COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a budget expenditure tracking and performance framework and other horizontal rules for the Union programmes and activities
Date: 2025-07-16
Institutions: Directorate-General for Budget, European Commission
Subjects: EU budget, EU expenditure, EU programme, budgetary expenditure, commitment of expenditure, financial control, financial management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.7.2025  SWD(2025) 590 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a   REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL   establishing a budget expenditure tracking and performance framework and other horizontal rules for the Union programmes and activities {COM(2025) 545 final} - {SEC(2025) 590 final} - {SWD(2025) 591 final}  
 
 
1. 
2. 

INTRODUCTION .................................................................................................................................2 
PROBLEM DEFINITION .....................................................................................................................4 

2.1.  What are the problems and their drivers? ..........................................................4 
2.2.  How likely is the problem to persist? ..............................................................14 
3.  WHY SHOULD THE EU ACT? ......................................................................................................... 14 

3.1.  Legal basis .......................................................................................................14 
3.2.  Subsidiarity: Necessity of EU action ...............................................................14 
3.3.  Subsidiarity: Added value of EU action ..........................................................15 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................ 15 

4.1.  General objectives ............................................................................................15 
4.2.  Specific objectives ...........................................................................................15 
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ..................................................................... 16 

5.1.  What is the baseline from which options are assessed? ...................................17 
5.2.  Description of the policy options .....................................................................18 
5.3. Options discarded at an early stage .....................................................................25 
6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................ 25 

6.1.          Economic impacts ......................................................................................26 
6.2.           Social impacts ...........................................................................................29 
6.3.           Environmental impacts .............................................................................31 
7.  HOW DO THE OPTIONS COMPARE? ............................................................................................. 32 

7.1.  Effectiveness ....................................................................................................32 
7.2.  Efficiency .........................................................................................................35 
7.3.  Coherence ........................................................................................................38 
7.4.  Comparison summary ......................................................................................39 
PREFERRED OPTION ....................................................................................................................... 42 

8. 

8.1.  Preferred policy option ....................................................................................42 
8.2.  REFIT (simplification and improved efficiency) ............................................43 
8.3.  Application of the ‘one in, one out’ approach .................................................43 
9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 43 
ANNEX 1: PROCEDURAL INFORMATION ............................................................................................. 45 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................. 52 
ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................... 57 
ANNEX 4: SME CHECK ............................................................................................................................. 64 
ANNEX 5: COMPETITIVENESS CHECK ................................................................................................. 67 

ANNEX 6: POLICY MAINSTREAMING AND PROGRAMMING ARCHITECTURE OF THE 2021-

2027 BUDGET .................................................................................................................................... 69 
ANNEX 7: MONITORING FRAMEWORK OF THE 2021-2027 BUDGET ............................................ 116 
ANNEX 8: REPORTING FRAMEWORK OF THE 2021-2027 BUDGET ............................................... 150 

ANNEX 9: ANALYSIS OF IMPACTS OF POLICY OPTIONS ............................................................... 190 

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1. 

INTRODUCTION 

Legal and political context 

The  true  value  of  the  EU  budget  lies  in  the  tangible  impact  it  delivers  on  the  ground. 
Through  performance  budgeting1,  the  EU  ensures  that  every  euro  is  spent  effectively  and 
efficiently,  enabling  European  citizens  to  get  better  value  for  money.  The  performance 
framework of the EU budget is also key to ensure maximum transparency and accountability, 
providing budgetary authorities and citizens with a clear view of how the EU budget is being 
used and what results are achieved.  

The implementation of the current and previous EU programmes, as demonstrated by 
relevant  programme  evaluations,  has  shown  that  the  complexity  of  the  funding 
architecture is the major factor hindering the impact of the EU budget. Currently, many 
programmes may finance the same activities, but without the same rules and conditions and 
there is insufficient flexibility to respond to unforeseen needs. This leads to inefficiencies and 
administrative burden for beneficiaries, Member States (MS) and the Commission. In addition, 
a difficult budgetary situation – with the start of NextGenerationEU repayments, the increasing 
number of EU priorities and the tight fiscal situation of MS – reinforces the need to reduce 
identified inefficiencies and administrative burden. The Political Guidelines acknowledge that 
‘our spending  is  spread  over too  many overlapping  programmes  – many  of  which fund  the 
same things  but  with different  requirements  and  difficulties to  combine funding effectively’. 
The Guidelines set out that the new long-term budget needs to be more focused, simpler, with 
fewer  programmes  and  more  impactful.  In  line  with  the  Political  Guidelines,  the  College 
adopted on 11 February 2025 the Communication ‘The road to the next multiannual financial 
framework’, which states that ‘the next long-term budget will have to address the complexities, 
weaknesses and rigidities that are currently present and maximise the impact of every euro it 
spends’. The Communication also underlines that flexibility is key in guaranteeing the budget’s 
ability to respond to a changing reality.  

The post-2027 MFF will need to be fit for delivering  on EU political priorities such as 
competitiveness, security and defence, migration, the green and digital transition, clean 
industry, and research and innovation, while also adapting to the evolving needs of the 
EU, upholding EU values  and ensuring social fairness. The increasing  number of policy 
priorities  that  the  EU  budget  will  have  to  address  calls  for  maximising  its  impact  and 
performance, in line with the highest standards of financial management. The post-2027 budget 
will therefore require a high-quality performance framework to develop its full potential, taking 
into account the lessons learned from the 2021-2027 MFF. This performance framework will 
need to be designed to strengthen the capacity to deliver against EU policy priorities, respond 
flexibly to new realities, ensure accountability, and allow the EU to communicate effectively 
with stakeholders and citizens about the EU budget and how it adds value to the lives of EU 
citizens. 

1  Performance  budgeting  can  be  defined  as  the  ‘systematic  use  of  performance  information  to  inform  budget 
decisions, either as a direct input to budget allocation decisions or as contextual information to inform budget 
planning’ Tryggvadottir, Á. and I. Bambalaite (2024), ‘OECD performance budgeting framework’ 

2 

 
 
 
 
 
Performance framework of the EU budget 

The performance framework of the budget is based on the Financial Regulation, which 
sets out a number of performance requirements for the EU budget, as well as programmes 
legal basis. It was further framed by the 2021 Communication from the Commission on the 
performance framework for the EU budget under the 2021-2027 MFF2. 

This impact assessment report focuses on the performance framework of the EU budget, 
which is based on three pillars:  

1.  Programming horizontal policy priorities such as gender equality and the green transition, 
across  all  EU  budget  programmes,  at  all  stages  of  the  EU  budget  decision  and 
implementation process – preparation, design, implementation, monitoring and evaluation; 
2.  Monitoring of expenditures contributing to certain horizontal priorities of the EU budget, 

and their outputs and results, with evaluations assessing impact;  

3.  Reporting on the performance of the EU budget including its contribution to and impact 
on horizontal priorities: EU budget performance information is reported annually through 
relevant reports and dashboards of indicators. Information on funding opportunities – e.g. 
calls for proposals – is also displayed through relevant portals. 

Performance in the 2021-2027 budget 

Under  the  interinstitutional  agreement  (IIA)  accompanying  the  2021-2027  MFF3,  the 
European  Parliament,  the  Council  and  the  Commission  committed  to  integrate 
horizontal priorities into the EU budget, including through spending targets for climate and 
biodiversity. The IIA commits in particular to: 

•  Spend  at  least  30%  of  all  resources  available  under  the  2021-2027  MFF  and 

NextGenerationEU on addressing climate change; 

•  Support biodiversity with a view to working towards the ambition of providing 7.5 % in 

2024 and 10 % in 2026 and in 2027 of annual spending;  

•  Develop a new gender equality expenditure tracking methodology and mainstreaming of 

that objective as a pilot as of 2023;  

•  Report  annually  on  the  implementation  of  the  United  Nations  Sustainable  Development 

Goals in all relevant programmes. 

While the 2021-2027 MFF benefits from a more modern performance framework4, there 
remains room for enhancement, notably in terms of simplification, consistency and better 
understanding of the results of the EU budget. The post-2027 MFF offers a key opportunity to 
address these challenges and maximise the impact of the EU budget, building upon the findings 
of the mid-term evaluations of programmes implemented since 2027.  

The post-2027 MFF will also need to be aligned with recent legal developments, including 
the 2024 Financial Regulation recast5 – which includes new requirements on the principles 

2 SWD(2021) 133 final 
3  Interinstitutional  Agreement  between  the  European  Parliament,  the  Council  of  the  European  Union  and  the 
European Commission, 2020 EUR-Lex - 32020Q1222(01) - EN - EUR-Lex 
4 Communication on the EU budget performance framework 2021-2027 - European Commission 
5 Regulation (EU, Euratom) 2024/2509, Regulation - EU, Euratom - 2024/2509 - EN - EUR-Lex 

3 

 
 
 
of  DNSH,  gender  equality,  performance  indicators  as  well  as  transparency  rules  regarding 
beneficiaries  of  EU  budget  programmes.  The  impact  assessment  focuses  therefore  on  the 
mainstreaming  of  the  gender  equality  and  DNSH  principles  because  these  are  legal 
requirements. Other policy objectives (such as competitiveness and defence) will be supported 
through  the  steering  mechanism  of  the  post-2027  MFF,  which  will  enable  to  identify  and 
mainstream  relevant  priorities  across  programmes,  and  through  the  specific  design  of 
individual programmes such as the European Competitiveness Fund and the policy objectives 
of the National and Regional Partnership Plans Fund6. 

This  impact  assessment  aims  at  defining  the  performance  framework  for  all  EU  budget 
programmes post-2027, including for the purpose of monitoring and evaluation. 

2.  PROBLEM DEFINITION 

Problem tree: problem drivers, problems and consequences  

2.1.  What are the problems and their drivers? 

2.1.1.  Problem  1:  Insufficient  flexibility  and  excessive  complexity  of  mainstreaming 
provisions   

The  establishment  of  a  modern  performance  framework  across  the  EU  budget  has 
enhanced the clarity of programmes intervention logic and understanding of their results. 
Through  a  tracking  methodology  that  accurately  identifies  green  investments  –  applied 
consistently  across  Cohesion  Funds  and  the  Recovery  and  Resilience  Facility  (RRF)  –  and 
robust  delivery  mechanisms,  spending  objectives  and  tools  –  such  as  climate  proofing  of 
investments or environmental safeguards in the Common Agricultural Policy (CAP), the EU 

6 This impact assessment does not consider SDGs as a priority to be mainstreamed per se due to the fact that SDGs 
are by definition embracing multiple other priorities, and of a high-level nature. 

4 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
 
 
 
 
budget has enhanced its capacity to achieve its climate ambitions. This enabled the EU budget 
to  provide  a  significant  contribution  to  implementing  the  Paris  Agreement7,  the  European 
Green Deal8 and the European Climate Law9. 

However, the EU budget operates within a relatively fixed framework which can limit its 
ability  to  adapt  to  evolving  policy  priorities  and  emerging  needs,  given  the  long-term 
nature of the MFF. Some mainstreaming provisions of the 2021-2027 MFF have an impact 
on flexibility, making it more difficult to respond to complex economic and geopolitical issues, 
such  as  crises,  pandemics,  war  and  natural  disasters,  which  demand  a  responsive  and  agile 
budgetary approach10. This weighs on the EU budget's ability to  respond to pressing policy 
priorities  while  simultaneously  advancing  key  long-term  objectives,  such  as  the  green  and 
digital transitions and gender equality. 

The  overlap  of  several  programmes  with  similar  policy  scopes  and  different  delivery 
models,  and  limitations  to  align  the  EU  budget  with  cross-cutting  priorities  creates 
inefficiencies (cf. Annex 6). The biodiversity spending target and gender equality provisions 
of the IIA were not fully matched with the necessary mainstreaming requirements in spending 
programmes, leading to inconsistent approaches. As a result, while the climate target is on track 
to be achieved, current projections indicate that the 2026 and 2027 biodiversity ambition will 
be challenging to meet11. Divergences have also been observed in how the 'DNSH' principle 
has been applied across programmes.12  

Problem driver 1: A fragmented MFF structure with multiple mainstreaming requirements at 
MFF and programme levels  

The 2021-2027 budget features heterogeneous mainstreaming requirements at MFF and 
programme levels. Funding is scattered across several EU funds which rely upon a variety of 
mainstreaming provisions – defined through programme regulations – which are fixed for the 
whole  MFF  duration,  such  as  programme-level  spending  targets,  budget  earmarking  and 
ringfencing, enabling conditions and conditionality requirements. This may generate barriers 
when needing to reallocate funding to the mainstreaming of new priorities in the context of a 
complex and dynamic geopolitical and economic environment. 

Similar  actions  are  often  supported  through  a  variety  of  mainstreaming  tools.  For 
instance, energy efficiency investments are subject to different conditions under the European 
Regional  Development  Fund  (ERDF),  Just  Transition  Fund  (JTF),  InvestEU,  and  the 
Modernisation  Fund.  Likewise,  renewable  energy  projects  receive  funding  from  multiple 
sources – InvestEU, ERDF, and Horizon Europe – each with its own requirements.  

7 https://unfccc.int/sites/default/files/english_paris_agreement.pdf  
8 https://commission.europa.eu/document/daef3e5c-a456-4fbb-a067-8f1cbe8d9c78_en  
9 https://eur-lex.europa.eu/EN/legal-content/summary/european-climate-law.html  
10  EU  Budget  Policy  Brief  –  Lessons  for  a  Future-Proof  EU  Budget,  2140592d-a44b-4d93-a00b-
4910e9b29584_en 
11  AMPR  –  Annex  I  –  3.  Horizontal  policy  priorities  in  the  EU,  https://op.europa.eu/en/publication-detail/-
/publication/7ebd8cea-2ebe-11ef-a61b-01aa75ed71a1/language-en  
12 
‘DNSH’  principle 
https://publications.jrc.ec.europa.eu/repository/handle/JRC135691  

implementation  of 

instruments,  2023, 

selected  EU 

JRC,  The 

the 

in 

5 

 
 
 
Ringfencing

Dedicated 
programmes 

Earmarking (e.g. 
strands, budget lines)

Programme 
design

Do no 
significant harm

Objectives

Exclusion list

Incentives

Technical Guidance

Programme target

Enabling conditions

Climate proofing

Performance

Framework

Tracking methodology

Monitoring/Indicators

EU budget-wide target

Reforms incentives

Environmental impact 
assessment

Reporting

Figure: Green mainstreaming toolbox 

Problem driver 2: Differences between spending targets applied at MFF and programme level  

While being effective in raising general awareness vis-à-vis policy priorities, as well as 
contributing  to  agreed  EU  objectives  and  international  commitments,  horizontal 
spending targets – such as the climate and biodiversity targets of the 2021-2027 MFF – 
can  hamper  the  responsiveness  of  the  EU  budget  to  address  new  needs  and  priorities. 
Spending targets have supported investment predictability and helped meet the EU climate and 
biodiversity  objectives,  while  contributing  to  reinforcing  industrial  competitiveness,  energy 
security and strategic independence. The climate and biodiversity targets have also helped the 
EU to meet its international obligations under the Paris Agreement and the Global Biodiversity 
Framework.  However,  setting  a  horizontal  spending  target  limits  the  objectives  that  can  be 
financed in the different programmes – which may have different priorities and less potential 
to contribute to spending targets set at the beginning of the MFF (e.g. Ukraine facility). Any 
spending target set at horizontal level can only work if there is a corresponding alignment of 
the policy objectives financed by the programmes. Some programmes such as LIFE and the 
EMFAF  reached  respectively  49%  and  28%  biodiversity  contribution,  exceeding  the 
biodiversity  spending  target,  focusing  on  nature  restoration  measures  (for  LIFE)  and  on 
protecting marine biodiversity and incentivising sustainable fishing (for EMFAF). However, 
the multiplicity of objectives to be mainstreamed – such as in the case of external action funds 
such as the Neighbourhood, Development and International Cooperation Instrument (NDICI-
Global Europe)13 – may make it challenging to achieve programmes spending targets. 

Problem driver 3: Heterogenous mainstreaming provisions included in programmes 

Mainstreaming provisions – such as on DNSH, gender equality, climate, biodiversity – 
are  included  in  MFF  programmes  in  a  heterogenous  way14.  While  this  enables  to  tailor 
requirements to the specificities of programmes, it generates complexities and burden for MS 
and project beneficiaries such as Small and Medium Enterprises (SMEs) and other businesses 
which  have  to  deal  with  divergent  requirements.  As  a  result,  beneficiaries  face  potential 

13  Regulation - 2021/947 - EN - EUR-Lex, Article 8.8 (list of objectives to be mainstreamed under NDICI) 
14 Full overview of the tools available in the swd_2022_225_climate_mainstreaming_architecture_2021-2027.pdf 
and in the Biodiversity tracking methodology for each programme 2021-2027 

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uncertainties and a lack of predictability, which may negatively impact the competitiveness of 
key sectors supported by EU funds, as  highlighted by the  evaluations15 of  a number of EU 
budget programmes, as also echoed by the results of the Open Public Consultation.  

A number of addition structural reasons hinder mainstreaming, such as the diversity of 
management modes, the design and complexity of programmes governance structure, which 
can make it difficult to ensure consistent application of horizontal principles across all levels 
of policy and implementation. The differences between Member States and third countries in 
terms of legal frameworks and political priorities also present additional challenges. These are 
often compounded by limited administrative capacity in certain Member States and regions. 

The DNSH principle has been applied in a number of EU programmes under the 2021-
2027 period16 but its application remains heterogenous17. The principle is mandatory only 
for some programmes and its application faces varying degrees of integration18. As a result, the 
same type of intervention is subject to different DNSH requirements depending on the rules 
applying under each programme, which can lead to consistency challenges and difficulties in 
channelling multiple sources of funding towards strategic investments19. The operationalisation 
of DNSH through varying technical guidances results in a parallel application of different sets 
of technical criteria for similar projects financed under different programmes. As shown by the 
evaluations  of  some  programmes,  implementing  DNSH  can  generate  administrative  burden 
and may complicate access to funding20. MS considered that the application of the principle 
would  have  benefited  from  further  guidance21.  Some  programmes  take  into  account  the 
proportionality principle e.g. through DNSH conditions (SCF22, RRF) or through a monetary 
threshold  (InvestEU).  While  several  programmes  use  exclusion  lists,  including  InvestEU, 
ERDF,  such  lists  are  not  aligned,  resulting  in  complexities  for  beneficiaries  and  limiting 
synergies between programmes. The inclusion of DNSH – where feasible and appropriate in 
accordance with the relevant sector-specific rules – in the recast Financial regulation requires 
a new approach to operationalise the principle across EU funds.  

The biodiversity spending target is likely to be missed due to a lack of policy design tools 
and spending targets under sectorial regulations. Current programming suggests that the 
target is likely to be missed, with 7.3% of MFF funds dedicated to biodiversity in 2024, and 
7.8% and 7.9% expected in 2026 and 2027 respectively. Biodiversity investments account for 
2% of green transition investments under the RRF23, and 6% under the cohesion policy funds. 
The Commission’s pledge24 to double external action support to biodiversity by 2027 – through 
NDICI-Global  Europe  and  IPA  III  –  is  nonetheless  on  track  to  be  achieved.  Biodiversity 
finance is likely to continue to rely mostly upon public sources, notably on the MFF, to fulfil 

15 Interim evaluation of the InvestEU programme, 2024 – Mid-term evaluation of the RRF, 2024 
16  Full  overview  by  tool  and  by  programme  available  in  the  climate  mainstreaming  architecture  2021-2027: 
swd_2022_225_climate_mainstreaming_architecture_2021-2027.pdf. 
17 Mainstreaming in the post-2027 Multiannual Financial Framework | Think Tank | European Parliament  
18  Bruegel  study  ‘Greening  the  EU  budget:  why  climate  mainstreaming  needs  reform’,  2025  –  European 
Parliament ‘Performance and mainstreaming framework for the EU budget – Empirical  evidence, analysis and 
recommendations’, 2024 
19 The implementation of the ‘DNSH’ principle in selected EU instruments, Joint Research Centre, 2023  
20 Interim evaluation of the InvestEU programme, 2024 
21 ECA special report 13/2024: Absorption of funds from the Recovery and Resilience Facility 
22 DNSH technical guidance to the SCF, 2025 
23 European Commission (2024), Recovery and Resilience Scoreboard 
24 2021 State of the Union Address by President von der Leyen 

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the  EU  biodiversity  commitments  until  the  next  decade,  including  in  the  context  of  the 
Kunming Montreal Global Biodiversity Framework.  

Mainstreaming of gender equality into MFF programmes has seen progress but remains 
uneven across the EU budget. A number of programmes have achieved significant progress, 
such as NDICI–Global Europe12 and through the Gender Action Plan III13 which set a target 
requiring 85% of actions to have gender equality as a principal or significant objective and at 
least 5% of those actions to have gender equality as principal objective. Similarly, the Common 
Provisions  Regulation  (CPR)  introduced  gender  equality  as  a  thematic  enabling  condition, 
establishing it as a prerequisite for the effective implementation of EU funds’ specific objective 
on gender balanced labour market participation. Horizon Europe and the European Social Fund 
also provide explicit gender equality objectives and legal provisions to achieve gender equality. 
Nonetheless, in 2023 only 11% of the EU budget is assessed as actively contributing to gender 
equality, including due to limited consideration of gender equality in the impact assessments 
and the design of some EU funds. Despite the positive trend in gender scores 1 and 225 between 
2021-2023, in 2023 a substantial portion of the EU budget (69%) is assessed as not contributing 
to gender equality.  

Figure: Gender mainstreaming toolbox 

2.1.2. Problem 2: The inconsistency and complexity of monitoring requirements hamper the 
measurement of the EU budget contribution to policy priorities. 

The monitoring requirements of the EU budget are inconsistent, which limits capacity to 
measure EU budget performance and inform policy making (cf. Annex 7). The monitoring 
of cross-cutting priorities – such as climate, biodiversity and gender equality – has improved 
but the current tracking system remains heterogeneous. The performance framework is also not 
fully equipped to measure progress of the EU budget’s contribution to cross-cutting priorities 
through  aggregable  performance  indicators.  Monitoring  provisions  complexity  generates 
administrative burden and costs affecting beneficiaries, MS, partner countries, implementing 
partners and EU institutions26, as also echoed by the results of the Open Public Consultation. 

25  Score  2  tags  interventions  primarily  aimed  at  improving  gender  equality; Score  1  tags  interventions  with 
significant but secondary gender equality objectives; Score 0 tags gender-neutral interventions; and Score 0* tags 
interventions with potential gender impact, but for which there is insufficient data available. 
26 2024 European Parliament study ‘Performance and mainstreaming framework for the EU budget: Empirical 
evidence, analysis and recommendations’ 

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Problem driver 1:  

The monitoring framework of the EU budget is based on different methodologies to track 
expenditures  contributing to horizontal priorities across  funds.  Tracking methodologies 
differ  between  programmes  i.e.  expenditures  allocated  to  a  given  intervention  type  –  e.g. 
ecosystem restoration – are challenging to measure across MFF programmes because of a lack 
of harmonised intervention fields at MFF level. Tracking methodologies differ between policy 
priorities, such as under the CAP whereby different methodologies are used for climate and 
biodiversity27.  This  lack  of  consistency  also  hinders  the  potential  to  assess  and  compare 
budgetary performance between programmes and MS. Tracking methodologies were mostly 
developed  after  the  start  of  the  2021-2027  period,  reducing  the  potential  of  programming 
decisions to rely on ex-ante expenditure tracking. The European Court of Auditors (ECA) has 
made  a  number  of  recommendations28  so  as  to  reinforce  the  consistency  of  expenditure 
monitoring. 

On gender equality, expenditure monitoring has significantly improved but continues to 
rely on a variety of approaches, and does not sufficiently enable to monitor the impacts 
of spending. The gender equality tracking methodology was introduced in 2022 – i.e. after the 
adoption of the basic acts of the 2021-2027 budget – which resulted in a variety of approaches 
across  programmes.  Some  adopted  specific  tracking  methods,  such  as  the  CPR  tracking 
method, the RRF method based on flagging relevant measures, and the Common Foreign and 
Security  Policy  marker.  In  2023,  gender  score  0*  still  represents  20%  of  the  EU  budget, 
showing  a  decreasing  but  structural  limitation  in  data  collection.  The  lack  of  gender-
disaggregated  data  also  remains  a  challenge,  as  a  number  of  programmes  do  not  collect  or 
report indicators broken down by gender, which makes it challenging to evaluate the actual 
impact of gender-related investments and make informed decisions about future funding. 

Problem driver 2:  

There are more than 5 000 – heterogenous, non-aggregable – performance indicators and, 
under the RRF, around 7 000 milestones and targets, defined to address different needs 
such  as  assessing  performance  in  the  context  of  the  draft  budget,  monitoring  and 
evaluation  of  programmes  and  MS  plans,  and  payments.  Performance  indicators  are 
defined  in  programme  regulations,  in  dedicated  delegated  acts  as  well  as  in  staff  working 
documents,  work  programmes  and  agreements  with  implementing  partners.  The  CAP  and 
Cohesion policy funds have developed systems using a limited and aggregable set of indicators, 
corresponding to around 360 indicators. In the CAP, the approach even prevents the collection 
of  MS  specific  indicators.  In  cohesion  policy,  common  indicators  are  used  to  set  targets  in 
national  and  regional  programmes,  with  a  subset  of  indicators  defined  for  use  in  corporate 
reporting. The ESF+ uses a monitoring system with a limited set of common indicators and 38 
indicators to monitor support in the area of material deprivation, as well as 3 934 additional 
programme-specific indicators as part of MS programmes. The RRF uses 14 – common – core 
performance indicators aimed at tracking progress towards the Facility’s objectives and, as part 
of the performance-based feature of the instrument, 7 129 indicators used as milestones and 

27  The  methodologies  use  different  approaches  e.g.  direct  payments  are  counted  as  3%  under  the  biodiversity 
methodology  vs.  40%  under  the  climate  one.  The  climate  methodology  is  less  granular  than  the  biodiversity 
methodology (Bruegel study ‘Greening the EU budget: why climate mainstreaming needs reform’, 2025). 
28  ECA  Special  report  14/2024  ‘Green  transition  –  Unclear  contribution  from  the  Recovery  and  Resilience 
Facility’, Report 09/2022 ‘Climate spending in the 2014-2020 EU budget Not as high as reported’, Report 13/2020 
‘Biodiversity on farmland: CAP contribution has not halted the decline’ 

9 

 
 
 
targets to measure progress towards the achievement of a reform or an investment, measuring 
outputs and results  and triggering  corresponding payments. Programmes using indicators  to 
guide disbursement decisions are an exception, as the vast majority of funds use indicators for 
information  gathering  and  monitoring  purposes.  Indicators  are  also  used  in  the  context  of 
programmes evaluations29, which sometimes lack adequate indicators and data to assess the 
progress  and  success  of  programmes  at  different  stages  of  their  intervention  logic.  The 
management  of  indicators  datasets  generates  administrative  burden  for  EU  institutions  and 
beneficiaries, as demonstrated by some programmes evaluations30. 

A number of programmes use similar yet slightly different indicators to report on similar 
outputs – e.g. regarding high-speed connectivity31. This fragmented approach results in a large 
number  of  non-aggregable  indicators  at  EU  budget  level32,  which  reduces  possibilities  to 
measure EU budget performance across programmes and to inform policies33. There are also 
significant question marks on the usefulness of a large number of indicators, which provide 
unclear added-value while generating significant administrative burden for MFF beneficiaries, 
MS, partner countries and EU institutions34.  

The balance between output, result and impact indicators has improved in the 2021-2027 
programming period but is not optimal. All three types of indicators are essential to assess 
programme performance and follow a different timeline: output indicators provide insight into 
what  the  programme  directly  finances  and  its  immediate  activities  (e.g.  construction  of  an 
electrified railway); result indicators track the immediate effects of these outputs (e.g. number 
of people using the newly constructed railways); and impact indicators measure trends in the 
long-term objectives addressed by the intervention (e.g. greenhouse gas emissions avoided). A 
comprehensive monitoring framework covering the main policy areas and the most significant 
effects with results and impacts is crucial35.  

29 as per Article 34 of the Financial Regulation 
30 Mid-term evaluation of the RRF - European Commission and InvestEU programme – interim evaluation 
31 For instance, connectivity is measured in the RRF by ‘additional dwellings with internet access provided via 
very  high-capacity  networks’,  while  CEF  measures  ‘new  connections  to  high  capacity  networks  for  socio-
economic  drivers and high quality connections foA recent European  r local communities’, and InvestEU uses 
‘additional households, enterprises or public facilities that obtained access to high-speed internet’. 
32  European  Parliament  study  ‘Performance  and  mainstreaming  framework  for  the  EU  budget  -  Empirical 
evidence, analysis and recommendations’, 2024 
33 Mainstreaming in the post-2027 Multiannual Financial Framework | Think Tank | European Parliament 
34 European Commission 2024, European Union's external financing instruments (2014-2020 and 2021-2027) 
35 2025 Council recommendation on the discharge to be given to the Commission in respect of the implementation 
of the general budget of the European Union for the financial year 2023 

10 

 
 
 
Figure: Understanding the different types of performance indicators  

Impact indicators are not designed in a manner that facilitates the measurement of long-
term  outcomes  of  programmes  beyond  their  expiration.  Visibility  of  programmes 
performance after their expiration needs to improve, particularly for measures funded across 
programming  periods,  such  as  large-scale  infrastructure  investments  under  CEF,  research-
funded projects, or ecosystem restoration. One of the challenges linked to measuring impacts 
is  that  benefits  often  accrue  over  longer  periods  than  the  MFF,  for  example  in  the  case  of 
infrastructure projects. 

Programme evaluations have provided further information on the fitness for purpose of 
the  existing  framework  to  measure  impacts.  The  interim  evaluations  of  Erasmus+  and 
Creative  Europe  found  that  existing  indicators  are  effective  for  monitoring  outputs  like 
participant numbers and projects funded, but less adequate for capturing long-term impacts, 
such  as  systemic  educational  reforms  or  cultural  diversity,  due  to  data  quality  issues  and 
attribution  challenges.  Recommendations  included  simplifying  indicator  sets,  enhancing 
qualitative metrics, and improving data collection to better assess performance and impact. 

Significant additional data are collected by MS through administrative registers, either 
as  beneficiary-level  data  under  EU  budget  programmes  or  as  administrative  data 
collected  under  other  legal  bases.  Such  registers  include  national  agencies  registers  or 
national statistical office databases. Such data – including information on e.g. location, gender, 
enterprise size – is a rich source of analysis and policy learning but is not available in a single 
structured  framework  and  therefore  remains  insufficiently  exploited  in  the  context  of 
performance monitoring. 

2.1.3. Problem 3: The fragmentation and duplication in reporting performance information 
and  funding  opportunities  across  the  EU  budget  leads  to  reduced  transparency  and  high 
administrative burden. 

The 2021-2027 performance framework improved reporting, focusing on four areas:   

•  streamlining – by merging the Programme Statements – Working document I of the Draft 
Budget and the Programme Performance Overview into a single, more focused document 
annexed to the Annual Management and Performance Report (AMPR);   

11 

 
 
 
• 

integrating performance in the annual budgetary cycle – publishing the draft annual 
budget  proposal  and  the  AMPR  on  the  same  day  ensures  that  decisions  on  next  year’s 
budget can take into account the results achieved in the previous year. 

•  providing  financial  information  –  including  on  transfers,  contributions  from  other 
countries and stakeholders, and decommitments – moving away from traditional budgetary 
presentation based on headings. 

•  providing context and assessments of how the programmes are performing. 

Yet the sheer abundance of documents results in an overload of data, leading to confusion 
and potential inconsistencies (cf. Annex 8). The fragmentation and duplication of information 
generates  administrative  burden  and  reduced  transparency  for  beneficiaries,  MS  budgetary 
authorities, implementing partners and EU institutions.  

Problem driver 1:  

Reporting  requirements  –  in  the  context  of  the  discharge,  draft  budget,  strategic 
planning, and other programme-specific reports – are not aligned in timing and content. 
The reporting framework is fragmented, as it is set by fund-specific regulations in addition to 
the  Financial  Regulation.  The  Commission  provides  extensive  reporting  on  the  EU  budget 
performance  through  the  programme  performance  statements  annexed  to  both  the  AMPR 
(discharge) and the Draft Budget, as well as 32 additional annual reports on  specific funds. 
This high  number of reports increases  risks  of inconsistencies and reduces  transparency for 
other  EU  institutions  and  MS  budgetary  authorities36.  Overall  the  reports  prepared  by  the 
Commission  are  underused  as  input  in  steering  budgetary  decisions  despite  the  significant 
resources that are employed in producing them.  

Problem driver 2:  

The  Commission  reports  performance  information  through  over  20  different  publicly 
available  online  dashboards37.  Efforts  have  been  made  during  the  2021–2027  period  to 

36 2024 European Parliament study ‘Performance and mainstreaming framework for the EU budget: Empirical 
evidence, analysis and recommendations’ 
37 including 4 dashboards published by DG BUDG: EU Financial Transparency System; EU Funded projects | EU 
Funding & Tenders Portal; EU Spending and Revenue 2021-2027; Programme Performance Statements   

12 

 
 
 
 
 
enhance transparency and harmonise data publication, such as for the CAP and Cohesion policy 
(AgriFood  Data  Portal,  Cohesion  Open  Data  Platform).  However,  as  the  organisation  and 
management of data – as well as the type and granularity of data – are not standardised across 
funds, it is not possible to compile information at EU budget level38. Existing dashboards do 
not allow a centralised view of EU budget allocations nor results achieved by sector, such as 
transport  or  education,  or  by  cross-cutting  priority,  such  as  climate  action  or  gender 
equality3940.  While  generating  administrative  burden,  the  current  reporting  system  does  not 
allow for an overview of all EU-funded projects within a specific territory – be it a city, region, 
or state. 

The recast of the Financial regulation reinforces transparency requirements across the 
EU  budget  as  from  the  next  MFF,  in  particular  by  requiring  to  make  available  on 
a centralised website information on recipients of funds financed from the budget41. The 
regulation provides several details regarding the information to be published, the process of 
publishing, and the rules for processing data, including personal data. A number of EU funds 
under  direct  and  indirect  management  publish  such  information  through  the  Financial 
Transparency  System.  However,  there  is  no  comprehensive  reporting  of  information  on 
beneficiaries for programmes under shared management. While the process of obtaining the 
necessary  information  remains  subject  to  sector-specific  rules,  information  still  has  to  be 
centralised through a single website as required by the Financial regulation. 

Information about funding opportunities is scattered through a large number of portals 
due to a lack of interoperability of databases across EU funds. For example, information 
about EU funding opportunities for many programmes in direct and indirect management is 
made available under the Funding & Tender Portal42. Information is made available through 
several other portals, such as Access to EU Finance43, the Enterprise Europe Network44 and the 
EU Rural toolkit45. As a result, project promoters cannot easily gain an overview of funding 
opportunities  available  in  their  region  or  sector,  as  they  must  already  be  familiar  with  the 
specific  funds  that  could  support  their  projects  in  order  to  apply.  This  lack  of  visibility 
generates confusion, undermines transparency and reduces beneficiaries’ ability – including 
local organizations and SMEs – to identify suitable funding sources and access financing under 
the EU budget. The fragmentation of portals also augments the likelihood for beneficiaries to 
apply and obtain funding from different EU sources for the same project. 72% of respondents 
to a Commission survey indicated that they would see value in a one-stop-shop combining EU 
and national funding46. 

38 Performance-based Programmes under the post-2027 MFF | Think Tank | European Parliament 
39 2024 European Parliament study ‘Performance and mainstreaming framework for the EU budget: Empirical 
evidence, analysis and recommendations’ 
40 For example, it is not possible to obtain information as to how many beneficiaries obtained funding for education 
across all EU programmes, or how many kilometres of railways were built. 
41 Article 38 of the Financial regulation 
42 EU Funding & Tenders Portal 
43 https://youreurope.europa.eu/business/finance-funding/getting-funding/access-finance/search/  
44 https://een.ec.europa.eu/about-enterprise-europe-network/advice-support/access-eu-funding-programmes 
45 https://funding.rural-vision.europa.eu/finder?lng=en  
46 2024 Commission STEP taskforce survey on ‘Access to EU funding – users perspective’ 

13 

 
 
 
2.2.  How likely is the problem to persist? 

The  limited  ability  to  aggregate  information  at  the  level  of  the  MFF  continues 
undermining  the  ability  to  assess  the  performance  of  the  EU  budget  and  support  an 
informed-based  EU  budget  implementation.  The  issue  of  inefficient  and  burdensome 
monitoring of performance is therefore likely to persist unless corrective action is taken. 

As long as the performance framework remains defined by provisions scattered across 
various legal bases of different programmes, ensuring the coherence of these provisions, 
rules, and principles will remain a significant challenge. This issue was evident during the 
2021–2027  period,  when  efforts  to  harmonise  provisions  across  programmes  achieved  only 
limited success. Without a unified performance framework upfront, it would be challenging to 
steer the mainstreaming of horizontal priorities in the EU budget in a consistent way and to 
form  a  clear  understanding  of  the  EU  budget's  overall  achievements.  The  current  lack  of 
consistency of performance provisions undermines beneficiaries’ ability to effectively leverage 
the  financing  opportunities  offered  by  the  EU  budget,  in  particular  for  sectors  that  can  be 
supported by different EU budget programmes. 

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

The legal basis for acting in this area is Article 322(1) TFEU, which requires the adoption of 
regulations laying down the financial rules which determine the procedure to be adopted for 
establishing and implementing the budget and for presenting and auditing accounts. 

In addition, the 2024 recast Financial Regulation requires the principles of DNSH and gender 
equality to be taken into account in the next generation of programmes in the post-2027 MFF, 
where feasible and appropriate in accordance with the relevant sector-specific rules. Article 38 
of  the  Financial  Regulation  also  foresees  new  requirements  regarding  the  publication  of 
information on EU budget recipients and operations, including through a centralised website. 
Article 33 of the Financial Regulation further requires appropriations to be used in accordance 
with  the  principle  of  sound  financial  management  and  thus  respecting  the  principles  of 
economy,  efficiency,  effectiveness,  and  focus  on  performance.  It  also  requires  performance 
indicators to be aggregable and comply with the RACER standard and, where applicable, be 
broken down by gender.   

3.2. 

Subsidiarity: Necessity of EU action 

The EU operates a trillion euro budget, holding the potential to drive significant impact 
both within the Union and globally, provided it is used and targeted efficiently, in line 
with political guidelines. It is essential to have a strong and effective performance framework 
in place in order to ensure that the EU budget delivers greater impact in priority areas and that 
its effects are measurable, transparent, and capable of driving continuous improvement through 
scrutiny and learning. EU action is more particularly necessary based on the following aspects: 

•  Fulfilment of Treaty objectives: EU action is justified on grounds of subsidiarity in line 
with Article 317 of the TFEU, which requires sound financial management. The TFEU also 
requires horizontal obligations such as the integration of environmental and climate action 
in EU policies and funding programmes. Article 8 of the TFEU also emphasises the need 
to promote equality between men and women.  

14 

 
 
•  International obligations on climate change and biodiversity: a coherent performance 
framework  supporting  green  mainstreaming  is  necessary  at  EU  level  based  on  its 
international obligations under e.g. the United Nations Framework Convention on Climate 
Change and the Convention on Biological Diversity. 

3.3. 

Subsidiarity: Added value of EU action 

Designing a more efficient performance framework, including the integration of existing 
data sources in a coherent manner, necessarily entails the development of a horizontal 
approach at EU level so as to maximise the performance of investments contributing to 
EU priorities. Making use of the EU budget in favour of e.g. climate, biodiversity and gender 
equality  has  added  value,  especially  for  measures  that  cannot  be  adequately  financed  from 
national  budgets  or  the  private  sector,  because  of  the  transboundary  nature  and  scale  of 
challenges,  territorial  cohesion,  just  transition  needs  or  uneven  levels  of  climate  and 
environmental action and fiscal capacity. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The general objective of this initiative is to propose a simplified, coherent and flexible 
performance  framework  for  the  post-2027  MFF  in  order  to  maximise  the  EU  budget 
capacity  to  deliver  on  policy  priorities  and  effectively  assess  the  performance  of  EU 
budget programmes, while ensuring alignment with the new requirements of the recast 
Financial Regulation.  

The initiative aims in particular at achieving: 

•  Increased flexibility and responsiveness of mainstreaming provisions  across  the 
EU budget:  the initiative should aim at  simplifying  and harmonising  the provisions 
enabling to mainstream horizontal policy priorities across Union programmes so as to 
ensure consistency across the EU budget.  

•  Simplification and streamlining of monitoring requirements across the EU budget
:  the  initiative  should  enable  to  simplify  and  harmonise  expenditure  tracking  across 
Union  programmes,  enabling  to  aggregate  data  across  programmes  and  ultimately 
improving  the  monitoring  of  the  EU  budget  performance.  The  initiative  should  also 
enable to streamline the system of performance indicators at MFF level, enabling to 
better assess performance, monitoring and evaluation, assessing implementation of MS 
plans, funding and payments. 

•  Harmonisation  and  rationalisation  of  reporting  performance  information  and 
funding opportunities across the EU budget: the initiative should address the current 
fragmentation  and  duplication  in  reporting  performance  information  and  funding 
opportunities across the EU budget. The initiative should enable to harmonise reporting 
requirements,  rationalise  existing  systems  of  dashboard  providing  performance 
information, and harmonise information on available funding opportunities and calls 
under the EU budget. 

4.2. 

Specific objectives 

This  impact  assessment  aims  at  evaluating  available  policy  options  according  to  their 
ability to deliver on the following specific objectives: 

15 

 
 
1.  Increased capacity to address current and future policy priorities, and specific MS and 

sectors needs; 

2.  Reduction of administrative burden and costs affecting EU budget beneficiaries, MS, 

partner countries, implementing partners and EU institutions by at least 25%;  

3.  Enhanced capacity to measure EU budget impact, and inform policies and programmes 

management; 

4.  Increased transparency and access to information for MS budgetary authorities and EU 

budget beneficiaries. 

Objectives tree: problem drivers, general and specific objectives, expected results 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

The draft impact assessment identifies three possible levels of harmonisation of performance 
provisions across the three problems identified: 

Policy 
options 

P. Programming and 
mainstreaming 

M. Monitoring 

R. Reporting 

1 

2 

P1: Baseline – 
Programme-specific rules 
on DNSH and gender 
equality 
P2: Activity-specific 
rules: harmonised 
provisions across 
programmes on DNSH 
and gender equality, with 
calibrated harmonisation 

M1: Baseline – Programme-
specific rules for defining 
tracking methodologies and 
performance indicators 
M2: Single methodology to 
track expenditures through 
intervention fields and a 
limited set of common 
mandatory performance 
indicators, with flexibility to 

R1: Baseline – 
Programme-specific 
reporting requirements, 
dashboards and portals 
R2: Single performance 
report, single portal on 
performance information 
and funding opportunities, 
with differentiated 
operationalisation of the 

16 

Fragmented MFF structure with multiple mainstreaming requirementsatMFF and programme levels e.g.earmarking, conditionality etcPROBLEM DRIVERSSPECIFIC OBJECTIVESEXPECTED RESULTSIncreased flexibility and responsiveness of mainstreaming provisions across the EU budgetIncreased capacity to address new and emerging priorities and challenges, and specific MS and sectors needsSimplification and streamlining of monitoring requirements across the EU budgetHorizontal spending targets applied at MFF or programme levelMainstreaming provisions included in programmes in an inconsistent way (e.g. DNSH, gender, working conditions)PROGRAMMINGEnhanced capacity to measure EU budget impactand inform policiesReduction of administrative burden and costs affecting beneficiaries, Member States, implementing partners and EU institutionsNo common methodologyto track expenditures for horizontal priorities across MFF programmes> 5 000-heterogenous, non-aggregable -performanceindicators and > 7 000 RRF milestones and targets addressing different needs: draft budget, monitoring and evaluation, MS plans, link to fundingMONITORING13 portals to inform about funding opportunities, lack of inter-operability of databasesacrossmanagement modes20 dashboards of performance information on programmes–Inconsistent transparency of data on beneficiaries supported32 programme-specificreportingrequirementson top of discharge, draft budget and strategicplanning -not alignedin timing and content Increased transparency and access to informationfor budgetary authorities and MFF beneficiariesREPORTINGSimplified, coherent and flexible performance frameworkenabling to maximize EU budget capacity to deliver on policy priorities post-2027Harmonization and rationalization of reporting of performance information and funding opportunitiesacross the EU budgetGENERAL OBJECTIVE 
 
    
 
and differentiated 
operationalisation per 
management mode 
P3: Activity-specific 
rules: fully harmonised 
provisions on DNSH and 
gender equality 

3 

adopt additional programme-
specific performance 
indicators 
M3: Single methodology for 
the EU budget to track 
expenditures through 
intervention fields, and fully 
harmonised list of 
performance indicators 
across programmes (linked to 
intervention fields) 

single portal per 
management mode or 
sector 
R3: Single performance 
report, single portal on 
performance information 
and funding opportunities, 
with fully harmonised 
operationalisation across 
management modes 

5.1.  What is the baseline from which options are assessed? 

Under a baseline situation, the performance provisions set at programme level under the 2021-
2027  period  would  continue  regarding  the  three  identified  problems.  The  baseline  does 
nonetheless not correspond to a ‘no-policy-change’ scenario, but to a dynamic baseline, as the 
performance framework of the EU budget will automatically need to undergo adaptations to 
reflect  the  new  architecture  of  the  post-2027  EU  budget,  which  would  entail  fewer 
programmes. If many of the current numerous programmes are consolidated, such programmes 
will necessarily result in changes in terms of monitoring and reporting on performance. More 
details on the expected impacts of this baseline options are available under Annex 9. 

Policy  option  P1:  Programming/mainstreaming  of  horizontal  priorities  –  Programme-
specific rules on DNSH and gender equality: 

Under this option, the mainstreaming of EU policy objectives – e.g. gender equality, climate 
and environment – into programming would follow a programme-based approach.  

The requirement from the financial regulation to implement programmes and activities taking 
into account the principles of DNSH to the environment and gender equality, where feasible 
and  appropriate  and  in  accordance  with  sector-specific  rules,  would  be  fulfilled  using  a 
programme-based approach, as applied in the 2021-2027 period. Specific DNSH and gender 
equality  requirements  would  be  established  for  each  EU  budget  programme,  even  if  the 
architecture of the post-2027 MFF features a lower number of programmes than in the 2021-
2027 period. 

A specific DNSH guidance or set  of requirements  would be developed for each EU budget 
programme to allow for tailored implementation of the DNSH principle. As a result, a given 
intervention  –  i.e.  category  of  activity  –  may  be  subject  to  different  DNSH  requirements 
depending on the rules applying under each programme. 

Gender equality would be mainstreamed through provisions varying across programmes, such 
as enabling conditions and other programme-specific requirements. 

Policy option M1: Monitoring of expenditures and indicators – Programme-specific rules 
for defining tracking methodologies and performance indicators: 

This  baseline  policy  option  foresees  maintaining  a  programme-based  approach  towards 
monitoring the performance of the EU budget. 

17 

 
 
Programme-specific  methodologies  would  track  expenditures  contributing  to  EU  policy 
objectives.  Some  programmes  would  use  intervention  fields  to  monitor  expenditures,  while 
other  programmes  would  use  different  approaches,  sometimes  requiring  a  subjective 
assessment at project officer level for each intervention and priority.  

Programme-specific performance indicators would be adopted e.g. through programmes legal 
acts.  Programmes  would  apply  different  rules  for  identifying  and  reporting  relevant 
expenditures,  as  well  as  different  sets  of  performance  indicators,  therefore  limiting  the 
possibility to aggregate data and evaluate performance at EU budget level. 

Policy option R1: Reporting of performance information – Programme-specific reporting 
requirements, dashboards and portals: 

This  baseline  policy  option  foresees  maintaining  a  programme-specific  approach  to  the 
reporting of performance information across the EU budget. 

Existing performance reporting requirements would be maintained, including heterogeneous 
requirements across programmes legal bases. 

The  multiple  dashboards  displaying  performance  information  would  be  maintained. 
Transparency  requirements  regarding  the  collection,  storage  and  publication  of  data  on 
beneficiaries funded by the EU budget would continue to vary across management modes. 

Portals informing beneficiaries on funding opportunities would continue through multiple entry 
points, with possible adjustments to reflect the architecture of the post-2027 budget. 

5.2.  Description of the policy options 

The impact assessment assesses three combinations of measures i.e. P2+M2+R2, P2+M3+R2 
and P3+M3+R3 against the baseline i.e. P1+M1+R1. This section focuses on the description 
of each individual policy option. 

Programming/mainstreaming of horizontal priorities: 

•  Policy option P2: Activity-specific rules – harmonised provisions across programmes 
on  DNSH  and  gender  equality,  with  calibrated  harmonisation  and  differentiated 
operationalisation per management mode 

This option foresees operationalising the support for key horizontal policy objectives – such as 
gender equality – and implementing the DNSH principle through a harmonised activity-based 
approach.  

Harmonised DNSH criteria would be set, following a single activity-based approach across the 
budget, contrary to the programme-based guidance in place in 2021-2027. Economic activities 
would be subject to harmonised DNSH requirements defined upfront by type of intervention, 
where feasible and appropriate and in accordance with sector-specific rules. Under this single 
system, MS, implementing partners, project promoters and other final recipients would have a 
clear understanding of the applicable DNSH requirements for each intervention type. While 
this option relies upon the adoption of a single DNSH guidance across programmes, it takes 
into  account  the  proportionality  principle  as  well  as  the  specificities  of  programmes 
management modes (direct, indirect, shared), the type of support (e.g. grants, guarantees, loans) 
and the size of the project. The application of the principle would also be adapted to external 
action to take into account differences in the environmental and climate legislation of partner 

18 

 
 
countries.  The  guidance  defining  DNSH  conditions  applying  to  each  group  of  intervention 
fields could also consider a bespoke approach for example in the case of sensitive sectors (such 
as certain defence and security activities). 

In line with the Financial Regulation, programmes and activities will need to be implemented 
taking  into  account  the  principle  of  gender  equality,  where  feasible  and  appropriate  and  in 
accordance with sector-specific rules. Under this policy option, gender equality requirements 
would be  set  at EU budget  level, supported by  a  single  guidance and  provisions tailored  to 
management  modes,  enabling  to  support  compliance  by  MS,  partner  countries  and 
implementing partners with the gender equality requirements of the Financial Regulation. This 
option foresees mainstreaming gender equality into a number of programmes for which gender 
equality  is  assessed  as  specifically  relevant  and  appropriate.  Specific  gender  equality 
provisions would be included into the design of programmes, for example by requiring MS to 
demonstrate  how  their  national  plans  contribute  to  gender  equality  or  by  including  gender 
equality provisions in the evaluation procedure of calls for proposals for programmes under 
direct management. The single guidance would support the mainstreaming of gender equality 
during the programming and implementation phases of the funds in a consistent way.  

In addition, EU budget expenditure promoting gender equality would be monitored through a 
single  methodology  applying  a  system  of  gender  scores  building  on  the  2021-2027 
methodology  as  well  as  the  OECD  methodology. Performance  indicators  would  be 
disaggregated by gender where relevant, in line with the Financial Regulation.  

Under this policy option, the programming and mainstreaming of horizontal priorities across 
programmes  would  be  done  through  harmonised  provisions  at  EU  budget  level,  but  with 
differentiated operationalisation per management mode, tailored for example to: 

-  work programmes, calls, procurements or contracts under direct management; 

-  work programmes and agreements with implementing partners under indirect management; 

-  MS to make a DNSH and gender equality assessment under shared management; 

- 

the  approach  for  implementing  the  DNSH  and  gender  equality  principle  would  also  be 
differentiated between internal and external action.  

•  Policy option P3: Activity-specific rules: fully harmonised provisions on DNSH and 

gender equality  

Similar to policy option P2, this option foresees operationalising the support for key horizontal 
policy objectives – such as gender equality – and implementing the DNSH principle through a 
harmonised  activity-based  approach,  where  feasible  and  appropriate  in  accordance  with  the 
relevant  sector-specific rules, supporting  alignment  with  the new requirements of the recast 
Financial Regulation.  

As under option P2, under this policy option harmonised gender equality requirements would 
be set at EU budget level. 

This option foresees implementing DNSH through a single activity-based approach applying 
to the entire budget, similar to option P2. DNSH requirements would be defined upfront for 
each type of intervention, through a single DNSH guidance including technical criteria tailored 
to the nature of the activity. Unlike option P2, this option foresees a fully harmonised approach 
whereby DNSH technical criteria would apply uniformly to all intervention fields as well as to 

19 

 
 
all management modes (direct, indirect, shared management), all internal and external action, 
and all types of support (grants, guarantees, loans). 

Monitoring of performance: 

•  Policy  option  M2:  Single  methodology  to  track  expenditures  and  a  limited  set  of 
common  mandatory  indicators,  with  flexibility  to  adopt  additional  programme-
specific performance indicators 

This option foresees the development of a single and simplified expenditure monitoring system 
applicable to all MFF programmes. The new system would use a harmonised classification of 
interventions  financed  by  the  EU  budget  –  through  intervention  fields  –  providing  a 
comprehensive,  aggregated  view  of  how  EU  funds  are  allocated. This  system  would  be  the 
basis  to  estimate  expenditures  contributing  to  cross-cutting  policy  objectives  (e.g.  climate 
mitigation and adaptation, biodiversity), by applying percentage-based coefficients (e.g. 0%, 
40%, 100%) to these intervention fields.  

The single list of intervention fields would build on existing intervention fields e.g. in cohesion, 
and EU strategic objectives and priorities. The system would take into account the specificities 
of programmes management modes (direct, indirect, shared), distinctions between internal vs. 
external action, and the type of support (e.g. guarantees, grants, loans). The list of intervention 
fields  would  enable  to  capture  new  financing  areas,  as  the  list  could  be  revised  during  the 
implementation phase of the MFF, as relevant. MS would programme measures in their plans, 
assigning a given intervention field to each measure. 

This  option  foresees  the  adoption  of  a  short  set  of  common  indicators  mandatory  across 
programmes – similar to shared management programmes having common indicators used by 
all  MS  in  2021-2027,  such  as  the  14  common  indicators  of  the  RRF.  This  would  enable 
aggregation at EU budget level for a small number of output and result indicators with a view 
to  monitoring  the  effects  of  the  EU  budget  towards  common  strategic  objectives.  MS, 
implementing partners and the Commission would collect data on such common indicators and 
regularly report their figures for the purpose of corporate reporting.  

In addition to this short list of mandatory common indicators across EU budget programmes, 
this policy option foresees the development of a standardised, yet indicative, set of performance 
indicators at  MFF level  – including  output and result indicators. These indicators would  be 
directly linked to the new set of intervention fields. Such indicators would be available for use 
by  EU  budget  programmes  under  direct,  indirect  and  shared  management,  but  offering 
flexibility  to  adopt  additional  programme-specific  performance  indicators  tailored  to  the 
specific needs of programmes. For example, programme-specific indicators could be adopted 
for the purpose of assessing performance47, for the purpose of evaluation of programmes48,  and 
to monitor implementing partners in the context of shared management49 and in the context of 
financing  not  linked  to  costs50  –  in  cases  where  a  data  gap  is  identified.  In  the  case  of 

47 as per Article 33 of the Financial Regulation 
48 as per Article 34 of the Financial Regulation 
49 as per Article 158 of the Financial Regulation 
50 as per Article 125 of the Financial Regulation 

20 

 
 
 
performance-based forms of funding, additional targets or steps – tailored to the specific nature 
of the concerned measures – could be adopted by Member States and third countries as part of 
their plans. Indicators would be defined based on a common methodology, following the Better 
Regulation Toolbox, including the RACER51 approach and other criteria52. 

This option further relies on the obligation for MS to share with the Commission key data at 
beneficiary level, enabling to exploit data collected by MS to operate each policy, including 
information on e.g. location, gender, enterprise size of the beneficiaries. 

•  Policy  option  M3:  Single  methodology  for  the  EU  budget  to  track  expenditures 
through  intervention  fields,  and  fully  harmonised  list  of  performance  indicators 
across programmes (linked to intervention fields) 

Similar to option M2, this option foresees a single expenditure monitoring system applicable 
to all programmes, relying upon a harmonised list of intervention fields covering all activities 
financed  by  the  MFF. The  system  would  enable  to  estimate  the  EU  budget  contribution  to 
priorities, such as climate, by applying percentage-based coefficients (e.g. 0%, 40%, 100%) to 
these intervention fields. For example, in the case of programmes under shared management, 
MS  would  programme  measures  in  their  plans,  assigning  a  given  intervention  field  to  each 
measure or sub-measure in the plan. 

This  option  foresees  the  development  of  a  standardised  set  of  –  mainly  output  and  result  – 
performance indicators at EU budget level. This approach would reduce the overall number of 
performance indicators, and ensure alignment with the new requirements of the recast Financial 
Regulation  requiring  to  aggregate  performance  indicators  across  programmes.  Relevant 
performance indicators would be attributed to each intervention field. As under option M2, a 
common  methodology  would  be  defined  for  each  indicator  based  on  the  Better  Regulation 
Toolbox guidance on the development of indicators. 

Similar  to  option  M2,  in  the  case  of  performance-based  forms  of  funding,  MS,  partner 
countries, and implementing partners would define performance steps or milestones using the 
pre-defined output indicators linked to relevant intervention fields as part of the single list. In 
a financing not linked to costs scheme, fulfilling such steps or milestones – through reporting 
against  relevant  output  and  result  indicators  –  would  trigger  payments,  not  linked  to 
expenditure of MS. In exceptional cases where a measure would deliver an output not covered 
by  the  single  list,  additional  performance  steps  or  milestones  –  tailored  to  the  measure 
specificities – could be adopted. The specificities of financial instruments (repayable support) 

51 Relevant, Acceptable, Credible, Easy and Robust 
52 E.g. attributable (changes in the indicator should be attributable to the initiative; data should be easily available 
and of a good quality, ideally at national or regional level), timeliness (indicators should capture the effects due 
to the initiative within a reasonable length of time, taking into account the frequency of measuring indicators), 
baseline and target value (the indicator should be based on a clear baseline and assumptions to derive the target 
value from the baseline), metadata (indicators definition should include a unit of measurement, the source of the 
data,  entities  in  charge  of  data  collection  and  reporting,  frequency  of  data  collection/reporting,  and  any  other 
information relevant to facilitate data sharing, use and aggregation) 

21 

 
 
 
would  be  taken  into  account.  The  set  of  common  intervention  fields  would  also  enable  the 
Commission to report its external support to the OECD DAC53. 

Unlike option M2, this option foresees a fully harmonised approach whereby a single common 
set of indicators would apply to all programmes. This would result in a reduction of the overall 
number  of  performance  indicators  across  the  EU  budget,  ensuring  consistency  across 
programmes. Output and result indicators would be specific to each policy area and  related 
intervention fields, ensuring effective monitoring of the outcomes of funding for each type of 
activity while allowing aggregation of data across EU funds. Different from option M2, the 
single list of performance indicators would not merely be indicative but would constitute the 
indicators for monitoring the performance of EU budget programmes, as well as the indicators 
used as performance steps or targets in performance-based forms of funding used for e.g. MS 
plans or under external action. Member States would be required to report on at least one output 
indicator (used as target) and at least one result indicator for each measure of their plan. The 
single list of indicators would also serve as indicators used for the purpose of evaluations of 
programmes. This option does not foresee any short set of common indicators against which 
reporting would be mandatory across programmes, since all funds would use the single set of 
indicators. 

Because the common list will include ca. 500 intervention fields reflecting the objectives of 
programmes, and because the list will include indicators attached to each intervention field, 
there will be several indicators available to monitor the achievement of programme objectives 
and therefore enable robust evaluations. 

This  option  relies  on  the  obligation  for  MS  to  share  with  the  Commission  key  data  at 
beneficiary level, enabling to exploit data collected by MS to operate each policy, including 
information  on  e.g.  location,  gender,  enterprise  size  of  the  beneficiaries.  The  Commission 
would  calculate  output  and  result  indicators  based  on  these  data,  where  feasible,  further 
reducing administrative burden on MS, and optimizing the monitoring of the performance of 
EU budget programmes. This option also entails increased use of Member States administrative 
registers as a way of collecting further data useful for performance monitoring. It also foresees 
modernising data collection processes and strengthening the use of artificial intelligence (AI) 
to  achieve  further  efficiency  gains  as  well  as  modernizing  data  sharing  and  improving 
interoperability of databases.  This  is  likely  to help  modernise data collection, help  Member 
States to allocate projects to intervention fields, and contribute to the cleaning, processing, and 
analysis  of  performance  data,  while  also  enhancing  data  quality  and  reliability  control 
mechanisms.  AI  may  also  help  in  the  future  in  terms  of  inter-operability  of  databases,  in  a 
context  where  performance  information  remains  scattered  across  several  Commission 
databases, which limits aggregation of indicators across programmes. 

AI is evolving at fast pace hence it remains difficult to anticipate the exact role that it will play 
in operationalizing the performance framework of the post-2027 budget. Yet it is expected to 
help  modernise  data  collection,  such  as  by  helping  Member  States  to  allocate  projects  to 
intervention fields, and to contribute to the cleaning, processing, and analysis of performance 

53 Development Assistance Committee of the Organisation for Economic Co-operation and Development 

22 

 
 
 
data, while also enhancing data quality and reliability control mechanisms. AI may also help 
in  the  future  in  terms  of  inter-operability  of  databases,  in  a  context  where  performance 
information remains scattered across several Commission databases, which limits aggregation 
of indicators across programmes. Lastly, future AI tools could also help make the reporting of 
performance information more interactive for the end users. 

Figure: Possible architecture of intervention fields, tracking coefficients, and indicators 

23 

 
 
 
 
   
 
 
Figure: Example of a measure in a MS plan, and subsequent aggregation with data from other MS, and 
data from Competitiveness and external action funds 

Reporting of performance: 

•  Policy  option  R2:  Single  performance  report,  single  portal  on  performance 
information and funding opportunities, with differentiated operationalisation of the 
single portal per management mode or sector 

This option foresees harmonised requirements on performance reporting. Under this option, 
there  would  no  longer  be  programme-specific  reporting  requirements,  consolidating  all  EU 
budget performance information into the AMPR, i.e. merged with the Programme Statements 
accompanying the Draft Budget prepared by the Commission.  

Performance  information  on  the  EU  budget  would  be  publicly  accessible  through  a  single 
online  portal presenting  a dashboard of  what  the EU budget  achieves. This  platform would 
provide comprehensive insights, including on budget implementation, expenditure monitoring 
by intervention field and horizontal priorities, and performance indicators. The portal could be 
modelled after the existing Open Data Platform for cohesion, ensuring transparency and ease 
of access for citizens  and budgetary authorities.  This  policy option  foresees  a differentiated 
operationalisation  per  management  mode  or  programme,  whereby  the  single  portal  would 
enable  to  display  specific  data  regarding  dedicated  areas  and  sectors,  and  performance 
information presenting specific programmes achievements. 

The recast Financial Regulation reinforces transparency requirements across the EU budget as 
from  the  next  MFF,  including  by  requiring  a  centralised  website  with  information  on 
beneficiaries and operations. This option foresees harmonising rules for transparency across 
programmes regarding collecting, storing and publishing data on beneficiaries and operations 
supported by the MFF, including publication of data through the single portal.  

Existing portals providing information on available funding opportunities would be replaced 
by the single portal centralising all information under the EU budget, improving transparency 
and  access  to  information,  in  particular  for  project  promoters  and  potential  beneficiaries. 
Building upon the approach followed with the Funding & Tenders and the STEP portals, this 
centralised system would address the shortcomings identified in the current system, such as the 
complexity  of  navigating  multiple  portals,  lack  of  interoperability,  and  unequal  access  to 

24 

 
 
 
funding information, particularly for SMEs and small organisations. The single portal would 
serve as a single entry point enabling applicants to directly submit their financing applications 
through the portal. AI advisory support could provide advice on appropriate funding source 
identification 
foresees  a  differentiated 
operationalisation  per  management  mode  or  programme,  whereby  the  single  portal  could 
display programme-specific information regarding available funding opportunities. The portal 
would also include links redirecting users to more specific sources such as portals hosted e.g. 
by MS and regions. 

for  potential  beneficiaries.  This  option 

•  Policy  option  R3:  Single  performance  report,  single  portal  on  performance 
information  and  funding  opportunities,  with  fully  harmonised  operationalisation 
across management modes 

Similar to policy option R2, this option foresees a single performance report, consolidating all 
EU budget performance information into the AMPR, merged with the Programme Statements 
accompanying the Draft Budget. 

Performance  information  on  the  EU  budget  would  be  publicly  accessible  through  a  single 
online  portal.  Data  on  beneficiaries  and  operations  supported  by  the  EU  budget  would  be 
managed and published in a harmonised way across all management modes through the single 
portal. Unlike policy option R2, the single portal would not include sections regarding specific 
policy areas or sectors. 

Similar to option R2, under this option a single portal centralising all information on available 
funding opportunities would replace existing portals. Unlike option R2, this option foresees a 
fully harmonised approach whereby the single portal would not display programme-specific 
information  on  funding  opportunities.  The  portal  would  also  integrate  and  replace  portals 
hosted e.g. by MS and regions. 

5.3. Options discarded at an early stage 

The impact assessment focuses on assessing three combinations of measures i.e. P2+M2+R2, 
P2+M3+R2  and  P3+M3+R3  against  the  baseline  i.e.  P1+M1+R1.  Other  combinations  of 
measures  are  discarded  in  the  impact  assessment,  such  as  combining  fully  harmonised 
programming  provisions  with  a 
relying  upon  differentiated 
operationalisation  of  the  single  portal  per  management  mode  or  sector.  Combining  a  fully 
harmonised  reporting  approach  with  a  monitoring  system  differentiated  across  programmes 
would also not be a realistic option, given that reporting performance information across the 
EU budget in a fully harmonised way would not be feasible if monitoring approaches – and 
resulting performance indicators – are partly heterogeneous across programmes. 

reporting  approach 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section assesses the economic, social and environmental impacts of policy options P2, 
M2, R2 and P3, M3, R3 against the baseline i.e. policy options P1, M1, R1. Annex 3 further 
describes the practical implications of the initiative – in particular for EU budget beneficiaries, 
MS, partner countries and implementing partners as well as EU institutions – as well as the 
costs and benefits of the initiative, and expected impacts in terms of contributions to the UN 
SDGs. Annexes 5 and 10 provide further details in relation to the impacts of the initiative on 
competitiveness  and  SMEs  respectively.  Annex  9  includes  a  qualitative  analysis  of  policy 
options P1, M1 and R1 as well as a quantitative analysis of the impacts of all policy options. 

25 

 
 
6.1.          Economic impacts 

a.  Impacts of options on programming/mainstreaming of horizontal priorities: 

Policy option 
P2: Activity-
specific rules: 
harmonised 
provisions across 
programmes on 
DNSH and gender 
equality, with 
calibrated 
harmonisation 
and differentiated 
operationalisation 
per management 
mode  

P3: Activity-
specific rules: 
fully harmonised 
provisions on 
DNSH and gender 
equality 

Economic impacts  
A single DNSH guidance would enable MS, partner countries and beneficiaries – including 
businesses – to achieve cost reductions. Economic benefits would be achieved by reducing 
the  resources  currently  required  to  apply  multiple  DNSH  guidances  and  sometimes 
contradictory requirements, enabling higher predictability and facilitating access to EU funds. 
Option  P2  follows  a  calibrated  and  proportionate  approach  –  whereby  DNSH  provisions 
would be implemented in a differentiated manner depending on the management mode, and 
the type of action (internal vs. external) – which is expected to reduce administrative burden 
and  facilitate  compliance.  A  single  DNSH  guidance  would  require  one-off  costs  for  the 
Commission to develop a set of technical criteria and provide technical support to MS on the 
new  DNSH  approach,  but  it  would  reduce  resources  by  the  Commission  to  develop  and 
implement  multiple  DNSH  guidances, reducing the  need  for  capacity  building to  MS  and 
beneficiaries, as the technical criteria would be the same across programmes. Exempting a 
list  of  intervention  fields  from  DNSH  checks  in  the  cased  of  defence  and  security  would 
reduce the resources needed by the Commission to develop technical criteria across the list 
of intervention fields, since part of the list would not require developing such criteria.  
This option also foresees a harmonised approach towards gender equality, which is expected 
to achieve efficiency gains compared to 2021-2027 where beneficiaries must navigate and 
comply with heterogeneous requirements, e.g. in the case of activities eligible under different 
EU funds. It would also have positive economic impacts due to the role of gender equality in 
enhancing competitiveness and inclusivity, in the context of the Union of Equality. 
Competitiveness:  Option  P2  would  support  the  competitive  growth  of  companies  and 
economic sectors supported by EU funds and support international competitiveness vis-à-vis 
third  countries.  Harmonising  DNSH  and  gender  equality  requirements  would  facilitate 
regulatory compliance by businesses and enhance market responsiveness. This would reduce 
the  complexity  of  compliance,  enabling  beneficiaries  –  e.g.  businesses  –  to  devote  fewer 
resources to navigating regulatory landscapes, enabling time and cost savings.  
SMEs: Implementing a harmonised approach to DNSH and gender equality across the EU 
budget is expected to bring benefits for SMEs, which are particularly challenged by complex 
regulations and administrative burdens. The calibrated approach foreseen under option P2 is 
expected to help SMEs by reducing the need to comply with varying requirements, ultimately 
facilitating  their  access to  EU  funds,  though  this may  also reduce  incentives  for  SMEs  to 
innovate. 
Similar  to  P2,  this  option  would  enable  cost  reductions  by  MS,  partner  countries  and 
beneficiaries – including businesses – linked to the single DNSH guidance.  
Unlike  policy  option  P2,  this  option  foresees  full  harmonisation  of  DNSH  requirements, 
which would bring full clarity on DNSH implementation, but would generate administrative 
burden  and  complicate  compliance  by  MS,  partner  countries  and  beneficiaries,  achieving 
reduced  economic  benefits  compared  to  option  P2,  including  because  of  a  lack  of 
differentiated  implementation  per  management  mode.  Systematic  DNSH  checks  to  all 
interventions  financed  by  the  EU  budget  would  increase  the  resources  needed  by  the 
Commission to develop technical criteria across the whole list of intervention fields, without 
exceptions.  
This  policy  option  also  foresees  a  harmonised  approach  towards  gender  equality 
requirements. This would enable MS and beneficiaries to achieve efficiency gains compared 
to  2021-2027  where  beneficiaries  must  navigate  and  comply  with  heterogeneous 
requirements, in particular if eligible under different EU funds. 

26 

 
 
 
Competitiveness: A fully harmonised DNSH and gender equality approach would simplify 
implementation by MS, partner countries and beneficiaries – including businesses – which 
would  facilitate  regulatory  compliance.  Full  harmonisation  of  DNSH  requirements  is 
nonetheless likely to complicate implementation by beneficiaries, since DNSH requirements 
would apply to all intervention fields supported by EU funds, to all management modes and 
to all types of action (internal and external) in a similar way, which is likely to create barriers 
to  accessing  EU  funds.  A  fully  harmonised  approach  may  therefore  undermine  the 
competitive growth of companies and economic sectors supported by EU funds. 
SMEs: Similar to policy option P2, the harmonised and simplified approach to DNSH and 
gender  equality  mainstreaming  across  EU  funds  is  expected  to  bring  several  benefits  for 
SMEs, which are particularly challenged by complex regulations and administrative burdens. 
A  fully  harmonised  approach  to  DNSH  is nonetheless  likely  to make  it  more difficult  for 
SMEs to access EU funds, because all projects would be subject to DNSH checks, resulting 
in maintaining certain barriers to entry and reducing success rates in funding applications, 
reducing opportunities for SMEs to mobilise additional capital.  

b.  Impacts of options on monitoring of performance: 

Policy option 
M2: Single 
methodology to 
track expenditures 
through 
intervention 
fields, and a 
limited set of 
common 
mandatory 
indicators, with 
flexibility to 
adopt additional 
programme-
specific 
performance 
indicators 

M3: Single 
methodology for 
the EU budget to 
track expenditures 
through 
intervention 
fields, and fully 

Economic impacts  
This option would enable to achieve cost reductions linked to a harmonised classification of 
activities financed by the EU budget – so as to enable simple tracking of expenditures through 
intervention fields – and a simplified set of performance indicators at MFF level.  
This option also foresees the possibility to adopt additional programme-specific performance 
indicators, which would result in the adoption of further indicators. Compared to option M1, 
this option is likely to reduce administrative burden but only to a certain extent, as MS, partner 
countries and beneficiaries as well as the Commission and EU agencies would also deal with 
additional indicators per programme, though the new architecture of the post-2027 MFF and 
the  reduction  of  the  number  of  EU  budget  programmes  is  expected  to  slightly  reduce 
monitoring  burdens.  The  adoption  of  programme-specific  indicators  may  enable  to  adopt 
more  specific  indicators  in  view  of  evaluations,  ultimately  enabling  more  effective  policy 
steering, and higher benefits to the economic sectors supported by the EU budget. At the same 
time, this option would limit indicators aggregation across programmes, which would reduce 
the ability to steer EU budget support to the most strategic sectors for the EU economy. The 
adoption  of  a  limited  but  mandatory  set  of  common  indicators  is  expected  to  generate 
administrative burden as MS, third countries, implementing partners, beneficiaries and the 
Commission would have to report against this additional set of common indicators. 
Competitiveness: This option could enable to track contributions to new EU priorities such 
as competitiveness, but programme-specific indicators would reduce the ability to aggregate 
competitiveness-relevant indicators across funds. Programme-specific indicators – translated 
in contracts or grant agreements – is overall expected to generate administrative burdens and 
hinder the competitiveness of companies and economic sectors supported by EU funds.  
SMEs:  SMEs,  often  limited  by  resources  and  staff,  are  expected  to  benefit  from  reduced 
complexity  in  indicators  reporting  requirements,  but  the  adoption  of  programme-specific 
indicators  may  maintain  administrative  burden  on  SMEs,  maintaining  complex  indicators 
monitoring and reducing access to EU funds.  
This option would achieve cost reductions due to the harmonised classification of activities 
financed by the MFF and a simplified set of performance indicators at MFF level. While the 
system would entail entry costs, MS, third countries and the Commission would in the longer 
run reduce resources allocated to dealing with expenditure tracking and indicators monitoring. 
Reducing  the  number  of  performance  indicators  would  enable  beneficiaries  to  face  less 
reporting burden and reduce the costs associated with project monitoring. In cases where a 
measure addresses a dimension not covered by the single list, this policy option foresees the 

27 

 
 
 
harmonised list of 
performance 
indicators across 
programmes 
(linked to 
intervention 
fields) 

possibility for MS to adopt e.g. milestones and targets – tailored to their specificities – as part 
of  their  national  plans,  which  would  achieve  economic  benefits  by  enabling  to  tailor 
milestones and targets to MS specific investment and reform needs in key economic sectors. 
Competitiveness: This option could enable to track contributions to new EU priorities such 
as competitiveness. A simplified approach to indicators in contracts or grant agreements is 
expected  to  reduce  administrative  burden  and  support  the  competitiveness  of  economic 
sectors supported by EU funds. By allowing companies to reduce compliance and monitoring 
costs, this option would enhance companies’ efficiency and support the competitiveness of 
EU businesses, including in terms of international competitiveness vis-à-vis third countries. 
SMEs: This option would achieve reduced complexity in monitoring and reporting by SMEs. 
Access  to  EU  funds  would  increase  by  lowering  entry  barriers  and  facilitating  reporting 
processes, leading to faster approvals and payments to participating SMEs. 

c.  Impacts of options on reporting of performance: 

Policy option 
R2: Single 
performance 
report, single 
portal on 
performance 
information and 
funding 
opportunities, 
with 
differentiated 
operationalisation 
of the single 
portal per 
management 
mode or sector 

R3: Single 
performance 
report, single 
portal on 
performance 
information and 
funding 
opportunities, 

Economic impacts  
This  option  would  achieve  cost  reductions  linked  to  harmonised  performance  reporting, 
consolidating  all  information  into  the  AMPR.  The  Commission  would  achieve  efficiency 
gains and reduce the resources  currently allocated to preparing multiple reports. Other EU 
institutions  – e.g. European Parliament  – budgetary authorities and interested stakeholders 
would reduce the costs currently allocated to navigating and processing multiple reports on 
the  performance  of  the  EU  budget.  The  new  system  would  promote  transparency  of 
performance information and efficient data utilisation for policy decisions. 
A single online portal displaying EU budget performance information would also enable MS 
and beneficiaries to reduce the costs currently allocated to navigating and processing multiple 
dashboards.  A  single  entry  point  would  enable  MS,  partner  countries  and  beneficiaries  to 
reduce  the  costs  currently  allocated  to  navigating  multiple  portals  on  available  funding 
opportunities, facilitating access to EU funds by beneficiaries in key economic sectors. The 
Commission would also reduce the costs currently allocated to the management of multiple 
dashboards and portals, though the development of such a single portal would require one-
off costs for the Commission to develop the new system. 
The single portal would enable to display specific data regarding specific economic sectors, 
which may deliver economic benefits by increasing transparency and access to information 
by stakeholders in relevant economic sectors. The simple inclusion of links to MS and regions 
portals  is  expected  to  have  limited  resources  implications  for  the  Commission,  while 
facilitating  access  to  information  on  funding  opportunities  available  to  beneficiaries  in 
relevant economic sectors, potentially achieving economic benefits. 
Competitiveness:  A  single  portal  on  information  on  EU  budget  performance  and  funding 
opportunities could streamline processes and simplify navigation, ultimately reducing costs 
and enhancing the competitiveness of businesses supported by the MFF.  
SMEs: SMEs, which operate with limited staff and resources, are disproportionately affected 
by the complexity of existing EU portals displaying information on funding opportunities. 
With a single portal, SMEs could quickly access information, helping them to become more 
responsive to new support opportunities and secure funding under EU funds.  
Similar  to  option  R2,  this  option  would  achieve  cost  reductions  linked  to  harmonised 
requirements on performance reporting. The Commission would achieve efficiency gains and 
reduce the resources allocated to preparing performance reports. 
A  single  online  portal  displaying  performance  information  would  enable  MS,  other  EU 
institutions (e.g. Parliament), partner countries and beneficiaries to reduce the costs currently 
allocated to navigating multiple dashboards. This option would also enable to reduce costs 
thanks to the single portal providing information on funding opportunities, including for the 
Commission, though the development of such a portal would require entry costs. 

28 

 
 
 
with fully 
harmonised 
operationalisation 
across 
management 
modes 

Unlike option R2, the single  portal would not display specific data regarding e.g. specific 
economic  sectors,  which  is  expected  to  deliver  reduced  economic  benefits  by  reducing 
transparency and access to information by stakeholders active in relevant economic sectors. 
The single portal would also integrate and replace specific sources such as portals hosted e.g. 
by MS and regions, which would entail higher entry costs than option R2 in particular for the 
Commission. Such a system would nonetheless significantly increase access to information 
on funding opportunities available to beneficiaries in relevant economic sectors. 
Competitiveness: Similar to option R2, a single portal on EU budget performance and funding 
opportunities  would  provide  a  single  entry  point,  reduce  costs,  and  enhance  the 
competitiveness of businesses supported by EU funds. A portal not displaying specific data 
on e.g. key economic sectors may nonetheless reduce transparency and access to information 
by stakeholders in economic sectors, which may negatively affect competitiveness.  
SMEs:  Similar  to  option  R2,  a  single  portal  is  likely  to  help  SMEs  to  quickly  access 
information, enabling faster decision-making and efficiency gains, helping them to become 
more responsive to new support opportunities under EU budget programmes.  

6.2.           Social impacts 

a. Impacts of options on programming/mainstreaming of horizontal priorities: 

Policy option 
P2: Activity-
specific rules: 
harmonised 
provisions across 
programmes on 
DNSH and gender 
equality, with 
calibrated 
harmonisation 
and differentiated 
operationalisation 
per management 
mode 
P3: Activity-
specific rules: 
fully harmonised 
provisions on 
DNSH and gender 
equality 

Social impacts  
Under this option, gender equality requirements would be systematically embedded in the EU 
budget and in the design of relevant programmes. This would enhance the overall efficiency 
and inclusivity of EU programmes, fostering equitable outcomes for all citizens both in EU 
MS  and  partner  countries.  This  approach  aligns  with  the  EU's  broader  commitment  to 
inclusivity and equity, ensuring that gender consideration are integrated consistently at all 
levels of planning, implementation, and evaluation. 
Under  this  option,  the  programming  and  mainstreaming  of  gender  equality  would  be 
differentiated per management mode, which is expected to have positive social impacts by 
enabling an effective mainstreaming approach across EU budget programmes. 

Similar to option P2, this option foresees embedding gender equality requirements in the EU 
budget and in the design of relevant programmes. Such an approach is expected to achieve 
social outcomes by fostering the inclusivity of EU programmes. 
Unlike  option  P2,  this  option  foresees  a  fully  harmonised  approach  to  gender  equality 
mainstreaming without differentiation per management mode. This is expected to have lower 
positive social impacts as it may result in less effective mainstreaming of gender. 

 b. Impacts of options on monitoring of performance: 

Policy option 
M2: Single 
methodology to 
track expenditures 
and a limited set 
of common 
mandatory 
indicators, with 

Social impacts  
Under this option, EU budget expenditure promoting gender equality would be monitored 
through a single methodology applying a system of 'gender scores' building on the 2021-2027 
methodology  as  well  as  the  OECD  methodology.  Performance  indicators  would  also  be 
disaggregated  by  gender  where  relevant,  in  line  with  the  requirements  of  the  Financial 
Regulation. Gender disaggregated data is likely to help identify areas where gender disparities 
exist under sectors or areas supported by EU funds, which may help addressing the unique 

29 

 
 
  
flexibility to 
adopt additional 
programme-
specific 
performance 
indicators 

M3: Single 
methodology for 
the EU budget to 
track expenditures 
through 
intervention 
fields, and fully 
harmonised list of 
performance 
indicators across 
programmes 
(linked to 
intervention 
fields) 

needs  and  challenges  faced  by  gender  groups.  This  option  would  therefore  achieve  social 
outcomes by enabling to consistently assess the contribution of EU funds to gender equality. 
This option foresees the possibility to adopt additional programme-specific indicators, which 
may  deliver  benefits  in  terms  of  adopting  more  specific  indicators  regarding  fundamental 
rights and social aspects. This option is nonetheless likely to reduce indicators aggregation 
across programmes, including social indicators, which would reduce the ability to steer EU 
budget support to fundamental rights and social priorities. 
Similar to option M2, expenditure promoting gender equality would be monitored through a 
single  methodology  applying  a  system  of  'gender  scores'  across  programmes.  The  fully 
harmonised  list  of  performance  indicators  would  enable  to  aggregate  indicators  across 
programmes,  including  social  indicators,  enabling  to  enhance  the  policy  steering  of  EU 
budget support to fundamental rights and social priorities. Performance indicators would be 
disaggregated  by  gender  where  relevant,  which  would  achieve  social  outcomes  by  more 
consistently assessing the contribution of programmes to gender. 
This option foresees a differentiated operationalisation of indicators per management mode, 
allowing to  adopt  e.g. milestones  and  targets  tailored  to  MS  specific  needs  in their  plans. 
Similar to option M2, this option would deliver higher social outcomes than option M1, e.g. 
if MS were to adopt  social-related milestones and targets addressing specific  fundamental 
rights and social challenges at national level. 

c. Impacts of options on reporting of performance: 

Policy option 
R2: Single 
performance 
report, single 
portal on 
performance 
information and 
funding 
opportunities, 
with 
differentiated 
operationalisation 
of the single 
portal per 
management 
mode or sector 
R3: Single 
performance 
report, single 
portal on 
performance 
information and 
funding 
opportunities, 
with fully 
harmonised 
operationalisation 
across 

Social impacts  
Consolidated reporting requirements – through a single performance report – would improve 
transparency  of  information,  including  regarding  the  EU  budget  contribution  to  social 
priorities  such  as  gender  equality.  This  is  likely  to  achieve  positive  social  outcomes  as  it 
would increase access to information for budgetary authorities and MS on how the EU budget 
contributes to gender equality, which may help policymakers to adopt more inclusive and 
equitable policies, ensuring that the diverse needs of all gender groups are considered in the 
management of EU budget programmes. 
This  option  would  facilitate  access  to  information  on  EU  budget  funding  opportunities 
through  a  single  portal.  Access  by  beneficiaries  looking  for  support  in  the  field  of  social 
objectives and equality would be facilitated, which would have a positive social impact. 
This option foresees a differentiated operationalisation per management mode or programme, 
whereby the single portal would enable to display specific data regarding dedicated areas and 
sectors. This may enable to provide the opportunity for displaying information on social- and 
equality-related aspects, which would enable to better integrate social considerations back 
into the management of EU budget programmes. 
Similar to option R2, this option foresees a single performance report which would enable 
improved transparency of information regarding the contribution of the EU budget to gender 
equality, which is likely to achieve positive social outcomes. 
This option would also facilitate access to information on funding opportunities, including 
for beneficiaries in the field of EU social objectives and equality. 
Unlike  option  R2,  this  option  foresees  a  fully  harmonised  operationalisation  across 
management  modes,  whereby  the  single  portal  would  not  display  specific  data  regarding 
dedicated areas and sectors. This may limit possibilities to display information on social- and 
equality-related aspects, which would reduce opportunities to integrate social considerations 
back into the management of EU budget programmes. 

30 

 
 
  
management 
modes 

6.3.           Environmental impacts 

a. Impacts of options on programming/mainstreaming of horizontal priorities: 

Policy option 
P2: Activity-
specific rules: 
harmonised 
provisions across 
programmes on 
DNSH and gender 
equality, with 
calibrated 
harmonisation 
and differentiated 
operationalisation 
per management 
mode  
P3: Activity-
specific rules: 
fully harmonised 
provisions on 
DNSH and gender 
equality   

Environmental impacts  
Under  this  option,  the  harmonised  approach  to  DNSH  would  reduce  the  potentially 
detrimental environmental impact of programmes. This would align projects supported by the 
EU  budget  with  EU  environmental  objectives,  such  as  the  European  Green  Deal,  the  EU 
Climate  Law  or  the  Nature  Restoration  Regulation.  By  applying  the  same  criteria  across 
programmes, all funded projects would adhere to environmental safeguards, reducing the risk 
of harmful practices. Harmonised DNSH criteria would make it easier for beneficiaries to 
understand and comply with environmental requirements, integrating environmental aspects 
into project design. The differentiated approach by management mode and by type of action 
(internal vs. external) is also likely to enable more effective implementation  of the DNSH 
principle. The exemptions from DNSH checks – for defence and security – may nonetheless 
result in not applying DNSH to projects with potentially environmentally harmful effects. 

Similar to option P2, a harmonised approach to DNSH would reduce the risks of detrimental 
environmental  impact  of  EU  funds.  Simplified  DNSH  criteria  would  make  it  easy  for 
beneficiaries to understand and comply with environmental requirements. Unlike option P2, 
DNSH technical criteria would apply uniformly to all intervention fields, there would be no 
differentiation by management mode and by type of action (internal vs. external), which is 
likely to lead to less effective implementation of the DNSH principle than option P2. The 
absence of exemptions from DNSH checks – for defence and security – would nonetheless 
result in systematic DNSH application including to projects with potentially environmentally 
harmful effects, which is likely to achieve higher environmental outcomes. 

 b. Impacts of options on monitoring of performance: 

Policy option 
M2: Single 
methodology to track 
expenditures and a 
limited set of common 
mandatory indicators, 
with flexibility to 
adopt additional 
programme-specific 
performance indicators 
M3: Single 
methodology for the 
EU budget to track 
expenditures through 
intervention fields, and 
fully harmonised list 
of performance 
indicators across 
programmes 

Environmental impacts  
Under this  option,  EU  budget expenditure  contributing  to  environmental  objectives  – 
such as climate mitigation, adaptation, and biodiversity – would be monitored through a 
common  methodology.  This  option  would  achieve  environmental  outcomes  by 
consistently assessing the contribution of programmes to environmental priorities. 
This option foresees the possibility to adopt additional programme-specific indicators, 
including regarding environmental aspects. This option is nonetheless likely to reduce 
indicators aggregation across programmes, including environmental indicators, reducing 
the ability to steer EU budget support to environmental priorities. 

Similar  to  option  M2,  this  option  would  enable  to  efficiently  monitor  EU  budget 
expenditure  contributing  to  environmental  objectives  such  as  climate  mitigation, 
adaptation, and biodiversity, enabling to achieve positive environmental impacts. The 
list  of  indicators  fully  harmonised  across  funds  would  enable  to  aggregate  indicators 
across programmes, including environmental indicators, and enhance the policy steering 
of  EU  budget  support  to  environmental  priorities.  The  adoption  e.g.  milestones  and 
targets  tailored  to  MS  specific  needs  in  their  plans  would  deliver  environmental 
outcomes, in particular in case MS were to adopt green milestones and targets addressing 
specific climate and environment challenges at national level. 

31 

 
 
 
c. Impacts of options on reporting of performance: 

Policy option 
R2: Single 
performance report, 
single portal on 
performance 
information and 
funding opportunities, 
with differentiated 
operationalisation of 
the single portal per 
management mode or 
sector 
R3: Single 
performance report, 
single portal on 
performance 
information and 
funding opportunities, 
with fully harmonised 
operationalisation 
across management 
modes 

Environmental impacts  
This  option  would  enable  to  improve  transparency  of  information  regarding  the  EU 
budget  contribution  to  climate  mitigation,  adaptation,  and  biodiversity.  Access  to 
information  on  EU  budget  funding  opportunities  would  be  facilitated,  including  for 
beneficiaries looking for support in the field of environmental objectives. 
This  option  foresees  a  differentiated  operationalisation  per  management  mode  or 
programme, whereby the single portal would enable to display specific data regarding 
dedicated areas and sectors. This may enable to display more detailed information on 
climate and environmental aspects, which would enable to better integrate environmental 
considerations and challenges back into the management of EU budget programmes. 

Similar to option R2, this option would enable to improve transparency of information 
regarding the EU budget contribution to climate mitigation, adaptation, and biodiversity, 
and to facilitate access to information on EU budget funding opportunities, including for 
beneficiaries looking for support in the field of environmental objectives. 
Unlike  option  R2,  this  option  foresees  a  fully  harmonised  operationalisation  across 
management modes, whereby the single portal would not display specific data regarding 
dedicated  areas  and  sectors.  This  may  limit  possibilities  to  display  information  on 
climate and environment, which would reduce opportunities to integrate environmental 
considerations  into the management of programmes, compared to option R2. 

7.  HOW DO THE OPTIONS COMPARE? 

This  section  compares  the  three  possible  combinations  of  policy  options  i.e.  P2+M2+R2, 
P2+M3+R2  and  P3+M3+R3  –  against  the  baseline  i.e.  P1+M1+R1  –  by  assessing  the 
effectiveness, the efficiency and the coherence of each combination of policy options. Sections 
7.1  to  7.3  compare  individual  policy  options,  enabling  to  draw  a  summary  comparison  of 
possible combinations under section 7.4. 

The assessment is based on a system of rating: 

=  (neutral):  the  policy  option  has  no  significant  contribution  to  effectiveness,  efficiency  or 
coherence. 

+  (low  positive):  the  policy  option  contributes  modestly  to  efficiency,  effectiveness  or 
coherence. 

++  (moderate  positive):  the  policy  option  significantly  supports  efficiency,  effectiveness  or 
coherence. 

+++ (high positive): the policy option strongly advances efficiency, effectiveness or coherence. 

7.1. 

Effectiveness 

The effectiveness of the policy options described under section 5 is examined against the policy 
objectives identified in section 4, building upon the findings of section 6, and based on the 
operational  objectives  presented  in  the  table  below.  As  specific  objective  2  relates  to  the 
reduction of administrative burden, this aspect is treated in a general way under section 7.1 
(Effectiveness) and assessed in more details under section 7.2 (Efficiency). 

32 

 
 
 
Specific objectives 

Operational objectives 

SO1: Increased capacity to address current 
and  future  policy  priorities,  and  specific 
MS and sectors needs 

SO2:  Reduction  of  administrative  burden 
and costs affecting EU budget beneficiaries, 
implementing 
MS,  partner  countries, 
partners  and  EU  institutions  by  at  least 
25% 
SO3:  Enhanced  capacity  to  measure  EU 
budget  impact,  and  inform  policies  and 
programmes management 

-  Increase  capacity  to  mainstream  gender  equality  across  EU 

budget programmes  

-  Increase  capacity  to  implement  the  Do  No  Significant  Harm 

principle across EU budget programmes 

-  Reduce  costs  linked  to  administrative  and  reporting  burden 
affecting  beneficiaries,  MS,  implementing  partners  and  EU 
institutions by at least 25%54 

-  Increase  capacity  to  aggregate  performance  data  across  EU 

budget programmes  

-  Increase availability of expenditure tracking data and indicators 
fit for measuring the performance of EU budget programmes  
-  Increase  availability  of  performance  information  to  inform 

policies and EU budget programmes management 

SO4: Increased transparency and access to 
information  for  MS  budgetary  authorities 
and EU budget beneficiaries 

-  Improve 

transparency  of  performance 

information  by 

harmonising and centralising Commission reports  

-  Improve access to information by harmonising and centralising 

dashboards displaying performance information  

-  Improve access to information by harmonising and centralising 

portals displaying information on funding opportunities 

•  Programming/mainstreaming:  

The following table provides the assessment of the effectiveness of policy options P1, P2 and 
P3 against the operational objectives associated to specific objectives 1 and 255: 

Specific 
objective 
1 
2 

Policy option P1 

Policy option P2 

Policy option P3 

(=) 
(=) 

(+++) 
(+++) 

(++) 
(+) 

SO1: Both options P2 and P3 are expected to increase the EU budget capacity to mainstream 
gender  equality  and  implement  the  DNSH  principle  due  to  their  activity-specific  approach 
relying upon harmonised provisions across programmes. Option P2 is expected to score higher 
due  to  its  differentiated  operationalisation  per  management  mode,  enabling  to  tailor  gender 
equality  mainstreaming  and  DNSH  implementation  to  programmes  management  modes 
(direct,  indirect,  shared  management),  types  of  support  (e.g.  grants,  guarantees,  loans)  and 
internal vs. external action. 

SO2:  Policy  option  P2  appears  to  score  the  highest  compared  to  other  options  due  to  its 
calibrated approach to implementing the DNSH principle, due to the exemption from DNSH 
checks – for defence and security. Such a proportionate approach to implementing the DNSH 
principle is expected to generate a significant reduction of costs linked to administrative and 
reporting  burden  affecting  beneficiaries,  MS,  implementing  partners  and  EU  institutions 
compared to option P3. 

54 In line with Commission target of reducing burdens associated with administrative requirements by 25% 
55 Specific objectives 3 and 4 are not relevant to comparing options P1, P2 and P3. 

33 

 
 
 
 
 
•  Monitoring:  

The following table provides the assessment of the effectiveness of policy options M1, M2 and 
M3 against the operational objectives associated to specific objectives 2 and 356: 

Specific 
objective 
2 
3 

Policy option M1 

Policy option M2 

Policy option M3 

(=) 
(=) 

(+) 
(+)  

(+++) 
(+++) 

SO2: Policy option M3 also ranks higher in terms of enabling a significant reduction of costs 
linked  to  administrative  and  reporting  burden  affecting  beneficiaries,  MS,  implementing 
partners and EU institutions compared to option M2. As described under section 6, option M3 
is  expected  to  streamline  reporting  processes  and  reduce  associated  costs,  including  for 
businesses – such as SMEs – supported by EU budget programmes. 

SO3: Both options M2 and M3 are expected to increase the EU budget capacity to increase 
availability of expenditure tracking data due to the proposed harmonised methodology to track 
expenditures through a single list of intervention fields. Policy option M3 appears to score the 
highest compared to other options due to its fully harmonised list of performance indicators – 
linked  to  intervention  fields  –  across  programmes.  While  policy  option  M2  presents  the 
advantage of enabling the adoption of additional programme-specific performance indicators 
in case of specific needs, the effectiveness of option M2 is expected to score lower regarding 
the operational objective of increasing the capacity to aggregate performance data across EU 
budget programmes, because the single list of performance indicators would only be used on a 
voluntary basis per programme,  and because  programme-specific indicators are expected to 
vary across funds, similar to the challenges faced in monitoring performance under the 2021-
2027  period.  Comparatively,  policy  option  M3  scores  higher  because  it  should  enable  to 
develop a list of performance indicators sufficiently comprehensive and detailed to address the 
monitoring  needs  of  all  EU  funds,  while  enabling  aggregation  of  data  across  programmes, 
enabling to develop a more robust set of performance indicators enabling to assess EU budget 
performance,  support  financing  not  linked  to  cost  schemes  and  effectively  evaluate 
programmes. 

•  Reporting:  

The following table provides the assessment of the effectiveness of policy options R1, R2 and 
R3 against the operational objectives associated to specific objectives 2, 3 and 457: 

Specific 
objective 
2 
3 
4 

Policy option R1 

Policy option R2 

Policy option R3 

(=) 
(=) 
(=) 

(+++) 
(+++)  
(++) 

(+) 
(++) 
(++) 

SO2: Option R3 ranks higher in terms of enabling a reduction of costs linked to administrative 
and reporting burden affecting beneficiaries, MS, implementing partners and EU institutions, 
compared  to  option  R2.  As  described  under  section  6,  option  R3  is  expected  to  streamline 

56 Specific objectives 1 and 4 are not relevant to comparing options M1, M2 and M3. 
57 Specific objective 1 is not relevant to comparing options R1, R2 and R3. 

34 

 
 
 
 
 
reporting processes and reduce associated costs, including for businesses – such as SMEs – 
supported by EU budget programmes. 

SO3:  Both  options  R2  and  R3  are  expected  to  increase  the  availability  of  performance 
information to inform sectoral and regional policies and programmes management, thanks to 
the annual preparation of a single performance report replacing programme-specific reports. 
Option  R2  ranks  nonetheless  higher  than  R3  as  the  single  portal  would  enable  to  display 
specific data regarding dedicated areas and sectors, and performance information presenting 
specific programmes achievements. 

SO4:  Both  options  R2  and  R3  are  expected  to  improve  the  transparency  of  performance 
information by harmonising and centralising Commission reports on the performance of the 
EU  budget,  facilitating  access  to  information  by  MS  budgetary  authorities  and  other  EU 
institutions (e.g. European Parliament). Both options would also enable to achieve increased 
transparency of information on beneficiaries and operations through the publication of such 
data via the single portal, compared to the baseline. Thanks to the creation of a single portal, 
both  options  R2  and  R3  are  expected  to  result  in  improved  access  to  information  by 
harmonising  dashboards  displaying  performance  data,  and  to  information  on  funding 
opportunities.  Option  R2  may  be  considered  as  ranking  higher  than  R3  as  the  single  portal 
would  enable  to  display  specific  data  regarding  dedicated  areas  and  sectors,  increasing 
transparency vis-à-vis MS and stakeholders active in such sectors. Option R3 is nonetheless 
expected to score significantly high as it would enable to integrate e.g. MS and regions portals 
on funding opportunities in a single portal, enabling beneficiaries to access information through 
a single entry point at EU level, compared to option R2 which foresees only the integration of 
links redirecting to MS portal. 

7.2. 

Efficiency 

The efficiency of the policy options described under section 5 is examined against: 

- 

the  expected  costs  of  each  policy  option,  i.e.  the  reduction  of  administrative  burden 
foreseen, and the percentage reduction of such administrative burden compared to objective 
of 25%58, based on the quantitative analysis presented under Annex 9. The analysis focuses 
on the costs of each policy option in particular for MS administrations and the Commission, 
including  entry  costs  of  transitioning  to  a  new  system,  and  potential  cost  savings  and 
efficiency gains resulting from reduced administrative burden linked to a harmonised and 
simplified performance framework across the EU budget; 

- 

the  expected  economic  (including  regarding  competitiveness  and  SMEs),  social  and 
environmental impacts of each policy option, building upon the findings of section 6.  

•  Programming/mainstreaming:  

Costs  

Total costs linked to 
administrative burden  
Percentage reduction 
compared to objective of 
25% 

Policy option P1 
(=) 
EUR 200 million 
0% 

Policy option P2 
(+++) 
EUR 110 million  
45% 

Policy option P3 
(+) 
EUR 176 million  
12% 

58 In line with specific objective 2 

35 

 
 
 
 
Benefits 

Economic impacts 
(including competitiveness 
and SMEs) 
Social impacts  
Environmental impacts 

(=) 

(=) 
(=) 

(+++) 

(++) 
(+) 

(+) 

(+) 
(++) 

Policy option P2 appears to deliver the greatest benefits in terms of reducing costs linked to 
administrative  burden,  exceeding  largely  the  objective  of  a  25%  reduction,  reflecting  the 
expected  simplification  of  DNSH  implementation  by  MS,  implementing  partners  and 
beneficiaries, as well as the proportionate approach foreseen under this option.  

Option P2 also scores highest in terms of economic impacts, as MS and beneficiaries – such as 
businesses – would achieve economic benefits by reducing the resources currently required to 
apply  multiple  DNSH  guidances,  enabling  to  achieve  higher  predictability  of  projects 
implementation and facilitating access to EU funding. Option P2 also ranks higher than option 
P3  due  to  its  calibrated  and  proportionate  approach  to  implementing  the  DNSH  principle, 
which is likely to facilitate compliance by businesses, including SMEs, ultimately supporting 
the competitiveness of economic sectors supported by EU funds. 

Policy option P2 also scores highest in terms of social impacts, as gender equality would be 
systematically  mainstreamed  across  EU  budget  programmes.  Yet  gender  equality 
mainstreaming  would  be  differentiated  per  management  mode,  which  might  have  positive 
social impacts as it would enable more effective mainstreaming across programmes.  

In terms of environmental impacts, option P3 achieves the highest benefits as this option does 
not foresee any exemptions from DNSH checks for defence and security. Such a systematic 
application  of  DNSH  checks,  including  to  defence  and  security  projects  with  potentially 
environmentally harmful effects, is likely to achieve higher environmental outcomes. 

•  Monitoring:  

Costs  

Benefits 

Total costs linked to 
administrative burden 
Percentage reduction 
compared to objective of 
25% 
Economic impacts 
(including competitiveness 
and SMEs) 
Social impacts  
Environmental impacts 

Policy option M1 
(=) 
EUR 1 401 million  
0% 

Policy option M2 
(+) 
EUR 1 345 million  
4% 

Policy option M3 
(+++) 
EUR 841 million  
40% 

(=) 

(=) 
(=) 

(+) 

(+) 
(+) 

(+++) 

(++) 
(++) 

Policy option M3 appears to deliver the greatest benefits in terms of reducing costs linked to 
administrative burden, exceeding largely the objective of a 25% reduction, while option M2 
would  result  in  a limited  reduction  of  administrative  burden  costs  i.e.  4%.  This  reflects  the 
expected  simplification  of  expenditure  tracking  and  reduction  in  the  number  of  unique 
indicators, e.g. from ca. 5 000 to ca. 900, resulting in a reduction of administrative burden. This 
reflects the expected efficiency gains linked to option M3, including reduced data collection, 
management and quality control efforts by MS authorities, the processing of indicators by the 
Commission, and an improvement in procedural clarity.  

36 

 
 
 
 
 
Option M3 also appears as scoring highest in terms of economic impacts, as beneficiaries and 
implementing partners would reduce resources allocated to dealing with multiple expenditure 
tracking and indicators monitoring systems, even though this option would entail significant 
entry  costs.  The  reduction  of  the  number  of  indicators  would  enable  beneficiaries  such  as 
businesses – including SMEs – to face less reporting burden and reduce the costs associated 
with  project  monitoring,  ultimately  supporting  the  competitiveness  of  economic  sectors 
supported  by  EU  funds.  Comparatively,  under  option  M2,  MS,  partner  countries  and 
beneficiaries would deal with both the harmonised list of indicators and additional indicators 
per  fund.  The  reporting  burden  would  be  slightly  lower  than  under  option  M1,  but  would 
remain  relatively  significant,  though  the  reduction  of  the  number  of  EU  funds  post-2027  is 
expected to slightly reduce monitoring burdens. 

Option  M3  also  appears  as  scoring  highest  in  terms  of  fundamental  rights,  social  and 
environmental impacts, as this option would enable to aggregate indicators across programmes, 
including social and environmental indicators, enabling to enhance the policy steering of EU 
budget  support  to  social  and  green  priorities.  Option  M3  foresees  a  differentiated 
operationalisation of indicators per management mode, which would allow MS to adopt e.g. 
environment- and social-related milestones and targets addressing specific fundamental rights 
and  green  challenges  at  national  level,  which  is  expected  to  deliver  higher  social  and 
environmental outcomes than option M1. 

•  Reporting:  

Costs  

Benefits 

Total costs linked to 
administrative burden 
Percentage reduction 
compared to objective of 
25% 
Economic impacts 
(including competitiveness 
and SMEs) 
Social impacts  
Environmental impacts 

Policy option R1 
(=) 
EUR 70.0 million  
0% 

Policy option R2 
(+++) 
EUR 15.9 million  
77% 

Policy option R3 
(+) 
EUR 29.8 million  
57% 

(=) 

(=) 
(=) 

(++) 

(++) 
(++) 

(++) 

(+) 
(+) 

Option  R2  appears  to  deliver  the  greatest  benefits  in  terms  of  reducing  costs  linked  to 
administrative burden, exceeding largely the objective of 25%. This reflects a reduction of the 
costs  of  development  and  management  of  performance  dashboards  and  portals  on  funding 
opportunities  by  the  Commission  as  a  result  of  merging  into  a  single  portal,  compared  to 
maintaining the current system of ca. 20 performance dashboards and 13 portals on funding 
opportunities.  While  option  R2  presents  costs  linked  to  the  integration  or  development  of 
specific pages displaying data related to dedicated areas and sectors, its overall costs are smaller 
than option R3 as it relies  on a simple re-direction towards MS portals. Option R3 foresees 
significant entry costs linked to integrating MS portals into an EU-wide system and operating 
costs for the Commission, MS and beneficiaries.  

Options  R2  and  R3  reach  equivalent  scores  in  terms  of  economic  impacts.  A  single  online 
portal  on  information  on  funding  opportunities  would  enable  MS,  partner  countries  and 
beneficiaries  to  reduce  the  costs  allocated  to  navigating  multiple  dashboards  and  portals, 
ultimately  facilitating  access  to  EU  funds  by  beneficiaries  in  key  economic  sectors.  Under 
option R2, the single portal would enable to display performance data regarding e.g. specific 

37 

 
 
 
 
economic sectors, which may deliver higher economic benefits than option R3 by improving 
access to information by stakeholders active in such sectors. On the contrary, under option R3 
the  single  portal  would  integrate  and  replace  portals  hosted  e.g.  by  MS  and  regions,  which 
would  increase  access  to  information  on  funding  opportunities  available  to  beneficiaries  in 
relevant  economic sectors.  This  would have  a particularly  positive impact  on SMEs,  which 
operate  with  limited  staff  and  can  be  disproportionately  affected  by  the  multiplicity  of  EU 
portals,  therefore  enabling  SMEs  to  become  more  responsive  to  new  support  opportunities 
under  EU  funds.  Option  R3  may  ultimately  deliver  slightly  higher  benefits  to  the 
competitiveness of economic sectors supported by EU funds. 

Similarly,  options  R2  and  R3  reach  equivalent  scores  in  terms  of  social  and  environmental 
impacts. Under option R3 the single portal would not display specific data regarding dedicated 
areas  and  sectors,  which  may  limit  possibilities  to  display  information  on  social  and 
environmental  aspects,  potentially  reducing  opportunities  to  better  integrate  social  and 
environmental  considerations  and  challenges  back  into  the  management  of  EU  budget 
programmes,  compared  to  option R2.  On  the  contrary,  option  R3  scores  higher  as  it  would 
facilitate access to information on EU budget funding opportunities, including for beneficiaries 
in the field of EU social and environmental policies. 

7.3. 

Coherence 

Policy options are assessed against their coherence with: 

-  EU policy objectives and principles, such as the EU budget support to gender equality, and 
the Commission’s commitment to achieve simplification and reduction of administrative 
and reporting burden in particular regarding businesses, and; 

- 

legislative  framework,  such  as  the  Financial  Regulation  requirements  in  relation  to  e.g. 
gender equality, implementation of the DNSH principle, and indicators. 

•  Programming/mainstreaming:  

Policy option P1 
(=) 

Policy option P2 
(+++) 

Policy option P3 
(+) 

(=) 

(+++) 

(+) 

Coherence with 
strategic EU 
policy 
objectives 
Coherence with 
legislative 
framework 

Option P2 scores highest in terms of coherence with the Commission commitment to achieve 
simplification  and  reduction  of  administrative  and  reporting  burden  in  particular  regarding 
businesses,  due  to  its  calibrated  and  proportionate  approach  to  implementing  the  DNSH 
principle.  Options  P2  and  P3  also  display  significant  coherence  with  horizontal  EU  policy 
objectives and principles, as these two options are expected to increase the EU budget ability 
to support gender equality in line with the Union of Equality objective. Due to its harmonised 
yet calibrated approach, option P2 scores highest in terms of compliance with the Financial 
Regulation on the need to apply DNSH across the EU budget where feasible and appropriate 
and in accordance with the relevant sector-specific rules. 

•  Monitoring:  

38 

 
 
 
 
Policy option M1 
(=) 

Policy option M2 
(+) 

Policy option M3 
(+++) 

(=) 

(+) 

(+++) 

Coherence with 
strategic EU 
policy 
objectives 
Coherence with 
legislative 
framework 

Option M3 scores highest in terms of coherence with the Commission’s commitment to achieve 
simplification  and  reduction  of  administrative  and  reporting  burden  in  particular  regarding 
businesses, due to its fully harmonised list of performance indicators. Option M3 also scores 
highest in terms of compliance with the Financial Regulation, which requires indicators to be 
relevant, accepted, credible, easy, robust and based on widely recognised scientific evidence 
and  an  effective,  transparent  and  comprehensive  methodology,  as  well  as  allowing  for 
aggregation of data across programmes. 

•  Reporting:  

Policy option R1 
(=) 

Policy option R2 
(++) 

Policy option R3 
(+++) 

N/A 

N/A 

N/A 

Coherence with 
strategic EU 
policy 
objectives 
Coherence with 
legislative 
framework 

Option  R3  scores  slightly  higher  than  R2  in  terms  of  coherence  with  the  Commission’s 
commitment  to  achieve  a  reduction  of  administrative  burden,  as  the  single  portal  would 
integrate  and  replace  specific  sources  such  as  MS  portals,  which  would  facilitate  access  to 
information on funding opportunities available to beneficiaries in relevant economic sectors. 
Both  options  R2  and  R3  would  achieve  increased  coherence  with  the  Financial  Regulation 
which reinforces transparency requirements on beneficiaries supported by EU funds, as both 
options foresee the publication of such data through the single portal. 

7.4. 

Comparison summary 

The table below summarises the comparison of policy options against their ability to achieve 
effectiveness, efficiency and coherence, building upon the findings of sub-sections 7.1, 7.2 and 
7.3:   

Policy options - 
Programming/
mainstreaming 
Effectiveness 
Efficiency 
Coherence 
Policy options - 
Monitoring 
Effectiveness 
Efficiency 

Policy option P1 

Policy option P2  

Policy option P3 

(=) 
(=) 
(=) 
Policy option M1 

(=) 
(=) 

(+++) 
(+++) 
(+++) 
Policy option M2 

(+) 
(+) 

39 

(++) 
(+) 
(+) 
Policy option M3 

(+++) 
(+++) 

 
 
 
 
 
 
Coherence 
Policy options - 
Reporting 
Effectiveness 
Efficiency 
Coherence 

(=) 
Policy option R1 

(+) 
Policy option R2 

(+++) 
Policy option R3 

(=) 
(=) 
(=) 

(+++) 
(+++) 
(++) 

(++) 
(+) 
(+++) 

This comparison shows the need for possible trade-offs and synergies between options: 

-  Programming/mainstreaming:  while  option  P2  foresees  potentially  slightly  lower 
environmental benefits, it scores high in terms of effectiveness and efficiency factors linked 
to reducing administrative burden and coherence with EU policy objectives and legislative 
framework.  Options  P2  and  P3  are  also  expected  to  achieve  significant  synergies  with 
option M3 as DNSH  guidance  would be  developed taking into account  the intervention 
fields of the mandatory list to be used under option M3. 

-  Monitoring: while option M2 presents the advantage of enabling the adoption of additional 
programme-specific  performance  indicators  in  case  of  specific  needs,  its  effectiveness 
scores  lower  regarding  the  need  to  increase  the  capacity  to  aggregate  performance  data 
across EU funds, because the single list of performance indicators would only be used on 
a voluntary basis by programmes, and because programme-specific indicators are expected 
to  vary  across  programmes,  similar  to  the  challenges  faced  in  monitoring  performance 
under the 2021-2027 period. Comparatively option M3 is expected to enable aggregation 
of  data  across  funds,  yet  it  risks  resulting  in  discontinuing  certain  indicators  that  were 
needed under some programmes. Such a risk should be mitigated by developing a list of 
performance indicators sufficiently comprehensive to address the monitoring needs of all 
EU  funds,  support  financing  not  linked  to  cost  schemes  and  effectively  evaluate 
programmes. Option M3 is also expected to achieve synergies with options R2 and R3 as 
the  single  portal  would  be  the  logical  vehicle  to  display  data  collected  under  a  single 
monitoring framework. 

-  Reporting: in terms of trade-offs, option R3 scores slightly higher in terms of coherence 
with  the  Commission’s  commitment  to  achieve  simplification  and  reduction  of 
administrative  burden  because  it  would  provide  a  fully  harmonised  portal  on  funding 
opportunities,  also  integrating  MS  portals.  Option  R2  scores  nonetheless  slightly  higher 
overall,  because  it  achieves  higher  effectiveness  and  efficiency,  mainly  due  to  its 
significantly lower entry costs i.e. reduced costs of development of a single portal compared 
to R3 which is ambitious but significantly more expensive to develop. 

In  terms  of  sensitivity  analysis,  the  above  comparison  may  need  to  be  nuanced  due  to  the 
uncertainty attached to certain findings and conclusions: 

- 

In  contrast  with  impact  assessments  linked  to  specific  EU  budget  programmes,  where 
impacts  are  typically  predicted  based  on  macro-economic  modelling,  the  quantitative 
analysis of this impact assessment focuses on assessing reductions of administrative costs 
for  MS  administrations.  The  analysis  particularly  faced  data  availability  limitations,  as 
quantitative information on administrative burden linked to performance is scarce beyond 
the  qualitative  findings  of  e.g.  programmes  evaluations.  The  analysis  is  based  on  a 
combination  of  data  available  from  studies  and  estimates  by  Commission  services, 
including  reduction  factors  enabling  to  calculate  expected  reductions  of  administrative 

40 

 
 
 
costs for each policy option. Any variations in the assumptions underpinning such factors 
is likely to have significant impacts on the costs estimated for each policy option. 

-  Moreover, while the quantitative analysis focused on assessing reductions of costs for EU 
institutions  and  MS  authorities,  significant  reductions  of  administrative  burden are  also 
expected – from options P2, P3, M2, M3, R2, R3 – at the level of beneficiaries, including 
businesses.  Quantifying  such  reductions  was  nonetheless  not  possible  due  to  a  lack  of 
available  data.  The  quantitative  analysis  would  also  have  benefitted  from  data  on  the 
administrative  costs  of  monitoring  performance  in  the  case  of  direct  and  indirect 
management. These shortcomings should be addressed in the future so as to fill the data 
gap,  in  particular  in  the  context  of  new  Commission  priorities  and  the  commitment  to 
reduce administrative and reporting burden (cf. section 9).  

-  The analysis of economic, social and environmental impacts provided under section 6 is 

also of a qualitative nature given the lack of quantitative data available. 

Policy options P2, M3 and R2 conform to the principles of subsidiarity and proportionality 
given the size and nature of the identified problems: 

-  Policy option P2 foresees that DNSH and gender equality are applied consistently across 
all  budget  programmes,  fostering  coherence  while  accommodating  diverse  management 
modes (direct, indirect, shared), type of support and internal vs. external action. This would 
give MS and implementing partners the flexibility to adapt to their specific circumstances, 
in line with the subsidiarity principle. Option P2 conforms to the proportionality principle 
because of its calibrated approach to DNSH.  

-  Option  M3  respects  subsidiarity  by  giving  MS  the  autonomy  to  adopt  country-specific 
milestones  and  targets  in  their  plans  if  needed,  and  by  avoiding  over-reporting  by  MS, 
implementing partners and beneficiaries.  

-  Option  R2  respects  subsidiarity  by  allowing  for  differentiated  operationalization  per 
management mode, ensuring that specific areas or sector needs are taken into account in 
the  single  portal.  The  single  portal  would  simplify  access  for  beneficiaries  and  MS, 
reducing  administrative  burden  in  line  with  the  proportionality  principle.  By  merging 
reporting requirements into a consolidated AMPR, option R2 further eliminates redundant 
processes, achieving proportionality.  

Building  upon  the  analysis  and  comparison  of  individual  policy  options,  the  table  below 
summarises the comparison of combinations of policy options against their ability to achieve 
effectiveness, efficiency and coherence: 

Effectiveness 
Efficiency 
Coherence 

P1+M1+R1 
(=) 
(=) 
(=) 

P2+M2+R2 
(++) 
(++) 
(++) 

P2+M3+R2 
(+++) 
(+++) 
(+++) 

P3+M3+R3 
(++) 
(++) 
(++) 

The  table  below  also  provides  a  comparison  of  the  administrative  costs  attached  to  each 
combination of policy options: 

P1+M1+R1 
EUR 1 671 Mio 

P2+M2+R2 
EUR 1 471 Mio 

P2+M3+R2 
EUR 967 Mio 

P3+M3+R3 
EUR 1 049 Mio 

Total costs linked 
to administrative 
burden 

41 

 
 
 
 
 
Combination  P2+M3+R2  appears  as  achieving  the  highest  effectiveness,  efficiency  and 
coherence  as  it  combines  individual  policy  options  scoring  best.  Both  combinations 
P2+M2+R2  and  P3+M3+R3  score  relatively  well,  but  P2+M2+R2  scores  lower  than 
combination P2+M3+R2 in terms of effectiveness of the performance monitoring system of 
the EU budget as it limits possibilities to aggregate indicators across programmes, and in terms 
of reduction of administrative burden because it would likely result in the adoption of a high 
number  of  programme-specific  indicators.  Combination  P3+M3+R3  also  scores  lower  than 
combination P2+M3+R2 because it achieves less proportionality in implementing DNSH and 
complying with the Financial Regulation requirements, and entails significant entry costs to 
develop and high operating costs to run a single portal on funding opportunities. 

8.  PREFERRED OPTION 

8.1. 

Preferred policy option 

In view of the analysis under section 7, the preferred combination of options is P2+M3+R259. 
This combination would enable to effectively deliver against horizontal EU principles such as 
DNSH  and  gender  equality,  yet  foreseeing  calibrated  and  proportionate  implementation  of 
DNSH, enabling to comply with the Financial  Regulation requirement to implement DNSH 
where feasible and appropriate, while reducing administrative burden for MS, implementing 
partners and beneficiaries. This combination also enables a significant upgrade of EU budget 
performance  monitoring  by  enabling  aggregation  of  indicators  across  programmes,  while 
achieving  significant  administrative  burden  reduction  thanks  to  the  simplification  of  the 
existing landscape of performance indicators, reducing them from ca. 5 000 to ca. 900. This 
combination of options also enables improved access to performance information and funding 
opportunities,  while  limiting  entry  costs  to  develop  a  single  portal  by  focusing  on  merging 
Commission portals only. 

Combination  P2+M3+R2  is  expected  to  achieve  ca.  EUR  623  Mio  of  administrative  costs 
savings for  MS administration and  the Commission  compared to  the baseline. This  number 
corresponds  however  to  a  strong  underestimation  of  expected  cost  savings,  since  the 
quantitative analysis of the impacts of policy options did not quantify all impacts due to a lack 
of data. However significant reductions of costs are also expected for beneficiaries, such as 
businesses, supporting the competitiveness of the sectors supported by EU funds. 

The most appropriate vehicle to operationalize this preferred combination of options appears 
to be a single performance framework through a single legal act. Such a performance regulation 
would enable to centralise most programming, monitoring and reporting provisions in a self-
standing horizontal act for the post-2027 MFF. 

The  regulation  will  include  relevant  provisions  on  implementing  the  DNSH  principle 
(including  an  empowerment  to  adopt  a  technical  guidance  setting  DNSH  criteria),  on 
mainstreaming  gender  equality  across  programmes  and  management  modes,  as  well  as  on 
performance monitoring, performance reporting through a single report (AMPR) and the single 
portal. The regulation will include the single list of intervention fields and associated indicators, 

59 Annexes 6, 7 and 8 provide further details on the proposed operationalisation of each element of the preferred 
combination. 

42 

 
 
 
 
developed  by  Commission  services  with  the  aim  to  ensure  an  extensive  coverage  of  all 
interventions supported by the EU budget. 

The  regulation  will  serve  as  the  overarching  performance  framework  for  all  EU  budget 
programmes post-2027. All programme regulations will include a dedicated recital ensuring a 
cross-reference to the performance regulation. By reflecting all interventions supported under 
EU budget programmes, the list of intervention fields and indicators will reflect programmes 
objectives,  enabling  the  use  of  such  indicators  in  the  context  of  programme  evaluations,  in 
addition to performance monitoring and payments. 

8.2. 

REFIT (simplification and improved efficiency) 

While the proposed regulation does not correspond to a revision of existing legislation stricto 
sensu, the preferred policy option is fully in line with the REFIT objective of simplification 
and  reduction  of  red  tape.  Section  7  describes  extensively  the  expected  reduction  of 
administrative  burden  and  improved  efficiency  expected  from  the  preferred  combination  of 
options enabling to achieve a significant reduction of regulatory costs.  

P2. Programming and 
mainstreaming   
EUR 110 million  
45%  

M3. Monitoring   

EUR 841 million  
40%  

Policy options  

Costs per policy option  
Percentage of reduction 
of administrative burden 
costs compared to 
baseline 

R2. Reporting   

EUR 15.9 million  
77%  

The significant decrease in the number of performance indicators and the establishment of a 
single  portal  for  performance  information  and  funding  opportunities  significantly  reduces 
administrative  burdens,  which  directly  addresses  REFIT’s  objective  of  cutting  red  tape  and 
lowering  costs  for  stakeholders,  thus  encouraging  broader  participation  and  engagement. 
Proportionate  DNSH  requirements  also  align  with  REFIT’s  emphasis  on  effectiveness  and 
efficiency,  and  increases  the  likelihood  of  successful  compliance  by  beneficiaries.  By 
upgrading the monitoring mechanism and enabling the aggregation of indicators across funds, 
the framework improves transparency and accountability, which also aligns with the REFIT 
goal  of  making  EU  interventions  more  results-oriented.  The  expected  improved  access  to 
performance information and funding opportunities also resonates with the REFIT principle of 
improving users experience by making systems more accessible. 

8.3. 

Application of the ‘one in, one out’ approach 

The single performance regulation would replace the performance provisions scattered across 
the legal  bases of more than 50  programmes  in  the 2021-2027 period. The adoption of  this 
single regulation is therefore expected to achieve significant simplification. The single list of 
intervention  fields  and  performance  indicators  will  replace  the  several  lists  of  intervention 
fields and performance indicators currently attached to e.g. the CPR, the RRF regulation and 
other programmes legal bases. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

A number of actions should be taken to monitor and evaluate the impacts of this initiative. 

The adequacy of the list of intervention fields and performance indicators – to be adopted as 
part of the performance regulation – should be monitored by the Commission in order to assess 
any  potential  gaps  or  shortcomings,  and  assess  whether  the  new  monitoring  framework  is 

43 

 
 
adequate in terms of effectiveness, efficiency and added value of interventions supported by 
the EU budget. Such monitoring will take place during the implementation phase of the post-
2027 MFF, including during the preparation of the annual reports on the performance of the 
EU budget, as requested in the Financial Regulation. As a mitigation measure, the regulation 
will contain an empowerment for the Commission to adopt a delegated act enabling to revise 
the  list,  as  relevant,  during  the  phase  of  implementation  of  the  budget.  As  relevant,  the 
Commission will assess the fitness for purpose of the list, identify any potential gaps, and may 
propose  updates  to  the  list.  At  the  same  time,  any  updates  of  the  list  should  be  kept  to  a 
minimum in order to preserve the ability to aggregate and compare data over the MFF duration.  

The Commission study on assessing the administrative costs and burden in the management of 
CPR funds (2025) should be updated during the phase of implementing the post-2027 budget, 
enabling  to  update  the  values  provided  in  terms  of  costs  of  performance  monitoring  and 
reporting. Such a study should estimate the administrative costs of monitoring performance in 
the case of direct and indirect management, in addition to shared management. The results of 
this study should be used as input for any future impact assessments in view of the following 
MFF. 

The monitoring and evaluation of this initiative should be carried out based on a number of 
core monitoring indicators, addressing the following aspects for all EU budget programmes 
(possibly by expanding the scope of the above study): 

• 

relevance of intervention fields and indicators in view of performance monitoring; 

•  administrative costs of implementing performance provisions – including at the level of EU 
budget beneficiaries, such as businesses – regarding monitoring and reporting, as well as 
implementation of e.g. the DNSH principle, costs of access to information of EU budget 
performance and funding opportunities, including by beneficiaries, budgetary authorities, 
implementing partners, partner countries and EU institutions.  

44 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/CWP references 

DG BUDG is the lead Directorate General, in close coordination with the Secretariat General, 
for  this  initiative  on  the  Performance  framework  of  the  post-2027  Multiannual  Financial 
Framework. 

2.  Organisation and timing 

The  work  on  the  Impact  Assessment  on  the  Performance  framework  of  the  post-2027 
Multiannual Financial Framework was coordinated with other Commission services through 
an Inter-Service Group (ISG).  The ISG was established on 9 January 2025. Representatives of 
the  Secretariat  General  (SG),  Legal  Service  (LS),  Reform  and  Investment  Task-Force  (SG 
REFORM), Directorate-General for Regional and Urban Policy (REGIO), Directorate-General 
for Employment, Social  Affairs and  Inclusion (EMPL), Directorate-General  for Agriculture 
and  Rural  Development  (AGRI),  Directorate-General  for  Maritime  Affairs  and  Fisheries 
(MARE),  Directorate  General  for  Research  and  Innovation  (RTD),  Directorate-General  for 
Communications  Networks,  Content  and  Technology  (CNECT),  Directorate-General  for 
Enlargement  and  Eastern  Neighbourhood  (ENEST),  Directorate-General  for  International 
Partnerships (INTPA), Directorate-General for Environment (ENV), Directorate-General for 
Climate Action (CLIMA), Directorate-General for Justice and Consumers (JUST), Directorate-
General  for  Migration  and  Home  Affairs  (HOME),  Directorate-General  for  Economic  and 
Financial  Affairs 
Industry, 
Entrepreneurship and SMEs (GROW),  Directorate-General for Education, Youth, Sport and 
Culture  (EAC),  Directorate-General  for  Mobility  and  Transport  (MOVE),  Joint  Research 
Centre (JRC), and Directorate-General for Eurostat (ESTAT) were appointed to the ISG.  The 
ISG met four times, first on 22 January 2025, and the final meeting before the submission of 
the draft Impact Assessment to the Regulatory Scrutiny Board took place on 10 April 2025. 
Other ISG meetings were held on 13 February and 12 March 2025. Several rounds of written 
consultations took place since January 2025, with the last round ending on 8 May. 

(ECFIN),  Directorate-General 

Internal  Market, 

for 

A number of other Commission services were also consulted on specific aspects of the impact 
assessment such as Directorate-General for European Civil Protection and Humanitarian Aid 
Operations (ECHO), Directorate-General for Energy (ENER), Directorate-General for Health 
and Food Safety (SANTE), Directorate-General for Competition (COMP), Directorate-General 
for the Middle East, North Africa and the Gulf (MENA)  and Directorate-General for Defence 
Industry and Space (DEFIS). 

3.  Consultation of the RSB 

The Draft Impact Assessment report was presented to the Regulatory Scrutiny Board during an 
upstream meeting on 1st April 2025. 

The Draft Impact Assessment report was submitted to the Regulatory Scrutiny Board on 21 
May 2025. It received an opinion without qualification on 13 June 2025. 

45 

 
 
The Board made comments in relation to the following areas, which were addressed in the final 
version of the impact assessment as follows: 

RSB comment 

Follow-up rectification of the impact assessment 

Clarified in sections 1 and 8.  

The impact assessment focuses on the mainstreaming of the 
gender equality and Do No Significant Harm principles 
because these are legal requirements under the Financial 
Regulation (Article 33). Other policy objectives (such as 
competitiveness and defence) will be supported through the 
steering mechanism, which will enable to identify and 
mainstream relevant priorities, and through the specific 
design of individual programmes such as the 
competitiveness fund and the policy objectives of the 
national and regional partnership plans. 

The regulation will serve as the overarching performance 
framework for all EU budget programmes post-2027. All 
programme regulations will include a dedicated recital 
ensuring a cross-reference to the performance regulation. By 
reflecting all interventions supported under EU budget 
programmes, the list of intervention fields and indicators will 
reflect programmes objectives, enabling the use of such 
indicators in the context of programme evaluations, in 
addition to performance monitoring and payments. 

Scope and coherence 

The report is not sufficiently clear 
on how it links with other ongoing 
MFF impact assessments in relation 
to the establishment of the 
monitoring and performance 
framework and its implementation. 
It does not justify why 
harmonisation and simplification of 
mainstreaming provisions is limited 
to only two policy areas. 

The report should better explain the 
link with the six other MFF impact 
assessments. It should clarify to 
what extent the analysis presented 
in the impact assessment covers the 
monitoring and performance 
frameworks of the impact 
assessments for the other 
programmes under the next MFF. 

The scope of the intervention 
linked to the policy mainstreaming 
is limited to only two policy areas 
foreseen in the current Financial 
Regulation: gender equality and the 
‘do no significant harm’ principle. 
The report should assess whether 
and how other horizontal priorities 
(e.g. competitiveness, security, 
digitalisation, preparedness) should 
also be mainstreamed reflecting 
major societal problems and 
political objectives of the EU. 

Problem definition and use of evaluations 

The report does not sufficiently 
investigate the necessary 
preconditions for tracking the 
impact of the EU budget. 

While referring to recent 
evaluations of spending 
programmes, the report in its 
problem definition does not reflect 

Clarified in section 2. Programme evaluations reviewed in 
the context of the impact assessment provided relatively 
limited information available on the fitness for purpose of 
the existing framework to measure impacts. A second review 
of evaluations – as well as relevant ECA audit findings – 
was carried out to better identify and describe issues linked 
to data availability and quality for monitoring and evaluation 
purposes, with particular attention to corresponding RSB 

46 

 
 
feedback, and taking into account the criteria on indicators of 
the recast Financial Regulation. 

their frequent conclusions and RSB 
recommendations in relation to data 
availability and need to 
significantly improve monitoring 
and evaluation arrangements. The 
current performance framework 
should be critically assessed against 
its ability to measure the impact of 
the EU budget identifying major 
deficiencies including underlying 
reasons, overlaps and 
inconsistencies, and reflecting the 
results of such analysis in the 
problem definition. 

Objectives and intervention logic 

It is not sufficiently clear what is 
intended to be achieved by the 
performance framework. 

The objectives of the initiative 
should be better specified in line 
with a more detailed problem 
definition. The link between budget 
transparency and accountability 
with the policy performance 
(achieving policy objectives) 
should be further developed. The 
report should better describe what 
the performance framework intends 
to achieve and thus better define the 
specific objectives in S.M.A.R.T. 
terms to the extent possible in order 
to facilitate continuous monitoring 
of the fit-for-purpose of individual 
performance indicators and the 
performance framework as a whole. 

Clarified in sections 7 and 9. The objectives are intended to 
provide strategic direction. Integrating quantified elements in 
the specific objectives (cf. section 4.2) has been particularly 
challenging, except for objective SO2 linked to reducing 
administrative burden and costs affecting EU budget 
beneficiaries, Member States, third countries, implementing 
partners and EU institutions – which includes a target value 
of 25%, in line with the Commission target of reducing 
burdens associated with administrative requirements.  

For other specific objectives linked to increasing capacity to 
address current and future policy priorities (SO1), enhancing 
capacity to measure EU budget impact (SO3), and increasing 
transparency and access to information for budgetary 
authorities and beneficiaries (SO4), setting precise 
quantitative targets is much more challenging. Instead, 
section 7.2 of the impact assessment identifies a number of 
operational objectives for each of the specific objectives in 
order to clarify what is intended to be achieved.  

Progress on the achievement of SO3 and SO4 will be 
monitored by assessing the adequacy of the common list of 
intervention fields and performance indicators in order to 
identify any potential gaps or shortcomings, as well as 
during the preparation of the annual reports on the 
performance of the EU budget, as requested in the Financial 
Regulation. To this effect, the regulation will contain an 
empowerment for the Commission to adopt a delegated act 
enabling to revise the list of intervention fields and 
indicators, during the phase of implementation of the post-
2027 budget.  

Options 

The content of options is not 
sufficiently developed to capture 

Clarify in Annexes 6, 7 and 8 (future operationalization of 
the preferred policy option). Additional elements were 

47 

 
 
not only budget execution but also 
impacts of different MFF 
programmes. The options the report 
considers achieving the desired 
objectives should be developed or 
presented in greater detail. For the 
programming options, subject to 
the possibly revised scope, the 
report should better explain the 
mechanisms that would allow for 
mainstreaming of a range of chosen 
policy objectives. For monitoring, 
the report should clearly delineate 
the differences between options, 
explain the different processes and 
methods for establishing and 
modifying the list of intervention 
fields and indicators. It should also 
be clarified how the lists of 
performance indicators are 
formulated and if the common list 
of indicators is of equal length and 
content in both options. It should 
further explain what the flexibility 
is to adopt and use additional 
indicators in each of the options. It 
should be clarified how the 
framework can provide a set of 
meaningful indicators for each of 
the MFF funds that would allow for 
measuring their respective impact, 
given that the framework’s list of 
indicators is supposed to be usable 
across instruments/funds. 

included to further reflect the construction of the 
Performance Regulation, which will include articles (e.g. on 
expenditure tracking and performance monitoring) setting 
out rules for each management mode i.e. ‘differentiated’ or 
‘calibrated’ operationalisation. Such articles define for 
example how Member States will have to pick output 
indicators from the common list to define milestones and 
targets in their plans, as well as result indicators to enable for 
additional performance monitoring. 

Annex 9 further includes an estimation of the baseline policy 
option, but an estimation of the current MFF baseline could 
be added in terms of current administrative burden and 
administrative costs. 

Because the common list will include ca. 500 intervention 
fields reflecting the objectives of programmes, and because 
the list will include indicators attached to each intervention 
field, there will be several indicators available to monitor the 
achievement of programme objectives and therefore enable 
robust evaluations. The list of indicators focuses on output 
and result indicators, as including relevant and available 
impact indicators remains a challenge. A methodology was 
developed with the support of the JRC to define intervention 
fields and related indicators. The list is based on a system of 
classification by policy area, covering the interventions of all 
programme intervention areas post-2027. The indicators 
linked to intervention fields will correspond to and enable to 
measure the outputs and results that are intended to be 
produced by all interventions in programmes.   

The ‘short set of indicators mandatory across programmes’ 
under option M2 refers to common indicators on output and 
results achieved by programmes, similar to the 14 common 
indicators of the RRF. Options M2 and M3 refer to 
flexibility for Member States and third countries to adopt 
output indicators outside the common list in case certain 
measures of their plans justify tailored targets. Generally, 
under their plans, it will be mandatory for Member States to 
report on at least one output indicator (used as target) and at 
least one result indicator – for each measure of their plan. 
Adopting an additional mandatory list of common indicators 
was assessed as delivering limited benefits in a context 
where the next MFF will evolve towards a performance-
based delivery model. 

Regarding option R3, the single performance report (AMPR) 
will continue to be prepared by relevant Commission 
services. Simplification is expected from the fact that there 
will no longer be programme specific performance reports as 

48 

 
 
Cost assessment 

The methodology and assumptions 
used to calculate cost savings are 
not sufficiently explained. The 
report does not provide estimates 
for administrative cost savings for 
other stakeholders including 
businesses. 

The analysis developed in Annex 9 
should be transparent on how 
efficiency is estimated for the 
different options and how it 
impacts the comparison of options. 
The report should clarify further the 
assumptions taken to calculate the 
correction coefficients (reduction 
factors) applied to the estimates of 
administrative burdens of the 
options as they are the key factor 
distinguishing the impact of 
different measures in terms of 
efficiency. Further efforts should be 
taken to provide estimates of the 
administrative burdens on 
businesses and their reduction, 
currently missing from the report. 

Governance 

The report does not sufficiently 
describe the governance and 
implementation mechanisms. The 
report should explain how the 
governance framework that will be 
put in place to ensure that 
meaningful indictors are included 
to track the performance and 
impact of the EU budget. The 
report should clarify the process 
and various steps for adopting and 
modifying, when necessary, the 
performance framework including 
intervention fields and indicators. 

Monitoring and data 

currently provided for in the legal bases of a number of 
programmes. 

Clarified in section 7 and Annex 9.  

The report provides qualitative analysis of impacts for 
beneficiaries, including businesses, in section 6. The 
quantitative analysis of policy options did not estimate 
administrative cost savings expected for other stakeholders 
including businesses due to a lack of data. Section 9 of the 
impact assessment proposes to assess expected costs savings 
for beneficiaries such as businesses. Annex 9 was amended 
to further explain the reduction factor, including linked to the 
expected decrease of the number of indicators from over 5 
000 to ca. 900. 

The sensitivity analysis was reinforced in section 7, and a 
sensitivity analysis included in Annex 9. Section 7.2 of the 
impact assessment assesses the efficiency of the policy 
options based on the quantitative analysis presented under 
Annex 9 (reduction of administrative costs). The analysis 
focuses on the costs of each policy option in particular for 
Member State administrations and the Commission, 
including entry costs of transitioning to a new system, and 
potential cost savings and efficiency gains resulting from 
reduced administrative burden linked to a harmonised and 
simplified performance framework across the EU budget. 
The assessment of the efficiency of each policy option also 
takes into account the expected economic (including 
regarding competitiveness and SMEs), social and 
environmental impacts of each policy option, building upon 
the findings of section 6. 

Annex 1 added, and further clarifications added to section 8. 
The concept and architecture of the list of intervention fields 
and indicators has been developed in the context of an 
interservice group gathering relevant Commission services, 
building upon scientific and methodological support by the 
JRC, with the aim to ensure an extensive coverage of all 
interventions supported by the EU budget. The list of 
intervention fields and indicators will be included in annexes 
to the Performance Regulation. The relevance of the list will 
be monitored over time, and the Commission will be 
empowered to adopt a Delegated Act should any revisions be 
needed. 

49 

 
 
Clarified in Annex 7. The new list of indicators aims at 
setting up a performance framework for the EU budget while 
enabling to conduct programme monitoring and evaluation. 
By establishing a direct link between intervention fields and 
indicators, the common list will provide more information 
than currently on the link between ‘how much do we spend’ 
and ‘what do we achieve’, which will be relevant in the 
context of programme monitoring and evaluation. The 
methodology for developing indicators also focuses on 
ensuring that indicators are drafted to measure what we 
actually achieve with EU investments, therefore ensuring a 
causal link between programmes objectives and the new 
common set of indicators. Because all management modes 
and programmes will use the same set of intervention fields 
and indicators, the new system will enable to compare the 
effectiveness, efficiency and added value of programmes’ 
budget interventions. The initiative focuses on monitoring 
outputs and results because of the lack of availability of 
meaningful long-term impact indicators beyond outputs and 
results, though some of the result indicators of the common 
list may also be seen as impact indicators (e.g. GHG 
emissions avoided). 

The report does not clarify to what 
extent the planned monitoring 
framework would be sufficient to 
ensure the availability of data for 
monitoring and evaluations of the 
specific programmes and how its 
continuous fit-for-purpose will be 
ensured. 

The report should bring forward 
how the proposed list of 
performance indicators would 
cover not only outputs and results 
but also mid to longer-term 
impacts, which are necessary for 
tracking the impact of the budget 
and for future evaluations, in 
particular of effectiveness, 
efficiency and EU added value, 
consistent with the Commission’s 
Better Regulation requitements. 
The report should also bring 
forward how compliance costs will 
be monitored, which is necessary, 
for example, to implement the 
Commission’s ‘one in one out’ 
principle. The report should 
establish at which stage and how 
the data plans as required by the 
Better Regulation Toolbox will be 
developed and what they will cover 
to ensure relevant and sufficient 
data for evaluation purposes. A 
systematic approach to assessing 
continued relevance of indicators, 
in particular, those linked to 
performance-based payments, and 
gaps in terms of objectives and 
impacts not sufficiently developed. 
To this end, the report should 
describe how the fit-for-purpose of 
the established intervention fields 
and indicators would be assessed. 
After defining the objectives in 
more S.M.A.R.T. terms, the report 
should outline appropriate 
monitoring and evaluation 
arrangements which would allow to 
monitor the progress on achieving 
the objectives of the performance 
framework. 

50 

 
 
What  are  the  available  AI  tools  to 
modernise  data  collection  and 
interoperability of databases? 

Clarified  in  section  5.  AI  is  evolving  at  fast  pace  hence  it 
remains difficult to anticipate the exact role that it will play in 
operationalizing the performance framework of the post-2027 
budget. Yet it is expected to help modernise data collection, 
such  as  by  helping  Member  States  to  allocate  projects  to 
intervention  fields,  and  to  contribute  to  the  cleaning, 
processing,  and  analysis  of  performance  data,  while  also 
enhancing data quality and reliability control mechanisms. AI 
may  also  help  in  the  future  in  terms  of  inter-operability  of 
databases,  in  a  context  where  performance  information 
remains  scattered  across  several  Commission  databases, 
which  limits  aggregation  of  indicators  across  programmes. 
Lastly, future AI tools could also help make the reporting of 
performance information more interactive for the end users. 

4.  Evidence, sources and quality 

The  Commission  collected  extensive  information  and  evidence  to  support  the  analysis 
underpinning the problem definition, for example in terms of mapping of existing performance 
provisions across EU budget programmes. Beyond analysing the legal basis and acts adopted 
in  the  context  of  EU  budget  programmes,  it  carried  out  an  extensive  review  of  available 
literature, including reports from the European Court of Auditors and the European Parliament. 

The  Commission  also  collected  information  relevant  in  the  context  of  the  quantitative  and 
quantitative analysis of the impacts of policy options, such as regarding the costs and benefits 
of  managing  existing  performance  dashboards  and  portals  as  well  regarding  the  costs  and 
benefits of creating a single performance portal. 

51 

 
 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

Introduction  

The  Commission  actively  engaged  the  stakeholders  in  the  process  of  the  initiative  and 
consulted  them  on  the  effectiveness  of  the  performance  framework  of  the  2021-2027  EU 
budget, both through a number of events and through an Open Public Consultation. The key 
findings of this consultation are summarised below.  

1.  Overview of the relevant stakeholder consultations  

The following relevant consultations of stakeholders have taken place or are planned, including 
workshops and ongoing studies:   

•  Citizens  panel  on  the  new  European  budget:  From  March  to  May  2025,  the 
Commission  organised  a  Citizens'  Panel  on  a  New  European  Budget  as  a  way  for 
citizens to engage with the EU institutions and have their say on the EU policymaking 
process. The event included three sessions gathering 150 randomly selected citizens to 
help the EU decide how to spend its money in future, including an in-person session 
from 28-30 March, a second online session (April 25-27), and a third and final session 
in  Brussels 
their 
recommendations. The participants, coming from all 27 EU countries and representing 
the EU’s diversity, reflected on where the EU Budget could bring the most added-value 
to  Europeans.  In  parallel,  the  Citizens'  Engagement  Platform,  an  online  discussion 
forum, enabled additional contributions from the general public.  

(May  16-18)  where  2  volunteers  officially  handed 

in 

•  Annual  Budget  Conference:  The  event  brought  together  high-level  speakers  – 
European  and  global  policymakers,  researchers,  representatives  of  think  tanks,  civil 
society and businesses leaders – who debated a broad range of topical questions on 20 
and 21 May 2025.  

•  Tour d’Europe: During the first half of 2025, Commissioner for Budget Piotr Serafin 
travelled  across  the  European  Union  to  consult  decision-makers,  regions,  citizens, 
businesses and other relevant stakeholders on the EU budget. These trips featured visits 
of many EU-funded projects in diverse fields – from education to research, defence to 
agriculture and more. 

•  Hearing with social partners on the next MFF: On 17 June 2025, the Commission 
(DG EMPL and DG BUDG) met with several representatives of the EU social partners 
with a view to discussing the challenges and guiding principles for the next MFF. 

A number of recommendations were made in the context of those consultations. A wide array 
of  topics  was  identified  as  priorities  such  as  defence  and  security,  migration  and  border 
management,  education  and  workforce,  climate  and  sustainability  and  healthcare,  social 
policies.  The  need  to  simplify  EU  budget-related  procedures  which  currently  generate 
significant  administrative  burden  and  costs  was  also  a  recurrent  theme  throughout  the 
discussions  and  featured  in  the  recommendations,  as  well  as  the  need  for  transparency  and 
accountability in spending EU funds.   

Furthermore,  recommendations  were  made  in  relation  to  the  importance  of  mainstreaming 
green and social priorities in the EU budget and ensuring that EU-funded projects do no harm 

52 

 
 
to the environment and the climate, the need to support gender equality, as well as the need to 
support SMEs to foster employment and reduce dependencies. 

2.  Results of the Open Public Consultation  

On 12 February 2025, the Commission published the Open Public Consultations on the post-
2027 MFF, including a dedicated consultation on the performance of the EU budget, open until 
6 May 2025. The consultation was based on an online questionnaire addressing the various 
dimensions of performance of the EU budget. The questionnaire focused in particular on: 

- 

the  tools  used  to  promote  horizontal  priorities  and  principles  (e.g.  gender  equality, 
digitalisation,  climate  and  biodiversity,  the  ‘do  no  significant  harm’  to  climate  and 
environmental objectives) across the EU budget, to ensure that EU spending is geared 
towards those objectives, also sometimes referred to as ‘mainstreaming’; 

-  performance framework, including the tools to monitor and report how effectively the 

EU budget is achieving its objectives. 

The questionnaire included 34 questions in total, focusing on the effectiveness of the above-
mentioned tools, including also specific questions on the mainstreaming of gender equality and 
of the Do No Significant Harm principle, and existing monitoring tools such as indicators, as 
well  as  reports,  dashboards  and  portals  used  to  report  performance  information  and  inform 
potential beneficiaries about funding opportunities. 

In total 555 stakeholders submitted their feedback, representing the views of a group of EU 
citizens (128), non-governmental organisations (124), public authorities (111), academic and 
research  institutions  (45),  business  associations  (40),  companies  and  businesses  (36), 
environmental  organisations  (7),  trade  unions  (6),  non-EU  citizens  (3),  and  others  (55). 
Respondents  originated  from  26  Member  States  and  8  non-EU  countries,  with  the  main  10 
countries  of  origine  being  the  following  ones  (in  decreasing  order):  Germany,  Belgium,  
Poland, France, Italy, Spain, Finland, Netherlands, Sweden, Romania. 

Overall the feedback to the Open Public Consultation supports the problem definition of the 
impact assessment, in particular regarding climate and gender equality mainstreaming across 
EU budget programmes, implementation of the DNSH principle as well as monitoring through 
indicators  and  the  need  for  transparency  of  performance  information,  calling  for  a  more 
structured  and  accountable  approach  to  integrating  horizontal  EU  priorities  into  the  MFF. 
Several respondents placed emphasis on shifting towards an impact-oriented approach, with a 
focus on aligning the framework with strategic goals like sustainability, climate action, digital 
transformation,  social  inclusion  and  health  equity,  also  highlighting  the  need  for  increased 
funding and co-financing rates to support these objectives. Several stakeholders highlighted 
the  need  for  alignment  of  the  EU  budget  with  broader  societal  goals  such  as  sustainability, 
gender  equality,  and  biodiversity.  Stakeholders  further  highlighted  the  need  for  "strategic 
reserve"  mechanisms  within  the  budget  for  adaptability  in  unforeseen  circumstances. 
Respondents  generally  highlighted  the  need  for  standardisation  and  simplification  of 
performance and mainstreaming provisions, also ensuring that policies are responsive to local 
contexts and needs. Stakeholders provided additional elements to  the problem definition, in 
particular regarding the need for stakeholders’ involvement in performance processes as well 
as  emphasising  the  need  for  capacity  building.  Respondents  also  highlighted  the  need  for 
binding indicators and spending targets to ensure that cross-cutting priorities are effectively 

53 

 
 
integrated into all EU funds and programmes, in particular in relation to gender equality and 
biodiversity.  Several  stakeholders  further  highlighted  the  need  to  create  a  centralised, 
multilingual portal to enhance transparency and accessibility of funding information. 

Respondents to the consultation provided additional details on a number of key areas:  

-  Promotion of the principle of gender equality across the EU budget: the responses to 
the  question  of  how  the  EU  budget  could  better  support  gender  equality  reveal  a 
complex  landscape  of  hurdles  and  proposed  actions,  reflecting  diverse  perspectives 
from various stakeholders. Stakeholders, including civil society organizations, public 
authorities,  and  private  sector  representatives,  have  highlighted  the  need  for  more 
targeted  and  flexible  approaches  to  gender  equality,  emphasising  the  importance  of 
context-specific solutions  and the integration of gender considerations across all EU 
funding  mechanisms.  The  data  indicates  a  significant  concern  over  administrative 
burdens and the effectiveness of current gender equality measures. Another significant 
hurdle is the perception of Gender Equality Plans as ‘box-ticking exercises’ that lack 
substantial  impact.  Furthermore,  the  data  points  to  structural  issues  such  as 
"geographical  isolation,  depopulation,  and  limited  economic  diversification",  which 
disproportionately affect women in certain regions. Stakeholders also advocate for the 
integration of "intersectionality" into gender equality  initiatives i.e. considering how 
various social identities, such as ethnicity, age, and sexual orientation, intersect with 
gender to create unique experiences of discrimination and disadvantage. A recurring 
theme  is  the  tension  between  the  need  for  comprehensive  data  collection  and  the 
administrative burden it imposes, while a number of respondents emphasised the need 
for inclusivity in gender data collection including to capture data related to non-binary 
and transgender individuals. Many stakeholders argue for a more streamlined approach 
that  balances  the  need  for  accountability  with  practical  implementation  as  well  as 
gender-responsive  budgeting  and  capacity  building  for  managing  authorities  and 
programme stakeholders. Additionally, there is a call for greater involvement of civil 
society and equality bodies in the planning and oversight of gender equality initiatives, 
suggesting  a  collaborative  approach  could  enhance  the  effectiveness  of  EU-funded 
projects.  There  is  a  call  for  "dedicated  funding"  for  gender  equality  projects  and 
policies.  Stakeholders  also  emphasise 
importance  of  "monitoring  and 
accountability"  mechanisms  to  track  the  progress  and  impact  of  gender  equality 
initiatives.  Respondents  further  place  emphasis  on  dedicating  specific  funding  to 
Women's Rights Organizations. 

the 

-  Promotion of the principle of ‘do no significant harm’  to climate and environmental 
objectives across the EU budget: the responses to the consultation identify a number of 
challenges and recommendations related to the implementation of the DNSH principle. 
Stakeholders  provided  insights  into  the  challenges  and  potential  solutions  for 
effectively integrating the DNSH principle into EU funding mechanisms. The primary 
hurdles  identified  include  excessive  administrative  burdens,  inconsistent  application 
across programmes, and a lack of clear guidance. Stakeholders argue that the current 
compliance  demands  are  overly  complex  and  discourage  participation,  particularly 

54 

 
 
 
from small and medium-sized enterprises (SMEs) and local entities. At the same time, 
several respondents highlighted the need to maintain the "DNSH horizontal principle 
as a mandatory requirement" for the green transition. In response, stakeholders have 
suggested a range of actions, such as the need for a more consistent and harmonised 
application of the DNSH principle across all EU programs and funding mechanisms 
through a single, harmonised DNSH guidance with an evidence-based exclusion list, 
simplifying  documentation  and  compliance  processes,  providing  sector-specific 
guidelines,  and  enhancing  training  and  capacity-building  efforts.  Stakeholders  have 
also advocated for the development of clear and ambitious exclusion lists to prevent 
inherently harmful projects from receiving EU funding, excluding funding for activities 
that undermine climate and biodiversity goals, such as nuclear power and fossil fuels. 
A number of stakeholders also recommended the integration of DNSH into the entire 
project  lifecycle,  with  robust  monitoring  and  reporting  mechanisms.  The  analysis 
highlights  both  areas  of  consensus  and  divergence  among  stakeholders,  with  some 
advocating  for  more  stringent  enforcement  and  others  calling  for  greater  flexibility. 
Responses by stakeholders further reflect a divergence in opinions regarding a potential 
expansion of the DNSH principle to include social and economic dimensions, though a 
number of stakeholders recommended a human rights-based, intersectional approach to 
DNSH. 

-  Promotion of horizontal priorities across the EU budget: Stakeholders emphasise the 
importance  of  aligning  EU  funding  with  strategic  priorities  such  as  climate  action, 
digital  transformation,  and  social  equity.  Several  respondents  the  systematic 
mainstreaming of climate and gender equality across EU budget programmes. 

for  simplification  while  maintaining 

-  Monitoring how effectively the EU budget is achieving its objectives, including through 
indicators: various stakeholders provided contributions on the effectiveness of the EU 
budget monitoring system, particularly its reliance on indicators. A recurring theme is 
excessive  bureaucratic  requirements,  administrative  burden  and  complexities 
associated with the collection and reporting of indicators under EU funds, particularly 
from smaller entities. Several respondents highlighted the need to balance flexibility 
with  accountability,  calling 
rigorous 
accountability standards, and including suggestions for introducing consequences for 
underperformance alongside incentives for success. Respondents regretted the lack of 
standardisation and coherence across different EU funds, creating significant hurdles. 
Stakeholders also raised the issue of overemphasis on output indicators and inadequacy 
of current indicators to capture the true impact of EU funds, particularly in areas like 
environmental protection and social inclusion, and the need to shift towards assessing 
outcomes and long-term impacts. Many stakeholders pointed to issues such as lack of 
granularity,  enforcement,  and  the  exclusion  of  negative  impacts.  These  hurdles  are 
interlinked  with  the  actions  proposed,  which  often  call  for  methodological 
improvements  and  greater  alignment  with  policy  objectives.  Stakeholders  from 
Germany, Belgium, and other EU countries have highlighted the disconnect between 
the indicators used and the actual outcomes they are meant to measure. This disconnect 
is often attributed to the complexity and lack of specificity in the indicators, which can 

55 

 
 
 
 
lead to administrative burdens and a failure to capture qualitative outcomes.  Several 
respondents also highlighted challenges linked to performance-based payments and the 
risks associated with unclear achievement criteria. Stakeholders from various sectors, 
including public institutions, private companies, and civil society organizations, have 
expressed  concerns  about  the  current  framework's  ability  to  effectively  support 
innovation and address emerging priorities. In response, proposed actions emphasise 
the need for simplification, flexibility,  and a more tailored approach to  performance 
evaluation.  Several  stakeholders  call  for  harmonisation  of  rules  across  different  EU 
funds. The actions proposed by stakeholders frequently emphasise the need for a more 
integrated  and  transparent  approach,  with  calls  for  the  inclusion  of  qualitative 
assessments and the alignment of indicators with broader EU objectives. Respondents 
further highlighted the need to involve local and regional stakeholders in the design and 
implementation  of  performance  frameworks,  suggesting  this  as  a  means  to  increase 
transparency  and  accountability.  A  number  of  stakeholders  emphasised  the  need  for 
improved  data  collection  and  digitalized  reporting  systems  for  evidence-based 
evaluations, and recommended the development of a single audit system to streamline 
processes and ensure consistent standards. Some respondents stressed the importance 
of enhanced transparency and feedback loops to incorporate lessons learned into future 
policy designs. Some stakeholders also highlighted the need for flexibility in the choice 
of  indicators  to  better  reflect  sectoral  and  regional  specificities,  and  the  need  for 
indicators to better reflect the need to support socially vulnerable groups. 

-  Access to funding: several stakeholders called for a centralised, multilingual portal to 
enhance  transparency  and  accessibility  of  funding  information.  Respondents  further 
recommended making EU funding mechanisms accessible and inclusive, particularly 
for marginalized communities. 

Stakeholders provided additional elements to the problem definition, in particular regarding 
the need for stakeholders involvement in performance processes as well as emphasising the 
need for capacity building.  

The legal proposal developed as a result of this initiative – i.e. a horizontal regulation on budget 
performance – built upon the results of the Open Public Consultation by addressing several of 
the key concerns expressed by stakeholders. This includes strengthening the EU budget legal 
framework to ensure consistent and proportionate implementation of the gender equality and 
DNSH principles, while ensuring the effective mainstreaming of green and social priorities. 
This also includes streamlining the monitoring framework of the EU budget with a view to 
increasing  the  ability  to  measure  the  EU  budget  performance  while  limiting  administrative 
burden. 

56 

 
 
 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

This annex explains the practical implications of a single performance framework applying at 
EU  budget  level,  based  on  implementation  of  the  preferred  policy  option  as  described  in 
Section 8 of the main impact assessment report. 

1.  Practical implications of the initiative 

The initiative aims at developing a simplified, coherent and flexible performance framework 
for the post-2027 Multiannual  Financial  Framework, enabling to  achieve simplification and 
reduce  administrative  burden  and  costs  affecting  EU  budget  beneficiaries,  Member  States, 
partner countries, implementing partners and EU institutions. 

The single performance framework would have the following key practical implications: 

For  EU  budget  beneficiaries  (including  businesses),  Member  States,  partner  countries  and 
implementing partners: 

The initiative is expected to achieve cost reductions linked to the development of: 

- 

- 

a single guidance on the application of the DNSH principle, including criteria following 
a single activity-based approach applying to the entire budget i.e. Member States and 
beneficiaries such as businesses would achieve a reduction of the resources currently 
required  to  apply  the  multiple  DNSH  guidances  and  sometimes  contradictory 
requirements, enabling to achieve higher predictability of projects implementation and 
facilitating access to EU funding; 

a harmonised classification of activities financed by the EU budget – so as to enable 
simple  tracking  of  expenditures  through  intervention  fields  –  and  a  simplified  and 
standardised set of performance indicators at MFF level i.e. Member States managing 
authorities  would  reduce  resources  currently  allocated  to  dealing  with  multiple 
expenditure tracking and indicators monitoring systems. The reduction of the number 
of performance indicators would enable beneficiaries, including businesses, to face less 
reporting burden and therefore to reduce the costs associated with project monitoring; 

-  harmonised  requirements  on  performance  reporting,  consolidating  all  EU  budget 
performance  information  into  the  Annual  Management  Performance  Report,  which 
would  enable  Member  States,  budgetary  authorities  and  interested  stakeholders  to 
reduce the costs currently allocated to having to navigate and process multiple reports 
on the performance of EU budget programmes; 

- 

a  single  online  portal  displaying  EU  budget  performance  information  would  enable 
Member  States,  partner  countries  and  beneficiaries  to  reduce  the  costs  currently 
allocated to having to navigate and process multiple dashboards. Businesses – such as 
SMEs  are particularly expected to benefit from such a single entry point, potentially 
improving access  to  EU funds.  The  single portal would also  provide information  on 
available  funding  opportunities  centralising  all  information  under  the  EU  budget, 
enabling  Member  States,  partner  countries  and  beneficiaries  to  reduce  the  costs 

57 

 
 
currently  allocated  to  having  to  navigate  and  process  multiple  portals.  A  2024 
Commission  STEP  taskforce  survey  on  ‘Access  to  EU  funding  –  users  perspective’ 
shows that 72% of respondents indicated that they would see value in a one-stop-shop 
combining EU and national funding. 

For EU institutions: 

The initiative would enable to achieve cost reductions linked to the development of: 

- 

- 

a single guidance on the application of the DNSH principle, including criteria following 
a single activity-based approach applying to the entire budget i.e. EU institutions – in 
particular  the  Commission  –  would  achieve  a  reduction  of  the  resources  currently 
required to develop and implement the multiple DNSH guidances, reducing the need 
for  providing  capacity  building  and  technical  support  to  Member  States  and 
beneficiaries to implement DNSH; 

a harmonised classification of activities financed by the EU budget – so as to enable 
simple  tracking  of  expenditures  through  intervention  fields  –  and  a  simplified  and 
standardised  set  of  performance  indicators  at  MFF  level  i.e.  EU  institutions  –  in 
particular the Commission – would reduce resources currently allocated to calculating 
and  aggregating  expenditures  based  on  multiple  tracking  methodologies,  as  the  new 
system  would  be  simpler  yet  enabling  to  track  contributions  to  several  priorities,  as 
relevant. The streamlining of the existing  – multiple, and sometimes overly heavy  – 
indicators monitoring systems; 

-  harmonised  requirements  on  performance  reporting,  consolidating  all  EU  budget 
performance  information  into  the  Annual  Management  Performance  Report,  which 
would  enable  the  Commission  to  achieve  efficiency  gains  and  reduce  the  resources 
allocated to preparing such reports, removing duplication of information and reporting 
processes. It would also enable other EU institutions – e.g. European Parliament – to 
reduce the costs currently allocated to having to navigate and process multiple reports 
on  the  performance  of  EU  budget  programmes.  The  new  system  would  provide 
comprehensive  insights  into  EU  budget  performance,  promoting  transparency  and 
efficient data utilization for policy decisions; 

- 

a single online portal displaying information on EU budget performance and available 
funding opportunities centralising all information under the EU budget,  enabling the 
Commission  to  reduce  the  costs  currently  allocated  to  the  management  of  multiple 
dashboards and portals. 

The initiative would nonetheless trigger initial one-off costs linked to the development of the 
above-mentioned tools and components as part of the new harmonised performance framework 
e.g. the development of the IT infrastructure necessary to run the new single dashboard and 
portal. Adapting to the new provisions is also likely to generate transition costs linked to the 
phase of stakeholders adapting to the new system. Such entry costs are expected to affect EU 
institutions  as  well  as  beneficiaries  (including  potential  compliance  costs  for  businesses), 
Member States, partner countries and implementing partners. 

58 

 
 
Example:  indicators  on  renewable  energy  (additional  capacity)  for  which  EU  budget 
beneficiaries, Member States, partner countries and implementing partners would benefit from 
harmonisation across MFF programmes so as to allow for simplification and aggregation of 
performance data at EU budget level 

Programme  
Recovery and 
Resilience Facility 

European Regional 
Development Fund 
(ERDF) 

InvestEU 

Regional Policy 
(European Regional 
and Development 
Fund and Cohesion 
Fund) 

Indicator 
Additional operational capacity installed for renewable 
energy 

Measurement 

Megawatts (MW) 

Additional capacity of renewable energy production 

Megawatts (MW) 

Additional renewable and other safe and sustainable 
zero and low-emission energy generation capacity 
installed 

Megawatts (MW) 

Additional renewable energy produced 

MWh/year 

2.  Summary of costs and benefits 

The  estimates  of  the  expected  costs  and  benefits  are  partial  given  the  lack  of  available 
quantitative data on costs associated with the administrative burden that EU institutions, EU 
budget beneficiaries, Member States, partner countries and implementing partners are facing 
in  terms  of  monitoring,  reporting  and  communicating  performance  of  the  EU  budget  and 
specific  programmes,  and  complying  with  a  number  of  requirements  e.g.  regarding 
implementation  of  the  Do  No  Significant  Harm  principle.  The  methodology  used  for 
calculating the costs of each policy option is presented under Annex 9. 

I. Overview of Benefits (total for all provisions) – Preferred Option 

Amount 

Direct benefits 

Comments 

EUR 85,5 million 

Description 

P2: Reduction of 
administrative burden 
resulting from the 
simplification of DNSH 
requirements, compared to a 
programme-specific 
approach requiring 
compliance with several 
different DNSH guidance 
and systems, sometimes for 
the same type of projects 

M3: Reduction of 
administrative burden as a 
result of simplifying 

EUR 700,6 million 

59 

Member States administrations (reduction 
of administrative burden linked to 
operationalization tasks such as: 
contribution to the design of DNSH 
guidance at EU level, transposing EU level 
guidance into national systems, providing 
guidance and training to national 
stakeholders and beneficiaries, checks of 
DNSH compliance, developing national 
assessment tools, as well as reporting and 
coordination of implementation at EU 
level) 

Member State administrations (reduction of 
administrative burden linked to 
operationalization tasks such as: 

 
 
 
expenditure tracking and 
indicator monitoring 
requirements,  compared to 
the current programme-
specific approach, which 
relies on a large number of 
indicators under the various 
EU budget programmes. 

R2: Reduction of costs 
linked to the development 
and management of 
performance dashboards  

R2: Reduction of costs 
linked to the development 
and management of portals 
on funding opportunities  

P2, M3, R2: Indirect 
benefits from expected 
reduction of administrative 
burden 

contributing to the design and management 
of indicators at EU level, transposing EU 
level indicators system into national 
systems, data collection and management at 
national level, data verification, providing 
guidance and training to national 
stakeholders and beneficiaries having to 
report against such indicators, developing 
national tools and systems, reporting and 
coordination of implementation at EU 
level) 

Commission (reduction of costs as a result of 
merging  dashboards  into  a  single  one, 
compared to maintaining the current system 
which 
20 
relies 
performance dashboards) 

approximately 

on 

Commission (reduction of costs as a result of 
merging existing portals into one compared 
to  maintaining  the  current  system  which 
relies  upon  ca.  12  portals  on  funding 
opportunities) 

EUR 24,6 million 

EUR 32 million 

Indirect benefits 

Could not be costed due to lack of available data  Implementing  partners,  third  countries  and 

beneficiaries 

(1)  Estimates  are  gross  values  relative  to  the  baseline  for  the  preferred  option  as  a  whole  (i.e.  the  impact  of 
individual  actions/obligations  of  the  preferred  option  are  aggregated  together);  (2)  Please  indicate  in  the 
comments column which stakeholder group is the main recipient of the benefit;(3) For reductions in regulatory 
costs, please describe in the comments column the details as to how the saving arises (e.g. reductions in adjustment 
costs, administrative costs, regulatory charges, enforcement costs, etc.;);.  

II. Overview of costs – Preferred option 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct 
administrative 
costs 

Could not be costed due to lack of available data 

Could not be costed due to lack of available data 

EUR 8,5 
million 

EUR 210,2 
million 

P2: 
activity-
based 
approach 
to DNSH 

M3: single 
expenditur
e  tracking 
and 
indicator 
monitorin
g 

60 

 
 
 
 
 
 
 
 
 
R2: Single 
performan
ce portal 

R2: Single 
portal  on 
funding 
opportunit
ies 

Could not be costed due to lack of available data 

Could not be costed due to lack of available data 

EUR 1,3 
million 

EUR 3 
million 

(1)  Estimates (gross values)  to be provided with respect to the  baseline; (2) costs are provided for each 
identifiable action/obligation of the preferred option otherwise for all retained options when no preferred 
option is specified; (3) If relevant and available, please present information on costs according to the 
standard  typology  of  costs  (adjustment  costs,  administrative  costs,  regulatory  charges,  enforcement 
costs, indirect costs;).  

The  total  benefits  of  the  initiative  are  estimated  at  EUR  842,7  Mio  and  the  total  costs  are 
estimated at  EUR 220  Mio.  The initiative would therefore  result in  total  net  benefits  of EUR 
622,6 Mio. 

III. Application of the ‘one in, one out’ approach – Preferred option(s) 

One-off 

Recurrent 

Total 

[M€] 

(annualised total net present 
value over the relevant period) 

(nominal values per year) 

Businesses 

New administrative 
burdens (INs) 

Removed administrative 
burdens (OUTs) 

Cf. section II 

Net administrative 
burdens* 

Adjustment costs** 

Citizens 

New administrative 
burdens (INs) 

Removed administrative 
burdens (OUTs) 

Net administrative 
burdens* 

Adjustment costs** 

Total administrative 
burdens*** 

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(*) Net administrative burdens = INs – OUTs;  
(**) Adjustment costs falling under the scope of the OIOO approach are the same as reported in Table 2 above. Non-
annualised values;  
(***) Total administrative burdens = Net administrative burdens for businesses + net administrative burdens for citizens. 

3.  Relevant sustainable development goals 

The  preferred  policy  option  is  expected  to  contribute  to  most  SDGs  since  it  is  expected  to 
improve the effectiveness, efficiency and EU added-value of all EU budget programmes and 
their contribution to several SDGs. Specific contributions are also expected towards SDGs 5, 
13 and 15. 

IV. Overview of relevant Sustainable Development Goals – Preferred Option(s) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG  5  –  Achieve  gender 
equality  and  empower  all 
women and girls 

Increase in EU budget support to gender equality  The  new  gender  provisions  will  support  the 
systematic  mainstreaming  of  gender  across 
EU budget programmes 

Improved  tracking  of  EU  budget  expenditures 
contributing to climate action 

Improved  tracking  of  EU  budget  expenditures 
contributing to biodiversity 

The  new  tracking  system  will  enabling  to 
monitor  contributions 
to  both  climate 
mitigation and adaptation 

The  new  tracking  system  will  enabling  to 
monitor contributions to biodiversity both on 
land and at seas (thereby also contributing to 
SDG 14) 

SDG 13 – Take urgent action 
to  combat  climate  change 
and its impacts 

SDG 15 - Protect, restore and 
promote  sustainable  use  of 
terrestrial 
ecosystems, 
sustainably  manage  forests, 
combat  desertification,  and 
land 
and 
halt 
degradation 
halt 
biodiversity loss 

reverse 
and 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
63 

 
 
 
 
ANNEX 4: SME CHECK 

Based on interservice group discussions, this initiative is relevant for SMEs. 

1.  Identification of affected businesses and assessment of relevance 

Are  SMEs  directly  affected? 
(Yes/No) In which sectors? 

Estimated  number  of  directly 
affected SMEs 

Yes – in all sectors supported by EU budget programmes e.g. 
agriculture,  rural  development,  research  and  innovation, 
regional development, environment and climate action, digital 
transformation,  culture  and  creative  industries,  education  and 
youth, transport and energy infrastructure, health 

ca.  16,3  million60  (the  exact  number  is  not  available,  but  the 
initiative  will  precisely  enable  to  aggregate  performance  data 
on  e.g.  the  number  of  SMEs  supported  across  all  EU  budget 
programmes, which is not possible in the 2021-2027 period) 

Estimated number of employees 
in directly affected SMEs 

ca. 59,4 million61 

Are  SMEs  indirectly  affected? 
(Yes/No) In which sectors? What 
is  the  estimated  number  of 
indirectly  affected  SMEs  and 
employees? 

Yes – in all sectors supported by EU budget programmes, as 
projects  supported  by  the  EU  budget  and  promoted  by  other 
types of beneficiaries are also likely to have impacts for SMEs 

60 This estimate is calculated, using the number of SMEs in the 2021-2027 and 2014-2020 EU budget – MFF and 
RRF – as a proxy for the post-2027 budget. This estimate is derived from the Financial Transparency System, 
which estimates that 26148,32 private companies were supported by direct and indirect management programmes 
in 2023, from data on the number of beneficiaries of the CAP (Europa website, Beneficiaries of CAP funds) and 
a  2018  European  Commission  report  which  noted  that  93%  of  EU  farms  are  classified  as  SMEs  based  on 
employment and turnover criteria, and from the 9th Cohesion Report (2024), which states that Cohesion Policy 
supported over  4.4  million  businesses  during  2014–2020, as  well  as  the  Implementation  of  the  Recovery  and 
Resilience Facility report (COM(2023)545), which states that by December 2022, the RRF had supported 1.43 
million enterprises. The estimate also takes into account Eurostat’s Structural Business Statistics, which shows 
that 99,8% of EU companies are SMEs. This estimate is likely to be an underestimate as it does not include the 
number of SMEs supported by other EU funds. 
61 This estimate is calculated based on the 9th Cohesion Report (2024), which estimates the total number of SME 
employees at 83.3 million and the total number of SMEs at 22.8 million i.e. 3.65 employees per SME on average. 

64 

 
 
 
 
 
 
2.  Consultation of SME stakeholders 

How has the input from the SME 
community  been 
into 
consideration 

taken 

The  input  from  the  SME  community  has  been  taken  into 
consideration  through  an  Open  Public  Consultations  on  the 
post-2027  MFF,  including  a  dedicated  consultation  on  the 
performance of the EU budget, running from 12 February 2025 
to 6 May 2025. The consultation received several contributions 
from companies and businesses, including SMEs, which were 
integrated  into  the  initiative.  The  SME  community  was  also 
indirectly consulted via the European Citizens Panel on a new 
EU  Budget,  which  made  recommendations  on  the  need  to 
support  SMEs  and  the  need  to  simplify  administrative 
procedures linked to EU budget programmes, which is one of 
the objectives of the initiative. 

Are SMEs’ views different from 
those of large businesses? 

Information not available as the OPC results do not differentiate 
between SMEs and other businesses. 

3.  Assessment of impacts on SMEs62 

What  are  the  estimated  direct 
costs for SMEs of the preferred 
policy option? 

What  are  the  estimated  direct 
benefits/cost savings for SMEs of 
the preferred policy option 

SMEs supported by EU budget programmes are likely to face 
limited  entry  costs  linked  to  transitioning  to  the  new 
reporting 
performance 
performance  based  on  partly  new  indicators,  new  DNSH  and 
gender mainstreaming provisions, new single portal on funding 
opportunities. 

framework  e.g.  monitoring  and 

initiative 

The preferred policy option is expected to generate significant 
cost  savings  linked  to  the  reduction  of  compliance  and 
administrative  costs  by  SMEs  supported  by  EU  budget 
foresees  a  calibrated  and 
programmes.  The 
proportionate approach to implementing the DNSH principle, 
which will facilitate compliance by SMEs, in particular as the 
initiative  foresees  exempting  certain  projects  from  DNSH 
checks  i.e.  in  the  fields  of  defence  and  security.  The 
simplification  of  performance  monitoring  provisions  and  the 
reduction  of the number  of  indicators  would enable  SMEs to 
face less reporting burden and reduce the costs associated with 
project  monitoring.  A  single  online  portal  displaying 
information on available funding opportunities is also expected 
to help SMEs to reduce the costs currently allocated to having 
to navigate and process multiple portals, ultimately facilitating 
access to EU funds by SMEs in key economic sectors. Overall 
the initiative will have a particularly positive impact on SMEs, 
which often operate with limited staff and resources and can be 
disproportionately  affected  by  the  complexity  of  monitoring 
and  reporting  requirements  under  EU  funds.  The  preferred 

62 This section summarizes impacts on SMEs from a qualitative perspective, as no quantitative information was 
available.  

65 

 
 
 
 
policy  option  will  therefore  enable  SMEs  to  become  more 
responsive  to  new  support  opportunities  under  EU  budget 
programmes (cf. section 6 of the impact assessment for more 
details). 

The  harmonised  performance  framework  of  the  post-2027 
budget will also enable to better assess the impacts of the EU 
budget  on  SMEs,  as  the  monitoring  system  would  enable  to 
assess how many SMEs are supported by the EU budget as well 
as other SME-relevant performance information.  

4.  Minimising negative impacts on SMEs 

SMEs are not expected to be disproportionately affected by the 
initiative compared to large companies. 

Are  SMEs  disproportionately 
large 
affected  compared 
companies? (Yes/No) 

to 

If  yes,  are  there  any  specific 
subgroups  of  SMEs  more 
exposed than others? 

5.  Contribution to the 35% burden reduction target for SMEs 

Are  there  any  administrative 
cost  savings  relevant  for  the 
35% burden reduction target for 
SMEs? 

The  preferred  policy  option  is  expected  to  significantly 
contribute to the Commission commitment to streamline rules 
and reduce the administrative burdens by 35% for SMEs by the 
end of the current mandate. 

66 

 
 
 
 
 
 
 
ANNEX 5: COMPETITIVENESS CHECK 

1.  Overview of impacts on competitiveness 

Dimensions of 
Competitiveness 

Impact of the initiative (++ / 
+ / 0 / - / -- / n.a.)  

References to sub-sections of 
the main report or annexes 

Cost and price competitiveness  ++ 

International competitiveness 

+ 

Capacity to innovate 

SME competitiveness 

n.a. 

++ 

2.  Synthetic assessment 

Sections 6, 7 and 8 
Annexes 3 and 9 
Section 6 

Sections 6, 7 and 8 
Annexes 3 and 9 

The  preferred  policy  option  is  expected  to  have  a  positive  impact  on  cost  and  price 
competitiveness,  as  it  is  expected  to  result  in  significant  reductions  of  compliance  and 
administrative  costs  at  the  level  of  EU  budget  beneficiaries  such  as  businesses,  enabling  to 
support the competitiveness of the economic sectors supported by EU budget programmes, in 
line with the initiative’s specific objective of a reduction of such administrative burden by at 
least 25%63. The initiative foresees a calibrated and proportionate approach to implementing 
the DNSH principle, which will facilitate compliance by businesses, ultimately supporting cost 
and  price  competitiveness  of  companies  supported  by  EU  funds.  The  simplification  of 
performance monitoring provisions and the reduction of the number of indicators would enable 
enterprises  to  face  less  reporting  burden  and  reduce  the  costs  associated  with  project 
monitoring. A single online portal displaying information on available funding opportunities 
is also expected to help businesses to reduce the costs currently allocated to having to navigate 
and process multiple portals, ultimately facilitating access to EU funds by beneficiaries in key 
economic  sectors.  The  quantitative  analysis  presented  under  Annex  9  focuses  on  expected 
reductions  of  costs  for  Member  States  authorities  and  the  Commission  due  to  a  lack  of 
quantitative data on impacts on beneficiaries such as businesses, but the initiative is expected 
to  generate  significant  cost  savings  and  efficiency  gains  for  beneficiaries  in  key  economic 
sectors. 

The  initiative  is  similarly  expected  to  have  a  limited  but  positive  impact  on  international 
competitiveness,  improving  the  competitive  position  of  EU  firms  supported  by  EU  budget 
programmes  compared  to  non-EU  competitors.  For  the  above-mentioned  reasons,  EU 
companies  would  be  facing  less  administrative  burden  associated  with  mainstreaming, 
monitoring  and  reporting  provisions,  improving  their  position  vis-à-vis  third  countries 
enterprises. This assessment should nonetheless be nuanced as the initiative will also apply to 
non-EU  companies  supported  by  EU  budget  programmes  e.g.  under  external  action  funds, 
meaning that such companies would equally benefit from the new performance framework. 

63 In line with the Communication target of reducing burdens associated with reporting requirements by 25% 

67 

 
 
 
 
 
While the initiative is not expected to have any significant impact on businesses capacity to 
innovate,  the  reductions  in  administrative  costs  expected  from  the  initiative  may  enable 
businesses to free up resources to the benefit of increased resources dedicated to innovation.  

The initiative will also have a particularly positive impact on SMEs, which often operate with 
limited staff and resources and can be disproportionately affected by the complexity of existing 
monitoring  and  reporting  requirements  under  EU  funds,  and  of  EU  portals  displaying 
information on funding opportunities, therefore enabling SMEs to become more responsive to 
new support opportunities under EU budget programmes. The initiative is particularly expected 
to contribute to the Commission commitment to streamline rules and reduce the administrative 
burdens  by  35%  for  SMEs  by  the  end  of  the  current  mandate.  The  future  performance 
framework will also enable to measure e.g. how many SMEs are supported by the EU budget 
overall, which is currently very challenging  as indicators differ from one programme to the 
other, making aggregation of data difficult. 

3.  Competitive position of the most affected sectors 

The  initiative  is  expected  to  have  positive  effects  on  the  competitiveness  of  all  sectors 
supported by EU budget programmes, since the new performance framework will apply to all 
EU funds. Affected sectors include e.g. agriculture, rural development, regional development, 
environment and climate action, research and innovation, digital transformation, culture and 
creative industries, education and youth, transport and energy infrastructure, health. 

As indicated above, a quantitative analysis of impacts on businesses supported by EU budget 
programmes could not be carried out due to a lack of available data. 

68 

 
 
 
 
 
ANNEX 6: POLICY MAINSTREAMING AND PROGRAMMING 
ARCHITECTURE OF THE 2021-2027 BUDGET 

6.1 Climate and biodiversity mainstreaming 

Since 2014, the EU budget has increased its support for climate objectives by mainstreaming 
climate  across  all  the  relevant  MFF  programmes.64  Mainstreaming  entails  embedding 
horizontal policy goals into all phases of the policy cycle of the relevant programmes, including 
preparation, design,  programming,  implementation,  monitoring and  evaluation. This  means, 
for example, that instead of establishing a separate and dedicated fund for climate and energy 
objectives,  these  policies  priorities  can  be  integrated  into  existing  EU  funds,  such  as  the 
cohesion  funds.  Since  2021,  this  mainstreaming  approach  has  also  been  extended  to 
biodiversity65. A more advanced approach – ‘green budgeting’ – has also been adopted in the 
EU budget as part of the increased emphasis on impact and performance in the current MFF. 

The mainstreaming approach has been further complemented with the inclusion of budgetary 
targets,  first  at  EU  budget  level,  and  then  at  programme  level.  Under  the  inter-institutional 
agreement  (IIA)  accompanying  the  2021-2027  Multiannual  Financial  Framework,  the 
European Parliament, the Council and the Commission agreed to allocate at least 30% of all 
resources  available  under 
the  2021-2027  Multiannual  Financial  Framework  and 
NextGenerationEU  to  measures  addressing  climate  change,  and  to  support  biodiversity 
objectives with 7.5% of annual spending in 2024, and 10% in 2026-2027.66 This approach has 
effectively raised the climate and biodiversity focus of MFF programmes under the EU budget 
– although the level of success varies across programmes and priorities.  

Budget earmarking – and target setting in particular – is only one of the elements of a wider 
‘mainstreaming toolbox’ aimed at reinforcing climate and biodiversity objectives within  the 
EU  budget.  The  EU  budget’s  contribution  to  climate  and  biodiversity  objectives  ultimately 
depends on how effectively these various tools are integrated and coordinated. 

Several tools were embedded in the design of 2021-2027 EU budget programmes to strengthen 
their  contribution  to  the  EU’s  green  objectives.  For  instance,  the  green  architecture  of  the 
Common Agriculture Policy was reinforced. ‘Eco-schemes’ were introduced in the Common 
Agricultural  Policy67  to  encourage  farmers  to  adopt  greener  farming  practices  by  providing 
additional income support, in addition to a wide range of tools, including agri-environmental-
climate measures, green investments and Natura 2000 payments. In Horizon Europe, thematic 
clusters68 – such as the cluster on ‘Climate, Energy, and Mobility’ and the ‘Clean Hydrogen 
Partnership’  –  complement  the  programme’s  bottom-up  approach  by  steering  research  and 
innovation  efforts  towards  environmental  goals.  Within  Cohesion  policy  funds,  thematic 

64https://eur-lex.europa.eu/resource.html?uri=cellar:d0e5c248-4e35-450f-8e30-
3472afbc7a7e.0011.02/DOC_4&format=PDF  
65  Interinstitutional  Agreement  of  16  December  2020  between  the  European  Parliament,  the  Council  of  the 
European Union and the European Commission on budgetary discipline, on cooperation in budgetary matters and 
on sound financial management, as well as on new own resources, including a roadmap towards the introduction 
of new own resources 
66 Ibid. 
67 Regulation - 2021/2115 - EN - EUR-Lex 
68 Regulation - 2021/695 - EN - EUR-Lex 

69 

 
 
 
enabling conditions for climate and biodiversity ensure that the right frameworks are in place 
to  maximize  the  impact  of  green  investments.69  InvestEU  supports  green  objectives  mainly 
through its dedicated sustainable infrastructure window70. In addition, a number of programmes 
were  introduced  with  the  primary  objective  of  addressing  various  dimensions  of  green 
priorities, such as the Modernisation Fund71 and the Social Climate Fund72. 

An overview of the different tools available and their application across funds are presented in 
Tables 1 and 2.  

69 Regulation - 2021/1060 - EN - EUR-Lex 
70 Regulation - 2021/523 - EN - EUR-Lex 
71 EUR-Lex - 02003L0087-20240301 - EN - EUR-Lex 
72 Regulation - 2023/955 - EN - EUR-Lex 

70 

 
 
 
Table: Green policy mainstreaming elements in the 2021-2027 MFF programmes 

Programme 

% 
climate 
achieved  2014-
2020/projected 
2021-2027 

biodiversity 
2014-

% 
achieved 
2020/projected 
2021-2027 

Green mainstreaming elements 

Horizon Europe 

30% (35% target) 

5% 

Legal basis and earmarking 

35% 

8% 

-  35% climate target (recital) 
-  Earmarking of budget for clusters (e.g. “energy, climate, transport” cluster) 

Governance 

-  Horizon Europe Strategic Plan ensuring follow up on the 35% climate target  
-  10% of total Horizon Europe budget for 2025-2027 dedicated to biodiversity (Strategic 

Plan) 

Policy design 

-  Missions on climate adaptation; climate neutral cities; restore our ocean and waters; 
- 
Joint undertakings on: Circular Bio-based Europe; Clean Aviation; Clean Hydrogen; 
Europe’s Rail; Single European Sky ATM Research;  

-  EIT cluster on urban mobility; climate change; future of food; sustainable energy; raw 

materials; 

-  Screening of topics for DNSH compliance (Article 5 (2) (p)) 
-  Climate proofing integrated on a topic-by-topic basis (i.e. infrastructures and 

innovation projects) 

71 

 
 
 
 
 
 
Euratom 
Research 
Training 
Programme 

and 

0%  (fusion  not 
of 
part 
methodology) 

0 

0 

35% 

International 
Thermonuclear 
Experimental 
Reactor (ITER) 

InvestEU 

0%  (fusion  not 
part 
of 
methodology) 

0 

0 

100% 

0%  

30% 

0 

0 

-  Climate related enabling conditions are inherent in program calls focusing on 

environmental sustainability and innovation. 

-  Biodiversity tracking by a handbook to facilitate attribution of markers to biodiversity 

relevant projects. 

Legal basis and earmarking 

-  Earmarking of budget towards fusion research objective 

Legal basis and earmarking 

-  30% climate target (recital) 
-  60% of investments under “sustainable infrastructure” policy window budget 

earmarked for climate and environment 

Policy design 

-  Exclusion list of activities (Annex Vb) 
-  Sustainability proofing (guidance of Commission takes into account DNSH) 
-  Projects that fall under the Environmental Impact Assessment Directive need to be 
screened regardless the total project cost and proofing performed, if necessary 

72 

 
 
 
  
 
Integration of the EU taxonomy framework where possible 

- 
-  Dedicated scheme for just transition territories 
-  Climate and environment tracking of expenditures (assess whether InvestEU 

operations contribute to green objectives) 

Connecting 
Europe  Facility 
(CEF),  including 
Military Mobility 

71% 

0 

Legal basis and earmarking 

77% (60% target) 

0 

-  60% climate target (recital and article 4) 
-  Decarbonization of energy sector objective; sustainable transport objective 
-  Earmarking per objective 
-  Methodology in the recital 

Policy design 

-  Environmental Impact assessment 
-  Reporting for Trans-European Network for Energy and assessment during the 
procurement process for Trans-European Networks for Transport with DNSH 

-  Screening of projects (energy and transport) during selection phase 
-  Climate proofing for infrastructure projects 

Digital 
Programme 

Europe 

0 

4% 

Single  Market 
Programme 

4% (COSME) 

4% 

0 

0 

0 

0 

No specific provisions 

No specific provisions 

73 

 
 
 
 
 
 
35% (Copernicus) 

6% 

Policy design 

European  Space 
Programme 

Secure 

EU 
Connectivity 
Programme 

35% 

NA 

Regional  Policy 
Funds (ERDF and 
Cohesion) 

20% 

35% 

6% 

NA 

4% 

6% 

-  Copernicus monitoring contributes to both mitigation and adaptation efforts 

No specific provisions in place 

Legal basis and earmarking 

-  At least 30% for ERDF and 37% for CF (Recital 6 ERDF and CF Regulation). 
-  Art 5 “a greener, low-carbon transitioning towards a net zero carbon economy and 
resilient Europe by promoting clean and fair energy transition, green and blue 
investment, the circular economy, climate change mitigation and adaptation, risk 
prevention and management, and sustainable urban mobility;” policy objective  
-  For ERDF, all regions and Member States must concentrate at least 30% of their 

allocation to PO2 (greener, low-carbon transitioning towards net zero carbon economy 
and resilient Europe) 

-  Art 6 “climate target adjustment mechanism”  
-  Art 15 “enabling conditions” (i.e. in water, waste and circular economy and nature / 

- 

biodiversity) 
“do no significant harm” should be taken into account (applied by the national 
authorities in the assessment of the investment priorities contained in the programmes 
before adoption) (Article 9 (4) CPR) 
Intervention fields methodology in CPR annex I 

- 
-  For ERDF/CF: Exclusion list for ineligible activities (article 7) 
-  Common output and result indicators for ERDF and CF (include environmental 

indicators) 

74 

 
 
 
 
to 

Support 
the 
Turkish  Cypriot 
Community 

4% 

0% 

and 

43% 

Recovery 
Resilience 
Facility 

0% 

1% 

2% 

Policy design 

-  Climate proofing mandatory for infrastructures project (lifespan of at least 5 years) 
-  Climate enabling conditions applied 
-  Strategic Environmental Assessment (most of cohesion policy subject to an SEA 

Legal basis and earmarking 

-  Recital 23 climate framework 
-  Recital 32 consistency with Semester and National Energy and Climate Plans 
-  Recital 76 reporting  
-  Art 16 climate target (37%) 
-  Art 18(e) National plan – climate 
-  Annex VI methodology 
-  30% Green bonds 

Policy design 

-  DNSH as an eligibility criterion   
-  Climate-related enabling conditions on green targets 

75 

 
 
 
 
 
 
0 

7% 

Civil 

35% 

15%  (2021-2024 
period) 

Technical 
Support 
Instrument 

Union 
Protection 
Mechanism 

EU4Health 
Programme 

0 

0 

0 

0 

Emergency 
Support 
Instrument (ESI) 

European  Social 
Fund + 

8% 

5% 

Erasmus +  

0 

0 

1% 

0 

2% 

0 

0 

0 

0 

0 

0 

0 

No specific provisions in place 

No specific provisions in place 

Policy design 

-  Two measures included in 2024 related to the health risks that are a consequence of 

climate change 

No specific provisions in place 

Legal basis and earmarking 

-  Art 5 “a greener, low-carbon transitioning towards a net zero carbon economy and 
resilient Europe by promoting clean and fair energy transition, green and blue 
investment, the circular economy, climate change mitigation and adaptation, risk 
prevention and management, and sustainable urban mobility” policy objective 

-  Secondary theme for tracking of “green” (reported as climate with 100% coefficient) 

Policy design 

-  Prioritisation of the green transition in cooperation activities 

76 

 
 
 
 
4% 

European 
Solidarity  Corps 
(ESC) 

0 

5% 

Justice 
Programme 

Creative Europe 

0 

0 

0 

12% 

0 

0 

0 

0 

0 

0 

0 

-  Promotion of green practices at the level of projects throughout the programme   
-  Funding rules for learning mobility: sustainable travel is the default option, 

encouraging participants to prioritise green travel as their first choice when planning 
their trip. 23% of the mobilities which took place in 2023 were carried out in an 
environmentally friendly way (vs 13% in 2021). 

Policy design 

-  Environmental sustainability and climate goals is one of the four transversal priorities 

of the programme. 

-  Corps projects should promote environmentally sustainable and responsible behaviour 
among participants. The Corps contributes to equipping young Europeans with the 
necessary skills to develop innovative practices to bring about change, in line with the 
objectives for the green transition and sustainable development. 

-  Funding rule for volunteering mobility: sustainable travel is the default option, 

encouraging participants to prioritise green travel as their first choice when planning 
their trip.  

-  Between 2021-2023, 4 280 projects tackled environment and climate change with 2 
709 organisations involved and 4 077 participants using green travel. 31% of the 
participants declared that they are more aware of environmental issues. 

No specific provisions in place 

No specific provisions in place 

77 

 
 
 
 
Citizens, 
Equality,  Rights 
and 
Values 
Programme 

0 

0 

Communication 

0 

Common 
Agricultural 
Policy (CAP) 

1% 

26% 

39% 

0 

0 

0 

0 

16% 

17% 

No specific provisions in place 

No specific provisions in place 

Legal basis and earmarking 

-  40% climate target (recital 94) 
-  Earmarking of budget for ecoschemes (25% pillar I) and “expenditures for climate, 

biodiversity and environment” in pillar II (35%) 

-  15% of expenditure from fruit and vegetable Operational Programme dedicated to 

environmental and climate friendly investments 

Governance 

-  CAP strategic plans – covering EAGF and EAFRD – approved by the Commission, 

and dialogues with Member States 

-  Targets set for CAP support for climate adaptation, for GHG emission reduction and 
carbon storage, renewable energy, preserving habitats and species investments for 
climate, afforestation, biodiversity, etc. 

-  Biannual performance review 

Policy design 

78 

 
 
 
 
-  Good agricultural and environmental conditions and Statutory Management 
Requirements (applying to all area payments under the CAP i.e. 87% of EU 
agricultural utilised area in 2023)  

-  Eco-schemes, agri-environment-climate measures and green investments under pillar II 

(ringfencing)   

-  Advice, cooperation and knowledge transfer 
-  Eligibility conditions for investments in irrigation, compatible with Water Framework 

Directive  

-  Consistency between coupled income support and Water Framework Directive 

Legal basis and earmarking 

-  30% climate target (recital) 
- 

“do no significant harm” should be taken into account (Article 9 (4) CPR) 

No specific provisions in place 

14% 

30% 

3% 

12% 

50% 

Legal basis and earmarking 

79 

European 
Maritime 
Fisheries 
and 
Aquaculture Fund 
(EMFAF) 

15% 

53% 

8% 

9% 

Regional 
Fisheries 
Management 
Organisations 
(RFMO) 
Sustainable 
Fisheries 
Partnership 
Agreements 
(SFPA)  

and 

Programme 
for 
Environment  and 

48% 

 
 
 
 
Climate  Action 
(LIFE) 

61% 

49% 

-  60% climate target (recital) 
-  Earmarking of budget per objective  
-  Recital 29 refers to DNSH 

Policy design 

-  Each strand has a strong link with different green dimensions 
-  Green assist (technical support) 

Transition 

Just 
Fund (JTM) 

NA 

100% 

0 

0 

Legal basis and earmarking 

-  100 % climate relevant as per regulation 
-  DNSH must be taken into account (Article 9(4) CPR) 

Policy design 

-  Climate proofing for infrastructures project (lifespan of at least 5 years) 
-  Enabling conditions for just transition plans aligned with climate neutrality goals 

No specific provisions in place 

Asylum, 
Migration 
and 
Integration  Fund 
(AMIF) 

80 

 
 
 
 
 
 
 
 
Integrated  Border 
Management 
Fund (IBMF) 

Internal  Security 
Fund (ISF) 

Safety 

Nuclear 
and 
decommissioning 
For 
(incl. 
and 
Bulgaria 
Slovakia) 

European 
Defence 
(EDF) 

Fund 

Neighbourhood, 
Development  and 
International 
Cooperation 
Instrument 
(NDICI  Global 
Europe) 

18%  (average  of 
past programmes) 

5% 

8% 

28%  

No specific provisions in place 

No specific provisions in place 

No specific provisions in place 

No specific provisions in place 

Legal basis and earmarking 

-  30% climate target (recital) + EUR 4 bn from SOTEU 
-  7 bn EUR to biodiversity from NDICI and IPA III over 2021-2027 i.e. doubling 

compared to 2014-2020 (political commitment via SOTEU) 

-  Projects environmental screening (incl. climate and biodiversity) with environmental 

impact assessment for sensitive environmental actions (Article 25) 

-  Exclusion list for activities incompatible with Paris Agreement, promote fossil fuels or 

cause significant effects on environment 

81 

 
 
 
 
 
 
 
 
 
 
 
Humanitarian Aid 
(HUMA) 

Overseas 
Countries 
and 
Territories (OCT) 
(including 
Greenland) 

10% 

19% 

23% 

22% 

Macro-Financial 
Assistance 
(MFA) 

NA 

Instrument 
Pre-Accession 
Assistance 
III) 

for 

18% 

(IPA 

27% 

0 

0 

NA 

11% 

NA 

2% 

4% 

No specific tools in place 

No specific tools in place 

No specific provisions in place 

Legal basis and earmarking 

-  20% climate target (recital)  
-  Doubling biodiversity support from NDICI and IPA III from 2014-2020 to 2021-2027 

(political commitment via SOTEU) i.e. reaching 7 bn EUR 

Ukraine Facility  NA 

NA 

Legal basis and earmarking 

-  At least 20% of the overall amount corresponding to support under the Ukraine 

investment framework and to investment under the Ukraine plan to contribute to green 
objectives 
-  Do no harm 

Innovation Fund  NA 

NA 

Legal basis and earmarking 

82 

 
 
 
 
-  The entire budget is dedicated to climate action (Article 10a §8): actions that 

contributes substantially to mitigating climate change. 

-  DNSH principle will be applied as 2025 onward (Article 10e). 
-  Stringent environmental criteria are in place (Article 10a). One of the evaluation 
criteria for the selection of projects for grants programme is GHG avoidance. 

Modernisation 
Fund 

NA 

NA 

Legal basis and earmarking 

-  Member States have to spend 80% of national envelope on green projects 
-  DNSH applied from 2025 onward (Article 10e) 

Policy design 

-  Enabling conditions implicitly included 

Green budgeting toolbox definitions  

Area 

Overall 
Strategy 

Area 

Mainstreaming 

Green budgeting 

Definition 

Mainstreaming  refers  to  the  integration  of  a  particular  priority  into  EU  policies  and 
budget. In various contexts, such as gender mainstreaming or green  mainstreaming, it 
involves ensuring that considerations related to that priority are included in all decision-
making processes, rather than being treated as a separate or peripheral concern. 

Green budgeting is an approach that incorporates environmental considerations into the 
budgeting  process.  It  aims  to  align  public  financial  management  with  environmental 
goals,  ensuring  that  government  budgets  reflect  commitments  to  sustainability  and 

83 

 
 
 
 
 
 
 
Legal 
Ringfencing 

Dedicated programme 

Earmarking  (e.g.  dedicated  strand,  budget 
lines) 

Programme Target 

EU budget-wide target 

Programme 
design 

Objectives 

Incentives 

Enabling conditions 

Milestones/targets 

climate  action.  This  approach  is  more  sophisticated  as  not  only  involves  a  tracking 
methodology for expenditures, but also accounting for impacts, and purposely allocating 
funds to green initiatives 

In  terms  of  legal  ringfencing  of  resources,  horizontal  target,  programme  target, 
earmarking (i.e. dedicating a specific portion of a programme to a particular policy area 
or objective) and dedicated programme (e.g. Innovation fund or LIFE) represent different 
degrees to dedicate specific resources towards green priorities. Through the continuum 
of these options, there are different degrees of flexibility. 

Inclusion of specific objectives dedicated to green priorities ensures that resources are 
dedicated (also through the link between objective and budget line, where possible), and 
specific actions for operationalization foreseen  

For instance, in the Common Agricultural Policy, ecoschemes are a specific programme 
action that incentivizes beneficiaries in the green transition. 

Enabling conditions are a key element of cohesion policy for 2021-2027. They build on the ex-
ante conditionalities from the 2014-2020 period to ensure that the necessary conditions for the 
effective and efficient use of the funds are in place. 

For  instance,  if  the  special  objective  ‘promoting  a  gender  balanced  labour  market 
participation, equal working conditions and a better work-life balance including through 
access  to  affordable  childcare  and  care  for  dependent  persons’  is  selected,  then  the 
enabling condition 4.2. ‘National strategic framework for gender equality’ needs to be 
fulfilled. 
One of the key features of the Recovery and Resilience Facility is its performance-based 
nature. RRF funds are disbursed when Member States have satisfactorily fulfilled key steps in 
the implementation of the reforms and investments included in the recovery and resilience 

84 

 
 
 
 
 
 
 
 
no 

Exclusion list 

Do 
significant 
harm 

Technical guidance 

Climate proofing 

Environmental impact assessment 

Performance 
framework 

Tracking methodology 

Monitoring/indicators 

plans. These key implementation steps are referred to as milestones and targets. Milestones 
represent a qualitative implementation step, targets a quantitative implementation step. 

Such milestones and targets can also be set to fulfil specific green requirement, such as 
the deployment of a certain amount of solar panels or a reform on a given environmental 
policy. They can also be linked to specific targets for outputs or results that are in line 
with overall policy objectives.  

List of activities or interventions that cannot be eligible for financing. For instance, the 
CPR provides for an exclusion of financing for activities related to coal or oil. 

A guidance to apply the DNSH principle, in a specific programme according to rules. 

The  process  of  assessing  and  ensuring  that  projects  and  policies  are  resilient  to  the 
impacts of climate change. In the context of the EU budget, climate proofing involves 
evaluating how proposed investments or expenditures will be affected by climate change 
and ensuring that they contribute to climate adaptation and mitigation goals. 

EIA  is  a  process  used  to  evaluate  the  potential  environmental  effects  of  a  proposed 
project  or  development  before  it  is  approved.  In  the  EU  budget  context,  it  is  a  legal 
requirement for certain projects to assess their environmental impacts, including effects 
on biodiversity, air and water quality, and climate change.  

This refers to the systematic approach used to monitor the allocation and implementation 
of EU budget funds, particularly in relation to specific objectives such as climate action 
and biodiversity. Tracking methodologies help ensure transparency and accountability 
by providing a framework for assessing how funds are spent and provide updates on their 
implementation. 

Monitoring involves the ongoing assessment of projects and policies to ensure they are 
on track to meet their objectives. Indicators are specific metrics used to measure progress 
and performance. In the context of the EU budget, monitoring and indicators are essential 

85 

 
 
 
 
 
 
Reporting 

for  evaluating  the  effectiveness  of  funding  in  achieving  goals  such  as  sustainability, 
economic growth, and social inclusion. 

Reporting  refers  to  the  process  of  documenting  and  communicating  the  results  of 
monitoring and evaluation activities. In the context of the EU budget, reporting is crucial 
for transparency and accountability, as it provides stakeholders with information on how 
funds are being used, the outcomes achieved, and the overall impact of EU budgetary 
measures. This includes regular reports from the European Commission to the budgetary 
authority, including through the Annual Management Performance Report. 

86 

 
 
 
 
Table: EU budget green financing overview73 

Programme 

Climate  average  contribution 
(2021-27) per year 

average 
Biodiversity 
contribution (2021-27) per year 

in EUR billion 

in EUR million 

 993 

2 413 

9 189 

 384 

 929 

 84 

 46 

14 430 

1 631 

Horizon Europe 

ITER 

Connecting 
Facility 

Europe 

Cohesion Policy Funds 

European Social Fund + 

Common 
Policy (CAP) 

Agricultural 

LIFE 

NDICI Global Europe 

IPA III 

Other 

Total 

Recovery  and  Resilience 
Facility (2021-2024) 

Innovation 
2030) 

fund 

(2021-

Social climate fund  

Modernization fund (2021-
2030) 

73 DB2025 data 

4 674 

 649 

3 492 

16 170 

 878 

20 837 

 470 

3 500 

 584 

3 326 

54 579 

91 900 

4 000 

9 286 

5 700 

87 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total ETS 

Total 

18 986 

165 465 

16 061 

Comment: The data available for the 2021-2027 period show that the EU budget is on track to reach its 30% target 
for  climate  mainstreaming,  thanks  to  the  strong  performance  of  the  Recovery  and  Resilience  Facility  and  the 
REPowerEU initiative, which are also contributing to clean air objectives. All data used in this report use expected 
commitment appropriations. For biodiversity mainstreaming, while the projection for 2024 is close to the target, 
the 2026 and 2027 targets will be more difficult to achieve. 

6.2 Gender equality mainstreaming  

Under the inter-institutional  agreement  accompanying  the 2021-2027 Multiannual  Financial 
Framework,  the  Commission  is  required  to  report  on  the  mainstreaming  of  gender  equality 
across relevant EU budget programmes. The incorporation of gender mainstreaming provisions 
into the 2021–2027 MFF has seen progress in some areas but remains uneven and incomplete 
across EU budget programmes. A number of MFF programmes have made notable progress. 
For instance, the NDICI–Global Europe Regulation74 and the Gender Action Plan75 set a target 
requiring 85% of new actions to have gender equality as a principal or significant objective. 
Similarly,  the  Common  Provisions  Regulation  introduced  gender  equality  as  a  thematic 
enabling  condition,  establishing  it  as  a  prerequisite  for  the  effective  implementation  of  EU 
funds’ specific objectives. The Common Agricultural Policy 2023-2027 introduced a specific 

74 Regulation - 2021/947 - EN - EUR-Lex 
75 join-2020-17-final_en.pdf --> to be checked 

88 

 
 
 
 
 
 
 
 
 
 
reference to gender equality and the need to enhance the participation of women in farming in 
one of its nine specific objectives. Horizon Europe, the EU's flagship research and innovation 
programme, positions gender equality as a cross-cutting principle. From 2022 onward, public 
bodies,  research  organisations,  and  higher  education  institutions  have  been  required  to 
implement a Gender Equality Plan76 to access funding, creating a multiplier effect for gender 
equality promotion. Meanwhile, the Recovery and Resilience Facility77 also requires Member 
States to explain how their plans contribute to gender equality. 

However, despite these  positive developments,  significant  gaps and limitations  remain. The 
preparation phase of many programmes did not adequately incorporate gender considerations. 
Impact assessments and ex-ante evaluations of MFF programmes often failed to identify the 
relevance of gender equality or define specific objectives, resulting in design shortcomings. 
For  instance,  the  inclusion  of  gender  as  a  specific  objective  of  programmes  is  inconsistent 
across the EU budget. This lack of integration partly explains the current situation, where 69% 
of EU budget programmes are assigned a gender score of 078. Also for certain programmes 
such  as  the  Common  Agricultural  Policy,  although  Member  States  were  provided  with  the 
framework  to  design  specific  interventions  in  favour  of  women79,  one  of  the  CAP  main 
missions is to support farmers regardless of their gender. 

At  the  same  time,  the  late  introduction  of  the  methodology80  for  tracking  gender-related 
expenditure – after programme implementation began – further complicated efforts to establish 
a coherent gender mainstreaming and tracking approach.  

Fragmentation has arisen from divergent methods of integrating gender objectives, designing 
mainstreaming  measures,  and  applying  tracking  methodologies.  The  misalignment  between 
programme  design  and  tracking  requirements  has  compounded  these  difficulties,  further 
impeding  the  establishment  of  a  cohesive  and  effective  approach  to  gender  mainstreaming 
across the MFF. 

Table: Gender policy mainstreaming elements in the 2021-2027 programmes 

Programme 

Gender mainstreaming elements 

Horizon Europe   Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

76 COUNCIL DECISION (EU) 2021/764 of 10 May 2021 establishing the Specific Programme implementing 
Horizon Europe – the Framework Programme for Research and Innovation, and repealing Decision 2013/743/EU 
Publications Office 
77 Regulation - 2021/241 - EN - rrf - EUR-Lex 
78 Annual Management and Performance Report for the EU budget – Annex I – 3. Horizontal policy priorities in 
the EU 
79 The majority of Member States imposed the requirement that at least 50% of women must be represented in 
LEADER decision making bodies. 
80 
priorities/gender-equality-mainstreaming_en  

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/horizontal-

89 

 
 
 
Recitals and dedicated articles. The gender requirements for research organisations applying for 
EU funding include having a Gender Equality Plan (GEP), integrating gender considerations 
into research content, and ensuring gender balance within teams and boards. Integration of sex 
and gender analysis is mandatory in all topics of calls for proposals unless on-relevance of 
gender  is  justified.  The  Commission  provides  guidance  and  training  to  support  GEP 
implementation and has introduced an EU Award for Gender Equality Champions. There is also 
dedicated funding for gender studies and women innovators, with a focus on promoting gender 
equality across various research and innovation programmes. 

Euratom 
Research and 
Training 
Programme 
(Euratom) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recital:  Gender  equality  is  a  cross-cutting  priority  in  the  Euratom  programme,  as  stated  in 
recital  2  of  the  Council  regulation.  The  Euratom  programme  is  promoting  gender  equality 
through sustainable institutional change by requesting that applicants (public bodies, research 
organisations and higher education establishments) have in place a gender equality plan as an 
eligibility  criterion  for  research  proposals  (requirement  shared  with  Horizon  Europe).  In  its 
2030  strategy,  the  Joint  Research  Centre  declares  itself  as  an  equal  opportunity  employer 
committed to the objective of being fully gender balanced. 

ITER 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

F4E has set targets to improve gender balance internally, particularly in managerial positions. 
The representation of female managers has progressed from 10% to 21% between 2018 and 
2023.  

InvestEU 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals and dedicated articles. Gender equality as supported objective. Regulation requires to 
estimate social impact of projects (incl. gender equality). Various projects focusing on gender 
equality (the gender smart advisory initiative, European Investment Fund equity financing). 

Connecting 
Europe Facility 
(CEF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals and dedicated articles: gender equality should be taken into account in CEF, articles on 
inclusivity of those with accessibility issues.  

Digital Europe 
Programme 

Gender tracking methodology: 

In line with the Commission’s methodology to track gender-equality-related expenditure, the 
programme has been attributed a  score of 0*, which means that the programme’s impact on 

90 

 
 
 
gender  will  be  determined  ex  post,  once  sufficient  information  from  the  programming  and 
implementation phase is available. 

Gender requirements: Recitals and dedicated articles. The contribution from DEP to gender 
equality  in  the  first  set  of  work  programmes  may  be  relevant  for  the  training  initiatives  to 
promote advanced digital skills organised under the 'advanced digital skills’ specific objective, 
in line with Article 7 of the Digital Europe regulation, according to which gender balance should 
be taken into account. 

Single Market 
Programme 

Gender tracking methodology: 

Commission gender equality tracking methodology 

requirements:  
Gender 
Recitals  and  dedicated  articles:  attention  to  female  entrepreneurs,  and  addressing  needs  of 
vulnerable consumers and underrepresented groups. 

EU Anti-Fraud 
Programme 
(Anti-Fraud) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements: 

Financial  support  from  the  programme,  OLAF  encouraged  the  Member  State  authorities  to 
aspire to a better gender balance in their selection of training participants to these events. 

Cooperation in 
the field of 
taxation 
(Fiscalis) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements: 

Score 0*: relates to the remaining types of expenditure, i.e. collaboration activities, training, 
studies  and  communication,  for  which  a  potential  to  promote  gender  equality  has  been 
identified.  

Cooperation in 
the field of 
customs 
(Customs) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements: 

Recital states that gender equality should be taken into account when selecting experts. 

European Space 
Programme 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements: 

Recitals and dedicated articles. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

EU Secure 
Connectivity 
Programme 

91 

 
 
 
 
 
Regional Policy 
Funds (ERDF 
and Cohesion) 

Gender requirements: 

The regulation establishing the programme states that the programme should contribute to the 
development  of  advanced  skills  in  space-related  fields  and  support  education  and  training 
activities,  along  with  promoting  equal  opportunities,  gender  equality  and  women’s 
empowerment. The Commission promotes and encourages increased participation of women 
and establishes equality and inclusion goals in tenders documentation. The Commission also 
supports initiatives to raise awareness of gender equality in the area of space. 

Gender tracking methodology: 

Cohesion policy uses a ‘categorisation’ information system, which specifically focuses on the 
gender equality dimension to capture information on the gender contribution of the 2021-2027 
programmes. These multiannual thematic allocations are used to calculate the indicative share 
of  investments  under  each  annual  commitment  as  set  above.  Commission  gender  equality 
tracking methodology. 

requirements:  
Gender 
Recitals and dedicated articles. Based on the adopted programmes, close to 10% of the planned 
EU amounts will be used to support interventions the principal objective of which is to improve 
gender equality or interventions that have gender equality as an objective.  

Support to the 
Turkish Cypriot 
Community 
(TCC) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements: 

Recovery and 
Resilience 
Facility (RRF) 

The programme contributes to gender equality (promoting the inclusion of women in social and 
economic life; SDGs, supporting the development of rural/remote areas; supporting the drafting 
of legal texts on equality issues (lesbian, gay, bisexual, transgender and intersex issues, anti-
trafficking,  domestic  violence,  patients’  rights);  providing  direct  support  to  civil-society 
organisations addressing equality issues,  promoting gender equality education, prevention of 
domestic violence and sexual health education in schools). 

Gender in legal basis:  

Mitigating the social and economic impact of the COVID-19 crisis on women is an objective 
of  the  RRF,  as  set  out  in  Article 4  of  the  RRF  Regulation81.  The  RRF  Regulation  requires 
Member States to explain how the measures in their RRPs contribute to gender equality and 
equal opportunities for all, and the mainstreaming of these objectives.  

tracking 

methodology: 
Gender 
The Commission, in consultation with Member States, has assigned a tag to measures with a 
focus  on  gender  equality,  based  on  the  methodology  set  out  in  the  delegated  act  on  social 
expenditure reporting under the RRF (Delegated Regulation (EU) 2021/2105). Following the 
respective amendments performed in 2023, the RRPs now include 136 measures with a gender 
tag. Follows Commission gender equality tracking methodology. 

requirements: 
Gender 
Mitigating  the  social  and  economic  impact  of  the  COVID-19  crisis  on  women  is  a  clear 
objective  of  the  RRF,  as  set  out  in  Article 4  of  its  founding  regulation. The  RRF  regulation 

81  REGULATION  (EU)  2021/241  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  of  12 
February 2021 establishing the Recovery and Resilience Facility 

92 

 
 
 
 
requires Member States to explain how the measures in their RRPs contribute to gender equality 
and equal opportunities for all and the mainstreaming of these objectives. 

Technical 
Support 
Instrument (TSI) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements: 

Recitals and dedicated articles: in line with the principles of the gender equality strategy 2020-
2025,  TSI  contributes  to  gender  equality  and  equal  opportunities  for  all  and  for  the 
mainstreaming of these objectives. 

Pericles IV 

Gender tracking methodology: 

Union Civil 
Protection 
Mechanism 
(UPCM) 

Commission gender equality tracking methodology 

Gender tracking methodology: 

The voted budget implementations committed to the mechanism are 0* category. This mark 
will be reviewed at the end of the multiannual financial framework cycle in order to categorise 
funds under scores of either 0 or 1. 

Gender requirements: 

Recitals and dedicated articles. The Commission commits to gender-sensitive civil protection, 
including addressing specific vulnerabilities and exchanging information on the issue of support 
for  victims  of  gender-based  violence  during  disasters.  The  Commission  promotes  gender 
equality  through  the  disaster  risk  cycle  and  raises  awareness  of  the  principles  of  non-
discrimination  and  inclusiveness.  It  also  promotes  a  gender-inclusive  approach  in  response 
activities and ensures that the gender component is considered. 

EU4Health 
Programme 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals and dedicated articles to tackle health inequalities. Some actions – for example cancer 
screening  for  breast  cancer  and  cervical  cancer,  and  vaccination  coverage  for  human 
papillomaviruses  –  that  focus  on  women’s  health  may  provide  relevant  information  for  the 
purpose of the gender tracking of the EU4Health programme, which for the time being has been 
assigned a score of 0*. Several indicators that focus on male-related diseases – such as prostate 
cancer, and the increase in vaccination coverage  for human papillomaviruses in boys  – may 
provide relevant information on gender equality.  

Emergency 
Support 
Instrument (ESI) 

European Social 
Fund + (ESF+) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender tracking methodology: 

The  amounts  provided  correspond  to  those  earmarked  for  the  gender  codes  of  the  common 
provisions regulation: ‘01’ for gender targeting (corresponding to a score of 2), ‘02’ for gender 
mainstreaming (corresponding to a score of 1) and ‘03’ for gender neutral (corresponding to a 
score of 0).  

93 

 
 
 
 
 
Gender requirements:  

Dedicated  articles  and  recitals.  Gender  equality  is  also  a  horizontal  priority  for  the  direct 
management strand of the ESF+, and should be taken into account in all activities. Under ESF+ 
shared  management,  Member  States  were  obliged  to  programme  targeted  actions  aimed  at 
promoting  gender  equality. Member  States  and  the  Commission  shall  ensure  that  equality 
between men and women, gender mainstreaming and the integration of a gender perspective are 
taken  into  account  and  promoted  throughout  the  preparation,  implementation,  monitoring, 
reporting  and  evaluation  of  programmes.  Gender  equality  is  one  of  six  thematic  enabling 
conditions used for the first time in the 2021-2027 period. This means that gender equality is a 
prerequisite for the effective and efficient implementation of the specific objective ‘promoting 
a gender-balanced labour market participation, equal working conditions, and a better work-life 
balance  including  through  access  to  affordable  childcare,  and  care  for  dependent  persons’. 
Member States have to assess in their programmes whether the enabling conditions linked to 
the selected specific objectives were fulfilled. 

Erasmus+ 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals  and  dedicated  articles.  In  line  with  the  principles  of  the  2020-2025  gender  equality 
strategy, Erasmus+ contributes to fostering equality. The programme seeks, among other aims, 
to help overcome gender stereotypes in education and educational careers and to strengthen the 
promotion  of  participation  of  women  in  the  area  of  science,  technology,  engineering  and 
mathematics education, especially in engineering, information and communication technologies 
and advanced digital skills. For instance, the programme contributes to fostering gender balance 
in higher education institutions, across fields of study and in leadership positions, while in the 
vocational education and training sector it supports targeted measures promoting gender balance 
in traditionally ‘male’ or ‘female’ professions and addressing gender and other stereotypes. 

European 
Solidarity Corps 
(ESC) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals  and  dedicated  articles:  gender  equality  in  humanitarian  response,  provide  equal 
opportunities, focus on social inclusion and equal opportunities. 

Justice 
Programme 

Gender tracking methodology: 

The  justice  programme  is  part  of  the  pilot  methodology  developed  by  the  Commission  to 
measure the contribution of the EU budget to gender equality. 

Gender requirements:  

Recitals and dedicated articles, promote gender equality (art.4). 

Citizens, 
Equality, Rights 
and Values 
Programme 
(CERV) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

94 

 
 
 
Recitals and dedicated articles. Promotion of gender equality, non-discrimination and equality, 
fight violence, including gender-based violence, equality mainstreaming in civil dialogue.  

Creative Europe  Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals and dedicated articles. Under the creative Europe programme, special attention is given 
to applications presenting adequate strategies to ensure gender balance, which was introduced 
as a cross-cutting priority in all strands of the programme starting with the 2021 annual work 
programme. 

Communication  Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

The working group on equality - created in March 2021 - produced a working plan on equality, 
and monitors its implementation. 

Common 
Agricultural 
Policy (CAP) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Tracking of the expenditure by gender for farm beneficiaries, as from financial year 2024 

Gender requirements: 

Under  CAP  2014-2022,  the  gender  perspective  was  considered  during  the  preparation  and 
implementation of the rural development programmes. Gender equality was specifically sought 
in the rural development policy through the possibility to submit thematic subprogrammes for 
women in rural areas (although no Member States had done so), the possibility to target rural 
development support to women through the application of selection criteria, and the obligation 
to respect ex ante conditionality on gender equality.  

The CAP 2023-2027 went further and introduced a specific reference to the need to enhance 
the  participation  of  women  in  farming  and  strengthen  the  inclusion  of  women  into  rural 
economy within the specific objective (h) (Art. 6 of 2021/2115). This provides Member States 
with  the  policy  and  funding  framework  for  the  design  of specific  interventions  in  favour  of 
women.  As  an  illustration,  Spain  introduced  enhanced  payments  for  young  women  farmers 
under EAGF and Ireland provides young women farmers with a possibility to receive higher 
payments under EAFRD. Furthermore, the majority of Member States committed to include at 
least  50%  of  women  into  LEADER  decision  making  bodies.  In  addition,  the  majority  of 
Member States included organisations representing the interests of women in their monitoring 
committees.  In  this  context,  Regulation  2021/2115  requires  Member  States  to  establish  a 
partnership that includes relevant bodies, including those responsible for gender equality and 
non-discrimination. 

European 
Maritime 
Fisheries and 
Aquaculture 
Fund (EMFAF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

95 

 
 
 
 
Programme for 
Environment 
and Climate 
Action (LIFE) 

Recitals and relevant articles in CPR. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

The LIFE programme does not directly target gender equality, since its main objective is linked 
to  climate  and  environment  spending.  A  gender  dimension  is  considered  in  some  areas  of 
intervention to identify how men and women relate to the environment and to climate action in 
different  ways,  thus  addressing  specific  gender  vulnerabilities  (e.g.  inherent  to  harmful 
chemicals such as endocrine disruptors and persistent organic pollutants). 

Just Transition 
Mechanism 

Gender tracking methodology: 

The JTM uses a categorisation information system, which focuses specifically on the gender 
equality  dimension,  to  capture  information  on  the  gender  contribution  of  the  2021-2027 
programmes.  

Gender requirements:  

Recitals and relevant articles in CPR. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Asylum, 
Migration and 
Integration Fund 
(AMIF) 

Recitals  and  dedicated  articles  and  CPR.  The  programme  is  committed  to  the  horizontal 
approach  of  the  EU  budget,  in  which  equality  between  women  and  men,  rights  and  equal 
opportunities for all and the mainstreaming of these objectives should be taken into account and 
promoted throughout the preparation, implementation and monitoring of relevant programmes, 
as stipulated in Article 6 of the programme regulation (Regulation (EU) 2021/1147). In order 
to receive payments from the Commission, Member State programmes will have to comply with 
a number of horizontal-enabling conditions, one of which concerns the effective application and 
implementation of the EU Charter of Fundamental Rights, including the equality of men and 
women. The programme regulation specifically stipulates that eligible actions need to take into 
account the human rights-based approach to the protection of migrants, refugees and asylum 
seekers  and  should,  in  particular,  ensure  that  special  attention  is  paid  to,  and  a  dedicated 
response  is  provided  for,  the  specific  situation  of  vulnerable  persons,  in  particular  women, 
unaccompanied minors and victims of trafficking in human beings. 

Integrated 
Border 
Management 
Fund (IBMF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals, dedicated articles and CPR. To receive payments, Member States programmes have 
to comply with a number of horizontal enabling conditions, one of which concerns the effective 
application  and  implementation  of  the  EU  Charter  of  Fundamental  Rights,  including  the 
equality of women and men. The horizontal enabling conditions must be fulfilled throughout 
the  entire  programming  period,  and  Member  States  must  report  on  their  application  to  the 
Commission. 
programme 

monitoring 

committee 

and 

the 

96 

 
 
As  regards  the  types  of  action  supported,  training  and  knowledge  sharing  habitually  tackle 
gender-specific issues, which is why they are financial interventions that may have potential to 
impact gender equality, among other areas. 

Internal Security 
Fund (ISF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recitals,  dedicated  articles  and  CPR.  To  receive  payments  from  the  Commission,  Member 
States’ programmes have to comply with several horizontal enabling conditions, one of which 
concerns  the  effective  application  and  implementation  of  the  EU  Charter  of  Fundamental 
Rights,  including  the  equality  of  men  and  women.  Horizontal  enabling  conditions  must  be 
fulfilled throughout the entire programming period, and Member States must report on their 
application to the programme monitoring committee and the Commission. As regards the types 
of action supported by the programme, training and knowledge sharing habitually tackle gender-
specific issues, which is why they are considered to be financial interventions that may have 
potential to impact gender equality, among other areas. 

Nuclear Safety 
and 
Decommissioning 
(NSD) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

The  gender  equality  perspective  was  considered  in  developing  Council  Regulation  (EU) 
2021/100.  

European 
Defence Fund 
(EDF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

Recital, seek balanced composition of expert groups. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender 
No specific provisions. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

requirements:  

requirements:  
Gender 
On  equality,  diversity  and  inclusion,  EDIRPA  is  not  directly  targeted  at  gender  equality 
initiatives.  Nevertheless,  indirect  contributions  supporting  the  gradual  raising  of  awareness 
about gender equality are continually being made as opportunities arise. For instance, gender 
equality aspects receive special mentions in communication activities and at events on various 
EDIRPA. 
matters 
Gender tracking methodology: 

relating 

to 

Regulation on 
Supporting 
Ammunition 
Production 
(ASAP) 

EU Defence 
Industry 
Reinforcement 
Through 
Common 
Procurement Act 
(EDIRPA) 

Neighbourhood, 
Development and 
International 

97 

 
 
 
 
 
Cooperation 
Instrument 
(NDICI Global 
Europe) 

OECD DAC methodology  

Gender requirements:  

Recitals and dedicated articles. According to the NDICI  – Global Europe regulation, at least 
85% of new initiatives implemented should have gender equality as a principal or a significant 
objective,  as  defined  by  the  gender  equality  policy  marker  of  the  Development  Assistance 
Committee of the Organisation for Economic Co-operation and Development. At least 5% of 
these actions should have gender equality and women’s and girls’ empowerment as a principal 
objective.  In  2020,  the  gender  action  plan  III  (2021-2025),  a  joint  communication  from  the 
Commission and the High Representative of the Union for Foreign Affairs and Security Policy, 
was adopted with the same objective of 85% towards the total number of adopted initiatives, 
following the Development Assistance Committee’s methodology. A significant number of EU 
delegations have a gender analysis at country level, along with a sector analysis, and they have 
put measures in place to ensure the use of gender-specific and sex-disaggregated data, which 
are essential tools to ensure quality mainstreaming into new initiatives. 

European 
Instrument for 
International 
Nuclear Safety 
Cooperation 
(INSC) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

requirements:  
Gender 
The INSC promotes gender equality through its training, tutoring and education  programme, 
where the participation of partner countries is conditional upon the gender-balanced registration 
of students. 

Humanitarian 
Aid (HUMA) 

Gender tracking methodology: 

Commission  gender  equality  tracking  methodology.  Humanitarian  aid  has  some  impact  on 
gender equality (therefore, scores 0 and 0* could not be assigned), but gender equality is also 
not the principal objective of the programme (therefore score 2 could not be assigned). 

requirements:  
Gender 
Mainstreaming gender and age is done across sectors of intervention, outlining the approach to 
gender  and  gender-based  violence  in  humanitarian  crises  in  the  staff  working  document 
‘Gender: Different needs, adapted assistance’. The EU is a member of the ‘Call to action on 
protection  from  gender-based  violence  in  emergencies’  initiative  and  reported  on  the 
commitments made on the road map for 2021-2025. Focus on conflict-related sexual violence 
was increased in response to observations in several recent and ongoing crises. 

Common 
Foreign and 
Security Policy 
(CFSP) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

requirements:  
Gender 
All civilian CSDP missions, except the newly established EU Partnership Mission in Moldova 
and the Gulf of Guinea initiative, have gender equality as an important objective (Development 
Assistance Committee gender equality marker 1) 

Overseas 
Countries and 
Territories 
(OCT) (including 
Greenland) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

requirements:  
Gender 
The DOAG programme states that gender equality should be mainstreamed into all initiatives 
as a key contribution to the successful achievement of the SDGs. New initiatives aim to ensure 

98 

 
 
Macro-Financial 
Assistance 
(MFA) 

Instrument for 
Pre-Accession 
Assistance (IPA 
III) 

that  gender  aspects  are  considered  to  the  extent  possible,  notably  through  sex-disaggregated 
data. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender tracking methodology: 

The Commission’s gender expenditure tracking methodology for the EU budget is in line with 
the Development Assistance Committee’s gender equality policy marker methodology. Score 2 
equals G2 and implies that gender equality is principal objective; score 1 equals G1 and implies 
that gender equality is a significant objective; score 0 equals G0 and means that gender equality 
is  not  targeted.  The  use  of  the  Organisation  for  Economic  Co-operation  and  Development 
gender marker is also aligned with the methodology established by the gender action plan III. 

Gender requirements: 

Recitals and dedicated articles. The gender action plan III (2021-2025) defines clear objectives 
and targets concerning gender mainstreaming in policies and programmes. The plan establishes 
that, by 2025, at least 85% of all new external actions should have gender equality and women’s 
and girls’ empowerment as a significant objective or as a principal objective, and that at least 
one action with gender equality as a principal objective should be supported in each country 
and region. Such objectives apply to actions funded under IPA III, as established by recital 27 
of  the  IPA  III  regulation  and  the  IPA  III  programming  framework.  In  2023,  the  European 
Commission and the European External Action Service adopted a joint midterm report on the 
implementation of the gender action plan III. 

Reform and 
Growth Facility 
for the Western 
Balkans 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender 
Activities under the facility mainstream gender equality. 

requirements:  

Ukraine Facility  Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

European 
Globalisation 
Adjustment 
Fund for 
Displaced 
Workers (EGF) 

Activities  under  the  facility  mainstream  gender  equality  and  non-discrimination,  where 
relevant. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

requirements:  
Gender 
The EGF regulation provides for the Commission and Member States to  ensure that equality 
between men and women and the integration of the gender perspective are integral parts of and 
promoted during all stages of the implementation of the financial contribution from the EGF. 
To  that  end,  Member  States  formally  confirm  the  respect  of  this  principle  at  the  time  of 
application, when they provide gender-disaggregated information on the workers targeted for 
assistance.  As  relevant,  the  Commission  requests  that  Member  States  provide  further 
information  on  the  gender  aspect  in  the  course  of  its  assessment  of  an  application.  This  is, 
however, a general principle applied across the implementation and final reporting of the EGF 

99 

 
 
 
cases, and estimating budget contributions is not relevant. Evaluations of the EGF include an 
analysis  of  both  gender  disaggregated  data  and  qualitative information  (beneficiary  surveys, 
interview with implementers, etc.) regarding possible gender discrimination. In the course of 
EGF evaluations, external contractors conduct case studies on EGF cases, also taking the gender 
perspective  into  account.  Past  evaluations  did  not  detect  gender  discrimination  in  either  the 
delivery of measures or the targeting of beneficiaries. In many cases, authorities aim to help 
participants overcome gender stereotypes when looking for a new job. 

EU Solidarity 
Fund (EUSF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender 
No specific provisions on gender equality. 

requirements:  

Innovation Fund 
(IF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Brexit 
Adjustment 
Reserve (BAR) 

Gender 
No specific provisions on gender equality. 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender requirements:  

requirements:  

No specific provisions on  gender equality. However, the objectives of the reserve  should be 
pursued in line with the principles set out in the European Pillar of Social Rights, including the 
inherent contribution to the elimination of inequalities and to the promotion of gender equality 
and gender mainstreaming, while ensuring respect for fundamental rights. 

Social Climate 
Fund (SCF) 

Gender tracking methodology: 

Commission gender equality tracking methodology 

Gender 
No specific provisions on gender equality. 

requirements:  

Table: Gender expenditure per programme (per gender score82): 

Programme 

Gender Score 2021-2023 

0 

0* 

1 

2 

82  The  gender  scoring  methodology  assesses  the  gender  equality  relevance  of  interventions:  Score  2  refers  to 
interventions the principal objective of which is to improve gender equality, Score 1 refers to interventions having 
gender equality as an important and deliberate objective (but not as the main reason for the intervention), Score 
0*  refers  to  interventions  having  the  potential  to  contribute  to  gender  equality,  and  Score  0  corresponds  to 
interventions not having a significant bearing on gender equality. 

100 

 
 
 
 
 
 
Horizon Europe 

1143.3 

29867.8 

4841.4 

215.3 

Euratom Research and Training 
Programme 

ITER 

InvestEU 

Connecting Europe Facility 

Digital Europe Programme 

Single Market Programme 

EU Anti-Fraud Programme 

Fiscalis 

Customs 

3% 

0 

0% 

2123.8 

100% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

73.3 

100% 

88.1 

82% 

354.7 

94% 

83% 

820.4 

100% 

0 

0% 

2366.2 

100% 

13906.4 

100% 

3701.4 

100% 

1903.9 

100% 

0 

0% 

19.8 

18% 

22.2 

6% 

European Space Programme 

1977.1 

4053.3 

EU Secure Connectivity Programme 

Regional Policy Funds (ERDF and 
Cohesion) 

Support to the Turkish Cypriot 
Community 

67% 

186.3 

100% 

0 

0% 
98.8 

33% 

0 

0% 

79945.6 

90% 
0 

101 

13% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0 

0 

0 

0 

1% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0 

0 

0 

0 

0% 

0% 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

710.1 

8014.1 

1% 
1.1 

9% 
0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Recovery and Resilience Facility 

627111.3 

0 

99% 

1% 

0 

Technical Support Instrument 

Pericles IV 

Union Civil Protection Mechanism 

EU4Health Programme 

Emergency Support Instrument 

European Social Fund + 

Erasmus+ 

European Solidarity Corps 

Justice Programme 

Citizens, Equality, Rights and 
Values Programme 

Creative Europe 

Communication 

97% 

0 

0% 

2.4 

100% 

0 

0% 

1729.1 

91% 

224 

97% 

0 

0% 

335.4 

94% 

0 

0% 

789.6 

100% 

178.1 

9% 

7.7 

3% 

13947.1 

7917.8 

2% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

1% 

20.4 

6% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

1448.9 

2352.7 

27249.8 

1324.9 

7% 

6799.1 

70% 

306.8 

73% 

96.8 

74% 

102.1 

19% 

983.8 

94% 

322.8 

100% 

4% 

0 

0% 

0 

0% 

20.6 

16% 

35.4 

7% 

0 

0% 

0 

0% 

102 

84% 

2030.3 

21% 

0 

0% 

12.4 

10% 

304.7 

58% 

0 

0% 

0 

0% 

4% 

938.3 

10% 

114.6 

27% 

0.3 

0% 

86 

16% 

61.8 

6% 

0 

0% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common Agricultural Policy 

European Maritime Fisheries and 
Aquaculture Fund (EMFAF) 

LIFE 

Just Transition Mechanism 

Asylum, Migration and Integration 
Fund (AMIF) 

Integrated Border Management 
Fund (IBMF) 

Internal Security Fund 

Nuclear Safety and 
Decommissioning 

European Defence Fund 

ASAP 

EDIRPA 

Neighbourhood, Development and 
International Cooperation 
Instrument 

European Instrument for 
International Nuclear Safety 
Cooperation (INSC) 

Humanitarian Aid 

160930.8 

100% 

40.6 

2% 

3371.9 

100% 

231.2 

9% 

95.7 

15% 

0 

0% 

1891.4 

67% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0 

0% 

2300.4 

98% 

2248 

99.80% 

10283.2 

73% 

0 

0% 

2253.6 

91% 

534.6 

85% 

166.4 

100% 

945.7 

33% 

0 

0% 

0 

0% 

3125.8 

9% 

15 

13% 

0 

103 

0 

0% 

0 

0% 

5.5 

0.20% 

3779.1 

27% 

0 

0% 

0 

0% 

0 

0 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

30944.2 

88% 

100.9 

87% 

7017.9 

0 

0% 

0 

0% 

0 

0% 

106.3 

1% 

0 

0% 

0 

0% 

0 

0 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

952 

3% 

0 

0% 

0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common Foreign and Security 
Policy 

Overseas Countries and Territories 
(OCT) (including Greenland) 

Macro-Financial Assistance 

Instrument for Pre-Accession 
Assistance (IPA III) 

Reform and Growth Facility for the 
Western Balkans 

Ukraine Facility 

European Globalisation Adjustment 
Fund for Displaced Workers 

EU Solidarity Fund 

Innovation Fund 

Brexit Adjustment Reserve 

Social Climate Fund 

0% 

1085.5 

56% 

74 

37% 

0 

0% 
3420.0 

56% 

0 

0% 

0 

0% 

0 

0% 

1059 

100% 

0 

0 

1991.1 

100% 

0 

0 

0 

0 

0% 

0 

0% 

630.8 

100% 
0 

0% 

0 

0% 

0 

0% 

44.3 

100% 

0 

0% 

6611.7 

100% 

0 

0% 

0 

0 

100% 

837.6 

44% 

127.1 

63% 

0 

0 
2557 

42% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0 

0 

0 

0 

0 

0 

0 

0 
83.6 

1% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0% 

0 

0 

743988.1 

243069.8 

94466.1 

19835.4 

69% 

21% 

8% 

2% 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Gender equality mainstreaming under the post-2027 programmes 

The integration of gender equality across all EU budget programmes is a cornerstone of the 
Union’s  commitment  to  inclusive  and  sustainable  development  and  an  essential  element 
towards building a Union of Equality and promote equal opportunities for all. In line with the 
Gender Equality Strategy post 2025, gender mainstreaming is embedded into the performance 
framework  as  a  horizontal  principle.  The  Financial  Regulation  requires  that  all  EU  budget 
programmes  and  activities,  where  feasible  and  appropriate,  are  implemented  taking  into 
account  the  principle  of  gender  equality  in  accordance  with  an  appropriate  gender 
mainstreaming methodology.  

There are several mechanisms to mainstream cross-cutting policy priorities into programmes 
(‘mainstreaming toolbox’). One of them is by means of a robust performance framework, with 
performance  indicators,  expenditure-tracking  methodology  and  reporting  requirements  that 
make it possible to identify investments and measures that contribute to that priority. Another 
tool is the design of the programmes, including by setting policy-specific objectives that guide 
the programming of the actions that get support from the EU budget. This section of the impact 
assessment deals with the latter point. The question hereby examined is when gender should 
be included as a specific objective in the programmes for the next MFF.  

To answer this question, guidance can be drawn from the Gender mainstreaming toolkit by the 
European Institute for Gender Equality (EIGE) as a starting point.83 In accordance with this 
document, an initiative is likely to impact on gender equality if the following two conditions 
are met: (1) The ultimate target group is people, considering both individuals and legal entities; 
and (2) the proposed initiative affects women and men regarding their access to and/or control 
of resources and it has an impact on the social situation or position of women and men, by 
either  improving  or  harming  it.  It  points  out  that  the  impact  may  be  direct  (regulating  or 
affecting people’s  access to  resources) or indirect (the measure affects  people indirectly, as 
they  are  behind  companies  that  may  be  subject  to  the  measures).  Gender  analysis  provides 
elements to discern these impacts. 

This EIGE analysis provides some general considerations for any public initiative, be it a law, 
policy or programme. For the purposes of determining the gender relevance of an EU budget 
programme, this  has to be read in conjunction with the wording of the Financial Regulation, 
which  requires  to  take  into  account  gender  equality  ‘where  feasible  and  appropriate’,  the 
principle of proportionality, and also the gender equality methodology currently applied to the 
EU  budget,  whereby  certain  interventions  are  given  a  ‘score  0’  where  they  do  not  have  a 
significant bearing on gender equality.  

EU spending instruments do not influence gender equality outcomes in the same way and with 
the  same  intensity,  because  of  their  objectives  or  the  policy  areas  they  focus  on.  Some 
programmes operate in technical or regulatory domains (e.g. administrative cooperation or anti-
fraud) and their interventions are not expected to have a significant bearing on gender equality. 
In such cases, the introduction of gender-specific objectives might not have a significant added-
value.  

83 
https://eige.europa.eu/sites/default/files/documents/eige_gender_impact_assessment_gender_mainstreaming_too
lkit.pdf  

105 

 
 
 
From  this  perspective,  gender-specific  policy  objectives  should  be  included  in  programmes 
with potentially direct impacts, and not included in programmes with indirect impacts only. 
This approach ensures the performance framework is more focused, targeted, and meaningful 
– supporting genuine integration of gender equality in programmes where it can make  most 
difference. It also ensures that the scoring system remains an effective policy tool, rather than 
a merely administrative exercise. 

The table below summarises the gender relevance for programmes under the next MFF. If a 
programme  does  not  seem  to  have  a  significant  gender  relevance,  in  the  sense  that  gender 
considerations  do  not  seem  substantially  pertinent  to  the  programme’s  logic,  activities,  or 
expected results, it can be concluded that gender should not feature as a specific objective in 
that programme. The fact that gender is not explicitly included as an objective of a programme 
would  not  preclude  that  programme  from  supporting  projects  with  a  gender  dimension. 
Moreover, the classification may be revisited should the scope or delivery mechanisms of these 
programmes evolve to include elements relevant to gender equality. 

Programme 

Gender 
relevant?  

Justification of whether gender 
mainstreaming is relevant and appropriate 

National and Regional 
Partnership Plans 

Yes 

European Competitiveness 
Fund 

Yes 

Gender mainstreaming will be relevant for 
National and Regional Partnership Plans, given 
their wide scope and the number of different 
policies with a gender dimension that such 
agreements will support, including for instance 
social policies and cohesion, which are 
ultimately aimed at supporting people in 
different ways. Integrating a gender perspective 
will lead to more inclusive, efficient, and 
resilient projects, in addition to helping to 
target diverse needs, supporting sustainable 
development, and aligning with EU priorities 
on equality and social cohesion. Moreover, 
National and Regional Partnership Plans will 
provide an opportunity to address gender 
inequalities in Member States not only through 
investments but also national reforms.  

Gender mainstreaming will be relevant for the 
EU Competitiveness Fund. The Fund will aim 
at supporting several strategic sectors, such as 
the clean and digital transition and health.  
Evidence shows that gender inclusive policies 
enhance innovation, productivity, and 
economic resilience, which are core drivers of 
competitiveness. Historically, overlooking 
gender disparities has limited talent potential 
and stifled growth in those sectors. Looking 
forward, as the EU aims for a more sustainable, 
digital, and equitable economy, integrating 

106 

 
 
Research framework 
programme 

Yes 

Global Europe Instrument 

Yes 

Connecting Europe Facility  No 

gender perspectives ensures that policies and 
investments are effective, fair, and future proof. 

Gender mainstreaming should be applied to the 
research framework programme to reinforce 
the EU's commitment to equality, diversity, and 
inclusion in research and innovation. As a 
cross-cutting priority, gender equality ensures 
equal opportunities, enhances research quality 
through diverse perspectives, and is already 
embedded as a requirement in Horizon Europe. 
Continuing and strengthening this approach 
will help sustain progress, improve the societal 
relevance of research outcomes, and ensure fair 
participation across the european research area. 

Gender is relevant for the EU external action 
funds as it ensures that gender equality is 
systematically integrated into all aspects of 
external action policy and programming. 
Persistent gender disparities have hindered 
inclusive development, stability, and 
peacebuilding efforts—areas central to EU 
external actions. Forward-looking, gender 
mainstreaming aligns with the EU’s strategic 
priorities and international commitments, such 
as the Sustainable Development Goals and the 
Gender Action Plan III, by promoting equitable 
outcomes, empowering women and girls, and 
enhancing the effectiveness, accountability, and 
sustainability of EU-funded interventions 
worldwide. 

Gender mainstreaming is not particularly 
relevant for the Connecting Europe Facility 
(CEF). In the CEF Transport strand, the 
primary focus is on large-scale infrastructure 
projects such as railway corridors, which are 
fundamentally different from local or regional 
infrastructure where gender relevance might be 
more pronounced. Additionally, CEF does not 
finance passenger train stations, which could 
have more direct implications for gender 
equality by affecting passengers. Consequently, 
the emphasis on large-scale infrastructure 
projects and the areas funded by CEF present 

107 

 
 
 
Erasmus – European 
Solidarity Corps 

Yes 

Creative Europe – Citizens, 
equality, rights and values 

Yes 

Union Civil Protection 
Mechanism 

Yes 

limited opportunities for addressing gender-
specific needs within this framework. CEF 
2021-2027 has been assigned a score of 0 for 
its contribution to gender equality.  

Gender mainstreaming is relevant for both 
Erasmus and European Solidarity Corps. These 
programmes have aimed to promote inclusion, 
diversity, and equal opportunities—values that 
are undermined without a gender-sensitive 
approach. Forward-looking, gender 
mainstreaming is essential to foster truly 
equitable access and participation for all, 
empower underrepresented groups, and prepare 
young people to become active, inclusive 
citizens in a rapidly evolving European society. 
It strengthens the impact and social fairness of 
these initiatives. 

Gender mainstreaming is relevant for the 
Creative Europe – Citizens, equality, rights and 
values fund because it ensures inclusive and 
equitable participation in cultural and civic life, 
promotes fair representation, combats 
stereotypes, and strengthens democracy by 
fostering inclusion and participation. 
Integrating gender perspectives enhances the 
fund’s impact, ensuring it supports a vibrant, 
pluralistic, and just European society. 

Gender mainstreaming is relevant for the Union 
Civil Protection Mechanism because it ensures 
that disaster risk reduction and response 
measures address the different needs, 
vulnerabilities, and strengths of all genders. 
Historically, women, girls, and other 
marginalized groups have often faced greater 
risks and barriers during emergencies due to 
unequal access to resources, decision-making, 
and protection. Looking forward, integrating 
gender perspectives enhances the effectiveness, 
equity, and sustainability of disaster response 
by promoting inclusive planning, empowering 
diverse community roles, and ensuring that no 
group is left behind in resilience-building 
efforts. 

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Single Market Programme +  No 

Justice programme 

Yes 

Euratom Research and 
Training - ITER 

No 

Instrument for Nuclear 
Safety cooperation and 
decommissioning 

No 

The gender dimension does not seem relevant 
for this programme, given its objectives. Its 
target group is national public administrations 
rather than individuals or legal entities in a 
socio-economic sense. The programme focuses 
on administrative efficiency, regulatory 
compliance, and fraud prevention. As such, it is 
not expected to have a significant impact on the 
social situation or position of women and men, 
and therefore does not present a clear gender-
differentiated effect. 
Gender mainstreaming is relevant for the EU 
Justice programme as it addresses long-
standing gender disparities in access to justice, 
protection from gender-based violence, and 
equal treatment under the law. It will also 
support the EU’s commitment to equality, non-
discrimination, and inclusive justice systems, 
enabling more effective responses to evolving 
social challenges. By embedding gender 
considerations, the programme promotes fairer 
legal outcomes and strengthens democratic 
values across member states. 

The gender dimension does not seem relevant 
for these programmes, given their objectives. 
The Euratom Research and Training and ITER 
programmes fund advanced nuclear research, 
including the development of nuclear fusion 
technologies. They involve international 
scientific partnerships, long-term engineering 
efforts, and support to public research 
institutions. Unlike other areas of research and 
innovation, there does not seem to be a clear 
gender dimension from the perspective of the 
content of the research.  

The gender dimension does not seem relevant 
for this programme, given its objectives. This 
programme supports actions to improve nuclear 
safety within the EU and in partner countries, 
including regulatory cooperation, capacity 
building, and technical assistance. Its focus is 
on aligning safety practices with international 
standards and supporting institutional 
development in the nuclear sector. Its target 
group consists of institutional actors. The 

109 

 
 
Nuclear decommissioning 
LT 

No 

Turkish-Cypriot Community  Yes 

Overseas Countries and 
Territories (incl. Greenland) 

Yes 

programme does not seem to have a significant 
gender impact. 

The gender dimension does not seem relevant 
for this programme, given its objectives. This 
programme supports the safe and efficient 
decommissioning of nuclear facilities in 
Lithuania, in line with EU safety standards and 
environmental protection objectives. Its 
implementation is highly technical, involving 
infrastructure dismantling, radioactive waste 
management, and site remediation. Its target 
group comprises national implementing bodies 
and specialised contractors. The programme 
focuses on technical operations such as 
dismantling infrastructure and managing 
radioactive waste. Therefore, it does not 
generate significant gender-differentiated 
impacts. 

Gender mainstreaming is relevant for the EU 
Turkish-Cypriot Community programme as it 
ensures inclusive development by addressing 
historical gender inequalities and promoting 
equal participation in social, economic, and 
political life. It acknowledges the 
underrepresentation and systemic challenges 
faced by women within the community. By 
integrating gender perspectives into all stages 
of programming, the initiative can more 
effectively meet the diverse needs of the 
community and contribute to long-term, 
inclusive growth. 

Gender mainstreaming is relevant for the EU 
Overseas Countries and Territories (OCTs) 
programme, including Greenland, both in terms 
of addressing past inequalities and shaping a 
more equitable future. Historically, gender 
disparities in access to resources, decision-
making, and opportunities have been prevalent 
in many OCTs, and gender mainstreaming 
ensures that policies and projects take these 
disparities into account. By integrating gender 
equality into development planning, the EU can 
foster more inclusive growth and address 
gender specific challenges, while promoting 

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Pericles 

No 

social justice and human rights across its 
territories. 

The gender dimension does not seem relevant 
for this programme, given its objectives. The 
Pericles programme aims to prevent and 
combat counterfeiting of the euro through 
training, technical assistance, and the 
strengthening of operational cooperation 
among competent national and European 
authorities. Its beneficiaries are public 
authorities such as police forces, financial 
crime units, customs, and judicial institutions. 
Pericles is narrowly focused on financial 
security and protection against organised crime. 
It does not target people. The technical nature 
of its interventions and the institutional profile 
of its actors provide no leverage for pursuing 
gender equality outcomes.  

The Performance Regulation will set out dedicated rules regarding the mainstreaming of gender 
equality  across  EU  budget  programmes.  It  will  also  include  dedicated  articles  setting  out 
specific  provisions  for  each  management  mode,  providing  for  the  systematic  integration  of 
gender equality in Member States and third countries plans, in calls under direct management 
as well as by implementing partners under indirect management. 

6.4 Do No Significant Harm  

Following adoption of the IIA for the 2021-2027 MFF – which refers to the contribution of the 
Union  budget  to  the  European  Green  Deal  and  the  ‘do  no  harm’  principle  –  the  ‘do  no 
significant  harm’  (DNSH)  principle  has  been  applied  across  an  increasing  number  of  MFF 
programmes,  with  the  respective  approaches  listed  in  the  Climate  Mainstreaming  SWD 

111 

 
 
 
 
 
(2022)84.  Specifically  the  RRF  Regulation  provides  that  no  measure  included  in  a  Member 
State’s Recovery and Resilience Plan (RRP) should lead to significant harm to any of the six 
environmental objectives within the meaning of Article 17 of the EU Taxonomy Regulation85. 
The  InvestEU  Fund  uses  sustainability  proofing  guidance  to  operationalise  the  DNSH 
principle.  In  addition,  the  DNSH  principle  will  be  applicable  in  different  forms  to  the 
Modernisation and Innovation Fund from 2025 (applying the Taxonomy delegated acts when 
technical  screening  criteria  have  been  developed  for  the  concerned  activity)  and  the  Social 
Climate Fund from 2026 (through the development of a dedicated guidance).  
The Financial Regulation recast86 further states that ‘programmes and activities shall, where 
feasible and appropriate in accordance with the relevant sector-specific rules, be implemented 
to achieve their set objectives without doing significant harm to the environmental objectives 
of climate change mitigation, climate change adaptation, the sustainable use and protection of 
water and marine resources, the transition to a circular economy, pollution prevention and 
control and the protection and restoration of biodiversity and ecosystems’. 

While the DNSH principle has been applied to most relevant programmes, the approach has 
not  been  coordinated  nor  harmonised  between  these  programmes.  A  2023  study  by  JRC 
examined  the  approach  to  DNSH  operationalisation  in-depth  for  a  select  number  of 
programmes,  illustrating  the  varied  landscape  of  DNSH  operationalization  under  the  2021-
2027 policy cycle87. 

Overall,  the  implementation  of  the  DNSH  principle  across  various  EU  budget  programmes 
under the 2021-2027 period presents a complex design with varying degrees of integration and 
operational depth. As the JRC report notes,88 this heterogeneity in DNSH application may lead 
to inconsistent results and create challenges for implementation. 

Depth  and  complexity  of  DNSH  implementation:  Some  programmes  have  thoroughly 
integrated DNSH into their operational frameworks, while others have not implemented it or 
have done so to a lesser extent. The differences can be attributed to the varying legal bases and 
the  specific  objectives  of  each  programme.  For  instance,  programmes  with  a  strong 
environmental focus like LIFE have a more detailed approach, while others, such as the Fiscalis 
programme, may not address DNSH due to the nature of their activities. In addition, the depth 
and complexity vary even between programmes with a similar approach towards DNSH.  

Inconsistencies  and  fragmentation  across  MFF  programmes:  Due  to  the  variance  in 
approach towards DNSH, there is a notable inconsistency and fragmentation in how DNSH is 
applied. The same type of interventions might be treated differently across programmes, which 

84  COMMISSION  STAFF  WORKING  DOCUMENT  Climate  Mainstreaming  Architecture  in  the  2021-2027 
Multiannual Financial Framework  
85 Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment 
of a framework to facilitate sustainable investment 
86 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) 
87 Beltran Miralles, M., Gourdon, T., Seigneur, I., Arranz Padilla, M. and Pickard Garcia, N., The implementation 
of the ‘Do No Significant Harm’ principle in selected EU instruments, Publications Office of the European Union, 
Luxembourg, 2023, doi:10.2760/18850, JRC135691. 

88  The  implementation of  the  ‘Do  No  Significant  Harm’  principle  in  selected  EU  instruments,  Joint  Research 
Center, JRC Publications Repository - The implementation of the ‘Do No Significant Harm’ principle in selected 
EU instruments 

112 

 
 
 
 
may generate challenges for beneficiaries eligible under different EU budget programmes. For 
example, an energy efficiency project might be subject to strict DNSH requirements under the 
LIFE Programme but  not  under  another programme with  a different legal  basis. Additional 
technical  guidances  for  some  funds  have  led  to  the  parallel  application  of  several  sets  of 
technical criteria, creating complexities for project implementers who must navigate both the 
DNSH criteria from EU fund guidance and the EU Taxonomy. 

Challenges faced by Member States and beneficiaries: The diverging application of DNSH 
has  resulted  in  additional  administrative  burden.  Member  States  and  project  beneficiaries, 
including businesses, face heterogeneity in requirements, leading to uncertainties and a lack of 
predictability. This can impact the competitiveness of sectors supported by EU funds, as they 
grapple with the administrative complexities associated with different DNSH applications. In 
addition, inconsistent approaches limit the synergies among EU funding instruments and hinder 
the overall contribution to the EU climate and environmental objectives. These divergences 
can prevent the efficient combination of support from different Union funds 

Future applications of DNSH: The financial regulation recast acknowledges the challenges 
by stipulating that DNSH should be applied where "feasible and appropriate." This provision 
aims to provide some flexibility and recognizes the need for a balanced approach to applying 
DNSH across diverse programmes, suggesting a more harmonised and streamlined application 
in the future. 

Table: DNSH application in the 2021-2027 programmes 

Programme 

DNSH application 

Horizon Europe  DNSH is integrated at project level and screened during the co-creation 
of work programs, though not uniformly applied across all parts of the 
program. 

InvestEU  

The InvestEU Regulation establishes the need for the operations to be 
funded to go through a sustainability proofing process, and the related 
guidance needs to take appropriate account do no significant harm. The 
InvestEU Regulation does not lay down that the operations must comply 
with  the  DNSH  principle.  However,  the  sustainability  proofing 
methodology has integrated to some extent the DNSH principle. There 
is  an  exemption  from  sustainability  proofing  for  projects  below  a 
specific threshold (generally 10 million euro) 

Connecting 
Europe  Facility 
(CEF) 

Applied 
proofing, and sustainability criteria in project selection. 

through  environmental 

legislation  compliance,  climate 

European  Space 
Programme 

Incorporates  DNSH  through  specific  templates  for  downstream 
Copernicus services to ensure they do not harm the environment. 

Regional  Policy 
Funds 
(ERDF, 
CF, ESF+) 

is  operationalized 

screenings,  environmental 
through 
DNSH 
assessments,  climate  proofing,  and  monitoring  within  operational 
programs. 

113 

 
 
and 

Recovery 
Resilience 
Facility (RRF) 

Follows  technical  guidance  on  DNSH,  with  ex  ante  assessments  that 
national plans do no significant harm to environmental objectives within 
the meaning of Article 17 of the EU Taxonomy Regulation. 

Technical 
Support 
Instrument (TSI) 

Not  directly  applicable  as  the  programme  provides  expertise,  i.e.  not 
direct  funding,  but  it  ensures  that  support  activities  do  not  contradict 
DNSH principles. 

Common 
Agricultural 
Policy (CAP) 

European 
Maritime, 
Fisheries 
and 
Aquaculture Fund 
(EMFAF) 

Integrated  through  strategic  planning  and  reviews,  with  provisions  to 
avoid environmentally harmful activities. 

Ensures compliance through conditions and exclusion of operations that 
could cause harm, guided by its regulation. 

LIFE Programme 

Embeds  DNSH  in  each  sub-programme,  with  stringent  screening 
against the EU Taxonomy's environmental objectives. 

Transition 

Just 
Mechanism 
(JTM) 

Neighbourhood, 
Development  and 
International 
Cooperation 
Instrument 
(NDICI  Global 
Europe) 

Assigns  a  100%  climate  coefficient  to  all  investments,  reflecting  the 
focus on supporting regions transitioning towards a green economy. 

Adopts  a  positive  approach,  excluding  activities  not  aligned  with 
climate  commitments,  with  mandatory  environmental  screenings  and 
mainstreaming DNSH through an ex-ante screening of projects. 

Social  Climate 
Fund (SCF) 

Additional guidance with annexes providing technical screening criteria 
for activities covered by the fund to comply with DNSH. 

Figure: JRC 2023 study on DNSH 

114 

 
 
 
DNSH application under the post-2027 programmes 

The Performance Regulation will set out dedicated rules regarding the application of the DNSH 
principle across EU budget programmes, including the development of a technical guidance to 
support  future  implementation.  It  will  also  include  dedicated  articles  setting  out  specific 
provisions for each management mode, providing for the systematic integration of DNSH in 
Member  States  and  third  countries  plans,  in  calls  under  direct  management  as  well  as  by 
implementing partners under indirect management. 

115 

 
 
 
 
 
 
ANNEX 7: MONITORING FRAMEWORK OF THE 2021-2027 BUDGET 

7.1 Tracking of expenditures in the EU budget 

7.1.1.1 Tracking of expenditures contributing to horizontal priorities  

The interinstitutional agreement on the 2021-2027 MFF introduced the following horizontal 
commitments: a climate spending target (30% of the EU budget), a biodiversity spending target 
(7.5% in 2024 and 10% in 2026-2027), report on the EU budget contribution to Sustainable 
Development Goals (SDGs), as well as the requirement to monitor gender equality expenditure. 
The latter is analysed in detail under subsection 7.1.2 ‘Gender equality tracking’. However, 
the  monitoring  of  cross-cutting  priorities  still  requires  further  refinement.  While  significant 
progress has been made – figures reflecting the EU budget's contributions to key priorities are 
now more robust and reliable thanks to substantial structuring efforts – challenges remain.  

On the one hand, a unified tracking system to monitor the current crosscutting issues has yet to 
be established. For green priorities, the Common Agricultural Policy and external funds still 
do not fully align with the intervention field methodology. External funds continue to rely on 
the OECD methodology based on Rio Markers, which focuses on the intent behind projects 
rather than their concrete, expected outcomes. This can lead to inconsistent project tagging and 
discrepancies in reporting. On the other hand, beyond the horizontal commitments introduced 
in the interinstitutional agreement, the European Commission is not able to track expenditures 
of additional cross-cutting priorities such as digitalisation, competitiveness, or defence, thus 
aligning  financial  instruments  more  closely  with  strategic  EU  priorities  and  future-proofing 
budgetary planning. 

On green priorities, agreed in the interinstitutional agreement, methodologies for climate and 
biodiversity should be developed ‘on the basis of an effective, transparent and comprehensive 
methodology’.  To  this  end,  the  Commission  decided  to  move  away  from  the  ‘OECD  Rio 
markers’ approach used in 2014-2020 and to develop a new distinct approach based on ‘EU 
coefficients’. This approach is based on a list of activities with specific coefficients decided 
ex-ante.  Such  an  approach  enhances  the  transparency  and  accountability  of  how  green 
expenditures are tracked and diminish the discretionality of the agent assigning the coefficient. 
As today, this new approach has nonetheless been only partially integrated into the EU budget, 
as  many  basic  acts  and  programmes  deviate  from  this  approach,  as  later  formalized  in  the 
communication  on  the  performance  framework  of  the  EU  budget  under  the  2021-2022 
multiannual  financial  framework.  The  new  methodological  approach  still  assigns  three 
different  coefficients  (0%,  40%  or  100%)  based  on  a  list  of  predefined  activities,  but  also 
integrating  the  taxonomy  where  relevant.  The  Commission  has  published  a  climate 
mainstreaming architecture staff working document89, where it has outlined the principles of 
its methodology, including the integration of the ‘do no (significant) harm’ principle.  

89  COMMISSION  STAFF  WORKING  DOCUMENT  Climate  Mainstreaming  Architecture  in  the  2021-2027 
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116 

 
 
 
 
 
 
On biodiversity, a dedicated tracking methodology90 was developed in 2021, using a similar 
approach to the climate methodology. In 2023, the Commission complemented the tracking 
methodology  with  a specific methodology  for the Common Agricultural  Policy, taking into 
consideration  the  adopted  strategic  plans.  More  details  are  available  in  the  Biodiversity 
Financing and Tracking Report.91 

On  SDGs,  although  the  European  Commission,  in  its  2021  Inter-Institutional  Agreement, 
mandated annual reporting on the EU's contribution to the SDGs92, this requirement has been 
met with challenges due to the high-level, cross-sectoral nature of the SDGs. Fragmentation 
across  MFF  programs  is  evident,  with  some  EU  programs  like  Horizon  Europe  explicitly 
incorporating SDGs in  their objectives, while others only  reference them indirectly or omit 
them entirely.93 This inconsistency undermines a unified, coherent approach to aligning EU 
financial instruments with global sustainability commitments and makes it difficult to gauge 
the collective impact of EU programs on the SDGs. Additionally, the annual reports produced 
by the Commission, as required by the IIA, offer limited added value because of their broad, 
over-arching  nature.  These  reports  present  high-level  summaries  that  do  not  provide  the 
actionable  insights  necessary  to  promote  policy  coherence  or  address  specific  gaps  in  SDG 
implementation.94 

Table: Contribution to SDGs in the 2021-2027 programmes 

Programme  

Sustainable Development Goal  

Total  

Horizon  

SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 
17 

17  

Euratom  

/  

ITER  

SDG: 7, 8, 9, 13, 17  

InvestEU  

SDG: 1, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15  

CEF  

SDG: 7, 9, 11, 13  

Digital Europe  

SDG: 3, 4, 8, 9, 13, 16  

Single market  

SDG: 7, 8, 9, 11, 12, 13, 16  

Anti-fraud  

SDG: 10, 16  

0  

5  

14  

4  

6  

7  

2  

90  https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-6cb0fadf29dc/library/b29ffe93-f385-4f9b-b6b7-
4695a1266edd/details?download=true  
91 European Commission, Biodiversity financing and tracking, Biodiversity financing and tracking - Publications 
Office of the EU 
92 European Parliament and Council, Interinstitutional Agreement on Budgetary Matters, 2021.  
93 European Commission, Analysis of SDG Mainstreaming in EU Programmes, 2022. 
94 European Commission, Annual Report on SDG Contributions, 2023. 

117 

 
 
 
 
 
2  

2  

11  

2  

12  

13  

Fiscalis  

SDG: 8, 9  

Customs  

SDG: 8, 9  

EU Space  

SDG: 2, 3, 5, 6, 7, 9, 11, 13, 14, 15, 17  

Secure 
Connectivity 

SDG: 5, 9  

Regional policy  

SDG: 1, 3, 4, 5, 6, 7, 8, 9, 11, 12, 13, 15  

TCC  

RRF  

TSI  

SDG: 2, 3, 4, 5, 6, 7, 8, 9, 11, 12, 14, 15, 16  

SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16  

16  

SDG: 1, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16  

14  

Pericles IV  

SDG: 8, 9  

UCPM  

SDG: 3, 6, 11, 13, 14, 15  

EU4Health  

SDG: 3 

ESI  

ESF+  

SDG: 3  

SDG: 1, 2, 3, 4, 5, 7, 8, 10, 11, 12, 13  

Erasmus  

SDG: 3, 4, 5, 8, 11, 12, 13, 16  

ESC  

Justice  

CERV  

SDG: 3, 4, 5, 8, 10, 11, 13  

SDG: 3, 5, 10, 16  

SDG: 4, 5, 8, 10, 16, 17  

Creative  

SDG: 3, 4, 5, 8, 10, 11, 12, 16, 17  

Communication  

SDG: 2, 3, 4, 5, 6, 7, 8, 9, 11, 13, 14, 15, 16  

CAP  

SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 13, 15, 17 

EMFAF  

SDG: 1, 2, 3, 5, 14  

Fisheries  

SDG: 14  

2  

6  

1  

1  

11  

8  

7  

4  

6  

9  

13  

14  

5  

1  

Life  

SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16  

16  

118 

 
 
5  

1  

1  

1  

1  

3  

1  

0  

3  

8  

2  

SDG: 1, 3, 4, 5, 7, 8, 9, 10, 11, 12, 13, 15  

12  

JTM  

AMIF  

IBMF  

ISF  

SDG: 3, 4, 10, 15, 16  

SDG: 10  

SDG: 16  

ND LT  

SDG: 12  

NSD  

EDF  

ASAP  

SDG: 12  

SDG: 7, 8, 9  

SDG: 9  

EDIRPA  

/  

NDICI  Global 
Europe 

SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 
17  

17  

INSC  

SDG: 5, 11, 16  

HUMA  

SDG: 1, 2, 3, 4, 5, 6, 13, 17  

CFSP  

OCT  

SDG: 5, 16  

SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 
17  

17  

MFA  

/  

IPA III  

SDG: 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16, 17  

Western  Balkans 
Facility  

/  

Ukraine Facility  

/  

EGF  

EUSF  

IF  

BAR  

SDG: 4, 5, 8, 10  

SDG: 3, 10, 13  

SDG: 7, 9, 13 

/  

119 

0  

14  

0  

0  

4  

3  

3  

0  

 
 
Modernisation 
Fund  

SCF  

/  

/  

0  

0 

Digital expenditure tracking remains ad-hoc and inconsistent. Unlike climate and biodiversity, 
digital tracking does not have a standardised framework and primarily relies on Reporting from 
the Recovery and Resilience Facility (RRF).95 This fragmentation complicates efforts to track 
progress comprehensively across the EU's policy priorities and budget. 

Lastly,  at  present,  the  European  Commission  is  not  equipped  to  effectively  track  other 
horizontal priorities like digitalisation, competitiveness, or security. This is a significant gap, 
as these areas are increasingly crucial in shaping policies that drive economic growth, enhance 
regional  stability,  and  ensure  the  EU’s  adaptability  to  global  challenges.  Tracking  these 
priorities would provide valuable insights into financial allocations and their impacts, guiding 
strategic investments and policy adjustments. The absence of such tracking mechanisms limits 
the EU's ability to align its financial strategies with broader socio-economic goals effectively. 

Figure:  Possible  functioning  of  single  methodology  to  track  expenditures  through 
intervention fields, and common set of indicators in the post-2027 programmes 

95 European Commission, Ad-hoc Digital Spending Reports, 2023. 

120 

 
 
 
 
 
 
 
 
Figure: Example of intervention fields, policy priorities and indicators under the single 
methodology in the post-2027 programmes 

Figure: Monitoring provisions per management mode in the post-2027 programmes 

121 

 
 
 
 
 
 
 
 
 
7.1.2. Gender equality tracking  

The Interinstitutional Agreement for the 2021-2027 Multiannual Financial Framework (MFF) 
required  the  Commission  to  develop  a  methodology  to  measure  the  relevant  EU  budget 
expenditure supporting gender equality. However, the agreement did not set out any spending 
targets  for  gender  equality,  contrary  to  other  priorities  (climate  and  environment).  The 
Commission developed this methodology in the context of the Draft Budget 2023 in 2022 and 
it  has  implemented  it  since.  It  is  based  on  assigning  the  following  gender  scores  to  budget 
interventions. 
EU budget methodology to estimate expenditure contributing to gender equality: 

Gender score 2: 

Gender score 1:  

Interventions whose principal objective is to 
improve gender equality;  

Interventions that have gender equality as an 
important and deliberate objective but not as 
the main reason for the intervention; 

Gender score 0:  

Gender score 0*:  

Non-targeted  interventions  (interventions 
that  are  expected  to  have  no  significant 
bearing on gender equality); 

Interventions with potential gender impact, 
but  for  which  there  is  insufficient  data 
available 

Since its implementation in 2022, the gender tracking methodology has enhanced transparency 
by identifying budget contributions to gender equality (scores 1 and 2) across EU programmes. 
This  has  also  led  to  a  significant  decline  in  score  0*  from  95%  to  20%  in  2023,  reflecting 
improved implementation and data availability. Additionally, interventions under scores 1 and 
2 have increased substantially, with score 1 quadrupling and score 2 tripling since 2021. 

Nevertheless,  the  introduction  of  the  new  gender  tracking  methodology  in  2022,  after  the 
adoption of the 2021–2027 programmes basic acts, has led to inconsistencies and difficulties 
in aligning data, tracking and monitoring with a coherent set of gender equality objectives. This 
is largely due to the timing and design misalignment. When the methodology was introduced, 
the  basic  acts  for  many  programmes  had  already  been  finalized,  leaving  little  room  to 
incorporate gender considerations into their structure. As a result, many programmes were not 
designed  with  the  tracking  methodology's  requirements  in  mind,  leading  to  fragmented 
approaches across different programmes. 

This  delay  and  misalignment  created  a  lack  of  cohesion  in  the  EU's  approach  to  gender 
expenditures monitoring. Various programmes adopted different tracking methodologies, such 
as  the  Common  Provisions  Regulation  tracking  methodology,  the  Recovery  and  Resilience 
Facility flagging methodology, and the Common Foreign and Security Policy marker system. 
These divergent methodologies make it challenging to implement a consistent tracking system 
across the entire EU budget, further complicating the evaluation of how funds contribute to 
gender equality. 

Consequently, a significant portion of the EU budget – 69% – is assessed as not contributing 
to  gender  equality  (score  0).  This  indicates  that  the  potential  for  the  EU  budget  to  support 

122 

 
 
 
 
gender equality remains underutilized. Moreover, 20% of the budget is classified as score 0*, 
representing measures with the potential for significant impact on gender equality, but where 
the actual impact remains unclear. Notably, a large part of this score 0* budget corresponds to 
the  Common  Agricultural  Policy,  which  began  implementation  under  its  new  regulation  in 
2023.96 

Another critical issue is the lack of gender-disaggregated data. Many EU budget programmes 
do not collect or report data broken down by gender, making it challenging to evaluate the real 
impact  of  gender-related  investments.  This  is  particularly  the  case  for  programmes  under 
shared  and  indirect  management,  where  the  availability  of  gender-disaggregated  data  is  not 
necessarily foreseen by programme regulations and implementation agreements. Without such 
data,  it  is  difficult  to  measure  contributions  to  gender-equality,  assess  the  effectiveness  of 
programmes, and make informed decisions about future funding. This lack of clarity hampers 
the EU's ability to ensure that its budget actively contributes to advancing gender equality and 
adds  to  the  significant  challenges  in  implementing  a  coherent  gender  mainstreaming  and 
tracking  approach.  The  absence  of  such  data  in  the  current  EU  budget  has  resulted  in  a 
significant data gap on gender equality. However, the financial regulation – Article 33.3 – now 
mandates the collection of gender-disaggregated data, aiming to address this gap and improve 
the evaluation and impact of gender-related initiatives moving forward. 

The Financial Regulation – Article 33 – explicitly mandates that EU budget programmes be 
implemented,  where  feasible  and  appropriate,  taking  into  account  the  principle  of  gender 
equality and in accordance with an appropriate gender mainstreaming methodology.  

Gender equality tracking under the post-2027 programmes 

A  single,  harmonised  gender  equality  tracking  methodology  could  be  established,  building 
upon  the  existing  Commission  gender  tracking  system.  Integrating  this  methodology  into  a 
horizontal framework would ensure that programmes incorporate gender equality requirements 
and scoring system from the design stage. 

A standardised gender tracking methodology would offer significant advantages, particularly 
in enhancing coherence and reducing administrative burdens for beneficiaries, Member States 
and EU institutions. A single methodology – based on the existing Commission system and 
aligned with the OECD framework – would create a harmonised approach, ensuring consistent 
assessment across all programmes. Such harmonisation would improve data comparability and 
facilitate more accurate evaluations,  leading  to  stronger evidence-based decision-making. A 
single  methodology  would  also  replace  multiple  programme-specific  tracking  methods, 
streamlining monitoring and reporting processes.  

Applying the revised methodology across MFF programmes would also guarantee that gender 
tracking  considerations  are  integrated  from  the  outset.  This  proactive  approach  addresses  a 
fundamental  weakness  of  the  current  system,  where  gender  tracking  is  often  applied 
inconsistently  or  only  retrospectively.  A  single  methodology  could  also  help  clarify  the 
treatment  of  complex  elements,  such  as  tracking  zero-cost  reforms,  which  are  currently 
insufficiently analysed. 

Under the single methodology, the tracking of expenditure promoting gender equality in the 
next MFF would be carried out using the system of gender scores, also making a connection to 

96 Annual Management and Performance Report for the EU budget – Annex I – 3. Horizontal policy priorities in 
the EU 

123 

 
 
 
intervention  fields  for  tracking  expenditures.  Unlike  other  areas  such  as  climate  and 
biodiversity, the promotion of gender equality could be done throughout most interventions 
(e.g.  digital  trainings  could  encourage  female  participation,  or  grant  funding  could  require 
enterprises to have a gender equality plan in place). Therefore, the list of intervention fields 
could include fields for gender score 2 actions specifically i.e. interventions for which gender 
equality would be the main objective.  

Other  EU  budget  interventions  –  tagged  through  a  dedicated  intervention  field  -  would  be 
tagged with a gender score of 0, 1 or 2 based on their specific design. The relevance of working 
with all intervention fields to identify categories expected to be relevant for gender equality 
due  to  their  direct  impact  on  persons  (score  1)  or  with  potential  to  support  gender  equality 
objectives if implemented in a way that is responsive to gender equality objectives should be 
explored. This may also be useful for intervention fields non relevant for gender equality (score 
0),  i.e.  the  possibility  to  pre-determine  some  intervention  fields  as  non-relevant  for  gender 
equality should also be considered. 

In  summary,  adopting  a  unified  gender  tracking  methodology  aligned  with  the  OECD 
framework would resolve the inconsistencies, inefficiencies, and complexities that hinder the 
current  system.  This  transition  provides  an  opportunity  to  enhance  coherence,  improve 
programme design and implementation, and reduce administrative burden, thereby advancing 
the EU’s commitment to gender equality in a more effective and transparent manner. 

Under  direct  management  programmes,  the  Commission  would  apply  the  gender  tracking 
methodology to the EU budget programmes and interventions fields. 

Under shared management programmes, national authorities would assign a gender score to 
interventions – a practice in place already in the Common Provisions Regulation funds in the 
2021-2027 period. For instance, the categorisation of the gender equality dimension occurs at 
the level of a specific objective within a programme, reflecting a targeted approach to ensuring 
that gender considerations are adequately addressed. Even in cases where an entire programme 
may not appear to contribute directly to gender equality, Member States managing authorities 
are responsible for identifying and highlighting actions or smaller sections of the programme 
specifically  aimed  at  advancing  gender  equality.  Financial  data  on  the  cost  of  selected 
operations and declared expenditure is reported to the Commission five times per year. This 
reporting is organised by categorisation dimension, meaning that each submission updates the 
amounts  associated  with  gender-targeted  or  gender-mainstreaming  actions  within  cohesion 
policy programmes. The Commission then reviews this data, enabling regular monitoring of 
the  financial  commitment  to  gender  equality  and  supporting  evidence-based  adjustments  to 
enhance the integration of gender perspectives across EU-funded programmes. Additionally, 
for  each  score,  a  brief  narrative  explanation  should  be  provided,  particularly  for  measures 
categorized as score 0 (not gender relevant), to ensure that these measures do not inadvertently 
harm gender equality.  

Under indirect management, agreements with implementing partners would include specific 
provisions for applying the methodology. This would include requirements for assessing and 
tagging gender-relevant measures and conducting impact assessments. The Commission would 
oversee and verify that implementing partners adhere to the gender analysis requirements and 
reporting standards. 

Finally, the recast Financial Regulation now requires the collection of  gender-disaggregated 
data, where appropriate. Gender-disaggregated indicators would allow for systematic tracking 
of how resources are allocated and the differential impacts on women and men. Incorporating 

124 

 
 
into  performance  frameworks  would  enable 

to  enhance 
gender-disaggregated  data 
transparency,  enable  more  accurate  assessments  of  gender-related  investments,  and  inform 
evidence-based decision-making. Ensuring that indicators are disaggregated by gender would 
strengthen the EU’s capacity to measure progress and adjust strategies to meet gender equality 
objectives effectively. 

One of the policy options that is sometimes recommended is to introduce a negative score to 
track expenditures contributing negatively to gender equality i.e. harming gender equality. The 
Commission’s gender tracking methodology is inspired by the OECD approach, which does 
not incorporate negative scoring. Maintaining alignment with the OECD is crucial for ensuring 
consistency  with  internationally  recognized  standards.  Introducing  negative  scores  would 
create a divergence from this established framework, undermining the comparability of gender 
equality  efforts  at  the  international  level  and  potentially  leading  to  confusion  within  EU 
institutions and among member states. inconsistency could complicate both the tracking and 
reporting processes, making it more challenging to evaluate progress in a way that aligns with 
global  benchmarks.  Introducing  negative  scoring  could  have  unintended  negative 
consequences.  It  may  discourage  innovation  by  making  programme  designers  hesitant  to 
explore new or unconventional approaches for fear of being penalized for unforeseen gender-
related  outcomes.  Gender  equality  impacts  are  often  complex  and  context-dependent,  and 
applying  negative  scores  risks  oversimplifying  these  dynamics.  This  could  lead  to 
misrepresentations  of  how  programmes  interact  with  gender  equality  objectives,  ultimately 
undermining the nuanced understanding necessary for effective policy making. The emphasis 
should  instead  be  on  enhancing  positive  contributions  to  gender  equality  rather  than  on 
penalization. A constructive approach that focuses on identifying and amplifying programmes 
that contribute positively to gender equality will foster a more supportive and forward-looking 
policy  environment.  Programmes  can  be  subjected  to  continuous  monitoring  and  periodic 
reviews  to  ensure  they  remain  aligned  with  gender  equality  goals.  If  any  issues  arise, 
adjustments  can  be  made  based  on  these  reviews,  promoting  an  adaptive  and  flexible 
framework that encourages improvement without resorting to punitive measures. Finally, from 
a legal and policy coherence perspective, the introduction of negative scoring is unnecessary. 
The EU already has robust gender equality frameworks and legal commitments in place, and 
the current  methodologies, combined with  the emphasis  on gender relevance in  programme 
design, are fully aligned with these commitments. Adding negative scoring mechanisms could 
create  unnecessary  complexity  and  legal  ambiguities,  potentially  leading  to  overlaps  or 
conflicts  with  other  evaluation  tools  and  reporting  mechanisms.  This  could  dilute  the 
effectiveness  of  existing  strategies  aimed  at  promoting  gender  equality.  In  conclusion, 
maintaining  methodological  consistency  with  the  OECD,  recognizing  the  inherent  gender 
relevance in EU budget programmes, and avoiding the potential risks associated with negative 
scoring all point to the conclusion that such a mechanism is neither necessary nor beneficial. 
The  focus  should  remain  on  fostering  positive  contributions  to  gender  equality  through 
proactive design and continuous improvement rather than through punitive tracking measures. 

Adopting a single and harmonised gender expenditure tracking framework would help address 
the inefficiencies and complexities inherent in the current fragmented system, which relies on 
a complex patchwork of tracking mechanisms. A unified framework would enable: 

1.  Simplification and streamlining: By eliminating multiple programme-specific tracking 
systems,  a  single  methodology  would  simplify  monitoring  requirements,  reduce 
administrative burdens, and promote efficiency.  

125 

 
 
2.  Improved  coherence  and  consistency:  A  harmonised  framework,  aligned  with  the 
OECD standards, would ensure uniform application of tracking methodologies across 
all EU programmes. This coherence would enhance data comparability, support more 
accurate progress evaluation, and enable evidence-based decision-making. 

3.  Proactive  integration  into  programme  design:  Embedding  the  unified  tracking 
framework  in  a  single  framework  upfront  would  ensure  that  gender  expenditure 
tracking  considerations  are  incorporated  during  programme  design  rather  than 
retroactively. This integration would address inconsistencies and improve the overall 
impact assessment. 

The adoption of such a harmonised gender expenditure tracking framework will be essential 
for simplifying and streamlining monitoring requirements across the EU budget. It represents 
a critical step towards achieving greater transparency, efficiency, and alignment with the EU’s 
strategic priorities, thereby ensuring a more effective allocation of resources and advancing 
overarching policy goals. 

126 

 
 
 
 
 
7.2 Indicators supporting the monitoring of performance of the EU budget  

Performance  indicators  are  defined  in  programme  regulations,  in  dedicated  basic  acts, 
delegated  acts  as  well  as  in  other  documents  such  as  staff  working  documents,  work 
programmes  and  agreements  with  implementing  partners.  As  a  result,  around  1 200  core 
performance  indicators  have  been  introduced,  out  of  which  76  are  used  to  report  on  the 
Cohesion Fund, ERDF, EAGF and EAFRD i.e. two thirds of the MFF, with the other ca. 1 100 
indicators being used in the context of programmes corresponding to the other third of the MFF 
and  the  RRF.  In  addition,  information  is  being  collected  based  on  ca.  7  000  indicators 
corresponding to milestones and targets under the RRF. 

The sheer abundance of information and reporting documents continues to create an overload 
of  data,  leading  to  confusion,  potentially  inconsistent  reporting,  and  a  high  administrative 
burden at all levels: beneficiaries, Member States, implementing partners, and the European 
Institutions’ services, who must collect, compile and review the data and various reports. This 
situation, already described and criticised by the European Court of Auditors97, the European 
Parliament Research Service98 and the OECD99 in the period 2014-2020, has been improved in 
the  2021-2027  period  but  not  fully  addressed.  It  remains  a  source  of  questions  from 
beneficiaries, Member States and project beneficiaries, who point out that both the information 
they are required to provide at the stage of calls for proposals as well as at the stage of reporting 
causes administrative burden to the point that puts the relevance of participating in such calls 
to question100. A study on administrative costs and burden linked to ESIF funds estimates that 
gathering information on the progress and results of the project (including financial information 
and  indicator  data)  and  submission  of  that  information  to  the  authorities  (monitoring  and 
reporting) is the most burdensome requirement for Member States and beneficiaries101. 

Some indicators are specifically used in the context of direct performance-based budgeting – 
such as under the RRF, where payments are triggered by fulfilling milestones and targets, or 
under the CAP, where result indicators are used to establish targets that, if unmet, may lead to 
payment  suspensions  or  deductions.  These  indicators  play  a  direct  role  in  EU  budget 
implementation by guiding disbursement decisions. However, programmes using indicators for 
this  purpose  are  an  exception,  as  the  vast  majority  of  indicators  are  used  for  information 
gathering  and  monitoring  purposes.  Their  number  raises  questions  about  the  relevance  and 
added value of several indicators, while the management of such indicators data sets generates 
significant administrative burden for EU institutions, Member States and MFF beneficiaries. 

The  information  thus  collected  is  not  always  aggregable.  This  is  because  indicators  were 
defined  separately  per  programme.  As  a  consequence,  a  number  of  MFF  programmes, 
including  those  that  pursue  the  same  or  similar  policy  objectives,  use  similar  yet  slightly 
different indicators to report on sometimes very similar outputs (e.g. measuring numbers of 
dwellings, buildings or houses, or measuring high-speed connectivity or 5G). This fragmented 

97 https://www.eca.europa.eu/Lists/ECADocuments/annualreports-2017/annualreports-2017-EN.pdf  
98Sapała, M. Briefing European Parliamentary Research Service. Performance budgeting – A means to improve 
EU spending, March 2018 
99 Downes, R., D. Moretti and S. Nicol (2017), "Budgeting and performance in the European Union: A review by 
the OECD in the context of EU budget focused on results", OECD Journal on Budgeting, vol. 17/1 
100 InvestEU and RRF midterm evaluations, among others. 
101  https://ec.europa.eu/regional_policy/information-sources/publications/studies/2018/new-assessment-of-esif-
administrative-costs-and-burden_en  

127 

 
 
 
and  heterogeneous  approach  leads  to  a  proliferation  of  heterogenous  and  non-aggregable 
indicators, which reduces possibilities to measure EU budget impact as a whole and to inform 
policies. At the same time, in many cases, there are no indicators that could be used to measure 
the progress towards the core aim of the activity.  

In addition to this, impact indicators or even result indicators are not designed in a manner that 
would  facilitate  the  measurement  of  long-term  outcomes  of  programmes  beyond  their 
expiration. Visibility of programmes performance after their  expiration could  potentially  be 
improved, particularly for measures funded across the duration of an MFF, such as large-scale 
infrastructure investments under CEF.  

Finally, the balance between output, result and impact indicators remains suboptimal despite 
having improved compared to previous programming periods. All three levels are essential for 
a comprehensive assessment of programme performance: output indicators provide insight into 
what  the  programme  directly  finances  and  its  immediate  activities  (e.g.  construction  of  an 
electrified railway); result indicators track the immediate effects of these outputs (shift from 
reliance on fossil fuels to the use of electricity as an energy source.); impact indicators measure 
the ultimate objectives of the intervention (greenhouse gas emissions avoided). Achieving the 
right balance among these indicators is crucial, yet this alignment has not been fully realised. 

128 

 
 
 
 
 
 
Table 8: Reporting of indicators in the 2021-2027 MFF programmes 

Programme 

Legal set up 

Status 

AMIF 

Article  33;  no  delegated  act  was  adopted; 
indicators do not impact payments 

quantitative 
and 
Qualitative 
indicators to report on the progress 
of 
the 
the  Fund 
achievement  of 
specific 
objectives. Indicators are used for 
the  midterm  evaluation.  Used  by 
Member  states  for  their  annual 
performance report.  

towards 
the 

Core 
perfor
mance 
indicat
ors 
defined 
in  legal 
basis 

Core 
perfor
mance 
indicat
ors 
NOT 
defined 
in  legal 
basis 

M&E 
indicat
ors 
defined 
in  legal 
basis 

Indicat
ors 
defined 
in 
Delegat
ed Acts 

M&E 
indicat
ors 
used, 
includi
ng 
those 
not 
defined 
the 
in 
legal 
basis 

Total 
numbe
r 
indicat
ors102 

of 

15 

41 

41 

102 Total = number of core performance indicators defined in legal basis OR number of M&E indicators defined in legal basis (when data is in the table because M&E indicators 
include core performance indicators) + number of indicators defined in Delegated Acts + number of M&E indicators used, including those not defined in the legal basis 

129 

 
 
 
 
 
 
  
  
 
 
Anti-Fraud 

Article  12;  no  delegated  act  was  adopted; 
indicators do not impact payments 

4 

quantitative 
and 
Qualitative 
indicators to report on the progress 
of  the  programme  towards  the 
achievement  of  the  general  and 
specific  objectives.  Mixed  of 
results and output indicators. 

ASAP 

BMVI 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

Article  27;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Brexit Reserve  No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

CAP 

2021/2115: 
142 
Article 
2021/2116: Article 42;  a delegated act was 
adopted; indicators impact payments 

7, 

14 

40 

quantitative 
and 
Qualitative 
indicators to report on the progress 
of 
the 
the  Fund 
achievement  of 
specific 
objectives. Indicators are used for 
the  midterm  evaluation.  Used  by 
Member  States  for  their  annual 
performance report. 

towards 
the 

indicators 

Output 
performance 
available 
reports of Member States. 

will 
through 

to  measure 
become 
the  

- Output indicators for monitoring  
-  Result  indicators  for  milestones 
and targets in CAP strategic plans 
-  Context  indicators  to  assess  the 
baseline  situation  for  preparation 
of the CAP strategic plans 

130 

29 

149 

11 
(conte
xt 
indicat
ors on 
comm

4 

0 

40 

0 

160 

 
 
 
  
  
  
  
  
 
  
  
  
 
  
  
  
 
  
  
  
 
  
CCEI 

Article  12;  a  delegated  act  was  adopted; 
indicators do not impact payments 

CEF 

Article  22;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Citizens, 
Equality,  Rights 
and Values 

Article  16  ;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Civil Protection  Article  3;  no  delegated  act  was  adopted; 

indicators do not impact payments 

- Impact indicators for evaluations 
-  Not  achieving  the  targets  may 
result in reduction of payments to 
MS (Article 41(2) of 2021/2116) 
quantitative 
and 
Qualitative 
indicators to report on the progress 
of  the  instrument  towards  the 
achievement  of  the  general  and 
specific objectives 

the  progress  of 

-  Quantitative  indicator  to  report 
the  CEF 
on 
towards  the  achievement  of  the 
general  and  specific  objectives.  
-  Mainly 
indicators 
output 
actions).  
of 
(number 
-Indicators are divided in 3 fields: 
energy, transport and digital. 

Quantitative  indicators  to  report 
on the progress of the Programme 
towards  the  achievement  of  the 
general  and  specific  objectives. 
Mixed of results and output 

Quantitative  indicators  used  for 
and 
monitoring, 
reviewing  as  appropriate 
the 
application of this Decision 

evaluating 

5 

16 

17 

4 

131 

odities
) 

11 

16 

51 

67 

17 

20 

24 

 
 
 
  
  
 
  
  
 
  
  
  
 
  
  
Cohesion 
(ERDF 
and 
Cohesion Fund) 

Article  8;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Creative Europe  Article  20;  no  delegated  act  was  adopted; 

indicators do not impact payments 

Customs 

Article  13;  a  delegated  act  was  adopted; 
indicators do not impact payments 

Indicators used by Member states 
to  report  on  the  progress  of  the 
ERDF  and  CF.  Programme-
specific  indicators  can  be  added. 
The  core  set  of  indicators  should 
be 
the 
the  basis  on  which 
Commission should report on the 
progress towards the achievement 
of specific objectives. 

Report  on  the  progress  of  the 
the 
Programme 
achievement of the objectives 

towards 

towards 

Mainly  qualitative  indicators  to 
report  on  the  progress  of  the 
Programme 
the 
achievement  of  the  general  and 
specific objectives. Rely on index 
(gathering of different indicators). 
In  DA,  more 
quantitative 
indicators 

Recital  42;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Indicators for the evaluation  

 4 

Decision  on  the 
Overseas 
Association, 
including 
Greenland 
Digital  Europe 
Programme 

47 

161 

161 

22 

15 

28 

22 

43 

4 

Article  25;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Qualitative 
indicators 

132 

and 

to  monitor 

quantitative 
the 

14 

298 

312 

 
 
 
  
  
 
  
  
  
 
  
  
 
  
  
  
 
  
  
post 

implementation  and  to  report  on 
the  progress  of  the  Programme 
towards  the  achievement  of  the 
specific 
objectives. 
10 indicators - not foreseen by the 
legal basis - are for mid-term and 
evaluation,  mainly 
ex 
contextual 
12 
quantitative; 
indicators in the framework of the 
Policy 
Digital 
Decade 
Programme;  276 
level 
indicators to monitor performance 
on  a  specific  topic  to  capture 
technical 
or  where 
details, 
individual  topics  are  not  directly 
covered by higher level indicators 

topic 

EDF 

Article  28;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Qualitative 
quantitative 
and 
indicators to report on the progress 
of 
the 
the  Fund 
achievement  of 
specific 
objectives 

towards 
the 

EFSD+ 

Article  41;  a  delegated  act  was  adopted; 
indicators do not impact payments 

Indicators  will  be  the  framework 
for  carrying  out  the  monitoring 
and 
(output, 
outcome and impact indicators) 

reporting 

tasks 

10 

19 

EGF 

Article  19;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Qualitative 
quantitative 
and 
indicators to report on the progress 

13 

133 

10 

283 

302 

13 

 
 
 
  
  
  
 
  
  
 
  
  
  
towards 

the  EGF 

the 
of 
achievement  of  the  objectives. 
They are also used for the purpose 
of  the  final  report  and  biennial 
report. 

Emergency 
Support 
Instrument 

EMFAF 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

Article  46;  no  delegated  act  was  adopted; 
indicators do not impact payments. 

-  For  reporting,  no  impact  on 
payments.  

12 

27 

0 

27 

Additionally,  the  Managing  authority  shall 
provide  the  Commission  with  operation-
level  implementation  data  defined  in  an 
implementing act. 

performance 

- 22 common result indicators and 
1  output  indicator.  There  are  12 
indicators 
core 
(some overlap with common result 
indicators)  to  be  used  by  the 
Commission  in  compliance  with 
its reporting requirement pursuant 
to  paragraph  (iii)  of  point  (h)  of 
Article  41(3)  of  the  Financial 
Regulation. -A total of 27 unique 
indicators 
the 
defined 
regulation  

in 

level  data 

to  be 
-  Operation 
reported  are  further  defined  in  a 
CIR. 

134 

 
 
  
  
 
  
  
  
 
  
  
Erasmus+ 

Article  23;  a  delegated  act  was  adopted; 
indicators do not impact payments 

quantitative 
and 
Qualitative 
indicators to report on the progress 
of  the  Programme  towards  the 
achievement  of  the  general  and 
specific  objectives.  Mixed  of 
results and output indicators 

15 

12 

27 

ERDIPA 

ESF+ 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

Article  17  -  For  general  support  from  the 
ESF+ 
(shared) 
strand 
Article  23  -  For  Priorities  addressing 
material 
(shared) 
deprivation 
Article  32  -  For  EaSi  strand  (direct) 

No delegated act was adopted; indicators do 
not impact payments 

EU 
Connectivity 

Secure 

Article  41;  no  delegated  act  was  adopted; 
indicators do not impact payments 

0 

3934
104  

4010 

76103 

target 

quantitative 
and 
Qualitative 
indicators  to  monitor  progress  in 
(for  Member 
implementation 
States).  Also  use 
to  assess 
(article 
milestones  and 
17.3). For EaSi strand, to report on 
the  progress  of  the  EaSI  strand 
towards  the  achievement  of  the 
specific  objectives.  Progress  in 
achieving  the  milestones  is  taken 
into  account 
the  mid-term 
in 
review (CRR Art. 18(1). 

and 

quantitative 
Qualitative 
indicators 
the 
implementation  and  to  report  on 

to  monitor 

39 

39 

103 indicators on persons are broken down by gender and all indicators are broken down by category of regions 
104 programme specific indicators (1890 output indicators and 2044 result indicators) 

135 

 
 
 
  
  
  
  
 
  
  
  
 
 
  
 
 
  
  
  
 
EU  Solidarity 
Fund 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

EU Space 

Article 101;  no delegated act  was adopted; 
indicators do not impact payments 

EU4Health 

Article  19;  no  delegated  act  was  adopted; 
indicators do not impact payments 

2 

36 

23 

2 

36 

42 

65 

the  progress  of  the  Programme 
towards  the  achievement  of  the 
specific objectives 

and 

to  monitor 

quantitative 
Qualitative 
indicators 
the 
implementation  and  to  report  on 
the  progress  of  the  Programme 
towards  the  achievement  of  the 
specific 
for 
objectives 
multiannual plan. 

and 

purpose: 
to 

quantitative  indicators  to  monitor 
the  implementation  and  to  report 
on the progress of the Programme 
towards  the  achievement  of  the 
objectives. 
specific 
Several 
Core 
monitor 
performance 
Programme’s annual performance 
and 
its 
objectives. 
Key performance indicators serve 
as  a  reference  for  the  annual 
performance 
reporting 
action-level  indicators  that  are 

progress 

towards 

136 

 
 
  
  
  
  
  
 
  
  
  
 
  
  
Euratom 

Article  12;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Article  14;  no  delegated  act  was  adopted; 
indicators do not impact payments 

for 

European 
Instrument 
International 
Nuclear  Safety 
Cooperation 

European 
Solidarity Corps 

Article  20;  a  delegated  act  was  adopted; 
indicators do not impact payments 

Financial 
for 
Statement 
Macro Financial 
Assistance 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

available  to  monitor  the  outputs 
and results of each action funded. 
Other 
the 
EU4Health dashboard 

indicators 

for 

Qualitative 
quantitative 
and 
indicators  to  report  on  an  annual 
the 
basis  on 
Euratom  Programme  towards  the 
achievement of the objectives 

the  progress  of 

measure 
to 
Indicators 
achievements  of  the  objective  of 
the  Instrument.  Indicators  are 
included in Multiannual indicative 
programmes. 

Qualitative 
quantitative 
and 
indicators to report on the progress 
of  the  Programme  towards  the 
achievement  of  the  general  and 
specific  objectives.  Mixed  of 
impact 
results, 
indicators 

output 

and 

137 

34 

3 

14 

34 

3 

5 

19 

0 

 
 
 
  
  
  
 
  
  
  
 
  
  
  
  
 
  
  
  
Fiscalis 

Article  14;  a  delegated  act  was  adopted; 
indicators do not impact payments 

Fisheries 
agreements 

 No  specific  performance  indicators  are 
defined  in  the  SFPAs;  indicators  do  not 
impact payments 

Horizon Europe  Article  50;  no  delegated  act  was  adopted; 

indicators do not impact payments 

16 

24 

40 

5  

5 

30 

151 

181 

towards 

Mainly  qualitative  indicators  to 
report  on  the  progress  of  the 
Programme 
the 
achievement  of  the  general  and 
specific objectives. Rely on index 
(gathering of different indicators). 
In  DA,  more 
quantitative 
indicators 

- The progress of the programmes 
the  basis  of 
is  followed  on 
for 
quantifiable 
periodic monitoring  

indicators 

the  progress  of 

Qualitative 
quantitative 
and 
indicators  to  report  on  an  annual 
basis  on 
the 
Programme  towards  achievement 
the 
the  objectives,  within 
of 
framework 
database. 
of 
Additional indicators can be used 
to  monitor individual Programme 
parts 

a 

Humanitarian 
Aid Programme 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

20 

20 

Innovation Fund  No delegated act was adopted; indicators do 

14 

14 

not impact payments 

138 

 
 
 
  
  
  
 
  
  
 
  
  
  
  
 
  
  
  
  
  
  
  
36 

18 

200 

236 

122 

140 

InvestEU 

Article  28;  a  delegated  act  was  adopted; 
indicators do not impact payments 

impact 
Output,  outcome  and 
indicators. No impact on payment. 
M&E framework to be established 
to  track  progress  towards  the 
Union's objectives.  

IPA III 

Article  13;  no  delegated  act  was  adopted; 
indicators impact payments 

of 

and 

for  monitoring 

quantitative 
Qualitative 
the 
indicators 
implementation  and  progress  of 
IPA  III  towards  the  achievement 
of  the  specific  objectives.  The 
the 
assessment 
annual 
implementation of the IPA should 
be  done  based  on 
indicators. 
Indicators  are  included  in  IPA 
programming  framework.  Where 
the  relevant  indicators  show  a 
significant regression or persistent 
lack  of  progress  by  a  beneficiary 
the 
intensity  of 
assistance  should  be  modulated 
8). 
accordingly 

scope  and 

(Article 

annual 

The  result  framework  is  used  for 
the 
Commission 
communication  on  the  Union’s 
the 
enlargement  policy 
Commission’s assessments  of the 
economic reform programmes. 

and 

139 

 
 
 
  
  
 
 
  
  
ISF 

Article  27;  no  delegated  act  was  adopted; 
indicators do not impact payments 

15 

33 

33 

quantitative 
and 
Qualitative 
indicators to report on the progress 
of 
the 
the  Fund 
achievement  of 
specific 
objectives. Indicators are used for 
the  midterm  evaluation.  Used  by 
Member  states  for  their  annual 
performance report.  

towards 
the 

ITER 

JTF 

No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

2021/1056: 
12 
2021/1229: Article 16; no delegated act was 
adopted; indicators impact payments 

Article 

2 

101 

2 

101 

report, 

Qualitative 
quantitative 
and 
indicators  are  used  for  the  final 
the 
performance 
Commission  may  make  financial 
corrections where less than 65  % 
of  the  target  set  out  for  one  or 
more 
is 
achieved. 

indicators 

output 

Programme-specific indicators for 
fund 
territorial 

transition 

just 

For loan facility, including output 
indicators is an eligibility criterion 
(Article  9  2021/1229).  There  are 
also  indicators  to  monitor  the 
implementation of the Facility and 

140 

 
 
 
  
  
  
  
  
  
  
 
 
 
  
  
  
progress 

its 
achievement of the objectives 

towards 

the 

Justice 

Article  13;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Qualitative 
quantitative 
and 
indicators to report on the progress 
of  the  Programme  towards  the 
achievement  of  the  general  and 
specific  objectives.  Mixed  of 
results and output indicators 

LIFE 

Article  19;  no  delegated  act  was  adopted; 
indicators do not impact payments 

level 

indicators 

Qualitative 
quantitative 
and 
indicators to report on the progress 
of  the  Programme  towards  the 
achievement  of  the  general  and 
specific  objectives  and  specific 
to  be 
project 
described  in  multiannual  work 
programmes or calls for proposals 
for tracking requirement (the latter 
with  a  focus  on  Natura  2000  and 
the 
certain 
atmospheric  air  pollutants).  Also 
use for mid-term evaluation. 

emissions 

of 

12 

19 

12 

13 

32 

NDICI  Global 
Europe 

Article  41;  no  delegated  act  was  adopted; 
indicators impact payments 

19 

1836 

1855 

Qualitative 
quantitative 
and 
indicators to report on progress of 
the 
Instrument 
the 
achievement  of 
specific 
objectives. They should be in line 
with SDGs. Indicators are used to 

towards 
the 

141 

 
 
 
  
  
  
 
  
  
 
  
  
included 

progress  within 

the 
assess 
framework  of  the  annual  report 
and present it. Indicators are used 
for the final evaluation. Indicators 
in  programming 
are 
documents which shall be results-
based  and  should  be  linked  to 
also 
targets. 
included in Multiannual indicative 
programmes. Disbursement of the 
budget  support  shall  be  based  on 
demonstrating 
indicators 
satisfactory  progress  being  made 
towards  achieving  the  objectives 
agreed with the partner country. 

Indicators 

are 

Nuclear 
Decommissioni
ng 

Article  10;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Nuclear 
Decommissioni
ng (Lithuania) 

Article  10;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Qualitative 
quantitative 
and 
indicators to report on the progress 
of  the  Programme  towards  the 
achievement  of  the  objectives. 
Should  be  defined 
the 
multiannual work programme and 
be related to objectives laid down 
in this work programme. 

in 

Qualitative 
quantitative 
and 
indicators to report on the progress 
of  the  Programme  towards  the 
achievement  of  the  objectives. 
the 
Should  be  defined 

in 

2 

2 

142 

2 

2 

 
 
 
  
  
  
 
  
  
  
Pericles 

Article  12;  no  delegated  act  was  adopted; 
indicators do not impact payments 

and 
Reform 
growth 
facility 
for  the  Western 
Balkans 

Article  13;  no  delegated  act  was  adopted; 
indicators do not impact payments 

5 

5 

13 

610 

623 

multiannual work programme and 
be related to objectives laid down 
in this work programme. 

and 

to  monitor 

quantitative 
Qualitative 
indicators 
the 
implementation  and  to  report  on 
the  progress  of  the  Programme 
towards  the  achievement  of  the 
specific  objectives.  Used  also  for 
the  evaluation  (final  and  mid-
term) 

the 

and 

The  Reform  Agendas  should  be 
results-based 
include 
indicators  for  assessing  progress 
towards 
achievement  of 
general and specific objectives of 
the  Facility.  The  indicators  shall 
be  expected  to  contribute  to  the 
Commission’s  monitoring  of  the 
Facility. The Reform Agendas set 
out the reforms to be implemented 
by the beneficiary concerned, the 
investment  areas  to  be  supported 
and the payment conditions. shall 
only  be  used  by  the  Commission 
to assess the progress towards the 
achievement  of  the  general  and 

143 

 
 
 
  
  
  
  
 
  
RRF 

Article  19;  a  delegated  act  was  adopted; 
indicators impact payments 

Single market 

Article  17;  a  delegated  act  was  adopted; 
indicators do not impact payments 

Social  Climate 
Fund 

Article  24;  no  delegated  act  was  adopted; 
indicators impact payments 

14 

7129 

7143 

16 

53 

69 

39 

39 

specific  objectives,  not  payment 
conditions  

Indicators used by Member States 
to  report in  the framework of the 
European Semester, and to report 
to the Commission. They are also 
the  Recovery  and 
used 
Resilience  Scoreboard,  and  the 
annual report of the RRF made by 
the Commission.  

for 

and 

to  monitor 

quantitative 
Qualitative 
indicators 
the 
implementation  and  to  report  on 
the  progress  of  the  Programme 
towards  the  achievement  of  the 
specific objectives. Mix of output 
and results indicators 

Qualitative 
quantitative 
and 
indicators  for  reporting  on  the 
progress  and  for  the  purpose  of 
monitoring  and  evaluation  of  the 
Fund towards the achievement of 
the objectives. Indicators are used 
in  the  framework  of  the  Social 
Climate 
(additional 
indicators  can  be  set  by  plans). 
Article  20:  Where  the  milestones 

Plans 

144 

 
 
 
  
  
 
  
  
 
  
  
  
reduce 

achieved 

targets  have  not  been 
and 
the 
satisfactorily 
Commission  shall 
the 
amount of the financial allocation 
It  should  be 
proportionately. 
possible for the Member States to 
use relevant common indicators to 
set out the milestones and targets 
in their Plans. 

TSI 

Article  14;  no  delegated  act  was  adopted; 
indicators do not impact payments 

Turkish Cypriot  No indicators in the legal basis; no delegated 
act  was  adopted;  indicators  do  not  impact 
payments 

Ukraine Facility  Article  17;  no  delegated  act  was  adopted; 
indicators impact payments 

5 

5 

150 

150 

5 

 0 

5 

Quantitative indicators to monitor 
the  implementation  and  to  report 
on the progress of the Programme 
towards  the  achievement  of  the 
specific objectives. 

The  Ukraine  Plan  shall  include 
indicators  for  assessing  progress 
towards  the  achievement  of  the 
general  and  specific  objectives. 
The  assessment  of  the  Ukraine 
Plan  determine  the  reforms  and 
investments to be implemented by 
Ukraine, the conditions laid down 
in the Ukraine Plan, the total and 
annual  maximum  amounts  for 

145 

 
 
 
  
  
  
  
 
  
  
  
 
  
  
non-repayable  financial  support 
and the total and annual indicative 
maximum  amounts  of  the  loan 
instalments... 
support, 

the 

for 

indicators 

the 
assessing 
progress towards the achievement 
specific 
of 
objectives  shall  be  defined  in  the 
Council implementing decision 

the  general  and 

TOTAL 

849 

28 

450 

146 

14870  16212 

146 

 
 
 
 
 
 
 
Proposed monitoring of performance indicators under the post-2027 programmes 

Types of indicators 

Indicators used to monitor the progress in the achievement 
of  objectives, 
including  mainstreamed  ones,  where 
relevant (Article 33(2)(b) of the Financial regulation 

Indicators  as  referred  to  in  Article  125(1)(a)  of  the 
Financial  regulation  used  when  the  form  of  the  Union 
contribution  is  not  linked  to  the  costs  of  the  relevant 
operations,  and  as  referred  to  in  Article  241  of  the 
Financial regulation in the context of budget support. 

to 

in  Article  16  “Performance 
Indicators  referred 
framework”  of  the  Common  Provision  regulation  2021-
2027  used  by  the  Member  States  in  the  context  of  the 
Cohesion  funds  and  the  Home  funds,  and  indicators 
referred to in Articles 7 and 142 of the CAP Strategic plan 
regulation. 

Indicators  as  referred  to  in  Article  34  of  the  Financial 
regulation used for evaluations 

Indicators as referred to in Article 158(7) of the Financial 
regulation used in the context of indirect management 

Degree of standardisation 
across EU budget 
programmes 

Standardised 

No programme-specific 
indicators 

Standardised as a general rule, 
with possibility to define ad 
hoc indicators when necessary 

Standardised 

No additional indicators 

No Member State-specific 
indicators 

Standardised 

No additional indicators 

Standardised 

No additional indicators 

Project or call level indicators (budgetary related) 

Standardised 

No additional indicators 

Thanks to standardisation at the EU budget level, the overall performance of the EU budget 
could be effectively monitored. Programmes would not be allowed to create specific indicators 
that cannot be aggregated with those of other programmes. For example, if two programmes 
support digitalisation, they must use the same set of indicators – such as “additional dwellings 
and enterprises with broadband access of very high capacity” – rather than varying definitions 
like  “additional  households  with  broadband  access  of  at  least  30  megabits  per  second”  or 
“dwellings  with  access  to very high-capacity internet networks, including 5G networks  and 
gigabit speeds” as done in the 2021-2027 period. 

At the same time, this pre-defined list of indicators would be linked to intervention fields used 
to track expenditures for all programmes. The indicators would be designed so that they would 
capture specificities of interventions falling under any particular intervention field.  

Intervention field 

Output indicators 

Result indicators 

Renewable energy: solar 

m2 of solar panels installed 

Renewable energy produced 

Peak capacity of solar panels 
installed 

147 

 
 
 
Support to the unemployed  Number 
trained 

of 

participants 

Number  of  participants  in 
employment after taking part 

Number  of 
services provided 

job 

search 

Number 
reporting 
after taking part 

of 
salary 

participants 
increase 

Examples for illustrative purpose only 

Because of indicators being linked to the intervention field, any type of intervention, regardless 
of the programme under which it would be implemented, would be monitored by one output 
and one  result indicator. For  example,  an intervention that involves  support to  employment 
would always be monitored by a result indicator that measures how many participants were in 
employment  after  taking  part  (and  not  for  example  how  many  participants  were  actively 
looking  for  employment).  This  approach  would  allow  to  compare  and  aggregate  similar 
interventions  across  different  programmes.  For  example,  if  a  similar  intervention  would  be 
implemented under the Social Climate Fund, a programme supporting youth and a programme 
supporting rural development, it would be possible to aggregate the data coming from the three 
programmes  and  understand  how  much  the  EU  budget  as  a  whole  is  contributing  towards 
labour mobility. 

The above approach will require designing indicators in a harmonised and coordinated manner, 
based on the indicators that are already being used. The entire list of indicators and the way 
they are linked to intervention fields would have to be agreed on simultaneously, before the 
programmes’ implementation would begin. This would necessarily mean that the number of 
indicators would be much limited than currently, since the same or similar indicators would be 
defined as one single indicator that would be used across all programmes. Where appropriate, 
the indicators would have to allow for the calculation of high-level impact indicators, such as 
GHG emissions avoided. The indicators would be introduced at the beginning of programmes’ 
implementation and would apply to all relevant programmes. 

As  a  general  rule,  harmonisation  will  be  needed  with  regards  to  indicators  for  triggering 
payments, for evaluation, or for monitoring implementing partners under indirect management, 
nor at the call or project level. In principle, only the predefined list of indicators should be used 
to  minimise  the  administrative  burden  on  final  beneficiaries,  implementing  partners,  and 
Member States while ensuring a comprehensive overview of the EU budget’s activities and 
impact across programmes.  

However, the preferred policy option foresees a differentiated operationalization of indicators 
per  management  mode.  Such  an  option  would  allow  for  the  use  of  tailored  indicators,  for 
example  in  the  case  of  shared  management,  where  e.g.  milestones  and  targets  –  tailored  to 
Member  States  specificities  and  needs  –  could  be  integrated  into  future  plans.  The  single, 
uniform set of indicators would therefore cater for payments triggered in ‘financing not linked 
to  costs’  schemes  as  well  as  evaluations,  enabling  streamlined  monitoring  of  performance, 
effective evaluation of programmes as well as management of programmes.  

The  list  of  intervention  fields  will  be  developed  by  identifying  relevant  policy  areas  and 
relevant interventions supported by EU budget programmes. Corresponding output and result 
indicators  will  be  developed  for  each  intervention  field,  building  upon  existing  indicators, 
selecting the most relevant ones, as well as coefficients enabling to track contributions to e.g. 
climate mitigation, adaptation and environment.  

148 

 
 
The list of intervention fields relies upon a combination of activity-oriented and policy-oriented 
intervention fields, along with varying levels of granularity, reflecting the complex nature of 
the EU budget, varying degrees of information availability, differing levels of implementation 
and programmable actions, as well as a differentiation between tracking coefficients for climate 
mitigation,  adaptation  and  environment.  The  tracking  approach  also  builds  upon  the 
intervention field  approach developed in  the context  of the  2021-2027  Common Provisions 
Regulation, ensuring that all intervention fields as they appear in the current CPR are covered 
by the proposed list. In addition, data requirements as they are currently existing regarding type 
of beneficiary have been included, though oftentimes only to a limited and targeted degree. 
This deviates from a more in-depth data collection approach and has been incorporated in this 
way to  reduce data  collection  burdens.  The tracking  approach also  relies  upon  the need for 
coherence  with  the  OECD  DAC  classification,  used  for  reporting  by  external  relations 
programmes. 

The  Performance  Regulation  will  set  out  dedicated  rules  regarding  the  monitoring  of 
performance across EU budget programmes. It will also include dedicated articles setting out 
specific  provisions  for  each  management  mode,  providing  for  monitoring  rules  in  Member 
States and third countries plans, in calls under direct management as well as by implementing 
partners  under  indirect  management.  The  regulation  will  for  example  define  that  Member 
States will be required to pick one output indicator from the common list to define milestones 
and targets in their plans, as well as one result indicator to enable for additional performance 
monitoring. 

The new list of indicators aims at setting up a performance framework for the EU budget while 
enabling  to  conduct  programme  monitoring  and  evaluation.  By  establishing  a  direct  link 
between intervention fields and indicators, the common list will provide more information than 
currently on the link between ‘how much do we spend’ and ‘what do we achieve’, which will 
be  relevant  in  the  context  of  programme  monitoring  and  evaluation.  The  methodology  for 
developing indicators also focuses on ensuring that indicators are drafted to measure what we 
actually achieve with EU investments, therefore ensuring a causal link between programmes 
objectives  and  the  new  common  set  of  indicators.  Because  all  management  modes  and 
programmes will use the same set of intervention fields and indicators, the new system will 
enable  to  compare  the  effectiveness,  efficiency  and  added  value  of  programmes’  budget 
interventions. The initiative focuses on monitoring outputs and results because of the lack of 
availability  of  meaningful  long-term  impact  indicators  beyond  outputs  and  results,  though 
some of the result indicators of the common list may also be seen as impact indicators (e.g. 
GHG emissions avoided). 

149 

 
 
 
 
ANNEX 8: REPORTING FRAMEWORK OF THE 2021-2027 BUDGET 

8.1 Reports on performance of the EU budget  

The Commission is required to report annually on the performance of the EU budget in the 
following context: 

•  Discharge procedure: Integrated Financial and Accountability Reporting (IFAR), 
which includes the AMPR, and its annex ‘programme performance statements’; 
•  Draft  Budget  procedure:  the  Statement  of  Estimates  includes  EU  budget 
expenditure for horizontal priorities, and working document 1 includes (the same) 
‘programme performance statements’; 

•  Strategic  planning  and  programming  cycle  (SPP):  which  includes  the  Annual 
Activity  Reports,  prepared  by  every  single  AoD,  which  describes  each  service 
progress  on  their  multiannual  policy  objectives.  The  Annual  Activity  Reports  are 
also a key part of the discharge procedure. 

•  Programme regulations: programme-specific requirements such as the RRF annual 

report. 

Figure: Performance reporting requirements under the 2021-2027 period 

The Commission provides extensive reporting on the performance of the EU budget, primarily 
through  the  programme  performance  statements.  These  statements  are  annexed  to  both  the 
Annual Management and Performance Report (discharge) and the Draft Budget, so as to ensure 
alignment  and  minimise  overlap  between  the  two  procedures.  Despite  this  comprehensive 
reporting, the Commission produces 33 additional annual reports on MFF programmes, which 
are usually prescribed by the programme-specific regulation. The annual reports are usually a 
very detailed presentation of facts and figures concerning implementation. In addition to this, 
budgetary information is included in some other reports, such as the yearly General report. 

The proliferation of reports results in overlapping content, as well as unsynchronised timelines 
and cut-off dates. This high number of reports requires significant resources and increases the 
risk  of  inconsistent  narratives.  These  reports  are  used  only  to  a  limited  degree  as  input  in 

150 

 
 
 
preparing  decisions  on  the  management  of  programmes,  with  the  exception  of  a  few 
programmes such as the RRF and the CAP. 

151 

 
 
Other  report  from  Commission 
without legal obligations  

Table 9: Reporting obligations in the 2021-2027 programmes 

Programme   Reporting 

Nature of the obligation and content of the report  

obligations  in 
/ 
regulations 
Article  in  the 
regulation  
YES:  Article 
50  

Horizon 
Europe  

Nature:  
The  Commission  shall  monitor  continuously  the  management  and 
implementation of the Programme. Data shall also be made publicly 
available  in  an  accessible  manner  on  the  Commission's  website 
according to the latest update.  

the  participation  of  widening  countries, 

Database should include:  
- Data for projects funded  
-  time-bound  indicators  to  report  on  an  annual  basis  towards 
achievement of the objectives  
-  information  (such  as  the  level  of  mainstreaming  SSH,  the  ratio 
between lower and higher TRLs in collaborative research, the progress 
on 
the  geographical 
composition  of  consortia  in  collaborative  projects,  the  evolution  of 
researchers’ salaries, the use of a two-stage submission and evaluation 
procedure, ...)  
- the levels of expenditure disaggregated at project level, including per 
intervention area;  
- the level of oversubscription, in particular the number of proposals 
and per call for proposals, their average score, the share of proposals 
above and below quality thresholds.  

Content:  

152 

 
 
  
  
  
Euratom 
Research  and 
Training  

YES:  Article 
12  

ITER  

NO  

InvestEU  

YES:  Article 
28.3  

Presenting  an  overview  on  evaluated  proposals  (incl.  success  rates) 
and  detailed  statistics  and  data  on  funded  projects  and  their 
participants in EU R&I programmes, broken down by countries and 
regions, research domain/programme part, organisation type, etc.  

https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/horizon-dashboard  
Nature:  
The  Commission  shall  monitor  continuously  the  management  and 
implementation of the Euratom Programme.  
Data shall be made publicly available in an accessible manner on the 
Commission’s webpage in accordance with the latest update of those 
data.  

Nature:  
In  accordance  with  Article  41(5)  of  the  Financial  Regulation,  the 
annual report shall provide information on the level of implementation 
of  the  Programme  with  respect  to  its  objectives  and  performance 
indicators. Where the Union  has granted a budgetary guarantee, the 
Commission  shall  attach  to  the  draft  budget  a  working  document 
presenting  for  each  budgetary  guarantee  and  for  the  common 
provisioning fund such as reference to the budgetary guarantee and its 
basic act, the counterparts for the budgetary guarantee, the budgetary 
guarantee’s  contribution  to  the achievement of the objectives of the 
budgetary guarantee as measured by the indicators established... 
For  that  purpose,  each  implementing  partner  shall  provide  on  an 
annual  basis  the  information  necessary  to  allow  the  Commission  to 

153 

Commission  has  developed  a 
dashboard.  
https://investeu.europa.eu/investeu
-programme/investeu-
fund/investeu-indicators_en 

 
 
  
  
  
  
  
comply  with  its  reporting  obligations,  including  information  on  the 
operation of the EU guarantee. 

Connecting 
Europe 
Facility  

YES:  Article 
12  

Nature: 
Biennial report - The Commission shall also present progress reports 
every two years. 

Information on the implementation of the CEF, clarifying whether the 
different sectors are on track, whether the total budgetary commitment 
is in line with the total amount allocated, whether the on-going projects 
are  sufficiently  complete,  and  whether  it  is  still  feasible  and 
appropriate to deliver them.  

Digital 
Europe 
Programme  

NO  

Single 
Market 
Programme 
EU 
Fraud 
Programme 
(Anti-Fraud) 

Anti-

NO  

YES:  Article 
12  

Nature:  
Annual  report  -  The  Commission  shall  report  annually  on  the 
performance of the Programme to the European Parliament and to the 
Council in the framework of its Annual Report on the protection of the 
Union’s financial interests – Fight against fraud.  

Content:  
Objectives, amount, projects, achievements  

154 

A  DIGITAL  Dashboard  has  been 
developed: 
https://dashboard.tech.ec.europa.eu/
qs_digit_dashboard_mt/public/exten
sions/CNECT_DIGITAL_dashboar
d/CNECT_DIGITAL_dashboard.ht
ml 

 
 
 
 
  
  
  
  
  
  
Cooperation 
in  the  field  of 
taxation 
(Fiscalis)  

YES:  Recital 
16  

https://anti-fraud.ec.europa.eu/system/files/2023-07/pif-report-
2022_en_0.pdf 
Nature: 
Annual  progress  reports  should  be  issued  to  monitor  the  progress 
made.  
Those  reports  should  include  a  summary  of  the  lessons  learnt  and, 
where appropriate, of the obstacles encountered, in the context of the 
activities  of  the  Programme  that  have  taken  place  in  the  year  in 
question.  

lessons 

learnt,  amount, 

Content: 
Implementation,  projects  description, 
performance indicators  
https://taxation-customs.ec.europa.eu/document/download/da84bf38-
a09f-4747-9c4d-
e784da690487_en?filename=SWD_2024_119_F1_STAFF_WORKI
NG_PAPER_EN_V2_P1_3386794.PDF  
Nature:  
Annual  progress  reports  should  be  issued  to  monitor  the  progress 
made.  
Those  reports  should  include  a  summary  of  the  lessons  learnt  and, 
where appropriate, of the obstacles encountered, in the context of the 
activities  of  the  Programme  that  have  taken  place  in  the  year  in 
question.  

Cooperation 
in  the  field  of 
customs 
(Customs) 

YES:  Recital 
20  

Content:  
Implementation,  projects  description, 
performance indicators  
https://taxation-customs.ec.europa.eu/document/download/d98e2e28-
5ca8-40cc-982f-

learnt,  amount, 

lessons 

155 

 
 
  
  
 
  
c4da233f305a_en?filename=swd_2024_120_f1_staff_working_pape
r_en_v3_p1_3383195-1.pdf 

NO  

NO  

NO  

Secure 

European 
Space 
Programme  
EU 
Connectivity 
Programme  
Regional 
Policy  Funds 
and 
(ERDF 
Cohesion)  

156 

High  level  report  -  Commission 
published  a  Report  on  economic, 
social  and  territorial  cohesion.  It 
deals with the European Social Fund 
(ESF+), 
the  European  Regional 
Development Fund (ERDF) and the 
Cohesion Fund (CF). It presents the 
state-of-play  of  EU  Cohesion 
situation 
economic 
through 
indicators in several fields (diversity, 
green  transition,  digital  transition, 
innovation,  governance...),  explains 
initiatives  led  by  the  EU,  some 
progress and achievements thanks to 
EU support. One section deals with 
Cohesion  Policy's 
impacts,  but 
remains high level.  

https://european-social-fund-
plus.ec.europa.eu/en/publications/ni

 
 
  
  
  
  
  
  
  
YES:  Article 
10  

Support 
to 
the  Turkish 
Cypriot 
Community 
(TCC) 

Nature:  
Annual  report  -  The  Commission  sends  each  year  a  report  on  the 
implementation of Community assistance under this instrument. 
The report shall contain information on the actions financed during the 
year  and  on  the  findings  of  monitoring  work,  and  shall  give  an 
assessment  of  the  results  achieved  in  the  implementation  of  the 
assistance.  

nth-report-economic-social-and-
territorial-cohesion  

Recovery  and 
Resilience 
Facility 
(RRF) 

YES:  Article 
31  

Content: 
-->  Programming,  implementation  mechanisms,  implementation, 
progress  by  objectives,  financial  execution,  monitoring,  audit  and 
controls, consultations with government  
Aid Report 2022  
Nature:  
The Commission provides an annual report on the implementation of 
the Facility.  
The annual report includes information on the progress made with the 
recovery and resilience plans of the Member States concerned under 
the Facility, implementation of the milestones and targets, the status 
of payments and suspensions thereof, contribution  of the Facility to 
the climate and digital targets, performance of the Facility based on 
the common indicators, expenditure financed by the Facility under the 
six pillars.  

Content:  
Progress with the RRPs at aggregate and MS level, including revision 
- RePowerEU 
- Financing through EU bonds and green bonds 

157 

 
 
  
  
  
  
- Status of M&T and payments 
- Contribution to climate and digital targets 
- Performance based on common indicators 
- Expenditure under the six pillars, and social exp. 
- Contribution of the facility the key RRF objectives 
- Available information on final recipients 
- Policies to improve competitiveness 
- Controls and audit 
- Communication and dialogues 
- Mid-term evaluation 
187852c2-07e0-4bef-af3f-5719b9077f2e_en  
Nature:  
Annual  report  -  The  Commission  provides  an  annual  report  on  the 
implementation of this Regulation.  
The annual report shall include information on:  
-requests for support submitted by Member States 
-the  analysis  of  the  application  of  the  criteria  used  to  analyse  the 
requests for support submitted by Member States;  
-cooperation and support plans;  
-special measures adopted;  
-the  implementation  of  support  measures,  where  appropriate  also  at 
national and regional level; and  
-the communication activities carried out by the Commission.  

Content:  
Request for support, projects supported, amount, execution of projects, 
cooperation and support plan, communication activities  
technical support instrument 2021  
Nature:  

158 

Technical 
Support 
Instrument 
(TSI) 

YES:  Article 
15  

Pericles IV  

YES:  Article 
12  

 
 
  
  
  
Union  Civil 
Protection 
Mechanism 
(UPCM) 

YES:  Article 
34  

Annual report - The Commission provides annual information on the 
results  of  the  Pericles  IV  programme  taking  into  account  the 
quantitative and qualitative indicators set out in the Annex.  

Content:  
Commitments  under  annual  work  programme,  implementation  of 
actions, monitoring of the quantitative and qualitative indicators.  
EUR-Lex - 52024DC0259 - EN - EUR-Lex  
Nature:  
Biennial report- Every two years, the Commission submits a report on 
operations and progress made. The report shall include information on 
progress  made  towards  the  Union  disaster  resilience  goals,  capacity 
goals  and  remaining  gaps,  taking  into  account  the  establishment  of 
rescEU capacities and provide an overview of the budgetary and cost 
developments relating to response capacities, and an assessment of the 
need for further development of those capacities.  

Content: 
Demand of assistance, actions taken, key findings.  
EUR-Lex - 52024DC0130 - EN - EUR-Lex  

EU4Health 
Programme 
Emergency 
Support 
Instrument 
(ESI) 

NO  

YES: Article 8   Nature:  

12 months after activation report  - At the latest  12 months after the 
activation  of  the  emergency  support  for  a  specific  situation,  the 
Commission shall present a report and, where appropriate, proposals 
to terminate it.  

Content:  

159 

 
 
  
  
  
  
  
  
  
implementation, 

Budget, 
performance.  
REPORT FROM THE COMMISSION TO THE COUNCIL  

communication, 

actions 

financed, 

European 
Social Fund + 
(ESF+)  

NO  

Erasmus+  

YES:  Article 
23 

160 

High  level  report  -  Commission 
published  a  Report  on  economic, 
social  and  territorial  cohesion.  It 
deals with the European Social Fund 
the  European  Regional 
(ESF+), 
Development Fund (ERDF) and the 
Cohesion Fund (CF). It presents the 
state-of-play  of  EU  Cohesion 
economic 
through 
situation 
indicators in several fields (diversity, 
green  transition,  digital  transition, 
innovation,  governance...),  explains 
initiatives  led  by  the  EU,  progress 
and  achievements  thanks  to  EU 
support.  One  section  deals  with 
impacts,  but 
Cohesion  Policy's 
remains high level.  

https://european-social-fund-
plus.ec.europa.eu/en/publications/ni
nth-report-economic-social-and-
territorial-cohesion  
An annual report is published by the 
Commission on Erasmus  
Erasmus+  annual  report  2022  - 
Publications Office of the EU  

 
 
  
  
  
European 
Solidarity 
Corps (ESC)  

YES:  Article 
230 

Justice 
Programme  

YES:  Article 
13  

and 

Citizens, 
Equality, 
Rights 
Values 
Programme 
(CERV)  
Creative 
Europe  

NO  

NO  

key 

figures 

A  report  on  the  period  2021-2023 
was  published  by  the  Commission 
with 
(projects, 
participants,  budget  commitments), 
testimonials, examples of projects.  
European 
solidarity 
Publications Office of the EU  

corps 

- 

Nature:  
Annual  report  - The Commission  reports on the performance of the 
Programme annually to the European Parliament and to the Council, 
within the existing reporting mechanisms, in particular the EU Justice 
Scoreboard.  
The  Commission  reports  on  the  use  of  the  funds  allocated  to  each 
specific  objective,  specifies  the  types  of  action  that  have  received 
funding, including actions linked to the promotion of gender equality.  

Content:  
Key findings on efficiency, quality and independence of justice.  
THE 2024 EU JUSTICE SCOREBOARD  

Annual  report  -  Creative  Europe 
report: 
political 
state-of-play, 
priorities,  applications,  projects, 
amounts...  

161 

 
 
  
  
  
  
  
  
  
Common 
Agricultural 
Policy (CAP)  

YES  

NO  

NO  

European 
Maritime, 
Fisheries  and 
Aquaculture 
Fund 
(EMFAF)  
Regional 
Fisheries 
Management 
Organisations 
and 
Sustainable 
Fisheries 
Partnership 
Agreements  

Creative  Europe  2021-2022 
Publications Office of the EU  

- 

Nature:  
Biennial performance review - Based on information from the annual 
performance reports prepared by MS. In case targets are substantially 
missed, the Commission is to provide an explanation and follow-up 
actions. The added value of the performance clearance is considered 
by  Member  States  and  the  Commission  as  low  compared  to  the 
administrative burden it generates.  

from 

There  are  references  to  the  SFPAs 
and RFMOs in  the annual  report of 
the  Common  Fisheries  Policy  (e.g. 
Communication 
the 
the  European 
Commission 
to 
Parliament  and 
- 
the  Council 
Sustainable  fishing  in  the  EU:  state 
of play and orientations for 2024 and 
working 
Commission 
the 
document 
document  Communication  from  the 
the  European 
Commission 
to 
- 
the  Council 
Parliament  and 

staff 
accompanying 

162 

 
 
  
  
  
  
  
Programme 
for 
Environment 
and  Climate 
Action 
(LIFE) 
Just 
Transition 
Mechanism 
(JTM)  

YES:  Article 
19  

Nature:  
The  contribution  of  the  LIFE  Programme  to  Union  climate  and 
biodiversity  objectives  shall  be  reported  regularly  in  the  context  of 
evaluations and the annual report.  

YES:  Article 
16  

Nature: 
Annual  report  -  By  31  October  of  each  calendar  year,  starting  with 
2022, the Commission shall issue a report on the implementation of 
the  Facility.  That  report  shall  provide  information  on  the  level  of 
implementation of the Facility with respect to its objectives, conditions 
and performance indicators  

Content:  
Budgetary  framework,  implementation,  communications  activities, 
lessons learnt  
EUR-Lex - 52023DC0713 - EN - EUR-Lex  

NO  

Asylum, 
Migration 
and 
Integration 
Fund (AMIF)  

163 

Sustainable  fishing  in  the  EU:  state 
of play and orientations for 2024) 

The  Commission  shall  ensure  that 
the summaries provided by Member 
States are translated into all official 
languages  of  the  Union  and  made 
publicly available. (Article 35)  

https://home-
affairs.ec.europa.eu/funding/asylum
-migration-and-integration-
funds/asylum-migration-and-

 
 
 
  
  
  
  
  
integration-fund-2021-
2027_en#annual-performance-
reports-from-the-member-state-
programmes  

The  Commission  shall  ensure  that 
the summaries provided by Member 
States are translated into all official 
languages  of  the  Union  and  made 
publicly available. (Article 29)  

https://home-
affairs.ec.europa.eu/funding/borders
-and-visa-funds/integrated-border-
management-fund-border-
management-and-visa-instrument-
2021-27_en#annual-performance-
reports-from-the-member-state-
programmes  

NO  

Border 
Management 
Visa 
and 
Instrument  

Customs 
Control 
Equipment 
Instrument  

YES:  Recital 
26  

reporting 

system,  be 

Nature:  
Annual  Report  -  Annual  progress  reports  should,  as  part  of  the 
the 
performance 
implementation  of  the  Instrument.  Those  reports  should  include  a 
summary of the lessons learnt and, where appropriate, of the obstacles 
encountered, and shortfalls discovered in the context of the activities 
of the Instrument that took place in the year in question. Those annual 
progress reports should be communicated to the European Parliament 
and the Council.  

to  monitor 

issued 

164 

 
 
  
  
  
  
  
  
Content:  
Implementation,  project  description, 
performance indicators.  
https://taxation-customs.ec.europa.eu/document/download/ef4ea7c1-
dc66-4a92-99fc-
2baf6f102e85_en?filename=SWD_2023_251_F1_STAFF_WORKI
NG_PAPER_EN_V2_P1_2823669.PDF 

lessons 

learnt,  amount, 

Internal 
Security 
Fund (ISF)  

NO  

The  Commission  shall  ensure  that 
the summaries provided by Member 
States are translated into all official 
languages  of  the  Union  and  made 
publicly available. (Article 30)  

https://home-
affairs.ec.europa.eu/funding/internal
-security-funds/internal-security-
fund-2021-2027_en#annual-
performance-reports-from-the-
member-state-programmes  

Nuclear 
Decommissio
ning 
(Lithuania)  

YES:  Article 
10  

Nature: 
Annual report - At the end of each year, the Commission shall draw 
up a progress report on the implementation of the work carried out in 
the previous years, including the rate of activities resulting from calls 
for tenders, and shall present it to the European Parliament and to the 
Council.  

Content:  
Programme 
performance, activities from call tenders.  

framework,  budgetary 

implementation,  progress, 

165 

 
 
  
  
  
  
  
NDAP Progress report 2021  

Nuclear 
Safety 
Decommissio
ning (NSD)  

and 

YES:  Article 
10  

Nature: 
Annual report - At the end of each year, the Commission shall draw 
up a progress report on the implementation of the work carried out in 
the previous years, including the rate of activities resulting from calls 
for tenders, and shall present it to the European Parliament and to the 
Council.  

Content: 
Programme 
performance, activities from call tenders.  
NDAP Progress report 2021  

framework,  budgetary 

implementation,  progress, 

European 
Defence Fund 
(EDF)  

NO  

Regulation on 
Supporting 
Ammunition 

YES:  Article 
23  

Nature:  
Evaluation report - By 30 June 2024, the Commission shall draw up a 
report evaluating the implementation of the measures set  out in  this 
Regulation and their results, as well as the opportunity to extend their 

166 

The  Commission  shall  monitor  the 
implementation  of  the  Fund  on  a 
report 
regular  basis  and  shall 
annually 
progress  made, 
on 
including how lessons identified and 
lessons learned from the EDIDP and 
the PADR are taken into account in 
the  implementation  of  the  Fund,  to 
the  European  Parliament  and  to  the 
the 
Council.  To 
Commission  shall  put 
in  place 
necessary monitoring arrangements. 
(Article 28)  

end, 

that 

 
 
  
  
  
  
Production 
(ASAP)  

YES:  Article 
14  

EU  Defence 
Industry 
Reinforcemen
t 
Through 
Common 
Procurement 
Act 
(EDIRPA)  

applicability and provide for their funding, particularly with regard to 
the evolution of the security context. The evaluation report shall build 
on consultations of the Member States and key  stakeholders and be 
communicated to the European Parliament and to the Council.  

Content:  
Implementation, work programme and calls preparation, application 
and progress, evaluation and recommendations.  
defence-industry-space.ec.europa.eu/document/download/d980180b-
0749-45d5-b857-e7864adef4b2_en?filename=ASAP  Implementation 
Report.pdf  
Nature:  
Evaluation report - The Commission shall monitor the implementation 
of the Instrument and shall report on progress made. To that end, the 
Commission shall put in place the necessary monitoring arrangements. 
By  31  December  2026,  the  Commission  shall  draw  up  a  report 
evaluating the impact and effectiveness of the actions taken under the 
Instrument (the ‘evaluation report’) and shall submit it to the European 
Parliament  and  to  the  Council.  The  evaluation  report  shall  build  on 
consultations  with  Member  States  and  key  stakeholders  and  shall 
assess the progress  made towards the achievement  of the objectives 
set  out  in  Article  3.  It  shall  evaluate  potential  bottlenecks  in  the 
functioning of the Instrument and, in particular, the contribution of the 
Instrument to:  
(a)cooperation  between  Member  States  and  associated  countries, 
including the creation of new cross-border cooperation;  
(b)the participation of SMEs and mid-caps in the actions;  
(c)the creation of new cross-border cooperation between contractors 
and subcontractors in supply chains throughout the Union;  

167 

 
 
  
  
YES:  Article 
41  

Neighbourho
od, 
Development 
and 
International 
Cooperation 
Instrument 
(NDICI 
Global 
Europe)  

NO  

European 
Instrument 
for 
International 
Nuclear 

(d)the  strengthening  of  the  EDTIB’s  competitiveness  and  the 
adaptation, modernisation and development to allow it to address, in 
particular, the most urgent and critical defence products needs;  
(e)the  overall  value  of  common  procurement  contracts  for  the  most 
urgent and critical defence products supported by the Instrument.  

Nature:  
The  Commission  shall  examine  the  progress  made  in  implementing 
the Instrument. Starting from 2022 onwards, the Commission shall, in 
a timely manner by 30 November each year, submit an annual report 
on  progress  towards  the  achievement  of  the  objectives  of  the 
Instrument by means of indicators, including, but not limited to, those 
set in Annex VI, reporting on the ongoing activities, results delivered 
and  the  effectiveness  of  the  Regulation.  That  report  shall  also  be 
submitted to the European Economic and Social Committee and to the 
Committee  of  the  Regions.  The  regulation  foresees  further  details 
which should be include in this report; 

Content:  
Achievements and reporting on SDGs, implementation, and detailed 
annexes  on  results  and  financial  statistics,  including  detailed  SDG 
reporting.  
2023 Annual  report on the implementation of the European Union's 
external action instruments in 2022 - Publications Office of the EU  

168 

 
 
  
  
  
  
  
  
Safety 
Cooperation 
(INSC)  
Humanitaria
n 
(HUMA)  

Aid 

YES:  Article 
19  

Nature:  
Annual report - At the close of each financial year, the Commission 
submits an annual report with a summary of the operations financed in 
the  course  of  that  year.  The  summary  shall  contain  information 
concerning  the  agencies  with  which  humanitarian  operations  have 
been  implemented.  The  report  shall  also  include  a  review  of  any 
outside  assessment  exercises  which  may  have  been  conducted  on 
specific operations.  

Content: 
Achievements and reporting on SDGs, implementation 
2023 Annual  report on the implementation of the European Union's 
external action instruments in 2022 - Publications Office of the EU  

Common 
Foreign  and 
Security 
Policy (CFSP)  
Overseas 
Countries 
and 
Territories 
(OCT) 
(including 
Greenland) 

NO  

YES:  Article 
86  

Nature: 
Annual report - The Commission submits a report every year starting 
in  2022  on  the  implementation  and  results  of  that  financial 
cooperation.  

Content:  
Achievements and reporting on SDGs, implementation...  
2023 Annual  report on the implementation of the European Union's 
external action instruments in 2022 - Publications Office of the EU  

169 

 
 
  
  
  
  
  
  
Macro-
financial 
Assistance 
(MFA)  

– 

YES 
Example: 
Covid – Article 
8  

YES:  Article 
13  

Pre-

Instrument 
for 
accession 
Assistance 
(IPA III)  

Nature: 
Annual report - By 30 June of each year, the Commission shall submit 
to  the  European  Parliament  and  to  the  Council  a  report  on  the 
implementation  of this Decision in  the preceding year, including  an 
evaluation of that implementation. The report shall: 
(a) examine the progress made in implementing the Union’s macro‐
financial assistance; 
(b) assess the economic situation and prospects of the partners, as well 
as progress made in implementing the policy measures referred to in 
Article 3(1); 
(c)  indicate  the  connection  between  the  economic  policy  conditions 
laid  down  in  the  MOU,  the  partners’  on‐going  economic  and  fiscal 
performance  and 
the 
the  Commission’s  decisions 
instalments of the Union’s macro‐financial assistance.  

to  release 

Content:  
Implementation, disbursements, operational assessment, evaluation  
EUR-Lex - 52024DC0240 - EN - EUR-Lex  
Nature:  
Annual report - Article 41 of Regulation (EU) 2021/947 in relation to 
monitoring  and  reporting  shall  apply  to  this  Regulation  mutatis 
mutandis. The annual report referred to in Article 41(5) of Regulation 
(EU) 2021/947 (NDICI Global Europe) shall also contain information 
on commitments and payments per instrument (IPA, IPA II and IPA 
III).  In  addition,  the  annual  report  shall  contain  information  on  the 
commitments for specific objectives.  

Content:  
Achievements and reporting on SDGs, implementation  

170 

 
 
  
  
  
  
YES:  Article 
25  

Reform  and 
growth 
facility for the 
Western 
Balkans  

Ukraine 
Facility  

YES:  Article 
39  

YES:  Article 
21  

European 
Globalisation 
Adjustment 
Fund 
Displaced 
Workers 
(EGF)  

for 

European 
Union 
Solidarity 
Fund (EUSF)  

YES:  Article 
12  

2023 Annual  report on the implementation of the European Union's 
external action instruments in 2022 - Publications Office of the EU  
Nature: 
Annual report - The Commission shall provide an annual report to the 
European  Parliament  and  the  Council  on  progress  towards  the 
achievement of the objectives of this Regulation. That annual report 
shall also address synergies and complementarities of the Facility with 
other  Union  programmes,  in  particular  support  provided  under 
Regulation (EU) 2021/1529, with a view to avoiding the duplication 
of assistance and double funding.  
Nature: 
Annual report - The Commission shall provide simultaneously to the 
European  Parliament  and  the  Council  an  annual  report  on  progress 
towards the achievement of the objectives.  
Nature: 
Biennial report - By 1 August 2021 and every two years thereafter, the 
Commission  shall  submit  to  the  European  Parliament  and  to  the 
Council  a  comprehensive,  quantitative  and  qualitative  report  on  the 
activities.  The  regulation  foresees  further  details  which  should  be 
include in this report;  

Content:  
Applications submitted, decisions adopted, measures funded, results 
achieved, financial execution, qualitative assessment.  
EUR-Lex - 52023DC0482 - EN - EUR-Lex  
Nature: 
Annual  report  -  Before  1  July  the  Commission  shall  present  to  the 
European Parliament and to the Council a report on the activity of the 
Fund  in  the  previous  year.  This  report  shall  in  particular  contain 
information relating to Articles 3, 4 and 8 of the regulation.  

171 

 
 
  
  
  
  
  
Innovation 
Fund (IF)  

YES:  Article 
10a  

Brexit 
Adjustment 
Reserve 
(BAR)  

YES:  Article 
17  

Content:  
Applications, financing and closures.  
COM_COM(2020)0034_EN.pdf  
Nature: 
Annual report - By 31 December 2023 and every year thereafter, the 
Commission shall report to the Climate Change Committee referred to 
in  Article  22a(1)  of  this  Directive,  on  the  implementation  of  the 
Innovation Fund, providing an analysis of projects awarded funding, 
by sector and by Member State, and the expected contribution of those 
projects towards the objective of climate neutrality in the Union  
Nature:  
By June 2024, the Commission shall inform the European Parliament 
and the Council on the state of play of the implementation process of 
this Regulation, based on available information.  
By  30  June  2027,  the  Commission  shall  carry  out  an  evaluation  to 
examine the effectiveness, efficiency, relevance, coherence and Union 
added  value  of  the  Reserve.  The  Commission  may  make  use  of  all 
relevant information already available in accordance with Article 128 
of the Financial Regulation.  
By  30  June  2028,  the  Commission  shall  submit  to  the  European 
Parliament,  to  the  Council,  to  the  European  Economic  and  Social 
Committee  and  to  the  Committee  of  the  Regions  a  report  on  the 
implementation of the Reserve.  

Content:  
Implementation, allocation, next steps, measures undertaken...  
SWD_2024_154_Officially_TRANSMITTED_20.06.2024.pdf  

172 

 
 
  
  
  
  
Social 
Climate Fund 
(SCF)  

NO  

173 

 
 
  
 
Reporting requirements under the post-2027 programmes 

Under  the  preferred  policy  option,  all  reporting  requirements  would  be  simplified  and 
consolidated  through  the  Annual  Management  and  Performance  Report.  This  would  first 
require consolidating and aligning legal provisions regulating all aspects of reporting, financial, 
performance and activity of services.  

The  reporting  would  be  done  at  the  same  period.  This  would  mean  that  under  the  current 
provisions of the Financial regulation and taking into account current practice, where the draft 
budget is presented early105, the reporting deadline would be 30 June each year, which includes 
any information that needs to be provided along with the draft budget. 

Reporting would be consolidated at the level of the entire budget. All information related to 
implementation,  financial  or  substantive,  would be  reported  within  one  report,  allowing  for 
correlations between financial and substantive implementation to be made where relevant. No 
separate  reporting  would  be  done  at  the  programme  level.  If  more  detailed  information  is 
necessary or where information needs to be updated more frequently, dashboards could be used 
to allow this. 

Some  separate  reporting  would  be  kept  because  the  object  of  reporting  is  technically  not 
implementation of budgetary interventions, such example being the Annual Activity Report. 
No  information  provided  in  one  report  would  be  repeated  in  another  report.  Rather,  cross-
cutting references to clusters of information between reports could be included when necessary. 
This would require that all reporting is produced roughly within the same timeframe. 

The  above  approach  would  reduce  the  reporting  burden,  since  it  would  reduce  the  need  to 
multiply the effort on providing the same type of information in view of different cut-off dates 
and potentially different methods of calculation. The possibility of error would decrease, both 
because data would no longer be provided in several reports, as well as because services could 
provide more resources to reporting if it is to be done less often. The insight and useability of 
such  reporting  could  increase  because  information  would  be  gathered  at  one  place.  By 
maintaining financial and performance reporting being bundled with draft budget, they could 
have a true impact on budgetary decisions, as well as on management of programmes, leading 
to a true performance-based budgeting. 

To a degree, some parts of reporting have already been consolidated by linking the preparation 
of the Annual Management and Performance Report to the draft budget. The experience with 
such approach is positive as administrative burden is less than it would be had an additional 
document have to be produced to be attached to the draft budget. 

105 Under the Financial regulation, the deadline for presenting the draft budget is 1 September each year 

174 

 
 
 
 
 
 
8.2 Reporting tools and systems  

There  are  at  least  20  dashboards  providing  information  related  to  the  EU  budget  and  its 
performance.  In  addition  to  the  four  dashboards  published  by  DG  Budget106,  there  are  16 
programme-specific dashboards publicly available. They can be roughly categorised in three 
groups: a) Qlik Sense-based dashboards, b) cohesion-related dashboards, and c) others. 

The organisation of the information they provide – as well as the type and granularity of data 
– is not standardised. The dashboards generally provide output data, with some exceptions – 
e.g. the Common Agricultural Policy dashboard provides a number of contextual indicators, 
such as the prices of agricultural commodities.  

Because the type of information that is provided depends on the programme, as well as because 
the organisation of the data is not standardised, it is not possible to easily compile information 
thus obtained. Moreover, the information included in the dashboards, even if compiled, does 
not  provide  information  on  contribution  to  cross  cutting  policy  objectives.  Indicators 
programmes are also often not standardised.  

For example, it is not possible to obtain information as to how many beneficiaries obtained 
funding for education across all EU programmes; or how many kilometres of railways were 
built.  From  these  dashboards,  it  is  also  not  possible  to  obtain  information  as  to  how  much 
funding  was  provided  towards  cross-cutting  objectives,  such  as  climate  action  or  gender 
equality. Similarly, information cannot be grouped by categories such as time-period (i.e. how 
many outputs of certain type were provided across the budget in a certain timeframe) or by 
place of implementation (e.g. how many EU-funded activities took place in a certain Member 
State, region or city). 

Providing information in a fragmented way or providing the same information via different 
dashboards  also  increases  risks  of  publishing  incoherent  information  or  leading  to 
misinterpretation.  Lastly,  such  multiplication  of  effort  is  inefficient  as  far  as  use  of  EU 
Institutions resources is concerned.  

106 The four dashboards published by DG BUDGET are EU Financial Transparency System; EU Funded projects 
| EU Funding & Tenders Portal; EU Spending and Revenue 2021-2027; Programme Performance Statements  

175 

 
 
 
 
Table: Reporting dashboards in the 2021-2027 MFF programmes 

Programme  

1. 

 EU Financial Transparency System  

Content Summary  

Qlik Sense dashboard 

2. 

 EU Spending and Revenue 2021-2027 

Qlik Sense apps in a webpage 

Link  

https://ec.europa.eu/budget/financial-transparency-
system/index.html 

https://commission.europa.eu/strategy-and-policy/eu-
budget/long-term-eu-budget/2021-2027/spending-and-
revenue_en  

https://commission.europa.eu/strategy-and-policy/eu-
budget/performance-and-reporting/programme-performance-
statements_en  

EU Funded projects | EU Funding & Tenders Portal  

3. 

 Programme Performance Statements  

4. 

EU  Funded  projects  |  EU  Funding  & 
Tenders Portal 

5. 

 Horizon Europe 

6. 

 InvestEU 

Presenting an overview on evaluated proposals (incl. success rates) 
and  detailed  statistics  and  data  on  funded  projects  and  their 
participants in EU R&I programmes, broken down by countries and 
regions, research domain/programme part, organisation type, etc.  

https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/horizon-
dashboard 

The graphs  show the implementation of the  InvestEU Fund. Data 
are based on the operational reporting of the InvestEU implementing 
partners  and  are  regularly  updated  as  data  are  available. 
Non-interactive graphs but also a link to Qlik Sense  

https://investeu.europa.eu/investeu-programme/investeu-
fund/investeu-indicators_en  

7. 

 Connecting Europe Facility (CEF) 

CEF  Data  Hub:  The  dashboard  presents  data  about  all  Grant 
Agreements (GA) managed by the European Climate, Infrastructure 
and Environment Executive Agency (CINEA) 

https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/sense/app/3744499f-670f-42f8-9ef3-
0d98f6cd586f/sheet/4c9ea8df-f0f9-4c0d-b26b-
99fc0218d9d9/state/analysis  

176 

 
 
 
  
 
 
8. 

 Digital Europe Programme  

The  Dashboard  currently  features  two  profiles:  the  DIGITAL 
Country Profile and the DIGITAL Projects Profile. 

https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/extensions/CNECT_DIGITAL_dashboard/CNECT_DI
GITAL_dashboard.html#country  

9. 

Regional  Policy  Funds 
Cohesion Fund) 

(ERDF  and 

10.   Recovery and Resilience Facility  

Open 

Platform  
Cohesion 
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF 
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal 
is available on this page. 

Data 

https://cohesiondata.ec.europa.eu/funds/erdf/21-27  
https://kohesio.ec.europa.eu/fr/ 

The  Recovery  and  Resilience  Scoreboard  gives  and  overview  of 
how  the  implementation  of  the  Recovery  and  Resilience  Facility 
(RRF) and the national recovery and resilience plans is progressing.  

https://ec.europa.eu/economy_finance/recovery-and-
resilience-scoreboard/index.html  

Dashboard: 
NextGenerationEU 
Information about the  NextGenerationEU green bonds allocations 
across  Member  States,  expenditure  categories  and  intervention 
fields. 

Green 

Bond 

https://commission.europa.eu/strategy-and-policy/eu-
budget/eu-borrower-investor-relations/nextgenerationeu-
green-bonds/dashboard_en  

11.   European Social Fund+ 

12.   Erasmus+ 

13.   Common Agricultural Policy 

Comprehensive overviews of the EU's main agricultural products, 
in the form of dashboards, integrating in one view graphs and tables 
of relevant market data  for  selected products, such as production, 
prices, trade, use and stocks.  

https://cohesiondata.ec.europa.eu/funds/esf_plus/21-27  

Qlik Sense. Presents regularly updated data stories of the Erasmus+ 
programme to provide an easy-to-use overview of the programme's 
activities and results. 

https://webgate.ec.europa.eu/eacdashboard/sense/app/c553d9
e9-c805-4f7a-90e4-103bd1658077/overview  

Two 
parts: 
1.  Financing  part,  non-interactive  but downloadable  graphs/charts 
2. Comprehensive overviews of the EU's main agricultural products, 
in the form of dashboards, integrating in one view graphs and tables 
of relevant market data  for selected products, such as production, 
prices, trade, use and stocks.  

https://agridata.ec.europa.eu/extensions/DataPortal/dashboard
s.html 

https://agriculture.ec.europa.eu/data-and-
analysis/financing/cap-expenditure_en 

EU budget execution - overview | Cohesion Open Data  

177 

 
 
 
 
 
 
 
14.   

European  Maritime,  Fisheries 
Aquaculture Fund  

and 

Open 

Platform  
Cohesion 
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF 
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal 
is available on this page. 

Data 

15.   LIFE 

Qlik Sense dashboard 

16.   Just Transition Mechanism  

17.   Asylum, Migration and Integration Fund 

18.   Integrated Border Management Fund  

19.   Internal Security Fund 

Open 

Cohesion 
Platform  
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF 
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal 
is available on this page. 

Data 

Open 

Cohesion 
Platform  
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF 
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal 
is available on this page. 

Data 

Open 

Cohesion 
Platform  
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF 
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal 
is available on this page. 

Data 

Open 

Cohesion 
Platform  
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF 
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal 
is available on this page. 

Data 

20.   Innovation Fund  

Qlik Sense dashboard 

178 

https://cohesiondata.ec.europa.eu/funds/emfaf/21-27 

https://emff-datahub.eismea.eu/ 

https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/sense/app/8298c020-48a6-4b84-91f4-
f6f2665c0f99/overview  

https://cohesiondata.ec.europa.eu/funds/jtf/21-27  

https://cohesiondata.ec.europa.eu/funds/amif/21-27  

https://cohesiondata.ec.europa.eu/funds/bmvi/21-27  

https://cohesiondata.ec.europa.eu/funds/isf/21-27  

https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/sense/app/6e4815c8-1f4c-4664-b9ca-
8454f77d758d/sheet/bac47ac8-b5c7-4cd1-87ad-
9f8d6d238eae/state/analysis  

 
 
 
The recast of the Financial regulation also reinforces transparency requirements across the EU 
budget  as  from  the next  MFF, in  particular by requiring to  make available on  a centralised 
website  information  on  recipients  of  funds  financed  from  the  budget.  Article  38  of  the 
regulation provides several details regarding the content of the information to be published, the 
process of publishing, and the rules for processing of data, including personal data. A number 
of  EU  budget  programmes  under  direct  and  indirect  management  publish  such  information 
through the Financial Transparency System. However, there is no comprehensive reporting of 
information on beneficiaries for programmes under shared management. While the process of 
obtaining the necessary information remains subject to sector-specific rules, information still 
has  to  be  centralised  through  a  single  website  as  required  by  the  Financial  regulation.  In 
addition to this, reporting for programmes under shared management needs to be provided for.  

Displaying performance information via a single portal under the post-2027 programmes 

The preferred policy option foresees the centralisation of performance data on the EU budget 
through  a  single  online  dashboard.  This  platform  would  provide  comprehensive  insights, 
including  budget  implementation  information,  expenditure  monitoring  by  intervention  field 
and  horizontal  priorities,  and  key  performance  indicators.  Additionally,  it  could  feature 
information on beneficiaries. The dashboard would be modelled after the existing Open Data 
Platform  for  cohesion  policy  funds  and  the  Recovery  and  Resilience  Scoreboard,  ensuring 
transparency and ease of access. 

This  option  will  require  a  detailed  mapping  of  the  information  displayed  via  existing 
dashboards, and an assessment of what information needs to be included. A uniform design of 
the dashboard could be developed, as well as functionalities that would allow for displaying an 
overview of performance information across the EU budget. Such a dashboard could include 
relevant analytical tools enabling to analyse data across Member States and objectives.  

Such a dashboard would build upon the new standardised system  of intervention fields  and 
performance indicators. Taking into account presentation and IT systems upfront would allow 
to design a dashboard with relevant options for data presentation and analysis. 

Stakeholders  would  have  access  to  a  wider  array  of  information,  meeting  diverse  needs 
regardless of the reason for their visit to the dashboard. This information would be of higher 
quality, offering a comprehensive view of performance data and enhancing transparency and 
accountability toward stakeholders. Furthermore, maintaining a single dashboard is likely to 
require fewer resources and reduce administrative burden on the Commission. 

The preferred policy option also foresees increased alignment with the Financial Regulation 
requirements  regarding  the  collection,  storage  and  publishing  of  data  on  beneficiaries  and 
operations supported by the EU budget. All EU budget programmes – under all management 
modes – would publish such information through the new single dashboard. 

While  facilitating  access  to  information  via  a  single  dashboard,  the  preferred  policy  option 
foresees a differentiated operationalization per management mode or programme, whereby the 
single dashboard would enable to display specific data regarding dedicated areas and sectors, 
and performance information presenting specific programmes achievements. 

179 

 
 
 
 
8.3  Portals  informing  project  promoters  and  potential  applicants  about  funding 
opportunities  

Currently, information about EU funding opportunities is fragmented and not readily available 
to project promoters. There is no single website, nor portal that comprises an overview of all 
EU funding opportunities.  

The  preliminary  mapping  of  portals  and  one-stop-shops  –  informing  potential  beneficiaries 
about EU funding opportunities – and their current expansion demonstrate the need for a more 
user-centric approach (see table below). 

The  proliferation  of  information  portals  addressing  the  needs  of  specific  constituencies  is 
essentially dictated by the complexity of the EU budget implementation framework, namely 
the  large  number  of  MFF  programmes,  140  different  types  of  actions  and  a  lack  of 
harmonisation of publication modalities across the three management modes.  

While the Funding & Tender Portal covers information about grants and procurements under 
directly  and  some  indirectly  managed  programmes,  information  on  upcoming  funding 
opportunities  at  national  level  is  published  on  Member  States  national  portals  and  calls  are 
published  on  regional  websites  (around  400).  Information  about  other  repayable  forms  of 
funding (equity, loans, guarantees) that are channelled through implementing partners – i.e. the 
EIB group, national promotional banks and the network of local financial intermediaries acting 
across the European Union – are spread across multiple websites. To remediate this situation, 
the  Access  to  EU  Finance  portal  redirects  users  to  the  local  financial  intermediaries  in  the 
Member  States  while  the  InvestEU  Portal,  which  brings  together  investors  and  project 
promoters under a single EU-wide platform, provides visibility and matchmaking opportunities 
for investment projects within the EU, Norway and Iceland.  

Extensive outreach and a dedicated survey answered by some 500 industry organizations and 
private companies implemented by the Commission STEP Task Force in 2024 has shown that:  

•  A significant majority of users, regardless of their experience with EU funds, struggle 

to understand and identify available funding opportunities;  

•  The  current  dispersion  of  information  across  multiple  websites  and  one-stop-shops 

hinders accessibility; 

•  Most project applicants rely heavily on external assistance (i.e., consultants) to navigate 
EU funding opportunities, resulting in additional costs for stakeholders before they 
even begin the application process.  

The  preliminary  mapping  of  portals  –  informing  potential  beneficiaries  about  EU  funding 
opportunities – shows that the Commission and/or implementing partners currently operate at 
least 11 portals. Additionally, 6 new portals are under development (see table below). 

From a technical point of view, the lack of harmonisation and standardisation of publication 
requirements  as  well  as  the  lack  of  inter-operability  of  databases  of  funding  opportunities 
across management modes prevents development of an intelligent search engine that  would 
provide  project  promoters  with  an  exhaustive  guidance  on  the  specific  EU  funding 
opportunities for which their projects may be eligible.    

180 

 
 
For  example,  information  about  EU  funding  opportunities  for  programmes  in  direct  and 
indirect  management  is  made  available  under  the  Funding  &  Tender  Portal107.  However, 
navigating the funding landscape to access relevant documents is time-consuming and difficult 
without  extensive  knowledge,  due  to  the  numerous  sources  and  absence  of  a  centralised 
repository108. It can lead to missed opportunities or oversight of critical details, rendering the 
efforts  of  potential  applicants  inefficient.  There  is  also  no  structured  service  to  orient  the 
applicants towards the appropriate form of support (grant, equity, loan). Therefore, potential 
applicants  must  already  be  familiar  with  the  specific  programmes  that  could  support  their 
projects to apply. This lack of visibility undermines the ability of project promoters to access 
financing  under  EU  budget  programmes  and  results  in  unequal  access  to  EU  funding,  in 
particular small organizations such as SMEs which are likely to have less resources to navigate 
existing portals and access procedures109.  

To  address  such  complexity,  public  and  private  organizations  in  the  Member  States  have 
developed  services,  resulting  in  a  highly  diverse  national  offer.  Certain  countries,  such  as 
France (e.g. via BPI France) and the Netherlands (e.g. via InvestNL), have established national 
service points and allocated significant resources to facilitate access to EU funding for national 
companies.  However,  not  all  Member  States  offer  such  services.  Additionally,  national 
promotional  banks,  institutions,  and  networks  of  financial  intermediaries  have  invested  in 
specific tools to navigate the EU financial landscape (e.g. Unicredit in Italy).  

Specific advice is also available at EU level, notably through programmes such as the Horizon 
Policy Support Facility, LIFE, EU4Health, the Innovation Fund, and the InvestEU Advisory 
Hub.  In  doing  so,  the  Commission  supports  potential  applicants  through  various  ‘one-stop-
shops' often focusing on individual sectors or areas (e.g., bio-, clean-tech). At EU level, there 
is no effective user-centric IT tool available to support project promoters across the whole EU 
funding landscape. Potential applicants must search by programme or groups of programmes, 
which assumes that they know which programmes objectives fit their investment needs in the 
first  place.  There  is  no  systematic  coordination  between  the  various  actors  (experts  in  the 
Member States, in executive agencies, or in financial institutions) delivering access to funding 
support. This also leads to the duplication of information linked to funding opportunities and/or 
calls under the same programmes under several portals. As illustrated below, programmes such 
as InvestEU are reflected under multiple portals. 

To summarise, the current landscape of portals generates confusion, undermines transparency 
and reduces project promoters’ ability – including local organizations and SMEs – to identify 
suitable funding sources.  

107 EU Funding & Tenders Portal 
108 In the 2024 STEP Task Force industry outreach, 24% of stakeholders reported difficulties in accessing and 
navigating  EU  funding.  When  asked,  "Is  information  on  EU  funding  easy  to  find?",  respondents  who  only 
searched for information rated it 4.95/10, while those with both search experience and application experience 
rated it slightly higher at 5.6/10. 
109 In the 2024 STEP Task Force industry outreach, stakeholders highlighted that SMEs struggle with a lack of 
clear  information  on  funding  opportunities  and  often  rely  on  external  consultancies  due  to  the  high  resource 
demands of the process. 

181 

 
 
 
Table: Portals and One-Stop-Shops on EU funding opportunities in the 2021-2027 period 

Portal 

Commission 
DG 
in 
charge 

Type  of 
funding  

Content 

Funding 
Tenders Portal 

and 

RTD 

Direct 

The Funding & Tenders Portal is the main entry point for funding programmes and procurement 
options managed by the European Commission and other EU institutions and agencies. 

Programmes  involved:  approx.  40  programmes  (e.g.,  AMIF,  CEF,  CREA,  ERASMUS,  EU4H 
etc.) 

Link: https://ec.europa.eu/info/funding-tenders/opportunities/portal/  

BUDG 

Strategic 
Technologies 
for 
Europe 
Platform (STEP) 

Direct  + 
Indirect 
+ Shared 

The  STEP  funding  dashboard  below  is  an  interactive  guide,  offering  a  continuously  updated 
state-of-play of funding opportunities supported by the EU budget and dedicated to projects 
related to strategic technologies contributing to STEP objectives.   

Programmes  involved:  STEP  uses  resources  across  11  EU  funding  programmes  (Horizon, 
EU4Health, IF, EDF, DEP, ERDF, CF, ESF+, JTF, RRF, InvestEU)  

Link: https://strategic-technologies.europa.eu/get-funding_en  

Net-Zero 
Europe Platform 

GROW 

Direct  + 
Indirect 
+ Shared 

Under development. The Net-Zero Industry Act (NZIA) establishes the Net-Zero Europe Platform 
(Platform) to support the implementation of NZIA. The platform includes representatives from the 
Commission and the EU countries, with the Commission chairing. It monitors progress towards 
the Act’s objectives. 

182 

 
 
 
 
 
Net-Zero Desk 

CLIMA 

tbd 

Under development.  

Access 
Finance 

to  EU 

GROW 

Indirect  The portal helps to apply for loans and venture capital supported by the European Union. 

EU funds: InvestEU, ESIFs, EIB, EIF, RRF. EFSE 

Link: 
finance/search/  

https://youreurope.europa.eu/business/finance-funding/getting-funding/access-

Batteries  One-
Stop-Shop 

GROW  

Direct  + 
Shared 

Access to EU public finance for start-ups and scale-ups in the battery value chain. Co-founded by 
the EU in cooperation with EIT InnoEnergy. (European Battery Alliance) 

Link: https://www.eba250.com/one-stop-shop/  

Hydrogene One-
Stop-Shop 

GROW 

Direct 

Under development.  

183 

 
 
 
 
 
 
 
 
 
InvestEU 
Advisory Hub 

ECFIN 

Indirect  The  InvestEU  Advisory  Hub  is  the  central  entry  point  for  project  promoters  and  intermediaries 

seeking advisory support and technical assistance. 

EU Funds: InvestEU  

Enterprise 
Europe Network 

GROW 

Direct  + 
Shared 

The  Enterprise  Europe  Network  offers  comprehensive  support  to  small  and  medium-sized 
enterprises (SMEs) in accessing and applying for various EU funding programmes: 

Link: https://investeu.europa.eu/investeu-programme/investeu-advisory-hub_en  

- 
Identify EU funding programmes; 
-  Guidance through the funding process; 
-  Finding research partners; 
-  Business innovation strategies 

EU funds: Horizon Europe, LIFE, Erasmus+, Single market Programme, ERDF 

Link: 
funding-programmes  

https://een.ec.europa.eu/about-enterprise-europe-network/advice-support/access-eu-

Innospace 
Platform 

RTD  /  EIC 
+EISMEA 

Direct 

Innospace Platform is a computer platform which aims to provide for an AI-based virtual European 
Innovation  Space  (the  Innospace)  open  to  all  interested  stakeholders  and  parties,  and  include  a 
specific  EIC  AI-based  sub-platform  (the  EIC  Space)  providing  for  the  implementation  and 
management of all EIC instruments and operations. 

184 

 
 
 
 
 
 
On hold  

RTD 

Direct 

The New European Innovation Agenda aims at providing access to finance for deep tech scale-ups 

New  European 
Innovation 
Agenda 

On hold  

EU Rural toolkit  AGRI / JRC  Direct  + 

Indirect 
+ Shared 

The EU Rural toolkit is a portal which guides to EU funding and support opportunities for rural 
areas  in  the  European  Union.  It  aims  to  help  local  authorities,  institutions  and  stakeholders, 
businesses and individuals to identify and take advantage of existing EU funds, programmes and 
other funding and support initiatives, and to foster development in rural territories.  

EU funds: Single Market Programme (SME pillar, Euroclusters), Citizens, Equality, Rights and 
Values programme, LIFE, Horizon Europe (Cluster 2, 5 and 6), CEF (5G), JTF, Creative, European 
Solidarity Corps, AMIF, Erasmus+, EMFAF, ERDF, ESF+, Interreg, CF, EAFRD, InvestEU 

Link: https://funding.rural-vision.europa.eu/finder?lng=en  

InvestEU 
Guarantee 
& 
Equity products 

ECFIN / EIF 

Indirect   The InvestEU Guarantee & Equity Products is a portal  describing and providing information on 

guarantees categories offer by the programme by the EIB within the framework of InvestEU. 

185 

 
 
 
 
 
 
 
 
EU funds: InvestEU 

https://engage.eif.org/investeu/guarantees  

Biotech  One-
Stop-Shop 

GROW 

tbd 

Under  development.  Better  support  for  scale-up  and  ease  of  navigating  regulations:  the 
Commission  is  developing  the  EU  Biotech  and  Biomanufacturing  Hub,  an  operational  tool  for 
biotech and biomanufacturing companies to navigate through the regulatory framework and identify 
support to scale up.  

and 

EAC 

Direct 

Portal  for  application  for  Erasmus+  and  European  Solidarity  Corps  actions  managed  by  the 
Erasmus+ National Agencies. 

Erasmus+ 
European 
Solidarity 
applications 

EU funds: Erasmus+ and European Solidarity Corps 

Erasmus+ and European Solidarity Corps platform 

Procurement, 
grants, 
and 
prizes  organized 
by EUSPA 

EU  Agency 
for 
Space 
Programme 

Indirect  List  of  procurement  opportunities  and  grants  financed  under  Space  regulation  and  launched  by 

EUSPA. 

EU funds: EU Space Programme, Horizon Europe 

186 

 
 
 
 
 
 
 
Transnational 
calls portal 

European 
Competence 
Centre 
for 
Social 
Innovation 

Procurement, grants, and prizes | EU Agency for the Space Programme 

Direct 

List of calls related to social experimentation and social innovation. 

EU funds: ESF+ (EaSI strand) 

https://socialinnovationplus.eu/transnational-calls/funding/transnational-calls/ 

187 

 
 
 
 
 
 
 
Displaying funding opportunities – available under EU funds – via a portal under the 
post-2027 programmes 

The preferred policy option involves transitioning from the current fragmented system of 
multiple portals to a unified, single portal that centralises all EU funding opportunities and 
calls, following the approach used with the Strategic Technologies for Europe Platform 
(STEP) portal. This centralised system would address many of the shortcomings identified 
in  the  current  system,  such  as  the  complexity  of  navigating  multiple  portals,  lack  of 
interoperability,  and  unequal  access  to  funding  information,  particularly  for  SMEs  and 
small organisations. 

The new portal would consolidate the data from all current portals into a single, unified 
database, integrating funding opportunities from the various EU funding programmes and 
across management modes. A centralised IT platform would host the portal, ensuring that 
all  users  (public  and  private  sector,  SMEs,  research  institutions,  etc.)  access  the  same 
database and interface,  for which the STEP  Portal  is  a testing  ground experiment. This 
would require developing the IT infrastructure, including scalable cloud-based solutions, 
to  handle potentially  large volumes of data and users. Here, the EU Funding  &  Tender 
Portal110,  for  example,  could  be  used  as  a  starting  point.  The  implementation  could  be 
designed in stages, starting with the harmonised publication of funding opportunities by 
all contracting authorities. To that end, the new portal would need to: 

- 

-  make  available  standardised  electronic  forms  and  templates  in  all  official 
languages  of  the  Union  (following  the  example  of  the  TED  portal  for 
procurements); 
allow for an electronic exchange of data, in accordance with Article 148 of the 
Financial Regulation, enabling the encoding and transmission of information 
by all contracting authorities;  
allow for the automatic allocation of unique identifiers for each publication;  
develop  virtual  assistance  for  the  identification  of  relevant  EU  funding 
opportunities by project applicants. 

- 

With  a  single  entry  point,  beneficiaries  would  no  longer  need  to  navigate  multiple, 
disparate portals. The portal would act as a one-stop shop where all funding opportunities 
and  calls  are  listed  in  a  centralised  location,  with  a  more  intuitive  and  user-friendly 
interface, similar to what has been done with the STEP portal. This would vastly improve 
user experience by reducing the need to search through multiple systems. There would be 
fewer instances of duplicated content, and beneficiaries would be able to access the correct, 
up-to-date information without encountering redundant or conflicting data.111 

By simplifying access to EU funding opportunities, the portal would help address the issue 
of unequal access, particularly for small and medium-sized enterprises (SMEs) and less-
resourced organisations. These organisations would find it easier to identify and apply for 
relevant funding opportunities without the burden of navigating complex systems.  

110 https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/home  
111  In  the  2024  STEP  Task  Force  industry  outreach,  72%  of  respondents  saw  value  in  a  one-stop-shop 
integrating  EU  and  national  funding,  citing  benefits  such  as  easier  discovery,  time  savings,  and  greater 
clarity. Additionally, nearly 89% of users reported finding the information they needed on the STEP Portal. 

 
 
 
In the second stage of implementation, the single portal would provide a single entry point 
enabling applicants to directly submit their project applications  in one place and in line 
with harmonised rules of procedure. 

The  portal  conceived  as  an  ‘EU  funding  shopping  mall’  could  offer  advanced  search 
functions  and  personalized  recommendations,  helping  users  find  the  most  relevant 
opportunities based on their specific projects and needs. The portal could also integrate 
AI-driven tools, such as chatbots and virtual assistants, to provide real-time guidance on 
the  available  funding  options,  helping  users  navigating  the  system  and  answering 
frequently  asked  questions  about  eligibility,  application  processes,  and  requirements.  It 
could feature an advanced guidance system that leads beneficiaries through a step-by-step 
process to identify the most suitable funding programs for their needs (e.g., grants, loans, 
equity) and provide access to sector-specific support through dedicated advisory services 
(e.g.  include  links  to  specialized  EU-level  support  services,  such  as  Horizon  Europe 
advisory services for research, or InvestEU advisory services for investment projects).112 
This would ensure that users are not overwhelmed by the complexity of funding options 
and can receive tailored advice. Key features would include user-friendly design, direct 
application,  smart  filtering  of  opportunities,  automatic  notifications,  updates  across  the 
application process, and dynamic profiling. 

A key technical requirement would be to standardise the data from current portals. This 
would  involve  creating  common  data  formats  and  metadata  across  different  funding 
programs to ensure consistency and accuracy. For example, aligning the way funding calls 
are categorised (e.g., by type of support, sector, or target group) across all programs. All 
funding calls, deadlines, eligibility criteria, and application details would be presented in 
a standardised format, making it easier for users to compare opportunities across different 
programs.  Automatic  integration  of  data  on  all  Union  programmes  would  ensure  that 
beneficiaries always have access to the most up-to-date information, reducing the risk of 
missed opportunities due to outdated data. 

The centralisation will also enable the Commission to reduce administrative burden and 
management costs by consolidating resources and streamlining operations. This approach 
will lead to greater operational efficiency and cost savings, while ensuring that the data 
remains accurate, up-to-date, and consistent across all funding initiatives. 

A centralised portal would allow for better tracking and monitoring of user engagement, 
funding  application  trends,  and  system  performance  contributing  to  enhanced  business 
intelligence.  This  could  guide  future  policy  decisions  and  improvements  to  the  portal’s 
functionality, ensuring that the system evolves to meet the needs of users. 

The preferred policy option foresees a differentiated operationalization per management 
mode  or  programme,  whereby  the  single  portal  would  enable  to  display  programme-
specific  information  regarding  available  funding  opportunities.  The  portal  would  also 
include links redirecting users to more specific sources such as thematic or national portals 
hosted e.g. by Member States and regions. 

112  In  the  2024  STEP  Task  Force  industry  outreach,  users  identified  AI's  greatest  value  in  keeping  them 
informed (74.7%), supporting them during onboarding (76%), and assisting with applications (69.6%). 

189 

 
 
 
ANNEX 9: ANALYSIS OF IMPACTS OF POLICY OPTIONS 

1.  Assessment of impacts of policy options P1, M1 and R1 (baseline) 

A.  Economic impacts  

For  EU  budget  beneficiaries,  Member  States,  partner  countries  and  implementing 
partners:  

Policy option  
P1: Baseline – 
Programme-specific 
rules on DNSH and 
gender equality  

Economic impacts   
This option corresponds to using different DNSH requirements and guidances 
across MFF programmes. As a result, in cases where the same type of projects 
are  eligible  for  funding  under  different  EU  funds,  different  DNSH 
requirements  may  apply  depending  on  the  rules  applying  under  each 
programme. Such heterogeneity can help better adapting DNSH requirements 
to the specificities of each programme, but can generate costs linked to the 
complexities  and  implementation  burden  expected  to  be  faced  by  Member 
States, partner countries and project beneficiaries such as businesses which 
have to deal with divergent requirements sometimes for a single project.   
This option also foresees programme-based gender equality requirements. For 
Member  States  and  beneficiaries  –  such  as  businesses  –  eligible  under 
different  EU  budget  programmes,  this  is  expected  to  generate  complexities 
and  administrative  burden,  as  they  would  have  to  manage  and  implement 
heterogeneous rules.  
Competitiveness:  Implementing  heterogeneous  DNSH  requirements  may 
generate price pressures i.e. navigating such complex requirements is likely to 
increase  production  costs,  which  may  lead  to  higher  prices  for  goods  and 
if 
services.  This  can  reduce  businesses  competitiveness,  especially 
competitors – inside or outside the EU – are not subject to the same stringent 
requirements or are able to absorb these costs more easily. Compliance with 
heterogeneous DNSH requirements may also lead to reducing market access 
and ultimately reduce competitiveness. While some markets may value and 
even  require  sustainable  practices,  others  may  prioritise  cost  over 
sustainability.  For  businesses,  especially  those  in  highly  price-sensitive 
markets, adherence to complex DNSH provisions can limit market access or 
the  ability  to  compete  effectively  on  pricing.  The  heterogeneity  of  DNSH 
requirements from one programme to the other is also expected to generate 
uncertainties and a lack of predictability for beneficiaries such as businesses, 
which is likely to negatively impact the competitiveness of economic sectors 
supported by EU funds.   
Small and Medium Enterprises: SMEs are expected to be directly confronted 
with such challenges. SMEs often have limited financial resources compared 
to 
implementing  complex  and  heavy  DNSH 
requirements is likely to require investments in new processes which can be 
costly. Navigating the regulatory requirements associated with DNSH can be 
complex, requiring significant time and effort to understand and implement 
compliant practices. As SMEs are likely to lack the necessary expertise and 
manpower  to  comply  with  complex  DNSH  requirements,  hiring  external 
consultants or dedicating existing staff to such activities can be a significant 
burden.  In  some  cases,  adhering  to  the  DNSH  principle  may  require 
substantial  changes  to  existing  business  models,  production  processes,  or 

larger  companies 

i.e. 

190 

 
 
 
M1: Baseline – 
Programme-specific 
rules for defining 
tracking methodologies 
and performance 
indicators  

supply chains, which can be expensive and disruptive, even though a change 
of  business  model  to  be  DNSH  compliant  may  also  have  a  positive  long-
lasting  impact  on  the  sustainability  of  the  company’s  business  model. 
Developing  or  adopting  innovative  solutions  to  align  with  complex  DNSH 
provisions  may  also  require  IT,  and  research  and  development  capabilities, 
that  SMEs  might  not  possess.  Overall,  while  the  DNSH  principle  aims  to 
promote sustainable practices, the costs and compliance challenges associated 
with the heterogenous requirements – in place in the 2021-2027 period – can 
disproportionately  affect  SMEs,  potentially  hindering  their  growth  and 
competitiveness in the market.  
The  adaptation  of  the  sector-specific  guidances  developed  under  the  2021-
2027 period to the architecture and new programmes in the post-2027 MFF 
would  also  trigger  one-off  costs  linked  to  the  transition  required  for  MFF 
beneficiaries  –  including  businesses  such  as  SMEs  –  to  adapt  to  the  new 
guidances.  
This  option  would  result  in  programme-specific  methodologies  to  track 
expenditures  supported  by  the  EU  budget,  as  well  as  multiple  sets  of 
performance  indicators  across  MFF  programmes.  Member  States,  partner 
countries and beneficiaries – including businesses – would deal with multiple 
expenditure tracking and indicators monitoring systems. The reporting burden 
is expected to remain relatively high and generate costs associated with project 
monitoring,  though  the  new  architecture  of  the  post-2027  MFF  and  the 
reduction  of  the  number  of  EU  budget  programmes  is  expected  to  slightly 
reduce reporting burdens.  
Competitiveness:  Maintaining  a  relatively  heterogeneous  and  complex 
approach  to  reporting  performance  via  indicators  in  contracts  or  grant 
agreements  under  EU  budget  programmes  is  expected  to  perpetuate 
administrative  burdens  and  hinder  the  competitiveness  of  economic  sectors 
and  companies  supported  by  EU  budget  programmes.  Different  –  and 
sometimes  heavy  –  sets  of  indicators  for  each  programme  may  create  a 
complex  reporting  environment,  in  particular  for  large  organisations  and 
companies  supported  by  various  EU  budget  programmes.  Under  direct  and 
indirect  management  programmes,  diverse  reporting  standards  may  require 
beneficiaries  to  develop  extensive  data  management  infrastructures  and 
expertise  to  ensure  compliance.  This  can  lead  to  higher  compliance  costs 
associated with hiring specialised staff or consultants and investing in multiple 
reporting  systems.  Complex  reporting  frameworks  may  also  increase  the 
likelihood  of  errors  in  data  collection  and  reporting.  Mistakes  can  lead  to 
compliance  issues,  delays  in  funding  disbursement,  and  potential  penalties, 
negatively  impacting  financial  stability  and  reputation  of  EU  budget 
beneficiaries. Overall, a complex reporting environment can limit the ability 
of businesses to innovate, grow, and remain competitive in the global market. 
Simplification  and  harmonisation  of  indicators  reporting  standards  would 
therefore be beneficial for beneficiaries, including businesses.  
Small and Medium Enterprises: SMEs, which often operate with limited staff 
and financial resources, can be disproportionately affected by the complexity 
of indicators reporting requirements under EU budget programmes. The need 
to comply with heavy requirements may divert resources from innovation and 
business  development,  thus  stifling  growth  potential.  The  complexity  of 
reporting requirements may also deter SMEs from participating in EU-funded 
programmes. The perceived or actual administrative burden may outweigh the 
benefits, restricting access to valuable funding opportunities.  

191 

 
 
R1: Baseline – 
Programme-specific 
reporting requirements, 
dashboards and portals  

This option would result in maintaining the current costs linked to maintaining 
a programme-specific approach to the reporting of performance information 
across the EU budget, maintaining the current system of multiple dashboards 
displaying  performance  information,  and  maintaining  existing  portals 
informing beneficiaries about funding opportunities. This option is expected 
to result in a continuation of the costs currently allocated by Member States, 
budgetary  authorities  and  interested  stakeholders  to  having  to  navigate  and 
process multiple reports, dashboards and portals on the performance of EU 
budget programmes and funding opportunities.   
Competitiveness: Maintaining multiple portals displaying information on the 
performance of EU budget programmes and funding opportunities is expected 
to  maintain  the  current  costs  of  navigating  and  using  several  sources  of 
information, ultimately hindering the competitiveness of businesses supported 
by EU budget programmes. This option is expected to rely upon several entry 
points  for  relevant  data  and  resources,  maintaining  potential  navigation 
challenges  for  businesses  and  resource  implications  related  to  the  time  and 
effort spent searching for information across multiple platforms. Businesses 
would  continue  to  face  costs  associated  with  managing  multiple  accounts, 
software tools, and consulting services needed to track and apply for diverse 
funding  opportunities.  This  option  is  therefore  expected  to  maintain  the 
challenges observed during the 2021-207 period for beneficiaries – including 
businesses  –  thereby  limiting  the  competitiveness  of  economic  sectors 
supported by EU budget programmes both a European and global scale.   
Small and Medium Enterprises: SMEs, which often operate with limited staff 
and financial resources, are disproportionately affected by the complexity of 
existing EU portals displaying information on funding opportunities. Under 
this  baseline  option,  SMEs  would  continue  to  face  challenges  in  accessing 
information,  limiting  their  ability  to  be  responsive  to  new  support 
opportunities  and  hindering  their  access  to  funding  under  EU  budget 
programmes.  

For EU institutions:  

Policy option  
P1: Baseline – 
Programme-specific rules 
on DNSH and gender 
equality  

M1: Baseline – 
Programme-specific rules 
for defining tracking 
methodologies and 
performance indicators  

Economic impacts   
This  option  corresponds  to  using  different  DNSH  requirements  and  guidances 
across  MFF  programmes.  This  would  require  adapting  the  sector-specific 
guidances  developed  under  the  2021-2027  period  to  the  architecture  and  new 
programmes in the post-2027 MFF, which would trigger significant costs linked 
to the development and implementation of such guidance by the Commission.   
This  option  would  result  in  programme-specific  methodologies  to  track 
expenditures supported by the EU budget, as well as multiple sets of performance 
indicators across MFF programmes. Having programme-specific methodologies 
may  allow  a  more  granular  monitoring  tailored  to  specific  programmes,  and 
indicators that are closely aligned with the intervention logic of each programme. 
At the same time, such an approach would result in relatively significant costs and 
administrative  burden  –  in  particular  for  the  Commission  –  linked  to  the 
development  and  management  of  several  ad  hoc  methodologies  to  track 
expenditures  across  programmes,  as  well  as  linked  to  the  collection  of  data, 
management  and  processing  of  a  large  number  of  heterogeneous  and  non-
aggregable performance indicators.  

192 

 
 
  
R1: Baseline – 
Programme-specific 
reporting requirements, 
dashboards and portals  

This option would result in maintaining the cost observed in the 2021-2027 period 
linked to multiple requirements on performance reporting, which would not enable 
the Commission to achieve efficiency gains nor reduce the resources allocated to 
preparing  such  reports,  maintaining  duplication  of  information  and  reporting 
processes.  It  would  also  result  in  EU  institutions  –  e.g.  European  Parliament  – 
continuing  to  face  costs  allocated  to  having  to  navigate  and  process  multiple 
reports on the performance of EU budget programmes. Maintaining the current 
system  would  is  likely  to  result  in  maintaining  an  intermediate  level  of 
transparency and data utilisation for policy decisions.  
This  option  would  also  result  in  a  continuation  of  the  costs  linked  to  the 
management  of  several  online  dashboards  and  portals  displaying  EU  budget 
performance  information  and  information  on  available  funding  opportunities 
centralising all information under the EU budget. This would maintain the costs 
currently faced by the Commission to manage multiple dashboards and portals.  

B.  Social impacts  

Policy option  
P1: Baseline – 
Programme-specific 
rules on DNSH and 
gender equality  

M1: Baseline – 
Programme-specific 
rules for defining 
tracking methodologies 
and performance 
indicators  
R1: Baseline – 
Programme-specific 
reporting requirements, 
dashboards and portals  

remain 

fragmented  and 

Social impacts   
Under this option, gender equality mainstreaming provisions would be applied 
at  programme  level.  While  progress  has  been  made  in  integrating  gender 
equality into the 2021–2027 Multiannual Financial Framework (MFF), gender 
mainstreaming  would 
inconsistent  across 
programmes.  This  reliance  on  heterogeneous  tools  such  as  earmarking  and 
conditionality  has  led  to  uneven  results,  with  some  initiatives  achieving 
notable success while others exhibit limited or no focus on gender equality. 
This option risks perpetuating these challenges, undermining the EU’s broader 
commitment to gender equality.   
This option would result in programme-specific methodologies to track EU 
budget  expenditures  supporting  gender  equality,  as  well  as  performance 
indicators that cannot systematically be disaggregated by gender. This option 
would therefore limit the Commission’s ability to achieve social outcomes as 
it  would  make  it  more  difficult  to  assess  the  contribution  of  EU  budget 
programmes to gender equality.  
Maintaining multiple reporting requirements – through several performance 
reports – would result in maintaining the level of transparency of information 
regarding the performance of the EU budget observed during the 2021-2027 
period,  including  regarding  the  EU  budget  contribution  to  social  priorities 
such as gender equality. Such an approach is likely to achieve no additional 
social outcomes as it would not enable to increase access to information for 
budgetary authorities and Member States on how the EU budget contributes 
to gender equality, which may ultimately limit policymakers’ ability to adopt 
more inclusive and equitable policies as part of the management of EU budget 
programmes.  
This option would also result in maintaining the level of access to information 
on  EU  budget  funding  opportunities,  through  multiple  portals.  Access  by 
beneficiaries  looking  for  support  in  the  field  of  social  objectives  such  as 
equality – including gender equality – would be maintained as under the 2021-
2027 period, which is expected to have no positive social impact.  

C.  Environmental impacts  

193 

 
 
  
  
Policy option  
P1: Baseline – 
Programme-specific 
rules on DNSH and 
gender equality    

M1: Baseline – 
Programme-specific 
rules for defining 
tracking methodologies 
and performance 
indicators  
R1: Baseline – 
Programme-specific 
reporting requirements, 
dashboards and portals  

Environmental impacts   
Under  this  option,  the  complexity  of  DNSH  requirements  and  guidances  – 
across  EU  budget  programmes  –  is  expected  to  result  in  uneven  and 
insufficient  implementation  of  the  DNSH  principle  across  the  EU  budget. 
Such  a  system  is  expected  to  lead  to  potentially  detrimental  environmental 
effects  and may  increase  the  risk  of  support  of  potentially  environmentally 
harmful activities by the EU budget.  
This option would result in programme-specific methodologies to track EU 
budget expenditures  supporting  environmental  objectives  –  such  as  climate 
mitigation, adaptation, and biodiversity. This option would therefore limit the 
Commission’s ability to achieve environmental outcomes as it would make it 
more  difficult  to  assess  the  contribution  of  EU  budget  programmes  to 
environmental objectives.  
This  policy  option  would result in  maintaining the  level of  transparency  of 
information regarding the performance of the EU budget observed during the 
2021-2027 period, including regarding the EU budget contribution to climate 
mitigation, adaptation, and biodiversity.  
This  policy  option  would  also  result  in  maintaining  the  level  of  access  to 
information on EU budget funding opportunities, including for beneficiaries 
looking for support in the field of environmental objectives.  

2.  Quantitative analysis of impacts of policy options 

The analysis presents the estimated quantitative impacts of the policy options considered 
in the context of the impact assessment of the performance framework for the post-2027 
Multiannual  Financial  Framework. It  aims  at  quantifying  the  impacts  of  each  policy 
option, the ultimate objective being to assess options 2 and 3 against the baseline i.e. option 
1.  This  analysis  of  expected  reductions  of  administrative  costs  supports  the  analysis  of 
efficiency of each policy option as presented under Section 7.2 of the impact assessment.  

The analysis focuses on  the costs of  each policy  option, and potential cost  savings and 
efficiency gains resulting from reduced administrative burden linked to a harmonised and 
simplified  performance  framework  across  the  EU  budget.  In  contrast  with  impact 
assessments  linked  to  specific  EU  budget  programmes,  where  investments  impacts  are 
typically predicted based on macro-economic modelling, this quantitative analysis assesses 
reductions of administrative costs and burdens for EU Member States, including national 
administrations  and  beneficiaries.  The  analysis  does  not  include  an  assessment  of  the 
impacts of the policy options on non-EU countries supported by EU external action funds 
due to  a lack of  available data, but  it is  expected that the policy options  will also  have 
significant  impacts  on  programming,  monitoring  and  reporting  requirements  in  partner 
countries. 

The quantitative analysis addresses the three dimensions of the impact assessment: 

-  programming and mainstreaming of horizontal priorities and principles: the 
analysis focuses on the administrative burden linked to implementing the Do No 
Significant Harm (DNSH) principle; 

194 

 
 
 
-  monitoring  of  performance:  the  analysis  focuses  on  the  administrative  burden 
linked to the monitoring of performance through a single list of intervention fields 
and performance indicators; 
reporting of performance information: the analysis focuses on the administrative 
burden  linked  to  the  development  of  a  single  portal  displaying  performance 
information and funding opportunities available under the EU budget.  

- 

The quantitative impacts presented in this analysis are based on a set of assumptions and 
estimates made by the Commission, derived from available data, and should be considered 
indicative, considering the lack of available data. The actual impacts of policy options may 
vary depending on future developments and the availability of new information. 

A.  Programming of horizontal priorities and principles 

The policy options foresee three levels of harmonising DNSH requirements across the EU 
budget, from  a programme-based approach (P1) to a fully  harmonised DNSH approach 
across all programmes (P3).  

The quantitative analysis focuses on the anticipated reduction of administrative burden for 
Member States administrations resulting from the simplification of DNSH requirements, 
compared to a programme-specific approach requiring compliance with several different 
DNSH guidance and systems, sometimes for the same type of projects. The analysis relies 
upon  a  quantification  of  the  number  of  full-time  equivalent  (FTE)113  employees  or 
consultants in charge of the operationalization of the DNSH principle in the 27 Member 
States administrations for a duration of 7 years. Such operationalization tasks may include 
contribution to the design of DNSH guidance at EU level, transposing EU level guidance 
into  national  systems,  providing  guidance  and  training  to  national  stakeholders  and 
beneficiaries, checks of DNSH compliance, developing national assessment tools, as well 
as reporting and coordination of implementation at EU level.  

A  reduction  factor  is  applied  to  policy  options  P2  and  P3,  reflecting  the  expected 
simplification of DNSH implementation and the corresponding decrease in administrative 
burden. This reduction factor is an estimate by the Commission in the absence of quantified 
data, reflecting the reduction of administrative burden achieved by reducing the number of 
DNSH  guidances  and  approaches,  moving  from  a  programme-based  approach  to  a 
harmonised  activity-specific  approach  based  on  a  single  guidance  applying  to  all  EU 
budget  programmes.  The  single  guidance  reduces  the  risks  of  confusion  and  allows 
projects to be subject to a single set of DNSH conditions irrespective of the programme 
providing support. Compared to option P3, the reduction factor applied to policy option P2 
further reflects the proportionate approach foreseen under this option, expected to further 
reduce administrative burden. This includes the exemption of DNSH checks foreseen for 
defence and security, and the differentiated operationalization per management mode and 
type of action (internal vs. external) which is expected to further facilitate implementation.  

113 The average cost of an FTE policy officer in EU Member State administrations is estimated at EUR 50,273 
per year, based on Eurostat’s 2020 average hourly labour cost for public administration, reflecting variations 
across EU Member States. 

195 

 
 
 
The  estimation  also  includes  an  entry  costs  factor  corresponding  to  the  costs  of 
transitioning to policy option 2 or 3. The entry cost factor attached to option P2 is lower 
than the entry cost factor attached to option P3, because P3 would entail the development 
of technical DNSH guidance by the Commission in consultation with Member States for 
all interventions and sectors of the common list of intervention fields, and the deployment 
and  training  of  Member  States  covering  the  scope  of  such  an  extensive  guidance. 
Comparatively option P2 applies DNSH checks to less interventions and projects, entailing 
lower entry costs for Member States.  

Policy option P1  

(baseline)  

Policy option P2 
(harmonised but 
proportionate DNSH)  

Policy option P3  

(fully harmonised DNSH)  

Number of EU Member 
States: 27 

Number of EU Member 
States: 27 

Number of EU Member 
States: 27 

Number of FTEs per year 
and per MS: 18114 

Number of FTEs per year 
and per MS: 18 

Number of FTEs per year and 
per MS: 18 

MFF duration (years): 7 

MFF duration (years): 7 

MFF duration (years): 7 

Total cost: EUR 171 
million  

Reduction factor: 0.5115 

Reduction factor: 0.8 

Entry costs factor: 1.1 

Entry costs factor: 1.2 

Total cost: EUR 94 million  

Total cost: EUR 151 
million  

Based on the above analysis, policy option P2 appears to deliver the greatest benefits 
in terms of reducing costs linked to administrative burden. 

114 The average number of 18 FTEs – per year and per Member State – corresponds to FTEs dedicated to 
DNSH implementation for all EU budget programmes (including RRF, cohesion policy funds, InvestEU) 
and for all national administrations i.e. both national and sub-national administrations of the Member States. 
This estimation is based on an extrapolation of data  from the  Technical Support Instrument assistance in 
implementing the DNSH principle in selected Member States (Spain, Italy, Cyprus) (source: SG REFORM). 
115 The reduction factors applied to policy options P2 (0.5) and P3 (0.8) are assumptions based on estimations 
by Commission services. These factors reflect anticipated efficiencies in administrative processes due to the 
simplification  and  harmonisation  of  DNSH  requirements,  representing  the  best  available  estimate  in  the 
absence  of  comprehensive  data.  The  factors  used  in  the  case  of  options  P2  and  P3  reflect  the  expected 
reduction of costs linked to programme-specific DNSH approaches and guidances from 13 in the 2021-2027 
period  to  a  single  approach  and  guidance  applying  to  all  EU  budget  programmes  post-2027.  The  factor 
attached  to  option  P3  could  therefore  have  been  set  at  1/13,  but  this  was  considered  as  a  strong 
underestimation  of  costs  due  to  uncompressible  administrative  costs  below  a  certain  number  of  DNSH 
approaches, hence the factor was set at 0.8. The factor applied to P2 (0.5) reflects a further reduction of the 
number of projects expected to be subject to DNSH compliance checks. 

196 

 
 
 
 
 
Under policy options P2 and P3, significant reductions of administrative burden are also 
expected at the level of EU budget beneficiaries, including businesses such as Small and 
Medium Enterprises (SMEs), but quantifying such a reduction was not possible due to a 
lack  of  available  data. Significant  cost  reductions  are  nonetheless  foreseen  for 
beneficiaries, as a simplified approach to DNSH would streamline compliance processes, 
reduce  the  complexity  and  time  required  to  navigate  varying  programme-specific 
requirements, and lower the costs and resources needed for documentation, reporting, and 
verification, facilitating access to EU budget programmes. 

B.  Monitoring of performance 

The policy options foresee three levels of harmonising the monitoring of expenditures and 
performance indicators across the EU budget, from a programme-based approach (M1) to 
a  fully  harmonised  list  of  intervention  fields  and  performance  indicators  across  all 
programmes (M3).  

The quantitative analysis focuses on the reduction of administrative burden expected to be 
achieved by Member State administrations as a result of simplifying expenditure tracking 
and  indicator  monitoring  requirements.  This  is  compared  to  the  current  programme-
specific  approach,  which  relies  on  a  large  number  of  indicators  under  the  various  EU 
budget programmes, requiring extensive monitoring and reporting. The analysis therefore 
assesses the costs linked to  each policy options in relation  to  a the tasks carried out  by 
Member  States  administrations,  such  as  contributing  to  the  design  and  management  of 
indicators at EU level, transposing EU level indicators system into national systems, data 
collection  and  management  at  national  level,  data  verification,  providing  guidance  and 
training to national stakeholders and beneficiaries having to report against such indicators, 
developing national tools and systems,  reporting and coordination of implementation at 
EU level. 

The analysis relies upon a quantification116 of the administrative costs linked to reporting 
and  monitoring  tasks  for  the  Common  Provisions  Regulation  funds  in  the  2021-2027 
period, extrapolated to the entire EU budget117. The analysis would have ideally required 
specific data on administrative costs for other EU budget  programmes, including funds 
under direct or indirect management, but such data was not available. A similar analysis 
was conducted following a slightly different approach, based on the number of full-time 
equivalent (FTE) employees or consultants in charge of the monitoring and reporting of 
indicators, using the mid-term evaluation of the Recovery and Resilience Facility, which 
led to results of a similar order of magnitude. 

Similar to section A, a reduction factor is applied to policy options M2 and M3, reflecting 
the expected simplification of expenditure tracking and reduction in the number of unique 
indicators, e.g. from ca. 5 000 in the 2021-2027 period to ca. 900, resulting in a reduction 
of the administrative burden. This reduction factor is an estimate by the Commission in the 

116  Draft  study  ‘ASSESSMENT  OF  THE  ADMINISTRATIVE  COSTS  AND  ADMINISTRATIVE 
BURDEN IN THE MANAGEMENT OF THE COMMON PROVISIONS REGULATION FUNDS 2021-
2027’ March 2025. 
117 The size of the post-2027 MFF being unknown at the stage of drafting the impact assessment, the estimate 
uses the size of the 2021-2027 MFF as a proxy for the size of the post-2027 MFF. 

197 

 
 
 
absence of further quantitative data, which captures expected efficiency gains, including 
reduced data collection and  quality  control  efforts  through the adoption of  standardised 
metadata, the automatic processing of some indicators by the Commission, reduced follow-
up on Member States and an improvement in procedural clarity. The reduction factor used 
in the case of option M3 is lower than  the factor used for M2, because M3 is expected to 
achieve significant higher reduction of the number of performance indicators and of the 
administrative burden linked to performance monitoring across EU budget programmes. 
The estimation also includes an entry cost factor corresponding to the costs of transitioning 
to policy option M2 or M3. The entry cost factor attached to option M2 is lower than the 
entry cost factor attached to option M3, reflecting higher costs of transitioning to a fully 
harmonised system of performance monitoring. 

Policy option M1  

Policy option M2   

Policy option M3  

(baseline)  

(single list of intervention 
fields, single non-mandatory 
list of indicators + limited set 
of common indicators)  

(single list of intervention fields, 
fully harmonised list of indicators 
+ limited set of common 
indicators)  

Estimated costs of reporting, 
monitoring and evaluation, in 
EUR per million EUR spent: 
EUR 1 957 

Estimated costs of reporting, 
monitoring and evaluation, in 
EUR per million EUR spent: 
EUR 1 957 

Estimated costs of reporting, 
monitoring and evaluation, in 
EUR per million EUR spent: 
EUR 1 957 

Ratio corresponding to 
monitoring and reporting 
costs: 2/3118 

Ratio corresponding to 
monitoring and reporting 
costs: 2/3 

Ratio corresponding to 
monitoring and reporting 
costs: 2/3 

Size of 2021-2027 MFF:                       
EUR 1 074 000 million 

Size of 2021-2027 MFF:                       
EUR 1 074 000 million  

Size of 2021-2027 MFF:                          
EUR 1 074 000 million 

Total cost: EUR 1 401 
million  

Costs reduction factor: 0.8119 

Costs reduction factor: 0.5 

Entry costs factor: 1.2 

Entry costs factor: 1.3 

118 This ratio corresponds to an assumption based on estimations by Commission services whereby, out of 
the amount of EUR 1957 spent  for the purpose of reporting, monitoring and evaluation  per million EUR 
spent, 2/3 is dedicated to the tasks in the scope of policy options M2 and M3 i.e. tracking of expenditures 
and monitoring of indicators (including management and data collection). 
119  The  reduction  factors  applied  to  policy  options  M2  (0.8)  and  M3  (0.5)  are  assumptions  based  on 
estimations  by  Commission  services.  These  factors  reflect  anticipated  efficiencies  in  administrative 
processes due to the simplification and harmonisation of performance monitoring requirements, representing 
the best available estimate in the absence of comprehensive data. The factor used in the case of option M3 
reflects  the  expected  reduction  of  costs  linked  to  programme-specific  monitoring  approaches  and  sets  of 
indicators, reflecting a reduction of indicators from over 5 000 in the 2021-2027 period to less than 1 000 
post-2027. The factor attached to option M3 could therefore have been set at 0,2, but this was considered as 
a  strong  underestimation  of  costs  due  to  uncompressible  administrative  costs  below  a  certain  amount  of 
indicators, hence the factor was set at 0.5. The factor applied to M2 (0.8) reflects a more limited expected 
reduction of administrative burden due to the fact that programmes would keep the flexibility to adopt – a 
potentially significant number of – programme-specific indicators in addition to the common list. 

198 

 
 
 
Total cost: EUR 1 345 
million 

Total cost: EUR 911 million 

Based on the above analysis, policy option M3 appears to offer the greatest benefits in 
terms of reducing the costs associated to administrative burden. 

Under policy options M2 and M3, significant reductions of administrative burden are also 
expected at the level of EU budget beneficiaries, including businesses such as Small and 
Medium  Enterprises  (SMEs),  which  would  result  from  streamlined  monitoring  and 
reporting requirements, in particular under direct management programmes. Quantifying 
such a reduction of administrative burden was nonetheless not possible due to a lack of 
available  data. Significant  cost  reductions  are  nonetheless  foreseen  for  beneficiaries,  as 
simplifying  monitoring  requirements under EU budget  programmes would decrease the 
number of indicators tracked, simplifying data collection and submission processes, and 
saving time and resources, particularly for small businesses with limited capacity, reducing 
resources required for extensive compliance documentation. 

C.  Reporting of performance information 

This section focuses on dashboards enabling to report performance information and portals 
displaying information on available funding opportunities.  

1.  Dashboards displaying performance information 

The  policy  options  foresee  three  levels  of  harmonising  the  reporting  of  performance 
information  across  the  EU  budget,  from  a  baseline  situation  whereby  performance 
information is displayed through several – often programme-specific – dashboards (R1) to 
a single and fully harmonised dashboard (R3).  

The quantitative analysis focuses on the reduction of costs linked to the development and 
management of performance dashboards, expected to be achieved by the Commission as a 
result of merging dashboards into a single one, compared to maintaining the current system 
which  relies  on  approximately  20  performance  dashboards.  The  analysis  is  based  on  a 
quantification of the costs of developing and maintaining performance dashboards, using 
the costs of existing dashboards as a benchmark120. 

A factor is  applied to  policy option R2,  to  account  for the expected  costs  linked to  the 
integration or development of specific pages displaying data related to dedicated areas and 
sectors. The analysis also assumes higher annual management and maintenance costs per 
dashboard in the case of a single – larger – dashboard than in the case of several – smaller 
– dashboards. 

Policy option R1  

Policy option R2   

Policy option R3  

120 Including performance SAP BPC tool and dashboards (source: DG BUDG) 

199 

 
 
  
 
(baseline)  

(single dashboard with 
harmonised performance 
information across the EU 
budget + pages displaying 
specific data regarding 
dedicated areas and sectors)  

(single dashboard with fully 
harmonised performance 
information across the EU 
budget)  

Initial development costs: 
EUR 0 

Initial development costs: 
EUR 0.65 million 

Initial development costs: 
EUR 0.65 million 

Annual management costs 
per portal: EUR 0.2 million 

Annual management costs 
per portal: EUR 0.4 million 

Annual management costs per 
portal: EUR 0.4 million 

Number of portals: 20 

Number of portals: 1 

Number of portals: 1 

MFF duration (years): 7 

MFF duration (years): 7 

MFF duration (years): 7 

Total cost: EUR 28.0 
million  

Factor reflecting the costs of 
displaying specific data 
regarding dedicated areas 
and sectors121: 2 

Total cost: EUR 3.5 million  

Total cost: EUR 6.9 million  

Based on the above analysis, policy option R3 appears to offer the greatest benefits in terms 
of reducing costs associated with  the development and maintenance of the performance 
information dashboard.  

Under policy options R2 and R3, significant reductions of administrative burden are also 
expected at the level of Member States and budget authorities as well as beneficiaries and 
stakeholders,  which  would  benefit  from  facilitated  access  to  performance  information 
compared to the current system which requires navigating several dashboards. Quantifying 
such a reduction of administrative burden was nonetheless not possible due to a lack of 
available data.  

2.  Portals displaying information on available funding opportunities 

The policy options foresee three levels of harmonising portals displaying information on 
available funding opportunities across the EU budget, from a baseline situation whereby 
performance information is displayed through several – sometimes programme-specific – 
portals (R1) to a single and fully harmonised portal replacing Member States portals (R3).  

121 The factor applied to policy option R2 (2) is an assumption based on estimations by Commission services. 
This factor reflects the expected increase of costs for the Commission to develop the necessary IT adaptations 
so  that  the  single  dashboard  would  enable  to  display  specific  data  regarding  dedicated  areas  and  sectors 
supported by the EU budget. 

200 

 
 
 
  
 
The quantitative analysis focuses on the reduction of costs linked to the development and 
management of portals expected to be achieved by the Commission as a result of merging 
existing portals into one compared to maintaining the current system which relies upon ca. 
12 portals on funding opportunities. The analysis relies upon a quantification of the costs 
of developing and maintaining existing portals developed by the Commission, using as a 
benchmark the costs of existing portals122. 

A  factor  is  applied  to  policy  option  R3,  reflecting  the  expected  costs  linked  to  the 
integration  of  Member  States  portals  into  an  EU-wide  system,  rather  than  a  simple  re-
direction towards Member States portals as foreseen under policy option R2. The analysis 
also assumes higher annual management and maintenance costs per portal in the case of a 
single – larger – portal than in the case of several – smaller – portals. 

Policy option R1  

Policy option R2   

Policy option R3  

(baseline)  

(single portal with 
harmonised information on 
funding opportunities across 
the EU budget + redirection 
to Member States portals)  

(single portal with harmonised 
information on funding 
opportunities across the EU 
budget + integration of Member 
States portals)  

Initial development costs: 
EUR 0 

Initial development costs: 
EUR 3 million 

Initial development costs: 
EUR 3 million 

Annual management costs 
per portal: EUR 0.5 million 

Annual management costs 
per portal: EUR 1 million 

Annual management costs per 
portal: EUR 1 million 

Number of portals: 12 

Number of portals: 1 

Number of portals: 1 

MFF duration (years): 7 

MFF duration (years): 7 

MFF duration (years): 7 

Total cost: EUR 42 million 

Total cost: EUR 10 million  

Factor reflecting the expected 
costs of the integration of 
Member States portals into an 
EU-wide system123: 3 

Total cost: EUR 30 million  

Based on the above analysis, policy option R3 appears to deliver the greatest benefits in 
terms of reducing costs associated with the development and maintenance of the funding 
opportunities portal 

122 Including Funding and Tenders portal and YourEurope (source: DG RTD, DG BUDG) 
123 The factor applied to policy option R3 (3) is an assumption based on estimations by Commission services. 
This factor reflects the expected increase of costs for the Commission to develop the necessary IT adaptations 
so that the single portal would integrate Member States portals into an EU-wide system. 

201 

 
 
 
 
 
Under policy options R2 and R3, significant reductions of administrative burden are also 
expected  at  the  level  of  beneficiaries,  which  would  benefit  from  facilitated  access  to 
information on available funding opportunities across EU budget programmes compared 
to  the  current  system  which  requires  navigating  several  portals.  Quantifying  such  a 
reduction of administrative burden was nonetheless not possible due to a lack of available 
data.    

3.  Total costs of policy options on reporting 

Policy option R1  

Policy option R2   

Policy option R3  

Total cost: EUR 70.0 million  Total cost: EUR 16.9 million  Total cost: EUR 32.8 million  

Overall policy option R2 appears to deliver the greatest benefits in terms of reducing 
costs associated with the development and maintenance of the performance dashboard and 
the funding opportunities portal. 

D.  Overview table of costs per policy option and percentage of reduction of 

administrative burden costs 

Policy 
options 

P.  Programming  and 
mainstreaming  

M. Monitoring  

R. Reporting  

1 

2 

3 

P1: EUR 171 million 

M1: EUR 1 401 million 

R1: EUR 70.0 million 

0% 

0% 

0% 

P2: EUR 94 million 

M2: EUR 1 345 million 

R2: EUR 16.9 million 

45% 

4% 

77% 

P3: EUR 151 million 

M3: EUR 911 million 

R3: EUR 32.8 million 

12% 

40% 

57% 

E.  Sensitivity analysis 

The  above  quantitative  analysis  should  be  nuanced  due  to  the  uncertainty  attached  to 
certain assumptions used in the calculation: 

- 

In contrast with impact assessments linked to specific EU budget programmes, where 
impacts  are  typically  predicted  based  on  macro-economic  modelling  (RHOMOLO 
model),  the  quantitative  analysis  of  this  impact  assessment  focuses  on  assessing 
reductions  of  administrative  costs  for  MS  administrations.  The  analysis  particularly 
faced data availability limitations, as quantitative information on administrative burden 

202 

 
 
 
 
 
 
 
linked  to  performance  is  scarce  beyond  the  qualitative  findings  of  e.g.  programmes 
evaluations.  

-  The analysis is based on a combination of data available from studies and estimates by 
Commission  services,  including  reduction  factors  enabling  to  calculate  expected 
reductions  of  administrative  costs  for  each  policy  option.  Any  variations  in  the 
assumptions underpinning such factors is likely to have significant impacts on the costs 
estimated for each policy option. 

-  While  the  quantitative  analysis  focused  on  assessing  reductions  of  costs  for  EU 
institutions and MS authorities, significant reductions of administrative burden are also 
expected  –  from  options  P2,  P3,  M2,  M3,  R2,  R3  –  at  the  level  of  beneficiaries, 
including businesses. Quantifying such reductions was nonetheless not possible due to 
a lack of available data.  

-  The quantitative analysis would also have benefitted from data on the administrative 
costs of monitoring performance in the case of direct and indirect management. These 
shortcomings should be addressed in the future so as to fill the data gap, in particular 
in  the  context  of  new  Commission  priorities  and  the  commitment  to  reduce 
administrative and reporting burden (cf. section 9).  

203