Cohesion’s action for refugees in Europe : increased flexibility but insufficient data hinders future assessment of effectiveness. Special report 05, 2025.
Date: 2025-02-13
Institutions: European Court of Auditors
Subjects: Cohesion Fund, Russo-Ukrainian issue, aid to refugees, performance audit, refugee, report

EN 

2025 

05 

Special report  Cohesion’s Action for Refugees in 

Europe 
Increased flexibility but insufficient data hinders 
future assessment of effectiveness 

 
 
 
Contents 

Executive summary 

Introduction 

The EU and member states’ response to the migratory challenges 
caused by Russian military aggression against Ukraine 

EU funding for projects addressing migratory challenges 

Amendments to the cohesion policy rules through CARE 

Roles and responsibilities 

Audit scope and approach 

Observations 

CARE measures were helpful in using the limited cohesion policy 
funding available 

Cohesion policy funding, including REACT-EU resources, constituted only a 
small proportion of overall assistance to refugees from Ukraine 

CARE flexibility mechanism considered helpful by managing authorities, but 
their use of it varied 

Reprogramming was based on needs analyses and contributed to 
the overall response to the crisis 

Funding was reallocated on the basis of an assessment of refugees’ needs 
and in line with national responses 

Reprogramming was affected by the uncertainty of an evolving situation and 
limited to the funding remaining for 2014-2020 

Projects were implemented quickly and met identified needs, but 
the effectiveness of assistance was rarely measured 

Projects were selected and implemented quickly 

Projects targeting refugees were adapted to specific situations and needs 

Participants considered projects useful, but effectiveness of granted 
assistance was rarely measured 

The Commission provided appropriate support, but lack of 
information limits the assessment of CARE’s effectiveness 

2 

Paragraph 

I-VIII 

01-14 

01-05 

06-09 

10-12 

13-14 

15-19 

20-80 

20-32 

21-23 

24-32 

33-45 

36-42 

43-45 

46-63 

47-53 

54-58 

59-63 

64-80 

 
 
3 

66-68 

69-78 

79-80 

81-87 

The Commission provided managing authorities with timely and suitable 
guidance on CARE 

Incomplete information on the use of CARE limits the assessment of its 
effectiveness 

The Commission had accepted to analyse the appropriateness of cohesion 
policy as a budgetary crisis-related measure 

Conclusions and recommendations 

Annexes 

Annex I – Examples of eligible activities co-financed by EU funds 

Annex II – Information on the audited projects 

Annex III – Detailed information on our survey 

Annex IV – Use and financial impact of CARE measures 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I On 24 February 2022 Russia launched its war of aggression against Ukraine, 
provoking mass arrivals of people from Ukraine in the EU. On 4 March 2022, the 
Council activated the Temporary Protection Directive for the first time, giving these 
displaced people (referred to in this report as refugees) the right to temporary 
protection. By the end of October 2024 there were around 4.2 million beneficiaries of 
temporary protection in the EU. To help address these migratory challenges, the EU 
gradually adapted the rules on EU cohesion policy funds by adopting three regulations 
on Cohesion’s Action for Refugees in Europe, known as CARE, CARE Plus and 
FAST-CARE, collectively referred to in this report as CARE. CARE introduced increased 
flexibility, liquidity, and simplification to make it easier for member states to finance 
related projects. It did not, however, allocate any new funding to member states. 

II The objective of the audit was to assess the use of CARE by member states and the 
available cohesion policy funds to address the specific needs of refugees. This report 
can contribute to the discussion on the effectiveness of the support and integration of 
third-country nationals in the EU and the role of cohesion policy in this process. 

III We concluded that CARE helped member states use the available cohesion policy 
funding to address the migratory challenges and the consequent needs of refugees 
arising from the war in Ukraine. These amounts were relatively small in comparison to 
the national funds used for refugees, but also to EU cohesion policy funds in general. 
The EU reacted promptly after the start of the war, and so did the member states we 
audited. However, the lack of CARE-specific data and monitoring on the use of funds is 
likely to hinder any subsequent evaluation of CARE’s effectiveness. 

IV Our audit showed that the use of CARE measures and their extent varied 
significantly between managing authorities, as the crisis did not affect all member 
states equally. The managing authorities considered that CARE was useful and 
provided them with the flexibility, liquidity and simplification measures they needed to 
react quickly to the crisis. 

 
 
5 

V We found that support was based on an analysis of refugee needs and was often 
part of the member states’ overall response to the crisis. The reprogramming of 
available cohesion policy funding, including REACT-EU resources, was affected by the 
uncertainty inherent in the evolving situation, in terms both of insufficient information 
concerning refugee flows and of the unstable political and economic situation caused 
by the crisis. In the current 2021-2027 programming period support for refugees from 
Ukraine is part of general support for third-country nationals. 

VI The projects we audited that targeted refugees were adapted to the specific 
needs and availabilities of the participants, but it was not possible to assess the overall 
effectiveness of the delivered assistance, as only three of these projects measured this. 
We found that the Commission had provided timely and suitable assistance to member 
states for the implementation of CARE and the managing authorities found that 
support useful when using CARE to address the migratory challenges. 

VII However, the general monitoring of cohesion policy funding does not cover all 
aspects of the support addressing the migratory challenges and the use of CARE. The 
Commission does not have a comprehensive overview of the programmes and 
amounts allocated under CARE, nor sufficient data on their use. Therefore, there is an 
insufficient basis for the Commission to assess CARE’s effectiveness as planned under 
its 2014-2020 ex post evaluation of cohesion policy funds. 

VIII We recommend that if the Commission were to prepare proposals for new 
crisis-related measures or amendments, it should ensure that there is an appropriate 
monitoring system with data necessary to assess their effectiveness. 

 
 
 
 
6 

Introduction 

The EU and member states’ response to the migratory 
challenges caused by Russian military aggression against 
Ukraine 

01 On 24 February 2022 Russia launched its military aggression forcing millions living 
in Ukraine to flee. As a result, the EU, and particularly its central and eastern regions, 
faced a substantial inflow of people fleeing the war. By the end of October 2024 
around 4.2 million people who had fled Ukraine were benefitting from temporary 
protection in the EU (see Eurostat data in Figure 1). 

02 In response to this mass influx of people, on 4 March 2022, the Council1 activated 
the Temporary Protection Directive2 for the first time, giving those falling under its 
scope the right to temporary protection. Initially this was granted for one year until 
4 March 2023, but it has subsequently been prolonged for further periods of one year. 
It is currently in place until 4 March 2026. 

03 Temporary protection applies to these categories of people displaced from 
Ukraine on or after 24 February 2022: 

o  Ukrainian nationals residing in Ukraine before that date; 

o 

third-country nationals other than Ukrainian or stateless people who benefitted 
from international protection or equivalent national protection in Ukraine before 
that date; 

o 

family members of these two categories. 

In addition, stateless people and nationals of third countries other than Ukraine who 
can prove that they were legally residing in Ukraine before 24 February 2022 on the 
basis of a valid permanent residence permit, and who are unable to return in safe and 
durable conditions to their country or region of origin, are entitled to either temporary 
protection or adequate protection under national law. Unlike people seeking asylum, 
those enjoying temporary protection have, among other rights, immediate residency 
rights, access to accommodation or housing, social welfare, medical care, education, 

1 

Implementing Decision (EU) 2022/382. 

2  Directive 2001/55/EC. 

 
 
 
7 

and the right to work. All those fleeing the military aggression against Ukraine are 
referred to in this report as refugees. We use this term in a broad political sense rather 
than the more narrow definition of the Geneva Convention and the EU asylum acquis. 

Figure 1 – Temporary protection granted to people fleeing Ukraine 

3 980

68 055

34 745

47 275

47 610

77 305

45 415

37 900

Ratio per 1 000 people

≥20.0

10.0 -<20.0

5.0 -<10

2.5 -<5.0

<2.5

Not available

4 198 480

EU total

108 665

120 210

85 675

983 880

1 140 705

379 370

128 345

9.3

Ratio to
EU population

3 850

66 980

59 820

83 505

38 480

175 310

10 015

25 620

66 025

165 680

221 900

64 215

32 100

21 935

670

2 185

Non-EU citizens who fled Ukraine and were under temporary protection at the end of October 2024.

Data for France does not generally include minors.
Data on the number of persons under temporary protection at the end of the month in Spain, Cyprus and Greece 
include some persons whose temporary protection status was no longer valid.

Source: Eurostat monthly statistics for October 2024 (online data codes: (migr_asytpsm, 
migr_asytpspop, demo_gind)). 

04 The large influx of refugees created significant challenges for the member states
and regions, which we refer to in this report as migratory challenges, since basic 

8 

infrastructure and services such as healthcare, transport and schools had to cater for 
more people. 

05 The assistance for these refugees has been financed from various national and/or 
international sources, including the EU budget. Numerous private initiatives have been 
undertaken by non-governmental organisations (NGOs), charity and civil society 
organisations, private companies and citizens. Local, regional and national public 
administrations have also launched initiatives. 

EU funding for projects addressing migratory challenges 

06 At EU level, the fund that provides support for legal migration to member states 
and contribute to the integration of third-country nationals is the Asylum, Migration 
and Integration Fund (AMIF)3. This fund targets the first reception and immediate 
relief stage, as well as the welcome and early integration stage. It focuses on 
education, language and other training (such as civic orientation courses and career 
guidance) and supports related infrastructure cost. People fleeing Ukraine were 
eligible for AMIF-funded integration operations. Moreover, the Fund for European Aid 
to the Most Deprived (FEAD) supports EU countries’ action to provide food and/or 
basic material assistance. 

07 Cohesion policy funds also play a role in addressing migratory challenges. They 
normally target the long-term and socio-economic integration of migrants residing 
legally in a member state. In the 2014-2020 period, the cohesion policy funds were the 
European Regional Development Fund (ERDF), the European Social Fund (ESF) and the 
Cohesion Fund (CF). In the 2021-2027 period, the cohesion policy funds are the ERDF, 
the European Social Fund Plus (ESF+), the CF and the Just Transition Fund (JTF). 
Migratory challenges are not usually the focus of cohesion policy, and its funding is 
meant to be complementary, in particular to that financed under AMIF4. 

08 In order to address migratory challenges, member states have also been able to 
use the resources of Recovery Assistance for Cohesion and the Territories of Europe 
(REACT-EU 5), established in 2020. It topped up the funding provided to them by the 
2014-2020 programmes, and was implemented through the ERDF, ESF and FEAD. 

3  The ECA has recently published a special report 26/2024 concerning the use of the Asylum, 
Migration and Integration Fund support for the integration of third-country nationals. 

4  Recital 5 of Regulation (EU) 2022/562. 

5  Regulation (EU) 2020/2221. 

 
 
 
9 

REACT-EU funding for member states amounted to €50.4 billion and was divided in 
two tranches, €39.6 billion in 2021 and €10.8 billion in 2022. 

09 In April 2022, the Commission issued an indicative list of the activities eligible 
under each fund6, with a view to member states maximising the impact of the 
spending. An overview of the different stages of support, examples of eligible activities 
and an indication of the EU co-financing instrument are provided in Annex I. 

Amendments to the cohesion policy rules through CARE 

10 To meet the new migratory challenges, the EU gradually adapted the cohesion 
policy rules to introduce increased flexibility, liquidity, and simplification to make it 
easier for member states to finance relevant projects7. In particular: 

o 

o 

o 

In April 2022, the Council and European Parliament adopted a regulation on 
Cohesion’s Action for Refugees in Europe, known as CARE8. This introduced 
measures allowing the rapid and flexible use of the available cohesion policy and 
FEAD funding. In particular, it allowed retroactive expenditure, facilitated 
cross-financing between the ERDF and ESF, and made it possible to request 100 % 
co-financing for the 2021-2022 accounting year9. 

Also in April 2022, less than a week after the adoption of CARE, the co-legislators 
adopted additional measures, known as CARE Plus10. This increased pre-financing 
rates on the 2021 REACT-EU tranche (see paragraph 08) and allowed the use of 
unit costs. 

In October 2022, the co-legislators adopted FAST-CARE11. Among other changes, 
this extended CARE cross-financing to the CF, helped projects outside of a 
programme’s geographical area to be funded, allowed the retroactive financing of 

6  People fleeing from Ukraine – Indicative list of eligible activities per fund (AMIF, ISF-Borders 

and Visa, ESF, FEAD, ERDF 2014-2020), version of 6 April 2022. 

7  Recitals 3, 4, 8, 9, 11, 12 of Regulation (EU) 2022/562; recitals 4-6 of Regulation (EU) 

2022/613; title and recitals 3, 5, 8-10 of Regulation (EU) 2022/2039. 

8  Regulation (EU) 2022/562. 

9  The possibility of 100 % co-financing is an example of flexibility that is used as a temporary 

exception to address crises as highlighted in paragraph 162 of our review 03/2024. 

10  Regulation (EU) 2022/613. 

11  Regulation (EU) 2022/2039. 

 
 
 
10 

completed projects, provided up to 100 % co-financing for the integration of 
third-country nationals, and simplified the phasing of certain operations over 
multiple programming periods12. 

11 An overview of CARE measures, classified into four groups, is provided in Table 1. 

Table 1 – Summary of the CARE regulations 

CARE 

CARE Plus 
Overall objectives 

FAST-CARE 

The three regulations aim to ease the burden on national budgets by improving liquidity and 
providing flexibility and simplification so that the available funding can be used quickly for projects 
addressing migratory challenges. In addition, FAST-CARE addresses disruptions in the implementation 
of ongoing cohesion projects due to labour shortages, supply chain difficulties and rising prices and 
energy costs. 

Funds concerned1 

ERDF, ESF, CF, FEAD 

ERDF, ESF, ESF+, CF 

Programming period 

2014-2020 

2014-2020 and 2021-2027 

Main measures introduced 

 Liquidity: 

Introducing 100 % EU 
co-financing of payment 
applications submitted 
between 1 July 2021 and 
30 June 2022 for the ERDF, 
ESF, CF and FEAD. 

Increasing the 
pre-financing rate from 
11 % to max. 45 % on the 
2021 REACT-EU 
allocation. 

 Flexibility: 

Facilitating cross-financing 
between the ERDF and ESF for 
projects addressing migratory 
challenges caused by the 
military aggression. A 
dedicated priority axis must 
be set up when this 
cross-financing is used. 

12  Refer to footnote 9. 

Introducing up to 100 % EU co-financing 
when a dedicated priority axis 
promoting the socio-economic 
integration of third-country nationals is 
established2, including when this is the 
result of using cross-financing between 
funds. 

Increasing the pre-financing rate by 
0.5 % in 2022 and 2023 for the ERDF, 
ESF+ and CF3. 

CARE cross-financing between funds 
extended to the CF. 

Facilitating funding from the ERDF, ESF 
and CF of operations located outside 
the geographical area of the 
programme but within a member state. 

Lowering the minimum threshold for 
total project cost from €5 million to 
€1 million for projects phased from 
2014-2020 to 2021-2027 programmes3. 

Increasing flexibility across priority axes 
at closure from 10 % to 15 %. 

 
 
 
 
 
 
 
 
 
CARE 

CARE Plus 

FAST-CARE 

11 

 Eligibility: 

Introducing retroactive 
eligibility to 24 February 2022 
for expenditure even if it was 
incurred before the 
amendment of the 
operational programme was 
submitted to the Commission. 
Applicable to projects 
addressing the migratory 
challenges co-funded by the 
ERDF, ESF and FEAD. 

Introducing a unit cost of 
€40 per week for every 
person granted 
temporary protection, for 
a maximum of 13 weeks. 

 Administrative 

simplification: 
Reducing ESF reporting 
obligations when a dedicated 
priority axis using 
cross-financing is introduced. 

Simplifying the FEAD 
programme amendment 
procedure. 
100 % co-financing option 
only requires notification to 
the Commission. 

Introducing retroactive eligibility to 
24 February 2022 for projects that were 
physically completed and fully 
implemented before the beneficiary 
applied for funding under the 
programme and/or before a 
programme amendment was approved. 
Applicable to projects addressing the 
migratory challenges, co-funded by the 
ERDF, ESF, and CF. 

Introducing the obligation to assign 
30 % of the financial allocation to a 
dedicated priority axis using CARE 
cross-financing (2014-2020) or a 
dedicated priority for the integration of 
third-country nationals (2021-2027) 
whose beneficiaries are local 
authorities or civil society organisations 
operating locally. 

Increasing the unit cost per person to 
€100 per week and up to 26 weeks. 

Simplifying ERDF, ESF and CF 
programme amendments for transfers 
between thematic objectives of the 
same priority axis and when opting for 
100 % co-financing. 

Reduced ESF reporting obligations 
extended to other priority axes only 
supporting projects addressing the 
migratory challenges. 

1  FAST-CARE also included some provisions on the European Maritime and Fisheries Fund (EMFF). 

However this is outside cohesion policy so is not covered by this audit. 

2  Relevant also for the 2021-2027 period but only for expenditure declared in payment applications 

until the end of the accounting year (30 June 2024). 
3  Only relevant for the 2021-2027 programming period. 

Source: ECA. 

12 CARE, CARE Plus and FAST-CARE (referred to collectively in this report as CARE) 
did not allocate new funding to member states. Instead, it gave them the discretion to 
swiftly direct funding remaining from 2014-2020 programmes, including REACT-EU 
resources, to operations addressing the migratory challenges. CARE was established as 
a flexibility mechanism to use EU funds to alleviate the burden on public budgets, 
rather than a new instrument to finance assistance for refugees. 

 
 
 
 
 
 
 
 
 
 
 
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Roles and responsibilities 

13 The management of cohesion policy is shared between member states and the 
Commission. The Commission departments responsible are the Directorate-General 
for Regional and Urban Policy (DG REGIO) and the Directorate-General for 
Employment, Social Affairs and Inclusion (DG EMPL). They make the assessments 
leading to the Commission’s approval of 2014-2020 and 2021-2027 programmes and 
subsequent amendments submitted by member states, as well as monitoring 
implementation and evaluating the effectiveness and efficiency of funding. 

14 At member state, regional or local level, designated managing authorities are 
responsible for implementing cohesion policy funding through programmes. They 
propose programme amendments for approval by the Commission, establish and apply 
appropriate selection procedures and criteria, enter into grant agreements with 
beneficiaries for the selected projects and monitor implementation, and report on 
output and results. 

 
 
 
 
13 

Audit scope and approach 

15 The objective of the audit was to assess the use of CARE by member states, and 
the available cohesion policy funds, to address the needs of refugees. We examined 
whether: 

o 

o 

o 

the member states reprogrammed funds available from the 2014-2020 period 
and used the CARE measures effectively; 

the projects implemented to assist refugees were selected swiftly, were based on 
needs’ analyses and improved refugees’ circumstances; and 

the Commission’s support to member states during the crisis and its monitoring 
of the use of funding were appropriate. 

16 We examined the application of the three CARE regulations. We covered both the 
2014-2020 and the 2021-2027 programming periods. Our audit covers the period from 
24 February 2022 (the beginning of the war in Ukraine) until the end of 2023. Our audit 
did not cover national funding used by member states to respond to the crisis. 

17 We collected evidence from: 

o 

o 

o 

Review of EU legislation (including the CARE regulations), and relevant reports, 
statistics and analyses published by the EU, member states, NGOs and experts. 

Interviews with staff from the relevant Commission departments – DG REGIO, 
DG EMPL and the Directorate-General for Migration and Home Affairs 
(DG HOME) – and representatives of national and regional administrations. 

A sample of four member states (Bulgaria, Germany, Italy and Poland) from which 
we analysed the relevant strategic policy frameworks, and two programmes from 
each of the 2014-2020 and 2021-2027 periods, including amendments in the 
context of CARE. We selected these four member states as they used CARE 
measures, and were a mix of states both neighbouring and not neighbouring 
Ukraine, and states with and without previous experience in receiving refugees. 
We also took into account the number of registrations for temporary protection, 
including relative to the general population. 

 
 
14 

o  On-the-spot audit work in the four member states, where we examined a sample 
of 18 projects and 11 grants from the 2014-2020 period (see Annex II). We 
selected the projects based both on their size and the range of the assistance 
offered. We covered both completed and ongoing projects. We analysed the 
project applications, selection procedures, grant approval, documentation and 
implementation reports. We interviewed staff of, and participants in, the audited 
projects, and representatives of NGOs. 

o 

A survey in all member states of all managing authorities dealing with the ERDF, 
ESF and CF in the 2014-2020 and 2021-2027. The aim was to obtain information 
on whether they were using the CARE measures and, if not, why, and the 
measures they found most useful (see Annex III). We also asked their views on 
the support provided by the Commission. We received responses from 
143 managing authorities, representing 38 % of those surveyed. 

18 We carried out this audit in the context of the ongoing war in Ukraine and 
continuing supporting from both the EU and member states for refugees. This allowed 
us to provide relevant information on how the available EU funding had been, and was 
still being, used. 

19 We hope that together with our report on the use of the Asylum, Migration and 
Integration Fund support for the integration of third-country nationals13, this report 
will contribute to the discussion on the effectiveness of the support for, and 
integration of, third-country nationals in the EU, and the role of cohesion policy in this 
process. 

13  See our special report 26/2024. 

 
 
 
 
 
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Observations 

CARE measures were helpful in using the limited cohesion 
policy funding available 

20 CARE provided member states with flexibility, liquidity and simplification to 
facilitate the use of cohesion policy funds to respond swiftly to migratory challenges 
(see Table 1). We examined whether member states availed themselves of the CARE 
measures and found them useful. 

Cohesion policy funding, including REACT-EU resources, constituted only 
a small proportion of overall assistance to refugees from Ukraine 

21 In response to the crisis, national, international and EU funding was mobilised in 
the member states. In addition, there was a significant number of private initiatives by 
NGOs, charities and civil society organisations, companies, and citizens. 

22 In terms of 2014-2020 cohesion policy funding (ERDF, ESF, CF), member states 
only had limited remaining funds available. There was under two years left until the 
end of the eligibility period (31 December 2023) when the war in Ukraine started, and 
most cohesion policy funding, including REACT-EU resources (2021 tranche), had 
already been earmarked (see Figure 2). Member states had already used cohesion 
policy funding for healthcare and support for businesses to address the impact of the 
COVID-19 pandemic. See our special report 02/2023. The 2022 tranche of REACT-EU 
amounting to €10.8 billion was still to be programmed within that year, but no new 
funding was made available specifically for supporting refugees from Ukraine 
(see paragraph 12). 

 
 
16 

Figure 2 – 2014-2020 cohesion policy funding, including REACT EU 
resources (2021 tranche), earmarked for projects at the end of 2021 

Audited member states

Other member states

10

20

30

40

50

60

70

80

90

100

110

120

130

140

1

100 %
benchmark
of planned funding 
earmarked for projects*

Ireland

Sweden

Italy

Bulgaria

Spain

Malta

Slovakia

Denmark

Latvia

Belgium

Poland

Estonia

Germany

Luxembourg

United Kingdom

Finland

Austria

Czechia

France

Cyprus

Hungary

Lithuania

Slovenia

Netherlands

Portugal

Croatia

Greece

Romania

* Member states can earmark more than 100 % of the funds available, as some of the projects will not 
use all the funds allocated. 

Source: ECA based on data from the Cohesion Open Data Platform. 

 
 
 
17 

23 There is no complete and reliable information on the total amounts of funding 
that member states used to respond to the crisis. The national authorities we audited 
did not collect such data, as they were not obliged to do so, and neither did the 
majority of those we surveyed. However, there are clear indications in two of the 
member states we audited that national funding (not subject to our audit) was 
significantly higher than the funding available through CARE (see Box 1). 

Box 1 

In two member states we audited, EU support for refugees 
represents less than 5 % of national funding 

Poland 

Poland’s Aid Fund provides financing and co-financing for support to Ukrainian 
citizens affected by the war who have found shelter in Poland. 

According to the annual report of the Polish Supreme Audit Office, the 
expenditure from the Aid Fund in 2022 amounted to PLN 13.9 billion 
(approximately €3 billion). 

In comparison, according to Commission data, Poland allocated €70 million from 
2014-2020 programmes (approximately 2 % of Aid Fund expenditure) to assist 
refugees. 

Italy 

We estimate that, up to February 2024, around €1.3 billion of national funding 
was allocated to support refugees on Italian territory. In comparison, according to 
data received from the Commission, Italy allocated €60 million for the same 
purpose from the cohesion policy funds (4.6 % of the allocated national funding). 

CARE flexibility mechanism considered helpful by managing authorities, 
but their use of it varied 

24 The influx of refugees and related migratory challenges did not affect all member 
states equally (see Figure 1). Our audit showed that the use and extent of CARE 
measures varied significantly among managing authorities (see Figure 3 as well as an 
overview of the use and financial impact of CARE measures in Annex IV). For example, 
in the 2021-2022 accounting year, Italian programmes only took advantage of the 
possibility of 100 % co-financing, whereas the Polish and German programmes made 
use of several other CARE measures. In general, all managing authorities we audited 

 
 
18 

considered that CARE was useful and provided member states with the flexibility they 
needed to react to the crisis quickly. 

Figure 3 – Use of CARE measures by selected programmes 

Italy

Germany Poland Bulgaria

100 % co-financing rate for the 2021-2022 
accounting year

LIQUIDITY

Up to 100 % co-financing rate for a dedicated priority 
axis promoting the socio-economic integration 
of third-country nationals

ELIGIBILITY

Retroactive eligibility of operations and expenditure

Simplified transfer of financial allocations between 
thematic objectives (CPR* Article 30(6))

FLEXIBILITY

Increased flexibility across priority axes at closure from 
10 % to 15 %

Simplified programme amendment procedures

SIMPLIFICATION

Unit cost linked to basic needs and support of people 
granted temporary protection

Reduced ESF reporting obligations when a dedicated 
priority axis to address the migratory challenges is 
introduced

* 2014-2020 Common Provisions Regulation. 

Source: ECA. 

 
 
 
19 

25 According to our survey, 72 (55 %) of the managing authorities that replied to the 
relevant question (see Annex III) indicated that they used CARE measures. They were 
responsible for managing at least 74 cohesion programmes for 2014-2020. Conversely, 
59 (45 %) managing authorities stated that they did not use any CARE measures for the 
2014-2020 programmes for one or more reasons. This was mainly due to the lack of 
programme funding since it had already been earmarked for other operations or 
because national or other funds were considered more suitable (see Figure 4). 

Figure 4 – Survey respondents’ reasons for not using CARE measures 

56 %

44 %

22 %

14 %

10 %

6 %

6 %

Cohesion policy 
funding was 
already 
earmarked for 
other operations

REACT-EU 
funding was 
already 
earmarked for 
other operations

National funds 
were considered 
more suitable

Other

Legal 
uncertainty of 
the flexibilities

Other funds 
considered to 
be better suited

Types of 
operations 
implemented 
were not eligible 
under cohesion 
policy

Note: The respondents could choose more than one reply to this question. 

Source: ECA survey. 

26 We found that the CARE measure which was most often used was the possibility 
of 100 % co-financing (see Annex IV). The managing authorities could use this for 
payment applications submitted between 1 July 2021 and 30 June 2022. They could 
also apply up to 100 % co-financing for expenditure within a dedicated priority 
established for the socio-economic integration of third-country nationals, including 
dedicated priority axes established as a result of using CARE cross-financing between 
funds. 

 
 
 
20 

27 In addition to permitting 100 % co-financing, the requirements linked to some of 
the CARE flexibilities provided an incentive to use dedicated priority axes addressing 
the migratory challenges, which enabled managing authorities to simplify and 
accelerate the implementation of projects (see Box 2). 

Box 2 

Advantages of establishing a dedicated priority axis to address 
migratory challenges 

The Polish regional programme for Pomerania established a dedicated priority axis 
with a total allocation of €5.4 million. 

The managing authority indicated that support for refugees was complex as it 
needed to meet multiple needs, such as subsistence and care support, healthcare, 
language courses, legal and psychological assistance, career guidance and 
vocational training. Implementing such varying activities under different thematic 
axes would normally have required a separate project for each activity, multiplying 
the administrative burden. 

However, the dedicated priority axis simplified and accelerated the 
implementation process, as one project could cover multiple operations. 

28 Another CARE measure often used by the managing authorities were the rules 
allowing the retroactive eligibility of expenditure and projects. The aim (see example 
in Box 3) was to enable member states to prioritise implementing the projects, and to 
formalise the related programme amendment or project application documents at a 
later date. 

Box 3 

Example of the retroactive eligibility of expenditure 

In one project, Bulgaria offered accommodation and hot meals to refugees 
between 24 February and 30 April 2022. The project was initially funded by the 
national budget, but the national authorities then used CARE retroactive financing 
to cover part of the incurred expenditure from the cohesion policy funds. 

29 Some CARE liquidity measures required no prior action on the part of the 
managing authorities. For example, the Commission provided a higher rate of initial 
prefinancing on the 2021 REACT-EU tranche and 2021-2027 programmes without the 
need for a specific request. 

 
 
21 

30 CARE14 introduced a unit cost option for operations addressing migratory 
challenges. The unit cost was set at €40 per week for each full or partial week a 
refugee was in the member state concerned, up to a maximum of 13 weeks, starting 
from the date they arrived in the EU. This was subsequently increased to €100 per 
person per week, and the duration of support extended to 26 weeks15. 

31 The unit cost option was only used by 7 % of the managing authorities we 
surveyed. However, one of the projects we audited did use this flexibility (see Box 4). 

Box 4 

An example of unit cost use 

A project in North Rhine-Westphalia used the unit cost option to partially finance 
the costs incurred by refugee reception facilities. 

As the first step in the integration process, refugees could use the short-term 
accommodation in the reception facilities upon their arrival. The facilities also 
provided them with assistance such as healthcare, legal information and 
registration, translation and interpretation services, labour market integration 
activities, administrative support, and language courses. 

Instead of using the actual number of refugees that were housed and the actual 
time they spent there, the managing authority agreed with the Commission an 
alternative basis for the calculation of the costs incurred. It used the number of 
Ukrainian nationals registered in the central register for foreigners after 
28 February 2022, and assumed an average 6-week stay in reception facilities for 
each of them. 

32 The Commission was in close contact with the member states, taking into 
account their specific circumstances, regarding the implementation of the CARE 
provisions. In October 2022, FAST-CARE introduced an obligation for at least 30 % of 
the financial allocation under the priority axis making use of CARE special 
cross-financing to be attributed to operations implemented by local authorities and 
civil society organisations operating in local communities. In one Bulgarian programme 
we audited (see Box 3), the managing authority reported that the relevant programme 
expenditure had already been incurred in May 2022, before FAST-CARE came into 
force. In response, the Commission provisionally signalled that it would not enforce 
the 30 % obligation in cases where funds had been committed to such an extent, 

14  CARE Plus: Regulation (EU) 2022/613. 

15  FAST-CARE: Regulation (EU) 2022/2039. 

 
 
 
22 

before the Regulation entered into force, that it was no longer possible to comply. 
When assessing the closure of the Bulgarian programme, the Commission will confirm 
whether and to what extent the obligation can be waived in this specific case. 

Reprogramming was based on needs analyses and contributed 
to the overall response to the crisis 

33 When reprogramming 2014-2020 cohesion policy funding, including REACT-EU 
resources, and using CARE measures, member states were required to design 
measures that addressed the needs of refugees. They also had to comply with 
partnership requirements and were encouraged to co-operate with other stakeholders 
(including migrant and refugee-led organisations) and build on their experience16. 

34 According to the “10-point plan for stronger European coordination on 
welcoming people fleeing the war from Ukraine”, member states should have 
developed national contingency plans to address the needs of refugees. We 
understand this to mean a national plan setting out what action is to be taken in an 
emergency and who is responsible for taking it. In two of its toolkits, the Commission 
encouraged aligning EU-funded measures for people with a migrant background with 
national, regional and local integration policy frameworks. We understand an 
integration policy framework to mean a member state’s / region’s / local authority’s 
policies to support the integration of migrants in areas where they may face 
challenges, such as accommodation, employment and education. 

35 We therefore assessed whether the reprogramming of 2014-2020 cohesion policy 
funding to address migratory challenges was appropriate. We also examined whether 
the interventions supported by the cohesion policy funds were sufficiently aligned with 
the integration policy frameworks and member states’ overall responses to the 
emergency. 

16  Articles 5 and 96 of Regulation (EU) 1303/2013; Articles 8, 10, 11 and 22 of Regulation (EU) 
2021/1060; Toolkits on the use of EU funds for the integration of people with a migrant 
background, European Commission, 2018 and 2021 (point 4.2. Coordinated use of funds). 

 
 
 
23 

Funding was reallocated on the basis of an assessment of refugees’ 
needs and in line with national responses 

36 Refugees have various needs, which dictate the timing of assistance. The needs 
can be divided into the following stages: 

o 

first reception and immediate relief, e.g. basic material assistance, consumables 
such as food and drink, personal care items, pharmaceutical products, transport 
services, immediate healthcare and information on legal rights and procedures, 
translation and interpretation services; 

o  welcome and integration, e.g. suitable accommodation, medical care, transport 
services, food and basic material assistance, language courses, day-care support 
for children and people with disabilities, schooling for children, civic orientation 
and information services; 

o 

support for long-term integration, such as access to social and healthcare 
services, sustainable accommodation, education and the labour market. 

In addition, the organisations supporting refugees have needs such as specific 
equipment, consumables and training for employees and volunteers. 

37 The managing authorities we audited indicated that the reprogramming of the 
2014-2020 programmes was based on refugee needs identified through exchanges 
with stakeholders such as civil society organisations. Needs were identified centrally 
(Bulgaria), at regional/local level (Germany) and both centrally and at regional or local 
levels (Italy, Poland). However, only Polish (see Box 5) and Italian managing authorities 
documented their needs analyses. 

Box 5 

Documented needs analysis 

The managing authority of the Pomeranian regional programme conducted a 
survey among NGOs (April and May 2022) and local governments (July 2022) 
working directly with refugees, concerning their needs and the best approach to 
assistance. The results of the survey were documented and used as a basis for 
preparing the programme amendment and designing projects (see Box 8 and 
Box 9). 

 
 
24 

38 Three out of the four member states we audited had experience of integrating 
refugees (Bulgaria, Germany and Italy). However, only two Italian managing authorities 
had previously supported similar operations for immigrants through the cohesion 
policy funds. They had therefore capitalised on their prior experience when designing 
calls for proposals and projects targeting refugees. 

39 In most cases, the managing authorities we audited reallocated the available 
cohesion policy funding, including REACT-EU resources, to finance interventions that 
were part of the overall national or regional response to the emergency. Some projects 
simply involved partially reimbursing expenditure already incurred by national or 
regional budgets (examples in Box 3 and Box 4). The Italian national programme we 
audited financed projects for refugees through the usual programme assistance for 
third-country nationals, i.e. there were no measures targeting only the refugees from 
Ukraine. 

40 All the member states we audited had national integration policy frameworks for 
third-country nationals in place before the war in Ukraine, even if the level of 
development and details of such national integration policy frameworks differed from 
one member state to another. In Italy and Poland these frameworks also existed at 
regional level. Bulgaria, Italy and Poland had national contingency plans in place. We 
found that the managing authorities we audited had allocated the available 2014-2020 
cohesion policy funding, including REACT-EU resources, in line with these frameworks. 

41 As regards the 2021-2027 period, for the programmes we audited the support for 
refugees is planned as part of the general support for third-country nationals. Most 
managing authorities we audited confirmed that the war in Ukraine had not impacted 
the preparation of programmes in terms of directing funding specifically towards 
refugees or allocating more funding for third-country nationals. The amounts 
programmed for support to third-country nationals only increased in the case of 
Poland (by 15 % for the national programme, and by 44 % for the regional programme 
we audited). 

42 The Commission indicated that 76 programmes for 2021-2027 allocated around 
€1.6 billion specifically to support operations for the integration of third-country 
nationals (of which €971 million in EU funding and the remainder in national funding). 
Third-country nationals, depending on the eligibility rules, may also benefit from EU 
funding programmed under other operations. Therefore, this provides only a partial 
view of the support that the target group might receive. 

 
 
25 

Reprogramming was affected by the uncertainty of an evolving situation 
and limited to the funding remaining for 2014-2020 

43 As described in the introduction (see paragraph 12), CARE did not allocate any 
new funding to member states but rather facilitated their use of the cohesion policy 
funding available. However, this funding was limited because the funds had been used 
to address the COVID-19 pandemic and the eligibility period was coming to an end (see 
paragraph 22). 

44 In the eight programmes we audited, only a relatively small amount of funding 
(including REACT-EU), remained available to address the migratory challenges resulting 
from the Ukrainian crisis. For example, for ESF North Rhine-Westphalia, the amount 
used under CARE (€ 49 million) was one of the largest we audited but represented only 
3.5 % of the total programme’s allocation (€ 1.41 billion). The Polish managing 
authorities we audited, and one of the Italian ones, calculated the possible allocation 
still available within the programmes. In Bulgaria and Germany, the managing 
authorities also used the available REACT-EU funding that was not yet programmed. 

45 At the same time, the information concerning the flows of refugees from Ukraine 
and the resulting need for support was either non-existent or very vague. The 
managing authorities we audited therefore faced difficulties when reprogramming (see 
two examples in Box 6). As a result, some of the cohesion policy funding, including 
REACT-EU resources, committed using measures offered by CARE was not spent. 

 
 
26 

Box 6 

Difficulties faced by managing authorities reprogramming available 
2014-2020 cohesion policy funding, including REACT-EU resources, in 
the context of CARE 

Bulgaria 

The operational programme “Human Resources Development” was amended by 
increasing the priority axis 6 budget by €23.8 million. The whole amount was 
allocated to a newly created project to integrate refugees into the labour market 
by subsidising their salaries. Due to declining interest from refugees – who saw 
Bulgaria as a transit rather than host country – the budget of the project was 
reduced to €6.9 million (29 % of the initial amount). 

Poland 

Under one of the programmes we audited, the unstable political and economic 
situation on Poland’s eastern border caused an additional difficulty in the 
reallocation of funds, resulting in projects being reduced in scope or cancelled. To 
avoid losing unspent funds, the managing authority used FAST-CARE to re-direct 
funding to projects supporting refugees, as well as to other projects where such 
support had not been initially planned. 

Projects were implemented quickly and met identified needs, 
but the effectiveness of assistance was rarely measured 

46 The crisis caused by the war in Ukraine required immediate action. Projects 
mitigating its consequences had to be selected without undue delay, and had to meet 
the objectives and quantifiable targets set in the grant agreement. The managing 
authorities were required to check that the co-financed products and services had 
been delivered, and that the operations were legally compliant and met the 
programme conditions17. We checked to what extent this was the case for the projects 
we audited. 

17  Article 125(3) and (4) of Regulation (EU) 1303/2013. 

 
 
 
27 

Projects were selected and implemented quickly 

47 We confirmed that the managing authorities we audited had started the 
procedures to select projects assisting refugees promptly, irrespective of the type of 
procedure, competitive or not (see Figure 5). 

Figure 5 – Timing of selection procedures for projects in our sample 

Competitive procedure
Non-competitive procedure

ı April

Start of a competitive 
procedure in Italy
(3 projects in sample)

ı September

Start of competitive procedure 
in Germany (4 projects in 
sample)

ı Non-competitive procedure 

in Poland (2 projects in 
sample)

2023

Start of the 
military 
aggression 
against Ukraine
24 February 2022

ı May

Non-competitive 
procedure in Bulgaria   
(1 project in sample)

Source: ECA. 

ı March

First round of non-
competitive procedure 
in Italy (4 projects in 
sample)

ı June

Second round of non-
competitive procedure 
in Italy

ı July

Non-competitive 
procedure in Bulgaria 
(1 project in sample)

ı Start of non-

competitive procedure 
in Germany (1 project 
in sample)

48 Because of the emergency situation, the managing authorities we audited in 
Bulgaria and Poland did not use competitive procedures to select projects, but rather 
selected specific, pre-defined beneficiaries to implement them. The schools that were 
potential beneficiaries of one call for projects implemented under the Italian national 
operational programme “Scuola” had also been selected before the call was issued, 
based on whether they had any enrolled refugees. 

49 One German managing authority (ESF North Rhine-Westphalia) used the unit cost 
approach allowed by the CARE regulations to finance existing regional short-term 
accommodation and its first welcome measures (see Box 4). Therefore, there was no 
need for a competitive procedure. 

 
 
 
 
28 

50 Two of the managing authorities we audited (one in Lazio, Italy, and one in 
Lower Saxony, Germany) did use competitive procedures to select projects supporting 
refugees. However, this did not slow down the support delivered to refugees (see 
example in Box 7). 

Box 7 

Using competitive procedures to select projects 

Italy 

The managing authority for the ESF regional programme for Lazio launched a 
public call for projects to create and develop a network of integrated active policy 
initiatives to support refugees. A public call ensured the widest participation of 
eligible beneficiaries. 

The call was published in April 2022, six weeks after the start of the war and the 
list of selected projects was approved in June 2022. 

Germany 

The managing authority for the regional programme for Lower Saxony prepared 
two funding guidelines (calls). 

One was a call for projects to support language learning. It was published on 
14 September 2022 and the main objective was for participants to acquire basic 
German language skills through language courses. The courses were to be 
accompanied by socio-pedagogical support and childcare for the children of 
participants. 

The other call, published on 1 September 2022, was for projects to support “good 
neighbourhood” initiatives. It provided financial support for projects in the field of 
community development and neighbourhood management, with the aim of 
promoting the integration of refugees from Ukraine in Germany. 

Both calls were published approximately seven months after the start of the war, 
and projects were approved as applications were received. 

 
 
29 

51 The implementation period of the projects we audited started as early as 
March 2022, with the majority commencing between June and October 2022 
(see Figure 6). 

Figure 6 – Start of implementation periods of the projects in our sample 

Start of the military 
aggression against 
Ukraine
24 February 2022

March

June
to August

September
to October

February

May to September

2023

2022

One symbol = 
one project

Bulgaria

Germany

Italy

Poland

Source: ECA. 

52 Out of 16 projects specifically targeting refugees that we audited, five only 
started in 2023, but they were addressing medium-term and long-term needs. 
Therefore, their selection and implementation naturally followed the first reception 
and immediate relief: 

o 

o 

a German project that started in February 2023 involved two courses on 
job-specific language skills for health professionals, as well as offering the 
possibility of job-shadowing and childcare for the children of participants 
(see Annex II, Germany, project 4); 

similarly, four Italian projects funded under the audited national programme and 
implemented between May and September 2023 were aimed at strengthening 
language skills and improving the inclusion of pupils and students, including 
refugees, and their families (see Annex II, Italy, projects 4-7). In this case the call 
and the projects were also meant to facilitate the integration process over the 
summer period. 

 
 
 
30 

53 The uptake rate following competitive procedures, i.e. committing funds by 
signing grant agreements, among the two managing authorities we audited that used 
them was varied: 

o 

o 

In Italy one call had 100 % uptake (the selected projects were enough to commit 
all planned funding), whereas the uptake of another was only modest. In the case 
of the latter, the managing authority indicated that the reason was that potential 
families and students from Ukraine had moved to other locations or 
accommodation, and there was a lack of interest in Italian language classes. This 
was confirmed by the project beneficiaries. 

In Lower Saxony the uptake of two calls was modest due to the limited time for 
implementing projects. The co-financing of the “good neighbourhood” call was 
only a top-up for existing projects, used to finance additional staff and include 
refugees among the participants. Due to the short implementation period in the 
call, potential beneficiaries were hard-pressed to find employees willing to accept 
such short-term contracts. Moreover, many of the positions offered were 
part-time, further explaining the low uptake. 

Projects targeting refugees were adapted to specific situations and 
needs 

54 We assessed whether the projects we audited were designed after a needs 
analysis and tailored their activities based on those needs. We found that while 
designing the selection procedures and projects, the beneficiaries and managing 
authorities were guided by the needs of the refugees and, if available, previous 
experience of implementing integration projects. An example of a needs analysis 
leading to a project design is presented in Box 8. 

 
 
31 

Box 8 

Designing a project to meet identified needs 

The idea of organising a Polish language course for teachers from Ukraine first 
emerged in March 2022. A survey and a study on the interest in developing Polish 
language skills among teachers from Ukraine were conducted in April and 
May 2022. The survey involved 320 teachers from Ukraine, of whom 180 wanted 
to work as a teacher in Poland and took part in the study. 

The study identified the need for: 

o 

o 

o 

conducting an intensive Polish language course tailored specifically to 
teachers from Ukraine; 

support enabling teachers from Ukraine to take part in the course; 

support with joining the Polish education system as teachers. 

The project aimed at enabling teachers from Ukraine to work in Polish schools by 
organising relevant Polish language courses. The training included modules on the 
organisation and administration of the Polish education system. Accommodation, 
catering, and childcare (for the children of participants) were also provided. More 
details about the project are included in Annex II (Poland, project 3). 

55 In relation to the war in Ukraine, the Commission issued an indicative list of 
eligible activities under the relevant funding instruments (see paragraph 09). The 
activities implemented within the projects we audited shown in Figure 7, are 
categorised according to the Commission’s indicative list. 

 
 
32 

Projects not specifically 
targeting people fleeing 
Ukraine

Labour market activation 
measures, vocational education 
and training (one project in 
Poland)

Infrastructure developments 
(building/refurbishing/extending) 
and related equipment (including 
responding to the needs of 
people with disabilities) through 
improved access to services in 
non-segregated healthcare (one 
project in Poland)

Figure 7 – Eligible activities in a sample of projects 

First reception and 
immediate relief

Welcome and integration

Accommodation and catering (one 
project in Bulgaria)

Civic orientation and interaction 
with the host society (two 
projects in Germany)

Accommodation, consumables, 
immediate healthcare, translation and 
interpretation services, administrative 
support, labour market activation 
measures (one project in Germany)

Language courses (one project in 
Germany)

Mainstream support for long-term integration into the host society

Labour market activation measures 
(one project in Bulgaria)

Job-specific language training (one 
project in Germany, one project in 
Poland)

Access for women to the labour 
market, language courses, recognition 
of qualifications and competences, 
family care services (one project in 
Italy)

Language courses, access to 
healthcare services, support for 
vulnerable groups, programme to 
develop competences (one project in 
Italy)

Source: ECA. 

Labour market activation 
measures, vocational education 
and training, language courses, 
access to healthcare services (one 
project in Italy)

Remedial classes, language 
courses, extracurricular activities, 
vocational education and 
training, programme to develop 
competences, access to 
healthcare services, assistance 
with finding employment, 
guidance, counselling (four 
projects in Italy)

Community building, access to 
social services, accompanying 
support, access to healthcare 
services, access to day-care 
services, language courses, 
remedial classes for children, 
vocational education and 
training, training of staff and 
volunteers (one project in Poland)

56 Our audit of the projects confirmed that, depending on the specific situation in 
the member state or region, managing authorities and beneficiaries designed projects 
to meet the identified needs of refugees (see Annex II). 

57 Eleven out of the 18 projects in our sample implemented the support for the 
long-term integration into the host society of the refugees. They offered various 
activities, such as language courses, professional training, psychological support, 

 
 
 
33 

physiotherapy, activities to facilitate the integration into the local community, civic 
orientation, and subsidised employment. Only two projects (one in Bulgaria and one in 
Germany) focused on the first reception and immediate relief stage. 

58 Our survey of managing authorities that funded projects targeting refugees 
showed that 21 % financed mainstream support for long-term integration into the host 
society, 17 % financed welcome and integration measures, and 15 % financed the first 
reception and immediate relief measures. 

Participants considered projects useful, but effectiveness of granted 
assistance was rarely measured 

59 Of the 18 projects we audited, 16 specifically targeted refugees and had varied 
results. However, only three of these 16 projects measured the effectiveness of the 
assistance provided (see details in Figure 8). 

Figure 8 – Results of the projects in our sample 

Projects specifically targeting refugees
(total of 16 projects)

Higher number of participants 
than planned

Lower number of participants 
than planned

Without any quantifiable 
targets

Source: ECA. 

9

5

2

3

Measured the 
effectiveness of the 
provided assistance

60 In nine of the projects we audited, more participants benefited than initially 
planned. This was the case for one Polish, one Bulgarian, three German and four Italian 
projects (see an example in Box 9). The nature of the project activities allowed more 
people to take part than initially expected. As a result, more refugees had access to the 
support offered. 

 
 
 
34 

Box 9 

Support provided to more participants than initially expected 

The main objective of one project in Poland was to support refugees settling in 
Pomerania, and to permanently strengthen their societal, professional, 
educational, health and cultural integration. 

The project beneficiary organised two calls for proposals and approved 81 grants, 
63 of which were awarded to NGOs and 18 to local governments. We audited 
three grants awarded within the project. 

The project achieved a higher output than initially planned mainly due to the 
possibility of accepting more participants in the activities organised. The number 
of actual participants was almost double that initially planned, and training was 
provided to four times the planned number of staff and volunteers. The reported 
social effectiveness indicator reached 81 % (the minimum required was 34 %). 

61 However, only three of the projects we audited – two in Poland and one in 
Bulgaria – both reported participant numbers and measured the effectiveness of the 
assistance. The two projects in Poland (see Box 8 and Box 9) reported on what was 
described by the managing authorities as the “social effectiveness indicator”. This 
indicator determines the proportion of participants who have made progress in 
entering the labour market and developing the skills necessary to live in the host 
community after receiving support. In most cases this indicator is a subjective 
assessment by the participant. The project in Bulgaria (see Box 6) reported that 48 % 
of refugees employed within the project remained in employment afterwards. 

62 For some projects, we were able to interview participants who had benefited 
from the assistance provided and confirmed that the support delivered improved their 
situation at the time. Participants found the assistance provided through the projects 
useful, timely and met their most urgent needs. Some of them had managed to find a 
job or start their own business as a result of their participation. 

63 Five projects – one in Bulgaria, three in Italy and one in Poland – had fewer 
recipients than originally estimated. The beneficiaries identified several factors that 
negatively impacted implementation, such as: 

o 

the initial unwillingness and inability of final recipients to integrate into the host 
country, learn the language, and find employment, due to the expectation that 
the conflict would be swiftly resolved and they would soon be able to return to 
Ukraine or their home country; 

 
 
35 

o 

o 

the cost of travelling to the location of the projects, the location of housing, the 
duty to care for family members under their responsibility (children, older 
relatives or relatives with disabilities), or work commitments; 

the subsequent relocation of the refugees to other places or back to Ukraine or 
their home country. 

The Commission provided appropriate support, but lack of 
information limits the assessment of CARE’s effectiveness 

64 The Commission should provide support to facilitate the implementation of CARE. 
When evaluating cohesion policy funding, including REACT-EU resources, it should 
examine the effectiveness of the use of resources 18. To be able to do so, the 
monitoring and reporting system should provide the Commission with comprehensive 
data and information on implementation. 

65 We examined whether the Commission’s support for CARE measures was timely 
and suitable. We also examined whether the Commission monitors member states’ 
use of cohesion policy funding, including REACT-EU resources, to address the 
migratory challenges, as well as the use of the CARE mechanism. 

The Commission provided managing authorities with timely and suitable 
guidance on CARE 

66 We found that the Commission’s support for the implementation of CARE was 
delivered to member states through various tools, such as: 

o 

o 

The CARE Q&A database accessible to all managing authorities. This was created 
in March 2022 and includes Commission replies to member states’ questions on 
using EU cohesion policy funding and on the CARE provisions for addressing the 
migratory challenges. It also provides information on key topics such as the 
eligibility of expenditure and the use of unit costs. 

The Commission organised two webinars, one in May 2022 on the CARE 
provisions and the use of unit costs, and another in July 2022 on project 
management in cohesion policy in the context of public procurement and cost 
increases. 

18  Article 57 of Regulation (EU) 1303/2013 and Article 2 of Regulation (EU) 2020/2221. 

 
 
 
36 

o 

o 

The Commission’s geographical units were in close contact with the member 
states to discuss how EU funding could be used to address emerging needs. 

In June 2022 the Commission issued a communication with guidance on refugees’ 
access to the labour market, vocational education and training and adult 
learning19. The guidance was based on lessons learned and good practice 
examples gathered during the early months of the war, as well as from the 
2015-2016 migration crisis. 

The Commission’s delivery of support was similar to the approach it took in the 
context of the coronavirus response investment initiatives (CRII/CRII+ regulations), and 
drew on that experience20. 

67 The managing authorities in Bulgaria, Germany and Poland that we audited found 
the guidance material provided by the Commission useful (see paragraph above). The 
Italian managing authorities did not use the guidance material but held bilateral 
discussions on CARE with the Commission to obtain the information they needed. All 
the managing authorities we audited emphasised their good co-operation with the 
Commission’s geographical units, which reacted swiftly to their requests and enquiries. 

68 The managing authorities that replied to our survey were likewise positive about 
the Commission support. Approximately 90 % of those expressing an opinion found the 
CARE Q&A database, the co-operation with geographical units and the webinars to 
have been useful. 

Incomplete information on the use of CARE limits the assessment of its 
effectiveness 

69 The CARE regulations do not set specific monitoring and reporting requirements 
on the use of CARE, as the aim was to adapt the existing cohesion policy rules rather 
than add to the administrative burden on member states. 

19  C(2022) 4050 final. 

20  We reported on this in our special report 02/23. 

 
 
 
37 

70 The Commission’s monitoring indicates that 46 out of 388 programmes in the 
2014-2020 programming period were amended to address the migratory challenges. 
However, the amended programmes are not the only programmes that allocated 
funding to support refugees. Other programmes might have been able to support 
refugees without any amendments, such as the ESF programme in Lazio we audited. 
However, this was not fully captured by the Commission’s monitoring. 

71 Similarly, the Commission’s monitoring is not able to track the total amount of 
funding allocated to support refugees. This was also the case where a programme had 
not been amended, or where the programme amendment included refugees as part of 
an existing target group for operations. In the latter case, it is also impossible to 
ascertain how much funding was directed specifically to refugees. 

72 As a result, for its overview of the use of CARE – which is a flexibility mechanism, 
and not a new instrument established to finance assistance for refugees (see 
paragraphs 10, 12 and 69) – the Commission does not have specific data on the 
number of programmes supporting refugees or the funding allocated. It only has 
sufficient data in cases where funding was allocated to the initiative through a 
dedicated CARE priority. Furthermore, the Commission has only limited data on the 
use of specific CARE measures (see Annex IV). 

73 Cohesion programmes use common and programme-specific indicators to 
monitor implementation. Common indicators are defined in the fund-specific 
regulation and enable the Commission to aggregate output and results at EU level. 
Programme-specific indicators are defined by managing authorities at programme 
level and do not allow the aggregation of data at EU level. 

74 Common indicators do not separate out support given to refugees. Therefore, the 
information available does not allow the Commission to measure the EU funding 
involved. 

75 One of the simplification measures introduced by CARE involved reducing the ESF 
reporting obligations concerning participants’ data (see Table 1). Programmes that 
established a dedicated priority axis supporting operations addressing the migratory 
challenges used two common output indicators to collect informed estimates on the 
number of people granted temporary protection who had received support: the total 
number of people supported and the number of people under 18 years of age. The 
Commission told us that 24 programmes applied this simplification and must include 
the values achieved in their annual implementation reports. 

 
 
38 

76 Where programmes supported refugees through an existing priority axis, the 
Commission recommended a programme-specific indicator, “total number of 
participants granted temporary protection after fleeing the war” on top of the 
obligatory common indicator set. Commission data shows that seven programmes (five 
Polish, one Bulgarian and one Portuguese) have included this indicator. As use of the 
indicator was very low, the data cannot be aggregated at EU level. 

77 CARE-specific indicators are output indicators, i.e., they provide information on 
the number of supported refugees. They are not result indicators, which would help to 
monitor the effectiveness of assistance. Some of the projects we audited 
(see paragraph 61) did include these result indicators. However, as they were not 
obligatory at EU level, the results achieved by cohesion policy funding, including 
REACT-EU resources, cannot be measured. 

78 The regulations do not require a specific evaluation of CARE. Nevertheless, as 
part of its 2014-2020 ex post evaluation on the cohesion policy funds, the Commission 
has included CARE in its studies on the effectiveness of the anti-crisis instruments used 
in that period. The studies will examine the diverse types of crisis response 
instruments, and assess their rationale, effectiveness, and relevance. However, the 
lack of a comprehensive overview of the support addressing the migratory challenges, 
as well as the limited data available on the use of CARE measures, will limit such an 
assessment. 

The Commission had accepted to analyse the appropriateness of 
cohesion policy as a budgetary crisis-related measure 

79 Cohesion policy has often been used to provide short-term responses to crises, 
such as the 2015 refugee crisis or COVID-19. As reported in our special report on 
adapting cohesion policy rules to respond to COVID-1921, the 2021-2027 cohesion 
policy rules allow for additional flexibility in times of crisis. This could enable the 
Commission to respond to exceptional situations by adopting implementing acts to 
deploy certain temporary measures. These rules also provide for more flexibility to 
transfer funds between the ERDF, ESF+ and CF, and more scope for implementing 
operations over different programming periods to address potential crisis-related 
delays. 

21  Special Report 02/2023. 

 
 
 
39 

80 However, there is a risk that the repeated use of cohesion policy to address crises 
may impact its primary strategic goal, which is to strengthen economic and social 
cohesion between European regions. This risk was also stressed by ten member states 
in a joint statement addressed to a group of EU Commissioners22, as well as by several 
managing authorities that replied to our survey (one from each of the following 
member states: Germany, France, the Netherlands and Austria). This risk was 
addressed in the above-mentioned special report, in response to which the 
Commission accepted our recommendation to analyse the impact of the policy’s use as 
a short-term budgetary crisis response tool on its long-term objectives, with a view to 
informing future policy proposals. 

22  Joint Statement of Bulgaria, Croatia, Czech Republic, Estonia, Hungary, Latvia, Lithuania, 
Poland, Romania and Slovakia on the needs and challenges regarding the unprecedented 
humanitarian migration to the European Union and response of Cohesion Policy to the 
consequences of the Russian aggression in Ukraine. 

 
 
 
 
 
40 

Conclusions and recommendations 

81 Our overall conclusion is that CARE has helped member states use the available 
cohesion policy funding to address the migratory challenges and refugee needs arising 
from the war of aggression against Ukraine. These amounts were relatively small in 
comparison to the national funds used for refugees, but also to the EU cohesion policy 
funds in general. The measures offered by CARE have allowed funding to be 
reallocated flexibly and quickly within the programmes we audited, but there is a lack 
of CARE-specific data and monitoring on the money spent. This is likely to hinder the 
upcoming evaluation of the use of cohesion policy funds to address crises. This could 
also apply to any future assessment of CARE’s effectiveness. 

82 The programmes we audited used a range of CARE measures. The managing 
authorities considered that CARE was useful and provided them with the flexibility, 
liquidity and simplification they needed to react quickly to the crisis. It also somewhat 
helped alleviate the burden on national budgets. The use of CARE measures and their 
extent varied significantly between managing authorities, as the crisis did not affect all 
member states equally. In addition, relatively little cohesion policy funding, including 
REACT-EU resources, was available at the end of the programming period in 
comparison to the total value of all the assistance provided (see paragraphs 21-32). 

83 We found that the managing authorities faced certain challenges when 
reallocating funding, such as insufficient information concerning the flows of refugees, 
or the unstable political and economic situation caused by the crisis. In the 2021-2027 
programming period the support for refugees from Ukraine is part of the general 
support for third-country nationals. Support was planned after an analysis of refugee 
needs and was often a part of the member states’ overall response to the crisis (see 
paragraphs 36-45). 

84 The projects we audited were all selected and implemented swiftly but uptake 
was modest in the case of some projects selected through competitive procedures. 
Projects were designed with a view to the needs and availability of participants, but it 
is impossible to assess the overall effectiveness of the assistance, as only three of the 
projects we audited measured it. However, according to some of the participants that 
we interviewed, the projects were useful and had improved their situation (see 
paragraphs 47-63). 

 
 
41 

85 Most of the managing authorities that replied to our survey found the 
Commission’s support on using the EU cohesion policy funds and CARE to address the 
migratory challenges to be helpful. In their opinion the Commission’s assistance was 
timely and suitable (see paragraphs 66-68). 

86 We found that the general arrangements for monitoring cohesion policy funds do 
not cover all aspects of support addressing migratory challenges and the use of CARE. 
This is because: 

o 

o 

o 

the Commission does not have a comprehensive overview of the programmes and 
amounts allocated under CARE; 

the Commission has only limited data concerning programmes’ use of specific 
CARE measures; and 

not all CARE-specific indicators introduced by the Commission are mandatory, 
leading to incomplete data reported by member states. This means there is a risk 
that the Commission will not be able to aggregate the data at EU level in a 
meaningful way. 

As a result, there will be some constraints on the planned assessment of CARE’s 
effectiveness which is to take place as part of the Commission’s 2014-2020 ex post 
evaluation of the cohesion policy funds (see paragraphs 69-78). 

87 The 2021-2027 cohesion policy rules allow for additional flexibility in times of 
crisis and should enable the Commission to respond to exceptional situations more 
swiftly. However, there is also a risk that the repeated use of cohesion policy to 
address crises may impact its primary strategic goal, which is to strengthen economic 
and social cohesion between European regions. We have previously recommended to 
the Commission, which accepted the recommendation, to analyse the appropriateness 
of cohesion policy as a budgetary crisis response tool (see paragraph 79-80). 

 
 
42 

Recommendation – Establish an appropriate system for 
monitoring the effectiveness of crisis-related measures or 
amendments 

We recommend that, if the Commission were to prepare proposals for new 
crisis-related measures or amendments, it should ensure an appropriate monitoring 
system is in place with data necessary for assessing effectiveness. This would also help 
improve future schemes. 

Target implementation date: when preparing the next crisis-related measures or 
amendments 

This report was adopted by Chamber II, headed by Ms Turtelboom, Member of the 
Court of Auditors, in Luxembourg on 8 January 2025. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
 
 
 
 
 
43 

Annexes 

Annex I – Examples of eligible activities co-financed by EU funds 

AMIF

FEAD

ESF*

FIRST RECEPTION AND IMMEDIATE RELIEF 

Support at the border or close to the border: food, non-food items and basic material assistance

Transport services from border to first reception

Immediate health care and psychological counselling

Consumables (personal care items, pharmaceutical products, beds, etc.)

Immediate information on rights and procedures (administrative support)

Translation and interpretation services

Specific material assistance for children equipment, and for persons with disabilities

AMIF

FEAD

ESF/ ERDF

WELCOME AND INTEGRATION 

Accommodation

Transport services to next reception (local / regional and/or accommodation, or to other host countries)

Food and basic material assistance

Language courses (and day care support during language courses)

Civic orientation and interaction with the host society

Information packages /information services

Training and hiring of staff to work with refugees

Capacity building for local and other authorities; Platforms to organise civil society contributions;
Support to developing networks and partnerships for integrated services;
Support to NGOs and citizens’ initiatives; Staff costs for organisation of integration activities.

AMIF

FEAD

ESF/ ERDF

MAINSTREAM SUPPORT FOR LONG-TERM INTEGRATION INTO HOST SOCIETY 

Access to non-segregated basic services (social inclusion and health) especially for vulnerable groups

Access to day care services notably for children and persons with disabilities;
Accompanying support such as translation and interpreters;
Infrastructure developments (building/refurbishing/extending) and related equipment in social services,
health care, child-care, public transport.

Access to the non-segregated accommodation

Refurbishing/building/purchasing social housing adapted to the needs of persons with disabilities, 
older people etc.

Access to the non-segregated labour market

Labour market activation measures (incl. vocational education, training, mentoring, counselling);
Work-based language training;
Assistance with and support to business start-ups;
Access to microfinance assistance;
Infrastructure developments and related equipment through improved access to labour market
institutions, public employment services, vocational training facilities, business incubators,
public transport.

Access to non-segregated education

Remedial classes, inclusive education, creation of additional school places (infrastructure and
related equipment to facilitate access);
Infrastructure developments and related equipment concerning all levels of education,
including ICT and public transport to facilitate access;
Training and hiring of additional teachers and staff;
Assessment of children’s educational needs;
Programme for developing competences.

Anti-discrimination measures like training and community building

* The ESF may provide support for first reception and immediate relief measures as long as they are a 
means for integrating the displaced people into the labour market. 
Source: ECA, based on the Commission guidance. 

 
 
 
 
 
44 

Annex II – Information on the audited projects 
The following figure shows the member states and projects selected for the audit. The 
table provides detailed information on the audited projects. 

Member states and projects selected for the audit 

Grants

ESF projects
ERDF projects

4

3

5

7

1

3

5

Source: ECA. 

POLAND

GERMANY

ITALY

BULGARIA

1

Projects co-funded by the ESF/ERDF. The amounts are indicated in the table below. 

 
 
 
 
45 

Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

Bulgaria 

Project 1 

14.7.2022 – 
14.12.2023 

(the project 
retroactively 
finances activities 
that took place 
between 
24.2.2022-
30.4.2022) 

Non-
competitive 

First 
reception 

30 246 881 

Bulgaria 

Project 1 – 
Grant 1 

3.3.2022 – 
30.4.2022 

Non-
competitive 

First 
reception 

282 990 

Accommodation. 

Providing first reception and 
immediate support to refugees 
arriving in Bulgaria, including an 
overnight stay, breakfast and hot 
meals. 

Accommodation. 

The grant beneficiary is a complex 
including a hotel and apartments. 
The beneficiary contacted the local 
hot spots to let them know how 
many Ukrainians could be 
accommodated. 

Planned: support 42 000 people, of 
which 16 800 were aged under 18. 

Achieved: 58 302 people supported, 
of which 24 647 were under 18. 

13 837 nights and 43 accommodated 
people. 

Bulgaria 

Project 1 – 
Grant 2 

18.3.2022 – 
30.4.2022 

Non-
competitive 

First 
reception 

1 270 397 

Accommodation. 

The grant beneficiary is a hotel. 

62 117 nights and 
1 798 accommodated people. 

Bulgaria 

Project 1 – 
Grant 3 

14.4.2022 – 
30.4.2022 

Non-
competitive 

First 
reception 

16 198 

Accommodation. 

The grant beneficiary is a private 
company (joint stock company) 
100 % owned by the Ministry of 
Education. 

Bulgaria 

Project 2 

1.6.2022-
30.9.2023 

Non-
competitive 

Mainstream 
support for 
long-term 

5 891 938 

Labour market activation measures. 

792 nights and 50 accommodated 
people. 

Planned: support to 9 054 people, 
4 875 to be in employment upon 
leaving the project. Decreased to 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

46 

integration 
into host 
country 

Mainstream 
support for 
long-term 
integration 
into host 
country 

Mainstream 
support for 
long-term 
integration 
into host 
country 

Mainstream 
support for 
long-term 
integration 
into host 
country 

Mainstream 
support for 
long-term 

Rapid integration into the labour 
market by reimbursing 
remuneration of employees, 
remuneration of mentors, 
supplement for accommodation, 
employers' contributions. 

2 500 people supported, 1 350 to be 
in employment upon leaving the 
project. 

Achieved: support granted to 
3 846 people. Out of them 
1 826 people were still in employment 
upon leaving the project. 

51 438 

Seasonal jobs in a hotel. 

49 available positions, 37 employed. 

85 742 

Seasonal jobs in a hotel. 

66 available positions, 60 employed. 

8 576  Employment in a hair salon. 

7 available positions, 7 employed. 

2 236 

Job in a hotel. 

5 available positions, 1 person 
employed. 

Bulgaria 

Project 2 – 
Grant 1 

25.7.2022-
25.1.2023 

Competitive 

Bulgaria 

Project 2 – 
Grant 2 

1.7.2022-
31.12.2022 

Competitive 

Bulgaria 

Project 2 – 
Grant 3 

20.7.2022-
20.1.2023 

Competitive 

Bulgaria 

Project 2 – 
Grant 4 

18.7.2022-
18.1.2023 

Competitive 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

47 

Bulgaria 

Project 2 – 
Grant 5 

25.8.2022-
25.5.2023 

Competitive 

integration 
into host 
country 

Mainstream 
support for 
long-term 
integration 
into host 
country 

12 180 

Employment in an NGO assisting 
refugees. 

13 available positions, 16 employed. 

Germany 

Project 1 

1.10.2022-
31.5.2023 

Competitive 

Second 
stage – 
Welcome 
and 
integration 

110 455 

Civic orientation and interaction 
with the host society. 

Establish a district office, organise 
excursions, provide assistance when 
visiting authorities, organise 
workshops, (artistic, cultural, 
IT-skills), intercultural café. 

No quantifiable targets included in the 
grant agreement. 

It is estimated that 45 490 people 
were reached overall, either directly 
or indirectly (e.g. through social media 
posts, newspaper articles, events, 
etc). 

More specifically: one participant was 
employed for the project and 
continued as a volunteer after the end 
of the project; 30 participants 
benefited from consultations with 
craftspeople; 100 female Ukrainian 
participants were reached directly, 
and 500 male Ukrainians indirectly 
through the different the 
sub-projects; the film “On packed 
suitcases” was shown to 300 guests 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

48 

Germany 

Project 2 

15.10.2022-
31.3.2023 

Competitive 

Second 
stage – 
Welcome 
and 
integration 

44 436 

160 773 

Germany 

Project 3 

1.3.2022-
31.3.2023 

Competitive 

Germany 

Project 4 

1.2.2023-
31.3.2023 

Competitive 

Second 
stage – 
Welcome 
and 
integration 

Mainstream 
support for 
long-term 
integration 
into host 
country 

before being uploaded on social 
media. 

No quantifiable targets included in the 
grant agreement. 

Info/welcome café on a weekly basis 
at two locations, yoga workshop, 
photo project with an exhibition, and 
further activities; psychological 
support and counselling. 

Planned: 88 participants. 

Achieved: 113 participants; language 
skills improved. 

Civic orientation and interaction 
with the host society. 

Support for the socio-economic 
integration of Ukrainians through 
social activities and individual 
counselling, such as an ‘info café‘ for 
regular exchanges on day-to-day 
issues, civic orientation, leisure 
activities, photo project. 

Eight language courses at A1/A2 
level at different locations (five 300 
hour courses, three 150 hour 
courses) with 7-15 participants per 
course. 

Further activities included civic 
orientation, socio-pedagogical 
support, and other support where 
needed. 

37 997 

Two language courses with 
job-specific language skills (health 
professions and childcare) with the 
possibility for job-shadowing. 
Further activities, childcare, and 
socio pedagogical support were 
offered. 

Planned: 30 participants, 
job-shadowing. 

Achieved: 33 participants, mostly 
Ukrainians. 
10 job-shadowing opportunities; 
3 participants secured further training 
or a job, others continued taking 
language courses. 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

49 

Germany 

Project 5 

1.3.2022-
28.2.2023 

Non-
competitive 

First 
reception 

49 000 000 

Italy 

Project 1 

1.8.2022-
31.12.2023 

Competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

268 376 

Accommodation in reception 
facilities in the Land of people 
fleeing Ukraine; provision of 
consumables, healthcare and care, 
legal information and registration, 
necessary translation and 
interpretation services, activities to 
integrate refugees into the labour 
market, administrative support and 
language courses. 

The project targeted those granted 
temporary protection status and 
sought to broaden opportunities for 
the social and labour market 
inclusion of women and families 
with children from Ukraine and to 
promote their psychological and 
physical well-being. 

The project included activities 
related to the development of a 
network for the social and labour 
market inclusion of the Ukrainian 
population to better address their 
needs. 

Planned: 150 000 people supported, 
of which 45 000 were under 18. 

Achieved (according to beneficiary): 
217 075, of which 72 455 were 
under 18. 
After corrections applied by MA: 
154 124 people (no information on 
those under 18). 

Planned: 150 people supported. 

Achieved: 89 people supported. 

Comprehensive assessment of 
139 people to determine their needs 
and potential inclusion in the project. 

25 people attended socio-linguistic 
support events. 

45 people participated in 
alphabetisation courses (40 % of 
participants attended 50 % of the 
courses). 

Personal development plan 
established for 44 people. 

Guidance and support for enrolment 
in education or employment. 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

50 

Psychological support through the 
network in the area. 

Socio-linguistic mediation and support 
related to health and children’s 
education. 

Guidance on housing. 

Networking activities, among others, 
included: 

mapping employment opportunities 
according to place of residence with 
an employment agency, and 

working with associations to find work 
opportunities in different sectors. 

Planned: 40 people supported. 

Achieved:78 people supported. 

180 hours of alphabetisation courses 
for a total of 42 people. 

360 hours of Italian language courses 
for a total of 36 people, of which 6 
received an A2 level certification. 

26 personal development plans 
established; 23 CVs prepared. 

15 families benefitted from 
psychological support. 

Italy 

Project 2 

5.7.2022-
31.12.2023 

Competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

220 033 

The project targeted children with 
cancer and their accompanying 
family members who had temporary 
protection. It aimed to reduce the 
risks of social exclusion and cultural 
deprivation through inclusion and 
active participation activities and 
from a gender perspective. 

The project also aimed to explore 
new forms of collaboration between 
the public and private sectors and 
new ways of delivering services to 
people supported particularly 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

51 

regarding health, psychological and 
gender aspects. 

Italy 

Project 3 

5.8.2022–
31.12.2023 

Competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

285 310 

The project targeted those granted 
temporary protection, women in 
particular. The aim of the project 
was to facilitate social and labour 
market inclusion by promoting 
individual empowerment and 
guaranteeing psychological support. 

The project also aimed at 
networking and sharing experiences 
with stakeholders to define 
reception practices for this specific 
population. 

29 people benefited from 
empowerment courses for women 
and cultural mediation. 

66 hours of guidance on housing. 

210 hours of educational activities 
through music for children. 

Networking activities, among others, 
included close cooperation with 
government services to help 
recipients access the social service 
system. 

Planned: 150 people supported. 

Achieved: 92 people supported. 

40 people attended alphabetisation 
courses. 

26 people received psychological 
support. 

40 people received career guidance or 
training. 

Three courses to facilitate integration 
into the labour market. The courses, 
which added up to a total of 
200 hours, were on catering, tailoring 
and baking. 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

52 

Italy 

Project 4 

28.6.2023–
13.7.2023 

Non-
competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

6 130 

Networking activities, amongst others, 
included the publication of a vade 
mecum on career guidance and 
training. 

Planned: three 30 hour modules 
(90 hours in total) and a total of 
50 participants. 

Achieved: one 30 hour module 
implemented and a total of 
17 students, of which eight were 
Ukrainian. 

All participants attended at least 75 % 
of each module in which they were 
enrolled. 

Remedial classes, language courses, 
extracurricular activities. 

The project consisted of three 
modules. Two modules were 
dedicated to sports, motor skills and 
learning through play. One module 
was dedicated to artistic expression. 
The project aimed to improve the 
level of socialisation and the 
treatment of others and reduce 
stress and anxiety. 

The project targeted students 
enrolled in the school and was not 
only for refugees. 

Italy 

Project 5 

12.9.2023–
21.9.2023 

Non-
competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

6 491 

The project consisted of one module 
aiming to develop linguistic and 
communication skills in Italian and 
to acquire learning strategies. 

The project targeted students 
enrolled in the school and was not 
only for refugees. 

Planned: one 30 hour module and a 
total of 18 participants. 

Achieved: one 30 hour module and a 
total of 19 participants, of which 
seven were Ukrainian. 

All participants attended at least 75 % 
of the module. 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

53 

Italy 

Project 6 

12.5.2023–
31.8.2023 

Non-
competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

The project consisted of 15 modules 
aiming to cover the various aspects 
of integration. It included: 

— three language modules on 

Italian 

— two modules on socialisation and 

learning through sports 

— two modules to develop skills 
related to specific professional 
training such as cooking, crafts 
and trades; 

84 380 

— eight modules on developing key 
skills for lifelong learning such as 
active citizenship, cultural 
awareness and artistic 
expression, and scientific and 
technological competences. 

The project targeted students (over 
16 years of age) enrolled in the 
school and was not only for 
refugees. 

Planned: 15 modules of 30 hours each 
(450 hours in total) and a total of 
252 participants. 

Achieved: 15 modules (450 hours in 
total) and a total of 339 participants, 
of which 57 were Ukrainian. 

Overall, around 77 % of participants 
attended at least 75 % of each module 
in which they were enrolled. 

Italy 

Project 7 

14.6.2023–
21.9.2023 

Non-
competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

The project consisted of 12 modules 
aiming to cover the various aspects 
of integration. It included: 

54 090 

— three language modules on 

Italian; 

Planned: 12 modules of 30 hours each 
(360 hours in total) and a total of 
180 participants. 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

54 

— two modules on health and 

well-being; 

— three modules on career 

guidance and access to services 

— four modules on active 

citizenship and integration. 

The project targeted students (over 
16 years of age) enrolled in the 
school and was not only for 
refugees. 

Labour market activation measures, 
and vocational education and 
training. 

The project aimed to support 
1 500 young people aged 15-20 in 
acquiring the qualifications or 
competences relevant for the labour 
market, regardless of nationality. 

2 735 635 

Achieved: ten modules (300 hours in 
total) and a total of 216 participants, 
of which 73 were Ukrainian. 

Overall, around 68 % of participants 
attended at least 75 % of each module 
in which they were enrolled. 

Planned: 

1500 people aged 15-20 (671 women 
and 829 men). 

Achieved: 

1455 people (659 women and 
796 men). 

2 420 934 

(project 
amount 
increased 
under 
CARE) 

Improve the accessibility of medical 
facilities to adapt them to the needs 
of patients with special needs, 
including people with disabilities 
and older people, regardless of 
nationality. 

5 additional hospitals 

(planned and achieved). 

Not 
specifically 
targeting 
people 
fleeing 
Ukraine 

Not 
specifically 
targeting 
people 
fleeing 
Ukraine 

Poland 

Project 1 

1.10.2022-
31.10.2023 

Non-
competitive 

Poland 

Project 2 

1.1.2019-
31.12.2023 

Non-
competitive 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

55 

Poland 

Project 3 

1.6.2022-
31.12.2022 

Non-
competitive 

Poland 

Project 4 

1.9.2022-
31.10.2023 

Non-
competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

215 330 

Polish language course at B1 and B2 
levels for Ukrainian teachers, 
combined with training covering the 
organisation and administration of 
the Polish education system. 
Accommodation, catering and 
childcare for the children of 
participants during the in-person 
part of the course were also offered. 

Mainstream 
support for 
long-term 
integration 
into host 
country 

6 082 192 

Project with 81 grants, of which 63 
were for NGOs and 18 for local 
governments to: 

— organise activities aimed at the 
social integration of migrants 
into the local community, 
including: living and care 
support, day care for children, for 
older people and people with 
disabilities, vocational and 
language courses, translations, 

Planned: hybrid course (390 hours in 
total) for 140 participants. 

Achieved: 

390-hour course, of which 374 hours 
were online 

133 project participants (124 women 
and nine men), of which 21 were 
children 

— 101 people completed the 

intensive Polish course for teachers 
20 participants also took part in an 
advanced e-learning course 

— 88 people had consultations 
through the support network 

Planned: 

— support 1 850 Ukrainian citizens 
(1 610 women and 240 men), of 
which 160 were children (80 girls 
and 80 boys); 

— training for 50 staff and volunteers 
assisting Ukrainians who arrived in 
Pomerania after 24 February 2022 
due to the war. 

Achieved: 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

56 

career guidance and legal and 
psychological assistance; 

— train the staff and volunteers of 
the grant beneficiaries working 
with refugees. 

Poland 

Project 4 – 
Grant 1 

1.9.2022-
28.2.2023 

Competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

59 132 

For Ukrainians: psychological 
assistance, legal counselling, 
workshops (educational, 
entrepreneurship), excursions. 

For volunteers: workshops on 
working in a multi-cultural 
environment. 

— 3 417 participants (2 508 women, 
909 men), of which 1 447 children 
(790 girls, 657 boys); 

— training for 202 staff members and 
volunteers (165 women, 37 men). 

81 % of people with disabilities 
(136 women and 90 men) achieved 
the social effectiveness indicator. All 
grant beneficiaries achieved the 
planned social effectiveness indicator 
for people with disabilities and for 
people at risk of social exclusion, i.e. 
at least 34 %. 

Planned: 30 Ukrainians and 
20 volunteers. 

Achieved: 

— 30 Ukrainian participants with 

temporary protection (28 women 
and two men); 

— 20 trained volunteers (12 women 

and eight men). 

Social effectiveness indicator: 100 %. 

According to the survey filled in by 
participants after taking part in the 
grant activities, the project improved 
their situation. Two participants 

Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

57 

Poland 

Project 4 – 
Grant 2 

1.12.2022-
31.5.2023 

Competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

66 025 

Psychological assistance, legal 
counselling, workshops 
(educational, Kashubian culture, 
yoga), vocational courses, Polish 
language courses, career guidance, 
packages with food and hygienic 
products for each participant at the 
end of the project. 

Poland 

Project 4 – 
Grant 3 

1.9.2022-
31.8.2023 

Competitive 

Mainstream 
support for 
long-term 
integration 
into host 
country 

219 751 

For Ukrainians: excursions, 
integration activities, camps for 
children, school tuition for children, 
workshops, volunteering, social 
activities, Polish language course. 

For staff and volunteers: training. 

experienced a significant 
improvement in their state of health. 
Six of them took up a job during the 
project or started their own SME 
thanks to their participation in the 
project. 

Planned: 

30 participants. 

Achieved: 

30 Ukrainian participants with 
temporary protection: 24 women 
(two with disabilities), six men. 

Social effectiveness indicator: 100 % 
for all participants. 

Planned: 

154 participants 

ten staff and volunteers. 

Achieved: 

154 Ukrainian participants with 
temporary protection: 114 women 
and 40 men, of which 71 were 
children (48 girls and 23 boys); 

ten trained staff and volunteers (nine 
women and one man). 

 
 
Member 
state 

Project/ grant 

Implementation 
period 

Selection 
procedure 

Type of 
project 

Amount in 
euro 

Description 

Output/Results 

Social effectiveness indicator: 88 % for 
people with disabilities, 92 % for other 
participants. 

58 

 
 
59 

Annex III – Detailed information on our survey 
Our survey included six sections: 

(a)  Background information: this section concerned the information on managing 

authorities, the member states they originate from, which programmes and the 
cohesion policy funds managed. 

(b)  Using CARE measures for the 2014-2020 programming period: we asked about 
both the national and European cohesion policy funding allocated to refugees, 
CARE measures used, reasons for not using them, usefulness of each of CARE 
measures, kinds of actions supporting refugees funded and challenges faced 
when implementing CARE. This section included multiple choice questions, in 
which the respondents could choose more than one reply. 

(c)  Using CARE measures for the 2021-2027 programming period: this section 

included questions on amounts planned for supporting the integration of third-
country nationals and in particular refugees, CARE measures used, reasons for not 
using them, other flexibilities that could be useful in order to support the 
integration of third countries nationals and in particular refugees. This section 
included multiple choice questions, in which the respondents could choose more 
than one reply. 

(d)  Lessons learnt: we asked about using the experience from previous migration 

crises or from the integration of third-country nationals during the Ukrainian crisis 
for both programming periods, as well as about sharing respondents’ previous 
experience with other member states or managing authorities. 

(e)  Commission’s role: we asked how useful the support on CARE’s implementation 

provided by the Commission was. 

(f)  Other remarks: in this section the respondents could share any additional 

comments that they might have had concerning the use of cohesion policy funds 
to support refugees and CARE measures. 

 
 
 
 
60 

Annex IV – Use and financial impact of CARE measures 

100 % co-financing rate on 
payment applications 
submitted between 
1 July 2021 and 30 June 2022 

According to Commission data, around 40 % of the 
2014-2020 cohesion policy programmes opted for the 
100 % co-financing rate and claimed an additional 
€6.7 billion of EU funding on top of their regular 
co-financing. Five out of eight programmes we audited 
used this measure. 37 % of our survey respondents 
indicated that they used the measure. 

Increased rate of initial 
pre-financing on the 2021 
REACT-EU allocation 

In April 2022 member states received an increased rate 
of initial pre-financing on the 2021 REACT EU allocation 
of around €3.5 billion. 

i

y
t
i
d
u
q
i
L

Increased rate of 
pre-financing on the 
2021-2027 allocation paid 
in 2022 and 2023 

2021-2027 ERDF, CF and ESF+ programmes received an 
additional pre-financing of 0.5 % in 2022 and in 2023. 
This amounted to around €3.5 billion. 

Up to 100 % co-financing rate 
on a dedicated priority axis 
established to promote the 
socio-economic integration of 
third country nationals, 
including those established as 
a result of CARE 
cross-financing 

y
t
i
l
i

b
i
g
i
l
E

Retroactive eligibility of 
expenditure and projects to 
24 February 2022 

CARE cross-financing between 
the ERDF, ESF and CF 

y
t
i
l
i

b
i
x
e
l
F

Ten out of 24 programmes that established a dedicated 
priority axis benefited from up to 100 % co-financing 
rate. Another nine programmes benefitted from a 100 % 
co-financing rate in relation to REACT-EU funding. 

Four out of the eight programmes we audited 
established a dedicated priority axis. Three benefited 
from a 100 % co-financing rate as they used REACT-EU 
funding whereas one did not opt for a higher 
co-financing rate. 11 % of our survey respondents 
indicated that they used the measure. 

The Commission does not have any data on this as 
managing authorities are not obliged to report it to the 
Commission. Four out of the eight programmes we 
audited and six out of the 18 projects we audited used 
this measure. 15 % and 13 % of our survey respondents 
indicated that they used the retrospective eligibility of 
expenditure and projects, respectively. 

Based on Commission data, 11 programmes used ERDF 
funding to finance ESF-type operations or vice versa. 
Ten programmes allocated around €403.4 million from 
the ERDF to finance ESF-type operations, whereas one 
programme allocated around €2.3 million from the ESF 
to finance ERDF type operations. The Commission 
indicated that the CF was not used for cross-financing. 

One of eight programmes we audited used the 
cross-financing flexibility. 6 % of our survey respondents 
indicated that they used the flexibility. 

Simplified transfer of financial 
allocations between thematic 
objectives 

The Commission is notified by managing authorities but 
does not aggregate data on this. 8 % of our survey 
respondents indicated that they used the flexibility. 

Simplified funding operations 
located outside programming 
area 

The Commission does not have any data on this as 
managing authorities are not obliged to report it to the 
Commission. 2 % of our survey respondents indicated 
that they used the flexibility. 

 
 
 
 
 
61 

Increased flexibility across 
priority axes at closure from 
10 % to 15 % 

The extent of the application of this flexibility will be 
known at closure. 25 % of survey respondents indicated 
that they intend to use this flexibility. 

Reduced threshold for phased 
projects in the 2021-2027 
period 

The Commission indicated that member states are 
required to list the phased projects in their final 
implementation report, which is submitted along with 
the other closure documents. Therefore, the 
Commission could, at closure, be in a position to identify 
the number and financial value of phased projects. 

Unit cost linked to basic needs 
and support of people granted 
temporary protection 

The Commission’s data is not comprehensive. One out of 
the eight programmes we audited used the unit cost. 
7 % of our survey respondents indicated that they used 
the measure. 

n
o
i
t
a
c
i
f
i
l

p
m
i
S

Simplified programme 
amendment procedure for 
transfers between thematic 
objectives of the same priority 
axis and 100 % co-financing 
rate 

Reduced ESF monitoring 
obligations 

Source: ECA. 

All programmes that opted for 100 % co-financing rate 
and/or transferred financial allocations between 
different thematic objectives did not need the entire 
programme amendment procedure. It sufficed to notify 
the Commission of the change following the approval by 
the monitoring committee. 18 % of our survey 
respondents indicated that they used the measure. 

All programmes that used cross-financing and/or that 
established a dedicated priority axis supported by the 
ESF to address migratory challenges benefit from lighter 
reporting obligations on ESF indicators. 

 
 
 
 
 
62 

Abbreviations 

AMIF: Asylum, Migration and Integration Fund 

CARE: Cohesion’s Action for Refugees in Europe 

CF: Cohesion Fund 

CPR: Common Provisions Regulation 

ERDF: European Regional Development Fund 

ESF: European Social Fund 

ESF+: European Social Fund Plus 

Eurostat: Statistical Office of the European Union 

FAST-CARE: Flexible Assistance to Territories 

FEAD: Fund for European Aid for the Most Deprived 

NGO: Non-governmental organisation 

REACT-EU: Recovery Assistance for Cohesion and the Territories of Europe 

 
 
 
 
63 

Glossary 

Asylum, Migration and Integration Fund: EU fund to support the development of a 
common asylum and migration policy among the member states, including measures 
to improve migration management. 

Cohesion Fund: EU fund for reducing economic and social disparities in the EU by 
funding investments in member states where the gross national income per inhabitant 
is less than 90 % of the EU average. 

Cohesion policy funds: EU funds supporting economic, social and territorial cohesion 
across the EU in the 2014-2020 period there were three such funds: the European 
Regional Development Fund, the European Social Fund, and the Cohesion Fund. In the 
2021-2027 period there are four: the European Regional Development Fund, the 
European Social Fund Plus, the Cohesion Fund and the Just Transition Fund. 

Cohesion policy: The EU policy which aims to reduce economic and social disparities 
between regions and member states by promoting job creation, business 
competitiveness, economic growth, sustainable development, and cross-border and 
interregional cooperation. 

Cohesion’s Action for Refugees in Europe: Mechanism for reallocating funding quickly 
so that member states and regions can provide emergency support to people fleeing 
the war in Ukraine. 

Common Provisions Regulation: Regulation setting out the rules that apply to a 
number of EU funds under shared management, including those supporting the EU’s 
cohesion policy. 

Cross-financing: Mode of EU financing that involves using resources from the 
European Regional Development Fund to finance operations usually falling within the 
scope of the European Social Fund, or vice versa. 

European Regional Development Fund: EU fund that strengthens economic and social 
cohesion in the EU by financing investments that reduce imbalances between regions. 

European Social Fund: EU fund for creating educational and employment 
opportunities and improving the situation of people at risk poverty. Superseded by the 
European Social Fund Plus. 

Fund for European Aid for the Most Deprived: EU fund supporting member states' 
actions to provide food and other material assistance to the poorest in society. 

 
 
64 

Internal Security Fund – Borders and Visa instrument: Contributes to ensuring a high 
level of security in the Union while facilitating legitimate travel. 

Managing authority: National, regional or local authority designated by a member 
state to manage an EU-funded programme. 

Monitoring committee: Body that oversees the implementation of an operational 
programme, comprising representatives of member state authorities and the 
Commission as an observer. 

Multiannual financial framework: The EU's spending plan setting priorities (based on 
policy objectives) and ceilings, generally for seven years. It provides the structure 
within which annual EU budgets are set. The current multiannual financial framework 
covers the 2021-2027 period and the previous one 2014-2020. 

Operation: Project, contract or action that forms part of an operational programme 
and contributes to its objectives. 

Operational programme: Framework for implementing EU-funded cohesion projects 
in a set period, reflecting the priorities and objectives laid down in partnership 
agreements between the Commission and individual member states. 

Phased project: Project implemented over two programme periods instead of one to 
limit the risk of non-completion. 

Prefinancing payment: Cash advance to fund defined activities in a given period. 

Priority axis: Key component of an operational programme comprising one or more 
investment priorities. In the context of CARE, member states could make use of the 
CARE cross-financing in a priority axis dedicated to operations addressing migratory 
challenges resulting from Russia’s military aggression, and provide up to 100 % 
co-financing to separate priority axes established to support operations promoting the 
socioeconomic integration of third country nationals. 

Programme period: Period within which an EU spending programme is planned and 
implemented. 

REACT-EU: NextGenerationEU programme that provides additional funding for existing 
cohesion policy programmes and FEAD to support crisis recovery while promoting 
green and digital transformation. 

Retrospective support: Award of EU funding for an operation which has already been 
completed before the formal funding application, or for which expenditure has already 
been incurred. 

 
 
Temporary protection: Right to reside, work and access basic services in an EU 
member state, granted for a limited period to displaced people who cannot return to 
their non-EU country of origin. 

65 

 
 
 
 
66 

Replies of the Commission 

https://www.eca.europa.eu/en/publications/sr-2025-05 

Timeline 

https://www.eca.europa.eu/en/publications/sr-2025-05 

 
 
 
 
 
 
 
 
 
 
67 

Audit team 

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

This performance audit was carried out by Audit Chamber II – Investment for cohesion, 
growth and inclusion, headed by ECA Member Annemie Turtelboom. The audit was led 
by ECA Member George-Marius Hyzler, supported by Romuald Kayibanda, Head of 
Private Office, Annette Farrugia, Private Office Attaché and Nikola Soukmandjiev, 
Private Office assistant; Gediminas Macys, Principal Manager; Annekatrin Langer and 
Agnieszka Plebanowicz, Heads of Task; Anna Fiteni, Margit Astelbauer, Plamen Petrov, 
and Rene Reiterer, Auditors. Zoe Amador Martínez and Thomas Everett provided 
linguistic support. Alexandra Damir-Binzaru provided graphical support. 

From left to right: Gediminas Macys, Annette Farrugia, Romuald Kayibanda, 
George-Marius Hyzler, Nikola Soukmandjiev, Agnieszka Plebanowicz, Rene Reiterer, 
Plamen Petrov.

 
 
 
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ISBN 978-92-849-4609-9 

ISSN 1977-5679  doi:10.2865/8637032  QJ-01-25-014-EN-Q 

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HOW TO CITE 

European Court of Auditors, special report 05/2025: “Cohesion’s Action for Refugees in 
Europe - Increased flexibility but insufficient data hinders future assessment of 
effectiveness”, Publications Office of the European Union, 2025. 

 
 
 
 
To address migratory challenges caused by the war in Ukraine, the 
EU gradually adapted cohesion policy rules by adopting 
Cohesion’s Action for Refugees in Europe (CARE). We examined 
whether member states used CARE and the cohesion policy funds 
available to address the needs of the refugees. We concluded that 
CARE helped member states use the available cohesion policy 
funding to address the crisis. However, we found that the 
monitoring of cohesion policy funding does not capture the entire 
support and the use of CARE. We recommend that if the 
Commission were to prepare proposals for new crisis-related 
measures or amendments, it should ensure that there is an 
appropriate monitoring system with data necessary to assess 
their effectiveness. 

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

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