COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a budget expenditure and performance framework and other horizontal rules for 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) 591 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a budget expenditure and performance framework and other horizontal rules for Union programmes and activities {COM(2025) 545 final} - {SEC(2025) 590 final} - {SWD(2025) 590 final}  
 
 
1.  WHAT IS THIS INITIATIVE ABOUT?  

A strong performance framework is essential to deliver on EU policy priorities and adapt to 
evolving  challenges,  while  ensuring  transparency  and  accountability.  It  has  the  potential  to 
enable  a  more  effective  communication  towards  the  Parliament,  Member  States  and 
stakeholders, demonstrating how the EU budget delivers value and improves citizens’ lives. It 
also has potential to contribute to the Commission targets for reducing administrative burden 
by at least 25% for all companies and at least 35% for SMEs. 

The  performance  framework  of  the  EU  budget  refers  to  the  systems  and  tools  designed  to 
ensure  that  spending  delivers  the  intended  results,  and  to  monitor  and  report  on  how 
effectively the EU budget is achieving its objectives.  

The 2024 Financial Regulation introduces requirements that must be taken into account when 
designing the new performance framework. It mandates that all programmes and activities be 
implemented  (where  relevant  and  appropriate)  without  doing  significant  harm  to  the 
environmental objectives and taking into account the principle of gender equality. In addition, 
it requires that indicators be designed to allow for data aggregation, and requires transparency 
about the publication of data on beneficiaries supported by the EU budget. 

The  rules  of  the  2021-2027  performance  framework  create  administrative  burdens  for 
Member  States,  partner  countries  and  EU  institutions,  and  make  it  difficult  for  the 
Commission  to  aggregate  performance  data  at  EU  budget  level,  and  ensure  adequate 
transparency and access to information for budgetary authorities and MFF beneficiaries. The 
draft impact assessment identifies three problems: 

•  Insufficient  flexibility  and  excessive  complexity  of  provisions  on  the  programming 
and  mainstreaming  of  horizontal  priorities:  the  2021-2027  EU  budget  features  a 
fragmented  structure  and  heterogeneous  mainstreaming  requirements  at  MFF  and 
programme  levels.  The  Do  No  Significant  Harm  (DNSH)  principle  is  currently 
inconsistently  applied  across  programmes,  with  multiple  technical  guidelines  creating 
complexity  for  beneficiaries  who  need  to  navigate  heterogeneous  requirements.  While 
progress  has  been  made  in  integrating  gender  equality  in  certain  MFF  programmes, 
gender mainstreaming remains uneven across EU programmes, including  because of the 
absence of a common methodology and objectives.  

•  Inconsistency  and  complexity  of  requirements  on  the  monitoring  of  performance 
information: the EU budget is currently not equipped to effectively monitor, at aggregate 
level,  the  financed  activities,  the  volume  of  expenditure  contributing  to  new  horizontal 
priorities  (e.g.  competitiveness)  and  their  outcomes  across  the  MFF.  This  is  due  to 
differing  monitoring  rules  across  programmes,  which  do  not  allow  to  effectively 
consolidate  and  communicate  the  performance  of  the  EU  budget  to  the  budgetary 
authorities and citizens, nor to effectively inform policy decisions. The current framework 
includes  a  vast  number  of  performance  indicators  and  varying  expenditure  tracking 
methodologies, creating complexity and administrative burden for beneficiaries, Member 
States, implementing partners and EU institutions.  

•  Fragmentation  and  duplication  in  reporting  performance  information  and  funding 
opportunities: there are multiple legal requirements for performance reporting, including 

 
 
 
those  related  to  the  budget  discharge  with  the  Annual  Management  and  Performance 
Report,  the  draft  budget,  and  reporting  requirements  under  more  than  30  programme 
regulations.  This  proliferation  of  reports  results  in  overlapping  content,  risk  of 
inconsistency  and  administrative  burden,  and  makes  it  difficult  to  access  and  present 
information on what the EU budget delivers. In addition, there are more than 15 different 
online  dashboards  presenting  information  on  the  performance  of  programmes,  which 
generates administrative burden and creates confusion as to how the budgetary authorities 
can access information on the performance of the EU budget. At least 10 different portals 
(so-called  one-stop-shops)  display  information  about  available  funding  opportunities 
under  EU  funds,  which  makes  it  difficult  for  beneficiaries  to  identify  suitable  funding 
sources under the EU budget. 

Building  on  the  lessons  of  the  2021-2027  EU  budget,  the  post-2027  MFF  should  reduce 
administrative  burdens  and  improve  accountability  and  transparency  under  a  simplified, 
single performance framework. 

Problem tree: problem drivers, problems and consequences 

Fragmented MFF structure with multiple mainstreaming requirementsatMFF and programme levels e.g.earmarking, conditionality etcPROBLEM DRIVERSPROBLEMSCONSEQUENCESInsufficient flexibilityand excessive complexity of mainstreaming provisions across the EU budgetLimited flexibility to address new and emerging priorities and challenges, and specific MS and sectors needsInconsistency and complexity inmonitoring 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)PROGRAMMINGLimited capacity to measure EU budget impactand inform policiesHigh 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 Reduced transparency and access to informationfor budgetary authorities and MFF beneficiariesREPORTINGComplexity and rigidity of the EU budget performance provisions hamper its capacity to deliver on policy prioritiesFragmentation and duplication in reporting performance information and funding opportunitiesacross the EU budget 
 
 
2.  WHAT IS TO BE ACHIEVED AND WHICH POLICY OPTIONS HAVE BEEN ASSESSED? 

 Intervention logic: problem drivers, general objective, specific objectives and expected results 

The  draft  impact  assessment  identifies  three  policy  options  corresponding  to  possible  levels  of 
harmonization of performance provisions across the three problems identified: 

Policy 
options 

P. Programming and 
mainstreaming 

M. Monitoring 

R. Reporting 

1 

2 

3 

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 and 
differentiated 
operationalisation per 
management mode 

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

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 adopt 
additional programme-
specific performance 
indicators 

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 
single portal per 
management mode or 
sector 

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

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

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 
 
 
across programmes 
(linked to intervention 
fields) 

operationalisation across 
management modes 

3.  WHAT IS THE PREFERRED OPTION AND WHY? 

The table below summarises the comparison of policy options against their ability to achieve 
effectiveness, efficiency and coherence:   

Policy options - 
Programming/
mainstreaming 

Effectiveness 

Efficiency 

Coherence 

Policy options - 
Monitoring 

Effectiveness 

Efficiency 

Coherence 

Policy options - 
Reporting 

Effectiveness 

Efficiency 

Coherence 

Policy option P1 

Policy option P2  

Policy option P3 

(=) 

(=) 

(=) 

(+++) 

(+++) 

(+++) 

(++) 

(+) 

(+) 

Policy option M1 

Policy option M2 

Policy option M3 

(=) 

(=) 

(=) 

(+) 

(+) 

(+) 

(+++) 

(+++) 

(+++) 

Policy option R1 

Policy option R2 

Policy option R3 

(=) 

(=) 

(=) 

(+++) 

(+++) 

(++) 

(++) 

(+) 

(+++) 

The preferred combination of policy options is  P2+M3+R2. This combination would enable 
to  effectively  deliver  against  horizontal  EU  policy  objectives  and  principles  such  as  DNSH 
and  gender  equality,  yet  foreseeing  calibrated  and  proportionate  implementation  of  DNSH, 
enabling  to  comply  with  the  requirement  of  the  Financial  regulation  to  implement  DNSH 
where feasible and appropriate, while reducing administrative burden and costs for Member 
States,  implementing partners and beneficiaries.  This  combination also  enables a significant 
upgrade of the monitoring of the performance of the EU budget by enabling the 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. 

The most appropriate vehicle to operationalize this preferred combination of options appears 
to be the development of a single performance framework through a single legal act. Such a 
performance  regulation  would  enable  to  centralize  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 a technical 
guidance  setting  DNSH  criteria  for  relevant  intervention  fields),  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, replacing  e.g. the 

 
 
 
several  lists  of  intervention  fields  and  performance  indicators  currently  attached  to  e.g.  the 
Common Provisions Regulation, the RRF regulation and other programmes’ legal bases. 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  for  Member  States, 
implementing partners, partner countries, beneficiaries and EU institutions.  

While  the  proposed  regulation  does  not  correspond  to  a  revision  of  existing  legislation  in  a 
strict  sense,  the  preferred  policy  option  is  fully  in  line  with  the  REFIT  objectives  of 
simplification  and  reduction  of  red  tape.  The  initiative  is  expected  to  result  in  a  significant 
reduction  of  administrative  burden  and  improved  efficiency  expected  from  the  preferred 
combination  of  options  enabling  to  achieve  a  significant  reduction  of  regulatory  costs.  The 
significant decrease in the number of performance indicators and the establishment of a single 
information  and  funding  opportunities  significantly  reduces 
portal  for  performance 
administrative  burdens,  which  directly  addresses  REFIT’s  objective  of  cutting  red  tape  and 
lowering costs for stakeholders, thus encouraging broader participation and engagement. By 
tailoring  DNSH  implementation  requirements  to  be  both  effective  and  reasonable,  the 
preferred  combination  of  options  ensures  that  policy  measures  are  proportionate  to  their 
desired impact. This approach aligns with REFIT’s emphasis on effectiveness and efficiency, 
and increases the likelihood of successful compliance by beneficiaries. 

4.  WHAT ARE THE IMPACTS OF THE PREFERRED OPTION? 

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

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 

Amount 

Direct benefits 

EUR 85,5 million 

Comments 

Member States administrations at all levels 
(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) 

EUR 700,6 million  Member State administrations at all levels 

M3: Reduction of administrative burden as a 
result of simplifying 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. 

(reduction of administrative burden linked to 
operationalization tasks 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) 

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

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) 

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

EUR 24,6 million 

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

EUR 32 million 

 
 
II. Overview of costs – Preferred option 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

P2: 
activity-
based 
approach 
to DNSH 

M3: 
single 
expenditur
e  tracking 
and 
indicator 
monitorin
g 

R2: Single 
performan
ce portal 

R2: Single 
portal  on 
funding 
opportunit
ies 

Direct 
administrative 
costs 

Could not be costed due to lack of available data 

Could not be costed due to lack of available data 

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 

EUR 1,3 
million 

EUR 3 
million 

Combination  P2+M3+R2  is  expected  to  achieve  ca.  EUR  623  Mio  of  administrative  costs 
savings  for  Member  States  administration  and  the  Commission  compared  to  the  baseline 
scenario.  This  corresponds  to  a  strong  underestimation  of  expected  cost  savings,  since  –  as 
indicated under section 7 – the quantitative analysis of the impacts of policy options did not 
quantify  further  impacts  due  to  a  lack  of  data.  However  significant  reductions  of 
administrative and reporting burdens are also expected at the level of EU budget beneficiaries, 
such  as  businesses,  enabling  to  support  the  competitiveness  of  the  sectors  supported  by  EU 
budget programmes. 

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% (1). 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 

(1)  In line with Communication target of reducing burdens associated with reporting requirements by 25% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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,  as  EU 
companies  would  be  facing  less  administrative  burden  associated  with  mainstreaming, 
monitoring  and  reporting  provisions,  improving  their  position  vis-à-vis  third  countries 
enterprises.  

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  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 
(Achieve  gender  equality  and  empower  all  women  and  girls),  13  (Take  urgent  action  to 
combat climate change and its impacts) and 15 (Protect, restore and promote sustainable use 
of  terrestrial  ecosystems,  sustainably  manage  forests,  combat  desertification,  and  halt  and 
reverse land degradation and halt biodiversity loss).  

5.  MEASURING SUCCESS?  

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.  As  a  mitigation 
measure, the regulation should 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 post-2027 budget.  

•  The  Commission  study  on  assessing  the  administrative  costs  and  administrative 
burden  in  the  management  of  the  Common  Provisions  Regulation  funds  (2018  and 
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,  in  particular  for  Member  States  authorities.  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): 

o  relevance  of  new  single  list  of  intervention  fields  and  indicators  in  view  of 

performance monitoring; 

o  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, as well as costs of access to information of EU budget performance 
and  funding  opportunities,  including  by  beneficiaries,  budgetary  authorities, 
implementing partners, partner countries and EU institutions.