Opinion of the Regulatory Scrutiny Board
Date: 2025-09-16
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: computer crime, fund (EU), help for victims, organised crime, police cooperation, policy analysis, project evaluation, radicalisation, risk management, terrorism

EUROPEAN COMMISSION 

Brussels, 16.9.2025 
SEC(2025) 254 final

REGULATORY SCRUTINY BOARD OPINION 

COMMISSION STAFF WORKING DOCUMENT EVALUATION 
Mid-term Evaluation of the Internal Security Fund (ISF) for the 2021-2027 
programming period

{SWD(2025) 274 final}
{SWD(2025) 275 final}

EUROPEAN COMMISSION 
Regulatory Scrutiny Board

Brussels, 
Ares(2025) 

Opinion 

Title: Evaluation / Mid-term Evaluation of the Internal Security Fund (ISF) 

Overall opinion: NEGATIVE 

(A) Policy context

The Internal Security Fund 2021-2027 (ISF) is one of the three Home Affairs funds for the 
period  2021-2027.  With  a  total  budget  of  EUR  1.93  billion,  it  aims  to  contribute  to 
preventing  and  combating  terrorism  and  radicalisation,  serious  and  organised  crime  and 
cybercrime.  

The  mid-term  evaluation,  covering  the  period  up  to  mid-2024,  is  foreseen  in  the  ISF 
Regulation  (EU)  2021/1149  and  shall  take  into  account  the  results  of  the  retrospective 
evaluation of the previous programming period. Its purpose is to assess: (a) the effectiveness 
of the Fund, including the progress made towards the achievement of its objective; (b) the 
efficiency  of  the  use  of  resources  and  the  management  and  control  measures;  (c)  the 
continued  relevance  and  appropriateness  of  the  implementation  measures;  (d)  the 
coordination,  coherence  and  complementarity  with  other  Union  funds;  and  (e)  the  Union 
added value. 

(B) Key issues

The  Board  notes  the  additional  information  provided  and  commitments  to  make 
changes to the report. 

However, the Board gives a negative opinion, because the report contains the following 
serious shortcomings:  

(1) The intervention logic is not clearly defined and does not specify how progress in
achieving  the  specific  objectives  was  meant  to  be  assessed.  The  report  does  not
effectively utilise available data to analyse the Fund's effectiveness and efficiency at
this stage.

(2) The analysis of coherence lacks sufficient substantiation. The report does not clearly

analyse the Fund’s continuous relevance and Union added value.

(3) Statements, conclusions and lessons learned do not consistently reflect underlying
evidence.  The  report  does  not  inform  on  how  the  monitoring  and  evaluation
framework needs to be adapted to allow for comparisons between different Member
States and for an evidence-based retrospective evaluation.

  ________________________________   
This opinion concerns a draft evaluation/fitness check which may differ from the final version. 

Commission européenne, B-1049 Bruxelles – Belgium - E-mail: regulatory-scrutiny-board@ec.europa.eu 

(C) What to improve 

(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. 

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Some more technical comments have been sent directly to the author Service.

(D) Conclusion

The lead Service must revise the report before launching the interservice consultation. 

The lead Service may resubmit to the Board a revised version of this report.  

Full title

Mid-term Evaluation of the Internal Security Fund (ISF)

Reference number 

PLAN/2023/1283 

Submitted to RSB on

05 February 2025

Date of RSB meeting 

05 March 2025 

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