COMMISSION STAFF WORKING DOCUMENT 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) 274 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Mid-term Evaluation of the Internal Security Fund (ISF) for the 2021-2027 programming period {SEC(2025) 254 final} - {SWD(2025) 275 final}  
 
 
Table of contents 

1. INTRODUCTION ........................................................................................................................ 1 
2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ............................... 4 

2.1. Background .......................................................................................................................... 4 

2.2. Description of the intervention and its intervention logic .................................................... 6 

2.3.   Points of comparison ........................................................................................................ 10 

3. HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD ................ 13 

3.1. Evolution of the policy context .......................................................................................... 13 

3.2 Description of the Implementation Set-up .......................................................................... 14 

3.3 ISF Implementation: Financial Progress ............................................................................. 16 

4. EVALUATION FINDINGS ....................................................................................................... 25 

4.1. To what extent was the intervention successful and why? ................................................. 25 

4.1.1. Effectiveness ............................................................................................................... 25 

4.1.2. Efficiency .................................................................................................................... 41 

4.1.3 Coherence ..................................................................................................................... 48 

4.2. How did the EU intervention make a difference and to whom? ........................................ 56 

4.3. Is the intervention still relevant? ........................................................................................ 59 

5. WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ......................................... 65 

5.1. Conclusions ........................................................................................................................ 65 

5.2. Lessons learned .................................................................................................................. 70 

ANNEX I.  PROCEDURAL INFORMATION .............................................................................. 73 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ..................................... 79 

Methodology ............................................................................................................................. 79 

Limitations and mitigation measures ........................................................................................ 80 

Output and result indicators defined in Annex VIII of the ISF Regulation. ............................. 81 

ANNEX III. EVALUATION MATRIX ......................................................................................... 83 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ........................................................... 102 
ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT ............................... 105 

Results from the consultation activities................................................................................... 106 

Feedback from targeted surveys .............................................................................................. 106 

Summary of the interviews ..................................................................................................... 115 

 
 
 
 
 
 
Abbreviations 

Term or acronym 

Meaning or definition 

AI 

AMIF 

API 

BMVI  

CCEI 

CEPOL  

CIPS 

CPR 

DG HOME 

DG INTPA 

DG JUST 

DG MARE 

DG NEAR 

DG REGIO 

DG RTD 

DISRUPT project 

DNSH 

EMAS 

EMPACT 

EOT 

ESF+ 

Artificial Intelligence 

Asylum Migration and Integration Fund 

Advanced Passenger Information System 

Border Management and Visa Instrument 

Customs Control Equipment Instrument 

European  Union  Agency  for  Law  Enforcement 
Training 

Preparedness 

Consequence 
Prevention, 
Management of Terrorism and Other Security-related 
Risks 

and 

Common Provisions Regulation 

Directorate-General for Migration and Home Affairs 

Directorate-General for International Partnerships 

Directorate-General for Justice and Consumers 

Directorate-General for Maritime Affairs and Fisheries 

Directorate-General  for  Neighbourhood  Policy  and 
Enlargement Negotiations 

Directorate-General for Regional and Urban Policy 

Directorate-General for Research and Innovation 

Enhance  digital  led  investigations,  prosecutions  and 
judicial responses for dismantling trafficking chains of 
children 

Do No Significant Harm 

Emergency Assistance 

European Multidisciplinary Platform Against Criminal 
Threats 

European Operational Team 

European Social Fund Plus 

 
 
Term or acronym 

Meaning or definition 

EU  

European Union 

EU Charter 

Charter of Fundamental Rights of the European Union 

EUDA 

Europol 

Eurostat 

FTE 

IPA 

ISEC 

ISF 

ISF-P  

JHA 

JRC 

KPI 

European Union Drugs Agency 

European Union Agency for Law Enforcement 

Statistical Office of the European Union 

full-time equivalent 

Instrument for Pre-accession Assistance 

Prevention of and Fight against Organised Crime 

Internal Security Fund 

Internal Security Fund-Police 

Justice and Home Affairs 

Joint Research Centre 

Key Performance Indicators 

MAOC-N 

Maritime Analysis and Operations Centre – Narcotics 

MPF 

MS 

MSA 

NDICI 

OLAF 

PNR 

PSA 

RAN 

SA CSA 

Mobility Partnership Facility 

Member States 

Member States Actions 

Neighbourhood,  Development  and 
Cooperation Instrument 

International 

European Anti-Fraud Office 

Passenger Name Record 

EU Protective Security Advisors 

Radicalisation Awareness Network 

‘Specific Action Support to prevent and combat child 
sexual abuse – CSA’ 

SA EMPACT 

‘Specific Action EMPACT’ 

 
 
Term or acronym 

Meaning or definition 

SA NCPF 

SA PPS II 

SA ROLEC 

SA THB 

SCOs 

SFC  

SG 

SJ 

SMEs 

SO 

SWD 

TFEU 

TFSG 

‘Specific Action Cybercrime - non-cash-payment fraud 
NCPF’ 

‘Specific  Action  Support  for  innovation  and  new 
technologies  for  the  protection  of  public  spaces  - 
Innovation PPS II’ 

‘Specific  Action  Council  Recommendation  on 
operational  law  enforcement  cooperation  –  Turning 
recommendations into joint actions 

‘Specific Action on the provision of services to victims 
of trafficking in human beings – THB’ 

Simplified cost options 

System for Fund Management in the European Union - 
Electronic data exchange system concerning the CPR 
Funds  

Secretariat-General 

Legal Service 

Small and Medium-sized Enterprises 

Specific Objective 

Staff Working Document 

Treaty on the Functioning of the European Union  

Thematic Facility Steering Group 

UNCRPD 

United  Nations  Convention  on  the  Rights  of  Persons 
with Disabilities 

 
 
1. INTRODUCTION 

The Internal Security Fund (henceforth the ‘ISF’ or the ‘Fund’), established  for the 2021-
2027 period, is applicable as of 1 January 2021 to all Member States1 except Denmark2. It 
was  established  by  Regulation  (EU)  2021/1149  of  the  European  Parliament  and  of  the 
Council of 7 July 2021 (henceforth ‘the ISF Regulation’)3. 

It builds on the 2014-2020 Internal Security Fund - Police (ISF-P)4, and pursuant to Article 
3(1)  of  the  ISF  Regulation  it  aims  to  ensure  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 
within the scope of this Regulation. 

The ISF (currently ca. EUR 1.9 billion)5 provides support to achieve its objectives (see 
Section 2.2.) and is implemented under shared, direct and indirect management modes.  

Purpose and scope of the Evaluation 

According to Article 44(5) of the Common Provisions Regulation (EU) 2021/10606 (CPR), 
Member States shall carry out a mid-term evaluation of their  programmes by 31 March 
2024.  On  the  basis  of  these  reports,  this  Staff  Working  Document  (SWD)  presents  the 
results  of  the  evaluation  of  the  initial  implementation  of  the  ISF  (hereafter  “the 
Evaluation”).   

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

1 As per Recital (67) of the ISF Regulation, in accordance with Article 3 of Protocol No 21 on the position 
of the United Kingdom and Ireland in respect of the area of freedom, security and justice, annexed to  the 
TEU  and  to  the  TFEU,  Ireland  has  notified  its  wish  to  take  part  in  the  adoption  and  application  of  this 
Regulation. 
2 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. 
3 Regulation (EU) 2021/1149 of the of the European Parliament and of the Council of 7 July 2021 establishing 
the Internal Security Fund.  
4 Regulation (EU) No 513/2014 of the European Parliament and of the Council of 16 April 2014 establishing, 
as part of the Internal Security Fund, the instrument for financial support for police cooperation, preventing 
and combating crime, and crisis management and repealing Council Decision 2007/125/JHA. 
5 As of 22 November 2024. 
6 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. 

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(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 Fund and support provided by other Union funds; 

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

Given the early stage of implementation of the Member States’  ISF programmes by 30 
June  20247,  the  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, 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 Fund 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 ISF Thematic Facility are fit for purpose and coherent with other national 
and EU funding instruments, and whether improvements should be introduced; 

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

The Evaluation covers the period from 1 January 20218 until 30 June 2024 and looks into 
the Member States’ programmes and the Thematic Facility components (Union Actions, 
Specific  Actions  and  Emergency  Assistance).  The  geographical  scope  includes  all  ISF 
participating Member States, i.e., all Member States except Denmark.  

The  Evaluation  is  based  on  thirteen  evaluation  questions  organised  around  the  five 
evaluation criteria9, as follows:  

7 The Member States’ programmes were largely adopted only during the last quarter of year 2022. Overall, 
during the accounting year 2021-2022 and in the second semester of 2022 Member States did not declare 
expenditure to the Commission and did not make interim payments to the 2021-2027 programmes. In the 
following accounting year 2022-2023, few interim payments were submitted and accepted by DG HOME. 
Information  on  performance  was  therefore  necessarily  limited:  operations  were  at  a  very  early  stage  of 
implementation and, consequently, information on performance indicators was limited.  
8 Even if the ISF Regulation was adopted on 7 July 2021, Article 35 sets out that the Regulation applies, with 
retroactive effect, from 1 January 2021. 
9 The evaluation questions are developed in Annex III. Evaluation matrix. 

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Effectiveness

• To what extent is the instrument on track to achieving its objectives?
• To what extent is the monitoring and evaluation framework suitable to inform on the

progress towards the achievement of the objectives of the instrument?

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

programming implementation, monitoring and evaluation?

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

principles?

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

opportunities as well as achievements?

Efficiency

• To what extent does the instrument support cost-effective measures?
• To what extent is the management and control system efficient?
• To what extent is further simplification achievable?

Coherence

EU Added 
Value

• To what extent is the instrument coherent with initiatives supported under its policy domain,
in particular with support under the thematic facility across the different management modes?
• To what extent is the instrument coherent with other EU funds (including other Home

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

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

Relevance

• To what extent does the instrument address the evolving needs?
• To what extent can the instrument adapt to the evolving needs?

The Evaluation is based on evidence obtained from the following sources: 

- 

- 

- 

- 

- 

- 

the output and result indicators set out in Annex VIII to the ISF Regulation10, 
which are regularly reported to the Commission by the Managing Authorities, 

the ISF Annual Performance Reports submitted every year, since 2023, by the 
Member States Managing Authorities11, 

the  ISF  mid-term  evaluations  produced  by  the  Member  States  by  31  March 
202412,  

the  Impact  Assessment  accompanying  the  2021-2027  Home  Affairs  Funds 
Regulations proposals (2018 Impact Assessment) 13, 

the  transmission  of  data  sent  by  the  Managing  Authorities  for  the  ISF 
Programme14, 

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

As the Commission was also requested to provide an ex-post evaluation report of the ISF-
P  for  the  2014-2020  programming  period15  by  June  2025,  the  Commission  decided  to 

10 Article 29(1)(a) of the ISF Regulation.  
11 Articles 29(1)(a) and 30 of the ISF Regulation.  
12 Article 44(5) of the CPR. 
13 SWD(2018) 347 final. 
14 Article 42(1) of the CPR. 
15 Article 57(2)(b) of Regulation (EU) No 514/2014. 

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carry-out  both  evaluations  of  ISF-P  (ex-post)  and  ISF  (mid-term)  simultaneously,  to 
facilitate the exchange of information and the use of common findings and analysis.  

The preparatory work for this Evaluation was conducted by an external consortium led by 
the consultancy ECORYS  on behalf of the European Commission. The methodology used 
primary and secondary data collection as well as quantitative and qualitative methods. Data 
collection  included  scoping  interviews,  desk  research  and  targeted  consultations  (i.e., 
interviews with stakeholders, targeted surveys and focus groups). It included data analysis 
concerning country and thematic case studies to provide additional input for the analysis 
of  the  different  fund  components  and  horizontal  principles.  The  data  collected  were 
triangulated to validate consistency across sources and provide well-founded insights and 
responses to the evaluation questions.  

Limitations 

The data collection and analysis processes faced several limitations, which have an impact 
on the Evaluation, notably:  

• 

Inconsistent  data  quality  and  availability16  across  Member  States  hindered 
comparisons; 

•  Member  State  mid-term  evaluations  and  target  setting  methodologies  displayed 
varying  levels  of  quality  and  depth.  Similarly,  the  Annual  Performance  Reports 
demonstrated varying levels of completeness and consistency;  

•  Data  on  output  and  result  indicators  transmitted  by  the  Member  States  via 
Electronic data exchange system concerning the CPR Funds SFC2021 included a 
number  of  omissions,  clerical  errors,  and  revealed  differences  in  how  Member 
States interpret, measure and report data; 

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

it difficult to measure the ISF’s programmes’ progress accurately; 

•  Limited  institutional  memory  owing  to  staff  changes  within  the  Managing 

Authorities may have led to the ommission of some information;   

•  As  the  study  for  the  ISF  was  conducted  at  the  same  time  as  the  mid-term 
evaluations of the  Asylum, Migration and Integration Fund (AMIF) and Border 
Management  and  Visa  Policy  Instrument  (BMVI),  which  collectively  form  the 
‘Home  Affairs  Funds’.  Participation  in  the  targeted  survey  was  voluntary  and 
survey fatigue may have set in and caused a lower response rate.    

2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Background  

Article 67(3) of the Treaty on the Functioning of the European Union (TFEU) sets out that 
the Union  shall endeavour to ensure a high level of security. This overarching objective 

16 The reduced availability of data was partially due to the early implementation stage of ISF programmes of 
Member States; most Member States’ programmes (19) were approved in Q4/2022, only roughly a year and 
a half before the cut-off date of the ISF mid-term evaluation. 

4 

 
 
shall be achieved inter alia through measures to prevent and combat crime, measures for 
coordination  and  cooperation  between  law  enforcement  authorities  and  other  Member 
States’ national authorities (including coordination and cooperation with relevant Union 
agencies  and  other  relevant  Union  bodies,  and  with  relevant  third  countries  and 
international organisations as well as with the help of private partners and civil society).  

The  Internal  Security  Strategy  for  the  European  Union  (‘Internal  Security  Strategy’)17, 
adopted by the Council in February 2010, constituted a shared agenda for tackling common 
internal  security  challenges  for  the  2010-2015  period.  This  Strategy’s  principles  and 
guidelines were later translated into concrete actions by the Commission Communication 
of 22 November 2010 entitled ‘The EU Internal Security Strategy in Action: Five steps 
toward a more secure Europe’. For the 2015-2020 period, the Commission, the Council 
and the European Parliament defined common priorities as set out in the European Agenda 
on Security of April 201518. This Agenda was reaffirmed by the Council in the renewed 
Internal Security Strategy of June 2015 and by the European Parliament in its Resolution 
of July 2015, namely by preventing and combating terrorism and radicalisation, serious 
and organised crime and cybercrime. Those common priorities have been reaffirmed for 
the 2020-2025 period in the EU Security Union Strategy and the Counterterrorism Agenda.  

To  achieve  an  effective  and  genuine  high  level  of  internal  security  throughout  the  EU, 
Member States have been provided with financial support from the Union. The first EU 
funding  for  internal  security  purposes  was  the  Framework  Programme  on  Police  and 
Judicial  Cooperation  in  Criminal  Matters  (AGIS)19 running  between  2003-2007,  which 
was  later  followed  by  the  General  Programme  on  Security  and  Safeguarding  Liberties 
covering the Specific Programmes ‘Prevention of and Fight against Crime’20 (ISEC) and 
‘Prevention, Preparedness and Consequence Management of Terrorism and other Security 
related  risks’21  (CIPS)  during  the  2007-2013  programming  period.  These  programmes 
were adopted during the pre-Lisbon intergovernmental period of EU police and security 
cooperation  based  on  Articles  30,  31  and  34(2)(c)  of  the  Treaty  on  European  Union. 
Following the entry into force of the Lisbon Treaty, Articles 82(1), 84 and 87(2) TFEU 
provide the legal bases for the financial instruments supporting the EU’s internal security 
policy. The ISF-P (2014-2020 period)22 and the ISF (2021-2027 period) were established 
with  the  aim  of  preventing  and  fighting  serious  and  organised  crime,  terrorism  and 
radicalisation,  corruption,  and  cybercrime,  and  by  assisting  and  protecting  victims  of 
crime. 

Funding from the EU budget focuses on actions for which Union intervention can bring 
greater added value compared with action by Member States alone. These may include the 
joint training of staff and police cooperation, as well as judicial cooperation in criminal 
matters involving Member States’ competent authorities and Union agencies, especially as 
regards  the  exchange  of  information,  increased  operational  cooperation  and  support  for 
necessary efforts to  strengthen capabilities to  prevent  and combat terrorism  and serious 

17 COM(2010) 673 final 
18 COM(2015) 185 final 
19 Council Decision 2002/630/JHA. 
20 Council Decision No 2007/125/JHA. 
21 Council Decision 2007/124/EC. 
22 Regulation (EU) No 513/2014.  

5 

 
 
and organised crime. However, funding cannot support actions limited to the maintenance 
of public order at Member State level and actions with a military or defence purpose23.  

2.2. Description of the intervention and its intervention logic 

The  ISF  aims  primarily  at  addressing  transnational  challenges  rather  than  national 
priorities. By prioritising cross-border internal security issues, the ISF aims to strengthen 
the  EU's  collective  response  to  internal  security  threats  that  individual  Member  States 
cannot effectively tackle alone.  

The ISF rationale is reflected in its 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”24.  

To achieve the policy objective, the ISF Regulation sets out three specific objectives25:  

Specific  Objective  1  (SO1):  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;  

Specific Objective 2 (SO2): 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  

Specific  Objective  3  (SO3):  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. 

To  address  these  objectives,  an  intervention  logic  was  developed  setting  out  the  causal 
links between the  ISF’s  needs, activities, outputs,  results and the expected intermediate 
effects.  

The critical needs to enhance EU internal security were identified as a result of the needs 
analysis and verified in a collaborative process with Managing Authorities, beneficiaries, 
and the Commission. To meet these needs, the ISF proposes a range of activities which  
are  directly  linked  to  the  implementation  measures  set  out  in  Annex  II  of  the  ISF 
Regulation26. The activities can, in turn, improve mutual understanding and coordination 
among different law enforcement authorities.  

23 Article 5(5)(a) and (b) of the ISF Regulation.  
24 Article 3(1) of the ISF Regulation.  
25 Article 3(2) of the ISF Regulation.  
26 Figure 2 sets out the intervention logic diagram and simplifies the activities linked to the implementation 
measures and does not present them per Specific Objective to avoid duplication. 

6 

 
 
 
The  outputs  of  these  activities  are  direct  deliverables,  which  are  expected  to  lead  to 
results, which include e.g. the increased interoperability of ICT systems, increased staff 
involvement in cross-border operations.  

Finally, these results are expected to lead to several intermediate effects that enhance a 
high level of security in the EU and further the ISF’s specific objectives (Figure 1). On the 
one  hand,  three  of  these  intermediate  effects  are  directly  linked  to  the  three  specific 
objectives of the ISF, i.e. increased exchange of information (SO1), enhanced cooperation 
between Member States, agencies and third countries in preventing and fighting serious 
and  organised  crime  and  terrorism  (SO2)  and  increased  capabilities  to  tackle  internal 
security threats (SO3). On the other hand, three of the expected intermediate effects are 
horizontal  and  expected  to  contributed  to  all  three  specific  objectives,  i.e.  fostering 
innovative  practices  to  tackle  internal  security  threats,  increased  involvement  of  civil 
society in internal security matters and fostered cooperation between private entitites and 
law enforcement authorities. 

To  better  illustrate  the  connection  between  the  needs  and  how  the  ISF  implementation 
addresses those needs, an overview has been developed for each specific objective.  

Specific Objective 1: Exchange of Information 

The objective of SO1 is to improve and facilitate 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. The implementation 
measures to achieve this aim include27:  

•  ensuring  the  uniform  application  of  Union  acquis  on  security  by  supporting  the 
exchange of relevant information (e.g. via Prüm, PNR and SIS II, etc. Point 1 of);  

•  setting  up,  adapting  and  maintaining  security-relevant  EU  and  decentralised 
information  systems,  including  ensuring  their  interoperability,  and  developing 
appropriate tools to address identified gaps;  

• 

increasing  the  active  use  of  security-relevant  EU  and  decentralised  information 
systems, ensuring that those systems are provided with high quality data; and  

•  supporting relevant national measures, including the interconnection of security-
relevant  national  databases  and  the  connection  of  those  databases  to  Union 
databases, 

These  activities  seek  to  further  information  exchange  by  providing  the  necessary 
technological  infrastructure.  The  outputs  of  these  activities  are  direct  and  measurable 
deliverables,  e.g.  the  number  of  ICT  systems  set  up  or  maintained  and  the  number  of 
equipments items purchased. In turn, these deliverables may lead to results, such as the 
increase  in  the  number  of  ICT  systems  made  interoperable  in  the  Member  States/with 
security-relevant EU and decentralised information systems/with international databases.  

27 Point 1 of Annex II of the ISF Regulation. 

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Specific Objective 2: Cross-border Cooperation 

SO2  aims  at  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. The interventions to achieve this aim are28: 

• 

• 

• 

increasing  the  number  of  law  enforcement  operations  involving  two  or  more 
Member States, including operations involving other relevant actors, in particular 
through facilitating and improving the use of joint investigation teams, joint patrols, 
hot pursuits, discreet surveillance and other operational cooperation mechanisms 
in  the  context  of  the  EU  policy  cycle,  with  special  emphasis  on  cross-border 
operations;  

improving the coordination and increasing the cooperation of competent authorities 
within  and  between  Member  States  and  with  other  relevant  actors,  for  example 
through networks  of specialised national  units, Union networks and  cooperation 
structures, and Union centres; and  

improving  inter-agency  cooperation  at  Union  level  between  the  Member  States, 
and between Member States and relevant Union bodies, offices and agencies, as 
well as cooperation at national level among the competent authorities within each 
Member State. 

These  activities  advance  cross-border  cooperation,  and  the  outputs  may  lead  to  the  
corresponding increase in the number of cross-border cooperations (of joint investigation 
teams and/or EMPACT operational actions), and in the purchase of equipment and means 
of transport for the purpose of cross-border operations. These outputs are then expected to 
lead to results such as the increase in assets frozen and in the quantity of illicit drugs and 
weapons seized in the context of cross-border operations, as well as in the number of staff 
involved in cross-border cooperation. 

Specific Objective 3: Strengthening of Member States’ Capabilities 

SO 3 has the aim of 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 interventions to achieve this aim are29: 

• 

training,  exercises  and  mutual 

increasing 
learning,  specialised  exchange 
programmes  and  sharing  of  best  practices  in  and  between  Member  States’ 
competent authorities, including at local level, and with third countries and other 
relevant actors; 

•  exploiting  synergies  by  pooling  resources  and  knowledge  and  sharing  best 
practices between Member States and other relevant actors, including civil society, 
through, for example, the creation of joint centres of excellence, development of 
joint risk assessments, or common operational support centres for jointly conducted 
operations; 

28 Point 2 of Annex II of the ISF Regulation. 
29 Point 3 of Annex II of the ISF Regulation. 

8 

 
 
 
•  promoting and developing measures, safeguards, mechanisms and best  practices 
for the early identification, protection and support of witnesses, whistleblowers and 
victims of crime and developing partnerships between public authorities and other 
relevant actors to this effect;  

•  acquiring  relevant  equipment  and  setting  up  or  upgrading  specialised  training 
facilities  and  other  essential  security-relevant 
increase 
preparedness,  resilience,  public  awareness  and  adequate  response  as  regards 
security threats; and  

infrastructure 

to 

•  protecting  critical  infrastructure  against  security-related  incidents  by  detecting, 

assessing and closing vulnerabilities. 

These activities aim at strenghthening Member States’s capabilities and may have several 
outputs such as the increase in the number of projects to prevent crime, to assist victims 
of crime, and of victims of crimes assisted. These outputs are expected to lead to results, 
such  as  the  increase  the  number  of  initiatives  developed/  expanded  to  protect/  support 
witnesses and whistleblowers. 

9 

 
 
 
 
Figure 1 – Intervention logic of the ISF 

10 

 
 
2.3.   Points of comparison  

EU funding for internal security has developed over several programming periods. Given 
this, and the early stage of delivery of the ISF 2021-2027, it is hard to delineate where 
results from one programming period begin and end as there are also differences across 
Member States and external factors that contributed to progress (or to the lack thereof on 
some aspects). As such, it is useful to highlight the main structural differences between the 
ISF and ISF-P, starting with the allocation of funds, and several structural differences. This 
is complemented by the different elements for assessing the performance of the ISF against 
its predecessor instrument ISF-P, and against other points of comparison (e.g. comparison 
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  Sections  5.1. 
(conclusions) and 5.2 (lessons learned). To face those challenges, several features were 
introduced in the policy set-up and delivery model of the ISF 2021-2027. 

Comparison with ISF-P  

The main point of comparison is the performance between the ISF and its predecessor the 
ISF-P – 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  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 202530. 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  Section  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. 

30 Article 1(5) of Regulation (EU) 2022/585 of 6 April 2022. 

10 

 
 
 
Accordingly, elements from the ex-post evaluation are by definition part of the mid-term 
evaluation  and  vice  versa,  since  these  specific  tools  looked  at  implementation  as  a 
continuum.  This  has  allowed  to  have  a  retrospective  view,  as  well  as  for  the  mid-term 
evaluation  to  comply  with  the  legal  requirement  to  take  into  account  the  results  of  the 
retrospective evaluation for the 2014-2020 programming period31. 

In  terms  of  funding,  the  ISF  benefits  from  a  larger  financial  allocation  compared  to  its 
predecessor, with an initial total EU contribution of ca. EUR 1.93 billion32 for the 2021-
2027  programming  period  compared  to  ca.  EUR  1.21  billion  for  the  2014-2020 
programming period.  

The financial progress and progress of output and result indicators over the first three years 
of implementation of the ISF (2021-2024) was compared to that of the ISF-P (2014-2017). 
In terms of indicator progress, it should be noted that the list of indicators defined in the 
ISF Regulation are not related to the ISF-P indicators nor do they result from an evolution 
from the 2014-2020 programming period. Hence, aggregating the values of indicators is 
methodologically challenging, and the values are taken at different points in time (end of 
year for ISF-P/mid-year for the ISF).  

Comparison with AMIF, BMVI and Cohesion Policy Funds 

A  comparison  with  the  AMIF  and  BMVI,  and  the  Cohesion  Policy  Funds’  financial 
progress has also been made, albeit with many caveats related to the different nature of the 
Funds. 

Legal Framework 

A significant point of comparison concerns the change in the legal framework governing 
the ISF. In the previous programming period, ISF-P was established by Regulation (EU) 
No  513/2014  (ISF-P  Regulation)  and  the  overall  implementation  of  the  Home  Affairs 
Funds was governed by a separate legal act, i.e. the Horizontal Regulation.33 For the 2021-
2027 programming period, in addition to their respective Fund-specific Regulations, all 
Home Affairs Funds are governed by the CPR, which lays down common provisions for 
eight  EU  Funds  subject  to  shared  management.  The  rationale  for  including  the  Home 
Affairs Funds under the CPR was to enhance the overall coherence and synergies among 
those Funds. The CPR has also enhanced the legal framework for simplified cost options 
which  can  be  used  at  two  reimbursement  levels:  (i)  reimbursement  of  the  Union 
contribution  by  the  Commission  to  the  Member  States’  programmes  and  (ii) 
reimbursement of grants provided by the Member States to beneficiaries34.  

Under the ISF-P, reimbursement of expenses was the primary method of funding, with one 
yearly  payment  application  per  Member  State  programme.  The  ISF  introduced  a  more 
flexible system of payments, allowing for pre-financing and advance payments, notably 

31 Article 29(1)(e) of the ISF Regulation. 
32 Article 7(1) of the ISF Regulation. 
33 Regulation (EU) No 514/2014 of the European Parliament and of the Council of 16 April 2014 laying 
down general provisions on the Asylum, Migration and Integration Fund and on the instrument for financial 
support for police cooperation, preventing and combating crime, and crisis management. 
34 Article 53 of the CPR. 

11 

 
 
up to six payment applications of Member States per programme35, thus accelerating the 
disbursement of funds and easing the administrative burden on Member States.  

Performance Framework 

The  new  legal  framework  also  entailed  a  refocus  on  performance.  The  reporting  and 
monitoring framework was reinforced with the introduction of the requirement for Member 
States to establish a performance framework pursuant to Article 16 of the CPR, to allow 
monitoring  and  evaluating  of  programme  performance  during  implementation  of  the 
programme  and  to  contribute  to  measuring  the  overall  performance  of  the  Fund.  The 
performance framework consists of (a) output and result indicators (b) milestones to be 
achieved by the end of 2024 for output indicators and (c) targets to be achieved by the end 
of 2029 for output and result indicators.  

Pursuant to Article 27(3) of the ISF Regulation, common output and result indicators on 
the progress of the Fund towards the Specific Objectives are laid down in Annex VIII of 
the ISF Regulation. Targets and milestones36 also allow the Commission and the Member 
States to measure progress towards the achievement of the Specific Objectives37. Pursuant 
to Article 27(3) of the ISF Regulation, the baseline for output indicators was set 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 indicators. 

The  definition  of  targets  is  in  the  hands  of  the  Member  States  in  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 
that  of  other  CPR  regulated  funding  and  allows  for  a  close  monitoring  of  the 
implementation  and  performance  of  the  programmes.  To  ensure  homogenous  reporting 
and facilitate aggregation at EU level, even prior to the negotiation on the Member State 
programmes,  the  Commission  provided  the  Member  States  with  a  metadata  set,  with  a 
standardised definition of each indicator in the performance framework. This will allow to 
aggregate targets and results at EU level in order to assess overall progress when it comes 
to the retrospective evaluation. 

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

Increased Flexibility 

The 2018 Impact Assessment for ISF concluded that more flexibility would be needed in 
the implementation of national programmes and a distribution system should be adaptable 
in  order  to  ensure  an  appropriate  response  to  changing  needs.  The  mid-term  review 
envisaged  for  the  ISF-P  was  mainly  a  policy  process  with  no  related  additional 
allocations38. Only one top-up took place in 2017.  

35 Article 91(1) of the CPR. 
36 Article 2(11) and (12) of the CPR, respectively. 
37 Article 16(3) of the CPR 
38 The ISF-P did not include the possibility of providing for an additional envelope to be distributed across 
the national programmes as a result of the mid-term review. 

12 

 
 
The ISF introduced increased flexibility. First, based on the insight gained in the 2014-
2020  programming  period  that  fixed  allocations  do  not  always  permit  to  reflect  the 
changing needs of the Member States over time, the ISF Regulation sets out the allocation 
of  additional  funding  following  a  mid-term  review39,  ensuring  that  funding  is  allocated 
based on performance and the effective use of previous allocations. Second, 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 to changes 
in policy and Union priorities, and to steer funding towards actions with a high level of 
Union added value”40. Accordingly, part of the ISF funding is periodically allocated, via 
the Thematic Facility, to its components, namely to Specific Actions, to Union Actions, 
and Emergency Assistance.  

3. HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD 

3.1. Evolution of the policy context  

Serious and organised crime is on the rise, a trend that has been further exacerbated by 
the changes in the geopolitical landscape of Europe in the last years: Russia’s aggression 
against Ukraine, the Hamas terrorist attack in October 2023, the military escalation in the 
Middle  East,  and  the  COVID-19  pandemic.  Criminal  groups  operate  in  a  networked 
environment across multiple countries and engage in various illegal activities, including 
drug- and human trafficking, illicit firearms trafficking, financial crime, and money 
laundering. They use electronic communications to advertise illicit goods and services, 
and  to  access  expertise  and  sophisticated  tools  enabling  their  illegal  activities  and  use 
legitimate businesses to conceal their crimes and infiltrate the legal economy, using their 
profits  to  fund  further  criminal  activities.  Criminal  activities  are  often  worldwide,  and 
criminals navigate constantly between the physical and digital worlds, which contributed 
to an increase in cybercrime and child sexual abuse.  

Terrorism remains a serious threat demonstrating the need to further counter terrorism, 
prevent radicalisation, and protection of public spaces and critical infrastructure/entities. 
Tackling these types of criminality remained a key strategic priority and required the EU 
to  further  extend  its  support  to  Member  States  and  the  need  to  enhance  and  improve 
information  exchange  and  cross-border  operational  cooperation  has  proven  of 
paramount importance due to their cross-cutting and vital role in meeting these threats as 
well as by a closer cooperation with third countries at international level.  

The ISF was established to address these needs which can be categorised into the following 
6 policy fields: (i) Counterterrorism, including i.a. prevention of radicalisation, protection 
of  public  spaces  and  critical  infrastructure/entities,  and  CBRN-E;  (ii)  Organised  crime, 
including i.a. drug trafficking, trafficking in human beings, firearms trafficking, migrant 
smuggling, corruption, and money laundering; (iii) Cybercrime, including i.a. child sexual 
abuse online;  (iv) Law enforcement cooperation (cross-border operational cooperation); 
(v) Information exchange; and (vi) Cooperation with third countries. 

39 Article 14 of the ISF Regulation.  
40 Recital (37) of the ISF Regulation. 

13 

 
 
3.2 Description of the Implementation Set-up 

The “Home Affairs Funds” for the 2021-2027 programming period amount to EUR 20.6 
billion41. 

Figure 2 - Total budget for the three EU Home Affairs Funds 

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  Facility42. 
Funding  from  the  Thematic  Facility  is  used  for  the  following  components:  Specific 
Actions,  Union  Actions  and  Emergency  Assistance. Together  with  the  Member  State 
programmes, these are referred to in this study as fund components.  

Shared management receives the largest share of the financial envelope, accounting for 
70%  of  the  initial  budget  allocation43.  At  the  beginning  of  the  programming  period, 
Member States design their programmes (hereinafter also referred to as Member States’ 
programmes) to directly address national and EU objectives through the measures and the 
actions  listed  in  Annexes  II44,  III  and  IV  of  the  ISF  Regulation.  To  implement  their 
programmes,  Member  States  have  to  establish  the  composition  and  functions  of  the 
Monitoring  Committee  according  to  Articles  38  to  40  of  the  CPR.  The  Commission 
follows  the  implementation  under  shared  management  by  examining  the  Annual 
Performance  Reports  and  the  cumulative  data  Member  States  submit  on  financial  and 
operational progress through the year (data on operational progress is reported five times 

41 As of 22 November 2024. 
42 Article 8(1)(a), (b) and (c) of the ISF Regulation.  
43 Article 7(2)(a) of the ISF Regulation.  
44 Article 13 of the ISF Regulation.   

14 

 
 
 
 
a year and financial data twice a year), while payment applications may be filed up to 6 
times per year.  

The Thematic Facility accounts for the remaining 30% of the ISF’s initial allocation. The 
Thematic Facility allows for a more flexible allocation of resources to address priorities 
with a high Union added value or to respond to urgent needs or emerging threats. The share 
of the budget managed by the Commission is subject to the Multiannual Work Programmes 
which  are  developed  directly  by  the  Commission  in  agreement  with  Member  States’ 
representatives and in consultation with relevant stakeholders. This flexibility ensures that 
both national and EU-wide priorities can be addressed efficiently while maintaining a high 
level of responsiveness to new developments in the internal security landscape. Resources 
from  the  Thematic  Facility  can  be  channelled  to  the  Member  States’  programmes  via 
Specific Actions, implemented as Emergency Assistance or in the case of Union Actions, 
directly managed by the Commission. 

Specific Actions introduced by  the ISF  Regulation are transnational  or national  projects 
that bring EU added value in accordance with the ISF’s objectives, for which one, several 
or all Member States may receive an additional allocation to their programmes45. This is a 
new  and  hybrid  funding  modality  which  has  common  elements  with  Union  Actions 
concerning their calls and selection phases and with regular Member States’ Actions under 
shared management, as Specific Actions are integrated into the programmes. Priorities for 
Specific Actions are set by the Commission and translated into the Thematic Facility Work 
Programmes,  approved  following  the  comitology  procedure46.  Calls  for  Expression  of 
Interest  are  drafted  and  launched  by  the  Commission  which  is  also  in  charge  of  the 
selection process. In terms of co-financing rate, Specific Actions may reach 90% of EU 
co-financing. Member States are entitled to amend their ISF programme, which will have 
to  be  approved  by  the  Commission,  to  incorporate  the  Specific  Actions  provided  that 
funding is subsequently earmarked as such in their respective programmes47 and ensure 
their implementation and monitoring, as for any other actions implemented under shared 
management.  

Union  Actions  are  transnational  projects  or  projects  of  particular  interest  to  the  EU 
implemented  in  accordance  with  the  ISF  objectives.48  They  are  meant  to  complement 
Member States’ efforts at national level and boost cooperation among stakeholders from 
law enforcement, civil society, and private sector. They are designed to implement internal 
security policy priorities in an innovative manner, to facilitate policy analysis and provide 
insights  for the development of new policies. Through Union  Actions, the Commission 
ensures the achievement of the Policy and Specific Objectives of the ISF and steers the 
direction  of  cooperation  and  exchange  of  best  practices  among  Member  States.  The 
overwhelming majority of Union Actions are implemented under direct management, with 
a small  number of interventions  carried out  under  indirect  management  (less  than 5%). 
Direct  management  actions  are  carried  out  through  direct  awards  (e.g.  awards  to 
transnational law enforcement networks promoting cooperation and information exchange 
among stakeholders in various policy fields), calls for proposals (open to stakeholders from 
the  public,  private  and  civil  society  sectors,  or  restricted);  and  procurement  contracts. 
Indirect  management  interventions  are  implemented  by  entrusted  entities  through 

45 Article 2(15) of the ISF Regulation. 
46 Commission Implementing Decision of 23.11.2022 on the financing of the components of the Thematic 
Facility under the Internal Security Fund and the adoption of the work programme for 2023, 2024 and 2025.  
47 Article 15(1) of the ISF Regulation.  
48 Article 2(17) of the ISF Regulation. 

15 

 
 
contribution agreements, such as the Mobility Partnership Facility (MPF), and agreements 
with the Joint Research Centre (JRC), and others.  

Emergency  Assistance  has  the  aim  of  strengthening  the  Union’s  capacity  to  react 
immediately to  security-related incidents  or to  newly emerging  threats  to the  EU. Such 
assistance should not be provided to support mere contingency or long-term measures, or 
to  address  situations  where  the  urgency  to  act  results  from  the  failure  of  competent 
authorities to plan and react properly. It may be provided either through grants (direct and 
indirect  management)  or  through  Member  State  programmes49,  even  if  this  latest 
possibility has not yet been applied.  

3.3 ISF Implementation: Financial Progress  

The  initial  envelope  of  the  ISF  was  EUR  1.93  billion.  Since  the  adoption  of  the  ISF 
Regulation, it has decreased to EUR 1.90 billion up to 30 June 2024. Despite the addition 
of  EUR 3.2 million  from  AMIF  to  shared  management,50  the  addition  to  the  Thematic 
Facility  of  EUR 7 million  by  the  budgetary  authorities  and  of  EUR 2.5 million  (unused 
appropriations from Agencies), the ISF was reduced by EUR 47 million to finance several 
new legislative initiatives and reinforce the Agencies’ budgets.  

Of the initial total financial envelope, EUR 1.35 billion (70%) are to be allocated to the 
Member States’ programmes in two subsequent phases. The initial allocation is based 
on the criteria outlined in Annex I of the ISF Regulation. Following the mid-term review, 
an additional allocation (EUR 225 million) is contingent upon Member States fulfilling the 
condition of their payment applications covering at least 10% of their initial allocation to 
the  Member  States’  programmes51.  Resources  allocated  for  Member  States  that  do  not 
reach the threshold will be transferred to the Thematic Facility52. The remaining EUR 579 
million (30%) of the ISF’s initial total allocation is allocated to the Thematic Facility. 

Financial progress across fund components and management modes, is presented only in 
terms of EU contribution (national co-financing excluded) 53.  

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 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-

49 Under the 2021-2022 and 2023-2025 Thematic Facility Work Programmes, EMAS is included under the 
envelopes for grants and EUR 3 million were set aside to this end.  
50 Article 26(1) of the CPR. 
51 Article 14(2) of the ISF Regulation. 
52 Article 10(2) of the ISF Regulation.  
53 Through this document, the following terminology is used when it comes to financial progress: 
Allocated resources correspond to the resources that have been designated to each specific objective and 
each Member State. They represent the programming stage of the ISF. 
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. 
Spent resources refers to EU payments made in response to an interim payment application to the EU for 
eligible expenditure incurred and paid to project beneficiaries. 

16 

 
 
up  the  necessary  structures  and  procedures,  as  well  as  for  completing  project  selection 
procedures, which is a prerequisite to spending the budget.  

Allocated resources 

Up to 30 June 2024, the total of the allocated resources amounted to EUR 1.535 billion 
(80.9% of the total ISF budget). This includes the initial allocation to the Member State 
programmes (ca. 59.7% of the total ISF budget) and the first two Thematic Facility Work 
Programmes for 2021-202254 and 2023-202555 (ca. 21.3%56 of the total ISF budget). Union 
Actions have received 19.1% of the overall allocated resources, whereas Specific Actions 
have received 2% and EMAS 0.2%.  

Figure 3 - Allocation of the Total ISF Budget: Distinguishing Planned and Unplanned Resources 
by Fund Component 

Source: Preparatory study based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data. * Numbers 
might add up to more than 100% due to rounding.  

Up  to  30  June  2024,  the  initial  share  of  resources  (70%  -  30%)  set  out  in  the  ISF 
Regulation57 has increased to 74% (Member States’ programmes) - 26% (Thematic 
Facility).   This is because there has been two flows of funding out of the Thematic Facility 
which  mainly  impacted  Union  Action  grants  during  2021-2024:  first,  the  amounts  of 
Specific  Actions  of  EUR  38.5  million  increase  the  Member  States’  programmes,  and 
second,  nearly  10%  of  the  entire  Thematic  Facility  allocation  2021-2027  has  been 

54 C(2021) 8460 final.  
55 C(2022) 8334 final.  
56 Numbers might add up to more than 100% due to rounding.  
57 Article 7(2) of the ISF Regulation.  

17 

 
 
 
transferred to EU Agencies (EUR 47 million) which  has de facto  reduced the envelope 
available between 2021-2025 for Union Actions grants. 

Figure 4 - Distribution of ISF Resources allocated – MSA and Thematic Facility 

74%

26%

MSA

Thematic Facility

Source: Preparatory study based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data 

The distribution of  allocated resources at  Fund level  between the 3 Specific Objectives 
shows that SO3 (EUR 832.8 million or 54.2%) is  predominant  followed by SO1 (EUR 
439.3 million or 28.7%) and SO2 (EUR 197.6 million or 12.8%). At fund component level, 
the allocated resources for the Member States’ programmes concentrate primarily on SO3 
and SO1, whereas Specific Actions mainly target SO2 and, to a lesser extent, SO3. Union 
Actions target primarily SO3 and EMAS is only focusing on SO3. 

Figure 5 - Allocated Resources by Specific Objective and Fund Component 

s
n
o

i
l
l
i

M

EUR 900

EUR 800

EUR 700

EUR 600

EUR 500

EUR 400

EUR 300

EUR 200

EUR 100

EUR 0

0,4%

2,5%

38%

58%

1,1%

0,6%

99,4%

11,1%

14,9%

73,9%

SO1 - Information exchange

SO - 2 Cross-border
cooperation

SO - 3 Strenghtening MS
capabilities

MSA

SA

UA - Direct

UA - Indirect

EMAS

Source: Preparatory study based on the most recent MS programmes and data transmitted up to 30 June 2024, and TF 
programming data. * Numbers might add up to more than 100% due to rounding.  

18 

 
 
 
s
n
o

i
l
l
i

M

As far as shared management is concerned, the largest Member States (DE, FR, ES, IT and 
PL)  show  the  highest  amount  of  allocated  resources,  whereas  relatively  small  Member 
States (HR, LT, and LV) receive a sizable amount owing to the ISF allocation criteria. 

Figure 6 - Total Allocated Resources by Member State (EUR in millions) 

120

100

80

60

40

20

0

DE FR ES

IT PL RO EL BG SE PT HU NL

FI HR CZ SK BE LV

LT AT EE

SI CY MT IE

LU

Source: Preparatory study, based on  data transmitted up to 30 June 2024. 

MSA

SA

Member  States’  programmes  show  significant  differences  in  the  prioritisation  of  funds. 
For SO3, the allocated EU average is 44.8% and thirteen Member States clearly prioritise 
this SO. HR (74.3%), CZ (66.6%) and AT (65.8%) show the highest level of prioritisation. 
For SO1, the planned EU average is 38.8%, and seven Member States clearly prioritise 
this SO with BE (78.6%) and MT (74%) showing the highest level of prioritisation. Six 
Member States maintain a balanced allocation to SO3 and SO1. For SO2, the allocated EU 
average is  16.5%.  HU (36.2%) and SI  (32.3%)  show the highest level  of prioritisation, 
whereas SK (10.7%), CY (10.7%), Malta (11%) and IT (11.1%) and EE (6.6%) stay close 
to or below the minimum threshold of 10% for SO258.  

58 Article 13(2) of the ISF Regulation sets out that Member States shall allocate a minimum of 10% of the 
resources allocated to them to SO1 and a minimum of 10% to SO2.  

19 

 
 
 
Figure 7 -  Distribution of ISF Allocated Resources by Specific Objective Across Member States 

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

BE MT LT FR PL LU IE

PT ES EL RO DE SK

HU SI EE CY NL FI

IT LV BG SE AT CZ HR

Focus on SO1 

Balance SO1 & SO3

Focus on SO3

SO1 - Increasing the exchange of information

SO2 - Intensifying cross-border cooperation

SO3 - Strengthening of MS capabilities

Source: Preparatory study, based on the most recent MS programmes up to 30 June 2024 

In accordance with the ISF provisions59, Member States Actions make up a higher share 
of the allocation of resources with EUR 701.3 million, followed by Annex IV actions60 
with  EUR  251.8  million.  Member  States  have  programmed  EUR  113.1  million  for 
Operating  Support  which  accounts  for  ca.  8.3%  of  the  ISF’s  initial  allocation.  Finally, 
Technical  Assistance  is  a  6%  flat  rate  applied  to  all  payment  applications61.  Amounts 
planned for Specific Actions 2021-2025 account for EUR 38.5 million. 

59 Article 12 of the ISF Regulation sets out the following co-financing rates: contribution from the EU budget 
shall not exceed 75% of the total eligible expenditure for a Member State Action, 90% for Specific Actions 
and Actions listed in Annex IV, and may be increased up to 100% for Operating Support and Emergency 
Assistance.   
60 Annex IV of the ISF Regulation lays down Actions which are eligible for higher co-financing rates as they 
target key policy areas with high EU added value. 
61 Art. 36(5) of the CPR. 

20 

 
 
 
Figure 8 - Breakdown of Resources Allocated in Shared Management by Co-Financing Rate (EUR 
in millions) 

s
n
o

i
l
l
i

M

EUR 800

EUR 700

EUR 600

EUR 500

EUR 400

EUR 300

EUR 200

EUR 100

EUR 0

701,306,620 

251,812,974 

113,109,053 

65,535,466 

38,500,000 

Regular actions

Annex IV actions

Operating support

Technical assistance

Specific actions

Source: Preparatory study, based on the most recent MS programmes up to 30 June 2024 

Committed resources 

The committed and spent resources are at 43.3%. At fund component level, these resources 
range between 30.9% for EMAS and 81.9% for Specific Actions up to 30 June 2024. Union 
Actions have a rate of 43.6% and Member States Actions reach 41.8%. Resources not yet 
committed are above 50% for all fund components except Specific Actions (18.1%), which 
is consistent with the early stage of implementation of the ISF.  

Figure 9 - Financial Progress of the ISF: Distribution of Allocated and Committed Resources by 
Fund Component 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

58.2%

38.4%

3.4%

MSA

18.1%

80.5%

1.4%
SA

56.4%

69.1%

56.7%

43.6%

-
UA

30.9%

EMAS

40.7%

2.5%

ISF

Spent

Decided not yet spent

Planned not yet spent nor decided

Source: Preparatory study based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data  

At  Fund  level,  the  committed  and  spent  resources  vary  between  the  three  Specific 
Objectives,  with  34.6%  for  SO2,  43.4%  for  SO3  and  46.9%  for  SO1.  The  remaining 
allocated resources are above 50% for all Specific Objectives, reflecting the early stage of 
ISF implementation.  

21 

 
 
 
Figure  10  -  Financial  Progress  of  the  ISF:  Distribution  of  Allocated,  Committed,  and  Spent 
Resources by Specific Objective 

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

233,171,187 
(53,1%)

180,901,545 
(41,2%)

129,330,316 
(65,5%)

64,547,025 
(32,7%)

25,202,405 
(5,7%)

3,713,603 
(1,9%)

SO1 - Exchange of
information

SO - 2 Cross-border
cooperation

471,357,012 
(56.6%)

353,420,884 
(42,4%)

7,986,196 
(1,0%)
SO - 3 Strengthening MS
capabilities

spent 
Spent

Decided not yet spent
committed resources 

Planned not yet spent nor decided

allocated resources 

Source: Preparatory study, based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data  

In Member States’ programmes, SO1 shows the highest committed and spent resources 
(46.7%) followed by SO3 (41.8%), and SO2 (38%).  

Figure 11 - Financial Progress under Shared Management: Breakdown of Allocated, Committed, 
and Spent Resources by Specific Objective 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

232.409.619,78 
(53,2%)

108.830.315,51 
(62%)

286.484.777,59 
(58,2%)

179.163.126 
(41%)

63.537.928 
(36,2%)

197.942.642 
(40,2%)

25.202.405 
(5,7%)

3.222.700 
(1,8%)

7.935.133 
(1,6%)

SO1 - Exchange of information

SO - 2 Cross-border cooperation

SO - 3 Strengthening MS
capabilities

spent 
Spent

committed resources 
Decided not yet spent

allocated resources 
Planned not yet spent nor decided

Source: Preparatory study, based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data  

At  Member  State  level,  Germany,  France,  Spain  and  Italy  have  the  highest  volume  of 
committed resources, while Portugal, Hungary, Slovakia and Ireland have the lowest.  

22 

 
 
 
Beneficiaries  located  in  Germany,  Belgium,  France,  Spain,  Italy,  Greece  and  Poland 
absorb the largest share of Union Actions grants (approximately 43.9%). 

Six Member States (Spain, the Netherlands, Germany, Poland, Belgium and Greece) have 
been more active in Specific Actions  and applied for more than 72% of the overall Specific 
Action  envelope  planned  in  the  Thematic  Facility  Work  Programmes.  Specific  Actions 
generally represent a very small share (below 5%) of the committed resources per Member 
States,  except  for  Greece  (23.3%),  the  Netherlands  (13.3%)  and  Spain  (9.5%)  which 
combined account for more than half of the overall resources committed under the Specific 
Actions across Member States.  

Due to the delays entailed by its management at national level, in some cases the Specific 
Action component shows a slow start of implementation and a lower rate of committed 
resources at Member State level, despite it having the highest level of committed resources 
at Fund level (81.9% at Commission level).  

Emergency Assistance activities have only taken place in Finland and Estonia.  

Figure  12  -  Resources  committed  by  Member  State  and  Fund  Component  (MSA,  SA,  UA  and 
EMAS) 

62

2

17

44

38
38

1

9

5

9

0

9

13
1 
1 

1

3
3

3
0
4

4
0

25
26
27

24

1
0

2
1
0

0

20
21
21
19

15
16
14
12
11
8
0

0
1

FR

IT

EE

BG

SI

SE

LT

LV

EL

1

3

7
4

1
3
1
2
2
1
1
1

PL

LU

SK

PT

EUR 0

EUR 20

EUR 40

MSA

SA

EUR 60
UA

EMAS

EUR 80

EUR 100

Millions

Source: Preparatory study, based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data 

23 

 
 
In Member States’ programmes, the policy field with  the highest amount of  committed 
resources  is  Information  Exchange  (ca.  EUR  213  million).  Counterterrorism  and 
Organised Crime receive a comparable share (ca. EUR 74 million each) and Cybercrime 
half of that. Under Union Actions, Counter-terrorism (ca. EUR 72 million) received the 
highest  amount  of  resources  followed  by  Cybercrime  (ca.  EUR  37  million) 
Counterterrorism is the only policy field covered by EMAS (ca. EUR 1 million). Compared 
to other policy fields, Law enforcement cooperation receives a lower amount of resources 
in  Member  States’  programmes  (ca.  EUR  41  million)  but  a  substantial  amount  under 
Specific  Actions  (EUR  23  million,  i.e.  more  than  75%  of  the  overall  Specific  Actions 
committed resources). Fewer resources are dedicated to cooperation with third countries 
in Member States’ programmes, EMAS and Specific Actions, and accounts for ca. 8% of 
the committed resources under Union Actions.  

Figure 13 - Resources committed by Policy Field and Fund Component (MSA, Specific Actions, 
Union Actions, and EMAS) 

Information exchange

211 

2 

Counter-terrorism, including prevention of radicalisation,
protection of public spaces, critical infrastructure/entities

74 

3 

72 

1 

Organised crime (including drugs trafficking, THB, firearms
trafficking, migrant smuggling, corruption, money laundering)

73 

1 

29 

Cybercrime, including Child Sexual Abuse

37 

4 

37 

Law enforcement cooperation

41 

23 

3 

Others

2 

Cooperation with third countries

12 

EUR 0

EUR 100

EUR 200

Millions

MSA

Specific Actions

Union Actions

 EMAS

Source: Preparatory study, based on SFC2021, data transmitted by the MS up to 30 June 2024 and TF data Resources 
from the MS transmission of data on cooperation with third countries have been omitted from the chart as, based on 
plausibility checks and information at sub-operation level from DG HOME, they resulted to be overestimated.   

Payments 

Across the fund components, the rates of payments made are low, with Member States 
Actions being 3.4%. In Member States’ programmes, the payment rate across the Specific 
Objectives is relatively low with SO1 having the highest rate at 5.7%, followed by SO2 
(1.8%) and SO3 (1.6%). 

24 

 
 
 
4. EVALUATION FINDINGS 

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

4.1.1. Effectiveness 

Given the late start of the implementation of the Fund, the Evaluation is not in a position 
to provide a full assessment of its effectiveness. Considering the stage of implementation 
of the ISF, as shown further in this section, many Member States did not provide indicator 
data  and/or  qualitative  information  under  all  Specific  Objectives.  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. 

The financial progress of the ISF seems to indicate a delayed implementation. At Fund 
level, nearly 57% (see Figure 9) of the allocated resources had neither been committed nor 
paid by 30 June 2024.  

•  Specific Actions are the leading fund component in terms of committed resources 
at EU level (81.9%), but generally represents a very small share (below 5%) of the 
committed resources per Member State, and 

•  Member States Actions (41.8%) 

In terms of physical performance62 (common output and result indicators), due to the 
late  start  of  the  programmes,  achievements  had  only  started  to  be  reported  when  the 
evaluation was launched. Moreover, there is a lag between implementation and regulatory 
reporting, which is also affected by the data transmission chain in the different Member 
States. Finally, some initial targets are obsolete by now due to changes in implementation 
plans. 

Although  the  programmes’  financial  progress  under  the  shared  management  mode,  in 
terms of funds committed, is satisfactory, the level of physical progress reported in terms 
of achievements under the common output indicators defined in the ISF Regulation63 is 
therefore generally lagging.64 

62 The physical performance is assessed by looking at the Member States programmes’ relative achievements 
compared  to  their  respective  milestones  and  targets  (See  Section  2.3.  Points  of  Comparison).  Such 
achievements  are  measured  via  the  Fund’s  output  and  result  indicators  set  out  in  Annex  VIII  of  the  ISF 
Regulation, based on their cumulative values up to 30 June 2024.  
63 For the whole list of output and result indicators, see list in Annex VIII of the ISF Regulation. 
64 The fact that indicators have not been reported, or in a limited manner, does not imply that implementation 
has not been progressing; it simply means that ISF co-financed operations are not yet finalised and thus not 
yet included in the 2024 reporting. The Member States Managing Authorities submit the cumulative financial 
data  five  times  a  year,  whereas  the  performance  data  (i.e.,  data  on  output  and  result  indicators)  is  only 
reported twice a year. Thus, the performance data we receive from Member States is not representative of 
current progress as there is always a lag.  

25 

 
 
An essential explanatory factor behind differences in physical progress indicators is that 
ISF’s monitoring system has weaknesses that need to be addressed in the remainder of 
the implementation period.  

(i) monitoring system design issues: as evidenced during the analysis carried out by the 
evaluators, several output indicators refer to physical units of equipment or  means of 
transport  purchased,  which  are  incomparable  across  Member  States  and  even  across 
operations, as the nature, area of utilisation and unit value of equipment and means of 
transport can be very different. 

(ii) operational issues with monitoring: as evidenced in the survey responses and case 
studies,  Managing  Authorities  encounter  difficulties  in  operationalising  the  new 
monitoring indicators and reporting system. Errors and missing/non-reported values in 
indicators  transmitted  to  the  Commission  through  the  SFC  system  occur  relatively 
frequently. Some Managing Authorities do not follow the guidance on the interpretation 
of certain common indicators and use slightly or significantly different methods when 
reporting (e.g. on the trainings provided), harming comparability across Member States 
(See assessment of ‘Effectiveness of the Monitoring and Evaluation Systems’).  

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

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

Ten  Member  States  have  not  reported  any  progress  for  any  of  the  output  and  result 
indicators  (Belgium,  Czech  Republic,  Greece,  Hungary,  Ireland,  Luxemburg,  Malta, 
Poland,  Portugal  and  Slovakia).  Considering  the  delayed  financial  implementation  and 
delayed  reporting,  the  indicator  progress  is  also  lagging;  the  overall  achievement 
percentages are  estimated at 20% for milestones of output indicators, 8% for targets  of 
output indicators and 6% for targets of result indicators. 

The performed comparisons show that the ISF’s shared management is  lagging behind 
AMIF  and  BMVI’s  financial  implementation.  Using  comparable  data  from  the 
Cohesion Open Data Platform65, up to 30 June 2024, 30% of the ISF resources for shared 
management have been committed, while the rate of resources spent for Member States 
Actions is 2%. For comparison, for AMIF66, up to 30 June 2024, about 43% of the allocated 

65 The ISF data on the financial progress used  to present the overall financial progress of the ISF is more 
complete (it presents data for the whole Fund) and more appropriate (as it presents the EU contribution rather 
than  the  total  budgets,  as  done  in  the  CODP).  Thus,  the  estimates  presented  here  are  just  for  indicative 
comparisons.  
66 For AMIF, for the rate of resources planned, the values are comparable with the ISF if we omit resettlement 
(which follows a different programming cycle) from the calculations. 

26 

 
 
 
budget has been committed and about 11% has been spent for funded activities67, i.e. both 
committed  and  spent  funds  are  higher  for  the  AMIF  than  for  the  ISF.  For  the  BMVI, 
according to data for shared management, as of June 2024, the committed amounts were 
40%, while the spent  amounts were 5%, i.e. both  rates are also  higher than for the ISF 
shared  management68.  If  net  payments  as  a  percentage  of  the  overall  Fund  budgets  are 
compared, for the first  years of the 2021-2027, the  ISF (19,7%) is  behind the financial 
progress of the AMIF (27%) and BMVI (21.3%).  

Further to the comparisons for the 2021-2027 period, the financial progress could also be 
compared across programming periods. For the ISF-P, the share of committed actions was 
37.7%69 in 2016, while the share of approved payments to Member States was 8.45% at 
the end of 201670. When comparing with the ISF progress up to 30 June 2024, for Member 
States Actions committed, it was around 42%. Considering that the date of comparison for 
the ISF is ca. 8 months later than the comparison point for the ISF-P, the ISF Member 
States Actions were committed at a slower pace than for the ISF-P. 

As shown in Figure 14, the progress achieved by Member States’ Actions varies across the 
three Specific Objectives.71  

Figure 14 - Indicator progress per Specific Objective (average, excluding outliers with reported 
achievements above 300%) 

40%

35%

30%

25%

20%

15%

10%

5%

0%

26%

15%

16%

5%

11%

6%

SO1

SO2

SO3

SO1

SO2

SO3

Milestone

Target

Output

3%

SO1

8%

4%

SO2

SO3

Target

Results

Source: Preparatory study, based on SFC2021, data transmitted by the MS up to 30 June 2024 

67 Decided: Financial resources allocated to selected projects (project pipeline) Open Cohesion data 
68 Decided: Financial resources allocated to selected projects (project pipeline). Source: Open Cohesion data 
69  Based  on  data  presented  in  the  ISF-P  interim  evaluation  and  own  calculations  based  on  European 
Commisson extracts for 2016. 
70 Based on SFC2014 data. 
71  Each  Specific  Objective  includes  multiple  indicators,  with  progress  measured  by  comparing  the 
achievement  of  each  indicator  against  its  corresponding  milestone  and  target.  This  method  provides  a 
percentage of progress, where 0% indicates no progress, 100% represents full achievement, and over 100% 
shows that the milestone or target has been exceeded. After calculating progress for individual indicators, 
the results are aggregated at the specific objective level. The average of all indicators within each objective 
is  used  to  present  a  balanced  and  comprehensive  overview.  This  approach  ensures  that  every  indicator's 
contribution, including those showing zero progress, is taken into account. However, missing data for any 
indicator is excluded to prevent skewing the results. 

27 

 
 
 
While comparisons in the financial progress are challenging across Funds and especially 
across programming periods, this is even more the case when comparing the progress in 
terms  of  indicators.  Nevertheless,  such  a  comparison  is  attempted  below  for  the 
performance of the ISF-P in terms of average progress to outputs and results. It has to be 
considered  that  the  indicators  are  not  the  same  between  the  two  programming  periods. 
Furthermore,  the values are taken at different points in time (end of year for ISF-P and 
mid-year  for  the  ISF).  With  all  the  caveats  in  mind,  the  comparison  of  the  indicator 
progress  shows  that  so  far,  the  ISF  indicator  values  show  slower  progress  when 
compared to the ISF-P achievements. 

Figure  15  -  Comparison  between  the  ISF-P  and  ISF  indicator  progress  (average  progress  to 
outputs and results) 

32%

30%

9%

8%

12%

6%

Outputs

Results

ISF-P 2016

ISF-P 2017

ISF mid-2024

Source: SFC2014 and SFC2021, ISF data transmitted by the MS up to 30 June 2024. 

At Specific Objective level, Member States’ programmes allocate resources primarily 
to SO3 (EUR 487,3 million) followed by SO1 (EUR 436,7 million) and SO2 ((EUR 173,6 
million). The lower funding allocation to cross-border operational cooperation under SO2 
may be owing to Member States perceiving SO 3 and SO1 as more relevant to their national 
needs; to the relatively low costs incurred for projects aimed at furthering SO2 and the 
practical challenges in funding cross-border cooperation projects as they are perceived as 
more difficult or complex (e.g. in determining eligibility, dividing budgets across multiple 
jurisdictions)  and  the  high  administrative  burden  involved.  In  turn,  the  prioritisation  of 
SO1  may  be  explained  by  some  Member  States’  reliance  on  their  programmes  to 
implement  EU  acquis  concerning  information  exchange  as  this  may  entail  significant 
costs72.  

72 See second focus group, Annex V.  

28 

 
 
 
 
Figure 16 - Resources committed by policy field under Member States Actions 

Information exchange

211 (48,5%)

Counter-terrorism, including prevention of radicalisation,
protection of public spaces, critical infrastructure/entities

Organised crime (including drugs trafficking, THB, firearms
trafficking, migrant smuggling, corruption, money laundering)

74 (17,0%)

73 (16,7%)

Cybercrime, including Child Sexual Abuse

37 (8,4%)

Law enforcement cooperation

41 (9,3%)

Others

Cooperation with third countries

EUR 0

EUR 50

EUR 100

EUR 150

EUR 200

EUR 250

Millions

Source: Consortium elaboration based on SFC2021, data transmitted by the Member States up to 30 June 2024  

The distribution of committed resources by policy field indicates a focus on information 
exchange  (EUR 211 million), which is  explained due to  the high  costs associated with 
setting up and maintaining IT systems. This is followed by counterterrorism (EUR 74 
million), and organised crime (EUR 73 million). Law enforcement cooperation (EUR 41 
million) is closely followed by cybercrime (EUR 37 million). Figure 16 provides a detailed 
breakdown of committed resources by policy field under Member States Actions. 

While  being  allocated  the  lowest  amount  of  resources  across  all  Member  States  and 
showing a slower relative financial progress, SO2 (cross-border cooperation) has shown 
the  highest  achievement  of  milestones  and  targets  (both  for  outputs  and  results). 
However,  it  is  partially  driven  by  overachievements  in  two  Member  States  (Spain  and 
Sweden).  

Output  indicators  under  SO1  (exchange  of  information)  show  a  very  slow  overall 
progress towards the milestones and targets, except for one indicator (number of expert 
meetings/workshops/study visits). Result indicators are currently far from the set targets. 
At Member State level, Germany, Latvia, Romania, and Estonia show the most progress 
in terms of output/result indicators under SO1. Thirteen Member States did not report any 
progress on the SO1 indicators. On the other hand, the review of the Annual Performance 
Reports shows that 20 Member States have reported some progress regarding SO1 (i.e. 6 
Member States have not reported any progress), but it is mostly related to the launching of 
calls for proposals. Projects put forward by the Member States include: interoperability of 
national  and  international  security-related  information  exchange  systems  and  networks, 
maintenance/upgrade of Disaster Recovery Reserve System, maintenance of the National 
Advanced Passenger Information System (API), operational and business continuity of the 
Passenger Name Record (PNR) database, exchange of information between the national 
and EU firearms information systems, and the training of staff and experts on the use of 
information exchange systems. The national mid-term evaluation reports note the efforts 
of the Member States in launching calls and starting projects that are expected to contribute 
to the achievement of the SO1 objectives (e.g. in Spain, Poland, Malta, and Luxembourg). 

The  achieved  output  indicators  under  SO2  show  a  good  overall  progress,  although 
driven  mostly  by  Spain  and  Sweden,  towards  milestones  and  targets  except  for  one 

29 

 
  
indicator (number of transport means purchased for cross-border operations). Similarly, 
result indicators show good progress, particularly for two indicators (administrative units 
and the quality of illicit drugs seized). At Member State level, Spain, Romania, Germany, 
Latvia, and Sweden show the most progress in terms of output/result indicators. Sixteen 
Member States did not report any progress on the SO2 indicators. Examples of activities 
and (soon-to-be implemented) projects provided in Annual Performance Reports include: 
improving  and  intensifying  cross-border  cooperation  through  joint  patrol  operations; 
setting up a Police network fusion centre for better coordination and management against 
serious and organised crime; and EMPACT projects (related to synthetic drugs).  

The achieved output indicators under SO3 (capacity building) indicate very slow overall 
progress towards reaching the milestone, and consequently an even slower progress in 
achieving  the  target  values,  even  for  the  indicator  currently  with  the  highest  value 
(number of projects to prevent crime). Progress towards result indicators also shows a 
very  slow  pace  of  achievement,  particularly  for  one  indicator  (number  of  initiatives 
developed/expanded to protect/support witnesses and whistle-blowers). At Member State 
level, Cyprus, Germany, Estonia, Italy, Latvia, Romania, and Spain have progressed the 
most  in  terms  of  output/result  indicators73.  Twelve  Member  States  did  not  report  any 
progress on the SO3 indicators. Examples of projects under SO3 include: training for anti-
corruption investigators, strengthening cooperation between the public and private sectors 
and civil society in the field of anti-corruption, detection and prevention of radicalisation, 
crime recidivism or new crimes in society by improving the knowledge and skills of staff 
working in detention units, provision of training, exercises, mutual learning opportunities 
and specific exchange programmes and the sharing of best practices within and among the 
Member  States  competent  authorities,  and  acquiring  forensic  equipment  for  detecting 
explosives and identifying ingredients and narcotic drugs. 

Figure  17  -  Progress  Towards  Targets  by  Specific  Objective  and  Member  State  in  Shared 
Management Mode 

100%

80%

60%

40%

20%

0%

1
O
S

3
O
S

AT

2
O
S

BE

1
O
S

3
O
S

BG

2
O
S

CY

1
O
S

3
O
S

2
O
S

1
O
S

3
O
S

CZ

DE

EE

2
O
S

EL

1
O
S

3
O
S

ES

2
O
S

FI

1
O
S

3
O
S

2
O
S

1
O
S

3
O
S

FR

HR

HU

2
O
S

IE

1
O
S

3
O
S

IT

2
O
S

LT

1
O
S

3
O
S

2
O
S

1
O
S

3
O
S

LU

LV MT

2
O
S

NL

1
O
S

3
O
S

PL

2
O
S

PT

1
O
S

3
O
S

RO

2
O
S

SE

1
O
S

3
O
S

SI

2
O
S

SK

Source: Preparatory study, based on SFC2021, data transmitted by the MS up to 30 June 2024 

Managing  Authorities  asserted  that  2025  reporting  will  demonstrate  that  financial  and 
indicator progress has accelerated and that Member States’ programmes are on track to 

73 It is important to note that there is insufficient information on MS programmes progress towards achieving 
the set objectives six Annual Performance Reports. 

30 

 
 
 
achieve their objectives by 2029, and that projects are generally progressing as planned 
with no major points of concern identified. As noted in the Synopsis report, when asked 
about the effectiveness of the ISF, many consulted stakeholders (20) were either positive 
about the extent to which the Fund is on track to achieving its objectives or did not expect 
significant challenges that might hinder the achievement of objectives.  

Survey  respondents  provided  generally  positive  opinions  on  the  effectiveness  of  the 
different ISF actions so far, as shown in the Figure 18. At the same time, stakeholders (both 
from the management and beneficiary sides) raised some common challenges such as: long 
national  bureaucratic  processes,  extended  preparatory  (both  the  programming  and  the 
awarding of projects) phases, challenges in coordination with relevant bodies and inter-
institutional communication, and national administrative capacity.  

Furthermore, some Managing Authorities74 perceive that certain limits placed on Member 
States’  use  of  resources75,  e.g.  the  35%  cap  on  the  purchase  of  equipment,  means  of 
transport, or the construction of security-relevant facilities,76 may hinder their ability to 
fully meet the Fund's objectives, as specialised equipment is crucial in combatting drug 
trafficking and cybercrime. While these Member States advocate for greater flexibility in 
using ISF-funded equipment, there are no restrictions on the type of equipment that can be 
purchased  with  ISF  funding  provided  that  it  has EU-added  value  and  does  not  concern 
actions limited to the maintenance of public order at national level which would not be 
eligible for funding pursuant to Article 5(5) of the ISF Regulation.  

Figure 18 – Answers to the question ‘To what extent were the following actions effective in ensuring 
a high level of security in the Union?’ 

Actions improving police cooperation and coordination, including with
relevant Union bodies

Implementing projects promoting collaboration, knowledge sharing, and
interoperability for enhanced security measures

Analytical, monitoring and evaluation activities, including studies and
threat, risk and impact assessments

Awareness-raising, dissemination and communication activities

Acquisition, maintenance of Union IT systems and national IT systems
and/or further upgrading of IT systems and technical equipment

Exchange, training and education of staff and experts of relevant
authorities

Measures deploying, transferring, testing and validating new
methodology or technology

56%

63%

30%

31%

39%

37%

30%

3%

11%

26%

3%

8%

13%

1%

17%

16%

1%

14%

46%

53%

26%

6%

3%

19%

34%

4%

9%

28%

40%

10%

3%

19%

Actions in relation to third countries

18%

25%

18%

4%

35%

To a large extent

To some extent

To a limited extent

Not at all

Don't know

0%

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

The  Thematic  Facility  fund  components  have  contributed  to  SO2  and  SO3  whereby 
Specific  Actions  have  mostly  targeted  SO2,  while  Union  Actions  have  contributed 
significantly and primarily to SO3. At policy field level, Union Actions clearly prioritises 
counterterrorism,  while  Specific  Actions  focuses  on  law  enforcement  cooperation. 

74 In the second focus group, see Annex V.  
75 Certain actions and equipment are not eligible for funding under the ISF, as set out in Article 5(5) ISF 
Regulation. 
76 As per Article 13(7) of the ISF Regulation. 

31 

 
  
 
While  vital  under  Member  States  Actions,  information  exchange  is  addressed  only 
marginally by both Specific Actions and Union Actions. 

Figure  19  -  Resources  committed  by  policy  field  and  fund  component  (Specific  Actions,  Union 
Actions, and EMAS) 

Counter-terrorism, including prevention of…

3

72 

1

Organised crime (including drugs trafficking, THB,…

1

29 

-

Cybercrime, including Child Sexual Abuse

4

Law enforcement cooperation

23

Information exchange

-
2 

Cooperation with third countries

12 

-

Others

2 

37 

3 

-

0

€0 M

€20 M

€40 M

€60 M

€80 M

Specific actions

Union Action

 EMAS

Source: Preparatory study, based on Thematic Facility data up to 30 June 2024  

Specific Actions 

The Commission identified six major policy areas as priority for Specific Actions’ calls of 
expression of interest: the European Multidisciplinary Platform Against Criminal Threats 
(SA EMPACT), Law Enforcement Operational Cooperation (SA ROLEC), Child Sexual 
Abuse (SA CSA), Trafficking in Human Beings (SA THB), Protection of Public Spaces 
(SA PPSII), and Cybercrime Non-cash Payment Fraud (SA NCPF). 

The Commission launched two larger calls under SO2 (SA EMPACT and SA ROLEC) 
with a total amount of EUR 27.5 million, i.e. 71% of the total Specific Actions envelope 
to enhance cross-border law enforcement cooperation and mitigate the fact that Member 
States  tend  to  allocate  in  their  programmes  only  the  minimum  10%  to  this  Specific 
Objective. Due to their transnationality, Specific Actions projects under SO2 have a much 
larger average budget (of more than EUR 1 million), compared with projects under other 
Specific Actions calls with a somewhat smaller budget (often less than EUR 500,000).  

SO3 came as a second priority with four calls aiming to strengthen measures to combat 
and  prevent  serious  and  organised  crime,  cybercrime,  trafficking  in  human  beings  and 
counterterrorism (EUR 9 million i.e. 23% of the total SA envelope). One call was planned 
under SO1 on exchange of information on child sexual abuse (EUR 2 million, i.e. 6% of 
the  total  SA  envelope).  Up  to  30  June  2024,  EUR  31.52  million  were  decided  at 
Commission  level  and  only  EUR  18.5  million  at  Member  State  level  (i.e.,  reported  in 
Member States’ financial transmission of data).  

Certain Member States have been more active in applying for Specific Actions funding 
under Option 2, with the top five Member States (Spain, the Netherlands, Germany, Greece 
and Poland) accounting for ca. 77% of the committed amount. Two Member States have 
received  funding  for  Specific  Actions  projects  under  three  calls  (Spain  and  Greece) 
whereas 10 Member States received funding under two calls (NL, DE, PL, RO, EE, AT,  
LT, LV, PT and BG), and 9 Member States under only one call (BE, CY, CZ, FI, FR, HR, 
IT, SI and SE). Some of the Specific Action projects have faced large delays in starting 
their  implementation,  due  to  heavy  national  legal  requirements  (“gold-plating”)  and 

32 

 
 
administrative  procedures  (Greece  and  Portugal).  IE,  SK,  HU  and  LU  do  not  have  any 
amounts in their programmes for Specific Actions as they only participated as partners in 
Option 1 projects. Malta has never applied to nor participated in SA calls. 

Specific Actions projects are still ongoing. Nevertheless, as reported in the 2023 Annual 
Performance Reports, some of these projects have already produced outputs and results, 
such  as  joint  operations,  investigations,  arrests,  seizures,  training  activities,  workshops, 
meetings, and procurement of equipment. Most Specific Actions projects plan activities to 
foster best practice transfer, and to a lesser extent innovation transfer between Member 
States. Projects that have initiated substantive work in their implementation have achieved 
or are on track to achieve planned results (POP-ART under PPS II) or have even exceeded 
them  (Alert  Helpers!  under  THB)  as  well  as  two  very  successful  projects  under  the 
EMPACT call. The ongoing ES-led project ‘European Operational Team (EOT) in Costa 
del Sol’ (SA EMPACT) involves the largest number of Member States (12) and aims at 
fighting criminal networks and high-value targets involved in drug trafficking. Thus far, it  
has already resulted in significant amounts of illicit drugs seized (10.6 tons of cocaine, 12 
tons  of  hashish,  2.5  tons  of  marijuana,  100  kg  of  MMDA)  and  in  EUR  71  million  in 
seizures of real estate. The DE-led LUMEN project under EMPACT, which has the aim of 
strengthening  cooperation  and  coordination  among  law  enforcement  authorities  and 
developing  innovations  in  detecting  fraudulent  call  centres  where  elderly  people  are 
targeted and subject to crimes started in the begining of January 2023 and already shows 
EUR 855,000 of frozen assets compared to the final target of EUR 2 million by December 
2025. 

Some  Member  States  take  advantage  of  the  complementarity  of  the  different  fund 
components of the ISF to ensure sustainability of their project. For example, for the EOT 
Costa del Sol project, national funding is used to extend the deployment of Member State 
officers and a Union Action grant is funding an EOT support unit.   

Union Actions  

The implementation progress of Union Actions, up to 30 June 2024, is that out of EUR 
361.9  million  allocated  for  Union  Actions  under  both  Thematic  Facility  Work 
Programmes, EUR 157.8 million have been committed (i.e. nearly 44% of the allocated 
amount). The highest share was planned under direct management, i.e. EUR 220.2 million 
for action grants (61%)  and  EUR 109.8  million for procurement  (30%).  Under indirect 
management, 6% were planned for contribution agreements and 3% for other contracts. 

A total of 64 action grants have been awarded with an overall maximum grant value of 
EUR 90.4 million, mainly in Cybercrime including the fight against online child sexual 
abuse (34%) and Counterterrorism (31%). Ca. 220 procurement contracts for a total value 
of EUR 63.5 million have been signed so far. The highest share of the procurement budget 
is  dedicated  to  supporting  the  Radicalisation  Awareness  Network  (51%)  followed  by 
support for meetings of expert groups, networks and other events. The reviewed sample of 
Union Action projects show that they all contribute towards the ISF Specific Objectives. 
For instance, project “HOTHREAT” addresses the existing gap in the protection of hotels 
from  CBRN-e  terrorist  threats,  and  has  the  aim  to  develop  response  procedures  and 
scenarios  in  case  of  terrorist  attacks,  as  well  as  training  and  workshops  to  enhance 
cooperation among LEAs, private and public entities, experts, and end-users in prevention 
and response efforts.  

33 

 
As to the implementation progress by policy area, 17 Union Actions grants support the 
prevention  of  and  fight  against  Cybercrime  and  child  sexual  exploitation  online  with  a 
maximum  grant  value  of  EUR  31.2  million  (14  through  open  calls  for  proposals  and  3 
through  direct  awards).  A  total  of  18  Union  Actions  grants  support  the  policy  field 
Counterterrorism  (prevention  of  radicalisation,  protection  of  public  spaces,  places  of 
worship,  and  critical  infrastructure/entities)  with  a  maximum  grant  value  of  EUR  27.8 
million (13 through open calls for proposals and 5 through direct awards) and procurement 
contracts of EUR 32.1 million. A total of 17 Union Actions grants have been supported for 
tackling Organised crime with a maximum grant value of EUR 15.9 million (14 through 
open calls for proposals and 3 through direct awards). Five Union Actions projects support 
cooperation with third countries for EUR 12 million.  

Union Actions support law enforcement cooperation and networks primarily through direct 
awards  with  a  grant  value  of  EUR  2.2  million  (e.g.  AIRPOL,  AQUAPOL,  ENFAST, 
ENLETS,  ENFSI,  RAILPOL,  @ON  Network,  AMON,  CARIN,  etc)  and  Information 
Exchange  projects  with  a  grant  value  of  EUR  1.7  million  through  one  open  call  for 
proposals and one direct award.  

Emergency Assistance 

Only  two  projects  have  been  awarded  under  the  ISF,  which  were  submitted  by  the 
Ministries of Interior from Finland and Estonia, respectively, with a total maximum grant 
amount  of  EUR  910,547.  By  30  June  2024,  both  awarded  projects  were  successfully 
completed. The projects  supported both  Member  States’ law enforcement  authorities to 
timely  and  efficiently  complete  the  investigations  of  the  sabotage  incidents  affecting 
critical infrastructure facilities in the Baltic Sea.  

Effectiveness of the Monitoring and Evaluation Systems 

As part of the monitoring and evaluation framework set out by the CPR, Member States 
must ensure that all exchanges of information with beneficiaries are carried out by means 
of  electronic  data  exchange  systems77.  Despite  being  highlighted  as  a  positive  change, 
some  Member  States  do  not  have  fully  functioning  national  electronic  data  exchange 
systems78 between beneficiaries and Managing Authorities. Furthermore, deficiencies in 
these systems have been reported, such as technical issues or media discontinuities (digital 
vs. paper formats) and user interface challenges, and the need to further refine and better 
align with user needs.  

In line with the CPR and ISF Regulation requirements, each Member State had to prepare 
a  methodology  to  establish  the  performance  framework.  The  Commission  provided 
guidance on target-setting methodology to design the monitoring system in a way most 
suitable  to  each  Member  States’  national  structure.  However,  most  Member  States 
experienced difficulties defining indicator methodologies79. 

77 Article 69(8) of the CPR. 
78  According to the survey results 36% responding that the system is fully operational, 30% responding that 
not all features are available, and 14% declaring that the system is not yet functional. 
79 Survey responses show that the majority of respondents (61% responded “Not at all” or “To a limited 
extent”) did not find it straightforward to establish the methodologies. 

34 

 
 
 
Figure 20 - Survey responses to the question “It was straightforward to establish a methodology 
for  the  performance  indicators,  which  included  criteria  for  selection  output  indicators, 
data/evidence used and factors potentially effecting the achievement of milestones and targets” 
(combining respondents with experience from both periods) 

25%

36%

27%

2%

9%

Not at all

To a limited extent

To some extent

To a large extent

Don't know

Member States (CY, DE, ES, FR, HR, NL, LV, PL and RO) used a very varied approach 
in  terms  of  describing  how  the  targets  were  set  in  terms  of  the  presentation  of  the 
documents  (structure,  format)  and  the  level  of  detail  provided.  Some  Member  States 
underlined also the challenges they met given the increasing level of detail requested and 
the turnover in Managing Authority staff.  

When  looking  at  the  Commission  specific  guidance80,  it  appears  that  all  the  reviewed 
methodologies  set  the  baselines  for  zero,  and  that  most  Member  States  described  the 
methodologies for defining the milestones and targets for a large majority of indicators. 
However, clarity on the evidence for setting targets/milestones differs significantly across 
Member  States  and  some  did  not  provide  sufficiently  clear  evidence.  In  general,  the 
contextual factors impacting the achievement of milestones and targets listed are delays in 
procurement and in selecting and starting projects, risks related to the complexity of ICT 
systems, risks related to the size of projects for setting up/upgrading of essential security-
relevant infrastructure, price increases, and hiring staff/high staff turnover.  

The  ISF  Impact  Assessment  concluded  that  the  monitoring  and  evaluation  framework 
needs to be established at the beginning of the programming period in order to facilitate a 
swift start, and indicators should allow for better measuring of the performance of national 
programmes,  with  a  view  to  monitoring  EU  added  value.  For  comparison,  common 
definitions for output/result/impact indicators were only introduced in 2017/2018 in the 
2014-2020 programming period, in the form of a Guidance on the common monitoring and 
evaluation framework of the AMIF and the ISF. There has been no obligation to report on 
core indicators for direct and indirect management in the 2014-2020 programming period, 
while in  the current  period the core indicators now apply  to  Union Actions and EMAS 
where relevant. Thus, the use of the core performance indicators as set out in Annex VIII 
of  the  ISF  Regulation    contributes  to  the  provision  of  structured  data  on  the  progress 
towards  the  achievement  of  the  objectives  of  the  Fund  and  can  be  considered  an 
improvement  when  compared  to  the  2014-2020  programming  period.  For  example,  the 
mid-term  evaluations  in  Bulgaria  and  Sweden  concluded  that  stakeholders  consider  the 
core  indicators  reflective  of  the  programmes’  achievements  and  in  line  with  their 
intervention logics.  

This is supported by the ‘Special Report on the Integration of Third Country Nationals’ of 
the  European  Court  of  Auditors’,  which  refers  to  AMIF  but  applies  to  the  reporting 
framework for all Home Affairs Funds: “This new reporting framework underscores the 

80 Note on the performance framework for the 2021-2027 AMIF/ISF/BMVI.  

35 

 
 
 
shortcomings in  the reliability of 2014-2020 project  reporting”. Additionally, the  Court 
highlighted as a progress that “these indicators were more easily linked to fund activities 
than the indicators for 2014-2020.”  

Furthermore, the improvement of the current performance framework as compared to the 
one in the 2014-2020 programming period is also confirmed in Chapter 3 of the European 
Court of Auditors Annual Report for 2023 under the section dedicated to the Home Affair 
Funds  and  entitled  “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 fund-specific regulations established indicators mapped to objectives, without 
distinguishing between output and results, while the 2021-2027 fund-specific regulations 
established  output  and  result  indicators  for  objectives,  as  well  as  core  performance 
indicators (a selection from the output and result indicators). In addition, the Commission 
established  a  metadata  set  to  provide  the  main  characteristics  (e.g.  definition,  unit  of 
measure,  frequency,  data  source,  whether  the  indicator  covers  output  or  results)  of 
indicators from the current programming period”.  

The intervention logic presented in Section 2.3 also illustrates that the output and result 
indicators, as defined in Annex VIII of the ISF Regulation, are relevant to the activities 
and expected achievements under the ISF. For example, the investments in ICT systems is 
an  activity,  which  leads  to  ICT  systems  setup/adapted/maintained  (an  output)  and  ICT 
systems made interoperable within and beyond the Member State (a result). This is aligned 
to improving and facilitating the exchange of information between Member States (SO1).  

At the same time, the general ISF intervention logic presented in the evaluation, did not 
include indicators such as “Number of projects to prevent crime” and “Number of projects 
to assist victims of crime”, as they can be useful for monitoring the progress of the ISF, 
but their value for assessing effectiveness is smaller. Also, for the purpose of comparison, 
in  the  2014-2020  programming  period,  the  ISF-P  indicator  framework  included  a  very 
small number of indicators (around 10 main indicators), including similar indicators such 
as: Number of projects in the area of crime prevention; Financial value of projects in the 
area  of  crime  prevention;  and  Number  of  projects  supported  by  the  Fund,  aiming  to 
improve  law  enforcement  information  exchanges  which  are  related  to  Europol  data 
systems, repositories or communication tools.  

Furthermore, the Intervention Logic for the 2021-2027 programming period includes a few 
indicators of a more qualitative nature, which are not presented in Annex VIII, but could 
be considered in the ex-post evaluation of the ISF: “Number and type of partners”, “Mutual 
trust building between different agencies and actors, at regional, national, and transnational 
level”,  and  “Adequate  availability  and  quality  of  means  of  transport,  equipment,  and 
security-related facilities”.  

Most survey respondents involved in the ISF management and coordination consider that 
defining all indicators at the beginning of the programming period was not an easy task,81 
particulary  when  predicting  equipment  quantities  over  the  long  implementation  period. 
Most Member States have selected all or most indicators depending on the operations and 
implementation  measures  they  planned  in  their  programmes.  Several  Member  States 

81  34% responding “not at all” and 34% responding “to a limited extent”. 

36 

 
 
highlight that the relevance of some result indicators (e.g. those related to the freezing of 
assets, seizure of illegal drugs, and confiscation of weapons in cross-border operations) is 
clearly affected by factors external to the Fund.  

Several stakeholders state that the use of predefined (mainly) quantitative indicators are 
not always suitable to fully capture the scope of activities of individual projects, leading to 
the development of project-specific indicators. For example, the evaluation of the Dutch 
programme,  concluded  that  the  pre-defined  indicators  are  not  always  relevant  to  the 
projects. As reported, by the evaluation of the Swedish programme, projects tend to focus 
more on their own project indicators rather than the programme indicators, which could 
blur  the  governance  level  of  the  EU  and  the  Member  State  programme,  making  it 
challenging  to  fully  evaluate  the  programme.  Moreover,  the  evaluation  in  Belgium 
concludes  that  (despite  the  efforts  of  the  Managing  Authority)  the  beneficiaries  face 
difficulties in tracking achievements due to a lack of understanding of core indicators set 
out in Regulation (EU) 2021/1149.  

As noted by the mid-term evaluations in Finland, Poland, Hungary, and Luxembourg, the 
framework uses predefined, mainly quantitative indicators to monitor the implementation 
of  the  Member  States  programmes,  but  these  indicators  are  not  always  suitable  for 
individual projects, leading to the development of project-specific indicators. Very similar 
sentiments  were  shared  by  stakeholders  interviewed  for  the  German  case  study  and  by 
some respondents to the survey. They also expressed the view that core indicators may not 
fully capture the scope of activities undertaken. Such experiences suggest that while key 
performance  indicators  (KPIs)  provide  a  measurable  framework,  they  may  not  always 
accommodate  the  diverse  roles  and  contributions  necessary  for  comprehensive  project 
success. This could increase the challenge to adequately evaluate ISF achievements.  

Despite  these  findings  on  the  relevance  of  core  indicators,  the  national  mid-term 
evaluations effectively did not provide sufficiently clear recommendations for changes. In 
some  Member  States  the  mid-term  evaluations  and  different  stakeholders  provided 
recommendations  for  improvement,  such  as:  introduction  of  “meta-indicators”  (e.g.  “at 
time X, at least 90% of all target indicators will be achieved”), indicators at the Member 
State programme-level, rather than at the level of the Specific Objective, limited number 
of  indicators  to  not  preclude  the  elaboration  of  further  programme  and  project-specific 
indicators, and the use of more “qualitative” indicators which measure the success of the 
projects and their sustainability.  

Despite  Commission  guidance,  Member  States  have  different  practices  in  assessing 
indicators  target  values.  For  example,  for  the  indicator  ‘Number  of  participants  who 
consider the training useful for their work’, the % rate differed between 90% (FR), 85% 
(PL), 80% (DE, CY) and 75% (RO). The indicator ‘Number of equipment items purchased’ 
shows great  variation across  Member  States  as  the definition of equipment  varies  from 
project  to  project.  The  indicator  ‘Number  of  ICT  systems  set  up/adapted/maintained’ 
shows great variation in target values, e.g. target values under SO1 range from 3 (SE) to 
901  (EL).  This  renders  the  interpretation  of  aggregated  values  challenging,  as  in  this 
instance, the combined target values of all other Member States (except for EL) are 389, 
i.e. the results for only one Member State could skew significantly the aggregated numbers. 

These differences may be due to the varying level of expertise, experiences, and knowledge 
at  Member  State  level.  Nevertheless,  these  lessons  learned  should  be  considered  in  the 
forthcoming ex-post evaluation. 

37 

 
Effective involvement of relevant partners 

Most Member States took actions to identify, inform, and reach the most relevant partners 
in  the  programming  phase.  Several  Member  States  reported  that  the  Monitoring 
Committees  are  composed  of  various  stakeholders,  including  representatives  of  public 
authorities, non-governmental organisations, social and economic partners, regional and 
local authorities, and other relevant actors. A Member State provided a concrete positive 
example,  in  which  the  Managing  Authority  sent  an  invitation  for  participation  to 
operational  meetings  in  designing  the  Member  State’s  programme  to  all  interested 
representatives  of  bodies/institutions/units  of  local  and  regional  self-government,  who 
were later included in the Monitoring Committee. However, the majority of the Member 
States  faced  challenges  involving  partners  other  than  public  institutions  (such  as  civil 
society and private entities). A Member State also had difficulties in coordinating different 
interests  at  regional  and  central  level,  and  finding  members,  given  that  it  is  an  unpaid 
voluntary position with a high workload.  

Figure  21  -  Survey  responses  to  the  question  “To  what  extent  ensuring  active  participation  of 
partners during the programming was challenging (N=44, combining respondents with experience 
from both periods and 2021-2027) 

16%

23%

36%

14%

11%

Not at all

To a limited extent

To some extent

To a large extent

Don't know

Notwithstanding the internal security aspect of ISF, partnerships  as per Article 8 of the 
CPR can be established, i.a., with NGOs, civil society and academic entities in the fields 
of combating trafficking in human beings, child sexual abuse, migrant smuggling, victims 
of crime, cybercrime, radicalisation, and drug trafficking; or private actors and Small and 
Medium-sized Enterprises (SMEs) in the field of Critical Entities Resilience, cybercrime 
and  terrorist  content  online;  trade  unions  of  law  enforcement  authorities  in  the  field  of 
training.   

Despite  Managing  Authorities’  general  effort,  the  implementation  of  the  partnership 
principle remains at a low-medium level for most ISF programmes, mostly due to different 
levels of knowledge of potential partners on internal security-related issues or the lack of 
direct experience involving NGOs.  

As  concerns  the  Thematic  Facility,  Member  States  are  part  of  the  programming  and 
monitoring via the Home Affairs Funds Committee. Moreover, ahead of each Thematic 
Facility  Work  Programme  and  calls,  DG  HOME  coordinates  with  other  Commission 
Services  (particularly  on  the  external  dimension)  and  with  relevant  Council  Working 
Parties and policy consultation fora.  

Several Union Actions projects contribute to the involvement of civil society and private 
partners in most policy fields. Their involvement was particularly strong in protection of 
public spaces and places of worship, prevention of radicalisation, fight against trafficking 
in human beings, cybercrime and child sexual abuse, assistance to victims of crime, etc., 
where most  projects  are  initiated and coordinated by beneficiaries from  the private and 
non-profit sectors.  

38 

 
 
Most Specific Actions calls aim at involving civil society and private partners active in 
internal security. However, the extent to which they are involved differs depending on the 
calls and policy field concerned. The calls targeting cybercrime and  child sexual abuse, 
trafficking in human beings and protection of public spaces show involvement of i.a., civil 
society,  academia,  youth  workers,  private  associations,  research  institutes  and  public-
private partnerships. In the field of law enforcement cooperation, the target group of both 
calls can only be law enforcement authorities and cannot therefore involve private entities 
nor civil society actors. 

Implementation of Horizontal Principles  

All actions implemented under Home Affairs Funds must comply with the horizontal 
principles set out in Article 9 of the CPR. To respect fundamental rights and in particular 
to  comply  with  the  Charter  of  Fundamental  Rights  of  the  European  Union  (EU 
Charter), Member States have established organisational and procedural arrangements to 
ensure compliance82. For instance, by incorporating the need for beneficiaries to respect 
both  the  EU  Charter  and  United  Nations  Convention  on  the  Rights  of  Persons  with 
Disabilities  (UNCRPD)  into  specific  clauses  within  contractual  agreements,  and 
Monitoring  Committees  having  to  review  compliance.  Several  Member  States  have 
established  reporting  systems  where  complaints  regarding  alleged  breaches  of  the  EU 
Charter can be filed, reviewed, and tackled. Up to 30 June 2024, no Managing Authority 
has reported any complaints nor any cases of non-compliance.  

Across  all  stages  of  the  programming  and  monitoring  cycle,  Member  States83  have 
established  mechanisms  to  respect  equality  between  men  and  women  and  gender 
mainstreaming  and  integrate  a  gender  perspective,  as  well  as  the  principle  of  no 
discrimination based on gender, racial or ethnic origin, religion or belief, disability, 
age  or  sexual  orientation,  as  required  by  Article  9  of  the  CPR.  Most  Member  States 
require legal  declarations from  beneficiaries as part of their project  proposals  to  ensure 
adherence to both principles. Some Member States (EE and FI) have established training 
sessions  to  educate  Managing  Authorities  and  project  beneficiaries  on  these  horizontal 
principles  in  project  planning  and  execution.  Member  States  have  also  established 
procedures for reporting cases of non-compliance and complaint mechanisms. They report 
that these principles have been respected, but there is some room for further advancing 
them in the implementation of the ISF. No Managing Authority has yet reported gender-
disaggregated  data  when  reporting  on  the  indicators,  as  the  ISF  is  at  an  early  stage  of 
implementation. Concerning the Thematic Facility, the principles of gender equality and 
non-discrimination  are  indirectly  refered  to  in  the  Work  Programmes  and  in  the  Union 
Actions and Specific Actions calls, as required by Article 4 of the ISF Regulation. 

Even  in  the  absence  of  horizontal  guidance,  pursuant  to  Article  9  of  the  CPR,  actions 
implemented under shared management and Specific Actions must promote sustainable 
development,  as  set  out  in  Article  11  TFEU.  The  Member  States’  national  mid-term 
evaluation  reports  of  Czechia,  Lithuania  and  Luxembourg  specifically  state  that  their 
programmes  align  with  the  “Do  No  Significant  Harm”  (DNSH)  principle,  without 
providing any further details. At project level, some sustainable development activities can 
be  noted  such  as  minimising  digital  footprint,  using  e-learning  modules,  and  reducing 

82 As stated in the national mid-term evaluation reports from CY, ES, FI, IT, the NL, RO, EE, LT, LU, MT, 
and SI 
83 As stated in the national mid-term evaluation report and/or Annual Performance  Reports of AT, BE, CY, 
EE, FI, IE and IT.  

39 

 
 
unnecessary travel. The Thematic Facility Work Programmes explicity state that the ISF 
should support activities that respect climate and environmental standards and priorities of 
the  Union  and  the  DNSH  principle.  Moreover,  the  ISF  aims  to  prevent  serious  and 
organised crime, including the detection, investigation and prosecution of environmental 
crime  (e.g.  Aquapol  2  project).  As  the  Union  Actions  calls  do  not  explicitly  refer  to  
sustainable  development,  projects  need  to  consider  environmental  EU  policy  interests/ 
priorities and applicants should specify if their envisioned activities could cause harm to 
the environment (e.g., green budgeting, choosing the most environmentally friendly means 
of transportation, and substituting physical travel with online meetings, etc.). 

Overall, it can be concluded that procedures and organisational arrangements are in 
place to ensure respect of horizontal principles in all fund components. Nevertheless, 
both  in  Member  States’  and  Thematic  Facility  Work  Programmes,  there  is  room  for 
improvement  in  actively  integrating  horizontal  principles  in  the  definition,  selection, 
monitoring, and implementation of projects.  

Effectiveness of Communication and Dissemination Activities 

In the programming phase, Member States outlined their approach to communication and 
programme visibility through defining its objectives, target audiences, and communication 
channels as legally required84. However, Member States’ programmes may considerably 
vary regarding the level of detail provided on their monitoring and evaluation indicators.  

In the implementation phase, several Member States’ programmes contain communication 
strategies85  with  correctly  identified  target  groups  and  monitoring  arrangements  to 
disseminating information on funding opportunities and achievements. As ISF is still in its 
early stages, information is scarce on the achievement of the communication strategies’ 
target values and their effectiveness.  

Despite most Member States indicating that the use of multiple communication channels 
is a common and effective practice among some programmes, others state that it may be 
too premature to assess effectiveness. Member States use diverse communication channels, 
i.a. websites, social media (e.g., Facebook, Twitter), newsletters and traditional media (like 
radio), and in-person events such as workshops and fairs. Yet, there remains potential to 
optimise the use of less frequently employed platforms to ensure even broader and more 
inclusive outreach.  

Moreover,  Member  States  have  designated  communication  officers  and  established  the  
website  portals86,  required  by  the  CPR87,  which  inform  about  their  programmes,  the 
announced and planned calls, rules for applicants, definitions of indicators and Monitoring 
Committee decisions.  

In some Member States (CZ, ES, MT and SE), challenges have been identified as regards 
how the balance can be  maintained between confidentiality (sensitive nature of internal 
security  projects)  and  public  awareness  to  ensure  transparency,  visibility  of  ISF’s 
achievements  and  public  engagement.  One  good  example  identified  was  to  tailor 

84 Article 22(j) of the CPR.  
85 As identified in the national mid-term evaluation report and/or Annual Performance Reports of AT, BE, 
BG, CZ, DE, EE, EL, ES, FI, IT, MT, NL, PL, PT, RO and SE. 
86 The Annual Performance Reports of all Member States show the establishment of website portals.  
87 Article 49(1) of the CPR. 

40 

 
 
communication  plans  (ES  and  FI)  that  differentiate  between  internal  and  public-facing 
information. Another challenge is the internal-external communication dichotomy as some 
national mid-term evaluations (BE, CZ, SE) indicate that programmes prioritise internal 
communication  between  Managing  Authorities  and  their  regular  project  beneficiaries, 
often at the expense of external outreach to the broader public and potential beneficiaries.  

4.1.2. Efficiency 

The current implementation of ISF does not yet allow for a comprehensive assessment of 
the  implementation  of  cost-effective  measures.  Efforts  undertaken  under  shared 
management and the Thematic Facility show reasonable results.  

Under shared management, Member States claim that the delays in the start of projects 
were  due  to  the  late  adoption  of  the  ISF  Regulation  and  approval  of  Member  States’ 
programmes  and  long  national  bureaucratic  processes,  in  spite  of  the  eligibility  of 
expenditure start date of 1 January 2021 as set out in the ISF Regulation. Some Member 
States  also  report  on  coordination  issues  with  relevant  bodies  and  inter-institutional 
communication, impacting the efficiency of project implementation. 

All Member States report on the challenges to implement two overlapping programming 
periods,  in  terms  of  human  resources,  procedures  and  reporting  requirements.  Member 
States’  mid-term  evaluation  reports  highlight  that  currently  the  ISF  management  and 
control  system  function  in  accordance  with  the  CPR.  However,  the  increased  reporting 
obligations, driven by the overlapping of the Funds and the increase in the frequency of 
transmission  of  indicators,  entail  significant  documentation  and  organisational  efforts, 
making  the  Fund  management  more  administratively  demanding  than  the  system  used 
under the ISF-P. 

Nevertheless,  the  vast  majority  of  Member  States  recognise  that  projects  are  generally 
progressing as planned, no points of major concern have been identified, and the level of 
cost-effectiveness is reasonable.   

Member  States  have  devised  different  methods  to  ensure  cost-effectiveness,  e.g., 
assessment of “Efficiency/Value for Money”  before project  approval (IE), a two-expert 
assessment of applications focusing on cost feasibility (PL) or preference given to second-
hand equipment and made efforts to ensure good value for money (LU), clear instructions 
and regular trainings on financial administration for grant applicants and beneficiaries (FI) 
and a structured project planning system (SI).  

Effective  planning  and  competitive  procurement  procedures  are  also  used  by  several 
Member States such as IE, EE with additional need maps and a cost-per-unit analysis, and 
IT with Consip. Assessment of market prices for similar products or services, estimates 
from  prospective  beneficiaries,  qualitative  explanations  on  cost-effectiveness  from 
beneficiaries,  and  benchmarking  with  previous  programming  periods  are  the  most  used 
methods to ensure cost-effectiveness. 

41 

 
Figure 22 - Results from survey question “What is the approach typically followed to gauge the 
cost-effectiveness of the projects selected for support?” 

Assessment of market prices for similar
products/ services

Benchmarking with previous programming
periods

19

22

28

Estimates from prospect beneficiaries

Qualitative explanations on cost-
effectiveness from prospect beneficiaries

21

None of the above

Other

Source: Preparatory study based on public survey 

The  SCOs,  as  per  Article  53  of  the  CPR,  which  sets  out  the  reimbursement  of  grants 
provided  by  the  Member  States  to  beneficiaries,  is  not  often  used  in  Member  States’ 
programmes  as  developing  the  methodology  for  their  application  is  a  complex  and 
intensive process for Member States audit and Managing Authorities (EE). Moreover, ISF 
relies heavily on procurement-based costs thus limiting the scope for SCOs.  

Nonetheless, some Member States introduced SCOs at national level (CY, IT, RO, SI, 
SE)  to  reduce  administrative  burden  and  improve  cost  management  and  monitoring 
efficiency, e.g. flat rates for high staff-share projects, unit costs for various expenses, and 
lump  sums  for  feasibility  studies  (SE).  These  Member  States  recognise  the  benefits  of 
simplified cost options in enhancing cost management and monitoring efficiency.  

Streamlined processes  were  also  introduced  in  several  Member  States,  contributing  to 
increased cost-effectiveness, e.g. the option to account for labour costs based on the tariffs 
in  the  Government  Tariff  Manual,  which  allows  for  fixed-rate  labour  cost  accounting 
instead of detailed pay sheets, reducing administrative burden and aligning with privacy 
laws (NL).  

42 

 
 
 
 
 
 
 
Challenges: Administrative burden, human resources and timelines  

Figure 23 - Results from survey question “To what extent have the following points represented a 
challenge in managing Member States Programmes and related application procedures?” (N=53) 

Designing direct and competitive award

13%

21%

Contractualization

4%

30%

40%

38%

9%

17%

9%

19%

Respecting the timelines

4%

25%

43%

21%

8%

Use of the digital platform for application

Providing sufficient support to beneficiaries

15%

15%

28%

30%

Adhering to reporting requirements

6%

30%

Adhering to reporting timelines

8%

28%

19%

26%

11%

30%

15%

9%

36%

36%

17%

11%

17%

11%

 Managing payments

13%

26%

36%

9%

15%

0%

50%

100%

Not at all

To a limited extent

To some extent

To a large extent

Don't know

Source: Preparatory study based on public survey 

Most  Member  States  report  that  resource  limitations  and  highly  demanding 
administrative  requirements  exacerbate  a  number  of  challenges  for  both 
beneficiaries and Managing Authorities. Resource limitations include insufficient level 
of staffing, high staff turnover and difficulties in recruiting staff with very specific skillsets. 
These  limitations  exacerbate  challenges  including  respecting  timelines  (particularly  for 
reporting  and  programme  management),  comprehensive  reporting  requirements,  system 
management and related procedures such as for payments and applications as well as the 
use of new digital platforms.  

This  emphasises  the  importance  of  streamlining  ISF  procedures  and  reducing  the 
administrative burden at national level, as well as providing greater support to Managing 
Authorities and beneficiaries by means of targeted training and guidance.  

Moreover, information extracted from the survey responses on the average time spent by 
Managing  Authorities  in  man-days  full-time  equivalent  (FTE)  for  each  activity/task  to 
implement ISF is reported in Annex IV, reflecting differences in project complexity and 
resource needs. This variability suggests that current procedures may disproportionately 
impact  project  efficiency,  particularly  for  projects  requiring  extensive  staff  time,  time 
commitments  for  managing  direct  and  competitive  awards,  preparing  and  evaluating 
proposals and reporting.  

The case study on Germany confirmed that ISF allocations are sufficient but stressed the 
importance of cost efficiency due to additional administrative challenges linked to a layer 
of national requirements (e.g. rigid procedures, paper-based extensive financial reporting, 
and insufficient clarity and frequent updates of guidelines). 

43 

 
 
The  ISF  Regulation  ensures  cost-effectiveness  through  the  Thematic  Facility.  Its 
significant flexibility allows any unspent resources within a specific fund component to be 
reallocated to other components, thus maximising the use of EU funding.  

Cost-Effectiveness of Specific Actions 

Specific Action projects are selected at national level and most Member States add national 
requirements and administrative procedures (“gold-plating”). As a result, projects usually 
start  their  implementation  with  a  certain  delay.  The  delays  may  be  reinforced  by 
complexity and coordination challenges of such large transnational projects and delays in 
procurement procedures. For example, the SA EMPACT Costa del Sol project was planned 
to start in early 2022 for one year, but experienced delays in implementation and had to be 
extended  by  one  more  year.  This  was  mainly  due  to  the  operational  and  financial 
complexity of managing a transnational project of such magnitude and to procedural and 
contractualisation issues at national level. 

Transnational  Specific  Action  can  be  financially  managed  under  two  different  options. 
Under Option 1, the funding is incorporated into the programme at the lead Member State, 
whose  Managing  Authority  is  subsequently  tasked  as  being  a  single  point  of  contact 
handling project related matters and reporting to the Commission. Option 1 is considered 
by DG HOME as the ‘default option which allows for the optimisation of the use of the 
EU  funding’  allowing  alignment  between  different  national  rules  to  which  project 
beneficiaries are subject. Option 2 allows for project beneficiaries to have project funding 
allocated to their respective programmes.  

A significant proportion of the ongoing transnational projects are managed under Option 
2,  allowing  project  beneficiaries  to  have  project  funding  allocated  to  their  respective 
programmes.  This concerns 8 out of 12 projects under Thematic Facility Work Programme 
2021-2022 and 3 out of 8 projects under Thematic Facility Work Programme 2023-2025, 
which indicates a decrease in managing projects under Option 2 as recommended by the 
Commission. Option 1 should be the default option for the sake of efficiency as the time 
and resources spent on the amendment of Member States’ programmes are proportionally 
increased when large consortia opt to implement Specific Actions projects under Option 
2, necessitating the amendment of many Member States’ programmes. This is especially 
the  case  for  beneficiaries  and  Managing  Authorities  which  have  smaller  shares  of  the 
Specific Actions project budget. The preference among beneficiaries for Option 2 likely 
reflects  considerations  of  differences  between  national  rules  which  can  hinder  project 
implementation  and  perceived  challenges  in  managing  a  larger  consortium.  The 
administrative  capacity  of  beneficiaries  and  the  Managing  Authorities  is  considered  an 
important limiting factor, pointing to a preference to distribute the administrative burden 
to project partners who should be more aware of applicable national rules.  

Irrespective  of  the  Option  under  which  projects  are  administered,  the  incorporation  of 
Specific Actions into Member States’ programmes and their subsequent management by 
Managing  Authorities  can  be  unclear  for  beneficiaries  unfamiliar  with  national  ISF 
procedures  and  rules.  At  the  beginning  of  the  programming  period,  some  beneficiaries 
were unaware whether it was the Managing Authority or Commission who were managing 
the project selection and the application requirements.  

Moreover, Specific Actions show a certain increase in administrative burden at national 
level and cases of gold plating by Member States (e.g. the need to rearrange initial work 

44 

 
activities to fit national rules). Initially, beneficiaries who had no experience in working 
on Specific Actions were not aware of these obstacles and had not factored in the necessary 
time, leading to a disruption of the planned timeline of the project already from the start.  

Nonetheless, beneficiaries note that once there is sufficient awareness of Specific Actions 
procedures, the administrative burden in preparing an application for a Specific Actions 
competitive call is considered comparable to Member States Actions and Union Actions.   

Cost-Effectiveness of Union Actions 

Despite still ongoing,  Union Actions projects  suggest  reasonable cost-effectiveness  and 
efficiency. Beneficiaries comply with the requirements to spend the allocated amounts in 
a highly efficient way, i.e. market research of resources and services during the application 
phase to secure the best economic value for their project activities, and regular monitoring 
of their expenditure and necessary adjustments during project implementation.  

Additionally,  some  beneficiaries  employ  further  measures  to  achieve  project  objectives 
cost-effectively, e.g. by reducing office expenses through remote work, choosing online or 
hybrid  meetings  to  lower  travel  costs  or  using  digital  training  materials.  Beneficiaries 
report that administrative demands for implementing their projects and reporting results 
are  reasonable,  and  they  receive  supportive  guidance  from  project  officers,  particularly 
when modifications are needed to the initial project activities and work plan, or in aligning 
their projects with EU goals. Some beneficiaries who have received multiple grants (such 
as transnational law enforcement networks) note that they have not experienced any gaps 
in financial support over the programming periods and have been able to continue their 
operations without interruption. 

Cost-Effectiveness of Emergency Assistance  

EMAS  beneficiaries  generally find the application process  straightforward compared to 
other EU funding, as it allows competent authorities to request it without any open calls. 
The new EMAS procedure, and its more detailed rules, is meant to ensure that the EMAS 
process is more structured, transparent, sound, and entirely emergency-driven.  

The  flexibility  entailed  by  the  Thematic  Facility  mechanism  attests  also  strong  cost-
effectiveness,  particularly  for  EMAS.  This  is  because  unspent  EMAS  resources  can  be 
reallocated to other fund components and unspent resources from other fund components 
can be redirected to support EMAS for emergency situations. 

Management and Control System 

Overall, under shared management,  the ISF management and control system operate 
as per the CPR’s legal requirements88. Several Member States report that these systems 
work efficiently, with clear and comprehensive procedures for reporting requirements and 
exchange of knowledge. They also report that Managing Authorities have adequate and 
experienced  staff  with  clearly  defined  roles  and  responsibilities.  Some  Member  States’ 
established  systems  (RO  and  LU)  allow  for  the  pooling  of  financial  and  management 
resources for all Home Affairs Funds, thereby reducing administrative burden and gaining 
access to additional training and exchange of experiences thus enhancing staff efficiency. 

88 Articles 69 to 85 of the CPR. 

45 

 
 
While the inclusion of the ISF in the CPR has potentially created economies of scale within 
Member States, as the same set of rules is applicable to all EU funds in shared management, 
a few Member States believe that the inclusion of the ISF under the CPR has negatively 
affected the management and control systems’ efficiency. They perceive the system to be 
over-regulated, with higher, more complex and desproportionate reporting and information 
demands compared to the ISF-P. Some Managing Authorities identified challenges such 
as difficulties in reporting data and indicators, lack of technical resources and insufficient 
staff; compliance with horizontal conditions and approval by the Monitoring Committee 
requirements; and lack of clarity on reporting.  

The perception of increased administrative burden  may be influenced by the fact that the 
obligations are new as compared to the previous programming period and the introduction 
of a new framework requires an adaptation period 89. 

Despite the increase in administrative burden, Member States consider it to be reasonable 
in  relation  to  the  results.  Programme  management  has  improved  without  creating  an 
insurmountable burden and beneficiaries’ increased reporting obligations are considered 
to be justified and proportionate to the ISF’s size.  

Some Member States (CY, IT, RO, SE and SI) recognise the benefits of simplified cost 
options  in  enhancing  cost  management  and  monitoring  efficiency.  Nonetheless, 
perceptions remain mixed, as others report their limited or no effect. This may be due to 
some  Managing  Authorities  viewing  the  development  and  implementation  of  SCO 
methodology at project level as adding to the administrative burden as it requires extensive 
preparatory work for both audit and national authorities. As Member States consider the 
independent development of SCOs to be overly burdensome, they suggest the Commission 
to centralise the process and establish standardised SCOs that could be applied across all 
projects.  

Some Member States introduced the use of SCOs at the national-level and as mentioned 
by  Cyprus,   Italy,  Romania,  and  Slovenia,   SCOs  contribute  to  the  reduction  of  the 
administrative  burden  and  the  improvement  of  cost  management  and  monitoring 
efficiency. Sweden implemented SCOs,  including flat rates for high staff-share projects, 
unit costs for various expenses, and lump sums for feasibility studies. In general, findings 
from Member States mid-term evaluation reports in AT, CZ, DE, LT and SI, show that the 
implementation  of  simplified  cost  options  is  seen  as  a  possibility  to  simplify  the  ISF 
administrative  procedures.  Nevertheless,  in  this  respect,  the  opinions  of  some  of  the 
consulted stakeholders differ. The Member States mid-term evaluation reports reveal that 
in some Member States, there is a perception of uncertainty regarding which expenditures 
(e.g. residual cost lump sum) can be settled by using a SCO and the extent to which they 
can be extended to other operations remains vague. According to the findings from the SI 
mid-term  evaluation  report, 
implemented  several 
simplifications. These include setting a three-month deadline for preparing reimbursement 

the  Managing  Authority  has 

89 To ease the transition into the new performance framework, the Commission has supported Member States 
by providing a clear definition of the elements of measure in the output and result indicators set in Annex 
VIII of the ISF, with information about the guiding principles of the performance framework for the 2021-
2027 AMIF/ISF/BMVI. Even prior to the approval of the programmes, the Commission provided indicator 
fiches to the Member States for each output and result indicator, specifying points like measurement unit, 
definition, or associated result and output indicator.   

46 

 
 
 
claims,  introducing  simplified  cost  methods  for  staff  costs,  and  providing  guidance  on 
reporting and methodology to beneficiaries.  

Figure  24 -  Survey  responses  to  the  question  “To  what  extent  had  the  following  changes  in 
procedures introduced by the ISF-P resulted in the simplification of administrative burden for the 
beneficiaries of the Fund?”  

10

11

Not at all

6

14

12

To a limited
extent

To some extent

The chart shows Managing Authorities 
survey responses on the extent to which 
reduced  administrative 
SCOs  have 
burden.  This  distribution  suggests  a 
mixed  perception  among  them,  with  a 
notable portion recognising some level 
of  simplification,  while  others  report 
limited or no effect. 

Source: Preparatory studies based on survey responses 

Gold-plating  

Due to “gold-plating” Member States often prefer project implementation under direct 
management  over  shared  management,  as  beneficiaries  under  the  latter  face  a 
significantly  higher  administrative  burden.  Examples  provided  are:  requirements  for 
Member States  Actions  are typically more  strict  than those under  Union  Actions  (DE); 
Member States Actions being overly complex and require extensive paperwork (HR); and 
the  expected  deliverables  for  each  project  work  package  under  direct  management  are 
clearly defined while shared management projects require detailed proof to justify incurred 
costs, making the process significantly more time-consuming (NL). 

Implementing SCOs at the national level demands extensive preparation, as both audit and 
national authorities must validate them, making the process time-consuming and complex. 
In  the  ISF,  reliance  on  procurement-based  costs  limits  SCO  effectiveness,  as  many 
expenses fall under indirect costs. The issue is increased by "gold-plating," where national 
authorities impose extra requirements beyond EU standards. A Managing Authority noted 
these arise from national laws and should align with audit authority recommendations to 
ease implementation.  

Member  States  authorities  and  beneficiaries  have  provided  key  recommendations  to 
further simplify the ISF implementation, monitoring, and reporting procedures.   

Firstly, the need for Commission to provide clearer guidance and training for projects 
under  shared  management,  such  as  on  the  use  of  new  IT  systems  and  sharing  good 
practices, and particularly, for the Commission to provide training and guidance on the 
implementation  of  SCOs,  thus,  alleviating  the  administrative  burden  and  workload  of 
individual Member States.  

Beneficiaries  of  projects  under  direct  management  indicate  the  need  for  Commission 
guidance  on  compliance  and  administrative  requirements,  as  well  as  increased  training 
opportunities for project coordinators and beneficiaries, and support throughout a project’s 
lifecycle.  

Secondly, the need for simplification in administrative and reporting requirements and 
indicators,  such  as  reporting  standardisation  and  the  use  of  Artificial  Intelligence  (AI) 

47 

 
to reduce project processing. There are mixed views regarding centralisation of expertise. 
On  the  one  hand,  one  Member  State  reports  its  need  in  order  for  experienced  staff  to 
manage  complex  funding  programmes  and  work  alongside  financial  and  operational 
experts. On the other hand, another Member State reports that keeping the ISF management 
within one Ministry guarantees a high degree of subject-matter expertise and institutional 
memory as in their experience, the transfer of the ISF Audit Authority from one Ministry 
to another resulted in a noticeable decline in expertise and in less effective oversight, which 
underscores  the  significant  drawbacks  of  separating  oversight  functions  from  subject-
matter expertise.  

4.1.3 Coherence 

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

Internal Coherence 

Overall,  the  ISF  is  considered  generally  coherent  with  other  initiatives  within  its 
policy domain and across management modes (shared, direct and indirect). Coherence 
is  also  present  between  the  Fund’s  four  components  (Member  State  programmes, 
Specific Actions, Emergency Assistance and Union Actions), although some challenges 
remain.  

Most Member States’ programmes are coherent with other initiatives and support the 
same  objectives  as  the  ISF.90  To  ensure  internal  coherence  and  complementarity 
throughout  the  ISF  programming  period,  Member  States  have  reported  establishing 
monitoring systems  designed to analyse and review overlap, duplication and synergies. 
For instance, a stakeholder highlighted participation in an informal ISF national Managing 
Authority  network,  which  convenes  approximately  every  six  months  to  facilitate 
knowledge exchange and explore synergies. 

Each Member State must ensure that priorities outlined in its programmes align with the 
Union’s internal security priorities and challenges.91 During the programming phase, the 
design of Member States’ programmes is based on their respective needs assessment and 
consistency  with  EU  internal  security  priorities,  which  is  subsequently  assessed  by  the 
Commission.92 Furthermore, Member States also established Monitoring Committees to 
oversee and identify any overlaps and duplications.93  

At  project  level,  coherence  and  complementarity  are  ensured  in  some  Member  States 
through procurement processes that require applicants to explain how their projects will 
generate synergies.94 Evaluation committees, whose members are typically well-versed in 

90 The national mid-term evaluation reports of 21 Member States indicate that an assessment of coherence 
with other initiatives supported under relevant policy areas was carried out during  the programming phase. 
91 Article 13(1) of the ISF Regulation. 
92 Article 13(2) of the ISF Regulation. 
93 This is the case in LU, MT, SI, LV, NL, BG, CY, CZ, FI, RO, EE, LT, and has been emphasised in the 
survey analysis.  
94 This is the case in Estonia and Lithuania and was mentioned in interviews with MA stakeholders. 

48 

 
 
other relevant programmes, then scrutinise these applications to identify potential risks of 
overlapping.  

Formal mechanisms are in place to ensure the Thematic Facility complements the support 
delivered through the Member States’ Programmes at the EU and national level.   

At EU level there is a designated coordination unit in DG HOME, which ensures there is 
a clear consultation process where the relevant geographic and policy units feed into the 
decision-making  processes  by  drawing  up  the  Thematic  Facility  Work  Programmes. 
Possible  complementarities  across  funding  provided  through  different  components  and 
management modes should therefore be ensured.  

Additionally,  the  Thematic  Facility  Steering  Group  (TFSG)  composed  of  DG  HOME 
Senior  management  is  responsible  for  the  overall  planning  and  monitoring  of  the 
implementation of the Specific Actions and the related budget. The TFSG validates the 
proposals for selection, based on the selection by the individual Specific Action Steering 
Committees95 and takes decisions on the final budget allocation resulting from the outcome 
of the evaluation of the calls, bearing in mind the implementation of all other strands of 
the Thematic Facility Work Programme.  

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

Direct and indirect management modes are specifically structured to enhance and support 
interventions outlined in Member States’ programmes or to finance initiatives that cannot 
be executed under shared management due to various constraints at the national level, such 
as financial challenges.  

The various actions under direct management complement each other and are considered 
coherent, as each has a distinct objective. Union Actions are considered coherent as they 
also promote cross-border cooperation. In a similar vein, Emergency Assistance facilitates 
actions that are difficult to implement within national programmes by addressing urgent 
and  unpredictable  needs  arising  from  emergency  situations.  Additionally,  indirect 
management  projects  empower  the  EU  to  delegate  budget  implementation  tasks  to 
entrusted entities through contribution agreements (e.g. MPF and JRC). 

Under shared management,  Specific Actions have complementarity with  other Member 
States’ programmes and Union Actions. For instance, EMPACT activities can be funded 
by  ISF  in  shared  management  under  the  Member  States  Programmes  and  via  Specific 
Actions, and in direct management via Union Acitions. But they also receive support from 
Europol  (through  grants),  from  other  EU  Agencies,  and  also  from  the  Member  States’ 
national budget. Each funding source is used in a different way to reach different objectives 
(e.g. reinforce national capacity/support running investigations / provide strategic medium-
term support) and the risk of overlap is minimised if, and only if, the EMPACT core actors 
involved  are  clearly  idenfied  and  coordinate  within  the  platform  and  with  actors  at  EU 
level  (including  the  Commission  services).  The  combination  of  funding  sources 
nevertheless  remain  complex  and  burdensome  and  somewhat  hampers  the  overall 

95 The Working Group on Specific Actions is responsible for the overall coordination, planning and support 
of all Specific Action Steering Committees. 

49 

 
 
efficiency of the fight against organised crime, and explains why EMPACT stakeholders 
call for a single and reinforced EMPACT budget.   

The ISF-P interim evaluation highlighted the need for improved awareness of all projects 
under  the  ISF-P  umbrella,  as  beneficiaries  reported  that  they  are  often  unaware  of  the 
projects  being  carried  out  within  this  framework.  This  challenge  was  also  noted  in  the 
current  ISF  mid-term  evaluation,  where  stakeholders  in  the  focus  group  specifically 
pointed out the disconnect between Union Actions projects and those funded through the 
shared  management  component  of  the  ISF.  National  stakeholders  acknowledged  its 
awareness  of  Union  Actions  but  often  found  it  unclear  how  these  relate  to  ISF-funded 
actions at the national level. Conversely, Union Actions beneficiaries indicated that they 
have limited oversight of projects funded at the national level, making it difficult for them 
to propose projects that align with and complement ongoing national initiatives. 

Coherence with the EU internal security policy  

Over  the  past  years,  the  EU  has  developed  consecutive  security  strategies  to  address  a 
spectrum  of  developments  and  threats  within  the  EU’s  internal  security.  The  current 
overarching strategy, the EU Security Union Strategy, serves as the multiannual framework 
guiding  these  efforts.  Within  this  framework,  the  EU  has  devised  various  thematic 
strategies  and  action  plans  aimed  at  combating  the  most  prominent  trends  in  internal 
security. 

Table 1 provides an overview of the strategic priorities and objectives outlined in the EU 
Security Union Strategy. These priorities and objectives are echoed in the objectives 
and policy fields of the ISF, demonstrating coherence between the two frameworks 
and  how  the  ISF  Specific  Objectives  are  closely  aligned  with  the  strategic  priorities 
outlined in the EU Security Union Strategy. 

Table 1 – Alignment between the Specific Objectives of the ISF and the EU Security Union Strategy 

EU Security Union Strategy 

Internal Security Fund 

Objectives 

Objectives 

Policy Fields 

Strategic 
Priorities 

future-proof 

‘A 
security 
environment’ 

‘Protecting 
Europeans 
terrorism 
organised crime’ 

from 
and 

‘Tackling 
threats’ 

evolving 

- Cybercrime 

Critical 

- 
protection and resilience 

infrastructure, 

- Cybersecurity 

- Protecting public spaces 

- Modern law enforcement 

-  Countering  illegal  content 
online 

- Terrorism and radicalisation 

- Organised crime 

50 

SO1: 
and 
improving 
facilitating  the  exchange 
of information  

SO2: 
and 
improving 
intensifying  cross-border 
cooperation 

SO3: 
the 
supporting 
strengthening  of  MS’ 
capabilities  in  relation  to 
preventing and combating 

- Counter-terrorism, incl. 
of 
prevention 
radicalisation,  protection 
of  public  spaces,  critical 
infrastructure/entities 

-  Organised 
(including 
trafficking, 
firearms 
migrant 
corruption, 
laundering) 

crime 
drug 
THB, 
trafficking, 
smuggling, 
money 

- Cybercrime, incl. Child 
Sexual Abuse 

 
‘A  strong  security 
Ecosystem’ 

-  Cooperation  and  information 
exchange 

- Strong external borders 

-  Strengthening  research  and 
innovation 

- Skills and awareness training 

Source: Preparatory study on Coherence. 

terrorism 

crime, 
and 
radicalisation,  as  well  as 
managing security-related 
incidents, risks and crises 

- 
Law 
cooperation 

enforcement 

- Information exchange 

-  Cooperation  with  third 
countries 

SO1 and SO2 are derived from strategic priority of “A strong security ecosystem” as it 
encompasses information exchange and cross-border cooperation. On the other hand, SO3 
is  derived  from  two  strategic  priorities:  “Protecting  Europeans  from  terrorism  and 
organised crime” and “A future-proof security environment”.  

Although the strategic priority on “tackling evolving threats” is not explicitly mentioned 
in any of the ISF Specific Objectives, the objectives under this priority are reflected in the 
policy fields that the ISF addresses. This demonstrates the coherence and complementarity 
of the Specific Objectives of the ISF within the broader framework of the  EU Security 
Union Strategy.  

External Coherence 

Coherence with national policies in the field of internal security 

Support provided under the ISF complements national, regional and local intervention as 
national security remains a competence of the Member States.96 In doing so, the ISF aims 
to enhance the Union’s contribution to achieving its objectives in areas where protecting 
security requires cooperation and coordination at Union level. 

Most Member States specifically reported aligning their programmes to national internal 
security  policies  to  ensure  coherence  and  complementarity.  While  most Member  States 
indicated  that  national  interventions  complement  ISF  activities  to  some  extent,  some 
reported  a  large  extent  of  complementarity,  and  a  few  Member  States  in  particular 
mentioned  that  national  financial  instruments  complement  ISF  funding.  A  considerable 
number of beneficiaries of Union Actions and Member States’ programmes also noted that 
national interventions complement the activities provided by the ISF to a large extent. 

Coherence with the other Home Affairs Funds (AMIF and BMVI) 

The Home Affairs  Funds play a key role in  tackling all changes  related to  the efficient 
management of migration, the EU’s external borders, and the ensuring of a high level of 
security in the EU. All Home Affairs Funds are under the CPR with the main rationale to 
facilitate  greater  coherence,  exploit  economies  of  scale  and  avoid  overlaps  between 
actions. In view of this, the ISF remains consistent with and complementary to other Union 
financial programmes in the field of security and ensures synergies with all Funds covered 
by the CPR and other Union instruments and funds 97.  

Concerning  the  Member  States’  programmes,  Article  22(2)  of  the  CPR  ensures 
coordination by prescribing that programmes supported by the Home Affairs Funds shall 

96 Article 6(1) of the ISF Regulation. 
97 Article 6(2) of the ISF Regulation. 

51 

 
 
only  use  support  from  one  of  these  Funds.  Furthermore,  the  Fund-Specific  Regulations 
generally  require  Member  States  and  Managing  Authorities  to  ensure  that  priorities 
addressed  in  their  programmes  are  consistent  with  and  respond  to  Union  priorities  and 
challenges in the given area, namely either to the area of security, to asylum and migration 
management  or  to  border  management  and  visa  policy.98  Article  13(5)  of  the  ISF 
Regulation, in particular, requires Member States to avoid any overlaps in the design of 
their  actions.  Furthermore,  information  must  be  provided  in  the  Annual  Performance 
Reports  on  the  complementarity  between  the  actions  supported  under  the  ISF  and  the 
support provided by other EU funds, including other Home Affairs Funds99.   

Under the Thematic Facility, coherence and complementarity are ensured at the planning 
stage through the adoption of Work Programmes by the Commission.  

To further strengthen complementarities between the ISF and BMVI, equipment and ICT 
systems whose primary use is in accordance with the ISF Regulation may also be used - to 
a maximum of 30% of the total period of use - in the complementary area to achieve the 
objectives of the BMVI.100  

Almost all Member States indicate that their programmes are coherent with other EU 
initiatives and EU funds (including HAF).101 Most Member States reported that the 
ISF is coherent with other Home Affairs Funds, and more than half of them102 explicitly 
refer  to  having  implemented  coordination  mechanisms  to  ensure  synergies  and  avoid 
overlaps. These efforts involve continuous cooperation between Managing Authorities and 
beneficiaries to align their programmes under the ISF with the BMVI and AMIF.  

A large portion of the Managing Authorities report that actions organised by the AMIF and 
BMVI were seen to complement ISF activities to some extent and actions supported by the 
BMVI  and  the  Customs  Control  Equipment  Instrument  (CCEI)  were  also  noted  as 
complementary to some extent.  

In turn, most beneficiaries of Union Actions and Member States’ programmes indicated 
that  actions  organised  by  the  AMIF  and  the  BMVI  complement  to  a  large  extent  ISF-
funded  initiatives  and  actions  organised  by  the  BMVI  and  CCEI.  When  applicable, 
Member States justify any overlaps on objective grounds, ensuring they address different 
needs  or  target  groups.  Furthermore,  most  Member  States  support  cross-cutting  policy 
agendas  by  complementing  the  support  offered  by  other  EU  Funds,  thereby  enhancing 
overall coherence and effectiveness.  

On the complementarity between ISF, AMIF and BMVI, over 70% of survey respondents 
across  all  stakeholder  groups  believe  that  activities  are  complementary  either  to  some 
extent or to a large extent. 

98 Article 13 (1) of the ISF Regulation,  Article 16(1) of the AMIF and Article 13(1) of the BMVI Regulation.  
99  Article  30(1)(c)  of  the  ISF  Regulation.  Prior  to  the  submission  of  this  information  in  the  Annual 
Performance Report, it must be approved by the Monitoring Committee (Article 40(2)(b) of the CPR). 
100 Article 5(4) of the ISF Regulation. 
101 All APRs or Mid-term Evaluation Reports, except for PL which did not include information to address 
this question. 
102 AT, BE, BG, CY, EE, ES, FI, FR, HR, IT, LT, LV, LU, NL, PL, RO and SK.  

52 

 
 
 
Coherence with other EU Funds 

To ensure further coherence and complementarity between the ISF and other EU Funds in 
other  policy  areas,  there  has  been  demarcation  lines  with  other  Funds  across  the 
programming  periods,  e.g.  Horizon  Europe,  the  Citizens,  Equality,  Rights  and  Values 
Programme,  the  Justice  Programme,  rescEU,  the  Digital  Europe  Programme,  and  the 
InvestEU  Programme.  To  remedy  the  coherence  issues  identified  in  2014-2020 
programming  period in  relation  to  crisis  management/civil protection and cybersecurity 
due  to  the  lack  of  a  clear  definition  in  the  legal  basis,  the  ISF  Regulation  has  added  a 
definition of “preparedness” and “cybercrime”.103 Also, to achieve further synergies and 
coherence in the area of drugs, certain elements of the ISF’s objectives related to drugs are 
now incorporated into the ISF, which were previously covered by the Justice programme 
in the 2014-2020 programming period.104 

Virtually all Member States’ programmes are coherent and demonstrate complementarity 
of the ISF with other EU Funds (e.g. Horizon Europe and the European Social Fund Plus 
(ESF+).  For  example,  between  ISF-funded  project  SWORD  -  Fighting  large-scale 
organised  property  crime  and  the  Horizon  Europe-funded  VANGUARD  project,  which 
aims to develop innovative tools for combating human trafficking. Several Member States 
reported coherence with the Justice Programme and Fiscalis and other EU initiatives105 too 
and  have  taken  steps  to  integrate  their  programmes  to  these  initiatives  ensuring  a 
comprehensive approach to EU policy objectives. 

Under  direct  and  indirect  management,  Union  Actions  have  been  complementary  to 
actions supported by Specific Actions and other EU funding opportunities (e.g. Horizon 
Europe, BMVI). Objectives and activities of Union Actions projects complement and are 
coordinated  with  those  of  EU-level  agencies  and  bodies  and  activities  (e.g.  projects 
‘SCOPE’  tackling  migrant  smuggling  networks  in  cooperation  with  third  countries  and 
‘MAOC-N’ combatting maritime drug trafficking) and Europol-led initiatives.  

Specific  Actions  also  are  complementary  with  other  EU  funding  mechanisms,  such  as 
Horizon 2020 (Horizon Europe’s predecessor). For instance, ES-led (PPS II) project ‘POP-
ART’ takes advantage of a technical solution previously developed in a HORIZON project. 
Complementarity is also prioritised by the Commission as a result of the launching of the 
PPS II call in which two projects financed under this call build on Horizon 2020 projects. 

Nonetheless, there is room for improvement in coordinating Union Actions projects with 
those under Member States’ programmes, with the view to maximise synergies between 
projects under these different fund components. Beneficiaries of Union Actions projects 
reveal limited knowledge or understanding of projects being implemented at Member State 
level (e.g. insufficient information sharing and access to project outputs) and indicate they 
would  benefit  from  information  on  ongoing  or  completed  projects  under  shared 
management. 

103 Articles 2(2) and 2(5) of the ISF Regulation, respectively. 
104 Recital (18) ISF Regulation. 
105  These  initiatives  focus  on  infrastructure  security,  cybersecurity,  and  radicalisation  prevention  (DE), 
cooperation between law enforcement, customs, and border authorities (FI), migration, internal security, and 
border  management  with  links  to  other  EU  instruments  (PL),  and  on  information  system  security  and 
environmental crime (SK). 

53 

 
 
The Commission and the Member States shall ensure that the support provided under the 
Fund  and  by  the  Member  States  is  consistent  with  the  relevant  actions,  policies  and 
priorities of the Union and is complementaryand is complementary to support provided 
under other Union instruments.106 If agreed by the Monitoring Committee, at the request 
of a Member State, up to 5% of the initial allocation to that Member State from any of the 
Funds covered by the CPR under shared management may be transferred to the Fund under 
direct or indirect management.107  

EU funds and financial instruments in other policy areas outside the scope of the CPR, but 
of  relevance  to  ISF  also  ensure  coherence  and  complementarity.  The  Regulation 
establishing  Horizon  Europe  sets  out  specific  rules  which  ensure  that  the  strategic 
planning, mission and partnership under this Fund are complementary and coherent with 
other  EU  funds,  including  the  ISF.108  Furthermore,  rescEU  specifically  states  that 
synergies,  complementarity  and  increased  coordination  shall  be  developed  with  other 
instruments of the Union, including those supporting security policies.109 

To ensure coherence and complementarity, most Member States put in place coordination 
measures during the programming and implementation phases.110 Managing Authorities 
reported coordination with other EU-funded initiatives (e.g. exchanges with other entities 
managing  the  ISF  at  Member  State  level)  as  the  most  common  measure,  followed  by 
assessing  interventions  with  similar  objectives  to  the  ISF  and  the  establishment  of  a 
Monitoring Committee or inter-institutional group.  

Several Member States reported coherence with the Justice Programme and Fiscalis and 
other EU initiatives and have taken steps to integrate their programmes to these initiatives 
ensuring a  comprehensive approach to  EU policy objectives. These initiatives focus  on 
infrastructure  security,  cybersecurity,  and  radicalisation  prevention  (DE),  cooperation 
between  law  enforcement,  customs,  and  border  authorities  (FI),  migration,  internal 
security,  and  border  management  with  links  to  other  EU  instruments  (PL),  and  on 
information system security and environmental crime (SK). 

A substantial number of Managing Authorities observed that the Cohesion Policy Funds, 
particularly the European Regional Development Fund (ERDF), along with actions from 
the Citizens, Equality, Rights and Values Programme, the Justice Programme, and Horizon 
Europe  complemented  ISF  activities  only  to  a  limited  extent  or  not  at  all.  The  Digital 
Europe Programme was similarly noted to complement ISF activities to a limited extent. 
Similarly, for actions organised by the InvestEU Programme and the Technical Support 
Instrument and actions from the rescEU, a large portion of Managing Authorities indicated 
no complementarity with ISF activities.111  

Coherence with the EU external policy 

The aim of SO3 to advance and facilitate the exchange of information (where relevant) 
with  third  countries  and  international  organisations  is  further  detailed  through  a  list  of 

106 Article 6(2) of the ISF Regulation. 
107 Article 7(4) of the ISF Regulation.  
108 Article 6, 10 and Annex IV of Regulation (EU) 2021/695. 
109 Article 26 (2) Decision No 1313/2013/EU. 
110 E.g.  AT, EE, FI, LT, MT, SI and SK demonstrate effective fund management strategies. 
111 Annex V. 

54 

 
 
implementation measures and actions supported by the ISF in Annexes II and III of the 
ISF Regulation.  

From the perspective of external action instruments, the general objectives and most of the 
specific  objectives  of  the  Neighbourhood,  Development,  and  International  Cooperation 
Instrument (NDICI - Global Europe) are distinct from those of the ISF as they only regard 
the furthering of stability through contributing to the protection of civilians and responding 
to crisis situations.112  

While  the  general  objectives  of  the  Instrument  for  Pre-Accession  Assistance  (IPA  III) 
remain broad, the specific objectives and the thematic priorities of IPA III show certain 
similarity  to  that  of  the  ISF  in  relation  to  reinforcing  security  and  the  fight  against 
corruption and organised crime and, more specifically, in promoting police cooperation 
and information exchange, developing effective tools to prevent and fight organised crime, 
trafficking in  human beings and of small  arms and light  weapons, migrants  smuggling, 
drug  trafficking,  money  laundering/financing  of  terrorism  and  corruption,  supporting 
engagement with the Union on counter-terrorism and preventing radicalisation.113 Under 
IPA  III,  ensuring  coherence  and  avoiding  duplication  between  its  assistance  under  and 
other assistance provided by the Union and the Member States is of key importance.114 To 
that  end,  the  Commission  and  the  Member  States  cooperate  closely,  i.e.  through 
consultations, and frequent exchanges of information especially during the programming 
processes.115 

Article 5(3) of the ISF 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.  

The ISF Regulation further ensures thematic coherence between actions outside the Union 
funded by the ISF or through other Union instruments.  

Under shared management, Member States need to consult the Commission prior to the 
approval of a project being supported by the ISF in or in relation to a third country116. A 
procedure  has  been  set  up  through  which  DG  HOME  consults  the  relevant  services 
(INTPA, MENA, ENEST, EEAS) and approves (with or without comments) or rejects the 
project that has been submitted by the Member State. There are however certain challenges 
in  shared  management,  amongst  which  the  limited  impact  of  the  Commission’s 
recommendations  as  well  as  the  limited  ability  of  the  Commission  to  monitor  the 
implementation of those activities by the Member States.  

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 

112 Article 3(2)(c)(iii) and Article 3(2)(d)(i) of Regulation (EU) 2021/947. 
113 Article 3 and Annex II of Regulation (EU) 2021/1529. 
114 Article 5(1) of Regulation (EU) 2021/1529. 
115 Article 6 of Regulation (EU) 2021/1529. 
116 Article 13(1) of the ISF Regulation. 

55 

 
 
participate contribute to the achievement of the objectives of the Fund117; 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 Fund118. At the reporting and evaluation stages 119, assessing 
complementarity between the actions supported under the ISF and the support provided by 
other Union funds to actions taken in or in relation to third countries is required. 

In  the  context  of  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.120  Also,  specific  rules  are  laid  down  on  the  conditions  of 
receiving contributions from both NDICI and from another Union programme.121 

Few Member States report specifically coordinating between the objectives and actions in 
or in relation to third countries supported by ISF, which are also fostered through national 
foreign policy with a view to ensuring coherence and complementarity.122 There appears 
to be limited complementarity between the ISF and other existing EU instruments 
with  an  EU’s  external  dimension,  such  as  NDICI  and  IPA  III.  The  views  of  survey 
respondents  vary:  a  number  of  them  noted  a  lack  of  complementarity  between  ISF 
activities  and  actions  from  both  IPA  III  and  NDICI.  In  turn,  consulted  stakeholders 
affirmed that the ISF aligns with other relevant policy initiatives and maintains coherence 
with other EU funds and external support actions.123 

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

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

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

According  to  Member  States,  ISF-funded  operations  considerably  contribute  to  a  high 
level of EU internal security. This is reflected at both Member State and EU level as the 
ISF has contributed to the prevention and combatting of cross-border serious and organised 

117 Articles 19(1)(a)(ii) and 19(3) of the ISF Regulation. 
118 Article 8(2) of the ISF Regulation. 
119 Article 30(2)(c) of the ISF Regulation and Article 29(5) of the ISF Regulation, respectively.   
120 Articles 12(2)(c), 35 41, 42 of Regulation (EU) 2021/947. 
121 Article 5 of Regulation (EU) 2021/947. 
122 Annual Performance Reports and Mid-term Evaluations BE, BG, DE, FR, LT, HR. 
123 Annex V. 

56 

 
 
crime and terrorism, and has reinforced coordination and cooperation between  Member 
States law enforcement authorities, Union bodies, relevant third countries and international 
organisations.  

The ISF achieves EU added value mainly by allowing Member States to mobilise resources 
and  reach  areas  that  would  otherwise  be  left  less  attended  (by  e.g.  enabling  strategic 
projects  and  staff  recruitment).  The  vast  majority  of  Member  States  affirm  that  in  its 
absence, many ISF-funded projects would not have been carried out nationally or would 
have been implemented at a much smaller scale (e.g. with a reduced number of Member 
States involved, or with fewer participants). This is supported by stakeholders who affirm 
that given the current  national  budget  constraints and limitations, projects under shared 
management would have likely been cancelled or significantly weakened if ISF funding 
were interrupted, as ISF-funded projects attract an increased number of participation of EU 
Agencies (DE), enable larger, long-term projects (ES), and support the acquisition of state 
of the art technologies and advanced knowledge (HR). 

Stakeholders  affirm  that  the  ISF  generates  several  benefits  at  EU-level  beyond  those 
Member States could achieve on their own. Benefits at EU-level include exchange of best 
practices, increased operational cross-border cooperation and trust and confidence among 
law enforcement authorities and national authorities across Member States, and broader 
scope for projects (in terms of policy, outreach or focus on issues that would otherwise 
receive less attention). Furthermore, innovative solutions have been developed to address 
internal security threats, e.g. enhanced cooperation and scale effects (DE), expanded IT 
systems  addressing  target  groups  or  introducing  new  types  of  interventions  (LT), 
development of international cooperation through liaison officers in Member States and 
third countries (CZ).  

Fund components under the Thematic Facility  

Emergency Assistance projects contribute to achieving EU added value by fostering 
benefits at the operational level for law enforcement authorities in crisis management, and 
response following attacks or sabotage against critical infrastructure. Despite transnational 
activities and cooperation not being explicitly required for EMAS funding, both EMAS 
projects, the FI-led ‘BalticConnector’ project and and EE-led ‘The investigation of damage 
to  critical  undersea  infrastructure  between  Finland  and  Estonia’  projects  have 
demonstrated  significant  transnational  impacts,  particularly  in  operational  cooperation, 
information exchange and sharing of results. This is evidenced in the transfer of expertise 
gained in the Finnish project to the Estonian project which helped in advancing an effective 
response to undersea cable disruption while leveraging new technologies, such as undersea 
drones. The success of these projects in supporting the repair of undersea cables contribute 
to a positive perception of the EU in supporting effective responses to threats to the critical 
infrastructure of individual Member States.  

Most Member States are overwhelmingly positive about the EU added value achieved 
through  Specific  Actions  projects  which  they  consider  could  not  have  been  achieved 
absent ISF funding.  Specific Actions achieve EU added value due to several reasons. 

Firstly, despite the bulk of the funding being channelled to Union Actions, most Specific 
Actions projects are transnational (i.e., 20 out of 26) and further SO2, which is the Specific 
Objective  which  Member  States’  programmes  least  focus  on.  Furthermore,  Specific 
Actions projects further SO3 as they boost the development of common capabilities, tools 

57 

 
and processes thereby increasing the Union’s capacity to prevent and combat serious and 
organised crime (e.g. drug trafficking, smuggling and human trafficking), cybercrime and 
protection of public spaces. This underlines the views shared by the Commission, Member 
States and beneficiaries that internal security issues are best tackled through transnational 
initiatives. While the Commission sees most added value of Specific Actions’ precisely in 
their transnationality, beneficiaries find them to be a well-suited instrument to respond to 
emerging national priorities. As to national Specific Actions projects, they produce results 
with a high degree of transferability, i.e., they are relevant for and can be used at EU level 
or by other Member States.  

Secondly, Specific Actions act as a form of “pilot projects” for priorities that should be 
developed at Member State programme level. This is exemplified by the ES-led project 
‘Costa del Sol’ involving 12 Member States which was selected under the ISF Specific 
Action EMPACT call. The implementation of this project was so successful that following 
the  mid-term  review,  DG  HOME  listed  that  several  Member  States  should  develop  a 
European  Operational  Team,  along  the  lines  of  Costa  del  Sol,  with  the  presence  of 
investigators from other Member States to carry out joint investigative activities on the 
ground  on  a  long-term  basis,  in  order  to  tackle  the  criminal  groups  operating  across 
Member States. 

Thirdly,  due  to  being  a  relatively  new  funding  mechanism,  Specific  Actions  projects 
enable the participation of a wide range of stakeholders beyond public authorities such as 
the private sector or civil society, thus fostering further synergies at Union level. 

Lastly, while most Specific Actions calls do not place the focus on innovation and best 
practice  transfer,  several  projects  funded  under  the  SA  EMPACT,  SA  PPS  II,  and  SA 
ROLEC  calls,  focus  on  advancing  such  activities.  For  instance,  the  DE-led  ‘LUMEN’ 
project  under  SA  EMPACT  is  in  the  process  of  developing  innovations  in  detecting 
fraudulent call centres where elderly people are targeted and subject to crimes. Specific 
Actions  benefits  include  enhanced  cooperation  through  the  development  of  common 
capabilities, tools and processes increasing the EU’s capacity to detect and address threats 
to  internal  security  in  the  areas  of  drug  trafficking,  smuggling  and  human  trafficking, 
organised crime, protection of public spaces and cybercrime. 

The ISF generates significant EU Added Value through Union Actions, particularly in 
policy areas where the nature of the threats  to  EU internal  security require coordinated 
response  by  all  or  several  Member  States  (preventing  and  combatting  transnational 
organised crime, cybercrime, counterterrorism), or where projects cannot not be financed 
by one national budget, i.e. projects with a transnational dimension.  

For  instance,  the  project  ‘MAOC-N’  (Maritime  Analysis  and  Operations  Centre  – 
Narcotics),  established  in  2007,  has  been  generating  EU  added  value  by  identifying, 
disrupting and dismantling the command and control structures of the higher echelons of 
transnational organised crime focused on drugs trafficking on the Atlantic Ocean and the 
Mediterranean. This projects has a proven record of coordinating the efforts of its partner 
countries124    with  initiatives  of  other  Member  States,  third  countries,  EU  agencies  and 
bodies,  and  international  organisations  in  the  fight  against  drugs  trafficking.  MAOC-N 
coordinated  operations  results  in  seizures  of  drugs  hidden  in  vessels  on  their  way  to 
Europe, and arrest of drug traffickers. In 2023, MAOC-N coordinated operations seized 

124 Belgium, France, Germany, Ireland, Italy, Spain, the Netherlands, Portugal and the United Kingdom. 

58 

 
 
close to 80 tons of cocaine in 49 seizures and facilitated 220 arrest of drug traffickers. All 
8 partner Member States benefit from the successful operations coordinated by the Centre, 
as the seizures of drugs trafficked in vessels reduce the supply of drugs to the European 
markets  and  helps  disrupt  the  activities  of  transnational  criminal  groups,  both  in  the 
countries of origin and in the countries of destination of the drugs.  

Union  Actions  advance  operational  cooperation  between  law  enforcement  authorities, 
cooperation  with  third  countries  and  international  organisations.  It  also  enganges  the 
involvement  of  stakeholders  from  the  private  sector  (e.g.  technology  or  transportation 
companies) and civil society sector (e.g. community organisations, academic institutions) 
involved  in  projects  preventing  and  combating  terrorism,  radicalisation,  cybercrime 
including  child  sexual  abuse  (e.g.,  DISRUPT,  iMONITOR,  Project  BRIDGE,  RAN), 
corruption and to tackling organised crime albeit to a lesser extent (e.g.,@ON network).  

Moreover,  Union  Actions  provide  continuity  both  to  transnational  networks  with  long-
standing  track  records  (e.g.  AIRPOL,  AQUAPOL,  ENFAST,  ENLETS,  ENFSI, 
RAILPOL, @ON Network, AMON, CARIN)  and to  relatively new initiatives (projects 
including  ‘We  Protect  Global  Alliance’  and  ‘European  Anti-Cybercrime  Technology 
Development Association).  

Union Actions beneficiaries agree that without ISF funding it would have been impossible 
to implement their projects in the same scale and timeframe, and that the financial support 
generated  EU  added  value  that  no  Member  State  would  have  achieved  on  its  own. 
Increased coordination between Union Actions projects  and those implemented through 
shared management could generate further EU added value. 

Balance between Member States Actions and Specific Actions under Shared Management 
and Thematic Facility fund components under direct and indirect management  

While most Specific Actions funded projects have focused on transnational cooperation 
and have proven adaptable and complementary to national needs, the 2023-2025 Thematic 
Facility  Work  Programme  foresees  that  future  EMPACT  calls  for  proposals  will  be 
addressed  via  the  Union  Actions  funding  component.  This  is  owing  to  the  success  of 
transnational projects under the Specific Actions EMPACT call, which could benefit from 
larger funding.    

The ISF is found to generate EU added value across all Fund components enabling 
the development of projects and the acquisition of capabilities and knowledge beyond the 
individual capacity of Member States. 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.  

4.3. Is the intervention still relevant?  

To what extent did the ISF address the evolving needs? 

The ISF has largely addressed the needs identified at the time of the beginning of the 
programming period in order to achieve the overall objective of 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. 

59 

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

The  scope,  objectives  and  actions  of  the  ISF  are  sufficiently  broad  to  enable  flexible 
implementation  of activities in  the  internal  security  environment,  effectively  addressing 
the diverse needs of Member States. This was confirmed through the survey analysis and 
in the focus group. 

Member States’ programmes provide information specific to their national internal security 
context (i.e., national strategies, policies, and legislation) and present key needs and trends 
to be addressed with ISF support. The programmes and mapping of needs and trends show 
alignment with ISF’s objectives and with policy priorities identified at EU and Member 
State level125.  

The key current and prospective needs identified in Member States’ programmes cover all 
ISF policy fields and were a consultative process combining both a bottom-up approach 
(consultation with different actors from Managing Authorities to beneficiaries) as well as 
a top-down approach (defining priorities based on strategic documents and concepts).  

Table 2 provides an overview of the Member States’ key needs in the relevant policy fields. 

Table 2 - Overview of key needs indicated in the Member States’ programmes for the ISF 2021-
2027 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

Counter-
terrorism  incl. 
prevention  of 
radicalisation, 
protection 
of 
public  spaces, 
and 
critical 
infrastructure/ 
entities 
X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Cybercrime, 
incl. 
child 
sexual abuse 

Law enforcement 
cooperation 
(cross-border 
operational 
cooperation) 

Information 
exchange 
security 
databases 
systems) 

(IT 

and 

Cooperation 
with 
countries 

third 

Organised  crime, 
incl. 
human, 
firearms, and drug 
trafficking, 
corruption, 
migrant 
smuggling,  money 
laundering 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

125 The priorities identified in the MS’ programmes are also subject to regular assessment through i.a., the 
Schengen  evaluation  and  monitoring  mechanism  (SCHEVAL),  which  ensures  that  priorities  identified  at 
national  level  and  the  use  of  any  ISF  funding  support  the  implementation  of  the  Union  acquis  via 
reprogramming on Member States needs. In this sense, see Council Regulation (EU) 2022/922. 

60 

 
 
 
 
 
 
MS 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SI 

SK 

ES 

SE 

Counter-
terrorism  incl. 
prevention  of 
radicalisation, 
protection 
of 
public  spaces, 
and 
critical 
infrastructure/ 
entities 
X 

X 

X 

X 

X 

X 

X 

X 

X 

Cybercrime, 
incl. 
child 
sexual abuse 

Law enforcement 
cooperation 
(cross-border 
operational 
cooperation) 

Information 
exchange 
security 
databases 
systems) 

(IT 

and 

Cooperation 
with 
countries 

third 

Organised  crime, 
incl. 
human, 
firearms, and drug 
trafficking, 
corruption, 
migrant 
smuggling,  money 
laundering 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Source: Preparatory study on the analysis of Member States’ programmes 

The  policy  areas  which  Member  States  prioritised  are  the  following:  prevention  and 
combatting  organised  crime  and  cybercrime,  to  enhance  cross-border  law  enforcement 
operational cooperation, and exchange of information/IT security databases and systems. 

Overall, Member States’ programmes respond to the national internal security needs. 
Most Member States report their programmes were designed to address evolving needs by 
demonstrating flexibility to the constantly changing conditions and threats.  

The majority of the interviewed stakeholders agree that the ISF is  (throughout the different 
management modes) capacity in addressing current and view being capable of addressing 
current needs and adapting to evolving ones. Nonetheless, three interviewed stakeholders 
suggested that budgetary limitations might constrain Member States’ programmes meeting 
the  key  internal  security  needs  as  contextual  factors  (e.g.  COVID-19  pandemic  and 
invasion of Ukraine) as inflation rates reduce purchasing power and affect the costs of the 
planned  activities  (CZ,  DE,  HU  and  LV).  Moreover,  some  stakeholders  indicate  that 
available resources are insufficient to effectively cover all priorities in the policy fields 
and suggest that to avoid ISF-funding becoming too “diluted”, the Fund’s scope should be 
streamlined to two or three major crime areas (e.g. organised crime and drug trafficking), 
thus ensuring resources are concentrated where they can have the largest impact. 

A  few  stakeholders  in  the  first  focus  group  raised  concerns  on  the  ISF’s  capacity  to 
adequately address needs identified at the beginning of the programming period as these 
priorities  risk  not  fully  reflecting  the  evolving  priorities  such  as  where  technological 
developments,  such  as  Artificial  Intelligence,  are  rapidly  changing.  These  concerns 
appear  to  suggest  low awareness  of  the  flexibility  foreseen  for  the  ISF,  such  as  the 
possibility of amending Member States’ programmes.  

Furthermore,  the  ISF  Regulation  also  foresees  additional  allocations  to  Member 
States’  programmes:  firstly,  through  the  mid-term  review,  which  is  the  occasion  for 
Member  States  to  take  stock  of  the  programme  implementation  and  revise  their  ISF 

61 

 
 
 
 
 
 
 
 
 
 
programmes to address existing and new challenges126. This review allows Member States 
to reprogramme the initial allocations to their programmes in line with emerging priorities, 
as well as to programme the allocations resulting from the mid-term review for the Member 
States that have qualified for additional funding127. Secondly, Member States’ programmes 
may receive additional funding from Specific Actions to contribute to the implementation 
of the objectives of the Fund, including covering newly emerging threats128.  

The Thematic  Facility  Work  Programmes  allows  national  and  EU-wide  priorities  to  be 
addressed efficiently while maintaining high responsiveness to new developments in the 
internal security landscape.  

Some  Member  States  national  mid-term  evaluations  affirm  the  Thematic  Facility 
responds  to  pressing  and  evolving  needs  at  national  and  EU  levels  and  allocated 
resources to be focused on high-value actions. The Fund’s capacity to respond to current 
and  emergency  needs  is  underlined  in  both Thematic  Facility Work  Programmes  as  for 
instance EU-wide open calls for proposals for transnational actions that acknowledge the 
changes in organised crime groups’ activities and evolving internal security needs (e.g. the 
development of skills and capacity for digital investigations and digital forensics, detection 
of child sexual abuse online, or implementation of the new legislation on the resilience of 
critical entities). Furthermore, the Thematic Facility Work Programme 2023-2025 foresees 
a Specific Action on Artificial Intelligence for law enforcement. This call has the aim to 
provide  financial  support  to  Member  States  to  facilitate  the  adoption  (i.e.  testing, 
validating,  further  piloting  and/or  deploying)  of  trustworthy,  ethical  and  transparent 
Artificial Intelligence  technologies and tools by law enforcement authorities for modern 
and  efficient  policing  to  prevent  and  combat  serious  and  organised  crime,  including 
terrorism. 

Nonetheless,  at  times,  dynamic  policy  developments  could  not  be  fully  met  with  ISF 
funding due to  the limitations on the use of that funding, as set out in the ISF Regulation. 
For instance, in the EU Protective Security Advisors (PSA) programme, a tool to provide 
Member States with advice on the vulnerability of public spaces and critical infrastructure, 
only costs related to the participation of Member States’ experts can be financed under the 
ISF. A further example concerns a project on training and handling over of demining dogs 
to the Ukrainian handlers, where not all costs (namely the purchase of dogs) were found 
to be eligible.   

Specific  Actions  beneficiaries  have  emphasised  the  complementarity  of  Specific 
Actions  with  Member  States’  programmes  and  their  alignment  with  key  national 
needs. These synergies allow Member States to advance their internal security priorities 
while contributing to broader EU internal security objectives. Thus, Specific Actions are a 
versatile  and  effective  tool  to  address  both  national  and  transnational  internal  security 
priorities.  While  most  funded  projects  have  focused  on  transnational  cooperation,  they 
have proven adaptable and complementary to national needs.  

Nonetheless, the administrative burden for large transnational projects under SA EMPACT 
has been deemed too heavy to be efficient; as a result future EMPACT call for proposals 
will be handled via Union Actions. Moreover, launching Specific Actions on take up of 
EU research results has proven to be work intensive as potential beneficiaries tend to either 

126 Recital (36) of the ISF Regulation. 
127 Article 14 of the ISF Regulation.  
128 Article 15(1) of the ISF Regulation.  

62 

 
 
misunderstand  the  ISF’s  scope  (e.g.  public  order  out  of  ISF  scope)  or  the  innovation 
concept as evidenced under the failed first call on Protection of Public Spaces (PPS I).  

Through Union Actions projects, the ISF has played an important and indispensable role 
in  improving  crime  prevention,  preventing  and  fighting  cross-border,  serious  and 
organised crime including terrorism and radicalisation, and have enhanced coordination, 
operational  cooperation  and  the  exchange  of  information  between  law  enforcement 
authorities,  supported  actions  to  strengthen  cooperation  with  third  countries  and 
international organisations and to include actors from the private sector and civil society 
in developing and implementing policies, technologies and skills that ensure a high level 
of  internal  security  in  the  Union.  Union  Actions  are  and  should  remain  the  most 
important – from the policy point of view – fund component. It allows the Commission 
to  steer  Member  States  Actions  and  support  implementation  of  EU  key  priorities. 
Moreover, their transnational nature makes them particularly valuable and indispensable.  

A key point concerns the balance between the share set for shared management and 
for the Thematic Facility in better supporting the ISF address its evolving needs. Even 
prior  to  the  mid-term  review,  there  was  a  larger  share  for  shared  management  than  for 
Union Actions as the current balance is of 74%-26%129. If this trend persists it would imply 
fewer transnational Union Actions grants to support key EU policies, and the upcoming 
EU  acquis  linked  to  the imminent  new  Internal  Security  Strategy  and  Counterterrorism 
Agenda.  This  raises  the  need  of  clearly  earmarking  an  amount  for  transnational  Union 
Actions grants.  

The balance between the share set for shared management and for the Thematic Facility 
represents  a  good  mix  on  tackling  Member  States’  needs  and  capabilities  under  shared 
management and EU key priorities through Union Actions and Specific Actions.  

At the Specific Objective level, Member States’ programmes tend to focus primarily on 
furthering  the  Member  States’  capacity  building  and  information  exchange  as  they 
perceive  SO  1  and  SO3  to  be  more  relevant  to  their  national  needs,  as  compared  to 
advancing SO2 perceived due to practical challenges in funding cross-border cooperation 
projects as they are perceived as more difficult or complex. In turn, under the Thematic 
Facility, Specific Actions mainly furthers cross-border cooperation (SO2), which will also 
be  further  by  Union  Actions  as  the  Thematic  Facility  Work  Programme  sets  out  that 
EMPACT projects will be funded through this fund component.  

The  level  of  complementarity  is  also  demonstrated  at  policy  level,  Member  States’s 
programmes focus primarily on information exchnage, whereas this policy field receives 
the least focus under the Tematic Facility.  

For  instance,  some  Member  States  take  advantage  of  the  complementarity  of  the  ISF 
different fund components to ensure sustainability of their project, e.g. for the EOT Costa 
del  Sol  project,  national  funding  is  used  to  extend  the  deployment  of  Member  States 
officers  and  a  Union  Action  grant  is  funding  an  EOT  support  unit.  Differently,  HR  is 
financing  the  running  costs  (fuel  for  24/7  mobile  teams)  for  their  law  enforcement 
authorities  participating  in  the  SA  EMPACT  project  on  migrant  smuggling  from  the 
Specific Actions allocation, not other sources of the ISF programme. This increases the 

129 Articles 7(2) and 8 of the ISF Regulation.  

63 

 
 
effectiveness of the operating support, which finances activities that are carried out on a 
regular basis within the scope of ISF (e.g. maintenance of dedicated IT systems). 

EMPACT funding is the best example of combining different resources from different fund 
components  (and  from  Europol).  Nonetheless,  beneficiaries  of  EMPACT  EU  funding 
indicate they would highly benefit from having one single funding tool to support their 
EMPACT activities.    

Lastly, under the Thematic Facility, Emergency Assistance supports rapid solutions to 
address  security-related  incidents  or  emerging  threats  with  sufficient  flexibility  to 
channel  financial  resources  promptly  to  where  they  are  most  needed,  avoiding 
unnecessary  delays.  EMAS  responds  to  emergency  national  needs  thus  meeting  the 
objectives it was set up for while not being limited to predetermined needs. 

To what extent can the ISF adapt to the evolving needs? 

The ISF has been able to adapt successfully to new and pressing needs that have been 
often caused by external factors and events such as Russia’s invasion of Ukraine in 2022 
and  the  resulting  increased  internal  security  threats  e.g.,  firearms  and  drug  trafficking, 
trafficking in human beings and migrant smuggling. Furthermore,  evolving threats, such 
as the sabotage of critical infrastructure and cyberattacks, can cause substantial economic 
damage,  and  undermine  public  security.  The  level  of  terrorist  threat  on  European  soil 
remains high. The threat to stability from organised crime continues to intensify, with the 
move online of much commerce and human interaction opening new avenues for criminal 
activity.  

Member  States  are  able  to  design  and  adapt  their  programmes  flexibly  based  on 
changes  in  national  needs  due  to  mechanisms  put  in  place,  such  as  the  possibility  of 
making  non-substantial  changes  to  a  Member  States’  programme  which  can  be 
implemented  rather  quickly  and  straightforwardly,  whereas  more  substantial  changes 
necessitate a programme amendment with Monitoring Committee approval (followed by 
the Commission’s approval)130. The most common approach for identifying needs is the 
Member  States’s  use  of  broad  consultation  processes  involving  relevant  authorities, 
project beneficiaries and policy dialogues (AT, ES, FR, HU, IT, PL, SE, LT). 

The ISF has a strong focus on the disruption of organised criminal networks which have 
been increasingly expanding in the past decade. Some Member States highlight increased 
needs in some policy fields related to fighting organised crime (e.g. drug trafficking and 
migrant smuggling) and cybercrime (including fighting child sexual abuse). This is notable 
in SO2 and SO3 which centre on improving cross-border cooperation, and the fight against 
terrorism  and  radicalisation,  and  serious  and  organised  crime.  The  European 
Commission’s Programming Fiches show that the ISF allows for flexibility in adapting to 
the different policy fields and thematic needs under its Specific Objectives. This is also 
due to the possibility of transferring allocations both between types of actions under the 
same  Specific  Objective  and  between  the  different  ISF  Specific  Objectives.  However, 
some Member States stated that the process of shifting priorities is bureaucratic and slows 
down the implementation of the changes in the transfer of Funds.  

The  Thematic  Facility  allows  for  a  more  flexible  response  to  changing  needs  and 
sudden changes in internal security through its components. Moreover, it entails the 

130 See Article 40(2) of the CPR.  

64 

 
 
possibility to make non-substantial amendments to the allocation of funds between actions 
under  direct  management  (i.e.,  grants  and  procurement),  indirect  management,  shared 
management (Specific Actions), and other actions or expenditure.131   

5. WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1. Conclusions 

Given  the  early  stage  of  implementation  of  the  Member  States’  programmes,  the 
Evaluation  is  particularly  focused  on  the  identification  of  issues  which  may  affect  the 
implementation of the ISF, and on ways to redress the programmes, if necessary. While 
addressing the main evaluation criteria of effectiveness, efficiency, coherence, EU added 
value  and  relevance,  the  evaluation  aims  less  at  obtaining  final  conclusions  on  the 
effectiveness  and  efficiency  of  the  programmes,  than  at  obtaining  evidence-based 
information on:  

•  whether the Fund 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. 

This section aims at summarising the conclusions regarding these three questions. 

Effectiveness 

At difference speeds, the interventions funded are on track and progress is observed 
with varying rates between Specific Objectives and Member States. 

Concerning financial progress, by 30 June 2024, ca. 57% of the allocated resources (ca. 
EUR 834 million) were neither committed nor spent indicating delayed financial progress.  

At fund 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 and results indicators, 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% of 
output indicators milestones have been achieved.  

In shared management, SO2 demonstrates good progress, however it is partially driven by 
overachievements in two Member States (Spain and Sweden). Progress for SO1 and SO3 

131 Annex to Commission Implementing Decision of 26.11.2021 C(2021) 8460 final.  

65 

 
 
is slower. Challenges that have impacted implementation progress include long national 
bureaucratic processes, extended preparatory (both the programming and the awarding of 
projects)  phases,  challenges  in  coordination  with  relevant  bodies  and  inter-institutional 
communication, and national administrative capacity. 

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

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

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

monitoring and reporting system. 

•  There  is  room  for  improving  the  understanding  of  the  components  of  the 

monitoring system. 

•  Annual Performance Reports miss the aim of efficiently sharing key messages on 

practical implementation. 

Union Actions  have  significantly  and  primarily  advanced  SO3.  The  two  policy  fields 
receiving the largest share of the funding for grants are Cybercrime (including the fight 
against online child sexual abuse) and Counterterrorism.  

Specific Actions have prioritised strengthening cross-border law enforcement cooperation 
and  strengthening  measures  to  combat  and  prevent  serious  and  organised  crime  and 
terrorism  (SO2  and  SO3).  Delays  in  Specific  Action  projects  have  been  observed, 
primarily due to complexity of the projects, national legal requirements and problems with 
national administrative capacity. 

The use of electronic data management systems  is  viewed as positive, however, not  all 
Member  States  have  finished  developing  the  system  to  connect  beneficiaries  with 
programme authorities. In comparison to the 2014-2020 programming period, the Member 
States target  setting  methodology  was enhanced, however there were some struggles in 
defining indicators and differences in describing target setting.   

Monitoring Committees have played an important role in the implementation, monitoring 
and evaluation of the Member State programmes; however, it was challenging to ensure a 
balanced representation of relevant stakeholders from civil society and private partners on 
the Monitoring Committee. 

Member States established organisational procedural arrangements to ensure compliance 
with  the  horizontal  principles.  Managing  Authorities  and  beneficiaries  were  found  to 
respect the respective laws and principles, however a more active approach to uploading 
the horizontal principles could be taken. 

Finally, Member States have communicated their activities via a variety of channels and at 
EU level, information is provided on funding opportunities and achievements under the 

66 

 
ISF.  Nonetheless,  some  stakeholders  found  balancing  confidentiality  with  public 
awareness challenging.  

Efficiency  

As the information on performance is still insufficient, it is too early  to carry out a 
full  cost-effectiveness  analysis.  Nonetheless,  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).   

Many  Member  States  have  implemented  cost-effective  measures  and  streamlined 
administrative  procedures.  For  example,  some  Member  States  have  taken  advantage  of 
simplified cost options to enhance efficiency. Nonetheless, challenges linked to extensive 
reporting, challenging payment processes and significant staff commitments for complex 
projects remain. 

Overall, the ISF management and control systems were found to function in line with the 
CPR, with many Member States reporting efficient management systems. Some Member 
states reported that the inclusion of ISF under the CPR generated administrative burden 
due to increased reporting obligations. However, other Member States’ established systems 
allow for the pooling of financial and management resources for all Home Affairs Funds, 
thereby  reducing  administrative  burden  and  gaining  access  to  additional  training  and 
exchange of experiences thus enhancing staff efficiency. 

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

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

and 

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

reduced with time. 

The perception of increased reporting and administrative burden may be influenced by the 
fact that the obligations are new as compared to the previous programming period and the 
introduction of a new framework requires an adaptation period and some learning on the 
side of the Managing Authorities. 

Relevance 

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

All consulted stakeholders agree that the 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).  

67 

 
Member States report that the interventions supported by the ISF address both structural 
long-term and emergency needs. The ISF foresees additional allocations to Member States’ 
programmes  through  the  mid-term  review  of  the  programmes  and  through  Specific 
Actions. Despite these  features,  some stakeholders suggested that budgetary limitations 
might constrain Member States’ programmes meeting the key internal security needs as 
contextual  factors  (e.g.  COVID-19  pandemic  and  Russian  war  against  Ukraine)  affect 
inflation  rates  thus  affecting  the  costs  of  the  planned  activities.  Moreover,  some 
stakeholders  indicate  that  available  resources  are  insufficient  to  effectively  cover  all 
priorities in the policy fields and suggest the Fund’s scope should be streamlined to two or 
three major crime areas, thus ensuring resources are concentrated where they can have the 
largest impact. 

A key point concerns the balance between the share set for shared management and for the 
Thematic Facility in better supporting the ISF addresses its evolving needs. Even prior to 
the  mid-term  review,  there  was  a  larger  share  for  shared  management  than  for  Union 
Actions. There has been two flows of funding out of the Thematic Facility which has de 
facto reduced the envelope available between 2021-2025 for Union Actions grants. If this 
trend persists, it will result in fewer transnational Union Actions grants to support key EU 
policies and the upcoming EU acquis. This raises the need of clearly earmarking an amount 
for transnational Union Actions grants.  

The ISF is adaptive to changing needs, often in response to external factors and events. 
The balance between the different fund components represents a good mix in addressing 
the Member States’ needs and capabilities under shared management and EU key priorities 
through  Union  Actions  and  Specific  Actions.  Member  States  are  able  to  adapt  their 
programmes  for  their  changing  needs  and  the  Thematic  Facility  allows  flexibility  and 
ensures the highest EU added value and the best response to evolving needs. While the ISF 
is adaptable overall, it has its legal limitations, as for instance, it is not able to finance all 
costs of certain projects. Such examples include the financing of the EU Protective Security 
Advisors programme, and the purchase of demining dogs.  

Coherence  

The Member States’ programmes and the Commission Work Programmes for the 
Thematic  Facility  are  fit  for  purpose  and  coherent  with  other  national  and  EU 
funding instruments.  

The  ISF’s  architecture  is  fit  for  purpose  as  it  enhances  internal  coherence  by  fostering 
complementarity  across  components.  The  combination  of  the  four  fund  components 
(Member States programmes and Thematic Facility’s components, i.e. Specific Actions, 
Union  Actions  and  Emergency  Assistance)  and  the  three  management  modes  (shared, 
direct and indirect) enables flexible fund management.    

Nonetheless, the complementarity between Union Actions and Member State programmes 
seems  to  be  limited  due  to  limited  awareness  and  knowledge  of  the  other’s  respective 
projects.  

In its external coherence, most Member States reported that the ISF is coherent with other 
Home Affairs Funds and have explicitly reported implementing coordination mechanisms 
to ensure synergies and avoid overlaps. Most beneficiaries of Union Actions and Member 
States’ programmes indicated that actions organised by the AMIF and BMVI complement 
to a large extent ISF-funded initiatives  

68 

 
Overall, there is evidence of coherence between the ISF and other EU Funds. Virtually all 
Member States’ programmes are coherent  and demonstrate complementarity of the  ISF 
with  other  EU  Funds  (e.g.  Horizon  Europe,  ESF+  and  the  Justice  Programme).  Under 
direct  and  indirect  management,  Union  Actions  have  been  complementary  to  other  EU 
funding  opportunities  (e.g.  Horizon  Europe,  BMVI),  while  Specific  Actions  also  are 
complementary  with  other  EU  funding  mechanisms,  such  as  Horizon  2020  (Horizon 
Europe’s predecessor). Complementarity is also prioritised by the Commission as a result 
of the launching of the PPS II call in which two projects financed under this call build on 
Horizon 2020 projects. 

As  far  as  coherence  with  external  spending  programmes  and  notably  the  NDICI  is 
concerned,  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  in  the  next  MFF,  including 
notably: the NDICI’s limitations for funding security-related actions, given that most of 
NDICI  spending  must  comply  with  the  criteria  for  official  development  assistance  
eligibility132; the need to further strengthen the link between internal and external priorities 
in the Union’s external security funding; and 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. 

EU Added Value 

The ISF’s EU added value lies in its ability to support projects that go beyond the 
financial and operational capacities of individual Member States.  

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

The  ISF  increased  the  range  of  stakeholders  involved,  introduced  new  types  of 
stakeholders, and increased the number of participants in projects.  

Most  Member  States  are  positive  about  the  EU  added  value  achieved  through  Specific 
Actions projects which they consider could not have been achieved in the absence of ISF 
funding. Most Specific Actions projects being implemented are transnational and improve 
cooperation  between  Member  States  as  well  as  boosts  the  development  of  common 
capabilities, tools and processes thereby increasing the Union’s capacity to prevent  and 
combat serious and organised crime. This underlines the views shared by the Commission, 
Member  States  and  beneficiaries  that  internal  security  issues  are  best  tackled  through 
transnational initiatives. While the Commission sees most added value of Specific Actions’ 
precisely in their transnationality, beneficiaries find them to be a well-suited instrument to 
respond to emerging national priorities. 

The  ISF  generates  significant  EU  Added  Value  through  Union  Actions,  particularly  in 
policy areas where the nature of the threats  to  EU internal  security require coordinated 
response by all or several Member States  or where projects cannot not be financed by one 

132  The  official  development  assistance  eligibility  criteria  is  set  by  the  Organisation  for  Economic 

Cooperation and Development. 

69 

 
 
 
national  budget,  i.e.  projects  with  a  transnational  dimension.  Union  Actions  advance 
operational  cooperation  between  law  enforcement  authorities,  cooperation  with  third 
countries and international organisations, as well stakeholders from the private sector (e.g. 
technology or transportation companies) and civil society sector. 

The ISF is found to generate EU added value across all Fund components  enabling the 
development  of  projects  and  the  acquisition  of  capabilities  and  knowledge  beyond  the 
individual capacity of Member States. 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.  

5.2. Lessons learned 

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

The ISF is found to generate EU added value across all Fund components, enabling the 
development of projects and the acquisition of capabilities and knowledge beyond Member 
States’ individual capacity. Notably, transferability and transnationality are features of the 
ISF  that  bring  the  highest  added  value,  and  these  are  most  expressed  through  Union 
Actions. This should be considered in future programming. 

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 prioritising the most 
relevant interventions. 

To make the most of the relevance of ISF, it would be important to further reinforce the 
complementarity  and  coherence  between  its  different  components,  creating  the  right 
instruments  for  coordination  at  EU  level,  but  especially  at  Member  State  level. 
Additionally,  innovative  methods  and  approaches  developed  through  Union  Actions 
should continue to be promoted by the Commission to make sure that Member States and 
stakeholders are aware and take advantage of these innovative approaches.  

Actions in direct management are generally seen as more efficient and less administratively 
burdensome,  which  can  have  implications  for  the  design  and  implementation  of  future 
programmes. For this reason, the 2023-2025 Thematic Facility Work Programme foresees 
that future EMPACT call for proposals will be addressed via the Union Actions funding 
component.  

In  terms  of  implementation  progress,  the  ISF  has  achieved  operational  progress  in  the 
implementation of SO3 and SO1. It is important that the implementation of SO2 does not 
lag behind. 

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

70 

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

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

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

Concerning  the  established  indicators,  some  Member  States  suggest  that  while  key 
performance  indicators  provide  a  measurable  framework,  they  may  not  always 
accommodate  the  diverse  roles  and  contributions  necessary  for  comprehensive  project 
success. This could increase the challenge to adequately evaluate ISF achievements.  

Finally, while the Member States adhere to the current participative processes as dictated 
by the partnership principle, some struggle to actively involve all relevant stakeholders. 
This is particularly prominent when it comes to the engagement of civil society actors in 
ISF priority areas such as organised crime, drug trafficking, and firearms trafficking, where 
civil society organisations might be less active. Moreover, Managing Authorities may be 
reluctant to share classified information during participatory dialogues, limiting thereby 
their usefulness. However, the necessity of holding a participatory dialogue during both 
programming and implementation remains unquestioned. 

71 

 
 
ANNEX I.  PROCEDURAL INFORMATION 

This evaluation has been carried out by DG HOME, as responsible for the implementation 
of ISF in the Commission.  

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

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

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

The  first  meeting  of  the  Interservice  Group  was  held  on  30  June  2023.The  meeting 
discussed the Specifications for the preparatory study to be carried out with the assistance 
of external consultants. Additional meetings of the Interservice group took place to discuss 
the deliverables of the preparatory study on 29 February 2024, 26 April 2024, 22 July 2024 
and 15 November 2024. The draft version of this Staff Working Document was submitted 
to the group in written consultation on 16 January 2025. 

The  preparatory  study  was  confided  to  a  consortium  made  up  of  ECORYS,  Rand, 
Wavestone and the Centre for the Studies of Democracy following an open call for tender 
launched on 3 October 2023. The contract was signed on 27 February 2024. 

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

Opinion of the Regulatory Scrutiny Board  

The draft Staff Working Document has been submitted to the Regulatory Scrutiny Board 
(RSB) on 5 February 2025 for scrutiny at the hearing of 5 March 2025.  

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

The RSB identified the following key issues: 

73 

 
 
 
(1)  The  intervention  logic  should  be  presented  and  discussed  in  the  main  report.  It  is 
unclear  and  does  not  explain  how  the  intervention  was  expected  to  work.  It  mixes 
indicators  with  expected  outputs  and  results,  lacks  clarity  on  how  Annex  II 
(implementation  measures)  of  the  Regulation  is  reflected  in  the  outputs,  and  does  not 
discuss how progress on reaching the specific objectives was meant to be assessed.  

(2)  The  report  should  be  clear  about  the  points  of  comparison  and  describe  also  in 
quantitative terms how progress towards attaining objectives is measured and against what 
point of comparison. The mid-term evaluation should take into account the results of the 
retrospective evaluation of the ISF-P under the previous programming period or explain 
upfront why this has not been done. It should explain why the majority of Member States 
have not reported on some objectives and better use available data to analyse the Fund's 
effectiveness and efficiency at this stage.  

(3) The report should more systematically refer to the existing evidence base and bring in 
more  elements  from  the  supporting  study  and  case  studies.  Reporting  on  progress  in 
financial implementation is not sufficient as evidence of effectiveness and efficiency, or 
as  a  basis  for  concluding  that  the  programme  is  on  track  to  achieve  its  objectives. 
Milestones and targets related to outputs and results should be clearly summarised in the 
report,  and  existing  data  on  such  achievements  should  be  systematically  reported.  The 
conclusions should be more nuanced and better aligned with the evidence available and its 
limitations. Statements not supported by evidence should be omitted.  

(4)  The  report  should  further  elaborate  on  the  monitoring  and  evaluation  framework  in 
place and assess the extent to which the data collected will allow to track progress on all 
elements of the intervention logic including on specific objectives. It should be explicit 
about data and information that Member States provide in their regular reporting, identify 
and analyse any issues such as inconsistencies, unnecessary reporting burden or gaps that 
would need to be addressed. The lessons learned should include potential changes to the 
reporting system and the established indicators in order to ensure the effective assessment 
of the Fund’s achievements in the retrospective evaluation.  

(5)  The  report  should  analyse  to  what  extent  different  stakeholders'  perceptions  of 
complexity  and  cumbersome  reporting  are  representative  and  reliable.  Administrative 
costs and potential for improvement, simplification and burden reduction should be better 
analysed for both shared management programmes and Thematic Facility.  

(6)  Statements  on  external  coherence  with  other  EU  funds  should  be  thoroughly 
substantiated.  Internal  coherence  across  different  management  modes  should  be  better 
assessed based on thorough analysis of complementarities of implemented operations. The 
analysis  should  allow  for  making  conclusions  on  the  current  mix  of  shared,  direct  and 
indirect management modes.  

(7) The report should better demonstrate continuous relevance and Union added value. It 
should analyse how the Fund addresses needs based on a comparative analysis of identified 
needs  and  focus  of  the  programme  and  the  content  of  operations.  It  should  identify 
evolving ones by incorporating relevant foresight analysis. As regards the Union added 
value, the report should better explain and provide supporting evidence on the effects of 
investments by the Fund, as opposed to other national investments in the same area and 
analyse any data gaps which could hamper the analysis of additionality in the retrospective 
evaluation 

74 

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

RSB comment 
(1)  The  intervention  logic  should  be 
presented  and  discussed  in  the  main 
report.  It  is  unclear  and  does  not 
explain  how  the  intervention  was 
expected to work 

Follow-up 
Under  Section  2.2.  (Intervention  Logic)  of  the 
revised version, the presentation of the intervention 
logic  in  the  SWD  was  adjusted  so  that  the  links 
between the ISF’s needs, activities, outputs, results 
and the expected intermediate effects leading to the 
achievement  of  the  objectives  of  the  Fund  were 
more explicitly presented.  

Furthermore,  under  Section  2.3. 
(Points  of 
Comparison),  the  importance  of  the  regulatory 
framework  to  the  ISF’s  performance  framework 
was  added  thus  underscoring  that  the  CPR’s 
framework 
emphasis 
methodologies strengthens the intervention logic. 

the  performance 

on 

II 
the  Regulation 

(1) It mixes indicators with expected 
outputs  and  results,  lacks  clarity  on 
(implementation 
how  Annex 
measures)  of 
is 
reflected in the outputs, and does not 
discuss how progress on reaching the 
specific  objectives  was  meant  to  be 
assessed 

in  quantitative 

(2)  The  report  should  be  clear  about 
the points of comparison and describe 
also 
terms  how 
progress towards attaining objectives 
is measured and against what point of 
comparison.  

(2)  The  mid-term  evaluation  should 
take  into  account  the  results  of  the 
retrospective evaluation of the ISF-P 
the  previous  programming 
under 
period or explain upfront why this has 
not been done.  

Section  2.2.  (Intervention  Logic)  of  the  revised 
version,  better  explains  on  how  Annex  II  of  the 
Regulation is reflected in the outputs and on how 
progress in reaching the Specific Objectives it to be 
assessed. 

Additional  information  has  been  provided  under 
Section  2.3.  (Points  of  comparison)  on 
the  
performance  framework  to  allow  monitoring  and 
evaluating of programme performance and how it 
measure progress. 

This is also clarified and expanded under  Section 
4.1.1. (Efficiency). 

As explained in the revised version in Section 2.3. 
(Points  of  Comparison),  even  if  the  mid-term 
evaluation  focuses  mostly  on 
the  situation, 
achievements  and  progress  during  the  initial 
implementation  of  ISF,  the  evaluation  of  the 
previous  programming  period  might  have  been  a 
useful input in terms of comparison.  

As a response to the Russian war of aggression to 
Ukraine,  the  implementation  period  of  the  Home 
Affairs  Funds  2014-2020  was  extended  by  one 
year, to allow the Member States to fully use any 
2014-2020 
unspent 
under 
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 

amounts 

the 

the 

75 

 
 
RSB comment 

(2) It should explain why the majority 
of  Member  States  have  not  reported 
on  some  objectives  and  better  use 
available  data  to  analyse  the  Fund's 
effectiveness  and  efficiency  at  this 
stage. 

report 

(3)  The 
should  more 
systematically  refer  to  the  existing 
evidence  base  and  bring  in  more 
elements from the support study and 
case studies. 

(3) Reporting on progress in financial 
implementation  is  not  sufficient  as 
and 
evidence 
efficiency,  or  as  a  basis 
for 
concluding that the programme is on 
track to achieve its objectives 

effectiveness 

of 

Follow-up 
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  Section  1,  both  the 
the  ex-post  evaluations  were 
mid-term  and 
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  ISF 
Regulation  to  take  into  account  the  results  of  the 
retrospective evaluation for the 2014-2020 period.” 

This has been addressed in the revised version of  
Section 4.1.1. (Effectiveness). 

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

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. This assumption was acknowledged and 
agreed with the ISG at the start of the preparatory 
work of the 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 
being implemented efficiently from an operational 
point of view.  

76 

 
 
RSB comment 
(3)  Milestones  and  targets  related  to 
outputs and results should be clearly 
summarised in the report, and existing 
data on such achievements should be 
systematically reported 

(3)  The  conclusions  should  be  more 
nuanced  and  better  aligned  with  the 
evidence available and its limitations. 

(3)  Statements  not  supported  by 
evidence should be omitted. 

report 

should 

further 
(4)  The 
elaborate  on 
the  monitoring  and 
evaluation  framework  in  place  and 
assess  the  extent  to  which  the  data 
collected will allow to track progress 
on  all  elements  of  the  intervention 
logic including on specific objectives. 
It  should  be  explicit  about  data  and 
information 
that  Member  States 
provide  in  their  regular  reporting, 
identify  and  analyse  any  issues  such 
unnecessary 
as 
reporting  burden  or  gaps  that  would 
need to be addressed 

inconsistencies, 

to 

learned  should 
lessons 
(4)  The 
include  potential  changes 
the 
reporting  system  and  the  established 
indicators  in  order  to  ensure  the 
effective  assessment  of  the  Fund’s 
achievements 
the  retrospective 
evaluation. 

in 

different 

(5) The report should analyse to what 
stakeholders' 
extent 
and 
perceptions  of 
are 
cumbersome 
representative and reliable 

complexity 
reporting 

(5) Administrative costs and potential 
for  improvement,  simplification  and 
burden  reduction  should  be  better 
analysed for both shared management 
programmes and Thematic Facility. 

(6) Statements on external coherence 
with  other  EU  funds  should  be 
thoroughly substantiated. 

Follow-up 
This  has  been  explained  in  the  revised  version 
under Section 2.3 (Points of Comparison). 

This has been applied throughout the report.  

This has been applied throughout the report.  

This has been reinforced in Sections 2.3 (Points of 
Comparison),  3.3  (ISF  Implementation:  Financial 
Progress), 4.1.1. (Effectiveness) and 5.2. (Lessons 
learned) 

Section 4.1.1. (Effectiveness) of the revised version 
provides examples of possible indicators of a more 
qualitative  nature,  which  are  not  presented  in 
Annex VIII, but could be considered in the ex-post 
evaluation of the ISF.  

This has been reinforced throughout the report.  

This aspect has been reinforced in Section 4.1.2 
(Efficiency). 

the 

thoroughly 

In 
revised  Section  4.1.3. 
(Coherence), the statements on external coherence 
with  other  EU  funds  have  been  expanded  and 
includes information on how the ISF interventions 
are coherent with other external interventions, i.e., 

77 

 
RSB comment 

(6) Internal coherence across different 
management  modes  should  be  better 
assessed  based  on  thorough  analysis 
of complementarities of implemented 
operations. 

(6)  The  analysis  should  allow  for 
making  conclusions  on  the  current 
mix  of  shared,  direct  and  indirect 
management modes  

report 

should  better 
(7)  The 
demonstrate  continuous 
relevance 
and  Union  added  value.  It  should 
analyse  how  the  Fund  addresses 
needs  based  on  a  comparative 
analysis of identified needs and focus 
of the programme and the content of 
operations. 

(7) It should identify evolving ones by 
foresight 
incorporating 
analysis.  

relevant 

(7) As regards the Union added value, 
the  report  should  better  explain  and 
provide  supporting  evidence  on  the 
effects of investments by the Fund, as 
opposed to other national investments 
in the same area and analyse any data 
gaps which could hamper the analysis 
of  additionality  in  the  retrospective 
evaluation 

Follow-up 
national  policies  in  the  field  of  security,  other 
Home  Affairs  Funds,  other  EU  funds  in  other 
policy areas and concerning the EU external policy. 

In the revised Section 4.1.3. (Coherence), the part 
on  internal  coherence  has  been  clarified  and 
expanded. It now includes information on how the 
four different components of the ISF work together, 
how  this  coherence  is  meant  to  work,  and  on  the 
extent  to  which  the  objectives  of  ISF  are  in  line 
with  the  objectives  of  the  EU  internal  security 
policy.  

This  aspect  has  been  reinforced  in  Section  4.3. 
(Relevance) 

This aspect has been reinforced in Sections 4.2 (EU 
Added Value) and 4.3. (Relevance) 

This  aspect  has  been  reinforced  in  Section  4.3. 
(Relevance) 

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

this  analysis 

to  deepen 

in 

78 

 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

This Annex presents the methodology employed for the Evaluation of the ISF 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, a literature review, scoping interviews, stakeholder mapping, 
developing an intervention logic, and the refinement of the methodological approach to be 
used. The 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 following phase focused on gathering data 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 focus was on collecting the remaining data necessary for the 
study as well as answering the evaluation questions. This included obtaining quantitative 
and qualitative data from SFC2021 and creating an overview of costs and benefits. The 
data was then triangulated to develop replies to each evaluation question.  

In  the  final  phase,  the  findings  were  synthesised,  a  synopsis  covering  the  consultation 
activities was drafted, and the study team followed up for clarifications where necessary . 
Furthermore, the second EU level focus group was held to validate the evaluation findings 
and  develop  lessons  learned.  The  contractors  delivered  a  draft  final  report  that  was 
discussed in a meeting with the Steering Group.  

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

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

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

Regarding  the  consultation  activities,  EU  level  interviews  were  conducted  with  the 
officials from DG HOME units D1, D2, E1, E2, E3, E4. The interviews included scoping 
interviews  and  semi-structured  interviews  to  gather  data  for  the  analysis,  including  the 
country case studies and thematic case studies. Further interviews were conducted for the 
case studies including with national authorities and beneficiaries.  

79 

 
Two EU level focus groups were held during the study. The first EU level focus group 
was  held  in  person  on  the  25  June  2024.  The  focus  group  consisted  of  Managing 
Authorities  and  project  beneficiaries,  for  a  total  of  50-60  participants.  After  a  plenary 
session the participants were divided into six break-out groups to facilitate more targeted 
discussions. The aim of the focus group was to collect views on whether and how well the 
ISF is addressing needs while also supporting activities that generate EU added value.  

The second focus group was held on 20 November 20214 and included participants from 
the  European  Commission,  EU  agencies,  relevant  national  authorities,  select  experts 
related to the policy fields covered by ISF, and beneficiaries of EMAS, Specific Actions 
and Union Actions. The objective of the focus group was to validate the evaluation findings 
and further develop the lessons learned.  

In  addition  to  the  focus  groups,  two  targeted  surveys  were  launched  to  target  various 
stakeholders  (one  for  Member  State  authorities  and  another  for  beneficiaries  of  Union 
Actions and the Member States’ programmes). The results of the survey fed into the main 
analysis.  

The study included five country case studies (NL, ES, DE, HR and LV) to dive deeper 
into the implementation of the ISF to identify challenges encountered, specific processes, 
and best practices. The study also included four thematic case studies on Union Actions, 
EMAS, Specific Actions, and the contribution to horizontal priorities. The thematic case 
studies allowed for deep-dives into certain aspects of the instrument and specific topics by 
reviewing specific projects.  

Limitations and mitigation measures 

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

Inconsistent data quality and availability across Member States hindered comparisons. The 
reduced  availability  of  data  was  partially  due  to  the  early  implementation  stage  of  ISF 
programmes of Member States; most Member States’ programmes (19) were approved in 
Q4/2022,  only  roughly  a  year  and  a  half  before  the  cut-off  date  of  the  ISF  mid-term 
evaluation. Consequently, there is no comprehensive analysis of the situation at national 
level, nor a description of the challenges which may have affected the overall achievements 
of the objectives of the ISF. 

The  Member  State  mid-term  evaluations  and  target  setting  methodologies  displayed 
varying  levels  of  quality  and  depth.  Similarly,  the  Annual  Performance  Reports 
demonstrated varying levels of completeness and consistency.  

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. Where data was deemed to be unreliable, it was 
omitted. 

Due  to  conceptual  issues  with  certain  common  output  and  result  ISF  indicators  it  was 
difficult  to  accurately  measure  the  ISF  programmes’  progress  achieved  so  far.  Limited 
institutional memory owing to staff changes within the Managing Authorities may have 
led to the ommission of some information.   

80 

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

Output and result indicators defined in Annex VIII of the ISF Regulation. 

Specific Objective set out in point (a) of Article 3(2) (SO1)  

Output indicators (O.1) 

1. Number of participants in training activities  

2. Number of expert meetings/workshops/ study visits  

3. Number of ICT systems set up/adapted/ maintained  

4. Number of equipment items purchased  

Result indicators (R.1)  

5. Number of ICT systems made interoperable in the Member States/with securityrelevant 
EU and decentralised information systems/with international databases  

6. Number of administrative units that have set up new, or adapted existing, information 
exchange mechanisms/procedures/tools/ guidance for exchange of information with other 
Member  States/Union  bodies,  offices  or  agencies/third  countries/international 
organisations  

7. Number of participants who consider the training useful for their work  

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

Specific Objective set out in point (b) of Article 3(2) (SO2)  

Output indicators (O.2.) 

1. Number of cross-border operations, separately specifying:  

1.1. the number of joint investigation teams  

1.2. the number of EU policy cycle/EMPACT operational actions  

2. Number of expert meetings/workshops/ study visits/common exercises  

3. Number of equipment items purchased  

4. Number of transport means purchased for cross-border operations 

Result indicators (R.2)  

5. The estimated value of assets frozen in the context of cross-border operations  

81 

 
6.  Quantity  of  illicit  drugs  seized  in  the  context  of  cross-border  operations,  by  type  of 
product 

7. Quantity of weapons seized in the context of cross-border operations, by type of weapon 

8.  Number  of  administrative  units  that  have  developed/adapted  existing  mechanisms/ 
procedures/tools/guidance for cooperation with other Member States/Union bodies, offices 
or agencies/third countries/international organisations  

9. Number of staff involved in cross-border operations  

10. Number of Schengen evaluation recommendations addressed 

Specific Objective set out in point (c) of Article 3(2) (SO3)  

Output indicators (O.3)  

1. Number of participants in training activities  

2. Number of exchange programmes/ workshops/study-visits  

3. Number of equipment items purchased  

4. Number of transport means purchased  

5.  Number  of  items  of  infrastructure/  security-relevant  facilities/  tools/  mechanisms 
constructed/ purchased/ upgraded  

6. Number of projects to prevent crime  

7. Number of projects to assist victims of crime  

8. Number of victims of crimes assisted  

Result indicators (R.3) 

9. Number of initiatives developed/ expanded to prevent radicalisation  

10.  Number  of  initiatives  developed/  expanded  to  protect/  support  witnesses  and 
whistleblowers  

11. Number of critical infrastructure/ public spaces with new/ adapted facilities protecting 
against security- related risks  

12. Number of participants who consider the training activity useful for their work  

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

82 

 
ANNEX III. EVALUATION MATRIX 

Effectiveness 

Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

EQ1. To what extent is the fund 

3.1  What  progress  has  been  made 

3.1.1 

Evidence  of  early  progress 

3.1.1 OI 1: Number of participants in training 

- Mapping of allocations (Task 1b) 

on 

track 

to  achieving 

its 

towards  the  achievement  of  the 

towards 

the  achievement  of 

the 

activities (i) 

-  Review  of  methodology  for  target 

objectives? 

expected  results  of  improving  and 

milestone  and 

target  values  as 

3.1.1  OI 

2:  Number 

of 

expert 

setting (Task 1c) 

facilitating 

the 

exchange 

of 

measured by output indicators related 

meetings/workshops/study visits (i) 

-  Synthesis  of  performance    reports 

information  between  and  within 

to  improving  and  facilitating  the 

3.1.1  OI  3:Number  of  ICT  systems  set 

(Task 1d) 

competent  authorities  and  relevant 

exchange  of  information,  provided 

up/adapted/maintained (i) 

- Systematic review of MS evaluations 

Union bodies, offices and agencies 

these  were  correctly  defined  and  in 

3.1.1  OI  4:  Number  of  equipment  items 

(Task 1e) 

and,  where  relevant,  with  third 

line with evolving needs 

purchased (i) 

- Quantitative analysis (Task 1f) 

countries 

and 

international 

3.1.2 

Evidence  of  early  progress 

3.1.1  OI  Union  Actions:  Number  of 

-  Final  project  reporting  (UAs  and 

organisations? 

towards the achievement of the target 

procurements for IT maintenance 

EMAS)  

values  as  measured  by  Result 

3.1.1  OI  Union  Actions:  Number  of  studies, 

- 

Interviews/survey  with  Member 

indicators  related  to  improving  and 

surveys,  evaluations and  impact  assessment 

States  Authorities 

(MA,  DA), 

facilitating 

the 

exchange 

of 

conducted 

beneficiaries, and end-beneficiaries 

information,      provided  these  were 

3.1.1 OI EMAS: Number of grants awarded 

- Case studies (Task 4) 

correctly  defined  and  in  line  with 

3.1.2  RI  1:  Number  of  ICT  systems  made 

- Public consultation (Task 2d) 

evolving needs 

interoperable 

in 

the  Member  States/with 

-  Desk 

research  on 

contextual 

3.1.3 

Stakeholder  perception  on 

security-relevant  EU 

and 

decentralised 

indicators 

Funds contribution to achievement of 

information 

systems/with 

international 

expected results  

databases (i) 

3.1.4 

Contribution 

of 

Fund 

3.1.2 RI 2: Number of administrative units that 

measures 

to 

improving 

and 

have  set  up  new,  or  adapted  existing, 

facilitating 

the 

exchange 

of 

information 

exchange 

mechanisms/ 

information 

procedures/tools/guidance  for  exchange  of 

83 

 
 
 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

3.1.5 

Identification  of 

factors 

information  with  other  Member  States/Union 

hampering 

the 

achievement  of 

bodies, 

offices 

or 

agencies/third 

intended objectives 

countries/international organisations (i) 

3.1.6 

Best  practices  as  identified 

3.1.2  RI  3:  Number  of  participants  who 

in  previous  evaluations  of  the  fund 

consider  the  training  activity  useful  for  their 

are put in place 

work (i/d) 

3.1.7  Evidence  of  early  progress 

3.1.2 RI 4: Number of participants who report 

towards 

the  achievement  of 

the 

three months after the training activity that they 

identified 

expected 

intermediate 

are using the skills and competences acquired 

impacts 

during that training activity (i/d) 

3.1.2 

Participants  who 

believe 

the 

activities contribute 

to 

increasing  mutual 

trust between authorities (d) 

3.1.2. 

Number of 

online platforms developed to 

share 

information and best practices (i) 

3.1.3  Degree  of  supporting  evidence  from 

consultations 

(opinion of stakeholders) (d) 

3.1.4 Strength of linkages between output and 

results indicators (d) 

3.1.5  Challenges 

identified 

that 

affect 

implementation  and  the  progress  towards  the 

objectives  of  the  fund  (e.g.,  identified  issues 

reflecting the performance of a programme as 

identified in implementation reports) (d) 

3.1.6  The  fund  makes  use  of  available  good 

practices where relevant and possible (d) 

84 

 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

3.1.7  Indicators/descriptors  of  intermediate 

effects as identified in the Intervention logics 

for shared management and Union actions 

3.2  What  progress  has  been  made 

3.2.1 

Evidence  of  early  progress 

3.2.1 OI 1: Number of cross-border operations, 

- Mapping of allocations (Task 1b) 

towards 

the 

improving 

and 

towards 

the  achievement  of 

the 

specifying joint 

investigation 

teams 

-  Review  of  methodology  for  target 

intensifying 

cross-border 

milestone  and 

target  values  as 

and EMPACT operational actions (i) 

setting (Task 1c) 

cooperation, 

including 

joint 

measured by output indicators related 

3.2.1  OI 

2:  Number 

of 

expert 

-  Synthesis  of  performance  reports 

operations,  between 

competent 

to  improving  and  intensifying  cross-

meetings/workshops/study 

visits/common 

(Task 1d) 

authorities  in  relation  to  terrorism 

border  cooperation,  provided  these 

exercises (i) 

- Systematic review of Member States 

and  serious  and  organised  crime 

were  correctly  defined  and  in  line 

3.2.1  OI  3:  Number  of  equipment  items 

evaluations (Task 1e) 

with a cross-border dimension? 

with evolving needs 

purchased (i) 

- Quantitative analysis (Task 1f) 

3.2.2 

Evidence  of  early  progress 

3.2.1  OI  4:  Number  of  transport  means 

-  Final  project  reporting  (UAs  and 

towards 

the  achievement  of 

the 

purchased for cross-border operations (i) 

EMAS)  

milestone  and 

target  values  as 

3.2.1 OI Union actions (the above indicators) 

- 

Interviews/survey  with  Member 

measured by Result indicators related 

and:  Number  of  cross-border  operations, 

States 

authorities 

(MA,  DA), 

to  improving  and  intensifying  cross-

separately specifying joint investigation teams 

beneficiaries, and end-beneficiaries 

border  cooperation,     provided  these 

and EMPACT operational actions (i) 

- Case studies (Task 4) 

were  correctly  defined  and  in  line 

3.2.2 RI 1: The estimated value of assets frozen 

- Public consultation (Task 2d) 

with evolving needs 

in the context of cross-border operations (also 

- Desk research on indicators 

3.2.3 

Stakeholder  perception  on 

for UA, even if to a smaller extent) (i) 

Funds contribution to achievement of 

3.2.2 RI 2: Quantity of illicit drugs seized in the 

expected results  

context of cross-border operations, by type of 

3.2.4 

Contribution 

of 

Fund 

product  (also  for  UA,  even  if  to  a  smaller 

measures 

to 

improving 

and 

extent) (i) 

facilitating 

the 

exchange 

of 

3.2.2 RI 3: Quantity of weapons seized in the 

information 

context of cross-border operations, by type of 

85 

 
 
 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

3.2.5 

Identification  of 

factors 

weapon  (also  for  UA,  even  if  to  a  smaller 

hampering 

the 

achievement  of 

extent) (i) 

intended objectives 

3.2.2 RI 4: Number of administrative units that 

3.2.6 

Best  practices  as  identified 

have 

developed/adapted 

existing 

in  previous  evaluations  of  the  fund 

mechanisms/procedures/tools/guidance 

for 

are put in place 

cooperation  with  other  Member  States/Union 

3.2.7  Evidence  of  early  progress 

bodies, 

offices 

or 

agencies/third 

towards 

the  achievement  of 

the 

countries/international  organisations  (also  for 

identified 

expected 

intermediate 

UA) (i) 

impacts 

3.2.2 RI 5: Number of staff involved in cross-

border operations (also for UA) (i) 

3.2.2  RI  6:  Number  of  Schengen  evaluation 

recommendations addressed (i) 

3.2.2  Boosted  participation  in  actions  in  the 

context of EMPACT (d) 

3.2.2  Participants  who  believe  the  activities 

contribute  to  increasing  mutual  trust  between 

authorities and to increased coordination (d) 

3.2.2 Increased use of networks of specialised 

national units (d) 

3.2.2  Mutual  trust  building  between  different 

agencies, at regional, national and international 

level (UA) (d) 

3.2.3  Degree  of  supporting  evidence  from 

consultations 

(opinion of stakeholders) (d) 

3.2.4 Strength of linkages between output and 

results indicators (d) 

86 

 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

3.2.5  Challenges 

identified 

that 

affect 

implementation  and  the  progress  towards  the 

objectives  of  the  fund  (e.g.,  identified  issues 

reflecting the performance of a programme as 

identified in implementation reports) (d) 

3.2.6  The  fund  makes  use  of  available  good 

practices where relevant and possible (d) 

3.2.7  Indicators/descriptors  of  intermediate 

effects as identified in  the Intervention logics 

for shared management and Union actions  

3.3 What progress has been made in 

3.3.1 

Evidence  of  early  progress 

3.3.1 OI 1: Number of participants in training 

- Mapping of allocations (Task 1b) 

supporting 

the  strengthening  of 

towards 

the  achievement  of 

the 

activities (also for UA) (i) 

-  Review  of  methodology  for  target 

Member  States’  capabilities 

in 

milestone  and 

target  values  as 

3.3.1  OI  2:  Number  of  exchange 

(i) 

setting (Task 1c) 

relation 

to 

preventing 

and 

measured by output indicators related 

programmes/workshops/study  visits  (also  for 

-  Synthesis  of  performance  reports 

combating  crime, 

terrorism  and 

to  supporting  the  strengthening  of 

UA) (i) 

(Task 1d) 

radicalisation, as well as managing 

Member  States’ 

capabilities 

in 

3.3.1  OI  3:  Number  of  equipment  items 

- Systematic review of Member States 

security-related incidents, risks and 

relation to preventing and combating 

purchased (also for UA) (i) 

evaluations (Task 1e) 

crises? 

crime, provided these were correctly 

3.3.1  OI  4:  Number  of  transport  means 

- Quantitative analysis (Task 1f) 

defined  and  in  line  with  evolving 

purchased (also for UA) (i) 

-  Final  project  reporting  (UAs  and 

needsd3.3.2  Evidence 

of 

early 

3.3.1  OI 

5:  Number 

of 

items 

of 

EMAS) (Task 1f) 

progress towards the achievement of 

infrastructure/security-relevant 

- 

Interviews/survey  with  Member 

the  target  values  as  measured  by 

facilities/tools/mechanisms 

States 

authorities 

(MA,  DA), 

Result 

indicators 

related 

to 

constructed/purchased/upgraded (also for UA) 

beneficiaries, participants  

supporting 

the 

strengthening  of 

(i) 

- Case studies (Task 4) 

Member  States’ 

capabilities 

in 

3.3.1 OI 6: Number of projects to prevent crime 

- Public consultation (Task 2d) 

relation to preventing and combating 

(also for UA) (i) 

- Desk research on indicators 

crime,   provided these were correctly 

3.3.1 OI 7: Number of projects to assist victims 

defined  and  in  line  with  evolving 

of crime (also for UA) (i) 

needsd3.3.3  Stakeholder perception 

87 

 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

on Funds contribution to achievement 

3.3.1  Number  of  stakeholders  reached  out 

of 

expected 

results 

d3.3.4

through  education/training  activities  (e.g.  on 

Contribution  of  Fund  measures 

crime prevention) (also for UA) (i) 

to  improving  and  facilitating  the 

3.3.1:  OI  Union  Actions:  Number  of  newly 

exchange 

of 

informationd3.3.5 

developed AI tools (also relevant for SO1) (i) 

Identification  of  factors  hampering 

(i) 

the 

achievement 

of 

intended 

3.3.1:  OI  Union  Actions:  Number  of  partners 

objectivesd3.3.6  Best  practices  as 

(relevant for all SOs) (i) 

identified  in  previous  evaluations  of 

3.3.1: Number of initiatives involving private 

the fund are put in place 

entities  and 

law  enforcement  authorities 

3.3.7  Evidence  of  early  progress 

(relevant for all SOs) (i) 

towards 

the  achievement  of 

the 

identified 

expected 

intermediate 

3.3.2  OI  8:  Number  of  victims  of  crimes 

impacts 

assisted (also for UA) (i) 

3.3.2  RI 

1:  Number 

of 

initiatives 

developed/expanded  to  prevent  radicalisation 

(also for UA) (i) 

3.3.2  RI 

2:  Number 

of 

initiatives 

developed/expanded 

to 

protect/support 

witnesses and whistleblowers (also for UA) (i) 

3.3.2 

RI 

3:  Number 

of 

critical 

infrastructure/public  spaces  with new/adapted 

facilities  protecting  against  security-related 

risks (also for UA) (i) 

3.3.2  RI  4:  Number  of  participants  who 

consider  the  training  activity  useful  for  their 

work (also for UA) (i/d) 

3.3.2 RI 5: Number of participants who report 

three months after the training activity that they 

88 

 
 
 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

are using the skills and competences acquired 

during that training activity (also for UA) (i/d) 

3.3.2 Improved capacity to rapidly respond to 

risks, crises and incidents via the application of 

the developed tools (i) 

3.3.2  Enhanced 

forensic 

and 

research 

capabilities  for  detecting  and  combatting 

cybercrime  and  conducting  laboratory  testing 

and (financial) crime investigations (i) 

3.3.2 Increased awareness on issues related to 

preventing and combating crime, terrorism and 

radicalisation (i) 

3.3.2 

Improved  skills,  sharing  of  new 

methodologies  across stakeholders (i) 

3.3.2 Increased speed and reactivity to threats 

thanks to AI tools (for UA) (i) 

3.3.3  Degree  of  supporting  evidence  from 

consultations 

(opinion of stakeholders) (i) 

3.3.4 Strength of linkages between output and 

results indicators (i) 

3.3.5  Challenges 

identified 

that 

affect 

implementation  and  the  progress  towards  the 

objectives  of  the  fund  (e.g.,  identified  issues 

reflecting the performance of a programme as 

identified in implementation reports) (i) 

3.3.6  The  fund  makes  use  of  available  good 

practices where relevant and possible (i) 

89 

 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

3.3.7  Indicators/descriptors  of  intermediate 

effects as identified in the Intervention logics 

for shared management and Union actions 

EQ2.  To  what  extent  is  the 

4.1 To what extent is the reporting 

4.1.1  A 

reliable  electronic  data 

4.1.1 An IT system is put in place to monitor 

-  Review  of  methodology  for  target 

monitoring 

and 

evaluation 

system  suitable  for  recording  and 

exchange system (especially between 

milestones and targets (d) 

setting (Task 1c) 

framework  suitable  to  inform 

storing information? 

Managing  Authorities/  Intermediate 

4.1.1  The  system  allows  Member  States 

-  Synthesis  of  performance  reports 

on  the  progress  towards  the 

achievement  of  the  objectives 

of the fund? 

Bodies 

and 

beneficiaries) 

for 

/beneficiaries 

to  report  on  progress  per 

(Task 1d) 

recording  and  storing  data 

for 

implementation measure and indicative action 

- Systematic review of MS evaluations 

monitoring and evaluation is in place 

(d) 

(Task 1e) 

4.1.2  The  data  provided  by  the 

4.1.2  Monitoring 

requirements  are  duly 

- Quantitative analysis (Task 1f) 

Member  States 

are 

considered 

understood by  the  actors  involved  in  the  data 

-  Final  project  reporting  (UAs  and 

reliable,  complete,  consistent,  and 

supply process (d) 

EMAS)  

based 

on 

robust 

target-setting 

4.1.2  Training  or  info-sessions  are  organised 

- 

Interviews/survey  with  MS 

methodologies  

for actors involved in the data supply process, 

authorities  (MA,  DA),  beneficiaries, 

where relevant (d) 

and participants 

4.1.2  Guidelines  provided  are  understood  by 

- Case studies (Task 4) 

the Member States / beneficiaries (d) 

4.2  To  what  extent  are 

the 

4.2.1  The  reporting  on  output  and 

4.2.1  Share  of  Member  States  outlining 

output/result indicators suitable for 

result  indicators  correctly  reflect  the 

underreporting  of  achievements  in  Annual 

the  monitoring  of  the  progress 

level  of 

implementation  on 

the 

performance reports (d) 

towards  the  achievement  of  the 

ground (no over/under-reporting) 

4.2.2 Member States report as per requirements 

objectives of the fund? 

4.2.2 The common indicators capture 

outlined  in  COM  Implementing  Regulation 

the main achievements of the fund in 

(EU)  2023/170  (sufficient 

information 

is 

line with the intervention logic of the 

provided in reports) (d) 

programme 

90 

 
 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

4.2.3  Programme  specific  indicators 

4.2.3  Programme  specific 

indicators  are 

are used to fill any substantial gap in 

identified  in  synthesis  of  implementation  and 

the  common  indicators  based  on  the 

evaluation reports (d) 

intervention logic of the programme 

4.2.4  Strength  of  linkages  between  output, 

4.2.4 The overall set of data recorded 

result and impact indicators (d) 

generates  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 

EQ3. 

How 

was 

the 

5.1  How  have  Member  States 

5.1.1  There  is  a  strategy  in  place  to 

5.1.1 Strategy for identification and outreach to 

-  Minutes  of  monitoring  committee 

involvement  of  the  relevant 

ensured  the  involvement  of  all 

identify,  inform  and  reach  the  most 

partners identified (d) 

meetings 

partners  ensured  across  all 

relevant  partners  in  a  balanced 

relevant partners 

5.1.2 Diverse groups of stakeholders identified 

-  Synthesis  of  performance  reports 

stages  of  the  programming, 

manner? 

5.1.2 A balanced representation in the 

in the monitoring committee (d) 

(Task 1d) 

implementation,  monitoring 

monitoring committee is ensured 

- Case studies (Task 4) 

and evaluation? 

5.2  To  what  extent  were  relevant 

5.2.1  Relevant  partners  have  been 

5.2.1  Relevant  partners  participate  in  the 

- 

Interviews/survey  with  Member 

partners 

involved  during 

the 

identified  and  were  involved  at  the 

monitoring committee in line with their role as 

States 

authorities 

(MA,  DA), 

programming phase? 

programming stage 

defined by the relevant rules of procedure (d) 

beneficiaries 

5.3  To  what  extent  were  relevant 

5.3.1  Actions  are  put  in  place  to 

5.3.1  Relevant  partners  participate  in  the 

partners 

involved  during 

the 

enable 

the  participation  of 

the 

monitoring committee in line with their role as 

implementation  phase,  monitoring 

partners  across  all  stages  of  the 

defined by the relevant rules of procedure (d) 

and evaluation? 

programme cycle 

91 

 
 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

EQ4.  To  what  extent  does  the 

6.1  Do 

the 

different 

fund 

6.1.1  Suitable  organisational  and 

6.1.1. 

Arrangements 

identified 

in 

-  Synthesis  of  performance    reports 

fund  respect  or  promote  in  its 

components  ensure  the  respect  of 

procedural  arrangements  are  put  in 

implementation  of  actions  that  ensure  the 

(Task 1d) 

implementation  the  horizontal 

the charter of fundamental rights of 

place  to  ensure  the  respect  of  the 

respect of the charter of fundamental rights of 

- Systematic review of Member States 

principles? 

the EU in the fund implementation 

charter  of  fundamental  rights  of  the 

the EU in the fund implementation - Art. 9(1) 

evaluations (Task 1e) 

as per Art. 9(1) of CPR? 

EU in the fund implementation - Art. 

of CPR (d) 

9(1) of CPR 

- 

Interviews/survey  with 

the 

Commission, 

Member 

States 

authorities  (MA,  DA),  beneficiaries, 

and participants 

-  Case  studies  (Task  4)  –  specifically 

case study on contribution to horizontal 

priorities 

6.2. How do the dts promote gender 

6.2.1  Suitable  organisational  and 

6.2.1 

Arrangements 

identified 

in 

equality and gender mainstreaming 

procedural  arrangements  are  put  in 

implementation  of  actions  that  ensure  that 

across all stages of the preparation, 

place  which  ensure  that  appropriate 

appropriate steps are taken to take into account 

implementation, 

monitoring, 

steps  are  taken  to  take  into  account 

and  promote  gender  equality  and  gender 

reporting  and  evaluation  of  the 

and  promote  gender  equality  and 

mainstreaming  across  all  stages  of 

the 

programme as per Art. 9(2) of CPR? 

gender  mainstreaming  across  all 

preparation, 

implementation,  monitoring, 

stages 

of 

the 

preparation, 

reporting and evaluation of the fund - Art. 9(2) 

implementation, 

monitoring, 

of CPR (d) 

reporting and evaluation of the fund - 

Art. 9(2) of CPR 

6.3  How 

is 

the  prevention  of 

6.3.1 

There 

are 

suitable 

6.3.1 

Arrangements 

identified 

in 

• 

discrimination  on  all  grounds  and 

organisational 

and 

procedural 

implementation  of  actions  that  allow  taking 

across 

all 

stages 

of 

the 

arrangements  in  place  that  allow 

appropriate steps to prevent discrimination on 

programming  cycle  (as  per  Art. 

taking  appropriate  steps  to  prevent 

all  grounds  and  across  all  stages  of  the 

9(3)) of CPR ensured? 

discrimination  on  all  grounds  and 

programming cycle - Art. 9(3) of CPR (d) 

across all stages of the programming 

cycle - Art. 9(3) of CPR 

92 

 
 
 
 
 
 
Evaluation Question 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

6.4  Are 

the 

different 

fund 

6.4.1  The 

fund 

has 

suitable 

6.4.1 

Arrangements 

identified 

in 

• 

components 

aligned  with 

the 

arrangements 

that 

ensure 

that 

implementation of actions that show alignment 

objectives  set  out  in  Article  11 

implementation  is  aligned  with  the 

with 

the  objective  promoting  sustainable 

TFEU, taking into account the UN 

objective 

promoting 

sustainable 

development,  as  set  out  in  Article  11  TFEU, 

Sustainable  Development  Goals, 

development, as set out in Article 11 

taking 

into  account 

the  UN  Sustainable 

the Paris Agreement and the "do no 

TFEU,  taking  into  account  the  UN 

Development Goals, the Paris Agreement and 

significant  harm"  principle  as  per 

Sustainable  Development  Goals,  the 

the  "do  no  significant  harm"  principle  -  Art. 

Art. 9(4) of CPR? 

Paris  Agreement  and  the  "do  no 

9(4) of CPR (d) 

significant harm" principle - Art. 9(4) 

of CPR 

EQ5. To what extent is the fund 

N/A 

7.1  There 

is  a  communication 

7.1.1  Evidence  of  communication  strategy 

-  Synthesis  of  performance  reports 

effective in communicating and 

disseminating 

on 

opportunities 

as  well 

its 

as 

achievements? 

strategy 

in  place,  with  correctly 

(i.e., measures to identify target groups and set 

(Task 1d) 

identified  target  groups  as  well  as 

monitoring arrangements) (d) 

- Systematic review of Member States 

relevant  monitoring  arrangements, 

7.2.1 Number and type of communication and 

evaluations (Task 1e) 

including appropriate and measurable 

visibility actions carried out (i) 

- Public consultation (Task 2d) 

targets 

for 

the 

communication 

7.2.2 Number of communication and visibility 

-  Desk  research  on  communication 

activities 

actions reaching their target (i) 

indicators 

7.2 Dissemination activities reach the 

7.3.1  Evidence  of  advertisement  of  funding 

- Case studies (Task 4) 

target  audience  and  are  carried  out 

opportunities  (e.g.,  on  websites  of  Managing  

through  an  appropriate  mix  of 

Authorities) (d) 

communication 

channels 

and 

7.3.2 Evidence of advertisement outreach (e.g., 

platforms,  including  social  media, 

web  sites  of  Member  State  programmes  and 

and generate interactions 

EU websites) (d) 

7.3  Funding 

opportunities 

are 

adequately  advertised  and  reach  the 

identified  target  group  of  potential 

beneficiaries 

93 

 
 
 
 
 
Efficiency 

Evaluation 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

EQ6.  To  what 

8.1  The  fund  supports  types  of  interventions  and  types of  actions 

8.1  Application  of  cost-effectiveness  analysis  in 

- Calls for proposals documents/ISF Guidance documents at 

extent  does  the 

that  are  known  to  be  cost-effective,  based  on  available  evidence, 

designing measures under the ISF (d) 

EU/National level (Task 1a) 

fund 

support 

including relevant literature or the ex-post evaluation of the previous 

8.1.  Managing 

authorities 

from  MS/ 

- Interviews/survey with MS authorities, EC, beneficiaries, 

cost-  effective 

programme 

Beneficiaries/End  beneficiaries’  opinion  on  cost-

and end-beneficiaries 

measures? 

8.2 The early evidence coming from the operations indicates that the 

effectiveness (d) 

- Operations budgets 

cost per unit is in line or below existing benchmarks and estimates. 

8.1  –  8.3  Costs  for  responsible  authorities  and 

-  Evaluations/budgetary 

information 

for 

previous 

8.3  The  differences  in  the  cost per  unit  among  similar  operations 

other delegated authorities (i) 

programming periods/services 

within  fund  components  can  be  explained  and  justified  (e.g., by 

8.1 – 8.3 Costs for the Commission (for direct and 

- Synthesis of performance  reports (Task 1d) 

differences  in  the  intensity  or  quality  of  the  support  offered, 

indirect management) (i) 

- Systematic review of Member States evaluations (Task 1e) 

innovativeness, etc.) 

8.1 – 8.3 Costs for beneficiaries (i) 

- Quantitative analysis (Task 1f) 

8.4 For highly specific, emergency or innovative actions supported 

8.1 – 8.3 Costs for final recipients / participants (if 

- Final project reporting (UAs and EMAS) (Task 1f) 

via  direct  or  indirect  management,  appropriate  mechanisms  exist 

any) (i) 

- Case study data on timeline and the application of the ISF 

which ensure that that cost-effectiveness is reviewed as a criterion 

8.1-8.3  Unit  costs  (e.g.,  costs  per  person  trained, 

procedures (Task 4) 

to select the beneficiary 

cost per event)/Overall absorption rate (i) 

-  Interviews/survey  with  Member  States  authorities  (MA, 

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

8.4  Stakeholders’  interpretation  (at  national  and 

DA), Commission, beneficiaries, and participants 

positive spillovers 

EU level) of the ISF requirements and experience 

8.6  The  thematic  facility  allows  to  address  new  developments  or 

in applying them (d) 

priorities at EU level in a swift and appropriate manner 

8.5 Examples of positive spillovers identified (d) 

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

8.6 – 8.7 (i) Number of Full Time Equivalent in the 

and efficient manner. 

Responsible  Authority,  the  Delegated  Authority 

and 

the  Audit  Authority  working  on 

the 

implementation  of  the  Fund  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 year; (i)  

94 

 
 
Evaluation 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

(ii)  technical  assistance  plus  the  administrative 

(indirect)  cost  of  projects  as  compared  to  the 

amount of funds claimed for the financial year; (i) 

EQ7.  To  what 

9.1 The management and control system, described as per the legal 

9.1.1  Commission/Member  States  authorities  / 

- Synthesis of performance  reports (Task 1d) 

extent 

is 

the 

basis,  aims  to  ensure  efficiency  in  the  selection  of  operations, 

beneficiaries  /  final  recipients’  opinion  on  the 

- Systematic review of Member States evaluations (Task 1e) 

management 

management 

tasks,  work  of 

the  monitoring  committee, 

quality of management and control systems (d) 

- Quantitative analysis (Task 1f) 

and 

control 

implementation of anti-fraud measures and procedures, fulfilment 

9.1.2  Audit  authorities  and  EU 

institutions’ 

- Final project reporting (UAs and EMAS)  

system 

efficient? 

of  accounting  function  and  recording  and  storing of data on  each 
operation (21) 

opinion  on  the  quality  of  the  management  and 

- Case study data on management and control measures put 

control systems (d) 

in place (Task 4) 

9.2 The administrative burden is proportionate for all implementing 

9.2.1  –  9.3.1  Commission/  Member  States 

-  Interviews/survey  with  Member  States  authorities  (MA, 

actors  compared  to  the  previous  programming  period/  similar 

authorities 

/  Beneficiaries  opinion  on 

the 

DA), Commission, beneficiaries 

services offered to comparable target groups without the support of 

administrative  burden  related  to  the  management 

the programme 

and control system (d) 

9.3 The administrative burden is proportionate for all beneficiaries, 

9.2.1  Costs  for  responsible  authorities  and  other 

e.g. compared to the previous programming period/ similar services 

delegated authorities (i) 

offered  to  comparable  target  groups  without  the  support  of  the 

9.2.2  Costs  for  the  Commission  (for  direct  and 

programme 

indirect management) (i) 

9.4  Absence  of  ‘gold-plating’  at  the  national  level  (e.g.  from 

9.2.3 Costs for beneficiaries (i) 

Managing  Authorities,  Intermediate  Bodies,  national  Audit 

9.4.1-9.5.1 Timelines and requirements of the ISF 

Authorities), i.e. requirements are not interpreted more restrictively 

procedures (i) 

than the legal basis or relevant documents providing methodological 

9.5.2-9.6.1 Stakeholders interpretation (at national 

advice to the Member States and unless a justified reason exists 

and  EU  level)  of  the  ISF  requirements  and 

9.5 Absence of ‘gold-plating’ at the EU level, i.e. requirements are 

experience in applying them (d) 

not interpreted more restrictively than in the legal basis and unless a 

9.6.2  –  9.7.1  Evidence  of  cost-effectiveness 

justified reason exists 

arrangements in the use of operating support (d) 

9.6 Simplified cost options used create simplification on the ground 

9.6.3 –  9.7.2  Evidence  of  cost-effectiveness 

9.7 Technical assistance is used to strengthen the management and 

arrangements  in  the  use  of  special  schemes 

control system when necessary 

(d) 

95 

 
 
Evaluation 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

EQ8.  To  what 

10.1 There is evidence of legal requirements, rules of procedures or 

N/A 

extent is further 

practices that create  disproportionate  administrative  burden  at the 

simplification 

EU or Member States level, and concrete alternatives exist 

- Synthesis of performance reports (Task 1d) 

- Systematic review of Member States evaluations (Task 1e) 

- Quantitative analysis (Task 1f) 

achievable? 

10.2 There is room for additional use of simplified cost options and 

-  Interviews/survey  with  Member  States  authorities  (MA, 

How? 

financing not linked to costs options 

DA), beneficiaries 

- Public consultation (Task 2d) 

Coherence 

Evaluation 

Sub questions 

Question 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

EQ9. 

To 

11.1  Was  an  assessment  of  other  EU  interventions 

11.1.1 Adequate degree of assessment of 

11.1.1 Number and type of other 

- Desk research of Member States programmes / TF 

what  extent 

(e.g.  BMVI,    Fiscalis  2021-2027,  Horizon  Europe, 

other  interventions  carried  out  during 

EU interventions covered in the 

work programmes; 

is  the  fund 

Hercule,  ERDF,  EAFRD,  FEAD,  EUTF,  NDCI, 

the programming phase. 

assessments 

- Synthesis of performance reports (Task 1d) 

coherent 

Digital  Europe,  ReSCUe,,  Technical  Support 

- Systematic review of Member States evaluations 

with 

Instrument (TSI) ) with similar objectives carried out 

11.2.1 

Existing 

evidence 

of 

11.2.1  Evidence  of  synergies 

(Task 1e) 

initiatives 

and  taken  into  account  during  the  programming 

complementarity between the Funds 

between 

funds 

(e.g. 

-  Final  project  reporting  (UAs  and  EMAS,  to  the 

supported 

stage? 

under 

its 

11.3.1  There  is  evidence  of  coherence 

acquired in accordance with one 

- Interviews/survey with Member States authorities 

multipurpose 

equipment 

extent available) (Task 1f) 

policy 

11.2 Is the fund complementary with BMVI? 

across the different management modes 

fund  but  used 

to  achieve 

EC(MA, DA), beneficiaries 

domain, 

in 

(coherence  between  specific  actions, 

objectives of both) 

- additional studies and literature 

particular 

11.3  Are  the  actions  that  the  Commission  initiates 

Union actions and emergency assistance 

-  Case  studies  (Task  4):  Cluster  analysis  and 

with support 

coherent  to  those  proposed  and  implemented  by 

and Member States programmes) 

11.3.1  Existing  evidence  of 

country 

case 

studies 

(to  understand 

the 

under 

the 

coherence  across  management 

harmonisation of the methodology among different 

96 

 
 
 
 
 
 
 
 
 
 
Evaluation 

Sub questions 

Question 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

thematic 

Member  States  through  their  programmes  (i.e.,  is 

modes  (i.e.,  no  duplication  of 

Member  States)  and  Thematic  case  studies  (to 

facility 

there evidence of internal coherence)? 

across 

the 

different 

management 

modes? 

actions 

and 

evidence 

of 

comprehend the Funds implementation) 

synergies between actions)  

- Desk analysis, at aggregate level of other funds to 

identify the coordination mechanisms used  

12.1.1  Number  of  Member 

- Public consultation (Task 2d) 

States 

with 

coordination 

- Interviews with EU officials 

mechanism established 

- Focus groups (validation) 

12.1.2 

Frequency 

of 

coordination 

12.2.1  No 

evidence 

of 

contradictory or adverse effects  

11.1.1-12.2.1 

Degree 

of 

supporting 

evidence 

from 

consultations  

EU Added Value 

Evaluation 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

EQ11.  To 

13.1  Would 

the 

13.1 Evidence demonstrates that the fund 

13.1  –  13.4  Established  volume,  scope  effects, 

- Synthesis of performance  reports (Task 1d) 

what extent 

Member  States  have 

achieved  additionality; 

it  successfully 

role and process effects (i/d) 

- Systematic review of Member States evaluations (Task 1e) 

is  the  fund 

carried 

out 

the 

mobilised resources and reached areas that 

- Final project reporting (UAs and EMAS) (Task 1f) 

generating 

actions  required 

to 

would  have  otherwise  been  inaccessible 

13.1 – 13.4 Existence of national funds available 

-  Interviews/survey  with  Member  States  authorities  (MA,  DA), 

implement 

the  EU 

without the fund. 

for policy (i/d) 

beneficiaries, and participants 

97 

 
 
 
 
 
 
 
Evaluation 

Sub questions 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

EU  added 

policies  in  the  Fund 

13.2  Evidence  of  decrease/weakened 

- additional studies and literature 

value? 

areas  without 

the 

policy implementation if interruption 

13.1  –  13.4  Evidence  of  funding  influencing 

- Reports from inter-DG coordination meetings 

financial  support  of 

national policy implementation (d) 

- Case studies (Task 4): Joint monitoring reports or cross-check of 

the Fund? 

13.3.1  The  Fund  focuses  on  areas, 

individual (project level) monitoring reports  

interventions and target groups where the 

13.1 – 13.4 Assessment of the contribution to the 

- Desk analysis, at aggregate level as well as a sample of projects-

13.2  What  would  be 

results at the EU level can go beyond what 

EU added value from each fund component (d) 

level information  

the  most 

likely 

can  be    achieved  by  the  Member  States 

- Public consultation (Task 2d) 

consequences  of  an 

acting on their own.  

13.1 – 13.4 Degree of supporting evidence from 

interruption  of 

the 

consultations (opinion of stakeholders) (d) 

support  provided  by 

13.3.2 There is evidence of scope effects, 

the Fund? 

i.e.  of  additional  target  groups  addressed 

13.1  –  13.4  Likely  scenario  consequences  at 

or additional types of intervention offered 

different 

levels 

(EU/Member 

States 

13.3 To which extent 

S/beneficiary/target group) (d) 

have 

actions 

13.3.3  There  is  evidence  of  scale  effects, 

supported  by 

the 

i.e.  of  a  higher  volume  of  services 

Fund  resulted  in  a 

offered/end-users addressed 

benefit  at  the  Union 

level? 

13.4 There is evidence of different levels 

of  achieved EU  added  value between  the 

13.4 

Is 

there 

a 

fund components 

difference  between 

the 

EU 

added 

generated 

between 

the  different 

fund 

components? 

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Relevance 

Evaluation 

Sub 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

questions 

EQ12.  To 

1.1.  Did  the 

1.1.1 The programme stakeholders are correctly identified 

1.1.1 Type of programme stakeholders identified (as per the categories described in the 

- Needs assessment (task 1a) 

what extent 

objectives  set 

in line with the objectives established in the legal basis 

Consultation strategy) (i) 

- Mapping of allocations (Task 1b) 

does 

the 

by 

the 

1.1.2 Extent to which needs and objectives are set in Member States’ Programmes 

- Calls for proposals procurement/awarded 

fund 

Member 

1.1.2  The  needs  analysis  that  led  to  the  definition  of  the 

are in line (d) 

grants  documents  (Union  actions  and 

address  the 

States in their 

programme and related distribution  of resources is in  line 

1.1.3 Extent to which the identified needs and projects are implemented in Member 

EMAS) 

evolving 

Programmes 

with  relevant  current  and  prospect  needs  of  the  relevant 

States (d) 

- TF work programmes for Specific Actions 

needs? 

respond to the 

stakeholders 

1.1.4 Degree of flexibility/broadness of  Member States programme objectives and 

- National evaluation reports; Synthesis and 

identified 

for accommodating changing needs (d) 

systematic review  (Task 1d and e) 

needs? 

1.1.3 The strategy developed to address such needs, which 

1.1.5 Ability  of  Member  States  programmes  in  focusing  on  few  key  objectives 

- Public consultation (Task 2d) 

is  translated  into  concrete  milestones  and  targets,  aims  to 

(instead of having too many priorities) (d) 

address  the 

  most  relevant  needs  with  proportionate 

resources 

1.1.4 The list of implementation measures included in the 

legal basis and planned within the programme is suitable to 

address current and prospect needs of the target groups 

1.2  Did  the 

1.2.1  The  work  programme  stakeholders  are  correctly 

1.2.1 Type of work programme stakeholders identified (i) 

objectives  set 

identified in line with the objectives established in the legal 

1.2.2 Extent  to  which  needs  and  objectives  are  in  line  with  those  set  in  the  Work 

in  the  Work 

basis 

Programmes 

Programmes for the Thematic Facility (d) 

1.2.3 Extent  to  which  the  identified  needs  and  projects  are  implemented  in  UAs  / 

for 

the 

1.2.2  The  needs  analysis  that  led  to  the  definition  of  the 

EMAS / Specific actions (d) 

Thematic 

work programme and related distribution of resources is in 

1.2.4 Extent to which the identified needs and objectives are implemented in EMAS 

Facility 

line with relevant current and prospect needs of the relevant 

1.2.4 Degree of relevance to current needs of calls for proposals, calls for expression 

address 

the 

stakeholders 

actual needs? 

of interest, awarded grants, procurements etc. (d) 

- 

Surveys/thematic 

interviews  with 

Managing 

and 

relevant  Delegated 

Authorities in the Member States 

- 

Surveys/thematic 

Interviews  with 

Beneficiaries  of 

the 

  Member  States 

programmes 

- Desk research 

- Case studies (Task 4) 

99 

 
 
 
 
 
 
 
 
Evaluation 

Sub 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

questions 

1.2.3 The strategy developed to address such needs, which 

is  translated  into  concrete  milestones  and  targets,  aims  to 

address 

the  most  relevant  needs  with  proportionate 

resources 

1.2.4 The list of implementation measures included in the 

legal  basis  and  planned  within  the  work  programme  is 

suitable to address current and prospect needs of the target 

groups 

EQ13.  To 

2.1  Which 

2.1.1 A  needs  assessment  is  performed  and  updated  on  a 

2.1.1 Frequency of needs assessments (d)  

what extent 

measures  did 

regular  basis  or  whenever  there  are  relevant  contextual 

- Needs assessment (Task 1a) 

- Mapping of allocations (Task 1b) 

can 

the 

the  Member 

changes 

2.1.2 Type of measures put in place to address changing needs (i) 

-  Synthesis  of  performance    reports  (Task 

fund  adapt 

States  put  in 

2.1.2 The  partnership  /  monitoring  committee  is  able  to 

1d) 

to 

the 

place 

to 

provide  timely  input  on  evolving  needs  and  relevant 

2.1.3 – 2.1.6 Degree of flexibility for the design or revisitations of the programmes (d) 

-  Systematic  review  of  Member  States 

evolving 

address 

developments on the    ground 

needs? 

changing 

2.1.3 There is an adequate degree of flexibility in the design 

needs? 

of the operations 

2.1.4 Where  necessary,  non-substantial  changes  to  the 

programme strategy can be applied swiftly 

2.1.5 There are rules and procedures in place that ensure that 

the  substantial  adjustments  of  the  programme  can  be 

implemented in due time if new needs arise 

2.1.6 If  there  have  been  changes  in  the  needs  after  the 

programme adoption, the programme strategy or operations 

have  been  adapted  in  due  time  or,  alternatively,  the  new 

needs have been duly addressed via the thematic facility 

100 

evaluations (Task 1e) 

- 

Surveys/thematic 

interviews  with  

Managing 

and 

relevant  Delegated 

Authorities  in the Member States 

- 

Surveys/thematic 

Interviews  with 

Beneficiaries  of 

the 

  Member  States 

programmes 

- Public consultation (Task 2d) 

 
 
 
 
 
 
 
 
Evaluation 

Sub 

Judgement Criteria 

Indicators (i) / descriptors (d) 

Source and analytical tools 

Question 

questions 

2.2  Which 

2.2.1 The work programme of the thematic facility focuses 

2.2.1-2.2.3  Degree  of  flexibility  of  TF  work  programmes  in  focusing  on  few  key 

- Needs assessment (Task 1a) 

measures 

on the key priority needs and target groups 

objectives (instead of having too many priorities) (d) 

- Case studies 

were  put  in 

2.2.2 The  Thematic  Facility  allows 

to  address  new 

-  TF  work  programmes  and 

their 

place 

to 

developments  or  priorities  at  EU  level  in  an  efficient 

2.2.1-2.2.3 Degree of supporting evidence from consultations 

amendments 

address 

manner 

(opinion of stakeholders) (d) 

- Survey/thematic interviews 

changing 

2.2.3 Procurement procedures  from the COM  ensures  that 

needs 

as 

there is built-in flexibility and bottom-up feedback 

concerns 

direct/indirect 

management? 

101 

 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

The table provides  an indication of the main  costs133 and benefits  of the  ISF implementation. Considering the early stage of implementation,  it is  not 
possible to carry out a fully-fledged CBA given the fact that there is little evidence of the achieved benefits, and most funding is not yet spent. 

From an administrative point of view, the expected benefits of the move to the Common Provisions Regulation were outlined in the Impact Assessment 
and include Ensuring flexibility; Simplifying the rules (by dissociating payment claims from the examination of the accounts or promoting SCOs); Ensuring 
more synergies between the Funds; and Increasing the focus on performance (by making reporting regular). However, these benefits were not identified in 
the mid-term evaluation. Moreover, as mentioned in the Efficiency section: the increased reporting obligations, driven by the overlapping of the Funds and 
the increase in the frequency of transmission of indicators, entail significant documentation and organisational efforts, making the Fund management more 
administratively demanding than the system used under the ISF-P. Nevertheless, the majority of Managing Authorities that responded to the survey consider 
the ISF to be proportionate to the burden associated with activities financed by other EU funding sources. Similarly, the majority of Managing Authorities 
that responded to the survey consider the ISF to be proportionate to the burden associated with activities financed from national sources. 

Cost or benefit 

Citizens/consumers  

Businesses  

Administrations  

Other?  

Quantitative   Comment  

Quantitative   Comment   Quantitative  

Comment  

Quantitative   Comment  

ISF 
funding (overall 
financial envelope) 
funding 
ISF 
(already planned) 
Direct  compliance 
costs 
(adjustment 
costs, 
administrative 
costs, 
charges)  

regulator 

One-off   

One-off   

Recurrent  

Recurrent  

1,93 billion  

1,535 billion 

Approx.40  person-days 
per call 

Between 8 to 30 person-
days per call 

info 

Direct  and  competitive  awards 
applicants, 
to 
(i.e., 
preparing 
and 
calls 
guidelines)134  
Costs for MAs for evaluation of 
proposals/  projects  (screening 

133 Based on information received from Managing Authorities and beneficiaries through the conducted targeted survey. 
134  The  costs  for  Managing  authorities  vary  across  countries: three  replies  reported  that  standards procedures under ISF  require  approximately  15-20 person-days,  while  three  other 
responses reported a 30-40 person-day range and for some cases two replies indicated a range between 60-80 work days. 

102 

 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
Cost or benefit 

Citizens/consumers  

Businesses  

Administrations  

Other?  

Recurrent  

One-off 

Recurrent  

Recurrent  

n/a  

Enforcement  costs 
associated 
(costs 
activities 
with 
the 
to 
linked 
implementation  of 
an  initiative  such 
monitoring, 
as 
and 
inspections, 
adjudication/ 
litigation)  

Indirect 
costs 
(compliance  costs 
indirect 
or  other 
costs 
as 
transaction costs)  
Direct (short-term) 
benefits 

such 

Direct  (mid-term) 
benefits (expected) 

Support  for  groups  such  as 
and 
victims 
whistle-blowers 

crime 

of 

103 

estimates 

Some 
are 
relatively low, such as 2 
man-days or 3 man-days, 
while  other  estimates 
suggest  substantial  time 
commitments  like  100 
person-days  or  90  days 
per year. Many estimates 
fall  in  the  20  to  45-day 
range. 
Wide  range,  from  1-4 
man-days to 10-60 man-
days per project proposal 
30 
Between 
10 
person-days 
(including 
meetings  of  Monitoring 
Committees  and  sub-
committees). 

to 

selecting 

applications) 

and 
under the ISF 
Time spent on reporting per year 
employee 
a 
by 
(beneficiaries) 

full-time 

The  time  spent  by beneficiaries 
for the preparation of one project 
proposal varies significantly. 
Monitoring  Member  States’ 
programme implementation 

These 
costs  are 
also 
incurred 
by  MC 
members 
such 
NGOs 

as 

Between 3 to 70 person-
days 

Auditing 
on-the-spot 
and 
controls  of  project  activities 
(MAs/Audit authorities) 

for 

projects 

exchange 

for 
of 
enhanced 
increased 

Support 
increased 
information, 
cooperation, 
capabilities in the ISF domain 
- 
information 

Increased 

exchange 

and 

of 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
Cost or benefit 

Citizens/consumers  

Businesses  

Administrations  

Other?  

- Enhanced cooperation between 
Member  States,  agencies,  and 
third countries in preventing and 
fighting  serious  and  organised 
crime, including terrorism 
- Increased capabilities to tackle 
internal security threats 

Indirect 
term) 
(expected)  

(long-
benefits 

Increased  internal  security 
in the EU 

104 

 
  
  
  
 
 
 
 
 
 
 
 
ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT 

Call for evidence 

Prior to the start of the evaluation, in line with the Better Regulation Provisions, a call for 
evidence  was  launched  in  the  Have  Your  Say  platform.  Two  contributions  were 
received (135): 

-  An anonymous contributor, from Czechia, proposed the Commission’s to repeal the 
current proposal of the ISF to establish a new definition of the EU Treaty and the ISF 
in the format of a voluntary contribution of the EU and Czech authorities.  

-  A  contributor,  from  Spain,  stated  that  the  ISF  should  be  dedicated  to  reporting  and 

preventing corruption. 

Consultation strategy and methodology 

The  stakeholder  consultation  activities  included  the  call  for  evidence,  (scoping  and 
targeted  interviews,  targeted  surveys,  and  two  Focus  Groups.Table  3  provides  a  short 
description of the targeted stakeholder per each activity and the number of participants. 

Table 3 Consultation activities 

Activities 

Stakeholder targeted 

Timing, stakeholder engagement 

Targeted 
surveys 

Survey  for  National  authorities  within 
Member  States  (Managing  Authorities, 
Delegated  Body,  audit  Authority,  other 
relevant national authority 

Survey  for  beneficiaries,  experts,  civil 
society and businesses 

8th  August  2024-18th  September  2024,  
53  respondents  (27  involved  in  either  both 
ISF-P and ISF or ISF only) 

8th  August  2024  –  18th  September  2024,  
195  respondents    (114  involved  in  either 
both ISF-P and ISF or ISF only) 

Interviews   Stakeholders 

covered  with 

scoping 

June-November 2024 

interviews: 
EU institution (DG HOME): 6 
Member State Managing Authority: 1 

Stakeholder  categories  targeted  via  the 
interview  programme  for  ISF-P  and  ISF 
(combined):136 
European Commission (DG HOME): 4 
Member State Managing Authorities: 5 

Total interviews:   

•  Total  scoping  interviews  for  ISF 

and ISF-P: 5.  

•  Total  targeted  interviews  for  ISF 

and ISF-P: 75.  

•  Targeted  interviews  covering  the 
ISF:  53  (29  as  part  of  the  country 

135 Internal Security Fund (ISF) for 2021-2027 – mid-term evaluation 
136  Section  3.2  of  the  Synopsis  Report  presents  a  breakdown  of  interviews  (intro  three  major  groups). 
Interviews were grouped into targeted interviews for country case studies, targeted interviews for thematic 
case  studies,  and  additional  interviews  for  the  mid-term  evaluation  of  ISF.  For  the  country  case  studies, 

105 

 
 
 
 
 
 
Activities 

Stakeholder targeted 

Timing, stakeholder engagement 

case  studies;  15  as  part  of  the 
thematic 
as 
additional interviews,  as indicated 
in section 3.2) 

studies;  9 

case 

Member  State  Monitoring  Committee 
members: 3 
Beneficiaries of National (ISF-P) / Member 
States’ programmes (ISF): 18 
Beneficiaries of Specific Actions: 5 
Beneficiaries of Union Actions: 19 
Beneficiaries of Emergency Assistance: 4 
and 
Final 
representatives  of  stakeholders  not  directly 
involved: 4 
Underserved groups (i.e. rejected applicants, 
including civil society organisations): 13 

participants 

recipients, 

First  Focus  Group:  25  June  2024,  77 
participants 

Second  Focus  Group:  20  November  2024, 
61 participants 

Focus 
Groups 

EU agencies; 
Relevant  national  authorities  (selection  of 
Responsible/Managing 
Authorities, 
Delegated Authorities, Intermediate Bodies, 
and Audit Authorities in Member States); 
Beneficiaries  of  Emergency  Actions, 
Specific Actions and Union Actions; 
Civil society organisations. 

Results from the consultation activities 

Feedback from targeted surveys 

Two targeted surveys were launched on 7 August and closed on 18September 2024. One 
of the targeted surveys addressed the key Member States competent authorities involved 
in the management, coordination, supervision of the ISF, while the other targeted survey 
aimed  at  targeting  the  Union  Actions  beneficiaries  and  Member  States’  programme 
beneficiaries. The total number of responses amounts to 218 covering both ISF-P and ISF. 
The majority of respondents, 98 (45%), come from law enforcement authorities such as 
police or customs  (Figure  25). There is  also  a notable representation  of NGOs (9%, 19 
respondents)  and other relevant  national  authorities (6%, 13 respondents). The smallest 
groups include businesses (2%, 5 respondents), audit authorities (1%, 3 respondents), and 
international  organisations  (1%,  3  respondents).  Half  of  the  respondents  (50%,  108 
respondents) have dealt with both the 2014-2020 and 2021-2027 programming periods of 
the ISF-P and ISF. A quarter of respondents (23%, 50 respondents) have experience solely 
with the ISF, and only a small proportion of respondents (2%, 4 respondents) did not know 
or refused to answer. 

interviews  covered  the  assessment  of  the  ISF  and  the  ISF-P  (combined).  For  the  thematic  case  studies, 
interviews cover the ISF and the ISF-P separately, unless beneficiaries received funding under both the ISF-
P and the ISF. 

106 

 
 
 
 
 
 
 
 
Figure 25 - Breakdown of responses by stakeholder group 

0

20

40

60

80

Law enforcement authority (e.g., police, customs)

Responsible Authority / Managing Authority

Research organisation, university, think tank or other…

Non-governmental organisation

Other relevant national authority (please specify) not acting…

Other (please specify)

Company/ Business

Don’t know/refuse to say

Intermediate Body / Delegated Body

Audit Authority

International Organisation

45%

15%

11%

9%

6%

5%

5
2%
5

2%

4
2%
3
1%
3

1%

32

24

19

13

11

100

98

Count

Percentage

The largest number of respondents are located in Italy, with 31 respondents (15%). France 
follows with 18 respondents (9%), while Belgium ranks third with 13 respondents (6%). 
Countries like Finland (11 respondents, 5%) and Bulgaria (10 respondents, 5%) are also 
relatively  well-represented.  Countries  with  fewer  responses  include  Latvia,  Ireland, 
Luxembourg,  Slovakia,  and  Slovenia,  with  only  1%  or  2%  of  total  respondents.  This 
distribution demonstrates a balanced representation across several EU Member States, but 
with a slight concentration in southern and western European countries. Italy, France, and 
Belgium  collectively  account  for  30%  of  the  total  responses,  indicating  significant 
participation from these regions (Figure 26).  

Figure 26 -  Breakdown of responses by country of origine  

31

35

30

25

20

15

10

5

0

18

13

11

en=218e 

10 10 10

9

9

8

8

8

8

8

6

5

5

5

4

4

4

3

3

2

2

2

Data shows that most respondents are beneficiaries, benefitting either from Union Actions 
or  projects  under  Member  States’  programmes  (Figure  27).  40%  of  respondents  (87 
respondents) identified themselves as beneficiaries of projects  funded by Union actions 
within  the  ISF  and  both  ISF-P  and  ISF.  Another  28%  (60  respondents)  have  been 
beneficiaries of projects funded by Member States’ programmes. 24% (53 respondents) 

107 

 
have been involved in the management, coordination, or supervision of the ISF and both 
ISF-P and ISF. A smaller proportion of respondents indicated  familiarity with the Funds 
from a professional or personal capacity (1%, 4 respondents combined).  

Figure 27 -  Breakdown of responses by geographic scope of business 

Role

0%

5%

10% 15% 20% 25% 30% 35% 40% 45%

40%

28%

24%

I am a beneficiary - I have implemented projects funded by Union
actions (a call for proposal launched by the European Commission)
within the ISF and/or ISF-P

I am a beneficiary  - I have implemented projects funded by the 
Member States’ programme (calls for proposals launched by a 
managing authority in my country under ISF and/or ISF-P)

I have been involved in the management/coordination/supervision of
the ISF and/ or ISF-P

Other (please, specify)

5%

I am familiar with the Fund(s) in my professional capacity (e.g.,
practitioner, expert, researcher)

I am familiar with the Fund(s) from my work for EU agencies, bodies
and offices or international organisations

1%

1%

I am familiar with the Fund(s) in my personal capacity (e.g. expert,
researcher)

0%

Percentage

N=218 

The largest group of respondents, 44% (64 respondents out of 147), participated in Fund 
actions as representatives of the police. This is followed by staff of ministries or national 
agencies  at  12%  (17  respondents)  and  NGOs  at  12%  (17  respondents).  Academia  or 
researchers  also  make  up  a  significant  portion,  at  11%  (16  respondents).  Other  groups, 
such  as  private  entities  (3%,  5  respondents),  border  police  (3%,  4  respondents),  and 
customs (2%, 3 respondents), represent smaller portions of the respondents. 

Figure 28 Breakdown of responses by organisation type 

Representative of...

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

Police

NGO

Other (please, specify)

Local and/or regional authority

Customs

N=214 

Percentage

108 

 
 
 
Survey for Competent authorities 

The survey targeting Member State Competent authorities gathered 53 responses from 23 
Member States.  

Effectiveness 

Actions  promoting  collaboration,  knowledge  sharing  and  operability  are  seen  as  the 
most effective in enhancing the EU’s internal security (66%, 35 respondents indicating “to 
a large extent”). Exchange, training, and education of staff and experts is viewed as highly 
effective, with 53% (28 out of 53) indicating it was effective "to a large extent.". Efforts 
related  to  analytical,  monitoring  and  evaluation  activities  as  well  as  actions  concerning 
third countries are also recognised for their contribution, though to a much lesser degree 
(respectively 19%, or 10 out of 53 and 17%, or 9 out of 53, indicating relevance to a large 
extent). 

the 

the  programming, 
involvement  of  relevant  partners  during 
As  concerns 
implementation,  monitoring  and  evaluation  of  the  Programme,  ensuring  the active 
participation of partners during the implementation was considered as a major challenge 
to a large extent  (19% of respondents, 10 out of 53). 

While the control systems and anti-fraud mechanisms are viewed positively to some 
extent, there is a considerable proportion of respondents unsure about some aspects of this 
mechanism. Coordination with relevant bodies is seen as effective "to a large extent" by 
19% (10 respondents), and follow-up actions on fraud detection received similar feedback, 
with 35% indicating effectiveness to a large or to some extent (24 out of 53). While fraud 
prevention training is seen as adequate by 19%, many respondents (10) indicate challenges 
"to a limited extent." The majority of respondents (64%, 34 out of 53) believe that effective 
fraud  detection  mechanisms  have  been  established  in  their  country,  i.e.,  there  are  clear 
procedures for reporting fraud and irregularities have been established. The timelines of 
reporting requirements are considered adequate, with 64% of respondents indicating they 
are  effective  to  a  large  or  to  some  extent  (31  out  of  53).  Among  those  countries  that 
benefitted from EMAS, 26% feel it was effective "to a large extent" (5 out of19 responses) 
while 21% see it working "to some extent” (54 out of 19 responses).  

Efficiency  

Respondents  generally  perceive  an  increased  administrative  burden  with  the  current 
reporting  requirements  under  the  CPR.  36%  (19  respondents  out  of  53)  and  45%  (24 
respondents  out  of  53)  agree  "to  a  large  extent"  that  the  obligations  on  output/result 
indicators  and  financial  data  reporting  create  too  much  burden.  There  is  a  noticeable 
challenge in defining output and result indicators, with 32% (17 respondents out of 53) 
finding  it  difficult  "to  a  limited  extent",  while  25%  believed  that  it  was  not  at  all 
straightforward to establish a methodology for the performance indicators, which included 
criteria for selection output indicators, data/evidence used and factors potentially affecting 
the achievement of milestones and targets.  

Respecting timelines emerged as the most significant issue in managing Member States 
Programmes and related application procedures, with 64% of respondents (28 out of 53 
respondents) finding it difficult to adhere to deadlines to some extent and to a large extent 
jointly, particularly concerning reporting and program management. Second, adhering to 
reporting requirements and timelines also proved challenging, with 53% of participants 

109 

 
(23 out of 53 and 24 out of 53, respectively) reporting difficulties, while 45% (22 out of 
53)  struggled with payment management. Lastly, providing support to beneficiaries and 
using  digital  platforms  were  notable  issues.  A  substantial  40%  (21  out  of  53)    of 
respondents  indicated  challenges  in  offering  adequate  support  to  beneficiaries,  with  the 
same percentage reporting obstacles in using the digital platform for applications (21 out 
of 53), and 23% of respondents (12 out of 53), finding this challenge relevant to a large 
extent.  

Figure 29 - Degree to which the following points represented a challenge in managing Member 
States Programmes and related application procedures  

Designing direct and competitive award

13%

21%

Contractualization

4%

30%

40%

38%

9%

17%

9%

19%

Respecting the timelines

4%

25%

43%

21%

8%

Use of the digital platform for application

Providing sufficient support to beneficiaries

15%

15%

28%

30%

Adhering to reporting requirements

6%

30%

Adhering to reporting timelines

8%

28%

19%

26%

11%

30%

15%

9%

36%

36%

17%

11%

17%

11%

 Managing payments

13%

26%

36%

9%

15%

0%

50%

100%

Not at all

To a limited extent

To some extent

To a large extent

Don't know

The survey showed different numbers of man-days for each activity performed by MAs. 
For direct and competitive awards (i.e., info to applicants, preparing calls and guidelines, 
contractualization),  3  respondents    (14%,  3  out  22  replies)    reported  that  standards 
procedures require approximately 15-20 man-days, while three other respondents (14%, 3 
out of 22 replies) reported 30-40 man-day range, while two respondents (9%, 2 out of 22 
replies) indicated a range between 60-80 work days. For the evaluation of proposals and 
projects (e.g., screening and selecting applications), overall, the estimates reflect a mix of 
moderate and significant time commitments, with most tasks requiring between 8 to 30 
man-days (46%, 8 out of 22 replies).  

The estimates for monitoring program implementation indicate that most tasks (according 
to 8 respondents out of 22, 36%) require between 10 to 30 man-days, including the time 
allocated  for  meetings  of  monitoring  committees  and  sub-committees.  For  reporting 
activities, the majority of FTEs spend approximately 55 man-days. Overall, the estimates 
indicate  that  reporting  under  ISF  typically  requires  between  5  to  55  man-days  (12 
respondents out of 22 replies, 55%). With regards to the average time spent by full-time 
employees on auditing and on-the-spot controls of project activities, Managing Authorities 
reported estimates ranging between 3 to 70 man-days (13 out of 22, 59%).  

The  majority  of  Managing  Authorities  consider  the  administrative  burden  of  the  ISF 
proportionate to its benefits (62%, or 33 out of 53) and to the burden associated with 
other  EU  funding  sources  (55%,  or  29  out  of  53).  In  contrast,  a  significant  portion  of 

110 

 
 
 
Managing Authorities view the ISF's burden as proportionate to that of activities funded 
solely from national sources only to a limited extent or not at all (38%, or 20 out of 53).  

The most common approach typically followed by the Managing Authorities to gauge the 
cost-effectiveness of the projects selected for support is the assessment of market prices 
for  similar  products  and  services  (28  out  of  94  responses,  30%)137,  followed  by  the 
estimates from prospect beneficiaries (22, 23%) and the benchmarking with the previous 
programming period (21 out of 94, 22%). 

Relevance 

Responses showed that 17% of respondents involved in managing and coordinating the 
fund  (9  out  of  53)  believed  that  the  Fund  had  been  flexible  to  a  large  extent  in 
responding  to  crises.  Another  38%  (20  out  of  53  respondents)  felt  that  the  Fund  was 
flexible "to some extent." Another notable proportion (25%, 13 respondents of 53) felt the 
Fund was flexible "to a limited extent," while only 2% (1 respondent) felt it had not been 
flexible  at  all.  This  may  reflect  that  it  is  still  early  in  the  2021-2027  period,  or  that 
respondents  have  not  yet  seen  the  full  impact  of  the  Fund’s  capabilities  to  respond  to 
emerging challenges. 

Regular  dialogue  and  consultation  activities  with  stakeholders  and  potential 
beneficiaries (if coming from channels other than the Monitoring Committee) is the most 
common  mechanism  to  ensure  that  the  operations  funded  by  the  Funds  best  match  the 
evolving needs in the Member States (27 out of 113 responses, 24%)138, followed by the 
mid-term review of the ISF-P as a source to update the needs assessment (20 out of 113 
responses, 18%), and the regular feedback from the Monitoring Committee (19 out of 113 
responses, 17%)139. 

The Funds’ activities sufficiently address the needs of law enforcement authorities with 
respect to their role in internal security matters to a large extent for 74% of respondents 
(39 out of 53). Similarly, it addresses the needs of relevant union agencies and bodies to a 
large extent for 25% of respondents (13 out of 53), but with another significant portion of 
respondents indicating to some extent (36%, 19 out of 53). For 28% of respondents (15 out 
of 53), the needs of the private sector are addressed to a limited extent, with 17 respondents 
(32%, 17 out of 53), believing that the needs are not addressed at all.  

Respondents who have been involved in the management, coordination, or supervision of 
the  ISF  generally  favour  maintaining  the  current  thresholds  for  most  areas.  Some 
support  for  slight  increases  is  expressed  for  thresholds  related  to  operating  costs  and 
information exchange. A significant portion of respondents support a slight increase (18 
respondents  out  of  43  replies,  42%)  or  prefer  maintaining  the  current  threshold  (13 
respondents out of 43, 35%) for operating support in the 21-27 period. The majority favour 
maintaining the threshold (16 respondents out of 37, 43%), while a few support a slight 
increase  (10  respondents  out  of  37,  27%)  of  the  minimum  of  10%  for  improving  and 
facilitating the exchange of information in the 21-27 period.  

More than half of the respondents (58%, 20 respondents out of 38 replies) believed that 
the maximum of 15% for transfer of allocation between specific objectives in the 21-27 

137 Multiple choice question. 
138 Multiple choice question. 
139 Multiple choice question. 

111 

 
 
period  should  be  increased.  Regarding  the purchase  of  Equipment  (35%  for  the 21-27 
period), 14 out of 30 replies(478%) preferred the current threshold, and a smaller number 
advocated for a slight increase (7 respondents out of 30, 23%).   

Coherence 

Among the most common measures implemented during the programme  designing and 
implementation phase to ensure coherence with other programmes funded by EU resources 
in  similar  areas  of  work,  the  coordination  with  other  EU-funded  initiatives  (e.g., 
exchanges  with  coordinators of other funds  and  between relevant  ministries) stood out, 
with  38%  of  Managing  Authorities  indicating  it  (33  out  of  88  replies),  followed  by 
assessing  interventions  with  similar  objectives  (22  out  of  88  replies,  25%),  and  the 
establishment  of  a  Monitoring  Committee  or  inter-institutional  group  (22  out  of  88, 
25%). 

According to responses from the Managing Authorities, most respondents (47%, or 25 out 
of 53) indicated that national interventions complement ISF activities to some extent, 
while 28% (15 out of 53) reported a large extent of complementarity. Similarly, actions 
organized  by  the  Asylum,  Migration  and  Integration  Fund  (AMIF)  and  the  Integrated 
Border Management Fund (IBMF) were seen to complement ISF activities to some extent 
by 36% of respondents (19 out of 53) and actions supported by the Border Management 
and  Visa  Instrument  (BMVI)  and  the  Instrument  for  Financial  Support  for  Customs 
Control Equipment were noted as complementary to some extent by 36% of respondents 
(19 out of 53).  

A significant share of respondents observed that the Cohesion Policy Funds, particularly 
the European Regional Development  Fund (ERDF),  complemented ISF activities to a 
limited  extent  (25%,  or  13  out  of  53),  while  5%  (10  respondents)  indicated  no 
complementarity.  Similarly,  actions  from  the  Citizens,  Equality,  Rights  and  Values 
Programme  and  the  Justice  Programme  and  Horizon  Europe  were  also  seen  as 
complementing ISF activities to a limited extent by 25% (13 out of 53) and 30% (16 out 
of 53), respectively. The Digital Europe Programme was likewise noted to complement 
ISF activities to a limited extent by 28% of respondents (15 out of 53).  

For actions organised by the InvestEU Programme and the Technical Support Instrument, 
a large portion of  respondents indicated no complementarity with ISF activities (25%, or 
13 out of 53, and 21%, or 11 out of 53, respectively). Similarly, actions from the rescEU 
reserve were seen as not complementary by 25% of respondents (11 out of 53).  

Finally,  a  significant  number  respondents  observed  no  complementarity  between  ISF 
activities  and  actions  from  both  the  Instrument  for  Pre-accession  Assistance  and  the 
Neighbourhood, Development and International Cooperation Instrument (NDICI), at 23% 
(12 out of 53) and 25% (13 out of 53), respectively.140 

EU added value 

For more than half of the Managing Authorities (57% of the respondents, 30 out of 53) the 
projects  funded  under  the  ISF  and  or  ISF-P  (e.g.  for  improving  cooperation  and 
coordination  between  different  Member  States,  exchange  of  information,  and  joint 
operations) would not have been carried out without the support of the Fund. On the 

140 Responses indicating “I don’t know” were excluded from the distribution of responses. 

112 

 
 
other hand, 38% of the Managing Authorities (20 out of 53) believe these projects would 
have been carried out without the support of the Fund., but on a smaller scale of quality, 
for example, involving fewer Member States or with fewer participants. 

The  exchange  of  best  practices  is  the  most  common  choice  as  the  main  value  added 
brought by the Fund according to Managing Authorities (45 responses out of 212, 21%), 
followed by the increased operational cross-border cooperation (41 responses out of 
212,  19%),  and  the  improved  mutual  trust  and  confidence  between  law  enforcement 
authorities and other national authorities of Member States (34 responses out of 212, 16%). 
141The establishment of public-private partnerships (14 out 212, 6%) figured as the least 
selected option among Managing Authorities. 

Survey for beneficiaries  

The survey received responses from 147 beneficiaries, both implementing projects funded 
by the Union actions (87 out of 147, 59%) and the Member States’ programmes (60 out of 
147, 41%) under ISF-P and ISF, where respondents represented all Member States except 
for Luxembourg. Considering beneficiaries of Union Actions and Member States actions 
that  were  funded  under  eitherboth  ISF-P  and  ISF  or  ISF  only,  the  total  number  of 
beneficiaries is 100 (47 beneficiaries of Union Actions programmes, and 53 beneficiaries 
of Member States’ programmes). 

Effectiveness 

Actions promoting collaboration, knowledge sharing and interoperability are seen as 
the most effective in enhancing the EU’s internal security according to beneficiaries (63%, 
93  beneficiaries  indicating  “to  a  large  extent”  out  of  147).  Exchange,  training,  and 
education of staff and experts is viewed as highly effective, with 53% (78 respondents out 
of 147) indicating it was effective "to a large extent.". Similarly, actions improving police 
cooperation and coordination, including with relevant Union bodies, are also viewed by 
beneficiaries as highly effective (79 out of 147, 54%). 

Beneficiaries  pointed  out  that  the  ISF-funded  activities  resulted  to  a  large  extent  in 
increased  knowledge  and  skills  of  training  participants  in  the  area  of  crime 
prevention/forensic  field    (59  out  of  147,  40%),  to  a  growing  number  of  stakeholders 
involved in the sharing of information, study and data collection (66 out of 147, 52%) and 
improved sophistication of vigilance tools, improved routines and recommended method 
support in response to crime events (44 out of 147, 30%).  

The ISF-funded actions implemented by beneficiaries resulted in increased communication 
between information systems and coordination between authorities for the largest share of 
respondents (44%, 66 out of 147), to increased capacity and skills of competent authorities 
for responding to internal security related accidents and incidents (59 out of 147, 40%). 
These  actions  ultimately  contributed  to  enhancing  the  capacity  of  Member  States  to 
manage  effectively  security-related  risks  and  crises  and  to  protect  people  and  critical 
infrastructure against terrorist attacks and security-related incidents.  

According  to  a  majority  of  beneficiaries  (51%,  or  24  out  of  47  responses),  the  current 
indicators  effectively  capture  their  projects'  benefits  to  a  large  extent.  However,  they 
identify several opportunities for improvement in the evaluation framework. Beneficiaries 

141 Multiple choice question. 

113 

 
 
suggest enhancing the system by giving project teams more flexibility to define success 
metrics  aligned  with  their  specific  objectives.  They  particularly  emphasise  the  value  of 
longer  assessment  periods,  especially  for  specialised  projects  such  as  financial  crime 
investigation training, to better measure sustained impact. Additionally, they recommend 
developing  more  targeted  indicators  for  different  project  types,  such  as  infrastructure 
upgrades  and  technology  implementations,  to  provide  more  meaningful  insights  into 
project value and effectiveness.  

The majority of beneficiaries implementing both shared management and Union Actions 
projects under ISF-P and ISF or ISF only indicated that reporting requirements are clear 
and comprehensive “to a large extent” according to 50% of respondents (50 replies out 
of 100 responses) and “To some extent” according to 34% of respondents (34 replies out 
of 100 responses).  

The  majority  of  beneficiaries,  across  both  shared  management  and  Union  Actions, 
expressed that the timelines for reporting requirements were generally adequate and 
deadlines allowed for sufficient time for comprehensive reporting, ensuring that the 
necessary information could be gathered and reviewed. Specifically, according to 56% (56 
respondents out of 100 responses) of beneficiaries, the timelines were adequate “to a large 
extent” according to 58% and “To some extent” according to 27% (27 out of 100 replies) 
of respondents.  

Efficiency 

67%  of  beneficiaries  (99  out  of  147)  pointed  out  that  the  ISF  is  proportionate  to  its 
benefits, and more than half of the respondents (52%, 76 out of 147) believe that the Fund 
is  proportionate  to  the  burden  associated  with  other  EU  fundings  (with  a  significant 
portion  not  able  to  answer  this  question,  44%,  or  65  out  of  147)  and  with  national 
interventions (50%, 73 out of 147). 

Beneficiaries of actions funded by Member States’ programmes see the coordination with 
the Responsible authority timely and effective (37 out of 47, 78%) and the beneficiaries 
implementing projects funded by Union Actions view the coordination with the European 
Commission  as  timely  and  effective  (42  out  of  53).  Furthermore,  most  beneficiaries  of 
Union Actions and member States’ Actions that were funded under both ISF-P and ISF or 
ISF only believe that the information regarding available support was clear and accessible 
in an easy manner (67 out of 100) and that the length and complexity of the procedures to 
access the available support were adequate (67 out of 100).  

In  terms  of  efficiency  of  time  spent  by  beneficiaries  for  the  preparation  of  one  project 
proposal, there is a wide range of estimates, indicating significant variability depending 
on the size and complexity of the project. A large share of respondents' estimates fall within 
the 10 to 60 man-days range  (23 responses out of 52, 44%), where some respondents 
mention  more  specific  roles  or  projects,  such  as  25  days  for  specific  interdepartmental 
cases,  or  60  days  (for  project  Coordinator)  plus  45  days  (staff)  for  complex  project 
leadership tasks.  

The responses for the time spent on reporting per year by a full-time employee also vary, 
with the majority falling in the 20-45 day range (18 out of 52, 35%). Larger and more 
complex estimates were given for cases involving larger teams or more extensive reporting 
requirements. For instance, 3 people full-time for 4 months, and 1 person for a year in a 
large consortium with over 10 partners. 

114 

 
Relevance 

The majority of beneficiaries agree to  a large  extent that the Fund has been  flexible in 
responding to new challenges and crisis situations, which emerged in the EU during its 
implementation  (39%,  57  out  of  147).  The  majority  of  beneficiaries  pointed  out  that 
organised crime and terrorism and radicalisation are some of the most important challenges 
for safeguarding the internal  security of the EU  (119 out  of 147 responses each, 81%). 
Challenges like money laundering and firearm trafficking are seen as critical but receive 
slightly less emphasis, with 57% (84 respondents) and 53% (78 respondents) rating them 
as important “to a large extent”. 

According to beneficiary survey responses, the Funds effectively meet internal security 
needs,  but  the  level  of  support  varies  significantly  across  different  groups.  Among 
beneficiaries, 63% (92 out of 147) indicate that law enforcement authorities' needs are well 
addressed. For Union agencies and bodies, 33% of beneficiary respondents (48 out of 147) 
report their needs are met to a large extent. However, beneficiaries indicate lower support 
levels for civil society and private organizations - only 25% (37 out of 147) and 13% (19 
out of 147) respectively report their needs being met to a large extent. 

Coherence 

Beneficiaries of Union Actions and Member States’ programmes indicated that national 
interventions complement the activities provided by the ISF to a large extent (25 each, 
out of 147, 34%).142 Similarly, most beneficiaries indicated that actions organised by the 
AMIF and the BMVI complement to a large extent ISF-funded initiatives. 

EU added value 

More than half of the Union Actions beneficiaries believe that the projects funded under 
the ISF would not have been carried out without the support of the Fund (75 out of 
147, i.e. 51%), while 36% of respondents (54 out of 147) pointed out that projects would 
have  been  carried  out  but  in  a  smaller  scale  or  quality,  i.e.,  involving  fewer  Member 
States or fewer participants.  

Also among Union Actions beneficiaries, the survey shows that the majority of responses 
(117 out of 514, 23%) see the exchange of best practices as the main value added by the 
Fund. Increased cross-border cooperation (95, 18%), fostered innovative solutions to 
tackle  internal  security  threats  (84,  16%)  and  improved  mutual  trust  and  confidence 
between law enforcement authorities and other national authorities of Member States (79, 
15%) also figure as prominent results brought by the Fund143.  

Summary of the interviews 

In line with the stakeholder consultation strategy, the study team conducted an extensive 
interview  programme  (simultaneously  covering  the  ISF  and  ISF-P).  Interviews  were 
grouped into: 

•  Targeted interviews for country case studies; 

142 With the exception of “I don’t know”.  
143 Multiple choice question. The total number of respondents is 100. 

115 

 
 
•  Targeted interviews for thematic case studies; 

•  Additional  interviews  for  the  mid-term  evaluation  of  ISF  (to  address  data  gaps 

faced during the research and following the Interim Report).  

the 

selected  depending  on 

The study team selected the stakeholders to be interviewed in close cooperation with the 
European  Commission  and  developed  the  interview  questionnaires  jointly.  The 
questionnaires  were  targeted  to  relevant  stakeholder  categories  and  included  questions 
covering the ISF (and the ISF-P). The interviews were semi-structured, and appropriate 
interviewees'  backgrounds  and 
questions  were 
knowledge.nnTargeted  interviews  for  country  case  studiesnThe  objective  of  these 
interviews was to collect country-specific insights on what has worked, and what has not 
with  the  implementation  of  the  ISF/ISF-P  at  the  Member  State  level  in  five  selected 
Member States (Croatia, Germany, Latvia, Netherlands, and Spain). They also served to 
identify  opportunities  and  challenges  in  the  implementation  of  the  ISF,  as  well  as 
recommendations  for  future  implementation.  For  the  country  case  studies,  interviews 
covered  the  assessment  of  the  ISF  and  the  ISF-P  (combined).nIn  total,  the  study  team 
conducted  29  interviews  with  various  stakeholder  groups  as  part  of  the  country  case 
studies, including six interviews for Croatia, 11 interviews for Germany, three interviews 
for Latvia, five interviews for the Netherlands, and four interviews for Spain. nTargeted 
interviews for thematic case studies  nThe objective of these interviews was to assess how 
each component of the ISF contributed to the ISF's objectives and, in particular, to identify 
both  positive  results  and  challenges  the  beneficiaries  of  funding  have  faced  in 
implementing their supported activities. For the thematic case studies, interviews cover the 
ISF and the ISF-P separately, unless beneficiaries received funding under both the ISF-P 
and the ISF.  In total, the study team conducted 37 interviews with various stakeholder 
groups as part of the thematic case studies and in particular: 17 for the Union Actions case 
study (four for ISF only); six for the Specific Actions case study (these covered ISF only); 
five  for  the  Emergency  Assistance  case  study  (two  for  ISF  only  );  and  nine  for  the 
horizontal principles case study (three for ISF only).nAdditional interviews for the mid-
term  evaluation  of  ISFnThese  interviews  aimed  to  address  any  information  gaps  that 
became evident after submitting the Interim Report, and the study team chose to dedicate 
the interviews to consulting underserved groups. In close cooperation with the European 
Commission, the study selected stakeholders who presented funding applications that were 
rejected to discuss their experience when responding to calls for proposals launched under 
two components of the ISF: Union Actions and Specific Actions. In addition, the study 
team  organised  interviews  with  civil  society  organisations  (which  received  funding  or 
submitted  unsuccessful  funding  applications)  to  discuss  the  extent  to  which  the  ISF 
promoted and encouraged civil society's active and meaningful involvement in developing 
and  implementing  EU  security  policies.  In  total,  9  interviews  were  conducted.  nThe 
following  sections  present  an  overview  of  stakeholders’  views  on  the  ISF's  relevance, 
effectiveness, efficiency, coherence, and EU added value.n,Effectiveness 

When asked about  the effectiveness  of the  ISF, many consulted stakeholders (20) were 
either positive about the extent to which the Fund is on track to achieving its objectives or 
did  not  expect  challenges  that  might  hinder  the  achievement  of  objectives.  Some 
stakeholders  (four,  Member  States’  competent  authorities)  reported  delays  with  the 
implementation  of  ISF-funded  projects,  with  two  stakeholders  attributing  this  delay  to 
bureaucracy and/or procurement challenges.   

116 

 
Several stakeholders from different groups (seven, across groups)  raised concerns about 
the  monitoring  and  evaluation  frameworks  and  the  inclusion  of  quantitative  indicators, 
considering  that  certain  impacts  of  the  projects  might  be  difficult  to  assess  from  a 
quantitative point of view. For the ISF’s capacity to engage a wide range of stakeholders, 
several interviewees expressed challenges in involving civil society organisations, or the 
private sector . Few national authorities argued that projects under the ISF are mainly for 
the public sector, considering the exclusive jurisdiction of national authorities over certain 
policy fields; these security topics often require a certain degree of confidentiality, and that 
data information cannot easily be shared with other stakeholder categories.  

Many  interviewees  (beneficiaries)  were  positive  about  how  horizontal  principles  were 
respected or promoted in ISF-funded projects. However, two of them indicated that the 
effectiveness of horizontal projects might be challenging to measure. At the same time, 
one  raised  doubts  about  how  to  include  certain  horizontal  principles,  such  as  non-
discrimination,  in  these  projects  (e.g.,  when  receiving  funding  to  acquire  specialised 
equipment).    

Efficiency 

The efficiency of the ISF was a topic of particular interest among consulted stakeholders, 
with many considering that the requirements for projects’ monitoring and reporting might 
impact the efficiency of the ISF.  

In  relation  to  the  Member  States’  Programmes,  the  overarching  view  of  consulted 
stakeholders  indicated  that,  while  the  ISF  has  progressed  in  certain  areas,  particularly 
through digital solutions that eased administrative processes, challenges remain in terms 
of coordination, administrative burden, and alignment with national contexts.  

Some stakeholders identified barriers to supporting cost-effective projects. These manifest 
in  the  form  of  overly  bureaucratic  national  systems,  fragmented  coordination  among 
relevant  actors  due  to  the  multi-layered  structure  of  the  Fund  (specifically  for  Specific 
Actions),  and  beneficiaries  sometimes  being  allocated  the  handling  of  too  complex 
coordination  tasks,  which  they  are  not  well  equipped  to  manage,  among  others,  due  to 
differences  in  the  language  and  legal  systems.  These  issues  might  lead  to  unnecessary 
labour  costs,  often  seen  as  doubling  the  cost  relative  to  the  benefit.  Inflation  was  also 
considered as having negative effects on the projects’ costs. 

Few  consulted  stakeholders  (Member  States’  competent  authorities)  perceived  that  the 
application  of  the  Common  Provisions  Regulation  (CPR)  brought  additional  burdens, 
particularly in the context of reporting and monitoring requirements. Specific examples 
include  the  detailed  reporting  by  codes,  which  adds  complexity  to  project  oversight. 
Despite  burdensome  reporting  requirements,  the  shift  to  digital  reporting  has  been  a 
positive  change,  simplifying  processes  compared  to  the  previous  programming  period. 
From  the  perspective  of  beneficiaries  of  Member  States’  Programmes,  the  preparation 
process  was  reportedly  smooth  after  the  initial  learning  curve,  and  many  appreciated 
collaboration  with  Managing  Authorities,  which  helped  navigate 
the  different 
requirements. However, some reported frustration with the funding process in relation to 
implementation (e.g. unclarities on costs that can be reimbursed). 

In  relation  to  Specific  Actions,  the  respondents  with  previous  experience  with  similar 
national projects and Union Actions found the administrative burden to be comparable but 
financial  reporting  was  described  as  particularly  time-consuming.  Some  stakeholders 

117 

 
(national  authorities)  further  indicated  a  lack  of  experience  in  implementing  Specific 
Actions  projects,  with  beneficiaries  needing  extensive  assistance,  leading  to  delays. 
Incorporating Specific Actions into a national programme is reportedly too lengthy and is 
not  worth  it  for  smaller  projects  due  to  the  administrative  burden.  However,  once  the 
project  is  incorporated,  project  reporting  and  managing  are  not  considered  to  be  more 
difficult  than  shared  management.  Sufficient  administrative  capacity  is  also  lacking  in 
some national contexts. A recurrent suggestion was for simplifying the implementation of 
Specific  Actions,  e.g.  with  Specific  Actions  to  be  managed  directly  by  the  European 
Commission  (similar  model  as  per  Union  Actions)  or  introducing  a  more  flexible 
mechanism  to  better  align  Specific  Actions    with  political  priorities  during  the  entire 
programming period. 

On the efficiency of Union Actions, stakeholders flagged the resource efficiency of how 
the ISF supports leveraging existing platforms and solutions, such as Europol’s sharing 
platform,  thereby  avoiding  duplications.  Further  cost-efficiency  was  flagged  through 
supporting  measures  that  limit  travel,  and  by  focusing  on  developing  long-term 
cooperation frameworks. At the same time, in relation to travel, some beneficiaries claimed 
that the limitation on reimbursement from the ISF for flight and general travel costs inhibits 
police forces.  In addition, it is reportedly not always clear how KPIs about activities match. 
For the functioning of the monitoring committees, despite improvements compared to the 
ISF-P, some stakeholders reported the lack of real opportunities to evaluate the projects 
substantively, with the performance report and program changes as being mere formalities, 
with  monitoring  committee  members  approving  them  without  in-depth  consideration. 
Controls  and  rigorous  audits  were  found  to  be  burdensome  mainly  due  to  the  multiple 
reported duplications by different authorities in the process.   

Some civil society organisations stressed the need to rethink the co-funding element as it 
has  become  increasingly  difficult  for  smaller  organisations  to  co-fund  10%.  They  are 
running out of grants, and it is not possible to use grants to co-fund others. Another reported 
problem relates to indirect costs, with 7% found to be very low. Lastly, it was noted that 
the  European  Commission  would  need  to  consider  whether  funding  always  goes  to  the 
same parties. A stakeholder raised that big applicants are constantly winning the funding, 
and one should question if certain organisations need to receive funding several times – 
leaving almost no chance for smaller organisations to compete. 

Relevance 

Most interviewed stakeholders were positive regarding the relevance of the ISF, as it is 
generally considered capable of addressing both current needs and adapting to evolving 
ones. This was considered true for both management modalities (shared management and 
direct/indirect management). 

Many interviewees (14) thought that the ISF succeeded in addressing evolving needs and 
highlighted that the Member States’ programmes reflected the national needs while in line 
with  the  EU  priorities.  Despite  the  enhanced  adaptability,  some  (three,  one  beneficiary 
under the Member States’ programmes and two from the underserved groups) interviewees 
were critical due to a perceived gap between policy and needs of actors operating on the 
ground , with the risk that some calls for proposals do not fully capture the actual needs in 
the key policy fields. Others, (three beneficiaries under the Member States’ programmes) 
reported  challenges  resulting  from  geopolitical  events,  such  as  Russia’s  invasion  of 
Ukraine and inflation, which affected the implementation of projects.  

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Some  stakeholders  (four,  one  beneficiary  of  Union  Actions  and  three  Member  States’ 
competent authorities) particularly appreciated the ISF's increased adaptability compared 
to  the  ISF-P  or  other  funding  frameworks.  Two  of  them  reported  that  Specific  Actions 
allowed  for  flexible  adjustments  and  additional  resources,  and  others  advised  increased 
flexibility of the ISF to the evolving needs in the security landscape. 

Coherence 

Most  consulted  stakeholders  indicated  that  the  ISF  aligns  with  other  relevant  policy 
initiatives and maintains coherence with other EU funds and external actions. In the context 
of  Member  States’  Programmes,  synergies  were  pointed  out,  for  instance,  with  the 
European Regional Development Fund (ERDF) in the area of fire rescue service, BMVI 
for certain equipment, Resilience and Recovery Mechanism in the context of the judiciary, 
Cohesion funds and the Erasmus+ programme for educational initiatives. In this context, 
however, a beneficiary flagged that the topics covered under ISF calls are also often seen 
under Horizon Europe as well in the Horizon 3 FCT calls, and that cooperation could be 
increased between different parties working on similar calls developing the same tools and 
rather complement each other’s work.  At the same time, other beneficiaries mentioned 
how 
increase 
complementarity and overall cohesion.  

the  sequencing  of  opportunities  under  different  EU  funds  can 

In relation to Union Actions, stakeholders (beneficiaries) believed that the ISF aligns with 
other initiatives by complementing existing law enforcement platforms and participating 
in  other  similar  initiatives,  such  as  Europol’s  initiatives.  It  ensures  coherence  through 
active collaboration and information exchange.  

The  ISF-funded  Specific  Actions  allowed  the  beneficiaries  to  focus  more  on  solving 
operational  challenges  and  issues  involved  in  full-scale  deployment.  As  such,  Specific 
Actions were also reported as generally coherent with Union Actions. For the coherence 
of the Specific Actions, another example concerns the work under EMPACT, where the 
beneficiaries know the projects well and exchange information frequently, which fosters 
collaboration and overall coherent action during implementation. AMIF was flagged as the 
main  complementary  funding  source  by  some  beneficiaries.  Lastly,  some  stakeholders 
(final  recipients)  reported  a  lack  of  clarity  around  using  multipurpose  equipment,  for 
instance,  using  ISF-funded  equipment  for  BMVI  objectives.  One  underlined  that  the 
sharing of equipment for multiple purposes is not feasible.  

EU added value 

Overall, consulted stakeholders agreed that ISF generated EU added value, especially by 
enhancing  cross-border  law  enforcement  collaboration  and  improving  the  exchange  of 
information across Member States, particularly on cyber threats. The ISF provided crucial 
support to projects that would not have been possible using exclusively national funding 
and contributed to the overall internal security of EU and its Member States. 

Some  stakeholders  (altogether  eight,  four  beneficiaries  under  the  Member  States’ 
programmes,  two  Specific  Actions  beneficiaries  and  two  Union  Actions  beneficiaries) 
appreciated ISF funding for enabling the acquisition of specialised equipment, increased 
training  (including  on  unexplored  issues),  network  building,  and  knowledge-sharing 
the  Member  States’ 
opportunities.  Other  stakeholders  (five  beneficiaries  under 
programmes) noted that the ISF helped to strengthen capacity building to manage internal 
security  challenges  and  promoted  cross-border  cooperation.  Several  stakeholders  (six 

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beneficiaries under the Member States’ programmes) highlighted ISF’s unique financial 
support,  which  complements  the  national  funding  levels.  Few  (two  beneficiaries  of 
Specific Actions beneficiaries) particularly valued the ones related to the development and 
interoperability of IT systems, which required high financial resources and benefited from 
long-term impacts due to ISF funding.  

A few stakeholders (three beneficiaries of Specific Actions) noted that the EU added value 
was  more  indirect  and  difficult  to  prove  or  quantify,  as  the  projects  under  the  Specific 
Actions focused mainly on national activities while being in line with EU-level priorities. 
Regarding  emergency  assistance,  one  stakeholder  (beneficiary  under  the  Thematic 
Facility) highlighted that the ISF-funded projects have the capacity to foster collaboration 
among Member States in addressing critical infrastructure security and enhance the EU’s 
image as a proactive actor in crisis management also at the regional level.    

Summary of the first Focus Group 

The first Focus Group was organised to collect views on whether and how the current set-
up of the ISF is fit for the purpose. The discussion with a wide range of stakeholders (50-
60 participants) explored how well the ISF can, on the one hand, address the key needs of 
its  target  groups  whilst,  on  the  other,  support  activities  that  are  able  to  generate 
additionality  at  the  EU  level,  e.g.  by  fostering  transnational  cooperation,  innovative 
practices and mutual trust. Although the focus was on ISF, changes vis-à-vis the previous 
programming period (ISF-P) were also raised. The Focus Group involved discussion in a 
plenary session and six break-out groups, allowing for targeted conversations.  

One of the key concerns raised by some stakeholders was the broad scope of the ISF and 
the covered policy fields, which lies in contrast with the limited funding resources. Some 
stakeholders  noted  that  the  Fund's  wide-ranging  priorities  often  lead  to  fragmentation, 
making  it  challenging  to  achieve  a  significant  impact  across  various  crime  areas.  To 
enhance  effectiveness,  many  participants  recommended  narrowing  the  focus  to  a  few 
major crime areas, particularly those linked to emerging threats. For certain participants, 
the priorities set up at the time of the ISF's adoption risk not fully reflecting the evolving 
priorities in certain crime areas where technological developments are rapidly changing. 

Stakeholders emphasised the necessity of broader engagement within ISF-funded projects, 
particularly regarding the inclusion of citizens and civil society organisations. However, 
some stakeholders considered their involvement complex. According to them, while civil 
society organisations might have a significant role to play in fields such as victim support, 
barriers to sharing sensitive information hinder their involvement in other fields, especially 
in organised crime initiatives.  

The  importance  of  capturing  qualitative  indicators,  such  as  stakeholder  satisfaction  and 
project  sustainability,  was  also  highlighted,  as  current  quantitative  measures  do  not 
adequately reflect projects’ impacts, with some stakeholders voicing concerns that ISF’s 
output indicators failed to capture the quality and success of projects effectively. 

A  recurring  challenge  was  reported  regarding  short  projects’  timelines,  which  some 
stakeholders considered limiting the scope and long-term impacts of ISF-funded projects. 
. Stakeholders suggested that longer project durations would allow for solidifying benefits 
and  recommended  adopting  a  building  block  approach,  enabling  projects  to  build  on 
previous initiatives and enhancing continuity and sustainability. 

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Moreover, the need for a transitional period between programming phases was highlighted 
to better adapt to evolving priorities.  

Sustainability emerged as a critical concern across discussions in the break-out groups. . 
Some  stakeholders  recommended  flexible  follow-up  funding  mechanisms  to  support 
projects’ sustainability. In particular, the need for enhanced coordination and knowledge-
sharing among projects was emphasised to avoid duplication of efforts and to maximise 
resource  utilisation.  The  challenge  of  measuring  long-term  impacts  was  especially 
indicated  in  fields,  such  as  corruption  and  child  sexual  abuse,  where  success  is  often 
difficult  to  quantify.  They  also  recommended  focusing  on  prevention  alongside 
intervention,  where  the  health  and  security  sectors  are  intertwined  but  not  sufficiently 
integrated under ISF. In light of the discussions on sustainability, some suggestions were 
made, including making the application for follow-up projects easier and creating stronger 
(funding) links between ISF and other funding mechanisms. 

Current challenges affecting projects' implementation include delays in proposal processes 
and budget constraints due to inflation. Some stakeholders urged improved communication 
of  projects’  results  (e.g.,  by  DG  HOME)  and  event-based  outreach  to  enhance  project 
visibility and stakeholder engagement. In comparison with the ISF-P, participants noted 
that  the  ISF-P  had  less  rigid  reporting  requirements,  allowing  for  easier  adaptation  to 
project-specific  contexts,  and  suggested  revisiting  these  criteria  to  facilitate  better 
implementation. 

A key challenge observed across the different break-out groups is the disconnect between 
the Union Actions’ projects and those funded through the Shared Management component 
of the ISF. National stakeholders indicated to be often aware of the Union Actions, but it 
is  often  unclear  to  them  how  these  relate  to  the  ISF-funded  actions  (through  Shared 
Management) on the national level. Vice versa, Union Action beneficiaries indicated that 
they have very little oversight over the projects funded on the national level through the 
Shared Management component and that this makes it difficult for them to propose projects 
that fit well with the already ongoing activities on the national level. 

Overall, the discussions revealed a consensus on the need for enhanced flexibility, more 
targeted focus, enhanced stakeholders’ engagement, improved visibility of results and a 
greater emphasis on the sustainability of projects’ results. Addressing these key elements 
is crucial for the ISF to effectively meet the evolving security challenges and ensure long-
term meaningful impacts. 

Summary of the Second Focus Group 

The second Focus Group aimed to collect feedback from relevant stakeholders and validate 
the study's findings, ensuring that the conclusions presented in the Draft Inception Report 
for  the  mid-term  evaluation  of  the  ISF  are  accurate  and  comprehensive  and  reflect  the 
perspectives of all key stakeholders. A total of 61 participants (including 12 study team 
members)  took  part  in  the  Focus  Group.  Participants  reflected  the  various  stakeholder 
groups.  The  study  team  presented  the  key  findings  of  the  Draft  Inception  Report  and 
reported the results per evaluation criteria.  

During the discussion on effectiveness, some Managing Authorities provided several key 
opinions for why actions implemented under shared management are progressing slower 
than those under other home affairs funds, i.e., AMIF and BMVI. These relate to structural 
constraints  of  the  ISF  (particularly  the  35%  restriction  on  equipment  and  infrastructure 

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spending),  administrative  and  resource  constraints,  timing  and  transitional  challenges 
affecting implementation rates (e.g. delays closing projects funded under previous cycle), 
project  implementation  characteristics  (with  the  ISF  projects  are  predominantly  public 
procurement-based), and indicators risking not effectively reflect the Fund objectives and 
activities.  

For efficiency, a Union Action beneficiary underlined that the current framework for travel 
unit  costs  poses  challenges,  as  the  allocated  amounts  (particularly  in  the  post-COVID 
context) are insufficient to meet actual expenses.  

The  late  inclusion  of  the  CPR  also  created  some  complexities,  as  the  CPR  has  been 
designed for other types of EU funds, i.e., cohesion funds. The type of payment reporting 
is also designed to fit cohesion funds rather than Home Affairs ones. The system is now 
more similar to the ones existing prior to 2014, which were more complex. According to 
some  Managing  Authorities,  the  reporting  system  used  from  2014  to  2020  was  more 
efficient.  

Some Managing Authorities agreed and reported that it is perceived as overly burdensome 
for  each  Member  State  to  independently  establish  their  own  Simplified  Costs  Options 
(SCOs) for projects. A more efficient approach would be for the European Commission to 
set up standardised SCOs applicable across all projects, as the targets and requirements—
such as specialised equipment and vehicles—are largely uniform. Additionally, providing 
comprehensive training and guidance on using SCOs would be highly beneficial. Although 
attempts  have  been  made  at  the  Member  State  level  to  develop  SCOs,  the  process  has 
proven highly challenging. Furthermore, for SCOs, challenges persist due to discrepancies 
between  costs  set  by  the  European  Commission  and  actual  costs  incurred.  While  the 
European Commission allows using certain SCOs, these are often less cost-effective than 
real costs, making them less appealing to use. Importantly, SCOs are mandatory for UAs 
but not for Member States, creating additional complexities. Implementing SCOs requires 
extensive preparatory work, as both audit authorities and national authorities must validate 
them, a time-consuming and administratively demanding process. Additionally, In the case 
of the  ISF, which relies  heavily on procurement-based costs, many expenses fall under 
indirect  costs,  leaving  limited  scope  for  using  SCOs  effectively.  The  situation  is 
exacerbated by "gold-plating" where national authorities impose additional requirements 
beyond the European Commission’s standards.  

Another challenge relates to the ISF's reliance on public procurement, which is inherently 
complex  and  risky.  It  is  unclear  what  simplifications  could  be  applied  to  public 
procurement within this fund, as the associated risks and complexities are likely to persist. 

With regard to the suggestion of having centralised expertise at the national level, the input 
collected during the Focus Group is in contrast to the evaluation finding: it was flagged 
that keeping the management of the ISF within the Ministry of Interior is beneficial as staff 
experts are more knowledgeable and expert on the subjects and the needs.  

On  relevance,  some  Managing  Authorities  provided  several  explanations  for  relatively 
lower funding allocated to cross-border cooperation under shared management than to the 
other specific objectives. First, some Member States perceived other specific objectives as 
more relevant based on national needs assessment. Second, another explanation referred 
to  the  relatively  low  costs  incurred  for  projects  aimed  at  enhancing  cross-border 
cooperation. Third, several Managing Authorities also pointed to practical challenges in 

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funding cross-border cooperation projects  as determining eligibility  can be complex.  In 
addition, several Managing Authorities stressed the high administrative burden, reporting 
that, in some instances, it is easier to utilise national budgets. Another explanation arises 
from the international nature of projects enhancing cross-border cooperation as they are 
perceived  as  more  difficult  or  complex.  Regarding  the  prioritisation  of  information 
exchange  under  shared  management  (and  its  limited  inclusion  within  the  Thematic 
Facility),  some  Managing  Authorities  attributed 
to  financial 
considerations.  They  explained  that  Member  States  primarily  rely  on  Member  States’ 
programmes to implement Directives that are related to information exchange.  

this  discrepancy 

During the discussion on coherence, several Managing Authorities and one civil society 
organisation stressed that complementarity exists between the ISF and other EU funding 
instruments.  Despite  positive  results  and  synergies  between  projects,  Managing 
Authorities and a beneficiary of Union Actions reported potential overlaps between the 
ISF and other EU funds. This is considering that, compared to the previous programming 
period, the distinctions between ISF and other EU funds have become less pronounced. 
The scope of ISF has broadened over time, encompassing policy fields that other EU funds 
may also address, such as Horizon. On the scope of the ISF, there was no consensus among 
participating  Managing  Authorities  on  whether  this  broadening  was  beneficial.  One 
expressed concerns that the ISF’s limited budget necessitates a return to its previous scope 
(as under the ISF-P), focusing on the critical policy fields. Others argued that narrowing 
the ISF’s scope could risk making EU funding overly sectoral and less flexible. Even one 
Union Actions beneficiary underlined that Union Actions should remain more operational 
and  not  be  slowly  assimilated  to  Horizon-type  of  actions,  which  would  diminish  the 
complementarity between both Funds. 

For  EU-added  value,  stakeholders  underlined  that  it  is  not  solely  connected  to  Union 
Actions. Other fund components can also contribute to EU-added value. National projects 
benefit from benchmarking opportunities and visits to other Member States, while Union 
Actions bring EU added value, particularly in fields such as cross-border cooperation and 
cybercrime.  Contacts  among  Project  Managers  for  different  projects  facilitate  the 
transferability  of  best  practices.  Even  actions  initially  considered  to  have  limited 
transnational relevance often showed elements that contributed to the EU added value, as 
suggested by two Managing Authorities.  

Some participants presented an example of a comparison between the ISF and the ISF-P 
regarding the funding rules on equipment.  They reported that the  ISF-P included fewer 
restrictions  on  equipment  funding  and  that  it  was  extensively  used  to  enhance  crime 
investigations.  This  approach  also  enabled  sharing  results  with  other  Member  States, 
particularly in cases with cross-border cooperation. According to some participants, the 
current  rules  on  equipment  funding  have  limited  exchange  opportunities,  reducing  the 
scope for collaboration and innovation.  

A representative from an EU agency reported that better results could be achieved if the 
training needs identified at the EU level were better integrated into the Member States’ 
calls for proposal at an early stage.  

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