COMMISSION STAFF WORKING DOCUMENT EVALUATION Mid-term Evaluation of the Instrument for Financial Support for Border Management and Visa Policy (BMVI) 2021-2027
Date: 2025-09-16
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, Schengen Agreement, border control, external border of the EU, fund (EU)

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.9.2025  SWD(2025) 272 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Mid-term Evaluation of the Instrument for Financial Support for Border Management and Visa Policy (BMVI) 2021-2027 {SEC(2025) 253 final} - {SWD(2025) 273 final}  
 
 
CONTENTS 

ABBREVIATIONS ................................................................................................. 2 

1. 

Introduction ..................................................................................................... 1 

2.  What was the expected outcome of the intervention? ..................................... 5 

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

2.2.  Points of Comparison ............................................................................ 8 

3.  How has the situation evolved over the evaluation period ............................ 11 

3.1.  Evolution of the policy context ........................................................... 11 

3.2.  Description of the Implementation Set-up .......................................... 12 

3.3.  BMVI Implementation - Financial Progress ....................................... 15 

4.  Evaluation findings ........................................................................................ 19 

4.1.  To what extent was the intervention successful and why? .................. 19 

4.1.1.  Effectiveness .......................................................................... 19 

4.1.2.  Efficiency .............................................................................. 32 

4.1.3.  Coherence .............................................................................. 44 

4.2.  How did the EU intervention made a difference and to whom? ... 63 

4.3. 

Is the intervention still relevant? ......................................................... 65 

5.  What are the conclusions and lessons learned? ............................................. 69 

5.1.  Conclusions ......................................................................................... 69 

5.2.  Lessons learned ................................................................................... 74 

ANNEX I: PROCEDURAL INFORMATION ..................................................... 76 

ANNEX II: METHODOLOGY AND ANALYTICAL MODELS USED ........... 81 

Methodology ................................................................................................. 81 

Output and result indicators defined in Annex VIII of the BMVI regulation
 ............................................................................................................. 82 

Limitations and mitigation measures ............................................................ 86 

ANNEX III: EVALUATION MATRIX ............................................................... 87 

ANNEX IV: OVERVIEW OF BENEFITS AND COSTS ................................. 100 

ANNEX V: STAKEHOLDER CONSULTATION – SYNOPSIS REPORT ..... 107 

 
 
 
 
 
 
ABBREVIATIONS 

AMIF 

BMVI 

CCEI 

CDP 

CPR 

Asylum, Migration and Integration Fund 

Instrument for Financial Support for Border Management and Visa 

Customs Control Equipment Instrument 

Border and Coast Guard Capability Development Plan 

Common Provisions Regulation (Regulation (EU) 2021/1060) 

EBCG 

European Border and Coast Guard 

ECA 

EES 

EIBM 

EMAS 

EBF 

ECA 

ERDF 

ESF+ 

ESIF 

European Court of Auditors 

Entry-Exit System 

European Integrated Border Management 

Emergency Assistance 

External Borders Fund (2007-2013) 

European Court of Auditors 

European Regional Development Fund 

European Social Fund Plus (2021-2027) 

European Structural and Investment Funds 

eu-LISA 

European Union Agency for the Operational Management of Large-
Scale IT Systems in the Area of Freedom, Security and Justice 

FRONTEX 

European Border and Coast Guard Agency 

HEC 

Horizontal Enabling Conditions (art. 15 CPR) 

ICMPD 

International Centre for Migration Policy Development 

IPA 

ISF 

ISF-BV 

Instrument for Pre-accession assistance 

Internal Security Fund (2021-2027) 

Instrument for financial support for external borders and visa for the 
period 2014-2020 

MOCADEM 

Operational Coordination Mechanism for the External Dimension of 
Migration 

MPF 

Migration Partnership Facility 

 
 
NDICI 

Neighbourhood,  Development  and 
Instrument 

International  Cooperation 

OLAF 

European Anti-Fraud Office 

RRF 

SA 

SACs 

SFC 

SWD 

TFEU 

TSI 

UA 

VIS 

Recovery and Resilience Facility 

Specific Action(s) 

Schengen  Associated  Countries  (Iceland,  Liechtenstein,  Norway, 
Switzerland) 

IT System for Fund Management in the European Union 

Staff Working Document of the Commission services 

Treaty on the Functioning of the European Union 

Technical Support Instrument 

Union Action(s) 

Visa Information System 

 
 
 
1. 

INTRODUCTION 

Regulation (EU) 2021/1148 (henceforward, “the BMVI Regulation”) established, as part 
of  the  Integrated  Border  Management  Fund,  the  Instrument  for  Financial  Support  for 
Border Management and Visa Policy (henceforward the “BMVI” or “the Instrument”) (1) 
for the 2021-2027 programming period. 

The  BMVI  is  established  for  the  period  from  1  January  2021  to  31  December  2027.  It 
applies to 25 EU Member States (all except Ireland) (2) and 4 non-EU countries (Iceland, 
Liechtenstein,  Norway  and  Switzerland,  the  so-called  Schengen  Associated  Countries 
(SACs). Denmark was excepted at in principle (3) but chose to implement the BMVI and 
be bound by it, pursuant to Article 4 of Protocol 22. 

The BMVI is one of the three Home Affairs Funds for the period 2021-2027, together with 
the Asylum, Migration and Integration Fund (AMIF) (4) and the Internal  Security Fund 
(ISF) (5). 

It builds on the results and investments of its predecessors, External Borders Fund (EBF) 
for  the  2007-2013  period  -  (6)  and  the  2014-2020  Instrument  for  financial  support  for 
external borders and visa as part of the Internal Security Fund for the 2014-2020 period 
(ISF-BV) (7). 

According to Article 3(1) of BMVI Regulation, the policy objective of the Fund is to ensure 
effective European integrated border management at the external borders policy, thereby 
contributing  to  ensuring  a  high  level  of  internal  security  within  the  Union,  while  
safeguarding the free movement of persons within it and fully respecting the Union acquis 
and  the  international  obligations  of  the  Union  and  the  Member  States  arising  from  the 
international  instruments  to  which  they  are  party.  Withing  this  policy  objective,  in 
accordance  with  Article  3(2)  of  BMVI  Regulation,  it  shall  contribute  to  the  specific 
objectives  of  (a)  supporting  effective  European  integrated  border  management  at  the 
external borders, to facilitate legitimate external  border crossings, to  prevent and detect 
illegal immigration and cross-border crime and to effectively manage  migratory flows; (b) 
supporting the common visa policy to ensure  a harmonised approach with regard to the 
issuance of visas and to facilitate legitimate travel, while helping to prevent migratory and 
security risks.  

(1)  Regulation (EU) 2021/1148 of the European Parliament and of the Council of 7 July 2021 establishing, 
as  part  of  the  Integrated  Border  Management  Fund,  the  Instrument for  Financial  Support  for  Border 
Management and Visa Policy 

(2)  Protocol (No 19) on the Schengen acquis integrated into the framework of the European Union 
(3)  Article 1 and Article 2 of Protocol (No 22) on the position of Denmark 
(4)  Regulation (EU) 2021/1147 of the European Parliament and of the Council of 7 July 2021 establishing 

the Asylum, Migration and Integration Fund. 

(5)  Regulation (EU) 2021/1147 of the European Parliament and of the Council of 7 July 2021 establishing 

the Asylum, Migration and Integration Fund. 

(6)  Decision of the European Parliament and the Council No 574/2007/EC establishing the External Borders 
Fund for the period 2007 to 2013 as part of the General programme ‘Solidarity and Management of 
Migration Flows’ 

(7)  Regulation  (EU)  No  515/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014 
establishing,  as  part  of  the  Internal  Security  Fund,  the  Instrument  for  financial  support  for  external 
borders and visa and repealing Decision No 574/2007/EC 

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BMVI  (currently  EUR  7.7  billion)  provides  support  to  achieve  its  objectives  and  is 
implemented under shared, direct and indirect management modes.  

Purpose and scope of the Evaluation 

This Staff Working Document (SWD) presents the results of the evaluation of the initial 
implementation of the BMVI (hereafter “the Evaluation”).  

According  to  Article  28(1)  of  the  BMVI  Regulation,  by  31 December  2024,  the 
Commission should carry out a mid-term evaluation of the Instrument to assess:  

(a)  its  effectiveness,  including  the  progress  made  towards  the  achievement  of  its 

objectives; 

(b) the efficiency of the use of resources allocated to the instrument and the efficiency 

of the management and control measures put in place to implement it; 

(c)  the continued relevance and appropriateness of the implementation measures  set 

out in the Regulation; 

(d) the coordination, coherence and complementarity between the actions supported 

under the Instrument and support provided by other Union funds; 

(e)  the Union added value of actions implemented under the Instrument. 

Given the early stage of implementation of the Member States BMVI programmes, which 
were only approved end of 2022, the mid-term evaluation is particularly focused on the 
identification  of  issues  which  may  affect  the  implementation  of  the  Instrument,  and  on 
ways to reassess the BMVI programmes, if necessary. For this reason, while addressing 
the  main  evaluation  criteria  of  relevance,  effectiveness,  efficiency,  coherence,  and  EU 
added value, the Evaluation aims less at obtaining final conclusions on the effectiveness 
and efficiency of the programmes, than at obtaining evidence-based information on:  

-  Whether the Instrument is addressing the needs it was meant to address, and the 
impact that new challenges and developments in the policy area have had on the 
continued relevance of the Instrument; 

-  Whether the Member State programmes and the Commission work programmes 
for the BMVI Thematic Facility are fit for purpose and coherent with other national 
and EU funding instruments, and whether improvements should be introduced; 

-  Whether  the  interventions  are  on  track  to  achieving  the  stated  objectives,  at  a 
reasonable cost, and which possible corrections may be introduced during the rest 
of the implementation of the interventions. 

The Evaluation is based on thirteen questions, organised as per five criteria (8), as follows:  

Relevance 

•  To what extent does the Instrument address the evolving needs? 

(8)  The evaluation questions are developed in Annex III (Evaluation matrix). 

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•  To what extent can the Instrument adapt to the evolving needs? 

Effectiveness 

•  To what extent is the Instrument on track to achieving its objectives? 

•  To what extent is the monitoring and evaluation framework suitable to inform on 

the progress towards the achievement of the objectives of the Instrument? 

•  How was the involvement of the relevant partners ensured across all stages of the 

programming implementation, monitoring and evaluation? 

•  To what extent does the Instrument respect or promote in its implementation the 

horizontal principles? 

•  To what extent is the Instrument effective in communicating and disseminating on 

its opportunities as well as achievements? 

Efficiency 

•  To what extent does the Instrument support cost-effective measures? 

•  To what extent is the management and control system efficient? 

•  To what extent is further simplification achievable? How? 

Coherence 

•  To what extent is the Instrument coherent with initiatives supported under its policy 
domain, in particular with support under the BMVI Thematic Facility across the 
different management modes? 

•  To what  extent is  the  Instrument coherent  with  other EU funds (including other 

Home Affairs Funds) and in particular with EU’s external action? 

EU Added Value 

•  To what extent is the Instrument generating EU added value? 

The information used for the Evaluation cover the period from 1 January 2021 (the date 
when  the  BMVI  Regulation  become  applicable),  to  end  of  June  2024,  except  where 
otherwise indicated.  

The geographical scope includes all countries to which the BMVI Regulation applies, i.e., 
all  Member  States  except  Ireland,  as  well  as  the  four  Schengen  Associated  Countries 
(henceforward “SACs”): Norway, Switzerland, Iceland and Liechtenstein. 

Following  the  requirements  in  the  BMVI  Regulation (9),  the  Evaluation  is  based  on 
evidence obtained from several sources, including: 

(9)  Article 28. 

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- 

- 

- 

- 

the output and result indicators defined in Annex VIII to the BMVI Regulation, 
which are regularly reported to the Commission by the Managing Authorities, 

the  BMVI  annual  performance  reports  submitted  every  year,  since  2023,  by  the 
Member State Managing Authorities for the BMVI programmes, 

the BMVI mid-term evaluations done by the Member States by 31 March 2024, 
the  Common  Provisions  Regulation (10) 
according 
(henceforward, “the CPR”), 

to  Article  44(5)  of 

the  impact  assessment  accompanying  the  2021-2027  Home  Affairs  Funds 
Regulations proposals, including the BMVI (11), 

-  other  studies,  sources  and  reports,  such  as  reports  following  BMVI  funding 
allocated under direct and indirect management, and from the European Court of 
Auditors, which provided useful information for the evaluation. 

As  the  Commission  was  also  requested  to  provide  an  ex-post  evaluation  report  of  the 
Instrument for financial support for external borders and visa (henceforward, the ISF-BV) 
for  the  period  2014-2020 (12)  by  June  2025,  the  Commission  decided  to  carry-out  both 
evaluations  of  ISF-BV  (ex-post)  and  BMVI  (mid-term)  simultaneously,  in  order  to 
facilitate the exchange of information and the use of common findings and analysis.  

The preparatory work for this Evaluation was confided to an external consortium led by 
EY  France  and  it  was  carried  out  in  the  timeframe  February  -  December  2024.  The 
methodology applied started with a comprehensive analysis of initial and emerging needs. 
The study used: qualitative and quantitative methods, including desk review of EU and 
national  documents,  EU-level  interviews  with  various  stakeholders,  such  as  European 
Commission’s  officials,  implementing  partners  and  beneficiaries,  as  well  as  surveys.  It 
included  data  analysis  covering  country  focused  and  thematic  case  studies.  The  data 
collected  were  triangulated  to  validate  consistency  across  sources  and  provide  well-
founded insights and responses to the evaluation questions. 

Limitations 

The data collection and analysis processes faced several limitations which have an impact 
on the mid-term evaluation of BMVI, notably:  

• 

Inconsistent  data  quality  and  availability (13)  across  Member  States  hindered 
comparisons;  

(10)  Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021 laying down 
common provisions on the European Regional Development Fund, the European Social Fund Plus, the 
Cohesion Fund, the Just Transition Fund and the European Maritime, Fisheries and Aquaculture Fund 
and financial rules for those and for the Asylum, Migration and Integration Fund, the Internal Security 
Fund and the Instrument for Financial Support for Border Management and Visa Policy. 

(11)  SWD(2018) 347 final 
(12)  Article 21(6) of Regulation (EU) No 515/2014 of the European Parliament and of the Council of 16 
April 2014 establishing, as part of the Internal Security Fund, the  Instrument for financial support for 
external borders and visa and repealing Decision No 574/2007/EC. 

(13)  The  reduced  availability  of  data  was  due  partially  to  the  early  implementation  stage  of  BMVI 
programmes  of  Member  States  upon  their  approval,  as  well  as  to  the  specificities  of  certain  border 

4 

 
 
 
 
•  Historical data was often incomplete, and some data errors in the IT System for 

Fund Management in the European Union (SFC) added to the challenges; 

•  Variations  in  data  granularity  and  maturity  of  BMVI  programmes,  as  Member 

States were at different stages of BMVI Regulation implementation; 

•  Difficulty of stakeholders distinguishing BMVI data from the predecessor 2014-

2020 ISF-BV data; 

•  Low response rates in the surveys;  

•  Additionally,  due  to  conceptual  issues  with  certain  common  output  and  result 
BMVI  indicators  it  was  difficult  to  accurately  measure  the  BMVI  programmes’ 
progress achieved so far.  

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.  Description of the intervention and its objectives 

The  European  Union  (hereafter  “the  EU”  or  “the  Union)  has  a  key  role  to  play  in  the 
development of an integrated management system and a common visa policy to secure the 
external borders from any unauthorised crossings, also by providing support to the Member 
States for checks on persons and efficient external borders surveillance, while preserving 
the Schengen Area and the free movement of persons within the Union.     

As concluded in the impact assessment (14) that accompanied the legislative proposals for 
the three 2021-2027 Home Affairs Funds Regulations (15), during the implementation of 
the previous generation of funds, there had been a number of crises that deeply affected 
the fields of migration, border management and security. Member States’ resources and 
capabilities  for  border  management  and  visa  were  put  under  pressure  due  to  the 
considerably  increased  migratory  challenges,  irregular  border  crossings  and  visa 
applications, as compared to the previous years. At the same time, according to the impact 
assessment, security concerns and climate change would continue to act as catalysts of the 
identified  large-scale,  cross-sectoral  and  cross-border  challenges  EU  and  its  Member 
States  face.  In  the  case  of  border  management  particularly,  the  need  to  protect  the 
functioning of the Schengen Area required a reinforced and comprehensive response to the 
management of Union’s external borders. 

The BMVI impact assessment concluded that the objectives of the Instrument should be 
“based  on  the  scope  of  ISF-BV,  which  is  considered  sufficiently  broad  to  support  the 
implementation  of  Union  policy  priorities,  providing  EU  added  value.”  Therefore,  the 
BMVI aligns with the objectives of the ISF-BV (16).  

management activities, whose completion requires longer periods than 3.5 years (e.g. the procurement 
of high quality, standardized, large-scale border surveillance equipment, the development of large-scale 
IT systems across EU and BMVI countries, etc.) 

(14)  SWD(2018) 347 final. 
(15)  The  Asylum,  Migration  and  Integration  Fund  (AMIF),  the  Integrated  Border  Management  Fund 
(including the BMVI and the Customs Control Equipment Instrument (CCEI)) and the Internal Security 
Fund (ISF). 

(16)  See the Article 3 of the ISF BV and BMVI Regulations. 

5 

 
 
 
The policy objective of the BMVI is “to ensure strong and effective European integrated 
border management at the external borders, thereby contributing to ensuring a high level 
of internal security within the Union, while safeguarding the free movement of persons 
within it and fully respecting the relevant Union acquis and the international obligations 
of the Union and the Member States arising from the international instruments to which 
they are party.” To this end, two specific objectives were defined, mirroring those for the 
ISF-BV: 

Specific  Objective  1  (SO1):  supporting  effective  European  integrated  border 
management at the external borders, implemented by the European Border and Coast 
Guard as a shared responsibility of the European Border and Coast Guard Agency 
and  the  national  authorities  responsible  for  border  management,  to  facilitate 
legitimate  border  crossings,  to  prevent  and  detect  illegal  immigration  and  cross-
border crime and to effectively manage migratory flows;  

Specific  Objective  2  (SO2):  supporting  the  common  visa  policy  to  ensure  a 
harmonised approach with regard to the issuance of visas and to facilitate legitimate 
travel, while helping to prevent migratory and security risks. 

To address the needs described above, the BMVI intervention was developed as follows 
(the complete intervention logic, presented as a diagram, is included in Annex II):  

Operational objectives: The operational objectives of SO1 focus on the implementation 
and improvement of the European integrated border management at the external borders; 
the development of the European Border Coast Guard and cooperation of Frontex agency 
with  Member  States;  the  enhancement  of  inter-agency  cooperation  at  national,  EU  and 
international  levels;  increasing  available  capacities  and  capabilities,  also  by  means  of 
innovative  solutions,  based  on  new  technologies;  and  support  to  search  and  rescue 
operations in situations that might rise during border surveillance operations at sea. The 
operational  objectives  for  SO2  are  to  enhance  efficient,  secure  and  client-friendly  visa 
services;  support  Member  States  in  issuing  visas;  and  enhance  consular  cooperation 
between Member States. In addition, the development and enhancement of relevant ICT 
systems, including of large-scale IT systems and the interoperability architecture for home 
affairs, as well as of the related infrastructure and equipment, are applicable to both BMVI 
specific objectives.  

Activities: To achieve the operational objectives, the activities supported by the Instrument 
include,  but  are  not  limited  to,  supporting  the  development  and  maintenance  of 
of 
IT/communication 
equipment, organisation of trainings, exchange of best practices, deployment of experts, 
communication activities, and operating support (17).  

infrastructure, 

development 

purchase 

systems, 

of 

Outputs: The immediate outputs of such activities include, but are not limited to: upgraded 
or new facilities for border crossing points at external borders, new equipment to carry out 
border management activities, new/upgraded/maintained ICT systems, the deployment of 
immigration liaison officers in third countries to combat illegal immigration to EU, support 
to  border  management  personnel  and  to  staff  deployed  to  Member  States  consulates  in 

(17)  ‘Operating support’ means a part (up to 33 % of the amount allocated to a Member State’s programme) 
which  may  be  used  as  support  to  the  public  authorities  responsible  for  carrying  out  the  tasks  and 
providing the services which constitute a public service for the Union (Art. 2(9) BMVI Regulation). 

6 

 
 
 
third countries, the set up and running of hotspots in areas with high migratory pressure, 
cooperation projects with third countries, as well as the digitalisation of visa processing.  

Results:  The  expected  results  include  an  integrated  management  of  the  EU  external 
borders, enhanced capacity of the European Border and Coast Guard as a whole, enhanced 
inter-agency cooperation between authorities responsible for border control and other tasks 
carried  out  at  the  external  borders  (such  as,  customs  control,  return  of  third  country 
nationals, compliance with fundamental rights, multipurpose maritime operations, sanitary 
control  measures,  etc.),  ICT  systems  run  smoothly,  infrastructure  built,  upgraded  or 
maintained,  facilitation  of  legitimate  travel  and  improved  cooperation  among  Member 
States  for  visa  processing,  overall  progress  towards  uniform  application  of  the  Union’s 
acquis on borders and visa.     

Impact: The BMVI aims to leave a lasting impact by contributing to effective integrated 
management  of  the  Union’s  external  borders,  thereby  contributing  to  a  high  level  of 
internal security and supporting the free movement of persons within it.   

To address the need for additional flexibility in dealing with critical situations, such as the 
2015 refugee  crisis,  and  in  line with  the two other Home Affairs funds,  the  Instrument 
included a Thematic Facility “to adapt the allocation of funding to changes in priorities for 
visa policy and border management, including changes that result from increased pressure 
at the border, and a need to steer funding towards the priorities with the highest Union 
added value” (18). The three pre-existing fund components under ISF-BV of Emergency 
Assistance  (“EMAS”),  Unions  Actions  (“UA”)  and  Specific  Actions  (“SA”),  were 
regrouped  under  the  BMVI  Thematic  Facility,  enabling  the  Commission  with  the 
necessary flexibility in the management of the BMVI to address the Union priorities, key 
actions with high EU added value and to respond to urgent needs (e.g. to prevent and detect 
cross-border crime at the external borders, in particular migrant smuggling and trafficking 
in human beings, to manage migratory flows, etc) (19). 

To  further  develop  a  coordinated  and  harmonised  implementation  of  Union  Funds 
implemented under shared management (20), the BMVI, as well as the AMIF and the ISF, 
were subject from 2021 to the general provisions for shared management funding defined 
by  the  Common  Provisions  Regulation (21)  (henceforward,  “the  CPR”).  This  shift 
addressed both the challenge of enhancing coherence and synergies with other EU funds, 
introducing  flexibility  and  simplification  in  the  financial  aspects  and  led  the  way  to  a 
reinforced focus on performance, with a more regular reporting on outputs and results, and 
the promotion of performance-based tools, such as financing not linked to costs. 

The BMVI objectives were translated into a series of implementation measures and fields 
of intervention (22), linked to specific Member States and SACs reporting obligations on 
their BMVI programmes under shared management. Reinforced reporting shows a strong 

(18)  Recital 46, BMVI Regulation. 
(19)  Article 8(1) BMVI Regulation. 
(20)  Recital 2 of the CPR Regulation. 
(21)  Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021 laying down 
common provisions on the European Regional Development Fund, the European Social Fund Plus, the 
Cohesion Fund, the Just Transition Fund and the European Maritime, Fisheries and Aquaculture Fund 
and financial rules for those and for the Asylum, Migration and Integration Fund, the Internal Security 
Fund and the Instrument for Financial Support for Border Management and Visa Policy. 

(22)  Annex III and VI BMVI. 

7 

 
 
 
commitment  on  financial  and  performance  monitoring,  and  an  effort  towards  external 
transparency through the publication of data in the Open Data Platform of the Commission. 

2.2. 

Points of Comparison  

EU funding for border management and visa policy has developed over several funding 
periods, following the EU strategies and policy developments for border management and 
visa policy, with a high level of continuity. Given this, and the early stage of delivery, it is 
hard to delineate where results from one funding period begin and end, as there are also 
differences across Member States and external factors that contributed to progress (or to 
the  lack  thereof  on  some  aspects).  As  such,  it  is  useful  to  highlight  the main  structural 
differences between the BMVI and ISF-BV, starting with the allocation of funds. This is 
complemented  by  the  different  elements  for  assessing  the  performance  of  the  BMVI 
against  its  predecessor  instrument  ISF-BV,  and  other  points  of  comparison  (i.e. 
comparative progress across Member States, impact of external factors and comparisons 
with similar EU funds).  

The challenges identified by the previous impact assessment 

For the post 2020 period, four main challenges, applicable to all Home Affairs Funds, were 
identified by the impact assessment: 

1.  Enhancing flexibility within a stable framework 

2.  Further simplifying the rules for implementing EU Funds 

3.  Ensuring more coherence and synergies between actions supported by EU funding 

instruments 

4.  Achieving the highest level of EU added value with a focus on performance 

The extent to which these challenges have been addressed is assessed in the sections on 
findings and conclusions. 

Comparison with 2014-2020 ISF-BV  

Possibly the most obvious point of comparison is the performance of the BMVI compared 
to ISF BV - although due note must be taken of the differences between the two in terms 
of resources allocation decisions and delivery before arriving at conclusions.   

Increased funding for BMVI compared to ISF-BV 

BMVI benefits from a significantly larger financial envelope compared to its predecessor. 
With a total initial EU contribution of EUR 6.4 billion (23) for the 2021-2027 programming 
period, which has increased since 2021 to EUR 7.7 billion (24), the level of funding is more 
than two-and-a-half times larger than the total budget of the predecessor programme ISF-

(23)  According to Article 7 of the BMVI Regulation, the financial envelope for BMVI 2021-2027 is EUR 
5,241,000,000 in current prices. This amount is increased by an additional allocation, as provided for in 
Article 5 and Annex II of Regulation (EU, Euratom) 2020/2093. 

(24)  The amount includes the additional allocation, as provided for in Article 5 and Annex II of Regulation 
(EU, Euratom) 2020/2093, the transfers Article 26 of the CPR, all transfers to and from Agencies as 
well as the additional amounts received in the context of the Budget Procedure. 

8 

 
 
 
 
BV over its seven years of implementation (25). This is meant to allowin for expanded and 
more comprehensive support to the Member States and Schengen Associated Countries. 
In the Evaluation, this increased funding is assessed against the scale of border security 
and migration challenges faced by the EU during the evaluation period. The comparison 
assesses whether the additional resources have been effectively allocated to address new 
challenges, such as technological advancements in border security, as well as increased 
migration pressures, while identifying areas where resource allocation may still be uneven 
across Member States. 

Legal framework 

A significant point of comparison is the shift in the legal framework governing the BMVI, 
particularly regarding the payment of expenditures incurred by the Member States under 
shared management, and the fact that it is governed by the Common Provisions Regulation 
(26), which means – among others – a new framework for monitoring the performance in 
the implementation of the Member States programmes. Under the ISF BV, reimbursement 
of expenses was the primary method of funding, with one yearly payment application per 
Member  State  programme.  The  BMVI  introduced  a  more  flexible  system  of  payments, 
allowing for pre-financing and advance payments, notably up to six payment applications 
of Member States per programme, thus accelerating the disbursement of funds and easing 
the administrative burden on Member States. This study assesses the extent to which these 
structural  changes  have  improved  financial  management  and  implementation  efficiency 
across the Member States BMVI programmes, particularly for EU external borders under 
high-pressure, e.g. due to with large migration flows (see, in particular, the assessment of 
efficiency). 

The performance framework 

The  new  legal  framework  also  entailed  a  refocus  on  performance.  The  reporting  and 
monitoring framework was reinforced with the introduction of the requirement for Member 
States  to  establish  a  performance  framework  pursuant  to  Article  16  CPR,  to  allow 
monitoring  and  evaluating  of  programme  performance  during  implementation  of  the 
programme,  and  to  contribute  to  measuring  the  overall  performance  of  the  Funds.  The 
performance framework consists of (a) output and result indicators (b) milestones to be 
achieved by the end of year 2024 for output indicators and (c) targets to be achieved by the 
end of the year 2029 for output and result indicators. Targets and milestones (27), also allow 
the Commission and the Member States to measure progress towards the achievement of 
the  specific  objective (28).  Pursuant  to  the  BMVI  Regulation (29),  common  output  and 
result indicators to report the progress of the Instrument towards the achievement of the 
specific objectives set out in the Regulation, are laid down in Annex VIII of the BMVI 
Regulation.  The  baseline  for  output  indicators  was  set  at  zero  at  the  beginning  of  the 

(25)  ISF BV initial EU financial envelope  was EUR 2.760 billion, out of which the allocation to Member 
States  and  SACs  programmes  was  EUR 1.276  billion.  As  per  January  2025 data,  the  EU  budget for 
ISF BV was ultimately EUR 2.904 billion in total, out of which EUR 2.420 billion for Member States 
and SACs ISF BV programmes. 

(26) Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021 laying down 
common provisions on the European Regional Development Fund, the European Social Fund Plus, the 
Cohesion Fund, the Just Transition Fund and the European Maritime, Fisheries and Aquaculture Fund 
and financial rules for those and for the Asylum, Migration and Integration Fund, the Internal Security 
Fund and the Instrument for Financial Support for Border Management and Visa Policy 

(27)  As defined in Article 2(11) and (12) of the CPR, respectively 
(28) Article 16(3) of the CPR 
(29)  Article 27(3). 

9 

 
 
 
programming period; The result indicators concerning the operations funded were also set 
as zero as they were linked to the output indicators. (30). 

The definition of targets belongs the Member States in the light of the strategy translated 
into the programme. They explain in their programmes the methodology used for target-
setting. Member States defined them on the basis of their own needs and strategic priorities, 
and  not  as  a  contribution  to  an  overall  EU  target.  Both  output  and  result  indicators  are 
linked to the implementation of interventions. This practice is in line with the one in other 
CPR  regulated  funding  and  allows  for  a  close  monitoring  of  the  implementation  and 
performance of the programmes. In order to ensure homogenous reporting and facilitate 
aggregation at EU level, even before the negotiation on the Member State programmes, 
the  Commission  provided  the  Member  States  with  a  metadata  set,  with  a  standardised 
definition of each indicator in the performance framework. This will allow to aggregate 
targets  and  results at  EU level  in  order to  assess  overall progress  when it comes to  the 
retrospective evaluation. 

This approach does not allow to compare progress in indicators with the evaluation and 
performance framework defined for the previous period, which was based on a different 
set of indicators and different performance setting.  

A Thematic Facility responding promptly to challenges at EU external borders 

The BMVI Thematic Facility is meant to offer greater flexibility compared to ISF-BV (31) 
and a more dynamic allocation of funding. While assessing the internal coherence of the 
BMVI  (including  its  Thematic  Facility),  the  Evaluation  examines  how  effectively  this 
Facility has been used to address unexpected crises, such as the rapid increase in migration 
flows,  or  the  need  for  urgent  infrastructure  upgrades  at  border  crossings  points,  and 
whether  it  has  contributed  to  more  equitable  and  strategic  resource  distribution  among 
Member States (see assessment of relevance, effectiveness, and internal coherence). 

Comparative Progress Across Member States 

Given the shared responsibility of Member States in implementing the BMVI, comparisons 
were drawn between different countries' implementation rates. Countries with significant 
external borders (e.g., Greece, Italy, Spain) were assessed against those with less exposure 
to migration pressures, to determine if resources and efforts have been effectively allocated 
in proportion to their needs. Section 3 evaluates disparities in Member States programmes 
delivery,  such  as  delays  or  accelerated  progress  in  border  management  and  visa  policy 
reforms,  identifying  patterns  of  implementation  success  or  obstacles  across  various 
regions. 

(30) Article 27(3) of the BMVI Regulation. Four of the indicators cannot be directly linked to the projects 
and are derived from general national statistics,  these indicators are: O.1.13. Number of persons who 
have applied for international protection at border crossing points; R.1.17. Number of border crossings 
through  automated  border  control  systems  and  e-gates;  R.1.20.  Number  of  persons  refused  entry by 
border authorities; and O.2.1. Number of visa applications using digital means. 

(31) The possibility to provide for emergency assistance under all management modes under BMVI, including 
shared management, for instance, compared to emergency assistance provided under direct management 
only under ISF BV  

10 

 
 
 
3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD 

3.1.  Evolution of the policy context 

The initial implementation of the Instrument was substantially affected by addressing the 
lessons learned from Covid-19. It was also impacted by the policy and legal developments 
determined  by  various  crises  triggered  by  the  geopolitical  challenges  in  the  EU 
neighborhood, notably those linked to the Russian war of aggression on Ukraine, and the 
mass  arrivals  of  persons  under  the  Temporary  Protection  Directive (32)  regime.  This 
created an unforeseen pressure at the borders in a number of Member States, scaling up 
fast on the short-term the resources needed for the management of EU Eastern borders, 
while on the longer term this had an impact on several Member States. This happened at a 
time when BMVI programmes had not yet been adopted, and it was not possible to deploy 
the new funds to address the situation. Similarly, the instrumentalization of migrants by 
Belarus led to historically high migration flows into the Baltic Member States. To support 
the  Member  States,  as  explained  below,  the  Commission  needed  to  mobilize  quickly 
support in the form of emergency assistance and Specific Actions. 

In more general terms, detections of irregular border crossings kept increasing through the 
first  years  of  implementation.  Even  with  a  reduction  of  38%  in  2024 (33),  irregular 
migration is and will continue to be the main risk (34). In the case of border management, 
this  was  compounded  by  a  return  to  normal  of  regular  arrivals,  after  the  restrictions 
imposed by the COVID-19 pandemic, which facilitated mobility at all levels, and included 
the rapid recovery of air passenger demand to pre-pandemic levels. 

This return to normal also impacted the level of cross-border crime activities, which took 
advantage  of  this  facilitated  mobility  to  go  back  to  higher  than  pre-pandemic  levels  of 
crime.  This  notably  includes  an  increase  in  migrant  smuggling  activity  and  the 
diversification of the modus operandi of smugglers. For instance, through the sea routes, 
means  used  for  smuggling  irregular  migrants  have  diversified  and  have  become  less 
dependent  on  seasonality,  with  the  corresponding  impact  on  border  surveillance 
activities (35). 

(32)  Council Directive 2001/55/EC of 20 July 2001 on minimum standards for giving temporary protection 
in  the  event  of  a  mass  influx  of  displaced  persons  and  on  measures  promoting  a  balance  of  efforts 
between Member States in receiving such persons and bearing the consequences thereof 

(33)  https://www.frontex.europa.eu/media-centre/news/news-release/irregular-border-crossings-into-eu-

drop-sharply-in-2024-oqpweX  

(34)  FRONTEX. Annual Risk Analysis 2024/2025. May 2024.  
(35)  FRONTEX. Risk Analysis for 2023/2024, at 
  https://www.frontex.europa.eu/assets/Publications/General/ARA_2023.pdf  

11 

 
 
 
 
 
3.2.  Description of the Implementation Set-up 

The BMVI is one of the three EU Home Affairs Funds for the 2021-2027 period, which 
altogether amount to EUR 20.6 billion (36). 

Figure 1: Total budget for the three EU Home Affairs Funds 

The BMVI is implemented through shared management, direct management and indirect 
management (37). The programming occurs at the Member State level, through the 2021-
2027 Member State Programmes, or at the Commission level, through the multi-annual 
BMVI Thematic Facility Programme.  

The  BMVI  components  of  the  Thematic  Facility  are  identified  as  follows:  Specific 
Actions, Union Actions and Emergency Assistance (henceforward EMAS) (38).  

(36)  As of 22 November 2024. 
(37)  For 
explanation 

an 

of 

the 

terminology 

in 

this 

chapter, 

please 

refer 

to 

https://commission.europa.eu/funding-tenders/find-funding/funding-management-mode_en#shared-
management  

(38)  Article 8 of BMVI Regulation. 

12 

 
 
 
 
 
 
 
 
 
 
Figure 2: Implementation modes of the EU budget 

Shared management receives the largest share of the initial BMVI financial envelope. This 
is valid in relation to the initial financial envelope and the current EU budget for BMVI.   
The initial EU financial envelope of BMVI amounted to  EUR 6.3 billion, out of which 
EUR 3.7 billion for the Member State programmes (58%), including the amount envisaged 
for the mid-term  review  (39), and EUR 2.6 billion for the BMVI Thematic Facility  (40). 
Currently, the BMVI EU total amount is EUR 7.7 billion, out of which EUR 4.3 billion (41) 
for  the  Member  States  programmes  (56%)  and  EUR  3.4  billion  for  BMVI  Thematic 
Facility.  

Having this EU support, Member States developed their BMVI programmes to respond to 
EU priorities through the implementation measures listed in Annex II and the support set 
out in Annex III of the BMVI Regulation.  Pursuant to Articles 38 to 40 of the CPR,  to 
implement  the  Member  States’  programmes,  Member  States  had  to  establish  the 
composition and functions of the Monitoring Committee which has a significant role in the 
monitoring the implementation of Member States BMVI programmes. The Commission 
follows  the  implementation  of  shared  management  by  examining  the  BMVI  annual 
performance  reports  and  the  cumulative  data  Member  States  submit  on  financial  and 
operational progress during each year (data on operational progress is reported five times 
a year and financial data twice a year), while payment applications may be submitted up 
to six times per year (42).   

(39)  EUR 611 million, as per Articles 10 and 14 of BMVI Regulation  
(40)  Additional resources stemming from the BMVI Thematic Facility are allocated (as Specific Actions and, 
possibly,  EMAS)  to  the  Member  State  programmes  and  implemented  through  shared  management 
throughout the programming period.   

(41)  This amount does not include the contribution of the Schengen Associated Countries and the mid-term 
review  additional  amounts  to  be  allocated  to  the  BMVI  programmes  as  per  Article  14 of  the  BMVI 
Regulation.  

(42)  Articles 41 and 42 of the CPR Regulation. 

13 

 
 
 
 
 
 
 
 
 
Table 1: Overview of budget programming for BMVI (as of 22 November 2024), billion 
EUR 

Total (43), 

of which: 

- for Member 
States 
programmes (44) 

- for the Thematic Facility (45) 

7,7 

4,3 

3,4 

0,4 

1,3 

1,7 

Total 

2021-2022 

2023-2025 

2026-2027 

The  Thematic  Facility  allows  for  a  more  flexible  allocation  of  resources  to  address 
priorities  with  a  high  Union  added  value  and  to  respond  to  urgent  needs  or  emerging 
threats.  The  amount  available  under  the  BMVI  Thematic  Facility  is  allocated  in 
Multiannual  Work  Programmes  which  are  established  by  the  European  Commission  in 
agreement  with Member  States’  representatives  and  in  consultation  with  relevant 
stakeholders.  This  flexibility  ensures  that  both,  national  and  EU-wide  priorities,  can  be 
addressed  efficiently  while  maintaining  a  high  level  of  responsiveness  to  new 
developments.  Resources  from  the  Thematic  Facility  can  be  implemented  as  Union 
Actions  (in  direct  or  indirect  management),  provided  as  Emergency  Assistance  or 
channelled to the Member States’ programmes via Specific Actions implemented in shared 
management.  

The actual implementation of the funds in shared management was delayed due to the long 
negotiation of the Member State programmes to meet the various policy objectives and 
legal obligations, including of the CPR. As a result, they were only approved by the end 
of 2022. As explained in later sections, a number of factors played in this delay, not least 
the  need  to  immediately  make  funding  available  to  Member  States  to  face  the 
consequences of the war in Ukraine. 

International agreements within the meaning of Article 218 TFEU between the Schengen 
Associated  Countries  and  the  Union  had  to  be  concluded  so  that  Norway,  Iceland, 
Switzerland and Liechtenstein participate to the 2021-2027 BMVI (46), as they did in the 
previous similar funding instruments. The agreements concluded between the Union and 
the  SACs (47)  lay  down  the  supplementary  rules  applicable  to  these  third  countries, 
enabling  them  to  contribute  to  and  benefit  from  the  BMVI.  In  the  current  set-up, 
negotiations on the supplementary agreements can only start after the formal adoption of 
the Home Affairs Funds Regulations. The participation of the SACs is not directly based 
on  the  BMVI  Regulation,  but  on  the  Association  Agreements  these  four  countries 
(Norway,  Switzerland,  Iceland,  Liechtenstein)  signed  with  the  Union  following  the 
integration  of  the  Schengen  acquis  into  the  framework  of  the  European  Union,  in 
accordance with Protocol 19 to the TFEU. Negotiations tend to be complex, and the formal 
adoption and ratification process of such agreements are lengthy. This explains why by the 

(43) Including additional allocations of EUR 1,1 billion agreed in November 2020 and the allocations to the 

Schengen associated countries 

(44) Member State envelopes  include the amounts foreseen under the  mid-term review as well as various 

transfers between funds.  

(45) Including Mid-term Review of the MFF, ie. EUR 0,8 bn for AMIF and EUR 1 bn for BMVI.  
(46)  Art. 7(6) BMVI Regulation. 
(47)  Agreement  between  the  European  Union  and  the  Kingdom  of  Norway  –  OJ  2024/1592; 
2024/1591; 
– 
the  Swiss  Confederation  -  OJ  2024/1292; 

Agreement 
Agreement  between 
Agreement between the European Union and the Principality of Liechtenstein – OJ 2024/200; 

the  European  Union  and 

European 

between 

Iceland 

Union 

and 

the 

OJ 

14 

 
 
 
 
 
 
 
 
 
 
end  of  2024  the  Commission  could  not  approve  the  BMVI  draft  programmes  of  the 
SACs (48)  and  why  the  implementation  of  the  BMVI  is  not  very  advanced  in  these 
countries. 

3.3.  BMVI Implementation - Financial Progress  

The initial financial envelope of the BMVI was EUR 6.3 billion. Since the adoption of the 
BMVI, the financial envelope has increased to EUR 7.7 billion by the end of 2024. The 
increase  is  a  result  of  transfers  from  the  Structural  Funds,  income  from  fines,  unused 
appropriations from the Justice and Home Affairs agencies, various budgetary procedures 
and the mid-term revision of the 2021-2027 Multiannual Financial Framework. (49) 

 Member States’ programmes – Shared Management (50)  

As of 30 June 2024, planned resources (51) in shared management amount to EUR 4.225 
million  (including  technical  assistance  which  is  a  flat  rate  of  6%  applied  to  all  eligible 
expenditure  included  in  payment  applications (52)).  Operations  under  SO1  represent  a 
larger share than those under SO2.   

(48)  Out of the 4 Schengen Associated Countries, Liechtenstein is not implementing BMVI under shared 

management mode.  

(49)  Through this document, the following terminology is used when it comes to financial progress: 

Implementation rate: the ratio of commitments to concrete operations over allocated funds. It measures 
progress in terms of operations selected. 
Absorption rate: the ratio of costs declared per allocated funds (at the closure of given operations, this 
will  correspond  to  the ratio  of  payments  per  allocated  funds,  once  possible  pre-payments,  recovered 
amounts are accounted for). The absorption rate measures progress of concrete operations. 
(50)  Unless otherwise mentioned, all figures and data are referred to the cut-off date of 30 June 2024. 
(51)  Planned resources refers to the initial allocation made at the programming stage. At the Commission 
level, these planned resources are based on the latest adopted versions of the Thematic Facility work 
programmes.  This  includes  resources  allocated  for  Union  Actions,  Specific  Actions  and  Emergency 
Assistance.  At  the  Member  State  level,  planned  resources  are  derived  from  the  latest  version  of  the 
adopted Member State programmes, reflecting allocations implemented via shared management, with 
the exclusion of Specific Actions to avoid double counting.   

(52)  Article 36(5) of the CPR Regulation.  

15 

 
 
 
Figure 3 - Allocations to Member States’ national programmes under SO 1 (EUR million, status 
30 June 2024) 

Source: European Commission - SCF2021 data 

Figure 4 - Allocations to Member States’ national programmes under SO2 (EUR million, status 
30 June 2024) 

Source: European Commission - SCF2021 data 

The rate of committed resources (53) in shared management is 31% for SO1 and 28.1% for 
SO2. The absorption rate is 5.2% for SO1 and 3.7% for SO2. The low absorption rate at 
that point in time demonstrates that Member States we still in the early stages of BMVI 

(53) Committed resources represent, in broad terms, the commitment of resources to the beneficiaries, i.e. to 
those responsible for initiating/ implementing the operations. In shared management, this corresponds 
to the eligible cost of operations that have been selected for support by the Managing Authorities. For 
direct  and  indirect  management,  it  corresponds  to  the  value  of  grants,  contracts  or  agreements  with 
beneficiaries, contractors and partner entities. 

16 

 
 
 
 
 
 
implementation. This is in line with the information provided in the Member States BMVI 
mid-term evaluations and annual performance reports.  

Table 2 – Shared management allocations, commitments, costs declared (June 2024) 

Specific 
Objectives 

Allocated 
Resources 

Committed 
Resources 

Costs 
declared 

SO1 - borders   4 303 319 490  2 571 978 333  306 633 447 

Implementation 
rate (%) 
59.8 

Absorption rate 
(%) 
7.1 

SO2 - visa  

367 712 530 

184 516 326 

22 005 339 

4 671 032 019  2 756 494 659  328 638 787 

50.2 

59.0 

6.0 

7.0 

The Member States with the highest amounts for  SO1 (integrated border management), 
including regular actions, specific actions and operations support, are: Greece (EUR 1 098 
million),  Italy (EUR 452 million),  Lithuania  (EUR 308 million)  and  Spain  (EUR  257 
million). This reflects their important position in EU external border management.   

Whereas  for  SO  2  (visa  policy),  the  Member  States  with  the  highest  amounts  are 
Greece (EUR 61 million), Spain (EUR 32.3 million) and France (EUR 31.6 million). This 
aligns with the reality that France and Spain are the Member States that receive the most 
short-stay visa applications (54). Member States are required to allocate minimum 10% of 
their  BMVI  programme  funds  to  SO2 (55),  nonetheless  this  objective  is  clearly  less 
prioritised in the Member State programmes.   

Member States  may receive additional funds  to their programme  to  implement targeted 
Specific Actions with the BMVI  Thematic Facility support. Of the 15 Specific Actions 
launched by 30 June 2024, 14 were under the scope of SO1 and one was under the scope 
of SO2.  

Under SO1, the Specific Action with the largest available budget was the call for the large-
scale  border  surveillance  equipment  for  Frontex  national  components,  purchased  under 
BMVI by the Member States and to be put also at the disposal of the agency. This Specific 
Action  resulted  in  awarding  EUR 201.1 million  to  12  Member  States.  Other  notable 
Specific Actions under SO1 include the allocation of EUR 185 million to enhance border 
surveillance in the countries neighbouring Belarus, in response to its instrumentalisation 
of migration in 2021, and EUR 141.2 million for electronic surveillance systems at the EU 
external land borders.   

Regarding the Specific Action under SO2 for the digitalization, consular cooperation, and 
other related actions, the Netherlands received EUR 1.5 million to accelerate and digitalise 
the  visa  application  process,  while  Sweden  received  EUR  1.26  million  to  develop  a 
common EU visa training.   

Annex  VI  of  the  BMVI  Regulation  details  the  fields  of  intervention.  Within  SO1,  the 
largest  share  of  resources  has  been  planned  for  border  surveillance  (23.9%  of  planned 
resources). Also noteworthy is the amount of resources planned for large-scale IT systems. 
In  contrast,  the  intervention  fields  for  inter-agency  cooperation  draw  less  interest,  with 
only five Member States allocating funds. The lowest amount of planned resources refers 
to  the  intervention  fields  for  data  quality  and  data  subjects’  rights  to  information  and 

(54)  Short-stay visas issued by Schengen countries 2022,  Short-stay visas issued by Schengen countries - 

European Commission 

(55)  Article 13(2) of the BMVI Regulation 

17 

 
 
  
 
  
 
measures related to the identification and referral of vulnerable persons. For three fields of 
intervention, no data has been reported thus far. (56)  

Under SO2,  the  most  reported  intervention  fields  are  large  scale  IT  systems  –  Visa 
Information System and other ICT systems for visa application processing purposes, which 
respectively have 28% and 15% of the total planned resources for SO2. In contrast, the 
intervention fields related to consulates have consistently received less planned resources.   

Union Actions - Direct Management  

As of 30 June 2024, the Commission approved nine Union Actions (including the Union 
Action for Liechtenstein) under the BMVI Thematic Facility for transnational projects or 
projects of particular interest to the Union. They involve 10 Member States, Liechtenstein 
and the International Organization for Migration (IOM). In total, the resources granted for 
BMVI direct management amount to EUR 10.3 million.   

Due  to  Liechtenstein's  small  allocation  in  the  2021-2027  programming  period  and  the 
administrative  burden  of  implementing  a  programme  under  the  CPR,  it  was  decided  to 
support Liechtenstein’s compliance with the Schengen acquis through grants under direct 
management, than a programme under shared management (57).   

Union Actions – Indirect Management  

Under  indirect  management  the  BMVI  Thematic  Facility  supports  projects  through  the 
Migration Partnership Facility (henceforth  MPF). MPF is  managed by the  International 
Centre for Migration Policy Development (ICMPD) and aims to strengthen dialogue and 
cooperation  on  migration  and  mobility  issues  between  EU  Member  States  and  partner 
countries.  MPF  is  supported  by AMIF, BMVI  and  ISF  Thematic  Facility  Programmes; 
however table 3 only shows the contribution from the BMVI Thematic Facility.  

Project title  

Table 3: MPF projects for the 2021-2027 programming period as of 30 June 2024 
Member 
State & third 
country  
LV, MD  

EU contribution 
committed  
(EUR)  
323 443.18  

Commitment 
year  

2023  

Status  

Awarded  

Strengthening the capacity of 
the  General  Inspectorate  of 
the 
the  Border  Police  of 
Republic  of  Moldova 
in 
“green”  and  “blue”  border 
control (LatMoldova)   
Visa  Capacity  Building  in 
and  Herzegovina 
Bosnia 
(VCBB)  

SE, BA  

2023  

1 142 548.51   Awarded  

(56)  Measures related to the identification and referral of persons who are in need of, or who wish to apply 
for, international protection; Large-scale IT systems – Eurodac for border management purposes; and 
Large-scale  IT  systems  –  European  Travel  Information  and  Authorisation  System  (ETIAS)  – 
Article 85(3) of Regulation (EU) 2018/1240 have not been reported on in the Transmission of Data as 
of 30 June 2024 

(57)  Agreement between the European Union and the Principality of Liechtenstein on supplementary rules 
in relation to the Instrument for Financial Support for Border Management and Visa Policy, as part of 
the Integrated Border Management Fund, for the period 2021 to 2027  

18 

 
 
 
 
A  third  project,  “Enhancing  the  Border  Management  Capacity  of  the  Presidency  of 
Migration Management (ENGAGE)”, with a budget of EUR 10 million from the BMVI 
Thematic Facility budget, implementing a collaboration between ICMPD, the Commission 
and Türkiye with the aim of strengthening Türkiye’s border management in line with the 
European Integrated Border Management standards, has been recently approved (after the 
cut-off date for the study). 

EMAS  

In response to the Russian war of aggression towards Ukraine, four EMAS projects were 
granted  to  assist  the  Member  States  dealing  with  an  exceptional  amount  of  pressure 
resulting from the high arrival of displaced Ukrainians arriving via the land borders. The 
EMAS  projects  concerned  Poland  (EUR  76.2  million),  Romania  (EUR  27  million), 
Hungary (EUR 11.5 million) and Slovakia (EUR 9.3 million). A fifth EMAS project was 
granted (EUR 17,490,149.49) with the aim of assisting Spanish authorities following the 
surge in irregular migration flows to the Canary Islands by strengthening their capacity to 
identify and assist irregular migrants arriving to the Islands. Finally, a sixth project was 
granted  to  the  Finnish  Border  Guard  (EUR  15,999,999.97)  to  support  further  efforts  to 
counter illegal migration at the external border and return border crossing traffic back to 
normal considering the unprecedented number of people seeking international protection 
at the eastern border with Russia (58). All the above-mentioned BMVI EMAS projects are 
implemented under direct management.  

4. 

 EVALUATION FINDINGS 

4.1.  To what extent was the intervention successful and why? 

4.1.1. 

Effectiveness 

Given the late start of the implementation of the BMVI, the Evaluation is not in a position 
to  provide  an  assessment  on  the  effectiveness  of  the  Instrument.  This  limitation  was 
foreseen when defining the evaluation questions, which in the case of effectiveness aimed 
at ascertaining whether the funding was on track to the achievement of the objectives at 
the end of the programming period. 

Nonetheless, the evidence obtained indicates that BMVI has made financial progress in 
some  activities  under  SO1  (integrated  border  management),  reflecting  the  strong 
commitment of Member States to enhance border control. Financial progress under 
SO2 has taken a slower start. 

Under  SO1,  implementation  rates  have  progressed  the  most  in  four  fields  of 
intervention by mid-2024 (59:  

(58)  This EMAS project was awarded in October 2024 and signed in November 2024, and is therefore out of 
the scope of this evaluation for the data analysis for which the cut-off is 30 June 2024, nonetheless it is 
worth mentioning this project in the state of play.  

(59) It should be noted that the Special Transit Scheme pertains exclusively to Lithuania and should therefore 
be regarded as a country-specific area of intervention. Furthermore, when examining absorption rates, 
the  quality  of  the  data  does  not  allow  for  an  accurate  depiction  of  distribution  across  all  countries. 
Consequently, this data will be approached with particular caution. 

19 

 
 
  
 
•  Special Transit Scheme (72.7%), 

•  Procurement of equipment for border surveillance (67.4%),  

•  Operating support for border management (44.8%), 

•  Establishment of large-scale IT systems (39.8%).  

The  implementation  rates  for  the  Special  Transit  Scheme  and  equipment  for  border 
surveillance are significantly higher than for other types of interventions.  

Figure 5: Implementation and absorption rates for SO1 (status 30 June 2024) 

Source: Cohesion Open Data Portal 

Member State mid-term evaluations and stakeholder consultations indicate that the 
current  geopolitical  situation  has  had  an  impact  on  migration  flows  and  border 
management,  marking  a  shift  in  Member  States  towards  investments  aimed  at 
strengthening EU’s external borders and reducing the investment on other activities 
still under the scope of SO1.  

The  analysis  of  financial  data  suggests  that  activities  under  SO1  such  as  measures  of 
protection of vulnerable groups within the framework of border control (60), infrastructure 
upgrades or data management and exchange have been much less implemented at this stage 
than activities that have more of a direct focus on border control. This observation can be 
explained by migration pressures at borders as suggested by stakeholders’ interviews from 
Member States. In Eastern Europe, this led Member States to reinforce the management of 
the influx of migrants  from  Russia and Belarus, because of the war in  Ukraine and the 
instrumentalization of migrants. Same pressure occurred also in southern Europe with high 

(60) 004, 001, 003 (Actions listed in annex IV, (5), (6), (8)). 
20 

 
 
 
migration  influx  arriving  for  instance  in  Spain  in  February  2024  on  El  Hierro,  Canary 
Islands.  In  the  long  run,  this  might  negatively  impact  the  achievement  of  operational 
objectives  concerning  data  management  and  exchange,  migrant  assistance  activities,  as 
well  as  the  enhancement  of  the  inter-agency  cooperation  at  all  requested  levels,  the 
increasing  capacity  to  render  assistance  to  persons  in  distress  at  sea  and  the  support  of 
search and rescue operations in the context of border surveillance operations at sea. 

The  specific  support  to  Lithuania  through  the  Special  Transit  Scheme  has  provided 
financial assistance in smooth transit between the Russian Federation and its Kaliningrad 
region  through  Lithuania  at  a  difficult  political  moment  following  the  Russian  war  of 
aggression  towards  Ukraine,  in  compliance  with  EU  regulations  on  transit  and  border 
management (61).  The  support  funded  assistance  to  managing  transit-related  visa 
procedures,  compensating  for  the  lost  revenue  from  visa  fees  and  covering  additional 
costs (62) incurred from implementing the Facilitated Transit Document and Facilitated 
Rail Transit Document schemes (63).  

Overall, concerning SO1 the Member States’ mid-term evaluation reports show a focus on 
better border checks and surveillance, analysis of risks and threats, as well as enhancing 
and  maintaining  IT  infrastructure  such  as  upgraded  software  and  equipment,  or 
cybersecurity for border management, all converging to meeting the objective of integrated 
and strengthen border management and control. According to interviews, the operational 
set up for the development of the Entry-Exit System with financial support from ISF-BV 
and BMVI has involved a huge effort for Member States. It involved setting it up at all 
border crossing points digital records of the entries and exits of short-stay visa holders and 
visa-exempt travellers crossing the EU’s external borders. 

Regarding  SO2,  the  progress  towards  the  achievement  of  the  objectives  is  slower  (see 
figure  6).  However,  the  higher  implementation  rates  for  measures  aiming  at  the 
implementation  of  the  Visa  Information  System  (VIS),  improving  the  visa  application 
processing, and the relevant ICT systems for application processing, show a positive trend 
towards  the  reinforcement  of  the  common  visa  policy.  There  has  been  no  progress  on 
extending consular coverage to accelerate procedures.  

(61) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0515 
(62) Additional costs include costs which result directly from the specific requirements of implementing the 
operation of the Special Transit Scheme and which are not generated as a result of the issuing of visas 
for the purpose of transit or other purposes. For example, investment in infrastructures, training of staff, 
salaries (European Parliament, Regulation (EU) No 515/2014 of the  European Parliament and of the 
Council of 16 April 2014 establishing, as part of the Internal Security Fund, the Instrument for financial 
support for external borders and visa and repealing Decision No 574/2007/EC, Article 11) 

(63)  The  Facilitated  Transit  Document  (FTD)  and  the  Facilitated  Rail  Transit  Document  are  specific 
authorisations allowing for a facilitated transit in the event of specific and direct transit needs by land of 
non-EU country nationals who must necessarily cross the territory of one or several EU countries in 
order to travel between two parts of their country which are geographically discontinuous. This is the 
case 
rest  of  Russia.  Source:  https://eur-lex.europa.eu/EN/legal-
content/summary/facilitated-transit-document-ftd-and-facilitated-rail-transit-document-frtd.html. 

for  Kaliningrad  and 

the 

21 

 
 
 
 
 
Figure 6: Implementation and absorption rates for SO2 (status 30 June 2024) 

Source: Cohesion Open Data Portal 

Following  a  relatively  slow  start,  implementation  rates  have  picked  up  and  BMVI  has 
shown good overall financial progress across all management modes, particularly due to 
an  increase  in  commitments  (shared  management)  during  the  second  quarter  of  2024, 
especially under Specific Objective 1 (SO 1). However, financial progress under Specific 
Objective 2 (SO 2), as measured by the implementation rate, has started more slowly. The 
implementation  rate  at  which  BMVI  is  progressing,  while  on  track,  is  still  facing 
challenges which may hinder the BMVI’s capacity to meet its objectives. 

As seen in figure 7, the absorption rate of the shared-management national programmes 
lags slightly behind that of the predecessor programme ISF-BV, although the good recent 
progress in the overall implementation rate suggests that absorption will gain speed and is 
likely to catch up with, and surpass, ISF-BV. The national programmes under ISF-BV have 
ended with a total absorption rate of 76.6% (N.B.: percentages are calculated on the basis 
of  the  current  total  allocations  to  national  programmes.  Possible  future  additional 
allocations reduce implementation and absorption rates proportionally). 

22 

 
 
 
 
 
 
 
 
Figure 7: Implementation and absorption rates for BMVI national programmes  (status 30 June 
2024), comparative evolution of the absorption rate of predecessor programme ISF-BV 

Source: Cohesion Open Data Portal, SFC2014 data (ISF-BV) 

As an indicative point of comparison and looking only at shared management, as of mid-
2024, BMVI has already committed amounts to concrete operations that more or less match 
that of the total funding under ISF-BV for national programmes for the whole period of 
implementation (EUR 2 079 million of commitments reported for BMVI vs. EUR 2 420 
million for the ISF-BV under shared management). 

In terms of physical performance (common output and result indicators), due to the 
late start of the programmes, achievements had only started to be reported (only one output 
indicator reported with a non-zero value for 2023, and only 45 by the end of 2023) when 
the  evaluation  was  launched.  Moreover,  there  is  a  lag  between  implementation  and 
regulatory reporting, which is also affected by the data transmission chain in the different 
Member  States.  Finally,  some  initial  targets  are  obsolete  by  now  due  to  changes  in 
implementation plans. Because of these reasons, it is not yet possible to draw conclusions 
on effectiveness, apart from the obvious fact that achievements in terms of meeting 
the 2024 milestones for common output and results indicators are uneven across both 
Member States and the areas of BMVI operations.  

Although  the  programmes’  financial  progress  under  the  shared  management  mode,  in 
terms  of  funds  committed  (implementation  rate),  is  satisfactory,  the  level  of  physical 
progress reported in terms of achievements under the common output indicators defined 
in the BMVI Regulation is therefore generally lagging (64). 

Information  on  physical  progress,  including  the  metrics  of  the  programme’s 
effectiveness towards reaching its expected objectives paints a heterogeneous picture. 
While  part  of  this  is  attributable  to  differences  across  the  progress  in  programme 

(64)  For the whole list of output and result indicators, see list in Annex 

23 

 
 
 
 
 
implementation  across  Member  States,  as  we  will  see  in  more  detail,  an  essential 
explanatory  factor  behind  differences  in  physical  progress  indicators  is  that  BMVI’s 
monitoring system has important weaknesses that need to be addressed in the remainder 
of the implementation period. These include: 

(i) monitoring system design issues: as evidenced during the analysis carried out by the 
evaluators, some common output and result indicators set out in the Regulation are not 
adequately  capturing  the  direct  consequences  of  programme  operations.  They  are 
heavily influenced by context and may be better used in the ex-post evaluation of the 
impacts  of  the  programme.  Also,  several  output  indicators  refer  to  physical  units  of 
equipment or buildings, which are incomparable across Member States and even across 
operations, as the nature, area of utilisation and unit value of equipment and buildings 
can be very different. 

(ii) operational issues with monitoring: as evidenced in the case studies and interviews, 
Managing  Authorities  encounter  difficulties  in  operationalising  the  new  monitoring 
indicators and reporting  system. Errors and missing/non-reported values in indicators 
transmitted  to  the  EC  through  the  SFC  system  occur  relatively  frequently.  Some 
Managing  Authorities  do  not  follow  the  guidance  on  the  interpretation  of  certain 
common indicators and use slightly or significantly different methods when reporting 
(e.g. on the trainings provided), harming comparability across countries. In addition, as 
identified by the Commission and verified by the evaluators, on several occasions the 
initial  targets  set  at  the  beginning  of  the  programme  period  became  outdated  as  a 
consequence of revised plans for implementation - or target setting methodologies were 
not appropriate from the outset.  

Concerning the second point it is expected that as Managing Authorities progress in their 
learning  curve  in  the  second  half  of  BMVI  implementation,  also  the  quality  of 
monitoring data might show some improvements. The Commission was counting on this 
issue from the beginning of the programming period, given the fact that an adjustment 
to the new system should necessarily be needed.  

As  highlighted  by  the  European  Court  of  Auditors,  the  current  monitoring  system 
presents significant improvements with respect to the one under ISF-BV, thanks to the 
adoption of a more standardised system under the CPR, and a clearer guidance on the 
monitoring system provided by the Commission. An additional limitation of the actual 
monitoring  system  is  due  to  the  lack  of  points  of  comparison  with  respect  to  the 
implementation of the ISF-BV due to the change in the monitoring set-up. 

Nine Member States (Belgium, Bulgaria, Hungary, Luxembourg, Malta, Poland, Romania, 
Slovakia and Portugal) had not yet reported any physical progress of their operations as of 
30 June 2024 – although five of them did indicate that they had committed funds to ongoing 
operations with planned output values for at least some of the relevant indicators (Belgium, 
Bulgaria, Malta, Poland and Romania). 

24 

 
 
 
 
 
 
Table 4: Number of output indicators June 2024 

Member State 

Number  of  indicators 
with 
milestones 
defined 

Number  of  indicators 
with 
achievements 
reported 

As  %  of  indicators 
with milestones 

Lithuania 

Estonia 

Germany 

Cyprus 

Austria 

Spain 

Czechia 

Slovenia 

Finland 

Sweden 

Latvia 

France 

Croatia 

Netherlands 

Denmark 

Italy 

Greece 

Belgium 

Bulgaria 

Hungary 

Luxembourg 

Malta 

Poland 

Romania 

Slovakia 

13 

14 

14 

13 

15 

21 

10 

22 

19 

16 

12 

22 

22 

14 

6 

16 

10 

15 

12 

19 

15 

9 

2 

15 

6 

Portugal 
Source: European Commission - SFC2021 data 

- 

12 

10 

9 

8 

9 

12 

5 

11 

9 

7 

5 

9 

8 

5 

2 

5 

3 

- 

- 

- 

- 

- 

- 

- 

- 

- 

92.3 

71.4 

64.3 

61.5 

60.0 

57.1 

50.0 

50.0 

47.4 

43.8 

41.7 

40.9 

36.4 

35.7 

33.3 

31.3 

30.0 

- 

- 

- 

- 

- 

- 

- 

- 

- 

In terms of the number of output indicators (with a positive milestone value set for 2024) 
where Member States have reported progress, a large discrepancy between countries can 
be seen: Cyprus reported to have already achieved more than half of its milestones, while 
a number of countries such as Czechia, Spain, Estonia, Austria, Germany, Slovenia and 
especially  Lithuania  have  reported  some  progress  for  half  or  more  of  their  output 
indicators. 

25 

 
 
 
 
 
 
 
 
Figure  8:  Number  of  output  indicators  with  milestone  value  achieved  /  some  progress  /  zero 
progress reported, by Member State (30 June 2024) 

Source: European Commission - SFC2021 data 

No  progress  at  all  had  been  reported  by  the  Member  States  for  two  output  indicators  - 
O.1.12 ‘Number of cooperation projects with third countries’ and O.2.7 ‘Number of real 
estates rented / depreciated’ – while reported progress has also been relatively slow and 
very uneven across countries under indicators O.1.5., O.2.2/2.2.1 or O.2.6. 

Figure  9:  Number  of  output  indicators  with  milestone  value  achieved  /  some  progress  /  zero 
progress reported, by indicator (30 June 2024) 

Source: European Commission - SFC2021 data 

26 

 
 
 
 
 
The uneven reporting of physical results can initially be attributed to delays. In most 
significant  cases,  triangulated  data  from  performance  reports  and  mid-term  evaluation 
reports indicates that, in Germany and Portugal, the lag is at least partially due to delays in 
the  overall  design  and  approval  process.  Germany's  Programme  was  approved  in 
November 2022 only. Although Portugal's Programme was validated in 2022, it had not 
been implemented by the end of 2023. Among the non-EU members, Iceland also faced 
delays:  its  participation  had  not  been  formalised  within  the  Icelandic  and  EU  legal 
frameworks by the end of 2023. Other examples of delays were reported, ranging from the 
late approval of the national programme, (65) the large-scale IT-related projects where the 
delays at EU level (e.g. interoperability and EU-LISA) (66), to the administrative burden in 
the preparation of the system (67). 

In addition to delays, evidence suggests that a fragile methodology and inconsistent 
application of the monitoring framework necessitate a cautious analysis of the data 
regarding the achievement of targets and objectives. Data limitation can be illustrated 
by the inappropriate definition of initial targets and the fragile adequacy of certain output 
indicators  in accurately  reflecting  BMVI  progress, which is  developed below under the 
assessment of the monitoring framework and its implementation sections. 

The BMVI Thematic Facility (EMAS, Specific Actions and Union Actions) has been 
effectively used to support countries in deploying interventions to face the crises that 
appeared even before the approval of the programmes, notably the consequences of 
Russia’s war of aggression against Ukraine and the instrumentalisation of migrants 
by Belarus. 

In all countries where the BMVI EMAS support was provided to address the impact of the 
Russian war in Ukraine (Hungary, Poland, Romania and Slovakia), the intervention was 
successful in providing urgent financial support for border management activities during a 
massive  influx  of  people.  This  has  been  confirmed  through  the  case  studies  and  the 
stakeholders’  surveys.  In  all  four  countries,  EMAS  contributed  to  improving  border 
management operations, which included construction of new border crossing points, the 
deployment of additional border guard officers to existing units and the procurement of 
equipment  designed to  aid  border control,  such as computers, scanners, routers, mobile 
phones,  document  readers,  biometric  data  readers,  printers,  and  Wi-Fi  routers.  For 
instance, in Poland and in Slovakia, the indicators show that the activities co-funded by 
BMVI have over-performed in managing to identify a higher number of crossings at the 
EU external borders than expected and in providing assistance to a high number of persons 
entering the EU. 

Apart  from  the  inevitably  reduced  information  on  performance  at  this  stage,  the 
implementation of the monitoring and evaluation framework is affected by  several 
shortcomings. 

The effectiveness of this framework is closely tied to the methodologies used by Member 
States  for  defining  indicators  and  setting  targets,  as  these  methodologies  influence  the 
alignment  of  indicators  with  programme  objectives  and  the  appropriate  monitoring  of 
relevant aspects of the BMVI programmes. The review of the target-setting methodologies 

(65) Delays were reported in the mid-term evaluation reports of the national programmes of Belgium, Estonia, 

Germany, Hungary, Italy, Luxembourg, Slovenia, 

(66)  Delays  were  reported  in  the  mid-term  evaluation  reports  of  the  national  programmes  of  Belgium, 

Lithuania, Sweden. 

(67)  Romania. 

27 

 
 
 
and  the  mid-term  evaluation  reports  made  clear  that  challenges  in  methodologies, 
implementation, data use, and risk management hinder the ability of the monitoring and 
evaluation framework to provide a full picture of progress.  

The analysis also points out a remaining lack of familiarity with a system of continuous 
monitoring  and  reporting  on  outputs  and  results,  as  the  one  defined  in  the  CPR.  While 
Annex VIII indicators in the BMVI Regulation are meant to provide a measure of progress 
and success at EU level, through the contribution of the Managing Authorities, their aim 
is not to monitor all operations in each programme. As explained to the Member States at 
the  beginning  of  the  programming  period ,  “if  the  Member  State’s  strategy  stresses  a 
particular output or result that is not included in Annex VIII, or it is relevant for a Member 
State  to  monitor  or  report  specific  aspects  of  implementation  not  covered  in  the  EU 
performance framework, they can develop their own programme indicators” (68).However, 
several Member States have complained during the evaluation that the indicators set out in 
Annex VIII BMVI do not cover all aspects of the programme. An effective monitoring 
system for programmes needs to be based on the specificities of the programmes  and a 
clear gap is apparent here. 

In addition, it is important to note that the data transmitted by Member States on indicators 
contain  various  errors,  including  clerical  mistakes  (instances  where  data  is  incorrectly 
assigned to a different indicator), omissions (such as missing breakdowns of indicators), 
and  inconsistencies  between  financial  reporting  and  physical  progress  reporting.  The 
source of these discrepancies may stem from operations failing to plan for indicators or 
from  competent  authorities  not  aggregating  and  reporting  them.  Additionally,  output 
indicators  may  be  reported  despite  no  allocations  or  commitments  being  made  for  the 
connected types of intervention, as indicated by the SFC2021 data transmission. 

Moreover,  progress  observed  across  Member  States–  and  the  appropriateness  of  some 
output indicators to accurately reflect progress for BMVI as a whole - also depends on the 
specificities of physical output measured. For instance, the output indicators for the entire 
programme can be driven by only a few Member States if they chose to purchase a large 
amount of equipment or maintain or repair a large amount of infrastructure at relatively 
low average prices (this is relevant for indicators O.1.1 ‘Number of items of equipment 
purchased  for  border  crossing  points’,  O.1.2  ‘Number  of  infrastructure  maintained  / 
repaired’,  O.1.5  ‘Number  of  aerial  vehicles  purchased’,  or  O.2.4  ‘Number  of  IT 
functionalities  developed  /  maintained  /  upgraded’).  Similarly  regarding  the  result 
indicators: Italy, Germany, the Netherlands, for instance, plan to upgrade functionalities in 
all of their consulates at a low cost per-unit, while other countries focus only on a few new 
or upgraded consulates and spending more per consulate upgrade, but their numbers will 
not  influence  the  programme’s  overall  indicator  in  any  perceivable  way  (see  result 
indicator R.2.8 ‘Number of new/ upgraded consulates outside the Schengen area’). 

Finally, reported achievements  have often little to  do with  the initial  targets.  In several 
instances, Member States quickly surpassed their initial targets, while in other cases the 
2029 targets (and certainly the 2024 milestones) might be out of reach. On the one hand, 
these issues can be attributed to the target-setting done prior to the operational decisions 
made on the best way forward (e.g. how to define the scope of projects). They can also be 
related  to  changes  in  the  context  or  in  the  challenges  faced  in  implementation.  While 
certain changes to plans are inevitable, especially in the field of border surveillance and 
monitoring,  the  analysis  suggests  that  the  initial  target-setting  exercise  was  not 

(68) Note HOME-Funds/2021/28 to the Home Affairs Funds Committee. 

28 

 
 
 
systematically grounded in solid evidence and detailed plans outlining how allocations to 
various intervention areas and types would be utilised. Targets should not be set to make 
public satisfactory achievements, but to allow for a solid monitoring of the evolution of 
performance  towards  the  programme  objectives.  This  is  often  linked  to  a  lack  of 
understanding of the indicators and of their purpose.  

This is at odds with the fact that the performance framework defined in the Regulations 
seems  to  mean  an  improvement  with  regard  to  the  system  used  during  the  2014-2020 
period. This point has been underscored by the European Court of Auditors in its Special 
Report on the Integration of Third Country Nationals, which refers to AMIF but may apply 
to  the  reporting  framework  for  the  three  Home  Affairs  Funds:  “This  new  reporting 
framework underscores the shortcomings in the reliability of 2014-2020 project reporting”. 
Additionally, the ECA highlighted as a progress that “these indicators were more easily 
linked to fund activities than the indicators for 2014-2020” (69). 

The ECA confirmed this assessment in chapter 3 of their annual report for 2023 (70) under 
the section dedicated to the Home Affairs Funds, with the title “The performance reporting 
framework improved.” The ECA concluded that “We also observed an improvement in the 
approach to indicators. Legislation introduced a requirement for member states to have a 
methodology for the establishment of the performance framework and to make it available 
to  the  Commission  if  requested.  The  2014-2020  fund-specific  regulations  established 
indicators mapped to objectives, without distinguishing between output and results, while 
the  2021-2027  fund-specific  regulations  established  output  and  result  indicators  for 
objectives, as well as core performance indicators (a selection from the output and result 
indicators). In addition, the Commission established a metadata set to provide the main 
characteristics  (e.g.  definition,  unit  of  measure,  frequency,  data  source,  whether  the 
indicator covers output or results) of indicators from the current programming period.” 

Operationally  speaking,  BMVI  annual  performance  reports  miss  sharing  key 
messages on implementation. 

The annual performance reports (APR) submitted by the Member States cover a large list 
of  topics  (six  topics  across  16  sections).  The  purpose  of  the  APR  is  to  understand  the 
overall  state  of  implementation  of  a  programme  by  requesting  information  on  progress 
made, challenges encountered, mitigation strategies, processes to ensure complementarity 
with other funds, etc. It is primarily seeking qualitative information and is complementary 
to other reporting, such as the transmission of financial data. Member States often report 
on the progress of each topic by presenting target and output indicators, budget committed 
(number  of  activities  launched,  targeted  people  impacted,  equipment  purchased,  etc.). 
While it contributes to a more comprehensive understanding of the data, the text frequently 
lacks decisive insights that can independently convey a clear picture of the key progress, 
achievements,  and  challenges  characterising  the  implementing  year.  As  a  result,  clear 
messages about performance-related issues and insights about the practical progress of the 
programmes towards the targets are often missing. This reduces the added value of such 
reporting for decision-making in the future.  

(69)  Special report 26/2024: Integration of third-country nationals in the EU  – Relevant support from the 

Asylum, Migration and Integration Fund but its impact could not yet be demonstrated.  

(70)  2023 Annual Reports on the implementation of the EU budget for the 2022 financial year and on the 
activities funded by the 9th, 10th and 11th European Development Funds (EDFs) for the 2023 financial 
year 

29 

 
 
 
On a smaller scale, the implementation of the IT system for the monitoring of EU 
funds at national level still needs to be fully implemented in a few  Member States, 
according to mid-term evaluation reports. 

This  may  constitute  a  minor  issue,  as  it  depends  on  adaptations  and  complete 
implementation  and  might  be  addressed  in  the  near  future,  according  to  the  mid-term 
evaluation reports. 

While the involvement of partners seems to be understood as a keystone of the CPR, 
the partnership principle does not seem to be implemented in a similar manner in all 
Member States. 

The Evaluation cannot reach a conclusion as to the actual implementation of a partnership 
principle. According to Article 8(1) of the CPR, partnership in the implementation of the 
programmes shall include at least the following partners: 

• 

regional, local, urban and other public authorities; 

•  economic and social partners; 

• 

relevant  bodies  representing  civil  society,  such  as  environmental  partners,  non-
governmental organisations, and bodies responsible for promoting social inclusion, 
fundamental  rights,  rights  of  persons  with  disabilities,  gender  equality  and  non-
discrimination; 

• 

research organisations and universities, where appropriate. 

Article  8(5)  of  the  CPR  provides  that  partners  should  be  involved  throughout  the 
through 
preparation, 
participation in monitoring committees. 

implementation  and  evaluation  of  programmes, 

including 

According to the preparatory study, Member States have undertaken actions involving the 
stakeholders in the definition, the implementation, the monitoring and validation of BMVI 
programme at national level. Evidence collected in the 26 national programmes suggests 
that 17 countries have social partners in the monitoring committee, 16 have civil society 
organisations,  and  seven  have  representatives  of  international  organisations.  Generally, 
experts and academics as well as economic partners are not well represented in monitoring 
committees. Engagement of stakeholders is observed but varies unevenly across countries.   

Good practices have been found, such as in Hungary, where the Managing Authority, in 
consultation with the Monitoring Committee, held seven preparatory forums for calls for 
proposals in 2023. These forums provided detailed presentations to potential beneficiaries 
about  the  BMVI  programme,  including  technical  content,  procedures,  and  financial 
frameworks.  Various  stakeholders  participated,  including  law  enforcement,  other  state 
administration  authorities  and  educational  institutions.  Feedback  from  these  events  was 
incorporated into the draft calls for proposals, which were adapted to meet the needs and 
preferences of potential applicants. 

However,  even  if  54%  of  the  beneficiaries  participating  in  the  survey  considered 
themselves “adequately involved in  the programming, implementation,  monitoring, and 
evaluation stages of the BMVI”, beneficiaries are stakeholders, but not necessarily partners 
as per CPR. There does not seem to be a common understanding of the concept of partner 

30 

 
 
in the programmes, and it is even less clear whether this diverse understanding is in line 
with  the  definition  in  the  legislation.  This  may  even  appear  from  the  profile  of  “other 
stakeholders”  who  participated  in  the  stakeholders’  survey.  Of  the  total  number  of 
respondents  (72),  55  were  public  authorities.  Only  4  research  institutions,  2  business 
associations and 1 NGO participated in the survey.  

The  respect  of  the  horizontal  principles  is  enshrined  in  the  preparation  and 
implementation of the BMVI programmes. However, more could be done to monitor 
the operational application of these principles (71). 

According to Article 9 of the CPR, in the preparation, implementation and monitoring of 
the fund, Member States and the Commission shall ensure respect for  

• 

fundamental rights and compliance with the Charter of Fundamental Rights of the 
European Union,  

•  equality between men and women, gender mainstreaming and the integration of a 

gender perspective,  

And take appropriate steps  

• 

to prevent any discrimination based on gender, racial or ethnic origin, religion or 
belief, disability, age or sexual orientation,  

•  and the accessibility for persons with disabilities  

Additionally, the objectives of the instrument shall be pursued in line with the objective of 
promoting sustainable development as set out in Article 11 TFEU, taking into account the 
UN Sustainable Development Goals, the Paris Agreement and the "do no significant harm" 
principle. These are the horizontal principles. 

through  detailed 

Countries participating in BMVI have reported in their annual performance reports that the 
respect  of  horizontal  principles  in  the  implementation  of  BMVI  programme  has  been 
ensured 
legislation  and  coordinated  with  relevant  authorities, 
incorporating  specific  activities  such  as  environmental  requirements  and  training  on 
equality.  Evidence  from  interviews,  mid-term  evaluation  reports  and  the  survey  for 
national authorities show that the respect and promotion of horizontal principles has been 
effectively ensured at the stage of the project selection through the display of eligibility 
criteria in the call for proposal and actions. However, they did not clearly indicate that they 
were monitored in all cases in the process of implementation. The evaluation identified 
examples in  Italy, Austria and Spain  as cases where the  Managing  Authorities engaged 
efforts to promote and serve horizontal principles during the implementation. For instance, 
in Italy, the annual performance report indicates that the Managing Authority has included 
civil society organisations and authorities competent in human rights into the overarching 
steering committees of the activity portfolio at the stage of activity and programme design. 

All participating countries have fulfilled their obligations in terms of communication 
and  visibility  of  the  EU  funded  operations  with  the  BMVI  programme  support. 

(71) This section does not refer to the respect of the Horizontal Enabling Conditions defined in Article 15 and 
Annex III of the CPR. The verification and monitoring of the HECs is carried out by the Commission 
through a horizontal mechanism covering all CPR funds. 

31 

 
 
 
However, it is too early to measure the effectiveness of these measures in reaching 
their targets. 

All  Member  States  having  provided  their  BMVI  annual  performance  report  (25)  have 
confirmed  that  they  comply  with  their  obligations  in  terms  of  communication  and 
visibility,  as  defined  in  the  CPR  (72).  Apart  from  setting  up  a  specific  website  for  the 
programme,  Managing  Authorities  have  carried  out  specific  initiatives  through  other 
means  of  communication,  mostly  social  media  networks  (Bulgaria  with  a  Facebook 
page (73),  Croatia  and  the  Managing  Authority’s  official  website  along  with  a  Twitter 
profile (74), Estonia with Spotify and a podcast, (75) France on the website presenting EU-
funded  activities  “L’Europe  s’engage  pour  la  France”, (76)  Spain  with  its  Instagram 
account) (77). Complementary to online actions, seven countries (Cyprus, Finland, Greece, 
Lithuania, Malta, the Netherlands, Spain) reported to have hosted meetings, seminars, and 
events to educate and inform beneficiaries and the public about the various objectives, the 
funding  of  BMVI,  and  the  results  of  the  programme  in  the  closing  of  years  or  for  an 
anniversary (Greece). 

The  Member  State  programmes  communication  strategies  are  at  different  stages  of 
maturity and the use of the communication coordination should be maximised to make the 
most of commonalities between funds. 

The use of different targets and platforms implies that an effort has been made to reach the 
different target populations. However, it was not possible to assess at this stage to what 
extent  these  targets  have  been  reached.  An  effort  in  order  to  monitor  this  aspect  and, 
therefore, provide a more targeted and effective communication to relevant stakeholders, 
should be an objective for the remaining programming period. 

4.1.2. 

Efficiency 

From its early stages of implementation, the BMVI has embedded cost-effectiveness 
elements  at  all  levels,  through  rigorous  project  selection  and  procurement 
mechanisms. However, there is insufficient evidence of effectiveness at this stage to 
carry  out  a  comprehensive  cost-effectiveness  analysis  of  operations  in  any 
management mode. 

Early evidence shows that key mechanisms such as rigorous project proposal evaluations, 
strategic  fund  allocation  based  on  historical  evidence,  and  standardised  procurement 
processes are designed to support the cost-effectiveness of the measures.  

The  evidence  collected  from  desk  research  and  stakeholder  feedback  point  to  a  strong 
emphasis on cost-effectiveness within the Instrument's design, both for measures under the 
Member States’ programmes and Union Actions. Cost-effectiveness is used as a criterion 
in the evaluation of the project proposals, and applicants are required to justify direct costs 
and submit market analyses to ensure that the proposed expenses are in line with expected 

(72) Art. 22(3)(j) and Chapter III CPR. 
(73) Source: https://www.facebook.com/BGISF/ 
(74) Source: https://eufondovi.mup.hr/; https://twitter.com/homefunds.hr  
(75)https://podcasters.spotify.com/pod/show/siseministeerium/episodes/20-Eurotoetus--miks-nii-keeruliselt-
e1t9vv4?fbclid=IwAR1-gKAOZ1sxCEar8q6V_RVCc12qwULSvwxQ0MrC6A56Eh9EzJCwu8nI5nI  
(76)  https://www.europe-en-france.gouv.fr/fr/fonds-europeens/instrument-de-soutien-financier-la-gestion-

des-frontieres-et-la-politique-des-visas  

(77) Source: https://www.instagram.com/fondosueseg/  

32 

 
 
 
outcomes and market rates. Cost estimates must be aligned with the technical scope and 
objectives of the projects, and resource allocations must be proportionate to the complexity 
of the tasks. This includes a careful review of human resources to confirm that team sizes 
and roles are suitable for the projects' demands. 

Drawing  from  historical  data,  such  as  the  mid-term  evaluation  of  ISF-BV,  BMVI 
prioritises interventions with a known record of cost-effectiveness. For instance, Spain's 
programme focuses on interventions that are grounded in evidence of cost-effectiveness, 
informed by previous programme evaluations. This strategic approach has led to targeted 
investments in areas vital to border management, such as biometric systems, surveillance 
equipment,  and  IT  infrastructure  for  visa  processing,  which  are  recognised  for  their 
potential to enhance operations. 

Additionally, beneficiaries in Member States use feasibility studies to assess the viability 
of  complex  projects,  which  contributes  to  selecting  cost-effective  interventions. 
Procurement  processes  across  Member  States  ensure  competitive  pricing  and  value  for 
money,  as  evidenced  by  centralised  public  procurement  offices  in  Italy,  Croatia  and 
Romania.  In  this  regard,  “effective  monitoring  mechanisms  of  the  public  procurement 
market” is  one of the  enabling conditions  established by the CPR (78). All participating 
countries comply with this condition. 

The results of the targeted survey suggest a general positive perception with respect to the 
cost-effectiveness  of  the  measures  under  shared  management.  Specifically,  51.9%  of 
national  authorities (79)  perceive  that  the  progress  through  the  BMVI  programme  was 
achieved at a reasonable cost to a very large or large extent. Beneficiaries (80) also have a 
favorable view on cost-effectiveness, 71% confirming that the activities they are involved 
in under BMVI have been executed to a very large or large extent at a reasonable cost.  

As concerns EMAS, while the available evidence suggests that the mechanism provides 
flexible and effective funding solutions (beneficiaries in Hungary, Poland, Romania, and 
Slovakia emphasised this), a more detailed analysis would be needed to confirm its cost-
effectiveness as compared to other delivery options. 

The  assessment  of  the  cost-effectiveness  of  the  interventions  funded  by  BMVI  should 
become  easier  as  the  programmes  implementation  unfolds  and  data  on  effectiveness 
become  more  abundant  and  reliable.  However,  there  is  a  challenge  in  evaluating  these 
practices as there is no system in place to track and measure the cost-effectiveness of the 
actions  taken  by  those  who  receive  funds  from  the  program.  Data  on  financial 
implementation is not connected to the performance indicators the Managing Authorities 
need to report on. As a result, it is difficult to analyse the financial investment against the 
outputs or results for each specific type of activity to determine which ones are giving the 
best value for money. 

The  design  of  the  management  and  control  systems  for  the  implementation  of  the 
instrument  contributes  to  the  efficiency  of  the  processes  involved.  The  progress  in 
financial  implementation,  though  at  different  speeds,  seems  to  confirm  that 

(78)  Notably annex III. 
(79) Targeted survey for national authorities, Question 25: “To what extent do you consider the progress of 
the operations financed by the following components of BMVI Instrument were achieved at a reasonable 
cost?”, 52 respondents. 

(80)  Targeted  survey  for beneficiaries,  Question  20:  “To  what  extent do  you  consider  the  progress  of  the 
operation(s) you implement / initiated under BMVI was achieved at a reasonable cost?”, 35 respondents. 

33 

 
 
 
programmes  are  being  implemented  efficiently  from  an  operational  point  of  view, 
since at the mid term stage, the programmes had committed an amount equivalent to 
the whole allocation in the previous instrument, ISF-BV. 

The shift from the implementation of the Home Affairs Funds from the previous Horizontal 
Regulation (81)  to  the  CPR  involved  several  changes  in  the  design,  management, 
monitoring and reporting of the Instrument, both at Commission and Member States level. 
This may have had a significant impact on the implementation rate of the programmes. 
Moreover, Member States BMVI programmes were allocated much higher EU amounts as 
compared to the previous programming period. As the implementation of the Instrument 
is  still  in  its  early  stage,  it  is  premature  to  draw  conclusions  on  the  efficiency  of  the 
management and control system. However, a first analysis at the financial implementation 
rate of the programmes activities may shed a first light on this point. 

By  mid-2024,  BMVI  Managing  Authorities  had  committed  an  amount  of  budget 
equivalent to the ISF-BV initial budget for Member States National Programmes (EUR 
1.591 billion for BMVI and EUR 1.551 billion for the ISF-BV). This seems to suggest that 
the Member States have been able to respond in an efficient manner to the challenge of 
mobilising the available funding. And this has happened in a context where the level of 
human  resources  involved  in  the  management  of  the  programmes  has  remained  stable, 
according to the evidence collected through the mid-term evaluations and the consultation 
of stakeholders. 

Figure 10: Situation at mid-term implementation (in million EUR) and implementation rates (in 
%) for Member States Programmes, ISF-BV and BMVI 

Source: Cohesion Open Data Portal, ISF-BV Interim Evaluation 

Moreover, BMVI’s financial implementation rate is at 30.7%, as compared to ISF-BV’s 
implementation  rate  of  38.1%  at  the  same  period  (mid-term).  Nonetheless,  financial 
implementation rates are widely diverging. Out of the 17 Member States that reported data 
in the annual performance report, BMVI implementation rates are higher than for ISF-BV 
in  the case of  ten  Member States (82). For the others, the budget  implementation  rate is 
lagging behind.  

(81)  Regulation (EU) No 514/2014 of the European Parliament and of the Council of 16 April 2014 laying 
down  general  provisions  on  the  Asylum,  Migration  and  Integration  Fund  and  on  the  instrument  for 
financial support for police cooperation, preventing and combating crime, and crisis management 

(82) Austria, Estonia, Finland, Italy, Hungary, Lithuania, Luxemburg, Latvia, Poland, and Sweden. 

34 

 
 
 
 
 
Table 5: Budget allocations and commitments for Member States Programmes (SO1 & 2), status 
March 2024 (EUR) 

Alternative budgetary baselines 

Allocated funds 

Commitments 
reported 

Implementatio
n rate 

Total allocations (excl. TA) (83) 

5 175 329 534 

1 591 013 812 

30.7 

Only  MS  reporting  progress  in  SFC2021 
(19) (84) 

3 954 290 784 

Only for SO where commitments were reported 
(SO1: 19, SO2: 1285) 

3 822 429 350 

Only for SO where commitments were reported, 
status March 2024 

3 476 860 320 

Source: European Commission - SFC2021 data 

.. 

.. 

.. 

40.2 

41.6 

45.8 

Figure 11 - Comparison of implementation rates between ISF-BV and BMVI at mid-term (30 June 
2017/2024), MS reporting data only 

Source: European Commission - SFC2021 data 

Almost all Member States have had higher implementation rates at the mid-term of BMVI 
than at the same period for ISF-BV - Romania and Germany being the exceptions (as well 
as Hungary and Slovakia, which did not report data through SFC2021, and Portugal that 
did not report either, but its ISF-BV implementation rate in 2017 was also null). Countries 
that have improved the most the implementation rate under BMVI compared to their mid-
term  financial implementation  rate for  ISF-BV include Croatia, Czechia, Finland, Italy, 
Latvia, Luxembourg and Sweden. Triangulated data from performance reports and mid-
term evaluation reports indicate that for Germany and Portugal the lagging behind stems 
at  least  partially from  the significant  delays in  the overall design  and approval  process. 
Germany's BMVI Programme was approved in November 2022 only. Although Portugal's 

(83) Funding allocated to Member States Programmes by 30 June 2024. 
(84) Countries: Austria, Belgium, Czechia, Germany, Denmark, Estonia, Greece, Finland, France, Hungary, 

Italy, Lithuania, Luxembourg, Latvia, Malta, the Netherlands, Poland, Sweden, Slovenia. 

85 Austria, Belgium, Czechia, Estonia, Greece, Finland, France, Hungary, Latvia, the Netherlands, Sweden, 

Slovenia. 

35 

 
 
 
 
BMVI Programme was validated in 2022, it had not been implemented by the end of 2023. 
From among the non-EU members, Iceland also faced delays: its participation had not been 
formalised within the Icelandic and EU legal frameworks by the end of 2023.  

Implementation  rates  are  perceptibly  different  between  Specific  Objectives.  The 
implementation rate on 30 June 2024 stood at 59.8% for SO 1 and at 50.2% for SO2. 
The analysis of available data on expenditures declared by operations shows differences 
as well: the absorption rate of the SO 1 is at 7.1%, compared to only 6.0% for SO 2. 

Figure 12: Absorption rates for BMVI, by Specific Objective (status 30 June 2024) 

Source: Cohesion Open Data Portal 

However, as mentioned before, possibilities for an analysis of the efficiency of spending 
under  BMVI  are  very  limited  at  this  stage.  Firstly,  progress  in  terms  of  physical 
achievements is modest for most indicators; declaration of eligible costs (i.e. reported upon 
receipt and checks by the competent authority) likewise. Secondly, reported outputs, and 
especially results, generally cannot be matched with concrete expenditure (eligible costs 
declared) under the Programme. Most indicators feed from different types of expenditure, 
and  one  type  of  expenditure  may  also  contribute  to  the  achievement  of  more  than  one 
indicator.  Nevertheless,  a  small  number  of  indicators  and  spending  categories  could  be 
matched and some considerations on unit costs could  be developed in  the retrospective 
evaluation. 

The assessment of the system's  architecture and design suggests that the system is 
structured  to  operate  with  efficiency.  Based  on  the  desk  research  and  stakeholder 
consultations conducted, management and control systems are designed with clearly 
assigned roles and responsibilities at both EU and national levels.  

At the EU level, the Commission, in collaboration with other authorities, coordinates and 
monitors the use of EU funds to guarantee the BMVI budget is spent appropriately. The 
involvement  of  multiple  actors  is  essential,  including  the  European  Anti-Fraud  Office 
(OLAF),  which  investigates  fraud  and  corruption,  and  the  European  Court  of  Auditors 
(ECA), which conducts audits to confirm the accuracy of EU expenditures and assess the 
performance  and  added  value  of  EU  policy.  Specialised  agencies,  such  as  Frontex,  eu-
LISA, play a specific role in border management and are involved in the oversight and 
assessment of measures financed through BMVI. 
36 

 
 
 
At  the  Member  State  level,  each  Member  State  has  designated  specific  authorities  or 
departments as Managing Authorities, Intermediate Bodies, Monitoring Committees, and 
Audit Authorities. These entities are responsible for the following: 

•  The  Managing  Authorities  are  responsible  for  managing  the  Member  States’ 
programmes,  selecting  operations  and  support  for  the  Monitoring  Committee. 
They are usually a part of the Ministry of Interior or an agency affiliated with it.  

• 

Intermediate  Bodies  are  designated  by  the  Managing  Authorities  to  perform 
certain tasks related to programme management. Their role is to facilitate the link 
between the Managing Authorities and the final beneficiaries of the funds.  

•  The  Monitoring  Committees  are  oversight  bodies  that  monitor  the  progress  of 
programme implementation and approve performance reports. They are composed 
of representatives of relevant public authorities and partners, including different 
ministries, police, immigration offices, and specialised agencies.  

•  At  the  national  level,  the  Audit  Authorities  are  responsible  for  auditing  the 

programmes and ensuring compliance with financial regulations. 

The  Member  States  and  stakeholder  consultations  have  highlighted  concerns 
regarding  the  administrative  burden,  which  may  affect  both  Management 
Authorities and beneficiaries.  

Insights  from  mid-term  evaluations  across  the  Member  States  and  stakeholder 
consultations have highlighted concerns regarding the administrative burden, which affects 
both  Management  Authorities  and  beneficiaries.  This  burden  is  attributed  to  a  range  of 
factors, such as the complex legal requirements and the need for extensive documentation 
and reporting.  The administrative requirements have proven particularly  demanding for 
beneficiaries, which find it difficult to keep up with reporting requirements due to their 
modest staffing resources. 

These findings are supported by the targeted surveys which show that national authorities 
find regulatory requirements, the complexity of the information obligations, and the time 
spent  in  fulfilling  reporting  obligations  particularly  burdensome.  For  a  specific 
representation of these findings, please refer to figure 13.  

37 

 
 
Figure  13:  Aspects  perceived  as  burdensome  by  national  authorities  (52  respondents,  312 
responses) 

Source: Targeted survey for national authorities 

According to the targeted survey, beneficiaries also face similar issues, though to a lesser 
degree, with the complexity of the information obligations and procurement procedures 
being  identified  to  pose  challenges  on  their  activity,  as  shown  in  figure  13.  The 
administrative  requirements  have  proven  particularly  demanding  for  smaller  entities, 
which find it difficult to keep up with reporting requirements due to their modest staffing 
resources. 

Figure 14: Aspects perceived as burdensome by beneficiaries (35 respondents, 210 responses) 

Source: Targeted survey for beneficiaries 

The Commission is taking the concerns of the Member States seriously and concrete efforts 
to  mitigate these issues  are  ongoing,  with  most Member States implementing measures 

38 

 
 
 
 
such as simplified cost options (e.g. flat-rate options and standard cost unit rates) and the 
new electronic data exchange systems to streamline processes (e.g., AMBIS in Belgium, 
MMIS in  Bulgaria, EUSA2 in  Finland and MCIS  in  Malta). While these simplification 
measures are in the early stages of implementation and may initially impose an additional 
administrative burden as individuals learn to adapt to new ways of working, the objective 
is that they will lead to beneficial outcomes. Stakeholders indicated that, to some extent, 
the  administrative  burden  will  reduce,  once  they  adapt  to  new  regulatory  and 
reporting requirements, as well as new ways of working. To facilitate the transition and 
enhance  user  proficiency,  training  programmes  are  being  provided  through  technical 
assistance. 

In  relation  to  the  required  administrative  procedures,  various  types  of  costs  have  been 
identified. As detailed in the subsequent sections and further elaborated in Annex IV, these 
include one-time adjustment costs for compliance with the CPR. Additionally, recurrent 
administrative  costs  arise  from  additional  administrative  burdens  faced  by  national 
authorities  and  beneficiaries  due  to  the  complexities  of  implementing  simplified  cost 
options. Despite these challenges, desk research and stakeholder consultations indicate that 
the  costs  are  outweighed  by  a  range  of  direct  and  indirect  benefits  for  authorities, 
beneficiaries,  and  target  groups.  However,  since  there  are  no  mechanisms  in  place  for 
systematically reporting costs related to the administrative burden, this hinders the ability 
to quantify these administrative costs accurately. Given this limitation, an overview of the 
costs  and  benefits  is  detailed  in  Annex  IV,  while  the  sections  below  provide  specific 
information  regarding  costs  related  to  workload,  the  human  resources  required  for 
implementation, encountered challenges, and the benefits that outweigh these costs. 

In relation to the administrative procedures to be followed, a series of types of costs and 
benefits occurred. With regards to the direct compliance costs, adjustment costs represent 
one-off expenses associated with the time and resources required for stakeholders to adapt 
to the changes introduced by the Common Provisions Regulation (CPR), as the objectives, 
scope, and structure of the Fund and Member States Programmes. Additionally, recurrent 
administrative  costs  emerged  due  to  increased  information  requirements  necessary  for 
compliance with monitoring and reporting obligations under the CPR. This included the 
additional  administrative  burden 
the 
methodological  complexities  of  implementing  simplified  cost  options  and  the  effort 
required to adapt to new electronic data exchange systems. Furthermore, enforcement costs 
were noted, encompassing recurrent expenses associated with monitoring activities. This 
are  linked  to  the  costs  related  to  providing  guidance  materials  and  trainings  for 
beneficiaries  to  use  the  new  electronic  data  exchange  systems.  Indirect  costs  were  not 
found.  

for  direct  beneficiaries  stemming 

from 

On the authorities’ side, it is expected that the standardization of CPR across ESI Funds 
and the development of electronic data exchange systems for monitoring will reduce the 
administrative burden in the future. On the side of direct beneficiaries, it is expected that 
in time, the benefits of using the new electronic data exchange systems and standardized 
reporting will improve the situation.  

The  actions  supported  through  the  Fund  will  facilitate  legitimate  border  crossing,  the 
detecting  of  illegal  immigration  and  cross-border  crime,  as  well  as  the  effective 
management of migratory flows. The Fund will also support the harmonised approach to 
the issuance of visas, facilitate legitimate travel, while helping to prevent migratory and 
security risks. However, given the state of implementation of the Fund, such benefits may 
yet be fully quantified as the implementation of the projects has only recently started.  

39 

 
 
Indirect benefits are also anticipated, including improved integration and a more uniform, 
standardized approach resulting from the implementation of the ESI Funds and the Home 
Affairs  Funds  under  the  CPR.  This  will  support  the  harmonised  application  of  Union 
acquis  and strengthen  effective European integrated border management  at  the Union’s 
external  borders. Furthermore, there will be increased and more effective cross-country 
cooperation in the areas of border management and visa issuance. 

Regarding the Thematic Facility, the design of the Specific Actions belongs to the Member 
State applying to the Commission calls for the expression of interest and needs to comply 
with  the  call  specifications.  It  also  belongs  to  the  Member  State  to  make  sure  that  its 
application is complementary with the BMVI programme and other EU funding, so that it 
can be integrated without overlaps. This requires a strategic approach to the development 
of  Specific  Actions  which  should  be  designed  to  complement  regular  interventions. 
According to the evidence collected, this understanding is not yet fully developed in all 
Member States, which may have led to inefficiencies such as potential overlaps in terms 
of  scope  or  timeline  between  the  measures  under  the  Member  States  Programmes  and 
Specific Actions within the Thematic Facility.  

Specific Actions are greatly appreciated for their advantages in terms of flexibility 
and provision of ad-hoc additional funding for specific priority interventions.  

Overall, Managing Authorities and beneficiaries gave positive feedback and are keen to 
make  further  use  of  them.  However,  some  cases  of  gold-plating,  where  participating 
countries have added administrative burden to the process of application for the Specific 
Actions, have been identified. According to the case studies, in some Member States, when 
the Specific Action has been awarded and integrated in the programme, the beneficiaries 
need to apply again for the funding. In those cases, the flexibility of the Thematic Facility 
is clearly affected. 

Technical  assistance  is  consistently  appreciated  as  a  positive  contribution  to  the 
effective and efficient implementation of management and control systems. 

Technical assistance is intended to provide financing for carrying out, inter alia, functions 
such  as  preparation,  training,  management,  monitoring,  evaluation,  visibility  and 
communication.  Even  if  presented  as  a  separate  objective,  Technical  Assistance  is 
provided in the form of lump sum amounts of 6% to the eligible expenditure included in 
each payment application (86).  

The targeted surveys conducted (87) show a high appreciation of this support, with 52% of 
the Managing Authorities who replied having received technical assistance from BMVI, 
with  over  half  reporting  a  significant  positive  impact  on  their  management  and  control 
systems.  Among  the  beneficiaries (88),  20%  received  assistance,  with  86%  noting  a 
substantial improvement in their systems, highlighting the value of technical support. For 
instance, data from the conducted country case studies indicate that technical assistance is 
used in Croatia, Italy, and Romania for the development of electronic systems and provide 
user  training  to  streamline  management  and  control  processes.  In  Greece,  technical 
assistance has been used to restructure the Managing Authority to make it more efficient 

(86) Article 36 of CPR. 
(87) Targeted survey for national authorities, Question 27: “Did you receive technical assistance under the 

Member State Programme funded by BMVI?”, 52 respondents 

(88) Targeted survey for beneficiaries, Question 25: “Did you receive technical assistance in the context of 

the operations implemented / initiated under BMVI?”, 35 respondents 

40 

 
 
 
and to help speed up the procurement processes. In Italy, technical assistance has improved 
the guide that outlines how projects should be managed and monitored (Operations Manual 
of Procedures) and supported a service (Technical-Administrative Secretariat help desk) 
that quickly addresses the need for simplifying procedures, making it easier to navigate the 
programme's requirements. 

Challenges related to administrative workload and organisational bottlenecks have 
delayed the start and implementation of activities.  

The initial challenges in implementing BMVI were primarily due to the delayed approval 
of Member State programmes in 2022, linked both to the development of the programme 
at national level, and the validation and discussion process between the Commission and 
Member States. In several Member States, the late approval of the BMVI programmes, 
including the funding plan, application opening, project selection, and implementation of 
the performance framework, postponed the granting of projects and extended the overall 
implementation timeline.  

Additionally,  as  mentioned  above,  human  resource  issues  have  had  an  impact  in  the 
efficient implementation of the programmes. In some cases, they were related to lack of 
staff. In other cases, there was the need for staff to become sufficiently skilled to manage 
the workload of activities required to manage and monitor such programmes benefitting of 
a  significantly  increased  allocation.  Staff  resources  seem  to  have  remained  overall 
constant,  and  this  situation  appears  to  have  led  to  difficulties  in  handling  the  sourcing, 
assessment  and  selection  of  projects.  However,  the  instrument  is  designed  to  support 
measures  that  assist  human  resources  through  the  technical  assistance  component.  As 
previously  mentioned,  in  Italy,  technical  assistance  has  been  employed  to  enhance  the 
management and monitoring and to support a helpdesk that swiftly responds to the need 
for  procedural  simplification,  thereby  facilitating  easier  navigation  of  the  program's 
requirements.  

In some cases, the lack of skilled staff, coupled with the heavy workload, has  hindered 
their  ability  to  seek  out  innovative  projects,  resulting  in  a  lack  of  diversity  in  project 
content. In some countries, national authorities have struggled to source and select projects 
that are both innovative and relevant. This occasional lack of projects has contributed to 
the  slow  pace  of  BMVI  implementation.  In  France,  Hungary,  and  Italy,  Managing 
Authorities faced this kind of challenges in selecting relevant and innovative beneficiaries. 

The  challenges  related  to  administrative  workload  and  organisational  bottlenecks  also 
influence costs. The review of Annual Implementation Reports confirms that direct labour 
costs  and  the  time  devoted  to  completing  activities  have  been  impacted  by  the 
administrative burden and the need for additional training and capacity building, as noted 
by  France  and  Greece.  As  already  mentioned,  the  absence  of  mechanisms  for 
systematically reporting costs associated with the administrative workload at the Member 
State level limits the possibility to quantify these expenses. 

Managing authorities know about the simplification possibilities in the CPR, but are 
not fully aware of how they work, which leads to a limited buy-in in some cases. 

The  evaluation  has  identified  two  areas  for  developing  simplification  strategies  in  the 
implementation of the fund: 

• 

Increasing the use of simplified cost options and financing not linked to costs; 

41 

 
 
• 

Implementing and improving electronic data exchange systems and other IT 
systems to reduce delays and administrative burdens. 

As mentioned above, the general knowledge about the simplified forms of grant funding 
is  counterbalanced  by  a  general  perception  of  potential  burden  in  applying  them,  and 
therefore there is room for development in this sense.  

Simplified cost options streamline administrative processes for Member States, allowing 
to  focus  on  policy  objectives  rather  than  administrative  requirements.  They  aid  small 
entities, minimise error risks, enhance  fund efficiency, and  adapt  to  economic changes. 
Simplified cost options also permit the adoption of established EU or national calculation 
methods  and  cover  operations  such  as  public  procurement  expenses (89).  A  significant 
number  of  Member  States  (14)  stated  that,  from  the  adoption,  the  Member  States 
programmes would make use of adopted simplified cost options / financing not linked to 
costs (90).  For  example,  Czech  Republic  and  Romania  have  implemented  simplified 
reporting  methods  including  unit  cost  reporting  for  wage  expenses,  reducing  the 
administrative load for beneficiaries and Managing Authorities. This method emphasises 
key control samples over exhaustive verification, enhancing project efficiency. 

Indirect  benefits  are  also  anticipated  on  medium  and  long  term,  including  improved 
integration and a more uniform, standardised approach resulting from the implementation 
of the European Structural and Investment Funds and the Home Affairs Funds under the 
CPR.  This  will  support  the  harmonised  application  of  Union  acquis  and  strengthen 
effective  European  integrated  border  management  at  the  Union’s  external  borders. 
Additionally,  enhanced  and  more  effective  cross-country  cooperation  in  border 
management and visa issuance is expected. 

Stakeholder  consultations  suggest  an  extended  use  of  simplified  cost  options,  even  in 
Member States that have not declared the use of simplified cost options from the adoption 
of the programme. The targeted survey results (91) support the finding, showing that a third 
of  the  Managing  Authorities  declare  they  implemented  simplification  measures  in  the 
programmes funded by BMVI. According to the CPR, where the total cost of an operation 
does not exceed EUR 200 000, the contribution provided to the beneficiary from the BMVI 
shall take the form of unit costs, lump sums or flat rates. However, the influence of this 
provision in the buy-in of simplified cost options has not been ascertained. 

Despite  these  efforts,  the  perceived  effectiveness  of  these  measures  in  simplifying 
programme  management  procedures  was  considered  modest,  with  a  significant  part  of 
respondents reporting only a low (28,1%) to moderate (25%) level of simplification.  

Some  stakeholders  reported  the  use  of  simplified  cost  options  is  hindered  by  the 
methodological complexity of formulating standardised rates that capture the varied costs 
across  different  regions,  sectors  and  types  of  projects.  Moreover,  determining  the 
appropriate rates for simplified cost options may involve complex calculations that account 

(89) Commission Notice Guidelines On The Use Of Simplified Cost Options Within The European Structural 

And Investment Funds (Esi) (2021/C 200/01) 

(90)  Austria,  Belgium,  Cyprus  Czech  Republic,  Denmark,  Spain,  Finland,  France,  Croatia,  Hungary, 

Luxembourg, Malta, Poland, Slovenia). 

(91) Targeted survey for  national authorities, Question 28: “Were simplification measures (e.g., simplified 

cost options) used into the Programmes funded by ISF -BV and BMVI Instruments?”, 52 respondents 

42 

 
 
 
for  historical  data,  statistical  analysis,  and  projections  of  future  costs,  which  presents  a 
substantial challenge for potential users. 

Moreover,  Commission’s  exchanges  with  Managing  Authorities  seem  to  show  that 
financing not linked to cost is a modality that is not fully understood by the Member States. 
This was obvious during the negotiations for the EMAS assistance for Member States at 
the  forefront  of  the  Ukrainian  crisis.  The  idea  of  financing  not  associated  to  the 
reimbursement of any specific type of costs requires a change in mentality. 

It is worth noting that a substantial share (46.3%) of the participants in the surveys were 
either uncertain about the existence of simplification measures or preferred not to respond, 
indicating a possible lack of awareness. 

The establishment of IT systems at Managing Authority level is a promising way of 
ensuring more streamlined communication and reporting, shortening the duration of 
the processes and the administrative workload.  

Member States (92) have implemented or are in the process of developing new IT systems, 
as the CPR requires the Managing Authority to set up electronic data exchange systems 
between programme authorities and beneficiaries (93). Some examples include the AMBIS 
platform  in  Belgium,  the  MMIS  system  in  Bulgaria,  the  FIMAS  accounting  system  in 
Cyprus,  the  E-Synergie  platform  in  France,  and  the  ROFED  computerised  system  in 
Romania.  These  systems  are  used  for  project  management,  reporting,  data  storage, 
communication, and simplification of administrative processes. 

As noted above, as the IT systems are still in the early stages of testing and user adoption, 
their contribution to implementation efficiency cannot be measured yet but are showing 
preliminary  benefits.  According  to  the  country  case  studies  conducted  as  part  of  the 
evaluation, the initial experiences with electronic data exchange platforms across various 
countries have been promising, indicating their potential to streamline processes.  

These  preliminary  gains  include  improved  data  sharing  and  communication  among 
involved parties, reduced reliance on paper-based processes, and the potential for enhanced 
transparency and accountability in programme management. However, many countries are 
in the early stages in the adoption of such technologies, and as with any innovation, there 
is a natural period of adjustment. As these systems continue to be developed and integrated, 
it is expected that they will further facilitate coordination between the national authorities 
and beneficiaries. 

At  these  initial  stages,  there  is  possibly  a  higher  administrative  burden  linked  to  the 
necessary learning process for getting the systems fully functioning. The increased effort 
required  to  implement  and  adapt  to  new  electronic  data  exchange  systems  results  in 
administrative costs. Additionally, as these platforms continue to evolve, ongoing technical 
assistance  and  accessible  training  will  be  essential  in  enabling  users  to  become  more 
comfortable and proficient, thereby maximising the benefits of these systems. This will 
also incur recurring enforcement costs, which encompass expenses related to the provision 
of  guidance  materials  and  training  for  beneficiaries  on  the  effective  use  of  the  new 
electronic data exchange systems. As noted in Annex IV, in the long term, the benefits of 

(92) Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Greece, Malta, 

Poland, Romania, Slovenia, Spain 

(93)  Article 69(8) and Annex XIV CPR. 

43 

 
 
 
implementing  these  new  IT  systems  are  expected  to  outweigh  the  incurred  costs.  The 
introduction  of  these  electronic  data  exchange  systems  for  monitoring  is  anticipated  to 
reduce  the  administrative  burden,  leading  to  enhanced  oversight  of  the  Fund’s 
implementation  and  ultimately  improving  the  efficiency  and  effectiveness  of  resource 
allocation. 

4.1.3. 

Coherence  

The  assessment  of  coherence  refers  to  the  assessment  of  both  internal  and  external 
coherence of BMVI. The internal coherence of BMVI relates both to the internal coherence 
of the Fund components and management modes and how interventions generate synergies 
through  formal  or  informal  cooperation  (EQ9).  The  assessment  of  external  coherence 
assesses the complementarities and synergies between BMVI and other EU policies and 
priorities, other Home Affairs Funds and other EU funding instruments (EQ10). 

Coherence between the components of the instrument 

The  assessment  of  coherence  refers  to  the  assessment  of  both  internal  and  external 
coherence of BMVI. The internal coherence of BMVI relates both to the internal coherence 
of the Fund components and management modes and how interventions generate synergies 
through  formal  or  informal  cooperation  (EQ9).  The  assessment  of  external  coherence 
assesses the complementarities and synergies between BMVI and other EU policies and 
priorities, other Home Affairs Funds and other EU funding instruments (EQ10). 

BMVI’s  architecture  enhances  internal  coherence  by  fostering  complementarity 
across  components.  The  combination  of  the  four  components  of  the  instrument 
(Member  State  programmes,  Specific  Actions,  Emergency  Assistance  and  Union 
Actions)  and  the  three  management  modes  (shared,  direct  and  indirect)  enables 
flexible fund management. 

44 

 
 
Table 6: Management mode and components in BMVI according to the legal base 

Purpose 

Shared 
management 

Direct 
management 

Indirect 
management 

Member 
Programmes 

States 

Thematic  facility: 
Specific Actions* 

/ 

/ 

/ 

/ 

Thematic facility: emergency assistance* 

/ 

Thematic facility: Union Actions 

7-years strategy for the contribution of 
the  fund  to  the  specific  objectives  of 
BMVI  at  participating  country  level 
(Art.  13)  (NB 
including  possible 
contributions from the thematic facility 
– Specific Actions) 

Transnational or national projects that 
bring Union added value in accordance 
with  the  objectives  of  the  instrument 
for  which  one,  several  or  all  Member 
States  may  receive  an  additional 
allocation  to  their  programmes  (Art. 
2.8).  Identified  on  an  on-going  basis 
the 
delivered 
and 
Commission’s  Thematic 
Facility 
multi-annual work programmes 

through 

Address  urgent  and  specific  needs  in 
the  event  of  duly  justified  emergency 
situations (Art.  25), delivered through 
Commission’s  Thematic 
Facility 
multi-annual work programmes 

Transnational  projects  or  projects  of 
particular  interest  to  the  Union  (Art. 
2.10)  identified  on  rolling  basis  and 
delivered  through  the  Commission’s 
Thematic  Facility  multi-annual  work 
programmes 

Source: Regulation (EU) no 2021/1148, Note: *Where Specific Actions and emergency assistance 
is  delivered  through  shared  management  in  the  Member  States  Programmes,  it  must  be  duly 
earmarked. 

This mixed architecture, with the creation of the Thematic Facility, is an innovation of the 
2021-2027 Home Affairs Funds. It is meant to ensure a right balance between a long-term 
capacity-building  strategy  around  the  objectives  of  the  Regulation,  and  the  need  for 
punctual flexibility in order to face unforeseen events or new policy developments. This 
approach is largely well perceived by the stakeholders. The survey of national authorities 
showed the vast majority consider the fund structure to positively contribute to ensuring 
complementarities (85-90% considering it to have contributed at least to some extent, or 
to a large or very large extent). The survey of “other stakeholders” shows similar findings 
(80-86% considering it to have contributed at least to some extent, or to a large or very 
large extent). 

The  complementary  nature  of  the  Thematic  Facility  components  has  been  positively 
assessed in the Member States mid-term evaluation reports on BMVI implementation. This 
is further confirmed by the replies to the surveys to which national authorities and other 
stakeholders participated. Examples from the country case studies show concretely how 
the different funding modalities can be used to complement each other. For instance, in 
Poland, a Specific Action was used to support the building of technical protection of the 
EU's external border in wetlands, coastal areas and rivers along the Polish-Belarusian state 

45 

 
 
border  and  the  modernisation  of  the  radio  communication  system.  The  funding  was 
ultimately insufficient to cover the entirety of the concerned border length, so an additional 
complementary project was included in the programme to cover the remaining part of the 
external  border  across  the  Świsłocz  and  Istoczanka  rivers.  In  other  cases,  the  Specific 
Actions are used to complement Member States Programmes.  

However,  as  mentioned  above,  the  strategic  approach  to  complementarity  between 
Specific  Actions  and  the  regular  actions  in  the  programmes  does  not  seem  to  be  fully 
developed in some countries (94), leading to a risk of overlap.  

The evaluation has also brought forward examples of complementarity between the Union 
Actions and the other components of the instrument, with projects providing added value 
by testing  approaches  for future development  in  the frame of standard programming  or 
policy  making.  For  instance,  this  was  the  case  for  the  so-called  “DTC  pilots”,  which 
supported the added value of digitalisation and remote checking of travel document, as a 
way of speeding up the procedures. However, the transnational character of Union Actions) 
are  reportedly  a  challenge  for  some  national  authorities  who  are  not  used  to  working 
systematically outside their national context (95). 

There  are  formal  and  informal  mechanisms  in  place  to  ensure  complementarities 
and,  where  relevant,  synergies  across  the  different  components  but  these  could  be 
strengthened, particularly for Union Actions.  

Formal mechanisms are in place to ensure the Thematic Facility (delivered through multi-
annual  work  programmes  developed  by  the  European  Commission)  complements  the 
support delivered through the Member States Programmes (developed by Member States 
in consultation with the European Commission at the start of the programming period) at 
the EU and national level.   

At EU level there is a designated coordination unit in DG HOME, which ensures there is 
a clear consultation process where the relevant geographic and policy units feed into the 
decision-making processes (i.e. drawing up the multi-annual work programmes). Possible 
complementarities  across 
through  different  components  and 
funding  provided 
management modes should therefore be ensured.  

Additionally,  the  Thematic  Facility  Steering  Group  (TFSG)  composed  of  DG  HOME 
Senior  management  is  responsible  for  the  overall  planning  and  monitoring  of  the 
implementation of the Specific Actions and the related budget. The TFSG validates the 
proposals for selection, based on the selection by the individual Specific Action Steering 
Committees (SASC) and takes decisions on the final budget allocation resulting from the 
outcome of the evaluation of the calls,  bearing in mind the implementation of all other 
strands of the Thematic Facility work programme.  

The  Working  Group  on  Specific  Actions  (WGSA)  is  responsible  for  the  overall 
coordination, planning and support of all SASCs. 

(94) For example: Poland, Bulgaria, Italy, and Romania. 
(95) As exemplified in discussions with national authorities in several countries for the country and thematic 
case studies conducted in the context of the preparatory study. Discussions revealed the organisational 
challenges  and  difficulty  prioritising  transnational  work  in  view  of  competing  demands.  It  is  worth 
noting that this challenge is not relevant for some Union Actions,  direct awards are also possible and 
these do not require a transnational component.  

46 

 
 
 
Other Commission services are consulted in the preparation of the Thematic Facility work 
programmes  through  the  interservice-consultation  process.    Finally,  the  Home  Affairs 
Committee approves the Thematic Facility Work Programme and has to give a positive 
opinion to all substantial amendments to it. 

At the national level, complementarity is ensured by the requirement to have a monitoring 
committee, which has oversight of all the support delivered at national level. The extent to 
which  complementarities  are  ensured  also  depends  on  the  day-to-day  coordination 
mechanisms at national level which are the responsibility of the Managing Authority. The 
national  midterm  evaluation  reports  indicate  that  this  coordination  is  almost  always 
assessed positively. However, as usual, this assessment varies from case to case.  

In some cases, stakeholders have pointed to a slight mismatch between the approach for 
Specific Actions and Union Actions, in the sense that Member States are not consulted ex 
ante  about  Union  Actions  in  the  manner  they  are  for  Specific  Actions.  However,  it  is 
important to note that each type of action is implemented in a different management mode. 
As  Specific  Actions  run  in  shared  management,  they  need  to  be  integrated  into  the 
programme. They need to be checked regarding the complementarity and lack of overlap 
with  the  interventions  in  the  programme,  which  may  only  happen  at  the  level  of  the 
Managing Authority. This is not the case for the Union Actions, which are implemented 
by  the  Commission  (in  direct  or  indirect  management  mode)  and  selected  by  the 
Commission  in  the  form  of  direct  awards  or  calls  for  proposals.  Even  so,  the  work 
programmes  for  the  Thematic  Facility  that  include  a  description  of  the  planned  Union 
Actions are submitted to the Home Affairs Funds Committee, where Managing Authorities 
are represented, for initial approval and any substantial amendment.  

When it comes to Union Actions, informal processes are in place to encourage the take up 
of  outputs  of  Union  Actions  in  Member  States  programmes.  Beneficiaries  of  Union 
Actions are encouraged to seek funding from national authorities to follow up innovative 
actions and activities once their grants end (e.g. to integrate the activities into the Member 
States  Programmes,  to  provide  national  funding  or  to  apply  the  results  into  policy 
measures).  

The use of events can encourage networking and ensure these synergies are exploited (96): 
not least, the event organised by DG HOME on 25 June 2024 to facilitate networking. This 
event brought together over 300 beneficiaries of HOME funds in the fields of migration, 
border  management  and  security,  gathering  in  Brussels  together  with  the  EU  national 
authorities managing the Funds (97). 

The BMVI is coherent with the different components of the border management and 
visa policy and contributes to support them. 

During  the  implementation  of  BMVI  (2021-2027),  the  following  EU  policies  and 
priorities, and related actors, are of particular relevance:  

(96) Interview with beneficiary and observational data from participation at event. 
(97)  See  https://home-affairs.ec.europa.eu/news/european-commission-helps-eu-funded-projects-migration-

security-and-borders-strive-excellence-2024-06-26_en.  

47 

 
 
 
•  The European Border and Coast Guard Regulation (EBCG) (98), which strengthened the 
Frontex mandate, and set out rules on EUROSUR (which is the integrated framework 
for information exchange and cooperation between the Member States and Frontex).  

•  The revised EU’s Visa Code (amended in 2019 (99), 2021 (100) and 2023 (101)) and the 
2021 Schengen Strategy (102), which proposes further actions to make the area without 
internal border controls fully functioning and more resilient. They set out the priorities 
in the area of visa policy, including the digitalisation of external border management 
(i.e. the EES, ETIAS and revisions to SIS and VIS), the digitalisation of the visa, as well 
as the need or a revised Schengen Borders Code.  

•  The  2023  European  Integrated  Border  Management  Strategy (103),  covers  the  EIBM 
dimension  and  defines  policy  priorities  and  strategic  guidelines  for  each  of  the  15 
components of EIBM set out in the 2019 EBCG Regulation (see figure 15). One of the 
components is dedicated to solidarity mechanisms (Component 12), under which BMVI 
is  specifically  highlighted  as  the  tool  to  achieve  the  effective  implementation  of  the 
EIBM Strategy, together with AMIF.  

•  The new EU Asylum and Migration Pact, which will apply from 2026, and its Common 
Implementation  Plan (104)  will  require  a  significant  change  in  the  approach  to  border 
management procedures and will, therefore, have an impact on funding through BMVI. 

According to the BMVI Regulation (105), the Instrument should complement and reinforce 
the  activities  implementing  European  integrated  border  management  in  line  with  the 
principle  of  shared  responsibility  and  solidarity  between  the  Member  States  and  the 
European Border and Coast Guard Agency, which represent the two pillars of the European 
Border and Coast Guard. 

The 2023 evaluation of the EBCG Regulation (106) did not specifically assess the coherence 
of  the  Regulation  with  BMVI.  However,  the  BMVI  Regulation  includes  numerous 

(98)Regulation (EU) 2019/1896 of the European Parliament and of the Council of 13 November 2019 on the 
European Border and Coast Guard and repealing Regulations (EU) No 1052/2013 and (EU) 2016/1624 
(99)  Regulation  (EC)  No  810/2009  establishing  the  EU’s  Visa  Code;  Regulation  (EU)  2019/1155  of  the 
European  Parliament  and  of  the  Council  of  20  June  2019  amending  Regulation  (EC)  No  810/2009 
establishing a Community Code on Visas (Visa Code) (OJ L 188, 12.7.2019, p.25) 

(100) Regulation (EU) 2021/1134 of the  European Parliament and of the Council of 7 July 2021 amending 
Regulations (EC) No 767/2008, (EC) No 810/2009, (EU) 2016/399, (EU) 2017/2226, (EU) 2018/1240, 
(EU) 2018/1860, (EU) 2018/1861, (EU) 2019/817 and (EU) 2019/1896 of the European Parliament and 
of the Council and repealing Council Decisions 2004/512/EC and 2008/633/JHA, for the purpose  of 
reforming the Visa Information System 

(101) Regulation  (EU)  2023/2667  of  the  European  Parliament  and  of  the  Council  of  22  November  2023 
amending  Regulations  (EC)  No  767/2008,  (EC)  No  810/2009  and  (EU)  2017/2226  of  the  European 
Parliament  and  of  the  Council,  Council  Regulations  (EC)  No  693/2003  and  (EC)  No  694/2003  and 
Convention implementing the Schengen Agreement, as regards the digitalisation of the visa procedure 
(102) Communication from the Commission to the European Parliament and the Council "A strategy towards 

a fully functioning and resilient Schengen area" 

(103)  Communication  from  the  Commission  to  the  European  Parliament  and  the  Council  establishing  the 

multiannual strategic policy for European integrated border management, COM(2023) 146 final 

(104) Communication from the Commission to the European Parliament, the Council, the European Economic 
and Social Committee and the Committee of the Regions Common Implementation Plan for the Pact on 
Migration and Asylum, COM/2024/251 final 
(105) Recital 20 and Article 3(2(a)) BMVI Regulation 
(106)  European  Commission,  Study  to  support  the  evaluation  of  the  EBCG  Regulation  and  review  of  the 

Standing Corps, July 2023. 

48 

 
 
 
references  on  coordination  with  Frontex  Funded  actions  need  (i)  to  be  aligned  to  the 
components of the EIBM as defined under the ECBG Regulation (107), (ii) contribute to 
the development of operational capabilities of the EBCG (108) and (iii) be aligned with the 
standards set in the EBCG Regulation (109). 

Coherence between EBCG and BMVI is  foreseen through the Member  State capability 
roadmaps, which are adopted in pursuant with Article 9(4) of the EBCG Regulation, and 
which should inform the planning of actions under the BMVI Member States programmes 
(see also under section 4.3 on Relevance).   

As regards the Thematic Facility, a call for a Specific Action for the purchase of equipment 
to  be  made  available  to  Frontex  was  launched  in  2021.  This  action  shows  the 
complementarity  of  the  work  between  Frontex  and  the  Commission,  since  the 
specifications for the call were drafted based on the technical assessment of its own needs 
made by Frontex, which was also involved in the award process. 

Specific  coordination  mechanisms  exist  to  ensure  the  coherence  of  BMVI  actions  that 
relate to Frontex. The EBCG Regulation and BMVI Regulation provide that BMVI should 
contribute to the development of operational capabilities of the EBCG, with the Member 
States  capability  plans  as  one  tool  to  ensure  coherence.  The  EIBM  Strategy  further 
indicates  that  “close  cooperation  between  the  Commission  and  Frontex  should  ensure 
synergies between Frontex activities and actions funded by other EU funding instruments 
and avoid double financing”. In practice, Frontex was consulted when adopting the BMVI 
programmes and, according to the established procedure for programme amendments, is 
consulted on the BMVI programme amendments "introducing operating support". Frontex 
can also be invited as an observer in the assessment of applications for Specific Actions, 
Union Actions or EMAS. In addition, the Frontex Management Board (consisting of all 
national authorities and DG HOME) also serves as a forum where Member States discuss 
emerging and future needs and how these needs can be best addressed  – either through 
national actions, by Frontex and/or with the support of Home Affairs funds. The Frontex 
Management  Board  has  set  up  a  specific  task  force  to  that  effect.  Some  stakeholders 
consulted  highlighted  the  need  to  further  strengthen  the  link  between  BMVI  and  the 
national capability roadmaps to ensure continued coherence of the BMVI with the EBCG 
Regulation and EIBM Strategy. 

BMVI is coherent with the revised Visa Code and Schengen Strategy, since it supports the 
interoperability  of  information  systems  and  the  ongoing  digitalisation  of  the  visa 
procedure,  therefore  helping  Member  States  to  cope  with  the  increased  numbers  of 
travellers to the EU and reinforce the security of the Schengen area. Examples from the 
country  case  studies,  such  as  the  research  in  Norway,  confirm  that  this  support  can  be 
observed in practice. The recently published evaluation of the Visa Code (110) concludes 
that  the  Visa  Code  amendments  are  internally  coherent  and  complementary  with  the 
general  orientation  and  specific  policy  interventions  at  EU  level  in  the  field  of  border 
management,  while  not  entailing  a  specific  assessment  of  the  coherence  with  BMVI. 

(107) See Annex II (1)(a) BMVI Regulation, referring to Article 3(1) of the EBCG Regulation 
(108) Point 1(b) of Annex II, and (1) of Annex IV, BMVI Regulation 
(109) E.g standards for IT and equipment, see Article 13(14)(a)BMVI Regulation or European educational 
and common training standards for border and coast guards, see Article 13(16) BMVI Regulation 
(110)  Commission  Staff  Working  Document,  Evaluation,  EU  visa  policy  –  evaluation  of  the  Visa  Code, 

Brussels, 19.4.2024 SWD(2024) 108 final 

49 

 
 
 
Looking  ahead,  BMVI  is  also  on  track  to  remain  coherent  with  the  new  rules  on  the 
digitalisation of the Schengen Visa process. (111) 

Coherence with the European Integrated Border Management Strategy  

Figure 15: The 15 components of European Integrated Border Management (112) 

Source: Based on Annex I: EIBM Components of COM(2023) 146 final 

BMVI  is  also  coherent  with  the  EIBM  Strategy,  since  the  objectives  of  BMVI  support 
correspond to the different components of the EIBM Strategy.  

Table  7  maps  the  relevant  operational  objectives  from  BMVI  (based  on  the  detailed 
intervention  logic)  to  each  EIBM  component.  It  shows  that  the  BMVI  was  meant  to 
contribute to all elements of the EIBM, with some objectives directly relevant to a specific 
component,  while  for  others  (e.g.  component  11  quality  control  mechanisms  and  13 
Fundamental Rights) all BMVI objectives contribute in a more horizontal way. 

Table 7 - Mapping of BMVI implementation measures in relation the EIBM 

Components EIBM 

BMVI Implementation measures (113) 

Border Control 

Search and Rescue 

Risk Analysis 

1(a): Improvement of border control 

1(f):  Increasing  capacity  to  render  assistance  to  persons  in 
distress at sea 

1(g): Support to search and rescue operations in the context of 
carrying out border surveillance at sea. 

1(a)(iii): Improvement of external border control: analysis of 
the  risks  for  internal  security  and  threats  affecting  external 
border security 

(111)https://www.consilium.europa.eu/en/press/press-releases/2023/11/13/council-gives-green-light-to-the-

digitalisation-of-the-visa-procedure/?utm_source=dsms-
auto&utm_medium=email&utm_campaign=Council+gives+green+light+to+the+digitalisation+of+the
+visa+procedure  and European Commission, Proposal for a Regulation of the European Parliament and 
of the Council amending Regulations (EC) No 767/2008, (EC) No 810/2009 and (EU) 2017/2226 of the 
European Parliament and of the Council, Council Regulations (EC) No 1683/95, (EC) No 333/2002, 
(EC) No 693/2003 and (EC) No 694/2003 and Convention implementing the Schengen Agreement, as 
regards the digitalisation of the visa procedure, COM/2022/658 final. 

(112) Communication from the Commission to the  European Parliament and the Council, establishing the 
integrated  border,  https://eur-lex.europa.eu/legal-

multiannual  strategic  policy 
content/EN/TXT/HTML/?uri=COM:2023:146:FIN 

for  European 

(113) Annex II BMVI Regulation. 

50 

 
 
 
 
Components EIBM 

BMVI Implementation measures (113) 

Information  exchange  and  cooperation 
between  MS,  and  between  MS  and 
Frontex 

1(c):  Enhancement  of  inter-agency  cooperation  at  national 
level among national authorities, inter-MS cooperation, other 
Union bodies and third countries 

Inter-agency cooperation within MS 

Cooperation between EU stakeholders 

Cooperation with third countries 

Technical  and  operational  measures 
within Schengen 

Return of third country nationals 

State  of  the  art  tech  and  large-scale  IT 
systems 

Quality Control Mechanisms 

1(c):  Enhancement  of  inter-agency  cooperation  at  national 
level among national authorities, inter-MS cooperation, other 
Union bodies and third countries 

1(c):  Enhancement  of  inter-agency  cooperation  at  national  -
level among national authorities, inter-MS cooperation, other 
Union bodies and third countries 

1(c):  Enhancement  of  inter-agency  cooperation  at  national 
level among national authorities, inter-MS cooperation, other 
Union bodies and third countries 

1(a)(ii)  Improvement  external  border  control:  technical  and 
operational measures within Schengen area related to border 
control 

N/A – no relevant objective under BMVI (returns falls under 
AMIF) 

1(e): IT systems/communication infrastructure, equipment 

1(d) – ensuring the uniform implementation of the EU acquis 
including quality control mechanisms 

Solidarity Mechanisms 

N/A – this component specifically relates to BMVI as a whole 

Fundamental Rights 

1(d) – ensuring the uniform implementation of the EU acquis 

Education and training 

N/A – cross cutting 

Research and Innovation 

N/A – cross cutting 

In  addition,  the  EIBM  Strategy (114)  provides,  in  line  with  the  EBCG  Regulation,  the 
development  of the  Border and Coast  Guard Capability Development  Plan (CDP) (115), 
based on the national capability development plans. As confirmed by interviewees, these 
national capability development plans will then also be used to inform the planned actions 
under BMVI Member States Programmes.  

EU Asylum and Migration Pact 

On 26 April 2024, the EU adopted the EU Asylum and Migration Pact, a set of new rules 
managing migration and establishing a common asylum system at EU level, that deliver 
results while remaining grounded in core European values (116).. The legislative package 
underpinning  the  Pact  specifies  that  the  relevant  Regulations  will  start  entering  into 
application from 1 July 2026. During the two-year transition period between the entry 
into force and the  start  of  application of the Pact,  the Member States are  called to  best 
prepare their systems and structure, in view of a quick and effective (full) implementation 
of the Pact  as from  July 2026, for example by strengthening their reception and border 

(114) Communication  from  the  Commission  to  the  European  Parliament  and  the  Council  establishing  the 
multiannual strategic policy for European Integrated Border Management, COM(2023),146, 14 March 
2023 

(115) The Border and Coast Guard Capability Development Plan (CDP) is a single comprehensive framework 
for border and coast guard capability development, foreseen to be established under the EIBM Strategy 

(116) https://home-affairs.ec.europa.eu/policies/migration-and-asylum/pact-migration-and-asylum_en  

51 

 
 
 
 
 
management capacity, in line with the higher standards introduced by the Pact. These will 
be reflected in their “National Implementation Plans due by mid-December 2024.” to be 
finalised by mid-December 2024.  

It will be necessary to make the best use of the AMIF and BMVI resources to address the 
needs of the Pact.   

Coherence with other Home Affairs funds (AMIF and ISF) 

Interdependence between the policy areas covered by the three Home Affairs Funds 
(AMIF,  BMVI,  ISF)  creates  challenges  for  the  delivery  of  the  overall  policy 
objectives.  However,  it  also  brings  opportunities  for  enhanced  synergies  and 
coordination and, ultimately, reduces the risk of overlaps or duplication.  

Coordination is indeed necessary to support free movement and maintaining the benefits 
of Schengen, which requires common action at Union level, and constant and continuous 
efforts from all Member States, as shown by the Schengen strategy from 2021 (117). The 
Schengen  area  needs  to  be  underpinned  by  an effective  external  border  management, 
common visa policy, effective and sustainable return policy, relevant police cooperation 
instruments  and  IT  systems  and  a  robust  governance.  To  sustain  the  area  of  freedom, 
security  and  justice  requires  measures  in  the  field  of  security,  police  and  judicial 
cooperation that also promote compliance with fundamental rights. 

A common migration and asylum system is also key to supporting the area without controls 
at internal borders. Each element is necessary – but on its own not sufficient – to achieve 
the  overarching  objective  of  a  fully  functioning  Schengen  area,  including  the  lifting  of 
internal  border  controls.  From  a  funding  perspective,  this  complex  interdependence 
requires  clear  priority  setting  at  national  level  and  adequate  level  of  Commission 
steering  where  relevant,  good  coordination  between  all  actors  involved  in  the 
programming and implementation of national and EU funds to ensure that the funding 
effectively  contributes  to  achieving  the  overall  policy  objectives  in  an  optimal  manner 
contributing to economies of scale.  

The legal framework allows for complementarities and synergies between BMVI and the 
other Home Affairs funds in three ways: 

(117) Communication from the Commission to the European Parliament and the Council “A strategy towards 

a fully functioning and resilient Schengen area”, COM(2021)277, 2 June 2021. 

52 

 
 
 
-  Funding  of  multi  purpose  equipment:    Pursuant  to  Article  13  (14)  BMVI 
Regulation,  equipment  and  ICT  systems  required  for  effective  and  secure 
border  control  funded  under  BMVI  may  also  be  used  for  achieving  the 
objectives of the ISF and AMIF. 

-  Also,  as  per  Article  26  of  the  CPR,  Member  States  may  also  request  in  an 
amendment  of a programme the transfer of up to  5 % of the initial national 
allocation of each Fund to another Fund or Funds.  

-  Finally,  article  26  of  the  BMVI  Regulation  provides  for  the  possibility  of 
cumulative financing, i.e. an action that has received a contribution under the 
instrument may also receive a contribution from any other Union programme, 
including funds under shared management, provided that the contributions do 
not cover the same costs. 

However,  the  evaluation  did  not  collect  evidence  on  the  extent  to  which  Managing 
Authorities are aware of and use these possibilities in practice. The only transfer of Funds 
(from ERDF to the BMVI) was requested by Greece. According to the Greek authorities, 
it made it easier for the Member State to react to specific situations at the external border. 

At EU level, coordination is ensured by the fact the Home Affairs Funds being handled in 
a single Directorate-General, as well as the existing consultation mechanisms applied in 
the preparation, discussion and adoption of Member State programmes and Commission’s 
work programmes for the Thematic Facility. The Commission also provides assistance to 
the Member States through the coordination and geographical units in DG HOME, which 
give  answers  to  questions  from  Managing  Authorities,  are  in  close  contact  with  the 
Managing  Authorities,  and  follow  up  closely  the  proceedings  of  the  monitoring 
committees.  

As regards the Thematic Facility, the Thematic Facility Steering Group and the Thematic 
Facility Working Group ensure the complementarity and coordination of Specific Actions 
with policy priorities and existing programmes. 

At Member State level, the country case studies confirmed that mechanisms exist to ensure 
actions  implemented  through  BMVI  and  AMIF  and  ISF  are  complementary  with  each 
other, although they differ across Member States. The key mechanisms in place to ensure 
coherence are the Managing Authorities (in doing their selection of funded actions) and 
the funds’ Monitoring Committees. Beyond this, Member States have also put  in  place 
additional means to coordinate across the three funds (see examples below).  

As  can  be  seen  in  Figure  16,  the  survey  with  national  authorities  confirmed  that  many 
Member States have at least one type of mechanism in place: most respondents stated to 
have  monitoring  mechanisms  in  place  to  avoid  overlap  of  funding  (55%),  followed  by 
coordination mechanisms to ensure their complementarity (45%), while just over a third 
of respondents reported to carry out assessment to identify similar funding instruments. 
Seven  respondents  (amounting  to  23%  of  respondents  and  covering  four  different 
participating  countries) responded “I don’t know/I prefer not  to  say” or  “no” across all 
three mechanisms. This lack of awareness could also indicate that such mechanisms are 
not widely used/consulted within the relevant national authorities.   

53 

 
 
Figure 16: Mechanisms in place at national level to ensure synergies/avoid overlap between BMVI 
and with other funding instruments 

Monitoring mechanisms to prevent overlap

55%

3%

42%

Coordination mechanisms to ensure synergies

45%

6%

Assessment to identify other similar funding instruments

35%

13%

49%

52%

0%

20%

40%

60%

80%

100%

Yes

No

I don’t know/prefer not to say

Source: Preparatory study, targeted survey of national authorities (n= 31) 

The  case  study  reports  provided  more  detailed  information  about  the  different  types  of 
tools in place in the Member States: 

•  Single  planning  documents:  For  example,  in  Poland  a  joint  Member  State 
Programme  was  developed  to  cover  the  three  funds:  ISF,  BMVI,  as  well  as 
AMIF (118). 

•  Reviews: such as a review process as that undertaken for the national budget, or 
examining  the actions planned in  the Member States Programmes against other 
relevant national and EU funding (e.g. AT, EL). 

•  Coordination  at  the  level  of  authorities,  which  shows  the  different  levels  of 

organisation across the Member States: 

o  Appointing the same authority as the Managing  Authority for  all three  funds 
(e.g. FI, PL, RO). The Polish case study highlighted in this regard that having 
the same Managing Authority and the same intermediate body for all three funds 
facilitates the processes (e.g. preparing calls for proposals) and thereby reduces 
administrative burden. 

o  Establishment  of  an  overarching  management  or  coordination  office  for  the 
Home Affairs funds (e.g. IT, EL, HR, FR, HU, MT). For example, in Greece, a 
Special Department of Coordination and Management of BMVI, ISF and AMIF 
was established to ensure the continued coherence of the funds. 

o  Ensuring the same persons sit on the Monitoring Committees of all three Home 
Affairs funds (e.g. IT, LT). For example, in Italy many of the members of BMVI 
Monitoring  Committee  are  also  members  of  the  ISF  Monitoring  Committee, 
which  according 
further  enhanced 
communication, awareness of activities and synergies. 

the  stakeholders 

interviewed 

to 

o  Organising  regular  meetings  between  Managing  Authorities  (e.g.  CZ),  or 

between monitoring committees (BG, EE). 

The final layer for assessing complementarity between BMVI funding and other funds are 
the audits carried out at national and EU level. 

(118) SFC2021 Programme for AMIF, ISF-BV and BMVI, Poland. 

54 

 
 
 
 
Stakeholders consulted held positive views on the coherence between BMVI and the 
other HOME Affairs  funds (ISF and AMIF), although lack  of awareness  seems to 
exist among national level stakeholders as to how synergies could be created. 

A  large  proportion  of  the  stakeholders  consulted  through  the  online  survey  (40-60% 
depending on the type of stakeholder) did not feel they could answer the question whether 
the  actions  implemented  through  BMVI  were  coherent  with  AMIF  or  ISF.  For 
beneficiaries and “other stakeholders”, this could simply indicate a lack of awareness of 
these other DG HOME funds. This was echoed in some of the case studies (e.g. Croatia), 
where beneficiaries considered that no overlaps existed but were not aware of how BMVI 
aligned with other EU instruments. For the managing/implementing national authorities, 
this  could  indicate  a  lack  of  available  mechanisms  in  place  to  identify  and  exploit 
opportunities to create synergies between the actions funded between the three funds (as 
also  noted  above).  This  thus  suggests  that  more  could  be  done  to  increase  the  national 
authorities’ awareness of the potential synergies that could be created, in order to further 
strengthen the coherence between the three Home Affairs funds. 

Of  those  who  were  able  to  answer  the  question,  the  majority  was  positive,  noting  that 
BMVI actions were coherent to a large or very large extent with AMIF and ISF funded 
actions. For both AMIF and ISF, only 3% of national authorities, and 6% of beneficiaries 
thought this was not the case (answering “not at all”). 

Figure  17:  “In  your  opinion,  were  the  actions  implemented  through  the  ISF-BV  and  BMVI 
instruments  coherent  with  and  non-contradictory  (no  duplications  or  overlap)  to  other  EU 
interventions with similar or complementary objectives? - Asylum, Migration and Integration” 

Coherence BMVI with AMIF (% respondents)

100%

80%

60%

40%

20%

0%

42%

3%
10%
19%

26%

60%

6%
6%
17%
11%

46%

4%
25%

25%

National authorities N = 31

Beneficiaries N=35

Other stakeholders N=28

To a very large extent

To a large extent

To some extent

Not at all

To a limited extent

I don’t know / I prefer not to answer

Source:  Preparatory  study,  targeted  surveys.  Note:  While  the  31  responses  from  national 
authorities  only  include  those  relevant  to  BMVI,  the  answers  of  beneficiaries  and  other 
stakeholders cover both programming periods (ISF-BV and BMVI funding) 

55 

 
 
 
Figure  18:  In  your  opinion,  were  the  actions  implemented  through  the  ISF-BV  and  BMVI 
instruments  coherent  with  and  non-contradictory  (no  duplications  or  overlap)  to  other  EU 
interventions with similar or complementary objectives? 

Coherence BMVI with Internal Security Fund (ISF)

100%

80%

60%

40%

20%

0%

45%

3%
10%

16%

26%

54%

6%
3%
11%

26%

25%

7%

36%

32%

National authorities N = 31

Beneficiaries N=35

Other stakeholders N=28

To a very large extent

To a large extent

To some extent

Not at all

To a limited extent

I don’t know / I prefer not to answer

Source:  Preparatory  study,  targeted  surveys.  Note:  While  the  31  responses  from  national 
authorities  only  include  those  relevant  to  BMVI,  the  answers  of  beneficiaries  and  other 
stakeholders cover both programming periods (ISF-BV and BMVI funding).  

According to the country case studies conducted in the context of the preparatory study, 
national level stakeholders did not note any overlaps, gaps, or inconsistencies between the 
activities  funded  by  BMVI  and  those  funded  under  AMIF  or  ISF.  Several  stakeholders 
highlighted  the  complementarity  between  BMVI  and  ISF,  with  BMVI  having  a  role  in 
reinforcing internal security by supporting strong border management. 

The thematic case study on the Russian war of aggression highlighted that AMIF EMAS 
and  BMVI  EMAS  funding  was  meant  to  be  used  for  different  types  of  activities  and 
therefore complemented each other: while AMIF EMAS funding in Poland and Slovakia 
was  meant  to  cover  activities  supporting  migrants  such  as  providing  accommodation, 
healthcare  services,  transportation,  BMVI  EMAS  funding  was  meant  to  cover  the 
strengthening  of  the  border  management.  However,  a  detailed  assessment  of  how  the 
activities complemented each other was not possible, as EMAS funding (under both funds) 
was used to support the State budget in more general terms, and it is not possible to identify 
activities funded through EMAS funding based on financing not linked to costs. 

Although coherence between BMVI and the other Home Affairs Funds (ISF and AMIF) 
has been acknowledged across the Member States, the case studies and Member State mid 
term evaluations highlighted the following challenges or limiting factors for the creation 
of synergies: 

•  Lack  of  robust  coordination  mechanisms  among  Managing  Authorities  and 
insufficient  information  sharing.  This  is  especially  the  case  in  Member  States 
where  different  authorities  are  in  charge  of  the  implementation  of  the  Home 
Affairs  Funds  programmes  or  where  the  Member  State  has  a  decentralised 
structure, which either do not communicate with each other, or where coordination 

56 

 
 
 
arrangements  between  the  Managing  authorities  are  informal  or  not  intensive 
enough (i.e. ad hoc or irregular meetings).  

•  The mid-term evaluations of several Member States reported that there was a lack 
of clarity in the Member States Programmes as to potential links between the funds 
(i.e. where synergies should be sought).  

Coherence with other EU funds 

The comparison between their respective objectives and measures shows a high level of 
complementarity between BMVI and other EU funds, namely: 

• 

• 

• 

In the field of customs: Customs Control Equipment Instrument (CCEI), 

In the field of research and innovation: Horizon Europe 

In the field of EU external action, including EU funds managed by DG INTPA, 
DG MENA and DG ENEST (NDICI Global Europe and IPAIII).  

•  Other  emergency  instruments:  including  the  Recovery  and  resilience  facility 

(RFF) and the Technical Support Instrument (TSI). 

•  Other EU funding instruments: the Justice Programme, the European Social Fund 

Plus and the European Regional Development Fund.  

Coherence  between  the  BMVI  and  other  EU  funds  is  conceptually  sound  and 
understood  in  general  by  stakeholders.  However,  interviews,  surveys  and  focus 
groups conclude that coordination mechanisms are sometimes not fully effective, and 
synergies  and  complementarities  not  always  visible  to  Managing  Authorities, 
stakeholders and beneficiaries. 

Coordination at EU level is overall ensured by regular or ad-hoc interservice consultation 
mechanisms  between  the  services  responsible.  Before  the  adoption  of  BMVI  Thematic 
Facility Work Programme and Member States Programmes, the relevant services must be 
consulted and can comment on the draft text. Conversely, DG HOME can comment on the 
draft  work  programmes  of  the  other  EU  funding  instruments.  EU  level  interviews 
confirmed  this  process  worked  well.  Issues  are  often  dealt  with  both  formally  and 
informally, including before the interservice consultation. 

•  Coordination with funds under shared management 

In the case of the funds run under the CPR, the main coordination mechanisms, aiming to 
a standard implementation of the rules and procedures of that regulation, is the CPR Stock-
Taking Group, which meets on a weekly basis. The Group includes representatives from 
DG  REGIO,  EMPL,  HOME  and  MARE.  The  Group  provides  guidance  on  the 
interpretation  of  the  funds  and  answers  to  CPR-related  questions  from  the  Managing 
Authorities. 

The mechanisms in place to ensure coordination of BMVI funding with other EU funds at 
national  level  are  similar to  those described  above for the  Home Affairs funds, namely 
through  the  Monitoring  Committee  and  regular  coordination  between  the  Managing 
Authorities of the different funds.  

57 

 
 
•  Coherence of BMVI with Horizon Europe 

BMVI funding is a crucial tool in the development of Research and Innovation in the 
border management policy area, by ensuring the concepts developed under Horizon 
lead to longer term testing and validation and eventually ensure these capabilities are 
available to procure on the EU market. However, possibilities of development are not 
fully implemented at EU or national level. 

The  BMVI  Regulation  supports  actions  that  develop  border  management  related 
innovation, which in practice is funded under cluster 3 of the Horizon Europe programme 
(Civil security for society).  

The  BMVI  Regulation  provides  among  others  that  BMVI  shall  support  “actions 
developing  innovative  methods  or  deploying  new  technologies  with  a  potential  for 
transferability  to  other  Member  States,  in  particular  deploying  the  results  of  security 
research projects where such deployment has been identified by the Frontex, acting under 
Article  66  of  Regulation  (EU)  2019/1896,  as  contributing  to  the  development  of 
operational capabilities of the European Border and Coast Guard (119). EU level interviews 
confirmed  that  the  programming  of  Horizon  Europe  research  funded  under  cluster  3  is 
directly based on the long-term needs in the Frontex and Member State capability plans, 
and no other funding mechanism exists to establish the link between innovation and later 
practice. 

The  Innovation  &  Security  Research  unit  in  DG  HOME  plays  an  important  role  in 
encouraging this link, being responsible for managing the projects funded under Horizon 
Europe cluster 3. The unit is involved at the programming stage of BMVI, by providing 
comments  on  BMVI  Member  States  Programmes  and  the  Thematic  Facility  Work 
Programme. According to the evidence collected, Managing Authorities are often unaware 
of the relevant Research and Innovation projects funded in their country, as well as the 
relevant stakeholders involved. In practice, the comments provided by the Commission are 
very often not taken up by Managing Authorities, as they tend to focus on using BMVI 
funding to address more immediate needs.  

While the BMVI Regulation lists measures deploying, transferring, testing and validating 
new  methodology  or  technology,  including  pilot  projects  and  follow-up  measures  to 
Union-funded  research  projects  amongst  the  actions  eligible  for  higher  co-financing 
rates120 , there appears to be limited awareness among BMVI Managing Authorities and 
beneficiaries of these more advantageous financial conditions.  

In an effort to encourage further uptake of Horizon Europe results, a Specific Action on 
innovation  was  launched  under  the  2021-2022  Work  Programme,  and  as  a  result  five 
projects  are  currently  ongoing.  Proposals  are  currently  being  assessed  under  a  second 
Specific Action on innovation.  

While interviewees welcomed these actions as an important step forward, they noted that 
funding for innovation and further development of long-term capabilities under BMVI was 
still insufficient. As BMVI funding dedicated to the follow up of Horizon Europe projects 
had been limited, promising results achieved under Horizon Europe may have been left on 
the shelf. Interviewees highlighted that if the uptake of these results would not improve 

(119) Point 1(f) of Annex III, BMVI Regulation. 
(120) Art 12(3) , and Annex IV (7) BMVI Regulation 

58 

 
 
 
under BMVI, the long-term capabilities needed in 10-15 years' time would not be available, 
leaving  Member  States  dependent  on  third  countries  to  procure  the  technologies  and 
operational capabilities they need.  

The interviewees suggested the need for more structural engagement of the stakeholders 
involved in border management Research and Innovation to ensure this is systematically 
taken  into  account  at  programming  stage  of  BMVI,  as  well  as  ringfencing  a  specific 
percentage of funding within Member States Programmes for these types of projects.   

•  Coherence of BMVI with the EU external action 

The external dimension of the policy area is first and foremost supported by funding from 
the External Action spending programmes with an objective to uphold and promote the 
Union’s  values,  principles  and  fundamental  interests  worldwide  and  to  pursue  the 
objectives and principles of the Union’s external action. Priorities in EU External Action 
spending programmes are increasingly linked to EU internal policy objectives, including 
on migration and internal security. 

Regarding BMVI-funded actions in and in relation to third countries, the Commission and 
the  Member  States,  together  with  the  European  External  Action  Service,  shall,  in 
accordance with their respective responsibilities, ensure coordination with relevant Union 
policies, strategies and instruments (121). In particular, they shall ensure that: 

• 

• 

• 

• 

they  are  carried  out  in  synergy  and  in  coherence  with  other  actions  outside  the 
Union supported through other Union instruments; 

they  are  coherent  with  external  Union  policy,  respect  the  principle  of  policy 
coherence  for  development  and  are  consistent  with  the  strategic  programming 
documents for the region or country in question; 

they focus on measures that are not development-oriented; and 

they serve the interests of internal Union policies and are consistent with activities 
undertaken within the Union. 

In this regard, whenever a Member State decides to implement a project with or in a third 
country with the support of the instrument, it shall consult the Commission prior to the 
approval of the project (122). A procedure has been set through which DG HOME consults 
the relevant services (INTPA, MENA, ENEST, EEAS, ECHO, FPI) and approves (with or 
without comments) or rejects the project that has been submitted by the Member State. 

Additionally, Member States need to notify the Commission of any bilateral or multilateral 
cooperation agreement signed with any third country, with which they decide to implement 
an action with, in or in relation to a third country with the support of the  instrument in 
relation to the monitoring, detection, identification, tracking, prevention and interception 
of unauthorised border crossings for the purpose of detecting, preventing and combating 
irregular  immigration  and  cross-border  crime  or  for  the  purpose  of  contributing  to  the 
protection of migrants and contributing to saving the lives of migrants. 

(121) Article 5(3) BMVI. 
(122) Article 13(12) BMVI. 

59 

 
 
 
Regarding  the  Thematic  Facility,  coherence  is  ensured  through  the  interservice 
consultations with the relevant external action services. 

There are however certain challenges in shared management, amongst which the limited 
impact  of  the  Commission’s  recommendations  as  well  as  the  limited  ability  of  the 
Commission  to  monitor  the  implementation  of  those  activities  by  the  Member  States. 
Additionally, Member States need to notify the Commission of any bilateral or multilateral 
cooperation agreement signed with any third country, with which they decide to implement 
an action with, in or in relation to a third country with the support of the  instrument in 
relation to the monitoring, detection, identification, tracking, prevention and interception 
of unauthorised border crossings for the purpose of detecting, preventing and combating 
irregular  immigration  and  cross-border  crime  or  for  the  purpose  of  contributing  to  the 
protection of migrants and contributing to saving the lives of migrants. 

In this regard, BMVI-funded calls for proposals have been launched under the Migration 
Partnership  Facility  (MPF),  the  EU  initiative  managed  by  the  International  Centre  for 
Migration Policy Development (ICMPD) that aims to strengthen dialogue and cooperation 
on  migration  and  mobility  issues  between  EU  Member  States  and  partner  countries. 
Coherence  with  other  EU  funds  is  ensured  through  the  consultations  process  that  takes 
place as part of the selection process. This process is aimed to verify complementarity with 
other projects in the same countries or covering the same thematic areas, and in order to 
avoid duplications and overlapping. The grant evaluation Committee is composed of DG 
HOME, DG INPTA, DG MENA, DG ENEST and EEAS, with these services also being 
members of the overall MPF Steering Committee  

An  additional  coordination  mechanism  was  put  in  place  in  2022,  the  Operational 
Coordination Mechanism for the External Dimension of Migration (MOCADEM). It was 
established under the Council presidency with the objective to exchange on and coordinate 
the  national  projects  that  are  funded  in  third  countries  by  the  EU  and  Member  States. 
External dimension funding is also a regular agenda item at both  the Working Party on 
External  Aspects  of  Asylum  and  Migration  (EMWP)  and  the  Strategic  Committee  on 
Immigration,  Frontiers,  and  Asylum  (SCIFA).  However,  all  these  fora  result  in  limited 
input from Member States on their national activities, and Member States tend to focus on 
NDICI rather than HOME funds. 

Finally, Partnership Agreements are in place between the EU and third countries, which 
include a section on coordination and complementarity to avoid overlaps between BMVI 
funding and other funding instruments. 

•  As far as coherence with external spending programmes is concerned, and notably 
the NDICI, enhanced cooperation and coordination on programming both between 
the Commission services and with Member States are needed. There are several 
challenges in the current funding architecture that should be addressed, including 
notably:  the  need  to  further  strengthen  the  link  between  internal  and  external 
priorities in the Union’s external security funding; the persistent challenge to use 
all existing (policy, funding, investment and other) tools, both at the disposal of 
the EU and its Member States in a Team Europe spirit, to use strategically and 
timely  leverage in relation to partner countries in order to improve cooperation on 
security; the limitations for funding border management and visa-related actions 
in  third  countries,  given  that  most  of  spending  in  the  external  dimension  must 
comply  with  the  criteria  for  development  assistance  eligibility.Coherence  with 

60 

 
 
other  emergency  instruments:  including  the  Recovery  and  Resilience  Racility 
(RFF) (123) and the Technical Support Instrument (TSI) (124). 

The stakeholders consulted did not report any overlaps between the BMVI funding and 
RFF and TSI funding. Interviewees estimated that around 5-10% of RFF proposals (period 
2020-2026) are relevant to border management and related fields, such as anti-corruption, 
or projects related to EU-LISA. Coherence in these cases is ensured through consultations 
between DG HOME Unit A1 (Policy Coordination & Interinstitutional Relations) and the 
Recovery  and  Resilience  Task  Force  (RECOVER)  within  the  Secretariat-General  of 
European Commission. and DG ECFIN. DG HOME reviews the RFF work programmes 
(as  part  of  the  Inter-service  consultation),and  is  also  consulted  upon  the  adoption  and 
amendment of national plans. Similarly, feedback from DG ECFIN and RECOVER on the 
BMVI work programmes is ensured through the Inter-service Consultations. As confirmed 
by  interviews,  TSI  and  BMVI  complementarity  is  rare,  instead  this  instrument  is  more 
relevant  to  AMIF  and  actions  funded  by  the  EUAA.  TSI  had  a  dedicated  call  on  the 
Migration  and  Asylum  Pact,  to  support  Member  States  with  the  preparation  of  their 
national implementation, which complements the BMVI National Programmes. Coherence 
is ensured through the Inter-service consultation, in which DG REFORM (in charge of the 
TSI) provides feedback to DG HOME Unit A1.  

•  Coherence  with  other  EU  funding  instruments:  the  Justice  Programme,  the 
European Social Fund Plus and the European Regional Development Fund.  

Stakeholders  consulted  noted  that  the  synergies  between  BMVI  and  ESIF  (2021-2027) 
were limited: In terms of beneficiaries, the authorities involved in ESF+ and ERDF are 
different from the beneficiaries of the BMVI. Moreover, the types of activities funded are 
more closely linked to AMIF, in that the ESF+ and the ERDF can help facing the migration 
pressure experienced by the EU, by supporting long-term integration of migrants. 

Similarly,  stakeholders  consulted  noted  the  synergies  between  BMVI  and  the  Justice 
programme were limited, as the Justice Programme has distinct focus and covers different 
beneficiaries (in the area of police and judicial cooperation).  

For both cases, coherence is mostly ensured through the interservice consultations on the 
BMVI,  which  include  DG  JUST  and  DG  EMPL  and  DG  REGIO.  Even  though  most 
interviewees were positive about the coordination mechanisms to ensure coherence 
with the EU external action, several of them found that the coordination processes 
should be strengthened, as it is currently heavily based on good ad hoc coordination. 
This is particularly relevant since the external dimension of border management is bound 
to become more relevant with the implementation of the Pact on Migration and Asylum. 

(123) The  RRF  is  a  temporary  instrument  that  is  the  centrepiece  of  NextGenerationEU  -the  EU’s  plan  to 
emerge stronger and more resilient from the current crisis.Through the Facility, the Commission raises 
funds by borrowing on the capital markets (issuing bonds on behalf of the EU). These are then available 
to its Member States, to implement ambitious reforms and investments that: 
1.  make their economies and societies more sustainable, resilient and prepared for the green and digital 

transitions, in line with the EU’s priorities; 

2.  address  the  challenges  identified  in  country-specific  recommendations  under  the  European 

Semester framework of economic and social policy coordination. 

(124) The  TSI  provides  tailor-made  technical  expertise  to  EU  Member  States  to  design  and  implement 
reforms. The support is demand driven and does not require co-financing from Member States. It is an 
important  pillar  of  the  EU’s  initiative  to  help  Member  States  mitigate  the  economic  and  social 
consequences of the outbreak of the COVID-19 crisis. 
61 

 
 
 
•  Challenges to coherence 

There is a lack of awareness amongst Managing Authorities and stakeholders about 
the  elements  of  complementarity  between  the  funds,  and  about  the  possibilities  to 
make use of them. This potentially hinders the development of synergies between the 
instruments. 

Most of the national authorities consulted through the online survey (58-75% depending 
on the EU funding instrument) did not feel they could answer the question whether the 
actions  implemented  through  BMVI  were  coherent  with  other  EU  funding  instruments. 
This  could  either  mean  these  authorities  are  not  familiar  with  these  other  EU  funding 
instruments  or  a  lack  of  mechanisms  to  identify  and  exploit  opportunities  to  create 
synergies between the EU funds. This was also apparent in the country case studies: in 
which  none  of  the  stakeholders  interviewed  highlighted  synergies  or  overlaps  between 
BMVI and these other EU funding instruments. 

Of those that were able to answer the survey question, the majority was positive, noting 
BMVI  actions  were  coherent  to  a  large  or  very  large  extent  with  other  EU  funding 
instruments. Respondents were most positive about coherence with Horizon Europe and 
ESIF. Only three national authorities thought there was no coherence at all between BMVI 
and IPA, NDICI, the Justice Programme and CCEI, and only two believed no coherence 
existed between BMVI and ESIF and Horizon Europe.  

As  far  as  coherence  with  external  spending  programmes  is  concerned,  and  notably  the 
NDICI,  enhanced  cooperation  and  coordination  on  programming  both  between  the 
Commission services and with EU Member States are needed. There are several challenges 
in  the  current  funding  architecture  that  should  be  addressed,  including  notably:  the 
insufficient  alignment  of  the  Union’s  external  migration  and  security  funding  with  the 
Union policies in these areas; the persistent challenge to use all existing (policy, funding, 
investment and other) tools, both at the disposal of the EU and its Member States, in a 
Team Europe spirit, to use strategically and timely  leverage in relation to partner countries 
in  order  to  improve  cooperation  on  migration  and  security;  the  limitations  for  funding 
migration- and security-related actions in third countries, given that most of spending in 
the  external  dimension  must  comply  with  the  criteria  for  development  assistance (125) 
eligibility. 

(125) Official development assistance eligibility criteria is set by the Organisation for Economic Cooperation 

and Development. 

62 

 
 
 
Figure  19:  Responses  to  the  survey  question:  In  your  opinion,  were  the  actions  implemented 
through the ISF-BV and BMVI instruments coherent with and non-contradictory (no duplications 
or overlap) to other EU interventions with similar or complementary objectives? (N= 31 national 
authorities) 

Coherence BMVI with other EU funds
N=31 national authorities 

Horizon Europe

European Structural and Investment Funds

Customs Control Equipment Instrument

Justice Programme

NDICI-Global Europe Instrument

Instrument for Pre-accession Assistance

0%

20% 40% 60% 80% 100% 120%

To a very large extent

To a large extent

To some extent

Not at all

To a limited extent

I don’t know / I prefer not to answer

Source: Preparatory study, targeted survey 

The survey with beneficiaries and “other stakeholders” showed similar results, with the 
majority  answering  they  “did  not  know”,  followed  by  respondents  that  responded 
positively (and most positively about ESIF and Horizon Europe).  

In  general,  there  is  the  perception  that  information  is  insufficient  and  communication 
between actors could be improved, notably in fields like Research and Innovation, where 
stakeholders perceive that there should be room for strengthened coordination.  

One  interviewee  noted  that  the  coordination  with  the  funding  of  equipment  under  the 
Customs Control Equipment Instrument (CCEI) was challenging, as BMVI mostly funds 
equipment through shared management, while under CCEI this is implemented through 
direct  management.  The  different  methods  of  implementation  can  only  be  efficiently 
combined through an active coordination. 

4.2.  How did the EU intervention made a difference and to whom? 

The BMVI’s added value lies in its ability to support projects extending beyond the 
financial  and  operational  capacities  of  individual  Member  States.  By  fostering 
cooperation, ensuring compliance with EU standards, and complementing the effort 
from  the  national  budget,  it  significantly  enhances  the  EU’s  collective  border 
management and visa policy framework.  

63 

 
 
 
The evaluation shows a strong consensus among national authorities on the importance of 
EU support for border management and visa policy and underscores the EU’s essential role 
in maintaining security and visa management across the Union. (126) 

Member  States  highlight  the  role  of  BMVI  in  improving  their  integrated  border 
surveillance  and  control  mechanisms.  Projects  such  as  the  deployment  of  advanced 
surveillance  equipment  and  the  development  of  integrated  border  management  systems 
have markedly bolstered border security. For instance, Bulgaria's Integrated Surveillance 
System (ISS) and Finland’s procurement of Border Guard equipment exemplify how EU 
funding  elevates  national  capabilities  to  meet  EU-wide  security  standards.  Similarly, 
countries such as Poland have benefitted from such assistance to enhance border security 
through  ICT  upgrades.   (127)    Mid-term  evaluation  reports  further  highlight  how  EU 
instruments  are  essential  for  initiating  projects  that  national  resources  alone  cannot 
support.  

Improvements in cross-border cooperation and the development of national surveillance 
systems  were  also  specifically  mentioned  by  the  national  authorities  responding  to  the 
survey as key additional positive effects of BMVI projects, which directly contribute to 
enhancing national capacities to meet EU security. (128) 

Evidence suggests that an essential added value brought about by BMVI is the alleviation 
of  pressures  on  the  national  budget.  Countries  such  as  Cyprus,  Estonia,  and  Malta  rely 
heavily on EU instruments to undertake critical projects that would otherwise be delayed 
or deprioritised. This funding not only ensures timely project completion but also allows 
for  broader  and  more  ambitious  initiatives  than  national  resources  alone  could 
support. (129)  The  mid-term  reports  also  show  that  the  EU  support  provided  via  BMVI 
brings  additional  credibility  to  national  budget  requests,  helping  to  secure  continuing 
national  funds  for  border  management  projects.  For  instance,  Cyprus,  demonstrates  a 
critical reliance on EU instruments to fulfill obligations tied to EU border management 
policies. Moreover, in countries such as Croatia, the EU support allows to broaden national 
priorities,  and  without  such  support,  funding  would  be  limited  to  the  most  essential 
requirements  for  obligations  towards  Schengen  standards,  thus  reducing  the  quality  of 
work being done in relation to border security and visa. 

Lastly,  evidence  from  desk  research  shows  that  the  funding  enhances  the  operational 
efficiency  and  predictability  of  recipient  administrations.  Projects  in  countries  such  as 
Finland and France have improved maritime surveillance and visa processing capabilities, 
contributing to overall EU security and policy goals. (130) For instance, France’s renovation 
of  the  Dieppe  semaphore  monitoring  room  and  the  acquisition  of  coastal  maritime 
surveillance  boats  enhance  its  ability  to  monitor  and  secure  its  maritime  borders 
effectively. Moreover, the mid-term evaluation reveals that countries such as France, Italy, 
and  Lithuania  experience  a  scale  effect,  where  the  combination  of  EU  and  national 

(126) Online survey question “How important is for EU to continue providing support in the area of border 
management and visa policy?” national authorities (n=51): Very important [75%, 38]; Important [8%, 
4]; Somewhat important [4%, 2]; Not very important [0%,  0]; Not important at all [0%, 0]; I do not 
know / I prefer not to answer [14%, 7]. 

(127) Mid-term evaluation reports: 3 Member States. 
(128) Online survey question “In addition to benefits brought to planned end-beneficiaries, have you noticed 
further positive effects due to the BMVI projects (to date)?” national authorities (n=30). This survey 
question was an open question. 

(129) Mid-term evaluation reports: 3 Member States.  Country case study consultations: 5 Member States. 
(130) Mid-term evaluation reports: 8 Member States. 

64 

 
 
 
resources  leads  to  a  more  significant  impact  on  border  management  and  surveillance 
capabilities. 

National  authorities  also  identified  the  development  of  IT  systems  as  a  major  positive 
outcome of BMVI-funded projects. Smart border technologies, as well as technological 
innovations,  such  as  the  further  development  of  Eurosur  which  facilitates  real-time 
information  sharing  and  cooperation  between  Member  States,  were  highlighted. (131) 
Interestingly,  project  development  timelines  were  sometimes  considered  a  positive 
difference, as they push Member States to implement IT systems more efficiently.  (132) 

Another  beneficial  effect  for  Managing  Authorities  and  stakeholders  lies  in  the 
enhancement  of  cooperation  between  participating  countries  and  the  promotion  of 
harmonized  procedures.  BMVI-funded  operations  promote  more  aligned  and  consistent 
procedures  across  borders,  making  it  easier  for  Member  States  to  collaborate 
effectively. (133) Similarly, beneficiaries largely acknowledged increased cooperation and 
contact  between  Member  States  and  other  authorities  involved  due  to  BMVI  projects, 
which is key to harmonising procedures and improving coordination across borders. (134) 

Finally,  EU  support  encourages  the  adoption  of  common  strategies  and  innovative 
approaches that would not be feasible without external support. For instance, the Union 
Action  IMPROV-EU  is  being  implemented  and  aims  to  develop  and  disseminate  an 
innovative  protocol,  based  on  good  practices,  to  streamline  the  implementation  of  the 
provisions related to  persons in  vulnerable situations of the EBCG Fundamental  Rights 
Strategy at the national level in multiple Member States. (135) 

4.3. 

Is the intervention still relevant? 

In general terms, the instrument still responds to the needs identified at the beginning 
of  the  programming  period  in  order  to  achieve  the  overall  objective  of  ensuring 
strong  and  effective  European  integrated  border  management  at  the  external 
borders, thereby contributing to ensuring a high level of internal security within the 
Union, while safeguarding the free movement of persons within it and fully respecting 
the  relevant  Union acquis and  the  international  obligations  of  the  Union  and  the 
Member States.  

The evaluation concludes that there is an essential continuity in the relevance of the needs 
identified  during  the  preparation  of  the  instrument,  during  the  programming  stage  at 
Member State level and in the preparation of the Commission’s work programmes for the 
Thematic Facility. 

(131) Online survey question “Which EU-funded initiatives would represent a significant contribution in the 
future  in  the  areas of  border management  and visa  policy?”  national  authorities  (n=30).  This  survey 
question was an open question. 

(132) Online survey question “In addition to benefits brought to planned end-beneficiaries, have you noticed 
further positive effects due to the BMVI projects (to date)?” national authorities (n=30). This survey 
question was an open question. 

(133) Online survey question “Which EU-funded initiatives would represent a significant contribution in the 
future  in  the  areas of  border management  and visa  policy?”  national  authorities  (n=30).  This  survey 
question was an open question. 

(134) Online survey question “In addition to benefits brought to planned end-beneficiaries, have you noticed 
further positive effects due to the BMVI projects (to date)?” Beneficiaries (n=28). This survey question 
was an open question. 

(135) Thematic case study on Union Actions. 

65 

 
 
 
BMVI’s  objectives,  actions,  and  scope  are  sufficiently  broad  to  enable  flexible 
implementation of activities in border management and common visa policy, effectively 
addressing the diverse needs of Member States. This was confirmed through interviews, 
the  survey  analysis  and  the  mid-term  evaluation  reports,  where  there  was  general 
agreement  that  the  BMVI  instrument  continued  to  meet  national  and  stakeholders’ 
overarching  and  specific  needs  (introduced  above  and  further  elaborated  below) 
throughout its implementation. 

Member  States  and  other  stakeholders  find  the  actions  supported  by  the  BMVI 
relevant and addressing real needs - both structural long-term needs and emergency 
needs  –  but  also  that  needs  significantly  exceed  the  financial  envelope  of  the 
instrument.  

The  volume  of  issues  to  be  addressed  by  the  instrument  has  increased  during  the 
programming periods, reflecting several factors, including the impact of the Russian war 
of aggression in Ukraine, instrumentalisation of migrants, and the economic context and 
budgetary pressures faced by Member States. Certain gaps have been identified, e.g. 

•  Some national authorities highlighted that the Union's contribution to their Member 
State  Programme  and  the  EMAS  funding  was  insufficient  to  cover  all  planned 
projects,  especially  in  light  of  the  increased  demands  that  some  countries 
experience due to increased migratory pressure at their external borders. However, 
it should be noted that BMVI is only intended to support Member States, and not 
to cover the full implementation of all planned projects. 

•  The  need  for  faster  development  and  implementation  of  planned  large-scale  IT 

systems (in particular, EES and ETIAS). 

•  The need for innovation to allow for a more secure border process as per the Smart 
Borders Package. National authorities noted the need for more funding in the ICT 
sector to address new security risks and challenges (e.g. document fraud, identity 
theft, cyber threats, etc.). 

•  Building/infrastructure  and  equipment:  the  need  for  more  support  in  terms  of 
construction,  including  fences/physical  barriers  at  the  border,  which  are  not 
currently funded under BMVI was also highlighted by national authorities. This is 
due to a political decision by the European Commission not to fund the construction 
of fences. 

•  Operating  support/running  costs:  National  authorities  consulted  considered  that 
needs for additional operational support to cover running costs were not sufficiently 
addressed under BMVI (i.e., a need for more funding to cover operational costs 
beyond the current maximum set at 33% of total funding which can be allocated to 
operating support) 

•  Stakeholders find that the Thematic Facilities provide flexibility, focus on the key 
priority  needs  and  key  target  populations  and  make  it  possible  to  address 
emergency situations. 

The specific architecture of the instrument, and its three components, appear as a 
substantial contribution to the flexibility of the instrument to adapt to the changing 
context in which interventions take place. This has been acknowledged by all actors.  

66 

 
 
Member  State  programmes  address  Member  States’  structural  and  long-term  needs  in 
border management and visa policy. They provide stable funding planned across several 
years to address overarching as well as specific needs. This conclusion is supported by the 
mid-term evaluations of the Member States. This was also confirmed through the surveys, 
which evidenced the strong relevance of BMVI for national authorities, beneficiaries and 
other  stakeholders,  including  its  objectives  and  the  type  of  activities  funded  under  the 
instrument.  

The design of BMVI’s enables Member States to tailor their Member States Programmes 
to their needs thus ensuring the relevance of the instrument. These needs were identified 
by Member States at the beginning of the period, although the engagement of beneficiaries 
and relevant stakeholders in this initial needs’ assessment shows substantial variation.  

As  evidenced  through  the  country  case  studies,  needs  assessments  are  a  consultative 
process  combining  both  a  bottom-up  approach  (consultation  with  different  actors  from 
managing authorities to beneficiaries) as well as a top-down approach (defining priorities 
based  on  strategic  documents  and  concepts).  For  instance,  in  Greece,  it  included  a 
dedicated  Policy  Dialogue  between  key  stakeholders  to  define  the  national  strategic 
guidelines and specific objectives of the Programme. The Managing Authority identified 
key programme stakeholders based on the experience from the ISF-BV and consulted them 
to gather their feedback through a dedicated workshop and through a consultation process 
where stakeholders could contribute with their concerns, comments, and proposals. 

In  this  regard,  while  some  actions  funded  through  the  programme  were  deemed  less 
relevant  than  others  and  some  needs  unmet,  all  stakeholders  consulted  highlighted  the 
strong relevance of the Member States Programmes in addressing their national needs. 

The Thematic Facility allows steering funding towards priorities with the highest Union 
added value and often linked to unexpected developments: 

•  Specific Actions concern actions which require cooperation among Member States 
or actions necessary to address developments in the Union which require additional 
funding to be made available to one or more Member States. They thus  address 
both the needs of the EU and its Member States, as confirmed by stakeholders. An 
indicative example provided by one national authority was the "Support to Member 
States  for  Smart  Borders" (136)  which  provided  Greece  with  needed  (and 
unexpected/planned)  additional  support  for  the  financing  of  the  ETIAS  and 
SIRENA systems. (137) Similarly, the flexibility conferred by Specific Actions in 
addressing evolving challenges was also evidenced in Poland, where the rapid shift 
in priorities due to the Belarusian border crisis required a reallocation of resources 
initially intended for the Ukrainian situation. This demonstrated the flexibility of 
Specific Actions that can quickly adapt to emerging challenges. 

However  as  evidenced  through  the  Specific  Action  thematic  case  study,  their 
relevance  has  been  limited  by  various  administrative,  financial,  and  operational 
challenges.  A  consistent  theme  across  multiple  Member  States  is  that,  while 
Specific Actions provided essential support in addressing national priorities, they 
often did not fully cover the breadth of these needs due to limited funding, unclear 

(136) Reference no: BMVI/2024/SA/1.5.1 
(137)  This  action  has  been  approved  by  the  EU  but  has  not  yet  been  included  in  the  Member  State 

Programmeas of September 2024 

67 

 
 
 
timelines,  and  complex  administrative  processes.  Moreover,  several  national 
authorities also raised concerns regarding the alignment between Specific Actions 
and their countries’ needs, particularly because the funding for these actions cannot 
be  factored  into  the  policy  formulation  process,  making  it  more  challenging  for 
national authorities to fully integrate these actions into their (long term) broader 
border and visa management strategies. 

•  EMAS  addresses  EU  and  Member  States’  needs  for  an  instrument  which  can 
provide funding to respond to pressing and emerging challenges/emergencies in a 
timely manner (e.g., the Russian War of Aggression in Ukraine resulting in a mass 
influx  of displaced persons from  Ukraine, requiring a significant  increase in  the 
capacity  of  Member  States,  especially  the  ones  at  the  frontline  of  the  crisis  to 
rapidly strengthen their migration and external border management systems.) As 
confirmed through the thematic case study on the topic, EMAS addresses this need 
by  providing  emergency  funding  to  assist  Member  States  in  reinforcing  their 
capacity to respond to emerging crises characterised by large or disproportionate 
numbers  of  arrivals  or  by  incidents  which  have  a  decisive  impact  on  border 
security.  EMAS  provided  EUR  124  million  financial  support  to  four  Member 
States  (Hungary,  Poland,  Romania  and  Slovakia)  under  BMVI  to  address 
emergency situations related to the Russian War of Aggression in Ukraine and the 
mass influx of displaced persons. Stakeholders consulted positively assessed the 
flexibility of EMAS in that regard. In particular, under BMVI, Member States now 
have the possibility to receive Emergency Assistance under shared management as 
part of their Member States Programmes. While never used, the possibility offered 
by these so-called “top-ups” was positively assessed by interviewees – but remains 
unverified. In addition, unlike other funding mechanisms, EMAS does not operate 
under  rigid  predefined  criteria.  Instead,  it  can  be  used  to  fund  a  wide  scope  of 
activities as needed by the applicant to respond to an emergency situation. Each 
funding request is assessed on a case-by-case basis, allowing for tailored flexible 
support. Moreover, while EMAS funding is originally granted for a period of 12 
months, emergency assistance is provided for as long as the emergency situation 
lasts, allowing for additional funds to be received and extension granted. 

•  Union  Actions  provide  complementary  funding  to  respond  to  emerging 
transnational needs and capture/finance projects/activities that are in the collective 
interest of the EU. However, the findings from the Union Actions thematic case 
studies highlighted that a lack of willingness and/or ability by stakeholders to buy 
in on the experience built through Union Actions, may result in reduced benefits. 
Additionallly, interviews conducted as part of the country case studies confirmed 
that while there may be an appetite for Union Actions in theory (thus highlighting 
their relevance), when required, working transnationally was not straightforward 
for national authorities and not perceived as a priority compared to their national 
needs. 

The  instrument  has  been  able  to  adapt  successfully  to  new  and  pressing  needs,  in 
particular those related to the war in Ukraine, thanks to the flexibility of its structure 
and delivery methods. 

It is difficult to assess the actual effectiveness of the measures supported in the Member 
States  at  the  forefront  of  the  Ukrainian  cases.  However,  the  case  study  shows  that  the 
existence of a flexible Thematic Facility and, in particular, the use of emergency assistance 

68 

 
 
under a financing not linked to costs approach allowed to quickly mobilise resources that 
substantially reinforced the capacity of those Member States to face the consequences in 
terms of border management. The funds were made available quickly (much quicker than 
in  case  of  national  programmes  or  Specific  Actions  –  as  stakholders  noted),  and  the 
procedure  was  not  challenging.  Stakeholders  noted  that  after  the  decision  to  make  the 
funding  available,  the  process  ran  smoothly  and  quickly.  The  application  was  not 
challenging for applicants and could be developed in a timely manner. Most stakeholders 
interviews highlighted that this was exactly what was needed at that particular moment of 
an  emergency  situation  when  most  institutions  dealing  with  border  management 
(ministries  of  internal  affairs,  border  guard,  border  police)  had  other  priorities,  had  to 
manage the influx of refugees and staff was often delegated directly to the border.  

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  Conclusions 

As explained in the introduction, given the early stage of implementation of the member 
state  programmes,  which  were  only  adopted  end  of  2022,  the  mid  term  evaluation  is 
particularly focused on the identification of issues which may affect the implementation of 
the instrument, and on ways to reassess the programmes, if necessary. While addressing 
the  main  evaluation  criteria  of  relevance,  effectiveness,  efficiency,  coherence,  and  EU 
added value, the evaluation aims less at obtaining final conclusions on the effectiveness 
and efficiency of the programmes, than at obtaining evidence-based information on:  

•  Whether  the  instrument  is  addressing  the  needs  it  was  meant  to  address,  and 
whether it has been able to tackle new needs resulting from new challenges and 
developments in the policy context; 

•  whether the Member State programmes and the Commission work programmes for 
the Thematic Facility are fit for purpose and coherent with other national and EU 
funding instruments, and whether improvements should be introduced; 

•  whether  the  interventions  are  on  track  to  achieving  the  stated  objectives,  at  a 
reasonable cost, and which possible corrections may be introduced during the rest 
of the implementation of the interventions. 

This section aims at summarising the conclusions regarding the five evaluation criteria 

Effectiveness 

At  different  speeds,  the  interventions  funded  are  on  track  to  achieving  the  stated 
objectives.  

BMVI has made financial progress in implementing activities under Specific Objective 1 
(Border  management)  reflecting  the  strong  commitment  of  Member  States  to  enhance 
border control. Regarding Specific Objective 2, the progress towards the achievement of 
the objectives is clearly slower, likely as a result of the need to address the consequences 
of the Russian war of aggression in Ukraine in terms of border management and reception 
capacities.  

69 

 
 
In terms of performance, reporting has only recently started and it is not possible to come 
to  conclusions  on  effectiveness  yet.  Logically  at  this  stage,  achievements  in  terms  of 
meeting the 2024 milestones for common output and results indicators are very uneven 
across both Member States and the different areas of BMVI interventions. This is explained 
by  different  paces  in  implementation,  but  also  by  inconsistencies  in  what  exactly  is 
measured, as well as inappropriate definition of initial targets. 

Apart from the obvious lack of actual information on performance at this stage, with regard 
to programmes of Member States, the monitoring and evaluation framework is affected by 
several shortcomings: 

•  There  is  the  Managing  Authorities’  lack  of  familiarity  with  a  continuous 

monitoring and reporting system. 

•  There is the Managing Authorities’ insufficient understanding of the components 

of the monitoring system. 

• 

In  several  case  the  methodologies  for  target  setting  methodologies  did  not 
adequately address the objectives of the programmes. 

•  Annual performance reports miss the aim of efficiently sharing key messages on 

practical implementation. 

The case studies on EMAS and Ukraine conclude that emergency assistance effectively 
contributed to support countries in deploying interventions to face the crises that appeared 
even before the adoption of the programmes. This is notably the case for the consequences 
of Russia’s war of aggression against Ukraine and the instrumentalization of migrants at 
the Belarus border. 

On the involvement of partners, there seems to be room for a more consistent approach to 
the involvement of partners. It has been argued that border management and visa policy, 
and the activities involved, leaves little ground for the participation of many of the social 
actors envisaged in the CPR. However, the activities carried out at the external borders of 
the  Union  have  an  impact  on  the  free  movement  of  persons  and  goods,  as  well  as  the 
internal security of the Union, affecting economic actors such as travel agents, air carriers 
and transport professionals.  

When it comes to the respect of the horizontal principles defined in the CPR, they have 
been considered in the preparation and implementation of the programmes. However, the 
case studies and the consultations done show that there are few mechanisms to monitor the 
application of these principles. 

In terms of communication and visibility, all participating Member States have fulfilled 
their  obligations,  but  it  is  too  early  to  measure  the  effectiveness  of  these  measures  in 
reaching their targets. 

Efficiency 

As the information on performance is still insufficient, it is too early to carry out a 
full  cost-effectiveness  analysis,  but  there  are  indications  that  financial  progress  is 
advancing  efficiently.  However,  adjustments  are  still  needed  to  fully  ensure  an 
efficient delivery of the funding and reduce the administrative burden. 

70 

 
 
The BMVI has embedded cost-effectiveness elements at all levels in its design, through 
the implementation of rigorous project selection and procurement mechanisms. There is 
insufficient  evidence  of  effectiveness  at  this  stage  to  carry  out  a  comprehensive  cost-
effectiveness analysis of operations in any management mode. 

The progress in financial implementation, though at different speeds, seems to confirm that 
programmes are being implemented efficiently from an operational point of view, since at 
the mid term  stage, the programmes had committed an amount equivalent  to  the whole 
allocation in the previous instrument, ISF-BV. 

Implementation rates across Specific Objectives are moving at different speeds, leading to 
confirm a different pace in the effective completion of the activities and potential future 
challenges in the achievements of the fund’s objectives. 

An assessment of the system's architecture and design suggests that the system is structured 
to  operate  with  efficiency.  Based  on  the  desk  research  and  stakeholder  consultations 
conducted, management and control systems are designed with clearly assigned roles and 
responsibilities at both EU and national levels. 

Early  insights  from  mid  term  evaluations  across  the  Member  States  and  stakeholder 
consultations have highlighted concerns regarding the administrative burden, which may 
affect  both  Management  Authorities  and  beneficiaries.  Factors  that  may  affect  this 
perception are:  

•  The need to adapt to a new legal structure, as a result of the transition to the CPR. 

•  A stability in the level of human resources at Member State level, as compared to 

the previous instrument, having to take care of notably increased budgets. 

•  The learning curve to adapt to new reporting mechanisms and tools, which may be 

reduced with time. 

A particular case where the advantages introduced by the instrument are appreciated are 
the  Specific  Actions.  Stakeholders  consider  that  they  make  a  difference  in  terms  of 
flexibility and provision of ad-hoc additional funding for specific priority interventions. 
Some cases of gold-plating may however have been identified at Member State level. 

Technical assistance is consistently appreciated as a positive contribution to the effective 
and  efficient  implementation  of  management  and  control  systems.  Under  the  CPR, 
technical assistance is provided as a lump sum of six percent of the eligible expenditure 
included in each payment application. This amount is allocated to a specific objective in 
BMVI programmes and may support actions, which may concern previous and subsequent 
programming periods, necessary for the effective administration and use of those Funds, 
such  as,  inter  alia,  preparation,  training,  management,  monitoring,  evaluation,  visibility 
and communication (138). This approach provides reinforced flexibility when addressing 
these operational functions in the programmes. 

To  face  the  potential  administrative  burden,  Managing  Authorities  know  of  the 
simplification possibilities in the CPR, in particular related to simplified cost options and 

(138)  Art. 36 BMVI Regulation. 

71 

 
 
 
financing not linked to costs, but are not fully aware of how they work, which leads to a 
limited buy-in in some cases. 

The  establishment  of  IT  systems  at  Managing  Authority  level  is  a  promising  way  of 
ensuring more streamlined communication and reporting, shortening the duration of the 
processes and the administrative workload. 

Relevance 

The instrument is addressing the needs it was meant to address and has been able to 
respond to new challenges and developments in the policy area. 

All consulted stakeholders agree that the instrument is still relevant for the needs identified 
in the definition of the instrument and translated into the overall objective of the BMVI: to 
ensure strong and effective European integrated border management at the external borders 
(specific objective 1) and support the common visa policy (specific objective 2.) 

Both  Member  States  and  stakeholders  consider  that  the  interventions  supported  by  the 
BMVI address the most important needs - both structural long-term needs and emergency 
needs-, even when these needs have been evolving. Moreover, the mid-term evaluations 
and stakeholder consultations suggest that the recent geopolitical crises and its impact on 
migration flows, and border management have marked a shift in Member States towards 
measures  aimed  at  strengthening  EU’s  external  borders,  to  the  detriment  of  the  needs 
related to the development of the common visa policy.  

The  specific  architecture  of  the  instrument,  with  its  four  components  (Member  State 
programmes, Specific Actions, EMAS and Union Actions), appears as a strength in this 
capacity  to  react  to  emerging  needs.  This  architecture  has  permitted  to  fully  apply  the 
flexibility of the instrument to adapt to the changing context in which interventions take 
place. This has been acknowledged by all actors, in particular as regards the response to 
new and extremely pressing needs, such as those related to the war in Ukraine. 

Coherence 

The  Member  State  programmes  and  the  Commission  work  programmes  for  the 
Thematic  Facility  are  fit  for  purpose  and  coherent  with  other  national  and  EU 
funding instruments. 

The BMVI’s architecture is fit for purpose as it enhances internal coherence by fostering 
complementarity  across  components.  The  combination  of  the  four  components  of  the 
instrument (Member State programmes, Specific Actions, emergency assistance and Union 
Actions) and the three management modes (shared, direct and indirect) enables flexible 
fund management.  

There  are,  however,  limited  instances  where  the  strategic  approach  to  complementarity 
between  Specific  Actions  and  the  regular  actions  in  the  programmes  could  be  better 
developed to support complementarity. Similarly, barriers to working transnationally were 
identified for the uptake of Union Actions that undermine their specific focus.  

There are formal and informal mechanisms in place at both EU and national level to ensure 
complementarities and, where relevant, synergies across the different components. These 
occur at planning stage but are also built into their day-to-day management. Nevertheless, 
these mechanisms could be strengthened, particularly for Union Actions, where a higher 

72 

 
 
uptake  of  lessons  learnt  and  systematic  sharing  of  results  across  Member  States  could 
possibly reinforce other elements of implementation.  

The  BMVI  is  also  coherent  with,  and  therefore  contributes  to,  supporting  the  different 
components of the border management and visa policy. Some stakeholders emphasised the 
importance of the alignment between the BMVI and the national capability roadmaps, in 
order  to  ensure  the  continued  coherence  of  the  BMVI  with  the  EBCG  Regulation  and 
EIBM Strategy. 

A common migration and asylum system is key to supporting the area without controls at 
internal  borders.  The  three  Home Affairs  funds  need  to  be  acting  complementarily  to 
achieve  the  overarching  objective  of  a  fully  functioning  Schengen  area.  This  complex 
interdependence  requires  clear  priority  setting  at  national  level  and  adequate  level  of 
Commission steering where relevant, good coordination between all actors involved in the 
programming and implementation of national and EU funds. The aim is to ensure that the 
funding  effectively  contributes  to  achieving  the  overall  policy  objectives  in  an  optimal 
manner contributing to economies of scale. 

This interdependence creates challenges for the delivery of the overall policy objective but 
also brings opportunities for enhanced synergies and coordination. Stakeholders consulted 
held positive views on the coherence between BMVI and the other HOME Affairs funds 
(ISF  and  AMIF),  although  there  is  not  always  full  awareness  among  national  level 
stakeholders as to how synergies could be created (such as the use of the CPR provisions 
on multipurpose funding of equipment). 

As regards the coherence between the BMVI and other EU funds (ERDF, ESF+, CCEI)), 
it is conceptually sound and understood in general by stakeholders. However, coordination 
mechanisms  are  sometimes  not  fully  effective,  and  the  potential  for  synergies  and 
complementarities  are  not  always  visible  to  Managing  Authorities,  stakeholders  and 
beneficiaries. 

In the case of Horizon Europe, the potential of BMVI funding to increase the uptake of 
innovative technological solutions at the level of EU and national programmes is not fully 
developed.  EU  funding  could  contribute  further  to  ensuring  that  the  concepts  and  tools 
developed under Horizon lead to longer term testing and validation, and eventually ensure 
these capabilities are available to procure on the EU market.  

Finally, even though most interviewees were positive about the coordination mechanisms 
to  ensure  coherence  with  the  EU  external  action,  notably  as  regards  NDICI  and  IPA, 
several  of  them  found  that  the  coordination  processes  should  be  strengthened,  as  it 
currently heavily based on good ad hoc coordination. 

EU added value 

The BMVI’s added value lies in its ability to support projects extending beyond the 
financial and operational capacities of individual Member States.  

The  evidence  collected  through  consultations  and  case  studies  indicates  that  the  BMVI 
provides  an  added  value  by  supporting  projects  that  go  beyond  the  financial  and 
operational capacities of individual Member States. Stakeholders agree that by fostering 
cooperation,  ensuring  compliance  with  EU  standards,  and  alleviating  national  budget 

73 

 
 
constraints, the instrument significantly enhances the EU’s collective border management 
and visa policy framework. 

The evaluation shows a strong consensus among national authorities on the importance of 
EU support for border management and visa policy and underscores the EU’s essential role 
in maintaining security and visa management across the Union. 

5.2.  Lessons learned 

The flexibility of the instrument is an essential component in ensuring the achievement of 
its  objectives,  also considering the changing  context of implementation.  This  flexibility 
should continue to be available as it allows meeting unexpected needs in a  smooth and 
quick way. 

To make the most of the relevance of BMVI, it would be important to further reinforce the 
complementarity  and  coherence  between  its  different  components,  creating  the  right 
instruments  for coordination at  EU level,  but especially  at  the level  of the participating 
Member States. The preparation of Specific Actions should be done with a strategic view, 
aimed  at  avoiding  overlaps  or  inefficiencies.  Additionally,  innovative  methods  and 
approaches  developed  through  Union  Actions  should  continue  to  be  promoted  by  the 
Commission  to  make  sure  that  Member  States  and  stakeholders  are  aware  and  take 
advantage  of  them.  In  terms  of  progress,  BMVI  has  achieved  significant  operational 
progress  in  the implementation  of its  first specific objective (border management).  It  is 
important that the implementation of the objective to reinforce visa policy does not lag 
behind. 

There  seem  to  be  significant  shortages  in  staff  or  resources  in  the  implementation  and 
monitoring of the programmes, which are mostly running at the same level of resources as 
they did in the previous programming period. This issue needs to receive attention in order 
to avoid inefficiencies that would compromise the achievement of BMVI objectives. 

Regarding the implementation of the horizontal principles, it is worth considering the need 
to reinforce its promotion and monitoring during the implementation of the programmes. 

There is potential room for simplification using the possibilities offered by the CPR and 
the benefits of streamlined IT systems. These possibilities are still underused and could be 
further promoted in order to facilitate administration and implementation. Moreover, cases 
of  gold  plating  have  been  identified  by  the  evaluation.  This  should  be  consistently 
addressed in order to contribute to reduce the administrative burden to the strict minimum. 

Coordination with the other EU home affairs funds could be further reinforced. This seems 
particularly relevant in view of the implementation of the Pact on Migration and Asylum.  

At national level, mechanisms that ensure an appropriate awareness of the possibilities and 
of  the  other  funds  would  contribute  to  a  more  efficient  planning  and  design  of  the 
interventions. 

In  the  same  manner,  there  should  be  means  at  the  disposal  of  the  Commission  and  the 
Member States to make the most of the work done in terms of research and innovation in 
the  migration  and  border  management  field.  There  is  room  for  further  reinforcing  the 
continuum between research and implementation. 

74 

 
 
As  regards  the  relation  between  BMVI  interventions  and  external  actions,  there  is  an 
overall  perception  that  the  mechanisms  exist  but  work  on  a  mostly  ad-hoc  manner.  A 
reflection should take place on how to enhance the complementarity between BMVI and 
external actions, and how to further underpin a strategic approach to this aspect. 

There is a need to reinforce the understanding of the performance framework of the BMVI 
regulation.  While  Managing  Authorities  have  formally  complied  with  their  obligations, 
there is a lack of common understanding about the system, its use and its implementation. 
It would be useful to launch a general reflection in terms of target setting, as well as support 
the  Member  States  in  supplying  more  reliable  and  up-to-date  information  about  the 
progress made. It would also be relevant to explain better to Managing Authorities how 
the performance framework can contribute to the management of the programmes, beyond 
the purely formal reporting that is required by the regulation. 

This is a precondition to an improvement in quality of the system, so that it is fully able to 
provide the relevant input for the retrospective evaluation of the programme. To this end, 
the  Commission  will  continue  to  follow  up  the  reporting  of  implementation  data  and 
provide ad hoc recommendations to ensure the quality, consistency and reliability of the 
information on performance. 

Finally, a more inclusive approach to the principle of partnership, as defined in the CPR 
would possibly consolidate the broader added value of BMVI. The objectives and benefits 
of the instrument have a wider scope than the purely operational implementation of border 
controls and surveillance, or the processing and monitoring of visa permits. It seems that 
a better engagement of partners through a better coordination of their actions would benefit 
the implementation of BMVI. Increased stakeholder engagement would allow a stronger 
collaboration  with  all  partners  in  the  implementation  of  the  programmes,  including 
exchanging good practices and advice as well as experiences in the field.  

75 

 
 
 
ANNEX I: PROCEDURAL INFORMATION 

This evaluation has been carried out by DG HOME, as responsible for the implementation 
of BMVI in the Commission. The evaluation was launched May 2023. 

The evaluation has been carried out in accordance with the rules of Better Regulation, by 
applying the methods and requirements established in the Toolbox. However, given the 
early  stage  of  implementation  of  the  funds  when  carrying  out  the  evaluation,  and  the 
limited evidence available in terms of effectiveness of the funds, it has not been possible 
to  carry  out  a  fully-fledged  cost-benefit  analysis  as  required  by  the  Better  Regulation 
guidelines. Some elements are provided though as annex IV to this document. 

The evaluation was also based on the orientations provided by DG HOME to the Member 
States  regarding  the  mid  term  evaluation,  in  particular,  the  evaluation  questions  with 
indicative judgment criteria presented to the Managing Authorities during a webinar on 19 
April 2023. Both the programmes’ and the Commission’s mid term evaluations are based 
on the same set of questions and indicative methodological elements.  

The evaluation  has  been  steered  by  an  Interservice  Group,  with  the  participation  of  the 
operational and policy units in DG HOME, as well as the following DGs and services: SG, 
DG  BUDG,  DG  INTPA,  DG  JUST,  DG  REGIO,  DG  RTD,  DG  DEFIS,  JRC,  SJ,  DG 
ECHO, DG TAXUD, DG EMPL, DG MARE, and OLAF. 

The first meeting of the Interservice Group was held on 30 June 2023. During the meeting 
were  discussed  the  Specifications  for  the  preparatory  study  to  be  carried  out  with  the 
assistance of external consultants. Additional meetings of the Interservice group took place 
to discuss the deliverables of the preparatory study on 11 March 2024, 13 May 2024, 23 
July 2024 and 25 October 2024. The draft version of this Staff Working Document was 
submitted to the group in written consultation on 17 December 2024. 

The preparatory study was confided to a consortium made up of EY France, Fondazione 
Brodolini and Tetra Tech, following an open call for tender launched on 3 October 2023. 
The contract was signed on 27 February 2024. 

The evaluation is mostly based on the work done during the preparatory study, as explained 
in  Annex  II  and  III,  in  line  with  the  requests  in  the  Specifications  drafted  by  the 
Commission.  

Opinion of the Regulatory Scrutiny Board 

The draft Staff Working Document was submitted to the Regulatory Scrutiny Board during 
its meeting of 12 February 2025. 

The Board issued a negative opinion based on a number of weaknesses and identified some 
recommendations for improvement.  

The RSB identified the following key issues: 

(1) The findings do not reflect the limited evidence, data gaps and limitations. The report 
does not sufficiently analyse the significant variations in degrees of implementation among 
the  Member  States.  It  is  not  clear  what  the  baseline  for  measuring  progress  towards 
achieving the objectives is, considering the absence of evaluation of the Fund’s previous 
programming period 2014-2020.  

76 

 
 
(2)  It  is  not  sufficiently  clear  in  the  report  whether  the  monitoring  and  evaluation 
framework in place will allow for robust conclusions to be drawn in the final evaluation of 
the program.  

(3) The report does not sufficiently analyse the administrative costs.  

(4) The assessment of coherence with the Pact on Migration and Asylum and other EU 
funds is not sufficient. The report does not adequately assess the additionality of the BMVI 
to the broader efforts of the Member States in these policy areas. 

The follow up to the above issues and the Board’s more specific suggestions on what to 
improve are displayed in the table below.  

Recommendation 

Follow-up 

References to the evidence from which findings and 
conclusions  are  drawn  have  been  consistently 
reinforced through the document. 

This has been applied through the report.  

should  more 
report 
The 
systematically 
the 
to 
refer 
existing evidence base and bring 
in  more  elements 
the 
support study and case studies. 

from 

The conclusions should be more 
nuanced  and  better  aligned  with 
the  evidence  available  and  its 
limitations.  In  particular, 
the 
conclusions on effectiveness and 
efficiency should be more clearly 
linked to available evidence 

on 

progress 

Reporting 
in 
financial  implementation  is  not 
sufficient  as  evidence  of  the 
effectiveness and efficiency, and 
to  allow  to  conclude  that  the 
programme is on track to achieve 
its objectives. 

Limited information on achievements was expected 
from the outset of the evaluation process, this being 
a  mid-term  evaluation  that  comes  too  early  in  the 
implementation of the Instrument to draw significant 
information  on  effectiveness  and  efficiency.  This 
fact that evidence on the progress of the operations 
was unlikely to suffice for a sound investigation on 
the net effects or impacts of the fund, and the focus 
should lie on whether the current programming and 
implementation  arrangements  appear  conducive  to 
effectiveness  as 
implementation  unfolds,  was 
acknowledged by the ISG at the start of the work in 
this evaluation. 

in 

The  progress  in  financial  reporting  has  not  been 
considered 
the  evaluation  as  evidence  of 
effectiveness.  The  evaluation  concludes  that  “The 
progress  in  financial  implementation,  though  at 
different speeds, seems to confirm that programmes 
from  an 
implemented  efficiently 
are  being 
operational  point  of  view,  since  at  the  mid  term 
stage,  the  programmes  had  committed  an  amount 

77 

 
 
 
Recommendation 

Follow-up 

The report should be clear about 
the baseline and describe also in 
quantitative  terms  how  progress 
towards  attaining  objectives  is 
measured  and  against  what 
baseline. 

As  far  as  possible  the  report 
should refer to the results of the 
final  evaluation  of  the  funds 
under the previous programming 
period. 

equivalent  to  the  whole  allocation  in  the  previous 
instrument, ISF-BV.” This has been clarified in the 
conclusions (p. 69). 

On p. 22, the reference to implementation being on 
track does not refer to the fact that objectives will be 
achieved.  It  is  made  clear  that  there  are  still 
challenges and the evaluation has not enter into an 
assessment of effectiveness. 

Additional  information  to  explain  this  finding  has 
been provided on p. 23. 

Additional  information  has  been  provided  in  the 
section  on  points  of  comparison,  regarding  the 
performance framework and the way of measuring 
progress. 

As  explained  in  the  revised  version  (section  2.2): 
“Even if the mid-term evaluation focuses mostly on 
the situation, achievements and progress during the 
initial  implementation  of  BMVI,  the  evaluation  of 
the previous programming period might have been a 
useful input in terms of comparison.  

As a  response to  the Russian war of aggression  to 
Ukraine,  the  implementation  period  of  the  Home 
Affairs Funds 2014-2020 was extended by one year, 
to allow the Member States to fully use any unspent 
amounts  under 
the  2014-2020  programmes. 
Accordingly, the final implementation period ended 
on  30  June  2024;  the  national  ex-post  evaluations 
were due on 31 December 2024 and the Commission 
ex post evaluation on 30 June 2025 (Article 1(5) of 
Regulation  (EU)  2022/585  of  6  April  2022). 
Therefore,  the  ex-post  evaluation  study  was  still 
ongoing  at  the  time  of  drafting  this  Staff  Working 
Document,  and  its  findings  and  conclusions  could 
not be used.  

Nevertheless,  as  explained  in  chapter  1,  both  the 
mid-term  and 
the  ex  post  evaluations  were 
implemented simultaneously, in order to maximise 
synergies. Some tools, such as the case studies, the 
surveys  and  the  interviews  were  common  to  both 
evaluations. Accordingly, elements from the ex post 
evaluation are by definition part of the mid-term and 
vice  versa,  since  these  specific  tools  looked  at 

78 

 
 
Recommendation 

Follow-up 

The  report  should  analyse  the 
on 
different 
implementation  among  Member 
States and underlying causes. 

degrees 

The  report  should  describe  in 
more  detail  the  monitoring  and 
evaluation  framework  in  place 
and assess the extent to which the 
data collected will allow to track 
progress  on  all  elements  of  the 
intervention logic and will allow 
to  evaluate  the  achievement  of 
the  programme’s  objectives  in 
the final evaluation. It should be 
explicit 
and 
information  that  Member  States 
provide in their regular reporting 
and  identify  any  issues  or  gaps 
that would need to be addressed. 

about 

data 

The  report  should  provide  more 
details 
of 
administrative costs. 

assessment 

and 

implementation as a continuum. This has allowed to 
have retrospective view, as well as complying with 
the requirement in the BMVI regulation (139) to take 
the  retrospective 
into  account 
evaluation for the 2014-2020 period.” 

the  results  of 

This has been reinforced in section 4.1.1., within the 
limits of the information available at this stage. As 
explained  in  the  chapter,  the  different  degrees  in 
implementation  seem  to  be  linked  to  the  different 
implementation rhythms in each Member States as 
well as to the impact of the external context, notably 
the Ukrainian crisis, in the selection of projects to be 
prioritised. 

in 

It is useful to highlight that data available at the cut-
off  date  point  (30  June  2024) 
terms  of 
implementation and performance do not necessarily 
reflect the actual progress of implementation. Since 
transmission  of  performance  data  occurs  twice  a 
year,  and  is  not  aligned  with  the  provision  of 
financial information, there is always a gap between 
two, which may provide a distorted view of actual 
implementation levels. 

This has been reinforced in sections 2.2, 4.1 and 5.2 

This aspect has been reinforced in section 4.1.2 of 
the  evaluation  and  Annex  IV.  However,  as 
mentioned  in  the  report,  there  is  a  challenge  in 
evaluating  these  practices,  other  than  through 
qualitative assessment, as there is no system in place 
to  track  and  measure  the  cost-effectiveness  of  the 
actions taken by those who receive funds from the 

(139) Article 28(1). 

79 

 
 
 
Recommendation 

Follow-up 

to 

indicators 

program.  Data  on  financial  implementation  is  not 
connected 
the 
the  performance 
Managing Authorities need to report on. As a result, 
it  is  difficult  to  analyse  the  financial  investment 
against the results for each specific type of activity 
to determine which ones are giving the best value for 
money.  Some  more  in-depth  work  should  be 
possible  during  the  retrospective  evaluation,  once 
information  becomes  more  complete  and  work  on 
unit costs can be developed.  

It  should  analyse  to  what  extent 
the  perceptions  of  national 
authorities  of  complexity  and 
cumbersome  reporting  are  valid 
and  assess  any  margin 
for 
improvement, simplification and 
burden reduction. 

This has been reinforced in section 4.1.2, within the 
limits described in the previous section. 

As  stakeholders  pointed  out,  the  administrative 
burden  they  currently  perceive  is  a  natural  by-
product  of  the  learning  process  to  adapt  to  new 
regulatory  and  reporting  requirements,  as  well  as 
new ways of working. 

the  current  degree  of 
Given 
implementation, 
report 
the 
should analyse the types of costs 
and 
underlying 
methodology. 

provide 

See the previous two comments. 

coherence 

the  programme 

The 
assessment 
should  better  explain  the  extent 
to  which 
is 
aligned  with  other  EU  funds 
(such as RFF and ESIF) and with 
the  Pact  on  Migration  and 
Asylum. 

The  report  should  better  assess 
the  additionality  of  BMVI  to 
measures  funded  by  Member 
States and analyse any data gaps 
which could hamper the analysis 
of  additionality 
the  final 
evaluation. 

in 

This element has been substantially reinforced in the 
revised version. 

The  revision  of  the  Staff  Working  Document  has 
consolidated the conclusion that the BMVI provides 
an  added  value  by  supporting  projects  that  go 
beyond  the  financial  and  operational  capacities  of 
individual  Member  States.  The 
information 
available,  progressively  reinforced  through  time, 
will allow to deepen this analysis in the retrospective 
evaluation,  by  providing  more  quantitative 
information  on  the  benefits  of  the  instrument.  The 
extent to which the EU funding reinforces the border 
management  budget  of  Member  States  cannot  be 
fully assessed in quantitative terms and it is subject 
to variations between Member States. 

80 

 
 
ANNEX II: METHODOLOGY AND ANALYTICAL MODELS USED 

This chapter presents the methodology employed for the mid term evaluation of the BMVI 
2021-2027 and the limitations encountered.  

Methodology 

The  evaluation  was  supported  by  an  external  study  that  was  divided  into  four  phases: 
inception, interim, data collection and finalisation.  

The inception phase was characterised by preparing the work to be done. This included 
preliminary desk research, scoping interviews, developing an intervention logic, and the 
refinement of the methodological approach to be used. The inception phase concluded with 
the production of an inception report which was discussed during a meeting of the Steering 
Group, revised by the contractors to incorporate the Commission’s feedback, and later the 
final inception report was approved. 

The interim phase focused on gathering data by completing the desk research, synthesising 
and analysing the annual performance reports submitted in 2023 and 2024, a review of the 
Member State mid term evaluations, reviewing a sample of target setting methodologies, 
and mapping the allocations by type of intervention and target group. This phase concluded 
with  an  interim  report  which  was  discussed  with  the  Steering  Group,  revised  and  then 
accepted.  

During the data collection phase, the focus was on collecting the remaining data necessary 
for  the  study.  This  included  obtaining  quantitative  and  qualitative  data  from  SFC2021, 
reviewing  EU  and  national  documents,  interviews  with  stakeholders,  and  conducting  a 
targeted survey.  

In the final phase, the findings were synthesised and triangulated, to formulate replies to 
the evaluation questions and draw conclusions. Furthermore, the second EU level focus 
group  was  held  to  validate  the  evaluation  findings  and  develop  lessons  learned.  The 
contractors  delivered  a  draft  final  report  which  was  discussed  in  a  meeting  with  the 
Steering Group.  

The draft staff working document was then shared with the Steering Group for a written 
consultation.  

Regarding  the  data  collection  methods,  the  desk  research  included  the  review  of  the 
legislation, BMVI work programmes of the Thematic Facility, evaluation reports at the EU 
and national level, the annual performance reports submitted in 2023 and 2024, notes to 
the Home Affairs Funds Committee, studies and more.  

Furthermore, data on financial allocations, financial progress and implementation progress 
was  extracted  from  SFC2021.  The  data  was  reviewed  by  management  mode,  specific 
objective, Member State and field of intervention to develop the state of play.  

Regarding  the  consultation  activities,  EU  level  interviews  were  conducted  with  the 
officials from DG HOME, DG NEAR, DG ENPL, Frontex, DG JUST, DG TAXUD, DG 
INTPA,  the  EEAS,  IOM,  UNHCR  and  ICMPD.  The  interviews  included  scoping 
interviews  and  semi-structured  interviews  to  gather  data  for  the  analysis,  including  the 

81 

 
 
 
country case studies and thematic case studies. Further interviews were conducted for the 
case studies including with national authorities and beneficiaries.  

Two EU level focus groups were held during the study. The first EU level focus group 
was  held  in  person  on  the  25  June  2024.    The  focus  group  consisted  of  Managing 
Authorities  and  project  beneficiaries.  The  focus  group  focused  of  presenting  the 
intervention logic, mapping needs, and understanding the extent to which needs were met 
by the instrument. 

The  second  focus  group  was  held  on  15  October  2024  and  consisted  of  Commission 
officials, Managing Authorities, Frontex, ICMPD, and an NGO. The objective of the focus 
group was to validate the evaluation findings and further develop the lessons learned.  

In addition to the focus groups, three targeted surveys were launched to target various 
stakeholders (national authorities, beneficiaries and other stakeholders). The analysis of 
the survey results fed into the main analysis.  

The study included eight country case studies (HR, CZ, EL, IT, NO, PL, RO and ES) to 
dive  deeper  into  the  implementation  of  the  BMVI  to  identify  challenges  encountered, 
specific processes, and best practices. The study also included five thematic case studies 
on Union Actions, EMAS, the impact of the Russian war of aggression towards Ukraine, 
Specific Actions, and the contribution to horizontal priorities. The thematic case studies 
allowed  for  deep-dives  into  certain  aspects  of  the  instrument  and  specific  topics  by 
reviewing specific projects.  

Based on the work described above, the final report for the mid term evaluation was drafted 
and approved. 

Output  and  result  indicators  defined  in  Annex  VIII  of  the  BMVI 
regulation 

Specific objective set out in point (a) of Article 3(2) (SO.1) 

Output indicators (O.1) 
1. The number of items of equipment purchased for border crossing points: 

1.1. of  which  the  number  of  automated  border  control  systems/self-service  systems/e-

gates purchased. 

2. The number of items of infrastructure maintained/repaired. 
3.  The number of hotspot areas supported. 
4. The number of facilities for border crossing points constructed/upgraded. 
5. The number of aerial vehicles purchased: 

5.1.  of which the number of unmanned aerial vehicles purchased. 

6.  The number of maritime transport means purchased. 
7.  The number of land transport means purchased. 
8. The number of participants supported: 

8.1.  of which the number of participants in training activities. 

82 

 
 
 
 
 
 
 
 
 
 
 
 
9. The number of immigration liaison officers deployed to third countries. 
10. The number of IT functionalities developed/maintained/upgraded. 
11. The number of large-scale IT systems developed/maintained/upgraded: 

11.1.  of which the number of large-scale IT systems developed. 
12.  The number of cooperation projects with third countries. 
13. The number of persons who have applied for international protection at 

border crossing points. 

Result indicators (R.1) 
14. The number of items of equipment registered in the technical equipment 

pool of the European Border and Coast Guard Agency. 

15. The number of items of equipment put at the disposal of the European 

Border and Coast Guard Agency. 

16. The number of initiated/improved forms of cooperation of national 
authorities with the EUROSUR national coordination centres. 

17. The number of border crossings through automated border control systems 

and e-gates. 

18. The number of addressed recommendations from Schengen evaluations and 

from vulnerability assessments in the area of border management. 

19. The number of participants who report three months after a training activity 
that they are using the skills and competences acquired during that training 
activity. 

20. The number of persons refused entry by border authorities. 

Specific objective set out in point (b) of Article 3(2) (SO 2) 

Output indicators (O.2) 
1. The number of projects supporting the digitalisation of visa processing. 
2.  The number of participants supported: 

2.1.  of which the number of participants in training activities. 
3. The number of staff deployed to consulates in third countries: 
3.1.  of which the number of staff deployed for visa processing. 

4. The number of IT functionalities developed/maintained/upgraded. 
5. The number of large-scale IT systems developed/maintained/upgraded: 

5.1.  of which the number of large-scale IT systems developed. 
6. The number of items of infrastructure maintained/repaired. 
7.  The number of real estates rented/depreciated. 

Result indicators (R.2) 
8. The number of new/upgraded consulates outside the Schengen area: 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8.1. of which the number of consulates upgraded to enhance client-friendliness for visa 

applicants. 

9. The number of addressed recommendations from Schengen evaluations in the 

area of the common visa policy. 

10.  The number of visa applications using digital means. 
11. The number of initiated/improved forms of cooperation set up among 

Member States in visa processing. 

12. The number of participants who report three months after a training activity 
that they are using the skills and competences acquired during that training 
activity. 

84 

 
 
 
 
 
 
 
 
 
 
 BMVI 2021-2027 Intervention Logic 

85 

 
 
 
 
 
 
 
 
 
Limitations and mitigation measures 

The  study  encountered  several  limitations  that  were  mitigated  to  the  greatest  extent 
possible.  

The first limitation was the inconsistent availability, quality and levels of granularity of 
data across the Member States. This made it difficult to conduct trend analysis and make 
comparisons across Member States.  The study team mitigated this challenge by seeking 
further information when needed and employing protocols to ensure data reliability.  

Secondly,  some  stakeholders  had  difficulty  distinguishing  between  the  2014-2020  and 
2021-2027 programming periods. The study made efforts to attribute the findings to the 
correct programming period.  

Third, as the study was conducted at the same time as the AMIF and ISF evaluations, and 
participation  in  the  targeted  survey  was  voluntary,  survey  fatigue  may  have  set  in  and 
caused a lower response rate.  

Finally,  the  output  and  result  indicators  data  transmitted  by  the  Member  States  via 
SFC2021 included a number of omissions, clerical errors, and revealed differences in how 
Member States interpret, measure and report data. The data was reviewed for consistency 
and  plausibility,  and  corrected  where  possible.  Furthermore,  not  all  Member  States  set 
milestones and targets. Of those that did, there were varying levels of ability to set realistic 
milestones and targets.  

86 

 
 
 
ANNEX III: EVALUATION MATRIX 

Relevance 

Evaluation Question 
EQ12. To what extent does the 
the  evolving 
fund  address 
needs? 

Judgment criteria 
The objectives and type of activities 
of the BMVI programme addressed 
the needs of stakeholders in the 
area of: 
• 
•  Common visa policy 
at the time of the implementation 

Integrated border management  

•  Documentary evidence that the funds 

Indicators 

Sources 
•  Desk research including BMVI impact assessment and 

ISF-BV evaluation. 

•  Mapping of the scope of investments and target groups 

• 

addressed  
Insights from Focus Group 1 (dealing with analysis of 
needs) 

•  Surveys of relevant national authorities within Member 

States 

•  Survey of other relevant national authorities, 

competence centres, experts at EU and national level 
•  Survey of beneficiaries under National Programmes 
•  Public Consultations 
• 
•  Country case studies 
•  Thematic case studies (in particular case studies 1 -4) 

Interviews with EU stakeholders  

objectives rely on diagnosis 
/studies/assessment of border management 
and visa policy needs in the EU and make 
direct reference to them (needs are identified) 

•  Evidence (from documents or reported by 
stakeholders) of consultation with relevant 
stakeholders /target group 

•  Stakeholders’ feedback on the extent to which 
they consider that the objectives and activities 
of the Fund addressed the needs of the EU, 
Member States, and citizens 

•  Evidence (from documents or reported by 

stakeholders)  that the flexibility offered by 
the Fund (i.e., transfers of money between 
different objectives) helped to address 
changing needs and emerging challenges (e.g. 
COVID-19 or country specific crisis) 

•  Mapping of sum allocated to Member States 
(assessment of whether priority/key Member 
States received the most funding). 

87 

 
 
 
 
Evaluation Question 

Judgment criteria 
The objectives and type of activities 
of the BMVI programme continued 
to address the needs of relevant 
stakeholders during the 
implementation  of the programme 
(2021-December 2023) 

EQ 13. To what extent can the 
fund  adapt 
the  evolving 
to 
needs? 

The BMVI programme is flexible 
enough to remain relevant as and 
when circumstances change and 
challenges emerge  
The thematic facility focuses on the 
key priority needs and key target 
groups. 

Indicators 
•  Stakeholders’ opinion on the extent to which 
the objectives and activities of the BMVI 
addressed their needs  
Identification of any unmet stakeholders’ 
needs 

• 

•  Examples where the BMVI programme 
showed flexibility/was able to adapt to 
unexpected changes/ external factors (e.g. 
COVID-19, the Russian war of aggression in 
Ukraine or country specific crisis) 

•  Stakeholders’ opinion on the flexibility of the 
BMVI and the relevance of the thematic 
facility to respond to emerging challenges and 
needs 

•  Evidence (from documents or reported by 

stakeholders) of the Thematic Facility ability 
to respond to emerging or unforeseen needs, 
changing EU priorities or evolving challenges 

•  Evidence (from documents or reported by 

stakeholders) of rules and procedures in place 
that ensure that the substantial adjustments of 
the fund can be implemented in due time if 
new needs arise. 

•  Evidence (from documents or reported by 
stakeholders)  that continuous needs 
assessment are performed on a regular basis 
or whenever there are relevant contextual 
changes at the national level (considering the 
National Programmes implementation) and 
transnational level (for Union Actions) 
•  Evidence (from documents or reported by 

88 

Sources 

•  Country case studies  
•  Mapping of the scope of investments and target groups 

• 

addressed  
Insights from Focus Group 1 (dealing with analysis of 
needs) 

•  Surveys of relevant national authorities within Member 

States 

•  Survey of other relevant national authorities, 

competence centres, experts at EU and national level 
•  Survey of beneficiaries under National Programmes 
• 
•  Thematic case studies (in particular case studies 1 -4) 

Interviews with EU stakeholders  

•  Desk research risk analysis reports, vulnerability 
assessment and foresight studies where available 
(analysis of future trends)  

•  Mapping of the scope of investments and target groups 

• 

addressed  
Insights from Focus Group 1 (dealing with analysis of 
needs) 

•  Surveys of relevant national authorities within Member 

States 

•  Survey of other relevant national authorities, 

competence centres, experts at EU and national level 
•  Survey of beneficiaries under National Programmes 
•  Public Consultations 
• 
•  Country case studies 
•  Thematic case studies (in particular case studies 1 -4) 

Interviews with EU stakeholders  

 
 
 
 
Evaluation Question 

Judgment criteria 

Indicators 

Sources 

stakeholders) of mechanisms and/or 
consultative process, such as the partnership / 
monitoring committee, to engage with 
stakeholders and ensure the continued 
relevance of Fund to address changing needs 
by providing timely input on evolving needs 
and relevant developments on the ground 
(e.g., changes in migratory pressures, threats 
of cross-border crime, and the need to 
maintain a balance between security concerns 
and facilitating legitimate travel). 

•  Stakeholders’ opinion on the flexibility of the 
BMVI and the relevance of the thematic 
facility to respond to emerging challenges and 
needs 

•  Sums allocated to the thematic facility to 

respond to emerging needs (as a % of the total 
BMVI fund) 

Effectiveness 

Evaluation Question 

Judgment criteria 

Indicators 

Sources 

EQ1. To what extent is the 
fund on track to achieving its 
objectives? 

The expected outputs and significant 
progress to achieve their targets: 
• 
(SO1) European Integrated 
border management, to 
facilitate legitimate border 
crossings, to prevent + detect 
illegal immigration and cross-
border crime + to effectively 

Assessing progress to achieve outputs against expected outputs 
and  objectives  in  the  implementation  of  the  Integrated  border 
management  (SO1)  and  the  common  visa  policy  (SO2)  across 
MS: 
• 

Increase of developed/ maintained/upgraded IT 
equipment/equipment; 
Increase cooperation and staff with 3rd countries. 

• 

Documentary review: 
•  Programme documents (National 

Programmes, national evaluation plan, 
Annual Performance Reports (APR) 
submitted in 2023 and 2024, financial data 
from SFC2021 and COMPASS, etc.)  
Interviews with DG HOME stakeholders 

• 

89 

 
 
Evaluation Question 

Judgment criteria 

Indicators 

Sources 

• 

manage migratory flows 
(SO2) Common visa policy to 
ensure a harmonised approach 
with regard to the issuance of 
visas + to facilitate legitimate 
travel, while helping to prevent 
migratory + security risks 

and other EU stakeholders including staff 
managing Fund  
•  Country case studies 
•  Surveys 
•  Focus groups 

90 

 
 
 
Evaluation Question 

Judgment criteria 

Indicators 

Sources 

EQ2. To what extent is the 
monitoring and evaluation 
framework suitable to inform 
on the progress towards the 
achievement of the objectives 
of the instrument? 

•  The monitoring and evaluation 

•  Number of Managing Authorities, Intermediate Bodies, 

framework ensures the 
reliability of data provided by 
Member States through a robust 
electronic data exchange 
system, fostering accurate 
reporting and informed 
decision-making. 

and beneficiaries with documented internal procedures to 
ensure the accuracy and reliability of reported data.  
•  Level of understanding based on stakeholders’ judgement 
of monitoring requirements among stakeholders involved 
in data supply process. 

Documentary review: 
•  Programme documents (National 

• 

Programmes, national evaluation plan, 
Internal regulation of the monitoring 
committee, Annual Performance Reports 
(APR) submitted in 2023 and 2024) 
Interviews with relevant stakeholders 
(Managing Authorities, Intermediate Bodies 
and beneficiaries)  
•  Country case studies 
•  Surveys 
•  Focus groups 

Documentary review: 
•  Programme documents (National 

Programmes, national evaluation plan, 
Internal regulation of the monitoring 
committee, Annual Performance Reports 
(APR) submitted in 2023 and 2024) 
Interviews with relevant stakeholders 

•  The utilization of common and 
fund-specific indicators enables 
the comprehensive capture of 
the Fund's achievements and 
facilitates robust ex-post 
evaluation. 

•  Number of common indicators included in monitoring and 

evaluation framework that align with Fund's intervention 
logic. 

•  Evidence of data collected that supports estimation of 

impacts attributable to the Fund with a clear causal link. 

•  Evidence from stakeholders on the comprehensiveness of 
monitoring system in capturing project performance and 

• 

91 

 
Evaluation Question 

Judgment criteria 

Indicators 

Sources 

outcomes. 

EQ3. How was the 
involvement of the 
relevant partners 
ensured across all 
stages of the 
programming, 
implementation, 
monitoring and 
evaluation? 

•  The active engagement of 
relevant partners in the 
monitoring committee (non-
exhaustive), reflecting their 
consistent participation across 
various stages of the fund cycle, 
is assessed. 

•  Evidence of relevant partners identified and involved in 

the monitoring committee (non-exhaustive), in accordance 
with their defined roles as per the relevant rules of 
procedure. 

•  Evidence of the effectiveness of communication channels 
utilized to engage relevant partners across all stages of the 
fund cycle is assessed. 

EQ4. To what extent does 
the fund respect or promote in 
its 
implementation the 
horizontal 
principles? 

•  The instrument actively 
promotes and adheres to 
horizontal principles, including 
the charter of fundamental 
rights of the EU, gender 
equality, prevention of 
discrimination, and sustainable 
development, across all stages 
of implementation, is assessed. 

•  Evidence of organizational and procedural arrangements 
are in place to ensure compliance with the charter of 
fundamental rights of the EU in all aspects of fund 
implementation. 

•  Evidence of organizational and procedural arrangements 

in promoting gender equality and mainstreaming across all 
stages of fund preparation, implementation, monitoring, 
reporting, and evaluation. 

•  Evidence of organizational and procedural arrangements 
to prevent discrimination on all grounds throughout the 
programming cycle. 

•  Evidence of organizational and procedural arrangements 

92 

(Managing Authorities, Intermediate Bodies 
and beneficiaries)  
•  Country case studies 
•  Surveys 
•  Focus groups 

Documentary review: 
•  Programme documents (National 

• 

Programmes, national evaluation plan, 
Internal regulation of the monitoring 
committee, Annual Performance Reports 
(APR) submitted in 2023 and 2024) 
Interviews with relevant stakeholders 
(Managing Authorities, Intermediate Bodies 
and beneficiaries) 
•  Country case studies 
•  Surveys 
•  Focus groups 
Documentary review: 
•  Programme documents (National 

Programmes, national evaluation plan, 
Internal regulation of the monitoring 
committee, framework to report a breach 
and/or violation of the charter, Annual 
Performance Reports (APR) submitted in 
2023 and 2024) 
Interviews with relevant stakeholders 
(Managing Authorities, Intermediate Bodies 
and beneficiaries)  
•  Country case studies 

• 

 
Evaluation Question 

Judgment criteria 

Indicators 

Sources 

EQ5. To what extent is the 
fund effective in 
communicating and 
disseminating on its 
opportunities as well as 
achievements? 

•  The instrument effectively 

communicates and disseminates 
information on its opportunities 
and achievements. 

ensure alignment with the objective of promoting 
sustainable development, including consideration of the 
UN Sustainable Development Goals, the Paris Agreement, 
and the "do no significant harm" principle 

•  Surveys 
•  Focus groups 

•  Number and types of channels employed to disseminate 
information about the instrument’s opportunities and 
achievements at all levels (UE, MS and beneficiaries) 
•  Stakeholders’ judgment on whether they feel informed 

about the opportunities and achievements of the fund 
•  Evidence of the fund's communication efforts reach the 

intended target audience and engage them effectively with 
information on fund opportunities and achievements.  

•  Evidence of clarity and accessibility of information 
provided by the fund regarding its opportunities and 
achievements, as perceived by stakeholders. 

•  Evidence of utilization and effectiveness of various 

communication channels employed by the fund to 
disseminate information. 

Documentary review: 
•  Programme documents (National 

• 

Programmes, national evaluation plan, 
Internal regulation of the monitoring 
committee, Annual Performance Reports 
(APR) submitted in 2023 and 2024) 
Interviews with relevant stakeholders 
(Managing Authorities, Intermediate Bodies 
and beneficiaries)  
•  Country case studies 
•  Surveys 
•  Focus groups 

93 

 
 
 
 
 
 
 
Efficiency 

Evaluation question 

Judgment criteria 

Indicators 

Sources 

EQ6. To what extent does the 
fund  support  cost-effective 
measures? 

EQ7.  To  what  extent  is  the 
management 
control 
system efficient? 

and 

•  The fund supports types of 

interventions and types of actions 
that are known to be cost-
effective, based on available 
evidence, including relevant 
literature or the ex-post evaluation 
of the previous fund 

•  The early evidence coming from 
the operations indicates that the 
cost per unit is in line or below 
existing benchmarks and estimates  
•  The differences in the cost per unit 
among similar operations within 
the same fund can be explained 
and justified (e.g., by differences 
in the intensity or quality of the 
support offered, innovativeness, 
etc.) 

•  Overall resources (human and 
financial) are allocated to 
technical assistance per member 
states 

•  Financial allocation per MS and per types of actions 
•  Absorption rate per MS and overall 
•  Result and Output indicators as per Core performance 

•  Annual Implementation Reports, Work 

programmes, annual reports 

•  Survey for responsible authorities and 

Indicators (2021-2027). 

•  Stakeholder perception on the level of cost-

effectiveness of Union Actions   

•  Stakeholder perception of the Level of cost-
effectiveness of Emergency Assistance 

beneficiaries 

Interviews  

•  Country case studies 
• 
•  Thematic case studies 
•  Previous Evaluations 
•  SFC2021 
•  National evaluation reports 

•  Annual Implementation reports 
•  Country case studies 
•  Online survey 
•  Thematic case studies 

•  Share of MS that report mechanisms in place at MS 
level to detect and prevent fraud and irregularities 

•  Number of follow up cases of fraud and other 

irregularities (where possible, analysed by country) 
•  The extent to which the consulted stakeholders consider 

the technical assistance is used to strengthen the 
management and control system 

•  Share of Stakeholders have issues in reporting and 
introducing data in the electronic data exchange 

94 

 
 
Evaluation question 

Judgment criteria 

Indicators 

Sources 

systems 

•  MS that report there are mechanisms in place that 

evaluate the level of cost-effectiveness to select the 
beneficiaries (for direct and indirect management, 
emergency or innovative actions) 

•  The extent to which the NPs, the EMAS and UA 

produced spill-over effects 

95 

 
Evaluation question 

Judgment criteria 

Indicators 

Sources 

EQ8. To what extent is further 
achievable? 
simplification 
How? 

•  Simplified cost options used 
create simplification on the 
ground 

•  Share of MS that used simplification measures (e.g., 

simplified cost options) into the National Programmes 

•  The extent to which consulted stakeholders consider the 

•  Annual Implementation reports 
•  Country Case studies 
•  Online survey 

•  There is room for additional use 
of simplified cost options and 
financing not linked to costs 
options 

simplification measures used in the implementation of 
National Programmes were effective 

•  The extent to which the consulted stakeholders consider 
there is room for additional use of simplified cost 
options and financing not linked to costs options 
•  Perception of stakeholders regarding the adequacy of 

the administrative burdens 

•  The extent to which the consulted stakeholders consider 
there is room for additional use of simplified cost 
options and financing not linked to costs options 

96 

 
 
Judgment criteria 

•  The structures of the Fund with 

Indicators 
•  Documentary evidence and/or 

Coherence 

Evaluation Question 
EQ9. To what extent is the 
fund coherent with initiatives 
supported under its policy 
domain, in particular with 
support under the thematic 
facility across the different 
management modes? 

(we interpreted this question 
as being about the internal 
coherence of the funds) 

the Thematic Facility component, 
ensured greater complementarities 
and, where relevant, synergies 
across the different management 
modes  

•  There are coordination 

mechanisms in place to ensure 
coordination, complementarities 
and,  

•  where relevant, synergies across 
the different management modes  

stakeholders’ opinion on synergies 
and/or duplication across the different 
management /implementation modes of 
the Fund (i.e. the National Programmes 
under shared management and the 
thematic facility under a combination of 
shared and in-/direct management).  

•  Documentary evidence and/or 

stakeholders’ opinion on the existence 
and use of coordination mechanisms or 
process within the Fund to ensure 
complementarity between the different 
management modes 

•  Stakeholders’ justification for (potential) 
overlap (e.g. same target group but 
different type of measure/ different need 
addressed/ different readiness of the type 
of funding support chosen) 

•  Stakeholders’ perception on the internal 
coherence of the management mode and 
the use of the thematic facility 
•  Documentary evidence of alignment 
between BMVI objectives and EU 
policies, strategies, and legal framework 
(including CPR) 

•  Documentary evidence and/or 

stakeholders’ opinion on synergies or 
duplications /overlaps between BMVI 

97 

Sources 

•  EU level desk research: review of programme documents 

(e.g., multi-annual workplans) and internal coordination 
mechanisms 
Interviews with DG HOME BMVI stakeholders (internal 
coherence)  

• 

•  Thematic case studies on the different management mode 

•  EU level desk research, including review of programme 
documents (e.g., multi-annual workplans) EU policy and 
strategy documents (e.g., CCEI documentation, documents 
on approach to Home Affairs Funds, New Pact on Migration 
and Asylum; EIBM strategy, etc.,) and Member States 
implementation reports (e.g., identification of challenges 
related to the coherence)  

EQ10. To what extent is the 
fund coherent with other EU 
funds (including other Home 
Affairs funds), and in 
particular with EU’s external 
action? 

•  BMVI is (externally) coherent 
(identification of synergies or 
duplications/overlaps) with: 
•  EU policy and priorities in the 
fields of visa policy and border 
management (e.g. on migration, 
EIBM and visa) as well as 

 
 
Evaluation Question 

Judgment criteria 

Indicators 

Sources 

• 

Interviews with DG HOME and other EU stakeholders 
including Commission staff managing other funds, the 
Committee for the Home Affairs Funds, and EU Agencies in 
the field of Justice and Home Affairs (external coherence) 

•  Case studies (country and thematic), including consultation 
at the MS level, and desk research (reviews of evaluation at 
the national and EU level) 

•  Survey with national authorities (coherence and 

complementarity with other EU and national funds) 

external actions 

•  other EU actions /activities in the 
area of migration and border 
management including other 
Home Affairs funds (e.g., AMF 
and ISF Police) as well as Frontex 
(e.g., evidence of inter-
agency/institution cooperation). 

•  Other broader EU action as 

relevant including DG TAXUD 
(Customs Control Equipment 
Instrument), DG JUST (Justice 
Programme), DG RTD (Horizon 
2020 and Horizon Europe), DG 
INTPA (NDCI Global Europe), 
DG NEAR (IPA), Cohesion 
Policy funds (ESF and ERDF) or 
EEAS (The Neighbourhood, 
Development and International 
Cooperation Instrument).   

and other thematically relevant EU 
interventions (see Judgement Criteria).  
•  Stakeholders’ perception on the external 
coherence of the Fund with other EU 
and national funds. 

•  Documentary evidence of coordination 
mechanisms and bodies (e.g., fund 
committees) to ensure coherence 
between the BMVI Fund and other 
national or European funds (notably 
those identified as having high potential 
for complementarity or synergies)  
•  Stakeholders’ perception on the extent to 
which the mechanisms and bodies in 
place are adequate to generate synergies 
and avoid duplication of effort. 
•  Documentary evidence and/or 

stakeholders’ perception on the existence 
of inter-agency cooperation (e.g., with 
Frontex as well as cooperation at 
national level among the competent 
authorities within each Member State) 

98 

 
 
 
 
 
 
EU Added Value 

Evaluation Question 

Judgment criteria 

Indicators 

Sources 

EQ11. Was any value added 
brought about by the EU 
Support? 

•  The Fund enabled to implement 
interventions and address target 
groups that would have not been 
covered by Member States acting 
on their own.  

•  There is evidence of scope 

effects, i.e. of additional target 
groups addressed or additional 
types of interventions offered 

•  Number of actions addressing a wider 

target groups / policy areas which were 
not considered in the programming phase 
•  Number and volume of actions per target 

group 

•  Volume of services offered  
•  Number and type of end-users addressed 
•  Level of alignment between priorities 

with a high Union added values and 
actions and interventions supported by 
the thematic facilities 

•  Number and type of national resources 
allocated for the implementation of 
initiatives similar to those supported by 
the Fund  

Documentary review:  
•  Annual Implementation Reports 
•  National Evaluations 
•  EASO reports 
•  National policies on visa, border management, illegal 

immigration 

•  Country case study interviews 

•  Thematic case study interviews 

•  Survey for end-beneficiaries 

• 

Interviews at MS level 

99 

 
 
 
 
 
 
 
 
ANNEX IV: OVERVIEW OF BENEFITS AND COSTS 

In relation to the administrative procedures required, various type of costs have been identified. Consultation activities revealed that direct compliance costs 
include adjustment costs, which are one-time expenses incurred as stakeholders adapt to the changes introduced by the Common Provisions Regulation 
(CPR). Additionally, recurrent administrative costs have emerged due to increased information requirements necessary for compliance with monitoring 
and  reporting  obligations  under  the  CPR.  Furthermore,  as  evidenced  in  countries  such  as  Finland  and  Italy,  costs  associated  with  managing  grants, 
procurement, and other administrative procedures have increased, primarily due to legal challenges in tendering processes and the need for procedural 
simplification140. The review of Annual implementation reports confirms that direct labour costs and the time devoted to completing activities have been 
impacted by the administrative burden and the need for additional training and capacity building, as indicated by France and Greece.  

Despite these challenges, desk research and stakeholder consultations suggest that the costs are outweighed by a range of direct and indirect benefits for 
authorities, beneficiaries, and target groups. It is anticipated that the administrative burden resulting from increased monitoring and reporting will decrease 
over time, as both administrations and beneficiaries become familiar with the new requirements. The reduction of administrative burden is further supported 
by the standardisation promoted by the CPR across the European Structural and Investment Funds. This was confirmed during consultation activities, with 
consulted stakeholders that mentioned the administrative burden they currently experience is a natural consequence of the learning process required to 
adjust to new regulatory and reporting requirements, as well as new operational methods.  

Indirect benefits are also anticipated on medium and long term, including improved integration and a more uniform, standardized approach resulting from 
the implementation of the ESI Funds  and the Home Affairs Funds under  the CPR. This  will support the harmonized application of Union acquis  and 
strengthen effective European integrated border management at the Union’s external borders. Additionally, enhanced and more effective cross-country 
cooperation in border management and visa issuance is expected. 

The effort to implement and adapt to the usage of new electronic data exchange systems imply enforcement costs, encompassing expenses such as those 
related to the provision of guidance materials and training for beneficiaries on the use of new electronic data exchange systems. The analysis of Member 
States' Programs highlights that Member States (141) have implemented or are in the process of developing new IT systems, planning budgets for capacity 
building  and  IT  system  development.  Furthermore,  national  authorities  and  beneficiaries  face  an  additional  administrative  burden  arising  from  the 
methodological complexities of implementing simplified cost options.  However, there are no mechanisms in place for systematically reporting costs related 
to the administrative burden, limiting the ability to quantify these costs. 

(140) Annual Implementation reports 
(141) Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Greece, Malta, Poland, Romania, Slovenia, Spain 

100 

 
 
Despite these costs, the direct and indirect benefits significantly outweigh the expenses incurred. The implementation of electronic data exchange systems 
for monitoring is expected to alleviate the administrative burden, thereby facilitating improved oversight of the Fund’s implementation. This is already 
confirmed by the fact that the preliminary gains include improved data sharing and communication among involved parties, reduced reliance on paper-
based processes, and the potential for enhanced transparency and accountability in programme management. Countries like Belgium and Finland have 
explicitly stated in their Member States Programmes that they anticipate the costs associated with new IT systems will enhance overall cost-effectiveness 
in the long term. 142 From the beneficiaries' perspective, it is expected that, over time, the benefits of utilising the new electronic data exchange systems and 
standardized reporting will outweigh the current training costs.  

Moreover, the initiatives supported by the Fund will facilitate legitimate border crossings, enhance the detection of illegal immigration and cross-border 
crime, and improve the effective management of migratory flows. The Fund will also promote a harmonized approach to visa issuance, facilitate legitimate 
travel, and assist in mitigating migratory and security risks. However, the lack of mechanisms for systematically reporting costs at the Member State level 
limits the possibility to quantify these administrative expenses. Additionally, given the current state of the Fund's implementation, the benefits may not yet 
be fully measurable, as project implementation has only recently begun. 

Cost or benefit 

Administrations 

Other (direct beneficiaries of the Fund, other than 
citizens / businesses) 

Quantitative  

Comment  

Quantitative  

Comment  

BMVI 
total 
funding out of 
which: 

BMVI Shared 
management 
funding 

One-
off 

One-
off 

EUR 7,152 million,  out of 
which: 

EUR 5,414 million (the EU 
to 
contribution  amounts 
EUR 4,225 million) 

(142) Member States Programmes 

101 

 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Administrations 

Other (direct beneficiaries of the Fund, other than 
citizens / businesses) 

Quantitative  

Comment  

Quantitative  

Comment  

BMVI  Direct 
management 
funding 

One-
off 

BMVI 
Indirect 
management 
funding 

Direct 
compliance 
costs: 

Adjustment 
costs  

One-
off 

One-
off 

Administrativ
e costs 

Recurr
ent 

EUR  124  million 
EMAS 

EUR  10,3  million 
Union Actions 

for 

for 

EUR 1,47 million 

Time spent  to  adapt  to  the 
transition  under  the  CPR, 
as  the  objectives,  scope, 
and  structure  of  the  Fund 
and  Member 
States 
Programmes 

Increased 
requirements 
with  monitoring 
reporting 
causing 
administrative burden 

information 
to  comply 
and 
under  CPR, 
additional 

Fund’s 

Administrative  costs  for 
the 
direct 
beneficiaries  for  adapting 
to 
the  usage  of  new 
electronic  data  exchange 
systems 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Administrations 

Other (direct beneficiaries of the Fund, other than 
citizens / businesses) 

Quantitative  

Comment  

Quantitative  

Comment  

Increased 
information 
requirements  and  effort 
the 
to 
related 
methodological 
complexity 
implementing 
cost options 

of 
simplified 

effort 

Increased 
to 
implement and adapt to the 
usage  of  new  electronic 
data exchange systems. 

Regulator 
charges 

Enforcement 
costs, 
meaning costs 
associated 
with activities 
linked  to  the 
implementati
of 
on 

an 

Reccur
ent 

Costs  related  to  providing 
guidance  materials  and 
trainings  for  beneficiaries 
to  use  the  new  electronic 
data exchange systems 

103 

 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Administrations 

Other (direct beneficiaries of the Fund, other than 
citizens / businesses) 

Quantitative  

Comment  

Quantitative  

Comment  

initiative such 
as: 

Monitoring 

Inspections  

Adjudication/ 
litigation 

Indirect costs 

Direct 
benefits  

that 

is  expected 

the 
It 
burden 
administrative 
caused 
increased 
by 
monitoring  and  reporting 
will  reduce  in  time,  as  the 
administrations 
and 
beneficiaries  will  get  used 
to  the  new  requirements. 
This  is  also  due  to  the 
standardization 
the 
CPR is fostering across ESI 
Funds 

that 

It is expected that in time, 
the  benefits  of  using  the 
data 
new 
electronic 
exchance 
and 
standardized reporting will 
current 
the 
outweigh 
training costs 

systems 

actions 

The 
supported 
the  Fund  will 
through 
facilitate  legitimate  border 
crossing,  the  detecting  of 
immigration  and 
illegal 
cross-border crime, as well 

Given 
the  state  of 
implementation  of  the 
Fund,  such  benefits 
fully 
may  yet  be 
quantified 
the 
as 
implementation  of  the 
only 
has 
projects 
recently started 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Administrations 

Other (direct beneficiaries of the Fund, other than 
citizens / businesses) 

Quantitative  

Comment  

Quantitative  

Comment  

The 
of 
development 
electronic  data  exchange 
systems for monitoring will 
reduce  the  administrative 
burden  in  the  future  and 
will 
better 
allow 
monitoring  of  the  Fund’s 
implementation 

In  time,  the  benefits  of 
implementing 
simplified 
cost  options  will  outweigh 
the  costs,  as  beneficiaries 
already sense a slight relief 
of 
administrative 
burden  in  terms  of  project 
reporting 

the 

the 

as 
effective 
management  of  migratory 
flows 

The Fund will also support 
the  harmonized  approach 
to  the  issuance  of  visas, 
facilitate  legitimate  travel, 
while  helping  to  prevent 
security 
and 
migratory 
risks 

105 

 
 
Cost or benefit 

Administrations 

Other (direct beneficiaries of the Fund, other than 
citizens / businesses) 

Quantitative  

Comment  

Quantitative  

Comment  

Indirect 
benefits  

A  better  integration  and 
more 
and 
uniform 
standardized  approach  due 
to  the  implementation  of 
the  ESI  Funds  and  the 
Home Affairs Funds under 
the CPR 

of 

Support for the harmonized 
the 
implementation 
Union  acquis  and  stronger 
and 
effective 
European integrated border 
management at the Union’s 
external borders 

more 

Increased 
and  more 
cross-country 
effective 
cooperation  in  the  field  of 
border  management  and 
visa 

106 

 
 
 
   
   
 
 
 
 
 
ANNEX V: STAKEHOLDER CONSULTATION – SYNOPSIS REPORT 

Call for evidence 

Prior to the start of the evaluation, in line with the Better Regulation Provisions, a call for 
evidence  was  launched  in  the  Have  Your  Say  platform.  Three  contributions  were 
received (143): 

-  The European Council for Refugees  and Exiles  (ECRE) provided  a series of points 

regarding  

o  The lack of implementation of the partnership principle in EU funds. 

o  The  lack  of  transparency  on  the  implementation  of  the  horizontal  enabling 

conditions related to the Charter of fundamental rights.  

o  A  positive  assessment  of  the  EU's  response  to  Ukraine,  particularly  regarding 

provision of EU funding to civil society.  

o  The importance to allocate EU funds to objectively identified needs and implement 

all parts of the CEAS.  

o  The  fact  that  the  use  of  internal  policy  funds  in  third  countries  undermines 

coherence of internal and external policy objectives. 

-  Red ACOGE, from Spain, stated that the set up and implementation of the Monitoring 
Committee for the Spanish programme was not in line with the requirements and the 
regulation, notably in terms of transparency (lack of rules of procedure and minutes) 
and the inadequate representation of NGOs and Civil Society Organisations.  

-  An anonymous contributor, from Greece, drew the Commission’s attention to the lack 
of solidarity between Member States when it comes to assisting those states more under 
pressure  at  the  borders.  It  also  highlighted  the  need  to  control  borders,  including 
internal borders, in such a way as not to restrict freedom of movement but also to ensure 
the security of citizens. 

Consultation strategy 

Consultations included an online survey, EU level interviews, a focus group, case studies 
(country and thematic), and a validation workshop. The objective of the consultations was 
to collect relevant information and insights on the effectiveness, efficiency, coherence, EU 
added value and relevance of the BMVI as well as to collect inputs on lessons learned. To 
do so, a wide range of EU, international and national level stakeholders were consulted. 

Even if the open public consultation carried out between September and November 2024 
concerned firstly the ex-post evaluation of ISF-BV, given the continuity in objectives and 
interventions,  elements  related  to  the  Instrument  for  financial  support  for  Border 

(143)  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13851-Border-Management-
and-Visa-Instrument-BMVI-for-2021-2027-mid-term-evaluation/feedback_en?p_id=32300637  

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111 
Office: LX46 05/162 – Tel. direct line +32 229-62081 

 
 
 
 
Management and Visa Policy (BMVI) (2021-2027) may have also be taken into account 
for the mid-term evaluation. 

Table  1:  Overview  of  the  stakeholders  reached  through  each  consultation  tool  / 
method 

level 
EU 
Interview
s 

Online 
surveys 

Focus 
Group 

Validation 
workshop 

Public 
consultation 

Country / 
thematic case 
studies 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

European 
Commission staff 

and 
Migration 
Home  Affairs  (and 
other 
relevant) 
Agencies 

National 
Authorities 

Participant  /  (end) 
beneficiaries 

Other  SHs 
(EU 
bodies,  IOs,  NGOs, 
etc.) 

x 

groups, 
Expert 
network,  research 
centres 
and 
academics 

Wider 
public 
(including Non-EU) 

Online survey 

An  online  survey  was  launched  to  (i)  collect  information  on  the  effectiveness, 
efficiency, coherence, EU added value and relevance of the BMVI, (ii) understand 
the problems/gaps affecting the functioning and effects of the BMVI, as well as (iii) 
gather  suggestions  for  future-looking  recommendations.  Three  different  survey 
questionnaires  were  used,  targeted  respectively  at  National  Authorities  (38  total 
respondents),  other  stakeholders 
total  respondents)  and 
beneficiaries (40 respondents). The survey ran from June 17, 2024, to September 
16, 2024, and it has been administered and centrally managed by the evaluation team 
by using the Qualtrics tool. 

involved 

(55 

EU level interviews  

Between July and November 2024, the Study team carried out 21 in-depth EU level 
interviews  aimed  to  gather  relevant  information  and  insights  on  the  effectiveness, 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
efficiency, coherence, EU added value, and relevance of the BMVI. The response rate 
amounted  60%  as  21  out  35  individuals  contacted  agreed  to  participate  in  an 
interview. Among the 14 negative responses, the vast majority involved individuals 
redirecting the Study team to a more appropriate contact. Specifically, 2 requests went 
unanswered,  11  individuals  referred  the  Study  team  to  another  interviewee,  and  1 
individual  declined.  Stakeholders  reached  through  the  EU  level  interviews  were:

Table 2: EU-Level interviews conducted 

European Commission staff 

DG HOME’s relevant Directorates 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Directorate  A:  International  &  Horizontal  Affairs 
Interinstitutional Relations (A1) 

/  Policy  Coordination  & 

Directorate B: Schengen, Borders & Visas / Schengen & External Borders (B1) 

Directorate B: Schengen, Borders & Visas / Schengen Governance (B2) 

Directorate B: Schengen, Borders & Visas / Visa Policy (B4) 

Directorate E: HOME Affairs Funds / Funds Coordination (E1) 

Directorate E: HOME Affairs Funds / Union Actions and Procurement (E4) 

Directorate E: HOME Affairs Funds / Budget & Reporting (E5) 

Directorate F: Innovation & Audit / Audit & Compliance (F1) 

Directorate F: Innovation & Audit / Innovation & Security Research (F2) 

Others relevant DGs 

10 

11 

12 

13 

14 

15 

DG TAXUD / Directorate A: Customs / Customs Policy (A1) 

DG NEAR / Migration (DGA2.01) 

DG NEAR / Rule of Law - Western Balkans Policy & Regional Strategy (D1) 

DG JUST / Coordinator of the Justice programme 

DG INTPA / Person in charge of NDICI-Global Europe Instrument 

DG EMPL / ESF+ Coordination Unit in charge of migration theme 

Migration and Home Affairs (and other relevant) Agencies 

16 

European Border and Coast Guard Agency (Frontex) 

EU Body 

17 

European External Action Service (EEAS) 

International Organisations 

109 

 
 
 
International  Centre  for  Migration  Policy  Development  (ICMPD)  /  Migration 
Partnership Facility (MPF) 

UNHCR Brussels 

UNHCR Liaison Office to Frontex 

IOM Greece 

18 

19 

20 

21 

Focus group 

A focus group was held in person on June 25, 2024, in Brussels, as part of the Home Affairs 
Funds Conference. Moderated by the Study Team, this focus group aimed to gather direct 
input from ISF-BV and BMVI Managing Authorities, audit authorities, and beneficiaries, 
regarding the current and emerging needs in the area of border management and visa policy 
in  their  Member  State.  The  discussions  focused  on  mapping  current  and  future  needs, 
evaluating how well these needs have been met, and identifying any gaps in the existing 
instruments. Twenty-one participants attended the focus group meeting, covering: 

•  managing authorities and beneficiaries from the following countries: AT, BE, 

DK, FI, FR, HU, HR, IS, LU, NL, SE, as well as CH, NO and LI.  

• 

two EU agencies: Frontex and EUDA (144) 

•  One NGO: ECRE.  

Validation workshop 

A validation workshop was held on October 15, 2024, with 13 representatives from a 
sample of national authorities (BG and EE), relevant EC stakeholders (DG HOME 
units E4 and B1) and EU agencies (Frontex), as well as from network expert groups 
(Profundo),  NGOs  and  International  Organisations  (ICMPD),  to  present  the 
evaluation  findings  and  related  conclusions,  and  to  discuss  the  feasibility  of  the 
preliminary  recommendations  under  assessment.  The  workshop  consisted  of  a 
plenary session, where the evaluation team presented the objectives of the study and 
the key evaluation findings, followed by a Q&A section with participants. 

Country and thematic case studies 

Eight country case studies were conducted in Croatia, the Czech Republic, Norway, 
Poland, Spain, Greece, Italy, and Romania. These countries were selected to provide 
meaningful and representative coverage of BMVI interventions across participating 
countries.  Through  these  country  case  studies,  a  total  of  74  stakeholders  were 
consulted,  including  EU  stakeholders,  managing  authorities,  intermediate  bodies, 
monitoring committees and beneficiaries. 

(144) Formerly EMCDDA  

110 

 
 
 
Table 3: Number and type of stakeholders interviewed per country case study 

Stakeholders  Croatia 

Czech 
Republic 

Greece 

Italy  Norway  Poland  Romania  Spain 

(per 
Total 
stakeholder) 

Commission 

Managing 
Authority 

1 

Intermediate 
bodies 

Monitoring 
Committees 

Beneficiaries  5 

Total 

6 

1 

4 

2 

2 

9 

1 

1 

1 

1 

10 

14 

1 

2 

2 

6 

10 

4 

5 

2 

2 

5 

9 

1 

1 

3 

5 

1 

1 

14 

16 

3 

13 

4 

5 

49 

74 

Additionally, five thematic case studies were conducted on Emergency Assistance, 
Specific Actions, Union Actions, the Russian war of aggression against Ukraine and 
Horizontal priorities. 34 stakeholders were interviewed as part of the first four case 
studies (the Horizontal priorities case study relied on the survey findings and desk 
research).  

Table 4: Number and type of stakeholders consulted per thematic case study 

Stakeholders 

Emergency 
Assistance 

Specific 
Actions 

Union 
Actions 

Russian  war 
of aggression 

Total 
stakeholder) 

(per 

Commission 

Managing 
Authority 

Monitoring 
Committees 

2 

3 

1 

Beneficiaries 

4 (145) 

Total 

10 

5 

5 

2 

1 

9 

12 

5 

2 

7 

4 

9 

1 

20 

34 

(145) Several of the project coordinators/beneficiaries were responsible for multiple projects. 

111 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Results of the consultation activities 

Online Surveys 

Relevance 

The  BMVI  instrument  is  widely  recognised  for  its  relevance  and  adaptability  by 
national authorities, stakeholders, and beneficiaries. Most national authorities (15 out 
of 17) conducted needs assessments before drafting their national programs, and 11 
did  so  during  implementation.  Specific  objectives  were  highly  rated,  with  SO1 
(external  borders)  considered  relevant  to  a  large  or  very  large  extent  by  61%  of 
national authorities and 60% of stakeholders, while SO2 (visa policy) was deemed 
even more relevant, with 82% of national authorities, 61% of stakeholders, and 47% 
of beneficiaries rating it highly. IT and communication systems emerged as the most 
critical  funded  activity,  followed  by  infrastructure  and  equipment,  whereas 
awareness-raising,  innovative  methods,  and  statistical  tools  were  rated  as  less 
relevant. Despite its relevance, 29% of national authorities identified unmet needs, 
including  financial  gaps  for  IT  systems  and  infrastructure,  operational  support  for 
staffing and vehicles, and expanded training. Flexibility was another strong point of 
BMVI, with 41% of national authorities, over two-thirds of stakeholders, and 38% of 
beneficiaries finding it adaptable to challenges such as COVID-19 and the Ukraine 
crisis, although 13% of beneficiaries considered it limited in flexibility. 

Effectiveness 

The  BMVI  instrument  is  widely  regarded  as  effective  by  national  authorities, 
stakeholders, and beneficiaries, though some areas for improvement remain. Audit 
Authorities (80%) and Intermediate Bodies (75%) rated progress as "completely" or 
"almost  completely  on  track,"  while  Managing  Authorities  had  mixed  views. 
Monitoring and evaluation were deemed effective by 29% of national authorities and 
53%  of  stakeholders,  though  concerns  were  raised,  particularly  by  Managing 
Authorities  (24%)  and  17%  of  stakeholders  who  expressed  dissatisfaction.  Partner 
involvement  was  rated  positively  by  71%  of  national  authorities  and  67%  of 
stakeholders, though gaps in inclusion were noted in some Member States. Horizontal 
principles like digital transition and green budgeting were respected to a very large 
extent by 35% of national authorities and 74% of stakeholders, though some reported 
limited adherence. Communication and dissemination efforts were seen as effective 
by 65% of national authorities, 57% of stakeholders, and 57% of beneficiaries, though 
dissatisfaction and uncertainty were noted by a minority. Among beneficiaries, 68% 
felt BMVI significantly or largely helped achieve project objectives, while 54% found 
the  monitoring  framework  effective  and  felt  adequately  involved  in  programming, 
implementation,  and  evaluation.  However,  mixed  engagement  levels  and  gaps  in 
partner inclusion suggest areas for improvement in ensuring consistent effectiveness 
and participation across countries. 

Efficiency 

The  efficiency  of  the  BMVI  instrument  shows  a  mixed  picture  across  key  areas. 
Regarding EU budget allocation, 39% of national authorities found it sufficient, while 
30% deemed it insufficient due to challenges like rising IT costs, border management 
pressures, and delays in EU-level implementation. Progress toward targets was rated 
positively, with 64% of respondents, including 53% of public authorities and 48% of 
beneficiaries, indicating alignment to a large or very large extent. Cost efficiency was 

112 

 
broadly  acknowledged,  with  73%  of  national  authorities  and  71%  of  beneficiaries 
finding  operations  cost-effective.  However,  burdens  such  as  time-consuming 
information obligations, procurement procedures, and regulatory requirements were 
significant, with 64% of national authorities and 20%-34% of beneficiaries reporting 
them  from  moderately  to  highly  burdensome.  Simplification  measures,  such  as 
simplified cost options, were moderately effective, but 71% of beneficiaries noted the 
need  for  further  improvements  in  reducing  administrative  burdens.  Technical 
assistance positively impacted management and control systems for 52% of national 
authorities and 67% of other stakeholders, though uptake was limited, with only 20% 
of beneficiaries receiving assistance. The electronic data exchange system also faced 
usability  challenges,  with  57%  of  beneficiaries  expressing  uncertainty  about  its 
functionality and user-friendliness. 

Coherence 

The internal coherence of the BMVI instrument was positively assessed by 95% of 
national authorities, who confirmed that its structure supports complementarities and 
synergies, though 20 respondents did not provide feedback. While 35% of national 
authorities  conducted  assessments  to  identify  complementary  funding  instruments, 
over half were unsure or did not answer. Coherence with other Home Affairs funds 
was rated highly, with 45% of respondents noting strong alignment with the Asylum, 
Migration  and  Integration  Fund  (AMIF)  and  42%  with  the  Internal  Security  Fund 
(ISF). Coherence with Horizon Europe and the European Structural and Investment 
Funds  (ESIF)  was  also  confirmed.  Coordination  mechanisms,  such  as  strategic 
planning  and  joint  monitoring  committees,  were  reported  by  45%  of  respondents, 
while 55% cited monitoring mechanisms to prevent overlap of financial instruments. 
Among  other  stakeholders,  95%  agreed  that  BMVI’s  management  and  funding 
modalities  promote  complementarity  and  synergies.  External  coherence  was  rated 
well with ISF (68%) and AMIF (50%), though uncertainty about coherence with other 
EU instruments was noted. Beneficiaries perceived strong coherence with ISF (37%) 
and AMIF (28%), but significant non-responses limited the comprehensiveness of the 
findings. 

EU Added Value 

The EU added value of the BMVI instrument was positively assessed, particularly by 
managing authorities, who noted improvements in the Smart Borders initiative and 
enhanced stakeholder cooperation, though some reported no additional effects at this 
stage. For the Thematic Facility, 43% of managing authorities believed it moderately 
focuses  on  high-value  Union  priorities,  with  13%  seeing  a  significant  focus.  Most 
surveyed  authorities  (74%)  deemed  continued  EU  support  for  border  management 
and visa policy "very important," with priorities including investments in IT systems 
(e.g., ETIAS, EES), border surveillance, and operational support, such as Frontex's 
role.  Among  other  stakeholders,  21%  found  the  Thematic  Facility  significantly 
focused on high-value Union  priorities, while 25% rated it as moderately focused. 
Uncertainty  was  notable,  with  29%  of  stakeholders  and  30%  of  public  authorities 
unsure  about  its  focus.  Positive  effects  of  BMVI  projects  for  broader  groups  were 
observed by 25% of other stakeholders and 26% of public authorities. However, high 
uncertainty  was  reported,  with  39%  of  other  stakeholders  and  48%  of  public 
authorities  unsure  about  additional  impacts  beyond  the  primary  project  goals. 
Beneficiaries  provided  mixed  feedback,  with  29%  recognising  BMVI’s  focus  on 
high-value  priorities  as  significant  and  31%  as  moderate,  but  37%  were  unsure. 

113 

 
Broader  benefits  included  strengthened  Member  State  cooperation,  improved 
communication  with  national  authorities,  and  capacity-building,  though  some 
respondents  noted  no  effects  beyond  primary  project  goals,  reflecting  limited 
spillover impacts and significant uncertainty in perceptions. 

EU level interviews 

Relevance 

There  was  a  strong  consensus  among  all  stakeholders  consulted  within  EU 
institutions,  agencies  and  bodies  that  BMVI  was  highly  relevant  in  addressing  the 
needs of the Union and its Member States, both in terms of their structural needs (e.g., 
through the national programme, specific actions, and transnational union actions)  as 
well as their emergency needs (e.g., EMAS funding addressing unforeseen needs such 
as  the  Russian  war  of  aggression  in  Ukraine  and  its  impact  on  Member  States  in 
Eastern Europe). 

Interviews  confirmed  that  stakeholders  within  other  EU  Institutions,  Agencies  and 
services are consulted and provide inputs into Member States’ programmes, Specific 
Actions,  Union  Actions  and  EMAS.  For  instance,  DG  INTPA  and  EEAS  are 
consulted  regarding  actions  touching  upon  cooperation  with  third  countries,  while 
Frontex is consulted for their technical and operational expertise and overview of the 
current and future challenges facing the EU. In addition, since 2021, Frontex, together 
with Member States, developed a new methodology through which Member States 
are required to implement foresight analysis in their contingency and capability plans 
(which  inform  the  EIBM  strategy  and  are  expected  to  be  used  when  developing 
BMVI’s  National  Programmes)  which  was  reported  by  interviewees  as  having 
resulted in more robust forward-looking needs assessments. 

All stakeholders also highlighted BMVI's flexibility in addressing evolving needs by 
supporting project and programme adjustments and budget reallocations. In terms of 
new  and  emerging  needs,  several  stakeholders  within  the  Commission  noted 
emerging needs such as interoperability of IT systems and the Pact on Migration and 
Asylum. Some also noted the need for more innovation and use of technologies, in 
particular AI, and a better understanding of their risks and possibilities. 

Effectiveness 

The  effectiveness  of  the  BMVI  instrument  was  positively  assessed  by  key 
stakeholders,  though  areas  for  improvement  were  highlighted.  DG  HOME 
emphasised BMVI's success in managing external borders, stressing the importance 
of adhering to policy goals to maintain effectiveness. It noted progress, particularly 
through  the  Schengen  Evaluation  Mechanism,  but  identified  challenges  such  as 
COVID-19,  increased  migration  flows,  and  domestic  political  factors  affecting 
implementation.  Rigorous  monitoring  tools  like  the  Schengen  Barometer  were 
highlighted  as  essential  to  addressing  problem  areas.  Significant  investments  in 
modernising the Visa Information System (VIS) and enhancing consular operations 
were recognised, though delays in visa appointments due to staffing shortages remain 
an issue. The under utilisation of funds for critical positions and political challenges 
in resource sharing were also noted, with a call for administrative simplification and 
better  fund  utilisation.  Additionally,  strengthening  synergies  with  Frontex, 
centralising  procurement,  and  increasing  engagement  with  Managing  Authorities 
were  suggested  to  improve  coordination.  Other  DGs,  such  as  DG  EMPL,  noted 

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limited synergies with BMVI due to structural differences, while Frontex highlighted 
variations  in  national  IBM  programs  and  communication  gaps  among  national 
authorities, particularly in larger Member States. International organisations like the 
ICMPD  and  IOM  also  reported  positive  impacts,  including  improved  compliance 
with  fundamental  rights  and  enhanced  reception  facilities,  though  some  noted 
confusion between the BMVI “regular” actions and the Thematic Facility. 

Efficiency  

The  BMVI  has  proven  to  be  efficient  in  supporting  cost-effective  measures. 
According  to  DG  HOME,  the  BMVI  has  been  widely  utilised  to  finance  IT 
expenditures  related  to  visa  systems,  which  is  considered  a  straightforward  and 
effective use of funds. Similarly, it highlighted that the BMVI supports cost-effective 
measures by providing targeted funding for specific recommendations and ensuring 
that resources are allocated to critical areas such as border surveillance and IT system 
updates. In addition, the management and control system of the BMVI is considered 
efficient,  as  it  operates  through  a  structured  evaluation  process.  However,  some 
Member States face challenges in implementation due to staff or funding issues, so 
that  further  simplification  is  deemed  achievable  by  combining  funds  into  a  single 
European  Interior  Fund,  which  would  enhance  flexibility  and  coherence  across 
various policy areas. Regarding the level of cost-effectiveness of Union Actions, it 
was  emphasized  that  cost-effectiveness  is  a  critical  assessment  element  of  the 
proposals, which are not funded unless they are deemed cost-effective. This aspect is 
scrutinized during the proposal evaluation to ensure that projects deliver results within 
a reasonable cost. As for Frontex, the agency noted that synergies and cooperation 
were ensured through consultations during the development of national programs and 
specific actions. This collaborative approach further enhances the cost-effectiveness 
of  the  BMVI.  According  to  the  ICMPD,  implementers  appreciated  the  technical 
support  and  quick  response  times  provided  by  the  BMVI,  which  have  helped 
implementers  manage  projects  effectively.  ICMPD  emphasised  the  continuous 
learning and capacity-building efforts to ensure the efficiency of the management and 
control system. 

Coherence 

EU-level interviews with DG HOME officials confirmed the internal coherence of 
the BMVI, including the complementary nature of the different funding modalities 
following  their  legal  base,  the  internal  mechanisms  within  DG  HOME  (e.g.  the 
coordination unit) to secure coherence and new initiatives to further exploit synergies 
where possible. For example, to build successful investments in Union Actions into 
national plans (either funded by the EU or funded nationally). EU level interviewees 
also held positive views on the coherence between the BMVI and EU policies and 
priorities in the field of visa policy and border management, including the EBCG, the 
EIBM and EU Pact on Asylum and Migration. However, a few EU level interviewees 
noted  the  need  to  further  strengthen  the  link  between  BMVI  and  the  national 
capability roadmaps foreseen under the EBCG and EIBM.  

In terms of the external coherence, EU level interviews confirmed that mechanisms 
are in place to ensure coordination between BMVI and other EU funding instruments. 
However,  the  interviews  also  confirmed  that  the  required  mechanism  in  place  to 
ensure coherence between BMVI and EU external action (incl. actions funded under 
NDICI Europe and IPAIII) had been used to a limited extent to date, as only a limited 

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number of proposals under BMVI related to third countries. EU level interviewees 
noted that had not been aware of any overlaps between BMVI and other EU funding 
instruments, as the consultation process (formal and informal) would make sure such 
situations  were  avoided.  However,  some  of  the  EU  level  interviews  did  highlight 
several challenges in their ability to assess the coherence of BMVI with other funding 
instruments, in particular in relation to the Member States Programmes – noting the 
need for more detailed information sharing. Moreover, some EU level interviewees 
highlighted the need to further strengthen the synergies between the BMVI and the 
CCEI (e.g. through the further use of the CPR provision of mutli-purpose funding) 
and with Horizon Europe (more follow-up funding of the Research and Development 
resulting from Horizon Europe). 

EU Added Value 

The  added  value  of  the  BMVI  was  mainly  appreciated  by  the  DG  HOME’s 
directorates, more than by other stakeholders, particularly in terms of financial aspects 
and  cross-border  cooperation.  According  to  DG  HOME,  the  BMVI  generates  EU 
added  value  by  ensuring  Member  States  implement  key  elements  of  the Schengen 
acquis and addressing specific issues through targeted funding. As for Union Actions, 
while  they  may  not  reach  different  target  groups,  they  can  deliver  outcomes  that 
National Authorities might avoid due to high costs. The EU added value of Union 
Actions  lies  in  initiatives  that  transcend  national  borders  and  enhance  EU  policy 
objectives. Moreover, DG HOME stated that the EU added value of the BMVI lies in 
its ability to mitigate the financial constraints and lack of incentivization that Member 
States  would  likely  face  without  such  support.  Through  targeted  EU  funding,  the 
BMVI  has  encouraged  Member  States  to  invest  in  essential  resources,  including 
vessels  and  helicopters,  for  joint  operations.  For  DG  NEAR,  the  fund  is  highly 
desirable  and  has  EU  added  value.  Firstly,  there  is  a  financial  rationale.  Member 
States find it beneficial to use it to address gaps in their national funding. Moreover, 
the  fund  has  EU  added  value  because  it  can  address  the  pressing  need  to  develop 
operational cooperation between Member States and third countries. This cooperation 
is essential to effectively address and combat the networks involved in trafficking and 
smuggling  migrations,  which  are  often  located  in  third  countries.  For  other 
stakeholders, the question about the EU added value was either outside their area of 
expertise, or they did not express their views on the matter. 

Focus group 

In terms of current needs, participants cited specific external events, such as “Syria”, 
“2015 migration crisis”, “Ukrainian crisis” as drivers for increased need / pressures 
for border management against a backdrop of stretched capacity. IT systems featured 
heavily in the discussion of needs, there was mention of the need for innovation to 
allow  for  secure  and  smooth  border  process  and  efficiency,  for  development  and 
maintenance of “big IT systems” / ”large scale IT systems”, and “enhanced security” 
as  per  the  Smart  Borders  Package.  In  terms  of  new/emerging  needs,  participants 
highlighted a continued need for increased border surveillance in the context of the 
Russian  war  of  aggression  against  Ukraine,  the  new  mandatory  border  procedures 
stemming from the EU Asylum and Migration Pact, increased needs in the field of 
implementation of large-scale IT systems, data management and AI, and the new EU 
rules to digitalise the visa procedure that would need to be implemented gradually as 
from 2028 until 2035. In terms of the relevance of types of activities that could be 
funded under the BMVI, participants generally thought these were relevant, but noted 

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a few examples of items they would have liked to see funded but were not possible 
under  the  current  fund  (or  were  not  funded  enough):  Participants  were  generally 
positive about the flexibility of the fund, noting that while inherently the funds were 
quite  rigid,  the  Thematic  Facility  was  a  helpful  mechanism  to  address  emerging 
needs.  Finally, some participants noted the need for better coordination on the EU 
funding across the different EU funds and agencies (e.g. Frontex). 

Validation workshop 

Relevance 

As for the revision of MS Programmes, one participant emphasised the necessity to 
make  it  easier,  to  better  align  with  evolving  needs  and  obligations.  The  current 
framework for initiating and implementing  changes  is  indeed seen as cumbersome 
and overly reliant on governmental approval, delaying the timely implementation of 
necessary  changes  and  hindering  the  program's  responsiveness  to  emerging 
challenges. 

Effectiveness 

As  for  the  reporting,  considered  too  lengthy  and  burdensome  by  Member  States, 
mostly  because  of  staff  shortages,  it  was  pointed  out  the  necessity  to  balance  this 
finding with the need for adequate administrative work backing the disbursement of 
funding. Moreover, it was emphasised that Member States have at their disposal a 
number of governance mechanisms to monitor progress that should be integrated into 
national programming. 

Efficiency 

As  for  the  improvement  of  synergies  between  the  “regular”  measures  and  other 
actions funded by the Instrument (e.g., Union Actions, Specific Actions, etc.), it was 
pointed out that some overlaps might be inevitable without, however, covering the 
same activities or costs (e.g., the development of the Schengen Information System 
was partly financed through MS Programmes and partly through Union and Specific 
Actions). With regard to the number of Member States using Simplified Cost Options 
(SCOs), it was emphasised that many Member States use the union-level flat rate for 
indirect costs, but they do not describe it into their programmes. 

Coherence 

With  regard  to  external  coherence,  a  low  level  of  awareness  among  national 
authorities  was  pointed  out,  partly  due  to  the  limited  synergies  between  the  three 
related funds (BMVI, ISF and AMIF), which, despite shared objectives, serve distinct 
purposes and beneficiaries. Coordination processes, especially  for projects in  third 
countries,  require  further  development,  with  greater  consultation  to  strengthen 
outcomes.  It  has  been  also  asked  to  integrate  fundamental  rights  and  related 
requirements  into  the  evaluation,  while  ensuring  alignment  with  the  appropriate 
dimensions of other funds, such as AMIF. Additionally, the European Commission 
emphasized the importance of the thematic facility and direct funding mechanisms 
but noted the low level of interest and applications from Member States, indicating 
that uptake challenges are more dependent on Member States than the Commission 
itself. A major challenge identified is the lack of a natural mechanism to transition 
research  findings  from  Horizon  Europe  into  development  or  commercialisation, 

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largely  due  to  intellectual  property  rights  being  retained  by  project  consortia.  The 
absence  of  highlighted  synergies  with  the  European  Defence  Fund  and  CCEI  was 
noted as a missed opportunity. There is also interest in understanding whether gaps 
between  research,  development,  and  market  commercialisation  have  been  bridged 
effectively. Lastly, it was suggested that security-related issues should be excluded 
from Horizon Europe’s scope to maintain its focus on research and innovation. 

EU Added Value 

Participants agreed with the presented findings. 

Country case studies 

Effectiveness 

National  authorities  across  all  countries'  case  studies  confirmed  BMVI's 
effectiveness,  highlighting  its  capacity  to  achieve  set  goals,  address  specific 
challenges,  and  support  comprehensive  border  management  and  visa  policy 
initiatives.  Across  the  eight  countries,  stakeholders  consistently  reported  that  the 
BMVI has significantly enhanced their operational capacities. For instance, in Greece 
and Italy, the program has been instrumental in improving surveillance capabilities 
and  modernising  border  control  infrastructures,  which  are  critical  given  the  high 
migratory pressures these countries face. The funding for advanced and interoperable 
IT systems and equipment was also highlighted as having enabled a more automated 
and efficient border management process across the EU as a whole, thereby reducing 
reliance on manpower and increasing overall effectiveness. 

BMVI faced initial delays in most countries, and its implementation is still in its early 
stages. Therefore, stakeholders considered it too early to assess specific outcomes but 
considered  that  the  instrument  was  on  track  to  meet  its  goals.  In  some  cases, 
stakeholders  have  expressed  concerns  about  insufficient  funding  to  meet  growing 
demands, particularly  in  countries facing  heightened security threats.  Additionally, 
administrative burdens related to compliance and reporting requirements have been 
noted as potential obstacles to effective implementation. 

Efficiency 

Across  the  eight  countries,  national  authorities  generally  reported  positive 
assessments  of  BMVI’s  efficiency,  particularly  in  terms  of  the  management  and 
control structures established. Across several Member States, procurement practices 
were highlighted as a key contributor to BMVI’s cost-efficiency. Stakeholders from 
Italy, Croatia, and Romania reported that public procurement ensures high-quality, 
cost-effective  solutions,  supported  by  robust  management  and  control  systems. 
Additionally,  stakeholders  in  Norway  found  calls  for  specific  actions  to  be 
straightforward,  allowing  beneficiaries  to  achieve  a  favourable  cost-benefit  ratio. 
However,  stakeholders  from  Poland  and  Greece  reported  struggling  with  public 
procurement, although it was due to public procurement rules in the countries, which 
often caused delays.  

Administrative requirements often emerged as a key bottleneck. Authorities across 
countries,  including  Italy,  Poland,  Romania,  and  the  Czech  Republic,  reported 
burdensome  monitoring,  redundant  documentation  requirements,  and  complex 
reporting  processes.  Specific  Actions,  in  particular,  were  consistently  flagged  as 

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administratively intensive. The BMVI's design, particularly in Poland, demonstrated 
adaptability in responding to emergencies such as the Ukrainian refugee crisis, with 
swift  and  flexible  funding  mechanisms  minimizing  administrative  delays.  While 
initial implementation challenges exist, digital systems like Romania's RO-FED offer 
promise  for  long-term  reductions  in  administrative  burdens,  enhancing  procedural 
efficiency  and  management  capabilities.  Likewise,  the  effect  of  digital  systems  on 
efficiency was also  confirmed by stakeholders from Croatia, which already started 
working on setting up an electronic system, from Poland where systems integration 
required a lot of work and the system was not well-tailored to the needs of the fund, 
and also from Greece where national programmes still relied on printed materials and 
the  digital  performance  monitoring  systems  lacked  the  flexibility  of  a  project 
management and monitoring tool. 

There  were  mixed  views  on  simplifying  measures.  Shorter  contract  periods  and 
technical assistance were welcomed, but some raised concerns about sufficiency for 
complex projects. In certain countries (Greece and the Czech Republic), stakeholders 
reported  insufficient  staff,  which  limited  the  capacity  to  manage  the  programme 
effectively.  

Coherence 

Across  the  eight  countries,  national  authorities  confirmed  that  BMVI  effectively 
complements other EU funding instruments, such as the Internal Security Fund (ISF) 
and  the  Asylum,  Migration  and  Integration  Fund  (AMIF).  Stakeholders  also 
highlighted that actions co-financed by the BMVI are well-aligned with the Schengen 
Strategy and the European integrated border management framework, ensuring that 
interventions contribute to broader EU objectives. 

Authorities  also  confirmed  the  coherence  of  BMVI  with  national  initiatives  and 
programmes with similar objectives, which ensured that interventions are consistent 
with  broader  policy  goals.  Different  countries  achieved  this  using  different  but 
effective coordination mechanism, such as different funds being overseen by the same 
Monitoring Committees (e.g. Romania) or managed by the same Managing Authority 
and/or  the  same  Delegated  Authority  (e.g.  Poland  and  Czech  Republic),  or  the 
Managing  Authority  being  part  of  the  Ministry  of  Interior  (e.g.  Croatia).  These 
mechanisms  have  facilitated  coordination,  ensuring  that  funded  actions  are 
complementary  and  do  not  overlap  with  other  initiatives.  Stakeholders  have 
emphasised the importance of these in maintaining coherence across various funding 
sources and aligning interventions with national and EU policies. 

There was a mixed view on synergies and complementarity. While some countries 
highlighted that BMVI fosters synergies with other EU instruments and/or national 
initiatives  (such  as,  Italy,  Poland  and  Romania),  others  (such  as  Greece,  Czech 
Republic and to some extent, Croatia) noted that there were little to no mechanisms 
(which they were aware of) to support synergies or co-funding of projects.  

Relevance 

National  authorities  across  all  eight  country  case  studies  highlighted  the  strong 
relevance of BMVI, in particular in regard to border management activities (more so 
than  the  visa  instrument).  Stakeholders  in  Greece,  Italy  and  Spain,  which  face 
significant  and  ongoing  migratory  pressures,  highlighted  the  importance  of  BMVI 
funding  in  bolstering  their  border  infrastructures  and  capabilities.  Similarly, 

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stakeholders in Poland and Romania emphasized the relevance of the instrument in 
irregular  migration  and  enhancing  operational  capacity  during 
addressing 
emergencies  –  such  as  during  the  Russian  war  of  Aggression  against  Ukraine. 
Implementing authorities and beneficiaries alike considered funded activities related 
to the development, upgrading, implementation and operationalisation of large-scale 
IT systems (and in particular, those required for border control and surveillance) as 
well  as  activities  funding  the  purchase  and  maintenance  of  equipment  and 
infrastructures to be among the most relevant.  

Most national authorities agreed that the programme’s design was also relevant as it 
allows for swift and non-substantial changes/ adjustments when new needs emerge. 
Similarly, stakeholders confirmed that BMVI allowed enough flexibility, particularly 
when  certain  emerging  needs  were  identified,  such  as  to  respond  to  the  increased 
pressure on Poland’s eastern borders with Ukraine and Belarus.  Moreover, interviews 
highlighted the importance of stakeholder engagement and participative approaches 
in  identifying  needs  and  adapting  interventions,  accordingly,  thus  ensuring  the 
relevance  of  the  BMVI.  Stakeholders  expressed  concerns  that  the  current  funding 
levels  may not  be sufficient to  meet  the growing demands of border management, 
particularly in light of evolving security threats and increased migratory flows.  

EU Added Value 

In all countries examined, national authorities unanimously recognised BMVI's EU-
added value in enhancing the capacity of managing external borders and visa policies 
effectively. Stakeholders consistently highlighted that the financial resources enabled 
countries  to  undertake  initiatives  that  would  not  be  feasible  with  national  funding 
alone. For instance, BMVI has facilitated the procurement of advanced surveillance 
technologies and the implementation of interoperable large-scale IT systems. These 
investments not only improve national capabilities but also contribute to the overall 
security and stability of the Schengen area, thus demonstrating their EU-added value. 
Stakeholders  noted  that  the  EU  funding  allows  for  a  more  coordinated  and 
comprehensive approach to border management, which is essential given the complex 
security  landscape.  The  ability  to  pool  resources  and  share  best  practices  among 
member  states  (e.g.,  Union  actions)  and  Frontex  (e.g.  specific  actions)  was  also 
highlighted as having enhanced operational capacities and ensuring a unified response 
to shared challenges. This collaborative approach was noted as not only strengthening 
national systems but also reinforcing the collective framework of the EU. 

Emergency Assistance 

the  allocation  of 

EMAS  was  assessed  by  all  stakeholders  consulted  (EC,  implementing  national 
authorities and beneficiaries) as highly relevant. It addressed EU and Member States' 
needs for a solidarity financial instrument with a flexible fund component which can 
adapt 
to  pressing  and  emerging 
challenges/emergencies in a flexible and timely manner. EMAS addressed that need 
under BMVI by providing emergency funding to assist Member States in reinforcing 
their capacity to respond to crises characterised by large or disproportionate numbers 
of arrivals or by incidents which have a decisive impact on border security.  

respond 

funding 

to 

Authorities consulted reported that EMAS's modalities were flexible, both in terms 
of its scope (i.e., the different activities it covers, the possibility of being used as a 
top-up mechanism, and the possibility of extending financing) and procedures (i.e., 

120 

 
the application and approval process is quick, efficient, and not burdensome for the 
national authorities).  

Moreover, EMAS was highlighted as internally coherent with the other modalities of 
BMVI (national programme including specific actions and Union Actions), as it has 
complementary  objectives  (i.e.,  addressing  immediate  emergency-related  needs  as 
opposed to structural and longer-term needs or transnational needs at the EU level). 
This internal coherence was also reported as ensured through the formal and informal 
coordination mechanisms in place to ensure complementarities and, where relevant, 
synergies across the management modes.  

Specific Actions 

National authorities consulted agreed that BMVI Specific Actions aligned with the 
specific needs identified in the Member States. However, stakeholders from multiple 
Member  States  noted  that  while  Specific  Actions  provided  essential  support  in 
addressing national priorities, they often did not fully cover the breadth of these needs 
due to limited funding, unclear timelines, and complex administrative processes.  

Concerning coherency with other funds, BMVI Specific Actions were perceived as 
fostering cooperation between Member States and as being aligned with broader EU 
initiatives. However, due to their specificity, stakeholders reported limited potential 
for synergies with other national funding streams, which prevented duplication but 
also  reduced  the  opportunity  to  enhance  the  scope  of  projects  through  national 
funding. 

EU  and  national  stakeholders  considered  that  BMVI  Specific  Actions  brought 
significant added value, particularly in enhancing the capabilities of Member States 
to manage their external borders and implement EU regulations. At the Union level, 
these  actions  contributed  to  a  more  cohesive  and  effective  approach  to  border 
management,  benefiting  the  entire  EU  by  ensuring  that  Member  States,  especially 
those  at  the  external  borders,  have  the  necessary  resources  to  address  shared 
challenges. 

Union Actions 

National  authorities  confirmed  that  Union  Actions  contributed  to  a  wide  range  of 
possible activities, and their achievements varied in line with the specific rationale 
for a given action. Union Actions were perceived as providing a unique opportunity 
to finance activities that paved the way for new and better ways of working when they 
were conceived to develop a specific concept or product and were well implemented. 
They provided significant EU added value and were more efficient than if all Member 
States had conducted the activities independently.  

However,  stakeholders  highlighted  certain  cases  where  the  appetite  to  deliver 
activities was low for example due to sensitivities, which led to the Union's Actions 
not  working  out  in  practice.  Furthermore,  they  acknowledged  that,  in  certain 
instances, innovative projects and good practices were being developed, effectively 
communicated,  and  logical  next  steps  were  being  pursued.  However,  there  was  a 
shared  sentiment  that  additional  efforts  could  be  made  to  ensure  that  processes  to 
ensure that possible synergies between Union Actions and actions at the national level 
are  exploited  in  a  more  systematic  manner.  Stakeholders  also  confirmed  that  the 
the 
Union  Actions  examined 

the  case  study  effectively  demonstrated 

in 

121 

 
complementarity  with  indirectly  managed  actions  under  the  Migration  Partnership 
Facility, underscoring the interconnected nature of these funding initiatives. 

Russian war of aggression 

Feedback  from  national  authorities  and  stakeholders  within  the  Commission 
confirmed the usefulness of EMAS to address the challenges posed by the Russian 
War of Aggression in Ukraine and its impact on the EU. Stakeholders appreciated the 
swift availability of funds, noting that the process was significantly quicker than that 
of  national  programs.  They  highlighted  that  the  application  procedure  was 
straightforward, allowing applicants to develop their proposals in a timely manner, 
and  they  were  also  pleased  with  the  fast  provision  of  funding.  Most  stakeholders’ 
interviews  highlighted  that  this  was  exactly  what  was  needed  at  that  particular 
moment  of  an  emergency  situation  when  most  institutions  dealing  with  border 
management had other priorities, had to manage the influx of refugees and staff was 
often delegated directly to the border. 

The  use  of  Financial  Not  Linked  to  Costs  (FNLC)  was  praised  for  enabling  quick 
project processing with low administrative overhead. However, national approaches 
to tracking EMAS funds varied: in Slovakia and Romania, funds contributed to the 
state budget, while in Poland, they were allocated to specific projects like developing 
perimeter  systems  at  the  Polish-Russian  border.  Despite  the  positive  impact, 
stakeholders noted that EMAS funding was insufficient, with Poland and Slovakia 
considering AMIF more significant in managing the crisis due to its larger size and 
broader scope. Other funds, such as cohesion policy and REACT-EU funds, offered 
more flexibility but did not provide additional resources.  

Horizontal priorities 

The  Fund's  implementation  has  demonstrated  some  progress  in  aligning  with 
horizontal principles, particularly in the areas of gender equality and digital transition, 
but  the  results  remain  uneven.  The  majority  of  national  authorities  and  other 
stakeholders  consulted,  as  well  as  40%  of  beneficiaries  believe  that  the  BMVI 
implementation  respects  or  promotes  horizontal  principles  to  a  very  large  or  large 
extent.  However,  more  than  one-fifth  of  the  respondents  including  the  national 
authorities, beneficiaries and other stakeholders have reported that they either do not 
know or prefer not to answer about the extent to which BMVI respects or promotes 
horizontal  principles.  Overall,  although  the  fund's  implementation  is  progressing 
towards effectively aligning with and promoting horizontal principles under shared 
management, it is difficult to track the extent to which these efforts have effectively 
led  to  tangible  outcomes  in  terms  of  advancing  gender  equality  and  fundamental 
rights in this ongoing phase of implementation. 

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