COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Report from the Commission to the European Parliament and the Council on the final evaluation of the programme for the competitiveness of enterprises and small and medium-sized enterprises (COSME) 2014-2020
Date: 2024-10-01
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EU programme, business start-up, company growth, competitiveness, corporate finance, market access, organisational culture, single market, small and medium-sized enterprises, sustainable development

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.10.2024  SWD(2024) 226 final  COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Report from the Commission to the European Parliament and the Council on the final evaluation of the programme for the competitiveness of enterprises and small and medium-sized enterprises (COSME) 2014-2020 {COM(2024) 425 final}  
 
 
Table of contents 

1 

INTRODUCTION ................................................................................................................................ 1 

1.1  Purpose and scope of the evaluation ................................................................................... 1 

1.2  Robustness of the findings and any limitations: .................................................................. 3 

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

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

2.2  Point(s) of comparison ...................................................................................................... 11 

3 

HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ....................... 12 

3.1  Current state of play .......................................................................................................... 12 

3.1.1  Specific objective 1 SO1 - Access to finance ......................................................................... 12 

3.1.2  Specific objective 2 SO2 -  Access to markets........................................................................ 15 

3.1.3  Specific Objective 3 SO3 - Framework conditions and competitiveness ................................ 17 

3.1.4  Specific objective 4 SO4 - Entrepreneurship .......................................................................... 17 

4 

EVALUATION FINDINGS (ANALYTICAL PART) ....................................................................... 18 

To what extent was the intervention successful and why? ........................................................ 18 

4.1  Effectiveness ..................................................................................................................... 18 

4.1.1  Specific Objective 1 SO1 - Access to finance ........................................................................ 26 

4.1.2  Specific objective 2 SO2 -  Access to markets........................................................................ 36 

4.1.3  Specific Objective 3 SO3 - Framework conditions and competitiveness ............................... 44 

4.1.4  Specific objective 4 SO4 - Entrepreneurship .......................................................................... 49 

4.2  Efficiency .......................................................................................................................... 53 

4.2.1  Costs of the different actions and cost-effectiveness metrics .................................................. 56 

4.2.2  Benefits of the different actions .............................................................................................. 58 

4.2.3  Proportionality of costs and benefits ....................................................................................... 62 

4.2.4  Administrative costs for applicants and beneficiaries ............................................................. 64 

4.3  Coherence .......................................................................................................................... 66 

4.3.1  Specific objective 1 SO1 - Access to finance ......................................................................... 68 

4.3.2  Specific objective 2 SO2 - Access to markets......................................................................... 69 

4.3.3  Specific objective 3 SO3 -  Framework conditions and competitiveness ............................... 70 

4.3.4  Specific objective 4 SO4 - Entrepreneurship .......................................................................... 70 

4.4  How did the EU intervention make a difference and to whom? ....................................... 71 

4.4.1  Specific objective 1 SO1 - Access to finance ......................................................................... 72 

4.4.2  Specific objective 2 SO2 - Access to markets......................................................................... 73 

4.4.3  Specific objective 3 SO3 - Framework conditions and competitiveness ................................ 74 

4.4.4  Specific objective 4 SO4 -  Entrepreneurship ......................................................................... 75 

 
 
 
 
4.5  Is the intervention still relevant? ....................................................................................... 75 

4.5.1  Specific objective 1 SO1 - Access to finance ......................................................................... 76 

4.5.2  Specific objective 2 SO2 - Access to markets......................................................................... 76 

4.5.3  Specific objective 3 SO3 - Framework conditions and competitiveness ................................ 77 

4.5.4  Specific objective 4 SO4  - Entrepreneurship ......................................................................... 78 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNT? .................................................... 79 

5.1  Conclusions ....................................................................................................................... 79 

5.2  Lessons learnt .................................................................................................................... 81 

ANNEX I:   PROCEDURAL INFORMATION ........................................................................................... 83 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................................... 87 

A. Summary of the methodology, limitations, mitigating actions and overall robustness ........ 87 

B. Detailed description of the methodology .............................................................................. 91 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

Conceptual and Evaluation Framework for COSME .............................................................. 91 

Document Review ................................................................................................................... 91 

COSME - Mapping and Grouping of actions ......................................................................... 91 

Statistical analysis ................................................................................................................... 94 

Assessment of Costs and Benefits .......................................................................................... 97 

Open Public Consultation and analysis of responses to the calls for evidence ....................... 98 

Targeted surveys of COSME stakeholders ............................................................................. 98 

Interviews ............................................................................................................................... 99 

Counterfactual analysis ......................................................................................................... 100 

Create the beneficiaries’ dataset ........................................................................................... 103 

Control group design............................................................................................................. 111 

Econometric analysis ............................................................................................................ 111 

Results ................................................................................................................................... 114 

Case studies........................................................................................................................... 115 

Main challenges and mitigation actions ................................................................................ 116 

ANNEX III.  EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 

TO THE EVALUATION QUESTIONS (BY CRITERION) ........................................................... 120 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS [AND, WHERE RELEVANT, TABLE 

ON SIMPLIFICATION AND BURDEN REDUCTION] ................................................................ 138 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ........................................... 150 

ANNEX  VI.  ADDITIONAL  INFORMATION  ON  THE  IMPLEMENTATION  OF  THE 

PROGRAMME, INCLUDING COUNTRY INFORMATION ........................................................ 159 

A.  COSME Interim Evaluation recommendations and how they were addressed ............... 159 

B.  Further information on implementation - SO1 - Access to finance ................................ 160 

C.  Further information on implementation - SO2 - Access to markets ................................ 168 

D.  Further information on implementation  – SO3 - Framework conditions and 
competitiveness ....................................................................................................................... 172 

E.  Further information on implementation – SO4 - Entrepreneurship ................................ 173 

 
 
F.  Country Information ........................................................................................................ 175 

ANNEX VII. PERFORMANCE AGAINST INDICATORS ..................................................................... 178 

ANNEX VIII. CASE STUDIES AND SUCCESS STORIES .................................................................... 182 

Introduction ............................................................................................................................. 182 

CASE STUDY 1: SUPPORT FOR ENTREPRENEURSHIP POLICY IMPLEMENTATION ................ 183 

CASE STUDY 2: IT TOOL ERASMUS FOR YOUNG ENTREPRENEURS ......................................... 185 

CASE STUDY 3: EARLY WARNING EUROPE EWE MENTOR ACADEMY .................................... 186 

CASE STUDY 4: WEGATE PLATFORM FOR WOMEN ENTREPRENEURSHIP .............................. 188 

CASE STUDY 6: SOCIAL ECONOMY MISSION .................................................................................. 191 

CASE STUDY 7: CLUSTERS GO INTERNATIONAL: ESCP-4I ........................................................... 193 

CASE STUDY 8: TRAINING FOR SME-FRIENDLY POLICIES IN CENTRAL PURCHASING 

BODIES ............................................................................................................................................ 194 

CASE STUDY 9: ENTERPRISE EUROPE NETWORK: CARVERTICAL ............................................ 196 

 
 
 
 
 
Term or 
acronym 

COSME 

Glossary 

Meaning or definition 

Programme for the Competitiveness of Enterprises and small and 
medium-sized enterprises (2014 - 2020) 

DG ENTR 

European Commission Directorate-General for Enterprise Policy (until 
January 2015) 

DG GROW   European Commission Directorate-General for Internal Market, Industry, 

Entrepreneurship and SMEs (since January 2015) 

EASME 

European Commission Executive Agency for Small and Medium-sized 
Enterprises (2014-2021). Responsible for management of the COSME 
programme during this period (see also EISMEA). 

EEN 

EFG 

EIF 

EIP 

EISMEA 

Enterprise Europe Network 

Equity Facility for Growth 

European Investment Fund 

Entrepreneurship and Innovation Programme (the predecessor to 
COSME) 

European Agency for Small and Medium-sized Enterprises, established 
in April 2021 (the successor to EASME). Ensures management of 
COSME legacy actions, the Single Market Programme (2021-2027), 
including the SME Pillar (the successor to COSME), and European 
Innovation Council support. 

EYE 

Erasmus for Young Entrepreneurs 

ERDF  

European Regional Development Fund 

HE 

Horizon 
2020 

ISG 

LGF 

Host Entrepreneur: an experienced entrepreneur that hosts a new or 
aspiring entrepreneur for an exchange supported by Erasmus for Young 
Entrepreneurs. 

EU Funding programme for research and innovation 

Interservice Steering Group 

Loan Guarantee Facility 

 
 
 
NE 

PE 

PPI 

REFIT 

SME 

SPR 

TTG 

TTI 

VC 

New or aspiring entrepreneur. Erasmus for Young Entrepreneurs offers 
NEs the possibility for a stay with an experienced entrepreneur to learn 
about running a business. 

Private equity 

Public Procurement of Innovation 

The European Commission’s regulatory fitness and performance 
programme 

SME Definition1 A business that meets the following criteria for 1. staff headcount or 
2. either turnover or balance sheet total 

Company category  N° of staff 

Turnover or  Balance sheet total 

Medium-sized 

Small 

Micro 

< 250 

< 50 

< 10 

≤ € 50 m 

≤ € 43 m 

≤ € 10 m 

≤ € 10 m 

≤ € 2 m 

≤ € 2 m 

SME Performance Review 

Time to grant: in relation to open calls, TTG refers to the time between 
the closure of a call and Grant Agreement signature, which typically 
marks the start of the project. 

Time to inform: in relation to open calls, TTI refers to the time from the 
call deadline to the invitation to sign the contract. 

VC Venture capital 

1 Commission Recommendation of 6/5/2003 (SME definition): http://data.europa.eu/eli/reco/2003/361/oj  

 
 
 
 
1 

INTRODUCTION 

1.1  Purpose and scope of the evaluation 

According to Article 15(4) of the COSME Regulation, the Commission shall establish a 
final  evaluation  report  on  the  longer-term  impact  and  sustainability  of  effects  of  the 
measures.2  The  conclusions  and 
the 
implementation  of  the  SME  Pillar  of  the  Single  Market  Programme  (the  programme 
supporting SME competitiveness and sustainability in the 2021-27 financial period3) and 
the  implementation  of  financial  instruments  for  SMEs  in  the  framework  of  InvestEU4. 
Regarding the SME pillar of the SMP, the findings of this evaluation would be be taken 
into  account  in  the  design  of  future  work  programmes,  and  in  the  implementation  of 
monitoring activities. 

learned  would  be  considered 

lessons 

in 

The  Programme  for  the  Competitiveness  of  Enterprises  and  small  and  medium-sized 
enterprises (COSME) (2014 - 2020) established by the COSME Regulation5 focused on 
tackling challenges and obstacles for SME competitiveness, growth and entrepreneurship. 
It  also  aimed to  contribute towards the goals  of  creating more  (and better) jobs  and on 
plugging the investment gaps in the EU.  

The COSME programme sought to address a number of market failures and issues  that 
were affecting SMEs’ survival and return to growth in the years after the 2008 financial 
crisis.  These  issues  included  high  borrowing  costs  and  difficulties  in  accessing  finance 
(partly  due  to  information  asymmetries  leading  to  reluctance  by  private  financial 
institutions  to  lend  to  or  invest  in  SMEs),  challenges  for  accessing  customers  and 
international markets, and weaknesses in the entrepreneurial culture. 

The COSME programme was set in the broader context of EU policy support to SMEs, 
notably the Europe 2020 Strategy and the Small Business Act for Europe6. The Europe 
2020 flagship initiative "An Industrial Policy for the Globalisation Era" emphasised the 
importance of promoting the creation and growth of SMEs. The COSME programme was 
one of the 11 actions put forward to implement this flagship initiative. Other key initiatives 
running  in  the  same  period  as  COSME  included  the  Horizon  2020  programme  that 
supported innovation, and the Digital Europe that included a focus on helping SMEs to 
reap the benefits of digital technologies. 

COSME also built on the achievements of previous EU support programmes for SMEs, in 
particular the Entrepreneurship and Innovation Programme 2007-2013 (EIP)7. The strong 

3 Regulation (EU) 2021/690 of the European Parliament and of the Council of 28 April 2021 establishing a programme 
for  the  internal  market,  competitiveness  of  enterprises,  including  small  and  medium-sized  enterprises,  the  area  of 
plants, animals, food and feed, and European statistics (Single Market Programme) and repealing Regulations (EU) 
No 99/2013, (EU) No 1287/2013, (EU) No 254/2014 and (EU) No 652/2014. 

4 InvestEU programme Regulation: http://data.europa.eu/eli/reg/2021/523/oj 
5 Regulation (EU) No 1287/2013 of the European Parliament and of the Council of 11 December 2013 establishing a 
Programme for the Competitiveness of Enterprises and small and medium-sized enterprises (COSME) (2014 - 2020) 
and repealing Decision No 1639/2006/EC Text with EEA relevance. 

6 The Small Business Act for Europe adopted in 2008 and updated in 2011 provided a comprehensive framework for EU 

SME policy, emphasising access to finance, markets, and entrepreneurship. 

7 The EIP was part of the Competitiveness and Innovation Framework Programme (CIP) 2007-13. 

1 

 
 
 
 
 
continuity from the EIP to COSME was acknowledged by the Commission in the proposal 
for the programme.8 Improving access to finance for SMEs (during the different phases of 
their lifecycle) and access to markets, supporting entrepreneurship and better framework 
conditions  for  enterprises  were  key  objectives  of  both  programmes.  Both  programmes 
targeted micro-enterprises and SMEs. COSME carried forward key EIP measures that had 
demonstrated their value-added and impact for SMEs9, notably the financial instruments, 
the  Enterprise  Europe  Network  (EEN)  and  Erasmus  for  Young  Entrepreneurs  (EYE). 
Some  adaptations  were  made  to  EEN  to  take  account  of  issues  noted  during  the  EEN 
impact evaluation covering the 2008-2014 period, in particular putting in place of a new 
quality and performance framework. 

There were also important differences between the EIP and COSME. Whilst the EIP had 
a dedicated focus on entrepreneurship and innovation and supported first application and 
market replication projects in the field of eco-innovation, the EIP actions for innovation 
were  not  carried  over  into  COSME,  as  technological  innovation  was  mainly  supported 
though  the  Horizon  2020  programme  in  2014-2020.  In  contrast  to  the  EIP,  COSME 
developed  actions  in  the  areas  of  tourism,  public  procurement  and  social  economy. 
COSME also included actions to promote awareness, information and support measures 
and tools towards SMEs (including the EU Open for Business campaigns). The number of 
target groups was higher in COSME and efforts were made to achieve long term impacts 
and simplify the governance of the programme.10 The Impact Assessment for the COSME 
programme11  finalised  in  2011  concluded  that  the  best  option  was  a  modest  budgetary 
expansion for all of the identified components, It also referred to findings from the final 
evaluation of EIP12 on monitoring and evaluation, noting the good progress made so far, 
but  also  highlighting  a  need  to  make  further  improvements  to  data  gathering  and 
presentation, and to indicators.  

The specific focus of COSME measures was adapted over time to take account of new EU 
policy initiatives related to SMEs, particularly the Single Market Strategy (2015)13 and the 
Startup and Scaleup initiative (2016)14. The SME Strategy (March 2020) also fed into the 
implementation of actions under the 2020 work programme, leading to an increased focus 
on  sustainability,  digitalisation,  boosting  resilience,  and  addressing  new  challenges 
affecting businesses (notably supply chain issues).  

The final beneficiaries of the COSME programme were SMEs. Many actions under the 
programme operated through business support organisations and other intermediaries that 
provided  advisory  and  support  services  and/or  funding  to  help  SMEs  to  boost  their 
competitiveness and sustainability.  

8 EC Proposal COM(2011) 834 final establishing COSME, Context of the Proposal, p.9. 
9 According to the final and the ex-post evaluations of EIP. 
10 For further information, see European Parliament (2012) Briefing note ‘Differences and Similarities Between CIP and 

COSME’. 

11 Commission Staff Working Paper, Impact assessment accompanying the Proposal for a regulation of the European 
Parliament and the Council establishing a Programme for the Competitiveness of enterprises and small and medium-
sized  enterprises  (2014  to  2020),  COM(2011)  834  final  and  SEC(2011)  1453  final: https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52011SC1452&rid=1 

12 Ex-post evaluation for the Entrepreneurship and Innovation Programme (EIP), Staff Working Document, 

European Commission (2024) 

13 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52015DC0550 
14 
the 

Start-up 
https://ec.europa.eu/docsroom/documents/20262/attachments/1/translations/en/renditions/native  

Initiative, 

Scale-up 

Europe's 

leaders: 

next 

and 

COM/2016/0733 

final 

2 

 
 
COSME  ran  from  2014-2020  with  a  total  planned  budget  of  EUR 2.3 billion. 
Implementation of some actions is still ongoing. The COSME financial instruments were 
designed to run over a longer period.15  

In addition to the Member States, the following countries participated in COSME: Albania, 
Armenia,  Bosnia  and  Herzegovina,  Iceland,  Kosovo*16,  Moldova,  Montenegro,  North 
Macedonia, Serbia, Türkiye and Ukraine. 

Taking account of the impact assessment for COSME referred to above and the interim 
evaluation of the programme completed in 201717, the final evaluation assesses the extent 
to which the programme has achieved its objectives and its performance related to all five 
Better Regulation criteria18. It also considers the longer-term impacts and sustainability of 
the measures supported, and the progress towards fulfilling the recommendations set out 
in  the  interim  evaluation.  It  also  develops  concrete  conclusions  and  lessons  learned 
covering policy aspects,  strategy, and operational levels.  The evaluation  covers the full 
programme duration and all countries participating in the programme. 

The  evaluation  covered  all  specific  objectives  of  the  programme.  The  findings  were 
supported by an external study19  (hereinafter ‘the supporting study’), in accordance with 
Better  Regulation  guidelines.  The  methodology  for  this  study  included  analysis  of 
monitoring data and statistics provided by the Commission including Eurostat, European 
Agency for Small and Medium-sized Enterprise (EISMEA) and the European Investment 
Fund  (EIF),  macro-economic  context  analysis,  counterfactual  analysis,  data  collection 
through surveys and 73 interviews with key stakeholders (focusing on six main evaluation 
questions  and  related  sub-questions),  and  triangulation  of  findings  from  these  different 
sources. Further information on the process and methodology to carry out this evaluation 
is available in Annexes I and II. 

Due to the large number of actions supported by the programme the supporting study (see 
below) presents a mapping and prioritisation of actions to focus on. This mapping is based 
primarily on the amount of EU funding allocated to the action, and the expected level of 
impacts on SME beneficiaries. It also includes several actions that were less successful or 
for which issues were encountered. 

1.2  Robustness of the findings and any limitations: 

There have been several challenges for carrying out this evaluation, notably the wide range 
of interventions (complexity, mitigated by mapping and prioritising actions), the different 
levels  of  detail  in  available  monitoring  data,  the  slow  initial  response  to  targeted 
consultations  and  stakeholder  fatigue20  (mitigated  by  further  promotion  of  the  surveys, 
extensions  to  survey  deadlines  and  additional  interviews).  There  is  a  lack  of  final 
beneficiary  data  for  specific  objectives  SO2-4  (only  data  on  intermediate  bodies  is 
available)  and  this  is  addressed  by  data  gathering  by  means  of  targeted  surveys  and 
interviews.  

15  The last operations for the COSME financial instruments are due to be wound down by 31 December 2034. 
16 *This designation is without prejudice to positions on status and is in line with UNSCR 1244/1999 and the ICJ Opinion 

on Kosovo’s declaration of independence. 
17 https://data.europa.eu/doi/10.2873/87360 
18 Evaluation criteria according to the Better Regulation Toolbox: Effectiveness, Efficiency, Coherence, Relevance, EU 

value added (Better regulation toolbox (europa.eu)) 

19 Study for the COSME final evaluation (CSES) 2024 COSME study  
20 and also due to the fact that the consultations took place over the summer holiday period. 

3 

 
 
Concerning  the  robustness  of  the  consultations,  the  supporting  study  concludes  that, 
overall, these provided the necessary evidence once the mitigating actions had been taken. 
However,  the  usefulness  of  the  different  consultation  exercises  varied.  Five  of  the  six 
targeted  consultations  attracted  a  good  response21.  There  was  a  modest  response  to  the 
targeted consultation of EEN’s SME clients (67), reflecting the challenge in reaching this 
population and getting them to respond. The 72 interviews provided valuable qualitative 
evidence to complement the quantitative data from the analysis of the programme portfolio 
and the targeted consultations. The call for evidence and the public consultation had a low 
response rate (3 and 24 responses respectively) despite the efforts to promote them, and 
the results were less useful and representative.  

As the consultant carrying out the supporting study only had access to Orbis data for the 
years 2013-2022, there was a potential data gap for counterfactual analysis on businesses 
supported by financial instruments in the first year of the COSME programme. However, 
in practice, Orbis data was only needed for 2013-2022, as the Loan Guarantee Facility only 
delivered finance to SMEs as from 2015, and the Equity Facility for Growth only started 
financing SMEs at the end of 201522.  

Challenges were also encountered for constructing a large and robust enough control group 
for counterfactual analysis for the Loan Guarantee Facility (LGF) due to the large number 
of SMEs supported by this facility (865 387 distinct SMEs). The consultant carrying out 
the supporting study proposed an alternative approach for the counterfactual scenario for 
the  LGF,  making  use  of  the  “the  estimator  of  Callaway  and  Sant’Anna  (2021)23”,  This 
involved  using  a  pool  of  not-yet  supported  companies  (e.g.  companies  that  received 
funding only from 2019 and onwards were used as a control group for companies supported 
in 2018 to measure the effects in the year the guarantee was received).  It should also be 
noted that the representativeness of the sample size is not uniform at the geographical level. 
While Italian companies are well represented in the final sample, SMEs from other key 
countries,  such  as  Spain  and  France,  are  not.  Furthermore,  medium-sized  enterprises 
present particularly positive trends in relation to the overall population and yet this is not 
reflected  in  the  overall  net  causal  impact  because,  among  other  factors,  the  share  of 
medium-sized enterprises equals only 1% of the overall sample of final recipients.   

The  results  of  the  counterfactual  analysis  for  the  LGF  (good  impact  on  the  number  of 
employees  and  survival  rates  over  time,  but  a  non-significant  effect  on  the  turnover, 
personnel  costs and total assets compared to businesses that had  not yet received LGF 
support) only partly align with existing studies on LGF’s predecessors (e.g., under CIP and 
MAP). Previous studies24 demonstrated that EU guaranteed loans impacted positively on 
SME growth in terms of employment, sales, and profits.  

Due  to  the  above-mentioned  alternative  approach,  the  counterfactual  analysis  results 
cannot be directly compared with previous research on financial instruments. One possible 

21  EEN  member  organisations  (109),  host  entrepreneurs  and  new  entrepreneurs  participating  in  Erasmus  for  Young 

Entrepreneurs (1,200), Providers and beneficiaries of other COSME co-funded services (110). 

22 For the LGF no results related to SMEs supported were available for 2014, because the COSME Delegation Agreement 
was signed on 22/07/2014, the call for expression of interest was published on 04/08/2014. Similarly, for the EFG, no 
results related to SMEs supported were available for 2014 and 2015, because the COSME Delegation Agreement was 
signed on 22/07/2014, the call for expression of interest was published on 04/08/2014 and the first fund agreements 
were signed only at the end of 2015. 

23 https://www.sciencedirect.com/science/article/pii/S0304407620303948 
24  See for example, Brault, J., and Signore, S. (2019). The real effects of EU loan guarantee schemes for SMEs: A pan-
European  assessment.  EIF  Working  Paper  2019/56,  EIF  Research  &  Market  Analysis.  June  2019.  
http://www.eif.org/news_centre/publications/EIF_Working_Paper_2019_56.htm 

4 

 
 
 
explanation for these different results is that the control group of businesses that had “not 
yet  benefited”  from  LGF  support  were  better  prepared25  than  the  businesses  used  as  a 
control group for previous studies (that did not subsequently benefit from any funding from 
financial instruments at all). Further additional tests/checks (notably a check using the “log 
linear  specification”)  to  track  the  relative  causal  effect  of  the  loans,  and  breakdown 
businesses that had benefited, and businesses that had not yet benefited were carried out to 
improve the robustness of the approach. 

In the case of the EFG, it was too early to formally establish a causal link for the full set 
of SME beneficiaries. Most SME recipients for the EFG received support as from 2021 
and the methodology for the counterfactual analysis requires data from 2-3 years after the 
intervention,  which  is  not  yet  fully  available.  The  available  Orbis  data  suggests  that 
impacts for EFG so far are in line with those from previous studies on equity facilities from 
previous programmes.  

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1 

  Description of the intervention and its objectives 

At  the  end  of  2011  when  the  impact  assessment  for  COSME  was  finalized,  SMEs 
constituted 99% of European businesses, provided two out of three private sector jobs and 
contributed more than half of the total value-added created by businesses in the EU.26 In 
the  five  years  preceding  the  impact  assessment,  80%  of  new  jobs  in  Europe  had  been 
created by SMEs.27 By 2013, SMEs had recovered to pre-crisis levels in terms of value 
added but SME employment had dropped by 2.6% with a loss of 1.9 million jobs.28 

A number of market, institutional and policy failures undermined the competitiveness of 
European enterprises, including SMEs, and as well as their possibilities for growth linked 
to  access  to  finance  and  global  markets.  The  impact  assessment  shed  light  on  key 
challenges faced by SMEs at that time:   

•  Access to finance: In many Member States, SMEs experienced difficulties in obtaining 
a bank loan. According to the external impact assessment study29, between 400 000 
and 700 000 SMEs were unable to obtain a loan from the formal financial system, with 
total foregone loans ranging from EUR 40 - 70 billion, because financial institutions 
required substantial collateral and extensive financial and business records.  
•  According to a 2010 ECB survey30 access to markets was a cause of concern. 

•  There were specific problems related to entrepreneurship, SME creation and growth.  
According to a 2009 Eurobarometer survey dedicated specifically to entrepreneurship, 
only 45% of European citizens indicated that they would like to be self-employed, as 
compared to 55% in the United States and 71% in China.  

25 For example, they could have been in the  process of improving their business plans in preparation for 

seeking additional finance in future. 
26 Structural Business Statistics (SBS), Eurostat 
27  Structural Business Statistics (SBS), Eurostat  
https://ec.europa.eu/eurostat/web/structural-business-statistics/overview 
28 A net increase of EUR 44,3 billion in SME value-added and an increase of 354 308 SMEs in EU-28 compared to 2008. 

The 2.6% drop in SME employment corresponded to 1 962 808 jobs. 

29 COSME impact assessment supporting study  
30 https://www.ecb.europa.eu/press/pr/date/2010/html/pr101022.en.html 

5 

 
 
 
 
•  SME competitiveness was hampered by administrative burdens and by the other issues 
referred to above. According to different surveys, between 70% and 88% of businesses 
regarded  administrative  difficulties  in  other  Member  States  as  ‘very  important’  or 
‘important’ in deciding whether to engage in cross-border trade.31  

These issues  were still prevalent in  2014  when COSME  started. For instance, the 2013 
SAFE survey identified the main challenges for SMEs (access to customers, followed by 
access  to  finance,  availability  of  skilled  staff  and  experienced  managers,  as  well  as 
competition and supply side pressures).32 The 2014 Innobarometer33 found that the lack of 
financial  resources  represented  the  main  barrier  encountered  by  companies  in  the 
commercialisation, marketing and distribution of their innovative products and services. 

Market failures due to information asymmetries and lack of soft information affect both 
the ability of financial providers to assess SMEs’ requests for finance in a cost-effective 
way, and the ability for SMEs to access full information on market opportunities in other 
countries and on how to overcome single market barriers.34 

The  intervention  logic35  describes  the  rationale  for  the  intervention  (market  failures, 
challenges and issues in the business environment), the hierarchy of general and specific 
objectives  of  the  programme,  and  the  inputs  and  activities  leading  to  desired  outcomes 
(measured in terms of outputs, results, intermediate outcomes and impacts). It is consistent 
with the version in the impact assessment but has been further elaborated in the context of 
this evaluation, taking account of the COSME Regulation and programme documents. 

COSME’s  main  objective  was  to  enhance  SME  competitiveness.  It  also  aimed  to 
contribute to creating more (and better) jobs and plug investment gaps. In accordance with 
the impact assessment, the four specific objectives of COSME were: 

Improving access to finance for SMEs in the form of equity and debt (SO1) 

• 
•  Supporting SME access to market and internationalisation (SO2) 
•  Creating a favourable environment for enterprises and supporting their competitiveness 

(SO3) 

•  Promoting entrepreneurship (SO4) 

The  programme  also  supported  the  implementation  of  the  Europe  2020  Strategy  -  EU 
202036 (contributing to the EU2020 objectives of “smart, sustainable and inclusive growth” 
and employment creation) and the Small Business Act for Europe - SBA (2008 and 2011), 
including the implementation of SBA monitoring governance37 

The  expected  impacts  were  increased  competitiveness,  growth  in  SME  value-added, 
improved sustainability performance of SMEs, improved SME access to markets, reduced 

31  European  Business  Test  Panel,  Commercial  Disputes  and  Cross  Border  Debt  Recovery,  14.07.2010–13.08.2010, 

http://ec.europa.eu/yourvoice/ebtp 

32 The 2013 SMEs’ Access to Finance survey: 

https://ec.europa.eu/docsroom/documents/7864/attachments/1/translations/en/renditions/pdf. 

33 https://ec.europa.eu/commission/presscorner/detail/en/IP_14_610.  
34 eif_working_paper_2022_84.pdf 
35 The intervention logic was originally defined at the time of the impact assessment and updated at the end of 2016 
based on the COSME Regulation and work programmes, and subsequently in the context of the interim evaluation. 
36 The Europe 2020 Strategy (EU2020) was the EU’s agenda for growth and jobs and a reference framework for policy 

interventions at the EU, national and regional levels (COM(2010)2020). 

37 The SBA laid down an overarching framework for EU SME policy fixing 10 key priorities including access to finance, 
framework conditions for SMEs, and entrepreneurship. The 2011 SBA review proposed a set of new actions in response 
to the economic crisis focusing on smarter regulation, SMEs’ financing  needs, and introduced an SBA governance 
structure: https://eur-lex.europa.eu/EN/legal-content/summary/a-small-business-act-for-european-smes.html  

6 

 
 
 
administrative burdens for SMEs, the implementation of new business concepts, models, 
products or services by SMEs (including for digitalisation and sustainability), strengthened 
entrepreneurship capabilities, and growth in SME employment. 

The  final  evaluation  of  the  previous  programme  (EIP)  pointed  to  a  need  for  a  clearer 
structure  with  fewer  objectives  and  more  focused  activities  closely  related  to  the  core 
objectives in order to use budget efficiently, facilitate communication with stakeholders, 
and  strengthen  internal  programme  management.  This  need  was  partially  addressed 
through the clearer structure of the COSME Regulation in comparison to the CIP and the 
inclusion  of  indicators  in  the  COSME  Regulation  that  provided  a  more  solid  basis  for 
managing the programme. However, further work is still needed as some indicators proved 
difficult  to  measure.  IT  tools  were  put  in  place  in  the  COSME  programme  to  address 
reporting burdens identified by intermediaries during the EIP. 

7 

 
 
Table 1: Intervention Logic   

8 

 
 
The table below lists Programme’s actions under each specific objective. For the purpose 
of this evaluation, the actions were also grouped according to a set of thematic areas. The 
actions in bold were given greatest consideration by the evaluation after a processing of 
mapping and prioritisation (as explained in Annex B). 

Table 2: Actions within the COSME programme (2014-2020) 

Thematic areas 
SO1 Improving access to finance for SMEs in the form of debt and equity 

Name of action and how it contributed to the specific objective 

Access to finance 

•  Equity  Facility  for  Growth  (EFG):  This  provides  equity  support  through  venture 
capital investments to support the growth and expansion stage development of SMEs. 
•  Loan  Guarantee  Facility  (LGF):    including  the  SME  Initiative:  This  provides 
guarantees and counter-guarantees to financial intermediaries which in turn support debt 
financing (e.g. loans, guarantees, leases) for riskier SMEs 

SO2 Improving access to markets for SMEs 
Business support 
networks and 
services 

•  Enterprise Europe Network (EEN):  EEN aims to improve SMEs’ access to markets 
by  providing  integrated  services  such  as  advice  and  information  on  EU  funding,  the 
internal market and internationalisation beyond the EU market, including international 
partnership services 

Public 
procurement 

•  EU-Japan centre for industrial cooperation 
•  International intellectual property (IPR) SME helpdesks 
•  Your Europe Business portal 
•  Single digital gateway 
•  Supporting European SMEs to participate in public procurement outside EU 
•  Co-financing of public procurement of innovation consortia 
•  Creating links for the facilitation of public procurement of innovation 
•  Training for SME-friendly policies in central purchasing bodies 

SO3 Improving framework conditions and competitiveness 
Internationalisation  •  Clusters Go International: This supported cluster and business network collaboration 
across  borders  and  sector  boundaries  and  the  establishment  of  European  Strategic 
Cluster Partnerships to lead international cluster cooperation in fields of strategic interest 
towards third countries beyond Europe.  

Competitiveness 

•  Clusters Go international in the defence and security sector: a separate action dedicated 

to the defence and security sector 

•  The  European  Cluster  Excellence  Programme:  this  aimed  to improve specialised  and 
customised  business  support  by  strengthening  cluster  management  excellence  and 
facilitating  exchanges  and  strategic  partnering  between  clusters  and  specialised  eco-
systems across Europe. 

•  E-Skills for competitiveness and innovation 
•  Strategic alliances for the uptake of advanced technologies by SMEs 
•  Early Warning Europe Mentor Academy 
•  Intellectual Property voucher (also known as SME fund): This supports SMEs with the 

protection of their IP, in order to maintain their competitive position.38  

•  Development of the European Food Price Indicator 
•  Worth  Partnership  Project:  an  acceleration  programme  which  provides  mentoring, 
coaching 
designers, 
business 
manufacturers/craftsmen and tech providers to develop new, innovative business ideas. 

partnerships 

visibility 

between 

and 

to 

Tourism 

•  Enhancing European Tourism Competitiveness and sustainability 

38 COSME 2020 Monitoring Report. 

9 

 
 
 
 
Thematic areas 

Framework 
conditions 

Name of action and how it contributed to the specific objective 
•  Capital of Smart Tourism 
•  Innovation uptake and digitalisation in the tourism sector 
•  SME performance review: a comprehensive review of the performance of SMEs and 

issues affecting the business environment. Used to support SME policy-making. 

•  Following  and  monitoring  the  Small  Business  Act  including  SME  Envoys  Network: 
COSME funded the meetings of the SME Envoys, an SME policy advisory group that  
supports the Commission’s work to make regulations and policies more SME-friendly. 
•  European Enterprise Awards: an annual competition to  recognise the most successful 
promoters of entrepreneurship across Europe and the best entrepreneurial practices. 
•  Small Business Act including implementation, outreach tools including Business Planet 
•  EU REFIT platform: COSME supported the development and testing of various IT tools 
for consulting stakeholders to support the Commission’s work on Better Regulation 

SO4 promote entrepreneurship and entrepreneurial culture 

Entrepreneurship 

Social Economy 

•  Erasmus  for  Young  Entrepreneurs  (EYE):  EYE  is  a  cross-border  exchange 
programme  which  gives  new  or  aspiring  entrepreneurs  the  chance  to  learn  from 
experienced  entrepreneurs  running  small  businesses  in  other  COSME  Participating 
Countries. The exchange of experience takes place during a stay with the experienced 
entrepreneur, which helps the new entrepreneur acquire the skills needed to start and run 
a small firm. 

•  European Network of female entrepreneurs and on-line e-platform, European Network 

of mentors for female entrepreneurs 

•  Support for entrepreneurship policy implementation 
•  EYE IT Tool: The IT tool that supports the matching process and the management of 

the EYE action 

•  Promotion of social economy in Europe 
•  European Social Economy Missions for developing inter-regional collaboration, 
sharing/replicating best practices, and inter-regional learning in the field of social 
economy. 

Source:  
i) Thematic areas and actions: elaboration based on the supporting study 
ii) Contribution of the action to the specific objective: analysis from the supporting study and  additional 
information from the European Commission. 

COSME  was  implemented  through  Annual  Work  Programmes  (AWPs),  drawn  up 
according to the Commission's policy priorities, evolving SME needs and support gaps and 
in  cooperation  with  relevant  DG  GROW  policy  units.  The  programme  committee 
composed of representatives of the Member States approved the work programmes. 

Progress towards the objectives was monitored according to key performance indicators 
(KPIs).  One step forward in comparison to previous programmes was the inclusion of an 
initial  set  of  indicators  in  the  legal  base  for  COSME.  These  were  subsequently  further 
elaborated.39 As presented in further detail in the effectiveness analysis, most of the actions 
met  or  exceeded  their  performance  targets.  However,  for  approximately  25%  of  the 
indicators,  there  were  either  issues  for  gathering  data,  or  performance  was  not  fully  on 
target.  

An interim evaluation of COSME covering the activities funded in the 2014-2016 period 
was undertaken in 2017.40 The interim evaluation found a strong alignment of the COSME 

39 A full list of programme level indicators is presented in Annex VII, and indicators for specific actions are mentioned 

for each action in the efficiency analysis (point 4.1).  

40 Technopolis (2017): Interim Evaluation of the COSME Programme, Final report.  

10 

 
 
 
 
programme  with  the  needs  of  SMEs  at  the  time  and  market  failures  that  needed  to  be 
addressed,  and  a  high  relevance  for  citizens  in  terms  of  its  targets  of  jobs  creation  and 
growth. It also confirmed that the programme had made progress towards its objectives 
and expected outputs. However, synergies between actions of the programme and other 
EU  interventions  could  have  been  improved.  The  main  conclusions  of  the  interim 
evaluation are summarised in Annex VI A.  

An  example  of  one  key  recommendation  that  was  taken  into  account  in  the  final 
implementation of the COSME programme was the evolution of EEN services after the 
interim  evaluation.  The  EEN  and  the  Commission  worked  together  on  a  medium-term 
strategy for revamping EEN's services and service delivery models to ensure that it could 
meet SME's changing needs. A central feature of this new approach was a focus on SME 
clients' needs and a medium-term client journey with more in-depth services to support 
SME competitiveness and internationalisation. Towards the end of the programme EEN 
also progressively started to build capacities for providing sustainability advisor services 
and started delivering these services on a small scale.  

COSME falls under the responsibility of DG GROW. DGs ECFIN and BUDG are closely 
associated  in  the  implementation  of  the  programme  for  matters  related  to  the  COSME 
financial instruments (SO1). Other DGs were also closely associated with COSME actions 
in their fields, including Secretariat General (for actions related to regulatory fitness and 
the reduction of regulatory burdens) and DG for Defence Industry and Space (DEFIS) for 
actions related to defence/dual use industries. 

The implementation of the COSME financial instruments was delegated to the European 
Investment  Fund  (EIF)  whereas  EASME  (now  EISMEA)  ensured  the  management  of 
delegated actions under the other specific objectives of the programme.  

2.2  Point(s) of comparison  

The COSME Regulation stipulates that the programme should build on the achievements 
of the previous programme (the Entrepreneurship and Innovation programme strand of the 
Competitiveness and Innovation Programme). It also indicates a number of matters to pay 
attention to, notably the visibility of financial instruments, synergies with other EU and 
national  programmes  and  to  make  further  advances  with  the  quality,  performance  and 
visibility of EEN. 

The present evaluation was informed by the above intervention logic and focuses primarily 
on the outputs, outcomes and impacts levels. It also takes account of the issues identified 
in  the  impact  assessment  (see  the  start  of  point  2.1)  and  the  consultations    designed  to 
address the questions on whether COSME has effectively resolved all the problems faced 
by SMEs identified therein.  

The  recommendations  made  in  the  interim  evaluation  of  COSME  (2017)41  serve  as 
important points for comparison (see Annex VI A), and the present evaluation includes an 
assessment of the progress made in this respect, broadened with additional indicators on 
other relevant aspects.  

41 https://op.europa.eu/en/publication-detail/-/publication/a7255ab4-a9d2-11e9-9d01-01aa75ed71a1 

11 

 
 
3  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1  Current state of play 

The  total  implemented  budget  of  the  COSME  programme  for  the  7-year  period42  was 
EUR 2.4 billion.  Bearing  in  mind  this  relatively  limited  overall  budget,  the  COSME 
programme  reached  a  relatively  large  number  of  SMEs43.  More  than  2.9  million 
SMEs44  benefited  from  the  financial  instruments  and/or  the  in-depth  services 
provided  under  this  programme,  and  21  million  SMEs  benefited  from  COSME’s 
digital services such as EEN web sites, digital information tools published by the IP SME 
helpdesks and the Your Europe Business Portal.  

Further information on KPIs and targets is provided in the effectiveness analysis (see point 
4.1.1). 

3.1.1  Specific objective 1 SO1 - Access to finance  

Loan Guarantee Facility (LGF) 

Between 2014 and 2022, the Loan Guarantee Facility (LGF) signed a total of 163 guarantee 
contracts with 128 financial intermediaries,45 in 35 countries. This resulted in 1 173 780 
transactions for a total guarantee amount of EUR 53.9 billion provided to 865 387 final 
recipients,  i.e.  SMEs.46  The  number  of  transactions  progressively  increased  until  2020 
when there was a peak in demand and a substantial top-up from EFSI, and decreased from 
2021 onwards47. 

Figure 1: Evolution of the number of LGF transactions and total guarantee amount 

42 Breakdown by year in Annex VI. 
43  The  number  of  SMEs  reached  compares  favourably  to  the  SME  competitiveness  objective  of  the  ERDF  which 
benefited from a significantly higher amount of EU funding (EUR 26.5 billion from the ERDF). Source: Evaluation 
study for the ex-post evaluation of Cohesion Policy programmes 2014-2020 financed by the ERDF. 

44 Including the financial instruments, in-depth support from EEN, EYE and the IP SME helpdesks 
45 Out of the 114 financial intermediaries that signed a guarantee contract under COSME, 26 had also signed agreements 

in the predecessor programme SMEG (the SME Guarantee Facility) 

46 The figures provided are based on the study’s own calculations combining EIF monitoring data and the COSME LGF 

Quarterly Report as of 31 December 2022. 

47 The number of transactions dropped as agreements signed with intermediaries earlier in the programme period started 
to expire and as the 2014-2020 budget for signing new transactions (with intermediaries) was increasingly used up. 

12 

 
 
 
Source: Elaborations on EIF monitoring data for the supporting study   

The LGF supported 865 387 distinct SMEs (i.e. final recipients) as of 31 December 2022. 
The countries with the highest number of final recipients are Italy, France, Spain, Greece 
and Poland. The geographical distribution of supported SMEs is mainly determined by the 
portfolio volume of the financial intermediaries in each country48. 

Most firms that benefited from the LGF are micro-enterprises (less than ten employees) - 
89%  of  the  final  recipients  reached.  Small-  (10-50  employees)  and  medium-sized 
enterprises (50-250 employees) account for 10% and 1% of the number of SMEs financed 
respectively. Overall, 50% of the firms financed under the LGF are sole proprietors. This 
is  not  unexpected  given  that  the  LGF  set  a  EUR  150  000  loan  threshold  above  which 
intermediaries had to apply a special procedure to verify the companies’ eligibility. 

Demand for the LGF was high throughout the programme and the budget was increased 
with  several  top-ups  from  the  European  Fund  for  Strategic  Investments’  (EFSI)  SME 
Window. The top-ups amounting to nearly EUR 1.5 billion in total for 2014-2020 were 
successfully implemented.49  

COSME Equity Facility for Growth (EFG) 

The EIF signed EFG agreements with 23 financial intermediaries and committed an overall 
amount of about EUR 324 million from the EU budget to their funds in addition to the EIF 
own resources alongside with other private resources investing in these funds.50 Under the 
core  part  of  the  COSME  EFG51,  the  EIF  has  committed  EUR 278 million  into  21 
intermediaries. The additional two operations (bringing the total to 23) for EUR 45 million 
have been signed under the Pan European VC Funds-of-Funds.  

Under the core COSME EFG programme, investments were made, with either private debt, 
private equity (PE) or venture capital (VC), into 104 COSME EFG eligible final recipients 
(distinct SMEs)52, amounting to EUR 822 million in total. As some funds are still in the 
investment period, additional investments are also expected.  

48 Further country information is given in Annex VI.  
49 The top-ups from EFSI are an additional guarantee (both commitments and payments) on top of the LGF commitments. 
The LGF commitments almost doubled thanks to that  extra guarantee. This allowed for signatures of  significantly 
more agreements with financial intermediaries that provided much more financial support to riskier SMEs. Payment 
wise,  however,  the  EFSI  top-up  guarantee  will  be  called  (in  cash  terms)  only  when  the  LGF  commitments  (as 
payments) are fully exhausted, i.e. the top-ups act as a second loss piece. 

50 Source: EIF database extract (June 2023). 
51 The core part focuses on providing risk capital investment to funds that in turn invest in SMEs in their expansion and 
growth-stage, with a view to supporting growth and employment. In doing so, the EFG aims to contribute to the tackling 
of persistent market gaps in risk capital availability for SMEs. 

52  To  be  determined  as  COSME  EFG  eligible  a  final  recipient  must  be  compliant  with  several  criteria,  such  as  for 
example:  a)  an  SME  immediately  before  or  after  the  time  of  first  investment;  b)  established  and  operating  in  a 
Participating  Country  at  the  time  of  first  investment;  c)  in  its  Expansion  and  Growth  Stage  at  the  time  of  first 
investment; d) not being an excluded final recipient.  

13 

 
 
Figure 2: Evolution of total amount invested in core EFG beneficiaries by year, million 
EUR 

Source: Elaborations on EIF database extract for the supporting study 

The number of EGF final recipients and the total amount invested were closely 
correlated. The top 5 countries for both were Germany, France, Finland the Netherlands 
and Greece.  

Size of SMEs supported by the EFG 
The  majority  of  investments  made  under  the  EFG  were  directed  to  medium-sized 
enterprises (50-250 employees), which accounted for 57% of the final recipients. Small 
enterprises  (10-50  employees)  represented  38%  of  the  SMEs  financed,  while  micro-
enterprises  (fewer  than  10  employees)  made  up  only  5%  of  the  COSME  eligible  final 
recipients. 

Pan European Venture Capital Funds-of-Funds Initiative 
In 2016 the Commission launched the Pan European Venture Capital Funds-of-Funds. The 
EIF  invested  in  two  multi-country  funds  established  in  Luxembourg  providing  EFG 
commitments of EUR 12 and 33 million respectively (14% and 12% of the funds’ size). 
These Funds-of-Funds invest in other funds which in turn finance the final beneficiaries of 
the programme. The two Funds-of-Funds supported a total of 45 funds which made 460 
investments into COSME EFG eligible SMEs. 

The eligibility criteria under the Pan European VC Funds of Funds are wider than for the 
core EFG programme. The COSME EFG eligible EU Target Investees for the Funds-of-
Funds  are  SMEs  that  are  established  or  operating  in  the  EU,  whereas  the  eligible  final 
recipients  for  the  core  EFG  operations  are  established  and  operating  in  a  COSME 
Participating Country. 

The Pan European VC Funds-of-Funds supported an overall investment of EUR 3.1 billion 
in the targeted SMEs. The funds’ investment activities remained low in the early years and 
started to  gather momentum as from 2019 (EUR 545.8 million  invested  in the targeted 
SMEs), reaching a peak in 2021 (EUR 1.2 billion invested in EU target investees). As some 
funds are still in the investment period, additional investments are expected.  

The  average  amount  invested  in  the  companies  is  smaller  when  compared  to  the  core 
COSME EFG operations: 65% of the businesses received less than EUR 5 million, and 
191  investments  (42%)  were  less  than  EUR  1  million.  In  contrast  with  the  EFG,  the 
majority of investments under the Pan European VC Funds-of-Funds were made in small 
enterprises (10-50 employees), which accounted for 35% (155 firms) of the eligible final 

14 

 
recipients. Micro and medium enterprises accounted respectively for 28% (115 firms) and 
19% (91 firms) of eligible final recipients. 

The  EFG  met  most  targets:  554  SMEs  received  investments  (target:  360-540)  and  the 
overall  financing  volume  was  EUR  3.9  billion  (target:  EUR  2.6  -  EUR  3.9  billion).  It 
achieved a leverage ratio of 1:1153, target: 1:4 - 1:654. The additionality target could not be 
measured. 

The LGF met all targets: 873 751 SMEs received loans (target: 220 000- 330 000) and the 
overall financing volume was EUR 54 billion (target: EUR 14.3-21.5 billion). It achieved 
a leverage ratio of 1:2155(target: 1:20 – 1:30) and an additionality of 85% of final recipients 
considering that financial support received could not have been obtained by other means 
(target 64 %). 

a 

also 

small  number  of 

SO 2-4 were mainly implemented through calls for proposals and calls for tenders. There 
were 
specialised 
actions 
bodies/organisations,  including  the  OECD  and  the  European  Chemicals  Agency  and 
European Union Intellectual Property Office (EUIPO). There were 69 calls for proposals 
in total, and these were published from 2014 - 2021. Since that time work has focused on 
implementing ongoing (legacy) projects which are expected to close by the end of 2025 at 
the  latest56.  The  most  important  action  in  financial  terms  was  the  Enterprise  Europe 
Network. 

implemented 

through 

At the end of September 2023, 64 COSME projects were still ongoing for SO 2-4. The 
total EU funding for these ongoing projects (EUR 52 million) amounts to 18.8 % of the 
combined 2019 and 2020 EU budget for these programme objectives.57 

Further information on country participation is given under the specific headings below. 
Across these three specific objectives there was high participation from Italy, Spain and 
France.   

3.1.2  Specific objective 2 SO2 -  Access to markets 

Under Specific Objective 2 (S02) 13 actions were implemented through 27 project calls 
with a total EU contribution amounting to EUR 396.5 million (57% of projects’ total 
costs). Most of this was allocated to business support networks and services.  

Enterprise Europe Network 

Since  2008,  the  EEN  has  supported  2.9  million  SMEs  by  providing  different  services, 
including  a  wide  range  of  advisory  services  on  topics  such  as  access  to  EU  funding, 
internationalisation  and  single  market,  and  cross-border  partnering  services  thus 
supporting their innovation and growth both within the EU Single Market and globally. 
EEN’s services evolved over time to help SMEs deal with new needs and challenges.58 

53 Calculated as total volume invested, divided by the COSME EFG budget committed. 
54  EUR  1  from  the  Union  budget  will  result  in  EUR  4-6  in  equity  investments  over  the  lifetime  of  the  COSME 

programme. 

55 Calculated as total supported lending to SMEs, divided by the COSME LGF budget committed. 
56 At the end of September 2023, 60 COSME projects for specific objectives 2-4 were still ongoing of which 2 are due 

to close by the end of 2023, 57 by the end of 2024 and 5 by the end of 2025. 

57 Based on data provided by EISMEA on 26/9/2023. 
58 Tailored innovation support services for SMEs were introduced in 2014 - supported by a Horizon 2020 grant, scale-
up services (started in 2017), support for digitalisation, sustainability, boosting resilience and supply chain issues (2020 
onwards). 

15 

 
 
In  total,  664  distinct  organisations  in  42  different  countries  participated  in  93  EEN 
consortia.59  These  consortia  were  located  in  all  EU  Member  States  and  all  countries 
associated with the COSME programme60. Their composition remained stable throughout 
the programme. The allocated budget per country/region was based on, inter alia, the size 
of the population, GDP and cost of living in the respective country. Further information on 
EEN calls and key figures on outputs and results61 are provided in Annex VI. 

Information  on  EEN  KPIs  fixed  in  the  COSME  Regulation  and  the  end  of  programme 
results are given under the effectiveness heading below. For example, EEN digital services 
reached 21.5 million businesses.  

Concerning  results  for  specific  contractual  periods,  inter  alia  EEN  achieved  5  101 
partnership agreements over 2-years from 2015-2016, 5 740 from 2017-18, 2 945 in 2019, 
and 5 095 from 2020-21 (systematically exceeding the target of 2 500 per year). EEN also 
provided 102 866 advisory services from 2015-6 and 81 442 from 2020-2162. 

The Your Europe Business portal provides information in 23 languages about rights and 
obligations when doing business in another EU country, and access to assistance services. 
The COSME programme supported IT development and maintenance, and promotion of  
Your Europe Business portal YEB with an annual EU budget of EUR 350 000. The number 
of unique visitors increased by 21% from 2014-2015,63 and doubled from 2015-2016.64 In 
2016 there were 2.9 million visitors (11% of all SMEs in COSME countries).  65,66 Most 
users were from large and EU countries such as Italy, Poland, the United Kingdom, Spain, 
France and Germany, but also non-EU countries such as Russia and the United States. 

The  Single  Digital  Gateway  (SDG)67  provides  information  on  how  EU  rules  and 
procedures are applied in each Member State, and access to assistance and problem-solving 
services  to  help  businesses  and  citizens  that  are  operating  across-borders  in  the  Single 
Market.  COSME  contributed  EUR 7.1 million  to  IT  development,  translation  and 
functionalities  for  the  SDG  in  2019  and  2020  enabling  it  to  go  live  on  schedule  in 
December 2020.68  

The International IP SME Helpdesks in China, South East Asia, Latin America and India 
provide  first  line  advice,  information  and  awareness  raising  services  to  help  European 
SMEs to protect their IP when doing business with these target markets.  They received 
EUR 20.7 million of COSME funding in total.   

59  Each  consortium  signed  a  7-Year  Framework  Partnership  Agreement  (FPA)  in  follow  up  to  one  of  the  calls  for 
proposals  published  in  2014  and  2015  (the  main  call  was  published  in  2014,  and the 2015  call  was  for  associated 
countries that joined the programme meanwhile). The FPAs were complemented by separate grant agreements for 1-2 
year work programme periods (2015-16, 2017-18, 2019, and 2020-21).  This resulted in 518 grant agreements. 

60 EU Member States, EEA countries, associated countries from the Balkans and from two overseas territories (New 
Caledonia and French Polynesia). This denotes the countries where EEN consortia are based. Each EEN consortium 
provides services to SMEs in their own region or country. The European dimension of EEN comes from the cooperation 
between EEN members in different countries for dealing with cross-border enquiries and partnership requests. 

61 Further information is given in Annex VI. 
62 The targets were the sum of the individual targets in each EEN consortium’s work programme for each period: 107,164 

for 2015-6, and 62,322 for 2020-21. 

63 COSME monitoring report 2015.  
64 COSME monitoring report 2016. 
65 All visitors were counted.   
66 European Commission. 2017. Interim evaluation of the COSME programme. 
67 Regulation (EU) 2018/1724 establishing a single digital gateway.  
68 COSME Monitoring Report 2019. 

16 

 
 
Between  mid-2020  and  2023,  the  International  IP  SME  Helpdesks  replied  to  7  830 
enquiries69  and  participated  in  585  matchmaking  events  (meeting  or  exceeding  overall 
targets for both). Over 200 of the events were for the South-East Asia Helpdesk alone70. 
See Annex VI for information on KPIs and outputs and Annex VIII for a case study. 

The EU-Japan Centre for Industrial Cooperation fosters industrial, trade and investment 
cooperation  between  the  EU  and  Japan  and  contributes  to  economic  diplomacy  with 
Japan.71 COSME provided EUR 21 million in funding to the centre from 2014-20. Figures 
on the centre’s key outputs are provided in Annex VI. 

3.1.3  Specific Objective 3 SO3 - Framework conditions and competitiveness 

SO3  covered  7  thematic  areas,  “Internationalisation”,  “Competitiveness”,  “Tourism”, 
“Social Economy”, “Framework conditions”, “Design of consumer goods” and “Fashion”.  

SO3 was implemented through 21 actions and 30 calls. Most of the EU contribution went 
to  Tourism  (EUR  28.8  million),  Internationalisation  (EUR  26.6  million),  and 
Competitiveness  (EUR  25.8  million).  Consistently  with  the  fund  allocations  there  were 
also many calls and projects in these three thematic areas. Many sectoral projects focused 
on  helping  SMEs  to  implement  innovative  methods  (including  digitalisation  and 
environment-friendly processes72. 

The 1 06673 project participants under SO3 were based in 37 distinct countries, including 
both EU and associate countries. Overall, the largest demand and a relatively large share 
of participants were located in Italy (17%), Spain (16%), and France (9%) while a minority 
(45)  were  located  in  associate  countries  (Albania,  Bosnia  and  Herzegovina,  Iceland, 
Moldova, Montenegro, North Macedonia, Norway, Serbia, and Türkiye).  

3.1.4  Specific objective 4 SO4 - Entrepreneurship 

Under specific objective 4, 88% of the EU funding went to EYE (EUR 58.5 million). The 
remainder was allocated to smaller actions, notably “European Network for Early Warning 
and for Support to Enterprises and Second Starters”, “Migrant Entrepreneurs Best Practice 
Exchange”, “The European Entrepreneurship Education NETwork”, and “Social Economy 
Missions”. 

The 478 participating organisations were located in 38  distinct countries. The countries 
with the largest number of participants are Italy (12.7% of the total), Spain (12.5%), and 
Belgium  (6.5%), followed by France (5.3%), Portugal (4.8%) and the United Kingdom 
(4.8%). It is noteworthy that all projects that received a grant under SO4 were implemented 
by transnational consortia. These had 3 to 17 distinct partners. 

69 including over 2,500 queries for the China Helpdesk (of which 98.8% were answered within 3 working days). The 

Latin America Helpdesk answered 83.1% of queries within 1 day. 

70 These figures are from the COSME Work Programme 2020, International IP SME Helpdesks, Synthesis report. 

EISMEA. 2023.  

71 The Centre is a joint venture established in 1987, funded and managed jointly by the European Commission (DG 
GROW) and the Japanese Government (METI), with its head office in Tokyo and an office in Brussels. It provides a 
coherent ‘package’ of tools, support and services to SMEs, including several help desks (on the Economic Partnership 
Agreement between the EU and Japan (EPA), public procurement, technology transfer. It also runs the ‘Get Ready for 
Japan’  scheme,  the  Vulcanus  in  Japan  programme  traineeship  scheme  (including  a  placement  in  a  Japanese  host 
company) for engineering and science students. It also delivers  seminars/webinars. 

72 Source: COSME Monitoring reports, examples 2019 and 2020.  
73 This number refers to unique and distinct participants (i.e. participants in more than one thematic area are only counted 

once). 

17 

 
 
4  EVALUATION FINDINGS (ANALYTICAL PART) 

To what extent was the intervention successful and why?  

4.1  Effectiveness 

This section provides an evidence-based assessment of the successes and shortcomings of 
the programme in terms of its effectiveness. 

For  specific  objective  1  (financial  instruments)  measurement  of  success  was  based  on 
evidence that the schemes mobilized additional finance for  riskier SMEs (leverage), the 
number  of  riskier  SMEs  reached,  and  evidence  of  positive  impact  on  company 
performance (notably survival rates, employment, turnover and total assets). The findings 
of  the  supporting  study  took  account  of  the  results  of  the  counterfactual  analysis,  the 
targeted surveys and other findings from desk research.  

For specific objectives 2-4, measurement of success was based on evidence that the actions 
delivered  on  the  targets  defined  in  the  indicators  (outputs,  outcomes  and  impacts). 
Concerning  impacts  key  measures  of  success  for  SO  2-4  were  the  impact  on  SMEs’ 
financial performance and other aspects  of competitiveness  (growth, survival, turnover, 
SME employment, new markets, new jobs, skills, including skills for doing international 
business).  The  targeted  surveys  and  desk  research,  including  monitoring  data,  previous 
evaluation studies, and case studies, were the main sources of information for this part of 
the  analysis.  Some  highlights  from  the  findings  are  given  below,  together  with  general 
observations on effectiveness. 

Bearing  in  mind  the  relatively  small  scale  of  the  programme  in  terms  of  EU  budget,  
COSME  reached  a  relatively  large  number  of  beneficiaries  and  businesses  (SMEs, 
entrepreneurs  including  new  and  female  entrepreneurs,  business  support  organisations, 
intermediary organisations and other stakeholders across the EU and beyond). Within the 
SME categories the largest number of beneficiaries are microenterprises (notably via the 
LGF).  

The  broad  reach  of  COSME  in  terms  of  number,  type,  geographical  and  sectoral 
distribution of its beneficiaries is illustrated in 3.1 above and Annex VI F.  Unsurprisingly, 
there are a larger number of beneficiaries in the largest Member States, i.e. Italy, France 
and  Spain  where  financial  instruments  have  been  of  particular  benefit  to  SMEs.  The 
supporting  study  notes  that  the  impacts  of  some  actions  can  be  explained  also  by 
differences in regional financial ecosystems and banking structures, where the countries 
with  historically  developed  financial  markets  such  as  Germany,  France,  Italy  and  the 
Netherlands  can  benefit  the  most.  In  addition,  regions  with  stronger  international  trade 
links or strategic positions have benefited further from EEN support to internationalisation. 
Entrepreneurial culture also varies across Europe so regions with robust entrepreneurial 
ecosystems,  supportive  networks,  and  educational  institutions  may  witness  stronger 
impacts. Countries such as Lithuania and Cyprus were among the key beneficiaries of the 
EYE programme relative to the size of population, whereas France and Germany registered 
relatively the lowest number of exchanges.   

18 

 
80%  of  the  COSME  budget  was  allocated  to  a  few  main  actions:  financial  instruments 
(60.42%74),  EEN  (15%),  EYE  (2.2%),  and  Clusters  actions  (1.9%).  The  financial 
instruments, EEN and EYE were particularly successful in achieving the expected results 
and  most  original  performance  targets  set  in  the  Regulation  were  accomplished  or 
exceeded75. Available information, albeit limited, indicate that clusters actions have also 
delivered some good results and impacts, but reporting data on indicators was incomplete. 
Further  information  and  justification  is  provided  under  the  headings  for  each  specific 
objective / action below. 

To summarise: 

•  COSME’s financial instruments (LGF and EFG, SO1) facilitated access to finance to 
over  800  000  SMEs.  Micro-enterprises  which  tend  to  struggle  to  demonstrate  their 
creditworthiness  was  the  main  beneficiary  group.  The  counterfactual  analysis 
demonstrated  that  the  LGF  had  a  positive  and  significant  impact  on  the  number  of 
employees and the survival rates of the SME final recipients. For the EFG, according 
to data from Orbis, SME final recipients experienced significant positive trends in their 
economic performance in the years after receiving finance via this scheme. However, 
it is too early to formally prove this causal link76. Nevertheless, evidence from other 
studies on similar equity schemes supported under previous EU programmes77 suggests 
that  the  positive  impacts  of  the  EFG  on  employment,  turnover,  and  total  assets 
observed with Orbis data would also prove to be valid if a counterfactual scenario were 
replicated once all the company data needed for the counterfactual analysis becomes 
available.78  

•  The EEN (SO2) provided integrated advisory and support services to help nearly two 
million SMEs to take advantage of business opportunities in new markets both within 
the EU and beyond and supported cross-border business cooperation and transfer of 
knowledge.  The  network’s  services  delivered  on  and/or  exceeded  all  targets  and 
evidence  from  the  targeted  consultations  shows  the  impact  of  EEN  on  various 
components of SME competitiveness. 

•  The cluster actions  (SO3) promoted the international  cooperation of SMEs, boosted 
their innovation capacity and excellence and the development of products and services. 
The programme supported 130 clusters initiatives with EUR 51 million of its budget79. 
As described in the specific heading on  clusters actions below, the clusters delivered 
some  useful  outcomes  such  as  boosting  cluster  management  skills,  boosting  cluster 
managers’  understanding  of  the  internationalisation  process,  and  led  to  increased 

74  The  implemented  EU  budget  for  LGF  and  EFG  amounted  to  60.42%  of  the  implemented  COSME  budget.  This 
increases  to  60.65%  when  the  accompanying  measures  for  access  to  finance  are  included  (inter  alia,  these 
accompanying measures funded communications materials on the financial instruments, and events such as the 2020 
European Angel Investment summit organised in cooperation with DG ECFIN (EU Invest portal), EBAN and EEN. 
75 Further information on indicators (targets and results) is provided under the headings for each specific 

objective below.  

76 Most of the SMEs supported through the EFG received support in the later stages of the programme, as from 2021. 
The methodology for the counterfactual analysis requires data from 2-3 years after (and before) the intervention (for 
both the treated beneficiary SMEs and not-yet treated control groups. In addition, it should be noted that it generally 
takes several months after the end of the relevant financial year for company data to be entered in Orbis. 

77 EIF (2021), The European venture capital landscape: an EIF perspective Volume VI: The impact of VC on the exit 
and innovation outcomes of EIF-backed start-ups. EIF (2019), The economic impact of VC investments supported by 
the EIF. EIBG (2022), Evaluation of EIB Group Equity and quasi-equity support for SMEs and midcaps. Final report. 
78 That is to say,  also allowing complete counterfactual analysis for businesses supported as of 2021 and a related control 

group including Orbis data from 2-3 years after the year in which support was provided by the scheme. 

79 There were 4 generations of calls for ESCP-4i under COSME: 1. 2016-2017 (15 partnerships funded), 2. 2018-2019 

(25 partnerships funded), 3. 2020-2022 (24 partnerships funded) and 2021-2024 (14 partnerships funded). 

19 

 
 
cooperation, networking and the development of joint strategies. 

•  EYE exchanges (SO4) aimed to help new and experienced entrepreneurs to learn from 
one another (SO4) in order to promote entrepreneurship and an entrepreneurial culture. 
EYE performed well on its KPIs and one key outcome observed in the targeted surveys 
was boosting the entrepreneurship and international business skills of the participating 
entrepreneurs (see the specific heading on EYE). 

The  advisory  and  support  services  for  SMEs  and  many  of  the  projects  (EEN,  EYE, 
financial instruments and Clusters) were implemented by intermediary bodies and entities 
with  established  relations  and  knowledge  of  the  specific  community  targeted  by  the 
different initiatives. The supporting study found that the use of intermediaries in this way 
was a key strength of COSME80.   

Key  success  factors  for  the  effectiveness  of  specific  actions,  and  factors  negatively 
influencing performance are mentioned in the following points:  

•  Two key success factors for LGF are the favourable conditions offered to financial 
intermediaries (to lend to riskier SMEs) combined with the reputational benefit of the 
EU support81 which boosted the supply of loan finance for SMEs, leading to improved 
survival rates and maintaining and/or increasing jobs.  

•  Key success factors for EEN services were the proximity of service providers in the 
local environment, the established relations between EEN members and the know-how 
developed  over  time.    However,  the  use  of  local  intermediaries  also  made  it  more 
difficult to raise awareness among final beneficiaries about the EU’s contribution to 
these actions (based on the interviews with EEN members carried out for the study), 
the supporting study also notes that this also impacted on the availability of monitoring 
data at a central level as data on final beneficiaries (EEN clients) was held at the level 
of intermediaries82. 

Further examples, and evidence are provided throughout the efficiency analysis.  

Effectiveness of COSME for enhancing SME competitiveness 
The  measures  supported  by  the  programme  impacted  on  various  dimensions  of  SME 
competitiveness (helping businesses to gain an advantage in the market by reducing costs, 
increasing  productivity,  innovating,  introducing  new  products/services,  and  expanding 
into new markets). 

All four specific objectives of the programme contributed towards this goal. For matters 
related to the methodology and the selection of actions for this evaluation, there is stronger 
evidence  of  the  contribution  of  SO1  and  SO2.  SO3  actions  contributed  both  directly 
(clusters)  and  indirectly  (SME  performance  review/SME  envoys)  to  strengthening 
elements of SME competitiveness. The latter supporting the work of the Commission and 
the Member States for reducing administrative burdens which are widely recognised as a 
significant  cost  for  SMEs.    SO4  actions  contributed  primarily  to  enhancing  skills  and 
promoting entrepreneurship. The impacts of the latter could be understated, as there is no 

80 Inter alia, there is evidence of this from the interviews with Commission officials and EISMEA staff. This was also 

mentioned in the Interim evaluation of the COSME programme. 

81 These generated good leverage, boosting the supply of loan finance available to SMEs which in turn impacted on 

survival, and maintaining / increasing jobs. 

82 With the exception of the main actions (access to finance, EEN, EYE), there are no granular monitoring data on the 
number and type of final beneficiaries of COSME interventions, their geographical and sectoral distribution and other 
characteristics.  The  lack  of  this  data  poses  limitations  on  the  assessment  of  the  performance  of  these  actions  and 
outcomes achieved as explained in the methodology (Annex II). 

20 

 
 
source  of  longer  term  data,  for  example  on  whether  entrepreneurs  actually  created  a 
business after participating in EYE83. The table below summarizes the impacts of different 
actions  on  competitiveness,  and  further  details  and  evidence  for  each  specific  action  is 
given in the points below the table. 

Table 3: Impacts of specific objectives and actions on SME competitiveness 

S01 

Financial instruments: 

•  Loan Guarantee Facility 

•  Equity Facility for Growth 

SO2 

Enterprise Europe Network 

S03 

Clusters Internationalisation 

Clusters excellence 

Supported  day-to-day  operations  of  riskier  SMEs  enabling 
them to remain competitive and to survive, expanded riskier 
SME  lending,  provided  finance  to  riskier  SMEs  on  better 
credit  terms  and  conditions,  helping  those  riskier  SMEs  to 
limit  the  costs  of  their  external  financing  (outcome)  to  an 
acceptable level from economic point of view.  
Allowed SMEs to develop and invest in innovation (including 
investment in energy and environment) (outcome) 

Improved access to markets, helped SMEs to introduce new 
products (impact) 

Enhanced 
understanding of internationalisation issues) (outcome) 

internationalisation  skills  of  clusters  (better 

Enhanced management skills of clusters (outcome) 
The quality label was used by national funding authorities as 
a  criterion  for  allocating  national  funding  to  clusters.  This 
therefore helped to ensure that national funding was allocated 
to  clusters  that  could  provide  better  quality  support  to 
businesses. 

SME Performance Review, and the 
work of the SME Envoys 

Contributed to reducing administrative burdens. Inter alia 
good progress was made with reducing the time and cost of 
registering a business (two related economic impact 
indicators in the COSME Regulation) but this does not 
prove a causal link. 
These  actions  contributed  to  the  Commission’s  work  to 
monitor actions and reforms by Member States for improving 
the business environment. (European semester, Recovery and 
resilience 
reform 
programmes).  

feedback  on  national 

facility  and 

SO4 

Erasmus for Young Entrepreneurs  Enhanced business and internationalisation skills of both new 

and host entrepreneurs (outcome) 

Boosted entrepreneurship, and boosted motivation to set up 
a business. There is also evidence of early-stage impacts of 
EYE exchanges on enterprise creation, but no longitudinal 
data. 

The financial instruments enabled SMEs to secure working capital or acquire/lease small-
scale equipment, supporting their day-to-day operations. This allowed SMEs to remain 
competitive.  

The LGF finance filled a market niche and demonstrated additionality84. Within the partner 
financial  intermediaries,  COSME  LGF  has  contributed  to  the  expansion  of  riskier  SME 

83 As explained under the heading “Specific objective 4 SO4 - Entrepreneurship” below, some data is available on the 

number of businesses created in the very early stages after the EYE exchanges. 

84 Section 4.2 of this document  

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
lending  and  the  enhancement  of  credit  terms  and  conditions85.  Such  a  competitive 
financing offer helped those riskier SMEs limit the costs of their external financing to 
affordable level from economic point of view. 

The evidence on higher survival rates of companies that benefited from the financial 
instruments  shows  that  the  COSME  support  often  helped  them  to  meet  their  basic 
needs. If those companies were more likely to survive also after the LGF support stopped, 
it means that they were also more competitive, could keep clients or gain new ones, keep 
their costs down, and be innovative – to secure their position in the market.  

According  to  the  survey  of  SMEs  supported  by  the  LGF,  the  loans  allowed  54%  of 
recipients (50/92) to develop a new product or service and 51% (47/92) to develop a new 
technology or process. 

The EFG had a positive impact on enhancing SMEs’ access to finance and stimulating the 
creation of the Venture Capital /Private Equity market. 

EFG targeted the subset of SMEs which are often young fast-growing innovative firms 
with a risk profile and business model that often makes them unable to obtain financing 
from the traditional system of financial intermediation. The key sector supported by the 
EFG  was  computing  and  consumer  electronics,  a  sector  renowned  for  its  focus  on  
innovation. The EFG also facilitated investment of more than EUR 62 million in SMEs in 
the energy and environment sector86.  

Over time, EFG final recipients have not only exhibited high survival rates, but they 
have also experienced significant positive trends in their economic performance87.  

The  positive  impacts  on  turnover,  where  identified,  confirm  the  positive  impact  on 
competitiveness. For example, regardless of their size at the time of investment, data from 
Orbis confirms that SMEs benefiting from EFG have grown in terms of employment, 
turnover, and total assets. According to these figures SMEs benefiting from EFG, have 
almost  doubled  the  number  of  employees  from  the  year  before  to  the  year  after  the 
intervention88. As explained in further detail in the previous sections, it is still too early to 
prove  this  via  counterfactual  analysis,  but  the  results  of  previous  surveys  on  similar 
financial instruments indicate that these impacts are likely to hold should a counterfactual 
analysis be held in future.  

International competitiveness has been supported by the services delivered by EEN: 
Advice,  pairing  of  business  partners,  guidance,  etc.  As  mentioned  earlier,  among  EEN 
client  SMEs,  62%  of  respondents  to  the  targeted  survey  pointed  to  expanding  to  new 
geographical markets. The COSME interim evaluation survey showed that more than 75% 
of client SMEs had entered a new market, including an international market for more than 
20%. More than half of respondents attributed these results at least to some extent to the 

85 The financial intermediaries that were interviewed for the study emphasised that LGF allowed them to offer loans to 
riskier SMEs on more favourable terms than they typically would have. Since the LGF guarantee was provided at no 
cost, financial institutions had greater flexibility to pass on financial benefits to their SME clients. This translated into 
lower interest rates compared to similar client profiles and longer loan maturities. 
Growth 

Facility 
https://www.eif.org/what_we_do/equity/single_eu_equity_instrument/cosme_efg/cosme-efg-implementation-
update.pdf. 

COSME-Equity 

Implementation 

Update, 

2022. 

EIF. 

for 

86 

87 See Table 8 on evolution in key economic performance indicators before and after the intervention. Furthermore, Table 
6 on survival rates of businesses benefiting from EFG support confirms that for the investment periods 2014-2017, 
100% of the SMEs supported were still in business in year t+4 (4 years after the intervention). For businesses that 
received funding in 2018/19 the survival rates at t+4 were 96% and 94.4% respectively. 

88 For example, micro enterprises increased their staff from 4-8 in that period. For small enterprises the increase in staff 
was from 19 to 39 and medium-sized enterprises had an increase from 76-139 employees. Further figures on economic 
impacts are provided in Annex VII. 

22 

 
 
services  provided  by  EEN.  Of  the  EEN  client  SMEs  responding  to  the  targeted  survey 
(59%)89 confirmed that the network’s support had enabled them to develop new products 
or services and 63% (20/32) confirmed that EEN services had helped them to safeguard 
the number of employees.  

Development of skills can also help increase competitiveness. EEN offered workshops, 
trainings, advice and support. The COSME Programme also supported E-skills for Jobs 
campaign in 2015-2016 to fill digital skill shortages, gaps and mismatches. 

The Your Europe Business portal supported by COSME is also a source of knowledge for 
SMEs to refer to. 

The 2021 evaluation study on clusters actions noted several important benefits/impacts 
of the clusters actions related to SME competitiveness, in particular: 

•  The clusters excellence action enabled clusters to enhance their management skills. 
•  Participation in the clusters excellence action also made it easier for clusters to obtain 
national funding, as many national support schemes for clusters targeted their support 
towards clusters organisations that had obtained the clusters excellence quality label. 
•  Clusters Initiatives also offered SMEs the unique opportunity to create new networks 

and develop new ideas with different partners. 

•  Clusters internationalisation actions enhanced the expertise of clusters in the field of 

internationalisation and enabled them to pool expertise.  

However, the supporting study notes that there is insufficient  evidence to determine the 
extent  to  which  Clusters  Go  International  increased  SME  internationalisation  and 
competitiveness90.  

The  2021  evaluation  study  on  clusters91,  found  that  the  clusters  excellence  action 
contributed  to  strengthening  the  management  skills  of  clusters  and  the  clusters 
internationalisation action enabled them to gain a better understanding of issues related to 
internationalisation and to pool expertise. 

The  EYE  programme  allowed  new  entrepreneurs  to  gain  skills,  and  boosted 
entrepreneurship by helping them to prepare better to start their own business: 

•  Amongst  the  entrepreneurs  responding  to  the  targeted  survey,  nearly  100% 
(654/655) of new entrepreneur respondents reported that participation in EYE had 
improved their knowledge and skills, particularly personal skills but also technical 
and managerial skills.  

•  Among the HEs 73% (165/227) confirmed that they had boosted their knowledge 
and skills. According to the survey of NEs carried out by DG GROW after the EYE 
exchanges  (based  on  data  from  1.2.2015  till  31.1.2023),  73.4  %  of  the  8009 
respondents were planning to set up a business (either immediately: 5.3%, in the 

89 The question asked EEN clients to confirm the different positive impacts of EEN support on their business. 19/32 of 

the respondents confirmed that they had developed new products or services as a result of EEN’s support. 

90  According  to  interview  feedback,  it  is  difficult  for  clusters organisations  to obtain  follow-up  data  on  participating 
SMEs, due to, among other factors, the time lags between initial contacts and the realisation of positive outcomes in 
terms of profitability and exports for SMEs 

91  European  Commission.  2021.  Evaluation  Study  of  and  Potential  Follow-Up  to  Cluster  Initiatives  under  COSME, 

H2020 and FPI, Final report. 

23 

 
 
 
next 12 months: 29.9% or in the next 3 months: 11.8%), and 9.5% had already 
set up a business by the time of this follow-up survey92. 

Effectiveness  of the programme for reducing administrative burdens 

Under S03, the COSME programme funded studies and meetings with stakeholders that 
supported the work by the Commission and the Member States to address administrative 
burdens in EU and national policies and to find solutions for helping SMEs to deal with 
emerging  issues.  The  monitoring  forms  provide  good  evidence  of  how  these  actions 
impacted on policy making and helped enhance the business environment and reducing 
administrative burdens, for example: 

• 

•  The Commission used the SME Performance Review surveys – financed by COSME 
– to inform its inputs to the European Semester and to policy actions related to SMEs, 
including its input to shaping national recovery programmes. 
 COSME  also  funded  the  meetings  of  the  SME  Envoys  and  SME  Assembly  which 
provide  advice  and  feedback  to  the  Commission  on  issues  that  SMEs  are  facing, 
including  administrative  burdens.  The  SME  Envoy  Network  regularly  provided  all 
Member  States  with  up-to-date  information  on  barriers/administrative  burdens  and 
national support measures for SMEs. That allowed Member States’ services for SMEs 
to learn from each other and coordinate support measures.  

•  COSME  also  provided  annual  support  to  Commission  Secretariat  General’s  action 
“Engaging SMEs and Stakeholders on policy design and implementation/strengthening 
of  the  Better  Regulation  Agenda”.  The  2019  edition  of  this  action  supported  the 
definition  of  “call  for  evidence”  business  requirements.  The  2020  work  programme 
supported work to define the requirements and develop an internal Commission “one 
in,  one out  calculator93, (e.g.  EUR  850  000 from  COSME  Work programme 2020). 
Some actions aimed to reduce the admin burden resulting from EU policy measures 
(e.g. the EU REFIT platform). 

Regarding administrative burdens in the implementation of COSME actions:  

•  Of  the  SMEs  responding  to  the  targeted  survey  for  EEN  SME  clients  85%  (26/31) 
reported incurring no direct or indirect costs as a result of receiving the EEN services 
(including administrative burden and reporting obligations).   

•  The majority of LGF final beneficiaries (SMEs) responding to the targeted survey did 
not experience a high administrative burden (57/92; 62%). Just less than half (46%; 
18/39) of surveyed LGF financial intermediaries reported an additional administrative 
burden  associated  with  reporting  (heightened  programme  monitoring  requirements 
compared to the EIP). However, according to interviews, the perception of this burden 
varied considerably across financial instruments.  

•  EFG fund managers interviewed did not report any administrative burden associated 

with COSME. 

92 For the moment, there is no longitudinal follow-up survey to track the number of enterprises created over 

a longer period as a result of an EYE exchange. 

93  Meanwhile  this  tool  is  operational  and  is  used  across  the  Commission  for  entering  information  on 
administrative burden, notably in relation to impact assessments, with a view  to reducing the burden of 
EU legislation for companies (including SMEs). 

24 

 
 
 
•  For the majority of  EYE entrepreneurs (64%, 522/ 827) responding to the survey, the 
administrative  requirements  and  reporting  obligations  were,  at  worst,  slightly 
burdensome. However, 33% did observe burdens94. 

Factors negatively influencing the performance of the programme 
Although the quality of descriptions of actions in annual work programmes improved in 
the latter years of the programme95, one key factor negatively influencing the performance 
of COSME, lies in the fragmentation of smaller actions96 which lacked a strong thematic 
link to other COSME initiatives and its overarching objectives. This includes a number of 
studies which did not have a strong thematic consistency with the programme, some pilot 
actions which did not foresee any follow up and were therefore perceived as a “one-off” 
by stakeholders, and other small actions which received few project applications due to the 
very limited budget offered.  

In most cases, although these smaller actions delivered the planned outputs (in terms of 
studies, events, training and other products), the monitoring data and reports do not clarify 
how and to what extent these actions contributed to COSME’s main objectives. This was 
particularly  the  case  in  the  earlier  years  of  the  programme.  In  the  latter  years  of  the 
programme, the monitoring reports (notably the 2020 monitoring report) provided a clearer 
picture of how the smaller actions fitted into the overall programme goals. 

Adapting to changing needs 
In  the  2020  COSME  Monitoring  Report,  examples  were  provided  of  how  particular 
components of COSME were adapted to reflect the changing needs of SMEs. For instance, 
an EFSI top-up supported LGF transactions related to the digitalisation pilot launched in 
2019 to enable financial intermediaries to provide broader and more comprehensive debt 
support to SMEs for digital transformation in line with EU policy. In addition, the pilot 
allows the Financial Intermediary to enter a (Counter-) Guarantee Agreement dedicated to 
the digital transformation of SMEs.97 

Feedback from consultations conducted for the supporting study indicates that the EEN 
services also supported enterprises in implementing disruptive innovations and managing 
changes resulting from the crisis, while providing advice on overcoming emerging barriers 
and accessing finance.  

The following sections provide an in-depth assessment of the effectiveness of COSME key 
actions. Further information on specific actions, particularly some of the smaller actions, 
is provided through case studies (Annex VIII). These also include a number of case studies 
illustrating weaknesses. For example, the WE-GATE action that has only delivered to a 
limited extent on its goal to become self-sustaining after the project. 

94 Nearly one quarter (24%, 195 out of 827) the administrative requirements and reporting obligations were 

not burdensome at all. Only 9% (78 out of 827) found the requirements to be very burdensome 

95 As noted in point 4.1.1.1 of the supporting study. 
96 The COSME programme remained fairly fragmented throughout the 7-year period. One key cause was the wide scope 
of the objectives and the imperative of addressing each of these goals.  In 2020, 8.7% of the programme budget went 
on 28 smaller actions with a budget of less than EUR 1 million each. The COSME monitoring report 2020 confirms 
the relevance of many of these smaller actions to wider programme goals.  Nevertheless the programme remained 
fragmented in terms of the size of actions supported. Only 26% of the COSME 2020 budget was spent on actions with 
a total budget of more than €5 million each (11 actions in total). The link between smaller actions and the programmes’ 
key objectives was less clear in the earlier years of the programme, as the work programme and monitoring report 
were less detailed at that time. 

97 https://www.eif.org/what_we_do/guarantees/single_eu_debt_instrument/cosme-loan-facility-growth/call/annex-
v-digitalisation-pilot-term-sheet.pdf.  

25 

 
 
 
4.1.1  Specific Objective 1 SO1 - Access to finance 

This  section  presents  the  supporting  study  findings  on  the  effectiveness  of  COSME 
financial instruments combining the results of the portfolio analysis with evidence gathered 
from desk research, targeted consultations and interviews.  

Overall,  EUR  1.6  billion  were  committed  to  the  COSME  financial  instruments  for  the 
2014-2020  programming  period  (slightly  above  the  60%  target  set  in  the  COSME 
Regulation98).    The  main  longer-term  impact  of  the  LGF  was  helping  riskier  SMEs  to 
enhance  their  viability,  improve  their  survival  rates  and  helping  to  maintain  and  create 
employment.  For  the  EFG,  there  is  evidence  from  Orbis  data  and  previous  studies  on 
similar actions that the support is likely to generate positive impacts on SME employment, 
turnover and total assets. This is described in further detail under the EFG heading below. 

Based on the portfolio analysis, including the analysis of KPIs and targets (see  Table 4 
below), it is possible to conclude that the COSME financial instruments met or exceeded 
their  final  targets  in  terms  of  number  of  SMEs  supported,  the  overall  volume  of 
investments and leverage. 

Table 4 – Achievements of the COSME financial instruments against targets 

Indicator 

Target 

EFG 
Number of VC-backed 
firms (final recipients) 
Overall volume invested 
Leverage ratio 
Additionality  

LGF 

SMEs receiving 
guaranteed loans (final 
recipients) 
Overall financing volume 
Leverage ratio 

Additionality 

Between 360 and 540 

Between EUR 2.6 and EUR 4 billion 
1:4 - 1:699 
More than 62% of the final recipients consider that 
financial support received could not have been 
obtained by other means 

220 000 - 330 000 

EUR 14.3-21.5 billion 
1:20 – 1:30 

More than 64% of the final recipients consider that 
financial support received could not have been 
obtained by other means 

Achieved as of 31 
December 2022 

521 

EUR 3.9 billion 
1:11100 
Not available 

873 751 

EUR 54 billion 
1:21 
85% 

Source: elaboration for the supporting study based on EIF monitoring data and target data (Annex to the 
COSME Regulation and COSME Work Programme 2020)101 

Loan Guarantee Facility (LGF)  
Looking at specific results achieved by financial instrument, COSME LGF supported 873 
751 distinct SMEs through 1 173 780 transactions (as, for example, some SMEs received 
more than one loan). As of 31 December 2022, EUR 54 billion had actually been provided 

98 Financial instruments accounted for 60.42% of the total implemented budget for the programme. Source European 

Commission, DG GROW. 

99  EUR  1  from  the  Union  budget  will  result  in  EUR  4-6  in  equity  investments  over  the  lifetime  of  the  COSME 

programme. 

100 Calculated as total volume invested, divided by the COSME EFG budget committed. 
101 European Commission. 2020. Commission implementing decision COSME WP 2020, 

https://ec.europa.eu/docsroom/documents/43487. 

26 

 
 
 
 
 
 
 
to those distinct SMEs. The financial intermediaries involved in LGF transactions were 
mainly  commercial  banks  and  guarantee  institutions,  covering  the  EU  and  COSME 
associated countries (see Annex VI). 

The LGF demonstrated strong additionality. It offered financial intermediaries and riskier 
SMEs a product that went above and beyond what was available from alternative public 
sources of finance (see section 4.2). According to the interviewed financial intermediaries, 
the  LGF  addressed  market  failures  (leading  to  a  lack  of  finance  for  SMEs)  in  a  more 
effective way than other national public programmes. Also, 19/24 respondents to the public 
consultation  declared  that  COSME  provided  higher  or  similar  support  than  other 
comparable national or regional programmes. 

The supporting study also found that no commercial product could rival the advantages 
offered by the LGF, namely the attractive guarantee rate, the reputational benefit due to 
the support provided by the EU and the EIF and the fact that the guarantee was considered 
state aid consistent. Participants in the survey of financial intermediaries declared that their 
lending  activity  to  SMEs  would  have  been  considerably  different  without  the  LGF 
guarantee. About 66% of survey respondents indicated that SME loans would have had 
higher collateral requirements, or higher costs (52%), or the volume of lending would have 
been reduced (59%). Financial intermediaries interviewed also confirmed that without the 
LGF they would have reduced their lending to SMEs, since most of them would not have 
had  sufficient  collateral  to  back  their  loan.  The  absence  of  LGF  support  would  have 
significantly increased the barriers to finance for riskier SMEs.  

For  SMEs  that  benefited  from  COSME  LGF,  there  were  few  comparable  alternatives 
available. Respondents to the SME survey conducted for the supporting study, were asked 
to report what would have happened to their business or investment project if they had not 
received the EU-guaranteed COSME financing support. Only 12% of respondents reported 
that they would have been able to secure financing from alternative sources at similar terms 
and conditions and without having to downsize their investment. The others indicated that 
they would have opted for loans that had either higher interest rate (59% 19/32) or worse 
collateral requirements (53% 17/32).102 The consultation also asked SMEs to share their 
opinions on the processes, terms and conditions of the EU-guaranteed financing compared 
to offers available on the market when they applied for the support. A majority stated that, 
compared to offers that were available on the market at the same time, the LGF guarantee 
was  either  much  more  favourable  or  favourable  in  relation  to  the  overall  terms  and 
conditions (71% 65/92), as well as the interest rate they had to pay on the borrowing (61% 
56/92),  the  collateral/security  requirements  (65%  60/92),  the  speed  of  processing  the 
application (51% 47/92), and the repayment period (50% (46/92).  

COSME  LGF  had  a  positive  impact  on  enhancing  SMEs'  access  to  finance. 
Contributions  to  the  targeted  consultation  emphasise  that  this  is  perhaps  the  most 
significant advantage of COSME: its ability to bridge the gap for businesses that would 
otherwise struggle secure financing or, if they did, would face less favourable terms, such 
as  higher  interest  rates  and  stringent  collateral  requirements  (see  the  statistics  in  the 
previous paragraph on how the LGF compared to other offers on the market). A substantial 
majority  of  financial  institution  respondents  (82%;  32/39)  reported  that  their  primary 
motive for seeking COSME loan guarantees was to extend lending opportunities to viable 
SMEs with insufficient collateral. The financial intermediaries that were interviewed for 
the supporting study also emphasised that LGF allowed them to offer loans to riskier 

102 The question allowed multiple choices. 

27 

 
 
SMEs  on  more  favourable  terms  than  they  typically  would  have.  Since  the  LGF 
guarantee was provided at no cost, financial institutions had greater flexibility to pass on 
financial benefits to their SME clients. This translated into lower interest rates compared 
to similar client profiles and longer loan maturities. 

COSME LGF played a role in expanding access to finance for specific segments of 
the SME market, particularly those experiencing higher loan rejection rates, such as 
sole proprietorships, microenterprises, and start-ups (see  Annex VI). However, it is 
worth noting that this outcome was not universal. It depended on the market strategies and 
deliberate choices made by financial intermediaries. For instance, it was more pronounced 
when financial intermediaries had a dedicated focus on these sectors, such as commercial 
banks providing microcredit and small loans, or leasing companies predominantly serving 
microenterprises.  In  some  cases,  national  promotional  banks  and  guarantee  institutions 
also played a significant role in shaping these outcomes by focusing explicitly on start-ups. 

Impacts on LGF final recipients’ economic performance 
LGF final recipients exhibit very high survival rates in the years that followed the loans. 
Based on Orbis data, on average only 0.6% of companies were liquidated one year after 
having received the loan, while the share increases up to 6% after five years. This is even 
more  surprising  if  compared  with  the  EU27  average  survival  rates  in  2020  that  ranged 
between  85.7%  after  one  year  and  58.4%  after  four  years103  (i.e.  14.3%  and  41.6% 
respectively did not survive). This analysis alone could not establish a causal link between 
company  performance  and  the  support  received,  which  is  instead  captured  by  the 
counterfactual analysis. Surprisingly, the share of active businesses after the intervention 
is broadly uniform over all the years of investment. 

Table 5: Share of active firms by year of first LGF financing and years after investment 

Cohort 

t+1 

t+2 

t+3 

t+4 

t+5 

t+6 

t+7 

t+8 

t+9 

2014 

98.9% 

98.9% 

98.9% 

97.8% 

94.4% 

92.2% 

88.9% 

86.7% 

86.7% 

2015 

99.1% 

97.7% 

96.0% 

94.3% 

93.1% 

91.9% 

90.5% 

89.8% 

2016 

99.1% 

97.6% 

95.9% 

94.4% 

93.1% 

91.6% 

90.7% 

2017 

99.2% 

97.9% 

96.6% 

95.4% 

93.9% 

93.0% 

2018 

99.3% 

98.4% 

97.2% 

95.5% 

94.6% 

2019 

99.7% 

99.0% 

97.5% 

96.4% 

2020 

99.5% 

98.6% 

97.7% 

2021 

99.4% 

98.9% 

2022 

99.7% 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Total 

90.6% 
Source: Elaboration by the consultant for the supporting study based on Orbis data 

95.4% 

93.9% 

99.4% 

98.3% 

97.0% 

92.3% 

89.7% 

86.7% 

The analysis was also narrowed to SMEs that received a LGF guaranteed loan between 
2014 and 2020 and observed the evolution in the share of active enterprises up to three 
years after having received the loan across countries and company size. The share of active 

103 Data are drawn from Eurostat - Business demography by size class and NACE Rev. 2 activity (2004-2020) 

28 

 
 
enterprises amongst small enterprises is lower compared to micro-enterprises which were 
expected to be more vulnerable to shocks. 

Figure 4.1: Share of active LGF final recipients by size and years after investment (loans 
disbursed 2014-2020) 

Source: Elaborations for the supporting study based on Orbis data 

Across countries, the share of active enterprises is quite homogeneous. A few exceptions 
are Croatia, Denmark, Finland, Kosovo*, Luxembourg, the Netherlands, Sweden and the 
United  Kingdom  where  the  share  of  active  enterprises  each  year  after  the  loan  is 
significantly below the average. 

Despite the limited increase in the absolute number of employees, it is worth noting that 
the growth rates between one year before having received the guaranteed loan and three 
years after is more significant. On the one hand, the average growth rates in the number of 
employees  equals  20%  for  micro-enterprises,  and  so  do  the  growth  rates  in  the  cost  of 
personnel. On the other hand, the average growth rates in the number of employees equals 
11% for small enterprises and 19% when the cost of personnel is concerned. In contrast, 
medium-sized  enterprises  have  experienced  on  average  an  increase  in  their  number  of 
employees (and so their average costs of personnel) both in absolute and relative terms. As 
far as the turnover and the total assets are concerned, all SMEs have shown positive trends, 
even though medium-sized enterprises have experienced larger growth rates. 

Considering the wider macro-economic context and the significant challenges SMEs faced 
in the aftermath of the financial crisis these results are nonetheless positive. 

Figure 4.2: Evolution in LGF final recipients’ employment before and after the loan, by 
size 

29 

 
 
 
Source: Elaborations for the supporting study based on Orbis data 

Since the trends analysis does not allow to draw any causal conclusion on the  observed 
patterns, a counterfactual analysis was conducted as part of the supporting study to estimate 
the net causal impact of the LGF intervention on SMEs’ economic performance (number 
of employees, cost of personnel, turnover, total assets).104 The analysis has revealed that 
the LGF support led to an increase in the number of employees but it did not lead to an 
increase in turnover, and total assets as compared to not-yet-treated companies (see Figure 
below). These results only partly align with existing  studies on the predecessor of LGF 
(e.g., CIP and MAP). Previous studies indeed found a positive impact of EU guarantee 
loans on SME growth in terms of employment, sales, and profits, even though the results 
are  not  always  consistent  across  countries  and  schemes.  The  results  obtained  in  the 
supporting study are to be considered with caution because of a series of limitations to the 
overall analysis105.  

104 Details on the counterfactual analysis are provided in the methodological annex. 
105 For example, the sample size is not fully representative. While Italian companies are well represented in the final 
sample, SMEs from other key countries, such as Spain and France, are not. Another potential issue is that, due to data 
limitations, the consultant for the supporting study carried out the analysis exploiting a sub-sample of companies that 
received  the  LGF  guaranteed  loan between  2015  and  2020,  while  the  intervention  spanned  from 2014 until 2022. 
Moreover, the positive trends observed amongst medium-sized enterprises are not fully reflected in the overall net 
causal  impact  because,  among  other  factors,  the  share  of  medium-sized  enterprises  equals  only 1%  of  the  overall 
sample of final recipients. 

30 

 
 
 
 
 
 
Figure  4.3:  Evolution  of  the  Average  Treatment  on  Treated  on  economic 
performance before and after the intervention (average 2015 – 2020) 

Number of employees 

Cost of personnel 

Turnover 

Total assets 

Note: In the figures above, the dot points equal the estimates of the ATT in the pre-treatment and post-
treatment period, while the bars represent the confidence intervals at 95%.106 
Source: Elaborations for the supporting study based on Orbis data 

106 ATT refers to the effect of the treatment for those who actually received treatment (in this case, the impact of LGF 
finance on final recipients). 

31 

 
 
 
 
 
 
 
 
 
 
The counterfactual analysis demonstrated that LGF had a positive and significant impact 
on the number of employees and the survival rates over time, but did not lead to an increase 
in  turnover,  cost  of  personnel  and  total  assets  of  beneficiaries  as  compared  to  not-yet-
treated companies. These results only partly align with earlier studies on the predecessors 
of LGF (e.g., CIP and MAP).107,108. These earlier studies observed a positive impact of EU 
guaranteed loans on SME growth in terms of employment, sales, and profits, even though 
the results are not always consistent across countries and schemes. As explained earlier, 
the results of the counterfactual analysis for COSME LGF cannot be directly compared 
with the previous surveys, due to the alternative methodological approach followed. The 
results of the supporting study are therefore considered likely to (at least partially) under-
represent the full extent of the economic impacts of the programme. 

One possible explanation for these different results is that the control group of businesses 
that had “not yet benefited” from LGF support were better prepared109 than the businesses 
used as a control group for previous studies (that did not subsequently benefit from any 
funding from financial instruments at all). 

The financial intermediaries interviewed for the supporting study reported that, in many 
instances,  the  LGF  guaranteed  loans  were  used  to  support  the  day-to-day  operations  of 
companies. The loans backed by the LGF were useful to SMEs, but the size of the loans, 
which were capped at EUR 150 000, did not allow firms to undertake sizeable investments.  

This data underscores the utility of LGF-backed loans in supporting SMEs but suggests 
that they did not play a disruptive or catalytic role in promoting substantial growth 
for these businesses. The LGF support was primarily directed towards securing working 
capital  or  acquiring/leasing  small-scale  equipment.  These  investments  were  vital  for 
maintaining  the  enterprises’  operational  continuity,  by  providing  access  to  finance  to 
SMEs facing difficulties due to their higher risk profiles. However, on average, they did 
not result in business expansion.  

Equity Facility for Growth (EFG)  

(see Table 4 above for related KPIs) 

The funds benefiting from EFG support invested in portfolios of final recipients including 
COSME EFG eligible firms110. The investments in COSME EFG Eligible firms amounted 
to EUR 3.9 billion distributed through investments in 554 distinct SMEs as reported by the 
EIF as of December 2022. There was geographic concentration of equity investments, as 
the majority of the investment (53%) went to enterprises located in Germany, France and 
the United Kingdom.111 This is to be expected considering that private equity (PE) / venture 
capital (VC) activity is often concentrated in geographical hubs and the availability of VC 
has a positive effect on the demand for external equity (i.e. firms are more likely to seek 

107  Brault,  J.,  and  Signore,  S.  (2019).  The  real  effects  of  EU  loan  guarantee  schemes  for  SMEs:  A  pan-
European  assessment.  EIF  Working  Paper  2019/56,  EIF  Research  &  Market  Analysis.  June  2019.  
http://www.eif.org/news_centre/publications/EIF_Working_Paper_2019_56.htm 

108  Bertoni,  F.,  Colombo,  M.,  and  Quas,  A.  (2023).  The  long-term  effects  of  loan  guarantees  on  SME 
performance. Journal of Corporate Finance. The long-term effects of loan guarantees on SME performance 
- ScienceDirect 

109 For example, they could have been in the process of improving their business plans in preparation for 

seeking additional finance in future. 

110  The  eligible  final  recipients  for  the  core  EFG  operations  were  SMEs  established  and  operating  in  a  COSME 

Participating Country 

111 COSME EFG Quarterly Report  December 2022. 

32 

 
 
external equity when the local availability of VC is high).112 It is important to note that the 
uptake of the EFG coincided with the development of the European equity market.113 

The average ticket size (amount of finance provided to an SME recipient) under EFG 
backed funds is around EUR 5 million, which is about three times the average European 
risk capital ticket size. This demonstrates that COSME has contributed to increasing the 
average volume of investments made by European PE/VC funds, addressing a structural 
weakness identified by the InvestEU impact assessment114 and in numerous studies, such 
as the feasibility  study to  examine the potential  for Venture Capital Funds-of-Funds.115 
Moreover, it is worth mentioning that despite its initially slow rollout, the EFG surpassed 
its intended leverage effect. 

Interviewed  fund  managers  for  the  EFG  confirmed  that  the  EIF  involvement  helped 
unlock  fundraising  by  crowding-in  other  private  investors  even  if  it  still  remains 
challenging for a first-time team. It contributed to sustaining the level of capital allocation 
with the effect of achieving the outputs documented above. 
In  contrast,  the  cap  imposed  on  EFG  investment116  is  perceived  by  the  financial 
intermediaries interviewed to  have been a barrier to  increasing  the  effectiveness  of this 
instrument. Yet, fund managers also complain about the absence of a matchmaking process 
between funds and other investors in addition to EIF. Sharing a list of investors making 
similar  investments  in  Europe  and  putting  in  contact,  e.g.,  limited  partners  (LPs)117 and 
venture capitalists would enlarge the outreach of the instrument. 

COSME EFG had a positive impact on enhancing SMEs' access to finance and stimulating 
the creation of the VC/PE market which is underdeveloped in relation to the U.S. 11% of 
(15) interviewed investees stated that they used the equity investment received to develop 
new products they probably would not be able to develop otherwise. 

112 EIF. 2016. The European venture capital landscape: an EIF perspective Volume I: The impact of EIF on the VC 

ecosystem. 

113 Private equity and venture capital markets grew rapidly in the EU starting from 2010/2011 and the total equity amount 
invested in European companies increased steeply in 2019 and continued to grow in 2020 and 2021, see: Kraemer-
Eis, H., Botsari, A., Gvetadze, S., Lang, F. and Torfs, W. 2021. The European Small Business Finance Outlook 2022. 

114 SWD(2018) 314 final. 
115 Assessing the potential for EU investment in venture capital and other risk capital fund of funds, Final report, available 
at: https://op.europa.eu/en/publication-detail/-/publication/8557bb3e-e10a-11e5-8a50-01aa75ed71a1/language-en.  
116 Each EFG Investment shall represent: (i) at least 7.5% of total commitments to the EFG financial intermediary at the 
closing  at  which  the  EFG  investment  is  made;  and  (ii)  up  to  25%  of  the  total  commitments  to  the  EFG  financial 
intermediary at any closing. In any event, the maximum size of the EFG investment in an EFG financial intermediary 
shall be limited to EUR 30 million or equivalent. 

117 Limited partners are entities or individuals who contribute capital to venture capital funds. 

33 

 
 
EFG  final  recipients  exhibit  very  high  survival  rates  in  the  years  that  followed  the 
investments.118 Out of those found in Orbis, for all years of the intervention except 2018 
and  2019,  none  of  EFG  related  final  recipients  were  liquidated  one  year  after  having 
received the investment, while the share increases to only 3.4% after five years. The results 
are  even  more  positive  if  compared  with  the  EU27  average  survival  rates  in  2020  that 
ranged between 85.7% after one year and 58.4% after four years.119 This analysis could 
not establish a causal link between company performance and the support received, which 
instead  could  only  be  captured  by  the  counterfactual  analysis.  The  share  of  active 
businesses two years after the intervention is 100% for the investment years 2014-2017,  
and falls by 4% to 96% for intervention year 2018, and ranges between 97.8-98.8 % for 
2020-2021. These rates remain nevertheless high when compared with the EU27 average 
survival rates referred to above. 

Table 6: EFG survival rates by year of investment and period after the intervention 

Cohort 

t+1 

t+2 

t+3 

t+4 

t+5 

t+6 

t+7 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

100.0% 

100.0% 

100.0% 

100.0% 

0.0% 

0.0% 

0.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

100.0% 

96.0% 

96.0% 

94.4% 

96.0% 

98.1% 

100.0% 

100.0% 

100.0% 

96.0% 

96.3% 

94.4% 

96.0% 

98.1% 

97.8% 

98.8% 

Total 

99.4% 

98.4% 

96.0% 

96.4% 

96.6% 

97.0% 

93.8% 

Source: Elaborations for the supporting study based on Orbis data 

Sample 
size 

1 

6 

9 

17 

25 

54 

90 

167 

94 

463 

The survival rates differ somewhat across countries. While in the United Kingdom 95.5% 
of the 67 supported companies were still active after two years from the intervention, the 
share lowers to 77.70% for the 130 final recipients in Germany, and to 25% in Slovenia 
and Slovakia. 

The LGF performed very well overall on survival rates by size class as can be seen in the 
table below. SME survival rates one year after the intervention were consistently good for 
micro,  small,  and  medium-sized  businesses.  Surprisingly,  micro  enterprises  had  higher 
survival rates than small or medium-sized businesses two years after the intervention. The 
table also displays data on mid-caps (based on size category information from Orbis), but 
it should be noted that at the time that LGF support was provided all final recipients were 
SMEs.   

118 These results might be overestimating the survival rates due to lag in reporting company defaults in the Orbis database. 
119 Data are drawn from Eurostat - Business demography by size class and NACE Rev. 2 activity (2004-2020). 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 7: EFG survival rates by company size and period after the intervention 

Size 

t+1 

t+2 

Sample 

Micro 

97.2% 

97.2% 

72 

Small 

97.9% 

95.9% 

146 

Medium 

97.0% 

96.0% 

100 

Mid-cap  100.0%  100.0% 

16 

Source: own elaborations on Orbis data 

EFG final recipients have experienced significant positive trends in their economic 
performance, as well as high survival rates. As shown in the table below, regardless of 
their size at the time of investment, SMEs have grown in terms of employment, turnover, 
and total assets. On average, they have almost doubled the number of employees from the 
year before to the year after the intervention. The EFG instruments have indeed targeted 
the equity needs of young and fast-growing enterprises. Whilst this is positive, a causal 
link could not yet be formally established for the full set of SME beneficiaries as most 
received support from 2021 and the methodology for the counterfactual analysis requires 
data from 3 years after the intervention.120 Most equity investments were provided after 
2021. It was therefore not possible to document their performance in the three years after 
the  investment.  Nevertheless,  previous  studies  on  similar  schemes  supported  by  EU 
institutions, showed a positive causal relationship between the provision of equity support 
and the economic performance of SMEs (e.g., employment, turnover, assets).121 Therefore, 
it  can  be  assumed  that  the  positive  impacts  observed  through  the  descriptive  statistics 
would hold also in a counterfactual scenario if the analysis is replicated in the future once 
all expected impacts have materialised. In line with this positive expectation, the average 
ratio of job creation at the end of 2019 was 1.44.122 

Table 8: EFG Evolution in key performance indicators before and after the intervention 
(average numbers per company) 

Size class 

t-1 

t 

t+1 

Delta123 year after 
year before 

Sample size 

Number of employees 

Micro 

Small 

Medium 

4 

19 

76 

Turnover (TH EUR) 

5 

27 

106 

8 

39 

139 

4 

20 

62 

20 

42 

34 

120 A necessary condition for a counterfactual analysis of this type is access to robust data for both the treated (beneficiary 
SMEs) and not-yet treated (control groups) entities for 2-3 years before and after the treatment. In addition, it should 
be noted that it generally takes several months after the end of the relevant financial year for company data to be 
entered in Orbis. 

121 EIF (2021), The European venture capital landscape: an EIF perspective Volume VI: The impact of VC on the exit 

and innovation outcomes of EIF-backed start-ups. EIF (2019), The economic impact of VC investments supported 
by the EIF. EIBG (2022), Evaluation of EIB Group Equity and quasi-equity support for SMEs and midcaps. Final 
report. 

122 Average job creation is the ratio of employees in 2019 (regardless of the year of investment) to employees at the 

time of the investment. Source: Growth & Employment report 31-12-2019. 

123 Difference between the variable in time t+1 (year after the intervention) and t-1 (year before the intervention). 

35 

 
 
Size class 

t-1 

t 

t+1 

Delta123 year after 
year before 

Sample size 

Micro 

Small 

2 012 

4 173 

2 955 

3 730 

3 444 

6 874 

Medium 

17 714 

21 342 

27 082 

Total assets (TH EUR) 

Micro 

Small 

2 102 

8 948 

5 792 

27 976 

14 631 

16 406 

Medium 

17 045 

32 081 

43 017 

1 432 

2 701 

9 368 

25 874 

7 458 

25 972 

6 

17 

23 

19 

38 

36 

Source: Elaborations for the supporting study based on Orbis data.  

The expected positive impacts on the economic performance of EFG-backed companies 
were further confirmed by interviewed funds. As an illustrative example, one fund declared 
to  have  successfully  divested  itself  from  nine  different  companies  with  performance  in 
terms of turnover ranging between 2x and 3x as compared to other firms in the targeted 
industry. Among the companies supported by the interviewee the number of jobs created 
was  between  500  and  1  000.  Despite  these  positive  outcomes,  the  interviewee 
acknowledged that a high-risk component permeates these investments which can result in 
a portfolio with a relatively high number of companies filing for bankruptcy. 

Overall,  combining  the  core  EFG  operations  with  the  Pan  European  Venture  Capital 
Funds-of-Funds  initiative,  evidence  shows  that  the  EGF  enhanced  access  to  finance, 
particularly in the form of equity products, in countries where supply was less developed.  

4.1.2  Specific objective 2 SO2 -  Access to markets 

Table 9: KPIs and targets for EEN set in the Regulation 

EEN KPIs as per the Regulation 
Number of cross-border 
partnership agreements 
signed124 
Recognition of the EEN 
amongst SME population 

Client satisfaction rate (% 
SMEs stating satisfaction, 
added-value of specific service 
provided by EEN) 
Number of SMEs receiving 
support services 

Long term target (2020) 
Partnership agreements signed: 
2 500/year 

18 701 

Results ( year 2020) 

Increase in the recognition of 
EEN amongst SME population 
compared to baseline (last 
known result in 2015 (8% of 
SMEs aware of EEN125) 
Client satisfaction rate > 82% 

Not measured since 2015  

92%126 

500 000 per year (for COSME 
countries) 

1 957 822 (for COSME countries)127 

124 Partnership Agreements are signed between organisations to make the cooperation official following a successful 

matching in the EEN matchmaking database. 

125 The 2015 Eurobarometer included a question on SME awareness of EEN. This survey was not repeated in 
the  original  format.  The  2022  edition  of  the  Flash  Eurobarometer  focused  on  small  and  medium  enterprises 
(SMEs), resource efficiency and green markets. 

126 Data from the EEN 2021 client satisfaction survey. 
127 Data on the EEN provided by EISMEA. 

36 

 
 
 
 
EEN KPIs as per the Regulation 
Number of SMEs using digital 
services (including electronic 
information services) provided 
by EEN 
In the EEN 2020 Final activity report, the Commission noted that the aggregated high-level targets had been 
achieved.129 

Long term target (2020) 
2.3 million SMEs per year using 
digital services 

21.5 million SMEs128  

Results ( year 2020) 

Source: Study Final evaluation of COSME (CSES) based on data provided by EISMEA 

Enterprise Europe Network 

The  COSME  Regulation  set  specific  targets  and  indicators  in  relation  to  the  EEN 
performance130 which were reached and often exceeded.  

The  satisfaction  rate  of  client  SMEs  has  been  high  at  around  85%  throughout  COSME 
implementation increasing to 92% in 2019-20.131  EEN members interviewed reported that 
the most effective services were advisory services, which create competences within SMEs 
and  help  them  innovate  and  grow,  and  B2B  or  matchmaking  events  that  foster  new 
partnerships.  Some  areas  for  further  improvement  were  mentioned  by  individual 
interviewees (a need to focus quality checks on content more than on form and to better 
differentiate between offers for basic common products).  

In the targeted consultation of EEN’s SME clients132 the vast majority of respondents (91%  
-29 unique SMEs/32) confirmed that EEN’s services had resulted in one or several positive 
impacts for their business (in particular, safeguarding the number of employees (63% of 
respondents),  expanding  to  new  geographical  markets  (63%),  and  developing  new 
products  or  services  (59%),  and  maintaining  turnover  (59%)  or  increasing  turnover 
(56%)133.  These positive impacts were also confirmed by past consultations (notably the 
2017 interim evaluation134, which also refers to an earlier impact study). 

The impact survey conducted by the EEN for EASME for the 2015-2016 period identified 
areas where the EEN had positive impacts.135 such as improved market share in existing 
markets (57%) and increased turnover (67%), while job growth was less supported (only 
32%).136  The  COSME  interim  evaluation  survey  showed  that  more  than  75%  of  client 
SMEs had entered a new market, including an international market for more than 20%. 
More than half of respondents attributed these results at least to some extent to the services 
provided by EEN.137 In addition, the interim evaluation of COSME showed that SMEs that 

128 Data on the EEN provided by EISMEA. 
129 Special Report No 07/2022: SME internationalisation instruments 
130 Annex to Regulation (EU) No 1287/2013. 
131 Based on a review of EEN satisfaction surveys, 86% of clients were satisfied or very satisfied with network services 
in  2015-2016,  88%  in  2017-2018  and  85%  in  2019-2020.  In  2020-2021,  92%  of  EEN  clients  confirmed  their 
satisfaction, see also COSME Monitoring Report 2017, 2019 and 2020 respectively.  

132 Maintain the number of employees (63% of respondents 20/32, expand to new geographical markets (63% 20/32),   

maintain their turnover  (59% 19/32), increase their turnover (56% 18/32). 

133 Of the SMEs that responded to this survey 91%  (29 unique SMEs/32) reported one or several positive impacts: The 
following impacts were most widespread: maintain the number of employees in their firm (63% of respondents 20/32, 
expand to new geographical markets (63%  20/32) and maintain their turnover  (59% 19/32) or increase their turnover 
(56% 18/32). 

134 The interim evaluation confirmed that the EEN services mainly supported SMEs. The interim evaluation mentioned 
the  quality  of  EEN  services,  leading  to  (expected)  growth  in  turnover  and  especially,  entry  to  new  (geographical) 
markets, both in Europe and beyond. It also indicated that the beneficiaries most often cited an improved performance 
in existing markets and increased turnover as a result of EEN services. Job growth seemed to be much less supported 
in this case. 

135 Data for the 2015-2016 EEN impact survey was presented in the 2017 interim evaluation of the COSME programme.  
136 N= 1 579 respondents to this question.  
137 European Commission. 2017. Interim evaluation of the COSME programme. 

37 

 
 
used the EEN services performed better than SMEs that did not, with 6.45% more turnover 
growth and 9.45% more employment growth. However, 50% of SMEs did not attribute 
any of their growth to EEN.138 

The majority of EEN SME clients responding to the  targeted survey for this evaluation 
stated that the EEN services had a positive impact on their business139 overall (21/32 or 
66%  ‘greatly’,  8/32  or  25%  ‘to  some  extent’).140  In  another  survey  of  EEN  member 
organisations  conducted  for  the  supporting  study,  49%  (33/68)  of  EEN  member 
respondents believe that the EEN services they provided have been effective in helping 
SMEs to access international markets to a great extent and 49% (33/68) to a reasonable 
extent.141 A large majority of SME clients (74% or 25/34) also stated that the EEN support 
received was effective in responding to their needs or in addressing the barriers they had.142  

A  key  success  factor  for  the  effectiveness  of  the  EEN  services  is  the  profile  of  EEN 
members, and in particular their credibility and close ties with their regional and national 
industrial and innovation ecosystems.143 The networking and knowledge-sharing activities 
between EEN members, training and the various EEN events are also key to ensuring the 
effective functioning and quality of services.144 It should be noted that while collectively 
most  of  the  targets  were  achieved,  the  achievements  in  the  number  of  partnership 
agreements signed and advisory services vary between countries and consortia 145 146 

From  2017,  EEN  scale-up  advisors  were  put  in  place  to  help  young  innovative  SMEs 
develop their activities outside their home country. As of 2019, support for start-ups and 
scale-up enterprises became part of EEN’s core services. This implies, in a longer-term 
perspective, a shift from demand-based service provision to a long-term connection, with 
the  provision  of  higher  added-value  services  which  can  be  enhanced  by  efficient 
signposting within EEN and by identifying external stakeholders to support clients’ needs 
in  more  specialist  areas.147  There  is  strong  continuity  in  the  EEN  membership.  The 
majority  (72%)  of  EEN  Network  members  have  remained  the  same  under  COSME 
compared  to  the  previous  programming  period.  This  has  allowed  knowledge  and 
relationships between EEN members to be consolidated over time.  

EEN also helps SMEs to plan their twin transitions (sustainable and digital). 

In light of the good performance of the EEN so far, it is planned to continue this service at 
least until 2027.148  

138 Interview feedback.  
139  Some  EEN  SME  clients  reported  an  increase  in  turnover  (between  12  and  2613%  in  the  2015-2023  period). 
Furthermore, SME clients reported an increase in their staff of up to 157% while 2 SMEs reported a decrease between 
17 and 54% 

140 N= 32 respondents to this question.  
141 N= 68 respondents to this question.   
142 N= 34 respondents to this question.   
143 European Commission. 2017. Interim evaluation of the COSME programme. 
144  In  the  2015-2016 period,  about two  thirds  of  the  EEN  staff  participated  in  EEN  network  training.  In  the  interim 
evaluation (2017) EEN members reported having increased their expertise and ability to provide services to their client 
SMEs by participating in EEN. EEN staff also received other local training from their host organisations and local 
EEN team members. 

145 European Court of Auditors. 2022. Special report 07/2022: SME internationalisation instruments 
146  For  example,  from  24  achievements  per  FTE  head  of  staff  in  Ireland  and  20  in  Lithuania,  to  2-4  in  many  other 

countries.  

147 COSME Monitoring Report 2018. 
148 Continuity of flagship actions such as EEN, EYE and clusters support will be ensured throughout the 2021-2027 
period.  The  current  EEN  covers  the  period  2022-2025  (Call  for  proposals:  https://ec.europa.eu/info/funding-
tenders/opportunities/docs/2021-2027/smp/wp-call/2021/call-fiche_smp-cosme-2021-een_en.pdf).  Another  call  is 
planned for the period 2025-2028.  

38 

 
 
Box 1: Summary of an EEN success story - Italy  

The Italian biomedical company has developed two products: an Xray-free mammogram 
for breast cancer detection, and a device for brain stroke detection and classification. In 
2017, the EEN provided the company with a coach to help them review their business 
and  development  plan  and  develop  their  presentations  for  commercialising  their 
products.  In  2017  and  2018  the  company  obtained  two  Horizon  2020  grants  which 
allowed it to expand its international clinical trials in other European hospitals. It was 
subsequently awarded a Marie Curie project in a consortium with 13 other international 
partners which allowed it to deepen its research. The EEN has been helping the company 
for 6 years and this SME has experienced a steady growth, from a few associates to 20 
staff members. The EEN played an important role in this development thanks to their 
advice and networking services. 

 See Annex VIII for other examples 

Your Europe Business portal and Single Digital Gateway 

Table 10: KPIs and targets - Single Digital Gateway (SDG) 

KPI 

Targets 

Results 

Preparatory study (2018), successful launch 
of beta version (2019), and of the SDG in 
2020 

Beta version: 2019 

SDG: December 2020 

Preparatory  study,  beta  version,  and  SDG 
successfully delivered as planned. 

Number of visits to Your Europe Business  Year on year increase by 

2019: 7 766 937 

User  satisfaction  figures  for  the  Your 
Europe  Business  component  of  the  SDG 
(based on user satisfaction surveys149) 

10% 

2020: 8 217 193 (increase by 5.8%) 

2021: 7 166 623 (decrease by 12.8%) 

90% positive rating 

2019: 93% positive rating 

2020: 94% positive rating 

2021: 92% positive rating 

Source: Elaborations for the supporting study based on COSME Monitoring Reports 2019 and 2020 

The Your Europe Business portal registered high satisfaction rates for the service provided. 
The overall user satisfaction rate remained above the target figure of 90%, reaching 93% 
in 2019 and 94% in 2020.150  . The key success factors are the multi-lingual format and its 
links to other national and EU support. In addition, the portal can help SMEs clarify simple 
issues  by  themselves,  freeing  up  time  for  EEN  to  help  SMEs  with  more  complex 
questions.151  

149 Further information on the YEB annual user surveys: 
-  2019: 1 349 responses, data gathering period: 11 February to 11 March 2019 
-  2020: 1 354 responses, data gathering period: 3 February to 6 March 2020 
- 2021: 1 634 responses, data gathering period: 1 February to 7 March 2021 
150 COSME Monitoring Reports 2019 and 2020. 
151 European Commission. 2017. Interim evaluation of the COSME programme. 

39 

 
 
 
 
Since the launch of the Single Digital Gateway, the number of visits to it has fluctuated, 
ranging from 7.2 million visits (2021) to 8.2 million visits (2020) and the user satisfaction 
remained high (92-94%), as presented in the KPIs in Annex VI. 

EU-Japan Centre for Industrial Cooperation 

Table  11:  Key  KPIs  and  targets  -    EU-Japan  Centre  for  Industrial  Cooperation  (EUJC) 
2020-2022 

KPI 

Targets 

Results 

Business Support - Infodesk (Answer 
EU & Japan-related inquiries within 48 
hours) 

Number of webinars organised covering 
sectors/operational and cross-cultural 
matters in Japan 

Number of meetings facilitated (via 
company missions, brokerage events, or 
incoming missions) 

 N/A 

1016 inquiries processed 

12 webinars 

40 webinars 

500 meetings 

1525 meetings facilitated 

Vulcanus in Japan (2x12-month 
traineeships + reports in Japan) 

2 session with 2x (22 to 
30) participants 

30 traineeships 

N° of  companies listed in the EU Japan 
Centre database 

5 000 in Japan 
36 000 in the EU 
Source: Elaboration for the supporting study based on the Monitoring data  

2 421 
32 722 

A  majority  of  EEN  members  (69%)  and  national  trade  promotion  organisations  (90%) 
reported  satisfaction  with  the  services  provided  and  the  cooperation  with  the  EU-Japan 
Centre. 152 The main reasons for satisfaction include the continuity of the Centre (in place 
since 1987), its role as an EEN member and national contact point for R&I programmes, 
and its close interaction with key stakeholders, including Trade Promotion Organisations 
(which gave the Centre a satisfaction rating of over 90 %) and business associations.153  

Box 2: Example of a success story of the EU-Japan Centre for Industrial Cooperation 

After a stay in Japan during a start-up programme organised in Osaka, the CEO of the 
Spanish company, developer of 3D printers for the food industry, contacted the EU-
Japan Technology Transfer Helpdesk and the EEN at the EU-Japan Centre to find a 
Japanese partner. The Centre connected them with the Japanese company, specialised 
in the distribution of consumer electronic products, organised a meeting and ensured 
follow-up between the two parties. This led to the signature of a partnership agreement 
to boost the sales of printers in the Japanese market.  
Source: Elaboration for the supporting study based on EU-Japan Centre for Industrial 
Cooperation EEN Japan (2021) 

152 European Court of Auditors. 2022. Special report 07/2022: SME internationalisation instruments  
153 European Court of Auditors. 2022. Special report 07/2022: SME internationalisation instruments  

40 

 
 
International IP SME Helpdesks 

Table 12: Key KPIs of the IPR Helpdesks during the COSME period 

Helpdesk 

Target 

Result 

Enquiries answered through the IP helpline 

China 

2015-2022: 3 900 

2015-2022: 4 864 

South-East Asia 

2015-2022: 3 118 

2015-2022: 3 700 

Latin America 

2018-2022: 2 000 

2015-2022: 3 265 

India 

2020-2022: 667 

2020-2022: 627 

All helpdesks 

2015-2018: 2 553 
2018-2020: 3 200 
2020-2022: 3 932 

2015-2018: 4 643 
2018-2020: 3 266 
2020-2022: 4 547 

Matchmaking events supporting EU SMEs 

China 

2015-2022: 155  

2015-2018: 281   

South-East Asia 

2015-2022: 204 

2015-2022: 334  

Latin America 

2018-2022: 128  

2015-2018: 352 

India 

2020-2022: 56  

2020-2022: 59 

All helpdesks 

2015-2018: 90 
2018-2020: 201 
2020-2022: 252 

2015-2018: 432 
2018-2020: 209 
2020-2022: 385 

Training sessions implemented 

China 

2015-2022: 405 (185 
in China, 220 in EU) 

2015-2022: 398 (194 in 
China, 204 in EU) 

South-East Asia 

2015-2022: 320 (170 
in SEA, 170 in EU) 

2015-2022: 269 (139 in 
SEA, 130 in EU) 

Latin America 

2018-2022: 124  

2015-2022: 208 

India 

2020-2022: 58 

2020-2022: 59 

All helpdesks 

2015-2018: 430 
2018-2020: 181 
2020-2022: 296 

2015-2018: 435 
2018-2020: 201 
2020-2022: 298 

Participants in training sessions (SMEs) 

China 

2015-2022: 14 500 

2015-2022: 15 394 

South-East Asia 

2015-2012: 11 600 

2015-2022: 13 539 

Latin America 

2018-2022: 1800 

2018-2022: 3 164 

India 

2020-2022: 900 

2020-2022: 980 

All helpdesks 

2015-2018: 22 500 
2018-2020: 2 700 
2020-2022: 3 600 

2015-2018: 18 644 
2018-2020: 8 224 
2020-2022: 6 189 

Over the 2015-2022 period, the international Intellectual Property Rights SME Helpdesks 
achieved most of their targets by running a successful helpline, developing and updating a 
wide range of business-friendly IP publications, running training sessions with the help of 
Chambers of Commerce and other business  intermediaries, providing  IP  support to  EU 

41 

 
 
 
 
 
SMEs for business field trips and trade fairs and organising matchmaking  events where 
SMEs are supported. 

All KPIs indicators were achieved except for the number of enquiries addressed by the 
India IP helpdesk which was slightly below target (627 queries responded out of a target 
of 667), due to the delay in launching the website.154 The Helpdesks collaborated with the 
EEN  and  sought  cooperation  with  other  EU  actions  (e.g.  SME  Assembly,  EU  Industry 
Days, EIC Days, etc).155  More detailed KPIs with a break-down per contractual period are 
provided in Annex VII. 

In addition, a large majority of IPR Helpdesk users reported satisfaction (around 90%) with 
the Helpdesk services.156 A majority of EEN members (80%) also reported satisfaction on 
the cooperation with the IPR SME Helpdesks.157 The box below presents an example of a 
use case of the Latin America IPR Helpdesk. 

Box 3: Example of case study of the Latin America IPR Helpdesk 

An  Italian-based  SME  providing  tailor-made  solutions  and  the  implementation  of 
machines and plants for agri-food processing contacted the Latin America IPR Helpdesk 
as it was seeking to expand to Argentina and potentially also to Brazil and Mexico. As 
this  SME  had  no  IP  protection  strategy  yet,  the  IP  expert  indicated  priority  areas  to 
address and advised them to identify and prioritise their IP and to estimate the financial 
resources needed and to seek professional IP advice. 

Based on this advice, the company decided to define a proper IP strategy before entering 
the Latin American market. They prioritised trademark registration, ensured that their 
products did not infringe any valid patents in Argentina, contacted a patent engineer to 
see if some of their inventions are patentable, and sought funding for registering IPR. 
The company also started using non-disclosure agreements (NDAs) in negotiations with 
third  parties  and  including  Technological  Protection  Measures  (TPMs)  when  sharing 
information on their products or services.  

The  information  provided  by  the  IPR  Helpdesk  had  an  impact  on  the  company’s 
knowledge  of  IP  and  its  strategy  for  entering  the  Latin  American  market.  It  was 
estimated that the Helpdesk support saved the company EUR 3 000 of costs for legal 
research NDA drafting and legal advice on how to tackle IP cases and saved them four 
months of time that would have been spent in trademark searches on public databases 
and  collecting  information  to  file  trademarks  in  the  different  trademark  and  patent 
offices.  

Clusters actions and internationalisation 

Given that there was an evaluation study of clusters actions in 2021 the efficiency analysis 
for  this  evaluation  relies  largely  on  the  findings  of  this  earlier  study.  Further  evidence 
includes monitoring data and the results of a targeted consultation for various beneficiaries 
including clusters. 

COSME funded 130 initiatives for EUR 51 million that promoted clusters. Clusters actions 
aimed to improve the competitiveness of SMEs by strengthening their capacity to identify 

154 It responded to 627 queries. Overall for the 2020-2022 period the 4 international IP SME helpdesks responded to 

4547 queries, exceeding the target of 3952 queries. 

155 EISMEA. 2023. COSME Work Programme 2020, International IP SME Helpdesks, Synthesis report. 
156 Data provided by EISMEA. 
157 European Court of Auditors. 2022. Special report 07/2022: SME internationalisation instruments  

42 

 
 
growth opportunities internationally, innovate and excel, and develop long-term strategic 
partnerships.  This  was  the  purpose  of  the  Clusters  Go  International  action,  one  of  the 
largest initiatives under COSME SO3.  

A key factor for enhancing the effectiveness of clusters is good cluster management. In 
this  respect,  the  European  Cluster  Excellence  Programme  (ECEP)  funded  under  the 
COSME  programme  was  designed  to  directly  respond  to  this  need  by  developing  a 
methodology for effective cluster management including a quality label scheme and the 
ClusterXchange mobility scheme (launched in 2020) to support short-term exchanges to 
better connect Europe’s industrial ecosystems158.  

Other  important  actors  involved  in  innovation  ecosystems  such  as  research-performing 
institutions and academia more generally also benefited from these actions, for example, 
in  Spain  the  EXXTRA  cluster  in  the  sector  of  rail  supplier  industries.  This  excellence 
cluster  has  over  840  members,  of  which  over  500  are  SMEs  and  130  are 
universities/research centres.  

The 2021 evaluation study on clusters actions showed that the ECEP was effective with 
regards  to  a  number  of  objectives.159 It  was  considered  successful  in  facilitating  cluster 
cooperation and in enhancing cluster management skills. For Member States which did not 
have national-level labelling schemes, ECEP labels added more value and were used as a 
criterion for channelling national funding to cluster organisations.  

Figure 4 - Long lasting effects of the Clusters Excellence initiative160 

The  2021  evaluation  study  of  clusters  also  indicated  that  the  projects  for  establishing 
European  Strategic  Cluster  Partnerships  for  Going  International  (strand  1)  enabled 
the 
beneficiaries 

their  understanding  of 

and  participants 

improve 

to 

158 The labelling scheme focused on continuous learning and benchmarking with other clusters. By 2020, 1,383 cluster 
organisations in Europe had been awarded a European cluster excellence label. Source: European Commission. 2023. 
European Clusters Excellence. 

159 European Commission. 2021. Evaluation Study of and Potential Follow-Up to Cluster Initiatives under COSME, 

H2020 and FPI, Final report. 

160 Source: Evaluation Study of Cluster Initiatives under COSME, H2020 and FPI, 2021 

43 

 
 
 
internationalisation  process  by  working  together  on  a  common  internationalisation 
strategy fostering cross-sectoral cooperation. This enabled them to gain an understanding 
of the complexity involved in the internationalisation process. They established strategic 
partnerships on the European level and in most cases, partnership agreements were signed 
by the involved clusters to merge their expertise and efforts on an international level. 
In total, 53 cluster partnership agreements were signed by clusters involved in the first two 
generations of projects from 2016-17 and 2018-19 respectively.  

This 2021 evaluation also indicated that the work carried out by cluster organisations for 
internationalisation  actions  was  seen  as  a  ‘first  step’  for  SME  internationalisation  and 
linkages to global value chains.  

The targeted survey was addressed to clusters for the supporting study. The respondents 
confirmed  that  the  Cluster  partnerships  for  going  international  successfully  fostered 
collaboration between cluster organisations. A large majority of clusters organisations who 
responded  to  the  survey  considered  the  Clusters  Go  International  action  to  be  effective 
(91%,  20  out  of  22).  The  initiative  contributed  to  addressing  key  obstacles  in  the 
collaboration between clusters such as the lack of awareness around the potential benefits 
deriving from the collaboration (especially the identification of common goals, bottlenecks 
and joint actions), the lack of management capacity in the partner clusters and of financial 
resources  dedicated  to  cluster  cooperation.  Furthermore,  it  offered  SMEs  the  unique 
opportunity  to  create  new  networks  and  develop  new  ideas  with  different  partners  and 
enhanced the expertise of SMEs’ managerial staff in the field of internationalisation.  

This  targeted  survey  also  confirmed  that  one  main  achievement  of  the  action  was  the 
cooperation agreements signed between EU companies and organisations outside the EU 
(e.g.  the  agreements  with  USA  and  Canadian  and  Chinese  cluster  ecosystems  brought 
together many innovative SMEs for further partnership). A key success factor for projects 
supported through this action, was the quality of the partners’ management and the level 
of commitment. Among the possible areas for improvement, survey respondents indicated 
a stronger orientation towards innovation. 

There is a strong view among stakeholders interviewed for this evaluation that clusters and 
business networks are an important and strategic tool to support the internationalisation of 
SMEs. Matchmaking and B2B events with visitors and local companies are particularly 
is  only  one  aspect  of 
appreciated  by  stakeholders  consulted.  However, 
internationalisation.  Export  promotion  programmes  supported  by  national  governments 
and regional organisations are also valued. The financial support provided by national and 
regional public sector bodies was also deemed relevant. 

this 

4.1.3  Specific Objective 3 SO3 - Framework conditions and competitiveness 

The  meetings  with  SME  Envoys  and  other  stakeholders  and,  in  particular,  the  studies 
funded under SO3 such as the SME Performance Review  contributed to the Commission’s 
work  to  monitor  actions  and  reforms  by  Member  States  for  improving  the  business 
environment (the European Semester, the Recovery and Resilience Facility and feedback 
on the National Recovery and Resilience Programmes). Relevant results are given below. 

44 

 
 
For example, good progress  was made  with  reducing  the time and cost  of registering a 
businesses. The REFIT action contributed to reducing burdens imposed by EU legislation.  

Table 13: KPIs and targets - SMEs and reducing administrative burdens 

KPI 

Targets 

Results 

Number of days to set up a business 
This  indicator  and  the  related  indicator 
below  on  the  “cost  of  setting  up  a 
business”, were designed to measure the 
impact  of  work  to  encourage  Member 
States to reduce the administrative burden 
of  setting  up  a  business  (inter  alia,  the 
SME  Performance  Reviews,  and  the 
meetings of the SME Envoys).  

Cost of setting up a business 

Number of Member States that had 
implemented the SME test 

Making the regulatory framework fit for 
purpose (REFIT) 

Marked reduction in 
number of days to set-
up a new SME 
(COSME Regulation) 

There was a steady downward trend in 
the number of days to set up a business 
from 15.63 in 2014 to 11.9 in 2020 but 
the full time series is not directly 
comparable due to a change in the 
methodology used by the World Bank 
for its Doing Business Surveys161. 

Marked reduction in the 
average start-up costs in 
the Union compared to 
baseline 

The original baseline of EUR 372 for 
cost had reduced to EUR 300 in 2018. 
The World Bank replaced this 
methodology by an index in 2019  

2020: a marked 
increase in the number 
of Member States using 
the SME test 

Up to 5 fitness checks 
to be launched over the 
course of the 
programme 

By 2017, 27 Member States were 
already using the SME test 

Already achieved early in the 
programme 
Last measurement: 5 in 2018 

Clusters actions 

The first two generations of Clusters Excellence and Clusters Go International actions met 
or exceeded most of their targets. In particular, the first generation of Clusters Excellence 
projects  showed  excellent  performance  with  the  number  of  supported  SME  exceeding 
expectations by far and the Clusters Go International projects were successful in reaching 
the expected outcomes.   

The final results for the Clusters Excellence 2020 projects are not yet fully available as 
some  projects  were  only  recently  completed162.  Based  on  the  partial  reporting  data 
available  for  the  period  up  to  July  2023,  the  indicators  seem  generally  in  line  with 
expectations. For 5 of the 9 indicators progress towards final targets was well under way163.  
The work programme 2020 projects were hampered by a delay in the development of the 

161 According to data calculated using the old methodology the original baseline of 5.4 days had reduced to 3.1 in 2017, 
and the original baseline of EUR 372 for cost had reduced to EUR 300 in 2018. As from 2019 data on the cost of 
setting up an SME was calculated on the basis of % of income per capita. The index went down from .05 in 2014 to 
.03 in 2020. Source MFF Performance Results Report 12/06/2023, page 921.  

162 The 15 projects closed very recently (including one that closed at the end of May 2024) and are still in reporting stage. 
Data shown in the KPIs table below are based on the 3rd synthesis report finalized in January 2024 that covered the 
period up to July 2023. The next consolidated synthesis report with final data is expected not earlier than Q4 2024 – 
Q1 2025. However, from preliminary and partial data coming through individual reports, indicators seem generally in 
line with expectations. 

163 The number of ClusterXchanges is significantly below target for the moment and also the number of  cooperation 

projects/cooperation agreements/business agreements and/or interregional partnerships resulting from the supported 
activities. 

45 

 
 
 
 
ClusterXchange IT tool164 which was only available and fully functioning in Q1 2023. This 
caused a postponement of several exchanges.  

The Clusters Go International 2020 projects are still ongoing. Based on the partial reporting 
data currently available, the actions are on track towards meeting all targets except three165. 
However,  these  specific  targets  are  normally  achieved  towards  the  end  of  the  project 
lifetime after the various international business missions have been concluded (at the end 
of a long preparatory phase and market analysis). 

The first call for proposals for Joint Clusters Actions under the Single Market Programme 
SME Pillar took account of the emerging findings from the clusters evaluation study and 
issues/trends emerging from reporting data at the time. The ongoing interim evaluation of 
the SMP will also focus close attention on lessons learnt from these projects.     

Table 14: KPIs and targets - Clusters Excellence 

KPI  

Results 

Target  

Work programme 2015 projects 
Number of project related surveys into cluster members 
Number of added value tools related to cluster management and skills 
enhancement 
Number of SME member's need analyses, surveys and/ or alternative feedback 
from cluster SMEs and other cluster members 
Number of cluster, value chains and market analyses 
Number of coaching or mentoring actions 
Number of educational visits and key networking activities such as visits 
(including those to regional authorities, incubators, accelerators, risk-capital 
providers of a cluster partnership). 
Number of cluster organisations engaged in benchmarking, accreditation, 
labelling 
Number of staff benefiting from training activities 
Number of participants in the events organised 
Number of cluster organisations, business networks having been involved in the 
activities 
Number of SMEs having benefitted from the supported actions through the 
provision of more professional services 
Number of bilateral/ multilateral partnership agreements signed 
WP 2018 projects 
Number of educational visits and key networking activities (e.g. visits, 
including to regional authorities, incubators, accelerators, risk-capital providers 
of a cluster partnership). 
Number of cluster organisations engaged in benchmarking, accreditation, 
labelling 
Number of staff benefiting from training activities 
Number of strategic analyses produced including, cluster innovation and growth 
potential, value chain analysis, European and global, smart specialisation 
analysis 

56 
25 

98 

41 
10 
21 

10 

51 
988 
43 

1285 

24 
18 

81 

17 
11 
14 

10 

42 
704 
33 

970 

16 
Results  
237 

19 
Target  
165 

105 

286 
73 

94 

190 
64 

164 The ClusterXchange IT tool is the ECCP tool and dashboard used for registering the exchanges, signing the 

agreements and uploading the reports.  

165 Number of cooperation projects/cooperation agreements/business agreements and/or interregional partnerships 
resulting from the supported activities, the number of cluster organisations and business networks from different 
COSME participating countries having benefited from the supported actions, and the number of resulting 
cooperation projects between clusters as well as business partners (result).    

46 

 
  
  
 
Number of cross-sector analyses including industrial transformation trends, 
relating to digitisation, servitisation, creativity and resource-efficiency, circular 
economy, SMEs and other cluster members surveys 
Number of cluster strategies, implementation roadmaps developed or updated 
Number of new or updated mission and vision statements for the cluster 
Number of exchanges through the ClusterXchange pilot scheme 
Number of workshops and meetings with cluster members including those with 
regional authorities, European Structural and Investment Funds managing 
authorities and implementing bodies where relevant 
Number of joint projects/ cooperation agreements where relevant 
WP 2020  projects 

Final reporting is in progress for these projects that finished at the end of 
January 2024. This data is based on the 3rd synthesis report (early 2024). 

Number of cluster organisations engaged in benchmarking, accreditation, 
labelling 
Number of strategic analyses produced 
Number of new support services developed by cluster organisations for their 
SME members 
Number of posts published on the ECCP site relating to specific awareness-
raising actions undertaken by the partnership 
Number of staff benefitting from training activities 
Number of trainings attended by cluster managers to enhance their skills 
Number of exchanges through the ClusterXchange pilot scheme 
Number of promotional events organised by the partnership 
Number of cooperation projects/cooperation agreements/business agreements 
and/or interregional partnerships resulting from the supported activities 

61 

34 

82 
67 
495 
247 

82 
66 
710 
153 

83 
Results 

61 
Target 

53 

168 
68 

99 

366 
125 
493 
131 
80 

77 

174 
117 

311 

275 
182 
1386 
172 
448 

Table 15: KPIs and targets - Clusters Go International 

KPIs 
Indicators 2017 
Number of promotional events organised by the partnership 
Number of bilateral/ multilateral partnership agreements signed 
Number of cluster organisations and business networks from different 
COSME participating countries having benefited from the supported actions 
Number of cluster and business matchmaking meetings supported 
Number of SMEs having directly or indirectly benefited from the supported 
actions, resulting in cooperation projects 
Impact of the supported actions in terms of number of resulting cooperation 
projects between international cluster and business network partners 
Indicators 2019 
Number of cooperation projects/cooperation agreements/business agreements 
and/or interregional partnerships resulting from the supported activities 
Number of promotional events organised by the partnership 
Number of cluster organisations and business networks from different 
COSME participating countries having benefited from the supported actions 
Number of cluster and business matchmaking meetings supported 
Number of SMEs having directly or indirectly benefited from the supported 
actions, resulting in cooperation projects 
Increase in the percentage of the turnover from international activities, and 
employment in Europe, of the SMEs having benefited directly and indirectly 
from the supported actions, as measured through a survey by the end of the 
action 
Impact of the supported actions in terms of number of resulting cooperation 
projects between international cluster and business network partners 

Results 

Target 

20 
2 
20 

6 
100 

5 

17 
2 
11 

3 
59 

8 

Results 
314 

Target 
293 

629 
638 

5391 
21729 

388 
317 

2667 
7764 

4,5% 

9,5% 

87 

79 

47 

 
 
 
  
  
Indicators 2020 
This is based on reporting data from the 3rd Synthesis report (early 2024). 
The projects are still ongoing until 15  September 2024 
Number of cooperation projects/cooperation agreements/business agreements 
and/or interregional partnerships resulting from the supported activities 
Number of promotional events organised by the partnership 
Number of cluster organisations and business networks from different 
COSME participating countries having benefited from the supported actions 
Number of cluster and business matchmaking meetings supported 
Number of SMEs having directly or indirectly benefited from the supported 
actions, resulting in cooperation projects 
Increase in the percentage of the turnover from international activities, and 
employment in Europe, of the SMEs having benefited directly and indirectly 
from the supported actions, as measured through a survey by the end of the 
action  
Impact of the supported actions in terms of number of resulting cooperation 
projects between international cluster and business network partners 
Impact of the supported actions to be measured in the number of resulting 
cooperation projects between clusters as well as business partners 

Results 

Target 

102 

477 
169 

355 
3186 

262 

301 
250 

177 
3796 

3,5% 

5% 

30 

37 

9 

103 

48 

 
 
4.1.4  Specific objective 4 SO4 - Entrepreneurship 

SO4  supported  various  actions  for  entrepreneurship,  notably  Erasmus  for  Young 
Entrepreneurs  described  in  further  detail  below  and  a  number  of  tools,  networks  and 
initiatives to support entrepreneurial opportunities and culture for women. For example, 
WEgate166 was established to help women create and run successful businesses. This action 
is presented through a case study in Annex VIII.  

Another entrepreneurship-related activity which particularly benefitted women was “Scale 
Up Innovation for a Circular Fashion Industry”, where three in four funded partnerships 
were female-led. The social economy measures also witnessed a large contribution from 
female entrepreneurs.167 

In the earlier years of the programme there were also actions for other specific target groups 
such as migrant entrepreneurs. 

Erasmus for Young Entrepreneurs (EYE) 

EYE is a cross-border exchange programme to support entrepreneurship. It gives new or 
aspiring entrepreneurs an opportunity to benefit from first-hand, practical coaching from 
an  experienced  entrepreneur  who  runs  a  small  and  medium-sized  business  in  another 
participating country. The new entrepreneur receives financial support for spending time 
on site in the experienced (host) entrepreneur’s business. This enables both entrepreneurs 
to learn from one another and enrich their experience.  

EYE is implemented via intermediary organisations. These organisations take care of 
promoting the programme on local level and recruiting entrepreneurs to participate. They  
match  the  new  and  experienced  entrepreneurs,  and  provide  them  with  assistance  for 
benefiting  from  this  scheme.  The  intermediary  organisations  receive  a  grant  from  the 
COSME programme for implementing these support activities.  

The  COSME  programme  also  provides  support  for  the  EYE  IT  tool  that  supports  the 
matching  process  and  the  management  of  the  action,  and  the  EYE  support  office  that 
coordinates  and  supports  activities  of  intermediary  organisations  (IOs)  and  supports 
EISMEA  and  the  European  Commission  (EC)  in  the  daily  management  of  the  EYE 
programme.  

Overall, the evidence from the desk research and consultations for the supporting study 
indicates  that  the  EYE168  was  effective  in  boosting  the  entrepreneurship  skills  of  the 
participating entrepreneurs.  

Overall, 15 600 new and host entrepreneurs were supported by EYE during the COSME 
programme. The performance of this action can be measured against several KPIs.  The 
table  below  presents  the  main  targets  for  EYE  defined  in  the  COSME  annual  work 

166 WEGate.eu. 2023. https://www.wegate.eu/. 
167 European Commission. 2022. COSME, 2014-2020 Programme for the Competitiveness of Enterprises and SMEs, 

2019 monitoring report, COM(2022) 527 final. 

168  More  recently,  there  was  a  pilot  project  and  preparatory  action  (funded  outside  the  framework  of  the  COSME 
programme) to temporarily expand the EYE programme to third countries beyond the EU that are not associated with 
the COSME programme. Through EYE Global, new entrepreneurs from EU countries and the UK were able to go on 
exchanges  with  host  entrepreneurs  from  Canada,  Israel,  Singapore,  South  Korea,  Taiwan  and  the  USA.  Source: 
COSME Monitoring report 2020. 

49 

 
 
 
 
programmes,  whilst  the  following  table  summarises  the  achievements  against  the  key 
performance indicators across all years. 

Table 16: EYE targets set out in work programmes 2014-2019 

Indicator 

Entrepreneurs 
newly-registered 
Entrepreneurs 
participating 
Matches 

Intermediary 
Organisations 
Countries 
covered 
Rate of 
successful 
exchanges 

2014 
WP: by 
Jan 2017 
2 000 

2015 
WP: by 
Jan 2018 
2 000 

2016 
WP: By 
Jan 2019 
5 500 

2017 
WP: by 
Jan 2020 
5 000 

2018 
WP: by 
Jan 2021 
2 500 

2019 
WP: By 
Jan 2022 
3 000 

Total 

17 000 

1 300 

1 300 

4 800 

2 600 

2 000 

3 600 

15 600 

650 

100 

25 

650 

100 

25 

2 400 

120 

1 300 

100 

1 000 

120 

1 800 

120 

7 800 

660 

28 

28 

28 

33 

33 

>90% 

>90% 

>90% 

>90% 

>90% 

>90% 

>90% 

Source: Annual COSME Work Programmes 2014-2019 

Table 17: Achievement against targets (EYE) 

2014 
Cycle 7 
by Jan 
2017 

871 

1 742 

2015 
Cycle 8 
by Jan 
2018 

1 022 

2 044 

Work Programme 
2016 
Cycle 9 
By Jan 
2019 

2017 
Cycle 10 
by Jan 
2020 

2018-19 
Cycle 11 
(SGA-2) 
by Jan 2022 

2019 
Cycle 12 
by Jan 
2023 

Total 

1 421 

2 843 

792 

1 583 

2 525 

5 051 

917 

1 833 

7 548 

15 096 

111 

131 

110 

- 

28 

29 

95 

29 

99 

- 

77 

623 

- 

>30 

98% 

93% 

83% 

>90% 

95% 

95% 

92% 

Indicator 

Matches169 

Participating 
entrepreneur
s  
Intermediary 
organisation
s170 
Countries 
covered 
Rate of 
successful 
exchanges 

Source: EISMEA 

Based on the analysis carried out for the supporting study, including a detailed review of 
monitoring data, the EYE realised between 792 to 2 525 matches a year and it is possible 
to  conclude  that  EYE  met  the  set  targets  and  achieved  important  results.  The  dynamic 
progress towards achievement of these quantitative targets is well illustrated by the steady 
increase in the number of registrations, matches, and exchanges completed from the time 
of EYE’s inception as a pilot under the EIP171 until 2019.  

170  The  total  for  all  years  is  the  number  of  annual  participations  by  intermediary  organisations  not  the  total  of 

organisations, as some organisations may have participated in multiple years. 

171 Between 2009 and 2012 (under the previous EIP programme) the number of registrations increased fivefold, up to 5 
000.171 By 2015, already 12 000 entrepreneurs’ profiles were registered and there had been 3900 matches involving 7 
700 entrepreneurs. 

50 

 
 
 
 
In the targeted survey of EYE entrepreneurs carried out for this evaluation, respondents 
confirmed that EYE achieved a range of positive results for the stakeholders involved, and 
for  the  European  business  environment  more  broadly.  Nearly  100%  (654/655)  of  new 
entrepreneur (NE) respondents reported that participation in the EYE had improved their 
knowledge  and  skills  at  least  to  some  extent,  and  the  corresponding  figure  for  host 
entrepreneurs  (HEs)  was  73%  (165/227).  Only  7%  of  the  survey  participants  have  not 
witnessed such a result at all. Based on feedback from HE gathered by the Commission, 
the  HE  considered  the  NE  entrepreneurial  attitude,  commitment  and  flexibility  as  key 
factors in the success of the scheme, followed by NE skills, language and knowledge of 
the sector. 

There  is  no  firm  evidence  of  the  impact  of  EYE  on  the  number  of  enterprises  actually 
created as a result of these exchanges. Surveys of the participating entrepreneurs after the 
exchanges  carried  out  by  DG  GROW  included  a  question  on  the  percentage  of  new 
entrepreneurs  that  intended  to  set  up  a  business.  It  should  also  be  noted  that  the 
intermediary organisations are required to pay specific attention to evidence of the new 
to  set  up  a  business,  when  selecting  candidate  new 
entrepreneur’s 
entrepreneurs.172  For this potential impact to be properly assessed there would be a need 
for an additional survey longer after the time of the exchange. 

intention 

The  EYE  Support  Office  (that  coordinates  and  supports  activities  of  the  Intermediary 
Organisations  (IOs)  and  supports  EISMEA  and  the  European  Commission  (EC)  in  the 
daily  management  of  the  EYE  programme),  was  effective  in  promoting  EYE  and 
coordinating the IOs network,173 as well as the provision of support and the day-to-day 
management of activities connected to the IOs.174  

Based  on  the  analysis  carried  out  by  the  evaluation  team,  EYE  is  expected  to  produce 
positive  long-term  impacts.  Interview  feedback  suggests  that  the  role  of  intermediary 
organisations was crucial in supporting the entrepreneurs returning from EYE exchanges 
to their home countries. In this context, the after-care programmes, the availability of legal 
support for EYE beneficiaries, and access to local support were identified as good practice 
that was effective in fostering longer-term impacts stemming from EYE exchanges. With 
respect to good practice within the EYE, interview feedback also suggested already having 
a business set up before participating in an EYE exchange might be a factor contributing 
to the production of long-term benefits.  

Next to the actions which performed very well, the supporting study also identified some 
actions which faced challenges during implementation and where performance issues were 
identified  (Box  4  presents  one  example).  This  has  also  been  investigated  through  case 
studies (Annex VIII).  

Box 4: Example of an action which faced implementation/performance issues 

The EWE Mentor Academy (GRO/SME/20/C/013) aimed to  create training content 
for mentors supporting SMEs facing various challenges. It aimed to develop a modular 
training programme, identify best practice in business mentoring, and build networks of 
mentors  and  support  organisations  across  Europe.  Challenges  emerged  during  the 

172 This is also confirmed in the quality manuals for intermediary organisations. See for example the quality manual for 
the  2019  call:  https://eismea.ec.europa.eu/funding-opportunities/calls-proposals/cos-eye-2019-4-01-erasmus-young-
entrepreneurs_en . 

173 The Intermediary Organisations provide guidance and support to new and experienced entrepreneurs throughout the 

application process and EYE exchange. 

174 COSME Monitoring Fiche - GRO/SME/20/D/021 Support to Erasmus for Young Entrepreneurs - Support office. 

51 

 
 
project, due to issues in the consortium. These affected activities such as communication 
and  training  curriculum  creation,  leading  to  delays  and  the  withdrawal  of  a  partner. 
Despite the delays, mitigation steps were taken, such as reinforcing the team and revising 
the implementation plan with external expert assistance. This helped steer this project 
back on track towards successful completion.   

Effectiveness of the programme for addressing key policy priorities 

At  a  policy  level,  the  programme  aligned  with  key  policy  priorities  such  as  the  Small 
Business Act175, the Single Market Strategy176, and the Start-up and Scale-up Initiative.177 
The  programme  played  a  crucial  role  in  achieving  the  Commission's  growth  and 
employment  priorities  by  improving  access  to  finance,  facilitating  networking  and 
cooperation between businesses, sharing of information and best practice, and expanding 
market opportunities for EU SMEs178. 

COSME was highly valued by respondents to the consultations for the supporting study 
due  to  its  focus  on  fostering  economic  growth  and  job  opportunities  and  facilitating 
sustainable growth. However, its contribution in areas beyond the economic sphere and 
addressing societal challenges and inclusive and sustainable growth is difficult to assess at 
a programme level given the evidence gathered. Some considerations can be made at an 
action/sub-programme level such as for social economy or tourism actions. 

Several actions considered climate-related challenges. Overall, the COSME contribution 
to the climate mainstreaming objective, set for all Commission programmes (overall 20% 
of the EU budget 2014-2020), is estimated at EUR 25.6 million (6% of the 2020 financial 
allocation). Over 200 expert EEN business  advisers specialise in  climate-related issues, 
and several studies provided evidence for policy measures on climate issues, in particular 
the European Climate Neutral Industry Competitiveness Scoreboard (CIndECS) informed 
policy  work  related  to  the  Clean  Energy  Technology  Observatory  and  the  Net  Zero 
Industry  Act.  However,  there  is  no  monitoring  or  assessment  of  the  precise  financial 
contribution of most COSME measures to climate mainstreaming, as emphasised in the 
COSME 2020 Monitoring Report,  

The COSME also considered environmental challenges and goals, such as fostering a more 
circular  economy  or  promoting  clean  technologies.    Monitoring  fiches  and  annual 
monitoring reports provided qualitative data and concrete examples of how specific actions 
had contributed to such objectives.  For example, the EFG facilitated investment of more 
than EUR 62 million in SMEs in the energy and environment sector. Under the Clusters 
Go International all sectors 2020 call, 6 of the 12 projects had a specific focus on helping 
SMEs to improve their resource-efficiency and implement the green transition. 

Tourism actions, actions supporting female entrepreneurship and social economy missions 
had mostly successful outcomes and demonstrated the role that SMEs can play in territorial 

175 European Commission. 2008. European Commission communication (COM (2008) 394 Final) – ‘think small first” 

– A ‘small business act’ for Europe. 

176 Available at: European Commission. 2023. The single market strategy. 
177 Available at: European Economic and Social Committee. 2016. Europe's next leaders: the Start-up and Scale-up 

Initiative. 

178 Inter alia, evidence is provided in the effectiveness analysis for the financial instruments and EEN. 

52 

 
 
 
and social cohesion. One focus area of the social economy missions was local or regional 
measures  tackling  unemployment.  In  the  tourism  sector,  some  smaller  workshops  and 
reports led to positive results, developing topics such as sustainability, digitalisation, and 
resilience  and  contributing  evidence  and  experiences  for  the  Transition  Pathway  for 
Tourism179 policy published by the Commission in February 2022.180 A number of events 
in  2020  led  to  proposals  for  concrete  action  points  on  the  long-term  transition  towards 
green, digital and resilient tourism.181 

Other  actions  in  the  field  of  Social  Economy  supported  inter-regional  learning  and 
collaboration  for  more  sustainable  growth.  The  European  Social  Economy  Missions  of 
2020182 involved a wide range of umbrella organisations focused on the social economy. 

Furthermore, the annual  SME Performance Reviews and smaller actions addressing the 
theme of Framework Conditions  provided solid evidence to  support policy making and 
published materials that generated additional visibility for the programme. For instance, 
the SME Performance Review reports have been useful in deepening the understanding of 
market  trends  through  key  performance  indicators  and  in  supporting  national  policy 
developments. Other initiatives were helpful in supporting evidence-based policy making 
and national reform efforts.183 

Some  smaller  actions  supported  SMEs  in  key  sectors  such  as  tourism  –  and  others 
contributed  to  improving  the  framework  conditions  for  the  competitiveness  and 
sustainability of enterprises in the EU. As indicated in the targeted consultations, a factor 
which contributed to their success was their focus on tackling specific issues or SMEs’ 
specific needs. Their strong coherence with other initiatives in the programme was also 
mentioned, and their contribution to the achievement of longer-term impacts. 

4.2  Efficiency 

The  assessment  of  the  efficiency  of  the  COSME  programme  covers  budget  and 
implementation structures and governance, proportionality of costs and benefits, and the 
administrative costs for applicants and beneficiaries. It is based on data sources such as 
programme documentation and programme data on key metrics, notably “Time to inform” 
(TTI) and “Time to grant” (TTG) in relation to open calls184. It also uses the findings of 
the interim evaluation of COSME covering implementation in 2014-2016, and evidence 
gathered  in  the  interviews  and  targeted  surveys  carried  out  for  this  evaluation  and  the 
results  of  earlier  surveys  (for  EYE),  and  the  findings  of  previous  evaluations  including 
evaluation studies on clusters actions and the international SME IP Helpdesks.  

Efficiency of programme management 

There  has  been  a  high  execution  rate  of  the  programme  budget  in  each  year  of  the 
programme’s  implementation,  even  though  there  was  a  steady  increase  in  the  annual 

179 https://ec.europa.eu/commission/presscorner/detail/en/ip_22_850 
180 Monitoring fiche. GRO/SME/20/C/081.  
181 These were presented at the European Tourism Convention (October 2020), see Monitoring fiche 

GRO/SME/20/C/083.  

182 These aimed to contribute to better, high-quality employment, the green, social and digital transition at a local level, 
and the adoption of resilient and sustainable business models. Monitoring fiche. GRO/SME/20/D/01 - European 
Social Economy Missions. 

183 For instance, the Initiative for a Built environment, produced a monitoring tool to support the design and monitoring 

of construction-related measures in the context of the NRRPs Monitoring fiche. GRO/SME/20/F/103. 

184 TTI refers to the time from the call deadline to the invitation to sign the contract, whilst TTG refers to the time elapsing 
between the closure of a call and the signature of the Grant Agreement, which typically marks the start of the project 

53 

 
 
budget year-on-year. The execution rate ranged from 94% in 2016 to 99% in (2014, 2015 
and 2020) and the average rate over the life of the programme was 98%.185  

Table 18: Budget commitments within COSME 2014-2020 

Year 

2014 
2015 
2016 
2017 
2018 
2019 
2020 

Budget available 
(EUR m) 
259.0 
329.3 
357.6 
405.8 
434.5 
448.1 
440.5 

Budget implemented 
(EUR m) 
257.0 
326.1 
337.6 
396.8 
422.1 
440.5 
436.4 

Percentage 
implemented 
99% 
99% 
94% 
98% 
97% 
96% 
99% 

Source: annual monitoring reports produced by the European Commission 

This high execution rate is broadly in line with other EU programmes. For example, the 
execution  rate  for  the  Creative  Europe  programme  was  close  to  100%186  and  Horizon 
Europe implemented 99.99% of commitments.187 

COSME was highly valued by stakeholders for the focus on fostering economic growth 
and job opportunities and facilitating sustainable growth. Its contribution in areas beyond 
the  economic  sphere  and  addressing  societal  challenges  and  inclusive  and  sustainable 
growth is difficult to assess at a programme level given the evidence gathered. However, 
some considerations can be made at a sub-programme level such as for social economy or 
tourism actions. 

Several actions considered climate-related challenges. Overall, the COSME contribution 
to the climate mainstreaming objective, set for all Commission programmes (overall 20% 
of the EU budget 2014-2020), is estimated at EUR 25.6 million (6% of the 2020 financial 
allocation). Over 200 expert EEN business  advisers specialise in  climate-related issues, 
and several studies provided evidence for policy measures on climate issues, in particular 
the European Climate Neutral Industry Competitiveness Scoreboard (CIndECS) informed 
policy  work  related  to  the  Clean  Energy  Technology  Observatory  and  the  Net  Zero 
Industry  Act.  However,  there  is  no  monitoring  or  assessment  of  the  precise  financial 
contribution of most COSME measures to climate mainstreaming, as emphasised in the 
COSME 2020 Monitoring Report. 

The COSME also considered environmental challenges and goals such as fostering a more 
circular  economy  or  promoting  clean  technologies.  Monitoring  fiches  and  annual 
monitoring reports provided qualitative data and concrete examples of how specific actions 
contributed to such objectives. For example, the EFG facilitated investment of more than 
EUR 62 million in SMEs in the clean energy and environment sector. Under the Clusters 
Go International 2020 call, 6 out of 12 projects has a specific focus on helping SMEs to 
improve their resource-efficiency and implement the green transition.  

185 Source: annual monitoring reports produced by the European Commission 
186 European Commission, Directorate-General for Communications Networks, Content and Technology, Directorate-
General for Education, Youth, Sport and Culture, European Education and Culture Executive Agency, Creative 
Europe – Monitoring report 2020, Publications Office, 2021, DOI: 10.2759/602038. 

187 European Commission. 2023. Horizon Europe Performance. 

54 

 
 
The share of the programme budget devoted to administrative expenditure is relatively low 
in the last 5 years of the COSME programme (3%)188. In the first 2 years (2014-2015), the 
administrative expenditure was slightly higher (4.6% of total programme budget). 

Overall,  the  percentage  of  the  COSME  programme  budget  devoted  to  administrative 
expenditure is comparable with other EU programmes or agencies: 

•  The administrative expenditure for other programmes ranged from 3.6% for LIFE189 to 
7% for Urban innovative actions, and Horizon 2020 was between these figures at 5%. 
190 

•  The  administrative  costs  for  agencies  generally  ranged  from  2.6  to  2.7%  (INEA: 

0.77%, REA: 2.6%, EISMEA H2020 actions: 2.7% and ERCEA: 2.75%)191 

The supporting study points out that the higher percentage of administrative costs in the 
first two years of the COSME can be largely explained by the need to establish programme 
management arrangements. It also suggests that the delegation of programme management 
tasks to EISMEA is a key factor explaining the decrease in the administrative costs over 
time for COSME, referring to the cost benefit analysis conducted by the Commission in 
2013192 on the delegation of programme management to executive agencies.  

Regular  monitoring  has  allowed  the  programme  implementation  bodies  to  reallocate 
funds193.  In  2018,  funds  were  reallocated  from  the  EFG  to  other  actions,  because 
agreements  for  equity  took  longer  to  sign,  due  to  the  complexity  of  due  diligence  and 
fundraising processes. In 2019, budget was reallocated notably to the LGF, reflecting high 
market  demand  for  guarantees  and  counter-guarantees.  In  2020,  EUR  815  000  was 
reallocated to the tourism call due to the high level of oversubscription of good quality 
proposals for this action194. 

The  programme  implementation  bodies  also  took  steps  to  respond  to  challenges  which 
affected several actions funded by 2019 and 2020 budget. They also carried out a specific 
monitoring  of  the  affected  projects,  with  re-allocation  of  funds  and  extensions  to  the 
duration of projects where appropriate195: 

In  the  response  to  the  targeted  survey  for  this  evaluation  that  included  “Improving 
Framework Conditions” actions196 respondents reported high levels of satisfaction with the 
support and assistance offered.  

188 Source: Annual monitoring reports for COSME 
189 LIFE is an EU programme for environment and climate. See: https://cinea.ec.europa.eu/programmes/life_en . 
190  Horizon  2020  administrative  expenditure:  Horizon  2020  interim  evaluation  swd_2017_222_en.pdf 

(europa.eu) 

191 2017 Interim Evaluation of Horizon 2020. INEA was the Innovation & Networks Executive Agency in the financial 

period 2014-20. It ran the Connecting Europe Facility, and parts of the Horizon 2020 programme and other 
programmes. REA is the European Research Executive Agency, and ERCEA is the European Research Council 
Executive Agency. 

192 Cost-benefit analysis conducted by the Commission in 2013 provided evidence that the delegation of programme 
management to external bodies or Executive Agencies is a more efficient and cost-effective approach (SEC(2013) 
493 final). 

193 Source: COSME monitoring data and monitoring reports. 
194 COSME Monitoring Report 2020, p. 14. 
195 COSME Monitoring Reports 2019 and 2020.  
196  Survey  of  providers  and  beneficiaries  of  COSME  actions  including  those  involved  in  framework 

conditions actions. 

55 

 
 
 
•  71/75 of providers and beneficiaries responding to the targeted survey confirmed that 
they were either very satisfied (37) or satisfied (34) with the support provided by the 
European Commission and EISMEA.  

•  57/61 beneficiaries reported being very satisfied or satisfied with the support offered 

by the relevant intermediary organisations. 

4.2.1  Costs of the different actions and cost-effectiveness metrics 

Table 19: Total EU contribution to COSME per COSME specific objective 

Specific objective 
SO1 (LGF, EFG) 
SO2 (EEN, IPR Helpdesks, Your Europe, etc.) 
SO3 (Clusters Go International ECCP, Tourism, 
SME policy, etc.) 
SO4 (EYE, etc.) 
TOTAL 

Budget committed (million EUR) 
1587 
482 
256 

78 
2403 

Source: European Commission (ABAC for SO1 and COSME Monitoring Data 2014-2020 for SO2-4)197 

It should be noted that within SO2, EEN accounted for most funding (93%), and within 
SO4, EYE accounted for most funding (89%). 

Regarding the cost-effectiveness metrics, their comparison with relevant indicators from 
other  programmes  proves  challenging  as  different  financial  instruments  have  different 
design, policy purpose, implementation mechanism and financing conditions. A dedicated 
horizontal  study  comparing  financial  instruments  would  have  to  take  into  account  all 
specificities  of  the  financial  instruments  by  weighting  the  final  results  from  a  cost 
effectiveness perspective.  

Table 20: Efficiency indicators for individual actions (2014-2020) 

This table presents some efficiency metrics for COSME key actions that can be compared 
with 2014-2016 figures from the interim evaluation (in brackets when available):  

€m = 1 million EUR  

Action 

CEA 
Indicator 
description 

[A] Benefits 
(n° of  units) 
based on 
results 
achieved and 
monitoring 
data 

[B] Direct costs  
(€m) 
(EU contribution 
+ administrative  
costs incurred by 
EISMEA, the 
EIF or the 
European 
Commission  

[C]  Indirect costs to 
beneficiaries  (€m) * 
Co-funding from 
project partners, 
EFSI guarantee for 
LGF, costs incurred 
by  EYE 
entrepreneurs 

CEA 
Indicator 1** 
 (n° of units  
of benefit per 
€m  invested) 
[A/B] x 1 
million 

EYE 

no. of new 
and 
experienced 
entrepreneur
s supported, 
per €m 
invested 

15 096 
no. of EYE 
entrepreneurs 
supported (both 
new and 
experienced 
entrepreneurs) 

EUR 58.5 
million 
(direct costs at 
interim stage  
EUR 25.9 
million) 

EUR 10.1million 
(value at interim 
stage EUR 12.2 
million) 

258 
entrepreneurs 
supported, 
per EUR 
1million 
invested 

CEA 
Indicator 
2*** 
(n° of units  
of benefit 
per €m 
invested) 
[A/B+C] x 1 
million 

220 
entrepreneur
s supported, 
per EUR 1 m 
invested 
(n° at interim 
stage 98) 

197 The final implementation as per the Commission’s accounting system offers a higher figure than the work programmes 
in respect of SO1, i.e. EUR 1 587 million, as Article 4 of each working programme provided for flexibility, which 
was ultimately used by the Commission to commit more based on the high market demand and availability of budget. 

56 

 
 
 
 
 
 
 
 
 
Action 

CEA 
Indicator 
description 

[A] Benefits 
(n° of  units) 
based on 
results 
achieved and 
monitoring 
data 

[B] Direct costs  
(€m) 
(EU contribution 
+ administrative  
costs incurred by 
EISMEA, the 
EIF or the 
European 
Commission  

[C]  Indirect costs to 
beneficiaries  (€m) * 
Co-funding from 
project partners, 
EFSI guarantee for 
LGF, costs incurred 
by  EYE 
entrepreneurs 

CEA 
Indicator 1** 
 (n° of units  
of benefit per 
€m  invested) 
[A/B] x 1 
million 

CEA 
Indicator 
2*** 
(n° of units  
of benefit 
per €m 
invested) 
[A/B+C] x 1 
million 

(no. at interim 
stage 3 737) 

(at interim 
stage198 144) 

EEN 

EEN 

LGF 

EFG 

EUR 367.28 
million 
(direct costs at 
interim stage 
EUR 154.1 
million) 
EUR 
367.28million ( 

 EUR 1.203 
billion  
(direct costs at 
interim stage EUR 
367.5 million) 

EUR 
378.1million   

n° of SMEs 
supported, 
per EUR m 
invested 

1 957 822 
no. of SMEs 
supported (no. 
at interim stage 
210 000) 

18 701 
no. of 
partnership 
agreements 
signed 
 865 387 
no. of SMEs 
supported, 
monitoring data 
(no. at interim 
stage 300 000) 

521 
 no. of SMEs 
supported, 
monitoring data 

no. of cross-
border 
partnerships 
signed, per 
€m invested 
no.  of 
SMEs 
supported 
though LGF 
financing, 
per €m 
invested 

no. of 
SMEs 
supported 
by EFG 
funds, per 
€m invested 

EUR 294.07 million 

5 337 (value 
at interim 
stage 1 363) 

2 960 

EUR 294.07 million 

 56.4 

 31.3 

EUR 1.34 billion 
(value  at interim 
stage EUR 262.4 
million) 

719.36 
(value at 
interim stage 
798.9)  

340.30 
(value at 
interim 
stage 470.3) 

0 

1.38 

1.38 

*C does not include costs incurred by other stakeholders that are not directly targeted 
** CEA1 reflects value generated by the programme per EUR 1 million invested (without the 
‘other’ costs) 
*** CEA2 reflects value generated by the programme per EUR 1 million invested (including the 
‘other’ costs) 

The approach followed by the table above is in line with that of the interim evaluation of 
COSME. The two cost-effectiveness indicators (CEA) above reflect the number of outputs 
and  outcomes  produced  per  million  Euro  invested  in  the  programme  (with  or  without 
‘other’ costs). The analysis is not exhaustive as it only considers the costs sustained by the 
Commission  and  other  participants  and  not  the  costs  to  society.  For  benefits  (A),  the 
analysis looks at direct  benefits of the programme, i.e. the number of SMEs supported, 
partnerships signed, etc. or outputs as proxy indicators of benefits.  

The budget committed per beneficiary has decreased for EEN and EYE which may indicate 
a higher efficiency and increased slightly for LGF comparing the budget per beneficiary at 
the interim stage and at the end of the programme.  

198 The Interim evaluation of COSME confirmed that the 98 SMEs per €1 million invested included both host and new 

entrepreneurs (see page 68). 

57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
For the LGF, the cost effectiveness indicators (798.9 as CEA I and 470.3 as CEA II) as 
expected  at  the  time  of  the  COSME  midterm  evaluation  are  higher  than  those  in  the 
COSME  final  evaluation (719.36  for  CEA  I  and  340.30  for  CEA  II).  This  is  due  to  a 
modification to the LGF in the period after the 2017 interim evaluation. More flexibility 
was given to users of the LGF and the LGF guarantee rate was increased from 50 to 80% 
accordingly. When a larger guarantee rate is provided, less SMEs will be supported under 
other  equal  budgetary  terms.  Hence,  the  cost  effectiveness  indicators  (which  are  ratios 
between SMEs supported via the LGF and EU guarantee) are lower in the final evaluation.  

4.2.2  Benefits of the different actions 

The COSME actions provided a diversity of (quantifiable and unquantifiable) benefits for 
participants and beneficiaries, as well as for the EU more generally.  

Table 21: Main quantifiable benefits of specific COSME actions 

Action 

Indicator (proxy of benefits) 

Type of indicator 

EYE 

Number of host/new entrepreneurs  

Number of intermediary organisations 

Number of EYE exchanges 

EEN 

Number of SMEs receiving EEN services 

Number of SMEs using digital services 

Output 

Output 

Outcome 

Outcome 

Outcome 

Value of the 
indicator 

15 096 

360 

7 548 

1 957 822 

21.5 m  
(2020-21) 

Number of cross-border partnership 
agreements signed 

Outcome 

18 701 

Clusters 

Number of cluster initiatives and events 

Number of cluster organisations involved 

Number of SMEs benefitting from actions 

Number of sectors covered by cluster 
initiatives 

LGF 

Total EU commitments to debt finance 

Number of intermediaries supported 

Total value of lending provided on the basis of 
LGF as supported by the EFSI 

Outcome 

Output 

Outcome 

Outcome 

Output 

Output 

Output 

132 

392 

>4,055 SMEs 

61 

EUR 1.2 billion 

128 

EUR 54 billion 

Number of SMEs receiving guaranteed loans 

Outcome 

865 387 

Number of jobs maintained or created in the 
SMEs or sector 

Impact 

233 146199 

EFG 

Total EU Contribution Committed by DG 
GROW 

Output 

EUR 378.1million 

Number of financial intermediaries supported 

Output 

23 

Total funding catalysed by instrument 

Outcome 

EUR 3.9 billion 

199 This figure is based on the COSME LGF – Growth & Employment report 31-12-2019. 

58 

 
 
Action 

Indicator (proxy of benefits) 

Type of indicator 

Value of the 
indicator 

Number of jobs maintained or created in the 
SMEs or sector 

Impact 

1 604200 

Source: COSME monitoring data 

Table 22 - Main benefits for beneficiaries 

An additional summary of information on the main benefits for beneficiaries based on data 
from  the  targeted  surveys,  studies,  the  interim  evaluation,  counterfactual  analysis,  and 
Orbis data (for LGF) is given below: 

Action 

LGF 

Indicator 
(proxy of 
benefits) 

Impacts on  
business:  

Impact on the 
number of 
employees, 
survival rates, 
turnover, cost 
of personnel 
and total assets 
of 
beneficiaries 
as compared to 
not-yet-treated 
companies  

Trends in 
survival 
rates/economic 
performance 

Type of 
indicator and 
data source 

Impact  
 based on 
targeted survey 
data 

Impact  
based on 
counterfactual 
analysis 

Impact 
based on Orbis 
data and studies 
on other similar 
financial 
instruments 

Value of the indicator and explanation 

Out of 92 LGF final beneficiaries surveyed, between 
47 and 72 agreed that EU-guaranteed financing had 
different positive impacts on their business (see 
Annex V). 

The counterfactual analysis demonstrated that LGF 
had a positive and significant impact on the number 
of employees and the survival rates over time, but a 
non-significant effect on the turnover, cost of 
personnel and total assets of beneficiaries as 
compared to not-yet-treated companies (see Annex 
VII below).  
As explained earlier, the counterfactual analysis is 
likely to (at least partially) under-represent the full 
extent of the economic impacts of the programme. 

Over time, EFG final recipients have not only 
exhibited high survival rates, but they have also 
experienced significant positive trends in their 
economic performance, e.g. increase in turnover 
and assets. Regardless of their size at the time of 
investment, data from Orbis confirms that that these 
SMEs have grown in terms of employment, turnover, 
and total assets. On average SMEs, have almost 
doubled the number of employees from the year 
before to the year after the intervention.  
These positive growth trends combined with the 
results of other studies for similar equity actions 
supported by the EIF would suggest that the EFG is 
likely to produce similar positive impacts over the 
longer term. 

Responding to 
SME’s needs / 
addressing 
barriers faced 
by SMEs 

Impacts for 
EEN’s SME 
clients 

Outcome 
based on targeted 
survey 

A large majority of SME clients (74% or 25/34) also 
stated that the EEN support received was effective in 
responding to their needs or in addressing the barriers 
they had.201 

Impacts on EEN 
clients 

The overwhelming majority of SME respondents to 
the targeted survey reported that EEN services 
delivered positive impacts for their business (91% 

EFG 

EEN 

EEN 

200 This figure is based on the COSME EFG – Growth & Employment report 31-12-2019. 
201 N= 34 respondents to this question.   

59 

 
 
 
Type of 
indicator and 
data source 

Value of the indicator and explanation 

Action 

Indicator 
(proxy of 
benefits) 
(employment, 
new markets, 
new products 
or services, 
turnover) 

based on targeted 
survey 
and the interim 
evaluation 

29/32202). EEN services had the greatest impact on 
SME employment, either for safeguarding employees 
(63% of SME respondents 20/32) or for helping them 
to expand their workforce (47% 15/32).  Other key 
impacts of EEN services for SMEs’ business were 
expansion to new geographical markets (62% of 
respondents), developing new products or services 
(59%) and maintaining turnover (59%) or increasing 
turnover (56%).203 The findings on turnover are 
consistent with the assessment provided in the interim 
evaluation which also quantified the impact in 
monetary terms at that time. The interim evaluation 
found that over the 2014-2016 period, each EUR 1 
million invested in the EEN led to an increase of EUR 
45 million in turnover and an increase in employment 
of circa 377 people among all client SMEs.204 
In another survey of EEN member organisations 
conducted for this study, 49% (33/68) of EEN 
member respondents believe that the EEN services 
they provided have been effective in helping SMEs to 
access international markets to a great extent and 49% 
(33/68) to a reasonable extent.205  

Helping SMEs 
to access 
international 
markets (EEN 
members 
perception of 
benefit for 
SMEs) 

Benefits for 
EEN members 
of belonging 
to EEN 
Commercial 
benefits for 
EYE 
entrepreneurs 

Outcome 
Based on survey 
data. 

Impact 

based on survey 
data 

Increased 
knowledge 
and skills of 

Impact – based 
on survey data 

Outcome 
based on survey 
data 

The EEN members perceived that the main benefits of 
belonging to EEN were the increased professionalism 
of staff in their organisation (95%), followed by the 
development of their organisation (70% 42/60).  

The vast majority of EYE Host entrepreneurs (90% 
193/214) reported that hosting the new entrepreneur 
contributed (to a great extent or to some extent) to one 
or several commercial benefits: including 
development or growth of the business (45%), an 
increase in jobs or safeguarding of jobs (43%)206. 
Only 19% of host entrepreneurs reported not gaining 
any of those benefits at all.  

In the targeted survey of EYE entrepreneurs, 73% of 
HE respondents (165/227) confirmed that they had 
boosted their knowledge and skills as a result of 
participation in EYE. 

EEN 

EEN 

EYE 

EYE 

203 Expansion of workforce: to a great extent 34% (11/32), to some extent 13% 4/32. 

Expansion to new geographical markets (62% 20/32): to a great extent 34% 11/32, to some extent: 26% 8/32. 
Maintain turnover: (59% 19/32:to a great extent 34% 11/32, to some extent 25% 8/32,  
Increase turnover: 56% 18/32 to a great extent: 34% 11/22, to some great extent: 22% 7/32 

204 This is based on an increase of 2 employees per company in the period 2014-2016 (calculated from the SME client 
survey conducted for the interim evaluation), the total number of companies supported (210 000), and the additionality 
factor. Source: European Commission. 2017. Interim evaluation of the COSME programme. 

205 N= 68 respondents to this question.   
206 Other benefits included expansion of sales to new countries (17%), expansion of operations in new countries (23%), 

increase in export turnover (14%)  to new countries (36%),  increase in the number of employees (26%), 
safeguarding jobs (17%) and an increase in turnover (29%), increased export turnover (14%). 

60 

 
 
 
 
Value of the indicator and explanation 

Amongst the new entrepreneurs responding to the 
targeted survey, nearly 100% (654/655) of 
respondents reported that participation in EYE had 
improved their knowledge and skills, particularly 
personal skills but also technical and managerial 
skills. An overwhelming majority of NEs (99%, 
630/635) confirmed that EYE contributed to 
strengthening their business and internationalisation 
skills and capacities.207 
There are no data on actual enterprise creations as a 
result of EYE exchanges but 61% of New 
entrepreneurs responding to the targeted survey 
confirmed their intention to set up a business within 
the next 12 months as a result of the exchange. 
One of the main benefits of the International IP 
SME Helpdesks highlighted in the 2018 Support 
Study for the Evaluation of these helpdesks is raising 
awareness among SMEs about IP management and 
protection issues.  

Action 

EYE 

Type of 
indicator and 
data source 

Impact – based 
on survey data 

Indicator 
(proxy of 
benefits) 
EYE host 
entrepreneurs 

Increased 
knowledge 
and skills of 
EYE new 
entrepreneurs 

EYE 

Intention to set 
up a business 

Outcome 

Outcome 

Based on the 
2018 Support 
Study for the 
Evaluation of the 
international 
SME IP 
helpdesks. 

International 
IP SME 
Helpdesks 

Increased 
awareness of 
IP issues /  

International 
SME IP 
Helpdesks 

First line 
support for 
SMEs with IP 
issues / 
helping SMEs 
to find out 
how to protect 
their IP before 
and after 
market entry 

Output 

Based on the 
above-mentioned 
study 

The above mentioned study also highlighted that the 
helpline, websites and events offered by the 
international IP SME Helpdesks enable European 
SMEs to obtain information on IP matters and how to 
protect their IP before entering a foreign market, but 
also after market entry. The study notes that helpline 
stands out as a useful service that is also in 
considerable demand and it seems to cover all major 
IP topics in an understandable manner and is 
considered a fast first-line support, particularly useful 
for micro-enterprises. The 2018 study also highlighted 
a related benefit: the helpdesks’ local presence and 
respective know how about the specific countries they 
provide advice on. This is considered particularly 
important by users dealing with South East Asia and 
China.  

International 
SME IP 
Helpdesks 

Potential 
impact 

Potential impact 
– not measurable, 
but expert 
opinion points to 
this 

Experts interviewed for the above-mentioned 2018 
study highlighted the importance of these helpdesks 
for helping SMEs to avoid litigation (and hence save 
costs), but the study highlighted that this benefit is 
difficult to measure in practice as it entails measuring 
costs that did not materialise. 

207They confirmed that EYE contributed (to a great extent or some extent) to at least one of the following benefits: 

learning about another country/market (86%), new knowledge and skills in running a business (83%), development 
of business plan/activities, (77%), encouragement to be professionally active in another EU country (73%), 
identifying potential business contacts and opportunities (70%). 

61 

 
 
 
Action 

Indicator 
(proxy of 
benefits) 

Type of 
indicator and 
data source 
Based on the 
above-mentioned 
study. 

Value of the indicator and explanation 

4.2.3  Proportionality of costs and benefits 

This section illustrates key findings on the cost-effectiveness of the main actions of the 
programme looking at the costs for the actions (considering figures in 2014-2016) and the 
benefits achieved. The targeted consultations with COSME participants for the supporting 
study have gathered some more comprehensive data on the extent to which the costs for 
intermediaries and final beneficiaries are proportionate to the benefits gained. This allows 
some comparison of the findings with those of the interim evaluation. This analysis covers 
those actions that received most funding (aside from the financial instruments), namely 
EEN and EYE. In addition, the end of this section contains analysis on the proportionality 
of benefits relative to costs for the international IP SME Helpdesks, and for the clusters 
internationalisation  and  clusters  excellence  actions,  based  on  the  results  of  recent 
evaluations of these actions.  

Some caveats are required here, as Toolbox 57 of the Better Regulation Guidelines states 
that a cost-effectiveness analysis (CEA) entails the quantification of the benefits and that 
the typical method used within a CEA to compare options is the benefit-cost ratio, which 
means dividing the benefits by costs. In the case of the COSME programme, whilst the 
financial  costs  can  be  known  with  some  accuracy,  a  diversity  of  (quantifiable  and 
unquantifiable)  benefits  are  produced.  For  that  reason,  a  benefit-cost  ratio  cannot  be 
calculated. Toolbox 57 also suggests that CEA is less easily applicable to interventions 
that have a number of objectives or that generate important indirect impacts, whereas the 
COSME programme addresses multiple objectives and is intended to generate both direct 
and  indirect  impacts.  Given  the  requirement  of  the  Better  Regulations  Guidelines,  the 
approach proposed here is to apply the broad concepts of a CEA, whilst recognising that 
the detailed requirements of a CEA cannot be satisfied. 

Taking  this  approach  –  which  depends  largely  on  the  perceptions  of  participants  and 
beneficiaries - the proportionality of costs and benefits is assessed in four ways. These are 
the extent to which participants and beneficiaries reported that: 

• 

• 

• 

• 

the benefits they gained exceeded the costs they incurred; 

the COSME actions offered value for money; 

the EU funding was sufficient for them to achieve the intended benefits; 

the administrative costs for them were proportionate (see next section). 

First, the majority of participants and beneficiaries of the EEN and EYE report that  the 
benefits they experienced exceeded the costs they incurred. As shown in the table below, 
this  was  confirmed  by  the  targeted  consultations  undertaken  at  the  interim  and  final 
evaluation stages. 

62 

 
 
Table 23: Proportionality of the benefits relative to costs 

Source: 
Interim 
evaluation of 
COSME 

Data from 
targeted 
consultations  

Source: Interim 
evaluation of 
COSME 

Data from 
targeted 
consultations 

Benefits outweighed Costs to a 
great/some extent 

Benefits outweighed Costs208 
not at all/to limited extent 

EEN 
SMEs 
Member 
Organisations 
EYE 
Host 
entrepreneurs 
New 
entrepreneurs 

68% 
63% 

69% 

67% 

91% 
92% 

55% 

64% 

5% 
10% 

11% 

8% 

9% 
5% 

31% 

23% 

Second, the majority of participants and beneficiaries report that the EEN and EYE offered 
value for money. For EYE, 71% (439/618) of new entrepreneurs reported that the exchange 
offered  value  for  money.  The  figure  was  slightly  lower  at  61%  (129/212)  for  host 
entrepreneurs. On the other hand, 22% (133/618) of new entrepreneurs and 29% (62/212) 
of host entrepreneurs responded that that benefits only outweigh costs “to a limited extent 
or not at all”209.  

The  vast  majority  of  EEN  members  responding  to  the  targeted  survey  (92%,  55/60) 
reported that EEN services offered value for money, given the benefits gained and the costs 
incurred.210 

Third,  majority of participants and beneficiaries of the EEN and EYE report that the EU 
funding was sufficient to achieve the intended benefits. Within the EYE programme, 48% 
of  NE  responding  to  the  Commission’s  feedback  survey  on  EYE  found  this  financial 
support to be “more or less” sufficient, and 28% found it to be sufficient, while 23% found 
the support to be insufficient.  

Only  a  small  proportion  of  EEN  member  organisations  faced  challenges  around  the 
sufficiency of funding to achieve the desired benefits. Of the EEN member organisations 
responding to the targeted survey, 79% (62/78) reported that the EEN COSME grant was 
sufficient  to  provide  all  planned  services,  while  17%  (13/78)  disagreed.  Overall,  91% 
(54/60) of the EEN members active during the COSME period considered that the EEN 
services offered value for money to a great extent (50% 30/60) or to some extent (41% 
25/60). 

The costs incurred for hosting a new entrepreneur for EYE varied but were rarely above 
EUR  5  000,  according  to  the  survey  of  EYE  participants.  The  host  entrepreneurs  who 

208  The  numbers  are  based  on  survey  responses  to  consultation  for  this  evaluation.  For  EEN,  the  SMEs  receive  the 
services for free but the surveys included a question on the administrative burden and those from reporting obligations. 
For EYE, respondents were asked whether the EY had offered value for money, given the benefits arising and the costs 
incurred. 

209 Some HEs shared feedback on possible ways to reduce the costs and increase the value derived from the exchange 
(notably be simplifying administrative, reporting and IT requirements. Overall, many HEs recognised that this situation 
has improved since 2018. 

210 Offered value for money to a great extent (50% of respondents 30/60), to some extent (42% - 25/60) 

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
quantified this in their responses mostly reported costs of no more than EUR 3 000 and 
nearly all reported costs below EUR 5 000. The feedback questionnaire commissioned by 
the Commission on EYE in 2023 indicated that 28% of new entrepreneurs considered the 
money to be sufficient, a further 47% considered the money to be more or less sufficient.211 
Finally, 25% of respondents considered the money to be insufficient.  

For  Clusters  Excellence,  64%212  of  respondents  to  the  survey  for  the  2021  Evaluation 
Study  of  Cluster  Initiatives  under  COSME,  H2020  and  FPI  confirmed  that  benefits 
generated by the initiative(s) exceeded the costs. Similarly, 87% of respondents213 to the 
survey  questions  on  Clusters  Go  International  for  this  2021  evaluation  confirmed  that 
benefits generated by the initiative(s) exceeded the costs. 214 

Regarding the international  IP SME Helpdesks,  as mentioned earlier, the 2018 Support 
Study for the Evaluation of the IP SME Helpdesks noted that the available evidence base 
for the efficiency criterion was limited, due to difficulties of fully measuring the possible 
benefits 
in 
litigation/enforcement of IP rights). This limits the possibility to use a classical cost/benefit 
(CB) ratio.  

(ie  potential  cost  savings  of  not  being 

infringed  or 

involved 

4.2.4  Administrative costs for applicants and beneficiaries 

Across  the  COSME  actions,  the  applicants  and  beneficiaries  tended  to  report  that  they 
found the administrative costs they incurred to be proportionate. 

The proportion of ineligible proposals depends on various factors including the experience 
and capabilities of the applicants, the level of attention paid to the provisions in the call 
and the clarity of the  call  documents. One situation that wastes time for  applicants  and 
evaluators is low eligibility rates and poor quality proposals  resulting from unclear call 
documents.  The  interim  evaluation  suggested  that  the  relatively  high  proportion  of 
ineligible proposals for Tourism grants, Cluster excellence and EYE215 pointed to a need 
to improve the description of the eligibility criteria. Conversely the interim evaluation also 
mentioned  the  link  between  the  clarity  of  the  work  programme  descriptions  and 
requirements for applicants and high proportion of eligible applicants, notably for actions 
such  as  EEN216  (4%  ineligible),  design-based  consumer  goods  (4%)  and  migrant 
entrepreneurship support schemes (8%).  

Across the full programme period, intermediaries and final beneficiaries found the costs 
and burdens associated with participation to be affordable and acceptable. At the interim 
evaluation stage, the costs and burdens were found to be affordable and acceptable across 
almost  all  actions.  However,  some  bodies  (especially  financial  intermediaries)  reported 
that  the  overall  administrative  burden  was  high.  The  evidence  gathered  for  this  final 
evaluation suggests a higher level of satisfaction on the part of intermediaries and final 
beneficiaries compared with the interim evaluation, as explained below. 

211 N= 6 050 NEs participating in exchanges between 2018 and 2023. 
212 N= 33.57% responded positive and 7% very positive. 
213 N= 66: 42% very positive and 45% positive. 

215 Share of ineligible proposals: Tourism grants (24%), Cluster excellence (24%) and EYE (18%) 
216 The high eligibility rate for EEN proposals was also partly  due to the fact that that most applicants had previous 

experience in the network. 

64 

 
 
 
 
Financial  intermediaries  for  the  LGF  report  a  reasonable  level  of  satisfaction  with  the 
administrative burden:  less than half (21/47) reported an additional administrative burden 
associated  with  reporting.  This  suggests  some  potential  for  streamlining  the  reporting 
process in this area.  

The majority of financial intermediaries are positive about the LGF process itself. Out of 
45  surveyed,  the  majority  reported  being  satisfied  with  the  different  procedural 
requirements, namely application (40), appraisal and due diligence (36), time taken to sign 
the contract  (29), and reporting requirements (27). The main exceptions to this positive 
experience overall tended to be small intermediary organisations and newcomers. Three 
issues  mentioned  were:  the  lengthy  period  for  negotiating  and  signing  the  contract,  the 
complexity of the contract (difficult to understand), and a linguistic barrier (as contracts 
and reporting documents were only available in English).217 

Private Equity and Venture Capital fund managers interviewed for this evaluation did not 
report  any  administrative  burden  specifically  associated  with  COSME,  although  some 
highlighted aspects that could be improved.218  The EIF’s in-depth due diligence and risk 
management  process  was  reported  by  a  few  of  the  fund  managers  interviewed  to  have 
slowed down investment operations, although others felt it was necessary - especially when 
dealing  with  public  money  -  while  increasing  the  transparency  and  quality  of  the 
investment.  Moreover,  the  requirement  to  prove  that  the  investment  is  part  of  the  EU 
taxonomy based on NACE codes can also limit or delay investment opportunities.219  

Final beneficiaries of the LGF report a high level of satisfaction with the administrative 
and  reporting  process.  In  the  targeted  survey,  only  a  minority  reported  increased 
complexity (9% 8/92) or costs (17% 16/92) related to the EU nature of the financing, and 
only 3% reported dissatisfaction with the reporting requirements (3/92). This is consistent 
with  the evidence from  the survey of final  SME beneficiaries carried out  as part of the 
interim  evaluation.  Of  the  final  beneficiaries  responding  to  the  targeted  survey,  the 
majority  had  not  experienced  a  greater  administrative  burden  (62%  57/92)  or  greater 
complexity (74% 68/92) compared with similar SME support programmes. Just over half 
(62%  57/92)  had  not  experienced  substantial  additional  costs  under  the  LGF.220  When 
asked to state the specific costs or administrative burdens incurred, most referred to those 
related to obtaining or preparing the necessary documentation.  47/92 LGF beneficiaries 
surveyed for this evaluation claimed that the speed of the processing of the application was 
more favourable than for other offers on the market, and 29/92 said it was the same. 61/92 
did not need any external help for this and 68 encountered no additional complexity due to 
the EU nature of the programme. 

Nevertheless, financial intermediaries noted an increase in administrative costs during the 
transition  from  the  EIP  to  COSME.  This  resulted  from  the  heightened  programme 
monitoring requirements stemming from the recommendations in the EIP final evaluation 
- the need to collect data on SME beneficiaries for programme assessment.221  

217 Source: intermediaries responding to the targeted consultations and one of the position papers for the public 

consultation. 

219 Frontier technologies in ICT and energy transitions do not always fit neatly into NACE codes and hard data 

requested to prove that they are part of the taxonomy discouraged firms from seeking support. 

220 European Commission. 2017. Interim Evaluation of the COSME programme. 
221 Especially given the limited availability of external data sources for certain SMEs, particularly microbusinesses. 

65 

 
 
 
 
As  regards  the  EEN,  the  survey  feedback  indicates  that  there  were  no  significant  costs 
related to administrative burdens for SME clients or for EEN members. Of the SME clients 
responding to the targeted survey222, 84% (27/32) reported incurring no direct or indirect 
costs because of receiving the EEN services (including administrative burden and reporting 
obligations). When asked in the targeted survey to comment on overhead costs incurred in 
the provision of EEN services, 11% of EEN members (12/106) reported incurring such 
costs. 

Intermediary  organisations  and  SMEs  involved  in  the  clusters  actions  report  high 
satisfaction with  administrative aspects.  In the targeted consultation  for this  evaluation, 
82% (18/22) confirmed that low human and financial costs of monitoring and reporting 
requirements  contributed  to  some  or  a  great  extent  to  the  clusters’  success.  86  %  of 
respondents (19/22)  said the same about simple administrative procedures.  

Similarly, for COSME clusters internationalisation actions, respondents to the surveys for 
the  2021  evaluation  study  on  clusters  actions223  tended  to  be  satisfied  overall  with  the 
application process,  the timeliness of support provision, the clarity of requirements and 
consortium agreement requirements. However, they were less satisfied with the frequency 
of calls.  

Concerning EYE, the majority of the participating entrepreneurs (64%) did not find the 
administrative requirements and reporting obligations to be particularly burdensome. Over 
a  third  of  them  found  the  obligations  to  be  fairly  or  very  burdensome  (25%  and  9% 
respectively.224 

4.3  Coherence  

The  most  internally  coherent  actions  are  the  financial  instruments,  EEN,  clusters 
internationalisation actions, the IP help desks, and the EU Japan centre. 

The supporting study finds that considerable progress has been since the time of the interim 
evaluation, which found that synergies within the COSME programme at that time were 
not  strong225.  Nevertheless,  it  also  suggests  a  need  for  a  more  systematic  approach  for 
identifying and implementing synergies, and for better interaction between communication 
tools for different actions.  

The COSME LGF and EFG were complementary, given that different types of SMEs had 
different financing needs.226  Both instruments were found to be mutually supportive. 

There  is  strong  coherence  between  the  international  IP  helpdesks  and  other  services 
supported  by  the  programme.  According  to  the  most  recent  monitoring  data,  the 
international  IPR Helpdesks  for  China, South-East  Asia, and Latin America  cooperated 
and  created  synergies  with  the  International  IP  Helpdesk  India  (COSME).  They  also 
cooperated with IP helpdesks funded by other EU programmes. Moreover, there was close 
cooperation between the EU Japan Centre, the international IPR Helpdesks and the clusters 
internationalisation programme (Clusters Go International and the ECCP platform). In its 

222 In total, 67 SMEs responded to this targeted survey, but the number of responses to individual questions varied.  
223 European Commission. 2021. Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, 

Galdiga, L., Van de Velde, E., Sadlik, A. et al., Evaluation study of and potential follow-up to cluster initiatives 
under COSME, H2020 and FPI, Publications Office, 2021, DOI: 10.2873/977418. 

224 N = 827 respondents to this question 
225 Information on these synergies is given in Monitoring reports 2019 and 2020. 
226 For example, start-ups and scale-ups/higher growth firms are proportionately more likely to need equity finance, 

whereas many established SMEs will only consider loan finance to fund their development and would be reluctant to 
use the equity instruments. 

66 

 
 
 
2022  special  report  on  SME  Internationalisation  activities227,  the  European  Court  of 
Auditors confirmed the good level of cooperation between the EU Japan Centre and EEN.  

The support for entrepreneurship was complementary to the financial instruments and the 
EEN, where some organisations are involved in implementation of both actions and  the 
EYE HEs are invited to the EEN annual conference, and EYE NEs receive information 
packages on EEN and its services. 

The  majority  of  EEN  members  surveyed  for  the  supporting  study  (62%  37/60)  also 
reported complementarity with services such as Your Europe Business portal and network, 
SME internationalisation portal, cluster networks and EYE. EEN members also actively 
informed  their  SME  clients  of  the  opportunities  available  under  COSME,  especially 
financial support.  

The  Your  Europe  Business  (YEB)  portal  included  information  from  various  sources 
relevant to SMEs, links to the EEN website and a form to submit questions to EEN. The 
EU-Japan  Centre  cooperated  with  EEN  for  partnership  services  and  EEN  concluded  a 
bilateral agreement with IPR Helpdesks. However, in the targeted stakeholder survey for 
the supporting study, only 10% (3/31) of SME client respondents reported that they also 
benefited  from  other  COSME  actions.  This  would  suggest  that  there  is  potential  for 
improving synergies within the programme. 

The study also suggests that COSME communication tools seemed not to have sufficient 
interaction  with  the  different  actions  (e.g.  for  entrepreneurship  support  actions).  One 
exception was the EU Open for Business campaign that did involve synergies between the 
main services and tools supporting SMEs. More could be done to signpost SMEs to the 
different forms of support available228. 

Table  24:  Synergies,  complementarities  and/or  cooperation  with  other  programmes  or 
support services 

Type or name of 
programme or 
actions  
Horizon 2020 
ESIF 

EFSI 
IP Helpdesks under 
various EU 
programmes 
National  and/or 
regional  support 
measures 

COSME actions that with synergies, 
complementarities, or cooperation 

Overlaps 

EEN, LGF, EFG 
EFG, EEN 
LGF: some overlap, but SMEs’ demand for 
credit was sufficiently strong to ensure that 
both regional and LGF finance were fully 
used. 
LGF (complementarity and cooperation) 
International IP helpdesks 
EU Japan Centre  

EYE: complementary to entrepreneurship 
and skills actions 
LGF and EFG: complementary to regional 
FIs 

See the middle 
column 

EFG 

227 European Court of Auditors. 2022. Special report 07/2022: SME internationalisation instruments   
228  The  study  and  recent  monitoring  data,  notably  the  COSME  2020  monitoring  report  and  the  2023  update  of  the 

monitoring fiches. 

67 

 
 
 
 
 
 
 
 
Digital Innovation 
Hubs229 

EEN:  
-  made  good  progress  with 

regional 

integration  

-  Cooperated with Digital Innovation Hubs 

Further details are given below, in the study, and the annual monitoring reports.  

4.3.1  Specific objective 1 SO1 - Access to finance 

Interviews  with  beneficiaries  and  the  EIF  carried  out  for  this  evaluation  pointed  to 
synergies between the COSME Loan Guarantee Facility (LGF) and the European Fund for 
Strategic  Investments  (EFSI)  SME  Window,  which  enabled  SMEs  to  benefit  from 
additional finance for working capital and for digitalisation.  

According to the monitoring reports and the interviews with beneficiaries and the EIF for 
the supporting study, beneficiaries found EFSI support more attractive (cheaper and with 
a longer tenure).230 Following an arrangement with EIF, EFSI resources were fully used to 
support investments in the EU, and EFG resources were used for investments in non-EU 
participating  countries  only.  The  2020  COSME  Monitoring  Report  noted  that  this 
challenged the deployment of COSME EFG resources as they could only be used for non-
EU participating countries where demand was much lower as the equity markets are much 
less developed in those non-EU participating countries. Since the market demand for the 
other COSME financial instrument LGF was much greater, the Commission addressed the 
situation also by allocating resources from EFG to LGF. 

Based  on  targeted  surveys,  the  supporting  study  suggests  that  there  is  some  overlap 
between the LGF and ESIF (e.g. in regions where ESIF managing authorities had designed 
guarantee  facilities  with  similar  risk  levels  to  COSME)231.  It  also  finds  them  to  be 
complementary.  ESIF  financial  instruments  are  only  implemented  in  the  national  or 
regional territories covered by the relevant programmes, which may lead to a fragmented 
delivery. The LGF, on the other hand, is  pan-European. The COSME instruments provide 
SMEs  with  access  to  finance  that  would  not  otherwise  be  available  or  would  only  be 
available on less favourable terms and conditions.232  

The  financial  intermediaries  surveyed  emphasised  that  a  distinct  advantage  of  COSME 
financial products, is their lack of geographical restrictions.233  

Coherence between COSME and Horizon 2020 financial instruments is strong. This final 
evaluation validates the preliminary finding of the interim evaluation. 234 

COSME LGF and national guarantee programmes were, in some cases, overlapping and 
competing against each other. The COSME interim evaluation raised some concerns that 
the  very  favourable  terms  and  conditions  of  the  LGF  could  have  displaced  national 

229 These started off as national/regional initiatives. As of 2023, the EDIH’s became operational.  
230 The Expansion and Growth Window under the EFSI Equity instrument has largely the same investment focus as the 
COSME EFG. However, the COSME EFG is broader in geographical scope as it can also invest in third countries 
participating in COSME.  

231 The targeted surveys of LGF financial intermediaries and SME beneficiaries. 
232 For example, 65 out of 92 LGF surveyed claimed that overall terms and conditions were more favourable compared 

to other offers. 

233 This made it easier for partner banks to construct a compatible portfolio, resulting in high and rapid absorption rates.  
234 EFG and Horizon 2020 InnovFin equity instruments were complementary (the EFG focused on funds investing in 
SMEs in the expansion and growth stage and InnovFin Equity focused on funds investing in early-stage companies - 
pre-seed, seed, start-up phase, and small midcaps that are RDI-driven. There was no overlap between the LGF and 
H2020 financial instruments. Synergies include the H2020 funding provided for specific EEN innovation services, 
and the cooperation between the international IP SME helpdesks and the IP Helpdesk supported under H2020. 

68 

 
 
guarantee programmes. The interviews for the supporting study confirmed that both were 
complementary  -  the  national  schemes  targeted  different  types  of  SMEs  than  LGF, 
particularly those seeking larger loan amounts. 

4.3.2  Specific objective 2 SO2 - Access to markets 

Enterprise Europe Network 

EEN  members  and  SME  beneficiaries  report  synergies  between  the  EEN  services  and 
business support services offered by Member States. This was confirmed by 68% (41/60) 
of EEN members235 responding to the survey for this final evaluation.  48% of EEN clients 
(15 out of 31) found that the EEN services complemented the existing national or regional 
support services.  

There was a high level of synergies and complementarity between EEN and innovation 
support activities funded through the Horizon 2020 programme (H2020) This finding was 
confirmed by the desk research and interviews undertaken for this final evaluation.  The 
EEN members interviewed for the supporting study confirmed that they collaborated with 
Horizon  2020  National  Contact  Points,  for  example  by  signposting  clients  to  them  and 
organising joint events. 

The EEN provides information and advisory services to SMEs to identify relevant funding 
opportunities and support services offered by other EU programmes. The EEN members 
interviewed  for  this  evaluation  confirmed  that  they  signposted  clients  towards  such 
services 236. 

The  design  of  the  EEN  helps  ensure  coherence  with  other  support  services  offered  to 
SMEs.  The  EEN  calls  for  the  2014-20  financial  period  required  that  network  services 
should  be  embedded  in  national  regional  and  local  support  environments  and  seek 
synergies  with  existing  actions  such  as  the  European  Institute  of  Innovation  and 
Technology (EIT) under Horizon 2020 and ensure that their services are complementary.  

The Commission also concluded bilateral agreements with organisations active in the field 
of  SME  internationalisation,  who  became  associate  members  providing  services  to  the 
EEN.237 

Nevertheless,  the  supporting  study  also  suggests  that  there  is  scope  for  improving  the 
integration  of  EEN  services  into  the  wider  support  offered  to  SMEs.    The  interim 
evaluation  of  COSME  highlighted  a  need  to  strengthen  EEN’s  regional  integration  and 
improve its visibility.238  

235 N=60 respondents to the question 
236  COSME  Monitoring  report  2020.  Services  provided  by  Horizon  2020  NCPs,  ERDF,  Interreg  projects,  EURES, 
Europe Direct centres, clusters and Digital Innovation Hubs. There was also regular collaboration between the EEN 
and a range of EU initiatives supporting SME internationalisation including the EU Gateway and Business Avenues. 
237 There were 7 European associate members (including Eurochambres, EBN, and European sectoral organisations such 
as  European  Major  Exhibition  Centres  Association  EMECA  ),  a  number  of  national  business  organisations).  EU 
agencies and networks (for example, the international IP SME helpdesks and EU-OSHA (health and safety). 

238 Ibid. 

69 

 
 
 
Other internationalisation actions 

There are no significant overlaps between COSME SME internationalisation actions and 
support  offered  by  Horizon  2020.  However,  there  are  sub-programmes  within  Horizon 
2020 that indirectly support SME internationalisation.  

The international IPR Helpdesks in China, South-East Asia, and Latin America and India 
cooperated  and  created  synergies  with  the  European  IP  Helpdesk  (Horizon  2020),  the 
Africa  IP  Helpdesk  (EU  Intellectual  Property  Office)  and  IP  Key  (DG  TRADE)  for 
organising joint events related to intellectual property. The international IP helpdesks also 
share a website with the European and Africa Helpdesks.239  

The 2021 clusters evaluation identified some synergies between both the European Cluster 
Partnership  for  Internationalisation  and  other  EU  programmes.  For  example,  36%  of 
respondents  to  the  survey  for  the  2021  evaluation240  considered  the  Horizon  2020 
programme 
the  European  Cluster  Partnership  for 
Internationalisation. They also benefited from support under other EU programmes. 

to  be  very  coherent  with 

The COSME programme also contributed to the Single Market Strategy and enabled SMEs 
to  capitalise on the opportunities afforded by the EU’s internal  market  notably through 
EEN service and by supporting the Single Digital Gateway.241  

4.3.3  Specific objective 3 SO3 -  Framework conditions and competitiveness 

The COSME tourism actions, by their unique focus on tourism SMEs, complement other 
forms of EU support for tourism. There are 17 EU programmes that offer the possibility of 
support for tourism businesses242, but  they have no funding specifically targeted at  this 
sector. The COSME tourism actions complemented these by providing specific support for 
the competitiveness and sustainability of tourism SMEs (127 projects funded from 2014-
20)243.  COSME  also  funded  several  studies  that  provided  data  and  findings  relevant  to 
other EU programmes and to national/regional support measures, including studies on out 
of  season  tourism  flows,  resilience,  digitalisation  and  sustainability244  and  a  flash 
Eurobarometer on tourism (2021).  

4.3.4  Specific objective 4 SO4 - Entrepreneurship 

The supporting study observes that there are similarities but no obvious overlaps between 
COSME  support  for  entrepreneurship  and  other  initiatives  in  the  Commission's 
Entrepreneurship 2020 Action Plan.245. 

239 COSME monitoring fiche IP Helpdesk 2020. 
240  See  page  and  9  of  the  evaluation  report:  H2020  EEN  (44/52)  respondents,  H2020  (43/56)  Smart  Specialisation 
Platform for Industrial Modernisation (S3P-Industry)  (32/44), ESIF (13/24). See p113 of this report for stakeholder 
survey results on Synergies between Clusters excellence and other EU support activities. 

241 European Commission. 2017. Interim Evaluation of the COSME programme.  
242  European  Commission. 
for 

2023.  Guide 

on  EU 

funding 

tourism, 

https://single-market-

economy.ec.europa.eu/sectors/tourism/eu-funding-and-businesses/funding-guide_en. 

243  European  Commission.  2021.  COSME:  Seven  years 

supporting 

the  growth  of  EU  Tourism, 

https://eismea.ec.europa.eu/news/cosme-seven-years-supporting-growth-eu-tourism-2021-05-31_en. 

244 GRO/SME/20/C/081 – events organisation - Very low value contract – Support to the stakeholder consultation process 

for preparing the transition pathway for tourism on Resilience, Digitalization and Sustainability.  
245https://single-market-economy.ec.europa.eu/smes/supporting-entrepreneurship/entrepreneurship-

education/commissions-actions-entrepreneurship-education_en 

70 

 
 
Overall, EYE was coherent with a number of EU policy goals and strategies in the field of 
SME and entrepreneurship policy, skills and education, and also single market.246 EYE has 
also shown additionality to national, regional and local measures: the interim evaluation 
found that EYE paved the way in emerging areas such as migrant entrepreneurship, and 
complemented  existing  EU  activities247  in  more  established  areas  of  support  to 
entrepreneurship248.  The  cross-border  dimension  of  EYE  is  highly  relevant  to  many 
entrepreneurs  and  is  a  key  feature  distinguishing  it  from  corresponding  national 
schemes.249  

The action “Enhancing Digital and Entrepreneurial Competences in Girls and Women” 
supported the implementation of the SME Strategy, the Skills Agenda, and the European 
Digital Education Action Plan.250 

4.4  How did the EU intervention make a difference and to whom? 

COSME has offered EU added value by supporting actions that go beyond the scope and 
depth of actions supported at national or regional level. The advisory services and grants 
brought  considerable  additionality  by  combining  expertise  from  a  large  number  of 
countries. This could not have been achieved by any national or regional programme. 

The programme enabled relatively large numbers of companies to benefit from finance and 
advisory services, bearing in mind the overall EU budget for the programme. The number 
of businesses receiving finance and/or advisory services was beyond the capacity of any 
national or regional support scheme.  

For the LGF, COSME provided EU added value by offering better conditions for SMEs 
than  national  and  regional  support  schemes.  It  also  ensured  availability  of  finance  for 
riskier businesses that did not have collateral. The EFG provided partial additionality by 
providing a wider scope or array of support than national or regional equity schemes. These 
findings were confirmed by interviews with fund managers for this evaluation. The EFG 
has  played  a  key  role  in  developing  the  European  equity  ecosystem  thanks  to  its  pan-
European  perspective  which  helped  overcome  fragmentation  of  the  European  equity 
market. It also provided larger amounts of capital to individual SMEs (larger ticket size) 
than the EU average, helping SMEs that needed larger amounts of finance to support their 
growth.  

COSME  supported  a  range  of  in-depth  advisory  services  for  SMEs  on  a  large  and 
international  scale.  The  international  component  of  these  services  was  not  available 
through national services and support schemes in many Member States, and therefore not 
available for a large part of EU SMEs. EEN offered total additionality and European value-
added by supporting networking and information sharing between the EEN advisors across 
the EU. This in turn enabled the network to provide in-depth services with a transnational 
and cross-border dimension which would not otherwise be offered by national or regional 
services. According to EEN clients responding to the survey, the main value-added of EEN 
was  the  individual  services  tailored  to  the  needs  of  the  enterprise,  the  support  and 
connections for finding business partners abroad and quick and relevant information on 

246 See supporting study for further information. In the EYE targeted survey (N=635), 86% of NEs agreed that the EYE 
exchange contributed to their learning about another market, 83% were encouraged to be professionally active in 
another MS, and 83% gained new knowledge and skills in running a business. 
247 European Commission. 2017. Interim evaluation of the COSME programme. 
248 European Commission. 2017. Interim Evaluation of the COSME programme. 
249 National schemes are complementary and serve a different audience. Furthermore,  over 70% of new entrepreneur 
respondents to the EYE targeted surveys (N = 635) reported gaining benefits related to operating internationally. 
250 Monitoring Fiche. GRO/SME/20/D/032 Enhancing Digital and Entrepreneurial competences in Girls and Women. 

71 

 
 
EU legislation and EU funding opportunities. The international IP helpdesks also provided 
full  additionality  by  helping  SMEs  to  obtain  tailor-made  responses  with  complex  input 
from several different countries.   

The 2021 evaluation study on Cluster Initiatives under COSME, H2020 & FPI251 found 
that  cluster  organisations  participating  in  Clusters  Go  International  considered  the 
supported cluster partnerships to be unique in terms of offering a cross-regional and cross-
sectoral  EU  approach  to  developing  market  access  for  SMEs  in  third  countries.  All  22 
respondents to the targeted survey for clusters and SMEs benefiting from cluster services 
for the COSME evaluation reported that the COSME funded actions would not have been 
funded in the absence of support from the programme.  

The  EYE  offered  additionality  and  strong  EU  added  value  by  providing  transnational 
mobility  possibilities  for  entrepreneurs  that  are  not  otherwise  available.  While  Member 
States offer a wide range of support for entrepreneurs, there are few if any instances of 
national programmes supporting transnational mobility and certainly none with the scale 
and international profile of EYE. 

Other  examples  of  projects  benefiting  entrepreneurship  include  those  supporting 
cooperation  and  peer  learning  between  regions.  These  provided  additionality  vis-à-vis 
national  programmes  by  fostering 
transfer  of 
entrepreneurial expertise that was more developed in certain regions and helped build a 
critical mass of specialised services and funding across individual ecosystems.  

the  cross-border  exchange  and 

Small actions to enhance framework conditions offered a stronger pan-EU focus than could 
have been offered by national funding and the funding of studies that contributed to EU 
policy actions for boosting competitiveness. For example, COSME supported monitoring 
actions  for  the  construction  sector  under  the  National  Recovery  and  Resilience  Plans 
providing a comparison between Member States and revealing differences and potential 
for improvement. 

The EU branding  and EU-wide scope of COSME has  delivered EU  added value in  the 
form  of greater international  profile. EEN branding  is  widely  used and its role for EU-
related support is recognized, but there is scope to increase SMEs’ awareness that EEN 
services are EU co-funded252. 

4.4.1  Specific objective 1 SO1 - Access to finance 

The LGF has filled a gap in financing for some SMEs that would not have been entirely 
filled by other sources of finance. Based on answers to the targeted survey253, it could be 
concluded that the additionality is 85%254, i.e. more than eight out of ten SMEs could not 
secure from other sources the same financial support that they received from COSME. This 
form  of  EU  added  value  was  also  confirmed  by  the  interim  evaluation,  where  the 
additionality was 63%. Of the SME beneficiaries surveyed in 2017, most relied on LGF 

251  Evaluation  Study  of  &  Potential  Follow-Up  to  Cluster  Initiatives  under  COSME,  H2020  &  FPI: 
https://www.ideaconsult.be/en/projects/evaluation-study-of--potential-follow-up-to-cluster-initiatives-
under-cosme-h2020--fpi 

252 Some of the interviewed EEN members reported that SMEs primarily recognise the  name of the EEN 
member organisation and do not always realise or remember that the services are co-funded by the EU. 

253 Question 'What would have happened if your business had not received the EU-guaranteed financing?' 
254  85%  is  the  sum  of:  39%  (32/83)  of  SMEs  would  have  obtained  the  same  amount  obtained,  but  with  different 
terms/conditions; 25% (21/83) of SMEs would have obtained smaller amount with different terms/conditions; 11% 
(9/83) of SMEs would have obtained smaller amount with same terms/conditions and 10% (8/83) of SMEs would not 
be able to obtain the financing needed at all, i.e. they had no other source. 

72 

 
 
financing  because  other  options  at  regional  or  national  level  were  either  unavailable  or 
insufficient255  and  the  LGF  provided  leverage  by  allowing  the  national  and  regional 
intermediaries to support more enterprises than they would be able to on their own. The 
possibility to combine national and LGF support led to even higher leverage, particularly 
in smaller markets.  

The  LGF  has  provided  more  favourable  financing  for  SMEs  than  would  otherwise  be 
available.  In the targeted survey for LGF final beneficiaries most respondents stated that, 
compared to offers that were available on the market at the same time, the LGF guarantee 
was either much more favourable or favourable than other sources of finance in relation 
the terms and conditions offered256. 

Intermediaries report in the interviews for the supporting study that the LGF has provided 
more  favourable  terms  and  conditions  for  financing  compared  to  similar  national 
programmes. Furthermore, even when compared to national programmes with comparable 
or better contract conditions, such as a free of charge guarantee without a cap rate, COSME 
remained  more  advantageous.  This  was  primarily  due  to  its  agile  implementation 
framework,  based  on  a  delegated  management  system.  In  contrast,  many  national 
guarantee programmes often required individual loan authorisation before disbursement, 
making them less suitable for smaller loans and unusable for leasing companies.   

The EFG provides more favourable and less fragmented financing than would otherwise 
be available. The fund managers consulted for the interim evaluation agreed that action at 
EU level is more efficient.  The fund managers interviewed for this evaluation confirmed 
these findings.  The EFG's pan-European perspective has been crucial in overcoming the 
fragmentation in the European equity market. Interviewees also highlight that the first-time 
teams (or fund managers that establish a private equity fund for a first time) might not have 
been created without EFG support. SMEs surveyed in the interim evaluation indicated that 
in  the  absence  of  EFG  financing,  they  would  have  considered  other  equity  financing 
sources, but expected that their growth rate would have been lower. The SME interviewed 
for the final evaluation confirmed that, in the absence of the EFG, the financing would 
have been received on less favourable terms, if at all.  

4.4.2  Specific objective 2 SO2 - Access to markets 

The EEN has a clear EU added value due to the scale and quality of their services, their 
cross-border nature in a Single Market context and the reciprocity.  

EEN services offer a transnational and cross-border dimension, which would not otherwise 
be offered by national or regional services.  In the interim evaluation of COSME,  87% of 
intermediaries and 48% of client SMEs indicated that EEN’s EU level support was ‘very 
important’ as opposed to only national support.257 In the survey for the supporting study, 
78% (47/60) of EEN members and 62% of SME clients258  consider it important (‘to a great 
extent’/’very’) for SMEs to have EU-level support services such as EEN as opposed to 
(only) national level support. 

255 European Commission. 2017. Interim evaluation of the COSME programme. 
256 Percentage of respondents confirming that the following points were much more favourable or favourable: overall 
terms and conditions (71%; 65/92), interest rate they had to pay on the borrowing (61%; 56/92), the collateral/security 
requirements (65%; 60/92), speed of processing the application (51%; 47/92) and the repayment period (50%, 45/92).  

257 European Commission. 2017. Interim Evaluation of the COSME programme. 
258 N = 36 respondents to the question.  

73 

 
 
The  EEN  introduced  certain  services  that  were  not  otherwise  available  at  national  or 
regional  level.  According  to  EEN  members  surveyed  and  interviewed  for  the  final 
evaluation, the EEN added value to the host organisations, expanding their networks and 
knowledge,  for  example  through  the  cross-border  working  groups  and  the  brokerage 
events.259  Moreover,  despite  a  strong  focus  on  cross-border  issues,  such  as  SME 
internationalisation, some EEN services also cover domestic markets issues, such as digital 
transformation and sustainability. In the targeted survey, EEN members reported that they 
were especially well supported by the Network for training (82%), monitoring/reporting 
(83%) and contractual management (73%).260 

The  EEN  provides  SMEs  with  free-of-charge  access  to  professional  services  that  they 
would not otherwise be able to afford. According to EEN members interviewed for the 
final evaluation, the main EU added value of the EEN is in providing access to professional 
in 
advice,  such  as 
internationalisation. According to the SME clients responding to the survey, the main value 
of EEN was the individual services tailored to the needs of the enterprise, the support and 
connections in finding business partners abroad and the quick and relevant information on 
EU legislation and EU funding opportunities. 

lawyers,  accountants  or  business  development  specialists 

In its 2022 special report on SME internationalisation activities261, the European Court of 
Auditors confirmed the high level of satisfaction on additionality of the EU Japan Centre. 
This was based on a survey of EEN members and trade promotion organisations conducted 
by the European Court of Auditors. 

4.4.3  Specific objective 3 SO3 - Framework conditions and competitiveness 

EU  added  value  is  offered  by  the  COSME  tourism  actions  by  providing  a  better 
understanding of the development of the sector and a greater contribution to its visibility 
than  national  actions.  For  example,  the  actions  for  boosting  innovation  in  tourism 
addressed the need to assist this ecosystem at an EU level, especially to  support digital 
transition which was progressing more slowly than in other sectors.262 Reports, studies and 
support actions funded by the Programme such as the Eurobarometer survey on tourism263 
and the European Capital of Smart Tourism264 addressed these needs.  

The  clusters  actions  offer  EU  added  value.  For  example,  the  2021  evaluation  study  on 
cluster initiatives under COSME, H2020 and FPI found that clusters organisations consider 
the Clusters Go International support unique for developing market access for SMEs in 
third countries.265  

The  same  evaluation  study  also  covered  the  European  Cluster  Collaboration  Platform 
(ECCP) and the European Strategic Cluster Partnerships for Excellence scheme. This 2021 
evaluation  study  noted that  the  added value of the  ECCP lies in  strengthening  clusters, 
companies or the regional ecosystem, offering new knowledge, links to important funding 
opportunities, and connecting similar clusters. The benefits include finding partners and 

259 62% EEN members in the targeted survey agreed that EEN activities helped their organisation develop. N=60 
260 N=60 respondents to the question.  
261 European Court of Auditors. 2022. Special report 07/2022: SME internationalisation instruments   
262 GRO/SME/20/C/07 (TOURINN) - Boosting the uptake of digitalisation, innovation and new technologies in 

tourism through transnational cooperation and capacity building.  

263 GRO/SME/20/F/116 - Eurobarometer Tourism 2020. 
264 GRO/SME/20/C/06 - European Capital of Smart Tourism - Fostering smart tourism solutions in EU destinations 

through the European Capital of Smart Tourism. 

265 In the survey for the supporting study, 82% of respondents (N=72) rated this EU level support as very important (and 
a  further  14%  responded  ‘important’). Some  77%  indicated  that  the  funding  allowed  them  (‘to  a great  extent’)  to 
undertake actions that would not otherwise have been funded, and a further 23% ‘to some extent’ 

74 

 
 
obtaining  access  to  information  that  would  otherwise  not  be  available.  Concerning  the 
European Strategic Cluster Partnerships for Excellence scheme, this 2021 evaluation study 
noted that they provide  value added  via widening of the network that leads to  capacity 
building of cluster organisations and improved services for members. 

Small actions on framework conditions have offered a stronger pan-EU focus on the issues 
in question.266,267   

4.4.4  Specific objective 4 SO4 -  Entrepreneurship 

The EYE offers transnational mobility possibilities for entrepreneurs that are not available 
elsewhere.  The  interim  evaluation  of  COSME  emphasised  the  importance  of  EYE’s 
transnational, large-scale approach and noted that this would not have been possible under 
national or regional initiatives.  

74%  of  EYE  HEs  surveyed  for  this  evaluation  reported  gaining  new  ideas  or  fresh 
perspectives  for  their  business,  55%  improvements  in  internal  skillsets  and  expanded 
knowledge of methods or techniques, and 41% highlighted the NE's contribution to the 
development or growth of their business.  

The projects supporting collaboration and peer learning among “European Entrepreneurial 
Regions”268  provided  EU  added  value  by  exchanges  of  entrepreneurial  expertise  (and 
addressing  potential  regional  gaps).  They  strengthened  regional  policy  development 
capacities and helped to build specialised services and funding across ecosystems.269  

4.5 

Is the intervention still relevant? 

The  specific  programme’s  objectives  are  in  line  with  a  series  of  EU  initiatives  and 
strategies including the 2008 Small Business Act for Europe (SBA),270 the Europe 2020 
strategy for smart, sustainable and inclusive growth, the Single Market Strategy (2015)271 
and the Start-up and Scale-up Initiative (2016).272 The “Think Small First” principle set 
forth in the SBA was at the core of COSME.  

COSME  objectives  aimed  at  addressing  key  challenges  for  European  SMEs,  and  the 
programme  adapted  to  emerging  needs,  building  on  its  predecessor,  the  EIP.  The 
supporting  study  suggests  that  programme's  flexibility  enabled  it  to  address  evolving 
priorities, including new issues faced by SMEs and new EU policy priorities. Changes in 
budget  allocation  were  made  during  the  implementation  of  the  programme  to  meet 
changing needs. Flexibility was cited in feedback provided by stakeholders benefiting from 
public procurement, social economy, and tourism actions273. All programming documents 

266 For example, a dashboard for monitoring actions for the construction sector under National Recovery and Resilience 
Plans.  provided  a  comparison  between  Member  States,  revealing  differences  and  potential  for  improvement. 
GRO/SME/20/F/103 - Initiatives for a Built environment.   

267  The  Better  Regulation  action  supported  the  further  development  of  consultation  tools  for  gathering  stakeholder 
feedback  (a  mandatory  part  of  the  process  of  preparing  EU  legislative  proposals).  GRO/SME/20/C/11  -  Better 
Regulation:  Engaging  SMEs  and  Stakeholders  on  policy  design  and  implementation/strengthening  of  the  Better 
Regulation Agenda. 

268 European Committee of Regions. 2022. Summary of the EER final workshop of the COSME project on Connecting 

entrepreneurial ecosystems. 

269 Monitoring Fiche, fostering collaboration through mapping, analysing and interlinking European Entrepreneurial 

Regions – Phase II (30_GRO-SME-20-C-01 F-EER II).  

270 Communication (COM(2008) 394 final) — ‘Think small first’ — A ‘small business act’ for Europe. 
271 Communication (COM(2015) 550 final) —Upgrading the Single Market: more opportunities for people and 

business 

272 Communication COM(2016) 733 final —Europe's next leaders: the Start-up and Scale-up Initiative. 
273 Feedback collected from interviews on the topic for the study 

75 

 
 
took account of the increased interest in sustainability, the digital and green transitions, 
and female entrepreneurship.  

The financial instruments (LGF and EFG), EEN, Clusters actions and EYE exchanges have 
positively contributed to achieving the objectives of COSME and addressing the market 
failures.  These  types  of  interventions  need  to  continue  to  support  the  SMEs’ 
competitiveness,  growth  and  performance  and  provide  an  SME-friendly  business 
environment and a stronger entrepreneurial culture in successor programmes. 

4.5.1  Specific objective 1 SO1 - Access to finance 

The  need  for  SMEs  to  access  finance  to  support  business  growth  remained  relevant 
throughout the 2014-2020 period (and beyond). There are differences in SME access to 
finance across the EU. Overall, insufficient collateral or guarantees as well as high interest 
rates or prices hindered SMEs from getting bank loans.274  

All financial institutions interviewed for the supporting study (22) confirmed that the main 
reason  for  rejecting  SME  loan  applications  is  the  lack  of  collateral.  COSME  LFG 
effectively addressed the issue of lack of collateral by diminishing or entirely removing 
collateral prerequisites through its guarantees. 

In  the  second  quarter  of  2021,  more  than  one  in  four  SMEs  that  replied  to  the  SAFE 
survey275  was  still  reporting  difficulties  in  accessing  finance,  but  the  share  of  SMEs 
perceiving this as a highly important issue decreased over time, pointing out that financing 
conditions had slightly improved.  

The EFG tackled strong market failures in the equity market and was highly relevant to 
SME needs. Young, fast-growing, innovative SMEs rely on equity financing more than 
other SMEs and these instruments are often not in sufficient supply.276 Equity can also be 
important for mature mid-market firms, helping them to unlock growth potential. Almost 
all  of  the  fund  managers  that  were  interviewed  for  the  supporting  study  (6  out  of  7) 
confirmed that the EFG's scope and the nature and volume of allocated resources were 
tailored to the needs of the different funds that it backed, and consequently the SMEs that 
were supported. 

4.5.2  Specific objective 2 SO2 - Access to markets   

Finding customers was a pressing problem for SMEs of all class sizes across the EU-28 
throughout the programme and this was reported as the most pressing problem in 2020277. 
The  2014  SME  performance  review  noted  that  there  were  many  internal  and  external 
barriers that impeded the internationalisation of SMEs278. It  also noted that SMEs were 
usually less well equipped with in-house expertise and financial or human resources than 
larger enterprises.  

274 According to the Commission’s 2014 Survey on the Access to Finance of Enterprises (SAFE), 59% of SMEs in EU-
28 expected their firm’s turnover to grow over the next 2-3 years. This figure remained broadly constant (at 58%-
65%) during 2014-2019, falling only slightly to 50% in 2020. To finance this growth, more than half of all SMEs 
(51%) required additional financing of more than 100 000 EUR, whilst another 26% required 25 000 EUR or more. 
During 2014-2020, 48-50% of SMEs continued to require additional financing of more than 100 000 EUR, whilst 
another 24-26% required 25 000 EUR or more. 

275 https://single-market-economy.ec.europa.eu/system/files/2021-11/Analytical%20report%202021.pdf 
276 Interim evaluation. 
277 SAFE Survey 2014 and SAFE survey 2020 p. 9. 
278 Related to market information, finding possible customers and the right partners, and compliance with foreign laws . 

SME Performance Review 2014, final report, p. 60. 

76 

 
 
The EEN services were relevant to addressing specific SMEs needs and market failures, in 
particular, information asymmetries and a lack of know-how on management processes, 
customer needs and how to enter foreign markets. Business cooperation services tackled 
networking failures of SMEs, by helping them to find partners.  

Overall, 58% (44/76) of EEN members participating in the targeted consultation for this 
evaluation, believe that the EEN services were pertinent to the needs of SMEs during the 
COSME period and 38% (29/76) to some extent.279 A majority of SME client respondents 
agreed that the EEN services were relevant to their business (22/34 or 65% ‘very relevant’ 
and  9/34  or  26%  ‘fairly  relevant’).280  According  to  the  SME  clients,  the  most  useful 
services  were  business  cooperation  services  (24/34  or  71%  rated  them  ‘very  useful’), 
followed by information services (22/34 or 65%) and advisory services (21/34 or 62%).281 

During the COSME period, EEN evolved to offer deeper support for SMEs, adapting to 
changing  SME  needs.  EEN  shifted  towards  providing  more  customised  and  customer-
centric  services  for  SMEs,  while  online  services  expanded  and  improved.  EEN  started 
providing  Innovation  Management  Support  in  2015  under  separate  grant  agreements 
funded by the Horizon 2020 programme. The scale-up advisors started in 2017 and other 
services  on  digital  transformation,  energy  savings  management  and  sustainability  were 
introduced towards the end of the programme.  

The Support Study for the Evaluation of the IP SME Helpdesks published in 2018 noted 
the  increasing  importance  of  internationalisation  and  global  value  chains,  including  for 
SMEs.  It  found  that  SMEs  (especially  the  helpdesk  users)  use  selected  IP  management 
techniques, but not the entire portfolio and that support to improve this situation was still 
relevant.  Survey respondents also supported a geographical extension of the help desk, in 
particular to India. In follow-up to this, the IP SME Helpdesk for India was set up (COSME 
work programme 2020).  

4.5.3  Specific objective 3 SO3 - Framework conditions and competitiveness 

At the start of the programme, SMEs faced particularly challenging framework conditions. 
Whilst they were in some ways more resilient than large enterprises during the downturn 
after  the  2008  crisis,  their  recovery  remained  slow  during  2011-2014.  The  2014  SAFE 
survey also highlighted compliance with regulation, availability of skilled and experienced 
managers, competition, and labour and production costs as pressing problems for many 
SMEs. This challenging context warranted specific measures to improve the SME business 
environment and ensure that SMEs could benefit fully from the wider growth expected in 
the first years of the programme. 

COSME  cluster  support  actions  are  relevant  to  address  the  clusters’  needs  for 
internationalisation  strategies.  The  targeted  survey  carried  out  for  the  supporting  study 
found that the Clusters Go International action programme was, overall, highly relevant to 
meeting the requirements of cluster organisations to develop joint strategies. It addressed 
to  support  SME 
key 
internationalisation: lack of finance (pointed to by 30% of programme participants), lack 
of personnel (30%), challenges in setting up joint investments (26%), lack of awareness of 
the potential benefits of joint activities (22%), and lack of regional support (29%).282  

issues  for  setting  up  collaborative  cluster  organisations 

279 N= 76 respondents to this question. 
280 N= 34 respondents to this question. 
281 N= 34 respondents to this question. 
282 Percentages of the respondents who strongly agreed that the mentioned factors constituted important obstacles to the 

cooperation among clusters in Europe at the time when they participated in the programme. N=23 

77 

 
 
The 2021 Evaluation Study of Cluster Initiatives under COSME, H2020 and FPI notes that 
the European Strategic Cluster Partnerships for Excellence action remains relevant since it 
enhances cluster cooperation, cluster management skills as well as strategy development. 

Tourism  actions  were  relevant  to  the  needs  for  SMEs  in  the  sector  to  move  towards 
sustainable and smart tourism practices.283 Overall, feedback from the interviews for the 
supporting study indicated that there was a significant gap in awareness and knowledge 
about sustainable and smart tourism practices among crucial stakeholders across the EU, 
coupled with a notably low rate of implementation of sustainable tourism initiatives among 
SMEs.284  285.    Although  there  were  very  few  responses  from  the  sector  to  the  targeted 
survey286, the results provide some insights into benefits of the COSME project. 82% of 
respondents (9/11) confirmed that the projects led to improved capacities for networking 
and  knowledge  sharing  in  the  sector,  and  73%  (8/11)  confirmed  that  the  projects  had 
improved exploitation of new tourism demand trends287.   
The SME performance review provides valuable insights into the state of SMEs across the 
EU with data-driven assessments of their performance and challenges, and further support 
is provided by the SME Envoys, the European Enterprise Awards288 and the EU REFIT 
platform289.  The  COSME  interim  evaluation,  and  stakeholders  consulted  for  the  final 
evaluation considered these measures to be relevant as they contributed to a more business 
friendly environment. 

4.5.4  Specific objective 4 SO4  - Entrepreneurship 

The  supporting  study  found  that  the  Promoting  entrepreneurship  and  entrepreneurial 
culture  objective  was  relevant  at  the  outset  of  the  programme  and  throughout  its 
implementation. 

The need for a stronger entrepreneurial culture has been highlighted in, inter alia, the 2014 
SME Performance Review ("Entrepreneurship" identified as a challenge290), and the Small 
Business Act (a need to pay attention to all situations that entrepreneurs face, including 
start-up, growth, transfer and bankruptcy (second chance), entrepreneurship education, as 
well as benchmarking and exchanges of good practices). 

In  a  number  of  entrepreneurship  actions,  COSME  targeted  potential,  young,  new  and 
female  entrepreneurs.  The  main  action  is  the  Erasmus  for  Young  Entrepreneurs  (EYE) 
programme.  The  survey  of  EYE  entrepreneurs  for  the  supporting  study  confirmed  the 
programme's relevance291, with nearly 80% of respondents stating that it addressed their 

283 In the targeted survey, 46% of participants agreed that the action improved networking and knowledge sharing in 

EU tourism, and improved exploitation of new demand trends. N=11 

284 Feedback collected from interviews on the topic. 
285 The study and the 2019 and 2020 monitoring reports highlight several examples of projects and studies that were 
particularly relevant to this goal including projects contributing to the transition pathway for tourism on resilience, 
digitalisation and sustainability and the Eurobarometer Tourism 2020 that  demonstrated the growing importance of 
sustainable tourist offers. (GRO/SME/20/F/116). 

286 Targeted survey of providers and beneficiaries of other COSME/EIP actions. 
287  Senior,  youth,  low  season,  sustainable  tourism,  cultural  tourism,  enhancing  uptake  of  innovation  and 

technical tools in the sector. 

288 Awards that recognise outstanding SME achievements, promoting innovation and entrepreneurship. 
289  A  platform  that  focuses  on  regulatory  fitness,  reducing  administrative  burdens,  and  improving  the  business 

environment. 

290 2014: A partial and fragile recovery - Annual report on European SMEs. 
291 In particular, more than 74% of host entrepreneurs and 76% of new entrepreneurs indicated that the EYE addressed 
“a lack of entrepreneurial culture and weak entrepreneurial spirit” at least to some extent, 72% of both HE and NE 

78 

 
 
 
 
 
needs to some or a great extent.292,293 These results are consistent with the 2017 interim 
evaluation294. 

Relevance to new EU policy priorities  

As  programme  implementation  progressed,  more  emphasis  was  put  on  innovation  and 
digitalisation.  New  EU  policy  initiatives  approved  in  the  final  years  of  the  programme 
include the Digital Europe Programme (2018) to strengthen the EU's digital capabilities. 
The  study  suggests  that  COSME  complemented  these  initiatives  and  the  Horizon  2020 
programme  by  supporting  projects  and  services  (such  as  EEN  and  sectoral  projects)  to 
support businesses with digital integration. The EU Single Digital Gateway (SDG) was set 
up to simplify access to information and single market services for citizens and businesses 
in the EU.  

In  the  2014-2020  period,  particular  attention  was  also  devoted  to  sustainability  and  the 
green  transition.  The  European  Green  Deal  (2019)  became  a  central  policy  framework 
aiming  to  make  the  EU  climate-neutral  by  2050.  COSME  funded  initiatives  helped 
enterprises and clusters develop green and sustainable products, and part of the COSME 
financial  support  was  allocated  to  SMEs  which  made  environmentally  friendly 
investments.  

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNT? 

5.1  Conclusions 

Overall,  the  final  evaluation  confirms  the  positive  conclusions  reached  by  the  interim 
evaluation of COSME and provides further evidence on the final years of the programme. 

The  programme  built  on  the  results  of  the  previous  EIP  (2007-13)  from  which  it  has 
inherited most of its actions. Whilst  acknowledging the importance of innovation in  its 
interventions,  COSME  adopted  a  broader  scope.  The  programme  made  significant 
progress  towards  achieving  its  general  and  specific  objectives,  successfully  tackling  a 
range of complex issues at the same time, based on the analysis of available hard data and 
the feedback from the surveys. 

The programme supported SMEs in accessing finance, in understanding how to operate in 
new  markets  and  global  value  chains,  and  in  collaborating  across  borders  and  within 
clusters. More generally, it promoted entrepreneurship and business creation and a more 
business-friendly environment.  

One  key  strength  of  COSME  was  the  use  of  intermediary  bodies  and  entities  with 
established relations and knowledge of the community targeted by the different initiatives 
to implement projects and deliver support services to SMEs. Other key strengths were the 
flexibility of the programme, the strong track record on financial implementation, and good 
budgetary monitoring, which enabled unused budget to be re-allocated to other actions. 

stated  that  it  helped  with  “obstacles  to  entrepreneurs  setting  up  businesses”,  and  65%  that  EYE  supported  “new 
businesses struggling to survive and grow” and 61% of HE and 66% of NE agreed that it addressed “low levels of 
entrepreneurial firm creation” 

292 N=500 respondents to this question.  
293 Altogether 45% of new entrepreneurs (NE) and 52% of host entrepreneurs (HE) assessed that EYE responds to the 
needs of entrepreneurs at least to some extent, while a further 28% of NE and 27% of HE reported that it had addressed 
their needs to a great extent. N=124HE and N=376NE 

294 European Commission. 2017. Interim evaluation of the COSME programme., p. 32. 

79 

 
 
The evidence gathered through the consultations and further research conducted for the 
study suggests that COSME had positive effects on final SME beneficiaries across all of 
its objectives.  

financial 

thousands  of  SMEs, 

instruments  supported 

The  COSME 
including 
microenterprises, and exceeded the original targets in terms of the volume of investments 
and funding mobilised. The counterfactual analysis for LFG demonstrated a good impact 
on survival rates, but no causal proof of impact on employment, turnover and total assets. 
The EFG had good impact on survival rates, employment and economic performance in 
general.  Although  the  EFG  could  not  demonstrate  statistically  significant  and  positive 
economic  benefits,  largely  due  to  the  very  small  final  sample  size,  nevertheless,  the 
analysis demonstrates that over time, the EFG final recipients have not only exhibited high 
survival  rates  but  have  also  experienced  significant  positive  trends  in  their  economic 
performance, e.g. increase in turnover and assets.   

The EEN was also  effective. It helped nearly 2.9 million SMEs obtain crucial advisory 
services, information to operate in new markets and support in finding partners. Evidence 
from  the  surveys  indicates  that  EEN  services  helped  SMEs  to  survive,  maintain  and/or 
increase their workforce, expand into new markets, and maintain or sustain their turnover. 
EYE also showed some very positive impacts, notably on skills.   

It  can  be  concluded  in  a  qualitative  way  that  the  support  provided  by  the  programme 
contributed to the competitiveness of the companies which obtained the support. 

Other thematic actions (including entrepreneurship, clusters and tourism) were successful, 
and many smaller  actions made a valuable contribution to  the goals  of the programme. 
Some  smaller  actions  were  more  successful  than  others.  A  few  actions  faced 
implementation and performance issues were closely monitored by the Commission.  

The  evaluation  finds  that  the  programme  was  implemented  efficiently  and  in  a  cost-
effective way. Evidence from the consultations indicate that costs and burdens associated 
with the programme are affordable and acceptable, although it was challenging to quantify 
the benefits. For most participants, the benefits generated by the programme outweighed 
the  costs.  However,  reporting  obligations  in  some  cases  were  found  to  be  somewhat 
burdensome  (for  instance  in  the  tourism  sector).  The  desk  research  confirmed  the 
comparatively  low  administrative  costs  of  the  programme,  providing  benchmarks  with 
other  EU  programmes.  The  execution  rate  of  the  programme  budget  remained  high 
throughout the programme and regular monitoring allowed the COSME budget to be re-
allocated, in response to emerging needs.  

The evaluation finds that COSME demonstrated a significant added value at the EU level. 
It provided SME support that goes beyond what is typically available at the national or 
regional level. These benefits include providing financing options that are not available in 
Member  States  on  the  same  terms,  offering  value-added  advisory  services  on  a  more 
international  scale,  and  delivering  effective  support  for  entrepreneurs  for  transnational 
cooperation and exchanges.  

The COSME programme was highly relevant, both at the start and throughout its duration. 
It  addressed  deep-seated  market  failures  affecting  the  Union  economy,  notably  high 
borrowing costs and difficulties in accessing finance due to information asymmetries, an 

80 

 
insufficient supply of equity finance, challenges for accessing customers and international 
markets, and weaknesses in entrepreneurial culture.295. 

It helped SMEs to survive, grow, and reap the benefits of the single market. Moreover, the 
programme performed well on adaptability to changing needs, adjusting its interventions, 
and  directing  funding  to  respond  to  new  challenges.  The  programme  addressed  these 
challenges notably through the  financial instruments,  information  and advisory services 
such  as  EEN  to  support  SMEs  with  market  access  and  help  them  deal  with  formalities 
related to cross-border business, EYE and other actions for entrepreneurship, and through 
studies  and  reports  such  as  the  SME  Performance  Review,  and  cooperation  with  SME 
stakeholders to address administrative burdens. 

COSME’s interventions were also aligned with broader EU policy priorities such as the 
green  and  digital  transition,  gender  equality  and  mainstreaming,  social  cohesion  and 
inclusion. Attention to these objectives increased in the later years of the programme. 

The supporting study identifies adequate levels of internal and external coherence overall 
(notably for the larger actions such as EEN and the financial instruments) and notes the 
progress made since the time of the interim evaluation.  

Financial instruments have demonstrated high internal coherence, with loan guarantee and 
equity  financing  being  mutually  supportive.  Larger  actions  such  as  EEN,  the  financial 
instruments, and actions such as the international IP SME Helpdesks built synergies with 
actions  supported  under  other  EU  funds  and  programmes  (Horizon  2020,  EIC,  others). 
Although many smaller actions made a valuable contribution to the goals of the programme 
and achieved good impacts, some were less coherent.  

5.2  Lessons learnt 

The evaluation found that an area for improvement in programme planning is developing 
a more complete logical framework explaining how all actions, especially the smaller ones, 
aim  to  address  specific  needs  and  market  failures  coherently  and  contribute  to  the 
programme’s  overall  objectives  and  broader  EU  policy  priorities296.  Developing  further 
such a framework would facilitate the on-going assessment of the programme and ensure 
that  all  actions  preserve  a  strong  relevance.  Such  a  framework  could  also  provide  a 
valuable tool at the work-programme design stage for screening of proposed actions. 

The  results  for  LGF  only  partially  align  with  those  for  the  predecessor  financial 
instruments under the CIP and MAP programmes.297 The supporting study concluded that 
the counterfactual results cannot be directly compared with previous research, due to the 
alternative methodological approach followed for the COSME study. The study notes that 
one possible explanation for these different results is that the control group of businesses 
that had “not  yet  benefited” from  LGF support were better prepared298 than the control 

295 These issues are highlighted in various studies and reports , including SAFE surveys, the annual SME 

Performance reviews and EIF papers such as eif_working_paper_2022_84.pdf .  

296  The  supporting  study  observed  progressive  improvements  in  internal  and  external  coherence  throughout  the 
programme,  notably  for  larger  actions.  The  supporting  study  also  noted  the  improvements  to  work  programme 
descriptions in the final years of the programme. These allowed to improve coherence of the supported actions.  

297  These  previous  studies  demonstrated  that  EU  guaranteed  loans  impacted  positively  on  SME  growth  in  terms  of 

employment, sales and profits. 

298  For  example,  they  could  have  been  in  the  process  of  improving  their  business  plans  in  preparation  for  seeking 

additional finance in future. 

81 

 
 
 
group used for previous studies (that did not subsequently benefit from any funding from 
financial instruments at all).  

involvement  of  multiple 

intermediary  bodies  has  clearly  contributed 

The 
to 
relevance/effectiveness  of  the  actions.  However,  this  mode  of  implementation  has  also 
contributed  to  the  fragmentation  of  the  actual  monitoring  and  reporting  system,  and 
challenges for gathering data on final impacts which in turn hampers the assessment of the 
impacts of the programme. Nevertheless, benefits stemming from involvement of many 
actors outweigh the downsides of Programme fragmentation.  

Evidence  from  the  consultations  indicate  that  the  costs  and  burdens  associated  with 
participation  in  the  programme’s  actions  were  affordable  and  acceptable,  though  some 
participants  in  specific  actions  (for  instance  in  the  tourism  sector)  found  reporting 
obligations to be somewhat burdensome. In light of this, further work on monitoring would 
benefit  from  increased  attention  to  avoiding  additional  burdens,  for  example  by  better 
integrating project reporting with Programme monitoring.  

In  general,  a  significant  part  of  the  findings  is  based  on  stakeholder  consultations  and 
targeted surveys. Although the public consultation resulted in a limited number of replies, 
targeted surveys were more successful and provided the Commission with evidence that 
can be considered robust, given the size of the programme.   

COSME demonstrated an adequate level of internal and external coherence overall, but 
there is still room for improvement. The identification of synergies for main actions could 
be better pursued on a regular basis. The evaluation suggests that a better signposting of 
support available for SMEs and entrepreneurs, and developing stronger links between the 
programme’s actions at the operational level could further enhance effectiveness. 

Key lessons learnt:  

COSME presented a number of key strengths. The Programme had positive effects on final 
SME  beneficiaries,  was  relevant  and  remained  relevant  throughout,  presented  a  strong 
track record on implementation and confirmed the validity of intermediaries as an effective 
implementation mode. Yet, a number of key suggestions for future improvement can also 
be proposed: 

•  Develop a simpler and more logical framework for monitoring which would 
facilitate the assessment of the programme and ensure that all actions preserve 
a strong relevance.  

• 

Increase  attention  paid  to  the  results  and  impacts  of  the  programme, 
including in the longer term, and to the measurement of the indicators laid down 
in the COSME regulation and subsequent programming documents for all the 
actions. 

• 

Improve coherence of smaller actions. The identification and activation of 
synergies should be further pursued on a regular basis.  

82 

 
ANNEX I:   PROCEDURAL INFORMATION 

Lead DG 

The DG for Internal Market, Industry, Entrepreneurship and SMEs (GROW) is the lead DG for this 
evaluation (PLAN/2022/491). 

Organisation and timing 

The final evaluation of the COSME programme was carried out in parallel with the ex post evaluation 
of  the  Entrepreneurship  and  Innovation  programme  (2007-2013),  the  predecessor  to  the  COSME 
programme. In this context, DG GROW set up one inter-service steering group (ISG) to guide both 
evaluations and certain deliverables such as the methodology are common to both evaluations.  

The ISG was established on 8 July 2022 involving representatives from the Secretariat-General, Legal 
Service,  DG  for  Research  and  Innovation,  DG  for  Budget,  DG  for  Competition,  DG  for 
Communications Networks, Content and Technology, DG for DG Defence Industry and Space, DG 
for  Economic  and  Financial  Affairs,  DG  for  Employment,  Social  Affairs  and  Inclusion,  DG  for 
Energy, DG for International Partnerships, DG for Structural Reform Support, DG for Taxation and 
Customs Union, DG for Trade and DG for Internal Market, Industry, Entrepreneurship and SMEs. 
The Joint Research Centre joined the ISG in September 2023 and also provided input at the time of 
the RSB upstream meeting in June 2023. DG Environment and EIF299 joined the group in September 
and November respectively. 

The ISG contributed to the evaluations and ensured that they met the necessary standards for 
quality. Six meetings300 were held between November 2022 and December 2023. An additional 
meeting took place in June 2024 to present the  draft Staff Working Documents for this evaluation. 

The Commission published a call for evidence on the final evaluation of the COSME Programme 
on 17 March 2023 that was open for feedback until 14 April 2023. 

The Commission published a public consultation on the final evaluation of the COSME 
Programme on 15 June 2023 that was open for feedback until 18 September 2023. 

Five targeted consultations related to COSME were carried out by the consultant who performed the 
supporting study301. The consultation period ran from early August 2023 until the end of September 
2023302. 72 interviews were carried out with key stakeholders. 

Consultation of the RSB 

The RSB was consulted informally in an upstream meeting on 9 June 2023. As a follow-up, a 
checklist was prepared and guidance was provided to the consultant on related points to address in 
the supporting study. 

A formal consultation of the RSB took place on 31 January 2024. 

299 The EIF was closely involved from the onset through the intermediary of DG GROW C1 and ECFIN. 
300 1) 16/11/2022, 2) 13/4/2023, 3) 23/5/2023, 4) 25/10/2023, 5) 4/12/2023, 6) 13/12/2023 
301 The 6th targeted consultation related purely to the ex post evaluation of EIP. 
302 Further information, including the consultation dates is available in the Annex II (Methodology) 

83 

 
 
 
The RSB issued a positive opinion on the evaluation.  

Table 25: Table on follow-up to RSB’s observations 

COMMENT RSB 
1.The report does not explain clearly enough the robustness of the counterfactual analysis 
and additionality of COSME. 

REPLY 

 The report should more explicitly present the 
robustness of the counterfactual analysis given the 
observed limitations such as the use of the Orbis 
data and the selection of the control group. It 
should better explain the reasons for any 
substantial methodological deviations from 
similar research and approaches. The report 
should explain what tests/checks were undertaken 
to ensure the robustness of data and whether 
results on economic impacts coming from 
different models diverge or not from the results of 
the counterfactual analysis. 

The analysis of the additionality of COSME 
should be further developed, especially for the 
actions other than the Loan Guarantee Facility. 
The report should better elaborate to what extent 
similar effects could have been achieved with 
different instruments, at the EU or Member States 
level. The analysis should be underpinned by 
evidence and adequate level of quantification. It 
should differentiate between the full additionality 
(no alternatives available) and partial additionality 
(alternatives available but at less favourable 
conditions or smaller scale). The additionality 
analysis should also inform the assessment of EU 
added value and relevance. 

Additional explanations were provided in the 
report with regards to the robustness of the 
counterfactual analysis such as limitations in 
the use of Orbis data, checks undertaken and 
conclusions on robustness (sections 1.2.  and 
Annex IIA. ). In particular the section 
“Robustness of the findings and any 
limitations” contains an explanation on the 
challenges of constructing a control group 
for the LGF. Regarding the EFG, the 
methodology for the counterfactual analysis 
requires data from 2-3 years after the 
intervention, which is not yet fully available. 
This was made clear in the text.    

Additional improvements and clarifications 
on the additionality of COSME in the area 
beyond LGF, including limitations of data, 
were made throughout the report, in 
particular in the section related to the EU 
added value “How did the EU intervention 
make a difference and to whom?”.   
Explanations on partial additionality vs. full 
additionality were added in this section. 

2.The effectiveness and efficiency assessments are not sufficiently clear. 

The report should be clearer whether the analysis 
was able to establish a causal link between 
company performance and the support received. It 
should explain how company performance was 
defined and whether the results vary for different 
parts of COSME. The report should better explain 
how effective COSME was in reaching the 
objective of enhancing SMEs competitiveness. 
The effectiveness analysis should also include 
more details on how effective COSME was in 
achieving the expected impact of reduced 

Additional improvements on effectiveness 
were made in the report, notably on the 
causal link between company performance 
and support received as well as the reduced 
administrative burden for SMEs. For the 
LGF the causal link was only demonstrated 
for the number of employees.  For the EFG 
it is too early to prove the causal link.   
Company performance was defined in the 
section 4.1.1. as “survival rates, 
employment, turnover and total assets”. 

84 

 
 
  
 
 
administrative burdens for SMEs. Targets and 
expected impacts included in legislation or 
subsequent documents should be clearly 
referenced. 

Outside the financial instruments, the 
findings indeed vary as it is not possible to 
demonstrate causality in the same way as for 
the counterfactual analysis. 
A new subsection “Effectiveness of COSME 
for enhancing SME competitiveness” was 
added in the effectiveness part, section 4.1.1. 
A new subsection “Effectiveness of the 
programme for reducing administrative 
burdens” was added  in the effectiveness 
part,  section 4.1.1.   

Additional information on indicators and 
targets has been added in section 4.1.1 and 
an overview of all indicators laid down in 
the COSME Regulation (targets and results) 
is given in Annex VII). 

The report should improve the efficiency analysis. 
It should better explain the conclusions on the 
benefits outweighing the costs and COSME 
providing good value for money. In this respect, 
the report should be clearer about the evidence 
base underpinning those statements, in particular 
whether or not they are only based on the 
perception of surveyed beneficiaries. The benefit 
analysis should be strengthened with qualitative 
analysis going beyond summarising different 
consultation activities. The report should provide 
further explanation of the efficiency (cost-
effectiveness) metrics by providing their 
comparison with relevant indicators from other 
appropriate EU or international programmes. 

Additional improvements on the efficiency 
analysis were made in the report, in 
particular about the evidence base 
underpinning  statements regarding benefits 
and costs. Qualitative analysis was added, 
notably on the cost savings of avoiding 
litigation in case of IP SME helpdesks and 
benefits exceedings costs for the Clusters 
Excellence action (heading “Proportionality 
of costs and benefits” in section 4.1.2). The 
explanation on the cost-effectiveness 
comparison  with other programmes was 
made in the report under the heading 
“Efficiency of programme management”. 

3. The conclusions and lessons learnt do not reflect well enough the key findings of the 
analysis. 

The conclusions and lessons learned should 
reflect the overall analysis in the report and make 
a clear connection with the existing evidence. The 
conclusions should be more explicit on the 
robustness of the analysis. The report should 
highlight how the lessons learned are going to be 
used to improve the future monitoring and 
evaluation arrangements for EU actions 
subsequent to COSME. 

Conclusions and lessons learnt have been 
reviewed to better reflect the key findings of 
the analysis. Additional language on the 
robustness of the analysis was added. In 
particular, the section detailing key strengths 
and weaknesses as well as lessons learnt was 
expanded in the section “What are the 
conclusions and lessons learnt?”.  

Evidence, sources and quality 

85 

 
  
 
 
 
This evaluation report drew on the following sources of evidence: 

•  Supporting study for the final evaluation of COSME, 2024303. The study was carried out by 
Centre  for  Strategy  and  Evaluation  Services  (CSES)  and  Centro  Studi  Industria  Leggera 
SCRL(CSIL), members of the Oxford Group A/S consortium. The study has been published. 

Interim evaluation of the COSME Programme, 2017305  

•  The COSME Programme Impact assessment, 2021304 
• 
•  COSME Annual Monitoring Reports and data306 
•  Economic data including SME Performance Reviews307, SAFE Surveys covering the period 

2014-20308 

303    COSME supporting study (2024) COSME 
304    SEC(2011)1452,  November 2011 
305   https://data.europa.eu/doi/10.2873/87360  
306   https://single-market-economy.ec.europa.eu/smes/cosme/programming-monitoring-and-evaluation_en 
307   https://single-market-economy.ec.europa.eu/smes/sme-strategy/sme-performance-review_en  
308   https://single-market-economy.ec.europa.eu/access-finance/data-and-surveys-safe_en 

86 

 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

A. Summary of the methodology, limitations, mitigating actions and overall robustness  

The final evaluation addresses the seven years of operation of the COSME programme, from January 
2014  to  December  2020  also  including  actions  and  projects  funded  by  2014-2020  budget  that 
continued after this period and those still ongoing at the time of the final report. The evaluation was 
carried out in line with the five evaluation criteria of the Commission’s Better Regulation Guidelines, 
complemented  with  an  additional  criterion  on  the  long-term  impacts  and  implications  for 
beneficiaries and stakeholders (and action taken to ensure the measures had long-lasting effects). 

 Sources of information and data analysis 

The evaluation methodology built on different analysis methods and data sources. The evaluation is 
mainly informed by the supporting study, incorporating case studies, and using the wealth of evidence 
already  collected  by  previous  studies  (including  previous  evaluations  of  the  programme),  the 
programme impact assessment, annual monitoring reports for the programme, monitoring forms filled 
in for each action, data from the European Investment Fund and EISMEA (see Annex I) and other 
relevant economic data (including data from the annual SME Performance Review. 

Supporting Study Design and methods 

Annex VIII of this document includes full case Studies, together with a number of shorter summaries 
of case studies and success stories.  

Reliability of data provided by EIF and EISMEA  

The  impact  of  the  above-mentioned  limitations  was  mitigated  to  a  maximum  possible  extent,  in 
particular  by  counter  balancing  lacking  reliable  quantitative  data  with  qualitative  and  quantitative 
data from the targeted surveys and the sources of additional evidence listed in Annex  I. 

Reliability of data and critical assessment of work carried out by the contractor 

There  were  some  limitations  in  the  availability/completeness  of  data  provided  by  the  EIF, 
EISMEA and DG GROW. These were compensated by quantitative and qualitative data provided in 
the targeted surveys and the interviews. 

Targeted  surveys:  Due  to  the  risk  of  stakeholder  fatigue  identified  in  the  inception  phase  of  the 
study,  the  timing  of  the  consultation  period  (2023  summer  holiday  period),  and  the  low  initial 
response in August, the consultancy team adopted all possible  mitigation measures to achieve a 
good response rate (as outlined in the full methodology later on in this annex). The consultant, 
the Commission and EISMEA promoted these consultations through multiple dissemination channels 
and by involving  intermediary organisations in  the survey dissemination  process.  These measures 
significantly  increased  the  survey  response  rate  in  September.    The  number  of  responses  to  the  5 
targeted surveys covering COSME309 are in line with the results achieved in previous consultations 
with particularly good results for the EYE survey.  

As  part  of  the  consultation  plan  for  the  study,  the  consultant  conducted  72  interviews  with  key 
stakeholders (surpassing the initial target of 45-60).  

targeted  consultations  (surveys)  for 
The  original  consultation  strategy  foresaw  separate 
intermediaries and beneficiaries of equity support. It was agreed, however, to conduct targeted 
more in-depth interviews with a sample of EFG fund managers and SMEs, given that another survey 

309 The number of responses ranged between 67 (final recipients of SMEG and LGF guaranteed loans) and 1200 (EYE) 

87 

 
 
outside this evaluation was planned for the summer, due to the limited population targeted, and with 
a view to increasing the response rate.  

Counterfactual approach 

The  design  of  the  counterfactual  approach  was  based  on  an  extensive  literature  review  of 
counterfactual  analysis  of  debt-based  support  instruments  within  and  outside  the  EU.  This  was 
relevant for drawing hypothetical conclusions on the EIP programme that could not be tested via a 
counterfactual analysis but that could be discussed in the interviews. 

The counterfactual analysis has quantitatively assessed the net causal impact of the COSME financial 
instruments on final beneficiaries’ performances in the short and medium term. This was the only 
methodological  approach  that  enabled  causal  conclusions  to  be  drawn  within  a  policy  evaluation 
framework.  

The assessment of impacts focused on indicators relating to firm performance, such as the number of 
employees, the cost of personnel, turnover, and total assets. During the assignment further work was 
done in cooperation with JRC with a view to trying to widen the list of indicators. However, due to 
data limitations it was not possible to use counterfactual analysis to capture impacts on areas such as 
firms’ cross-border trade, contribution to climate objectives or gender mainstreaming because of lack 
of data proxying the phenomena. These non-economic impacts were assessed by means of targeted 
consultations and interviews. 

The final beneficiary analysis (based on monitoring data from EISMEA, EIF and the Commission) 
was used by the consultant to leverage a database developed in the context of the interim evaluation 
of COSME (especially the methodology for identifying and classifying different types of stakeholders 
and sectors of activity).   

This monitoring data was combined with data from Orbis310 to assess final beneficiaries’ performance 
before and after they received the support (e.g survival rates, evolution in the number of employees, 
evolution of turnover, etc.) for the COSME LFG and EFG firms. 

•  The consultant managed to locate 60% of the beneficiary enterprises in Orbis but missing 

data was a key issue that reduced the sample size 

•  One measure taken to maximize the sample size was the use of control groups with a different 

geographical distribution to that of the beneficiaries  

Due to data limitations (an Orbis licence allowing access to the last 10 years of data), it is also not 
possible to  carry out  a  counterfactual analysis on the very first years of the COSME  programme. 
However, in practice this has no significant impact as the implementation of the financial instruments 
only took off after the first couple of years of the programme.  

Recognised methodologies were used for addressing any issues related to data or the sampling for the 
control  group,  including  a  methodology  to  maximise  the  sample  size  that  could  be  used  for  each 

310 Database by Bureau Van Dijk, https://www.bvdinfo.com/en-gb/ 

88 

 
 
 
  
 
 
question  (the  analysis  on  each  indicator  was  performed  using  different  samples  of  treated  SMEs 
(those with sufficient data available for that indicator). 

Due to the challenges of constructing a large enough sample in the limited timeframe of the survey, 
a  pool  of  not-yet  supported  companies  was  used  to  simulate  the  counterfactual  scenario  (e.g. 
companies  that  received  funding  only  from  2019  and  onwards  were  used  as  a  control  group  for 
companies  supported in  2018 to  measure the effects  in  the year the guarantee was received).  It  is 
worth highlighting that this is a substantial deviation from similar research carried out on predecessor 
programmes by the EIF (Brault and Signore, 2019) as well as in peer-reviewed research (Bertoni et 
al., 2023), in which a pool of never supported companies (but potentially benefitting from similar 
financial  instruments)  is  typically  used  to  simulate  the  counterfactual  scenario.  As  a  result,  the 
selected empirical approach is likely to under-represent the full extent of the economic impacts of the 
programme. 

The Difference-in-Differences (DiD) counterfactual method was used to establish whether there are 
any visible impacts on SME performances that can be attributed to the COSME interventions. 

A special approach was followed to take into account the fact that some businesses receive several 
rounds of financing, utilizing the approach recently developed by Callaway and Sant’Anna (2021), 
specifically suited to cases where final beneficiaries receive support at different points in time. 

The evidence from this analysis showed that the LGF had a positive and significant impact on the 
number of employees and the survival rates over time, but a non-significant effect on the turnover, 
cost  of  personnel  and  total  assets  of  beneficiaries.  For  EFG  the  analysis  could  not  demonstrate 
statistically significant and positive economic benefits, largely due to the very small final sample size. 
Nevertheless,  the  analysis  demonstrates  that  over  time,  the  EFG  final  recipients  have  not  only 
exhibited  high  survival  rates,  but  they  have  also  experienced  significant  positive  trends  in  their 
economic performance, e.g. increase in turnover and assets.    

Different specifications were carried out to test the sensitiveness of the results and the preliminary 
results of the counterfactual analysis were analysed. As a result, additional controls were performed 
for ensuring the robustness of data (for example, a check using a “log-linear specification” to track 
the relative causal effect of guaranteed loans).    

The  approach  used  for  the  counterfactual  analysis  seems  robust  enough.  However,  it  contradicts 
similar  previous  counterfactual  analyses311,  which  provided  evidence  that  the  guaranteed  loans 
provided under the MAP and CIP programmes significantly312 boosted firm growth with particularly 
visible effects for SMEs that, as predicted by theory, are the most likely to face financing constraints. 
This potential contradiction, (i.e. diverging results on economic impacts compared to the results of 
other studies, might be due to either: 

 (i)  a different methodological approach, e.g. that the counterfactual analysis for COSME compares 
SMEs benefiting from COSME with SMEs not yet benefiting from COSME but benefiting from other 
EU and/or national interventions; whereas the previous counterfactual analyses managed to identify 
as  a  control  group  indeed  SMEs  that  have  not  yet  benefited  from  COSME  or  other  similar 
interventions; or to  

311 CIP-MAP counterfactual analysis for Italy, the Benelux and Nordic countries: https://publications.europa.eu/en/publication-detail/-

/publication/7c0f4808-13c2-11e9-81b4-01aa75ed71a1/language-en/format-PDF 
MAP-CIP counterfactual analysis for France: https://www.eif.org/news_centre/publications/eif-wp-52.pdf 
MAP counterfactual analysis for Central, Eastern and South-Eastern European countries:  
https://ec.europa.eu/info/publications/economy-finance/economic-impact-eu-guarantees-credit-smes-evidence-cesee-countries_en 

312 https://www.eif.org/news_centre/publications/EIF_Working_Paper_2019_56.htm 

89 

 
 
(ii)  the  fact  that  an  average  LGF  guaranteed  loan313  would  be  much  lower  in  comparison  to  the 
schemes covered by previous studies and, in the majority of cases, would only be used for working 
capital needed for the day-to-day operations of SMEs and not for sizeable investments.  

Other limitation factors to the current COSME counterfactual analysis worth highlighting are the fact 
that the sample at geographical level is not fully representative, the data limitations and the small 
share of medium-sized enterprises in the overall sample of final recipients. Also, the companies in 
the sample, both treated and not-yet-treated, might in general exhibit different characteristics to “an 
average  company”,  e.g.  have  more  entrepreneurial  managers,  who  proactively  look  for  support. 
Therefore, the results obtained in the current COSME counterfactual analysis are to be considered 
with caution because of a series of limitations to the overall analysis as outlined above. 

Critical assessment of work carried out by the external contractor 

The work carried out by the contractors is of good quality. The conclusions of the support study are 
sound  and  based  on  a  good  understanding  of  the  complexities  and  the  wide  range  of  actions 
implemented within the COSME Programme. 

The  ISG  confirms  the  robustness  of  the  methodology,  but  highlights  that  due  to  the  alternative 
empirical approach, the outcome of the counterfactual analysis for the financial instruments cannot 
be  directly  compared  with  previous  findings  and  diverges  from  other  research  on  financial 
instruments  carried  out  on  predecessor  programmes  by  the  EIF314  as  well  as  in  peer-reviewed 
research315. As a result, this alternative empirical approach is considered likely to (at least partially) 
under-represent the full extent of the economic impacts of the programme. 

313 Generally around 40,000 euros for approximately about ten years. 
314  Brault,  J.,  and Signore,  S.  (2019).  The  real  effects  of  EU  loan guarantee  schemes  for SMEs:  A  pan-European  assessment.  EIF 
2019.  

Working 
http://www.eif.org/news_centre/publications/EIF_Working_Paper_2019_56.htm 

Analysis. 

Research 

2019/56, 

Market 

Paper 

June 

EIF 

& 

315 Bertoni, F., Colombo, M., and Quas, A. (2023). The long-term effects of loan guarantees on SME performance. Journal of Corporate 

Finance, 80, 102408. 

90 

 
 
 
B. Detailed description of the methodology 

This annex gives more information on the methodology used for the evaluation, the research plan, the challenges encountered and mitigation actions taken. 
Note  that  this  is  a  common  section  of  both  the  COSME  final  evaluation  and  the  Entrepreneurship  and  Innovation  ex-post  evaluation  as  much  of  the 
supporting work was undertaken in parallel. 

The objective of the final evaluation of COSME was to assess the implementation of this programme, against its general and specific objectives. The study 
addressed a number of evaluation questions grouped around five evaluation criteria (relevance, effectiveness, efficiency, coherence and EU added value, 
and also examined the longer-term impacts) defined in line with the EU’s Better Regulation Guidelines (BRG). The draft final reports provide the full 
list of evaluation questions.  

1.  Conceptual and Evaluation Framework for COSME 

The evaluation study set out a comprehensive conceptual and evaluation framework (also covering the ex-post evaluation of the Entrepreneurship 
and Innovation Programme (EIP). In the Inception Report and subsequently in the Progress Reports, this framework was revised and refined taking into 
account the feedback from the Commission Inter-Service Steering Group (ISG), the preliminary comments made by the Regulatory Scrutiny Board and 
results of the research.  

2.  Document Review 

The consultant’s research team reviewed: 

•  key programme documentation (including COSME work programmes, implementation reports, monitoring data and fiches) 
•  previous evaluations (including the interim evaluation of COSME),  
•  other secondary sources (listed in the bibliography or the supporting study). 

3.  COSME - Mapping and Grouping of actions 

As discussed during the Kick-off meeting, the study scope is broad and it was not possible to cover all interventions, given the wide scope. A meaningful 
prioritisation, grouping and selection of the programmes’ activities was key to providing a coherent structure to the evaluation. Consideration was also 
given to the approach used in previous evaluations.  Selection of COSME actions to cover in the evaluation was informed by the following criteria:  

•  Size of the actions and policy relevance. The study focused on COSME’s main actions including the financial instruments, the EEN and EYE, that 

91 

 
 
 
absorb the majority of COSME’s budget. 

•  Demand-driven selection. In addition to focusing on the main actions, some smaller/thematic actions were selected (e.g. supporting tourism, clusters 
and social economy) for which impacts on SME beneficiaries were expected to be high. These were deemed particularly important by stakeholders.  

•  Performance of selected actions. Finally,  a  few actions that have faced implementation  challenges and/or performance issues were also covered, 
including for instance, the Early Warning Europe (EWE) mentor academy, the EYE IT Tool and a study on the ‘Development of European Food Price 
Indicator along the value chain’.  

92 

 
 
 
The table below presents the results of this selection. 

Table 7: Mapping of main programme measures against SOs: COSME 

Specific objectives 

Thematic area 

Actions 

SO1 Improving access to finance for SMEs in the 
form of debt and equity 

Access to finance 

Equity Facility for Growth 

SO2 Improving access to markets for SMEs 

Business support networks and 
services 

Enterprise Europe Network 

EU-Japan centre for industrial cooperation 

Loan Guarantee Facility including the SME Initiative 

International intellectual property (IPR) SME helpdesks 

Your Europe Business portal 

Single digital gateway 

Public procurement 

Supporting European SMEs to participate in public procurement outside EU 

Co-financing of public procurement of innovation consortia 

Creating links for the facilitation of public procurement of innovation 

Training for SME-friendly policies in central purchasing bodies 

SO3 Improving framework conditions and 
competitiveness 

Internationalisation 

Clusters Go International 

Clusters Internationalisation programme for SMEs in the Defence & Security sector 

Competitiveness 

European Cluster Excellence Programme with ClusterXchange scheme connecting ecosystems and 
cities 

E-Skills for competitiveness and innovation 

Strategic alliances for the uptake of advanced technologies by SMEs  

Early Warning Europe Mentor Academy 

Intellectual Property voucher (also known as SME fund) 

Development of the European Food Price Indicator 

Enhancing European Tourism Competitiveness and sustainability 

Tourism 

Capital of Smart Tourism 

Innovation uptake and digitalisation in the tourism sector 

Framework conditions 

SME performance review 

Following and monitoring the Small Business Act including SME Envoys Network 

European Enterprise Awards 

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Specific objectives 

Thematic area 

Actions 

SO4 promote entrepreneurship and 
entrepreneurial culture 

Small Business Act including implementation, outreach tools including Business Planet  

Entrepreneurship 

Erasmus for Young Entrepreneurs 

EU REFIT platform 

European Network of female entrepreneurs and on-line e-platform, European Network of mentor for 
female entrepreneurs 

Support for entrepreneurship policy implementation 

EYE IT Tool 

Social Economy 

Promotion of social economy in Europe 

European Social Economy Missions  

Source: Elaboration for the supporting study. Social economy actions were moved to SO4, in line with EISMEA data 
The assessment for the COSME evaluation study draws on the review of COSME monitoring data316 including monitoring fiches for selected actions, other 
secondary sources, and targeted stakeholder surveys and interviews with selected stakeholders. Furthermore, case study research was conducted on eight 
actions from the table above (See Annex VIII).  

4.  Statistical analysis  

Overall approach The task consisted of providing an analysis of various sets of monitoring data along with external data sources. By doing so, the statistical 
analysis enabled achieving two main objectives:  

•  Depict the programme’s state of play (through the use of monitoring data) 

•  Answer several evaluation questions related to relevance, effectiveness and additionality (by combining monitoring data with external data sources).  

Data type 

Programme 

Level 

Source 

Data hub for COSME 

COSME - SO2, 3, 4 

Projects 

SME Performance Review data 

COSME - SO1, 2, 3, 4 

Aggregated 

EASME/EISMEA 

DG GROW 

316 COSME Monitoring reports 2014-2020. Also available on: https://single-market-economy.ec.europa.eu/smes/cosme/programming-monitoring-and-evaluation_en. 

94 

 
 
 
 
 
Data from Quarterly reports 

COSME - SO1 

Data from EIF 

COSME - SO1 

Aggregated 
financial 
intermediaries + final recipients 

+ 

DG GROW 

Intermediaries 
beneficiaries 

and 

final 

EIF 

Country/region statistics 

COSME - SO1 

Countries/regions 

Eurostat/  SAFE/ 
ECB/ EIBIS  

Final recipients’ balance sheet 
Portfolio analysis 

COSME - SO1 

Final recipients 

Orbis 

The  portfolio  analysis  involved  mapping  the  policy  mix  used  in  the  programme  by  reconstructing  COSME  expenditures  by  several  parameters  (e.g., 
operations and budget distribution over the different structural components of the programme). The table provides an overview of the data analysed. 

Data type 

Programme 

Level 

Source 

Data hub for COSME 

COSME - SO2, 3, 4 

Projects 

SME  Performance  Review 
data 

COSME - SO1, 2, 3, 4  Aggregated 

EASME/EISME
A 

DG GROW 

from 

Quarterly 

COSME - SO1 

Data 
reports 

Data from EIF 

COSME - SO1 

+ 
Aggregated 
intermediaries 
recipients 

financial 
final 
+ 

DG GROW 

Intermediaries  and 
beneficiaries 

final 

EIF 

Country/region statistics 

COSME - SO1 

Countries/regions 

Final  recipients’  balance 
sheet 

COSME - SO1 

Final recipients 

ECB/ 

Eurostat/ 
SAFE/ 
EIBIS  

Orbis 

95 

 
 
For the portfolio analysis, data on both planned and committed operations/budgets have been collected. The distribution of operations and budget has been 
determined across policy instruments and thematic areas (and corresponding action lines). Using data disaggregated at the country level, the analysis was 
enriched to detect geographical patterns. 

The portfolio analysis generated findings regarding: 

•  Relevance of the COSME programme, in terms of the budget allocated for the attainment of specific objectives and sub-objectives as an illustration 

of the relative importance attributed.  

•  Efficiency of implementation, in terms of the extent to which COSME allocated sufficient levels of budget to specific actions and projects within these 

actions, and the eventual distribution or fragmentation of the budget over multiple actions with similar objectives.  

The portfolio analysis has been contextualised with data on macroeconomic conditions using macroeconomic statistics (such as GDP, business demography) 
and data on the evolution of relevant indicators (mainly EIBIS and SAFE data). Multivariate analyses combining portfolio data with macroeconomic data 
have allowed to draw conclusions amongst others, on whether the amount paid is mostly concentrated in countries where the macroeconomic conditions 
are more constraining, i.e., where there is lower access to finance. 

Final beneficiaries’ analysis 

The final beneficiary analysis consisted of profiling the stakeholders involved in the financial instruments of the COSME programme. The main variables 
covered by the analysis were the geographical locations of the beneficiaries, the types of stakeholders involved in the actions funded, and their sectoral 
distribution. 

Overall, the final beneficiary analysis leveraged the database developed in the context of the Interim evaluation of COSME, especially the methodology for 
identifying  and  classifying  different  types  of  stakeholders  and  sectors  of  activity.  Additionally,  the  existing  information  was  complemented  with  an 
elaboration on data drawn from the Orbis database. By combining monitoring data with Orbis data, it was possible to assess final beneficiaries’ performance 
before and after they received support (e.g., survival rates, the evolution in the number of employees, evolution of the turnover etc.) for the COSME LGF 
and EFG firms. 

Despite the very large share of micro-enterprises benefitting from the programme, it was possible to find almost 60% of companies in Orbis. Nevertheless, 
missing values emerged as a key issue when reviewing the available Orbis data, which further reduced the sample size of the analysis. 

Another constraint that finally did not have any impact on the COSME evaluation was the fact that the contractor’s Orbis licence did not allow access to 
company data from before 2013. As the roll out of the COSME financial instruments only took off as of 2015, this access was largely sufficient for gathering 
the data needed to analyse the situation of the businesses before they had benefited from treatment. 

96 

 
 
Finally, the analysis (including the counterfactual) of the Orbis data was based on a sample which was not balanced with respect to the original sample of 
firms (in particular in terms of the location and size of firms). 

5.  Assessment of Costs and Benefits 

Regarding the assessment of costs and benefits, in so far as possible, the consultant aligned its approach with the approach adopted during the Interim 
evaluation of COSME (Technopolis, 2017). 

The analysis of the costs is not exhaustive as it only considers the costs sustained by the Commission (EU contribution to the programme and its actions) 
and costs incurred by participants. It does not include direct or indirect costs to other stakeholders not targeted or participating in the actions (e.g. industry 
representatives, sub-contractors). The analysis considers the outputs and outcomes of the programme as proxies of the benefits generated. The impacts 
achieved by the programme were also explored through the study consultation. However, stakeholders were not able to provide specific estimates to allow 
quantification. Therefore, the metrics presented in the report provide a partial picture of the benefits generated. This was complemented in qualitative terms 
by the consultation feedback on the impacts.   

In terms of costs and benefits, the consultant have thus considered the following: 

•  direct costs of the programme (i.e. EU contribution in 2014-2020). The data extraction included a portfolio analysis involving the mapping of the policy 
mix used in the programme by reconstructing COSME expenditure and by several parameters (e.g. budget distribution over the  different structural 
components of the programme). Data was obtained from the quarterly reports, information on budget committed and information on administrative 
costs when available.  

•  other costs to beneficiaries. For the Enterprise Europe Network (EEN), this includes the co-funding from member organisations; for Erasmus for Young 
Entrepreneurs  (EYE)  it  includes  additional  costs  incurred  by  hosts  and  new  entrepreneurs;  and  for  the  LGF,  indirect  costs  include  the  additional 
guarantee provided under EFSI. These come from portfolio data provided by EISMEA (for EYE and EEN) and from Q4 2022 quarterly report (for LGF 
and EFG). The figures represent the total for the 2014-2020 period. 
the benefits produced by the actions (based on the results achieved). Monitoring data from the different actions informed the assessment of the benefits. 

• 

Two cost-effectiveness indicators (CEA) are produced using the above data. The first indicator (CEA Indicator 1) reflects the benefits produced per million 
Euro invested by the programme. The second indicator (CEA Indicator 2) reflects the benefits produced over the cost of the programme and the indirect 
costs to beneficiaries.  

These metrics can be compared across actions. In particular, the analysis focuses on the following actions: EYE, EEN, LGF and EFG. The value of these 
indicators at the interim stage (assessed in the earlier evaluation) is also considered when available. This allows to understand whether there have been any 
improvements in the cost/ benefits ratio.  

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6.  Open Public Consultation and analysis of responses to the calls for evidence  

Call for Evidence 

The call for evidence opened on 17 March 2023 and closed on 14 April 2023. There was a very limited response to this initial consultation exercise as 
only three responses were received, although these included position papers. The supporting study team summarised the contributions received the 
Inception Report. The feedback received was considered in the scope of the analysis, i.e. concerning the COSME programme. 

Open Public Consultation (OPC)  

An OPC on the COSME programme was carried out between 15 June and 18 September 2023. The OPC received 24 responses in total. Furthermore, 2 
position papers submitted via EU Survey. The results of the OPC are presented in the Synopsis Report submitted together with the supporting study.   

The objective of the OPC consultation was to provide COSME’s stakeholders with an opportunity to express their views and experiences of the measures 
evaluated under COSME. It also sought to encourage them to contribute to the data-gathering channels that have been set up during the overall evaluation, 
such as the public consultation in question and other targeted consultations that have been part of the overall study. Everyone was welcome to participate 
to the consultation.  

7.  Targeted surveys of COSME stakeholders 

A series of online surveys targeted intermediaries and beneficiaries served by the COSME, as shown in the table below. (It should be noted that each 
consultation covered both COSME and the previous EIP period, thus the number of responses received includes intermediaries and beneficiaries not only 
for COSME, but also for the EIP. The questionnaires for the targeted consultations are provided in the supporting study. 

There was a slow initial response to targeted consultations (reflecting stakeholder fatigue  and the fact that the consultations were launched during the 
summer), which was mitigated by further promotion of the surveys, extensions to survey deadlines and additional interviews. After taking the mitigating 
actions,  the  targeted  consultations  provided  the  necessary  evidence  on  the  opinions  and  experiences  of  stakeholders  and  beneficiaries.  Five  of  the  six 
targeted consultations attracted a good response: EEN member organisations, entrepreneurs participating in EYE, and providers and beneficiaries of other 
COSME co-funded services. There was a modest response to the targeted consultation of SME clients served by the EEN, which reflected the challenge in 
reaching this population (i.e. relying on EEN member organisations to forward the invitation to their clients, the time elapsed since some SMEs were served 
by the EEN and those clients perhaps feeling somewhat remote from the COSME programme). The 72 interviews provided valuable qualitative evidence 
to complement the quantitative data from the analysis of the programme portfolio and the targeted consultations. 

Table 10: Results achieved by targeted consultation 

98 

 
Target group 

Financial 
intermediaries  for  the  LGF 
(COSME)  and  SME  Guarantee  (SMEG) 
Facility (EIP) 
SMEs supported by the LGF (COSME) and 
SMEG (EIP) 
EEN member organisations 
SME clients served by the EEN 
Host 
new 
entrepreneurs 
entrepreneurs  participating  in  Erasmus 
for Young Entrepreneurs 
Providers  and  beneficiaries  of  other 
COSME  co-funded  services  (including 
tourism 
social 
economy) 

clusters, 

actions, 

and 

Sampling strategy 
Sample of 102 intermediaries 

Responses received 
59 

SMEs  served  by  a  sample  of  48 
financial intermediaries 
All beneficiaries 
All beneficiaries 
All beneficiaries 

All beneficiaries 

201 

109 
67 
1,200 

110 

8.  Interviews  

A series of 72 one-on-one interviews was undertaken, as shown in the table below (compared with the initial target of 45-80). It should be noted that each 
consultation covered both the COSME and EIP periods. The questionnaires for the interviews are provided together with the supporting study.  

Table 11: Overview of the interview target groups 

1.  Representatives from EU institutions and bodies (DG GROW, DG ECFIN, EIF, EISMEA) 

3-5 

9 

Interview target 

Interviews 

Performed 

99 

 
 
 
 
  
 
2.  MS Competent Authorities and Agencies (including agencies/ministries in charge of delivering SME support) 

3.  EIP SMEG / COSME LGF Financial Intermediaries  

4.  EIP GIF / COSME EFG Funds  

5.  EIP GIF / COSME EFG Investee companies 

6.  Providers and partners of COSME/EIP co-funded services to SMEs (e.g. EEN member organisations, EYE support office, cluster managers, 
NGOs/civil society relevant to the social economy) and representatives from different categories of stakeholder organisations (e.g. Business 
Support Organisations, associations)317 

Total 

* This was the original target set before adding EIP GIF / COSME EFG stakeholders to the interview programme. 

7-10 

17-20 

7-15 

2-5 

10-15 

45-60* 

7 

21 

7 

5 

23 

72 

The original consultation strategy foresaw separate targeted consultations (surveys) for intermediaries and beneficiaries of equity support. However, the 
EIF suggested not to conduct a survey of fund managers, given that another survey was planned and the population was limited  (23). Instead, the EIF 
proposed more in-depth interviews with a sample of fund managers. Similarly, the EIF recommended replacing the survey for investee companies with 
more in-depth interviews about additionality, costs, and the impact of support received by a sample of beneficiaries. The primary reason for this change 
was to mitigate the risk of survey fatigue among beneficiaries. Consequently, the team sampled fund managers and investee companies and conducted 
interviews with them. 

9.  Counterfactual analysis 

Overall approach 

The counterfactual analysis assessed the net quantitative causal impact of the COSME financial instruments on final beneficiaries’ performances in the 
short and medium term.  It involved a comparison of the supported SMEs to a control group of “not-yet-supported” SMEs. This was the only feasible 
methodological  approach  that  enabled  causal  conclusions  to  be  drawn  within  a  policy  evaluation  framework.  The  assessment  of  impacts  focused  on 
indicators relating  to  firm  performance, such  as  the number of employees, the cost  of personnel,  turnover, and total  assets.  Given the data limitations 
explained below, the consultant carrying out the supporting study has not further enriched the list of indicators. Other type of impacts, e.g., on firms’ cross-

317 These stakeholders are at the same time beneficiaries of the programme but also partners in the provision of services to SMEs.  

100 

 
  
 
border trade, contribution of the actions to climate objectives or gender mainstreaming could not be captured by the counterfactual analysis because of lack 
of data proxying the phenomena. These impacts were assessed by means of targeted consultations and interviews. 

A necessary condition for any counterfactual analysis is access to reliable and extensive data for both the treated (beneficiary SMEs) and “not-yet-treated” 
(control groups) entities for at least the two years before and after the treatment. The contractor’s subscription to Orbis, covering the period as of 2013, was 
sufficient for gathering the company data needed for the counterfactual analysis for the early years of the COSME programme as the roll out of the financial 
instruments only became significant as of 2015. However, in the case of the EFG, a causal link could not yet be formally established for the full set of SME 
beneficiaries as most received support from 2021 and the methodology for the counterfactual analysis requires data from 2-3 years after the intervention.318  

One key challenge for the consultant was the construction of a large enough sample for the control group for the counterfactual analysis in the limited 
timeframe for the study, due to the large number of SMEs supported by the LGF (865,387). The approach for the counterfactual scenario for the LGF made 
use of the estimator proposed by Callaway and Sant’Anna (2021),319 an approach that has been widely used in peer-reviewed academic works. This involved 
using a pool of not-yet supported companies (e.g. companies that received funding only from 2019 and onwards were used as a control group for companies 
supported in 2018 to measure the effects in the year the guarantee was received). It should also be noted that the representativeness of the sample size was 
not fully satisfied at the geographical level.320  

The results of the counterfactual analysis for the LGF (good impact on the number of employees and survival rates over time, but a non-significant effect 
on the turnover, personnel costs and total assets compared to businesses that had not yet received LGF support) only partly align with existing studies on 
LGF’s predecessors (e.g., under CIP and MAP). Previous studies demonstrated that EU guaranteed loans impacted positively on SME growth in terms of 
employment, sales, and profits.321 However, due to the alternative approach followed for this counterfactual analysis, the results cannot be directly compared 
with previous research on financial instruments. One possible explanation for these different results is that the control group of businesses that had “not yet 

318 A necessary condition for a counterfactual analysis of this type is access to robust data for both the treated (beneficiary SMEs) and not-yet treated (control groups) entities for at least the two years before 
and after the treatment. In addition, it should be noted that it generally takes several months after the end of the relevant financial year for company data to be entered in Orbis. 

319 https://www.sciencedirect.com/science/article/pii/S0304407620303948 

320  Italian SMEs were well represented in the final sample, but SMEs from other key countries, such as Spain and France, are not. Moreover, the positive trends observed amongst medium-sized 
enterprises are not reflected in the overall net causal impact because, among other factors, the share of medium-sized enterprises equals only 1% of the overall sample of final recipients. 

321 See, for example: Brault, J., and Signore, S. (2019). The real effects of EU loan guarantee schemes for SMEs: A pan-European assessment. EIF Working Paper 2019/56, EIF Research & Market Analysis. 
June 2019. http://www.eif.org/news_centre/publications/EIF_Working_Paper_2019_56.htm. 

101 

 
 
benefited” from LGF support were better prepared than the businesses used as a control group for previous studies (that did not subsequently benefit from 
any funding from financial instruments at all).322  

The following paragraphs, after having presented the results of a literature review on the topic, present the approach followed by the consultant for the 
supporting study for assessing the short and medium-term impacts of COSME debt financing measures including the provision of portfolio guarantees. 
Credit  enhancement  support  is  excluded  because  the  underlying  operations  provide  capital  relief  to  financial  intermediaries,  but  usually,  no  financial 
advantages are transferred to final beneficiaries. The geographical scope of the “counterfactual analysis” extends to all countries eligible for the programme, 
despite the heterogeneity of the data coverage across countries. 

Box 5: Literature review of impact assessment studies of financial instruments (debt-based)323 

Indicators 

Turnover 
Employment 
Survival rate 
Assets 
Profitability 

Positive 
19 
23 
8 
16 
10 

Negative 
- 
1 
- 
- 
1 

Null 
5 
3 
4 
3 
8 

In contrast, the evidence related to the impact on the beneficiary’s profitability, including profit (e.g., EBIT, EBITDA), productivity, returns on assets 
(ROA) and investment (ROI) is more mixed. Among the 18 papers that examine the impact on profit, 10 papers indicate positive results, meaning that there 
is a positive and statistically significant difference in the profit between the treated SMEs and their control group. However, 8 out of 34 papers do not find 
any difference between the two groups. The absence of a positive effect on profit is explained by the literature through two possible factors. Firstly, the 
observed difference in the output of the production process (increased turnover) and inputs (increased assets, employment) offset each other leaving the 
profits almost unaltered. Secondly, profit measures from balance sheet data are less available than other output and input indicators and this strongly reduces 

322 For example, they could have been in the process of improving their business plans in preparation for seeking additional finance in future. 

323 A similar literature review has been carried out by one of the partners in the consortium carrying out the study (CSIL) within the remit of an EIB evaluation of EIBG equity-based support to SMEs and 

midcaps to review different methodologies that have been used to assess the impact of equity-type support on portfolio companies. 

102 

 
 
 
the reliability of results based on profitability. Lastly, profitability indicators come downstream in the income statements after having factored in taxation, 
which makes attribution to the policy under investigation more difficult.  

According to the literature, most of the impacts materialise in the short-medium term, particularly between 1 to 4 years: firstly, a direct impact on assets 
(after one or two years after the loan); later, indirect impacts on turnover, employment, and other economic performance indicators. However, it should be 
said that the time horizon of impacts covered by the papers depends on data availability with only 4 papers (out of 34) looking at the long-term impacts, 
namely from 5 to 10 years after the treatment.  

The literature also highlights that impacts are not homogeneous and there are important factors that shape the magnitude of publicly supported debt-based 
products on SMEs’ performance. These are:  

Age of the beneficiary SME: the effect on key performance indicators is larger for younger companies, which face higher financial constraints as compared 
to larger companies;  

Size of the beneficiary SME: the effect is larger for smaller companies, especially micro, which are more likely to lack collateral and credit history;  

Geographical location. Evidence from pan-European and multi-country studies identifies a different geographical distribution of benefits. These studies 
support the idea that the effects on both intermediated loans and loan guarantees are larger in less developed regions where more barriers to credit access 
exist as compared to developed areas (Nyikos et al., 2020). For instance, Amamou et al., (2020), and Asdrubali and Signore (2015) show that the effects 
are larger in Central, East Europe, and South Europe as compared to West and North Europe. Similarly, Barrot et al. (2020) argue that the effect is larger 
in areas characterised by high unemployment rates.  

Economic cycle. 10 out of 34 papers reviewed look for economic-cycle specific impacts and all of them corroborate the hypothesis that intermediated loans 
and guarantee schemes act as countercyclical policies. Access to finance is likely to make a difference in a period characterised by financial and economic 
turmoil having positive impacts on assets, investments and survival probability. 

Source: Elaborations for the supporting study. 

10. Create the beneficiaries’ dataset 

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The consultant relied on granular portfolio data provided by the EIF (the list of final beneficiary SMEs) and cross-sectional data series on SMEs’ economic 
performance from Orbis. Orbis is widely used in economic research as a source of firm-level data for micro-econometric analysis and has been widely used 
in existing studies on the impact of guaranteed loans on SMEs and midcaps, as well as on the impact of equity financing. 

The two sources of data (portfolio data and Orbis data) were matched using the companies’ Orbis ID, and when this was not available the matching was 
based on the company name, VAT number, and locations. The figure below shows the process followed by the consultant to construct the database on 
treated companies. This database was also used for the final beneficiary analysis (see Statistical Analysis). 

Figure 5: Database construction 

Source: Elaboration for the supporting study 

The matching process was time-consuming since it was based on Orbis batch algorithm search and manual checks needed to be performed to ensure the 
correctness of the results.324 To make the process as efficient as possible, the batch search was carried out only for companies with more than one employee 
at the time of investment. The consultant combined all data retrieved using the software STATA 17. The assessment of impacts focused on  indicators 
relating to firm performance as listed in the table below. 

Table 13: Selected variables relevant to this “counterfactual analysis” 

324 The EIF provided the Bureau van Dijk ID (BvD ID) unique firm identifier for 60% of the portfolio. This facilitated the downloading of firms’ financial data, but a consistent number of batch searches 
were needed to retrieve data on the entire portfolio. 

104 

 
 
 
 
 
 
TOPIC 

VARIABLE 

Firm’s structural feature  Country, year of incorporation, firm size 

Economic performance 

Number of employees, Personnel cost, Turnover, Profit, Revenue, 
Operating Costs, Liabilities, Total assets, Fixed assets, Profitability 
ratio, Solvency ratio 

Source: Elaboration for the supporting study 

SOURC

E 

Orbis 

Orbis 

Once data had been downloaded, the data went through a cleaning procedure to finalise the database of treated companies. Out of the companies that were 
successfully matched in Orbis, some had incomplete time series. 8.6% (42,530) of LFG beneficiaries found in Orbis and 18.1% (85) of EFG beneficiaries 
found in  Orbis  were excluded for this reason.  In addition  to  this,  the consultant  also  excluded observations with  odd or inconsistent values, firm-year 
observations in  which data from  the balance sheet  have negative values; firm-year financial statements when the basic balance-sheet  equivalences are 
violated by more than 10%. Finally, variables were deflated using the country-specific Harmonised Index of Consumer Prices (HICP) deflators.  

After having cleaned the data, we assessed the degree of data attrition (see table below). To avoid losing too many observations, the analysis on each 
indicator was performed using different samples. In other words, the sample of treated SMEs varies across the analysis depending on the data availability 
on the explanatory variable and the covariates included in the model. 

Table 14: Overview and completeness of LGF final recipients’ data in Orbis 

Country 

Number 
of 
final 
recipients 

Number of 
companies 
found in 
Orbis 

Number of 
companies 
in the final 
database 

Number 
of 
employe
es 

Cost of 
personn
el 

Turnov
er 

Total 
Asset
s 

COSME - LGF 

Albania 

Austria 

209 

3,400 

170 

137 

2,762 

1,933 

0 

0 

0 

10 

0 

1 

0 

577 

105 

 
 
  
Belgium 

Bosnia 
Herzegovina 

Bulgaria 

Croatia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

Ireland 

Italy 

Kosovo 

Latvia 

Lithuania 

Luxembourg 

Montenegro 

4,879 

448 

3,501 

2,950 

410 

409 

426 

266 

456 

92 

48 

174 

752 

276 

and 

11,531 

11,439 

11,330 

6,474 

4,878 

6,373 

6,476 

1,048 

392 

386 

Czech Republic 

14,756 

13,864 

13,598 

681 

1,596 

4,053 

622 

1,258 

3,576 

425 

1,258 

3,574 

236,425 

170,122 

165,246 

31,929 

21,448 

5,999 

3,998 

3,735 

3,965 

172 

442 

0 

730 

439 

530 

15 

132 

205 

205 

1,603 

1,940 

3,536 

0 

0 

0 

652 

894 

920 

1,151 

1,426 

1,618 

4,114 

4,792 

9,922 

14 

2 

358 

1,686 

1 

1,670 

1,690 

13,956 

13,098 

13,074 

6,009 

6,570 

7,874 

8,605 

62 

3,828 

19 

297 

19 

279 

2 

64 

1 

16 

0 

0 

183,861 

125,080 

122,438 

43,575 

40,335 

51,584 

2,057 

1,021 

990 

199 

1,081 

1,596 

837 

699 

170 

767 

76 

771 

697 

163 

752 

6 

563 

434 

0 

513 

0 

20 

0 

1 

0 

502 

336 

0 

71 

451 

513 

106 

5 

167 

51,71
0 

0 

25 

214 

29 

 
Netherlands 

6,145 

5,321 

Poland 

Portugal 

Romania 

Serbia 

Slovakia 

Slovenia 

Spain 

Sweden 

Türkiye 

United Kingdom 

TOTAL 

65,112 

29,843 

6,982 

6,408 

1,055 

8,752 

6,406 

24 

48 

2 

0 

142 

887 

1,345 

1,410 

3,495 

3,206 

3,647 

3,727 

13,120 

11,917 

11,917 

6,301 

5,098 

6,295 

6,291 

18,029 

16,393 

16,380 

4,826 

4,632 

4,670 

4,831 

4,320 

2,298 

4,273 

2,199 

4,262 

2,194 

39 

1,034 

1,862 

2,025 

1,491 

1,456 

1,510 

1,726 

173,057 

52,126 

51,089 

14,504 

15,074 

17,949 

18,51
1 

26 

31,947 

3,235 

22 

4,324 

2,265 

22 

1,894 

2,051 

6 

1 

31 

5 

1 

20 

11 

13 

143 

130 

39 

1,070 

863,729 

495,767 

453,237 

93,112 

91,532 

115,74
3 

127,4
74 

Table 15: Overview and completeness of EFG final recipients’ data in Orbis 

Country 

Number of 
final 
recipients 

Number of 
companies 
found in 
Orbis 

Number of 
companies 
in the final 
database 

Number of 
employees 

Cost of 
personnel 

Turnover 

Total 
Asset
s 

COSME – EFG 

Austria 

2 

2 

2 

0 

0 

0 

0 

107 

 
 
 
Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech 
Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hong Kong 

Hungary 

Ireland 

Israel 

Italy 

Latvia 

Luxembourg 

Mexico 

5 

6 

2 

1 

7 

13 

2 

13 

79 

5 

6 

2 

0 

7 

12 

2 

12 

47 

134 

133 

7 

1 

4 

12 

6 

1 

1 

4 

1 

6 

1 

4 

12 

6 

1 

1 

4 

1 

5 

6 

2 

0 

7 

12 

2 

12 

46 

92 

6 

1 

4 

10 

0 

1 

1 

2 

1 

Netherlands 

36 

36 

31 

0 

3 

2 

0 

3 

0 

0 

7 

4 

2 

4 

0 

4 

0 

0 

1 

0 

0 

0 

0 

3 

3 

2 

0 

3 

0 

0 

7 

4 

14 

4 

0 

4 

1 

0 

1 

0 

0 

0 

3 

3 

3 

2 

0 

2 

0 

0 

6 

3 

3 

2 

0 

4 

3 

0 

1 

0 

0 

0 

1 

3 

3 

2 

0 

3 

0 

0 

6 

2 

1 

0 

0 

4 

0 

0 

1 

0 

0 

0 

0 

108 

 
Norway 

Portugal 

Romania 

Serbia 

Slovakia 

Slovenia 

Spain 

Sweden 

Switzerland 

Türkiye 

United 
Kingdom 

United States 

Total 

2 

2 

4 

1 

4 

4 

18 

22 

9 

1 

74 

2 

2 

4 

1 

4 

4 

17 

21 

9 

1 

69 

2 

1 

4 

1 

4 

4 

12 

21 

5 

0 

58 

45 

523 

36 

470 

29 

384 

0 

1 

1 

1 

0 

4 

4 

5 

0 

0 

3 

0 

0 

1 

1 

1 

1 

4 

4 

5 

0 

0 

1 

1 

0 

1 

1 

1 

1 

4 

4 

5 

0 

0 

2 

1 

0 

1 

1 

1 

1 

4 

4 

5 

0 

0 

8 

3 

52 

44 

50 

77 

109 

 
 
 
 
 
 
Table 16: Overview and completeness of LGF final recipients’ data in Orbis 

Year 
investment 

of 

N. 
recipients 

Final 

companies 

N. 
found in Orbis 

N.  companies 
in 
final 
the 
database 

N. employees 

Cost 
personnel 

of 

Turnover 

Total 
Assets 

COSME – LGF 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

Total 

466 

50,119 

97,907 

129,509 

138,082 

134,916 

160,453 

99,988 

52,254 

35 

100 

26,526 

59,104 

76,693 

90,590 

84,655 

99,073 

40,010 

18,992 

24 

92 

25,174 

55,395 

72,744 

84,168 

73,905 

91,200 

35,205 

15,339 

15 

0 

2,853 

8,610 

16,044 

20,539 

12,494 

25,322 

7,250 

0 

0 

0 

3,145 

9,064 

15,649 

19,520 

12,287 

25,104 

6,763 

0 

0 

0 

0 

3,977 

5,446 

11,534 

13,258 

20,077 

22,053 

25,051 

26,634 

16,022 

17,550 

30,983 

32,609 

8,099 

9,924 

0 

0 

0 

0 

863,729 

495,767 

453,237 

93,112 

91,532 

115,743 

127,474 

Table 17: Overview and completeness of EFG final recipients’ data in Orbis 

Year 
investment 

of 

N. 
recipients 

Final 

companies 

N. 
found in Orbis 

N.  companies 
in 
final 
the 
database 

N. employees 

Cost 
personnel 

of 

Turnover 

Total 
Assets 

COSME - EFG 

2014 

2 

2 

1 

0 

0 

0 

0 

110 

 
 
 
2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

Total 

6 

11 

18 

25 

61 

97 

195 

108 

523 

6 

9 

17 

25 

56 

91 

169 

95 

470 

5 

9 

17 

24 

52 

70 

137 

69 

384 

0 

3 

5 

9 

6 

2 

11 

16 

52 

0 

1 

4 

6 

3 

4 

10 

16 

44 

1 

2 

4 

7 

6 

4 

11 

15 

50 

1 

3 

7 

11 

8 

7 

20 

20 

77 

Finally, the consultant performed some data processing along a number of important dimensions that are needed as control variables. This included using 
data on location, company’s age, sector of activity, independence indicator.  

11. Control group design  

Constructing the sample of potential controls is another crucial step for any counterfactual analysis. The main challenge of the evaluation of the impacts is 
that  the  control  group  cannot  be  observed  by  construction,  and  the  consultant  needed  to  select  a  pool  of  not-supported  companies  to  simulate  the 
counterfactual scenario. Control companies should not have received the COSME support and should perform as the supported SMEs and midcaps. Ideally, 
not-supported companies should not have received any type of support. Since constructing an ad-hoc group of never treated companies would have not 
been feasible because of time constraints, the consultant has used not-yet-treated companies as a control group. This implies that companies who received 
the treatment in 2019 have been used as control group for companies that have received the support in 2018. This approach excluded those receiving support 
in 2021 from the analysis since they were the last group receiving support. 

12. Econometric analysis 

This analysis establishes if there are any visible impacts on SMEs’ performance that can be attributed to COSME interventions. The consultant deployed a 
Difference-in-Differences (DiD) as the counterfactual method, whereby the net impact of the COSME’s guaranteed loans is measured by the difference in 
means between the observed outcomes (employment, turnover, total assets) in the treated and not-yet-treated group, and before and after the treatment 
period. The DiD estimator produces very accurate and, often, conservative estimates of the net effect of policy interventions. It allows control for other 
sources of selection bias, including unobservable characteristics specific to the individual firms, which remain stable over the time period covered by the 
analysis and influence the observed outcomes (e.g., the quality of the management). 

111 

 
To account for the fact that the treatment is delivered over multiple time periods (i.e., staggered treatment adoption), the consultant followed the approach 
recently developed by Callaway and Sant’Anna (2021). Traditionally, Two-Way Fixed Effect (TWFE) estimators and their dynamic variation would have 
been  applied.  However,  both  approaches  do  not  necessarily  provide  unbiased  estimates.  Authors  (Borusyak  and  Jaravel,  2017;  de  Chaisemartin  and 
D’Haultfœuille, 2020; Goodman-Bacon, 2021; Sun and Abraham, 2020) have demonstrated that the TWFE estimator might not be interpreted as a causal 
parameter  nor  as  reliable  measures  of  dynamic  treatment  effects,  especially  if  there  is  heterogeneity  of  the  impact  across  cohorts.  Indeed,  in  TWFE 
specifications, OLS only considers variations in the treatment dummy variable and does not consider the fact that the treated were not  exposed to the 
treatment at the same time but that, within the treated group, there are separate cohorts. 

The estimator of Callaway and Sant’Anna (2021) overcomes this issue and explicitly  accounts for the fact  that among  treated units, there are  cohorts 
exposed to the treatment at different points in time. Another key advantage of this estimator is that it compares in each year companies that have been 
supported with those that have not yet been supported (i.e., not yet treated) without the need for pure controls (i.e., never treated). Additional details on the 
underlying theoretical framework are described in the box below. 

112 

 
 
 
 
Box 6: The identification strategy in a nutshell 

Let 𝑌𝑖𝑡 be the observed outcome variable of company 𝑖 in period 𝑡 ;  

𝐷𝑖𝑡   ∈ {0,1} be the staggered treatment adoption variable, with 𝐷𝑖𝑡 = 1 if the company 𝑖 has received the treatment in 
period  𝑡 or before and  0 otherwise (this is the irreversibility of treatment assumption:  𝐷𝑖𝑡 = 1 implies that 𝐷𝑖(𝑡+1) =
1 𝑓𝑜𝑟 𝑡 = 1,2, … , 𝑇). 

𝐺 be the time period when a company first becomes treated; this variable defines the cohorts among treated units; 

𝐺𝑖𝑔 ∈ {0,1} be the treatment starting dummy (or cohort dummy), with 𝐺𝑖𝑔 = 1 if company 𝑖 is first treated at time 𝑔 and 
0 otherwise; 

 𝑝𝑔𝑠(𝑋)  be  the  generalised  propensity  score  (𝑝𝑔𝑠(𝑋) = 𝑃(𝐺𝑔 = 1|𝑋, 𝐺𝑔 + (1 − 𝐷𝑠)(1 − 𝐺𝑔) = 1))  indicating  the 
probability of being first treated at time 𝑔, conditional on pre-treatment covariates 𝑋 and on either being in the group 𝑔 
such that 𝐺𝑔 = 1 or a in the not-yet-treated group at time 𝑠 such that (1 − 𝐷𝑠)(1 − 𝐺𝑔) = 1. 

The consultant estimated the average treatment effect for the group of companies first treated at time 𝑔 in the calendar 
time 𝑡 as follows: 

𝐴𝑇𝑇(𝑔, 𝑡) = 𝔼(𝑌𝑡(𝑔)− 𝑌𝑡(0)| 𝐺𝑔 = 1), 𝑓𝑜𝑟 𝑡  ≥ 𝑔 

Then, the consultant estimated the overall average treatment effect by means of weighted averages of the 𝐴𝑇𝑇(𝑔, 𝑡). 
𝑇
Specifically, ∑
. Two weighting schemes were exploited, and results were compared to 
𝑔=2
investigate the differences: i) simple weighted average of all 𝐴𝑇𝑇(𝑔, 𝑡); ii) average effect of participating in the treatment 
for the group of companies that have been exposed to the treatment for exactly 𝑘 time periods. 

𝟏{𝑔 ≤ 𝑡}𝑤𝑔𝑡𝐴𝑇𝑇(𝑔, 𝑡)

𝑇
∑
𝑡=2

As in the traditional DiD framework, also in this framework, parallel trends assumption on both never treated groups and 
not-yet-treated groups must hold.  

Elaboration by the consultant for the supporting study 

The estimation phase assessed the impact of COSME on supported SMEs and midcaps. As previously mentioned, the consultant for the supporting study 
employed the DiD approach with multiple time periods, recently developed by Callaway and Sant’Anna (2021) to obtain the DiD estimator (i.e., the ATT) 
using the STATA command “csdid”. Thus, the consultant measured the net casual impact of COSME support on each outcome variable for each cohort 
(by year of first investment) as well as the aggregated impact. To ensure the robustness of the results, the consultant conducted different specifications to 
test how sensitive the results were to certain specifications. Finally, robustness checks by the consultant confirmed the obtained. The consultant tested the 

113 

 
 
parallel trends assumption underlying the DID estimation of the ATTs. This assumption requires that both treated and not-yet-treated firms share the same 
trend in the outcome variables in the pre-treatment period in the absence of the treatment. 

13. Results 

The table below shows the aggregated results obtained for final recipients of the LGF and EFG, separately. As shown in the table and elaborated upon in 
the main report, the evidence suggests an average null effect  of both  financial instruments  on the economic performance of supported companies.  An 
exception is the positive and significant impact of LGF on the number of employees. However, these findings may be biased by the fact that the sample of 
analysis is not fully representative of the entire population, particularly in terms of geographical distribution. As shown in the tables above, for the LGF 
instrument, a significant portion of French and Spanish companies was not included in the analysis due to data availability issues. Moreover, the findings 
are likely to be influenced by the relatively small average ticket size of LGF support, which was primarily used by SMEs for working capital purposes 
rather than for expansion. Conversely, the results obtained for the EFG may be biased due to the small sample size and the restriction of the sample to 
companies that had full time series, as EFG mostly targeted very young companies. Moreover, most EFG recipients received equity financing starting from 
2021, which was too early to determine if any impact materialises. 

Table 18: Aggregated results of the counterfactual analysis for final recipients of the LGF and EFG 

N° of employees 

Cost of personnel 

Turnover 

Total assets 

ATT_LGF 

1.170** 

(0.451) 

N. observation 

93,112 

ATT_EFG 

17.10 

(27.02) 

N. observation 

52 

0.875 

(1.970) 

91,532 

1093.6 

(1007.4) 

44 

0.0304 

(0.161) 

115,743 

0.359 

(0.626) 

50 

-465,223.9 

(1946415.3) 

127,474 

23.96 

(16.24) 

77 

Standard errors in parentheses: * p<0.05, ** p<0.01, *** p<0.001 

114 

 
 
 
 
 
  
  
To check the robustness of the results, the consultant carried out the pre-trends analysis using the “csdid” STATA command. Results are provided in the 
table below. It should be noted that the null hypothesis (H0) states that all pre-treatment are equal to 0. Although for turnover, the overall Chi2 statistics 
did not allow the consultant to conclude that the pre-trends assumption holds, it is noted that the event study shows that the coefficients associated with 
ATT in each pre-treatment period are never statistically significant. 

Table 19: Results of the pre-trends analysis available in the csdid STATA command 

N° of employees 

Cost of personnel 

Turnover 

Total assets 

Chi2_LGF 

p-value 

20.3738 

0.1581 

N. observation 

93,112 

Chi2_ EFG 

p-value 

7.7815 

0.9322 

N. observation 

52 

18.0649 

0.2593 

91,532 

12.0797 

0.5999 

44 

38.0428** 

0.0009 

115,743 

22.0106* 

0.0374 

50 

17.4266 

0.2940 

127,474 

12.7226 

0.6237 

77 

Standard errors in parentheses: * p<0.05, ** p<0.01, *** p<0.001 

The Commission requested additional tests/checks (notably a check using the “log linear specification”) to track the relative causal effect of the loans, and 
a breakdown of businesses that had benefited, and businesses that had not yet benefited. The results were consistent with those obtained with the main 
specification: an average null effect was estimated for both financial instruments on the economic performance of supported companies. 

14. Case studies  

A series of case studies was produced by the consultant that carried out the supporting study to explore some of the key evaluation issues in greater depth. 
The case studies included flagship actions, good practice examples, and examples of activities that had not performed as well as expected. 

The case studies provide a qualitative assessment to complement the quantitative work under the counterfactual (econometric) analysis to assess the longer-
term impacts of interventions supported by COSME.  

115 

 
 
  
  
  
  
  
More specifically, the case studies include examples of flagship actions and their achievements, examples of good practice/success stories to investigate 
the factors that have led to the effective implementation of the activities as well as examples of initiatives that have not performed as effectively in order 
to identify and review barriers and disabling factors that have prevented the achievement of results. The analysis of these examples allows the identification 
of lessons learnt and of the elements and contextual factors to take into account, in order to maximise the effectiveness of future initiatives for SME growth 
and competitiveness. The case studies are presented in Annex VIII of this report. 

15. Main challenges and mitigation actions 

Table 20: Main challenges encountered in the implementation of this evaluation and  mitigation actions taken. 

Challenges 
Scope of the study  

Lack of common 
reporting 
arrangements/ 
 level of detail in 
monitoring data 

Lack of quantitative 
data on benefits for 
the assessment of the 
efficiency criterion 

Description of the challenge and mitigation actions taken  
The scope of the study was broad, as COSME supported a wide range 
of  interventions  that  pursued  different  objectives  and  targeted 
different beneficiaries.  The consultant for the supporting study found 
it  challenging  to  strike  the  right  balance  between  different  actions 
supported by the programme (between larger and smaller actions for 
instance).  To  address  this  issue,  the  consultant  took  a  balanced 
approach in its research efforts for COSME, making the best use of 
available  evidence  from  monitoring  data,  past  evaluations,  and 
studies 

The availability of monitoring data and information on actions varies 
significantly based on their type and value. Additionally, there was no 
unified monitoring and reporting system for all actions, and a clear 
set  of 
indicators  for  assessing  the  programme  performance, 
especially for smaller actions, is missing. Targeted consultations and 
interviews with selected stakeholders were used to gather relevant 
information and data on some of these smaller actions.  
Limited  quantitative  data  was  found  in  relation  to  efficiency.  The 
consultant’s team followed a similar approach to that of the earlier 
evaluation  by  assessing  the  costs,  both  direct  costs  to  the 
Commission,  and  other  costs  incurred  by  beneficiaries  in  order  to 

116 

 
 
develop  some  efficiency  metrics,  relative  to  the  number  of 
beneficiaries.  Other  costs  include  the  costs  by  other  organisations, 
non-EU and including beneficiaries. These include co-funding costs or 
additional guarantees, for instance under EFSI. These were calculated 
from the total costs of the action subtracting the EU contribution.  
The  consultant’s  research  team  conducted  an  extensive  data 
collection exercise involving different stakeholders (e.g., EISMEA, EIF, 
intermediary organisations, business umbrella organisations etc.) to 
gather  relevant  monitoring  information  as  well  as  data  on  the 
programmes, the projects and final recipients supported through the 
different  specific measures.  This  complex  governance  structure  has 
posed some challenges to the data gathering process. The monitoring 
data are indeed managed by different entities at different levels of 
granularity. As an illustrative example, for financial instruments data 
was collected at the level of the final recipients, i.e., SMEs, while for 
other measures/thematic actions, the most granular unit of analysis 
were  the  intermediate  bodies  (rather  than  final  beneficiaries). 
Therefore,  one  key  challenge  has  been  that  the  information  was 
fragmented and so ad-hoc requests for clarification and meetings had 
to  be  scheduled.  To  accommodate  the  data  availability,  multiple 
datasets have been built depending on the unit of analysis available 
and  the  type  of  measure.  The  size  of  each  dataset  widely  differs, 
ranging from 5,788 rows for grants to more than 1 million for the LGF. 
Furthermore,  the  team  has  ensured  a  smooth  cooperation  and 
exchange of information with the Commission, EISMEA and the EIF to 
discuss data availability and needs. 
The  testing  and  finalisation  phase  of  the  six  survey  questionnaires 
with the  Commission,  EISMEA  and  the  EIF took slightly  longer  than 
expected  (more  than  one  month).  This  was  due  to  the  fact  that 
different Commission, EISMEA and EIF services were involved in the 

117 

Monitoring and 
programme data 
gathering 
process/governance 
structure 

Slight delay in the 
launch of the 
targeted 
consultations 
& 

 
Contractor 
responsible for the 
dissemination of the 
surveys 

Limited response to 
interview requests 
and surveys 

review of the questionnaires. However, the Commission believes that 
this resulted in better quality surveys.  

As regards the dissemination, according to the original consultation 
plan, the EIF and EISMEA were expected to play a significant role in 
the dissemination of the surveys to targeted stakeholders in order to 
ensure higher participation. However, the EIF could not play this role 
due  to  the  potential  burden  imposed  on  the  front  office.  The 
contractor  agreed  with the  EIF  on a  solution:  the  contractor would 
disseminate the survey links to the selected financial intermediaries 
using the contact details shared by the EIF and keep the EIF’s front 
office  copied  into  the  communications  to  encourage  a  better 
response.  Unfortunately,  the  surveys  of  financial  recipients  and 
beneficiaries did not receive a significant response during the first two 
weeks  of  the  consultation.  To  mitigate  this 
issue  and  boost 
participation, the research team translated the survey questionnaire 
for final recipients into different EU languages. The EIF also supported 
the contractor in sending follow-up messages to the intermediaries. 
Overall,  the  consultations  provided  the  necessary  evidence  (e.g. 
needs  addressed,  activities  undertaken,  and  the  characteristics, 
opinions  and  experiences  of  stakeholders  and  beneficiaries).  A 
number  of  mitigating  actions  were  taken  to  ensure  a  sufficient 
response  rate.  Two  main  challenges  were  faced:  a  general 
'consultation  fatigue'  among  the  targeted  stakeholders  given  that 
other  consultations  were  launched  just  before  or  in  parallel  to  the 
evaluation; and the fact that some of the consultations overlapped 
with the summer period. The successful mitigating actions included 
working closely with the Commission, the EIF, and EISMEA to identify 
stakeholders willing to participate in interviews and leverage effective 
channels  for  survey  dissemination  and  extended  the  deadlines  for 
completing surveys. 

118 

 
Risk that emerged 
during the project: 
The limited duration 
of the contractor’s 
Orbis licence could 
hamper counter-
factual analysis for 
interventions at the 
start of the 
programme. 
Challenge arising 
during the 
assignment: 
constructing a large 
enough sample for 
the LGF control group 
in time due to the 
large number of 
SMEs supported 
(865,387) 

The contractor’s Orbis licence, only covered access to company data 
from 2013 onwards. In practice, there was no need to go back earlier 
than 2013 for analysing the control group’s performance, as the LGF 
only started delivering finance to SMEs in 2015, and the EFG at the 
end of 2015. 

for 

and 

Callaway 

Sant’Anna 

The  consultant  proposed  an  alternative  approach 
the 
counterfactual scenario for the LGF, making use of the “the estimator 
(2021)325https://euc-word-
of 
edit.officeapps.live.com/we/wordeditorframe.aspx?ui=en-US&rs=en-
IE&wopisrc=https://eceuropaeu.sharepoint.com/teams/GRP-
COSMEEIPEvaluationISG/_vti_bin/wopi.ashx/files/c38dc58cfa23404dbea6fb5511
376c0e&wdenableroaming=1&mscc=1&hid=605E30A1-80AF-9000-0A43-
6ACFD16FEAD8.0&uih=sharepointcom&wdlcid=en-
US&jsapi=1&jsapiver=v2&corrid=fb9a7735-2994-2e01-33ad-
aac5ec956ccb&usid=fb9a7735-2994-2e01-33ad-
aac5ec956ccb&newsession=1&sftc=1&uihit=docaspx&muv=1&cac=1&sams=1&
mtf=1&sfp=1&sdp=1&hch=1&hwfh=1&dchat=1&sc={"pmo":"https://eceuropaeu.
sharepoint.com","pmshare":true}&ctp=LeastProtected&rct=Normal&wdorigin=Ite
msView&wdhostclicktime=1717780951688&instantedit=1&wopicomplete=1&wd
redirectionreason=Unified_SingleFlush ”, a recent approach that, has been 
already widely used in peer-reviewed academic works. This involved 
using a pool of not-yet supported companies. This is further explained 
in  the  points  on  the  counterfactual  analysis  and  the  methodology 
section of the main report. The Commission requested further data 
and tests which the consultant provided.  

325 https://www.sciencedirect.com/science/article/pii/S0304407620303948 

119 

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

Final COSME Evaluation questions  
EFFECTIVENESS 
General Questions  

Information source(s) 

effective  was 
EQ1.1  How 
COSME  in  achieving  its  general 
and  specific  objectives,  in  terms 
of outputs, results and long-term 
impact of its measures? 

EQ  1.1.1  What  have  been  the 
results  and 
outputs,  outcomes, 
impacts of COSME actions (for the 
4  specific  objectives), 
in  both 
quantitative  and  qualitative  terms? 
To  what  extent  have  these  actions 
to  the  general  and 
contributed 
specific objectives of COSME? 

EQ  1.1.2  Who  were  the  main 
beneficiaries  of  COSME? 
In 
particular, what types of enterprise 
benefitted?  Were  any  measures 
more  effective  for  certain  types of 
SMEs than others? 

Desk research  
•  Portfolio analysis 
•  Flash  Eurobarometers, 

trade 
statistics, annual burden survey, 
etc.)289 
-  Review  COSME  monitoring 
system 
(Annual  monitoring 
reports)  

• 

Interviews 
consultations 

and 

Targeted 

Desk research  
• 
•  Flash  Eurobarometers, 

 Portfolio analysis 

trade 
statistics, annual burden survey, 
etc.) 
-  Review  COSME  monitoring 
system 
(Annual  monitoring 
reports)  

• 

Targeted consultations 

Desk research 

Portfolio analysis 

• 
•  Review 

of  COSME 
system 
monitoring 

monitoring 
(Annual 
reports) 

Draft  final  report 
sections 
4.2, 4.2.1 

Indicators/specific evidence 

 Assessment  of  achievements  of  the  programme  by  COSME 
specific objective  

(Note:  Part  2  of 
this  document  provides  more  detailed 
‘effectiveness’ KPIs by programme specific objective. These can be 
considered  as  measures  of  ‘success’.  KPIs  presented  in  Part  2 
which  are  also  reported  in  this  table  by  relevant  evaluation 
question are marked with a ‘*’ and colour coded:  red for output 
indicators,  blue  for  result  indicators  and  black  for  impact 
indicators)  

Beneficiary  coverage  by  type  (size,  sector,  turnover,  assets)  and 
country (SO1) 
Beneficiary coverage by Member State (Other SO) 

3, 4.2, 4.2.1, 4.3.1. 

 . 

120 

 
 
 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
Interviews 
consultations 

and 

Targeted 

EQ  1.1.3  To  what  extent  did  the 
effectiveness  of  the  Programme 
vary  across  different  Member 
States  and  participating 
third 
countries? 

to 

EQ  1.1.4  Are  the  results  achieved 
thus far in line with the objectives 
and milestones foreseen in the prior 
Impact  Assessment  or 
the 
baseline  for  KPIs  indicated  in  the 
Regulation?  Where  expectations 
have  not  been  met,  what  factors 
have hindered their achievement? 
EQ1.2  How  was  COSME 
implemented 
the 
Programme period? 
EQ1.2.1  How  was 
the  budget 
allocated per specific objective and 
type  of  action  (as  defined  by  the 
COSME Regulation)?  

over 

has 

the 
How 
EQ1.2.2. 
effectiveness  of  the  programme 
evolved  over 
its 
implementation?  

the  years  of 

EQ1.2.3  Which  factors  drove  or 
hindered  progress  and  why,  and 
how  did  these  factors  vary  across 
the  different 
the 
Programme? 

actions 

in 

Desk research 
• 
•  Review 

Portfolio analysis 

of 

monitoring  system 
monitoring reports) 

Beneficiary coverage by Member State/COSME country (e.g. for 
financial  support:  Number  of  SMEs  getting  finance,  volume  of 
finance,  agreements  signed  with  intermediaries,  international 
collaborations) 

3, 4.2.1 

COSME 
(Annual 

Interviews 
consultations 

As above 

and 

Targeted 

Contribution of actions to COSME objectives by MS/participating 
country based on feedback from consultations 

Assessment of achievements and estimations/baseline KPIs290  

4.2,  4.2.1,  4.2.1.3, 
4.2.1.4, 4.3 

Changes  in  SME  growth,  GVA,  competitiveness,  sustainability 
based on feedback from consultations 

Factors cited in consultations - by thematic group of actions 

Desk research  

Implementation milestones 

2.2, 3.3, 3.4, 4.2.1 

•  Portfolio analysis 
•  Review  COSME  monitoring 
(Annual  monitoring 

system 
reports) 

Budget  allocation  in  terms  of  amounts,  annual  number  of 
operations,  geographical  allocation,  type  of  financial  instrument 
(SO1) 

3, 3.1.2, 4.2, 4.2.1.1 

Interviews 
consultations 

and 

Targeted 

Budget allocation in terms of amounts, specific objectives, group of 
actions (other SOs) 

Desk research  
•  Portfolio analysis 
•  Review  COSME  monitoring 
(Annual  monitoring 

system 
reports) 
Interviews  
Desk research  
Interviews,  

Evolution of financial and accounting ratios of the programme over 
the years by type of financial instrument and sectors (SO1) 

4.1.1.2, 

3, 
4.2.1.1,  4.2.1.2 

4.2, 

Changes  in  the  nature  of  actions/flexibility  of  the  programme  to 
adapt  and  respond  to  new  needs  (digitalisation,  new  markets, 
response to external factors) 
Factors cited in consultations - by thematic group of actions 

4.2.1 

121 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EQ1.2.4.  How  effectively  has 
information  about  the  availability 
of the programme instruments and 
the  results  and  impacts  of  actions 
been 
to  potential 
stakeholders and beneficiaries? 

transmitted 

Desk research 

Interim evaluation 

•  Review  COSME  monitoring 
(Annual  monitoring 

system 
reports) 

Promotion efforts by action/group of actions 

4.2.2 

Recognition of the EEN Network amongst SME population  

Evidence of beneficiaries’ awareness cited in consultations 

EQ1.3. To what extent and how 
has the Programme contributed to 
broaden EU policy priorities and 
objectives? 

Targeted consultations 
Desk research  
• 

• 

Flash  Eurobarometer  surveys 
on SMEs, Resource Efficiency 
and Green Markets? 
Eco-Management  and  Audit 
Scheme (EMAS) (europa.eu) 
Interim evaluation 

• 
•  Review  COSME  monitoring 
(Annual  monitoring 

system 
reports) 

EQ1.3.1 How far has the 
Programme contributed to the 5 
Union priorities for smart, 
sustainable and inclusive growth 
in the period up to 2019 (including 
climate objectives and gender 
mainstreaming) and to the current 
Commission’s keynote objective 
“An economy that works for 
people”? 
EQ1.3.2 Has the programme/its 
measures achieved any 
unintended effects? 
Specific questions on Action: (SO 1) LFG & EFG  

Interviews 
consultations 

Counterfactual 
analysis 
Interviews,  
Targeted consultations 

and 

Targeted 

(econometric) 

- To what extent have the financial 
instruments contributed to 
improving access to finance for 
SMEs? How is any improvement in 
access to finance for SMEs 
measurable and/or objectively 
verifiable? What are other key 
achievements and impacts? 

Desk 
Monitoring reports 

research 

and  Annual 

Interviews,  
Targeted consultations 

Contributions to EU policy priorities cited in consultations 

4.2.2 

Feedback  from  participants  regarding  an  improved  regulatory 
framework 

Other impact indicators in Part 2 

Contributions to climate & gender mainstreaming priorities cited in 
consultations Performance of SMEs as regards sustainability 

4.2.2 

Assessment of unintended (positive/negative) impacts 

4.2.2 

4.2, 
4.2.1.1.2, 5.2.1.1.3 

4.2.1.1.1, 

*Funding  distributed  by  EFG  /Total  EC  commitments  to  debt 
finance 
*Number  of  VC  funds  supported  /Number  of  intermediaries 
supported  
*Sectoral distribution of EFG and LGF 
*Total funding catalysed by instrument 
*Total value of lending provided on the basis of LGF 
*Gearing effect of the instrument) 
*% of SMEs reporting difficulty in accessing finance  

*Leverage Ratio 

*Number of jobs maintained or created in the SMEs or sector  

*% of SMEs reporting a positive impact as a result of the funding 
received (growth, added-value and employees) 

122 

 
 
 
 
 
 
 
 
  
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
- To what extent did the instruments 
reach the target groups or groups of 
beneficiaries 
envisaged?  What 
could be done to improve targeting?  
-  What  are  the  barriers,  if  any, 
impeding access by beneficiaries to 
the  instruments?  What  could  be 
done to make access easier? 
- To what extent has the principle of 
additionality  been  ensured?  What 
was done/could be done to improve 
additionality?  
- To what extent have the visibility 
and  promotion  of  the  instruments 
been ensured and to what extent has 
the  support  provided  from 
the 
instruments been recognised in the 
final 
market 
recipients)? 
-  To  what  extent  has  EFSI 
increasing 
to 
contributed 
effectiveness 
LGF 
of 
instrument?  

(including 

the 

by 

As above 

*Feedback  regarding  changes  in  lending/  investment  patterns  of 
financial instruments as a result of COSME 
*Change  of  venture  capital  availability  indicator  (EU  average) 
2014-2020 
*Change of access to loans indicator (EU average) 2014-2020 
*  Funding  take-up  by  country  where  access  to  finance  is  more 
constrained (signature amounts, number of SMEs supported) 
*Number and type of SMEs receiving guaranteed loans  

As above 

*% of SMEs reporting difficulties in accessing finance  

4.2, 
4.2.1.1.2, 5.2.1.1.3 

4.2.1.1.1, 

4.2, 
4.2.1.1.2, 5.2.1.1.3 

4.2.1.1.1, 

As above 

As above 

As above 

 *%  of  SMEs  reporting  full  (no  alternatives  available)  or  partial 
additionality  (alternatives  available  but  at 
less  favourable 
conditions or smaller scale) 

4.2, 
4.2.1.1.2, 5.2.1.1.3 

4.2.1.1.1, 

*% of intermediaries and final beneficiaries recognising the origin 
of the support 

4.2, 
4.2.1.1.2, 5.2.1.1.3 

4.2.1.1.1, 

EFSI  impacts  on  LFG  :  additional  signatures  made  possible  by 
EFSI top-ups, additional SMEs reached and investment mobilised 

4.2, 
4.2.1.1.2, 5.2.1.1.3 

4.2.1.1.1, 

123 

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
Specific questions on Action: (SO 2) EEN 

- How effective was the Enterprise 
Europe Network in achieving its 
aim?  

Desk research  
•  Annual monitoring reports 
• 

Final evaluation of EEN (dated 
2014) 
Interim evaluation of COSME 

• 
Interviews  
Targeted consultations 

As above 

Case Studies 

of 

than 

effective 

technology 
Encouraging 

-  Are  certain  aspects  of 
the 
Enterprise Europe Network more or 
others? 
less 
(Information,  Feedback,  Business 
cooperation, 
Internationalisation 
beyond  the  EU,  Innovation  and 
and 
transfer 
the 
knowledge, 
participation  of  SMEs 
the 
Community framework programme 
for RTD, Networking activities) 
-  How  have  the  services  of  the 
Enterprise 
Network 
Europe 
evolved  over  the  period  of  the 
Programme and from the EIP? 
Specific questions on Action: (SO 4) EYE  

in 

As above 

- How effective was the Erasmus 
for Young Entrepreneurs (EYE) in 
achieving its aim?  

Desk research – 
• 

 Annual  Monitoring  reports 
European  business  exchange 
programme 
for 
Entrepreneurs 
Young 
(erasmus-entrepreneurs.eu) 

-  Erasmus 

*Number of EEN member organisations  
*Number  of  SMEs  receiving  EEN  services  (or  which  advisory 
services  such  as  EU  programmes,  IPR,  technology  review, 
financing services etc.) 
*Number  of  SMEs  using  digital  services  (incl.  electronic 
information services) provided by the network 

4.2, 4.2.1.2, 4.5.3 

*Number of co-operation agreements 
*Number of partnership agreements signed 
*Global and average SME client satisfaction rate 

*% of SMEs reporting positive impact due EEN support (growth, 
jobs, others) 

 *Feedback  from  SMEs  and  EEN  organisations  on  effectiveness 
and utility of specific EEN services  

4.2, 4.2.1.2, 4.5.3 

Identification of success stories 

Key  variations  in  service  provision  (number  of  regional/local 
events, level of advisory support) 

4.2, 4.2.1.2, 4.5.3 

*Number  of  host/new  entrepreneurs  participating  in  the  EYE 
programme 
*Number of successful EYE matches  
*Number  of  intermediary  organisations  involved  in  the  EYE 
programme 

3.3,4.2, 
Case Study 2 

4.2.1.4, 

Interviews,  
Targeted consultations 

*Feedback  regarding  the  number  of  new  enterprises  created  and 
enhanced capacities/knowledge etc. following the EYE exchange 

124 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- Which impacts did EYE have on 
the 
(New 
participants 
Entrepreneurs(NEs)/Host 
Entrepreneurs (HEs)?  

As above 

-  How  has  EYE  evolved  over  the 
period  of  the  Programme  in  terms 
of its impacts?  
Other actions - tourism actions, cluster actions, social economy  

As above 

*% of EYE entrepreneurs reporting other positive impacts of the 
EYE exchange in terms of jobs created, joint projects/cooperation 
agreements, others 
*Increase in the entrepreneurship rate: percentage of entrepreneurs 
who have started a business or currently taking steps to start one 
Key variations in nature and level of impacts 

- To what extent and how have the 
smaller  actions  contributed 
to 
COSME objectives?  

there 

- 
Are 
any 
that  render 
aspects/means/actors 
certain  aspects  of  these  actions 
more  or  less  effective  than  others, 
and – if there are – what lessons can 
be drawn from this?  
-  How  have  the  selected  actions 
evolved  over  the  period  of  the 
Programme 
their 
impacts?  

terms  of 

in 

Desk research  
• 

-Trade  statistics  (see  Small 
businesses  exporting  outside 
the EU employ over 13 million 
people (europa.eu)) 

Interviews  
Targeted consultations 
As above  

 See Part 2 (objective C) 

Factors cited in consultations 
Factors explaining performance variations 

As above 

Time sequence of main performance variables of actions 

3.3,4.2, 
Case Study 2 

4.2.1.4, 

3.3,4.2, 
Case Study 2 

4.2.1.4, 

Case  Study  5,  Case 
Study 6, Case Study 
7, Case Study 8 

Case  Study  5,  Case 
Study 6, Case Study 
7, Case Study 8 

Case  Study  5,  Case 
Study 6, Case Study 
7, Case Study 8 

COSME Evaluation Questions 

 Efficiency 

General 

Information source(s) 

Indicators/specific evidence 

Draft final report sections 

EQ3.1 To what extent were the 
effects (benefits) of COSME 
achieved at a reasonable cost 
(including the administrative and 
reporting burden on participants, 
beneficiaries and stakeholders)? 
Were the costs (direct and 
indirect) generated by the 

Desk research  
•  Cost  data  from  programme 
expenditure 
/ 
monitoring 
information  through  portfolio 
analysis 
Interim evaluation 
SME Performance Review 
External:  Annual  Burden 
Survey (europa.eu) 

• 
• 
• 

Benefits  derived  from  the  participation  in 
COSME  
Reported  costs  including  the  administrative 
and reporting costs 

4.3.1 

125 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
programme proportionate to the 
benefits generated? 

EQ3.1.1 What are the 
regulatory/administrative costs 
and the benefits for the different 
participants and stakeholders?  

EQ3.1.2 Which interventions of 
COSME were the most efficient or 
inefficient, especially in terms of 
resources mobilised by 
stakeholders?  

EQ3.1.3 What was the potential 
for simplification and reduction of 
the administrative burden?  

EQ3.2 How efficient was the 
implementation structure and 
governance of the programme? 

EQ3.3 How did overlaps/ 
complementarities between 
COSME and any other Community 
action in the relevant areas affect 
the administrative burden?  
Action: (SO 1) LFG & EFG 

- Given the results that have been 
or are likely to be generated, to 
what extent are the costs of 
managing the instrument 
reasonable? 

- To what extent are the costs in 
line with the initial expectations 
and with comparable instruments, 
and (if intermediated) those of 
financial intermediaries? 

Interviews 
Targeted consultations 
Case studies 
Econometric  analysis  (benefits  / 
impacts) 
As above 

As above 

Interim evaluation 

Desk research  
• 
Interviews 
Targeted consultations 
As above  

As above 

administrative 

Benefits  derived  from  the  participation  in 
COSME 
Reported 
reporting 
burden/costs experienced by participants and 
other stakeholders  
Benefit  cost  ratio/comparison  of  different 
actions  (NB:  not  all  benefits  may  be 
quantifiable so a ratio may not be feasible) 

and 

4.3.3, 4.3.2.1. 

4.3.2.1 

Extra  resources  mobilised  by  actions  (e.g. 
own resources) 
Simplifications cited by stakeholders 

4.3.3 

the  programme  devoted  as 

Perceived ease of use, complexity, and speed 
of operations 
Share  of 
administrative expenditure 
Assessment  of  costs/benefits  generated  by 
overlaps with other Community actions (joint 
collaborative  actions  and  any  savings  from 
these) 

4.3.1 

4.3.3 

research 

instruments 

(programme 
Desk 
management  data  on  EIF  costs  of 
administering 
on 
delegated basis) 
Interviews 
Case studies 
As above 

Qualitative  assessment  of  administrative 
costs/burden in relation to finance provided 
Human 
applications (e.g. for financial instruments). 

resources  allocated 

to  process 

Comparative  analysis  of  costs  incurred  with 
other 
(qualitative 
assessment) 

comparable 

schemes 

4.3.2.1, 4.3.3 

4.3.2.1, 4.3.3 

126 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As above 

As above 

- Have the instruments, including 
the respective asset management, 
been implemented efficiently by 
the EIF and DG GROW, BUDG and 
ECFIN?  
- What lessons can be learned 
including for further alignment of 
the design of financial instruments 
on the most efficient and up-to-
date market practices? 
Action: (SO 2) EEN 

Number  of  FTE  devoted  at  EC  to  manage 
LGF and EFG 
Steps taken to ensure efficiency by EC and the 
EIF 

4.3.2.1, 4.3.3 

Lessons  cited  by  stakeholders  and  own 
judgements 

4.3.2.1, 4.3.3 

- Are the costs of the EEN 
structure (direct and indirect) 
proportionate to the benefits 
obtained? 

Desk research  
Interim evaluation 
Annual monitoring reports 
Interviews 

 Feedback  on  the  proportionality  of  costs 
Ratio between EU funds and own resources 
for  the  EEN  activities  (reported 
in  the 
interviews and in the survey) 

4.3.2.1, 4.3.2.2. 

- Are certain activities or 
components of the Enterprise 
Europe Network more or less 
efficient than others, and – if this 
is the case – what lessons can be 
drawn from this? 
- Use a few specific examples or 
case studies of Partnership 
Agreements to describe the cost-
efficiency of the EEN services 
provided for this purpose 
- Use a few specific examples or 
case studies of Advisory Service 
Outcomes to describe the cost-
efficiency of the EEN services 
provided for this purpose.  
Action: (SO 4) EYE 

- How efficient was EYE? 
(Comparing the costs and 
benefits).  

- Use a few complementary 
examples or case studies of 

As above 

Lessons cited by stakeholders 

4.3.2.1, 4.3.2.2. 

Case studies 

Case studies 

Examples  of  Partnership  Agreements  cited, 
their costs and benefits  

4.3.2.1, 4.3.2.2. 

Examples  of  Advisory  Service  Outcomes 
cited, their costs and benefits 

4.3.2.1, 4.3.2.2. 

Desk research 
Interim evaluation 
Annual monitoring reports 
Interviews 
Case studies 
Case studies 

Benefits  derived  from  the  participation  in 
EYE 
Costs incurred for participating in EYE  

4.3.2.1, 4.3.2.2., Case Study 2 

Examples of successful matches cited 

4.3.2.1, 4.3.2.2., Case Study 2 

127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
successful matches to describe the 
cost-efficiency of the support 
provided to achieve each 
match291?  
- Use a few complementary 
examples or case studies to 
illustrate what is the cost-
efficiency of one new 
job/enterprise created by EYE?  
Other actions - tourism actions, cluster actions, social economy  

Case studies 

- To what extent was it cost-
efficient to implement the specific 
objectives of the programme by a 
significant number of small 
actions?  

Desk research 
Interviews 
Interim evaluation 
Annual monitoring reports 

Targeted consultation  

Examples 
jobs/enterprises cited 

of 

successful 

creation 

of 

4.3.2.1, 4.3.2.2., Case Study 2 

costs/benefits of participating in actions based 
on estimates provided by survey respondents 

4.3.1, Case Study 5, Case Study 6, Case 
Study 7, Case Study 8 

Areas  for  improvement  in  terms  of  cost-
efficiency 

that 
Percentage  of  survey 
indicate that costs deriving from participating 
in COSME were proportionate to the benefits 
derived from it 

respondents 

COSME Evaluation Questions 

Relevance 

EQ5.1 To what extent were COSME's initial 
objectives relevant and pertinent to the needs, 
problems and issues they were designed to 
address?  
EQ5.1.1. Were the initial objectives and 
measures more relevant to specific types of 
SMEs than others?  
EQ5.2. To what extent were COSME’s objectives 
and measures relevant to the needs and 
problems faced by SMEs throughout their 
implementation period? How did the 
programme adapt to new needs, priorities, 
problems? 
EQ5.2.1 To what extent were adaptations made 
to meet current and emerging needs and 
problems of different types of SMEs 

Desk research 
Interviews 

Correspondence  between  actions  and 
needs, problems and issues identified in 
Programme legislation  

Draft final report sections 

4.1.1, 4.1.1.3,  

As above 

As above 

Mapping of actions to needs of different 
SME 

4.1.1 

Identification of new needs, priorities & 
problems and responses 

4.1.1 

Identification of the main changes made 

As above 

As above 

4.1.1, 4.1.2, 4.1.3 

128 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EQ5.2.2 To what extent were there adaptation 
mechanisms in place to ensure that the 
programme meets new needs in response to 
political, economic, technological, and scientific 
and social developments?  
EQ5.2.3 How did COSME adapt to political 
priorities for instance to the new Single Market 
Strategy and its particular objective to support 
Start-ups and Scale-ups? 
EQ5.2.4 How did COSME adapt to deal with 
major new challenges affecting businesses, in 
particular the Covid-19 crisis? 
EQ5.2.5 To what extent are the COSME actions 
addressing new market deficiencies?  
Action: (SO 1) LFG & EFG 

- To what extent were the instruments' 
objectives pertinent to the needs, priorities, 
problems and issues they were designed to 
address?  
- To what extent are they relevant to current 
needs?  
Action: (SO 2) EEN 

As above 

Description  of  adaptation  mechanisms 
&  their  use  in  relation  to  specified 
political,  economic,  technological,  and 
scientific and social developments 

4.1.1, 4.1.3 

As above 

Changes  made  to  support  new  policy 
priorities 

4.1.1 

As above 

Changes made to respond to Covid-19 

4.1.1, 4.1.2 

As above 

Desk research 
Interviews 

Identification 
deficiencies & responses 

of 

new  market 

between 

Correspondence 
financial 
actions and finance needs, problems and 
issues 
Programme 
legislation 

identified 

in 

4.1.1, 4.1.1.1.1, 4.1.3 

4.1.1.1 

As above 

Correspondence  with  current  finance 
needs and market gaps/ weaknesses 

4.1.1.1 

-To  what  extent  were  the  objectives  set  for  the 
network  at  the  start  of  the  programme,  and  the 
network’s  initial  services  in  line  with  SMEs’ 
needs at that time? 

Desk research 
Interviews 
Targeted survey 

As above 

- To what extent do EEN objectives and services 
meet current needs/challenges faced by SMEs?  

Action: (SO 4) EYE 

- To what extent did EYE respond to the needs/ 
problems and challenges identified at the start 
of the programme?  
- To what extent does EYE respond to current 
needs and challenges faced by SMEs?  

Desk research 
Interviews 

As above 

Action: Other actions - tourism actions, cluster actions, social economy  

Correspondence 
objectives and the services provided 

between 

network 

4.1.1.2, 4.1.2, 

Identification  of  current  service  needs 
and 
EEN 
correspondence  with 
objectives & services  

4.1.2, 4.1.3 

Correspondence  between  perceived 
problems  and  challenges  and  EYE 
responses 
Identification  of  current  needs  of  new 
entrepreneurs and correspondence with 
EYE objectives & services 

4.1.1.4, Case Study 2 

4.1.1.4, Case Study 2 

129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
- To what extent were the smaller actions 
relevant to the needs, priorities, and problems 
that the COSME programme was designed to 
address?  
- To what extent were the smaller actions 
pertinent to the current needs, priorities, and 
problems faced by SMEs? 

Desk research 
Interviews 
Targeted survey 

As above 

COSME Evaluation Questions 

Coherence 

EQ7.1 To what extent has the internal coherence 
of the four specific objectives been maximised? 
What are the lessons learnt?  

Desk research 
Interviews 
Case studies 

As above 

As above 

As above 

As above 

EQ7.1.1 To what extent were/are the different 
actions of COSME implemented coherently 
between one another? Are/were there any issues 
of internal coherence between the various 
components of the Programme?  
EQ7.1.2 To which extent have the individual 
components of the Programme been coordinated 
to maximise the effects of the Programme and, in 
this regard to which extent has there been active 
management of synergies in place?  
EQ7.2 Are there overlaps or complementarities 
between the measure and any other EU action 
which have similar objectives?  
EQ7.2.1 How have the different COSME 
instruments overlapped/synergised with the 
activities of ESI funds, the Innovfin, SME 
instrument and Innosup actions of Horizon 2020 
or the SME window of EFSI (European Fund for 
Strategic Investments), EASI (Employment and 
Social Innovation) and other measures impacting 
SMEs in other programmes?  

Identification  of  contribution  of  other 
actions 
to  needs,  priorities,  and 
problems  expressed  in  the  Programme 
legislation 

4.1.1.3, 5.1.3, Case Study 5, Case Study 
6, Case Study 7, Case Study 8 

Identification of current needs in areas 
covered 
and 
other 
correspondence with current provision 

actions 

by 

4.1.1.3, 5.1.3, Case Study 5, Case Study 
6, Case Study 7, Case Study 8 

Draft final report sections 

Identification  of  interaction  between 
the actions under the 4 objectives  
Identification  of  potential  for  further 
interaction 
in 
Identification  of  key  elements 
COSME  implementation  processes  & 
interaction between them 

Examples  of  co-ordination  within 
COSME 
Identification  of  any  management  of 
synergies 

of 

Identification 
main 
overlaps/complementarities with other 
EU action 
Examples  of  main  overlaps/synergies 
with the other EU SME actions 

4.4.1 

4.4.1 

4.4.1 

4.4.2 

4.4.2, 4.4.2.1 

130 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Action: (SO 1) LFG & EFG 

- To what extent are the financial instruments 
complementary to others such as EFSI (European 
Fund for Strategic Investment), Horizon 2020’s 
Innovfin or financial instruments set up under ESIF 
(European Structural and Investment Funds)? To 
what extent have EGF and LGF been implemented 
in synchronicity as part of the single equity/debt 
financial instruments, respectively? Are there 
complementarities with other relevant EU-level 
financial instruments?  
- To what extent has the external coherence 
between COSME financial instruments and 
national programmes maximised?  

- How could complementarities be improved, 
particularly with ESIF instruments (cohesion 
policy)?  
Action: (SO 2) EEN 

- What is the level of interaction of different 
support services for businesses (Your Europe 
Business portal, and the EEN)?  
-  Does  the  intervention  (for  the  EEN)  create 
synergies  with/contradict  other  EU  interventions 
that  have  similar  objectives?  (e.g.,  for  the  EU: 
cluster networks, Erasmus for Young Entrepreneurs 
programme,  business  centres  in  third  countries, 
EIAH  (EFSI  related),  Gateway  and  Executive 
countries, 
Training  programmes  with 
helpdesks etc.):  
-  Does  the  intervention  (for  the  EEN)  create 
synergies  with/contradict  other  Member  States 
interventions  that  have  similar  objectives?  (e.g. 
chambers of commerce in third countries etc.). 
Action: (SO 4) EYE 

third 

As previous 

4.4.1, 4.4.2.1 

Institutional  arrangements 
for  co-
ordination of EU financial instruments 
by EIF 
Identification 
particular 
contributions  of  EFG  &  LGF  &  their 
interaction with other EU funds 

of 

As previous  

As previous  

Desk research 
Interviews 
Case studies 
As previous  

Identification  of  overlaps/  synergies 
between COSME financial instruments 
and national programmes 
Evidence 
of 
shopping’ 
during 
Improvements 
consultations, particularly in relation to 
ESIF 

competition/ 

cited 

‘deal 

4.4.1, 4.4.2.1 

4.4.1, 4.4.2.1 

Identification  of  interaction  between 
EEN  services  and  between  EEN  & 
related services provided by COSME 
Identification 
main 
complementarities or frictions between 
EEN services & other EU action 

of 

4.4.1, 4.4.2.2. 

4.4.1, 4.4.2.2. 

As previous  

of 

Identification 
main 
complementarities or frictions between 
EEN  services  and  national/regional 
services  

4.4.1, 4.4.2.2. 

- To what extent are the objectives and 
implementation of EYE coherent with the 
Enterprise Europe Network?  

Desk research 
Interviews 
Case studies 

Identification 
main 
complementarities  between  EEN  and 
EYE services  

of 

4.4.2.4, Case Study 2 

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Action: Other actions - tourism actions, cluster actions, social economy  

- To what extent are the other actions coherent with 
the overall objectives of COSME? 

Desk research 
Interviews 
Case studies 

Identification  of  relative  contribution 
of  other  actions  to  overall  COSME 
objectives 

4.4.2.3,  Case  Study  5,  Case  Study  6, 
Case Study 7, Case Study 8 

COSME Evaluation Questions  

EU Value-added 

EQ9.1 How did COSME and its measures deliver 
added value, compared to what could be achieved 
on merely national, regional and/or local level?  

EQ9.1 .1 How has the Programme tackled the 
challenges it is addressing at the level of each of 
its 4 specific objectives? 
EQ9.1.2 How has COSME helped to improve the 
business environment across the EU? 
EQ9.1.3 To what extent has the programme 
supported the development of cross-border 
business activities?  
EQ9.1.4 How and to what extent have 
Programmes’ actions synergised or overlapped 
with national and regional programmes?  
EQ9.1.5  Are  the  Programmes’  actions  better 
addressing  the  market  failures  detected  than 
national or regional programmes? 
EQ9.1.6 The Impact Assessment accompanying the 
proposal  for  a  COSME  regulation  established  five 
areas  making  up  the  potential  European  added 
value.  To  what  extent  have 
the  actions 
demonstrated  that  they  add  value  at  European 
level? 
EQ9.2 To what extent do the issues addressed by 
the Programme and its measures continue to 
require action at EU level?  
EQ9.2.2. What would be the most likely 
consequences of stopping or withdrawing the 
measure?  
Action: (SO 1) LFG & EFG 

Desk research 
Interviews 
Case studies 
Validation Workshops 
As previous  

As previous  

As previous  

As previous  

As previous  

As previous  

As previous  

As previous  

Identification  of  main  instances  of 
COSME EU added-value  

4.5, 4.5.1 

Draft final report sections 

of 

on 

improvements 

Identification 
distinctive 
contributions of COSME in relation to 
each of the 4 objectives 
Feedback 
attributable to COSME 
Identification  of  extent  of  support  to 
cross-border  activity  across  COSME 
actions 
Feedback  on  duplications  in  COSME 
and country-level provision and effects 

Contributions  to  addressing  market 
failures  of  COSME  and  national  or 
regional programmes 
Observed  value-added  in  the  5  areas 
identified by the Impact Assessment 

4.5, 4.5.1 

4.5, 4.5.1 

4.5, 4.5.1 

4.5, 4.5.1 

4.5, 4.5.1 

4.5, 4.5.1 

Identification 
continuing need for EU action 

instances 

of 

of 

4.5, 4.5.1 

Principal 
anticipated 
stopping or withdrawing the measure 

impacts  of 

4.5, 4.5.1 

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- To what extent have the COSME financial 
instruments contributed to improving access to 
finance for SMEs at EU level in comparison to 
national or regional similar instruments and what 
is their EU added value?  
Action: (SO 2) EEN 

- To what extent can the added value of the 
Enterprise Europe Network be considered EU 
added value? To what extent do the stakeholders 
attribute the perceived added value to the EU?  
- Which services do host organisations (chambers 
of commerce etc.) provide exclusively under the 
umbrella of the Network compared with those 
services that they provide in their own right 
without support from the Programme? 
Action: (SO 4) EYE 

- To what extent is EYE creating EU added value? 

Desk research 
Interviews 
Case studies 

Desk research 
Interviews 
Case studies 

As previous 

EU-value  added  of  COSME  financial 
instruments,  

4.5.2 

Identification of the nature and extent 
of EU value-added by the EEN.  
Recognition  of  EU 
evidenced in consultations 

contribution 

4.5.3 

Identification  of  services  exclusively 
provided through the EEN 

4.5.3 

Desk research 
Interviews 

Identification  of  nature  &  extent  of 
EYE EU added-value 

4.5.1, 4.5.5., Case Study 2 

Action: Other actions - tourism actions, cluster actions, social economy  

- What is the EU added-value of the other actions?  Desk research 

Interviews 

Identification of nature & extent of the 
EU added-value of the other actions 

4.5.4.,  Case  Study  5,  Case  Study  6, 
Case Study 7, Case Study 8 

COSME Evaluation Questions  

Longer term continuity and impacts 

EQ11.1  What  measures  were  taken  to  foster  the 
longer-term continuity and  impact of actions that 
generated  positive  changes  or  impacts  for  SMEs 
and stakeholders? Could any further measures be 
taken to this scope? 

Desk research 
Interviews 
Validation Workshops 

Identification  of  COSME  measures 
positively 
longer-term 
fostering 
continuity and the impact of actions 

5.2.1 

Draft final report sections 

Part 2: List of performance indicators by specific objective (focus on effectiveness and impact)   

EQ1.1 How effective was COSME in achieving its general and specific objectives, in terms of outputs, results and 
long-term impact of its measures? 

Draft final report sections 

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
COSME activities 

Indicators (red: output, blue: result, black: impact) 

EFG (Equity Facility 
for Growth) 

Funding distributed by EFG 
Number of VC funds supported 
Sectoral distribution of EFG  

4.2.1.1.,4.2.1.1.1, 4.2.1.1.2, 
4.2.1.1.3. 

Specific 
objectives 
a. To improve 
access to finance 
for SMEs in the 
form of equity 
and debt 

Operational 
objectives 
Improve SMEs’ 
access to venture 
capital and 
mezzanine 
markets and 
strengthen EU 
wide markets for 
these 
instruments 

LGF (Loan 
Guarantee 
Facility) 

Improve 
conditions for 
guarantees and 
other forms of 
risk sharing 
including cross-
border lending 
and commercial 
activities 

Funding take-up by country where access to finance 
is more constrained (signature amounts, number of 
SMEs supported)Total funding catalysed by 
instrument 
% of SMEs reporting difficulty in accessing finance  
% of SMEs reporting full (no alternatives available) or 
partial additionality (alternatives available but at less 
favourable conditions or smaller scale)  

Number of jobs maintained or created in the SMEs or 
industry  
Leverage ratio 
% of SMEs reporting a positive impact as a result of 
the funding received (growth, added-value and 
employees) 
Change of venture capital availability indicator (EU 
average) 2014-2020 
Total EC commitments to debt finance 
Number of intermediaries supported  
Sectoral distribution of LGF 

Number and type of SMEs receiving guaranteed loans  
Total value of lending provided on the basis of LGF 
Leverage ratio 
Feedback from SMEs on added-value, utility and 
relevance (e.g. firms stating financial instruments as 
only/significant source of finance) 
% of intermediaries and final beneficiaries 
recognising the origin of the support 

Number of jobs maintained or created in the SMEs or 
industry  
% of SMEs reporting a positive impact as a result of 
the COSME guarantees (growth, added-value and 
employees) 

134 

 
 
 
 
 
 
 
 
 
Help SMEs take 
full advantage of 
the Single 
Market 

Enterprise Europe 
Network (EEN) 

b. To improve 
access to 
markets, 
particularly 
inside the Union 
but also at global 
level 

Help SMEs to 
access and 
develop activities 
in markets 
outside the EU 

c. To improve 
framework 
conditions for 
the 
competitiveness 
and 
sustainability of 

Enhance the 
effectiveness of 
policies and 
institutions 
supporting 
competitiveness 
and growth 

Support for SME 
internationalisation 
including:  
1) EU-Japan centre 
for industrial 
cooperation 
2) Your Europe 
Business portal 
4) China IPR 
Helpdesk 
5) other Helpdesks 

 Activities to 
improve European 
competitiveness 

4.2.1, 4.2.1.2,, 4.2.1.3 

Feedback reading changes in lending/ investment 
patterns of financial instruments as a result of 
COSME 
Number of EEN member organisations ( 
Number of SMEs receiving EEN services (or which 
advisory services such as EU programmes, IPR, 
technology review, financing services etc.) 
Number of SMEs using digital services (incl. 
electronic information services) provided by the 
network 
Enterprise Awards with media publications/clippings 
in all Member States 

Number of co-operation agreements 
Number of cross-border partnership agreements 
signed 
Global and average SME client satisfaction rate 

% of SMEs reporting positive impact due EEN support 
(growth, jobs, others) 
Feedback  from  SMEs  and  EEN  organisations  on 
effectiveness and utility of specific EEN services 
Number of activities organised 
Number of information material (leaflets, web pages, 
etc.) 

Number of users of services (e.g. use of help 
lines/services/website)  
Clients/users satisfaction rate 

Trade balance of goods/services as % of total exports 
of goods/services 

Feedback from participants regarding an improved 
regulatory framework 

3, 4.2.2. 

135 

 
 
 
 
 
 
 
 
 
 
Union 
enterprises, 
particularly 
SMEs, including 
in the tourism 
sector 

Foster the 
competitiveness 
of targeted EU 
sectors 

Facilitate market 
uptake of 
sustainable, 
inclusive 
products, 
services and 
processes 

Improve 
framework 
conditions and 
SME policy  

Support for specific 
industry sectors - 
tourism 

Number of total applications for tourism related 
funding opportunities 

Number and type of beneficiaries supported 

Clusters 
Internationalisation 

European Cluster 
Excellence 
Programme with 
ClusterXchange 
scheme connecting 
ecosystems and 
cities 

Feedback the improved visibility of tourism 
destinations and products 
Number of cluster initiatives and events 
(workshops/conferences/match-making organised) 
Number of cluster organisations and SMEs 
participating in events 
Number of sectors covered by cluster initiatives 
Numbers of SMEs assisted to export within or outside 
the Union 

Successful cluster matching and cooperation 
agreements 
Feedback from cluster organisations and cluster 
managers on the added-value of the supported 
activities and cluster actions 

% of SMEs reporting positive impact from cluster 
actions (growth, jobs, others) 

SME performance 
review 

Reduction of start-up time and complexity for new 
enterprises 

Small Business Act 
for Europe (SBA) 
including 
implementation, 
outreach tools and 
communication 
activities 

EU REFIT platform 

136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
d. To promote 
entrepreneurship 
and 
entrepreneurial 
culture 

Foster 
entrepreneurial 
attitudes, 
mindsets, skills 
and capabilities 

Erasmus for Young 
Entrepreneurs 
(EYE)  

Number of host/new entrepreneurs participating in 
the EYE programme (per year of the programme) 
Number of successful EYE matches (per year of the 
programme) 
Number of intermediary organisations involved in the 
EYE programme (per year of the programme) 

4.2.1.4 

Feedback regarding the number of new enterprises 
created and enhanced capacities/knowledge etc. 
following the EYE exchange 

Increase in the entrepreneurship rate: percentage of 
entrepreneurs who have started a business or 
currently taking steps to start one (survey feedback) 

% of EYE entrepreneurs reporting other positive 
impacts of the EYE exchange in terms of jobs created, 
joint projects/cooperation agreements, others 
Feedback regarding new policy measures for 
entrepreneurship in MSs (survey feedback) 

Improve 
framework 
conditions for 
entrepreneurship 
development 

Other actions 
supporting 
entrepreneurship 
e.g. 

European Network 
of female 
entrepreneurs and 
on-line e-platform,  

Support for 
entrepreneurship 
policy 
implementation 

137 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS [AND, WHERE RELEVANT, TABLE ON SIMPLIFICATION AND BURDEN REDUCTION] 

The following Tables offer an overview of costs and benefit identified, assessed compared to the situation that preceded the COSME programme, and of the 
potential for burden reduction. 

138 

 
 
Table 1. Overview of costs and benefits identified in the evaluation326 

Citizens/Consumers  

Businesses 

Administrations 

Other :   European Fund for 
Strategic Investments (EFSI), 
participants in different actions  

Quantitative   Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

Costs description: The costs from the COSME Programme focused on the costs and investments sustained by the European Union and participant organisations.  The COSME programme 
had a total implemented budget of EUR 2.4 billion (incl. administrative costs) of which 66% was assigned to improve access to finance for SMEs (SO 1), and 20.1% to improve 
access to markets (SO  2).  The rest was aimed at improving framework conditions and competitiveness (SO 3) (10.7%) and promoting entrepreneurship (SO 4) (3.2%). Costs 
are available on specific activities, such as access to finance initiatives (Loan Guarantee Facility and Equity Facility for Growth), Enterprise Europe Network (EEN), Erasmus for Young 
Entrepreneurs (EYE). In the context of the programme, direct compliance costs are understood to represent EU contribution.  

Comment 

Monetary value  Comment 

Monetary value 

Comment 

Monetary value  Comment 

Monetary 
value 

Type: 
one-off 
or 
recurrent 

N/a 

N/a 

N/a 

N/a 

Direct costs – activities to 
do with improving access 
to finance (Specific 
Objective 1) 

One-off 

EUR 1.587 billion 
were committed to 
these activities for 
programming period 
2014-2020 (of 
which 1.2 billion to 
LGF) 

EUR 1.34 
billion 

Costs incurred 
by the 
European 
Fund for 
Strategic 
Investments 
(EFSI) to top-
up the 
COSME LGF 
budget 

326 Where there is a prior impact assessment, the table should contain as a minimum the costs/benefits identified in the IA with the information gathered on the actual cost/benefit. As available, the table 
should include the monetisation (€) of the costs/benefits based on any quantitative translation of the data (time taken, person days, number of records/equipment/staff etc. affected or involved represented 
in monetary value  – see Standard cost model, for example). For all information presented, it should be included in the comments section whether it relates to all Member States or is drawn from a subset. 
An indication of the robustness of the data should be provided in Annex II on Methodology and analytical models used. 

139 

 
 
 
  
 
  
 
 
N/a 

N/a 

N/a 

N/a 

Direct costs – activities to 
do with improving access 
to markets (Specific 
Objective 2) 

One-off 

N/a 

N/a 

N/a 

N/a 

Direct costs – activities to 
do with improving  
Framework Conditions 
and Competitiveness 
(Specific Objective 3) 

One-off 

EUR 482 million for 
this objective, with 
367.3 million of EU 
contribution going 
to the EEN.  Actions 
included  the EEN, 
public procurement 
of innovation (PPI), 
actions to support 
internationalisation 
such as the 
Intellectual Property 
Rights (IPR) 
Helpdesks in China, 
Latin America and 
south-east Asia, and 
initiatives to 
improve SME 
access to 
information, such as 
the Your Europe 
Business portal and 
the Single Digital 
Gateway.  

EU contribution 
EUR 256 million of 
which EUR 94.6 
million.  went into 
projects funded by 
actions related to 
Tourism (EUR 28.8 
million), 

EUR 294 
million327 
supported by 
participants in 
the different 
actions (e.g. 
own financing 
by the EEN 
members and 
the participants 
in other 
projects) 

EUR 
32.7million328 
sustained by 
project 
participants 

327 The costs were obtained through a portfolio analysis involving the mapping of the policy mix used in the programme by reconstructing expenditures by several parameters (e.g., operations and budget 
distribution over the different structural components of the programme). The overall costs (i.e, 2014-2020) were retrieved from the Q4 2022 quarterly report (Access to Finance) and from the data provided 
by EISMEA (for the other actions). Those data referred to the whole period. 

328 Ibid. 

140 

 
 
 
 
 
 
Internationalisation 
(EUR 26.6 million), 
and Competitiveness 
(EUR 25.8 million). 

EU contribution 
amounted to EUR 
78 million with the 
largest contribution 
being to EYE (EUR 
58.5 million) 

EUR 10.1 
million   
sustained by 
project 
participants. 

N/a 

N/a 

N/a 

N/a 

N/a 

N/a 

N/a 

N/a 

Direct costs – activities to 
do with Promoting 
Entrepreneurship and 
Entrepreneurial culture 
(Specific Objective 4) 

One-off 

N/a 

N/a 

Indirect costs (indirect 
compliance costs or other indirect 
costs such as transaction costs) 

One-off 

Survey has 
revealed some 
costs to 
participants in 
EYE.  Of the 
host 
entrepreneurs 
responding to the 
survey of EYE 
participants who 
offered a figure, 
nearly all 
reported costs 
between zero 
and EUR 5 000.  
These costs 
included 
welcome and 
hospitality costs, 
equipment 
(office supplies 
and material), 
workplace, travel 
costs. These 
costs are 
however not 
obligatory. Other 
indirect costs 

141 

 
 
 
 
 
Benefits description: The benefits from COSME vary according to the different actions but range for better conditions on access to finance, direct benefits, to improving innovation 
(indirect benefits). In most cases, the benefits (measured as outcomes) have not been monetised, but there are quantitative metrics on the number of beneficiaries that can be used as 
proxies of impacts (outputs indicators).  

from EEN 
services are 
reported to be 
limited 

N/a 

N/a 

N/a 

N/a 

Benefits for 
companies by 
enabling them to 
access finance at 
a cheaper rate 
than in their 
national markets. 

N/a 

N/a 

Direct benefits – activities 
to do with improving 
access to finance (Specific 
Objective 1) 

One-off 

Between 2014 
and 2022, the 
LGF signed a 
total of 163 
guarantee 
contracts with 
128 financial 
intermediaries, 
which resulted in 
1 173 780 
transactions for a 
total guarantee 
amount of EUR 
53.9 billion 
provided to 865 
387 final 
recipients, i.e., 
SMEs. 
The EIF signed 
EFG agreements 
with 23 financial 
intermediaries 
and committed 
an overall 
amount of about 
EUR 324 
million.  Overall, 
core COSME 
EFG operations 
supported an 
overall 

142 

 
N/a 

N/a 

Direct benefits – activities 
to do with improving 
access to markets (Specific 
Objective 2) 

One-off 

the  Pan 
VC 

investment of 
EUR 822 million 
in SMEs. 
Under 
European 
Funds-of-Funds 
Initiative,  EFG 
committed  EUR 
45  million  in  the 
funds  of 
two 
funds, 
which 
resulted  in  EUR 
in 
3.1  billion 
investments 
in 
eligible SMEs. 

COSME 
implemented 13 
actions, through 
27 project calls. 
EEN is the 
largest action 
with ten calls for 
projects to 
provide advisory 
services to SMEs 
were launched 
during the 
programme, 
relating to a total 
of 518 distinct 
projects and 664 
beneficiaries. 
The number of 
SMEs being 
supported is 
nearly 2 million 
a year. 

91% of the 
SMEs clients 
that responding 
to the targeted 
survey on EEN 
services 
confirmed that 
EEN’s support 
had helped them 
to maintain the 
number of 
employees in 
their firm, to 
expand to new 
geographical 
markets and/or 
maintain or 
increase their 
turnover. 

59% of SMEs 
responding to 
this targeted 

143 

N/a 

N/a 

N/a 

N/a 

 
 
 
survey reported 
that the EEN 
services helped 
them to 
maintain, and 
56% reported an 
increase in their 
turnover. 

The services of 
the IP SME 
Helpdesks 
enable SMEs to 
save costs for 
protecting their 
IP for moving 
into a foreign 
market. The 
2018 evaluation 
study also 
highlights the 
“potential 
benefit” of these 
services for 
helping SMEs to 
avoid litigation 
(potentially huge 
cost savings but 
non-measurable 
benefit) 

IP SME 
Helpdesks: 33 
000 SMEs 
participated in 
events organised 
by the helpdesks 
and the 
helpdesks 
responded to 12 
456 helpline 
queries  

COSME 
supported 21 
actions, through 
30 project calls, 
and financed 263 
projects. In total, 
grants were 

Of the 11 
tourism sector 
respondents to 
the targeted 
survey for 
“beneficiaries 
and providers of 

144 

N/a 

N/a 

Direct benefits – activities 
to do with improving  
Framework Conditions 
and Competitiveness 
(Specific Objective 3) 

N/a 

N/a 

N/a 

N/a 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
provided to 1175 
participants. 

other COSME 
actions” 82% 
(9/11) confirmed 
that the projects 
led to improved 
capacities for 
networking and 
knowledge 
sharing in the 
sector, and 73% 
(8/11) confirmed 
that the projects 
had improved 
exploitation of 
new tourism 
demand trends. 

Clusters 
internationalisati
on actions 
enhanced the 
internationalisati
on skills of 
clusters (better 
understanding of 
internationalisati
on issues)  
Clusters 
Excellence 
actions : 
enhanced 
management 
skills of clusters  
The 
clusters 
excellence 
quality label was 
used  by  national 
funding 

145 

 
 
authorities  as  a 
criterion 
for 
allocating 
national  funding 
to  clusters.  This 
therefore  led  to 
increased 
funding 
clusters 
could 
better 
support 
businesses. 

for 
that 
provide 
quality 
to 

N/a 

N/a 

N/a 

N/a 

Direct benefits– activities 
to do with Promoting 
Entrepreneurship and 
Entrepreneurial culture 
(Specific Objective 4) 

According to 
the survey of 
NEs carried 
out by DG 
GROW after 
the 
exchange, 
73.4 % of the 
8009 
respondents 
were 
planning to 
set up a 
business 
(either 
immediately: 

COSME 
implemented 5 
actions, through 
12 project calls, 
financing 111 
projects.  The 
action that 
funded the 
largest number 
of projects is 
“Erasmus for 
Young 
Entrepreneurs” 
(EYE) where EU 
contributions 
was granted to 

Erasmus for 
Young 
Entrepreneurs 
(EYE) action :     
- 90% of Host 
entrepreneurs 
(HEs) reported 
that hosting the 
new 
entrepreneur 
contributed to 
one or several 
commercial 
benefits 
including 
development or 

146 

 
 
 
 
 
 
 
 
(5.3%, in the 
next 12 
months: 
29.9% or in 
the next 3 
months: 
11.8%), and 
9.5% had 
already set 
up a 
business. 

360 intermediate 
organisations 
and the number 
of projects 
totalling 83.  
Host 
entrepreneurs 
responding to the 
targeted survey 
reported that 
hosting the new 
entrepreneur 
contributed (to a 
great extent or 
some extent) to: 
development or 
growth of the 
business (50%), 
expansion of 
sales to new 
countries (36%), 
expansion of 
operations to 
new countries 
(32%), increase 
in the number of 
employees 
(32%), 
safeguarding 
jobs (29%) and 
an increase in 
turnover (29%), 
increased export 
turnover (21%). 

growth of the 
business (45%), 
an increase in 
jobs or 
safeguarding of 
jobs (43%) 
Other benefits 
for new and host 
entrepreneurs 
from EYE  
exchanges 
include 
improved skills 
(Almost 100% of  
NE and 73% of 
HE confirmed 
that the 
exchanges 
strengthened 
their skills and 
knowledge). 
Other benefits 
included the 
possibility to 
meet potential 
partners or 
collaborators and 
suppliers 55% of 
the host 
entrepreneurs 
within EYE 
thought that the 
exchange offered 
value for money. 

147 

 
 
TABLE 2:  Simplification and burden reduction (savings already achieved)  
Report any simplification, burden reduction and cost savings achieved already by the intervention evaluated, including the points of comparison/ where available (e.g. REFIT savings 
predicted in the IA or other sources).  

Citizens/Consumers/Workers 

Businesses 

Administrations 

Other : participating 
parties/beneficiaries 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative  Comment  

Quantitative  Comment 

Administrative costs savings to the Commission.  The share of the programme budget devoted to administrative expenditure is relatively low particularly in the latest years (3% of 
the total programme costs). In the initial years (2014-2015), when the programme was being established, the administrative expenditure was slightly larger than comparable 
programmes, but it has fallen since then. Following a cost-benefit analysis conducted in 2013329, the Commission recognised that the delegation of programme management to 
external bodies or Executive Agencies is a more efficient and cost-effective approach. Estimates from the last evaluation are of around EUR 6.9 million a year which is just below the 
EUR 7.2 million per annum calculated in the previous evaluation conducted in 2014.  

Type: Recurrent  

N/a 

N/a   

N/a 

N/a   

The reduction 
in 
administrative 
costs is due to 
a delegation of 
programme 
management to 
executive 
agencies; but 
any figures 
should be 
interpreted 
with caution.   

Estimates 
from the last 
evaluation 
are of around 
EUR 6.9 
million a 
year which is 
just below 
the EUR 7.2 
million per 
annum 
calculated in 
the previous 
evaluation 
conducted in 
2014. 

Across the 
full 
programme 
period, 
intermediari
es and final 
beneficiaries 
found the 
costs and 
burdens 
associated 
with 
participation 
to be 
affordable 
and 
acceptable. 

PART II: II Potential simplification and burden reduction (savings) 
Identify further potential simplification and savings that could be achieved with a view to make the initiative more effective and efficient without prejudice to its policy objectives330. 

Citizens/Consumers/Workers 

Businesses 

Administrations 

Other :Participating parties 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment   Quantitative 

Comment 

148 

 
               
 
 
 
 
 
 
 
Description: According  to the evaluation, there was a high share of ineligible proposals in some actions in the early years of the programme (in areas such as tourism grants and the 
clusters of excellence  due to the lack of clarity of the work programme descriptions, which represents an unnecessary cost for applicants and evaluators of proposals. It has also been 
highlighted in the interviews conducted for the evaluation that some of the synergies between the actions could have been enhanced, with may have resulted in some administrative 
savings. No quantification has been possible, however.  

Type:  One-off  

N/a 

N/a 

N/a 

N/a 

N/a 

N/a 

Costs of 
submitting 
proposals if 
lack of 
clarity 

329 CBA conducted by the Commission (SEC(2013) 493 final) 

330    This assessment is without prejudice to a possible future Impact Assessment. 

149 

 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

This is an overview of the results of the consultation activities carried out in the context of 
the  COSME  final  and  EIP  ex-post  evaluations,  including  the  targeted  and  public 
consultations  as  well  as  the  interviews.  Further  details  on  the  consultations  are  in 
standalone survey reports, attached the supporting studies. 

Call for Evidence 

The feedback period started on 17 March 2023 with a deadline for feedback by 14 April 
2023. In total, 3 stakeholders provided feedback. There were 2 business associations from 
Belgium and an NGO from Slovakia. The feedback received was considered in the scope 
of the analysis. 

Public consultation (the Summary report is available online331) 

The consultation was published on 15 June 2023 and responses were accepted until 18 
September 2023. 24 organisations and individuals responded to the consultation. The 
responses came from Italy (8 replies), Belgium (2), Germany (2), Netherlands (2), 
Romania (2), Finland (1), France (1), Hungary (1), Luxembourg (1), Malta (1), Poland 
(1), Portugal (1) and Spain (1). No responses were received from non-EU countries. 

Overview of the Consultation Strategy 

The  consultation  activities  carried  out  for  the  supporting  study  included:  an  interview 
programme with selected stakeholders and 6 targeted consultations conducted via online 
survey.  

As regards the interview programme, 73 interviews were carried out with key stakeholders 
(the agreed target was 45-60). These includes scoping interviews with EC and Executive 
Agency officials, interviews with financial intermediaries, funds, investee companies and 
other participants in thematic actions. On multiple occasions, interviews were conducted 
with more than one stakeholder (these have been counted as single interview).  

As part of the consultation strategy, 6 targeted consultations were carried out via online 
surveys. These were used to obtain evidence on the programme and specific actions which 
complemented the statistical analysis and the results of the review of available monitoring 
data/secondary sources. All surveys were launched on 7 August and ran until 25 September 
(apart  from  the  financial  support  ones  kept  open  for  a  few  more  additional  days  to 
encourage participation). The approach to dissemination is explained in the table below. 

Stakeholder Groups Involved in the Targeted Consultations 

The  online  surveys  targeted  different  stakeholders  relevant  to  either  strand  of  the 
supporting  study  (COSME  and  EIP)  or  both.  These  included:  COSME/EIP  financial 

331 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13399-COSME-programme-

evaluation/public-consultation_en 

150 

 
 
 
 
 
instruments  intermediaries  and  final  recipients  of  SMEG  /  LGF  support,  EEN  member 
organisations and SMEs clients, EYE host and new entrepreneurs, as well as providers and 
beneficiaries of other COSME/EIP co-funded services (including tourism actions, clusters, 
social economy and others).  

No 

Target groups 

Approach to the 
dissemination  

Initial 
estimate 

Number of 
responses 

1 

Final recipients of SMEG 
and LGF guaranteed 
loans 

2 

Financial Intermediaries 
for SMEG and LGF 

3 

4 

5 

EEN member 
organisations334 

EEN beneficiary SME 
clients 

and 

Providers 
SME 
beneficiaries  of  other 
(e.g.  cluster 
measures 
international 
organisations/managers, 
thematic 
actions 
including  tourism,  social 
economy)  

6 

EYE  Entrepreneurs  (host 
and new entrepreneurs) 

5 000332 

201 

128333 

59 

530 

109 

10 000 

67 

Not known 

110 

The evaluation team agreed 
on  the  approach  with  EIF 
and  invited  the  financial 
intermediaries 
to 
disseminate the survey link 
to clients in portfolio. 

The evaluation team agreed 
on  the  approach  with  EIF 
and  invited  the  financial 
to 
intermediaries 
contribute. 

v 

The  research  team  asked 
the 
to 
EISMEA 
survey 
to  member 
link 
organisations  

send 

The  research  team  asked 
EISMEA to invite the EEN 
Contact Points to forward a 
survey link to SMEs which 
received  EEN 
support 
services 

The  research  team  asked 
EISMEA 
forward  a 
to 
survey link to intermediary 
final 
agencies 
beneficiaries 
other 
actions 

and 
of 

4,143 

1,200 

The  research  team  asked 
EISMEA and GROW EYE 
team to promote the survey 
and 
to 
the 
entrepreneurs. 

send 

link 

332 This figure is an estimate of the number of responses the survey could target. This value accounts for less than 1% of 
the  total  population  of  final  recipients  of  financial  support  under  COSME  and  the  EIP  (based  on  available  data). 
However, the target takes into account the approach and response rate obtained by the LGF beneficiaries survey from 
the COSME interim evaluation (at that time, the total population of LGF final recipients was equal to 70,000. The 
survey received 356 responses, which represented less than 1% of the population). The target will not include final 
recipients that have been involved in recent evaluations, such as the EFSI ex-post evaluation. 

333  This  figure  is  an  estimate  of  number  of  responses  that  could  be  obtained  by  the  survey  based  on  the  list  of 

intermediaries available at the time when the Inception Report was produced.  

334 Member organisations of the EEN consist of regional development organisations, universities and research institutes, 

chambers of commerce and industry and innovation agencies. 

151 

 
 
 
 
The results achieved in terms of response rate are in line with past consultation exercises. 

As  part  of  the  consultation  strategy,  the  supporting  study  team  carried  out  6  targeted 
consultations via online surveys, tailored to 6 different groups of stakeholders, covering 
different interventions of the COSME programme and the EIP. 5 of the surveys covered 
COSME. These were used to obtain evidence on the programmes and key interventions. 
The  evidence  gathered  complemented  the  statistical  analysis  and  the  results  of  the 
secondary research and interview programme.  

All surveys operated on-line from 7 August to 25 September 2023 (with exception of two 
surveys LGF and SMEG (EIP) guaranteed loans were kept live until 27 September 2023, 
to obtain more responses). 

The online surveys targeted  different  stakeholders relevant  to  either strand of the study 
(COSME and EIP) or both. These included: SMEG and LGF financial intermediaries and 
final recipients of support, EEN member organisations and SMEs clients, EYE host and 
new entrepreneurs, as well as providers and beneficiaries of other COSME/EIP co-funded 
services  (including  tourism  actions,  clusters,  social  economy  and  others).  The  rationale 
behind the selection of these stakeholder groups was illustrated in the technical proposal. 
The approach was then refined in the inception phase to address the ISG feedback. 

To ensure continuity with past assessments of the programmes, the survey questionnaires 
were  drafted  considering  the  questionnaires  used  for  the  consultation  supporting  the 
COSME  interim  evaluation  and  the  EIP  Final  Evaluation.  These  questionnaires  were 
adapted and refined in order to reflect the specific aims and scope of this study. 

The  survey  questionnaires  were  piloted  and  tested  with  the  Commission’s  Services, 
EISMEA and the EIF. The survey testing and piloting phase lasted from 30 June until 7 
August  2023.  All  comments  and  feedback  received  were  promptly  addressed  and 
contributed to improving the quality of the questionnaires.  

The  research  team  discussed  and  agreed  the  survey  dissemination  strategy  with  DG 
GROW,  EISMEA  and  the  EIF.  In  particular,  the  team  adopted  different  dissemination 
approaches tailored to the survey targets (as summarised in the table below). As regards 
the survey for SMEG and LGF financial intermediaries, the team randomly sampled the 
financial intermediaries, excluding those invited in the interview programme and obtained 
their contact  details from  the EIF. Overall, 102 financial intermediaries were invited  to 
contribute to the survey. As regards the consultation with final beneficiaries of SMEG and 
LGF guaranteed loans, the consultant took the following steps: 

•  They sampled financial intermediaries that will be invited to cascade the survey link to 
their final beneficiaries, based on country, type of institution (commercial bank, leasing 
company, promotional institution, guarantee institution), programme (COSME, EIP) 
and type of support (direct guarantee, counter guarantee, on-lending).  

•  They  randomly  sampled  the  final  recipients  within  their  portfolio,  considering  the 
distribution of SMEs in terms of country and sector (in line with the approach used in 
the COSME Interim Evaluation), and considered the most recent transactions. For the 
selection of final recipients, the following rules applied: 

▪  COSME-LGF: they selected the entire the portfolio if this included less than 500 
SMEs. Otherwise, around 500 companies were  chosen in  order to  maintain the 
distribution of SMEs in terms of country and sector. For the interim evaluation of 

152 

 
 
COSME,  the threshold  was 250.  For this study,  the consultant has doubled the 
threshold to obtain a larger target sample. 

▪  EIP-SMEG: The entire portfolio was selected if the portfolio included less than 
250  SMEs.  If  the  portfolio  was  larger,  the  consultant  chose  around  250  final 
recipients ensuring that the distribution of SMEs in terms of country and sector 
remained the same. The lower threshold for EIP-SMEG is justified by the fact that 
it had less than half of the number of beneficiaries reached by LGF. 

In total, 48 financial intermediaries were asked to cascade the survey link to final 
recipients in their portfolio and were provided with the list of targeted SMEs. The results 
of this sampling and the targets are presented below. 

Table 21: Results of sampling and targets for SMEG and LGF final participants 

Survey to SMEG and LGF final recipients 

A. Number of unique SME beneficiaries 

B. Number of SME in selected FI portfolio 

D. Number of SME sampled 

C . % of potential target over total population (B/A) 

E. % of sampled SMEs over total population (D/A) 

F. % of sampled SMEs over potential target (D/B) 

COSME 

EIP 

864 024 

249 796 

28.9% 

14 092 

1.6% 

5.6% 

388 378 

54 078 

13.9% 

4 941 

1.3% 

9.1% 

Expected N of responses (assuming a response rate between 2% and 5%, 
over D) 

ca. 280-
700 

ca. 100-
250 

Table 22: - Results achieved by targeted consultation and the initial estimates. 

No 

Target groups 

Approach to the 
dissemination  

Initial 
estimate 

Number of 
responses 
received 

1 

Final recipients of SMEG 
and LGF guaranteed loans 

2 

Financial Intermediaries for 
SMEG and LGF 

The evaluation team agreed 
on the approach with EIF and 
invited the financial 
intermediaries to 
disseminate the survey link 
to selected clients in their 
portfolio. 

The evaluation team agreed 
on the approach with EIF and 
invited the sampled financial 
intermediaries to contribute. 

5 000335 

201 

128336 

59 

335  This  was  an  estimate  of  responses  the  survey  could  have  obtained.  However,  the  survey  of  LGF  beneficiaries 
conducted for the COSME interim evaluation received 356 responses, which represented less than 1% of the original 
population. From this perspective, the result achieved is in line with past exercises.  

336 This figure was an estimate of number of responses that could have been obtained by the survey based on the list of 

intermediaries available at inception stage. The result achieved accounts for 57% of targeted population. 

153 

 
  
  
  
 
 
 
No 

Target groups 

Approach to the 
dissemination  

Initial 
estimate 

Number of 
responses 
received 

3 

EEN member 
organisations337 

4 

EEN beneficiary SME clients 

5 

Providers and SME 
beneficiaries of other 
measures (e.g. cluster 
international 
organisations/managers, 
thematic actions including 
tourism, social economy)  

6 

EYE Entrepreneurs (host 
and new entrepreneurs) 

530 

109 

10 000 

67 

110 

Not known 
(the survey 
addressed 
different 
stakeholders) 

4,143 

1,200 

EISMEA disseminated the 
survey link to member 
organisations  

EISMEA invited EEN member 
organisations to forward a 
survey link to SMEs which 
received EEN support  

EISMEA forwarded the survey 
link to intermediary agencies 
and final beneficiaries of 
other actions.  

EISMEA and DG GROW EYE 
team disseminated the 
survey link to intermediary 
organisations and final 
beneficiaries, entrepreneurs. 
The survey link was posted 
on programme social media, 
and in the alumni section of 
the EYE platform. 

The number of responses obtained through the different surveys are in line with the results 
achieved in previous consultations about the programme. It should also be noted that the 
surveys  were  launched  and  carried  out  during  the  summer  period.  Given  the  limited 
participation of targeted audiences over the month of August, the team adopted all possible 
mitigation measures to achieve a good response rate. These included: collaborating closely 
with  the  Commission,  EISMEA,  EIF  to  identify  and  activate  multiple  dissemination 
channels, sending follow-ups to encourage participation, extending the survey deadlines 
and enhancing the involvement of intermediary organisations in the survey dissemination 
process. Furthermore, the survey for final recipients of SMEG and LGF guaranteed loans 
was translated into French, Italian, German and Spanish to facilitate participation. These 
measures  significantly  increased  the  survey  response  rate  in  September  (with  the  EYE 
survey achieving particularly good results).  

Interview Programme  

As part of the consultation plan for the study, the consultant conducted 72 interviews with 
key stakeholders (surpassing the initial target of 45-60). These include scoping interviews 
with EC officials and interviews with financial intermediaries, funds, investee companies 
and other participants in thematic actions. On several occasions, they conducted interviews 

337 Member organisations of the EEN consist of regional development organisations, universities and research institutes, 
chambers of commerce and industry and innovation agencies. The number of responses obtained is approximately 
20% of the population. 

154 

 
 
 
 
with multiple stakeholders, counting them as single interviews. The interview programme 
complemented the desk research and the review of monitoring data.  

The  interview  programme  and  target  groups  were  refined  by  the  consultant  during  the 
Inception and Data Collection Phases. Initially the plan also included financial entities that 
did not apply to COSME financial instruments. This target was removed due to the lack of 
information and records on intermediaries who did not apply or were rejected.  

Another important change relates to the consultation of COSME – EFG and EIP – GIF 
funds and investee companies. The original consultation strategy presented in the Inception 
Report  foresaw  separate  targeted  consultations  (surveys)  for  intermediaries  and 
beneficiaries of equity support. During a project meeting, the EIF suggested not conducting 
a survey of fund managers, given that another survey was planned for the summer and the 
population  was  limited  (23  people).  Instead,  they  proposed  conducting  more  in-depth 
interviews with a sample of fund managers. Similarly, the EIF recommended replacing the 
survey for investee companies with more in-depth interviews about additionality, costs, 
and the impact of support received by a sample of beneficiaries. The primary reason for 
this change was to mitigate the risk of survey fatigue among beneficiaries. Consequently, 
the  consultants’  team  sampled  fund  managers  and  investee  companies  and  conducted 
interviews with them. The table below provides an overview of the stakeholders involved 
in the interview programme. 

Table 23: Overview of the interview target groups 

Interview target 

Interviews 

Performed 

1.  Representatives  from  EU  institutions  and  bodies  (DG  GROW,  DG  ECFIN, 

3-5 

EIF, EISMEA) 

2.  MS  Competent  Authorities  and  Agencies  (including  agencies/ministries  in 

7-10 

charge of delivering SME support) 

3.  EIP SMEG / COSME LGF Financial Intermediaries  

4.  EIP GIF / COSME EFG Funds  

5.  EIP GIF / COSME EFG Investee companies 

6.  Providers and partners of COSME/EIP co-funded services to SMEs (e.g. EEN 
member  organisations,  EYE  support  office,  cluster  managers,  NGOs/civil 
society  relevant  to  the  social  economy)  and  representatives  from  different 
categories of stakeholder organisations (e.g. Business Support Organisations, 
associations)338 

17-20 

7-15 

2-5 

10-15 

9 

7 

21 

7 

5 

23 

Total 

45-60* 

72 

* This was the original target set before adding EIP GIF / COSME EFG stakeholders to the interview programme. 

The following sections provide details on the performed interviews and the sampling of 
financial support stakeholders. Section 1.5 of this report contains the interview 
checklists. It should be noted that these checklists were tailored to the specific 
interviewee during the interview. 

Where  possible,  the  consultant  tried  to  create  synergies  between  the  research  activities 
supporting  the  final  evaluation  of  COSME  and  the  ex-post  evaluation  of  the  EIP. 
Therefore, in the interviews reported below the consultant asked questions relating to both 
COSME and the EIP. 

338 These stakeholders are at the same time beneficiaries of the programme but also partners in the provision of services 

to SMEs.  

155 

 
 
Table 24 - Scoping Interviews 

Entity 

Thematic scope 

EC 

EC 

EC 

EC 

EC 

EC 

EEN  

EEN (COSME and EIP) 

COSME Financial instruments 

EIP Financial instruments 

COSME (all actions) 

EIP (all actions) 

EISMEA 

Competitiveness and 
internationalisation actions 

EISMEA  COSME (all actions) 

EIF 

COSME Financial instruments 

SMEG339 / LGF Sampling and Interviews 

A total of 21 financial intermediaries contributed to the study. The selection was made 
considering several criteria: including the programme covered (EIP/COSME), geographic 
diversity, different categories of financial intermediaries. To prevent consultation fatigue, 
intermediaries who were recently interviewed for other evaluations were excluded from 
the list. The sample was approved by the EIF who helped establish initial contact with the 
selected  financial  intermediaries.  The  resulting  interviewee  sample  is  not  fully 
representative of the entire financial intermediaries’ population because in some countries 
existing intermediaries had either very tiny portfolios or had no longer active relationships 
with  the EIF. However,  intermediaries that were  not  selected for the interviewees were 
reached out though the targeted consultations.  

The selected financial intermediaries were also invited to complete a survey and provide 
structured feedback. The interviews offer more flexibility in data collection and allow to 
delve into contextual aspects that are not covered by the survey questionnaire. 

Table 25 – Overview of selected financial intermediaries 

Financial Intermediary 

Programme 

Country 

Type of support 

COSME / EIP  Austria 

COSME 
EIP 

COSME 
COSME / EIP 

Romania 
Malta 

Portugal 
Slovakia 

Counter 
Guarantees  
Direct Guarantees  

Type of Financial 
Intermediary 
Guarantee Institution  

Commercial Bank 
  Commercial Bank 

Direct Guarantees  
Direct Guarantees  

Promotional Institution 
Commercial Bank 

Austria Wirtschaftsservice 
GmbH 
Banca Transilvania S.A. 
Bank of Valletta P.L.C. 

Caixa Geral de Depósitos S.A. 
Ceskoslovenska obchodna 
banka, a.s. 
CM-CIC Leasing Solutions 

COSME / EIP 

France 

Direct Guarantees  

Leasing Company 

Franfinance SA 
Ethniki Trapeza Tis Ellados A.E. 
Byggdastofnun 

COSME 
COSME 
COSME 

France 
Greece 
Iceland 

Direct Guarantees  
Direct Guarantees  
Direct Guarantees  

Leasing Company 
Commercial Bank 
Guarantee Institution  

K&H Bank 
KfW Bankengruppe 

COSME 
Hungary 
COSME / EIP  Germany  On-lending 

Direct Guarantees  

Commercial Bank 
NPB 

339 SMEG is the SME Guarantee Facility, a financial instrument providing loan guarantees to stimulate the 

supply of debt finance to SMEs under the EIP Programme (2007-13).  

156 

 
 
Národní rozvojová banka, a.s. 

COSME 

Czechia 

Credito Emiliano S.p.A. 
Nuevo MicroBank S.A.U. 

COSME 
COSME / EIP 

Italy 
Spain 

Counter 
Guarantees  
Direct Guarantees  
Direct Guarantees  

PKO Leasing S.A. 

COSME / EIP  Poland 

Direct Guarantees  

Guarantee Institution  

Commercial Bank 
Commercial Bank 

Commercial Bank / Leasing 
Company 
Promotional Institution 
Commercial Bank 

PMV Standaardleningen NV 
NLB Komercijalna banka ad 
Beograd 
Privredna Banka Zagreb d.d 

COSME 
COSME 

Belgium 
Serbia 

Direct Guarantees  
Direct Guarantees  

COSME / EIP  Croatia 

Direct Guarantees  

Commercial Bank 

Swedbank AS (Latvia) 

COSME 

Latvia 

Direct Guarantees  

United Bulgarian Bank AD 

COSME 

Bulgaria 

Direct Guarantees  

Vaekstfonden (EIFO) 

COSME / EIP  Denmark 

Counter 
Guarantees / 
Direct Guarantees 

Commercial Bank / Leasing 
Company 
Commercial Bank 

Promotional Institution 

GIF340 / EFG Sampling and Interviews 

Overall,  7  out  of  the  selected  15  funds  contributed  to  the  interview  programme.  The 
selection was informed by the following criteria: country coverage, programme coverage 
(EIP/COSME),  fund  size,  beneficiary  coverage,  venture  capital  or  private  equity,  fund 
generation.  To  mitigate  the  risk  of  consultation  fatigue,  funds  who  were  recently 
interviewed  for  other  evaluations  were  excluded  from  the  list.  The  sample  for  the 
interviews was discussed and agreed with the EIF who helped establish initial contact with 
fund managers.  

Table 26: Funds that contributed to the interview programme 

Fund Name 

Arx CEE IV 

Bullnet Capital Fund II 

Fund Manager 

Country 

Strategy 

Programm
e 
COSME 

ARX Equity Partners 
B.V. 
Bullnet Gestión SGECR  EIP 

Netherland
s 
Spain 

CapHorn 2, FPCI 

CapHorn Invest 

COSME 

France 

EMH Digital Growth Fund GmbH & Co. 
KG 
HPE PRO Institutional Fund 

HPE Growth B.V. 

EMH Partners GmbH 

COSME 

Germany 

MVP Fund II GmbH & Co. KG 

MVP Management 

SET Fund II C.V. 

SET Management B.V. 

COSME 

EIP 

EIP 

Netherland
s 
Germany 

Netherland
s 

Furthermore, for every fund manager, the consultants’ team extracted a random sample of 
final beneficiaries. In total, 4 interviews with representatives from five investee companies 
were conducted. 

Table 27: Final beneficiaries that contributed to the interviews 

Fund Name 
Electrochaea GmbH 

Fund Manager 
MVP Fund II GmbH & Co. KG 

Programme 
CIP 

Country 
Germany 

340 GIF is the High Growth and Innovative SME Facility, a financial instrument providing equity financing 

under the EIP Programme (2007-13).  

157 

Private Equity 

Venture 
Capital 
Venture 
Capital 
Venture 
Capital 
Private Equity 

Venture 
Capital 
Venture 
Capital 

 
 
As good as new 
Knowledge Development for POF S.L. 
+ Knowledge Development for Rugged 
Optical Communications SL  

MVP 

Bullnet Capital Fund II 

Fenestra Wieden s.r.o. 

ARX CEE IV 

CIP 

CIP 

COSME 

Germany 

Spain 

Czech 
Republic 

Interviews with COSME and EIP Providers and Beneficiaries  

The  consultants’  team  contacted  100  providers  and  beneficiaries  of  COSME  and  EIP 
actions. This included intermediary organisations, agencies, bodies and other participants 
in COSME and EIP interventions as well as final beneficiaries.  

Table 28: Providers and beneficiaries of COSME and EIP evaluations interviewed 

Entity 

Thematic scope 

Agency for Development and Innovation of the Nouvelle-Aquitaine 

Antik Art LLC  

BIZGARDEN SRO 

Chamber of Commerce and Industry of the Republic of Moldova 

Center for Technology Transfer and Innovation (CTT) 

Municipality of Vila Nova de Famalicão - Portugal 

Municipality of Buti - Italy 

Consorzio Materahub - Cultural and Creative Industries 

DITECFER – District of Railway Technologies 

Bourgogne Franche-Comté Chamber of Commerce and Industry 

Business House Central Jutland - Denmark 

ESBA - European Small Business Alliance 

Estonian Health Insurance Fund 

G.A.C. Group - Innovation & Performance for Impact 

European Innovation Council and SMEs Executive Agency (EISMEA) 

Federturismo Confindustria 

IAPMEI - Agency for Competitiveness And Innovation 

Instituto Tecnologico de Canarias 

Interreg Europe Policy Learning Platform 

IT Solution 

Center for Security Studies (KEMEA) 

Latvian Technological Center foundation 

NEST Tourism Innovation Centre 

NorthDenmark EU Office 

Public Procurement Policy Group – Ministry of Defence 

SMEUnited 

VDI/VDE Innovation + Technik GmbH 

Financial Services Specialist Group, Vienna Chamber of Commerce 

Municipality of Reggio Emilia 

REVES- European Network of cities and Regions For The Social Economy. 

158 

Tourism 

EYE 

Tourism 

EEN 

EEN 

Social Economy 

Social Economy 

EYE 

Competitiveness 

EEN/EYE 
EYE 

EYE 

Public Procurement 

Cluster action 

Public Procurement 

Tourism 

EEN 

EYE 

Internationalisation 
EYE 

Public Procurement 

EEN 

Tourism 

EEN 

Public Procurement 

Business support 

Competitiveness 

EEN 

Social Economy 

Social Economy 

 
  
 
 
 
 
ANNEX  VI.  ADDITIONAL  INFORMATION  ON  THE  IMPLEMENTATION  OF  THE 
PROGRAMME, INCLUDING COUNTRY INFORMATION  

A.  COSME Interim Evaluation recommendations and how they were addressed 

Table 29: Interim evaluation recommendations and how they were addressed  

Interim Evaluation of COSME - Recommendations 
Recommendation  1:  The  Commission  should  carefully  explore  ways  to  improve  COSME's 
alignment with EU policy goals relating to the improvement of EU global competitiveness and 
sustainable and inclusive growth. COSME serves as Europe's programme for small and medium-
sized  firms.  SMEs  are  essential  to  achieving  these  EU  policy  goals,  as  several  studies  and 
initiatives on policy have shown. 

Recommendation 2: A stronger emphasis on industrial competitiveness would make it easier 
for the COSME programme to be more fully integrated into all of DG GROW's initiatives and 
strategies. 
Action taken to address Recommendations 1 and 2: Increased attention was paid to actions 
for supporting competitiveness, and sustainability (including actions for industrial ecosystems) 
in the latter years of the programme, including several substantial calls for clusters projects. 
The EEN and the Commission worked on a medium-term strategy for revamping EEN's services 
and service delivery models to ensure that it could meet the changing needs of SMEs. A central 
feature  of  this  new  approach  was  a  focus  on  SME  clients'  needs  and  a medium-term  client 
journey with more in-depth services to support SME competitiveness and internationalisation. 
Towards  the  end  of  the  programme,  EEN  also  progressively  built  capacities  for  providing 
sustainability advisor services and started delivering these services on a small scale. 
Recommendation  3:  The  programme  should  be  able  to  limit  or  even  prevent  financing  for 
specific  standalone  activities  and  guarantee  the  integration  of  smaller  actions  within  the 
broader programme portfolio with a better description of the COSME priority areas and the 
boundaries  of  its  duties.  It  is  advised  that  the  Commission  think  through  the  best  ways  to 
increase COSME's comparative cost-effectiveness. 
Action taken to address Recommendation 3: The process for screening actions and drafting 
the work programme improved throughout the programme (also taking account of advice from 
EISMEA on the scope for enhancing cost-effectiveness: size of calls, number of projects, etc.). 
Nevertheless, the supporting study found that some smaller actions from the latter years of 
the programme had a weaker link with overall programme goals. 
Recommendation 4:  To promote  better COSME programme management  efficiency  and an 
improved ability for a quality execution of the monitoring and evaluation role, the Commission 
must adopt a more consolidated approach to data management. 
Action  taken  to  address  Recommendation  4:  A  review  of  data  for  the  evaluation  study 
confirmed  that  the  quality  of  data  gathering  and monitoring  reports  improved in  the  latter 
years of the programme allowing more complete reporting to be provided on the coverage of 
the  activities,  outputs  and  state  of  play,  also  for  smaller  actions.  However,  the  quality  and 
completeness of the data on beneficiaries remains sub-optimal with the exception of the larger 
actions.  For  example,  this  was  the  case  for  secondary  beneficiaries  (i.e.  SMEs)  within  the 
Clusters programmes and internationalisation. 
Recommendation 5: The COSME's integration with other EU projects and its synergies/added 
value with national and regional programmes and policies might both be strengthened by the 
Commission. 

159 

 
 
  
Action taken to address Recommendation 5: Progress has been achieved with internal and 
external  synergies,  in  particular  for  larger  actions  such  as  EEN,  financial  instruments,  the 
international SME IP helpdesks, and the EU Japan Centre.  
Recommendation 6: We advise the Commission to direct the programme's resources towards 
those  areas  of  intervention  where  they  will  have  the  greatest  impact  in  the  line  with  the 
mandate of COSME. 
Action taken to address Recommendation 6: A large proportion of the budget was allocated 
to flagship actions which had demonstrated their impacts such as the financial instruments and 
EEN. 

B.  Further information on implementation - SO1 - Access to finance 

The Loan Guarantee Facility (LGF)  

Figure 6: Number of LGF operations signed and financial intermediaries by country 

The  163  guarantee  agreements  were  signed  by  financial  intermediaries  located  in  35 
countries. Since some of the agreements have terminated, the following analyses are based 
only on the 157 active ones. As shown in the figure above, the countries with the highest 
number of active guarantee agreements are Italy,341 France,342 Bulgaria,343 and Romania.344 
The  only  COSME  Participating  Country  where  no  agreement  was  signed  is  Cyprus. 
Among eastern neighbouring countries, Armenia, Moldova and Ukraine did not participate 
in the COSME financial instruments, although they had signed an International Agreement 
under  the  COSME  programme,  whereas,  in  Malta  and  North  Macedonia,  the  signed 
guarantee agreement did not generate any financing as of December 2022. 

Concerning the type of financial intermediaries that signed agreements, two considerations 
emerge.  The  role  of  National  Promotion  Banks  and  guarantee  institutions  has  been 
instrumental in facilitating participation in the programme in certain countries. This holds 

341 28 active agreements (18%) signed by 20 distinct financial intermediaries (16%). 
342 15 active agreements (10%) signed by 7 financial intermediaries (6%). 
343 11 active agreements (7%) signed by 9 financial intermediaries (7%). 
344 9 active agreements (6%) signed by 8 financial intermediaries (6%). 

160 

 
 
 
 
true not only for countries that exclusively participated through their NPBs but also for 
Belgium, Bulgaria, France, Hungary, Italy and Poland. 

Regarding the involvement of leasing companies in the LGF, their participation in some 
cases (e.g., France, Netherlands) was influenced by the specific characteristics of national 
guarantee programmes. These programmes either do not consider these intermediaries as 
eligible for financing, or the terms at which these programmes are offered do not align well 
with the business model of leasing companies. 

Out  of  the  157  active  guarantee  contracts  signed,  92  (59%)  aimed  to  provide  direct 
guarantees,  51  (32%)  counter  guarantees,  9  (6%)  an  SME  Initiative  Securitisation 
Instrument, and 5 (3%) on-lending.  

Although  commercial  banks  signed  a  larger  number  of  guarantee  contracts,  guarantee 
institutions  and  promotional  banks,  by  providing  counter-guarantees  through  sub-
intermediaries, managed to  generate a significantly  higher number of transactions, with 
56%  of  the  LGF  final  recipients  receiving  support  through  counter-guarantees 
(almost twice as many final recipients as those reached by commercial banks (guarantees).  

The reasons for the higher results of the counter-guarantees are several. On one hand, on 
average, counter-guarantees provide for a higher leverage of the budget committed to an 
individual  transaction  (calculated  as  total  supported  lending  to  SMEs,  divided  by  the 
COSME  LGF  budget  committed).  This  is  achieved  thanks  to  the  additional  guarantee 
layers present in the structure, with each additional layer mobilising additional resources 
alongside  the  COSME  LGF  resources.  On  the  other  hand,  while  a  greater  number  of 
contracts were signed under the direct-guarantee structure, the value of these contracts is 
lower with ca. 57% of the budget having been signed under counter-guarantee. 

LGF Final recipients 

The LGF supported 865 387 distinct SMEs (i.e. final recipients) as of 31 December 2022. 
The  countries  with  the  highest  number  of  final  recipients  are  Italy,  France,  Spain,  and 
Poland.  The  geographical  distribution  of  supported  SMEs  is  mainly  determined  by  the 
number of agreements signed in each country and the size (maximum portfolio volume) of 
these agreements. In addition to this there were other factors at play, such as the average 
size of loans the EIF agreed with the financial intermediaries in the different countries. As 
shown in the Figure below, in general, the larger the maximum portfolio volume signed, 
the larger the number of SMEs supported in each country. 

161 

 
Figure 7: LGF final recipients and maximum portfolio volume signed by country 

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Axis Title

Maximum Portfolio Volume (mEUR)

N. Eligible final recipients

Source: Consultant’s own elaborations on COSME LGF Quarterly Report as of 
31/12/2022 

Figure 8: LGF final recipients as a percentage of all SMEs in each country 

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Size of investment and size of business supported 

The relationship between the average size of final recipient transaction (i.e., average ticket 
size)  and  the  GDP  per  capita  across  Member  States  highlights  that  there  are  strong 
differences across countries. On the one hand, in France and the UK, where the GDP per 
capita is more than EUR 30,000, the average size of final recipients’ transaction was less 
than EUR 25,000. On the other hand, in Albania and Bulgaria where the GPD per capita 
is respectively EUR 4,700 and EUR 8,900, the average ticket size was EUR 102,000 and 
EUR 119,000.. This heterogeneity of ticket sizes is mainly driven by the different strategies 
implemented  by  the  intermediary  banks,  which  in  some  cases  mainly  lend  to  micro-
enterprises, while in others also targeted other SMEs with larger loans. 

162 

 
 
 
 
 
 
 
 
 
 
 
 
 
As far as the size of final recipients is concerned, most firms reached by the programme 
are micro-enterprises, i.e., they have less than ten employees. These firms represent 89% 
of the final recipients reached by the LGF. Small (10-50 employees) and medium (50-250 
employees)  enterprises  account  for  10%  and  1%  of  the  number  of  SMEs  financed 
respectively. Overall, 50% of the firms financed under the LGF are sole proprietors. 
This is not unexpected given that the LGF set a EUR 150,000 loan threshold above which 
intermediaries  had  to  apply  a  special  procedure  to  verify  the  company  eligibility  for 
financing under the LGF. 

Number of enterprises supported by sector 

A quarter of final LGF recipients (SMEs) operated in sector G, “Wholesale and retail 
trade, repair of motor vehicles and motorcycles”, in almost all countries supported345. The 
second  most  common  sector  was  sector  C  “Manufacturing”,  followed  by  sector  F 
“Construction”.346 Overall, the sectoral distribution of LGF final recipients is in line with 
the distribution for SMEs in Eurostat Structural Business Statistics (SBS). It reflects the 
sectors where SMEs, and in particular micro-enterprises, are mostly active.  

Figure 9: Number of final recipients by Sector (NACE level 1) 

Source: Elaboration for the supporting study on EIF monitoring data 

Equity Facility for Growth 

Under the EFG agreements were signed with  21 selected funds located in 17 countries. 
Typically, operations within one country are provided by a single fund. However, multiple 
funds signed operations in Bulgaria, Germany, the Netherlands and Portugal. Out of the 
21  funds,  the  majority  (14)  focused  on  the  expansion  and  growth  stage only,  while  the 

345 There were some differences in sector coverage between countries as further described in Annex VI. 
346 NACE code sectors, following the classification applied by Eurostat 

163 

 
 
 
remainder were multi-stage (as also co-invested by InnovFin): six funds offered venture 
capital, while only one fund provided private debt. 

Figure 10: Core EFG eligible final recipients and total amount invested by legal country 

258

14

11 10
53

8
62 55

72
7

7
28

6
41

6

5

4
4
29 20 28 25 24

4

4

6

3

25 21 18 21
2
1

2

11
1

9

1

7

1

1

5

1

5

1

0

Total amount invested (EUR, million)

EFG final recipients

COSME  EFG  eligible  final  recipients’  headquarters  were  located  in  23  different 
countries. The countries with the highest number of EFG final recipients’ headquarters 
were  Germany  (14,  13%),  France  (11,  11%),  and  Finland  (10,  10%),  followed  by  the 
Netherlands (8, 7%), Greece (7, 6%) and Ireland (7, 6%). In 15 countries, less than five 
SMEs received investment. This distribution is in line with the overall distribution of EIB 
group347’s equity operations in the period 2010-2021. For the EIB group’s operations in 
general, funding was concentrated in a few countries notably the UK, France, Germany 
and Sweden. 

The study notes that when these investment flows are compared to the size of the equity 
markets in the respective country, it emerges that the EIF provided significant support to 
companies in Member States with less mature and underserved equity markets. 

EFG – average size of investments and size of businesses supported 

The majority of investments made in EFG final recipients were below EUR 10 million 
(47% of the firms received between EUR 5 and EUR 10 million, while 34% received less 
than 5 million. This is in line with the average ticket size348 in the EU market. 

The  majority  of  investments  made  in  EFG  final  recipients  were  below  EUR  10 
million. In particular 47% of the firms received between EUR 5 and EUR 10 million, while 
34% of the beneficiaries received less than 5 million. By way of casting some light on this 
range,  the  2019  report  of  the  European  Court  of  Auditors349  on  centrally-managed  EU 
interventions for VC shows that EU-backed VC funds have invested, on average, EUR 1.4 
and  EUR  2.6  million  per  SME  in  the  seed  and  start-up  stages  respectively,  while  the 

347 The EIB group refers to both the EIB and the EIF. 
348 In the interviews for the study EFG backed investors/ Fund managers reported that depending on the investment round 

(e.g., seed, series A, Series B) or the investee life-cycle, the ticket size varies between EUR 1 to EUR 8 million. 
349 ECA. 2019. Centrally managed EU interventions for venture capital: in need of more direction, Special report. 

164 

 
 
 
average investment in the growth and buy-out stages per SME were EUR 4.9 and EUR 7.2 
million respectively.  

Figure 11: Distribution of final recipients by invested amount, million EUR 

35

49

11

4

2

[0, 5]

(5, 10]

(10, 15]

(15,  20]

(20, 25]

3

>35

Source: Own elaborations on EIF monitoring data 

EFG – Main sectors supported 

Most EFG final recipients are in the “Computer and Consumer Electronics” or  “Business 
and industrial products” sectors. Differently from LGF investments, EFG tended to target 
SMEs which are young fast-growing innovative firms. Their innovation-oriented risk 
profile and business model often made it impossible for them to obtain financing from the 
traditional financial intermediation system.350  

Figure 12: Number of EFG final recipients by sector of activity 

29

16

14

12

9

6

Computer and Consumer Electronics

Business and industrial products

Consumer Goods and Retail

Communications

Life Sciences

Consumer Services: Other

Energy and Environment

Chemicals and materials

Construction

Financial Services

Transportation

Real estate

Agriculture

4

4

3

2

2

1

1

Source: Elaborations for the supporting study on the EIF database extract 

350 In exchange for the higher risk, these instruments offer higher expected returns to investors– usually beyond the profit-
generating capabilities of traditional SMEs. These innovative firms also tend to rely heavily on intangible assets that 
often cannot be used as collateral for loans. 

165 

 
 
 
 
Pan European VC Funds of Funds 

In 2016 the Commission launched the Pan European VC Funds of Funds initiative. The 
targeted Funds-of-Funds act as financial intermediaries and, instead of directly investing 
in  firms,  they  invest  in  other  funds  which  in  turn  finance  the  final  beneficiaries  of  the 
programme.  Under  this  initiative  two  operations  were  signed  with  multi-country  funds 
based in Luxembourg and EFG committed respectively EUR 12 and 33 million to these 
funds. These investments corresponded to 14% and 12% respectively of the size of these 
intermediaries. Together the two Funds-of-Funds supported a total of 45 funds. 

The  funds  that  the  Funds-of-Funds  invested  in  made  460  investments  into  418  distinct 
COSME  eligible EU target  investees (companies that were eligible under this scheme). 
They were also allowed to invest in businesses in other countries (without EU support) in 
order to balance the overall risk in their portfolio. 

The Pan European VC Funds-of-Funds initiative supported an overall investment of EUR 
3.1 billion in the targeted firms. It has to be noted however, that some funds are still in 
the investment  period, therefore additional investments  are expected. As from  2018 the 
invested amount ramped up with a considerable peak in 2021.  

Figure 13: Total amount invested in EFG eligible EU target investees by year, million EUR    

Source: Elaborations by the consultant for the supporting study on EIF database extract 

The EFG participation in the Pan European VC Funds of Funds far surpassed the 
EFG intended leverage effect. In fact, while the targeted leverage effect for the signed 
operations was between 4 and 6 as per COSME Regulation,351 the leverage effect obtained 
through the Funds-of-Funds operations equals 69.3352. 

As far as the COSME EFG eligible EU Target Investees are concerned, their headquarters 
are based in 22 distinct countries. As underlined above the eligibility criteria also include 
companies whose legal country is not a COSME Participating Country (companies with 
headquarters outside EU), as long as it is operating in the EU. The country where the largest 
number  of  beneficiaries  were  reached  are  Germany  (with  29%  of  the  total),  United 
Kingdom (17%) and France (16%). These are followed by United States (11%) and the 
Netherlands (7%). The top five countries in terms of the number of final recipients are also 
the top five countries in terms of the total amount invested. 

351 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013R1287  
352 Ratio of the total invested amount by the intermediaries over the total EFG commitment. 

166 

 
 
 
 
As shown by the figure below, on average the amount invested in the companies is smaller 
as compared to the core COSME EFG operations. Most of the firms received investments 
worth less than EUR 5 million (65%). In particular 191 investments (42%) amounted to 
less than EUR 1 million. This figure is particularly surprising considering that among the 
eligible  final  recipients  benefitting  from  the  core  COSME  EFG  operations  only  2 
investments (2%) were worth less than EUR 1 million. This can be explained by the size 
of the companies receiving the investments, as explained in the next paragraph. 

Figure 14: Distribution of COSME EFG eligible EU Target Investee by financed amount 

300

l

a
n
i
f

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e
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N

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e
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a
i
c
i
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43

40

26

25

8

6

[0, 5]

(5, 10]

(10, 15]

(15,  20]

(20, 25]

(25, 30]

(30, 35]

EUR, million

12

>35

Source: Elaboration for the supporting study based on an EIF database extract  

When considering the firms’ size, it is noteworthy that, differently from beneficiaries of 
core EFG operations, the majority of investments made under the Pan European VC Funds-
of-Funds  initiative  were  directed  to  small  enterprises  (i.e.,  10-50  employees),  which 
accounted  for  35%  (155  firms)  of  the  eligible  final  recipients.  Micro  and  medium 
enterprises instead accounted respectively for 28% (115 firms) and 19% (91 firms) of the 
eligible final recipients.  Finally, for 64 companies (13%) the headcount was not available 
while in 23 cases (5%) the final recipients counted more than 249 employees, therefore 
falling into the Mid-cap category. Nevertheless, note that the headcount might have grown 
since the time of first investment, therefore making some enterprises, which must had been 
SMEs at the time of the investment, change their size category. 

As far as the sector of activity is concerned instead, the sector where the largest number of 
firms is active is the “Computer and Consumer Electronics” (with 37% of the firms for 
which the information is  available), the same  as  that of the  core COSME  EFG eligible 
beneficiaries. The second most common sector is instead the Life Sciences sector (16%) 
followed by the Financial Services (12%). Note that these two sectors only represented 9% 
and 2% of the core COSME EFG eligible beneficiaries respectively. 

167 

 
 
 
 
Figure 15: Number of COSME EFG eligible EU Target Investees by sector of activity 

Source: Elaboration for the supporting study based on an EIF database extract 

Country distribution and sectors 

The headquarters of the COSME EFG eligible EU Target Investees are based in 22 distinct 
countries (including non COSME Participating Countries). The countries with the largest 
number  of  EFG  eligible  EU  Target  Investees  are  Germany  (29%  of  the  total),  United 
Kingdom (17%) and France (16%). These are followed by United States (11%) and the 
Netherlands (7%). 

Generally, the invested amount is proportional to the number of firms reached.  

The  main  sector  benefiting  from  the  Funds-of-Funds  is  “Computer  and  Consumer 
Electronics” (37% of the firms for which sector information is available), the same as for 
the core COSME EFG eligible beneficiaries. The second most common sector is the Life 
Sciences sector (16%) followed by Financial Services (12%). Note that these two sectors 
only represented 9% and 2% of the core COSME EFG eligible beneficiaries respectively.  

C.  Further information on implementation - SO2 - Access to markets 

Table  32:  SO2  -  Actions,  calls,  projects,  total  cost,  EU  contribution,  and  benefitting 
organisations by thematic area 

Actions 

N Calls 

Total costs 

Maximum EC 
grant amount 

N. projects 

Beneficiaries 

Business support networks and services total 

Enterprise Europe Network 

Awareness-raising 
entrepreneurs 
Points of Single Contact 

on 

for 
the 

EU SME Centre in China 

Information  Platform  on 
Parcel  Delivery  Services  to 
reduce  barriers 
to  e-
commerce 

10 

1 

1 

1 

663 345 624.4 

367 277 676.5 

518 

664 

61 801 

46 350 

1 333 253 

1 199 925 

526 718 

360 000 

1 

1 

1 

2 

3 

5 

168 

 
Actions 

N Calls 

Total costs 

Maximum EC 
grant amount 

N. projects 

Beneficiaries 

International 
property SME helpdesks 

intellectual 

and 
Pre-Diagnostic 
IP 
Improving Access to Patent 
Protection  for  Innovative 
EU SMEs. 

SME Internationalisation 

of 

Co-financing 
public 
procurement of innovation 
consortia 

links 

the 
Creating 
facilitation 
public 
procurement of innovation 

for 

of 

access 
on 

to 
Facilitating 
regulations 
light 
remotely  piloted  aircraft 
systems 

Improving  SMEs  Access  to 
Cross-Border 
Public 
Procurement 

Supporting European SMEs 
to  participate 
in  public 
procurement outside EU 

Training  for  SME-friendly 
policies 
central 
in 
purchasing bodies 

1 

1 

1 

2 

2 

1 

1 

1 

4 

10 209 423 

9 188 481 

4 548 231 

4 084 186 

356 537 

264 568 

Public procurement 

5 017 792 

7 172 257 

2 380 299 

2 099 835 

1 147 680 

1 032 912 

1 250 439 

937 220 

2 967 996 

2 225 993 

1 388 424 

1 249 577 

4 

1 

2 

4 

3 

1 

4 

6 

4 

15 

2 

1 

26 

13 

8 

22 

18 

2 

Source: Elaboration for the supporting study based on EISMEA data 

The  geographical  distribution  of  EU  grants  for  SO2  was  well  aligned  with  the 
distribution  of  participants  by  country.  Most  of  the  EU  contribution  was  granted  to 
participants  based  in  Spain,  the  United  Kingdom,  and  France.  Concerning  the  different 
countries involved in international projects, it is interesting to note that in most of the cases 
the  participants  were  from  multiple  EU  countries.  Five  projects  involved  organisations 
located in non-COSME participating countries, namely in Brazil, China, Chile, Mexico, 
Thailand  and  Vietnam,  which  were  supporting  EU  enterprises.  These  organisations 
received  considerable  amounts  for  activities  supporting  the  internationalisation  of  EU 
enterprises to those third countries. 

169 

 
Figure 16 : Total COSME SO2 funding by participants’ country (excluding EEN) 

7,6

5,7

2,3

1,9

1,8

1,5

1,2

1,1

0,8

0,7

5,2

EU contribution, m EUR

Source: Elaboration for the supporting study based on data from EISMEA.  

A general overview of these actions is provided in the body of the report. Some further 
information on EEN is given below.  

Enterprise  Europe  Network  members  are  situated  in  all  EU  Member  States  and  other 
countries participating in the COSME programme. And they provide services in all regions 
of these countries.353 The number of organisations participating in EEN consortia varies 
from one country to another, either because of the size of the country, or because of the 
number of relevant organisations with the necessary operational capacities in the regional 
/ national business and innovation support ecosystem354.  

The  representation  of  the  EEN  around  the  world  is  crucial  to  provide  SMEs  with  the 
services to access global markets (including support for international partner search and 
country  information)355.  The  third  country  members  of  the  EEN  network  (known  as 
“Business  Cooperation  Centres  (BCCs)”  in  the  2014-20  period).  supported  the  EEN 
network with partnership and market information services. There were 73 BCCs in 29 third 
countries and these centres did not receive a grant from the COSME programme.356 

Since 2008, the EEN has supported 2.9 million SMEs by  providing different services 
(including advisory services, partnering services and brokerage events and information on 
EU grants and funding opportunities, Intellectual property rights) thus supporting their 
innovation and growth both within the EU Single Market and globally. EEN’s services 
evolved over time. In 2014, the EEN introduced tailored innovation support for enterprises 
(supported under a separate grant from the Horizon 2020 programme). In 2017, the EEN 
launched targeted scale-up services. By the end of the programme, different services had 
been introduced to support SMEs through digitalisation, sustainability (extending earlier 
services that focused more on green/climate aspects of sustainability) and to help boost 
their resilience.  

353 Typically at NUTS1 level for EU member States (NUTS 2021 classification: Statistical regions in the European Union 

and partner countries — NUTS and statistical regions 2021). 

354 E.g many EEN organisations were located in Italy (11.6%), Germany (10.7%) and Spain (9.8%). 
355 Special Report No 07/2022: SME internationalisation instruments. 
356 These receive non-financial support from the Commission, in the form for instance of technical assistance and access 
to online services. BCC do not rely on financial support from the EU but rather from national authorities elsewhere 
including in third countries. At the end of 2020. 

170 

 
 
 
Table 33: EEN - Calls, projects, total cost, EU contribution, and beneficiary organisations 
by call year 

Call Year 

N Calls 

Total Costs (EUR) 

Maximum EC 
Grant Amount 
(EUR) 

N of 
contracts 

N of benefitting 
organisations 

2014 

2015 

2016 

2017 

2018 

2020 

3 

1 

2 

1 

1 

2 

178 417 151.9 

97 804 863.5 

6 154 598.8 

2 912 171.5 

187 357 828.9 

103 598 787.9 

1 763 751.3 

1 025 533.2 

96 742 152.4 

53 872 308.7 

192 910 141.1 

108 064 011.7 

174 

10 

147 

3 

92 

92 

TOTAL 

10 

663 345 624.4 

367 277 676.5 

518 

Source: Elaboration for the supporting study based on data from EISMEA 

602 

46 

544 

20 

529 

516 

664 

There was a high level of synergies and complementarity between EEN and innovation 
support activities funded through the Horizon 2020 programme (H2020). This included 
the SME Instrument (where the EEN acted as an intermediary between SME beneficiaries 
and coaches), the European Innovation Council – EIC (which provided EUR 10 million of 
funding  for  EEN  partners  to  provide  advice  to  SMEs  for  implementing  projects  and 
enhancing  their  innovation  management  capacities).357  This  was  also  the  case  for  the 
“Innovation in SMEs” (INNOSUP) programme, which offered highly specialised support 
services aiming to complement existing national and regional support initiatives.358 This 
finding  was  confirmed  by  the  desk  research  and  interviews  undertaken  for  this  final 
evaluation. Whereas  H2020 funded the testing  of new approaches for better innovation 
support through funding opportunities for innovation actors across the EU, for instance, 
through  cross-sectoral  SME  projects,  the  EEN  focused  on  entry-level  innovation 
awareness support and innovation capacity building.359 

Single Digital Gateway 

Table 34: KPIs for the Single Digital Gateway 

KPI 

Targets 

Results 

Preparatory study (2018), successful launch 
of beta version (2019), and of the SDG in 
2020 

Beta version: 2019 
SDG: December 2020 

Preparatory  study,  beta  version,  and  SDG 
successfully delivered as planned. 

Number of visits to Your Europe Business  Year on year increase by 

10% 

2019: 7 766 937 
2020: 8 217 193 (increase by 5.8%) 
2021: 7 166 623 (decrease by 12.8%) 

357 Monitoring fiche COSME EEN grants 2020. 
358 European Commission. 2017. Interim evaluation of the COSME programme. 
359 Innovation audits and strategy, advice on IPR, technology and innovation brokerage services and advice on 

technology marketing; Monitoring fiche COSME EEN grants 2020. 

171 

 
 
User  satisfaction  figures  for  the  Your 
Europe  Business  component  of  the  SDG 
(based on user satisfaction surveys360) 

2019: 93% positive rating 
2020: 94% positive rating 
2021: 92% positive rating 
Source: Elaborations by the consultant based on COSME Monitoring Reports 2019 and 2020 

90% positive rating 

D.  Further information on implementation  – SO3 - Framework conditions and 

competitiveness 

Under Specific Objective 3 (SO3) “Improve framework conditions for the competitiveness 
and sustainability of Union enterprises”, COSME supported 21 actions, through 30 project 
calls, and financed 263 projects. While the total cost of these projects amounted to EUR 
127.5  million,  the  corresponding  EU  contribution  amounted  to  EUR  94.8  million. 
Therefore,  the  EU  contribution  represented  about  75%  of  the  total  project  costs.  The 
remaining costs were sustained by projects participants using own resources. 

Table 35: SO3 - Actions, calls, projects, total cost, and EU contribution by thematic area 

Thematic Area 

N. 
Actions 

N. 
Calls 

N. 
Projects 

N. 
Participants 

Total 
costs 
(million, 
EUR) 

EU 
contribution 
(million, 
EUR) 

Competitiveness 

Design of consumer 
goods 

Fashion 

Framework 
conditions 

5 

1 

1 

2 

Internationalisation  1 

Social economy 

1 

9 

2 

1 

2 

5 

1 

58 

10 

4 

3 

78 

7 

257 

27 

25 

27 

283 

10 

32.2 

16.5 

4.5 

1.6 

33.1 

0.5 

Tourism 
Source: Elaboration for the supporting study based on data from EISMEA 

39.2 

103 

546 

10 

10 

25.8 

8.2 

3.4 

1.4 

26.6 

0.4 

28.8 

The actions funded under this specific objective were grouped into seven thematic areas, 
“Internationalisation”,  “Competitiveness”,  “Tourism”,  “Social  Economy”,  “Framework 
conditions”,  “Design  of  consumer  goods”  and  “Fashion”.  Most  of  the  EU  contribution 
went  into  projects  funded  by  actions  related  to  Tourism  (EUR  28.8  million), 
Internationalisation  (EUR  26.6  million),  and  Competitiveness  (EUR  25.8  million). 
Coherently with the fund distributions, these three thematic areas were also those under 
which a high number of calls were launched, and projects funded. Among the actions under 
the “Tourism” thematic area, there is a mix of actions that were funded with small grants 
and    studies,  and  actions  with  larger  grants    e.g.,  “Boosting  sustainable  tourism 
development  and  capacity  of  tourism  SMEs  through  transnational  cooperation  and 
knowledge transfer”. 

The “Internationalisation” thematic area, which is the second in terms of EU contributions, 
includes a single action, the Clusters Go International action. This action is among the most 

360 Further information on the YEB annual user surveys: 
-  2019: 1,349 responses, data gathering period: 11 February to 11 March 2019 
-  2020: 1,354 responses, data gathering period: 3 February to 6 March 2020 
- 2021: 1,634 responses, data gathering period: 1 February to 7 March 2021 

172 

 
 
significant under SO3, having funded 72% of the total number of projects and accounted 
for nearly 26% of the project costs. Through five calls, 78 projects were funded. 

Clusters  bring  together  businesses,  institutions  and  other  economic  actors.  They  help 
enterprises achieve higher levels of productivity and innovation mainly by facilitating the 
exchange of good practices, knowledge and information within networks. There are around 
3,000 specialised clusters in Europe, accounting for 54 million jobs.361  

As regards the project participants, SO3 provided grants to 1,066 participants based in 37 
distinct  countries,  including  both  EU  countries  and  associate  countries.  Overall,  a 
relatively large share of participants was located in Italy (17%), Spain (16%), and France 
(9%) while a minority of participants (45) were located in an associate country (namely, 
Albania,  Bosnia  and  Herzegovina,  Iceland,  Moldova,  Montenegro,  North  Macedonia, 
Norway, Serbia, and Turkey). 

Figure 17: Number of S03 project participants by legal country of the participant 

Source: own elaborations on EISMEA data 

E.  Further information on implementation – SO4 - Entrepreneurship 

Table 36: SO4 - Projects, total cost, and EU contribution by action 

Action 

N 
Call
s 

N 
Project
s 

N 
beneficiaries 

EU 
contribution 
(million, 
EUR) 

Total 
costs 
(million, 
EUR) 

Erasmus for Young 
Entrepreneurs 

8 

83 

360 

58.5 

68.6 

361 According to data from the European Cluster Collaboration Platform (https://clustercollaboration.eu/content/how-

joining-cluster-provides-vital-support-eu-smes).  

173 

 
 
 
The European 
Entrepreneurship 
Education NETwork 

Migrants Entrepreneurs 
best practice exchange 

European Network for 
Early Warning and for 
Support to Enterprises 
and Second Starters 

Social Economy 
Missions 

TOTAL 

1 

1 

1 

1 

4 

1 

1 

12 

22 

111 

17 

32 

92 

4 

505 (478 
different 
organisations) 

0.3 

1.5 

3.6 

2.1 

66.1 

0.5 

1.6 

4.8 

2.4 

77.9 

Source: Elaboration for the supporting study based on EISMEA data 

The actions funded under this specific objective all relate to entrepreneurship and include 
the  following:  “Erasmus  for  Young  Entrepreneurs”,  “European  Network  for  Early 
Warning and for Support to Enterprises and Second Starters”, “Migrant Entrepreneurs best 
practice exchange”, “The European Entrepreneurship Education NETwork”, and “Social 
Economy  Mission”.  As  shown  in  the  Table  below,  the  action  that  funded  the  largest 
number  of  projects  is  “Erasmus  for  Young  Entrepreneurs”  (EYE).  Through  this  action 
EUR  58.5  million  in  EU  contributions  was  granted  to  360  intermediate  organisations, 
participating in 83 distinct consortia, with the aim of promoting and organizing exchanges 
between new and experienced entrepreneurs. The total costs of these projects amounted to 
EUR 68.6 million. The remaining actions funded a very limited number of projects. 

As  far  as  project  participants  are  concerned,  SO4  provided  grants  to  478  organisations 
located in 38 distinct countries. The countries with the largest number of participants are 
Italy  (12.7%  of  the  total),  Spain  (12.5%),  and  Belgium  (6.5%).  Those  are  followed  by 
France (5.3%), Portugal (4.8%) and the United Kingdom (4.8%). It is noteworthy that all 
projects  that  received  a  grant  under  SO4  were  implemented  by  consortia  with  3  to  17 
distinct partners. Moreover, all the consortia included organisations that were located in 
different countries. 

Table 37: SO2-4 Actions, calls, projects, total costs and EU contribution 

Specific 
Objective 

N°  of 
action
s  

of 

N° 
project 
calls 

N° 
of 
projects 

N°  of 
partici
pants 

Total costs of 
projects 
(EUR 
million) 

13 

SO2  (access 
to  markets 
and 
internationali
sation 

781 

27  (of 
which 
10  for 
EEN) 

550 
(518 
for 
EEN) 

694.4    (of 
which 
663.3 
EEN) 

for 

EU 
contribu
tion  as 
% 
of 
total 
project 
costs 
57% 

Total  EU 
contributi
on 
(EUR 
million) 

396,5 
(of 
which 
367.3 
million 
for 
EEN) 

174 

 
 
SO3 
(framework 
conditions) 
SO4 
(entrepreneur
/ 
ship 
entrepreneuri
al culture) 
Total 

21 

30 

263 

1175 

127.6 

94,6 

74,1% 

5 

12 

111 

505 

77.9 

66.1 

84.7% 

39 

69 

924 

2461 

900 

557.4 

61.9% 

F.  Country Information 

The country information included in the previous points is also consolidated in this point 
for ease of reference, together with cross-references to graphs (figures). 

•  LGF financial intermediaries and final recipients: 

-  The 163 guarantee agreements were signed by financial intermediaries located in 
35  countries.  Since  some  of  the  agreements  have  terminated,  the  following 
analyses  are  based  only  on  the  157  active  ones.  The  countries  with  the  highest 
number  of  active  guarantee  agreements  are  Italy,362  France,363  Bulgaria,364  and 
Romania.365  The  only  COSME  Participating  Country  where  no  agreement  was 
signed is Cyprus. Among eastern neighbouring countries, Armenia, Moldova and 
Ukraine did not participate in the COSME financial instruments, although they had 
signed  an  International  Agreement  under  the  COSME  programme,  whereas,  in 
Malta and North Macedonia, the signed guarantee agreement did not generate any 
financing as of December 2022. 

-  Concerning  the  type  of  financial  intermediaries  that  signed  agreements,  two 
considerations  emerge.  The  role  of  National  Promotion  Banks  and  guarantee 
institutions has been instrumental in facilitating participation in the programme in 
certain countries. This holds true not only for countries that exclusively participated 
through  their  NPBs  but  also  for  Belgium,  Bulgaria,  France,  Hungary,  Italy  and 
Poland. 

-  Regarding the involvement of leasing companies in the LGF, their participation in 
some  cases  (e.g.,  France,  Netherlands)  was 
the  specific 
characteristics of national guarantee programmes. These programmes either do not 
consider these intermediaries as eligible for financing, or the terms at which these 
programmes  are  offered  do  not  align  well  with  the  business  model  of  leasing 
companies. 

influenced  by 

-  The LGF supported 865,387 distinct SMEs (i.e. final recipients) as of 31 December 
2022. The countries with the highest number of final recipients (SMEs receiving 
finance  via  the  LGF)  are  Italy,  France,  Spain,  and  Poland.  The  geographical 
distribution of supported SMEs is mainly determined by the number of agreements 

362 28 active agreements (18%) signed by 20 distinct financial intermediaries (16%). 
363 15 active agreements (10%) signed by 7 financial intermediaries (6%). 
364 11 active agreements (7%) signed by 9 financial intermediaries (7%). 
365 9 active agreements (6%) signed by 8 financial intermediaries (6%). 

175 

 
 
 
 
 
 
signed  in  each  country  and  the  size  (maximum  portfolio  volume)  of  these 
agreements.  

In addition to this there were other factors at play, such as the average size of loans 
the  EIF  agreed  with  the  financial  intermediaries  in  the  different  countries.  (See 
Figure 7 - LGF final recipients and maximum portfolio volume signed by country). 
In general, the larger the maximum portfolio volume signed, the larger the number 
of SMEs supported in each country. 

-  As shown in Figure 8 (LGF final recipients as a percentage of all SMEs in each 
country),  the  percentage  of  the  national  SME  population  receiving  LGF  support 
was highest in  Spain and France (6%), followed by Serbia, Italy and Finland (5%), 
and Poland (4%).  

•  EFG Funds and final recipients: 

-  COSME  EFG eligible final  recipients’ headquarters were located in  23 different 
countries.  The  countries  with  the  highest  number  of  EFG  final  recipients’ 
headquarters were Germany (14, 13%), France (11, 11%), and Finland (10, 10%), 
followed by the Netherlands (8, 7%), Greece (7, 6%) and Ireland (7, 6%). In 15 
countries, less than five SMEs received investment. This distribution is in line with 
the overall distribution of EIB group366’s equity operations in the period 2010-2021. 
For  the  EIB  group’s  operations  in  general,  funding  was  concentrated  in  a  few 
countries notably the UK, France, Germany and Sweden. For further information 
see Figure 10: Core EFG eligible final recipients and total amount invested by legal 
country, page 170.  

•  Specific Objectives SO2 – SO4 

-  S02: Access to markets – networks and services 

Figure 16 : Total COSME SO2 funding by participants’ country (excluding 
EEN) on page 176 provides and overview of country participation for this specific 
objective. 

The  geographical  distribution  of  EU  grants  for  SO2  was  well  aligned  with  the 
distribution of participants by country. Most of the EU contribution was granted to 
participants  based  in  Spain,  the  United  Kingdom,  and  France.  Concerning  the 
different countries involved in international projects, it is interesting to note that in 
most of the cases the participants were from multiple EU countries. Five projects 
involved organisations located in non-COSME participating countries, namely in 
Brazil, China, Chile, Mexico, Thailand and Vietnam, which were supporting EU 
enterprises.  These  organisations  received  considerable  amounts  for  activities 
supporting the internationalisation of EU enterprises to those third countries. 

Enterprise  Europe  Network  members  are  situated  in  all  EU  Member  States  and 
other countries participating in the COSME programme. And they provide services 
in all regions of these countries  367 . The number of organisations participating in 
EEN consortia varies from one country to another, either because of the size of the 
country,  or  because  of  the  number  of  relevant  organisations  with  the  necessary 

366 The EIB group refers to both the EIB and the EIF. 
367 Typically at NUTS1 level for EU member States (NUTS 2021 classification: Statistical regions in the European Union 

and partner countries — NUTS and statistical regions 2021). 

176 

 
 
operational  capacities  in  the  regional  /  national  business  and  innovation  support 
ecosystem368.  

The representation of the EEN around the world is crucial to provide SMEs with 
the services  to  access  global markets  (including support for international partner 
search and country information)369. The third country members of the EEN network 
(known  as  “Business  Cooperation  Centres  (BCCs)”  in  the  2014-20  period). 
supported  the  EEN  network  with  partnership  and  market  information  services. 
There were 73 BCCs in 29 third countries and these centres did not receive a grant 
from the COSME programme.370 

•  S03 Framework Conditions and Competitiveness 

SO3 provided grants to 1 066 unique and distinct participants based in 37 distinct 
countries, including both EU countries and associate countries. Overall, a relatively 
large  share  of  participants  was  located  in  Italy  (17%),  Spain  (16%),  and  France 
(9%)  while  a  minority  of  participants  (45)  were  located  in  an  associate  country 
(namely, Albania, Bosnia and Herzegovina, Iceland, Moldova, Montenegro, North 
Macedonia, Norway, Serbia, and Türkiye). 

See also:  Figure 17:  Number of S03 project  participants  by legal  country of the 
participant, page 179. 

•  SO4 (Entrepreneurship) 

SO4  provided  grants  to  478  organisations  located  in  38  distinct  countries.  The 
countries  with  the  largest  number  of  participants  are  Italy  (12.7%  of  the  total), 
Spain  (12.5%),  and  Belgium  (6.5%).  Those  are  followed  by  France  (5.3%), 
Portugal (4.8%) and the United Kingdom (4.8%). It is noteworthy that all projects 
that received a grant under SO4 were implemented by consortia with 3 to 17 distinct 
partners. Moreover, all the consortia included organisations that were located in 
different countries. 

368 E.g many EEN organisations were located in Italy (11.6%), Germany (10.7%) and Spain (9.8%). 
369 Special Report No 07/2022: SME internationalisation instruments. 
370 These receive non-financial support from the Commission, in the form for instance of technical assistance and access 
to online services. BCC do not rely on financial support from the EU but rather from national authorities elsewhere 
including in third countries. At the end of 2020. 

177 

 
 
 
ANNEX VII. PERFORMANCE AGAINST INDICATORS 

The Annex to the COSME Regulation provided indicators for the general and specific objectives 
of the programme. The table below summarises the evidence of achievement against the indicators 
and, where necessary, provides a comment. 

Indicator 

Evidence of achievement 
General objective: To strengthen the competitiveness and sustainability of the Union's enterprises, 
particularly SMEs 
A.1. Performance of SMEs as regards sustainability 
• 

Comment 

SME 

Increase in the proportion of 
Union 
producing 
green,  i.e.  environmentally 
friendly,  products  compared 
to baseline 

Programme Regulation specifies 
measurement by means of a 
Eurobarometer survey. 
However, no survey was 
undertaken. 

A.2 Changes in unnecessary administrative and regulatory burden on both new and existing 
SMEs 
•  Marked reduction in number 
of days to set-up a new SME 

Based on the methodology used 
by the World Bank for the 
Doing Business Report 

Quantitative data unavailable to 
the evaluation 

Several actions contributed to 
this indicator. (See section 4.2.7 
of the main report.) 

Difficulties in attributing 
impacts to the COSME 
programme 

As from 2019, this criterion 
looked not only at the minimal 
legal requirements, but also took 
account of input from experts 
about how long it takes in 
practice to set up a business. The 
reported number of days has 
therefore been considerably 
higher than before 2019. The 
data for this indicator is 
complete and shows a 
continuous decrease throughout 
the programme from 15.6 days 
in 2014 to 11.9 days in 2020.  
As from 2019, the data for cost 
to set up a new SME is 
expressed in % of income per 
capita. There was a progressive 
decrease from 4.84% in 2014 to 
3.09% in 2020. 
The time to obtain licences to 
start up a company, the 
milestone target for 2017 had 
already been reached in 2014. 

•  Marked  reduction 

the 
average start-up costs in the 
Union compared to baseline 

in 

•  Marked 

in 

the 
increase 
number  of  Member  States 
where the time needed to get 
permits 
licences 
and 
(including 
environmental 
take  up  and 
permits) 
perform the specific activity 
of an enterprise is one month 

to 

Based on the methodology used 
by the World Bank for the 
Doing Business Report. 

A study carried out in 2015 
provided additional data on 
licencing procedures, including 
those related to protection of the 
environment, health and safety 
which typically represent a 
challenge for start-ups. 

•  Marked 

in 

the 
increase 
number  of  Member  States 
with  a  one-stop  shop  for 
business start-ups 

The baseline was already 18 
Member States in 2009 with 
good progress in the early years 
of the programme. 

Reporting on this indicator was 
discontinued in the latter years 
of the programme. 

A.3. Changes in the proportion of SMEs exporting within or outside the Union (Impact indicator) 

178 

 
 
 
 
Indicator 

• 

Increase in the proportion of 
SMEs exporting and increase 
in  the  proportion  of  SMEs 
exporting  outside  the  Union 
compared to baseline 

Evidence of achievement 
2018 targets achieved in 2014:  
• 

30%  of  SMEs  export  (2009 
baseline: 25%) 

• 

20% of SMEs export outside 
the EU (2009 baseline: 13%) 

Comment 

Lack of data for assessing 
further progress, as there was no 
later Eurobarometer surveys to 
update this data. 

General objective: to encourage an entrepreneurial culture and promote the creation and growth 
of SMEs 
B.1. Changes in SME growth 
• 

Source: European Commission 

Increase  of  SME  output 
(value  added)  compared  to 
baseline 

•  Targets were fully met until 
2018. The result was slightly 
below target in 2019 (3.84% 
compared  to  the  target  of 
4%).  

• 

Increase 
compared to baseline 

of 

employees 

•  Employment  exceeded  the 
target  figure  of  1%  for  all 
years 
2014-2019, 
from 
except 2015.  

Source: European Commission 

B2. Changes in the proportion of Union citizens who wish to be self-employed (impact indicator) 
• 

[not known] 

• 

Increase in the proportion of 
Union  citizens  that  would 
to  be  self-employed 
like 
compared to baseline 

Performance against this 
indicator was to be measured 
every 2-3 years by a 
Eurobarometer survey. But no 
survey on entrepreneurship has 
been performed since 2012. 

Specific objective: To improve access to finance for SMEs in the form of equity and debt 
C. Financial instruments for growth 
• 
•  C1.  Number 
benefiting 
financing 

865  387  supported  by  the 
LGF (target: 220 000 to 330 
000) 

Source: COSME programme 
data 

of 
from 

firms 
debt 

•  C2.  Number  of  venture 
capital investments from the 
COSME  programme  and 
overall volume invested 

• 

521  investments,  including 
the  core  COSME  EFG  and 
the  VentureEU 
SMEs 
(target: 360 to 540) 

•  EUR 

3.9 

billion 

of 
investments  (target:  EUR 
2.6 billion to 3.9 billion) 

Source: COSME programme 
data  
Some funds are still in the 
investment period, therefore 
additional investments are 
expected. 

•  C3. Leverage ratio 

•  Debt 

instrument: 
(target: 1:20 - 1:30) 

1.21 

Source: COSME programme 
data 

•  Equity 

instrument:  1.11 

(target: 1:4 - 1:6) 

•  EFG: 

data 

unavailable 

(baseline: 62%) 

•  LGF: 85% (baseline: 64%)  

•  C4. Additionality of the EFG 
and LGF (Proportion of final 
beneficiaries 
considering 
that  the  EFG  or  the  LGF 
provide  funding  that  could 
not  have  been  obtained  by 
other means) 

It had been planned to measure 
the EFG additionality via the 
interviews of SME beneficiaries 
of EFG for the final evaluation 
of COSME. As interviews for 
other evaluations took place at 
the same time, the Commission 
decided that extensive online 
surveys should be replaced by 
targeted interviews.  

Specific objective: To improve access to markets, particularly inside the Union but also at global 
level 
D: International co-operation 

179 

 
Indicator 
•  D1.  Number  of  cases  of 
improved alignment between 
Union  and  third  countries' 
regulations 
industrial 
for 
products 

Evidence of achievement 
[no data] 

• 

Comment 
The Commission discontinued 
reporting on this indicator due to 
measurability issues.  

E: Enterprise Europe Network (EEN) 
•  E1.  Number  of  partnership 

• 

agreements signed 

•  E2.  Recognition  of 

the 
amongst  SME 

Network 
population 

•  E3.:  Client  satisfaction  rate 
(% 
stating 
SMEs 
satisfaction,  added-value  of 
specific  service  provided  by 
the EEN) 

18 
701 
partnership 
(target: 2,500 per year) 

cross-border 
agreements 

• 

8% (2015) 

• 

92% (target: 82%) 

•  E4.  Number  of  SMEs 
receiving support services 

• 

1  957  822  (target:  500  000 
per year) 

•  E5.  Number  of  SMEs  using 
digital  services  (including 
information 
electronic 
services)  provided  by  the 
Network 

• 

21.5  million  (target:  2.3 
million per year) 

Source: COSME programme 
data 

The Commission discontinued 
reporting on this indicator as the 
underlying survey to provide 
this data was not renewed. 
Source: EEN 2021 client 
satisfaction survey 
This was measured throughout 
the programme. 

The methodology was changed 
in 2015. EEN partners no longer 
need to record the number of 
clients. If the old methodology 
had been continued, the reported 
figures would have been 
approximately 3,800,000 
(compared with the target of 
3,500,000). 
Data on the EEN provided by 
EISMEA. 

Specific objective: To improve framework conditions for the competitiveness and sustainability of 
Union enterprises, particularly SMEs, including in the tourism sector 
F: Activities to improve competitiveness 
•  F1. Number of simplification 

2014: 5 (target: 7) 

• 

measures adopted 

• 

2015: 4 (target: 4) 

•  F2.  Making  the  regulatory 
framework fit for purpose 

• 

5-8 

2014-2018: 
fitness 
checks  launched  per  year 
(target: 5 during 2014-2020) 

This refers to the number of 
simplification measures adopted 
and accompanied by an impact 
assessment. This quantitative 
reporting was discontinued in 
subsequent years. 
Data was not available for 
subsequent years. 

•  F3.  Number  of  Member 
the 
proofing 

States 
competitiveness 
test 

using 

•  F4.  Resource 

efficiency: 
Increase in the proportion of 
Union  SMEs  that  are:  i) 
taking  at  least  one  action  to 
be  more  resource  efficient; 
ii) are planning to implement 
additional 
resource 
efficiency actions every two 

Quantitative data unavailable to 
the evaluation. 

Programme Regulation specifies 
measurement by means of a 
Eurobarometer survey. 
However, no survey was 
undertaken. 

• 

[no data] 

• 

[no data] 

180 

 
Indicator 

Evidence of achievement 

Comment 

years. 

G: Developing SME policy 
•  Number  of  Member  States 

• 

using SME test 

2017: 27 (baseline: 15) 

As the underlying report 
providing the data for this 
indicator was discontinued by 
the Commission, no data is 
available for subsequent years. 
Specific objective: To improve framework conditions for the competitiveness and sustainability of 
Union enterprises, particularly SMEs, including in the tourism sector 
H: Tourism 
•  H1. 

•  >3  countries  covered  per 

Participation 

in 
cooperation 

project 

transnational 
projects 

This indicator was measured 
from 2017-2021 with a data gap 
for 2020. Figures were 
consistently above target, in all 
years where data was provided. 
Data unavailable for subsequent 
years. 

•  H2.  Number  of  destinations 
adopting 
sustainable 
the 
tourism development models 
promoted  by  the  European 
Destinations of Excellence 

• 

2018:  158  (baseline:  98; 
target: 200) 

I: New Business Concepts 
• 

of 

I1.  Number 
products/services 
market 

in 

new 
the 

Transnational partnerships:  
• 

2017-2021: 152 

• 

2021-2025: 138 

This indicator measures the 
number of new partnerships 
supported by WORTH, an 
acceleration pilot project 
providing support to develop 
innovative business ideas. The 
2017-2021 edition supported 
152 transnational partnerships. 
The second edition supported by 
work programme 2020 is 
ongoing until 2025. So far it has 
supported more than 138 
partnerships (against a target of 
200). 

Specific objective: To promote entrepreneurship and entrepreneurial culture 
J. Support for entrepreneurship 
• 
J1.  Number  of  Member 
implementing 
States 
entrepreneurship 
solutions 
based  on  good  practice 
identified 
the 
programme 

28 (baseline: 22) 

through 

• 

Source: European Commission 
Programme Statement for the 
COSME Programme. 

• 

28 

• 

J2.  Number  of  Member 
implementing 
States 
entrepreneurship 
solutions 
targeting  potential,  young, 
female 
new 
entrepreneurs,  as  well  as 
other specific target groups 

and 

Source: European Commission 
Programme Statement for the 
COSME Programme. 

181 

 
 
 
 
 
 
 
ANNEX VIII. CASE STUDIES AND SUCCESS STORIES 

Contents 

1. 

INTRODUCTION 188 

2.  CASE  STUDY  1:  SUPPORT  FOR  ENTREPRENEURSHIP  POLICY 

IMPLEMENTATION  189 

3.  CASE STUDY 2: IT TOOL ERASMUS FOR YOUNG ENTREPRENEURS

  191 

4.  CASE  STUDY  3:  EARLY  WARNING  EUROPE  EWE  MENTOR 

ACADEMY 192 

5.  CASE 

STUDY 
ENTREPRENEURSHIP  194 

4:  WEGATE 

PLATFORM 

FOR  WOMEN 

6.  CASE  STUDY  5:  EUROPEAN  CAPITAL  OF  SMART  TOURISM  - 
FOSTERING  SMART  TOURISM  SOLUTIONS  IN  EU  DESTINATIONS 
THROUGH THE EUROPEAN CAPITAL OF SMART TOURISM  196 

7.  CASE STUDY 6: SOCIAL ECONOMY MISSION 

198 

8.  CASE  STUDY  7:  CLUSTERS  GO 

INTERNATIONAL:  ESCP-4I 

CONTEXT  199 

9.  CASE  STUDY  8:  TRAINING  FOR  SME-FRIENDLY  POLICIES  IN 

CENTRAL PURCHASING BODIES 

201 

10.  CASE STUDY 9: ENTERPRISE EUROPE NETWORK: CARVERTICAL  201 

Introduction 

This annex presents nine case studies undertaken as part of the study supporting the evaluation of 
the Programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises 
(COSME) 2014-2020 and the Entrepreneurship and Innovation Programme (EIP) 2007-13. The 
case  studies  were  developed  to  illustrate,  using  practical  examples,  the  implementation  of  the 
different Programme actions. The purpose of the case studies is to provide an additional research 
tool  to  explore  some  of  the  key  evaluation  issues  in  greater  depth.  The  case  studies  provide  a 
qualitative assessment to complement the quantitative work under the counterfactual (econometric) 
analysis to assess the longer-term impacts of interventions supported by COSME. 

More specifically, the case studies include examples of flagship actions and their achievements, 
examples of good practice/success stories to investigate the factors that have led to the effective 
implementation  of  the  activities  as  well  as  examples of  initiatives  that  have  not  performed  as 
effectively  to  identify  and  review  barriers  and  disabling  factors  that  have  prevented  the 
achievement of results. The analysis of these examples allows the identification of lessons learnt 
and of the elements and contextual factors to consider, in order to maximise the effectiveness of 
future initiatives for SME growth and innovation.  

The  case  studies  draw  primarily  on  data  and  desk  research.  Interviews  with  beneficiaries  and 
intermediaries  provide  specific  insights  on  the  topics  and  allow  exploration  of  the  contextual 
elements in more depth. 

The table below provides an overview of the case studies and the sources used. 

182 

 
 
Case study topic 

Rationale for 
selection 

Data sources 

Table VIII.1: Overview of case studies 

1.  Support for entrepreneurship policy implementation 

Success story  Desk 

research  

Interviews 

Survey 
results 

Identification 
of costs and 
benefits 

2.  IT Tool Erasmus for Young Entrepreneurs  

3.  The EWE Mentor Academy 

4.  WEGate Platform for Women Entrepreneurship 

Difficult 
action 

Difficult 
action 

Difficult 
action 

5.  European  Capital  of  Smart  Tourism  -  Fostering  smart 

Success story 

tourism  

6.  Social Economy Mission 

7.  Cluster Go international 

Success story 

Flagship 
Action 

8.  Training for SME-Friendly policies in Central Purchasing 

Success story 

Bodies  

9.  Enterprise Europe Network: CarVertical 

Success story 

CASE STUDY 1: SUPPORT FOR ENTREPRENEURSHIP POLICY IMPLEMENTATION 

Context: The support for entrepreneurship policy implementation aimed to address the specific 
needs and difficulties faced by European entrepreneurs through support for establishment of pro-
entrepreneurship policies across the EU. Specifically, taking into account the specific objectives of 
the three public events that it delivered, the support aimed to contribute to the development of: 
policies  supporting  liberal  professionals  across  the  EU;  policies  supporting  honest  failed 
entrepreneurs  and  destigmatising  business  failure;371  and,  development  of  knowledge  and  good 
practices around business transfers.  

 The action involved the delivery of three conferences:  

• 

• 

• 

“Conference on Boosting the Business of Liberal Professions” (2014) 

“Conference on Transfers of Business” (2017) 

“Conference on Second Chance for Honest Failed Entrepreneurs” (2015). 

Objective: The general objective was to support the implementation of entrepreneurship policy, 
whilst each conference had its own specific objective. 

The specific objective of the “Conference on Boosting the Business of Liberal Professions” was to 
follow  up  on  the  outputs  of  the  working  group  on  liberal  professions  from  2013  and  provide  a 

371 The data on EU business survival rates indicate that one in five newly-established firms would fail during their first 
year:  Statista.com  (2021).  One-year  business  survival  rates  in  selected  European  countries  by  country,  2018. 
https://www.statista.com/statistics/1114070/eu-business-survival-rates-by-country/#:~:text=One-
year%20business%20survival%20rates%20Europe%202018%2C%20by%20country,survival%20rates%20in%20the%
20European%20Union%20for%202018 (accessed: 11.10.2023). 

183 

 
 
 
 
  
 
 
 
 
 
 
forum  for  discussion  of  the  draft  paper:  "Action  Lines  for  Bolstering  the  Business  of  Liberal 
Professions".  The  policy  paper  included  proposals  for  measures  targeting  support  for  liberal 
professionals  within  five  thematic  areas  (Reduction  of  Regulatory  Burden;  Access  to  Finance; 
Strengthening Representation and Participation at European Level; Access to Markets; Education 
and Training for Entrepreneurship), that were analysed by the attendees of the conference.  

The  specific  objective  of  the  “Conference  on  Transfers  of  Business”  was  to  “follow-up  on  the 
Commission  expert  group  in  2013  and  earlier  Communications  and  recommendations  and  to 
promote  the  findings  of  the  Evaluation  of  the  implementation  of  previous  Commission 
recommendations  (1994)  and  Communications  (2006)  on  business  transfers  conducted  in 
cooperation with the Commission expert group throughout 2013”.372 The Conference built on the 
previous  findings  around  regulatory  and  financial  issues  connected  to  business  transfers  and 
support for using on-line platforms for business transfers. 

The specific objective of the “Conference on Second Chance for Honest Failed Entrepreneurs” was 
to  provide  a  follow-up  to the  expert  group run  by  the  Commission  since  2010  and  to the  2017 
Communication concerning stigmatisation of business persons who previously experienced failure 
in their businesses while maintaining integrity, overcoming of such a stigma, and possibilities to 
support such persons in starting over again. 

Outputs and results: The “Conference on Boosting the Business of Liberal Professions” reported 
the following outputs: 103 representatives of national and European organisations in the area of 
liberal professions attended, and peer-learning has been facilitated among EU Member States. The 
resources accessed by the evaluation team, including the referenced monitoring fiche, indicate that 
this  provided a suitable forum for discussion of the draft policy paper, the event contributed to 
more  joined-up  and  cohesive  policies  and  actions  supporting  the  expansion  of  the  business  of 
liberal professions across Europe. The conference was followed by the meeting of the Working 
Group on Liberal Professions in the SME Assembly that took place in late 2014 in Italy. 

The  “Conference  on  Transfers  of  Business”  resulted  in  identification  of  good  practices  around 
regulatory and financial issues related to business transfers, including good practices to support 
utilisation  of  on-line  platforms  for  such  transfers.  The  results  included  testimonials  by 
policymakers,  businesspersons  and  business  support  providers.  More  than  100  participants 
attended  the  one-day  conference.  Attendees  included  national  and  regional  decision-makers,  as 
well as a range of other relevant stakeholders. The participants had an opportunity to attend four 
workshops  and  two  plenary  sessions  where  they  contributed  towards  development  of  tangible 
solutions for business transfer issues. The participants’ contribution led to exchange of knowledge 
between stakeholders from different Member States, and increased awareness of the subject and of 
good practices across Europe. 

“The Conference on Second Chance for Honest Failed Entrepreneurs” reported attendance of 280 
representatives of academia, public administration, businesses, and other stakeholder groups. Key 
topics  addressed  during  the  conference  included  financial  support  for  persons  who  previously 
failed in business, legal knowledge connected to business failures, and information on how to learn 
from past mistakes made in entrepreneurial activity. Specific recommendations were developed 
and  included  in  the  report  summarising  the  conference’s  proceedings.  The  COSME  2014 
Monitoring Report noted that the conference had paved the way for the initiative on the European 
network of early warning and advisory services for a second chance established in 2016. 

Costs and benefits: Overall, the “Support for entrepreneurship policy implementation” was one 
of the minor activities financed under the fourth specific objective of COSME, namely “Promoting 
entrepreneurship  and  entrepreneurial  culture”.  Its  share  of  the  overall  envelope  devoted  to  this 

372 Commission Staff Working Document - Accompanying the document Report from the Commission to the European 
Parliament and the Council COSME - Programme for the Competitiveness of Enterprises and SMEs 2014-2020 - 
Monitoring Report 2014, SWD(2016) 274 Final. 

184 

 
 
objective  was  roughly  4%  (EUR  0,6M  out  of  EUR  12,9M).  By  comparison,  the  financial 
investment in EYE was more than ten times larger.373 

The eventual costs of all three conferences were considerably below the initial budget. The planned 
budgets of the both the “Conference on Transfers of Business” and the “Conference on Second 
Chance for Honest Failed Entrepreneurs” were EUR 200 000 and the ultimate commitments were 
EUR  149  140  each.  The  third  initiative,  “Conference  on  Boosting  the  Business  of  Liberal 
Professions”, had a planned budget of EUR 300 000, while the reported commitment totalled EUR 
178 358. It follows that the planned budget for all three the initiatives totalled EUR 700 000, while 
the total commitment reached close to EUR 480 000.4 

Conclusions  and  lessons  learned:  Overall,  taking  into  consideration  COSME’s  broader 
framework, the “Support for entrepreneurship policy implementation” particularly contributed to 
the  creation  of  a  favourable  environment  for  European  businesses’  competitiveness  and 
development,  based  on  a  tangible  contribution  to  an  improved  policy  framework  for  European 
firms.  The  three  conferences  allowed for  a knowledge  exchange,  discussion, and  refinement  of 
policy proposals to improve a policy framework for three, specific areas of the European economy. 
The follow-up actions identified based on the documentation analysis confirmed the relevance of 
the  initiative  to  the  needs  of  the  European  business  landscape.  Moreover,  the  feedback  on  the 
conferences cited in the COSME Monitoring Report from 2014 further confirmed their success in 
terms of contribution to development of European business.374 The “Conference on Boosting the 
Business of Liberal Professions” was part of a broader trend of support for development of Liberal 
Professionals-targeted policy that was supported at the time also by the Italian EU Presidency and 
by the European Parliament. No information on the feedback to the “Conference on Second Chance 
for  Honest  Failed  Entrepreneurs”  has  been  identified.  However,  the  information  on  the 
conference’s  outputs  suggests  that  it  has  delivered  the  results  matching  the  expectations.  The 
“Conference  on  Transfers  of  Business”  was  described  as  “highly  relevant,  informative  and 
successful” by the organisers and participants. 

CASE STUDY 2: IT TOOL ERASMUS FOR YOUNG ENTREPRENEURS 

Context: From its launch in 2009 as a pilot under the EIP until February 2023 the Erasmus for 
Young  Entrepreneurs  (EYE)  programme  delivered  11  000  transnational  exchanges  between 
experienced host entrepreneurs and new entrepreneurs in other countries. During this period, there 
was  a  significant  technological  progress.  The  original  IT  technology  supporting  EYE  was 
ColdFusion,  a  web  programming  language  that  allows  online  applications  to  maintain 
communication with back-end systems. That technology, however, stopped being supported by the 
European Commission. This warranted investment in a new IT Tool (the full name of the action: 
IT  Tool  Erasmus  for  Young  Entrepreneurs  -  GRO/SME/20/D/02).  The  starting  date  of  the 
contract for the investment was March 2020, and the project closed in late October 2021. 

Objectives: The objective of the project was to re-develop the original EYE IT Tool database in 
light of the technological advances made since its creation in 2008. Given the decision to no longer 
use ColdFusion, the European Commission had planned to assess the technology to be used for the 
investment, then plan, develop, and test several modules of the new IT tool, and at the same time 
maintain the old version of the IT tool to support implementation of the EYE. 

Outputs and results: Based on the assessment of the documentation, the action delivered partial 
results. Some deliverables were developed according to original plans and some deliverables had 

373 Report from the Commission to the European Parliament and the Council COSME Programme - for the 
Competitiveness of Enterprises and SMEs 2014-2020 Monitoring Report 2014, COM(2016) 526 final. 
374 Report from the Commission to the European Parliament and the Council, COSME Programme for the 
Competitiveness of Enterprises and SMEs 2014-2020 Monitoring Report 2014, COM(2016) 526 final. 

185 

 
 
 
to  be  re-classified  as  negative  priorities  due  to  external  factors  that  impacted  the  cost  and 
availability of IT staff. These issues are explained in the point on challenges below.  

The modules that were re-developed included the Registration process, European Partnership and 
Intermediary Organisation management and the New/Host entrepreneurs management. The 2020 
monitoring  report  specifically reports  that  “these  deliverables  [had  been]  provided  on-time and 
according to requirements”. The 2020 Monitoring Fiche reported that the necessary maintenance 
and  updates  had  been  made  to  the  old  system  which  in  turn  allowed  participants  to  apply  and 
participate in the EYE programme.375  Overall, the challenges described in this case study had no 
impact on the overall implementation of the EYE, as all the project activities were carried out as 
planned. 

Those modules that were originally envisaged but finally were not developed nor tested during 
2021  implementation  (funded  by  2020  budget)  included  Search  and Match,  Relationships, 
Monitoring, Reporting and Administration).376 The challenges encountered are explained below. 

Challenges: While the original plan was to redevelop the abovementioned modules, this was no 
longer  feasible  due  to  a  lack  of  resources.  The  problem  with  resourcing  stemmed  from  the 
requirement (under the DG DIGIT framework contract) for the IT specialists working on the project 
to be based in Belgium. There were difficulties and delays in recruiting, which increased the costs 
of the project. Moreover, in light of DG DIGIT’s requirements for project owners to move away 
from using ColdFusion (the EYE IT Tool had been written in that technology), the project had to 
invest  more  resources  to  switch  to  one  of  the  technologies  supported  by  DG  DIGIT  (PHP 
Symphony, JAVA, Drupal). 

Costs and benefits: The above-mentioned challenges resulted in a need to increase the budget. In 
the third quarter of 2020, the revised 2023 work programme confirmed an increase in the IT Tool 
action’s  budget  from  EUR  200,000  to  EUR  300,0000.  The  actual  cost  incurred  was  within the 
increased budget at EUR 299,813. 

Lessons learnt: Overall, the IT Tool for the EYE action can be seen as a necessary response to a 
changing technological environment. It was also heavily impacted by external market conditions, 
and  changing  compliance  requirements  which  led  to  additional  costs.  However,  based  on  the 
Commission’s feedback, such challenges had no impact on the overall implementation of EYE, as 
the  old  version  of  the  tool  was  fully  operational  and  allowed  the  programme’s  activities  to  be 
carried out.  Prompt action was taken to  minimise the incidence of these exceptional challenges 
on the adaptations to this IT tool and to ensure that the best possible set of updates were made 
taking account of budgetary constraints.  The IT Tool for the EYE was a key enabler for EYE, in 
particular  it  helped  to  connect  new  and  experienced  entrepreneurs  together  with  collecting 
to  COSME’s  objectives  of  supporting 
participants'  feedback.  Hence, 
entrepreneurship and growth should not be understated. 

its  contribution 

CASE STUDY 3: EARLY WARNING EUROPE EWE MENTOR ACADEMY 

Context:  The  action  “Improving  the  availability  and  the  scope  of  services  for  companies  in 
financial difficulties - GRO/SME/20/C/013 – 1” (branded as “Early Warning Europe EWE Mentor 
Academy” to increase its attractiveness towards businesses and entrepreneurs) was planned to start 
in late 2021 to respond to the needs of firms at risk of insolvency, both in EU Member States and 
in third countries participating in COSME. It should be seen as a direct follow-up and a support to 
the transposition of Article 3 of the Directive on Restructuring and Insolvency of the Parliament 
and the Council (Directive (EU) 2019/1023) providing for early warning tools.   

Objectives: The project had a strong adult-learning component and focused largely on building up 
company resilience. It supported the development of training courses targeted at  future mentors 

375 Monitoring fiche, IT Tool Erasmus for Young Entrepreneurs - GRO/SME/20/D/022. 
376 Monitoring fiche, IT Tool Erasmus for Young Entrepreneurs - GRO/SME/20/D/022. 

186 

 
 
who would support entrepreneurs facing challenges connected to solvency at different company 
life-cycle stages. Based on hands-on experiences, the activity anticipated mapping best practices 
and supporting connections between business mentors and a broader community of European and 
country-level providers of business support. 

Outputs and results: There is very limited information on the outputs and results of the action. 
The  monitoring  fiche  for  the  EWE,  covering  the  period  up  to  May  2023,  reported  a  period  of 
underperformance and the intention to suspend the action in April 2022. Subsequent mitigation 
measures  were  implemented  to  steer  the  project  back  on  track,  with  a  view  to  its  successful 
completion.377 These measures included:  

• 

• 

• 

introduction  of  a  revised  implementation  plan  following  the  withdrawal  of  one  of  the 
consortium partners (for example: acknowledging that some project activities will be run in 
parallel instead of sequentially); 

strengthening of the project team with some new, senior-level hires (a new Task Leader on 
Training and QA, a new Leader on the Communication Task, and a new Task Leader on Pilot 
and Training); and,  

a review of the project by an external expert, and the subsequent implementation of several 
recommendations to address issues. 

The  project  is  expected  to be  concluded  in  November  2024.  As  of  October  2023,  according  to 
interview feedback, 30 networks are operating under its framework, which allows the project to 
source  adequate  know-how  inputs.  Beyond  that,  it  was  reported  that  there  are  direct,  positive 
consequences of its activities, such as partnership established by some mentors to  provide pro-
bono  services  (e.g.,  in  Italy  and  Serbia),  businesses that  have  avoided  court  costs  connected  to 
insolvencies,  and  individuals  that  avoided  bankruptcy.  In  the  first  year  of  implementation,  the 
project  met  or  exceeded  most  of  its  progress  indicators,  including  recruitment  of  mentors, 
organisation of substantive activities such as peer-learning workshops, facilitation of networking, 
or conducting research on the existing resources around the project’s area of interest. 

Challenges:  Several  challenges  are  reported  in  the  monitoring  fiche.378  Some  activities  (e.g., 
communication  and  creation  of  modular  training  curricula)  were  affected  by  “a  rather 
unfortunate composition of the consortium which hindered the implementation of specific parts of 
the activities” (including the withdrawal of one of the consortium partners). Other challenges in 
project  implementation  included:  poor  quality  assurance  leading  to  some  deliverables  being  of 
insufficient quality, or the social media channels functioning sub-optimally during the deployment 
of the action. These delays impacted some of its deliverables. Based on the interview feedback, it 
has  also  been  identified  that  the  administrative  requirements  around  the  project  were  seen  as 
burdensome (detailed reporting on 9 workshops) by the implementing party.  

Costs and benefits: According to the work programme, the budget totalled EUR 900 000 over 
three years of the programme, while the funding committed in practice was EUR 842 064,43. The 
implementing party that was interviewed described the project as very cost-efficient, with trainers 
often providing the courses for free. 

Conclusions and lessons learned: The EWE Mentor Academy can be seen as an example of an 
important and relevant initiative that was facing challenges around successful delivery on its aims, 
having  been  significantly  undermined  by  internal  project  management-related issues  within  the 
project consortium. On the other hand, the EWE Mentor Academy can be seen also as an important 
illustration of an under-performing initiative getting back on track by sourcing external expertise. 
It illustrates how early detection of implementation issues by the contracting authority can trigger 

377 Monitoring Fiche, IT Tool Erasmus for Young Entrepreneurs-GRO/SME/20/D/022. 
378 Monitoring Fiche, Improving the availability and the scope of services for companies in financial difficulties - 

GRO/SME/20/C/013. 

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the development of a contingency plan and raise awareness of additional resources available in the 
broader market to help making good use of public funding that would have otherwise been wasted. 

CASE STUDY 4: WEGATE PLATFORM FOR WOMEN ENTREPRENEURSHIP 

Context: WEGate was established in 2016 as an online platform, and funded again in 2020 with 
the aim of ensuring its long-term economic viability. The platform was one of several solutions set 
up by COSME to support women’s entrepreneurship, aiming at bringing female-targeted initiatives 
together in a single online space. Since early 2020, it has been under EASME management (based 
on  a  grant  procedure),  with  EASME  functioning  as  a  contracting  authority  through  COSME 
(“WEGate Platform for Women Entrepreneurship - GRO/SME/18/F/204”). The project ended in 
January 2023. 

Objective:  The  objective  of  the  project  was  to  support  women  in  establishing,  managing,  and 
securing  financing  for  their  firms.  The  operational  objectives  included  the  development  of  a 
“European women entrepreneurship community of practice” and involving more stakeholders, and 
not  just  women  entrepreneurs,  in  supporting  female  businesspersons.  The  aim  was  to  see  the 
“women entrepreneurs’ community reflourishing in Europe” and indeed, based on the interview 
with  the  managing  organisation,  the  project  attempted  to  build  an  umbrella  organisation  for 
stakeholders involved in supporting female entrepreneurship, and ensure there would be a vivid 
community centred around WEGate. To help with this, WEGate planned an updated visual identity  
for the platform, with contributions from “an external consortium with high communication skills 
and academic, financial and scientific backgrounds”. 

Outputs and results:  According to the 2017-18 COSME monitoring report, the project was to 
feature events providing inspiration to aspiring female entrepreneurs, promoting role-models, or 
stimulating  the  women  entrepreneurs’  ecosystem  (including  facilitated  access  to  training, 
mentoring, or networking). Other planned activities conceived as follow-up items  included peer-
learning  (workshops,  networking  events,  webinars),  or  communication  and  outreach  (activities 
targeting  the  youth  and  beginner  entrepreneurs,  awareness-raising,  coaching,  sharing  of 
information, newsletter publication, blogging, press releases, rebranding of WEGate, its promotion 
and others), a strategic and multifaceted community building process, as well as implementation 
of  specific  activities  connected  to  project  coordination,  and  management  of  an  e-platform 
(including e.g., preparation of optimised layout and navigation, richer contents, or achieving a more 
engaged  community).  The  activities  supported  by  the  project  included  “a  homogeneous  set  of 
services,  i.e.,  organisation  of  meetings/events,  peer  learning  workshops,  communication  and 
community building activities and finally […] one practical tool to network and support female 
entrepreneurs.”  

The  majority  of  WEGate  participants  were  female  entrepreneurs  representing  many  sectors, 
particularly the service sector and ICT sector. The WEGate developed an online assistance module 
providing  information  on  a  broad  range  of  female  entrepreneurship/entrepreneurship-related 
subjects.  Subjects  addressed  by  the  website’s  materials  include  women  empowerment  through 
skills-development,  digital  transition,  advocacy,  access  to  funding,  and  support  for  women 
entrepreneurs  in  Ukraine).  Another  initiative  implemented  through  the  platform  was  a 
WEBarometer survey that mapped challenges and needs of female entrepreneurs. The results of 
the survey informed the choice of subjects for the subsequent public activities (such as webinars) 
implemented under the project. Importantly, the WEGate platform served as a tool for sharing best 
practices regarding women’s participation in the European business landscape. Finally, according 
to the organisation managing WEGate, the summits (the third summit was organised in Brussels in 
October  2022)  organised  under  the  project  had  been  particularly  productive,  having  fostered 
lobbying and networking in the context of female entrepreneurship, both online and in person. 

As  of 2020,  WEGate featured  1,814 members  from  43  countries,  including  all  28  EU  Member 
States.  As  of  October  2023,  there  were  4,000  members  of  the  project,  and  50  networks  on  a 
European  level,  involved  in  its  community.  The  available  data  suggests  that  the  action  was 
successful in achieving the end goals, in particular in contributing to gender mainstreaming. The 

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successful performance of the project in terms of its outreach is well illustrated by the fact that 
WEGate gained approximately 2,000 followers on LinkedIn, which was assessed by the managing 
organisation as a success. 

To  secure  the  long-term  impacts  of  the  project,  it  was  necessary  to  ensure  the  community’s 
functioning  beyond  the  official  end  of  the  project.  For  this  reason,  the  proposal  accepted  for 
continuation of EU funding for WEGate stressed that there would be a business plan developed to 
allow WEGate to become self-sustaining. Indeed, such a business plan had then been developed 
and it was decided that WEGate would be transformed into a Brussels-based association, funded 
by its members’ fees. The feedback on this proposal, provided by the stakeholders addressed by 
the WEGate management team, confirmed the community’s willingness to participate in the cited 
association and start the process for its establishment. 

Challenges:  Challenges  to  successful  implementation  of  the  project  include  a  delay  in 
implementation  due  to  the  change  of  the  managing  team.  The  change  was  prompted  by  a 
suboptimal communication between the managing team and the project coordinator. To make the 
internal cooperation on the project smoother a completely new team for implementing the project 
was appointed by the lead of the consortium (ESBA) to start work on the project in August 2020, 
with  a  view  to  reinvigorating  the  initiative.379  The  new  consortium  successfully  took  over  and 
established connections with the WEGate partners and a broader community, even if initially the 
new managers had to build trust among the WEGate stakeholders.  

One success factor in the implementation of the project was the good communication between the 
management team and the Commission’s policy officers. Moreover, based on the feedback from 
the interview with the institution in charge of the project, the involvement of the target audiences 
(the  community)  in  shaping  the  project  (most  importantly,  via  direct  communication  and  the 
WEBarometer tool) ensured that WEGate delivered results of high relevance to the needs of female 
entrepreneurs across Europe. This now allows for WEGate’s sustainability, as the community itself 
requested for the initiative to be continued. The project was also implemented in a flexible manner, 
being gradually amended in line with the changing perception of the target community’s needs. 
Finally, during an interview the managing organisation highlighted the importance of a responsible 
and engaged approach to the use of EU funding. 

Costs  and  benefits:  According  to  the  COSME  detailed  report  for  2017-2018,  the  budget 
committed to this project totalled EUR 850 000. The 2018 COSME implementation report further 
specified that administrative expenditure accounted for 3% of the annual budget of the project. 
According to data from EISMEA, the COSME-funded project finished at the end of January 2023 
as planned.  A long-term business strategy was adopted by the managing organisation with a view 
to  ensuring  continuity  of  services  in  the  long  term,  with  the  members  of  the  new  association 
potentially contributing financially to WEGate.  

Conclusions and lessons learnt: The WEGate is an example of a project where implementation 
issues  led  to  some  challenges  around  delivery,  but  the  successful  sourcing  of  human  resources 
allowed  it  to  get  back  on  track.  It  should  be  seen  as  significantly  relevant  to  the  COSME’s 
intervention  logic,  having  supported  the  European  business  landscape,  and  at  the  same  time 
successfully mainstreaming gender-focused approach into promotion of entrepreneurship. As such, 
it  exemplified  two  dimensions  of  COSME,  as  a  programme  that  is  both  business-driven,  and 
conducive to broader societal development. One success should be noted: the effective integration 
of the target audiences’ voices into the design and delivery of activities (which supported relevance 
and  sustainability  of  the  investment).  The  ongoing  state  of  play  also  illustrates  the  type  of 
challenges typically faced by projects once EU support has ended. Almost one year after the end 
of the grant agreement, this project remains self-sustaining to some extent. Inter alia, the web site 
remains accessible providing access to a number of tools that will continue to be relevant to women 
entrepreneurs over the medium-term (notably, recordings of webinars). More recently, the start of 

379 We-gate.eu, https://www.WEGate.eu/WEGate-is-back-with-a-new-managing-consortium/, access: 03.10.2023. 

189 

 
 
work on the 2023 WEbarometer has been announced. However, given the lack of new materials 
and news items on the site, it is not clear to what extent the animation of this project continues. 

CASE STUDY 5: EUROPEAN CAPITAL  OF SMART TOURISM –  FOSTERING  SMART  TOURISM 
SOLUTIONS  IN  EU  DESTINATIONS  THOROUGH  THE  EUROPEAN  CAPITAL  OF  SMART 
TOURISM 

Context: The survey of providers and beneficiaries of EIP/COSME actions provided a picture of 
the  context  and  needs  of  the  European  tourism  sector  when  the  action  "GRO/SME/20/C/06  - 
European  Capital  of  Smart  Tourism"  was  implemented.  The  action  was  prompted  by  several 
factors. Firstly, there was a significant gap in awareness and knowledge concerning sustainable 
tourism practices among key stakeholders, coupled with a notably low rate of implementation of 
sustainable tourism initiatives among SMEs. Public authorities were keen to address these issues 
and sought to bolster the development of sustainable tourism and support small tourism businesses, 
necessitating access to funding for the tourism sector. In addition, there was a challenge at the level 
of providers of tourism-related services as they displayed limited interest in environmental and 
sustainability  aspects.  The  overall  landscape  also  revealed  a  lack  of  public-private  cooperation 
within  the  tourism  sector,  as  well  as  insufficient  collaboration  between  various  tourism 
stakeholders.380 

Objectives:  The  action  "GRO/SME/20/C/06  -  European  Capital  of  Smart  Tourism"  aims  to 
promote innovation, intelligence, and sustainability within the tourism industry, primarily through 
the  exchange  of  best  practices  at  the  EU  level.  It  recognises  and  rewards  exceptional  tourism 
initiatives in larger European cities and destinations, designating two as the European Capitals of 
Smart  Tourism.381  This  initiative  provides  European  cities  with  a  platform  to  showcase  their 
innovative approaches as smart tourism destinations and acknowledges their efforts by awarding 
titles in four key categories: sustainability, accessibility, digitalisation, and cultural heritage and 
creativity.382 

Through this programme, cities across Europe are encouraged to implement outstanding measures 
and enhance their tourism offerings while contributing to the broader goal of advancing intelligent 
and sustainable tourism practices in the EU.383 

Outputs and Results: The action successfully achieved its planned objectives, which involved 
providing European cities with the opportunity to share their exemplary practices as smart tourism 
destinations  and  promoting  cooperation  among  cities  at  the  EU  level  for  innovative  and  smart 
tourism  initiatives.  This  success  was  notably  demonstrated  by  awarding  the  titles  of  European 
Capital of Smart Tourism through an EU-wide competition to cities that implemented outstanding 
measures. The outcomes included the selection of two European Capitals of Smart Tourism per 
year  for  2022  and  2023,  the  exchange  of  good  practices  among  cities  (both  winners  and  non-
winners), the  organisation of  events, and  effective communication, media coverage,  and public 
relations activities to enhance the visibility of the winners. Notably, this action generated long-
term  appreciation,  even  among  non-winners,  as  they  benefited  from  valuable  information 
exchanges.  

Success  Factors:  The  success  of  the  action  "GRO/SME/20/C/06  -  European  Capital  of  Smart 
Tourism"  is  evident  on  several  fronts.  Firstly,  it  has  significantly  enhanced  international 
networking opportunities, bringing together cities from diverse backgrounds and facilitating the 
exchange  of  innovative  ideas  and  practices.  This  diversity  of  participating  cities  has  proven 
extremely valuable, encouraging the cross-pollination of new approaches across different regions 
and  countries.  Furthermore,  the  action's  ability  to  draw  more  tourists  to  these  cities  not  only 

380 Survey of providers and beneficiaries of EIP/COSME actions 
381 COSME 2020 Monitoring fiche on action FRO/SME/20/C/06 
382 https://smart-tourism-capital.ec.europa.eu/index_en  
383 https://smart-tourism-capital.ec.europa.eu/system/files/2021-04/Compendium_2020_FINAL.pdf 

190 

 
 
 
contributes to their economic growth but also supports the market expansion of SMEs within these 
geographic  areas.  It  might  be  beneficial  to  further  investigate  whether  winning  cities  indeed 
experience a notable increase in tourist numbers. Additionally, this action enhanced the uptake of 
innovation and technological tools in the tourism sector, exploiting the synergies between tourism 
offers and other industries and assets (e.g. culture, creative industries, sport, nature, etc.).384 

The action on European Capital of Smart Tourism has spurred a wave of exemplary practices across 
the EU in various categories. In terms of Accessibility, cities such as Vienna have implemented 
comprehensive  accessible  tourism  strategies,  ensuring  that  public  spaces,  attractions,  and 
transportation are fully accessible to people with disabilities. Regarding Digitalisation, Barcelona 
stands out for its innovative use of technology, offering augmented reality apps and digital maps 
to  enhance  visitor  experiences  and  navigation.  In  the  Sustainability  category,  Ljubljana  has 
excelled in promoting eco-friendly practices by emphasising green mobility, sustainable tourism, 
and waste reduction efforts. For Creativity and Cultural heritage, Athens showcases its rich history 
and culture through immersive exhibitions and cultural events, while also encouraging creativity 
in  the  arts.  Collectively,  these  cities  demonstrate  the  diverse  and  impactful  ways  in  which  the 
"European Capital of Smart Tourism" initiative is driving positive change in European tourism, 
fostering accessibility, digital innovation, sustainability, and cultural preservation.385 

Challenges: The main challenge was the significant time and resources required to administer the 
action. Clearer and more comprehensible guidelines at the outset of the project would have also 
enhanced its execution. Finally, further promotion of tourism offers at the transnational level and 
extending beyond Europe would have strengthened the initiative's impact and reach.386 

Costs and Benefits: The total budget available as per work programme for this action was EUR 2 
million.  The  action  facilitated  international  networking,  encouraged  diverse  participation,  and 
recognized outstanding smart tourism practices in various categories. The initiative demonstrated 
the potential for economic growth and SME market expansion through increased tourism. 

Conclusion  and  lessons  learned:  In  summary,  the  "GRO/SME/20/C/06  -  European  Capital  of 
Smart Tourism" initiative successfully addressed key challenges in the European tourism sector by 
promoting  innovation  and  sustainability.  However,  it  faced  challenges  due  to  administrative 
demands, unclear guidelines, and the need for broader transnational tourism promotion. Despite 
these obstacles, it has made significant progress in advancing intelligent and sustainable tourism 
practices in the EU, benefiting both cities and the tourism sector as a whole.387 The action indirectly 
supports  SMEs  in  the  tourism  sector  and  contributes  to  COSME's  goals  of  improving 
competitiveness and access to finance for European SMEs. 

CASE STUDY 6: SOCIAL ECONOMY MISSION  

Context: As noted by the Commission, fostering social innovation at the local, regional and inter-
regional  level  is  seen  as  crucial  to  support  green  transition  and  stimulate  cohesion  and 
inclusiveness.388 The social economy, in all its diversity of forms and business models, offers the 
potential for the necessary changes. However, awareness of this potential is uneven across the EU 
and hampered by the application of different definitions in the Member States  and by uneven take-
up of EU tools and support schemes. Nonetheless, social economy stakeholders expressed a clear 
desire to gain insights from the experiences and good practices of other countries. Additionally, 
SMEs engaged in social projects lacked avenues to connect with similar initiatives, highlighting a 
need for improved networking and communication within the sector.389 

384 Survey of providers and beneficiaries of EIP/COSME actions 
385 https://smart-tourism-capital.ec.europa.eu/system/files/2021-04/Compendium_2020_FINAL.pdf 
386 Survey of providers and beneficiaries of EIP/COSME actions 
387 Feedback collected from interviews on Tourism actions 
388 Call for proposals: European Social Economy Missions (SMP-COSME-2023-RESILIENCE) 
389 Feedback collected from interviews on Social Economy Mission 

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Objective:  This  action  aimed  to  promote  inter-regional  collaboration  and  knowledge  sharing 
among social economy stakeholders. It involved numerous workshops with the participation of 88 
beneficiary  organisations  from  27  EU/COSME  countries.  390  Furthermore,  the  project  aimed  to 
establish a network of regional and local authorities across the EU and COSME  countries with 
similar social economy priorities, fostering inter-regional learning and collaboration. Ultimately, 
the goal was to facilitate the development of a social economy community of practice as an integral 
part of a sustainable European economic model.391 

Outputs  and  Results:  The  action  successfully  achieved  its  planned  objectives.  It  effectively 
motivated participants to engage in future projects and fulfilled the crucial need for a cross-sectoral 
network of social economy actors. Furthermore, it significantly increased the visibility of initiatives 
in its domain and promoted the sharing of best practices, resulting in improved knowledge and 
connections  with  stakeholders.  The  action  facilitated  bilateral  dialogues  and  enhanced 
responsiveness to stakeholder needs. It also enabled the involvement of socio-economic institutions 
in innovative work tools. 392 Importantly, the action established an inter-regional network of SMEs 
actively engaged in the social economy, fostering collaboration, peer learning, and the exchange 
of  best  practices  across  different  regions.  Overall,  it  generated  valuable  materials  to  enhance 
regional and local social economies through a series of inter-regional workshops, engaging over 
2,500 participants from 27 EU/COSME countries and resulting in the identification of 350 good 
practices.393 The experiences of this action contributed to a subsequent action “Social economy and 
local green deals supporting SMEs to become more resilient” that aimed to accelerate the green 
and digital transition in different industrial ecosystems and economic sectors. 

Success  Factors:  The  action  demonstrated  several  successful  factors.  First,  it  showcased 
significant flexibility in adapting to new emergencies and needs, benefiting from robust support 
from Commission officials. The work was engaging and produced valuable local outputs. Effective 
communication  and  dissemination  of  best  strategies  was  ensured,  leveraging  various  channels, 
including  social  media,  local  newsletters,  and  interviews.  The  action's  strong  commitment  to 
dissemination and communication contributed to its success, aided by comprehensive support from 
the COSME programme. Networking added significant value, fostering active involvement and a 
keen interest in long-term impact. Even participants facing language barriers found opportunities 
to engage.394 

Challenges: Despite its successes, the action faced several challenges. The lack of in-person study 
groups also hindered their full potential. While the action facilitated the exchange of practices, it 
lacked  tools  for  concrete  applications,  limiting  the  potential  for  shareable  results.  Stakeholders 
expressed a need for more local, in-person visits to complement the action's efforts. In addition, 
the  duration  of  the  project  was  considered  too  short  by  some  partners,  and  that  more  time  for 
information sharing was needed.395 

Costs and Benefits: The total EU funding per work programme was EUR 1 900 000. Examples of 
the type of expenses of the action included workshop organisation, translation, interpretation, and 
video production, with many experts participating voluntarily. Subcontracting was employed to 
enhance events development. 

Conclusions  and  lessons  learned:  In  conclusion,  the  implementation  of  the  Social  Economy 
Mission action has proven successful in achieving its objectives and promoted the creation of a 
social  economy  community.  This  initiative  managed  to  effectively  promote  inter-regional 
collaboration  and  knowledge  sharing  among  social  economy  stakeholders  by  establishing  a 
network of authorities across the EU with similar social economy priorities, fostering inter-regional 

390 COSME 2020 Monitoring Report 
391 Monitoring fiche 2020, Social Economy Mission 
392 Feedback collected from interviews on Social Economy Mission 
393 Monitoring fiche 2020, Social Economy Mission 
394 Feedback collected from interviews on Social Economy Mission 
395 Feedback collected from interviews on Social Economy Mission 

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collaboration.396  The  project's  ability  to  adapt  to  emerging  needs,  supported  by  Commission 
officials,  demonstrated  remarkable  flexibility.  It  created  a  valuable  cross-sectoral  network  of 
actors, significantly increased the visibility of social economy initiatives, and facilitated the sharing 
of best practices. Moreover, it established an inter-regional network of SMEs actively engaged in 
the social economy, fostering collaboration and peer learning. 

CASE STUDY 7: CLUSTERS GO INTERNATIONAL: ESCP-4I 

Context: Clusters contribute to industrial innovation by supporting collaboration and linking of 
enterprises within a given region, especially SMEs.397. COSME provided EUR 51 million funding 
for  clusters  for  capacity  building  and  networking  from  2014-2021.398Since  2015,  the  European 
Cluster Collaboration Platform (ECCP) has provided a platform for cluster networking and growth. 
It hosts European Strategic Cluster Partnerships (ESCP) which pool resources and knowledge so 
that clusters can carry out joint actions for their members to improve competitiveness, growth and 
resilience.  Within  ESCP,  one  of  the  four  strands  of  work  is  internationalisation  towards  third 
countries through ESCP-4i (Clusters Go International).  

Objectives: The objective of ESCP-4i is to get clusters collaborating to develop and implement 
joint  internationalisation  strategies  so  that  SMEs  develop  new  value  chains  and  leading  global 
positions. There are two strands in ESCP-4i: one to develop joint internationalisation strategies and 
roadmaps, the other to develop specific activities that support co-operation with partners in third 
countries.399,400 

Outputs and results: According to the survey for this study, cluster organisations valued support 
to help them deal with issues such as lack of finance and personnel, challenges in making joint 
investments, lack of awareness of the benefits of joint action and lack of regional support. The 
clusters were, as a result, able to develop common internationalisation strategies, communications, 
market research, etc., all of which were highly valued. There were three generations of calls for 
ESCP-4i under COSME (2016-2017, 2018-2019 and 2020-2022). Under the first generation, 15 
co-partnerships were funded (10 on a voluntary basis), 25 under the second-generation, and 24 in 
the  third  generation  (2020-2022).  Under  first  and  second-generation  projects,  1,314  cluster-to-
cluster events were organised. 45 collaboration projects were established as a result of the first-
generation projects and 180 from the second generation. 401 

The cluster organisations participating in these projects gained an improved understanding of the 
internationalisation process and better access to international markets for SMEs that put them in a 
good position to strengthen their support for internationalisation. These projects have also helped 
increase awareness of the benefits of internationalisation among SMEs (indirect beneficiaries) and 
provided support for their internationalisation journey. The International matchmaking activities 
and the support for initial identification of new strategic partners provided by the clusters were 
highly valued  by the SME final beneficiaries.402 However, there is no evidence that these clusters 
actions led to successful SME internationalisation (new value chains or global positioning) in third 
countries on a significant scale. 

Success factors: Factors identified as contributing to the success of ESCP-4i in the survey for this 
study were: good collaboration between clusters and the Commission, duration of the programme, 

396 Feedback collected from interviews on Social Economy Mission 
397 Support for clusters has been a recognised part of the economic development arsenal of the EU since the 1980’s. 
398 Within COSME specific objectives C: improving framework conditions 
399 Prognos, CSES, Idea Consult (2021); Evaluation Study of and Potential Follow-Up to Cluster Initiatives under 
COSME, H2020 and FPI, DG GROW, European Commission, Brussels, p.34 
400 Two assessments of the ESCP-4i have been undertaken: one, by Prognos et. al. (op.cit.), the other by Sociedade 
Portuguesa de Inovação (SPI) (2019); Progress Report on the European Strategic Cluster Partnerships, EOCIC, 
EASME 
401 Prognos et. al., p.34 
402 Prognos et. al. p.63 and targeted survey. 

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simple administration, the funding level, good stakeholder engagement and the level of resource 
inputs required. 

The main change between EIP cluster initiatives and ESCP-4i was that, in the case of ESCP-4i, 
there was a focus on planning for entering new markets and then implementing these plans whereas 
the EIP initiatives focused more on joint collaboration between clusters. Both the targeted survey 
and the 2021 evaluation identified synergies with the H2020 programme, as well as the EEN (e.g. 
to  find  contacts  in  third  countries  and  for  match  making  events)  and  the  Smart  Specialisation 
Platform  for  industrial  modernisation.  Links  with  national  and  regional  programmes  could  be 
improved.403 

Challenges: In the 2021 evaluation, cluster organisations pointed out that after 24 months (duration 
of  a  call)  only  a  modest  number  of  successful  co-operation  cases  were  counted  because 
development of business relationships needs time and trust, and it is difficult to follow up after the 
end  of  the  project.404  While SMEs  see  ESCP-4i  as  a door-opener  and  way  to  achieve  a critical 
marketing mass (travelling as part of a European delegation) compared to travelling alone,405 they 
see participation in ESCP4-i as only part of the internationalisation process, and other activities are 
not  funded  under  ESCP4-i.  National  and  regional  programmes  funded  some  activities  not 
supported by ESCP-4i.  

Costs and Benefits: In the survey for this study, some cluster organisations indicated that their 
costs for implementing ESCP-4i projects ranged from EURO 20k to EURO 100k. Benefits related 
to the ESCP-4i can most readily be identified as accruing to cluster organisations (see above  – 
outputs and results), although these would have been passed on to SMEs. 

Conclusions: The evidence gathered by this evaluation and the 2021 evaluation demonstrates that 
the EU support has largely been effective in stimulating the formation of clusters at EU level and 
in  generating  direct  benefits  for the  organisation and also,  indirectly, for  SMEs served  by  such 
organisations. However, the available data is insufficient to form a robust view regarding the long-
term impacts of Clusters Go International. Conducting an ex-post evaluation after the completion 
of the projects could be beneficial to observe the expected benefits for participating SMEs. 

CASE  STUDY  8:  TRAINING  FOR  SME-FRIENDLY  POLICIES  IN  CENTRAL  PURCHASING 
BODIES 

Context: SMEs across the EU faced challenges in accessing public procurement opportunities  at 
the time when COSME was implemented, EU public sector bodies had a limited understanding of 
the impact of public procurement rules on SMEs and the difficulties SMES experienced in meeting 
those requirements and accessing the market.406 Under COSME, numerous actions and initiatives 
aimed to improve SMEs' access to public procurement markets by boosting their knowledge about 
the  procurement  process  and  their  rights  within  and  outside  the  EU,  navigating  the  perceived 
administrative barriers and capacity-building for procurement authorities. 

Objectives: The action "Training for SME-Friendly Policies in Central Purchasing Bodies (CPBs)" 
can be considered as a good practice example for future actions. This action aimed to equip CPBs 
staff  members  from  COSME  participating  countries  with  the  necessary  skills  to  better  involve 
SMEs  in  important  public  procurement  tenders.  Further  objectives  included  promoting  the 
professional growth of CPBs in the EU, increasing awareness about facilitating SME participation 
in  public  procurement,  and  encouraging  the  use  of  strategic  procurement  practices,  including 
innovation,  sustainability, and  social  considerations.407  This training initiative targeted  CPBs  in 
COSME  participating  countries,  particularly  those  with  structurally  weak  or  newly  established 

403 Prognos et.al., p.69 
404 Prognos et.al., p.65 
405 Prognos et.al., p.65 
406 Feedback collected from interviews on the action: Training for SME-friendly policies in central purchasing bodies. 
407 https://eismea.ec.europa.eu/system/files/2022-02/call-SME-friendly-training-central-purchasing-bodies_en.pdf  

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procurement  systems,  such  as  Bulgaria,  Croatia,  the  Czech  Republic,  Greece,  Hungary,  Italy, 
Latvia, Malta, Poland, Romania, Slovakia, and Slovenia.408 

Outputs and results: The action was considered by participants to be very successful in meeting 
its objectives. It provided CPBs’ staff members with an established and well-connected network of 
experts,  an  improved  interaction  with  SMEs  and  it  contributed  to  developing  fairer  and  more 
transparent  procurement  processes.  Notable  achievements  include  the  acquisition  of  valuable 
insights into daily tasks and work processes, offering a better understanding from the perspective 
of  SMEs  and  the  creation  of  an  international  network  of  CPBs’  staff  members  across  the  EU 
Member States. 

Success factors:  As emphasised by interviewees contributing to this study, key success factors 
included: increased competences of experts in public procurement, the creation of networks and 
platforms which enable concrete collaboration across regions and the elimination of entry barriers 
for SMEs thanks to the simplification of the procurement criteria and procedures that EU SMEs 
had  to  meet.  Furthermore,  it  tailored  procurement  approaches  for  smaller  countries,  simplified 
entry criteria, and provided SMEs with timely access to essential information. Barriers to SME 
entry were strategically and systematically dismantled, and the establishment of a dedicated SME 
helpline enhanced overall transparency in the process.409 The added value of the action also lies in 
the contribution to developing and consolidating networks both across CPBs and SMEs though 
workshops and events, which created new market opportunities for less -connected SMEs.410 

Challenges:  It  has  been  reported  that,  despite its successes,  the  action  faced  minor  challenges. 
Beneficiaries  from  the  action  reported  that  the  intensive  nature  of  the  programme,  requiring 
participation  six  days  a  week  might  have  been  too  intensive  for  the  attendees.  However,  such 
logistical  issues  have  been  addressed  in  the  subsequent  programme  batches.411  Visibility  and 
promotion were also perceived as minor challenges, with a need for more effective advertising and 
outreach efforts. Ineffective information-sharing practices were identified, emphasising the need 
for  clearer  communication.  Furthermore,  ensuring  SME  commitment  as  reliable  partners  was 
highlighted,  as  a  lack  of  commitment  and  understanding  of  contract  obligations  could  lead  to 
implementation issues. To address this, a feedback loop was introduced to better understand delays 
and  derive  lessons  from  these  experiences  in  collaboration  with  SMEs.  Furthermore,  the 
interviewees reported that it was appreciated that the programme was designed for subject experts 
on public procurement, however, at the same time, it was suggested that, given the specific needs 
of different sectors, it would have been highly beneficial to make sure that the number of experts 
per field attending the workshop is evenly distributed. 

Costs and Benefits: The maximum grant amount per Specific Grant Agreement (SGA) resulting 
from the first consultation for SGAs was EUR 400 000.412 While the programme's intensity posed 
scheduling  challenges,  the  in-person  format  was  deemed  highly  valuable.  The  action's  benefits 
included  improved  public  procurement  expertise,  reduced  barriers  for  SME  entry,  and  the 
establishment  of  networks,  enhancing  market  opportunities  for  less-connected  SMEs.  It  also 
simplifies entry criteria and offers a dedicated SME helpline for transparency. 

Conclusions  and  lessons  learned:  the  "Training  for  SME-Friendly  Policies  in  CPB"  action 
effectively addressed the pressing issue of SMEs' access to public procurement markets. It provided 
significant value for participants. The adjustments in the timing of the action and flexibility shown 
proved  advantageous.  It  contributed  to  establishing  a  network  of  experts  which  is  expected  to 
deliver value in the long term by facilitating the sharing of knowledge and good practices. The 
initiative also complemented existing actions in participating countries. 

408 Annex I: Details of COSME actions in 2019 
409 Feedback collected from interviews on the action: Training for SME-friendly policies in central purchasing bodies. 
410 Feedback collected from interviews on the action: Training for SME-friendly policies in central purchasing bodies. 
411 Feedback collected from interviews on the action: Training for SME-friendly policies in central purchasing bodies. 
412 https://ec.europa.eu/research/participants/data/ref/other_eu_prog/cosme/wp-call/cosme-call-cos-tsmfriend-fpa-2019-

2-02_en.pdf  

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CASE STUDY 9: ENTERPRISE EUROPE NETWORK: CARVERTICAL 

The way that EEN operates and the impact of its services on competitiveness is illustrated in the 
published  EEN  success  story  about  the  Lithuanian  business  “CarVertical”.  CarVertical  is  a 
Blockchain-based technology firm that compiles data on the previous history of second hand cars, 
providing an accurate picture of a vehicle’s history for use by potential buyers. 

Background and services provided by EEN 

The  entrepreneur  planning  to  set  up  this business  contacted an  EEN member  in  Lithuania  who 
advised him in relation to an Initial Coin Offering. The successful outcome of this provided enough 
funding to get the business up and running. EEN then successively provided various advisory and 
partnership services to support the business with growth and internationalisation. To continue its 
international expansion, CarVertical needed to access information from other European countries 
to broaden the coverage of its Blockchain database. Given the complex array of legal requirements 
and procedures across Europe for accessing this type of vehicle data, the business needed in-depth 
advice. The Lithuanian EEN member networked with EEN members across the EU to clarify the 
exact procedures to follow for accessing this data. 

Impacts of EEN services on the growth and competitiveness of this business 

The Network’s support had a significant impact on this business, and it has achieved its goal of 
rapid expansion. Within 12 months, CarVertical launched its product within 16 different countries. 
CarVertical also created jobs in Lithuania, growing from 8 to 28 members of staff as a result of the 
Network’s support. Revenue continues to increase at a rate of 30% per month. "The Network was 
one of those key factors that enabled us to scale our business fast" said the entrepreneur who created 
this business. 

Source: published EEN case study.413 

413 https://een.ec.europa.eu/success-stories/lithuanian-technology-firm-accelerates-towards-international-growth 

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