COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2015/1017, (EU) 2021/523, (EU) 2021/695 and (EU) 2021/1153 as regards increasing the efficiency of the EU guarantee under Regulation (EU) 2021/523 and simplifying reporting requirements
Date: 2025-03-27
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EU aid, EU financial instrument, EU programme, disclosure of information, exchange of information, financing, investment project, investment promotion, investment protection

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.3.2025  SWD(2025) 84 final  Addendum to Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2015/1017, (EU) 2021/523, (EU) 2021/695 and (EU) 2021/1153 as regards increasing the efficiency of the EU guarantee under Regulation (EU) 2021/523 and simplifying reporting requirements (COM(2025)84) COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROEAN PARLIAMENT AND OF THE COUNCIL  amending Regulations (EU) 2015/1017, (EU) 2021/523, (EU) 2021/695 and (EU) 2021/1153 as regards increasing the efficiency of the EU guarantee under Regulation (EU) 2021/523 and simplifying reporting requirements {COM(2025) 84 final}  
 
 
Staff working document accompanying the proposal for an amendment to Regulations 

(EU) 2015/1017, (EU) 2021/523, (EU) 2021/695 and (EU) 2021/1153 as regards increasing 

the efficiency of the EU guarantee under Regulation (EU) 2021/523 and simplifying 

reporting requirements 

1. Introduction 

The InvestEU Programme is the largest risk-sharing instrument currently in place within the EU 

and its guarantee capacity should be increased to properly serve the current and emerging needs 

while focusing on financing higher risk and scale-up investment. 

As highlighted in his report, ‘The Future of European Competitiveness’, Mario Draghi emphasised 

that the transition to a low-carbon, resource-efficient, and circular economy will also be essential 

for securing the EU’s long-term economic prosperity, resilience, and competitiveness.1 However, 

to unlock the full potential of this transition, a cohesive and well-executed strategy will be crucial, 

including fostering the role of public and private finance in supporting the transition.  

Thanks to its partial provisioning and multiplier effect,  InvestEU offers a budget-wise efficient 

instrument  to  address  huge investment  needs in  priority areas by leveraging  public and private 

investment.  This  is  particularly  relevant  in  the  context  of  constrained  public  finances.  While 

InvestEU targets a broad range of key policy areas, there is a strong focus on investments which 

can support the objectives of the Competitiveness Compass, the Clean Industrial Deal and digital 

innovation  and  transition  including  support  for  start-ups  and  scale-ups.  InvestEU  is  a  versatile 

instrument and can serve policy areas according to priorities of the Union.  

As of June 2024,  InvestEU is  estimated to  have mobilised investments  of EUR 280 billion, of 

which EUR 201 billion (close to 70%) stem from the private sector. Close to 45% of the volume 

of operations signed under InvestEU are supporting the climate objective. The interim evaluation 

of the InvestEU Programme, published in September 20242, highlighted the need to consider ways 

to enhance the financial capacity of InvestEU in the remainder of the current Multiannual Financial 

1  M.  Draghi,  The  future  of  European  competitiveness,  2024,  available  at:  https://commission.europa.eu/topics/eu-
competitiveness/draghi-report_en#paragraph_47059 
2 
affairs/evaluation-reports-economic-and-financial-affairs-policies-and-spending-activities/interim-evaluation-
investeu-programme_en 

https://commission.europa.eu/about/departments-and-executive-agencies/economic-and-financial-

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Framework (MFF) and to reduce the administrative burden on key stakeholders. Moreover, the 

interim  evaluation  recommended  ensuring  continuity  in  the  financial  products  offered  to  the 

market  and  avoiding  a  stop-and-go  situation,  as  this  would  create  not  only  a  gap  in  the  much-

needed  Union  support  for  policy  priorities  but  would  also  add  complexity  for  financial 

intermediaries and final recipients. 

A  legislative  amendment  to  the  InvestEU  Regulation 3  is  proposed  to  simplify  reporting 

requirements under InvestEU and the European Fund for Strategic Investments (EFSI), to increase 

the EU guarantee available by EUR 2.5 billion underpinned by EUR 1 billion provisioning for the 

remainder of this MFF and to allow the use of existing resources more efficiently by consolidating 

and further enhancing combination of the InvestEU guarantee with the EFSI guarantee and the 

guarantee  available  under  two  legacy  financial  instruments  (i.e.  the  CEF  Debt  Instrument  and 

InnovFin Debt Facility), thus providing continued support to businesses and projects in the last 

two years of this MFF. The proposed changes are expected to mobilise around EUR 50 billion in 

private and public investment. 

Efficiency gains and simplifications will also be achieved through non-legislative measures. The 

Commission is engaging with the implementing partners of InvestEU and of legacy investment 

support programmes to reduce the reporting burden through contractual simplifications where no 

legislative amendment is needed. 

2. Estimates of savings from reporting simplifications  

Reporting simplifications are needed for InvestEU, EFSI and other legacy instruments to reduce 

the reporting burden on implementing partners, financial intermediaries and final recipients. Such 

simplifications will be implemented via legislative amendments to the InvestEU Regulation4 and 

to the EFSI Regulation, as well as via non-legislative means, and are expected to save around EUR 

350 million: 

3 COM(2025) 84 final, 26.2.2025. 
4 Certain  reporting  simplifications  reducing  the  frequency  of  reporting under  the InvestEU  Regulation  are  already 
being adopted by the co-legislators. The trilogues on the proposal were concluded in December 2024. 

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•  More than 90% of the estimated cost savings, i.e. around EUR 324 million, will stem from 

(a) the introduction of a waiver for transactions of an amount up to EUR 100 000 as regards 

the  key  performance/monitoring  indicators  (KPI/KMIs)  reporting,  and  (b)  an  adjusted 

application of the SME definition based on the proportionality principle, whereby in case 

of  market  conform  financial  products,  the  implementing  partners  may  only  take  into 

account the number of employees in the last annual or consolidated accounts instead of 

using the full analysis set out in the Commission SME Recommendation5, and for non-

market conform financial products, where considered appropriate, the guarantee agreement 

may derogate from the Commission SME Recommendation. The conservative estimate, 

based on the experience with EFSI, is that around 900 000 small business will benefit from 

these  measures  with  an  average  estimated  saving  of  around  EUR  360  per  SME, 

corresponding to 1.5 days of work. 

•  The decrease in the InvestEU implementing partners’ costs related to: (a) the possibility to 

replace the annual audit opinions on the management declarations by other independent 

means providing an equivalent level of assurance; (b) the introduction of a waiver for the 

reporting of KPIs/KMIs for small transactions which they no longer need to collect and 

process; and (c) the reduction of the frequency of the progress report from four to three 

times  per  year.  The  total  estimated  cost  savings  for  these  measures  amount  to  EUR  20 

million. 

•  The  decrease  in  the  European  Investment  Bank  (EIB)  Group  costs  related  to:  (a)  the 

reduction  of  the  frequency  of  the  EFSI  operational  and  risk  reports  from  quarterly  to 

annually  and  the  streamlining  of  their  content;  and  (b)  the  removal  of  the  obligation  to 

produce  the  yearly  EFSI/InvestEU  investment  barriers  report.  The  total  estimated  cost 

savings for these measures amount to around EUR 6 million. 

The Commission  estimates  were mainly  based on: (a) the number of final  recipients  supported 

under EFSI, the SME window in particular; and (b) the information and feedback received from 

the EIB Group,  as well  as  other implementing partners,  as  regards time  needed to  produce the 

5 Commission Recommendation 2003/361/EC of 6 May 2003 concerning the definition of micro, small and medium-
sized enterprises (OJ L 124, 20.5.2003, p. 36). 

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various  reports  requested  under  the  two  programmes,  their  average  hourly  costs  and,  where 

relevant, the amount of other costs when external service providers were used for the production 

of independent reports.  

3. Use of reflows to increase the EU guarantee 

The legislative amendment proposal also includes an increase in the EU guarantee available under 

InvestEU by EUR 2.5 billion, with the corresponding  provisioning of additional EUR 1 billion 

stemming from reflows becoming available in 2025, 2026 and 2027 from EFSI and other legacy 

instruments6. 

The increase of the EU guarantee is consistent with the objective of reaching the target InvestEU 

provisioning with  lower  contributions from  the voted  budget  appropriations in  2026  and 2027. 

Since the beginning of this MFF, reflows from financial instruments and the EFSI surpluses have 

been allocated to InvestEU and the Public Sector Loan Facility (PSLF).  

This  increase  of  the  EU  guarantee  will  support  the  mobilisation  of  around  EUR 25  billion  in 

additional private and public investment. The increased InvestEU capacity will be mainly used to 

finance higher risk activities in support of priority Union policies, such as the ones outlined in the 

Competitiveness Compass – covering tech sectors that will matter in tomorrow’s economy such 

as  digital  frontier  technologies  –  and  the  Clean  Industrial  Deal,  as  well  as  any  potential  new 

initiatives in priority areas such as defence industrial policy, dual-use activities or military mobility. 

More  specifically,  the  incremental  capacity  can  be  used  to  support  equity  and  quasi-equity  in 

highly innovative and risky projects, higher risk debt such as certain forms of subordinated debt, 

guarantee instruments, and other instruments to support the scaling up of innovative companies. 

The indicative distribution of the EU guarantee between the four policy windows is proposed to 

be  increased  proportionately  to  the  increase  of  the  EU  guarantee.  This  is  without  prejudice  to 

initiatives that may be taken in the coming months to meet compelling and urgent financing needs. 

The proposed increase for each policy window will be as follows: 

6 Those instruments are enumerated in Annex IV to the InvestEU Regulation. 

4 

 
 
 
 
 
 
2021 – InvestEU 

Regulation 

2025 – InvestEU 

Regulation 

amendment proposal 

InvestEU guarantee 

26 152 310 073  

28 652 310 073  

Sustainable Infrastructure Window (SIW) 

9 887 682 891  

10 832 884 564  

Research,  Innovation  and  Digitisation 

Window (RIDW) 

6 575 653 460  

7 204 245 489  

SME Window (SMEW) 

6 906 732 440  

7 566 973 583  

Social  Investment  and  Skills  Window 

(SISW) 

2 782 241 282  

3 048 206 437  

4. Combinations of the InvestEU guarantee with guarantee released from EFSI and legacy 

instruments 

An additional optimisation takes the form of a more efficient use of the EU guarantee by combining 

the  InvestEU  guarantee  with  support  from  the  Union  budget  under  EFSI  and  other  two  legacy 

financial instruments (i.e. the CEF Debt Instrument and InnovFin Debt Facility). This combination 

will  enable continued support to businesses and projects in the last two years of the investment 

period. In particular, the combination may support financial products or portfolios implemented or 

to be implemented by the EIB or the European Investment Fund (EIF) under InvestEU, including 

financial  products  and  portfolios  containing  exclusively  financing  and  investment  operations 

eligible under InvestEU. 

The combination allows for a proactive use of EU resources that otherwise may have remained 

under-used  and  will  be  deployed  by  the  EIB  Group,  the  sole  implementing  partner  for  EFSI, 

InnovFin Debt Facility and CEF Debt Instrument. The use of these resources in combination with 

the InvestEU guarantee enhances the overall guarantee capacity, however it  does not lead to an 

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increase in the total InvestEU guarantee available on top of the EUR 2.5 billion increase proposed 

by the Commission (see Section 3 of this Staff Working Document). 

The possibility of combining resources from InvestEU and the resources of legacy instruments 

already  exists  under  the  existing  InvestEU  Regulation  and  has  been  applied  for  two  EIB  debt 

portfolios under EFSI and InvestEU. The combinations lead to an increase of the risk-absorption 

capacity of the EU guarantee, which in turn increases the volume of new operations that could be 

supported under InvestEU. For example, an additional combination of EIB debt instruments with 

CEF Debt Instrument and InnovFin Debt Facility could be portrayed as shown below. The CEF 

Debt Instrument and InnovFin Debt Facility guarantee could also be used as a first loss piece. 

The  possibility  of  combination  will  be  further  simplified  in  order  to  maximise  flexibility  in 

integrating resources from legacy instruments and to optimise InvestEU financing. For example, 

in the case of EIF uncapped guarantees, that are at the core of SME financing for innovation and 

green and digital transition, the proposal is to combine the EU guarantee under InvestEU and the 

risk-bearing capacity of EFSI without merging the transactions originated with the support of EFSI 

into the portfolio originated under InvestEU (see picture below).  

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The  higher  risk-bearing  capacity  provided  by  the  Union  budget  will  also  allow  for  a  greater 

diversification  and  allow  the  EIB  and  the  EIF  to  increase  their  residual  risk  more  than 

proportionally (re-tranching  between first  loss piece and residual  risk), hence ensuring an  even 

higher level of new InvestEU financing. 

The implementation of the above changes will avoid a detrimental stop-and-go, that would have 

created a gap in the much-needed Union support to policy priorities and added complexity to the 

financial  intermediaries  and  final  recipients,  and  lead  a  significantly  higher  amount  of  new 

financing without increasing the budget made available to InvestEU and therefore a continuity in 

the offer to the market of financial products.  

The  combination  will  trigger  substantial  efficiency  gains  by  creating  the  possibility  for  an 

increased volume of guarantee cover to be provided for strategic investments in key Union priority 

areas. It will lead to an additional investment of around EUR 25 billion that can be expected to be 

mobilised and to an increased diversification of risks. 

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