COMMISSION STAFF WORKING DOCUMENT EVALUATION EFSI 2.0 ex-post evaluation
Date: 2022-12-20
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: EU growth strategy, European Fund for Strategic Investments, economic growth, financing, investment, small and medium-sized enterprises

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.12.2022  SWD(2022) 443 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  EFSI 2.0 ex-post evaluation {SWD(2022) 444 final}  
 
 
Table of Contents 

1. 

INTRODUCTION ....................................................................................................... 3 

1.1  Purpose and scope of the evaluation ....................................................................... 3 

1.2  Methodology applied .............................................................................................. 4 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ............. 5 

2.1  Description of the intervention and its objectives .................................................. 5 

2.2  Point(s) of comparison .......................................................................................... 12 

3.  HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 

PERIOD? ................................................................................................................... 12 

3.1  Evolution of the situation...................................................................................... 12 

3.2  Current state of play.............................................................................................. 15 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ............................................. 17 

  The European Fund for Strategic Investments (including the EU guarantee) ...... 17 

 To what extent was the intervention successful and why? .............................. 17 

 How did the EU intervention make a difference? ............................................ 32 

 Is the intervention still relevant? ...................................................................... 34 

  The European Investment Advisory Hub ............................................................. 35 

 To what extent was the intervention successful and why? .............................. 35 

 How did the EU intervention make a difference? ............................................ 41 

 Is the intervention still relevant? ...................................................................... 41 

  The European Investment Project Portal .............................................................. 42 

 To what extent was the intervention successful and why? .............................. 43 

 How did the EU intervention make a difference? ............................................ 45 

 Is the intervention still relevant? ...................................................................... 45 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED ......................... 46 

  Conclusions .......................................................................................................... 46 

 The European Fund for Strategic Investments and the EU guarantee ............. 46 

 The European Investment Advisory Hub ........................................................ 48 

 The European Investment Project Portal ......................................................... 50 

  Lessons learned ..................................................................................................... 51 

ANNEX I.   PROCEDURAL INFORMATION ............................................................... 54 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ....................... 57 

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ANNEX  III.  EVALUATION  MATRIX  AND  DETAILS  ON  ANSWERS  TO 

THE EVALUATION QUESTIONS (BY CRITERION) ......................................... 72 

ANNEX IV. ASSESSMENT OF THE EU GUARANTEE .............................................. 89 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  ................ 98 

ANNEX VI. COMPARATIVE FEATURES OF EFSI SUPPORTED FIRMS ............. 134 

ANNEX VII. GLOSSARY ............................................................................................. 140 

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1. 

INTRODUCTION 

1.1 Purpose and scope of the evaluation 

According  to  the  amended  EFSI  Regulation  (Regulation  (EU)  2017/2396,  or  ‘EFSI  2.0 
Regulation’), the Commission has to submit to the European Parliament and the Council 
a report containing an independent evaluation of the application of the Regulation at the 
end of the investment period (i.e., end-2022). It includes the functioning of the European 
Fund  for  Strategic  Investments  (EFSI),  the  use  of  the  EU  guarantee,  the  activity  of  the 
European  Investment  Advisory  Hub  (EIAH)  as  well  as  of  the  European  Investment 
Project Portal (EIPP). 

The  evaluation  has  been  performed  against  the  criteria  of  relevance,  effectiveness, 
efficiency,  EU  added  value  and  coherence.  Moreover,  the  evaluation  also  assesses  the 
additionality of EFSI, as defined in the EFSI 2.0 Regulation. The assessment will cover 
both the Infrastructure and Innovation and the SME Windows (‘IIW’ and ‘SMEW’). 

The evaluation focuses on the following elements: 

  An assessment of the functioning of the EFSI, the use of the EU  guarantee and 

the functioning of the EIAH and of the EIPP; 

  An  assessment  of  whether  the  EFSI  consists  of  a  good  use  of  resources  of  the 
general  budget  of  the  Union,  mobilises  a  sufficient  level  of  private  capital,  and 
crowds-in private investment; 

  An  assessment  of  whether  maintaining  a  scheme  for  supporting  investment  is 

useful from a macroeconomic point of view; 

  An assessment of the application of the specific procedures put in place to support 

EFSI (as referred in Article 4(2)(a)(v) of the EFSI 2.0 Regulation);1 and 

  An  evaluation  concerning  the  use  of  the  scoreboard  of  indicators  used  by  the 
Investment  Committee  to  ensure  an  independent  and  transparent  assessment  of 
the potential and actual use of the EU guarantee, in particular with regard to the 
consideration of the appropriateness of each pillar and their respective roles in the 
assessment. 

The  geographic  coverage  of  the  evaluation  includes  the  27  EU  Member  States  and  the 
United  Kingdom.  It  also  includes  cross-border  projects  extended  to  one  or  more  third 
countries falling within the scope of the European Neighbourhood Policy. 

1 This article allowed the EIB Group to reduce the financing cost (by modulating the remuneration of the 
EU guarantee) to certain types of viable projects such as those under stressed financial market conditions, 
or  where  investment  platforms  were  facilitated,  or  to  the  funding  of  projects  in  sectors  or  areas 
experiencing a significant  market failure or suboptimal investment situations. During the implementation 
of  the  EFSI,  the  need  to  activate  the  “clause”  did  not  materialise  and  therefore  the  EIB’s  Pricing  Policy 
continued to apply for the EFSI operations. 

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The conclusions and lessons learned of the evaluation will serve to assess the extent to 
which the EFSI, the EIAH, and the EIPP are achieving their objectives. The conclusions 
may  also  inform  future  European  Commission  (EC)  legislative  proposals  related  to 
investment support instruments. 

The  EFSI  and  the  EIAH  activities  started  in  2015,  whereas  the  EIPP  was  launched  in 
June  2016.  The  evaluation  has  taken  into  consideration  data  and  results  through  to  31 
December 2021. 

1.2 Methodology applied 

The evaluation is based – inter alia – on an independent study carried out by an external 
service  provider  (ICF  SA)  and  is  published  as  a  Staff  Working  Document  on  the 
European Commission website.2  

Primary  data  was  collected  from  a  sample  of  the  portfolio  of  the  EFSI  financing  and 
investment operations, the EIAH advisory assignments and the EIPP projects; secondary 
data was obtained from existing reports, studies, databases and relevant literature, as well 
as  from  consultation  activities  (i.e.,  open  consultation,  targeted  consultations,  and 
interviews).  The  analysis  of  this  information  was  conducted  using  quantitative  and 
qualitative  methodologies,  including  portfolio  analysis,  contribution  analysis,  survey 
analysis, cost-efficiency assessment, case studies, and an evaluation matrix. The overlaps 
between  these  data  collection  tools  and  methodologies  lend  some  robustness  to  the 
analysis,  allowing  for  horizontal  triangulations  (e.g.,  between  contribution  analysis  and 
interview  results)  and  vertical  validations  (e.g.,  between  portfolio  analysis  and  case 
studies’  “deep  dives”).  Yet,  some  limitations  exist.  Firstly,  the  broad  scope  of  the 
evaluation  relative to  the resources and time available, inevitably  constrained the depth 
and breadth of the research that could be undertaken. Secondly, the low response rate to 
the  Open  Public  Consultation  made  it  less  representative  for  the  evaluation  outcome. 
Thirdly,  the  difficulty  in  organising  large-scale  surveys  of  counterparts  and  final 
beneficiaries  (due  to  practical  challenges  relating  to  assembly  of  contact  details, 
obtaining  consent  and  survey  fatigue)  meant  that  the  targeted  consultations  had  to  be 
based on existing surveys. Finally, confidentiality considerations prevent from disclosing 
private information on financing characteristics and activities of identifiable entities and 
projects. 

2 The external evaluation report is also published on the same website. 

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2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1 Description of the intervention and its objectives 

Investment expenditure collapsed in Europe in the aftermath of the 2008 global financial 
crisis. In this context by 2013, total investment across the EU had fallen about 20% from 
its  peak  in  2008  (Figure  1).  In  the  most  crisis-hit  countries,  investment  had  fallen  by 
more  than  40%.  Moreover,  during  the  crisis,  the  decline  of  investment  in  Europe  was 
twice as much as the decline in the US and Japan.  

Figure 1: Investment levels in the EU 

Real gross fixed capital formation (GFCF), Baseline vs. historical norm, EU, in 2013 prices, EUR billion. 
Source: COM(2016) 359 final - Europe investing again. Taking stock of the Investment Plan for Europe 
and next steps. 

In addition, the economic weakness lingering from the financial and sovereign debt crises 
left scars in the financial markets, exacerbating the difficulty to access finance, especially 
for small and medium-sized enterprises (SMEs). Europe had plenty of investment needs 
and economically viable projects in search of funding. Yet, at the same time, there were 
significant  levels  of  savings  and  large  amounts  of  financial  liquidity  that  could  be 
mobilised. The challenge was to put savings and financial liquidity  to productive use in 
order to support sustainable jobs and growth in Europe.3  

To address this challenge, the European Commission, in a partnership with the European 
Investment  Bank  Group  (EIBG)4,  proposed  in  November  2014  the  Investment  Plan  for 

3 See An Investment Plan for Europe, Commission Communication, COM(2014) 903 final. 

4 European Investment Bank (EIB) and European Investment Fund (EIF). 

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Europe  (IPE)  also  known  as  the  Juncker  Plan.  The  overarching  goal  was  to  kick  start 
investment  in  Europe,  and  through  that  contribute  to  restoring  the  EU  competitiveness 
and  consequently  help  boost  growth  and  employment.  Indeed,  upon  request  from  the 
ECOFIN  Council,  a  Special  Task  Force  had  been  set  up  by  the  European  Commission 
and the European Investment Bank, in coordination with Member States, to address the 
above  issues.  They  called  for  financial  instruments  aimed  at  catalysing  private 
investments  in  projects/programmes  of  EU  significance,  tailored  to  Member  States’ 
needs, including also possible cooperation with National Promotional Banks and the EIB 
participation.5  Past  simulations  carried  out  through  the  RHOMOLO-EIB  model6 
projected  that,  both  in  the  short  and  in  the  long  run,  the  EFSI-financed  operations 
approved  through  the  end  of  2016  would  significantly  boost  EU  GDP  and  create 
employment, also via an increase in total factor productivity.7  

The Investment Plan for Europe consists of three pillars. The first pillar is the European 
Fund for Strategic Investments, initially aimed at mobilising at least EUR 315 billion of 
additional  investment  in  infrastructure,  innovation,  and  SME  financing  by  mid-2018. 
This was to be accomplished by endowing the EIB Group with an increased risk-bearing 
capacity  via  an  EU  budgetary  guarantee  of  EUR  16  billion  and  an  EIB  Group’s 
contribution of EUR 5 billion.  

The  second  pillar  of  the  Investment  Plan  for  Europe  helps  to  ensure  that  investment 
finance  reaches  the  real  economy  by  developing  and  promoting  a  robust  pipeline  of 
investment projects. It consists of the European Investment Advisory Hub that provides 
technical and financial advisory services to private and public project promoters, as well 
as of the European Investment Project Portal, that is an online platform connecting EU-
based project promoters and investors from the EU and beyond. 

In September 2016, the Commission proposed to strengthen the initiatives under the first 
and  the  second  pillar  and  an  amendment  to  the  EFSI  Regulation  was  adopted  in 
December 2017 (Regulation (EU) 2017/2396 – the “EFSI 2.0 Regulation”). The EFSI 2.0 
Regulation  extended  the  EFSI  duration,  enhanced  its  additionality,  and  increased  its 
financial  capacity  from  EUR  21  to  33.5  billion  to  mobilise  EUR  500  billion  of 

5 See the Final Report of the Special Task Force (Member States, Commission, EIB) on Investment in the 
EU (https://www.eib.org/attachments/efsi_special_task_force_report_on_investment_in_the_eu_en.pdf). 

6 This model, originally developed in collaboration with DG REGIO, provides information on the 276 EU 
regions'  economies,  disaggregated  into  several  economic  sectors.  It  also  simulates  spatial  interactions 
between  regional  economies,  captured  by  trade  matrices  for  goods  and  services,  income  flows,  factor 
mobility  and  knowledge  spill-overs.  The  model  provides  support  to  EU  policy  makers  showing  the 
macroeconomic  effects  of  a  wide  range  of  investments  and  policies  (e.g.,  human  capital,  research, 
development  and  innovation)  at  regional  and  sectorial  level,  on  variables  such  as  GDP,  income, 
consumption, investments and savings. 

7  See  RHOMOLO  Press  Brief  2017  (https://www.eib.org/attachments/press/media-days-sept-2017-pack-
rhomolo-press-brief.pdf) for simulation details and precise figures. 

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investment  through  end-2020.  Moreover,  the  EFSI  2.0  included  also  enhancements  for 
the  EIAH  which  was  provided  a  more  specific  mandate  to  support  the  EFSI  pipeline 
development and to contribute to its sectoral and geographical diversification.  

The EFSI financial structure both before and after EFSI 2.0 is described below: 

EFSI: doing more with less 

At the core of EFSI is the principle of “doing more with less”. EFSI was conceived at a time when 
public  finances  were  highly  constrained  and  the  EU  Multi-annual  Financial  Framework  (MFF)  had 
already  been  earmarked  for  a  seven-year  period  (2014-2020).  In  this  context,  the  Commission  had 
limited budgetary resources to work with. A new type of instrument – based on guarantees - was thus 
created. As a budgetary guarantee, EFSI was different from a classical EU financial instrument. In the 
case  of  the  latter,  all  potential  financial  liabilities  are  fully  provisioned  (i.e.,  the  amount  of  the  EU 
guarantee cannot exceed the amount of budget available for the financial instrument); whereas in the 
case  of  a  budgetary  guarantee,  the  EU  only  covers  a  portion  of  the  financial  liability  (actual 
losses/called amounts) supported by provisions. An EU guarantee thus creates an unfunded financial 
liability for the EU budget (i.e., a contingent liability) and in doing so, provides greater leverage to the 
EU budget as shown in the diagram below.  

Financial structure of EFSI and EFSI 2.0 

EFSI  was  furthermore  designed  as  an  irrevocable,  unconditional,  first  demand  guarantee  to allow  the 
EIB  Group  to  finance  higher  risk  projects  (loan  grading  of  D-  or  below)  and  provide  subordinate  or 
equity/  equity-type  financing  to  projects  and  companies  addressing  market  failures  or  sub-optimal 
investment situations, without jeopardising the Group entities' credit rating.  

The  third  pillar  aims  at  supporting  the  investment  eco-system  by  improving  the 
regulatory  environment  and  eliminating  barriers  to  investment.  The  activities  under  the 
third pillar  of the IPE  are not  subject  to the EFSI 2.0 Regulation,  are carried out  under 
other  legal  frameworks  and  will  not  be  part  of  the  scope  of  this  evaluation.

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Figure 2 illustrates the Theory of Change for the three components of the EFSI Regulation, underlying the intervention logic of the programme.  

Figure 2: Intervention logic 

Source: Wilkinson, C.

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Registration of projects and investors on PortalNumber and types  of new products developedImpactsIncreased levels of:}Innovation}Employment}Economic growth}Productivity}CompetitivenessEconomicSocietal}Lower carbon emissions}Improved societal wellbeingIntermediate OutcomesFinancing of new types of clients and projectsDirect ResultsOutputsActivitiesInputsEuropean CommissionEU  budgetary resourcesDevelopment of new higher risk productsDirect financing of (higher risk) projectsNumber of infrastructure projects financed e.g. transport, energy, digital, social housing etc.Number of PE/VC/debt funds supportedNumber of Financial intermediaries supportedNumber of R&D, and innovation projects financedDevelopment/ modernisation of infrastructureChange in FI lending to SMEs, mid-caps, social entities, micro borrowers Improved access to finance (debt & equity) for SMEs, mid-caps, social entities, micro borrowersSupported companies invest in projects/ meet their  working capital needsDevelopment/ demonstration/ commercialisation  of new products, processes and technologies Investment in start-ups or growing companiesProject-specific advisory supportEIPPImproved investibilityof supported projectsNumber of projects listed on the PortalNumber of advisory assignmentsIncreased visibility of available investment opportunitiesProjects secure financing from public and/ or private sectorRationale for interventionSizeable investment gap relative to historical average and policy objectives/ societal needsFinancing gaps resulting from:}Market failures e.g. information asymmetry (SME financing), externalities (R&D&I financing)}Market imperfections e.g. inability of private investors to accurately assess and price risk}Structural factors e.g. imperfect competition, under-developed capital markets, lack of non-bank alternatives to debt financing}Limited risk-bearing capacity of the private sector following the global financial crisis}Squeezed public financesRisk coverage by the EU Guarantee (EFSI)Capacity building supportEIAHEFSI backed financingEIB own resourcesTechnical expertiseInstitutional inputs e.g. policy steerTechnical expertiseInstitutional inputs e.g. AAA rating, due diligence etc.EIBGTechnical expertise e.g. Investment CommitteeIndependent expertsCreation of Investment PlatformsSupport (funding, risk sharing/ guarantees) to financial intermediaries/ fundsNumber of awareness raising and preparatory activitiesNumber of capacity building assignmentsNumber of investors registeredIncreased capacity of promoters to develop &  implement projectsIncreased capacity of public authorities to deploy financial instrumentsBetter heath, education outcomes, improved housing conditions etc.Improved infrastructure (clean transport, energy, digital, energy efficient buildings etc.)Development of innovative solutions to societal needsSystemic}Development of sustainable finance}Development of social investment markets}Diversification of sources of financeBigger and more diverse pool of investment projectsImproved efficiency of public spendingAssumptions underpinning Inputs>> Activities>> Outputs:}There exists a suitable pipeline of investment projects}The Investment Committee selects operations that address market failures or sub-optimal investment needs}EIBG would not normally be able to finance these projects in absence of the EU guarantee }EFSI products are relevant and appropriate to diverse and changing needs}Presence of suitable financial intermediaries across EU Member States  }EFSI is not crowding out private investors}EFSI products are not cannibilisingor overlapping with national promotional schemes}There is demand for the Hub’s services }Project promoters and investors are aware of the PortalExternal factors affecting inputs>>Activities>>Outputs}Nature and scale of societal challenges and policy response (e.g.Climate Change targets) >> investment needs}Macroeconomic and political conditions >> levels of public and private investment, risk perceptions of investors}Financial development of EU MSe.g.market structure, existence of fintechs, presence of suitable FIs >> availability of finance from private sources}Financial market regulation and conditions (e.g.Monetary policy, access to liquidity and capital constraints, regulatory framework for ABS, covered bonds, cyclical credit standards applied to SME and mid-cap lending) >> demand for InvestEU support}National SME and mid-cap financing schemes >> demand for InvestEU supportAssumptions underpinning Results>> Outcomes>> Impacts:}Supported operations would not go ahead in the same form and/or timetable without EFSI support}EFSI support makes projects attractive for private investors}There is demonstration effect of EFSI projects (i.e.demonstrating the viability of particular financialproducts or specific projects)}Projects supported by EFSI deliver the planned activities}EFSI support is not used to support zombie companies}The advice and support provided by the Hub is used by project promoters to improve the viability of their projects i.e.they make the necessary changes }The evidence and capacity building support provided by the Hub is used by public authorities  }There are good quality investment opportunities on the portal}The investors registered on the Portal are genuineExternal factors affecting achievement of Results>>Outcomes>>Impacts}Technological advances e.g.big data, robotics}Regulatory barriers to investment}Political and social factors e.g.impact of covid and government response}Macro-economic conditions}Societal shifts e.g.ageing populations, rising inequality, urbanisation}Changing expectations e.g.sustainable and responsible consumption 
 
 
Under certain assumptions (see box below), the logic of the intervention runs as follows: 
using financial, technical and institutional resources, the EFSI increases the risk-bearing 
capacity of the  EIB Group, allowing it to  engage in  new,  higher-risk  financing support 
for several sectors (e.g., transport, energy, and R&D) and groups (e.g., SMEs) which are 
ridden by market failures or suboptimal investment situations. Such financial products – 
either  directly  or  indirectly  through  financial  intermediaries  or  special  vehicles  –  fund 
additional investments by the beneficiary sectors or groups.  These investments, flanked 
by  the  EIAH  advisory  and  the  EIPP  investment  facilitation,  will  eventually  produce 
additional  goods  and  services,  generating  higher  economic  growth  and  employment  in 
the EU. 

There  are  a  number  of  assumptions  underpinning  the  theory  of  change  outlined  above. 
The  extent  to  which  (and  the  instances  and  circumstances  in  which)  these  assumptions 
hold  true  were  tested  as  part  of  the  evaluation.  These  assumptions  are  listed  in  the 
following  box  (NB:  The  assumptions  that  have  been  the  focus  of  the  evaluation  are 
highlighted in bold below). 

The theory of change has been tested in subsequent phases of the evaluation, in particular 
via a number of country case studies (i.e., France, Germany, Greece, Italy, and Latvia). 

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Assumptions  External Factors Assumptions underpinning   Inputs>> Activities>> Outputs Assumptions underpinning Results>> Outcomes>> Impacts Factors affecting the take-up of the EFSI financing and of the EIAH and the EIPP services Factors affecting the achievement of results, outcomes and impacts EFSI products are well designed i.e., relevant to diverse and changing financing needs and attractive to market There exists a suitable pipeline of investment projects that the market is not willing to finance on its own Demand for financing under EFSI is facilitated by EIAH and EIPP Presence of suitable financial intermediaries across EU Member States NPBs are willing to cooperate and collaborate with the EIB Group and the EC in the implementation of EFSI, EIAH and EIPP The Investment Committee selects operations that address demonstrable market gaps or suboptimal investment situations EIBG would not normally be able to finance these projects in absence of the EU guarantee  EFSI and its operations are not duplicating or crowding out market financing or other EU/national policies and programmes and are complementary with the latter There is demand for the EIAH services The advice and support provided by the EIAH are used by project promoters to improve the viability of their projects i.e. they make the necessary changes Supported operations would not go ahead in the same form and/or timetable without EFSI support EFSI support makes projects attractive for private investors There is demonstration effect of EFSI projects (i.e. demonstrating the viability of particular financial products or specific projects) Projects supported by EFSI deliver the planned activities EFSI support is not used to support zombie companies The advice and support provided by the EIAH is used by project promoters to improve the viability of their projects i.e. they make the necessary changes The evidence and capacity building support provided by the EIAH is used by public authorities There are good quality investment opportunities on the EIPP that are attractive for the types of investors registered/targeted The investors registered on the EIPP are genuine Investors registered on the EIPP actively engage with the portal (e.g. participate in events, make use of resources available etc.)  Nature and scale of societal challenges and policy response (e.g. Climate Change targets) → investment opportunities and needs Macroeconomic conditions and business cycle → investment opportunities and levels of investment undertaken Regulatory environment → levels of investment undertaken Financial development of EU Member States  e.g. market structure, existence of fintechs, presence of suitable financial intermediaries (FIs) → availability of finance  Financial market regulation and conditions (e.g. monetary policy, risk taking capacity of FIs - access to liquidity and capital constraints, regulatory framework for asset-backed securities (ABS), covered bonds, cyclical credit standards applied to SME and mid-cap lending) → demand for EIB Group products National financing schemes → demand for EIB Group products Availability of other similar initiatives --> reduce added value / distinctiveness of EIAH and EIPP offers  Wider economic context e.g. macroeconomic situation affecting demand and supply, business and consumer sentiment etc.  Policy commitment to tackling societal challenges such as climate change, affordable housing, clean transport, ageing populations, rising inequality, urbanisation etc. Technological advances e.g. big data, robotics Regulatory barriers to investment Political and social factors e.g. impact of Covid-19 and government response Changing expectations e.g. sustainable and responsible consumption  
 
 
SDG 7 (Affordable and 
Clean Energy) 

By providing financing 
support targeted to 
energy efficiency, with 
signed amounts for 
energy and environment 
and resource efficiency 
of approx. EUR 19 
billion as of end-2021, 
mobilising an estimated 
EUR 94.9 billion of 
investment for energy 
capacity building from 
renewable energy 
sources, improving 
energy efficiency and 
supporting electricity 
network projects. 

SDG 12 (Responsible 
Consumption and 
Production) 

By providing dedicated 
support to SMEs active 
in circular economy, 
those using recyclable 
materials, and those 
deploying energy 
efficiency measures. 

Contribution to Sustainable Development Goals 8 

SDG 1 (No Poverty)  SDG 3 (Good 

By providing 
financing support 
and advisory 
targeted to micro-
entrepreneurship 
and social 
entrepreneurship, 
e.g., for social 
housing projects. 

Health and Well-
being) 
By ensuring better 
healthcare through 
contribution to the 
rehabilitation and 
expansion of 
health facilities 
and the support 
given to medical 
research. 

SDG 4 (Quality 
Education) 

Through support for 
social 
entrepreneurship 
and social 
infrastructure, with 
approx. EUR 
439.92 million of 
signed amounts, as 
of end-2021, mainly 
dedicated to social 
infrastructure 
investment for the 
purposes of 
education. 

SDG 8 (Decent 
Work and Economic 
Growth) 

SDG 9 (Industry, 
Innovation and 
Infrastructure) 

SDG 10 (Reduced 
Inequalities) 

By ultimately 
pursuing economic 
growth and 
employment, 
through the 
provision, as of end-
2021, of guarantees 
worth EUR 2.7 
billion to financial 
intermediaries, 
unlocking EUR 14.7 
billion to finance 
businesses, 
including micro- 
and social 
enterprises as well 
as SMEs in the 
cultural and creative 
sectors; also, 
through the direct 
and indirect effects 
of IIW project 
financing. 

By improving the 
EU industrial 
fabric through 
financing support 
to firms, 
particularly SMEs 
and midcaps; by 
fostering research, 
development and 
innovation 
through 
participations in 
risk capital of 
start-ups and 
highly innovative 
firms; by 
providing direct 
and indirect loans 
for transport, 
social and digital 
infrastructure 
projects. 

By providing 
financing support 
and advisory 
targeted to social 
entities and to 
skills, education 
and training 
provision; by 
providing special 
guarantees to 
incentivise banks 
and other lenders to 
provide liquidity to 
European SMEs 
and small mid-cap 
companies hit by 
the economic 
impact of the 
coronavirus 
pandemic. 

SDG 6 (Clean 
Water and 
Sanitation) 
Through support 
to sustainable 
water 
management, 
wastewater 
treatment and 
sanitation, 
ensuring, as of 31 
December 2021, 
around EUR 2.6 
billion of total 
EFSI lending 
volume signed for 
projects related to 
water supply, 
sewerage and 
waste 
management. 
SDG 11 
(Sustainable 
Cities and 
Communities) 
By supporting 
dedicated 
investments in 
economic and 
social 
infrastructure 
projects 
promoting 
resilient and 
inclusive 
infrastructure, as 
well as inclusive 
and sustainable 
cities. For 
example, a better 
waste treatment 
was made 
available for 39.5 
million people 
through the EFSI 
supported 
investments. 

8 A detailed description of the EFSI contribution to the SDGs can be found in: Draft general budget of the 
European  Union  for  the  financial  year  2023,  Working  Document  Part  I:  Programme  Statements  of 
operational  expenditure,  COM(2022)  400  –  June  2022  (https://data.europa.eu/doi/10.2761/451669), 
Section 6.5. 

11 

 
 
 
                                                 
SDG 13 (Climate Action) 
By explicitly binding 40% of the projects 
supported under the Infrastructure and 
Innovation Window to climate action in 
line with the Paris Agreement. 

SDG 14 (Life Below Water) 
By providing support to activities related 
to the sustainable use of marine 
resources, aquaculture and other elements 
of the wider bio-economy. One example 
is the launch of the EUR 75 million 
BlueInvest Fund to support equity funds 
investing in innovative European small 
and medium-sized Blue Economy 
companies. 

SDG 15 (Life on Land) 
By supporting 
investments contributing 
to sustainable forest 
management. 

The  IPE  is  an  overarching  programme,  which  provides  financing  support,  advisory 
services and visibility to projects covering a wide range of sectors (R&D, transport, etc.) 
and  groups  (SMEs,  unemployed,  etc.).  As  such,  even  though  the  programme  was 
launched  before  their  publication,  it  contributes  to  several  of  the  17  UN  Sustainable 
Development Goals (SDG), and particularly to the goals presented in the box above (see 
also figure 2 above). 

In addition, the cross-cutting effects of the programme synergically impact several SDGs 
(e.g., SDG 1 and SDG 10, or SDG 1 and SDG 2-No Hunger). 

2.2 Point(s) of comparison  

Whenever  possible,  this  evaluation  assesses  the  results  against  various  points  of 
comparison.  This  is  naturally  done  in  the  assessment  of  effectiveness,  but  it  is  also 
present  in  the  assessment  of  EU  value  added  and  of  its  additionality.  The  points  of 
comparison used include: 

  Comparison  over  time  (“before-and-after  analysis”)  –  assessment  of  results  in 

comparison to an earlier period (e.g., evolution over time); 

  Comparison  across  space  –  assessment  of  results  in  comparison  to  similar 

situations in the same period (e.g., geographical distribution); and 

  Comparison  across  states  of  nature  (“counterfactual  analysis”)  –  Since  a  full-
fledged  micro-econometric  analysis  in  this  case  was  not  feasible,  a  comparison 
study  was  performed  based  on  a  comparative  perspective  (see  Annex  VI).  The 
results  of  a  model-based  macro-economic  simulation  through  the  RHOMOLO-
EIB model are also presented. 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1 Evolution of the situation 

Following the launch of the EFSI, the fading economic disruptions brought about by the 
financial and sovereign crises, together with the policy responses at both national and EU 
level,  contributed  to  a  gradual  catching  up  of  EU  investment  with  its  trend  and  to  a 
loosening  of  the  financial  constraints  plaguing  EU  SMEs  and  midcaps.  Since  2020, 
however,  the  economic  consequences  of  the  Covid-19  pandemic  reversed  many  of  the 

12 

 
 
 
economic gains of the previous years with a sharp contraction in economic activity and 
fall in investment levels. 

The European  Fund for Strategic Investments  was set  up in  2015, together with  the 
European  Investment  Advisory Hub  and the European  Investment  Project  Portal,  under 
Regulation  (EU)  2015/1017  of  the  European  Parliament  and  of  the  Council  of  25  June 
2015,  amending  Regulations  (EU)  No  1291/2013  and  (EU)  No  1316/20139  (the  EFSI 
Regulation),  with  the  aim  of  kick-starting  investments  in  the  Union  through  the 
mobilisation  of  private  (and  public)  finance.  The  agreement  on  the  management  of  the 
EFSI and on the granting of the EU Guarantee (the EFSI Agreement) was signed by the 
European Commission and the European Investment Bank Group on 22 July 2015. 

The EFSI Agreement was amended and restated several times: 

  The first amendment and restatement of the EFSI Agreement was signed on 21 
July  2016,  adding  two  further  products  under  the  SME  Window:  the  SMEW 
Equity Product and the EaSI10 Guarantee Enhancement; 

  The second amendment and restatement of the EFSI Agreement was signed on 
21  November  2017,  converting  the  three  guarantee  products  under  the  SMEW 
from a temporary enhancement (frontloading) to a permanent enhancement (top-
up) structure and adding a new SMEW product, the Cultural and Creative Sectors 
Guarantee Facility (CCS GF) Enhancement; 

In  2017,  to  accommodate  a  persistently  buoyant  demand  for  investment  financing,  the 
EFSI  Regulation  was  amended  by  Regulation  (EU)  2017/2396  of  the  European 
Parliament and Council of 13 December 2017 amending Regulations (EU) No 1316/2013 
and (EU) 2015/1017 as regards the extension of the duration of the EFSI as well as the 
introduction  of  technical  enhancements  for  the  EFSI  and  the  EIAH  (the  EFSI  2.0 
Regulation). The EFSI 2.0 Regulation increased, inter alia, the size of the EU Guarantee 
from EUR 16 to 26 billion and adjusted the provisioning target rate (from 50% to 35%) 
in  order  to  expand  the  programme’s  financing  capacity  and  better  reflect  the  estimated 
risk  profile  of  the  operations  deployed  under  the  EFSI.  In  addition,  it  enhanced  the 
scoreboard of indicators, a tool for the Investment Committee to ensure an independent 
and  transparent  assessment  of  the  potential  and  actual  use  of  the  EU  Guarantee  in  its 
investment decisions. 

  A third amendment and restatement of the EFSI Agreement was signed on 9 

March 2018 to reflect the EFSI 2.0 Regulation. 

  The fourth amendment and restatement of the EFSI Agreement was signed on 
20 December 2018 to increase the EFSI contribution to existing SMEW products 

9 OJ L 169, 1.7.2015, p. 1-38. 

10 EU Programme for Employment and Social Innovation. 

13 

 
 
                                                 
and  add  two  further  SMEW  products  (EFSI  Combinations  Product  and  EFSI 
Private Credit for SMEs Product); 

  The fifth amendment and restatement of the EFSI Agreement was signed on 27 
March 2020 to, inter alia, increase the EFSI contribution to the existing SMEW 
products  and  add  two  new  SMEW  products  (the  European  Scale-up  Action  for 
Risk Capital (ESCALAR) Product and Skills and Education (S&E) Product); 
  As  a  response  to  contain  the  economic  impact  of  the  Covid-19  virus,  the  sixth 
amendment  and  restatement  of  the  EFSI  Agreement  was  signed  on  27  April 
2020 to repurpose within EFSI resources from the Infrastructure and  Innovation 
Window Equity Portfolio National Promotional Banks as well as certain existing 
SMEW  products  to  support  working  capital  lending  to  companies  impacted  by 
Covid-19. 

In this context, the EU Guarantee allocated to the SMEW product labelled COSME11 
Loan Guarantee Facility (COSME LGF) Enhancement was increased to  EUR 1,484 
million  and  the  EU  Guarantee  allocated  to  the  SMEW  product  labelled  InnovFin 
SMEG12 Enhancement was increased to EUR 1,400 million. 

The  EIAH  Framework  Partnership  Agreement  signed  with  the  EIB  in  July  2015  was 
amended in May 2017 and in April 2018 for the second time after the adoption of EFSI 
2.0. Yearly Specific Grant Agreements (SGAs) were signed with the EIB. 

The  Commission  Implementing  Decision  on  the  EIPP  adopted  in  2015  ((EU) 
2015/1214)  was  amended  with  Commission  Implementing  Decision  (EU)  2017/919  in 
2017 to increase its accessibility and user-friendliness: 

  The minimum project size was reduced from EUR 10 million to EUR 1 million, 
providing  more  opportunities  for  smaller  projects  such  as  those  supplied  by 
municipalities, regions, SMEs or start-ups;  

  The publication of projects on the EIPP is free of charge for all project promoters 

(public or private) since May 2017; 

  Project promoters can register their project online (previously this was done via a 

 

downloadable PDF form); and 
Investors  can  also  register  online,  receive  automatic  notifications  every  time  a 
new  project  is  published  on  the  Portal  and  also  subscribe  to  tailored  project 
updates according to their interests and preferences. 

The  EFSI  commitment  period  ended  on  31  December  2020.  Signatures  of  the  already 
approved  EFSI  operations  may  occur  until  31  December  2022,  whilst  operational 
monitoring  will  continue  until  repayment  of  all  financing  and  investment  operations 
supported by the EU Guarantee (expected until 2080). 

11 Programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises. 

12 SMEs & Small Midcaps R&I Loans Service under Horizon 2020. 

14 

 
 
                                                 
3.2 Current state of play 

After six  and a half  years since its adoption,  by  end-2021 the EFSI has triggered some 
EUR 524.3 billion of investments, thus exceeding the target for mobilised investments of 
EUR 500 billion. This relates to 708 approved Infrastructure and Innovation projects and 
805  SME  approved  operations  with  financial  intermediaries.  These  SMEW  operations 
are expected to have eased access to finance for some 1,5 million start-ups, SMEs, and 
mid-cap companies, including micro and social enterprises (through the EaSI Guarantee 
Facility13  and  Impact  Equity  pilot)  as  well  as  individuals,  enterprises  and  organisations 
investing in education and training (via the Skills & Education Guarantee Pilot).  

The transactions approved covered the 27 EU Member States plus the United Kingdom 
across all general  objectives set  out  in  the Article 9(2)  of the EFSI 2.0 Regulation (see 
Figures 3  and 4).  This  geographical  spread is  notable, taking into account  the demand-
driven nature of the EFSI and the different state of Member States’ economies.   

The share of the EFSI signatures in EU1314 has consistently improved since the start of 
the  EFSI  in  mid-2015,  although  in  absolute  figures  (e.g.,  related  to  investment  to 
population  ratio),  at  the  EIB  Group  level,  the  EFSI  support  remains  relatively  less 
predominant in this region.  

In terms of guarantee calls, a total of EUR 162 million was called from the EU guarantee 
as at the end of 2021. However, due to the current economic and social situation and the 
continuous  pandemic  implications,  an  increase  in  the  number  and  volume  of  future 
guarantee calls can be expected. 

13 The EFSI resources which were topped up as Second Loss Piece to the EaSI guarantee amounted to EUR 
300 million. The first top-up of EUR 100 million was provided in December 2016. This was further 
increased to a total amount of EUR 300 million at the end of 2018. 

14  EU13  stands  for  the  group  of  member  States  joining  the  EU  since  2004:  Czechia,  Estonia,  Cyprus, 
Latvia, Lithuania, Hungary, Malta, Poland, Slovak Republic and Slovenia, Romania, Bulgaria, and Croatia. 

15 

 
 
                                                 
Figure 3: EIB financing under EFSI IIW 

Source: EIB (amounts in EUR are based on the exchange rate of the event (approval / signature)) 

Figure 4: EIF financing under EFSI SMEW 

Source: EIB (based on approved operations) 

16 

 
 
 
 
 
As regards the EIAH, as of end-December 2021, more than 2030 requests were received 
from 27 Member States and the United Kingdom, of which 1715 were project-related and 
about 58% of them came from the private sector. As of end-2021 1,044 assignments were 
ongoing  or  completed.  The  underlying  investment  project  estimated  for  the  EIAH 
pipeline  represents  more  than  EUR  70  billion.  Moreover,  77  EIAH-supported  projects 
entered the EFSI pipeline.  

In  order  to  ensure  broad  coverage  of  advisory  services  across  the  whole  Union  and  to 
establish the cooperation platform as requested in the EFSI Regulation, the EIB and the 
Commission worked closely with a group of National Promotional Banks or Institutions 
(NPBIs)  and  prepared  a  Memorandum  of  Understanding  for  possible  cooperation 
between  the  EIAH  and  the  NPBIs.  In  this  context,  29  NPBIs  from  22  Member  States 
signed  Memoranda  of  Understanding  with  the  EIB.  The  EIAH,  in  line  with  the  EFSI 
Regulation, also established cooperation with the European Bank for Reconstruction and 
Development (EBRD), where the EIAH supports EBRD’s “Advice for Small Businesses 
Programme" in four Member States (Bulgaria, Croatia, Greece and Romania) in order to 
enhance SMEs’ access to professional advice and support for their growth.  

A total of 1,873 projects were submitted to the EIPP since its launch on 1 June 2016 – of 
which over 1,112 were published as of end-2021 and they spread over 25 high-economic-
potential sectors. The total expected investment cost of the published projects amounts to 
EUR 107.8 billion. Private promoters submitted 94% of these projects. 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

This section is based primarily on the evaluation reports prepared by the independent 
consultant, which the EC deems analytically robust and sufficiently evidence based. 

  The European Fund for Strategic Investments (including the EU guarantee) 

  To what extent was the intervention successful and why?  

This section assesses the extent to which the EFSI has delivered on its two primary goals: 
(i)  mobilising  investment  and  (ii)  enhancing  access  to  finance  for  SMEs  and  mid-caps 
(including micro and social enterprises).  

It  also  examines  whether  the  EFSI  has  contributed  to  any  wider  objectives  such  as 
institutional change and market development. In assessing the effectiveness of the EFSI, 
the evaluation takes a critical look at the additionality of EFSI financing, including any 
evidence  of  crowding-out  effects.  Finally,  this  section  examines  the  efficiency  and 
coherence of the EFSI. 

17 

 
 
 
4.1.1.1  Effectiveness of the EFSI and the EU Guarantee 
During the implementation of the EFSI, the cyclical investment gap in the EU gradually 
disappeared  and  financing  conditions  for  businesses  continued  to  improve  until  the 
Covid-19 pandemic. 

Effectiveness in mobilising investment 

The EFSI was successful in mobilising a significant volume of private financing and 
investment across the EU. By the end of 2021, EUR 99.3 billion of EFSI financing had 
been  approved  (and  86.6  billion  signed),  bound  to  mobilise  EUR  524.3  billion  of 
investment  across  Europe  based  on  approved  operations.  The  EFSI  is  also  on  track  to 
achieve its target of mobilising EUR 500 billion of investment based on signatures by the 
end of 2022.15 Overall, private financing represents 72% of the investment expected to be 
mobilised by the EFSI based on signed operations. 

The  EFSI  mobilised  investment  represented  roughly  2.7%  of  the  annual  investment  at 
EU  level,  but  in  some  Member  States  (particularly  in  Greece  but  also  in  Bulgaria  and 
Estonia)  it  accounted  for  a  significant  share  of  investment.  In  fact,  apart  from  a  few 
exceptions,  EFSI  financing  was  well-aligned  with  country-level  investment  gaps. 
Generally, the proportion of EFSI financing taken up by each Member State was in line 
with the relative size of its economy, measured by each Member State’s GDP as a share 
of the total EU27 GDP (Table 1; see also Figures 4 and 5 above). 

Table 1: Investment gaps and distribution of EFSI-supported investment 

EFSI 
Signatures 
(EUR bn) 

EFSI 
signatures 
as a %  
total EU 
level 
signatures 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia  
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 

1.962 
1.708 
666 
367 
154 
891 
971 
266 
1.802 
14.604 
8.017 
2.823 
526 
1.080 
12.006 
168 

2,3% 
2,0% 
0,8% 
0,4% 
0,2% 
1,0% 
1,1% 
0,3% 
2,1% 
16,9% 
9,3% 
3,3% 
0,6% 
1,2% 
13,9% 
0,2% 

National 
GDP as % 
EU27 GDP 
(average 
over the 
period 
2015-2021) 
2,7% 
3,3% 
0,4% 
0,4% 
0,2% 
1,5% 
2,3% 
0,2% 
1,7% 
17,9% 
24,0% 
1,5% 
1,0% 
2,3% 
13,1% 
0,2% 

Investme
nt 
mobilised  
EUR bn 

Average 
annual 
investment 
mobilised 
(2016-2021) 

EFSI 
investment 
mobilised as 
a %  TGFCF  
(average 
2016-2021) 

Pre-EFSI 
Investment 
Levels (2010-
2015)* 

Historical 
trend  
(1995-
2005)** 

Investment 
gap*** 

6.781 
8.947 
4.394 
1.379 
398 
6.140 
5.115 
3.360 
12.388 
80.400 
38.206 
13.732 
4.143 
6.686 
73.362 
935 

1.130 
1.491 
732 
230 
66 
1.023 
853 
560 
2.065 
13.400 
6.368 
2.289 
691 
1.114 
12.227 
156 

1,2% 
1,4% 
7,0% 
2,2% 
1,6% 
1,9% 
1,3% 
7,8% 
3,7% 
2,5% 
0,9% 
11,6% 
2,0% 
0,9% 
3,9% 
2,4% 

22,48% 
22,62% 
21,28% 
19,76% 
16,86% 
26,18% 
18,68% 
26,00% 
22,30% 
22,16% 
20,02% 
12,76% 
20,30% 
18,62% 
18,38% 
23,04% 

24,70% 
21,65% 
16,66% 
21,28% 
21,57% 
31,00% 
20,76% 
29,22% 
21,85% 
20,76% 
21,61% 
22,96% 
23,96% 
23,50% 
20,29% 
23,35% 

-2,22% 
0,97% 
4,62% 
-1,52% 
-4,71% 
-4,82% 
-2,08% 
-3,22% 
0,45% 
1,40% 
-1,59% 
-10,20% 
-3,66% 
-4,88% 
-1,91% 
-0,31% 

15 To be confirmed on the basis of official EIB Group reporting as at 31 December 2022. 

18 

 
 
 
 
                                                 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia**** 
Slovenia 
Spain 
Sweden 
UK 
Regional - 
EU 
Non-EU 
Total 

251 
124 
40 
3.056 
3.259 
2.770 
972 
572 
197 
11.439 
3.249 
1.691 
10.934 

302 
86.868 

0,3% 
0,1% 
0,0% 
3,5% 
3,8% 
3,2% 
1,1% 
0,7% 
0,2% 
13,2% 
3,8% 
2,0% 
12,6% 

0,35% 
100% 

0,3% 
0,4% 
0,1% 
5,8% 
3,9% 
1,5% 
1,4% 
0,7% 
0,3% 
9,3% 
3,6% 
0,0% 
- 

1.380 
542 
199 
14.043 
19.517 
10.735 
4.471 
1.849 
1.343 
51.966 
13.178 
20.354 
85.633 

230 
90 
33 
2.341 
3.253 
1.789 
745 
308 
224 
8.661 
2.196 
3.392 
14.272 

2,3% 
0,9% 
1,2% 
1,4% 
3,7% 
4,9% 
1,6% 
1,7% 
2,5% 
3,8% 
1,9% 
0,8% 
- 

18,00% 
18,58% 
18,00% 
18,92% 
19,78% 
16,92% 
25,66% 
21,12% 
19,74% 
19,10% 
22,74% 
15,98% 
0,00% 

21,59% 
21,03% 
22,05% 
21,45% 
20,44% 
25,42% 
21,15% 
28,98% 
25,64% 
25,05% 
21,39% 
25,05% 
0,00% 

-3,59% 
-2,45% 
-4,05% 
-2,53% 
-0,66% 
-8,50% 
4,51% 
-7,86% 
-5,90% 
-5,95% 
1,35% 
-9,07% 
0,00% 

100% 

478 
492.058 

81.930 

2,7% 

19,64% 

21,10% 

-1,46% 

*The period 2016-2021 is taken due to the small volume of EFSI signatures in 2015 (3% of the total EFSI 
signatures) 
** Calculated as average annual GFCF over the period 2010-2014 
***EU average used for Slovakia and Poland due to absence of data 
Sources: ICF analysis based  on combined IIW and  SMEW Operational reports, IIW portfolio bottom-up 
analysis, SMEW Operational reports, Eurostat 

In line with Article 9 of the EFSI Regulation, EFSI-backed operations addressed a range 
of  market  failures  and  sub-optimal  investment  situations,  albeit  to  varying  degrees.16 
These include: 

  Financial support to entities having up to 3 000 employees; 
  Development and deployment of information and communication technologies; 
  Development of the energy sector; 
  Development  of 

infrastructures,  and  equipment  and 

transport 

innovative 

technologies for transport; 

  Environment and resource efficiency; 
  Human capital, culture and health; 
  Research, development and innovation; and 
  Sustainable  agriculture,  forestry,  fishery,  aquaculture  and  other  elements  of  the 

wider bio-economy. 

16  Based  on  a  review  of  project  descriptions  for  the  entire  EFSI  portfolio  and  deep-dives  of  a  sample  of 
operations. 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 2: EFSI mobilised investment by thematic area 

*Less-developed and transition regions 
**Sustainable agriculture, forestry, fishery, aquaculture and wider bio-economy 
Note: EFSI mobilised investment reflects the overall volume of investment expected to be mobilised by the 
EFSI over several years by operations signed until the end of 2021. All figures are in EUR billions. 
Source: EFSI Combined IIW and SMEW Operational Report 2021.  

Overall,  it  is  hard  to  judge  if  EFSI  financing  was  well  balanced  across  all  policy 
objectives / thematic areas (see Table 2), as policy objectives / thematic areas are broadly 
defined, and hard to  be  assigned precise weights;  yet,  overall, EFSI-IIW  financing was 
well targeted to areas where the private sector is less likely to invest on its own. Several 
examples can be found of this nature, most notably including:17 

  EFSI financing to support investment in new technologies. For example, the EIB 
provided EFSI financing to a biopharmaceutical company in Germany to develop 
a  safe  and  effective  vaccine  against  Covid-19  and  its  production  on  the  scale 
necessary to make the vaccine available globally; 

  EFSI support to large, complex projects. For example, the EFSI financed a large-

scale greenfield urban development project in France; and 

  EFSI  investments  in  social  objectives  and  public  goods.  This  includes  projects 
where  social  return  is  higher  than  private  return  such  as  network  goods  (e.g., 
transport  and  energy  networks),  public  goods  (e.g.,  health  and  education 
facilities18) and goods that deliver social objectives (e.g., social housing19). By end 
2021,  4%  of  EIB-financed  investment  and  8%  of  EIF-financed  investment  are 
channelled to social infrastructure.  

17  Examples  of  EFSI-backed  projects  by  country  and  sector  can  be  found  on  the  IPE  website 
(https://ec.europa.eu/info/strategy/priorities-2019-2024/economy-works-people/jobs-growth-and-
investment/investment-plan-europe/investment-plan-results_en). 

18 For example,  the EIB is  extending EFSI-backed  lending  to  the University of  Latvia  (EUR 30  million) 
and  to  the  Medical  University  of  Warsaw  (EUR  24  million)  to  build  state  of-the-art  research  and  study 
facilities.  

19  Likewise,  an  EUR  42  million  loan  was  granted  for  the  first  time  to  the  municipal  communal  housing 
company in Poznan (Poland) to finance the construction or refurbishment of around 1 160 social housing 
apartments  for  low-income  earners  and  14  community  healthcare  centres.  Details  can  be  found  on  the 
following website: https://www.eib.org/en/stories/efsi-in-poland. 

20 

Objective as per Article 9Volume% TotalVolume% TotalVolume% TotalEnergy77,807          28%77,807          16%Financial support to entities having up to 3 000 employees73,817          26%85,097       40%158,914        32%RDI50,719          18%74,552       35%125,271        25%Transport31,472          11%31,472          6%ICT16,907          6%33,401       16%50,309          10%Environment and resource efficiency17,081          6%17,081          3%Human capital, culture and health9,791            3%17,429       8%27,221          6%Bioeconomy**2,904            1%2,904            1%Regions*1,080            0.4%1,080            0.2%Total         281,578 100%      210,480 100%         492,058 100%IIWSMEWTotal EFSI 
 
 
 
                                                 
EIB  financing  under  the  IIW  also  offered  several  features  that  were  not  available  to 
project promoters from alternative sources (private or public).  These included: 

  Scale  of  financing  (financing  of  a  similar  scale  would  not  have  been  possible 
from alternative sources/ channels) – for instance, among the sample of projects 
selected  for  deep-dives,  EFSI  financing  to  projects  in  the  ICT,  manufacturing, 
transport  and  energy  sectors  (across  France,  Germany,  Greece,  Italy  and  Spain) 
averaged around EUR 200 million;  

  Lower interest rates / cost compared to prevailing market interest rates; 
  Flexibility of financing conditions e.g., floating or fixed rates depending on needs, 

flexibility of drawdowns, grace period etc.; 

  Long-term nature of EIB financing, thereby lowering average financial costs and 

facilitating repayments; 

  Funding diversification for promoters; 
  Tailored or innovative financing solutions; 
  The “green stamp” for projects in certain sectors, e.g., if the project was selected 

for the EIB’s Climate Awareness Bond financing; 

  EIB’s technical expertise, and technical and legal due diligence; and 
  Quality stamp / reputational benefit of the EIB’s involvement. 

Despite  some  stakeholder  feedback  suggesting  that  EFSI  financing  under  the  IIW  may 
have overreached, and crowded-out private or NPBI finance in a few instances, all in all, 
the weight  of the evidence suggests that EFSI played a role in  reducing the investment 
gap in Europe by accelerating and boosting investment in areas characterised by market 
failures or sub-optimal investment needs. 

Effectiveness in improving access to finance 

EFSI financing has supported hundreds of thousands of enterprises across Europe. As of 
31  December  2021,  the  SME  window  under  EFSI  had  provided  EUR  33.5  billion  of 
financing  to  an  estimated  1.5  million SMEs  and  mid-caps  across  the  EU.  Additionally, 
SMEs  and  mid-caps  were  also  supported  through  several  intermediated  lending 
operations  under  the  IIW.  Beyond  the  headline  numbers,  EFSI  financing  has  backed 
several  top  start-ups  and  unicorns  (valuation  >  EUR  1  billion).  For  example,  SMEW 
equity operations went to several new TOP 100 start-ups in Germany and unicorns, such 
as  Sennder  and  Isar  Aerospace,  which  are  among  the  list  of  Top  100  start-ups  in 
Germany. 

A  range  of  products  (debt,  equity  and  quasi-equity  /  venture  debt)  were  deployed  or 
piloted under the EFSI to meet the diversity of financing needs across segments, sectors 
and geographies. In its first phase, EFSI financing under the SMEW was used to front-
load and top-up existing financial instruments such as COSME and InnovFin20. Overtime, 

20 “EU Finance for Innovators” initiative under Horizon 2020. 

21 

 
 
                                                 
as the focus shifted from volume to additionality, a range of new products were piloted or 
developed  under  SMEW  to  meet  financing  needs  in  specific  segments  and  thematic 
areas, e.g.: 

  The European Scale-up Action for Risk capital;  
  The digitalisation  pilot under COSME  to  provide enhanced access  to  finance to 

SMEs undertaking a digital transformation; 

  Private  credit  product,  to  increase  the  availability  of  non-bank  financing  for 

businesses from alternative investment funds; 

  EFSI  combination  product,  targeted  primarily  to  the  agricultural  sector  by 
stimulating  a  greater  allocation  of  European  Agriculture  Fund  for  Rural 
Development (EAFRD) funds in Europe; 

  Skills & education pilot; 
  EFSI pilot on social impact and impact investing; and  
  Additional product offering in the fields of blue economy, life sciences, artificial 

intelligence, and blockchain technologies. 

Patterns of absorption of the SMEW products vary across countries. In several Member 
States, a significant  share of  the SMEW support was  channelled  through NPBIs and/or 
counter-guarantee  institutions  (e.g.,  Ireland,  France,  and  Italy).  The  involvement  of 
NPBIs  had  certain  advantages  in  the  form  of  a  higher  multiplier  effect  and 
complementarity  with  national  promotional  products.  The  product  mix  also  reflected 
differences  in  market  needs,  as  well  as  the  structure  and  sophistication  of  financial 
markets. On the other hand, there was limited take up and reach of the SMEW relative to 
needs in countries such as Croatia, Latvia, Poland and Slovenia (see Table 3). This also 
reflected  semi-structural  factors,  such  as  the  limited  extent  of  NPBIs  and/or  counter-
guarantee  institutions’  involvement,  the  product  mix  offered,  the  average  loan  amount 
(the higher the average loan amount, the fewer the number of beneficiaries reached) and 
the financial intermediaries capacity. 

22 

 
 
Table 3: Financial constraints and distribution of SMEW financing 

Signatures/EIF 
financing 

Total 
SMEW 
Financing 
(EUR 
million) 

SMEW 
financing 
signed 
as a % 
total 
SMEW 

Member 
State 
GDP as 
share 
of EU 
GDP 

Country 

Final Recipients 

Breakdown of Financing Signed 

No of final 
recipients 

Amount of 
financing 
received 
(EUR million) 

% of total 
number 
of final 
recipients 

% SMEs 
declaring 
they face 
credit 
constraints 
(2019)  

Number of 
micro 
enterprises and 
SMEs (2019) 

Share of 
enterprises 
supported 
by EFSI 

% EFSI 
Financing 
COSME 

% EFSI 
Financing 
other 
debt* 

% EFSI 
Financing 
equity 

 Austria  

             300  

 Belgium  

             244  

 Bulgaria  

             296  

 Croatia  

 Cyprus  

             262  

                 9  

 Czechia  

             739  

 Denmark  

             406  

 Estonia  

 Finland  

 France  

               50  

             145  

1.1% 

0.9% 

1.1% 

1.0% 

0.0% 

2.8% 

1.5% 

0.2% 

0.5% 

2.7% 

           2,741  

                 923  

3.3% 

           6,620  

              1,406  

0.4% 

         10,796  

              1,875  

0.4% 

           1,624  

                 364  

0.2% 

                23  

                   20  

1.5% 

         22,064  

              3,095  

2.3% 

           1,438  

              1,460  

0.2% 

           4,201  

                 460  

1.7% 

           4,970  

              1,520  

0% 

1% 

1% 

0% 

0% 

3% 

0% 

1% 

1% 

4% 

               329,937  

6% 

               672,617  

11% 

               347,971  

10% 

               181,989  

8% 

                 57,196  

7% 

            1,057,113  

6% 

               227,730  

10% 

                 82,100  

0% 

               232,141  

          3,029  

11.3% 

17.9% 

       190,790  

            15,548  

25% 

3% 

            2,963,416  

 Germany  

          1,193  

4.4% 

24.0% 

         24,998  

              6,988  

 Greece  

             502  

 Hungary  

             153  

 Ireland  

             331  

1.9% 

0.6% 

1.2% 

1.5% 

         24,871  

              3,592  

1.0% 

         13,770  

              1,272  

2.3% 

           6,561  

                 606  

 Italy  

 Latvia  

          3,535  

13.2% 

13.1% 

       196,475  

            22,701  

               24  

0.1% 

0.2% 

           2,691  

                 163  

5% 

            2,580,860  

18% 

               717,154  

10% 

               646,130  

8% 

               265,297  

6% 

            3,613,275  

19% 

               111,434  

3% 

3% 

2% 

1% 

26% 

0% 

23 

0.8% 

1.0% 

3.1% 

0.9% 

0.0% 

2.1% 

0.6% 

5.1% 

2.1% 

6.4% 

1.0% 

3.5% 

2.1% 

2.5% 

5.4% 

2.4% 

6% 

23% 

36% 

1% 

0% 

13% 

3% 

63% 

38% 

10% 

9% 

63% 

30% 

9% 

14% 

26% 

94% 

70% 

64% 

88% 

100% 

87% 

97% 

7% 

21% 

75% 

62% 

34% 

70% 

57% 

66% 

74% 

0.0% 

7.5% 

0.0% 

11.7% 

0.0% 

0.0% 

0.0% 

29.9% 

41.1% 

14.9% 

28.6% 

3.0% 

0.0% 

33.7% 

20.4% 

0.0% 

 
 
  
Signatures/EIF 
financing 

Total 
SMEW 
Financing 
(EUR 
million) 

SMEW 
financing 
signed 
as a % 
total 
SMEW 

Member 
State 
GDP as 
share 
of EU 
GDP 

Country 

Final Recipients 

Breakdown of Financing Signed 

No of final 
recipients 

Amount of 
financing 
received 
(EUR million) 

% of total 
number 
of final 
recipients 

% SMEs 
declaring 
they face 
credit 
constraints 
(2019)  

Number of 
micro 
enterprises and 
SMEs (2019) 

Share of 
enterprises 
supported 
by EFSI 

% EFSI 
Financing 
COSME 

% EFSI 
Financing 
other 
debt* 

% EFSI 
Financing 
equity 

 Lithuania  

               18  

 Luxembourg  

               81  

 Malta  

                 7  

0.1% 

0.3% 

0.0% 

0.3% 

           3,169  

                 231  

0.4% 

              461  

                 611  

0.1% 

                  4  

                     4  

Multi-country 
(SMEW)  

          9,860  

36.8% 

- 

- 

- 

15% 

               219,530  

5% 

                 35,122  

8% 

                 31,792  

1.4% 

1.3% 

0.0% 

- 

- 

- 

 Netherlands  

             661  

 Poland  

             292  

 Portugal  

          1,568  

 Romania  

             279  

 Slovakia  

               57  

 Slovenia  

               44  

 Spain  

          1,907  

 Sweden  

             407  

 United Kingdom  

             427  

2.5% 

1.1% 

5.8% 

1.0% 

0.2% 

0.2% 

7.1% 

1.5% 

1.6% 

5.8% 

         12,913  

              2,029  

3.9% 

         59,201  

              2,608  

1.5% 

         10,740  

              3,231  

1.4% 

         27,524  

              1,174  

0.7% 

           6,466  

                 342  

0.3% 

           3,713  

                 669  

9.3% 

       114,082  

              9,756  

15% 

6% 

            2,689,291  

3.6% 

           6,728  

              2,070  

- 

           1,386  

              3,735  

1% 

0% 

3% 

               646,376  

7% 

5% 

            1,292,840  

14% 

            2,018,958  

5% 

               929,317  

13% 

               515,051  

4% 

               511,488  

10% 

               148,782  

1.0% 

2.9% 

1.2% 

5.3% 

1.3% 

2.5% 

4.2% 

1.0% 

0% 

0% 

0% 

- 

2% 

8% 

1% 

4% 

1% 

0% 

 Total  

        26,826  

100.0% 

0.0% 

       761,084  

            88,749  

100% 

8% 

          22,794,970  

3.3% 

13% 

*Includes InnovFin, CCS, EaSI, EFSI Combination Product (ECP), Skills & education 
**Data on financially constrained firms in Finland not available  
Sources: ICF analysis based on SMEW Operational reports (signed operations), Eurostat, EIBIS 

24 

23% 

2% 

74% 

- 

5% 

51% 

5% 

18% 

30% 

49% 

16% 

0% 

0% 

77% 

98% 

26% 

- 

61% 

36% 

92% 

82% 

70% 

39% 

69% 

78% 

15% 

69% 

0.0% 

0.0% 

0.0% 

- 

34.2% 

13.7% 

3.1% 

0.0% 

0.0% 

11.9% 

15.2% 

21.8% 

84.5% 

18.3% 

 
 
  
  
  
In  line  with  its  intervention  logic,  the  EFSI  resulted  in  improved  availability  and 
conditions  of  finance  for  SMEs  and  mid-caps  (including  micro  and  social  enterprises). 
Financial intermediaries interviewed consistently reported that the EFSI support enabled 
them to: 

Increase lending volumes; 

 
  Target riskier clients / under-served / niche segments;  
  Offer better terms and conditions as compared to their normal business practice; 
  Enhance their offer; and 
  Develop their risk appetite. 

This  was possible thanks to  the incentivisation mechanisms  built  in the SMEW design, 
such as: 

1.  Risk  reduction,  high  guarantee  coverage  (especially  on  a  loan-by-loan  basis  for 

COSME and InnovFin top-ups); 
2.  Zero fee (for COSME top-ups); 
3.  Design that ensured the State aid consistency of EFSI financing. No further State 
aid conditions or procedures had to be followed by EIB/beneficiaries (no need of 
checking limits as in case of de minimis aid/ possibility to target companies that 
used up their de minimis limits); and 

4.  Capital relief. 

Despite inevitable ‘deadweight’,21 the above results would have been difficult to achieve 
without  EFSI  support.  For  example,  in  Latvia,  the  SMEW  top-ups  for  the  InnovFin 
guarantees  enabled  financial  intermediaries  to  provide  loans  and  leases  to  innovative 
SMEs and small mid-caps across various sectors, which would not have otherwise been 
possible.  Likewise, 
that  EaSI  microfinance  guarantee 
reported 
programme, topped up under the EFSI SMEW, allowed them to provide loans (of up to 
EUR  25,000 
individuals  and 
microenterprises without the need for collateral. The EFSI also contributed to enhancing 
and  diversifying  access  to  finance,  by  supporting  the  development  of  equity  and 
alternative  sources  of  finance,  where  the  EIB  Group’s  added  value  is  particularly 
pronounced. 

to  financially-excluded  self-employed 

intermediaries 

in  value) 

21 Changes that would have occurred even in the absence of intervention. In the EIB EV survey of EFSI-
backed financial intermediaries, 10% of the respondents reported that in absence of the EFSI support they 
would  have  obtained  the  financing/  guarantee  from  another  source  (similar  size,  same  timeframe  and 
features). This level of deadweight is relatively low and within acceptable bounds. There is however, the 
risk of a potential positive bias in the responses of supported financial intermediaries. 

25 

 
 
 
 
 
 
                                                 
Financing climate action 

EFSI delivered on its target of 40% financing for climate action under the IIW. 59% of 
the EFSI operations signed until the end of 2021 had a climate action component. This 
represented  44%  of  the  signed  EFSI  IIW  volumes.  Overall,  the  EFSI  supported  392 
operations (half of which concentrated in Germany, Spain and France) that had a climate 
action  component  with  EUR  20.5  billion  of  financing.  The  introduction  of  the  climate 
action target, however, did not have any side effects on the geographical diversification 
or the risk profile of the EFSI portfolio. Nevertheless, in terms of the composition of the 
portfolio,  the  EFSI  also  financed  projects  with  potential  environment  externalities, 
notably  when  these  addressed  sub-optimal  investment  situations  in  specific  regions  or 
countries. 

Alleviating the impact of Covid-19 pandemic on the European economy 

By  enabling a quick and flexible response,  the EFSI proved to  be an effective counter-
cyclical  instrument  during  the  Covid-19  pandemic.  The  feedback  on  the  Covid-19 
response by the EIB Group in general and under the EFSI specifically is very positive: 
quick  response,  well-tailored  to  changing  needs,  at  considerable  scale,  under  both  the 
IIW and SMEW (see box). 

Summary overview of Covid-19 response under EFSI 
SMEW 
Reallocating within the EFSI some EUR 1 billion of available EFSI resources towards 
existing guarantee products under the SMEW (InnovFin SMEG Enhancement and 
COSME LGF Enhancement) managed by the EIF to the benefit of the hard-hit SMEs and 
mid-cap sector in the EU, with a view to mobilise some EUR 8 billion of additional 
financing. At the time, the majority of their budget resources had been largely absorbed. 
The calls for expression of interest for the two EFSI SMEW products (the COSME Loan 
Guarantee Facility Enhancement and InnovFin SME Guarantee Facility (SMEG) 
Enhancement) were published as early as April 2020, with closing in June 2020. The 
calls were oversubscribed. 

Updated terms and conditions. These were made available to new intermediaries through 
the calls for expression of interest and granted semi-automatically to existing 
intermediaries (after financial intermediaries submitted their applications through an 
online form on the EIF’s website). The most important enhancements to the terms 
offered specifically under the two SMEW products (COSME LGF Enhancement and 
InnovFin SMEG Enhancement) comprised the following: 

 

Increase the guarantee rate for working capital from 50% to up to 80% for transactions under the 
COSME LGF and InnovFin SMEG (with retroactive effect from April 2020); 

  Maximum guarantee cap rate increased from 20% to 25% (COSME); 
  Minimum financial intermediary risk retention reduced from 20% to 10%; 
  Postponement, rescheduling or credit holiday period explicitly allowed; 
  Coverage of accrued or capitalised interest extended to 360 days; 
  Possibility of increasing the maximum rollover period of revolving credit transactions from five to 

nine years (COSME LGF) and to six years (InnovFin SMEG); 

  Possibility of verifying innovation eligibility criteria based on self-declarations by companies 

rather than independent confirmations (InnovFin SMEG); 

26 

 
 
 
  Refinancing of existing guaranteed transactions permitted (InnovFin SMEG); 
  Minimum maturity of bridge financing reduced to six months (InnovFin SMEG); and 
  Speedier treatment of requests for approval thanks to measures at the level of the EIF Board 

(streamlining the compliance risk assessment and the request for approval template). 

The updated terms and conditions were, according to financial intermediaries concerned 
interviewed as part of EIB EV22’s evaluation, very useful for them to maintain their 
activity throughout the pandemic.  
Note: enhanced terms and conditions were made available also for other SMEW 
products: the EaSI GFI23 and the CCS GF product and the InnovFin Equity24 facility. 
Unlike COSME and InnovFin SMEG, these facilities did not however benefit from 
additional budget reallocation within the EFSI. 

IIW  
41 new EFSI operations approved in 2020 specifically targeting Covid-19 crisis 
response for an amount of EUR 4.5bn. These included: 

  A dedicated EUR 2 billion Programme Loan for support to SMEs and Mid-Caps via mezzanine 
tranches in Asset-Backed Security transactions facilitating up to EUR 10 billion of additional 
intermediated financing.  

  A venture debt programme (the European Growth Finance Facility (EGFF)), that targets the early 

and growth stage highly innovative European companies in sectors such as ICT, energy 
efficiency, engineering and life science (including innovative biotech or medtech companies/ 
projects involved in the fight against Covid-19).  

  Financing to BioNTech for the development and manufacturing of its vaccine candidate which 
became the first approved vaccine against the SARS-CoV-2 virus in the EU and saved about 6 
million lives only in 2021.  

  Simplified approval process for specific underlying operations within Covid-19 Envelopes of 
financing under the IIW, as decided by the Steering Board in April 2020, including for: 
(i) 

Sub-operations above the threshold of EUR 50 million under the Covid-19 specific 
programme loans, which would normally be examined and approved individually, were 
approved under their respective programme loans; and 
Top-ups for existing operations and repeat operations with existing clients, to 
compensate for difficulties in finding new sources of financing. 

(ii) 

  Accelerating approvals and signatures for EIB Group-financed operations in general, including 

the EFSI operations. In general EIB Covid-19 operations were more than twice as fast in moving 
from the launch of the project appraisal to the first disbursement. 

Sources: 2020 and 2021 EFSI REPORT - From the European Investment Bank to the European Parliament 
and the Council on EIB Group Financing and Investment Operations under the EFSI  
EIB  EV  (2021)  Rapid  assessment  of  the  EIB  Group’s  operational  response  to  the  Covid-19  crisis, 
December 2021.  
EIB EV (2021) Evaluation of the European Fund for Strategic Investments 2021 – Thematic Report 

22 European Investment Bank Operations Evaluation. 

23 EaSI Guarantee Financial Instrument. 

24 Equity Facility (early-stage capital) for Research and Innovation of Horizon 2020. 

27 

 
 
 
 
 
 
 
 
                                                 
Creating jobs and growth 

The impact of the EFSI-supported operations on the EU economy was estimated through 
the  RHOMOLO-EIB  model.25  Two  main  channels  were  taken  into  consideration:  a 
shorter-term  investment  effect  and  a  longer-term  structural  and  competitiveness  effect. 
The estimates concluded that investments supported by EFSI (EUR 545 billion as of end-
2020 - final number as end-2022 will be slightly lower due to partial or full cancellations 
of some operations but still above EUR 500 bn) are expected to help the creation of 2.1 
million jobs and generate an increase of EU GDP by 2.4% by 2025, thanks to short-term 
investment effects.  

While  short-term  investment  effect  will  by  nature  fade  over  time,  the  EFSI  impacts  on 
growth and employment are expected to be still visible in the longer term thanks to the 
more persistent structural effects (e.g., enhanced production technologies, better private 
and public infrastructure, and greater labour productivity). In line with the intended logic 
of  the  EFSI  intervention,  the  model  also  concluded  that  Cohesion  regions26  benefit 
significantly more than better-developed regions both in the short and long term (twice as 
high and 10% higher, respectively, when it comes to GDP impact). Similarly, countries 
hit hardest by the 2008 economic and financial crisis are expected to benefit more from 
EFSI. 

Cooperating and collaborating with NPBIs 

The  EFSI  placed  a  significant  emphasis  on  cooperation  and  collaboration  with  NPBIs 
and  indeed  high  levels  of  NPBI  involvement  were  achieved  under  the  EFSI.  Overall, 
20.5%  of  EFSI  financing  was  implemented  in  collaboration  with  NPBIs,  with  greater 
collaboration  under  the  SMEW  (21%  of  operations  and  28%  in  terms  of  volume)  as 
compared  to  the  IIW  (12.5%  of  operations  and  17%  of  IIW  financing).  60  investment 
platforms were set  up in  18 Member States reflecting  an important outreach  effort, but 
their  set-up  and  implementation  was  deemed  complex  and  inefficient,  due  to  the  large 
transaction  costs  and  expertise  required,  making  collaboration  with  NPBIs  often 
challenging. For this reason, investment platforms were more attractive in large Member 
States with experienced and established NPBIs.  

4.1.1.2  Efficiency of the EFSI and the EU Guarantee 
The evaluation looked at the following aspects of efficiency: (i) the budgetary impact of 
the  first  loss  piece  covered  by  the  EU;  (ii)  the  multiplier  effect  achieved;  (iii)  the 

25  EIB  (2021)  Macroeconomic  Impact  of  the  European  Fund  for  Strategic  Investments.  Complementary 
section to the Evaluation of the European Fund for Strategic Investments 2021. 

26  Cohesion  Member  States  are  Bulgaria,  Czechia,  Estonia,  Greece,  Croatia,  Cyprus,  Latvia,  Lithuania, 
Hungary, Malta, Poland, Portugal, Romania, Slovenia, and Slovakia. 

28 

 
 
                                                 
adequacy of the Guarantee Fund provisioning; and (iv) governance and implementation 
structure. 

Budgetary impact of the first loss piece covered by the EU 

Under  the  SMEW,  resources  from  the  EFSI  were  combined  with  resources  from  other 
EU sectoral  programmes  in  the following manner:  the portfolio’s  first  loss piece (FLP) 
from Horizon 2020, COSME, EaSI and CCS would pay for all guarantee calls from  the 
EFSI as well as non-EFSI operations signed under those mandates; the EFSI second loss 
piece (SLP) would cover guarantee calls with respect to the EFSI. The full scale of losses 
is yet unknown as the operations are still underway, but the table provides an indication 
of  the  potential  budgetary  impact  of  the  FLP  together  with  EFSI  SLP.  Later  on  in  this 
section, the adequacy of provisioning under the EFSI is discussed.  

Table 4: Budget contribution and investment mobilised 

*Also  known  as  the  IFE  Facility  for  Early  Stage.  This  is  a  structured  financial  product  with  an  overall 
financial  envelope  of  EUR  1,619  million;  it  combines  resources  from  InnovFin  Equity  (45%),  EFSI 
(26.5%) and EIF (28.5%). 
Note: Some fund of funds investments were made in the pan-European FoF programme of IFE, hence the 
high amount of investment mobilised 
Source: EFSI SMEW Operational Report 2021 

Multiplier effect of the EFSI 

The EFSI has delivered a high multiplier effect, exceeding initial assumptions. The 
currently estimated multiplier effect of the EFSI (15.75) is slightly higher than the initial 
target  of  15.  The  multiplier  effect  captures  the  relation  between  the  underlying  EFSI 
support  and  the  amount  of  total  investment  that  is  expected  to  be  generated  by  such 
financing (i.e., the total project cost for investment). The total multiplier is made of two 
components: (i) the internal multiplier which shows the multiple between the underlying 
EFSI  contribution  and the amount of EIB/EIF financing and (ii) the external  multiplier 
which shows the multiple between the EIB/EIF financing under the EFSI and the amount 
of total investment.  

Neither the EFSI multiplier methodology, nor the EFSI Regulation, make the assumption 
that  all  sources  of  finance  flowing  into  a  project  are  attracted  as  a  result  of  the  EFSI 
guarantee.  As  such,  the  multiplier  methodology  does  not  claim  attribution  or  causality. 
The  methodology  is  used  as  the  best  indication  of  total  investment  mobilised 

29 

EFSI financial product  with FLP from Financial InstrumentFLP coverage by Financial InstrumentSLP coverage by EFSI guarantee Total EU budgetary  coverage in EURInvestment mobilised million EURInvestment mobilised per EUR of EU contribution(1)(2)(3)(4)=(2)+(3)(5)(6)=(5)/(4)SMEW InnovFin SMEG1,184,845,7281,400,000,0002,584,845,72833,31213SMEW COSME LGF1,124,350,2571,484,000,0002,608,350,25784,39832SMEW EaSI118,030,729300,000,000418,030,7294,12510SMEW CCS112,535,229130,000,000242,535,2293,08813Sub-total: debt products2,539,761,9433,314,000,0005,853,761,943124,92321SMEW Equity sub-window 2*728,550,000429,035,0001,157,585,00033,28529Total: debt + equity3,268,311,9433,743,035,0007,011,346,943 
 
 
(irrespective  of  the  actual  circumstances  underlying  the  mobilisation)  –  with  some 
adjustments  e.g.,  with  regards  to  other  EU  co-financing  (e.g.,  EU  grant-financing,  EU 
financial  instruments  or  European  Structural  and  Investment  Funds  (ESIF)  grants  or 
financial instruments including related national co-financing) are not taken into account 
in the calculation of the multiplier.27 

Adequacy of the Guarantee Fund provisioning 

EFSI  has  two  financing  components:  the  maximum  guarantee  amount  from  the  EU 
budget of EUR 26 billion and the maximum EIB allocation amount of EUR 7.5 bn. This 
evaluation considers the EU guarantee and its provisioning of 35%, which was chosen to 
avoid  a  ‘pay  as  you  go’  approach.  Cumulative  budgetary  appropriations  for  EFSI 
provisioning  transferred  and  paid  into  the  Common  Provisioning  Fund  (CPF)  by  2021 
amount to EUR 8.769 billion, including the remuneration received according to the EFSI 
Agreement to the extent transferred to the CPF as internal assigned revenues (EUR 0.731 
billion). By 2023 the cumulative appropriations are planned to reach EUR 9.521 billion, 
including EUR 1.096 billion of internal assigned revenues.  

The  overall  EFSI  provisioning  set  at  35%  sufficiently  protects  the  EU  budget.  A 
model-based analysis conducted as part of this evaluation (see Annex IV) shows that the 
provisioning rate of 35% is adequate, i.e., it will avoid future burden of the EU budget. In 
fact, with a conservative approach until the end of 2021 additional (small) buffers were 
created on top of the budget appropriations (internal assigned revenues, unused guarantee 
allocations, value adjustments, etc.). The provisioning does not  cover the expected loss 
only;  according  to  a  Value  at  Risk  (VaR)  approach,  it  will  be  sufficient  to  cover  with 
95%  probability  the  potential  future  losses  (including  unexpected  losses)  over  the 
programme’s lifetime. 

Governance and implementation structure 

The  governance  structure  that  had  been  set-up  for  the  EFSI  worked  well.  Interviewees 
highlighted several positive aspects of the governance structure: 

  The  governance  structure  brought  together  the  market  knowledge  and  banking 
expertise  of  the  EIB  with  policy  steer  from  the  EC,  while  ensuring  clear 
separation between the EIB and the EC (between the lender and guarantor);  
  Clear  role  for  the  Investment  Committee  (IC)  -  purely  responsible  for  decisions 
around the allocation of the EU guarantee and balancing well policy and financial 
considerations; 

  Decisions of the IC being facilitated by the Guarantee Request Form with a strict 

timetable for the IC to make decisions (10 working days); and   

27 In the case of the SME window, the EFSI contribution cannot be disentangled from the first loss piece 
provided by other EU financial instruments (e.g., COSME, InnovFin, EaSI and CCS). 

30 

 
 
                                                 
  The  Steering  Board  enabling  open  and  transparent  discussions  between  the  EIB 
and  EC.  The  advantages  of  a  small  group  were  evident  in  this  respect,  even  if 
there  was  some  (unsubstantiated)  criticism  that  the  Steering  Board  consisted  of 
the EIB and EC only (plus one observer from the European Parliament). 

Transparency  of  the  scoreboard  was  seen  as  a  positive  development.  Although  it  is 
unclear to what extent the scoreboards were widely accessed and used, the publication of 
scoreboards  improved  perceptions  of  transparency  and  was  generally  appreciated  by  a 
wide  range  of  stakeholders.  Overall,  there  was  consensus  among  stakeholders 
interviewed as part of the external evaluation that transparency efforts bring added value 
as long as (i) they do not burden the final beneficiaries, intermediaries, or implementing 
partners and (ii) they do not negatively impact time to market of the EFSI support. 

4.1.1.3  Coherence of the EFSI and the EU Guarantee 

Internal coherence of the IPE 

There were limited linkages between the three components of the IPE subject to this 
evaluation  (EFSI,  EIAH  and  EIPP).  Expectations  as  to  the  Hub’s  role  in  pipeline 
generation increased with EFSI 2.0 enhancements.  It  was not  the case  for the EIPP  for 
which it was not monitored whether EIPP projects get financing from the EFSI given that 
this was not an objective of the Regulation. 

Complementarity between the EFSI and other relevant EU interventions 
(e.g., CEF28, Horizon 2020 and ESIF) 

Following the launch of the EFSI, some of the existing EU financial instruments had to 
be re-configured to avoid overlaps. In particular: 

  Following  the  launch  of  the  Expansion  and  Growth  Window  under  the  EFSI 
Equity  instrument,  the  Equity  Facility  for  Growth  (EFG)  was  refocused  to 
prioritise  funds  investing  in  COSME  third  countries  participating  in  the 
programme; 

  The InnovFin Delegation Agreement was amended various times, among other, to 
provide financing to higher-risk thematic products (on infectious diseases and on 
energy demonstration projects, as well as investment platforms); and 

  The  Connecting  Europe  Facility  Debt  Instrument  (CEF-DI)  Delegation 
Agreement was amended in June 2019 to focus on green innovative investments, 
ensure complementarity with the EFSI and to allow for the absorption of the NER 
300 programme.29 

28 Connecting Europe Facility. 

29 The  NER 300 is an  EU  funding programme pooling together about EUR 2 billion for  innovative  low-
carbon energy demonstration projects. 

31 

 
 
 
                                                 
The  co-existence  of  existing  mandates  under  the  SMEW,  each  with  its  own  rule  book, 
created  operational  challenges,  particularly  for  (smaller)  financial  intermediaries.  The 
combination  of  the  EFSI  with  the  ESIF  (structural  funds)  was  a  key  challenge,  as  the 
regulatory  environment  remained  not  conducive  to  such  combination.  Yet,  the  EFSI 
combination  product  (with  the  EAFRD)  eventually  proved  successful,  despite  being 
utilised  only  in  few  cases,  as  it  was  introduced  with  the  Omnibus  Regulation.  It  has 
helped the creation of much larger portfolios of guaranteed loans and the achievement of 
a very high leverage effect for financial instruments under shared management, such as 
in France (region Nouvelle-Aquitaine), or has helped the setting up of an instrument in a 
situation where the demand for financing has been very high, like in Portugal.  

  How did the EU intervention make a difference? 
4.1.2.1  EU added value of the EFSI and the EU Guarantee 
The EU added value of the EFSI was significant and wide-ranging. Apart from the scale 
of financing made available by the EU guarantee, the following aspects constituted key 
elements of the EU added value of the EFSI: 

  Financing of multi-country operations – such operations received EUR 11 billion 

of EFSI financing; 

  Helping  move  international  cooperation  ahead  e.g.,  European  Securitisation 

Initiative;  

  Provided  a  proof  of  concept  for  budgetary  guarantees  as  a  tool  for  mobilising 

private investment efficiently and effectively; 

  Contributing to shifting mind-sets at the EU and national levels, e.g., in a  more 
joined-up  approach  within  the  Commission  with  several  policy  DGs  working 
together, or in changing perspective in favour of investment / SMEs; 

  Developing  institutional  capacities  within  NPBIs  to  implement  guarantee 

schemes and investment platforms; and 

  Developing  niche  products  such  as  venture  debt  and  addressing  gaps  in  niche/ 

under-served segments (e.g., agriculture, micro-finance, leasing). 

Moreover,  as  compared  to  national  promotional  schemes,  the  EFSI  allowed  for  more 
favourable conditions,30 including: 

1.  Better pricing conditions (e.g., free guarantees under COSME);  
2.  More modest co-financing requirements;  
3.  Higher guarantee rate; 
4.  Wider / less restrictive eligibility criteria (including e.g., agriculture or leasing, non-

bank intermediaries);  

5.  Design that ensured the State aid consistency of EFSI financing. No further State aid 
conditions  or  procedures  had  to  be  followed  by  EIB/beneficiaries  (no  need  of 
checking  limits  as  in  case  of  de  minimis  aid/  possibility  to  target  companies  that 
used up their de minimis limits); and 

30 However, this did not apply everywhere. See section on coherence. 

32 

 
 
                                                 
6.  Lower administrative requirements. 

The  EFSI  support  often  complemented  national  promotional  schemes.  In  Poland,  for 
example,  the  EFSI  addressed  niches  /  gaps  not  covered  by  national  schemes,  such  as 
assistance for start-ups, leasing transactions, and the agriculture sector. But there is also 
evidence of some competition between the EFSI and national promotional schemes. 

4.1.2.2  Additionality  of  the  EFSI  with  respect  to  other  EU  financial 

instruments 

Additionality with  respect  to  existing EU financial instruments  was reverse-engineered, 
addressing potential overlaps through frontloading (of COSME and InnovFin), topping-
up  (of  guarantee  products),  developing  a  bigger  equity  instrument  under  the  EFSI,  and 
developing  deal  allocation  policies  (to  manage  overlaps  with  the  CEF  Debt  instrument 
and  with  InnovFin  Debt  products).  There  were,  however,  some  clear  advantages  of  the 
EFSI  compared  to  existing  EU  financial  instruments.  For  example,  the  EFSI  budgetary 
guarantee freezes less budgetary resources compared to classical financial instruments, as 
it requires limited provisioning needs compared to the level of financial engagement. 

4.1.2.3  Additionality of the EU Guarantee 
At portfolio level, the EIBG would not have been able to  provide the same volumes of 
financing  targeting  higher  risk  projects  ˗  otherwise  often  unviable  ˗  without  the  EFSI 
guarantee. The EFSI IIW represents a fundamental shift in the nature of projects financed 
by the EIB. The EFSI projects are riskier, smaller than a standard EIB project and more 
complex (often with new clients, sub-investment grade borrowers or using more complex 
products  or  in  new  markets).  EFSI  operations  thus,  tend  to  be  costlier  to  implement 
(higher  costs  involved  in  deal  origination,  structuring  and  monitoring),  more  capital 
intensive  (due  to  their  higher  risk  profile)  and  less  profitable  in  terms  of  revenue 
generation (due to their smaller size). 

Factors contributing to the higher risk of the EFSI operations under the IIW 
On  the  basis  of  a  sample-based  review  of  the  IIW  operations,  the  most  common  risk 
factors  identified  were  as  follows:  (1)  financial  /  credit  risk;  (2)  market  risk;  and  (3) 
implementation  risk.  The  EIB  Evaluation  Division’s  evaluation  of  the  Group’s  Special 
Activities (70% of which are EFSI backed) further identified the following factors:  

  Higher  risk  profile  of  the  borrower.  The  special  activities  portfolio  has  a  much  higher  share  of 
non-investment  grade  borrowers  (68%)  in  terms  of  volume  as  compared  to  the  EIB’s  standard 
operations (13%) and 

  The unsecured and subordinated structure of the EIB financing.  

Financial / credit risk 
Financial / credit risk refers to the promoters’ ability to manage their debt and fulfil their 
financial obligations (repayment of principal and interest and any other fees and charges). 
Among the projects reviewed, a few were perceived to carry medium to high financial/ 
credit  risk  for  various  reasons,  including  uncertainty  around  cash  /  revenue  flows  and, 
hence, promoters’ ability to make repayments.  For example, a social housing project was 
assessed  to  be  financially  risky  as  repayment  of  the  EIB  loan  was  expected  to  rely 

33 

 
 
important  (medium/high).  Operations  aimed  at 

heavily on the cash flows generated from the lease of the units built by the promoters, in 
turn dependent on: (i) the demand for the new housing units; (ii) the long-term ability of 
tenants  to  pay  rent;  and  (iii)  the  capacity  of  the  promoters  to  keep  construction  and 
operational costs under control. 
Market risk 
Market  risk  is  the  risk  arising  from  changes  in  the  market  to  which  a  promoter  / 
beneficiary  organisation  has  exposure.  Market  risk  was  identified  in  the  context  of 
certain  operations.  It  was  generally  attributed  to  market  dynamics,  notably  the  level  of 
competition/ ease of market entry; demand/ product uptake; and price. For example, the 
extent  of  market  risk  associated  with  operations  in  the  telecommunications  sector  was 
generally  considered 
improving 
broadband access, for example, were exposed to market risk owing to the high degree of 
uncertainty around future demand/ take-up rates of new broadband solutions (especially 
among certain target groups – e.g., end-users in rural areas), and rigorous competition in 
the  broadband  market,  which  collectively  made  it  difficult  to  predict  future  revenue 
streams. 
Implementation risk 
Implementation risks were identified for certain operations. Risk factors commonly cited 
were  cost  overruns  and  delays.  Delays  were  foreseen  in  the  context  of  large-scale 
infrastructure  projects,  such  as  road  construction,  but  also  ‘green’  investments,  such  as 
those directed to the renewable energy sector – as such, the authorisation procedures for 
Photo-voltaic, solar and onshore wind projects and their effective connection to the grid 
are currently lengthy. Significant implementation risk was also foreseen in the context of 
an operation in the ICT sector (involving the rollout of Ultra High Speed fibre). Delays 
were  expected  due  to  the  country’s  complex  and  slow  permit  allocation  process,  and 
labour shortage. 

  Is the intervention still relevant? 

4.1.3.1  Relevance of the EFSI and the EU Guarantee 
In the context of the investment gap illustrated in section 2, the overarching objective of 
the IPE was to bring investment levels in the EU back on track. It aimed at tackling the 
three major issues that were holding back investment in Europe  — reduced capacity of 
investors  to  take  risk  following  the  financial  and  economic  crises,  lack  of  pipeline  of 
high-quality  investment  projects  and  non-financial  barriers  to  investment.  The  IPE  was 
structured around three pillars that corresponded to these issues, and described in section 
2 above. In particular, pillar one consisted of the EFSI, which was designed to mobilise 
public and private investments. The idea behind the EFSI was to enhance the risk-taking 
capacity of the EIB Group by providing an EU budgetary guarantee. 

Despite improving macroeconomic and financing conditions, the EFSI remained relevant 
throughout  2015-2021  as  new  policy  objectives,  investment  needs  and  market  gaps 
emerged. Therefore, in response to these new needs, policy developments and feedback 
(gathered  through  evaluations,  audits,  stakeholder  consultations  etc.),  the  EFSI  was 
constantly adapted (chiefly in the passage to EFSI 2.0). 

34 

 
 
 
Moreover, despite the achievements of EFSI, significant and persistent investment needs 
˗ triggered by the  Covid-19 pandemic and the  Russian  unprovoked and  unjustified  war 
against  Ukraine  ˗  remain  across  EU  that  require  further  public  intervention.  The 
successor  EU-level  investment  programme,  the  InvestEU,  will  continue  to  support 
investment  in  the  EU  where  there  are  market  failures  or  investment  gaps,  facilitating 
economic  recovery  in  line  with  the  EU’s  green  and  digital  priorities,  strengthening 
resilience,  stepping  up  sustainable  investment,  innovation  and  job  creation,  while 
ensuring wide geographical coverage of EU support. 

  The European Investment Advisory Hub 

The specific mandate of the EIAH, as per Article 14 of the EFSI Regulation, was to: 

  Be a single point of entry for advisory activities in the EU; 
  Support project promoters in developing their activities; 
  Support  the development  of  Public Private Partnerships (PPPs), use of  financial 
instruments, combination of EU funds, development of investment platforms and 
provision of capacity building for the public sector in these areas; and 

  Enable  peer-to-peer  exchanges  to  a  platform,  as  well  as  know-how  sharing  on 

project development. 

Demand-driven in nature, the EIAH services covered  all stages of the investment cycle 
and  were  intended  to  complement  existing  services.  With  the  EFSI  2.0  Regulation,  the 
EIAH  had  a  more  specific  mandate  to  support  the  EFSI  pipeline  and  contribute  to  its 
sectoral and geographical diversification. 

  To what extent was the intervention successful and why? 

4.2.1.1  Effectiveness of the EIAH 
In previous evaluations (EY, 201631; ICF, 201832), the risk that the EIAH services would 
potentially crowd out the private sector was noted. There has been no evidence that this 
has happened. When selecting projects, the EIAH does probe promoters on why EU level 
advisory is needed. Typically, the EIAH will provide services with EU added value that 
would not be directly available from the market. 

The EIAH as a single entry point for advisory services in the EU 

The  EIAH  functioned  effectively  as  an  entry  point  for  advisory  services.  The  EIAH 
website acted as a good access point with 15,000 to 16,000 unique visitors each year, and 

31  EY  (2016),  Ad-hoc  audit  of  the  application  of  the  Regulation  2015/1017  (the  EFSI  Regulation),  Final 
Report, 14 November. 

32 ICF (2018), Independent Evaluation of the EFSI Regulation, Final Report, June. 

35 

 
 
    
                                                 
requests  systematically  exceeding  milestones  (Figure  5  and  the  first  evaluations  (EY, 
201633;  EIB  EV,  201834))  had  concluded  that  when  the  EIAH  received  requests,  it 
systematically  assessed  whether  these  could  be  covered  by  the  EIAH  as  well  as  other 
existing programmes and signposted the beneficiaries to the most appropriate support. 

Figure 5: Number of projects for which advisory support has been requested 

Source: ICF based on EFSI Programme Statement (Draft Budget 2023).  
Note:  the  target  of  200  was  defined  ex-ante  in  2015,  by  the  European  Commission,  and  has  not  been 
revised during the EIAH implementation period 

The EIAH’s impact on investment generation 

Over time, with the EFSI 2.0 Regulation, the role of the EIAH in pipeline generation for 
the EFSI increasingly became a key area of focus. However, it is challenging to capture 
the impacts of certain types of advisory activities, as these occur after a considerable time 
lag.  

As of end-2021, the EIAH supported 217 project-specific direct assignments expected to 
mobilise EUR 30 billion of investment.35 Moreover the EIAH impact through the Light 
Projects Advisory (LPA) support, which is by nature very specific and comes late in the 
investment  cycle,  is  also  to  be  noted.  By  this  indicator,  by  end-2021,  8%  of  LPAs  had 

33 Ibidem 

34 EIB Operations Evaluation (2018), Evaluation of the European Fund for Strategic Investments, June.  

35 Examples include strategic advisory support  to one promoter in Italy in the delivery of school projects 
(PPP), or technical advisory support to the municipality of Athens on the restoration and energy efficiency 
of historical buildings and on the construction of public spaces. 

36 

 
 
 
 
                                                 
turned  into  projects  entering  the  EIB  or  EFSI  pipeline.  This  is  not  particularly  high 
(compared  to  a  rate  of  conversion  of  60%  for  the  EIAH  project-specific  direct 
assignments), but given the LPAs’ overall number of assignments (approx. 1,450 vs 217 
EIAH  project-specific  direct  assignments),  LPA-related  projects  represent  40%  of  the 
EIAH-supported projects that entered the EIB or EFSI pipeline. 

Finally,  it  should  also  be  noted  that,  according  to  the  EIAH  beneficiaries,  advisory 
activities  typically  improved  the  quality  of  supported  projects  (e.g.,  by  reducing  their 
environmental impact) and/or contributed to smoother implementation. 

The EIAH’s contribution to supporting the EFSI pipeline as well as sectoral 
and geographical diversification of the EFSI 

There  were  several  factors  that  limited  the  possibilities  for  the  EIAH  to  generate  a 
substantial  pipeline  of  projects  for  EFSI  financing.  These  include  the  demand-driven 
nature  of  the  EIAH,  the  eligibility  constraints  due  to  the  higher  risk  profile  of  EFSI-
supported  projects,  and  the  need  for  significant  upstream  project  advisory  and  capacity 
building advisory that delivers pipeline building activity over a longer time horizon than 
the period covered under this evaluation. Despite these limitations, the EIAH was able to 
ensure  that  60%  of  the  project-specific,  EIAH  direct  assignments  were  successful  in 
obtaining either EFSI or EIB financing (classified as standard lending operations) and are 
expected to mobilise EUR 72.9 billion of investment36. 

The EIAH’s efforts to widen the geographic coverage of the EFSI have delivered some 
results, as projects from cohesion countries are comparatively more present in the group 
of projects  supported by the  EIAH  compared to  the EFSI-supported projects in  general 
(44% vs 23%). 

Geographic outreach of the EIAH services 

The  EIAH  provides  more  value  added  in  Member  States  where  local  technical  and 
functional  capacity  gaps  persist,  notably  in  cohesion  Member  States.  Seven  cohesion 
Member States appear in the top ten EIAH beneficiaries. This pattern is to a large extent 
driven by the high number of small-sized EBRD assignments delivered under the EIAH 
umbrella  in  four  cohesion  countries  covered  under  the  “Advice  for  Small  Businesses 
Programme".  Overall,  for  the  assignments  managed  directly  by  the  EIAH,  advisory 
support  was  rather  well  balanced  across  Europe,  with  all  Member  States  (MS)  being 
reached and 54% of the assignments taking place in cohesion countries. The geographic 
distribution of other types of assignments is more mixed. 

Sectoral outreach of the EIAH services 

36 EIAH (2021), Technical and Financial Report. 

37 

 
 
                                                 
Most of the EIAH assignments (82%) related to the higher priority sectors identified in 
the 2016 market gap analysis, i.e., SMEs and small mid-caps, environment and resource 
efficiency, transport and energy; other sectors were less well served. To some extent, this 
was to be expected, as investments in these other sectors are of a nature that can hardly 
benefit from advisory services (e.g., ICT investments driven by large corporations that do 
not require public support to access advisory services). 

With EFSI 2.0, there was an expectation that the following sectors would be better served 
by  the  EIAH:  climate  change,  circular  economy,  digital  and/or  cross-border  projects. 
Overall, the data confirms  that climate change is a well addressed theme (all ELENA37 
assignments receiving also EIAH support  and 31% of the  EIAH  direct  assignments are 
somehow related to this issue). Awareness-raising activities were completed on circular 
economy  financing  options,  and  more  recently,  the  EIAH,  the  EIB  Group  and  the 
European  Commission  collectively  agreed  to  create  the  ‘Circular  City  Centre’,  a 
competence and resource centre within the EIB. On digitalisation, on top of the project-
specific support delivered,  the Hub also launched a market  study on the  role of Digital 
Innovation  Hubs  and  the  Digital  Innovation  and  Scale-up  Initiative,  to  the  benefit  of 
countries  in  Central  and  Eastern  Europe.  Other,  more  targeted,  themes  were,  however, 
more  marginally  addressed  by  the  EIAH,  in  terms  of  number  of  direct  assignments 
completed. For instance, in the social areas, the Hub realised the following services:  

  Social  Enterprises (FR),  developing  the  business  model  and  investment 

readiness of a consortium of social enterprises in France. 

  Swedish  Social  Impact  Bond  (SIB)  Assessment  Study, preparing  a  feasibility 
study  for  the  implementation  of  a  Social  Impact  Bond  scheme  for  occupational 
wellness aiming to improve mental health and reduce absenteeism from work. 
  Health  infrastructure  projects  (RO),  providing  both  expertise  and  funding  to 
support the preparation of three health infrastructure projects in underserved areas 
in Romania. 

Contribution to developing new partnerships 

To  reach  regions  where  needs  are  greatest,  the  EIAH  sought  to  establish  partnerships, 
notably with NPBIs. Furthermore, the EIAH hired a permanent advisor located in Sofia 
and  to  some  extent  relied  on  cooperation  with  the  EIB  Advisory  Services  which  have 
regional  offices  (e.g.,  JASPERS38  has  experts  in  Bucharest,  Vienna,  Brussels,  Warsaw 
and Sofia).  

As  part  of  the  cooperation  platform  with  NPBIs,  the  EIAH  supported  partner  NPBIs’ 
advisory programmes through funding agreements under an EIAH call for proposals. On 

37 European Local ENergy Assistance. 

38 Joint Assistance to Support Projects in European Regions. 

38 

 
 
                                                 
the side of the EBRD, the EIAH financed, since 2017,  about 70% of the total costs for 
the  implementation  of  the  EBRD  Advice  for  Small  Businesses  Programme.  Overall, 
cooperation with NPBIs and other  International Financial Institutions was initially slow 
to  set  up  (due  to  several  factors,  including  legal  complexity  and  NPBIs’  varying 
willingness and capacity to cooperate), but once established, the cooperation was able to 
deliver results. 

Investment platforms 

As of end-2021, the EIAH had undertaken 35 investment platform-related assignments, 
in  16  different  countries.  The  country  case  study  from  Bulgaria  confirms  the  EIAH 
involvement  was  crucial  when  setting  up  new  Urban  Development  Funds  (UDFs),  to 
adequately  design 
financial 
intermediaries. 

to  enable  selection  of  well-suited 

tendering 

the 

4.2.1.2   Efficiency of the EIAH 

Adequacy of budgetary allocation 

Over the period under consideration, the deployment of the EIAH activity has not been 
constrained by budgetary considerations. On the contrary, earlier evaluations highlighted 
that  in  its  first  years,  during  the  ramp  up  phase,  the  EIAH  underspent  its  budgetary 
allocations. One of the identified reasons has been the type of requests received, and the 
relatively large number of requests with no potential to lead to actual assignments (ECA, 
202039). Secondly, contrary to expectations, setting up the EIAH itself and then building 
an  external  network  of  partners  was  more  time  intensive  than  resource  intensive  (EC 
replies in ECA, 2020). To adjust to the rather long ramp up phase, the termination date of 
all  SGAs  has  been  pushed  back.  Over  time,  with  the  ramp-up  of  EIAH’s  activity, 
consumption  of  resources  also  picked  up:  as  at  31  December  2021,  the  actual  eligible 
costs  of  EIAH  attributable  to  the  EU  budget  for  the  period  2015-2021  were  EUR  73 
million, or 69% of the amounts available from the EU budget (vs 26% as at 31 December 
2018). Since three SGAs are still running, projections on whether or not the  EIAH will 
spend all the budgetary allocation are only tentative. 

Pricing policy 

The EFSI Regulation provided that cost sharing arrangements be put in place, with some 
exceptions  (services  provided  to  public  project  promoters  were  meant  to  be  free  of 
charge) and safeguard conditions (SMEs should not be charged more than a third of the 
cost  of  the  technical  assistance  provided  to  them).  While  the  exception  for  public 
promoters  was  key  for  them  to  enter  into  the  process  of  seeking  advisory  support  (as 

39  European  Court  of  Auditors  (2020),  The  European  Investment  Advisory  Hub  -  Launched  to  boost 
investment in the EU, the Hub’s impact remains limited, Special Report 12/2020. 

39 

 
 
                                                 
declared  in  country  case  interviews),  the  fee  created  barriers  to  access  the  services  for 
private  project  promoters  (they  only  represented  6%  of  Hub  beneficiaries  as  of  end-
2021). In 2018, the EIAH Coordination Committee however did relax the rules for LPAs: 
below  a  certain  project  size  (of  EUR  20,000),  it  became  possible  to  exempt  private 
entities  from  paying  fees  for  the  EIAH  services.  While  no  systematic  information  is 
available on the characteristics of LPAs’ beneficiaries, interest in LPAs did increase, and 
the  EIAH  team  confirmed  that  demand  for  LPAs  largely  emanates  from  the  private 
sector. 

Governance and reaction time 

As  foreseen  in  the  Framework  Partnership  Agreement  (FPA)  that  defines  the  general 
terms  and  conditions  that  apply  to  the  EIAH  Partnership,  an  EIAH  Coordination 
Committee  was  established.  The  Coordination  Committee  was  found  to  be  quite  agile, 
according  to  both  the  EC  and  the  EIB.  Annual  priority  areas  for  EIAH  activity  and 
corresponding budget available were defined in the SGAs.  

The  governance  model  was  efficient,  in  that  the  speed  of  response  and  service  when 
interacting  with  the  EIAH  was  considered  as  fast  or  very  fast  by  32  out  of  37  EIAH 
beneficiaries  that  completed  a  feedback  form.  Despite  the  very  quick  first  reaction, 
signature  of  the  actual  assignment  contract  can  take  months.  However,  the  EIAH  team 
and the beneficiaries interviewed as part of Country case studies both agree that the time 
which elapses is also useful to define more precisely the needs and type of support that is 
required.  It  also  includes  the  time  needed  to  get  approval  of  legal  documents  within 
public beneficiaries. 

Visibility and communication efforts 

A  lot  of  effort  was  made  to  improve  the  visibility  of  the  EIAH.  Relevant  actions 
included: 

  Development and continuous improvements to the EIAH website (with 15,000 to 

16,000 unique visitors each year); 
Increased social media presence on Twitter, Facebook, and LinkedIn; 

 
  Organisation  of  numerous  events  including  the  organisation  of  (i)  8  sessions  of 
the  annual  EIAH  Days  to  provide  for  knowledge  exchange  and  networking 
opportunities  for  NPBIs,  representatives  of  the  EC  and  the  EIB  and  (ii)  several 
rounds  of  local  EIAH  Roadshow  events  and  (iii)  physical  or  online  signing 
ceremonies  or  launch  events  e.g.,  when  the  Green  Eligibility  Checker  was 
launched in 2020; 

  The publication of promotional videos of assignment case studies (with 28 videos 

being available online as of mid-2022); and 

  Publication  of  reports  and  their  active  promotion  (with  e.g.,  short  video  of  EIB 
Director presenting the 2020 Annual Report being viewed almost 4 000 times). 

40 

 
 
Despite all the effort,  the  evaluation’s  country case studies  revealed that there was still 
insufficient awareness among relevant stakeholders about what the EIAH had to offer. 

4.2.1.3   Coherence of the EIAH 
The  EIAH  was  designed  as  an  entry  point  with  all  incoming  requests  centralised  and 
analysed  with  a  view  to  ensure  complementarity  with  existing  technical  assistance  and 
advisory  programmes  (such  as  JASPERS,  ELENA,  etc.)  and  to  avoid  duplication  of 
funding  and  work.  Stakeholder  interviews  confirm  that  these  complementarities  were 
realised  in  practice.  Concretely,  once  the  admissibility  of  the  requests  was  established, 
the  requests  were  reviewed  during  monthly  EIAH  screening  group  meetings,  aimed  to 
identify  any  requests  that  would  potentially  be  addressed  simultaneously  by  different 
services  within  the  EIB  and/or  the  EC.  In  addition  to  cross-referrals,  further  synergies 
were realised between the EIAH and other advisory  support services. For example, the 
EIAH intervened either upstream or downstream in the project development compared to 
other  EU  advisory  initiatives  to  facilitate  the  implementation  of  the  same  investment 
plans / projects. More importantly, while partners only engaged in project-specific work, 
the EIAH also provided non-project specific support (27% of the assignments). This type 
of  assignment  related  to  the  production  of  market  studies,  capacity  building  support  to 
administrations  (e.g.,  design  of 
tools  and  methodologies  for  assessing  project 
applications), and design of investment platforms. 

  How did the EU intervention make a difference? 

4.2.2.1  EU Added Value of the EIAH 
To  deliver  its  advisory  projects,  the  EIAH  often  brings  together  a  team  of  experts 
including  EIB  experts  and  also  typically  external  consultants  from  the  private  sector, 
thereby  providing  beneficiaries  with  a  unique  combination  of  expertise.  Indeed,  the 
EIAH  team,  like  EIB  experts  in  general,  are  seen  as  best  placed  to  advise  on  EU 
impact 
regulatory  requirements  (such  as  cost  benefit  analysis,  environmental 
assessments,  compliance  with  EU  taxonomy  etc.),  also  due  to  their  pan-EU  coverage 
which  enables  best  practice  sharing.  Similarly,  the  level  of  expertise  provided  by  the 
EIAH  services  is  highly,  or  very  highly  valued  by  beneficiaries,  as  testified  by  their 
feedback  forms.  According  to  interviews  conducted  as  part  of  this  evaluation,  other 
advisory services were available but the same levels of expertise or the same quality were 
not often readily available from other institutions. 

  Is the intervention still relevant? 

4.2.3.1   Relevance of the EIAH 
The establishment of an Advisory Hub was one of the key actions identified by the Task 
Force  in  2013,  to  ensure  a  continuous  and  effective  advisory  service.  The  two-phase 
market gap analysis studies, launched by the EIAH and carried out by PwC in 2016 and 

41 

 
 
2017,40 also confirmed the existence of needs that the EIAH could contribute to address. 
Indeed,  demand  for  the  EIAH  services  has  been  satisfactorily  high  from  all  Member 
States,  significantly  exceeding  initial  projections  every  year.  The  evaluation  confirms 
that  the  EIAH  progressively  developed  and  delivered  all  expected  services  and 
supporting activities, including project specific work, capacity building activities, market 
analysis, awareness raising activities, development of partnerships.  

In an effort to deploy more support to specific regions and reach out more effectively to 
those most in need, the EIAH also developed networks and collaborations. In light of the 
high  number  of  requests  received,  supply,  as  measured  by  the  actual  number  of 
assignments performed, was more moderate. This is however also partly an indicator of 
success  as,  by  design,  the  EIAH  is  not  meant  to  cover  on  its  own  all  the  requests 
received, but rather to function as a single-entry point for promoters seeking advisory and 
a large part of its work is to redirect requests to other, better suited services. Beyond the 
high  demand  /  take-up  for  the  services  provided,  feedback  forms  confirmed  that  the 
support  was  highly  relevant.  The  relevance  of  the  support  for  meeting  the  stated 
objectives is largely assessed as positive. The EIAH fully met needs of the beneficiaries 
in 31 cases (out of 37) and all beneficiaries were either satisfied or very satisfied with the 
support received. 

  The European Investment Project Portal 

The EIPP’s main role was to address two key market challenges identified at EU-level at 
the launch of the IPE:  

  The  need  to  improve  transparency  and  visibility  of  investment  opportunities 
available  within  the  EU  to  investors  worldwide,  and  relatedly  a  need  for  a 
pipeline of EU investment projects; and  

  The need to  increase  and  facilitate  the nature of contacts between investors and 

promoters. 

The  next  subsections  examine  how  these  challenges  were  addressed,  through  the 
evaluation  criteria  based  on  a  triangulation  of  evidence  collected  via  interviews,  desk 
research, EIPP annual surveys and feedback included primarily in the eight country case 
studies. 

40 EIB (2016) Market Gap Analysis for Advisory Services under the European Investment Advisory Hub 
(EIAH). Available at: 
https://advisory.eib.org/publications/attachments/Market_gap_analysis_for_the_advisory_services_under_t
he_European_Investment_Advisory_Hub_EIAH.pdf  

EIB  (2017),  Market  Gap  Analysis  for  Advisory  Services  under  the  European  Investment  Advisory  Hub 
(EIAH)  –  Phase  II.  Available  at:  https://advisory.eib.org/publications/attachments/market-gap-analysis-
advisory-smes-phase-ii-en.pdf  

42 

 
 
                                                 
  To what extent was the intervention successful and why? 

4.3.1.1  Effectiveness of the EIPP 
The  EIPP  has  contributed  to  improving  the  visibility  of  available  investment 
projects in the EU among the global investor community. As shown in Figures 6 and 
7 below, as of end-2021 the number of projects registered to the EIPP (1,112) exceeded 
targets (500), and the number of EIPP visitors has continued to grow over time (260,000 
in 2021). There is, however, limited awareness of the EIPP beyond policy makers, NPBIs 
and/or active users, as evidenced by the majority of the case study countries. 

Figure 6: Number of projects uploaded to the EIPP against milestones 

Figure 7: Number of visitors to the EIPP website over time 

Source:  EC  EIPP  KPIs  and  KMIs.  Week  1:  06.-12.06.2016  -  Week  254:  12-18.04.2021.  Data  based  on 
number of unique visitors for which the cumulative was calculated by the EC.  

43 

 
 
 
 
From  the  investors’  point  of  view,  the  projects  listed  on  the  EIPP  do  not  always 
meet  their  target  profile.  For  instance,  several  interviewees  mentioned  that  the  high 
proportion of early-stage investments present on the EIPP meant that it was more useful 
for Venture Capital investors and smaller projects. The EIB and NPBIs on the other hand 
typically have direct  channels  of communication with  project  promoters  and hence, the 
EIPP is of limited use for them as a source of pipeline generation. But some indicative 
evidence suggests that the EIPP is now starting to deliver in terms of matching projects 
with  investors.  In  fact,  despite  the  initial  difficulties,  the  number  of  contacts  between 
investors and projects are growing. 

The  direct  users  of  the  Portal  are  generally  satisfied  with  the  user  experience,  as 
shown in in all survey rounds. This is also thanks to the matchmaking events, which have 
witnessed an increasing proportion of investors attending. 

4.3.1.2  Efficiency of the EIPP 
As the benefits slowly start to materialise, the economic justification of the EIPP is 
improving.  The  overall  budget  allocated  to  EIPP  is  EUR  2.7  million  over  5  years. 
Budgetary resources funded several key activities performed by the EIPP, including: 

  Communication activities, including the delivery of matchmaking and networking 

events; 
 
IT development of the EIPP website and platform; and 
  Screening of projects submitted for publication to the portal. 

The  EIPP  was  generally  always  able  to  work  within  its  budget  allocations,  though  in 
some  years  there  was  some  under-spend.  Despite  the  costly  nature  of  maintaining  and 
animating  such  a  platform,  evidence  suggests  that  process  efficiency  of  the  EIPP 
increased over time. The removal of the charge to promoters for publishing projects may 
have harmed overall efficiency in terms of costs, but increased the relevance of the EIPP, 
as commented above. 

4.3.1.3  Coherence of the EIPP 

Internal coherence   

Internal  coherence  in  the  context  of  the  EIPP  centres  around  the  extent  to  which  there 
were opportunities for the portal  to  develop  synergies  and complement the work of  the 
EFSI  and the EIAH.  However, as  already mentioned, there was no expectation  that  the 
EIPP  would  feed  the  EFSI  pipeline,  and  the  EIPP  team  did  not  receive  information 
regarding whether, or the extent to which projects published on the EIPP were supported 
by the EFSI. 

External coherence   

External coherence in the context of the EIPP refers to the extent to which the EIPP was 
able  to  identify  and  develop  mutual  cooperation  agreements  with  similar  EU  and 

44 

 
 
national-level initiatives amongst Member States. The 2018 interim evaluation found that 
where  there  were  initiatives  that  slightly  overlapped  with  the  Portal,  these  were 
effectively identified. Cooperation agreements  were signed to  ensure the exploration of 
synergies in many cases (e.g., with EuroQuity or the Global Infrastructure Hub), though 
it  was  also  suggested  that  synergies  could  be  further  explored  in  others.  Evidence 
collected  as  part  of  the  external  ex-post  evaluation  suggests  that  this  finding  was 
sustained throughout this evaluation period. 

  How did the EU intervention make a difference? 

4.3.2.1  EU Added Value of the EIPP 
Given its mandate, the EIPP surpassed expectations in its role of proactively animating 
the  platform,  supporting  projects  in  achieving  financing,  delivering  events,  and 
developing  partnerships  to  insert  itself  more  effectively  in  the  investor  community. 
However,  there  is  mixed  evidence  regarding  the  comparative  advantage  of  the  EIPP 
relative  to  other,  similar  initiatives.  Feedback  from  interviews  and  case  studies 
highlighted that some benefits of the EIPP, relative to similar initiatives, were related to: 

  The vetting of projects; 
  The structure and quality of matchmaking and deal flows; 
  The EU coverage; 
  The neutrality; 
  The fact that it is free of charge; 
  The fact that it provides the option to participate in online pitching, networking, 

and matchmaking activities; and  

  The EIPP newsletter. 

Nonetheless,  evidence  gathered  suggested  that  other,  similar  initiatives  benefitted  from 
comparative  advantages  relative  to  the  EIPP  (for  example,  EuroQuity  or  the  European 
Innovation Council (EIC) Community Platform had more functionality compared to the 
EIPP). In fact, feedback from the country case studies highlighted that there is scope to 
improve  the  added  value  of  the  EIPP,  e.g.,  by  focusing  on  further  animating  the  EIPP, 
and ensuring it is well inserted into the ecosystem and connected with similar platforms 
and networking partners. 

  Is the intervention still relevant? 

4.3.3.1   Relevance of the EIPP 
Shortly  after  its  launch,  the  EIPP  had  generated  a  relatively  high  number  of  visits, 
contacts between promoters and investors, and events across Member States. Since then, 
interest in the EIPP has grown, as shown by the increasing number of visitors to the EIPP 
website. Moreover, the progress achieved in terms of the number of projects uploaded to 
the  EIPP  had  surpassed  milestone  expectations  by  2018,  and  this  trend  continues, 
showing that the EIPP is answering a general need for more transparency of investment 
opportunities  in  the  EU  and  is  therefore  more  and  more  relevant.  Indeed,  the  changes 
introduced in  2017 (lowering the minimum  project  size and making publication free of 

45 

 
 
charge  to  all  project  promoters)  were  considered  as  positive  and  beneficial  to  the 
relevance of the EIPP. 

In fact, the EIPP has provided a platform on which projects from across all 27 MS and 
the United Kingdom have been promoted, though relatively more projects were received 
and published from some Member States (such as Germany, Greece, Spain, France, and 
Italy) as well as the UK until 2020. Likewise, the EIPP has also served as a platform for 
projects  across  a  wide  range  of  sectors,  the  largest  being  the  digital  economy  sector, 
followed by social, infrastructure and tourism. 

User  feedback  suggests  that  the  EIPP  is  relatively  easy  to  use,  although  there  is  some 
scope for improvement, in terms of additional information on the projects. 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED 

  Conclusions 

  The European Fund for Strategic Investments and the EU guarantee 

The EFSI played an important role in accelerating and incentivising investment in 
the  EU  and  by  doing  so,  contributed  to  reducing  the  investment  gap.  As  of  31 
December  2021,  EUR  99.3  billion  of  EFSI  financing  had  been  approved,  expected  to 
mobilise EUR 524.3  billion of private and public investment over the period 2015-2021 
(this  investment  will  actually  be  spread  over  a  longer  period),  thereby  exceeding  the 
target of unlocking additional investment of at least EUR 500 billion. In terms of sheer 
volume,  EFSI  mobilised  investment  accounted  for  a  significant  share  of  the  cyclical 
investment gap during this period. And although some findings indicate that several EFSI 
financed  operations  could  have  plausibly  occurred  without  the  EFSI,  the  investments 
would have taken place at a reduced scale, on less favourable conditions and at a slower 
pace. Hence, in absence of EFSI, it would have taken longer to address EU’s investment 
gap and the low-investment spell would have been prolonged. The EFSI also supported 
investment activity indirectly, by shifting the focus of the policy attention and resources 
on investment at a national level (e.g., in the Italian case). 

The EFSI was particularly successful in crowding-in private sector financing. 72% 
of  the  investment  mobilised  by  the  EFSI  is  expected  to  come  from  private  sources. 
Private investment was incentivised by offering features that were not available to project 
promoters from alternative sources of finance (private or public). These included: higher 
scale  of  EIBG  financing;  lower  interest  rates  /  cost  compared  to  prevailing  market 
interest  rates;  flexible  conditions;  longer  tenors;  tailored  financing  solutions  including 
subordinated  positions;  technical  and  legal  due  diligence;  quality  stamp  /  reputational 
benefits; and stability of financing. According to some stakeholders, the EFSI might have 
also  crowded-out  private  or  NPBI  finance  in  a  few  instances,  but  this  is  difficult  to 
substantiate. 

46 

 
 
The  EU  guarantee  enabled  the  EIB  Group  to  take  more  risk.  While  examples  of 
operations  can  be  found  which  could  have  been  delivered  without  the  EFSI,  the  EIB 
Group would not have been able to finance the entire EFSI portfolio on its balance sheet 
in  absence  of  the  EU  guarantee  without  adversely  affecting  its  credit  rating,  capital 
consumption and financial sustainability. 

Thanks to the EU guarantee, the EIB Group was able to address a range of market 
failures  and  sub-optimal  investment  situations  across  geographies  and  thematic 
areas.  At  a  geographic  level,  the  distribution  of  EFSI  financing  was  well  aligned  with 
country-level  investment  gaps.  This  geographical  spread is  notable, taking into account 
the demand-driven nature of EFSI and the different state of Member States’ economies. 
Generally, countries that received a higher share of EFSI financing relative to their GDP 
share were also the countries with some of the highest investment gaps (e.g., Spain and 
Greece)  or  lower  levels  of  investment  relative  to  other  Member  States  (e.g.,  Bulgaria). 
But  there  are  some  exceptions.  The  market-driven  nature  of  the  instrument,  the 
dynamism of the respective economies and financing absorption capacity etc., affect the 
take-up of the instrument. In terms of thematic focus, EFSI financing was well targeted 
to  areas  where  the  private  sector  is  less  likely  to  invest  on  its  own  e.g.,  supporting 
investment  in  new/  unproven  technologies;  financing  large,  complex  projects;  and 
investing in social objectives and public goods. 

Hundreds  of  thousands  of  businesses  across  Europe  have  benefitted  from  EFSI 
financing.  While much of the EFSI support was focused on start-ups, micro enterprises 
and  SMEs  in  general,  EFSI  financing  was  also  used  to  address  the  financing  needs  of 
mid-caps not able to get financing on suitable terms from the market. Additionally, EFSI 
contributed  to  addressing  the  needs  of  under-served  /  niche  segments  such  as  social 
enterprises,  innovative  businesses,  and  businesses  in  specific  segments  such  as 
agriculture and culture and creative industries.  The  EFSI  resulted not  only in  improved 
availability of finance for these businesses, but also better conditions (e.g., lower interest 
rates, lower collateral requirements, longer repayment period and lower down-payments). 
The EFSI also contributed to diversifying the sources of finance available to businesses 
by supporting the development of equity, private debt and alternative finance markets. 

Overall,  the  macro-economic  impact  of  the  EFSI  is  expected  to  be  significant.  By 
2025,  the  EFSI  is  expected  to  create  2.1  million  jobs  and  increase  EU  GDP  by  2.4% 
compared to  the baseline scenario.  The EFSI will particularly benefit Cohesion  regions 
and crisis-affected countries in terms of job creation and growth.   

Other key achievements of the EFSI include: 

  Supporting  Europe’s  green  transition  by  financing  a  range  of  climate  action 
projects  (renewable  energy,  energy  efficiency,  low  carbon  technologies  etc.).  In 
fact, 44% of EFSI-IIW financing went to such projects. 

47 

 
 
  Alleviating the impact of the Covid-19 pandemic by enabling a quick and flexible 

response. 

  Channelling  private  capital  to  social  objectives  e.g.,  social  housing,  long  term 

 

care, and education. 
Improving the efficiency of public spending. The target multiplier effect (15) was 
exceeded  and  as  such,  the  EFSI  leveraged  a  critical  mass  of  resources  to  get 
investments off the ground. The EFSI also proved the efficiency and viability of a 
budgetary  guarantee  as  an  additional  policy  instrument  (on  top  of  grants  and 
classical EU financial instruments) to achieve policy objectives. 
Instigating  a  mind-shift  in  how  public  policy  is  delivered  e.g.,  more  joined-up 
approach and the use of budgetary guarantees to channel resources to policy aims. 
  Developing  cooperation  with  the  EIBG  and  national  promotional  banks  and 

 

institutions. 

Overall, the EFSI had a clear and demonstrable EU added value. The benefits of EU 
level action (as opposed to Member States acting alone) related to the financing of multi-
(e.g.,  European 
country  operations;  moving 
Securitisation  Initiative);    providing  a  proof  of  concept  for  budgetary  instruments  as  a 
tool for mobilising private investment efficiently and effectively; developing institutional 
capacities  within  NPBIs  to  implement  guarantee  schemes  and  investment  platforms; 
piloting  and  scaling-up  of  niche  products  such  as  venture  debt  and  addressing  gaps  in 
niche/under-served segments (e.g., equity, agriculture, micro-finance, and leasing). 

international  cooperation 

forward 

A  de-risking  instrument  such  as  the  EFSI  was  relevant  at  its  launch  and  remains 
relevant  going  forward.  Europe  needs  large  amounts  of  investment  to  meet  its  policy 
objectives  and  address  societal  needs.  Both  the  public  and  private  sector  will  need  to 
significantly  step-up  investment  to  achieve  the  EU’s  structural  transformation  to  a 
carbon-neutral  and  digital  economy  as  well  as  strategic  autonomy  in  areas  such  as 
energy, semi-conductors, and artificial intelligence. The uncertainty created by Russia’s 
war of aggression against Ukraine, the energy crisis, and knock-on effects of the Covid-
19 pandemic will constrain investment  going forward.  In  this context, the public sector 
will need to take more risk to unlock private investment in critical areas.  The EFSI has 
demonstrated the value of (a) a budgetary-guarantee based instrument  and (b) EU-level 
action in tackling common problems. 

  The European Investment Advisory Hub  

The EIAH functioned effectively as an entry point for advisory services. The EIAH 
website acted as a good access point with 15,000 to 16,000 unique visitors each year, and 
the  first  evaluations  (EY,  201641;  EIB  EV,  201842)  had  concluded  that  when  the  EIAH 
received requests, it systematically assessed whether these could be covered by the EIAH 

41 Ibidem 

42 Ibidem 

48 

 
 
                                                 
services directly or other existing programmes and signposted beneficiaries to  the most 
appropriate support. 

The  EIAH  has  started  generating  a  pipeline  of  investible  projects.  Given  the 
limitations of available indicators, it remains challenging to comprehensively assess the 
EIAH contribution to investment generation. However, as time elapsed, it became clearer 
that the EIAH contributed actively to investment  generation in general  and to the EFSI 
pipeline  in  particular,  notably  through  the  provision  of  project-specific  advisory 
assignments as well as through the LPAs (last-mile advisory support). The EIAH efforts 
on  this  accentuated  once  this  became  a  clearer  priority  in  the  EFSI  2.0  Regulation  and 
focused inter alia on the setting up of investment platforms and on the cohesion countries 
to contribute to the geographical and sectoral diversification of the EFSI pipeline. 

For  the  accomplishment  of  its  mandate,  the  EIAH  managed  to  reconcile  different 
and to some extent conflicting priorities. On the one hand, it remained demand driven: 
it assessed all incoming requests for support and catered for all types of needs, including 
more  upstream  support.  On  the  other  hand,  it  undertook  awareness-raising  activities  to 
stimulate  high-quality  demand  for  and  improve  take-up  of  its  services.  It  remained 
additional  to  other  EU  advisory  services,  putting  in  place  adequate  processes  to  avoid 
overlaps / duplication of efforts (e.g., via monthly EIAH screening group meetings) and 
providing support only in those cases when such a support was not available through an 
existing advisory offer at EU level. 

The  EIAH  covered  adequately  all  countries  and  sectors,  directly  or  through  a 
network  of  external  partners  (e.g.,  EBRD  for  SME  support).  It  dedicated  specific 
efforts to reach cohesion countries who are the main recipients of the EIAH support (for 
EIAH  direct  assignments  and  EBRD  assignments).  The  use  of  funding  agreements  to 
build the advisory capacities of NPBIs in less developed markets, however, functioned to 
a  more  limited  extent,  while  NPBIs  from  more  developed  markets  absorbed  larger 
volumes of grant support. In theory, the EIAH services targeted both public and private 
sector projects, but given its pricing policy, its support was more attractive for the public 
sector. Private project promoters had to pay to access EIAH services and in that context 
were  better  served  by  other  existing  advisory  offers  (available  for  free,  like  InnovFin 
Advisory). 

The  EIAH  support  provided  EU  added  value.  Key  elements  of  EU  added  value 
included advice on EU regulatory requirements; sharing of best practice across Member 
States  while  still  considering  the  local  context  when  providing  hands-on,  practical 
support; credibility of the outputs with the EIAH / EIB / EU seal of approval; high level 
of  expertise.  A  differentiator  is  also  the  quality  assurance  /  peer-review  aspect  of  the 
work that is typically provided when EIB experts supervise and review the work of the 
external  service  providers  that  are  hired  on  EIAH  assignments.  As  such  there  is  no 
obvious alternative that would be equivalent to the EIAH support, even if advisory offers 
exist on the marketplace. 

49 

 
 
There  remains  a  need  for  EU  level  advisory  services  going  forward.  Despite  the 
existence of a supply of advisory services on many markets, issues of availability, access 
and  affordability  of  advisory  services,  pointed  by  previous  market  gap  analyses,  are 
likely  to  persist  going  forward.  Needs  and  demands  for  advisory  services  are  in  fact 
expected to increase as InvestEU has become more thematically oriented and given the 
need to accompany the green and digital transitions. With all EU advisory initiatives now 
under  one  roof,  the  InvestEU  Advisory  Hub  will  have  the  potential  to  fully  act  as  the 
central and unique entry point for any advisory and technical assistance requests. 

  The European Investment Project Portal 

The  EIPP  has  contributed  to  improving  the  visibility  of  published  investment 
projects. Generally, the EIPP has made good progress towards its goal of improving the 
visibility of published investment projects in the EU amongst investors globally.  

Expectations  were  surpassed,  although  there  were  few  concrete  targets  set  for  the 
EIPP  and  therefore  broader  impacts  of  the  EIPP  are  hard  to  measure.  Given  its 
mandate  and  its  budget,  the  EIPP  often  surpassed  expectations  in  terms  of  its  role  by 
proactively animating the platform, supporting projects in achieving financing, delivering 
events,  and  developing  partnerships  to  insert  itself  more  effectively  in  the  investor 
community. However, it is important to note that there were relatively few expectations 
or  concrete  targets  set  for  the  EIPP,  particularly  regarding  its  ability  to  generate 
investments. 

The  EU  added  value  of  the  EIPP  was  somewhat  limited  but  improved  over  time 
thanks  to  the  EIPP’s  proactivity  and  partnerships.  In  practice,  the  EIPP  faced 
challenges  in  embedding  itself  within  the  investor  ecosystem  (e.g.,  related  to  scam 
investor contacts, the types of projects made available on the EIPP) which hampered its 
ability  to  make  fast  progress  in  generating  meaningful  contacts.  Though  this  improved 
over time, these challenges affected perceptions of the  EIPP, fostering some scepticism 
from the perspective of both investors and project promoters. 

The relevance and usefulness of the EIPP could be improved by enabling the EIPP 
to  further  distinguish  itself.  In  fact,  there  exist  several  other,  similar  initiatives  to  the 
EIPP, some of which have advantages relative to the EIPP and thus compete for the time 
and attention of investors. This highlights how critical the user-friendliness of the EIPP is 
in ensuring its relevance. But generally, direct users of the EIPP are satisfied with their 
user experience.  

50 

 
 
  Lessons learned 

Based  on  the  implementation  of  the  EFSI,  the  EIAH  and  the  EIPP,  some  key  lessons 
have already been identified and taken over for the InvestEU programme43, the new EU-
level investment support programme for the current MFF period (2021-2027): 

  Maintaining an EU-level scheme like the IPE for supporting investment is useful 
from  a  macroeconomic  point  of  view,  as  it  helps  foster  sustainable  growth  and 
create jobs both in the short and in the long run. 

  Agility and flexibility were key to the success of the EFSI (e.g., the possibility of 
developing and testing new types of financial products, introducing measures to 
enable a quick response during Covid-19, demand-driven nature of the instrument 
etc.). All these factors contributed to a high level of relevance and effectiveness. 
This flexibility needs to be maintained going forward. 

  As pioneered by the EFSI, the InvestEU brings in even more simplification to the 
plethora  of  EU  financing  support  tools,  by  pulling  together  under  a  single 
umbrella the EFSI budgetary guarantee, 13 financial instruments and 12 advisory 
initiatives.  

  While the emphasis on volume is justified during downturns and crisis situations, 
the  focus  should  be  more  explicitly  on  ‘policy  return’  during  normal  times 
(targeting projects or sectors with a clear policy impact and strong additionality). 
Based  on  the  IPE  experience,  the  InvestEU  contains  a  clearer  definition  of 
additionality, as set out in Annex V of the InvestEU Regulation, and of mobilised 
investment.  Moreover,  the  InvestEU  includes  a  very  comprehensive  list  of 
performance  and  monitoring  indicators,  as  set  out  in  Annex  III  of  the  InvestEU 
Regulation. 

  Some  types  of  projects  (e.g.,  public  sector  projects  of  the  municipalities, 
sustainable infrastructure, social infrastructure, and social economy) remained too 
small for the EIB intervention under the EFSI. In this context, the opening of the 
EU guarantee to new implementing partners is welcome as this will also enable a 
better outreach of the EU guarantee and provide a local presence. The InvestEU 
Advisory Hub and investment platforms would also have a role to play. 

  The  market-driven  nature  of  the  EFSI  means  that  it  is  designed  to  respond  to 
demand. Given the nature and scale of investment needs faced in the EU and the 
highly  thematic  nature  of  the  InvestEU  Fund  (the  successor  to  the  EFSI), 
proactive  and  concerted  efforts  will  be  required  to  support  pipeline  generation 
and to channel private capital to areas of policy impact. 

  Related to the above, while the provision of advisory services should be demand 
driven, it should also take into account the policy priorities. There is also a need 
to  stimulate  and  shape  the  demand  along  clear  thematic  policy  priorities  (e.g., 
green and digital transition). 

  The  IPE  has  pioneered  ways  to  balance  several  trade-offs,  which  should  be 

pursued and improved in future financing programmes: 

43 Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing 
the InvestEU Programme and amending Regulation (EU) 2015/1017. 

51 

 
 
                                                 
o  On  the  one  hand,  the  EFSI  exceeded  its  target  for  financing  of  climate 
action. On the other hand, the EFSI also financed projects with  potential 
environmental  externalities,  notably  when  these  addressed  sub-optimal 
investment  situations  in  specific  regions  or  countries.  The  twin  goals  of 
climate neutrality and economic growth  can be  mutually reinforcing, but 
there are also situations where these two goals are hard to reconcile, and 
setting a climate floor to the investment is one way to address them. 

o  Balancing risk taking with policy impact is another aspect that needs to be 
taken  into  account.  The  level  of  risk  taking  needs  to  be  commensurate 
with the provisioning level prescribed in the underlying regulation. In the 
case  of  the  EFSI,  the  level  of  around  a  third  operations  with  investment 
grade  borrowers  supports  a  balanced  portfolio  and  is  a  precondition  for 
the  choice  of  the  provisioning  rate.  This  implies  that  financing  from  an 
EFSI finance project cannot be 100% sub-investment grade. 

o  In  the  case  of  advisory  services,  there  needs  to  be  a  balance  between 
thematic support and horizontal/cross-sectoral advisory support services. 

  Efforts  should  be  made  to  reach  out  to  all  geographies  and  sectors,  including 
those outside the EIB´s  core  areas of  expertise.  Under the EIAH, this was done 
exclusively  via  a  network  of  external  partners  through  the  EIB  contracting 
procedures. Under the InvestEU Advisory Hub, there is the additional possibility 
to  contract  other partners directly, for up to  25% of the budget  share. However, 
the pool of potential direct advisory partners is likely to remain limited, given the 
difficulties  experienced  in  deploying  funding  agreements  for  the  provision  of 
local  advisory  services  by  NPBIs  under  the  EIAH.  The  efforts  to  increase  the 
advisory capacities of the NPBIs through the InvestEU Advisory Hub will need to 
continue, to ensure that all geographies and sectors are reached (within the limits 
imposed  by  the  legal  mandates  of  certain  NPBIs).  The  InvestEU  Advisory  Hub 
has already incorporated some important features: 

o  The  EIAH’s  one-stop  shop  principle  for  advisory  support  to  mitigate 
duplication  and  overlapping  initiatives  and  to  simplify  and  facilitate 
access  to  advisory  support  through  the  creation  of  a  central  entry  point; 
and 

o  The  opening  to  several  advisory  partners  to  facilitate  the  local  outreach, 
coupled  with  the  signature  of  a  single  agreement  per  advisory  partner  to 
avoid internal competition between the different advisory offers financed 
by several EU resources. 

  The EIPP needs flexibility and responsiveness to feedback in order to continue to 
stay  relevant  to  both  project  promoters  and  investors  in  such  a  changing  and 
diverse  context  whilst  ensuring  alignment  with  the  wider  policy  goals. 
Considering  the  overall  functioning  of  the  platform,  perceptions  can  play  a 
relatively important role in affecting the success of this intervention. Scepticism 
regarding  the  quality  of  the  EIPP  projects  or  the  usefulness  of  the  EIPP  in 
generating  meaningful  contacts  between  investors  and  promoters  can  jeopardise 
momentum and interest in the initiative. 

  Clear direction is needed regarding the importance of and focus on the EIPP as a 
key  pillar  within  the  wider  programme  going  forward.  There  is  a  need  for,  and 
interest  in  a tool such as the EIPP. Setting  more  stretching  and fixed targets,  or 
focussing  instead  on  leveraging  existing  portals/platforms,  may  help  generate 

52 

 
 
momentum  and  therefore  greater  value  for  money  in  terms  of  the  investment 
made into the EIPP. The InvestEU Portal should be the provider of a direct link to 
the InvestEU implementing partners that will be required to examine the projects 
falling under their geographical area and activity scope. Likewise, to establish a 
closer link to the InvestEU Advisory Hub, projects in need for advisory support 
can  be  directed  to  an  existing  advisory  initiative  implemented  by  any  of  the 
InvestEU advisory partners.  

53 

 
 
ANNEX I. PROCEDURAL INFORMATION 

This  evaluation  was  carried  out  by  the  Directorate-General  for  Economic  and 
Financial  Affairs  (ECFIN)  as  an  initiative  published  in  Decide  with  the  reference 
number PLAN/2021/10462 . 

The timeframe for the evaluation was as descripted in Table I.1: 

Table I.1: Organisation and timing  

Publication of the roadmap and feedback period 
An interservice steering group (ISSG) was set 
up  
Request for services for the external study to 
underpin the evaluation launched 
Signature of the contract for the study with ICF 
SA (in consortium with ICF CSL) 
Last deliverable handed in 
Number of steering group meetings 
Discussion of the draft staff working document 
Participating DGs (in addition to DG ECFIN) 
and implementing partners 

April 2021 

December 2021 

March 2022 

October 2022 
5 
October 2022 
BUDG: Budget  
GROW: Internal Market, Industry, 
Entrepreneurship and SMEs 
EISMEA: Small and Medium-sized 
Enterprises 
EMPL: Employment, Social Affairs 
and Inclusion  
ENER: Energy  
CNECT: Communication Networks, 
Content and Technology 
MOVE: Mobility and Transport  
SG: Secretary General 
EIB: implementing partner  
EIF: implementing partner 

The evaluation was based on two main sources of information: 

1.  A  study  carried  out  by  an  external  team  of  experts,  under  contract 
(ECFIN/067/2022)  through  DG  EMPL’s  Multiple  Framework  Contract 
EMPL/2020/OP/0016 
the 
implementation of the Better Regulation Guidelines; and  

the  provision  of  services 

related 

for 

to 

2.  The twelve-week open public consultation, carried out and analysed with the 

assistance of the external team of experts. 

The quality of the final report of the external contractor was assessed as good by the 
interservice steering group. The final report can be found in DG ECFIN’s website. 

54 

 
 
 
 
 
The conclusions and findings of the external evaluation are considered to be robust, 
as described in section 5 of this report. 

The  external  evaluation  was  carried  out  by  a  team  of  experts,  who  performed  the 
evaluation tasks as described in Figure I.1 

Figure I.1 Evaluation team 

The evaluation team’s fields of expertise are detailed in Table I.2: 

Table I.2: List of the key evaluation experts 

Evaluation tasks  

Experts  

Field of expertise  

Team Leader 
Key researcher  
(Transversal tasks and 
cross-country analysis) 
Project manager Country 

Charu Wilkinson 
Juliette Mathis 

Research 
Research 

Facundo Herrera 

Employment, social affairs, 

55 

 
 
 
 
lead Spain 

Thematic Expert and 
Country lead Germany 

Matthias Kollatz 

inclusion and evaluation, 
impact assessment and 
monitoring 
Advisor (promotional 
banking) 

Key researcher (Transversal 
tasks) Researcher Italy 

Diana Mori 

Research 

National Experts 

Employment, social affairs, 
inclusion and evaluation, 
impact assessment and 
monitoring 

Maciej Gajewski 
Jan Szczucki 
Svetoslav Danchev 
Georgios Gatopoulos 
Jonathan Lonsdale 
Jerome Kisielewicz 
Maurice van der Velden 
Gloria Uwingabiye 
Yann Verstraeten 
Ralitsa Donkova 
Janne Filet 

56 

 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

This  evaluation  was  carried  out  in  line  with  the  European  Commission’s  Better 
Regulation  Guidelines44.  This  section  describes  the  conceptual  framework  for  the 
evaluation and the methodologies used for data collection and analysis. 

Conceptual approach 

The  first  step  towards  developing  a  conceptual  framework  for  the  study  constituted 
drafting and refining a Theory of Change (ToC) model for  the EFSI, the EIAH and the 
EIPP (see Figure 4 in Section 2.2 of the main report). This model was based on the study 
team’s pre-existing knowledge of these interventions as well as ton he findings from the 
desk research and the scoping interviews conducted as part of the study’s inception phase 
(as discussed in more detail below). The ToC depicts how the activities delivered as part 
of these interventions intended to bring about the desired changes and therefore deliver 
specific results, outcomes and wider impacts.  

Based  on  this  underlying  programme  theory,  as  well  as  the  findings  from  the  scoping 
interviews  and  preparatory  desk  research  carried  out  during  the  inception  phase, 
evaluation  frameworks  for  each  component  were  developed  (see  Annex  3).  The 
evaluation frameworks set out the judgement criteria on which the evaluative conclusions 
would be based, the evidence (including quantitative and qualitative indicators) required 
to  answer  each  evaluation  question  and  the  methods  and  tools  that  would  be  used  to 
compile this evidence.  

Practical approach 

To  ensure  the  timely  delivery  of  a  high  quality  evaluation,  a  step-by-step  methodology 
(depicted  in  Figure  II.1  below)  was  developed.  It  offered  a  structured  and  systematic 
approach  to  the  evaluation,  setting  out  the  key  tasks  necessary  for  building  a  robust 
evidence base, interpreting the data collected and drawing final conclusions. 

44 European Commission (2021), Better Regulation Guidelines. Available at: 
https://ec.europa.eu/info/sites/default/files/swd2021_305_en.pdf  

57 

 
 
 
 
 
                                                 
Figure II.1: Step-by-step evaluation methodology 

Research methods 

Table II.1 below provides an overview of data collection/ research methods used as part 
of the evaluation.  A more in-depth  description of each of these methods  is  provided in 
subsequent sub-sections. 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table II.1: Overview of research methods used 

●●● Very important method for addressing the evaluation criterion 
●● Important method for addressing the evaluation criterion  
● Complementary method 

Literature review / desk research 

Desk research/ literature reviews were conducted in three main phases of the evaluation, 
including as part of the:  

 

Inception  phase:  where  the  study  team  consolidated  and  synthesised  relevant 
background documents regarding the EFSI;  

  Transversal  tasks,  where  relevant  public  and  non-public  literature  regarding  the 
EFSI as well as the context in which it operates was systematically compiled and 
analysed; and  

  Case  study  research,  where  researchers  researched  and  reviewed  documentation 

relevant to the country context (as described further below). 

The evaluation drew on literature from a wide range of sources, including academic and 
grey 
texts, 
programme-related  reports  and  other  documentation,  past  EC  and  other  independent 

information  reviewed  mainly  comprised: 

literature.  The 

legislative 

59 

Research method/ technique Key evaluation criteria Relevance Effectiveness Efficiency Coherence EU added value Literature review / desk research ●●● ●●● ● ●●● ●● Assessment of EU guarantee / adequacy of provisioning rate   ●●●    Portfolio analysis ●●●  ●●●  ●●●    Comparative analysis ● ● ● ● ● In-depth project reviews/ ‘deep dives’ ●●● ●●● ●● ●● ●●● Open Public Consultation (OPC) ●  ●  ●  ●  ●  Existing targeted surveys ●●● ●●● ● ● ●●● Interviews (EU level) ●●●  ●● ●● ●●●  ●●●  Country case studies ●●● ●●● ● ●● ●●●   
 
 
evaluations, targeted surveys, impact assessments, and external/ private research studies. 
Key sources of data / information reviewed are set out in more detail in Table II.2 below. 
The output from the analysis of relevant literature (past evaluations and wider literature) 
can be found in A4.8 and A4.9 of the ICF report.  

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table II.2: Desk review – main sources 

61 

Type Description   EFSI, EIAH, EIPP Legal basis   EFSI Regulation, EFSI 2.0 Regulation, InvestEU Regulation  Past evaluations  Past evaluations from ICF, the Commission, the EIB Evaluation department, and audits of the ECA  Reporting (public)  EFSI programme statements  EIB EFSI implementation reports EFSI specific  Additional official reporting (non public)   Operational reports  Risk reports  Unofficial reporting in Excel format EFSI governance-related documents   EFSI Agreement between the Commission and the EIB Group (and the six amendments and restatements of the Agreement)  Steering Board meetings minutes  Decisions and Rationales of the Investment Committee  Presentations made at Steering board meetings  Other  Guidelines i.e., documentation on estimation of multipliers1, Key Performance Indicators/ Key Monitoring Indicators2;   EC-EIB communication framework on EFSI   EIB RHOMOLO macroeconomic study on EFSI impact on growth and jobs EU Guarantee Reporting  Commission Staff Working Documents on the management of the Guarantee Fund of the European Fund for Strategic Investments and reporting on annual EU budget flows for the purpose of the analysis of the use of the EU Guarantee;  Other  DG ECFIN internal documentation related to the estimation of the provisioning rate                                            1 EIB, 2018. EFSI Multiplier Methodology Calculation - Update of July 2018. Available at: https://www.eib.org/attachments/strategies/efsi_steering_board_efsi_multiplier_methodology_calculation_en.pdf 2 EIB, 2015. Key Performance Indicators. Available at: http://www.eib.org/attachments/strategies/efsi_steering_board_kpi_kmi_methodology_en.pdf  
 
 
 
 
Detailed assessment of the EU guarantee / adequacy of provisioning rate 

It  was  agreed  with  the  ISSG  that  a  cost-benefit  analysis  (CBA)  –  which  would  have 
compared the net cost to the EU budget of the EFSI guarantee with the expected benefits 
– would have had major pitfalls: 

  Calculating the Net Present Value of the EFSI guarantee would be complex and 
subject  to  multiple  assumptions  and  forecasts  regarding  future  costs/losses  and 
revenue projections. 

  For debt-type operations, the EFSI Guarantee can be activated to cover guarantee 
calls,  restructuring  losses  and  recovery  costs.  For  equity-type  operations,  the 
EFSI Guarantee covers value adjustments, funding costs and recovery costs. The 
EC also pays fees to the EIF for management of the SMEW. The revenue stream 
is formed by the annual guarantee fees paid by the final beneficiaries as well as 
any  one-off  fees  e.g.,  during  the  appraisal  phase;  recoveries;  returns  on  equity 
operations  and  a  share  of  risk  pricing  on  debt  operations.  Under  the  EFSI 
Agreement,  the  EU  is  entitled  to  a  remuneration  for  its  guarantee.  As  such,  the 
risk-related  revenues are shared between the EU and the EIB (commensurate to 
the risk taken). 

  The  EIB  and  EIF  teams  confirmed  that  they  will  not  be  able  to  provide 

projections on losses or revenues. 

In  that  context,  a  detailed  assessment  of  the  adequacy  of  the EFSI  provisioning  rate 
was  conducted  instead.  Essentially,  this  evaluated,  using  good  proxy-models  at  the 
situation end of 2019, end of 2020 and end of 2021: 

  How  and  to  what  extent  the  modelling  worked  when  the  EFSI  developed  and 

reached its full volume; and 

  To  what  extent  this  can  be  projected  for  the  future  years  in  the  framework  of  a 

simplified model. 

Details  regarding  the  methodology  employed  to  conduct  this  analysis,  as  well  as  its 
findings, are found in Annex IV.  

Portfolio analysis 

The  portfolio  analysis  consisted  of  an  in-depth  review  of  the  key  characteristics  of  the 
EFSI portfolio, where relevant alongside key economic/financial indicators. The analysis 
covered  the  main  key  performance  indicators  (KPIs)  and  (other)  key  monitoring 
indicators (KMIs)45 of the EFSI programme. The analysis also aimed to add value to the 
operational  reporting already produced by the  EC  and EIB Group by  going beyond the 
KPIs/KMIs for a deeper and more insightful analysis. To do so, a “bottom-up” approach 
was adopted to the portfolio analysis. This included the following key steps: 

45 EIB (2015), KPIs, KMIs methodology. Available at: 
http://www.eib.org/attachments/strategies/efsi_steering_board_kpi_kmi_methodology_en.pdf  

62 

 
 
                                                 
1.  All  relevant  operational  and  risk  reports  produced  by  the  EIB,  EIF  and  DG 
ECFIN during the evaluation period (2015-2021) were received and compiled. 
2.  A  list  of  desired  metrics/indicators  and  analyses  (including  of  trends,  patterns, 
and relationships between indicators/variables e.g., breakdown by country/sector, 
relative to  GDP/investment) were compiled and agreed, based on the evaluation 
framework and available data. 

3.  To the extent possible, all relevant data at the operational level was compiled into 

a single dataset (this was done separately for the IIW and the SMEW). 

4.  Using  the  single  datasets  compiled  (for  the  IIW  and  the  SMEW),  additional, 
novel analyses were conducted which went beyond the KPIs/KMIs, for example 
by assessing different indicators or exploring evolutions over time. 

5.  Any  additional  data  required  (including  macroeconomic  or  financial  data  from 
publicly available sources and where relevant/necessary pre-made analysis tables 
available within operational reports) were requested and compiled. 

6.  Data  and  analyses  were  iteratively  sense-checked,  and  quality  assured  against 
other  data  sources  to  ensure  accuracy  (e.g.,  comparing  aggregate  figures  within 
reports and across the bottom-up analysis and operational report figures). Where 
required, discrepancies were checked with relevant data owners to ensure drivers 
for these could be explained. 

The study team adopted a collaborative and iterative approach to the portfolio analysis, 
working alongside the relevant teams within DG ECFIN, the EIB and the EIF to request, 
review,  analyse  and  quality  assure  data  and  analytical  outputs  to  ensure  consistency 
across  various  datasets,  sources  and  reports.  The  portfolio  analysis  drew  primarily  on 
operational  reports  received  from  DG  ECFIN,  the  EIB  and  the  EIF  respectively.  Data 
pertaining  to  investment  levels  and  other  economic  indicators  were  sourced  from 
Eurostat, the EIB Investment Survey (EIBIS) and the European Central Bank’s (ECB’s) 
survey on the access to finance of enterprises (SAFE).  

The indicators included within the final portfolio analysis are summarised in Table II.3 
below.

63 

 
 
Table II.3: Indicators and analyses included in the portfolio analysis

64 

High-level indicator Analysis conducted/compiled Financing approved  Value by country (IIW) Financing Signed  Number of projects signed and value of signatures by country, product, objective (IIW, SMEW, aggregate), relative to indicative limits   Value of financing signed as a % total (IIW, SMEW, aggregate), relative to indicative limits, by country  Value of financing signed as a % national GDP, by country  Average transaction size (IIW, SMEW), by country  Evolution of financing signed over time, by country (IIW, SMEW) Financing Disbursed  Value of EFSI disbursements by country, objective, product (IIW)  Disbursement rate (i.e., disbursement as a % signatures) by country Attrition/cancellations  Number and value of operations cancelled, withdrawn, closed (aggregate) Investments mobilised  Value of investments mobilised by country, objective and product (IIW, SMEW, aggregate)  Average annual investments mobilised, by country (IIW, SMEW, aggregate)  Investments mobilised as a % total (by country) (IIW, SMEW, aggregate)  Average annual investments mobilised as a % average annual investments (by country) (IIW, SMEW, aggregate)  Evolution of investments moblised over time, by country (IIW, SMEW) Private finance mobilised  Private finance mobilised by country (IIW, SMEW, aggregate)  Private finance mobilised by product (IIW, SMEW Debt)  Private finance mobilised by objective (IIW)  Share of investments that were private finance by country (IIW, SMEW, aggregate), product (IIW, SMEW Debt) and objective (IIW) Multipliers  External multipliers, by country and objective (IIW)  Internal and external multipliers by product and objective (IIW)  Internal and external multipliers by high-level product types (IIW, SMEW)  Internal and external multipliers by product (SMEW) Final beneficiaries  Number of SMEs supported, and value of financing received by country (SMEW)  Number of SMEWs supported, and value of financing received by product (SMEW Debt) Employment impact  Number of jobs supported by country (SMEW)  Jobs supported per EUR of EFSI financing signed, per EUR  
 
 
The analysis also considered the evolution and performance of the EIAH and  the EIPP. 
This was mainly based on data from the programme statements, as well as supplementary 
data provided by the relevant teams within the EC/EIB. As regards the EIAH, the number 
of requests for support was assessed. The analysis was also conducted at more granular 
level,  i.e.,  comparing  against  milestones,  breakdowns  by  type  of  support/  assistance 
sought  and  by  sector  and  country.  Other  key  indicators  included:  the  number  of 
assignments  performed,  their  nature;  the  EIAH-supported  projects  entering  the  EIB 
Group appraisal system; the profile of beneficiaries. In relation to the EIPP, the analysis 
spanned the number of submitted projects that were published on the Portal (including by 
sector, size, and country), the number of site visitors and the number of  contacts  made 
between investors and promoters via the Portal. 

Comparative analysis using ORBIS data 

A comparative analysis was undertaken, involving EU companies having received EFSI 
financing  (the  so-called  “treatment  group”)  versus  those  who  did  not  (the  “comparison 
group”). The detailed methodology for this analysis, as well as its findings, are set out in 
Annex VI.  

Within  this  analysis,  the  ‘treatment  group’  was  built  based  on  an  EIF  list  of  final 
beneficiaries  of  the  EFSI  SMEW  matched  to  the  Orbis  Database  (a  data  resource  on 
private  companies  across  the  globe).  A  total  of  3,269  firms  were  identified  (across 
Bulgaria,  Czechia,  France,  Greece,  Italy,  Latvia,  Poland  and  Spain).  To  create  a 
‘comparison group,’ a sample of firms that matched certain characteristics ((1) being EU-
based; (2) being small or medium in size; and (3) employing at most 250 employees) was 
randomly  selected  from  the  Orbis  Database.  On  the  basis  of  the  selection  criteria,  a 
random  sample of 20,000 companies was extracted to  match with  the 3,269 companies 
belonging to the ‘treatment group’.46 

A  comparative  analysis  between  the  two  groups  was  undertaken,  which  provided  an 
indication  of  the  profile  of  companies  –  notably  in  terms  of  age,  size,  and  innovation 
capacity –  among which EFSI financing was concentrated and differences in behaviour 
in  the  years  following  the  implementation  of  the EFSI.  Differences  were  assessed  with 
respect  to  several  indicators,  namely:  number  of  employees,  operating  revenue 
(turnover),  intangible  fixed  assets,  tangible  fixed  assets,  working  capital,  and  interest 
paid. 

46 When selecting a ‘comparison group,’ companies from all EU-27 Member States were considered (even 
if the ‘treatment group’ consisted of companies from a limited number of Member States only). 

65 

 
 
 
 
                                                 
Project ‘deep-dives’ 

An  in-depth  review  of  60  EFSI-backed  projects  was  undertaken.  Among  the  projects 
reviewed,  20  were  supported  through  the  SME  Window  (of  which  12  were  financed 
through  debt  and  8  through  equity)  and  41  through  the  Infrastructure  and  Innovation 
Window. Within  the sample of projects  supported by the  IIW,  14 operations fell under 
parent operations. Where this was the case, the study team reviewed the documentation 
pertaining to the parent operation. In some cases, operations selected fell under the same 
parent operation (10 of the operations). Where this occurred, the study team reviewed the 
parent  operation  documentation  only  once  (meaning  that  of  the  14  operations,  7 
documents were reviewed). 

The  sample  of  projects  concerned  spanned  eight  Member  States:  Bulgaria,  France, 
Germany,  Greece,  Italy,  Latvia,  Poland,  and  Spain  (those  that  were  selected  for  case 
studies, as described in detail below). The review drew on official documentation made 
available by the EC, the EIB and the EIF. Key information was extracted, including inter 
alia: 

  Profile of the beneficiary; 
  Basic/ core information pertaining to the operation and product; 
  Factors contributing to the risk of the operation; 
  Rationale for EFSI financing; 
  Evidence of market failures/ sub-optimal investment conditions; 
  Contribution  of 

the  EIB  Group  (extent  of:  financial  and  non-financial 

additionality; financial facilitation; crowding-in effect; and technical support); 
  What would have happened if the operation had not been financed by the EFSI; 
 
  Expected results/ impacts; and 
  Actual achievements. 

Investment mobilised and multiplier calculation; 

Additionally, 11 projects having benefited from the EIAH support underwent an in-depth 
review.  Core  project  information  was  extracted,  along  with  contextual  information  and 
information pertaining to the promoter and the nature/ scale/ duration of the support. This 
information was used in preparation for interviews and to feed into overall triangulation 
and analysis for the final report. 

Open Public Consultation (OPC) 

An  OPC  was  conducted  in  line  with  Better  Regulation  Requirements.  It  provided  an 
opportunity for stakeholders across the EU-27 Member States to provide their feedback 
and views on the EFSI, in terms of what it achieved and what could be done differently 
in  the  future.  Though  anyone  could  respond  to  the  OPC,  stakeholders  of  particular 
interest were identified as including: 

66 

 
 
  Member  State/  regional  representatives  (e.g.,  authorities  in  charge  of  economy/ 
infrastructure-related 

investment/  growth,  SMEs, 

innovation,  and 

finance, 
policies); 

  EU  level  and  national/  regional  business  or  industry  associations  (e.g.,  SMEs, 

financial sector representatives, public banks, investors); 

Investors and financial intermediaries;  

  SMEs or individual project promoters (having been involved with EFSI or not); 
 
  Representatives from the civil society (e.g., NGOs, social partners); 
  Think tanks, research organisations and academia; and 
 

Individual citizens. 

Drafting  of  the  OPC  questionnaire  was  led  by  the  study  team,  with  review  and  inputs 
provided  by  the  ISSG.  The  questionnaire  comprised  of  one  section  containing  general 
questions  for respondents with  limited knowledge of, and/  or no direct  experience with 
the EFSI, the EIAH and/or the EIPP; and two other sections with in-depth questions for: 
(i) respondents that were supported by the EFSI or used the EIAH or EIPP services; and 
(ii) respondents that indicated having an in-depth knowledge of the EFSI Regulation. 

The  OPC  was  launched  on  25  May  2022  on  the  European  Commission’s  open 
consultation  page.  It  ran  for  12  weeks,  in  accordance  with  the  ‘Better  Regulation 
Guidelines’ and closed on 17 August 2022 at midnight Brussels time. The key pillars of 
the dissemination strategy for the OPC included: 

  The use of relevant websites, newsletters and social media channels (by the EC, 
EASME,  EIB  /  EIF,  etc.;  and  by  ICF)  to  promote  the  OPC  to  specific 
communities – e.g., relevant, actively used LinkedIn Groups (such as EU FUNDS 
for SMEs group; Finance Helpdesk; and Infrastructure Finance Alumni); 

  Recruiting  multipliers  such  as  business  associations,  European  Enterprise 
Networks  and  relevant  national  contact  points  to  respond  to  and  promote  the 
OPC; and 

  Ensure  the  questionnaire  was  short,  simple  and  designed  in  plain  English,  with 
questions  relating  to  more  specific  and  technical  issues  being  explored  through 
stakeholder interviews. 

Despite the above efforts, the response rate to the OPC was relatively low, with a total of 
25  responses  received.  Responses  were  concentrated  among  private  companies,  public 
banks/  promotional  institutes  and  business/  industry  associations  primarily  located  in 
Belgium, Denmark, Finland, France, Germany, Hungary, Italy, Luxembourg, and Poland. 
Once the OPC was closed, the study team conducted a full analysis of the responses. The 
results  of  the  OPC  cannot  be  regarded  as  representative  due  to  the  limited  number  of 
responses received. An analysis of the responses to the consultation is provided in Annex 
A4.5 of the ICF report. 

67 

 
 
 
 
Existing targeted surveys 

Many  target  groups  (the  likes  of  IIW  project  promoters,  IIW  and  SMEW  financial 
intermediaries,  EIAH  beneficiaries)  have  already  been  subject  to  many  surveys  in  the 
context  of  past  EFSI  evaluations  and/  or  evaluations  of  EU  financial  instruments  more 
generally. Additionally, the European Commission currently undertakes an annual survey 
of  EIPP  project  promoters  and  investors.  The  Hub  has  been  collecting  feedback  (via 
dedicated feedback forms) from its beneficiaries since 2018. It has also been carrying out 
exercises meant to follow up on advisory assignments for which at least 12 months have 
elapsed since their completion. The aim is to see how the underlying investment project, 
where applicable, has evolved. 

Given this, and the associated risk of survey fatigue, the study team  and  ISSG decided 
early  on  that  no  additional/  new  surveys  would  be  carried  out  in  the  context  of  this 
present evaluation (to avoid placing an undue burden on stakeholders). Instead, the study 
team conducted an in-depth review of existing survey data available, including: 

  Annual  EC  EIPP  surveys  of  project  promoters  (2018,  2019  and  2021)  and 

investors (2019, 2021); and 

  Surveys conducted in 2018 as part of the ICF-led independent evaluation of the 
EFSI  Regulation  (including  of  project  promoters  and  financial  intermediaries 
under IIW, NPBIs and beneficiaries of EIAH assistance). 

In total, 472 survey responses (over three separate years) were analysed. The results are 
provided in Annex A4.5 of the ICF report. 

Interviews 

A total of 120 interviews were carried out as part of this study, in three different phases, 
as  part  of  the:  study  inception  phase  (scoping  interviews),  transversal  task  (in-depth 
interviews at the EU level) and country case studies. Once the interview programme was 
complete, the study team conducted a full analysis of the results. Results were extracted 
by  study  question  using  NVivo  to  facilitate  analysis.  A  summary  of  the  interview 
findings by stakeholder type is provided in the synopsis report in Annex V.  

Scoping interviews 

Nine  exploratory  interviews  were  carried  out  with  European  Commission  officials  (8) 
and  representatives  from  the  EIB  Group  (2  with  the  EIB  and  1  with  EIF)  during  the 
inception phase. These interviews were exploratory  in  nature, and  aimed at  obtaining a 
better  and  more  up-to-date  understanding  of  the  three  initiatives  (context,  main 
achievements, changes brought about by the EFSI 2.0 Regulation, details on the actions 
taken  in  more  recent  implementation  periods  in  response  to  the  recommendations 
contained in previous evaluations). Stakeholders were also asked about their expectations 
for the study, likely data gaps or obstacles to information access, and potential sources of 
evidence to consult. 

68 

 
 
In-depth interviews (EU level) 

24 in-depth interviews were carried out with stakeholders at the EU level, as summarised 
in Table II.4 below. 

Table II.4: Profile of interviewees – in-depth interviews 

These  interviews  provided  an  opportunity  to  obtain  more  detailed  and  contextualised 
views on specific aspects regarding the EFSI, the EIAH and/or the EIPP. Interview topic 
guides were developed to help guide discussions and shared with interviewees in advance 
of  the  call.  Topic  guides  were  tailored  to  the  relevant  target  audience,  drawing  on 
findings from the desk research and deep dives  conducted as  well as findings from  the 
inception  phase  of  the  study.  Generally,  discussions  focused  on  testing  the  underlying 
programme  theory  as  well  as:  (1)  the  relevance  of  the  three  initiatives;  (2)  the 
effectiveness  of  the  initiatives  in  achieving  their  objectives  and  supporting  wider  EU 
policy  goals;  (3)  the  internal  and  external  coherence  of  the  initiatives;  (4)  their  impact 
and added-value; and (5) lessons learned.  

Country case studies (including interviews) 

Eight  case  studies  were  undertaken  at  the  Member  State  level.  The  selected  Member 
States  were:  Bulgaria,  France,  Germany,  Greece,  Italy,  Latvia,  Poland,  and  Spain.  The 
proposed sample was purposefully selected to capture a variety of different contexts, and 
levels  of take-up of  the EFSI, as  well as  to  ensure an adequate portfolio coverage. The 

69 

Stakeholder type Number of interviews Commission (Including DG ENER, MOVE, GROW, EMPL, ECFIN, and REFORM) 9 EBRD 1 European Innovation Council and SMEs Executive Agency (EISMEA) 1 EIB Group 5 Banking Association 1 Investment Association 1 Investment Network 2 SME Association 3 NPB 1 Total 24   
 
 
 
selection  criteria  included:  (1)  geographical  coverage  (i.e.,  including  north,  south,  east 
and west); (2) local economic context (including selecting countries that were more and 
less affected by the financial crisis); (3) accession to the EU (‘old’ versus ‘new’ Member 
States); and (4) take-up  of the EFSI (in absolute and relative terms), the  EIAH and the 
EIPP. 

Figure II.2: Selected case study countries 

The purpose for conducting country case studies was multi-fold, including: 

  Understanding  the  take-up  of  the  different  initiatives  (EFSI-IIW,  EFSI-SMEW, 
EIAH  and  EIPP)  in  selected  Member  States  relative  to  investment  needs  and 
financing gaps, identifying all relevant factors affecting take-up; 

  Understanding  the  extent  of  complementarities  and  linkages  between  the  EFSI, 

the EIAH and the EIPP at the country level; 

  Testing  the  theory  of  change  in  different  national  contexts,  i.e.,  the  extent  to 
which the assumptions and causal mechanisms underpinning the ToC are valid in 
different national settings; 

  Understanding the more intangible effects of the initiatives, e.g., the non-financial 

added value of the EFSI; 

  Gathering  views  on  lessons  learned  that  could  be  applied  to  subsequent 

programmes, such as InvestEU. 

The  first  step  in  the  delivery  of  the  case  studies  was  the  development  of  a  case  study 
protocol. This set out in detail the methods, sources of information, research tools, case 
study report structure and detailed work plan that country researchers would draw upon 
and refer to throughout delivery. 

The case studies were based on both primary and secondary research, including: 

  Desk research:  The case studies drew on evidence  gathered as  part of the desk/ 
literature review and the project ‘deep dives’ conducted as part of the transversal 
tasks. To address any gaps, additional desk research was undertaken. Additional 
evidence  was  sourced  from  evaluations,  parliamentary  reports,  research 
publications  and  other  grey  literature  available  that  focussed  on  each  Member 
State.  Country  researchers  were  also  provided  with  individual  country-specific 
data  files  that  contained  relevant  portfolio,  macroeconomic  and  financial  data 

70 

 
 
 
analysis at the country level (including data from Eurostat and survey-based data 
e.g.,  from  EIBIS,  ECB  SAFE  etc.).  Where  EU  level  sources  of  information 
existed,  these  were  preferred,  in  an  effort  to  foster  harmonisation  and  limit 
comparability  issues  across  the  evidence  base.  EU  level  sources  of  information 
were  still  in  many  cases  complemented  by  national  sources  of  information  to 
capture  richer  evidence,  and  here  differences  in  information  available  or  data 
treatment were taken into account within the cross-case analysis. 

  An  interview  programme:  The  interview  programme  for  the  case  studies 
commenced  in  mid-June  and  finished  in  September  2022.  Country  researchers, 
supported by DG ECFIN and the EIB Group, identified relevant stakeholders to 
contact  in  line  with  specific  targets  per  stakeholder  profile.  Targeted  profiles 
included: national policy makers; national /regional promotional banks; business 
associations;  participating  financial  intermediaries;  non-participating  financial 
intermediaries;  public  and  private  project  promoters  (IIW  beneficiaries);  main 
banks and investors in IIW projects;  EIAH beneficiaries; investors registered on 
the EIPP;  project  promoters active on the EIPP;  and other relevant  stakeholders 
(e.g., parliamentarians, academics, authors, etc.). Where possible, interviews were 
conducted  with  promoters  associated  with  the  operations  /  EIAH  requests 
reviewed as part of the Deep Dives. Topic guides were prepared, tailored on the 
basis  of  data  gathered  from  the  desk  research  conducted,  and  shared  with 
interviewees  ahead  of  interviews  to  help  guide  conversations.  A  total  of  87 
interviews  were  conducted  across  the  selected  sample  of  Member  States.  On 
average,  in  each  Member  State,  10-15  interviews  were  undertaken.  Interviews 
were then written up in English and fed into the analysis of interviews conducted 
overall throughout the study (as discussed above). 

As  the  evidence-gathering  exercise  progressed,  the  evidence  was  reviewed  and 
summarised. Once the case study research had significantly progressed, a brainstorming 
session  was  organised  involving  all  country  researchers  to  allow  for  findings  to  be 
exchanged  across  the  team.  The  session  took  place  on  5  August  2022.  Initial  feedback 
ensued, which fed into finalised versions of the case study write-ups. Key findings were 
reported  via  individual  slide  decks  (which  constituted  case  study  write-ups)  for  each 
Member State. These are provided in full in Annex A4.2 of the ICF report. 

Notwithstanding  the  above  limitations,  the  overall  evidence  base  for  the  evaluation  is 
rather strong and robust. This is because: 

  The  evaluation  team  had  access  to  large  volumes  of  documentary  evidence  and 

factual data on the EFSI take-up, investment mobilised, etc. 

  The eight country case studies highlight key themes and processes which resonate 

across the broader portfolio.  

  The range of applied methods permitted multiple lines of inquiry and evidence to 

answer each evaluation question (triangulation).  

  The  evidence  emerging  from  the  different  sources  was  rather  consistent.

71 

 
 
ANNEX III. EVALUATION MATRIX AND DETAILS ON ANSWERS TO THE EVALUATION 
QUESTIONS (BY CRITERION) 

The evaluation matrix and relative key findings are presented below by instrument. 

EFSI / EU Guarantee 

Table III.1: Key findings for the EFSI by evaluation criteria 

Evaluation criteria / questions 

Key findings 

Relevance 

EQ1 To what extent has the design and 
implementation of the EFSI responded 
to the needs of the project promoters, 
financial intermediaries, and private 
investors?  

  JC 1.1 The product offer under 
EFSI was suitable i.e., the range 
of products deployed under EFSI 
(i) addressed market failures/ 
constraints that may inhibit or 
restrict private investment (ii) 
addressed the diversity of needs 
across sectors and EU Member 
States  

  JC 1.2 The allocation of 

resources between IIW and 
SMEW reflected needs  

  JC 1.3 There was demand for 
EFSI financing across sectors 
and countries 

A range of products were deployed and piloted under 
EFSI. These ranged from the ‘plain vanilla’ products 
(such as unsecured loans, portfolio guarantees) to more 
complex and sophisticated products e.g., mezzanine 
ABS, venture debt/ quasi-equity (IIW) to Private Credit, 
Equity instruments for specific sectors (AI & blockchain, 
Space, Blue Economy), ESCALAR, Private Credit etc. 

Under IIW, EFSI financing was well targeted to areas 
where the private sector is less likely to invest on its 
own.   

Under SMEW, products were designed to cover the 
needs of different types of enterprises (micro enterprises, 
SMEs, small mid-caps, social economy enterprises) and 
across different stages (pre-seed, seed/start-up, 
development and growth). The product mix included 
generalised as well as thematic products targeting 
specific segments or sectors (e.g., CCS, innovative 
businesses, agricultural businesses etc.) 

Generally speaking, no gaps were identified in the EFSI 
product offer. In some smaller Member States and 
sectors (e.g., social infrastructure), there was an issue 
relating to the size of projects being too small for EIBG 
financing.  Investment Platforms were created to address 
this issue. 

EFSI-backed operations addressed a range of market 
failures and sub-optimal investment situations e.g., 
market failures in SME financing or financing of certain 
types of businesses (e.g., CCS, social enterprises, start-
ups) or activities (e.g., RDI) 

All policy objectives and countries were covered by 

72 

 
 
 
EQ2 To what extent has the design and 
implementation of the EFSI instruments 
responded to the evolving market needs? 

  JC 2.1 There were processes in 
place for market sounding  

  JC 2.2 There was flexibility to 

make adjustments in response to 
evolving market conditions e.g., 
introduction of new products, 
budget re-allocations etc. 

  JC 2.3 There was room for 

market testing new approaches 
and products 

  JC 2.4 EFSI financing was 

allocated to sectors/ thematic 
areas with the greatest financing 
needs and gaps  (while balancing 
policy prioritisation and 
absorption capacity) 

EFSI financing, albeit to varying degrees – see EQ2 

There were processes in place for market sounding. The 
Steering Board was informed by three sources: 

  Market studies and feedback from the EIBG 
  Market  studies  and  stakeholder  consultations 
carried  out  directly  by  the  Commission  and 
internal  reflections  within 
the  Commission 
services 

  Request from Cabinet and the Council e.g., fund 

of fund initiative 

A key feature of EFSI was its agility and flexibility to 
changing circumstances and emerging needs. This was 
particularly evident during the Covid-19 pandemic 
response. 

Throughout EFSI implementation period, but in 
particular under EFSI 2.0, a range of products were 
developed to address specific needs and in response to 
lessons learned e.g., Investment Platform, NPB-equity, 
range of thematic products under SMEW. As can be 
expected, some products were more successful than 
others. 

All thematic areas were covered to varying levels, 
However, roughly three-quarters of the investment 
mobilised by EFSI was concentrated in three thematic 
areas (SME and mid-cap financing, RDI and energy). 
Overall it is hard to judge if this represents a balanced 
distribution of EFSI support or not for 3 reasons (i) the 
thematic areas are not entirely mutually exclusive; (ii) it 
is hard to assess scale of EFSI financing relative to 
investment needs per thematic areas as the definitions 
are not entirely consistent (iii) the relative weight of 
policy objectives has shifted overtime notwithstanding 
the estimated scale of investment needs 

Apart from a few exceptions, EFSI financing was well-
aligned with country-level investment gaps.  

EQ3 To what extent has each pillar of 
the scoreboard (Article 7(14) and Annex 
II of the EFSI 2.0 Regulation) been 
appropriate and relevant? 

  JC 3.1 The scoreboard is relevant 

There is general consensus among stakeholders that the 
publication of the scoreboard (for IIW) was a positive 
development. Although it is unclear to what extent the 
scoreboards were widely accessed and used, the 
publication of scoreboards improved perceptions of 
transparency and was generally appreciated by a wide 

73 

 
 
and balanced (pillars focus on 
the right parameters and the 
scoreboard adequately inform 
decision-making) 

  JC 3.2 Stakeholders regard the 
scoreboard as fair, transparent 
and useful 

  JC 3.3 The publication of the 
scoreboard has improved 
stakeholder perceptions of EFSI 

Effectiveness / additionality 

EQ 4a To what extent has the EFSI 
achieved its objectives, in particular the 
target of mobilising EUR 500 billion of 
total investment by 2020? 

  JC 4.1 EFSI has achieved or 

exceeded its target of mobilising 
EUR 500 billion of additional 
investment across the EU 

  JC 4.2 Applicable methodology 
has been used consistently and 
data for calculation are reliable 

EQ 4b What factors, even if unexpected 
or unintended, have driven or hindered 
progress and how are they linked (or 
not) to the EU intervention?  

EQ 5 To what extent has the sectoral and 
geographical distribution of EFSI 
investments been in line with the defined 
indicative limits? 

  JC 5.1 The sectoral and 

geographic distribution of EFSI 
financing are in line with the 
defined indicative limits 

  JC 5.2 Efforts were made to 

widen sectoral and geographic 
take-up of EFSI, particularly in 

range of stakeholders. 

EIB EV’s evaluation (published in 2021)47 found that 
transparency requirements contributed to a more positive 
perception of EFSI operations, with no significant 
drawbacks in terms of client relationships, or loss of 
efficiency in implementation due to additional requests 
for information from external stakeholders 

By the end of 2021, EUR 99.3 billion of EFSI financing 
had been approved. This financing is expected to 
mobilise EUR 524.3 billion of investment across Europe. 
Although signed volumes slightly lag behind approvals 
(due to the time lag between approvals and signatures as 
well as cancellation of some operations in 2021), EFSI 
appears to be on track to exceed the target of EUR 500 
billion of investment mobilised from operations signed 
by the end of 2022. 

Multiplier effect has been calculated in line with 
methodologies approved by the EFSI Steering Board. 
Care is taken to avoid double-counting. The 
methodology however, is not designed to (and cannot be 
expected to) address causality and attribution.  

EFSI is a demand driven instrument and there are no 
geographic or sectoral targets. The EFSI's investment 
guidelines simply require that excessive geographical 
concentration be avoided and the Strategic Orientation as 
elaborated by the EFSI Steering Board set out the limits 
for such concentrations under IIW: 

Geographic: the share of investment in any three 
Member States should not exceed 45% of the EFSI 
portfolio at the end of the investment period)48 

Sectoral: the volume of signatures in any “general 

47 EIB Operations Evaluation (2021), Evaluation of the European Fund for Strategic Investments, June. 

48 For SMEW, there are no precise indications. It mentions that “the EIF should aim at reaching all the EU 

Member States and achieve a satisfactory geographical diversification among them”. 

74 

 
 
 
 
                                                 
those sectors and Member States 
with the largest investment needs 
and gaps 

objective” as defined by Article 9 of the EFSI 
Regulation should not exceed 30% of the total volume of 
signatures at the end of the investment period 

At the end of 2021, the top three countries (France, 
Spain and Italy) accounted for 49.4% of the IIW 
portfolio. Efforts are being made to bring this in line 
with the indicative allocation by the end of the 
investment period in 2022 

The sectoral limits are being respected. Energy accounts 
for the largest share of EFSI financing under IIW 
portfolio. As of end-2021, it represented 24%, well 
below the indicative limit of 30% 

EQ 6 To what extent has the EFSI 
achieved its objectives in relation to the 
40% target under IIW to support project 
components that contribute to climate 
action? 

  JC 6.1 The climate action target 
has been achieved or exceeded 

  JC 6.2 EIB methodology for 
determining climate action 
financing is robust and in line 
with accepted standards 

EFSI delivered on its soft target of 40% financing for 
climate action under IIW. 59%of EFSI operations signed 
until the end of 2021 had a climate action component. 
This represented 44%of the signed EFSI-IIW volumes 

However, EFSI-IIW portfolio also contains projects with 
significant negative environmental externalities e.g., 
airports, road transport (addressing sub-optimal 
investment situations in specific regions or Member 
States) 

EIB uses credible definitions and methodologies to tag 
Climate Action (CA) components 

EQ 7 To what extent has the EFSI 
contributed to increased access to 
financing in the EU policy areas in line 
with the objectives listed in Article 9(2) 
of EFSI 2.0 Regulation? 

  JC 7.1 Access to finance has 
improved in areas defined in 
Article 9.2 and alignment of 
projects with EU policy 

  JC 7.2 The increase in access to 
financing can at least partly be 
attributed to EFSI   

All policy objectives have been covered, although to 
varying degrees. 

There is evidence to demonstrate additionality of EFSI 
financing: 

Input additionality: EFSI enabled EIBG to provide 
financing on better terms and conditions to projects and 
counterparts as compared to alternative sources. EFSI 
also provided non-financial inputs in the form of its 
technical expertise, due diligence standards and 
signalling effect. 

Investment additionality: many of the activities would 
have been delayed or taken place at a reduced scale in 
absence of EIBG financing 

Additionality is stronger in some areas than others both 
in terms of sectors and geographies. 

75 

 
 
Significant efforts were made under EFSI to facilitate 
cooperation and collaboration with NPBIs. 

High levels of NPBI involvement were achieved under 
EFSI. Overall, 262 EFSI operations (17.5%) were 
implemented in collaboration with NPBIs (representing 
20.5% of EFSI financing). There was greater 
collaboration under SMEW as compared to IIW  

60 investment platforms were set up in 18 Member 
States reflecting an important outreach effort. Under 
IIW, Investment platforms provided a mechanism for 
pooling and financing smaller operations. This was an 
important benefit of these platforms, but their set-up was 
extremely challenging for all parties concerned 

Under SMEW, the EIF did not always see a substantial 
value added from the setting up of platforms except for a 
few cases, where platforms were created at the request of 
NPBIs to attract additional national financing 

The heterogeneity of NPBIs made it difficult to set up a 
collaboration with them on a systematic basis. 
Consequently, collaboration was stronger in some 
countries than in others. 

In the short-term (by 2025), the EFSI is expected to 
create 2.1 million jobs and increase EU GDP by 2.4% 
compared to the baseline scenario 

By 2040, it is estimated that EFSI-supported operations 
will still have created 1.3 million jobs and increased EU 
GDP by 1.6%, relative to the baseline 

Key informants confirmed the usefulness of the 
scoreboard in facilitating decision-making. No issues 
were highlighted by decision makers. 

EQ 8 To what extent have the National 
Promotional Banks or Institutions and 
the Investment Platforms been 
instrumental to the achievement of the 
EFSI objectives? 

  JC 8.1 NPBs/NPIs and 

Investment platforms have been 
largely effective in stimulating 
project pipelines in target sectors 
and crowding-in of private 
lenders / investors 

  JC 8.2 The cooperation had a 

positive effect on geographic and 
sectoral distribution 

EQ 9 To what extent have the projects 
supported by the EFSI contributed to the 
creation of jobs and sustainable 
economic growth?  

EQ 10 To what extent has the use of the 
scoreboard (Article 7(4) and Annex II of 
the EFSI Regulation) been effective in 
ensuring an independent and transparent 
assessment of the possible use of the EU 
Guarantee by the Investment 
Committee? To what extent have the 
individual pillars contributed to the 
scoreboard's effectiveness? 

 

 JC 10.1 The scoreboard has 
been effective in aiding decision-
making 

76 

 
 
 
Efficiency 

EQ 11 What has been the relation 
between the resources used to implement 
the EFSI - and the activities undertaken, 
in view of the objectives? Did EFSI 
represent an efficient use of EU budget? 

  JC11.2 Allocative efficiency – 

EU budget was allocated in such 
a way as to produce a given level 
and quality of output at the 
lowest possible cost (cost 
minimisation) 

  JC 11.3 Dynamic efficiency – 

there were efficiency 
improvements overtime 

  JC 11.1 Technical efficiency –

under EFSI, quality and quantity 
of outputs were maximised for a 
given level of resources (output 
maximisation) 

EQ 12 What have been the leverage ratio 
and multiplier of the EFSI contribution, 
broken down by product?  

EFSI delivered a higher than expected multiplier effect 
(15.75 as compared to a target of 15) 

The impact of EFSI is expected to be budget-neutral at 
the very least. It is expected that in the end there might 
even be a positive surplus as (i) the level of losses that 
have materialised are lower than expected and (ii) the 
remuneration of risk taken by the EU guarantee has 
generated revenues 

The EU budget did not bear the full cost of 
implementation of EFSI. Some of these costs were 
absorbed by the EIB 

Provided in the form of a table in the main report 

EQ 13 To what extent have the 
governance structures put in place for 
EFSI IIW have been efficient in 
supporting its implementation? 

The governance structure that had been set-up for EFSI 
worked well. The evaluation did not find any evidence to 
suggest otherwise and this was also the perception of the 
stakeholders interviewed 

  JC 13.1 A two tier governance 
structure was appropriate for 
EFSI IIW 

  JC 13.2 Clear lines of 

responsibility and accountability 
were established 

  JC 13.3 The governance 

structure allowed for decision 
making autonomy 

  JC 13.4 Investment Committee 
members had no conflict of 
interest 

  JC 13.5 The governance 
structure did not cause, 
confusion, clashes of 
competences 

77 

 
 
 
 
EQ 14 To what extent have EFSI 
communication methods been efficiently 
used to engage stakeholders? 

  JC 14.1 There was a 

communication strategy in place 
setting our communication 
objectives, target audiences, 
intended outcomes etc. 

  JC 14.2 The communication 
strategy was implemented  

  JC 14.3 There is evidence of 
stakeholder engagement  

  There was coordination between the EC and EIB 
group on the communication aspects as foreseen 
within  the  EFSI  Regulation.  This  was  never 
communication 
formalised 
as 
agreement  but 
the  EFSI 
communication framework set out the following 
three objectives for communication: 
1.  Stakeholder 
communication 

a 
concrete 
article  3  of 

the 

on 

functioning of EFSI,  
to 

2.  Public  access 

performance of EFSI  

information  on 

the 

3.  Create  support  from  stakeholders  and  the 

general public 

/fliers/ 

broadened 

infographics/ 

  A  range  of  communication  tools  and  mediums 
were used by the EIB e.g., brochures / websites/ 
presentations 
project 
examples  or  descriptions/  pictures/videos.  EIB 
usually 
the 
also 
available/used  by  institutions  to  communicate 
e.g., 
these 
fringe 
using  VR, 
communication 
presented 
exhibitions  where 
products,  social  media  campaigns,  influencer 
videos). 

initiatives 
videos 
beneficiaries 

channels 

kinds 

(360 

of 

of 

  Focus 

communication 

from 
explaining  why  EFSI  is  and  how  it  works  to 
demonstrating the impacts of projects financed 
  Cooperation between EC and EIB worked well 

evolved 

Coherence 

EQ 15 To what extent have EFSI, EIAH 
and EIPP been coherent with other EU 
interventions (i.e. for EFSI, 
complementarity, potential synergies and 
/ or overlaps with the European 
Structural and Investment Funds, 
Connecting Europe Facility, Horizon 
2020, etc.) in terms of objectives, scope 
and activities?  

  JC 15.2 There was no direct 
competition between the 
different EU interventions 

EQ 16 To what extent have the actions 
of the EFSI Regulation (EFSI, EIAH, 
and EIPP) been internally coherent in 
terms of potential synergies in 
contributing to the achievement of the 
objectives of the Investment Plan for 

  Additionality  w.r.t.  centralised  instruments  was 

ensured by the design of EFSI  

  Front-loading of COSME and InnovFin 
  Topping-up  via  SLP  (COSME,  InnovFin,  EaSI, 

CCS) 

  Reducing  COSME  budget  for  equity;  creating  a 

bigger equity instrument under EFSI 

  Deal allocation policy to avoid overlaps between 
EFSI and CEF debt instrument and InnovFin 
  Overlaps  continued  to  exist  between  EFSI  and 
decentralized instruments particularly in the area 
of SME financing, yet due to significant demand 
no crowding out was noted 

  There  were  limited  linkages  between  the  three 
components of the IPE (EFSI, EIAH and EIPP). 
At  the  beginning,  there  was  no  expectation  that 
EIAH  or  EIPP  would  feed  EFSI  pipeline. 
Expectations  as  to  the  Hub’s  role  in  pipeline 
generation increased with EFSI 2.0.  See findings 

78 

 
 
 
Europe? 

for EIAH. 

  JC 16.1 There are feedback loops 
between EFSI and EIAH/ EIPP 

  JC 16.2 Evidence of EIAH 

feeding project pipeline for EFSI 
and Invest EU 

  JC 16.3 Evidence of EIAH 

contributing to widening the 
sectoral and geographic coverage 
of EFSI and Invest EU 

  JC 16.4 EIPP is contributing to 

fruition of investment 
opportunities 

EU Added Value 

EQ 17 To what extent has the EFSI, 
EIAH and EIPP support provided EU 
added value compared to what Member 
States acting on a national or regional 
level could reasonably achieve on their 
own? 

  JC 17.1 EFSI, EIAH and EIPP 
have features that distinguish 
them from other similar support 
available at national level 

  JC 17.2 There are clear benefits 
of EU level intervention e.g., 
economies of scale, efficiency 
gains, cross border dimension, 
larger partnerships, enhanced 
quality of projects etc.  

  Financing  of  multi-country  operations  –  such 
operations  received  EUR  11  billion  of  EFSI 
financing.  

  Helping  move  international  cooperation  ahead 

e.g. European Securitisation Initiative  

  Provided  a  proof  of  concept  for  budgetary 
guarantees  as  a  tool  for  mobilising  private 
investment efficiently and effectively 

  Contributing to shifting mind-sets at the EU and 

national levels 

  Developing institutional capacities within NPBIs 
to implement guarantee schemes and investment 
platforms 

  Developing specialised products such as venture 
debt and addressing gaps in thematic and under-
served segments (e.g., agriculture, micro-finance, 
leasing).  

Additionality of EFSI and EU guarantee 

EQ 18 To what extent have the projects 
and resulting portfolios for which the EU 
Guarantee was extended proved 
additional (in the sense of the EFSI 
Regulation, see footnote 8)?  

  JC 18.1 EFSI financed crowding 
in private investment in specific 
sectors or projects of high policy 
added value which suffer from 
persistent market failures 

  JC 18.2 EFSI financed projects 

have higher input additionality as 

  There is clear evidence of input additionality 
under both IIW and SMEW (lower cost of 
financing, better terms and conditions e.g., tenor, 
grace period, collateral requirements etc.) 

  There is also evidence of EFSI playing a role on 

crowding-in private investors. 88% of the 
investment mobilised is expected to come from 
private sources. Particularly in the case of equity, 
there are many examples of EIBG participation 
playing a role in attracting investors to the 
market or to a particular operation. 

  At the same time there is anecdotal evidence of 

79 

 
 
 
compared to standard operations 

  JC 18.3 EFSI financed projects 

would not have gone ahead at all 
or in the same form without 
EFSI support 

  JC 18.4 EIB Group would not 
have been able to finance these 
projects in absence of the EU 
guarantee in the same time 
period and to the same extent 
(concept of additionality as per 
EFSI Regulation) 

EFSI crowding-out private or NPBI financing. 
Although such examples are very limited and 
cannot be proven 

 

 

IIW: evidence suggests most projects / activities 
would have gone ahead even in absence of EFSI 
but only at a reduced scale, higher cost or slower 
pace. Consistency of findings from different 
sources (range of stakeholders interviewed, 
interviews versus past surveys, broader context – 
improving macroeconomic conditions and ample 
liquidity in the market). 

In case of SMEW: FIs would not have been able 
to lend to the same scale or take the same level 
of risk or offer the same financing conditions in 
absence of EFSI 

  The EIBG would not have been able to take the 
same level of risk in absence of EU guarantee – 
projects entail higher level of risk, are much 
smaller, more complex, with newer and lower 
rated counterparts – this would have had 
implications on capital consumption, profitability 
and overall financial sustainability of the EIB 

EQ 19 To what extent has the EFSI 
portfolio had a higher risk profile than 
the portfolio of investments supported 
by the EIB under its normal operations?  

  Special Activities (LG D- or below or equity/ 
equity type operations) represent 97.40% of 
EFSI financed operations and 94.56% of EFSI 
signed volumes 

  JC 19.1 EFSI portfolio has a 

higher risk profile than the EIB’s 
own risk portfolio 

EU Guarantee 

Table III.2: Key findings for EU Guarantee by evaluation criteria 

Evaluation criteria / questions 

Key findings 

Relevance 

EQ 1 To what extent has the EU Guarantee been 
used to respond to the identified needs? To what 
extent do the identified needs still exist? To what 
extent has the use of the scoreboard been relevant 
to assure an independent and transparent 
assessment of the use of the EU Guarantee? 

  JC 1.1 In absence of the EU guarantee, 
EIB Group’s risk-taking capacity would 

  The EU Guarantee was relevant for the 
EIB to take necessary risk without 
affecting its financial sustainability and 
AAA rating 

  The EIF has limited capital of its own and 
relies on resources from mandators. 
Without the EU guarantee, it would not 
have had the resources to carry out such 
activities on its balance sheet. 

80 

 
 
 
 
have been greatly reduced 

Effectiveness 

EQ 2 To what extent have the objectives of EU 
Guarantee been achieved? 

  JC 2.1 The EU Guarantee was effective in 
enhancing the risk-taking capacity of the 
EIB Group 

EQ3 To what extent has the EU guarantee been 
effectively used to cover the potential losses that 
the EIB Group may suffer from its EFSI 
supported investments under the IIW and 
SMEW? 

  JC 3.1 Current provisioning is adequate 

to cover potential losses over the lifetime 
of EFSI 

  JC 3.2 Provisioning is based on robust 

risk modelling approaches 

  JC 3.3 The procedure of modulation of 

the EU Guarantee remuneration referred 
to in Article 4(2)(a)(v) has been properly 
applied. 

Efficiency 

EQ4 To what extent have the financial resources 
provided to EFSI, namely the EU Guarantee (and 
its revenues) and Union support of combined 
financial instruments, been appropriately sized 
and used through risk sharing arrangements and 
for coverage of different costs to achieve its 
expected effects? 

  JC 4.1 The size of the guarantee balances 
affordability (EU budget available) with 

81 

  There is a clear difference in the profile 

of EFSI financed projects as compared to 
the EIB’s standard operations: 
  Much smaller in size: median size of 

EFSI financed operations (EUR 53m vs 
EUR 140 million for standard operations) 

  Riskier clients: higher share of sub-
investment grade and newer clients 
  Riskier projects by definition (LG of D- 

or below or equity/ equity type) 

  More diverse and complex set of products 
  Standard operations: sovereign/ sub-
sovereign and corporate lending 
  EFSI: a wide spectrum covering risk 
sharing instruments, capital market 
instruments,  venture debt/ quasi-equity, 
private debt, equity (Venture Capital 
/Private Equity) 

  The current provisioning rate is adequate  
  The level of around 1/3 operations with 
investment grade borrowers supports a 
balanced portfolio and is a precondition 
for the choice of the provisioning rate. By 
comparison to ‘grant programmes only’ 
the EU budget is spent with a large-scale 
guarantee programme and a number of 
financial instruments more efficiently. 
The robust provisioning supports the 
view that at the end there might be left-
overs from the provisioning. It could be 
recommended to increase the volume and 
outreach of successor programmes, if 
such outcome would materialise in the 
future. 

 

It freezes less budgetary resources 
compared to financial instruments, as it 
requires limited provisioning needs 
(35%) and assumes a contingent liability, 
thus generating a higher multiplier effect 
as compared to classical financial 
instruments 

  The assumed multiplier effect for EFSI 

has been surpassed (15.75 as compared to 
15) 

  EFSI budgetary guarantee has also 

 
 
 
 
 
proven more cost-efficient for the EU 
budget, as it is remunerated for the risk 
taken and it limits the payment of 
management fees to EIBG 

  See above and response to EFSI: EQ4a 

practical considerations such as 
absorption capacity  

  JC 4.2 The assumed multiplier effect of 

the EU Guarantee is plausible 

  JC 4.3 Risk sharing arrangements in each 

EFSI product are optimal 

  JC 4.4 The guarantee rate is adequate to 
enhance EIB/ EIF’s risk taking capacity 
without affecting their credit rating 

  JC 4.5 EIB own contribution is sufficient 

EQ5 What has been the leverage ratio and 
multiplier of the EU budget (i.e., EU guarantee + 
FI financed from Union budget)? 

  JC 5.1 The expected EFSI multiplier 
effect of 15 has been met or exceeded 

  JC 5.2 The underlying methodologies and 

calculations are reliable 

EIAH 

Table III.3: Key findings for the EIAH by evaluation criteria 

Evaluation criteria / questions 

Key findings 

Relevance 

EQ 1 To what extent have the EIAH’s services 
(Article 14(2) of the EFSI and EFSI 2.0 
Regulations) been relevant for the 
accomplishment of its mandate (Article 14(1) of 
the EFSI and EFSI 2.0 Regulations)? 

  JC 1.1 EIAH services corresponded to 
those required by the EFSI Regulation 
  JC 1.2 All eligible sectors / profiles of 
beneficiaries were adequately served 
  JC 1.3 Following the adoption of EFSI 
2.0 Regulation, the EIAH tailored its 
service offer and actively sought to : 
-  provide support in the additional 
specific areas mentioned by the 
Regulation (climate action and 
circular economy, digital sector, and 
cross-border projects, setting up of 
Investment Platforms);  
stimulate demand for EFSI support 
where needed 

- 

82 

  The EIAH developed all relevant services 
that were envisaged in the Regulation. 

  While some services were delivered 

directly by the EIAH, it also relied on a 
network of external partners (EBRD, 
NPBIs) in an effort to effectively and 
efficiently meet its objectives and to 
reach all countries / sectors. (NB: The 
extent to which all countries / sectors 
were adequately served is assessed under 
effectiveness criteria). 

  The EFSI 2.0 Regulation did not lead to 
the service offer being completely 
revamped. There was however an 
increased focus on LPAs in the more 
recent years and increased attention to the 
other specific policy policies, notably 
through the provision of upstream 
support. 

 
 
 
 
EQ 2 To what extent has the design and 
implementation of the EIAH responded to the 
needs of beneficiaries (Public and private project 
promoters; National / Regional authorities; 
Financial intermediaries; NPBs) ? 

  JC 2.1 Demand for Hub services has been 

satisfactorily high/ in line with 
expectations 

Effectiveness 

EQ 3 To what extent has the EIAH deployment 
fulfilled its mandate and objectives as listed in 
Article 14 of the EFSI and EFSI 2.0 Regulation? 

  JC 3.1 The EIAH functioned as a single 
technical advisory hub for project 
financing within the Union 

  JC 3.2 The EIAH fed the EFSI pipeline 
and actively contributed to the EFSI 
geographic and sectorial diversification 
  JC 3.3 EIAH assistance provided resulted 
in investment projects being implemented 
(using financing sources other than EFSI)  

  JC 3.4 EIAH contributed effectively to 
other objectives including building of 
capacities in less developed markets, 
development of investment platforms 

EQ 4 On which sectors and geographies has 
EIAH had most impact and why? What have 
been the challenges for making EIAH effective 
across all eligible sectors and areas and how have 
they been eventually overcome? 

  JC 4.1 EIAH assistance has brought 
tangible results across sectors and 
geographies 

83 

  The level of requests received has vastly 

exceeded expectations 

  The rate of conversion (from requests to 

assignments) is not readily available (lack 
of common denominator to be 
calculated). 

  The pool of assignments is much smaller 
compared to requests received. On the 
one hand, not all requests have the 
potential to turn into an advisory 
assignment and on the other hand, the 
EIAH is by definition meant to redirect 
requests in many cases. 

 

  The Hub functioned as an entry point. Its 
website gained traction and adequate 
processes were in place to coordinate 
with other advisory services.  
Impacts naturally took time before they 
started to materialise. At the end of 2021, 
77 Hub supported projects entered the 
EFSI pipeline (as approved/signed or 
about 8% of IIW approved or signed 
projects have benefited from Hub 
support). Hub supported EFSI projects 
were more likely to originate from 
Cohesion countries, compared to standard 
IIW projects, thereby confirming the Hub 
contribution to the geographic 
diversification of the EFSI pipeline. 
  The Hub contribution to investment 

generation does not capture the full range 
of Hub impacts (e.g., the Hub also 
contributed to quality of projects, 
smoother implementation, maturation of 
projects). 

  There is no evidence that the Hub’s 

increased attention on feeding the EFSI 
pipeline took place at the detriment of 
some types of services or beneficiaries. 

  The EIAH’s direct assignments were well 
balanced across geographies. Specific 
efforts were made to reach Cohesion 
countries. Cohesion countries were the 
main beneficiaries of EIAH direct 
assignments and EBRD Advice for Small 
Business programme. 

  EIAH support covered adequately 

priority sectors. 

  Funding agreements were signed to build 

 
 
 
 
 
 
 
 
the advisory capacities of NPBIs in less 
developed markets. Comparatively, 
NPBIs from more developed markets 
however benefitted from larger volumes 
of grant support. 

  The EIAH successfully established 

cooperation with NPBIs from 22 Member 
States. 

  Capacity building support through 
funding agreements was more 
concentrated (8 countries covered) and 
seen as less successful (heavy 
administrative requirements, 
opportunistic behaviours of NPBIs). 
  The EIAH diversified its offer towards 
SMEs through partnering with EBRD.  
It also established a modus operandi to 
coordinate with DG REFORM. 

 

  No precise estimate of the level of 

 

demand was underpinning the size of the 
budgetary allocation ex-ante.  
In the ramp up phase, the Hub underspent 
its budgetary allocations. At the time of 
writing this report, it is too early to say 
whether the EIAH will spend all of its 
budgetary allocation. Termination date of 
SGAs were pushed back to facilitate 
absorption. 

  The free character of Hub support for the 
public sector was seen as appropriate. 
Pricing policy for the private sector was 
seen as not inadequate, creating access 
issues. Pricing policy was revised 
accordingly, but only for small LPAs. 

  Governance based on a small 

Coordination committee was found to be 
quite agile. 

  Beneficiaries assessed very positively the 

Hub support. 

EQ 5 To what extent has EIAH effectively used 
the expertise of the National Promotional Banks 
or Institutions, and the managing authorities of 
the European Structural and Investment Funds 
and the international financial institutions 
(Article 14(5) and 14(6) of EFSI and EFSI 2.0 
Regulations) to achieve its objective?  

  JC 5.1 EIAH was successful at 

developing cooperation with external 
partners 

Efficiency 

EQ 6 To what extent have the financial resources 
provided to the EIAH been appropriately sized to 
meet its objectives and how could they have been 
optimised? 

  JC 6.1 EIAH spending is in line with its 

budgetary allocation 

  JC 6.2 The EIAH staff capacity in place 
is sufficient to meet the requests for 
advisory 

  JC 6.3 Other, non-dedicated EIB and EIF 
existing expert staff were available to 
supplement EIAH resources where 
needed 

  JC 6.4 Resources have been deployed 

against the various work streams of EIAH 
in a sensible manner  

  JC 6.5 The Hub pricing policy was seen 

as adequate 

EQ 7 To what extent has the EIAH governance 
model been efficient in meeting the EIAH 
objectives? 

  JC 7.1 The decision-making processes, 

roles and priorities were clear. 

  JC 7.2 Reference documents maintained 
the necessary degree of flexibility to 
adjust during implementation 

  JC 7.3 Average reaction time is seen as 

84 

 
 
 
 
 
 
reasonable 

EQ 8 To what extent have EIAH communication 
methods been efficiently used to promote its 
service to public and private project promoters 
(including national promotional banks or 
institutions and investment platforms or funds 
and regional and local public entities)? 

  JC 8.1 The EIAH undertook the 

necessary steps to effectively promote its 
activities. 

  JC 8.2 Promotional activities around 

EIAH were targeted at the right groups 
and designed in a way that ensures value 
for money. 

  JC 8.3 The Hub is now visible among its 

target audience.  

Coherence 

EQ 9 To what extent has the EIAH proved 
coherent with other existing advisory initiatives 
in terms of additionality, potential synergies 
and/or overlaps? 

  JC 9.1 Adequate processes were in place 
to ensure the Hub provides services 
additional to those already available 
under other EU programmes 

  JC 9.2 Synergies with other EU advisory 

initiatives were exploited  

EU Added Value 

EQ 10 To what extent has the EIAH support to 
project promoters and beneficiaries provided EU 
added value? 

  JC 10.1 EIAH offers support that brings 
in EU added value (e.g., alignment with 
EU priorities, transfer of knowledge 
across Member States)   

  There is evidence of sustained 

communication methods through various 
complementary channels. 

  There is consensus that visibility 

improved, but awareness levels still need 
to be improved across the wider target 
audience. 

  Adequate processes (monthly EIAH 

screening group meetings) were effective 
at avoiding overlaps / duplication of 
efforts. 

  There are positive examples of synergies, 

e.g., with ELENA and JASPERS. 
  There is no evidence of crowding out 

with the private sector. 

  Beneficiaries confirmed an EU added 
value from Hub support (advice on EU 
regulatory requirements, consideration of 
the local context, sharing of best practice, 
credibility of the outputs) 

EQ 11 To what extent has the EIAH support 
provided EU added value compared to what 
Member States acting on a national or regional 
level could reasonably achieve on their own? 

  There is no clear-cut conclusion on the 
availability of alternatives. In short, 
alternatives seem to be available, but their 
suitability challenged. 

  JC 11.1 EIAH offers support capacity that 
cannot be met by national / regional 
programmes or the private sector  

85 

 
 
 
 
 
 
 
 
EIPP 

Table III.4: Key findings for the EIPP by evaluation criteria 

Evaluation criteria / questions 

Key findings 

Relevance 

EQ 1 To what extent have the EIPP’s design and 
activities been relevant to its mandate (Article 15 
of the EFSI 2.0 Regulation)? 

 

 

 

 

JC 1.1 EIPP was adequately designed to 
encourage its use by project promoters 
and investors. 
JC 1.2 The new features introduced in 
2017 (lower minimum project size, free-
of-charge publication) were helpful in the 
achievement of the EIPP mandate. 
JC 1.3 Communication / promotion 
actions were undertaken to promote the 
EIPP.  
JC 1.4 Pitching and/or matchmaking 
events were organised and/or promoted 
by the EIPP 

Effectiveness 

EQ 2 To what extent has the EIPP deployment 
fulfilled its mandate as listed in Article 15 of the 
EFSI 2.0 Regulation? How effective has the EIPP 
been in increasing visibility and information 
available on current and future investment 
projects in the Union? 

 

 

JC 2.1 The EIPP is known among project 
promoters across the EU, and actively 
used across sectors. 
JC 2.2 The EIPP is visible to investors 
across the EU and globally, and actively 
used across sectors. 

86 

  The EIPP sustained the level of interest 
identified in the interim evaluation, with 
number of projects uploaded exceeding 
expectations and increasing numbers of 
website visitors. 

  The EIPP published projects from all MS 
and several sectors. There were relatively 
more projects received from some 
countries (e.g., Germany, Greece, and 
Spain) and sectors (e.g., digital economy) 
over others. 

  Overall, the EIPP was adequately 
designed to encourage its use by 
promoters and investors, though some 
areas for improvement were suggested 
  The changes introduced in 2017 were 

viewed as positive and beneficial to the 
relevance of the portal 

  The change in focus of the portal away 
from larger infrastructure projects and 
towards SMEs was seen as positive for 
its relevance 

  Several activities were conducted to 

promote the portal, including developing 
promotional materials, organising events 
and setting up partnerships. Though not 
initially foreseen by the EFSI regulation, 
generally these events and partnerships 
were found to help the EIPP to gain 
traction. 

  The EIPP has contributed to improving 

visibility of available investment projects 
in the EU among the global investor 
community. The target number of 
projects published was exceeded and 
portal visitors grew over time. However, 
the lack of data on the number of 
registered investors over time was a 
limitation to evidencing the EIPP’s 
increased traction and global reach with 
investors over time. 

  However, there were limitations 

regarding awareness of the portal beyond 
the group of policy makers, NPBIs 

 
 
 
 
 

JC 2.3 The EIPP is deemed as useful by 
its users: it facilitates new, serious 
contacts between project promoters and 
investors/potential business partners 

Efficiency 

EQ 3 To what extent have the financial resources 
used for the EIPP been appropriately sized to 
meet EIPP's objectives and how could they have 
been optimised? 

 

 

 

 

JC 3.1 EIPP spending is in line with its 
budgetary allocation 
JC 3.2 The staff capacity in place is 
sufficient to run the Portal and organise 
the side activities 
JC 3.3 Resources have been deployed 
against the various activities in a sensible 
manner  
JC 3.4 The pricing policy was seen as 
adequate 

EQ 4 To what extent have EIPP communication 
methods been efficiently used to promote the 
Portal? 
 

JC 4.1 Promotional activities around 
EIPP are targeted at the right groups, and 
designed in a way that ensures value for 
money 

87 

and/or active users. 

  Beyond its visibility objectives, there was 
mixed evidence regarding the EIPP’s 
usefulness, in terms of generating 
contacts and investments. The number of 
contacts generated grew, though there 
were some key challenges around 
perceptions of projects on the portal, 
scam investors and competition with 
alternative communication channels for 
investors. 

  Despite the scepticism around the 

usefulness of the portal, its direct users, 
particularly event participants, had 
generally positive feedback. However, 
further suggestions for improvement in 
terms of the effectiveness of events were 
identified. 

  The InvestEU portal will build on some 
lessons learned, making changes to its 
design to improve on its effectiveness 
and create greater impact 

  The benefits are now starting to 

materialise, improving the economic 
justification for the portal 

  Budgetary resources funded three key 

activities: screening, IT and 
communication activities 

  The EIPP were generally always able to 
work within their budget allocations. 
Though they did underspend in some 
years, sufficient resources were always 
available to deliver on its activities 
  Efficiency in terms of staff time and IT 

costs have improved over time 

  The EIPP budget share dedicated to 

communications decreased in 2020, due 
to the transition to virtual events. These 
were found to be more cost-effective. 
Events overall were most commonly held 
online (18 out of 72 events) 

  EIPP enhanced efficiency by drawing on 
its partnerships for communication and 
promotion activities, including by: 
delivering events in collaboration with its 
partners, attending partner-run events or 
asking partners to promote the EIPP at 
their events 

  However, the relatively limited 

 
 
 
Coherence 

EQ 5 To what extent has the EIPP proved 
coherent with other existing major EU-wide 
platforms (complementarity, potential synergies 
and/or overlaps)? 

 

JC 5.1 EIPP is unique or offers 
complementary service or caters to 
complementary target groups compared 
to similar initiatives at the EU level 

EU Added Value 
EQ 6 To what extent has the EIPP provided EU 
added value for enhancing the visibility of 
published investment projects from the 
perspective of project promoters and investors? 

 

JC 6.1 EIPP offers services that bring in 
EU added value (e.g., contacts across 
borders)   

EQ 7 To what extent has the EIPP support 
provided EU added value compared to what 
Member States acting on a national or regional 
level could reasonably achieve on their own? 

 

JC 7.1 EIPP is unique or offers 
complementary service or caters to 
complementary target groups compared 
to similar initiatives at the national level 

awareness of the EIPP beyond policy 
makers, NPBIs and/or active users 
suggests promotional activities could be 
more efficient in increasing awareness if 
broadened 

  Overall, similar initiatives to the EIPP 

were adequately identified, and synergies 
were explored.  

  Partnerships were developed with several 
relevant initiatives, though in some cases 
these were more advanced than others. 
  Going forward, the portal’s ambition is to 
work with partners to integrate more into 
the project promoter and investor 
community 

  Overall, the EIPP’s activities surpassed 
expectations in terms of its mandated 
role. It created added value through 
organising events and establishing 
partnerships. 

  There was some scepticism regarding the 
added value of the EIPP, and suggestions 
to improve this were identified (e.g., 
further focus on platform animation, 
insertion into the ecosystem)  

  There is mixed evidence regarding the 
EIPP’s added value relative to similar 
initiatives. Its key success factors related 
to project vetting, structure and quality of 
matchmaking, organisation of online 
events/activities, communication 
materials, and the fact that it is free of 
charge. However, other initiatives also 
offered similar advantages, and in some 
cases benefitted from comparative 
advantages in this regard.  

88 

 
 
 
 
ANNEX IV. ASSESSMENT OF THE EU GUARANTEE  

As part of a previous 2018 Evaluation of the EFSI Regulation led by ICF, an academic 
expert conducted an independent peer review of the in-house credit risk model used by 
the DG ECFIN to determine the EFSI provisioning rate (see Annex 7 of the evaluation). 
The review found the Commission’s approach to modelling to be adequate. As such, we 
saw no added value in duplicating this exercise.   

The present ICF evaluation takes place in a situation where: 

  On  the  one  hand,  most  of  the  EFSI  operations  are  already  signed,  many  are 
disbursed  (for  the  IIW)  and  no  new  volumes  are  expected  to  be  added  to  the 
portfolio.  Last  signatures  without  an  increase  of  the  assigned  guarantee  volume 
are possible until end of year 2022; and 

  On the other hand, the major part of the lifetime of the portfolio is still ahead of 

us. 

Detailed projections on expected future costs and revenues are not readily available for 
the entire EFSI portfolio. This excludes the possibility of conducting an analysis which 
combines  ex-post  data  (for  the  period  2015  to  December  2021)  with  ex-ante  estimates 
(for the period 2022 to the end of the expected lifetime of EFSI). But what can be done is 
to  look  with  good  proxy-models  at  the  situation  end  of  2019,  end  of  2020  and  end  of 
2021 and to evaluate: 

  How and to what extent the modelling worked when EFSI developed and reached 

its full volume, and  

  To  what  extent  this  can  be  projected  for  the  future  years  in  the  framework  of  a 

simplified model.  

Provisioning of EFSI  

EFSI has two components, the maximum guarantee amount from the Commission budget 
of  EUR  26  billion  and  the  maximum  EIB  allocation  amount  of  EUR  7.5  billion.  This 
evaluation considers the Commission guarantee and its provisioning which was chosen to 
avoid  a  ‘pay  as  you  go’  approach.  Cumulative  budgetary  appropriations  for  EFSI-
provisioning are transferred and paid into the Common Provisioning Fund (CPF): 

  until 2020   EUR 8.138 billion  

  until 2021   EUR 8.769 billion 

  until 2022   EUR 9.393 billion (planned) 

  until 2023   EUR 9.521 billion (planned)49 

49 Draft General Budget of the European Union 2023, Working Document Part XI, Budgetary Guarantees, 
Common Provisioning Fund and Contingent Liabilities, June 2022, p 10. 

89 

 
 
                                                 
These  cumulative  figures  include  remuneration  received  according  to  the  EFSI 
Agreement to the extent transferred to the CPF as internal assigned revenues. Cumulative 
(received  until  2021)  remuneration  summed  up  to  EUR  1.159  billion,50  transferred  as 
internal assigned volumes were EUR 0.731 billion.51 The internal assigned revenues will 
increase  according  to  plans  until  EUR  1.096  billion  until  the  end  of  2023.52  Further 
remuneration and revenues can be expected. The tenor of guarantees for many operations 
reaches out beyond the planning horizon of 2023 for the budget. In addition, a significant 
share  of  signed  operations  is  still  not  disbursed  and  further  revenues  can  be  expected 
there as well. 

The  pure  cumulative  budget  figure  without  the  internal  assigned  remuneration  in  2023 
will  be  EUR  8.425  billion.  As  35%  of  EUR  26  billion  result  in  EUR  9.100  billion  the 
budget appropriations alone do not reach a level of provisioning of 35%, but plus internal 
assigned remuneration 36.6% are achieved. 

Following  even  more  exactly  the  provisioning  model  one  can  add  the  money  spent  for 
guarantee  calls  or  value  adjustments  already53,  i.e.,  EUR  0.162  billion  cumulative  until 
end of 2021.54 Thus the overall provisioning covers 37.2% end of 2023 - forming a buffer 
beyond the assumed 35%.55 

Appropriation of EFSI volumes to EFSI  financial products  

To fulfil reporting obligations and to steer the implementation of EFSI guarantees on an 
annual basis, each end of year EC services receive reporting on the volumes of approved, 
signed  and  disbursed  operations.  A  proxy  model  to  estimate  provisioning  needs  is 
applied. 

  This model relies on risk metrics for debt and hybrid products in the IIW of EFSI. 
A simplified artificial portfolio with a granularity of 100 transactions will mirror 
all notches of the rating applied by the EIB Group. 

 

In  absence  of  accessible  credit  risk  metrics  for  equity  operations,  the  risk  for 
equity  operations  included  in  the  IIW  and  the  SMEW  cannot  be  modelled  with 
risk  metrics.  Against  this  backdrop  the  Commission  services  work  with  expert 

50 Ibidem, p 19. 

51 Ibidem, p 11. 

52 Ibidem, p 11. 

53  This  follows  from  the  fact  that  we  compare  the  amount  of  provisioning  with  the  entire  amount  of  the 
guarantee (EUR 26 million) without deducting the calls made.  

54 Ibidem, p 20. The volume of calls until end of 2021 is reported with EUR 162 m.  

55 Revenues - if achieved - to be added for the years 2024ff. 

90 

 
 
                                                 
judgement  as  a  plausibility  check  for  future  revenues  and  repayments.  This 
experts’  judgement  as  a  ‘Delphi  proxy  tool’  is  also  used  for  SMEW  debt 
operations. 

The  goal  of  the  proxy-model  (in-house  credit  model  of  the  Commission  services)  is  to 
estimate what provisioning is needed to cover future life-time losses from the operations 
guaranteed under EFSI with a 95% confidence level. 

DG ECFIN allocated EFSI guarantees to different types of financial products according 
to  plans  and  development  of  the  portfolio  over  time.  The  breakdown  of  EFSI  is  as 
follows: 

Total II Window 
of which    IIW Debt Standard56 

                   EUR 13.24 billion 

                  IIW Debt Hybrid 

                   EUR   2.00 billion 

                  IIW Equity Standard  

                   EUR   3.50 billion 

                  IIW Equity NPB platform 

                   EUR   0.51 billion 

Total SME Window 
of which   SMEW Equity57 

                   EUR   3.30 billion 

                 SMEW Guarantees (Debt)58 

                   EUR   3.45 billion 

Groups of financial products are shown here for the SME Window, as the more detailed 
breakdown  in  specific  financial  products  is  discussed  below.  Each  type  of  financial 
product  has  an  individual  guarantee  allocation  and  an  individual  percentage  of 
provisioning according to  the modelling between 24% and 58%. The weighted average 
results at 33.9% (see below). 

56 Allocated guarantee ceilings are shown in Draft General Budget of the European Union 2023, Working 
Document  Part  XI,  Budgetary  Guarantees,  Common  Provisioning  Fund  and  Contingent  Liabilities,  June 
2022, tables p 21 

57 2.32 + 0.43 + 0.25 + 0.30 = 3.30 

58 1.40 + 1.48 + 0.30 + 0.13 + 0.09 + 0.05 = 3.45 

91 

 
 
 
 
 
 
 
 
 
                                                 
IIW and SMEW 
provisioning end of 
2021  

EFSI guarantee 
allocation, EUR 
billion59 

EFSI provisioning 
needed according to 
the model for the 
allocations, EUR 
billion 

Provisioning (col 3) 
/ guarantee 
allocation (col 2) 

Total  

26.00 

8.81 

33.9% 

As  of  end-2021,  the  EFSI  enabled  the  EIB  Group  to  sign  EUR  86.9  billion  of  riskier 
financing  and  investment  operations.60  Relevant  for  EC  is  the  volume  covered  by  the 
EFSI  guarantee.  The  guarantee  volume  of  EUR  26  billion  de-risks  around  EUR  80.9 
billion.61  The  difference  of  EUR  6.0  billion  to  EUR  86.9  billion  comes  from  own 
programmes of the EIB Group without contributions of the EFSI guarantee, notably the 
RCR  EIF  programme.62  Bottom-up  calculation  shows  that  the  EU  risk-taking  for 
operations  signed  by  counterparts  at  the  end  of  2021  is  less  than  EUR  26  billion  -  the 
liability is reported at EUR 24.7 billion.63 Taking guarantees already called into account 
the buffer between EUR 26 billion on one side and signed operations and already called 
guarantees on the other side amounts to EUR 1.1 billion. It seems to be unlikely that this 
additional buffer will be fully utilised until the end of 2022. But as the build-up phase of 
EFSI lasts until 31 December 2022 increases of the guaranteed volume are still possible.   

 The guarantee allocation works for each type of financial product has de facto worked as 
a  cap,  defining  the  maximum  possible  volume  to  be  signed.  New  signatures  in  each 
product  were  done  beyond  the  allocated  volume  of  the  respective  products.  As  no 
reallocation of the guarantee volumes for the  type of financial product  shall take place, 
unused parts contribute to the additional buffer mentioned in the previous paragraph. 

59 Column 4 based on Information ECFIN, column 3 own calculation  

60 Draft General Budget of the European Union 2023, Working Document Part I, Programme Statements of 
Operational Expenditure, June 2022, p 89. 

61 See fn 7. 47.04 + 6.01 + 6.33 + 0.45 + 12.83 + 2.58 + 0.41 + 0.24 + 2.26 + 1.59 + 0.75 + 0.10 + 0.27 + 
0.04 = 80.90. 

62 Information of ECFIN (email 23 September 2022). 

63  It  makes  sense  to  add  guarantees  already  called  (EUR  0.16  billion).  See  Draft  General  Budget  of  the 
European  Union  2023,  Working  Document  Part  XI,  Budgetary  Guarantees,  Common  Provisioning  Fund 
and Contingent Liabilities, June 2022, p 19 and 20 (tables). 

92 

 
 
 
  
 
 
                                                 
Proxy model for IIW debt and hybrid operations  

The  two  sub-windows  IIW  Debt  Standard  and  IIW  Debt  Hybrid  comprise  66%  of  the 
signed EFSI operations at the end of December 2021. The counterpart EIB-Group signed 
EUR 47.04 billion and EUR 6.01 billion respectively, together EUR 53.05 billion. 64 But 
the  exposure  is  less,  mainly  due  to  repayments.  The  majority  of  the  operations  are  not 
made with bullet repayments and thus show repayment schedules. 

EC  services  (ECFIN)  have  developed  a  credit  risk  model  and  announced  to  develop  it 
further into a unified credit risk model for all budgetary guarantees. This model based on 
risk  metrics  provides  an  estimate  on  the  underlying  operations  over  the  lifetime  of  the 
guarantee  using  pragmatic  assumptions  to  estimate  future  losses  and  the  uncertainty 
around  those  expected  loss  estimates.65  The  model’s  calculations  are  made  with  an 
artificial portfolio comprising 100 loans mirroring the distribution found in reality. With 
the default probabilities of the different risk levels one can estimate: 

  Expected  losses  based  on  disbursed  exposure  for  the  lifetime  of  the  EFSI 

portfolio, and 

  Value at Risk based on signed exposure; here looking for the probability having 

less losses than the provisioned money of 95% over lifetime.  

The provisioning for the two sub-windows is set to 33% for the portfolio including the 
defaulted  D  operations.  For  the  defaulted  operations  the  provisioning  is  set  to  300% 
following the first loss piece approach.66 

Again,  there  are  several  effects  visible  forming  an  additional  buffer.  The  approach 
chosen is understandably rather conservative; we find firstly (i) that volume of operations 
signed is smaller than volume of operations according to the guarantee allocation, so no 
overbooking and no full utilisation of the allocation emerge. Secondly (ii) not all signed 
operations will see disbursements (e.g., operations  get  cancelled). Thirdly (iii) the VaR 
consideration of the proxy model delivers a provisioning need of 31.85% for a Gaussian 
distribution end of the year 2021 (and 28.89% for a Gamma distribution).67 Following a 

64 See footnote 47. 

65 Draft General Budget of the European Union 2023, Working Document Part XI, Budgetary Guarantees, 
Common Provisioning Fund and Contingent Liabilities, June 2022, p 66. 

66 The rationale is that at an LGD of 100% the provisioning for D rates operations would be in line with the 
first loss piece approach 1/25% = 400%. This holds as long as the maximum guarantee amount of EC is not 
achieved.  In  the  given  situation  such  ceiling  is  very  far  away.  As  LGD  is  however  significantly  below 
100% a level of 300% is chosen by experience from the past and is considered as a conservative estimate. 

67  Information  ECFIN  (email  16  September  2022).  As  guarantee  fees  create  revenues  a  left-skewed 
distribution can cause more revenues and need less provisioning. On the other hand a right long or fat tail 
can cause more provisioning needs. 

93 

 
 
                                                 
conservative  approach  the  distribution  with  the  higher  rate  of  provisioning  need  is 
chosen.   

Altogether EUR 4.85 billion provisioning are needed to achieve the VaR objective for II 
Window Debt and Hybrid at the end of 2021 instead of EUR 5.03 billion according to the 
allocation ceilings modelling.68 

% of rating 
signed under II 
W Debt and 
Hybrid  

Signed Exposure  

EU risk  

(EUR billion)69  

(EUR billion)70  

Provisioning needed 
with xx rate (see text, 
Gaussian distribution 
for 2021, EUR 
billion)  

Total 

100.00  

46.56  

15.16  

5.00 (with 33% rate)  

100.00  

4.85 (with 32% rate)  
Total 
Note: The change in the provisioning need for II W Debt and Hybrid together from end of 2019 to 2021 (in 
each of the years the distribution with the higher provisioning rate was chosen, otherwise the provisioning 
rate would gone down in 2021 to EUR 4.38 billion). 

46.56  

15.16  

The trend of the last three years showed an increase for the Gaussian distribution and a 
decrease  for  the  Gamma  distribution  (standing  in  2019  at  33.5%  provisioning  need  to 
meet the VaR requirement). This trend of two opposite developments could be caused by 
an increase of guarantee revenues and the (somehow counter-intuitive) decrease for the 
Gamma  distribution  highlights  the  importance  of  revenues  for  the  economic  model  of 
EFSI.   

 A  deterioration  of  the  development  cannot  be  excluded  for  the  future,  but  the 
provisioning so far proves to be robust and creating additional buffers.  

68 Own calculations. 

69 Information ECFIN, email 16 September 2022 

70 Draft General Budget of the European Union 2023, Working Document Part XI, Budgetary Guarantees, 
Common Provisioning Fund and Contingent Liabilities, June 2022, table p 21 

94 

 
 
 
  
 
 
 
 
 
                                                 
Proxy model for the SMEW and for the equity operations of the IIW  

SMEW provisioning  

end of 2021  

Total SMEW   

of which   

SMEW EP SW 1  

SMEW EP SW 2  

SMEW PC SW1 (EP)  

SMEW InnovFin SMEG (GP)  

SMEW COSME LGF (GP)  

SMEW EaSi (GP)  

SMEW CCS (GP)  

SMEW ECP Agri Nat Combi W and 
EAFRD (GP)  

ESCALAR (EP)  

Education, apprenticeship & skills pilot 
(GP)  

II W Equity provisioning  
end of 2021  

Total II W Equity  

of which  

IIW Equity Standard  

EFSI guarantee 
allocation, EUR 
billion   

EU risk for operations 
signed by counterpart 
end of 2021, EUR 
billionn71  

 6.75  

2.32  

0.43  

0.25  

1.40  

1.48  

0.30  

0.13  

0.09  

0.30  

0.05  

6.26  

2.22  

0.42  

0.23  

1.38  

1.34  

0.30  

0.10  

0.00  

0.27  

0.04  

EFSI guarantee allocation, 
EUR bn   

4.01  

3.50  

EU risk for operations 
signed by counterpart end 
of 2021, EUR bn72 
3.28  

2.85  

IIW Equity NPB  
Note:    More  detailed  view  of  SMEW  and  IIW  Equity.  (GP)  Guarantee  Programme,  (EP)  Equity 
Programme.  Three  promotional  programmes  comprise  79%  of  the  volume.  All  programmes  show  no 
overbooking and no full utilisation of the guarantee allocation. 

0.43  

0.51  

For equity products experts give a judgement for each of them. Their opinion is based on 
experience with similar products in the past and market sectorial results.73 They consider 

71 Draft General Budget of the European Union 2023, Working Document Part XI, Budgetary Guarantees, 
Common Provisioning Fund and Contingent Liabilities, June 2022, p 21 (tables) 

72 Draft General Budget of the European Union 2023, Working Document Part XI, Budgetary Guarantees, 
Common Provisioning Fund and Contingent Liabilities, June 2022, p 21 (tables) 

95 

 
 
 
  
  
  
  
                                                 
risk including sector-risks and future losses, future revenues, repayments and profits. For 
the purpose of provisioning EFSI each product can show an individual provisioning rate. 
These rates are not  carved in  stone and may be  reviewed  and adapted by  experts when 
necessary.  Three products comprise 79% of the volume of all SMEW programmes. The 
provisioning  rates  for  all  SMEW  products  provided  by  the  expert  judgement  are  in  the 
range  of  15%  up  to  100%.  All  products  –  under  SMEW  and  IIW  Equity  -  show  no 
overbooking and no full utilisation of the guarantee allocation.   

Altogether EUR 0.85 billion are needed end of 2021 for the provisioning for IIW Equity 
instead of EUR 1.01 billion according to the allocation ceilings. As regards SMEW the 
provisioning needs add up to EUR 2.57 billion instead of EUR 2.77 billion according to 
the allocation ceilings.74 Here again an additional buffer is visible.  

Active versus automatic balancing of the portfolio  

Even if EFSI’s main objective is to go for non-investment grade risk, it is obvious that 
not  all strategic investments  are high risk. The scaled up EFSI portfolio shows that the 
provisioning mechanism works as planned, if around one third of the volume is given to 
investment grade borrowers.75 Thus, it is important to identify strategic investments with 
high impact with investment grade borrowers, too.   

Such  an  approach  while  building  up  the  portfolio  seems  to  be  necessary.  It  will  not  be 
possible to create a balanced portfolio relying on an automatic mechanism only. If, e.g., 
all EFSI borrowers were non-investment grade at the date of signature, rating upgrade for 
successful innovative companies will take place (and did already take place in the case of 
EFSI), but by far not enough to achieve one third investment grade volume in the EFSI 
stock.  As  the  overall  portfolio  is  on  the  rather  risky  side  one  would  expect  more 
downgradings than upgradings of the borrowers. That was confirmed by this evaluation. 
Figures show that the trend to see more downgrades prevails and is not compensated by 
rating upgrades.  

Another approach to achieve a balanced portfolio is to rely on the mechanism that - under 
normal  circumstances  -  risk  decreases  over  time.  This  effect  is  mirrored  best  in  the 
development of the loan gradings. There is a significant improvement in the portfolio’s 

73  One  Member  State  mentioned  in  an  interview  that  they  work  with  expert  judgements  for  guarantee 
programmes which can be adapted for each budget. The range of provisioning communicated is in between 
20 and 35%. 

74 Own calculations. 

75 The biggest programme (IIW Debt Standard) shows an increase of non-Special Activity over time at the 
time  of  signature.  It  is  3.3%  of  the  signed  exposure  end  of  2016,  3.8%  end  of  2017, 5.1%  end  of  2018, 
6.8% end of 2019, 10.1% end of 2020. See Risk Reports II W Standard Debt. 

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loan grading. Such improvement supports the view that provisioning is robust. The life-
span effect of shorter tenor while time is progressing helps to improve the loan grading. 

Thus,  a  balanced  portfolio  requires  active  measures  such  as  a  certain  volume  of 
operations  with  investment  grade  borrowers  and  a  certain  volume  with  ‘non  Special 
Activity’  at  signature.  Active  measures  are  possible  as  long  as  EFSI  volumes  are  still 
increasing. For the provisioning level chosen for EFSI it turned out that the combination 
of  slightly  more  than  one  third  of  investment  grade  borrowers  and  slightly  more  than 
10% of ‘non Special Activity’ loan grading at signature delivered a balanced portfolio. 

Summary  

The provisioning of 35% of EFSI guarantees shall avoid future burden of the EU budget. 
That  is  important  as  EFSI  has  created  a  large-scale  programme  family.  Calls  for 
guarantees in case of large-scale activities cannot be served in a ‘pay as you go’ approach 
without causing difficulties for the EU budget.  

So far, the provisioning system worked well: partial provisioning from the budget was set 
aside;  revenues  created  with  the  guarantee  fees  also  contributed  to  the  provisioning. 
Moreover it seems rather likely that revenues will contribute in the future, too. 

The  provisioning  does  not  cover  the  expected  loss  only,  it  shall  be  sufficient  in  a  VaR 
approach to cover with 95% probability the future losses over the lifetime.  

In  fact,  this  evaluation  shows  that  with  a  conservative  approach  until  the  end  of  2021 
additional  (small)  buffers  are  created.  In  the  years  to  come  additional  revenues  may 
improve the business case of EFSI further. In case of a worsening economic situation the 
EFSI system seems to be sufficiently robust. 

EC  services  developed  a  proxy  credit  model  for  first  indications  of  past,  present  and 
future developments. This model calculates VaR. It helps to steer portfolios - as long as 
the  reporting  frequency  of  the  implementation  partners  remains  annual,  the  steering 
impact will remain annual. This restriction is rather caused by the contractual agreements 
with implementation partners, VaR was originally developed for daily reporting. As the 
modelling  it  is  sufficiently  precise,  EC  can  be  encouraged  to  develop  its  model  further 
into a unified credit risk model for all budgetary guarantees. 

Altogether:  the  provisioning  seems  to  work.  The  level  of  around  1/3  operations  with 
investment  grade  borrowers  supports  a  balanced  portfolio  and  is  a  precondition  for  the 
choice  of  the  provisioning  rate.  By  comparison  to  ‘grant  programmes  only’  the  EU 
budget  is  spent  with  a  large-scale  guarantee  programme  and  a  number  of  financial 
instruments more efficiently. The robust provisioning supports the view that there might 
be left-overs from the provisioning.  

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ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

This  report  provides  a  summary  of  the  key  findings  from  the  stakeholder  consultation 
activities  conducted  as  part  of  this  study,  against  each  judgment  criteria  as  per  the 
evaluation  framework.  This  includes  information  from  all  interviews  conducted 
throughout  the  study,  specifically:  scoping  interviews  conducted  during  the  inception 
phase  of  the  study,  EU-level  interviews  conducted  as  part  of  the  transversal  research 
tasks, and interviews with stakeholders at the Member State level, conducted as part of 
the country case study research. 

The synopsis report is included for transparency purposes. It  contains the interviewees’ 
views and does not constitute the evaluation team’s assessment. 

1.  EFSI 

Relevance 

EQ 1. To what extent has the design and implementation of the EFSI responded to 
the  needs  of  the  project  promoters,  financial  intermediaries,  and  private 
investors?  

JC  1.1  The  product  offer  under  EFSI  was  suitable  i.e.,  the  range  of  products 
deployed  under  EFSI  (i)  addressed  market  failures/  constraints  that  may 
inhibit  or  restrict  private  investment  (ii)  addressed  the  diversity  of  needs 
across sectors and EU Member States 

IIW 

According to market players, the product offer under the EFSI needed to be different to 
EIB  traditional  product  offer  centred  upon  standard  debt  products  /  direct  lending 
products  (need  for  increased  risk  bearing  to  achieve  EFSI  targets).  Standard  loans  but 
longer maturities were also needed. 

It does not mean that the EIB had to deploy completely new products though. Products 
other  than  standard  debt  were  already  used  by  the  EIB  before  EFSI,  but  often  not 
mainstream  /  not  deployed  at  scale  /  limitedly  used  at  own  risk  and  instead  developed 
under mandates such as InnovFin (e.g., risk sharing, equity) 

The more mainstream use of products such as venture capital, venture debt products was 
welcome by market players. The EFSI was an opportunity to test these new products.  

Overall, specific products were not launched following market studies or ex-ante needs 
assessments. These were developed to suit particular clients’ needs (demand driven). For 

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example for debt funds, there is no standard model – each debt fund had specific features 
tailored to clients’ needs. 

Less  successful  products  under  the  IIW  included  captive  funds  and  the  NPB  equity 
window (see also EQ 8). 

SMEW 

The frontloading / topping up was the most effective use of the EFSI support. The EFSI 
was  reinforcing  existing,  successful  programmes  that  were  already  being  rolled  out. 
There  was  demand  under  those  programs  and  it  was  easier  /  faster  to  implement  -  it 
allowed to do more of the same. There was an oversubscription of existing programmes, 
demand for SME support greater than the speed at which the EC could provide support 
before  the  EFSI  (through  budgetary  allocations/contributions).  The  EFSI  frontloading 
avoided stop and go and was an early sign that earlier mandates were not appropriately 
sized.  

The  importance  to  have  classical  guarantee  schemes  /  general  SME  products  was 
emphasized by market players (despite pressures to do more on the equity side and to use 
more innovative / sectoral/ thematic programs). Besides, for smaller institutions general 
SME products are easier to implement (easier reporting and eligibility checks). 

General  SME  products  are  crucial  at  times  of  crisis  (e.g.,  during  the  Covid-19  crisis). 
When Covid-19 hit a number of changes to product features were made, to speed up the 
roll out  of support and enhance the  risk  coverage.  Without  this,  there are  fears that the 
insolvency rate would have been much higher.  

Guarantee coverage under the different  programmes  was  generally seen  as  adequate by 
the intermediaries, and the pricing was considered as attractive. 

Note  that  for  public  intermediaries,  COSME  type  of  additionality  criteria  were  not 
necessarily considered as easy to meet, as, depending on the baseline / if already doing a 
lot, it is hard to demonstrate that one does more or takes more risk.  

Programmes  targeting  niche  markets  such  as  CCS  were  found  hard  to  implement  for 
some intermediaries (difficulties finding a client base / meeting market demand). 

Some  stakeholders  noted  that  the  EIF  also  contributed  to  re-launching  securitisation 
products in some markets where their use had stopped. While some see this as a positive 
market development, others perceive  as a lower additionality when guaranteeing a loan 
book that a bank has already generated.  

There  were  also  calls  from  NPBIs  to  offer  more  equity  financing  for  public 
intermediaries  /  funds  but  the  understanding  was  that  this  will  probably  remain  a 
limitation under the InvestEU too, as the idea of a Solvency Support Instrument was not 
maintained. 

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JC 1.2 The allocation of resources between IIW and SMEW reflected needs  

The increases of resources for the SMEW and transfer of resources from the IIW to the 
SMEW were seen as justified given the high market demand for SMEW financing, and 
high deployment levels.  

At the start of the EFSI, in 2015, the SMEW had EUR 2.5 billion. In the end, a total of 
EUR 6.75 billion was allocated and the budgetary allocation was almost fully deployed 
(around 95-100%). 

On the debt side, the inclusion rate is at 95%. This suggests that ultimately the SME 
served demand. 

There was also huge demand for equity. Outcomes will take more time to be generated 
but full deployment of the equity windows is to be expected. 

JC 1.3 There was demand for EFSI financing across sectors and countries 

EFSI  covered  a  range  of  sectors.  In  2020,  the  need  to  focus  on  healthcare  and  life 
sciences increased and the EFSI helped finance riskier investments in this sector. There 
was  also  a  rationale  to  finance  investments  in  sectors  such  as  road  transport  in  certain 
countries (e.g., Italy).  

There  were  calls  from  some  market  players  to  continue  to  support  a  generalist  type  of 
support (not only very specific sectors). 

EQ 2. To what extent has  the design and implementation of the EFSI instruments 

responded to the evolving market needs? 

JC 2.1 There were processes in place for market sounding 

There is a consensus view that the EFSI remained relevant over time and adapted to the 
changing circumstances. Progressively, the policy focus sharpened. 

Reported factors that contributed to the flexibility: 

  Possibility to use contractual amendments to quickly implement changes (with no 

need to modify the legislation); 

  Governance  process  with  functional  feedback  loop  with  the  Steering  Board, 
Steering Board issuing updates to the strategic orientations as and when needed; 
  Embedment within the EIB (any EFSI operation was first an EIB operation, and 

all the EFSI aspects were managed and embedded in the Bank). 

JC  2.2  There  was  flexibility  to  make  adjustments  in  response  to  evolving  market 
conditions e.g., introduction of new products, budget re-allocations etc. 

EFSI  proved  to  be  an  effective  countercyclical  instrument  during  the  Covid-19  crisis, 
thanks  to  its  firepower  and  flexibility  (e.g.,  IIW:  reduced  time  to  market,  top  ups  to 

100 

 
 
existing  IIW  operations;  SMEW:  increased  budgetary  allocation,  increases  to  the  cap 
rate, guarantee rate etc., financing of working capital needs). 

More generic demand driven instruments such as the EFSI are logically more flexible in 
times  of  crisis  (broad  scope).  The  adjustment  of  the  parameters  for  the  guarantees  was 
very helpful to accommodate the increase in risk levels and easy to implement through 
contractual amendments. The use of the guarantees exploded during the pandemic. The 
EIB response under the EFSI was immediate, creating a positive signalling effect for the 
market.  The  quick  launch  with  retroactive  application  was  very  helpful.  At  times  of 
crisis, it makes sense to rely on instruments that already exist and not to try to invent new 
products that take years to develop.   

Comparatively  national  responses  were  sometimes  seen  as  having  played  a  more 
important  role  to  address  liquidity  needs.  E.g.,  in  Italy  responses  were  much  quicker 
under “Garanzia Italia”. This is not true in all cases; for example, in France the national 
scheme  came  later  in  the  summer  of  2020.  Some  highlighted  in  that  context  that  open 
access  to  the EU  guarantee would have been helpful in  times of crisis,  to  speed up the 
rapidity of the EU response. 

Over  the  time  of  its  implementation,  the  EFSI  had  to  be  flexible  enough  to  adjust  to 
changing policy priorities. The EFSI was able to accommodate the increased policy focus 
e.g., on climate policy. 

JC 2.3 There was room for market testing new approaches and products 

In the first phase of the EFSI, it was more about volumes, deploying as much as possible 
to kick-start investment but over time product development became more policy-focused. 
These changes were due to several factors, including the legislative changes introduced 
as part of the EFSI 2.0. The clear direction about the need for more additionality was one 
factor (amongst others) behind the development of more policy focused products. 

Products were developed / scaled up / mainstreamed under EFSI, under both the IIW and 
the SMEW. Under the IIW there was e.g., the venture debt product. 

Under SMEW a number of products were piloted / tested to see how the market reacts: 

 The European Scale-up Action for Risk capital (ESCALAR); 

 
  The digitalisation pilot under COSME which was really made possible thanks to 
the  additional  resources  made  available  through  EFSI  (for  more  demanding 
products  in  terms  of  eligibility  /  more  policy  oriented  products,  needed  higher 
guarantee rates also given higher risk concentration);   

  Private credit product for SMEs;  
  EFSI combination product for agricultural sector; 
  Skills & education pilot guarantee product;   
  EFSI pilot on social impact bond scheme/ equity instrument; and   

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  Additional  equity  product  offering  in  the  fields  of  blue  economy,  life  sciences, 

Artificial Intelligence, and Blockchain technologies 

JC  2.4  EFSI  financing  was  allocated  to  sectors/  thematic  areas  with  the  greatest 
financing  needs  and  gaps  (while  balancing  policy  prioritisation  and 
absorption capacity) 

Not many examples of market failures/ gaps not addressed by EFSI products were given, 
but the following points were made: 

  A programme based on an EU guarantee is not meant to cover the first loss piece, 
it  is  not  a  one  size  fits  all  programme.  Fully  funded  financial  instruments  and 
grants  are  needed  too.  Some  gaps  were  and  are  to  be  covered  through  other 
channels including Cohesion Policy. 

  Some  types  of  projects  (e.g.,  public  sector  projects  of  the  municipalities, 
sustainable infrastructure, social infrastructure, and social economy) remained too 
small for the EIB intervention under the EFSI – in that context the opening of the 
EU  guarantee  to  new  implementing  partners  is  welcome.    The  EIAH  and 
investment platforms also have a role to play.  

  Some  businesses  become  eligible  repeatedly  (e.g.,  repeat  loans).  This  means  a 
higher  risk  for  the  financing  entities  (including  the  State)  and  limited  economic 
impact (as others are left out). 

  Lack  of  instruments  /  support  was  also  quoted  (more  anecdotally):  some 
sectors/areas  including  new  materials  tied  to  circular  economy  concepts  and 
recycling,  water  scarcity,  emission  control,  industry  4.0  and  the  productive 
process  surrounding  the  green  transition,  design  and  more  generally  the  equity 
side. 

  The case of tourism was also quoted where the EIB added constraints restraining 
intervention  (only  in  Cohesion  regions,  only  for  EE  projects  or  territorial 
development) while in theory the sector was eligible for EFSI financing. Logistics 
is another such example where EIB does not intervene. 

  The absence of specific features that would have facilitated the implementation of 
cross border projects was also quoted (e.g., guarantees typically not designed to 
cover the impact of currency fluctuations). 

EQ 3. To what extent has each pillar of the scoreboard (Article 7(14) and Annex II 

of the EFSI 2.0 Regulation) been appropriate and relevant? 

Transparency of the Scoreboard was seen as a positive development, even if it is unclear 
to what extent scoreboard were widely accessed and used (only a close circle of informed 
stakeholders would have an interest). Transparency efforts bring added value as long as it 
does not burden too significantly the final beneficiaries, intermediaries, or implementing 
partners, EIB (transparency efforts should not negatively impact time to market). 

For NPBIs and national authorities this was considered as useful to better understand the 
focus of EFSI. From that perspective, the absence of information on rejected projects was 
seen as a limitation.  

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Effectiveness 

 EQ 4a. To what extent has the EFSI achieved its objectives, in particular the target 

of mobilising EUR 500 billion of total investment by 2020? 

JC  4.1  EFSI  has  achieved  or  exceeded  its  target  of  mobilising  EUR  500  billion  of 

additional investment across the EU 

The  volume  of  investment  mobilised  is  impressive  (high  leverage  effect,  higher 
compared  to  other  instruments).  EFSI  worked  to  leverage  EIB  own  resources,  but  the 
most  impressive  is  that  a  large  proportion  is  private  investment  too.  The  possibility  of 
attracting  private  investment  to  meet  public  policy  goals  is  the  key  message  of  EFSI: 
public resources are limited but can be enablers.  

There  is  evidence  to  suggest  that  EFSI  has  generally  served  as  a  catalyst  for  attracting 
this  private  investment  ––see  also  EIB  EV  evaluation  ((i)  survey  data  –  where  most 
clients  suggest  that  the  presence  of  the  EIB/EFSI  helped  and  was  perceived  positively; 
(ii)  interviews  with  NPBIs  and  European  banking  federation  member  focus  group 
confirming that the presence of EFSI and EIB was a positive aspect encouraging private 
investors; (iii) case studies concluded that both signalling effect and risk coverage played 
a role). 

The  SMEW  has  had  a  particular  good  leverage  effect  (as  opposed  to  other  windows). 
Note  that  despite  the  good  results,  the  actual  leverage  of  the  COSME  LGF  realised  to 
date actually is lower than initially anticipated (17 vs 25), and so is the multiplier effect 
(21  vs  31)  -  see  41(5)  report  for  2020.  This  is  because  the  portfolios  are  still  under 
development (actual leverage and multiplier will go up) and guarantee rate increased in 
Covid-19 times (which mechanically lowers leverage). 

The EUR 500 billion target refers to operations that are approved. The figure went down 
from EUR 545 billion (end-2020) to 524 billion (end-2021). This is normal because some 
of  the  approved  operations  have  been  partially  or  fully  cancelled.  Reasons  for 
cancellation are varied (not EFSI specific): there is no obligation for the client to sign the 
-full-  contract  when  an  operation  is  approved,  projects  are  sometimes  cancelled  / 
downsized or alternative sources of finance found, and at the margin there  is also some 
currency impact. The rate of cancellation is in line with expectations. 

The  final  figure  will  be  known  by  end-2022.  The  expectation  is  that  the  level  of 
investment mobilised will remain above EUR 500 billion. The latest operational report, 
end-2021, showed that EUR 492 billion were mobilized based on signed amounts. This is 
very close to reaching the target (only EUR 8 billion left).  

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JC 4.2 Applicable methodology has been used consistently and data for calculation 

are reliable 

Note  that  the  multiplier  methodology  does  not  claim  direct  causality  between  EFSI 
intervention  and  investment  mobilised  and  acknowledges  that  causality  is  difficult  to 
demonstrate and cannot be conclusively proven.  

There are specific methods to avoid double counting and  deal with co-financing (under 
other EU instruments) and double financing (repeat operations). 

For the  IIW, the EFSI multiplier calculation methodology is not based on assumptions. 
Estimates are project based, estimates of the total project cost done by EIB engineers and 
economists. The only assumption is for venture debt operation for early-stage start-ups, 
which is based on an ECB market study. 

For the SMEW,  the  EIF methodology is  based on  relevant  assumptions established ex-
ante, specific to each market, applied consistently. 

EQ  4b.  What  factors,  even  if  unexpected  or  unintended,  have  driven  or  hindered 

progress and how are they linked (or not) to the EU intervention?  

In the interviews, there has been a discussion on the role of the EIB as sole implementing 
partner under EFSI and the geographical/sectoral spread of EFSI. It was one of the topics 
that  was  most  discussed  in  the  implementation  of  EFSI  and  development  of  InvestEU. 
The idea was that EFSI successes and well targeted segments (countries/sectors) reflected 
the capacity of the EIB/EIF (- Large projects - Debt products - SMEs - Certain sectors – 
Certain countries)  

EFSI  had  only  one  implementing  partner  which  was  the  EIB  Group.  EIB  enables  pan-
European coverage. Given the limited time available when EFSI was launched, the EIB 
was  the  natural  partner  for  operationalising  the  instrument.  But  it  did  not  prevent  the 
geographical  skewness.  EIB  is  more  present  in  some  countries/markets  than  in  others. 
The EIB is a very centralised organisation, with no territorial network. It has, and rather 
logically  so,  no  in-depth  context  of  the  local  contexts.  It  does  not  cover  well  the  small 
projects / certain sectors. It is more specialised in larger and/or cross border projects. EIB 
finances rather large projects (EUR 50-300 million) even if EFSI helped the EIB to deal 
directly with smaller projects (starting even with volumes of EUR 10 million).  

In  relative  terms,  the  concentration  could  have  been  worse.  Several  factors  explain  a 
certain  degree  of  concentration  (see  also  –  special  activity  evaluations  as  80%  of  EIB 
Special Activity Operations fall under EFSI): 

  The  market  maturity  was  a  limitation  for  certain  types  of  lending  and  equity 
financing.  Countries  with  more  developed  markets  ended  up  putting  forward 
more proposals.  

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  From a certain point of view a different picture could have been expected - some 
countries are more in need and the EIB's AAA rating makes more of a difference 
for these countries. But in these countries, there is also a 'competition' effect from 
grants  –  ESIF  grants  are  available  for  possible  EFSI  beneficiaries  so  financial 
instruments may not be their first choice.   

  There were also challenges for instance in trying to bring investments to smaller 
countries such as i.e., Czechia or Latvia. In many cases projects are also smaller 
in size – i.e., local municipalities that need financing – and as such are below the 
threshold EIB is normally used to.  

  The  macroeconomic  environment  also  played  a  role  –  a  positive  context  like  in 

Poland increased demands for loans. 

There was a distinction between the SMEW and the IIW. 

Deployment  was  faster  under  the  SMEW.  Cooperation  between  EIF  and  NPBIs  / 
financial intermediaries was already pre-existing and working well. Financial instruments 
were used and generating interest among SMEs and banks. The EIF offers standardised 
products, and the banks work well with these products. They are already well promoted 
to  the  customers  and  integrated  into  the  systems  of  the  bank.  It  is  reportedly  easy  for 
intermediaries to switch from a programme to another and from one programming period 
to  the  next.  In  some  countries  however,  there  was  a  limited  number  of  national 
intermediaries to absorb resources (Romania, Cyprus, Ireland and the UK). 

Under the IIW, presence of a strong NPBI was a key factor to facilitate deployment and 
facilitate  the  financing  of  smaller  projects  /  facilitate  outreach  on  the  whole  territory, 
including  through  investment  platforms.  However,  often,  there  was  no  pre-existing 
cooperation between NPBIs and the EIB (there was some form of cooperation in France). 

Without mobilisation efforts (and e.g., efforts to set up investment platforms), it is likely 
that there will be a limited pool of projects the EFSI can finance, that it will be hard to 
find  transactions  with  higher  level  of  additionality  to  go  under  the  EFSI.  For  instance, 
regarding  social  infrastructure,  there  were  needs  (housing,  education,  now  also  health), 
but it was unclear whether an EU guarantee was needed. The low share of financing for 
projects  in  some sectors  generally  reflected the low riskiness (e.g., social infrastructure 
projects  often  being  plain  vanilla  Social  Security  Administration  lending).  Another 
example:  telecom  projects  often  being  corporate  finance  projects  financed  under  EIB 
own resources. 

Progressively, and notably thanks to EFSI 2.0, the targeting under the IIW was extended. 
The NPBI equity window served that purpose. 

The  opening  to  more  implementing  partners  under  InvestEU  is  generally  welcome  by 
interviewees. Local presence is needed to target smaller corporates. In countries such as 
France,  NPBIs  even  have  local/regional  offices.  More  partners  can  improve  the 
geographical  coverage  and  also  sector  spread  (e.g.,  social  projects  are  specifically 
targeted by the Council of Europe Development Bank).  

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EQ  5.  To  what  extent  has  the  sectoral  and  geographical  distribution  of  EFSI 

investments been in line with the defined indicative limits? 

A policy instrument needs policy-related targets. In the case of EFSI, the targets were not 
hugely  difficult  to  reach  so  it  did  not  significantly  constrain  the  implementation  of  the 
programme, this was quite proportionate.  

The  interviews  did  not  shed  much  light  on  how  the  sectoral  and  geographical 
concentration limits were decided upon. A compromise was certainly found between, on 
the one hand, not wanting to have too  geographically concentrated deployment and, on 
the other hand, what was feasible to achieve in terms of deployment  

On geographic concentration, the paper produced for the Steering Board in July 2019 sets 
out  all  the  activities  that  were  conducted  in  terms  of  communication  and  reach-out  in 
other countries. 

Comparatively,  sectoral  concentration  was  less  topical  under  the  EFSI  (although  it 
became  more  of  a  concern  under  InvestEU).  The  limit  was  monitored,  and  always 
respected (note on the sectoral breakdowns: interesting to look  at figures separately for 
the IIW and the SMEW). 

EQ  6.  To  what  extent  has  the  EFSI  achieved  its  objectives  in  relation  to  the  40% 
target  under  IIW  to  support  project  components  that  contribute  to  climate 
action? 

JC 6.1 The climate action target has been achieved or exceeded 

The  EFSI  was  the  first  EU  programme  with  a  concrete  climate  objective  –  it  was  an 
important development.  The EU Green Deal and other EU political agendas on climate 
action  were  set  after  the  initial  design  of  the  EFSI  but  have  since  then  gained  a  lot  of 
importance. 

Meeting the CA target was not binding, yet it was met. It was within reach – calculated at 
a time when the EIB already knew the composition of its portfolio and concomitantly the 
EIB was also developing its own climate policy and climate roadmap. 

There  were  no  negative  unintended  side  effects  (in  terms  of  risk  levels,  geographical 
diversification)  ˗  see  also  EIB  EV  (2021).76  In  reality,  climate  operations  are  not 
necessarily more risky – increasingly proven that it is not the case. 

The introduction of the target has enriched discussions. 

76 Ibidem p.72 

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However, in terms of the composition of the portfolio,  the EFSI was not only targeting 
climate  action.  Fossil  fuel  projects  remained  eligible.  All  transport  modes  have  been 
allocated funds. Over time though, impression at the EC that the portfolio shifted towards 
more CA projects, for instance less motorways and more electrical bus fleet.  

Comparatively, InvestEU will provide a more robust policy steer for CA.   

JC 6.2 EIB methodology for determining climate action financing is robust and in 

line with accepted standards 

There were only a few remarks on the methodology for determining CA (same under the 
EFSI than for the EIB in general): 

  There may be some examples where there are CA projects that we cannot claim to 

be climate friendly, but these would be marginal. 

  Focus  on  CA  should  not  be  at  the  detriment  of  other  sectors  or  of 

projects/companies who are transitioning to a lower climate impact. 

  Strict  rules  applied  in  a  standard  manner  across  the  whole  EU  does  not  always 
make sense. E.g., environmental norms that apply  when building social housing 
need to be  “national legislation +10% additional effort” to qualify as CA for the 
EIB. This penalises projects from MS with very strict national legislations. 

EQ 7. To what extent has the EFSI contributed to  increased access to financing in 
the EU policy areas  in line with the objectives listed in Article 9(2) of EFSI 
2.0 Regulation? 

SMEW 

Interviews with intermediaries confirmed impact from the EFSI / underlying programmes 
on: 

  Volumes  – EFSI permitting  intermediaries to  expand their capacity or to  sustain 

their offer; 

  Profiles of firms supported – encouraging intermediaries to finance firms unable 
to provide guarantees or other collaterals, more risky customers, smaller firms; 

  Broader spectrum of assets financed (e.g., less liquid assets); and  
  Terms and conditions (e.g., lower interest rates, lower collateral requirements, no 

requirement for any personal liability, and lower fees) 

Beyond the positive impacts on those supported, interviewees found it hard to extrapolate 
and affirm that the EFSI changed the global picture in terms of availability of financing, 
difficulties  persist  on  certain  markets.  EIF  has  been  involved  on  the  markets  for  years. 
Some  did  highlight  changing  perceptions  for  some  asset  classes  (e.g.,  ABS,  Venture 
Capital, and Venture Debt) though. 

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Some  did  also  highlight  positive  learning  effects,  with  intermediaries  now  being  more 
open  for  new  /  more  risky  customers,  intermediaries  being  upskilled  in  reaching  their 
clients.  

See e.g., Polish study last year that evaluated the impact of the COSME guarantee.77 

IIW 

Discussions  were  centred  upon  ways  by  which  EIB  fosters  crowding  in  effect  /  limits 
crowding out: 

  EIB’s  limits  as  per  the  statutes:    EIB  can  only  finance  50%  of  a  project  so  by 

default it brings in other co-financiers. 

  EIB’s  subordinate  position,  risk  coverage  or  longer  maturity  operations  while 

others would choose less risky positions.  

  EIB’s technical and legal due diligence which reassures other investors. The EIB 
project team typically includes an economist and an engineer that are specialised 
in the sector and have experience of this type of operation across all of Europe. 
They participate to the due diligence process and site visits and bring in project 
based  technical  assistance,  outside  of  mandates,  and  help  structure  the  project 
from a financial and technical perspective. This gives comfort to other financiers.  

  Signalling effect from EIB involvement, from its triple A rating. 

Nevertheless  it  was  emphasised  how  crowding-in  /  absence  of  crowding  out  is 
complicated  to  prove.  There  are  anecdotal  claims  arguing  there  has  been  crowding  out 
and public promoters in surveys tend to be incentivised to say they have options on the 
table (otherwise they would be recognising that they are not financeable). 

EQ 8. To what extent have the National Promotional Banks or Institutions and the 
Investment  Platforms  been  instrumental  to  the  achievement  of  the  EFSI 
objectives? 

JC  8.1  NPBs/NPIs  and  Investment  platforms  have  been  largely  effective  in 
stimulating  project  pipelines  in  target  sectors  and  crowding-in  of  private 
lenders / investors 

The EFSI  did  put  the NPBIs on the  forefront  - see 2015  communication  on the role of 
National  Promotional  Banks  and  Institutions  in  supporting  the  Investment  Plan  for 
Europe. There was a KMI saying 15-20% of operations should be in collaboration with 
NPBIs. It was closely followed by Steering Board. Cooperation with NPBIs was meant 
to be a way to  achieve the geographical balance objectives of EFSI, to better cover the 
needs of regional markets (NPBIs know the local needs). NPBIs are also an entry to help 

77    https://www.flipsnack.com/aecmeurope/aecm-statistical-yearbook-2021.html 

https://www.flipsnack.com/aecmeurope/aecm-statistical-yearbook-2020/full-view.html 
https://aecm.eu/wp-content/uploads/2020/07/AECM-Statistical-Yearbook-2019.pdf 

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blending  national  grants  with  EU  resources  (although  opportunities  in  that  regard  were 
underused under EFSI). Generally speaking, collaboration was not seen as impacting the 
mobilisation of private finance.  

EFSI did foster the dialogue, and the collaboration was more publicised. EIB reached out 
to all the NPBIs, through platform and/or bilaterally. Collaboration happened throughout 
the  EFSI  from  the  beginning  (not  new  with  EFSI  2.0  Regulation).  Overall  NPBIs 
involvement  under  the  EFSI  was  high  and  this  created  a  precedent.  Going  forward, 
cooperation  under  InvestEU  will  be  smoother,  some  of  them  will  go  through  the  pillar 
assessment.  

Under the IIW, 17% of operations were in collaboration with NPBIs. Under the SMEW, 
it was 30% (higher under  the SMEW as NPBIs  are also  acting as intermediaries under 
SMEW).  

Most investment platforms were delivered with  NPBIs. No specific goals or number of 
platforms  were  set.  Overall  60  investment  platforms  (IPs)  were  set  up  in  18  MS, 
reflecting an important outreach effort. NPBIs’ experience with investment platforms is 
spelled out below (separately for each window).  

IIW 

their  setup  and 
Investment  platforms  helped 
implementation  were  not  efficient.  NPB  equity  window,  demanded  by  NPBIs,  was  not 
used as per expectations. Some of the operations being discussed never materialised.  

to  reach  smaller  operations  but 

IPs could only be created under the NPB equity window– before that efforts were made, 
but these were unsuccessful.  

By  definition  it  is  not  easy  to  implement  investment  platforms  –  all  partners,  having 
initially different institutional / legal contexts – need to subscribe to the same objectives, 
terms and conditions. Given the large transaction costs and expertise required, IPs were 
more attractive in large MS with experienced NPBIs. Besides, unlike the EIB, NPBIs co-
investing in IPs were not benefiting from the guarantee directly.  

Feedback  from  those  with  experience  setting  up  platforms  was  that  it  was  hard/long  to 
find  a  design  that  would  work  from  the  legal  and  financial  point  of  view.  As  a  result, 
most IPs only became operational (i.e., ready to start making investments) in 2019-20.  

Once set up, investment platforms were often still slow with disbursement. The processes 
were  meant  to  align  interests  –  but  with  not  enough  consideration  for  the  operational 
aspects / causing undue delays.  

Given  all  hurdles  in  creating  the  platforms,  from  the  perspective  of  some  NPBIs,  it 
seemed direct access to EU guarantee would be easier. IPs could still be created together 

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with  the  EIB  to  capitalise  on  the  EFSI  experience  under  InvestEU  –  in  parallel  to  the 
open access.  

SMEW 

The EIF did  not  always  see a substantial  value added from  the setting up of platforms, 
yet  some  platforms  were  created  at  the  demand  of  NPBIs,  in  which  cases  this  has 
crowded in additional budgetary means on the national level - see the example of Cassa 
Depositi e Prestiti (CDP) Italy which structured an investment platform for SMEs where 
a national guarantee was combined with an EFSI guarantee to provide more financing to 
SMEs.  

Otherwise going for normal guarantee/counter guarantee was by far the preferred route. 
Advantages to collaboration with NPBIs come in when NPBIs enable the EIF to deliver 
more e.g., if it helps EIF deliver funds in one big transaction, through counter guarantee 
for instance. NPBIs are also aligned in terms of their risk appetite which is often bigger. 
Otherwise  there  is  more  added  value  collaborating  with  commercial  players  (as  NPBIs 
are already backed by MS).78 

JC 8.2 The cooperation had a positive effect on geographic and sectoral distribution 

Collaboration  was  easier  in  some  countries  than  in  others.  NPBIs  are  very  diverse  in 
terms of levels of sophistication and several MS did not have an NPBI (until recently). 
NPBIs  have  completely  different  business  models  across  MS  and  sometimes  within  a 
MS.  For  example,  Poland  has  16  NPBIs  and  they  all  have  different  rules  in  using 
structural funds.  

Where NPBIs were less strong, the deployment of the EFSI was also less strong despite 
the  EIAH’s  capacity  building  activities.  The  stronger  NPBIs  tended  to  be  most  often 
working with the EIB. 

Where  collaboration  was  less  successfully,  it  is  unlikely  that  the  EFSI  offer  was  not 
suited to local needs – more a matter of: 

  Lack  of  clarity  of  possible  forms  of  cooperation  (expectations  around 
collaboration  with  NPBIs  were  very  high,  but  not  well  defined)  and  initial 
misconceptions - some NPBIs thought EFSI was a source of grant financing; 
  Capacity - some smaller NPBIs did not have structures well developed, there was 
less  confidence  on  the  EIB  side  that  they  were  able  to  effectively  deliver  the 
financing;  

78 In InvestEU, many of the NPBIs are becoming implementing partners but can in some cases also remain 
EIF clients. From the client’s perspective, the situation may thus become more complex, but the EC should 
have a role in steering this. 

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  (Perceived) lack of scope for collaboration / few market opportunities. In smaller 
countries, project promoters looking for grants, EIB financing larger projects that 
NPBIs weren’t in a position to finance, projects of moderate size not needing both 
EIB  and  NPBI  co-financing  (on  larger  projects  from  bigger  markets  there  is 
typically room for both EIB and NPBI). 

EQ  9. To what extent  have the projects supported by the EFSI contributed to the 

creation of jobs and sustainable economic growth?  

It is too early to assess impacts - signatures are still ongoing. EIF conducted a series of 
impact  studies  regarding  how  counter  guarantees  allowed  decreases  in  defaults  and 
increases in sales, employment and assets. These are useful for the study team to review. 

Overall,  the  EFSI  has  managed  to  reach  about  800,000  SMEs  (i.e.,  4%  of  the  total 
number of all EU-based SMEs). Given the figures, it cannot be argued that its impact has 
been extensive in the sense of changing the market. But for the 4% of those companies, 
the impact of the EFSI must have been significant.  

Interviews with project promoters and fund managers highlight benefits: 

  Direct  benefits  in  terms  of  (i)  innovation,  job  creation  and  competitiveness  for 
supported  firms,  e.g.,  as  evidenced  by  growth  in  turnover,  CAPEX  and 
employment ; (ii) climate and environmental benefits (waste treatment, and clean 
energy production) (iii) ESG, governance (audit and reporting requirements); and 
  Indirect  benefits  (e.g.,  indirect  effects  on  employment  and  growth,  local 

communities’ development, and digital inclusion) 

EQ 10. To what extent has the use of the scoreboard (Article 7(4) and Annex II of 
the  EFSI  Regulation)  been  effective  in  ensuring  an  independent  and 
transparent  assessment  of  the  possible  use  of  the  EU  Guarantee  by  the 
individual  pillars 
Investment  Committee?  To  what  extent  have  the 
contributed to the scoreboard's effectiveness?  

No specific insight from interviews. See also EQ3 under relevance. 

EQ  11.  To  what  extent  have  EFSI  communication  methods  been  used  to  engage 

stakeholders effectively? 

There was coordination between the EC and EIB group on the communication aspects as 
foreseen  within  the  EFSI  Regulation.  This  was  never  formalised  as  a  concrete 
communication  agreement  but  article  3  of  the  EFSI  communication  framework  set  out 
the following three objectives for communication: 

  Stakeholder communication on the functioning of EFSI; 
  Public access to information on the performance of EFSI; and 
  Create support from stakeholders and the general public. 

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First,  the  strategy  implemented  mostly  by  the  EIB  focussed  on  explaining  core 
functionalities  and  debunking  myths.  There  were  on  an  ongoing  basis  road  shows  with 
(potential)  co-investors/clients/promoters  to  show  how  the  EFSI  works.  The  Steering 
Board  engaged  quite  regularly  with  different  stakeholder  groups  to  explain  the 
programme and hear from them any concerns. 

At the start, it was a challenge to explain the benefits of using a financial instrument to 
solve the economic issues caused by the financial crisis. The EFSI is complex with a long 
chain of intermediaries. But negative sentiment slowly but surely went down during the 
course of the EFSI.  

Progressively, communication focussed more and more on public access to information 
and  communicating  on  impact  of  the  projects  (country  campaigns,  thematic  campaigns 
on  impacts  on  e.g.,  innovation  or  climate).  The  EFSI  was  revolution  for  how  the  EIB 
communicated  –  the  EIB  developed  new  brochures/  websites  /  presentations/  fliers/ 
infographics/ project examples or descriptions/ pictures/ videos. The EIB also broadened 
the  channels  usually  available/used  by  institutions  to  communicate  these  kinds  of 
initiatives.  e.g.,  fringe  communication  (360  videos  using  VR,  exhibitions  where 
beneficiaries  presented  products,  social  media  campaigns,  and  influencer  videos).  The 
EIB  made  sure  that  anyone  who  wanted  to  know  about  the  EFSI  could  find  out  every 
detail: 

  Live  monthly  updates  of  signatures  –  where  you  could  find  what  projects  had 
been  signed,  benefits/  concrete  impacts.  You  can  find  all  this  information  by 
country and exact geolocation – they had a map with pictures/ links etc. 

  Podcasts and 3rd party content of people recounting how they got jobs while the 

economy was difficult thanks to the EFSI. 

  There was also communication on the EIB study on the EFSI macro impacts. 

From  the  EIB  /  EC  perspective,  the  inter-institutional  coordination  was  very  good 
(monthly  meetings  were  organised).  This  ensured  every  EFSI  project/signature  was 
properly communicated by press release and social media; fact sheets showcasing impact 
and country financing data were frequently updated, for all MS. A range of key metrics 
was followed, covering all channels – print, online, social and traditional media. The EIB 
measured  general  public  engagement  on  their  website  -  monitoring  downloads  of 
information/PDFs, page views.  

Communication activities mainly covered EFSI financing, rather than also the portal/hub. 
For the advisory hub, they did a lot of communication as well – more focused on the hub 
specifically rather than putting it in the EFSI context. The aim was also to show the EU 
at  work  and  what  it  does  to  benefit  businesses,  citizens  etc.  The  messages  were  a  bit 
broader than just explaining and talking about the initiatives.  

Over the course of the EFSI implementation, communication efforts were implemented 
at  the  national  level  too  (through  the  administration,  NPBIs,  the  EIB  local  offices, 

112 

 
 
national associations) but only in some countries, e.g., Poland or France (organisation of 
meetings  with  key  stakeholders,  dissemination  of  information  on  dedicated  webpages). 
Information  was  also  disseminated  via  EU  level  business  associations  for  the  SMEW 
(e.g., the European Association of Guarantee Institutions - AECM). 

In  general,  the  understanding  was  that,  over  time,  the  knowledge  of  the  programme 
improved amongst stakeholders. There is less misconception about the EFSI specifically 
and about programmes of that type more generally. 

Despite the efforts, some stakeholders still reported low awareness levels about the EFSI 
offer especially among final beneficiaries. Some project promoters wished the EIB would 
initiate  contact  with  potential  beneficiaries  (the  same  way  that  EIF  does  reach  out  to 
potential  intermediaries).  Some  intermediaries  feared  that  some  final  recipient  may  not 
even be aware of the exact programme through which they received support. For the IIW 
projects,  more  systematic  use  of  posters  signalling  the  EFSI  /  EU  involvement  was 
advised. 

The  launch  of  the  InvestEU  campaign  in  the  course  of  the  deployment  of  EFSI  was  a 
challenge from the communication perspective.  

Additional evidence: EFSI legacy 

New tool for  public intervention. The EFSI was  the start  of  a paradigm  shift  towards a 
different way of using public money – away from grants. This enabled the use of fewer 
resources  for  the  same  objectives  and  implemented  the  idea  of  attracting  private  sector 
financing  for  public  policy  goals.  However,  with  the  EFSI  there  is  a  trade-off  between 
volume and impact, because to make a greater impact, a high provisioning rate is needed 
(some think that working on high value interventions with 40% provisioning rate will be 
a stretch). 

First  market  driven  instrument.  The  EFSI  reconciled  the  need  for  Europe  to  invest  in 
strategic areas with having a demand driven instrument. It was seen as a market driven, 
not a policy driven instrument. Yet policy objectives were clear. The EIB Group made it 
clear that the EFSI was part of the policy design of the EU. For example, when Covid-19 
pandemic happened, the EIB highlighted the reprioritisation and within a couple of days 
they saw projects come in to support RD&I in this area. 

Change in culture at different levels. This includes: 

  At the national level, spotlight on the need for long term investment, support for 
investments  (in  some  countries  there  was  almost  a  culture  against  investments 
due to the need to fulfil the EU Stability and Growth Pact), changing perspective 
in favour of investment / SME (demonstrating by experience to investors and FIs 
these activities are bankable), upskilling of intermediaries; 

113 

 
 
  At the EU level,  overcoming silo mentality  within the EC,  policy  DGs  working 
together  (thereby  laying  the  ground  for  InvestEU),  enabling  the  EIB  to  think 
differently and focus on riskier projects; 

  Cooperation between the EU and national levels  in favour of investment  / SME 

through NPBIs which also have reciprocally more of an EU dimension. 

Other main achievements claimed. Smaller projects financed (smallest EFSI deal was a 
EUR  7.5  million  deal,  to  be  compared  with  average  EIB  project  size  pre-EFSI),  more 
risky projects (special activities), and new products offering a lot of market opportunities.  

Lessons  learned  for  InvestEU.  The  EFSI  was  a  way  to  learn  how  to  work  with  the 
budgetary guarantee – this experience was helpful when designing InvestEU e.g., under 
the SMEW, pilots were helpful to trial products within thematic areas and helped the EIF 
evolve as  a thematic institution. Lessons taken on board when designing InvestEU (see 
also programme statement) include: 

  Under InvestEU, all financial instruments and advisory are under one roof (now 
EC entry point) and this will reduce the risk of duplication and overlap between 
instruments; 

  More implementing and advisory partners in InvestEU;  
 

InvestEU is still demand driven but has 4 policy windows – it will have more of a 
policy focus; and 

  Simplification  meant  to  foster  blending  grants  from  other  EU  programmes  with 

support from InvestEU (InvestEU rules will apply for the entire project). 

Efficiency 

EQ  14. To what  extent  have  the  governance  structures  put  in  place for  EFSI  IIW 

have been efficient in supporting its implementation? 

There was no criticism of the governance processes within the interview programme. The 
governance seemed to work well. Contributing factors according to interviewees were: 

  Clear separation between the EIB and the EC / between the lender and guarantor; 
  Clear  role  for  the  IC  -  purely  responsible  for  decisions  around  the  portfolio 

guarantee and balancing well policy and financial considerations; 

  Decisions  of  the  IC  being  facilitated  by  the  Guarantee  Request  Form,  strict 

timetable for the IC to make decisions (10 working days); 

  Use of the EIB structures to avoid duplications;  
  Steering  Board  enabling  open  and  transparent  discussion  between  the  EIB  and 
Commission. (advantage of a small group even if there was some criticism that it 
was only the EIB and the EC – plus one parliamentary observer in addition). 

SMEW 

The EIF was not represented in the Steering Board (the guarantee was through the EIB, 
the EFSI was not a tripartite agreement). 

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For  the  SMEW  which  deploys  rather  standardised  products,  approval  took  place  at  the 
product  level  –  not  at  the  level  of  individual  transactions  (approval  of  Steering  Board 
after mandate due diligence and approval of  Board of Directors); the IC played no role 
for the deployment of the SMEW. 

Note:  additional  steps  are  foreseen  under  InvestEU  and  are  deemed  necessary  for  the 
onboarding of new implementing partners – this is expected to significantly slow down 
the time to market and create additional costs. 

Coherence 

EQ  15.  To  what  extent  have  EFSI,  EIAH  and  EIPP  been  coherent  with  other  EU 
interventions  (i.e.,  for  EFSI,  complementarity,  potential  synergies  and  /  or 
overlaps  with  the  European  Structural  and  Investment  Funds,  Connecting 
Europe  Facility,  Horizon  2020,  etc.)  in  terms  of  objectives,  scope  and 
activities?  

JC  15.1  There  was  complementarity  between  EFSI  and  other  relevant  EU 

interventions e.g., CEF, H2020 and ESIF 

There was complementarity in the sense that the EFSI was co-existing with fully funded 
financial  instruments  designed  to  support  the  first  loss  piece.  Under  the  SMEW,  EFSI 
resources were used for the front-loading and top-up of existing mandates.  

Some  existing  financial  instruments  however  had  to  be  refocused  as  their  pipeline  was 
absorbed under the EFSI: 

  Following  the  launch  of  the  Expansion  and  Growth  Window  under  the  EFSI 
Equity  instrument,  the  Equity  Facility  for  Growth  was  refocused  to  prioritize 
funds investing in COSME third countries participating in the programme. This is 
not yet visible in reporting at company level (it takes time for the funds to build 
their portfolio) but already visible at fund level; 

  The CEF-DI Delegation Agreement was amended in June 2019 to focus on green 
innovative investments,  ensure complementarity  with  the EFSI and to  allow the 
absorption  of  NER  300  programme  (managed  by  DG  CLIMA).  The  amended 
CEF-DI  Delegation  Agreement  also  introduced  the  ‘Future  Mobility’  financial 
product  to  support  high-risk  deployment  of  alternative  fuels  infrastructure,  the 
roll out of innovative technologies and smart mobility services. 

The combination of the EFSI with the ESIF (structural funds) was a key challenge. The 
Omnibus  regulation  was  a  step  in  the  right  direction  but  the  regulatory  environment 
remained not conducive to combination.  

JC 15.2 There was no direct competition between the different EU interventions 

In general no, there were no major constraints and understanding that efforts were made 
to ensure complementarities. 

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For  (smaller)  financial  intermediaries,  it  was  reportedly  an  additional  complexity  to 
manage various programmes (different processes, different reporting). Programmes with 
larger  scope  were  found  easier  to  manage,  however  the  limit  of  EUR  150,000  under 
COSME  was  found  restrictive.  Having  a  single  rule  book  for  all  products  including 
thematic products under InvestEU is expected to be beneficial. 

Situations where the EIF would provide counter guarantees and direct guarantees on the 
same market were found to be distortive.  

EQ 16. To what extent have the actions of the EFSI Regulation (EFSI, EIAH, and 
EIPP) been internally coherent in terms of potential synergies in contributing 
to the achievement of the objectives of the Investment Plan for Europe? 

The objective to have internal coherence makes sense. Yet, in the beginning, there was 
no expectations that the EIAH or the EIPP would feed the EFSI pipeline. Expectations as 
to  the  Hub  contribution  increased  with  EFSI  2.0.  It  was  not  the  case  for  the  EIPP 
(whether EIPP projects  get  financing from  the EFSI is  not  monitored).  Under the EFSI 
there  was  no  automatic  cross-referral  systems  e.g.,  to  redirect  promoters  in  need  of 
financing  or  Hub  beneficiaries  to  the  EIPP.  Such  systems  will  be  put  in  place  under 
InvestEU  (and  implementing  partners  automatically  updated  in  case  a  new  project  is 
published on the Portal). 

For  some  interviewees  however,  interlinkages  are  more  of  a  technocratic  concern. 
Advisory services help foster investment but in the rather long run and there cannot have 
too  much  pressure  on  feeding  the  EFSI  pipeline  however  advisory  services  risk  being 
offered  to  projects  that  do  not  really  need  the  support.  As  to  the  EIPP,  it  will  not 
necessarily attract projects that will later become eligible for the EFSI. 

The  EIAH  contribution  to  the  EFSI  IIW  implementation  is  assessed  under  the  EIAH 
section. 

One finding here is  that  the EIAH contributed limitedly to  the SMEW implementation. 
This  was  not  necessarily  seen  as  a  key  limitation  thus  far  under  the  EFSI  but  going 
forward,  under  InvestEU,  advisory  needs  are  expected  to  be  bigger  since  InvestEU  is 
more thematically oriented.  

One interviewee also reminded the linkages with Pillar 3 of the IPE which are often not 
discussed. The EFSI cannot replace an insufficient regulatory environment. For instance, 
it was quickly implemented where capital markets properly functioned and in countries 
with strong NPBIs but for countries without this it took a long time.  

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EU added value 

EQ 17. To what extent has the EFSI, EIAH and EIPP support provided EU added 
value compared to what Member States acting on a national or regional level 
could reasonably achieve on their own? 

The  need  for  additional  support  from  the  EU  is  dependent  on  the  amount  of  support 
available  at  national  level.  In  general,  there  seemed  to  have  scope  for  several  support 
schemes  being  run  in  parallel.  Only  few  issues  of  competition  were  reported.  Bulgaria 
and Greece are two countries where competition with national products was mentioned.  

Many  programmes  /  initiatives  with  national  or  regional  scope  were  quoted  during 
interviews.  These  mostly  concerned  the  SMEW,  and  guarantee  schemes  in  particular 
while  experience  with  more  innovative  instruments  such  as  equity/quasi-equity 
instruments seemed to be more limited. Programmes similar to the EFSI for the IIW type 
of projects were quoted in a limited number of instances (including e.g., the French PIAs 
which have a slightly more upstream positioning). In other countries, the availability of 
some limited grant type of support was mentioned instead. 

Interviewees  generally  did  not  claim  that  the  EFSI  type  of  support  was  completely 
unique in their countries. However, conditions of EU schemes were in general found to 
be more favourable, including: 

  Better pricing; 
  More modest co-financing requirements;  
  Higher guarantee rate; 
  Wider  /  less  restrictive  eligibility  criteria  (including  e.g.,  agriculture  or  leasing, 

non-bank intermediaries); 

  Design that ensured the State aid consistency of EFSI financing.79 ; and 
  Ease of administrating EU programmes. 

Some exceptions were: 

  More  advantageous  national  programmes  in  the  context  of  Covid-19  response 
(providing  coverage  level  above  80%,  90%,  or  100%)  –  with  the  understanding 
however  that  this  type  of  support  can  only  be  temporary  as  intermediaries  will 
need to again take on more responsibility; and  

  (For  the  IIW)  when  financing  projects,  national  players  may  be  able  to  evaluate 
risk  of  financing  given  recipient  in  more  adequate  way  and  therefore  propose 
more favourable conditions. 

79  No  further  State  aid  conditions  or  procedures  had  to  be  followed  by  EIB/beneficiaries  (no  need  of 
checking limits as in case of de minimis aid/ possibility to target companies that used up their de minimis 
limits). 

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Note  that  in  some  cases  it  was  clearly  highlighted  that  the  national  schemes  were 
provided on a much larger scale compared to the EFSI. 

Additionality 

EQ 18. To what extent have the projects and resulting portfolios for which the EU 
Guarantee  was  extended  proved  additional  (in  the  sense  of  the  EFSI 
Regulation, see footnote 8)?  

JC 18.1 EFSI financed crowding in private investment in specific sectors or projects 
of high policy added value which suffer from persistent market failures 

Initially  the  concept  of  additionality  was  more  centred  upon  around  the  risk  profile  – 
special activities. Quickly the concept evolved to focus more on impact (going from an 
input  orientation  towards  impact)  –  focus  on  issues  related  to  market  gaps,  market 
failures and suboptimal investments.  

Progressively, the quality of the documents provided improved.  In that sense, the change 
to additionality definition within the EFSI 2.0 Regulation (EFSI 2.0 Regulation defined 
additionality beyond the special activity status and specified the other elements that had 
to  be  considered)  was  more  an  official  endorsement  of  what  was  already  being 
implemented. It is not clear that it modified the type of projects being financed, though 
one  interviewee  did  mention  that  the  number  of  projects  rejected  by  the  Investment 
Committee was higher after the EFSI 2.0 Regulation. 

Market failures and suboptimal investments are different across countries, so the concept 
of additionality needs to be applied to the needs of the different markets. Some segments 
(SME market, innovation) are viewed as needing support throughout Europe. 

For  the  EIF,  the  concept  of  additionality  is  operationalised  differently.  It  is  embedded 
into  the  product  design  rather  than  added  at  the  level  of  individual  transactions.  For 
instance, terms sheets specify that intermediaries have to change their lending policy or 
include policy fit criteria within eligibility criteria. The only exception is in the Covid-19 
pandemic  context  when  efforts  were  made  to  understand  the  other  schemes  that  were 
available at the national level. 

JC  18.2  EFSI  financed  projects  have  higher  input  additionality  as  compared  to 

standard operations 

SMEW 

Debt 

Attractive features include: 

  For the intermediary level 

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o  Risk  reduction,  high  guarantee  coverage  (especially  on  a  loan  by  loan 

basis for COSME); 
o  Zero fee (for COSME); 
o  Design  that  ensured  the  State  aid  consistency  of  EFSI  financing.  No 
further  State  aid  conditions  or  procedures  had  to  be  followed  by 
EIB/beneficiaries (no need of checking limits as in case of de minimis aid/ 
possibility to target companies that used up their de minimis limits); and 
o  Capital  relief  (the  guarantee  coming  with  AAA  collateral  to  the 

intermediary). 
  For final beneficiaries 

o  Reduced price (benefits passed on to beneficiaries); and 
o  No  collateral  requirements,  possibility  to  use  any  collateral  for  other 

benefits (such as securing other loans). 

Note: one interviewee (from an NPBI) challenged the idea (from the EC) that in the debt 
segment market failures need to be addressed through reduced price. He/she was of the 
opinion that products on market terms can still addressing market failures (playing with 
loan size, maturity) including in the debt segment. 

Equity 

According to interviewees, input additionality took the form of: 

  Financial support role in closing the fund / reaching the target size; 
  Role in attracting further investment due to signalling effects especially when EIF 
commits  to  the  Fund  early.  As  the  EIF  is  traditionally  very  disciplined  in  due 
diligence and in the negotiation of the fund regulation this provides assurance for 
other investors (esp. less sophisticated ones); 

  Support  around  the  Fund’s  governance  and  procedures  (more  professionalism, 

integration of ESG (Environmental, Social, and Governance) factors); and 

  Comparatively  influence  on  Fund’s  strategy  and  the  team  composition  less 

frequent. 

IIW 

The following elements were mentioned: 

  Large ticket size; 
  Diversification of funds;  
  Long tenor / duration (longer tenor is often otherwise not available on the market 

and helps to negotiate better terms with other lenders too); 

  Financial  conditions:  low  rates,  floating  /  fixed  rates  depending  on  needs,  low 

fees, flexibility of drawdowns; 

  Quality stamp (signalling the quality of the project to others); 
  Technical expertise, option to have advisory services. Note: this is not necessarily 
about getting extensive support (no example where scope and size of the project 
would have changed following EIB involvement  but  can be simply  about better 
selling the project); and 

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  Possibility  for  the  EIB  to  tag  the  project  as  eligible  for  green  bonds  (where 

applicable). 

Note that the EIB’s involvement does not necessarily attract other lenders or influenced 
the financial structure of the project if commitment of the EIB comes later. Often on the 
debt side it was not specifically quoted. 

On equity side, examples of crowding in effect through reputational benefits were quoted 
(thanks to  the EIB being seen as a prudent  investor conducting detailed  due diligence). 
Note: interviewees however highlighted in some cases oversubscription and doubts that 
the EIB support was instrumental to others. But  even so, the EIB involvement was still 
seen  as  helpful  e.g.,  to  obtain  better  conditions  from  the  other  financiers  (who  benefit 
from the EIB risk coverage) or to free up resources from the promoter itself. 

JC  18.3  EFSI  financed  projects  would  not  have  gone  ahead  at  all  or  in  the  same 

form without EFSI support 

The potential counterfactual scenarios were described as follows: 

SMEW 

  Lower volumes (for some intermediaries; others think only conditions would have 

been affected, rather than volumes as well); 

  Some specific segments  (e.g., innovative companies) would have been less well 
served (on many markets, there is no competition to serve these specific segments 
and it cannot be assumed companies would have access to finance otherwise); 

  Less favourable financing conditions (shorter tenor, higher pricing); 
  Higher collateral requirements; and 
  Higher co-financing requirements. 

Equity 

  Most  frequently  the  answer  was  that  the  Fund  would  have  been  capitalized 
anyway, other investors would not have necessarily/systematically pulled out but 
the Fund would have been of a lower value and/or taken longer to arrange. 

  Possibly  this  would  have  meant  that  the  average  size  of  supported  investments 

would have been smaller. 

IIW 

  Project may have gone ahead; 
  Alternative financing would often have been secured; 
  The scope/quality of the projects would have remained similar; 
  This is a common argument in general but project promoters did not specifically 
mention that their projects would otherwise have been financed later (referring to 
rather long EIB procedures in baseline scenario); 
BUT 

  Less beneficial conditions, higher project cost overall; and 

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  Less scope to invest into other projects in parallel. 

EQ  19.  To  what  extent  has  the  EFSI  portfolio  had  a  higher  risk  profile  than  the 

portfolio of investments supported by the EIB under its normal operations?  

SMEW 

When selecting intermediaries  the EIF checks there will be higher  risk.  For higher risk 
transactions:  they  calculate  the  standard  risk  coverage  zone  /  standard  expected  losses 
(average  losses,  loss  rates  and  recovery  rates)  and  agree  that  the  guaranteed  portfolio 
would have higher expected losses (by a certain %). There are also “volume” transaction 
where the EIF calculates average business volumes and the FI commits to do at least x% 
more  (more  common  for  public  intermediaries  who  typically  focus  on  lower  rated  
businesses which have difficulties in accessing financing from commercial sources). 

Intermediaries  generally  communicated  that,  thus  far,  portfolios  have  performed  as 
expected, or better than expected – even if default rates are higher than in their standard 
unguaranteed  portfolio.  Same  message  for  EaSI  looking  at  instrument  level  evidence: 
despite lower financial returns compared to COSME (average 5% vs 20%), the financial 
stability of the fund has been maintained over the years.  

The  EFSI  helped  financial  intermediaries  to  take  on  additional  risk,  helped  cover  the 
most  risky  part  of  the  market  because  it  topped  up  fully  funded  instruments  meant  to 
cover first loss piece, meant to be lost in a way. 

IIW 

In general, the EIB can only allocate resources to AAA+-type of projects. The EFSI was 
meant to target higher risk projects given its ambition to cover market failures. The risk 
profile  of  EFSI  financed  projects  was  different  compared  to  what  the  EIB  had  done 
before  (more  similar  to  special  activities).  Within  the  IIW,  the  equity  sub-window  or 
NPB equity window was where the most risky projects were to be found. 

Yet,  the  EFSI  was  not  designed  initially  and  even  over  time  to  support  the  most  risky 
projects. As per the EFSI Regulation, projects should be viable. Most risky projects are 
very uncertain, require higher provisioning / fully funded instruments and were meant to 
be addressed by other FIs run in parallel such as InnovFin. 

EIB would not have been able to support the same amount of special activities at its own 
risk. There was  no pre-existing plan to  increase  the special activity. There are limits  to 
the amount of risk the EIB can take on its own balance sheets and provisioning it needs 
to set aside. Some operations could certainly have been delivered without the EFSI (e.g., 
doubts were cast for some projects such as the case of tram wagons or 5G deployment) 
but not the whole portfolio – this would have affected prudential ratios /statutory limits 

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and/or credit rating. This argument was developed in the EIB EV (2018) evaluation (even 
if no paper modelling the impact of the absence of the EU guarantee is available). 

Client experience accessing EIB / EIF programmes / loans 

SMEW 

 

 Well-articulated  decision  making  processes  at  the  EIF,  even  some  bureaucracy, 
generally  understood  as  necessary,  certain  non-negotiable  ‘must  haves’  for  the 
EIF. 

  Good relation with the EIF teams, supportive teams, fast and concrete responses 

to any question, professionalism, dedicated to make transactions a success.  

  Demanding  in  terms  of  information  to  be  provided  at  the  signature/application 

process. Potential of digitalisation not fully used. 

  One comment  on approval  being  rather quick, but  the legal  aspects,  onboarding 
which take too much time. Months during which the envelope could be deployed 
are  lost  as  a  result  (not  fully  lost  because  investments  can  be  brought  into  the 
portfolio a posteriori) – but managers lack visibility.  

  Becoming too burdensome and complex for more recent / future programmes. A 
lot  of  information  requirements  for  the  final  level  too,  which  can  discourage 
companies. 

  COSME  implementation  comparatively  rather  favourable  with  respect  to  admin 
costs.  COSME  instrument  less  demanding  –  broad  scope,  flexible  in  terms  of 
implementation and absorption, and easy reporting. The program did not involve 
invoices and had a small burden in terms of management.  
InnovFin as  a more specific programme involves more work on implementation 
(transfer of benefits based on risk assessment, more eligibility criteria that need to 
be translated into internal eligibility tool).  

 

  On  eligibility  criteria:  one  can  see  that  they  are  meant  to  be  applicable  in  27 
countries  –  there  is  a  need  to  translate  the  criteria  into  local  definition  /  legal 
terms.  (e.g.,  is  it  possible  to  finance  working  capital  under  the  guarantee,  what 
counts as working capital). Same goes for the definition of innovative companies 
–  quite  subjective  in  the  end  (French  fund  referred  to  local  equivalent  –  e.g. 
targeting  companies  that  qualify  as  “Jeunes  Entreprises  Innovantes”).  To  some 
extent  this  may  be  inevitable,  but  correspondence  tables  would  help.  It  works 
nevertheless because there is an understanding there is openness and support on 
the EIF side as long as intermediaries abide to the contractual documentation.  
  EaSI  uses  a  very  pragmatic  way  to  check  supported  companies  are  social 
enterprises: the intermediaries have to annex a short form to their loan contract, in 
which supported companies have to  answer a series of short questions and self- 
declare  that  they  are  social  enterprises  (easier  to  implement  than  instruments  at 
the national level).  

  Administration / management easier compared to national programmes (though it 

depends on the countries) 

  Reporting tedious the first time but experience helps and it remains manageable. 

Some calling for semi-annual reporting instead of quarterly reporting.  

  Flexibility  to  extend  the  duration  and  volumes  of  guarantee  programmes.  Same 
flexibility when an envelope should on the contrary be downsized (in case of low 

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implementation  rate,  proactiveness  reaching  out  to  the  FI,  solutions  offered  to 
switch support programmes). 

  The EIF pays quickly whenever the bank calls a guarantee. 
  As  an  unintended  positive  effect,  collaboration  with  the  EIF  helps  connect  FIs 

with relevant EU level associations and influence policy making. 

IIW 

  Demanding  appraisal  process  –  questions  /  requirements  are  helpful  though  and 

 

contribute to project development. 
 Long  approval  processes, 
procedures  (extensive  and  excessive  reporting)  which  are  heavier 
commercial banks’ respective processes, sometimes creating detrimental delays. 

internal  processes  and  administrative 
than 

lengthy 

2.  EIAH 

Relevance 

EQ 1. To what extent have the EIAH’s services (Article 14(2) of the EFSI and EFSI 
2.0 Regulations) been relevant for the accomplishment of its mandate (Article 
14(1) of the EFSI and EFSI 2.0 Regulations)? 

The  EIAH  covers  both  types  of  activity:  i)  upstream  activities  e.g.,  developing 
investment/advisory platforms; and ii) 'last mile' advisory support. 

Both types of activities have an impact on investment although upstream activities take 
more time to translate into investments. The ECA audit encouraged the focus on LPAs in 
more  recent  years  but  the  EIAH  being  demand  driven  it  continued  to  serve  the  whole 
project lifecycle. 

The  ramp  up  phase  took  longer  than  planned,  high  quality  requests  were  not 
spontaneously flowing in from all eligible sectors / countries. With EFSI 2.0, the EIAH 
became  a  lot  more  proactive,  tried  to  be  more  visible  and  created  new  approaches  to 
delegate activities including: 

  Increased networking: within the EIB, within the NPBI network, with Enterprise 
Europe Network (helpful – for example in providing local contacts that promoters 
can reach out to for support in developing their projects); 

  Drawing on partnerships: with EBRD to deliver work to the benefit of SMEs; and 
  Drawing  on  NPBIs:  through  a  call  for  expression  of  interest  offering  NPBIs  the 

opportunity to develop their advisory support capacity. 

Overall, 2/3 of the EIAH assignments took place in the 'cohesion countries'. The monthly 
screening  group  meetings  were  helpful  in  determining  who  was  best  placed  to  deliver 
advisory  support  and  select  assignments  that  should  be  prioritised  within  the  overall 

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portfolio e.g., to help offset any geographic biases. Note: the needs assessment developed 
by PwC was helpful to identify the EIAH priorities within various MS.  

EQ 2. To what extent has the design and implementation of the EIAH responded to 
the  needs  of  beneficiaries  (Public  and  private  project  promoters;  National  / 
Regional authorities; Financial intermediaries; NPBs?) 

Overwhelmingly positive feedback: 

  Very positive experience; 
  Very responsive contact point; 
  Collaborative processes, consultation of all key stakeholders; 
  Professionalism; 
  Support tailored to the specific needs;  
  Support available in local language (key to communicate with technical staff); 
  High level of expertise; 
  Good  experts  hired  (mix  of  international  and  local  consultants  with  local 

knowledge); 

  Very  practical  consulting,  hands-on  support 

(rather 

than 

just 

issuing 

recommendations); 

  Peer review / QA of the work of consultants by the EIAH; 
  Gathering experiences of other (more advanced) countries interesting; 
  Valuable guidance, application of EU standards; 
  Comprehensive  support,  additional  advisory  support  available 

implementation phase in case of need; and 

  EIAH team patient with bureaucracy on beneficiary’s side. 

for 

the 

Caveats were: 

  Experience  is  not  necessarily  transferable  across  EU  countries  given  different 

regulatory landscapes; and 

  In one case, the hired consultants performed poorly. 

Effectiveness 

EQ 3. To what extent has the EIAH deployment fulfilled its mandate and objectives 

as listed in Article 14 of the EFSI and EFSI 2.0 Regulation? 

JC 3.3 EIAH assistance provided resulted in investment projects being implemented  

EIAH often reportedly leads to advancement of projects: 

 
 Pivotal for the success of the project, advancement of the project; 
  Higher quality outputs, less time taken for the preparatory phase; 
  Higher quality project, better prepared; 

124 

 
 
 
 

In  a  better  position  to  select  most  appropriate  financing  structural,  accurate 
estimate of total project cost, financial education among technical staff too; and 

  For some projects, attracted funding, and the EIB financing. 

The mandate of the EIAH is very broad. In a context of political pressure to justify Hub 
impact,  there  was  an  increased  focus  on  link  between  advisory  and  investment.    LPAs 
were prioritised as it appeared more efficient.  

The  link  is  weak  between  the  EIAH  and  the  EFSI  –  the  EIAH  cannot  guarantee  EFSI 
financing. However, since the ECA audit and EFSI 2.0 Regulation, expectations are high 
regarding  link  between  advisory  services  and  the  EFSI  pipeline.  It  risks  being 
counterproductive  if  the  focus  is  too  much  on  feeding  the  EFSI  pipeline  –  advisory 
services  risk  being  offered  to  projects  that  do  not  really  need  the  support.  All  the 
upstream activity and support for more difficult to serve are also impactful but less easy 
to  capture,  it  takes  longer  to  translate  to  investment.  Fortunately,  as  the  EIAH  was 
sufficiently resourced, all types of activities were still served.  

The EIAH assignments did enter the EIB lending appraisal system – see reporting. One 
facilitating  factor  was  that  after  EFSI  2.0,  it  was  agreed  that  staff  from  the  projects 
directorate  –  the  EIB  staff  developing  the  projects  –  would  deliver  the  EIAH  support 
(clearly  delineating  their  time  under  the  EIAH  from  the  normal  EIB  due  diligence  on 
their time sheets). 

There  are  rules  put  in  place  to  avoid/manage  conflict  of  interest  under  the  EIAH.  The 
objective is to optimize financing structures in the best interest of the project rather than 
for  considerations  such  as  feeding  the  EFSI/EIB  pipeline  (as  highly  priced,  the  EIAH 
may not be the best solution for supported projects).   

Monitoring  system  currently  in  place  do  not  track  when  financing  is  received  (if  not 
coming  from  EIB).  Only  the  one-off  follow  up  exercise  provided  some  information  on 
past  projects.  There  is  no  overall  indicator  measuring  the  success  rate  of  the  projects 
assisted in securing financing.  

Going  forward,  the  InvestEU  Advisory  Hub  will  have  a  less  broad  mandate,  and  more 
emphasis will be put on project related work. 

JC  3.4  EIAH  contributed  effectively  to  other  objectives  including  building  of 

capacities in less developed markets, development of investment platforms 

The  EIAH  had  in  place  contracts  with  big  NPBIs  but  also  with  smaller  NPBIs  –  with 
different focus. Despite initial concerns, it was not the case that only NPBIs with the best 
capacity  benefitted  from  collaboration  with  the  Hub.  Mixed  results  however  from  the 
EIAH’s call for expression of interest: only a few large NPBIs were effectively able to 
provide advisory support, some NPBIs did not have the mandate to deliver advisory, or 
considered it heavy to manage. 

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The  EIAH  has  also  been  providing  capacity  building  to  intermediaries  that  are  serving 
SMEs.  For  example,  they  have  supported  financial  intermediaries  working  with  multi-
beneficiary  investment  loans,  suggesting  new  products/clients/  marketing  materials  to 
meet climate action targets. These are often for SME clients.  

The EIAH has started to provide advisory services for the EIF client base and this will be 
expanding under InvestEU.  

Efficiency 

EQ  6.  To  what  extent  have  the  financial  resources  provided  to  the  EIAH  been 
appropriately  sized  to  meet  its  objectives  and  how  could  they  have  been 
optimised? 

JC 6.1 EIAH spending is in line with its budgetary allocation 

In the first years of its existence, the Hub underspent its budgetary allocations (ramp up 
phase). This reflected time needed to build-up of the network, conduct awareness raising 
activities. It naturally took time to find the right positioning for the Hub, disseminate the 
message. Project promoters do not always realise that they would benefit from advisory – 
demand does not flow in by itself. Once first contacts are established, time is needed to 
scope the needs and ensure productive engagement and filter out requests.  

Overall, the budget was adequate in terms of allocation. It reflected quite well the level of 
demand for the EIAH services. There was still some underspending though. Reasons are 
less  clear,  pandemic  may  have  played  a  role  (dynamic  was  good  before).  Besides,  it  is 
possible  that  the  overlap  with  the  InvestEU  is  confusing.  The  EIAH  still  exists  and 
provides support until end-2023, but there is no longer any EFSI financing behind. 

JC 6.4 The Hub pricing policy was seen as adequate 

Cost sharing with the beneficiary was introduced to foster ownership. The pricing policy 
was set in stone in the EFSI Regulation  and maintained under EFSI 2.0. However, this 
choice created also a certain barrier to access the services and created competition among 
the  different  advisory  offers,  as  the  EIAH  was  the  only  public  scheme  requiring  cost 
sharing with beneficiaries. 

Besides, the fees  collected were not  significant  / not  really making  a difference from a 
cost coverage perspective. 

In that context, some flexibility was introduced through the pricing policy paper agreed 
by  the  EIAH  Coordination  Committee  –  but  only  in  relation  to  light  project  advisory 
beneath a certain project size (of EUR 20 000) due to legal constraints. 

From  the  beneficiaries’  perspective  (all  from  the  public  sector),  the  free  character  was 
important: alternative services, offered by the private sector, would most likely not have 

126 

 
 
been  affordable.  Also  at  an  early  stage  in  the  project  lifecycle  it  can  be  hard  to 
demonstrate that the benefits  from  advisory services outweigh the costs, and gather the 
necessary support within the organisation to pay for the services.  

EQ 7. To what extent has the EIAH governance model been efficient in meeting the 

EIAH objectives? 

JC 7.1 The decision making processes, roles and priorities were clear. 

The governance structure of the EIAH was based on a small coordination committee see 
FAFA  (Financial  and  Administrative  Framework  Agreement)  /  FPA  for  details.  It  was 
found to be quite agile – used as a principle to develop that of InvestEU. 

However,  it  was  not  easy  to  contract  other  advisory  partners  through  the  EIB  to  cover 
gaps outside of the EIB expertise (complex processes) – that is why it will be possible to 
contract other advisory partners directly under InvestEU. 

JC 7.2 Reference documents maintained the necessary degree of flexibility to adjust 

during implementation 

The  EIAH  partners  welcomed  the  option  to  extend  the  grant  agreements  beyond  their 
initial due date, to facilitate absorption. 

JC 7.3 Average reaction time is seen as reasonable 

Overall,  fast  response,  good  communication.  According  to  beneficiaries,  delays  were 
more  internal  (time  needed  to  clarify  needs,  get  approval,  gather  the  necessary 
documentation) and there was nothing the EIAH could have done to speed the processing 
the initial stages, limited bureaucracy. 

EQ 8. To what extent have EIAH communication methods been efficiently used to 
promote  its  service  to  public  and  private  project  promoters  (including 
national promotional banks or institutions and investment platforms or funds 
and regional and local public entities)? 

Visibility  of  the  Hub  is  generally  now  quite  good,  judging  by  website  use,  requests 
received.  

There is good brand recognition for the Hub, the move to DG ECFIN of the central entry 
point as part of InvestEU may be disruptive from that perspective. 

127 

 
 
 
 
 
 
Coherence 

EQ  9  To  what  extent  has  the  EIAH  proved  coherent  with  other  existing  advisory 
initiatives in terms of additionality, potential synergies and/or overlaps? 

JC  9.1  Adequate  processes  were  in  place  to  ensure  the  Hub  provides  services 

additional to those already available under other EU programmes 

The  EIAH  came  late  in  the  middle  of  the  MFF  when  there  were  existing  initiatives  in 
place that is why they had to test additionality each time. The purpose for the EIAH was 
to capture projects that had been missed by other initiatives– on a demand driven basis.  

Now  with  InvestEU  Advisory  Hub,  coordination  will  be  easier:  all  projects  are  filtered 
centrally. InvestEU Advisory Hub only needs to coordinate with DG REFORM. 

There has been no perceived overlap between the work conducted by the EIAH and other 
initiatives, e.g., ELENA. The EIAH channelled promoters to ELENA whenever relevant. 

JC 9.2 Synergies with other EU advisory initiatives were exploited  

Compared to other EU advisory initiatives, the EIAH has a broader remit. Opportunities 
for collaboration included: 

  Financial  advisory  services  for  projects  applying  to  CEF  Transport  Blending 
Facility (how to structure their projects from a financial standpoint, how to create 
a special purpose vehicle (SPV), as well as the mixing of the EIB and CEF debt 
instruments); 

  Upstream support to ELENA applicants; and  
  EIAH  support  to  projects  implementing  strategic  frameworks  developed  with 

JASPERS support. 

On  the  side  of  InnovFin  Advisory,  scope  for  collaboration  was  limited  by  the  EIAH 
pricing policy towards the private sector. 

EU added value 

EQ 10. To what extent has the EIAH support to project promoters and beneficiaries 

provided EU added value? 

The EU dimension was  important  – to learn  from other EU countries, to develop some 
transferrable guidelines useful across MS, to benefit from the EIAH experience with the 
EU regulations, to make sure impact assessments complied with the EU taxonomy.  

The  EIAH  was  able  to  join  together  the  market  part,  the  EU  regulation  and  the  local 
regulation limitations. 

128 

 
 
 
Seal  of  approval:  The  report  was  read  very  carefully  and  well  received  because  it  was 
coming from a respectful institution. Opened doors, leveraged political support (EU seal 
of approval). 

EQ 11. To what extent has the EIAH support provided EU added value compared 
to  what  Member  States  acting  on  a  national  or  regional  level  could 
reasonably achieve on their own? 

No  equivalent  support  or  possibilities  quite  limited:  not  affordable  on  marketplace, 
various  quality  of  advisers,  provision  of  theoretical  support  /  recommendations  (but  no 
hands  on  practical  support),  hard  to  select  the  best  advisory  providers  through  public 
tenders, high competition for the public schemes when available.  

Note: only in few Western countries (the UK and Netherlands), there has been virtually 
no EIAH assignment, advisory support through the private sector was reportedly already 
very present.  

In delivering projects, the EIB often complement their internal EIB expertise with that of 
private consultants – they use the private sector and consultancy on the majority of the 
bilateral assignments. This brings in both EU added value and local expertise and is quite 
unique compared to what private sector alone can offer. There is an added value from not 
hiring directly consultancies (EIB/EIF independence) 

In the absence of EIAH support: 

  The  project  would  have  gone  ahead  but  at  a  slower  pace  –  e.g.,  there  would  be 

delays to understand how to achieve financing; 

  The EU dimension would not have been taken into account; and 
  There would not have been the benefits in terms of interdisciplinary upskilling – 

technicians gaining knowledge/understanding of financing structures. 

In France, where an NPBI advisory offer is already  available, yet financing limited, the 
EIAH became a financing partner and allowed more advisory support to be provided. 

3.  EIPP 

Relevance 

EQ  1.  To  what  extent  have  the  EIPP’s  design  and  activities  been  relevant  to  its 

mandate (Article 15 of the EFSI 2.0 Regulation)? 

When  the  idea  of  an  EIPP  emerged,  it  was  focused  on  infrastructure  projects  (list  of 
2,000 projects from MS). A fraction of these ended up on the EIPP but the portal never 
really gained much traction. 

129 

 
 
 
The EC team decided to shift the focus of the portal. The minimum project size was 
lowered from EUR 10 to 1 million to give opportunities to SMEs and eventually also 
start-ups to be placed on the portal. In fact now in InvestEU the limit was further lowered 
to EUR 500,000. Lowering the size enabled the portal to cover different types of projects 
beyond infrastructure. The EIPP now works mainly for SMEs or startups (different 
positioning). This responded to demands from promoters and policy DGs – particularly 
DG GROW and RTD. The EUR 1 million could still be a limitation for start-ups in the 
sense that first seed investment in Europe usually ranges from EUR 50,000 -1 million 
(the EU average is EUR 200,000) depending on the type of business. 

The publication charge  (of around 100 EUR) was removed since this was a burden  for 
many companies and also for the team in charge of the Portal – and was not too helpful 
from a cost coverage perspective.  

To  generate  interest,  partnerships  were  set  up  e.g.,  with  the  European  Business  Angels 
Network, Bpifrance and other partners. Doing this helped them to gain traction and there 
was  more  interest.  They  occasionally  organize  events  together  where  companies  can 
pitch to  investors. This  is additional to  the core EIPP mandate. However, they do have 
budget available for this purpose. This is a good way to give visibility to the Portal too 
(usually  these  events  have  300-400  attendees).  Organising  events  in  partnership 
facilitates the achievement of a good investor/promoter ratio – first events organised only 
by the EC did not bring enough investors. 

From  the  user  perspective,  the  Portal  is  user-friendly  and  registration  procedures  fairly 
easy. The template to be filled in resembled a business plan template. Some difficulties 
were  reported  with  the  terminology  used  (EU  jargon  with  no  glossary  of  terms),  some 
fields hard to fill in for early stage projects (e.g., details on the financing of the project, 
user  experience  and  user  interface  being  outdated  (lacking  e.g.,  automatic  matching 
functions). 

Effectiveness 

EQ  2.  To  what  extent  has  the  EIPP  deployment  fulfilled  its  mandate  as  listed  in 
Article  15  of  the  EFSI  2.0  Regulation?  How  effective  has  the  EIPP  been  in 
increasing  visibility  and  information  available  on  current  and  future 
investment projects in the Union? 

The EIPP delivered on its objectives to provide visibility to investors globally as regards 
available investment projects in the EU (around 1,100 projects are on the portal). There is 
no public communication on the number of investors registered on the Portal.  

A  number  of  projects  have  also  received  financing  after  being  published.  Once  on  the 
Portal, the team sends a notification to project promoters every three months to ask them 

130 

 
 
 
to  update  their  information  including  on  amount  of  financing  secured  (some  project 
promoters  complained  these  emails  are  sent  too  frequently).  This  is  how  EIPP  track 
whether the projects have received financing. At the end of 2021, there were around 80 
projects confirming that they have secured financing or 8% of the total projects. This is 
considered to be satisfactory (there was no target set on this aspect). Note however that 
projects may have received financing from a range of sources including internal/external 
sources.  There  is  no  attempt  to  capture  more  precisely  the  role  of  the  EIPP,  the  team 
assumes  that  the  Portal  played  a  role,  because  projects  became  visible  to  investors 
through the Portal.  

For the EIPP, it was not an objective to feed the EFSI pipeline. There is no monitoring of 
the EIPP contribution. With the InvestEU Project Portal, they have made some changes 
to help promoters supported by the Portal to gain visibility with implementing partners, 
financial intermediaries  etc. The Portal  will also give projects  an opportunity to  submit 
an  advisory  request  when  registering  on  the  Portal.  These  changes  aim  to  promote 
interlinkages.  

Events  were  also  organised  (online  during  the  pandemic)  –  in  partnership  with  e.g., 
European Business Angels Network (EBAN). 

On the side project promoters, expectations related to: 

  Enhanced visibility at the EU / global level; 
  Possible contacts with investors; 
  Potential for increased financing opportunities; and 
  Possible networking opportunities, e.g., with business partners. 

Reported issues related to: 

 

 Contact  by  scam  investors  (to  prevent  this,  projects  on  InvestEU  Project  Portal 
will  be  visible  only  to  registered  investors  that  went  through  the  tightened 
screening process); 

  Lack of serious/ credible investor proposal, lack of visibility towards certain types 

of investors (e.g., Venture Capital); 

  Absence of secured financing for published projects; and 
  Lack of networking opportunities. 

From the lender / investor perspective, there are impressions that: 

 

 Traditional  channels  are  better  ways  to  reach  out,  investors  do  not  go  on 
platforms to identify projects, this idea is “technocratic”; 

  The EIPP attracts projects that are not mature enough, not yet ready for financing 

or even low quality; and 

  Project descriptions too high level to generate interest of investors. 

131 

 
 
 
Efficiency 

EQ  3.  To  what  extent  have  the  financial  resources  used  for  the  EIPP  been 
appropriately sized to meet EIPP's objectives and how could they have been 
optimised? 

The actions / spending were calibrated to fit into the budget, split across tasks relating to 
communication, IT development and screening: 

 
 IT development costs were higher in initial years (now, infrastructure is in place); 
  There  were  savings  on  communication  budget  with  the  organisation  of  online 

events; and 

  Costs related to screening processes, when relating to internal staff time costs, are 

not captured in the budget. 

Coherence 

EQ 5. To what extent has the EIPP proved coherent with other existing major EU-

wide platforms (complementarity, potential synergies and/or overlaps)? 

At one point in time, the number of platforms was flourishing (e.g., Global Infrastructure 
Hub).  Now  it  is  less  the  case  (new  platform  in  the  pipeline  in  Bulgaria  however).  It  is 
costly  to  maintain  a  platform,  to  animate  it  (via  communities,  events)  and  be  able  to 
know  companies  and  their  ecosystem  so  well  as  to  be  able  to  voluntarily  generate 
sustainable matches between specific people.  

The main initiative with similar objectives is Bpifrance's EuroQuity platform.  

EuroQuity  has  been  partnering  with  the  EIPP  for  about  four  years  now.  It  is  seen  as 
helpful to  integrate more into the project  promoter and investor community. EuroQuity 
and  the  EIPP  organise  together  some  events  /  ePitching  sessions,  first  one  in  2018. 
Beyond  contacts,  participating  companies  also  valued  helpful  feedback  on  how  to 
upgrade  their  website.  Overall  feedback  from  EuroQuity  was  more  positive  than  the 
EIPP (seal of excellence, deal flow is qualified, more interactive, more user-friendly). 

From  the  beneficiary  perspective,  there  is  some  regret  that  there  is  no  linkage  or 
interoperability  between  the  different,  largely  fragmented  and  partially  overlapping, 
initiatives  and  no  central  or  coordinating  mechanisms  matching  the  firms  with  the 
financing tools so as to minimize time loss.  

At  the  EU  level,  there  is  now  as  well  the  EIC  (European  Innovation  Council)  online 
Community.  The  main  added  value  of  the  portal  is  the  high-quality  projects  which  are 
being  published.  Their  promoters  are  usually  winners  of  the  European  Innovation 
Council Prize.  

132 

 
 
 
EU added value 

The  reasons  for  using  the  platform  relate  to  the  fact  that  it  is  EU  focused  and  it  is 
neutral/public/free-of-charge.  

EU  added  value  could  be  increased  through  higher  interconnection  across  various  EU 
opportunities and scheme 

133 

 
 
ANNEX VI. COMPARATIVE FEATURES OF EFSI SUPPORTED FIRMS 

 Introduction 

Within  the  framework  of  this  evaluation,  the  study  team  conducted  a  sample-based 
analysis  comparing  the  characteristics  of  EFSI  supported  firms  versus  the  general 
business  population.  This  section  presents  the  results  of  this  analysis.  It  is  divided  in 
three parts: (i) elaboration of the methodological approach to the analysis; (ii) description 
of the data employed alongside the cleansing and sampling process; and (iii) the results 
and findings of the analysis. 

Methodological approach 

This analysis is based on the EIF dataset containing a set of 9,552 unique EFSI backed 
loans  to  companies.  We  compared  several  characteristics  and  performance  metrics 
relating to a selected sub-sample of final beneficiaries with a larger sample of firms that 
have  not  received  any  financial  support  from  the  EFSI  (“comparison  group”)  over  the 
period  2013  –  2021.  In  theory,  EFSI  final  beneficiaries  can  be  expected  to  exhibit 
different characteristics and behaviour compared to the comparison group e.g., size, age, 
evolution of turnover and employment etc. The overall aim of this exercise was to check 
if there are any differences in characteristics and behaviour of the two groups: 

  Firm level characteristics 

o  Age  -  whether  EFSI  final  beneficiaries  are  younger  than  the  comparison 

group; and  

o  Size  -  whether  EFSI  final  beneficiaries  are  on  the  smaller  side  as 

compared to the average size of business population. 

  Performance metrics 

o  The overall evolution of employee numbers and yearly turnover; 
o  Interest paid; and 
o  Evolution of tangible and intangible assets. 

The team sought to analyse the above indicators where the data allowed for comparative 
variables. Trends would highlight differences through the years following the EFSI loan. 

Data acquisition 

To  create  a  comparison  group,  the  team  used  Orbis,  a  dataset  provided  by  Bureau  van 
Dijk which contains financial information on millions of EU companies. Through various 
iterations, and thanks to the collaboration of the EC, the team extracted data from Orbis 
for  3,269  final  beneficiaries  from  the  original  list  of  EIF  loans.  Those  companies  are 
based in the following countries: ES, GR, PL, IT, BG, FR, CZ, and LV. 

134 

 
 
 
 
Figure VI.1: Sectoral distribution of the sample of EFSI final beneficiaries 

0,21%

0,15%

0,21% 0,24%

0,31%0,37%0,43%

0,06%

1,04%

0,49%

1,07%

1,13%

21,66%

11,13%

9,36%

6,70%

8,90%

6,97%

1,35%

1,28%
1,90%2,17%
2,45%

Biotechnology and Life Sciences

Banking, Insurance & Financial
Services
Communications

3,43%

3,52%

3,67%

4,59%

5,20%

Mining & Extraction

Media & Broadcasting

Transport Manufacturing

Utilities

Miscellaneous Manufacturing

Waste Management & Treatment

Leather, Stone, Clay & Glass
products
Property Services

Printing & Publishing

Source: EFSI, SMEW administrative data 

As shown in Figure VI.1 above, the biggest group of EFSI final beneficiaries come from 
the wholesale, construction, business services and retail. The vast majority (87.86%) are 
either medium or small companies.  

The  comparison  group  has  been  extracted  from  Orbis  following 
the  overall 
characteristics  of  the  sample  of  EFSI  final  beneficiaries:  being  an  EU  company,  either 
small or medium and having at maximum 250 employees. From the 7 million companies 
matching  the  profile,  the  team  extracted  a  randomly  generated  subsample  of  20,000 
companies (“comparison group”) to  match with  the 3,269 from  the sample of  the EFSI 
final beneficiaries (“treated group”). A dummy variable was used to distinguish between 
the  two  groups.  The  team  selected  companies  from  all  27  EU  countries  for  the 
comparison group, as the program was rolled out in the entire EU. 

135 

 
 
 
 
 
 
 
 
Figure VI.2: Comparison group firms’ sector 

0,22% 0,25% 0,35% 0,37% 0,39%0,61% 0,67% 0,84%

0,87%

1,03%1,30%

16,74%

1,87%

14,44%

10,26%

4,18%

5,00%

5,05%

1,00%
1,03%

1,66%

2,56%

2,95%

2,97%

Mining & Extraction

Biotechnology and Life Sciences

Miscellaneous Manufacturing

Transport Manufacturing

Communications

6,87%

Waste Management & Treatment

9,05%

7,47%

Leather, Stone, Clay & Glass
products

Source: Orbis 

The random generation of a comparison group subsample led to significant differences of 
population  characteristics.  Here  the  most  representative  sectors  are  mining  and 
extraction, biotechnology and life sciences, manufacturing and communication.  

The team  performed a comparative trends  analysis  on the following indicators:  number 
of employees, operating revenue (turnover), intangible fixed assets, tangible fixed assets, 
working capital, and interest paid (all expressed in millions of EUR). 

Other  key  metrics  were  analysed  without  a  time  variable  (size,  average  lifespan  and 
innovation).  The  reason  being  that  Orbis  presents  limitations  on  small  firms’  data 
availability, as not all indicators are reported in a timely manner. Most of financial data 
contained  in  Orbis  provides  partial  information,  thus  preventing  any  meaningful 
subsampling.  The  process  led  to  sample  selection  bias  and  reduced  efficacy  of  the 
comparison  group.  To  reduce  any  risks,  the  team  opted  for  a  barebone  comparison  to 
enhance robustness at the expense of granularity. 

Outcome and key findings 

Figure VI.3 shows that the average lifespan of the comparison group is 21 years, whereas 
the average age of EFSI final beneficiaries is only 16.5 years. 

136 

 
 
 
 
 
 
 
Figure VI.3: Average firms age by group (years) 

Comparison

Treated

0

5

10

15

20

25

Source:  EFSI,  SMEW  administrative  data  and  OrbisFigure  VI.3  shows  that  EFSI  final 
beneficiaries  pay lower levels  of interests than comparison  group. Normally, we would 
expect  EFSI  final  beneficiaries  to  benefit  from  lower  cost  of  financing.  But  this  data 
should  be  interpreted  with  caution  as  we  have  no  information  on  their  respective  debt 
levels, or interest rates. 

Figure VI.4: Interest paid by group in million EUR 

0,40

0,35

0,30

0,25

0,20

0,15

0,10

0,05

0,00

2013

2014

2015

2016

2017

2018

2019

2020

2021

Treated

Comparison

Source: EFSI, SMEW administrative data and Orbis 

Figure  VI.4  and  Figure  VI.5  expose  respectively  tangible  and  intangible  fixed  assets 
trends.  Both  trends  are  positive  and  broadly  follow  the  same  growing  curve.  Notably, 
companies  belonging  to  the  treated  group  present  average  intangible  fixed  assets  being 
lower than the comparison group (Figure VI.4). 

137 

 
 
 
 
 
 
 
Figure VI.5: Tangible fixed assets in million EUR 

3,50

3,00

2,50

2,00

1,50

1,00

0,50

0,00

2013

2014

2015

2016

2017

2018

2019

2020

2021

Treated

Comparison

Source: EFSI, SMEW administrative data and Orbis 

Figure VI.6:  Intangible fixed assets in million EUR 

2,00

1,80

1,60

1,40

1,20

1,00

0,80

0,60

0,40

0,20

0,00

2013

2014

2015

2016

2017

2018

2019

2020

2021

Treated

Comparison

Source: EFSI, SMEW administrative data and Orbis 

When analysing size however, there is a specific timeframe (2016-2019) where turnover 
and employees’ numbers significantly diverge. In both Figure VI.6 and Figure VI.7, one 
can  notice  how  treated  companies  experienced  a  resurgence  in  their  key  factors  as 
opposed  to  control  firms.  In  the  case  of  employment,  it  is  clear  how  trends  look 
substantially  opposed  during  these  three  years.  It  is  also  the  timeframe  where  the 
European  Commission  rolled  out  EFSI  funding.  It  therefore  suggests  there  might  have 

138 

 
 
 
 
been  a  series  of  factors  reversing  treated  companies’  trends  in  2016-2019,  possibly 
concurring with the availability of EFSI financing, however this analysis did not attempt 
to determine causality. 

Figure VI.7: Average Operating revenue in million EUR    

10,00

9,00

8,00

7,00

6,00

5,00

4,00

3,00

2,00

1,00

0,00

2013

2014

2015

2016

2017

2018

2019

2020

2021

Treated

Comparison

Source: EFSI, SMEW administrative data and Orbis 

Figure VI.8: Average Number of employees 

60

50

40

30

20

10

0

2013

2014

2015

2016

2017

2018

2019

2020

2021

Treated

Comparison

Source: EFSI, SMEW administrative data and Orbis 

139 

 
 
 
 
 
 
ANNEX VII. GLOSSARY 

Term or acronym 

Meaning or definition 

ABS 

CA 

CCS GF 

CEF 

CEF-DI 

COSME 

Asset-Backed Security 

Climate Action 

Cultural and Creative Sectors Guarantee Facility 

Connecting Europe Facility 

Connecting Europe Facility Debt Instrument 

Programme for the Competitiveness of Enterprises and 
Small and Medium-sized Enterprises 

COSME LGF 

COSME Loan Guarantee Facility 

CPF 

EAFRD 

EaSI 

EaSI GFI 

EBRD 

EC 

ECA 

ECB 

ECFIN 

ECP 

EFG 

EFSI 

EGFF 

EIAH 

EIB 

Common Provisioning Fund 

European Agriculture Fund for Rural Development  

EU Programme for Employment and Social Innovation 

EaSI Guarantee Financial Instrument 

European Bank for Reconstruction and Development 

European Commission 

European Court of Auditors 

European Central Bank 

Directorate General for Economic and Financial Affairs 

EFSI Combination Product 

Equity Facility for Growth (under COSME) 

European Fund for Strategic Investments 

European Growth Finance Facility 

European Investment Advisory Hub 

European Investment Bank 

140 

 
 
EIB EV 

European Investment Bank Operations Evaluation 

EIBG 

EIC 

EIF 

EIPP 

ELENA 

EQ 

European Investment Bank Group 

European Innovation Council  

European Investment Fund 

European Investment Project Portal 

European Local ENergy Assistance 

Evaluation Question 

ESCALAR 

European Scale-up Action for Risk Capital 

ESIF 

EU 

EUR 

FIs 

FLP 

FPA 

GDP 

GFCF 

IC 

IFI 

IIW 

European Structural and Investment Funds 

European Union 

Euro 

Financial intermediaries 

First loss piece 

Framework Partnership Agreement 

Gross Domestic Product 

Gross Fixed Capital Formation 

Investment Committee 

International Financial Institution 

EFSI’s Infrastructure and Innovation Window 

InnovFin 

“EU Finance for Innovators” initiative under Horizon 2020 

InnovFin Equity 

InnovFin SMEG 

IP 

IPE 

Equity Facility (early-stage capital) for Research and 
Innovation of Horizon 2020 

SMEs & Small Midcaps R&I Loans Service under Horizon 
2020  

Investment platform 

Investment Plan for Europe (a.k.a. Juncker Plan) 

141 

 
 
ISSG 

JASPERS 

JC 

KMI 

KPI 

LPA 

MFF 

MS 

NPB 

Interservice Steering Group 

Joint Assistance to Support Projects in European Regions 

Judgment Criteria 

Key Monitoring Indicator 

Key Performance Indicator 

Light Project Advisory 

Multiannual Financial Framework 

Member States 

National Promotional Bank 

NPBIs 

National Promotional Banks and Institutions 

OPC 

PE 

PPP 

R&D 

RDI 

S&E 

SDG 

SGA 

SLP 

SME 

SMEW 

SWD 

ToC 

VaR 

Open Public Consultation 

Private Equity 

Public-private partnership 

Research and Development 

Research, development and innovation 

Skills and Education 

Sustainable Development Goals  

Specific Grant Agreement 

Second loss piece 

Small and medium-sized enterprises 

EFSI’s Small and Medium-Sized Enterprise Window 

Staff Working Document 

Theory of Change 

Value at Risk 

142