COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION Mid-term Evaluation of the Internal Security Fund (ISF) for the 2021-2027 programming period
Date: 2025-09-16
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: computer crime, fund (EU), help for victims, organised crime, police cooperation, policy analysis, project evaluation, radicalisation, risk management, terrorism

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.9.2025  SWD(2025) 275 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE EVALUATION  Mid-term Evaluation of the Internal Security Fund (ISF) for the 2021-2027 programming period {SEC(2025) 254 final} - {SWD(2025) 274 final}  
 
 
BACKGROUND TO THE EVALUATION 

The Regulation1 establishing the Internal Security Fund (ISF) for the 2021-2027 period, 
was  adopted  on  7  July  2021.  The  ISF  was  established  as  the  successor  of  the  Internal 
Security Fund - Police (ISF-P) for the 2014-2020 programming period. The ISF benefits 
from a larger budget, enabling more comprehensive support to Member States. With a total 
EU contribution of EUR 1.93 billion2 for the 2021-2027 programming period compared to 
the EU contribution of ca. EUR 1.21 billion for the 2014-2020 programming period. The 
ISF  is  implemented  through  shared  management,  direct  management  and  indirect 
management.  The  programming  occurs  either  at  the  Member  State  level  through  the 
Member State programmes or at the Commission level, via the Thematic Facility3.  

Moreover, the ISF is now under the Common Provisions Regulation (CPR)4 which sets the 
financial and implementation rules for most EU funds in shared management. This new 
legal framework introduced more flexible payments, improving financial management and 
easing administrative burdens. The ISF’s Thematic Facility provides greater flexibility to 
respond  to  pressing  needs  and  to  changes  in  policy  and  Union  priorities,  and  to  steer 
funding towards actions with a high level of Union added value5. Accordingly, part of the 
ISF  funding  is  periodically  allocated,  via  the  Thematic  Facility,  to  Specific  Actions,  to 
Union Actions, and Emergency Assistance.  

The ISF has one overall policy objective: “to contribute to ensuring a high level of security 
in  the  Union,  in  particular  by  preventing  and  combating  terrorism  and  radicalisation, 
serious and organised crime, and cybercrime, by assisting and protecting victims of crime, 
as well as by preparing for, protecting against and effectively managing security-related 
incidents, risks and crises.” 

The ISF has three Specific Objectives: 

1.  Improving  and  facilitating  the  exchange  of  information  between  and  within 
competent authorities and relevant Union bodies, offices and agencies and, where 
relevant, with third countries and international organisations;  

2.  Improving and intensifying cross-border  cooperation,  including  joint  operations, 
between competent authorities in relation to terrorism and serious and organised 
crime with a cross-border dimension; and  

3.  Supporting  the  strengthening  of  Member  States’  capabilities  in  relation  to 
preventing and combating crime, terrorism and radicalisation, as well as managing 
security-related incidents, risks and crises, including through increased cooperation 
between public authorities, relevant Union bodies, offices or agencies, civil society 
and private partners in different Member States. 

The implementation of the programmes in shared management started with some delay, 
due  to  the  late  approval  of  the  Member  State  programmes  and  the  nature  of  share 
management which requires Member States to set up necessary structures and procedures, 

1 Regulation (EU) 2021/1149 (OJ L 251, 15.7.2021, p. 94, ELI: http://data.europa.eu/eli/reg/2021/1149/oj 
2 Article 7(1) of the ISF Regulation. 
3 Article 8(1)(a), (b) and (c) of the ISF Regulation.  
4 Regulation (EU) 2021/1060 (OJ L 231, 30.6.2021, p. 159), ELI: http://data.europa.eu/eli/reg/2021/1060/oj 
5 Recital (37) of the ISF Regulation. 

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launch calls, and complete project selection procedures before being able to spend their 
appropriations.  

Moreover, the implementation context was considerably impacted by the Russian war of 
aggression in Ukraine and the COVID-19 pandemic. These events have had an influence 
in the initial implementation of the fund. 

According to Article 29(1) of the Regulation establishing the ISF, the Commission should 
carry out a mid-term evaluation of the ISF by 31 December 2024 to assess:  

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

(b) the efficiency of the use of resources allocated to the instrument and the efficiency 
of the management and control measures put in place to implement it; 

(c) the continued relevance and appropriateness of the implementation measures set out 
in the Regulation; 

(d)  the  coordination,  coherence  and  complementarity  between  the  actions  supported 
under the instrument and support provided by other Union funds; 

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

The temporal scope of this mid-term evaluation of the Internal Security Fund (ISF) covers 
the  period  from  1  January  2021  until  30  June  2024.  The  geographical  scope  of  the 
evaluation is the 26 Member States bound by the ISF Regulation, i.e. excluding Denmark6. 
The evaluation relied on qualitative and quantitative methods, including the consultation 
of Member States, Commission officials, implementing partners and beneficiaries.  

This document sums up the results of that evaluation. In general, figures and data used for 
the analysis had 30 June 2024 as a cut-off date. Later developments are in principle not 
covered by the evaluation. 

MAIN FINDINGS AND LESSONS LEARNED  

Effectiveness 

At different speeds, the interventions funded have been progressing in operational terms. 
At fund level and Member States’ programmes level, the distribution of committed and 
spent  resources  between  the  three  Specific  Objectives  show  that  Specific  Objective  1 
(furthering  information  exchange)  is  predominant  followed  by  Specific  Objective  3 
(strengthening of Member States’ capabilities).  

As regards the progress of output indicators towards their milestones, some Member States 
are making significant progress towards achieving their milestones and targets. However, 
ten  Member  States  have  not  reported  any  progress  for  the  output  and  result  indicators. 
Overall, 20% for milestones of output indicators have been achieved.  

6 As per Recital (66) of the ISF 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. 

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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  ISF  has  seen  significant 
improvements  compared  to  the  2014-2020  period  thanks  to  predefined  performance 
indicators, the differentiation between output and result indicators, and more explanatory 
documents and resources provided to Member States. Nonetheless, the need for Member 
States  to  adapt  to  a  new  reporting  and  monitoring  framework  explains  the  still  uneven 
provision of performance data on the implementation of ISF programmes. 

Efficiency  

As the information on performance is still insufficient, it is too early to carry out a full 
cost-effectiveness analysis, but there are indications that financial progress is advancing 
efficiently.  At  mid-term,  under  the  ISF  programmes,  Member  States  had  committed  an 
amount (EUR 409 million) equivalent to ca. 61% of the total initial allocation for 2014-
2020 ISF-P for national programmes of Member States (EUR 662 million).   

The fund demonstrates a commitment to supporting cost-effective measures. Nonetheless 
adjustments are still needed to ensure an efficient delivery of the funding and reduce the 
administrative  burden  that  is  perceived  as  substantial  by  beneficiaries  and  Managing 
Authorities. Some elements may have impacted the efficiency of implementation, notably 
the need to adapt to the new legal framework, under the Common Provisions Regulation. 
In  addition,  there  is  a  limitation  in  human  resources,  while  facing  increased  available 
funding, workload, and complexity of the various tasks, as well as a learning process due 
to new reporting mechanisms and tools. 

With  the  move  to  the  common  frame  for  shared  management  under  the  Common 
Provisions Regulation, there has been a shift toward a more transparent, accountable, and 
performance-oriented reporting system, addressing inefficiencies identified in the earlier 
period.  The  introduction  of  simplification  measures  such  as  flat  rates,  lump  sums,  and 
electronic data exchange systems have contributed to easing administrative burdens and 
streamlining certain processes.  

However,  some  beneficiaries  and  Managing  Authorities  report  that  regulatory  and 
monitoring  requirements  remain  cumbersome.  Stakeholders 
the 
administrative burden should be reduced, once they adapt to new regulatory and reporting 
requirements, as well as new ways of working.  

indicated 

that, 

Relevance 

The Fund is addressing the needs it was meant to address and has been able to respond 
both structural long-term needs and emergency needs.  

There  is  general  agreement  that  the  ISF  is  still  relevant  for  the  needs  identified  in  the 
definition of the fund and translated into the overall objective of the ISF: to improve and 
facilitate  the  exchange  of  information  (SO1),  to  improve  and  intensify  cross-border 
cooperation (SO2), and to support the strengthening of Member States’ capabilities (SO3).  

Overall, the flexibility afforded by the ISF Regulation has allowed Member States to adapt 
their Member State programmes to evolving needs over the course of implementation. The 
Thematic Facility has also proved a flexible component and helped address emerging needs 
and emergency situations.  

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However,  the  ambitions  of  the  ISF  may  be  curtailed  by  the  limited  funds  available.  A 
strategic approach is needed to make the most of the available resources with a view to 
achieving its policy and specific objectives. This should be done by ensuring resources are 
concentrated where they can have the largest impact. 

Coherence  

The Member State programmes and the Commission Work Programmes for the Thematic 
Facility are fit for purpose and coherent with other national and EU funds.  

Concerning internal coherence, there is room for reinforcing the complementarity between 
Union  Actions  and  Member  State  programmes  and  to  increase  the  awareness  and 
knowledge of the other’s respective projects.  

Awareness of stakeholders regarding the coherence and complementarity of the three funds 
in  the  area  of  home  affairs  (AMIF,  ISF  and  BMVI)  should  be  reinforced  in  order  to 
optimise the achievement of the respective policy objectives in the interrelated areas of 
border management, migration and security.  

There is coherence between the ISF and other EU Funds, particularly the Horizon Europe 
and the ESF+.  Coordination between ISF and other funds  are  achieved through  several 
coordination  mechanisms,  such  as  the  Monitoring  Committee  and  exchange  of 
information.  

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

EU Added Value 

The ISF provides an EU added value across all Fund components by supporting projects 
that go beyond the financial and operational capacities of individual Member States and 
mobilising  resources  and  reaching  otherwise  inaccessible  areas.  Notably,  transferability 
and  transnationality  bring  the  highest  added  value  of  the  ISF,  and  are  most  expressed 
though Union Actions, which should be considered in future programming.  

Stakeholders agree that by fostering cooperation, ensuring compliance with EU standards, 
and alleviating national budget constraints, the Fund significantly contributes to ensure a 
high level of security in the Union. 

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