter III 
of the Istanbul Convention)  
Ensuring that victims and potential victims 
of gender-based violence against women 
and domestic violence are effectively 
protected from (further) violence  
Ensuring the effective access to justice for 
victims of all forms of gender-based 
violence against women and domestic 
violence  
Ensuring the effective availability of support 
for victims of all forms of gender-based 
violence against women and domestic 
violence   

No impact on this objective.  

No impact on this objective.  

No impact on this objective.  

Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms may particularly help referrals 
to support agencies and improve access to support for victims.  

Ensuring that gender based harassment of 
women at work is effectively addressed    

Ensuring more effective governance 
structures in relation to gender-based 
violence against women and domestic 
violence  

Effectiveness – other impacts  
Social impacts  

Victims will also be more able to locate and access support through the obligation to provide 
one-stop online access to relevant protection and support services, and the location of a 
number of services in the same premises. 
No impact on this objective.  

Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms, as well as a one-stop online 
access to relevant protection and support services, and the location of a number of services in 
the same premises is clearly important to allow for a comprehensive and appropriate 
handling of referrals of cases of GBVVAW between different actors involved in the 
governance structures of GBVAW.  

Victims of violence against women and domestic violence   
The measure could improve referrals between actors who make up the governance structure 
related to GBVAW and ensure victims can access support and protection available.   
One-stop online access to relevant protection and support services, and the location of a 
number of services in the same premises will also help victims locate and access varied 
support services much more easily. 

Particular groups of victims (child victims and witnesses, victims at risk of 
intersectional discrimination)   

227 

 
 
 
 
 
  
  
  
  
 
  
  
 
  
 
No impact.  

Perpetrators of violence against women and domestic violence   
No impact.  

Wider society    
No impact.  

National authorities  
Measures strengthening multi-agency cooperation between law enforcement, judiciary, 
social and health services by coordinated referral mechanisms will help ensure the smooth 
referral of cases between different actors involved in the governance structures of GBVAW 
and thus shape the functioning of national authorities.  
National authorities will also be required to provide one-stop online access to relevant 
protection and support services, and will be required to locate a number of services in the 
same premises. 
Victims of violence against women and domestic violence:  

Fundamental rights  

  Right to life (Article 2(  
  Right to the integrity of the person (Article 3)  
 

Prohibition of torture and inhuman or degrading treatment (Article 4)  

Child victims /witnesses  

Environmental impacts  
Efficiency: comparison of benefits and costs   
Administrative and compliance costs  

 
No impacts expected.  

Protection of the rights of the child (Article 24).  

An annual cost of € 3,571,651 to run the information centres. This is based on a minimum of 
four employees per country, increased for larger countries. 

Overall assessment  
Overall, measures strengthening multi-agency cooperation between law enforcement, judiciary, social and health services by coordinated referral 
mechanisms is important to allow for a comprehensive and appropriate handling of referrals of cases of GBVVAW between different actors 
involved in the governance structures of GBVAW. The obligation to provide one-stop online access to relevant protection and support services and 
the requirement to locate a number of services in the same premises will also help achieve this aim and will make it easier for victims to locate 
appropriate support. It can help improve the overall governance structure and ensure victims access support and protection available.  

The total investment required is negligible.   

It is difficult to determine political acceptance of this measure. 

228 

 
 
 
 
  
  
  
 
 
 
 
ANNEX 6: Overview of available data on gender-based violence against women 

 The Fundamental Rights Survey - Crime, Safety and Victims’ Rights, European 

Union Agency for Fundamental Rights (2021)388: 

  Nearly one in 10 people (9 %) in the EU-27 experienced physical violence in the five 
years  before  the  survey,  and  6 %  experienced  physical  violence  in  the  12  months 
before  the  survey.  This  corresponds  to  more  than  22 million  people  experiencing 
physical violence in one year in the EU-27 (an estimate based on the results of the 
survey relative to the EU’s population). 

  Incidents of physical violence against men (excluding specifically sexual violence) 
most often took place in public settings (39 %), such as streets, parks or other public 
places. Incidents of physical violence against women (again excluding specifically 
sexual violence) most often took place in their own home (37 %).  

  For  men,  these  incidents  most  often  involved  a perpetrator  they  did  not  know 
(42 %). In contrast, physical violence against women most often involved a family 
member  or  a relative  as  the  perpetrator.  These  survey  results  should  be  read 
alongside  the  earlier  findings  of  FRA’s  violence  against  women  survey,  which 
measured in  more detail women’s experiences of violence, including intimate partner 
violence and sexual violence, which disproportionately affect women. 

  In the majority of cases of physical violence, the perpetrator was a man or a group 
of men. This was the case in 72 % of incidents of physical violence against men and 
60 % of those against women. 

  In  the  EU-27,  two  in  five  people  (41 %)  experienced  harassment  –  ranging  from 
offensive  and  threatening  comments  in  person  to  offensive  and  threatening  gestures 
and messages sent online, including through social media – in the five years before the 
survey.  In  the  12  months  before  the  survey,  29 %  experienced  harassment.  This 
corresponds  to  almost  110 million  people  in  the  EU-27  experiencing  harassment  in 
a year (an estimate based on the results of the survey relative to the EU’s population).  

  Overall, 14 % of people in the EU experienced cyber-harassment in the five years 
before the survey. This could involve receiving offensive or threatening emails or text 
messages,  or  coming  across  offensive  or  threatening  comments  about  oneself 
disseminated online. 

  Three in five people (61 %) in the age group 16–29 years experienced harassment 
in the five years before the survey. Overall, in  the same age group and time frame, 
27 % experienced cyber-harassment. These are the highest rates in all the age groups, 
with harassment experiences decreasing with age.  

  While  the  prevalence  of  harassment  is  similar  for  women  and  men,  18 %  of  women 
described  the  most  recent  incident  of  harassment  as  being  of  a sexual  nature, 
compared with 6 % of men.  

  Most incidents of physical violence and harassment are not reported to the police. 

388 https://fra.europa.eu/sites/default/files/fra_uploads/fra-2021-crime-safety-victims-rights-summary_en.pdf 
FRA guidance: These survey results should be read alongside the earlier findings of FRA’s violence against women survey, 
which  measured  in  more  detail women’s  experiences  of  violence,  including  intimate  partner  violence  and  sexual  violence, 
which disproportionately affect women. 

229 

 
                                                 
  For fear of being physically or sexually assaulted, or harassed, women engage in active 
risk  avoidance  more  than  men  in  the  three  situations  listed  in  the  survey:  avoiding 
places  where  there  are  no  other  people  around,  avoiding  certain  streets  or  areas,  and 
avoiding being alone with someone they know.  

  Whereas 64 % of women at least sometimes avoid going to places where there are 
no other people around, 36 % of men do so. Avoiding certain situations and places is 
also more common among young people, but with noticeable gender differences. In the 
age  group  16–29  years,  83 %  of  women  and  58 %  of  men  avoid  one  or  more  of  the 
three situations listed in the survey, for fear of assault or harassment.  

  Specifically,  41 %  of  women  at  least  sometimes  avoid  being  alone  with  someone 

they know, for fear of assault or harassment, compared with 25 % of men. 

 ‘The  Covid-19  pandemic  and  intimate  partner  violence  against  women  in  the 

EU’, EIGE (2021)389: 

This study offers a preliminary overview of the measures undertaken across the EU to support 
victims  of  violence  during  the  Covid-19  outbreak  (from  March  until  the  end  of  September 
2020),  identifies  examples  of  promising  practices  and  provides  initial  recommendations  for 
the EU and Member States on how to better support victims during the pandemic, as well as 
in other potential crises. 

An  online  survey  was  sent  to  196  support  services  across  the  EU;  the  survey  ran  for  a 
relatively  long  period,  from  7  September  to  28  September  2020,  in  order  to  maximise  the 
response  rate.  There  were  35  responses  received  in  total  (an  18  %  response  rate),  from  17 
Member States.  

Regarding the services provided:  

  Fourteen survey respondents (40 %), from DK, IE, EL, HR, LT, AT and SE, indicated that 
a  reduction  in  services  had  been  one  of  the  main  challenges  resulting  from  the 
pandemic 

  Twenty-six survey respondents (74 %) (BG, DK, EE, IE, EL, HR, CY, LV, LT, HU, AT, 
RO,  SK,  FI  and  SE)  reported  that  demand  for  their  services  was  either  ‘somewhat’  or 
‘much’  higher  than  prior  to  the  pandemic  with  the  highest  levels  occurring  once 
restrictions  had  started  to  lift  three  interviews  with  service  providers,  one  with  a 
government representative and one with an academic. 

  Twenty-eight survey respondents (80 %) (BG, DK, EE, IE, EL, HR, CY, LV, LT, HU, AT, 
PT,  RO,  SK,  FI  and  SE)  reported  that  the  levels  of  distress  of  victims  were  at  least 
‘somewhat’ higher during Covid-19, with 18 of these (BG, DK, EL, HR, CY, LV, HU, 
PT, RO and SE) considering them to be ‘much higher’ 

Regarding the violence:  

  All participants estimated that the violence perpetuated on the basis of gender was the 

same or increased during the lockdown. 

389  The  Covid-19  pandemic  and  intimate  partner  violence  against  women  in  the  EU,  EIGE  (2021),  available  on:  
https://eige.europa.eu/publications/covid-19-pandemic-and-intimate-partner-violence-against-women-eu  

230 

 
 
 
                                                 
  Over 57% of participants felt that the frequency of violence was somewhat higher. 

  More  than  50%  -  or  one  out  of  two  respondents  -    felt  that  the  distress  level  of  the 

victims was much higher during the lockdown 

 ‘Tackling  violence  against  women  and  domestic  violence  in  Europe:  The  added 
value  of  the  Istanbul  Convention  and  remaining  challenges’,  European  Parliament, 
(2020)390 

  Stakeholders  noted  an  increase  in  contact  to  helplines  for  victims  of  VAW  during  the 
COVID-19 pandemic in Belgium, Finland, Germany, Ireland and Romania. This increase 
ranged from 25 % in Ireland, 30 % in Germany, and over 50 % in Belgium, to 233 % 
in  Romania  and  694  %  in  Finland.  The  periods  over  which  these  increases  were 
measured  differed  between  countries  and  refer  to  individual  helplines.  Other  countries 
reported increases but did not provide supporting data.  

  Certain  stakeholders  noted  an  increase  in  the  demand  for  specialised  support  services 
for  victims  of  VAW  (emergency  accommodation,  counselling  services)  and  emergency 
protection orders issued for DV cases during the COVID-19 pandemic. 

  Stakeholders  reported  an  increase  in  the  number  of  risk  factors  for  VAW  due  to  the 
pandemic  (e.g.  isolation,  stress,  working  from  home),  coupled  with  a  decrease  in 
accessibility of support available to victims.  

  Almost  one-in-three  (29  %)  stakeholders  who  noted  that  the  COVID-19  pandemic  and 
lockdown measures  have resulted in  an increase in  VAW reported that this was due to  a 
lack of access to support services. Barriers to accessing support services included reduced 
staffing levels, limited capacity due to social distancing requirements and fear of accessing 
shelters and exposure to the virus.  

  Over  half  (51  %)  of  respondents  to  the  online  consultation  noted  that  they  had 
partially closed or limited the provision of some services due to lockdown measures. 
One in ten (10%) had to completely close their service. 

  Across  the  28  countries  covered  by  this  study,  an  average  of  six  measures  were 
implemented  per  country  in  relation  to  VAW  -  seven  in  countries  that  have  ratified  the 
Istanbul Convention (from two in Estonia to 14 in Austria) and four in those that have not 

390 https://www.europarl.europa.eu/RegData/etudes/STUD/2020/658648/IPOL_STU(2020)658648_EN.pdf 

231 

 
 
                                                 
 
(from 0 in Hungary and Slovakia to eight in Czechia). Measures included strengthening of 
services,  awareness-raising  campaigns,  integration  of  VAW  in  the  Covid-19  response 
plans, additional funding as well as legal and judicial measures. 

 Combatting  gender-based  violence:  cyber  violence,  European  Parliament 

(2021)391 

  4 to 7 % of women in the EU-27 have experienced cyber harassment during the past 12 

months, while between 1 and 3 % have experienced cyber stalking.392 

  The  economic  assessment  estimated  the  overall  costs  of  cyber  harassment  and  cyber 

stalking at between €49.0 and €89.3 billion. 

  The  overall  costs  of  cyber  harassment  and  cyber  stalking  perpetrated  against  women 

over 18 years of age were estimated to range from €49.0 to 89.3 billion. 

  38%  of  harassed  women  found  their  most  recent  experience  with  online  harassment 
extremely or very upsetting, compared to only 17% of harassed men based on research 
by Pew Research Centre. 

  51% of young women and 42% of young people are reluctant to participate in online 

debates because they were harassed online (EIGE).  

  42% of LGBTQ interviewees from around the world said they are harassed because of 

their gender or sexual identity.393 

  56% of respondents from eight countries (UK, US, Sweden, New Zealand, Italy, Spain, 
Denmark, and Poland) were less able to focus on everyday tasks after being subjected 
to cyber harassment.394 

Open public consultation: Combating gender-based violence – protecting victims and 
punishing offenders, European Commission (2021)395 

  94.2% of respondents considered that it is very important that their Member State takes 

measures to prevent violence against women and domestic violence. 

  61.1% are not aware of prevention programmes set up at the national or local levels for 

perpetrators of violence against women or domestic violence.  

  52.1% thought the law enforcement authorities and judicial authorities of their Member 
State don’t ensure an appropriate follow-up to reports of violence against women and 
domestic violence. 

  70.6% considered that the relevant authorities or services ensure that risk factors, such 
as  serious  safety  concerns  of  the  victim  and  risk  of  repeated  violence,  are  not 
sufficiently take into account at all stages of investigation and court proceedings. 

391 https://www.europarl.europa.eu/thinktank/en/document.html?reference=EPRS_STU(2021)662621.  
392 Compare to FRA estimates that 1 in 10 women (11 %) have experienced cyber harassment or cyber stalking since the age 
of 15 
393 Toxic Twitter. Amnesty International. (2020). Chapter 3: Women’s Experience of Violence and Abuse on Twitter.  
394 Toxic Twitter. Amnesty International. (2020). Chapter 3: Women’s Experience of Violence and Abuse on Twitter. 
395  Open  public  consultations  are  not,  by  nature,  statistically  representative  of  the  population  (unlike,  for  example,  public 
opinion polls). Therefore, their purpose is not to find answers that could be generalised, but rather to gain in-depth insights 
that can shed new light on a range of issues. 

232 

 
                                                 
  67%  considered  that  further  measures  to  improve  access  to  justice  in  matters  of 
violence against women and domestic violence could improve the situation of victims 
at both national and EU level.  

  50.6% are not aware of a workplace policy on sex-based harassment in their company, 
including  but  not  limited  to  identification,  prevention  and  control  of  risks,  complaint 
and investigation procedures, as well as trainings and awareness raising. 

  51% do not know which national authorities or other bodies they can contact in their 

Member State in cases of sex-based harassment at work. 

  61% considered illegal and harmful gendered online content become more common in 

recent years in their Member State. 

  42.6%    think  the  existing  preventive,  intervention  or  support  measures  for  victims  of 

harmful practices against women are not effective. 

  47.9%  are  not  aware  of  any  specific  measures  in  their  Member  Stat  to  address 

psychological violence, including coercive control, been effective. 

  55.1%  considered  there  is  a  regional  differences  in  the  availability  of  preventive, 
protection  and  support  services  regarding  gender-based  violence  against  women  or 
domestic violence. 

  60.8%  considered  of  the  impact  of  the  COVID-19  outbreak  on  gender-based  and 

domestic violence in their Member State as severe. 

Gender, Institutions and Development – OECD (2019)396 

EU  Member 
state in 2019 

Prevalence  of  violence 
against  women    in  the 
lifetime397: 

Legal  framework  on 
against 
violence 
women398 

Attitudes 
violence399: 

toward 

Austria 

Belgium 

Bulgaria 

13% 

24% 

23% 

0.25 

0.5 

0.75 

3% 

2% 

18.2% 

396 OECD (2021), Violence against women (indicator). doi: 10.1787/f1eb4876-en (Accessed on 15 April 2021) available on 
http://www.oecd.org/gender/vaw.htm  

397 This table highlights the percentage of women who have experienced physical and/or sexual violence from an intimate 
partner at some time in their life. 
398 The index provides a measure of the legal frameworks according to this logic:  
 0: The legal framework protects women from violence including intimate partner violence, rape and sexual harassment, 
without any legal exceptions and in a comprehensive approach. 
0.25: The legal framework protects women from violence including intimate partner violence, rape and sexual harassment, 
without any legal exceptions. However, the approach is not comprehensive. 
0.5: The legal framework protects women from violence including intimate partner violence, rape and sexual harassment. 
However, some legal exceptions occur. 
0.75: The legal framework protects women from some forms of violence including intimate partner violence, rape or sexual 
harassment but not all. 
1: The legal framework does not protect women from violence nor intimate partner violence nor rape and sexual harassment. 
399 The percentage of women who agree that a husband/partner is justified in beating his wife/partner under certain 
circumstances 

233 

 
                                                 
Croatia 

Cyprus 

Czech 
Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

13% 

15% 

21% 

32% 

20% 

30% 

26% 

22% 

19% 

21% 

15% 

19% 

32% 

24% 

Luxembourg 

22% 

Malta 

15% 

Netherlands 

25% 

Poland 

Portugal 

Romania 

Slovak 
Republic 

Slovenia 

Spain 

Sweden 

13% 

19% 

24% 

23% 

13% 

13% 

28% 

0.25 

0.25 

0.75 

0.5 

0.25 

0.75 

0.25 

0.75 

0.25 

0.75 

0.25 

0.75 

0.75 

0.5 

0.75 

0.25 

0.75 

0.75 

0.25 

0.25 

0.25 

0.25 

0.5 

0.25 

4.4% 

10.5% 

2% 

0% 

16.9% 

11.2% 

6.6% 

19.6% 

2% 

8.7% 

1% 

5.3% 

2% 

2% 

2% 

0% 

6.4% 

7.9% 

2% 

7.5% 

5% 

15.8% 

0.6% 

10.2% 

 EIGE administrative data and statistics on GBV (2018) 

234 

 
 
EIGE’s statistics on Intimate Partner Violence (IPV)400 result from a joint effort with Member 
States to improve the quality and availability of data on violence against women, to monitor 
institutional progress, and to establish a robust and coordinated response to data collection. 

Data displayed by EIGE on IPV is based on national administrative data collected by EIGE 
against  13  indicators.  The  increased  harmonisation  of  data  collection  across  the  Member 
States will eventually allow for a comparison of scope and trends between the Member States 
based on the 13 indicators. 

The 13 indicators on intimate partner violence are as follows: 

Annual number of women victims of intimate partner violence (aged 18 and over) committed 
by men (aged 18 and over), as recorded by police 

Number of reported offences related to intimate partner violence against women committed 
by men (aged 18 and over) 

Number of men perpetrators of intimate partner violence against women (and percentage of 
male population that are perpetrators) 

Annual number of women victims of physical intimate partner violence (aged 18 and over) 
committed by men (aged 18 and over) as recorded by police 

Annual  number  of  women  victims  of  psychological  intimate  partner  violence  (aged  18  and 
over) committed by men (aged 18 and over) as recorded by police 

Annual  number  of  women  victims  of  sexual  intimate  partner  violence  (aged  18  and  over) 
committed by men (aged 18 and over) as recorded by police 

Annual number of women victims of economic intimate partner violence (aged 18 and over) 
committed by men (aged 18 and over) as recorded by police 

Annual number of women victims reporting rape (aged 18 years and over) committed by men 
(aged 18 and over) as recorded by police 

Women  victims  of  intimate  femicide  (aged  18  and  over)  committed  by  a  male  intimate 
partner (aged 18 and over), as a share of the women victims of homicide aged 18 and over 

Number of protection orders applied and granted in cases of intimate partner violence against 
women by type of courts 

Number of men (aged 18 and over) prosecuted for intimate partner violence against women 

Number of men (aged 18 and over) sentenced for intimate partner violence against women 

Annual  number  of  men  (aged  18  and  over)  sentenced  for  intimate  partner  violence  against 
women held in prison or with a sanction involving a form of deprivation of liberty 

400 Intimate partner violence is ‘[a]ny act of physical, sexual, psychological or economic  violence that occurs between former 
or  current  spouses  or  partners,  whether  or  not  the    perpetrator  shares  or  has  shared  the  same    residence  with  the  victim’ 
(EIGE, 2017b). This definition includes all forms of intimate partner violence. This violence ‘constitutes a form of violence 
which affects women disproportionately and which is therefore distinctly  gendered’ (EIGE, Glossary and Thesaurus). 

235 

 
                                                 
The administrative data on intimate partner violence is not harmonised at EU level and does 
not  enable  comparison  among  the  majority  of  Member  States.  Some  comparison  can  be 
conducted among four Member States: the Czech Republic, Germany, Latvia, Slovenia. 

Annual number of women victims of intimate partner violence 
(18+) by men (18+) recorded by  police
(per hundred thousands of total population)

160

140

120

100

80

60

40

20

0

2014

2015

2016

2017

2018

Czech Republic

Germany

Latvia

Slovenia

Figure 43 - Source: EIGE, https://eige.europa.eu/gender-
statistics/dgs/indicator/genvio_int_adm_ipv__ipv_indic_1/datatable; ESTAT 
https://ec.europa.eu/eurostat/databrowser/view/demo_pjan/default/table?lang=en 

In  addition  to  intimate  partner  violence,  EIGE’s  gender  statistics  database  includes  data  on 
various  forms  of  violence  against  women,  such  as  homicide,  sexual  violence  and  sexual 
harassment at work.  

Data on violence against women published on EIGE’s gender statistics database: 

Physical violence 

Homicide 

Administrative data  

  Available national administrative data on homicide (available for all MS, 2016) 

 

 

 

 

 

Intentional  homicide  and  sexual  offences  by  sex  of  the  victim  and  by  sex  of  the 
perpetrator or suspected  perpetrator  - number  and rate for the  relevant  sex group (2008-
2018) 

Intentional homicide by sex of the perpetrator or suspected perpetrator - number and rate 
for the relevant sex group (2008-2018) 

Intentional  homicide  by  sex  of  the  victim  -  number  and  rate  for  the  relevant  sex  group 
(2008-2018) 

Intentional  homicide  by  sex  of  the  victim  and  by  sex  of  the  perpetrator  or  suspected 
perpetrator - number and rate for the relevant sex group (2008-2018) 

Intentional homicide committed by family members other than intimate partners - number 
and rate for the relevant sex group of victim (2008-2018)  

 

Intentional homicide victims by age and sex - number and rate for the relevant sex and age 

236 

 
 
 
groups (2008-2018) 

 

Intentional homicide victims by victim-offender relationship and sex - number and rate for 
the relevant sex group (2008-2018) 

Other physical violence than homicide (IPV and non-IPV) 

Survey data  

  Over  the  last  12  months,  during  the  course  of  your  work  have  you  been  subjected  to 

physical violence? (% of respondents, 15+ workers) (2010, 2015) 

  Prevalence of physical  and sexual  violence by intimate partners since the age of 15 and 
during the 12 months prior to the interview by the age, education, and main activity of the 
victim and relationship between the victim and the perpetrator (2012) 

  Prevalence of physical and sexual violence by persons other than intimate partners since 
the age of 15 and during the 12 months prior to the interview by the age, education, and 
main activity of the victim (2012) 

  Prevalence of physical and sexual violence since the age of 15 and during the 12 months 
prior  to  the  interview  by  the  age,  education,  and  main  activity  of  the  victim  and 
relationship between the victim and the perpetrator (2012) 

  Prevalence of physical violence by intimate partners since the age of 15 and during the 12 
months prior to the interview by the age, education, and main activity of the victim and 
relationship between the victim and the perpetrator (2012) 

  Prevalence of physical violence by persons other than intimate partners since the age of 15 
and during the 12 months prior to the interview by the age, education, and main activity of 
the victim (2012) 

  Prevalence of physical violence since the age of 15 and during the 12 months prior to the 
interview by the age, education, and main activity of the victim and relationship between 
the victim and the perpetrator (2012) 

Sexual violence 

Rape 

Survey data (IPV and non-IPV) 

  Prevalence of rape by intimate partners since the age of 15 and during the 12 months prior 
to  the  interview  by  the  age,  education,  and  main  activity  of  the  victim  and  relationship 
between the victim and the perpetrator (2012) 

  Prevalence of rape by persons other than intimate partners since the age of 15 and during 
the 12 months prior to the interview by the age, education, and main activity of the victim 
(2012) 

  Prevalence of rape since the age of 15 and during the 12 months prior to the interview by 
the age, education, and main activity of the victim and relationship between the victim and 
the perpetrator (2012) 

Administrative data 

  Available national administrative data on rape (available for all MS) 

  Rape by sex of the perpetrator or suspected perpetrator - number and rate for the relevant 

237 

 
 
 
sex group (2008-2018) 

  Rape by sex of the victim - number and rate for the relevant sex group (2008-2018) 

  Rape by sex of the victim and by sex of the perpetrator or suspected perpetrator - number 

and rate for the relevant sex group (2008-2018) 

Sexual assault (IPV and non-IPV) 

Survey data 

  Over the last month, during the course of your work have you been subjected to unwanted 
sexual attention? (% of respondents, 15+ workers) (1995, 2000, 2001, 2005, 2010, 2015) 

  Prevalence  of  sexual  assault  by  intimate  partners  since  the  age  of  15  and  during  the  12 
months prior to the interview by the age, education, and main activity of the victim and 
relationship between the victim and the perpetrator (2012) 

  Prevalence  of  sexual  assault  by  persons  other  than  intimate  partners  since  the  age  of  15 
and during the 12 months prior to the interview by the age, education, and main activity of 
the victim (2012) 

  Prevalence  of  sexual  assault  since  the  age  of  15  and  during  the  12  months  prior  to  the 
interview by the age, education, and main activity of the victim and relationship between 
the victim and the perpetrator (2012) 

Administrative data 

  Available national administrative data on sexual assault (available for all MS apart from 

IT and BG).  

  Sexual  assault  (other  than  rape)  by  sex  of  the  perpetrator  or  suspected  perpetrator  - 

number and rate for the relevant sex group(2008-2018) 

  Sexual assault (other than rape) by sex of the victim - number and rate for the relevant sex 

group (2008-2018) 

  Sexual  assault  (other  than  rape)  by  sex  of  the  victim  and  by  sex  of  the  perpetrator  or 

suspected perpetrator - number and rate for the relevant sex group (2008-2018) 

Sexual harassment at work  

Survey data 

  Over  the  last  12  months,  during  the  course  of  your  work  have  you  been  subjected  to 

harassment? (% of respondents, 15+ workers) (2005, 2010, 2015) 

  Over the last month, during the course of your work have you been subjected to unwanted 
sexual attention? (% of respondents, 15+ workers) (1995, 2000, 2001, 2005, 2010, 2015) 

Physical and sexual violence by IPV and non-IPV  

Survey data 

  Prevalence of physical  and sexual  violence by intimate  partners since the age of 15 and 
during the 12 months prior to the interview by the age, education, and main activity of the 
victim and relationship between the victim and the perpetrator (2012) 

238 

 
 
 
 
  Prevalence of physical and sexual violence by persons other than intimate partners since 
the age of 15 and during the 12 months prior to the interview by the age, education, and 
main activity of the victim (2012) 

  Prevalence of physical and sexual violence since the age of 15 and during the 12 months 
prior  to  the  interview  by  the  age,  education,  and  main  activity  of  the  victim  and 
relationship between the victim and the perpetrator (2012) 

  Prevalence of sexual violence by intimate partners since the age of 15 and during the 12 
months prior to the interview by the age, education, and main activity of the victim and 
relationship between the victim and the perpetrator (2012) 

  Prevalence of sexual violence by persons other than intimate partners since the age of 15 
and during the 12 months prior to the interview by the age, education, and main activity of 
the victim (2012) 

  Prevalence of sexual violence since the age of 15 and during the 12 months prior to the 
interview by the age, education, and main activity of the victim and relationship between 
the victim and the perpetrator (2012) 

Administrative data 

  Available national administrative data on other sexual offences (available for AT, BE, FI, 

FR, DE, DU, IE, LV, LT, MT, NL, RO, SK Sl, ES, SE) 

 

Intentional  homicide  and  sexual  offences  by  sex  of  the  victim  and  by  sex  of  the 
perpetrator or suspected  perpetrator  - number  and rate for the  relevant  sex group (2008-
2018) 

  Sexual offences by sex of the perpetrator or suspected perpetrator  - number and rate for 

the relevant sex group 

  Sexual offences by sex of the victim - number and rate for the relevant sex group (2008-

2018) 

  Sexual offences by sex of the victim and by sex of the perpetrator or suspected perpetrator 

- number and rate for the relevant sex group (2008-2018) 

Psychological violence 

Survey data on discrimination and harassment in general and at work 

 

In  the  past  12  months  have  you  personally  felt  discriminated  against  or  harassed  on  the 
basis of one or more of the following grounds? (Percentage of respondents who mentioned 
each ground of discrimination) (2015, 2019) 

  Over  the  last  12  months,  during  the  course  of  your  work  have  you  been  subjected  to 

bullying? (% of respondents, 15+ workers) (2010, 2015) 

  Over  the  last  12  months,  during  the  course  of  your  work  have  you  been  subjected  to 

harassment? (% of respondents, 15+ workers) (2005, 2010, 2015) 

  Over  the  last  month,  during  the  course  of  your  work  have  you  been  subjected  to 

humiliating behaviours? (% of respondents, 15+ workers) (2015) 

  Over the last month, during the course of your work have you been subjected to threats? 

(% of respondents, 15+ workers) (2015) 

  Over  the  last  month,  during  the  course  of  your  work  have  you  been  subjected  to  verbal 

239 

 
 
abuse? (% of respondents, 15+ workers) (2010, 2015) 

Administrative data on stalking 

  Available national administrative data on stalking (available for BE, HR, CZ, DE, IE, IT, 

MT, NL, RO, SK, SI, ES, SE)  

Intimate partner violence  

Physical violence 

Survey data on physical and sexual violence by intimate partners   

  Prevalence  of  physical  and  sexual  violence  by  intimate  partners  since  the  age  of  15 
and  during  the  12  months  prior  to  the  interview  by  the  age,  education,  and  main 
activity of the victim and relationship between the victim and the perpetrator (2012) 

  Prevalence of physical violence by intimate partners since the age of 15 and during the 
12 months prior to the interview by the age, education, and main activity of the victim 
and relationship between the victim and the perpetrator (2012) 

Sexual violence by intimate partners  

  Prevalence  of  physical  and  sexual  violence  by  intimate  partners  since  the  age  of  15 
and  during  the  12  months  prior  to  the  interview  by  the  age,  education,  and  main 
activity of the victim and relationship between the victim and the perpetrator (2012) 

  Prevalence of rape by intimate partners since the age of 15 and during the 12 months 
prior  to  the  interview  by  the  age,  education,  and  main  activity  of  the  victim  and 
relationship between the victim and the perpetrator (2012) 

  Prevalence of sexual assault by intimate partners since the age of 15 and during the 12 
months  prior  to  the  interview  by  the  age,  education,  and  main  activity  of  the  victim 
and relationship between the victim and the perpetrator (2012) 

  Prevalence of sexual violence by intimate partners since the age of 15 and during the 
12 months prior to the interview by the age, education, and main activity of the victim 
and relationship between the victim and the perpetrator (2012) 

Intimate partner violence indicators 

Administrative data 

  Annual  number  of  women  victims  of  intimate  partner  violence  (aged  18  and  over) 

committed by men (aged 18 and over), as recorded by police 

  Number  of  reported  offences  related  to  intimate  partner  violence  against  women 

committed by men (aged 18 and over) 

  Number  of  men  perpetrators  of  intimate  partner  violence  against  women  (and 

percentage of male population that are perpetrators) 

  Annual number of women victims of physical intimate partner violence (aged 18 and 

over) committed by men (aged 18 and over) as recorded by police 

  Annual number of women victims of psychological intimate partner violence (aged 18 

and over) committed by men (aged 18 and over) as recorded by police 

240 

 
 
 
 
  Annual  number  of  women  victims  of  sexual  intimate  partner  violence  (aged  18  and 

over) committed by men (aged 18 and over) as recorded by police 

  Annual number of women victims of economic intimate partner violence (aged 18 and 

over) committed by men (aged 18 and over) as recorded by police 

  Annual number of women victims reporting rape (aged 18 years and over) committed 

by men (aged 18 and over) as recorded by police 

  Women victims of intimate femicide (aged 18 and over) committed by a male intimate 
partner (aged 18 and over), as a share of the women victims of homicide aged 18 and 
over 

  Number of protection orders applied and granted in cases of intimate partner violence 

against women by type of courts 

  Number  of  men  (aged  18  and  over)  prosecuted  for  intimate  partner  violence  against 

women 

  Number  of  men  (aged  18  and  over)  sentenced  for  intimate  partner  violence  against 

women 

  Annual  number  of  men  (aged  18  and  over)  sentenced  for  intimate  partner  violence 
against  women  held  in  prison  or  with  a  sanction  involving  a  form  of  deprivation  of 
liberty 

Other administrative data 

  Available national administrative data on intimate partner violence (available for BE, 
HR, CY, CZ, EE, FI, FR, DE, EL, HU, LV, LU, MT, NL, PL, PT, RO, SK, SI, ES, 
SE) 

 

Intentional  homicide  victims  by  victim-offender  relationship  and  sex  -  number  and 
rate for the relevant sex group (2008-2018) 

 Violence  against  Women  Prevalence  Estimates,  World  Health  Organization 

(2018)401  

The  report,  Global,  regional  and  national  estimates  for  intimate  partner  violence  against 
women and global and regional estimates for non-partner sexual violence against women 
was  developed  by  WHO  and  the  UNDP-UNFPA-UNICEF-WHO-World  Bank  Special 
Programme of Research, Development and Research Training in Human Reproduction (HRP) 
for the United Nations Inter-Agency Working Group on Violence Against Women Estimation 
and Data.402  

Global, regional and national prevalence estimates of intimate partner violence: 

Lifetime prevalence (since age 15 years):   

401 WHO, on behalf of the United Nations Inter-Agency Working Group on Violence Against Women Estimation and Data 
(VAW-IAWGED) available on https://www.who.int/publications/i/item/violence-against-women-prevalence-estimates  

402 This report presents data from the largest ever study of the prevalence of violence against women, conducted by WHO on 
behalf  of  a  special  working  group  of  the  United  Nations.  Based on data  from  2000 to 2018,  it  updates  previous  estimates 
released in 2013. 

241 

 
                                                 
  Globally,  26%  (UI403  22–30%)  of  ever-married/partnered  women  aged  15  years 
and older have been subjected to physical and/or sexual intimate partner violence 
at least once in their lifetime.  

  641 million (26%) and up to 753 million (27%) ever married/partnered women aged 
15  years  and  older  had  been  subjected  to  physical  and/or  sexual  intimate  partner 
violence at least once since the age of 15. 

 

In each of the subregions of Europe, which mainly comprise high-income countries, the 
estimated lifetime prevalence of intimate partner violence ranges from 23% in Northern 
Europe (UI 16–33%) to 16% (UI 12–21%) in Southern Europe. 

Prevalence of physical and/or sexual intimate partner violence 

 

In each of the subregions of Europe, which mainly comprise high-income countries, the 
estimated  lifetime  prevalence  of  intimate  partner  violence  ranges  from  23%  in 
Northern Europe (UI 16–33%) to 16% (UI 12–21%) in Southern Europe. Even the 
relatively low prevalence estimates in these subregions are still unacceptably high. 

  As for the prevalence rates of past 12 months physical and/or sexual intimate partner 
violence  the  prevalence  estimates  among  women  aged  15–49  range  from  4–5%  in 
Southern, Western and Northern Europe, to 7% in Eastern Europe. 

Country-level prevalence of physical and/or sexual intimate partner violence 

  Twelve countries and two areas fell into the group with the lowest prevalence estimates 
intimate  partner  violence  among  ever-

for 
married/partnered women aged 15–49 (i.e. prevalence of 10–14%; see Fig. 4.1). 

lifetime  physical  and/or  sexual 

o  Six of the 12 countries  are in  the subregions  of  Europe (Albania,  Bosnia and 
Herzegovina, and Switzerland [all 12%], Croatia, North Macedonia and Poland 
[all 13%]). 

o  Six additional countries in the subregions of Europe (Austria, Cyprus, Ireland, 

Italy, Montenegro and Spain). 

Global and regional prevalence of non-partner sexual violence  

  Globally,  it  is  estimated  that  6%  (UI  4–9%)  of  women  aged  15–49  have  been 
subjected  to  sexual  violence  from  someone  other  than  a  current  or  former 
husband or male intimate partner at least once in their lifetime, since age 15. 

  Estimated  prevalence  of  non-partner  sexual  violence  since  age  15  in  Northern 

Europe is (10%, UI 6–16%). 

Global  and  regional  combined  prevalence  estimates  of  intimate  partner  violence  and 
non-partner sexual violence 

  Globally,  31%  (UI  27–36%)  of  women  aged  15–49  and  30%  (UI  26–34%)  of 
women aged 15 years and older have been subjected to physical and/or sexual violence 
from  any  current  or  former  husband  or  male  intimate  partner,  or  to  sexual  violence 

403 The uncertainty interval (UI) indicates the range within which an estimate’s true value falls (i.e. there is an almost 50% 
probability that the value lies between 22 and 26% or between 26 and 30%, with 26% as most probable value). 

242 

 
 
                                                 
from  someone who is  not  a current  or former husband or intimate partner, or to  both 
these forms of violence at least once since the age of 15.  

  These  findings  suggest  that  on  average  736  million  and  up  to  852  million  women 
who  were  aged  15  years  or  older  in  2018  have  experienced  one  or  both  of  these 
forms of violence at least once in their lifetimes. 

  Prevalence  estimates  of  lifetime  physical  and/or  sexual  intimate  partner  violence 
(IPV) or non-partner sexual violence (NPSV) or both among all women aged 15–
49 years in Europe is 26% (UI 21-31%) 

 Violent sexual crimes recorded in the EU, Eurostat (2019)404 

• 

• 

Almost 178,000 violent sexual crimes were recorded by the police in the EU in 2019. 

Over a third of these (more than 60,000) were rapes. 

•  More than 9 in 10 rape victims and more than 8 in 10 sexual assault victims were girls 
and women, while nearly all those imprisoned for such crimes were male (99%). 

In 2019, in absolute terms the highest number of reported sexual offences was recorded in 
the following EU27 countries: France (55,229of which 23,236 recorded as rapes, i.e. 42%), 
Germany  (40,724 of which 9,576  as rapes, i.e. 24%) and Sweden (19,960 of which 8,271 
rapes  i.e.  41%).  As  a  relative  to  population  size  these  numbers  translate  into  195.113 
reported  sexual  offences  per  hundred  thousands  inhabitants  in  Sweden  and  respectively 
82.21 and 49.05 for France and Germany. 

 Estimating  the  costs  of  gender-based  violence  in  the  European  Union,  EIGE 

(2014).405 

This report from 2014 by EIGE provides an analysis of methodological options on the cost of 
gender-based  violence  and  intimate  partner  violence,  by  studying  different  literatures  and 
studies,  and  provides  recommendations.  It  includes  a  case  study  on  the  cost  of  intimate 
partner violence against women in the UK during 2012 and provides a calculation of the costs 
in the EU. EIGE is also in the process of finalising a new study on the estimation of the costs 
of gender-based violence during June-July 2021. 

 

intimate partner violence against women costs more than 13.5 billion euros;  

  of intimate partner violence against women and men is more than 15 billion;  

 

 

the cost of gender-based violence against women almost 28.5 billion;  

the  cost  of  gender-based  violence  against  women  and  men  is  more  than  32.5  billion 
euros. 

  By  extrapolating the cost  for the UK to  the EU,  proportionally to the population,  the 
costs of gender-based violence against women in the EU is almost 226 billion euros.  

  This represents 87 % of the total cost of gender-based violence against women and men 

to the EU close to 256 billion euros. 

404  Eurostat – Recorded offences by offence category  - police data  [crim_off_cat] (here);  Intentional homicide and sexual 
offences by legal status and sex of the person involved - number and rate for the relevant sex group [crim_hom_soff] (here); 
Prisoners by offence category and sex - number and rate for the relevant sex group [crim_pris_off] (here)  .  
405 https://eige.europa.eu/publications/estimating-costs-gender-based-violence-european-union-report. 

243 

 
                                                 
 Violence against Women: an EU-wide Survey, the European Union Agency for 

Fundamental Rights (2014)406  

  One in three women (33  %) has experienced physical and/or sexual violence since 
the  age  of  15,  EU-28.  The  range  was  from  10  %  to  50  %  of  women  experiencing 
physical and/or sexual violence across the different EU-28. 

  One in 20 women (5 %) has been raped since the age of 15, EU-28. 

  Out of all women who  have a (current  or previous) partner,  22 % have experienced 

physical and/ or sexual violence by a partner since the age of 15, EU-28. 

  Overall, 43 % of women have experienced some form of psychological violence by 

an intimate partner, EU-28. 

  Every second woman (55 %) in the EU has experienced sexual harassment at least 

once since the age of 15, EU-28. 

  13 %  of  women  have  experienced  some  form  of  economic  violence  in  past 
relationships, some 5 % of women have experienced economic violence in their current 
relationships, EU-28.  

  18 % of women have experienced stalking since the age of 15, EU-28. 

  5 % of women have experienced stalking in the 12 months preceding the survey which 
corresponds  to  about  9 million women experiencing stalking within a period of 12 
months, EU-28.  

  Some 12 % of women indicate that they have experienced some form of sexual abuse 
or  incident  by  an  adult  before  the  age  of  15,  which  corresponds  to  about  21  million 
women, EU-28.  

  30 % of women who have experienced sexual victimisation by a former or current 
partner  also  experienced  sexual  violence  in  childhood.  Of  those  women  who  have 
not  experienced  sexual  victimisation  in  their  current  or  former  relationship,  10  % 
indicate experiences of sexual violence in their childhood, EU-28. 

  Half  of  all  women  in  the  EU  (53  %)  avoid  certain  situations  or  places,  at  least 

sometimes, for fear of being physically or sexually assaulted, EU-28.  

  11% of women since the age of 15 have received unwanted, offensive, sexually explicit 
emails or SMS messages, or inappropriate advances on social networking sites at some 
point in their lives, EU-28. 

406 Available on: https://fra.europa.eu/en/news/2019/towards-european-survey-gender-based-violence  

244 

 
                                                 
ANNEX 7: Monitoring and evaluation 
Implementation of the initiative will be monitored against the specific objectives (by problem 
area).  The  table  below  includes  such  further  indicators  that  could  be  used  to  assess  the 
progress  and  effectiveness  of  the  preferred  option.  The  Commission  will  identify  suitable 
indicators for each area in its questionnaire. 

Table 1: Summary of monitoring and evaluation indicators 

Specific 
objectives 

e
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Operational measurable 
objectives 
The general public is aware of 
violence against women and 
domestic violence and 
information is available in 
concrete cases; 

Relevant practitioners  are 
aware of violence against 
women and domestic violence 
and targeted information is 
available for professional 
group to tackle violence 
against women and domestic 
violence cases appropriately; 

Availability of other measures 
in the prevention problem 
area. 

Key performance indicators 

Sources and tools 

For all problem areas: 
Monitoring through the 
information and data reported by 
Member States to the 
Commission pursuant to the 
reporting obligation in the act. 

Number, complexity and 
effectiveness of infringements 
pursued at EU level. 

Monitoring through qualitative 
indicators developed in 
cooperation with Eurostat and 
EIGE at https://composite-
indicators.jrc.ec.europa.eu/ges-
monitor/maps. 
Potential indicators depending 
on information availability: 

-  Number of campaigns 

organised / audience 
reached; 

-  Number of perpetrator 
programmes available / 
audience reached / 
terms of participation. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As above. 

Monitoring through qualitative 
indications developed in 
cooperation with Eurostat and 
EIGE at https://composite-
indicators.jrc.ec.europa.eu/ges-
monitor/maps. Number of 
training courses provided / 
number of participants. 

Potential indicators depending 
on information availability: 
-  Number of risk 

assessments conducted 
by MS in violence 
against women and 
domestic violence 
cases; 

-  Number of protection 
orders issued in cases 
of violence against 
women and domestic 
violence 

Reporting by equality bodies. 

As above. 

Reporting by Member States. 

Increased violence against 
women and domestic violence 
reporting; 

Targeted training on violence 
against women and domestic 
violence is provided;  

Increase in risk assessments 
conducted; 

Increase in protection orders 
issued in cases of violence 
against women and domestic 
violence; 

Number of violence against 
women and domestic violence 
cases handled by equality 
bodies. 

Number of violence against 
women and domestic violence 
prosecutions and convictions. 

Increase in requests for and 
level of compensation in 
violence against women and 
domestic violence cases. 

s
m

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a

General support services are 
available to victims of 
violence against women and 
domestic violence. 

Specialised support services 
are available to victims of 
violence against women and 
domestic violence. 

As above. 

Potential indicators depending 
on information availability: 
-  Number of shelter 
places available by 
MS; 

-  Number of helplines 

available to victims of 
violence against 
women and domestic 
violence by MS; 

- 

Issuance of violence 
against women and 
domestic violence-
specific guidelines to 
health and social 
service providers.  

As above. 

Participation of all MS in EU-
wide survey. 

Minimum standards on 
administrative data collection. 

Increased multi-agency 
coordination. 

All MS participate in the GBV 
survey coordinated at EU level. 
More comparable data are 
available to Eurostat and EIGE. 

Establishment and frequency of 
meetings of coordination bodies 
at EU level. 

Increased referral between 
national law enforcement, 
support service and judicial 
authorities and actors. 

Where available through MS 
reporting, information on the 
number of referrals between 
authorities by MS. 

Reduction of sexual 
harassment at work. 

EU survey/administrative data. 

Reporting by MS. 

Questionnaires to equality bodies. 

Survey among social partners. 

EU survey + administrative data 

Number of cases of sexual 
harassment at work handled by 
equality bodies 

Potential indicators depending 
on information availability: 

-  Number of cases on 

sexual harassment 
before the courts; 

Potential indicators depending 
on information availability: 
reduction of cyber violence 
cases as indicated by admin. 
data; no. and type of support 
measures 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
       
 
 
 
4 

 
 
 
 
 
ANNEX 8 Gap analysis and good practices  

5 

 
 
 
 
 
This gap analysis evaluates to what extent the existing EU legislation and national policy and 
legislative measures in place are effective in preventing and tackling violence against women 
and domestic violence and in addressing the specific needs of victims of such violence. The 
analysis  is  carried  out  in  the  five  problem  areas  identified  in  the  impact  assessment  report: 
prevention, protection, access to justice, victims’ support and coordination. 

The  first  section  of  the  gap  analysis  evaluates  to  what  extent  the  EU  legal  framework 
effectively addresses victims’ needs in the identified problem areas. The main findings of this 
section are illustrated in table 1. 

The second section of the gap analysis examines the measures in place in the  EU Member 
States in the five problem areas. The aim of this analysis is to assess whether, despite the gaps 
in  EU  law  identified  in  the  first  section,  Member  States  adopted  sufficient  and  effective 
measures  to  address  the  problems.  Member  State  action  may  be  the  result  of  the 
implementation  of  the  Istanbul  Convention  on  preventing  and  combatting  violence  against 
women  and  domestic  violence,  other  international  legal  frameworks,  such  as  in  particular 
CEDAW  Convention,    or  self-standing  action  at  national  level.  This  section  also  highlights 
best practices found in the Member States. The findings are summarised in table 2.  

The gap analysis is based on various studies, partly conducted in support of this initiative, 
results of monitoring by international bodies (e.g. baseline reports of the Council of Europe 
Group  of  Experts  on  Action  against  Violence  against  Women  and  Domestic  Violence 
(GREVIO)),  and  a  broad  consultation  process  with  substantial  input  from  a  variety  of 
stakeholders.   

The scope of this analysis is violence against women and domestic violence, as explained in 
the impact assessment report. 

I. 

Gap analysis of the EU legal framework in the areas of prevention, protection, 

access to justice, victims’ support and coordination at national level  

At  the  time  of  proposing  EU  accession  to  the  Istanbul  Convention,407  the  Commission 
identified  14  instruments  of  EU  law,  which  could  potentially  contribute  to  addressing  the 
problem  of  violence  against  women  and  domestic  violence  in  the  areas  of  prevention, 
protection, access to justice, victims’ support and coordination. These instruments are set out 
below. 

The Istanbul Convention itself is not covered by the gap analysis because it does not form part 
of  the  EU  acquis,  hence  does  not  form  part  of  the  EU  legal  and  policy  framework  which 
should be evaluated. 

Victims’ rights and protection measures 

407  Roadmap  on  a  possible  EU  Accession    to    the    Council    of    Europe    Convention    on    preventing    and 
combating violence against women and domestic violence (Istanbul  Convention), at https://ec.europa.eu/smart-
regulation/roadmaps/docs/2015_just_010_istanbul_convention_en.pdf. 

6 

 
 
 
 
                                                 
  Directive  2012/29/EU  establishing  minimum  standards  on  the  rights,  support  and 

protection of victims of crime (‘Victims’ Rights Directive’);408 

  Directive 2011/99/EU on the European protection order (‘EPO Directive’);409 
  Regulation  (EU)  No  606/2013  on  mutual  recognition  of  protection  measures  in  civil 

matters (‘Mutual Recognition Regulation’);410 

  Council  Directive  2004/80/EC 
(‘Compensation Directive’);411 

relating 

to  compensation 

to  crime  victims 

  Directive  2011/93/EU  of  the  European  Parliament  and  of  the  Council  on  combating 
the  sexual  abuse  and  sexual  exploitation  of  children  and  child  pornography,  and 
replacing Council Framework Decision 2004/68/JHA (‘CSA Directive’);412 

  Directive 2011/36/EU on preventing  and combating trafficking in  human beings and 

protecting its victims (‘Anti-Trafficking Directive’).413 

Gender Equality Directives 

  Directive  2006/54/EC  on  the  implementation  of  the  principle  of  equal  opportunities 
and  equal  treatment  of  men  and  women  in  matters  of  employment  and  occupation 
(‘Gender Equality Recast Directive’);414 

  Council  Directive  2004/113/EC  implementing  the  principle  of  equal  treatment 
between men and women in the access to and supply of goods and services (‘Goods 
and Services Directive’);415 

  Directive 2010/41/EU on the application of the principle of equal  treatment  between 
men and women engaged in  an activity in  a self-employed capacity (‘Self-employed 
Directive’).416 

Asylum Directives 

408  Directive  2012/29/EU  of  the  European  Parliament  and  of  the  Council  of  25  October  2012  establishing 
minimum standards on the rights, support and protection of victims of crime, and replacing Council Framework 
Decision 2001/220/JHA, OJ L 315, 14.11.2012, p. 57–73. 
409 Directive 2011/99/EU of the European Parliament and of the Council of 13 December 2011 on the European 
protection order, OJ L 338, 21.12.2011, p. 2–18. 
410  Regulation  (EU)  No  606/2013  of  the  European  Parliament  and  of  the  Council  of  12  June  2013  on  mutual 
recognition of protection measures in civil matters, OJ L 181, 29.6.2013, p. 4–12. 
411  Council  Directive  2004/80/EC  of  29  April  2004  relating  to  compensation  to  crime  victims,  OJ  L  261, 
6.8.2004, p. 15–18. 
412 Directive 2011/93/EU of the European Parliament and of the Council of 13 December 2011 on combating the 
sexual  abuse  and  sexual  exploitation  of  children  and  child  pornography,  and  replacing  Council  Framework 
Decision 2004/68/JHA, OJ L 335, 17.12.2011, p. 1–14.  
413  Directive  2011/36/EU  of  the  European  Parliament  and  of  the  Council  of  5  April  2011  on  preventing  and 
combating trafficking in human beings and protecting its victims, OJ L 101, 15.4.2011, p. 1–11. 
414 Directive 2006/54/EC of the European Parliament and of the Council of 5 July 2006 on the implementation of 
the  principle  of  equal  opportunities  and  equal  treatment  of  men  and  women  in  matters  of  employment  and 
occupation, OJ L 204, 26.7.2006, p. 23–36. 
415 Council Directive 2004/113/EC of 13 December 2004 implementing the principle of equal treatment between 
men and women in the access to and supply of goods and services, OJ L 373, 21.12.2004, p. 37–43. 
416 Directive 2010/41/EU of the European Parliament and of the Council of 7 July 2010 on the application of the 
principle of equal treatment between men and women engaged in an activity in a self-employed capacity, OJ L 
180, 15.7.2010, p. 1–6. 

7 

 
 
 
 
 
                                                 
  Directive  2013/33/EU  laying  down  standards  for  the  reception  of  applicants  for 

international protection (recast); (‘Reception Conditions Directive’);417  

  Directive  2013/32/EU  on  common  procedures  for  granting  and  withdrawing 
international  protection  (recast)  asylum  procedures  directive;  (‘Asylum  Procedures 
Directive’);418  

  Directive  2008/115/EC  on  common  standards  and  procedures  in  Member  States  for 

returning illegally staying third-country nationals; (‘Return Directive’);419  

  Directive 2011/95/EU on standards for the qualification of third-country nationals or 
stateless  persons  as  beneficiaries  of  international  protection,  for  a  uniform  status  for 
refugees  or  for  persons  eligible  for  subsidiary  protection,  and  for  the  content  of  the 
protection granted; (‘Qualification Directive’).420  

International instruments 

  Article 16 of the United Nations Convention on the Rights of Persons with Disabilities 

(UNCRPD); - freedom from exploitation, violence and abuse.421 

While these instruments are mainly gender-neutral, they are relevant for victims of violence 
against women and domestic violence, because they either apply to all victims of crime422 or 
cover victims of specific forms of violence against women and domestic violence423.  

The  main  deficiency  in  the  EU  legal  framework  as  a  whole  is  precisely  that  it  is  not 
focussed  on  violence  against  women  and  domestic  violence.  With  the  exception  of  the 
Anti-trafficking  and  the  CSA  Directives,  the  EU  framework  focusses  on  the  rights  and 
protection  of  all  victims  of  crime,  or  specific  crimes,  and  of  all  applicants  of  international 
protection  regarding  their  qualification,  reception  and  return,  without  a  gender-sensitive 
approach. It thus addresses the protection and needs of victims of violence against women and 

417 Directive 2013/33/EU of the European Parliament and of the Council of 26 June 2013 laying down standards 
for the reception of applicants for international protection (recast), OJ L 180, 29.6.2013, p. 96–116. 
418 Directive 2013/32/EU of the European Parliament and of the Council of 26 June 2013 on common procedures 
for granting and withdrawing international protection (recast) asylum procedures directive, OJ L 180, 29.6.2013, 
p. 60–95. 
419  Returns  Directive  2008/115/EC  of  the  European  Parliament  and  of  the  Council  of  16  December  2008  on 
common standards and procedures in Member States for returning illegally staying third-country nationals, OJ L 
348, 24.12.2008, p. 98–107.  
420 Directive 2011/95/EU of the European Parliament and of the Council of 13 December 2011 on standards for 
the qualification of third-country nationals or stateless persons as beneficiaries of international protection, for a 
uniform status for refugees or for persons eligible for subsidiary protection, and for the content of the protection 
granted, OJ L 337, 20.12.2011, p. 9–26. 
421 United Nations Convention on the Rights of Persons with Disabilities, 13 December 2006; Council Decision 
concerning  the  conclusion,  by  the  European  Community,  of  the  United  Nations  Convention  on  the  Rights  of 
Persons with Disabilities, 26 November 2009, pp. 35-36. 
422 For instance, the Victims’ Rights Directive and the European Protection Order (EPO). 
423  For  instance,  the  directives  on  child  sexual  abuse  or  trafficking  in  human  beings,  the  gender  equality 
directives insofar as they regulate sex-based, including sexual harassment, and the UN Convention on the rights 
of  persons  with  disabilities  (UNCRPD)  which  requires  Parties  to  ensure  that  women  and  children  with 
disabilities enjoy equal rights and that persons with disabilities are protected against exploitation, violence and 
abuse. The EU is a party to this Convention together with the Member States. 

8 

 
 
 
 
 
                                                 
domestic violence mainly by way of general obligations and recommendations. While in some 
instances,  e.g.  in  the  Victims  Rights’  Directive,  women  are  included  in  the  category  of 
‘vulnerable groups’ entitled to specific protection, the lack of explicit measures for this group 
of victims leads to a lack of implementation at national level with a focus on this group.  

The gender-neutral approach of EU law provisions is problematic because it does not provide 
women victims of violence and domestic violence effective protection, support and access to 
justice. GREVIO noted with respect to states parties to the Istanbul Convention that a gender 
neutral  approach  in  legislation  may  not  always  do  justice  to  the  particular  experiences  of 
victims of violence against women, who are more frequently and more severely impacted. For 
example, it can result in a policy approach which does not recognise violence against women 
as a form of discrimination against women and that does not consider the specific experiences 
of  women  experiencing  violence,  such  as  the  setting  up  of  specialised  support  services  or 
trainings  for  practitioners.  It  does  not  take  into  account  the  specific  problems  of  systemic 
under-reporting  (due  to  the  lack  of  follow-up  by  law  enforcement,  perceived  shame  and 
embarrassment  surrounding this type of violence, the fear of retaliation  especially  when the 
perpetrator  is  a  relative  or  otherwise  close  acquaintance,  including  at  work),  disrupted 
criminal  proceedings,  the  commonly  sexual  nature  of  crimes  and  a  high  prevalence  of 
elements of coercive control.424  

In addition, EU law does not recognise violence against women and domestic violence as a 
form of discrimination. Only the Gender Equality Directives recognise, within their limited 
scope,  sex-based  and  sexual  harassment  as  discrimination.  The  Victims’  Rights  Directive 
limits  itself  to  underlining  the  importance  of  treating  violence  against  women  and  domestic 
violence  as  a  violation  of  fundamental  rights.425  This  leads  to  unequal  and  insufficient 
measures  across  the  EU,  since  victims  of  all  forms  of  such  violence  do  not  unequivocally 
have access to non-discrimination remedies, such as equality bodies. 

A detailed gap analysis of the EU legal framework in the five problem areas is set out below: 

 Prevention of violence against women and domestic violence  

a. Awareness-raising and information provision 

As  outlined  in  the  impact  assessment  report,  prevention  measures  of  this  kind  of  violence 
usually  consist  of  awareness-raising  and  information  provision  measures,  training  of 
professionals and perpetrator programmes.  

The relevant EU legal framework contains obligations regarding awareness-raising in Article 
18(2) of the Anti-Trafficking Directive, Article 23(2) of the CSA Directive and Article 26(2) 
of the Victims’ Rights Directive. 

424 FRA, Violence against women: an EU-wide survey. Main results report, 2014; Infra 490. 
425 According to the EELN report,  only nine Member States recognise to some extent (gender-based) violence 
against women as a form of discrimination or an equality issue (FR, DE, EL, MT, PL, PT, RO, ES, SE), while in 
11  States  there  is  no  explicit  recognition  of  violence  against  women  and  domestic  violence  as  an 
equality/discrimination issue (BE, HR, CY, HR, DE, FI, IE, LV, LT, SI, SK). 

9 

 
 
 
 
                                                 
These  provisions  have  proven  to  be  somewhat  effective,  even  though  shortcomings  remain. 
The  problems  identified  in  this  regard426  include,  in  particular,  the  fact  that  the  provisions 
either  focus  on  a  broader  subject-matter,  such  as  rights  of  all  victims’  (as  for  instance  in 
Article 26 the Victims’ Rights Directive on all groups of victims, even if groups at risk such 
as children, victims of gender-based violence427 and violence in  close relationships428 are to 
be  specifically  targeted).  The  provisions  can  also  be  narrower  in  scope,  such  as  the  Gender 
Equality Directives, which include a general obligation for the Member States to prevent  sex-
based and sexual harassment as one form of prohibited discrimination.  

In the targeted consultation of Member States, 25 Member States reported having organised 
awareness-raising  campaigns  on  violence  against  women  and  domestic  violence.429  This 
information  is  somewhat  corroborated  by  the  open  public  consultation,  where  60%  of 
respondents  indicated  knowing  about  such  campaigns  in  their  Member  States.  However, 
GREVIO  has  noted  challenges  related  to  awareness-raising  in  terms  of  a  narrow  focus  on 
domestic violence, short duration of the campaigns and lack of intersectionality.430  

Awareness-raising can also be provided through education to develop skills, such as on non‐
violent conflict resolution and tackling harmful stereotypes. EU law does not currently oblige 
Member  States  to  conduct  awareness-raising  or  provide  information  on  violence  against 
women and domestic violence in particular. In addition, EU action in the field of education is 
limited to supportive action as established in Article 165 TFEU.  

b. Perpetrator programmes 

Programmes for perpetrators are included only in the CSA Directive. Article 22 of the CSA 
obliges  Member  States  to  provide  for  access  to  effective  intervention  programmes  or 
measures designed to evaluate and prevent the risk of committing child sexual abuse offenses 
covered  by  the  Directive  for  persons  at  risk  of  offending.  The  implementation  report 
highlighted that challenges remain in several Member States in the areas of prevention and, in 
particular, concerning prevention programmes for offenders and for people who fear that they 
might offend.431 

According  to  the  European  Network  for  Work  with  Perpetrators  (WWP  EN),  the  relevant 
provisions in the instruments under review had limited effectiveness in this area.432 

In the targeted consultation, all but one country – Hungary – reported having set up support 
programmes for perpetrators of violence against women and domestic violence.433 However, a 

426 Study conducted in support of the impact assessment report. ICF 2021 [upcoming]. 
427 This notion is understood in this gap analysis as covering violence against women  
428 This notion is understood in this gap analysis as covering domestic violence. 
429 Targeted consultation of Member States, responses to question no. 10. No response from HU and MT. 
430 GREVIO, Mid-term Horizontal Review of GREVIO baseline evaluation reports, 2021, pp. 53-57, available at: 
(https://rm.coe.int/horizontal-review-study-2021/1680a26325). 
431 European Commission, Report from the Commission to the European Parliament and the Council assessing 
the extent to which the Member States have taken the necessary measures in order to comply with Directive 
2011/93/EU of 13 December 2011 on combating the sexual abuse and sexual exploitation of children and child 
pornography, COM(2016) 871 final, 16 December 2016. 
432 Interview with European Network for Work with Perpetrators (WWP EN), 2 July 2021.   
433 Targeted consultation of Member States, responses to q. no. 29. No response from PL, HR, LT. 

10 

 
 
 
                                                 
descriptions  of  the  measures  show  that  most  target  only  domestic  violence  and  not  all  are 
compulsory. 

c. Training of professionals  

Key  provisions  regarding  the  training  of  relevant  professionals  likely  to  come  into  contact 
with  victims  of  this  kind  of  violence  are  in  the  Victims’  Rights  Directive,434  the  Anti-
Trafficking Directive,435 and the Gender Equality Recast Directive436.  

The relevant EU provisions on training are however not specific to violence against women 
and domestic violence. They thus disregard the specific needs of this group of victims and do 
not require specific skills and competences from the trainers themselves. For instance, Article 
25  of  the  Victims’  Rights  Directive  sets  out  a  requirement  to  provide  training  to  ‘officials 
likely to come into contact with victims’, without specifying any particular groups of victims.  

d. Coherence with international standards 

The EU legal framework as set out above can generally be considered not to be in line with 
the  standards  set  in  the  Istanbul  Convention,  in  particular  its  Article  13  which  contains  an 
obligation to raise awareness on all manifestations of violence against women in cooperation 
with other stakeholders, particularly women’s organisations, and its Article 15 which requires 
to offer appropriate training to relevant stakeholders and professionals that come into contact 
with victims or perpetrators of acts of violence. The requirements of Article 16 of the Istanbul 
Convention on perpetrator programmes are included only in the CSA Directive and therefore 
limited to perpetrators of child sexual abuse. 

e. Conclusion 

The EU Framework contains prevention obligations in a fragmented manner. This creates gaps 
in  relation  to  the  contexts  in  which  and  the  forms  of  violence  against  women  and  domestic 
violence  that  are  to  be  targeted.  The  EU  legal  framework  is  insufficiently  in  line  with  the 
requirements of the Istanbul Convention. 

2. Protection of victims of violence against women and domestic violence  

The  European  Protection  Order  Directive  (‘EPO’)437  and 
the  Mutual  Recognition 
Regulation438 allow for the cross-border recognition of protection orders439 issued within the 
EU.440 The EPO provides an obligation to recognise criminal law protection orders issued by 
judicial  authorities  from  other  Member  States.  It  is  thus  a  mechanism  based  on  mutual 
recognition,  not  a  harmonisation  instrument  and  therefore  it  does  not  include  provisions  on 
when and how the protection measures should be applied in the Member States. The Mutual 

434 See: Art. 25. 
435 See: Art. 18. 
436 See: Art. 25. 
437 Supra 409. 
438 Supra 410. 
439 Measures issued by law enforcement or judicial authorities for the protection of the life, physical or 
psychological integrity, dignity, personal liberty or sexual integrity of victims. 
440 Council of the European Union, Initiative for a directive of the European Parliament and of the Council on 
the European Protection Order - Explanatory memorandum, 2010/0802(COD), 5677/10, 22 January 2010.  

11 

 
 
 
 
                                                 
Recognition  Regulation  provides  for  the  recognition  of  protection  measures  issued  as  civil 
law measures. 

These instruments  were  set  out  to  be gender-neutral  and non-specific to  victims of violence 
against  women  and  domestic  violence.  Nevertheless,  the  Regulation  recognizes  the  aim  of 
preventing  any  form  of  gender-based  violence  or  violence  in  close  relationships,  such  as 
physical  violence,  harassment,  sexual  aggression,  stalking,  intimidation  or  other  forms  of 
indirect coercion, while underlining that it is applicable to all victims.441  

Provisions  on  protection  of  victims  are  also  included  in  the  Victims’  Rights  Directive 
(Chapter  IV),  the  CSA  Directive  (Articles  18  and  20)  and  the  Anti-trafficking  Directive 
(Articles 12 and 13). 

In particular, Article 22 of the Victims’ Rights Directive requires Member States to undertake 
an  individual  assessment  of  victims  to  identify  specific  protection  needs.  EU  law  however 
does not include an obligation to assess the risk posed by the alleged perpetrator of this 
kind  of  violence  on  the  victim.  This  creates  a  gap  with  regard  to  Article  51  of  the  Istanbul 
Convention, which requires all relevant national authorities to carry out an assessment of the 
‘lethality risk, the seriousness of the situation and the risk of repeated violence’.  

Since  there  are  currently  no  specific  training  obligations  in  EU  law  as  regards  this  kind  of 
violence,  EU  law  does  not  currently  require  the  provision  of  specific  training  for  law 
enforcement authorities either. Training on violence against women and domestic violence 
would be needed to understand why their interventions in situations of domestic violence is 
needed and what is expected of their intervention.442 

a.  Protection  of  child  victims  or  witnesses  of  violence  against  women  and  domestic 
violence 

The  Victims’  Rights  Directive  requires  specific  protection  for  vulnerable  groups  through 
individual  assessment  of  victims’  needs  in  relation  to  protection  during  criminal 
proceedings.443  In  addition,  Article  24  establishes  special  rules  on  the  right  to  protection  of 
child victims of all crimes during criminal proceedings. 

Comprehensive  information  about  the  special  protection  measures  granted  in  the  Member 
States  for  child  victims  of  violence  against  women  under  Article  24  of  the  Victims’  Rights 
Directive  is  not  available.  Problems  with  practical  implementation  of  these  measures  were 
identified in a few Member States.444. In addition, Article 24 applies to child victims, but does 
not  explicitly  apply  to  child  witnesses  of  violence.  This  creates  a  protection  gap  for  child 

441 Supra 410, Recital (6). 
442 FRA, Women as victims of partner violence – Justice for victims of violent crime, Part IV, 2019, p. 12, 
available at: (https://fra.europa.eu/en/publication/2019/women-victims-partner-violence-justice-victims-violent-
crime-part-iv). 
443 Supra 408.  
444 European Commission, Report on the implementation of Directive 2012/29/EU of the European Parliament 
and of the Council establishing minimum standards on the rights, support and protection of victims of crime, and 
replacing Council Framework Decision 2001/220/JHA, COM(2020) 188 final, 11 May 2020 

12 

 
 
 
 
                                                 
witnesses of violence against women and domestic violence, since such violence is found to 
be equally traumatising to children witnessing it445. 
In  addition,  Articles  13,    14,  15  and  16  of  the  Anti-Trafficking  Directive  include  targeted 
protection  measures  for  child  victims  of  trafficking  in  human  beings.  Those  provisions 
foresee  that  this  specific  group  of  child  victims  shall  be  provided  with  protection  measures 
and that the child’s best interests shall be a primary consideration.  
Article  20  of  the  CSA  Directive  provides  for  measures  for  protection  of  child  victims  of 
sexual abuse and exploitation in the course of criminal investigations and proceedings. The 
scope of the Directive is limited to this specific form of violence.  
EU law includes gaps in that it does not provide for the child-sensitive protection of children 
victims  of  other  forms  of  violence  against  women  and  domestic  violence.  Reporting  of 
violence  by  children  should  be  child-friendly446,  and  there  should  be  a  possibility  for  visits 
with family members suspected of this kind of violence to take place in a safe, surveyed place 
and in the best interest of the child447. 

b. Protection of victims living with a disability  

Article 16 UNCRPD requires the parties to the Convention to protect persons with disabilities 
from  all  forms  of  exploitation,  violence  and  abuse  and  obliges  them  to  take  into  account 
gender-  and  age-specific  needs.  In  addition,  Article  6  UNCRPD  requires  states  parties  to 
recognise  multiple  forms  of  discrimination  against  women  and  girls  with  disabilities  and 
guarantee equality and the full enjoyment of their rights.448 

The practical implementation of the UNCRPD in the EU and its Member States continues to 
face challenges. Specifically in regard to violence against women and domestic violence, the 
UN  Committee  on  the  Rights  of  Persons  with  Disabilities’  noted  with  concern  in  its 
concluding  observations  to  the  EU  in  2015  that,  in  the  EU,  ‘persons  with  disabilities, 
especially  women,  girls  and  boys,  and  older  persons,  are  subjected  to  violence,  abuse  and 
exploitation, especially in institutional settings’.  

445 See e.g. Explanatory Report to  the  Council  of  Europe  Convention  on  preventing  and  combating  
violence against women and domestic violence. 
446 https://ec.europa.eu/info/sites/default/files/child-friendly_justice_20180625-26_background_paper_final.pdf, 
at 3. Also meeting with Victim Support Europe, 24 November 2021. 
447  According  to  information  gathered  in  October  2021  from  the  European  Judicial  Network,  access  between 
family  members  and  children  in  cases  of  alleged  domestic  violence  can  be  organised  as  surveyed  meetings  in 
safe  places  in  the  presence  of  child  protection  officials  e.g.  in  ES,  FI,  DE  and  MT.  In  addition,  Brussels  IIa 
Regulation  (Council  Regulation  (EC)    No.  2201/2003  of  27  November  2003  concerning  jurisdiction  and  the 
recognition  and  enforcement  of  judgments  in  matrimonial  matters  and  the  matters  of  parental  responsibility, 
repealing Regulation (EC) No. 1347/2000) contains rules on cross-border family law  matters, such as parental 
responsibility,  custody  rights  and  international  child  abduction.  The  Regulation  is  intended  to  supplement  the 
rules of the 1980 Hague Convention on the Civil Aspects of International Child Abduction (HC80), to which all 
EU  Member  States  are  signatories.  HC80  aims  at  resolving  cross-border  disputes  and  includes  specific 
provisions, which are also applicable in situations involving suspicions of this kind of violence. The “Brussels 
IIa  Recast”  Regulation  (Council  Regulation  2019/1111  of  25  June  2019  on  jurisdiction,  the  recognition  and 
enforcement of decisions in matrimonial matters and the matters of parental responsibility, and on international 
child abduction (recast)) will apply from 1 August 2022 onwards and will lead to substantial improvements in 
judicial cooperation in matters of parental responsibility for the benefit of the children concerned. 
448 Supra 421, Art. 6. 

13 

 
 
 
 
                                                 
Training of professionals is key to recognise the specific risks and needs also with regard to 
this group of victims. EU law does not foresee specific training for professionals dealing with 
person  with  disabilities  who  have  experienced  violence  (see  above  on  training).  The 
supporting study shows limitations in the protection to victims with disabilities in most of the 
Member  States,  including  an  important  lack  of  sensitization  and  training  of  such 
professionals449. The supporting study also notes a lack of measures responding to  multiple 
forms  of  discrimination,  taking  into  account  both  sex  and  disability  in  most  Member 
States450.  In  its  Concluding  observations  to  the  initial  periodic  report  of  the  EU451,  the  UN 
Committee on the Rights of Persons with Disabilities recommended for the EU to mainstream 
disability  in  all  legislation,  policies  and  strategies  for  combating  violence,  abuse  and 
exploitation  and  provide  effective  protection  from  violence,  abuse  and  exploitation  to  all 
people with all sorts of disabilities within and outside the home environment.  

c.  Ensuring continued protection in cross-border situations  

Cross-border  protection  of  victims  of  violence  against  women  and  domestic  violence  is 
ensured  in  EU  law  by  the  EPO  instruments.  These  instruments  provide  for  the  cross-border 
recognition of protection orders issued under national law. Such mutual recognition continues 
to be a challenge, particularly because of the large divergence of existing orders at national 
level.452  The  EPO  instruments  have  been  very  little  used.453  In  the  targeted  consultation454, 
two Member States  report that foreign protection orders are not  recognised and enforced.455 
Several  countries  identified  a  lack  of  awareness  of  the  measure  by  relevant  authorities456, 
divergences  in  sanctions457  and  in  differences  in  type  and  scope  of  protection  measures 
between  Member  States458  as  challenges.  However,  in  cases  where  the  mutual  recognition 
instruments were applied, they were mainly used with regard to protection of women ‘in cases 
of intimate partner or domestic violence, harassment, stalking or sexual assault’.459 

449 AT, HR, LT, PL, PT, ES. 
450 For example, Luxembourg and Romania have an action plan related to disability that does not address victims 
of  violence  against  women  and  domestic  violence  and  the  Netherlands,  Belgium  and  Poland  have  national 
policies related to this kind of violence that pay very limited attention to disability. 
451 UN Committee on the Rights of Persons with Disabilities, Concluding observations on the initial report of the 
European  Union,  CRPD/C/EU/CO/R.1,  1  September  2015,  available  at: 
(https://documents-dds-
ny.un.org/doc/UNDOC/GEN/G15/226/55/PDF/G1522655.pdf?OpenElement).  
452 Submission for the Member States Targeted Consultation  q. 19. 
453  Statistics  provided  by  Member  States  for  the  years  2015-2018  record  a  total  of  37  EPOs  issued  and  the 
majority were EPOs issued by one Member State (27 out of 37). Only 15 EPOs were recognised and led to the 
adoption of protection measures in the executing State.  
454 Submission for the Member States Targeted Consultation q.18.  
455  J.  Candido,  et  al.,  Slachtoffer  en  de  rechtspraak  –  Handleiding  voor  de  strafrechtspraktijk,  2017,  p.  213, 
available at: (https://www.rechtspraak.nl/SiteCollectionDocuments/Slachtoffer-en-de-Rechtspraak.pdf 
). Figures from the Public Prosecution Service in NL also show that EPOs are not yet being used in practice in 
this country. The other Member State is CZ. 
456 NL, CZ, FI, BE, FR. 
457 NL, BG. 
458 NL, RO. 
459 European Commission, Report on the implementation of Directive 2011/99/EU of the European Parliament 
and  of  the  Council  of  13  December  2011  on  the  European  protection  order,  COM(2020)  187  final,  11  May 
2020,  p.  3,  available  at:  (https://op.europa.eu/en/publication-detail/-/publication/770f93b9-9369-11ea-aac4-
01aa75ed71a1/language-en).  

14 

 
 
 
                                                 
 
Most  importantly,  however,  the  EPO  instrument  do  not  ensure  that  effective  protection 
orders are available and speedily granted at national level. Emergency protection orders 
are available in only 18 States. In some Member States – such as FR, PT - protection orders 
are  only  available  for  victims  of  domestic  violence.  Further  problems  reported  concern  the 
lack  of  (multilingual)  information  and  lengthy  proceedings.460  In  addition,  the  VOCIARE 
report  identifies  the  lack  of  availability  of  interpretation  and  translation  services461  at 
national  level.  This  right  is  particularly  important  for  migrant  women.  In  the  targeted 
consultation,  four  countries462  stated  that  information  was  not  available  in  all  languages.463 
The VOCIARE report suggests that the problem could be more widespread and notes a lack 
of  interpreters  and/or  translators  in  six  countries464  and  a  lack  of  general  information  (e.g. 
information in public websites)465 available in other languages.466 

d.  Protection  of  migrant  women  and  girls  victims  of  violence  against  women  and 

domestic violence 

The  Victims’  Rights  Directive  provides  that  services  should  be  available  on  a  non-
discriminatory  basis  to  all  victims  ‘regardless  of  residence  status’.467  In  contrast,  residence 
status should be taken into account during individual assessments.468  

The Family Reunification Directive provides that Member States must issue an autonomous 
residence permit to third-country nationals who have entered their territory by virtue of family 
reunification  in  the  event  of  particularly  difficult  circumstances  (Article  15(3)  second 
sentence).469  Member  States  are  required  to  lay  down  provisions  in  national  law  for  this 
purpose . Such obligation has been interpreted to include situations of domestic violence and 
violence  against  women.470  This  enables  women  to  leave  a  situation  of  domestic  violence 

2017, 

available 

Assessment, 

No monitoring reports have been issued on directives 2004/113/EC and 2010/41/EU. Concerning the Goods and 
Services Directive, see: EPRS, Gender Equal Access to Goods and Services Directive 2004/113/EC – European 
Implementation 
at: 
(https://www.europarl.europa.eu/RegData/etudes/STUD/2017/593787/EPRS_STU(2017)593787_EN.pdf).  
460 Supra 
461 A right set out in Art. 7 Victims’ Rights Directive. 
462 EE, AT, LV, FR. 
463 Submission for the Member States Targeted Consultation q.28.  
464 AT, CZ, ES, FI, PT and RO. 
465 PT and RO. 
466  Supra,  p.  79.  FRA  report  states  that  the  police,  not  just  support  services,  provide  information  in  several 
languages in most (25) Member States. Half of the support services offer translation and interpretation services. 
Some of the support services offering information in other languages do so in many different languages. Even 
though  most  provide  information  in  less  than  a  handful  of  languages,  some  victim  support  organisations  offer 
information  in  10  (CY,  HU),  20  (DK,  FI  and  SE)  and  even  50  (AT)  languages,  as  well  as  (upon  request) 
potentially up to 200 in the UK.  
467 See: Art. 1. 
468 See: Art. 22. 
469 For cases of domestic violence, the Court has recently confirmed in a decision concerning the validity of 
Article 13(2) of Directive 2004/38/EC, that Article 15(3) of Directive 2003/86 pursues the objective of ensuring 
protection for family members who are victims of domestic violence (Judgement of 2 September 2021, X v 
Belgian State (C‑930/19), paragraphs 70 and 89). 
470 Supra Error! Bookmark not defined., p. 19 and Communication from the Commission to the European Parliament 
and the Council on guidance for application of Directive 2003/86/EC on the right to family reunification, COM/2014/0210 
final. 

15 

 
 
 
                                                                                                                                                         
without having to fear the loss of their status and further victimization due to the precarity of 
their immigration status.  

Such obligation has been interpreted to include situations of domestic violence and violence 
against  women.471  In  case  of  undocumented  migrants,  however,  the  Returns  Directive 
provides  that  Member  States  have  the  discretion  to  provide  residence  permits  for 
humanitarian  or  compassionate  purposes  (Article  6(4)).  This  provision  is  not  connected  to 
victims of violence, but their victimhood could play a role in the decision to grant or refuse 
residence.472 Therefore, while the EU framework thus provides for protection, such protection 
is lower for undocumented migrant victims of violence against women or domestic violence.  

Despite  these  provisions  in  EU  law,  a  report  based  on  the  Asylum  Information  Database 
(AIDA) notes that the ‘fragmented legal framework for identifying vulnerable categories 
of  asylum  seekers,  as  well  as  defining  the  special  guarantees  necessary  to  preserve  their 
ability to enjoy their rights and comply with their obligations in the asylum process leads to a 
lack  of  protection.473  A  Council  of  Europe  report  notes  that  ‘many  women  and  girls  have 
been and are subjected to severe forms of violence against women and domestic violence in 
accommodation, reception and detention facilities throughout Europe and gender-sensitive 
measures to address this are often absent’.474 
In  the  targeted  consultation,  eight  Member  States475  replied  to  the  question  on  what  extent 
access  to  support  services  is  conditional  upon  the  victim’s  residence  status,  but  it  was  not 
clear from their answers whether such access was limited to migrants with legal status.476 The 
European Network of Migrant Women notes that there is strong evidence that support is not 
always  available  for  irregularly-staying  migrants  (i.e.  those  without  a  legal  status). 
Similarly the VOCIARE report notes that the status of victim is often conditional on formal 
requirements, such as legal residence.477  

The NGO ‘Platform for International Cooperation for Undocumented’ (PICUM) further notes 
a high degree of hesitancy among irregularly-staying migrants to seek support for fear of the 
exchange  of  information  between  services  and  immigration  enforcement.  PICUM  also 
notes  that  the  needs-based  approach  in  the  Victims’  Rights  Directive  combined  with  the 
that  enable  provisions  from  Directive 
provisions 
2004/81/EC to apply, could have as a consequence that the issuance of residence permits to 
third-country  national  victims  of  trafficking  in  human  beings  is  conditional  on  their 

the  Anti-Trafficking  Directive 

in 

471 Supra Error! Bookmark not defined., p. 19 and Communication from the Commission to the European Parliament 
and the Council on guidance for application of Directive 2003/86/EC on the right to family reunification, COM/2014/0210 
final. 
472 Supra Error! Bookmark not defined.. 
473 AIDA is the Asylum Information Database that is managed by the European Council on Refugees and Exiles, 
and  contains  information  on  asylum  procedures,  reception  conditions,  detention  and  content  of  international 
protection  across  23  countries,  including  19  MS,  as  explained  on  their  website:  (asylumineurope.org/about-
aida/).  The  findings  are  from  the  following  report:  AIDA,  The  concept  of  vulnerability  in  European  asylum 
procedures, 
(https://asylumineurope.org/wp-
at: 
content/uploads/2020/11/aida_vulnerability_in_asylum_procedures.pdf). 
474 L. Hooper, Gender-based asylum claims and non-refoulement: Articles 60 and 61 of the Istanbul Convention, 
Council of Europe, 2019, available at: (https://rm.coe.int/conventionistanbularticle60-61-web/1680995244). 
475 EE, HU, LV, BG, DK, LT, BE, FR. 
476 Submission for the Member States Targeted Consultation q.33.  
477 Supra, p. 172. 

available 

2017, 

53, 

p. 

16 

 
 
 
                                                 
willingness  to  cooperate  with  the  authorities.478  The  inconsistency  between  the  Victims’ 
Rights Directive and the asylum directives regarding the conditions for access to support and 
their limited gender-sensitive approach479 has resulted in protection gaps for women asylum-
seekers in particular for those at risk of violence during the asylum process.  

e.  Protection of victims of sex-based harassment at the workplace 

Under international law, sex-based and sexual harassment are considered as forms of violence 
against women. The overarching challenge in  matters of sex-based harassment has been the 
‘slow  transition’  from  sexual  harassment  at  work  as  a  health  and  safety  problem  to  an 
approach  recognising  it  as  rooted  in  discrimination  and  a  form  of  violence  against  women 
and  domestic  violence.480  EU  law  recognised  sex-based  harassment  as  a  form  of 
discrimination in 2002.481 

The EELN confirms that sex-based and sexual harassment in relation to work are generally 
prohibited at national level as a response to the EU directives on gender equality.482 In most 
Member States, the scope of prohibition of sex-based harassment and sexual harassment has 
been  broader  than  in  EU  law,  going  beyond  the  context  of  employment  and  occupation, 
covering  all  spheres  of  life.  The  report  views  this  as  an  indication  that  Member  States 
consider the current EU legal framework as insufficient, in particular as regards its scope. 

Some trade unions have put considerable effort into mainstreaming violence against women 
and domestic violence in occupational safety and health measures, especially by addressing 
psychosocial  risks  in  risk  assessments  and  in  company  policies.483  However,  such 
frameworks have not proven very effective for lack of gender-sensitivity, thus hindering the 
delivery  of  protection  and  support  at  the  workplace.  Social  partners  reported  that  violence 
against  women  and  domestic  violence  are  still  ‘not  seen  as  a  structural  gender  equality 

478 Interview with PICUM, 2 July 2021. Trafficking victims can be eligible for residency permits but these are 
often temporary. Article 11 (3) of the Anti-Trafficking Directive in fact states that Member States shall take the 
necessary measures to ensure that assistance and support for a victim are not made conditional on the victim’s 
willingness  to  cooperate  in  the  criminal  investigation,  prosecution  or  trial,  without  prejudice  to  Directive 
2004/81/EC or similar national rules. Article 8 of Directive 2004/81/EC states that with regard to the issue and 
renewal of the residence permit MS authorities need to consider among other factors whether the third-country 
national has shown a clear intention to cooperate and Article 14 on withdrawal specifies that the residence permit 
may  be  withdrawn  (among  other  factors)  if  the  competent  authority  believes  that  the  victim's  cooperation  is 
fraudulent or that his/her complaint is fraudulent or wrongful; or when the victim ceases to cooperate. Thus the 
Anti-Trafficking Directive in itself contains a provision to the contrary, but provides for a way for the provisions 
of  Directive  2004/81/EC  to  apply  that  put  a  cooperation  obligation  on  the  third-country  national  victims  of 
human beings seeking residence permits. 
479  The  Asylum  Procedures  Directive  2013/32  requires  gender  competence  during  the  interview  (Article 
15(3)(a)), an interviewer of the same sex (Article 15(3)(b)), an interpreter of the same sex (Article 15(3)(c)), the 
assessment of vulnerabilities, i.e. that an applicant is in need of special procedural guarantees (Article 24(1)) and 
adequate  support  if  applicants  need  special  procedural  guarantees  as  a  result  of  rape  or other  serious  forms  of 
psychological,  physical  or  sexual  violence  (Article  24(3)).  Furthermore,  dependent  adults  must  consent  to  the 
lodging of applications on their behalf, following dedicated and in private information about the consequences 
(Article 7(2)). They must also have an opportunity for a separate personal interview (Article 14(1)(3)). 
480 While not all harassment is violence, sex-based and sexual harassment are recognised as a form of violence 
against women and domestic violence. 
481 Infra. 
482 Supra, p. 82.  
483 Safe at work report p. 23 and social partner workshop.  

17 

 
 
 
                                                 
issue’.484  Nonetheless,  they  have  engaged  in  a  wide  range  of  measures  and  provided 
assistance,  particularly  through  collective  bargaining  (see  e.g.  Framework  Agreement  on 
Harassment  and  Violence  at  Work,  to  which  they  link  most  of  their  action  at  least  at  EU 
level485).486  

Another  important  gap  is  the  lack  of  measures,  at  the  workplace,  to  address  the  effects  of 
domestic  violence  at  work.  Domestic  violence  is  considered  largely  unrelated  to 
employment,  and  occurring  in  the  private  sphere,  thus  not  triggering  action  on  the  part  of 
employers.487 Nevertheless, domestic violence has an impact at the workplace, for instance in 
terms  of  prolonged  absences  and  reduced  productivity.  This  gap  has  been  recognized  at 
international  level  (ILO  Recommendation,  no.  206),  but  not  in  the  Gender  Equality 
Directives at EU level. 

f.  Protection of victims of cyber violence against women  

The general provisions of EU law applicable to all victims of all crime do not address victims 
of cyber violence against women specifically. According to the EELN report, no countries –
except  Romania–  have  a  specific  legal  definition  of  cyber  violence  against  women.  11 
Member  States488  have  criminalized  or  are  about  to  criminalize  the  non-consensual 
dissemination  of  intimate/private/sexual  images.489  All  forms  of  cyber  violence  against 
women  are  hence  not  criminalised  in  the  Member  States,  and  no  targeted  criminalisations 
exist at the EU-level. Victims of cyber violence are therefore in most cases  not eligible for 
the  protection  measures  under  the  Victims’  Rights  Directive,  which  apply  to  victims  of 
crime.  

The  limited  effect  of  the  directives  marks  a  significant  protection  gap,  given  the  high 
prevalence of this phenomenon.490 A European Parliament study491 found EU legislation to be 
‘inadequate’.  Firstly,  the  absence  of  a  harmonised  definition  creates  wide  disparities  in 
protection between Member States, despite the cross-border nature of the violence. This also 
brings  several  legal  challenges  such  as  the  difficulties  in  accessing  evidence  in  the  online 
environment and in conducting cross-border investigations in the EU.  

Secondly,  due  to  the  persistent  lack  of  awareness  of  those  forms  of  crimes,  for  various 
reasons,  including  persisting  gender  stereotypes,  victims  may  not  be  aware  of  their  rights 

and 

484 COM/ICF meeting with social partners 29 June 2021; COM meeting with a number of employer associations, 
30 June 2021 (see annex 2).  
485 European Agency for Safety and Health at Work, Framework agreement on harassment and violence at work, 
2017,  available  at:  (https://osha.europa.eu/en/legislation/guidelines/framework-agreement-on-harassment-and-
violence-at-work). 
486  ETUC,  Safe  at  home,  safe  at  work:  Trade  union  strategy  to  prevent,  manage  and  eliminate  work-place 
at: 
harassment 
(https://www.etuc.org/sites/default/files/document/files/en_-_brochure_-_safe_at_home_1.pdf). 
487 COM/ICF consultation with social partners, 30 June 2021.  
488 BE, FR, IE, IT, MT, NL, PL, PT, ES, SE. 
489 Supra, p. 9. 
490  EPRS,  Combating  gender-based  violence:  Cyberviolence,  European  added  value  assessment,  2021,  p.  8, 
available 
at: 
(https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662621/EPRS_STU(2021)662621_EN.pdf).  FRA 
estimates that 11% of women have experienced cyber harassment or cyber stalking since the age of 15. 
491 Supra 490, pp. 12-13. 

available 

violence 

women, 

against 

2017, 

18 

 
 
 
                                                 
and/or  may  face  many  obstacles  in  obtaining  protection,  reporting  crimes,  being  taken 
seriously,  and  recovering  from  the  incident.492  EIGE  held  that  the  response  of  law 
enforcement as well as treatment of victims across the EU are deeply inadequate.493 Literature 
attributes these shortcomings to the lack of specific legal instruments targeted to address this 
type of violence.494  

g.  Protection of women and girls victims of trafficking  

The Anti-Trafficking Directive has effectively contributed to addressing trafficking in women 
and  girls  as  a form of violence  against women  and domestic violence.  All but  one Member 
States  –  Germany  –  have  some  cooperation  mechanisms  (formal  or  informal)  in  place 
according  to  Article  11(4)  of  the  directive,  to  improve  early  identification,  assistance  and 
support  to  victims  of  trafficking.495  Gender-specific  measures  include  policy  instruments 
informing  healthcare  on  how  to  identify  victims  trafficked  for  sexual  exploitation,  training 
and guidance for immigration authorities on violence against women and domestic violence, 
and assistance especially addressing victims in hotspots.496 
A  gender-sensitive  interpretation  of  the  directive  has  improved  its  effectiveness.497 
According to EIGE, the EU measures promote gender responsive legal or policy measures498 
and  the  provisions  on  identification,  support  and  protection  are  satisfactory.499  Gender 
sensitivity is  also a response to empirical trends, showing that sexual exploitation makes up 
60% of trafficking cases and 90% of victims are female.500 Legal and policy measures overall 
are reported as strong. According to the EELN report, all states  criminalise sexual violence 
explicitly in connection to trafficking in human beings, except for IT and SI.501  

Potential protection gaps nevertheless exist for women victims of trafficking, relating to the 
difficulties  in  presenting  and  substantiating  an  application  for  international  protection 

492 Supra 490, p. 232.  
493 EIGE, Cyberviolence against women and girls, 2017, available at: (https://eige.europa.eu/publications/cyber-
violence-against-women-and-girls). 
494  K.  Barker  &  O.  Jurasz,  “Online  violence  against  women  as  an  obstacle  to  gender  equality:  a  critical  view 
from Europe”, European Equality Law Revision, Vol. 2020/1, 2020, pp. 47-60.  
495  European  Commission,  Study  on  reviewing  the  functioning  of  Member  States’  National  and  Transnational 
Referral  Mechanisms,  HOME/2018/ISFP/PR/THB/0000,  2018,  available  at: 
(https://ec.europa.eu/anti-
trafficking/sites/antitrafficking/files/study_on_reviewing_the_functioning_of_member_states_national_and_tran
snational_referral_mechanisms.pdf). 
496 European Commission, Third report on the progress made in the fight against trafficking in human beings 
(2020) as required under Article 20 of Directive 2011/36/EU on preventing and combating trafficking in human 
beings and protecting its victims, COM(2020) 661 final {SWD(2020) 226 final}, 20 October 2020, available at: 
(https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0661). 
497 European Commission, The EU Mutual Learning Programme in Gender Equality: Combatting trafficking in 
women  and  girls  for  the  purpose  of  sexual  exploitation,  Spain,  29-30  October  2018,  Summary  Report,  2018, 
available at: (https://ec.europa.eu/info/publications/mlp-gender-equality-seminar-combatting-trafficking-women-
and-girls-purpose-sexual-exploitation-madrid-29-30-october-2018_en). 
498  EIGE,  An  analysis  of  the  Victims’  Rights  Directive  from  a  gender  perspective,  2016,  available  at: 
(https://eige.europa.eu/publications/analysis-victims-rights-directive-gender-perspective). 
499  EIGE,  Gender-specific  measures 
(https://eige.europa.eu/publications/gender-specific-measures-anti-trafficking-actions-report). 
500 Supra 496, pp. 3-4.  
501 The report does not clarify the situation in Italy or Slovenia. Italy nonetheless has strong measures in place for 
anti-trafficking in Decree 2014/24 (transposing Directive 2011/36) (Italy country report).  

in  anti-trafficking  actions: 

report,  2018, 

available 

at: 

19 

 
 
 
                                                 
under  the  asylum  directives.  This  could  lead  to  a  lack  of  identification  of  victims  of 
trafficking  or  at  risk  of  being  exploited  among  applicants  and  thus  to  ineffective  referral  to 
adequate  support.502  Another  challenge  in  addressing  trafficking  is  the  low  level  of 
prosecution and conviction.503 

h.  Coherence with international standards 

While EU law contains  several provisions on protection of victims, including on restraining 
and protection orders, as well as regarding the assessment of the protection needs of particular 
categories of victims, it however fails to address the specific protection needs of victims of 
violence  against  women  and  domestic  violence  as  required  by  the  Istanbul  Convention 
(Chapter IV). In particular, EU law does not require the provision of specific training for law 
enforcement authorities would be needed to understand why their interventions in situations 
of domestic violence is needed and what is expected of their intervention.504 

Compared  to  EU  law,  the  Istanbul  Convention  and  ILO  Convention  No.  190  have  widened 
the scope of the protection from sexual harassment and harassment based on sex to include 
behaviours in spheres of life that are not limited to employment, occupation, and the provision 
of and access to goods and services505. This is an important gap in EU law, even if it applies 
to the anti-discrimination legal framework at EU level more generally. 

The EU legal framework can generally be considered in line with the Istanbul Convention’s 
standards  on  the  protection  of  women  asylum  seekers  who  are  victim  of  violence  against 
women  or  domestic  violence;  however  EU  law  fails  in  addressing  the  requirements  on 
protection prescribed by the UNCRPD. 

i.  Conclusion 

The  EU  law  framework  contains  protection  obligations  in  a  fragmented  manner.  Either  the 
measures  target  victims  of  all  types  of  crime  (as  for  the  Victims’  Rights  Directive  and  the 
EPO  Directive)  or  target  very  specific  group  of  victims,  such  as  children  victims  of  sexual 
abuse and victims of trafficking in human beings.  

The instruments on the mutual recognition of protection orders are mainly applied to cases of 
violence  against  women  and  domestic  violence.  National  requirements  on  the  modalities  of 
protection  measures  however  vary  considerably,  which  has  led  to  the  EU-level  instruments 
being  considerably  underused.  In  addition,  the  lacking  availability  of  interpretation  and 

502 Supra 496, p. 9. 
503 The EU framework addresses these issues through the Victims’ Rights Directive (chapter 4), the Anti-
trafficking Directive (Article 12), the European Protection Order Directive, and the Protection Measures 
Regulation and the Gender Equality Directives (prohibition of discrimination). 
504 FRA, Women as victims of partner violence – Justice for victims of violent crime, Part IV, 2019, p. 12, 
available at: (https://fra.europa.eu/en/publication/2019/women-victims-partner-violence-justice-victims-violent-
crime-part-iv). 
505  European  network  of  legal  experts  in  gender  equality  and  non-discrimination,  Thematic  Report  on  the 
Criminalisation of gender-based violence against women in European States, including ICT-facilitated violence, 
at 4.4. 

20 

 
 
 
                                                 
 
translation services at national level is a particularly important obstacle especially for migrant 
women, for whom the fragmented legal framework also leads to a lack of protection. 

Sex-based and sexual  harassment  in  relation  to work  and the access  to  and supply of  goods 
and  services  are  generally  prohibited  at  national  level  as  a  response  to  the  Gender  Equality 
Directives.  These  obligations  however  do  not  contain  explicit  provisions  on  measures  to  be 
taken for the protection of the victim in concrete cases of sex-based harassment. Despite the 
international  recognition  (in  particular  in  ILO  Recommendation  no.  206)  that  domestic 
violence  experienced  in  private  life  can  have  an  impact  on  work,  the  Gender  Equality 
Directives do not address this issue at EU level. This means that employers are not obliged to 
inform victims of protection measures provided outside the workplace.  

The  EU  provisions  do  not  address  victims  of  cyber  violence  against  women  or  between 
intimate  partners,  resulting  in  a  lack  of  effective  protection.  Victims  of  different  forms  of 
cyber  violence  are  not  eligible  for  protection  under  the  Victims’  Rights  Directive,  if  the 
conduct  is  not  criminalised  under  national  law.  There  are  currently  no  targeted  EU-level 
criminalisations.  

EU  law  provisions  thus  fail  to  address  the  specific  protection  needs  of  victims  of  violence 
against women and domestic violence as required by the Istanbul Convention. 

The  lack  of  provisions  taking  into  account  multiple  discrimination  occurring  at  the 
intersection of sex and disability is a barrier for the full protection of women with disabilities 
from violence targeting them.  

3. Access to justice for victims of violence against women and domestic violence 

a.  Criminalisation 

Only the CSA and Anti-Trafficking Directives currently include EU-level criminalisations of 
specific  forms  of  violence  against  women  and  domestic  violence.  The  Gender  Equality 
Directives require Member States to sanction sex-based work harassment in employment and 
in the access to and supply of goods and services; this does however not necessarily include 
criminalisation. The majority of respondents to the public consultation are of the opinion that 
sanctions in their Member States for this kind of violence are not sufficient (75%). Only 11% 
said they were sufficient.  

While most conduct related to violence against women and domestic violence is criminalized 
at national level, this does leave important gaps.  

A significant gap exists in the area of cyber violence against women. Cyber violence against 
women is a relatively new phenomenon which has so far not been addressed in EU law. The 
forthcoming DSA impose certain  obligations on intermediary service providers to   act  upon 
notification  and  tackle  illegal  content;  however,  the  DSA  does  not  itself  define  what 
constitutes illegal content. In the absence of an EU-wide definition of cyber violence against 
women,  the  application  of  the  DSA  will  depend  on  the  level  of  criminalisation  of  such 
violence  at  national  level,  which  for  the  time  being  is  rather  limited.  The  lack  of 
criminalisations  directly  affects  the  victims’  access  to  justice:  if  other  remedies,  such  as 
measures of civil and administrative law, are not available in individual cases, and if victims 
are unable to obtain the removal of the content from the platform, criminalisation of serious 

21 

 
 
 
 
 
 
forms of such cyber violence enable the state to guarantee victims’ access to justice and the 
offender’s entitlement to due process506. 

Another  gap  exists  with  regard  to  sex-based  harassment  at  work:  the  background  studies 
conducted  for the initiative show that the implementation of the  relevant  provisions has not 
been effective, and sexual harassment continues to remain common in the Member States. 507   

b. Reporting 

Despite the measures to protect victims from intimidation, retaliation and repeat victimisation 
in the Gender Equality Directives and the Victims’ Rights Directive, Member States refer to 
the lack of reporting as a serious problem to effectively address violence against women and 
domestic  violence.508This  is  also  confirmed  by  the  recent  FRA  survey  “Crimes,  Safety  and 
Victims’ Rights”.509 Further, with the exception of the CSA Directive, the EU acquis does not 
sufficiently  ensure  reporting  by  third-parties,  indicating  a  lack  of  training  on  identifying 
potential  victims  of  this  kind  of  violence  or  concerns  about  breaching  professional 
confidentiality  rules.510  The  targeted  consultation  showed  that  relevant  professionals  are  not 
obliged to report, in particular, suspicions of early, child or forced marriages or FGM in five 
Member States.511 

There  are  several  reasons  for  underreporting,  which  is  very  specific  to  the  area  of  violence 
against  women  and  domestic  violence.  First  of  all,  victims  of  violence  against  women  and 
domestic violence are particularly sensitive to secondary victimisation, including the stigma, 
victim-blaming512, and the risk of retaliation by way of a defamation claim513 that are often 
associated with this type of violence. The problem of underreporting also specifically affects 
victims  of  violence  against  women  at  the  workplace,  due  to  victims’  fear  of  career-related 
retaliation,  high  societal  tolerance  for  sex-based  harassment514,  a  lack  of  information  and 
reporting mechanisms515, and a lack of awareness at the most senior levels of employers.516 

506 EELN 2021, at 9. 
507 Supra 505. 
508 Submission for the Member States Targeted Consultation q. 43. 
509 FRA survey, Crime, Safety and Victims’ Rights, 2021, available at: 
(https://fra.europa.eu/sites/default/files/fra_uploads/fra-2021-crime-safety-victims-rights_en.pdf). Only 30% of 
incidents involving physical violence, and 11% of those involving harassment were reported. 
510 Supra 430. 
511 Submission for the Member States Targeted Consultation q. 45 and 46.  
512 European Commission, Special Eurobarometer 449 – Report Gender-Based Violence, 2016, p. 58, available 
at: (https://europa.eu/eurobarometer/surveys/detail/2115): more than one in five respondents (22%) across the 
EU agree women often make up or exaggerate claims of abuse or rape, although this figure masks a wide 
variation between countries. Respondents in MT (47%), CY (44%) and LT (42%) are the most likely to agree, 
compared to 8% in SE and 13% in FR and IT. 
513 Supra, p. 82. 
514 Eurofound, Violence and harassment in European workplaces: Causes, impacts and policies, 2015, p. 52, 
available at: 
(https://www.eurofound.europa.eu/sites/default/files/ef_comparative_analytical_report/field_ef_documents/ef14
73en.pdf). 
515 (https://eige.europa.eu/publications/sexism-at-work-handbook/part-1-understand/under-reporting-sexual-
harassment), last visited (18/08/2021). 

22 

 
 
 
 
 
 
 
                                                 
In  addition,  the  lack  of  information  on  the  follow-up  to  complaints517  is  one  of  the  factors 
highlighted  by  EIGE  as  discouraging  in  particular  victims  of  domestic  violence  from 
reporting.518  Also,  when  victims  report,  they  are  often  subject  to  secondary  victimisation. 
Only the CSA and Anti-Trafficking Directives ensure that prosecution is not dependent on the 
cooperation of the victim. Prosecution ex officio for most serious forms of violence against 
women and domestic violence crime would alleviate the burden of cooperation for victims. 

Furthermore, victims of in particular domestic violence often have financial barriers which 
prevent  them  from  seeking  access  to  justice.  Even  though  legal  aid  is  available  in  most 
Member States, in line with the Victims’ Rights Directive519, access is barred by lengthy and 
difficult  processes to prove eligibility  and lack of information  on conditions  and procedural 
rules  at  national  level.520  Even  if  this  problem  may  exist  for  all  victims,  it  particularly  hits 
victims  of  domestic  violence  who  may  depend  for  their  living  on  the  perpetrator.  Problems 
have  also  been  highlighted  for  victims  of  sex-based  harassment;  the  assessment  of  the 
implementation of the Self Employed Directive found that in Estonia, reimbursement claims 
for legal  assistance had  to  be filed separately  and claimants could  wait several  years before 
receiving recovery of costs and compensation. Similarly, in Hungary, it was reported that the 
law made it difficult for women to seek effective and proportionate penalties and in Slovakia, 
the claimant was required to pay 3% of the sum claimed in court fees.521 Asylum-seekers can 
face additional barriers including caps on the amount of time a legal representative can spend 
on a case (NL), and legal aid representatives who do not sufficiently understand asylum law 
or violence against women and domestic violence (FI).522  
A  further  important  obstacle  to  reporting  is  the  clear  evidence  of  low  conviction  and 
prosecution of violence against women and domestic violence.523 Victims do not feel taken 
seriously and prefer not to report if they doubt whether any follow-up will be given. Training 
of  law  enforcement  professionals  is  also  relevant  for  the  purposes  of  securing  adequate 
prosecution and convictions. 

Closely linked to the low prosecution and conviction rate is the difficulty to prove a case of 
violence  against  women  and  domestic  violence.524  The  instruments  under  analysis  fail  to 
recognise that most forms of violence produce little traditional evidence. Victims of violence 

516 P. Petroglou, “Sexual harassment and harassment related to sex at work: time for a new directive building on 
the EU gender equality acquis”, European Equality Law Review, Vol. 2, 2019, p. 19. 
517 See: Art. 5 Victims’ Rights Directive. 
518 EIGE written submission to public consultation.  
519 See: Art. 13. 
520 Supra 430.  
521 EELN¸ Self-Employed: The Implementation of Directive 2010/41 on the application of the principle of equal 
treatment  between  men  and  women  engaged  in  an  activity  in  a  self-employed  capacity,  2015,  available  at: 
(https://www.equalitylaw.eu/component/edocman/self-employed-en). 
522 Supra 430.  
523  For  instance,  in  the  area  of  trafficking,  the  third  progress  report  2017-2018  reports  11,788  suspects,  6,163 
prosecutions and 2,426 convictions in the EU. Figures for cases related to sexual exploitation or other forms of 
violence against women and domestic violence are not available, although 60% of trafficking victims are victims 
of sexual exploitation. 
524 Submission for the Member States Targeted Consultation q. 43. 

23 

 
 
 
 
 
                                                                                                                                                         
against women and domestic violence are often reluctant/unable to  testify in  proceedings or 
are  pressured  to  withdraw  reports,  and  protection  and  support  measures  are  often  not 
sufficient  to  help  victims  overcome  this  reluctance.  Victims  often  feel  that  the  court  only 
looked  at  one  violent  incident  in  isolation  without  recognising  the  severity  of  the  harm 
inflicted overall.525 The complexity in anti-trafficking cases leads to additional difficulties in 
international evidence gathering.526 Guidance to prosecutors on how to approach and handle 
cases of violence against women and domestic violence with regard also to the difficulties in 
gathering and assessing evidence would be welcomed by many stakeholders.527 

c.  Compensation 

The  2019  Milquet  report  on  compensation  prepared  for  Commission  President  Juncker 
highlighted  violence  against  women  as  one  of  the  three  areas  of  crime  where  access  to 
compensation is  particularly problematic.528  This  is the case despite the minimum  standards 
set in the Compensation Directive and, at least for certain types of sex-based harassment, the 
Gender Equality Directives and the Victims’ Rights Directive.  

Levels  of  compensation  are  inadequate.  The  Gender  Equality  Directives  require  ‘real  and 
effective’ compensation, but without further guidance on what this should mean in practice. 
Even  if  victims  can  claim  compensation,  such  as  healthcare  costs  and  other  quantifiable 
damages, from the perpetrator in all States,529 the Milquet report concludes that ‘the amount 
of  compensation  attributed  in  violence  against  women  and  domestic  violence  cases  is  often 
very low. This might in  part be related to a lack of awareness  and training of judges on the 
dynamics  and  traumatic  consequences  of  this  type  of  crime.  The  amount  of  compensation 
should reflect the wide-ranging and long-term harm of gender-based violence, going beyond 
potential medical and therapy costs, to also cover loss of earnings and broader psychological 
damages. Compensation should serve as a means for re-building an independent and violence-
free life of dignity”.530  
In  several  States,531  rehabilitation  is  regularly  provided  through  public  services.  State 
compensation is  usually  granted subsidiarily, in  the absence of compensation obtained from 
the  perpetrator  or  other  sources.  The  Compensation  Directive  establishes  a  mechanism 
facilitating  access  to  state  compensation  in  cross-border  cases  for  all  victims  of  violent 
intentional crimes. The Court of Justice has recently clarified that the Compensation Directive 
also imposes an obligation on Member States to set up national state compensation schemes 
including in cases without a cross border nature and ensure an adequate level of compensation 
at  national  level.  In  line  with  the  Compensation  Directive,  State  compensation  is  mostly 

525  FRA,  Sanctions  that  do  justice  –  Justice  for  victims  of  violent  crimes,  Part  III,  2019,  p.  19,  available  at: 
(https://fra.europa.eu/en/publication/2019/sanctions-do-justice-justice-victims-violent-crime-part-iii). 
526 Supra 496.  
527 See annexes 2 and 4. 
528  European  Commission,  Strengthening  Victims’  Rights:  from  compensation  to  reparation.  For  a  new  EU 
Victims’ rights strategy 2020-2025. Report of the Special Adviser, J. Milquet, to the President of the European 
Commission,  Jean-Claude  Juncker,  2019,  available  at: 
(https://ec.europa.eu/info/files/summary-report-
strengthening-victims-rights-compensation-reparation_en). 
529 Supra 528, p. 185. 
530 Supra 133, p.32. 
531 HR, EE, FI, DE, EL, LT, ES. 

24 

 
 
 
 
                                                 
restricted to victims of violent crimes, and in at least 12 States,532 this option is only available 
if  victims  have  sustained  serious  bodily  injury  or  impairment  of  health  –  thus  excluding 
other  forms  of  violence.  This  is  especially  a  problem,  for  instance,  in  the  area  of 
trafficking:533 when pimps or traffickers have no assets – or they cannot be found – women 
often receive no compensation or compensation is simply too low.534   

Problems with compensation are not limited to the level of compensation, they also concern 
the  procedure  for  claiming  compensation  itself.  The  VOCIARE  report  notes  that  while  the 
vast majority of Member States guarantee the right of the victim to seek compensation within 
criminal proceedings535, criminal judges are not always obliged to decide on such claims. As a 
result, victims may have to  re-testify in the subsequent civil  proceedings.536 Art.  16(1) of 
the  Victims’  Rights  Directive  leaves  it  up  to  Member  States  to  allow  victims  to  seek 
compensation within the criminal proceedings or to refer them to separate civil proceedings, 
thus exposing them to high risks of secondary victimisation. 

Furthermore, almost half of the respondents of the public consultations (49%) do not believe 
that information  on  access  to  compensation  is  available  in  their  Member  States.537  84% 
described the process of pursuing compensation as difficult and long.538  

d.  Coherence with international standards 

With regards to compensation, Article 30 of the Istanbul Convention provides for the right of 
the  victims  to  claim  compensation  from  the  perpetrator  for  all  forms  of  violence  against 
women and domestic violence. Compensation can also be sought  from insurance companies 
or  from  state-funded  health  and  social  security  schemes.  This  Article  also  establishes  a 
subsidiary  obligation  for  the  state  to  compensate.  The  Compensation  Directive  facilitates 
access to state compensation for victims of violent intentional crimes, committed in other EU 
Member States or in their Member State of residence.539 It obliges Member States on whose 
respective territories the crime has occurred to establish a national scheme on compensation 
and  guarantee  victims’  access  to  fair  and  adequate  compensation.540  However  the  way 
national  authorities develop,  implement  and understand the  right  for  compensation is  left  to 
the discretion of the Member States. In several  States541, rehabilitation is regularly provided 
through  public  services.  In  line  with  the  Compensation  Directive,  it  is  mostly  restricted  to 
victims of violent crimes, and in at least 12 States542, this option is only available if victims 
have sustained serious bodily injury or impairment of health – thus excluding other forms of 
violence. 

532 BE, CZ, DE, HU, LU, MT, NL, PL, PO, RO, ES. 
533 See the mutual learning seminar on trafficking, Supra 497.  
534 For example, in Spain, the average compensation is around €150. 
535 Infra 547.  
536 Infra 547, p. 121.  
537 See: Art. 9 Victims’ Rights Directive. 
538 Public consultation q. 19. 
539 See also: CJEU, Case C-129/19 (Presidenza del Consiglio dei Ministri v. BV), ECLI:EU:C:2020:566, 16 July 
2020. 
540 Supra 411, Recital (11) & Art. 12 (2). 
541 HR, EE, FI, DE, EL, LT, ES. 
542 BE, CZ, DE, HU, LU, MT, NL, PL, PO, RO, ES. 

25 

 
 
 
 
                                                 
With few exceptions (child sexual abuse and trafficking in human beings), EU law does not 
provide for the criminalisation of most of the forms of violence against women and domestic 
violence.  

e. Conclusion 

The current EU law framework fails to address targeted needs of victims of violence against 
women and domestic violence with regard to their access to justice. 

The  reporting  rate  of  such  violence  is  very  low  and  has  been  recognised  by  several  EU 
Member States as a problem to be urgently addressed.  

Regarding cyber violence against women and intimate partners, the EU legal framework does 
not  include  specific  criminalisations  or  other  targeted  measures  to  facilitate  this  group’s 
access to justice. 11 Member States have criminalised or are about to criminalise some forms 
of such violence. Since the Victims’ Rights Directive applies to criminalised conduct, victims 
of  cyber  violence  against  women  are  often  not  eligible  for  protection  and  support  measures 
under the Directive. 

Lack of adequate compensation remains a challenge and obstacle for this group of victims in 
accessing justice, despite the minimum standards of the Compensation Directive and, for sex-
based  harassment,  the  Gender  Equality  Directives.  A  report  on  victims’  compensation  from 
2019 concludes that ‘the amount of compensation attributed in  violence against women and 
domestic violence cases is often very low’ and compensation is not granted in adequate time. 

4. Support to victims of violence against women and domestic violence 

a.  General support 

The  EU  framework,  mainly  through  the  Victims’  Rights  and  Anti-trafficking  Directives, 
provides that victims of all crime and victims of trafficking respectively receive appropriate 
information  in  their  first  contact  with  authorities,  assistance  to  participate  in  criminal 
proceedings and a variety of support services, including specialised support services, such as 
shelters  or  interim  accommodations  and  specialised  counselling  (Chapter  II  and  III  of  the 
Victims’ Rights Directive; Article 11 of the Anti-trafficking Directive). They also guarantee 
that  women  victims  of  violence  receive  individualised  protection  to  reduce  possible  re-
victimisation (Chapter IV of the Victims’ Rights Directive; Article 12 of the Anti-trafficking 
Directive).  

Despite this acquis, gaps remain in the EU framework. The Victims’ Rights Directive, mainly 
in  Articles 4 and 7, requires Member States to  ensure that if needed there are interpretation 
and  translation  services  available  to  woman  victims  so  that  they  can  understand  the 
information  they  receive.  However,  while  foreseeing  such  right  for  victims  when  making  a 
complaint and during criminal proceedings, it does not foresee it in relation to, or as part of, 
the access to protection and support offered to all victims. Hence an important gap exists in 
this  regard.  Moreover,  such  protection  is  also  not  available  to  victims  in  the  European 
Protection  Order  procedure  and  the  cross-border  recognition  of  protection  measures  in  civil 
law  procedure.  In  addition,  the  EU  framework  does  not  provide  a  procedure  to  ensure  that 
women victims receive equivalent support measures if they move cross-border. 

26 

 
 
 
 
 
b.  Specialised support 

Helplines 

The EU framework does not provide for the establishment of a harmonised helpline to support 
and  assist  women  victims  of  gender-based  violence.  The  EU  has  made  such  requirement 
regarding e.g. children’s helplines (Article 96 Directive (EU) 2018/1972).Work towards such 
an EU-level helpline has been set up by the German Presidency in 2019; so far 15 Member 
States  have  signed  up  to  it.  An  EU  level  obligation  on  Member  States  would  ensure  the 
success of this helpline.  

Shelters 

On access to shelters543, the Commission found implementation problems in several Member 
States,  including  as  regards  the  availability  of  shelters  for  victims  of  certain  types  of  crime 
and an insufficient number of shelters. Such shortcomings tend to particularly affect victims 
of violence against women and domestic violence.  

The WAVE Report (2019) shows that only three countries544 fulfil the requested number of 
specialised women’s shelters per 10,000 people recommended by the Istanbul Convention.545 
51% of beds needed are missing.546 Victim Support Europe notes547 insufficient geographical 
coverage in a number of countries.548 There are access barriers for children, migrant women 
and  women  with  a  disability.  Given  the  lack  of  knowledge  concerning  victims’  support 
services  amongst  relevant  authorities,  their  discretion  on  referral  to  support  services  could 
lead to gaps.549  

Women with disabilities 

Article  3(2)  of  the  Victims’  Rights  Directive  requires  Member  States  to  ensure  that 
communication  with  victims  takes  into  account  possible  disabilities  which  may  affect  the 
ability of victims to understand or to be understood. This limited provision in EU law does not 
address  the  many  challenges  faced  by  women  with  disabilities,  as  recognised  by  the  CRPD 
which  requires  addressing  the  needs  of  persons  with  disabilities  specifically.  The  main 
problem  is  that,  apart  from  Article  3(2)  Victims’  Rights  Directive,  the  EU  framework 
considers women with disabilities within the broader category of vulnerable victims and not 
as a group with specific needs and rights.  

543 See: Art. 9(3). 
544 LU, MT, SL. 
545 WAVE, Wave Country Report 2019 – The Situation of Women’s Specialist Support Services in Europe, 2019, 
available at: (https://www.wave-network.org/2019/12/30/wave-country-report-2019). 
546 Supra 545.  
547  Victim  Support  Europe,  Victims  of  Crime  Implementation  Analysis  of  Rights  in  Europe:  Synthesis  Report, 
2019, 
(https://victimsupport.eu/activeapp/wp-
content/uploads/2019/08/VOCIARE_Synthesis_Report-web.pdf). 
548 BG, HR, CY, EL, ES, IT, LT, LU, RO, SK. 
549 Supra 547, p. 57.  

available 

56, 

at: 

p. 

27 

 
 
 
 
 
                                                 
The supporting study shows limitations in the support to victims with disabilities in most of 
the MS, including an important lack of sensitization and training of professionals550 and lack 
of support services more generally551. Other challenges concern victims with disabilities more 
generally, including victims of violence against women and domestic violence. For instance, 
in  the  Targeted  Consultation,  only  about  half  of  Member  States  reported  having  fully 
accessible  support  services  (i.e.  availability  of  barrier-free  environment,  easy  to  read  and 
understand  language,  sign  language  interpretation,  etc.).552  In  its  written  submission  to  the 
public  consultation,  the  European  Disability  Forum  notes  barriers  throughout  the  entire 
criminal justice process, including to victims’ support services because of a lack of qualified 
interpreters for deaf and deafblind women. 

The EU legal framework therefore does not guarantee disability inclusiveness of the support 
services  provided  to  women  victims  of  violence  against  women  and  domestic  violence  as 
required by Article 16(3) CRPD. Furthermore, the EU framework does not ensure that people 
involved  with  persons  with  disabilities  (including  victims  of  violence  against  women  and 
domestic  violence)  receive  appropriate  training,  as  required  by  Article  4(1)(i)  CRPD.  In 
addition,  the  EU  framework  is  not  consistent  with  the  requirements  of  Article  13  CRPD 
regarding effective access to justice for persons with disabilities, including victims of violence 
against women and domestic violence) in court, investigative and other proceedings, as it does 
not  provide  any  procedural  accommodation  in  that  regard.  Hence,  important  gaps  exist  in 
relation to the rights and protection of people with disabilities, including victims of violence 
against women and domestic violence.   

Children 

While children are generally recognised as a particularly vulnerable group of victims of crime 
in  EU  law  (see  Article  24  of  the  Victims’  Rights  Directive;  Articles  13-16  of  the  Anti-
trafficking Directive), their status is uncertain when they are not direct victims of violence but 
witnesses of violence. This is especially problematic in situations of domestic violence.  
A  recent  Study  on  the  added  value  of  tackling  violence  against  women553  highlighted  that 
currently  in  the  EU  Member  States  there  are  insufficient  measures  to  ensure  the  safety  of 
mothers who are victims of domestic violence and their children in the decision and exercise 
of  child  custody  and  visitation  rights  in  all  Sate  Parties  reviewed  to  date.  Shortcomings  are 
also  noted  in  custody  and  visitation  decisions  and  the  ban  on  obligatory  mediation  in  civil 
procedures.  With  regard  to  support,  in  the  targeted  consultation  only  13  Member  States 
reported  that  their  specialist  support  services  systematically  take  into  account  the  special 
needs  of  child  victims  or  witnesses  of  domestic  violence554  and  10  more  Member  States 
reported  to  apply  a  child  sensitive  approach555,  but  not  systematically.556  A  FRA  report 

550 AT, HR, LT, PL, PT, ES. 
551 AT, HR, LT, PL, PT, ES. 
552 Submission for the Member States Targeted Consultation q.31. 
553  https://www.europarl.europa.eu/RegData/etudes/STUD/2020/658648/IPOL_STU(2020)658648_EN.pdf  at 
105. 
554 DE, IE, NL, AT, PL, LV, BG, LU, DK, ES, BE, HR, IT. 
555 SL, SK, EE, CZ, FI, PT, EL, SK, RO, CY. 
556 Submission for the Member States Targeted Consultation q.22. No response from HU, LT and HR. 

28 

 
 
 
                                                 
concluded  that  children  in  several  countries  believe  that  ‘victim  and  witness  support 
specialists are not widely available or play too passive a role’557.  

A key challenge affecting the effectiveness of the existing EU law is that courts still legally 
categorise  child  witnesses  as  indirect  victims,  despite  it  being  standard  practice  in  child 
protection  to  consider  child  witnesses  as  direct  victims  due  to  the  psychological  harm 
inflicted.558 This can hinder children’s access to services such as counselling as they are not 
considered ‘victims’ within the meaning of Art. 9 Victims’ Rights Directive.  

As  mentioned  above,  in  the  targeted  consultation  all  but  one  responding  Member  States  – 
Denmark559  –  reported  to  provide  specialised  training  on  working  with  child  victims  or 
witnesses of violence against women and domestic violence, encompassing a child-sensitive 
approach.560  

c.  Victims of sex-based and sexual harassment 

EU  law  provides  for  the  support  by  equality  bodies  under  the  Gender  Equality  Directives. 
Such support is, however, only available for sex-based harassment within the scope of these 
directives. This leaves the vast array of victims of other forms of violence against women and 
domestic  violence  outside  the  scope  of  these  directives  without  access  to  assistance  and 
advice in legal procedures.  

Even  where  the  support  comes  in  the  competence  of  equality  bodies,  these  bodies  do  not 
always have the necessary powers to provide effective support.561 One major deficiency exists 
in those States where equality bodies do not have legal standing to represent victims in court. 
Only  in  nine  Member  States,  can  equality  bodies  act  on  behalf  of  victims.  Also,  equality 
bodies cannot act on behalf of a group of victims, except in four Member States. This limits 
collective action, something that may be particularly useful in cases of workplace harassment. 
An  Equinet  survey  noted  the  following  challenges  expressed  by  equality  bodies:  a  lack  of 
clarity on their mandate relating to sex-based discrimination, including sexual and sex-based 
harassment,  a  lack  of  attention  to  gender-based  cyber  violence  and  problems  in  adequately 
addressing intersectionality.562  

d.  Compliance with international standards 

in 

or 

parties 

nine  EU  Member  States, 

557  FRA,  Child-friendly  justice  -  Perspectives  and  experiences  of  children  involved  in  judicial  proceedings  as 
victims,  witnesses 
at: 
(https://fra.europa.eu/en/publication/2017/child-friendly-justice-perspectives-and-experiences-children-involved-
judicial). 
558 Supra, p. 6; Luxembourg Country Report.  
559 Denmark is not bound by the Victims’ Rights Directive. 
560 Submission for the Member States Targeted Consultation q.12 No response from MT and DE.  
561 Submission for the Member States Targeted Consultation q. 39. 
562 
 Equinet, Tackling Violence against Women and Gender-Based Violence: Equality Bodies’ Contribution¸ 2019, 
(https://equineteurope.org/2019/tackling-violence-against-women-and-gender-based-violence-
available 
equality-bodies-contribution/). 

2017,  p. 

available 

79, 

at: 

29 

 
 
 
 
 
                                                 
The Istanbul Convention entails a set of provisions regarding assistance and support measures 
for  women  victims  of  violence,  including  access  to  information,  general  (Article  20)  and 
specialist support services (Article 22) to victims of violence and sexual violence (Article 25), 
shelters  (Article  23),  telephone  helplines  (Article  24),  assistance  in  complaint  procedures 
(Article 21) and protection of child victims and witnesses (Article 26). 

Regarding  gaps  in  EU  law  compared  to  the  standards  set  by  the  Istanbul  Convention,  as 
mentioned  above,  the  EU  framework  does  not  address  the  issue  of  witnesses  of  violence 
against  women  and  domestic  violence,  particularly  child  witnesses.  The  framework  does 
address  the  needs  of  child  victims  of  violence  (Article  24  of  the  Victims’  Rights  Directive, 
Articles  13-16  of  the  Anti-trafficking  Directive),  but  only  when  they  are  considered  direct 
victims themselves.  

Lastly, the EU framework does not yet provide for the establishment of a harmonised helpline 
to  support  and  assist  women  victims  of  gender-based  violence.  However,  the  EU  has  made 
such requirement regarding e.g. children’s helplines (Article 96 Directive (EU) 2018/1972). 

e.  Conclusion 

For  support  measures  the  EU  framework  provides  general  measures  such  as  for  example 
interpretation  and  translation,  but  since  those  are  not  provided  for  victims  of  all  forms  of 
violence  against  women,  their  lack  in  access  to  protection  or  support  services  can  lead  to 
important gaps for victims. 

Among specialised support services the EU law does not provide for a helpline for victims of 
violence against women and domestic violence, and the availability of shelters for victims is 
insufficient. Access to shelters is not specifically ensured for certain groups of victims such as 
children on women with disabilities.  

EU law considers women with disabilities within the broader category of vulnerable victims 
and not as a group with specific needs and rights, and does not follow the approach of CRPD 
which requires addressing the needs of persons with disabilities specifically.  

Stakeholders  reported  a  lack  of  support  services  fully  accessible  to  women  with  disabilities 
(i.e.  availability  of  barrier-free  environment,  easy  to  read  and  understand  language,  sign 
language  interpretation,  etc.),563  and  barriers  throughout  the  entire  criminal  justice  process, 
including to victims’ support services because of a lack of qualified interpreters for deaf and 
deafblind women.564 

A key challenge affecting the effectiveness of the existing EU law is that courts still legally 
categorise  child  witnesses  as  indirect  victims,  despite  it  being  standard  practice  in  child 
protection  to  consider  child  witnesses  as  direct  victims  due  to  the  psychological  harm 

563 Submission for the Member States targeted consultation q.31. 
564 European Disability Forum, Recommendations on EU policies to combat violence against women and girls 
with disabilities https://www.edf-feph.org/publications/edf-position-paper-on-violence-against-women-and-girls-
with-disabilities-in-the-european-union/ at p. 11. 

30 

 
 
 
 
                                                 
inflicted.565 This can hinder children’s access to services such as counselling as they are not 
considered ‘victims’, and shortcomings are noted in custody and visitation decisions and the 
ban on obligatory mediation in civil procedures.   

EU  law  provides  for  the  support  by  equality  bodies  under  the  Gender  Equality  Directives, 
which  is  however  only  available  to  victims  of  sex-based  harassment,  leaving  victims  of  all 
other  forms  of  violence  against  women  and  domestic  violence  without  access  to  assistance 
and advice in legal procedures. Equality bodies also often lack sufficient powers to grant this 
assistance where mandated with it. 

The  lack  of  specific  provisions  for  witnesses,  particularly  children  witnesses  of  violence 
against  women  and  domestic  violence  leaves  a  gap  compared  to  international  requirements, 
especially in the Istanbul Convention. 

5. Coordination at national level and data collection 

a.  Coordination at national level 

Several of the instruments of the EU framework require Member States to engage in dialogue 
with  non-governmental  organisations  (Article  22  Gender  Equality  Recast  Directive)  or  to 
facilitate  the  involvement  of  such  organisations  in  providing  support  to  victims  (Article  8 
Victims’  Rights  Directive),  providing  support  in  judicial  proceedings  (Article  7  Directive 
2010/41/EU) or providing support in  the asylum  application procedures  (Article 10  Asylum 
Procedures Directive). However, the EU framework does not foresee a consultation with civil 
society  during  the  development,  implementation,  and  evaluation  of  national  policies.  Such 
involvement  is  essential  in  ensuring  that  the  needs  of  women  victims  of  violence  are 
addressed effectively. In addition, EU law does not provide for coordinated action among all 
actors  involved  in  the  fight  against  violence  against  women  and  domestic  violence,  despite 
such  coordination  generally  being  recognised  as  absolutely  necessary  for  an  effective 
response. 

b.  Data collection 

As  regards  the  collection  of  disaggregated  statistical  data  on  all  forms  of  violence  against 
women  and  domestic  violence,  the  EU  framework  requires  some  data  collection  that  is 
relevant to violence against women and domestic violence, in particular from equality bodies 
(Gender Equality Directives). It also entails obligations on data collection on victims’ rights 
(Article 28 the Victims’ Rights Directive and Article 22 the EPO Directive) but such data are 
not  specific on violence  against women and domestic violence. EIGE has worked for many 
years on the improvement of administrative data collection, including progress towards more 
comparability  of  data;  also  these  efforts  remain  dependent  on  the  political  will  at  national 
level and have not lead to the desired results. 

565 Supra, p. 6; Luxembourg Country Report.  

31 

 
 
 
 
 
 
 
 
 
                                                 
An  EU-wide  prevalence  survey  is  being  developed  and  rolled  out  by  Eurostat;  however, 
participation  by  Member  States  is  voluntary  and  only  18  Member  States  participate  despite 
financial support by the European Commission.   

The  supporting  study566  highlighted  awareness  among  Member  States  on  the  need  for  data 
collection and comparison at the EU level on violence against women (AT, BE, CY, DK, EL, 
IE, IT, LU). For example, in Denmark this was seen as being useful to better target prevention 
measures,  develop  new  and  innovate  concepts  for  training,  and  concepts  to  support  women 
victims  of  violence  or  domestic  violence.  In  some  Member  States,  it  was  seen  as  useful  to 
particularly collect information on vulnerable groups. Reports also highlighted the need for – 
and current  lack of  –  strong data collection to  support measures to  address  violence against 
women  and  domestic  violence567  and  recommend  further  guidance  on  data  that  Member 
States should collect568 and promoting high quality survey and administrative data569.  

c.  Compliance with international standards 

EU  law  can  generally  be  considered  not  to  be  in  line  with  the  obligations  set  out  in  the 
Istanbul  Convention.  In  particular,  the  lack  of  coordination  mechanisms  is  not  in  line  with 
Article 10 of the Convention.  The lack of consultation of organisations working with women 
with disabilities is not in line with Article 4(3) UNCRPD. As to data collection, Article 11 of 
the Istanbul Convention requires State Parties to take action in order to collect disaggregated 
statistical  data  on  all  forms  of  violence  against  women  and  domestic  violence.  The  EU 
framework requires some data collection that is relevant to VAW/DV from Equality Bodies 
(Gender Equality Directives) but such data is limited to sex-based and sexual  harassment. It 
also  entails  obligations on data collection on victims’ rights  (Article 28 the Victims’ Rights 
Directive  and  Article  22  the  EPO  Directive).  However,  there  is  not  an  obligation  on  the 
Member States to collect data specifically on violence against women and domestic violence.  

d.  Conclusions 

There  is  no  requirement  in  EU  law  to  consult  civil  society  during  the  development  and 
evaluation  of  national  policies  and  coordinated  action  is  not  required  among  all  actors 
involved  although  both  of  those  measures  would  enhance  the  effectiveness  of  all  measures 
targeting violence against women and domestic violence. 

566 Study conducted in support of the impact assessment report. ICF 2021 [upcoming]. 

567  European  Parliament,  Study  for  the  FEMM  Committee:  Tackling  violence  against  women  and  domestic 
violence in Europe – The added value of the Istanbul Convention and remaining challenges, 2020, available at: 
(https://www.europarl.europa.eu/RegData/etudes/STUD/2020/658648/IPOL_STU(2020)658648_EN.pdf); 
EAVA,  European  Added  Value  Assessment:  Combatting  violence  against  women,  2013,  available  at: 
(https://www.europarl.europa.eu/RegData/etudes/etudes/join/2013/504467/IPOL-
JOIN_ET(2013)504467_EN.pdf). 
568 EPRS, The Victims’ Rights Directive 2012/29/EU – European Implementation Assessment, 2017, available at: 
(https://www.europarl.europa.eu/RegData/etudes/STUD/2017/611022/EPRS_STU(2017)611022_EN.pdf).  
569 EPRS, Gender-based violence as a new area of crime listed in Article 83(1) TFEU  – European added value 
at: 
assessment, 
(https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662640/EPRS_STU(2021)662640_EN.pdf). 

available 

2021, 

32 

 
 
 
 
 
 
 
 
                                                 
 
There  is  no  requirement  in  EU  law  to  collect  disaggregated  data  specifically  on  violence 
against  women  and  domestic  violence,  efforts  remain  dependent  on  the  political  will  at 
national level and have not lead to the desired results. Stakeholders also emphasized the need 
for,  and  the  current  lack  of  strong  data  collection  to  support  measures  to  address  violence 
against women and domestic violence. 

EU  law  can  generally  be  considered  not  to  be  in  line  with  the  obligations  set  out  in  the 
Istanbul  Convention  as  a  result  of  the  obligation  on  the  Member  States  to  collect  data 
specifically on violence against women and domestic violence, and the lack of coordination 
mechanisms.  Similarly  to  the  latter,  the  lack  of  consultation  of  organisations  working  with 
women with disabilities is not in line with the UNCRPD.  

33 

 
 
 
 
 
 
6. Overview of existing provisions in EU law 

The  table  below  summarises  the  provisions  under  EU  law  which  concern  the  prevention, 
protection, access to justice, victim support, and coordination/data collection. 

Section II.  Gaps  and good practices on the  measures to tackle violence against women 
and domestic violence in the 27 EU Member States.  

34 

 
 
 
 
 
 
Member States’ measures 

Problem 
areas 

Subareas 

Gaps 

Best practices 

n
o
i
t
n
e
v
e
r
P

.
1

Awareness-
raising 
(including 
harassment 
work) 

at 

- Lack  of  awareness-raising  initiatives  to  tackle 
underlying  patriarchal  and  stereotypical  attitudes 
(BE, IT, NL, PT570) 
- Insufficient  teaching  material  on  issues  such  as 
equality between women and men, gender roles, etc. 
(FI, IT, MT, SE571) 
- Prevention strategies limited to DV (BG, HU572). 

Stakeholders’ view 
OPC:  lack  of  services  and  activities  to  empower 
survivors  and  encourage  them  to  break  the  silence 
(73%). 
NGO:  highlighted  the  need  to  further  address 
harmful  gender  stereotypes  as  one  of  the  main  root 
causes  of  gender-based  violence  and  the  education 
sector has a pivotal role in addressing them. 

[harassment] 
European Parliament: need to tackle sexual 
harassment and sexual abuse against women and 
girls through a Directive573.  

INGOs:  guidance,  resources,  training  and  other 
relevant  tools  in  accessible  format  for  employers’ 
and  workers’  organizations,  on  violence  and 

-  Awareness raising  
of VAWG and DV and training  
of professionals  
intensified  after  the  ratification  of  the  Istanbul 
Convention  (AT,  FI,  FR,  EL,  IT,  LU,  NL,  PT,  RO, 
ES, SE575). 

- Development of School education programmes on 
the topics of gender equality  
and VAWG after the ratification of the Istanbul 
Convention (DK,IT, NL, PT, RO)576 

- Development of early detection  
and intervention programmes (ES577). 

[harassment] 
- Awareness-raising campaigns on sexual harassment 
relayed by national media;   
face-to-face  counselling  and  a  national  telephone 
information  service.  This  include  specific    attention 
to  vulnerable  groups  of  workers, 
including 
immigrant workers; 
in  Labour  and 
The  Commission  for  Equality 
Employment disseminates information on redress for 
victims  of  gender  discrimination  in  the  workplace  
provides  legal  support  to  victims  and  receives 

570 GREVIO submission targeted consultation, para. 2.  
571 GREVIO submission targeted consultation, para. 3.  
572 BG and HU, Submission for the Member States Targeted Consultation. 
573 Resolution of 26 October 2017 on combating sexual harassment and abuse in the EU (2017/2897/(RSP)), OJ 
C  346,  27.09.2018,  p. 192.  See  in  its  preamble:  ‘D…  sexual  violence  and  harassment  are  contrary  to  the 
principle  of  gender  equality  and  equal  treatment  and  constitute  gender-based  discrimination’  and  ‘I…  the 
persistence of gender stereotypes, sexism, sexual harassment and abuse is a structural and widespread problem 
throughout  Europe  and  the  world  …  gender  stereotypes  and  sexism,  including  sexist  hate  speech,  offline  and 
online, are root causes of all forms of violence against women’. 
575 EWL, Towards a Europe Free From Male Violence Against Women and Girls  - Recommendations from the 
European Women’s Lobby to end violence against women and girls in Europe once and for all, 2020, available 
at: (https://womenlobby.org/IMG/pdf/ic-2.pdf). 
576 Supra Error! Bookmark not defined.. 
577 Supra Error! Bookmark not defined.. 

35 

 
 
 
                                                 
 
 
 
 
 
  
 
 
 
 
harassment,  including  domestic  violence,  to  be  able 
to support anyone seeking for information574.  

complaints on which it renders its legal opinion; 
Multi  stakeholder  initiative  which  resulted  in  the 
development  of  information  material  and  tools  to 
support self-regulation to prevent and combat sexual 
harassment in the workplace (PT578). 
To incentivise employers’ respect of gender equality, 
the National Commission on the Promotion of 
Equality (NCPE) awards companies an Equality 
Mark Certification when employers give priority to 
gender equality. One of the criteria on the basis of 
which the certification is granted is whether the 
company has put in place a sexual harassment policy 
(MT579). 

Training 
professionals 

of 

- Lack  of  initial  and  in-service  trainings  and  lack  of 
guidelines  based  on  a  gendered  understanding  of 
violence against women and domestic violence (AT, 
BE, DK, FI, FR, IT, MT, NL, PT, ES, SE580) 
- Lack  of  training  of  social  workers  and  relevant 
court appointed professionals (FR, IT, MT, PT581) 
- Need to expand training on different manifestations 
of  violence  against  women,  their  detection  and  root 
causes (AT, BE, FI, FR, IT, MT, PT582) 
- Insufficient  training  or  lack  of  sensitivity  of 
professionals involved in providing medical care and 
forensic examinations in the area of sexual violence 
(IT, MT, NL583) 

survey  highlighted 

Stakeholders’ view: 
FRA:  FRA’s  VAW 
the 
“considerable  potential  for  health  professionals  to 
identify  violence,  inform  the  police,  secure  forensic 
evidence  and  initiate  intervention  processes  that  set 
out  to  end  violence”.  FRA  recommended  Member 
States 
specific  guidelines  on  how 
professionals  working  in  healthcare  services  should 
respond to indications of partner violence584.” 

to  pass 

574 ILO submission on the targeted consultation. 
578 GREVIO submission targeted consultation, para 25. 
579 GREVIO submission targeted consultation, para 27. 
580 GREVIO submission targeted consultation, para 11, pp. 78-79. 
581 GREVIO submission targeted consultation, para 11, p. 79. 
582 GREVIO submission targeted consultation, para 11, p. 78. 
583 GREVIO submission targeted consultation, para 36. 
584 Supra 504, pp. 12 & 34. 

36 

 
 
 
                                                 
 
 
 
 
Work 
perpetrators 

with 

Protection  from 
repeat 
victimization 

n
o
i

t
c
e
t
o
r
P

.
2

for 

guidelines 

perpetrators 

- Consolidated 
programmes (IT591). 
- Prevention  of  violent  behaviour 
is  addressed 
through  education  programmes  and  support  groups 
for  men,  boys  and  young  men.  The  available 
education programmes, support groups and helplines 
promote  the  recognition  and  prevention  of  violent 
behaviours.  Moreover,  in  these  Member  States, 
voluntary  programmes  for  offenders  and  inmates 
offer  counselling,  psychological 
treatment  and 
support to change their behaviour.  (EE, DK, FI, DE, 
NL, SE592).  

- Programmes are not set up (HU585) 
- Insufficient  availability  or 
low  attendance  of 
programmes  for  perpetrators  of  DV  (DK,  IT,  PT, 
AT, FI, MT, NL586). 
- Referrals 
to  perpetrator  programmes  are  not 
integrated into the criminal justice system as a tool to 
reduce recidivism (FI, MT, NL587) 
- Perpetrator  programmes  are  ordered  to  replace 
prosecution, conviction or sentencing, contrary to the 
principle  of  victims’  access  to  fair  and  just  legal 
processes (AT, PT588). 
- Lack of gendered understanding of violence against 
women in the programmes (BE, NL589). 
- Perpetrator 
focus 
strongly/exclusively  on  medical 
treatment 
substance abuse or mental health issues (FR590). 

programmes 

too 
for 

Stakeholders’ view 
NGOs:    called for EU level minimum standards on 
prevention  and  protection  measures  including  on 
work with perpetrators 

- Repetition or regularity of violent acts in definition 
of domestic violence (HU, IE, IT, PT, SE593). 
- Lack of gendered understanding of violence against 
women (BE594) 
- Disempowering 
interventions, 

victimising 
to 

repeat 
asking 

and 
as 

victims 

such 

585 Hungary submission for the MS targeted consultation. 
586 GREVIO submission targeted consultation, para 22. 
587 GREVIO submission targeted consultation, para 23. 
588 GREVIO submission targeted consultation, para 23. 
589 GREVIO submission targeted consultation, para 12. 
590 GREVIO submission targeted consultation, para 24. 
591 GREVIO submission targeted consultation, para 20. 
592 EE, DK, FI, DE, NL, SE, Submission for the Member States Targeted Consultation. 
593 Supra 505, at. 2.3. 
594 GREVIO submission targeted consultation, para 31. 

37 

 
 
 
                                                 
 
 
 
 
accommodate  perpetrators’  behaviour,  change  their 
own behaviour, etc. (NL595). 

Stakeholders’ view 
FRA:  need  for  legislation  and  trainings  for  law 
enforcement  authorities 
improve  protection 
against repeat victimisation.  
training596. 

to 

- Lack  of  effective  and  immediate  protection  after 
reporting (AT, FE, DE, NL, PL,PT597)  

Stakeholders’ view 
NGOs:    lack  of  resources  for  issuing  emergency 
barring orders598 
FRA:  lack  of  immediate  action  by  law  enforcement 
authorities  waiting  for  the  prosecution  service  or  a 
court to seize the initiative 599. 

Protection 
orders, 
emergency 
barring orders 

child 

Special 
protection 
measures  in  the 
context 
of 
domestic 
violence  

- Lack of special rules for custody or visitation rights 
in cases of DV (CZ601) (FI602) (BE, IT603). 
- Lack  of  risk  assessment  for  children  experiencing 
domestic violence (IT, RO604 ). 

Stakeholders’ view 
European  Parliament:  When  examining  custody 
cases,  the  child  shall  also  be  provided  with  the 

- Introduction of emergency barring orders which 
allow law-enforcement agencies, for the first time in 
Poland, to temporarily evict a domestic abuser from 
the family residence. This measure is accompanied 
by extensive training initiatives throughout the 
country to implement a system of emergency and 
protection orders (PL)600. 

https://fra.europa.eu/sites/default/files/fra_uploads/fra-2019-justice-for-victims-of-violent-crime-part-4-

595 GREVIO submission targeted consultation, para 32. 
596 Supra 504, pp. 36-37. 
597 Supra 504, pp. 36-39. 
598 NGOs workshop  (see Annex 2). 
599 
women_en.pdf at 42. 
600 GREVIO, Baseline evaluation report: Poland, 2021, p. 75, available at: (https://rm.coe.int/grevio-baseline-
report-on-poland/1680a3d20b). 
601  Baker  McKenzie,  Fighting  Domestic  Violence:  Czech  Republic, 
available 
(https://resourcehub.bakermckenzie.com/en/resources/fighting-domestic-violence/europe/czech-republic).  
602  GREVIO,  Baseline  Evaluation  Report:  Finland,  2019,  pp.  40-41,  available  at:  (https://rm.coe.int/grevio-
report-on-finland/168097129d). 
603 Supra 430, pp. 112-113.  
604 The European Court of Human Rights (Fourth Section), case of O.C.I. and Others v. Romania. 

2021, 

at: 

38 

 
 
 
                                                 
 
 
 
 
 
opportunity to be heard and, in cases where intimate 
partner  violence  is  suspected,  hearings  must  be 
conducted in a child-friendly environment by trained 
professionals.  Children  who  have  witnessed 
domestic violence should be recognised as victims of 
gender-based  violence  and  receive  better 
legal 
protection and psychological support605. 

Risk  assessment 
and 
management 

- Individual assessments are absent in seven Member 
States (CZ, BE, EE, LU, RO, SI and SK606).     
- Lack  of  standardized  and  systematized  procedures 
(IT, MT607). 

Stakeholders’ view 
Social  partners:  highlighted  (with  regards  to  sex-
based and sexual harassment at work) that very  few 
risk  assessments  are  carried  out  and  when  they  are, 
they do not include psychosocial risks608. 

Criminalisation 

e
c
i
t
s
u
j

o
t

s
s
e
c
c
A

.
3

factors 

intimate/private/sexual 

- Lack  of 
criminalization  of  non-consensual 
images 
dissemination  of 
(online) (AT, BG, HR, CY, CZ, DK, EE, FI, DE, EL, 
HU, LV, LT, LU, RO, SK, SL610). 
- Aggravating 
sexual  harassment 
committed  online  (AT,  BE,  BG,  HR,  CY,  CZ,  DK, 
EE,  FI,  DE,  HU,  IE,  IT,LU,  LV,  LT,  MT,  NL,  PL, 
PT, RO, SK, SL, ES, SE611) 
- Consent  requirement  in  criminalization  of  rape 
(AT, BG, CZ, EE, FI, FR, EL, HU, IT, LV, LT, NL, 
PL, PT, RO, SK, SL, ES612). 

for 

- Risk assessment is mandatory in cases of domestic 
violence,  and  it  is  based  on  standardised  forms.  
After the risk assessment is completed, a safety plan 
is  developed  for  the  victim,  an  application  for 
protective  measures  is  made,  and  the  seizure  of 
weapons is also provided for (PT)609. 

- Non gender-neutral definition of rape (SK613) 

Right 
Information 

to 

- Not  all  relevant  stakeholders  pro-actively  and 
systematically  provide  information  on  services  and 
measures available (IT, MT614) 

- Development  of  examples  of  active  outreach  to 
inform  victims  on  their  rights  and  the  services 
available (e.g. “Come to Us” campaign, online portal 

605 European Parliament, Draft Report on the impact of intimate partner violence and custody rights on women 
and children, 2019/2166(INI), 2021, available at: 
(https://oeil.secure.europarl.europa.eu/oeil/popups/ficheprocedure.do?lang=en&reference=2019/2166(INI)).  
606 Supra, p. 154. 
607 GREVIO submission targeted consultation, para. 71-72. 
608 Social partners’ workshop (Annex 2). 
609 GREVIO, Baseline Evaluation Report: Portugal, 2018, para. 201, available at: (https://rm.coe.int/grevio-
reprt-on-portugal/168091f16f). 
610 Supra 505, Chapter 8. 
611 Supra 505, at 4.3. 
612 Supra 505, at 3.2 b) i). 
613 Supra 505, at 3.2 b) i). 
614 GREVIO submission targeted consultation, para. 66. 

39 

 
 
 
                                                 
 
 
 
 
 
 
- Insufficient  information  on  forms  of  violence 
against  women  other  than  domestic  violence  (AT, 
BE, DK, FI, FR, IT, MT,NL, PL, PT,SI, ES615) 
- Lack  of  accessible  information  for  women  with 
disabilities  /  mothers  of  children  with  disabilities 
(BE, FR, IT, PT616). 

Stakeholders’ view 
FRA:    women  who  are  victims  of  partner  violence 
are significantly more dissatisfied than other victims 
of  violent  crime  with  their  limited  role  in  the 
proceedings  and  with  the  limited  information  about 
their potential role available to them617. 

- Lack  of  measures  protecting  victims  against 
retaliation  and  repeat  victimization  (AT,  FR,  DE, 
NL, PL, PT619)  
- A lack of reporting was highlighted by six Member 
State  authorities  in  the  targeted  consultation  as  one 
of the main challenges in the prosecution of cases of 
GBV (BE, BG, CY, DE, IE, RO620).   
- Barriers  for  migrant  and  asylum  seeking  women’s 
ability to report violence to the police (MT, NL, ES, 
SE621).  

Stakeholders’ view 
INGOs:  highlighted  the  need  for  clear  and  easy  to 
access  reporting  mechanisms  including  anonymous 
reporting. 

time 

for  state 
limits 
-  Restrictive 
compensation  (AT,  CY,  HR,  HU623)  and  for 
perpetrator’s and state compensation (EL624). 

to  apply 

www.youmo.se) (SE618). 

- Legislative amendments to allow professionals who 
had previously been bound by confidentiality rules to 
notify statutory agencies where they suspect a risk to 
the  life  of  a  woman  or  child  in  the  context  of 
domestic violence (FI622). 

- Criminal  sanctions  as  pressure  on  the  offender  to 
make  payments  to  the  victim  -compensation  in  lieu 
of punishment- (DE627). 

Violence 
reporting  

Victim 
compensation 

- In  cases of sexual violence  the seriousness of the 
consequences for the victims of the crime committed 
is  not  taken  into  account    and  the    fixed  rate 
compensation  does  not  represent  an  appropriate 
contribution  to  the  reparation  of  the  harm  suffered 
(IT625). 

615 GREVIO submission targeted consultation, para. 67. 
616 GREVIO submission targeted consultation, para. 76. 
617 Supra 504, p. 73. 
618 GREVIO submission targeted consultation, para. 64. 
619 Supra 504, pp. 34-35. 
620 Submission for the MS targeted consultation question n. 43. 
621 GREVIO submission targeted consultation, para. 75. 
622 Supra Error! Bookmark not defined., p. 37.  
623 Supra 528, p. 23. 
624  Baker  McKenzie,  Fighting  Domestic  Violence:  Greece,  2021, 
(https://resourcehub.bakermckenzie.com/en/resources/fighting-domestic-violence/europe/greece). 
625 CJEU, Case C-129/19 (Presidenza del Consiglio dei Ministri v. BV), ECLI:EU:C:2021:140, 25 February 
2021. 
627 Supra 528, p. 24. 

at  4.2.4., 

available 

at: 

40 

 
 
 
                                                 
 
 
 
Role of Equality 
Bodies 

Effective 
remedies 
in 
cases of gender-
work 
based 
harassment 

General support 

m

i
t
c
i
V

t
r
o
p
p
u
s

.
4

Stakeholders’ view 
OPC:    49%  of  the  respondents  do  not  believe  that 
information on how victims can obtain compensation 
(from  the  offender  and/or  the  state)  is  available  in 
their Member State.626 

- National  equality  bodies  cannot  receive  claims  of 
sexual harassment (AT, CZ, FI, IT, LT, LU, ES628). 
- National  Equality  Bodies  can  deal  with  claims  on 
cases  of  sexual  harassment  but  not  with  claims  on 
other forms of VAW/DV(BG, HR, CY, CZ, DK, FI, 
FR, EL, HU, IE, IT, LT, LV, LU, MT, NL, PL, RO, 
SK, ES629) 

-  Collective  redress  in  cases  of  gender-based  work 
harassment  is  not  widely  available  in  all  Member 
States.  Only  in  four  Member  States  equality  bodies 
can act on behalf of a group of victims of VAW/DV 
in  legal  proceedings  (BE,  LV,  PT,  EE)  and  in  five 
equality  bodies  assist  a  group  of  victims  of 
VAW/DV  in  legal  proceedings  (EE,  LV,  LT,  SK, 
BE630).   

- French  Law  No.  2018  771  of  5  September  2018 
also  provides  for  a  series  of  measures,  such  as  the 
establishment  in  any  company  employing  at  least 
250 employees of an adviser responsible for guiding, 
informing  and  assisting  employees  in  the  fight 
against  sexual  harassment  and  sexist  behaviour, 
aimed  at  providing  victims  with  better  access  to 
information on possible remedies (FR631).  

trainings  of 

-  Difficult access (in practice) to public housing and 
financial assistance (BE, FI, FR, IT, MT, NL632). 
- Lack  of 
relevant  professionals 
operating  in  general  support  services  (BE,  FI,  IT, 
ES633). 
- Significant  barriers  for 
  migrant  and  asylum 
seeking  women  to  access  general  and/or  specialised 
support services (BE, DK,IT, NL,ES, SE634)  

- Guidelines have been developed for social workers 
on how to assist victims of domestic violence. For a 
woman  seeking  refuge  at  a  shelter,  the  municipality 
is  obliged 
initial  and  coordinated 
counselling to identify their needs and offer solutions 
(DK638). 

to  provide 

626 Open public consultation q.20. 
628 Supra 505, at 11.3 b). 
629 Supra 505, at Table 30. 
630 Submission for the MS targeted consultation question n. 39. 
631 GREVIO submission targeted consultation, para. 26. 
632 Supra 430, p. 87.  
633  GREVIO,  Baseline  evaluation  report:  Belgium,  2020,  para.  119,  available  at:  (https://rm.coe.int/grevio-report-on-
belgium/16809f9a2c);  Supra  Error!  Bookmark  not  defined.,  paras.105-106;  Infra  Error!  Bookmark  not  defined.,  para. 
141; Infra Error! Bookmark not defined., para. 152. 
634 GREVIO submission targeted consultation, para. 75. 
638 GREVIO, Baseline evaluation report: Denmark, 2017, p. 32, available at: (https://rm.coe.int/grevio-first-
baseline-report-on-denmark/16807688ae). 

41 

 
 
 
                                                 
 
 
 
 
 
 
 
 
to 

improve 

the  support 

Stakeholders’ view 
OPC:    As  to  whether  further  measures  should  be 
taken 
to  victims  of 
VAW/DV,  the  majority  (77%)  believe  they  should, 
at national and EU level635. 
FRA:  rarely  law  enforcement  authorities  refers 
victims to a support organisation636. 
  protection  and  support  services  are 
INGOs: 
negatively affected by inadequate infrastructure, long 
waiting  periods,  insufficient  funding  or  limited 
of 
geographical 
specialized/trained personnel637. 

coverage, 

lack 

and 

Specialized 
support 
(including 
shelters 
helplines)  

and 

-  Insufficient  rape  crisis  centres  and/or  sexual 
violence  referral  centres  to  ensure  proper  coverage 
and  easy  access  by  victims  of  sexual  violence  (AT, 
BE, FR, IT, NL, PT, ES, SE639). 
- Low number of specialised support services dealing 
with forms of violence other than domestic violence  
such  as  sexual  violence,  FGM,  forced  marriage, 
forced abortion and sterilisation or sexual harassment 
(AT,BE,FR,MT,PT, ES640)  
- Inadequate number and/or distribution of specialist 
services for domestic violence (BE, DK, FI, FR, DK, 
IT, MT, DK, SE641) 
- Shortcomings in the provision of specialist support 
services catered to the needs of specific 
groups of victims (AT, BE, IT, PT, SE642)  
- Lack of national state-wide helplines (BE, HR, CZ, 
LV, LT, MT, NL, PL, PT643)  
- Lack of national state-wide 24/7 and free of charge 
helplines (BE, BG, HR, CY, CZ, FI, FR, EL, HU, IE, 
LV, LT, LU, MT, NL, PL, PT, SL644) 
- Lack  of  multilingual  support  on  national  women’s 
helplines  (BE,  HR,  CZ,  HU,  LV,  LT,  MT,  NL,  PL, 
PT, SL645). 

Stakeholders’ view 
NGOs:    lack  of  availability  (including  geographical 

centres 

specialised 

-  Protection 
in  dealing 
exclusively with cases of domestic violence. Some of 
these  organisations  have  a  decentralised  structure 
allowing  them  to  better  cover  rural  areas.  The  core 
staff members are paid professionals (AT648). 

635 Open Public Consultation (see annex 2). 
636 Supra 504, p. 13. 
637 Submission for the INGO targeted consultation: United Nations – Joint Paper-Consultation on Preventing and 
combatting gender-based violence against women and domestic violence. 
639 GREVIO submission targeted consultation, para. 59. 
640 Supra 430, p. 90. 
641 Supra 430, p. 91. 
642 Supra 430, p. 91. 
643 WAVE, WAVE Report 2015 on the role of specialist women’s support services in Europe, 2015, p. 90. 
644 Supra Error! Bookmark not defined., p. 90. 
645 Supra Error! Bookmark not defined., p. 90. 
648 Supra 504, p. 56. 

42 

 
 
 
                                                 
 
 
 
Specialized 
support 
children 

for 

Specialized 
support 
vulnerable 
groups 

for 

distributions)  lack  of  funding  for  victim  support 
services646.  
INGOs:  identified  as  the  main  gaps  in  the  lack  of 
gendered understanding of violence by professionals 
and the insufficient availability of shelters647. 

the  professionals 
Lack  of  awareness  among 
concerned 
legal  and  health 
  (social  workers, 
professionals,  and  psychologists)  of  the  harmful 
effects  of  witnessing  domestic  violence  on  children 
and 
to 
to  provide  access  for  child  witnesses 
appropriate, age specific support services based on a 
gendered  understanding  of  violence  against  women 
and pay  due  regard  to  the  best interests  of  the  child 
(FR, IT649). 

Stakeholders’ view: 
INGOs:  highlighted  the  need  for  Member  States  to 
invest  more  in  services  and  support  for  child 
witnesses  of  violence  against  women  and  domestic 
violence650. 

- Limited support available for migrant and asylum 
seeking women to report violence or access services 
(BE, DK, IT, MT, NL, ES, SE651) 
- Inaccessibility of police premises for women with 
disabilities / mothers of children with disabilities 
(BE, FR, IT, PT652). 
Stakeholders’ view 
NGOs: lack of accessibility of services (including 
shelters) for women and girls with disabilities 
victims of gender-based violence653 . 

The General Secretariat for Gender Equality (GSGE, 
Ministry of Interior) developed the ‘Protocol of 
Cooperation’ in 2017 to provide protection and 
support for refugee women at risk of gender-based 
violence. It constitutes an innovative, coordinated, 
and gender-sensitive network of services for 
vulnerable refugee women, who are victims of 
gender-based violence  and their children. It utilises 
existing resources and services to help staff in public 
administration, municipalities, and NGOs to 
cooperate and find common solutions. The Protocol 
coordinates services provided through the ‘National 
Network of Structures for Preventing and Combating 
Violence against Women’, comprising 40 
Counselling Centres, 21 Shelters and a 24-hour SOS 

646  NGOs workshop  (see annex 2). 
647 INGO workshop (see annex 2). 
649 GREVIO submission targeted consultation, para. 43. 
650  
651 GREVIO submission targeted consultation, para. 75. 
652 GREVIO submission targeted consultation, para. 76. 
653 EDF, Position Paper on Violence against women and girls with disabilities in the European Union, 2021, pp. 
12-13,  available  at:  (https://www.edf-feph.org/publications/edf-position-paper-on-violence-against-women-and-
girls-with-disabilities-in-the-european-union/). 

43 

 
 
 
                                                 
 
 
 
 
Support 
victims  at 
workplace 

for 
the 

- Limited availability of special leaves for victims of 
sex-based harassment, sexual harassment and 
domestic violence (AT, BE, BG, HR, CY, CZ, DK, 
EE, FI, FR, DE, GR, HU, IR, LV, LT, LU, MT, NL, 
PL, PT, RO, SK,SI, , ES, SE655). 

Specific 
measures 
for 
cases  of  cyber 
violence  against 
women 

Data collection 

- Lack  of  measures  tackling  specifically  Cyber 
harassment  (AT,  BE,  BG,  HR,  CY,  CZ,  DK,  EE, 
FI,DE,GR,  HU,  IR,  IT,  LV,  LT,  MT,  NL,  PL,  PT, 
RO, SK, SL, ES, SE658). 

Stakeholders’ view 
Social  partners:  noted  that  online  harassment  is 
increasing,  also  in  work  contexts,  and  taking  new 
forms.  Certain  professions  are  more  at  risk,  such  as 
female journalists. It was considered that more action 
is  needed  including  training  and  encouragement  to 
report  cyber  violence,  user  friendly  tools  to  report 
and 
flag  online  content,  a  national  media 
regulatory659. 

-The criminal justice system does not collect sex 
disaggregated data on victims/perpetrators of 
violence against women (BE, DK, MT, NL660) 

- Lack of harmonisation of data from one public 
body to another across the criminal justice sector 
(AT, BE, DK, FI, FR, IT, MT, SE661). 

Stakeholders’ view 

n
o
i
t
a
n
i
d
r
o
o
C

.
5

helpline (GR654).   

- Victims of VAW have the right to abstain from 
work as long as protection by employer is not 
ensured (FR656). 
- Victims of VaW  are entitled to special paid leave, 
allowing them to reduce their working schedule 
while retaining their full pay and pension benefits 
(IT657) 

from 

law-enforcement  bodies  and 

- Data 
the 
judiciary  must  be  collated  to  reconstruct  the  entire 
criminal  proceedings  chain,  from  the  filing  of  the 
complaint  to  the  delivery  of  the  judgment.  A 
standard  form  is  used  to  record  domestic  violence 
(PT663). 
- The  Ministry  of  Interior  compiles  and  publishes 
monthly  data  on  the  number  of  cases  of  intimate 
partner  violence  against  women  entered  by  law-
enforcement  agencies  and  other  public  institutions 

654 European Commission, MLP in gender equality seminar - Support services for victims of violence in asylum 
and migration, 2018, available at: (https://ec.europa.eu/info/publications/mlp-gender-equality-seminar-support-
services-victims-violence-asylum-and-migration-february-2018-greece_en). 
655 (https://www.oireachtas.ie/en/debates/debate/dail/2020-12-08/33/), last visited (10/11/2021). 
656  ETUC,  Safe  at  home,  safe  at  work:  Trade  union  strategies  to  prevent,  manage  and  eliminate  work-place 
harassment and violence against women, 2017, at 49. 
657 GREVIO, Baseline Evaluation Report: Italy, 2019, p. 48, available at: (https://rm.coe.int/grevio-report-italy-
first-baseline-evaluation/168099724e). 
658 Supra 505, at.4.4. 
659 Social partners workshop (see annex 2). 
660 Supra 430, pp. 42-46. 
661 Supra 430, p. 46. 
663 Supra Error! Bookmark not defined., para. 60. 

44 

 
 
 
                                                 
 
 
 
 
 
 
NGOs: lack of comparable and comprehensive 
disaggregated data to understand the scale of the 
problem and better identify victims662. 

into  the  Integrated  Monitoring  System  for  cases  of 
Gender  Violence  (VioGen).  These  cases  are  then 
classified  by  the  level  of  risk  assessed  by  Spanish 
standardised  risk-assessment 
tools  (Police  Risk 
Assessment  (VPR)  and  Police  Assessment  of  Risk 
Evolution 
by 
and 
geographical location (ES664). 

disaggregated 

(VPER)) 

Multi-agency 
cooperation  (at 
national level) 

- Cooperation  limited  to  DV  /or  intimate  partner 
violence (FI, MT,ES665) 
-  Lack  of  effective  co-operation  and  multiagency 
approach to the protection and support of victims in 
the area of domestic violence (IT, DK, PT, SE666). 
Stakeholders’ view 
NGOs:    highlighted  the  need  for  comprehensive 
long-term 
and 
and  multiagency 
cooperation for the protection of victims667. 

coordination 

- Support  and  protection  measures  for  victims  of 
intimate  partner  violence  to  be  offered  in  an 
integrated  manner  and  on  the  basis  of  multi-agency 
law-enforcement  agencies, 
co-operation  among 
specialist  courts  on  violence  against  women,  health 
services and any entities providing legal counselling 
to  women. 
requires 
specialist  knowledge  and  effective  service  delivery, 
for  example  by  offering  these  services  in  the  same 
facility  (“one-stop  shop”)  and  includes  longer-term 
economic empowerment measures (ES668). 

  Legislation  specifically 

662  
664 GREVIO, Baseline Evaluation Report: Spain, 2020, para. 58, available at: (https://rm.coe.int/grevio-s-report-
on-spain/1680a08a9f). 
665 GREVIO submission targeted consultation, para. 50. 
666 GREVIO submission targeted consultation, para. 51. 
667  
668 GREVIO submission targeted consultation, para. 49. 

45