Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs (FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 programming periods : final report.
Date: 2025-03-24
Institutions: Directorate-General for Regional and Urban Policy
Subjects: Cohesion Fund, EAFRD, European Maritime and Fisheries Fund, European Regional Development Fund, European Social Fund, administrative cooperation, administrative formalities, regulation (EU), report, simplification of formalities

Study on the uptake of Simplified 
Cost Options (SCO) and Financing 
Not Linked to Costs (FNLC) for the 
Common Provisions Regulation 
(CPR) Funds in the 2014-2020 and 
2021-2027 programming periods 

Final Report 

t33 and PPMI 
Nicola Brignani  
Luca Santin  
Cintia Denise Granja  
December – 2024 

 
 
EUROPEAN COMMISSION 

Directorate-General for Regional and Urban Policy 
Directorate F – Better Implementation, Closure and Programme Implementation III 
Unit REGIO.F.1 – Better Implementation and Closure 

Contact: Charlie Grant 

E-mail:  REGIO-F1-HOU@ec.europa.eu  

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Study on the uptake of Simplified 
Cost Options (SCO) and Financing 
Not Linked to Costs (FNLC) for the 
Common Provisions Regulation 
(CPR) Funds in the 2014-2020 and 
2021-2027 programming periods 

Final report 

2025 

EN 

Directorate-General for Regional and Urban Policy 

 
Manuscript completed in December 2024 

1st edition 

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ISBN 978-92-68-26007-4   

doi:10.2776/8776773 

KN-01-25-022-EN-N 

 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Table of contents 

Acronyms .......................................................................................................... 5 

Introduction ...................................................................................................... 6 

Executive summary .......................................................................................... 7 

Key findings and lessons learnt ................................................................... 10 

1.  Methodology ........................................................................................... 19 

1.1.  Structuring data collection ................................................................... 20 

1.2.  Data collection ..................................................................................... 21 

1.3.  Checking and cleaning ........................................................................ 23 

1.4.  Analysis ............................................................................................... 25 

1.4.1.  Programme budget covered by SCO/FNLC ............................................ 25 
1.4.2.  Type of SCO/FNLC ................................................................................. 26 
1.4.3.  Type of policy area, cost and beneficiary ................................................ 26 
1.4.4.  Questions to gather stakeholder perceptions .......................................... 27 

2. 

The response rate .................................................................................. 27 

2.1.  Response to the questionnaire addressed to the programme authorities

27 

2.2.  Responses to questionnaire for beneficiaries ...................................... 33 

3.  DG AGRI Fund – EAFRD........................................................................ 34 

3.1.  SCO use in 2014-2020 ........................................................................ 34 

3.1.1.  Types of SCO used in 2014-2020 ........................................................... 35 
3.1.2.  EAFRD measures covered by SCOs in 2014-2020 ................................. 36 
3.1.3.  Beneficiaries covered by SCOs in 2014-2020 ......................................... 37 
3.1.4.  Types of costs covered by SCOs in 2014-2020 ...................................... 37 

3.2.  EAFRD stakeholder perceptions of SCO ............................................. 39 

3.2.1.  Advantages, challenges and reasons for not using SCO ........................ 39 
3.2.2.  Perception of beneficiaries ...................................................................... 40 

4.  DG EMPL Funds – ESF/ESF+ ................................................................ 42 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

4.1.  Key findings ......................................................................................... 42 

4.2.  Use of SCOs in 2014-2020 .................................................................. 42 

4.2.1.  Types of SCO used in 2014-2020 ........................................................... 44 
4.2.2.  Thematic objectives covered by SCOs in 2014-2020 .............................. 46 
4.2.3.  Beneficiaries covered by SCOs in 2014-2020 ......................................... 47 
4.2.4.  Type of costs covered by SCOs in 2014-2020 ........................................ 47 

4.3.  Use of SCOs in 2021-2027 .................................................................. 48 

4.3.1.  Types of SCO used in 2021-2027 ........................................................... 50 
4.3.2.  Specific Objectives covered by SCOs in 2021-2027 ............................... 53 
4.3.3.  Beneficiaries covered by SCOs in 2021-2027 ......................................... 54 
4.3.4.  Type of costs covered by SCO in 2021-2027 .......................................... 54 

4.4.  ESF/ESF+ stakeholder perceptions of SCO ........................................ 56 

4.4.1.  Advantages and challenges .................................................................... 56 
4.4.2.  Involvement of the audit authority in defining SCOs ................................ 59 

4.5.  Use of FNLC in ESF+ .......................................................................... 60 

4.5.1.  Types of FNLC used in 2021-2027 ......................................................... 62 
4.5.2.  Specific Objectives covered by FNLC in 2021-2027 ............................... 65 
4.5.3.  Advantages, challenges and reasons for not using FNLC ....................... 65 
4.5.4.  Involvement of the audit authority in defining the FNLC .......................... 68 

4.6.  Perception of beneficiaries .................................................................. 69 

5.  DG HOME Funds - AMIF/BMVI/ISF ........................................................ 71 

5.1.  Use of SCOs in AMIF .......................................................................... 71 

5.1.1.  Types of SCO used in 2021-2027 ........................................................... 73 
5.1.2.  Specific Objectives covered by SCO in 2021-2027 ................................. 74 
5.1.3.  Beneficiaries covered by SCOs in 2021-2027 ......................................... 74 
5.1.4.  Type of costs covered by SCOs in 2021-2027 ........................................ 75 

5.2.  AMIF stakeholder perceptions of SCO ................................................ 76 

5.2.1.  Advantages, challenges and reasons for not using SCO ........................ 76 
5.2.2.  Involvement of the audit authority in defining SCOs ................................ 77 
5.2.3.  Perception of beneficiaries ...................................................................... 78 

5.3.  Use of SCOs in BMVI .......................................................................... 80 

5.3.1.  Types of SCO used in 2021-2027 ........................................................... 82 
5.3.2.  Specific Objectives covered by SCOs in 2021-2027 ............................... 83 
5.3.3.  Beneficiaries covered by SCOs in 2021-2027 ......................................... 83 
5.3.4.  Types of costs covered by SCOs in 2021-2027 ...................................... 84 

5.4.  BMVI stakeholder perceptions of SCO ................................................ 84 

5.4.1.  Advantages, challenges and reasons for not using SCO ........................ 84 
5.4.2.  Involvement of the audit authority in defining SCOs ................................ 86 
5.4.3.  Perception of beneficiaries ...................................................................... 87 

5.5.  Use of SCOs in ISF ............................................................................. 89 

5.5.1.  Types of SCO used in 2021-2027 ........................................................... 91 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

5.5.2.  Specific Objectives covered by SCOs in 2021-2027 ............................... 92 
5.5.3.  Beneficiaries covered by SCO in 2021-2027 ........................................... 92 
5.5.4.  Types of costs covered by SCOs in 2021-2027 ...................................... 93 

5.6. 

ISF stakeholder perceptions of SCOs .................................................. 93 

5.6.1.  Advantages, challenges and reasons for not using SCOs ....................... 93 
5.6.2.  Involvement of the audit authority in defining SCOs ................................ 95 
5.6.3.  Perception of beneficiaries ...................................................................... 96 

6.  DG MARE Funds – EMFF/EMFAF ......................................................... 98 

6.1.  Key findings ......................................................................................... 98 

6.2.  Use of SCOs in 2014-2020 .................................................................. 98 

6.2.1.  Types of SCO used in 2014-2020 ........................................................... 99 
6.2.2.  Union priorities covered by SCOs in 2014-2020 .................................... 101 
6.2.3.  Beneficiaries covered by SCO in 2014-2020 ......................................... 101 
6.2.4.  Types of costs covered by SCOs in 2014-2020 .................................... 101 

6.3.  Use of SCOs in 2021-2027 ................................................................ 102 

6.3.1.  Types of SCO used in 2021-2027 ......................................................... 104 
6.3.2.  Specific Objectives covered by SCOs in 2021-2027 ............................. 105 
6.3.3.  Beneficiaries covered by SCO in 2021-2027 ......................................... 105 
6.3.4.  Types of costs covered by SCOs in 2021-2027 .................................... 106 

6.4.  EMFF/EMFAF stakeholder perceptions of SCO ................................ 107 

6.4.1.  Advantages and challenges related to SCO .......................................... 107 
6.4.2.  Involvement of the audit authority in defining SCOs .............................. 110 
6.4.3.  Perception of beneficiaries .................................................................... 110 

7.  DG REGIO Funds - ERDF/CF/JTF ....................................................... 113 

7.1.  Use of simplification measures in ERDF ............................................ 113 

7.1.1.  Key findings .......................................................................................... 113 
7.1.2.  Use of SCOs in 2014-2020 ................................................................... 113 
7.1.3.  Use of SCOs in 2021-2027 ................................................................... 118 
7.1.4.  ERDF programme authorities’ perceptions of SCOs ............................. 125 
7.1.5.  Use of FNLC in ERDF ........................................................................... 130 

7.2.  Use of SCO in CF .............................................................................. 138 

7.2.1.  Key findings .......................................................................................... 138 
7.2.2.  Use of SCOs in 2014-2020 ................................................................... 138 
7.2.3.  Use of SCOs in 2021-2027 ................................................................... 142 
7.2.4.  CF programme authorities’ perceptions of SCOs .................................. 148 
7.2.5.  Involvement of the audit authority in defining SCOs .............................. 152 

7.3.  Use of SCO in JTF ............................................................................. 153 

7.3.1.  Types of SCO used in 2021-2027 ......................................................... 155 
7.3.2.  Specific objectives covered by SCOs in 2021-2027 .............................. 158 
7.3.3.  Beneficiaries covered by SCOs in 2021-2027 ....................................... 158 
7.3.4.  Types of costs covered by SCOs in 2021-2027 .................................... 158 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

7.3.5.  JTF programme authorities’ perceptions of SCO .................................. 159 
7.3.6.  Involvement of the audit authority in defining SCOs .............................. 161 

7.4.  REGIO Fund beneficiary perceptions of SCOs .................................. 162 

8.  Annex – questionnaires ...................................................................... 164 

8.1.  2021-2027 questionnaire structures .................................................. 165 

8.2.  2014-2020 questionnaire structures .................................................. 169 

8.3.  Structure of the questionnaire for beneficiaries ................................. 171 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Acronyms 

AGRI   

Directorate General for Agriculture and Rural development  

AMIF 

Asylum, Migration and Integration Fund 

BMVI   

Border Management and Visa Instrument 

CCI 

CF 

Character Code Identifying – programme identifier 

Cohesion Fund 

EAFRD 

European Agricultural Fund for Rural Development 

EMFAF 

European Maritime, Fisheries and Aquaculture Fund 

EMFF   

European Maritime and Fisheries Fund 

EMPL   

Directorate-General for Employment, Social Affairs and Inclusion 

ERDF   

European Regional Development Fund 

ESF(+)  

European Social Fund (Plus) 

FNLC   

Financing Not Linked to Cost 

HOME  

Directorate-General for Migration and Home Affairs 

ISF 

JTF 

Internal Security Fund 

Just Transition Fund 

MARE   

Directorate General for Maritime affairs and Fisheries  

OP 

Operational Programme 

REGIO  

Directorate-General for Regional and Urban Policy 

SCO 

SFC 

Simplified Cost Option 

System for Fund Management in the European Union 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Introduction 

This report is the final deliverable in the study on the uptake of Simplified Cost Options 
(SCO) and Financing Not Linked to Costs (FNLC) for Common Provisions Regulation 
(CPR) Funds in the 2014-2020 and 2021-2027 programming periods.  

The report highlights key findings on the uptake of simplification measures across two 
programming periods i.e. 2014-2020 and 2021-2027. It distinguishes between use at a 
lower  level  (between  programme  authorities  and  beneficiaries)  and  at  an  upper  level 
(between  programme  authorities  and  the  European  Commission).  These  findings  are 
primarily based on data from the survey of programme authorities from 27 February to 
31  May  2024.  In  addition,  the  report  includes  an  analysis  of  qualitative  responses 
regarding reasons for using and not using SCO/FNLC, as well as perceptions of their 
advantages and hindrances to their use. Furthermore, the report presents an analysis of 
qualitative data collected through another survey, of CPR Funds beneficiaries, between 
July and August 2024. Finally, key lessons have been elaborated. 

The  document  also  has  sections  with  information  and  analysis  for  funds  under  the 
responsibility of individual Directorates-General (DGs) as follows:  

•  Chapter 1 - data collection and analysis methodology. 

•  Chapter 2 - survey responses across funds and programming periods.  

•  Chapter 3 - SCO under EAFRD in 2014-2020. 

•  Chapter 4 - SCO and FNLC under ESF and ESF+ for the programming periods 

2014-2020 and 2021-2027 respectively. 

•  Chapter 5 - SCO under AMIF, BMVI and ISF in 2021-2027. 

•  Chapter  6  -  SCO  under  EMFF  and  EMFAF  for  2014-2020  and  2021-2027 

respectively. 

•  Chapter 7 - SCO and FNLC under CF, ERDF and JTF for 2014-2020 and 2021-

2027 respectively. 

6 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Executive summary 

This  study  examines  the  use  of  Simplified  Cost  Options  (SCOs)  and  Financing  Not 
Linked to Costs (FNLC) by aggregating schemes classified as ‘in use’ and ‘ programmed’ 
across two levels: 

•  Upper level: Between the European Commission and Member States. 
•  Lower level: Between programme authorities and beneficiaries. 

The analysis covers both the 2014-2020 and 2021-2027 programming periods, with three 
main objectives: 

•  Mapping  and  quantifying  the  use  of  SCOs  and  FNLC  during  the  2014-2020 

programming period for ERDF, CF, ESF, EAFRD, and EMFF. 

•  Mapping  and  quantifying  the  use  of  SCOs  and  FNLC  for  the  2021-2027 
programming  period  across  ERDF,  CF,  ESF+,  JTF,  EMFAF,  AMIF,  ISF,  and 
BMVI, differentiating between those already ‘in use’ and those ‘programmed’ for 
future implementation.  
It is important to highlight that the study applied a very stringent definition of what 
qualifies  as  ‘programmed.’  Only  schemes  already  ‘under  development’  by 
managing authorities were classified as programmed. This means that schemes 
not  yet  in  the  development  phase  by  managing  authorities  at  the  time  of  the 
survey (spring 2024) were not included. 

• 

•  Exploring  the  advantages  of  SCOs  and  FNLCs,  identifying  barriers  to  their 
implementation and offering recommendations to improve their adoption during 
2021-2027 and post-2027 programming periods. 

Methodology 

Data collection relied primarily on a survey targeting programme authorities across all 
CPR  programmes  implemented  in  2014–2020  and  2021–2027.  This  survey  was 
conducted between 27 February and 31 May 2024. 

A second survey aimed at a sample of CPR Funds beneficiaries was conducted from 1 
July to 31 August 2024. 

Response rate 

•  Programme  Authorities  Survey:  Over  740  completed  questionnaires  were 
received. Response rates were above 50% for most funds, except EMFF/EMFAF 
(47%)  and  EAFRD  (30%).  The  response  rate  ranged  from  57%  for  JTF  (26 
responses  from  46  programmes)  to  87%  for  CF  (41  responses  from  47 
programmes). 

•  Beneficiaries Survey: Over 1 770 completed questionnaires were received from 
26  Member  States,  818  from  beneficiaries  of  REGIO  Funds  (i.e.,  CF,  ERDF, 
Interreg,  JTF),  699  from  ESF/ESF+  beneficiaries,  114  from  EMFF/EMFAF 
beneficiaries,  63  from  EAFRD  beneficiaries  and  81  from  HOME  Funds 
beneficiaries (i.e., AMIF, BMVI, ISF). 

Quality Assurance 

Survey data underwent rigorous checks to ensure consistency and accuracy, particularly 
concerning amounts covered by simplification schemes. Respondents were recontacted 
to resolve inconsistencies  and quality  checks  continued  until  September 2024. Of  the 
more than 740 completed questionnaires, 612 passed the quality check. The response 
rate, considering only programmes that passed the quality check, exceeds 50% for all 
Funds except for EAFRD (29%), EMFF/EMFAF (40%), and ESF/ESF+ (42%) 

7 

 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Preliminary  findings  were  shared  with  stakeholders  including  the  CPR  Expert  Group, 
ESF+  Committee,  REGIO  Simplification  matrix,  ESF+  Simplification  Ambassadors’ 
Network  and  transnational  simplification  networks  in  Malmö  (October  2024)  and 
Marseille  (November  2024).  Stakeholder  feedback  helped  consolidating  the  study’s 
results and drawing the related conclusions. 

Key Findings on the Uptake of Simplification Measures 

•  2014–2020 Programming Period: 

-  CF: 0.5% of the total budget (EUR 0.38 billion). 
-  EAFRD1: 4.6% (EUR 9.2 billion). 
-  EMFF: 7.7% (EUR 0.6 billion). 
-  ERDF: 6.7% (EUR 20.5 billion). 
-  ESF: 31.5% at the lower level (EUR 44.2 billion) and 6.5% at the upper 
level under Article 14(1) of (ESF) Regulation 1304/2013 (EUR 9.2 billion). 

•  2021–2027 Programming Period: 

-  There  is  a  significant  increase  in  the  budget  covered  by  simplification 
measures. For example: ESF coverage increased from EUR 44.2 billion 
to  EUR  70.7  billion  (+63%);  ERDF  from  EUR  20.5  billion  to  EUR  37.5 
billion; CF from EUR 0.38 billion to EUR 1.1 billion; Fisheries fund from 
EUR 0.6 billion (EMFF) to over EUR 1 billion (EMFAF). 

-  Home  Funds  (AMIF,  BMVI,  ISF)  are  less  experienced  with  SCOs  and 
FNLCs  but  show  a  strong  interest  in  simplification  measures.  SCOs 
account for 19.5% of the AMIF budget (EUR 1.5 billion), 6.7% of the BMVI 
budget (EUR 0.36 billion), and 11% of the ISF budget (EUR 0.16 billion). 
-  Upper Level Use: Predominantly in ERDF and ESF+, where adoption has 
increased  compared  to  the  use  of  Article  14(1)  of  (ESF)  Regulation 
1304/2013 in 2014–2020. 

-  FNLCs:  Limited  uptake  covering  0.7%  (EUR  2.2  billion)  of  the  ERDF 
budget and 6% (EUR 7.8 billion) of the ESF+ budget. However, several 
Member States are actively exploring FNLC schemes for future use. 

Advantages of Simplification Measures 

•  Across  both  periods,  the  primary  benefits  for  programme  authorities  include 

reduced administrative burden and easier compliance with rules. 

•  There  is  a  noticeable  shift  from  focusing  on  administrative  efficiency  to 

appreciating broader benefits such as: 

-  Enhanced orientation on results; 
-  Benefits for beneficiaries; 
Improved governance. 
- 

•  Beneficiaries highlighted similar advantages, particularly reduced administrative 
burden and the  potential  to improve  project  quality  due to  a  stronger  focus on 
results. 

Challenges to Developing Simplification Schemes 

•  SCOs: 

1 The analysis concerns only the use of SCOs under non-Integrated Administration and 
Control System (IACS) measures. 

8 

 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

-  The most significant challenges include a lack of historical data and the 

absence of alternative data sources. 

•  FNLCs: 

-  The main barriers are a lack of experience of designing and implementing 
FNLC schemes as well as the administrative burden associated with their 
development. 

-  These  challenges  reflect  the  early-stage adoption of  FNLCs  and mirror 

initial apprehensions observed when SCOs were first introduced. 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Key findings and lessons learnt 

Overview of the uptake 

Figure  1  below  summarises  the  key  figures  on  the  uptake  of  simplification  measures 
across funds and programming periods, aggregating the information on SCOs and FNLC 
mapped  in  this  study.  Specifically,  the  size  of  the  bars  represents  the  share  of  total 
budget  covered  by  simplification  measures  for  each  fund,  enabling  comparisons 
between  the  two  programming  periods.  The  figure  also  distinguishes  between 
simplification  measures  at  the  lower  level  (blue  bars)  and  at  the  upper  level  (orange 
bars). In addition, below the figure, there is a table with the absolute value of the budget 
covered by the mapped simplification measures. 

Figure 1 Uptake of simplification measures by fund 

Coverage at upper level

Coverage at lower level

31,5%

24,9%

49,8%

19,5%

D
R
F
A
E

F
S
E

+
F
S
E

I

F
M
A

I

V
M
B

F
S

I

2014-2020

2014-2020

2021-2027

2021-2027

2021-2027

2021-2027

F
F
M
E

F
A
F
M
E

2014-2020

2021-2027

2014-2020

2021-2027

2014-2020

2021-2027

2021-2027

F
D
R
E

F
C

F
T
J

4,6%

6,5%

6,7%

11,0%

7,7%

12,8%

6,7%

4,2%

11,5%

0,5%

0,7%

2,3%

2,3%

10,4%

10 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Fund 

Programming 
period 

Coverage at lower 
level (EUR bn) 

Coverage at upper 
level (EUR bn) 

EAFRD 

2014-2020 

ESF 

ESF+ 

AMIF 

BMVI 

ISF 

2014-2020 

2021-2027 

2021-2027 

2021-2027 

2021-2027 

EMFF 

2014-2020 

EMFAF 

2021-2027 

ERDF 

ERDF 

CF 

CF 

JTF 

2014-2020 

2021-2027 

2014-2020 

2021-2027 

2021-2027 

9.180 

44.245 

70.679 

1.460 

0.357 

0.163 

0.596 

1.022 

20.501 

37.484 

0.375 

1.141 

2.808 

- 

9.174 

22.892 

0 

0 

0 

- 

0 

- 

9.582 

- 

0.309 

0.340 

When  examining  the  funds  where  simplification  has  been  mapped  across  two 
programming  periods  (i.e.,  ESF/ESF+,  EMFF/EMFAF,  CF,  and  ERDF),  there  is  a 
significant increase in the budget share covered by simplification measures in the 2021–
2027 period compared to the previous programming period. 

For  the  uptake  of  simplification  measures  in  2021–2027,  the  study  applied  narrow 
definition  of  what  qualifies  as  ‘schemes  programmed.’  Only  schemes  already  ‘under 
development’ by managing authorities were classified as ‘programmed.’ This means that 
schemes not yet in the development phase by managing authorities at the time of the 
survey (spring 2024) were not included. 

Even with this consideration, the increased uptake of simplification options is particularly 
evident from the financial flow between Member States and beneficiaries (lower level) 
of + 63% for ESF, while ERDF, CF and EMFAF almost doubled the budget covered by 
these  measures  compared  to  2014-2020.  In  absolute  terms,  the  ESF  increased  its 
coverage  from  EUR  44.2  billion  in  2014–2020  to  EUR  70.7  billion  in  2021–2027. 
Similarly,  for  ERDF  it  rose from  EUR  20.5  billion  in 2014–2020 to  EUR  37.5  billion  in 
2021–2027. For CF, the coverage tripled from approximately EUR 0.38 billion in 2014–
2020  to  EUR  1.1  billion  in  2021–2027.  Finally,  the  fisheries  fund  coverage  increased 
from some EUR 600 million under EMFF to over EUR 1 billion under EMFAF in 2021–
2027. 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

The Home Funds (AMIF, BMVI, and ISF) have less experience with SCOs and FNLC, 
yet their use at the lower level demonstrates a strong interest in simplification measures. 
SCOs  mapped  at  the  lower  level  account  for  19.5%  of  the  AMIF  budget,  6.7%  of  the 
BMVI budget, and 11% of the ISF budget - equivalent to approximately EUR 1.5 billion, 
EUR 360 million, and EUR 160 million, respectively. 

The use of simplification measures at the upper level is less widespread and is primarily 
concentrated in the two funds with the most experience, ESF+ and ERDF. However, a 
comparison between the use of the option under Article 14.1 of Regulation 1304/2013 in 
ESF and the options under Article 94-95 of the CPR in 2021-2027 for ESF+ reveals that 
even  at  the  upper  level,  the  simplification  measures  have  significantly  increased 
compared to the previous programming period (in absolute terms, from EUR 9.2 billion 
covered by Article 14.1 in 2014–2020 to EUR 22.9 billion covered by Articles 94-95 of 
the CPR in 2021–2027). 

A significant portion of the budget covered by simplification measures comes from SCOs, 
while the impact of FNLCs remains more limited at present. As of spring 2024, the data 
collection period for this study, FNLCs mapped are relevant only for ERDF and ESF+. 
FNLCs cover 0.7% and 6% of their respective budgets, or EUR 2.2 billion and EUR 8.5 
billion, respectively. 

Main advantages 

Figure 2 below presents programme authorities’perceptions of advantages offered by 
simplification measures. This illustrates the share of survey respondents who rated each 
advantage as highly relevant, aggregating all responses from all funds. Specific figures 
are provided for each fund in the following chapters. 

12 

 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 2 Advantages of simplification measures for programme authorities 

LESS
ADMINISTRATIV
E BURDEN

SIMPLER
COMPLIANCE

LOWER ERROR
RATE

EASY TO APPLY
FOR
BENEFICIARIES

FOCUS ON
OTHER
ACTIVITIES

MORE FOCUS
ON RESULTS

66%

62%

60%

58%

60%

55%

42%

44%
45%

49%
50%
50%

28%
26%

28%

40%

43%

SCO 14-20

SCO 21-27

FNLC 21-27

58%

Across  both  programming  periods,  the  most  significant  advantages  of  SCOs  for 
programme  authorities  are reduced  administrative  burden  and  easier  compliance  with 
the rules. As shown in the figure above, in the 2021-2027 programming period the share 
of respondents who consider other advantages as highly relevant has increased across 
the  board,  compared  to  the  previous  programming  period.  These  include  a  stronger 
emphasis on results, benefits for beneficiaries and enhanced governance. This suggests 
that with the time and by gaining experience, programme authorities increasingly value 
broader, outcome-oriented benefits of SCOs beyond administrative simplification. 

This  evolution  highlights  a  growing  recognition  of  the  strategic  advantages  of  SCOs, 
transitioning from an initial focus on efficiency gains to a more comprehensive emphasis 
on achieving higher-quality and more impactful outcomes. 

The  emphasis  on  benefits  from  improving  project  quality  is  similarly  reflected  in 
responses about the potential advantages of FNLCs. For these, ‘more focus on results’ 
is the second most relevant advantage, just after ‘less administrative burden.’ 

For beneficiaries, as shown in the figure 3 below, the main advantages of SCOs are 
reduced administrative burden (for 38% of respondents) and the potential to enhance 
project quality by enabling a greater focus on results (25%). There was no feedback from 
beneficiaries on FNLC. 

13 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 3 Advantages of SCO schemes for beneficiaries  

REDUCTION OF
ADMINISTRATIVE BURDEN

38%

FASTER REIMBURSEMENT

17%

LOWER ERROR RATE

19%

MORE FOCUS ON QUALITY
AND RESULTS

25%

Among  the  potential  advantages  of  using  simplification  measures  is  the  possible 
improvement  in  programme  governance  through  greater  involvement  of  audit 
authorities,  both  formally  and  informally.  The  figure  4  below  provides  a  comparative 
analysis of the involvement of audit authorities in developing simplification schemes, with 
data aggregated from all the funds.  

Figure 4 Involvement of audit authorities in defining SCOs/FNLC 

55%

AA WAS NOT
CONSULTED

8%

AA WAS
CONSULTED
INFORMALLY

AA COMPLETED
A FORMAL EX
ANTE
ASSESSMENT

30%

27%

33%

18%

19%

36%

SCO 14-20

SCO 21-27

FNLC 21-27

73%

14 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

The “optional” involvement of audit authorities in developing SCO schemes during the 
2021-2027 programming period concerns exclusively lower level schemes. All schemes 
at the upper level approved under Article 94 of the CPR require a formal assessment by 
the  audit  authorities.  The  involvement  of  audit  authorities  in  the  development  of  SCO 
schemes has increased over time. This is through informal consultation, rising from 27% 
of schemes in the 2014-2020 period to 33% in the 2021-2027 period. More notably formal 
assessment has increased from 18% of schemes in 2014-2020 to 36% in 2021-2027. 
For FNLC, data on schemes mapped under ERDF and ESF+ indicate that, even though 
it is not a legal requirement, audit authorities are asked to provide assessments of the 
schemes  in  the  vast  majority  of  cases  (73%  informal  assessment,  19%  formal 
assessment). 

Main  challenges 

Figure 5 below presents the perceptions of programme authorities regarding potential 
challenges to developing SCOs during the current programming period (2021–2027). It 
illustrates  the  share  of  survey  respondents  who  identified  various  issues  as  highly 
relevant. This figure aggregates data across all the funds, while detailed figures for each 
fund are provided in the subsequent chapters 

Figure 5 Main issues faced in developing SCO schemes in 2021-2027 

NEGATIVE FEEDBACK FROM THE AA

5%

LEGAL UNCERTAINTY

16%

LACK OF KNOWLEDGE/EXPERTISE

13%

LACK OF RESOURCES

LACK OF HISTORICAL DATA

18%

19%

NO ALTERNATIVE SOURCES

22%

The challenges for programme authorities in developing SCO schemes are primarily the 
lack of historical data which is perceived as highly relevant by 19% of respondents, while 
the  absence  of  alternative  data sources  to  address the  limitations of  historical  data  is 
seen as the most significant challenge for 22%.  

Resource  limitations  (highly  relevant  for  18%  of  respondents)  predominantly  relate  to 
human resources and time constraints rather than financial shortages. 

The qualitative responses concerning knowledge and expertise gaps as critical issues 
significantly overlap with ‘lack of resources.’ Some respondents mentioned the absence 
of  national  coordination  to  address  the  shared  needs  of  managing  authorities  facing 

15 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

similar challenges. Additionally, some noted administrative cultures deeply entrenched 
in real-cost justifications, which can impede the transition toward SCOs. 

Some programme authorities (in particular under ERDF and ESF+) have overcome the 
lack of  historical  data  by  using  statistics from  national  institutes,  market  surveys,  or  a 
combination of these. Alternative sources have also been combined with an increased 
use of expert judgement, showing it is possible to develop simplification measures when 
historical data are not available. 

Leveraging  the  experiences  of  authorities  more  advanced  in  using  simplification 
measures would greatly assist those  looking to increase their use of these measures. 
Fostering knowledge transfer and best practice sharing would enable less experienced 
authorities to capitalise on opportunities provided by the regulatory framework.  

At the time of the survey (spring 2024), the primary reason for authorities not using FNLC 
(see  figure  6  below)  is  the  lack  of  information/experience  on  how  to  design  and 
implement  such  schemes  (highly  important  for  44%  of  respondents).  Managing 
authorities also pointed out the administrative burden of designing FNLC schemes and 
the significant legal uncertainty associated with them (highly important for 32% and 30% 
of respondents respectively).  

Figure 6 Key reasons for not using FNLC 

NOT SUITABLE FOR THE
PROGRAMME

RISK OF SYSTEMIC IMPACT

14%

NOT OBVIOUS BENEFITS

TOO RISKY

LEGAL UNCERTAINTY

BURDENSOME

LACK OF
INFORMATION/EXPERIENCE

25%

23%

32%

30%

32%

44%

Additional reasons include the perception of risks and legal uncertainty. The comments 
from respondents indicate that these two categories often overlap. Both areas include 
uncertainties regarding FNLC covered by public procurement or doubts about the audit 
trail, such as ‘it is not entirely clear what the audit expectations are for substantiating the 
fulfillment  of  the  conditions.’  Additionally,  respondents  expressed  concerns  about 
potential  consequences  of  not  fulfilling  reimbursement  conditions,  particularly  where 
lower  level  financial  flows    (i.e.  between  Member  States  and  beneficiaries)  would  be 
based on real costs. 

The reasons for the limited use of FNLC must be considered in context. Firstly, FNLCs 
are a recent addition to simplification measures available to programme authorities. The 
initial  challenges  and  apprehensions  for  programme  authorities  designing  and 
implementing FNLCs mirror experiences when SCOs were first introduced. As illustrated 

16 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

by reasons for ERDF/CF authorities for not using SCOs in 20182, there was widespread 
hesitation due to a lack of familiarity, insufficient practical knowledge and potential legal 
and administrative complexities/risks. However, as programme authorities became more 
experienced and confident in implementing SCOs, the use increased significantly. 

While FNLCs are currently in limited use, several Member States are actively considering 
and developing new FNLC schemes. As knowledge increases and practical examples 
become more widespread, the use of FNLCs should expand beyond the initial estimates 
presented in this report. 

Lessons learnt/recommendations 

→  At  EU  level,  further  promote  simplification  particularly  at  the  highest  (policy  and 
technical) level and develop a structured communication to inform about the advantages 
of  simplification  measures  and  to  further  disseminate  the  numerous  good  practices 
available  at  EU  level.  Investing  in  promotion  and  communication  plays  a  key  role  for 
overcoming  preconceptions  around  SCOs/FNLC  and  encouraging  less  experienced 
authorities and stakeholders to change mindset towards simplification measures.  

→ At EU level, continue to enhance exchanges of experience between more and less 
experienced  programme  authorities  to  achieve  widespread  use  of  simplification 
measures.  This  includes  to  further  enhance  the  approach  of  EMPL  and  REGIO 
Transnational networks on simplification and to extend it to other Directorates-General 
(e.g.,  by  establishing  additional  networks  specifically  dedicated  to  other  Funds).  The 
networks  also  serve  to  test  and  discuss  concrete  proposals  to  facilitate  a  wider  and 
easier uptake of simplification measures. 

→  At  EU  level,  a  particularly  beneficial  step  would  be  the  development  of  models  of 
SCOs/FNLC that provide Member States with a clear framework and outline essential 
aspects necessary for designing their own country-specific schemes. Such models could 
serve as adaptable tools, enabling programme authorities to tailor the schemes to their 
unique  national  contexts  before  submitting  them  for  approval  by  the  European 
Commission.  

→  At  EU  level,  further  enhance  capacity  building  and  knowledge  sharing  around 
simplification  measures within  each  Directorate-General,  also  by  establishing  working 
groups / networks coordinated by the units responsible for simplification measures and 
involving Geographical Desks and, where relevant, Policy units.  

→ At Member State level, make enhanced simplification and wider use of simplification 
measures  a  strategic  objective  and  develop  an  agenda  for  simplification,  taking  into 
account  that  the  advantages  of  simplification  measures  go  beyond  the  reduction  of 
administrative costs and burden and include enhanced focus on quality and results of 
interventions.  The  agenda  for  simplification  should  encourage  collaboration  among 
authorities  responsible  for  different  Funds,  building  on  the  experience  of  the  most 
advanced users of simplification measures.   

2 https://ec.europa.eu/regional_policy/sources/studies/use_sco_esif_en.pdf 

17 

 
 
 
 
 
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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

→ At Member State level, establish national networks and national coordination centres 
on simplification, capitalising on the experience of the transnational networks and of the 
Member States which are more advanced in the use of simplification measures.   

→  At  Member  State  level,  develop  national  roadmaps  to  achieve  the  objective  of 
enhanced simplification, through an increased use of SCOs and FNLC. The roadmaps 
should include: an assessment of the stay of play and key issues hindering the use of 
simplification measures in the Member State, a clear description of the specific actions 
to be implemented by national / regional authorities, a precise timeline and a description 
of  roles  and  responsibilities  of  all  actors  involved  in  implementation,  including  those 
implementing operations on the ground  

→  At  Member  State  level,  strengthen  formal  and  informal  collaboration  between 
managing authorities and audit authorities, in particular enhance the involvement of audit 
authorities  when  defining  simplification  schemes,  while  fully  respecting  the  roles  and 
responsibilities of the programme authorities. 

→  At  Member  State  level,  further  enhance  opportunities  for  collaboration  between 
programme authorities and beneficiaries and ensure that simplification is achieved for all 
parties involved in the implementation of EU funded interventions. 

18 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

1. 

Methodology 

This study maps actual and planned use of SCO and FNLC at European Commission – 
Member State (upper) level as well as programme authority – beneficiary (lower) level in 
the 2014-2020 and 2021-2027 programming periods. 

The study has three objectives: 

•  Mapping/quantifying SCO  use in the 2014-2020 programming period for ERDF, 

CF, ESF, EAFRD and EMFF. This involves updating the 2018 study.  

•  Mapping/quantifying SCO and FNLC use in the 2021-2027 programming period 
for  ERDF,  CF,  ESF+,  JTF,  EMFAF,  AMIF,  ISF  and  BMVI.  This  differentiates 
between SCOs and FNLC already ‘in use’ and those ‘programmed’ to be used. 

•  Exploring  the  advantages  of  SCOs  and  FNLC,  also  analysing  enduring 
lessons  and 
hindrances 
recommendations  to  improve  their  use  in  the  2021-2027  and  post-2027 
programming periods. 

implementation,  as  well  as  deriving 

their 

to 

The  primary  method  for  collecting  data  and  information  was  a  survey  of  programme 
authorities which involved the following steps: 

•  Step 1: structuring the inception phase. A kick-off meeting in Brussels between 
the  study  team  and  the  Commission  on  9  January  2024  tackled  a  number  of 
issues  to  ensure  smooth  and  succesful  implementation  of  the  study.  A 
subsequent  meeting    with  the  Commission  in  Brussels  on  1  February  2024 
helped to further define the questionnaires and ensure a uniform understanding 
of the information to be gathered. 

•  Step 2: collecting data from Member States on SCO and FNLC use across two 
programming  periods  (i.e.  2014-2020  and  2021-2027).  This  covered  all  27 
Member States and required a team of national experts. 

•  Step  3:  checking  and  cleaning 

the  database.  Survey 

information  was 
meticulously verified to ensure consistency, particularly in relation to the amounts 
covered by the schemes. These controls continued after the survey closed and 
any programme authorities that provided data with potential inconsistencies were 
recontacted. The goal was to create a reliable database to support analysis for 
the final report. 

•  Step 4: analysing the data including calculating SCO and FNLC coverage. Once 
the data had been cleaned they were consolidated in a database, which is the 
basis for this report.  

•  Step 5: formulating lessons learnt and recommendations.  

The study also includes information from a sample of CPR Funds beneficiaries. A second 
survey, targeting these beneficiaries was launched from July to August 2024.  

19 

 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

1.1.   Structuring data collection 

Most  of  the  study  depends  on  web  survey  responses  from  programme  authorities.  A 
significant  factor  when collecting such  crucial  primary  data  is  for  questionnaires  to  be 
fully aligned with the objectives. To ensure this, the study team scheduled two meetings 
to discuss concepts and definitions with the Commission, ensuring clarity and common 
understanding. The table below summarises the agreed definitions. These are presented 
in  the  introduction  to  the  web  survey  and  were  shared  with  national  experts  and  all 
respondents. 

Table 1 – Key concepts and definitions agreed with the European Commission 

SCO 
Lower 
Level 

SCO  
Upper 
Level 

FNLC 

In use 

Programmed 

SCO already adopted or included in a call 
for proposals/in the programme. 

SCO currently under development or fine-
tuning and will be used in the near future. 

For SCOs developed by the Member State 
under Article 94(2) CPR, the SCO included 
in Appendix 1 of the programme has been 
already approved by the Commission. 

For  SCOs  adopted  by  the  Commission 
under Article 94(4) CPR (‘EU level SCOs’), 
a  formal  decision  to  use  the  concerned 
SCOs  has  been  taken  by  the  programme 
authority. 

For SCOs developed by the Member State 
under  Article  94(2)  CPR,  the  programme 
authority  is  developing  or  fine-tuning  the 
SCO proposal (to be) included in Appendix 
1 of the programme (but not yet approved 
by the Commission). 

For  SCOs  adopted  by  the  Commission 
under Article 94(4) CPR (‘EU level SCOs’), 
the  programme  authority  has  already 
programmed the operation(s) to which the 
concerned SCO will be applied. 

For FNLC developed by the Member State 
under  Article  95(2)  CPR, 
the  FNLC 
included  in  Appendix  2  of  the  programme 
has  been  already  approved  by 
the 
Commission. 

For  FNLC  adopted  by  the  Commission 
under Article 95(4) CPR (‘EU level FNLC’), 
a  formal  decision  to  use  the  concerned 
FNLC  has  been  taken  by  the  programme 
authority. 

For FNLC developed by the Member State 
under  Article  95(2)  CPR,  the  programme 
authority  is  developing  or  fine  tuning  the 
FNCL  proposal 
in 
Appendix 2 of the programme (but not yet 
approved by the Commission). 

included 

(to  be) 

For  FNLC  adopted  by  the  Commission 
under Article 95(4) CPR (‘EU level FNLC’), 
the  programme  authority  has  already 
programmed the operation(s) to which the 
FNLC will be applied. 

In addition, for each survey the study team submitted a draft questionnaire tailored to 
each fund and programming period to the respective DG. This allowed each DG to review 
and confirm the appropriateness and coherence of the questions. 

The questionnaires are presented in the annex (see chapter 8). 

20 

 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

1.2.  Data collection 

The  surveys targeted  all  authorities of  CPR  programmes  implemented  during the  two 
most recent programming periods. 

The  table  below  illustrates  the  number  of  programmes,  differentiating  between  2014-
2020 and 2021-2027 programmes and specifying the number of programmes per DG. 
Based  on  data  from  the  Commission,  the  web-survey  involved  537  authorities  of 
programmes in 2014-2020 and 484 authorities of programmes in 2021-2027. 

Table 2 – Number of programmes in the web-survey mapping SCO and FNLC use 
in 2014-2020 and 2021-2027 

2014-2020 

2021-2027 

Member 
State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

I

O
G
E
R

1 

3 

5 

1 

6 

15 

2 

1 

21 

1 

7 

2 

2 

2 

22 

1 

2 

4 

5 

2 

4 

9 

L
P
M
E

1 

4 

2 

1 

1 

16 

1 

1 

23 

6 

1 

1 

21 

1 

1 

1 

1 

2 

2 

1 

/

L
P
M
E
O
G
E
R

I

1 

1 

2 

1 

16 

2 

27 

5 

8 

1 

1 

16 

8 

1 

I

R
G
A

1 

2 

1 

1 

1 

14 

1 

1 

1 

18 

2 

30 

1 

1 

1 

23 

1 

1 

1 

1 

1 

1 

3 

1 

1 

E
R
A
M

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

I

O
G
E
R

1 

3 

6 

6 

15 

2 

4 

21 

3 

2 

2 

3 

21 

1 

1 

5 

5 

2 

12 

10 

L
P
M
E

1 

5 

3 

1 

15 

1 

1 

23 

2 

1 

1 

18 

1 

1 

1 

1 

2 

1 

1 

1 

/

L
P
M
E
O
G
E
R

I

E
M
O
H

E
R
A
M

1 

1 

1 

2 

1 

16 

2 

17 

5 

9 

1 

1 

1 

16 

8 

3 

3 

3 

3 

3 

3 

3 

1 

3 

3 

3 

3 

3 

3 

3 

2 

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

2014-2020 

2021-2027 

Member 
State 

SI 

SK 

UK 

TC 

L
P
M
E

1 

6 

I

O
G
E
R

4 

9 

76 

TOTAL 

207 

95 

TOTAL 

/

L
P
M
E
O
G
E
R

I

1 

1 

92 

537 

I

O
G
E
R

L
P
M
E

1 

I

R
G
A

1 

1 

4 

E
R
A
M

1 

1 

1 

116 

27 

86 

211 

82 

/

L
P
M
E
O
G
E
R

I

1 

1 

87 

484 

E
M
O
H

3 

3 

E
R
A
M

1 

1 

78 

26 

Source : https://cohesiondata.ec.europa.eu/ 

The  web-survey  for  programme  authorities  was  launched  on  27  February  and 
ended on 31 May 2024. 

To  assist  respondents,  the  web  survey  was  translated  into  12  languages:  Bulgarian, 
Czech,  French,  German,  Greek,  Hungarian,  Italian,  Polish,  Portuguese,  Romanian, 
Slovak and Spanish. For Member States not covered by these translations, the survey 
was provided in English. 

Each programme authority was contacted via email with their addresses provided by the 
European Commission. An automatic email, generated by the Alchemer web platform, 
included a link to the web survey and an official invitation letter from the Commission. 

After  the  initial  invitation,  national  experts  began  reaching  out  to  each  programme 
authority, offering support to complete the questionnaires. Additionally, a helpdesk email 
address was managed by the core team to provide continuous support to any authority 
that received the survey but had not been contacted by a national expert. This ensured 
that all respondents could receive assistance and guidance as needed throughout the 
process. Authorities with specific challenges were offered tailored solutions from the core 
team  to  facilitate  their  participation.  For  example,  some  authorities  encountered 
difficulties  accessing  the  Alchemer  web  platform due to  strict  security  protocols  within 
their departments. The core team emailed them the questionnaire in Excel format.  

During the three months of the survey, the core team continuously monitored responses, 
notifying  national  experts  of  low  response rates in  their  country.  For  particular  issues, 
such as national experts facing difficulties reaching authorities, the core team informed 
the Commission. The Commission then alerted its services such as geographical units 
and  requested  support  from  national  authorities  involved  in  the  two  transnational 
networks  on  simplification.  Assistance  from  these  networks  was  particularly  effective, 
especially  when  email  addresses  were  outdated  or  not  directed  to  the  relevant 
individuals. 

Moreover, the study's preliminary findings were shared with key stakeholders to ensure 
transparency and gather additional insights. These included presentations to the CPR 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Expert  Group,  ESF+  Committee,  ESF+  Simplification  Ambassadors’  Network  and 
REGIO  Simplification  matrix.  The  findings  were  also  discussed  at  the  ESF+ 
Transnational Network on Simplification meeting in Malmö in October 2024, and at the 
REGIO Transnational Network on Simplification meeting in Marseille in November 2024. 

As a result, several additional inputs were submitted to the core team during October 
and  November  2024.  These  contributions  played  a  critical  role  in  refining  the  study’s 
results and ensuring their accuracy.  

The beneficiary web-survey was launched on 1 July and ended on 31 August 2024. 
Each  programme  authority  that  participated  in  the  initial  survey  was  recontacted  and 
requested to send a web survey link to their beneficiaries. This survey was structured 
around the questions outlined in Box 6. 

1.3.  Checking and cleaning 

Before proceeding with the analysis, data from the survey underwent rigorous checks to 
ensure consistency and prevent potential biases from incoherent data, including: 

Programme ID coherence. 

Each response was scrutinised to verify consistency regarding the type of programme. 
We ensured that the programme identifier (CCI), programming period and the fund all 
corresponded. Several respondents were recontacted for clarification. A common error 
involved programme authorities completing the questionnaire for the 2014-2020 period 
while referencing the CCI of the 2021-2027 programme, or vice versa. 

Amount covered or expected to be covered.  

The amounts covered by the schemes presented particular challenges for respondents. 
At scheme level, automatic alerts were triggered if (i) respondents failed to provide data 
on the amount covered by the scheme at the end of the programming period (for 2014-
2020  programmes),  or  the  amount  programmed  to  be  covered  by  the  end  of  the 
programming period (for 2021-2027 programmes); or (ii) respondents reported amounts 
for reimbursed/claimed expenditure which exceeded amounts planned for the end of the 
programming period (for 2021-2027 programmes). 

At programme level, automatic alerts notified if the budget for 2014-2020 programmes 
was near 0%, or for programmes funded in 2021-2027 was programmed to be near 0%, 
or exceeded the programme budget.  

In such instances, respondents were recontacted to verify and correct the information. 
Additionally, we reached out to all programme authorities who had to use SCOs for small 
operations but reported not using or intending to use any3. This was to determine whether 
their programme budget is not covered by an SCO, or they do not intend to participate 
in the survey. For the former, their response is included in the calculations for the total 
budget  covered  by  SCO  at  both  EU  and  Member  State  levels.  For  the  latter,  the 

3 Programme authorities required to use SCOs are those where Article 67(2a) of the Regulation 1303/2013 and Article 
53(2) of the Regulation 2021/1060 apply. As a title of example, any ESF, ERDF, JTF and HOME Funds authorities 
that responded ‘NO’ to the initial question about the SCO use in 2021-2027 were recontacted. Where a programme 
authority declared they do not use an SCO, we also inquired whether this means they do not finance small operations 
(i.e. operations where Article 53.2 CPR is applicable). 

23 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

questionnaire was deemed incomplete and excluded from the responses considered for 
this report. 

Estimating the amounts expected to be covered by SCO at the end of the  2021-2027 
programming period has been a major challenge. Many programme authorities say they 
cannot estimate these. Their responses have been excluded and are not considered for 
the  quantitative  analysis  in  this  report.  However,  their  qualitative  insights  have  been 
taken into account when analysing reasons for using and not using SCO/FNLC, as well 
as perceptions of the advantages and factors impeding their use. 

Checks and integration of data with alternative sources.  

Data  from  the  survey  were  verified,  particularly  with  data  from  the  SFC  portal.  Data 
approved  and  submitted  to  the  Commission  under  Appendixes  1  and  2  were  used  to 
refine and supplement survey responses. Integrating survey data with SFC data involved 
corrections  to  align  the  information  if:  (i)  the  amounts  for  approved  schemes  were 
inconsistent with information in Appendix 1 and 2, or (ii) survey data was only partial, 
such as multi-fund SCO data relating only to a single fund.  

In addition to the SFC, survey data were verified against databases provided by Member 
States.  

Consistency between 2014-2020 and 2021-2027 data. 

There were challenges in estimating SCO coverage at the end of 2021-2027 for ERDF, 
CF, ESF+ and EMFAF, where both programming periods were mapped and analysed. 
An intermediate step verified data consistency before proceeding with the estimates for 
the end of the 2021-2027 period where the responses were checked against Member 
State data for the 2014-2020 period. 

After reviewing the data, the SCO share of budget at Member State level was compared 
for  both  periods.  A  lower  SCO  share  in  2021-2027  than  in  2014-2020  is  considered 
inconsistent, possibly due to the difficulties of accurately estimating coverage at the end 
of the programming period.  

For these Member States it is unrealistic to expect less coverage in 2021-2027, so the 
share of SCO coverage in 2014-2020 was attributed to the 2021-2027 period. EU-level 
coverage is the result of this additional check (further details are provided in the following 
chapter). Member States where the 2021-2027 coverage was recalculated are indicated 
throughout the report (highlighted in blue in the relevant tables). 

24 

 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

1.4.  Analysis 

Data  was  verified  and  inconsistent  records  removed  or  corrected  and  the  resultant 
database forms the basis for the analyses.  

1.4.1.  Programme budget covered by SCO/FNLC 

As previously emphasised, the data for each scheme was thoroughly checked. The first 
step  in  the  analysis  of  programme  budget  covered  by  SCO/FNLC  is  to  sum  the 
amounts covered at Fund level. 

For  simplicity,  the  formulas  are  based  on  beneficiary  expenditure  planned  to  be 
reimbursed by the end of 2021-2027. The approach is consistent with estimating SCO 
use in 2014-2020, SCO/FNLC use at the upper level and analysis of amounts already 
reimbursed. 

𝐸𝑈𝑅 𝑆𝑢𝑚 𝑜𝑓 𝑡ℎ𝑒 𝑏𝑢𝑑𝑔𝑒𝑡 𝑝𝑙𝑎𝑛𝑛𝑒𝑑 𝑡𝑜 𝑏𝑒 𝑐𝑜𝑣𝑒𝑟𝑒𝑑 𝑏𝑦 𝑆𝐶𝑂 𝑎𝑡 𝑙𝑜𝑤𝑒𝑟 𝑙𝑒𝑣𝑒𝑙 = ∑ 𝑎𝑖

𝑖=1

𝑛

Where:  

n is the total number of schemes that passed the quality check at Fund level; 

ai is the amount planned to be covered by an SCO for the i-th scheme. 

The second step involves comparing the amount quantified in the first step with 
the total fund budget for programmes that provided consistent data and which passed 
the  quality  check.  From  this  comparison,  we  derive  the  budget  share  covered  by  the 
SCO/FNLC schemes. 

% 𝑜𝑓 𝑏𝑢𝑑𝑔𝑒𝑡 𝑐𝑜𝑣𝑒𝑟𝑒𝑑 𝑏𝑦 𝑆𝐶𝑂

=

𝑆𝑢𝑚 𝑜𝑓 𝑡ℎ𝑒 𝑏𝑢𝑑𝑔𝑒𝑡 𝑝𝑙𝑎𝑛𝑛𝑒𝑑 𝑡𝑜 𝑏𝑒 𝑐𝑜𝑣𝑒𝑟𝑒𝑑 𝑏𝑦 𝑆𝐶𝑂 𝑎𝑡 𝑙𝑜𝑤𝑒𝑟 𝑙𝑒𝑣𝑒𝑙
𝑇𝑜𝑡𝑎𝑙 𝑏𝑢𝑑𝑔𝑒𝑡 𝑜𝑓 𝑡ℎ𝑒 𝑝𝑟𝑜𝑔𝑟𝑎𝑚𝑚𝑒𝑠 𝑡ℎ𝑎𝑡 𝑝𝑎𝑠𝑠𝑒𝑑 𝑡ℎ𝑒 𝑞𝑢𝑎𝑙𝑖𝑡𝑦 𝑐ℎ𝑒𝑐𝑘

Where: 

‘Sum  of  the  budget  planned  to  be  covered  by  an  SCO  at  lower  level’  only  covers 
information provided by programmes that passed the quality check. 

‘Total  budget  of  programmes’  refers  to  the  budget  allocated  to  the  fund,  only  for 
programmes whose data passed the quality check. 

Box 1 - Calculation under step 2 for ERDF, CF, ESF/ESF+ and EMFF/EMFAF 

As mentioned in the previous chapter, for ERDF, CF, ESF/ESF+and EMFF/EMFAF 
funds,  an  additional  step  checked  the  consistency  of  SCO  coverage  in  2021-2027 
compared to the previous period. This reviews the percentages calculated in Step 2 
for the two programming periods, discarding the 2021-2027 value if it is lower than the 
2014-2020 value. 

25 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

%𝒗𝒂𝒍𝒊𝒅 =   {

%𝟐𝟎𝟏𝟒−𝟐𝟎𝟐𝟎 𝒊𝒇  %𝟐𝟎𝟐𝟏−𝟐𝟎𝟐𝟕 < %𝟐𝟎𝟏𝟒−𝟐𝟎𝟐𝟎
𝒐𝒕𝒉𝒆𝒓𝒘𝒊𝒔𝒆 %𝟐𝟎𝟐𝟏−𝟐𝟎𝟐𝟕

The percentage of SCO coverage at EU level for 2021-2027 is calculated using this 
approach. It is derived using data from 2021-2027 for some Member States and from 
2014-2020 for Member States where the 2021-2027 share is lower than in 2014-2020. 

The third step is to estimate, in absolute terms, the budget potentially covered by 
SCO/FNLC  at  EU  level  (i.e.,  the  SCO/FNLC  coverage  of  all  programme  budgets)  by 
applying the share calculated in step 2 for the Fund budget at EU level. 

1.4.2.  Type of SCO/FNLC 

This  section  details  the  methodology  used  to  analyse  responses  on  the  types  of 
SCO/FNLC.  

The  first  step  involves  summing  the  amounts  covered  by  a  particular  type  of 
SCO/FNLC at programme and Fund level (in this example, unit costs). 

𝑆𝑢𝑚 𝑜𝑓 𝑢𝑛𝑖𝑡 𝑐𝑜𝑠𝑡𝑠 𝑢𝑠𝑒𝑑 𝑎𝑡 𝑙𝑜𝑤𝑒𝑟 𝑙𝑒𝑣𝑒𝑙 = ∑ 𝑈𝐶𝑖

𝑖=1

𝑚

Where:  

m is the number of schemes that passed the fund level quality check and use unit costs. 

ui is the unit cost for the i-th scheme in the fund. 

The second  step  quantifies  the  amount covered by the type  of  SCO  per the  previous 
paragraph.  The  only  difference  is  that  the  amount  refers  to  the  type  of  SCO  (in  this 
example, unit cost). 

𝐸𝑈𝑅 𝑆𝑢𝑚 𝑜𝑓 𝑡ℎ𝑒 𝑏𝑢𝑑𝑔𝑒𝑡 𝑝𝑙𝑎𝑛𝑛𝑒𝑑 𝑡𝑜 𝑏𝑒 𝑐𝑜𝑣𝑒𝑟𝑒𝑑 𝑏𝑦 𝑢𝑛𝑖𝑡 𝑐𝑜𝑠𝑡 𝑎𝑡 𝑙𝑜𝑤𝑒𝑟 𝑙𝑒𝑣𝑒𝑙

𝑚

= ∑ 𝑈𝐶𝑒𝑢𝑟𝑖
𝑖=1

Where:  

m is the number of schemes that passed the fund level quality check and use unit costs. 

UCeuri denotes the amount planned to be covered by unit costs for the i-th scheme. 

1.4.3. 

Type of policy area, cost and beneficiary 

Under the questionnaire structure, each SCO/FNLC scheme can cover multiple policy 
areas, beneficiaries and costs. Quantifying the coverage of these variables aligns with 
the multifaceted approach and involves calculating the percentage of SCOs that cover a 

26 

 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

specific  policy  area,  beneficiary,  or  cost  compared  to  the  total  number  of  SCOs  that 
passed the quality checks outlined in the previous chapter. 

This percentage may exceed 100% since a single scheme can be associated with more 
than one policy area, beneficiary, or cost. 

1.4.4. 

Questions to gather stakeholder perceptions 

Under the questionnaire for programme authorities, each respondent was asked to share 
their perceptions of advantages and issues related to the use of SCO and FNLC, as well 
as the extent they interacted with the audit authority on these simplification measures. 

To fully use data from responses to qualitative questions based on Likert scales, it was 
decided to use  all  the completed  questionnaires.  So,  responses that  did not  pass the 
quantitative data quality checks were still used in the analysis of programme authorities' 
perceptions. 

A similar approach was used for the beneficiaries, where all  responses were used for 
the analysis. 

2. 

The response rate 

2.1.  Response to the questionnaire addressed to the 

programme authorities 

This chapter details the web survey response rate, emphasising variations across funds 
and programming periods. 

The analysis is based on two criteria: 

The  number  of  programmes  participating  in  the  survey  (programme 
authorities  completing  the  questionnaire)  relative  to  the  total  number  of 
programmes funded, by fund and by programming period; 

The  proportion  of  EU  and  national  co-financing  budget  for  participating 
programmes compared to the  total budget allocated, also broken down by 
fund and programming period. 

The  tables  below  show  all  the  responses  at  fund  level  before  cleaning  the  data.  For 
EMPL  and  REGIO  Funds,  to  accurately  depict  the  response  rate  at  fund  level,  each 
response from a multifund programme counts separately for each fund. For example, a 
response from an ERDF/ESF programme is counted once in the ERDF row and once in 
the  ESF  row.  Consistently,  ‘Total  OPs’,  which  are  the  denominators  for  the  response 
rate, are the number of programmes at EU level financed by a specific fund.  

27 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Table 3 – Responses from both programming periods 

Complete 
questionnaires 

Total OPs 

Response rate 
(Total OPs) 

Response rate 
(Budget 
coverage) 

41 

359 

26 

206 

25 

34 

22 

19 

16 

47 

574 

46 

357 

53 

115 

26 

26 

26 

87% 

63% 

57% 

58% 

47% 

30% 

85% 

73% 

62% 

97% 

71% 

59% 

66% 

41% 

56% 

87% 

73% 

54% 

Table 4 – Responses from 2014-2020 programmes 

Complete 
questionnaires 

Total OPs 

Response rate 
(Total OPs) 

Response rate 
(Budget 
coverage) 

22 

174 

107 

13 

34 

24 

290 

188 

27 

115 

92% 

60% 

57% 

48% 

30% 

98% 

67% 

63% 

33% 

56% 

Fund 

CF 

ERDF 

JTF 

ESF/ESF+ 

EMFF/EMFAF 

EAFRD 

AMIF 

BMVI 

ISF 

Source: survey  

Fund 

CF 

ERDF 

ESF 

EMFF 

EAFRD 

Source: Survey 

28 

 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Table 5 – Responses from 2021-2027 programmes 

Complete 
questionnaires 

Total OPs 

Response rate 
(Total OPs) 

Response rate 
(Budget 
coverage) 

19 

185 

26 

99 

12 

22 

19 

16 

23 

284 

46 

169 

26 

26 

26 

26 

83% 

65% 

57% 

59% 

46% 

85% 

73% 

62% 

95% 

75% 

59% 

68% 

49% 

87% 

73% 

54% 

Fund 

CF 

ERDF 

JTF 

ESF+ 

EMFAF 

AMIF 

BMVI 

ISF 

Source: Survey 

The table below presents the response rate at Member State and fund level highlighting 
the  impact  of  data  cleaning.  Multi-fund  programmes  are  counted  separately  for  each 
fund.    

29 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs (FNLC) for the Common Provisions Regulation (CPR) Funds in the 
2014-2020 and 2021-2027 programming periods 

Table 6 – Response rate by Member State for REGIO Funds 

CF 

ERDF 

JTF 

l

e
t
e
p
m
o
C

0 
0 
2 
2 
5 
0 
0 
2 
4 
0 
0 
0 
2 
5 
0 
0 
2 
0 
1 
2 
0 
3 
3 
3 
0 
2 
3 
0 
0 

.
r
g
o
r
p
.
o
N

0 
0 
4 
2 
6 
0 
0 
2 
5 
0 
0 
0 
2 
6 
0 
0 
2 
0 
2 
2 
0 
3 
3 
3 
0 
2 
3 
0 
0 

/ 

/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 

MS 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
TC 

Source: Survey 

l

l

a
u
q

a
u
q

K
O
y
t
i
l

K
O
y
t
i
l

e
t
e
p
m
o
c

e
t
e
p
m
o
c

t
e
g
d
u
B
R
R

t
e
g
d
u
B
R
R

- 
- 
43% 

.
r
g
o
r
p
.
o
N
R
R
- 
- 
50% 

.
r
g
o
r
p
.
o
N
R
R
- 
- 
- 
- 
50% 
43% 
100%  100%  100%  100% 
99% 
83% 
- 
- 
- 
- 
60% 
99% 
- 
- 
- 

100%  100% 
99% 
80% 
- 
- 
- 
- 
- 
- 

83% 
- 
- 
50% 
80% 
- 
- 
- 

99% 
- 
- 

100%  100%  100%  100% 
97% 
83% 
- 
- 
- 
- 

83% 
- 
- 

97% 
- 
- 

100%  100%  100%  100% 

- 
- 
50% 
56% 
100%  100%  100%  100% 

- 
50% 

- 
56% 

- 

- 

- 

- 

100%  100%  100%  100% 
100%  100%  100%  100% 
100%  100%  100%  100% 

- 

- 

- 

- 

100%  100%  100%  100% 
100%  100%  100%  100% 

- 
- 

- 
- 

- 
- 

- 
- 

a
u
q

K
O
y
t
i
l

.
r
g
o
r
p
.
o
N
R
R
50% 
100% 
0% 
100% 
100% 
0% 
100% 
0% 
0% 
0% 
100% 
43% 
0% 
50% 
100% 
0% 
100% 
50% 
0% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
- 
- 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

42% 
100% 
0% 
100% 
100% 
0% 
100% 
0% 
0% 
0% 
100% 
50% 
0% 
4% 
100% 
0% 
100% 
40% 
0% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
- 
- 

l

e
t
e
p
m
o
C

2 
5 
9 
2 
11 
14 
2 
2 
18 
32 
4 
23 
3 
12 
4 
31 
2 
0 
2 
3 
5 
36 
17 
15 
19 
2 
5 
0 
79 

.
r
g
o
r
p
.
o
N

2 
6 
12 
2 
12 
33 
2 
2 
36 
41 
5 
53 
3 
13 
4 
59 
2 
2 
2 
3 
8 
41 
18 
18 
19 
2 
6 
6 
162 

/ 

/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 

l

e
t
e
p
m
o
c

.
r
g
o
r
p
.
o
N
R
R
100% 
83% 
75% 
100% 
92% 
42% 
100% 
100% 
50% 
78% 
80% 
43% 
100% 
92% 
100% 
53% 
100% 
0% 
100% 
100% 
63% 
88% 
94% 
83% 
100% 
100% 
83% 
0% 
49% 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

100% 
93% 
87% 
100% 
79% 
43% 
100% 
100% 
77% 
39% 
100% 
53% 
100% 
99% 
100% 
54% 
100% 
0% 
100% 
100% 
54% 
95% 
96% 
80% 
100% 
100% 
88% 
0% 
50% 

a
u
q

K
O
y
t
i
l

.
r
g
o
r
p
.
o
N
R
R
50% 
83% 
75% 
100% 
50% 
30% 
100% 
50% 
31% 
56% 
60% 
36% 
100% 
77% 
50% 
49% 
100% 
0% 
50% 
100% 
63% 
76% 
83% 
50% 
95% 
100% 
67% 
0% 
46% 

l

e
t
e
p
m
o
c

.
r
g
o
r
p
.
o
N
R
R
100% 
100% 
0% 
100% 
100% 
20% 
100% 
0% 
0% 
0% 
100% 
43% 
100% 
50% 
100% 
0% 
100% 
50% 
0% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
- 
- 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

100% 
100% 
0% 
100% 
100% 
28% 
100% 
0% 
0% 
0% 
100% 
50% 
100% 
4% 
100% 
0% 
100% 
40% 
0% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
- 
- 

l

e
t
e
p
m
o
C

2 
1 
0 
1 
1 
1 
1 
0 
0 
0 
1 
3 
1 
1 
1 
0 
1 
1 
0 
1 
1 
5 
0 
1 
1 
0 
1 
0 
0 

.
r
g
o
r
p
.
o
N

2 
1 
1 
1 
1 
5 
1 
1 
1 
1 
1 
7 
1 
2 
1 
1 
1 
2 
1 
1 
1 
5 
3 
1 
1 
1 
1 
0 
0 

/ 

/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 
/ 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

61% 
93% 
87% 
100% 
55% 
27% 
100% 
49% 
61% 
35% 
99% 
44% 
100% 
83% 
70% 
52% 
100% 
0% 
51% 
100% 
54% 
78% 
90% 
47% 
100% 
100% 
87% 
0% 
48% 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs (FNLC) for the Common Provisions Regulation (CPR) Funds in the 
2014-2020 and 2021-2027 programming periods 

Table 7 – Response rate by Member State for ESF/ESF+, EMFF/EMFAF and EAFRD 

ESF/ESF+ 

EMFF/EMFAF 

EAFRD 

l

e
t
e
p
m
o
C

2 
4 
6 
2 
5 
5 
2 
2 
16 
36 
3 
26 
2 
10 
2 
11 
2 
2 
2 
2 
2 
30 
19 
5 
3 
2 
3 
0 

/ 

.
r
g
o
r
p
.
o
N

/  3 
/  9 
/  6 
/  2 
/  5 
/  35 
/  2 
/  2 
/  34 
/  46 
/  4 
/  52 
/  2 
/  10 
/  2 
/  56 
/  3 
/  2 
/  3 
/  2 
/  2 
/  35 
/  19 
/  6 
/  3 
/  3 
/  3 
/  6 

.
r
g
o
r
p
.
o
N
R
R

l

e
t
e
p
m
o
c

67% 
44% 
100% 
100% 
100% 
14% 
100% 
100% 
47% 
78% 
75% 
50% 
100% 
100% 
100% 
20% 
67% 
100% 
67% 
100% 
100% 
86% 
100% 
83% 
100% 
67% 
100% 
0% 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

99% 
94% 
100% 
100% 
100% 
29% 
100% 
100% 
29% 
78% 
100% 
81% 
100% 
100% 
100% 
23% 
97% 
100% 
98% 
100% 
100% 
90% 
100% 
67% 
100% 
98% 
100% 
0% 

.
r
g
o
r
p
.
o
N
R
R

K
O
y
t
i
l

a
u
q

33% 
33% 
67% 
100% 
100% 
11% 
100% 
50% 
32% 
63% 
75% 
29% 
100% 
90% 
0% 
14% 
67% 
50% 
67% 
100% 
100% 
51% 
79% 
33% 
67% 
67% 
67% 
0% 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

48% 
72% 
70% 
100% 
100% 
10% 
100% 
48% 
15% 
36% 
100% 
44% 
100% 
94% 
0% 
12% 
97% 
76% 
98% 
100% 
100% 
51% 
80% 
35% 
100% 
98% 
94% 
0% 

l

e
t
e
p
m
o
C

2 
0 
1 
1 
2 
2 
2 
0 
2 
1 
2 
0 
0 
0 
0 
0 
0 
0 
0 
2 
0 
2 
0 
2 
1 
1 
2 
0 

/ 

.
r
g
o
r
p
.
o
N

/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  0 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  2 
/  1 

.
r
g
o
r
p
.
o
N
R
R

l

e
t
e
p
m
o
c

100% 
0% 
50% 
50% 
100% 
100% 
100% 
0% 
100% 
50% 
100% 
0% 
0% 
0% 
0% 
0% 
0% 
- 
0% 
100% 
0% 
100% 
0% 
100% 
50% 
50% 
100% 
0% 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

100% 
0% 
46% 
49% 
100% 
100% 
100% 
0% 
100% 
53% 
100% 
0% 
0% 
0% 
0% 
0% 
0% 
- 
0% 
100% 
0% 
100% 
0% 
100% 
41% 
54% 
100% 
0% 

.
r
g
o
r
p
.
o
N
R
R

K
O
y
t
i
l

a
u
q

50% 
0% 
50% 
50% 
100% 
100% 
0% 
0% 
100% 
50% 
100% 
0% 
0% 
0% 
0% 
0% 
0% 
- 
0% 
100% 
0% 
100% 
0% 
100% 
0% 
50% 
100% 
0% 

MS 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 

Source: Survey 

l

e
t
e
p
m
o
C

1 
1 
1 
0 
1 
10 
0 
0 
1 
1 
2 
0 
0 
1 
0 
4 
1 
0 
1 
1 
1 
1 
3 
1 
0 
1 
1 
0 

/ 

.
r
g
o
r
p
.
o
N

/  1 
/  2 
/  1 
/  1 
/  1 
/  14 
/  1 
/  1 
/  1 
/  18 
/  2 
/  29 
/  1 
/  1 
/  1 
/  23 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  3 
/  1 
/  1 
/  1 
/  1 
/  4 

.
r
g
o
r
p
.
o
N
R
R

l

e
t
e
p
m
o
c

100% 
50% 
100% 
0% 
100% 
71% 
0% 
0% 
100% 
6% 
100% 
0% 
0% 
100% 
0% 
17% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

100% 
49% 
100% 
0% 
100% 
79% 
0% 
0% 
100% 
2% 
100% 
0% 
0% 
100% 
0% 
23% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 

.
r
g
o
r
p
.
o
N
R
R

K
O
y
t
i
l

a
u
q

100% 
50% 
100% 
0% 
100% 
71% 
0% 
0% 
100% 
6% 
100% 
0% 
0% 
100% 
0% 
13% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

100% 
49% 
100% 
0% 
100% 
79% 
0% 
0% 
100% 
2% 
100% 
0% 
0% 
100% 
0% 
17% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

52% 
0% 
46% 
49% 
100% 
100% 
0% 
0% 
100% 
53% 
100% 
0% 
0% 
0% 
0% 
0% 
0% 
- 
0% 
100% 
0% 
100% 
0% 
100% 
0% 
54% 
100% 
0% 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs (FNLC) for the Common Provisions Regulation (CPR) Funds in the 
2014-2020 and 2021-2027 programming periods 

Table 8 – Response rate by Member State for HOME Funds 

l

e
t
e
p
m
o
C

1 
0 
1 
1 
1 
1 
0 
1 
1 
0 
1 
1 
0 
1 
1 
1 
1 
1 
0 
1 
1 
1 
1 
1 
1 
1 
1 

/ 

.
r
g
o
r
p
.
o
N

/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  0 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 

.
r
g
o
r
p
.
o
N
R
R

l

e
t
e
p
m
o
c

100% 
0% 
100% 
100% 
100% 
100% 
- 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

AMIF 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

100% 
0% 
100% 
100% 
100% 
100% 
- 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

.
r
g
o
r
p
.
o
N
R
R

K
O
y
t
i
l

a
u
q

100% 
0% 
100% 
100% 
100% 
0% 
- 
100% 
100% 
0% 
0% 
100% 
0% 
100% 
0% 
100% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

100% 
0% 
100% 
100% 
100% 
0% 
- 
100% 
100% 
0% 
0% 
100% 
0% 
100% 
0% 
100% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
100% 
100% 
0% 
100% 

l

e
t
e
p
m
o
C

1 
0 
1 
1 
1 
1 
0 
1 
1 
0 
1 
1 
1 
1 
0 
0 
1 
1 
0 
1 
1 
1 
0 
1 
0 
1 
1 

/ 

.
r
g
o
r
p
.
o
N

/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  0 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 

.
r
g
o
r
p
.
o
N
R
R

l

e
t
e
p
m
o
c

100% 
0% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
- 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

BMVI 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

100% 
0% 
100% 
100% 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
100% 
- 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

.
r
g
o
r
p
.
o
N
R
R

K
O
y
t
i
l

a
u
q

100% 
0% 
0% 
100% 
100% 
0% 
0% 
100% 
0% 
0% 
0% 
100% 
100% 
100% 
- 
0% 
100% 
0% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

MS 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Source: Survey 

l

e
t
e
p
m
o
C

0 
0 
1 
1 
1 
0 
0 
1 
1 
0 
1 
1 
0 
1 
0 
0 
1 
1 
0 
1 
1 
1 
0 
1 
0 
1 
1 

/ 

.
r
g
o
r
p
.
o
N

/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  0 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 
/  1 

.
r
g
o
r
p
.
o
N
R
R

l

e
t
e
p
m
o
c

0% 
0% 
100% 
100% 
100% 
0% 
- 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
0% 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

ISF 

t
e
g
d
u
B
R
R

l

e
t
e
p
m
o
c

0% 
0% 
100% 
100% 
100% 
0% 
- 
100% 
100% 
0% 
100% 
100% 
0% 
100% 
0% 
0% 
100% 
100% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

.
r
g
o
r
p
.
o
N
R
R

K
O
y
t
i
l

a
u
q

0% 
0% 
100% 
100% 
100% 
0% 
- 
100% 
0% 
0% 
0% 
100% 
0% 
100% 
0% 
0% 
100% 
0% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

0% 
0% 
100% 
100% 
100% 
0% 
- 
100% 
0% 
0% 
0% 
100% 
0% 
100% 
0% 
0% 
100% 
0% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

t
e
g
d
u
B
R
R

K
O
y
t
i
l

a
u
q

100% 
0% 
0% 
100% 
100% 
0% 
0% 
100% 
0% 
0% 
0% 
100% 
100% 
100% 
- 
0% 
100% 
0% 
0% 
100% 
100% 
100% 
0% 
100% 
0% 
100% 
100% 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

2.2. 

Responses to questionnaire for beneficiaries 

The survey  was  distributed to  beneficiaries  with  the  support  of  programme authorities 
who participated in the initial survey. Each authority was recontacted and asked to share 
a web survey link with their beneficiaries. The Table 9 below shows the responses at 
Funds/policy domain level, by Member State. 

In total, 1 775 completed questionnaires were collected from 26 Member States (with no 
responses from beneficiaries in Cyprus or Ireland). Details on the types of respondents 
for each fund are provided in the fund-specific sections. 

Table 9 – Responses to questionnaire for beneficiaries 

g
e
r
r
e
t
n
I
/

F
T
J
/

/

F
D
R
E
F
C
22 
25 
33 
0 
28 
111 
2 
3 
21 
18 
90 
8 
126 
25 
0 
88 
9 
1 
12 
1 
4 
81 
14 
5 
53 
18 
20 
0 

MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 

TOTAL  818 

+
F
S
E
F
S
E

/

0 
21 
181 
0 
4 
33 
0 
1 
1 
55 
34 
3 
38 
1 
0 
48 
0 
4 
1 
1 
10 
205 
6 
0 
49 
3 
0 
0 
699 

F
A
F
M
E
F
F
M
E

/

0 
0 
0 
0 
0 
1 
0 
0 
0 
104 
0 
3 
0 
0 
0 
1 
0 
0 
0 
3 
0 
1 
1 
0 
0 
0 
0 
0 
114 

D
R
F
A
E

0 
1 
3 
0 
0 
3 
0 
0 
0 
33 
1 
1 
3 
0 
0 
0 
0 
0 
8 
4 
0 
4 
0 
0 
0 
1 
0 
1 
63 

F
S

I
/
I

/

V
M
B
F
M
A

I

0 
2 
0 
0 
1 
47 
0 
0 
0 
0 
9 
8 
1 
0 
0 
0 
10 
0 
0 
3 
0 
0 
0 
0 
0 
0 
0 
0 
81 

33 

 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Source: survey 

3. 

DG AGRI Fund – EAFRD 

3.1.  SCO use in 2014-2020 

The  table  below  displays  data  regarding  SCO  use  under  EAFRD  in  2014-2020  as 
percentages and totals. The percentage is the SCO share of the budgets of programmes 
that participated in the survey. For more detail, refer to the first and second steps of the 
process  outlined in  Chapter  1.4.  The  amounts  in the  last  column  are  estimates  of the 
potential budget covered at EU level including both EU and national co-financing. This 
is  determined  by  applying  the  programme  budget  share  of  the  entire  EAFRD  budget 
(including co-financing) at EU level (for more detail, refer to the third step of the process 
outlined in Chapter 1.4). 

It is important to highlight that all figures in this chapter exclusively concern the use of 
SCOs  under  non-IACS measures.  In  other  words,  surface-based  unit  costs  and  other 
forms  of  unit cost reimbursement  applied  within EAFRD  IACS measures  are  explicitly 
excluded from the scope of this study. 

Table 10 – EAFRD SCO use in 2014-2020 

(1) % of OP budget 
covered 

(2) Estimated OP budget 
covered at EU level 
(EUR bn)  

SCOs 

4.6% 

9.180 

SCO use of 4.6% in the respondent EAFRD programmes would cover over EUR 9 billion 
if applied to the total EAFRD budget. 

The table below shows the percentage of EAFRD budget covered by SCO schemes at 
Member State level. 

Table 11 – EAFRD SCO use in 2014-2020 by Member State 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

SCOs 

0.05% 

7.54% 

0.29% 

No reply 

0.01% 

1.50% 

No reply 

No reply 

14.37% 

23.37% 

2.00% 

34 

 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Member State 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

SCOs 

No reply 

No reply 

7.35% 

No reply 

1.64% 

1.34% 

No reply 

5.08% 

3.16% 

1.82% 

14.06% 

3.37% 

0.08% 

No reply 

2.20% 

0.29% 

No reply 

As  presented  in  the  table  above,  at  the  end  of  the  2014-2020  period,  three  Member 
States covered more than 10% of their EAFRD budget using SCOs: Greece, Spain and 
Poland. On the other hand, five Member States used less than 1%: Austria, Bulgaria, 
Czechia, Romania and Slovakia. 

3.1.1. 

Types of SCO used in 2014-2020 

The table below illustrates the use of flat rate, unit cost and lump sum SCOs as the share 
of programme budget covered by each type per Member State. 

Table 12 – EAFRD Type of SCO at lower level in 2014-2020 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Lower level 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

0.02% 

3.38% 

0.29% 

No reply 

0.01% 

0.72% 

No reply 

No reply 

14.37% 

22.17% 

0.00% 

No reply 

No reply 

4.74% 

0.03% 

0.00% 

0.00% 

No reply 

0.00% 

0.15% 

No reply 

No reply 

0.00% 

0.63% 

1.93% 

No reply 

No reply 

0.00% 

0.00% 

4.16% 

0.00% 

No reply 

0.00% 

0.63% 

No reply 

No reply 

0.00% 

0.57% 

0.06% 

No reply 

No reply 

2.62% 

35 

 
 
 
 
 
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programming periods 

Member State 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

TOTAL* 

Flat Rate 

No reply 

1.63% 

1.06% 

No reply 

4.90% 

0.00% 

0.79% 

0.22% 

2.31% 

0.08% 

No reply 

1.93% 

0.16% 

No reply 

0.3% 

Lower level 

Budget covered (%) 

Unit Cost 

No reply 

0.01% 

0.28% 

No reply 

0.15% 

0.00% 

1.03% 

0.76% 

0.12% 

0.00% 

No reply 

0.24% 

0.12% 

No reply 

1.8% 

Lump Sum 

No reply 

0.00% 

0.00% 

No reply 

0.03% 

3.16% 

0.00% 

13.08% 

0.94% 

0.00% 

No reply 

0.03% 

0.01% 

No reply 

2.5% 

*Coverage of budget at EU level for each type of SCO. 

For most Member States, flat rate SCOs cover the most budget. However, at EU level 
(last row of the table), lump sum SCOs cover the most, 2.5%, followed by unit costs. 

3.1.2. 

EAFRD measures covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs by EAFRD measure calculated from the 
number  of  SCOs  identified  for  each  measure  in  the  EAFRD  survey.  The  total  is  over 
100% because each SCO can cover multiple measures. 

Table 13 – SCO coverage of EAFRD measures 

EAFRD measure 

Measure 1: Knowledge transfer and information 

Measure 2: Advisory services, farm management and relief services 

Measure 3: Quality schemes for agriproducts and foodstuffs 

Measure 4: Investments in physical assets 

Measure 5: Natural disasters: restoring production potential and preventing damage 

Measure 6: Farm and business development 

Measure 7: Basic services and village renewal in rural areas 

Measure 8: Investments in forest area development and improvement of the viability  
Measure 9: Setting up of producer groups and organisations 
Measure 10: Agri-environment-climate 

Measure 11: Organic farming 

Measure 12: Natura 2000 and Water Framework Directive payments 

Measure 13: Payments to areas facing natural or other specific constraints 

Measure 14: Animal welfare 

% of 
SCOs  
36% 

2% 

3% 

34% 

11% 

5% 

8% 

18% 

0% 

4% 

0% 

0% 

0% 

0% 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Measure 15: Forest-environmental and climate services and forest conservation 

EAFRD measure 

Measure 16: Cooperation 

Measure 17: Risk management 

Measure 18: Complementary direct payments for Croatia 

Measure 19: Support for LEADER local development (CLLD) 

Measure 20: Technical assistance 

% of 
SCOs  
6% 

31% 

0% 

0% 

38% 

4% 

Almost 40% of the SCOs were used with EAFRD technical assistance (measure 19) as 
well as knowledge transfer and information actions (measure 1). Furthermore, 34% were 
used  for  investments  in  physical  assets  through  measure  4  and  31%  for  cooperation 
through measure 16.  

3.1.3. 

Beneficiaries covered by SCOs in 2014-2020 

The  table  below  illustrates  the  distribution  by  type  of  beneficiary  based  on  SCOs 
identified in the EAFRD survey. The total is more than 100% because each SCO can 
cover multiple beneficiaries. 

Table 14 – Beneficiaries reimbursed through SCOs for EAFRD operations 

Type of beneficiary 

% of SCOs  

Agrifood/ agricultural SMEs 

Agrifood/ agricultural micro-enterprises 

Training organisations 

Municipalities 

Research centres 

Agrifood/ agricultural large enterprises 

Regional authorities 

45% 

42% 

24% 

20% 

19% 

18% 

3% 

Many  EAFRD  SCO  (45%)  covered  operations  implemented  by  agrifood/  agricultural 
SMEs. Other major beneficiaries were agrifood/ agricultural micro-enterprises (42%), as 
well as municipalities (20%). Only 3% of the SCOs reimbursed regional authorities. 

3.1.4. 

Types of costs covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs across types of costs calculated from 
SCOs identified in the EAFRD survey for each type of cost. The total is more than 100% 
because each SCO can cover multiple costs. 

Table 15 – Types of costs covered by SCOs 

Type of costs 

Direct costs 

All costs of the operation 

Indirect costs 
All direct costs other than staff 

% of SCOs  

57% 

34% 

17% 
2% 

The  majority  of  EAFRD  SCO  schemes  (57%)  covered  direct  costs  of  the  operations, 
while around a third (34%) covered all the costs. Only 17% covered indirect costs. 

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programming periods 

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Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

3.2.  EAFRD stakeholder perceptions of SCO 

3.2.1. 

Advantages, challenges and reasons for not using SCO 

This section presents qualitative responses regarding the advantages of SCO schemes 
as  well  as  issues  encountered  when  developing  them.  It  also  includes feedback from 
respondents who did not use SCO. 

Figure 7 - Advantages of SCO schemes for EAFRD programme authorities in 
2014-2020 (values in %) 

LESS ADMINISTRATIVE BURDEN

3

24

74

SIMPLER COMPLIANCE

9

26

65

LOWER ERROR RATE

3

18

47

32

EASY TO APPLY FOR
BENEFICIARIES

12

29

59

FOCUS ON OTHER ACTIVITIES

15

47

21

18

MORE FOCUS ON RESULTS

15

21

39

24

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

The  greatest  advantage  of  SCO  schemes  for  EAFRD  programmes  is  the  reduced 
administrative  burden  (highly  relevant  for  74%  of  respondents),  followed  by  simpler 
compliance checks and an easier application process for beneficiaries. 

The survey also aimed at mapping issues encountered by programme authorities when 
developing the SCO schemes, as presented in the figure below. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 8 - Challenges faced in developing SCO schemes for EAFRD programme 
authorities in 2014-2020 (values in %) 

LEGAL UNCERTAINTY

21

44

18

18

LACK OF KNOWLEDGE

24

53

21

3

LACK OF RESOURCES

18

41

24

18

LACK OF HISTORICAL DATA

26

24

35

15

NO ALTERNATIVE SOURCES

15

29

32

24

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

For EAFRD programme authorities, the difficulties of finding alternative data sources as 
well as the limited availability of historical data are the most relevant hindrances when 
developing these schemes.  

The main reasons for programme authorities to not use any SCO schemes were the lack 
of information as well as the potential burden. 

3.2.2. 

Perception of beneficiaries 

The survey of EAFRD beneficiaries was conducted in July and August 2024 and resulted 
in 63 complete replies. The figure below shows the types of beneficiaries responding to 
the survey. 

Figure 9 – Types of EAFRD beneficiaries responding to the survey 

ENTERPRISE

NATURAL PERSON

44%

27%

RESEARCH/EDUCATIONAL INSTITUTION

14%

OTHER

PUBLIC INSTITUTION/ADMINISTRATION

TRADE UNION/NGO/ASSOCIATION

8%

8%

6%

COC/BUSINESS SUPPORT ENTITIES

0%

Almost  half  the  respondents  were  enterprises  and  many  were  natural  persons  or 
research/education institutions. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

The factsheet  below  highlights  that  almost  half the  respondents (48%)  were  aware  of 
SCOs (no responses were received regarding FNLC). Of those, 70% used SCOs, while 
47% received training, workshops, or guidelines from the managing authority. 

Almost all the EAFRD beneficiaries who completed the survey and used  SCOs declared 
they  benefitted  project management  (86%).  For  them,  less  administrative burden  was 
the  main  benefit  (27%),  which  matches  programme  authority  inputs  presented  in  the 
previous sections. In addition, 11% of the beneficiaries agreed that SCOs enabled them 
to focus more on the quality and results of their project. 

Figure 10 - Data collected through the survey concerning EAFRD beneficiaries 

The  analysis  of  responses 
learnt  and 
recommendations  to  encourage  the  wider  adoption  of  SCOs  does  not  provide  many 
insights. Only two specific recommendations were made: 

to  open-ended  questions  on 

lessons 

•  One respondent emphasised the importance of regularly updating SCOs to avoid 

misalignment with inflationary trends. 

•  Another  suggested  extending  the  Interreg  practice  to the  LEADER  framework, 
allowing  personnel  costs  to  be  covered  through  SCOs  without  requiring 
timesheets. Instead, at the start of the project, an assignment letter would specify 
the percentage of work time allocated to the project by the individual expert. 

The final section of the survey invited beneficiaries to share their perspectives on barriers 
and obstacles limiting access to CPR Funds. The responses from EAFRD beneficiaries 
highlighted two issues: the administrative burden associated with project management 
and the length and complexity of the project selection process. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

4. 

DG EMPL Funds – ESF/ESF+ 

4.1.  Key findings 

The table below summarises the uptake of simplification measures covered by this study 
across two programming periods. 

The first column shows the use of simplification measures at both lower and upper levels 
during the 2014–2020 period. The second column presents the coverage of simplification 
measures  mapped  by  this  study  for  the  2021–2027  programming  period,  combining 
schemes ‘in use’ and ‘programmed.’ 

For both programming periods and at both levels, the table shows uptake as a share of 
the  ESF/ESF+  budget.  Additionally,  it  shows  uptake  from  the  ESF/ESF+  budget 
excluding financial instruments, for which SCOs and FNLC are not applicable. 

Table 16 – Simplification measure use in ESF/ESF+  

2014-2020 

2021-2027 

SCO 

SCO + FNLC 

Coverage 
at lower 
level 

Coverage 
at upper 
level 

Total budget 

31.5% 

49.8% 

Total budget 
excluding financial 
instruments 

31.8% 

50.0% 

Total budget 

6.5% 

24.9% 

Total budget 
excluding financial 
instruments 

6.6% 

25.0% 

4.2. 

Use of SCOs in 2014-2020 

The first two rows in the table below present lower level use of SCOs in 2014-2020. The 
first  row  shows  the  total  budget  covered  by  the  end  of  the  programming  period.  The 
second row details the amount covered by operations under EUR 100 000 (mandatory 
under  Article  67(2)(a)  of  Regulation  (EU)  1303/2013).  The  final  row  provides  data  on 
upper level SCO use between the Commission and Member States4. 

The percentage is based on the total covered by SCOs identified through the study and 
the budgets of programmes that participated in the survey. For more detail, please refer 
to the first and second steps of the process outlined in Chapter 1.4. The amounts in the 
last column are estimates of the potential budget covered at EU level, including both EU 
and national co-financing. This applies the percentage covered by identified SCOs to the 

4 Approved under Article 14(1) of Regulation (EU) 1304/2013 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

entire ESF budget (including co-financing) at EU level (for more detail, refer to the third 
step of the process outlined in Chapter 1.4). 

Table 17 – ESF SCO use in 2014-2020 

(1) % of OP 
budget covered 

(2) Estimated OP budget 
covered at EU level 
(EUR bn) 

All SCOs 

31.5% 

Of which SCO 
<100k 
Of which article 
14(1) 

3.6% 

6.5% 

44.245 

5.118 

9.174 

If scaled up to EU level, SCO use within ESF could account for around EUR 44 billion, a 
third of the total ESF budget. Of this, approximately EUR 5 billion would be for operations 
costing  less  than  EUR  100 000  which  was  mandatory  under  Article  67(2)(a)  of 
Regulation  (EU)  1303/2013.  Some  EUR  9.2  billion  would  be  for  upper  level  SCO 
schemes approved under Article 14(1) of Regulation (EU) 1304/2013. 

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
percentage of ESF budget covered at the lower level, while the second column details 
the portion of lower level SCOs covered by small operations, highlighting the impact of 
the  mandatory  use  of  SCOs  for  operations costing  less than EUR  100  000.  The third 
column displays the percentage of total budget covered by upper level schemes. As an 
example, in Czechia, 30.4% of the total ESF budget was covered by SCOs at the lower 
level;  2.1%  of  this  30.4%  covered  small  operations;  additionally,  18.4%  of  the  ESF 
budget was covered by upper level schemes. 

Member States that did not complete the questionnaire are marked in the table as ‘No 
reply,’  while  those  that  provided  only  partial  responses  (e.g.,  no  quantitative  data  on 
amounts) or inconsistent responses which did not pass the quality check (see section 
1.3) are marked as ‘Partial.’ 

Table 18 – ESF SCO use in 2014-2020 by Member State 

Lower level 

Upper level 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

SCOs 

partial 
19.1% 

36.8% 

29.3% 

30.4% 

31.9% 

32.3% 

18.7% 

31.6% 

47.6% 

Of which 
SCOs <100k 
partial 
0.0% 

0.0% 

0.0% 

2.1% 

0.0% 

1.0% 

0.0% 

0.0% 

18.2% 

SCOs 

partial 
0.0%5 

0.0% 

20.2% 

18.4% 

0.0% 

0.0% 

0.0% 

0.0% 

0.3% 

5 Responses from Belgium were incomplete. The ESF Programme for Flanders participated in the survey but was unable 

to provide data on amounts covered by SCOs.  

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programming periods 

Lower level 

Upper level 

MS 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

SCOs 

13.5% 

26.4% 

23.0% 

9.0% 

partial 

44.0% 

25.2% 

23.1% 

56.3% 

83.4% 

32.0% 

26.3% 

30.8% 

partial 

80.2% 

62.2% 

14.1% 

Of which 
SCOs <100k 
2.9% 

0.9% 

0.0% 

0.0% 

partial 

11.9% 

0.0% 

0.7% 

0.0% 

10.9% 

0.0% 

0.5% 

0.6% 

partial 

0.2% 

0.0% 

0.0% 

SCOs 

1.1% 

1.4% 

23.0% 

0.0% 

partial 

5.1% 

0.0% 

0.0% 

0.0% 

70.1% 

17.0% 

0.7% 

1.2% 

partial 

80.2% 

0.0% 

0.1% 

No reply 

No reply 

No reply 

As presented in the table above, at the end of the 2014-2020 period, four Member States 
covered more than 50% of their ESF budget using SCOs: Latvia, Malta, Sweden and 
Slovenia.  

4.2.1. 

Types of SCO used in 2014-2020 

The table below illustrates the use of flat rate, unit cost and lump sum SCOs as the share 
of total programme budget covered by each type at the lower level. 

Table 19 – ESF Types of SCO at the lower level in 2014-20206 

Member State 

Flat Rate 

Unit Cost 

Lower level 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

partial 

19.1% 

7.7% 

1.1% 

8.1% 

0.0% 

13.6% 

4.1% 

partial 

0.0% 

29.1% 

28.0% 

22.4% 

31.9% 

18.7% 

13.5% 

Lump Sum 

partial 

0.0% 

0.0% 

0.3% 

0.0% 

0.0% 

0.0% 

1.2% 

6 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in a 
given Member State) may not precisely match the corresponding value for that Member State in the previous table. 
These discrepancies result from the rounding of decimal figures 

44 

 
 
 
 
 
 
 
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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Lower level 

Budget covered (%) 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

TOTAL* 

21.0% 

12.0% 

12.4% 

23.2% 

0.0% 

9.0% 

partial 

11.1% 

0.3% 

0.2% 

0.3% 

4.1% 

15.0% 

16.1% 

1.8% 

partial 

0.0% 

4.1% 

6.2% 

10.0% 

35.3% 

0.0% 

2.2% 

23.0% 

0.0% 

partial 

27.2% 

24.9% 

22.1% 

52.0% 

79.3% 

17.0% 

8.4% 

28.6% 

partial 

80.0% 

57.6% 

8.0% 

0.6% 

0.3% 

1.1% 

1.0% 

0.0% 

0.0% 

partial 

5.6% 

0.0% 

0.8% 

4.1% 

0.0% 

0.0% 

1.8% 

0.4% 

partial 

0.2% 

0.5% 

0.0% 

No reply 

9.4% 

No reply 

21.3% 

No reply 

0.8% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

The majority of Member States predominantly used unit costs. Specifically, in 18 of the 
24  Member  States  that  provided  complete  questionnaires,  unit  costs  were  the  most 
frequently used. At EU level, unit costs account for 21.3% of the total budget, followed 
by flat rates, which cover 9.4%. 

The  table  below  details  the  types  of  SCO  approved  under  Article  14(1)  of  Regulation 
(EU) 1304/2013 which excludes flat rates. 

Table 20 – ESF Types of SCO under Article14(1) Regulation (EU) 1304/2013 

Upper level 

Budget covered (%) 

Member State 

Unit Cost 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

partial 

0.0% 

0.0% 

20.2% 

18.4% 

0.0% 

0.0% 

0.0% 

Lump Sum 

partial 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Upper level 

Budget covered (%) 

Member State 

Unit Cost 

Lump Sum 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

TOTAL* 

0.0% 

0.0% 

0.0% 

1.4% 

23.0% 

0.0% 

partial 

3.2% 

0.0% 

0.0% 

0.0% 

70.1% 

17.0% 

0.7% 

1.2% 

partial 

80.0% 

0.0% 

0.1% 

0.0% 

0.3% 

1.1% 

0.0% 

0.0% 

0.0% 

partial 

1.8% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

partial 

0.2% 

0.0% 

0.0% 

No reply 

6.3% 

No reply 

0.2% 

*Coverage of the budget at EU level for each type of SCO. 

At the upper level there is also a predominant use of unit costs. Specifically, in 10 of the 
14  Member  States,  unit  costs  were  the  most  frequently  used.  At  EU  level,  unit  costs 
account for 6.3% of the total budget, while lump sums cover only 0.2%. 

4.2.2. 

Thematic objectives covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs across Thematic Objectives identified 
through  the  ESF  survey.  The  total  is  more than  100%  because  each  SCO  can  cover 
multiple Thematic Objectives. 

Table 21 – Coverage of ESF Thematic Objectives by SCO 

Thematic objective 

% of SCOs 

TO 8: Promoting sustainable and quality employment 
and supporting labour mobility 
TO 9: Promoting social inclusion, combating poverty 
and any discrimination 
TO 10: Investing in education and training for skills and 
lifelong learning 
TO 11: Enhancing the capability of public authorities 
and efficient public administration 

65% 

66% 

65% 

3% 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Some two thirds of SCOs are used for operations under TOs 8 (65%), 9 (66%) and 10 
(65%). Only 3% are used to improve the efficiency of public administration (TO 11).  

4.2.3. 

Beneficiaries covered by SCOs in 2014-2020 

The  table  below  illustrates  the  distribution  of  SCO  among  types  of  beneficiary.  The 
percentage  is  calculated  from  the  total  number  of  SCOs  identified  for  each  type  of 
beneficiary  through  the  ESF  survey.  The  analysis  in  the  table  includes  schemes 
approved under EU Regulation 1304/2013 Article 14(1) to reimburse operations under 
EUR  200 000.The  percentages  total  more  than  100%  because  each  SCO  can  cover 
multiple beneficiaries. 

Table 22 – Beneficiaries reimbursed through SCOs for ESF operations 

Type of beneficiary 

Associations/NGOs 

Municipalities 

Regional authorities 

Schools 

Universities 

National authorities 

Employment agencies 

Research centres 

Health institutions 

% of SCOs  

43% 

29% 

29% 

25% 

21% 

18% 

13% 

12% 

11% 

Many  SCOs  (43%)  are  used  for  operations  implemented  by  NGOs  and  associations. 
Other types of beneficiaries are municipalities and regional authorities (29% each), as 
well as schools (25%).  

4.2.4. 

Type of costs covered by SCOs in 2014-2020 

The  table  below  shows  the  distribution  of  SCOs  among  the  types  of  costs  identified 
through  the  ESF  survey.  The  total  is  more than  100%  because  each  SCO  can  cover 
multiple costs. 

Table 23 – Types of costs covered by the SCOs 

Type of costs 

Direct costs 

All costs of the operation 

Indirect costs 

All eligible costs other than direct staff 
Only staff costs 

% of SCOs 

36% 

27% 

19% 

12% 
1% 

Over a third of the SCO schemes used under ESF (36%) cover only the direct costs of 
operations, while 27% cover all costs of the operations. Off-the-shelf schemes that cover 
only indirect costs account for 19%, while 12% cover all eligible costs except staff costs. 
Finally, just 1% of the schemes cover only direct staff costs. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

4.3.  Use of SCOs in 2021-2027 

The first four rows in the table below present SCOs mapped at the lower level for the 
2021–2027 programming period. 

The first row shows the coverage of SCOs mapped in this study, aggregating schemes 
classified as ‘in use’ and ‘programmed’. The subsequent three rows provide a breakdown 
of the total already covered by SCOs, the amount covered by operations below EUR 200 
000, and the portion already reimbursed to beneficiaries using SCOs. 

The  fifth  and  sixth  rows  focus  on  Member  State  defined  SCOs  at  the  upper  level 
approved under Article 94(2) of the CPR. The fifth row presents the overall coverage, 
aggregating schemes already submitted to the Commission and those programmed. The 
sixth row details the amount covered by schemes that have already been submitted to 
the Commission. 

The final two rows focus on Commission defined SCOs at the upper level under Article 
94(4) of the CPR. 

The percentage is based on SCO budgets of programmes that participated in the survey 
(for more detail, refer to the first and second steps of the process outlined in Chapter 
1.4). The amounts in the last column are estimates of the potential budget covered at 
EU  level  including  EU  and  national  co-financing.  This  is  determined  by  applying  the 
percentage from the first column to the entire ESF+ budget (including co-financing) at 
EU level (for more detail, refer to the third step of the process outlined in Chapter 1.4). 
The only exception is for the calculation of amounts related to upper level Member State 
defined  schemes  in  use  approved  under  Article  94(2),  which  considers  only  amounts 
declared by survey respondents. 

Table 24 – Overview of SCO in ESF+ in 2021-2027 

(1) % of 
programme 
budget covered 

(2) Estimated 
programme budget 
covered at EU level 
(EUR bn)  

SCOs mapped*  
(in use + programmed) 

- of which: SCOs in use 

- of which: SCOs mapped* <200k 
(in use + programmed) 
- of which: already reimbursed to 
beneficiaries 
SCOs mapped*  
(in use + programmed) 

- of which: SCOs in use 

Delegated act Art. 94(4) 
2023/1676 
Delegated act Art. 94(4) 
2022/2175 

Lower level 

Upper level 
Article 94(2) CPR 

Upper level  
Article 94(4) CPR 

43.8% 

39.9% 

10.8% 

1.3% 

17.2% 

15.6% 

1.6% 

0.1% 

62.158 

56.708 

15.349 

1.874 

11.951 

9.662 

2.066 

0.132 

*The amounts covered by the SCO mapped includes both in use and programmed SCO 
schemes mapped by the survey. 

48 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

impact 

SCO use under ESF+ of approximately 44% would cover over EUR 62 billion if applied 
to the total ESF+ budget. Based on data from respondents, a significant portion of the 
to  existing  schemes  (over  EUR  56  billion).  SCO 
expected 
reimbursements of 1.3%, or EUR 1.9 billion, confirms some delay in implementation of 
the  2021-2027  funds  and  suggests  that  reduced  costs  and  administrative  burden  will 
only  be  felt  as  financial  absorption  of  the  programmes  progresses.  The  coverage  of 
operations costing less than EUR 200 000 each is approximately EUR 15 billion. 

linked 

is 

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
percentage of ESF+ budget covered at the lower level, while the second column details 
the portion of lower level SCOs covered by operations under EUR 200 000, providing an 
estimate  of  the  impact  of  mandatory  SCOs  for  small  operations.  The  third  column 
displays the percentage of the total budget covered by Member State defined schemes 
approved under Article 94(2) of the CPR, while the fourth column shows the coverage of 
Commission defined schemes approved under Article 94(4) of the CPR. As an example, 
in Austria, 48.4% of the total ESF+ budget is covered by SCOs at the lower level, with 
31.8% specifically covering small operations and all schemes used at the lower level are 
also applied at the upper level through Article 94(2), as reflected by 48.4% in the third 
column.  

For some Member States (identified in blue in the table), the coverage for 2021-2027 in 
the  column  ‘SCOs  mapped’  is  derived  from  2014-2020  data.  For  more  details  see 
chapters 1.3 and 1.4. 

Table 25 –SCOs mapped in ESF+ in 2021-2027 at Member State level 

Lower level 

Upper level 

Member State  SCOs mapped 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

48.4% 

32.0% 

36.8% 

53.0% 

64.7% 

41.7% 

73.7% 

partial 

34.7% 

54.4% 

72.8% 

37.3% 

24.3% 

partial 

partial 

49.7% 

33.6% 

partial 

56.3% 

47.5% 

65.0% 

Of which SCOs 
<200k 
31.8% 

0.2% 

3.8% 

0.0% 

27.4% 

0.0% 

0.0% 

partial 

5.2% 

1.9% 

26.1% 

22.3% 

0.6% 

partial 

partial 

9.5% 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

Article 94(2) 

Article 94(4) 

48.4% 

9.3% 

4.5% 

11.3% 

30.2% 

30.3% 

0.0% 

partial 

0.0% 

7.6% 

0.0% 

7.9% 

24.3% 

partial 

partial 

6.3% 

33.6% 

partial 

0.0% 

17.3% 

62.0% 

0.0% 
0.0% 
0.0% 
0.0% 
11.1% 
0.0% 
0.0% 
partial 
0.0% 
7.9% 
0.0% 
0.5% 
0.0% 
partial 
partial 
2.9% 
0.0% 
partial 
0.0% 
0.0% 
0.0% 

49 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Lower level 

Upper level 

Member State  SCOs mapped 

PL 

PT 

RO 

SE 

SI 

SK 

29.0% 

51.7% 

31.0% 

80.2% 

62.2% 

32.6% 

Of which SCOs 
<200k 
12.9% 

7.5% 

25.3% 

0.6% 

2.2% 

0.0% 

Article 94(2) 

Article 94(4) 

0.0% 

39.0% 

31.0% 

0.0% 

0.0% 

0.0% 

0.0% 
2.3% 
0.0% 
0.0% 
0.0% 
0.0% 

As shown in the table above, by the end of the 2021-2027 period, ten Member States 
are  expected  to  cover  more  than  50%  of  their  ESF+  budget  using  lower  level  SCOs. 
These  are:  Cyprus,  Czechia,  Denmark,  Spain,  Finland,  Latvia,  Netherlands,  Portugal, 
Sweden and Slovenia.  

4.3.1. 

Types of SCO used in 2021-2027 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States, with the share of total programme budget covered by each type of SCO. 

Table 26 – ESF+ Type of SCO at lower level in 2021-20277 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

Lower level 

Budget covered (%) 

Flat Rate 
0.0% 

Unit Cost 
47.9% 

Lump Sum 
0.4% 

16.8% 

7.7% 

9.0% 

11.1% 

1.4% 

14.8% 

Partial 

6.5% 

8.6% 

30.7% 

25.4% 

0.5% 

partial 

Partial 

18.2% 

0.3% 

Partial 

0.3% 

15.2% 

29.1% 

44.0% 

49.0% 

34.4% 

58.9% 

partial 

28.3% 

44.4% 

30.2% 

12.0% 

23.8% 

partial 

partial 

29.8% 

33.2% 

partial 

52.0% 

0.0% 

0.0% 

0.0% 

4.6% 

6.0% 

0.0% 

partial 

0.0% 

1.4% 

11.9% 

0.0% 

0.0% 

partial 

partial 

1.7% 

0.0% 

partial 

4.1% 

7 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in a 
given Member State) may not precisely match the corresponding value for that Member State in the previous table. 
These discrepancies result from the rounding of decimal figures 

50 

 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Member State 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

Lower level 

Budget covered (%) 

Flat Rate 
14.9% 

Unit Cost 
32.6% 

Lump Sum 
0.0% 

9.0% 

15.5% 

3.3% 

0.0% 

2.9% 

4.1% 

11.9% 

10.3% 

56.0% 

5.2% 

48.1% 

31.0% 

76.7% 

57.6% 

20.7% 

31.7% 

0.0% 

8.4% 

0.3% 

0.0% 

0.6% 

0.5% 

0.0% 

1.7% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

The  predominant  use  of  unit  costs  is  also  confirmed  for  the  2021–2027  programming 
period.  In  fact,  the  overall  increase  in  SCO  lower  level  uptake  between  the  two 
programming periods is almost entirely attributable to an 10% rise in the budget covered 
by  unit  costs,  from  21.1%  in  2014–2020  to  31.7%  in  2021–2027  (for  greater  clarity, 
compare the previous table with Table 19). 

The use of flat rates has remained stable (9.4% at EU level in 2014–2020 and 10.3% in 
2021–2027). Meanwhile, the use of lump sums has seen a slight increase (0.9% at EU 
level in 2014–2020, rising to 1.7% in 2021–2027). 

The significance of unit costs is underscored in the table below, which details the types 
of SCO approved or programmed to be approved under  Article 94(2) of the CPR and 
Article 94(4) of the CPR. 

Table 27 – ESF+ Type of upper level SCO in 2021-20278 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

Upper level Article 94(2) and Article 94(4) 

Budget covered (%) 

Flat Rate 
0.0% 

Unit Cost 
47.9% 

Lump Sum 
0.4% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

Partial 

0.0% 

0.0% 

9.3% 

4.5% 

11.3% 

41.3% 

30.3% 

0.0% 

partial 

0.0% 

14.1% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

partial 

0.0% 

1.3% 

8 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in a 
given Member State) may not precisely match the corresponding value for that Member State in the previous table. 
These discrepancies result from the rounding of decimal figures 

51 

 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Member State 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

Upper level Article 94(2) and Article 94(4) 

Budget covered (%) 

Flat Rate 
0.0% 

Unit Cost 
0.0% 

Lump Sum 
0.0% 

0.0% 

0.5% 

partial 

Partial 

0.0% 

0.3% 

Partial 

0.0% 

0.0% 

6.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.1% 

8.3% 

23.8% 

partial 

partial 

9.2% 

33.2% 

partial 

0.0% 

17.3% 

56.0% 

0.0% 

41.1% 

31.0% 

0.0% 

0.0% 

0.0% 

18.6% 

0.0% 

0.0% 

partial 

partial 

0.0% 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

0.0% 

0.2% 

0.0% 

0.0% 

0.0% 

0.0% 

0.1% 

* The ‘total’ row displays the percentage of the budget covered by SCO at the EU level. 

The 2021-2027 SCO regulation allows for different approaches at lower and upper levels. 
It permits to use SCOs under Article 94 of the CPR at the upper level, but at the lower 
level different SCOs or even actual costs can be used. 

The survey reveals a consistent approach between lower and upper levels, with all SCOs 
adopted under Article 94 of the CPR also being implemented at the lower level. The table 
below focuses on the lower level and highlights, for each Member State, the ‘weight’ of 
schemes approved under Article 94 in the financial flow to beneficiaries. The table shows 
the  budget  share  covered  by  SCOs  for  beneficiaries,  distinguishing  between  those 
exclusively for the lower level (Article 53) and those also used for payment requests to 
the Commission (Article 94). The latter category is further divided into schemes under 
Article 94(2) of the CPR and ‘EU level SCOs’ under Article 94(4) of the CPR. 

Table 28 – SCOS at lower level under ESF+ : Article 53 vs Article 94 CPR 

Lower level 

Member 
State 
AT 

Total SCOs planned 
(Articles 53 + 94 CPR) 
48.4% 

Of which Article 
53  
0.0% 

Of which Article 
94(2) 
48.4% 

Of which Article 
94(4) 
0.0% 

BE 

BG 

CY 

CZ 

32.0% 

36.8% 

53.0% 

64.7% 

22.6% 

31.0% 

41.7% 

23.5% 

9.3% 

5.8% 

11.3% 

30.2% 

0.0% 

0.0% 

0.0% 

11.1% 

52 

 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Member 
State 
DE 

Total SCOs planned 
(Articles 53 + 94 CPR) 
41.7% 

Of which Article 
53  
11.4% 

Of which Article 
94(2) 
30.3% 

Of which Article 
94(4) 
0.0% 

Lower level 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

73.7% 

Partial 

34.7% 

54.4% 

72.8% 

37.3% 

24.3% 

partial 

Partial 

49.7% 

33.6% 

Partial 

56.3% 

47.5% 

65.0% 

29.0% 

51.7% 

31.0% 

80.2% 

62.2% 

32.6% 

73.7% 

partial 

34.7% 

38.9% 

72.8% 

29.0% 

0.0% 

partial 

partial 

40.5% 

0.0% 

partial 

56.3% 

30.1% 

3.0% 

29.0% 

10.4% 

0.0% 

80.2% 

62.2% 

32.6% 

0.0% 

partial 

0.0% 

7.6% 

0.0% 

7.9% 

24.3% 

partial 

partial 

6.3% 

33.6% 

partial 

0.0% 

17.3% 

62.0% 

0.0% 

39.0% 

31.0% 

0.0% 

0.0% 

0.0% 

0.0% 

partial 

0.0% 

7.9% 

0.0% 

0.5% 

0.0% 

partial 

partial 

2.9% 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

0.0% 

2.3% 

0.0% 

0.0% 

0.0% 

0.0% 

4.3.2. 

Specific Objectives covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  across  Specific  Objectives  identified 
through the ESF+ survey. The percentages total more than 100% because each SCO 
can cover multiple Specific Objectives. 

Table 29 – Coverage of ESF+ Specific Objectives per SCO 

Specific objective 

% of SCOs 

SO 4.1: Access to employment and activation measures for all 

SO 4.2: Modernising labour market institutions 

SO 4.3: Gender balanced labour market participation 

SO 4.4: Adaptation of workers and enterprises to change 

SO 4.5: Improving education and training systems 

SO 4.6: Quality and inclusive education and training systems 

SO 4.7: Lifelong learning and career transitions 

SO 4.8: Active inclusion and employability 

SO 4.9: Integration of third country nationals 

50% 

7% 

12% 

11% 

16% 

32% 

25% 

31% 

6% 

53 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Specific objective 

% of SCOs 

SO 4.10: Integration of marginalised communities 

SO 4.11: Equal access to quality social and healthcare services 

SO 4.12: Social integration of people at risk 

SO 4.13: Addressing material deprivation 

Technical assistance 

8% 

15% 

12% 

3% 

5% 

Half  the  SCOs  (50%)  are  used  for  ESF+  operations  on  access  to  employment  and 
activation measures for all (SO 4.1). Furthermore, 32% and 31%, respectively, are used 
for operations promoting inclusion, through SO 4.6 (quality and inclusive education and 
training systems) and SO 4.8 (active inclusion and employability). Only 7% are used to 
modernise labour market institutions (SO 4.2). The least covered is SO 4.13 addressing 
material deprivation (3%). 

4.3.3. 

Beneficiaries covered by SCOs in 2021-2027 

The table below illustrates the distribution of SCOs for different types of beneficiaries. 
The  percentage  is  calculated  from  the  number  of  SCOs  for  each  type  of  beneficiary 
identified  in  the  ESF+  survey.  The  percentages  total  more  than  100%  because  each 
SCO can cover multiple beneficiaries. 

Table 30 – Beneficiaries reimbursed through SCOs for ESF+ operations 

Type of beneficiary 

NGOs/Associations 

Municipalities 

Regional authorities 

Schools 

National authorities 

Employment agencies 

Health institutions 

Research centres/universities 

% of SCOs 

49% 

35% 

34% 

31% 

22% 

14% 

14% 

10% 

Approximately half the SCOs (49%) are used under operations implemented by NGOs 
and  associations.  Other  significant  types  of  beneficiaries  are  municipalities/local 
authorities (35%), regional authorities (34%) and schools (31%). Only 10% of the SCOs 
reimburse research centres/universities. 

4.3.4. 

Type of costs covered by SCO in 2021-2027 

The table below shows the distribution of SCOs across different types of costs identified 
through the ESF+ survey.  

Table 31 – Types of costs covered by the SCOs 

Type of costs 

Direct costs 

All costs of the operation 

Indirect costs 

All eligible costs other than staff 

% of SCOs  
38% 

30% 

18% 

14% 

54 

 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Around a third of the SCO schemes covered direct costs (38%), as well as all costs of 
the  operations  (30%).  It  is  noteworthy  that  the  percentage  of  schemes  covering  all 
operational costs has increased compared to the previous programming period (30% vs. 
27%).  

55 

 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

4.4.  ESF/ESF+ stakeholder perceptions of SCO 

4.4.1. 

Advantages and challenges 

This section presents qualitative responses regarding the advantages of SCO schemes 
as well as issues encountered when developing them. This section on ESF/ESF+ does 
not include an assessment of why programme authorities decided not to use any SCOs 
because all responses that passed the quality check used SCOs. 

Figure 11 - Advantages of SCO schemes for ESF/ESF+ programme authorities 
(values in %) 

S
S
E
L

O
T
Y
S
A
E

R
O
F
Y
L
P
P
A

N
O
S
U
C
O
F

N
E
D
R
U
B
E
V

E
C
N
A
I
L
P
M
O
C

E
T
A
R
R
O
R
R
E

A
A
E
H
T
M
O
R
F

S

I

T
A
R
T
S
N
M
D
A

I

I

R
E
L
P
M
S

I

R
E
W
O
L

T
R
O
P
P
U
S

I

I

E
R
A
C
F
E
N
E
B

I

R
E
H
T
O

I

I

S
E
T
V
T
C
A

I

S
U
C
O
F
E
R
O
M

S
T
L
U
S
E
R
N
O

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

3

5

32

5

5

31

60

59

3

6

40

51

3

9

28

60

5

11

4

8

24

25

40

41

30

10

30

20

5

12

37

7

10

34

44

47

46

49

36

25

6

30

36

29

7

21

10

18

39

41

11

12

32

33

31

45

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

56 

 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

There  is  an  increased  perception  that  SCOs  benefit  programme  authorities.  In  both 
programming periods, the greatest advantages for programme authorities were reduced 
administrative burden and simplified compliance. Between 2014-2020 and 2021-2027, 
ESF/ESF+ programme authorities increasingly viewed SCOs as effective in improving 
the  focus  on  results,  support  from  audit  authorities  and  the  application  process  for 
beneficiaries. The increased perception of such advantages confirms the advantages of 
SCOs go beyond less administrative burden.  

Other advantages that increased between the two programming periods are fewer error 
rates and corrective actions, more focus on other activities, simpler compliance, as well 
as less administrative burden. 

The  survey  also  mapped  issues  for  programme  authorities  when  developing  SCO 
schemes, as seen in the figure below. 

57 

 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 12 - Challenges faced in developing SCO schemes for ESF/ESF+ 
programme authorities (values in %) 

M
O
R
F
K
C
A
B
D
E
E
F

L
A
G
E
L

F
O
K
C
A
L

F
O
K
C
A
L

I

L
A
C
R
O
T
S
H

I

I

E
V
T
A
G
E
N

F
O
K
C
A
L

A
A
E
H
T

I

Y
T
N
A
T
R
E
C
N
U

E
G
D
E
L
W
O
N
K

S
E
C
R
U
O
S
E
R

A
T
A
D

14-20

47

23

16

14

21-27

43

32

17

9

14-20

26

24

31

19

21-27

30

29

25

16

14-20

29

23

35

13

21-27

29

24

34

13

14-20

27

25

34

14

21-27

22

30

35

13

14-20

25

23

34

18

21-27

19

40

27

14

I

E
V
T
A
N
R
E
T
L
A
O
N

S
E
C
R
U
O
S

14-20

22

22

33

23

21-27

19

32

29

19

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

In both programming periods, the most relevant issue has been the lack of alternative 
sources. However, the relevance of each issue decreased across the two programming 
periods, proving that experience in 2014-2020 has helped in the current programming 

58 

 
 
 
 
 
 
 
 
 
 
Study on the uptake of Simplified Cost Options (SCO) and Financing Not Linked to Costs 
(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

period. Support from the audit authority is not considered an issue for most respondents 
(70% in 2014-2020 and 75% in 2021-2027). 

4.4.2. 

Involvement of the audit authority in defining SCOs 

The figure below provides a comparative analysis of the level of involvement of the AA 
in the development of simplification schemes. It is noteworthy that the figures reflecting 
the  involvement  of  AA  in  the  development  of  SCO  schemes  during  the  2021-2027 
programming period pertain exclusively to schemes used at the lower level. For schemes 
at the upper level, it should be emphasized that all schemes approved under Article 94 
require a formal assessment by the AA. 

Figure 13 – Involvement of the audit authority in defining SCOs under ESF/ESF+ 

THE AA WAS NOT CONSULTED

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

41%

30%

39%

31%

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

19%

39%

14-20

21-27

For the great majority of SCO schemes, in 2014-2020, the audit authority was either not 
consulted or consulted only informally (80%). It completed a formal ex-ante assessment 
for only 19% of the schemes. 2021-2027 shows a clear change, since the audit authority 
completed  a formal  ex-ante  assessment  on  approximately  40%  of  the  SCO  schemes 
developed under ESF+ (54%). 

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programming periods 

4.5.  Use of FNLC in ESF+ 

The first three rows in the table below display data on lower level FNLC use.9 The first 
row shows the budget covered by FNLC, including schemes already in use and those 
programmed. The next two rows detail the amount covered by FNLC schemes in use 
and the portion of the budget already reimbursed to beneficiaries using FNLC. 

The final three rows provide data on FNLC at the upper level. The first row displays the 
amount expected to be covered, including FNLC schemes in use and programmed. The 
next row details only FNLC in use. The last row details the amount already claimed by 
programme authorities from the Commission. 

All  this  information  is  presented  as  percentages  of  programme  budgets  and  total 
amounts.  The  percentage  is  the  ratio  between the  amount  covered  by  FNLC  and  the 
budgets of programmes that participated in the survey and passed the quality check. The 
amounts  in the  last  column  are  estimates  of the  potential  budget  covered  at  EU  level 
including both EU and national co-financing. This applies the percentage from the first 
column to the entire fund budget at EU level, extracted from the Cohesion Open Data 
Platform,  except  for  the  FNLCs  in  use  (second  row  for  both  lower  and  upper  levels), 
where actual (not estimated) values are displayed. 

Table 32 – Overview of FNLC use in ESF+ in 2021-2027 

(1) % of programme 
budget covered 

(2) Estimated programme 
budget covered at EU 
level (EUR bn) 

Lower level 

Total FNLC planned 
(in use + programmed) 

- of which: FNLC in use 

- of which: already 
reimbursed to 
beneficiaries 
Total FNLC planned 
(in use + programmed) 

Upper level 

- of which: FNLC in use 

- of which: already 
claimed  

6.0% 

2.3% 

0.70% 

6.0% 

2.34% 

0% 

8.521 

3.325 

999 

8.521 

3.325 

0 

Both lower and upper level FNLC under ESF+ account for approximately 6% of the total 
ESF+ budget for the analysed programmes. This would be EUR 8.5 billion if applied to 
the full ESF+ budget. Based on the responses and complemented by data from the SFC, 
a  significant  portion  of  this  amount  refers  to  FNLC  schemes  already  in use  (2.3%,  or 
EUR  3.3  billion).  For  the  amount  already  reimbursed  to  beneficiaries  and  amounts 
claimed  from  the  EC,  implementation  is  still  in  progress,  with  only  0.70%  of  the 
programme budget already reimbursed to beneficiaries (some EUR 1 billion at EU level) 
and no reported amounts claimed from the EC. 

The table below presents FNLC use at Member State level. The second column shows 
the percentage of ESF+ budget covered at the lower level and the third column the upper 

9 Article 53 (1) (f) of the CPR states that financing not linked to costs are possible at the lower level provided such 

grants are covered by a reimbursement of the Union contribution pursuant to Article 95. 

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programming periods 

level share. Figures are calculated per Member State from the amount covered by FNLC 
and the budgets of programmes that participated in the survey and passed the quality 
check. 

Table 33 – FNLC use in ESF+ in 2021-2027 per Member State 

Member State 

Total FNLC mapped 

Total FNLC mapped 

Lower level 

Upper level 

AT 

BE 

BG 

CY 
CZ10 
DE11 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 
NL14 

PL 

PT 

RO 

SE 

SI 

SK 

0% 

0% 

0% 

6.9% 

0% 

0% 

0% 
5.3%12 
0.6%13 

0% 

0% 

1.5% 

27.8% 

36.8% 

0% 

0% 

2.0% 

0% 

0% 

0% 

6.9% 

0% 

0% 

0% 

5.3% 

0.6% 

0% 

0% 

1.5% 

27.8% 

36.8% 

0% 

0% 

2.0% 

No reply 

No reply 

0.2% 

0% 

0% 

6.5% 

0.6% 

10.9% 

0% 

No reply 

0% 

0.2% 

0% 

0% 

6.5% 

0.6%  

10.9% 

0% 

No reply 

0% 

By  the  end  of  the  current  programming  period,  at  least  fourteen  Member  States  are 
expected  to  use  FNLC.  Among  them,  eight  Member  States  already  have  approved 
schemes,  namely,  Cyprus,  Estonia,  France,  Hungary,  Latvia,  Poland,  Portugal,  and 
Romania. 

10 Czechia is preparing an FNLC proposal. No financial information is available at the moment. 

11 Germany is preparing an FNLC proposal. No financial information is available at the moment. 

12 Estimated based on upper level amounts. 

13 Estimated based on upper level amounts. 

14 The Netherlands is preparing an FNLC proposal. No financial information is available at the moment. 

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programming periods 

Three Member States are expected to cover more than 10% of their ESF+ budget using 
FNLC: Croatia, Hungary and Romania.  

4.5.1. 

Types of FNLC used in 2021-2027 

The table below shows the use of Article 95(4) of the CPR (Delegated acts adopted by 
the Commission), Appendix 2 of the Article 95 of the CPR and Appendix 2 of the Article 
37 of the CPR across Member States. For each Member State, the table displays the 
ratio between the amount covered by FNLC identified through the study and the budgets 
of programmes that participated in the survey and passed the quality check. 

Table 34 – ESF+ type of FNLC in 2021-2027 

Lower level 

Upper level 

Budget covered (%) 

Appendix 2 
of Article 95  
CPR 

Appendix 2 
of Article 37 
CPR 

0% 

0% 

0% 

6.92% 

0% 

0% 

0% 

No financial 
data 
0% 

0% 

0% 

1.48% 

27.8% 

36.75% 

0% 

0% 

2.0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Article 95(4) 
CPR 
(Delegated 
acts) 
0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Appendix 2 
of Article 95  
CPR 

Appendix 2 
of Article 37 
CPR 

0% 

0% 

0% 

6.92% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

5.30% 

0%   

0.64% 

0% 

0% 

1.48% 

27.8% 

36.75% 

0% 

0% 

2.0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Article 95(4) 
CPR 
(Delegated 
acts) 
0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

6.46% 

0.56% 

10.87% 

0% 

0% 

0% 

0.24% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

6.46% 

0.56% 

10.87% 

0% 

0% 

0% 

0.24% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

For most Member States, the majority of the coverage is based on schemes adopted 
through Appendix 2 of the Article 95 of the CPR, which are also used at the lower level. 

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programming periods 

Of the 15 programmes reporting FNLC schemes for ESF+, only one programme reported 
adopting  a  FNLC  through  Appendix  2  of  Article  37  of  the  CPR.  No  schemes  were 
implemented through Delegated Acts.  

The figure below shows the types of FNLC indicators triggering payments under ESF+. 
Information from the survey and SFC show that five of the schemes with information on 
the indicators use a mix of output and result-based indicators to trigger payment, four 
use  only result-based  indicators  and four  only  output-based  indicators. Four  schemes 
did not have any information on indicators available.15 

Figure 14 – Types of FNLC indicators triggering payment in ESF+ 

38%

31%

Output only

Result only

Output & Result

31%

Examples of indicators used in programmes reporting FNLC are listed in the two boxes 
below. 

Box 2 – Examples of output-based indicators used in FNLC schemes 

-  Number of settlements participating in the program 

-  Number of children/adolescents included in the program 

-  Number of persons provided with health services 

-  Number of childcare places operating for 12 months for children up to 3 years 

-  Number of childcare places maintained for the next 24 months 

-  Number of participants entering and exiting employment/self-employment policy 

measure 

-  Number of teachers per year 

-  Number of educational/youth professionals in professional development activities 

15 Out of the 17 schemes reported, 3 are from the same CCI in Hungary. These schemes were counted separately as 

OPs reported the use of different indicators and amounts. 

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programming periods 

-  Persons included in training programs 

-  Proportion of regular child protection discount recipients 

-  Subsidised employment days for unemployed persons 

Box 3 – Examples of result-based indicators used in FNLC schemes 

-  Changes in the parental competence of parents of children aged 0-3 

-  Live births under 2500 grammes as a % of all live births 

-  Number  of  participants  in  employment,  including  self-employment,  six  months 

after leaving 

-  Number of undocumented absences of more than 50 hours in primary schools with 

full-time education 

-  Participants gaining a qualification upon leaving 

-  Persons entering public employment services 

-  Proportion of those admitted to secondary schools that offer graduation 

-  Proportion of those who remain in the field 3 years after starting the program 

-  Public expenditure savings per recipient who overcomes the vulnerability condition 

-  The number of vulnerable minors per thousand residents of the same age 

-  The  ratio  of  the  average  salary  of  teachers  working  in  public  education  to  the 

average salary of people with higher education 

The survey also highlights that most of the programmes reporting the use of FNLCs (over 
75%) did not set any adjustment/update methodology. The remainder set adjustments 
based on indicators for annual payroll, inflation, statistical data on public investment, or 
average monthly/daily costs. 

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programming periods 

4.5.2. 

Specific Objectives covered by FNLC in 2021-2027 

The table below  shows  the  Specific Objectives covered  by  operations  under  FNLC  in 
ESF+. Figures are shown as percentages of FNLCs associated with a Specific Objective 
divided by the total number of FNLC schemes. Each FNLC can cover multiple Specific 
Objectives. 

Table 35 – Coverage of ESF+ Specific Objectives per FNLC 

Specific Objectives 

4.1 - Access to employment and activation measures for all 
4.2 - Modernising labour market institutions 
4.3 - Gender balanced labour market participation 
4.4 - Adaptation of workers and enterprises to change 
4.5 - Improving education and training systems 
4.6 - Quality and inclusive education and training systems 
4.7 - Lifelong learning and career transitions 
4.8 - Active inclusion and employability 
4.9 - Integration of third country nationals 
4.10 - Integration of marginalised communities such as Roma 
4.11 - Equal access to quality social and healthcare services 
4.12 - Social integration of people at risk 
4.13 - Addressing material deprivation 
FNLC Schemes with no Specific Objective noted by respondents 

% of FNLC 
schemes covering 
the Specific 
Objective 
35% 
6% 
6% 
6% 
12% 
0% 
12% 
24% 
0% 
0% 
0% 
12% 
0% 
29% 

For ESF+ programmes with FNLC schemes which passed the quality check, the most 
common Specific Objective was ‘Access to employment and activation measures for all’ 
(SO  4.1),  in  more  than  a  third  of  schemes.  The  second  most  common  was  ‘Active 
inclusion and employability’ (SO 4.8), in 24% of them. This was followed by ‘Improving 
education and training systems’ (SO 4.5), ‘Social integration of people at risk’ (SO 4.12) 
and ‘Lifelong learning and career transitions’ (SO 4.7), covered by 12% of the schemes. 
6%  cover  operations  on  ‘Modernising  labour  market  institutions’  (SO  4.2);  ‘Gender 
balanced  labour  market  participation’  (SO  4.3);  and  ‘Adaptation  of  workers  and 
enterprises to change’ (SO 4.4). For 29% of FNLCs, authorities did not note any Specific 
Objective when replying to the survey. 

4.5.3. 

Advantages, challenges and reasons for not using FNLC 

The figure  below  presents  a  qualitative  analysis  of  FNLC  advantages,  as  reported  by 
managing  authorities.  Respondents  identified  key  benefits,  with  the  most  frequently 
mentioned  being  the  reduced  administrative  burden  and  that  FNLCs  are  simpler  and 
easier to check compliance (medium/high relevance for over 90% of respondents).  

Authorities  also  highlighted  that  FNLC  schemes  are  easier  to  apply  for  beneficiaries, 
simplifying  applications  and  implementation.  Additionally,  these  schemes  have  less 
errors,  financial  corrections  or  other  remedial  actions.  It  also  enables  authorities  to 
reallocate resources to other activities, such as performance monitoring and focus more 
on achieving outputs and results. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 15 Key advantages of FNLC (ESF+) (values in %) 

LESS ADMINISTRATIVE BURDEN

SIMPLER COMPLIANCE

LOWER ERROR RATE

EASY TO APPLY FOR BENEFICIARIES

8

8

31

31

8

8

31

8

8

23

62

62

54

62

FOCUS ON OTHER ACTIVITIES

8

8

38

46

MORE FOCUS ON RESULTS

8

8

17

67

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

The  primary  reason  for  authorities  to  not  use  FNLC  (Figure  16)  was  the  lack  of 
information/experience on how to design and implement such schemes, with over 75% 
of respondents rating this as medium/high importance. Managing authorities also cited 
the  administrative  burden  of  designing  FNLC  schemes  and  the  high  level  of  legal 
uncertainty associated with them, both of which were medium/high importance for about 
70% of respondents.  

Additional reasons include the perception that FNLC schemes are too risky, concerns 
about the potential systemic impact of miscalculating the financial amounts and the view 
that the benefits of FNLC are not immediately evident. All these reasons were considered 
of medium/high importance by a significant number of respondents.  

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programming periods 

Figure 16 Key reasons for not using FNLC (ESF+) (values in %) 

BURDENSOME

14

17

35

LACK OF INFORMATION

16

7

27

35

49

LEGAL UNCERTAINTY

14

16

30

41

NOT OBVIOUS BENEFITS

20

19

36

26

NOT SUITABLE FOR THE PROGRAMME

31

31

23

15

RISK OF SYSTEMIC IMPACT

15

21

36

28

TOO RISKY

21

14

41

24

OTHER REASONS

100

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

Figure  17  highlights  issues  reported  by  managing  authorities  when  developing  FNLC 
schemes with medium/high importance. Over 80% of respondents indicated that FNLC 
schemes are complicated and challenging to put in practice, alongside a lack of guidance 
and  practical  examples  on  how  to  design  FNLC  methodologies,  including  defining 
indicators and setting up results or conditions.  

Following  closely,  with  over  70%  of  respondents  rating  them  with  medium  or  high 
importance, are difficulties in identifying suitable types of operations, a lack of knowledge 
and  expertise  within  the  programme  authority,  insufficient  resources  to  develop  the 
scheme and legal uncertainty surrounding FNLC schemes. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 17 Key challenges faced in developing FLNCs (ESF+) (values in %) 

COMPLICATED AND DIFFICULT

8

8

46

38

DIFFICULT TO IDENTIFY SUITABLE
OPERATIONS

17

8

33

42

LACK OF DATA

15

15

31

38

LACK OF GUIDANCE

15

46

38

LACK OF KNOWLEDGE

23

31

46

LACK OF RESOURCES

8

15

46

31

LEGAL UNCERTAINTY

8

15

38

38

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

4.5.4. 

Involvement of the audit authority in defining the FNLC 

In 60% of schemes, managing authorities reported that the audit authority was consulted 
informally but did not conduct a formal assessment of the FNLC. A further 27% indicated 
the audit authority carried out a formal ex ante assessment, while 13% stated that the 
audit authority was not consulted.16 

For  schemes  where  the  audit  authority  was  not  involved,  the  reasons  included  the 
absence  of  a formal  requirement,  ongoing  adjustments  to  the  scheme  in  response to 
feedback from the Commission and the early developmental stage of the scheme. 

16 Please note that Article 95 of the CPR does not request a formal assessment. 

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programming periods 

Figure 18 Involvement of audit authority in ESF+ 

THE AUDIT AUTHORITY WAS NOT 
CONSULTED

13%

THE AUDIT AUTHORITY WAS 
CONSULTED INFORMALLY BUT DID 
NOT CARRY OUT A FORMAL 
ASSESSMENT OF THE FNLC

THE AUDIT AUTHORITY 
COMPLETED A FORMAL EX ANTE 
ASSESSMENT

60%

27%

4.6. 

Perception of beneficiaries 

The survey of beneficiaries was conducted through July and August 2024 and resulted 
in 699 complete answers. Of those, 62% declared benefiting from ESF+ and 65% from 
ESF (some beneficiaries benefited in both programming periods, hence the percentages 
total more than 100%). The figure below shows the types of beneficiaries responding to 
the survey.  

Figure 19 – Types of ESF/ESF+ beneficiaries responding to the survey 

PUBLIC INSTITUTION/ADMINISTRATION

RESEARCH/EDUCATIONAL INSTITUTION

OTHER

ENTERPRISE

TRADE UNION/NGO/ASSOCIATION

COC/BUSINESS SUPPORT ENTITIES

2%

NATURAL PERSON

0%

44%

27%

18%

14%

12%

44%  of  the  respondents  were  public  institutions/administrations,  while  27%  were 
research/education institutions. ‘Other’ respondents include foundations. 

The factsheet below presents data from the survey across both programming periods. It 
shows  that  most  respondents  (81%)  were  aware  of  SCOs  (there  were  no  responses 
about  FNLC).  Of  those,  the  great  majority  used  SCOs  (87%),  also  many  received 
training, workshops, or guidelines from the managing authority on SCOs (74%).  

Almost  all  the  ESF/ESF+  beneficiaries  who  completed  the  survey  and  were  aware  of 
SCOs (89%) declared that SCOs brought benefits for project management. For them, 
reduced administrative burden is the main benefit (56%), similar to programme authority 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

inputs  in  previous  sections.  In  addition,  more  than  a  third  (37%)  agreed  that  SCOs 
enabled a greater focus on the quality and results of their project. This is similar for both 
programming periods. 

Figure 20 – Survey data concerning ESF/ESF+ beneficiaries 

The  responses  to  open-ended  questions  on  lessons  learnt  and  recommendations  to 
encourage the wider adoption of SCOs reveal a strong appreciation for SCOs among 
survey participants. Most respondents who provided input noted that SCOs significantly 
simplify administrative processes as well as allowing a greater focus on project results. 

Regarding specific recommendations from ESF/ESF+ beneficiaries, some respondents 
called for an even broader adoption of SCOs, with comments such as ‘simplified costs 
should be the norm’ and suggestions that entire projects, rather than just portions, should 
be  covered  by  SCOs (‘no more real  costs’). Other recommendations  addressed  more 
technical  aspects,  such  as  ensuring  regular  adjustments  to  cost  units  to  prevent 
misalignment due to inflation. Additionally, some respondents highlighted the importance 
of  involving  beneficiaries  more  actively  in  the  development  of  SCO  schemes,  as 
facilitated by programme authorities. 

The final section of the survey invited beneficiaries to share their views on barriers and 
obstacles limiting access to CPR Funds. The responses identified two key challenges: 
the length and complexity of the project selection process and excessive bureaucracy, 
with project requirements often being poorly adapted to small NGOs. 

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programming periods 

5. 

DG HOME Funds - AMIF/BMVI/ISF 

This section does not include any sub-section on the use of FNLC because no data on 
FNLC schemes were provided by programme authorities. 

5.1. 

Use of SCOs in AMIF 

The table below covers SCO use under AMIF during the 2021-2027 programming period. 
The first four rows show SCO use at the lower level. The first row presents the coverage 
of SCOs ‘in use’ and ‘programmed’. The subsequent three rows detail the total budget 
already  covered  by  SCOs,  the  amount  covered  by  SCOs  for  operations  below 
EUR 200 000 and the portion already reimbursed to beneficiaries using SCOs.  

The final two rows show Member State designed SCO use at the upper level. However, 
as of the end of May 2024, no such schemes were programmed under AMIF. 

The  percentage  is  based  on  the  share  of  programme  budgets  covered  by  SCOs 
identified in the survey (for more detail, refer to the first and second steps of the process 
outlined in Chapter 1.4). The amounts in the last column are estimates of the potential 
budget covered at EU level including EU and national co-financing. This is determined 
by applying the percentage from the first column to the entire AMIF budget (including 
national co-financing) at EU level (for more detail, refer to the third step of the process 
outlined  in  Chapter  1.4).  It  is  important  to  note  that  the  budget  considered  for  this 
calculation refers to the entire AMIF budget (including national co-financing) as at the 
end of May 2024, according to data provided by cohesiondata.ec.europa.eu. 

Table 36 – Overview of SCO in AMIF 

(1) % of 
programme 
budget covered 

(2) Estimated 
programme budget 
covered at EU level 
(EUR bn)  

SCOs mapped 
(in use + programmed) 

- of which: SCOs in use 

- of which: SCOs mapped <200k 
(in use + programmed) 
- of which: already reimbursed to 
beneficiaries 
SCOs mapped  
(in use + programmed) 

SCOs in use 

19.5% 

16.3% 

0.3% 

1.4% 

0.0% 

0.0% 

Lower level 

Upper level 
Article 94(2)  

1.460 

1.221  

0.019 

0.103  

0  

0  

SCO use accounts for almost 20% of the AMIF budget. Based on data from respondents, 
a significant portion of the expected impact at the end of the programming period is linked 
to existing schemes (over EUR 1.2 billion). Expenditure already reimbursed covered by 
SCOs (1.4%, or EUR 0.1 billion) may concern some delay in implementation of the 2021-
2027 funds and suggests that reduced costs and administrative burden will only be felt 
as  financial  absorption  progresses.  The  coverage  of  small  operations  is  very  low: 
approximately EUR 19 million of the EUR 1.5 billion covered by SCOs are attributed to 
operations costing less than EUR 200 000. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

 At  the  time  of  the  survey  (spring  2024),  the  programmes  have  not  planned  to  use 
reimbursement  of  the  EU  contribution  according  to  Article  94(2)  of  the  CPR,  for  any 
HOME Funds (AMIF, BMVI, ISF). 

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
percentage of AMIF budget covered at the lower level, while the second column details 
the  portion  of  lower  level  SCOs  covered  by small  operations  below  200  000  EUR  for 
which the use of SCO is mandatory.  

The  third  column  would  display  the  percentage  of  the  budget  covered  by  upper  level 
schemes  but  no  such  SCOs  are  programmed  under  AMIF  at  the  time  of  the  survey 
(spring 2024). Member States that did not complete the questionnaire are marked in the 
table as ‘No reply,’ while those that provided only partial responses (e.g., no quantitative 
data)  or  submitted  inconsistent  responses  (i.e.,  did  not  pass  the  quality  check,  see 
section 1.3) are marked as ‘Partial.’ 

Table 37 – AMIF SCO mapped in 2021-2027 by Member State 

Lower level 

Member State  SCOs mapped 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Of which SCOs 
<200k 
1.5% 

No reply 

0.0% 

0.0% 

2.3% 

partial 

- 

0.0% 

0.0% 

No reply 

partial 

0.0% 

No reply 

0.0% 

partial 

0.0% 

0.2% 

2.1% 

Upper level 

SCOs mapped 

0.0% 

No reply 

0.0% 

0.0% 

0.0% 

partial 

- 

0.0% 

0.0% 

No reply 

partial 

0.0% 

No reply 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

35.8% 

No reply 

1.6% 

5.4% 

60.1% 

partial 

- 

3.7% 

15.0% 

No reply 

partial 

18.1% 

No reply 

44.9% 

partial 

8.0% 

12.9% 

4.3% 

No reply 

No reply 

No reply 

84.5% 

44.0% 

4.3% 

12.9% 

8.5% 

31.5% 

partial 

0.0% 

0.0% 

0.0% 

0.0% 

2.4% 

8.5% 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

partial 

0.0% 

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programming periods 

As presented in the table above, by the end of the 2021–2027 period, six Member States 
expect the proportion of the AMIF budget covered by lower-level SCOs will be higher 
than the EU average shown in the previous table (i.e., 19.5%). These Member States 
are Austria (36%), Czechia (60%), Hungary (45%), Malta (84%), the Netherlands (44%), 
and Sweden (31%). On the other hand, eight Member States plan SCOs covering less 
than  10%  of  their  budget:  Bulgaria,  Cyprus,  Estonia,  Italy,  Luxembourg,  Poland, 
Romania and Slovakia. 

5.1.1. 

Types of SCO used in 2021-2027 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States as the share of total programme budget covered by each type of SCO. 

Table 38 – AMIF Type of SCO at the lower level in 2021-202717 

Member State 

Flat Rate 

Lower level 

Budget covered (%) 

Unit Cost 

13.3% 

No reply 

1.6% 

0.0% 

29.2% 

Partial 

- 

0.0% 

15.0% 

21.0% 

No reply 

0.0% 

5.4% 

30.9% 

Partial 

- 

3.7% 

0.0% 

No reply 

No reply 

Partial 

7.3% 

Partial 

10.8% 

No reply 

No reply 

14.2% 

Partial 

6.6% 

12.8% 

4.3% 

30.8% 

Partial 

1.4% 

0.1% 

0.0% 

Lump Sum 

1.5% 

No reply 

0.0% 

0.0% 

0.0% 

Partial 

- 

0.0% 

0.0% 

No reply 

Partial 

0.0% 

No reply 

0.0% 

Partial 

0.0% 

0.0% 

0.0% 

No reply 

No reply 

No reply 

18.6% 

21.6% 

4.3% 

12.9% 

0.0% 

13.7% 

65.9% 

22.4% 

0.0% 

0.0% 

8.5% 

17.2% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.5% 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

17 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

Lower level 

Budget covered (%) 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

SI 

SK 

TOTAL* 

Partial 

0.0% 

8.8% 

Partial 

0.0% 

10.6% 

Partial 

0.0% 

0.1% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

Among the Member States using SCOs there are two main approaches. In half the cases 
they use flat rates, the other half use unit costs more. However, at EU level, the impact 
of unit costs are more significant, covering approximately 11% of the AMIF budget. 

5.1.2. 

Specific Objectives covered by SCO in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  across  Specific  Objectives  identified 
through the AMIF survey. The total is more than 100% because each SCO can cover 
multiple Specific Objectives. 

Table 39 Coverage of AMIF Specific Objectives by SCOs 

Specific Objective 

% of SCOs 

SO 1: Common European Asylum System 

SO 2 : Legal migration and integration 

SO 3: Return 

SO 4: Solidarity 

34% 

49% 

36% 

3% 

Approximately  half  the  SCO  schemes  (49%)  cover  operations  strengthening  and 
developing  legal  migration  to  the  Member  State,  promoting  and  contributing  to  the 
integration of third-country nationals (SO2), 36% are for countering irregular migration, 
return and reintegration in third countries (SO3), 34% for operations strengthening and 
developing  the  Common  European  Asylum  System  (SO1)  and  3%  for  operations  for 
increasing  solidarity  and  responsibility-sharing  between  the  Member  States,  with 
particular focus on those most affected by migration and asylum flows (SO4).  

5.1.3. 

Beneficiaries covered by SCOs in 2021-2027 

The table below illustrates the distribution of SCO among types of beneficiary identified 
through the AMIF survey. The total is more than 100% because each SCO can cover 
multiple beneficiaries. 

Table 40 Beneficiaries reimbursed through AMIF SCOs 

Type of beneficiary 

NGOs/Associations 

National authorities 

Municipalities/ Local authorities 

% of SCOs 

72% 

64% 

57% 

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Type of beneficiary 

% of SCOs 

Humanitarian organisations 

Regional authorities 

56% 

44% 

For AMIF interventions, NGOs and associations are being reimbursed by 72% of SCOs. 
The other types of beneficiaries are targeted by over 50% of SCOs, except for regional 
authorities (44%).  

5.1.4. 

Type of costs covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs among different types of costs identified 
through the AMIF survey. The total is more than 100% because each SCO can cover 
multiple costs. 

Table 41 Types of costs covered by the SCO in AMIF 

Type of costs 

Direct costs 

Indirect costs 

All eligible costs other than staff 

All costs of the operation 

% of SCOs  
44% 

29% 

15% 

13% 

Most SCOs cover direct costs (44%), along with indirect costs (29%). To a lesser extent, 
SCOs  use    the  off-the-shelf  flat  rate  provided  under  Article  56(1)  of  the  CPR,  which 
covers all costs of the operation except direct staff costs (15%). Finally, around 13% of 
SCOs cover all costs of the operations.   

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programming periods 

5.2. 

AMIF stakeholder perceptions of SCO 

5.2.1. 

Advantages, challenges and reasons for not using SCO 

This section presents qualitative responses regarding the advantages of SCO schemes 
as  well  as  issues  encountered  when  developing  them.  It  also  includes feedback  from 
respondents who did not use any SCO. 

Figure 21 - SCO advantages for AMIF programme authorities in 2021-2027 
(values in %) 

LESS ADMINISTRATIVE BURDEN

9

14

77

SIMPLER COMPLIANCE

9

36

55

LOWER ERROR RATE

5

9

36

50

SUPPORT FROM THE AA

5

32

27

36

EASY TO APPLY FOR
BENEFICIARIES

5

23

73

FOCUS ON OTHER ACTIVITIES

9

45

14

32

MORE FOCUS ON RESULTS

5

32

32

32

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

The  most  significant  advantage  is  the  reduced  administrative  burden  for  programme 
authorities,  considered  highly  relevant  by  77%  of  respondents.  This  is  followed  by  a 
simpler application process for beneficiaries, simpler compliance and a lower error rate. 
Conversely, the opportunity to focus on other activities was of no or little relevance for 
more than half the respondents. 

The survey also mapped issues encountered by programme authorities when developing 
SCO schemes as shown in the figure below. 

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programming periods 

Figure 22 - Challenges faced in developing SCO schemes for AMIF programme 
authorities in 2021-2027 (values in %) 

NEGATIVE FEEDBACK FROM THE AA

41

45

14

LEGAL UNCERTAINTY

18

36

23

23

LACK OF KNOWLEDGE

18

32

41

9

LACK OF RESOURCES

23

14

32

LACK OF HISTORICAL DATA

18

23

36

32

23

NO ALTERNATIVE SOURCES

14

18

50

18

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

Combining the responses rated as ‘medium’ and ‘high relevance’, the most significant 
challenges for AMIF authorities concern the lack of resources to develop SCO schemes 
(considered highly problematic by nearly one-third of respondents) and issues related to 
the  absence  of  historical  data  or  alternative  sources  through  which  to  develop  the 
methodologies underpinning the schemes. 

Among  the  two  programme  authorities  who  did  not  use  any  SCO  scheme,  the  main 
reasons  were  awareness  of  the  impact  of  miscalculating  a  scheme  as  well  as 
burdensomeness related to SCOs. 

5.2.2. 

Involvement of the audit authority in defining SCOs 

The  figure  below  presents  the  audit  authority  involvement  in  defining  SCO  schemes 
developed under AMIF. 

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programming periods 

Figure 23 - Audit authority involvement in defining AMIF SCOs in 2021-2027 

THE AA WAS NOT CONSULTED

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

41%

44%

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

15%

The analysis of AMIF data reveals two predominant approaches in interactions with the 
audit authority : the majority approach, where the AA is primarily involved at an informal 
level  (44%  of  responses)  and,  to  a  lesser  extent,  at  a  formal  level  (15%).  41%  of 
respondents did not consult AA at all.  

5.2.3. 

Perception of beneficiaries 

The survey of beneficiaries was conducted through July and August 2024 and resulted 
in  57  complete  answers.  The  figure  below  shows  the  types  of  respondent.  The  total 
exceeds  100%  because,  in  some  cases,  respondents  have  identified  themselves  as 
belonging to multiple categories. 

Figure 24 - Types of AMIF beneficiaries responding to the survey 

TRADE UNION/NGO/ASSOCIATION

60%

PUBLIC INSTITUTION/ADMINISTRATION

32%

OTHER

16%

RESEARCH/EDUCATIONAL INSTITUTION

7%

ENTERPRISE

COC/BUSINESS SUPPORT ENTITIES

4%

2%

NATURAL PERSON

0%

Over  half  of  the  respondents  were  from  the  category  ‘trade  unions,  NGOs  or 
institutions  or 
associations’,  while  approximately  one-third 

represented  public 

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programming periods 

administrations.  The  ‘Other’  category  includes  respondents  such  as  charitable 
organisations and police forces. 

The factsheet below shows that almost all respondents (88%) were aware of SCOs (no 
responses were received on FNLC). Of those, the great majority used SCOs (88%) and 
received training, workshops, or guidelines from the managing authority (70%). 

Almost  all  the  AMIF  beneficiaries  who  completed  the  survey  and  used  SCOs  (93%) 
declared that SCOs benefit project management. The reduced administrative burden is 
the main  benefit (69%), similar to  programme  authority  inputs  in  previous  sections.  In 
addition, 42% of respondents agreed that SCOs enabled a greater focus on the quality 
and results of the project. 

Figure 25 - Data collected through the survey concerning AMIF beneficiaries 

The  analysis  of  responses  to  the  open-ended  questions  on  lessons  learnt  and 
recommendations  to  encourage  the  wider  adoption  of  SCOs  highlights  a  strong 
appreciation for SCOs among survey participants. Specifically, most answers noted that 
SCOs  greatly  streamline  the  administrative  processes  associated  with  projects.  For 
specific  recommendations  from  AMIF  beneficiaries,  some  respondents  stressed  the 
importance of guidance from programme authorities to support SCO implementation. 

The final section of the survey allowed beneficiaries to share their views on barriers and 
obstacles limiting access to CPR Funds. AMIF beneficiaries focused on three challenges 
to  project 
the  administrative  burden  associated  with  project 
management;  the  length  and  complexity  of  the  project  selection  process;  and  the 
difficulty, particularly for smaller beneficiaries and associations, of self-financing part of 
the project activities through the co-financing requirement. 

implementation: 

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5.3. 

Use of SCOs in BMVI 

The table  below  presents  BMVI  SCO  use  in  the 2021-2027  programming  period.  The 
first four rows show SCO use at the lower level. The first row presents the coverage of 
SCOs  ‘in  use’  and  ‘programmed’.  The  subsequent  three  rows  detail  the  total  budget 
already  covered  by  SCOs,  the  amount  covered  by  SCOs  for  operations  below 
EUR 200 000 and the portion already reimbursed to beneficiaries using SCOs.  

The  final  two  rows  cover  SCOs  at  the  upper  level,  through  Article  94(2)  of  the  CPR. 
However, as of the end of May 2024, no such SCO schemes were programmed under 
BMVI. 

The percentage is the share of programme budgets covered by SCOs identified through 
the study (for more detail, refer to the first and second steps of the process outlined in 
Chapter  1.4).  The  amounts  in  the  last  column  are  estimates  of  the  potential  budget 
covered  at  EU  level  including  EU  and  national  co-financing.  This  is  determined  by 
extrapolating the percentage in the first column to the EU level BMVI budget including 
national  co-financing  (for more  detail,  refer to  the third  step  of the  process  outlined in 
Chapter 1.4). The BMVI budget refers to the entire BMVI budget including national co-
financing  available  as  of  the  end  of  May  2024,  according  to  data  provided  by 
cohesiondata.ec.europa.eu. 

Table 42 – Overview of SCO in BMVI 

(1) % of 
programme 
budget covered 

(2) Estimated 
programme budget 
covered at EU level 
(EUR mio)  

SCOs mapped  
(in use + programmed) 

- of which: SCOs in use 

- of which: SCOs mapped <200k 
(in use + programmed) 
- of which: already reimbursed to 
beneficiaries 
SCOs mapped  
(in use + programmed) 

SCOs in use 

Lower level 

Upper level 
Article 94(2) 

6.7% 

6.3% 

0.0% 

0.3% 

0.0% 

0.0% 

357  

340  

1  

18  

0  

0  

SCO use within BMVI accounts for approximately 6.7% of the BMVI budget. Based on 
responses, a significant portion of the expected impact at the end of the programming 
period  is  linked  to  existing  schemes  (over  EUR  340  million).  Expenditure  already 
reimbursed  covered  by  SCOs  is  0.3%,  or  EUR  18  million.  The  coverage  of  small 
operations is much less at some EUR 1 million. 

At the time of the survey (spring 2024), no programmes for HOME Funds (AMIF, BMVI, 
ISF) have planned to use an upper level SCO according to Article 94(2) of the CPR. 

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
share of BMVI budget covered at the lower level, while the second column details the 
portion of lower level SCOs for operations under EUR 200 000, providing an estimate of 
the impact of Article 53(2) of the CPR with mandatory SCOs for small operations. The 

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programming periods 

third column displays the share of total budget covered by upper level schemes approved 
under Article 94(2) of the CPR.  

As previously mentioned, as of the end of May 2024, no such SCO schemes are currently 
programmed under BMVI.  

Member States that did not complete the questionnaire are marked as ‘No reply,’ while 
those  that  provided  only  partial  responses  with  no  quantitative  data,  or  which  did  not 
pass the quality check (see section 1.3) are marked as ‘Partial.’ 

Table 43 – SCO mapped in BMVI in 2021-2027 by Member State 

Member State  SCOs mapped  Of which SCOs <200k 

Lower level 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

23.1% 

No reply 

partial 

7.8% 

2.8% 

partial 

No reply 

0.8% 

partial 

No reply 

partial 

4.2% 

0.0% 

33.8% 

- 

No reply 

0.2% 

partial 

No reply 

12.1% 

52.0% 

0.0% 

No reply 

0.2% 

No reply 

6.0% 

0.0% 

0.0% 

No reply 

partial 

0.0% 

0.0% 

partial 

No reply 

0.0% 

partial 

No reply 

partial 

0.0% 

0.0% 

0.0% 

- 

No reply 

0.0% 

partial 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

0.2% 

No reply 

0.0% 

0.0% 

Upper level 

SCOs mapped 
0.0% 

No reply 

partial 

0.0% 

0.0% 

partial 

No reply 

0.0% 

partial 

No reply 

partial 

0.0% 

0.0% 

0.0% 

- 

No reply 

0.0% 

partial 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

0.0% 

As  shown  in the  table above,  by  the  end  of  the 2021-2027  period, the  Netherlands  is 
projected to be the only Member State covering over 50% of its BMVI budget with SCOs. 
Notable also is Hungary (34%). 

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5.3.1. 

Types of SCO used in 2021-2027 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States as the share of total programme budget covered by each type of SCO. 

Table 44 –Types of lower level SCO in 2021-202718 

Lower level 

Budget covered (%) 

Member State 

Flat Rate 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

23.1% 

No reply 

Partial 

7.8% 

2.8% 

Partial 

No reply 

0.8% 

Partial 

No reply 

Partial 

4.2% 

0.0% 

5.3% 

- 

Unit Cost 

0.0% 

No reply 

Partial 

0.0% 

0.0% 

Partial 

No reply 

0.0% 

Partial 

No reply 

Partial 

0.0% 

0.0% 

28.5% 

- 

No reply 

No reply 

0.2% 

Partial 

0.0% 

Partial 

No reply 

No reply 

11.2% 

25.3% 

0.0% 

No reply 

0.0% 

No reply 

1.6% 

0.0% 

3.3% 

0.9% 

26.7% 

0.0% 

No reply 

0.2% 

No reply 

4.4% 

0.0% 

3.3% 

Lump Sum 

0.0% 

No reply 

Partial 

0.0% 

0.0% 

Partial 

No reply 

0.0% 

Partial 

No reply 

Partial 

0.0% 

0.0% 

0.0% 

- 

No reply 

0.0% 

Partial 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

0.0% 

0.0% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

18 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

Among Member States using SCO, flat rates are the most commonly used. Specifically, 
in 7 of the 12 Member States that use SCOs, flat rates are the most used. At EU level, 
the coverage by flat rates and unit costs is similar (3.3% of the total budget). Lump sums 
are not used by any Member State. 

5.3.2. 

Specific Objectives covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  across  Specific  Objectives  identified 
through the BMVI survey. The percentages total more than 100% because each SCO 
can cover multiple Specific Objectives. 

Table 45 Coverage of BMVI Specific Objectives by SCOs 

Specific Objective 

% of SCOs 

SO 1: European integrated border management 

SO 2: Common visa policy 
All SOs (i.e., SCOs applicable to the entire 
programme) 

41% 

34% 

55% 

For  BMVI,  55%  of  the  SCOs  cover  all  Specific  Objectives  of  the  fund.  Operations 
supporting effective European integrated border management, which facilitate legitimate 
border crossings, prevention and detection of illegal immigration and cross-border crime 
(SO1)  are  covered  by  41%  of  the  schemes.  Operations  supporting  the  common  visa 
policy and prevention of migratory and security risks (SO2) are covered by 34% of SCO 
schemes. 

5.3.3. 

Beneficiaries covered by SCOs in 2021-2027 

The table below illustrates the distribution of SCOs identified through the BMVI survey. 
The total is more than 100% because each SCO can cover multiple beneficiaries. 

Table 46 Beneficiaries reimbursed through SCOs for BMVI operations 

Type of beneficiary 

% of SCOs 

State and federal authorities 
Constituent elements of the European 
Border and Coast Guard 
Education and research organisation 

NGOs/Associations 

Municipalities/ Local authorities 

International organisations 

Union agencies 

Private and public law companies 

79% 

24% 

17% 

7% 

7% 

3% 

3% 

3% 

Almost 80% of the SCOs reimburse costs to state and federal authorities. In addition, a 
smaller  portion  finance  European  Border  and  Coast  Guard  authorities  (24%)  and 
education  and  research  organisations  (17%).  All  other  categories  of  beneficiaries  are 
covered by 3% to 7% of schemes. 

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programming periods 

5.3.4. 

Types of costs covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  among  the  types  of  costs  identified 
through the BMVI survey. The total is more than 100% because each SCO can cover 
multiple costs. 

Table 47 – Types of costs covered by the SCOs 

Type of cost 

Direct costs 

Indirect costs 

All costs of the operation 

All direct costs other than staff 

% of SCOs 
65% 

43% 

4% 

4% 

65% of SCOs cover direct costs, while 43% cover indirect costs. Few schemes cover all 
costs of the operations or only direct costs other than staff. 

5.4. 

BMVI stakeholder perceptions of SCO 

5.4.1. 

Advantages, challenges and reasons for not using SCO 

This section presents qualitative inputs from respondents regarding the advantages of 
SCO schemes as well as issues encountered when developing them. It also includes the 
feedback of respondents who did not use any SCO. 

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programming periods 

Figure 26 - Advantages of SCO schemes for BMVI programme authorities in 
2021-2027 (values in %) 

LESS ADMINISTRATIVE BURDEN

5

32

63

SIMPLER COMPLIANCE

37

63

LOWER ERROR RATE

21

32

47

SUPPORT FROM THE AA

10

35

20

35

EASY TO APPLY FOR
BENEFICIARIES

16

47

37

FOCUS ON OTHER ACTIVITIES

16

37

11

37

MORE FOCUS ON RESULTS

5
11

53

32

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

The  greatest  advantages  of  SCO  schemes  for  BMVI  programme  authorities  are  the 
reduced  administrative  burden  as  well  as  simpler  compliance  checking  (63%  of 
respondents acknowledged both as highly relevant). This is followed by fewer errors and 
financial  corrections,  simpler  application  and  implement  processes,  along  with 
opportunities to focus on other activities. However, the latter was also assessed as not 
relevant by 16% of the respondents. Most respondents found most advantages relevant 
to some degree. 

The survey also mapped issues encountered by programme authorities when developing 
the SCO schemes, as presented in the figure below. 

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programming periods 

Figure 27 - Challenges faced in developing the SCO schemes for BMVI 
programme authorities in 2021-2027 (values in %) 

NEGATIVE FEEDBACK FROM THE AA

58

37

5

LEGAL UNCERTAINTY

16

47

16

21

LACK OF KNOWLEDGE

21

26

47

5

LACK OF RESOURCES

21

16

32

LACK OF HISTORICAL DATA

21

16

32

32

32

NO ALTERNATIVE SOURCES

21

11

37

32

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

The  lack  of  internal  resources  and  historical  data  as  well  as  difficulties  in  finding 
alternative data sources are the most relevant issues when developing SCO schemes. 
Most respondents (58%) acknowledged that negative feedback from the audit authority 
was not an issue. 

Among  the  six  programme  authorities  not  using  SCOs,  the  main  reasons  were  the 
burdens  related  to  SCOs,  along  with  awareness  of  the  impact  of  miscalculating  a 
scheme. 

5.4.2. 

Involvement of the audit authority in defining SCOs 

The figure below presents the involvement of the audit authority in the definition of SCO 
schemes developed under BMVI. 

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programming periods 

Figure 28 - Involvement of the audit authority in SCO definition under BMVI in 
2021-2027 

THE AA WAS NOT CONSULTED

42%

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

53%

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

5%

For the majority of the BMVI SCO schemes, the audit authority was consulted informally 
(53%), though not at all for 42%. There was a formal ex-ante assessment for only 5%. 

5.4.3. 

Perception of beneficiaries 

The survey of beneficiaries was conducted through July and August 2024 and resulted 
in six complete answers. All respondents were public institutions/administrations. 

The  factsheet  below  presents  data  collected  through  the  survey,  showing  that  all  six 
respondents were aware of SCOs (no responses were received regarding FNLC). Five 
used SCOs and received training, workshops, or guidelines from the managing authority 
explaining SCOs. 

All  the  BMVI  beneficiaries  who  completed  the  survey  and  used  SCOs  declared  that 
SCOs brought benefits for project management. Reduced administrative burden is the 
main benefit in line with programme authority inputs presented in previous sections. In 
addition, a third of respondents agreed that SCOs speed up reimbursement. 

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Figure 29 - Data collected through the survey concerning BMVI beneficiaries 

Responses to open-ended questions on potential lessons learnt or recommendations for 
the use of SCOs were limited. Two out of six respondents, despite previously confirming 
that  SCOs  had  benefited  their  projects,  especially  by  reducing  administrative  costs, 
stated that SCOs are not always preferable to actual costs.  

None  of  the  respondents  identified  any  specific  barriers  or  challenges  that  hindered 
access to EU funds. 

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5.5. 

Use of SCOs in ISF 

The table below covers SCO use under ISF during the 2021-2027 programming period. 
The first four rows show SCO use at the lower level. The first row presents the coverage 
of SCOs ‘in use’ and ‘programmed’. The subsequent three rows detail the total budget 
already  covered  by  SCOs,  the  amount  covered  by  SCOs  for  operations  below 
EUR 200 000 and the portion already reimbursed to beneficiaries using SCOs.  

The final two rows cover SCO designed at the upper level, through Article 94(2) of the 
CPR.  However,  as  of  the  end  of  May  2024,  no  such  SCO  schemes  are  currently 
programmed under ISF. 

The  percentage  is  based  on  the  share  of  programme  budgets  covered  by  SCOs 
identified  through the study  (for  more  detail, refer to the first  and  second  steps  of the 
process outlined in Chapter 1.4). The amounts in the last column are estimates of the 
potential budget covered at EU level including EU and national co-financing. This applies 
the  percentage  from  the  first  column  to  the  entire  ISF  budget  including  national  co-
financing at EU level (for more detail, refer to the third step of the process outlined  in 
Chapter  1.4).  The  ISF  budget  considered  for  this  calculation  refers  to  the  entire  ISF 
budget including national co-financing available as of the end of May 2024, according to 
data provided by cohesiondata.ec.europa.eu. 

Table 48 Overview of SCO in ISF 

(1) % of 
programme budget 
covered 

(2) Estimated 
programme budget 
covered at EU level 
(EUR mio)  

SCOs mapped*  
(in use + programmed) 

- of which: SCOs in use 

- of which: SCOs mapped <200k 
(in use + programmed) 
- of which: already reimbursed to 
beneficiaries 
SCOs mapped 
(in use + programmed) 

SCOs in use 

Lower level 

Upper level 
Article 94(2) 

11.0% 

11.0% 

0.3% 

0.4% 

0.0% 

0.0% 

163  

163  

5  

6  

0  

0  

Based on information from Member States, only 11% of the ISF budget will be allocated 
to  SCOs  (around  EUR  163  million).  This  is  fully  covered  by  existing  SCOs  (no  new 
schemes envisaged). Of this a low share of 0.3% (EUR 5 million) is for operations of less 
than EUR 200 000 and 0.4% (EUR 6 million) has been reimbursed to beneficiaries.  

At  the  time  of  the  survey  (spring  2024),  no  ISF  programmes    have  planned  to  use 
reimbursement of the EU contribution according to Article 94(2) of the CPR. 

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
share  of  ISF  budget  covered  at  the  lower  level,  while  the  second  column  details  the 
portion of lower level SCOs covered by small operations. The third column displays the 
budget covered by schemes approved under Article 94(2) of the CPR. 

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As  previously  mentioned,  at  the  time  of  the  survey  (spring  2024)  no  such  SCO  is 
programmed under ISF. 

Member States that did not complete the questionnaire are marked in the table as ‘No 
reply,’ while those that provided only partial responses  with no amounts, or submitted 
inconsistent responses which did not pass the quality check (see section 1.3) are marked 
as ‘Partial.’ 

Table 49 –SCO mapped in ISF in 2021-2027 by Member State  

Lower level 

Upper level 

Member State  SCOs mapped 

Of which SCOs 
<200k 
No reply 

No reply 

0.3% 

0.0% 

0.0% 

SCOs mapped 

No reply 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

No reply 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

No reply 

No reply 

0.3% 

5.3% 

18.8% 

No reply 

- 

1.4% 

partial 

- 

0.0% 

partial 

No reply 

No reply 

partial 

4.4% 

No reply 

54.2% 

No reply 

No reply 

0.5% 

partial 

partial 

0.0% 

No reply 

0.0% 

No reply 

No reply 

0.0% 

partial 

No reply 

No reply 

11.5% 

53.0% 

0.0% 

No reply 

3.2% 

No reply 

5.6% 

0.0% 

0.0% 

0.0% 

0.0% 

No reply 

3.2% 

No reply 

0.1% 

0.0% 

- 

0.0% 

partial 

No reply 

partial 

0.0% 

No reply 

0.0% 

No reply 

No reply 

0.0% 

partial 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

3.2% 

No reply 

0.0% 

0.0% 

By  the  end of the  2021-2027  period,  two  Member  States  expect  over  50%  of the ISF 
budget to be covered by SCOs: Hungary (54%) and the Netherlands (53%). Most of the 
other Member States expect the SCO to cover only a small portion of their budget. 

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5.5.1. 

Types of SCO used in 2021-2027 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States, with the share of total programme budget covered by each type. 

Table 50 – ISF Type of SCO at the lower level in 2021-202719 

Lower level 

Budget covered (%) 

Flat Rate 
No reply 

No reply 

0.0% 

5.3% 

4.1% 

Unit Cost 
No reply 

No reply 

0.0% 

0.0% 

14.7% 

Lump Sum 
No reply 

No reply 

0.3% 

0.0% 

0.0% 

No reply 

No reply 

No reply 

- 

1.4% 

partial 

- 

0.0% 

partial 

No reply 

No reply 

partial 

4.4% 

No reply 

7.0% 

No reply 

No reply 

0.5% 

partial 

partial 

0.0% 

No reply 

47.2% 

No reply 

No reply 

0.0% 

partial 

No reply 

No reply 

11.4% 

26.4% 

0.0% 

No reply 

0.0% 

No reply 

4.8% 

0.0% 

4.4% 

0.1% 

26.5% 

0.0% 

No reply 

3.2% 

No reply 

0.7% 

0.0% 

6.6% 

- 

0.0% 

partial 

No reply 

partial 

0.0% 

No reply 

0.0% 

No reply 

No reply 

0.0% 

partial 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

0.0% 

0.0% 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

* The ‘total’ row displays the percentage of the budget covered by SCO at the EU level. 

19 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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Among  Member  States  using  SCOs,  flat  rates  are  the  most  commonly  employed. 
Specifically, in 6 of the 11 Member States using SCOs, flat rates predominate. However, 
at EU level (as shown in the last row of the table), unit cost SCOs account for the larger 
share at 6.6%, compared to 4.4% for flat rates. Lump sums are used only in Bulgaria, 
where they are the only type of SCO implemented. 

5.5.2. 

Specific Objectives covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  among  Specific  Objectives  identified 
through  the  ISF  survey.  The  total  is  more  than  100%  because  each  SCO  can  cover 
multiple Specific Objectives. 

Table 51 - Coverage of ISF Specific Objectives by the SCO 

Specific Objective 

% of SCOs  

SO 1: Exchange of information 

SO 2: Cross-border cooperation 

SO 3: Prevention and combating crime 
all SOs(i.e., SCOs applicable to the entire 
programme) 

42% 

27% 

27% 

12% 

42%  of  the  SCO  schemes  under  ISF  cover  the  exchange  of  information  (SO  1).  In 
addition,  almost  one third  (27%)  cover  operations  related to  cross-border  cooperation 
(SO 2), as well as preventing and combatting crime (SO 3). 

5.5.3. 

Beneficiaries covered by SCO in 2021-2027 

The  table  below  illustrates  the  distribution  of  SCOs  among  the  types  of  beneficiaries 
identified through the ISF survey. The total is more than 100% because each SCO can 
cover multiple beneficiaries. 

Table 52 – Beneficiaries reimbursed through SCOs for ISF operations 

Type of beneficiary 

State/federal police 

Customs and other specialised law enforcement services 

NGOs/Associations 

International organisations 

Research institutes and universities 

Municipalities/ Local authorities 

Private and public law companies 

Networks 

Union agencies 

% of SCOs  

64% 

45% 

30% 

21% 

18% 

9% 

6% 

6% 

0% 

Over 60% of SCOs cover operations supporting state and federal police. Many schemes 
concern  customs  and  specialised  law  enforcement  (45%),  with  some  covering  NGOs 
and associations (30%), international organisations (21%), as well as research institutes 
and  universities  (18%).  Few  cover  municipalities  or  local  authorities  (9%)  or  private/ 
public law companies and networks (6%). 

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5.5.4. 

Types of costs covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs across types of costs identified through 
the ISF survey. The percentages total more than 100% because each SCO can cover 
multiple costs. 

Table 53 – Types of costs covered by the SCOs 

Type of cost 

Direct costs 

Indirect costs 

All costs of the operation 

All direct costs other than staff 

% of SCOs 

55% 

38% 

7% 

3% 

55% of SCO schemes cover direct costs, while 38% cover indirect costs. Similar to BMVI, 
few schemes cover all costs of the operations (7%). 

5.6. 

ISF stakeholder perceptions of SCOs 

5.6.1. 

Advantages, challenges and reasons for not using SCOs 

This section presents qualitative inputs from respondents regarding the advantages of 
SCO schemes as well as issues encountered when developing them. It also includes the 
feedback of respondents who did not use any SCO. 

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Figure 30 - Advantages of SCO schemes for ISF programme authorities in 2021-
2027 (values in %) 

LESS ADMINISTRATIVE BURDEN

18

24

59

SIMPLER COMPLIANCE

41

59

LOWER ERROR RATE

12

41

47

SUPPORT FROM THE AA

13

28

33

25

EASY TO APPLY FOR
BENEFICIARIES

18

41

41

FOCUS ON OTHER ACTIVITIES

18

29

18

35

MORE FOCUS ON RESULTS

18

12

41

29

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

The  greatest  advantages  for  programme  authorities  are  the  reduced  administrative 
burden as well as simpler compliance checking (highly relevant for 59% of respondents 
in  both  cases).  This  is  followed  by  fewer  errors  and  financial  corrections  as  well  as 
simpler application and implementation processes.  

Audit  authority  involvement,  as  well  as  opportunities  to  focus  on  other  activities  and 
results were not relevant for 13% and 18% of respondents respectively.  

The survey also mapped issues encountered by programme authorities when developing 
the SCO schemes, as seen in the figure below. 

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Figure 31 - Challenges faced in developing the SCO schemes for ISF programme 
authorities in 2021-2027 (values in %) 

NEGATIVE FEEDBACK FROM THE AA

47

35

18

LEGAL UNCERTAINTY

24

35

24

18

LACK OF KNOWLEDGE

29

18

47

6

LACK OF RESOURCES

24

12

47

18

LACK OF HISTORICAL DATA

24

24

29

24

NO ALTERNATIVE SOURCES

18

29

35

18

1 = not relevant 2 = low relevance 3 = medium relevance 4 = high relevance

Combining  the  responses  rated  as  ‘medium’ and  ‘high  relevance’  the  most  significant 
challenges for  ISF authorities concern the lack of resources to develop SCO schemes 
and issues related to the lack of historical data or  alternative data sources through which 
to  develop  the  methodologies  underpinning  the  schemes.  Conversely,  approximately 
half of the respondents consider negative feedback from the audit authority to be a non-
issue. 

Among the five programme authorities who declared not using any SCO schemes, the 
main reasons were the burden of SCOs, awareness of the impact of miscalculating the 
schemes and a lack of information. 

5.6.2. 

Involvement of the audit authority in defining SCOs 

The figure below presents the involvement of the audit authority in the definition of SCO 
schemes developed under ISF. 

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programming periods 

Figure 32 - Audit authority Involvement in SCO definition under ISF in 2021-2027 

THE AA WAS NOT CONSULTED

43%

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

52%

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

5%

For the majority of the SCO schemes developed under the ISF, the audit authority was 
consulted  informally  (52%),  but  not  consulted  at  all  for  43%.  The  audit  authority 
completed a formal ex-ante assessment for only 5% of the schemes. 

5.6.3. 

Perception of beneficiaries 

The survey of beneficiaries was conducted through July and August 2024 and resulted 
in 18 complete answers. Almost all respondents were public institutions/administrations 
benefiting from ISF funding, the only exception was one law enforcement agency. 

The factsheet below presents data collected through the survey. It shows that 14 of the 
18 respondents (72%) were aware of SCOs (no responses covered FNLC). Of those, 
nine (69%) used SCOs and five (38%) received training, workshops, or guidelines from 
the managing authority explaining SCOs. 

All  the  ISF  beneficiaries  who  completed  the  survey  and  used  SCOs  said  that  SCOs 
brought  benefits  for  project  management.  According  to  them,  reduced  administrative 
burden is the main benefit (39%), which matches programme authority inputs presented 
in  the  previous  sections.  In  addition,  28%  of  respondents  agreed  that  SCOs  enabled 
more focus on the quality and results of the project. 

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Figure 33 - Data collected through the survey concerning ISF beneficiaries 

The  analysis  of  responses  to  the  open-ended  questions  on  lessons  learnt  and 
recommendations on promoting wider adoption of SCOs reveals a strong appreciation 
for  SCOs.  Most  respondents  highlighted 
the 
administrative processes for projects. 

that  SCOs  significantly  simplify 

Regarding specific recommendations, none of the respondents offered suggestions on 
how to enhance the use of SCOs. 

In  the  final  section  of  the  survey,  where  respondents  were  invited  to  share  their 
perspectives  on  barriers  and  obstacles  limiting  access  to  CPR  Funds,  only  two  ISF 
beneficiaries  provided  responses.  These  focused  on  the  administrative  burden 
associated  with  project  management  and  the  length  and  complexity  of  the  project 
selection process. 

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6. 

DG MARE Funds – EMFF/EMFAF 

6.1. 

Key findings 

The table below shows the uptake of simplification measures across two programming 
periods.  The  first  column shows  uptake at  both lower  and upper  levels  in  2014-2020. 
The second column combines the expected impacts of SCOs and FNLC, presenting their 
expected  coverage  by  the  end  of  the  current  programming  period.  It  is  important  to 
highlight that these figures are solely based on responses to the survey. For instance, 
data on SCOs planned under Article 94(2) by Estonia are not included in the report, as 
Estonia did not participate in the survey. 

For  both  programming  periods  and  both  levels,  the  percentage  refers  to  the  total 
EMFF/EMFAF budget. The uptake of total EMFF/EMFAF + budget excludes the portion 
covered by financial instruments, for which SCOs and FNLC are not applicable. 

Table 54 – Use of simplification measures in EMFF/EMFAF  

2014-2020 

2021-2027 

SCO 

SCO + FNLC 

7.7% 

- 

12.8% 

0.0% 

Coverage at 
lower level 
Coverage at 
upper level 

6.2. 

Use of SCOs in 2014-2020 

The percentage in the table below is based on the share of programme budgets covered 
by SCOs identified through the study. For more detail, refer to the first and second steps 
of the process outlined in Chapter 1.4. The amounts in the last column are estimates of 
the potential budget covered at EU level, including EU and national co-financing. This 
applies  the  percentage  from  the  first  column  to  the  entire  EMFF  budget  including  co-
financing at EU level (for more detail, refer to the third step of the process outlined in 
Chapter 1.4). 

Table 55 – Overview of EMFF SCO use in 2014-2020 

(1) % of OP budget 
covered 

(2) Estimated OP budget 
covered at EU level 
(EUR mio) 

SCOs 

7.7% 

596 

SCO use would account for almost EUR 600 million, or 7.7% of the total EMFF budget. 

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The table below shows SCO use at Member State level through the percentage of EMFF 
budget covered by SCOs. Member States that did not complete the questionnaire are 
marked in the table as ‘No reply,’ while those that provided only partial responses (e.g. 
no  amounts)  or  submitted  inconsistent  responses  which  that  did  not  pass  the  quality 
check (see section 1.3) are marked as ‘Partial.’ 

Table 56 – EMFF SCO use in 2014-2020 by Member State 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

SCOs 
partial 

No reply 

2.9% 

27.0% 

0.0% 

11.6% 

partial 

No reply 

0.0% 

No reply 

30.8% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

0.0% 

No reply 

9.3% 

No reply 

0.0% 

partial 

No reply 

0.0% 

No reply 

As shown in the table above, at the end of the 2014-2020 period, only two Member States 
covered more than 20% of their EMFF budget using SCOs: Cyprus and Finland. 

6.2.1. 

Types of SCO used in 2014-2020 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States as the share of total programme budget covered by each type of SCO. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Table 57 –Type of EMFF SCO at the lower level in 2014-202020 

Lower level 

Budget covered (%) 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

TOTAL* 

Flat Rate 

partial 

No reply 

0.0% 

15.0% 

0.0% 

10.6% 

partial 

No reply 

0.0% 

No reply 

0.1% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

0.0% 

No reply 

9.3% 

No reply 

0.0% 

partial 

No reply 

0.0% 

No reply 

2.2% 

Unit Cost 

partial 

No reply 

2.9% 

1.5% 

0.0% 

1.0% 

partial 

No reply 

0.0% 

No reply 

27.2% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

partial 

No reply 

0.0% 

No reply 

5.0% 

Lump Sum 

partial 

No reply 

0.0% 

10.5% 

0.0% 

0.0% 

partial 

No reply 

0.0% 

No reply 

3.4% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

partial 

No reply 

0.0% 

No reply 

0.5% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

The  five  Member  States  using  SCOs  use  two  predominant  approaches.  In  Cyprus, 
Germany  and  Poland  flat  rates  are  the  most  frequently  used  SCO.  In  Bulgaria  and 
Finland unit costs are more prevalent. At EU level, the impacts of unit costs are more 
significant, covering approximately 5% of the EMFF budget. 

20 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

6.2.2. 

Union priorities covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs among the EMFF EU priorities identified 
through the EMFF survey. The percentages total more than 100% because each SCO 
can cover multiple Union priorities. 

Table 58 – Coverage of EMFF Union priorities by SCOs 

Union priority 

Union priority 1: Promoting environmentally sustainable (…) fisheries 

Union priority 2: Fostering environmentally sustainable (…) aquaculture 

Union priority 3: Fostering implementation of the Common Fisheries Policy 

Union priority 4: Increasing employment and territorial cohesion (CLLD) 

Union priority 5: Fostering marketing and processing 

Union priority 6: Fostering implementation of the Integrated Maritime Policy 

% of 
SCO 
67% 

13% 

53% 

20% 

33% 

7% 

Some  two  thirds  of  SCO  schemes  (67%)  were  used  in  EMFF  operations  promoting 
environmentally sustainable, resource–efficient, innovative, competitive and knowledge–
based  fisheries.  Over  half  (53%)  were  used  to  foster  implementation  of  the  Common 
Fisheries Policy. The least covered Union priority  was fostering the implementation of 
the Integrated Maritime Policy (7%). 

6.2.3. 

Beneficiaries covered by SCO in 2014-2020 

The  table  below  illustrates  the  distribution  of  SCOs  among  the  types  of  beneficiaries 
identified through the EMFF survey. The total  is more than 100% because each SCO 
can cover multiple beneficiaries. 

Table 59 – Beneficiaries reimbursed through SCOs for EMFF operations 

Type of beneficiary 

% of SCOs 

Legal person 

Public authority 

Natural person 

Universities 

Organisation of fishers 

73% 

67% 

40% 

27% 

13% 

Nearly three quarters of the SCOs (73%) were used for EMFF operations implemented 
by  legal  persons.  Other  types  of  beneficiaries  reimbursed  through  SCOs  are:  public 
authorities (67%), as well as natural persons (40%). Only 13% reimbursed organisations 
of fishers.  

6.2.4. 

Types of costs covered by SCOs in 2014-2020 

The  table  below  shows  the  distribution  of  SCOs  among  the  types  of  costs  identified 
through the EMFF survey. The total is more than 100% because each SCO can cover 
multiple costs. 

Table 60 – Types of costs covered by the SCOs 

Type of cost 

% of SCOs 

All costs of the operation 

60% 

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programming periods 

Type of cost 

Direct costs 

Indirect costs 
All direct costs other than staff 

% of SCOs 

33% 

20% 
0% 

The  majority  of  SCO  schemes  (60%)  covered  all  the  costs  of  the  operations,  33% 
covered direct costs and 20% covered indirect costs.  

6.3. 

Use of SCOs in 2021-2027 

The  table  below  covers  SCO  use  within  EMFAF  during  the  2021-2027  programming 
period. The first three rows show SCO use at the lower level. The first row presents the 
coverage of SCO ‘in use’ and ‘programmed’. The subsequent two rows detail the total 
already covered by SCOs and the part already reimbursed to beneficiaries using SCOs.  

The final two rows represent the use of SCOs at the upper level under Article 94(2) of 
the  CPR.  Based  on  the  survey  responses,  no  such  SCOs  are  currently  programmed 
under EMFAF. However, according to information provided by DG MARE, Estonia (which 
did not respond to the survey questionnaire) has submitted a SCO scheme for approval 
under Article 94(2) of the CPR. 

The percentage is based on the share covered by SCOs of the budgets of programmes 
that participated in the survey. For more detail, refer to the first and second steps of the 
process  outlined in  Chapter  1.4.  The  amounts  in the  last  column  are  estimates  of  the 
potential budget covered at EU level including both EU and national co-financing. This 
applies  the  percentage  from  the  first  column  to  the  entire  EMFAF  budget  including 
national co-financing at EU level (for more detail, refer to the third step of the  process 
outlined in Chapter 1.4). 

Table 61 – Overview of SCO in EMFAF in 2021-2027 

(1) % of programme 
budget covered 

(2) Estimated 
programme budget 
covered at EU level 
(EUR mio)  

SCOs mapped  
(in use + programmed) 
- of which: SCOs in 
use 
- of which: already 
reimbursed to 
beneficiaries 
SCOs mapped  
(in use + programmed) 

SCOs in use 

Lower level 

Upper level 
Article 94(2) 

12.8% 

7.7% 

1.3% 

0.0% 

0.0% 

1 022 

619 

106 

0 

0 

The use  of  SCOs  within  EMFAF accounts for  some  13%  of the  EMFAF budget  (over 
EUR 1 billion). Based on responses, a significant portion of the expected impact at the 
end of the programming period is linked to existing schemes (over EUR 0.6 billion). The 
expenditure already reimbursed by SCOs (1.3%, or EUR 0.1 billion) seems to confirm 
some delay in implementation of the 2021-2027 funds. This suggests the cost reduction 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

and  administrative  burden  benefits  will  only  be  felt  as  financial  absorption  of  the 
programmes progresses.  

The table below shows the use of SCOs at Member State level. The first column shows 
the share of EMFAF budget covered at the lower level, while the second column displays 
the percentage of the total budget covered by schemes approved under Article 94(2) of 
the CPR, which are not applicable in this case. 

For some Member States (identified in blue in the table), coverage for 2021-2027 in the 
column ‘SCOs planned’ is derived from 2014-2020 data. For more details see chapters 
1.3 and 1.4. 

Table 62 – SCO mapped in EMFAF in 2021-2027 by Member State 

EMFAF 

Lower level 

Upper level 
Article 94(2) 

Member state 

SCOs mapped 

SCOs mapped 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

5.6% 

No reply 

No reply 

No reply 

13.9% 

11.6% 

partial 

No reply 

0.1% 

18.5% 

39.2% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

0.0% 

No reply 

25.0% 

No reply 

9.3% 

No reply 

0.0% 

No reply 

2.8% 

0.0% 

No reply 

No reply 

No reply 

0.0% 

0.0% 

partial 

No reply21 

0.0% 

3.9% 

0.0% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

0.0% 

No reply 

16.3% 

No reply 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

21 Estonia (which did not respond to the survey questionnaire) has submitted a Member State designed SCO scheme 

for approval under Article 94(2) of the CPR. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

SK 

0.0% 

0.0% 

All  Member  States  are  expected  to  cover  less  than  half  the  programme  budget  using 
SCOs – the highest being Finland (39%), Malta (25%), Spain (19%) and Czechia (14%).  

6.3.1. 

Types of SCO used in 2021-2027 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States as the share of total programme budget expected to be covered. Detail 
for Member States marked in blue is derived from 2014-2020 data. 

Table 63 – EMFAF type of SCO at lower level in 2021-202722 

Lower level 

Budget covered (%) 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Flat Rate 
0.7% 

No reply 

No reply 

No reply 

0.6% 

2.9% 

partial 

No reply 

0.0% 

0.8% 

28.5% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

8.3% 

No reply 

5.6% 

No reply 

0.0% 

No reply 

0.0% 

0.0% 

Unit Cost 
4.9% 

No reply 

No reply 

No reply 

13.3% 

8.7% 

partial 

No reply 

0.0% 

17.7% 

0.0% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

16.7% 

No reply 

3.7% 

No reply 

0.0% 

No reply 

0.0% 

0.0% 

Lump Sum 
0.0% 

No reply 

No reply 

No reply 

0.0% 

0.0% 

partial 

No reply 

0.1% 

0.0% 

10.7% 

No reply 

No reply 

No reply 

No reply 

No reply 

No reply 

- 

No reply 

0.0% 

No reply 

0.0% 

No reply 

0.0% 

No reply 

2.8% 

0.0% 

22 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Lower level 

Budget covered (%) 

Member State 

TOTAL* 

Flat Rate 
2.9% 

Unit Cost 
9.4% 

Lump Sum 
0.5% 

* The ‘total’ row displays the percentage of the budget covered by SCO at the EU level. 

For most Member States, the majority of coverage is based on unit costs. Similarly, at 
EU level (last row of the table), unit cost SCOs cover 8.1%. This is followed by the flat 
rate, predominantly off-the-shelf flat rate as set in the regulation. Lump sums are only 
used by three Member States and have low budget coverage (0.5% at EU level). 

6.3.2. 

Specific Objectives covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs among the Specific Objectives identified 
through the EMFAF survey. The total is more than 100% because each SCO can cover 
multiple Specific Objectives. 

Table 64 – Coverage of EMFAF Specific Objectives by the SCOs 

Specific Objective 

% of SCOs 

SO 1.1: Strengthening economically, socially and 
environmentally sustainable fishing activities 
SO 1.2: Engine replacement and modernisation 

SO 1.3: Permanent and temporary cessation 

SO 1.4: Control and data collection 

SO 1.5: Outermost regions 

SO 1.6: Protection and restoration of biodiversity 

SO 2.1: Sustainable aquaculture activities 

SO 2.2: Marketing and processing 

SO 3.1: Enabling a sustainable blue economy 

SO 4.1: Strengthening international ocean governance 

38% 

19% 

22% 

54% 

5% 

11% 

49% 

41% 

30% 

19% 

More than half the SCOs (54%) are used by EMFAF operations to foster efficient fishery 
control and enforcement including fighting illegal, unreported and unregulated fishing, as 
well as reliable data for knowledge-based decision making (SO 1.4). Furthermore, 49% 
of  the  SCOs  are  used  for  promoting  sustainable  aquaculture  activities,  especially 
strengthening  aquaculture  production  competitiveness,  while  ensuring  activities  are 
environmentally  sustainable in the  long term  (SO  2.1).  41%  are  promoting  marketing, 
quality and added value of fishery and aquaculture products, as well as processing those 
products (SO 2.2). Only 5% of the SCOs are used for promoting a level playing field for 
fishery  and  aquaculture  products  from  the  outermost  regions  (SO  1.5),  which  is  not 
available for all Member States. 

6.3.3. 

Beneficiaries covered by SCO in 2021-2027 

The  table  below  illustrates  the  distribution  of  SCOs  among  the  types  of  beneficiaries 
identified through the EMFAF survey. The total is more than 100% because each SCO 
can cover multiple beneficiaries. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Table 65 – Beneficiaries reimbursed through SCOs for EMFAF operations 

Type of beneficiary 

Micro-enterprises 

NGO/Association 

SMEs 

Public authority 

Natural person 

Research centre/ university 

LAG – Local action group 

Producer organisation 

Association of producer organisations 

Inter-branch organisation 

% of SCOs 

41% 

41% 

38% 

35% 

35% 

30% 

30% 

24% 

24% 

22% 

SCOs cover all types of EMFAF beneficiaries to some extent. The main ones are micro-
enterprises and NGOs/Associations (41%), followed by SMEs (38%), large enterprises, 
public authorities and natural persons (35%). Research centres/universities and LAG are 
covered by 30% of mapped SCOs.  

6.3.4. 

Types of costs covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs among types of costs identified through 
the EMFAF survey. The total is more than 100% because each SCO can cover multiple 
costs.  

Table 66 – Types of costs covered by the SCOs 

Type of costs 

All direct costs 

Indirect costs 

All costs of the operation 

All direct costs other than staff 

% of SCOs 

57% 

30% 

14% 

5% 

Direct costs are covered by 57% of the SCOs, followed by indirect costs (30%). A portion 
of SCOs (14%) cover all costs of the operation. Finally, around 5% of SCOs refer to the 
use of the off-the-shelf flat rate provided under Article 55(1) of the CPR while 5% cover 
all costs other than direct staff costs. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

6.4. 

EMFF/EMFAF stakeholder perceptions of SCO 

6.4.1. 

Advantages and challenges related to SCO 

This section presents the qualitative inputs from respondent regarding the advantages 
of SCOs as well as issues encountered when developing them. It also includes feedback 
from respondents who did not use any SCO. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 34 – Advantages of SCO schemes for EMFF/EMFAF programme 
authorities (values in %) 

I

E
V
T
A
R
T
S
N
M
D
A

I

I

R
E
L
P
M
S

I

R
O
R
R
E
R
E
W
O
L

M
O
R
F
T
R
O
P
P
U
S

R
O
F

R
E
H
T
O

S
S
E
L

Y
L
P
P
A
O
T
Y
S
A
E

N
O
S
U
C
O
F

N
E
D
R
U
B

E
C
N
A
I
L
P
M
O
C

E
T
A
R

A
A
E
H
T

I

I

S
E
R
A
C
F
E
N
E
B

I

I

I

S
E
T
V
T
C
A

I

S
U
C
O
F
E
R
O
M

S
T
L
U
S
E
R
N
O

14-20

21-27

14-20

21-27

14-20

21-27

23

8

8

33

77

50

62

38

33

23

42

38

25

38

33

17

33

17

14-20

38

38

23

21-27

68

29

3

14-20

21-27

14-20

21-27

14-20

21-27

8

8

8

54

50

38

33

23

15

31

31

25

33

33

8

23

23

38

15

17

33

33

17

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

In  both  programming  periods,  the  greatest  advantages  of  SCOs  are  seen  as  less 
administrative burden, simpler compliance checks, and easier application processes for 
beneficiaries.  However, unlike other funds,  programme  authorities  perceived  SCOs to 
be  more  effective  in  reducing  administrative  burden  and  simpler  compliance  during 
2014–2020 compared to 2021–2027.  

The survey also mapped issues encountered by programme authorities when developing 
SCOs, as seen in the figure below. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 35 - Challenges faced in developing SCOs for EMFF/EMFAF programme 
authorities (values in %) 

A
A
E
H
T
M
O
R
F

I

Y
T
N
A
T
R
E
C
N
U

E
G
D
E
L
W
O
N
K

S
E
C
R
U
O
S
E
R

A
T
A
D

I

E
V
T
A
G
E
N

K
C
A
B
D
E
E
F

L
A
G
E
L

F
O
K
C
A
L

F
O
K
C
A
L

I

L
A
C
R
O
T
S
H

I

F
O
K
C
A
L

O
N

I

E
V
T
A
N
R
E
T
L
A

S
E
C
R
U
O
S

14-20

46

38

15

21-27

50

42

8

14-20

38

23

15

23

21-27

33

42

17

8

14-20

15

38

23

23

21-27

14-20

21-27

25

25

25

25

15

23

46

15

42

17

25

17

14-20

31

31

23

15

21-27

33

14-20

25

42

38

46

15

21-27

42

25

33

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

In 2014-2020, the most relevant issue for EMFF programme authorities were the lack of 
alternative  sources,  and  the  lack  of  resources  while  in  2021-2027  it  is  a  lack  of 
knowledge. All the issues were less problematic for programme authorities in the current 
programming  period  than  in  the  previous  one,  proving  that  experience  in  2014-2020 
helped with SCOs in the current programming period. Audit authority involvement is not 
considered an issue for half the respondents in both cases. 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Five programme authorities declared not using any SCO schemes under EMFF in 2014-
2020, while only two did not in 2021-2027. The main reason is that SCOs are not suitable 
for their programme. This is followed by burdensomeness as well as awareness of the 
impact of miscalculating schemes. 

6.4.2. 

Involvement of the audit authority in defining SCOs 

The figure below presents the involvement of the audit authority in the definition of SCO 
schemes developed under EMFF/EMFAF. 

Figure 36 – Audit authority involvement in SCO definition under EMFF/EMFAF 

THE AA WAS NOT CONSULTED

45%

21%

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

50%

64%

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

5%

14%

14-20

21-27

For  almost  all  of  the  SCO  schemes  developed  under  EMFF  in  2014-2020,  the  audit 
authority was either not consulted or consulted only informally (95%). There was a formal 
ex-ante assessment for only 5% of the schemes. Data from 2021-2027 shows a clear 
change in the involvement of the audit authority, which was consulted informally for more 
than half the SCO schemes developed under EMFAF (64%) and completed a formal ex-
ante assessment for 14%.  

6.4.3. 

Perception of beneficiaries 

The survey of beneficiaries was conducted through July and August 2024 and resulted 
in 114 complete answers. The figure below shows the types of beneficiaries responding 
to the survey.  

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Figure 37 – Types of EMFF/EMFAF beneficiaries responding to the survey 

ENTERPRISE

OTHER

34%

28%

NATURAL PERSON

18%

PUBLIC INSTITUTION/ADMINISTRATION

TRADE UNION/NGO/ASSOCIATION

11%

9%

RESEARCH/EDUCATIONAL INSTITUTION

COC/BUSINESS SUPPORT ENTITIES

2%

1%

Around a third of respondents were enterprises benefitting from EMFF/EMFAF funding. 
‘Other’ includes cooperatives and foundations. 

The factsheet below presents survey data across both programming periods. Only 19% 
of respondents declared being aware of SCOs (there were no responses on FNLC). Of 
those,  64%  used  SCOs,  while  more  than  half  (55%)  received  training,  workshops,  or 
guidelines  from  the  managing  authority  explaining  SCOs.  Comparing  the  results  from 
each  programming  period,  respondents  aware  of  SCOs  increased  from  11%  to  28% 
between 2014-2020 and 2021-2027.  

The great majority of EMFF/EMFAF beneficiaries who completed the survey and used 
SCOs declared these brought benefits for project management (86%). For respondents, 
less administrative burden is the main benefit (10%), in line with programme authority 
inputs  presented  in  the previous sections.  In  addition,  6%  of respondents  agreed  that 
SCOs  reduce  the  error  rate.  When  comparing  each  programming  period,  reduced 
administrative burden remains the greatest advantage.  

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programming periods 

Figure 38 – Survey data concerning EMFF/EMFAF beneficiaries 

The responses to the open-ended questions on lessons learnt and recommendations to 
encourage the wider adoption of SCOs highlights a strong appreciation for SCOs among 
respondents  who  reported  using  them.  Most  noted  that  SCOs  significantly  simplify 
administrative processes and facilitate access to funds, particularly for smaller entities. 
Specific recommendations from beneficiaries to promote the use of SCOs included the 
need for additional training and clearer guidelines from programme authorities. 

The final section of the survey invited beneficiaries to share their views on barriers and 
obstacles  limiting  access  to  CPR  Funds.  The  few  EMFF/EMFAF  beneficiaries  who 
provided feedback consistently highlighted bureaucracy related to EMFF/EMFAF as the 
primary barrier. 

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7. 

DG REGIO Funds - ERDF/CF/JTF 

7.1. 

Use of simplification measures in ERDF 

7.1.1. 

Key findings 

The table below summarises the uptake of simplification measures covered by this study 
across two programming periods.  

The first column shows the use of simplification measures at both lower and upper levels 
during the 2014–2020 period. The second column presents the coverage of measures 
mapped by this study for the 2021–2027 programming period, combining schemes  ‘in 
use’ and ‘programmed.’ 

For both programming periods and both levels, the table displays uptake as a share of 
the total ERDF budget. It also shows uptake from the total ERDF budget, excluding the 
portion covered by financial instruments, for which SCOs and FNLC are not applicable. 

Table 67 – Simplification measures use in ERDF 

2014-2020 

2021-2027 

SCOs 

SCOs + FNLC 

Coverage at 
lower level 

Coverage at 
upper level 

Total budget 

Total budget excluding 
financial instruments 

Total budget 

Total budget excluding 
financial instruments 

6.7% 

7.7% 

- 

- 

11.5% 

12.2% 

4.2% 

4.5% 

7.1.2. 

Use of SCOs in 2014-2020 

The table below covers SCO use under ERDF in 2014-2020.   

The first row shows the budget covered by SCOs by the end of the programming period. 
The next row details the amount covered by operations below EUR 100 000 (mandatory 
use of SCO under Article 67(2)(a) of Regulation (EU) 1303/2013).  

The percentage is based on programme budgets covered by SCOs identified through 
the study. For more detail, refer to the first and second steps of the process outlined in 
Chapter  1.4.  The  amounts  in  the  last  column  are  estimates  of  the  potential  budget 
covered  at  EU  level  including  both  EU  and  national  co-financing.  This  applies  the 
percentage  from  the  first  column  to  the  entire  ERDF  budget  including  national  co-
financing at EU level (for more detail, refer to the third step of the process outlined in 
Chapter 1.4).  

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programming periods 

Table 68 – SCO use in ERDF in 2014-2020 

(1) % of OP 
budget covered 

(2) Estimated OP budget covered 
at EU level (EUR bn)  

All SCOs 

Of which SCOs 
<100k 

6.7% 

0.8% 

20.501 

2.403 

SCOs under ERDF account for almost EUR 20.5 billion, or approximately 7% of the total 
ERDF  budget.  Based  on  data  provided  by  respondents,  some  EUR  2.4 billion  are  for 
operations costing less than EUR 100 000.  

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
percentage of total ERDF budget covered at the lower level, while the second column 
details  the  portion  covered  by  small  operations,  showing  the  impact  of  SCOs  for 
operations costing less than EUR 100 000, where the use of SCO is mandatory under 
Article 67(2)(a) of Regulation (EU) 1303/2013. 

Member States that did not complete the questionnaire are marked as ‘No reply,’ while 
those that provided only partial responses (e.g., no amounts) or submitted inconsistent 
responses which did not pass the quality check (see section 1.3) are marked as ‘Partial.’ 

Table 69 –SCO used in ERDF in 2014-2020 by Member State 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

SCOs 
6.6% 

15.7% 

1.6% 

7.4% 

14.8% 

17.1% 

33.8% 

2.8% 

1.6% 

4.7% 

9.0% 

6.1% 

6.6% 

4.8% 

1.0% 

7.0% 

9.5% 

Of which SCOs <100k 
0.1% 

0.0% 

1.1% 

0.0% 

0.0% 

0.4% 

0.7% 

1.7% 

0.0% 

0.3% 

0.9% 

1.8% 

0.0% 

0.9% 

0.0% 

0.3% 

3.5% 

No reply 

No reply 

8.9% 

1.5% 

16.7% 

7.1% 

2.6% 

0.2% 

0.0% 

1.4% 

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PT 

RO 

SE 

SI 

SK 

UK 

TC 

1.4% 

1.5% 

19.2% 

33.5% 

0.0% 

No reply 

9.8% 

0.0% 

0.0% 

0.6% 

3.2% 

0.0% 

No reply 

0.9% 

At the end of the 2014-2020 period, two Member States covered more than 30% of their 
ERDF budget using SCOs: Denmark and Slovenia. On the other hand Malta, Portugal, 
Romania and Slovakia used 1.5% or less of the total budget for SCOs. 

7.1.2.1. 

Types of SCO used in 2014-2020 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States as the share of total programme budget covered by each type of SCO. 

Table 70 – ERDF Types of SCO in 2014-202023 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

Flat Rate 
2.7% 

1.8% 

0.1% 

1.1% 

14.8% 

3.2% 

21.8% 

1.1% 

1.0% 

2.9% 

8.5% 

4.8% 

1.1% 

4.8% 

1.0% 

1.0% 

2.8% 

Budget covered (%) 

Unit Cost 
3.9% 

13.9% 

0.4% 

6.3% 

0.0% 

13.9% 

12.0% 

1.4% 

0.6% 

1.8% 

0.0% 

1.2% 

5.5% 

0.1% 

0.0% 

5.8% 

4.8% 

Lump Sum 
0.0% 

0.0% 

1.1% 

0.0% 

0.0% 

0.0% 

0.0% 

0.2% 

0.0% 

0.1% 

0.5% 

0.0% 

0.0% 

0.0% 

0.0% 

0.3% 

2.0% 

No reply 

No reply 

No reply 

0.3% 

1.0% 

2.8% 

0.2% 

5.8% 

0.2% 

23 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

TC 

TOTAL* 

15.1% 

4.1% 

1.4% 

1.5% 

18.6% 

4.8% 

0.0% 

1.6% 

1.8% 

0.0% 

0.0% 

0.0% 

25.8% 

0.0% 

0.0% 

1.2% 

0.0% 

0.0% 

0.6% 

2.9% 

0.0% 

No reply 

No reply 

No reply 

6.7% 

3.6% 

2.8% 

2.5% 

0.3% 

0.5% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

Among the Member States using SCOs, flat rates are the most commonly used. In 15 of 
the 26 Member States that use SCOs, flat rates predominate. At EU level (last row of the 
table),  flat rates  cover  the  largest  portion of  the budget  (3.6%), followed by unit  costs 
(2.5%). Lump sums have low budget coverage (0.5% at EU level). 

7.1.2.2. 

Thematic objectives covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs across Thematic Objectives identified 
through the ERDF survey. The percentages total more than 100% because each SCO 
can cover multiple Thematic Objectives. 

Table 71 – Coverage of ERDF Thematic Objectives by SCO 

Thematic objective 

% of SCOs 

TO 1: Strengthening research, technological development and innovation 
TO 2: Enhancing access to and use and quality of information and 
communication technologies 
TO 3: Enhancing the competitiveness of small and medium-sized 
enterprises 
TO 4: Supporting the shift towards a low-carbon economy; 
TO 5: Promoting climate change adaptation, risk prevention and 
management 
TO 6: Preserving and protecting the environment and promoting resource 
efficiency 
TO 7: Promoting sustainable transport and removing bottlenecks in key 
network infrastructures 
TO 8: Promoting sustainable and quality employment and supporting 
labour mobility 
TO 9: Promoting social inclusion, combating poverty and any 
discrimination 
TO 10: Investing in education and training for skills and lifelong learning 
TO 11: Enhancing the capability of public authorities and efficient public 
administration 

74% 

15% 

42% 

30% 

9% 

33% 

14% 

10% 

10% 

8% 

18% 

Nearly  three  quarters  of  SCOs  (74%)  are  used  for  ERDF  operations  strengthening 
research, technological development and innovation (TO 1). Respectively 42% and 33% 
of the SCOs are used for enhancing the competitiveness of SMEs through TO 3 as well 
as preserving and protecting the environment and promoting resource efficiency through 

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programming periods 

TO 6. The least covered is TO 10 related to investing in education, training and lifelong 
learning (8%). 

7.1.2.3. 

Beneficiaries covered by SCOs in 2014-2020 

The  table  below  illustrates  the  distribution  of  SCOs  among  the  types  of  beneficiaries 
identified through the ERDF survey. The total is more than 100% because each SCO 
can cover multiple beneficiaries. 

Table 72 – Beneficiaries reimbursed through SCOs for ERDF operations 

Type of beneficiary 

% of SCOs  

SMEs 

Universities 

Associations/ NGOs 

Municipalities 

Regional authorities 

Micro-enterprises 

National authorities 

Chambers of commerce 

Large enterprises 

Health institutions 

Households 

60% 

50% 

46% 

41% 

40% 

37% 

37% 

29% 

26% 

19% 

2% 

The  majority  of  SCOs  (60%)  are  used  for  SMEs.  Other  major  types  of  beneficiaries 
reimbursed through SCOs are universities (50%), associations and NGOs (46%), as well 
as municipalities (41%). 

7.1.2.4. 

Types of costs covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs among types of costs identified through 
the ERDF survey. The total is more than 100% because each SCO can cover multiple 
costs. 

Table 73 – Types of costs covered by the SCOs 

Type of cost 

Indirect costs 

Direct costs 

All costs of the operation 

Only staff costs 

All eligible costs other than staff costs 

% of SCOs  

48% 

24% 

18% 

7% 

6% 

Nearly half the SCOs covered indirect costs of the operation (48%) while 24% covered 
all direct costs of the operation and 18% covered all costs of the operation. 

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programming periods 

7.1.3. 

Use of SCOs in 2021-2027 

The table below covers SCO use within ERDF in 2021-2027. 

The first four rows present the SCOs mapped at the lower level. The first row shows the 
coverage  of  SCOs  mapped  in  this  study,  aggregating  ‘in  use’  and  ‘programmed’ 
schemes. The subsequent three rows provide a breakdown of the total already covered 
by  SCOs,  the  amount  covered  by  operations  below  EUR  200 000,  and  the  portion 
already reimbursed to beneficiaries using SCOs. 

The fifth and sixth rows focus onSCOs at the upper level, approved under Article 94(2) 
of the CPR. The fifth row presents the overall coverage, aggregating schemes already 
submitted to the Commission and those programmed. The sixth row details the amount 
covered by schemes that have already been approved by the Commission. 

The  percentage  is  the  share  covered  by  SCOs  of  the  budgets  of  programmes  that 
participated  in  the  survey.  For  more  detail,  refer  to  the  first  and  second  steps  of  the 
process  outlined in  Chapter  1.4.  The  amounts  in the  last  column  are  estimates  of the 
potential budget covered at EU level including EU and national co-financing. This applies 
the percentage from the first column to the entire ERDF budget including co-financing at 
EU  level  (for  more  detail,  refer  to  the  third  step  of  the  process  outlined  in  Chapter 
1.4). The only exception is for amounts related to schemes in use approved under Article 
94(2), which considers only amounts declared by the survey respondents. 

Table 74 – SCOs mapped in ERDF in 2021-2027 

(1) % of 
programme budget 
covered 

(2) Estimated programme 
budget covered at EU level 
(EUR bn) 

SCOs mapped  
(in use + programmed) 

11.5% 

- of which: SCOs in use 

9.0% 

Lower level 

Upper level 
Article 94(2) 
CPR  

- of which: SCOs mapped 
<200k 
(in use + programmed) 
- of which already 
reimbursed to beneficiaries 
SCOs mapped  
(in use + programmed) 

SCOs in use 

1.4% 

0.2% 

3.5% 

3.1% 

37.479 

29.347 

4.575 

0.740 

7.407 

5.988 

SCO use under ERDF accounts for over EUR 37.5 billion, or 11.5% of the ERDF budget. 
Based on data from respondents, a significant portion of the expected impact at the end 
of the  programming  period  is  linked to schemes already in use (over  EUR  29  billion). 
Expenditure already reimbursed by SCOs (0.2%, or EUR 700 million) seems to confirm 
some  delay  in  the  implementation  of  2021-2027  funds.  The  benefits  of  SCOs  from 
reduced  costs  and  administrative  burden  will  be  felt  as  financial  absorption  of  the 
programmes  progresses.  For  small  operations,  approximately  EUR  4.5  billion  are 
attributed to operations costing less than EUR 200 000 each. 

The table below shows SCO use per Member State. The first column shows the share 
of ERDF budget covered at the lower level, while the second column details the portion 
of lower level SCOs covered by operations under EUR 200 000, providing an estimate 
of the impact of mandatory use of SCOs for small operations under Article 53(2) of the 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

CPR. The third column displays the percentage of the total budget covered by schemes 
approved under Article 94(2) of the CPR, while the fourth column details the portion of 
upper level SCOs covered by small operations.  

For some Member States (in blue in the table), the coverage for 2021-2027 in the column 
‘SCOs planned’ is derived from 2014-2020. For more details see chapters 1.3 and 1.4. 

Table 75 – SCO mapped in ERDF in 2021-2027 by Member State  

Lower level 

Upper level - Art.94(2)  

Member 
State 
AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TC 

SCOs mapped 

partial 

14.8% 

12.4% 

25.4% 

18.8% 

17.1% 

32.8% 

partial 

4.4% 

4.7% 

38.9% 

19.7% 

6.1% 

6.8% 

4.9% 

10.1% 

26.1% 

No reply 

partial 

10.7% 

19.8% 

7.2% 

10.1% 

3.7% 

54.9% 

33.5% 

11.4% 

23.9% 

Of which SCOs 
<200k 
partial 

0.0% 

0.2% 

0.0% 

4.5% 

2.4% 

0.1% 

partial 

1.1% 

1.5% 

20.0% 

0.9% 

0.0% 

0.2% 

0.2% 

1.5% 

0.0% 

No reply 

partial 

0.2% 

0.0% 

2.1% 

0.2% 

0.5% 

3.0% 

13.9% 

0.0% 

1.6% 

SCOs mapped 

partial 

9.7% 

0.0% 

1.1% 

11.4% 

0.7% 

0.0% 

partial 

0.0% 

1.0% 

0.0% 

11.2% 

0.0% 

0.0% 

0.1% 

1.1% 

26.1% 

No reply 

partial 

4.0% 

19.4% 

2.7% 

9.2% 

0.02% 

0.0% 

0.0% 

0.0% 

3.9% 

By the end of the 2021-2027 period, four Member States are expected to cover more 
than 30% of their ERDF budget using SCOs: Denmark, Finland, Sweden and Slovenia. 
Sweden is the only Member State expected to cover more than 50%. However, seven 
Member  States  may  cover  less  than  10%:  Greece,  Spain,  Croatia,  Hungary,  Ireland, 
Poland and Romania. 

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programming periods 

7.1.3.1. 

Types of SCO mapped in 2021-2027 

The table below illustrates the use of flat rate, unit cost and lump sum SCOs with the 
share of total programme budget expected to be covered by each type of SCO.  

Table 76 – ERDF Type of SCO at the lower level in 2021-202724 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Lower level 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

partial 

4.4% 

9.7% 

3.9% 

5.4% 

3.2% 

18.4% 

partial 

4.4% 

2.9% 

26.3% 

8.2% 

6.1% 

4.8% 

4.6% 

1.4% 

0.3% 

No reply 

partial 

6.6% 

0.6% 

2.6% 

0.9% 

3.7% 

26.1% 

4.8% 

1.2% 

partial 

10.4% 

0.3% 

21.5% 

10.2% 

13.9% 

14.5% 

partial 

0.0% 

1.8% 

1.0% 

11.4% 

0.0% 

2.0% 

0.3% 

8.3% 

25.7% 

No reply 

partial 

3.8% 

19.3% 

3.1% 

9.2% 

0.0% 

25.9% 

25.8% 

10.3% 

partial 

0.0% 

2.4% 

0.0% 

3.1% 

0.0% 

0.0% 

partial 

0.0% 

0.1% 

11.5% 

0.1% 

0.0% 

0.0% 

0.0% 

0.3% 

0.0% 

No reply 

partial 

0.2% 

0.0% 

1.5% 

0.0% 

0.0% 

3.0% 

2.9% 

0.0% 

24 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

TC 

TOTAL* 

13.7% 

4.1% 

8.9% 

6.6% 

1.3% 

0.8% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

Member States using SCOs have two predominant approaches. In half of them, flat rates 
are the most frequently used SCOs, the other half mostly uses unit costs. However, at 
EU  level,  unit  costs  are  more  significant,  covering  approximately  6.6%  of  the  ERDF 
budget. 

The significance of unit costs is underscored in the table below, which details the types 
of SCO approved or programmed to be approved under Article 94(2) of the CPR.  

Table 77 – ERDF Type of SCO at the upper level in 2021-202725 

Member State 

Flat Rate 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

partial 

1.2% 

0.0% 

1.1% 

0.0% 

0.0% 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

0.01% 

0.0% 

0.0% 

0.0% 

0.0% 

0.3% 

No reply 

partial 

0.0% 

0.1% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

Upper level 

Budget covered (%) 

Unit Cost 

partial 

Lump Sum 

partial 

8.5% 

0.0% 

0.0% 

9.5% 

0.7% 

0.0% 

partial 

0.0% 

1.0% 

0.0% 

11.1% 

0.0% 

0.0% 

0.1% 

0.8% 

25.7% 

No reply 

partial 

3.8% 

19.3% 

2.4% 

9.2% 

0.02% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

1.9% 

0.0% 

0.0% 

partial 

0.0% 

0.0% 

0.0% 

0.1% 

0.0% 

0.0% 

0.0% 

0.3% 

0.0% 

No reply 

partial 

0.2% 

0.0% 

0.3% 

0.0% 

0.0% 

0.0% 

0.0% 

25 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

SK 

TC 

TOTAL* 

0.0% 

0.0% 

0.0% 

0.0% 

3.8% 

3.3% 

0.0% 

0.1% 

0.2% 

* The ‘total’ row displays the percentage of the budget covered by SCO at the EU level. 

The 2021-2027 CPR Regulation allows different approaches at lower and upper levels 
for SCOs. For instance, SCOs approved under Article 94 of the CPR can be used at the 
upper level, with a different type of SCO or even actual costs used at the lower level.  

Survey data highlights that all Member State designed SCOs adopted under Article 94 
of the CPR that have also been implemented at the lower level. The table below focuses 
on  the  lower  level  and  highlights,  for  each  Member  State,  the  ‘weight’  of  schemes 
approved  under  Article  94  of  the  CPR  in  the  financial  flow  to  beneficiaries.  The table 
shows  the  budget  share  covered  by  SCOs  for  beneficiaries,  distinguishing  between 
those  exclusively  for  the  lower  level  (Article  53  of  the  CPR)  and  those  also  used  for 
payment requests to the Commission (Article 94 of the CPR). 

As an example, in Belgium 14.8% of the ERDF budget  is covered by lower level SCOs, 
of which 5.1% are established through Article 53 of the CPR and the remaining 9.7% 
through Article 94(2) of the CPR. 

Table 78 – ERDF use of SCO at lower level under Article 53 vs Article 94 CPR 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

Lower level 

Total SCO planned 
(Article 53 + 94 CPR) 
partial 

Of which Article 53 
CPR 
partial 

Of which Article 94 
CPR 
partial 

14.8% 

12.4% 

25.4% 

18.8% 

17.1% 

32.8% 

partial 

4.4% 

4.7% 

38.9% 

19.7% 

6.1% 

6.8% 

4.9% 

10.1% 

26.1% 

No reply 

partial 

10.7% 

19.8% 

7.2% 

10.1% 

5.1% 

12.4% 

24.3% 

7.4% 

16.2% 

32.8% 

partial 

4.4% 

3.7% 

38.9% 

8.5% 

6.1% 

6.8% 

4.8% 

9.0% 

0.0% 

No reply 

partial 

6.7% 

0.4% 

4.6% 

0.9% 

9.7% 

0.0% 

1.1% 

11.4% 

0.9% 

0.0% 

partial 

0.0% 

1.1% 

0.0% 

11.2% 

0.0% 

0.0% 

0.1% 

1.1% 

26.1% 

No reply 

partial 

4.0% 

19.4% 

2.7% 

9.2% 

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programming periods 

RO 

SE 

SI 

SK 

TC 

3.7% 

54.9% 

33.5% 

11.4% 

23.9% 

3.7% 

54.9% 

33.5% 

11.4% 

20.0% 

0.0% 

0.0% 

0.0% 

0.0% 

3.9% 

7.1.3.2. 

Specific Objectives covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs among the Specific Objectives identified 
through the ERDF survey. The percentages total more than 100% because each SCO 
can cover multiple Specific Objectives. 

Table 79 – Coverage of ERDF Specific Objectives by the SCOs 

Specific Objective 
SO 1.1: Enhancing research and innovation 

SO 1.2: Reaping the benefits of digitisation 

SO 1.3: Growth and competitiveness of SMEs 

SO 1.4: Skills for smart specialisation and transition 

SO 1.5: Digital connectivity 

SO 2.1: Energy efficiency 

SO 2.2: Renewable energy 

SO 2.3: Smart energy systems 

SO 2.4: Climate change adaptation 

SO 2.5: Sustainable water 

SO 2.6: Circular economy 

SO 2.7: Nature protection and biodiversity 

SO 2.8: Sustainable urban mobility 

SO 3.1: Sustainable TEN-T 

SO 3.2: Sustainable transport 

SO 4.1: Labour market infrastructure 

SO 4.2: Education and training infrastructure 

SO 4.3: Integration of marginalised communities 

SO 4.4: Integration of third country nationals 

SO 4.5: Access to health care 

SO 4.6: Culture and sustainable tourism 

SO 5.1: Integrated development in urban areas 

SO 5.2: Integrated development in rural and coastal areas 

Technical assistance 

% of SCOs 
52% 

23% 

30% 

17% 

4% 

25% 

21% 

14% 

31% 

7% 

27% 

25% 

8% 

6% 

10% 

7% 

15% 

5% 

2% 

13% 

24% 

9% 

7% 

10% 

About  half  the  SCOs  (52%)  are  used  for  ERDF  operations  regarding  research  and 
innovation (SO 1.1). While 30% and 27% respectively are used for operations concerning 
growth and competitiveness of SMEs (SO 1.3) and the circular economy (SO 2.6). The 
least covered are SO 4.4 for the integration of third country nationals (2%). 

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programming periods 

7.1.3.3. 

Beneficiaries covered by SCOs in 2021-2027 

The  table  below  illustrates  the  distribution  of  SCOs  among  types  of  beneficiaries 
identified  through  the  ERDF  survey.  The  percentages total  more than  100%  because 
each SCO can cover multiple beneficiaries. 

Table 80 – Beneficiaries reimbursed through SCOs for ERDF operations 

Type of beneficiary 

% of SCOs 

SMEs 

Municipalities/ Local authorities 

Research centres/ Universities 

Regional authorities 

NGOs/Associations 

Micro-enterprises 

National authorities 

Chamber of commerce 

Large enterprises 

Health institutions 

Households 

55% 

52% 

51% 

47% 

46% 

44% 

42% 

35 % 

31% 

30% 

10% 

More  than  half  the  SCOs  are  for  ERDF  operations  implemented  by  SMEs  (55%), 
municipalities/local  authorities  (52%),  as  well  as  research  centres/universities  (51%). 
Other types being significantly reimbursed through SCOs are regional authorities (47%) 
and NGOs/associations (46%).  

7.1.3.4. 

Types of costs covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  among  the  types  of  costs  identified 
through the ERDF survey. The total is more than 100% because each SCO can cover 
multiple costs. 

Table 81 – Types of costs covered by the SCOs 

Type of cost 

Indirect costs 

Direct costs 

All costs of the operation 

All eligible costs other than staff costs 
Only direct staff costs 

Travel/accommodation 
Preparation costs 

% of SCOs 

38% 

24% 

16% 

10% 
6% 

5% 
1% 

Over a third of the SCO schemes mapped (38%) cover indirect costs, while 24% cover 
direct costs. Schemes covering all operational costs account for 16%. Additionally, 10% 
of the schemes mapped under ERDF involve the use of the schemes covering all eligible 
costs other than the staff costs. Finally, respectively 6% and 5% of the schemes mapped 
cover direct staff costs (only) and travel/accommodation costs. 

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programming periods 

7.1.4. 

ERDF programme authorities’ perceptions of SCOs 

7.1.4.1. 

Advantages and challenges related to SCOs 

This section presents qualitative inputs from respondents regarding the advantages of 
SCO schemes as well as issues encountered when developing them. It also includes the 
feedback of respondents who did not use any SCO. 

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programming periods 

Figure 39 - Advantages of SCO schemes for ERDF programme authorities 
(values in %) 

S
S
E
L

Y
L
P
P
A
O
T
Y
S
A
E

N
O
S
U
C
O
F

I

E
V
T
A
R
T
S
N
M
D
A

I

I

R
E
L
P
M
S

I

R
O
R
R
E
R
E
W
O
L

M
O
R
F
T
R
O
P
P
U
S

R
O
F

R
E
H
T
O

N
O
S
U
C
O
F
E
R
O
M

N
E
D
R
U
B

E
C
N
A
I
L
P
M
O
C

E
T
A
R

A
A
E
H
T

I

I

S
E
R
A
C
F
E
N
E
B

I

I

I

S
E
T
V
T
C
A

I

S
T
L
U
S
E
R

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

2

7

25

5

4

28

2

8

29

4

5

26

2

16

38

66

63

61

65

44

5

11

39

45

33

33

26

32

28

26

13

1

12

39

6

8

33

7

26

11

24

38

41

8

19

44

12

13

40

49

53

29

24

29

35

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

Over  60%  of  respondents  perceive  reduced  administrative  burden  and  simpler 
compliance as highly relevant advantages. This is consistent across both programming 
periods, with a slight decrease for reduced administrative burden (highly relevant from 
66% to 63%) and a slight increase in the perceived benefits of simpler compliance (highly 
relevant  from 61% to 65%). 

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programming periods 

Combining responses marked as high and medium relevance, over 60% of beneficiaries 
note  the  advantages  of  all  the  listed  items,  except  support  received  from  the  audit 
authority which is relevant for a minority of respondents. 

Finally,  focusing  solely  on  responses  marked  as  high  relevance,  the  most  significant 
change  between  the  two  programming  periods  concerns  the  greater  focus  on  results 
(+6%). This indicates that increased experience with SCOs enhances the perception of 
their benefits, particularly the ability to shift time and resources from administrative tasks 
to improving the quality of projects and programmes. The survey also mapped issues 
encountered by programme authorities when developing the SCO schemes. 

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programming periods 

Figure 40 – Challenges faced when developing SCO schemes for ERDF 
programme authorities (values in %) 

I

E
V
T
A
G
E
N

F
O
K
C
A
L

M
O
R
F
K
C
A
B
D
E
E
F

L
A
G
E
L

F
O
K
C
A
L

F
O
K
C
A
L

I

L
A
C
R
O
T
S
H

I

I

E
V
T
A
N
R
E
T
L
A
O
N

A
A
E
H
T

I

Y
T
N
A
T
R
E
C
N
U

E
G
D
E
L
W
O
N
K

S
E
C
R
U
O
S
E
R

A
T
A
D

S
E
C
R
U
O
S

14-20

56

28

9

7

21-27

57

26

10

7

14-20

25

20

29

25

21-27

28

30

28

14

14-20

25

29

32

14

21-27

30

29

27

13

14-20

24

24

36

16

21-27

25

28

28

19

14-20

21-27

14-20

21-27

28

20

30

21

21

23

36

21

27

19

34

20

22

20

33

25

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

In  2014-2020,  the  most  relevant  issue  for  ERDF  programme  authorities  was  legal 
uncertainty, while in 2021-2027 it is a lack of alternative sources and a lack of historical 
data. However, the share of programme authorities affected by legal uncertainty and a 
lack  of  knowledge  significantly  decreased  across  the  two  programming  periods.  This 

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programming periods 

shows  experience  from  2014-2020  improved  approaches  to  SCOs  in  the  current 
programming  period.  Support  from  the  audit  authority  is  not  considered  an  issue  for 
almost half the respondents in both periods. 

In both 2014-2020 and 2021-2027, the main reasons programme authorities did not use 
SCOs is because they were not suitable for the programme and they were burdensome. 
However, the number of programme authorities not using any SCO drastically decreased 
from 35 in 2014-2020 to only 9 in 2021-2027. 

7.1.4.2. 

Audit authority involvement in SCO definition 

The figure below presents the involvement of the audit authority in the definition of SCO 
schemes  developed  under  ERDF.  It  is  noteworthy  that  the  figures  reflecting  the 
involvement  of  AA  in  the  development  of  SCO  schemes  during  the  2021-2027 
programming period pertain exclusively to schemes used at the lower level. For schemes 
at the upper level, it should be emphasized that all schemes approved under Article 94 
require a formal assessment by the AA.Figure 41 – Involvement of the audit authority in 
SCO definition under ERDF 

THE AA WAS NOT CONSULTED

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

26%

22%

26%

23%

56%

48%

14-20

21-27

For many SCO schemes developed under ERDF in 2014-2020, the audit authority was 
either  not  consulted  or  consulted  only  informally  (78%).  There  was  a  formal  ex-ante 
assessment for only 23% of the schemes. Data from 2021-2027 shows a clear change, 
with the audit authority completing a formal ex-ante assessment for almost half the ERDF 
SCOs (48%).  

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programming periods 

7.1.5. 

Use of FNLC in ERDF 

The  first  three  rows  in  the  table  below  display  data  on  the  use  of  FNLC  at  the  lower 
level.26 The first row shows the budget covered by FNLC including schemes already in 
use  and  those  programmed.  The  next  two  rows  detail  the  amount  covered  by  FNLC 
schemes in use and the portion of the budget already reimbursed to beneficiaries using 
FNLC. 

The final three rows provide data on FNLC at the upper level. The first row displays the 
amount expected to be covered by FNLC, including schemes in use and programmed. 
The next row details only FNLC in use. The last row details the amount already claimed 
by programme authorities from the Commission. 

All  this  information  is  presented  as  percentages  of  programme  budgets  and  total 
amounts. The percentage is the ratio between the total amount covered by FNLC and 
the budgets of programmes that participated in the survey and passed the quality check. 
The amounts in the last column are estimates of the potential budget covered at EU level 
including both EU and national co-financing. This applies the percentage from the first 
column to the entire fund budget at EU level, extracted from the Cohesion Open Data 
Platform, except for the FNLCs in use (second rows for both lower and upper levels), 
where actual (not estimated) values are displayed. 

Table 82 Overview of FNLC in ERDF in 2021-2027 

(1) % of programme 
budget covered 

(2) Potential programme 
budget covered at EU 
level (EUR mio) 

Lower level 

Total FNLC mapped 
(in use + programmed) 

0.002% 

- of which: FNLC in use 

0.001% 

- of which: already 
reimbursed to 
beneficiaries 
Total FNLC mapped  
(in use + programmed) 

0% 

0.666% 

Upper level 

- of which: FNLC in use 

0.388% 

- of which: already 
claimed  

0% 

5  

4 

0  

2.175 

1.268 

0  

FNLC within ERDF funds account for some 0.002% of the total budget at the lower level, 
some EUR 5 million for the full ERDF budget in 2021-2027 and 0.7% at the upper level 
(EUR 2 billion). Based on the responses and complemented by data from the SFC, a 
significant portion of this amount refers to schemes already in use (EUR 4 million at the 
lower  level  and  EUR  1.3  billion  at  the  upper  level).  Looking  at  amounts  already 
reimbursed to beneficiaries and those claimed from the Commission, implementation is 
still ongoing. In neither case were there reports of amounts being reimbursed/claimed.  

The table below presents an overview of FNLC use at Member State level. The second 
column shows the percentage of the fund budget covered at the lower level, while the 

26 Article 53 (1) (f) of the CPR states that financing not linked to costs are possible at the lower level provided such 

grants are covered by a reimbursement of the Union contribution pursuant to Article 95. 

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programming periods 

third column covers schemes approved at the upper level. Figures are calculated as the 
ratio  between  the  amount  covered  by  the  FNLC  identified  through  the  study  and  the 
budgets of programmes that participated in the survey and passed the quality check. 

Table 83 – FNLC use in 2021-2027 at Member State level (ERDF) 

MS 

AT 

BE 
BG27 

CY 

CZ 
DE28 

DK 
EE29 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 
RO30 

SE 

SI 

SK 

Lower level 

Upper level 

Total FNLC mapped 

Total FNLC mapped 

0% 

0% 

20.54% 

0% 

No financial data 

No financial data 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

No reply 

0.12% 

0% 

0% 

0% 

0% 

10.72% 

0% 

0% 

0% 

0% 

1% 

0% 

0% 

0% 

0% 

0% 

0% 

3.49% 

0% 

No reply 

0.12% 

0% 

0% 

0% 

0% 

No financial data 

No financial data 

0% 

0% 

0% 

0% 

0% 

0% 

By  the  end  of  the  current  programming  period,  only  one  Member  State  (Latvia)  is 
expected  to  use  FNLC  at  the  lower  level  under  ERDF,  while  at  least  seven  Member 
States are expected to use FNLC at the upper level: Austria, Bulgaria, Cyprus, Greece, 
Italy, Latvia and Romania. Of the latter only Austria and Cyprus cover more than 10% of 

27 Bulgaria has an FNLC adopted for ERDF. Financial information on the scheme was limited. 

28 Germany has an FNLC scheme in the pipeline for ERDF. Financial information on the scheme was limited. 

29 Estonia has an FNLC scheme in the pipeline for ERDF. Financial information on the scheme was limited. 

30 Romania has an FNLC scheme funded by both ERDF and ESF+. Financial information is limited for the ERDF 

component.  

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programming periods 

their  ERDF  budget  using  FNLC  schemes.  Additionally,  Germany  and  Estonia  have 
schemes in the pipeline; however, financial information on these was not available to the 
study team. 

7.1.5.1. 

Types of FNLC used in 2021-2027 

The table below shows the use of Article 95 of the CPR and Article 37 of the CPR across 
Member  States  for  ERDF.  Until  September  2024,  there  were  no  delegated  acts  for 
REGIO  funds.  The  table  displays  the  ratio  between  the  amount  covered  by  FNLC 
identified  through  the  study  and  the  budgets  of  programmes  that  participated  in  the 
survey and passed the quality check. 

Table 84 – ERDF Type of FNLC in 2021-2027 

Lower level 

Upper level 

Article 95(4) 
CPR 
(Delegated 
acts) 
0% 
0% 

0% 

0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
No reply 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

MS 

AT 
BE 

BG 

CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Appendix 2 of 
Article 95  
CPR 

Appendix 2 of 
Article 37 
CPR 

0% 
0% 
No financial 
data 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
No reply 
0% 
0% 
0% 
0% 
0% 
No data 
0% 
0% 
0% 

0% 
0% 

0% 

0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
No reply 
0.12% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

Article 95(4) 
CPR 
(Delegated 
acts) 
0% 
0% 

0% 

0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
No reply 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

Appendix 2 of 
Article 95  
CPR 

Appendix 2 of 
Article 37 
CPR 

20.54% 
0% 
No financial 
data 
10.72% 
0% 
0% 
0% 
0% 
0.79% 
0% 
0% 
0% 
0% 
0% 
0% 
3.49% 
0% 
No reply 
0% 
0% 
0% 
0% 
0% 
No data 
0% 
0% 
0% 

0% 
0% 

0% 

0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
No reply 
0.12% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

At the upper level, almost all FNLC schemes have been adopted through Appendix 2 of 
Article 95 of the CPR, with only one Member State reporting a scheme through Appendix 
2 of Article 37 of the CPR (Latvia). The Latvian scheme is also the only one used at the 
lower level.  

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programming periods 

Figure 41 – Types of FNLC indicators to trigger payment in ERDF  

40%

20%

40%

Output only

Result only

Output & Result

Information from the survey and the SFC for six programmes (11 schemes)31 show four 
reported schemes using a combination of output and result-based indicators to trigger 
payments. In four schemes, these indicators are result-based only, while for two they are 
output-based. One scheme did not provide information on the indicators used. Examples 
of these indicators are listed in the boxes below. 

Box 4 – Examples of output-based indicators used in FNLC schemes 

-  Kilowatt hour 

-  Number of administrations adhering to the Staff Employment Agreement 

-  Number of public staff hires 

-  Number  of  Research  and  Development  infrastructures  supported  and  put  into 

operation under the respective funding agreement 

-  Number of working days offered to beneficiaries 

-  Regional projects carried out 

-  Training services provided 

Box 5 – Examples of result-based indicators used in FNLC schemes 

-  Estimated greenhouse gas emissions 

-  Performance improvement: improvement in the spending capacity of ERDF funds 

31 Out of these 11 schemes reported, 5 are from the same CCI in Italy, while 2 are from the same CCI in Austria. These 

schemes were counted separately as OPs reported the use of different indicators and amounts. 

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programming periods 

-  Performance  improvement:  percentage  change  in  projects  implemented  out  of 

those financed in the 2021-27 programming compared to the 2014-20 

-  Percentage increase in the absorption of ERDF funds in selected sectors  

-  Total energy saved from households after the energy upgrade 

Survey data also indicates that most of the FNLC schemes do not include an established 
adjustment/update  methodology.  Only 
incorporating 
adjustment mechanisms based on indicators. However, only one programme disclosed 
the  indicator  used  to  adjust  amounts,  which  involved  a  price  review  informed  by 
environmental promotion reports from previous years.  

two  programmes  reported 

7.1.5.2. 

Specific objectives covered by FNLC in 2021-2027 

The  table  below  shows  the  use  of  FNLC  schemes  across  each  Specific  Objective 
identified  through  the  survey.  Figures  are  shown  as  percentages  of  FNLC  schemes 
reported for each Specific Objective divided by the total number of reported FNLCs. Each 
FNLC can cover multiple Specific Objectives.  

Table 85 – Coverage of ERDF Specific Objectives per FNLC 

Specific Objectives 

1.1 - Enhancing research and innovation 

1.2 - Reaping the benefits of digitisation 

1.3 - Growth and competitiveness of SMEs 

1.4 - Skills for smart specialisation and transition 

1.5 - Digital connectivity 

2.1 - Energy efficiency 

2.2 - Renewable energy 

2.3 - Smart energy systems 

2.4 - Climate change adaptation 

2.5 - Sustainable water 

2.6 - Circular economy 

2.7 - Nature protection and biodiversity 

2.8 - Sustainable urban mobility 

3.1 - Sustainable TEN-T 

3.2 - Sustainable transport 

4.1 - Labour market infrastructure 

4.2 - Education and training infrastructure 

4.3 - Integration of marginalised communities 

4.4 - Integration of third country nationals 

4.5 - Access to health care 

4.6 - Culture and sustainable tourism 

5.1 - Integrated development in urban areas 

% of FNLC schemes 
covering the Specific 
Objective 
9% 

0% 

0% 

0% 

0% 

18% 

9% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

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programming periods 

5.2 - Integrated development in rural and coastal areas 

FNLC Schemes with no Specific Objective informed by respondents 

0% 

64% 

Of the ERDF FNLC schemes which passed the quality checks, the most common relate 
to energy efficiency (SO 2.1), in two reported schemes. One scheme enhance research 
and innovation (SO 1.1) and one relates to renewable energy (SO 2.2). Seven schemes 
did  not  have  any  Specific  Objective  noted  by  survey  respondents,  as  they  refer  to 
Technical Assistance projects.32 

7.1.5.3. 

Advantages, challenges and reasons for not using FNLC 

The  figure  below  provides  a  qualitative  analysis  of  FNLC  advantages,  as  reported  by 
managing  authorities  in  our  survey.  Respondents  highlighted  key  benefits,  notably 
reduced  errors  and  financial  corrections  or  other  corrective  actions,  as  well  as  the 
simplicity  and  ease  of  compliance  checks,  both  of  which  were  rated  as  high/medium 
priority by over 80% of respondents.  

Additionally,  over  70%  of  managing  authorities  identified  the  reduced  administrative 
burden, their ability to focus more on concrete outputs and results and the opportunity to 
reallocate  resources  to  other  activities,  such  as  performance  monitoring  as  having 
medium or high relevance. 

Figure 42 – Key advantages of FNLC (ERDF) (values in %) 

LESS ADMINISTRATIVE BURDEN

14

14

14

57

SIMPLER COMPLIANCE

14

43

43

LOWER ERROR RATE

14

57

29

EASY TO APPLY FOR BENEFICIARIES

29

29

14

29

FOCUS ON OTHER ACTIVITIES

14

14

43

29

MORE FOCUS ON RESULTS

14

14

29

43

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

Figure 43 outlines reasons for not using FNLC schemes, with the primary concern being 
a  lack  of  information  on  how  to  design  and  implement  such  schemes;  75%  of 

32 Please note that out of these 7 schemes reported, 5 are from the same CCI. They were counted separately as they 

reported the use of different indicators. 

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programming periods 

respondents  rated  this  as  medium/high  importance.  Following  closely,  70%  cited  the 
administrative burden of designing FNLC schemes as a significant issue. 

Other  concerns  include  legal  uncertainty  surrounding  FNLC  schemes,  the  perception 
they  do  not  offer  clear  benefits, they  are  too risky  and their  perceived  unsuitability for 
certain programmes. Each of these factors was rated as medium/high priority by at least 
60% of respondents. 

Figure 43 – Key reasons for not using FNLC (ERDF) (values in %) 

BURDENSOME

16

14

39

31

LACK OF INFORMATION

13

13

32

42

LEGAL UNCERTAINTY

18

21

35

26

NOT OBVIOUS BENEFITS

22

16

38

25

NOT SUITABLE FOR THE PROGRAMME

19

19

24

37

RISK OF SYSTEMIC IMPACT

27

20

43

10

TOO RISKY

20

18

39

23

OTHER REASONS

91

6
1
2

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

The  figure  below  highlights  key  challenges  faced  by  managing  authorities  when 
developing  FNLC  schemes.  Two  concerns  stand  out:  legal  uncertainty  surrounding 
FNLC schemes, rated as a medium/high priority by over 85% of respondents and the 
lack of guidance and practical examples on designing FNLC methodologies, including 
defining indicators and setting up results or conditions, rated as highly relevant by 71% 
of respondents. 

Other important but less prominent issues include the perception that FNLC schemes 
are  complicated  and  difficult  to  implement,  difficulties  in  identifying  suitable  types  of 
operations, insufficient data for developing methodologies and a lack of knowledge and 
expertise  within  the  programme  authority.  Each  of  these  issues  was  rated  as 
medium/high importance by over half the respondents. 

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programming periods 

Figure 44 – Key challenges faced in developing FLNC (ERDF) (values in %) 

COMPLICATED AND DIFFICULT

14

29

DIFFICULT TO IDENTIFY SUITABLE
OPERATIONS

14

29

LACK OF DATA

29

14

43

43

43

14

14

14

LACK OF GUIDANCE

14

14

71

LACK OF KNOWLEDGE

14

29

29

29

LACK OF RESOURCES

14

43

29

14

LEGAL UNCERTAINTY

14

29

57

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

7.1.5.4. 

Audit authority involvement in defining FNLC 

The figure below shows the audit authority involvement in defining the FNLCs from the 
survey of stakeholders. In over 90% of reported schemes, managing authorities reported 
that  the  audit  authority  was  consulted  informally  without  conducting  a  formal 
assessment.33  The  remainder  had  a  formal  ex  ante  assessment.  No  managing 
authorities reported a lack of consultation with the audit authority. 

Figure 45 – Involvement of audit authority in the FLNC (ERDF) 

THE AUDIT AUTHORITY WAS NOT 
CONSULTED

0%

THE AUDIT AUTHORITY WAS 
CONSULTED INFORMALLY BUT DID 
NOT CARRY OUT A FORMAL 
ASSESSMENT OF THE FNLC

THE AUDIT AUTHORITY COMPLETED 
A FORMAL EX ANTE ASSESSMENT

9%

91%

33 Please note that Article 95 of the CPR does not request a formal assessment. 

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programming periods 

7.2. 

Use of SCO in CF 

7.2.1. 

Key findings 

The table below summarises the uptake of simplification measures covered by this study 
across two programming periods.  

The first column shows the use of simplification measures at both lower and upper levels 
during the 2014–2020 period. The second column presents the coverage of simplification 
measures mapped by this study for the 2021–2027 programming period, combining ‘in 
use’ and ‘programmed’ schemes. 

For  both  programming  periods  and  for  both  levels,  the  table  displays  uptake  as  a 
percentage  of the total ERDF budget. It  also shows  uptake from the total  CF budget, 
excluding the portion covered by financial instruments, for which SCOs and FNLC are 
not applicable. 

Table 86 – The use of simplification measures under CF 

Coverage at 
lower level 

Coverage at 
upper level 

Total budget 

Excluding financial 
instruments 

Total budget 

Excluding financial 
instruments 

2014-2020 

2021-2027 

SCOs 

0.5% 

0.5% 

- 

- 

SCOs 

2.3% 

2.9% 

0.7% 

0.6% 

7.2.2. 

Use of SCOs in 2014-2020 

The table below covers SCO use under CF in 2014-2020.   

The first row shows the budget covered by SCOs by the end of the programming period. 
The next row details the amount covered by operations below EUR 100 000.  

The percentage is based on programme budgets covered by SCOs identified through 
the study. For more detail, refer to the first and second steps of the process outlined in 
Chapter  1.4.  The  amounts  in  the  last  column  are  estimates  of  the  potential  budget 
covered  at  EU  level  (including  both  EU  and  national  co-financing).  This  applies  the 
percentage from the first column to the entire CF budget (including national co-financing) 
at EU level. For more detail, refer to the third step of the process outlined in Chapter 1.4.  

Table 87 – SCO use in CF in 2014-2020 

(1) % of OP 
budget covered 

(2) Estimated OP budget 
covered at EU level (EUR bn) 

SCOs 

0.5% 

0.375  

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SCO use under CF accounted for some 0.5% of the CF budget (EUR 375 million).  

The table below shows SCO use at Member State level.  

Table 88 –SCO use under CF in 2014-2020 by Member State 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

SCOs 
- 

- 

0.5% 

5.7% 

0.0% 

- 

- 

1.6% 

2.6% 

- 

- 

- 

0.9% 

0.2% 

- 

- 

4.3% 

- 

4.2% 

10.1% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

- 

As seen in the table above, at the end of the 2014-2020 period, only Malta covered more 
than 10% of their CF budget using SCOs. At least six Member States do not use SCOs 
under CF: Czechia, Poland, Portugal, Romania, Slovenia and Slovakia. 

7.2.2.1. 

Types of SCO used in 2014-2020 

The table shows the use of flat rate, unit cost and lump sum SCOs across Member States 
as the percentage of the total programme budget covered by each type of SCO. 

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programming periods 

Table 89 – CF Type of SCO in 2014-202034 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

TOTAL* 

- 

- 

0.5% 

0.7% 

0.0% 

- 

- 

0.0% 

0.1% 

- 

- 

- 

0.1% 

0.2% 

- 

- 

0.3% 

- 

0.1% 

0.0% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

- 

0.1% 

- 

- 

0.0% 

5.0% 

0.0% 

- 

- 

1.6% 

2.6% 

- 

- 

- 

0.9% 

0.0% 

- 

- 

4.0% 

- 

0.0% 

0.0% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

- 

0.3% 

- 

- 

0.0% 

0.0% 

0.0% 

- 

- 

0.0% 

0.0% 

- 

- 

- 

0.0% 

0.0% 

- 

- 

0.0% 

- 

4.1% 

10.1% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

- 

0.1% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

Among Member States using SCOs, unit costs are the most commonly used. In 5 of the 
8  Member  States  that  use  SCOs,  unit  costs  predominate.  At  the  EU  level,  unit  costs 
cover 0.3%. 

34 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

7.2.2.2. 

Thematic objectives covered by SCOs in 2014-2020 

The table below shows the distribution of SCOs across Thematic Objectives identified 
through the CF survey. The percentages total more than 100% because each SCO can 
cover multiple Thematic Objectives. 

Table 90 – Coverage of CF Thematic Objectives by SCOs 

Thematic objective 

% of SCOs 

TO 4: Supporting the shift towards a low-carbon economy 
TO 5: Promoting climate change adaptation, risk prevention and 
management 
TO 6: Preserving and protecting the environment and promoting 
resource efficiency 
TO 7: Promoting sustainable transport and removing bottlenecks in 
key network infrastructures 
TO 11: Enhancing the capability of public authorities and efficient 
public administration 

33% 

19% 

44% 

26% 

0% 

Many SCOs (44%) were used for operations preserving and protecting the environment 
and promoting resource efficiency (TO 6). Furthermore, 33% and 26% respectively of 
the schemes were supporting the shift towards a low-carbon economy through TO 4 as 
well  as  for  promoting  sustainable  transport  and  improving  network  infrastructures 
through TO 7.  

7.2.2.3. 

Beneficiaries covered by SCOs in 2014-2020 

The  table  below  illustrates  the  distribution  of  SCOs  across  types  of  beneficiaries 
identified through the CF survey. The total is more than 100% because each SCO can 
cover multiple beneficiaries. 

Table 91 – Beneficiaries reimbursed through SCOs for CF operations 

Type of beneficiary 

% of SCOs 

National authorities 

Municipalities 

Households 

Regional authorities 

Associations/ NGOs 

SMEs 

Micro-enterprises 

Large enterprises 

Universities 

Health institutions 

56% 

26% 

26% 

19% 

11% 

11% 

4% 

4% 

4% 

5% 

Most  SCOs  (56%)  were  used  for  CF  operations  implemented  by  national  authorities. 
Other major beneficiaries were municipalities and households (26%). 

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programming periods 

7.2.2.4. 

Types of costs covered by SCOs in 2014-2020 

The  table  below  shows  the  distribution  of  SCOs  among  the  types  of  costs  identified 
through  the  CF  survey.  The  total  is  more  than  100%  because  each  SCO  can  cover 
multiple costs. 

Table 92 – Types of costs covered by SCOs 

Type of cost 

Direct costs 

Indirect costs 

All costs of the operation 

% of SCOs 

50% 

38% 

21% 

50%  of  the  SCOs  covered  direct  costs  from  CF  operations  and  38%  covered  indirect 
costs. In addition, 21% covered all costs of the operations.  

7.2.3. 

Use of SCOs in 2021-2027 

The table below covers SCO use under CF in 2021-2027. 

The first four rows present SCOs at the lower level. The first row shows the coverage of 
SCOs  mapped  in  this  study,  aggregating  ‘in  use’  and  ‘programmed’  schemes.  The 
subsequent three rows provide a breakdown of the total already covered by SCOs and 
the portion already reimbursed to beneficiaries using SCOs. 

The fourth and fifth and rows focus on SCOs at the upper level approved under Article 
94(2)  of  the  CPR.  The  fifth  row  presents  the  overall  coverage,  aggregating  schemes 
submitted to the Commission and those programmed. The sixth row details the amount 
covered by schemes already submitted to the Commission. 

The  percentage  is  the  share  covered  by  SCOs  of  the  budgets  of  programmes  that 
participated  in  the  survey.  For  more  detail,  refer  to  the  first  and  second  steps  of  the 
process  outlined in  Chapter  1.4.  The  amounts  in the  last  column  are  estimates  of the 
potential budget covered at EU level including EU and national co-financing. This applies 
the percentage from the first column to the entire CF budget including co-financing at EU 
level (for more detail, refer to the third step of the process outlined in Chapter 1.4). The 
only  exception  concerns  amounts  for  schemes  in  use  approved  under  Article  94(2), 
which considers only the amounts declared by the survey respondents. 

Table 93 – SCO mapped in CF in 2021-2027 

(1) % of 
programme 
budget covered 

(2) Estimated programme 
budget covered at EU 
level (EUR bn) 

SCOs planned*  
(in use + programmed) 

Lower level 

- of which: SCOs in use 

- of which already reimbursed 
to beneficiaries 
SCOs planned 
(in use + programmed) 

Upper level 
Article 94(2) 

2.3% 

2.3% 

0.1% 

0.7% 

1.141 

1.127 

0.048 

0.309 

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programming periods 

SCOs in use 

0.7% 

0.309 

SCO  use  under  CF  accounts  for  over  EUR  1.1 billion,  some  2.3%  of  the  CF  budget. 
Based on the responses, almost all the expected impact at the end of the programming 
period is linked to existing schemes (EUR 1.1 billion). This suggests the effort required 
to  define  new  SCOs  by  programme  authorities  is  largely  complete.  Conversely, 
expenditure already reimbursed through SCOs (0.1%, or EUR 50 million) implies some 
delay  in  implementation  of  2021-2027  funds.  So  the  benefits  of  reduced  costs  and 
administrative  burden  will  only  be  felt  as  financial  absorption  of  the  programmes 
progresses. 

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
percentage of CF budget covered at the lower level, while the second column displays 
the share of the budget covered by schemes approved under Article 94(2) of the CPR.  

For some Member States (in blue in the table),  coverage for 2021-2027 in the ‘SCOs 
planned’ column is derived from 2014-2020. For more details see chapters 1.3 and 1.4. 

Member States that did not complete the questionnaire are marked in the table as ‘No 
reply,’ while those that provided only partial responses (e.g., no amounts) or submitted 
inconsistent responses which did not pass the quality check (see section 1.3) are marked 
as ‘Partial.’ 

Table 94 – SCO use in CF in 2021-2027 by Member State 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

Lower level  
SCOs mapped 
- 
- 
4.1% 
5.7% 

Upper level Article 94(2) 
SCOs mapped 
- 
- 
0.0% 
0.0% 

1.9% 

- 

- 

partial 

1.3% 

- 

- 

- 

5.9% 

7.9% 

- 

- 

15.9% 

- 

No reply 

7.1% 

- 

1.9% 

0.0% 

0.4% 

- 

- 

partial 

1.3% 

- 

- 

- 

0.0% 

0.0% 

- 

- 

15.9% 

- 

No reply 

0.0% 

- 

0.0% 

0.0% 

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programming periods 

Member State 

RO 

SE 

SI 

SK 

Lower level  
SCOs mapped 
0.0% 

Upper level Article 94(2) 
SCOs mapped 
0.0% 

- 

0.6% 

1.0% 

- 

0.0% 

0.0% 

As presented in the table above, by the end of the 2021-2027 period, five Member States 
are expected to cover more than 5% of their CF budget using SCOs: Cyprus, Croatia, 
Hungary,  Lithuania  and  Malta.  Three  Member  States  use  1%  or  less  of  their  budget: 
Portugal, Romania and Slovenia. 

7.2.3.1. 

Types of SCO used in 2021-2027 

The table below shows flat rate, unit cost and lump sum SCOs across Member States 
as the share of programme budget expected to be covered by each type.  

Table 95 – CF Type of SCO at lower level in 2021-202735 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Lower level 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

- 

- 

4.1% 

0.7% 

1.5% 

- 

- 

partial 

0.0% 

- 

- 

- 

5.9% 

5.9% 

- 

- 

- 

- 

0.0% 

5.0% 

0.4% 

- 

- 

partial 

1.3% 

- 

- 

- 

0.0% 

2.0% 

- 

- 

- 

- 

0.0% 

0.0% 

0.0% 

- 

- 

partial 

0.0% 

- 

- 

- 

0.0% 

0.0% 

- 

- 

0.3% 

- 

No reply 

7.0% 

15.5% 

- 

No reply 

0.1% 

0.0% 

- 

No reply 

0.0% 

35 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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programming periods 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Lower level 

Budget covered (%) 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

- 

1.9% 

0.0% 

0.0% 

- 

0.0% 

1.0% 

1.5% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

0.8% 

- 

0.0% 

0.0% 

0.0% 

- 

0.6% 

0.0% 

0.0% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

Among the Member States using SCO, flat rates are the most common. In 7 of the 10 
Member  States  that  use  SCOs,  flat  rates  are  predominate.  At  the  EU  level,  flat  rates 
cover 1.5% of the total budget, followed by unit costs (0.8%). Lump sums are not used 
by any Member State. 

The  table  below  details  the  types  of  Member  State  designed  SCO  approved  or 
programmed to be approved under Article 94(2) of the CPR. 

Table 96 – CF Type of SCO at the upper level in 2021-202736 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Upper level 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

- 

- 

0.0% 

0.0% 

0.0% 

- 

- 

partial 

0.0% 

- 

- 

- 

0.0% 

0.0% 

- 

- 

- 

- 

0.0% 

0.0% 

0.4% 

- 

- 

partial 

1.3% 

- 

- 

- 

0.0% 

0.0% 

- 

- 

- 

- 

0.0% 

0.0% 

0.0% 

- 

- 

partial 

0.0% 

- 

- 

- 

0.0% 

0.0% 

- 

- 

0.3% 

15.5% 

0.0% 

36 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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(FNLC) for the Common Provisions Regulation (CPR) Funds in the 2014-2020 and 2021-2027 
programming periods 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Upper level 

Budget covered (%) 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

- 

- 

- 

No reply 

No reply 

No reply 

0.0% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

0.7% 

0.0% 

- 

0.0% 

0.0% 

0.0% 

- 

0.0% 

0.0% 

0.0% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

The 2021-2027 CPR Regulation allows different approaches at lower and upper levels 
for SCOs. For instance, SCOs approved under Article 94 of the CPR can be used at the 
upper level, with a different type of SCO or even actual costs used at the lower level.  

Survey  data  highlights  that  all  schemes  adopted  under  Article  94  have  also  been 
implemented  at  the  lower  level.  The  table  below  focuses  on  the  lower  level  and 
highlights, for each Member State, the ‘weight’ of schemes approved under Article 94 in 
the financial flow to beneficiaries. The table shows the budget share covered by SCOs 
for beneficiaries, distinguishing between those exclusively for the lower level (Article 53) 
and those also used for payment requests to the Commission (Article 94). 

As an example, in the table, Czechia covered 1.9% of the CF budget with lower level 
SCOs,  of  which  1.5%  were  established  through  Article  53  and  the  remaining  0.4% 
through Article 94. 

Table 97 – CF use of SCOs at lower level under Article 53 vs Article 94 CPR 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

Total SCO planned 
(Article 53 + 94 CPR) 
- 
- 
4.1% 
5.7% 

1.9% 

- 

- 

partial 

1.3% 

- 

- 

- 

Lower level 

Of which Article 53 
CPR 
- 
- 
4.1% 
5.7% 
1.5% 
- 
- 
partial 
0.0% 
- 
- 
- 

Of which Article 94 
CPR 
- 
- 
0.0% 
0.0% 
0.4% 
- 
- 
partial 
1.3% 
- 
- 
- 

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programming periods 

Member State 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Total SCO planned 
(Article 53 + 94 CPR) 
5.9% 

7.9% 

- 

- 

15.9% 

- 

No reply 

7.1% 

- 

1.9% 

0.0% 

0.0% 

- 

0.6% 

1.0% 

Lower level 

Of which Article 53 
CPR 
5.9% 
7.9% 
- 
- 
0.0% 
- 
No reply 
7.0% 
- 
1.9% 
0.0% 
0.0% 
- 
0.6% 
1.0% 

Of which Article 94 
CPR 
0.0% 
0.0% 
- 
- 
15.9% 
- 
No reply 
0.1% 
- 
0.0% 
0.0% 
0.0% 
- 
0.0% 
0.0% 

7.2.3.2. 

Specific objectives covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  across  Specific  Objectives  identified 
through  the  CF  survey.  The  total  is  more  than  100%  because  each  SCO  can  cover 
multiple Specific Objectives. 

Table 98 – Coverage of CF Specific Objectives by the SCOs 

Specific Objective 

% of SCOs 

SO 2.1: Energy efficiency 

SO 2.2: Renewable energy 

SO 2.3: Smart energy systems 

SO 2.4: Climate change adaptation 

SO 2.5: Sustainable water 

SO 2.6: Circular economy 

SO 2.7: Nature protection and biodiversity 

SO 2.8: Sustainable urban mobility 

SO 3.1: Sustainable TEN-T 

SO 3.2: Sustainable transport 

Technical assistance 

30% 

30% 

0% 

9% 

23% 

14% 

14% 

14% 

16% 

5% 

16% 

Almost a third of the SCOs (30%) are used in CF operations regarding energy efficiency 
and renewable energy (SO 2.1 and SO 2.2). Furthermore, 23% are used for operations 
related to sustainable water (SO 2.5). SO 2.3 which concerns smart energy systems is 
not covered at all. 

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7.2.3.3. 

Beneficiaries covered by SCOs in 2021-2027 

The  table  below  illustrates  the  distribution  of  SCOs  among  types  of  beneficiaries 
identified through the CF survey. The total is more than 100% because each SCO can 
cover multiple beneficiaries. 

Table 99 – Beneficiaries reimbursed through SCOs for CF operations 

Type of beneficiary 
National authorities 
Municipalities/ Local authorities 
NGOs/Associations 
Regional authorities 
Large enterprises 
Health institutions 
SMEs 
Research centres/ Universities 
Households 
Micro-enterprises 

% of SCOs 
25% 
22% 
13% 
9% 
9% 
6% 
6% 
6% 
6% 
3% 

Most of the SCOs are used for CF operations implemented by national authorities (25%), 
municipalities/local authorities (22%) and NGOs/associations (13%).  

7.2.3.4. 

Types of costs covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs across types of costs identified through 
the CF survey. The total is more than 100% because each SCO can cover multiple costs. 

Table 100 – Types of costs covered by the SCOs 

Type of cost 

Direct costs 

Indirect costs 

All eligible costs other than staff  

All costs of the operation 

% of SCOs 

81% 

25% 

9% 

6% 

81% of the SCOs are being used to cover all the direct costs from CF operations and 
25% to cover indirect costs. Such costs are mostly covered by off-the-shelf SCOs. Only 
6% of the SCOs cover all costs of the operations. 

7.2.4. 

CF programme authorities’ perceptions of SCOs 

7.2.4.1. 

Advantages and challenges related to SCO 

This section presents qualitative inputs from respondents regarding advantages of SCO 
schemes  as  well  as  issues  encountered  when  developing  them.  It  also  includes  the 
feedback of respondents did not use any SCO. 

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Figure 46 – Advantages of SCO schemes for CF programme authorities (values 
in %) 

S
S
E
L

Y
L
P
P
A
O
T
Y
S
A
E

I

E
V
T
A
R
T
S
N
M
D
A

I

I

R
E
L
P
M
S

I

R
O
R
R
E
R
E
W
O
L

M
O
R
F
T
R
O
P
P
U
S

R
O
F

R
E
H
T
O
N
O
S
U
C
O
F
N
O
S
U
C
O
F
E
R
O
M

N
E
D
R
U
B

E
C
N
A
I
L
P
M
O
C

E
T
A
R

A
A
E
H
T

I

I

S
E
R
A
C
F
E
N
E
B

I

I

I

S
E
T
V
T
C
A

I

S
T
L
U
S
E
R

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

14-20

21-27

10

20

9

14

10

20

23

10

50

9

32

70

77

70

77

59

40

15

35

50

18

23

41

18

50

41

50

59

20

35

25

20

50

32

18

10

20

50

20

41

18

41

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

Between  2014-2020  and  2021-2027,  CF  programme  authorities  increasingly  viewed 
SCOs as effective in reducing error rates and corrective actions, simplifying compliance, 
easing  administrative  burden  and  improving  support  from  audit  authorities.  All 
programme  authorities  from  both  programming  periods  consider  that  SCO  schemes 
simplify the application process for beneficiaries. While half of them considered it highly 

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relevant in 2014-2020, this increased to 59% in 2021-2027. Overall, there is an increased 
perception of SCOs bringing benefits for programme authorities. 

The survey also mapped issues encountered by programme authorities when developing 
SCO schemes, as shown in the figure. 

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Figure 47 – Challenges faced in developing SCO schemes for CF programme 
authorities (values in %) 

I

E
V
T
A
G
E
N

F
O
K
C
A
L

M
O
R
F
K
C
A
B
D
E
E
F

L
A
G
E
L

F
O
K
C
A
L

F
O
K
C
A
L

I

L
A
C
R
O
T
S
H

I

I

E
V
T
A
N
R
E
T
L
A
O
N

A
A
E
H
T

I

Y
T
N
A
T
R
E
C
N
U

E
G
D
E
L
W
O
N
K

S
E
C
R
U
O
S
E
R

A
T
A
D

S
E
C
R
U
O
S

14-20

40

45

10

5

21-27

45

36

18

14-20

21-27

14-20

21-27

14-20

10

20

55

15

36

45

18

25

40

35

14

23

41

23

5

30

50

15

21-27

18

36

32

14

14-20

10

30

30

30

21-27

9

55

18

18

14-20

21-27

30

40

30

59

18

23

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

The  most  relevant  issue  is  a  lack  of  knowledge.  However,  this  perception  decreased 
between  2014-2020  and  2021-2027,  proving  that  experience  in  2014-2020  helps 
approaches  to  SCOs  in  the  current  programming  period.  The  share  of  programme 
authorities perceiving a lack of alternative sources and historical data as an issue also 

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significantly  decreased  across  the  two  programming  periods.  Nevertheless,  legal 
uncertainty  remains  important  for  some  two  thirds  of  programme  authorities  (67%  in 
2014-2020 and 70% in 2021-2027). However, support from the audit authority is not an 
issue for 40% of respondents in 2014-2020 and 42% in 2021-2027. 

In both 2014-2020 and 2021-2027, the main reasons programme authorities did not use 
any SCO is because they were not suitable for the programme, or the burden. 

7.2.5. 

Involvement of the audit authority in defining SCOs 

The  figure  below  presents  the  involvement  of  the  audit  authority  in  defining  SCO 
schemes developed under CF. It is noteworthy that the figures reflecting the involvement 
of AA in the development of SCO schemes during the 2021-2027 programming period 
pertain exclusively to schemes used at the lower level. For schemes at the upper level, 
it  should  be  emphasized  that  all  schemes  approved  under  Article  94  require  a  formal 
assessment by the AA. 

Figure 48 – Audit authority involvement in the definition of SCOs under CF 

THE AA WAS NOT CONSULTED

73%

50%

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

14%

20%

14%

30%

14-20

21-27

For  the  great  majority  of  SCO  schemes  developed  under  CF  in  2014-2020,  the  audit 
authority was either not consulted or consulted only informally (87%). There was a formal 
ex-ante  assessment  for  only  14%  of  the  schemes.  Data  from  2021-2027  shows  a 
change, since the audit authority completed a formal ex-ante assessment for almost one 
third of the SCO schemes (30%). Nevertheless, there was no consultation for 50% of the 
schemes. 

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7.3. 

Use of SCO in JTF 

The table below covers SCO use within JTF in 2021-2027. 

The first four rows present the SCOs mapped at the lower level. The first row shows the 
overall coverage of SCOs mapped in this study, aggregating ‘in use’ and ‘programmed’ 
schemes. The subsequent three rows provide a breakdown of the total already covered 
by SCOs, the amount covered by operations below EUR 200 000 and the portion already 
reimbursed to beneficiaries using SCOs. 

The fifth and sixth rows focus on SCOs at the upper level approved under Article 94(2) 
of the CPR. The fifth row presents the overall coverage, aggregating schemes already 
submitted to the Commission and those programmed. The sixth row details the amount 
covered by schemes that have already been submitted to the Commission. 

The percentage is the SCO share of the budgets of programmes that participated in the 
survey.  For  more  detail,  refer  to  the  first  and  second  steps  of  the  process  outlined  in 
Chapter 1.4. The amounts in the last column are estimates of potential budget coverage 
at EU level including EU and national co-financing. This applies the percentage from the 
first column to the entire JTF budget including co-financing at EU level (for more detail, 
refer to the third step of the process outlined in Chapter 1.4). The only exception is for 
amounts related to schemes in use approved under Article 94(2), which considers only 
the amounts declared by survey respondents.  

Table 101 – SCO mapped in JTF in 2021-2027 

(1) % of OP 
budget covered 

(2) Estimated OP budget 
covered at EU level 
(EUR bn)  

SCOs mapped  
(in use + programmed) 

- of which: SCOs in use 

- of which: SCOs mapped <200k 
(in use + programmed) 
- of which already reimbursed to 
beneficiaries 
SCOs mapped* 
(in use + programmed) 

SCOs in use 

Lower 
level 

Upper 
level 
Article 
94(2) 

10.4% 

10.3% 

1.6% 

0.5% 

2.3% 

2.2% 

2.808  

2.771 

0.421  

0.147  

0.340 

0.313 

SCOs under JTF use approximately 10% of the JTF budget (over EUR 2.8 billion). Based 
on data from respondents, a significant portion of the expected impact at the end of the 
programming period is linked to existing schemes. This suggests the effort required to 
define  new  SCOs  by  programme  authorities  is  largely  complete.  Expenditure  already 
reimbursed covered by SCOs (0.5%, or EUR 147 million) seems to confirm some delay 
in implementation of the 2021-2027 funds. This suggests the benefits of reduced costs 
and  administrative  burden  will  only  be  felt  as  financial  absorption  of  the  programmes 
progresses. Small operations cover EUR 0.4 billion of the EUR 3 billion total.  

The  table  below  shows  SCO  use  at  Member  State  level.  The  first  column  shows  the 
percentage  of  JTF  budget  covered  at  the  lower  level.  The  second  column  details  the 
portion of lower level SCOs for operations under EUR 200 000, providing an estimate of 

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the impact of mandatory SCOs for small operations. The third column displays the share 
of total budget covered by schemes approved under Article 94(2), 

Member States that did not complete the questionnaire are marked in the table as ‘No 
reply,’ while those that provided only partial responses (e.g., not supplying quantitative 
data on amounts) or submitted inconsistent responses (i.e., those that did not pass the 
quality check, see section 1.3) are marked as ‘Partial.’ 

Table 102 –SCO use in JTF in 2021-2027 by Member State 

Member 
State 
AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Lower level 

SCOs mapped 

26.7% 
7.3% 
No reply 
4.0% 
14.4% 
partial 
22.3% 
No reply 
No reply 
No reply 
39.8% 
8.2% 
partial 
8.0% 
8.3% 
No reply 
0.9% 
54.0% 
No reply 
7.0% 
18.0% 
9.0% 
No reply 
0.9% 
22.6% 
No reply 
1.0% 

Of which SCOs 
<200k 
26.7% 
0.0% 
No reply 
0.0% 
0.2% 
partial 
0.0% 
No reply 
No reply 
No reply 
19.7% 
0.1% 
partial 
0.0% 
0.6% 
No reply 
0.0% 
5.4% 
No reply 
0.0% 
0.0% 
0.7% 
No reply 
0.6% 
1.9% 
No reply 
0.0% 

Upper level 
Article 94(2) 

SCOs mapped 

26.7% 
2.0% 
No reply 
3.5% 
0.0% 
partial 
0.0% 
No reply 
No reply 
No reply 
0.0% 
6.4% 
partial 
0.0% 
0.0% 
No reply 
0.9% 
0.0% 
No reply 
0.0% 
18.0% 
0.0% 
No reply 
0.0% 
0.0% 
No reply 
0.0% 

As seen in the table above, by the end of the 2021-2027 period two Member States are 
expected  to  cover  more  than  30%  of  their  JTF  budget  using  SCOs:  Finland  and 
Luxembourg. Luxembourg is the only Member State where SCO covers more than half 
the  JTF  budget  (54%).  Four  Member  States  use  SCOs,  but  for  less  than  5%  of  the 
budget: Cyprus, Lithuania, Romania and Slovakia.  

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7.3.1. 

Types of SCO used in 2021-2027 

The  table  below  illustrates  the  use  of  flat  rate,  unit  cost  and  lump  sum  SCOs  across 
Member States as the percentage of total programme budget expected to be covered by 
each type of SCO. 

Table 103 – JTF Type of SCO at the lower level in 2021-202737 

Member State 

Flat Rate 

Lower level 

Budget covered (%) 
Unit Cost 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

TOTAL* 

0.0% 

5.3% 

No reply 

0.5% 

6.9% 

partial 

19.1% 

No reply 

No reply 

No reply 

15.2% 

1.8% 

partial 

2.3% 

8.3% 

No reply 

0.3% 

0.0% 

No reply 

7.0% 

0.1% 

7.1% 

No reply 

0.9% 

9.4% 

No reply 

1.0% 

5.0% 

26.7% 

2.0% 

No reply 

3.5% 

6.3% 

partial 

3.2% 

No reply 

No reply 

No reply 

12.9% 

6.4% 

partial 

5.7% 

0.0% 

No reply 

0.6% 

54.0% 

No reply 

0.0% 

17.8% 

1.6% 

No reply 

0.0% 

11.2% 

No reply 

0.0% 

4.5% 

Lump Sum 

0.0% 

0.0% 

No reply 

0.0% 

1.3% 

partial 

0.0% 

No reply 

No reply 

No reply 

11.7% 

0.0% 

partial 

0.0% 

0.0% 

No reply 

0.0% 

0.0% 

No reply 

0.0% 

0.0% 

0.3% 

No reply 

0.0% 

1.9% 

No reply 

0.0% 

0.9% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

37 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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Among the Member States using SCOs, there are two predominant approaches. In nine 
Member States flat rates are the most commonly used, while in the other eight unit costs 
are more prevalent.  

At  EU  level,  flat  rates  have  slightly  more  impact,  covering  5%  of  the  JTF  budget, 
compared to 4.5% covered by unit costs.  Lump sums are more limited, with only four 
Member States implementing them. 

For SCOs at the upper level, as shown in the table below, all schemes covered under 
Article 94(2) of the CPR in the JTF relate to unit costs. 

Table 104 – JTF Type of SCO at the upper level in 2021-202738 

Member State 

Flat Rate 

Unit Cost 

Lump Sum 

Upper level 

Budget covered (%) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

0.0% 

0.0% 

No reply 

0.0% 

0.0% 

partial 

0.0% 

No reply 

No reply 

No reply 

0.0% 

0.0% 

partial 

0.0% 

0.0% 

26.7% 

2.0% 

No reply 

3.5% 

0.0% 

partial 

0.0% 

No reply 

No reply 

No reply 

0.0% 

6.4% 

partial 

0.0% 

0.0% 

0.0% 

0.0% 

No reply 

0.0% 

0.0% 

partial 

0.0% 

No reply 

No reply 

No reply 

0.0% 

0.0% 

partial 

0.0% 

0.0% 

No reply 

No reply 

No reply 

0.3% 

0.0% 

0.6% 

0.0% 

0.0% 

0.0% 

No reply 

No reply 

No reply 

0.0% 

0.1% 

0.0% 

0.0% 

17.8% 

0.0% 

0.0% 

0.0% 

0.0% 

No reply 

No reply 

No reply 

0.0% 

0.0% 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

0.0% 

0.0% 

0.0% 

No reply 

0.0% 

38 In some cases, the total of the values reported in each row (i.e., the sum of the percentages for each type of SCO in 
a given Member State) may not precisely match the corresponding value for that Member State in the previous 
table. These discrepancies result from the rounding of decimal figures 

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TOTAL* 

0.0% 

2.3% 

0.0% 

* The ‘total’ row displays the percentage of the budget covered by SCOs at EU level. 

The 2021-2027 CPR Regulation allows different approaches at lower and upper levels 
for SCOs. For instance, SCOs approved under Article 94 can be used at the upper level, 
with a different type of SCO or even actual costs used at the lower level.  

Survey  data  highlights  that  all  schemes  adopted  under  Article  94  have  also  been 
implemented  at  the  lower  level.  The  table  below  focuses  on  the  lower  level  and 
highlights, for each Member State, the ‘weight’ of schemes approved under Article 94 in 
the financial flow to beneficiaries. The table shows the budget share covered by SCOs 
for beneficiaries, distinguishing between those exclusively for the lower level (Article 53) 
and those also used for payment requests to the Commission (Article 94). 

For example in Cyprus, 4.0% of the JTF budget  is covered by lower level SCOs, of which 
0.5% are established through Article 53 and the remaining 2% through Article 94(2). 

Table 105 – JTF use of SCO at lower level under Article 53 vs Article 94 CPR 

Member State 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

Lower level 

Total SCO planned (Article 53 
+ 94 CPR) 
26.7% 

Of which Article 53 
CPR 
0.0% 

Of which Article 94 
CPR 
26.7% 

7.3% 

No reply 

4.0% 

14.4% 

No reply 

22.3% 

No reply 

No reply 

No reply 

39.8% 

8.2% 

No reply 

8.0% 

8.3% 

No reply 

0.9% 

54.0% 

No reply 

7.0% 

18.0% 

8.7% 

No reply 

0.9% 

22.6% 

No reply 

5.3% 

No reply 

0.5% 

14.4% 

No reply 

22.3% 

No reply 

No reply 

No reply 

39.8% 

1.8% 

No reply 

8.0% 

8.3% 

No reply 

0.0% 

54.0% 

No reply 

7.0% 

0.0% 

8.7% 

No reply 

0.9% 

22.6% 

No reply 

2.0% 

No reply 

3.5% 

0.0% 

No reply 

0.0% 

No reply 

No reply 

No reply 

0.0% 

6.4% 

No reply 

0.0% 

0.0% 

No reply 

0.9% 

0.0% 

No reply 

0.0% 

18.0% 

0.0% 

No reply 

0.0% 

0.0% 

No reply 

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SK 

1.0% 

1.0% 

0.0% 

7.3.2. 

Specific objectives covered by SCOs in 2021-2027 

The  table  below  shows  the  distribution  of  SCOs  across  Specific  Objectives  identified 
through  the  JTF  survey.  The  total  is  more  than  100%  because  each  SCO  can  cover 
multiple Specific Objectives.  

Table 106 – Coverage of JTF Specific Objectives by SCOs 

Specific Objective 

JSO 8.1: Just transition fund specific objective 

Technical assistance 

% of SCOs 

99% 

9% 

The great majority of SCOs (99%) are used for the JTF Specific Objective while 9% are 
for operations related to Technical Assistance. 

7.3.3. 

Beneficiaries covered by SCOs in 2021-2027 

The  table  below  illustrates  the  distribution  of  SCOs  among  types  of  beneficiaries 
identified through the JTF survey. The total is more than 100% because each SCO can 
cover multiple beneficiaries.  

Table 107 – Beneficiaries reimbursed through SCOs for JTF operations 

Type of beneficiary 

% of SCOs 

Municipalities/Local authorities 

Regional authorities 

National authorities 

NGOs/Associations 

63% 

53% 

45% 

1% 

The great majority (63%) are used for JTF operations implemented by municipalities or 
local authorities and 53% for operations implemented by regional authorities. Only 1% 
reimburse NGOs/associations. 

7.3.4. 

Types of costs covered by SCOs in 2021-2027 

The table below shows the distribution of SCOs among types of costs identified through 
the JTF survey. The percentages total more than 100% because each SCO can cover 
multiple costs. 

Table 108 – Coverage of JTF Specific Objectives by the SCOs  

Type of cost 

Direct costs 

Indirect costs 

All costs of the operation 

All eligible costs other than staff 

Only direct staff costs 

% of SCOs 
35% 
35% 
14% 
12% 
5% 

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Travel and accommodation 

2% 

Over  a  third  of  the  SCO  schemes  mapped  (35%)  cover  direct  and  indirect  costs. 
Schemes  covering  all  operational  costs  account  for  14%.  Additionally,  12%  of  the 
schemes  mapped  under  JTF  use  off-the-shelf  flat  rates  provided  under  Article  56(1) 
CPR. Finally, 5% and 2% of the schemes mapped respectively cover direct staff costs 
(only) and travel/accommodation costs. 

7.3.5. 

JTF programme authorities’ perceptions of SCO 

7.3.5.1. 

Advantages and challenges related to SCO 

This section presents qualitative inputs from respondents regarding advantages brought 
by SCOs as well as issues encountered when developing them. This section does not 
include  an  assessment  of  why  programme  authorities  decided  not  to  use  any  SCOs 
because all responses that passed the quality checked use them. 

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Figure 49 - Advantages of SCO schemes for JTF programme authorities in 2021-
2027 (values in %) 

LESS ADMINISTRATIVE BURDEN

9

3

38

50

SIMPLER COMPLIANCE

9

9

44

38

LOWER ERROR RATE

9

16

53

22

SUPPORT FROM THE AA

28

28

28

16

EASY TO APPLY FOR
BENEFICIARIES

13

16

31

41

FOCUS ON OTHER ACTIVITIES

9

44

31

16

MORE FOCUS ON RESULTS

16

25

38

22

1 = not relevant

2 = low relevance

3 = medium relevance 4 = high relevance

The  greatest  advantage  of  SCOs  for  JTF  programmes  is  the  reduced  administrative 
burden  (for  50%  of  respondents  this  is  highly  relevant).  This  is  followed  by  simplified 
compliance checking as well as an easier application process for beneficiaries. On the 
other hand, support from the audit authority was not relevant for 28% of the respondents. 

The survey also mapped issues encountered by programme authorities when developing 
the SCO schemes, as seen in the figure below. 

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Figure 50 - Challenges faced in developing SCO schemes for JTF programme 
authorities in 2021-2027  (values in %) 

NEGATIVE FEEDBACK FROM THE AA

47

38

16

LEGAL UNCERTAINTY

9

41

25

25

LACK OF KNOWLEDGE

25

44

16

16

LACK OF RESOURCES

44

19

19

19

LACK OF HISTORICAL DATA

19

28

31

22

NO ALTERNATIVE SOURCES

16

25

38

22

1 = not relevant

2 = low relevance

3 = medium relevance

4 = high relevance

For JTF programme authorities, legal uncertainty related to SCOs is the most relevant 
issue (highly relevant for 25% of respondents). This is followed by a lack of alternative 
sources,  historical  data  and  resources.  Many  respondents  (47%)  acknowledged  that 
negative feedback from the audit authority was not an issue. 

7.3.6. 

Involvement of the audit authority in defining SCOs 

The figure below presents the involvement of the audit authority in the definition of the 
SCO  schemes  developed  under  JTF.  It  is  noteworthy  that  the  figures  reflecting  the 
involvement  of  AA  in  the  development  of  SCO  schemes  during  the  2021-2027 
programming period pertain exclusively to schemes used at the lower level. For schemes 
at the upper level, it should be emphasized that all schemes approved under Article 94 
require a formal assessment by the AA. 

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Figure 51 - Audit authority involvement in the definition SCOs under JTF in 2021-
2027 

THE AA WAS NOT CONSULTED

THE AA WAS CONSULTED INFORMALLY
BUT DID NOT CARRY OUT A FORMAL
ASSESSMENT OF THE SCOs

24%

27%

THE AA COMPLETED A FORMAL EX ANTE
ASSESSMENT

49%

For many SCO schemes developed under JTF, the audit authority completed a formal 
ex-ante assessment (49%).  

7.4. 

REGIO Fund beneficiary perceptions of SCOs 

The survey of beneficiaries was conducted through July and August 2024 and resulted 
in 818 complete answers from respondents who benefited from ERDF/CF/Interreg/JTF 
funding. The figure below shows the types of beneficiaries responding to the survey.  

Figure 52 – Types of REGIO Funds beneficiaries who responded to the survey 

PUBLIC INSTITUTION/ADMINISTRATION

RESEARCH/EDUCATIONAL INSTITUTION

OTHER

ENTERPRISE

39%

24%

21%

19%

TRADE UNION/NGO/ASSOCIATION

11%

COC/BUSINESS SUPPORT ENTITIES

6%

NATURAL PERSON

1%

Almost  40%  of  the  respondents  were  public  institutions/administrations.  In  addition, 
respectively 24% and 19% of the respondents were research/educational institutions and 
enterprises. ‘Other’ includes cultural institutions and foundations. 

The  factsheet  below  presents  survey  data  and  shows  that  the  great  majority  of 
respondents (79%) were aware of SCOs (there were no responses on FNLC). Of those, 
85%  used  SCOs,  while  73%  received  training,  workshops,  or  guidelines  from  the 
managing authority explaining SCOs.  

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90%  of  the  REGIO  funding  beneficiaries  who  completed  the  survey  and  used  SCOs 
declared they benefit project management. Reduced administrative burden is the main 
benefit (57%), similar to programme authority inputs presented in previous sections. In 
addition, 38% of respondents agreed that SCOs enable more focus on the quality and 
results of the project.  

Figure 53 - Data collected through the survey concerning REGIO funding 
beneficiaries 

The  analysis  of  responses  to  the  open-ended  questions  on  lessons  learnt  and 
recommendations  to  encourage  the  wider  adoption  of  SCOs  highlights  a  strong 
appreciation  for  SCOs.  Most  respondents  noted  that  SCOs  significantly  simplify 
administrative processes and also enable a stronger focus on project results. 

Regarding  specific  recommendations  from  beneficiaries  of  REGIO  funds,  some 
respondents suggested using the flat rate provided under Article 56.1 of the CPR. Other 
recommendations focused on technical aspects, such as ensuring regular adjustments 
to  costs  to  avoid  misalignment  with  inflation  trends.  Additionally,  some  respondents 
emphasised the need for more training and guidance from programme authorities. 

The final section of the survey invited beneficiaries to share their views on barriers and 
obstacles  limiting  access  to  CPR  Funds.  According  to  REGIO  fund  beneficiaries,  the 
main  challenges  include  excessive  administrative  costs  and  an  overly  complex 
application process. In some cases, they also highlighted the difficulties NGOs and small 
organisations had in covering pre-financing and co-financing requirements of projects. 

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8. 

Annex – questionnaires  

Below are key components of the 13 web questionnaires. Five questionnaires assess 
the uptake of SCO/FNLC during the 2014-2020 programming period (ERDF/CF, ESF, 
EAFRD,  EMFF  and  Multifund)  and  eight  questionnaires  cover  the  current  2021-2027 
programming period (ERDF/CF, ESF+, JTF, AMIF, BMVI, EMFAF, ISF and Multifund). 

Two sets of questions address different levels of reimbursement. One for SCO/FNLC at 
the  lower  level  to  reimburse  expenditure  from  Member  States  to  beneficiaries,  in 
accordance  with  Article  53  of  the  CPR.  The  other  set  focuses  on  the  upper  level, 
reimbursement from the Commission to Member States as per Articles 94-95 of the CPR. 
As  outlined  in  subsequent  sections,  the  questionnaires  for  the  2014-2020  period 
generally exclude the upper level of reimbursement, with the exception of ESF. For ESF, 
the  questions  explore the use  of  Article 14(1)  of  Regulation  (EU)  1304/2013 covering 
reimbursement from the Commission. 

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8.1. 

2021-2027 questionnaire structures 

The  questionnaires  mapping  SCO/FNLC  use  for  the  2021-2027  period  have  three 
sections:  i)  for  SCOs  at the  lower  level,  ii)  for  SCOs  at  the  upper  level and iii)  FNLC. 
These  questionnaires  are  as  similar  as  possible  to  those  on  SCOs  in  the  2014-2020 
period.  This  eases  the  task  for  authorities  completing  both  questionnaires  (i.e.  those 
responsible for programmes under both the 2014-2020 and the 2021-2027 programming 
periods). It also enhances data comparability across the two periods.  

Figure 54: Structure of 2021-2027 questionnaires 

The sequence for completing the questionnaire was: 

1.  Lower level SCOs, where Member States reimburse beneficiaries; 

2.  Upper level SCOs, where the Commission reimburses Member States; 

3.  FNLC schemes.  

For each section, respondents enter the number of schemes used in the programme. 
The CPR does not define what constitutes a scheme. Therefore, the study team included 
examples and clarifications to help respondents understand the context and meaning of 
this query (see box below). 

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Clarifications on ‘number of schemes’ 

In  the  logic  of  the  questionnaire,  each  ‘SCO/FNLC  scheme’  must  be  attributed  to  a 
single indicator. This means that: 

With several SCOs under the same operation, each is a separate SCO. For example, 
if your Programme combines two SCOs to reimburse the total cost of the operation – 
e.g., (i) unit cost to cover direct staff costs and (ii) 40% flat rate to cover all other eligible 
costs  of  operations  –  these  are  two  schemes,  requiring  qualitative  and  quantitative 
information for each. 

If the same SCO (e.g., a flat rate of 7% to cover indirect costs) is used across various 
measures/operations, it is a single SCO scheme. 

The  questionnaire  was  structured  to  collect  data  on  schemes  that  are  'in  use'  or 
'programmed'.  Guidance  and  support  ensured  that  respondents  did  not  include 
information on SCOs that are merely 'under consideration'. 

Figure 55: Questionnaire for programme authorities 

Key question on the no. of SCOs 

The  web  platform  automatically  generates  a  page  for  each  scheme  declared  by  a 
respondent, organised into three groups: 

1.  The  type  of  SCO,  where  respondents  select  from  options  and  sub-options  to 

categorise each scheme accurately. 

2.  Details of measures, costs and beneficiaries covered by the SCO. 

3.  The amounts that each scheme covers. 

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Figure 56: Questionnaire for programme authorities 

Set of questions to identify the type of SCO 

Figure 57: Questionnaire for programme authorities 

Questions to identify measures and beneficiaries covered by the SCO 

As outlined in the following section, for each SCO used or programmed at the lower level, 
the final part of the questionnaire probed whether the same scheme is also employed at 
the upper level, to claim reimbursement from the Commission. If so, respondents were 
then asked quantitative questions on the scheme’s application at the upper level. 

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Figure 58: Questionnaire for programme authorities 

Set of quantitative questions aimed at gathering data on the amounts of budget covered by the scheme 

The  second  part  of  the  questionnaire  was  dedicated  to  SCOs  exclusively  used  or 
programmed at the upper level. This focussed on schemes not covered in the first part, 
which addressed SCOs used at both lower and upper levels. If the programme includes 
any additional SCO solely at the upper level, the questions cover those schemes, using 
the same logic as for SCOs at the lower level. 

Figure 59: Questionnaire for programme authorities 

Initial question of the second part of the survey 

The  only  differences  between  questions  in  the  first  and second  parts  were regulatory 
references between Article 53 and Article 94 of the CPR 2021-2027. Similarly, the third 
part focusing on FNLC followed a comparable logic, beginning with an initial question 
where respondents quantified the number of FNLC schemes in use or programmed. The 
survey then asked for information on measures and beneficiaries covered by the FNLC, 
characteristics of the FNLC and the amount covered (see the figures below). 

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Figure 60: Questionnaire for programme authorities 

Qualitative questions on FNLC 

Figure 61: Questionnaire for programme authorities 

Quantitative questions on FNLC 

8.2. 

2014-2020 questionnaire structures 

The  questionnaires  mapping  SCO  use  in  2014-2020  were  a  simplified  version  of  the 
2021-2027 questionnaires, since they did not include: 

-  a distinction between ‘in use’ and ‘programmed’ schemes, 

-  mapping SCOs at upper level, except for ESF. 

-  mapping of FNLC. 

The structure of the 2014-2020 questionnaires (apart from ESF) is presented in the figure 
below. 

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Figure 62: Structure of 2014-2020 questionnaires 

The questionnaires followed the same logic as the ones for 2021-2027. In each section, 
respondents were asked to specify the number of schemes implemented. Questions for 
each  scheme  were  followed  by  a  qualitative  assessment.  Both  ERDF/CF  and  ESF 
questionnaires included a further question to map whether the SCO was used to claim 
reimbursement from the Commission under the FAST CARE package, as set out in CPR 
2014-2020 Article 68(c). For the ESF questionnaire, an additional section mapped SCOs 
at  Commission  –  Member  State  (upper)  level  covering  SCO  use  under  Article  14(1) 
Regulation 1304/2013, following the same structure.  

Key differences between the questionnaires for different funds are the same as  in the 
2021-2027 questionnaires. For instance, for both EAFRD and EMFF it was important to 
concentrate data collection on SCOs in ‘investment measures’ (i.e. EAFRD non-IACS 
measures), avoiding predefined amounts for ‘surface or compensation measures’. 

The table below covers the questionnaires and was the basis of the web survey. 

Table 109 – Links to the questionnaires 

Questionnaire 

Link to the web survey 

AMIF 

https://www.t33.it/resources/383_SCO_FNLC_mapping/AMIF_21-27.pdf  

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Questionnaire 

Link to the web survey 

BMVI 

https://www.t33.it/resources/383_SCO_FNLC_mapping/BMVI_21-27.pdf  

EAFRD 

https://www.t33.it/resources/383_SCO_FNLC_mapping/EAFRD_14-20.pdf  

EMFAF 

https://www.t33.it/resources/383_SCO_FNLC_mapping/EMFAF_21-27.pdf  

EMFF 

https://www.t33.it/resources/383_SCO_FNLC_mapping/EMFF_14-20.pdf  

ERDF/CF 2014-2020 

https://www.t33.it/resources/383_SCO_FNLC_mapping/ERDF_CF_14-
20.pdf  

ERDF/CF 2021-2027 

https://www.t33.it/resources/383_SCO_FNLC_mapping/ERDF_CF_21-
27.pdf  

ESF 

https://www.t33.it/resources/383_SCO_FNLC_mapping/ESF_14-20.pdf  

ESF+ 

https://www.t33.it/resources/383_SCO_FNLC_mapping/ESF_21-27.pdf  

ISF 

JTF 

https://www.t33.it/resources/383_SCO_FNLC_mapping/ISF_21-27.pdf  

https://www.t33.it/resources/383_SCO_FNLC_mapping/JTF_21-27.pdf  

Multifund 2014-2020 

https://www.t33.it/resources/383_SCO_FNLC_mapping/MULTI_14-20.pdf  

Multifund 2021-2027 

https://www.t33.it/resources/383_SCO_FNLC_mapping/MULTI_21-27.pdf  

8.3. 

Structure of the questionnaire for beneficiaries 

The questionnaire to gather beneficiaries' perceptions of SCO and FNLC was structured 
to minimise the time required to complete it, while ensuring it captured their perceptions 
and  experience.  Following  the  initial  identification  section,  the  questionnaire  had  a 
preliminary general question to ascertain whether the respondent is aware of what SCOs 
and FNLC entail. The box below outlines the questions regarding SCOs and FNLC for 
both programming periods. 

Box 6 Beneficiary questionnaire on SCOs and FNLC  

Name of the respondent 

Email 

Please select the EU Fund you have benefited from 

Please indicate during which programming period you have benefited from such Fund: 

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Name of the Programme you benefited from: 

What type of beneficiary are you?  

Are you aware of the possibility to claim expenditures through simplified methods  – 
such as SCO and FNLC – in the context of CPR Funds? (YES/NO) 

Did you use any SCO/FNLC for the programming period (2014-2020 or 2021-2027)? 
(YES/NO) 

Did the managing authority/intermediate body explain SCO/FNLC to you by providing 
training, workshops, or guidelines? (YES/NO) 

Please  describe  the  type(s)  of  project(s)  where  the  SCO/FNLC  was  used  (OPEN 
QUESTION) 

Please indicate the type of SCO/FNLC adopted (OPEN QUESTION) 

Please  indicate  the  types  of  categories  of  cost  covered  by  the  SCO/FNLC  (OPEN 
QUESTION) 

Please  indicate  the  estimated  percentage  (%)  and  amount  (in  EURO)  of  grants 
received  as  beneficiary  of  one  of  the  Funds  covered  by  SCO/FNLC  (OPEN 
QUESTION) 

Did/do  the  use  of  SCO/FNLC  bring  any  benefit  in  the  management  of  the  project? 
(YES/NO). If yes, please specify (OPEN QUESTION) 

What lessons learnt / recommendations would you like to share to facilitate wider use 
of SCO? (OPEN QUESTION) 

In your  experience,  have you  encountered  any barriers/obstacles that  hindered the 
access to EU Funds? (YES/NO). If yes, please specify (OPEN QUESTION) 

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