COMMISSION STAFF WORKING DOCUMENT EVALUATION Mid-term Evaluation of the Asylum, Migration and Integration Fund (AMIF) 2021-2027
Date: 2025-09-16
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, aid to refugees, fund (EU), integration of migrants, migration control, project evaluation, refugee, return migration, right of asylum

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.9.2025  SWD(2025) 270 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Mid-term Evaluation of the Asylum, Migration and Integration Fund (AMIF) 2021-2027 {SEC(2025) 248 final} - {SWD(2025) 271 final}  
 
 
Table of contents 

1. 

INTRODUCTION ........................................................................................... 1 

Purpose and scope of the evaluation ...................................................................................... 1 

2.WHAT  WAS 
THE 
EXPECTED 
INTERVENTION? .................................................................................................. 5 

OUTCOME 

THE 

OF 

2.1 

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

2.2 Intervention Logics ............................................................................................................ 7 

2.3   Points of comparison ..................................................................................................... 16 

3.  HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 
PERIOD? ....................................................................................................... 20 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ................................. 23 

4.1.  TO  WHAT  EXTENT  WAS  THE  INTERVENTION  SUCCESSFUL  AND 
WHY? ............................................................................................................ 23 

4.1.1 Effectiveness .................................................................................................................. 23 

4.1.2 Efficiency ....................................................................................................................... 35 

4.1.3 Coherence ...................................................................................................................... 41 

4.2.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE AND TO 
WHOM? ........................................................................................................ 50 

4.2.1 To what extent is AMIF generating EU added value? ............................................. 50 

Expanding the Scope of Services ..................................................................................... 51 

Scaling Services and Increasing Reach ........................................................................... 51 

Enhancing Administrative and Functional Capacity ..................................................... 52 

Mitigating Financial Dependency .................................................................................... 53 

Addressing High-Value EU Priorities through the Thematic Facility ........................ 54 

4.3.  IS THE INTERVENTION STILL RELEVANT? ........................................ 55 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ........... 63 

5.1.  CONCLUSIONS ........................................................................................... 63 

5.1.1 

 Effectiveness ............................................................................................................. 63 

5.1.2 

 Efficiency .................................................................................................................. 66 

5.1.3 

 Coherence .................................................................................................................. 67 

5.1.4 

 How did the EU intervention make a difference and to whom (EU added value)?
 ..................................................................................................................................... 67 

 
 
 
 
 
5.1.5 

 Is the intervention still relevant (Relevance)? ...................................................... 68 

5.2.  LESSONS LEARNED .................................................................................. 69 

ANNEX I:   PROCEDURAL INFORMATION ................................................... 71 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ........... 77 

Methodology ........................................................................................................................... 77 

Limitations and mitigation measures ................................................................................... 78 

Supporting information, tables and figures ......................................................................... 79 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS 
ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION)
 ....................................................................................................................... 88 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS .................................. 111 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ... 115 

Call for evidence ................................................................................................................... 115 

Interviews .............................................................................................................................. 116 

First EU-level focus group .................................................................................................. 121 

Second EU-level focus group ............................................................................................. 122 

Targeted surveys ................................................................................................................... 124 

 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AMIF  
APR  
ARM  
BMVI  

CEAS  
Common indicators 

COVID-19  
CPR  
CSO  
CST  
DG  
DG ECHO  

DG EMPL  

DG HOME  

DG NEAR  

DG REGIO  

DG RTD  
Direct Management 

EC  
EMAS  
EMN  
ERF  
ESF+  
ESI  
EU  
Eurostat  
EUAA  
FEAD  
FIR  

Asylum, Migration and Integration Fund  
Annual Performance Report  
Annual Reports of Migration and Asylum  
Integrated  Border  Management  Fund  –  Border 
Management and Visa Policy Instrument  
Common European Asylum System   
The set of indicators defined in Annex 8 of the AMIF 
Regulation (EU) 2021/1147 
Coronavirus disease of 2019  
Common Provisions Regulation  
Civil Society Organisation  
Central IT System  
Directorate-General  
Directorate-General for European Civil Protection and 
Humanitarian Aid Operations  
Directorate-General  for  Employment,  Social  Affairs 
and Inclusion  
Directorate-General for Migration and Home Affairs  

Directorate-General 
Enlargement Negotiations  
Directorate-General for Regional and Urban Policy  

for  Neighbourhood 

and 

Directorate-General for Research and Innovation  
In  direct  management,  the  European  Commission  is 
directly  responsible  for  all  steps  in  a  programme's 
implementation. 
European Commission  
Emergency Assistance  
European Migration Network  
European Refugee Fund  
European Social Fund Plus  
European Structural and Investment Funds  
European Union  
European Statistical Office  
European Union Agency for Asylum  
Fund for European Aid to the Most Deprived  
Final implementation report  

 
 
 
Term or acronym 

Meaning or definition 

Frontex  
FTE  
Indirect Management 

IOM  
ISF  
JHA  
MA 
MS  
NDICI  

NGO  
OECD  

RF  
RRF  
SA  
SCOs  
SFC  

SFI  
Shared Management 

SM  
SO  
SWD  
TA  
TCN  
TFEU  

Thematic Facility 

for 

instance, 

International 

development, 

for  Economic  Co-operation 

European Border and Coast Guard Agency  
Full Time Equivalent  
Funding  managed  by  partner  organisations  or  other 
authorities  inside  or  outside  the  EU,  e.g.  national 
authorities or international organisations. The majority 
of  the  EU  budget  allocated  to  humanitarian  aid  and 
is 
international 
implemented under indirect management. 
International Organisation for Migration  
Internal Security Fund  
Justice and Home Affairs  
Managing Authority 
Member States  
Neighbourhood,  Development  and 
Cooperation Instrument  
Non-governmental organisation  
Organisation 
Development  
European Return Fund  
Recovery and Resilience Facility  
Specific Actions  
Simplified cost options  
Electronic data exchange system concerning the CPR 
Funds  
Swedish for immigrants  
In shared management, both the European Commission 
and  national  authorities  in  Member  States,  such  as 
ministries  and  public  institutions,  are  in  charge  of 
running a particular programme. 
Shared management  
Specific Objective  
Staff Working Document  
Technical Assistance  
Third-country national  
Treaty of the Functioning of the European Union   

and 

Part of the AMIF budget is periodically allocated to a 
Thematic  Facility  for  the  funding  of  its  components, 
i.e.,:  Specific  Actions,  Union  Actions,  Emergency 
Assistance, 
Humanitarian 
Admission,  and  to  additional  support  for  Member 
States  contributing  to  solidarity  and  responsibility 
efforts (Relocation) 

Resettlement 

and 

 
 
Term or acronym 

Meaning or definition 

Facility  Work 

Thematic 
Programmes 

The Charter  
UA  
UNHCR  

Annual  or  multi-annual  programming  documents 
describing the interventions programmed in relation to 
the different components of the Thematic Facility 
EU Charter of Fundamental Rights  
Union Actions  
United Nations High Commissioner for Refugees  

 
 
1. 

INTRODUCTION 

Purpose and scope of the evaluation 

This Staff Working Document covers the mid-term evaluation of the Asylum, Migration 
and  Integration  Fund  (hereinafter  the  ‘AMIF’  or  ‘the  Fund’)  for  the  period  2021-2027 
established by Regulation (EU) 1147/20211 (AMIF Regulation). The purpose and scope of 
this  mid-term  evaluation  are  set  out  in  Article  34(1)  of  the  AMIF  Regulation,  which 
requires the Commission to carry out by 31 December 2024 a mid-term evaluation of the 
fund, in particular 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 AMIF 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. 

The evaluation covers both the Member States  programmes (programmed by the Member 
States  and  implemented  in  shared  management)  and  the  AMIF  Thematic  Facility  work 
programmes  (programmed  by  the  Commission  and  implemented  in  direct,  indirect  and 
shared management) (see Annex II for further information on the structure of AMIF 2021-
2027  and  the  Thematic  Facility).  The  Member  States  programmes  absorb  most  of  the 
AMIF budget (around two thirds). The majority of these programmes were approved in 
the last quarter of 2022.  

The temporal scope of the evaluation covers the period from January 2021 until mid-2024. 
The geographical scope includes 26 Member States, i.e. excluding Denmark 2. 

Article 7 of the AMIF Regulation sets out the criteria  under which third countries may be 
associated to the AMIF. However, no third countries are currently associated to the Fund.  

As laid down in Article 3(1), the Fund contributes to the efficient management of migration 
flows and to the implementation, strengthening and development of the common policy on 
asylum and the common immigration policy, in accordance with the Union acquis and the 
international obligations of the Union and the Member States arising from the international 
instruments to which they are party.  

Pursuant to Article 16 (11) AMIF, Member States willing to implement projects with or in 
a third country with the support of the Fund, should consult the Commission prior to the 

1 Regulation (EU) 2021/1147 of the European Parliament and of the Council of 7 July 2021 establishing the 
Asylum, Migration and Integration Fund. http://data.europa.eu/eli/reg/2021/1147/oj  
2 As per Recital (73) of the AMIF Regulation, in accordance with Articles 1 and 2 of Protocol No 22 on the 
position of Denmark annexed to the TEU and to the TFEU, Denmark is not taking part in the adoption of 
this Regulation and is not bound by it or subject to its application. 

1 

 
 
approval  of  those  projects.  The  scope  of  support  as  regards  actions  in  relation  to  third 
countries is set out in Article 5 (2) and (3) AMIF, which must also respect a number of 
conditions.  

Given  the  partial  implementation  of  the  programmes  by  30  June  2024,  the  mid-term 
evaluation primarily focuses on assessing the extent to which the regulatory structure, the 
Member  States’  programmes  and  the  Commission’s  work  programmes  are  effectively 
serving their purpose in view of the expected results and impacts, rather than at obtaining 
final conclusions on their effectiveness and efficiency.  

In  addressing  the  main  evaluation  criteria  of  relevance,  effectiveness,  efficiency, 
coherence, and EU added value, the evaluation primarily aims 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 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.  

•  whether  the current  monitoring and evaluation arrangements  can be expected to 
generate sufficient evidence to measure the impacts of the fund by June 2029 (at 
Member State level), and by December 2031 (at EU level). 

It should be noted at this point that, due to the mid-term nature of the evaluation and the 
delays  which  have  occurred,  only  a  limited  assessment  can  be  made  regarding  the 
effectiveness and efficiency of the programmes. Therefore, as outlined above, the focus of 
the analysis is on evaluating how well the regulatory framework as well as the programmes 
are  fulfilling  their  intended  objectives  and  impacts,  rather  than  drawing  overarching 
conclusions about effectiveness and efficiency of the fund. In doing so, relevant sources 
of information, including those mentioned in Articles 34 to 36 of the AMIF Regulation, 
have been considered. 

The  evaluation  is  based  on  thirteen  evaluation  questions  organised  around  the  five 
evaluation criteria of effectiveness, efficiency, coherence, EU added value and relevance: 

2 

 
As the Commission is also requested to provide an ex-post evaluation report of the AMIF 
for the programming period 2014-20203, it decided to carry out the preparatory work for 
both evaluations simultaneously, in order to facilitate the exchange of information and the 
use  of  common  findings  and  analysis  between  both  exercises.  Nevertheless,  this  Staff 
Working Document presents the mid-term evaluation of the AMIF for the period 2021-
2027.  

The  preparatory  work  for  this  evaluation  was  contracted  to  an  external  consortium 
composed  by  “Ernst  and  Young  (EY)”  and  “Technopolis  Group”.  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 stakeholders such as European Commission officials, 
implementing partners, and beneficiaries, as well as focus groups and targeted surveys. It 
included data analysis covering country case 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.  

The approach to data collection is exemplified in the following: 

3 Regulation (EU) No 516/2014 of the European Parliament and of the Council of 16 April 2014 establishing 
the  Asylum,  Migration  and  Integration  Fund,  amending  Council  Decision  2008/381/EC  and  repealing 
Decisions No 573/2007/EC and No 575/2007/EC of the European Parliament and of the Council and Council 
Decision 2007/435/EC. https://eur-lex.europa.eu/eli/reg/2014/516/oj  

3 

 
 
 
 
 
 
 
 
Figure 1: Data collection diagram 

The  document  review  was  based  on  evidence  obtained  from  a  number  of  sources, 
including:  

• 

• 

• 

the output and result indicators defined in  Annex VIII to  the  AMIF Regulation, 
which are regularly fed to the Commission by the authorities managing the Member 
State programmes (hereinafter “Managing Authorities”),  

the annual performance reports produced every year, since 2023, by the Managing 
Authorities,  

the  mid-term  evaluations  drawn-up  by  the  Member  States  by  31  March  2024, 
according to article 44(5) of the Common Provisions Regulation4  (henceforward, 
the CPR),  

• 

the Impact Assessment for the AMIF,  

•  any other studies, sources and reports, such as reports from  grants  in  direct  and 
indirect management, and from the European Court of Auditors, which may have 
provided useful information for the evaluation.  

The data collection and analysis processes faced several limitations:   

• 

inconsistent  data  quality  and  availability  across  Member  States  hindered 
comparisons;  

•  historical  data  was  often  incomplete,  and  errors  in  the  Electronic  data  exchange 

system concerning the CPR Funds (SFC) data added to the challenges;  

4  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. 

4 

 
 
 
•  variations in data granularity and programme maturity, as AMIF programmes were 

at different stages of implementation;  

• 

low response rates in surveys;   

•  conceptual issues with certain common output and result indicators, which made it 

difficult to measure programme progress accurately. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1  Description of the intervention and its objectives 

The AMIF, along with the Instrument for Financial Support for Border Management and 
Visa Policy (BMVI)5 and the Internal Security Fund (ISF)6 for the programming period 
2021-2027, collectively form the “Home Affairs Funds”.  

The Home Affairs Funds contribute to complementary EU level objectives in the field of 
migration, border management and security.   

Altogether the Home Affairs Funds amount to EUR 20,6 billion7. 

Figure 2: Total budget the three EU Home Affairs Funds 

5 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 PolicyRegulation (EU) 2021/1148. https://eur-lex.europa.eu/eli/reg/2021/1148/oj   
6 Regulation (EU) 2021/1149 of the European Parliament and of the Council of 7 July 2021 establishing the 
Internal Security Fund.  https://eur-lex.europa.eu/eli/reg/2021/1149/oj  
7 As of 22 November 2024. 

5 

 
 
 
 
The  AMIF  2021-2027  was  preceded  by  the  Asylum,  Migration  and  Integration  Fund 
(AMIF) 2014-2020 that was established by Regulation No 516/20148 with the purpose of 
promoting efficient management of migration flows and the implementation, strengthening 
and development of a common Union approach to asylum and immigration. The creation 
of  the  AMIF  2014-2020  responded  to  a  need  to  rationalise  the  architecture  of  different 
funding instruments under the Solidarity and Management of Migration Flows (SOLID) 
programme (2007-2013). 

The  2018  Impact  Assessment9  that  accompanied  the  legislative  proposals  for  the  three 
Home  Affairs  Funds  for  the  2021-2027  programming  period10  highlighted  a  number  of 
developments over the previous programming period and corresponding challenges for the 
AMIF 2021 - 2027. In the area of asylum and migration, over the last decade, the EU has 
faced  a  very  large,  and  growing,  number  of  asylum  seekers  and  migrants.  The  sudden 
increase in flows in 2015 and 2016 meant a shift in the scale of the pressure at the external 
borders and evidenced the need for a new, stronger, and more coordinated EU response. 
In the aftermath of the COVID-19 pandemic, continued and renewed pressure on the routes 
across the Mediterranean and the Western Balkans has become increasingly visible. 

Other factors, such as geopolitical instability combined with economic and demographic 
factors  and climate change  have increased  migratory and forced displacement pressure, 
which  has  been  increasingly  challenging  for  the  EU  migration,  asylum,  and  border 
management systems. The challenges in the areas of asylum and migration are by their 
nature  interlinked  and  cannot  be  adequately  addressed  by  Member  States  acting  alone. 
Moreover, the burden on individual  Member States’ migration and border management 
systems varies significantly. 

The interim evaluation of the AMIF 2014-2020 has showed that EU funding, despite its 
relatively small size in comparison with the asylum and migration challenges at the level 
of  the  Union,  provides  a  clear  added  value  by  supporting  actions  with  a  transnational 
dimension,  boosting  national  capacities  and  optimising  procedures  related  to  migration 
management, and enhancing solidarity and responsibility sharing between Member States, 
in particular through emergency assistance and the relocation mechanism.  

Both the interim evaluation of AMIF 2014-2020 and the Impact Assessment of HOME 
funds undertaken in 2018 have underlined the importance to support legal migration and 
integration  of  third-country  nationals  to  face  the  decline  in  the  EU's  working  age 
population, enhance the sustainability of social security systems and support growth. The 
Impact  Assessment  also  identified  the  need  to  continue  the  support  for  actions  in  the 

8 Regulation (EU) No 516/2014 of the European Parliament and of the Council of 16 April 2014 establishing 
the  Asylum,  Migration  and  Integration  Fund,  amending  Council  Decision  2008/381/EC  and  repealing 
Decisions No 573/2007/EC and No 575/2007/EC of the European Parliament and of the Council and Council 
Decision 2007/435/EC. 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014R0516&qid=1752827657455  
9 SWD (2018) 347 final (LexUriServ.do) Proposal for a Regulation of the European Parliament and of the 
Council establishing the Asylum and Migration Fund; Proposal for a Regulation of the European Parliament 
and  of  the  Council  establishing  the  Internal  Security  Fund;  Proposal  for  a  Regulation  of  the  European 
Parliament  and  of  the  Council  establishing,  as  part  of  the  Integrated  Border  Management  Fund,  the 
instrument for financial support for border management and visa; Proposal for a Regulation of the European 
Parliament  and  of  the  Council  establishing,  as  part  of  the  Integrated  Border  Management  Fund,  the 
instrument for financial support for customs control equipment 
10 COM/2018/471 final, Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL establishing the Asylum and Migration Fund 

6 

 
 
external dimension, complementary to the support provided by the external Funds, as well 
as  for  catering  to  specific  needs  of  vulnerable  groups,  such  as  victims  of  trafficking  in 
human beings and children in migration.  

Overall,  through  AMIF,  the  EU  has  strived  towards  establishing  an  effective,  safe  and 
humanitarian  European  migration  policy,  which  addresses  both  legal  and  irregular 
migration and considers the safety of people seeking international protection or a better 
life, as well as the concerns of countries who worry that migratory pressures will exceed 
their capacities. Together with the integrated management of the EU’s external borders, 
the completion of a Common European Asylum System (CEAS) has contributed to share 
responsibilities  and  their  financial  implications  between  Member  States  fairly.  In  this 
respect,  the  AMIF  funding  is  playing  a  very  important  role  in  providing  financial  and 
operational support to Member States under pressure, thereby upholding the principle of 
solidarity and fair sharing of responsibility.  

Based on the Impact Assessment, the AMIF 2021 – 2027 pursues the general objective to 
contribute  to  the  efficient  management  of  migration  flows  and  to  the  implementation, 
strengthening  and  development  of  the  common  policy  on  asylum  and  the  common 
immigration policy, in accordance with the relevant Union acquis and fully respecting the 
international obligations of the Union and the Member States arising from the international 
instruments  to  which  they  are  party.  This  general  objective  is  further  elaborated  in  the 
following four Specific Objectives (SOs):  

1.  strengthening and developing  all aspects  of the  Common European Asylum  System, 

including its external dimension (SO1); 

2.  strengthening and developing legal migration to the Member States in accordance with 
their  economic  and  social  needs,  and  promoting  and  contributing  to  the  effective 
integration and social inclusion of third-country nationals (SO2); 

3.  contributing to countering irregular migration, enhancing effective, safe and dignified 
return and readmission, and promoting and contributing to effective initial reintegration 
in third countries (SO3); 

4.  enhancing solidarity and fair sharing of responsibility between the Member States, in 
particular as regards those most affected by migration and asylum challenges, including 
through practical cooperation (SO4). 

2.2 Intervention Logics 

To address the objectives above and illustrate the connection between the needs and how  
the AMIF implementation addresses those needs, an intervention logic has been developed 
for each specific objective. It provides a description of how and why desired changes is 
expected to happen as a result of the AMIF interventions.  

Specific Objective 1: Asylum 

The  objective  is  to  strengthen  and  develop  all  aspects  of  the  Common  European 
Asylum System, including its external dimension, by ensuring the uniform application 
of the Union acquis and priorities related to the CEAS. It supports the capacity of Member 
States'  asylum  systems,  including  infrastructure  and  services  at  various  levels,  and 
enhances cooperation with third countries to manage migration. This includes improving 

7 

 
protection for those in need of international protection and providing technical assistance 
to Member States in cooperation with the European Union Agency for Asylum (EUAA)11. 

The  target  groups  addressed  under  this  specific  objective  include  all  third-country 
nationals (TCNs) who are either in need of international protection, in migration, and those 
in  need  of  resettlement  or  humanitarian  admission.  Furthermore,  applicants  for  or 
beneficiaries  of  international  protection  or  asylum  are  also  targeted.  The  Fund  aims  to 
provide  legal  and  sustainable  support  that  responds  to  the  needs  of  each  target  group, 
including those who are particularly vulnerable, such as children.  

Under SO1, the AMIF addresses four key areas: reception conditions, asylum procedures, 
resettlement and humanitarian admission, and protection systems in third countries. Each 
of these areas addresses specific challenges through targeted interventions with intended 
tangible improvements in the asylum system12. 

Specific  needs  in  reception  include  insufficient  material  aid,  inadequate  infrastructure, 
gaps in identifying vulnerable groups, and limited staff capacity. Additionally, detention 
is used, and links between reception and social inclusion need strengthening. To address 
these  challenges,  interventions  focus  on  expanding  and  improving  reception  facilities, 
providing material aid, strengthening identification mechanisms for vulnerable groups, and 
training staff. Alternatives to detention and integration-focused support services are also 
developed. These measures aim to ensure that asylum seekers receive adequate assistance 
that infrastructure meets standards, and that trained staff apply best practices, including by 
fostering a more humane and effective reception system. 

With regard to asylum procedures, inefficiencies arise from delays, backlogs, inconsistent 
decision-making,  and  barriers  to  legal  and  procedural  support.  Strengthening  capacity, 
information-sharing,  and  digital  tools  is  key  to  overcoming  these  challenges.  The 
interventions  are  aimed  at  enhancing  country-of-origin  information  systems,  workflow 
efficiency,  and  accessibility  of  legal  assistance.  The  intended  result  are  accelerated 
procedures  and  facilitating  fairer  asylum  decisions,  based  on  better-informed  and  more 
transparent processes in Member States. 

Specific needs in resettlement include unclear procedures and limited capacity, affecting 
its  effective  implementation.  To  improve  this,  the  Fund’s  interventions  focus  on 
developing  structured  resettlement  frameworks,  enhancing  procedural  clarity,  and 
strengthening coordination with UNHCR. These efforts intend to achieve more predictable 
and  efficient  resettlement  processes,  reducing  dropout  rates  and  improving  access  to 
protection for those in need. 

With  regard  to  the  external  dimension,  protection  systems  in  third  countries  impact 
migration patterns and compliance with fundamental rights. Support focuses on building 
asylum capacity, improving legal frameworks, and strengthening reception conditions. By 
enhancing  protection  in  third  countries,  these  measures  contribute  to  safer  migration 
management and greater access to asylum outside the EU.

11 Annex II, point 1 d) of the AMIF Regulation 
12 Annex III point 1 of the AMIF Regulation 

8 

 
 
Figure 3: Intervention Logic for Specific Objective 1 

Specific Objective 2: Legal Migration and Integration 

The objective is concerned with strengthening and developing legal migration to the 
Member  States  in  accordance  with  their  economic  and  social  needs  as  well  as 
promoting and contributing to the effective integration and social inclusion of third-

9 

 
 
 
 
country  nationals.  It  aims  to  develop  and  implement  policies  that  promote  legal 
migration,  including  family  reunification  and  enforcement  of  labour  standards.  It  also 
focuses  on facilitating regular entry and  residence in  the  Union, enhancing cooperation 
with third countries, as well as promoting integration and social and economic inclusion 
of  third-country  nationals.  This  includes  measures  to  facilitate  family  reunification  and 
prepare third-country nationals for active participation in society.  

The main target group under SO2 are TCNs who are lawfully residing in an EU Member 
State or are in the process of obtaining such residency. Family members of individuals in 
the  target  group  can  also  be  included  in  the  measures  if  necessary.  The  objective  also 
includes  those  who  have  access  to  integration  or  professional  language  courses,  have  a 
residency  permit,  or  have  a  permit  for  skilled  employment  or  vocational  training.  The 
target  group  should  receive  tailored  support  to  ensure  successful  integration  and  social 
inclusion, while meeting the economic and social needs of Member States. TCNs receiving 
information  on  legal  migration  pathways  or  participating  in  mobility  schemes  are  also 
included.  

Under SO2, the AMIF  addresses  two key  areas:  international  and national  immigration 
policies and tools and local and regional integration measures for legally residing TCNs. 
Addressing the specific needs in these areas aims to ensure that TCNs  can access legal 
migration pathways, overcome barriers to integration, and participate fully in society. 

Specific needs in the area of international and national immigration policies and tools 
include  insufficient  information  for  TCNs  on  legal  migration  opportunities,  mobility 
obstacles, inconsistent family reunification procedures, and limited cooperation between 
Member States and TCs. TCNs often struggle to exercise their rights due to administrative 
complexities and a lack of structured support. To address these gaps, interventions focus 
on  developing  information  campaigns,  mobility  schemes,  and  support  mechanisms  for 
family  reunification  and  legal  migration  procedures.  Additionally,  cooperation  between 
Member  States  and  third  countries  is  enhanced  through  structured  tools  and  protocols. 
These  measures  aim  to  ensure  that  TCNs  have  better  access  to  clear  information,  legal 
pathways  become  more  transparent,  and  cooperation  between  countries  strengthens 
migration  governance.  In  the  long  run,  this  results  in  greater  participation  in  mobility 
schemes and more efficient handling of migration-related applications. 

At  the  local  level,  barriers  to  integration  include  limited  access  to  services,  language 
barriers,  insufficient  support  after  arrival,  and  underutilised  cooperation  with  non-
governmental bodies. Additionally, integration authorities face high workloads and require 
further  capacity-building  to  implement  effective  policies.  To  strengthen  integration 
outcomes,  interventions  include  pre-departure  measures,  tailored  integration  strategies, 
language training, skill  recognition  mechanisms, and legal  assistance for  TCNs. Efforts 
also focus on enhancing cooperation between governmental and non-governmental bodies, 
supporting host societies in engaging with integration efforts, and providing training for 
integration authorities. These activities aim to provide TCNs with better access to services, 
improve  language  proficiency,  and  participate  in  civic  and  economic  life,  while  local 
authorities and civil society strengthen their role in integration processes. Over time, these 
measures intend to contribute to more cohesive and inclusive societies, where TCNs can 
fully engage in their new communities.

10 

 
Figure 4: Intervention Logic for Specific Objective 2

11 

 
 
Specific Objective 3: Return  

The objective is to contribute to countering irregular migration, enhancing effective, 
safe  and  dignified  return  and  readmission,  and  promoting  and  contributing  to 
effective initial reintegration in third countries. It supports an integrated approach to 
return management at both Union and Member State levels. The development of capacities 
for  effective  returns  includes  supporting  assisted  voluntary  return,  family  tracing  and 
reintegration, while respecting the best interests of the child.  

The  target  groups  under  SO3  comprises  those  awaiting  decisions  on  their  residence 
permits, TCNs who opt for voluntary return to their countries of origin, individuals who 
do  not  meet  the  requirements  for  legal  residence,  including  those  for  whom  the 
enforcement of deportation has been postponed in compliance with the relevant articles of 
Directive  2008/115/EC,  those  who  have  already  left  the  EU  Member  State  either 
voluntarily or through a removal based on an adminstrative or judicial decision, and third-
country nationals in migration who are in their countries of origin or in transit countries 
with the purpose of countering irregular migration.  

Under SO3, the AMIF addresses four key areas: return procedures from EU Member States 
to third countries, reintegration support in  third countries, deterring irregular migration, 
and pre-return conditions and services in Member States. Targeted interventions in these 
areas  aim  to  ensure  that  return  processes  are  effective,  humane,  and  sustainable  while 
deterring irregular migration and improving pre-return conditions. 

Enhancing  the  efficiency  of return  procedures  and cooperation with  third countries  is 
essential for a credible return system. The interventions include providing information on 
voluntary  return,  strengthening  return  assistance,  improving  cooperation  with  third 
countries, and enhancing operational capacities. These efforts lead to greater awareness of 
return options, expanded support, streamlined procedures, and better monitoring of return 
operations, ensuring timely and effective returns. 

Limited reintegration opportunities can lead to re-migration through irregular pathways. 
To address this challenge, the interventions focus on developing reintegration support and 
strengthening services in third countries. These measures help returnees rebuild their lives 
and  ensure  temporary  accommodation  and  assistance,  with  the  aim  to  create  a  more 
sustainable return system. 

Lack of awareness about legal migration options contributes to irregular migration. To 
counter  this,  interventions  include  awareness  campaigns,  training  for  staff,  and 
mechanisms for irregular migrants to claim back wages and file complaints. These efforts 
aim  to  provide  the  migrants  with  more  and  improved  information,  enforce  migration 
regulations more strongly, and reduce irregular migration. 

Ensuring  dignified  and  safe  conditions  for  returnees  is  crucial.  Key  actions  include 
improving  reception  and  detention  facilities,  developing  alternatives  to  detention,  and 
enhancing  pre-return  support.  These  measures  lead  to  better  accommodation,  increased 
community-based  case  management,  and  improved  return  preparation,  particularly  for 
vulnerable groups.

12 

 
 
Figure 5: Intervention Logic for Specific Objective 3 

13 

 
 
Specific Objective 4: Solidarity and Fair Sharing of Responsibility 

This objective is to enhance solidarity and fair sharing of responsibility between the 
Member States, in particular as regards those most affected by migration and asylum 
challenges,  including  through  practical  cooperation.  This  includes  supporting 
resettlement  and  humanitarian  admission  in  the  Union  and  transfers  of  applicants  or 
beneficiaries of international protection from one Member State to another. This objective 
aims to foster a fair sharing of responsibility among Member States, particularly those most 
affected by migration and asylum challenges.  

The main target group of SO4 is the Member States as the interventions aim to enhance 
Member States  capacity to process  applications  for international  protection  and support 
applicants or beneficiaries of international protection. In addition, SO4 supports Member 
States resettlement and humanitarian admission efforts, thereby demonstrating solidarity 
with  third  countires  impacted  by  a  large  number  of  persons  in  need  of  international 
protection.   

Under SO4 (Solidarity and Fair Sharing of Responsibility), the AMIF is addresses two key 
areas: transfers between Member States, resettlement and humanitarian admission, as well 
as  operational  support  among  Member  States,  to  the  EUAA,  and  to  third  countries. 
Targeted interventions ensure a more balanced sharing of responsibilities across the EU, 
strengthening migration management and supporting Member States and third countries 
under pressure. 

Certain  Member  States  and  third  countries  face  disproportionate  migratory  pressures, 
requiring mechanisms to redistribute responsibilities and provide safe pathways for those 
in need of protection. Interventions under the fund include implementing humanitarian 
admission schemes, relocation within the EU, and resettlement from third countries. 
These  actions  aim  for  greater  voluntary  participation  of  Member  States  in  solidarity 
mechanisms,  pre-departure  support  for  TCNs,  and  the  facilitation  of  transfers  and 
resettlement  procedures.  Over  time,  these  measures  intend  to  relocate  applicants  and 
beneficiaries  of  international  protection  to  Member  States  with  greater  capacity,  while 
vulnerable persons are safely admitted to the EU from third countries. 

Member States with high numbers of TCN arrivals often require additional operational 
and financial support to maintain adequate reception conditions and asylum procedures. 
To address this challenge, interventions focus on establishing support measures between 
Member  States,  enhancing  reception  infrastructure,  and  providing  seconded  staff  and 
financial  resources  to  Member  States  and  EUAA.  These  efforts  aim  to  improve  the 
equipment of reception facilities, increase staffing capacity, and financial assistance where 
needed.  In  the  long  term,  Member  States  facing  migratory  pressures  can  improve  their 
reception systems and asylum processes, aiming to ensure a more effective and balanced 
EU migration system.

14 

 
 
Figure 6: Intervention Logic for Specific Objective 4

15 

 
 
2.3   Points of comparison  

EU funding for asylum, migration and integration policy has developed and evolved over 
several funding period. Given this, and the early stage in delivery of the AMIF 2021-2027, 
it is hard to delimit where results from one funding period begin and end, there are also 
differences across Member States and external factors that contribute to progress (or the 
lack thereof). As such, it is useful to highlight the main structural differences between the 
AMIF  2021-2027  and  the  AMIF  2014-2020,  starting  with  the  allocation  of  funds,  and 
several structural differences. This is complemented by the different elements for assessing 
the  performance  of  the  AMIF  2021-2027  against  its  predecessor,  and  other  points  of 
comparison (i.e. comparative progress across Member States, impact of external factors 
and comparisons with similar EU funds).  

For  the  post-2020  period,  four  main  challenges,  applicable  to  the  Home  Affairs  Funds, 
were identified by the 2018 Impact Assessment:  

a)  Enhancing flexibility for allocating budget to the needs within a stable framework;  

b)  Further simplifying the rules for implementing EU Funds;  

c)  Ensuring more coherence and synergies between actions supported by EU funding 

instruments;  

d)  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. 

To face those challenges, several features were introduced in the policy set-up and delivery 
model of the AMIF 2021-2027. 

Comparison with AMIF 2014-2020 

As indicated above, the main point of comparison is the performance of the AMIF 2021-
2027  against  its  predecessor  from  2014-2020  -  although  due  note  must  be  taken  of  the 
differences between the two funds in terms of resource allocation decisions and delivery 
before arriving at conclusions.   

It should be noted that the ex-post evaluation was ongoing and at a preliminary stage at the 
time of writing this Staff Working Document, hence the final results regarding the ex post 
evaluation are not yet available to serve as a basis for comparison. As a response to the 
Russian war of aggression against 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.  

16 

 
 
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 implementation as a continuum. This 
has allowed to have retrospective view, as well as complying with the requirement in the 
AMIF regulation (13) to take into account the results of the retrospective evaluation for the 
2014-2020 period. 

In addition, serving as best available data, the findings from the interim evaluation of the 
AMIF  2014-2020  programming  period  from  2018  as  well  as  data  from  SFC2014  for 
implementation of the AMIF 2014-2020 up until the end of 2017 have been used as a point 
of comparison.14 Notably, since SFC2014 contains annual data for the implementation, the 
considered implementation period for the AMIF 2014-2020 is 6 months longer than the 
available data for the present evaluation, which covers an implementation period up until 
30  June  2024.  Therefore,  caution  must  be  applied  with  regard  to  the  interpretation  of 
comparisons of the progress made. Taking these precautions into account, at the mid-term 
stage  of  the  AMIF  2014-2020,  a  total  of  EUR  4,27  million  was  allocated  to  the  Fund, 
compared  to  the  initially  foreseen  budget  of  EUR  1,70  million,  representing  a  152% 
increase relative to what was originally envisaged.15 In terms of financial progress, about 
60% of the  allocated16  budget had been  committed17 and  paid (EUR  2.6 billion) for 
activities  under  the  AMIF  by  the  end  of  2017.  The  largest  share  of  funding  was 
committed and paid for the National programmes (EUR 1.1 billion) and EMAS (EUR 
1 billion). Union Actions had about EUR 419 million committed and paid, and EMN had 
about EUR 54 million committed and paid. About EUR 14 million were committed and 
paid under Specific Actions. 

In terms of physical progress, Member States made good progress in the achievement of 
targets for the common indicators listed in Annex VIII of the AMIF Regulation18  within 
the  first  three  years  of  the  2014-2020  programming  period.  Notably,  there  had  been 
substantial progress  for common indicators  related to the number of target group 
persons who had received assistance co-financed by the AMIF, such as the number of 
persons aided through projects in the field of reception and asylum systems (SO1 R1)19, as 

13  Article 34(1). 
14  The  2018  Interim  evaluation  has  been  conducted  at  roughly  the  same  point  in  time  during  the 
implementation phase as the present mid-term evaluation. The data that informed the 2018 Interim evaluation 
comprises an implementation period up until 30 June 2017, corresponding to the data used for the present 
mid-term evaluation which includes implementation up until 30 June 2024.  
15 Numbers on overall allocated resources (until end of 2017) are taken from the 2018 Interim evaluation of 
the AMIF 2014-2020. 
16 Allocated resources correspond to the resources that have been designated to each specific objective and 
each country. They represent the programming stage of AMIF. 
17 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. 
18 A list of the common indicators is provided in Annex II. 
19 By the  end of 2017 a total of  1,348,245  target group persons had been supported by the fund through 
projects in the field of reception and asylum systems, out of 1,263,700 persons planned across all Member 
States. 

17 

 
 
well as the number of persons aided through integration measures (SO2 R2)20. Likewise, 
the overall target for the number of persons trained in asylum-related topics with assistance 
of the fund (SO1 C3.a) had been achieved for the most part.21 

Increased funding for AMIF in the 2021-2027 programming period  

The AMIF 2021-2027 benefits from a significantly larger financial allocation compared to 
its  predecessor.  In  response  to  the  migratory  and  security  crises  that  occurred  in  the 
previous period, the AMIF budget increased from almost EUR 3.14 billion in the 2014-
202022 period to EUR 9.88 billion for the 2021-2027 programming period23.  

Increased Flexibility 

First, to increase financial flexibility and increase the response capacity of the instrument 
to critical situations, a “Thematic Facility” was created “to respond to pressing needs and 
changes in policy and Union priorities, and to steer funding towards actions with a high 
level  of  Union  added  value”24.  Accordingly,  part  of  the  AMIF  funding  is  periodically 
allocated, via the Thematic Facility, to Specific Actions (implemented through the Member 
States  programmes,  in  shared  management),  to  Union  Actions,  to  actions  of  local  and 
regional authorities, to emergency assistance, to resettlement and humanitarian admission, 
and to additional support for Member States contributing to solidarity and responsibility 
efforts.  

In addition, based on the insight gained in the 2014-2020 period that fixed allocations do 
not always permit to reflect the changing needs of the Member States over time, for the 
2021-2027 programming period, the AMIF includes the allocation of additional funding 
following a mid-term review, ensuring that funding is allocated based on performance and 
the effective use of previous allocations.  

Legal Framework 

A significant point of comparison is the shift in the legal framework governing the AMIF. 
In terms of simplifying the rules and streamlining the AMIF, along with the other Home 
Affairs Funds, has been included under the scope of the CPR. The CPR provides common 
rules for the implementation of eight Funds (including those under Cohesion and Maritime 
and Fisheries policies) in shared management. The application of the CPR rules to AMIF 
and other Funds was also meant to enhance the overall coherence  and synergies among 
those  Funds.  It  also  entailed  a  refocus  on  performance,  with  more  regular  reporting  on 
outputs and results, and the promotion of performance-based tools, such as financing not 
linked to costs. The 2021-2027 CPR has also enhanced the legal framework for simplified 
cost options. For instance, as regards grants provided to beneficiaries, Member States can 
increasingly make use of the simplified cost options since the regulation provides methods 

20 By the  end of 2017 a total of  2,916,996 target group persons had been supported by the fund through 
integration measures (in the framework of national, local and regional strategies), out of 2,618,062 persons 
planned across all Member States. 
21 This refers to the sum of implemented values compared to the sum of target values across Member States. 
By the end of 2017 a total of 22,898 persons had received training in asylum-related topics, out of 25,205 
persons planned across all Member States. 
22 Overall allocated resources (2014 to 2020) are taken from the 2018 Interim evaluation of the AMIF 2014-
2020. 
23 These are the initial financial envelopes.  
24 Recital 44 of the AMIF Regulation. 

18 

 
 
and rates that are able to be used without the requirement for Member States to carry out a 
calculation or define a methodology. Furthermore, the threshold linked to the obligatory 
use of simplified cost options is linked to the total costs of the operation in order to ensure 
the same treatment of all operations below the threshold, regardless of whether the support 
is  public  or  private.  Finally,  simplified  cost  options  can  be  used  at  two  reimbursement 
levels: (1) reimbursement of the Union contribution by the Commission to the Member 
States’ programmes and (2) reimbursement of grants provided by the Member States to 
beneficiaries. 

The reporting and monitoring framework for the AMIF 2021-2027 has also been improved 
to better enable tracking of whether the AMIF delivers the intended results and to inform 
potential  changes  to  policy  intervention  (Articles  33  and  36  of  the  AMIF  Regulation). 
Progress towards the Fund's specific objectives is tracked using common output and result 
indicators listed in  Annex VIII  of the AMIF Regulation, with  output  indicators starting 
from a baseline of zero and setting cumulative milestones for 2024 and targets for 2029. 

The Performance Framework 

The integration into the CPR rules   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 the 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. Pursuant to Article 33 (3) AMIF, 
Commonoutputs and result indicators assess the progress of the Fund towards the  specific 
objectives set out in Article 3(2) AMIF, are laid down in Annex VIII of AMIF. Targets 
and milestones as set out in Article 2 (11) and (12) of the CPR respectively,  also allow the 
Commission and the Member States to measure progress towards the achievement of the 
specific objectives25. Pursuant to Article 33 (3),the baseline for output indicators should be 
at zero at the beginning of the programming period. The result indicators measure results 
linked to the operations funded and were also set as zero as they were linked to the output 
indicators26. 

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 while allow to aggregate 
targets  and  results at  EU level  in  order to  assess  overall progress  when it comes to  the 
retrospective evaluation. 

25 Article 16(3) of the CPR. 
26 Article 33(3) of the AMIF Regulation. 

19 

 
 
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.  

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

All the 26 AMIF Member States programmes were approved by the end of 2022, the 
majority of them during the last quarter. This delay was mainly due to the late adoption of 
the legal framework (June 2021), as the respective negotiations were in turn delayed by 
the  Covid-19  pandemic.  The  initial  Member  States    programmes  cover  the  initial 
allocations allocated to each programme for the period 2021-2027, for a total amount of 
around EUR 5.2 billion in Union contribution (of which 66% allocated to five Member 
States:  Germany,  Greece,  France,  Spain  and  Italy)27.  Over  time  allocations  from  the 
Thematic  Facility  to  the  Member  States  programmes  (via  Specific  Actions, 
Resettlement  and  Humanitarian  Admissions  and  Relocation)  have  increased  the  budget 
covered by the Member States programmes to around EUR 6.2 billion by 30 June 2024. 
The bulk of this increase is represented by the resources planned in relation to resettlement 
and  humanitarian  admission,  which  reached  an  amount  of  around  EUR  844  million  in 
Union contribution in 11 Member States (BG, DE, ES, FR, FI, IT, NL, PT, RO, SE, SI). 
The  additional  resources  from  the  Thematic  Facility  for  resettlement,  humanitarian 
admission and relocation have been allocated through amendments to the Member State 
programmes.  

An additional amount of around EUR 1 billion, for the period 2025-2027, is being allocated 
to the Member States programmes in 2025, subject to the reaching of a minimum spending 
level of 10% of the initial allocations by 31 December 202428. Also in this case, this is 
being  implemented  through  amendments  of  the  Member  States    programmes,  to  be 
submitted by the relevant Member States during the year 2025. Further to the mid-term 
review  pursuant  to  Article  17  AMIF,  Member  States  should  not  be  eligible  to  receive 
additional allocations to the programmes not satisfying the minimum spending level laid 
down in Article 17 (2) AMIF. If the amount set out in Article 13 (1), b), AMIF for the 
adjustments of the allocations to the Member States’ programmes referred to in Article 17 
(1) AMIF, the remaining amount may be allocated to the budget of the AMIF Thematic 
Facility work programmes pursuant to Article 10(2), b) AMIF, for the years 2025, 2026 
and 2027.  

The first AMIF Thematic Facility work programme, covering the years 2021 – 2022, 
was  adopted  on  25  November  2021,  for  an  overall  amount  of  EUR  879,681,861.    A 
separate work programme only covering emergency assistance (EMAS) for 2021 (EUR 
80,000,000) was adopted on 17 August 2021. This was due to the need to mobilise quickly 
funding  under  EMAS  (see  below).  Also,  the  first  work  programme  for  the  European 
Migration Network (EMN) covering the period 2021-2022 was adopted separately, on 26 
November 2021, as the procedure for the adoption of this work programme is different 
from the procedure applying to the AMIF work programme. The budget assigned to the 

27  For  some  Member  States  the  initial  programmes  also  included  amounts  allocated  from  the  Thematic 
Facility in relation to Resettlement and Humanitarian Admission. 
28 Article 17(2) of the AMIF Regulation: where at least 10 % of the initial allocation to a programme referred 
to in point (a) of Article 13(1) of this Regulation has not been covered by payment applications submitted in 
accordance with Article 91 of Regulation (EU) 2021/1060, the Member State concerned shall not be eligible 
to  receive  the  additional  allocation  for  its  programme  referred  to  in  point  (b)  of  Article  13(1)  of  this 
Regulation. 

20 

 
 
EMN  work  programme  is  EUR  22,976,000.  By  mid-2024  the  AMIF  work  programme 
2021-2022,  the  specific  EMAS  2021  work  programme  and  the  EMN  work  programme 
were  fully  implemented,  meaning  that  the  corresponding  budget  was  fully  committed, 
either  by  allocating  additional  resources  to  the  Member  States’  programmes  (Specific 
Actions,  resettlement,  and  relocation,  implemented  in  shared  management)  or  through 
grants  and  other  administrative  arrangements  (Union  Actions,  implemented  in  direct  or 
indirect  management).  The  AMIF  work  programme  2021-2022  was  amended  six  times 
over the last years, to adapt its content to evolving needs, thus underpinning the financial 
flexibility built in the Thematic Facility instrument.  

As regards the second round of Thematic Facility work programmes for the period 
2023 - 2025, the AMIF work programme was firstly adopted on 23 November 2022 with 
a budget of EUR 1,490,539,000 and subsequently amended five times by mid-2024. The 
EMN  work  programme  was  adopted  on  17  October  2022,  with  a  budget  of  EUR 
36,000,000.  

The initial implementation of the funding was substantially affected by the Russian 
war of aggression against Ukraine, and the related inflow of persons benefitting from 
Temporary Protection in the EU. This situation created an unforeseen and acute pressure 
on the asylum and reception systems in a range of Member States, both for those sharing 
the  border  with  Ukraine  and  other  Member  States,  such  as  Germany  and  Czechia. 
Similarly, the instrumentalisation of irregular migration at the EU Eastern borders 
led to historically high migration flows into Latvia, Lithuania and Poland, also exposing 
them to extraordinary pressure.  In response, the Commission mobilised support in the 
form of emergency assistance under the AMIF 2021-2027. Since this happened at a time 
when the Member States programmes were not yet approved, the quick mobilisation of 
EMAS was particularly important. In addition, the legislative framework governing the 
2014-2020 period was modified29, to prolong by one year the implementation period (i.e. 
from June 2023 30to June 2024) and to introduce financial flexibility for Member States to 
reallocate  amounts,  which  were  technically  earmarked  for  specific  purposes  (e.g. 
resettlement) in the programmes. That allowed to quickly mobilise financial resources for 
the  Member  States  to  face  immediate  needs  in  the  aftermath  of  the  Russian  war  of 
aggression against Ukraine, notably in relation to asylum and reception systems, as well 
as  early  integration  of  persons  fleeing  the  war.  The  extension  of  the  2014  –  2020 
programming  period  also  prolonged  the  overlapping  period  between  the  AMIF  2014  – 
2020 and the AMIF 2021 – 2027, thus entailing additional pressure on the administrative 
system and relevant authorities of the Member States.   

As regards the progress in the execution of the Fund, by mid-2024 the Member States 
programmes were still at a relatively early stage of implementation.  As a common 

2021/1147 

establishing 

29  Regulation  (EU)  2022/585  of  the  European  Parliament  and  of  the  Council  of  6  April  2022  amending 
Regulations (EU) No 514/2014 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,  (EU) No 516/2014 establishing the Asylum, Migration and Integration Fund and 
(EU) 
Fund. 
http://data.europa.eu/eli/reg/2022/585/oj  
30  Commission Implementing Decision C(2021) 6023 final of 17.8.2021 on the financing of the Emergency 
Assistance component within the Thematic Facility of the Asylum, Migration and Integration Fund and the 
adoption of the work programme for 2021. As amended by Commission Implementing Decision C(2021) 
9622 final of 17.12.2021. Also funded through Commission Implementing Decision C(2021) 8458 final of 
25.11.2021  on  the  financing  of  components  of  the  Thematic  Facility  under  the  Asylum,  Migration  and 
Integration Fund and adoption of the Work Programme for 2021 and 2022, as amended. 

Asylum,  Migration 

Integration 

and 

the 

21 

 
 
pattern to all funds implemented in shared management, Member States need time before 
being able to allocate and spend their appropriations. This includes the time necessary for 
setting-up  the  necessary  structures  and  procedures,  as  well  as  for  completing  project 
selection procedures, which is a prerequisite to spending the budget.  

Moreover, information retrieved from the Annual Performance Reports31 points to delays 
in the start of the implementation on the ground (launching calls and their attribution 
to the final beneficiaries) in Member States due to more specific challenges, such as: 

• 

• 

the national legal framework requiring a lengthy procedure and many steps for the 
implementation of public tenders and the conclusion of contracts;  

 delays  in  the  decision  making  on  the  institutional  set-up  governing  the 
management of the programme (change in the Managing Authority, etc.)  and the 
attribution of the necessary human resources. 

•  complex  application  procedures  and  the  applicants'  lack  of  experience  with  EU 
funding, along with a certain complexity in the development and understanding of 
the new IT system for these procedures  

•  delays attributed to the incorporation of the requirements under the CPR in relation 
to  the  Home  Affairs  Funds,  requiring  administrative  efforts  by  the  Managing 
Authorities  in  parallel  to  the  programming  exercise  in  2022  and  often  still 
throughout 2023. 

Remedial actions to overcome the initial delays and accelerate the implementation of 
the programmes were put in place in several Member States. These generally relate to 
increasing human resources and strengthening coordination between different actors (e.g. 
stricter  collaboration  with  the  International  Organization  for  Migration  (IOM)), 
simplification of administrative procedures, and IT developments.  

On  average,  by  June  2024,  45.9%  of  the  Member  States  programmes  allocations 
(including allocations transferred  from the Thematic Facility) was committed with 
final beneficiaries (“operations selected for support”), of which 13.9% was already 
paid. The most advanced programmes in terms of spending32 were Finland (36%), Sweden 
(35%), France (29%), Greece (16%) and Germany (15%). Spending  levels  were still at 
zero in four Member States: Slovakia, Poland, Hungary and Ireland.  

When looking at the funds committed under both the Member States programmes and the 
Thematic  Facility33,  the  support  dedicated  to  reception  conditions,  legal  pathways 
(including  resettlement  and  humanitarian  admission)  and  integration  measures 
account for the largest share of resources committed, with a total of EUR 2.4 billion 
(66% of the total of committed resources). A sizable part of the Union Actions component 
of the Thematic Facility supports projects in the field of external dimension, via funding 

31 In accordance with Article 35 of the AMIF Regulation.  
32 Spending refers to EU payments made in response to an interim payment application to the EU for eligible 
expenditure incurred and paid to project beneficiaries.  
33 Resources committed 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. 

22 

 
 
to  the  Migration  Partnership  Facility  and  the  Regional  Development  and  Protection 
Programme. Specific Actions contribute to different areas of support with a clear focus on 
vulnerable persons, including children and victims of trafficking in human beings. 

Figure  7:  Resources  committed  by  areas  of  support  and  Fund  component  (in  EUR,  at 
30/06/2024) 

Source: Mid-term Evaluation study report, based on SFC 2021 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

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

4.1.1 Effectiveness 

Given the late start of the implementation of the Fund, the evaluation is not in a position 
to provide an assessment on its effectiveness. 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 achieving the objectives by the end of the programming period. 

Progress in the implementation of Member States’ programmes  

Financial Progress 

After  approximately  1.5  years  from  the  approval  of  the  Member  State  programmes, 
financial progress is visible across all Specific Objectives (SO), with nearly 46% of the 
allocated  resources  committed  to  selected  operations.  The  absorption  rate34 
(resources paid, 11% on average) is the highest under the CPR, especially for SO1 
(Common  European  and  Asylum  System)  and  SO2  (Legal  Migration  and 
Integration). This reflects a continuing high level of needs from the target groups as well 
as the ability from all actors involved in the implementation of the Fund to offer timely 

34  This  corresponds  to  the  ratio  between  the  costs  declared  and  the  allocations.  It  measures  the  effective 
implementation of activities. 

23 

 
 
support. The financial progress by Specific Objectives and main areas of support, by 30 
June 2024 are given in the following graphs: 

Figure 8: Financial progress by intervention field for SO1 

Financial Progress by intervention field, SO1

Reception conditions

Asylum procedures

Children in migration

Union resettlement programmes or national…

Implementation of the Union acquis

Operating support

Persons with special reception and procedural needs

SO1 average

0%

20%

40%

60%

80%

100%

implementation rate 
commitment rate

absorption rate 
expenditure rate

For  SO1  (Common  European  and  Asylum  System),  the  high  rate  of  commitments  in 
relation  to  “Reception  Conditions”  are  most  probably  triggered  by  the  high  number  of 
persons benefiting from temporary protection due to the Russian war of aggression against 
Ukraine. 

Figure 9: Financial progress by intervention field for SO2 

Financial Progress by intervention field, SO2

Vulnerable persons, including unaccompanied minors
Integration measures – civics and other training
Pre-departure measures
Development of integration strategies

Integration measures – Introduction, participation, …

Integration measures – language training

Integration measures – information and orientation, …

Acquisition of legal residence
Integration measures – basic needs
Operating support
Mobility schemes
Victims of trafficking in human beings
SO2 average

0%

20%

40%

60%

commitment rate
implementation rate 

expenditure rate
absorption rate 

For  SO2  (Legal  Migration  and  Integration),  integration  measures  show  the  best  ratio 
between resources committed resources and resources paid, also in this case following a 
similar pattern as SO1. Mobility schemes and support to victims of trafficking in human 
beings show a relatively slower start. 

24 

 
 
 
Figure 10: Financial progress by intervention field for SO3 

implementation rate 

absorption rate 

SO3  (Return,  Reintegration  and  Countering  Illegal  Migration)  shows  a  less  marked 
progress compared to SO1 and SO2 (but still relatively higher than other Home Affairs 
Funds), most probably due to inherent difficulties of return measures, demanding needs in 
terms of coordination and dependence on the cooperation of third countries.  

Figure 11: Financial progress by intervention field for SO4 

implementation rate 

absorption rate 

25 

 
 
 
 
 
In the case of SO4 (Solidarity and fair sharing of Responsibility), the high level of progress 
is  clearly  influenced  by  the  role  played  by  the  allocations  related  to  resettlement  and 
humanitarian  admissions,  which  follow  a  specific  programming  cycle.  Member  States 
inform  the  Commission  of  their  intent  to  participate  in  resettlement  and  humanitarian 
admissions by submitting a voluntary pledge to the Commission during specified periods. 
The  pledges  specify  the  number  of  persons  to  be  resettled  and/or  admitted  through 
humanitarian admission. Thus far, three pledging cycles have been conducted (covering 
the  years  2021-2022,  2023,  and  2024-2025).  The  related  resources  are  then  regularly 
allocated to the relevant Member States through amendments to their AMIF programmes, 
based on the financial progress in the implementation of their previous pledges. 

Progress of Output and Result Indicators 

Evidence  suggests  that,  despite  some  delays  at  the  beginning  of  the  funding  period, 
Member States are progressing towards the Fund’s operational objectives, albeit with 
notable variations in terms of progress of indicators. As of 30 June 2024, five Member 
States (IE, HU, MT, PL, SK) reported no progress across any output and result indicators. 
At  the  same  time,  some  Member  States  reported  having  exceeded  milestone  and  target 
values for some indicators by a substantial margin (DE, LV, SE, PT, BE, HR, EL, FI in 
the case of output indicators, and RO in the case of result indicators). 

As regards specifically the progress of output indicators towards their milestones, by 
Specific Objective (SO), on average SO1 (Common European Asylum System) shows the 
best performance (72%), followed by SO2 (Legal migration and integration) (25%), SO3 
(Return) (21%) and SO4 (Solidarity) (16%). However, as regards SO4 it should be noted 
that the activities in relation to resettlement, humanitarian admission and relocation, which 
represent the main components in financial terms under this objective, are not captured by 
the milestones on output indicators, but rather by the progress towards the targets for result 
indicators (see below). Progress towards the milestones for output indicators also varies 
across  Member  States.  The  figure  below  shows  average  milestone  performance  rates35 
across output indicators, by Specific Objective (1, 2, 3 and 4) for all 25 Member States for 
which data were available.36 

35 The rate of progress of the output indicators compared to the milestones set by the Member States. 
36  Progress  to  milestones  for  a  Member  State  under  a  Specific  Objective  is  illustrated  as  the  average  of 
milestone performance rates across output indicators under the Specific Objective, excluding sub-indicators. 
While this methodology helps to display progress at the aggregate level, it remains prone to outliers. Notably, 
some Member States reported having exceeded milestone values for some indicators by a substantial margin, 
with progress rates exceeding 100% (DE, LV, SE, PT, BG, HR, EL, FI, NL). Table 7 of SFC2021 did not 
contain data on Ireland as of 30 June 2024. 

26 

 
 
 
 
 
 
 
 
Figure 12: Average milestone performance rates across output indicators 

Average milestone performance rates across output indicators, by 
Specific Objective and Member State (in %)

2,5

2

1,5

1

0,5

0

FR AT BE BG CY CZ DE EE EL ES

FI HR HU IT

LT LU LV MT NL PL PT RO SE SI

SK

4

3

2

1

Looking at the individual output indicators, on average, the faster progress towards the 
milestones  across  Member  States  was  reported  under  the  following  output  indicators: 
“Number of participants supported” under SO2, “Number of returnees who received re-
integration  assistance”  under  SO3  and  “number  of  participants  supported”  under  SO1, 
which reached 81%, 62% and 20% respectively. The strong achievements in these areas 
(for  which  similar  trends  were  observed  in  the  2014-2020  programming  period)  are 
possibly due to the nature of indicators under SO1 and SO2 (number of persons supported), 
as well as to contextual elements, such as the sudden increase of persons fleeing the war 
in Ukraine (not initially foreseen and quantified in the level of the milestones). The average 
progress rates for the remaining output indicators are below 4%. 

When looking at the targets of result indicators, across Member States, on average, the 
highest  progress  was  reported  under  those  belonging  to  SO4,  notably:  “Number  of 
applicants for and beneficiaries of international protection transferred from one Member 
State to another” (under relocation), “Number of persons admitted through humanitarian 
admission” and “Number of persons resettled”, which reached rates  of 34%, 30% and 24% 
respectively. This trend reflects that fact that the funding of relocation, resettlement and 
humanitarian admission happens through the Thematic Facility, and the respective target 
levels are progressively adjusted as long as corresponding financial resources are allocated 
from the Thematic Facility to the programmes. The average progress towards the targets 
of the remaining common result indicators is below 9%, with the most performing ones 
being: “Number of participants who applied for their qualification or skills acquired in a 
third country to be recognised / assessed”, “Number of returnees who were removed” and 
“Number of participants who consider the training useful for their work”. When looking 
at the achievements realised in terms of result indicators, it should also be noted that the 
result  indicators  under  SO1  and  SO2  rely  on  survey  data  collected  among  participants, 
which  may  be  affected  by  methodological  issues  (e.g.  non-response  rate  and  time-lag 
between the end of certain operations and the supply of the corresponding data) leading to 
under-estimation. 

In addition to the late start of implementation of the Fund, several external and internal 
challenges have impacted the Fund’s progress. Externally, the Russian war of aggression 

27 

 
 
towards  Ukraine  led  to  changing  needs.  The  COVID-19  pandemic  brought  its  own 
challenges in containment of the second wave of COVID-19 and administrative capacity. 
The results of the targeted survey for Managing Authorities showed that 14 out of 26 (53%) 
of the Managing Authorities consider the sudden influx or long-term influx of migrants, 
in particular due to the Russian war of aggression in the Ukraine as well as COVID-
19, to be the challenges with the greatest negative impact on implementation of the Fund. 
Member  States  also  faced  challenges  internally.  These  included  challenges  related  to 
internal organisation, a lack of experienced staff with certain expertise, and the regulatory 
environment within MS.  

As demonstrated in the Annual Performance Reports (APRs), Member States developed 
various remedy strategies to deal with these challenges. Several MS invested in new and 
flexible reception capacities and strengthening coordination between actors (CZ, LU, NL, 
PT,  SE,  SI).  Belgium  and  Ital  simplified  administrative  procedures  to  enhance  the 
processing  of  current  and  new  arrivals.  Germany  increased  their  staff  and  enhanced 
cooperation with the International Organization for Migration.  

Progress in the implementation of the Thematic Facility  

A total of 675 projects under direct and indirect management (i.e. Union Actions and 
Emergency Assistance (EMAS)) were signed by June 2024 (of which 19 under EMAS). 
The  highest  number  of  projects  were  signed  in  the  broad  areas  of  support  under 
“Integration  Measures  –  Employment  and  Access”,  with  166  projects,  as  well  as 
“Reception Conditions” and in relation to the “EMN activities” with each 65 projects. 

Under the Specific Actions, a total of seven calls were launched by June 2024, most of 
which were open and competitive calls (with topics such as “reception at the borders” and 
“unaccompanied minors”), others targeted to one Member State which would support a 
project in the interest of all Member States, such as the improvement of tools for language 
assessment in the field of asylum. The activities covered the areas of “Support to children 
and persons with special and procedural needs, including victims of trafficking of human 
beings” as well as “Reception Conditions”.  

As regards “Resettlement and Humanitarian Admission”, by June 2024, 12 Member 
States committed a total of EUR 730 million in Union contributions (see section 3) and 
three  Member  States  (DE,  FI,  SI)  reported  a  total  of  EUR  14.7  million  in  Union 
contributions  for  transfers  of  international  protection  beneficiaries  and  applicants 
(“Relocation”). 

Based on qualitative information retrieved through case studies and targeted surveys, the 
implementation of both Union Actions and EMAS projects is perceived by stakeholders to 
be on track according to the envisaged timetable. 

As regards more in particular the Union Actions, they are considered particularly effective 
in strengthening and developing legal migration to the Member States in accordance with 
their economic and social needs and to contribute to the effective integration and social 
inclusion of third-country nationals (TCNs):  

28 

 
 
 
 
Figure 13: Results of targeted survey for effectiveness 

Results of the survey on the effectiveness of Union Actions (N=36) 

Improve the cooperation with third countries compared with the
past

1

5

7

8

15

Effective in supporting the Member States capacity to manage the
migration crises and enhance the cooperation with Third countries

1

7

6

9

Effective in enhancing solidarity and fair sharing of responsibilities
between the Member States, particularly those most affected by
migration and asylum challenges, including through practical
cooperation

1

4

11

Effective in contributing to countering irregular migration,
enhancing effective, safe, and dignified return and readmission,
and promoting and contributing to effective initial reintegration in
third countries

Effective in strengthening and developing legal migration to the
Member States in accordance with their economic and social needs,
and promoting and contributing to the effective integration and
social inclusion of third-country nationals

1

9

7

13

13

14

7

5

2

5

15

6

8

Effective in strengthening and developing all aspects of the
European Common Asylum System, including its external
dimension

1

1

17

4

13

To a very low extent

To a low extent

To a high extent

To a very high extent

I don’t know / prefer not to answer

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Targeted survey with beneficiaries (August – September 2024) 

Assessment by the AMIF Managing Authorities 

Based on the case studies and dedicated surveys that took place during the evaluation, the 
Managing Authorities held an overall positive perception of the effectiveness of the 
Fund  to  address  its  intended  objectives,  despite  the  relatively  limited  time  of 
implementation.  

This  is  particularly  visible  in  areas  such  as  the  AMIF’s  capacity  to  provide  targeted 
assistance to third-country nationals throughout the asylum procedure and to persons with 
special needs within this target population, including minors, across all the areas of support 
(reception, asylum, integration, return). Stakeholders expressed lower confidence on the 
effectiveness  of  more  systemic  measures  such  as  the  development  of  strategies  and 
innovative approaches across most specific objectives.  

Effectiveness of the Monitoring System  

Overall, at this stage the set of data recorded is not yet sufficient to assess the effects 
and potential future impacts of the Fund. A closer examination of the Member States 
involved in the country case studies reveals that for six out of the seven Member States 
(EL, FR, IT, LT, PL, RO) analysed, no meaningful conclusions can be drawn from the data 
provided. The insufficiency of data may be attributed to the early stage of implementation, 
during  which  not  enough  information  has  been  collected  and  reported  by  the  Member 
States. Nevertheless, the preparatory work undertaken during this evaluation demonstrate 
the  current  monitoring  system  and  performance  framework  has  great  potential  to 
adequately  capture  the  long-term  impacts  of  the  Fund.  Therefore,  while  definitive 
conclusions cannot be drawn at this time, it is anticipated that as the programmes progress 
and  data  collection  efforts  enhance,  a  clearer  understanding  of  the  Fund's  impacts  will 
emerge. 

29 

 
 
In terms of adequacy of the indicator system, the common outputs and result indicators 
laid down  in  Annex  VIII  of  the  AMIF  Regulation37  are  considered  to  capture  to  a 
certain extent the quantifiable and comparable main achievements of the Fund in line 
with its intervention logic. Nonetheless, there is room for additional indicators in order 
to better cover the scope of the AMIF support in a more exhaustive manner.38 Examples 
include: 

1. 

2. 

3. 

4. 

For SO1, the material aid provided to the target population is considered difficult 
to be assessed, in lack of a dedicated sub-indicator. Additionally, there is limited 
opportunity to capture the effects of the funding for services in the area of social 
inclusion.  

The  effects  of  the  interventions  under  SO2  are  largely  captured  by  the  existing 
indicators.  However,  there  is  no  counting  of  members  of  the  host  society 
participating in relevant projects.  

With  regard  to  SO3,  the  common  output  and  result  indicators  reflect  the  main 
achievements anticipated by the intervention logic. Nevertheless, Member States 
are not asked to report the number of developed facilities and support services in 
third countries for the purpose of reintegration.  

While the number of resettled and relocated persons are covered by indicators, SO4 
has  room  for  improvement  in  terms  of  the  number  of  staff  provided  to  other 
Member States and EUAA. 

A  number  of  improvements  are  visible  with  respect  to  the  previous  programming 
period, notably as regards the development and better coverage of the common indicator 
system, as well as in terms of information, explanatory documents and tools that have been 
made  available  for  the  users  of  the  monitoring  system.  This  also  includes  the  targeted 
support  that  has  been  provided  through  dedicated  training  (including  webinars)  at  the 
central level, while it is noted that margins of improvement still exist to support the 
understanding of monitoring requirements by the final beneficiaries. In addition, the 
positive progress in the use of standard templates is observed, which for example have 
helped to streamline reporting requirements on indicators and within APRs.  

Still  on  the  positive  side,  qualitative  evidence  supports  the  conclusion  that  a  reliable 
electronic  exchange  system  for  recording  and  storing  data  between  beneficiaries  and 
authorities has been developed and is operating in accordance with the Article 69 (8) CPR. 

In addition to that, the 2021-2027 programming period benefits from the establishment of 
the Performance Framework defined in the in the CPR, enabling precise tracking of 
progress using defined performance indicators, with the obligation for Member States to 
set milestones and targets. Relevant stakeholders have expressed a range of perceptions 
regarding the Performance Framework; some recognise it as a substantial improvement to 
the monitoring and evaluation system, while others see the enhancements as more modest, 
reflecting a diverse response to the changes implemented. 

37 A list of the common indicators is provided in Annex II. 
38 However, it should be noted at this point that the existing indicators cannot be changed without a legal 
amendment to the fund. Consequently, changes or new introductions of indicators would have to be examined 
in more detail and cannot simply be implemented. 

30 

 
 
In its Special Report on the Integration of Third Country Nationals39, the European Court 
of  Auditors  (ECA)  highlighted  that  the  current  performance  framework40  is  an 
improvement as compared to the one defined in the Common Monitoring and Evaluation 
Framework for the period 2014-202041 As the ECA stated: “This new reporting framework 
underscores the shortcomings in the reliability of  2014-2020 project reporting”. This point 
is  also  confirmed  in  chapter  3  of  the  ECA  annual  report  for  202342  under  the  section 
dedicated  to  the  Home  Affair  Funds  and  titled  “The  performance  reporting  framework 
improved”:  “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  Home  Affairs  Funds-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) directly linked to the implementation of the fund. 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. 

However, there are a number of challenges affecting the quality of the monitoring and 
reporting of AMIF-funded projects, in part jeopardising the reliability of data reported 
through the SFC data reporting system.  

First,  the  interviews  with  Managing  Authorities  and  final  beneficiaries  revealed  a 
widespread perception of excessive administrative burden linked with data collection, 
monitoring and reporting. Duplication of provision of the same information at different 
stages and for different administrative purposes is also often recalled by the interviewed 
stakeholders, albeit in a rather unspecified manner. Overall, the evaluation concludes that 
it is too early to judge on whether the administrative burden associated to the monitoring 
and reporting system is proportionate with respect to the benefits in terms of transparency 
and policy development. 

Anecdotal evidence points to the fact that that national IT systems used for monitoring 
are often not fully integrated, leading to discrepancies in data reporting. This relates in 

Instrument 

39  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. 
40  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 
Visa 
for 
the 
Policy. http://data.europa.eu/eli/reg/2021/1060/oj 
41  Commission  Delegated  Regulation  (EU) 2017/207  of  3 October  2016 on  the  common  monitoring  and 
evaluation framework provided for in Regulation (EU) No 514/2014 of the European Parliament and of the 
Council  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. EUR-Lex - 02014R0514-20220412 - EN - EUR-Lex 
42 
2023 
https://www.eca.europa.eu/ECAPublications/AR-2023/AR-2023_EN.pdf 

Border  Management 

(2024),  Annual 

concerning 

Financial 

financial 

Support 

reports 

year, 

ECA 

122, 

and 

the 

for 

p. 

31 

 
 
 
particular to the fact that the interface between the national and EU monitoring systems is 
not properly in place.  

Similarly,  few  stakeholders  have  referred  that  the  scope  of  the  common  indicators  is 
often too broad and fail to capture the specificities of certain projects, implying that 
the effects of the operations in certain policy areas may be underestimated. This could be 
due  to  the  fact  that  several  projects  funded  cannot  be  reflected  in  their  full  scope  and 
effects,  as  they  do  not  clearly  fall  under  one  of  the  indicators  and  their  underlying 
definitions. The preparatory work of the evaluation fails to assess the extent to which this 
finding is (or could be) overcome by the provision of programme specific indicators. Other 
stakeholders have referred to possible gaps in data collection and reporting.  

No firm conclusions are drawn in the APRs on the capacity of the monitoring system 
to correctly reflect the status of implementation on the ground. This is essentially due 
to the fact that the early stage of implementation of the programmes has hindered fully-
fledged considerations in the APRs on data discrepancies, corrections, and cases of over- 
or under-reporting. 

As  regards  target-setting  methodologies  the  case  study  analysis  reveals  clear 
discrepancies  in  how  the  observed  nine  Member  States  have  defined,  calculated,  and 
presented their targets. While the limited number of observed cases does not permit to draw 
firm  conclusions,  this  variation  may  suggest  that  while  some  Member  States  have 
established robust frameworks for target-setting, others may require additional clarity and 
consistency  in  their  approaches.  In  addition  to  that,  the  Member  States  show  notable 
differences in terms of completeness, consistency and plausibility in their data reported 
regarding achievements of targets and milestones.  

Concerning  Union  Actions  under  the  Thematic  Facility,  they  utilise  a  structured  yet 
flexible framework, employing standardised templates and detailed reporting guidelines to 
ensure high data quality and timely, and accurate financial and narrative reporting.  

Effective involvement of the partners 

Article 8 of the Common Provision Regulation (CPR) requires the Managing Authorities 
to set-up a partnership involving the relevant stakeholders of programmes implemented in 
shared  management  in  all  the  phases  concerning  the  preparation,  implementation  and 
evaluation  of  those  programmes.  It  also  defines  specific  rules  for  the  composition  and 
functioning  of  the  partnership  throughout  the  programming  cycle.  In  addition,  the 
organisation  and  implementation  of  the  partnership  must  follow  the  European  code  of 
conduct on partnership established by Delegated Regulation (EU) No 240/201443.  

While the requirement of involving the partners was not new to the Managing Authorities 
of the Home Affairs Funds, the CPR and the European Code of Conduct have established 
a more structured framework and stricter rules for the implementation of the partnership 
principle, to which they have been confronted for the first time. Overall, the establishment 
of a comprehensive and balanced partnership has been challenging under the Home 
Affairs Funds.  

43 Commission Delegated Regulation (EU) No 240/2014 of 7 January 2014 on the European code of conduct 
on  partnership 
Investment  Funds. 
framework  of 
http://data.europa.eu/eli/reg_del/2014/240/oj  

the  European  Structural 

and 

the 

in 

32 

 
 
Despite  this  generalised  trend,  the  analysis  shows  that,  as  regards  AMIF  the  Member 
States  are  endeavouring  to  involve  relevant  partners  and  stakeholders  in  the 
programming and implementation of their programmes. The Member States have paid 
particular  attention  to  this  regarding  the  development  of  the  programmes  and  the 
involvement of the partners in the corresponding Monitoring Committee44. Contrary to the 
case of BMVI and ISF, the AMIF Regulation includes specific provisions concerning the 
involvement  of  the  partners,  (Article  4  of  the  AMIF  Regulation),  in  addition  to  the 
provisions  of  the  CPR.  This  specific  feature,  combined  with  the  scope  of  the  AMIF 
interventions, may have helped to have a smoother application of the partnership principle 
compared to the other two Home Affairs Funds. 

The  evaluation  findings  underpin  that  all  26  Member  States  involved  relevant 
stakeholders  within  the  process  of  defining  the  main  priorities  of  their  AMIF 
Programmes. All Member States involved partners in the preparation of their Programmes 
by consulting the stakeholders on their needs and problems.  

Detailed  analysis  concerning  the  actions  put  in  place  to  enable  partners’  participation, 
shows that the Member States have taken actions going beyond the legal requirements, 
to  ensure  the  partners  participation  throughout  all  stages  of  the  Fund’s  cycle.  Some 
examples include: 

5. 

6. 

7. 

8. 

Regular consultation meetings: eight Member States hold regular meetings going 
beyond those of the Monitoring Committee with key stakeholders, including Civil 
Society Organisations, local authorities and international organisations, to align the 
objectives of the Fund with the needs of relevant partners. 

Bilateral discussion: to address emerging challenges and needs, two Member States 
have organised targeted bilateral discussions during the preparation phase of their 
programmes.  

Public consultations and events: six Member States launched targeted consultation 
during the programming stage (e.g. sending of questionnaires on draft versions of 
the  programme,  organisation  of  webinars,  “Home  Affairs  Fund  Days”  and 
workshops on specific topics such as award of contracts and communication). 

Collaboration  with  experts:  two  Member  States  have  set-up  dedicated  expert 
groups to deal with specific topics, e.g. for the screening of submission in relation 
to Calls for Proposals.   

The analysis also shows that all Member States satisfy the requirements of Article 39 of 
the CPR (“Composition of the Monitoring Committee”) and of Article 49 (Responsibilities 
of the Managing Authorities”), notably as regards transparency rules and  publication of 
information on Calls for Proposals and implemented projects. The interviews conducted 
support the finding that relevant partners are involved across all stages of the Fund’s cycle. 

Concerning  the  effectiveness  of  the  Monitoring  Committee,  17  out  of  24  (71%)  of  the 
Managing  Authorities  stated  that  the  members  of  the  Monitoring  Committee  provide 

44 Article 38 of the CPR: each Member State shall set up a committee to monitor the implementation of the 
programme (‘monitoring committee’), after consulting the managing authority, within 3 months of the date 
of notification to the Member State concerned of the decision approving the programme. 

33 

 
 
recommendations, with 12 (50%) of the respondents perceiving the recommendations as 
helpful and 5 (21%) sometimes not fully constructive. 

Implementation of Horizontal Principles 

According  to  Article  9  of  the  CPR,  on  horizontal  principles,  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, 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  Funds  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.  

Overall, the analysis showed that all Member States are committed to complying with 
the  horizontal  principles.  In  addition,  it  emerged  that  the  horizontal  principles  of 
gender equality, respect of fundamental rights and non-discrimination are promoted 
more prominently than those related to sustainable development. This is however in 
line  with  the  scope  and  nature  of  the  interventions  supported  under  AMIF.  As  regards 
gender mainstreaming, and contrary to BMVI and ISF, all indicators included in Annex 
VIII of the AMIF Regulation must be reported by the Member States by gender.  

The  requirements  for  horizontal  principles  are  considered  and  reflected  in  the  Member 
States’  Programmes  and  the  Thematic  Facility  Work  Programmes.  Beyond  that,  the 
Toolkit on the use of EU funds for the integration of people with a migrant background: 
2021–2027 programming period provides clear guidelines for authorities and beneficiaries 
on how to comply with the requirements. 

The detailed analysis of the individual Member States regarding the question of whether 
suitable organisational and procedural arrangements are in place to ensure compliance with 
the horizontal principles shows that all Member States are committed to complying with 
the horizontal principles and promote these within their Programmes. The Member States 
further use various national mechanisms to ensure this compliance, such as:45 

• 

Informing  beneficiaries:  Four  Member  States  notify  beneficiaries  of  their 
obligations  to  comply  with  horizontal  principles  when  grant  agreements  are 
concluded. 

•  Training and guidelines: Two Member States organise training sessions to educate 
beneficiaries on aligning projects with the horizonal principles, while one Member 
State  provides  additional  guidelines  to  assist  beneficiaries  in  understanding 
compliance requirements. 

•  Reporting requirements: Eleven Member States request beneficiaries to report on 
compliance  or  violations  in  calls  for  proposals,  with  non-compliance  negatively 
impacting assessment outcomes. 

45 The national mechanisms are  particularly outlined in the Member States’ APRs and national mid-term 
evaluations, though to varying extents between the Member States. 

34 

 
 
•  Audits  and  consultations:  Six  Member  States  conduct  audits  and  consultations 

focused on beneficiaries' adherence to horizontal principles. 

•  On-site compliance checks:  Two Member States  perform on-site visits  to  verify 

compliance with horizontal principles. 

•  Stakeholder  involvement:  Three  Member  States  invite  key  stakeholders  to 

Monitoring Committees to promote equality and prevent discrimination. 

However,  the  national  mid-term  evaluations  indicate  that  the  effectiveness  of  these 
measures  varies  considerably  from  one  Member  State  to  another.  Moreover,  not  all 
Member States report on the exact arrangements in place and mechanisms applied. 

Effectiveness of Communication and Dissemination Activities 

Overall,  effective  communication  activities  are  in  place  and  reaching  the  target 
audience, in many cases by using an appropriate mix of communication channels and 
platforms.  The  Member  States  use  different  communication  channels  and  platforms  to 
reach  their  target  audience,  such  as  information  events,  social  media  and  dedicated 
websites.  The  importance  of  online  presence  is  becoming  increasingly  relevant  for  the 
Member  States  and  results  in  widened  presence  on  social  media  channels.  Minor 
weaknesses  are  observed,  especially  in  reaching  smaller  organisations  and  Civil 
Society Organisations. 

Based  on  the  APRs  and  the  mid-term  evaluation  reports  of  the  AMIF  Member  States 
programmes,  18 Member  States  have put in place a communication strategy. Some 
Member States, such as Greece and Germany, have also developed measures to assess the 
effectiveness of the deployed communication means. Interviewed Managing Authorities 
consider  the  advertising  and  reach  of  the  identified  target  groups  to  be  appropriate. 
Compared  to  the  previous  funding  period  2014-2020,  they  emphasise  significant 
improvements  in  visibility,  which  eventually  led  to  a  higher  numbers  of  funding 
applications. Interviewed beneficiaries generally consider awareness raising appropriate, 
but some report moderate success in reaching Civil Society Organisations, due to hurdles 
for small organisations, lack of experience, and bureaucratic language. 

4.1.2 Efficiency 

Cost-effectiveness 

A  quantitative  assessment  of  the  efficiency  of  AMIF  was  hindered  by  the  limited 
availability of data. Member States and Thematic Facility beneficiaries are not required to 
collect  and  report  on  costs  per  unit,  full-time  equivalents  (for  design,  implementation, 
monitoring,  control  and  audits),  technical  assistance  (disaggregated  per  year  and  from 
preparatory funding, evaluations and communication activities), or gold-plating evidence. 
They  are  also  not  required  to  report  on  administrative  burden.  In  addition,  data  on  the 
efficiency of anti-fraud measures could not be forwarded in a consolidated manner. This 
is  understandable  in  the  overall  context  of  striving  towards  a  reduced  administrative 
burden. Significant efforts to collect the relevant data were made, including through its 
methodological design (targeted survey, semi-structured interviews, country case studies), 
however, faced the challenge that this data in some instances simply does not exist or is 
too cumbersome to be retrieved on an ad hoc basis.  

35 

 
As  a  result  of  these  challenges,  overall,  the  collected  input  was  too  limited  and 
heterogenous to conduct a robust evaluative assessment. Where evidence did exist, it was 
primarily anecdotal and too high-level to use for conclusions. To mitigate these limitations 
in  the  context  of  extensive  Fund-specific  evaluations,  the  Commission  has  launched  a 
dedicated study on the “Assessment of the administrative costs and administrative burden 
in the management of the common provisions regulation funds 2021-2027” (including the 
Home Affairs Funds). This study is ongoing and planned to be finalised in the last quarter 
of 2025. It will provide meaningful insights on the subject.  

The findings below thus rely on exemplary and illustrative qualitative evidence from the 
analysis  of  desk  research.  Annual  Performance  Reports,  national  mid-term  evaluations, 
interviews, targeted surveys, and thematic and country case studies.   

Evidence  from  EU  benchmarking  studies  and  country  cases  interviews  support  the 
conclusion that AMIF supports a diverse range of cost-effective interventions across 
asylum, integration and return.  

Language learning, a cornerstone of migrant integration, is recognised for its high cost-
effectiveness46,  as  seen  in  the  “Swedish  for  Immigrants”  programme  and  France’s 
mandatory language courses, both improving employability and reducing social exclusion. 
Employment support and vocational training, such as Poland’s ‘Together to Independence’ 
and  Latvia’s  entrepreneurship  projects,  further  aid  economic  independence  and  reduce 
reliance  on  social  services.  AMIF  also  funds  health  care  services  and  civic  orientation 
courses,  for  example  specialised  trauma  care  in  Italy  and  social  orientation  in  Poland, 
which  mitigate  long-term  costs  by  fostering  early  integration.  Additionally,  AMIF’s 
voluntary return focus offers a more cost-effective and humane alternative to forced return, 
promoting  economic  self-sufficiency  and  social  stability  while  significantly  reducing 
return-related expenditures. 

At  the  mid-term  stage,  no  firm  conclusions  can  be  drawn  about  the  Fund's  cost-
effectiveness. Although diverse interventions funded by AMIF are deemed cost-effective, 
only 11% of the budget is spent (however more compared to BMVI and ISF), and progress 
varies across objectives, with SO1 and SO2 leading (see section 3). The assessment of the 
cost-effectiveness  of  the  interventions  funded  by  AMIF  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  funding 
recipients. Data on financial implementation is not connected to the performance indicators 
the Managing Authorities need to report on. As a result, the cost benefit analysis of the 
financial investment is rather limited.  

While  the  AMIF  supports  a  wide  range  of  interventions  recognised  for  their  cost-
effectiveness, the evaluation concludes that the Fund's potential to further enhance it is 
limited by the absence of unit cost calculations, which could provide a more systematic 
approach to maximising value for money. The analysis of data from 10 selected Member 
States  (Austria,  France,  Germany,  Greece,  Italy,  Lithuania,  Poland,  Romania,  The 
Netherlands,  and  Sweden)  shows  that  relevant  benchmarks  for  key  categories  of  costs 

46 For more information, please refer to Bertelsmann Stiftung (2008), Benchmarking Integration in the EU: 
Analysing the debate on integration indicators and moving it forward, as well as NIEM (2019), The European 
benchmark for refugee integration: a comparative analysis of the national integration evaluation mechanism 
in 14 EU countries. 

36 

 
 
under  the  scope  of  AMIF  are  systematically  established  only  in  a  few  Member  States. 
Indeed, the review of 10 target-setting methodologies annexed by these Member States to 
their Member State Programmes shows that discussions on unit costs are either entirely 
absent or only minimally addressed. The link between establishing targets and unit costs 
lies in the fact that unit costs provide a basis for setting realistic targets. By understanding 
the cost per participant or measure (specific and predetermined amount of funding which 
is assigned for completing one measurable action or providing one instance of a service), 
the  Member  States  could  more  accurately  forecast  the  financial  resources  needed  to 
achieve specific objectives.  

Based on the target-setting methodology analysis carried out, there is no adequate data 
available  to  date  to  provide  reliable  evidence  that  the  costs  per  unit  of  ongoing 
operations are in line with, higher than, or below existing benchmarks47. Overall, the 
evaluation concludes that there is no uniform pattern across the Member States. Rather, 
the alignment of costs with benchmarks seems to depend on the specific indicators and 
types of measures. When looking at output indicators, their calculated unit costs are often 
close to benchmarks, while result indicators have more variation, especially in countries 
with higher reported costs. 

According to the targeted survey responses, Managing Authorities employ a variety 
of tools to select the most cost-effective projects. Compared to the programming period 
2014-2020, during which the selection was largely based on qualitative justifications or 
prospects from beneficiaries, during the 2021-2027 programming period this increasingly 
complemented by a comparison with market prices of similar products/services or relevant 
lessons learned from the previous programming period. 

Value for money is considered  within the selection criteria for projects under (in-) 
direct  management  by  the  European  Commission,  evidenced  by  the  list  of  award 
criteria of the nine calls for proposals published since 2021. Cost-effectiveness and value 
for money feature as sub-criteria under “Quality”, which is given 50 points in total, while 
“Relevance” and its sub-criteria is given 30 points and “Impact” and its sub-criteria is given 
20 points. Cost-effectiveness is evaluated on a case-by-case basis with the type of projects 
in mind since there are differences between for example Union Actions (mostly innovative 
so  challenging  to  benchmark  in  terms  of  efficiency)  and  EMAS  (where  the  focus  is 
especially to address quickly the emergency situation).  

The  cost-effectiveness  of  operations  under  the  Fund  can  also  be  assessed  through  the 
degree of support Emergency Assistance (EMAS) offers in addressing urgent challenges. 
According to survey responses, six out of seven EMAS project participants reported 
that EMAS met organisational and individual needs to a large or very large extent. 
The  thematic  case  studies  confirm  that  EMAS  is  well-suited  to  tackle  emergency 
needs, offering flexibility for budgetary and project plan adjustments.  

Efficiency of management and control system 

The evaluation of the costs to comply with the management and control system shows that 
the current practices are relatively efficient. The balance between application efforts and 
financial resources received is generally proportional, with beneficiaries finding the 
application  processes  for  the  resources  programmed  by  the  Commission  through 

47 Benchmarks were established based on the “Study to develop EU level Simplified Cost Options (SCOs) 
and other EU level results-based tools in the programming period 2021-2027”, published in July 2023.   

37 

 
 
EMAS, Specific Actions, and Union Actions relatively efficient, as evidenced by the 
thematic case studies conducted during the preparatory work of the evaluation.  

Changes  in  reporting  requirements  between  the  AMIF  2014–2020  and  2021–2027 
programming  periods  appear  to  have  increased  efficiency  by  introducing  more 
structured, comprehensive, and technologically integrated processes. Improvements with 
respect to the previous period include detailed reporting on specific Union priorities, such 
as milestones, targets, and compliance with fundamental rights, with  earlier submission 
deadlines.  In  shared  management,  the  addition  of  mandatory  electronic  data  exchange 
systems  further  streamlines  the  process  by  ensuring  secure,  real-time  data  sharing  and 
reducing  administrative  burdens  through  automation.  These  enhancements  suggest  a 
shift toward a more transparent, accountable, and performance-oriented reporting 
system, addressing inefficiencies identified in the earlier period.  

While changes have been welcomed by interviewed beneficiaries of shared and in-/direct 
management projects, the latter have also pointed out that monitoring and reporting 
requirements  can  be  particularly  burdensome.  Despite  these  issues,  beneficiaries 
consider  the  effort  required  to  apply  for  funding  justified  by  the  volume  of  financing 
received, making the process overall cost-effective.  

Based  on  the  case  studies  carried  out,  there  is  limited  evidence  to  judge  on  the 
proportionality of the costs for the Managing Authorities to comply with the CPR, 
although  at  least  two  Managing  Authorities  highlighted  that  there  were  high  transition 
costs  in  particular  to  adapt  the  procedures  to  the  Common  Provision  Regulation48 
requirements. This could not be quantified. Full Time Equivalent (FTE) data has not been 
systematically  collected  during  2021-2027  and  targeted  survey  answers  from  Member 
States did not allow for satisfactory quantification: not all participated, and the data are not 
available in a disaggregated format by year and months. However, it is expected that the 
administrative burden caused by increased monitoring and reporting will reduce in time, 
as the administrations and beneficiaries will get accustomed to the new requirements.  

Similarly, there is limited evidence to evaluate whether the implementation of anti-
fraud measures and procedures enhances overall efficiency. Targeted survey feedback 
from  a  low  number  of  Managing  Authorities  on  the  average  time  (man-days)  spent 
preparing for audits and on-site controls, as part of the audit strategy, was inconclusive due 
to limited or unavailable data. 

The use of some simplification measures contributed to increased efficiency, however, 
considerable challenges remain. The majority of stakeholders, including both beneficiaries 
and Managing Authorities, consulted through targeted surveys, semi-structured interviews, 
and case studies, perceive the administrative burden during project implementation as 
substantial, particularly regarding regulatory and monitoring requirements. Procurement 
procedures also pose difficulties, though to a slightly lesser degree. Communication with 
other stakeholders is seen as the least challenging, with most respondents indicating low 
or very low difficulty: 

48 Based on the country case studies. 

38 

 
 
Figure 14: Extract from targeted survey on perceived challenges  

To what extent were the following aspects perceived as a challenge by your institution / 
organisation  /  company  in  the  implementation  of  the  project(s)  funded  by  the  MS 
Programme AMIF? (N=138) 

Source: Targeted survey with Beneficiaries (August – September 2024) 

The  perception  by  the  Fund  beneficiaries  about  the  improvements  for  the  2021-2027 
programming  period  compared  to  the  previous  programming  period  mirrors  the  results 
above:  

Figure 15: Extract from targeted survey on improvements in 2021-2027 

To what extent the following aspects have been improved in the programming period 2021-
2027, compared with the previous period? (N=138) 

Source: Targeted survey with Beneficiaries (August – September 2024 

Findings  from  the  literature  and  document  review  show  that  the  efficiency  of  the 
management  and  control  system  is  also  influenced  by  the  level  of  coordination 
between actors involved in the implementation of the Fund. In this vein, Luxembourg 
and Latvia highlighted the importance of improving coordination to reduce administrative 
burden and ensure coherence in implementing the  Fund. The integration of processes, 
undertaken  by several Member States particularly through digitalisation has been 
identified as a critical factor in improving the efficiency of the management system. 

Simplified cost options (SCOs) and flat rate technical assistance appear to have had 
a notable positive impact, with a combined 17 respondents (approximately 12% each) 
indicating  that  these  measures  simplified  processes  to  a  "high"  or  "very  high"  extent. 

39 

 
 
 
Similarly,  multiannual  programming  was  recognised  by  a  significant  proportion  of 
respondents  to  the  targeted  survey  (14  in  total)  as  reducing  administrative  burden  to  a 
"high" or "very high" degree. However, “financing not linked to costs” and “No project-
level reporting” were less frequently identified as effective measures.  

Figure 16: Extract from targeted survey on administrative burden 

To  what  extent  have  the  following  changes  in  AMIF  resulted  in  simplification  and/or 
reduction of  administrative burden for  the actors involved in  the implementation of  the 
fund? (N=26) 

Source: Targeted survey with Beneficiaries (August – September 2024) 

Compared to the 2014-2020 programming period, the 2021-2027 period mandates more 
use of SCOs, including thresholds for mandatory application by the Managing Authorities 
and  predefined  methods  to  simplify  calculations.  The  interview  data  reveals  that 
simplified  cost  options  have  been  implemented  to  a  varying  degree,  but  their 
effectiveness  and  uptake  are  mixed.  Some  beneficiaries  appreciate  their  potential  to 
reduce the administrative burden, particularly when using flat rates and lump sums, which 
streamline the reporting process. However, others highlight significant challenges, such as 
funding  streams  and  cumbersome  preparation 
inconsistent  application  across 
requirements.  The new  IT systems,  such as Germany’s digital application platform and 
Poland’s ROFED system, have also facilitated simplification, particularly in monitoring 
and reporting. Despite these improvements, beneficiaries frequently report that the overall 
administrative workload for AMIF projects remains high compared to national funding. 
This is compounded by complex rules (including for eligibility), multiple approval layers, 
and frequent reporting requirements, which limit the efficiency gains from simplified cost 
options. Overall, the analysis concludes that while simplified cost options is a promising 
avenue to increase efficiency in the implementation of AMIF (also confirmed by the 
national  mid-term  evaluations),  more  consistent  implementation  and  clearer 
guidance are necessary to fully realise their efficiency potential. In addition, further 
simplifications,  such  as  cost  catalogues  or  expanded  flat  rates,  could  enhance 
efficiency. 

There is limited evidence of additional constraints beyond EU requirements introduced by 
national legislation and rules (gold plating) in the six country case studies – except for one 
Member State. However, interviewed beneficiaries find the administrative burden under 
direct or indirect management lighter compared to shared management.  

In  the  same  way  as  the  other  Home  Affairs  Funds,  AMIF  applies  a  flat  rate  of  6%  for 
Technical Assistance (TA), which can be used for communication, administrative support, 

40 

 
 
 
monitoring and control, evaluation, capacity building. An analysis of financial resources 
allocated to TA in the Member States Programmes shows that TA is broadly being used 
to  strengthen  the  management  and  control  system  (supported  by  the  mid-term 
evaluations in 7 Member States). Due to a lack of quantitative data covering all EU MS, it 
has  not  been  possible  to  assess  comprehensively  whether  the  6%  flat  rate  is  sufficient, 
although the consulted stakeholders have highlighted that the available technical assistance 
is insufficient to cover high personnel costs.  

Based on the considerations above, overall, the management and control system show 
moderate  efficiency,  with  simplified  cost  options  and  flat  rate  technical  assistance 
helping to reduce administrative burdens compared to the 2014-2020 programming 
period.  While  some  beneficiaries  benefit  from  streamlined  reporting,  others  face 
inconsistent  application,  unclear  methodologies,  and  high  documentation  demands. 
Technical Assistance supports system improvements, though evidence on the impact of 
anti-fraud measures and gold-plating is limited. Despite progress, administrative burdens 
and uneven simplification measures indicate room for improvement. 

As regards the scope for further simplification, in addition to expanded simplified cost 
options,  opportunities  are  also  seen  in  relation  to  the  introduction  of  electronic 
exchange  data  systems  for  the  communication  between  project  beneficiaries  and  the 
Managing Authorities (Article 69(8) CPR), supporting also the systematic transmission of 
data from  Member States to  the Commission. The analysis of interview data,  mid-term 
evaluations,  and  targeted  survey  results  highlights  multiple  challenges  associated  with 
AMIF’s electronic data exchange systems across the Member States. Key issues relate to 
data entry, indicator tracking, and the extraction of relevant data for reporting. Duplication 
of  data  entry  presents  an  additional  challenge,  as  highlighted  in  national  mid-term 
evaluations and corroborated by interview data from Germany as well as France. In some 
cases, AMIF beneficiaries are required to input the same information into both national 
systems and internal documentation, thereby increasing the administrative workload. This 
finding  aligns  with  data  from  the  targeted  survey,  where  approximately  one-third  of 
respondents indicated that the contribution of electronic systems to reducing administrative 
burdens was limited.  

4.1.3 Coherence 

Internal Coherence  

“Internal  coherence”  looks  at  the  degree  to  which  AMIF  is  coherent  (in  terms  of 
complementarities, synergies and overlaps) with other initiatives supported under its policy 
domain, in particular as regards the interaction between the Member States’ programmes 
and the Thematic Facility, or otherwise across the different management modes through 
which the support is provided.   

Overall,  the  evaluation  concludes  that  the  programming  and  implementation  of 
operations under the AMIF policy domain are coordinated to a good extent, although 
this  coordination  is  still  inadequately  reported  by  the  Member  States,  making  it 
difficult to draw comprehensive conclusions.   

The Member State Programmes are aligned with Union Actions’ priorities, ensuring 
complementarity. Union Actions and EMAS address additional needs in comparison 
to the Member State Programmes, thereby creating synergies rather than overlaps. 

41 

 
Overall,  stakeholders  agree  that  AMIF  instruments  are  complementary  and  effectively 
coordinated, fostering synergies. 

According to the analysis, the coherence of the Member States  Programmes and the 
AMIF Thematic Facility, was not dealt with in a comprehensive way in the APRs and 
mid-term  evaluations  of  the  Member  States  programmes.  In  fact,  only  eight  Member 
States (DE, EL, ES, IT, LT, LU, MT, PL) report on the complementarity of the Thematic 
Facility initiatives and Member States  Programmes in their APRs. These eight Member 
States confirm the complementarity. Beyond that, only 12 Member States (BE, CY, DE, 
EE, ES, FI, IT, LT, LV, PL, PT, SI) address the complementarity between the Thematic 
Facility and Member States Programmes in their mid-term evaluations.  

For  instance,  the  mid-term  evaluation  of  the  programmes  of  Cyprus  emphasises  that 
funding  from  the  Thematic  Facility  has  helped  to  address  additional  needs  towards 
changing priorities at national and EU level and evolving challenges arising in the policy 
area. This premise is supported by the findings of the interviews conducted, which showed 
overall that the  interventions  funded by the  AMIF  Thematic  Facility in  their respective 
Member States address important gaps, such as emerging needs and unforeseen challenges 
(i.e. a rise in the number of unaccompanied minors, the Russian war of aggression against 
Ukraine) not covered by the funded measures of the Member State Programmes. 

Regarding the views of stakeholders, 67% of the Managing Authorities surveyed agree 
or  strongly  agree  that  the  instruments  of  the  AMIF  (i.e.  the  Member  States 
Programmes  and  the  Thematic  Facility)  are  complementary.  Likewise,  the 
respondents agree on the fact that the interventions under the Thematic Facility and the 
Member  States  programmes  are  effectively  coordinated,  which  leads  to  the  creation  of 
synergies. The remaining 33% either had no knowledge of it or preferred not to answer, 
i.e.  none  of  the  respondents  disagreed  about  the  complementarity  between  the  Member 
States programmes and the Thematic Facility. 

As concerns the coherence between the Fund and current policy agendas at EU and 
national  levels,  the  findings  of  the  desk  research  show  that  coordination  and 
development of synergies are highly necessary. This need is addressed by establishing 
comprehensive  strategic  policy  frameworks  and  strengthening  coordination 
mechanisms across different levels.  At the EU level, efforts are being made to coordinate 
the  AMIF  interventions  with  action  plans  and  strategies,  such  as  the  Action  Plan  on 
Integration and Inclusion 2021-2027 and the EU Strategy on Combatting Trafficking in 
Human  Beings  2021-2025.  This  coordination  aims  to  enhance  the  coherence  and 
effectiveness of AMIF-funded projects in contributing to overarching EU objectives and 
addressing key issues in a harmonised manner. 

As concerns the situation at the national level, 19 Member States stated in their mid-term 
evaluations  that  the  measures  under  the  AMIF  are  coherent  with  the  policy  agendas  at 
national level49. While some countries go into detail, many simply note the coherence.  

Concerning the cooperation within and between relevant bodies involved in various 
capacities  in  the  management  of  the  AMIF,  or  in  relation  with  the  Fund,  findings 

49 As this judgment criteria is not mandated by the AMIF regulation, the omission of similar statements in 
the other MS mid-term evaluations should simply be understood as the information was not provided. 

42 

 
 
show that cooperation takes place in most Member States. Information on cooperation 
is not available for only two Member States (BG, EE). 

Both forms of cooperation (within and between authorities) involve coordination efforts 
between the Member States’ authorities and other stakeholders to effectively plan, fund 
and implement actions. The findings from the analysis of the interviews, programmes and 
reports show that  cooperation efforts are pursued both within the AMIF  Managing 
Authorities,  to  align  the  various  instruments  and  funded  measures,  and  between  the 
AMIF Managing Authorities and other authorities and institutions to align with other 
funding  and  to  coordinate  the  necessary  measures.  In  particular,  the  Thematic  Facility 
Work  Programmes  foster  inter-agency  cooperation,  for  example  through  transnational 
cooperation and the involvement of local communities and Civil Society Organisations for 
more effective integration of persons in need.   

Looking at the Member States, it emerges that cooperation is generally considered to be 
very important.  24 Member States are reporting  on established and desired cooperation 
with other agencies and organisations. Most Member States report on cooperation efforts 
at national level between the authorities, such as relevant ministries or with responsible 
municipalities. In addition, 10 Member States report cooperation efforts with relevant EU 
bodies,  offices  and  authorities.  Cooperation  with  other  Member  States  is  mentioned 
relatively  little,  by  only  five  Member  States.  While  six  Member  States  report  on 
cooperation efforts with international organisations such as the IOM or UNHCR. However, 
it must be mentioned that the Member States rarely go into detail about how exactly this 
cooperation  takes  place,  if  not  by  referring  in  general  terms  to  the  composition  of  the 
Monitoring Committee. 

In the context of mentioning the cooperation efforts already undertaken, Member States 
emphasise that they want to intensify their cooperation with the authorities in the country 
of origin and with non-state actors and seek further cooperation with other Member States. 
The further pursuit of cooperation with other national authorities, for example to create 
synergies, as well as internal cooperation within the Monitoring Committee and external 
cooperation with beneficiaries is also emphasized. 

In conclusion, the coherence between the AMIF and current policy agendas at both 
EU and national levels is actively pursued through strategic policy frameworks and 
coordination mechanisms. Efforts  at  the EU level  aim to  enhance the effectiveness  of 
AMIF-funded projects.  Most  Member States report alignment between AMIF measures 
and  their  policy  agendas.  Cooperation  within  and  between  relevant  bodies  is  recurrent, 
though detailed information on how this cooperation is carried out is often lacking. Overall, 
while significant efforts are being made, more detailed reporting on cooperation practices 
and further action to enhance these efforts are needed. 

External Coherence  

“External coherence” looks at the degree to which there are complementarities, synergies 
and overlaps with respect to other policy instruments, EU funding instruments (including 
other Home Affair Funds) and programmes.  

Overall,  the  findings  show  that  coherence  between  the  support  under  AMIF  and 
other measures, including the creation of synergies as well as complementarities are 
clearly pursued by the Member States. The operations supported under the AMIF are 
coordinated with other Home Affairs Funds, EU funding instruments and programmes at 

43 

 
both  EU  and  national  levels  through  various  mechanisms.  Increasing  synergies  and 
complementarities between different national and EU funding instruments require a 
high level of coordination between different authorities and agreement with several 
stakeholders.  

Coherence with other Home Affairs Funds (ISF and BMVI)  

While the Home Affairs Funds cover different themes and policy areas, they do contribute 
to complementary EU level objectives in the field of migration, border management and 
security,  provide  funding  to  similar  types  of  beneficiaries  and  funding  similar  types  of 
activities. These interlinkages require that mechanisms are in place to avoid the funding of 
overlapping  or  contradictory  activities,  and  to  ensure  that  synergies  are  created  where 
relevant.  

Robust  mechanisms  exist  at  national  and  EU  level  to  ensure  actions  implemented 
through  AMIF,  BMVI  and  ISF  are  complementary  and  coherent,  although  this  is 
pursued through different mechanisms and tools across the Member States.  

Firstly, the legal framework allows for complementarities and synergies between AMIF 
and the other Home Affairs Funds in two ways: 

As laid out in AMIF Regulation (EU) 2021/1147, recital 32: “In keeping with the principle 
of efficiency, synergies and consistency should be sought with other Union Funds 
and overlap between actions should be avoided”. 

Transfer of funding: As per Article 26 of the CPR,  Member States may request the transfer 
of up to 5 % of the initial national allocation of each EU funding instrument  to any 
other instrument under direct or indirect management.  The table below provides 
examples  of  transfers  that  have  been  made  under  shared  management  at  the 
beginning of the implementation period. 

Table 1: Transfers of initial national allocations to other Home Affairs Funds 

No transfer from BMVI or ISF to AMIF have taken place.  The possibility for transfers 
between the AMIF and the other CPR funds is described further in the following section 
on coherence with other EU funding instruments. 

At national level, the key mechanism in place to ensure that overlaps are avoided are the 
Managing  Authorities  (in  doing  their  selection  of  funded  actions)  and  the  Monitoring 
Committees. The latter ensures the monitoring of the implementation of the Programme, 
and  supports  the  Managing  Authorities  in  their  implementation  efforts.  In  addition, 
Member States are obliged to consult and coordinate with DG HOME in relation to projects 

44 

 
 
 
under the Member States Programmes planned to be implemented with, or in relation to 
third countries50. 

At EU level, overlaps are avoided and synergies between the three Home Affairs Funds 
are  ensured.The  Commission  maintains  an  overview  of  the  Thematic  Facility  Work 
Programmes and is therefore able to ensure the priorities for the Thematic Facility for each 
of the Funds do not overlap at programming stage. In addition, as confirmed through the 
interviews  with  DG  HOME,  the  Commission  has  other  tools  as  its  disposal  to  ensure 
coherence between the funding instruments:  

Participation of DG HOME in Monitoring Committee meetings. 

Dialogue between DG HOME and Managing Authorities, for example when DG HOME 
is contacted with a question for clarification, or when programme amendments are 
submitted.  

The possibility to carry out on site visits: DG HOME has a prerogative to carry out on site 
visits  in  the  Member  States  to  better  understand  how  the  funding  is  being 
implemented.  

Review  of  information  provided  to  the  Commission  as  part  of  the  responsibilities  of 
Member  States  under  Chapter  III  of  the  CPR  on  Visibility,  transparency  and 
communication. 

Coherence with other EU funding instruments 

Those conclusions are essentially based on qualitative evidence. According to the targeted 
survey with Managing Authorities, three-quarters (75%) of the respondents consider the 
AMIF  to  be  complementary  with  other  EU  funding  instruments  (in  particular  ESF+, 
ERDF, NDICI). While 21% preferred not to answer, only 4% disagreed with the AMIF 
being complementary with other EU funding instruments. The respondents further agree 
that the Funds under shared management are well coordinated and work together 
effectively  as  regards  AMIF,  ESF+  and  the  ERDF.  This  is  in  particular  because  the 
AMIF shares financial rules and strategic objectives with these Cohesion Policy Funds. 
The  consultations  of  relevant  stakeholders  confirms  that  the  Member  States  are  clearly 
keen to exploit and assess complementarities with other EU funding instruments. All 26 
Member  States  describe  existing  complementarities  and  synergies  with  other  Funds  or 
indicate plans to develop them in their Member State Programmes. 

In  addition  to  the  Home  Affairs  Funds,  it  is  particularly  important  to  highlight  the 
following Funds due to their complementarities and synergies with the AMIF:  

•  ESF+: The ESF+ is the EU's main instrument for investing in people, focusing on 
employment, social, education, and skills policies, as well as structural reforms. It 
emphasises long-term integration measures, particularly in labor market integration 
and social inclusion of migrants. The ESF+ complements the AMIF in promoting 
the integration  of TCNs and encourages  transnational  cooperation.  Compared to 
the AMIF, the ESF+ is aimed at follow-up measures that are more geared towards 
long-term  integration.  Both  funds  follow  the  same  financial  rules  and  strategic 
objectives. The Commission’s services have developed a “Toolkit on the use of EU 

50 Article 16(11) AMIF Regulation. 

45 

 
 
funds for the integration of people with a migrant background51” aiming to assist 
all  relevant  stakeholders  at  European,  national,  regional  and  local  levels  in 
designing and implementing integration policies targeted at people with a migrant 
background, through the coordinated use of relevant EU funds in the 2021–2027 
programming period (AMIF, ESF+, ERDF, EAFRD, as well as TSI). 

•  ERDF: The ERDF aims to strengthen economic, social, and territorial cohesion in 
the  EU  by  funding  long-term  integration  initiatives.  It  supports  infrastructure, 
access to quality and inclusive services in education, employment, housing, social 
affairs,  health,  childcare,  and  culture,  and  cooperation  across  borders  (under  its 
Interreg  strand).  While  the  ERDF  and  AMIF  both  promote  the  integration  and 
social inclusion of TCNs, the ERDF further complements AMIF by facilitating the 
transition  to  community-based care  and investing in  SMEs to  create jobs, from 
which migrants as well as other vulnerable groups can benefit. Both funds follow 
the  same  financial  rules  and  strategic  objectives,  ensuring  a  cohesive  approach 
across the EU. Member States are also required to describe the complementarity 
between  cohesion  policy  funds  and  other  CPR  funds,  including  AMIF,  in  the 
Partnership Agreements and in the respective cohesion policy programmes. 

•  NDICI:  The  NDICI  is  designed  to  assist  third  countries  in  the  Neighbourhood, 
Sub-Saharan  Africa,  Asia  and  the  Pacific,  and  the  Americas  and  the  Caribbean, 
particularly  those  facing  significant  development  challenges.  It  supports  these 
countries in overcoming long-term developmental issues and aligns with the EU's 
international commitments, including the 2030 Agenda and the Paris Agreement. 
The  NDICI  regulation  provides  that  indicatively  10%  of  the  overall  financial 
envelope for the Instrument should be dedicated to actions supporting management 
and governance of migration and forced displacement, and to actions addressing 
the  root  causes  of  irregular  migration  and  forced  displacement.52  The  NDICI 
merges  several  former  EU  external  financing  instruments  and  coordinates 
initiatives  with  Member  States  and  international  organisations  before  funding 
decisions,  rather  than  through  calls  for  proposals.  In  contrast,  the  AMIF  targets 
migration  management  within  the  EU.  It  funds  initiatives  to  ensure  a  uniform 
application  of  EU  asylum  rules,  support  legal  migration,  and  facilitate  the 
integration of TCNs. Thus, the NDICI addresses broader developmental challenges 
in  third  countries,  while  the  AMIF  is  dedicated  to  managing  migration  and 
integration  within  the  EU.  Nevertheless,  both  instruments  aim  to  enhance 
cooperation with third countries on migration management. 

•  RRF53: The RRF is a central element of the EU's NextGenerationEU plan for post-
crisis  recovery  and  resilience,  supporting  the  EU's  strategy,  REPowerEU,  to 
address  socio-economic  impacts  and  energy  market  disruptions  due  to  Russia's 
invasion  of  Ukraine.  Synergies  with  the  AMIF  exist  to  the  extent  that  the  RRF 

51    European Commission: Directorate-General for Regional and Urban Policy, Toolkit on the use of EU 
funds  for  the  integration  of  people  with  a  migrant  background  –  2021–2027  programming  period, 
Publications Office, 2021, https://data.europa.eu/doi/10.2776/319860 
52 Recital 51 of Regulation (EU) 2021/947 of the European Parliament and of the Council of 9 June 2021 
establishing the Neighbourhood, Development and International Cooperation Instrument – Global Europe, 
amending  and  repealing  Decision  No  466/2014/EU  of  the  European  Parliament  and  of  the  Council  and 
repealing Regulation (EU) 2017/1601 of the European Parliament and of the Council and Council Regulation 
(EC, Euratom) No 480/2009. http://data.europa.eu/eli/reg/2021/947/oj  
53 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing 
the Recovery and Resilience Facility. http://data.europa.eu/eli/reg/2021/241/oj 

46 

 
 
provides  broader  socio-economic  support  and  infrastructure  development  to 
Member States, which consequently improves the overall resilience and integration 
capacity associated with the AMIF within the EU. However, it is important to note 
here that the RRF does not cover TCNs. Thus, projects that are eligible for AMIF 
funding due to their target group cannot apply for RRF funding, as the latter covers 
different target groups, and vice versa. 

Coherence with EU external policy  

All  the  AMIF  specific  objectives  may  support  actions  in  the  external  dimension  that 
represent  a  continuum  from  the  internal  dimension  into  the  external  dimension  of 
migration. For example, by supporting legal migration pathways. Article 5(3) of the AMIF 
Regulation  lays  out  that  the  Commission  and  the  Member  States,  together  with  the 
European  External  Action  Service  must  ensure  that  actions  in  and  in  relation  to  third 
countries (a) are carried  out  in  synergy and in  coherence with  other actions outside the 
Union supported through other Union instruments; (b) 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; (c) focus on 
measures that are not development-oriented; and (d) serve the interests of internal Union 
policies and are consistent with activities within the EU.  

Under shared management, Member States need to consult the Commission prior to the 
approval of a project being supported by the AMIF in or in relation to a third country54. 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. Regarding the Thematic Facility, 
coherence  is  ensured  through  the  interservice  consultations  with  the  relevant  external 
action services. Under direct and indirect management, only third countries listed in the 
Commission’s Work Programme are eligible for Union financing ensuring that the actions 
in which they participate contribute to the achievement of the objectives of the Fund55; and 
funding from the Thematic Facility can only be used to support actions in or in relation to 
third countries, within the objectives of the Fund56. At the reporting and evaluation stages 
57,  assessing  complementarity  between  the  actions  supported  under  the  AMIF  and  the 
support provided by other Union funds to actions taken in or in relation to third countries 
is required. 

In this regard, AMIF-funded calls for proposals have been launched under the Migration 
Partnership  Facility  (MPF)58,  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 

and 

returns 

funded 

admission 

54 Article 16 (11) of the  AMIF Regulation. A formal consultation process  does not concern resettlement, 
humanitarian 
concerning 
readmission/reintegration  of  third  country  nationals  in  line  with  Annex  III  (4)  of  the  AMIF  regulation 
provided  that  they  are  not  development-oriented,  and  they  do  not  concern  third  countries  in  politically 
sensitive situations.  
55 Articles 24(1)(a)(ii) and 24(3) of the AMIF Regulation. 
56 Article 11(2) of the AMIF Regulation. 
57 Article 35(2)(c) of the AMIF Regulation and Article 34(4) of the AMIF Regulation, respectively.   
58 Home - Migration Partnership Facility 

through  AMIF,  nor 

operations 

47 

 
 
avoid duplications and overlapping. The grant evaluation Committee is composed of DG 
HOME, DG INTPA, 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. 

In the context of the NDICI, consistency, coherence, synergies and complementarity with 
other  external  financing  instruments,  and  with  other  relevant  Union  policies  and 
programmes, are particularly sought. The Union and the Member States ensure inclusive 
consultations  with  each  other  at  the  programming,  implementation,  monitoring,  and 
evaluation stages as well.59 Also, specific rules are laid down on the conditions of receiving 
contributions from both NDICI and from another Union programme60. 

Nevertheless, 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  need  to  further  strengthen  the  link  between  external  and  internal  priorities  of  the 
Union’s  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 assistance61 eligibility. 

Mechanisms to ensure external coherence 

Based  on  the  analysis  of  the  programmes,  national  mid-term  evaluations  and  Annual 
Performance Reports, 22 Member States have put in place mechanisms to coordinate 
AMIF with other CPR Funds. Those mechanisms are: 

•  Coordination meetings with other Funds: observed in 16 Member States, 

•  Unique Monitoring Committee for all CPR Funds: observed in 2 Member States, 

•  Cross-participation in other Funds committees: observed in 11 Member States,  

59 Article 12, 35 41, 42 of the NDICI Regulation. 
60 Article 5 of the NDICI Regulation.  
61 Official development assistance eligibility criteria is set by the Organisation for Economic Cooperation 
and Development. 

48 

 
 
•  Appointment of a coordination/working group: observed in 5 Member States. 

Good  coordination  between  AMIF,  ESF+  and  ERDF  is  happening  in  the  domain  of 
integration and social inclusion of third country nationals, as called for in the Action 
Plan  on  Integration  and  Inclusion  2021-202762.  On  this,  the  evaluation  concludes  that 
overall, the Member States have put in place the necessary monitoring arrangements 
to ensure that the activities to be financed are clearly differentiated from one another 
and  do  not  overlap.  For  this  purpose,  the  Member  States  use,  for  example,  a  regular 
exchange  of  information  or  integrate  members  of  the  different  Funds  on  the  same 
Monitoring Committee to establish complementarities and synergies. 

On the interaction between AMIF and ESF+ in the field of integration, the recent special 
report by the European Court of Auditors (ECA) 63 points out that, during the 2014-2020 
programming  period,  limited  coordination  between  EU  Funds  was  found,  especially 
regarding integration of third-country nationals. This limited coordination between AMIF 
and ESF hindered the establishment of comprehensive integration pathways and there were 
no notable examples of  seamless  transitions  from  early  integration measures  funded by 
AMIF  to  medium-  or  long-term  support  financed  by  the  ESF.  In  some  cases,  national 
funding filled these gaps, but this lack of synergy reduced the overall effectiveness of EU 
funding mechanisms.  

Nonetheless, better demarcation between AMIF and ESF/ESF+ during the 2021–2027 
programming period, has enhanced their complementarity compared to the previous 
programming  period. AMIF now focuses  on early-stage integration activities, such as 
language training, civic orientation, and pre-departure information campaigns, while ESF+ 
and ERDF addresses long-term socio-economic inclusion, including access to education, 
housing,  and  employment.  The  Commission  also  issued  targeted  guidance  to  Member 
States,  helping  them  to  plan  and  define  areas  of  intervention  for  each  Fund  to  avoid 
overlaps  and  enhance  continuity.  Furthermore,  mutual  consultations  between  the 
Directorates-General  managing  AMIF  and  ESF/ESF+  during  the  programming  phase 
strengthened this alignment.  

In April 2022 the Commission issued guidance to the Member States on a comprehensive 
list of indicative measures which could be supported by the Funds, to maximise the joint 
impact  of  the  Funds  in  supporting  the  Member  States  dealing  with  the  high  number  of 
persons who were fleeing the war in Ukraine. This document was made available to the 
Member States and provides a very good example of complementary actions between CPR 
Funds to face challenges for the Union under a common framework and complementary 
instruments. 

In practical terms, some Member States have implemented measures to reduce duplication 
and improve fund management. For example, Spain introduced integrated calls for project 
applications that allowed entities to apply for funding from AMIF, ESF, or state budgets 
depending  on  the  nature  of  their  activities.  This  system,  combined  with  mandatory 
documentation requirements to distinguish funding sources, minimised the risk of double 

62 COM(2020)758 final. Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions: Action Plan on Integration 
and Inclusion 2021-2027: 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0758  
63  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. 

49 

 
 
funding  while  ensuring  that  diverse  integration  needs  were  met  efficiently.  These 
advancements  mark  a  significant  step  toward  leveraging  the  full  potential  of  EU 
Funds in supporting the integration of third-country nationals. 

the  need  for  good  coordination 

Preliminary  results  from  an  ongoing  study  on  “Strategic  coordination  and  financial 
complementarity  of  CPR  Funds  with  other  EU  Instruments”64  support  the  evaluation 
conclusion  about 
to  enhance  synergies  and 
complementarities.  However,  the  study  also  points  to  increased  complexity  and  the 
administrative  burdens  of  coordinating  multiple  programmes  and  Funds  such  as 
varying objectives, target groups, and management styles. The same study also refers 
to the fact that for some Managing Authorities, the primary difficulties in implementing 
synergies  among  Funds  stem  from  the  diverse  set  of  rules  governing  each  Fund, 
including  the ensuing  risk of double funding,  and the lack of clear communication and 
information  from  the  Commission  on  the  possibilities  and  modalities  of  implementing 
synergies  between  the  various  Funds  and  instruments.  In  particular,  the  variance  in 
definitions  and  procedures  between  funds  poses  challenges  and  generates  additional 
costs.  The  study  concludes  that  the  Monitoring  Committee  can  play  a  vital  role  in 
coordinating  CPR  Funds,  ensuring  strategic  alignment  across  EU  programmes. 
Comprising representatives from various Managing Authorities, the diverse composition 
of Monitoring Committees facilitates robust collaboration and information exchange. This 
the  effective 
enhances  synergy  and  prevents  overlap,  significantly 
implementation and integration of multiple funding streams. 

influencing 

The  Home  Affairs  Funds  have  only  been  marginally  concerned  by  the  possibility 
introduced  by  the  CPR  to  transfer  financial  resources  from  or  to  other  CPR  funds  (i.e. 
under Cohesion or Fisheries and Maritime policies), and no transfers between the AMIF 
the other CPR funds has taken place.  

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

4.2.1 To what extent is AMIF generating EU added value? 

The evidence collected underscores the AMIF’s role in providing essential support to 
Member  States,  extending  beyond  their  individual  capacities  to  address  migration 
and asylum challenges. Through its scope, scale, and functional contributions, AMIF has 
not only enhanced national systems but also strengthened the EU’s collective ability to 
respond  to  migration  dynamics.  This  aligns  with  the  broader  objective  of  fostering 
solidarity, innovation, and shared responsibility across the Union. 

The assessment shows that AMIF has played a significant role regarding scope effects in 
the majority of the supported Member States, specifically in addressing additional target 
groups  and  in  introducing  new  interventions  to  address  emerging  needs.  AMIF’s 
added value is furthermore demonstrated by its visible efforts that enabled a significant 
expansion of services, enhancing administrative capacity in managing migration and 
asylum processes in several Member States. It was not possible to carry out an extensive 
analysis  of  Member  States  investments  under  national  funds  during  the  course  of  the 
evaluation. Nevertheless, the  preparatory work undertaken during this  evaluation found 
evidence of AMIF generating EU added value.  Overall, AMIF  is  acting as  an  essential 
instrument for implementing EU migration policies. 

64 The study has been launched and coordinated by DG REGIO and is expected to be available in 2025. 

50 

 
 
Expanding the Scope of Services 

AMIF has demonstrated flexibility in addressing additional target groups and adapting 
to new migration challenges, such as the influx of unaccompanied minors and Ukrainian 
refugees, in 19 Member States. Examples include the establishment of temporary shelters 
in  Luxembourg  and  specialised  reception  facilities  in  Italy  for  unaccompanied  minors, 
showcasing AMIF’s flexibility in addressing emerging migration challenges. The Fund has 
enabled  the  introduction  of  new  interventions  to  meet  these  emerging  needs.  For 
instance,  three  Member  States  (EE,  MT,  RO)  have  introduced  psychological  support 
services  that  were  previously  unavailable.  In  France,  the  stakeholder  survey  involving 
public  authorities,  civil  society  organisations  and  service  providers,  revealed  that 
expanding  the  geographic  reach  and  diversifying  services  enabled  fund  recipients  to 
develop  new  support  measures  that  effectively  addressed  emerging  needs.  Moreover, 
Member  States  like  Finland  and  Hungary  expanded  training  services  and  integration 
programs  for  Ukrainian  refugees,  showcasing  AMIF’s  capacity  to  adapt  and  provide 
support  in  times  of  crisis.  This  expansion  in  scope  of  services  has  also  led  to 
improvements  in  public  policy  systems  and  the  management  of  migration-related 
services. For example, in Cyprus the AMIF’s investment in human resources and project 
implementation have helped to raise the standard of procedures, not only for short-term 
projects but in building sustainable expertise networks and infrastructures that continue to 
provide  value  even  after  AMIF  funding  ends.  This  has  led  to  an  improved  capacity  to 
manage migration and integration services effectively. 

Scaling Services and Increasing Reach 

AMIF has also enabled an expansion of services and increased the number of end-users 
in 11 Member States, particularly those facing migration crises. By significantly scaling 
up  services,  Member  States  such  as  Finland  and  Hungary  enhanced  their  training  and 
integration  programmes,  respectively,  to  better  serve  affected  populations.  This  was 
particularly  evident  during  the  Ukrainian  refugee  crisis,  where  Member  States  rapidly 
expanded their reception and integration  capacities. Notable  examples include Poland’s 
Foreigners’ Integration Centres and hybrid reception facilities in the Netherlands. The box  
below provides further examples of scale effects that can be observed under AMIF. 

Examples of scale effects under AMIF 

•  Ireland  reported  that  the  higher  volume  of  services  would  not  have  been 
possible without AMIF, as it is unclear if national resources alone could have 
supported  investment  on  new  services  (e.g.  CSO-led  projects,  mobile  health 
screening activities).   

•  In  Italy,  AMIF  guaranteed  a  higher  volume  of  services,  including  courses, 
complementary  services  such  as  childcare,  travel  cost  reimbursement, 
mentoring  services,  and  intercultural  mediation,  as  well  as  the  activation  of 
higher-level pathways beyond those normally provided.  

•  Lithuania benefitted from increased volumes of services such as translation, 
legal  assistance,  language  training,  employment,  and  counselling.  Here,  an 
interviewed  beneficiary  flagged  that  AMIF  support  for  infrastructure 
projects, particularly to enhance accommodation capacities for third-country 
nationals, demonstrates the scalability of AMIF’s interventions. These projects 

51 

 
would  not  have  been  financially  feasible  without  AMIF’s  backing,  thus 
contributing to the higher volume of services available for migrants.  

•  In Malta, the Fund has scaled up the provision of services, particularly in the 
areas  of  healthcare  and  material  aid  for  asylum  seekers  (e.g.  food,  medical 
supplies, social assistance and allowances). These elements have, according to 
stakeholders, been crucial in meeting the increased demand for services due to 
irregular migration flows. 

•  In  the  Netherlands,  the  programme’s  beneficiaries,  including  Civil  Society 
Organisations such as Save the Children, have noted an increase in the scale 
of services offered, especially concerning migrant integration and support for 
refugees. The volume of resettlement services has also expanded. 

•  In  Romania,  the  number  of  asylum  seekers  receiving  accommodation  in 
regional centres reached 10,100 individuals, reflecting a substantial increase 
in  service  capacity  from  900  to  over  2000  accommodating  spots.  Similarly, 
Sweden  was  able  to  increase  the  number  of  asylum  reception  places  and 
expand integration services.  

•  In Slovenia, AMIF helped increase the volume of services, particularly legal 
and  social  support  (e.g.  translation  services,  interpretation,  legal  services, 
healthcare)  for  asylum  seekers  and  third-country  nationals.  The  increased 
capacity for service provision was crucial in managing the growing number of 
asylum seekers. 

Enhancing Administrative and Functional Capacity 

AMIF has strengthened the administrative capacity of Member States in managing 
migration and asylum processes (CY, DE, EE, FI, FR, HU, LT, LU, MT, PL, RO, SE, 
SI,  SK).  This  has  resulted  in  enhanced  management  of  asylum  seekers  and  improved 
integration services, ultimately contributing to the EU’s added value in handling migration 
challenges  across  Member  States.  A  significant  number  of  Managing  Authorities  have 
reported notable progress in their ability to manage asylum systems and integrate migrants, 
aligning with EU objectives and standards. The AMIF programme was also reported as 
useful to improve capacity and coordination within public institutions: for instance, in 
Luxembourg AMIF contributed to improving coordination between government bodies, 
thus  enhancing  the  overall  migration  and  asylum  management.  In  addition,  in  the 
Netherlands, national institutions such as the Central Agency for the Reception of Asylum 
Seekers  and  the  Immigration  and  Naturalisation  Service  were  able  to  improve  their 
operational approaches, particularly through the adoption of hybrid reception models and 
enhanced  integration  efforts,  reflecting  significant  learning  and  capacity  building.  In  a 
similar manner, AMIF has provided key support for staff training and infrastructure 
development in three Member States (PL, RO, SI). Moreover, in Malta, AMIF enabled 
the Migration Agency and municipalities to expand their capacity to manage reception, 
integration,  and  return  services,  illustrating  the  direct  functional  benefits  of  the 
programme.  

52 

 
 
Mitigating Financial Dependency 

While AMIF has provided substantial financial support, there is no strong evidence of 
Member States being overly dependent on EU funding. National resources remain a 
cornerstone of migration and integration efforts, with AMIF serving as a complementary 
source. Examples include Slovenia and Slovakia, which have implemented measures to 
sustain integration services with national resources. However, in countries like Ireland and 
Cyprus, challenges such as reduced philanthropic funding or high migration inflows have 
led to some degree of reliance on AMIF. 

Overall, AMIF funding is critical for implementing specific projects that might not 
have  been  possible  without  such  support.  Managing  Authorities  underscored  AMIF's 
role  in  supplementing  national  budgets,  facilitating  a  unified  European  response  to 
migration and asylum challenges, and creating targeted integration measures for specific 
groups.65 Without  AMIF funding,  many beneficiaries  of the funding  would have had to 
scale  back  critical  initiatives  like  migrant  integration  and  language  training  or  resort  to 
fragmented  internal  resources,  significantly  reducing  efficiency  and  scope.  This  would 
have left gaps in services such as reception capacity, vocational training, and psychosocial 
support,  which  alternative  funding  could  not  easily  address,  especially  during  EU 
migratory emergencies. 

According  to  the  AMIF  beneficiaries,  the  absence  of  European  funding  during  the 
2021–2027  programming  period  would  pose  significant  challenges.  Among  the 
surveyed  beneficiaries,  88%  (22  respondents)  indicated  that  they  would  have  faced 
difficulties in implementing projects funded by EMAS under national funding.66  

Furthermore,  AMIF  funding  has  been  vital  for  fostering  multidisciplinary  networks 
crucial  for  knowledge-sharing  and  integrated  support  for  third-country  nationals.  Five 
beneficiaries highlighted the challenge of establishing such networks without EU funding, 
noting  that  relying  solely  on  national  budgets  would  have  slowed  these  processes  and 
jeopardized 
like 
long-term  projects,  particularly 
unaccompanied minors’ reception and temporary protection measures.67 

the  sustainability  of 

in  areas 

Despite this, AMIF is seen as a complementary rather than the unique source of funding. 
Member  States  consistently  demonstrate  efforts  to  combine  AMIF  with  national 
resources, ensuring services are not entirely dependent on EU support. For instance, 
Malta utilises national resources for core activities, while AMIF supplements these efforts 
to  secure  material  aid  and  additional  services  without  creating  dependency.  Similarly, 
Poland  integrates  national  initiatives,  supported  by  mechanisms  like  the  State  Fund  for 
War  Refugees  and  Border  Guard-financed  programs,  ensuring  that  EU  funding 
complements rather than replacing national efforts. 

Some  Member  States  have  proactively  reduced  dependency  on  EU  Funds  by 
sustaining key services through national resources. Slovenia has maintained long-term 
integration services with its budget, ensuring balanced investment. Slovakia, leveraging 
resources  from  its  Ministry  of  Labour  and  Social  Affairs,  collaborates  with  AMIF  to 
deliver social services and integration support. Interviews with Civil Society Organisations 
in  these  countries  stressed  the  importance  of  both  short  and  long-term  solutions  for 

65 Interviews with four Managing Authorities. 
66 Targeted survey with beneficiaries. 
67 Ibid. 

53 

 
 
empowerment, such as civic engagement, entrepreneurship, and professional networking, 
to mitigate reliance on external funding. 

However, challenges persist in certain countries. Ireland faces increasing dependence 
on  AMIF  due  to  a  decline  in  philanthropic  funding,  making  EU  support  essential  for 
maintaining  critical  services.  Similarly,  Cyprus  heavily  relies  on  AMIF  to  manage 
capacity-building  efforts,  mainly  due  to  its  particular  situation,  as  Cyprus  receives  the 
highest  proportional  migrant  influx  in  the  EU,  overwhelming  national  reception 
mechanisms. 

Ultimately,  while  AMIF  funding  has  been  instrumental  in  enhancing  migration 
management and integration, it is not the sole driver. National resources continue to 
play  a pivotal  role, with  EU funding acting as a significant enabler for addressing 
migration challenges at both national and EU levels. 

Addressing High-Value EU Priorities through the Thematic Facility 

The AMIF Thematic Facility, particularly through Specific Action projects and the 
European  Migration  Network  (EMN),  has  focused  on  EU-wide  priorities  such  as 
improving reception conditions, psychological support, and migration management. 
These initiatives align with EU standards and policies, showcasing the added value of 
AMIF in achieving common European responses to migration and asylum challenges. 

For instance,  the Thematic Facility has been  essential in delivering integration and 
resettlement services, contributing to broader Union goals of managing migration flows 
and  integrating  third-country  nationals  within  the  EU.  Projects  aimed  at  improving 
reception conditions, psychosocial support, and humane treatment were aligned with EU-
wide standards (ES, MT, NL, PL, RO, SE). In Poland, these efforts strengthened asylum 
infrastructure  and  aligned  with  EU  objectives,  while  in  Hungary,  they  allowed 
beneficiaries  to  legally  reside  in  the  EU  while  acquiring  skills  for  labour  market 
integration. 

Furthermore,  Thematic  Facility  funding  has  targeted  vulnerable  groups,  reinforcing 
high Union added value. For example, initiatives focusing on unaccompanied minors and 
refugees  from  conflict  zones  showcased  a  strong  commitment  to  EU  priorities,  such  as 
temporary  protection  and  values  of  solidarity  and  humanitarian  assistance,  particularly 
relevant during the Ukrainian refugee crisis (IT, LU, SK, SE). In Italy, Thematic Facility 
support  provided  essential  services  for  vulnerable  children  in  municipalities,  ensuring 
critical aid that would otherwise not have been guaranteed without EU funding. 

Specific Action projects, assessed within the respective thematic case study, clearly 
demonstrate EU added value. These projects complement national efforts by addressing 
immediate  needs  that  Member  States  alone  could  not  meet,  contributing  to  EU-wide 
migration  goals  of  harmonizing  systems  across  Member  States  and  offering  tailored 
solutions  to  specific  challenges.  For  example,  the  European  Return  and  Reintegration 
Network  project  established  an  EU  structural  intervention  programme  for  providing 
reintegration  services  and  support  that  did  not  exist  previously,  and  which  will  be 
continued by Frontex due to the success of the original project.  

To conclude, the analysis shows that AMIF has generated substantial EU added value 
across all Member States. With AMIF resources 19 Member States were able to develop 
new interventions and address new target groups,  thereby generating scope effects, and 

54 

 
enhancing the overall response to developments in migration. AMIF implementation has 
also generated scale effects in 11 Member States, as it enabled the expansion of services 
and end-users reached. In particular, in response to the influx of Ukrainian refugees that 
necessitated certain  Member States quickly scale up their service provision  to  meet  the 
heightened  demand.  AMIF  implementation  also  enhanced  and/or  increased  the 
administrative  capacity  to  manage  migration  and  asylum  processes  (e.g.  through 
improved capacity  and coordination, provision  of trainings, infrastructure  development, 
fostering of new partnerships) in 14 Member States. Overall, although AMIF funding is 
indeed pivotal for Member States, except for two Member States, all the others showcase 
no systematic dependency on EU funding. Finally, the additional support provided by 
the  Thematic  Facility  (e.g.  through  Specific  Actions  and  EMAS)  has  successfully 
addressed  priorities  with  a  high  Union  added  value,  while  also  supporting  Member 
States.  

4.3. 

Is the intervention still relevant? 

The relevance criterion assesses whether AMIF addresses the existing policy needs at the 
time of adoption and to what extent it is still relevant to address the stakeholders’ current 
needs and problems. Furthermore, it tackles the question of the Fund’s flexibility in the 
face of changing circumstances. The relevance of the intervention was assessed by using 
evidence from various desk sources such as Member State Programmes and national mid-
term evaluations, as well as field sources such as interviews, surveys, and case studies.  

To what extent did AMIF address the evolving needs?  

The  main  needs  of  the  intervention  have  been  identified  by  “The  Annual  Reports  of 
Migration and  Asylum”68  published by the European Migration Network  between 2019 
and 2023, as the need to:  

- 

- 

- 

- 

- 

- 

strengthen the management of asylum procedures due to the increase in the number 
of asylum applications; 

foster socio-economic integration of migrants, notably labour market integration, 
including language acquisition and education; 

improve assistance of protection measures for unaccompanied minors due to the 
high number of migrant children; 

address the needs of other relevant vulnerable groups of migrants (i.e. victims of 
trafficking, women, LGBTQI); 

improve return and readmission systems as well as reception capacity due to the 
higher number of irregular border crossings; 

further  enhance  migration  management  and  the  capacity  of  national  reception 
systems due to the additional strain cause by the large inflows of people fleeing the 
war in Ukraine.  

68  The  Annual  Reports  of  Migration  and  Asylum  are  produced  by  the  European  Migration  Network. 
Available at: EMN annual reports - European Commission.  

55 

 
 
These reflected growing trends at the time of Member States’ AMIF programme adoptions 
as regards number of asylum applications, number of first residence permits and number 
of resettled persons in the EU. Indeed, after COVID-19 restrictions started being lifted and 
applications  for  international  protection  started  increasing  again  in  2021,  bringing  the 
numbers back to the 2018 levels. This increase put pressure on Member States’ reception 
and asylum systems. In a similar way, the increased number of residence permits issued 
by  Member  States  in  2021  highlighted  the  need  to  strengthen  the  adoption  of  strong 
integration measures. Contrarily, the effectiveness of returns of the 27 Member States has 
seen  a  substantial  decline  in  2019  and  2020,  dropping  from  almost  45%  of  average 
effectiveness  to  35%  whereas  2021  was  marked  by  a  relative  increase,  going  up  to 
approximately 38% effectiveness69.  

These  evolving needs shaping  the  volatile  context  of migration  and asylum  are aligned 
with the specific needs defined in the intervention logic of AMIF 2021-2027 programming 
period. In fact, none of the evidence collected as part of the stakeholder consultation 
indicated that the intervention logic is not relevant anymore.  

AMIF’s relevance at the time of the Member States’ programme approval 

Table 1 in Annex II demonstrates that, overall, Member States incorporated measures 
addressing both the evolving migration context and the specific needs outlined in the 
intervention logic at the time their programmes were adopted. 

Targeted surveys involving beneficiaries, national authorities, Managing Authorities, and 
Civil Society Organisations provided generally  positive feedback on the proportional 
allocation  of  resources  to  identified  needs.  However,  some  stakeholders  noted  that 
insufficient resources limited the ability to address specific needs of certain target groups, 
such as unaccompanied minors requiring integration and education services. 

The box below shows key challenges gathered from three national mid-term evaluations: 

69  Eurostat  (2024),  Third  country  nationals  ordered  to  leave  -  annual  data  (rounded),  available  at: 
https://ec.europa.eu/eurostat/databrowser/view/migr_eiord__custom_13558582/default/table?lang=en 
.  
Eurostat (2024), Third country nationals returned following an order to leave  - annual data, available at: 
https://ec.europa.eu/eurostat/databrowser/view/migr_eirtn__custom_13557630/default/table?lang=en  

56 

 
 
Challenges  in  the  proportionality  of  milestones  and  targets  that  prevent  a  full 
coverage of evolving needs  

• 

• 

• 

In  Greece,  there  was  a  growing  demand  and  use  of  national  resources  to  cover 
emerging  needs,  which revealed  a certain  rigidity  in  diverting  existing  resources 
while still satisfying the initially established milestones and targets.  

In Romania, whilst overall allocation proved to be aligned with identified priority 
needs,  there  were  calls  for  proposals  for  which  no  applications  were  submitted, 
indicating  potential  mismatches  between  funding  availability  and  stakeholder 
readiness  to  use  them,  which  in  the  end  might  affect  an  effective  response  to 
ongoing and emerging challenges. 

In  Estonia,  bureaucratic  challenges  and  financial  constraints  hindered  overall 
capacity to scale up and adjust the interventions in response to crises such as the 
Ukrainian refugee influx. 

In  conclusion,  during  the  approval  phase  of  Member  States’  programmes,  AMIF 
allocations  for  the  2021–2027  programming  period  were  relatively  well-aligned  with 
evolving needs. Nevertheless, limitations were noted in addressing the specific needs of 
vulnerable groups (e.g., unaccompanied minors’ integration services) and in overcoming 
bureaucratic and procedural barriers to effectively respond to emerging challenges. 

AMIF’s relevance during its implementation 

Overall,  key  measures  planned  at  the  national  level  proved  to  be  suitable  for 
addressing  evolving  needs  during  programme  implementation,  particularly  in 
response to crises such the influx of Ukrainian refugees as reported in  most of the 
Member States’ mid-term evaluations (15 Member States).  

In  their  mid-term  evaluations,  Bulgaria  and  Germany  reported  on  the  strategies  they 
developed to ensure AMIF resources are allocated to priority areas and address the most 
pressing migration challenges during programme implementation to maximise the impact 
of the Fund. In Bulgaria, priority areas include enhancing asylum processing systems and 
expanding integration services. The strategy ensured these areas, which remain important 
due to  global conflicts  that drive asylum seeks toward the  country,  received  the largest 
share of AMIF funding. In Germany, a flexible approach to resource allocation allows for 
responsive resource allocation according to shifts in migration policy and migration flows. 
The  needs  are  regularly  evaluated  based  on  migration  data  and  stakeholder  input,  and 
ensures pressing needs are consistently funded.  

The correct identification of stakeholders proved effective to engage a large spectrum of 
actors, in line with the multi-dimensionality of the Fund’s objectives, and to establish an 
efficient partnership, in line with the objectives outlined in the legal basis.  

Indeed, case studies show that AMIF’s capacity to address evolving needs is further 
enhanced by the fact that stakeholders are correctly identified. The case studies show 
that actors involved in AMIF’s implementation have expertise in all relevant fields such 
as irregular migration, asylum processes and reception facilities, among others. The variety 

57 

 
 
of perspectives of actors involved in the implementation process shows that relevant needs 
were considered during programme implementation.  

A key mechanism that contributed to ensure the Fund’s identification and respondence to 
priority  needs  is  the  effective  partnership  with  national  stakeholders  who  were  able  to 
provide  inputs  on  the  evolving  needs  using  public  consultations  for  example.  The  box 
below outlines key examples of mechanisms adopted to identify relevant stakeholders in 
the Member States.  

Identification of national stakeholders who can provide inputs on evolving needs in 
the Member States  

•  Finland: To facilitate networking and enable partnerships, the Managing Authority 
organises  events  and  training  sessions  targeted  at  relevant  national  stakeholders, 
with a view to engage them during the implementation of the Fund and gather useful 
feedback to adapt programme implementation to evolving needs. The involvement 
of national  stakeholders  is  facilitated by the use  of an electronic tool for  project 
management,  which  is  accessible  by  all  programme  stakeholders  and  other 
interested parties, enabling structured cooperation between them and the Managing 
Authority.  

•  France:  In  2021,  France  adopted  a  plan  to  strengthen  the  management  of  the 
vulnerabilities  of  asylum  seekers  and  refugees,  following  a  broad  consultation 
involving  health  and  mental  health  stakeholders  (central  administrations  of  the 
Ministry of Health, regional health agencies, carers, etc.), operators of the national 
reception system and specialised Civil Society Organisations. 

•  Italy:  During  the  current  programming  period,  Italy  established  the  so-called 
“Control  Room”,  serving  as  a  permanent  coordination  mechanism  among 
stakeholders  responsible  for  the  implementation  of  the  various  interventions 
covered in the Member State Programme. Additional partners may join if needed. 
The  Control  Room  can  meet  regularly  or  on  a  need-basis,  allowing  for  quick 
detection and analysis of any contextual changes that might require adjustments to 
the Member State Programme. Moreover, Italy set up three Technical Groups for 
asylum,  integration,  and  repatriation,  which  include  immigration  management 
officials and the National Statistic Office with a view to share ongoing updates on 
thematic  needs  and  agree  on  any  necessary  corrective  measures.  Two  more 
mechanisms  for  identifying  contextual  shifts  and  adapting  the  MS  Programme 
accordingly  are  the  Permanent  Table,  composed  of  foreign  communities  and 
relevant Civil Society Organisations, and the Thematic Consultative Tables, which 
involve  various  national  stakeholders  such  as  regions,  universities,  and 
humanitarian corridor entities, promoting active civil society participation. Lastly, 
an independent evaluator is responsible for regularly analysing contextual changes 
and update the needs analysis, and to suggest recommendations towards addressing 
new and changing circumstances. 

Lastly, the Thematic Facility Work Programmes have demonstrated a clear focus on 
addressing  key  priority  needs  and  target  groups,  including  asylum  seekers,  third-
children, 
country  nationals  under 

international  protection, 

vulnerable 

58 

 
 
unaccompanied minors, and victims of trafficking of human beings. The Thematic 
Facility instruments have proven effective  to support  key needs and target groups 
that were not fully covered by the Member States programmes.  

In Malta, resources from the Thematic Facility helped cover the key needs of asylum seeks 
and unaccompanied minors (i.e. medical supplies, food, psychological assistance). In other 
Member  States  (LT,  PL,  RO),  resources  from  the  Thematic  Facility  helped  strengthen 
national reception systems. Overall, the thematic case studies on Union Actions, Specific 
Actions and EMAS demonstrate that these instruments were key to supporting Member 
States  with  evolving  challenges  and  needs  that  were  not  fully  covered  through  AMIF 
funding allocated to Member State programmes. 

To what extent can AMIF adapt to the evolving needs?  

Overall,  AMIF  can  largely  adapt  to  evolving  needs.  This  was  stressed  by  twelve 
Member States in their national mid-term evaluation the AMIF as they highlighted AMIF’s 
ability to adapt to new developments in migration flows and TCNs’ needs (AT, DE, IE, 
IT, LU, MT, NL, PL, RO, SE, SI, SK). Several factors contribute to the Fund’s ability to 
adapt to new and emerging circumstances.  

Needs assessment 

Firstly, all Member States perform a needs assessment before preparing their programme, 
and some clearly state in their national mid-term evaluations that this is regularly updated. 
Evidence from the survey targeted at Managing Authorities indicates that needs assessment 
and  the  Member  State  programmes’  strategy  were  defined  based  on  consultations  with 
relevant  stakeholders  (AT, BE, BG, CZ, HR, IT, PT, SI), in  some  cases  also  involving 
regional  offices  and  international  bodies  such  as  UNHCR,70  and/or  defined  based  on  a 
SWOT analysis71 (or equivalent) analysis (BE, DE, EE, LT, RO). The box below provides 
examples of needs assessments performed across the Member States. 

Overview of needs assessments performed across the Member States  

•  Finland performs a needs assessment during the preparation phase of the AMIF 
programme,  but  there  is  very  limited  flexibility  in  adapting/updating  it  vis-a-vis 
evolving external circumstances.  

•  France performs a needs assessment at the beginning of the programming period, 
but there is no evidence that this assessment is regularly updated beyond the initial 
programming phase, which could limit the programme’s ability to address evolving 
needs effectively. 

• 

In Germany, the programme incorporates the role of the monitoring committee to 
assess needs and make necessary adjustments.  

•  Similarly,  Bulgaria  and  Czech  Republic  carried  out  initial  needs  assessments 
based on statistical data and thematic areas, focusing on the most significant threats 
and  gaps.  However,  the  available  information  does  not  clarify  whether  these 

70 Interview with four Managing Authorities. Interview with one beneficiary. 
71 A SWOT analysis identifies the strengths, weaknesses, opportunities and threats of a project, programme, 
organisation, etc.  

59 

 
 
assessments  have  been  regularly  updated,  relying  more  on  baseline  analyses 
without systematic adjustments for new developments. 

•  Hungary recognises that the initial needs assessment requires updates, yet there is 

no evidence that this is taking place systematically.  

•  Luxembourg: The Managing Authority and the National Reception Office (ONA) 
conducted  rapid  assessments  in  response  to  the  Ukrainian  refugee  crisis,  which 
allowed them to update their programmes swiftly and increase temporary housing 
capacity by opening 11 emergency shelters in early 2022.  

The role of the monitoring committee  

The  Monitoring  Committee  plays  a  key  role  in  ensuring  timely  input  on  evolving 
needs  and  facilitating  programme  adjustments,  ensuring  that  both  immediate  and 
long-term migration challenges are addressed. 

The lack of a regular update to the needs assessment might undermine the capacity of the 
Member States  programmes to adapt to evolving needs, but the Managing Authorities can 
also benefit from the efficient stakeholder identification and hence receive timely inputs 
through  other  ways.  There  is  indeed  evidence  from  most  Member  States  that  the 
management  of  the  Fund  entails  a  partnership  approach  based  on  the  involvement  of 
relevant  national  stakeholders  from  the  design  to  the  implementation  and  monitoring 
phases of the Fund (CY, CZ, DE, EE, EL, ES, FR, IT, LU, MT, NL, PL, SE, SI, SK).  

Examples of involvement of the Monitoring Committee across the Member States  

• 

• 

• 

• 

In Finland, the AMIF Monitoring Committee is a comprehensive body, including 
local administrations and public authorities, as well as organisational actors.  This 
broad membership ensures that diverse backgrounds and perspectives are taken into 
account, thus facilitating comprehensive adjustments when needed.  

In Malta, the Monitoring Committee provided timely feedback on the possibility 
to amend the Maltese AMIF programme in line with evolving needs, although there 
is room for improving communication and feedback mechanisms.  

In the Netherlands, regular meetings coordinated by the Ministry of Justice and 
Security with the Monitoring Committee helped gather insights from stakeholders 
on the necessity to modify the Dutch AMIF programme to cover evolving needs, 
though some have noted the need for more proactive and frequent communication, 
especially during delays in the application process. 

In  Romania,  the  Monitoring  Committee,  with  representatives  from  government 
bodies,  Civil  Society  Organisations,  and  international  organisations  such  as 
UNHCR,  met  regularly  to  review  programme  progress  and  adapt  it  to  emerging 
migration challenges, ensuring responsiveness to changing conditions.  

• 

In Slovakia, the Monitoring Committee, which includes actors such as the Ministry 
of  Labour  and  Social  Affairs  and  local  Civil  Society  Organisations,  provided 

60 

 
 
continuous input during the Ukrainian crisis, allowing the government to quickly 
adapt the Slovakia’s AMIF programme to provide emergency housing and services.  

AMIF’s flexibility 

AMIF has demonstrated significant flexibility in adapting to the evolving needs of 
Member  States.  Article  24(5)  of  the  Common  Provision  Regulation,  allows  Member 
States to transfer up to 15% of the initial allocation of a priority to another priority within 
the  same  Fund  during  the  programming  period,  without  requiring  the  approval  of  an 
amendment by the Commission. This mechanism has eased adjustments of Member State 
Programmes in response to migration-related challenges and external shocks.72 

Notably, most of the Managing Authorities consulted highlighted how AMIF’s flexibility 
enables  the  relocation  of  funds  and  the  adaption  of  Member  State  programmes  to 
respond to new challenges, such as the refugee crisis stemming from the Russian war of 
aggression against Ukraine and the related increased service demand, or the need to expand 
the  number  of  municipalities  covered.73  Overall,  there  is  evidence  for  eleven  Member 
States (AT, CY, DE, EE, EL, ES, FI, FR, NL, RO, SI) that flexibility mechanisms as per 
Article 24 (5) of the Common Provision Regulation allowed Member States to introduce 
non-substantial changes to their Member State programmes. 

Several Member States turned to the Thematic Facility to respond to newly emerging 
needs  and  benefitted  from  the  flexibility  offered  by  it,  for  instance  in  managing  the 
migratory wave from Ukraine and the management of unexpected inflow of refugees and 
needs  for  resettlement  (speeding  up  procedures  and  enhancing  infrastructure,  such  as 
housing and healthcare) (AT, CZ, DE, EL, ES, IE, IT, LU, MT, NL, RO, SE, SI, SK). For 
instance, in Malta, the Thematic Facility was used to address emerging needs, particularly 
in providing material aid and healthcare services to newly arrived asylum seekers. Indeed, 
different  types  of  actions  such  as  Union  Actions,  EMAS  and  Specific  Action  financed 
through the Thematic Facility have been flexibly used by the Member States to address 
evolving  needs.  Notably,  the  “Safe  Hut”  Union  Action,  which  focuses  on  creating  safe 
spaces for women and girls to empower them and provide support against gender-based 
violence and human trafficking, was flexible enough to enable project partners in Lithuania 
and  Romania  to  reallocate  budget  to  accommodate  the  influx  of  migrant  women  from 
Ukraine.  

Mechanisms facilitating financial flexibility 

•  Reallocation of Resources: examples from Member States show how flexibility 
mechanisms enabled non-substantial changes in budgets to accommodate emerging 
needs: 

o  Germany:  Budget  readjustments  within  Germany’s  AMIF  programme 
increased  funding  for  SO1  by  around    €53  million  to  support  Ukrainian 
refugees, while reducing SO3 and SO4 funding. 

72 Interview with six Managing Authorities 
73 Interview with six Managing Authorities. 

61 

 
 
 
o  Poland: funds were shifted to enhance reception capacities and support for 

Ukrainian nationals. 

o  Romania:  Resources  were  reallocated  to  address  the  resettlement  of 

Ukrainian refugees under solidarity objectives. 

o  Slovenia: Flexibility was demonstrated through reallocations of up to 15% 

between types of actions in the same specific objective. 

Administrative and Procedural Challenges 

Despite its strengths, certain barriers have limited AMIF’s full adaptability: 

•  Administrative  Hurdles:  Bureaucratic  delays,  particularly  when  requiring 
Commission approval, are claimed to have slowed Programme adjustments in some 
Member  States  (e.g.,  Bulgaria,  Czech  Republic,  Estonia,  France,  Malta,  and 
Poland). 

•  Procurement Procedures: Challenges in procurement processes hindered timely 
project implementation, with notable issues in countries like Luxembourg, Malta, 
and the Netherlands. For example: 

o  Luxembourg’s  centralised  procurement 

limited  project  adaptability, 

especially for large-scale infrastructure projects. 

o  Poland  faced  early-stage  difficulties  with  the  CST2021  administrative 

system, increasing administrative burdens, 

o  Malta experienced significant delays due to lengthy procurement processes. 

The Pact on Migration and Asylum 

The recently adopted Pact on Migration and Asylum, consisting of a legislative package 
embedding nine Regulations74,  is  beyond the scope of this evaluation. Nonetheless  it is 
clear that the scope of AMIF largely covers the activities  underpinned by the Pact. The 
Member  States  have  developed  National  Implementation  Plans  7576in  accordance  with 
Article  86  of  the  Asylum  Migration  Management  Regulation77  pointing  to  the  different 
elements of their asylum and migration systems to be further developed in view of ensuring 
full  preparedness  for  the  Pact  implementation.  While  the  scope  of  the  current  AMIF  is 
considered to be relevant to address those needs, the Commission services have clarified 

74 Pact on Migration and Asylum - European Commission 
75 Regulation (EU) 2024/1351 of 14 May 2024 on asylum and migration management, amending Regulations 
(EU) 2021/1147 and (EU) 2021/1060 and repealing Regulation (EU) No 604/2013. Article 86, ‘Transitional 
Provisions’: each Member State shall, with the support of the Commission and relevant Union bodies, offices 
and  agencies,  establish  a  national  implementation  plan  setting  out  the  actions  and  the  timeline  for  their 
implementation. Each Member State shall complete the implementation of its plan by 1 July 2026. 
76 Article 86, ‘Transitional Provisions’: each Member State shall, with the support of the Commission and 
relevant Union bodies, offices and agencies, establish a national implementation plan setting out the actions 
and the timeline for their implementation. Each Member State shall complete the implementation of its plan 
by 1 July 2026. 
77 Each Member State shall, with the support of the Commission and relevant Union bodies, offices and 
agencies,  establish  a  national  implementation  plan  setting  out  the  actions  and  the  timeline  for  their 
implementation. Each Member State shall complete the implementation of its plan by 1 July 2026. 

62 

 
 
to the Member States on several occasions that national funds will also be necessary to 
comply with the new acquis.  

To conclude, AMIF’s flexibility mechanisms, particularly resource reallocation and the 
Thematic Facility, have enabled Member States to adapt to evolving migration needs 
effectively. While AMIF has mechanisms for flexibility, the needs assessments carried 
out  at  the  start  of  the  programming  period  to  support  the  AMIF  programmes’ 
preparation  are  not  systematically  updated  during  implementation.  Feedback  on 
evolving needs primarily comes from stakeholders via Monitoring Committees, rather than 
through  a  structured  process.  However,  administrative  and  procedural  barriers, 
especially  in procurement processes,  pose challenges to the swift adaptation of  the 
AMIF  programmes.  To  enhance  responsiveness,  improving  procurement  frameworks 
and systematically updating needs assessments could further strengthen AMIF’s capacity 
to address emerging challenges. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  Conclusions 

5.1.1 

 Effectiveness 

Considering the relatively early stage in the implementation of the Fund, the effectiveness 
criterion has been mainly applied to assess the processes and mechanisms within the Fund 
and how they function to allow adequate and timely progress towards the achievement of 
the objectives, rather than providing a final assessment of the actual levels of achievement 
of the objectives.  

Following an initial delay in the start of implementation, AMIF programmes seem to 
have reached cruise speed, with an implementation rate of 46% and absorption rate 
of 11% (the highest rate of among the CPR Funds).   

Financial  progress,  observed  through  the  absorption  rate,  appears  particularly  evident 
under Specific Objective (SO) 1 (in relation to the development of the Common European 
Asylum System) and SO2 (focusing on promoting legal migration, integration and social 
inclusion  of  third-country  nationals).  SO3  (countering  illegal  migration,  and  enhancing 
return and readmission of irregular third-country nationals) shows a less marked progress, 
most probably due to inherent difficulties of the return measures, demanding needs in terms 
of coordination and high dependence on the cooperation of third countries. SO4 (solidarity 
measures, such resettlement, humanitarian admissions and relocation) is essentially fed by 
allocations transferred from the Thematic Facility, based on pledges or number of persons 
effectively relocated. This explains the high level of execution observed for this SO.       

When  looking  at  physical  progress  of  output  and  result  indicators  against  their 
respective milestones and target levels, the evaluation concludes that Member States 
are  progressing  towards  the  Fund  operational  objectives,  albeit  with  notable 
variations in terms of speed and levels of achievements.  

Under SO1 (Common European Asylum System), the analysis shows strong progress in 
terms of the number of participants supported. Nine Member States (LV, SE, DE, SI, FI, 
EL, HR, BG, NL) report average milestone performance rates across SO1 output indicators 

63 

 
exceeding 100%, with an overall average across Member States of 72%. However, nine 
other Member States (BE, CZ, ES, HU, MT, PL, PT, RO, SK) reported no progress in SO1. 

For  SO2  (Legal  migration  and  integration),  substantial  progress  has  been  made  for  the 
number  of  participants  supported.  Germany  (234%),  Luxembourg  (102%)  and  Latvia 
(67%)  have  achieved  the  highest  average  milestone  performance  rates  across  output 
indicators under SO2. Eleven Member States (BG, EL, ES, HR, HU, LT, MT, PL, PT, RO, 
SK) have achieved average milestone performance rates of 0%. 

Under  SO3  (Return),  the  strongest  progress  across  Member  States  was  made  under  the 
indicator "Number of returnees who received re-integration assistance" (62% on average). 
Portugal  (175%),  the  Netherlands  (93%)  and  Estonia  (61%)  have  achieved  the  highest 
average milestone performance rates across output indicators under SO3, with the overall 
average across Member States being 21%. At the same time, ten Member States (BE, BG, 
EL, HR, HU, LV, MT, PL, RO, SK) have achieved average milestone performance rates 
of 0% and Lithuania has reported no data on progress of output indicators.  

For SO4 (Solidarity), significant progress towards result indicators across Member States 
has  been  reported  for  the  "Number  of  applicants  for  and  beneficiaries  of  international 
protection  transferred  from  one  Member  State  to  another"  (34%),  "Number  of  persons 
admitted  through  humanitarian  admission"  (30%),  and  "Number  of  persons  resettled" 
(24%). These advancements are however driven by few Member States, such as Romania, 
Finland and Sweden, having nearly already achieved their targets. Germany is leading in 
terms  of  absolute  numbers  of  persons  resettled  and  admitted  through  humanitarian 
admission. 

Progress towards AMIF milestones and targets has been impacted by both external 
factors,  such  as  the  war  in  Ukraine  and  COVID-19,  and  internal  challenges  such  as 
staffing shortages and regulatory issues. While some Member States have addressed these 
challenges through strategies such as increasing staff or simplifying procedures, there is 
no  uniform  approach  to  overcoming  these  barriers.  Nonetheless,  good  practices  have 
emerged,  including  capacity  building,  flexible  project  objectives,  and  effective  crisis 
response, demonstrating the resilience of AMIF in supporting migration management and 
integration. 

As regards the progress in the implementation of the Thematic Facility, by mid-2024 
the AMIF work programme 2021-2022, the specific EMAS 2021 work programme 
and the EMN 2021-2022 work programme were fully implemented, meaning that the 
corresponding budget has been fully committed, either by allocating additional resources 
to the programmes (Specific Actions, resettlement, and relocation, implemented in shared 
management)  or  through  grants  and  other  administrative  arrangements  (Union  Actions, 
implemented in direct or indirect management). The implementation of the 2023 – 2025 
work programme is on track.  

By  mid-2024,  the  AMIF  Thematic  Facility  has  supported  656  projects  under  Union 
Actions,  19  EMAS  projects  and  22  Specific  Actions.  In  addition,  a  total  of  EUR  730 
million  has  been  allocated  to  the  programmes  for  the  funding  of  resettlement  and 
humanitarian  admission  activities  and  EUR  14.7  million  for  the  funding  of  relocation 
activities  (both  under  SO4).  Overall,  Union  Actions  are  considered  by  the  projects’ 
beneficiaries particularly effective in strengthening and developing legal migration and in 
contributing to the integration and social inclusion of third-country nationals.  

64 

 
Interviewed Managing Authorities also share a positive judgement on the effectiveness 
of  the  Fund  to  address  its  intended  objectives  (under  both  the  programmes  and  the 
Thematic Facility). 

Concerning the suitability of the monitoring and evaluation framework to inform on 
the progress towards the achievement of the objectives of the instrument, the evaluation 
concludes  that  the  monitoring  and  evaluation  framework  for  AMIF  has  seen 
significant  improvements  compared  to  the  2014-2020  period,  including  in  terms  of 
more detailed explanatory documents and resources provided to Member States. However, 
challenges persist in terms of quality of data collection and reporting. Those mainly 
relate to issues such as missing or inflated data, unsubstantiated outputs, and inconsistent 
reporting. The evaluation highlights that higher efforts should be deployed in supporting 
the understanding of monitoring requirements by the final beneficiaries.  

Based on qualitative information (interviews with Managing Authorities and beneficiaries) 
the  evaluation  reports  a  widespread  perception  of  excessive  administrative  burden, 
including  due  to  duplication  in  the  provision  of  information  at  different  stages  and  for 
different purposes. However, it is too early to judge on whether the burden of the system 
is  proportionate  with  respect  to  its  benefits  in  terms  of  transparency  and  policy 
development. Other findings of the evaluation point in direction  of possible gaps in the 
coverage of the  effects  of the  funding  based on  the existing  set  of  common  output and 
result indicators laid down in Annex VIII  AMIF Regulation (too broad scope of certain 
indicators or missing indicators in certain policy areas).  

Concerning  Union  Actions,  the  evaluation  concludes  that  they  utilise  a  structured  yet 
flexible framework, employing standardised templates and detailed reporting guidelines to 
ensure high data quality and timely, and accurate financial and narrative reporting. 

Despite the challenges linked to the stricter rules introduced by the CPR on the application 
of the partnership principle, relevant partners are broadly and effectively involved in 
the  management  of  AMIF  across  all  stages  of  the  programming,  implementation, 
monitoring and evaluation.  

The involvement of relevant partners in the preparation, implementation, and evaluation 
of  the  AMIF  has  been  consistently  emphasised  by  all  Member  States.  The  Member 
States have employed a variety of mechanisms to ensure broad participation throughout 
the  Fund’s  cycle.  Stakeholders  such  as  civil  society  organisations,  local  authorities, 
and international bodies have been actively engaged, particularly in the development of 
the programmes and through membership in Monitoring Committees. Challenges in the 
involvement  of  the  partners  are  signalled  in  relation  to  difficulties  by  the  participating 
stakeholders  in  fully  understanding  the  somehow  complex  legislative  framework  and 
operational aspects linked to the implementation of AMIF.  

The  analysis  confirms  that  all  Member  States  are  committed  to  upholding  the 
horizontal principles, including gender equality, non-discrimination, and sustainable 
development, within their programmes. National mechanisms, such as training, audits, 
and compliance checks, are in place to ensure adherence to these principles, though their 
effectiveness  varies  across  countries.  While  gender  equality  and  non-discrimination  are 
actively promoted, sustainable development receives a less prominent attention. Overall, 
while  progress  has  been  made,  gaps  remain  in  the  consistency  of  reporting  on  the 
horizontal principles. 

65 

 
The analysis of communication measures confirms that all Member States have put in 
place  various  mechanisms  to  disseminate  information  on  the  AMIF.  While  many 
Member States have established communication strategies, these are often only described 
in  general  terms  in  the  available  documentation  without  detailed  explanations  of  their 
implementation.  Overall,  the  communication  measures  are  deemed  successful  in 
reaching  a  broad  audience,  but  challenges  persist  in  fully  engaging  smaller 
organisations and Civil Society Organisations. Despite these challenges, the measures 
have  contributed  to  improved  visibility  and  outreach  compared  to  the  previous 
programming period. 

5.1.2 

 Efficiency 

Overall, the Fund demonstrates a commitment to supporting cost-effective measures, 
with  evidence  of  diverse  interventions  that  align  with  best  practices  in  areas  such  as 
asylum,  integration,  and  voluntary  return.  However,  its  cost-effectiveness  is  unevenly 
realised. While simplified cost options and flat-rate technical assistance have contributed 
to  reducing  administrative  burden,  the  implementation  of  simplified  cost  options  is 
inconsistent,  and  unit  cost  calculations  are  not  systematically  applied  to  optimise 
spending. Additionally, disparities in costs per unit across similar activities highlight gaps 
in  efficiency.  Despite  these  challenges,  the  Fund's  emphasis  on  cost-effectiveness  as  a 
criterion for project selection and its ability to address urgent needs through components 
like Emergency Assistance reflect its potential to improve efficiency.  

The  cost-efficiency  of  the  management  and  control  system  under  the  Fund  shows 
mixed  results.  On  one  hand,  the  system  has  benefited  from  the  introduction  of 
simplification measures such as flat rates, lump sums, and electronic data exchange 
systems,  which  have  eased  administrative  burdens  and  streamlined  certain  processes. 
Technical  Assistance  has  played  a  critical  role  in  strengthening  management 
capacities,  with  resources  allocated  to  improve  IT  systems  and  provide  training. 
These measures have contributed to a more proportionate administrative burden compared 
to the previous programming period.  

On the other hand, challenges persist. Many beneficiaries and Managing Authorities 
report that regulatory and monitoring requirements remain cumbersome. Issues such 
as duplicative data entry, inconsistent application of simplification measures, and delays 
in the implementation of integrated information systems undermine the overall efficiency 
of  the  system.  These  challenges  suggest  that  while  progress  has  been  made,  the 
management and control system still requires further refinement to fully optimize its cost-
efficiency. 

for 

improvement 

Key  areas 
integration  and  automation. 
include  system 
Interoperability between national systems and EU platforms would reduce duplicative data 
entry,  while  automating  processes  like  indicator  tracking  could  cut  manual  work  and 
errors.  Revising  reporting  requirements,  especially  for  smaller  projects,  and  expanding 
the use of lump sums and flat rates would also ease administrative burdens. Capacity-
building  initiatives  to  train  Managing  Authorities  and  beneficiaries  in  data 
management  could  further  enhance  efficiency.  Implementing  these  measures  would 
better  align  administrative  tasks  with  the  Fund’s  goals,  ensuring  more  resources  are 
directed toward achieving strategic objectives. 

66 

 
5.1.3 

 Coherence 

The AMIF demonstrates a satisfactory degree of coherence with initiatives supported 
under its policy domain, particularly between the Member States programmes and 
the Thematic Facility, as well as between the programming under AMIF and other 
EU Funds.  

The relationship between the AMIF's Member States’ Programmes and the Thematic 
Facility  is  broadly  complementary,  although  the  clear  delineation  between  these  two 
components remains a challenge in practice. Only some Member States reported on the 
alignment and complementarity between the fund components, highlighting the need for 
improved integration and transparency in reporting practices. However, the Member States 
that  reported  on  coherence  in  their  APRs  and  national  mid-term  evaluations  viewed  it 
positively.  

At the EU level, efforts to ensure coherence between the AMIF and policy agendas 
are actively pursued. The Member States generally align their AMIF programmes with 
EU priorities, with many reporting significant coherence with national strategies.  While 
inter-  and  intra-agency  cooperation  is  widespread,  further  details  on  the  coordination 
mechanisms in place are needed to evaluate the effectiveness of these efforts. 

Overall,  while  further  reporting  on  internal  coherence  is  necessary  for  a  more 
comprehensive analysis, the data available exhibits a satisfactory degree of coherence.  

The AMIF demonstrates strong complementarities with other EU Funds, such as the 
ESF+,  the  BMVI  and  the  ERDF.  These  Funds  share  similar  strategic  objectives,  and 
synergies  are  pursued  through  coordination  mechanisms  such  as  joint  Monitoring 
Committees and regular exchanges or information. While there are occasional overlaps in 
objectives, these are largely justified by the distinct roles each Fund plays in the migration 
and integration landscape. In terms of complementarities, the NDICI and the RRF work 
alongside the AMIF by addressing different areas of support. The NDICI focuses on long-
term development in third countries, while the RRF provides immediate socio-economic 
support to EU Member States. Together, they strengthen overall resilience and integration 
capacity in  response to  crises.  However, concerning  funding in  the  external  dimension, 
enhanced cooperation and coordination on programming both between the Commission 
services and with EU Member States are needed.  

Overall,  while  there  are  challenges  in  the  seamless  coordination  of  the  various  AMIF 
instruments and other EU Funds, in particular due to the diverse rules and procedures of 
each  Fund,  the  AMIF’s  design  and  operational  mechanisms  foster  coherence  and 
complementarity. 

 How  did  the  EU  intervention  make  a  difference  and  to  whom  (EU  added 

5.1.4 
value)? 

Overall,  the  assessment  of  the  EU  added  value  of  AMIF  reveals  significant 
contributions across various dimensions. 

AMIF has demonstrated clear scope effects in the majority of Member States (19), by 
addressing  additional  target  groups  and  introducing  new  interventions  to  meet 
emerging needs, such as unaccompanied minors and Ukrainian refugees. The programme's 

67 

 
flexibility allowed for a substantial expansion in both the groups served and the services 
provided, particularly in response to the Ukrainian refugee crisis.  

In terms of scale effects, AMIF has enabled the expansion of services and increased the 
number  of  end-users  reached  in  11  Member  States.  This  was  particularly  evident  in 
countries responding to migration crises, such as the influx of Ukrainian refugees.  

Function  effects  are  also  evident,  with  AMIF  enhancing  administrative  capacity  in 
managing migration and asylum processes in several Member States. This led to improved 
management of asylum seekers and integration services, contributing to the EU’s added 
value  in  handling  migration  challenges,  for  example,  through  improved  capacity  and 
coordination,  provision  of  training,  infrastructure  development,  and  fostering  of  new 
partnerships. 

Despite the extensive and pivotal support provided by AMIF, there is no strong evidence 
of  Member  States  being  excessively  dependent  on  EU  funding.  National  resources 
continue to play a key role, with AMIF serving as a complementary source of funding. 
Some  Member  States  have  taken  measures  to  avoid  full  dependence  on  EU  Funds  by 
sustaining  long-term  integration  services  with  national  resources.  Some  degree  of 
dependency on AMIF funding emerged only in two Member States.  

Finally,  the  Thematic  Facility,  especially  through  Specific  Actions  and  EMAS,  has 
successfully addressed broader priorities with high Union added value, contributing 
significantly to EU-wide goals. Such projects focused on improving reception conditions, 
providing psychological support, and ensuring humane treatment and effective migration 
management, aligning with EU standards and priorities. Generally, AMIF funding is seen 
as essential for implementing specific projects that could not have been achieved without 
the Fund, thus ensuring a common European response to migration and asylum challenges. 

5.1.5 

 Is the intervention still relevant (Relevance)? 

The  AMIF addresses evolving needs both at the time of Programme adoption and 
during  Programme  implementation.  A  proper  identification  of  stakeholders  to  be 
involved in the AMIF implementation ensured that relevant inputs on evolving needs to be 
addressed were taken into account. Also, AMIF allocated resources and implemented 
measures included in the legal basis were deemed relevant to address evolving needs.  

Moreover,  Thematic  Facility  Work  Programmes  have  demonstrated  a  clear  focus  on 
addressing  key  priority  needs  and  target  groups,  including  asylum  seekers,  third-
country  nationals  under  international  protection,  vulnerable  children,  unaccompanied 
minors and victims of trafficking of human beings.  

Overall,  limited  concerns  remain  regarding  whether  the  planned  milestones  and  targets 
remain proportionate or are apt to follow changes in the financial resources allocated to 
different Specific Objectives to address evolving needs.  

The evaluation has found that Member States can adapt their programmes to evolving 
needs,  especially  thanks  to  existing  financial  flexibility  mechanisms  under  the  Fund 
Regulation  and  Thematic  Facility.  Another  finding  refers  to  the  fact  that  the  needs 
assessment  performed  at  the  beginning  of  the  programme  is  not  regularly  and 
systematically  updated  during  programmes’  implementation.  This  could  undermine  the 
capability to fully and timely adapt to evolving needs. However, there is  evidence that 

68 

 
timely inputs on evolving needs during programme implementation are provided by 
stakeholders involved within the Monitoring Committee.   

Overall, the flexibility enshrined in the AMIF Regulation has allowed Member States to 
promptly  adapt  their  Member  State  Programmes  to  evolving  needs  during  the 
implementation phase (e.g. growing number of beneficiaries of temporary protection, due 
to the war situation in Ukraine). Also, the Thematic Facility has greatly helped to address 
emerging needs and emergency situations. However, some concerns remain regarding 
the flexibility of procurement procedures. Indeed, there is evidence of administrative 
barriers  across  Member  States  that  do  not  ensure  a  full  flexibility  of  procurement 
procedures preventing their swift adaption to evolving needs. 

5.2.  Lessons learned 

A reflection should take place with and between the Member States on the best practices 
and mechanisms to promote flexibility in programme and project management to respond, 
quickly  and  in  a  complementary  manner  to  the  Thematic  Facility  interventions,  to  the 
impact of external factors, such as the Russian war of aggression towards Ukraine or the 
COVID-19  pandemic,  which  can  then  cause  delays  and  complications  in  project 
implementation and eventually in the achievement of the programmes’ objectives. 

Internal administrative issues in certain Member States, such as insufficient allocation of 
human resources and lack of coordination between relevant actors, hindered the smooth 
implementation  of  AMIF.  Further  efforts  should  be  considered  to  promote  efficient 
internal  processes  and  ensure  smoother  implementation.  Similarly,  while  some  remedy 
strategies  were  implemented,  only  a  few  Member  States  had  identifiable  and  effective 
strategies in place to overcome the delays and challenges they faced. The Member States 
should  be  encouraged  and  supported  in  developing  and  documenting  comprehensive, 
proactive remedy strategies for addressing challenges.  

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 for better attracting and supporting more small beneficiaries and Civil 
Society Organisations, which currently have difficulties accessing the AMIF funding due 
to  their  lack  of  experience  with  EU  funding  and  co-financing  requirements.  It  is  worth 
considering  providing  targeted  support  to  smaller  organisations  with  application 
procedures  for  EU  funding,  encouraging  Member  States 
inclusive 
communication  on  funding  opportunities  and  introducing  additional  capacity  building 
measures for smaller organisations.  

to  ensure 

Another avenue that could be explored to broaden the spectrum of AMIF beneficiaries to 
smaller organisations relates to the establishment of dedicated financial instruments (e.g. 
loans, guarantees, microcredit).  

There  is  a  window  of  opportunity  for  the  Member  States  to  further  involve  certain 
categories of partners  in  the implementation  of the AMIF programmes,  for example by 
launching  regular  calls,  throughout  the  programming  period,  for  Civil  Society 
Organisations and local/regional authorities to participate in the Monitoring Committees. 
Consideration could also be given to alternative consultation mechanisms for organisations 
unable to commit to roles in the Monitoring Committees, due to resource constraints. 

69 

 
There is a need to reinforce the understanding of the performance framework of the AMIF 
Regulation and its potential benefits. 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 how 
to improve the target setting, as well as to 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 how the performance framework can contribute to the management of the 
Member States programmes, beyond the purely  formal reporting that is required by the 
AMIF Regulation. 

This is a precondition to an improvement in quality of the performance monitoring 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 on the reporting of 
implementation  data  and  provide  ad  hoc  recommendations  to  ensure  the  quality, 
consistency and reliability of the information on performance. 

Promoting  digitalisation  and  automatisation  for  the  collection  and  submission  of 
information and providing targeted training to the final beneficiaries of the AMIF support 
could help to streamline and simplify the application of monitoring requirements. 

There  is  potential  room  for  further  simplification,  using  the  possibilities offered  by  the 
CPR to facilitate administration and implementation. It is worth, for the Commission and 
the Member States, continuing to support the use of simplified cost options, such as flat 
rates,  lump  sums,  and  unit  costs,  to  minimise  administrative  overhead,  especially  for 
smaller projects and routine expenses.  

While many Member States have communication strategies in  place, they are often not 
elaborated in detail. This lack of specificity can hinder the effectiveness of communication 
efforts.  The  Member  States  could  make  better  use  of  the  guidance  and  toolboxes  on 
communication and visibility requirements provided for the CPR funds. 

Clarity concerning cooperation between and within national authorities could be improved. 
Although inter- and intra-agency cooperation at national level is widely reported across 
Member  States,  many  countries  provide  limited  or  vague  details  regarding  how 
cooperation is managed. This limits the evaluation of cooperation to ensure coherence and 
consequently the establishment of possible best practices. 

Finally, coordination with the other Union Funds could be further reinforced. Particularly 
in  regard  to  external  spending  programmes,  such  as  the  NDICI,  and  in  view  of  the 
implementation of the Pact on Migration and Asylum. At national level, mechanisms that 
ensure an appropriate awareness of the possibilities offered by other Funds of the Union 
would contribute to a more efficient planning and design of the interventions. 

70 

 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

This  evaluation  has  been  implemented  by  DG  HOME,  as  responsible  for  the 
implementation of AMIF in the Commission. The evaluation was launched in 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 Fund when carrying out the evaluation, and the limited 
evidence available in terms of effectiveness of the Fund, 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, DG TRADE, JRC, 
SJ, DG ECHO, DG EMPL, and OLAF. 

The first meeting of the Interservice Group was held on 30 June 2023, where the group 
discussed  the  actions  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 8 March 2024, 3 May 2024, 9 September 2024 
and 18 November 2024. The draft version of this Staff Working Document was submitted 
to the group for written consultation on 17 December 2024. 

The  preparatory  study  was  confided  to  a  consortium  made  up  of  EY  Germany  and 
Technopolis Group following an open call for tender launched on 3 October 2023. The 
contract was signed on 7 March 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 for its 
meeting of 12 February 2025. 

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

The RSB identified the following key issues: 

1)  While  acknowledging  limitations  and  data  gaps,  the  report  is  not  sufficiently 
underpinned  with  evidence  and  analysis,  given  the  degree  of  financial 
implementation. The report does not sufficiently analyse the significant variations 
in implementation among the member States. It is not clear what is the baseline and 

71 

 
points of comparison regarding the achievement of the objectives, considering the 
absence of the final evaluation of the Fund’s previous programming period 2014-
2020.  

2)  The report does not sufficiently assess the intervention logic. It is also not clear 
whether the evaluation and monitoring framework in place will allow for drawing 
conclusions in the final evaluation of the programme.  

3)  The report does not sufficiently analyse administrative costs.  

4)  The  assessment  of  coherence  with  the  Pact  on  Migration  and  Asylum  and  with 
other  EU  funds  is  not  sufficient.  The  report  does  not  sufficiently  assess  the 
additionality  of  the  AMIF  to  broader  efforts  of  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.  

in 

report 

costs 
and 

RSB Comment 
should  more 
The 
systematically refer to the existing 
evidence  base  and  integrate  more 
elements  from  the  support  study 
and  case  studies.  With  roughly 
EUR 3 billion allocated and EUR 1 
billion  spent,  the  report  should 
integrate  more  data  on  outputs, 
the 
results 
and 
effectiveness 
efficiency 
analysis. 
The  conclusions,  in  particular  on 
effectiveness 
efficiency, 
and 
should be more nuanced and better 
aligned  with 
evidence 
available.  
Reporting on progress in financial 
implementation is not sufficient as 
evidence  of  effectiveness  and 
efficiency, and to allow to conclude 
that  the  programme  is  on  track  to 
achieve its objectives.  

the 

Follow-up 
References  to  the  evidence  from  which  findings 
and conclusions are drawn have been consistently 
reinforced  through  the  document.  For  example, 
details on the ECA’s perception of the suitability 
of  the  monitoring  and  evaluation  framework  has 
been added to section 4.1.1 Effectiveness.  

This has been applied through the report.  

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  Fund  to  draw 
significant 
information  on  effectiveness  and 
efficiency for the remainder of the funding period. 
This  assumption  was  acknowledged  and  agreed 
with the ISG at the start of the preparatory work 
for this evaluation. 

The  progress  in  financial  reporting  has  not  been 
considered  in  the  evaluation  as  evidence  of 
effectiveness.  Rather  the  progress  in  financial 
implementation  demonstrates  the  high  level  of 
needs from the target groups and that projects are 

72 

 
 
 
 
 
RSB Comment 

The  report  should  deepen 
the 
analysis  of  how  the  situation  was 
to  evolve  and  how 
expected 
progress 
attaining 
towards 
objectives is measured and against 
what baseline. 
The  mid-term  evaluation  report 
2021-2027 
into 
should 
account  the  results  of  the  final 
evaluation 2014-2020.  

take 

Follow-up 
being implemented efficiently from an operational 
point of view.  

Additional  information  has  been  provided  in  the 
section 2.2 on points of comparison, regarding the 
performance framework and the way of measuring 
progress. 

the 

the 

amounts 

As explained in the revised version (section 2.2): 
“It should be noted that the ex-post evaluation was 
ongoing and at a preliminary stage at the time of 
writing this Staff Working Document, hence final 
results regarding the ex post evaluation are not yet 
available to serve as a basis of comparison. As a 
response to the Russian war of aggression against 
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 
2014-2020 
under 
unspent 
programmes. 
final 
Accordingly, 
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 implementation as a continuum. This has 
allowed  to  have  retrospective  view,  as  well  as 
complying  with  the  requirement  in  the  AMIF 
regulation (78)  to  take  into  account  the  results  of 
the  retrospective  evaluation  for  the  2014-2020 
period. 
In  addition,  serving  as  best  available  data,  the 
findings from the interim evaluation of the AMIF 
2014-2020 programming period from 2018 as well 

(78)  Article 
http://data.europa.eu/eli/reg/2021/1147/oj ) 

34(1) 

of 

the  AMIF  Regulation 

(OJ  L 

251, 

15.7.2021, 

p. 

1,  ELI: 

73 

 
 
 
Follow-up 
as data from SFC2014 for implementation of the 
AMIF  2014-2020  up  until  the  end  of  2017  have 
been  used  as  a  point  of  comparison.79  Notably, 
since  SFC2014  contains  annual  data  for  the 
implementation,  the  considered  implementation 
period for the AMIF 2014-2020 is 6 months longer 
than the available data for the present evaluation, 
which covers an implementation period up until 30 
June  2024.  Therefore,  caution  must  be  applied 
with regard to the interpretation of comparisons of 
the progress made.” 
Additional  information  has  been  provided  on 
output indicators in section 4.1.1.  
The intervention logics have been moved from the 
annexes  to  the  main  report.  The  details  of  the 
intervention  logic  have  been  expanded  upon  in 
section 2.2. 

Additional  information  has  been  provided  in  the 
section 2.2 on points of comparison, regarding the 
performance framework and the way of measuring 
progress. 

This has been reinforced in sections 2.2 and 4.1.1. 
Furthermore, 
list  of  common 
indicators  has  been  added  to  Annex  II  for 
reference.  

the  complete 

This has been reinforced in sections 2.2 and 5.2. 
The  reasons  behind  the  different  degrees  of 
implementation 
is 
described  in  section  3  within  the  limits  of  the 
information available at this time.  

among  Member  States 

RSB Comment 

financial 
Beyond  documenting 
progress,  the  report  should  make 
use of available data on outputs and 
results  to  analyse  effectiveness, 
logic  and  provide 
intervention 
preliminary  assessment  of  causal 
links. 
The report should describe in more 
detail 
and 
the  monitoring 
evaluation framework in place and 
assess the extent to which the data 
collected  will  make  it  feasible  to 
evaluate  the  achievement  of  the 
programme’s objectives in the final 
evaluation.  
include  an 
The  report  should 
overview  of  indicators,  points  of 
2024  milestones, 
comparison, 
the 
baselines 
quantified 
indicators and correlate them with 
what should be considered success. 
It should be explicit about data and 
information  that  Member  States 
provide  in  their  regular  reporting 
and identify any issues or gaps that 
would  need  to  be  addressed.  It 
should  also  assess  the  reasons 
behind  the  different  degrees  on 
implementation  among  Member 
States.  
Beyond  acknowledging  that  there 
is 
improvement  of 
monitoring,  the  lessons  learned 
should include potential changes to 

room 

for 

for 

79  The  2018  Interim  evaluation  has  been  conducted  at  roughly  the  same  point  in  time  during  the 
implementation phase as the present mid-term evaluation. The data that informed the 2018 Interim evaluation 
comprises an implementation period up until 30 June 2017, corresponding to the data used for the present 
mid-term evaluation which includes implementation up until 30 June 2024.  

74 

 
 
RSB Comment 
the 
reporting  system  and 
the 
established  indicators  in  order  to 
ensure  the  effective  assessment  of 
the  fund’s  progress  in  the  final 
evaluation. 
The  report  should  provide  more 
details on administrative costs and 
their assessment 

for 

and 

It  should  analyse  to  what  extent 
different  stakeholders'  perceptions 
of  complexity  and  cumbersome 
reporting  are  valid  and  assess  the 
improvement, 
potential 
burden 
simplification, 
reduction. 
Given 
the  current  degree  of 
implementation,  the  report  should 
analyse  the  types  of  costs  and 
provide underlying methodology 
The  coherence  assessment  should 
better  explain  the  extent  to  which 
the  programme  is  aligned  with 
other EU funds (in particular, RFF, 
ESF and NDICI) and with the Pact 
on Migration and Asylum 
The report should assess better how 
the  AMIF 
has 
addressed  emerging  needs  and 
identified evolving ones instead of 
relying  on  elements  related  to  the 
previous programming period. 
As  regards  EU  added  value,  the 
report should also be clear in terms 
of  the  additionality  of  AMIF  to 
funded  by  Member 
measures 
States, analyse any data gaps which 

2021-2027 

Follow-up 

of 

and 

limitations 

Text was added in section 4.1.2 expanding on the 
challenges 
assessing 
administrative costs. 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  funding 
recipients. Data on financial implementation is not 
connected  to  the  performance  indicators  the 
Managing  Authorities  need  to  report  on.  As  a 
result,  the  cost  benefit  analysis  of  the  financial 
investment is rather limited. Some more in-depth 
work should be possible during the future ex-post 
evaluation of these instruments, once information 
becomes  more  complete  and  work  on  unit  costs 
can be developed.  
This has been reinforced in section 4.1.2, and the 
cost-
limits 
effectiveness at this point in time were clarified.  

conclusions  on 

to  drawing 

See the previous two comments. 

This  has  been  reinforced 
in  section  4.1.3, 
including  further  analysis  on  coherence  with  EU 
external policy.  
The  relevance  of  the  AMIF  with  the  Pact  on 
Migration and Asylum has been added to section 
4.3. 
This was reinforced in section 4.3. with more on 
the  use  of  flexibilities  to  adapt  Member  State 
programmes to emerging needs. 

This was reinforced in section 4.3 with examples 
of  how  AMIF  resources  expanded  the  scope  of 
services and scaling up projects in Member States.  
toolbox, 
the  Better  Regulation 
Following 
general 
by 
additionality  was 

covered 

75 

 
 
RSB Comment 
could  hamper 
additionality 
evaluation.  

the  analysis  of 
final 
in 

the 

Follow-up 
considerations regarding the added value; the item 
was  not  part  of  the  Terms  of  Reference  for  this 
evaluation, as Member States are not requested to 
provide 
the 
in 
Commission. 

this  respect 

information 

to 

76 

 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

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

Methodology  

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

The inception phase was characterised by preparing the work to be done. This included 
preliminary  desk  research,  scoping  interviews  with  officials  from  the  Commission, 
stakeholder mapping, 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 data collection phase focused on gathering data by by 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, mapping the 
allocations  by  type  of  intervention  and  target  group,  launching  a  targeted  survey  and 
conducting  interviews  and  a  focus  group.  This  phase  concluded  with  an  interim  report 
which was discussed with the Steering Group, revised and then accepted.  

During the analysis phase the contractors focused on analysing the data collected to draw 
conclusions for the evaluation questions. During this phase the contractors held the second 
EU level focus group 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  relied  upon  reviewing 
approximately 125 documents including evaluation reports at the EU and national level, 
the annual performance reports submitted in 2023 and 2024, notes to the Home Affairs 
Funds  Committee,  regulatory  and  policy  frameworks,  grey  literature  and  academic 
publications.  

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

Regarding the consultation activities, 90 interviews were completed during the course of 
the study. The interviews included scoping interviews and semi-structured interviews to 
gather data for the analysis, including the country case studies and thematic case studies.  

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 

77 

 
 
Authorities  and  project  beneficiaries.  The  focus  group  focused  on  understanding  the 
challenges encountered, good practices, and policy issues affecting the achievement of the 
AMIF specific objectives.  

The second level focus group was held on 12 December 2024 and consisted of Commission 
officials, Managing Authorities, and the European Union Agency for Fundamental Rights. 
The objective of the focus group was to validate the evaluation findings and further develop 
the lessons learned.  

In  addition  to  the  focus  groups,  four  targeted  surveys  were  launched  to  target  various 
stakeholders. Of the 419 surveys completed, 37 were from National/Managing Authorities 
and 382 were from beneficiaries. The results of the survey fed into the main analysis.  

The study included seven country case studies (DE, FR, IT, EL, PL, RO, and LT) to dive 
deeper  into  the  implementation  of  AMIF  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 the horizontal priorities. The thematic case studies allowed 
for deep-dives into certain aspects of the AMIF 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. 

Limitations and mitigation measures 

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

First, there were several limitations concerning the data which particularly impacted the 
analysis of effectiveness and efficiency. First, the level of granularity of the data differed 
across management modalities. Similarly, the heterogeneity of data varied across the fund 
components and management modes due to varying arrangements and monitoring systems. 
For example, the data on resources paid for Union Actions was excluded from the financial 
analysis as the resources paid do not accurately reflect the progress of the work done.  

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

In  addition,  the  Member  State  mid-term  evaluations  and  target  setting  methodologies 
displayed varying levels of quality and depth. Similarly, the APRs demonstrated varying 
levels of completeness and consistency. Finally, the data on output and result indicators 
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 

78 

 
 
Supporting information, tables and figures 

The following section presents additional information, large tables and diagrams that are 
referenced in the main report. 

AMIF 2021-2027 Structure 

The  AMIF  budget  is  implemented  through  Member  States  Programmes  and  Thematic 
Facility Work Programmes. 

The Member States programmes absorb around two thirds of the AMIF budget and cover 
a period of seven years (2021-2027). The interventions included in the programmes are 
programmed and implemented by the Member States, with the Commission mainly acting 
in  an  advisory  role.  The  programmes  are  formally  approved  by  the  Commission  and 
managed  in  shared  responsibility  between  the  Member  States  and  the  Commission 
(“shared management”). 

The  Thematic  Facility  Working  programmes  are  multiannual.  During  the  2021-2027 
programming period there three Work Programmes are foreseen, respectively covering the 
years  2021-2022,  2023-2025  and  2026-2027.    The  interventions  under  the  work 
programmes are programmed by the Commission. These interventions are implemented 
by the Commission (“direct management”), or by international bodies acting on behalf of 
the  Commission  (“indirect  management”)  or  by 
the  Member  States  (“shared 
management”). 

The components of the Thematic Facility Work Programmes are the following: 

-  Specific Actions: transnational or national projects that bring Union added value 
in line with the objectives of the Fund for which one, several or all Member States 
may receive an additional allocation to their programmes; 

-  Union Actions: transnational projects or projects of particular interest to the Union 

implemented in accordance with the objectives of the Fund; 

-  Resettlement:  the  admission  following  a  referral  from  the  UNHCR  of  third-
country nationals or stateless persons from a third country to which they have been 
displaced, to the territory of the Member States, and who are granted international 
protection  and  have  access  to  a  durable  solution  in  accordance  with  Union  and 
national law; 

-  Humanitarian  Admission’  the  admission  following,  where  requested  by  a 
Member State, a referral from the European Asylum Support Office (EASO), the 
United Nations High Commissioner for Refugees (‘UNHCR’), or another relevant 
international  body,  of  third-country  nationals  or  stateless  persons  from  a  third 
country to which they have been forcibly displaced to the territory of the Member 
States, and who are granted international protection or a humanitarian status under 
national law that provides for rights and obligations equivalent to those of Articles 
20 to 34 of Directive 2011/95/EU for beneficiaries of subsidiary protection; 

-  Relocation: the transfer of applicants or beneficiaries of international protection 
from another Member State in accordance with Article 17 of Regulation (EU) No 

79 

 
604/2013  of  the  European  Parliament  and  of  the  Council  (36)  or  as  a  result  of 
similar forms of relocation; 

-  Emergency  Assistance  (EMAS):  the  Fund  shall  provide  financial  assistance  to 
address urgent and specific needs in the event of duly justify emergency situations 
resulting  from  one  or  more  of  the  cases  described  in  Article  31(1)  of  AMIF 
Regulation (EU) 2021/1147). 

List  of  common  output  and  result  indicators  (cp.  Annex  VIII  of  the  AMIF 
Regulation) 

Output indicators 

Indicator code  Indicator name 

O.1.1 

O.1.2 

O.1.3 

O.1.4 

Number of participants supported 

Number of participants in training activities 

Number of newly created places in reception infrastructure in line 
with Union acquis 

Number of renovated/refurbished places in reception infrastructure in 
line with Union acquis 

O.2.1 

Number of participants in pre-departure measures 

80 

 
 
 
Indicator code  Indicator name 

O.2.2 

O.2.3 

O.2.4 

O.2.5 

O.2.6 

O.2.7 

O.3.1 

O.3.2 

O.3.3 

O.3.4 

O.3.5 

O.4.1 

O.4.2 

Number of local and regional authorities supported to implement 
integration measures 

Number of participants supported 

Number of information packages and campaigns to raise awareness of 
legal migration channels to the Union 

Number of participants receiving information and/or assistance to 
apply for family reunification 

Number of participants benefitting from mobility schemes 

Number of integration projects where local and regional authorities 
are the beneficiary 

Number of participants in training activities 

Number of equipment purchased, including number of ICT systems 
purchased / updated 

Number of returnees who received re-integration assistance 

Number of places in detention centres created 

Number of places in detention centres refurbished/renovated 

Number of staff trained 

Number of participants who received pre-departure support 

Source: Regulation (EU) 2021/1147, Annex VIII. 

Result indicators 

Indicator code  Indicator name 

R.1.5 

R.1.6 

R.1.7 

R.2.8 

Number of participants who consider the training useful for their work 

Number of participants who report three months after the training 
activity that they are using the skills and competences acquired during 
the training 

Number of persons placed in alternatives to detention 

Number of participants in language courses who have improved their 
proficiency level in the host-country language upon leaving the 

81 

 
 
Indicator code  Indicator name 

language course by at least one level in the Common European 
Framework of Reference for Languages or national equivalent 

R.2.9 

R.2.10 

Number of participants who report that the activity was helpful for 
their integration 

Number of participants who applied for their qualification or skills 
acquired in a third country to be recognised / assessed 

R.2.11 

Number of participants who applied for a long-term residence status 

R.3.6 

R.3.7 

R.3.8 

R.4.3 

R.4.4 

R.4.5 

Number of returnees voluntarily returned 

Number of returnees who were removed 

Number of returnees subject to alternatives to detention 

Number of applicants for and beneficiaries of international protection 
transferred from one Member State to another 

Number of persons resettled 

Number of persons admitted through humanitarian admission 

Source: Regulation (EU) 2021/1147, Annex VIII. 

82 

 
 
 
Table 1: Overview of how Member States Programmes address the needs identified in the intervention logic 

Specific Needs (IL)  

AT   BE   BG   CY   CZ   DE   EE   EL   ES   FI   FR   HR   HU   IE   IT   LT   LU   LV   MT   NL   PL   PT   RO   SE   SI   SK  

S01 - CEAS  
Insufficient provision of 
material aid  
Insufficient availability of beds 
in reception facilities in line 
with the Union acquis   
Room for enhancing 
effectiveness of identifying 
vulnerable groups and the 
provision of tailor-made 
services to these groups during 
reception  
Room for strengthening staff 
skills to effectively implement 
Union acquis relating to 
reception  
Gaps between reception and 
further social inclusion  
Wide use of detention, 
including for vulnerable 
groups  
Delays and backlogs in the 
processing of requests for 
asylum  
Room for enhancing support to 
asylum seekers in relation to 
asylum procedures, including 
e.g. in relation to knowledge 
on rights and procedures as 
well as specialised services for 
vulnerable groups  
Need to ensure continuous 
monitoring and evaluation to 
generate a complete 
understanding of the 

83 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Specific Needs (IL)  

AT   BE   BG   CY   CZ   DE   EE   EL   ES   FI   FR   HR   HU   IE   IT   LT   LU   LV   MT   NL   PL   PT   RO   SE   SI   SK  

effectiveness of existing 
practices   
Room for enhancing processes 
for the implementation of 
humanitarian admission of 
existing practices  
Varying quality of protection 
systems in third countries, with 
implications on migration flows 
into the EU and the adherence 
to fundamental rights  
S02 - Legal Migration  
Insufficient information for 
TCNs on the complex EU policy 
framework on legal migration  
Mobility obstacles for TCNs 
including based on an 
inconsistent implementation of 
the rules of family reunification 
for TCNs staying for specific 
purposes  
Incomprehensive use of the 
potential cooperation with 
TCs   
Barriers relating to the 
effective integration of TCNs 
into receiving societies, 
including e.g. based on 
insufficient access to 
supporting services, language 
barriers  
Insufficient support for TCNs 
integration needs after arrival  
Integration authorities need to 
be further strengthened to deal 
with the current workload   

S03 - Irregular migration  

84 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Specific Needs (IL)  

AT   BE   BG   CY   CZ   DE   EE   EL   ES   FI   FR   HR   HU   IE   IT   LT   LU   LV   MT   NL   PL   PT   RO   SE   SI   SK  

Potential to enhance 
effectiveness and efficiency of 
returns   
Potential to enhance re-
integration support in the EU 
and in TCs   
Need to deter and counter 
irregular migration and better 
inform about the legal 
migration routes and risks of 
irregular migration  
Shortcomings relating to the 
conditions returnees face 
ahead of their return, including 
in relation to accommodation 
and preparatory measure  
S04 - Solidarity and Cooperation  
Disproportionate/high 
migratory pressures across MS 
with room for enhancing the 
use of tools to balance these   
Disproportionate/high 
migratory pressures in TCs 
facing challenges to 
accommodate TCNs  
Insufficient support to MS 
registering a comparably high 
number of TCNs   
Source: national mid-term evaluations  

85 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 2: Progress and methodology thematic case studies 

Case study   Purpose and scope of the case study 

Progress and methodology 

Union 
Actions 

The purpose of the UA case study  report is specifically 
focused on the implementation of Union Actions, 
aiming to evaluate them on the basis of effectiveness, 
efficiency, relevance, coherence and EU added value. 

A Union Actions database was consolidated and analysed along agreed selection 
criteria, following which a long list was submitted to DG HOME and a short-list 
of 6 projects agreed.80 The case was developed using desk research and in-
depth interviews with beneficiaries, supplemented by relevant information from 
the targeted survey and semi-structured interviews conducted in other activities 
of the mid-term evaluation. 

EMAS 

Ukraine 

The purpose of the EMAS thematic case was to explore 
what types of activities have been implemented so far 
under the funding component, their outputs and results, 
and  the  implementation  experiences  of  a  selection  of 
beneficiaries  to  identify  lessons  for  future  EMAS 
projects. 

The Emergency Assistance projects were analysed using agreed selection 
criteria agreed with DG HOME, resulting in a longlist and a final shortlist of 4 
projects.81 The case was developed using desk research and in-depth interviews 
with beneficiaries, supplemented by relevant information from the targeted 
survey and semi-structured interviews conducted in other activities of the mid-
term evaluation. 

The aim of the Ukraine thematic case was to take a 
horizontal perspective and examine the adjustments 
made to the AMIF 2021 – 2027 period, focusing on the 
funding components UA, EMAS and SA. Specifically, 
this case explores the actions implemented, effects, 

The Ukraine projects were analysed using agreed selection criteria agreed with 
DG HOME, resulting in a longlist and a final shortlist of 3 projects.82 The case 
was developed using desk research and in-depth interviews with beneficiaries, 
supplemented by relevant information from the targeted survey and semi-
structured interviews conducted in other activities of the mid-term evaluation. 

for  EMAS  2021  –  2027:  Urgent 

80 SAFE HUT- Holding safe spaces for women and girls’ empowerment; Migration Partnership facility (MPF IV), Targeted support to key protection activities in Greece; Women-centred 
Intervention for Social Entrepreneurship Resilience; Fostering inclusion of LGBTQI+ migrants at local level; Strengthening guardianship in the EU through capacity building, knowledge 
exchange and peer learning; Service and support management of the European website on integration 
81  Shortlist  of  projects 
from  Belarus, 
HOME/2021/AMIF/AG/EMAS/TF1/LT/0002; EU support through IOM to the Italian Ministry of Interior to ensure adequate reception conditions during emergencies and the safe and 
dignified transfer of migrants landed in Lampedusa to other reception centres in Italy (Su-Port), HOME/AMIF/CA/EMAS/TF2/IT/0018; Support for refugees from Ukraine at the initial 
stage  of  admission  to  Poland,  HOME/2022/AMIF/AG/EMAS/TF1/PL/0008;  Support  for  refugees  from  Ukraine  at  their  admission  and  early  integration  in  Poland, 
HOME/2022/AMIF/AG/EMAS/TF1/PL/0011;  Adoption  of  emergency  measures  against  the  increase  in  arrivals  of  migrants  and  refugees  at  the  Ceuta  coast  and  border  of  Spain, 
HOME/2021/AMIF/AG/EMAS/TF1/ES/0001 
82 Shortlist of projects Ukraine 2021 – 2027: The transition from emergency assistance to social sustainability and autonomous inclusion of Ukrainian refugees into Romanian society, 
AMIF/2023/SA/1.2.3/03; SAFE HUT- Holding safe spaces for women and girls’ empowerment, AMIF-2022-AG-CALL-THB; Support for refugees from Ukraine at the initial stage of 
admission to Poland, HOME/2022/AMIF/AG/EMAS/TF1/PL/0008   

third-country  nationals 

to  disproportionate 

to  Lithuania 

influx  of 

response 

86 

 
 
 
Case study   Purpose and scope of the case study 

Progress and methodology 

Specific 
Actions 

and implementation experiences of beneficiaries active 
in projects which focus on Ukraine. 

The purpose of the Specific Action case study report is 
specifically focused on the implementation of Union 
Actions, aiming to evaluate them on the basis of 
effectiveness, efficiency, relevance, coherence and EU 
added value. 

Horizontal 
priorities 

The selection of Specific Action Calls for the in-depth review was performed in 
two steps. First, the Study Team assessed the Specific Action Calls awarded in 
both programming period according to selection criteria (e.g. scope of Specific 
Actions, relevance of the topic, coverage of Specific Objectives), resulting in a 
long-list and a final selection of Calls. The case study analysis was performed 
by triangulating desk and field sources. However, since the availability of desk 
documents on the ongoing selected projects was highly limited, the analysis 
relies mostly on feedbacks collected through targeted interviews with 
beneficiaries.   

The  evaluation  team  identified  seven  projects  for  the  HP  case  study  based  on 
relevance, start date, value, and replicability. These projects were selected from 
EC  databases  (UA,  SA,  EMAS)  and  ongoing  list  of  projects  under  the  MS 
Programmes, published on the official websites. By November 6, four interviews 
with  seven  participants  were  completed:  two  UA  projects  (three  participants), 
one  SA  project  (two  participants),  and  one  MS  Programmes  project  (two 
participants).  The 
replicable 
methodologies. 

findings  highlight 

learned  and 

lessons 

87 

 
 
 
 
 
ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Effectiveness 

Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

EQ1: To what extent is 
the Fund on track to 
achieving its 
operational and specific 
objectives? 

Implementation has 
started with operations 
selected for support of the 
MS Programmes under 
relevant specific objectives 
and types of intervention, 
except where a delayed 
start was planned by 
design or adequately 
justified 

The early progress 
towards the achievement 
of the set milestones and 
target values, taking into 
account the timing for the 
adoption of the fund, is in 
line with the planning (or 
delays and changes can be 
adequately explained and 
justified) 

Share of operations planned that have been 
started or completed out of the total number of 
operations planned at MS Programme level  

Reasons /justifications for delays relating to the 
implementation of selected operations in MS 
Programmes 

Semi-structured 
interviews  
Targeted survey  
Country case studies 

Share of the following result indicators for 
which actual progress is aligned with the 
targets planned: 
R.1.5 Number of participants who consider the 
training useful for their work 
R.1.6 Number of participants who report three 
months after the training activity that they are 
using the skills and competences acquired 
R.1.7 Number of persons placed in alternatives 
to detention 
R.2.8 Number of participants in language 
courses who, upon leaving the language course, 
have improved their proficiency level in the 
host-country language by at least one level in 
the Common European Framework of Reference 
for Languages or national equivalent 

88 

Mid-term national 
evaluations (where 
available) 

Mid-term national 
evaluations (where 
available) 
Annual Performance 
reports 

SFC2021 

 
 
 
  
 
 
 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

R.2.9 Number of participants who report that 
the activity was helpful for their integration 
R.3.6  Number of returnees voluntarily 
returned 
R.3.7  Number of returnees who were removed 
R.3.8  Number of returnees subject to 
alternatives to detention 
R.4.3  Number of applicants for and 
beneficiaries of international protection 
transferred from one Member State to another 
R.4.4  Number of persons resettled 
R.4.5  Number of persons admitted through 
humanitarian admission 
*This analysis can be extended to common 
indicators for which targets and milestones 
exists such as: 
New, renovated or refurbished places in 
reception infrastructure are created in 
accordance with Union acquis 
Support services are available for TCNs, 
including qualified psycho-social and 
rehabilitation services 
Suitable training offers for staff dealing with 
asylum seekers are implemented 
Services for TCNs reflect any special needs, 
including information on rights, legal 
assistance, translation and interpretation 
assistance 
TCNs are placed in alternatives to detention 
instead of detention wherever possible 
Staff participates in the training and uses it in 
their daily work 
Information packages and campaigns to raise 
awareness of legal migration channels to the 
Union are developed 
Mobility schemes are established or developed, 
including measures to enhance employability  

89 

 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

Participants receive information or assistance in 
applying for family reunification 
Pre-departure support for TCNs is developed 
and implemented in cooperation with TCs 
Rejected asylum applicants are returned / 
removed to their TCs 
Equipment for monitoring is purchased, 
including ICT systems or other tools to monitor 
return operations 
Persons are admitted through humanitarian 
admission schemes 
MS with high number of applicants for 
international protection benefit from relocation 
schemes 
Applicants for and beneficiaries of international 
protection are transferred from one Member 
State to another 
Progress towards the output indicators  
e.g.: output/ result indicators:  
O.1.1  Number of participants supported 
O.1.2  Number of participants in training 
activities 
O.1.3  Number of newly created places in 
reception infrastructure in accordance with 
Union acquis 
O.1.4  Number of renovated or refurbished 
places in reception infrastructure in accordance 
with Union acquis 
O.2.1  Number of participants in pre-departure 
measures 
O.2.2  Number of local and regional authorities 
supported to implement integration measures 
O.2.3  Number of participants supported 
O.2.4  Number of information packages and 
campaigns to raise awareness of legal migration 
channels to the Union 

90 

SFC 2021 

 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

O.2.5  Number of participants receiving 
information or assistance in applying for family 
reunification 
O.2.6  Number of participants benefitting from 
mobility schemes 
O.2.7  Number of integration projects where 
local and regional authorities are the beneficiary 
O.3.1  Number of participants in training 
activities 
O.3.2  Number of equipment purchased, 
including number of ICT systems purchased or 
updated 
O.3.3  Number of returnees who received 
reintegration assistance 
O.3.4  Number of places in detention centres 
created 
O.3.5  Number of places in detention centres 
refurbished or renovated 
* A factorial analysis can be performed to 
reduce the number of indicators to be used 

Share of activities supported via the Thematic 
Facility that have started per area 

Share of projects implemented under direct and 
indirect management for which actual progress 
is aligned with the planned milestones and 
targets  
Reasons /justifications for delays relating to the 
implementation of selected operations 
Share of consulted stakeholders that consider 
the Union Actions support is effective, e. g in 
supporting the Member States capacity to 
manage the migration crises and enhance the 
cooperation with Third countries 

91 

Operations supported via 
the Thematic Facility have 
started in all areas 

There is not significant 
delay in the start and 
implementation of projects 
in direct and indirect 
management 

The Union Actions 
supported are effective in 
achieving / progressing 
towards their aims 

Semi-structured 
interviews 
Thematic case studies 

Semi-structured 
interviews 
Thematic case studies 

Project mapping (Long 
list of Thematic facility) 

Project mapping (Long 
list of Thematic facility) 

Semi-structured 
interviews 
Thematic case  
Targeted survey 

 
  
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

Challenges that affect 
implementation and the 
progress towards the 
objectives of the Fund are 
duly identified and linked 
with effective remedy 
strategies 

The Fund makes use of 
available good practices 
where relevant and 
possible 

The extent to which internal/external factors 
(positive and negative) influenced the progress 
towards the achievement of target values 

The extent to which remedy strategies were 
duly identified and effective in mitigating the 
effects of the challenges face (considering MS 
Programmes, Thematic Facility)  
Share of consulted stakeholders that consider 
the strategies implemented were effective in 
addressing the challenges that influenced the 
implementation 

The extent to which the MS Programmes make 
use of good practices (e.g. integration 
programs, innovation learning solutions, youth 
inclusion, building partnership between public 
authorities, CSOs), and other stakeholders to 
ensure a multi-disciplinary and coordinated 
approach to migrant and refugee assistance) 
The extent to which Union Actions made use of 
good practices, e.g. integration programs, 
youth inclusion, building partnership between 
public authorities from multiple countries to 
ensure a multi-disciplinary and coordinated 
approach to migrant and refugee assistance 
The extent to which Emergency Assistance 
actions make us of good practices (e.g. rapid 
response teams, legal advisory services, multi-
language information dissemination) 

92 

Targeted survey  
Semi-structured 
interviews 
Country case studies  
Thematic case studies  

Targeted survey  
Semi-structured 
interviews   
Country case studies 
Thematic case study  

MS Programmes 
Annual Performance 
reports 
Mid-term nation 
evaluations (where 
applicable) 
Thematic Facility Work 
Programmes 

Thematic Facility Work 
Programmes 
Annual Performance 
reports (in case of the 
MS who reported on this 
topic) 
Mid-term national 
evaluations (where 
applicable) 

Country case studies 
Targeted survey  

Member States 
Programmes 

Thematic case studies  
Targeted survey  

Thematic case studies 
Targeted survey  

 
 
 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

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

A reliable electronic data 
exchange system 
(especially between 
Managing Authorities/ 
Intermediate Bodies and 
beneficiaries) for recording 
and storing data for 
monitoring and evaluation 
is in place  
The data provided by the 
MS are reliable 

The reporting on output 
and result indicators 
correctly reflects the level 
of implementation on the 
ground (not 
over/underreporting)  

Monitoring requirements 
are duly understood by the 
actors involved in the data 
supply process and 
training or info-sessions 
are organised where 
relevant 

The common indicators 
capture the main 
achievements of the fund 
in line with the 
intervention logic of the 
fund 

Fund specific indicators 
are used to fill any 

The extent to which the data reported by 
Member States reflets the current level of 
implementation of the MS Programmes  

Semi-structured 
interviews  

Target setting 
methodologies (of 
certain countries) 
SFC 2021 (data 
validation checks 
(quantitative analysis) 

Share of consulted stakeholders that consider 
data reported by Member States reflets the 
current level of implementation of the MS 
Programmes 
The extent to which guidance is easy to access, 
including written instructions/ guidelines, 
trainings or info-sessions 
Extent to which support, and guidance is 
considered useful by stakeholders   

Targeted survey  
Semi-structured 
interviews  
Country case studies 

Semi-structured 
interviews  
Country case studies 

Target setting 
methodologies (of 
certain countries) 
Available information on 
support and guidance  

The extent to which all relevant components of 
the LoI are captured either by the common 
indicators or by fund specific indicators 
Share of stakeholder that consider that all 
relevant components of the LoI are linked with 
monitoring indicators 

Semi-structured 
interviews  
Evaluation team analysis 
based on the validated 
versions of the LOI 

93 

 
 
 
  
 
 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

substantial gap in the 
common indicators based 
on the intervention logic of 
the fund   
The overall arrangements 
are sufficient evidence to 
be used as a basis to 
estimate the impacts of 
the funds (i.e., impacts 
attributable to the fund 
with a clear causal link), 
thus paving the way for 
the ex -post evaluation 

A proportionate monitoring 
system exists for activities 
carried out in direct and 
indirect management, that 
allows understanding the 
performance and 
outcomes of the projects 
supported whilst ensuring 
sufficient flexibility and 
customisation 

The extent to which the set of data recorded 
are sufficient to generate an impact assessment 
e.g. identification of gaps regarding the 
information recorded, using also the 
stakeholders’ consultation (selection of MS will 
be considered) 

Semi-structured interview 
Country case studies 

Target setting 
methodologies (of 
certain countries) 

Quality, accuracy and level of up to date of data 
included in the monitoring system  
Perception of the stakeholders regarding the 
level of burdensome of the informative 
requirements 

Semi-structured 
interviews  
Thematic case studies  

The extent to which the information collected 
through the monitoring system allow the 
formulation of robust conclusions regarding the 
progresses made 

Semi-structured 
interviews 

SFC2021 
(Analysis of the 
information collected 
through the monitoring 
system) 

SFC2021 
(Analysis of the 
information collected 
through the monitoring 
system) 

MS Programmes 

Member States 
Programmes 

EQ3: How was the 
involvement of the 
relevant partners 
ensured across all 
stages of the 
programming, 
implementation, 

There is a strategy in 
place, at national level, to 
identify, inform and reach 
the most relevant partners 
and which aims to ensure 
their balanced 
representation in the 
monitoring committee  

Share of consulted stakeholders that consider 
all relevant stakeholders are involved in the 
Monitoring Committee of the MS Programmes 
Share of MS with adequate methodologies 
regulating the composition of the Monitoring 
Committees at MS Programme level83  
The extent to which relevant partners attend 
the meetings in the monitoring committee84 

Semi-structured 
interviews 
Country case studies 

Semi-structured 
interviews 
Country case studies 

83  Considering the limited data available, this was checked as part of the country case studies   
84 Considering the limited data available, this was checked as part of the country case studies   

94 

 
  
  
  
 
  
 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

monitoring and 
evaluation? 

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

Relevant partners 
participate in the 
monitoring committee in 
line with their role as 
defined by the relevant 
rules of procedure  
Relevant partners have 
been identified and 
involved at the 
programming stage 

Actions are put in place to 
enable the participation of 
the partners across all 
stages of the fund cycle  

Relevant stakeholders are 
involved, in line with their 
roles, in the process of 
determining the main 
priorities for the work 
Programmes and activities 
of the thematic facility 

There are suitable 
organisational and 
procedural arrangements 
in place to ensure the 
respect of the charter of 
fundamental rights of the 
EU in the fund 
implementation - Art. 9(1) 

Share of consulted stakeholder that consider 
partners involved in the programming stage 
were relevant  

Semi-structured 
interviews 
Country case studies 

Number of actions that are put in place to 
enable the participation of the partners across 
all stages of the fund cycle (for the MS 
Programmes or a selection of them) 

Country case studies 
Semi structured 
interviews  

Number of actions that are putted in place to 
enable the participation of the partners across 
all stages of the fund cycle, considering the 
thematic facility 

Semi-structured 
interviews  
Thematic case studies 

The extent to which relevant stakeholders are 
involved in the process of determination the 
main priorities for the work Programmes and 
activities of the thematic facility  

Semi-structured 
interviews  
Thematic case studies 

The extent to which the programming 
documents and legislative frameworks include 
mechanism for the respect of the Charter of 
Fundamental Rights of the EU for those main 
actions for which the principles are relevant, at 
the EU level and in (selected) Member States 

Thematic case studies 
Targeted survey  

Member States 
Programmes 
Annual Performance 
reports, any other 
project/ Programme 
reporting 

Work Programmes 
Regulatory and policy 
frameworks such as 
Commission 
Recommendations, EU 
Regulations establishing 
or relating to the AMIF 
and other funds, 
Commission 

95 

 
 
  
 
  
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

implementing 
regulations, Commission 
delegated regulations 

 There are suitable 
organisational and 
procedural arrangements 
in place which ensure that 
appropriate steps are 
taken to take into account 
and promote gender 
equality and gender 
mainstreaming across all 
stages of the preparation, 
implementation, 
monitoring, reporting and 
evaluation of the fund - 
Art. 9(2) 
There are suitable 
organisational and 
procedural arrangements 
in place that allow taking 
appropriate steps to 
prevent discrimination on 
all grounds and across all 
stages of the 
programming cycle - Art. 
9(3)  

The fund has suitable 
arrangements that ensure 
that implementation is 
aligned with the objective 
promoting sustainable 
development, as set out in 
Article 11 TFEU, taking 
into account the UN 
Sustainable Development 

The extent to which the programming 
documents and legislative frameworks include 
suitable organisational and procedural 
arrangements at the level of interventions 
(under shared, direct and indirect management) 
in order to:  
- ensure that appropriate steps are taken to 
take into account and promote gender equality 
and gender mainstreaming across all stages of 
the Fund 
-allow taking appropriate steps to prevent 
discrimination on all grounds and across all 
stages of the programming cycle  
- ensure that implementation is aligned with the 
objective 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 
Identification of good practices and challenges 
in this regard 

96 

Semi-structured 
interviews  
Thematic case studies 
Targeted survey 
Country case studies 

MS Programmes 
Annual Performance 
reports 
Thematic Facility Work 
Programmes 

 
 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

Goals, the Paris 
Agreement and the "do no 
significant harm" principle 
- Art. 9(4)  

There are suitable 
organisational and 
procedural arrangements 
in place to ensure the 
respect of the charter of 
fundamental rights of the 
EU is ensured, gender 
equality and gender 
mainstreaming are 
promoted and 
discrimination on all 
grounds is prevented in 
the activities funded in 
direct/indirect 
management 
There is a communication 
strategy in place, with 
correctly identified target 
population as well as 
relevant monitoring 
arrangements, including 
appropriate and 
measurable targets for the 
communication activities  

Dissemination activities 
reach the target audience 
and are carried out 
through an appropriate 
mix of communication 
channels and platforms, 

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

Identification of communication strategies 
concerning the overall fund and the MS 
Programmes  
The extent to which available communication 
strategies identified relevant target population, 
include relevant monitoring arrangements 
Success of existing communication strategies, 
including e.g. based on existing analyses 
relating to the reach of target population 

Semi-structured 
interviews  
Country case studies 
Thematic case studies 

Annual Performance 
reports 
Member States 
programmes  
Thematic Facility Work 
Programmes 
Annual Performance 
reports, any other 
project/ Programme 
reporting 

97 

 
 
 
 
Evaluation Question  

Judgment criteria  

Indicator / Descriptor 

Primary source 

Secondary source 

including social media, and 
generate interactions  

Funding opportunities are 
adequately advertised and 
reach the identified target 
population of potential 
beneficiaries 

Identification of strategies / means used to 
advertise funding opportunities  

Development of the number of funding 
applications over the years and identification of 
calls that did not lead to a sufficient number of 
applicants 
Assessments of stakeholders on the visibility of 
the fund and related funding opportunities and 
challenges in this regard  

Semi-structured 
interviews  
Country case studies 
Thematic case studies 

Annual Performance 
reports  
Mid-term evaluation 
(where available) 

Thematic case studies 

Mid-term evaluation 
(where available) 

Semi-structured 
interviews 
Country case studies 

Relevance  

Evaluation 
question  

EQ11: To what 
extent does the 
Fund address the 
evolving needs? 

Judgment criteria  

Indicator / Descriptor 

Primary 
source 

Secondary 
source 

The Fund stakeholders are 
correctly identified in line with 
the objectives established in the 
legal basis  

Share of consulted stakeholders that consider all relevant 
stakeholders are correctly identified considering the objectives of the 
Fund 

The milestones and targets 
planned address the most 
relevant needs with 
proportionate resources  

Share of consulted stakeholders that consider the distribution of 
resources are in line with their needs  

Semi-
structured 
interviews 

Country case 
studies  

Thematic case 
studies 

Targeted 
survey  

Country case 
studies 

98 

 
 
 
 
 
 
 
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary 
source 

Secondary 
source 

The list of implementation 
measures included in the legal 
basis and planned within the 
fund is suitable to address 
emerging needs 

The extent to which the measures planned are suitable to address 
emerging needs  

Share of stakeholders that consider the measures planned address the 
emerging needs of target population 

Semi-
structured 
interviews 

Targeted 
survey 

Country case 
studies 

Thematic case 
studies 

The work Programme of the 
thematic facility focuses on the 
key priority needs and key 
target populations 

The extent to which Thematic Facility actions consider additional 
target populations and needs that are not fully covered by the other 
Fund components 

Thematic case 
studies 

A needs assessment is 
performed and updated on a 
regular basis or whenever there 
are relevant contextual changes  

The extent to which at Member State level update of need 
assessments has been performed and updated following relevant 
contextual changes  

The extent to which at Thematic facility level update of need 
assessments has been performed and updated following relevant 
contextual changes  

EQ12: To what 
extent can the 
Fund adapt to 
the evolving 
needs? 

The partnership / monitoring 
committee is able to provide 
timely input on evolving needs 

The extent to which the consulted stakeholders consider the 
monitoring committee has been able to provide inputs on evolving 
needs and relevant developments on the ground  

99 

Targeted 
survey with 
national 
authorities 

Semi-
structured 
interviews  

Country case 
studies 

Thematic case 
studies 

Targeted 
survey for 
national 
authorities 

Mid-term 
national 
evaluations 

 
 
 
 
 
 
 
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary 
source 

Secondary 
source 

and relevant developments on 
the ground  

Share of Member States that keep track of the level of implementation 
of the inputs provided by the committee 

Country case 
studies 

(where 
available) 

There is an adequate degree of 
flexibility in the design of the 
operations  

Procurement procedures from 
the COM ensures flexibility 
facilitate the bottom-up 
feedback 

Types of measures taken to ensure flexibility 

Share of consulted stakeholders that consider the implemented 
measures were effective in ensuring flexibility in the design of the 
projects, call for proposals, procurement procedures 

Non substantial changes to the 
MS Programme were applied 
swiftly 

Number of changes to the MS Programmes  

Share of consulted stakeholders that consider that non substantial 
changes were applied swiftly 

Rules and procedures have been 
established to ensure that 
substantial adjustments to the 
Fund can be implemented in a 
timely manner should new 
needs arise 

Types of existing rules and procedures that ensure that substantial 
changes can be implemented  

Share of consulted stakeholders that consider substantial changes can 
be implemented should new needs arises 

If there have been changes in 
the needs after the fund 
adoption the new needs have 

Share of consulted stakeholders that consider the Thematic Facility 
actions addressed new needs which emerged after the Fund adoption 

100 

Targeted 
survey  

Country case 
studies 

Work 
Programmes 

Thematic case 
studies 

Semi-
structured 
interviews 

Country case 
studies 

Semi-
structured 
interviews 

Country case 
studies 
Thematic case 
studies 

Semi-
structured 
interviews 

Member 
States 
Programmes  

Mid-term 
evaluations 
(where 
available) 

Thematic 
Facility Work 
Programmes 

Mid- term 
national 
evaluations 
(where 
available) 

 
 
 
 
 
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary 
source 

Secondary 
source 

been duly addressed via the 
thematic facility 

The Thematic Facility allows to 
address new developments or 
priorities at EU level in an 
efficient manner 

Share of consulted stakeholders that consider the Thematic Facility 
measures were efficient in the management of new developments/ 
emergency situations EU level 

Thematic case 
studies 

Efficiency 

Evaluation 
question  
EQ6: To what 
extent does the 
fund support cost-
effective measures? 

Judgment criteria  

Indicator / Descriptor 

Financial allocation per Member State per 
types of actions  
Level of achievement of outputs/ results 
indicators per type of actions 
Absorption rate per Member State and overall  

Primary 
source 
 Country case 
studies 

Secondary 
source 
SFC 2021 

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.)  
For highly specific, emergency or innovative 
actions supported via direct or indirect 
management, appropriate mechanisms exist which 
ensure that cost-effectiveness is reviewed as a 
criterion to select the beneficiary 

The extent to selection criteria for projects 
considers the level of cost-effectiveness  

Semi-structured 
interviews  
Country case 
studies 
Thematic case 
studies 

101 

 
 
 
 
 
 
 
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

The EMAS allows to address urgent and specific 
needs in a swift and sufficient manner 

EQ7: To what 
extent is the 
management and 
control system 
efficient? 

The management and control system, described 
as per the legal basis, aims to ensure efficiency in 
the selection of operations, management tasks, 
work of the monitoring committee, 
implementation of anti-fraud measures and 
procedures, fulfilment of accounting function and 
recording and storing of data on each operation 

The administrative burden is proportionate for all 
implementing actors (Managing Authorities, 
Intermediate Bodies), compared to the previous 
programming period/ similar services offered to 
comparable target population without the support 
of the fund  

The administrative burden is proportionate for all 
beneficiaries, compared to the previous 
programming period/ similar services offered to 
comparable target population without the support 
of the fund    
The administrative burden is proportionate for all 
end-users, e.g. compared to the previous 

Share of consulted stakeholders that consider 
EMAS actions allowed to address urgent and 
specific needs 
Assessment of the needs for EMAS and 
comparison to the scope of EMAS, 
identification of gaps / needs that were not 
possible to address  
Number of mechanisms in place at MS level to 
report, detect and prevent fraud and 
irregularities and assessment of the 
effectiveness of these measures (where 
possible, analysed by country e.g. for the 
case study countries)  
Number of follow up cases of fraud and other 
irregularities (where possible, analysed by 
country)  
Identification for each category of 
stakeholders (i.e Managing Authorities, 
Intermediate Bodies, beneficiaries and end-
users) the following:  
- source of costs (activities for which they are 
responsible based on the Regulations); 
- costs to comply with the Regulation. 
Share of consulted stakeholders that perceive 
as burdensome in the implementation aspects 
such as: procurement procedures, regulatory 
requirements, monitoring requirements, 
communication with other stakeholders 
involved in the implementation, obtaining 
guidance and support 

102 

Secondary 
source 

Primary 
source 
Semi-structured 
interviews 
Thematic case 
studies  

Country case 
studies 

Country case 
studies 

Semi-structured 
interviews  
Country case 
studies 
Thematic case 
studies 

Targeted 
survey  
Semi-structured 
interviews  

Mid-term 
national 
evaluations 
(where 
available) 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary 
source 

Secondary 
source 

programming period/ similar services offered to 
comparable target population without the support 
of the fund 

 Absence of ‘gold-plating’ at the national level 
(e.g. from Managing Authorities, Intermediate 
Bodies, national Audit Authorities), i.e. 
requirements are not interpreted more 
restrictively than the legal basis or relevant 
documents providing methodological advice to the 
Member States and unless a justified reason exists  
Absence of ‘gold-plating’ at the EU level, i.e. 
requirements are not interpreted more 
restrictively then in the legal basis and unless a 
justified reason exists  

Simplified cost options used create simplification 
on the ground 
There is evidence of legal requirements, rules of 
procedures or practices that create 
disproportionate administrative burden at the EU 
or MS level, and concrete alternatives exist  
There is evidence of lack of coordination between 
the actors involved in the implementation of the 
fund, resulting in e.g., lack of coherence, 
increased administrative burden, etc 

The extent to which simplification measures 
were used (e.g., simplified cost options) into 
the MS Programmes 

Targeted 
survey  
Semi-structured 
interviews 
Country case 
studies 

 Member States 
Programmes 
Mid-term 
national 
evaluations 
(where 
applicable) 
SFC2021 

Perception of the consulted stakeholders on 
the effectiveness of the simplification 

Country case 
studies 

103 

 
  
 
 
  
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary 
source 

Secondary 
source 

Technical assistance is used to strengthen the 
management and control system when necessary 

measures used in the implementation of MS 
Programmes  
Assessment of the overall resources (human 
and financial) allocated to technical 
assistance85 in the MS Programmes 

Country case 
studies 

The extent to which the consulted 
stakeholders consider the technical assistance 
is used to strengthen the management and 
control system  
Number of Full Time Equivalent in the 
Managing Authorities, Intermediate Bodies 
working on the implementation of AMIF and 
paid by the technical assistance or national 
budgets as compared to the number of 
projects implemented and to the amount of 
the funds claimed for the  
financial year86 
Share of consulted stakeholders that consider 
there is room for additional use of simplified 
cost options and financing not linked to costs 
options 

EQ8: To what 
extent is further 
simplification 
achievable? How? 

There is room for additional use of simplified cost 
options and financing not linked to costs options  

There are issues with the electronic data exchange 
systems that create delays and can and should be 
addressed 

Share of consulted stakeholders that 
encountered difficulties in reporting and 

Semi-structured 
interviews  
Country case 
studies 
country case 
studies 

Targeted 
survey 
applicable) 
Semi-structured 
interviews  
Country case 
studies 
Semi-structured 
interviews  

Member States 
programmes 
Mid-term 
national 
evaluations 
(where 
available) 

Mid-term 
national 
evaluations 
(where 
available) 
SFC2021 

85 The degree to which it will be possible to check this for all or a selection of Member States (e.g. the countries selected for the case studies) will be checked following the submission 
of this inception report. 
86 The degree to which it will be possible to check this for all or a selection of Member States (e.g. the countries selected for the case studies) will be checked following the submission 
of this inception report. 

104 

 
 
  
 
  
  
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

introducing data in the electronic data 
exchange systems,  
Type of difficulties encountered by the 
Stakeholders in introducing data in the 
electronic data exchange systems and 
mitigation measures 

Primary 
source 
Country case 
studies 

Secondary 
source 

Coherence  

Evaluation question  

Judgment criteria  

Indicator / Descriptor 

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 

The complementarity between MS 
Programmes and Thematic Facility or other 
EU funds was assessed in the programming 
phase 

Number of MS that assessed the 
complementarity of the Fund with other 
National and EU funds 

The fund is coherent with the objectives of 
the current policy agendas at EU and national 
levels 

The extent to which the initiatives under 
the thematic facility, and MS 
Programmes are complementary with 
other interventions at the national level, 
e.g. based on the identification of 
synergies, contradictions and overlaps 

Primary 
source 

Secondary 
source 

Country 
case studies 

Targeted 
survey 

Annual 
Performance 
reports  

Member States 
programmes 

Semi-
structured 
interviews 

Targeted 
survey  

Country 
case studies 

Thematic 
case study 

Mid-term 
national 
evaluations 
(where 
available) 

105 

 
 
 
 
 
 
Evaluation question  

Judgment criteria  

Indicator / Descriptor 

There is evidence of inter- and intra-agency 
cooperation 87 

Type of inter and intra-agency 
cooperation in the operations funded by 
the MS Programmes and thematic Facility  

Primary 
source 

Secondary 
source 

Semi-
structured 
interviews  

Country 
case studies 

Thematic 
case studies 

MS Programmes 

Annual 
Performance 
reports 

Thematic Facility 
Programmes 

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? 

Structures, organisational arrangements or 
coordination mechanisms have been in place 
which ensuring coordination, 
complementarities and, where relevant, 
synergies across other EU funds, in particular 
cohesion policy and EU’s external action  

Coordination mechanisms at programme 
level are used regularly and ensure the 
interventions do not overlap 

Number of MS that have in place 
coordination mechanisms between the 
Fund and other national or European 
funds 

Share of stakeholders that consider the 
coordination mechanism as adequate to 
generate synergies across other EU funds 

Targeted 
survey  

Semi-
structured 
interviews  

Member States 
programmes  

Mid-term 
national 
evaluations 
(where 
available) 

Annual 
Performance 
reports  

Mid-term 
national 
evaluations 
(where 
available) 

Annual 
Performance 
reports  

87 This includes e.g. cooperation between the Member States at the EU level, and between Member States and relevant EU bodies, offices and agencies, as well as cooperation at national 
level among the competent authorities within each Member State.  

106 

 
 
 
  
 
Evaluation question  

Judgment criteria  

Indicator / Descriptor 

Any identified overlaps are justified on 
objective grounds (e.g., the same target 
population is addressed, but different types 
of measures / a different need are addressed  

The extent to which the MS Programmes, 
Thematic Facility are complementary 
with other interventions at national level 
and other EU policy  

Percentage of consulted stakeholders 
who considered that existing overlaps 
have been justified on objective grounds 

Primary 
source 

Secondary 
source 

Member States 
Programmes 

Mid-term 
national 
evaluations 
(where 
available) 

Thematic Facility 
Work 
Programmes 

Member States 
Programmes 

Semi- 
structured 
interviews  

Country 
case studies  

Thematic 
case studies 

Semi- 
structured 
interviews  

Country 
case studies  

Thematic 
case studies 

107 

 
 
 
 
 
 
 
 
EU Added Value 

Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary source  Secondary source 

When relevant, there 
is evidence of leverage 
effects and/ or positive 
spillovers  

The extent to which the Thematic Facility and MS Programme 
actions produced spillover effects e.g. impacts on a target 
population who was not targeted initially), including also the 
evidence based on stakeholders’ view; 

The extent to which the Thematic Facility addressed new 
developments or priorities at national and EU level in a swift and 
appropriate manner, including evidence based on stakeholders’ 
view  

Targeted survey  

EQ13: To what 
extent is the fund 
generating EU added 
value? 

There is evidence of 
scope effects, i.e., of 
additional target 
population addressed 
or additional types of 
intervention offered 

There is evidence of 
scale effects, i.e., of a 
higher volume of 
services offered/end-
users addressed 

Types of additional target population compared with the initial 
targeted groups, if possible, at the level of all MS Programmes 
and Thematic Facility operations 

Types of additional actions per target group, compared with the 
initial targeted operations, if possible, at the level of all MS 
Programmes and Thematic Facility  

Targeted survey 

Country case 
studies 

Thematic case 
studies 

Semi-structured 
interviews 

Country case 
studies 

Thematic case 
studies 

Annual Performance 
reports 

Previous EU and MS 
level evaluations and 
assessments  

Literature from EU 
institutions and 
relevant migration 
organisation 

Annual Performance 
reports  

Mid-term national 
evaluations (where 
available) 

Thematic Facility Work 
Programmes 

EASO reports 

Annual Performance 
reports 

Member States 
evaluations 

108 

 
 
 
Evaluation 
question  

Judgment criteria  

Indicator / Descriptor 

Primary source  Secondary source 

There is evidence of 
function effects, i.e., of 
learning and increased 
capacity to manage 
the provision of public 
support within the 
administrations 
involved 

The thematic facility 
addresses priorities 
with a high Union 
added value 

There is no evidence of 
dependency, i.e. of 
systematic lack of 
investment based on 
national resources for 
relevant services that 
are provided entirely 
through support from 
EU funds 

Share of stakeholders that consider the technical assistance 
provided through the MS Programmes increased the capacity to 
manage the provision of public support  

Targeted survey  

Semi-structured 
interviews 

Mid-term national 
evaluations (where 
available) 

Share of consulted stakeholders that consider the migration 
crises or the collaboration with third countries could have been 
managed without the support of the Thematic Facility  

Thematic case 
studies  

Semi-structured 
interviews  

Thematic facility Work 
Programmes 

Research and Studies, 
grey and academic 
literature 

Amount of national funds available for similar objectives 

Country case 
studies 

Semi-structured 
interviews 

109 

 
 
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

Consistent with the Better Regulation Toolbox #56 and #57, table 2 below provides a proportionate overview of the costs and benefits entailed by the 
fund. This table has been completed based on the information gathered during the study supporting the mid-term evaluation of the AMIF 2021-2027. 

The quantitative data on AMIF funding and national contributions stems from the transmission of data from SFC2021 (as of 30 June 2024) as well as 
data on Union Actions and Emergency Assistance (EMAS) from and outside of COMPASS (as of 30 June 2024). 

Quantitative estimates for direct compliance costs and enforcement costs for administrations and for beneficiaries of the AMIF are based on responses 
to the targeted survey, conducted as part of the evaluation study, as well as on anecdotal evidence from semi-structured interviews with stakeholders. 

Table 2: AMIF 2021-2027 cost and benefits analysis  

Cost or benefit 

Citizens / Consumers 
Quantitative  Comment 

Businesses 
Quantitative  Comment 

AMIF 
funding88 

One-off 

National 
contributions89 

One-off 

Other 
Quantitative  Comment 

Administrations 
Quantitative  Comment 
AMIF budget 
Appr. 3.6 billion 
EUR 
allocated to 
operations 
under shared, 
direct and 
indirect 
management. 
MS 
contributions 
allocated to 
operations 
under shared 
management 
(MS 
programmes 
and Specific 
Actions). 

Appr. 823 
million EUR 

88 Committed resources, i.e. committed AMIF budget allocated to actual operations. Source: Table 3, TOD from SFC2021 (June 2024); EMAS and UA data from and outside of COMPASS 
(June 2024). 
89 Committed resources, i.e. committed national contribution allocated to actual operations. Source: Table 3, TOD from SFC2021 (June 2024). 

110 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

One-off  

Citizens / Consumers 
Quantitative  Comment 

Businesses 
Quantitative  Comment 

Administrations 
Quantitative  Comment 
Appr. 175 to 
350 million EUR 

Recurrent  

Direct 
compliance 
costs90 

Preparation of 
direct awards 
and Calls: 
appr. 6 to 30 
man-days per 
award/ call per 
MS 
Screening of 
applications: 
appr. 6 to 20 
man-days per 
call per MS 

The estimate is 
based on the 
AMIF budget 
allocated to 
Technical 
Assistance, as 
an 
approximation 
for direct 
compliance 
costs.91 
Evidence on the 
direct 
compliance 
costs for 
authorities is 
very limited, 
based on 
responses to 
the targeted 
survey provided 
by 11 national 
authorities.92 

Other 
Quantitative  Comment 

Direct compliance 
costs for 
beneficiaries: 
Regulatory 
requirements as 
well as 
procurement 
procedures were 
each perceived as 
a challenge by 
>50% of 
surveyed 
beneficiaries.93 
Despite some 
improvements 
due to more use 
of simplification 

90 Adjustment costs, administrative costs, regulatory charges. 
91 The planned resources for Technical Assistance of 350 million EUR (Source: Table 6, TOD from SFC2021, June 2024) are taken as a ceiling estimate for direct compliance costs of 
national authorities. The lower bound of 175 million EUR represents a best estimate which could not be verified. While EU contributions for Technical Assistance can be used for more 
than adjustment costs and administrative costs, there are likely to be additional direct costs borne by national authorities for which no data is available. Funding for Technical Assistance, 
as defined in Article 36(5) of Regulation (EU) 2021/1060, is allocated to actions necessary for the effective administration and use of AMIF funds, including for capacity building, as 
well as functions such as preparation, training, management, monitoring, evaluation, visibility and communication. 
92 Quantitative estimates were made based on the responses provided for the time spent on the preparation of funding and the screening of applications, which varied significantly across 
respondents. 
93 Survey question: “To what extent were the following aspects perceived as a challenge by your institution / organisation / company in the implementation of the project(s) funded by the 
MS Programme AMIF?” (Q30; N=138) 

111 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Citizens / Consumers 
Quantitative  Comment 

Businesses 
Quantitative  Comment 

Administrations 
Quantitative  Comment 

Other 
Quantitative  Comment 

One-off  
Recurrent  

n/a  

Enforcement 
costs94 

One-off  

Indirect 
costs97 

Evidence on the 
enforcement 
costs for 
authorities is 
very limited, 
based on 
anecdotal 
evidence 
provided by two 
national 
authorities.95 

Monitoring: 
appr. 2 to 10 
man-days per 
year per MS 
Reporting: 
appr. 50 man-
days per 
reporting year 
per MS 
Auditing:  
appr. 3 man-
days for one 
on-the-spot 
control per MS 

measures, 
beneficiaries of 
the AMIF still 
perceive the 
administrative 
costs of the AMIF 
as substantial. 

Enforcement costs 
for beneficiaries: 
Monitoring 
requirements 
were perceived as 
a challenge by 
55% of surveyed 
beneficiaries.96 

Indirect costs for 
beneficiaries: 
Anecdotal 
evidence from a 
large beneficiary 
organisation 
suggests that the 
fulfilment of 
reporting and 
monitoring 
requirements ties 

94 Costs associated with activities linked to the implementation of an initiative such as monitoring, inspections, and adjudication/ litigation 
95 Responses from other authorities suggest that more man-days were spent for auditing per on-the-spot control or per project, which is likely due to the varying sizes of projects. 
96 Survey question: “To what extent were the following aspects perceived as a challenge by your institution / organisation / company in the implementation of the project(s) funded by the 
MS Programme AMIF?” (Q30; N=138) 
97 Compliance costs or other indirect costs such as transaction costs 

112 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Citizens / Consumers 
Quantitative  Comment 

Businesses 
Quantitative  Comment 

Administrations 
Quantitative  Comment 

Other 
Quantitative  Comment 

Recurrent  
- 

n/a  

Direct benefits 

- 

Indirect 
benefits 

Direct support 
facilitates 
access to 
essential 
services for 
target groups. 

Actions aimed 
at enhancing 
the integration 
of migrants 
ultimately 
benefits social 
cohesion in 
Member States. 

Actions aimed 
at the 
integration of 
migrants 
facilitate their 
entry into the 
labour force of 
EU Member 
States. 

98 Such indirect costs to beneficiaries can in some cases lead to a temporary reduction of services to the target groups. 
99 This qualitative reasoning is based on the findings of the ex-post evaluation of the AMIF 2014-2020. 

113 

up resources, 
thereby causing 
indirect costs.98 

Direct support 
through the AMIF 
funding of 
projects in the 
field of asylum, 
migration and 
integration. 

Apart from direct 
support for the 
measures of 
beneficiaries, 
AMIF funding 
enables 
organisations to 
engage in the field 
of asylum, 
migration and 
integration, 
further 
contributing to 
societal 
acceptance 
national and EU 
policies. 

Direct support 
through AMIF 
funding via 
Union Actions, 
Emergency 
Assistance and 
Technical 
Assistance.  
Support in the 
management of 
migration and 
the 
achievement of 
policy 
objectives in 
the field of 
asylum, 
migration and 
integration. It 
can further be 
assumed that 
there are 
efficiency gains 
in the delivery 
of funding for 
asylum, 
migration and 
integration in 
Member 
States.99 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

The consultation strategy for this mid-term evaluation included semi-structured interviews, 
two focus groups and targeted surveys. The objective of the consultations was to collect 
relevant  information  and insights on the effectiveness,  efficiency, coherence, EU added 
value and relevance of the AMIF, as well as to collect inputs on lessons learned. To do so, 
a wide range of EU, international and national level stakeholders were consulted. 

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.  Eight  contributions  were 
received (100): 

-  The Red Cross EU office provided a series of points regarding:  

o  In a number of Member States, AMIF is a core funding instrument and this 
makes  projects  dependent  on  funding  cycles,  thereby  affecting  the 
sustainability of a project particularly in the period between funding cycles. 

o  Greater flexibility in the target group that benefit from the fund would ease 

the Red Crosses ability to provide services. 

o  Efforts  should  be  made  to  improve  civil  societies  and  humanitarian 

organisations access to AMIF funds. 

o  The  Thematic  Facility  work  programmes  should  ensure  predictability 
regular calls, for example calls concerning the exchange of best practices.  

o  The  need  to  allocate  greater  resources  to  EMAS  under  the  2021-2027 

programming period.  

o  Possibilities  to  ease  reporting  requirements  under  AMIF  should  be 

explored. 

o  Calls  for  applications  under  Union  Actions  should  consider  longer 

deadlines.  

o  It is considered a good practice for the main AMIF implementing partners 
to be included in the Member State monitoring committees and should be 
further encouraged.  

- 

International Rescue Committee (IRC) stated appreciation for AMIF’s contribution 
to innovation and mutual learning. They expressed that longer grant periods would 

(100) Asylum, Migration and Integration Fund (AMIF) for 2021-2027 – mid-term evaluation 

114 

 
 
 
 
increase impact. They demonstrated concern that projects to support beneficiaries 
of temporary protection reduced support to other refugee populations. 

-  The  European  offices  of  the  Bavarian,  Baden-Württemberg  and  Saxony 
municipalities suggest that to increase and ease the participation of municipalities, 
virtual information sessions should be offered, the requested financial contribution 
should be reduced, and calls for applications should be streamlined.  

-  The  European  Council  on  Refugees  and  Exiles  provided  a  series  of  points 

regarding: 

o  Increasing  the  participation  of  civil  society  organisations  in  the  Member 
States AMIF monitoring committees and greater transparency around the 
monitoring committee’s selection procedure and work. 

o  Increasing  transparency  of  the  arrangements  for  reporting  cases  of  non-
compliance with the Charter of Fundamental Rights of the European Union 
to the Member State AMIF monitoring committees. 

o  Considering establishing a legal requirement that 30% of AMIF funds reach 
civil  society  organisations  to  increase  efficiency  and  increase  the 
participation of civil society organisations. 

o  Greater efforts should be made to ensure coherence of the AMIF resources 

dedicated to the external dimension.  

-  The Government of the Canary Islands expressed  increasing the participation of 
regional  authorities  is  essential,  one  suggestion  is  to  make  it  easier  for  regional 
authorities to benefit from direct management. They also suggest a revision of the 
result  indicators  to  be  more  realistic  and  reflective  of  projects  concerning 
unaccompanied minors.  

-  Oxfam  Italia  stated  the  Thematic  Facility  work  programmes  do  not  clearly 
communicate which calls for proposals will be launched in 2024 and the budget 
envelop per call.  

-  A private citizen reiterated the objectives of the mid-term evaluation. 

-  FAIRWORK  Belgium  expressed  appreciation  for  the  inclusion  of  support  to 
exploited workers without legal residence in the scope of support in AMIF for the 
2021-2027 programming period. 

Interviews 

Overall,  89  interviews  were  conducted  as  part  of  the  study.  The  interviews  that  were 
conducted during the data collection phase fed into answering the evaluation questions, as 
well as into the development of the country and thematic case studies.  

The table below provides an overview of the number of interviews conducted by activity 
as well as the types of consulted stakeholders and the objectives of the different interviews 
conducted.  

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Table 3: An overview of the interviews conducted during the study 

Interviews by 
activity  

Scoping 
interviews (7)   

Review of a 
sample of 
target setting 
methodologies 
(10) 

Semi-
structured 
interviews 
(14) 

Country case 
studies (40) 

Type of consulted stakeholders   Objectives 

To deepen the understanding 
of  the  functioning  of  the 
AMIF,  and  to  finetune  the 
methodological approach 

DG HOME (6): Funds 

9. 
coordinators (Unit E1, E2, 
E3); Union actions (E4); 
Specific Actions (E3); 
Irregular Migration, 
Returns and Readmission 
sector (Unit C1), Legal 
Pathways and Integration 
(Unit C2), Asylum Policy 
(Unit C3) 

Managing Authority (1): IT 

National Managing Authorities 

•  To gather information on 

(10): DE, IT, AT, EL, LT, 
NL, FR, SE, PL, RO 

National /Managing Authorities 

10. 

(10): IT, BE, CZ, EL, ES, 
HU, PT, NL, SE, PL, CY 

DG REGIO (1) 
EU agencies (2): EUAA, FRA. 

National Managing Authorities 

11. 

(DE, EL, FR, IT, LT, RO) 

Project representatives and 
beneficiaries 
Research and civil society 
organisations 

12. 

13. 

the methodologies used by 
Managing Authorities to 
establish their targets for 
the 2021-2027 period 

strategic  and 
To  gather 
information 
operational 
AMIF 
about 
the 
implementation, 
including 
considerations  related  to  its 
impacts and added value 

identify  and  discuss 
To 
potential specific factors and 
processes that are crucial for 
the  success  of  the  AMIF 
implementation 

To  identify  how  AMIF  is 
being  implemented  both  by 
non-
governmental 
governmental stakeholders. 

and 

To  investigate  the  current 
state  of  funding  in  specific 
countries  with 
special 
emphasis  on  the  extent  to 
which  and  the  reasons  why 
the funding was particularly 
effective,  efficient  etc.  (or 
not).    

Thematic case 
studies (18) 

Beneficiaries 
representatives for:  

and 

project 
14. 

To gather granular evidence 
on  the  portfolio  of  projects 

116 

 
 
 
 
 
Interviews by 
activity  

Type of consulted stakeholders   Objectives 

Union Actions (2)  
EMAS (3)  
Ukraine (4)  
Specific Actions (5)  
Horizontal priorities (4) 

under  the  specific  types  of 
the 
and 
components 
programmes  of  the  Fund, 
identifying 
innovative 
approaches  and  projects, 
good  practices,  key  drivers 
towards 
and 
achieving specific objectives 
and 
lessons 
learned 

results,  and 

barriers 

Source: The consortium 

Overall, the interviews conducted during the study helped assess how effectively the AMIF 
framework is progressing towards its goals  of enhancing national capacities, improving 
migration  management,  and  promoting  responsibility  sharing  between  Member  States. 
Consulted  stakeholders  provided  a  positive  evaluation  of  the  fund’s  effectiveness  and 
efficiency  in  meeting  its  objectives.  They  noted  that  AMIF  is  successfully  addressing 
evolving  needs,  while  aligning  with  both  internal  and  external  initiatives.  In  addition, 
consulted  stakeholders  highlighted  the  significant  EU  added  value  that  AMIF  brings  to 
addressing issues and crisis that national funds alone cannot effectively tackle.  

However, acknowledging the fund’s effectiveness, the stakeholders interviewed expressed 
concerns  about  some  challenges  hindering  and  slowing  down  AMIF’s  implementation. 
Among  these  challenges,  unexpected  crisis  and  migration  flows,  delays  in  the  initial 
funding provision, and high administrative costs. Lastly, while there is an administrative 
burden  associated  with  performing  changes  to  the  AMIF  projects  at  the  time  of 
implementation, consulted stakeholders noted a high degree of flexibility within the AMIF 
framework.    The  next  sections  cluster  the  findings  of  the  interviews  according  to  the 
different evaluation criteria (e.g. effectiveness, efficiency, coherence, relevance, EU added 
value).  

EFFECTIVENESS  

Overall, the fund seems to be on track in achieving its operational and specific objectives. 
For  instance,  34  consulted  stakeholders  (17  MA,  nine  beneficiaries,  five  projects’ 
representatives,  three  CSOs)  indicated  progress  in  achieving  objectives  and  targets  for 
projects funded by AMIF during the 2021-2027 programming period. Nonetheless, several 
challenges hampering or slowing down the implementation progress have been identified 
by  the  majority  of  consulted  stakeholders.  Uncertainty  about  responsibilities  sharing 
among  the different  authorities involved in  the projects,  as well as the delayed funding 
provision compared to the expected date of delivery caused delays in the projects’ launch.  

Despite the overall positive assessment in terms of effectiveness of the AMIF, a consulted 
project  representative  stressed  that  the  current  structure  of  AMIF  calls  for  projects, 
characterised by detailed requests and tight time constraints, limits the ability of smaller 
organisations  with  limited  staff  to  participate  effectively.  In  addition,  the  small  budget 

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provided  through  co-funding  presents  a  challenge  for  these  organisations,  further 
restricting their capacity to engage in the process. However, the interviewee did not specify 
whether these considerations refer to direct or shared management.   

Experiences related to the monitoring and evaluation framework and the extent to which 
the latter is suitable to inform on the progress towards the achievement of AMIF objectives 
are  mixed.  While  two  MA  are  still  finalising  the  development  of  their  monitoring 
mechanisms, 19 consulted stakeholders believed it to be to a good extent appropriate to 
effectively  assess  the  fund's  objectives.  Four  stakeholders  (two  MA,  one  CSO  and  one 
beneficiary)  even  emphasised  the  improvement  of  common  indicators’  definition  and 
clarity in comparison to the previous programming period. Other consulted stakeholders 
seemed  to  be  less  satisfied  with  the  existing  monitoring  mechanisms’  scope  and 
effectiveness,  while  one  CSO  was  not  at  all  aware  of  the  existence  of  a  monitoring 
mechanism.  Even  when  providing  an  overall  positive  assessment  of  the  monitoring 
mechanisms’  effectiveness,  four  MA  stressed  the  current  IT  system’s  limitations, 
considering it outdated and non-comprehensive. 

Partners  are  highly  involved  across  all  stages  of  the  programming,  implementation, 
monitoring  and  evaluation  of  AMIF.  Indeed,  13  MA,  as  well  as  two  CSOs,  five 
beneficiaries and one representative of a research centre/think tank or academia reported 
that all relevant partners and stakeholders (e.g. beneficiaries, CSOs, IOs, local and regional 
authorities) participate in AMIF national monitoring committees. Notably, four MA and 
one representative of a research centre/think tank or academia emphasised that MA in their 
Member  States  hold  meetings  more  frequently  than  the  required  annual  meeting,  while 
some maintain constant exchanges with relevant partners.  

According  to  16  consulted  stakeholders,  effective  collaboration  and  involvement  of 
partners and beneficiaries in AMIF projects  is ensured by effective communication and 
dissemination  of  opportunities  and  achievements.  Eight  MA  reported  that  they 
communicate  constantly  with  beneficiaries  through  electronic  channels  and  provide 
beneficiaries with guidance, ad-hoc seminars, trainings, and workshops. Information about 
AMIF  achievements  is  disseminated  to  the  wider  public  in  the  form  of  reports  or 
information campaigns material (e.g. posters, flyers) through mailing lists, websites, social 
media, TV and radio spots, or dedicated notice boards.     

Regarding  the  respect  of  horizontal  principles,  most  consulted  stakeholders  highlighted 
that there is a clear obligation outlined in the AMIF call. However, when it comes to the 
implementation  of  AMIF  projects,  stakeholders  highlighted  the  lack  of  a  mechanism 
specifically  tracking  funding  allocations  for  these  horizontal  principles  (e.g.  for  digital 
transition or green initiatives).  

EFFICIENCY  

17  consulted  stakeholders  believe  AMIF  funded  measures  to  be  cost-effective  and  one 
stakeholder even featured an improvement in terms of efficiency compared to the former 
programming period. The use of simplified cost  options and measures of simplification 
have  been  emphasised  by  five  MA  as  positively  fostering  efficiency.  However,  most 
stakeholders  believe  further  simplification  to  be  possible  and  four  MA  mentioned  their 
impossibility  to  quantify  or  assess  the  cost-effectiveness  of  AMIF-funded  projects. 
Moreover,  one  stakeholder  even  lamented  the  limited  role  of  the  Commission  in 
elaborating simplified cost options, as it does for other funds (i.e. ESF).  

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Despite  assessing  the  management  and  control  system  as  efficient  overall,  five  MA 
highlighted  an  increase  in  the  administrative  burden  compared  to  the  previous 
programming  period,  due,  for  example,  to  the  complexity  of  the  Common  Provision 
Regulation  (CPR),  or  the  reporting  requirements.  As  a  matter  of  fact,  significant 
administrative costs linked to the reporting mechanisms were reported to cause delays in 
the projects’ implementation by seven consulted stakeholders.  In particular, one project 
representative  explained  that  the  transition  to  the  electronic  systems  has  increased  the 
administrative  burden,  creating  data  reconciliation  challenges  between  the  old  non-
electronic  and  the  new  electronic  data.  Only  one  stakeholder  stated  that  administrative 
costs  have  decrease  due  to  simplified  cost  options.  Overall,  most  inquired  authorities 
convened  that  there  is  great  room  for  further  simplification.  Suggestions  to  enhance 
efficiency  entail  the  simplification  of  applications;  enhance  clarity;  reduce  reporting 
requirements; differentiate requirements according to the scope of the project, particularly 
reducing  requirements  for  small  projects;  allow  interoperability  between  the  national 
information systems and SFC systems. 

COHERENCE  

According  to  12  Managing  Authorities,  three  beneficiaries,  two  CSOs,  two  project 
representatives, one representative of a research centre/think tank or academia, and two 
EU-level stakeholders, the AMIF allows to establish good synergies among policies and 
projects under the same policy domain, while avoiding duplication with national projects 
and initiatives.  For instance, one MA even highlighted that AMIF projects,  specifically 
Specific  Actions  and  EMAS,  tend  to  be  more  competitive  than  national  projects  with 
similar objectives due to the rapid availability and flexibility of the AMIF. In addition, four 
MA emphasised coherence and successful cooperation of MA and/or beneficiaries with 
EU agencies (e.g. EUAA and Frontex), while seven other consulted stakeholders reported 
good complementarity with other DG HOME (e.g. ISF, BMVI) and, more generally, EU 
funds (i.e. ESF, Next Generation EU).  

Nonetheless,  one  EU-level  stakeholder  pointed  out  that  discussions  on  duplication  are 
ongoing,  implying  that  it  may  occur  to  some  extent.  Additionally,  two  MA  voiced  the 
possibility of further enhancing existing synergies. Four MA suggested that this could be 
achieved,  for instance, by conducting joint  calls (at  present  not  available for AMIF but 
feasible for other funds). 

RELEVANCE  

According to 39 consulted stakeholders, the AMIF effectively addresses the needs of the 
target groups. 17 stakeholders (13 MA, one representative of a research centre/think tank 
or academia, one project representative, one beneficiary, and one EU-level stakeholder) 
stated that the needs assessment effectively identifies the needs of target groups, mainly 
thanks to the authorities’ holistic approach and the broad scope enabled by the involvement 
and repeated interaction and cooperation with a wide variety of relevant stakeholders (e.g. 
beneficiaries,  NGOs,  IOs,  local  and  regional  authorities).  Only  one  MA  and  one  CSO 
reported that needs assessment was, according to them, unnecessary due to the wide and 
holistic  involvement  of  stakeholders  and  beneficiaries,  and  their  regular  consultations 
providing sufficient information to identify evolving and new emerging needs, rendering 
the  replication  of  formal  needs  assessments  unnecessary.    Despite  the  overall  positive 
assessment, two CSOs and one project representative highlighted that the AMIF fails to 
address specific needs of some vulnerable groups (e.g. people who require repatriation but 

119 

 
lack  a  valid  residence  permit  and,  thus,  cannot  benefit  from  integration  services  or 
repatriation assistance). 

In a similar manner, AMIF is flexible and able to adapt to evolving needs according to 20 
MA, three CSOs, three beneficiaries, one project representative, and one representative of 
a  research  centre/think  tank  or  academia.  In  particular,  six  MA  reported  that  needs 
assessments are regularly performed, and beneficiaries consulted to identify new arising 
needs. Situations where AMIF demonstrated a significant degree of flexibility entail the 
Russian Aggression of Ukraine (mentioned by 10 MA, one EU-level stakeholder, and one 
beneficiary),  the  situation  in  Afghanistan  (highlighted  by  one  MA,  one  EU-level 
stakeholder, and one beneficiary) and the newly adopted Pact on Migration and Asylum 
(identified by two MA, and four EU-level stakeholders). Regarding the Pact, DG Home 
considers  the  AMIF  to  be  the  appropriate  mechanism  for  its  successful  and  timely 
implementation. However, one stakeholder highlighted that the Pact’s implementation is 
hampered by the lack of available resources under the AMIF left to be allocated to it.  

Despite a formal significant degree of flexibility, two MA, one beneficiary, and one CSO 
stressed the administrative burden linked to such changes, that de facto limits the flexibility 
of AMIF. Similarly, according to two consulted stakeholders, the strict rules in the CPR101 
hamper  the  ability  to  adjust  the  design  of  operations  and  actions  at  the  time  of 
implementation. 

EU ADDED VALUE  

The AMIF brought remarkable added value, allowing the realisation of projects and actions 
that could  have not  been achieved through national  funds alone or that would not  have 
been  carried  out  due  to  not  representing  pressing  priorities  to  single  Member  State,  as 
highlighted by 34 consulted stakeholders (19 MA, three CSO, four project representatives, 
five  beneficiaries,  two  EU-level  stakeholders,  and  one  representative  of  a  Research 
centre/think  tank  or  academia).  Two  consulted  stakeholders  emphasised  that  the  AMIF 
allows to  keep national  asylum policies aligned  with  the Union’s policies, enabling the 
provision of a common response to asylum. In addition, two MA stressed the substantial 
role of AMIF to enable responses and actions in times of great pressures or crisis. 

First EU-level focus group 

The  first  EU-level  focus  group  was  held  on  25  June  in  Brussels,  gathering  participants 
from eight Managing Authorities (AT, BG, EE, DE, IT, NL, SK, SE) and 21 beneficiaries, 
with the aim of gathering preliminary evidence on AMIF implementation challenges and 
good practices related to the AMIF four specific objectives.  

After  a  brief  presentation  of  the  study,  two  breakout  sessions  were  organised  to  hold 
thorough discussions on: 1) challenges hampering the successful AMIF implementation, 
particularly  focusing  on  programming  and  selection,  implementation,  monitoring,  and 
communication; and 2) good practices and policy issues with respect to four SOs of the 
Fund (i.e. SO1, SO2, SO3, SO4).  

The first breakout session highlighted several key insights, offering a deeper understanding 
of both challenges and positive aspects associated with AMIF implementation.  

101 Regulation (EU) 2021/1060. 

120 

 
 
Firstly, with regard to the programming and selection of projects, both beneficiaries and 
Managing  Authorities  noted  that  applications  for  AMIF  projects  are  sometimes  too 
cumbersome and not clear enough. As for implementation, Managing Authorities stressed 
the  importance  of  focusing  on  the  use  of  simplified  cost  options  to  enhance 
implementation, while both Managing Authorities and beneficiaries highlighted that the 
use  of  unit  costs  has  streamlined  project  implementation  and  reporting.  Nonetheless, 
beneficiaries also highlighted that unit costs are hardly adjusted against inflation and that 
the related reporting requirements, though streamlined, are quite time-consuming.  

No major issues were highlighted concerning monitoring, except for limited involvement 
of relevant partners in the Monitoring Committees featured by Managing Authorities. As 
for  managing  controls,  beneficiaries  stressed  the  need  to  prioritise  the  achievement  of 
project results and objectives, rather than strict adherence to the initial project proposal.  

Lastly,  beneficiaries  and  Managing  Authorities  noted  that  there  is  limited  visibility  of 
AMIF  projects  and  their  impact,  despite  the  overall  increase  of  budget  allocated  to 
communication activities.  

Among the main outcomes of the second break-out session on AMIF SOs, beneficiaries 
noted that AMIF’s contribution  through SO2 is pivotal,  as it enables Member States to 
fund what they would not be able to fund otherwise. As for SO3, beneficiaries suggested 
that irregular migration should be covered by other Home Affairs Funds instead (e.g. ISF) 
and that AMIF should focus more on aspects  related to  integration. No issues emerged 
with  regard  to  SO4,  with  beneficiaries  noting  that  since  the  2014-2020  programming 
period there have been improvements in terms of the relevance of AMIF projects related 
to migrants sharing capacities and overall EU solidarity. 

Overall, throughout the focus group the EU added value of AMIF was highlighted by both 
Managing  Authorities  and  beneficiaries.  Beneficiaries  further  added  that  AMIF  plays  a 
pivotal role at the national level as no other national initiatives allocate enough funding on 
the  same  policy  priorities.  As  noted  by  participants,  AMIF  provides  legitimacy  to  the 
projects carried out at the grass-root level in the field of migration and asylum.  

Second EU-level focus group 

A second EU-level focus group was held online through Microsoft Teams on 12 December 
2024. This focus group gathered 13 participants from:  

•  EU Commission (6): DG HOME (unit E1, E2, E3, E4, C2) and DG EMPL (Unit 

G5); 

•  EU Agencies (3) : EUAA (2), FRA (1); 

•  Managing Authorities (4): DE, FR, IT, PL; 

The  focus  group  had  a  twofold  objective  of:  (i)  Validating  the  findings  of  the  study, 
particularly in view of potential factual mistakes, thus allowing the Team to fine-tune the 
evaluation results, and (ii) discussing the challenges identified and the design of lessons 
learned, based on the inputs provided by the Team, including their prioritisation.   

The focus group was organised in two plenary sessions.  

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The first session was devoted to the presentation of the study, followed by a Q&A session. 
During  this Q&A, participants asked for some clarifications on the evaluation  findings, 
and highlighted new elements to be taken into consideration in the evaluation of AMIF, 
such as the following (each of these points has been integrated in the list of challenges and 
lessons learned in section 5): 

•  As  concerns  the  partnership  principle,  DG  HOME  explained  that,  to  their 
understanding, local authorities and some CSOs do not believe that there has been 
a  significant  degree  of  inclusion,  for  instance  in  the  Monitoring  Committees. 
Together with one Managing Authority (MA), DG HOME suggested to account 
for  the  variance  of  relevant  stakeholders  across  Member  States  when 
considering the partnership principle.  

•  DG HOME and one MA stressed that the possibility of ensuring swift adaption of 
Member States programmes may be hindered not only by the Commission’s delay 
in  the  approval  of  amendments,  but  also  by  MAs  delays,  e.g.  due  to  internal 
discussions  or  to  administrative  burdens  at  national  level  connected  to 
amendments.   

•  One MA explained that the current set-up of reporting adds complexity and should 
be  taken  into  account  as  a  challenge  that  needs  to  be  addressed  through  further 
simplification. 

•  DG HOME noted that several findings of the supporting study fail to distinguish 
between the impact of the CPR rather than the AMIF Regulation.  Firstly, DG 
HOME suggested to reflect on the connection between CPR and AMIF and the 
extent  to  which  changes  in  the  management  of  the  Member  States  
programmes  in  the  2021-2027  programming period  have  been  triggered  by 
CPR  requirements.  For  example,  with  regard  to  communication,  DG  HOME 
raised whether the improvement in communication was due to Art. 48 and Art. 49 
of the CPR, which foresee specific obligations for Member States to comply, or if 
this  is  stemming  from  overall  improvement  in  the  magement  of  AMIF.  Similar 
questions  were  raised  about  the  management  and  control  systems,  which  are 
aspects embedded in the CPR. Secondly, DG HOME suggested to reflect strictly 
on  the  link  between  horizontal  principles  and  the  CPR,  which  prescribes 
horizontally  enabling  conditions  partially  overlapping  with  the  horizontal 
principles. For example, Member States must enforce measures to comply with the 
horizontal enabling condition related to the correct implementation of the Charter 
of Fundamental Rights.  

The second plenary consisted of an interactive, co-design workshop. 

Firstly, the Study Team presented an overview table displaying the challenges identified 
in  the  study  clustered  into  three  groups  according  to  their  degree  of  urgency  (i.e.  low, 
medium  and  high),  and  asked  the  participants  to  complement  the  table  with  additional 
challenges, modify the existing ones, or change the associated degree of urgency.  

Secondly,  an interactive  discussion on the design of lessons learned took  place starting 
from inputs already provided by the Team leading the supporting study.  More precisely, 
the participants were asked to provide feedback on the lessons learned already identified, 
and  to  propose  additional  recommendations  and  assess  their  degree  of  feasibility  (i.e. 

122 

 
specifying whether each lesson learned / recommendation was highly feasible, moderately 
feasible  or  hardly  feasible).  The  discussion  unfolded  starting  from  the  challenges 
accounted  as  most  urgent  in  the  previous  discussion,  to  follow  with  moderately  urgent 
challenges,  and  to  conclude  with  the  least  urgent  ones.  Overall,  while  most 
recommendations presented in the study were maintained as originally proposed, others 
were discarded and replaced with alternative suggestions, and a limited number of new 
recommendations were introduced.      

Targeted surveys 

Objectives and scope 

The purpose of the targeted surveys conducted between August and September 2024 was 
to  gather  feedback  from  National/Managing  Authorities  (NAs/MAs)102  involved  in  the 
planning, monitoring, and assessment of AMIF measures, as well as from organisations, 
institutions, or companies participating in their implementation (i.e., beneficiaries).  

It  concentrated  on  aspects  such  as  relevance,  coherence,  effectiveness,  efficiency, 
influencing factors, sustainability of observed effects, and the EU added value provided by 
the implemented measure over both  programming periods (2014-2020 and 2021-2027). 
Furthermore,  the  survey  examined  how  eligible  measures  under  all  AMIF  components 
(National/Member  State  programmes,  Union  Actions,  and  Emergency  Assistance)  are 
perceived in terms of promoting horizontal principles like gender equality, green transition, 
and digital transition. Specific details related to Union Actions and Emergency Assistance 
were also included, in order to be analysed separately in thematic case studies. The findings 
detailed in the dedicated section below were combined with conclusions from other sources 
as part of the overall evaluation exercise. 

Methodology 

The target surveys included a mix of multiple-choice and open questions. Additionally, the 
surveys'  design  enabled  participants  to  concentrate  on  the  specific  programming  period 
they  were  involved  in  and,  if  engaged  in  both  periods,  to  compare  them,  emphasising 
potential improvements.  

As  defined  in  the  inception  phase,  the  survey  encompassed  the  entire  EU  and  utilised 
contact  information  from  MS  representatives  provided  by  the  European  Commission. 
Managing Authorities played a pivotal role in promoting survey participation among other 
stakeholders, including Audit Authorities, Delegated Authorities, Monitoring Committees, 
and beneficiaries.  

The survey, available in English103, was sent to 418 unique stakeholders: 143 contacts from 
National/Managing Authorities managing AMIF and 275 beneficiaries, UA, and EMAS. 

102  National  Authorities  for  the  2014-2020  programming  period  are  the  equivalent  of  the  Managing 
Authorities  in  the  2021-2027 programming  period.  For most  Member  States,  the  National  Authority  and 
Managing Authority are the same. The targeted surveys addressed both the 2014-2020 and the 2021-2027 
programming periods and it is possible survey respondents were only involved in one programming period, 
therefore reference is made to both National and Managing Authorities.  
103 Considering the request from beneficiaries, the  survey for beneficiaries was also translated in French, 
Italian and German. Additionally, there were also particular cases where respondents provided answers in 
their language.  

123 

 
 
Management  Authorities  were  requested  to  send  the  invitations  to  beneficiaries  of 
National/Member State Programmes. 

From  an  operational  perspective,  after  DG  HOME  validated  the  survey  questionnaires, 
they were distributed using the EU survey platform. Based on the contact list provided by 
the  European  Commission,  the  initial  invitations  were  sent  between  19  and  27  August, 
followed by two reminders in the first week of September, and a final reminder informing 
about the extension by 20 September 2024.  

Respondents profile 

Out  of  a  total  of  474  respondents  who  accessed  the  surveys104  (48  National/Managing 
Authorities and 426 Beneficiaries), 419 completed questionnaires were considered for the 
analysis  of  the  results  (37  questionnaires  from  National/Managing  Authorities  and  382 
from AMIF beneficiaries105).  

As indicated in the Figure 7 below, the survey's reach was broad, encompassing a diverse 
typology of stakeholders, with the strongest response rates from civil society and public 
authorities, central and local. The varying response rates across categories may indicate 
differences in the size of these groups, their accessibility and eligibility, or their interest in 
the survey's subject matter. 

Figure 7: National/Managing Authorities and Beneficiaries: Distribution by 
typology  

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AMIF 
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2014-2020

2021-207

Delegated 
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Body
4
11%

Audit 
Authority
6
16%

Source: Targeted Survey with beneficiaries and National Authorities (August - 
September 2024) 
The survey successfully achieved a  broad coverage across  all AMIF components for 
both programming periods, as illustrated in Figure 8 below. The most significant level of 
participation  was  observed  in  the  National  Programme  for  the  2014-2020  period.  This 
predominance may be attributed to the incipient stage of the programmes for the current 

104 The survey was sent to 418 unique stakeholders: 143 contacts from national authorities managing AMIF 
and  275  beneficiaries,  Union  Actions,  and  EMAS.  Management  Authorities  were  requested  to  send  the 
invitations to beneficiaries of National/Member State Programmes. 
105 11 National Authorities did not complete the questionnaire,  with 27 beneficiaries were not sure about 
their involvement in AMIF funded projects (i.e. indicating "I don't know" in the filtering questions) and 17 
stating they were not AMIF beneficiaries. So, uncomplete or not relevant questionnaires were not considered 
in the analysis of the results. 

124 

 
 
 
period  and  the  larger  financial  allocations  designated  for  National/Member  State 
programmes compared to other AMIF components. 

The  survey  questions  were  generally  posed  in  a  broad  context,  and  whenever  feasible, 
respondents  were  asked  about  their  perceptions  across  different  fund  components  and 
programming  periods.  However,  considering  that  respondents  were  often  involved  in 
multiple  fund  components  and  programming  periods,  their  responses  may  reflect  their 
overall  experiences  rather  than  specific  aspects  of  any  single  component  or  period. 
Therefore, conclusions drawn across fund components and programming periods should 
be approached with caution, and it is advisable to consider overarching trends rather than 
focusing solely on individual numbers or percentages. 

Figure 8: National/Managing Authorities and Beneficiaries: Distribution by fund 
components and programming period 

Beneficiaires

7

36

23

71

291

138

100%

80%

60%

40%

20%

0%

100%

80%

60%

40%

20%

0%

National authorities

13

18

20

17

21

7

2014-2020
National/ Member State Programme

2021-2027

2014-2020

2021-2027

Source:  Targeted  Survey,  Beneficiaries  and  National  Authorities  (August  -  September 
2024) 
The survey's distribution by Member State shows varying levels of coverage, with some 
countries demonstrating a strong response rate while others have lower representation (see 
9 below). 

Figure 9: National/Managing Authorities: Distribution by Country and Role 

4

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38%

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2014-2020

2021-207

Delegated 
Authority/ 
Intermedi
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4
11%

Audit 
Authority
6
16%

 Source:  Targeted  Survey,  Beneficiaries  and  National  Authorities  (August  -  September 
2024) 

125 

 
 
Figure 101: National/ Managing Authorities: Distribution by Country 

139

84

68

32

20

12

13

14

11

10

9

5

9

6

8

4

6

2

5

1

5

1

4

3

3

1

3

1

3

1

3

2

2

2

1

1

1

1

1

1

Source: Targeted Survey, National Authorities (August - September 2024) 

Results 

This  section  presents  the  main  findings  per  evaluation  criterion,  where  relevant 
distinguishing  between  findings  emerging  from  the  consultation  of  NAs  and  findings 
emerging from the consultation of beneficiaries. 

RELEVANCE 

Upon  analysing  the  survey  findings,  it  is  evident  that  there  are  some  differences  in 
perceptions  between  NAs/MAs  and  beneficiaries  regarding  the  implementation  and 
relevance of the AMIF. 

NAs/MAs noted that the AMIF strategy planning used a diverse and inclusive approach at 
the national level. They positively assessed the fund's flexibility and relevance for 2014-
2020  and  2021-2027.  Many  NAs/MAs  reported  that  AMIF  programme  strategies  were 
adapted based on political changes and stakeholder input, with the Monitoring Committee 
playing a positive role through its recommendations. Despite this, authorities sometimes 
had  difficulties  implementing  these  suggestions.  Many  NAs/MAs  saw  an  improvement 
over  the  time  in  the  proportionality  and  adequacy  of  the  resource  allocated  to  address 
migration needs. The majority felt the budget limits posed by the regulation were "slightly 
too  low"  or "adequate,"  hinting  at  support for more ambitious targets.  For international 
protection transfer thresholds, only 40% found it adequate, with 25% of respondents seeing 
it as "slightly too high”. 

The  survey  indicates  that  there  is  general  consensus  among  beneficiaries  about  the 
appropriateness  of  the  support  their  organisations  provided  to  TCNs,  with  this  support 
meeting the needs of TCNs. Nonetheless, the agreement rate decreased from 88% to 63%, 
highlighting remaining challenges and obstacles in aiding TCNs.   

Moreover, beneficiaries expressed concerns about the flexibility of calls for proposals and 
procurement procedures. While during the 2014-2020 period both calls for proposals and 
procurement procedures flexibility was rated positively by the majority of respondent, the 
positive perception diminished somewhat in the subsequent period.  

126 

 
 
 
Survey findings indicate that, despite most beneficiaries giving high marks to the staff's 
expertise and the clarity of information available for TCNs when seeking support, several 
challenges  persist.  Only  45%  reported  no  language  barriers,  and  less  than  half  were 
satisfied with the length of the processes TCNs must navigate to access support. Although 
there has been slight progress in the 2021-2027 period in reducing language barriers and 
raising awareness of TCN rights and procedures, opinions remain divided. This suggests 
that further efforts are necessary to enhance the accessibility of support for TCNs. 

COHERENCE 

Consulted  NAs/MAs  consider  that  all  components  of  the  AMIF  were  complementary, 
coordinated, and effective, enhancing their impact during both the 2014-2020 and 2021-
2027  periods.  This  view  is  even  stronger  for  the  2021-2027  period.  MAs  particularly 
appreciated the synergies generated between AMIF and ESF for 2014-2020 and with ESF+ 
for 2021-2027. 

EFFECTIVENESS 

NAs/MAs  and  beneficiaries  generally  agreed  that  AMIF  has  achieved  its  goals, 
successfully  supporting  reception  conditions,  aiding  vulnerable  non-EU  nationals,  and 
helping  with  the  integration  and  return  of  TCNs.  NAs/MAs  also  acknowledge  AMIF's 
contribution  to  the  development  of  national  strategies  and  fostering  transnational 
cooperation.  

Additionally,  AMIF  has  been  effective  in  enhancing  the  capabilities  of  beneficiaries 
supporting  TCNs.  Organisation  representatives  benefiting  from  capacity-building 
programmes reported a range of positive outcomes. These included increased collaboration 
and networking with other professionals, agencies, and authorities, as well as strengthened 
organisational procedures and more efficient case-handling. Furthermore, the development 
of  new  programs  or  services  for  TCNs  and  improved  soft  and  technical  skills  to  better 
support and manage procedures related to TCNs were highlighted. Specifically, 63% of 
the beneficiaries stated they have extensively  applied the knowledge gained. Moreover, 
45%  noticed  some  changes,  while  38%  observed  major  improvements  in  how  their 
organization supports TCNs due to the support received under AMIF. 

Nevertheless,  there is  room for improvement;  MAs focus on pre-departure measures, 
family reunification, and TCN relocation, while beneficiaries emphasise reintegration and 
enhancements in the asylum process.   

The  impact  visibility  of  AMIF  can  be  limited  due  to  the  current  electronic  exchange 
system,  which  MAs  perceive  as  not  fully  capturing  on-ground  achievements,  with  no 
significant improvements observed for the 2021-2027 period.   

Both categories of consulted stakeholders agree that other groups (not targeted by AMIF) 
have benefited from its implementation. Specifically, civil society organizations, service 
providers,  and  government  agencies.  Their  views  diverge  on  additional  groups:  NAs 
believe  irregular  migrants  and  temporary  protection  beneficiaries  have  gained,  whereas 
beneficiaries disagree. 

EFFICIENCY 

127 

 
The  survey  revealed  that  various  strategies  are  used  by  NAs/MAs  to  select  the  most 
effective  projects.  From  2014  to  2020,  they  relied  on  qualitative  and  quantitative 
justifications  from  beneficiaries.  In  the  2021-2027  period,  they  are  comparing  market 
prices and learning from previous experiences, along with beneficiary justifications. The 
efficacy of these methods is further corroborated by feedback from beneficiaries: 60% of 
participants  in  AMIF  2014-2020  projects  assisting  TCNs  reported  delivering  efficient 
support  at  reasonable  costs  relative  to  the  positive  outcomes  achieved.  A  similar 
percentage  regarded  ongoing  projects  as  cost-efficient,  suggesting  that  the  expenses 
incurred so far provide significant value for money. 

Assessing the efficiency of programme management is challenging, as limited feedback 
and significant variability in estimates make it difficult to provide a single average figure 
for  the  time  NAs/MAs  spend  on  procurement  procedures,  monitoring,  and  reporting. 
However,  the  major  finding  is  that  collected  estimates  do  not  change  between  the  two 
programming  periods,  indicating  no  improvement  in  the  effort  required  to  manage 
tasks is perceived.  

The fund's efficiency is perceived to be partially reduced by the administrative burdens 
associated with regulatory obligations, which stakeholders (NAs/MAs) indicated to only 
partly justify the benefits. These obligations are viewed as more burdensome compared to 
national  programs,  while  EU  programs  have  similar  administrative  demands.  However, 
simplification  measures  have  largely  improved  program  efficiency,  with  most 
respondents  finding  them  helpful  except  for  project-level  reporting.  Additionally,  some 
Member  States  reported  not  adopting  the  "financing  not  linked  to  cost"  measures.  It  is 
important to note that this analysis is based on stakeholders’ perceptions, and they were 
not able to quantify the burdens106.  

Furthermore, the majority of consulted NAs/MAs (16) reported irregularities during audit 
missions,  including  non-compliance  with  procurement  procedures,  ineligible  expenses, 
and delayed reporting. Seven cited all three issues combined. 

FACTORS THAT INFLUENCED AMIF IMPLEMENTATION 

Both  NAs/MAs  and  beneficiaries  agreed  on  the  positive  effects  of  AMIF  resource 
allocation and the capabilities of both groups.  

Additionally, NAs/MAs highlighted the positive impacts  of implementing the Common 
European Asylum System and the Union Acquis.  

However, opinions diverged on other factors: while NAs/MAs viewed the implementation 
of the Common European Asylum System and Union Acquis as beneficial, they considered 
external  crises  and  migrant  influxes,  including  COVID-19  and  the  war  in  Ukraine,  to 
negatively impact AMIF.  

106  The  respondents  were  asked  “to  provide  an  estimate  of  the  average  time  spent,  in  both  programming 
periods,  (number of man-days that a full-time employee spent) for the preparation of : a. Direct awards (i.e., 
info to applicants, preparing calls and guidelines,  contractualization); b. Competitive awards (i.e., info to 
applicants,  preparing  calls  and  guidelines,  contractualization);  c.  Evaluation  of  proposals/  projects  ( 
screening and selecting applications); d. Monitoring of programme implementation (meetings of monitoring 
committees  and  sub  committees);  e.  Reporting;  f.  Auditing  and  on-the-spot  controls  of  projects”.  18 
respondents  answered  at  this  question,  but  considering  the  high  variance  of  the  data  collected  and  the 
different level of details it was not possible to aggregate the answers 

128 

 
 
Conversely,  most  beneficiaries  viewed  the  procedures  required  to  start  and  manage  an 
AMIF project as negative.  

All other factors were seen as having neither a distinctly positive nor negative effect by all 
stakeholders consulted.  

Notably, both NAs/MAs and beneficiaries concurred that the influencing factors for the 
2014-2020 and 2021-2027 periods were essentially identical. 

HORIZONTAL PRIORITIES  

MAs consider that eligible measures under the AMIF, especially through Member State 
programmes and EMAS, are more relevant to promote gender equality. However, when it 
comes to digital and green transitions, there is a belief that AMIF-funded initiatives either 
support these priorities less effectively or that it is difficult to assess their relevance.  

This conclusion is corroborated by beneficiaries' perceptions: they believe their projects 
have greater success in promoting gender equality compared to green or digital transitions. 

129