Support to mitigate Unemployment Risks in an Emergency (SURE) : SURE financing contributed to preserving jobs during the COVID-19 crisis, but its full impact is not known. Special report 28, 2022.
Date: 2023-01-31
Institutions: European Court of Auditors
Subjects: EU aid, EU financial instrument, coronavirus disease, economic consequence, emergency aid, employment aid, epidemic, fight against unemployment, job security, performance audit, report, self-employed person, unemployment

EN 

2022 

28 

Special report  Support to mitigate Unemployment 

Risks in an Emergency (SURE) 
SURE financing contributed to preserving jobs 
during the COVID-19 crisis, but its full impact is 
not known 

 
 
 
Contents 

Executive summary 

Introduction 

Background 

About SURE 

Financial envelope 

Audit scope and approach 

Observations 

The SURE instrument was a timely response to mitigate the risk 
of unemployment during the COVID-19 pandemic 

The EU introduced SURE quickly 

Member States’ demands for SURE funding were in line with the 
Commission’s estimate 

The Commission estimates that Member States potentially saved around 
€8 billion through SURE 

The SURE instrument entails a limited financial risk to the EU 
budget 

Member States guaranteed 25 % of all loans under SURE 

Additional prudential rules further limit the financial risk to the EU budget 

The Commission put in place a flexible framework for SURE which 
did not follow the standard funding arrangements 

The SURE framework reflects the emergency context 

The conditions set in the SURE regulation were broad and the Commission 
assessed them in close contact with Member States 

The scope of the SURE instrument was extended by the Council to finance 
health-related measures, reducing its primary focus on employment 

The Commission disbursed funds to Member States rapidly 

The SURE loan agreements included provisions regarding the risk of fraud 
and irregularity but the legal framework did not require assessment of the 
robustness of Member States’ control systems 

2 

Paragraph 

I-IX 

01-10 

01-03 

04-07 

08-10 

11-15 

16-64 

16-26 

17-20 

21-24 

25-26 

27-31 

28-29 

30-31 

32-47 

33-34 

35-40 

41-43 

44 

45-47 

 
 
3 

SURE loans helped to finance the national job retentions schemes 
to contain the rise in unemployment during the COVID-19 crisis 

48-51 

The impact of SURE cannot be fully assessed because of 
limitations in the monitoring data and the lack of an ex-post 
evaluation 

Monitoring and reporting requirements focus on the use of the financial 
assistance rather than the results achieved 

The Commission’s bi-annual reports on the use of the SURE financial 
assistance can only provide broad estimates of results 

The Commission has not evaluated the SURE instrument 

Conclusions and recommendation 

52-64 

53-60 

61-62 

63-64 

65-70 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I The COVID-19 pandemic caused a severe shock to the European economy with 
significant disruption to labour market, putting millions of jobs at risk. Against this 
background, the EU put in place a temporary instrument, SURE (Support to mitigate 
Unemployment Risks in an Emergency) to help Member States in dealing with the 
impact of the pandemic on their labour markets. In particular, the instrument was 
designed to support Member States in the implementation of new or the extension of 
existing job retention schemes. The Council chose to expand the scope of the scheme 
initially proposed by the Commission so that SURE could also be used to support 
health-related measures. 

II Unlike traditional social policy support funded from the EU budget, SURE provides 
long-term loans to Member States under favourable financial terms. The Commission 
manages the instrument and can borrow up to €100 billion on the capital markets. By 
August 2022, the Council had approved €93.3 billion of financial assistance to 
19 Member States, of which nearly €92 billion (98 %) had been disbursed. The period 
of availability ends on 31 December 2022, although the Council can decide to extend 
this period, based on a Commission proposal. 

III We carried out an audit of SURE because of its importance in cushioning the 
impact of the COVID-19 pandemic. Moreover, the financial support from SURE up to 
€100 billion is significant. We assessed whether the instrument was efficient and 
effective mitigating the unemployment risk in the EU. 

IV Overall, we conclude that the Commission reacted quickly and efficiently to the 
challenge of helping Member States preserve employment. It was able to get EU 
support to the Member States more rapidly than is the case under standard funding 
procedures. The SURE framework reflected the emergency context and limited the 
financial risk to the EU budget. While there are some indications at aggregate level 
that SURE support reached millions of people, the lack of comprehensive Member 
State data limits the Commission’s ability to assess the results achieved by SURE. 

V The Commission proposed a new, innovative regulation with Council approval 
following in a timely manner, only two months after the designation of COVID-19 as a 
pandemic. SURE support enabled Member States to create or extend existing job 
retention schemes but, given the very different circumstances of each national labour 
market, the approaches taken across the EU varied significantly. 

 
 
5 

VI SURE funding is based on loans, not grants. Member States’ demand for these 
loans was in line with the budget proposed by the Commission of €100 billion. One of 
the unique features of SURE is that all Member States have provided guarantees, up 
to 25 % of all loans paid under SURE, all of which are due to be repaid by 2050. These 
guarantees serve as a buffer to protect EU budget, as, in the event of default, they 
might be called upon before the Commission’s own resources. 

VII SURE is a crisis-response instrument where the rapid disbursement of funds is 
key. Most Member States received their first disbursement less than one month after 
their request. As job retention schemes are prone to misuse, the SURE regulation 
requires that the loan agreements with Member States include provisions about 
controls and audits, to minimise the risk of fraud and irregularity. The Commission 
launched an ad hoc survey on national audit and control systems at the beginning 
of 2022, when most of the funding had already been disbursed to Member States. All 
Member States except one reported cases of irregularities and alleged fraud. However, 
as at September 2022, as it was not aware of any major irregularities or fraud with 
respect to its own responsibilities under the legislation, the Commission had not 
launched any specific investigations in this matter. 

VIII There are indications at aggregate level that SURE reached millions of 
employees and self-employed individuals during the most severe period of the crisis, 
and, together with other policy support measures, contributed to mitigating the 
unemployment risks. However, the design of the instrument does not make it possible 
to identify separately the impact of SURE, in terms of outputs and results, within the 
national schemes. The effect is that the Commission cannot assess the results of SURE 
in each Member State. For example, the lack of comprehensive Member State data 
means that the number of people and businesses supported by SURE – the potential 
contribution of the instrument in mitigating the unemployment risks – cannot be fully 
assessed. Member State data on health-related measures reported to the Commission 
is more limited. An evaluation is not mandatory in the SURE regulation. 

IX We recommend that the Commission carry out a comprehensive evaluation of 
SURE, with a view to learning lessons for potential future crisis instruments. 

 
 
 
6 

Introduction 

Background 

01 During the COVID-19 pandemic, EU Member States took a number of public 
health measures to limit the spread of the coronavirus. These measures, together with 
the economic uncertainty brought by the pandemic and supply chain disruption 
caused by border and factory closures, resulted in a significant decline in both 
production and consumption in the EU. In the early stages of the pandemic, these 
measures included lockdowns which led to the temporary closure of various sectors of 
the EU economy, such as tourism and hospitality 1. 

02 The resulting economic contraction, felt particularly strongly in the EU’s southern 
Member States, put millions of jobs at risk. The European Centre for the Development 
of Vocational Training (CEDEFOP) estimated in 2020 that about 45 million jobs, 23 % of 
the workforce, in the EU-27 labour market faced a very high risk of COVID-19 
disruption, and that another 22 % of the EU workforce – mostly medium to lower-
skilled workers in the service sector – was exposed to some significant risk2. 

03 Against this background, and on a temporary basis, the EU put in place SURE 
(Support to mitigate Unemployment Risks in an Emergency) to help Member States in 
dealing with the impact of the pandemic on their labour markets. The instrument 
supports Member States in the implementation of new or extended job retention 
measures. These schemes provide public income support for the hours not worked for 
businesses experiencing economic difficulties. Job retention instruments include short-
time, furlough and wage subsidy schemes. 

1  Marcus, J. S. et al.: The impact of COVID-19 on the Internal Market, European Parliament, 

2021. 

2  Pouliakas, K.; Branka, J.: EU jobs at highest risk of COVID-19 social distancing: Is the 

pandemic exacerbating the labour market divide?, No 1, CEDEFOP working paper, 2020. 

 
 
                                                        
7 

About SURE 

04 The primary objective of SURE is to provide financial assistance to Member States 
which are experiencing, or are seriously threatened with, a severe economic 
disturbance. In financing job retention schemes, SURE aims ultimately at reducing the 
incidence of unemployment and loss of income (see Figure 1). It supports existing jobs; 
it does not finance unemployment schemes. 

Figure 1 – Main SURE objectives 

Purpose

Provide liquidity support for
short-time work schemes
and similar measures

Ultimate goals

• Preserve EU’s economic structures
• Prevent long-lasting economic

and social damage
• Favour a swift recovery

Source: ECA based on the Commission. 

Immediate objectives

• Preserve jobs
• Sustain incomes
• Support companies
• Help the self-employed

05 The Commission’s initial legislative proposal for SURE was limited to the 
employment objective3. When adopting the SURE regulation in May 2020, the Council 
decided to extend its scope to support health-related measures (see Figure 2). 

3  Commission proposal for a Council regulation for SURE, COM(2020) 139. 

 
 
 
                                                        
8 

Figure 2 – Typology of actions financed under SURE 

Actions financed under SURE

WORK

HEALTH

 Wage subsidy schemes
 Support for self-employed workers
 Special parental leave benefits
 Support for seasonal workers
 Support for training linked to short-time 

work

 Special COVID-19 sick leave and/or quarantine 

leave

 Support to meet health and safety 

requirements in the public sector and at 
workplaces

 Increased public healthcare expenditure

(medical staff, equipment, hospital renovation)

 Bonus payments to existing healthcare 

workers and other personnel

 Hiring of additional health professionals

Source: ECA based on the Commission. 

06 SURE provides loans to Member States and is financed by borrowing. The 
instrument is managed by the Commission, covering borrowing operations, and 
administration and disbursement of the loans. The Directorate-General for Economic 
and Financial Affairs (DG ECFIN), as lead DG, coordinated the set-up and the 
implementation of the instrument, in close collaboration with the Directorate-General 
for Employment, Social Affairs & Inclusion (DG EMPL) and the Directorate-General for 
Budget (DG BUDG) (see Table 1). 

 
 
 
9 

Table 1 – DG roles and responsibilities 

DG ECFIN 

DG EMPL 

DG BUDG 

o 

o 

o 

o 

Developing guidance 
about which type of 
schemes could be 
considered eligible for 
SURE support and 
templates regarding how 
to request SURE funding; 

o 

o 

Assessing the national 
measures under SURE 
(jointly with ECFIN); 

Checking that there was 
no overlap with the 
European Social Fund 
grants; 

o  Monitoring financial 
implementation: 
providing inputs to the 
bi-annual reports (with 
ECFIN coordinating). 

Assessing the national 
measures under SURE 
(jointly with DG EMPL); 

Assessing compliance 
with sudden and severe 
increase of public 
expenditure (triggering 
conditions for SURE 
loans); 

Drafting the Commission 
proposal for the Council 
implementing decisions; 

o 

o 

o 

Preparing guarantee and 
loan agreement 
templates; 

Determining with the 
Member States 
characteristics of the loan 
(e.g. maturity); 

Bond issuance, loan 
administration, handling 
of disbursements and 
repayments; 

o  Monitoring the financial 
implementation by 
producing quarterly 
financial reports. 

o  Monitoring the financial 
implementation and 
producing bi-annual 
reports. 

Source: ECA. 

07 SURE is a temporary instrument. Its availability ends on 31 December 2022, 
unless the Council, on a proposal from the Commission, decides to extend it. 

 
 
10 

Financial envelope 

08 Under the regulation, the Commission can borrow up to €100 billion on the 
capital markets to finance SURE support4. Each Member State wishing to benefit from 
SURE support sends a request to the Commission. The Commission assesses each 
request and, if it complies with the eligibility conditions of the regulation, proposes 
that the Council approve the SURE financial assistance. This decision takes the form of 
a Council implementing decision for a back-to-back loan (a loan issued on the same 
terms the Commission received on the capital markets) representing financial 
assistance to the Member State concerned. 

09 To finance the instrument, the Commission issued bonds on the capital markets. 
The bonds issued by the Commission had various maturities, ranging from five to 
30 years. There was strong investor interest in the SURE bonds. 

10 Moreover, and for the first time, the Commission issued the bonds under the 
SURE instrument as social bonds (see Box 1). 

Box 1 

Social bonds and the SURE social bond framework 

Social bonds are defined as instruments that raise funds for new and existing 
projects with positive social outcomes. 

The SURE social bond framework is aligned with the Social Bond Principles 
established by the International Capital Markets Association, a self-regulatory 
organisation and trade association for participants in the capital markets. Under 
this framework, the Commission is required to publish reports, based on data 
provided by the Member States, on the allocation of SURE proceeds, type of 
expenditure and impact of SURE financial assistance. 

4  Article 5 of Regulation (EU) No 2020/672. 

 
 
 
 
                                                        
11 

Audit scope and approach 

11 We assessed whether SURE was an efficient and effective response to mitigate 
unemployment risks in the EU from the COVID-19 pandemic and implemented 
efficiently by the Commission. In particular, we examined whether: 

o 

o 

o 

o 

setting-up the instrument was timely; 

appropriate arrangements were put in place to limit the financial risk to the EU 
budget through SURE; 

the legislative framework for SURE and its implementation reflected the crisis 
situation while minimising the risk of fraud and irregularity; 

the Commission developed a robust framework for monitoring the 
implementation of national job retention schemes financed by SURE and 
evaluating their impact; and  

o 

SURE was effective in helping Member States to protect jobs. 

12 The time period covered was from April 2020, when the Commission proposed 
the SURE regulation to the end of the audit fieldwork in September 2022. The focus of 
the audit was the Commission. Assessments of the implementation of SURE at 
individual Member State level and of the Commission’s management of the borrowing 
operations were outside the audit scope. 

13 We obtained data and information from the main Commission DGs responsible 
for SURE, as well as Eurostat. We consulted Eurofound (the EU agency for improving 
working conditions) and the Centre for European Policy Studies (CEPS, an EU 
think-tank). 

 
 
12 

14 As part of the our audit work we:  

o 

o 

o 

o 

reviewed existing EU legislation, Commission guidance and exchange of 
information with Member States and other relevant documents; 

interviewed representatives of the Commission, CEPS and Eurofound; 

analysed the processes for applying and reporting on SURE for a sample of 
requests for financial assistance; and 

examined Member States’ replies to the Commission’s survey in early 2022 to 
assess the risk of irregularities and fraud. 

15 We carried out an audit of SURE because of its reported importance in cushioning 
the impact of the COVID-19 pandemic’s impact and preventing unemployment from 
rising as sharply as was initially feared. Moreover, the financial support from SURE of 
up to €100 billion is significant. 

 
 
 
 
13 

Observations 

The SURE instrument was a timely response to mitigate the risk 
of unemployment during the COVID-19 pandemic 

16 We examined whether the instrument was a timely response to mitigate the risk 
of unemployment during the COVID-19 pandemic, analysing in particular the timeline 
of the processes involved from the date that the pandemic was declared. We also 
examined whether the Commission appropriately assessed the expected level of 
demand for SURE loans to set the financial envelope and the Commission’s estimate of 
the hypothetical financial savings for Member States achieved through SURE. 

The EU introduced SURE quickly 

17 The World Health Organisation declared the pandemic on 11 March 2020. 
On 2 April, less than one month later, the Commission submitted its proposal for a 
SURE regulation to the Council. At this point, the Commission had already started 
negotiations with the Member States on their commitment to provide joint guarantees 
for part of the borrowing. 

18 Two months after the designation of COVID-19 as a pandemic, on 19 May 2020, 
the Council adopted the regulation, with some modifications such as extending the 
scope of the financial assistance under SURE to also include health-related measures 
(see paragraph 05). 

19 SURE is unique, making like-for-like comparisons difficult. However, while it took, 
on average, six months between Commission proposal and Council adoption for 
amendments to the Common Provisions Regulation5 in response to previous crises, the 
SURE regulation was adopted within two months. This was instrumental in having the 
first loans disbursed to Member States early during the COVID-19 crisis. 

20 Following adoption of the regulation in May 2020, the Commission raised funding 
on the capital markets and disbursed the first loans to Member States in October of 
the same year (see Figure 3). 

5  For Common Provisions Regulations relating to the 2007-2013 and 2014-2020 programme 

periods: Council Regulation (EU) No 1083/2006 and Regulation (EU) No 1303/2013 
respectively. 

 
 
                                                        
14 

Figure 3 – The period from pandemic declaration to first disbursement 
under SURE was short 

International organisation

European Commission

European Council

Member States

11 March 2020

WHO declares COVID-19 outbreak a pandemic 

WHO’s Director-General announced that COVID-19 can be characterized as a 
pandemic. Swift actions were essential. WHO/Europe states that balancing acts 
between protecting health and preventing economic and social disruption are 
needed. 

2 April

SURE proposal

Commission proposes creation of SURE. Member States are eligible to apply for 
SURE loans if COVID-19 outbreak led to sudden and severe increase of public 
expenditure of national measures as of 1 February 2020. National measures have 
to aim at persevering the employment relationship or to replace the income loss 
to self-employed and other categories of workers. 

19 May

Council modifies and adopts SURE regulation
Council amends and adopts SURE regulation. 
The main modifications are the introduction of health-related measures and the 
sunset clause of the regulation.

24-25 August

Commission proposes SURE financial support to 16 Member States

Commission sends proposals of implementing decisions to the Council for the 
financial support (€87 billion) to 16 Member States. 

22 September

SURE activated after 27 Member States agree to guarantee SURE loans

SURE instrument is activated after the 27 Member States guarantee the at least 
25 % of the maximum SURE loan amount. 

25 September

Council makes available first SURE loans

Council adopts its first implementing decisions to grant SURE loans to 16 Member 
States.  

15 October

Commission signs first three loan agreements 

with the three biggest SURE beneficiaries (Italy, Spain and Poland). 

20 October

Commission issues first SURE bonds

Commission issues its first SURE bonds under social bond framework and aligning 
with UN’s SDGs. The bonds are 13 times oversubscribed.

27 October

Commission’s first disbursements to Member States

Commission disburses €17 billion to Italy, Spain and Poland. These three Member 
States represent the 60 % of the SURE loans (the maximum allowed under SURE 
regulation).  

Source: ECA based on Commission documents. 

 
 
 
15 

Member States’ demands for SURE funding were in line with the 
Commission’s estimate 

21 SURE provides financial assistance to Member States facing disruption to the 
labour market as a result of the COVID-19 pandemic. In order to gauge the expected 
level of demand for SURE loans, at the end of March 2020, the Commission prepared 
three scenarios, taking into account the potential length of lockdowns, their scope and 
the number of countries requesting loans. This led to estimated financing needs for job 
retention schemes between €50 billion and €100 billion. The Commission chose to 
proceed on the basis of the scenario with the highest financing needs (€100 billion), 
given the uncertainty about the full of impact of the COVID-19 pandemic prevailing at 
the time. 

22 The Commission’s estimate was sufficient to satisfy the EU-wide demand for 
financial support from SURE, although the Council had included health-related 
measures in the scope of the regulation. Eight Member States (Denmark, Germany, 
France, Luxembourg, Netherlands, Austria, Finland and Sweden) chose not to make 
use of SURE. All of these Member States already had nationally funded job retention 
schemes in place. 

23 By August 2022, the Council had approved a total of €93.3 billion of financial 
assistance to 19 Member States. Of this total, nearly €92 billion (98 %) had been 
disbursed by August 2022 (see Figure 4). 

 
 
Figure 4 – SURE disbursement amounts (€91.8 billion, August 2022) 

16 

Estonia

Latvia

0.23

0.31

Poland

Lithuania

9.74

0.96

Belgium

Czechia

Slovakia

8.20

2.00

0.63

(billion euros)

Slovenia

Hungary

Romania

1.11

0.65

3.00

Croatia

Bulgaria

1.02

0.51

Greece

5.27

Italy

27.44
27.44

Malta

0.42

Cyprus

0.60

Ireland

2.47

Portugal

Spain

5.93

21.32

Source: ECA based on the Commission SURE disbursement data. 

24 Nearly half of the support was provided to two Member States, Italy and Spain. 
Only two Member States, Poland and Romania, where spending on measures eligible 
for SURE support was lower than forecast, did not ask for the disbursement of all loans 
available. 

 
 
 
17 

The Commission estimates that Member States potentially saved around 
€8 billion through SURE 

25 One reason for the high level of Member State demand for SURE support is the 
possibility of accessing funding at relatively low cost. The Commission estimated that 
thanks to the EU’s AAA credit rating, the financial assistance provided under SURE has 
led to a saving of €8.5 billion in interest payments for Member States compared to 
what they would have hypothetically paid if they had borrowed the same amount on 
the capital market themselves6. 

26 We verified that the estimated interest savings reflect the size of the loans and 
the difference between the credit rating of the EU and that of individual Member 
States. They are concentrated in five of the benefiting Member States (Italy, Spain, 
Romania, Poland and Greece), ranging between €0.5 billion and €3.8 billion, and 
accounting for almost 86 % of the total estimated savings. 

The SURE instrument entails a limited financial risk to the EU 
budget 

27 Based on the provisions and rules in the SURE regulation and guarantee 
agreements with Member States, we analysed whether arrangements were put in 
place to limit the financial risk to the EU budget. 

Member States guaranteed 25 % of all loans under SURE 

28 Although SURE funding is based on loans, not grants, there remains a risk to the 
EU budget if one or several Member States default on their loan repayments. This is 
why a key element of SURE was that all Member States agreed to provide irrevocable 
on-demand guarantees, in proportion to their relative share of the EU’s total gross 
national income, covering 25 % of the SURE financial envelope. The remainder is 
guaranteed by the EU budget. 

29 The Member State guarantees were designed to act as a buffer to protect the EU 
budget. If Member States fail to make a repayment on time, the Commission can hold 
all of the other Member States liable. In case of any defaults, under the legislation the 
Commission “is expected to examine the scope” for using the EU budget to repay 

6  SURE: Two Years On: fourth bi-annual report, COM(2022) 483. 

 
 
                                                        
18 

outstanding debts 7. However, it also has the option of first drawing on Member States 
guarantees. The Commission told us that this was likely to be their preferred course of 
action. In the event that the whole Member State guarantee buffer of €25 billion is 
exhausted, the remaining debt will be repaid by the EU budget. These arrangements 
provide a guarantee to investors that there is very limited risk of the EU defaulting on 
its debts owing to the EU’s AAA credit rating (see paragraph 25). 

Additional prudential rules further limit the financial risk to the EU 
budget 

30 In addition, the SURE regulation includes two main mechanisms (referred to as 
“prudential rules”) to mitigate the maximum yearly exposure and for each Member 
State8: 

o 

o 

the total yearly amount repayable is limited to €10 billion, 10 % of the total 
funding available under SURE. The Commission issued bonds with different 
maturities to achieve this goal; and  

not more than 60 % of the total funding available can be granted to any three 
Member States. 

In our view these prudential rules further limit the financial risk to the EU budget in 
case of a Member State default. 

31 SURE provides funding to Member States through loans. The repayment is due 
between 2025 and 2050, with an average maturity of 14.5 years9. Figure 5 gives a 
breakdown by country of the different maturity dates and illustrates the operation of 
the prudential rules. For example, between 2025 and 2050, there are three years when 
the maximum amount of €10 billion of loans are due for repayment. Unlike some 
previous crises, many Member States were in need of support at the same time. 
Member States sent their requests for funds in total and with their preferred loan 
maturity. The Commission accordingly programmed different SURE loans with 
different maturities. 

7  Article 11(5) of Regulation (EU) No 2020/672. 

8  Article 9 of Regulation (EU) No 2020/672. 

9  SURE: Two Years On: fourth bi-annual report, COM(2022) 483. 

 
 
                                                        
19 

Figure 5 – SURE loan maturities and repayment schedule per Member 
State 

8.0 8.0

10.0 8.1 10.0

8.5 9.0

7.0

5.0 6.0

10.0

TOTAL
(billion euros)

TOTAL
(billion euros)

Italy

Spain

Poland

Belgium

Portugal

Greece

Romania

Ireland

Czechia

Slovenia

Croatia

Lithuania

Slovakia

Cyprus

Bulgaria

Hungary

Malta

Latvia

Estonia

91.8

27.4

21.3

9.7

8.2

5.9

5.3

3.0

2.5

2.0

1.1

1.0

1.0

0.6

0.6

0.5

0.5

0.4

0.3

0.2

Source: ECA based on Commission data on SURE loan maturities and repayment schedules. 

The Commission put in place a flexible framework for SURE 
which did not follow the standard funding arrangements 

32 We assessed whether the governance framework for SURE reflected the 
emergency context. We also analysed the processes that the Commission put in place 
for requesting and granting financial assistance under SURE, up to disbursement to 
Member States, and corroborated our analysis based on a sample of cases. We finally 
assessed whether the Commission took the first steps to assess the risk of fraud and 
irregularities in the implementation of the job retention schemes financed by SURE at 
the level of the Member States. 

 
 
 
20 

The SURE framework reflects the emergency context 

33 SURE is a crisis response instrument, designed to provide temporary and 
repayable financial assistance to Member States. Accordingly, the SURE framework – 
comprising the regulation itself together with the choices made by the Commission in 
putting it into operation – is deliberately simpler than the Commission’s standard 
funding procedures. 

34 For example, the SURE regulation did not require the Commission to carry out an 
analysis of the scope and design of the existing or planned national job retention 
schemes when assessing Member State requests for financial assistance. As these 
schemes varied significantly (in terms of the size, sector and turnover of companies 
supported, the groups of workers eligible, the level and duration of the scheme, and 
the inclusion of a ban on dismissals) across Member States, such an analysis would 
have significantly delayed the disbursement of loans. 

The conditions set in the SURE regulation were broad and the 
Commission assessed them in close contact with Member States 

35 Eleven of the 19 Member States in receipt of SURE funds allocated the financial 
assistance to create new job retention schemes, and eight to extend or modify existing 
schemes (see Figure 6). 

 
 
Figure 6 – New short-time work schemes and extensions of pre-existing 
ones financed by SURE 

21 

SURE Member States 
with a new scheme

SURE Member States with 
pre-existing STW that was 
extended or modified

Source: ECA based on Eurofound. 

22 

36 The SURE regulation10 set two main conditions for using the instrument: 

o 

o 

a sudden and steep rise in public expenditure directly related to job retention 
schemes (the triggering condition); 

SURE support has to be used for job retention schemes (i.e. short-term work 
schemes or similar measures) or for health-related measures (the eligibility 
condition). 

37 Based on our review of a sample of 31 cases (including health-related measures), 
we found that the Commission adequately assessed whether these two conditions for 
using SURE were fulfilled. 

38 The eligibility conditions set in the regulation were broad, giving Member States 
considerable latitude in deciding where to target the EU funding. This made the 
Commission’s job of assessing requests for support less onerous. The Commission’s 
checks were therefore limited to confirming that the measures for which funds were 
requested would help people keep their jobs in the context of COVID-19. However, the 
legislation did not require the Commission to assess the cost-effectiveness of 
measures. The legislation states that the SURE instrument “shall complement the 
national measures … by providing financial assistance”11. The Commission considered 
that this requirement was guaranteed by the conditions attached to the instrument 
and that there was no need to assess the complementarity of SURE support with other 
national measures in the Member States. 

39 The Commission, with a view to facilitating the rapid disbursement of funds, also 
maintained close bilateral contacts with Member States during the assessment process 
of the proposed schemes in order to, for example: 

o 

explain the conditions for using the instrument (in particular through bilateral 
meetings at technical level before the submission by Member States of the formal 
request for assistance). For example, at times the Commission had to clarify to 
Member States that certain national measures were not eligible for support under 
SURE (see Box 2); 

o 

obtain additional clarifications, where necessary, in relation to the information 
submitted by the Member States. 

10  Article 3 of Regulation (EU) No 2020/672. 

11  Article 2 of Regulation (EU) No 2020/672. 

 
 
                                                        
23 

Box 2 

National measures not eligible for SURE 

o 

o 

o 

o 

Support to the unemployed (e.g. benefits or active labour market policies) 

Support to the inactive (e.g. students, pensioners) 

Liquidity support and grants for businesses, not related to employment (e.g. 
electricity/water costs, subsidies for rents, one-off measures for SMEs to 
avoid bankruptcies) 

Reduction in indirect labour costs of firms without any requirement to 
maintain employment (e.g. across-the-board reduction in social security 
contributions) 

o  Direct income support to employees (e.g. reduction in tax obligations of 
employees as these measures do not directly protect employment and 
prevent job losses) 

o  Deferrals of firms’ tax liabilities, such as postponement of the payment of 

social security contributions, as these measures are not public expenditure 

Source: ECA based on Commission documents. 

40 In cases where the Commission noted a lower uptake of SURE funds compared to 
what had been planned, the Commission was active in engaging in discussions with the 
national authorities to help them make use of the available financing – such as the 
adoption of additional eligible measures, or the extension of existing ones. 

The scope of the SURE instrument was extended by the Council to 
finance health-related measures, reducing its primary focus on 
employment 

41 The SURE regulation recognises that employment is its primary aim. Including the 
financing of health-related measures (examples of which are in Figure 2) reduces the 
primary focus of keeping people in employment. While health-related measures are 
eligible, they must remain “ancillary”12. 

12  Article 1.2 of Regulation (EU) No 2020/672. 

 
 
                                                        
24 

42 Informal Commission guidance, discussed and agreed at an August 2020 Council 
working party, was that the share of total SURE spending on health-related measures 
in a Member State should not exceed 15 %. Overall, this ceiling was complied with, as 
spending by Member States on health-related measures accounted for around 5 % of 
the total SURE budget. 

43 Ultimately, however, the Commission, supported by the Council, interpreted the 
regulation term “ancillary” as meaning that the proportion of SURE spending on 
health-related measures in each Member State should not exceed 50 %. Of the seven 
Member States which allocated SURE funding to health-related measures, four kept 
the proportion of this spending to less than 15 %. Portugal used 23 % of its SURE loans 
on health-related measures and Hungary and Romania almost 50 %. The remaining 
twelve Member States did not make use of this facility. 

The Commission disbursed funds to Member States rapidly 

44 The Commission carried out its assessment of Member States’ requests rapidly. 
As a result, 13 of the 19 Member States requesting SURE funding received the first 
disbursement in less than one month from the request for funds, and five Member 
States within a further month. The other Member State asked to receive the funds 
later, five months after request. 

The SURE loan agreements included provisions regarding the risk of 
fraud and irregularity but the legal framework did not require 
assessment of the robustness of Member States’ control systems 

45 Crisis-response measures, such the job retention schemes financed by SURE, are 
particularly prone to potential irregularities and misuse, as has been pointed out by 
the Commission funded network European Platform tackling undeclared work13 and 
several reports by Supreme audit institutions 14. 

13  COVID-19: combating fraud in short-term financial support schemes, European Platform 

tackling undeclared work, May 2021. 

14  The Supreme audit institutions of Croatia (2021), Ireland (2021), Latvia (2020). 

 
 
                                                        
25 

46 The SURE regulation requires that the loan agreement with each Member State 
includes provisions regarding checks and audits, to minimise the risk of fraud and 
irregularity, as required in the financial regulation15. The Commission has systems 
designed to cover the absence of fraud and irregularities between the EU and Member 
States. The Member States are responsible for the proper use of funds at the national 
level, to prevent irregularities and fraud and potentially to recover misused funds from 
recipients. The legal framework does not require the Commission to assess the 
robustness of the Member States’ control systems governing the implementation of 
the national measures supported by EU funds. In line with the legal framework for 
agreeing loans, the Commission focused on the responsibilities of the EU as lender, 
and the Member States as borrowers. For example, as an ex post control, the 
Commission’s checks cover whether the Member State measures supported by SURE 
are consistent with those in the Council implementing decisions. We note that the use 
of loans as a mechanism to provide funding means that the legal responsibilities of the 
Commission relating to fraud and irregularity are less extensive than when it provides 
Cohesion policy grant funding. 

47 In January 2022, in response to our audit, and in order to acquire more 
information about the operation of the loan agreements on the ground, the 
Commission carried out an ad hoc survey on audit and control systems to SURE 
beneficiary Member States. At this time, around 95 % of the loans had already been 
disbursed. In their responses to the survey, the Member States reported that, for the 
measures supported by SURE, they were using the audit and control systems in place 
prior to the pandemic. With one exception, all Member States reported that they had 
detected instances of irregularities or fraud. In all such cases, the Member State 
concerned carried out an investigation. This led to legal action to recover improperly 
used funds in 13 Member States16. If the Commission has serious doubts concerning 
the Member State use of SURE funds, it has the option of launching investigations. At 
September 2022, the Commission had not undertaken any investigations on the basis 
that it was not aware of any major irregularities or fraud with respect to its own 
responsibilities under the legislation as set out in the previous paragraph. The use of 
loans means that potential irregularities in national schemes limits the financial risk to 
the EU budget. Nevertheless, there remains a reputational risk for the EU if the 
measures financially supported by the EU budget are perceived as being prone to 
fraud. 

15  Article 13.1 of Regulation (EU) No 2020/672 as required by article 220(5) of the Regulation 

(EU) No 2018/1046. 

16  SURE at 18 months: third bi-annual report, COM(2022) 128. 

 
 
                                                        
26 

SURE loans helped to finance the national job retentions 
schemes to contain the rise in unemployment during the 
COVID-19 crisis 

48 We examined whether SURE met its overall objective of financing national 
schemes designed to support workers in the Member States during the crisis and 
mitigating the unemployment risks. The design of the instrument does not make it 
possible to identify the impact of SURE separately within these schemes. We analysed 
data from Eurostat and Eurofound as well as information from the Commission and a 
comparative IMF study. 

49 One of the main ways in which national governments sought to combat a 
potential rise in unemployment was through the use of job retention schemes, which 
were eligible for SURE support (see Box 3). These schemes and similar measures 
allowed employers who experienced temporary drops in demand or production (in 
particular during the lockdown phases of the pandemic) to reduce their employees’ 
hours instead of laying them off. In this way employees were able to keep their 
employment while maintaining income levels. 

 
 
27 

Box 3 

The use of job retention schemes during the pandemic 

The budgets of job retention schemes in the EU during the pandemic were 
unprecedented. According to Eurofound data, between March and 
September 2020, over 40 million workers and close to four million employers in 
the EU made use of employment protection schemes and measures. This means 
that more than 20 % of the EU workforce benefited from short-time working or 
temporary unemployment allowances. At the peak of the financial and economic 
crisis in 2009, fewer than 1.8 million workers were covered by employment 
protection schemes. Expenditure on these national schemes in the first wave of 
the pandemic was almost 10 times higher than during the whole of the 2008–2010 
financial crisis17. 

50 In 2021 Eurofound18 published a study comparing the impact on unemployment 
after the financial crisis of 2008 and the COVID-19 crisis. This study found that the 
increase in unemployment rates in the first year of the COVID-19 crisis in the Member 
States benefiting from SURE was lower than during the financial crisis of 2008-2010. 
While the pandemic led to a significant drop in economic activity, this was not 
translated into an equivalent reduction in employment rates, which fell by a relatively 
small amount. While the fall in gross domestic production was matched by a significant 
reduction in hours worked, there was no corresponding large increase in 
unemployment19. According to Eurofound, between Q2 2019 and Q2 2020, while the 
share of workers employed but not working more than doubled to 17 %, employment 
in the EU declined by only 2.4 %. 

17  COVID-19: Implications for employment and working life, COVID-19 series, Eurofound, 

Publications Office of the European Union, Luxembourg, 2021. 

18  Monitoring convergence in the European Union: Looking backwards to move forward - 

Upward convergence through crises, Eurofound, Challenges and prospects in the EU series, 
2021. 

19  Commission report on labour market and wage developments in Europe, December 2021, 

p. 45. 

 
 
                                                        
28 

51 The EU approach can be compared with that of the United States. According to 
a 2022 IMF study20, in the US the spike in unemployment caused by COVID-19 was 
largely driven by temporarily laid off workers: in the second quarter of 2020, workers 
that were temporarily laid off accounted for more than 70 % of the newly 
unemployed. Over the whole of 2020, US employment fell by 6.2 % and the 
unemployment rate increased by 4.4 percentage points, compared to 1.4 % and 
0.4 percentage points respectively in the EU. 

The impact of SURE cannot be fully assessed because of 
limitations in the monitoring data and the lack of an ex-post 
evaluation 

52 We assessed whether the Commission developed a robust framework for the 
monitoring and reporting the implementation of SURE. To that end, we analysed the 
monitoring processes of the Commission, from data collection from Member States to 
the publication of the bi-annual reports on the use of the financial assistance. We also 
assessed whether the Commission has planned for an evaluation of the instrument in 
accordance with its internal rules. 

Monitoring and reporting requirements focus on the use of the financial 
assistance rather than the results achieved 

53 The monitoring and reporting requirements for the Commission and Member 
States in the SURE regulation focus mainly on the use of the financial assistance and 
outputs, rather than on what has been achieved through the national job retention 
schemes supported by SURE in terms of results. 

54 The Commission’s financial monitoring, in addition to checking whether the 
measures reported were in line with those adopted by the Council Implementing 
Decision, focused on the way in which loan was used and the total expenditure of the 
measures funded under SURE. This allowed the Commission to proactively engage in 
discussions with the national authorities where there was a lower uptake of SURE 
funds compared to planned (see paragraph 40). 

20  European Labor Markets and the COVID-19 Pandemic: Fallout and the Path Ahead, 

International Monetary Fund, March 2022. 

 
 
                                                        
29 

55 The Commission estimates that, across the 19 Member States using the 
instrument, SURE supported around 31.5 million people and 2.5 million firms in 2020. 
The Member States where most people were supported were Italy (10.8 million), Spain 
(5.7 million) and Poland (3.6 million). Over a million people were also supported in five 
other Member States: Greece, Czechia, Belgium, Portugal and Romania. In 
August 2022, the Commission estimated that around nine million people in 2021 were 
benefiting from job retention schemes financed by SURE21. 

56 However, the data reported by the Member States on outputs, such as the 
number of employees and firms, covered, was generally based on estimates, was not 
always comprehensive, as was reported in SURE bi-annual reports, and sometimes 
varied significantly. This data formed the basis of the reports submitted by the 
Commission to the European Parliament and the Council (see Box 4). 

Box 4 

Examples of limitations in the monitoring data 

As regards the data reported by Member States we noted, based on the 
information provided by SURE bi-annual reports: 

—  variations in the data reported by several Member States over time; 

—  overlaps between the number of recipients of support across different 

measures; 

— 

for 2020, four Member States did not report on the sectoral coverage of 
SURE, and two did not report on the size of the firms benefiting from the 
support; 

— 

for 2021, one Member State did not report either the workers covered by 
SURE, nor the firms supported. 

57 Over time, Member States provided more data. However, this increased data 
availability also led to significant variations between data reported in different 
bi-annual reports. For example, the number of people benefiting from the support 
in 2021 was reported as 5 million, 3 million and 9 million in the second, third and 
fourth bi-annual reports respectively. 

21  SURE: Two Years On: fourth bi-annual report, COM(2022) 483. 

 
 
                                                        
30 

58 The Commission’s checks on the output data reported by Member States were 
limited and focused on broad consistency with previous submissions as well as the cost 
of the measures, using various available labour market data sources (e.g. Eurostat). 
They covered only an assessment of whether the information provided by the Member 
State on the number of beneficiaries of SURE funds (in terms of employees, self-
employed or firms, and by sector) seemed to be “plausible”. 

59 In addition, Member States generally provided the information at aggregate level. 
The lack of detailed data on the outputs and results of the national job retention 
schemes means that it is not possible to identify the main beneficiaries of the national 
measures financed by SURE22. While the COVID-19 pandemic resulted in a major shock 
to the labour market, not all sectors, companies and groups of workers were hit in the 
same way. Employees with less secure jobs, self-employed individuals and vulnerable 
workforce groups (such as women, older employees, non-natives, disabled and the less 
educated) were more likely to be affected by social distancing measures and other 
restrictions, severely disrupting their labour prospects23. 

60 The Commission did not ask for any data from Member States on what was 
achieved with the health-related measures on the basis that they had very different 
scope and objectives (see paragraphs 41-43). These measures can be financed by a 
number of different EU and national funding instruments and are typically 
implemented in a decentralised manner by a large number of different authorities and 
bodies, leading to a risk of double funding. Overall, health-related measures account 
for around €3.2 billion of the total SURE financial envelope, and vary significantly in 
terms of their nature and scope. 

22  COVID-19: Implications for employment and working life, COVID-19 series, Eurofound, 

Publications Office of the European Union, Luxembourg, 2021. 

23  EU jobs at highest risk of COVID-19 social distancing, CEDEFOP, 2020. 

 
 
                                                        
31 

The Commission’s bi-annual reports on the use of the SURE financial 
assistance can only provide broad estimates of results 

61 By end of September 2022, the Commission, in line with the regulation24, had 
published four bi-annual reports on the use of the SURE financial assistance. These 
reports are the basis for keeping the European Parliament, the Council and other 
stakeholders informed. These reports include information about the implementation 
of the financial assistance (for example, the amounts remaining to be paid, repayment 
schedules) and on the extent to which the exceptional occurrences justifying SURE 
continued to be in place. 

62 The SURE regulation does not require the Commission to report on the results 
nor effectiveness of the instrument, but the social bond framework requires impact 
reporting (see Box 1). In order to comply with this requirement, the bi-annual reports 
also include information on results achieved through the job retention schemes 
financed by SURE (see Box 5). 

Box 5 

Reporting on the results of SURE 

According to the Commission, policy support measures, including those supported 
by SURE, effectively prevented around 1.5 million people from becoming 
unemployed in 2020 in the SURE beneficiary Member States25. 

This estimate is based on a standard econometric model which compares 
historical labour market data with actual Member State data. Like all models, it is 
a simulation. 

According to the Commission, this figure should be interpreted with caution as it is 
difficult to assess what would have happened in the labour market in the absence 
of SURE, and employment rates are influenced by a very wide range of factors. 

24  Article 14.1 of Regulation (EU) No 2020/672. 

25  SURE: Two Years On: fourth bi-annual report, COM(2022) 483. 

 
 
                                                        
32 

The Commission has not evaluated the SURE instrument 

63 According to the financial regulation, the “Interinstitutional Agreement on Better 
Law-Making” and the “Better Regulation Guidelines”, the Commission is expected to 
evaluate the performance of EU programmes in relation to effectiveness, efficiency, 
relevance, coherence and EU added value26. These evaluations should critically and 
objectively assess whether an EU instrument was fit for purpose and delivered its 
intended objectives at minimum cost based on robust evidence of both successes and 
shortcomings27. Moreover, in the framework of “the European Pillar of Social Rights 
Action Plan”, the Commission committed to evaluate the experience of SURE28. The 
SURE regulation, however, does not specifically require the Commission to evaluate 
the performance of the instrument. 

64 For initiatives proposed as a matter of urgency during the COVID-19 pandemic for 
which public consultation and impact assessment were not carried out, the 
Commission had specified in April 2021 that it would “set out clearly how and when 
the act will subsequently be evaluated”29 in a staff working document published no 
later than three months after the legislative proposal. As the SURE regulation was 
adopted in May 2020, this was not done for SURE. 

26  Article 34 of the Regulation (EU, Euratom) 2018/1046. Paragraph I.3 of Interinstitutional 

Agreement between the European Parliament, the Council of the European Union and the 
European Commission on Better Law-Making, 12.05.2016, p. 1. SWD(2021) 305, Better 
Regulation Guidelines, 3.11.2021, p. 23. 

27  Commission communication on Better regulation: Joining forces to make better laws, 

COM(2021) 219, pp. 16-17. SWD(2021) 305, Better Regulation Guidelines, 3.11.2021, p. 23. 

28  The European Pillar of Social Rights Action Plan, 2021, p. 18. 

29  Commission communication on Better regulation: Joining forces to make better laws, 

COM(2021) 219, pp. 13-14. 

 
 
 
 
                                                        
33 

Conclusions and recommendation 

65 The COVID-19 pandemic caused a severe shock to the European economy, with 
significant disruption to the labour market, putting millions of jobs at risk. Overall, we 
conclude that the Commission reacted quickly to the challenge of helping Member 
States preserve employment, getting EU support to the Member States seven months 
after the pandemic had been declared, more rapidly than is the case under standard 
funding procedures. The governance framework reflected the emergency context and 
temporary Support to mitigate Unemployment Risks in an Emergency (SURE) was 
designed in such a way to limit the financial risk to the EU budget. While there are 
some indications at aggregate level that SURE support reached millions of people, the 
design of the instrument – where the EU provided loan financing to support national 
schemes – and the lack of comprehensive Member State data limit the Commission’s 
ability to assess the results achieved by SURE. 

66 SURE was set up and launched in an emergency context, when restrictive 
measures to limit the spread of the coronavirus were being implemented and when 
Member States were facing a sudden and severe increase in public expenditure. 
Against this background, the Commission proposed a new, innovative regulation with 
Council approval following in a timely manner, only two months after the designation 
of COVID-19 as a pandemic. Most Member States, 19, chose to use the instrument, 
with nearly a half of the total €100 billion support going to Italy and Spain. SURE 
support enabled Member States to create or extend existing job retention schemes. In 
general, new job retention schemes were created in eastern EU Member States but, 
given the very different circumstances of each national labour market, the approaches 
taken across the EU varied significantly. The Commission estimated that Member 
States with a credit rating weaker than the EU’s have together saved around 
€8.5 billion in interest compared to what they would have paid had they chosen to 
take out the loans themselves (see paragraphs 17-26). 

67 The structure of SURE support was novel, and limited the risk to the EU budget. 
Funding is based on loans, not grants and all Member States (including those choosing 
not to make use of SURE) have provided irrevocable on-demand guarantees, up to 
25 % of all loans paid under the instrument, all of which are due to be repaid by 2050. 
These guarantees serve as a buffer to protect the EU budget, as, in the event of 
default, the Member States’ guarantees may be called upon before the Commission’s 
own resources. Furthermore, there are prudential rules in place to mitigate the 
exposure per year and per Member State. Overall, there has been a strong demand for 
SURE loans, with nearly €92 billion disbursed by August 2022 (see paragraphs 27-31). 

 
 
34 

68 SURE is a crisis response instrument where the rapid disbursement of funds is a 
priority. The Commission’s procedures in SURE were simpler than normal Commission 
interventions. For example, the SURE regulation is short in length but broad regarding 
the triggering and eligibility conditions, giving Member States considerable latitude in 
deciding where to target the EU funding. As a consequence, there was no Commission 
check on whether the national measures supported by SURE were cost-effective or 
complemented other schemes. Extending the scope of the SURE instrument to finance 
health-related measures has reduced its primary focus on employment. Ultimately, the 
Commission, supported by the Council, accepted that three of the 19 Member States 
used more than 15 % of their SURE loans on health-related measures (see 
paragraphs 32-43). 

69 The Commission disbursed the funding to Member States quickly: most Member 
States received their first disbursement less than one month after their request. Job 
retention schemes are prone to misuse, and the SURE regulation requires that the loan 
agreements with Member States include provisions regarding systems of controls and 
audits, to minimise the risk of fraud and irregularity. The Commission launched an 
ad hoc survey on audit and control systems in Member States at the beginning 
of 2022, when most of the funding had already been disbursed. All Member States 
except one reported cases of irregularities and alleged fraud, leading to the recovery of 
improperly-used funds in 13 Member States. At September 2022, as it was not aware 
of any major irregularities or fraud with respect to its own responsibilities under the 
legislation, the Commission had not launched any specific investigations in this respect 
(see paragraphs 44-47). 

70 There are indications at aggregate level that SURE reached millions of employees 
and self-employed individuals during the most severe period of the crisis, and, 
together with other policy support measures, contributed to mitigating the 
unemployment risks. However, the design of the instrument does not make it possible 
to identify separately the impact of SURE, in terms of outputs and results, within the 
national schemes. The effect is that the Commission cannot assess the results of SURE 
in each Member State. For example, the lack of comprehensive Member State data 
means that the number of people and businesses supported by SURE – the potential 
contribution of the instrument in mitigating the unemployment risks – cannot be fully 
assessed. There is also little monitoring data on health-related measures on the basis 
that they had very different scope and objectives. An evaluation is not mandatory in 
the SURE regulation (see paragraphs 48-64). 

 
 
35 

Recommendation – Evaluate SURE 

With a view to learning lessons for potential future emergency instruments, and in line 
with its commitment in the European Pillar of Social Rights Action Plan, the 
Commission should evaluate the experience of SURE. Such an evaluation should 
include: the extent to which SURE and the national measures it supported added value 
(for all SURE objectives, including the health-related measures); whether and how 
SURE complemented national measures; and whether the SURE framework was 
effective in minimising the risk of irregularities and fraud, given the cases reported by 
Member States. 

Target implementation date: By end of Q3 of 2024. 

This Report was adopted by Chamber II, headed by Mrs Annemie Turtelboom, Member 
of the Court of Auditors, in Luxembourg at its meeting of 9 November 2022. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
36 

Abbreviations 

CEPS: Centre for European Policy Studies 

DG BUDG: Directorate-General for Budget 

DG ECFIN: Directorate-General for Economic and Financial Affairs 

DG EMPL: Directorate-General for Employment, Social Affairs and Inclusion 

Eurofound: European Foundation for the Improvement of Living and Working 
Conditions 

SURE: Support to mitigate Unemployment Risks in an Emergency 

 
 
 
 
37 

Glossary 

Eurofound: European Foundation for the Improvement of Living and Working 
Conditions, an EU agency that provides information, advice and expertise in the field of 
EU social policy on the basis of comparative information, research and analysis. 

Health-related measures: Measures aiming at reducing occupational hazards and 
ensuring the protection of workers and the self-employed in the workplace, and, 
where appropriate, some other health-related measures. 

Short-time work scheme: Public programme that, in certain circumstances, allows 
businesses experiencing economic difficulties to temporarily reduce the hours worked 
by their employees, who are provided with public income support for the hours not 
worked. 

Similar measures to short-time work schemes: Labour market measures other than 
short-time work schemes which protect employment by means of subsidising income 
support for employees and the self-employed. 

 
 
 
 
Replies of the Commission 

38 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=62745 

Timeline 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=62745 

 
 
 
 
 
 
 
 
 
 
 
 
 
39 

Audit team 

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

This performance audit was carried out by Audit Chamber II Investment for cohesion, 
growth and inclusion spending areas, headed by ECA Member Annemie Turtelboom. 
The audit was led by ECA Member Iliana Ivanova, supported by James Verity, Head of 
Private Office and Ivan Genchev, Private Office Attaché; Pietro Puricella, Principal 
Manager; Jussi Bright, Head of Task; Fernando Pascual Gil, Andras Augustin Feher, 
Zeljko Mimica and Cristina Jianu, Auditors. 

From left to right: Fernando Pascual Gil, James Verity, Jussi Bright, Iliana Ivanova, 
Ivan Genchev, Pietro Puricella, Zeljko Mimica. 

 
 
 
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The economic impact of the COVID-19 pandemic put millions of 
jobs at risk. Against this background, the EU put in place a 
temporary instrument, SURE (Support to mitigate Unemployment 
Risks in an Emergency). SURE provided up to €100 billion in loans 
to Member States under favourable terms for new, or the 
extension of existing, job retention schemes. We conclude that 
the Commission reacted quickly to the challenge, reflecting the 
emergency context. While there are indications that SURE funding 
reached millions of people, the lack of comprehensive Member 
State data limits the Commission’s ability to assess how many 
jobs were preserved. We recommend that the Commission should 
evaluate the experience of SURE to learn lessons for future crises. 

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