Opinion of the Regulatory Scrutiny Board
Date: 2025-09-16
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: EU migration policy, EU visa policy, aid to refugees, fund (EU), integration of migrants, migration control, project evaluation, refugee, return migration, right of asylum

EUROPEAN COMMISSION 

Brussels, 16.9.2025
SEC(2025) 248 final

REGULATORY SCRUTINY BOARD OPINION 

COMMISSION STAFF WORKING DOCUMENT EVALUATION 
Mid-term Evaluation of the Asylum, Migration and Integration Fund 
(AMIF) 2021-2027

{SWD(2025) 270 final}
{SWD(2025) 271 final}

EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels, 
Ares(2025) 

Opinion 

Title:  Interim evaluation of Asylum, Migration and Integration Fund 
(AMIF) (2021/2027) 

Overall opinion: NEGATIVE 

(A) Policy context

The Asylum, Migration and Integration Fund (AMIF) (2021-2027) is one of the three Home 
Affairs funds. With a total budget of EUR 11 billion it aims to support national capacities, 
improve  procedures  for  managing  migration,  strengthen  solidarity  and  the  sharing  of 
responsibility between Member States.  

The  mid-term  evaluation  covering  the  period  up  to  mid-2024  is  foreseen  in  the  AMIF 
Regulation  (EU)  2021/1147.  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) While  acknowledging  limitations  and  data  gaps,  the  report  is  not  sufficiently
underpinned  with  evidence  and  analysis,  given  the  degree  of  financial
implementation. The report does not sufficiently analyse the significant variations
in implementation among the Member States. It is not clear what is the baseline
and points of comparison regarding the achievement of objectives, considering the
-
absence of the final 
2020.

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

(3) The report does not sufficiently analyse administrative costs.
(4) The assessment of  coherence  with the  Pact  on  Migration and  Asylum  and  with
other  EU  funds  is  not  sufficient.  The  report  does  not  sufficiently  assess  the
in  these  policy
additionality of the  AMIF  to  broader  efforts of 
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 integrate 
more elements from the support study and case studies. With roughly EUR 3 billion allocated 
and EUR 1 billion spent, the report should integrate more data on outputs, results and costs 
in the effectiveness and efficiency analysis. The conclusions, in particular on effectiveness 
and  efficiency,  should  be  more  nuanced  and  better  aligned  with  the  evidence  available. 
Reporting  on  progress  in  financial  implementation  is  not  sufficient  as  evidence  of 
effectiveness  and  efficiency,  and  to  allow  to  conclude  that  the  programme  is  on  track  to 
achieve its objectives.   
(2)  The report should deepen the analysis of how the situation was expected to evolve and 
how progress towards attaining objectives is measured and against what baseline. The mid-
term evaluation report 2021-2027 should take into account the results of the final evaluation 
2014-2020. 
(3)  Beyond documenting financial progress, the report should make use of available data on 
outputs  and  results  to  analyse  effectiveness,  intervention  logic  and  provide  preliminary 
assessment  of  causal  links.  The  report  should describe  in  more  detail  the  monitoring  and 
evaluation framework in place and assess the extent to which the data collected will make it 
feasible to evaluate 
 in the final evaluation. 
The report should include an overview of indicators, points of comparison, 2024 milestones, 
quantified baselines for the indicators and correlate them with what should be considered 
success. It should be explicit about data and information that Member States provide in their 
regular reporting and identify any issues or gaps that would need to be addressed. It should 
also  assess  the  reasons  behind  the  different  degrees  on  implementation  among  Member 
States. 
(4)  Beyond acknowledging that there is room for improvement of monitoring, the lessons 
learned  should  include  potential  changes  to  the  reporting  system  and  the  established 
indicators  in  order  to  ensure 
  in  the  final 
evaluation.  
(5)  The report should provide more details on administrative costs and their assessment. It 
should  analyse  to  what  extent  different  stakeholders'  perceptions  of  complexity  and 
cumbersome reporting are valid and assess the potential for improvement, simplification, and 
burden reduction. Given the current degree of implementation, the report should analyse the 
types of costs and provide underlying methodology.    
(6)  The coherence assessment should better explain the extent to which the programme is 
aligned  with  other  EU  funds  (in  particular,  RFF,  ESF  and  NDICI)  and  with  the  Pact  on 
Migration  and  Asylum.  The  report  should  assess  better  how  the  AMIF  2021-2027  has 
addressed emerging needs and identified evolving ones instead of relying on elements related 
to the previous programming period. As regards EU added value, the report should also be 
clear in terms of the additionality of AMIF to measures funded by Member States, 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.  

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Full title 

Mid-term Evaluation of the Asylum, Migration and Integration 
Fund for the 2021-2027 programming period 

Reference number 

PLAN/2023/1285 

Submitted to RSB on 

16 January 2025 

Date of RSB meeting 

12 February 2025 

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