REGULATORY SCRUTINY BOARD OPINION Mid-term evaluation of the Single Market Programme
Date: 2025-07-01
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EU programme, EU statistics, European standard, competitiveness, consumer protection, food safety, performance measurement, public health, single market, small and medium-sized enterprises

EUROPEAN COMMISSION 

Brussels, 29.11.2024 
SEC(2025) 195 final 

 REGULATORY SCRUTINY BOARD OPINION 

Mid-term evaluation of the Single Market Programme 

{SWD(2025) 172 final} 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2024) 

Opinion 

Title: Mid-term evaluation of the Single Market Programme 

Overall opinion: NEGATIVE 

(A) Policy context 

The  Single  Market  Programme  (SMP)  consolidated  a  range  of  existing  EU  funding 
programmes to help achieve the single market’s full potential and ensure Europe’s long-term 
recovery from the COVID-19 pandemic. 

The  SMP  has  a  budget  of  EUR  4.3  billion  for  2021-2027.  It  includes  actions  around  six 
pillars in the areas of (i) enforcement and market surveillance, (ii) small- and medium-sized 
enterprises (SMEs), (iii) standardisation, (iv) consumer protection, (v) food safety, and (vi) 
statistics. The mid-term evaluation covers the period 2021-2023. 

(B) Key issues 

The  Board  notes  the  additional  information  provided  and  commitments  to  make 
changes to the report. However, the Board gives a negative opinion because the report 
contains the following shortcomings: 

(1)  The report is not sufficiently informative and self-standing. It does not provide a 

comprehensive assessment of the overall programme’s performance. 

(2)  The evaluation is not clear enough about the limitations of the current monitoring 
system  and  evaluation  arrangement  and  how  the  achievement  of  some  specific 
objectives can be measured. 

(3)  The  analysis  of  relevance,  coherence  and  EU  added  value  is  not  adequately 
developed. The conclusions and lessons learned in the report are not supported by 
sufficient evidence.  

(C) What to improve 

(1)  The  main  report  should  be  more  informative  and  self-standing.  To  this  end,  the  key 
analysis and evidence provided in the pillar-specific annexes should be better reflected in the 
main body of the report to allow for an assessment of the overall programme’s performance. 
The report should set out a clear intervention logic and the links between the overarching 

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

Commission européenne, B-1049 Bruxelles - Belgium. E-mail: regulatory-scrutiny-board@ec.europa.eu 

 
 
 
 
 
 
objectives and the pillar-specific objectives should be clearly established for the purpose of 
the evaluation. 

(2)  The key elements of the pillar-specific analyses should be systematically summarised in 
the main report and presented in a manner that reflects the evidence, its limitations positive 
and  negative  findings  etc.  The  extent  to  which  perception  data  is  sufficient  and  could  be 
subject to possible biases and other limitations, including lack of representativeness needs to 
be taken into account.  

(3)  The evaluation should set out upfront the limitations of the current monitoring system. 
It should explain what those limitations are and how they were addressed in the analysis. The 
report should be clear on the lessons learned from the mid-term evaluation that can be drawn 
for  the  final  evaluation  in  this  regard.  It  should  present  which  indicators  are  used  in  the 
analysis and for which areas indicators are missing. It should also identify more clearly which 
SMART objectives are considered for the assessment of the programme’s performance and 
the links between them and the specific objectives at pillar level. As far as possible, the report 
should identify gaps in the current monitoring system that may hamper an evaluation in the 
future. In particular, the need to attribute benefits to the actions under the programme should 
be reflected. 

(4)  Estimates  of  benefits  should  not  be  presented  as  evidence  of  the  effectiveness  of  the 
programme if they are based on ex ante modelling. As the evaluation should assesses the 
actual benefits, an approach based on ex-ante modelling is conceptually misplaced, and the 
estimates should not be used in the effectiveness and efficiency analyses. As the mid-term 
evaluation focuses on outputs, and to a limited extent results, as it is too early to observe the 
impacts  of  the  intervention,  this  should  be  more  clearly  acknowledged  when  drawing 
assessments and conclusions about the effectiveness and efficiency of the programme. The 
overview table of costs and benefits should provide adequate information on benefits and 
costs.  Once  the  effectiveness  and  efficiency  analyses  are  improved,  the  cost  benefit  table 
should be extensively amended to provide estimates of all relevant costs and benefits in, a 
transparent, structured, and comparable format. 

(5)  The analysis of relevance should be further strengthened. It should explore whether the 
programme is still relevant for problems linked with the COVID crisis, whether it is suitable 
to  address  emerging  problems  and  needs,  and  how  they  affect  the  prioritisation  among 
actions. The report should consider whether the limited complementarity across pillars and 
actions may reflect lack  of synergies. It should assess the external coherence between the 
programme and other initiatives or national programmes contributing to the same general 
objectives.  

(6)  The report should strengthen the EU added value section. It should provide evidence to 
substantiate  the  claim  that  the  programme  has  generated  EU  added  value  beyond  what 
interventions at national level could have achieved. In particular, it should better explain and 
provide evidence on EU added value related to the capacity of the programme to achieve 
economies of scale and allow certain activities that could not be ensured by interventions at 
national level to take place.  

(7)  The analysis in the main report should take into account the differences in the analysis 
across pillars, including data availability, monitoring systems and methodologies used. Such 
variability  across  pillars  should  be  reflected  in  more  nuanced  conclusions  and  lessons 
learned.  

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(8)  The conclusions should omit statements if they are not underpinned by the analysis and 
the evidence provided in the main report. It should make conclusions drawn on the basis of 
only partial evidence more nuanced reflecting that they rely mainly on output data and to 
some extent result indicators or perception data. The report should explain better how the 
conclusions  at  programme  level  were  derived  from  the  ones  in  the  six  pillar-specific 
evaluations. The main report should be more balanced and present both positive and negative 
findings. 

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

(D) Conclusion 

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

The lead Service may resubmit to the Board a revised version of this report.  

Full title 

Mid-term evaluation of the Single Market Programme 

Reference number 

PLAN/2023/1289 

Submitted to RSB on 

30 October 2024 

Date of RSB meeting 

27 November 2024 

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Electronically signed on 29/11/2024 13:37 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121