OPINION ON THE EX POST EVALUATION OF THE EUROPEAN UNION PROGRAMME FOR EMPLOYMENT AND SOCIAL INNOVATION (EASI) INCLUDING THE FINAL EVALUATION OF THE EUROPEAN PROGRESS MICROFINANCE FACILITY (EPMF)
Date: 2023-12-22
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: EU programme, European social policy, employment aid, employment policy, gender equality, innovation, labour mobility, microfinance, social change, social economy

EUROPEAN COMMISSION 

Brussels, 22.12.2023 
SEC(2024) 184 final 

 OPINION ON THE EX POST EVALUATION OF THE EUROPEAN UNION 
PROGRAMME FOR EMPLOYMENT AND SOCIAL INNOVATION (EASI) 
INCLUDING THE FINAL EVALUATION OF THE EUROPEAN PROGRESS 
MICROFINANCE FACILITY (EPMF) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2023) 

Opinion 

Title:  Evaluation  of  the  Programme  for  Employment  and  Social  Innovation 
(EaSI)  including  the  final  evaluation  of  the  European  Progress  Microfinance 
Facility (EPMF) 

Overall 2nd opinion: POSITIVE 

(A) Policy context 

The Employment and Social Innovation Programme 2014-2020 (EaSI) was designed to: 
(i) contribute to the modernisation of employment and social policies (PROGRESS axis); 
(ii)  to  facilitate  access  to  labour  markets  and  job  mobility  (EURES  axis);  and  (iii)  to 
increase  access  to  microfinance  and  social  entrepreneurship  (Microfinance/Social 
Entrepreneurship axis). EaSI is implemented by the Commission and applies to Member 
States and other participating countries (EFTA/EEA, EU candidate countries and potential 
candidates). 

The European Progress Microfinance Facility 2010 - 2016 (EPMF) was designed with the 
aim  of  extending  the  outreach  of  microfinance  to  specific  groups  at-risk  and  to 
microenterprises. The EPMF is implemented by the European Investment Fund (EIF) and 
applies  to  EU  Member  States.  The  EPMF  was  followed  up  by  a  new  generation  of 
financial  instruments  under  the  Microfinance/Social  Entrepreneurship  axis  of  the  EaSI 
programme. 

The evaluation was carried out in compliance with Articles 13(4) and 38(1) of the EaSI 
Regulation  and  is  subject  to  a  report  to  the  European  Parliament,  the  Council,  the 
European Economic and Social Committee and the Committee of the Regions. 

(B) Summary of findings 

The Board notes the improvements to the report.  

The Board gives a positive opinion. The Board also considers that the report should 
further improve with respect to the following aspects:  

(1)  The report does not critically assess the adequacy and suitability of the existing 

monitoring system.  

(2)  The report does not sufficiently recognise the constraints and data limitations 
when drawing conclusions. On a number of concrete areas lessons learned and 
suggestions  for  improvements  are  missing.  Some  conclusions  on  effectiveness 
and efficiency and qualitative assessment of costs and benefits do not fully reflect 
the underpinning analysis.  

  ________________________________   
This opinion concerns a draft evaluation which may differ from the final version. 

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu 

 
 
 
C) What to improve 

(1) The  report  acknowledges  the  weaknesses  in  the  performance  measurement  of 
PROGRESS axis and the necessity for quantitative indicators. However, the analysis 
should go further in explaining what quantification and further indicators are needed 
to assess the impact of the measures on the ground. It should analyse to what extent 
the specific objectives of the PROGRESS axis are SMART enough to serve as a base 
for an improved monitoring system to analyse the effectiveness, the efficiency and the 
coherence. It should explain how the proposed simplification in the ESF+ addresses 
the need for more suitable indicators for informing future evaluation. 

(2) In  assessing  efficiency,  the  report  should  better  explain  how  indicators  based  on  a 
small number of stakeholders’ opinions, are sufficiently reliable to draw conclusions. 
It  should  clarify  the  design  and  parameters  of  the  ‘cost-effectiveness’  ratio  for  the 
PROGRESS axis and explain to what extent such ratio is informative in concluding 
on performance over time. It should clarify the maximum and minimum levels of such 
a ratio. 

(3) In  general,  answers  to  the  evaluation  questions  should  be  balanced  and  linked  to 

preceding analysis, taking into account all available evidence, in particular: 

- 

- 

- 

the conclusion on EPMF and EaSI’s effect on economic growth and employment, 
does not seem substantiated by the preceding analysis; 

the conclusion that EPMF was “highly” effective in increasing the availability of 
microfinance (including for women and the unemployed) does not seem to account 
for the uncertainty in the evidence of whether the 50% target was reached, due to 
data limitations and potential overlaps; it should also address the evidence pointing 
to potential decrease in access over time for these two categories; 

the conclusion on the effectiveness of the general objective on ‘high quality and 
inclusive EU labour markets’ needs to address the evidence, which could equally 
lend itself to alternative readings of the data, such as large decreases of the share 
of placements resulting from all contacts. 

(4) The  report  should  ensure  that  all  identified  weaknesses  are  followed  up  by 
corresponding  lessons learned,  and equally that  all lessons learned  follow  logically 
from the preceding analysis. In particular, although the report: 

- 

indicates that the flexibility clause, permitting to adjust funding among axes was 
in  practice  inefficient  given  the  important  (potential)  administrative  burden 
generated to operate these changes, there is no discussion in the lessons learned 
on this finding; 

-  highlights  the  utility  of  an  easy-to-use  tool  allowing  stakeholders  to  have  an 
overview of all programmes and opportunities available at EU level, this is not 
reflected in the lessons learned; 

-  concludes that the evidence presented indicates that the budgets planned for the 
remaining programme’s activities were appropriate, it still suggests as an area for 
improvement  the  provision  of  additional  funding  for  social  experimentation  to 
achieve their expected impacts. 

(5) The  parameters  for  some  qualitative  judgements  accompanying  or  substituting 
quantification in Annex IV (Overview of costs and benefits) are not explained, and 
sometimes do not appear in line with the analysis and the answers to the evaluation 
questions  in  the  report.  They  should  be  reassessed  to  ensure  that  they  reflect  the 

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underpinning evidence and previous analysis (for example cases where effectiveness 
was found to be “moderate”). In particular:  

- 

- 

the analysis is unclear whether qualifying the magnitude of benefits for certain 
areas of the intervention is based only on outputs such as number of analytical 
documents,  mutual  learning  events  etc.,  and  whether  this  is  the  parameter  to 
justify the qualitative assessment of the benefit as “high”; 

the  qualitative  assessment  of  EPMF’s  burden  reduction  achievement  needs  to 
address findings in the report on impacts on the efficiency due to administrative 
burden in the projects’ application, award, and implementation stages in cases of 
using the EFSI guarantee, in particular for small organisations and some EU-level 
NGO networks.  

(D) Conclusion 

The  DG  must  take  these  recommendations  into  account  before  launching  the 
interservice consultation. 

Full title 

Evaluation  of  the  Programme  for  Employment  and  Social 
Innovation  (EaSI)  including  the  final  evaluation  of  the 
European Progress Microfinance Facility (EPMF) 

Reference number 

PLAN/2019/5817 

Submitted to RSB on 

27 November 2023 

Date of RSB meeting 

Written procedure 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2023) 

Opinion 

Title: Evaluation of the Programme for Employment and Social Innovation 
including  the  final  evaluation  of  the  European  Progress 
(EaSI) 
Microfinance Facility (EPMF) 

Overall opinion: NEGATIVE 

(A) Policy context 

The Employment and Social Innovation Programme 2014-2020 (EaSI) was designed to: (i) 
contribute to the modernisation of employment and social policies (PROGRESS axis); (ii) 
to facilitate access to labour markets and job mobility (EURES axis); and (iii) to increase 
access to microfinance and social entrepreneurship (Microfinance/Social Entrepreneurship 
axis).  EaSI  is  implemented  by  the  Commission  and  applies  to  Member  States  and  other 
participating countries (EFTA/EEA, EU candidate countries and potential candidates). 

The European Progress Microfinance Facility 2010 - 2016 (EPMF) was designed with the 
aim  of  extending  the  outreach  of  microfinance  to  specific  groups  at-risk  and  to  micro-
enterprises. The EPMF is implemented by the European Investment Fund (EIF) and applies 
to  EU  Member  States.  The  EPMF  was  followed  up  by  a  new  generation  of  financial 
instruments under the Microfinance/Social Entrepreneurship axis of the EaSI programme. 

The  evaluation  was  carried  out  in  compliance  with  Articles  13(4)  and  38(1)  of  the  EaSI 
Regulation and is subject to a report to the European Parliament, the Council, the European 
Economic and Social Committee and the Committee of the Regions. 

(B) Summary of findings 

The  Board  notes  the  additional  information  provided  and  commitments  to  make 
changes to the report. 

However,  the  Board  gives  a  negative  opinion  because  the  report  contains  the 
following significant shortcomings:  

(1)  The  evidence  base  underpinning  the  analysis  is  insufficient.  The  report  relies 
mostly on value judgements from stakeholders but it is not clear how these can 
be considered representative. 

(2)  The  analysis  does  not  sufficiently  explain  nor  consistently  use  the  target 
indicators.  It  does  not  assess  the  adequacy  and  suitability  of  the  monitoring 
system in place for informing the evaluation.  

(3)  The  report  does  not  identify  appropriate  “lessons  learned”  to  inform  future 

policy. 

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The Board considers that in its present form this report does not sufficiently respond 
to the mandate of the evaluation. 

(C) What to improve 

(1)  The  report  should  provide  an  appropriate  evidence  base  underpinning  analysis  by 
avoiding  exclusively  or  mostly  relying  on  the  value  judgements  of  stakeholders.  The 
evidence base should be supported by measurable and tangible results, and  claims and views, 
to the extent they are used as evidence base, should be reflected in such results on the ground. 
In this regard, the report should consider what data and figures currently contained in the 
annexes and/or in the supporting study should substantiate further the analytical part of the 
report  and  provide  support  to  the  conclusions,  in  particular,  on  the  performance  of  the 
measures. Overall, in discussing implementation of the programmes, the report should go 
further than listing activities and inputs and assess outcomes and impacts. It should explain 
why it may be difficult or not possible in some cases to identify and measure the specific 
contribution of the programmes to the general objectives.  

(2)  The  report  should  explain  why  EaSI  proved  to  be  unevenly  applied  across  Member 
States.  It  should  analyse  in  detail  the  reasons  behind  the  uneven  participation  across  and 
within countries, what the consequences were in terms of making the intervention effective, 
relevant and efficient across Member States, and whether  there was an evolution following 
the implementation of corrective measures, like the National Contact Points (NCP) network 
and improved promotion. It should thoroughly explore whether EaSI was equally beneficial 
for all recipients and if all its features are equally useful. Rather than relying primarily on 
stakeholder  feedback,  the  report  should  present  clearly  EaSI’s  identified  outcomes  and 
impacts and how these can be used as a measure of success across the EU.  

(3)  The report should explain how it has concluded on the effectiveness of EPMF based on 
the number of micro loans, while only 30% of beneficiaries are female and cannot provide 
data to evaluate the objective of 50% beneficiaries to be unemployed. If the information is 
not fully available the report should explain why.  

(4)  While the report considers only the input, the output and the stakeholders’ satisfaction 
with  the  services  provided  when  assessing  the  achievement  of  Specific  Objective  5 
(transparent  labour  market  information),  it  should  also  evaluate  the  impact  based  on  the 
number of additional recruitments. While the report shows a decreasing trend of the number 
of monthly visitors to the EURES Portal it should explain why it could be “a positive sign of 
improved employment rates and labour conditions”. 

(5)  The report should explain how specific targets were set and present all of them if some 
are missing. It should provide clarity on which targets are used where and how in analysing 
effectiveness and efficiency. There should be a thorough explanation of whether and how 
indicators  based  on  a  small  number  of    stakeholders’  opinions,  can  be  considered 
representative. 

(6)  The  report  should  assess  more  thoroughly  the  suitability  of  the  existing  monitoring 
system and identify the areas for improvement.  

(7)  Conclusions should present adequate and relevant ‘lessons learned’ to inform the next 
programming period, also referring to improvements and changes already implemented for 
the current programming period. It should be based on the main issues identified in the report 
and all lessons learned should be discussed and  substantiated  in the analysis section.  The 

5 

 
 
report should recognise the constraints and limitations it faced in gathering evidence, and the 
fact that such constraints may bring caveats and nuances in the analysis. 

(8)  The report should better discuss the coherence of EaSI with other EU programmes (such 
as Horizon2020, European Social Fund for social innovation, etc). It should explain whether 
synergies were sought or emerged and how the risk of overlap was addressed. 

(9)  Annex IV (Overview of costs and benefits) should be revised. Costs and benefits should 
be reported separately, specific benefits should be encoded; narrative statements on degrees 
of performance should be kept to a minimum and the general lack of quantification should 
be clearly explained and justified.  

Some more technical comments have been sent directly to the author DG. 

(D) Conclusion 

The  Board  advises  the  DG  not  to  launch  the  interservice  consultation  before 
substantially revising the report. 

The lead DG may resubmit to the Board a revised version of this report. 

Full title 

Evaluation of the Programme for Employment and Social 
Innovation (EaSI) including the final evaluation of the 
European Progress Microfinance Facility (EPMF) 

Reference number 

PLAN/2019/5817 

Submitted to RSB on 

3 April 2023 

Date of RSB meeting 

25 May 2023 

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Electronically signed on 22/12/2023 13:02 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121