Study to support the impact assessment on preventing and combatting violence against women and domestic violence.
Date: 2023-02-22
Institutions: Directorate-General for Justice and Consumers
Subjects: EU Member State, EU policy, domestic violence, gender equality, help for victims, human rights, impact study, national law, psychological harassment, sexual discrimination, sexual harassment, sexual violence, women's rights

Study to support the 
Impact Assessment 
on Preventing and 
Combatting Violence 
Against Women and 
Domestic Violence
A report submitted by ICF S.A. 
22 May 2022

Submitted to:
DG Justice and Consumers
Directorate D: Equality and Union Citizenship
Unit D.2: Gender Equality

Justice 
and Consumers

This document should not be considered as representative of the European Commission’s official position. 

Luxembourg: Publications Office of the European Union, 2022
© European Union, 2022

The reuse policy of European Commission documents is implemented by Commission Decision 2011/833/EU of 
12 December 2011 on the reuse of Commission documents (OJ L 330, 14.12.2011, p. 39). Unless otherwise 
noted, the reuse of this document is authorised under a Creative Commons Attribution 4.0 International 
(CC-BY 4.0) licence (https://creativecommons.org/licenses/by/4.0/). This means that reuse is allowed 
provided appropriate credit is given and any changes are indicated.

For any use or reproduction of elements that are not owned by the European Union, permission may need 
to be sought directly from the respective rightholders. 

PDF 
HTML 

ISBN 978-92-76-53170-8 
ISBN 978-92-76-53172-2 

doi:10.2838/742767 
doi:10.2838/093100 

DS-09-22-227-EN-N 
DS-09-22-227-EN-Q

  Contents

ABSTRACT 

EXECUTIVE SUMMARY 

RÉSUMÉ ANALYTIQUE 

1. 

INTRODUCTION 

  Definitions 

2. 

 WHAT ARE THE MAIN PROBLEMS AND THEIR 
DRIVERS AND CONSEQUENCES? 

  2.1.  Drivers 

  2.2.  Scale of the problem  

  2.3.  How will the problems evolve? 

  2.4.  Objectives: what is to be achieved?  

  2.5.  What are the available policy options?  

2

3

5

7

8

9

9

14

16

19

19

  4.3.  Coherence 

  4.4.  Efficiency  

5.  THE PREFERRED POLICY OPTION 

46

47

48

6. 

 HOW WILL ACTUAL IMPACTS BE MONITORED  
AND EVALUATED? 

49

ANNEX 1. 

 HOW WILL THE IMPACT BE  
MONITORED? 

ANNEX 2.  STAKEHOLDER CONSULTATION 

  1.1.  Stakeholder Engagement Methods  

  1.2.  Stakeholder views 

ANNEX 3.  WHO IS AFFECTED AND HOW? 

ANNEX 4.  ANALYTICAL METHODS 

3.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 22

  1.  General 

  3.1.  Policy option 0: Baseline 

  3.2.  Policy option 1: Moderate 

  3.3.  Policy option 2a: Comprehensive 

  3.4.  Policy option 2b: Comprehensive 

4.  COMPARISON OF THE POLICY OPTIONS 

  4.1.  Effectiveness 

  4.2.  Effectiveness – other impacts  

22

22

29

36

43

45

46

  2. 

  3. 

  4. 

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

 Estimation of administrative and compliance  
costs 

 Estimation of cost reductions (economic  
benefits) 

50

54

54

57

66

70

70

70

71

82

1

Abstract

This study supports the impact assessment for an initiative 
that develops a set of measures with the objectives of: 
preventing violence against women and domestic violence, 
providing victims with improved protection, support and 
access to justice, and strengthening coordination. Violence 
against women is a violation of human rights and a form 
of discrimination that can occur in any context. Domes-
tic violence differs in that it occurs within the family or 

domestic unit. Both include physical, sexual, psychological 
or economic harm or suffering. The initiative responds to 
fragmentation in the EU acquis and the high prevalence of 
the problem, whereby one in three in women have experi-
enced violence against women and domestic violence. The 
initiative will benefit victims and enable all citizens across 
all Member States to live in societies that are more equal, 
just and violence free. 

2

Executive Summary

What is the problem and why is 
it a problem at EU level?

Violence against women and domestic violence is a form 
of gender discrimination and a violent crime that remains 
highly prevalent in the EU, with one in three women expe-
riencing physical and/or sexual violence in their lifetime1. 
Existing prevention measures have therefore proved to be 
insufficient, and many victims struggle to access protection, 
support and justice. Data on the subject is also lacking or 
incomparable between Member States which hinders more 
effective monitoring and responses to the problem. 

access to protection and support services within and across 
Member States. Legislative measures are necessary for 
addressing this kind of violent crime in an effective and 
sustainable manner. EU level action can increase their ef-
fectiveness by specifying minimum standards and adding 
value in line with good practices and recommendations of 
international monitoring bodies and research. EU-legislation 
on violence against women and domestic violence would 
further align the EU legal framework with internationally 
recognised norms and permit coordinated action at EU level, 
particularly in the six Member States which have not ratified 
the Istanbul Convention. 

What are the objectives? 

What are the various options to 
achieve the objectives? 

The general objective of the initiative is to prevent and 
combat violence against women and domestic violence as 
a criminal act and a form of discrimination between women 
and men. The specific objectives are: ensuring effective pre-
vention of violence against women and domestic violence; 
protection of victims; access to justice; victim support; and 
strengthened coordination.

What is the value added of action 
at the EU level (subsidiarity)? 

Although all Member States have adopted national legisla-
tion and policies to prevent and combat violence against 
women and domestic violence these have not led to an ob-
servable decrease in this kind of violent crime in the EU. The 
multitude of national approaches creates legal uncertainty 
regarding the rights of victims of violence against women 
and domestic violence as well as significant differences in 

Two options are outlined, in addition to the baseline: Option 
1 which sets out measures which are considered to have 
moderate impact on the policy objectives and Options 2a 
and 2b which would have a more comprehensive impact. 

What are stakeholders’ views? 

Extensive consultation with stakeholders showed a broad 
consensus for EU action across all the measures and op-
tions. This was rooted in clear agreement about the scale of 
the problem and the lack or deficiency of current measures 
that do not consider the particular needs and experiences 
of victims of violence against women and domestic vio-
lence. There were particular calls to address online violence 
against women and domestic violence and ensure an in-
clusive approach that benefits all victims. Employer as-
sociations expressed concerns about additional obligations 

1 

https://eige.europa.eu/gender-based-violence/what-is-gender-based-violence

3

they could face which have been considered in deciding 
the preferred option. 

against women and domestic violence can be expected to 
generate cost reductions amounting to EUR 82.7 billion.

Impact of the options and preferred option

What are the costs of the preferred option? 

All three options are assessed as having a positive impact 
on achieving the policy objectives. Policy Option 2b is consid-
ered to have the most impact but, following the comparative 
assessment of the effectiveness, efficiency and coherence 
of the options, Policy Option 2a is the preferred option as 
Policy Option 2b ultimately becomes more costly than Policy 
Option 2a in the long run and places a disproportionate 
burden on SMEs and the Member States. 

What are the benefits of the preferred option?

In the short term, a total benefit of EUR 53.1 billion can be 
expected, resulting from a 20% reduction in the prevalence 
of violence against women and domestic violence. This will 
be achieved primarily as a result of reduced costs related to 
physical and emotional impacts, lost economic output and 
costs of the criminal justice system. Other areas, such as 
health services and social welfare, will also incur lower costs 
due to decreased numbers of victims of violence against 
women and domestic violence as a result of the measures 
implemented under the preferred policy option. In the long 
term, a 30% reduction in the number of victims of violence 

The costs associated with the implementation of the pre-
ferred option are expected to range from EUR 4.98 to 6.59 
billion in the first year, subsequently ranging between EUR 
4.96 and 6.58 billion in the years to come. The areas re-
quiring the highest levels of spending include provisions 
to prevent sexual harassment at work, as well as on- and 
offline support for victims of cyber violence against women. 
Considerable investments will also have to be made for 
the provision of surveyed safe places for child victims and 
witnesses of DV, and the provision of medical care and 
complaint mechanisms for victims of sexual harassment 
at work.

How will the initiative be monitored? 

The establishment of a system for data collection and moni-
toring is one of the core impacts pursued by the preferred 
option. This includes the enhanced ability to monitor preva-
lence of violence against women and domestic violence 
through the regular collection of sex-disaggregated data. 
Monitoring will make use of proxy monitoring of other initia-
tives to reduce the administrative burden on Member States. 

4

Résumé analytique

Quelle est la problématique ?

La violence à l’encontre des femmes et la violence do-
mestique constituent une forme de discrimination fondée 
sur le genre et de délinquance violente qui demeure très 
répandue dans l’UE, où une femme sur trois subit des vio-
lences physiques et/ou sexuelles au cours de sa vie2. Par 
conséquent, les mesures de prévention existantes se sont 
avérées insuffisantes, et de nombreuses victimes ont du 
mal à accéder à la protection, à l’aide et à la justice. Les 
données sur la question sont, elles aussi, insuffisantes ou 
incomparables entre les États membres, ce qui empêche 
de mettre en place un suivi et des réponses efficaces au 
problème. 

Quels sont les objectifs?

L’objectif général de l’initiative est de prévenir et de com-
battre la violence à l’encontre des femmes et la violence 
domestique en tant que délits et forme de discrimination 
entre les femmes et les hommes. Les objectifs particuliers 
sont les suivants : assurer la prévention effective de la vio-
lence à l’encontre des femmes et de la violence domestique, 
la protection des victimes, l’accès à la justice, l’aide aux 
victimes et une coordination renforcée.

Quelle est la valeur ajoutée de l’action 
au niveau de l’UE (subsidiarité) ? 

Bien que tous les États membres aient adopté leurs propres 
législations et politiques nationales pour prévenir et com-
battre la violence à l’encontre des femmes et la violence 
domestique, celles-ci n’ont pas donné lieu à une diminution 

visible de ce type de délinquance violente dans l’UE. La 
multitude d’approches nationales engendre une insécurité 
juridique concernant les droits des victimes de la violence 
à l’encontre des femmes et de la violence domestique, ainsi 
que des différences de taille dans l’accès à la protection et 
aux services d’aide au sein des États membres et d’un État 
membre à l’autre. Des mesures législatives s’avèrent néces-
saires pour s’attaquer à ce type de délinquance violente 
d’une manière efficace et durable. Une action au niveau de 
l’UE peut accroître l’efficacité, en définissant des normes 
minimales et en créant une valeur ajoutée conformément 
aux bonnes pratiques et recommandations des organes 
de suivi et des chercheurs internationaux. Par ailleurs, une 
législation de l’UE concernant la violence à l’encontre des 
femmes et la violence domestique harmoniserait le cadre 
juridique de l’Union avec les normes internationalement 
reconnues et permettrait une action coordonnée au niveau 
de l’UE, notamment dans les six États membres qui n’ont 
pas ratifié la Convention d’Istanbul. 

Quelles sont les différentes options 
disponibles pour atteindre ces objectifs ? 

Deux options s’esquissent, en sus de la base de référence : 
l’option 1 prévoit des mesures considérées comme ayant 
un impact modéré sur les objectifs politiques, tandis que 
les options 2a et 2b auraient un impact plus exhaustif. 

Quels sont les points de vue des 
différentes parties prenantes ? 

Une  consultation  approfondie  des  parties  prenantes 
montre un large consensus en faveur d’une action de 

2 

https://eige.europa.eu/gender-based-violence/what-is-gender-based-violence

5

l’UE concernant l’ensemble des mesures et options. Ceci 
était ancré dans un accord clair concernant l’étendue du 
problème et le manque ou la déficience des mesures ex-
istantes, lesquelles ne saisissent pas les besoins et situa-
tions particuliers des victimes de la violence à l’encontre 
des femmes et de la violence domestique. Il y a eu des 
demandes particulières pour aborder en ligne la violence à 
l’encontre des femmes et la violence domestique et assurer 
une approche inclusive bénéfique à toutes les victimes. Les 
associations d’employeurs ont exprimé certaines préoccupa-
tions concernant les obligations additionnelles auxquelles 
elles pourraient se voir confrontées, lesquelles ont été prises 
en considération à l’heure de décider l’option à privilégier. 

Impact des options et option retenue

Les trois options ont été évaluées comme susceptibles 
d’avoir un impact positif sur la réalisation des objectifs 
stratégiques. L’option politique 2b a été considérée comme 
la plus retentissante mais, à l’issue d’une évaluation com-
parative de l’efficacité, de l’efficience et de la cohérence des 
options, l’option politique 2a été retenue, car l’option 2b 
s’avère, in fine, plus coûteuse que l’option 2a sur le long 
terme et fait peser une charge disproportionnée sur les 
PME et les États membres. 

des frais, grâce à la diminution du nombre de victimes 
de la violence à l’encontre des femmes et de la violence 
domestique, du fait des mesures mises en œuvre dans le 
cadre de l’option politique retenue. Sur le long terme, une 
réduction de 30 % du nombre de victimes de la violence à 
l’encontre des femmes et de la violence domestique peut 
être attendue, donnant lieu à des diminutions de coûts de 
l’ordre de 82,7 milliards d’euros.

Quels sont les coûts de l’option retenue ? 

Les coûts associés à la mise en œuvre de l’option retenue 
devraient s’élever à 4,98–6,59 milliards d’euros au cours 
de la première année, oscillant, par la suite de 4,96 à 
6,58 milliards d’euros les années suivantes. Les domaines 
exigeant les niveaux les plus élevés de dépense incluent 
les dispositions visant à prévenir le harcèlement sexuel au 
travail, ainsi qu’une aide en ligne et hors ligne aux victimes 
de la violence informatique à l’encontre des femmes. Des 
investissements considérables devront aussi être consentis 
pour la mise à disposition de lieux sûrs surveillés pour les 
enfants victimes et les témoins des violences domestiques, 
ainsi que pour la fourniture de soins médicaux et de mé-
canismes de signalement pour les victimes de harcèlement 
sexuel au travail.

Quels sont les avantages de l’option retenue ?

Comment l’initiative sera-t-elle supervisée ? 

Sur le court terme, un bénéfice total de 53,1 milliards d’euros 
peut être attendu, résultant d’une réduction de 20 % de la 
prévalence de la violence à l’encontre des femmes et de 
la violence domestique. Ceci serait réalisé, principalement, 
grâce à la réduction des coûts associés aux répercussions 
physiques et émotionnelles et à la perte de rendement 
économique, ainsi que des coûts afférents au système de 
justice pénale. D’autres domaines, comme les services de 
santé et de protection sociale encourront, eux aussi, moins 

La mise en place d’un système pour la collecte des données 
et le suivi constitue, en tant que telle, l’une des principales 
répercussions visées par l’option retenue. Ceci inclut une 
capacité accrue de suivi de la prévalence de la violence à 
l’encontre des femmes et de la violence domestique par 
l’intermédiaire de la collecte régulière de données ventilées 
par sexe. Le suivi fera appel à une supervision intermédiaire 
d’autres initiatives, afin de réduire la charge administrative 
pesant sur les États membres. 

6

Introduction1. 

Introduction

The topic of violence against women and domestic violence 
remains high on the public and political agenda. Atten-
tion increased with the publication of the Fundamental 
Rights Agency (FRA) survey in 2014 which showed the high 
prevalence of incidents of violence against women3: one 
woman in three has experienced some form of physical 
and/or sexual violence since the age of 15. Most recently, 
the COVID-19 pandemic brought along severe lockdowns in 
many countries worldwide, including across the European 
Union (EU). By April 2020, victim support organisations, 
police forces and governments began to release figures 
showing sharp increases in the numbers of women reporting 
incidents of violence4. 

Against this context, in her political guidelines President 
von der Leyen announced that the Union should do ‘all it 
can to prevent and combat gender-based violence, support 
and protect victims of such crimes, and hold perpetrators 
accountable for their abusive behaviour’5. The EU Gender 
Equality Strategy 2020-20256 announced key actions 
for preventing and combatting violence against women and 
domestic violence in the Europe Union and, in particular, a 
legislative proposal tackling such violence. 

At international level, the Council of Europe Convention on 
preventing and combating violence against women and 
domestic violence (‘Istanbul Convention’) was the first 
instrument in Europe to set legally binding standards on 
combatting violence against women and domestic violence 
through a holistic approach. The EU signed the Convention 
on 13 June 2017 and, although the EU accession to the 
Istanbul Convention remains firm on the political agenda7 
of the current European Commission8, to date, the process 
has stalled. On 6 October 2021, the Court of Justice of the 
European Union (CJEU) issued its opinion on the EU acces-
sion to the Istanbul Convention9. The CJEU clarified that the 
EU can accede to the Convention even if not all Member 
States have ratified it, but grants the Council discretion to 
gather the largest possible consensus in support of the 
accession. It is therefore not possible to predict when the 
EU’s accession to the Istanbul Convention might take place, 
and how many Member States would eventually ratify the 
Convention. This initiative aims to achieve the objectives 
and standards of the Istanbul Convention in the areas of 
EU competence and fill gaps identified in the EU acquis in 
matters of judicial cooperation in criminal matters covered 
by the Convention. 

3 

4 

5 

6 

7 

FRA (2014): Violence against women: an EU-wide survey. Main results report, https://fra.europa.eu/en/publication/2014/violence-against-women-eu-
wide-survey-main-results-report 
See the data presented in ‘Coronavirus and the shadow pandemic of violence against women’ by Rosamund Shreeves, November 2020, published 
by EPRS Blog https://epthinktank.eu/2020/11/24/coronavirus-and-the-shadow-pandemic-of-violence-against-women/
A Union that strives for more. My agenda for Europe; https://ec.europa.eu/commission/sites/beta-political/files/political-guidelines-next-commission_
en.pdf 
European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions. A Union of Equality: Gender Equality Strategy 2020-2025, COM(2020) 152 final, 5 March 2020.
The current Gender Equality Strategy has confirmed the EU’s intention to access the Convention: https://ec.europa.eu/info/policies/justice-and-
fundamental-rights/gender-equality/gender-equality-strategy_en 

8  Declarations of the EC’s President von der Leyen and of the Equality Commissioner, Dalli in 2020. COM(2020) 152 final; https://www.europarl.

europa.eu/doceo/document/OJQ-9-2020-11-25_EN.html# 
Court of Justice of the European Union (Grand Chamber); opinion A-1/19 of 6 October 2021.

9 

7

IntroductionIntroductionDefinitions

This study covers violence against women and domestic 
violence as defined by the Istanbul Convention (see box). 

The term gender-based violence is commonly used to 
highlight the dynamics and drivers behind this type of vio-
lence and often used interchangeably with violence against 
women, as most violence against women is inflicted due to 
their gender. This supporting study follows the approach of 
the Istanbul Convention and uses the term violence against 
women.

Violence against women is a form of discrimination and 
is rooted in an unequal balance of power between women 
and men. It is both a cause and consequence of gender 
inequality. Certain groups of women, such as young girls, 
elderly women, women with disabilities or migrant women 
are often found to be at higher risk of violence of violence 
against women and domestic violence.

This supporting study also includes assessment of other 
forms of violence which are not included or defined by the 
Istanbul Convention but are nonetheless prevalent forms 
of violence against women. Online or Cyber violence 
against women refers to online content or activity which 
targets the victim because she is a woman or targets wom-
en victims disproportionately10. Cyber violence can also be 
perpetrated between current or former intimate partners11. 
Cyber violence can take a variety of forms, ranging from 

cyber stalking and non-consensual sharing of private and 
intimate images or personal data to sexual cyber harass-
ment12. Sexual harassment is included as it is currently 
covered by a number of gender equality directives which 
have proven not to be effective in preventing and combat-
ting this type of violence against women.

Key Terms

Violence against women = a violation of human 
rights and a form of discrimination against women 
and shall mean all acts of gender-based violence 
that result in, or are likely to result in, physical, sex-
ual, psychological or economic harm or suffering to 
women, including threats of such acts, coercion or 
arbitrary deprivation of liberty, whether occurring in 
public or in private life.

Domestic violence = all acts of physical, sexual, 
psychological or economic violence that occur within 
the family or domestic unit or between former or 
current spouses or partners, whether or not the per-
petrator shares or has shared the same residence 
with the victim. Thus, domestic violence covers not 
only women, but any person living in the household, 
including men and children.

10  See HRC, Report of the Special Rapporteur on online violence against women and girls, at 23. European Parliament Research Centre, Combating 

gender-based violence: cyber violence. European added value assessment, 2021, at 4-7. Also Centre for international governance innovation (CIG), 
What is gender-based online violence, https://www.cigionline.org/multimedia/what-is-online-gender-based-violence/.

11  CyberSafe. Cyber violence against women and girls. Final report 2021, pp. 29- 34. 
12  Council of Europe Cybercrime Convention Committee (C-TY) 2017, Mapping study on cyber violence (T-CY (2017)10), at 6. European Institute for 
Gender Equality (EIGE), Cyber violence against women and girls, 2017. GenPol Gender & Policy Insights 2019. When technology meets misogyny. 
Multi-level, intersectional solutions to digital gender-based violence, p. 16.

8

What are the main problems and their drivers and consequences?Introduction2.  What are the main problems and their drivers and 
consequences?

Violence against women and domestic violence is a wide-
spread problem across the EU, as most clearly indicated by 
its high prevalence. This section outlines five core problems, 

as well as their drivers and consequences, as summarised 
in the below ‘problem tree’. 

2.1.  Drivers

Social norms and stereotypes: violence against women 
and domestic violence in its diverse forms is not always 
perceived as an issue that affects women’s lives. Certain 
forms of harassment, such as uncomfortable staring, 
catcalling and lewd gestures are seen as simply normal 
nuisances that women have learned to put up with. Oth-
er forms, such as DV, are sometimes considered private 
matters. In a recent Eurobarometer survey (2016) ap-
proximately one in six respondents believed that domestic 
violence should not always be punished by law and should 

be treated as a private matter that should be handled 
within the family. 

The role men play in the perpetuation of a violent culture 
and behaviours against women is not always recognized in 
educational and perpetrator programmes. About one in five 
respondents in a Eurobarometer survey expressed victim-
blaming views, agreeing that women make up or exaggerate 
claims and that violence against women is often provoked by 
the victim. Just under one in five respondents (17%) agreed 

9

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?Introductionthat violence against women is often provoked by the victim, 
with respondents in Eastern areas of the EU most likely to 
agree. More than one in four respondents thought sexual 
intercourse without consent can be justifiable. The fact that 
a non-negligible minority holds these views perpetuates 
violence and leads to impunity for perpetrators. 

Lack of recognition of the specificities of crimes and 
offences: Violence against women and domestic violence 
is a very specific form of crime and thus requires a tailored 
response by professionals. For instance, a lack of evi-
dence can make prosecution difficult. Domestic violence 
and other forms of violence (for example psychological 
violence) typically produce little or no physical evidence, 
and take place in private settings which means there are 
no witnesses other than the victim. In anti-trafficking cases, 
the third progress report noted there can be evidentiary 
difficulties because of the complexity of the elements of 
the case, difficulties ensuring there is the right level of 
resources and knowledge for carrying out financial inves-
tigations, and difficulties in cross-border and international 
cooperation13. Furthermore, domestic violence especially 
also requires an approach to evidence collection that rec-
ognises the specific nature of the crime. For example, 
domestic violence is often a purposeful pattern of behav-
iour, rather than a single incident, which may be overlooked 
by investigators untrained in domestic violence cases14. 

The stigma associated with violence against women and 
domestic violence and trauma involved can also hinder re-
porting and access to justice, protection and support. Victims 
may be unwilling to make a statement because it can mean 
reliving traumatic incidents and because they fear negative 
reactions from others, including victim-blaming and stigma. 
Victims can also feel disbelieved and belittled if the case is 

dismissed as ‘he-said-she-said’. Victims may also withdraw 
their statement because of their close relationship to the per-
petrator which can make victims vulnerable to manipulation. 

2.1.1.  Problem 1: Existing efforts to prevent violence 
against women and domestic violence are fragmented 
and perpetuate social norms and attitudes that nor-
malize violence against women and domestic violence

To address the problem of violence against women and 
domestic violence in all its forms, Member States have 
introduced different measures, such as public awareness 
raising campaigns, training to law enforcement and judicial 
authorities and perpetrator programmes. These were all 
considered necessary to address underlying patriarchal/ste-
reotypical attitudes and to apply a gendered understanding 
of violence. As EIGE noted, ‘there is a causal link between 
harmful gender stereotypes and violence against women 
and domestic violence’ 15. However, to date the effective-
ness of the measures has been limited.

Public discussion and awareness

In the last few years, all Member States have introduced 
some form of measures to promote gender equality and 
challenge prevailing social norms and stereotypes. In re-
sponse to the targeted consultation with Member State 
authorities, 23 Member States reported to have organised 
awareness raising campaigns on violence against women 
and/or domestic violence16. There are a number of short-
comings with existing campaigns as they: are not system-
atic, focus predominantly on victims of domestic violence 
and not victims of other types of violence, do not reach 
target groups meaningfully; are too focused on victims and 
directing them towards services, with little emphasis on 

13  European Commission (2020) Third report on the progress made in the fight against trafficking in human beings https://ec.europa.eu/anti-trafficking/

sites/default/files/third_progress_report.pdf

14  FRA (2019) Sanctions that do justice – justice for victims of violent crimes part III’ p.19 https://fra.europa.eu/en/publication/2019/sanctions-do-

justice-justice-victims-violent-crime-part-iii

15  EIGE, written submission to the public consultation. 
16  Targeted Consultation with Member State authorities q.10. No response from HU. 

10

What are the main problems and their drivers and consequences?their right to be protected against these forms of violence 
against women; and are not sufficiently targeting perpetra-
tors to address their behaviour and their role in perpetuating 
violence against women and domestic violence17.

Treatment of perpetrators

Prevention measures are not only limited to awareness rais-
ing and training of competent authorities. To have a more 
comprehensive approach, work with perpetrators is needed to 
prevent reoffending. The EU provisions do not regulate treat-
ment of perpetrators of all forms of violence against women 
and domestic violence. The European Network for Work with 
Perpetrators (WWP EN) considered that current EU legislation 
had limited relevance to their work and that the Istanbul 
Convention is the main driver of change across the EU18. 
In the targeted consultation with Member State authorities 
(outlined in Annex 2), all but one country (HU) reported hav-
ing set up support programmes for perpetrators of violence 
against women and domestic violence19. Description of the 
measures show that most target domestic violence and not 
all are compulsory. According to WWP EN, most countries do 
not have structured programmes in place for perpetrators, 
although there are more programmes available in prison20. 

Training and capabilities of professionals to identify 
and address violence against women and domestic 
violence

Training for professionals is another measure common 
measure introduced to prevent violence against women and 

domestic violence. Even though it has been widely recognized 
that well-trained, informed, and sensitised professionals are 
important to prevention efforts, in practice available training 
programmes are insufficient. The training of professionals, 
particularly among police and judicial authorities, in their 
interaction with victims, is lacking and needs improvement. 
This finding is supported, for example, by GREVIO monitoring 
of Article 16 of the Istanbul Convention.21 Some common 
problems highlighted by GREVIO about the trainings delivered 
to different categories of professionals are: lack of gender 
sensitivity, gender awareness and recognition of violence 
against women as rooted in discrimination. Moreover, train-
ings where they exist, are not regular or mandatory. 

2.1.2.  Problem 2: Protection of victims of violence 
against women and domestic violence, especially the 
most vulnerable ones, is ineffective, increasing the 
risk of repeat victimisation

Protection of victims of violence against women and do-
mestic violence from repeat victimization is crucial. While 
there are no reliable EU data on repeat victimization, data 
from the UK suggest that more than a quarter of domes-
tic violence victims (27%) have been victimized between 
two and four times.22 To address this problem, protection 
measures are essential. 

To prevent further violence, protection orders and emer-
gency protection/barring orders can be issued. Existing 
protection order provisions do not cover all victims of vio-
lence against women23and there are challenges in take-up 

17  GREVIO (2021) ‘Mid-term Horizontal Review of GREVIO baseline evaluation reports’ pp.53-57. https://rm.coe.int/horizontal-review-study-

2021/1680a26325. Targeted Consultation with Member State authorities q.10. No response from HU
Interview with European Network for Work with Perpetrators (WWP EN), 2 July 2021. 

18 
19  Targeted consultation with Member State authorities q. 29. No response: PL, HR, LT
20 
21  GREVIO (2021) ‘Mid-term Horizontal Review of GREVIO baseline evaluation reports’ pp.53-57. https://rm.coe.int/horizontal-review-study-

Interview with European Network for Work with Perpetrators (WWP EN), 2 July 2021. 

2021/1680a26325

22  EIGE (2021) ‘The cost of gender-based violence in the European Union’, p.11.https://eige.europa.eu/publications/costs-gender-based-violence-

23 

european-union
In France and Portugal they are only available for victims of domestic violence. GREVIO (2021) ‘Mid-term Horizontal Review of GREVIO baseline 
evaluation reports’ pp.53-57. https://rm.coe.int/horizontal-review-study-2021/1680a26325

11

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?because of the time taken to access orders24, insufficient 
sanctions for breaking them and lack of awareness of 
their availability25. Individual assessments, which can help 
lead to protection measures, are not well-implemented in 
practice, not available in all Member States or only cover 
certain crimes.26 

psychological, economic and online violence. Member States 
also vary in how these forms of violence are criminalised 
and the exact definition. Of note, most are criminalised 
in a gender-neutral manner, except for FGM, and further 
forced marriage is not widely considered a form of violence 
against women.28 

2.1.3.  Problem 3: Victims of violence against women 
and domestic violence face significant obstacles in 
their efforts to access justice

Women and children face different forms of violence with-
out the possibility to access justice. Reporting rates of 
incidents of violence against women and domestic 
violence remain low. A survey conducted by FRA in 2021 
shows that most incidents of violence and harassment are 
not reported to the authorities.27 This is rooted in a lack 
of awareness of support and protection available, stigma 
associated with being a victim, a lack of gender-sensitive 
response by professionals and a perception that many cases 
do not result in successful prosecution. 

Another barrier to justice is that all forms of violence against 
women and domestic violence are not criminalised con-
sistently across all Member States, particularly regarding 

Another core problem in terms of accessing justice is access 
to compensation, and compensation that is commensurate 
with the crime. While victims of violence against women 
can claim compensation from the perpetrator in all Mem-
ber States29, in most cases state compensation is provided 
only to victims of violent crimes excluding other forms 
of violence. There is also evidence that levels of com-
pensation are not adequate30. This can have particularly 
damaging consequences for victims of violence against 
women and domestic violence as they may need the funds 
to as a means for ‘re-building an independent and violence-
free life of dignity’, especially as domestic violence can 
often occur in situations of economic dependence31. CJEU 
in C-129/19, for example, considered that the fixed rate 
of €4800 awarded in a case of sexual violence in Italy 
was “manifestly insufficient,” because “sexual violence 
… gives rise to the most serious consequences of violent 
intentional crime”32. 

24  Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis report’. https://victimsupport.eu/activeapp/

wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-web.pdf. 

25  This issue was highlighted in the targeted consultation with Member State authorities q.18 by NL, CZ, FI, BE, FR.
26  Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis report’. https://victimsupport.eu/activeapp/

wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-web.pdf. 

27  FRA (2021) Crime, safety and victims’ rights – Fundamental Rights Survey. Available from: https://ec.europa.eu/eurostat/statistics-explained/index.

php?title=Crime_statistics&stable=0&redirect=no 

28  European Commission, European Equality Law Network, (2021) ‘Criminalisation of gender-based violence against women in European States, 

including ICT-facilitated violence’, Luxembourg, Publications of the European Union. Available from: https://www.equalitylaw.eu/downloads/5535-
criminalisation-of-gender-based-violence-against-women-in-european-states-including-ict-facilitated-violence-1-97-mb

29  European Commission, European Equality Law Network, (2021) ‘Criminalisation of gender-based violence against women in European 

States, including ICT-facilitated violence’, Luxembourg, Publications of the European Union, p.185. Available from: https://www.equalitylaw.eu/
downloads/5535-criminalisation-of-gender-based-violence-against-women-in-european-states-including-ict-facilitated-violence-1-97-mb
30  European Commission (2019) ‘Strengthening victims’ rights: from compensation to reparation’ p.26. https://ec.europa.eu/info/sites/default/files/

strengthening_victims_rights_-_from_compensation_to_reparation.pdf

31  European Commission (2019) ‘Strengthening victims’ rights: from compensation to reparation’ p.26. https://ec.europa.eu/info/sites/default/files/

strengthening_victims_rights_-_from_compensation_to_reparation.pdf

32  CJEU in C-129/19 

12

What are the main problems and their drivers and consequences?2.1.4.  Problem 4: The quality and availability of 
support services varies significantly across Member 
States and in some cases is insufficient

Support services, such as counselling and shelters for vic-
tims and their children, are fundamental in helping women 
to leave abusive relationships and avoid repeat victimisa-
tion. Existing data shows that the number of shelters is 
insufficient, with only three Member States meeting the 
standards put forward in the Istanbul Convention.33

Several Member States have developed a wider and strong-
er network of specialist support services that assist 
victims of DV, however specialist support services for victims 
of other forms of gender-based violence such as female 
genital mutilation is limited. There are also access chal-
lenges for women who do not have residency34 and women 
living with a disability35.

Specific groups of victims receive even less support. Vic-
tims of online violence, for example, receive little sup-
port, particularly because it is a relatively new form of 
violence that is not yet recognised as a crime: no coun-
tries, except Romania, have a specific definition of online 
violence in law36. This is a particular problem because 
the prevalence of this form of violence is estimated to 
be very high. FRA estimates that 11% of women have 
experienced cyber harassment or cyber stalking since the 
age of 1537. EIGE (2017) has also noted that responses of 

law enforcement agencies across the EU to instances of 
online violence against women reveal deeply concerning 
inadequacies in approaching such forms of abuse, as well 
as in the treatment of its victims38. 

Another group that can struggle to access the support 
they need, and access justice is victims of sexual har-
assment at work. Equality bodies represent a crucial 
source of support for many victims of discrimination at 
work, however only six Member States have the capacity 
to receive gender-based violence related complaints (AT, 
BE, EE, IT, PT, SL)39. 

2.1.5.  Problem 5: Significant obstacles persist in 
accessing comparable and high-quality EU data on 
different forms of violence against women and do-
mestic violence

In the last few years, efforts have been made at EU level 
to address the problem of data collection on aspects of 
violence against women and to ensure comparability at 
this level.40 Eurostat and other EU agencies (FRA, EIGE, 
Eurofound) have carried out substantive work in this area, 
supporting Member States to improve their data collection 
approaches and advocating for an EU-wide uniform system 
for mapping data on VAW. At the Member State level, recent 
GREVIO evaluations noticed that states have been increas-
ingly establishing systems to disaggregate data by type 
of violence, sex, age and relationship of the perpetrator to 

Interview with PICUM, 2 July 2021. 

33  WAVE (2019) Wave Country Report 2019. https://www.wave-network.org/2019/12/30/wave-country-report-2019.
34 
35  European Disability Forum contribution to public consultation. 
36  European Commission, European Equality Law Network, (2021) ‘Criminalisation of gender-based violence against women in European States, 

including ICT-facilitated violence’, Luxembourg, Publications of the European Union. Available from: https://www.equalitylaw.eu/downloads/5535-
criminalisation-of-gender-based-violence-against-women-in-european-states-including-ict-facilitated-violence-1-97-mb

37  Quoted in European Parliament report (2021) ‘Combating gender-based violence: cyber violence’ p.8. https://www.europarl.europa.eu/RegData/

etudes/STUD/2021/662621/EPRS_STU(2021)662621_EN.pdf

38  European Institute for Gender Equality (2017), ‘Cyberviolence against women and girls’. https://eige. europa.eu/publications/cyber-violence-against-

women-and-girls.

39  European Commission, European Equality Law Network, (2021) ‘Criminalisation of gender-based violence against women in European 

States, including ICT-facilitated violence’, Luxembourg, Publications of the European Union, p.117. Available from: https://www.equalitylaw.eu/
downloads/5535-criminalisation-of-gender-based-violence-against-women-in-european-states-including-ict-facilitated-violence-1-97-mb

40  EIGE ‘Data collection on violence against women’. Available from: https://eige.europa.eu/gender-based-violence/data-collection

13

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?the victim. However, very few data are collected and 
disaggregated based on the mentioned categories. 
Data collection systems often vary from one public body 
to another and are rarely harmonised, which prevents the 
effective mapping of trends throughout the entire judicial 
process (from the time a crime is reported to the police 
until the end of the judicial proceedings). 

Collecting data in an aggregate form while not ensuring 
compatibility between institutions or missing out certain 
categories creates a distorted image of the existing reality 
and hides gaps. These gaps could be identified and addressed 
with more comprehensive and timely data collection.

2.1.6.  Consequences 

 Violence against women and domestic violence has conse-
quences at an individual, organisational and wider societal 
level. At an individual level, violence against women can 
have detrimental effects on a victim’s life, health, well-being 
and income. In cases of child victims, violence has long-
term effects in the physical, psychological and emotional 
development of the child. At organisational level, violence 
against women and domestic violence and gender-based 
harassment affect the economic performance of companies 
by lowering employee engagement and increasing absences. 
At a societal level, violence perpetuates inequalities, dis-
crimination and injustice in society. 

2.2.  Scale of the problem 

 Violence against women and domestic violence continues 
to be a persistent and widespread problem across the EU 
affecting significant proportions of women and other house-
hold members. Yet, the real magnitude and consequences 
can only be estimated as the area lacks systematic research 
and robust, recent data. 

 Violence against women and domestic violence con-
tinues to be a persistent and widespread problem 
across the EU. FRA’s EU-wide survey on VAW41, based 
on interviews with 42,000 women across the EU, paints 
a stark picture. One woman in three aged 15 or above 
has experienced some form of physical and/or sexual vio-
lence. One in 10 women has been victim to some form of 
sexual violence, and one in 20 has been raped. Just over 
one in five women has suffered physical and/or sexual 
violence from either a current or previous partner, whilst 
43% of women have experienced some form of psycho-
logically abusive and/or controlling behaviour when in a 
relationship. 

EIGE provided a composite measure42 of gender-based 
violence across the EU, in terms of prevalence, severity 
and disclosure. Prevalence measures the share of women 
who have experienced physical and/or sexual violence since 
the age of 15 (including femicide) and it was estimated at 
21.2% for EU-28. Regarding severity measures, the per-
centage of women who experienced health consequences 
of physical and/or sexual violence was estimated at 46.9% 
for EU-28. Regarding disclosure measures, the reporting 
(to anyone) of violence experienced in the past 12 months 
was estimated at 14.3% for EU-28.

Often violence occurs within the household either 
between intimate partners or intergenerationally. 
Acts of physical violence (excluding sexual violence) 
against women usually do not occur at places or by 
people unknown to them. The second report from FRA’s 
Fundamental Rights survey43 highlighted that most often 
women become victims in their own homes (37%) and the 
perpetrator is a family member or relative. In contrast, 
these incidents for men most often involve a perpetrator 
they do not know (42%).

Idem. 

41 
42  EIGE Gender Statistics Database: https://eige.europa.eu/gender-statistics/dgs
43  FRA (2021) Crime, safety and victims’ rights – Fundamental Rights Survey. Available from:https://ec.europa.eu/eurostat/statistics-explained/index.

php?title=Crime_statistics&stable=0&redirect=no 

14

What are the main problems and their drivers and consequences?Data collected by Eurostat44 on the number of reported 
incidents of intentional homicide, rape and sexual assault 
show that over half of all female murder victims are killed 
by an intimate partner, relative or family member. These 
data demonstrate that violence against women tends to 
be widespread, taking several forms, including femicide in 
domestic and/or intimate partner relationships.

The same tendency emerges when analysing administra-
tive data on homicides, collected from national authori-
ties across the EU-27 and published by EIGE. In the three 
countries where data is available for 2016 (the last year 
covered by the data collection), women are three to nine 
times more likely to become victim of homicide by men 
known to them45. 

To understand the scale of physical VAW, it should be noted 
that rates of reporting to the police range from 9% to 40% 
across the Member States46. This means that the level of 
physical violence, particularly by men known to the victim, 
is likely to be significantly higher. 

Harassment of a sexual nature affects women 
more severely than men and is most often com-
mitted by unknown persons. The second report from 
FRA’s Fundamental Rights survey47 highlights that 72% 
of women and 40% for men have experienced harass-
ment of a sexual nature by unknown persons. More than 
every second woman affected says that harassment of 
a sexual nature took place in public, such as a street or 

park. Women thus are more likely than men to avoid 
places and situations due to concerns, reducing their 
ability to take part in public life. 

Gender-based violence also disproportionately af-
fects women’s professional life. Eurofound’s publica-
tion48 found that adverse social behaviour is more fre-
quently reported by women, particularly by young women, 
than by men. It happens more often in the public sector 
and in female-dominated professions i.e. personal care 
workers.

The emergence of digital technologies comes with 
increasing danger of cyber violence for women, par-
ticularly young women. Women, especially young wom-
en, are particularly affected. The World Health Organisation 
estimated that one in ten women (11%) has experienced 
cyber harassment or stalking since the age of 1549. A lack 
of clear and consistent definitions as to what constitutes 
gender-based cyber violence however hinders efforts to 
measure or compare its prevalence among and across 
Member States. As a European Parliament’s study noted, 
gender-based cyber violence is not criminalised in most 
Member States. This means law enforcement and justice 
records are not available to estimate the prevalence of 
the issue50. A relative lack of data and research therefore 
makes it challenging to quantify both the prevalence and 
consequences of cyber gender-based violence51. 

44  https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Crime_statistics&stable=0&redirect=no
45  EIGE administrative database, 2016. 
46  FRA (2021) Crime, safety and victims’ rights – Fundamental Rights Survey. Available from: 

https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Crime_statistics&stable=0&redirect=no 

47  FRA (2021) Crime, safety and victims’ rights – Fundamental Rights Survey. Available from: 

https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Crime_statistics&stable=0&redirect=no 

48  Eurofound (2020), Gender equality at work, European Working Conditions Survey 2015 series, Publications Office of the European Union, Luxembourg. 

https://www.eurofound.europa.eu/sites/default/files/ef_publication/field_ef_document/ef19003en.pdf 

49  European Parliament (2021), Combating gender-based violence: cyber violence 

https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662621/EPRS_STU(2021)662621_EN.pdf 
Idem. 

50 
51  European Institute for Gender Equality (2017), Cyber violence against women and girls.  

https://eige.europa.eu/gender-based-violence/cyber-violence-against-women 

15

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?The situation deteriorated during COVID-19. As a re-
sponse to the COVID-19 pandemic, strict lockdown and 
confinement measures were introduced in most EU Member 
States. A large part of personal and professional life moved 
online with people leaving their homes only for essential 
reasons. Public support services (including organisations 
and shelters providing support in cases of violence against 
women and domestic violence) were required to reduce or 
temporarily stop their work. Figures shared by organisations 
active in the field of victim support and by law enforcement 
in April 2020 showed a clear increase of reports of VAW52. 
As the research of UNODC highlighted, the consequences 
of measures against COVID-19 have not, in all cases, led to 
a growing number of reports to relevant support services.53 
It appears that this was often because women’s access to 
such services was controlled by their partners. This included 
the increased use of technology such as webcams, smart 
locks, social media or simply forbidding women to leave 
their homes. 

Data gathered through web scraping for this study comple-
ments these findings (see Figure 1). Using Google trends, 
ICF compared searches for the topic of Domestic Violence 
before and during the pandemic to explore the extent to 
which searches increased or decreased during this period. 
Twenty of the EU 27 countries have experienced an in-
crease in searches since the onset of the pandemic, with 
the largest increase seen in Cyprus and Austria. There was 
no discernible change in Croatia and six member states saw 
a decrease in searches with Lithuania and Latvia seeing 
the largest decrease. 

Website monitoring data from organisations providing sup-
port to victims of domestic violence in seven Member States 
demonstrate a similar trend as they show a steep increase 
in traffic when national restrictions came into effect. 

Figure 1: Google searches for domestic violence and 
related terms

Source: Google Trends. Visualisation: author’s own elaboration.

2.3.  How will the problems evolve?

The legislative and policy framework addressing violence 
against women and domestic violence has been changing 
within the EU but not in a uniform way and varies across 
EU Member States. The existing EU Directives that touch 
upon aspects of violence against women and domestic 
violence provided some impulse for actions at Member State 
level to strengthen the legislative protection and rights of 
victims of violence against women and domestic violence. 

52  See the data presented in ‘Coronavirus and the shadow pandemic of violence against women’ by Rosamund Shreeves, November 2020, published 

by EPRS Blog. 
https://epthinktank.eu/2020/11/24/coronavirus-and-the-shadow-pandemic-of-violence-against-women/

53  UNODC ‘Research brief: What crime and helpline data say about the impact of COVID-19 pandemic on reported violence against women and girls’. 

https://www.unodc.org/documents/data-and-analysis/covid/Violence_against_women_24Nov.pdf

16

What are the main problems and their drivers and consequences?The Victim Rights Directive was the main instrument that 
had a positive impact in this regard. However, most of the 
changes that took place in improving and strengthening 
the protection of women against violence were due to the 
ratification of the Istanbul Convention. 

The signing and ratification of the Istanbul Convention 
changed the legislative and policy landscape in the 21 
EU Member States that did so. It influenced the commit-
ments of the national authorities in acknowledging and 
addressing diverse forms of violence against women and 
domestic violence and thus increased the chances of bet-
ter protecting women against violence. For example, after 
ratification, Austria adopted a new Violence Protection 
Act (2019) and changed its Criminal Code Procedure to 
introduce a better protection to victims. Romania adopted 
a new legislation that changed its law on combating and 
preventing domestic violence to align it with the provi-
sions of Convention; furthermore, it applied for funding 
and expertise support to develop further its legislative 
and policy framework to answer the standards of the 
Convention. Several other EU Member States (DE, ES, FI, 
FR, IT, PL, PT) changed their criminal or penal codes to 
harshen punishments to specific forms of violence or even 
define new ones.54 

The monitoring process put in place by the Istanbul Conven-
tion and carried out regularly by GREVIO offers an incentive 
to make such topics high on the policy agenda and pro-
vides a basis for identifying good practices, recommenda-
tions and knowledge exchanges. The assessments of the 
effects of signing and ratifying the Istanbul Convention 
are positive: effects included legislative changes, increased 
levels of awareness and funding allocation, education pro-
grammes and trainings for professionals, research, and a 
more prominent positioning of the topic in the juridical 
system. Thus, the ratifying Member States are clearly in a 

more progressive position compared to those that did not 
ratify the Convention, to ensure a high level of protection 
to their citizens and residents. The European Parliament 
concluded that ‘Across the EU-27, all countries that have 
ratified the Convention […] have adopted new legislation 
or amended existing laws’.55 It can be concluded that the 
ratification of the Istanbul Convention had an impact at 
legislative and policy level within the Member States, and 
most likely progress will continue in the years to come even 
without further EU action.

Despite these positive trends, progress remains uneven 
in the EU Member States that ratified the Convention. The 
efforts by the 21 ratifying EU Member States to improve 
the existing situation were not constant, uniform, coordi-
nated or sufficiently resourced. For example, as discussed 
above, looking at measures to prevent violence all Member 
States provide some form of training to law enforcement 
and judicial authorities. The need and utility of trainings is 
recognized in all EU Member States for several categories 
of professionals, as trainings have been made available, 
delivered, even made mandatory for certain categories (po-
lice, judges, prosecutors) in some Member States (EE, ES, PT, 
SE). However, trainings are still voluntarily in most Member 
States for several categories of professionals, and are not 
institutionalized, not developed and rarely available to the 
same standards and frequency for all types of categories. 
Many of these trainings are delivered by women’s NGOs, 
and this creates huge pressure and demand on these pro-
fessionals. Another example is the definitions of different 
forms of violence against women and domestic violence. 
Few EU Member States introduced a gender-based defini-
tion of domestic violence and include all forms of violence 
described by the Istanbul Convention. Progress has been 
happening in this area and there is movement towards a 
uniform legal definition of domestic violence with recogni-
tion that it affects women disproportionately and includes 

54  European Parliament (2020) ‘Tackling violence against women and domestic violence in Europe – The added value of the Istanbul Convention and 

remaining challenges’, pp. 34-38. https://www.europarl.europa.eu/thinktank/en/document/IPOL_STU(2020)658648

55  European Parliament (2020) ‘Tackling violence against women and domestic violence in Europe – The added value of the Istanbul Convention and 

remaining challenges’. https://www.europarl.europa.eu/thinktank/en/document/IPOL_STU(2020)658648

17

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?all forms of violence (physical, psychological, economical, 
verbal, etc), but again progress is slow and uneven. Without 
further EU action, a minimum level of protection for victims 
in the EU will not be ensured. 

Additionally, new EU-wide and world-wide forms of vio-
lence against women are emerging (e.g. online violence 
against women) or increasing in their prevalence as women 
are more present in the labour market and hold more 
decision-making positions in business and politics (e.g. 
gender-based work harassment and hate speech). These 
new forms of violence, and old forms of violence against 
women now perpetuated and amplified through electronic 
means, are not explicitly addressed by the Istanbul Con-
vention nor by other EU regulations. Without further action 
at EU level, this provides space for violations of funda-
mental rights (e.g. political representation, free speech, 
democratic participation) and protection of victims of these 
new forms of violence will remain low even in countries 
that have ratified the Istanbul Convention. Furthermore, 
online violence is increasingly prevalent at Member State 
level and young people are more likely to be exposed to 
it, however addressing it requires complex thinking and 
trans-national – or EU wide – solutions. Addressing such 
complex issues, which are likely to develop and become 
more complex, requires cooperation and a specific legal 
instrument. 

violence have limited impact and do not cover the existing 
gaps. Therefore, action at the EU level would strengthen 
and intensify the legislative and policy changes in these 
EU Member States, bringing them closer to the others, and 
might even push forward the demands for ratification of 
the Istanbul Convention. 

In other three EU Member States (BG, HU, SK) ratification 
of the Istanbul Convention has been rejected by constitu-
tional courts (BG), governments or parliaments (HU, SK). 
Furthermore, social movements against the ratification of 
the Convention have mounted in these countries and have 
spread misinformation about the meaning and application 
of several concepts or terms defined by the Convention (e.g. 
gender, gender equality). For these EU Member States, EU 
inaction would most likely worsen the level of protection 
against for victims. Besides the lack of services, funding, 
research, and analysis on violence against women and do-
mestic violence, legislation in these EU Member States ad-
dresses violence mostly in the so called ‘domestic setting’, 
within a restrained definition of what constitutes ‘family’ 
and places little or no emphasis on existing gender inequali-
ties that perpetuate violence against women. There are 
few or almost no discussions about emerging new forms 
of violence against women – particularly those promoted 
or carried out through electronic means or online – and no 
inclusion of gender-based work harassment. 

In comparison, the EU Member States that did not ratify 
the Istanbul Convention have a lower level of protection for 
victims of violence against women and domestic violence 
and the comprehensiveness of policy and services varies. In 
some of these EU Member States the debate about ratifica-
tion is on-going. This is the case in particular of Czechia, 
Latvia and Lithuania. Ratification would have a significant 
impact on the legislative and policy framework of violence 
against women and domestic violence in these Member 
States. The research carried out for this study shows that in 
these EU Member States, legislation, services, and funding 
stand short when compared to the standards set by the 
Istanbul Convention. Current EU legislation that address 
some aspects of violence against women and domestic 

Furthermore, without strong action at the EU level, the 
gains so difficultly reached for women’s protection against 
violence might be lost or even reversed. In the current con-
servative political environment developed and manifested 
in several EU Member States, there is even a threat of 
withdrawal from the Istanbul Convention. The striking ex-
ample of Turkey’s (not an EU Member State, but a state 
party within the Council of Europe) withdrawal from the 
Convention, despite protests from the local civil society and 
international fora, has been picked up by representatives 
of these conservative forces. 

In conclusion, the different ways and levels of protection 
against forms of violence ensured to women living in EU 

18

What are the main problems and their drivers and consequences?Member States depend on their citizenship and residency 
situation. This means that women facing and confronting 
different forms of violence do not have their rights ensured 
to the same level across the EU. Thus, the EU as a whole 
is placed in a position of not fulfilling its responsibilities 
towards the protection of its citizens uniformly and equally. 
The lack of action on the side of the EU is most likely to 
perpetuate the existing situation and even increase the 
discrepancies among its Member States when it comes 
to protection of women against violence; it would not ad-
dress violations of fundamental rights that can take place 
in its Member States and would not be able to protect 
women against offences not covered in the Istanbul Pro-
tection across the EU (online violence against women and 
harassment in workplace). 

Violence against women and domestic violence in all its 
diverse forms will not be diminished, and it might even 
increase, particularly certain forms and those amplified 
and perpetuated by technology (online violence against 
women). At the same time, societies evolve and knowledge 
spreads quickly, thus awareness and knowledge about 
violence against women and domestic violence might in-
crease and reporting could rise, as evidenced in the recent 
#metoo movement. Without action and coordination at EU 
level, Member States will not be able to develop a com-
prehensive understanding of the scale of the problems, of 
the nuances that the new complexities bring and support 
each other in addressing them. A lack of action would 
perpetuate the existing gaps and even deepen them as 
no common definitions and methodologies Policy Objec-
tives and Options

2.4.  Objectives: what is to be achieved? 

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

The specific objectives are: 

 

 

 

 

 

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

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

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

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

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

2.5.  What are the available policy options? 

Three policy options have been developed to address EU-
wide issues in relation to violence against women and do-
mestic violence. Table 1 outlines the measures for each 
policy option and how they link to the problem area. 

19

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?Table 1: Summary of options considered in addition to the baseline

Problem 
area

Option 1 – Moderate 
measures

1.1 Obligation on MS to 
provide targeted informa-
tion to and raise aware-
ness of the general public.

1.2 Obligation on MS to 
have perpetrator pro-
grammes in place.

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

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

Sub-option 2A
1.1A Obligation on MS to provide targeted 
information to and raise the awareness of 
groups at risk.

Sub-option 2B
Same as 2A

1.2A Obligation on MS to make available 
voluntary perpetrator programmes to all 
those at risk of offending and mandatory 
programmes for re-offenders.

1.3A Obligation on MS to provide - spe-
cialised, regular and mandatory training to 
professionals likely to come into contact 
with victims; and - mandatory training to 
managers on sexual harassment at work 
and the effects of domestic violence on the 
workplace.

1.4A Obligation on MS to ensure that 
sexual harassment at work is addressed in 
national policies. Obligation on MS to en-
sure that company risk assessments cover 
sexual harassment at work.

1.2B Obligation on MS to 
make available voluntary 
perpetrator programmes to 
all those at risk of offending 
and mandatory programmes 
for all offenders.

Same as 2A

Same as 2A

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

2.1A Obligation on MS to ensure efficiency 
through minimum standards on the issu-
ance, conditions and enforcement of emer-
gency barring orders and protection orders.

Same as 2A

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

2.3 Obligation to provide 
age-appropriate psycho-
social counselling to child 
victims and witnesses of 
domestic violence

2.2A Obligation on MS to conduct risk as-
sessments speedily and in cooperation with 
support services. 

Same as 2A

2.3A Obligation on MS to ensure the 
protection of children by providing for 
surveyed safe places for visits in case of 
allegations of domestic violence.

Same as 2A

1

2

20

What are the main problems and their drivers and consequences?Problem 
area

Option 1 – Moderate 
measures

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

3.1 Obligation on MS to 
encourage reporting of 
violence by third parties

Sub-option 2A
3.1A Obligation on MS to ensure easy and 
accessible reporting, including child friendly 
reporting mechanisms and online reporting.

3.2A EU-level criminalisations:
Additional approximation of criminal 
definitions and sanctions on the basis of 
the legal bases of computer crime (ICT-
facilitated cyber violence), sexual exploita-
tion (certain forms of sexual violence), and 
serious forms of sexual harassment.

3.3A Right of victims to obtain full com-
pensation from the perpetrator in one 
single procedure and within adequate time 
limits.

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

4.1A Obligation on MS to facilitate access 
to specialised support services to groups at 
risk, such as children, migrant and asylum 
seeking women and women with disabili-
ties. Connect national helplines to EU-level 
helpline

Sub-option 2B
Same as 2A

3.2B EU level criminalisations:
Introduction of violence 
against women and domestic 
violence as a new EU crime.

3.3B Obligation on MS to 
provide state compensation 
in cases where victims cannot 
obtain compensation from the 
perpetrator or other sources. 

4.1B Obligation on MS to 
provide 1 shelter space for 
10,000 inhabitants.

4.2A Obligation on MS to provide specific 
support to victims of sexual harassment at 
work (including medical care and complaint 
mechanisms).

4.2B obligation on MS special 
compensated leave for work-
ers victim of violence against 
women or domestic violence.

4.3A Obligation on MS to establish both 
on- and offline support for victims of cyber 
violence against women. 

Same as 2A

5.1 Measures strengthen-
ing multi-agency coopera-
tion.

5.1A Obligation to provide one-stop online 
access to relevant protection and support 
services. Encouragement to locate support 
services in the same premises.

5.1B Obligation on MS to 
locate multi-agency support 
services for victims in the 
same premises. 

5.2 Voluntary participation 
in surveys coordinated at 
EU-level.

5.3 Obligation to regularly 
collect disaggregated rel-
evant administrative data.

5.2A Obligatory participation in surveys 
coordinated at EU-level

Same as 2A

5.3A Data collection: 
Obligation to regularly collect disaggre-
gated relevant administrative data in line 
with a number of harmonised minimum 
requirements.

5.3B Data collection:
Integrated centralised data 
collection system at national 
level.

3

4

5

21

What are the main problems and their drivers and consequences?What are the main problems and their drivers and consequences?3.  What are the impacts of the policy options?

This section assesses the impacts of the policy options 
described in the previous section against the policy objec-
tives. A full assessment of each measure is available in An-
nex 5. Each policy option is cumulative, therefore only new 
measures in each Option are assessed, to avoid repetition. 

3.1.  Policy option 0: Baseline

In Policy Option 0 – Baseline, at the EU level, the European 
Commission (EC) would continue to support the EU’s ac-
cession to the Istanbul Convention and to work with those 
Member States that have not yet ratified the Convention. 
Given the current political situation in the Member States, 
the ratification of the Istanbul Convention is unlikely in 
all 27 Member States in the foreseeable future. The EC 
would continue to implement the non-legislative measures 
of the EU Gender Equality Strategy on ending gender-based 
violence: through launching an EU network on preventing 
gender-based violence and domestic violence, and providing 
funding for training, capacity-building and support services. 
It would also issue a Recommendation on the prevention of 
harmful practices against women and establish a network 
on the prevention of violence against women. The Victims’ 
Rights Directive would remain the generally applicable di-
rective that would also apply to violence against women 
and domestic violence in addition to all other intentional 
crime as criminalised at the national level. The Commission 
would implement the actions outlined in the EU Strategy 
on victims’ rights on empowering victims of gender-based 
violence. 

training to prevent and combat such forms of violence 
against women.

To protect women’s safety online, the EC would facilitate 
the development of a framework for cooperation between 
online platforms and stakeholders, including national au-
thorities. Further action on online violence against women 
would focus on self-regulatory actions undertaken on a 
voluntary basis. 

Taking into account how the COVID pandemic has high-
lighted and increased violence against women and domestic 
violence in the Member States, the slow progress towards 
the EU objectives in this field can be expected to have been 
hampered further. The economic costs of fighting violence 
against women and domestic violence are likely to continue 
to grow after the pandemic, and measures in this field are 
likely to remain insufficient in a manner that cannot be 
mitigated by policies to relaunch the economy. 

3.2.  Policy option 1: Moderate

The first policy option offers set of measures leading to a 
moderate reduction in violence against women and domes-
tic violence. A full assessment of the measures is avail-
able in Annex 5. Policy option 1 includes and builds on the 
measures of the baseline.

3.2.1.  Effectiveness: contributing to achieving the 
policy objectives

In relation to gender-based work harassment, the EC would 
encourage Member States to continue to implement the 
existing EU rules and raise awareness about them, to work 
closely with employers and those responsible for vocational 

Three measures specifically contribute to the policy ob-
jective on prevention (1.1-1.3). They will help to change 
attitudes and embedded gender norms that cause and 
facilitate violence against women and domestic violence 

22

What are the impacts of the policy options?among the general public and will facilitate training of 
professionals likely to come into contact with victims and 
managers in workplace settings. Similarly, perpetrator 
programmes will help challenge the views of those most 
likely to commit violence against women and domestic 
violence in the future. The effectiveness of the measures 
will however be limited as Member States will only be 
obligated to have the trainings and programmes in place 
and not mandatory uptake. 

Three measures (2.1- 2.3) relate directly to the objective 
to protect victims from (further) violence. The measures 
relate to the availability of protection orders and risk as-
sessments which can both provide important protection for 
victims, however both measures are very close to the baseline 
and do not address current challenges around awareness 
and implementation, including enforcement. Similarly, the 
measure to provide psychosocial counselling to child victims 
and witnesses of domestic violence is more explicit than the 
Victims’ Rights Directive but does not address other protection 
risks for children such as safe places for visitations. 

There is one measure directly related to ensuring effec-
tive access to justice for victims of violence against 
women and domestic violence in this Option (3.1). Ac-
cess to justice for victims is key in ensuring the victims’ 
fundamental rights and deterring perpetrators and thus 
preventing further crime. An important study in the US 
showed a significant reduction in repeat domestic violence 
after an initial arrest56. Measure 3.1 is an obligation on MS 
to encourage reporting of violence by third parties. As this 
obligation is in place under the Istanbul Convention, this 
measure could have more impact on countries who have 
not ratified it (BG, CZ, LV, LT, SK) although as it is very 
similar to the baseline, and there are no clear guidance/
instruction on how to encourage third party reporting, the 
overall impact is expected to be limited.

Similarly, there is one additional measure (4.1), in relation to 
the baseline, regarding support for victims. A wide-reaching 
measure obliges Member States to ensure access to specialist 
support including rape crisis centres, shelters and helplines. 
This will be effective in helping to address overarching the 
gaps in provision. For example, the NGO WAVE demonstrated 
that only three Member States (LU, MT, SL) fulfil the request-
ed number of specialised women’s shelters per 10,000 of 
population recommended by the Council of Europe57 Violence 
against women and domestic violence is however a highly 
complex issue, with many different groups of victims and 
forms of violence and there is a high risk that certain sup-
port needs will not be met, such as victims of online violence 
against women and domestic violence. 

Three measures aim to improve coordination in prevent-
ing and combating violence against women and domestic 
violence (5.1-5.3). Such measures will help facilitate refer-
rals of victims between different sectors helping victims 
to more effectively access the support and protection they 
need. However, coordination and easy access for victims 
may be hindered without it being required that all services 
are on the same premises or available online. Two measures 
relate to improving governance through data collection as 
it facilitates planning, monitoring and evaluation of exist-
ing measures. However, both measures are very similar to 
the baseline and do not address the incomparability of a 
data or oblige Member States to participate in surveys, of 
whom nine have recently demonstrated their unwilling to 
participate in such surveys. 

3.2.2.  Effectiveness – other impacts

3.2.2.1.  Social impacts

The following social impacts are expected, by stakeholder 
group:

56  C. Maxwell, J. Garner, & J. Fagan, The effects of arrest on intimate partner violence: New evidence from the spouse assault replication program. 

Washington, DC: National Institute of Justice, 2001

57  WAVE (2019) Wave Country Report 2019. https://www.wave-network.org/2019/12/30/wave-country-report-2019.

23

What are the impacts of the policy options?What are the impacts of the policy options?Victims of violence against women and domestic vio-
lence: Victims of violence against women and domestic 
violence are expected to benefit from all measures under 
this policy option. Victims will benefit directly from increased 
access to specialist support services and protection orders. 

Particular groups of victims: Under this option, Meas-
ure 2.3 offers particular support and protection for child 
victims and witnesses. Moreover, Measure 1.3 includes 
training for managers thus helping to prevent women 
from violence against women at work. Although there will 
be a provision to ensure implementation without discrimi-
nation on any ground, without more specific measures, 
there is a risk measures will not be inclusive of victims at 
heightened risk of violence and those who may be more 
difficult to reach. 

Perpetrators of violence against women and domestic 
violence: One measure (1.2) specifically focuses on inter-
vention and treatment programmes for perpetrators, whilst 
another two other measures could include this group as 
members of the public (1.1) and professionals (1.3). These 
measures will help change the behaviour and attitudes of 
perpetrators although as the measures are not mandatory, 
uptake may be low. 

Wider society: Measure 1.1 directly targets wider society 
and aims to change negative gender stereotypes and in-
crease understanding of how to combat and prevent vio-
lence against women and domestic violence. 

National authorities: National authorities are overall very 
likely to consider the policy option as politically acceptable 
as it is reasonably close to the baseline, although those 
that have not ratified the Istanbul Convention may be more 
reluctant and concerned about the cost implications, and 
acceptance may be lower where there is currently resistance 
to the concept of ‘gender’ such as in Hungary and Poland. 

3.2.2.2.  Fundamental rights

The policy option is expected to have a positive impact on 
the following fundamental rights in the Charter on Funda-
mental Rights (CFR):

Right to life (Article 2, CFR), Right to the integrity 
of the person (Article 3, CFR), Prohibition of torture 
and inhuman or degrading treatment (Article 4, CFR), 
Respect for private and family life (Article 7, CFR): 
As violence against women and domestic violence often 
involves physical violence, including femicide, all measures 
will help ensure these rights either directly or indirectly. 
Protection measures (2.1, 2.2 and 2.3) in particular will 
have positive impacts on these rights as they directly aim 
to protect victims from further violence. In E.B. v. Roma-
nia (no. 49089/10)58, for example, the Court expressed the 
opinion that in failing to adequately respond to the ap-
plicant’s allegations of rape and to adequately respect her 
rights as a victim, the respondent State had failed to meet 
its positive obligations to effectively apply a criminal-law 
system punishing all forms of rape and sexual abuse and to 
adequately protect the applicant’s physical integrity, which 
constituted a violation of Articles 3 and 8 ECHR. Moreover, 
the provision of specialist support services including shelters 
(4.1) would likely help women at risk of further violence 
and those whose lives are potentially in danger in their own 
home, to feel able to leave and find safe accommodation.

Non-discrimination (Article 21, CFR) and Equality be-
tween women and men (Article 23, CFR): all measures 
will help contribute to the non-discrimination and equality 
between women and men as violence against women and 
domestic violence is a form of gender discrimination that 
perpetuates inequality. 

Rights of the elderly (Article 25, CFR): Although no 
measures particularly target the elderly, it is possible the 

58  CASE OF E.B. v. ROMANIA. (Application no. 49089/10). JUDGMENT. STRASBOURG. 19 March 2019. http://hudoc.echr.coe.int/app/conversion/

docx/?library=ECHR&id=001-191749&filename=CASE%20OF%20E.B.%20v.%20ROMANIA.docx&logEvent=False

24

What are the impacts of the policy options?rights of the elderly could be better ensured through the 
range of measures for victims of in particular domestic 
violence. However, without targeted measures it is likely 
the impact would be limited. 

Right to fair and just working conditions (Article 31, 
CFR): This right will be reinforced somewhat by one meas-
ure that obliges training of managers regarding harassment 
at work (1.3).

Integration of persons with disabilities (Article 26, 
CFR): the same considerations as for the elderly above 
would apply.

Rights of the child (Article 24 of Charter, CFR): the 
measure concerning psycho-social counselling for child victims 
and witnesses (2.3) will likely benefit children’s rights as they 
would ensure that children’s safety and wellbeing is prioritised.

Rights to social assistance and health care (Article 34 
and 35, CFR): The support measures (4.1) included in this 
policy option will help meet these rights, particularly rape 
crisis centres which help victims access specialist medical 
assistance they may require. 

The right to an effective remedy and to a fair trial 
(Article 47, CFR) Measure 3.1 is targeted at improving 
reporting by third parties, which is a crucial first step in 
facilitating affect to effective remedy and a fair trial, as 
underreporting is a major challenge (see problem definition). 

3.2.3.  Efficiency: comparison of benefits and costs 

3.2.3.1.  Administrative and compliance costs

This section summarises the administrative and compliance 
costs for each measure in policy option 1 that is assumed to 
incur additional costs compared to the baseline. The costs 
are outlined in Table 2. The assumptions used to develop 
the costings and details about who will bear the costs are 
outlined in Annex 4. 

Table 2: Overview of administrative and compliance costs – Option 1

Policy 
objective

Description of measure

One-off development 
cost (Millions of euros)

Running cost per annum 
(Millions of euros)

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

1.2: Obligation on MS to have perpetrator 
programmes in place.

1.3: Obligation on MS to provide specialised 
training and targeted information to profes-
sionals likely to come into contact with 
victims and managers. 

n
o
i
t
n
e
v
e
r
P

0 

0 

 0.6

1.7 – 4.0

0.04 

 18.4

TOTAL

0.6 

20.1 – 22.4

25

What are the impacts of the policy options?What are the impacts of the policy options?Policy 
objective

Description of measure

One-off development 
cost (Millions of euros)

Running cost per annum 
(Millions of euros)

n
o
i
t
c
e
t
o
r
P

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

2.2: Obligation on MS to conduct risk as-
sessments on the seriousness of the threat 
of violence to victims.

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

TOTAL

o
t

s
s
e
c
c
A

c
i
t
s
u
j

e 3.1: Obligation on MS to encourage report-

ing of violence by third parties.

TOTAL

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

0

0

0

0

0

0

3.4 – 22.9

43.3

598.9 – 1,618.2

645.5 – 1,684.4

0

0

13.6

127.9 – 491.4 

TOTAL

13.6

127.9 – 491.4 

5.1: Measures strengthening multi-agency 
cooperation.

5.2: Voluntary participation in surveys coor-
dinated at EU-level.

5.3: Obligation to regularly collect disaggre-
gated relevant administrative data.

TOTAL

TOTAL ALL AREAS

0

0

0

0

0

0

0

0

14.2

793.6 – 2,198.1

t
r
o
p
p
u
s
m

i
t
c
i
V

n
o
i
t
a
n
i
d
r
o
o
C

26

What are the impacts of the policy options? 
 
 
3.2.3.2.  Economic impacts

The expected impact of this policy option is mainly due to 
the economic benefits generated due to a decrease in the 
prevalence of gender-based violence. 

The economic impact is assessed based on a cost estimation 
of gender-based violence against women in the EU produced 
by EIGE using 2019 data. To quantify the economic impact, 
assumptions are needed on the percentage of reduction in 
costs due to the implementation of this policy option. Due 
to lack of evidence quantifying the causal link between the 
full set of measures under this policy option, two scenarios 
are tested in Table 3.

The two scenarios build on the European Parliament’s as-
sessment of the added value of Gender-based violence as 
a new area of crime listed in Article 83(1) TFEU59. The as-
sessment assumed that the prevalence of violence against 
women and domestic violence will decrease by 15% in the 
short-term (about five years) and 20% in the long-term (10 
years and more) after an EU–wide legislation is introduced. 
The short-term assumption is based on estimated impact60 
of the introduction of the US Violence Against Women Act of 
1994 on annual rates of criminal victimisation of women. 
The long-term assumption is based on an assessment of 
two studies:

—   Analysis based on DHS data for selected countries in the 
global south finds that an additional year of legislation 

criminalising DV61 is correlated with a 2% decrease in 
prevalence. 

—   Analysis based on Fundamental Rights Agency data for 
2014 finds that women living in EU Member States that 
passed a law on gender-based violence before 2005 
had a 40% lower probability of victimisation compared 
to women living in EU Member States that passed laws 
more recently62.

To estimate the potential economic benefits of the combina-
tion of measures included in this policy option, the following 
assumptions are made:

•   The costs estimated in EIGE’s forthcoming study repre-
sents the overall cost of gender-based violence against 
women in the baseline. 

•   The subsequent decrease in costs is proportionate to the 
decrease in prevalence of gender-based violence under 
each scenario.

•   For the criminal and civil justice system, there are coun-
teracting economic impacts of an increase in costs due 
to increased reporting (assumed increase of 7.5%) of 
violence against women and domestic violence and a 
decrease in costs due to the reduction in prevalence. The 
assumed change is therefore a lower proportion com-
pared to the other cost categories. 

59  European Parliament (2021) Gender-based violence as a new area of crime listed in Article 83(1) TFEU: Added value assessment. Available from: 

https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662640/EPRS_STU(2021)662640_EN.pdf 

60  Clark, K. A., Biddle, A. K., & Martin, S. L. (2002), ‘A cost-benefit analysis of the Violence Against Women Act of 1994’, Violence Against Women, 8(4), 

pp. 417-428. 

61  Klugman et al, Voice and Agency: Empowering Women and Girls for Shared Prosperity, The World Bank, 2014
62  Sanz-Barbero B., Corradi C., Otero-García L., Ayala A., and Vives-Cases C., ‘The effect of macrosocial policies on violence against women: a multilevel 

study in 28 European countries’, International journal of public health, 63(8), 2018, pp. 901- 911.

27

What are the impacts of the policy options?What are the impacts of the policy options?Table 3: Estimated economic benefits of prevention, protection, access to justice and victim support measures in the 
EU under Policy Option 1

Cost category

Estimated 
EU-27 cost of 
GBV63

Scenario 1: 
prevalence reduced by 15%

Scenario 2: prevalence reduced 
by 20%

% change in 
costs

Estimated 
reduction in 
costs/ economic 
benefits

% change in 
costs

Estimated 
reduction in 
costs/ economic 
benefits

Lost economic output

€40.5 billion

Health services

Criminal justice 
system

€12.5 billion

€59.7 billion

- 9%

Civil justice system

€1.6 billion

Social welfare

Personal costs

Specialist services

Physical/emo-tional 
impacts

€10.3 billion

€3.2 billion

€1.0 billion

- 15%

- 15%

- 9%

- 15%

- 15%

- 15%

€6.1 billion

€1.9 billion

€5.1 billion

€0.1 billion

€1.5 billion

€0.5 billion

€0.2 billion

- 20%

- 20%

- 12%

- 12%

- 20%

- 20%

- 20%

- 20%

€8.1 billion

€2.5 billion

€7.2 billion

€0.2 billion

€2.1 billion

€0.6 billion

€0.2 billion

€32.2 billion

€161.2 billion

- 15%

€24.2 billion

Total

€290 billion

€39.6 billion

€53.1 billion

The estimated total economic benefits of policy option 
1 range between a cost reduction of 39.6 billion to 
53.1 billion Euros.

3.2.4.  Coherence

The policy option will improve internal coherence by ad-
dressing the fragmented nature of the relevant EU legal 
framework, which includes 14 separate EU legal instru-
ments. It will also address the lack of systematic and fo-
cussed measures related to violence against women and 
domestic violence. It is internally coherent with existing 
EU legislation, particularly the Victim Rights’ Directive, as 
it ensures existing provisions meet the particular needs of 
victims of violence against women and domestic violence. 

As regards external coherence, the policy option will first 
and foremost address the emerging fragmentation created 
as 21 Member States are party to the Istanbul Convention 
and six are not, and all of them adopt different measures on 
violence against women and domestic violence. Inconsisten-
cies with other international instruments, such as the ILO 
Violence and Harassment Convention no 190 will also be 
improved to a limited extent, as the policy option includes 
one measure addressing harassment at work specifically 
(1.3). Similarly, greater coherence with the Convention on 
the Rights of the Child will be ensured by adding a measure 
to improve support and protection of child witnesses and 
victims (2.3). 

63  Estimation of the costs of gender-based violence in the UK case study and extrapolation to EU Member States (forthcoming EIGE paper, 2021).

28

What are the impacts of the policy options?3.2.5.  Overall assessment

Policy option 1 is expected to have a good overall positive 
impact, by putting into place a single EU legislative instru-
ment specifically focussed on violence against women and 
domestic violence. This also means that, whilst several of 
the measures included in this option already exist as part 
of the baseline, these will still have a positive impact due 
to their specific focus and coverage. A specific piece of leg-
islation in this area can be expected to have a significant 
impact on prevalence: In the US, for example, the Violence 
Against Women Act (which included prevention, prosecution 
and protection) was passed in 1994, and has been noted 
by several studies to have resulted in a significant decline 
in acts of violence against women64. The impact may take 
some time to appear but in the long-run the impact will be 
a significant: a study pointed out that women living in EU 
Member States that had, prior to 2005, passed a law to fight 
violence against women, have a 40% lower probability of 
being victims of violence if compared to women living in 
Member States that passed the law more recently65. Similarly, 
a World Bank study showed that each additional year that 
a country has had domestic violence legislation in place is 
associated with a reduced prevalence of about two per cent66.

Whilst the positive impacts of this policy option are mostly 
expected in those six Member States that currently have 
not ratified the Istanbul Convention, it will also impact on 
Member States which did ratify it, but which have not fully 
implemented the Convention or the relevant EU acquis such 
as the Victims’ Rights Directive. 

However, even in those Member States which already 
have most of the measures put forward in this policy op-
tion in place, having them combined in a coherent and 

comprehensive legal framework is expected to have a mul-
tiplier effect, and contribute to a consistent and harmonised 
implementation across the EU. 

Member States’ political acceptance is expected to be over-
all very high, especially given that the majority have rati-
fied the Istanbul Convention and transposed the relevant 
EU legislative framework. However, the current resistance 
in some countries towards policies about gender (instead 
of sex) may make some reluctant to accept some of the 
measures included. 

Whereas overall the policy option is assessed as positive, it 
does not fully address the problems identified, particularly 
regarding access to justice, as there is only one measure that 
is very similar to the baseline. Similarly, measures related to 
data collection and protection are also close to the baseline 
and without mandatory training, uptake of this measure may 
be limited A lack of targeted measures to different groups 
of victims of violence against women and domestic violence 
also restricts the ability of the measures to effectively meet 
the needs and fundamental rights of all victims. 

3.3.  Policy option 2a: Comprehensive

The second policy option would offer a comprehensive set 
of measures leading to a significant reduction in violence 
against women and domestic violence. A full assessment 
of the measures is available in Annex 5. 

3.3.1.  Effectiveness: contributing to achieving the 
policy objectives

Four measures specifically contribute to the specific objec-
tive on prevention (1.1-1.4A). They will help to change 

64  K. A. Clark, A. K. Biddle, & S. L. Martin, ‘A cost-benefit analysis of the Violence Against Women Act of 1994’, Violence Against Women, 8(4), 2002, 

pp. 417-428. Female Victims of Violence (unl.edu) (Bureau of Justice Statistics), cited in M. N. Modi, S. Palmer, & A. Armstrong, ‘The role of Violence 
Against Women Act in addressing intimate partner violence: A public health issue’, Journal of Women’s health, 23(3), 2014, pp. 253-259.

65  B. Sanz-Barbero, C. Corradi, L. Otero-García, A. Ayala, and C. Vives-Cases, ‘The effect of macrosocial policies on violence against women: a multilevel 

study in 28 European countries’, International journal of public health, 63(8), 2018, pp. 901- 911.

66  Glugman et al, Voice and Agency: Empowering Women and Girls for Shared Prosperity, The World Bank, 2014.

29

What are the impacts of the policy options?What are the impacts of the policy options?attitudes and embedded gender norms that cause and facil-
itate violence against women and domestic violence among 
the general public and will facilitate training of professionals 
likely to come into contact with victims and managers in 
workplace settings. Similarly, perpetrator programmes will 
help challenge the views of those most likely to commit 
violence against women and domestic violence in the future. 
The measures will be particularly effective compared to the 
baseline because of the targeted and mandatory nature of 
the measures: information will be targeted at groups at risk, 
thus reaching those who need information most (1.1A) and 
national policies and company risk assessments will cover 
sexual harassment at work (1.4A). Current progress in this 
area is very varied, with only some unions mainstreaming 
violence against women in occupational safety and health 
measures67. Perpetrator programmes will also be manda-
tory for all re-offenders which is currently only the case in 
seven Member States (BE, CZ, ES, LV, PL, PT, FR for those 
in prison, and HR as part of probation service)68 and train-
ing for managers on sexual harassment and the effects 
of domestic violence will be mandatory, which is similarly 
not widely the case. This means this measure could have 
a significant impact on prevention. However, the measure 
does not include first-time offenders, potentially allowing 
reoffending before preventative measures are implemented.

Three measures (2.1A - 2.3A) are expected to have a posi-
tive impact on ensuring that victims of violence against 
women and domestic violence are better protected from 
violence. These measures mark a significant increase in 
the effectiveness of the delivery of protection measures 
compared to the baseline through ensuring that risk as-
sessments are issued speedily and establishing minimum 
standards on the issuing of protection orders. This addresses 
the problem that, although these measures are available in 

Member States, they are implemented in ways that leave 
many victims at risk of further violence. Measure 2.3A also 
places an obligation on Member States to ensure the protec-
tion of children by providing for surveyed safe places for 
visits in case of allegations of DV. Supervised visitations 
in safe places are ways for parents of a child to maintain 
contact but in an environment that is safe for the child and 
ensures the location of the child is not identifiable by the 
perpetrator. This measure would have a particular impact 
on countries that have not ratified the Istanbul Convention. 

Three measures contribute to the policy objective on re-
garding access to justice (3.1A- 3.3A). Measure 3.1A is a 
general obligation to make all reporting easy and accessible, 
including through online reporting and tailored provisions for 
children. This will help address barriers that currently result 
in low reporting rates. Measure 3.2A provides additional 
approximation of criminal definitions and sanctions on the 
basis of the legal bases of computer crime (ICT-facilitated 
cyber violence), sexual exploitation (certain forms of sexual 
violence), and serious forms of sexual harassment. This 
measure would have the most significant impact on combat-
ting online violence as current definitions are not uniform: 
no countries, except Romania, have a specific definition of 
online violence in law69. Although the measure does not 
cover all forms of violence against women and domestic 
violence, most forms are already criminalised at national 
level, with the possible exception of psychological violence 
and lack of recognition of the gender-dynamics in these 
forms of violence (see mapping in Annex 5). 

Furthermore, Measure 3.3A gives the right to victims to 
obtain full compensation from the perpetrator in one single 
procedure and within adequate time limits. Currently, victims 
of crime can claim compensation from the perpetrator in 

67  ETUC (2017) ‘Safe at home, safe at work: trade union strategy to prevent, manage and eliminate work-place harassment and violence against’. P.23 

https://www.etuc.org/sites/default/files/document/files/en_-_brochure_-_safe_at_home_1.pdf and social partner workshop (see Annex 2). 

68  Targeted Consultation with Member State authorities q. 29. No response: PL, HR, LT
69  European Commission, European Equality Law Network, (2021) ‘Criminalisation of gender-based violence against women in European 

States, including ICT-facilitated violence’, Luxembourg, Publications of the European Union, p.9. Available from: https://www.equalitylaw.eu/
downloads/5535-criminalisation-of-gender-based-violence-against-women-in-european-states-including-ict-facilitated-violence-1-97-mb

30

What are the impacts of the policy options?all Member States. However, the time taken to receive com-
pensation is widely seen as ‘long and difficult’70. The process 
of accessing compensation in a single procedure process 
may also have positive impacts on victims as judges are 
not obligated to decide on victims’ compensation claims in 
criminal proceedings so a criminal case can be followed by 
a civil case for compensation71. This measure however will 
be limited in its impact because it does not ensure access 
to state compensation if the perpetrator is unable to pay. 
Moreover, the measure does not ensure a sufficient level 
of compensation: the amount of compensation attributed 
in gender-based violence cases is often very low.

The policy option envisages three measures (4.1A - 4.3A) 
dedicated to enhancing victim support. This set of meas-
ures takes an inclusive approach and recognises the diverse 
experiences and needs of different groups who are victims 
of violence against women and domestic violence. Measure 
4.1A will ensure that groups at risk, such as children, migrant 
and asylum-seeking women and women with disabilities have 
access to specialist support services. Measure 4.2A will oblige 
Member States to ensure that medical care is available to all 
victims of work-based harassment and Measure 4.3A offers 
specific provisions for victims of cyber VAW, a new and grow-
ing area of VAW. This will address the barriers that women 
living with a disability and migrant women face accessing 
service and lack of services tailored to online violence.

Under the area of coordination, this policy option proposes 
three measures. Measure 5.1A is an obligation on Member 
States to provide one-stop online access to relevant protec-
tion and support services, with encouragement to locate 
support services in the same premises. This would help 
ensure services work together better and are more acces-
sible to victims as they are together in one place, as often 
victims are not aware of all services available to them. 
Online services will increase access for victims who fear 

the visibility of offline services because of the threat from 
their perpetrator. Two measures improve the availability 
of comparable data across the EU. Measure 5.2A makes 
making participation in surveys coordinated at EU level 
obligatory which will the ensure in the inclusion of nine 
member states who have opted out of the upcoming FRA 
survey on violence against women and domestic violence. 
Similarly, Measure 5.3A makes relevant administrative data 
be collected ‘in line with a number of harmonised minimum 
requirements’ which is not widely practiced currently. 

3.3.2.  Effectiveness – other impacts

3.3.2.1.  Social impacts

The following social impacts are expected, by stakeholder 
group:

Victims of violence against women and domestic vio-
lence: Victims of violence against women and domestic 
violence are expected to benefit from all measures under 
this policy option. Victims will benefit directly from increased 
efficiency of protection orders and claims for compensation. 

Particular groups of victims: Particular groups are ex-
pected to strongly benefit from this policy option as there 
are suitably tailored measures regarding support, protec-
tion and access to justice for victims at heightened risk 
of violence such as children, migrant and asylum-seeking 
women and women living with a disability, victims of sexual 
harassment at work and online violence. 

Perpetrators of violence against women and domestic 
violence: This policy option includes intervention and treat-
ment programmes for perpetrators and takes the important 
step of making participation in such programmes mandatory 
for re-offenders to ensure take-up. 

70  Public consultation q.19. The question asked respondents to hypothetically describe the process of pursuing compensation, should they be 

entitled, to which the overwhelming majority (84%) described as difficult and long. See also Annex 2. 

71  Victim Support Europe (2019) ‘Victims of Crime Implementation Analysis of Rights in Europe: Synthesis report’, p.121. https://victimsupport.eu/

activeapp/wp-content/uploads/2019/08/VOCIARE_Synthesis_Report-web.pdf. 

31

What are the impacts of the policy options?What are the impacts of the policy options?Wider society: Wider members of society could be im-
pacted by this policy option as managers will be mandated 
to undertake training on sexual assessment at work on 
the effects of DV. Wider society could also be impacted 
by participation in EU-level surveys, although this would 
remain voluntary at an individual level. 

rights of the elderly could be better ensured through the 
range of measures for victims of DV. Measure 4.1 obliges 
Member States to facilitate access to specialised support 
services to groups at risk, and as this measure is not tailored 
and inclusive it may be by nature more likely to positively 
impact this fundamental right. 

National authorities: National authorities are overall 
likely to consider the policy option as politically accept-
able, although those which have not ratified the Istanbul 
Convention may be more reluctant and concerned about 
the cost implications and where there is currently resistance 
to the concept of ‘gender’. 

3.3.2.2.  Fundamental rights

The policy option is expected to have a very positive im-
pact on the following fundamental rights in the Charter on 
Fundamental Rights (CFR):

Right to life (Article 2, CFR), Right to the integrity 
of the person (Article 3, CFR), Prohibition of torture 
and inhuman or degrading treatment (Article 4, CFR), 
Respect for private and family life (Article 7, CFR): 
As violence against women and domestic violence often 
involves physical violence, including femicide, all measures 
will help ensure these rights either directly or indirectly. 
Protection measures (2.1A, 2.2A and 2.3A), in particular, 
would have a very positive impacts on these rights as they 
directly aim to protect victims from further violence, includ-
ing the risk of femicide. 

Non-discrimination (Article 21, CFR) and Equality 
between women and men (Article 23, CFR): All meas-
ures will strongly help contribute to the non-discrimination 
and equality between women and men as violence against 
women and domestic violence is a form of gender discrimi-
nation that perpetuates inequality. 

Rights of the elderly (Article 25, CFR): Although no 
measures particularly target the elderly, it is possible the 

Integration of persons with disabilities (Article 26, 
CFR): the same considerations as for the elderly above 
would apply.

Rights to social assistance and health care (Article 34 
and 35, CFR): The support measures, particularly Measure 
4.1A, included in this policy option will help meet these 
rights, particularly rape crisis centres which help victims 
access specialist medical assistance they may require. 

The right to an effective remedy and to a fair trial 
(Article 47, CFR): Measures 3.1A, 3.2A and 3.3A will all 
improve access to effective remedy and fair trial through 
increasing reporting, improving access to compensation 
and additional approximation of criminal definitions and 
sanctions of certain forms of violence against women and 
domestic violence. 

Right to fair and just working conditions (Article 31, 
CFR): This right would be strongly enforced under this Policy 
Option through four measures that target sexual harass-
ment at work: training of managers regarding harassment 
at work (1.3A), national policies and risk assessments on 
sexual harassment at work (1.4A), additional approximation 
of criminal definitions and sanctions against sexual harass-
ment (3.1A) and support for victims of sexual harassment 
at work (4.2A).

Rights of the child (Article 24 of Charter, CFR): Meas-
ure 2.3A on protection of children by providing for surveyed 
safe places for victims in case of allegations of domestic 
violence would help enforce the rights of child, along with 
targeted support measures in Measure 4.1A and instigation 
of child-friendly report mechanisms (3.1A). 

32

What are the impacts of the policy options?3.3.3.  Efficiency: comparison of benefits and costs 

3.3.3.1.  Administrative and compliance costs

This section summarises the administrative and compliance 
costs for each measure in policy option 2a that is assumed 

to incur additional costs compared to the baseline. The costs 
are outlined in Table 4. The assumptions used to develop 
the costings and details about who will bear the costs are 
outlined in Annex 4. 

Table 4: Overview of administrative and compliance costs – Option 2A

Policy 
objective

Description of measure

1.1a: Obligation on MS to provide targeted information 
to and raise the awareness of groups at risk.

1.2a: Obligation on MS to make available voluntary 
perpetrator programmes to all those at risk of offending 
and mandatory programmes for re-offenders.

1.3a: Obligation on MS to provide - specialised, regular 
and mandatory training to professionals likely to come 
into contact with victims; and - mandatory training to 
managers on sexual harassment at work and the effects 
of domestic violence on the workplace.

1.4a: Obligation on MS to ensure that sexual harass-
ment at work is addressed in national policies. Obligation 
on MS to ensure that company risk assessments cover 
sexual harassment at work.

TOTAL

2.1a: Obligation on MS to ensure efficiency through 
minimum standards on the issuance, conditions and 
enforcement of emergency barring orders and protection 
orders.

2.2a: Obligation on MS to conduct risk assessments 
speedily and in cooperation with support services. 

2.3a: Obligation on MS to ensure the protection of chil-
dren by providing for surveyed safe places for visits in 
case of allegations of domestic violence.

TOTAL

n
o
i
t
n
e
v
e
r
P

n
o
i
t
c
e
t
o
r
P

One-off development 
cost (Millions of 
euros)

Running cost per 
annum (Millions 
of euros)

0 

0 

1.8

4.0 – 8.5

0.1 

25.9

 0.6

 1,893.9 

2.4 

0

0

0

0

1,923.9 – 
1,928.5 

3.7 – 25.2

 46.9 

719.0 – 1,942.6

769.5 – 2,014.6

33

What are the impacts of the policy options?What are the impacts of the policy options?Policy 
objective

Description of measure

One-off development 
cost (Millions of 
euros)

Running cost per 
annum (Millions 
of euros)

e
c
i
t
s
u

j

o
t

s
s
e
c
c
A

t
r
o
p
p
u
S

n
o
i
t
a
n
d
r
o
o
C

i

3.1a: Obligation on MS to ensure easy and accessible 
reporting, including child friendly reporting mechanisms 
and online reporting.

3.2a: EU-level criminalisations: additional approxima-
tion of criminal definitions and sanctions on the basis of 
the legal bases of computer crime (ICT-facilitated cyber 
violence), sexual exploitation (certain forms of sexual 
violence), and serious forms of sexual harassment.

3.3a: Right of victims to obtain full compensation from 
the perpetrator in one single procedure and within ad-
equate time limits.

TOTAL

4.1a: Obligation on MS to facilitate access to special-
ised support services to groups at risk, such as children, 
migrant and asylum-seeking women and women with 
disabilities. Connect national helplines to EU-level 
helpline.

4.2a: Obligation on MS to provide specific support to 
victims of sexual harassment at work (including medical 
care and complaint mechanisms).

4.3a: Obligation on MS to establish both on- and offline 
support for victims of cyber violence against women. 

TOTAL

5.1a: Obligation to provide one-stop online access to 
relevant protection and support services. Encouragement 
to locate support services in the same premises.

5.1b: Obligatory participation in surveys coordinated at 
EU-level

5.1c: Obligation to regularly collect disaggregated 
relevant administrative data in line with a number of 
harmonised minimum requirements.

TOTAL

TOTAL ALL AREAS

0

0

0

0

326.5

2.0

0

328.5

13.6

138.6 – 502.0

0

0

13.6

0

0

0.2

0.2

16.1

627.1

1,159.6

1,925.2 – 
2,288.7

0.4

16.8

0.1

17.3

4,964.5 – 
6,577.6

34

What are the impacts of the policy options? 
 
3.3.3.2.  Economic impacts

The expected impact of this policy option is mainly due to 
the economic benefits generated in due to a decrease in the 
prevalence of violence against women and domestic violence. 

Due to additional measures for prevention, protection, sup-
port to victims and coordination, the impact of this option (on 
prevalence) is expected to be higher than the more moderate 

policy option 1. Therefore, the assessment of economic im-
pacts follows the same methodological approach as Section 
3.2.3.2 but assumes a higher decrease in prevalence rates for 
the two scenarios shown below. Moreover, a higher increase in 
reporting of 10% is used to calculate the change in costs for 
the criminal justice system and the criminal justice system. 
The estimated total economic benefits of policy option 2a 
range between a cost reduction of 53.1 billion and 82.7 
billion Euros, as shown in Table 5.

Table 5: Estimated economic benefits of prevention, protection, access to justice and victim support measures in the 
EU under Policy Option 2a

Cost category

Estimated 
EU-27 cost 
of GBV72

Scenario 1: prevalence 
reduced by 20%

Scenario 2: prevalence 
reduced by 30%

% 
change 
in costs

Estimated 
reduction in 
costs/ economic 
benefits

% 
change 
in costs

Estimated 
reduction in 
costs/ economic 
benefits

Lost economic output

€40.5 billion

- 20%

€8.1 billion

Health services

€12.5 billion

- 20%

€2.5 billion

Criminal justice 
system

€59.7 billion

- 12%

€7.2 billion

Civil justice system

€1.6 billion

- 12%

€0.2 billion

Social welfare

€10.3 billion

- 20%

€2.1 billion

Personal costs

€3.2 billion

Specialist services

€1.0 billion

- 20%

- 20%

€0.6 billion

€0.2 billion

Physical/emotional 
impacts

€161.2 billion

- 20%

€32.2 billion

- 30%

- 30%

- 23%

- 23%

- 30%

- 30%

- 30%

- 30%

€12.2 billion

€3.8 billion

€13.7 billion

€0.4 billion

€3.1 billion

€1.0 billion

€0.3 billion

€48.4 billion

Total

€290 billion

€53.1 billion

€82.7 billion

72  Estimation of the costs of gender-based violence in the UK case study and extrapolation to EU Member States (forthcoming EIGE paper, 2021).

35

What are the impacts of the policy options?What are the impacts of the policy options?3.3.4.  Coherence

The policy option will improve internal coherence by ad-
dressing the fragmented nature of the current EU legal 
framework, which includes 14 separate EU legal instru-
ments. It will also address the lack of systematic and fo-
cussed measures related to violence against women and 
domestic violence. It is internally coherent with existing 
EU legislation, particularly the Victims’ Rights Directive by 
ensuring existing provisions meet the particular needs of 
victims of violence against women and domestic violence. 

As regards external coherence, the policy option would 
first and foremost address the emerging fragmentation 
created as 21 Member States are party to the Istanbul 
Convention and six are not, and all of them adopt differ-
ent measures on violence against women and domestic 
violence. Inconsistencies with other international instru-
ments will also be significant improved. Coherence with 
the ILO Violence and Harassment Convention no 190 will 
be improved through measures addressing harassment 
at work specifically (1.3A, 1.4A, 3.1A, 4.2A). Similarly, 
greater coherence with the Convention on the Rights 
of the Child will be ensured through two measures to 
improve support and protection of child witnesses and 
victims (2.3A, 4.1A). 

3.3.5.  Overall assessment

The policy option is expected to have a strongly positive 
impact, by putting into place a single EU legislative instru-
ment specifically focussed on victims of violence against 
women and domestic violence, which combines preven-
tion, protection and prosecution measures, in line with the 
requirements of the Istanbul Convention and beyond. This 
means also that, whilst some of the measures included 
in this option already exist as part of the baseline, these 
will still have a positive impact due to their specific focus 
and coverage. 

The policy option goes beyond the baseline by introducing 
several measures in areas where gaps had been identified , 

including specific action with regard to online violence and 
work-based harassment of women, as well as a tailored 
and inclusive approach to groups at risk and children. 
The measure is also particularly strong regarding data 
collection as participation in surveys is mandatory and 
data must be collected according to harmonised minimum 
requirements. 

The positive impacts of this policy option are not only 
expected in those six Member States which currently have 
not ratified the Istanbul Convention, but across the EU, as 
Member States, even when already having similar meas-
ures in place, would now base these on a set of minimum 
standards and conditions. This would, at the same time, 
strongly favour cross-border recognition and action. 

Overall, having a detailed set of measures combined in a 
coherent and comprehensive legal framework is expected 
to have a multiplier effect on Member States which have 
been lagging behind, and contribute to a consistent and 
harmonised implementation across the EU. The policy op-
tion overall addresses nearly all problems identified in the 
current situation. 

Member State political acceptance is expected to be overall 
good, as many Member States have ratified the Istanbul 
Convention and fully implemented the relevant EU legis-
lative framework. However, as some of the measures put 
forward would require significant investments if not yet in 
place, a few Member States may be more reluctant. Further, 
the current resistance in some countries towards policies 
about gender (instead of sex) may make some reluctant 
to accept some of the measures included. 

3.4.  Policy option 2b: Comprehensive

This section assesses the impact of the measures under 
policy option 2b. The measures build on those in policy 
option 2b and 1 with seven additional measures. The 
assessment here focuses only on these new measures to 
avoid repetition. A full assessment of the measures is avail-
able in Annex 5. 

36

What are the impacts of the policy options?3.4.1.  Effectiveness

In the area of prevention, Measure 1.2B builds on Measure 
1.2A by making perpetrator programmes mandatory for all 
those convicted of crimes related to violence against women 
and domestic violence. Currently, there are only mandatory 
programmes for perpetrators in seven Member States (BE, 
CZ, ES, LV, PL, PT, FR for those in prison, and HR as part of 
probation service) which means this measure could have 
a significant impact on prevention73. Measures related to 
protection are the same as option 2a. 

Measure 3.3B would improve access to justice through 
ensuring that state compensation is provided in cases where 
victims cannot obtain compensation from the perpetrator or 
other sources. In most states, state-funded compensation 
is available subsidiarily, thus only when the victim cannot 
procure payment from the perpetrator, either because they 
have not been identified, cannot afford the compensation, or 
compensation was denied in the criminal or civil proceed-
ings, in line with Council Directive 2004/80/EC. However, this 
measure would strengthen obligations and help ensure it 
is available for all victims of violence against women and 
domestic violence. 

Measure 3.2B would introduce a new legal basis for the 
EU to have a specific legal instrument on violence against 
women and domestic violence. Although the legal instru-
ment could address any aspect of violence against women 
and domestic violence, it would likely have the most impact 
on access to justice as it would allow the EU to adopt es-
tablish minimum rules concerning the definition of criminal 
offences and sanctions on all forms of violence against 
women and domestic violence. It would enable common le-
gal definitions of violence against women and domestic 
violence and common minimum rules for sanctions. This 
measure would help, to some extent, ensure consistency 
across Member States. Currently, according to EELN, the 

majority of Member States criminalise psychological vio-
lence, stalking, physical violence, sexual violence, forced 
marriage, FGM, forced abortion and forced sterilization. 
The only forms of violence where there is significant vari-
ation among Member States is psychological violence and 
online violence (as discussed above) so the greatest im-
pact would be achieved for these crimes. The measure 
may also help ensure criminalisations are applied in a 
gender-sensitive manner. 

Option 2b has two significant measures related to support. 
Measure 4.2B obliges Member States to provide three days 
of special leave compensated at the level of sick leave for 
worker victims of violence against women and domestic 
violence. As this is not in place in any Member State, this 
will have a significant impact on the support available to 
victims. Measure 4.1B obliges Member States to provide 
shelters in line with Council of Europe recommendation of 
1 space per 10,000 inhabitants. This will have a significant 
impact on the support available to victims, WAVE has shown 
that in 2019, only three Member States (LU, MT, SL) met 
this standard74. 

Two measures will improve coordination on violence 
against women and domestic violence. Measure 5.1B cre-
ates an obligation for Member States to provide multi-
agency one-stop access to relevant protection and support 
services in the same premises. This measure will allow 
for a more coordinated and comprehensive approach to 
the protection and support available to victims. Measure 
5.3B will ensure that sex-disaggregated administrative 
data, collected according to minimum standards to ensure 
comparability, is centralised at the national level across 
relevant sectors such as police, judiciary, health and so-
cial services. This would further support data analysis, as 
comparable data would be available in one place across 
sectors. 

73  Targeted Consultation with Member State authorities q. 29. No response: PL, HR, LT
74  WAVE (2019) Wave Country Report 2019. https://www.wave-network.org/2019/12/30/wave-country-report-2019. 

37

What are the impacts of the policy options?What are the impacts of the policy options?3.4.2.  Effectiveness – other impacts

3.4.2.1.  Social impacts

The following social impacts are expected, by stakeholder 
group:

Victims of violence against women and domestic 
violence: Victims of violence against women and do-
mestic violence are expected to strongly benefit from this 
policy option. Support would be more accessible as multi-
agency services would be available in the same premises. 
Moreover, support would also increase as Member States 
would be obliged to provide shelters in line with Council 
of Europe recommendation (1 space per 1,000) which is 
only currently met in only three Member States. Victims 
would also benefit from more secured access to com-
pensation as the state would provide it in cases where 
victims cannot obtain compensation from the perpetrator 
or other sources. 

Particular groups of victims (child victims and wit-
nesses, victims at risk of intersectional discrimina-
tion): The measures will have a particularly positive impact 
on worker victims of violence against women and domestic 
violence as they would receive three days of paid leave 
which would will give victims the time to recover, access 
to support and pursue justice.

Perpetrators of violence against women and domes-
tic violence: Perpetrators will be significantly impacted by 
this measure, as all convicted offenders will be mandated 
to attend perpetrator programmes to help them change 
their attitudes and behaviours and thus prevent further 
violence

politically acceptable, particularly because of the very high 
cost of some measures. 

3.4.2.2.  Fundamental rights

The policy option is expected to have a very positive im-
pact on the following fundamental rights in the Charter on 
Fundamental Rights (CFR):

Right to life (Article 2, CFR), Right to the integrity 
of the person (Article 3, CFR), Prohibition of torture 
and inhuman or degrading treatment (Article 4, CFR), 
Respect for private and family life (Article 7, CFR): 
As violence against women and domestic violence often 
involves physical violence, including femicide, all measures 
will help ensure these rights either directly or indirectly. 
Measure 1.2B will help prevent such violence through man-
datory perpetrator programmes. 

Non-discrimination (Article 21, CFR) and Equality 
between women and men (Article 23, CFR): All meas-
ures will strongly help contribute to the non-discrimination 
and equality between women and men as violence against 
women and domestic violence is a form of gender discrimi-
nation that perpetuates inequality. 

Rights to social assistance and health care (Article 34 
and 35, CFR): The support measures, particularly Measure 
4.1B which would significantly approve the availability of 
shelters as well as Measure 4.2B which would give workers 
victims of violence against women and domestic violence 
paid leave from work which will help them to have the time 
and space to access social assistance, and Measure 5.1B 
which will approve the access to services through locating 
them on the same premises.

Wider society: No additional direct impacts expected on 
wider society.

National authorities: As the policy option goes beyond 
the standards set out in the Istanbul Convention, national 
authorities may be somewhat more hesitant to consider it 

The right to an effective remedy and to a fair trial 
(Article 47, CFR): Measures 3.1B and 3.3B will improve 
access to effective remedy and fair trial through improving 
access to state compensation and additional approximation 
of criminal definitions and sanctions for all forms of violence 
against women and domestic violence. 

38

What are the impacts of the policy options?3.4.3.  Efficiency

3.4.3.1.  Administrative and compliance costs

This section summarises the administrative and compliance 
costs for each measure in policy option 2b that is assumed 

to incur additional costs compared to the baseline. The costs 
are outlined in Table 6. The assumptions used to develop 
the costings and details about who will bear the costs are 
outlined in Annex 4. 

Table 6: Overview of administrative and compliance costs

Policy 
Objective

Description of measure

1.1a: Obligation on MS to provide targeted information to and 
raise the awareness of groups at risk

1.2b: Obligation on MS to make available voluntary perpetrator 
programmes to all those at risk of offending and mandatory 
programmes for all offenders.

1.3a: Obligation on MS to provide - specialised, regular and 
mandatory training to professionals likely to come into contact 
with victims; and - mandatory training to managers on sexual 
harassment at work and the effects of domestic violence on the 
workplace.

1.4a: Obligation on MS to ensure that sexual harassment at 
work is addressed in national policies. Obligation on MS to en-
sure that company risk assessments cover sexual harassment 
at work.

TOTAL

2.1a: Obligation on MS to ensure efficiency through minimum 
standards on the issuance, conditions and enforcement of 
emergency barring orders and protection orders

2.2a: Obligation on MS to conduct risk assessments speedily 
and in cooperation with support services. 

2.3a: Obligation on MS to ensure the protection of children by 
providing for surveyed safe places for visits in case of allega-
tions of domestic violence.

TOTAL

n
o
i
t
n
e
v
e
r
P

n
o
i
t
c
e
t
o
r
P

One-off 
development 
cost (Millions 
of euros)

 0 

0

Running cost 
per annum 
(Millions of 
euros)

4.0 – 8.5

0.8

1.8

25.9

0.6

1,893.9

2.4 

0

0

0

0

1,924.5 – 
1,929.1 

3.7 – 25.2

 46.9 

719.0 – 1,942.6

769.5 – 2,014.6

39

What are the impacts of the policy options?What are the impacts of the policy options? 
Policy 
Objective

Description of measure

e
c
i
t
s
u
j

o
t

s
s
e
c
c
A

t
r
o
p
p
u
S

n
o
i
t
a
n
i
d
r
o
o
C

3.1a: Obligation on MS to ensure easy and accessible report-
ing, including child friendly reporting mechanisms and online 
reporting.

3.2a: Introduction of violence against women and domestic 
violence as a new EU crime.

3.3b: Right of victims to obtain full compensation from the 
perpetrator in one single procedure and within adequate time 
limits, and obligation on MS to provide state compensation 
in cases where victims cannot obtain compensation from the 
perpetrator or other sources. 

TOTAL

4.1b: Obligation on MS to facilitate access to specialised sup-
port services to groups at risk, such as children, migrant and 
asylum seeking women and women with disabilities. Connect 
national helplines to EU-level helpline, and obligation on MS to 
provide 1 shelter space for 10,000 inhabitants.

4.2b: Obligation on MS to provide specific support to victims of 
sexual harassment at work (including medical care and com-
plaint mechanisms), and obligation on MS special compensated 
leave for workers victim of violence against women or domestic 
violence.

4.3a: Obligation on MS to establish both on- and offline support 
for victims of cyber violence against women. 

TOTAL

5.1b: Obligation to provide one-stop online access to relevant 
protection and support services. Encouragement to locate support 
services in the same premises, and obligation on MS to locate 
multi-agency support services for victims in the same premises. 

5.2a: Obligatory participation in surveys coordinated at EU-level.

5.3b: Integrated centralised data collection system at national 
level.

TOTAL

TOTAL ALL AREAS

One-off 
development 
cost (Millions 
of euros)

0

0

0

Running cost 
per annum 
(Millions of 
euros)

326.5

2.0

 1,569.1

0

136.2

1,897.6

 322.9 – 3,919.3 

0

0

136.2

0

0

0.2

0.2

138.7 

955.5 – 3,256.9

1,159.6

2,438.0 - 
8,335.7

3.6

16.8

3.9

24.3

7,054.1 – 
14,201.4

40

What are the impacts of the policy options? 
 
 
 
 
3.4.3.2.  Economic impacts

The expected impact of this policy option is mainly due to 
the economic benefits generated due to a decrease in the 
prevalence of violence against women and domestic violence. 

Due to further-reaching obligations on gender-based work 
harassment, access to justice, protection and data collec-
tion in option 2B compared to option 2A, the impact of this 
option (on prevalence) is expected to be somewhat higher 

than policy sub-option A. Therefore, the assessment of eco-
nomic impacts follows the same methodological approach 
as Section 3.2.3.but assumes a higher decrease in some of 
the prevalence rates for the two scenarios shown below. 
Moreover, a higher increase in reporting of 12.5% is used 
to calculate the change in costs for the criminal justice 
system and the criminal justice system. The estimated total 
economic benefits of sub-option 2B range between €57.8 
billion in the short-term and €87.6 billion in the long-term, 
as shown in Table 7.

Table 7: Estimated economic benefits of prevention, protection, access to justice and victim support measures in the 
EU under Policy Option 2B

Cost category

Estimated 
EU-27 cost 
of GBV75

Scenario 1: 
prevalence reduced by 22%

Scenario 2: 
prevalence reduced by 32%

% change 
in costs

Estimated 
reduction in costs/ 
economic benefits

% change 
in costs

Estimated 
reduction in costs/ 
economic benefits

Lost economic output

€40.5 billion

- 22%

€8.9 billion

Health services

€12.5 billion

- 22%

€2.8 billion

Criminal justice system

€59.7 billion

- 12%

€7.3 billion

Civil justice system

€1.6 billion

- 12%

€0.2 billion

Social welfare

Personal costs

€10.3 billion

- 22%

€2.3 billion

€3.2 billion

- 22%

€0.7 billion

Specialist services

€1.0 billion

- 22%

€0.2 billion

Physical/emotional 
impacts

€161.2 billion

- 22%

€35.5 billion

- 32%

- 32%

- 24%

- 24%

- 32%

- 32%

- 32%

- 32%

€13.0 billion

€4.0 billion

€14.0 billion

€0.4 billion

€3.3 billion

€1.0 billion

€0.3 billion

€51.6 billion

Total

€290 billion

€57.8 billion

€87.6 billion

75  Estimation of the costs of gender-based violence in the UK case study and extrapolation to EU Member States (forthcoming EIGE paper, 2021).

41

What are the impacts of the policy options?What are the impacts of the policy options?3.4.4.  Coherence

3.4.5.  Overall assessment 

The policy option will improve internal coherence by ad-
dressing the fragmented nature of the current EU legal 
framework, which includes 12 separate EU legislative in-
struments. It will also address the lack of systematic and 
focussed measures related to violence against women and 
domestic violence. It is internally coherent with existing 
EU legislation, particularly the Victim Rights’ Directive by 
ensuring existing provisions meet the particular needs of 
victims of violence against women and domestic violence. 

As regards external coherence, the policy option would 
first and foremost address the emerging fragmentation 
created as 21 Member States are party to the Istanbul 
Convention and six are not, and all of them adopt differ-
ent measures on violence against women and domestic 
violence. Inconsistencies with other international instru-
ments will also be significant improved. Coherence with 
the ILO Violence and Harassment Convention no 190 will 
be greatly improved through measures addressing har-
assment at work specifically three days of paid leave for 
victims (4.2A). Similarly, greater coherence with the Con-
vention on the Rights of the Child will be ensured through 
two measures to improve support and protection of child 
witnesses and victims.

The policy option is expected to have a very strongly positive 
impact in terms of achieving the policy objectives, by putting 
into place a single EU legislative instrument, specifically fo-
cussed on victims of violence against women and domestic 
violence, by going beyond the standards contained in the Is-
tanbul Convention. The positive impacts of this policy option 
are therefore not only expected in those six Member States 
which currently have not ratified the Istanbul Convention, 
but across the EU, as Member States, even when already 
having similar measures in place, would now base these 
on a set of minimum standards and conditions. This would, 
at the same time, strongly favour cross-border recognition 
and action. The Policy Option is particularly strong in the 
area of support, coordination and prevention. 

Member State political acceptance is expected to be mixed. 
Some Member States may be willing to go further than the 
measures already in place under the Istanbul Convention, 
in recognition that the problem of violence against women 
and domestic violence remains prevalent, however the sig-
nificant investments required may make them resistant. 
This is particularly the case for measures such as three 
days of paid leave for worker victims which is not in place 
in any Member State. 

42

Comparison of the policy optionsWhat are the impacts of the policy options?4.  Comparison of the policy options

This section presents a comparison of the policy options. 
Table 8 provides the weighted scores attributed to the im-
pacts of each policy option against the assessment criteria, 

covering effectiveness, efficiency and coherence. Overall, 
Policy Option 2a scores most highly. 

Table 8: Comparison of the scoring of the policy options

Scoring 
-3 Highly negative impact, 0 No impact, 3 Highly positive impact

Baseline 

Policy Options 

Weighted score

Effectiveness 

Effectiveness in achieving the objectives (25%)

Prevention

Protection 

Access to Justice

Support 

Coordination

Social impacts (12.5%)

Impact on: 

- victims of violence against women and domestic violence

-  particular groups of victims (child victims and witnesses, victims at risk 

of intersectional discrimination, etc.)

- perpetrators of violence

- wider society

- national authorities

Environmental impacts (0%)

Impact on the environment

Fundamental rights (12.5%)

PO0

0.00

PO1

6.26

PO2a 

PO2b

8.66

8.52

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

7

1

1.5

2

1.5

1

8.5

2

2

1.5

1.5

1.5

0

0

20

11

2

2.5

2.5

2.5

1.5

11

2.5

2.5

2.5

2.5

1

0

0

11.25

2

2.5

2.5

2.75

1.5

11.25

2.75

2.5

2.5

2.5

1

0

0

26.5

27

43

Comparison of the policy optionsComparison of the policy optionsWhat are the impacts of the policy options? 
 
 
 
 
 
 
 
Scoring 
-3 Highly negative impact, 0 No impact, 3 Highly positive impact

Baseline 

Policy Options 

Victims of violence against women and domestic violence 
- Right to life (Article 2)

- Right to the integrity of the person (Article 3)

- Prohibition of torture and inhuman or degrading treatment (Article 4)

- Respect for private and family life (Article 7)

- Non-discrimination (Article 21) 

- Equality between women and men (Article 23)

- Rights of the elderly (Article 25)

- Integration of persons with disabilities (Article 26)

- Rights to social assistance and health care (Article 34 and 35)

- Right to an effective remedy and to a fair trial (Article 47)

Victims of online violence against women and domestic violence 
- Protection of personal data (Article 8)

- Freedom of expression and information (Article 11)

Victims of gender-based harassment at work 
- Right to fair and just working conditions (Article 31)

- Right to an effective remedy and to a fair trial (Article 47)

Child victims /witnesses 
- Protection of the rights of the child (Article 24)

Coherence (20%)
Internal coherence

External coherence

Efficiency 
Costs (15%)
Administrative and compliance costs 

Economic impacts (15%)
Impacts on public health

PO0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

PO1

1.5

1.5

1

1.5

1.5

1

1

1.5

1.5

1.5

1

1

1.5

1.5

1.5

4

2

2

-0.5

-0.5

1.5

1.5

PO2a 

PO2b

2

2

1.5

2

2

1.5

1.5

2

2

2

1

1

2

2

2

5

2.5

2.5

-1

-1

2.5

2.5

2

2

1.5

2

2

1.5

1.5

2

2

2

1

1

2.25

2.25

2

5

2.5

2.5

-3

-3

2.5

2.5

To improve the accuracy of the comparison, the scores 
that been weighted through a sensitivity analysis. Table 9 
summaries the variation in the comparison of the scores 
of the different policy options when assigning different 
weights to the three criteria of effectiveness, efficiency 

and coherence. Four different combination of weights for 
these three criteria are denoted as weightings A-D. Option 
1 is always dominated by each sub-options of Option 2. 
The sensitivity analysis shows that Option 2A maintains its 
advantage in all the different weighting scenarios.

44

Comparison of the policy options 
 
 
 
Table 9: Sensitivity analysis

Weighting

Unweighted

A

B

C

D

s
s
e
n
e
v
i
t
c
e
ff
E

N/A

50%

40%

50%

40%

e
c
n
e
r
e
h
o
C

N/A

20%

20%

10%

10%

y
c
n
e
i
c
ffi
E

N/A

30%

40%

40%

50%

PO0

PO1

PO2a

PO2b

0.00

0.00

0.00

0.00

0.00

40.50

55.00

54.00

6.26

5.25

5.91

4.90

8.66

7.25

8.24

6.83

8.52

6.98

7.99

6.45

4.1.  Effectiveness

Policy option 2a is expected to make a greater contribution 
to ensuring effective measures for preventing violence 
against women and domestic violence compared to Policy 
option 1 because it adds important new elements that focus 
on groups of victims who are at heightened risks and spe-
cific measures to prevent sexual harassment at work and 
gender-based cyber violence. This tailored approach is likely 
to be more effective and inclusive. Perpetrator programmes 
are also mandatory for re-offenders, rather than voluntary, 
which will significantly increase take-up. Policy Option 2b 
builds on this slightly by making perpetrator programmes 
mandatory for all offenders which would help prevent more 
violence against women and domestic violence, although 
Option 2a is more targeted at those most likely to re-offend. 

Compared to the Policy Option 1, the Policy Option 2a also 
adds several valuable elements in the area of protection, 
thus also enhancing its effectiveness in ensuring that vic-
tims of violence against women and domestic violence are 
protected from (further) violence. In particular the measure 
introducing minimum standards in relation to the issuance 
of protection orders (emergency barring orders) which is 
expected to improve their timeliness and effectiveness, and 
favour cross-border recognition. The suggested individual 
risk assessments should also offer better protection to 

victims thourgh better identifying those in need of pro-
tection measures. In this area, the Policy Option 2a also 
foresees measures specifically aimed at child victims and 
witnesses. There is negligible difference between Policy Op-
tion 2a and 2b in relation to this specific objective. 

As for the previous two objectives, with respect to ensuring 
affective access to justice for victims (specific objective 
3), all three policy options are expected to have a positive 
impact. Policy Option 1 offers the least impact, as the meas-
ure to increase reporting by third parties is very similar to the 
baseline. Policy Options 2a and 2b go significantly further. Op-
tion 2b proposes criminalisation of violence against women 
and domestic violence as an EU crime however option 2a 
is more proportionate in targeting only criminalisation not 
already addressed at national level. 2b would however have 
far more impact regarding access to compensation through 
offering state compensation subsidiarily as there are proven 
challenges obtaining compensation from perpetrators. 

Also in the area of support services, Policy Options 2a and 2b 
are expected to make a greater contribution to the objective 
of ensuring the effective availability of support for victims of 
all forms of violence against women and domestic violence, 
as it is expected to boost the quality and capacity of exist-
ing services and further expand them, including to victims 
of sexual harassment at work, groups at risk and victims of 

45

Comparison of the policy optionsComparison of the policy optionsonline violence. 2b sets stricter targets regarding availability 
of shelters and introduces three days of paid leave for victims 
which would have a very significant impact these measures 
are not currently is not in place across the EU. 

Finally, Policy Options 2a and 2b are also expected to have 
a significantly higher impact on ensuring more effective 
cooperation and coordination in relation to violence 
against women and domestic violence than Policy Option 
1, particularly in the area of data collection. Option 2a ad-
dresses the main challenge regarding the comparability of 
data collected across the EU but 2b goes further to create 
a centralised data collection system at national level which 
would make such data easier to access. 

4.2.  Effectiveness – other impacts 

With regard to effectiveness in terms of social impacts, 
Policy Option 2b is expected to overall have a more positive 
impact on victims of violence against women and domestic 
violence, as it offers a stronger package of measures, which 
will enhance both the quality and capacity of current ser-
vices and facilities, and expand them to additional victims 
e.g. those of online violence and victims of violence against 
women and domestic violence at work. 

Option 2b includes measures tailored to the needs of par-
ticular groups of victims (child victims and witnesses, 
migrant women victims etc.), which means that here too 
its impact is expected to be more positive than the 1 and 
very similar to 2b. 

Along the same lines, again because of some additional 
measures, the impact on perpetrators of violence is as-
sessed more positively in 2a and 2b, in particular, as already 
mentioned above, because of the inclusion of potential 
perpetrators in treatment programmes and other preven-
tion activities. 

be impacted across the Policy Options through their involve-
ment in general awareness-raising initiatives.

The only exception constitutes the social impact on na-
tional authorities, as the wider scale and scope of the 
Policy Option 2a and especially 2b may make it less po-
litically acceptable for some Member States, in particular 
those which would be expected to make major investments 
(e.g. because of the specific requirement in relation to the 
number of shelter places and paid leave). Moreover, it is 
likely that some Member State will not support the option 
because of resistance to the term ‘gender’. Politicians have 
spoken publicly against the term and advocated for the 
terms ‘sex’ or ‘men and women’ instead. The resistance 
is rooted in a binary understanding of sex that it consid-
ers disrupted by the notion of gender and as undermining 
traditional family structures and values.

With regard to the effectiveness in terms of impacts on 
fundamental rights, both policy options are expected to 
strengthen the fundamental rights of women, men and 
children as potential victims of violence against women 
and domestic violence and society more generally through 
enabling a more equal and less violent society. Policy Op-
tion 2b receives a more positive assessment overall, for 
the reasons already set out above. 

4.3.  Coherence

The internal coherence of all three policy options is as-
sessed positively, as all are expected to address some of 
the key problems identified and gaps identified in Section 2. 
All the options help address the highly fragmented nature 
of the current EU legal framework, and the lack of system-
atic, focused measures related to violence against women 
and domestic violence. Policy Option 2b has the strongest 
internal coherence through it ensuring the general provisions 
in the Victims Rights’ Directive fully meet the particular 
needs of violence against women and domestic violence. 

Impacts on wider society are limited because of the fo-
cused nature of the measures on victims of violence against 
women and domestic violence although wider society would 

Similarly, all three policy options will contribute to enhanc-
ing external coherence, mostly by aligning to the Istanbul 

46

Comparison of the policy optionsConvention, as well as other international instruments such 
as the ILO Violence and Harassment Convention and the 
Convention on the Rights of the Child. Here too, the Policy 
Option 2b achieves a higher scoring, as it goes beyond the 
standards in the Istanbul Convention and includes additional 
action in relation to work-based harassment as well as 
protection of child witnesses. 

4.4.  Efficiency 

In terms of the efficiency of the policy options, all three 
policy options are expected to incur substantial administra-
tive and compliance costs, but these costs are exceeded by 
the potential economic benefits of each option (reduction 
in costs of violence against women and domestic violence) 
in the short-run by all three options, although not in the 
long-run for 2b. 

First, comparing policy options 2a and 1, the administrative 
and compliance costs for each problem area are higher for 
Policy Option 2a compared to Policy Option 1 Overall, the 
total administrative and compliance costs for Policy Option 
2a are between €4.2-4.4 billion euros higher than the Policy 
Option 1 in the first year of implementation. 

The difference in costs is largely driven by the running 
costs per year of the various measures. In particular, the 
most substantial differences are observed in the running 
costs for additional measures related to access to justice 
and victim support. For example, the administrative and 
compliance costs related to access to justice are over 
€0.3 billion euros higher for Policy option 2a which is 
mainly driven by the availability of more meaningful 

compensation to victims of violence against women and 
domestic violence and the cost of new measures to en-
courage the reporting of violence by third parties. The costs 
for victim support are around €1.8 billion euros higher in 
the Comprehensive Policy Option which is mainly driven by 
the cost of measures to support victims of online Violence 
Against Women or victims of Violence Against Women 
work harassment. 

While the potential economic benefits are considerable 
under both policy options, Policy Option 2a is expected 
to provide higher economic benefits. This is due to the 
higher expected impact on the reduction in prevalence of 
violence against women and domestic violence compared 
to the Policy Option 1. Specifically, the total economic ben-
efits due to the full set of measures under Policy Option 
2a are expected to be around €13.5 billion higher than the 
Moderate Policy option under scenario 1 and €29.6 billion 
higher than the Moderate Policy option under scenario 2. 

Second, comparing 2a to 2b, even though the economic 
benefit of Option 2b is expected to be higher than Option 
2a, the costs of 2b make the net benefit of 2a and 2b quite 
similar as the total costs of Option 2a in the short-term are 
€5.0 billion, compared to €7.2 billion for Option 2b. This 
leads to net benefits in the short-term of €48.1 billion for 
2a and €50.6 billion for 2b (a difference of only €2.5 billion). 
However, in the long-term, the costs of Option 2b become 
very high, reaching €14.3 billion as opposed to the €6.6 
billion cost of Option 2a. This translates to the long-term 
net benefits of option 2b being as much as €2.8 billion 
lower than those of option 2a, namely a net benefit of 
€73.3 billion of option 2b and of €76.1 billion for option 2a. 

47

Comparison of the policy optionsComparison of the policy options5.  The preferred policy option

Following the comparative assessment of the effectiveness, 
efficiency and coherence of the policy options, the preferred 
option is Policy Option 2a. 

Policy Option 2a encompasses and builds on Policy Option 
1 and contains a larger set of measures that will better 
address the shortcomings identified in the current situation, 
and which will further contribute to the achievement of the 
policy objectives to better prevent violence against women 
and domestic violence, to better protect and support victims 
of such crimes, to facilitate access to justice and address-
ing child witnesses and victims. It also provides extensive 
protection of fundamental rights due to its comprehensive 
set of obligations. 

Although Option 2b contains more comprehensive meas-
ures, regarding data collection, shelters, a one-stop-shop, 
minimum standards for criminalisation of violence against 
women and domestic violence and three days of leave for 
worker victims, Option 2b ultimately becomes more 
costly than 2a in the long run. Even though the economic 
benefit of Option 2b is expected to be higher than Option 2a 
in the short-term, the costs of the proposed measures make 
the net benefit of 2a and 2b quite similar as the total costs 
of Option 2a in the short-term are €5.0 billion, compared 
to €7.2 billion for Option 2b. This leads to net benefits in 
the short-term of €48.1 billion for 2A and €50.6 billion for 

2b (a difference of €2.5 billion). However, in the long-term, 
the costs of Option 2b become very high, reaching €14.3 
billion as opposed to the €6.6 billion cost of Option 2a. 
This translates to the long-term net benefits of option 
2b being as much as €2.8 billion lower than those of 
option 2a, namely a net benefit of €73.3 billion of option 
2b and of €76.1 billion for option 2a. 

The high costs in Option 2b of the measures it proposes 
on Violence Against Women work harassment, three days 
of paid leave for victims, stricter targets on shelter provi-
sion, and centralised data collection would be very costly 
and place disproportionate burden on SMEs and the 
Member States. The measure to establish a new Eurocrime 
in the area of violence against women and domestic vio-
lence seems disproportionate in light of the fact that most 
conduct of violence against women and domestic violence 
is criminalised at national level, leaving gaps mainly in 
the areas of cyber violence, sexual violence, and Violence 
Against Women harassment. 

Political acceptance overall of the preferred option is 
likely to be high, although with resistance from a minority 
of Member States about the emphasis placed on gender, 
and the potentially high administrative and compliance 
costs for some of those Member States which had not 
ratified the Istanbul Convention.

48

How will actual impacts be monitored and evaluated?The preferred policy option6.  How will actual impacts be monitored and 
evaluated?

The monitoring and evaluation of the new legislative in-
strument will need to be assured at all stages of the policy 
cycle (including implementation, application and evaluation), 
assessing progress and achievements against the specific 
objectives of this initiative 

At the implementation stage, as for all Directives, the 
Commission is expected to issue guidance to the EU-27 
Member States to clarify any issues that may arise during 
the transposition phase. 

Once the transposition period has expired, the Commission 
will verify that the legislative initiative has been transposed 
correctly into national laws in all EU-27. 

During the application stage, the practical implemen-
tation and functioning of the directive will be monitored 
against the specific objectives as listed above. The subse-
quent monitoring and evaluation of the Directive will be 
highly important to assess its efficiency and effectiveness 
in addressing the underlying problems and meeting policy 
objectives. 

The Commission will present a report evaluating the im-
plementation, functioning and impact of the directive. To 
facilitate the reporting, Member States will communicate 
to the Commission all relevant information concerning the 
application of this Directive after the transposition deadline. 
These reports will play a key role in assessing the correct 
application of the directive. 

One method to monitor the Directive is to monitor the out-
comes, as fully outlined in Annex 1. As the overall intended 
impact is to reduce the prevalence of violence against wom-
en and domestic violence, this can be monitored through the 
administrative data about reporting, prosecution, conviction 
and sanctions. Currently, such data is available to a limited 
decree through EIGE’s gender statistics database76. Impor-
tantly, under the preferred policy option, there is a measure 
to ensure Member States collect disaggregated administra-
tive data, including data from law enforcement agencies 
and judicial data, as well as data from social and health 
services and NGOs, at regular intervals, and to participate 
in regular centralised surveys at EU-level (following up on 
the ESTAT-GBV survey). These new requirements are thus 
expected to add more detail and comparability to the cur-
rently available data and together with the Member State 
reporting, form the basis for monitoring and evaluating the 
impact of the new EU legal instrument. 

Another way to monitor the impact, as indicated in Annex 
1, is to use data collected through existing monitoring 
exercises as many measures are consistent with provisions 
in the Istanbul Convention, ILO Convention 190 and exist-
ing EU reports on the monitoring of the implementation of 
various EU legal instruments. This will substantially reduce 
the administrative burden on Member States that could be 
posed by monitoring.

76  EIGE Gender Statistics Database: https://eige.europa.eu/gender-statistics/dgs

49

How will actual impacts be monitored and evaluated?How will actual impacts be monitored and evaluated?The preferred policy optionAnnex 1.  How will the impact be monitored?

The below table sets out indicators for monitoring each measure in the proposed policy options. As explained in the main 
report, existing legal monitoring is available which is indicated in the far-right column of the table. 

Objectives

Measure

Indicator

Ensuring effec-
tive prevention 
of violence against 
women and domestic 
violence

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

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

Obligation on MS to have perpetrator programmes 
in place.

Obligation on MS to make available voluntary per-
petrator programmes to all those at risk of offend-
ing and mandatory programmes for re-offenders.

Obligation on MS to make available voluntary per-
petrator programmes to all those at risk of offend-
ing and mandatory programmes for all offenders.

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

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

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

Obligation on MS to ensure that company risk as-
sessments cover sexual harassment at work.

Number of targeted awareness rais-
ing campaigns and information activi-
ties per year, including assessment of 
activities to ensure they reach groups 
at heightened risk of violence against 
women and domestic violence.

Percentage of relevant category 
of offenders attending perpetrator 
programs.

Number of professionals dealing with 
victims or perpetrators of violence 
against women and domestic violence 
trained per year. 

Number of companies that report 
having a risk assessment in place that 
cover sexual harassment.

MS have national policy in place (Y/N)

50

Annex 1Objectives

Measure

Indicator

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

(further) violence 

Obligation on MS to ensure availability of emer-
gency barring orders and protection orders.

Number of protection orders issued 
for violence against women and do-
mestic violence. cases. 

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

Whether Member States have adopted 
minimum standards in relation to the 
issuance and conditions of national 
emergency barring orders. 

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

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

Percentage of emergency barring 
orders issues within 24 hours. 

Number of breaches of protection 
orders. 

Number of assessments of the lethal-
ity risk as a percentage of violence 
against women and domestic vio-
lence. cases.

Existence of a formal coordination 
mechanisms in place between those 
conducting risk assessment and sup-
port services i.e. referral systems. 

Obligation to ensure that due account is taken of the 
rights and needs of child witnesses in the provision 
of protection and support services, incl. an obligation 
to provide age-appropriate psychosocial counselling.

Number of age-appropriate psycho-
social counselling appointments/cent-
ers available in relation to the target 
population. 

Ensuring effective 
access to justice 
in cases of violence 
against women and 
domestic violence

Obligation on MS to ensure that in custody and 
access rights matters in situations of DV competent 
authorities can ensure maintaining contact with the 
child in a surveyed safe place outside the alleged 
perpetrator’s home.

A EU-level criminalisations:

Additional approximation of criminal definitions and 
sanctions on the basis of the legal bases of com-
puter crime (ICT-facilitated cyber violence), sexual 
exploitation (certain forms of sexual violence), and 
serious forms of sexual harassment./ Introduction 
of VAW/DV as a Eurocrime. 

EU-level criminalisations of certain forms of vio-
lence against women and domestic violence. 

Number of surveyed safe places 
available for custody visits in relation 
to the target population. 

Legal assessment of implementation 
of relevant EU legislation.

Legal assessment of whether 
indicated forms of violence against 
women and domestic violence are 
criminalized. 

51

Annex 1Objectives

Measure

Indicator

Obligation on MS to encourage reporting of violence 
by third parties

Ensuring effective 
access to justice 
in cases of violence 
against women and 
domestic violence

Obligation on MS to ensure easy and accessible 
reporting, including child friendly reporting mecha-
nisms and online reporting.

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

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

Obligation for MS to ensure general support ser-
vices are available to victims of violence against 
women and domestic violence, including:

–   access to general health care and social services

–   services are adequately resourced

–   professionals are trained to assist victims and 

refer them to the appropriate services 

Existence of measures to encourage 
reporting such as training of profes-
sionals about how and when to report 
incidents of violence against women 
and domestic violence.

Existence of online reporting mecha-
nisms

Existence of reporting mechanism 

Legal assessment of right to state 
compensation 

Average time taken to decide com-
pensation cases

Legal assessment of ability to access 
compensation in a single procedure. 

Number of general support services. 

Levels of funding to support services 
in EUR per year

Ensuring effective 
victim support in 
cases of violence 
against women and 
domestic violence

Obligation for MS to provide three days of special 
leave compensated at the level of sick leave for all 
victims of violence against women and domestic 
violence.

Existence of provision of special leave 
compensated at the level of sick leave 
for all victims of violence against 
women and domestic violence.

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

Number of specialist support services 
per population 

Number of rape crisis or sexual violence 
referral centres per population 

Obligation for MS to ensure availability of support 
services to groups at a heightened risk of violence 
(such as migrant women, victims from minority 
communities, women with disabilities)

Existence of national helpline 

Rates of use of support services 
by groups at a heightened risk of 
violence. 

Obligation to provide shelters in a manner correspond-
ing to actual need (e.g. one family place in specialised 
women’s shelters per 10,000 of population as recom-
mended by CoE available in every region. 

Whether the target number has been 
reached of one family place in special-
ized women’s shelters per 10,000 of 
population in every region.

52

Annex 1Objectives

Measure

Indicator

Ensuring strength-
ened coordination 
in preventing and 
combatting violence 
against women and 
domestic violence

Obligation to regularly collect disaggregated rel-
evant data.

Obligation to regularly collect disaggregated 
relevant data in line with harmonised minimum 
requirements.

Full harmonisation of administrative data collection 
on violence against women and domestic violence..

Whether Member States regularly col-
lect disaggregated, relevant data (Yes/
No/Partially).

Whether Member States collect disag-
gregated relevant data in line with 
harmonized minimum requirements 
(Yes/No/Partially).

Whether Member States collect fully 
harmonized administrative data (Yes/
No/Partially).

Obligatory participation in surveys coordinated at 
EU-level

Participation in EU-level surveys (Yes/
No/Partially).

Voluntary participation in surveys coordinated at 
EU-level.

Measures strengthening multi-agency cooperation.

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

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

Existence of a coordinated referral 
mechanism.

Existence of one-stop online access to 
protection and support services. 

Existence of one-stop access to pro-
tection and support services. 

Number of services located in the 
same premises as a percentage of 
the total. 

Number of trainings carried out with 
professionals to ensure the handling 
of referrals in multi-agency coopera-
tion. 

53

Annex 1Annex 2.  Stakeholder consultation

1.1.  Stakeholder Engagement Methods 

Stakeholder consultations closely informed preparation 
and analysis of the impact assessment. The stakeholder 
engagement was conducted through the below methods:

•  Open public consultation
•  Written submissions to the public consultation
•  Targeted consultation with Member States authorities 
• 
 Workshops and consultations with NGOs, international 
organisations, trade unions and employer organisations 
(social partners) 

•  National level interviews with Member State authorities 

This section provides an outline of these methods.

1.1.1.  Open Public Consultation 

The European Commission conducted an open public con-
sultation to gather the views of the public on the measures 
taken by the EU Member States to address gender-based 
violence against women and domestic violence. The purpose 
of the consultation is to inform the Commission’s work 
on further measures for improved, coordinated prevention 
of and protection against this kind of violence. This pub-
lic consultation forms part of the evidence gathering the 
Commission is carrying out in preparation for a legislative 
initiative to prevent and combat gender-based violence 
and domestic violence.

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

The public consultation was open from 08 February 2021 
- 10 May 2021. It contained 66 questions across five sec-
tions. Two of the questions were exclusively open-ended and 
11 were multiple choice which permitted the selection of 
multiple response options. 47 of the closed-ended ques-
tions also provided the opportunity to include an open text 
response. The consultation gathered input from a range 
of stakeholders, including individual citizens, civil soci-
ety organisations, social partners, equality bodies, Mem-
ber States and national authorities. The questionnaire was 
uploaded to the Have Your Say platform of the European 
Commission. 

Overview of the respondents 

There were 767 respondents to the open public consulta-
tion from across Member States with Hungary being the 
most represented with 371 (48%) respondents, followed 
by Italy with 126 (16%) and Germany with 87 (11%) (see 
Figure 1). The high number of responses in Hungary was 
the result of publicity of the consultation in national media, 
not a targeted campaign. 

54

Annex 2Figure 1: Respondent country of origin

Figure 1.1: Respondent skateholder type

Overview of responses  

Overview of responses  

The questionnaire permitted respondents to reply to one, several, or all of the 

sections. Whilst the total number of respondents was 767 this was not the total 

The questionnaire permitted respondents to reply to one, several, or all of the 

2 

sections. Whilst the total number of respondents was 767 this was not the total 

55

2 

Annex 2 
  
  
  
  
  
  
  
  
Overview of responses 

The questionnaire permitted respondents to reply to one, 
several, or all of the sections. Whilst the total number of 
respondents was 767 this was not the total response rate 
for each question. As can be seen in Figure 2, which shows 

response rate for each question. As can be seen in Figure 2, which shows the 
number of responses received for each question, Question 1 received the highest 
number of responses (758) and question 19 received the fewest (287). Of the five 
sections, Section I received the highest average number of responses (751), 
followed by Section III (711). Section IV received the fewest (664) (see Figure 3).  

the number of responses received for each question, Ques-
tion 1 received the highest number of responses (758) and 
question 19 received the fewest (287). Of the five sections, 
Section I received the highest average number of responses 
(751), followed by Section III (711). Section IV received the 
fewest (664) (see Figure 3). 

Figure 2 

Figure 3

1.1.2.  Written Submissions to public consultation 
1.1.2  Written Submissions to public consultation  
In the course of the preparation of this Impact assessment, 
the Commission received 23 position papers and written 
submissions from the following stakeholders: United Na-
tions Agencies (1), European Agencies (1) Social Partners 
(2) and NGOs (19). 

In the course of the preparation of this Impact assessment, the Commission 
received 23 position papers and written submissions from the following 
stakeholders: United Nations Agencies (1), European Agencies (1) Social Partners 
(2) and NGOs (19).  

on the measures taken to prevent and combat gender-
based violence against women and domestic violence. 
Responses were received from all Member States apart 
from Malta, although response rates varied for each country, 
with Croatia not responding to the most questions.

The questionnaire is structured in five parts:

1.1.3  Targeted Consultation for Member State Authorities  
1.1.3.  Targeted Consultation for Member State 
Authorities 

The European Commission organised a targeted consultation with Member State 
Authorities. The online survey aimed to gather the Member States’ views 
and provide information on the measures taken to prevent and combat gender-
based violence against women and domestic violence. Responses were received 
from all Member States apart from Malta, although response rates varied for each 
country, with Croatia not responding to the most questions. 
The questionnaire is structured in five parts: 

1)  national action plans, good practices and data collection
2)  prevention
3)  protection and support measures
4)  access to justice and prosecution
5)  measures against harmful practices. 

The European Commission organised a targeted consulta-
tion with Member State Authorities. The online survey aimed 
to gather the Member States’ views and provide information 

1)  national action plans, good practices and data collection 
2)  prevention 
3)  protection and support measures 
4)  access to justice and prosecution 
5)  measures against harmful practices.  

56

1.1.4  Workshops/Consultations 

NGO Consultations  

Consultations with NGOs have been conducted through an ad hoc meeting of the 

Victims’ Rights Platform and NGOs working in the area of violence against women, 

co-organized by Unit B2 and Unit D2 of DG JUST, European Commission and eight 

individual interviews conducted by ICF with NGOs.  

Social Partner Workshop 

DG Just and ICF organised a targeted workshop with social partners on 29 June 

2021. The meeting focused on two overarching questions: 1) Exchange of views on 

the effectiveness and relevance of the EU framework on preventing and combatting 

3 

Annex 2 
  
1.1.4.  Workshops/Consultations

1.2.  Stakeholder views

NGO Consultations 

Consultations with NGOs have been conducted through 
an ad hoc meeting of the Victims’ Rights Platform and 
NGOs working in the area of violence against women, co-
organized by Unit B2 and Unit D2 of DG JUST, European 
Commission and eight individual interviews conducted by 
ICF with NGOs. 

Social Partner Workshop

DG Just and ICF organised a targeted workshop with social 
partners on 29 June 2021. The meeting focused on two 
overarching questions: 1) Exchange of views on the effec-
tiveness and relevance of the EU framework on prevent-
ing and combatting violence against women at work and 
2) Exchange of views on possible measures for increased 
prevention of sex-based work harassment and protection 
of victims:

Employer Association Workshop

DG Just and ICF organised a workshop with four Employer 
Associations on 30 June 2021 with the same agenda as 
mentioned above for the social partners.

International Organisations Consultation

DG Just organised a workshop with international organisa-
tions on 8 July 2021. 

1.1.5.  National level interviews

As part of national-level research, interviews were con-
ducted with some Member State authorities. Responses 
were received from 10 Member States (At; HR; CY; FR; IE; 
IT; LV; PT ES; SE). These are summarised in section 1.2.1.

This section outlines stakeholder views according to the objec-
tives, with an additional section on view on the initiative as a 
whole, and particular forms of violence and particular groups. 

1.2.1.  The need for a new initiative 

Overall, there was very strong support from NGOs and 
international organisations regarding the need for a spe-
cific EU initiative on violence against women and domestic 
violence. Responses from Member States authorities and 
employer organisations were slightly more mixed. There 
was also a shared view that one challenge is with effective 
implementation of current EU legislation. 

Individuals interviewed from Member State authorities 
indicated support for a new initiative on the topic (AT, CY, 
ED, FR, IE, IT, PT, SE). In Croatia, the Ministry of Justice and 
Administration and Ministry of Labour, Pension System, 
Family and Social Policy expressed the view that protection 
of victims primarily lies with the state, and a representa-
tive from the Ministry of Justice in Latvia said focus should 
be on implementing existing legislation. 

NGO Consultation: NGOs identified a wide range of 
protection and support gaps across the EU for victims of 
violence against women and domestic violence. Victims 
also face significant challenges accessing justice. NGOs 
consistently felt significant more action was needed at 
both national and EU level. NGOs did not articulate chal-
lenges with the current EU legislation, apart from for it to 
be more fully implemented in practice, but felt the main 
challenge is the need for more comprehensive legislation 
to tackle the issue of violence against women and domes-
tic violence specifically, particularly in Member States that 
have not ratified the Istanbul Convention. 

In the written submission to the public consultation, two 
NGOs objected to the use of the term gender, as opposed 
sex. These were the Centre for Fundamental Rights, Hungary 
and Association Society and Values, Bulgaria.

57

Annex 2Social Partner Workshop: Social partners saw the cur-
rent EU legislative framework as not as lacking although 
there were mentions that it was not sufficiently imple-
mented. EU legislation was seen as only one factor af-
fecting the work of social partners with many participants 
noting the important role of other factors, including the 
ILO Convention no.190 and the MeToo movement. One 
participant said there needs to be a more proactive ap-
proach. The current approach is largely reactive and re-
quires litigation to claim those rights. 

Employer Association Workshop: Participants were 
largely resistant to more obligations relating to violence 
against women and domestic violence. One noted that 
that soft measures, such as EIGE’s Handbook on Sexism 
was a better route and more training. One participant 
noted that understanding of the challenge and illegality 
sexual harassment is very well establish and understood 
but the challenge is practical implementation. Two par-
ticipants noted that the issue of tackling sexual harass-
ment varies considerably on the size of the company. In 
small companies, it can be hard to maintain confidentiality. 
Smaller companies may also not have a comprehensive 
HR structure or trainings in place. 

1.2.2.  Prevention

This section outlines views on prevention of violence against 
women and domestic violence.

Open public consultation: 

The public consultation revealed strong support for further 
prevention measures. 82% of respondents believe addi-
tional measures are necessary to ensure coordination 
among prevention services. Furthermore, 96% of respons-
es indicated that they believe it is ‘Very Important’ that 
their Member State takes measures to prevent violence 
against women. It was deemed very important by most re-
spondents (90%) that harmful gender stereotypes are 
challenged to prevent violence against women and do-
mestic violence. Measures that teach non-discrimination, 

gender equality and non-violent communication topics in 
schools (94%) are viewed as the most needed to better 
prevent violence against women and domestic violence, 
followed by measures that raise awareness about violence 
against women and domestic violence among the general 
public (82%). 

Perceived gaps were also noted regarding training: almost 
half of all respondents (48%) do not believe that profession-
als are adequately trained to work with victims of violence 
against women and domestic violence or perpetrators. This 
is echoed in the responses from Hungary and Italy whereas 
43% of respondents from Germany believe they are. As to 
whether training is provided by NGOs, almost half of the 
respondents indicated that they do not know (49%) and 
38% indicated that it is. 

Social Partner Workshop: Risk assessments were dis-
cussed in the consultation as having an important role in 
preventing and combatting violence against women. How-
ever, it was raised that risk assessments are not currently 
gender responsive which could be addressed in future 
measures. It was also noted that very few risk assess-
ments are carried out and when they are, they do not include 
psychosocial risks, suggesting implementation challenges 
in the existing legislation. 

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

International Organisations Consultation: A range 
of measures were considered to be need of development 
to ensure better prevention measures. These include: in-
tegrated service delivery; psychosocial risk assessments 

58

Annex 2that include violence and harassment; awareness-rais-
ing measures that include harassment, stalking, online vio-
lence, FGM, forced marriage which are not currently cov-
ered. Similarly, the need to combat societal prejudices, 
assumptions and gender stereotypes was also noted. 
Education and training across numerous fields, including 
work, the medical field (to include nurses and midwives), 
comprehensive sexuality education in schools, training 
for lawyers and judges. It was noted that training should 
be continuous and be based on clear guidelines. Some 
participants noted the important of engaging men and 
boys in prevention measures, and more perpetrator pro-
grammes, including better evaluation of which perpetrator 
programmes work best. 

NGO Consultation: All participants in the consultation felt 
that better prevention and protection measures are needed, 
including work with perpetrators, more awareness of the 
issue of violence against women and domestic violence 
and support for victims to know how to access support and 
protection. Address harmful gender stereotypes as one of 
the main root causes of gender-based violence. Targeted 
trainings for professionals across sectors as essential to 
providing effective support to victims, particularly with police 
and judicial authorities.

Written submission to the open public consultation: 

• 

• 

• 

 United Nations Brussels, Joint Paper (ILO, OHCHR, 
UN Women, UNHCR, UNICEF, UNODC) said a key point 
was to ‘Put preventative measures in place’.

 EIGE: ‘Prevention should be achieved including address-
ing structures norms and values that perpetuate it and 
negative gender stereotypes. It also requires a holistic, 
well-coordinated approach, including a coordinating 
framework’.

 Council of Europe Municipalities and Regions call 
for prevention of GBV/DV, including promoting coopera-
tion between all levels of government. e.g. through the 
Icelandic cooperation model.

1.2.3.  Access to Justice

This section outlines views on access to justice for victims 
of violence against women and domestic violence.

Open public consultation: 

In the public consultation, when asked whether further 
measures to improve access to justice in matters of violence 
against women and domestic violence could improve the 
situation of victims, to which 73% believe that they could at 
both national and EU level. 

The consultation also revealed a range of gaps they per-
ceived affecting access to justice. When asked whether 
victims of violence against women and domestic violence 
are provided information on their rights, the services they 
can turn to and the follow up given to their complaints, 60% 
of respondents selected ‘Partially’. Moreover, in terms of the 
timeliness that this information is provided and its acces-
sibility, respondents most predominantly selected that infor-
mation is not provided quickly enough (43%), it is difficult to 
find (42%), and it is inconsistent and spread over different 
sources (42%). 

For questions concerning the conduct of authorities, the 
majority (75%) of respondents do not consider that rel-
evant authorities or services ensure that risk factors are 
sufficiently considered at all stages of investigation and 
court proceedings. Additionally, 56% of respondents do not 
believe that law enforcement and judicial authorities in 
their Member State ensure appropriate follow-up of vio-
lence against women and domestic violence reports. Over 
half of the respondents (56%) do not believe that these 
authorities treat victims, as well as child witnesses, in a 
gender-sensitive and child friendly manner. Finally, the 
prevalent view across all respondents is that sanctions for 
gender-based and domestic violence offences are not suf-
ficient (75%). In supplementary open text commentary, 
many respondents conveyed issues with sanctions such 
as low rates of conviction, light or suspended sentences, 
and lack of enforcement. 

59

Annex 2Regarding compensation for victims, almost half of the 
respondents (49%) do not believe that information on how 
victims can obtain compensation (from the offender and/
or the state) is available in their Member State. Whilst this 
view was echoed by two of the most represented countries 
(Hungary and Italy), 59% of respondents from Germany (the 
third most represented country) do deem this information to 
be available. A minority of respondents (15%) believe that 
victims do receive compensation from the offender, al-
though 39% do not know. The final question on compen-
sation (question 19) received the fewest responses across 
all questions. It asks respondents to hypothetically describe 
the process of pursuing compensation, should they be enti-
tled, to which the overwhelming majority (84%) described 
as difficult and long. 

NGO Consultation: Participants clearly highlighted the 
need for more actions to address barriers to access to 
justice and the low rate of reporting gender-based violence.

Social partner consultation: One participant discussed 
the important of collective action by trade unions as it is a 
safer and cheaper option. Another participant noted that 
collective action can have a role in protecting victims from 
exposure, especially in high profile cases. It was noted 
that it is too costly for many women to get a lawyer 
so cannot access courts. On an individual bases, access 
to justice can be very difficult, cumbersome, and lengthy. 
Another participant noted that the shift of the burden of 
proof onto employers is very important in securing ac-
cess to justice. 

International Organisations Consultation: Partici-
pants noted that in work settings there are particular 
challenges with access to justice and there is a need 
for clear reporting mechanisms and anonymous report-
ing. External complaint mechanisms, such as courts with 
sufficient knowledge, are necessary. Legal advice should 
be available for free. Guidance and information on ac -
cessible resources, also in languages different from the 
main one in the country. One participant noted that the 
shift on the burden of proof as in EU anti-discrimination 

legislation is beneficial. One participant noted that manda-
tory participation in alternative dispute resolution occurs 
such as through a form of deferrals of prosecution with 
the consent of the perpetrator, and not of the victim. 
Concerning access to compensation from the state or the 
perpetrator, shortcomings have been identified in particular 
regarding too short timeframes to claim compensation, 
limitations concerning claims for moral damages (only 
for certain types of crimes but not all), high court fees 
or excessively high thresholds for proof. Steps are were 
discussed to improve reporting, including ensuring non-
disclosure agreements do not prevent reporting, insur-
ance of confidentiality and protection from retaliation and 
re-victimisation.

Written submission to the public consultation:

• 

• 

 United Nations Brussels, Joint Paper (ILO, OHCHR, 
UN Women, UNHCR, UNICEF, UNODC) said it was 
important to ‘Place a high priority on police and justice 
responses’. 

 EIGE: On the point of access to justice, EIGE said ‘a more 
gender-sensitive approach is needed to Victims’ Rights 
Directive and more guidance in this area for Member 
States. They also note a lack of intersectional perspec-
tives and attention to specific groups such as migrant 
women. EIGE notes the importance of individual assess-
ments but challenges in implementation. They also note 
that protection orders are breached in 44% of cases, 
seriously hindering their effectiveness. More perpetra-
tors programmes are needed, including evaluation of 
their effectiveness. 

• 

 Council of Europe Municipalities and Regions men-
tioned achieving access to justice through information 
campaigns and reporting systems.

1.2.4.  Protection

This section outlines views on protection for victims of vio-
lence against women and domestic violence.

60

Annex 2•  Council of Europe Municipalities and Regions mentioned achieving 
access to justice through information campaigns and reporting systems. 

1.2.4  Protection 

This section outlines views on protection for victims of violence against women 
and domestic violence. 

Figure 4: Would further measures be useful to make 
national protection orders more effective in practice?

Targeted Consultation with Member State authori-
ties: when asked ‘Would further measures be useful to 
make national protection orders more effective in prac-
tice?’, 14 Member State authorities responded that they 
Targeted Consultation with Member 
would. Six Member State Authorities (NL, SL, FR, CZ, LU, AT) 
State authorities: when asked ‘Would 
responded in the negative and no response was provided 
further measures be useful to 
by seven Member State Authorities. See Figure 4. 
make national protection orders more 
effective in practice?’, 14 Member State 
NGO Consultation: Participants raised the need for bet-
authorities responded that they would. Six 
ter support and protection provided to victims of domestic 
violence in the post-litigation process to ensure that the 
Member State Authorities (NL, SL, FR, 
victim is free from repeated violence, threats and fear. 
CZ, LU, AT) responded in the negative 
Generally, all participants agreed on the need to increased 
and no response was provided by seven 
resources for issuing emergency barring orders to ensure 
Member State Authorities. See Figure 4.  
more effective police interventions, and a comprehensive 
long-term and multiagency protection for victims.

1.2.5.  Support

Open public consultation: 

Figure 4: Would further measures be useful to 
make national protection orders more effective in 
practice?   

NGO Consultation: Participants raised 
the need for better support and protection 
provided to victims of domestic violence 
in the post-litigation process to ensure 
This section outlines views on support for victims of violence 
that the victim is free from repeated 
against women and domestic violence.
violence, threats and fear. Generally, all 
participants agreed on the need to 
increased resources for issuing 
The public consultation revealed support for further measures 
emergency barring orders to ensure more 
regarding support measure for victims of violence against 
effective police interventions, and a 
women and domestic violence. When asked whether further 
comprehensive long-term and multiagency protection for victims. 
measures should be taken to improve the support to victims 
of violence against women and domestic violence, the major-
ity (77%) believe they should be and at national and EU level. 

Regarding general support services, three quarters of 
respondents (75%) selected that neither they nor those with 
whom they have a close relationship have used them in 
their Member State. Those that selected that they have 
(17%), detailed the services that had been used and the 
most frequently mentioned were social services, followed 
by employment services, health services, psychological or 
counselling services, and anti-violence centres. In response 
to whether general support services systemically account 
for the needs of victims of violence against women and 
domestic violence, 17% believe they do, while the remainder 
either do not know (35%) or do not believe they do (48%). 
In the supplementary open text responses, the focus is 
the limited scope of support, with financial support and 
provision of counselling to victims often missing. Similarly, 
19% of respondents believe general support services do 
take systematic account of the special needs of child vic-
tims/witnesses of domestic violence, and the remaining 
either do not know (35%) or do not believe they do (46%). 

This section outlines views on support for victims of violence against women and 
domestic violence. 

The public consultation also revealed perceived gaps in 
support available. When asked whether support services 
(either general or specialist) are available to victims of 
gender-based and domestic violence in respondent Mem-
ber States. Across all respondents, 64% do understand 
these services to be available. However, for two of the most 
represented countries, Germany and Italy, this proportion 
is substantially higher, at over 82%. Relatedly, nearly seven 
in ten (453 respondents, 67%) of all respondents believe 
that NGOs encounter issues in their work on gender-based 
violence and domestic violence. 

Open public sonsultation:  
The public consultation revealed support for further measures regarding support 
measure for victims of violence against women and domestic violence. When 
asked whether further measures should be taken to improve the support to victims 
of violence against women and domestic violence, the majority (77%) believe 
they should be and at national and EU level.  

1.2.5  Support 

The public consultation also revealed perceived gaps in support available. When 
asked whether support services (either general or specialist) are available to 
victims of gender-based and domestic violence in respondent Member States. 
Across all respondents, 64% do understand these services to be 

available. However, for two of the most represented countries, Germany and Italy, 

this proportion is substantially higher, at over 82%. Relatedly, nearly seven in ten 

(453 respondents, 67%) of all respondents believe that NGOs encounter issues in 

their work on gender-based violence and domestic violence.  

61

Regarding general support services, three quarters of 

respondents (75%) selected that neither they nor those with whom they have a 

9 

Annex 2 
 
 
 
  
Regarding specialist support, 39% of respondents believe 
that general support services do refer victims to appropriate 
specialist services in their Member State. The proportion, 
however, is higher among respondents from Italy and Ger-
many and accounts for over 60% in both cases. In terms 
of specialist support services that are accessible only to 
women victims of gender-based or domestic violence, 54% 
of respondents believe that these are available. However, 
knowledge of services that are accessible to male victims 
is much less (20%). For the special needs of child victims 
and child witnesses of domestic violence, almost 50% of 
respondents do not know if these specialist services sys-
tematically take them into account with supplementary 
open- text responses suggesting inadequacy in this area. 

Regarding support services that account for cultural and 
physical differences, the availability of services without dis-
crimination, such as racial or ethnic origin, is split across re-
spondents (32% believe they are, 35% believe they are not 
and 33% do not know). Responses to whether victims re-
ceive information on support services in a timely manner 
and in a language they understand is also split but with a 
higher preponderance of not knowing (42%). 

International Organisations Consultation: It was noted 
in the consultation with international organisations that 
a gendered understanding of violence is sometimes miss-
ing from support services and too often focus on media-
tion and reconciliation in cases of domestic violence. One-
stop-shop approaches were highlighted as best practice. 
It was also noted there is a need to dissociate access to 
support services from the willingness to report or pursue 
the criminal process. There is a need to invest more in ser-
vices for child witnesses who by witnessing become victims. 
Concerning shelters, prompt access is often lacking, insuf-
ficient funding or geographical coverage, lack of specialised 
personnel. Some countries are overcoming access barriers 
by setting up specialist shelters for women who cannot 
access regular shelters, like women with substance abuse 
or mental disabilities. COVID has negatively impacted the 
services provided and the number of shelters in general 
is insufficient. 

Employer Association Consultation: A focus of the dis-
cussion was on employers’ role in responding to domestic 
violence. Participants felt that it is important that employ-
ers are not made responsible or have obligations related 
to domestic violence as it is beyond their control. There 
are also issues of privacy that victims may not want dis-
cussed at work. One participant drew an analogy with 
health and safety whereby employers are not responsi-
ble for health and safety issues when an employee has 
left the workplace. Participants felt that there is a clear 
separation between the public/work sphere and the private 
sphere. Another employer noted that there are challenges 
implementing existing legislation and adding domestic 
violence might make it more complicated and would lead 
to difficult negotiations. 

Social Partner Consultation: The importance of support-
ing victims of domestic violence and its impact on work 
environments was discussed in the social partners con-
sultation. Examples of concrete measures were discussed 
including 10 days leave for victims and measures in the 
ILO Convention 190. Some participants stressed that what 
happens at home has an impact on the work. This is not 
about encouraging into employees’ private lives but work-
places must be inclusive places so issues can be raised. 
Victims need insurance they will not lose their job. It was 
also noted that violence in the workplace can also lead 
to domestic violence. One participant raised that there is 
evidence of the costs to companies included around absen-
teeism and other costs that would make it in companies 
interest to address it. 

Written submission to the public consultation:

United Nations Brussels, Joint Paper (ILO, OHCHR, UN Wom-
en, UNHCR, UNICEF, UNODC) said it was imperative to ‘Make 
urgent and flexible funding available for women’s rights 
organizations and recognize their role as first responders; 
‘to support health and social services to continue their duty 
of care to VAW survivors and to remain accessible, espe-
cially to those most likely to be left behind’; and to ‘Ensure 
that services for VAWG survivors are regarded as essential, 

62

Annex 2Figure 5: Are additional multi-agency cooperation 
measures needed to ensure a better, coordinated 
cooperation between the actors in charge of prevention, 
protection and support services to tackle harmful 
practices against women? 

remain open and are resourced and made accessible espe-
cially to those most likely to be left behind.’

1.2.6.  Coordination 

Council of Europe Municipalities and Regions called for sup-
porting victims of violence against women and domestic 
violence, including through support that is close to home. 
protection and support services to 
tackle harmful practices against 
women?, over half of Member State 
This section outlines views on coordination mechanisms 
Authorities (14) responded that they are 
related to responding to violence against women and do-
needed to ensure a better, coordinated 
mestic violence.
cooperation between the actors in 
charge of prevention, protection and 
Targeted Consultation with Member State authori-
support services to tackle harmful 
ties: When Member States were asked: ‘Are additional 
practices against women (see Figure 
multi-agency cooperation measures needed to ensure 
5). 
a better, coordinated cooperation between the actors 
Moreover, when asked ‘Could multi-
in charge of prevention, protection and support services 
agency cooperation be strengthened or 
to tackle harmful practices against women?, over half 
would it be useful to set up such 
of Member State Authorities (14) responded that they 
cooperation if not yet established?’ 
are needed to ensure a better, coordinated cooperation 
fourteen Member State Authorities 
between the actors in charge of prevention, protection 
believe that multi-agency 
and support services to tackle harmful practices against 
women (see Figure 5).
cooperation could be strengthened, and 
three Member State Authorities (DE, 
Moreover, when asked ‘Could multi-agency cooperation be 
EL, ES) believe it should be 
strengthened or would it be useful to set up such coopera-
established. Authorities representing 
tion if not yet established?’ fourteen Member State Au-
Czechia and Romania do not believe 
thorities believe that multi-agency cooperation could be 
cooperation can be strengthened. 
strengthened, and three Member State Authorities (DE, EL, 
ES) believe it should be established. Authorities represent-
ing Czechia and Romania do not believe cooperation can 
be strengthened.

Figure 5: Are additional multi-agency cooperation 
measures needed to ensure a better, coordinated 
NGO Consultation: Most participants in the NGO consulta-
cooperation between the actors in charge of 
tion stressed the lack of comparable and comprehensive 
prevention, protection and support services to tackle 
disaggregated data to understand the scale of the prob-
harmful practices against women?  
lem and better identify victims. They are also suggested a 
coordinator be appointed for gender-based violence, as it 
already exists for victim’s rights, as best practice in ensur-
ing coordination between Member State authorities and 
civil society. 

Open Public Consultation: Responses in the public consultation as to whether 
data on gender-based violence and domestic violence is being regularly collected 
showed that views are split: 43% selected that it is, 31% do not know and 26% 
believe it is not). In Hungary 47% are unaware of data collection, whereas in Italy 
and Germany the majority profess knowledge of data collection (69% and 75% 
respectively).  

Open Public Consultation: Responses in the public con-
sultation as to whether data on gender-based violence and 
domestic violence is being regularly collected showed that 
views are split: 43% selected that it is, 31% do not know 
and 26% believe it is not). In Hungary 47% are unaware of 
data collection, whereas in Italy and Germany the major-
ity profess knowledge of data collection (69% and 75% 
respectively). 

NGO Consultation: Most participants in the NGO consultation stressed the lack of 
comparable and comprehensive disaggregated data to understand the scale of the 
problem and better identify victims. They are also suggested a coordinator be 
appointed for gender-based violence, as it already exists for victim’s rights, as best 
practice in ensuring coordination between Member State authorities and civil 
society.  

International Organisations Consultation: To improve 
policy coordination, several participants from international 
organisations noted the need for improve data collection, in-
cluding better disaggregated data and for it to be published. 
It was noted there are also not enough population surveys 
to understand prevalence of violence against women and 
domestic violence. 

International Organisations Consultation: To improve policy coordination, 
several participants from international organisations noted the need for improve 

data collection, including better disaggregated data and for it to be published. It was 

noted there are also not enough population surveys to understand prevalence of 

violence against women and domestic violence.  

63

Written responses to the public consultation  

•  United Nations Brussels, Joint Paper (ILO, OHCHR, UN Women, 

UNHCR, UNICEF, UNODC) said to ‘Collect data only if it is clear that it is 

needed, it will be used to improve services/programmes and ethical and 

safety standards can be met’. 

•  EIGE: It was noted that there are gaps and challenges in the collection of 

comparable and reliable data.  

12 

Annex 2 
 
 
 
 
Written submission to the public consultation:

• 

 United Nations Brussels, Joint Paper (ILO, OHCHR, 
UN Women, UNHCR, UNICEF, UNODC) said to ‘Collect 
data only if it is clear that it is needed, it will be used to 
improve services/programmes and ethical and safety 
standards can be met’.

• 

 EIGE: It was noted that there are gaps and challenges 
in the collection of comparable and reliable data. 

1.2.7.  Particular Groups / Types of Violence against 
Women and Domestic Violence

This section highlights views on particular groups of victims 
and type of violence. Various groups were highlighted in 
the consultation including women living a disability, child 
witnesses and victims and migrants and asylum-seeking 
women victims. This section focuses on online violence 
against women and LGBTI victims as these received re-
peat mentions in the consultations, particular in written 
responses to the public consultations. 

1.2.7.1.  Online violence against women and domestic 
violence

Social partner consultation: The issue of online violence 
was discussed in the consultation with social partners. It 
was noted that online harassment is increasing and taking 
new forms, including ‘deep fakes’. It was considered that 
more action is needed including training and encourage-
ment to report online violence, user friendly tools to report 
and flag online content, a national media regulatory. It was 
noted that certain professions are more at risk, such as 
female journalists. 

procedures both online and to the police. Challenges were 
also raised about what should be included in the definition 
and scope of online violence.

Written submission to the public consultation:

• 

• 

• 

 EBU, Operating Eurovision and Euroradio: EBU 
raises concern that women journalists and media pro-
fessionals face gendered-based online violence aimed at 
discrediting and humiliating them in order to ultimately 
silence them. Many women journalists have encountered 
online attacks based on their origin, minority affiliation, 
disabilities, religion, etc. Patterns from different surveys 
suggest online attacks against women journalists and 
media professionals are more common than online at-
tacks against their male counterparts, are exponentially 
growing and have been exacerbated by the COVID-19 
pandemic. 

 EIGE: EIGE noted that the prevalence on online violence 
against women is high and it has not been full concep-
tualised or legislated against at EU level. 

 HateAid (Germany): HateAid is a NGO based in Ger-
many that focuses on online violence. It includes the 
following recommendations in its written response to 
the public consultation:

1)   Acknowledge that digital violence against women is 

psychological violence

2)   Create nationwide consultation and support networks 

for women 

3)   Raise awareness in public service and installation 

of contact persons for women

4)   Create low-threshold options to act against digital 

violence

International Organisations Consultation: Online vio-
lence was considered a new field that is not explicitly cov-
ered in current legislation at EU and international level. One 
participant in the consultation said that more regulation of 
the media and internet service providers is needed – in bal-
ance with the freedom of expression - and more reporting 

5)   Enable law enforcement and litigation, creation of 

legal certainty

6)   Conduct studies and creation of statistics on digital 

violence against women 

7)   Hold online platforms liable for their handling of 

illegal content and protection

64

Annex 21.2.7.2.  LGBTI Victims

Written submission to the public consultation:

• 

 OII Europe: The EU-level NGO called for the inclusion 
of comprehensive and explicit protection of intersex 
people in any legislative proposal that aims to prevent 
and combat specific forms of gender-based violence 
and domestic violence. It also called for the inclusion 
of the harmful practice of intersex genital mutilation 
(IGM) as a form of gender-based violence in any of 
such proposals.

• 

 TransGender Europe (TGEU): The NGO offered the 
following recommendations: 

1)   Use a definition for gender-based violence that is 
inclusive of gender identity and gender expression.
2)   Fully implement all relevant EU legislation, policies 
and strategies, in a way that is inclusive of trans 
people.

3)   Set a standard for Member States by advancing 
trans-inclusivity in other legislation and policies.
4)   Monitor and support Member States in the imple-
mentation of gender-based violence and domestic 
violence legislation and measures that are inclusive 
of trans people.

5)   Include trans people in data collection mechanisms 

on gender-based violence.

• 

 ELC (Euro-central-asian lesbian community): ELC 
notes an increase in violence against lesbians, from 
cyber-harassment to “corrective rapes” and femicides. 
The situation is further complicated by the rise of the 

nationalist, far-right and anti-gender movements as 
well as by the Covid-19 pandemic, enhancing the risk of 
attacks and backlash against women and LGBTI people 
as well as the exposure to domestic violence. This ex-
posure to violence makes it crucial that lesbian needs 
and interests are adequately and explicitly addressed 
risking other ways to “fall through the cracks” of dif-
ferent policies and measures. In order to completely 
tackle this phenomena, and in line with the intersectional 
approach chosen by the European Commission in its 
Strategies on Gender Equality and LGBTIQ Equality, it 
is particularly important to take into consideration the 
specific positions of non-heterosexual women, be they 
cisgender, trans or intersex. Data and cases, mentioned 
further in this document, show that lesbians are victims 
of gender based and domestic violence because they 
are exposed to lesbophobia, a powerful conglomerate 
of sexism, misogyny and homophobia. 

• 

 Young Feminist Europe: Young Feminist Europe called 
for a wider definition of gender-based violence that 
includes violence against transgender or gender-non-
conforming people. It argues that the focus on domes-
ticity steals attention away from violence in the public 
realm. Intersectional approach must become a standard 
in analysis of gender-based violence and interventions 
against it. More disaggregated and intersectional must 
be collected and shared e.g. data that makes visible the 
experiences of women and girls belonging to minority 
groups and data beyond gender binary parameters. More 
data should also be collected about perpetrators, in 
order to better understand and prevent male violence, 
as well as about online manifestations of gender-based 
violence. 

65

Annex 2Annex 3.  Who is affected and how?

Summary of costs and benefits

The tables below present the costs and benefits associ-
ated with the preferred Policy Option, Policy Option 2a 

(“comprehensive policy option”). Benefits are mainly in the 
form of direct costs savings across Member State authori-
ties and individual victims. Costs were mainly identified for 
national authorities and include one-off and recurring costs.

I. Overview of Benefits (total for all provisions) – by policy option

Description

Amount

Comments

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

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

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

Cost reductions are estimated to be EUR 
8.1 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 12.2 (Scenario 2) in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)
Cost reductions are estimated to be EUR 
2.5 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 3.8 (Scenario 2)  in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)
Cost reductions are estimated to be EUR 
7.2 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 13.7 (Scenario 2) in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)

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

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

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

66

Annex 3I. Overview of Benefits (total for all provisions) – by policy option

Description

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

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

Reduction in costs of vio-
lence against women and 
domestic violence
(Personal costs)

Reduction in costs 
of violence against 
women and domestic 
violence(Specialist ser-
vices)

Reduction in costs of vio-
lence against women and 
domestic violence
(Physical/emotional 
impacts)

Amount
Cost reductions are estimated to be EUR 
0.2 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 0.4 (Scenario 2) in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)
Cost reductions are estimated to be EUR 
2.1 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 3.1 (Scenario 2) in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)
Cost reductions are estimated to be EUR 
0.6 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 1.0 (Scenario 2) in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)
Cost reductions are estimated to be EUR 
0.2 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 0.3 (Scenario 2) in the longer-term 
i.e. 10 years after implementation.

(Please note that all figures are rounded 
to the nearest million)
Cost reductions are estimated to be EUR 
32.2 billion (Scenario 1) in the shorter-
term i.e. 5 years after implementation and 
EUR 48.4 (Scenario 2) in the longer-term 
i.e. 10 years after implementation. 

(Please note that all figures are rounded 
to the nearest million)

Comments

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

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

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

These reductions in costs would accrue 
to national authorities as a result of a 
reduction in the costs incurred for services 
such as refuges, telephone helplines, victim 
support centres, counselling and advocacy 
due to lower prevalence of violence against 
women and domestic violence.

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

Indirect benefits
None quantified, see Annex 4

67

Annex 3II. Overview of costs (by policy measure) – Preferred option (in EUR)

Measure

Recurring

Minimum

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

Direct costs

4,005,000

Indirect costs n/a

Direct costs

134,000

Indirect costs n/a

Maximum

8,546,000

n/a

134,000

n/a

One-off

n/a

n/a

n/a

n/a

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

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

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

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

2.2 Obligation on MS to conduct risk as-
sessments speedily and in cooperation with 
support services. 

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

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

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

68

Direct costs

25,857,000

25,857,000

1,816,000

Indirect costs n/a

n/a

n/a

Direct costs

1,893,919,000 

 1,893,919,000

605,000

Indirect costs n/a

n/a

Direct costs

3,696,000

25,175,000

Indirect costs n/a

n/a

Direct costs

46,855,000

46,855,000

Indirect costs n/a

n/a

Direct costs

718,971,000

1,942,604,000

Indirect costs n/a

n/a

Direct costs

326,459,000

326,459,000

Indirect costs n/a

n/a

Direct costs

2,027,000

2,027,000

Indirect costs n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Annex 3 
II. Overview of costs (by policy measure) – Preferred option (in EUR)

Measure

Recurring

Minimum

3.3 Right of victims to obtain full compensa-
tion from the perpetrator in one single proce-
dure and within adequate time limits.

Direct costs

n/a

Indirect costs n/a

Maximum

n/a

n/a

One-off

n/a

n/a

Direct costs

138,589,000

502,045,000

13,576,000

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

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

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

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

Indirect costs n/a

n/a

Direct costs

627,091,000

627,091,000

Indirect costs n/a

n/a

Direct costs

1,159,566,000

1,159,566,000

Indirect costs n/a

n/a

Direct costs

357,000

357,000

Indirect costs n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

5.2 Obligatory participation in surveys coordi-
nated at EU-level

Direct costs

16,835,000

16,835,000

Indirect costs n/a

n/a

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

Direct costs

137,000

137,000

152,000

Indirect costs n/a

n/a

n/a

Total costs for preferred policy option

4,964,499,000 

6,577,608,000 16,149,000

Note: Please note that estimates have been reported to the nearest thousand.

69

Annex 3 
Annex 4.  Analytical methods

1.  General

For the assessment of the policy options and policy meas-
ures, the following main baseline assumption has been 
made:

1. 

2. 

 No actions are taking place at the moment where there 
is no robust evidence of them77.

 For the purpose of administrative costing, it is assumed 
that the costs incurred due to the policy option are 
additional to the baseline.

3. 

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

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

4. 

1. 

2. 

 Firstly, the cost items associated with each policy 
measure were assessed, considering the type of cost 
(i.e., one-off or recurring), and, in the case of Member 
States, how many of these were likely to be impacted 
by the measure/change.

 For each cost item, estimates for the value of the cost 
were developed. Further details on how each type of 
cost item was estimated are set out below. Overall, es-
timates and assumptions were based on a combination 

of several factors, including publicly available data (see 
each measure for details on sources) and the study 
team members’ experience of conducting similar quan-
tification exercises. 

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

 For cost reductions (economic benefits), estimations 
were based on figures on the overall cost of violence 
against women and domestic violence78 (i.e., the overall 
potential for cost reduction of violence against women 
and domestic violence associated with all policy meas-
ures under each policy option). This is because there is 
a lack of evidence and available data on the potential 
for cost reduction thought to be associated with each 
policy measure. On the basis of a review of studies on 
the economic impact of policy measures on combatting 
and preventing violence against women and domestic 
violence, economic benefits of the policy options were 

77  Evidence for current actions was available for the following measures: 1.2 Work with perpetrators; 2.1 Protection orders; emergency barring 

orders; 2.2 Risk assessment and management; 2.3 Special measures for the protection of children in the context of domestic violence; 3.3 Victim 
compensation; 4.1 Specialised support, shelters and helplines.

78  Estimation of the costs of gender-based violence in the UK case study and extrapolation to EU Member States (forthcoming EIGE paper, 2021).

70

Annex 4considered to be generated due to a decrease in the 
prevalence of violence against women and domestic 
violence. Moreover, due to lack of evidence quantifying 
the causal link between prevalence and the full set of 
measures under each policy option, three hypothetical 
scenarios were assumed.

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

Assumptions used:

3.  Estimation of administrative 
and compliance costs

Estimation of costs of prevention

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

The estimation of this measure is based on the cost of a 
general and targeted awareness raising campaign.

The following calculations are used, for each Member State:

Cost = twice yearly x (budget for general awareness 
raising + budget for targeted awareness raising campaign)

1.2.  Obligation on MS to make available voluntary per-
petrator programmes to all those at risk of offending and 
mandatory programmes for re-offenders in Option 2a, and 
for all offenders in Option 2b.

The estimation of this measure is based on the cost pro-
viding a series of sessions (online or face-to-face) to each 
perpetrator.

The following approach is used, for each Member State:

Cost =  Number of perpetrators  

x (hourly compensation for health and social 
worker x 6 sessions per year)

—   6 one-on-one sessions of 1 hour of health and social 
worker support provided per perpetrator with no set-
up costs

—   the compensation of social and health workers equals 
the European average for Member States with miss-
ing data

—   no Member State currently provides sufficient perpetra-
tor intervention and treatment programme, but the costs 
would be lower for countries that have a programme in 
place. The total cost is discounted by 50% for Member 
States that have a perpetrator programme in place in 
the baseline79

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

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

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

1. 

 Online training on violence against women and do-
mestic violence to professionals dealing with victims 
or perpetrators & professionals working with victims of 
violence against women and domestic violence

2. 

 Equipment of law enforcement and judicial authorities 
with specialized resources/training to prosecute online 
violence against women and domestic violence

79  Based on the study’s mapping of baseline situation 

71

Annex 4For training on violence against women and domestic vio-
lence, the following approach is used, for each Member State:

Cost =  two hours per year  

× (number of police officers × %attend × police officer salary per hour  
+ number of prosecutors × %attend × prosecutor's salary per hour  
+ number of lawyers × %attend × lawyer's salary per hour  
+ number of judges × %attend × judge's salary per hour) 
+ cost of developing two training sessions

For training on online violence against women and do-
mestic violence, the following approach is used, for each 
Member State:

Cost =  two hours per year  

× ( number of cases reported

number of cases per official  

× police officer salary per hour  

+ number of prosecutors required × prosecutor's salary per hour  
+ number of judges required × judge's salary per hour) 
+ fixed cost of developing a training session

Number of cases report =  population of females 15 to 64 

× proportion with personal experience with online violence 
× proportion reporting such experience to an online platform

Assumptions used:

—   the assessment of the baseline finds that all Member 
States have some form of awareness-raising in place. 
Therefore, we assume an additional 2 general cam-
paigns and 2 additional targeted campaigns are needed 
per year needed to ensure regular campaigns
—   selected officials attend a 2-hour training session
—   the assessment of the baseline did not find information 
hours of trainings provided or the presence of tailored 
training on violence against women and domestic vio-
lence or online violence against women and domestic 

violence, therefore we assume that all Member States 
incur additional costs

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

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

72

Annex 4The estimation of this measure is based on the cost for 
managers to attend a training course on violence against 

women and domestic violence in the workplace. The fol-
lowing calculation is used, for each Member State:

Cost =  Number of managers per large employer and, or SME 

× (hourly compensation for managers × 2 hours attended per year)  
× (Number of SMEs or large enterprises) 
+ Cost of developing one online training session

Number of managers per large enterprised and, os SME = 

= 

number employed in large enterprises and, or SMEs

number of large enterprises and, or SMEs

× 

1

10

Assumptions used:

Estimation of costs of protection

—   all managers attend a 2-hour training session
—   one manager per 10 employees
—   costs of awareness-raising and information provision 
on gender-based work harassment at governmental, 
social partners’ and company levels would already be 
covered by 1.1b and 1.1c

—   negligible cost of development of policies on anti- har-
assment and risk assessments at governmental, social 
partners’ and/or employer level

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

2.1.  Obligation on MS to ensure efficiency through mini-
mum standards on the issuance, conditions and enforce-
ment of emergency barring orders and protection orders.

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

The following approach is used, for each Member State:

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

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

Number of women victims of sexual violence =

= population of females 15 to 64 
× prevalence of physical violence against a woman 
× rate of physical violence that was of sexual nature

73

Annex 4 
Number of women victims of physical violence = 
= (population of females 15 to 64 
× prevalence of physical violence against a woman) 
- Number of women victims of sexual violence

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

Assumptions used:

—   due to lack of comparable data on the number of 
women victims of violence against women and domes-
tic violence by Member State, a minimum and maxi-
mum estimate of women victims of violence against 
women and domestic violence is used based on FRA 
2020 survey results 

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

—   relative unit cost of a protection order is constant across 

Member States and there are no set-up costs

—   no Member State issues a sufficient number of protec-
tion orders on violence against women and domestic 
violence but costs would be lower for Member States 
that have the possibility to apply for protection orders. 
Therefore, the total cost is discounted by 50% for Mem-
ber States where emergency protection orders are avail-
able in the baseline, and by 25% for Member States 
where they are partially available in the baseline80 
—   each Member State incurs an additional 10% of total 
costs to increase efficiency and ensure timely issuance 
and more effective enforcement

2.2.  Obligation on MS to conduct risk assessments speed-
ily and in cooperation with support services. 

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

—   application rate is constant across Member States 

The following approach is used, for each Member State:

Cost =  Number of women victims of physical violence that reported the crime 
× hourly compensation of policy officer × (one hour for screening  
+25% × (two hours for in depth assessment 
+ half an hour to coorperate with support services))

 Number of women victims of physical violence that reported the crime = 
= population of females 15 to 64 
× prevalence of physical violence against a woman 
× proportion of women that report the crime to the police

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

80  Based on study’s mapping of baseline situation 

74

Annex 4 
Assumptions used:

—   due to lack of comparable data on the number of women 
victims of violence against women and domestic vio-
lence by Member State, the estimate of victims eligible 
for risk assessment is based on the broader category 
of all women victims of physical violence

—   screening requires one hour, an in-depth assessment 
requires two-hours, and cooperation with victim support 
services required half an hour 

—   25% of women victims qualify as high risk i.e., for in-
depth assessment and referral to victim support services

—   no set-up costs
—   no Member State provides sufficient levels of individual 
risk assessment, but the cost is lower for Member States 
that carry out such assessments. Therefore, the total 
cost for Member States is discounted by 50% for Mem-
ber States that carry out individual risk assessments 
in the baseline, and by 25% for Member States that 
partially carry out such assessments in the baseline81

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

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

The following approach is used, for each Member State:

Cost =  number of chid witnesses × 29 hours 

× hourly compensation of health and social 
workers

Number of child witnesses = 
=  population under 15 years × prevalence of child 

maltreatment 
× rate of co occurrence of child abuse and domestic 
violence

Assumptions used:

—   based on 2-hours of health and social worker support 
per child/ week for 3 months, and an additional hour 
per month for three months to maintain contact. The 
total is 29 hours per case82

—   rate of co-occurrence of child abuse and domestic vio-

lence is constant across Member States

—   no set-up costs
—   no Member State provides sufficient levels of support to 
child witnesses, but costs would be lower for Member 
States that have support services in place to account 
for the special needs of child witnesses of domestic 
violence. Therefore, the cost of support for Member 
States is discounted by 50% for Member States where 
such services are available in the baseline, and by 25% 
for Member States where such services are partially 
available83. For Member States (FR, HU, LI, MT) with 
no information available on the baseline, partial avail-
ability is assumed.

—   no Member State provides services for maintaining 
contact with child witnesses and therefore all Member 
States incur full costs to provide this service

Estimation of costs of access to justice

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

81  Based on study’s mapping of baseline situation 

82  2 hours per week x 4.345 weeks per month x 3 months) + (1 session 

a month x 3 months) = 29 hours per case
83  Based on study’s mapping of baseline situation 

75

Annex 4The estimation of this measure is based on the cost for 
Member States to allow online/other low threshold reporting 
of incidents of online violence against women and domestic 
violence to national law enforcement or other authorities. 

The following calculation is used, for each Member State:

Cost = 

number of cases reported under a low threshold

number of cases per official

× compensation for police officers per hour 
× 2080 hours in a working year

Number of cases reported under a low threshold = 
=  population of females 15 to 64 

× percentage with personal experience with online 
violence 
× proportion reporting such experience to an online 
platfomr

violence against women and domestic violence as a new 
EU crime under Option 2b.

The total investment required for criminal definitions is 
assumed to be negligible as there are likely to be low ad-
ministrative costs to change national and EU legislation 
and several Member States already have laws in place 
criminalising various forms of violence against women and 
domestic violence.

However, costs would be incurred to ensure legal standing 
to equality bodies to assist and represent violence against 
women and domestic violence, incl. online violence against 
women and domestic violence, victims in line with COM 
Rec on equality.

The following approach is used, for each Member State:

Cost = (additional FTEs required  
× mean earnings of staff in equality bodies)

Assumptions used:

—   constant reporting and prevalence of online violence 
against women and domestic violence across Member 
States

—   low threshold would translate into reporting of online 
violence against women and domestic violence to police 
instead of platforms

—   no set-up costs
—   cost of training covered by Measure 1.3
—   the assessment of the baseline did not find informa-
tion on comparable measures in place, therefore it is 
assumed that all Member States incur full costs

3.2.  Additional approximation of criminal definitions and 
sanctions on the basis of the legal bases of computer 
crime (ICT-facilitated cyber violence), sexual exploitation 
(certain forms of sexual violence), and serious forms of 
sexual harassment under Option 2a; and introduction of 

Assumptions used:

—   2 additional FTEs required per Member State to as-
sist and represent victims of violence against women 
and domestic violence including online violence against 
women and domestic violence

—   no set-up costs
—   for countries with no data, assume average salary 

across 23 countries with data 

—   no costs for Member States where equality bodies al-
ready have a legal standing to receive violence against 
women and domestic violence complaints or claims or 
sexual harassment and harassment based on sex
—   for Member States where either equality bodies cannot 
receive violence against women and domestic violence 
complaints or cannot receive claims of harassment, 
additional FTE’s are needed. For Member State with 
no information on the baseline (SI), it is assumed that 
equality bodies have no legal standing and hence, full 
costs are incurred

76

Annex 4 
3.3.  Right of victims to obtain full compensation from the 
perpetrator in one single procedure and within adequate time 
limits under Option 2a, and obligation on MS to provide state 
compensation in cases where victims cannot obtain compen-
sation from the perpetrator or other sources under Option 2b.

The estimation of this measure is based on the cost of pro-
viding access to compensation for victims of online serious 
gender-based harassment. It is assumed that bodily injury 
and impairment of health and meaningful compensation 
to violence against women and domestic violence victims 
are covered by the baseline scenario, as current EU law 
already requires States to provide such compensation for 
violent intentional crimes.

The following approach is used, for each Member State:

Cost = (number of women reporting online violence

+ number of women reporting gender based 
harassment
× proportion of women that apply for compensation 
× 50% × amount of state compensation awarded)

Number of women reporting online violence = 
=  population of females 15 to 64  

× percentage who personally experienced online 
violence 
× percentage that reported to online platform

Number of women reporting gender based harassment  
=  (population of females 15 to 64  

× percentage who personally experienced 
harassment 
× percentage reporting harassment incidents)

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

Assumptions used:

—   the number of women experiencing harassment or dis-
crimination is used as an estimate of the number of 
victims serious gender-based harassment

—   no set-up costs
—   limited to costs for the state. Obligation of the future 
directive for States to pay compensation in those situ-
ations where the victim is not able to recover such 
compensation from the perpetrator or other sources. It 
is assumed the state pays in 50% of the cases

—   negligible costs are incurred to inform victims of violence 
against women and domestic violence about the pos-
sibility to request compensation from the perpetrator 
and to provide a decision in a reasonable time

Estimated costs of victim support

4.1.  Obligation on MS to facilitate access to specialised 
support services to groups at risk, such as children, migrant 
and asylum-seeking women and women with disabilities, 
and to connect national helplines to EU-level helpline under 
Option 2a; and obligation on MS to provide 1 shelter space 
for 10,000 inhabitants under Option 2b.

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

1. 

2. 

3 

 Specialized support, based on the cost of ensuring 
availability of specialist women’s support services to 
all women victims of violence and their children and 
groups at a heightened risk of violence (such as migrant 
women, victims from minority communities, women 
with disabilities, women working in the sex industry 
and women prisoners)
 Shelters, based on the cost of providing an additional 
10% of refuge spaces needed (2A) and all spaces 
needed i.e., one refuge space per 10,000 population 
(2B) for women victims of violence against women and 
domestic violence and their children
 Helplines, based on the cost of setting-up and operating 
state-wide 24/7 helpline free of charge for victims of 
violence against women and domestic violence 

77

Annex 4For specialized support, the following calculation is used, 
for each Member State:

Cost = (annual government expenditure for specialist 
services for sexualised violence

× percentage of missing services for survivors of 
sexualised violence) × 1.1

Note that costs where not estimated for three Member 
States (RO, SI, SE) with missing data on the proportion of 
missing services and therefore the total costs might be 
higher than estimated.

Assumptions used:

—   due to lack of data available on Member State expendi-
ture on specialist support services for women victims 

of violence against women and domestic violence and 
their children, the annual UK expenditure adjusted by 
relative population size of UK and each EU Member 
State is used
—   no set-up costs
—   the expenditure needed is a function of the percent-
age of missing expenditure on survivors of sexualised 
violence

—   all Member States need an additional 10% of total 
expenditure to ensure availability of services to groups at 
heightened risk

For shelters, the following calculation is used, for each 
Member State:

Cost = (Additional beds needed × (0.1) × unit cost of a refuge space per year) 

+ (

Additional beds needed
Average capacity per shelter   

× expenditure needed to establish a shelter)

Additional beds needed  

+ ( Population on 1st January 2020

10,000

- existing number of beds in shelters)

Assumptions used:

due to lack of available data, it is assumed that the ex-
penditure needed to establish a shelter is the same across 
all Member States

the encouragement of shelter provision (2A) would lead to 
10% of additional beds provided and obligation to provide 
shelters in line with CoE recommendation (2B) would lead 
to all additional beds provided

the requirement for 1 space per 10,000 population would 
be sufficient to provide safe accommodation to all women 
victims of violence against women and domestic violence 
and their children that need it for Member States (CY, EE, 
LV, LU, MT, SI) that exceed or meet the requirement for 
1 space per 10,000 population in the baseline, no costs 
are incurred

78

Annex 4  
For helplines, the following calculation is used, for each 
Member State:

3. 

Cost = (budget needed to establish a helpline  
+ budget needed to operate a helpline per year)

 Effective remedies in cases of sexual harassment at 
work, based on the cost to all employers including SMEs 
(2B) and only large employers with over 250 employ-
ees (2A) to have an internal company reporting and/
or dispute resolution mechanism

Assumptions used:

For victim support – special leave, the following calcula-
tion is used, for each Member State:

—   due to lack of available data, it is assumed that the 
budget needed to establish a helpline is the same across 
all Member States

—   for Member States (AT, BG, CY, DK, EE, FI, DE, EL, IE, IT, 
LT, RO, SK, ES, SE) that have 24/7 toll free helpline in 
place for victims of violence against women and do-
mestic violence 84, no additional costs are incurred to 
set-up and operate the national helpline

—   negligible cost of setting-up a harmonised EU helplines 

and no costs to run a harmonised EU helpline

4.2.  Obligation on MS to provide specific support to victims 
of sexual harassment at work (including medical care and 
complaint mechanisms) under Option 2a, and obligation on 
MS special compensated leave for workers victim of violence 
against women and domestic violence under Option 2b.

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

1. 

2. 

 Victim support – special leave, based on the cost, which 
falls on companies, of the obligation for MS to provide 
three days of special leave compensated at the level 
of sick leave for all victims of violence against women 
and domestic violence 
 Support to victims of sexual harassment at work, based 
on the cost of ensuring that medical care and counsel-
ling services are available to all victims of work-based 
harassment and that victims are informed about the 
relevant services

84  Based on information available from WAVE annual report (2018) on 

national women’s helplines in EU MS meeting the standard of the 
Istanbul Convention. 

Cost = 3 × Average daily compensation for women 
16 to 64

× (Number of women victims of sexual violence 
+ Number of women victims of physical (excl. 
sexual) violence)

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

Assumptions used:

—   due to lack of comparable data on the number of women 
victims of violence against women and domestic vio-
lence by Member State, the estimate of victims eligible 
is based on the broader category of all women victims 
of physical violence

—   three-day leave is implemented in all MSs
—   level of sick leave compensation set at 100% of pay
—   negligible cost of issuing guidelines
—   no set-up costs

For support to victims of sexual harassment at work, 
the following calculation is used, for each Member State: 

Cost = health staff time needed per year per large 
enterprise and, or SME

× Hourly earnings for health staff 
× number of large enterprises and, or SMEs

79

Annex 4 
Health staff time needed per year per large enterprise and, or SME

= employment per large enterprise and, or SME 
× percentage of females in total employment 
× of female employees subject to work based harassment in the past 12 months × 2 – hours

Assumptions used:

—   proportion of female employees is constant across dif-

ferent business sizes

—   no set-up costs
—   for countries with 0% prevalence reported i.e., BG & RO, 

—   for countries with 0% prevalence i.e., BG & RO reported, 

prevalence rate of EU-27 average is assumed

assume prevalence rate of EU-27 average

—   each reported case of gender-based work harassment 

is dealt with two-hour sessions

—   the assessment of the baseline did not find information 
on comparable measures in place; therefore, it is as-
sumed that all Member States incur full costs

—   obligation on companies to provide information on rem-
edies external to the company (judicial remedies, equal-
ity bodies, etc.) can be covered by managers’ training 
under Measure 1.4 at a negligible cost

—   Collective complaints in cases of gender-based work 
harassment can also be covered by managers’ training 
under Measure1.4 at a negligible cost

For effective remedies in cases of sexual harass-
ment at work, the following approach is used, for each 
Member State: 

—   the assessment of the baseline did not find information 
on comparable measures in place; therefore, it is as-
sumed that all Member States incur full costs

Cost = HR staff time needed per year per large 
enterprise and, or SME

× hourly earnings for HR staff 
+ number of large enterprises and, or SMEs

HR staff time needed per year per large enterprise 
and, or SME  
= employment per large enterprise and, or SME

× percentage of females in total employment 
× percentage of female employees subject to 
work based harassment in the past 12 months 
× 2 – hours

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

The estimation of this measure is based on the cost of pro-
viding on- and offline support for victims of online violence 
against women and domestic violence.

The following approach is used, for each Member State:

Cost = six hours per year

× (number of cases reported 
× health and social worker staff  salary per hour)

Assumptions used:

—   no set-up costs
—   each HR staff requires 2 hours to handle one case
—   HR staff can work across companies but not across 

countries

Number of cases reported = 
=  population of females 15 to 64  

× proportion with personal experience with online 
violence 
× proportion reporting such experience to an online 
platform

80

Annex 4Assumptions used:

—   no set-up costs
—   each reported case of online violence against women 
and domestic violence is dealt with 6 one-hour sessions
—   on-line support is already covered under the helplines 

in Measure 4.1

—   the assessment of the baseline did not find information 
on comparable measures in place; therefore, it is as-
sumed that all Member States incur full costs

5.2.  Obligatory participation in surveys coordinated at 
EU-level

The estimation of this measure is based on the cost of 
participating in a centralised survey on violence against 
women and domestic violence at the EU-level. The following 
calculation is used, for each Member State:

Cost = cost per interviewee × sample size of survey

Estimated costs of coordination

Assumptions used:

5.1.  Obligation to provide one-stop online access to rel-
evant protection and support services, and encouragement 
(2a) or obligation (2b) to locate multi-agency support ser-
vices in the same premises.The estimation of this measure 
is based on the cost of the obligation for MS to provide 
multi-agency and multi-disciplinary one-stop access to rel-
evant protection and support services in the same premises. 
The following approach is used, for each Member State:

—   the costs to participate in an EU-level survey on violence 
against women and domestic violence represents a new 
cost to all Member States and therefore, all Member 
States would incur costs every two-years

—   assumed cost of €100 per interviewee includes all costs 
that would need to be incurred by Member States
—   for countries with no data on sample size, an average 

across all countries is assumed

Cost = number of employees needed 

× annual salary of health and social workers

Number of employees is set at 4 by default. To match 
population differences, this is increased by 1 employee for 
every 2 million females aged 15 to 6485 (when the female 
population is above 10 million)

Assumptions used:

—   minimum of four staff members needed for informa-

tion centre

—   employees compensated at the level of “health and 

social workers”

—   assuming 52 40-hour weeks every year
—   no set-up costs

85  Eurostat, Population on 1st January 2020 [demo_pjanbroad] 

5.3.  Obligation to regularly collect disaggregated relevant 
administrative data in line with a number of harmonised mini-
mum requirements under Option 2a, and an integrated central-
ised data collection system at national level under Option 2b.

The estimation of this measure is based on the cost of con-
ducting administrative data collections at regular intervals 
meeting ICCS standards. The following calculation is used, 
for each Member State:

Cost = Costs to fill national questionnaires per year
+ costs of changing the national data collection 
system 
+ cost of maintaining central database on 
admin data

Cost = Costs to fill national questionnaires per year 
= hourly cost to fill questionnaire × 360

81

Annex 4Assumptions used:

—   the assessment of the baseline did not find information 
on national administrative data collection based on ICCS 
standards; therefore, it is assumed that all Member 
States would incur this cost

—   due to lack of available data on number of hours 
required to change a data collection system and to 
complete questionnaires on administrative data, it is 
assumed that they require 120 hours each and that 
three administrative data collections would be required 
in a year

—   Personal costs to individual victims of moving homes 
due to divorce related to gender-based violence and 
to self-fund legal proceedings for separation from a 
violent partner

—   Specialist services costs to national authorities related 
to refuges, telephone helplines, victim support centres, 
counselling, and advocacy

—   Physical and emotional impacts to individual victims 
due to negative impacts of the crime on quality of life

The calculation of cost reductions was made using the 
formula below:

4.  Estimation of cost reductions 
(economic benefits)

Cost reduction = cost of VAW/DV by cost category  
× % reduction in prevalence

The overall costs of violence against women estimated 
to be €290 billion by EIGE were used for the costs in the 
status quo. The estimated reduction in costs was calculated 
for each of the cost categories measured by EIGE which 
includes86:

—   Lost economic output to individual victims measured 
in lost earnings due to time taken off work and lost 
productivity

—   Health services costs to national authorities as victims 
of gender-based violence make use of health services 
for treatment of physical and mental harms

—   Criminal justice system costs to national authorities 
due to involvement in investigations and prosecutions 
of gender-based violence

—   Civil justice system costs to national authorities to pro-
vide legal aid to victims of gender-based violence to 
separate from a violent partner

—   Social welfare costs to national authorities to provide 
housing aid and child protection to victims of gender-
based violence

The following assumptions were made for the calculation:

—   Two scenarios, for each of the sub-options, were con-
sidered for the percentage reduction in prevalence: 20% 
reduction and 30% reduction (2a) and 22% reduction 
and 32% reduction (2b). The scenario’s build on the 
European Parliament’s assessment of the added value 
of Gender-based violence as a new area of crime listed 
in Article 83(1) TFEU87. The assessment assumed that 
the prevalence of GBV will decrease by 10% in the 
short-term (about five years) and 20% – 30% in the 
long-term (about 10 years) after an EU–wide legisla-
tion is introduced. 

—   Given that this policy option 2b includes additional 
measures for support to victims of violence against 
women and domestic violence and for prevention, the 
reduction in prevalence was assumed to be greater 
than that estimated by the European Parliament’s as-
sessment.  For example, based on an assessment of 
the US National Crime Victimization Survey (NVCS), 
the use of victim services was shown to be associated 

86  Estimation of the costs of gender-based violence in the UK case 
study and extrapolation to EU Member States (forthcoming EIGE 
paper, 2021)

87  https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662640/

EPRS_STU(2021)662640_EN.pdf 

82

Annex 4with a 40 percent reduction in the risk of repeat 
victimisation88.

The following sources and assumption were used for the 
above calculation:

—   The reduction in costs is proportionate to the decrease 
in prevalence of violence against women and domestic 
violence under each scenario. 

—   For the criminal and civil justice system, there are 
counteracting economic impacts of an increase in costs 
due to increased reporting of violence against women 
or domestic violence and a decrease in costs due to 
the reduction in prevalence. The assumed change is 
therefore a lower proportion compared to the other 
cost categories. 

To estimate the percentage reduction for the criminal justice 
system and civil justice system, calculations were made 
using the formula below which is used by the European 
Parliament’s assessment89:

% reduction in prevalence = (1 + % change in 
prevalence) × (1 + % change in reporting) – 1

—   The measures under this policy option (e.g., criminalisa-
tion, awareness-raising, information provision to victims 
of violence against women and domestic violence and 
encouragement of reporting of VAW/DV by witnesses and 
professionals) is likely to lead to an increase in reporting 
of violence against women and domestic violence  cases. 
This change in reporting rates would likely lead to higher 
costs for the criminal and civil justice system. 

—   The change in reporting rates is assumed to be 10% 
for option 2a. This assumption is based on a European 
Parliament study90 which estimates that an EU Directive 
on gender-based cyberviolence could increase report-
ing rates by 5% to 10%. Given that this policy option 
includes measures beyond EU-level criminalisation, the 
higher bound of 10% is used. 

—   Given that reporting rates might increase further due 
to additional support measures in 2b, the reporting rate 
is assumed to be 12.5% for option 2b.

—   The increase in reporting rates is assumed to be the 

same in the two scenarios for option 2a and 2b.

Ibid. 

88 
89  https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662640/

EPRS_STU(2021)662640_EN.pdf based on approach by N. Lomba, 
C. Navarra, M. Fernandes, Combating Gender-based Violence: Cyber 
Violence, briefing, EPRS, European Parliament, 2021.  

90  N. Lomba, C. Navarra, M. Fernandes, Combating Gender-based 

Violence: Cyber Violence, briefing, EPRS, European Parliament, 2021.  

83

Annex 4GETTING IN TOUCH WITH THE EU

In person
All over the European Union there are hundreds of Europe Direct information centres. You can find the 
address of the centre nearest you at: https://europa.eu/european-union/contact_en

On the phone or by email
Europe Direct is a service that answers your questions about the European Union. You can contact this service:
– by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls),
– at the following standard number: +32 22999696 or 
– by email via: https://europa.eu/european-union/contact_en

FINDING INFORMATION ABOUT THE EU

Online
Information about the European Union in all the official languages of the EU is available on the Europa 
website at: https://europa.eu/european-union/index_en

EU publications 
You can download or order free and priced EU publications at: https://op.europa.eu/en/publications. 
Multiple copies of free publications may be obtained by contacting Europe Direct or your local information 
centre (see https://europa.eu/european-union/contact_en).

EU law and related documents
For access to legal information from the EU, including all EU law since 1952 in all the official language 
versions, go to EUR-Lex at: http://eur-lex.europa.eu

Open data from the EU
The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets from the EU. Data 
can be downloaded and reused for free, for both commercial and non-commercial purposes.