COMMISSION STAFF WORKING DOCUMENT EVALUATION Interim evaluation of the Strategic Technologies for Europe Platform (STEP) Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Investing in the competitiveness and technological leadership of the EU
Date: 2025-07-16
Institutions: Directorate-General for Budget, European Commission
Subjects: EU investment, biotechnology, clean technology, competitiveness, digital technology, industrial development, investment promotion, professional qualifications, project funding, technological independence

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  EN 

   EUROPEAN COMMISSION  Brussels, 16.7.2025  SWD(2025) 194 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Interim evaluation of the Strategic Technologies for Europe Platform (STEP) Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Investing in the competitiveness and technological leadership of the EU {COM(2025) 421 final}  
 
 
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Table of contents 
INTRODUCTION .................................................................................................................................................................................................... 3 

WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ......................................................................................... 5 

2.1 Description of the intervention and its objectives ......................................................................................................... 5 

2.2 Point of comparison .......................................................................................................................................................................... 9 

HOW HAS THE SITUATION DEVELOPED OVER THE EVALUATION PERIOD? ............................................................... 11 

3.1 Development of the political context .................................................................................................................................. 11 

3.2 State of play of STEP implementation .............................................................................................................................. 13 

3.3 Evolution in STEP implementation over the evaluation period .......................................................................... 13 

EVALUATION FINDINGS............................................................................................................................................................................... 15 

4.1 Effectiveness ........................................................................................................................................................................................ 15 

4.2 Efficiency ............................................................................................................................................................................................... 29 

4.3 Coherence ............................................................................................................................................................................................. 34 

4.4 EU added value ................................................................................................................................................................................. 36 

4.5 Relevance .............................................................................................................................................................................................. 36 

CONCLUSIONS AND LESSONS LEARNED ........................................................................................................................................ 38 

5.1 Conclusions .......................................................................................................................................................................................... 38 

5.2 Lessons learned ................................................................................................................................................................................ 39 

ANNEX I. Procedural information .......................................................................................................................................................... 41 

ANNEX II. Methodology and analytical  models used.............................................................................................................. 42 

Approach to the evaluation ................................................................................................................................................................ 42 

Overview of the evaluation methods .......................................................................................................................................... 43 

ANNEX III. Evaluation matrix and answers to the evaluation questions (by criterion) ...................................... 45 

ANNEX IV. Overview of benefits and costs; table on simplification and burden reduction ............................ 51 

ANNEX V: synopsis report on stakeholder consultations ...................................................................................................... 55 

Results of the consultation activities .......................................................................................................................................... 56 

ANNEX VI: Complementary information .......................................................................................................................................... 65 

 
 
 
 
 
List of abbreviations 

Abbreviation 

Definition 

AI 

capex 

EDF 

EFTA 

ERDF 

ESF+ 

artificial intelligence 

capital expenditure 

European Defence Fund 

European Free Trade Association 

European Regional Development Fund 

European Social Fund Plus 

EU4Health 

European Union health programme 

EIB 

JTF 

MFF 

NCP 

NUTS 

OCA 

opex 

R&D 

R&I 

RRF 

RRP 

SME 

STEP 

TRL 

European Investment Bank 

Just Transition Fund 

multiannual financial framework 

national contact point 

Nomenclature of Territorial Units for Statistics 

ownership control assessment 

operating expenditure 

research and development 

research and innovation 

Recovery and Resilience Facility 

recovery and resilience plan 

small to medium-sized enterprise 

Strategic Technologies for Europe Platform 

technology readiness level 

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INTRODUCTION 

This staff working document presents the European Commission staff’s views on the interim 
evaluation of STEP, building on multiple sources. 

The  Strategic  Technologies  for  Europe  Platform  (STEP)  was  set  up  in  March  2024  by 
Regulation (EU) 2024/795 (the ‘STEP Regulation’) as part of the mid-term review of the current 
EU  multiannual  financial  framework  (MFF).  It  operates  until  the  end  of  this  MFF  period 
(end-2027) and aims to enhance the EU support to the Union’s long-term competitiveness 
and sovereignty in critical technologies.  

Designed as part of the EU strategic response to emerging geopolitical and industrial challenges, STEP 
aligns  and  steers  11  existing  EU funding  instruments  to  mobilise  resources  in  support  of  critical 
technologies in three strategic areas: (i) digital and deep technologies; (ii) clean and resource-efficient 
technologies;  and  (iii)  biotechnologies.  While  equipped  with  limited  extra  funding  (except  for  a 
EUR 1.5 billion  reinforcement  for  the  European  Defence  Fund),  it  introduces  targeted  incentives  to 
facilitate reorientation/reprioritisation of funding, as well as new tools – such as the STEP (Sovereignty) 
Seal and the STEP (Sovereignty) Portal. 

As required by the STEP Regulation (Article 8), this interim evaluation provides a mid-term 
assessment  of  how  STEP  is  delivering  on  its  objectives,  with  a  view  to  inform  future 
decision-making. The evaluation also fulfils the requirements of the Commission’s Better Regulation 
Guidelines and the Interinstitutional Agreement on Better Law-Making1. It assesses the extent to which 
the objectives have been achieved (i.e. ‘effectiveness’), the efficiency in the use of resources and the 
comparison between costs and benefits (i.e. ‘efficiency’), the European added value, the consistency of 
STEP with other EU initiatives (‘coherence’), and the relevance of STEP objectives and actions. In addition, 
it: (i) provides an overview of the EU regions where cohesion programmes have been amended in line 
with  the  partnership  principle;  (ii)  evaluates  the  feasibility  of  a  single  EU  portal  to  consolidate 
information  on  EU  programmes,  improving  transparency  and  accessibility  for  the  public;  and  (iii) 
examines the feasibility of a simulator to guide project promoters, especially small to medium-sized 
enterprises (SMEs), in identifying suitable EU funding opportunities. 

This mid-term evaluation covers the first 13 months of implementation of the platform in 
all Member States, with the cut-off date of 31 March 2025. It encompasses the full scope and 
objectives of STEP as specified in the STEP Regulation and further clarified in the Guidance Note2. The 
extension  of  STEP  to  cover  defence  technologies  as  a  fourth  priority  area,  as  proposed  by  the 
Commission on 22 April 20253, is not assessed in this evaluation. 

This report is published at an early stage in the implementation of STEP, which hinders a 
fully-fledged  impact  evaluation 4 .  For  example,  not  all  financial  resources  allocated  to  STEP 

1

 European  Commission  Better  Regulation  Guidelines 

(2021),  available  at:  https://commission.europa.eu/system/files/2021-

11/swd2021_305_en.pdf. 

2 Commission  Communication  C/2024/3209,  Guidance  Note  concerning  certain  provisions  of  Regulation  (EU)  2024/795  establishing  the 
Strategic Technologies for Europe Platform (STEP), 2024, available at: https://eur-lex.europa.eu/eli/C/2024/3209/oj.  

3  Proposal  for  a  regulation  incentivising  defence-related  investments  in  the  EU  budget  to  implement  the  ReArm  Europe  Plan, 
COM(2025) 188 final. 

4 The STEP Regulation (Article 8) requires that an interim evaluation be concluded by end-2025. 

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objectives have yet been channelled into the financing and implementation of actual projects within 
the targeted technology sectors. As a consequence, a systematic assessment of results and impacts is 
not feasible at this point (in other words, most of the information available at this stage consists of 
output indicators). Still, the report takes stock of progress and evaluates  the impact of STEP where 
possible. To do so, it outlines the steps taken to steer EU funding towards STEP-relevant technologies 
and  highlights  progress  on  two  key  tools:  (i)  the  STEP  (Sovereignty)  Seal,  a  label  awarded  by  the 
Commission to high-quality projects; and (ii) the STEP Portal, a user-friendly one-stop shop for STEP-
relevant funding and investment opportunities across the EU. 

The assessment is primarily based on: (i) the experience and data gathered from relevant stakeholders, 
including relevant national public authorities, during the implementation of STEP, and compiled by the 
Commission’s staff (see Annex V on stakeholder consultations); and (ii) a dedicated call for evidence5. 
Overall, the evaluation process went as planned, and the data gathered are considered reliable. No 
significant difficulties were encountered in reaching key stakeholders involved in the implementation 
of STEP. Therefore, even with the limitations linked to the still early stage of STEP’s implementation, 
the conclusions and lessons learned can be considered sufficiently robust for an interim evaluation.  

To ensure the quality of the evaluation, a Commission interservice steering group oversaw 
the evaluation process. The group provided information, expertise, steer and quality assurance in 
line with evaluation standards. The members of the group represented 15 Commission services6 that 
are responsible for EU funding programmes and EU policies relevant to STEP.  

The  results  of  the  evaluation  will  serve  two  aims.  First,  they  can  help  identify  possible 
improvements in implementing STEP  over the remaining period (until the end  of the current MFF)7. 
Second, early lessons from STEP may also inform the design of the future MFF, including the European 
Competitiveness Fund. 

This staff working document is structured as follows: Section 2 summarises the objectives and 
expected outcomes of STEP. Section 3 describes how the situation has developed since STEP’s inception 
in 2024. Section 4 presents the main findings of the evaluation based on the above-mentioned criteria. 
The fifth and final section provides conclusions and lessons learned. The annexes provide additional 
information about the methodology used, the stakeholder consultation, and the process and procedures 
followed for this interim evaluation.  

5 See Annex V for further information on the call for evidence. 

6  The  interservice  steering  group  is  composed  of  representatives  of  the  Directorate-General  (DG)  for  Budget;  DG  Climate  Action;  DG 
Communications Networks, Content and Technology; DG Competition; DG Defence Industry and Space; DG Economic and Financial Affairs; DG 
Employment, Social Affairs and Inclusion; DG Internal Market, Industry, Entrepreneurship and SMEs; the Health Emergency Preparedness and 
Response Authority; the Legal Service; DG Regional and Urban Policy; DG Research and Innovation; DG Health and Food Safety; the Secretariat-
General; and the Reform and Investment Task Force. 

7 Article 8(3) of the STEP Regulation provides that ‘where appropriate, the interim evaluation report shall be accompanied by a legislative 
proposal for an amendment of this Regulation’. 

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WHAT WAS THE EXPECTED OUTCOME OF THE 
INTERVENTION? 

2.1 Description of the intervention and its objectives  

Context of the intervention 

The EU set up the Strategic Technologies for Europe Platform as part of its response to the urgent 
need  to  strengthen  its  technological leadership and  resilience  in  strategic  sectors. It was 
deemed essential to reorient the EU  budget in support of strategic investments in critical technologies 
against the backdrop of increasing supply chain vulnerabilities, aggravated by the COVID-19 crisis and 
Russia’s war of aggression against Ukraine, which affect the EU’s ability to pursue its goals in terms of 
green  and  digital  transitions  and  undermine  the  EU’s  industrial  competitiveness,  as  well  as  in  the 
general context of not always fair competition in a fragmented global market. Several major economies 
launched ambitious initiatives to support strategic industries8.  

To remain competitive, the EU must have in place well-coordinated public funding mechanisms 
that match the scale and ambition of those of global counterparts and that can also act as leverage to 
mobilise private funding – as stated in the Commission Communication on the Savings and Investments 
Union9. Mobilising private capital is  also essential, since massive investments are  required to  boost 
innovation and productivity growth in the EU and secure Europe's freedom, security and autonomy. As 
an illustration, the Draghi report10 estimates them at EUR 750-800 billion in the EU per year until 2030. 

STEP also reflects long-standing EU sectoral policy initiatives, such as the Green Deal Industrial Plan11 
and the Digital Decade Policy Programme 203012, as well as more recent strategic frameworks such 
as the Competitiveness Compass13 and the Clean Industrial Deal14, with a strong focus on regions and 
territories, consistent with EU cohesion policy.  

Objectives, tools and functioning of the intervention 

STEP was created with the ambition to help ensure that the future of industry is made in 
Europe.  The  instrument  was  set  up  to  reorient  existing  EU  funding  instruments,  ensuring 
consistency among them, to the benefit of projects and technological areas that were identified as 
crucial for Europe’s technological leadership, industrial competitiveness, and strategic autonomy.  

STEP pursues two specific objectives, as set out in Article 2 of the STEP Regulation:  

8 The United States, through the Inflation Reduction Act, plans to mobilise over USD 360 billion (approx. EUR 330 billion) by 2032 for clean 
technologies, while Japan's green transformation strategy aims to direct up to JPY 20 trillion (approx. EUR 140 billion) to sustainable industries. 
Other countries, including India, the United Kingdom, and Canada, have also implemented targeted investment strategies to strengthen their 
strategic technology sectors. 

9 See COM(2025) 124 final. 

10 See the Draghi report on EU competitiveness. 

11 See COM(2023) 62 final. 

12 See Decision (EU) 2022/2481 of the European Parliament and of the Council of 14 December 2022. 

13 See COM (2025) 30 final. 

14 See COM(2025) 85 final. 

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1.  supporting the development or manufacturing of critical technologies throughout the 
EU, or safeguarding and strengthening their respective value chains, in the following three 
sectors: digital and deep innovation technologies, clean and resource-efficient technologies, 
and biotechnologies; and 

2.  addressing  shortages  of  labour  and  skills  across  these  strategic  industries,  ensuring 

Europe has the workforce necessary for innovation and production. 

To  achieve  its  objectives,  STEP  was  designed  to  boost  flexibility  and  synergies  across 
existing  EU  funding  instruments,  as  illustrated  in  the  intervention  logic  below.  Its  main 
implementation tool is the reprogramming of 11 EU funding instruments (see below), supported – in 
some cases – by financial incentives offered by the STEP Regulation, such as those set out below.  

•  For cohesion policy funds (the ERDF, CF, ESF+ and JTF15), Member States benefit from: (i) the 
possibility  to  finance  productive  investments  in  enterprises  other  than  SMEs16 under  the 
ERDF’s STEP-dedicated priorities; (ii) higher co-financing rates of up to 100% at the level of 
the STEP-dedicated priority; and (iii) 30% of the allocation to STEP priorities being paid by 
the Commission as one-off pre-financing17.  

•  Additional  funding  of  EUR 1.5 billion  for  the  European  Defence  Fund  for  projects  that 

contribute to the STEP objectives. 

•  Under InvestEU,  Member States can further support the identified  critical  technologies  by 
allowing an additional transfer of up to 6% of the resources in their national recovery and 
resilience plans to their InvestEU Member State compartment18.  

The  STEP  Regulation  introduced  a  new  quality  label,  the  STEP  (Sovereignty)  Seal,  awarded  by  the 
Commission under the five Funds in STEP’s remit that are directly managed by the Commission (i.e. 
‘under direct management’), namely the Innovation Fund19, the European Defence Fund, Horizon Europe, 
the Digital Europe Programme, and EU4Health. The STEP Seal is to be awarded to projects that align 
with  STEP  objectives  and  meet  the  evaluation  standards  of  STEP-relevant  calls  for  proposals.  The 
objective is to increase the visibility of these projects to help them attract cumulative or alternative 
public funding, including from cohesion policy funds and the Recovery and Resilience Facility (RRF), as 
well as funding from private investors. 

Additionally, the STEP Regulation required the launch of a STEP (Sovereignty) Portal20 to simplify 
access to all relevant information on EU funding for STEP, be it at EU, national or regional level. This 
new hub of the Commission provides – in an integrated manner – all relevant funding opportunities for 
project  promoters  and  includes  a  dashboard  showcasing  the  projects  awarded  a  STEP  Seal  for  the 
benefit of private investors and public authorities. 

15 European Regional Development Fund, Cohesion Fund, European Social Fund Plus and Just Transition Fund. 

16 For less developed and transition regions, as well as more developed regions in Member States whose average GDP per capita is below the 
EU-27 average. 

17 Upon adoption of the STEP Regulation, 30% pre-financing was also paid to all JTF programmes. 

18 The resources transferred from the RRF to InvestEU are implemented according to the rules of InvestEU, allowing to sign contracts between 
implementing partners and the recipients up until end-2028 as set out in the InvestEU Regulation. 

19 The Innovation Fund is funded with revenues from the Emissions Trading System (ETS). 

20 See Strategic Technologies for Europe Platform - European Union (STEP). 

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Finally, the implementation of STEP is supported by a dedicated Commission team – the STEP Task 
Force – responsible for central coordination within a broad Commission network, and in support of the 
new network of STEP national contact points, which aims to facilitate implementation in Member 
States. 

Intervention logic 

The  STEP  intervention  logic  framing  the  purpose,  actions  and  expected  outcomes  of  the 
platform, is presented in Figure 1. This captures the consecutive steps of STEP from the initial needs 
to be addressed to the ultimate goals to be achieved.  

The STEP intervention logic operates as follows: with increased focus of EU investment on strategic 
technologies and a EUR 1.5 billion top-up for the European Defence Fund, the Commission, supported 
by  the  network  of  STEP  national  contact  points  and  by  managing  authorities,  coordinates  the 
reallocation of EU financial instruments across 11 EU funding programmes to align with STEP 
objectives. 

These 11 instruments fall under three management modes: 

•  direct management by the Commission; 

•  shared management between the Commission and Member States; and 

•  indirect management through implementing partners. 

As a result, calls for proposals are launched at both EU and national levels to fund STEP-relevant 
projects. For direct management programmes, and in the selection process of the relevant calls, the 
Commission also awards the STEP Seal to high-quality projects (see Section 4.1 on effectiveness). 
This quality label, introduced above, enables projects to benefit from special conditions when seeking 
additional or alternative funding from national sources, including cohesion policy funds and the RRF. 
For example, under the ERDF and the ESF+, such projects may be awarded additional or alternative 
funding directly, i.e. via a simplified/fast-track selection process. 

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FIGURE 1: INTERVENTION LOGIC OF STEP 

Source:  STEP Task Force elaboration

8 

 
 
2.2 Point of comparison 

STEP  is  not  a  new  spending  programme,  but  rather  a  coordination  instrument  meant  to 
mobilise higher amounts of financial support for the priority areas through a  more coordinated, 
effective,  efficient  and  targeted  use  of  EU  funds.  Hence,  there  is  no  immediate  point  of 
comparison in terms of a similar initiative under the EU budget. 

At the time of entry into force of STEP, all 11 EU funding instrument contributing to STEP 
were  already  providing  support  to  the  strategic  sectors  identified  under  STEP,  albeit  to 
varying degrees and with limited coordination among them. These programmes pursue multiple 
objectives beyond those introduced by STEP. They are listed below.  

•  Cohesion  policy  is  the  EU’s  main  investment  policy,  targeting  all  regions  and  cities  to 
support business competitiveness, economic growth, sustainable development, improvement 
of people’s quality  of life, and job  creation21. It operates within pre-allocated  budgets  for 
each Member State, who are in charge of implementation. Cohesion policy contributes to the 
social, economic and territorial cohesion in the EU and aims to correct imbalances between 
countries  and  regions.  It  delivers  on  the  EU’s  political  priorities,  especially  the  green  and 
digital  transitions.  Its  investment  firepower  includes  a  total  of  EUR 225 billion  under  the 
European Regional Development Fund (ERDF), EUR 39 billion under the Cohesion Fund (CF), 
EUR 20 billion under the Just Transition Fund (JTF) and EUR 95 billion under the European 
Social Fund Plus (ESF+)22. 

•  The Recovery and Resilience Facility (total financial envelope of EUR 650 billion in grants 
and loans as included in the national recovery and resilience plans (RRPs) as of mid-October 
2024)  is  a  temporary performance-based  instrument  launched in  2021  and  running  until 
December  2026  that  finances  reforms  and  investments  in  Member  States  for  the  EU  to 
emerge stronger and more resilient from the COVID-19 pandemic. It also operates with pre-
allocated national envelopes for grants and loans. RRPs had to allocate at least 37% and 
20% of their envelopes to green and digital measures, respectively23. 

•  The Innovation Fund is managed by the Commission and supports the European industry’s 
transition  to  climate  neutrality  for  2020-2030.  The  fund  is  financed  through  revenues 
generated by the EU Emissions Trading System (ETS). Although its financial capacity varies 
in line with fluctuations in the carbon price, it is currently estimated at about EUR 40 billion 
for 2020-2030, calculated by  using a carbon price of  EUR 75 per tonne of CO2. The fund 
supports  innovative  low-carbon  technologies,  including  the  manufacturing  of  these 
technologies, for instance to reduce the carbon footprint of energy-intensive industries and 
develop  carbon  capture  and  storage,  innovative  renewable  energy  generation,  or  energy 
storage24. 

21 See Inforegio - Cohesion Policy. 

22 See New Cohesion Policy. 

23 See Recovery and Resilience Facility. 

24 See Climate Action. 

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•  InvestEU  is  a  programme  managed  indirectly  via  the  implementing  partners  of  the 
Commission.  It  contributes  both  to  the  green  transition  and  to  digitalisation,  with  a  total 
EU guarantee of EUR 26.2 billion2526over the 2021-2027 MFF period. Two of its windows are 
especially  relevant  for  STEP:  (i)  the  research,  innovation  and  digitisation  window 
(EUR 6.6 billion),  supporting  R&D,  technology  transfer,  and  scaling  up  of  innovative 
companies2728;  and  (ii)  the  sustainable  infrastructure  window  (EUR 9.9 billion),  focusing  on 
clean transport, renewable energy, energy efficiency, and digital connectivity. At least 30% 
of  total  investments  across  all  policy  windows  and  at  least  60%  of  those  under  the 
sustainable infrastructure window target climate objectives. 

•  Horizon  Europe  is  a  flagship  EU  programme  managed  by  the  Commission  to  support 
research and innovation with a total budget of EUR 93.5 billion over the 2021-2027 MFF 
period29. In particular, the European Innovation Council (EIC) under the ‘Innovative Europe’ 
pillar  of  Horizon  Europe  is  Europe’s  flagship  innovation  programme  with  a  budget  of 
EUR 10.1 billion for 2021-2027. The EIC plays a pivotal role in supporting the scale-up of 
critical  breakthrough  and  deep  tech  innovations  across  Europe.  Its  mission  is  to  turn 
cutting-edge  science  and technology  into  globally  competitive  solutions,  driving  economic 
growth and strengthening the EU’s technological sovereignty. Pillar II ‘Global Challenges and 
European Industrial Competitiveness’ also supports strategic technologies.  

•  The Digital Europe Programme, with a total budget allocation of EUR 8.1 billion over the 
2021-2027  MFF  period,  supports  digital  transformation  while  strengthening  the  EU’s 
resilience and digital sovereignty30. 

•  The European Defence Fund, with an initial budget of nearly EUR 7.3 billion for 2021-2027, 
supports  research  and  development  of  state-of-the-art  and  interoperable  defence 
technology  and  equipment.  As  mentioned,  the  STEP  Regulation  provided  a  EUR 1.5 billion 
budgetary reinforcement for the EDF for STEP actions31. 

•  EU4Health invests EUR 4.4 billion over 2021–2027 to build stronger, more resilient health 
systems  and  improve  health  across  the  EU.  It  supports  crisis  preparedness,  disease 
prevention,  healthcare  workforce  capacity,  digital  health,  and  access  to  medicines  and 
medical devices32. 

The main benchmark for assessing the implementation and expected impact of STEP is the 
counterfactual scenario, i.e. what would have happened without it.  

25 Based on the InvestEU Regulation, the amount of the EU guarantee is EUR 26.2 billion. However, the total amount of guarantee with top-
ups and MS contributions currently stands at EUR 30.15 billion. 

27 See InvestEU. 

29 See Research and Innovation. 

30 See The Digital Europe Programme. 

31 See Defence Industry and Space. 

32 See EU4Health. 

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In the absence of STEP, support for the strategic technologies identified would likely have 
continued on the same trend observed during the initial years of the 2021-2027 MFF. This 
level of support cannot be easily quantified, including because at its inception, the MFF did not feature 
a  common  definition  of  what  constitutes  ‘strategic  technologies’.  It  is  this  drawback,  however,  that 
offers  the  opportunity  of  a  qualitative  comparison.  The  counterfactual  provides  a  benchmark  for 
evaluating  STEP’s  impact:  a  context  in  which  EU  programmes  under  direct  management  operated 
independently and without coordination with the programmes under shared and indirect management 
and where, especially given the narrow and focused scope of STEP, EU funding programmes aligned 
only partially and incidentally with its priorities. 

The  main  goal  of  STEP,  and  the  dimension  against  which  its  effectiveness  should  be 
measured,  was  to  reprioritise  the  EU  budget,  adapting  it  to  changing  political  and 
technological  needs.  At  the  start  of  the  2021-2027  MFF,  many  EU  programmes  set  predefined 
priorities,  which,  in  the  absence  of  STEP,  would  have  likely  remained  largely  stable  throughout  the 
period. However, since 2021, the EU’s strategic priorities have shifted significantly - particularly in light 
of geopolitical tensions, supply chain vulnerabilities, and the accelerating pace of technological change. 
STEP  responds  to  these  changing  circumstances  by  introducing  incentives  and  tools  for  dynamic 
reprioritisation,  stimulating  the  redirection  of  existing  EU  funds  towards  critical  and  emerging 
technologies. The complexity of adjusting funding allocations halfway through the programming period 
should not be underestimated, especially given that 90% of resources under the 2021-2027 MFF and 
NextGenerationEU – in particular its main instrument, the RRF – are already pre-allocated to specific 
objectives, programmes, or national envelopes33. 

Another  dimension  along  which  to  measure  the  impact  of  STEP  is  the  ease  with  which 
relevant EU funding information can be found. Before STEP, applicants – particularly SMEs – had 
to navigate a fragmented funding landscape. While efforts to consolidate grant opportunities through 
the Funding & Tenders Portal were welcome, the portal still does not include programmes under shared 
management.  Survey  data  from  2024  (see  Annex  V  on  stakeholder  consultations)  show  that  users 
rated ‘ease of finding funding information’ at just 5/10, with 33% of them relying on paid consultants 
to navigate the complex universe of EU funding opportunities.  

HOW HAS THE SITUATION DEVELOPED OVER THE 
EVALUATION PERIOD? 

3.1 Development of the political context  

STEP was proposed by the Commission in June 2023 as part of the mid-term review of the 
2021-2027  multiannual  financial  framework  (MFF),  as  a  response  to  growing  concerns 
about  the  EU’s  technological  and  industrial  sovereignty.  Institutional  negotiations  in  the 
European Parliament (Committee on Budgets and Committee on Industry, Research and Energy) and 
the Council (under the Belgian Presidency) took place in January and February 2024. Compared to the 
initial Commission proposal of EUR 10 billion of budgetary reinforcements for a number of programmes 

33 See  European  Commission  (2023),  Annual  management  and  performance  report  for  the  EU  budget,  Financial  year  2022.  Volume  1, 
COM(2023) 401 final. 

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covered  by  STEP,  and  the  EUR 13 billion  proposed  in  the  European  Parliament’s  position,  a 
EUR 1.5 billion budgetary reinforcement for the European Defence Fund was adopted. The main aspects 
of the Commission proposal were maintained, including the STEP (Sovereignty) Seal, flexibilities for 
cohesion policy funds, the requirement for Member States to consider STEP Seal projects as priority 
when  revising  their  recovery  and  resilience  plans,  and  the  provision  of  equity-only  support  via  the 
European  Innovation  Council.  The  final  agreement  maintained  the  scope  of  STEP  –  covering 
development and manufacturing, explicitly excluding deployment – and its focus on the three strategic 
the 
technologies,  while  adding  associated  services 
manufacturing/development of such strategic technologies.  

that  are  critical  and  specific 

to 

At the beginning of its term of office in December 2024, the new College of Commissioners 
and  the  Commission  President  identified  strengthening  the  EU’s  prosperity  and 
competitiveness as their priority for 2024-202934. In particular, the Political Guidelines35 further 
underscore the need for Europe to accelerate its transformation to stay ahead in the global race for 
climate neutrality and tech leadership, harnessing its strengths while removing structural barriers to 
competitiveness.  Among  the  EU’s  planned  actions,  a  European  Competitiveness  Fund  will  be 
proposed as part of the EU’s long-term budget to strengthen the EU’s investment capacity in strategic 
technologies36.  

STEP is well aligned with the priorities of the current mandate. 

The  Competitiveness  Compass,  adopted  by  the  Commission  in  January  2025,  provides  a 
roadmap  for  boosting  competitiveness,  by  taking  key  measures  to 
implement  three 
transformational imperatives: (i) closing the innovation gap; (ii) a joint roadmap for decarbonisation 
and  competitiveness;  and  (iii)  reducing  excessive  dependencies  and  increasing  security.  The 
Competitiveness  Compass  builds  on  the  recommendations  from  multiple  expert  reports,  including 
Draghi’s report on the future of European competitiveness. It highlights investment as one of the four 
key  drivers  of  long-term  competitiveness  and  emphasises  the  need  to  mobilise  public  and  private 
capital to support innovation, strategic technologies and the green and digital transitions.  

In February 2025, the Commission presented the Clean Industrial Deal, a strategic push to 
boost  Europe’s  global  competitiveness  by  simplifying  regulations,  accelerating  green 
investments,  and  ensuring  access  to  affordable  energy  and  raw  materials  –  empowering 
industries  to  lead  in  the  clean  tech  transition  while  creating  quality  jobs  and  cutting  strategic 
dependencies.  The  Critical  Medicines  Act,  proposed  by  the  Commission  in  March  2025,  aims  to 
increase the availability, supply and production of essential medicines in the EU, reducing dependency 
on external sources and addressing supply chain vulnerabilities. In March 2025, the Commission also 
unveiled its strategy for the Savings and Investments Union, which seeks to improve Europeans’ 
access to capital markets and provide better financing options for companies, thus increasing people’s 
wealth  and  boosting  EU  economic  growth  and  competitiveness.  In  April  2025,  the  Commission  put 
forward the AI continent action plan, aiming to ensure the EU becomes a global leader in artificial 
intelligence (AI).  

34 Statement at the European Parliament plenary by President Ursula von der Leyen, 18 July 2024. 

35 See the Political Guidelines for the next European Commission. 

36 See COM(2025) 46 final. 

12 

 
 
3.2 State of play of STEP implementation  

As  of  31 March 2025,  the  implementation  of  STEP  was  advancing  across  all  main  areas, 
though progress is uneven. 

Member States had demonstrated strong interest in reprogramming cohesion policy funds 
to support STEP objectives. By end-March 2025, 38 cohesion policy programme amendments for 
STEP had been submitted by France, Germany, Latvia, Lithuania, Romania, Italy, Spain, Denmark, the 
Netherlands,  Austria  and  Poland  and  adopted  by  the  Commission,  redirecting  approximately 
EUR 6.3 billion  in  funding  to  STEP  priorities.  Germany,  Denmark,  Italy,  Latvia  and  Romania  have 
already launched STEP-related calls for proposals, with a combined budget of almost EUR 2 billion, 
and project selection is under way. 

Additionally, 60 calls for proposals and two calls for tenders had been launched under five 
directly  managed  EU  programmes,  including  the  Innovation  Fund  (calls  opened  2024),  Horizon 
Europe, the European Defence Fund, EU4Health, and  the Digital Europe Programme37,38. These calls 
represented EUR 9.5 billion in available funding39, with over EUR 5 billion already allocated to projects. 
Most of this funding has been directed to clean technologies under the Innovation Fund. See Annex VI 
for a breakdown of the calls by funding programme. 

The Commission had awarded 190 STEP Seals to projects that align with STEP objectives. 
These  high-quality  projects  are  eligible  for  additional  or  alternative  funding  through  other  EU 
instruments,  although  none  had  received  any  yet.  See  Annex VI  for  a  breakdown  of  the  Seals  by 
funding programme. 

•  No Member State had amended its RRP to support a project that had been awarded the STEP 
Seal. Similarly, no Member State had used the increased possibility to transfer RRF resources 
to the InvestEU Member State compartment for STEP priorities. 

Launched in April 2024, the STEP (Sovereignty) Portal has become a key tool for accessing 
STEP-related information. As of the end of March 2025, it featured over 70 funding opportunities, 
a database of STEP Seal projects, and contact details for STEP national contact points. Since early 2025, 
the  portal  has  attracted  around  10 000  unique  visitors  each  month.  To  further  improve  the  user 
experience,  preliminary  development is under way for an  AI-powered  simulator  and  chatbot  to 
assist project applicants in identifying eligible funding opportunities. 

3.3 Evolution in STEP implementation over the evaluation 

period  

Following the Commission proposal  of June 2023 to  set up STEP, a dedicated STEP  Task 
Force was created within the Commission’s Directorate-General for Budget.  

37 On 1 April 2025, the Digital Europe Programme published six additional STEP-relevant topics for a total budget of EUR 208 million. These 
include three topics in the field of the Digital Innovation Hubs and three topics on digital skills that were published between the 3 April and the 
14 April. For further information see Get Funding. 

38 On 3 April 2025, nine STEP-relevant topics were launched by the Circular Bio-based Europe Joint Undertaking under Horizon Europe, for a 
total budget of EUR 150 million. For further information see Get Funding.  

39 Excluding the budget of the procurement calls under EU4Health. 

13 

 
 
Implementing STEP across programmes with different rules, timelines and legal bases and 
across  Member  States  was  a  considerable  operational  challenge,  requiring  large 
coordination and clarification efforts. Thanks to constant dialogue and feedback, the task force 
and the many Commission services involved in STEP, in particular the directorates-general managing 
the  11  funding  instruments,  have  taken  various  steps,  as  described  below,  to  improve  the 
implementation of STEP within the remit of the STEP Regulation. 

Increasing clarity on STEP’s scope and implementation modes 

Since the set-up of STEP, the Commission has produced a range of guidance documents to 
facilitate its implementation.  

In May 2024, pursuant to Article 2(7) of the STEP Regulation, the Commission adopted a 
Communication in the form of a Guidance Note40, providing practical direction to ensure consistent 
and  effective  implementation  across  funding  programmes.  The  Guidance  Note:  (i)  clarifies  STEP’s 
objectives, as defined in Article 2 of the Regulation; (ii) provides examples of supported sectors and 
includes  a  non-exhaustive  list  of  eligible  technologies;  and  (iii)  elaborates  on  the  conditions  for 
technologies  to  be  considered  ‘critical’.  Stakeholders,  in  particular  STEP  national  contact  points  and 
national managing authorities of cohesion policy programmes, broadly welcomed this initiative that 
clarified the scope of applicability of STEP.  

Additionally, in June 2024, the Commission prepared a brochure41 for STEP national contact 
points  and  managing  authorities  and  published  it  on  the  STEP  (Sovereignty)  Portal.  It 
provides stakeholders with practical aspects to facilitate the implementation of STEP at 
national and regional level, specifically in the context of cohesion policy and the RRF. During the 
first year of STEP implementation, and thanks to the support of the relevant Commission services, the 
brochure was enriched to provide guidance on the most pressing questions, including on the treatment 
of  projects  with  multiple  beneficiaries/promoters  from  different  countries  /  Member  States  under 
cohesion policy, and the State aid regulatory provisions applicable to STEP projects. In June 2024, the 
Commission amended the Guidelines on regional State aid42 to allow higher maximum aid 
intensities in assisted areas for projects falling within the scope of STEP. 

Finally,  in  July  2024,  the  Commission  also  updated  the  Guidance  on  recovery  and  resilience 
plans43 to clarify the procedures for amending RRPs, including with respect to the allocation of 
resources to STEP objectives. 

Advancing STEP through stronger cooperation 

The coordination effort to implement STEP across programmes and Member States required 
the Commission to set up two main networks. First, an internal network of 14 Commission 
directorates-general involved in STEP, in particular those managing the 11 funding instruments 

40 Commission  Communication  C/2024/3209,  Guidance  Note  concerning  certain  provisions  of  Regulation  (EU)  2024/795  establishing  the 
Strategic Technologies for Europe Platform (STEP), 2024, available at: https://eur-lex.europa.eu/eli/C/2024/3209/oj. 

41 See Brochure for STEP National Contact Points and Managing Authorities. 

42 See Communication from the Commission supplementing the Guidelines on regional State aid with regard to the Strategic Technologies for 
Europe Platform (STEP). 

43 See Commission Notice Guidance on recovery and resilience plans. 

14 

 
 
listed  in  the  STEP  Regulation.  This  internal  network  met  nine  times  over  the  reporting  period  and 
engaged  very  actively  and  regularly  throughout  the  year.  Second,  the  network  of  STEP  national 
contact points, appointed by all Member States except Ireland, chaired by the Director for Revenue 
and MFF of the Directorate-General for Budget. This network has met five times already, including once 
in person in Brussels. At these meetings, national contact points shared national experiences, and the 
Commission clarified STEP’s objectives and shared updates on awarded STEP Seals. A second in-person 
meeting was held in May 2025 to further strengthen coordination. 

Delivering a user-centric one-stop shop 

In accordance with Article 6 of the STEP Regulation, on 29 April 2024, the Commission launched the 
STEP  (Sovereignty)  Portal  to  serve  as  a  one-stop  shop  for  project  applicants,  public 
authorities, and investors, providing streamlined access to information on EU funding for 
strategic  technologies  under  STEP. A  revamped version was later released in September 2024, 
featuring a user-centric structure tailored to the needs of different user groups. It introduced several 
new  tools,  including  a  ‘Get  Funding’  dashboard,  a  map  of  STEP  national  contact  points,  the 
dashboard  of  the  STEP  Seals,  and  updates  on  regional  cohesion  policy  funding.  The  technical 
developments of the STEP Portal are inspired by the continuous feedback received from stakeholders, 
including but not limited to the survey on access to EU funding carried out in autumn 2024 (see 
Section 4.3 on efficiency and Annex V on stakeholder consultations). 

Strengthening ties with stakeholders and industry 

To better understand the needs of all those involved in the EU funding landscape in relation 
to  STEP,  the  Commission  conducted  extensive  consultations  with  research  and  industry 
stakeholders throughout the first period of implementation of STEP. Leveraging established 
networks and platforms (such as the Industrial Forum, the Enterprise Europe Network, and the European 
Cluster Collaboration Platform) as well as sectoral organisations listed in the EU Transparency Register, 
the Commission primarily engaged with industry players, but also consulted public institutions, including 
EU regional offices, European Institute of Innovation and Technology (EIT) Knowledge and Innovation 
Communities, regional networks, investors,  and  other  stakeholders.  Around half of the stakeholders 
consulted operate across multiple STEP sectors, with strong representation from the clean tech sector. 
The  Commission  also  engaged  with  EU-wide  organisations  and  events  –  such  as  EuroChambres, 
Hannover  Messe,  and  the  SME  Assembly  under  the  Hungarian  Council  Presidency  –  as  well  as 
stakeholders  from  specific  Member  States  during  technical  missions  to  Estonia,  Latvia,  Lithuania, 
Romania, Slovenia, Greece and Portugal (see Annex V on stakeholder consultations). 

EVALUATION FINDINGS 

4.1 Effectiveness 

This section assesses STEP’s mid-term progress towards the specific objectives set out in 
Article 2(1) of the STEP Regulation: (a) supporting the development or manufacturing of critical 
technologies across the EU, or safeguarding and strengthening their respective value chains in digital 
technologies,  clean  and  resource-efficient  technologies,  and  biotechnologies;  and  (b)  addressing 

15 

 
shortages of labour and skills critical to quality jobs supporting objective (a). It also evaluates the 
feasibility of bringing together all relevant EU funding opportunities in a single portal, and 
of setting up a simulator to guide project promoters – particularly SMEs — towards suitable 
EU funding opportunities for their projects. 

While significant progress has been made in mobilising EU funding towards STEP priorities, 
it is too early to draw firm conclusions about the extent to which STEP has achieved its core 
objectives. The Regulation setting up STEP clarifies that the initiative is meant to ‘mobilise resources 
within  the  existing  Union  programmes’  and  supports  this  with  a  set  of  tools,  including  the  STEP 
(Sovereignty) Portal and the STEP (Sovereignty) Seal. As such, and as set out in the intervention logic, 
STEP  operates  mainly  by  reprogramming  EU  funding  programmes  towards  its  objectives.  Where 
available, early evidence and qualitative feedback are used to assess the ‘actions’ performed under 
STEP  and  the  achievement  of  its  ‘outputs’.  The  lag  between  resource  (re)allocation  and  observable 
results thereof makes it difficult to provide a comprehensive assessment of the ‘results’ of STEP at this 
stage.  

Financial support to STEP objectives under programmes under direct 
management 

This section presents the progress in reprogramming resources of the five STEP-relevant 
EU funding programmes under direct management in the first 13 months of implementation 
of  STEP.  Overall,  STEP  has  been  effective  in  steering  resources  towards  strategic  technologies 
identified in the  STEP  Regulation. This is noteworthy, considering that the adopted STEP  Regulation 
provided no specific financial incentives in this respect, except for a top-up of EUR  1.5 billion for STEP 
priorities under the European Defence Fund (EDF). 

At the time of the adoption of the STEP Regulation, the investment potential of STEP under directly 
managed programmes was difficult to evaluate and could have been expected to be limited to the 
additional funding for the EDF. This low expectation was largely exceeded in just over one year 
of STEP implementation.  

In terms of programmed funding, by the end of March 2025, 60 STEP-relevant calls for proposals had 
been  launched 44  under  the  five  programmes  under  direct  management.  A  total  budget  of 
EUR 9.5 billion45 was initially allocated to support technologies relevant to STEP under these 
calls, with the bulk of the funding directed towards clean and resource-efficient technologies through 
the Innovation Fund, which by design is fully aligned with the scope of STEP. This amount also includes 
the new dedicated STEP Scale-Up call of the European Innovation Council (EIC) launched in October 
2024 with an initial budget of EUR 300 million for 2025 (providing up to EUR 30 million in investments 
per  company),  projected  to  reach  EUR 900 million  by  2027;  and  five  STEP-relevant  EIC  Accelerator 

44 Out of the 60 calls for proposals, at the time of the report, 26 were still open and accepting submissions. Additional topics will open for 
submission over the course of April, May and June 2025 under Digital Europe and Horizon Europe. For further information see Get Funding. 

45 This amount includes the EUR 208 million budget of six topics under Digital Europe (three in the field of the Digital Innovation Hubs and 
three on digital skills) that were launched over the course of April 2025 and nine STEP-relevant topics were launched in early-April by the 
Circular Bio-based Europe Joint Undertaking under Horizon Europe, for a total budget of EUR 150 million. 

16 

 
 
Challenges calls for a total budget of EUR 250 million. The pie chart and table in Figure 1 display how 
much budget each programme has allocated to STEP priorities out of the mentioned EUR 9.5 billion. 

FIGURE 1: BUDGET ALLOCATED TO ALREADY LAUNCHED STEP CALLS AS OF 
END-MARCH 2025, BREAKDOWN BY PROGRAMME 

Source: Commission services’ reporting 

Programme 

Innovation Fund 
EDF 
EIC 
Digital Europe 
Horizon Europe (excluding EIC) 
EU4Health 
Total 

Budget in million EUR 

7 400 
762 
550 
318 
289 
129 
9448 

As  regards  already  allocated  funding,  at  the  time  of  this  report,  the  five  programmes  under  direct 
management  within  the  remit  of  STEP  had  allocated  around  EUR 5.2 billion  in  funding 4647  to 
selected projects, with only EUR 68 million awarded to projects supporting the development of skills 
in the realm of digital technologies. See Figure 2 for the breakdown. 

46 This amount corresponds to the total amount awarded to the projects selected for funding under the Innovation Fund, Horizon Europe, the 
Digital Europe Programme and EU4Health. It may be adjusted upon the signing of the actual grant agreements, which could modify individual 
contributions, and cannot be reconciled with the EUR 9.5 billion of the previous paragraph, which refers to ex ante allocated budget (vs ex post 
funding awarded) under the STEP calls launched by March 2025 under all five directly managed programmes in STEP’s remit.  

47 This amount includes EUR 150 million from the EIC that is exceptionally included in the scope of the evaluation, despite projects having been 
selected  on  3 April.  Investments  are  pending  authorisation  by  the  Commission  through  the  award  decision  and  the  ownership  control 
assessment. 

17 

 
 
 
 
 
 
FIGURE 2: FUNDING AWARDED TO SELECTED PROJECTS UNDER STEP-RELEVANT 
CALLS UNDER DIRECT MANAGEMENT, BREAKDOWN BY SECTOR AND PROGRAMME48 

Source: Commission services’ reporting 

These  STEP-relevant  projects  are  expected  to  be  implemented  over  the  next  five  to 
ten years,  progressively  contributing  to  strengthening  EU  manufacturing  capacity  and 
addressing skills shortages in the three strategic technology areas. Given the long-term nature 
of these investments, it is too early at present to provide a quantitative assessment of the extent to 
which the reprogrammed financial resources under the directly managed programmes are effectively 
supporting these objectives. 

Moreover,  additional  resources  are  expected  to  be  reprogrammed  and  awarded  to  STEP 
projects as further STEP-relevant calls for proposals are launched and evaluated, in line 
with the developing work programmes of the relevant funding instruments. Therefore, the 
figures  reported  as  of  end-March  2025  regarding  budget  allocations  and  awarded  funding 
(EUR 9.5 billion and EUR 5.2 billion, respectively) should be understood as a snapshot in a dynamic and 
ongoing process. Similarly, the currently limited volume of resources awarded to skills-related projects 

48 The funding amounts under the EIC (totalling EUR 150 million) are exceptionally included in the scope of the evaluation, despite projects 
having been selected on 3 April. Investments are pending authorisation by the Commission through the award decision and the ownership 
control assessment. An amount of EUR 15 million falls in two technology areas (digital and clean). It is allocated to the primary sector of activity 
of the relevant project: digital technologies. 

18 

 
 
 
should  be  seen  in  light  of  the  fact  that,  so  far,  only  one  topic  on  skills  has  been  evaluated:  the 
‘Specialised Education Programmes in Key Capacity Areas’ under the Digital Europe Programme49. More 
skills-focused initiatives can be expected to follow as STEP implementation continues. 

Financial support to STEP objectives under cohesion policy 

The STEP Regulation introduced flexibilities and incentives to encourage Member States to reprioritise 
their cohesion policy programmes50 by adding dedicated STEP priority axes.  

As of 31 March 2025, STEP was on track to deliver a successful mobilisation of cohesion 
policy resources. A total of 38 STEP-related programme amendments had been approved by 
the  Commission,  representing  commitments  to  implement  STEP-related  investments  of 
EUR 6.3 billion in cohesion policy funding from the European Regional Development Fund (ERDF), 
the  European  Social  Fund  Plus  (ESF+),  and  the  Just  Transition  Fund  (JTF)  in  11  Member  States. 
Investments  in  skills  development  account  for  about  15%  of  the  allocation 51.  See  Annex VI  for  a 
complete overview of the cohesion policy programmes amended for STEP, across Member States and 
regions. 

FIGURE 3: COHESION POLICY FUNDING REPROGRAMMED FOR STEP, BREAKDOWN BY 
MEMBER STATE AND FUND 

49 Three further topics, focusing on digital skills, for a total budget of EUR 27 million, were launched under Digital Europe on 14 April 2025. 

50 The  main  flexibilities  and  incentives  introduced  by  STEP  for  cohesion  policy  included:  (i)  the  limited  possibility  to  finance  productive 
investments in businesses other than SMEs under the European Regional Development Fund’s STEP-dedicated priorities; (ii) higher co-financing 
rates of up to 100% at the level of the STEP-dedicated priority; and (iii) 30% of the allocation to STEP priorities being paid by the Commission 
as one-off pre-financing. Upon adoption of the STEP Regulation, 30% pre-financing was also paid to all JTF programmes. On 1 April 2025, the 
Commission  published  a  legislative  proposal  with  targeted  amendments  to  the  regulatory  framework  of  the  cohesion  policy  funds  that 
increases or extends incentives to reprogramming under cohesion policy. For example, restrictions linked to STEP as regards the ceiling set at 
20% of the ERDF/CF allocation for reprogramming are proposed to be removed, the deadline for submitting STEP amendments benefiting from 
the additional one-off pre-financing of 30% is extended to end-December 2025, and the support to businesses other than SMEs under the 
ERDF for STEP is now extended to cover all EU regions.  

51 Data point accounting only for programmes with dedicated STEP priority axes or known amounts dedicated to STEP. 

19 

 
 
 
Source: Member States’ reporting 

It  is  too  early  to  assess  the  effectiveness  of  STEP  under  cohesion  policy,  which  will 
ultimately depend on whether all funds allocated to STEP materialise into projects selected 
for  support.  As  of  the  end  of  March  2025,  calls  for  proposals  had  been  issued  worth  almost 
EUR 2 billion. Out of this, EUR 148 million had been allocated to actual selected projects. Under cohesion 
policy, project selection  under  the allocated funds will take place gradually in the next months and 
years – depending on the adoption dates of the STEP programme amendments, on the planned launch 
and completion dates, and on the nature of the calls. 

At  the  same  time,  several  complexities  have  been  observed  in  the  implementation  of  STEP  under 
cohesion policy. These issues sometimes arise from regulatory and structural differences between the 
programmes within STEP's scope or are related to the design of the platform itself. 

Firstly, the ultimate absorption of committed resources across Member States will depend 
on the availability of a pipeline of eligible STEP-relevant projects in the regions and Member 
States. The mismatch between the locations of (i) the projects, (ii) the financial resources and (iii) the 
incentives might represent a structural obstacle for STEP. 

•  The large number of Seals awarded confirms the existence of such a well-established 
pipeline  across  the  EU.  By  March  2025,  179  STEP  Seals  had  been  awarded  (with  11 
additional STEP Seals awarded under the EIC on 3 April). While cohesion policy funds may 
support any project that meets STEP eligibility criteria and complies with cohesion policy rules, 
the  STEP  Regulation  explicitly identifies  the  STEP  Seal  as  a tool  to  facilitate  the  selection 
process under cohesion policy.   

•  There  might  be  a  mismatch  between  the  geographic  location  of  the  STEP  Seal 
projects and the distribution of cohesion policy funds. All Member States, except for 
Lithuania, have at least one beneficiary who has been awarded the STEP Seal. However, most 
STEP Seal projects are located in regions classified as ‘more developed’ under cohesion policy 
definitions  (see  Figure  4  and  Table  1),  which  traditionally  receive  a  much  lower  share  of 
cohesion policy resources than ‘less developed’ and ‘transition’ regions do. 

•  Additionally, the increased maximum aid intensities introduced for STEP investments (even 
in absence of a Seal) by Section 7.4.3a. of the Guidelines on regional State aid apply only to 
‘initial  investments’  (which  is  already  a  narrower  definition  than  ‘productive  investments’ 
under  STEP)  in  the  less  advantaged  regions  of  Europe  (‘assisted  areas’,  which  are  the 
geographical  areas  where  companies  can  receive  regional  State  aid  to  incentivise 
investments),  in  line  with  the  principles  of  cohesion  policy.  Even  though  some  ‘productive 
investments’ under STEP can be covered by other State aid provisions and guidelines (e.g., 
the  Clean  Industrial  State  aid  Framework 52 ),  some  managing  authorities  from  ‘more 
developed’  regions  have  considered  conditions  attached  to  State  aid  rules  in  the  field  of 
regional  aid  to  be  an  obstacle  to  their  supporting  of  STEP-relevant  manufacturing 
investments, including STEP Seal projects, carried out by large enterprises.  

52 See New State aid framework enables support for clean industry, announced in June 2025. 

20 

 
 
 
 
FIGURE 4.1: DISTRIBUTION OF STEP SEALS ACROSS SECTORS AND MEMBER STATES53 

Source: Member States’ reporting 

53 The map does not include STEP Seals awarded under the EIC as they were awarded after the 31 March 2025 cut-off date for this report. 

21 

 
 
 
 
 
 
FIGURE 4.2: DISTRIBUTION OF STEP SEALS ACROSS SECTORS AND MEMBER STATES  

Date: 31 March 2025 

Source: Member States’ reporting 

22 

 
 
 
 
 
TABLE 1: CONCENTRATION OF STEP SEAL-AWARDED PROJECTS IN MORE 
DEVELOPED REGIONS BY MARCH 2025 (SEE ANNEX VI FOR THE FULL LIST) 

Country 

ES 

IT 

BE 

FR 

SE 

Country 

FR 

BE 

FI 

ES 

ES 

Country 

DE 

FR 

PT 

BE 

BE 

NUTS2 

ES51 

ITC4 

BE21 

FRD2 

SE12 

NUTS2 

FR10 

BE10 

FI1B 

ES30 

ES61 

NUTS2 

DE21 

FR10 

PT1A 

BE10 

BE21 

Cleantech 

Region 

Cataluña 

Lombardia 

Prov. Antwerpen 

Haute-Normandie  

Östra Mellansverige 

Digital tech 

Region 

Île-de-France 
Région de Bruxelles-Capitale / Brussels Hoofdstedelijk 
Gewest 
Helsinki-Uusimaa 

Comunidad de Madrid 

Andalucía 

Biotech 

Region 

Oberbayern 

Île-de-France 

Grande Lisboa 

Région de Bruxelles-Capitale / Brussels Hoofdstedelijk Gewest 

Prov. Antwerpen 

# 

5 

5 

4 

4 

4 

# 

10 

9 

8 

7 

6 

# 

2 

2 

2 

1 

1 

Secondly, the STEP Regulation explicitly encourages ‘cumulative funding’ from several EU 
programmes via the STEP Seal, but in practice, this has proved elusive so far. A key goal of 
the STEP Regulation is to facilitate synergies, including the possibility for a project to obtain funding 
from programmes under both direct and shared management, and to leverage the evaluation/triage of 
projects carried out at EU level. For this, the Regulation introduces the STEP Seal, which can be awarded 
to  high-quality  projects  that  have  been  positively  evaluated  in  a  STEP-related  call  for  proposals 
launched by the Commission, whether or not they receive actual financial support under said call.  

In practice, such combination of resources may be challenging, particularly if a project seeks cohesion 
policy funding while already having received a grant under a Commission programme, due to a mix of 
structural characteristics of STEP itself and factors related to the instruments in the remit of STEP. So 
far, no project with a STEP Seal has received either cumulative or alternative funding. 

•  To address uncertainties as to how cumulating EU budget resources would work in practice, 
the  Commission  drew  up  a  notice  on  synergies  between  Horizon  Europe  and  the  ERDF54, 
which  sets  out  a  clear  step-by-step  guide  and  timeline  for  cumulating  funding  from  a 
programme  under  direct  management  and  a  cohesion  policy  fund.  Although  workable  in 
theory,  the  proposed  solution  does  not  cover  the  full  spectrum  of  potential  cases  of 

54 See Synergies between Horizon Europe and ERDF programmes. 

23 

 
 
 
 
cumulation and places rather heavy demands on both the Commission and the managing 
authority,  requiring  very  close  coordination  all  the  way  from  the  launch  of  the  calls  for 
proposals – something that can rarely happen in practice. 

•  A first issue emerging when trying to implement cumulation of directly managed resources 
with  cohesion  policy  funds  relates  to  the  differing  methodologies  used  by  the 
Commission  and  granting  authorities  to  reimburse  costs  under the  respective  funding 
instruments. Under the programmes it manages directly, the Commission frequently uses 
‘simplified  cost  options’  55 ,  which  base  reimbursements  on  cost  estimations  or  on  the 
achievement of predefined milestones. Aligning these methods with reimbursement systems 
that  rely  on  actual  incurred  costs  (frequently  used  under  cohesion  policy  programmes)  is 
challenging,  particularly  in  terms  of  ensuring  compliance  with  Article  63(9)  of  Regulation 
2021/1060 (Common Provisions Regulation), which prohibits declaring the same expenditure 
under  two  EU  instruments,  and  with  Article  194(3)  of  Regulation  2024/2509  (Financial 
Regulation)56, which prevents any cost item from receiving more than 100% of its funding 
from the EU budget (i.e. risk of overcompensation).  

•  An  additional  obstacle  to  cumulative  funding  (and,  in  this  case,  also  alternative  funding) 
concerns the fact that under certain directly managed programmes within STEP’s scope, the 
STEP Seal is awarded to actions that are implemented by large transnational consortia, 
often  comprising  several  participants  across  multiple  Member  States  (and  therefore  also 
across  multiple  regions)  as  well  as  associated  non-EU  countries.  This  is  an  inherent 
characteristic of certain STEP-relevant funding instruments. It is, for example, the case for 
projects funded under the European Defence Fund and under the Pillar II of Horizon Europe57. 
This  poses  practical  challenges  for  any  potential  uptake  of  such  projects  under  cohesion 
policy, as it may be difficult to ensure alignment with the specific objectives and territorial 
scope of several regional or national cohesion programmes, particularly when cross-border 
actions are involved58. Even when such alignment would exist, a common pool problem might 
still emerge, whereby the managing authority might hold off from providing support due to 
concerns  that  their  relevant  counterparts  in  other  Member  States  might  not  step  in  or, 
conversely, on the hope  that they might be  very invested in the cross-border project  and 
might be prepared to support it in its entirety to ensure that it actually materialises.  

•  While  the  Commission  has  provided  general  guidance  to  the  extent  possible,  managing 
authorities may still face challenges in supporting transnational projects – particularly when 
determining how and when to fund only the portion implemented within their own region or 
Member State. These challenges stem from the inherent complexity and variability of such 
schemes  across  different  directly  managed  programmes,  each  with  its  own  structure, 
objectives, duration, budget and financing arrangements. 

55 Article 125 of the Financial Regulation provides that EU contributions under direct, shared or indirect management may take the form of 
financing  not  linked  to  the  costs  of  the  relevant  operations  based  on:  (i)  the  fulfilment  of  conditions  set  out  in  sector-specific  rules  or 
Commission decisions; or (ii) the achievement of results measured by reference to previously set milestones or through performance indicators. 

56 Article 194 of the Financial Regulation, although allowing for joint financing from separate budget lines, lays down that ‘in no circumstances 
shall the same costs be financed twice by the budget’. 

57 See Article 10(4) of Regulation (EU) 2021/697 of the European Parliament and of the Council of 29 April 2021 establishing the European 
Defence Fund and Article 22 of Regulation (EU) 2021/695 of the European Parliament and of the Council of 28 April 2021 establishing Horizon 
Europe. 

58 See Article 63(4) of Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021. 

24 

 
 
Thirdly, the provisions of the STEP Regulation apply without prejudice to State aid rules. 
When  Member  States  plan  to  finance  projects  having  received  a  STEP  Seal,  they  need  to  verify 
compliance with State aid rules. In some cases, Member States may simply make use of the General 
Block Exemption Regulation (GBER), which exempts Member States from the notification requirement 
and  covers  also  areas  of  relevance  for  STEP,  in  particular  research,  development  and  innovation. 
Otherwise, depending on the nature of the STEP project, different State aid rules may apply (e.g. the 
framework for R&D and innovation, the Clean Industrial State aid Framework, regional aid guidelines, 
climate, environmental protection and energy State aid guidelines). While projects awarded the ‘Seal of 
Excellence’ benefit from specific provisions allowing aid measures under the General Block Exemption 
Regulation (GBER) (such seals are only awarded to excellent SME R&D projects requiring aid amounts 
up to EUR 2.5 million59), there is no equivalent provision for STEP Seals, as these are awarded to a large 
variety of projects under different programmes and based on award criteria that can be very different 
from one call to another. As a result, the State aid treatment of STEP projects will depend on the size 
and type of projects concerned.  While the Commission has provided guidance on the relevant types of 
State  aid  rules  per  type  of  project  and  has  established  mechanisms  to  facilitate  the  State  aid 
assessment in some cases (e.g. ‘grant-as-a-service’60), the absence of any specific State aid treatment 
for STEP projects61 has been mentioned by stakeholders as one aspect that should be reviewed (see 
Annex V on stakeholder consultations). The absence of a specific exemption in the GBER for the STEP 
Seal, similar to that for the Seal of Excellence under Article 25a, may diminish the fast-tracking benefits 
otherwise  associated  with  the  STEP  Seal,  as  conducting  a  specific  assessment  per  project  on  the 
applicable State aid rules and on the maximum possible aid is a complex and time-consuming process, 
including because of the need for managing authorities to sometimes involve other national entities, 
e.g. those in charge of competition.  

Some of the difficulties perceived by some public and private stakeholders were addressed 
by the recent legislative proposal by the Commission as part of the mid-term review62 of 
the cohesion policy funds. This proposal includes additional facilitation and incentives for Member 
States to further support investments contributing to STEP objectives. 

Financial support to STEP objectives under the RRF and InvestEU 

As  of  31 March 2025,  STEP  had  not  yet  succeeded  in  mobilising  resources  under  the 
Recovery and Resilience Facility (RRF) and InvestEU. No recovery and resilience plan had been 
amended to include a STEP Seal-awarded project, and no Member State had made use of the increased 

59 See Articles 25, 25a and 25b of Commission Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories of aid compatible 
with the internal market in application of Articles 107 and 108 of the Treaty. 

60 The Commission has developed the concept of ‘Grants-as-a-Service’ according to which Member States can implement State aid schemes 
specific to support projects having passed the evaluation process of the Innovation Fund (which includes projects awarded a STEP Seal and 
targets in particular projects in industrial decarbonisation, energy efficiency and energy generation). Provided that the scheme fulfils certain 
conditions that build upon the identified synergies between the Innovation Fund and the State aid assessment, the scheme can be approved 
under the Clean Industrial Deal State Aid Framework which will allow the Commission to assess swiftly. The Member States have not yet made 
use of this possibility. 

61 Except in cases of a so-called double award, where a project is awarded both a Seal of Excellence and a STEP Seal (which can occur in the 
case of EIC Accelerator Challenges). 

62 See EUR-Lex - 52025PC0123 - EN - EUR-Lex. 

25 

 
 
possibility to allocate funds to the InvestEU Member State compartment for STEP-relevant investments 
(STEP MS-C)63. 

The STEP Regulation amended the RRF64 and InvestEU65 Regulations to introduce options66 for Member 
States to consider STEP priorities within the two programmes. This was intended to unlock a strong 
investment  potential,  mainly  driven  by  the  possibility  to  contribute  to  the  InvestEU  Member  State 
compartments. However, it is important to note that these options are voluntary and not accompanied 
by additional incentives, in contrast with those provided under cohesion policy. 

Consequently, the limited mobilisation of STEP-related funding under the RRF may reflect a broader 
reluctance by Member States to reallocate resources through these channels.  

The  adoption  of  the  STEP  Regulation  more  than  halfway  through  the  implementation  of  the  time-
limited  RRF  did  not  encourage  Member  States  to  use  the  opportunities  offered  under  the  RRF  and 
InvestEU.  The  slow  uptake  of  these  opportunities,  particularly  in  comparison  to  cohesion  policy 
mobilisation,  may  be  due  to  several  factors.  Member  States  are  primarily  focused  on 
implementing their current recovery and resilience plans, given the August 2026 deadline to 
achieve all milestones and targets under the RRF67, which may reduce their willingness to amend plans 
to include STEP Seal-awarded projects. Moreover, the first batch of STEP Seals was awarded in late 
2024  to  projects  that  had  just  started  or  had  yet  to  start  and  typically  had  timelines 
extending beyond the August 2026 RRF final deadline. 

The  opportunity  to  transfer  resources  from  the  RRF  allocation  to  the  InvestEU  Member  State 
compartment could allow final beneficiaries to receive funding until December 2028, if the contribution 
agreement  between  the  Member  State  involved  and  the  Commission  is  signed  and  all  investment 
operations are approved by the InvestEU Investment Committee by August 202668. Several obstacles 
are, however, hindering the take-up of this possibility. 

•  Using  a  STEP-aligned  InvestEU  Member  State  compartment  requires  either  that  InvestEU 
implementing partners set up new STEP-aligned financial products or that they use existing 
financial  products.  The  first  approach  risks  a  timeframe  beyond  the  RRF  deadlines.  The 
second  approach  –  while  easier  in  the  earlier  implementation  phase  –  adds  to  the 
administrative burden on implementing partners, who would be required to provide additional 
ex post reporting on a per-transaction basis to justify STEP alignment. 

63 However, eight Member States (Bulgaria, Czechia, Finland, Greece, Malta, Romania, Spain and Portugal) have contributed to their InvestEU 
Member State compartments, five of them using RRF resources, for non-STEP specific objectives. 

64 See Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience 
Facility. 

65 See Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the InvestEU Programme and 
amending Regulation (EU) 2015/1017. 

66 Member States are allowed to allocate 6% of their RRF resources to the InvestEU Member State compartment for investments in STEP-
relevant technologies. This is in addition to the existing option of transferring up to 4% of RRF funds to InvestEU for broader purposes, enabling 
a  combined  transfer  of  up  to  10%.  Member  States  are  also  required  to  prioritise  STEP  Seal-awarded  projects  when  revising  their  RRPs. 
Furthermore, the STEP Seal must be considered by both the Commission and Member States in consultations on investments by the European 
Investment Bank (the main InvestEU partner) and during policy checks on investments by other InvestEU implementing partners. 

67 See Article 14 of Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the Recovery 
and Resilience Facility. 

68 See Article 13(7) of Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the InvestEU 
Programme and amending Regulation (EU) 2015/1017. 

26 

 
 
•  The option to contribute up to 6% of a Member State’s RRF envelope to the InvestEU Member 
State compartment in support of STEP objectives is additional to the pre-existing possibility 
of transferring up to 4% without thematic restrictions. The fact that no Member State has 
contributed the full 4% of its initial envelope already reflects limited appetite – making it 
unsurprising that interest in the STEP-specific compartment, which imposes a narrower scope, 
is even lower.  

The single EU portal and the simulator 

The STEP Regulation requires the interim evaluation to assess how effectively STEP: (i) has brought 
together all STEP-relevant EU funding opportunities in a single portal; and (ii) has set up a simulator to 
guide project promoters towards suitable EU funding opportunities for their projects. 

As of 31 March 2025, the ‘Get Funding’ section of the STEP Portal featured information on 
70 calls for proposals – 41 of which were still open, including two procurement calls – and received 
over 4 000 visits per month. From that section, users can access all necessary information on STEP-
relevant calls, including those under EU  programmes under direct management and national/regional 
cohesion  policy  programmes,  such  as  those  in  Germany  (Bavaria,  Baden-Württemberg,  Schleswig-
Holstein,  North  Rhine-Westphalia),  Romania,  Italy  (Lombardia),  Latvia,  and  Denmark  (Syddanmark, 
Nordjylland). Project promoters can apply directly through the STEP Portal, which redirects them to the 
relevant application websites. For example, calls launched by the Commission link to its Funding  & 
Tenders Portal69. By doing so, the STEP Portal avoids duplicating entry points and instead helps users 
access  existing  tools  more  easily.  To  support  this  simplification,  many  STEP-related  funding 
programmes – such as the Digital Europe Programme – now reference STEP on their websites and 
include cross-links to the portal. 

As of 31 March 2025, the ‘For Investors’ section featured details on 142 projects70 awarded 
the  STEP  Seal71 across  Member  States  and  collected  over  2 000  page  views  per  month, 
generating  visibility  for  projects  and  increasing  their  chances  of  getting  alternative  or  cumulative 
funding. The result is even more relevant considering that the first projects awarded the 
STEP  Seal  were  published  only  in  December  2024.  The dashboard includes project identifiers, 
locations  and  funding  statuses,  along  with  an  interactive  map  for  navigating  project  locations  and 
promoters. 

The portal’s success is reflected in traffic analytics, showing an average monthly growth rate of 
around 20% in key statistics, including unique visitors, visits accounting for multiple page views, 
and  total  page  views.  Most  visitors  come  from  the  Member  States  where  most  STEP  Seals  were 
awarded, namely Spain, Italy, Belgium and France. Additionally, an EU-wide survey conducted shortly 
after the STEP Portal’s launch (see Section 4.2 on efficiency and Annex V on stakeholder consultations) 

69 See EU Funding & Tenders Portal. 

70 An additional batch of projects under the Digital Europe Programme and the EIC have been awarded the STEP Seal but were published only 
at the end of April 2025 due to technical and administrative procedures for publication. 

71Article  125  of  Regulation  (EU,  Euratom)  2024/2509  on  the  financial  rules  applicable  to  the  general  budget  of  the  Union  (the  ‘Financial 
Regulation’) requires the Commission to publish information on recipients of EU funds. Therefore, the Commission can only publish projects 
that have received financial support, or those that, even if not financially supported, have consented to the publication of their details. This 
explains why only 142 projects are published out of the 179 awarded STEP Seals.  

27 

 
 
found that, although only 25% of respondents were familiar with the portal, 90% of them reported a 
positive experience and found the information they needed. 

FIGURE 5: DEVELOPMENT OF THE KEY ANALYTICS OF THE STEP PORTAL 

Source: STEP Task Force reporting 

These results confirm the STEP Portal’s effectiveness as a central resource for stakeholders, despite 
some considering it still too fragmented or limited in functionality. An area for improvement is the STEP 
Portal’s visibility and outreach: efforts should focus on increasing awareness among target sectors (e.g. 
biotechnologies), driving additional traffic to useful resources (e.g. dashboard of the STEP Seals), and 
consistently reminding users that applications for five of the 11 programmes must still be submitted 
via the Funding & Tenders Portal. 

In line with Article 8(2), point (d), of the STEP Regulation, the Commission is developing an 
AI-based  simulator  to  help  project  promoters  identify  the  most  relevant  EU  funding 
opportunities based on their project specifications. A minimum viable product is planned for Q3-
2025, pending compliance with technical and security requirements and validation at corporate level. 
A beta version will be tested by a selected group of users. 

Some  initial  conclusions  can  already  be  drawn  regarding  the  simulator’s  feasibility.  The 
fragmentation of information across a wide range of portals reflects the complexity of the EU budget 
architecture – characterised by numerous funding programmes, over 140 action types, and especially 
differing publication practices across direct, indirect and shared management modes. 

While  the  Funding  &  Tenders  Portal  provides  information  on  centrally  managed 
programmes, national and regional funding opportunities are published on Member State 
websites (estimated to number around 400). Existing tools such as the Access to EU Finance portal, 
which is a central database of all repayable forms of finance supported by the EU, and the InvestEU 

28 

 
 
Portal only partially address the current dispersion of  information on repayable  instruments (loans, 
guarantees and equity) by linking users to local intermediaries or investment matchmaking platforms. 

From  a  technical  perspective,  the  lack  of  harmonised  publication  standards  and  limited 
interoperability  across  databases  hinder  the  development  of  a  truly  comprehensive  and 
intelligent  search  engine.  As  a  result,  project  promoters  –  particularly  SMEs  and  smaller 
organisations – face difficulties in accessing information on relevant EU funding, leading to uneven 
access and missed opportunities across the EU. 

The STEP Portal, with its simulator project, is a testing ground for the next MFF for the set-up of a 
single  point  of  entry  for  beneficiaries  to  all  EU  funding  and  advisory  services,  as 
recommended  in  the  Commission  Communication  ‘The  road  to  the  next  multiannual  financial 
framework’. 

4.2 Efficiency  

This  section  assesses  how  the  costs  of  implementing  the  Platform  compared  with  its 
benefits, including an assessment of administrative burden and complexity pertaining to its design, 
governance and implementation. 

Efficiency of STEP instruments  

Some of the instruments and flexibilities introduced by STEP have clear potential benefits, such as the 
possibility to mobilise more funding for strategic technologies by supporting STEP Seal projects and 
transferring RRF resources to InvestEU Member State compartments.  

At the same time, the implementation of these instruments is hampered by inefficiencies. As 
developed further in Section 4.1 on effectiveness, combining funding is a complex process, demanding 
intensive  coordination  and  facing  legal  obstacles.  Complications  arise  from  differing  cost 
reimbursement methods, which make it hard to align and comply with EU budget rules, particularly to 
avoid double funding. The diversity in terms of minimum award criteria and the large variety of project 
types also call for using different types of State aid compatibility, making it a bit more difficult for 
Member States to identify the applicable State aid rules, in turn impacting the efficiency of the tool. 

Moreover, administrative burden and timeline misalignment for setting up new STEP-aligned financial 
products hampers the efficiency of STEP and the full use of possibilities for mobilising STEP investment 
under InvestEU (via the Member State compartment).  

STEP’s effect on internal coordination among EU funding programmes 
and coordination with national/regional authorities    

STEP  is  a  novel  instrument  for  improving  coordination  among  existing  EU  funding 
programmes towards joint strategic objectives. To that end, a new, small task force was created 
within  the  Commission’s  Directorate-General  for  Budget  to  coordinate  a  number  of  Commission 
departments (DGs) and external stakeholders, including Member States.  

29 

 
The internal network set up within the Commission, with 14 departments72 managing or involved 
in EU funding programmes under the remit of STEP, has so far met 9 times73, to align and facilitate the 
implementation  of  STEP.  This  coordination  effort  has  mobilised  EU  programmes  in  different 
management  modes  (e.g.  direct,  indirect  and  shared),  towards  shared  priorities:  the  promotion  of 
investment in the best EU projects on clean tech, deep and digital tech and biotech.  

Coordination with Member States was ensured via a newly created network of STEP national 
contact points (see Section 3). Over the course of 2024, all Member States but Ireland had appointed 
a contact point, and the network has met 5 times, allowing Members to share their national experience 
and the Commission to provide clarity on the requirements for implementing STEP.  

The Commission developed a number of informative materials during the reporting period, 
to  facilitate  the  implementation  of  STEP  (see  Section  3).  The  Commission  also  frequently 
presented STEP Seal projects to managing authorities / national contact points. In the first year of STEP 
implementation,  the  STEP  Task  Force  held  outreach  missions  in  Germany,  France,  Estonia,  Latvia, 
Lithuania, Romania, Slovenia and Portugal, where it met with public authorities, industry associations, 
SMEs, start-ups and financial intermediaries. 

This  increased  coordination  also  generated  costs.  Implementing  STEP  across  programmes 
operating  under  different  rules,  timelines,  and  legal  bases  was  an  operational  challenge.  This  is 
exemplified by the number of meetings that have taken place as part of the STEP network, which each 
required the mobilisation of operational resources by the Commission (albeit as limited as possible).  

Effort was also needed to adapt processes (e.g. ownership and control assessment of organisations 
participating  in  calls  that  included  participation  restrictions,  for  security  reasons)  and  upgrade  IT 
systems  (e.g.  flag  for  STEP  topics,  automatic  generation  of  the  STEP  Seal  certificates  under  the 
Funding&Tenders Portal, information for applicants), as well as assess amendments to cohesion policy 
funds.  

The Commission made efforts to minimise such operational costs. STEP did not create new 
staffing costs at the Commission, since this was covered by the internal reallocation of posts within 
the Commission or by staff already working on the programmes under STEP.  

STEP’s effect on the fragmentation of the funding landscape  
at EU level  

While  seeking  to  promote  consistency  and  synergies  across  funding  programmes,  STEP  is  not 
designed to eliminate the fragmentation of the funding landscape at EU level as it does not 
merge or limit the number of programmes. Still, the STEP Portal and coordination efforts aim to 
simplify users’ interface with the EU funding landscape. Limited coordination between programmes, 
varying governance structures and timing mismatches limit efficiency (as well as effectiveness and 
coherence) and increase complexity, in particular from the perspective of project promoters.  

72 DG Budget; the Reform and Investment Task Force; DG Economic and Financial Affairs; DG Regional and Urban Policy; DG Research and 
Innovation; DG Health and Food Safety; DG Climate Action; DG Defence Industry and Space; the Health Emergency Preparedness and Response 
Authority; DG Employment, Social Affairs and Inclusion; DG Internal Market, Industry, Entrepreneurship and SMEs; DG Communications Networks, 
Content and Technology; DG Competition; and the Secretariat-General. 

73 As of end of April 2025. 

30 

 
 
EU financing instruments are designed to serve diverse objectives and support a wide range of policies 
and  priorities,  frequently  in  an  uncoordinated  manner.  Overall,  today,  the  EU  manages  close  to  50 
funding  programmes,  sometimes  with  multiple  –  occasionally  intersecting  –  objectives  and  using 
different instruments. As  outlined in the Commission Communication entitled  ‘The road to the next 
multiannual financial framework’74, this fragmentation – coupled with complexity and lack of flexibility 
in reallocating funding – weighs on the effectiveness of EU funding. 

Zooming in on STEP, the variety of the 11 programmes under the STEP remit75 may hamper 
its efficiency. One issue is the lack of alignment in timelines among the different programmes: Some 
projects funded at central EU level have timeframes that extend beyond the legal timespans of some 
of the cohesion policy programmes, limiting the possibility that the two sources of EU funding could be 
combined. STEP does not alter the full spectrum of underlying objectives reflected in the programmes’ 
respective  legal  bases,  meaning  there  are  structurally  varying  degrees  of  alignment  towards  STEP 
objectives across the different programmes.  

Simplified access to funding for beneficiaries and reduced cost for 
accessing the EU budget  

The complexity of the EU budget generates costs for applicants / project promoters. This is 
evidenced by an EU-wide survey on access to EU funding from mid-September to end of October 2024, 
carried out by the STEP Task Force (referred to in Section 3.1 and Annex V on stakeholder consultations), 
which received almost 500 replies from all 27 Member States.  

In  parallel  30  bilateral  interviews  took  place  with  a  sample  of  potential  beneficiaries,  industry 
associations,  national  contact  points  from  various  programmes  and  consulting  companies.  The 
conclusions were similar.   

Key takeaways:   

1.  Applicants face challenges in finding information on EU funding  

IS INFORMATION ON EU FUNDING EASY TO FIND? 

Source: EU-wide survey on access to EU funding conducted from mid-September to end of October 2024 

74 See Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social 
Committee and the Committee of the Regions, The road to the next multiannual financial framework. 

75 Of  which  5  programmes  are  managed  directly  by  the  Commission,  5  funded  through  national  pre-allocated  budgets  under  shared 
management and 1 implemented via indirect management with implementing partners. 

31 

 
 
 
CHALLENGES WHEN LOOKING FOR FUNDING INFORMATION (% OF USERS) 

Source: EU-wide survey on access to EU funding conducted from mid-September to end of October 2024 

•  Both new and experienced users score the easiness of finding info on EU funding at only 
5/10, indicating that the overall experience is challenging, regardless of the user’s level 
of experience.  

•  Most indicated that the struggles are related to the awareness and identification phases, 
confirming that the current landscape of EU funding opportunities is too difficult to read 
and navigate through (‘I need to scan very often for new information [no useful reminders]’, 
‘I get confused on the overall timelines [opening, closing, due date]’, ‘it’s hard to understand 
eligible funding amounts [what are the eligible costs]’) . 

•  Therefore, users must rely heavily on external support: they look in particular for free 
resources  like  events  and  webinars,  but  33%  of  users  need  to  rely  on  paid  professional 
experts or consultants for guidance. Identifying EU funding opportunities has thus a cost for 
stakeholders even before they start the application process.  

2.  Stakeholders would like to see a clear and easy EU funding portal 

•  Official channels remain the main source of info. Expectations are thus high among the 
stakeholders for a clear, easy-to-navigate and understand portal that hosts all the funding 
opportunities stemming from the EU budget.  

•  Non-official  sources  such  as  events  and  professional  networks  are  used  heavily  for 

additional information and updates.  

The STEP Portal addresses a number of these shortcomings, such as the complexity of navigating 
multiple  portals  across  management  modes,  lack  of  interoperability  between  different  portals  and 
platforms and unequal access to funding information, particularly for SMEs and small organisations. 
Its  user-centric  structure  tailors  content  to  the  needs  of  targeted  audiences  (project  promoters, 
managing authorities, private investors). However, setting up this new Platform generated additional 
costs and required sizeable coordination efforts across Commission departments to pool all 

32 

 
 
the  relevant  information  for  project  promoters.  The  estimated  annual  budget  for  design, 
development  and  maintenance  of  different  STEP  Portal  functionalities  and  features  is  around 
EUR 800 000  per  year,  including  both  the  STEP  Portal's  front  office  (content  management  and 
dashboard development) and the back office (calls management application). 

Focus of the STEP scope  

STEP introduced a set of detailed objectives and conditions (Article 2 of the STEP Regulation), 
as well as a precise scope regarding the targeted strategic technologies (digital and deep technologies, 
clean and resource-efficient technologies and biotechnologies). This is due to the nature of STEP as an 
instrument targeting only specific technological readiness levels. These requirements came on top of 
existing requirements and the scope of EU programmes covered by STEP. 

Under Article 2(7) of the STEP Regulation, the Commission published a guidance note to clarify 
the STEP objectives76 (including key concepts, such as value chains and associated services, as well 
as highlighting the focus of STEP on development and manufacturing, excluding fundamental research 
and deployment activities), clarify the definition of the three sectors prioritised by STEP (including an 
indicative list of technologies), and explain the conditions to meet to be considered critical. This helped 
stakeholders implement STEP consistently across Member States and the 11 funding instruments and 
gave useful information to potential beneficiaries.  

However, the very precise definition of the scope of activities to be supported by STEP may 
be difficult to grasp for project promoters, possibly hindering the efficiency of the initiative. The 
STEP Task Force has been working to minimise the possible burden linked to understanding the scope 
of STEP, through extensive consultations with research and industry stakeholders, as well as regular 
contacts with NCPs and managing authorities.   

How efficient are STEP’s reporting and monitoring processes 

As per Article 7 of the STEP Regulation, reporting requirements under STEP  build  on  the  existing 
reporting requirements in the EU programmes contributing to STEP. As specified in the legal 
basis, the monitoring of STEP implementation is targeted and proportionate to the activities carried out 
under STEP, and recipients of EU funding only contribute with data for monitoring based on the existing 
reporting  requirements  for  the  funding  programme  to  which  they  apply,  where  necessary  and  in  a 
proportionate manner (no new reporting requirement has been imposed on beneficiaries of EU funding 
under STEP).  

To  this  end,  the  STEP  Task  Force  has  set  up  a  monitoring  system  tailored  to  each  contributing 
programme, to align with its specific reporting  practices.  This has been  formalised within  the STEP 
Commission network, to define how to report on STEP-contributing activities under each programme.  

While this approach intends to minimise reporting burden, the pre-existing heterogeneity of 
reporting requirements across programmes (also reflecting specificities in the programmes’ legal 
bases) hampers the comparability of data and limits  STEP’s efficiency. It proved difficult to 
build  a  comprehensive  monitoring  framework  for  the  performance  of  EU  funding  for  strategic 
technologies. For example, for some programmes it is easier to obtain a breakdown by sector of support 

76 See Guidance Note concerning certain provisions of Regulation (EU) 2024/795 establishing the Strategic Technologies for Europe Platform 
(STEP). 

33 

 
 
provided, or by stage of development / technological readiness level, for others this is not immediately 
possible, or it may become possible only with a long delay.  

Despite progress in recent years77, for some purposes the monitoring frameworks for the different EU 
programmes remain heterogenous, which reduces the capacity to measure the EU budget performance 
and inform policy making, especially on a general priority such as STEP. 

4.3 Coherence  

Coherence among the EU funding instruments covered by STEP  

STEP was introduced with the overarching goal of increasing coherence across the diverse 
set of existing EU funding programmes, to align them towards the specific priorities of STEP 
(see Section 4.1 on effectiveness). So because it does not qualify as a standalone programme, STEP 
cannot be assessed for its consistency with other EU funding instruments. Rather, it should be evaluated 
based on its capacity to foster consistency among the programmes within its remit to support STEP 
objectives. 

Prior  to  STEP’s  introduction,  the  11  EU  funding  instruments  now  under  its  scope  were 
already supporting what would later be defined as STEP priorities – albeit to varying extents 
and  in  an  uncoordinated  manner  (see  Section  2.2  on  point(s)  of  comparison).  An  advance  
assessment of the extent of this support is not feasible, as the concept of ‘strategic technologies’ was 
previously subject to divergent, and sometimes conflicting, interpretations.  

For  example,  STEP  priorities  in  cohesion  policy  were  pursued  across  several  policy  objectives.  The 
introduction of two new STEP-relevant specific objectives under the ERDF and CF Regulation, alongside 
the  establishment  of  dedicated  STEP  priority  and  specific  intervention  fields,  has  brought  greater 
consistency and precision to how such investment is identified and pursued. A similar shift occurred in 
programmes under direct management, where calls for proposals must now explicitly refer to STEP to 
be considered to be contributing to its objectives. 

In its policy steering role, the Commission has clarified the scope of STEP through a dedicated 
Guidance  Note 78 ,  to  encourage  consistent  interpretation  of  STEP  objectives  and 
requirements across funding instruments, particularly where the boundary between eligible and 
non-eligible investment is not always clear. 

To further reinforce this consistency, the STEP Task Force has carried out a second-level review 
of proposed STEP-relevant calls and individual projects. These efforts help to mitigate the risk 
of  ‘STEP-washing’,  enhance  the  visibility  and  distinctiveness  of  STEP  investment  and  support  the 
emergence of a recognisable STEP brand. However, ensuring full coherence across instruments where 
the Commission has varying levels of visibility and control – ranging from project-level detail under 
direct management programmes to often broader, programme-level frameworks under cohesion policy 
– remains a challenge. 

77 See the 2021 Communication on the Performance Framework of the EU budget, available at EUR-Lex - 52021DC0366 - EN - EUR-Lex. 

78 Commission  Communication  C/2024/3209,  Guidance  Note  concerning  certain  provisions  of  Regulation  (EU)  2024/795  establishing  the 
Strategic Technologies for Europe Platform, 2024, available at EUR-Lex - 52024XC03209 - EN - EUR-Lex. 

34 

 
 
This consistency challenge extends to cohesion policy amendments, aligning funding under 
shared management (e.g. cohesion policy funds) with that under direct management (e.g. 
the Innovation Fund). For example, the Commission has developed a general methodology to support 
first-of-a-kind electrolyser projects, using technical criteria such as capacity, technological innovation, 
and the novelty of the integrated business model.  

This  effort  has  also  had  spillovers  into  the  reporting  framework  for  the  EU budget, 
contributing to increased transparency and accountability. In particular, beginning with 2025 
reporting  (on  the  2024  financial  year),  the  Commission’s  Annual  Management  and  Performance 
Report79 on the EU budget will also cover how each EU funding programme contributes to supporting 
the strategic technologies in the STEP remit. 

Some  challenges  have  resulted  from  regulatory  and  structural  divergences  within  the 
programmes covered by STEP, which have limited its full potential, as anticipated in Section 
4.1 on efficiency. For example, several Member States presented examples of projects that had been 
awarded the STEP  Seal under the Innovation Fund but which are potentially ineligible for support from 
the ERDF and the Just Transition Fund (JTF) because of regulatory provisions80 in these funds ruling 
out their use to finance installations covered by the Emissions Trading System (ETS).  Note that this 
applies to many projects assessed under the Innovation Fund, and thus many projects awarded a STEP 
Seal so far.81 

These  examples  illustrate  that,  while  STEP  has  initiated  a  valuable  process  to  improve  internal 
coherence  among  EU  funding  instruments,  more  is  needed,  including  in  terms  of  reviewing  the 
coherence of different pieces of legislation with one another. This lesson informs the ongoing work 
towards designing a more impactful budget for the next MFF, as discussed in both the Commission’s 
Political Guidelines and the recent Communication on the road to the next MFF. 

External Coherence between STEP and other initiatives not covered by 
STEP.  

The  STEP  Regulation  aims  to  achieve  coherence  between  STEP  and  other  compatible 
initiatives. 

The  EU  Net-Zero  Industry  Act  (NZIA)  and  the  Critical  Raw  Materials  Act  (CRMA)  both  establish 
frameworks for identifying strategic projects essential to the EU’s resilience and competitiveness, which 
typically contribute to STEP objectives. Similarly, the technologies supported by Important Projects of 
Common European Interest (IPCEI) are to be deemed critical technologies for the purpose of STEP when 
they fall within the three STEP sectors. 

While  such  projects  are  generally  considered  to  contribute  to  STEP  objectives,  their  eligibility  for 
financing under STEP is not automatic. STEP funding remains subject to separate eligibility criteria, and 

79 See Annual management and performance reports - European Commission. 

80 Article  7  of  Regulation  (EU)  2021/1058  of  the  European  Parliament  and  of  the  Council  of  24 June  2021  on  the  European  Regional 
Development  Fund  and  on  the  Cohesion  Fund  and  Article  9  and  Article  11(2),  point  (h),  of  Regulation  (EU) 2021/1056  of  the  European 
Parliament and of the Council of 24 June 2021 establishing the Just Transition Fund. 

81 On 1 April, the Commission published a legislative proposal with targeted amendments to the regulatory framework for the cohesion policy 
funds, including allowing investment related to production, processing, transport, distribution, storage or combustion of fossil fuels, in operations 
that received a STEP Seal under the Innovation Fund and more support from the ERDF for decarbonisation projects awarded a STEP Seal (e.g. 
under the Innovation Fund). 

35 

 
 
strategic  designation  alone  does  not  guarantee  financial  support.  In  addition,  NZIA/CRMA  strategic 
projects and IPCEIs in STEP sectors do not benefit from the facilitations that are provided to projects 
that have received a STEP Seal. 

Nevertheless, the designation of a project as strategic under NZIA or CRMA, as well as IPCEI 
projects, may encourage Member States to support these projects under STEP, particularly in 
the  context  of  cohesion  policy  reprogramming.  In  this  respect,  STEP  incentivises  the  alignment  of 
national investment choices with EU-level priorities. 

4.4 EU added value  

STEP  delivers  clear  EU  added  value  by  enforcing  coordination  and  consistency  across 
different layers of public funding – EU, national, and regional – to maximise support for 
investment  in  strategic  technologies  and  its  impact.  This  level  of  alignment  could  only  be 
achieved at EU level, given the need to steer and combine resources that are managed both centrally 
and  across  Member  States.  It  helps  align  various  programmes  along  the  same  priorities  and  steer 
funding under direct, indirect or shared management towards the development and manufacturing of 
digital and deep technologies, clean technologies and biotechnologies (see Section 4.3 on coherence).  

STEP aims to increase consistency between the EU level and the national/regional level, in 
particular through the STEP Seal, by directing cohesion policy funding toward projects with 
high  strategic  value  for  the  EU  as  a  whole.  The  strong  engagement  of  managing  authorities 
suggests that the financial and other incentives provided under the STEP Regulation (see Section 4.1 
on effectiveness) may be effective in encouraging Member States to invest in strategic projects that 
deliver EU added value. Nevertheless, the STEP Seal is yet to prove itself as a successful tool in enabling 
cumulative or alternative funding from national and regional EU resources to strategic projects. 

The  STEP  Portal  also  brings  EU  added  value  by  promoting  easier  access  to  funding 
information  across  EU  programmes,  in  particular  for  SMEs  and  smaller  organisations.  It  brings 
together all funding opportunities afforded by the EU budget for STEP-relevant projects. The survey on 
access to EU funding (see Section 4.2 on efficiency) reported that ‘72% of users see value in a one-
stop shop for EU and national funding’, as opposed to the same information being dispersed across 
EU-level and national depositories. Users cited time savings and clarity among the key benefits. 

4.5 Relevance  

From the outset, STEP was designed to help as part of a broader set of initiatives to make 
European industry more competitive and resilient. Among these strategic initiatives is the Green 
Deal Industrial Plan, which serves as the EU’s roadmap for supporting industry in the swift transition to 
climate neutrality.  

By design, STEP works in synergy with key legislative initiatives and policy networks such as the Net-
Zero Industry Act and the Critical Raw Materials Act (see Section 4.3 on coherence). STEP is also aligned 
with  the  objectives  of  the  European  Chips  Act 82 ,  to  bolster  Europe’s  resilience  in  semiconductor 
technologies and applications, and boost the EU's share of the global microchips market. Moreover, 

82 See Regulation (EU) 2023/1781 of the European Parliament and of the Council of 13 September 2023 establishing a framework of measures 
for strengthening Europe’s semiconductor ecosystem. 

36 

 
 
STEP also fits with EU action to identify its strategic dependencies: the updated ‘2020 New Industrial 
Strategy’83,  in-depth  reviews  of  dependencies  in  different  strategic  areas84,  the  European  Economic 
Security Strategy85.  

STEP’s continued relevance has been confirmed in the priorities announced at the outset of 
the second von der Leyen Commission. The President’s Political Guidelines for 2024-2029 highlight 
the  urgent  need  for  the  EU  to  invest  in  its  competitiveness.  The  Draghi  report  on  the  future  of  EU 
competitiveness called for decisive action to promote economic growth, including through additional 
investment.  

The Competitiveness Compass highlights that ‘the STEP experience so far shows the added value of 
refocusing  the  EU  budget  support  around  clear  and  shared  competitiveness  priorities’86.  The  Clean 
Industrial Deal outlines the EU’s plan for enhancing competitiveness and decarbonisation, including by 
strengthening EU funding for clean technologies – a priority that is already promoted by STEP. It further 
calls for enhancing synergies between existing funding instruments to maximise the financing of STEP 
Seal projects across regions in the EU.  

As identified in the Joint White Paper for European Defence Readiness 2030, the EU should 
do more to support the urgent need to increase European defence investment with the EU 
budget, against the backdrop of the unprecedented geopolitical instability. While support for several 
defence technologies – like drones, cyber technologies or AI – was possible under STEP’s initial scope, 
President von der Leyen identified, in her letter to EUCO members on 6 March 2025, the enlargement 
of STEP’s scope to all defence technologies as an option to incentivise defence-related investment with 
the EU budget.  

Therefore,  on  22 April 2025  the  Commission  adopted  a  proposal  for  a  Regulation  to  extend  STEP’s 
scope, creating a fourth sector covering all defence technologies, as well as to amend some of the 
programmes  covered  by  STEP  (e.g.  EDF,  DEP,  HE)  to  optimise  their  capacity  to  mobilise  the  EU’s 
resources towards defence.  

This proposal complements the Commission’s proposal for a Regulation in the context of the mid-term 
review of the cohesion policy adopted earlier in April 2025. This proposal would use the incentives for 
cohesion  policy  funds  under  STEP,  which  have  proved  their  effectiveness  as  explained  above,  to 
incentivise the pursuit of additional priorities, besides removing potential barriers presently limiting the 
capacity of cohesion policy funds to support some specific STEP-relevant projects.  

In March 2025, the Commission proposed the Critical Medicines Act (CMA) to improve the 
availability, supply and production of critical medicines within the EU. Under the CMA, strategic 
projects  may  benefit  from  access  to  existing  EU  funding  instrument,  including  funding  facilitation 
through STEP. The CMA amends the STEP Regulation so that strategic projects designated in accordance 
with  the  CMA  which  address  a  vulnerability  in  the  supply  chains  of  critical  medicinal  products  are 
deemed to contribute to the STEP objectives. 

83 See Commission Communication updating the 2020 New Industrial Strategy: Building a stronger Single Market for Europe’s recovery, 2021. 

84  Commission  staff  working  document  on  strategic  dependencies  and  capacities,  2022,  available  at  eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52021SC0352. 

85 Joint Communication on European Economic Security Strategy, 2023. 

86 See Competitiveness compass - European Commission. 

37 

 
 
STEP was designed as  a testing ground, to promote a new approach, also in view of the 
preparations of the next multiannual financial framework (MFF). The Communication on the 
road to the next MFF, adopted on 11 February 2025, outlined the objectives for the next EU budget: 
simpler, more focused and more impactful. STEP promotes the same objectives, albeit on a smaller 
scale. It aims to focus funding programmes on a selected set of strategic sectors, promoting higher EU 
impact. It aims to simplify access to EU funds, and the Communication recognises that the STEP Portal 
provides a first overview of all calls for proposals focusing on strategic technologies, at EU and Member 
State / regional level, for the programmes in STEP’s remit.  

CONCLUSIONS AND LESSONS LEARNED 

5.1 Conclusions 

This mid-term evaluation provides a first, early assessment of STEP one year after its entry 
into  force.  The  assessment  is  taking  place  against  the  five  evaluation  criteria  of  effectiveness, 
efficiency, consistency (‘coherence’), relevance, and EU value added. 

While this interim evaluation responds to the requirements of the STEP Regulation, its early 
delivery limits its reach. Since funding reallocation has in effect just started and is still in progress, 
a fully-fledged assessment of the ultimate impact of  STEP with respect to its objectives  is not  yet 
possible. The report nevertheless reviews progress so far, particularly with respect to steering EU funds 
towards STEP-relevant technologies, and to developing the STEP Seal and the STEP Portal. 

At  this  early  stage,  STEP  appears  to  be  on  track  to  deliver  on  its  objectives.  As  of 
March 2025,  around  EUR 16 billion  had  already  been  earmarked  for  STEP.  This  included 
EUR 9.5 billion mobilised through the programmes under direct management – of which EUR 5.2 billion 
had already been  awarded under the respective STEP-relevant calls – as well as EUR  6.3  billion  in 
redirected funding from cohesion policy programmes. However, no specific financial resources had been 
mobilised as of March 2025 under the Recovery and Resilience Facility (RRF) or InvestEU for STEP-
related projects using the STEP-specific tools, mainly due to the lack of incentives introduced by the 
STEP Regulation for this specific case and the regulatory timeline of the RRF. 

The evaluation confirms the added value of the STEP Seal to identify strategic projects for 
the single market, while highlighting obstacles in leveraging its full potential to catalyse 
investment across the EU. By March 2025, 190 STEP Seals had been awarded87, with the first Seals 
issued in October 2024 following the completion of the selection process for the first STEP-relevant 
calls.  

However,  at  this  stage  no  project  awarded  a  STEP  Seal  has  received  any  alternative  or  additional 
funding  from  Member  States  under  cohesion  policy  resources  or  from  the  RRF.  Combining  funding 
across  EU funding instruments  remains a  challenge.  In many cases, this is  the consequence of the 
necessity for combined financial support for cross-country consortia awarded with a STEP Seal, of the 
lack of any specific State aid treatment for STEP Seals, and of the introduction of such label less than 
two years from the deadline of the RRF. In other cases, the obstacles are posed by the divergent rules 

87 This includes 11 STEP Seals awarded under the EIC on 3 April 2025. 

38 

 
 
of  the  instruments  in  the  remit  of  STEP,  for  example  the  different  methodology  for  assessing  and 
reimbursing the costs of a project or the exclusions of specific technologies under cohesion policy funds.  

The  STEP  Portal  has  become  a  tool  for  simplified  access  to  STEP-relevant  EU funding, 
receiving positive feedback from users. An AI-powered simulator is being developed to further help 
project promoters navigate EU funding opportunities. Efforts are also ongoing to make it more widely 
known among target users.  

STEP adds EU value by enhancing coordination and consistency across EU funding at central, 
national, and regional level with the aim of maximising investment in strategic technologies. 
Such a degree of alignment with shared priorities could only be achieved through EU-level intervention. 
By encouraging national and regional managing authorities to take into account the broader EU-level 
value added, when deciding how to allocate EU funds, STEP steers funding towards projects with high 
potential for the EU as a whole.  

Coordination  across  11  funding  instruments  and  14  Commission  Directorates-General 
entails costs, though these have been kept to a minimum, including by the Commission’s decision 
to carry out these additional activities without extra staff. Most of these costs stem directly from the 
need to bring together funding instruments, whose legal bases are already different and sometimes 
conflicting, under a unique set of STEP objectives and conditions.  

The  continued  relevance  of  STEP  under  the  new  Commission  mandate  was  confirmed,  as 
illustrated by its priority on competitiveness and by the proposal to extend the scope of STEP to defence 
applications. 

5.2 Lessons learned 

STEP model to improve coordination of programmes 

The experience of STEP has so far shown the benefits of increasing coordination between 
funding  programmes  and  different  governance  models,  around  a  targeted  set  of  policy 
objectives. However, this coordination has come with significant operational costs and barriers to the 
full potential in implementation. The Communication on the road to the next MFF highlights that the sheer 
number  of  EU funding  programmes  (more  than  50)  –  all  with  different  eligibility  rules,  application 
processes, co-financing rates and multiple entry points for potential applicants – puts at risk the speed 
and quality of implementation.  

In the same way, the abundance of tools providing technical assistance and support options under these 
programme (around 30) calls for simplification and reduction of overlaps. STEP is an experiment to better 
link EU policy priorities with the EU funding and to create a true single-entry point for beneficiaries to all 
EU funding and advisory services, two of the core objectives of the EU’s next long-term budget.  

STEP as an instrument for increasing synergies between EU programmes 

The experience of the STEP Seal has shown the appetite for a more seamless combination 
of funding between EU funding programmes. At this stage in STEP’s implementation, while STEP 
has been successful in identifying a large number of high-potential projects across the EU under the 
respective programmes, the evaluation also highlights a number of major challenges to deliver on the 

39 

 
objective  of  synergies  in  funding  which  could  be  addressed  more  systematically  as  part  of  the 
Commission’s proposal for the next MFF.  

Single entry point to EU funding  

Today,  EU  funding  opportunities  are presented to  potential  applicants via  multiple  entry 
points. While the STEP Portal serves as a pilot initiative bringing together calls for proposals in different 
management modes in a user-friendly manner for applicants, fragmentation is still present. In fact, 
while the Funding & Tenders Portal centralises information for directly managed programmes, national 
and regional opportunities are spread across an estimated 400 Member State websites.  

Looking ahead – what to make of the lessons learned  

In the short term, in April 2025, the Commission proposed to: (i) expand and extend the financial 
incentives available under STEP in cohesion policy and to enlarge the scope of support from 
the ERDF to those projects awarded a STEP Seal under the Innovation Fund that had been 
established by the EU Emissions Trading System (ETS), as part of the cohesion policy programmes’ 
mid-term review; and (ii) expand the scope of STEP to cover all defence-related technologies88, 
in line with political priorities.  

At the current juncture, other legal amendments to improve the functioning of STEP  do not 
seem warranted – also considering the implementation time that would be needed to see possible 
benefits and the fact that STEP is a temporary instrument expiring with the current MFF at the end of 
2027.  

Still,  many  of  the  lessons  learned  from  STEP  and  its  limitations  in  addressing  existing 
challenges may inform the design of the future MFF, including when it comes to EU funding 
for  competitiveness  and  economic  convergence.  The  next  EU  long-term  budget  will  be  more 
focused,  simpler,  more  flexible  and  deliver  better  on  EU  priorities.  As  announced  in  the  Political 
Guidelines, the Competitiveness Compass, and the Communication on the road to the next MFF, the 
European Competitiveness Fund will establish an investment capacity that will support strategic sectors 
and  technologies  critical  to  EU  competitiveness,  including  research  and  innovation,  and  Important 
Projects of Common European Interest.  

The Fund’s comprehensive architecture will allow it to accompany European projects along the entire 
investment journey, from research, through scale-up, industrial deployment, to manufacturing. It will 
also  help  leverage  and  crowd-in  private  investment.  Some  of  the  key  objectives  of  STEP,  such  as 
ensuring simplified access to funding to beneficiaries with simpler rules and a single-entry point, could 
inspire the design of the next MFF instruments.   

88 Commission proposal for a regulation to incentivise defence-related investment in the EU budget. 

40 

 
 
 
ANNEX I. Procedural information   

The interim evaluation of the Strategic Technologies for Europe Platform was completed in compliance 
with Article 8 of the Regulation establishing STEP89 by the Directorate-General for Budget (BUDG). The 
Decide planning entry is PLAN/2025/10.  

An interservice group helped draft the evaluation, building on the existing STEP Commission network 
across DGs, with valuable input from the Legal Service. The group provided input on the call for evidence, 
intervention logic, evaluation questions and evaluation report.  

Organisation and timing 

Interservice group 
(ISG) created 

March 2025 

Call for evidence 
published, and 
feedback period 

Number of 
interservice group 
meetings 

Discussion on final 
evaluation report in 
ISG 

March 2025-April 2025 

3 

May 2025 

ISC launch 

May 2025 

Participating 
Directorates 
Generals (in addition 
to DG BUDG, Chair) 

SG – Secretariat-General 
SG-REFORM – Reform and Investment Task Force  
ECFIN – Directorate-General for Economic and Financial Affairs 
REGIO – Directorate-General for Regional and Urban Policy 
RTD – Directorate-General for Research and Innovation 
LS – Legal Service  
SANTE – Directorate-General for Health and Food Safety 
CLIMA – Directorate-General for Climate Action 
DEFIS – Directorate-General for Defence Industry and Space 
HERA – Health Emergency Preparedness and Response Authority  
EMPL – Directorate-General for Employment, Social Affairs and Inclusion 
GROW – Directorate-General for Internal Market, Industry, Entrepreneurship  
and SMEs 
COMP – Directorate-General for Competition 
CNECT–  Directorate-General  for  Communications  Networks,  Content  
and Technology 

89 Regulation (EU) 2024/795 of the European Parliament and of the Council of 29 February 2024 establishing the Strategic Technologies for 
Europe Platform, see Regulation - EU - 2024/795 - EN - EUR-Lex. 

41 

 
 
ANNEX II. Methodology and analytical  
models used   

This section describes the evaluation and methodological approach. It provides a brief explanation of 
the overall approach to the evaluation, followed by an overview of the methods adopted, including 
caveats and limitations.  

Approach to the evaluation 

The design of the evaluation was guided by several key considerations: 

•  Evaluation criteria and questions to be addressed: the criteria for the evaluation outlined 
a  series  of  questions  to  be  addressed,  focusing  on  effectiveness,  efficiency,  coherence, 
relevance  and  EU  added  value.  To  systematically  address  these  questions,  an  evaluation 
matrix was developed (see Annex III), detailing the necessary data and evidence. 

•  Early  stage  of  programme  implementation.  Given  the  early  stage  of  the  platform’s 
implementation,  there  were  significant  limitations  on  the  extent  to  which  the  evaluation 
questions, especially on effectiveness and efficiency, could be addressed. While quantitative 
data  was  utilised  wherever  possible,  the  limited  availability  of  data  (e.g.  on  projects  that 
received alternative or cumulative financing thanks to STEP) was considered when designing 
evaluation.  
the 

Therefore, the evaluation relies heavily on qualitative approaches, including the first-hand 
experience of the Commission staff involved in the implementation, a survey and feedback 
gathered  from  external  stakeholders  both  in  the  call  for  evidence  and  through  regular 
exchanges with interested counterparts across the EU. 

•  Novel aspects of the platform. The evaluation methodology must take into account the 
unique features of STEP as an initiative. Given that STEP has little to no dedicated spending 
budget  (see  Section  3.1  on  the  development  of  the  political  context),  serves  primarily  a 
coordinating and steering function across existing EU funding programmes, and has largely 
qualitative  objectives,  there  are  inherent  limitations  in  assessing  its  standalone  impact—
particularly in economic terms.  

•  By  considering  these  factors,  the  interim  evaluation  of  STEP  aims  to  provide  meaningful 
insights  into  the  initial  implementation  and  innovative  aspects  of  the  platform,  while 
complementing,  rather  than  replacing,  the  evaluations  of  the  individual  EU  funding 
programmes  involved  in  the  platform,  and  setting  the  stage  for  a  more  comprehensive 
evaluation at a later stage. 

42 

 
 
 
 
Overview of the evaluation methods 

As explained, the evaluation combines both qualitative and quantitative methods where feasible. 

Document review 

The  evaluation  included  a  thorough  review  of  existing  documentation  relevant  to  the  design, 
implementation, and performance of STEP. This review focused primarily on programming documents 
specific  to  the  platform  –  such  as  the  STEP  Regulation90,  the  Financial  Regulation91 and  the  STEP 
Guidance Note92 – as well as the legal and policy frameworks of the EU funding programmes covered 
by  STEP,  including  the  Common  Provisions  Regulation93,  the  RRF  Regulation94 and  the  Commission 
Notice providing guidance on recovery and resilience plans95. 

In  light  of  the  timing  of  the  evaluation,  the  analysis  also  incorporated  key  programmatic  policy 
documents published by the Commission during the drafting period. These include the Communication 
on the Competitiveness Compass96, the Communication on the Clean Industrial Deal97, the Draghi Report 
on  EU  Competitiveness 98  and  the  Communication  on  the  road  to  the  next  multiannual  financial 
framework 99. 

This review provided a critical foundation for assessing STEP against the established evaluation criteria. 

Database analysis 

The evaluation team – with the support of the relevant Commission departments – collected, examined, 
and analysed a range of data sources, including: 

•  STEP-labelled calls for proposals and calls for tender under direct management; 

•  STEP Seals awarded through these STEP-labelled calls; 

•  funding allocated to STEP projects in direct management; 

•  STEP-relevant programme amendments under cohesion policy; 

•  STEP-relevant calls for proposals launched within cohesion policy programmes; 

•  projects selected and funded under cohesion policy that qualify as STEP-relevant. 

90 See Regulation (EU) 2024/795 of the European Parliament and of the Council of 29 February 2024 establishing the Strategic Technologies 
for Europe Platform (STEP). 

91 See Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 on the financial rules 
applicable to the general budget of the Union (recast). 

92 See C(2024) 3148 final. 

93 See Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021. 

94 See Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience 
Facility. 

95 See Commission Notice – Guidance on recovery and resilience plans. 

96 See COM(2025) 30 final. 

97 See COM(2025) 85 final. 

98 See The Draghi report on EU competitiveness. 

99 See COM(2025) 46 final. 

43 

 
 
This data enabled the evaluation team to analyse the geographical and sectoral distribution of STEP-
related commitments and investment. 

The  scope  of  the  data  considered  includes,  for  direct  management,  calls  launched  and  STEP  Seals 
awarded up to the end of March 2025. For shared management, it includes programme amendments 
adopted, calls launched and projects selected by the same date. 

Survey 

Between  September  and  October  2024,  the  Commission,  with  support  from  an  external  contractor, 
carried out a survey to capture feedback on end-user experience with the EU funding landscape. 

The study consisted of two components: 

1.  27 qualitative interviews, each lasting one hour, involving Commission departments and 
executive  agencies,  national  contact  points,  industry  clusters  and  associations,  consulting 
firms and experienced applicants. 

2.  An  EU-wide  survey  composed  of  66  open  and  closed  questions,  which  received  487 

responses. 

Together, these two components of the study ensured broad coverage across different user profiles 
(including  inexperienced  users,  experienced  applicants  and  professionals),  STEP-relevant  industry 
sectors and all stages of the EU funding journey – from the search for funding opportunities to project 
award, implementation and reporting (for results, see Annex V). 

Observation and engagement with stakeholders 

As part of the DG BUDG STEP Task Force the evaluation team participated in a wide range of meetings 
and events, both within and outside of the Commission, involving all relevant stakeholders for STEP 
and also during visits to selected Member States.  

This immersive engagement allowed the evaluation team to: (i) capture a wide array of perspectives 
(ranging from national contact points and public authorities to final recipients); (ii) develop a nuanced 
understanding  of  the  operational  realities,  challenges,  successes  and  the  perceptible  impact  of  the 
platform on final recipients, and (iii) identify areas for improvement (for results, see Annex V). 

44 

 
 
ANNEX III. Evaluation matrix and answers to the evaluation questions (by criterion) 

Evaluation criteria 

Evaluation questions 

Judgement criteria  Data 

Summary of evaluation findings 

How successful has STEP been in 
supporting the 
development/manufacturing of 
critical technologies, and addressing 
shortages of labour and skills for 
developing/manufacturing such 
technologies?   

Significant financial 
amounts are 
reprogrammed across 
all programmes in 
the scope of STEP  

Effectiveness 

How successful has the STEP Seal 
been to achieve STEP objectives?  

The STEP Seal helps 
projects find 
alternative or 
cumulative funding, 
as well as additional 
sources of funding 
from private 
investors  

Quantitative and 
qualitative data on 
amended programmes, 
funding amounts 
reprogrammed to STEP, 
selected projects and 
relative funding awarded 
specifically in direct 
management and in 
cohesion policy 
programmes  

Number of STEP Seals 
issued / Number of STEP 
Seals selected for funding 
in cohesion or RRF and 
relative funding amounts / 
Number of Seals that 
have received private 
funding and relative 
funding amounts / 
Qualitative feedback from 
industry on Seals / 
Qualitative evidence on 
obstacles regarding 
cumulative and 
alternative funding from 

45 

Section 
of main 
report 

4.1 

At this early stage, STEP appears to be on track 
to deliver on its objectives. As of March 2025, 
STEP had allocated over EUR 11 billion in 
funding, including a total budget of 
EUR 10 billion from the five STEP programmes 
under direct management, as well as 
EUR 6.3 billion of redirected funds from 
cohesion policy funds.  

No specific financial resources had been 
mobilised as of March 2025 under the 
Recovery and Resilience Facility (RRF) and 
InvestEU for STEP-related projects using the 
STEP-specific tools.  

Too early to assess full impact of 
reprogramming efforts.  

STEP Seal presents potential to facilitate 
alternative and combined funding, though no 
project awarded a STEP Seal has yet received 
alternative or additional funding. Legal and 
operational challenges remain, including 
aligning cost assessment methods and 
navigating the relevant State aid rules. 

4.1 

 
 
 
Evaluation criteria 

Evaluation questions 

Judgement criteria  Data 

Summary of evaluation findings 

Section 
of main 
report 

internal and external 
stakeholders 

How effective has the STEP Portal 
been in achieving STEP objectives?  

The STEP Portal helps 
users access EU 
funding and find 
funding opportunities 
in critical 
technologies 

Metrics on traffic on STEP 
Portal / Access to EU 
funding survey results / 
Qualitative evidence from 
stakeholders on the Portal  

Efficiency 

How has STEP increased coordination 
among EU funding instruments? 
What have been the costs related to 
such coordination? Could this 
coordination happen in a more 
efficient way?  

STEP has helped 
increase coordination 
among programmes 
and with investment 
at national/regional 
level (STEP Network 
within the 
Commission, network 

Number of meetings of 
the STEP Network and 
NCPs / Number of 
bilateral meetings with 
Managing Authorities / 
Qualitative evidence of 
actions undertaken by 
STEP Task Force and NCP 

46 

The STEP Portal has been successful in 
simplifying access to EU funding by bringing 
together funding opportunities for strategic 
technologies across the EU budget, with 
positive user feedback.  

A potential AI-powered simulator is also being 
developed to assist project promoters in 
navigating funding opportunities. Technical and 
operational hurdles remain to develop a fully 
fledged single entry point to the EU budget  

4.1 

Increased coordination of 11 STEP funding 
instruments and alignment along shared 
priorities, with associated coordination and 
operational costs  

4.2 

 
 
 
 
 
 
 
Evaluation criteria 

Evaluation questions 

Judgement criteria  Data 

Summary of evaluation findings 

Section 
of main 
report 

of national contact 
points)  

STEP has helped 
reduced the 
fragmentation of EU 
programmes and 
helped align 
programmes over 
common priorities  

STEP has improved 
access to funding for 
beneficiaries and 
reduced the 
complexity of the EU 
budget  

The new 
requirements 
introduced by STEP 
(i.e. STEP scope) are 
proportionate and 
sufficient efforts 
have been made to 
clarify them to 
stakeholders  

for coordination 
(preparation of 
informative materials e.g. 
guidance, leaflets, 
brochures, dissemination 
activities e.g. promotion of 
Seals with MAs)  
Quantitative evidence on 
number of programmes in 
current EU budget (and 
fact STEP does not reduce 
number of programmes), 
qualitative evidence on 
current EU funding 
landscape and work of 
STEP Task Force to align 
on common priorities 
across instruments 

Evidence from a survey on 
access to EU funding: 
qualitative evidence from 
stakeholders on the 
Portal: Portal metrics  

Qualitative evidence from 
STEP Task Force and 
stakeholders on STEP 
scope  

47 

What has been the effect of STEP on 
the fragmented funding landscape at 
EU level?  

To what extent has STEP simplified 
access to funding for beneficiaries 
and reduced access cost to the EU 
budget?  

To what extent has STEP introduced 
additional complexities?  

STEP does not reduce the number of funding 
programmes, the funding landscape remains 
fragmented. STEP helps to align along common 
priorities.  

4.2 

STEP leads to simpler access to funding via the 
STEP Portal including information of funding in 
different management modes for strategic 
technologies. Substantial coordination efforts 
across Commission departments to pool all the 
relevant information for project promoters 
remain key for the success of the STEP Portal 
as a tool.  

STEP introduced a set of detailed objectives 
and conditions which are sometimes complex 
to understand for project promoters, and came 
on top of existing requirements of EU funding 
instruments. The Commission has made efforts 
to clarify the STEP scope via a guidance 
document. 

4.2 

4.2 

 
Evaluation criteria 

Evaluation questions 

Judgement criteria  Data 

Summary of evaluation findings 

Section 
of main 
report 

4.2 

STEP does not introduce new reporting 
requirements and relies on reporting 
requirements in existing EU funding 
programmes.  

The inherent limitations of the EU budget 
performance monitoring framework limit the 
collection of data on EU funding for strategic 
technologies.  

STEP improves coherence among EU funding 
programmes by aligning them along common 
strategic priorities. Incoherences among 
respective programmes' legal bases remain 

4.3 

STEP improves consistency among EU funding 
programmes by aligning them on common 
strategic priorities (i.e. common STEP scope 
promoted via the STEP Guidance, similar 
wording used in direct management calls for 
proposals and cohesion policy funds) 

4.3 

How efficient are STEP’s reporting 
and monitoring processes?  

To what extent are the different 
instruments introduced by STEP 
coherent?  

To what extent has STEP helped 
increase synergies among 
programmes and increase the 
consistency of the EU budget?  

Reporting under STEP 
is efficient and data 
can be collected 
smoothly  

All the instruments 
introduced by STEP 
are coherent (STEP 
Seal, incentives to 
reprogram cohesion 
policy funds, STEP 
portal) 

STEP helps increase 
synergies across EU 
programmes 
(common priorities 
across direct and 
shared management, 
cumulative funding)  

Qualitative evidence (case 
study) on data collection 
for reporting purposes in 
the context of STEP and 
the setting up of reporting 
requirements by the STEP 
Task Force 

Qualitative evidence on 
the degree of 
matching/mismatch 
between different 
programmes (i.e. different 
timelines for different 
funds making the Seal 
less consistent) 
Quantitative evidence on 
take-up of STEP Seals in 
cohesion policy funds, 
qualitative evidence on 
reprogramming under 
different funds around 
common priorities aligned 
in terms of scope 

Coherence 

48 

 
 
 
 
 
 
 
 
Evaluation criteria 

Evaluation questions 

Judgement criteria  Data 

Summary of evaluation findings 

To what extent is STEP consistent 
with other initiatives at EU level?  

STEP is consistent 
with other initiatives 

EU added value 

To what extent does STEP bring EU 
added value? Could this have been 
done by Member States alone?  

Coordinated pursuit 
of STEP objectives by 
the different 
programmes  

Qualitative assessment of 
how consistent STEP is 
compared to other 
initiatives (NZIA, CRMA, 
Competitiveness Compass, 
Clean Industrial Deal, 
Defence, Critical Medicines 
Act)  

Consistency with initiatives like the Net-Zero 
Industry Act (NZIA) and Critical Raw Materials 
Act (CRMA) is promoted in STEP's legal base. 
While being designated as strategic under 
these acts can help access to STEP funding, 
challenges arise, especially with the CRMA, 
where the lack of formal evaluation criteria 
leads to inconsistencies.  

Additionally, Important Projects of Common 
European Interest (IPCEI) also face regulatory 
limitations in accessing STEP funding. 
Simplified procedures to enable funding under 
STEP have been proposed under the mid-term 
review of cohesion policy. 

Qualitative evidence on 
the relevance of an EU-
level action added value 
of STEP to ensure policy 
objectives are achieved in 
a coordinated and 
consistent manner  

STEP adds EU value by enhancing coordination 
and consistency across EU, national, and 
regional funding to maximise investment in 
strategic technologies.  

STEP helps overcome fragmentation by 
steering funding towards high-potential 
projects for the EU. 

Section 
of main 
report 

4.3 

4.4 

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation criteria 

Evaluation questions 

Judgement criteria  Data 

Summary of evaluation findings 

Relevance 

Is STEP still relevant? To what extent 
did its scope and objectives remain 
relevant over the implementation 
period? To what extent does it 
correspond to wider EU policy goals 
and priorities?  

STEP remains 
relevant in the 
context of the EU’s 
competitiveness 
agenda  

Qualitative evidence on 
relevance of STEP in view 
of EU competitiveness 
agenda (Competitiveness 
Compass, Clean Industrial 
Deal) and other initiatives 
(Defence)  

The continued relevance of STEP in the second 
von der Leyen Commission has been confirmed 
(Competitiveness Compass, Clean Industrial 
Deal).  

There is a new need to increase European 
defence investment with the EU budget, 
against the backdrop of unprecedented 
geopolitical instability. The current STEP scope 
was not deemed fully fit for that purpose, 
hence the proposal to extend STEP’s scope by 
creating a 4th sector covering all defence 
technologies  

Section 
of main 
report 

4.5 

50 

 
ANNEX IV. Overview of benefits and costs; table 
on simplification and burden reduction  

The tables below outline the benefits and costs of STEP, as well as its impact on simplification and 
burden reduction. Considering that STEP is not a new programme but rather a new mechanism  for 
coordinating programmes, many of its features rely on existing programmes and cannot be considered 
to represent an additional cost (for instance, as specified in Article 7 of the STEP Regulation, monitoring 
on STEP progress relies on monitoring frameworks of existing EU programmes).  

STEP  brings  a  number  of  simplifications  and  burden  reductions,  both  for  national  authorities  (i.e. 
cohesion policy flexibilities) and project promoters (via the STEP Portal).  

51 

 
TABLE A4.1: OVERVIEW OF BENEFITS AND COSTS IDENTIFIED IN THE EVALUATION 

Description 

Type of 
benefit / 
cost 

One-off / 
recurrent 

Stakeholder 

Citizens 

Businesses 

Administrations (EU and national) 

Strengthening the 
EU's technological 
sovereignty in 
strategic sectors 
(digital, cleantech, 
biotech) with long-
term societal 
benefits 

Indirect 
benefits 

Long-term 

B E N E F I T S 

STEP contributes to EU-wide strategic 
investment goals, especially in climate, 
digital, and health sovereignty – this will 
potentially create, in the long run, quality 
job opportunities in critical sectors. By 
focusing on upskilling in technology 
sectors, citizens might potentially access 
better employment prospects in the 
knowledge economy. 

Increased visibility 
for investments in 
strategic 
technologies 

Direct and 
indirect 
benefits 

Recurrent 
(during 21-
27 MFF 
period) 

Increased 
coordination and 
strategic 
alignment across 
the EU budget 

- 

Indirect 
benefits 

Long-term 

Simplified access 
to and provision of 
funding 

Direct 
benefits 

Recurrent 
(during 21-
27 MFF 
period) 

The STEP Seal and the STEP Portal increase 
the visibility for companies operating in 
STEP-relevant technologies, enhancing 
their potential to attract public and private 
investments 

- 

The STEP Portal ensures that regional 
investments in STEP technologies are 
recognised  

Incentives (increased pre-financing, co-
financing) to redirect funding towards STEP 
technologies for managing 
authorities / national authorities in cohesion 
policy funds and RRF increase alignment 
around shared priorities between regional, 
national authorities and EU 

The STEP Portal streamlines the funding 
application process, reducing the 
administrative burden for businesses trying 
to access EU funding. The STEP Seal 
ensures that compliance with STEP 
conditions is assessed only once thus 
streamlining the procedure to be awarded 
cumulative/alternative funding at national 
level and possibly shortening its timeline  

Administrations benefit from the 
harmonization of national and regional 
funding with EU priorities, which avoids 
duplicated efforts and ensures that 
resources are directed towards projects of 
high strategic value, including by fast-
tracking mechanisms (e.g. direct award 
under ERDF) 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Human resources 
at European 
Commission level 

Direct 
compliance 
cost 

Long-
term 

- 

Resources spent on 
consultation, 
outreach activities 
and 
communication, 
including STEP 
Portal 

Administrative 
burden on Member 
States to amend 
cohesion policy 
programmes and 
implement STEP 
priorities 
Effort by project 
promoters to align 
proposals with 
STEP criteria 

Coordination costs 
(STEP Commission 
Network, national 
contact points) 

Direct 
compliance 
cost 

Recurrent 

- 

Direct 
compliance 
cost 

Direct 
compliance 
cost 

One-off 

- 

Recurrent 

- 

Enforcement 
costs 

Recurrent 

- 

C O S T S 

- 

- 

- 

20 FTEs (no creation of new posts; 
reallocation of posts within Commission)  

STEP Portal: EUR 800 000 per year, 
including both the STEP Portal's front office 
(content management and dashboard 
development) and the back office (calls 
management application). 
Missions by STEP Task Force: around 
EUR 10 000  
Meetings of STEP national contact 
points: around EUR 40 000 

Cohesion policy reprogramming involves 
one-off administrative costs for proposal 
and fund adjustments 

Complexity and time cost for applicants to 
understand STEP scope vary; efforts made 
by Commission to lessen these costs (STEP 
Guidance, outreach, STEP Portal) 

- 

Coordination cost of internal STEP 
Commission network across 14 
Commission DGs; 9 meetings so far 
Administrative and coordination cost for 
newly appointed national contact points (5 
meetings so far) 

- 

53 

 
 
 
 
 
TABLE A4.2: OVERVIEW OF SIMPLIFICATION MEASURES (ALREADY ACHIEVED) 

Description 

Type 

One-off / 
recurrent 

Citizens 

Businesses 

Administrations 

30% pre-financing 
for STEP Priorities 

Up to 100% co-
financing Rate for 
STEP Projects 

STEP Portal as 
central access hub 

Liquidity and 
cash flow 
simplification 

Financial 
simplification 
for project 
funding 

Access to 
funding 
simplification 

One-off 

- 

One-off 

- 

Recurrent 

- 

- 

- 

Immediate upfront payment reduces 
financial planning burden for managing 
authorities 

Removes need for national co-financing 
in some cases and reduces financial 
burden for managing authorities 

Aggregates calls from 11 EU instruments 
in one dashboard, including calls for 
proposals in shared management 

- 

TABLE A4.3: OVERVIEW OF SIMPLIFICATION MEASURES (POTENTIAL) 

Description 

Type 

STEP Seals serves 
as pre-evaluated 
project label 

Simplified 
project 
selection 

One-off / 
recurrent 

Citizens 

Recurrent (?) 
(if seen per 
project: on-
off) 

- 

STEP Portal as 
central access hub 

Access to 
funding 
simplification 

Recurrent 

- 

Businesses 

Administrations 

The STEP Seal avoids double evaluations 
and thus saves resources and time for 
the project promoters. However, savings 
only if managing authority grants 
support directly. 

thus 

The STEP Seal avoids double evaluations 
selection 
and 
saves  project 
if 
resources.  However,  savings  only 
managing  authority  grants 
support 
directly. 

AI simulator may reduce search and 
application time for SMEs 

- 

54 

 
 
 
ANNEX V: synopsis report on stakeholder 
consultations   

To  support  this  evaluation,  the  Commission  launched  a  call  for  evidence  in  March–April  2025. 
Throughout  the  implementation  of  STEP,  the  Commission  has  regularly  engaged  with  stakeholders 
through dedicated meetings, participation in events, and specific missions to Member States.  

Since March 2024, it has also convened four meetings with STEP national contact points across the EU 
to discuss the progress of implementation. In addition, a EU-wide survey on access to EU funding was 
conducted in September–October 2024.  

The results of all these consultation activities are presented in this annex. 

TABLE A5.1: OVERVIEW OF CONSULTATION STRATEGY AND METHODOLOGY 

Activities 

Stakeholders targeted 

Timing 

13 March 2025  -  10 April 2025, 
30 responses 

September to October 2024 

•  12 June 2024 

•  4 July 2024 

•  5 September 2024 

•  7 November 2024 

•  19 February 2025 

the 

Over 
implementation 

course  of 

the 

Call for evidence  

Survey  on  access 
to EU funding 

Individual citizens, academic and research 
organisations, NGOs, consumer and social 
organisations, individual economic 
operators and representatives, public 
authorities 
European Commission and executive 
agencies, national contact points for EU 
funding programmes, industry clusters and 
associations, consulting companies, private 
companies 

Meetings  of 
STEP 
contact points 

the 
national 

STEP national contact points  

Outreach 
initiatives 

Private  companies,  public 
institutions, 
financial investors, academic and research 
organisations, consulting firms 

55 

 
 
 
 
 
Results of the consultation activities 

Feedback from the call for evidence 

The call for evidence on the STEP interim evaluation ran from 13 March to 10 April 2025. 
The Commission received 30 responses.  

FIGURE A5.1: CATEGORIES OF RESPONDENTS TO THE CALL FOR EVIDENCE 

Source: STEP Task Force elaboration 

FIGURE A5.2: MEMBER STATE OF ORIGIN OF RESPONDENTS  

Source: STEP Task Force  

56 

 
 
 
 
Funding accessibility and coordination were central concerns across all stakeholder groups. 
Respondents  widely  supported  simplified  and  coordinated  access  to  funding  under  STEP.  Business 
associations and companies emphasised the need for a single, centralised portal to help SMEs and 
investors navigate available opportunities. The STEP Portal was seen as a helpful starting point.  

Regional and national authorities regretted the lack of alignment between STEP and existing cohesion 
funding  rules,  making  implementation  complex.  National  authorities  also  expressed  concerns  about 
unequal access for non-EU countries and called for stronger integration into support networks like the 
national contact points. 

In terms of strategic technology focus, most stakeholders agreed that STEP is targeting the 
right sectors. However, several called for a broader interpretation of these categories. Industry and 
civil society groups encouraged STEP to support emerging areas such as hydrogen purification, open-
source digital infrastructure, and circular economy solutions. Clarification of strategic dependencies was 
raised in many of the responses, with a call for better defining and breaking down the term ‘strategic 
dependencies’ within the STEP framework.  

The current emphasis on carbon capture technologies was criticised by several stakeholders, arguing 
that such projects may sustain fossil fuel dependency and do not align with long-term climate goals. 
Academic  institutions  raised  concerns  that  STEP’s  focus  on  strategic  technologies  and  industrial 
competitiveness could marginalise basic research, particularly in the social sciences and humanities 

The  administrative  and  regulatory  burden  was  raised  repeatedly,  especially  by  public 
authorities. Respondents described STEP as difficult to implement, including due to mismatches with 
national  eligibility rules. State  aid  rules were also raised an obstacle by  six respondents (four 
managing  authorities,  one  national  promotional  bank  and  one  private  company),  with  one 
recommending that STEP be given a dedicated legal provision under the GBER to facilitate the funding 
of both single and multi-beneficiary projects. Managing authorities found that the STEP Seal concept 
was hard to apply without clearer legal foundations. Others asked for clearer guidance on project 
selection and coordination to improve implementation across Member States. 

Views on the STEP Seal recognition and impact were consistent across stakeholder types. 
Most saw its value in principle but noted that in practice, it offers few concrete benefits. Many called 
for the creation of national-level follow-up mechanisms to support Seal-endorsed projects. Introducing 
a ‘Gold STEP’ label was proposed, to reward exceptional proposals and enhance visibility. Authorities 
and companies alike flagged inconsistencies in how the Seal is recognised across Member States, which 
weakens its purpose. Within cohesion policy programmes, the STEP regulation provides flexibilities and 
incentives for managing authorities to support STEP Seals, but it imposes no obligation on them. This 
context  might  not  be  widely  understood  by  all  stakeholders.  Consequently,  some  stakeholders 
suggested implementing appeal procedures for cases where local authorities choose not to  support 
projects. 
Seal-endorsed 

The topic of inclusiveness and regional balance was highlighted by both public and private 
stakeholders. Regional authorities, SME representatives and industry associations emphasised the 
need for tailored tools to support SMEs, particularly in less developed regions. These actors highlighted 
that  SMEs  are  essential  to  Europe’s  strategic  autonomy,  but  often  struggle  to  access  STEP  due  to 
complex procedures and a lack of dedicated support. Universities and research organisations added 

57 

 
 
 
that social and regional inclusion should be safeguarded and warned against an overly narrow focus 
on industrial outcomes.  

Feedback from Commission survey on access to EU funding 

Between September and October 2024, the Commission launched an EU-wide study on access to EU 
funding with a twofold objective: 91) assess users’ current experience with EU funding, and (2) gather 
views on the potential use of AI tools in this context.  

The aim was to inform the future development of the STEP Portal, particularly regarding how AI – such 
as  a  chatbot  –  could  improve  the  user  experience  in  identifying  and  assessing  relevant  funding 
opportunities (for methodology, see Annex II). 

Key takeaways 

•  Users encounter major barriers at every stage of the EU funding journey, particularly 
in  the  awareness  and  identification  phases  –  when  they  start  navigating  the  resources 
available online and identifying the most relevant funding opportunities for their needs. The 
system is perceived to be fragmented, overly complex and difficult to navigate, especially 
applicants.  
for 

first-time 

Information is often buried in lengthy documents, jargon-heavy, or inconsistently presented 
across platforms, leading users to rely heavily on informal networks, external consultants, 
guidance.  
and  webinars 

compensate 

official 

clear 

lack 

the 

for 

of 

to 

According  to  48%  of  users  the  main  challenge  is  related  to  ‘understanding’  the 
different funding programmes. 30% of them lament the lack of consistency between 
funding opportunities at EU and national level as well as the complexity of identifying the 
relevant information sources. The core focus of users is to understand which opportunities 
are currently open and until when (i.e. timeline) and their second focus is on understanding 
whether there is a strong fit for them (e.g. eligibility, objectives, scope etc.) 

58 

 
 
 
 
FIGURE A5.3: OVERVIEW OF CHALLENGES IDENTIFIED BY RESPONDENTS

Source: EU-wide survey on access to EU funding (mid-September–end October 2024) 

•  There  is  strong  demand  for  a  more  user-centric  and  consistent  access  point  to 
funding opportunities. 72% of consulted users expressed support for a one-stop shop that 
integrates EU and national funding information. This would reduce the current need to cross-
check  between  multiple  sources  and  portals,  bringing  enhanced  clarity  and  time  savings. 
However, users also highlighted that simply aggregating information is not sufficient – to be 
effective the platform must offer clarity, structured navigation and tailored filtering. 

•  75% were not yet familiar with the STEP Portal, indicating a need to significantly raise 
awareness.  Among  those  who  had  used  the  platform,  feedback  was  generally  positive, 
despite some usability challenges. It is important to note that these findings likely reflect 
user experiences with the pre-revamp version of the website, as the survey was conducted 
in parallel with the redesign launched in September 2024. 

59 

 
 
 
 
 
•  AI is seen as key for improving the STEP user experience, particularly through tools 
like  chatbots,  document  summarisation  and  smart  filtering.  Users  value  AI  for  its 
potential  to simplify  access to relevant opportunities, guide users through the application 
process and reduce manual effort. However, successful implementation depends on ensuring 
security.  
high 

relevance 

levels 

trust, 

data 

and 

of 

More than 80% of surveyed users, as well as interviewees, stress that AI tools must deliver 
accurate, up-to-date  and context-aware support. Multilingual  support and friendliness are 
instead  seen  as  the  least  relevant  features,  although  the  former  was  more  strongly 
supported  in  eastern  European  countries.  Privacy  and  security  for  exchanged  information 
during chatbots interactions is the major concern raised by users. 

FIGURE A5.4: RELEVANCE OF THE DIFFERENT CHARACTERISTICS OF AN AI TOOL FOR 
EU FUNDING 

Source: EU-wide survey on access to EU funding (mid-September to end October 2024) 

Feedback from meetings of the national contact points 

Since  June  2024,  the  Commission  has  organised  regular  meetings  with  all  national  contact  points 
(NCPs) designated by Member States to coordinate the implementation of STEP nationally. To date, 
five such meetings have taken place. 

These meetings serve as a key coordination forum, enabling the exchange of information on the 
implementation of STEP at both EU and national levels. They help ensure alignment across Member 
States, share practical guidance and collectively address implementation challenges and bottlenecks. 

1st NCP Meeting – 12 June 2024  

The first formal engagement between the Commission and national STEP coordinators. The session 
introduced the objectives and structure of the STEP Regulation, clarified the expected role of the NCPs, 
and established working arrangements for the network. The meeting also addressed the way forward 
on the implementation of STEP through cohesion policy and the Recovery and Resilience Facility. 

60 

 
 
 
 
2nd NCP Meeting – 4 July 2024  

Focused  on  the  STEP  scope,  presenting  in  detail  the  STEP  Guidance  Note  and  clarifying  questions 
received from the Member State representatives. 

3rd NCP Meeting – 5 September 2024 
Focused on the InvestEU Member State compartments and the new opportunities introduced by the 
STEP  Regulation under this instrument. The Commission provided an overview of how STEP-related 
investment  could  be  supported  through  national  compartments,  and  NCPs  exchanged  on  the 
practicalities and challenges of mobilising resources under this framework. 

4th NCP Meeting – 7 November 2024 

NCPs  convened  in  Brussels  for  the  first  in-person,  full-day  meeting  of  the  network.  The  discussion 
primarily centred on the STEP Seal. The Commission presented the initial batch of STEP Seals awarded 
under the Innovation Fund, with a particular focus on clean and resource-efficient technologies. A key 
topic of debate were the limits to the uptake of these projects under cohesion policy. 

Participants highlighted several barriers, including: 

•  the exclusion of sectors covered by the ETS Directive from ERDF eligibility (see Section 

4.3 on coherence), 

•  the absence of a dedicated State aid regime for STEP Seal projects; 

•  practical  difficulties  related  to  combining  EU  funding  sources  –  an  interesting 

opportunity, given the large budgets for projects awarded STEP Seals. 

Several  Member  States  also  shared  their  experience  with  ongoing  cohesion  policy  programme 
amendments  and  raised  questions  about  the  scope  of  STEP  and  its  interplay  with  other  EU 
initiatives – such as IPCEI, the Net-Zero Industry Act (NZIA) and the Critical Raw Materials 
Act (CRMA) (see Section 4.3 on coherence). 

Finally, the meeting addressed the use of STEP incentives under the Recovery and Resilience Facility 
(RRF).  Many  Member  States  indicated  limited  interest  in  using  this  option,  citing  either  full 
commitment  
of their RRF envelopes or the administrative complexity and time required to amend national 
recovery and resilience plans. 

5th NCP Meeting – 19 February 2025 
Featured  a  presentation  by  Aura  Aero,  a  French  start-up  and  STEP  Seal  recipient  under  the  2023 
Innovation Fund call. The company shared positive feedback on the signalling effect of the STEP 
Seal and emphasised the ongoing funding challenges faced by start-ups, notably the need for 
improved matchmaking with private investors at national level. 

The  Commission  presented  the  latest  batches  of  STEP  Seals  awarded  under  the  Digital  Europe 
Programme and EU4Health. The discussion also addressed the specific challenges related to the uptake 
of  STEP  Seal  projects  under  cohesion  policy,  particularly  those  involving  consortia  of  multiple 
beneficiaries, which often require tailored, case-by-case approaches. 

61 

 
 
Several  Member  States  reported  having  been  contacted  by  Seal  holders  seeking  alternative  or 
complementary funding solutions. Selected NCPs shared national-level initiatives aimed at facilitating 
the integration of STEP Seal projects into cohesion policy funding streams. 

Feedback from the outreach initiatives 

Since the launch of STEP in March 2023, the Commission has actively engaged with a wide range of 
stakeholders across the EU through dedicated meetings and public events. These exchanges serve as 
valuable  opportunities  to  gauge  stakeholder  perspectives  on  STEP,  collect  feedback  on  its 
implementation  and  assess  the  relevance  and  usability  of  key  tools,  such  as  the  STEP  Portal  (for 
background, see Annex II). 

By the end of March 2024, the Commission had participated in 105 meetings with external stakeholders 
and  conducted  visits  to  Germany,  Hungary,  France,  Estonia,  Latvia,  Lithuania,  Romania, 
Slovenia, Greece, and Portugal. These engagements covered a broad spectrum of actors – including 
industry  representatives,  private  investors,  public  authorities,  academic  institutions  and  consultancy 
firms – across 22 EU Member States100. 

100 The Commission, in the context of its outreach initiatives on STEP, has not yet been in contact with any external stakeholder from Malta, 
Cyprus, Austria, Bulgaria and Ireland. 

62 

 
 
 
FIGURE A5.5: COUNTRY OF ORIGIN OF THE ORGANISATIONS WHO MET WITH THE 
STEP TASK FORCE (number of meetings)

Source: EU-wide survey on access to EU funding (mid-September to end October 2024) 

Across the Commission’s stakeholder engagements, several recurring concerns have emerged: 

•  Complexity  of  access  to  EU  funding:  Navigating  the  EU  funding  landscape  remains 
challenging,  particularly  for  SMEs.  Stakeholders  highlighted  the  complexity  of  application 
documents,  the  volume  of  information  required  and  the  administrative  burden  involved. 
These  challenges  –  along  with  associated  costs  (e.g.  for  external  consultants)  and 
uncertainties such as delays – discourage participation and prompt many companies to seek 
funding elsewhere. 

•  Funding gaps in the innovation cycle: While stakeholders acknowledged the EU’s strong 
support for research and development, they pointed to a lack of sufficient resources for the 
start-up and scale-up phases. This funding gap limits the ability of innovative companies to 
grow and commercialise their technologies. 

•  Regulatory and structural barriers: The effectiveness of EU funding is constrained by a 
fragmented  landscape  and  misalignment  between  funding  instruments.  Differences  in 
timelines across programmes (e.g. Horizon Europe, the Innovation Fund and Digital Europe) 

63 

 
 
 
hinder continuity. In addition, the variety of applicable State aid frameworks (resulting from 
a  variety  of  objectives  and  policies  pursued  by  the  calls  under  which  STEP  Seals  were 
granted) were identified as barriers to effective project support. 

•  Comparative disadvantage to the US system: The US was frequently cited as offering a 
more  favourable  environment  for  industry  –  characterised  by  simpler procedures,  greater 
public  investment  and  more  direct  engagement  opportunities  with  public  authorities, 
by-passing complex procurement requirements. 

•  Need for long-term budget certainty: Industry stakeholders underlined the importance of 
a  more  stable,  long-term  EU  funding  framework  to  support  planning  and  sustained 
engagement in strategic sectors. 

Among  outreach  initiatives,  one  stands  out  particularly.  On  12 March 2025,  the  Italian  
STEP  national  contact  point  (NCP),  with  support  from  the  Commission,  organised  the  
first-ever  workshop  bringing  together  STEP  Seal  holders  and  managing  authorities  
of cohesion policy funds. 

The workshop served multiple purposes: it raised awareness of STEP among Italian beneficiaries of the 
STEP  Seal  under  the  Innovation  Fund,  allowed  the  NCP  to  present  an  overview  of  the  ongoing 
reprogramming of cohesion policy programmes in Italy and provided a forum for three regional ERDF 
managing authorities to showcase their respective reprogramming efforts. A dedicated Q&A session 
followed the presentations. 

Key questions raised during the exchange: 

1.  The role of State aid in supporting STEP projects and the potential for future facilitation 

measures. 

2.  Compliance with the Financial Regulation (FR) and Common Provisions Regulation (CPR), as 

regards double funding. 

3.  The design of cohesion incentives and the possibility of increasing allocations beyond the 

current flexibility limits. 

4.  The practical uptake of the STEP Seal, including the administrative burden associated with 

funding multi-beneficiary projects. 

64 

 
 
 
 
 
ANNEX VI: Complementary information 

TABLE A6.1: OVERVIEW OF THE REGIONAL DISTRIBUTION OF THE STEP SEALS101  

Cleantech 

Country NUTS2 Region 

# 

5 

5 

4 

ES51  Cataluña 

ITC4  Lombardia 

BE21  Prov. Antwerpen 

FRD2  Haute-Normandie   4 

SE12  Östra Mellansverige 4 

DK05  Nordjylland 

DE21  Oberbayern 

DE94  Weser-Ems 

ES61  Andalucía 

3 

3 

3 

3 

FRE1  Nord-Pas de Calais  3 

FRI1  Aquitaine 

ITH5  Emilia-Romagna 

NL36  Zuid-Holland 

PT1A  Grande Lisboa 

BE23 

Prov. Oost-
Vlaanderen 

BE32  Prov. Hainaut 

CZ06  Jihovýchod 

DK02  Sjælland 

DK04  Midtjylland 

3 

3 

3 

3 

2 

2 

2 

2 

2 

DKZZ  Extra-Regio NUTS 2  2 

DEA1  Düsseldorf 

EL30  Aττική 

2 

2 

EL53  Δυτική Μακεδονία  2 

EL64  Στερεά Ελλάδα 

2 

ES42  Castilla-La Mancha  2 

ES43  Extremadura 

ES52 

Comunitat 
Valenciana  

2 

2 

FRD1  Basse-Normandie   2 

FRH0  Bretagne 

FRJ2  Midi-Pyrénées 

2 

2 

FR 

FR 

HR 

LV 

PT 

FI 

SE 

SE 

SE 

BE 

BE 

BG 

CZ 

CZ 

CZ 

CZ 

DK 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

EE 

IE 

ES 

ES 

ES 

FRK2  Rhône-Alpes 

FRL0 

Provence-Alpes-
Côte d’Azur 

2 

2 

HR02  Panonska Hrvatska  2 

LV00  Latvija 

PT1C  Alentejo 

FI19  Länsi-Suomi 

SE22  Sydsverige 

SE23  Västsverige 

SE33  Övre Norrland 

BE25 

Prov. West-
Vlaanderen 
BE33  Prov. Liège 

BG31  Северозападен 

CZ02  Střední Čechy 

CZ04  Severozápad 

CZ05  Severovýchod 

CZ08  Moravskoslezsko 

DK03  Syddanmark 

DE11  Stuttgart 

DE22  Niederbayern 

DE24  Oberfranken 

DE40  Brandenburg 

DE93  Lüneburg 

DEA2  Köln 

2 

2 

2 

2 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

DEB3  Rheinhessen-Pfalz  1 

DED2  Dresden 

DEG0  Thüringen 

EE00  Eesti 

IE04 

Northern and 
Western 

ES11  Galicia 

ES12 

Principado de 
Asturias 

ES13  Cantabria 

1 

1 

1 

1 

1 

1 

1 

ES 

ES 

FR 

FR 

FR 

FR 

FR 

HR 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

LU 

HU 

NL 

NL 

NL 

NL 

AT 

AT 

PL 

PL 

PT 

PT 

RO 

SK 

FI 

FI 

SE 

SE 

ES21  País Vasco 

ES24  Aragón 

FRE2  Picardie 

FRF1  Alsace 

FRF3  Lorraine 

FRG0  Pays de la Loire 

FRI3  Poitou-Charentes 

1 

1 

1 

1 

1 

1 

1 

HR03  Jadranska Hrvatska  1 

ITC1  Piemonte 

ITF4  Puglia 

ITG1  Sicilia 

ITG2  Sardegna 

ITH3  Veneto 

1 

1 

1 

1 

1 

ITH4  Friuli-Venezia Giulia  1 

ITI1 

Toscana 

LU00  Luxembourg 

HU23  Dél-Dunántúl 

NL11  Groningen 

NL34  Zeeland 

NL42  Limburg (NL) 

1 

1 

1 

1 

1 

1 

NLZZ  Extra-Regio NUTS 2  1 

AT12  Niederösterreich 

AT13  Wien 

1 

1 

PL42  Zachodniopomorskie 1 

PL52  Opolskie 

PT11  Norte 

PT19  Centro (PT) 

RO31  Sud-Muntenia 

1 

1 

1 

1 

SK03  Stredné Slovensko  1 

FI1C  Etelä-Suomi 

1 

FIZZ  Extra-Regio NUTS 2  1 

SE11  Stockholm 

1 

SE32  Mellersta Norrland  1 

ES 

IT 

BE 

FR 

SE 

DK 

DE 

DE 

ES 

FR 

FR 

IT 

NL 

PT 

BE 

BE 

CZ 

DK 

DK 

DK 

DE 

EL 

EL 

EL 

ES 

ES 

ES 

FR 

FR 

FR 

101 A region is considered to have received a STEP Seal if at least one project with an awarded Seal is partially or fully located within its borders, 
even in the case of multi-location projects. 

65 

 
 
 
 
 
MS NUTS2 

FR  FR10 

BE  BE10 

FI  FI1B 

Digitaltech 

FI  FI1C 

Etelä-Suomi 

Region 

# 

FI  FI1D 

Pohjois- ja Itä-Suomi 

Île-de-France 
Région de Bruxelles-
Capitale / Brussels 
Hoofdstedelijk Gewest 
Helsinki-Uusimaa 

10 

DE  DE14 

SE  SE11 

DE  DE11 

DE  DE50 

9 

8 

Tübingen 

Stockholm 

Stuttgart 

Bremen 

ES  ES30  Comunidad de Madrid  7 

EL  EL52 

Κεντρική Μακεδονία 

ES  ES61 

Andalucía 

IE 

IE06 

Eastern and Midland 

ES  ES51 

IT 

IT 

IT 

ITC4 

ITH5 

ITI4 

EL  EL30 

IT 

ITF3 

Cataluña 

Lombardia 

Emilia-Romagna 

Lazio 

Aττική 

Campania 

NL  NL41 

Noord-Brabant 

PT  PT1A 

FR  FRJ2 

BG  BG41 

EE  EE00 

EL  EL61 

DE  DE21 

IT 

ITC1 

Grande Lisboa 

Midi-Pyrénées 

Югозападен 

Eesti 

Θεσσαλία 

Oberbayern 

Piemonte 

EL  EL62 

IT 

ITI1 

LV  LV00 

HU  HU11 

NL  NL21 

NL  NL35 

NL  NL36 

AT  AT13 

PL  PL21 

PL  PL71 

PT  PT19 

BE  BE33 

DE  DE40 

DE  DE92 

DE  DED2 

FR  FRF3 

6 

6 

6 

6 

6 

6 

5 

5 

5 

5 

4 

4 

4 

4 

3 

3 

Ιόνια Νησιά 

Toscana 

Latvija 

Budapest 

Overijssel 

Utrecht 

Zuid-Holland 

Wien 

Małopolskie 

Łódzkie 

Centro (PT) 

Prov. Liège 

Brandenburg 

Hannover 

Dresden 

Lorraine 

3 

3 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

1 

1 

1 

1 

1 

EL  EL51 

EL  EL63 

Aνατολική Μακεδονία, 
Θράκη 
Δυτική Ελλάδα 

EL  EL65 

Πελοπόννησος 

ES  ES42 

Castilla-La Mancha 

ES  ES62 

Región de Murcia 

ES  ES70 

Canarias 

FR  FRB0 

Centre – Val de Loire 

FR  FRE1 

Nord-Pas de Calais 

FR  FRE2 

FR  FRF1 

Picardie 

Alsace 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

FR  FRJ1 

Languedoc-Roussillon  1 

HR  HR03 

Jadranska Hrvatska 

HR  HR05 

Grad Zagreb 

IT 

IT 

IT 

ITC3 

ITF4 

ITF5 

IT 

ITH2 

IT 

ITI3 

MT  MT00 

PL  PL22 

PL  PL63 

Liguria 

Puglia 

Basilicata 
Provincia Autonoma di 
Trento 
Marche 

Malta 

Śląskie 

Pomorskie 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

PL  PL91  Warszawski stołeczny  1 

BE  BE24  Prov. Vlaams-Brabant  3 

BE  BE23  Prov. Oost-Vlaanderen  1 

PT  PT11 

Norte 

DE  DEA2 

ES  ES21 

FR  FRH0 

FR  FRK2 

DK  DK01 

DK  DK04 

IE 

IE05 

EL  EL43 

Köln 

País Vasco 

Bretagne 

Rhône-Alpes 

Hovedstaden 

Midtjylland 

Southern 

Κρήτη 

3 

3 

3 

3 

3 

3 

3 

3 

ES  ES52  Comunitat Valenciana  3 

CY  CY00 

Κύπρος 

RO  RO32 

Bucureşti-Ilfov 

3 

3 

BG  BG33 

Североизточен 

CZ  CZ01 

DK  DK02 

DE  DE12 

DE  DE25 

DE  DE26 

DE  DE80 

DE  DEA3 

DE  DEG0 

Praha 

Sjælland 

Karlsruhe 

Mittelfranken 

Unterfranken 
Mecklenburg-
Vorpommern 
Münster 

Thüringen 

1 

1 

1 

1 

1 

1 

1 

1 

1 

PT  PT1B 

Península de Setúbal 

PT  PT1D  Oeste e Vale do Tejo 
Região Autónoma dos 
Açores 
Nord-Est 

RO  RO21 

PT  PT20 

RO  RO22 

Sud-Est 

RO  RO41 

Sud-Vest Oltenia 

FI  FI19 

Länsi-Suomi 

SE  SE12 

Östra Mellansverige 

SE  SE23 

Västsverige 

IE 

IE04  Northern and Western  1 

SE  SE31 

Norra Mellansverige 

EL  EL41 

Βόρειο Αιγαίο 

1 

SE  SE33 

Övre Norrland 

66 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

 
 
 
 
 
 
 
 
MS 

DE 

FR 
PT 
BE 
BE 
DK 
DE 

DE 
DE 
DE 
DE 
DE 
DE 

DE 
DE 
DE 
EE 
ES 
IT 

IT 
IT 
IT 
FI 
FI 
SE 

NUTS2 
DE21 
FR10 
PT1A 
BE10 

BE21 

DK04 
DE14 
DE60 

DE71 
DE72 
DE91 
DE92 
DEA1 
DEA2 

DEB3 
DEC0 
EE00 
ES51 
ITC4 
ITH3 

ITI1 
ITI4 
FI19 
FI1B 
SE11 

# 

2 

2 
2 
1 
1 
1 
1 

1 
1 
1 
1 
1 
1 

1 
1 
1 
1 
1 
1 

1 
1 
1 
1 
1 
1 

Biotech 

Region 

Oberbayern 

Île-de-France 
Grande Lisboa 
Région de Bruxelles-Capitale / Brussels Hoofdstedelijk Gewest 
Prov. Antwerpen 

Midtjylland 
Tübingen 
Hamburg 

Darmstadt 
Gießen 
Braunschweig 
Hannover 
Düsseldorf 
Köln 

Rheinhessen-Pfalz 
Saarland 
Eesti 
Cataluña 
Lombardia 
Veneto 

Toscana 
Lazio 
Länsi-Suomi 
Helsinki-Uusimaa 
Stockholm 

67 

 
 
 
 
 
TABLE A6.2: OVERVIEW OF THE COHESION PROGRAMME AMENDMENTS ACROSS EU 
MEMBER STATES AND REGIONS AS OF 31 MARCH 2025 

MS 

Title 

ERDF 
(m EUR) 

JTF 
(m EUR) 

ESF+ 
(m EUR) 

CF 
(m EUR) 

Total 
(m EUR) 

DE 

DE 

DK 

ES 

DE 

DE 

ES 

LV 

IT 

IT 

IT 

ES 

IT 

FR 

IT 

DE 

ES 

IT 

ES 

IT 

ES 

RO 

IT 

IT 

ES 

IT 

Multi Funds Programme ERDF/JTF 
North Rhine-Westphalia 2021-2027 

200.20 

301.60 

Programme ERDF 2021-2027 Baden-
Württemberg 

62.22 

52.30 

34.87 

114.44 

Green Technologies and Skills for a 
Just Transition 

Programme Catalonia ERDF 2021-
2027 

Programme ERDF 2021-2027 
Bavaria 

Programme ERDF 2021-2027 
Schleswig-Holstein 

Programme Basque Country ERDF 
2021-2027 

European Union Cohesion Policy 
programme 2021-2027 

RP Lazio ERDF 2021-2027 

Sicilia ERDF 2021-2027 

RP Sardegna ERDF 2021-2027 

Programme Cantabria ERDF 2021-
2027 

RP Lombardia ERDF 2021-2027 

Programme Hauts de France ERDF-
ESF+-JTF 2021-2027 

RP Campania ERDF 2021-2027 

Programme ERDF 2021-2027 
Mecklenburg-Vorpommern 

Programme Community of Madrid 
ERDF 2021-2027 

113.51 

104.54 

47.00 

33.12 

56.81 

109.04 

615.20 

166.01 

15.53 

120.00 

581.14 

138.69 

72.67 

RP Calabria ERDF ESF+ 2021-2027 

264.45 

Programme Castilla y Leon ERDF 
2021-2027 

RP Puglia ERDF ESF+ 2021-2027 

Programme Aragon ERDF 2021-2027 

Health 

RP Emilia-Romagna ERDF 2021-2027 

NP Research, innovation and 
competitiveness for green and digital 
transition 2021-2027 

Programme Region of Valencia ERDF 
2021-2027 

RP Umbria ERDF 2021-2027 

44.71 

471.53 

23.44 

351.77 

61.46 

558.46 

143.88 

31.42 

68 

501.8 

62.2 

52.3 

113.5 

104.5 

47.0 

33.1 

56.8 

109.0 

615.2 

166.0 

15.5 

120.0 

34.9 

581.1 

138.7 

72.7 

264.5 

44.7 

471.5 

23.4 

466.2 

61.5 

558.5 

143.9 

31.4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MS 

Title 

ERDF 
(m EUR) 

JTF 
(m EUR) 

ESF+ 
(m EUR) 

CF 
(m EUR) 

Total 
(m EUR) 

RO 

FR 

DE 

ES 

ES 

RO 

LT 

NL 

AT 

ES 

PL 

Smart growth, digitalization and 
financial instruments 

Programme régional Île-de-France et 
bassin de la Seine ERDF-ESF+ 2021-
2027 

271.01 

35.19 

Bayern - ESF+ 

Cantabria - ESF+ 

Madrid - ESF+ 

Education and Employment – RO – 
ESF+ 

Programme for the European Union 
funds’ investments in 2021–2027 

Programme ERDF 2021-2027 East 
Netherlands 

IJG/ERDF & JTF 2021-2027 

Pluri-regional programme Spain ERDF 
2021-2027 

European Funds for Mazowsze 2021-
2027 

58.55 

15.65 

9.32 

25.00 

17.74 

12.48 

36.92 

3.17 

63.82 

572.63 

RO 

Just Transition 

266.33 

Total 

38 

4 801.5 

638.0 

838.3 

0.0 

TABLE A6.3: CALL FOR PROPOSALS LAUNCHED UNDER STEP BY FUNDING 
PROGRAMME

271.0 

47.7 

36.9 

3.2 

63.8 

572.6 

58.6 

15.7 

17.7 

9.3 

25.0 

266.3 

6 278 

Sector 

Programme 

Topic of the call for 
proposal 

General decarbonisation - 
Large-Scale Projects 

General decarbonisation - 
Medium-Scale Projects 

General decarbonisation - 
Small-Scale Projects 

Budget 
(in EUR 
m) 

Open 

Close 

€1 700 

Nov '23 

Apr '24 

€500 

Nov '23 

Apr '24 

€200 

Nov '23 

Apr '24 

Clean and 
resource-
efficient  
technologies 

Innovation 
Fund 

Clean-tech manufacturing 

€1 400 

Nov '23 

Apr '24 

Pilot projects 

€200 

Nov '23 

Apr '24 

General decarbonisation - 
Large-Scale Projects 

General decarbonisation - 
Medium-Scale Projects 

General decarbonisation - 
Small-Scale Projects 

69 

€1 200 

Dec '24 

Apr '25 

€200 

Dec '24 

Apr '25 

€100 

Dec '24 

Apr '25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
European 
Defence 
Fund 

Horizon 
Europe (EIC) 

Horizon 
Europe 
(Hydrogen 
Joint 
Undertaking
) 

Total 
Cleantech 

Horizon 
Europe 

Digital 
technologies 

Horizon 
Europe (EIC) 

Digital 
Europe 
Programme 

€700 

Dec '24 

Apr '25 

€200 

Dec '24 

Apr '25 

€1 000 

Dec '24 

Apr '25 

€40 

Jun '24 

Nov 
'24 

€20 

Feb '25 

Oct '25 

€50 

Nov '24 

€50 

Nov '24 

€6 

Jan '25 

Apr '25 

€8 

Jan '25 

Apr '25 

€6 

Jan '25 

Apr '25 

€5 

Jan '25 

Apr '25 

€80 

Jan '25 

Apr '25 

€7 665 

€14 

Nov '23 

Apr '24 

€20 

Nov '23 

Apr '24 

€50 

Nov '24 

€50 

Nov '24 

€25 

Feb '24 

May 
'24 

Clean-tech manufacturing 

Pilot projects 

Manufacturing of electric 
vehicles battery cells 
Energy-independent and 
energy-efficient systems for 
military camps 

Naval hybrid propulsion and 
power systems 

Acceleration of advanced 
materials development and 
upscaling along the value 
chain 

Breakthrough innovations for 
future mobility 

Efficient electrolysis coupling 
with variable renewable 
electricity and/or heat 
integration 
Innovative hydrogen and solid 
carbon production from 
renewable gases/biogenic 
waste processes 
Demonstration of scalable 
ammonia cracking technology 

Demonstration of stationary 
fuel cells in renewable energy 
communities 
Large-scale Hydrogen Valley 
Small-scale Hydrogen Valley 

Quantum Space Gravimetry 
Phase-B study & Technology 
Maturation 
Space technologies for 
European non-dependence and 
competitiveness 

GenAI4EU: Creating European 
Champions in Generative AI 
Innovative in-space servicing, 
operations, space-based 
robotics and technologies for 
resilient EU space 
infrastructure 
Making available a high 
performing open-source 
European foundation model 
for fine-tuning 

70 

 
 
 
 
 
 
 
 
 
 
 
Reference deployments of 
European cloud-edge services 
(industrial IoT Edge and Telco 
Edge developments) 
Specialised Education 
Programmes in Key Capacity 
Areas 
Unmanned collaborative 
combat aircraft (U-CCA) 
systems 
Secured and adaptive 
underwater communications 
for UUSs  

Methods for bridging reality 
gaps  

€30 

Feb '24 

€55 

Jul '24 

€15 

Jun '24 

€24 

Jun '24 

€15 

Jun '24 

Electronic components  

€25 

Jun '24 

Quantum technologies 

€24 

Jun '24 

AI-based multifunctional 
aperture and transceiver 

Defence multi-dimensional 
communication standard  

€45 

Jun '24 

€25 

Jun '24 

Small enhanced European UAS 

€11 

Jun '24 

May 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

Nov 
'24 

European 
Defence 
Fund 

Next-Generation Cooperative 
Cyber Range 

Secure waveform for satellite 
communications 

Multipurpose unmanned 
ground systems 

Simulation and training for 
medical emergencies 

Multifunctional Information 
Distribution System 

Chiplet for Defence Application  
Live, Virtual, Constructive 
training interoperability – Joint 
operations and service-specific 
solutions  
Risk, robustness and resilience 
for autonomous vehicles in 
military operations 
Privacy-preserving human-AI 
dialogue systems – 
Participation in a technological 
challenge 

Multiband 4D Radar 

71 

€48 

Jun '24 

€25 

Jun '24 

€50 

Jun '24 

€10 

Jun '24 

€39 

Feb '25 

Oct '25 

€25 

Feb '25 

Oct '25 

€15 

Feb '25 

Oct '25 

€20 

Feb '25 

Oct '25 

€20 

Feb '25 

Oct '25 

€29.5 

Feb '25 

Oct '25 

 
 
Total digital 
tech 

Biotechnologie
s 

Technologies for optronic 
detectors 

Improved cyber defence 
operations capabilities  

Land collaborative combat 
including air-land 

Digital Ship and Naval Combat 
Cloud 

Advanced underwater 
networks 

The European Vaccines 
Development Hub (EVH) 

Call for proposals to support 
the development of novel 
antivirals 
Call for proposals to support 
innovative manufacturing 
technologies and processes in 
the Union for medicines 
production 
Speed up the Development of 
and Access to Innovative 
Medical Countermeasures: 
Next-Generation Influenza 
Vaccines (Procurement) 
Development of a rapid point-
of-care antimicrobial 
susceptibility testing 
diagnostic medical device 
(Procurement) 
Defence medical 
countermeasures Alliance – 
Research actions 
Defence medical 
countermeasures Alliance – 
Development actions 
Defence medical 
countermeasures Alliance – 
Research actions 
Defence medical 
countermeasures Alliance – 
Development actions 
Biotechnology driven low 
emission food production 
systems 

EU4Health 

European 
Defence 
Fund 

Horizon 
Europe (EIC) 

Total 
biotech 

All sectors 

Horizon 
Europe (EIC) 

EIC Strategic Technologies 
for Europe Platform (STEP) 
Scale Up Call 

72 

€29 

Feb '25 

Oct '25 

€34 

Feb '25 

Oct '25 

€44 

Feb '25 

Oct '25 

€54 

Feb '25 

Oct '25 

€25 

Feb '25 

Oct '25 

€896 

€102  May '24 

Sep '24 

€10  May '24 

Sep '24 

€17  May '24 

Sep '24 

€225  Mar '25 

€12.86  Mar '25 

May 
'25 

May 
'25 

€15 

€10 

€13.5 

€11.5 

€50 

Nov '24 

€467 

€300 

Nov 
'24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General 
total 

€9 448102 

TABLE A6.3: STEP SEALS AWARDED BY FUNDING PROGRAM

Funding Programme 

Number of STEP Seals awarded 

Innovation Fund 

EU4Health 

Horizon Europe 

Horizon Europe (EIC) 

Digital Europe Programme 

149 

7 

6 

11 

17 

102 This amount excludes €238 million from the two procurement calls under EU4Health displayed in the table and includes respectively €208 
million and €150 million from calls for proposals being launched after 31 March 2025 under respectively Digital Europe and Horizon Europe. 

73