REGULATORY SCRUTINY BOARD OPINION Mid-term evaluation of the Space Programme
Date: 2024-02-16
Institutions: Directorate-General for Defence Industry and Space, European Commission
Subjects: EU office or agency, EU programme, European Space Agency, digital transformation, extra-atmospheric space, satellite communications, satellite navigation, space policy, space technology, use of outer space

EUROPEAN COMMISSION 

Brussels, 16.2.2024 
SEC(2024) 202 final 

 REGULATORY SCRUTINY BOARD OPINION 

Mid-term evaluation of the Space Programme 

{SWD(2024) 173 final} 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2024) 

Opinion 

Title: Mid-term evaluation of the Space Programme 

Overall opinion: NEGATIVE 

(A) Policy context 

The  EU  Space  Programme  established  by  Regulation  (EU)  2021/696  for  the  first  time 
combined all EU space activities - Copernicus, Galileo, EGNOS GOVSATCOM and space 
situational awareness - in a single Regulation. Article 102 of the Regulation mandates the 
European  Commission  to  evaluate  both  the  implementation  of  the  Programme  and  the 
performance of EUSPA and to present a Report by June 2024 to other institutions. 

(B) Summary of findings 

The Board notes the additional information provided. 

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

(1)  The report does not present clearly the intervention logic and evaluation matrix to 

guide the analysis for each component of the programme.  

(2)  The report does not present and use the available evidence in a self-standing way. 
It does not sufficiently assess the programme’s performance in terms of effective 
and efficient delivery on its objectives based on robust impact indicators.  

(3)  The  report  does  not  clearly  present  the  methodology  used,  its  assumptions  and 
limitations, and does not adequately distinguish between the evaluation of actual 
impacts and ex-ante projected results. 

(4)  The report does not sufficiently analyse the impact of the programme’s components 
on the competitiveness of the EU space industry eco-system and connected sectors. 
The SME competitiveness and participation dimensions are underdeveloped. 

(5)  The report does not present clear and operational conclusions and lessons learned 

to inform on future actions, based on the analysis. 

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

  ________________________________   
This opinion concerns a draft evaluation/fitness check 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  should  include  a  comprehensive  intervention  logic  for  each  programme 
component  reflecting  their  specific  policy  needs  and  better  regulation  requirements.  This 
should include all elements in such a way as to allow for a full understanding of causality, 
identifying  relationships  and  dependencies  and  linking  the  specific  objectives  to  policy 
actions and to their output/result/outcome/impact and their related indicators. To support the 
analysis  of  the  intervention  logic  and  evaluation  findings,  the  report  should  develop  a 
comprehensive evaluation matrix and present it in the annex. 

(2)  The report should ensure that all the better regulation requirements are complied with, 
and on this basis the report can also address the specific requirements of Article 102. 

(3)  The  report  should  clearly  present  the  available  evidence,  incorporating  it  from  all 
relevant sources such as the accompanying study, earlier work and the data sets supporting 
the  key  performance  indicators,  to  render  the  analysis  robust,  the  evaluation  SWD  self-
standing and to comprehensively report on the programme’s main achievements and progress 
towards  targets.  The  report  should  explain  how  the  evidence  is  used  to  substantiate  the 
assessment and findings. It should take full ownership of all evidence used, the methodology 
applied, and the analysis undertaken, up to conclusions and lessons learned. It should provide 
a  comprehensive  narrative  enabling  the  understanding  of  the  main  elements  of  the 
programme, avoiding unnecessary technicalities and focusing on the programme’s tangible 
achievements  against  the  points  of  comparison  /  baseline  based  on  clear  performance 
indicators.   

(4)  The  analysis  should  clearly  present  the  methodology  applied,  including  approach, 
assumptions,  quality  and  relevance  of  evidence,  gaps  and  their  impact  on  the  evaluation, 
estimates and calculations. Costs and benefits should be systemised and triangulated as far 
as  possible  with  other  findings.  The  report  should  ensure  that  methodology  presented  in 
Annex II is aligned with the analysis in the body of the document, including the terminology 
used. References to accompanying studies should not substitute essential explanations and 
evidence, which should be included in the report. The report must be clear on the reference 
period for this mid-term evaluation, distinguishing in the analysis and methodology between 
the results and impacts effectively achieved in the period under consideration, and those that 
are expected, based on ex-ante models and/or projections. Limitations to evaluating certain 
programme  components  which  are  more  recent  or  still  under  development,  and  the 
implications for the assessment of costs and benefits, should be clearly explained. The report 
should use the most relevant key programme indicators on outcomes, results and impacts, 
demonstrating the programme’s performance evolution.  

(5)  The  analysis  should  be  more  explicit  on  the  potential  for  simplification  of  the 
programme, reduction of administrative costs and burdens, including for SMEs, in particular 
as regards procurement procedures which are acknowledged as sometimes burdensome.  

(6)  The  report  should  put  more  emphasis  on  evaluating  how  the  programme  affects  the 
competitiveness of the European space industry eco-system, related industries and sectors as 
well as those who benefit from the programme in a more indirect way. Particular attention 
should  be  paid  to  the  impact  on  SMEs,  including  ease  of  their  participation,  programme 
relevance and ultimately SME competitiveness. The assessment of the pricing policy should 
explain  how  international  outlook  and  technological  advancements  were  taken  into 
consideration, including in the conclusions.   

(7)  The  report  should  present  conclusions,  based  on  the  preceding  analysis,  of  the 
programme’s functioning against all mandatory evaluation criteria. The conclusions should 
reflect the analysis in a more balanced way. The lessons learned should be presented as a 

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separate section, which should include any issues affecting the programme’s performance 
and ways  to address them with  a  view to inform further policy developments. The report 
should also discuss the recommendations from earlier evaluations and ECA reports of the 
programme’s  components  and  assess  the  extent  to  which  they  have  been  addressed  or 
difficulties persist.  

(8)  The synopsis report on stakeholder views should be more comprehensively presented, 
and the report should explain how the views of the different stakeholder groups are reflected 
in the analysis.  

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

(D) Conclusion 

The Board advises the lead Service to revise the report before launching the interservice 
consultation. 

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

Full title 

Mid-term evaluation of the Space Programme 

Reference number 

PLAN/2023/1512 

Submitted to RSB on 

17 January 2024 

Date of RSB meeting 

14 February 2024 

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Electronically signed on 16/02/2024 11:08 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121