REGULATORY SCRUTINY BOARD OPINION REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS The European Defence Fund: supporting the development of the defence capabilities of tomorrow Interim evaluation of the European Defence Fund
Date: 2025-06-17
Institutions: Directorate-General for Defence Industry and Space, European Commission
Subjects: EU programme, European defence policy, common security and defence policy, defence expenditure, fund (EU), innovation, military equipment, military research, research and development, technology

EUROPEAN COMMISSION 

Brussels, 5.5.2025 
SEC(2025) 169 final 

REGULATORY SCRUTINY BOARD OPINION 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE 
COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE 
COMMITTEE OF THE REGIONS 

The European Defence Fund: supporting the development of the defence capabilities of 
tomorrow Interim evaluation of the European Defence Fund 

{COM(2025) 299 final} 
{SWD(2025) 151 final} 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2025) 

Opinion 

Title: Evaluation/fitness check of the European Defence Fund 

Overall opinion: POSITIVE WITH RESERVATIONS 

(A) Policy context 

The  EUR  7.3  billion  European  Defence  Fund  (EDF)  is  the  EU’s  defence  research  and 
development  (R&D)  funding  programme  for  2021-2027  which  aims  to  strengthen  the 
competitiveness, efficiency, and innovation of the EU defence industry. It supports cross-
border collaboration, particularly among SMEs and mid-sized companies, and improves 
defence supply and value chains. The EDF is designed to integrate co-financing thereby 
leveraging national contributions. 

The  EDF  builds  on  two  precursor  programmes:  the  2017-2019  Preparatory  Action  on 
Defence Research (PADR) and the 2019-2020 European Defence Industrial Development 
Programme  (EDIDP).  In  line  with  Article  29  of  the  EDF  Regulation,  the  interim 
evaluation covers the period 30 June 2021 until 31 July 2024. 

(B) Key issues 

The Board notes the additional information provided in advance of the meeting and 
commitments to make changes to the report. 

However, the report still contains shortcomings. The Board gives a positive opinion 
with reservations because it expects the lead Service to rectify the following aspects: 

(1) The  analysis  of  the  performance  of  the  programme  is  not  framed  by  an 
intervention  logic  that  fit  for  the  purpose  of  the  evaluation.  The  specific 
objectives are insufficiently operationalised.  

(2) The report does not provide sufficient reassurance on the effectiveness of the 
monitoring and evaluation framework or that it will adequately support the 
final  evaluation.  The  data  and  data  collection  limitations  are  not  properly 
reflected in the conclusions.  

(3) The  presentation  of  the  findings  and  data  does  not  allow  for  a  robust 
appreciation of the programme's effectiveness and efficiency. It does not use 
possible  benchmarking  to  demonstrate  the  programme’s  benefits.  The  
Rhomolo-based projection of the  benefits is inappropriate for the purpose of 
the evaluation or the specificities of the defence sector.  

  ________________________________   
This opinion concerns a draft evaluation which may differ from the final version. 

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu 

 
 
 
(4) The conclusions do not reflect the outcome of the analysis in a balanced way. 

(C) What to improve 

1)  The report should review the programme’s intervention logic to ensure the European 
Defence  Fund's  (EDF)  specific  objectives  are  sufficiently  operationalised  to  be 
precise enough and measurable.  The report should reconstruct the intervention logic 
to include causal links between its elements, allowing for a better assessment of the 
programme's  progress  towards  success,  thereby  preparing  the  ground  for  the  final 
evaluation.  Against  this  backdrop,  the  report  should  discuss  the  validity  of  the 
indicators set  out  in  the Regulation’s Annex and  the programme’s monitoring  and 
evaluation  framework  to  ensure  they  are  fit  for  future  monitoring  and  capable  of 
providing  meaningful  results  at  the  time  of  the  final  evaluation.  This  includes 
assessing  the  framework's  ability  to  track  the  programme's  progress  and  propose 
possible  adjustments.  The  findings  on  evidence  gaps  on  monitoring  and  reporting 
arrangements should be reflected in the conclusions section.  In the lessons learned 
section of the report an analysis should be included whether and how the indicators 
in the Regulations’ Annex and the monitoring and evaluation framework should be 
amended. 

that  are  based 

inappropriately  on 

2)  The  report  should  better  link  the  findings  with  the  corresponding  evidence  and 
analytical  methods.  Given  its  wide  reliance  on  the  stakeholder  consultations,  the 
report  should  transparently  present  views  from  different  groups  and  data  from  all 
affected  parties,  including  non-participants  to  the  programme  whose  feedback  can 
provide valuable insights into the programming and implementation shortcomings.  
3)  Further, the report should review the parts of the effectiveness and efficiency analysis 
(and  corresponding  conclusions) 
the 
macroeconomic  projections  of  the  Rhomolo  model,  which  –  being  an  ex-ante 
methodology – is conceptually misplaced for demonstrating benefits in retrospective 
evaluations. The unsuitability of this model is further accentuated by the numerous 
specificities of the defence sector which are not adequately considered by the model. 
Instead, the  report  at  this stage  should establish  effectiveness  and efficiency using 
other methods, complementing the output indicators with a comparison with the pre-
programme situation in the defence industry and the national approach to R&D in the 
sector,  benchmarking  against  earlier  projects  or  approaches  and/or  explaining  the 
limitations  of  the  possible  points  of  comparison.  The  report  should  assess  key 
implementing modalities of the programme such as allocation of bonus points in the 
project selection phase.  Anecdotal evidence and flagship achievements, e.g. around 
the  prototypes  envisaged  and  under  development  within  the  pipeline  of  ongoing 
projects should be used to a greater extent to build the case as potential indicators of 
the future programme’s success. The report should also better present the nature and 
results  of  the  increased  cooperation  and  multinational  partnerships  in  innovation, 
discussing  value  added  of  reduced  fragmentation  and  increased  convergence  and 
impacts on competitiveness of the sector.  

4)  Regarding efficiency, the report should consider the costs associated with reporting 
and project coordination accruing to the stakeholders. It should discuss the lead time 
of  its  programming  phases,  accentuating  the  adequacy  of  the  framework  and 
identifying justified potential for improving efficiency.  The report should assess to 
what extent the programme allows for sufficient agility and reactivity in the evolving 

2 

 
 
 
dynamic geopolitical context with quickly emerging needs, notably through the lens 
of the Russian war of aggression against Ukraine. 

5)  The  report  should  draw  conclusions,  reflecting  the  outcome  of  the  analysis  of  the 

programme’s functioning, paving the way for the necessary adjustments.  

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

(D) Conclusion 

The  lead  Service  should  revise  the  report  before  launching  the  interservice 
consultation. 

Full title 

Interim evaluation of the European Defence Fund 

Reference number 

PLAN/2023/1621 

Submitted to RSB on 

2 April 2025 

Date of RSB meeting 

30 April 2025 

3 

Electronically signed on 05/05/2025 17:34 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121