Opinion of the Regulatory Scrutiny Board
Date: 2025-09-16
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: EU migration policy, EU visa policy, Schengen Agreement, border control, external border of the EU, fund (EU)

EUROPEAN COMMISSION 

Brussels, 16.9.2025 
SEC(2025) 253 final

REGULATORY SCRUTINY BOARD OPINION 

COMMISSION STAFF WORKING DOCUMENT EVALUATION 
Mid-term Evaluation of the Instrument for Financial Support for 
Border Management and Visa Policy (BMVI) 2021-2027

{SWD(2025) 272 final}
{SWD(2025) 273 final}

EUROPEAN COMMISSION 
Regulatory Scrutiny Board

Brussels, 
Ares(2025) 

Opinion 

Title:  Evaluation  /  Mid-term  Evaluation  of  the  Instrument  for  Financial 
Support  for  Border  Management  and  Visa  Policy  for  the  2021-2027 
programming period 

Overall opinion: NEGATIVE 

(A) Policy context

The  Border  Management  and  Visa  Policy  Instrument  (BMVI) is  one  of  the  three  Home 
Affairs funds for the period 2021-2027 with a total budget of EUR 7.7 billion, the instrument 
aims to support the border management at external borders and a harmonised approach to 
the visa policy.  

The mid-term evaluation covering the period up to June 2024 is foreseen by the Regulation 
2021/1148. The  purpose  of  this  mid-term  evaluation  is  to  look  at  the  progress  made  in 
implementing  the  programme  and  assess whether  actions  are  needed  to  ensure  it  duly 
delivers on its intended objectives.

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

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

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

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

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

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu 

(C) What to improve 

(1)  The report should more systematically refer to the existing evidence base and bring in 
more elements from the support study and case studies.  The conclusions should be more 
nuanced and better aligned with the evidence available and its limitations. In particular, the 
conclusions  on  effectiveness  and  efficiency  should  be  more  clearly  linked  to  available 
evidence. Reporting on progress in financial implementation is not sufficient as evidence of 
the effectiveness and efficiency, and to allow to conclude that the programme is on track to 
achieve its objectives. 
The report should be clear about the baseline and describe also in quantitative terms how 
progress  towards  attaining  objectives  is  measured  and  against  what  baseline.  As  far  as 
possible the report should refer to the results of the final evaluation of the funds under the 
previous  programming  period.  The  report  should  analyse  the  different  degrees  on 
implementation among Member States and underlying causes. 
(2)  The report should describe in more detail the monitoring and evaluation framework in 
place and assess the extent to which the data  collected will allow to track progress on all 
elements  of  the  intervention  logic  and  will  allow  to  evaluate  the  achievement  of  the 
programme’s  objectives in  the  final  evaluation.  It  should  be  explicit  about  data  and
information that Member States provide in their regular reporting and identify any issues or 
gaps that would need to be addressed. 
(3)  The report should provide more details and assessment of administrative costs. It should 
analyse to what extent the perceptions of national authorities of complexity and cumbersome 
reporting  are  valid  and  assess  any  margin  for  improvement,  simplification  and burden 
reduction. Given the current degree of implementation, the report should analyse the types 
of costs and provide underlying methodology.  
(4)  The coherence assessment should better explain the extent to which the programme is 
aligned with other EU funds (such as RFF and ESIF) and with the Pact on Migration and 
Asylum. The report should better assess the additionality of BMVI to measures funded by 
Member States and analyse any data gaps which could hamper the analysis of additionality 
in the final evaluation.  

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 Instrument for Financial Support 
for Border Management and Visa Policy for the 2021-2027 
programming period 

Reference number 

PLAN/2023/1284  

Submitted to RSB on

16 January 2025

Date of RSB meeting 

12 February 2025 

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