COMMISSION STAFF WORKING DOCUMENT Public Sector Loan Facility under the Just Transition Mechanism interim evaluation Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the interim evaluation of the Public Sector Loan Facility under the Just Transition Mechanism in 2025, as referred to in Article 17 of Regulation (EU) 2021/1229
Date: 2025-10-08
Institutions: Directorate-General for Regional and Urban Policy, European Commission
Subjects: EU aid, EU environmental policy, EU loan, carbon neutrality, circular economy, climate change, green economy, public sector, regional aid, regional development

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.10.2025  SWD(2025) 287 final  COMMISSION STAFF WORKING DOCUMENT Public Sector Loan Facility under the Just Transition Mechanism interim evaluation Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the interim evaluation of the Public Sector Loan Facility under the Just Transition Mechanism in 2025, as referred to in Article 17 of Regulation (EU) 2021/1229 {COM(2025) 628 final}  
 
 
Table of contents 

1. 
1.1 

INTRODUCTION ................................................................................................................. 1 
Purpose and scope of the evaluation .............................................................................................. 1 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? .................. 3 
Description of the intervention and its objectives ........................................................................ 3 
2.1 
Points of comparison ..................................................................................................................... 11 
2.2 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? .. 12 
3.1 Current state of play of PSLF implementation ................................................................................. 12 

4.  TO WHAT EXTENT WAS THE INTERVENTION SUCCESSFUL AND WHY? ..... 17 
Effectiveness .................................................................................................................................. 17 
4.1. 
Efficiency ....................................................................................................................................... 31 
4.2. 
Coherence ...................................................................................................................................... 34 
4.3. 
EU added value ............................................................................................................................. 42 
4.4. 
Relevance ....................................................................................................................................... 45 
4.5. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? .............................. 49 
Conclusions .................................................................................................................................... 49 
5.1 
Lessons learned ............................................................................................................................. 54 
5.2 

ANNEX I:   PROCEDURAL INFORMATION ....................................................................... 60 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED .............................. 64 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 
TO THE EVALUATION QUESTIONS (BY CRITERION) .................................................. 80 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ........................................................ 86 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ........................ 93 

ANNEX VI. SUPPORTING STUDY ....................................................................................... 118 

ANNEX VII. LIST OF PSLF SELECTED PROJECTS (INCLUDING BOTH AWARDED AND 
UNDERGOING EIB DUE DILIGENCE) AND ADVISORY ASSIGNMENTS ................. 119 

ANNEX VIII. PSLF MONITORING AND REPORTING FRAMEWORK....................... 129 

EN 

  EN 

 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

CEF 

CF 

CINEA  

EC 

EIB 

ERDF 

ESF+ 

EU 

FNLC 

JTF 

JTM 

JTP 

JTS 

KPI 

MS 

NPBIs 

PSLF 

RRF 

RRP 

SDG 

SWD 

TJTP 

TSI 

Connecting Europe Facility 

Cohesion Fund 

European  Climate,  Infrastructure  and  Environment 
Executive Agency  

European Commission 

European Investment Bank 

European Regional and Development Fund 

European Social Fund Plus 

European Union 

Financing Not Linked to Costs  

Just Transition Fund 

Just Transition Mechanism 

Just Transition Platform  

Just Transition Scheme 

Key Performance Indicator 

European Union Member State  

National Promotional Banks and Institutions  

Public Sector Loan Facility 

Recovery and Resilience Facility 

Recovery and Resilience Plan  

United Nations Sustainable Development Goal  

Staff Working Document 

Territorial Just Transition Plan 

Technical Support Instrument 

EN 

  EN 

 
 
 
1.  INTRODUCTION 

1.1 Purpose and scope of the evaluation 

The Public Sector Loan Facility (PSLF) was established in July 2021 by Regulation (EU) 
2021/12291 (hereafter referred to as ‘PSLF Regulation’) to help achieve the Union’s 2030 
climate target and climate neutrality by 2050 in an effective and socially fair manner. The 
Facility  was  set  up  to  address  serious  social,  economic  and  environmental  challenges 
deriving from the transition for the benefit of the Union territories identified in the territorial 
just transition plans (‘TJTPs’). As a blended instrument, the PSLF is expected to mobilise 
up to EUR 1.3 billion of EU grants, between EUR 6 billion and EUR 8 billion in loans from 
the  European  Investment  Bank  (‘EIB’)  and  EUR  6  billion  in  additional  funding  sources, 
reaching a total of between EUR 13.3 and EUR 15.3 billion. 

As required by the PSLF Regulation (Article 17), the purpose of this interim evaluation is to 
evaluate PSLF implementation and its capacity to achieve the objectives set out in Article 3 
of the same Regulation. In  particular, it should assess:  

a)  the  extent  to  which  the  Union  support  provided  under  the  Facility  contributed  to 
address  the  needs  of  territories  implementing  the  Territorial  Just  Transition  Plans 
(TJTPs); 

b)  how the horizontal principles referred to in Article 4 of the Regulation were taken 

into account; 

c)  the need to carry out a gender impact assessment; 
d)  the application of the eligibility conditions set out in Article 9 of the Regulation and 

how the visibility obligations were applied; 

e)  on the basis of the projects supported by the Facility, the extent to which the Facility 
contributed  to  the  environmental  objectives  laid  down  in  Article  9  of  Regulation 
(EU) 2020/8522 . 

Next to the specific evaluation requirements as laid out here-above and in line with the Better 
Regulation (BR) Guidelines and the Interinstitutional Agreement on Better Law-Making3, 
the interim evaluation covers the five BR evaluation criteria, namely (i) effectiveness; (ii) 
efficiency; (iii) relevance; (iv) coherence; and (v) EU added value. 

The scope of the evaluation  covers the Facility from the date when the PSLF Regulation 
entered into force on 14 July 2021 until 31 January 2025 and targets all EU Member States, 
in particular, the territories identified in the TJTPs.  

1 Regulation (EU) 2021/1229 of the European Parliament and of the Council of 14 July 2021 on the public 
sector loan facility under the Just Transition Mechanism, available at: Regulation - 2021/1229 - EN - EUR-
Lex  
2  Regulation  (EU)  2020/852  of  the  European  Parliament  and  of  the  Council  of  18  June  2020  on  the 
establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088, 
available at: Regulation - 2020/852 - EN - taxonomy regulation - EUR-Lex  
3 Interinstitutional Agreement between the European Parliament, the Council of the European Union and the 
European Commission on Better Law-Making, available at: EUR-Lex - 32016Q0512(01) - EN - EUR-Lex 

1 

 
 
 
The grant and the loan components of the PSLF are included in the scope of the evaluation. 
In particular, the achievement of the objectives of the PSLF is covered for both components. 
However, the PSLF Regulation has not created an obligation for the EIB to be subject to the 
EC’s evaluations, and the EIB has not agreed to be subject to the Commission’s evaluations 
nor to carry out joint evaluations in the subsequent Administrative Agreement between the 
EU and the EIB for the implementation of the PSLF. The EIB manages the loan component 
with its own resources, without any funding from the Commission to cover its administrative 
or operational costs. In line with the above, the management itself of the loan component by 
the EIB could not be included in the scope of this evaluation. Specific aspects covering the 
loan  component  of  the  PSLF  are  based  on  the  supporting  study’s  literature  review  and 
stakeholder consultation, as well as publicly available information such as the Commission's 
interim evaluation of the InvestEU programme4, the EIB Group Evaluation of EIB advisory 
activities in the European Union5 and the EIB Mid-Term Review of the EIB Group support 
to the Just Transition Mechanism6. 

This  interim  evaluation  is  conducted  at  an  early  stage  of  implementation  and,  as  such, 
focuses  on  activities  and  outputs  since  results  and  impact  cannot  be  assessed  yet.  As  of 
January 2025, seven PSLF projects have begun implementation in 2023 and 2024, while 12 
applications  are  either  under  evaluation  or  in  the  process  of  having  grant  agreements 
prepared.  The  assessment  of  results  and  long-term  impact  will  be  included  in  the  final 
evaluation, which is required by the end of the implementation period by no later than 31 
December 2031 in accordance with PSLF Regulation (Article 17(3)).  

The findings presented in the scope of this Staff Working Document (‘SWD’) build on two 
main  components.  Firstly,  this  interim  evaluation  is  based  on  in-house  expertise  and 
documentation.  Secondly,  the  assessment  builds  on  the  results  of  a  supporting  study 
(hereafter referred to as ‘supporting study’) contracted by the Commission and prepared by 
a consortium comprising T33 srl and Prognos AG (for further information, see the Annex 
II). The supporting study which was carried out between end of April 2024 and January 2025 
combines  various  methods  (document  review/desk  research,  survey,  interviews  and  case 
studies)  to  provide  answers  to  the  evaluation  questions  enabling  the  triangulation  of  the 
findings.  

The evaluation encountered several challenges. Due to the novelty of the PSLF and its early 
stage of implementation, the pool of stakeholders who could provide meaningful feedback 
about  the  PSLF  is  small.  This  was  especially  the  case  in  EU  Member  States  with  no 
implementation  of  the  PSLF.  Nevertheless,  the  Commission  considers  the  analysis  and 

4  Commission  Staff  Working  Document  SWD(2024)  229,  available  at:  https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13770-InvestEU-programme-interim-evaluation_en    
5  Evaluation  of  EIB  advisory  activities 
(2023), 
https://www.eib.org/en/publications/20230211-evaluation-of-eib-advisory-activities-in-the-eu  
6 EIB (2024) Mid-Term Review of the EIB Group Support to the Just Transition Mechanism .  

the  European  Union 

  available  at: 

in 

2 

 
 
 
results of the evaluation to be sufficiently reliable to draw some early-stage conclusions and 
lessons learned about the PSLF. 

A  Commission  Inter-Service  Steering  Group  (‘ISSG’)  established  for  the  purpose  of  this 
evaluation. It was useful in steering the supporting study and this SWD, while ensuring the 
quality,  representativeness  and  credibility  of  the  evaluation  and  its  coherence  with  other 
related EU policies. 

This  SWD  is  organised  as  follows:  section  2  summarises  the  objectives  and  expected 
outcomes  of  the  PSLF,  and  section  3  describes  how  the  situation  has  evolved  since  the 
adoption  of  the  PSLF  Regulation  in  2021.  Section  4  presents  the  main  findings  of  the 
evaluation by criteria and section 5 provides conclusions and lessons learned. The annexes 
provide additional information about the methodology and analytical models used, about the 
stakeholder  consultation  conducted,  about  the  procedure  followed  for  this  interim 
evaluation, provide the supporting study and more information about the PSLF’s reporting 
and monitoring framework.  

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1   Description of the intervention and its objectives 

Context of the intervention 

On 11 December 2019, the Commission adopted a Communication on the European Green 
Deal7,  drawing  its  roadmap  towards  a  new  growth  policy  for  Europe  which  is  based  on 
ambitious climate and environmental objectives.  The transition towards a sustainable and 
climate-neutral  economy  is  a  source  of  new  economic  opportunities,  with  significant 
potential for job creation. At the same time, the transition poses significant challenges for 
some territories.  

The most vulnerable regions and territories are those most affected by the transition given 
their dependence on fossil fuels. Those regions and territories will need to restructure their 
industries,  ensure  that  new  economic  activities  can  keep  the  economic  and  social  texture 
together, and provide the necessary training to the workers concerned to find new jobs. Job 
displacement  in  sectors  historically  dependent  on  fossil  fuels  is  a  critical  concern.  As 
positions in these industries diminish, there is an immediate need to create new, high-quality 
jobs  in  emerging  sectors.  Economic  diversification  remains  an  indispensable  part  of  the 
solution. 

The transition also raises issues of social inequality and fairness.  It is imperative that the 
shift towards a sustainable economy is equitable and inclusive, ensuring that the associated 
benefits  and  burdens  are  distributed  justly  across  different  regions  and  social  groups. 

7 Communication from the Commission on the European Green Deal, available at: EUR-Lex - 52019DC0640 

- EN - EUR-Lex 

3 

 
 
 
Addressing existing social inequalities is pivotal to achieving a fair transition that is socially 
acceptable. 

Regional  disparities  compound  the  challenge,  as  areas  with  limited  financial  capacity 
struggle to meet the investment needs required for this transition. The most affected regions 
and territories are also those which dispose of limited resources to mitigate the economic 
and  social  costs  of  that  transition  and  those  that  have  been  already  weakened  by  the 
disruptive economic and social effects of the COVID-19 crisis. Mobilising resources in these 
regions  to  upgrade  infrastructure  and  adopt  low-carbon  technologies  is  essential.  These 
regions  require  additional  support  to  capitalise  on  investment  opportunities  necessary  for 
their  transformation.  In  this  context,  on  14  January  2020,  the  Commission  adopted  a 
Communication on ‘Sustainable Europe Investment Plan – European Green Deal Investment 
Plan’8  in  which  it  announced  a  Just  Transition  Mechanism  (JTM)  to  address  the  specific 
challenges  encountered by the regions that are most affected by the transition because of 
their dependence on fossil fuels but have less capacity to finance the necessary investments. 
The  JTM  provides  means  for  facing  the  climate  challenge  while  leaving  no  one  behind. 
Targeted  support  to  generate  the  necessary  investments  in  these  territories  is  channelled 
through  three  pillars:  a  Just  Transition  Fund  (JTF)  providing  primarily  grants  and 
implemented under shared management,  a dedicated  Just  Transition  Scheme (JTS) under 
InvestEU  crowding  in  private  investments,  and  the  PSLF  aiming  to  leverage  additional 
public financing.  

Objectives of the intervention 

The general objective of the PSLF is “to address serious social, economic and environmental 
challenges deriving from the transition towards the Union’s 2030 climate and energy targets 
and the objective of climate neutrality in the Union by 2050 at the latest, set out in Regulation 
(EU)  2021/1119,  for  the  benefit  of  the  Union  territories  identified  in  the  territorial  just 
transition plans” (Article 3(1) PSLF Regulation). 

The specific objective of the PSLF is “to increase public sector investments which address 
the development needs of the territories identified in the territorial just transition plans, by 
facilitating the financing of projects that do not generate sufficient streams of revenues to 
cover their investment costs, in order to prevent the replacement of potential support and 
investment from alternative resources” (Article 3(2) PSLF Regulation). 

Foremost, the PSLF offers financial support targeted to public entities in vulnerable regions 
that are heavily reliant on carbon-intensive industries. By directing resources to these areas, 
the Facility aims to mitigate the socio-economic costs that arise from the transition, thereby 
easing  the  impact  on  local  economies.  Infrastructural  development  is  a  key  focus  of  the 
PSLF. The Facility can fund critical projects that upgrade and develop infrastructure needed 
for a low-carbon economy.  It can  finance initiatives that create jobs  in  emerging  sectors. 

8 Communication from the Commission on the European Green Deal Investment Plan, available at: https://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=celex:52020DC0021  

4 

 
 
 
Additionally,  the  PSLF  acts  as  a  catalyst  for  further  investment,  leveraging  its  financial 
support to attract additional public and private funding. 

The scope of sectors that may benefit from PSLF support is large and covers various types 
of public investments. Recital 6 of the PSLF Regulation refers to a wide range of investments 
to enhance cohesion and the economic diversification of territories impacted by the transition 
which include  among  others,  investments  in  renewable  energy and green and sustainable 
mobility,  including  the  promotion  of  green  hydrogen,  efficient  district  heating  networks, 
public  research,  digitalisation,  environmental  infrastructure  for  smart  waste  and  water 
management,  sustainable  energy,  energy  efficiency  and  integration  measures,  including 
renovations and conversions of buildings, urban renewal and regeneration, the transition to 
a circular economy, land and ecosystem restoration and decontamination, taking into account 
the ‘polluter pays’ principle, biodiversity, as well as up-skilling and re-skilling, training and 
social infrastructure, including care facilities and social housing. Investments in other sectors 
could also be supported if they are consistent with the approved TJTPs. On the other hand, 
investments  covering  any  of  the  activities  excluded  under  Article  9  of  Regulation  (EU) 
2021/10569 cannot be supported under the PSLF10. 

All  investments  are  expected  to  take  into  account  the  United  Nations  Sustainable 
Development Goals (‘SDGs’), the ‘polluter pays’ principle, the Paris Agreement11 and the 
‘do no significant harm’ principle throughout the preparation and implementation of eligible 
projects. Respect for fundamental rights and compliance with the Charter of Fundamental 
Rights  of  the  European  Union  (‘EU’),  in  particular  gender  equality  and  accessibility  for 
persons with disabilities are also to be ensured. 

In achieving the objectives and to ensure the effective implementation of the PSLF, advisory 
support which is paid by the PSLF resources (an amount of up to EUR 35 million of PSLF 
resources is made available) but implemented under the InvestEU Advisory Hub12 was set 
up  for  the  preparation,  development  and  implementation  of  eligible  projects,  including 
support for the preparation of projects prior to the submission of the application. Advisory 
support for the purpose of the PSLF under other Union programmes is also possible. 

9 Regulation (EU) 2021/1056 of the European Parliament and of the Council of 24 June 2021 establishing the 
Just Transition Fund, available at: Regulation - 2021/1056 - EN - EUR-Lex  
10 The PSLF shall not support: a) the decommissioning or the construction of nuclear power stations; b) the 
manufacturing, processing and marketing of tobacco and tobacco products; c) an undertaking in difficulty, as 
defined in point (18) of Article 2 of Commission Regulation (EU) No 651/2014; d) investment related to the 
production, processing, transport, distribution, storage or combustion of fossil fuels.  

11  OJ L 282, 19.10.2016, p. 4, available at: EUR-Lex - L:2016:282:TOC - EN - EUR-Lex  
12 Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the 
InvestEU Programme and amending Regulation (EU) 2015/1017, available at: Regulation - 2021/523 - EN - 
EUR-Lex 

5 

 
 
 
Functioning of the intervention 

Support under the Facility consists of a loan and grant component. With the contribution of 
EUR 1.3 billion from the grant component, between EUR 6 billion and EUR 8 billion from 
the loan component and  an estimated EUR 6 billion contribution  from  other sources, the 
Facility  aims  at  mobilising  between  EUR  13.3  billion  and  EUR  15.3  billion  of  public 
investments over the period 2021-27.  

In order to be eligible to access the grant component under the PSLF, projects should achieve 
measurable impact, should not receive support under any other EU funding programmes and 
should also secure a loan from the EIB, the only finance partner of the Facility, in accordance 
with its own rules, policies and procedures. As a supporting measure, the EIB approved, in 
December  2021,  the  possibility  to  exceptionally  increase  its  financing  share  of  Pillar  3-
eligible  operations  located  in  its  cohesion  priority  regions  to  beyond  50%  of  the  project 
investment cost, while respecting its rules about limits on combined EU and EIB support. 
There are several  types of loans available under  the Facility:  (i) “investment  loans” of at 
least EUR 12.5 million requested directly from the EIB for a single project, (ii) “framework 
loans”  of  at  least  EUR  12.5  million,  requested  directly  from  the  EIB,  that  allow  for  the 
financing  of  several  smaller  projects,  and  (iii)  “intermediated  loans”  of  at  least  EUR  1 
million, that are offered through partner financial intermediaries (private or public),  hence 
reaching individually smaller public sector projects and entities.  

The  grant  component,  implemented  by  the  Commission  in  direct  management,  takes  the 
form  of  Financing  Not  Linked  to  Costs13  (‘FNLC’)14  which  is  calculated  as  a  percentage 
(15%) of the loan. A higher grant rate (25%) is applied to the loan when the project is located 
in a less developed region15.  

The grant component is allocated through a multi-annual call for proposal. The Commission 
has delegated specific tasks  concerning the implementation  of the PSLF  to  the European 
Climate, Infrastructure and Environment Executive Agency (‘CINEA’) which manages the 
PSLF calls for proposals, including the application process of the grant component. Project 
proposals  are  first  checked  against  admissibility  and  eligibility  criteria  within  15  days. 
Proposals found admissible and eligible are then evaluated by the Commission and CINEA 
and  either  approved  or  rejected  by  the  evaluation  committee.  Successful  proposals  are 
invited to prepare a grant agreement. The EIB then finalises its due diligence for the loan 
component,  which  may  take  up  to  max.  18  months.  Once  the  EIB  approves  a  financing 
agreement, CINEA may proceed to sign the corresponding grant agreement. 

accordance 

13 Financing not linked to costs (FNLC) is a simplified reimbursement tool where reimbursements are based 
on meeting specific conditions or achieving pre-defined results. 
14In 
with  Article 
https://commission.europa.eu/publications/eu-financial-regulation_en  
15  The  regional  classification  is  defined  in  the  Common  Provisions  Regulation,  EU  Regulation  2021/1060, 
Article 108(2), available at: https://eur-lex.europa.eu/eli/reg/2021/1060/oj/eng  

Regulation, 

Financial 

available 

125 

the 

of 

at: 

6 

 
 
 
Figure 1: PSLF application process  

Source: European Commission. 

In order to ensure that all EU Member States are able to benefit from the grant component, 
pre-allocated national shares per EU Member State are earmarked until 31 December 202516. 
The national shares applicable under the Facility are shown in Figure 2.  

Figure 2: PSLF national shares per EU Member State (reserved until 31 December 2025) 

280

240

200

160

120

80

40

0

PL DE RO CZ BG FR IT ES EL NL FI SK EE LT HU SI PT LV HR BE SE AT CY DK IE MT LU

Source: European Commission. 

The remaining resources of the grant component will be made available without any pre-
allocated national shares and on a competitive basis at Union level after the 31 December 
2025, in order to optimise the impact of the Facility, through the launch of a second multi-
annual call for proposals in Q4 2025. 

In order to monitor the implementation and progress, specific key performance indicators  
(‘KPIs’)  are  established  in  Annex  II  of  the  PSLF  Regulation.  These  include  KPIs  on  the 
financial  execution  through  the  volume  of  grants  and  loans  granted,  overall  investment 

16  The  national  shares  are determined  based  on  the  allocation  methodology detailed  in  Annex I of  the  JTF 

Regulation. 

7 

 
 
 
 
 
mobilised (broken by sectors) and number of projects receiving support (broken by country 
and  by  sector).  Reduction  of  Greenhouse  gas  emissions  (GHG)  and  job  creation,  where 
relevant, are also included. A list of the PSLF KPIs is presented in Annex VIII as well as a 
more detailed description of the Facility’s reporting and monitoring framework. 

Intervention logic 

The  intervention  logic  of  the  PSLF  summarises  how  the  instrument  is  expected  to  work, 
framing its objectives, inputs, activities, expected outputs, results and impact, as presented 
in  figure  3.  While  using  financial,  technical,  human  and  institutional  resources 
(incorporating  different  type  of  activities),  the  PSLF  will  support  investments  by  public 
entities addressing the challenges deriving from the green transition in the regions identified 
in the TJTPs. Such investments, flanked by the InvestEU Advisory Hub (part of which is 
paid by the PSLF), will produce specific outputs and results as measured via the PSLF KPIs. 
They are also expected to have wider economic, social, climate and environmental impacts 
in the EU.  

8 

 
 
 
 
Figure 3: PSLF intervention logic 

Needs: A wide range of social, economic and environmental needs resulting from the transition challenges in territories (undergoing heavy decarbonisation process) as described in the TJTPs. 

Objectives 

Inputs                                                 Activities 

Outputs 

Results 

Impact 

economic 

The  general  objective  of  the 
is  to  address  serious 
PSLF 
and 
social, 
challenges 
environmental 
deriving  from  the  transition 
towards 
the  Union’s  2030 
climate and energy targets and 
the  objective  of 
climate 
neutrality in the Union by 2050 
at  the  latest  for  the  benefit  of 
the  Union  territories  identified 
in  the  territorial  just  transition 
plans. 

of 

the 

is  to 

The  specific  objective  of  the 
increase  public 
PSLF 
investments  which 
sector 
development 
address 
needs 
territories 
the 
identified  in  the  territorial  just 
transition plans,  by  facilitating 
the  financing  of  projects  that 
do  not  generate  sufficient 
streams  of  revenues  to  cover 
their investment costs, in order 
to  prevent  the  replacement  of 
support 
potential 
and 
investment 
from  alternative 
resources. 

Financial 
•  Resources from the EU 

budget. 

•  Assigned revenues 

Negotiating 
administrative 
with finance partner(s). 

and  managing 
agreements 

(provided by reflows from 
EU financial instruments). 

Raising awareness about the 
PSLF and ensuring visibility. 

Designing and managing calls 
for proposals, evaluating and 
selecting projects. 

Managing signed grant 
agreements and monitoring 
their implementation.  

Contributing 
concerning the PSLF. 

to 

the  TJTPs 

Providing advisory for the 
preparation, development and 
implementation of investment 
projects.  

Managing financial resources.  

Governance/institutional 
• 
• 
• 
• 
• 

PSLF Regulation. 
InvestEU Regulation. 
Financial Regulation. 
TJTPs. 
InvestEU Advisory Hub 
Advisory Agreement. 
EC grant management 
systems and procedures. 
Finance partner(s) rules, 
policies and procedures. 

• 

• 

Technical/human 
Expertise of:  
• 
• 
•  MS, TJTP regions. 
• 

EC, CINEA. 
EIB. 

• 

NPBIs and other financial 
institutions.  
Advisory and technical 
services and assistance of 
the EIB via the Advisory 
Hub and/or contractors 
via consultancies. 

Number  of  projects  supported 
by sector : 
• 
• 
• 

Transport. 
Social infrastructure. 
Public utilities (water, 
wastewater, district 
heating, energy, waste 
management). 
Urban infrastructure and 
housing. 
Others 

• 

• 

Number of projects supported 
by:  
• 
• 
• 

Country. 
NUTS 2 region. 
Just transition territory. 

Volume  of  grants  awarded 
(EUR). 

Volume  of  loans  signed  per 
loan type: 
• 
• 

Individual loans.  
Loan schemes 
(framework loans). 
Intermediated loans. 

• 

Overall investment mobilised 
by type of region:  
• 
• 

Less developed regions. 
Other regions.  

Amount of public financing 
mobilised.  

Estimated greenhouse 
emission savings (tonnes of 
CO2 equivalent per year). 

Estimated climate impacts 
(climate change mitigation and 
adaptation). 

Amount of financing mobilised 
from other sources. 

Number of direct jobs created 
disaggregated by gender. 

Use of services and 
infrastructure  provided by 
supported projects addressing 
social and economic needs. 

Total 
persons 
disaggregated by gender.  

reached 

Number and types of public 
infrastructure, including 
transport, social infrastructure 
and public utilities created. 

Number of projects providing 
direct support to facilitate the 
transition towards climate 
neutrality (renewable energy, 
decarbonisation, energy  
efficiency). 

Number of projects  fulfilling 
environmental objectives. 

External factors: 
• 
• 

Availability of public resources which can be leveraged.  
Administrative capacity of the just transition regions and potential beneficiaries.  

•  Maturity of project pipelines.  
• 

Potential beneficiaries’ capacity to make use of debt-based instruments. 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The intervention logic of the PSLF follows a structured progression from identifying needs 
to  achieving  long-term  impacts.  Needs  refer  to  the  underlying  social,  economic,  and 
environmental  challenges  that  arise  during  the  decarbonisation  process,  particularly  in 
regions  historically  dependent  on  carbon-intensive  industries.  These  needs  are  the 
foundation of the PSLF’s rationale. 

In response to these needs, the PSLF sets a general objective: to address the adverse effects 
of the green transition in just transition territories. This is further operationalised through a 
specific  objective,  which  is  to  stimulate  public  sector  investment  in  projects  that  would 
otherwise lack sufficient funding due to limited revenue generation.  

To achieve these objectives, various inputs are mobilised. Inputs are the financial, technical, 
institutional, and human resources that support implementation. In the context of the PSLF, 
these include funding from the EU budget, applicable regulatory frameworks (such as the 
PSLF and InvestEU regulations), and the expertise and administrative support provided by 
the European Commission, the European Investment Bank, and national and regional actors. 

These  inputs  enable  a  set  of  activities  designed  to  operationalise  the  Facility.  Activities 
include  raising  awareness  about  the  PSLF,  designing  and  managing  calls  for  proposals, 
evaluating and selecting projects, offering technical assistance and advisory services, and 
overseeing  grant  management  and  implementation.  These  actions  directly  support  the 
deployment of financial assistance and ensure that beneficiaries can access and effectively 
use the facility. 

As a result of these activities, tangible outputs are produced. Outputs are the direct products 
and deliverables of the intervention.  In the PSLF, these include the number and types of 
projects  supported,  the  volume  of  grants  and  loans  awarded,  and  the  construction  or 
renovation of public infrastructure. 

These outputs generate immediate and measurable effects, known as results. Results capture 
how the outputs affect the target groups or regions in the short term. For the PSLF, results 
include greater public financing mobilised in line with just transition goals, and the delivery 
of projects that actively contribute to job creation and climate neutrality. In the context of 
the PSLF, the “overall investment mobilised”, the “amount of public financing mobilised” 
and the “amount of financing mobilised from other sources” are seen as results instead of 
inputs given that the PSLF is designed to mobilise public financing. This is crystallised by 
the specific objective of the PSLF, which “is to increase public sector investments which 
address  the development  needs of the territories  identified in  the territorial  just transition 
plans.”  

Over time, these results contribute to broader, longer-term impacts. Impacts represent the 
ultimate changes the intervention seeks to bring about. In the case of the PSLF, these include 
reductions  in  greenhouse  gas  emissions,  the  creation  of  jobs,  and  the  enhancement  of 

10 

 
 
regional resilience to climate change. These impacts reflect systemic shifts that align with 
the EU’s strategic climate, cohesion and just transition policies. 

The expected impacts  of the Facility cannot  be described more precisely,  given the wide 
range of eligible sectors and its demand-based character which make it impossible to predict 
the  sectors  in  which  the  Facility  will  have  impacts.  Additionally,  the  large  number  of 
potential  sectors  supported  by  the  PSLF  makes  sector-based  metrics  impractical  for  the 
intervention logic.  

It should also be considered that the PSLF Regulation allows EU Member States and the 
Commission to define priority sectors through the Territorial Just Transition Plans, which 
are still subject to change. Consequently, selecting specific sectors for impact measurement 
may lead to inconsistencies with the priorities outlined in these plans. 

Therefore, the intervention logic employs cross-sectoral metrics to capture impacts, such as 
reductions in greenhouse gas emissions and the number of direct jobs created, categorised 
by  gender.  Furthermore,  additional  cross-sectoral  impacts  not  covered  by  the  PSLF 
Regulation  KPIs,  such  as  those  related  to  public  infrastructure  and  climate  impacts,  are 
included in the intervention logic. Currently, while the development of public infrastructure 
is defined as a milestone or a result at project level in grant agreements, the intervention 
logic does not include a programme level metric to measure support to public infrastructure. 
Cross  sectoral  metrics  such  as  “reach”  (percentage  of  the  just  transition  territories’ 
population that uses or has access to the infrastructure) and/or “utilisation rate” (proportion 
of the infrastructure's design capacity that is actively being used over a given time period) 
could be used to monitor the use of supported public infrastructure. 

2.2 Points of comparison  

The PSLF is a new instrument which was established in 2021 and therefore the current period 
of PSLF implementation cannot be compared with previous implementation periods of the 
same instrument.  

The  primary  point  of  comparison  for  the  PSLF  will  involve  assessing  its  progress  and 
outcomes  against its own benchmarks at  various stages of implementation.  This  includes 
examining  various  aspects  such  as  the  number  of  projects  supported,  sectoral  coverage, 
leverage of private and public funds, geographical coverage, environmental impact and the 
inclusion  of  less  developed  regions.  The  assessment  of  these  points  will  primarily  be 
quantitative;  however,  qualitative  evaluation  will  be  employed  where  quantitative  data  is 
unavailable. 

The comparison with other Financial Instruments (FIs) implemented under cohesion policy 
was  also  considered  but  was  not  retained.  The  scope  of  the  support  of  cohesion  policy 
financial  instruments  is  usually  specific,  whereas  PSLF  has  a  very  wide  eligibility  scope 

11 

 
 
which  makes  these  FIs  difficult  to  compare.  Moreover,  FIs  implemented  under  shared 
management typically target  financially  viable  investments  in  the private  sector, whereas 
eligible  beneficiaries  under  PSLF  are  limited  to  the  public  sector.  Furthermore,  EIB 
operations under the PSLF are relatively large. The minimum EIB loan amount of EUR 12,5 
million exceeds the size of the smaller-scale operations supported by ESIF FIs. No other FIs 
with  similar objectives to  the PSLF were identified for the purpose of comparison  in  the 
framework of this evaluation. 

Another point of comparison to assess PSLF implementation which can be considered relates 
to a counterfactual situation of what would have happened in its absence. This could be done 
by comparing a group of applicants that have applied for the PSLF grant but did not receive 
it, with the group that did apply and did receive the PSLF grant. Such a comparison would 
allow to assess the added value of the PSLF grant but is not feasible yet due to the limited 
number  of  instances  where  beneficiaries  either  withdrew  their  applications  or  saw  their 
applications  rejected,  making  the  population  of  control  group  too  small  to  reach  any 
meaningful conclusions. 

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

3.1 Current state of play of PSLF implementation  

Publication and results of the PSLF multi-annual call for proposals (2022-25) 

The  publication of the first call for proposals under the Facility was subject to the completion 
of a number of preparatory steps and the adoption of a sufficient number of TJTPs which 
eventually allowed CINEA to publish the call for proposals under the PSLF on 19 July 2022, 
with  the first  submission deadline occurring  on 19 October 2022 which was followed by 
three  submission  deadline  each  calendar  year  (January,  April,  and  September).  Only  the 
TJTPs for Greece and Cyprus had been adopted at the time the PSLF call for proposals was 
launched.  Therefore,  while  the  call  was  published,  most  potential  beneficiaries  could  not 
apply yet as their TJTPs were not adopted. Publishing the call at this date was meant to (i) 
give access to the PSLF to applicants from MS which had adopted TJTPs, (ii) allow other 
applicants  to  submit  proposals  to  the  PSLF  call  for  proposals  as  soon  as  their  respective 
TJTPs were adopted and (iii) give visibility to all stakeholders about the delivery model of 
the PSLF in order to promote its future uptake.  

The  results  of  the  call  for  proposals  (from  1st  until  the  8th  submission  deadline)  have 
occurred as follows (as shown in figure 4):  

12 

 
 
Figure 4: results of the PSLF call for proposals (until the 8th submission deadline)  

16

14

12

10

8

6

4

2

0

Submission deadlines

15

3

1

1

4

3

3

6

6

5

5

8

7

5

2

7

6

4

2

2

2

2

2

1st

2nd

3rd

4th

5th

6th

7th

8th

Submitted proposals

Eligible proposals

Selected for funding

Rejected/withdrawn proposals

Source: European Commission. 

By the 8th submission deadline, 46 project proposals have been received, 30 out of these 
(65%) were found admissible and eligible, and 17 were selected for funding by the PSLF 
evaluation  committee. After completing the due diligence process  of the  loan component 
undertaken by the EIB, 7 selected project proposals were awarded a PSLF grant after the 
signature of the loan agreement.  

Currently,  PSLF  selected  projects17  focus  on  various  infrastructure  initiatives  with  a  key 
emphasis  on  cultural,  sustainability,  energy  efficiency,  and  mobility  improvements.  In 
regions  such  as  Moravia-Silesia,  sustainable  projects  include  constructing  a  world-class 
Ostrava Concert Hall and expanding the capacity for student housing. In places like Usti nad 
Labem, efforts include the modernization of railway infrastructure and public transportation 
systems,  as  well  as  the  revitalization  of  historical  areas  to  support  tourism  and  urban 
regeneration. 

Across various European regions like Västerbotten, Hauts de France, and Provence-Alpes-
Côte d'Azur, projects target sustainable housing, green mobility, and the extension of public 
transport networks, supporting the transition to low-emission transportation and enhancing 
urban  infrastructure.  Other  initiatives  like  Mijnwater  in  The  Netherlands  focus  on 
sustainable  district  heating,  while  diverse  projects  in  Greece  and  Spain  aim  at 
socioeconomic, healthcare, and energy efficiency transitions. A detailed list of these projects 

17 Including both awarded and undergoing EIB due diligence.  

13 

 
 
 
 
and  their  KPIs  is  presented  in  Annex  VII.  By  January  2025,  an  amount  of  EUR  124,27 
million, representing 9,5% of the budget available, has been committed. 

PSLF national share uptake per EU Member State  

Selected projects18 were received from 6 different Member States: Czechia (11), France (3), 
Greece (1), Latvia (1), Spain (1), Sweden (1), and Netherlands (1). Beneficiaries from France 
and Sweden have exhausted their MS’ respective national shares, and significant uptake is 
taking place in Czechia. However, there is no uptake in the three MS with the largest national 
shares (Poland, Germany and Romania). There is no uptake of the PSLF in a majority of MS 
(20 out of 27). 

PSLF uptake per region, sector and type of support  

As shown in figure 5, most of the selected projects19 (17) are located in less developed (11) 
and transition (4) regions, while the remaining projects (2) are located in more developed 
regions.  

Figure 5: PSLF uptake in developed, transition and less developed regions. 

12

10

8

6

4

2

0

Less developed

Transition

More developed

CZ

EL

ES

FR

NL

SE

Source: European Commission. 

Regarding the type of support, 6 of the selected projects20  received are investment loans, 6 
received framework loans and 5 received intermediated loans.  

18 Including both awarded and undergoing EIB due diligence. 
19 Including both awarded and undergoing EIB due diligence. 
20 Including both awarded and undergoing EIB due diligence. 

14 

 
 
 
 
The selected projects21  cover a wide range of sectors including energy efficiency, sustainable 
district heating and cooling, urban infrastructure, urban renewal and regeneration, renovation 
and conversion of buildings, sustainable mobility, sustainable tourism, public utilities and 
social infrastructure including social housing, health and education. Even though one project 
can cover more than one sector, the most commonly supported sectors include sustainable 
mobility, energy efficiency and urban infrastructure projects. 

Use of advisory support  

Potential PSLF beneficiaries can benefit from advisory support financed by PSLF resources 
(an amount of up to EUR 35 million of PSLF resources is made available), but there are no 
restrictions  for  potential  beneficiaries  to  request  technical  assistance/advisory  from  other 
sources, such as the TSI, to support the development of their PSLF applications.  

PSLF financed advisory is implemented under the InvestEU Advisory Hub and is provided 
for  the  preparation,  development  and  implementation  of  eligible  projects.  Six  InvestEU 
Advisory Hub assignments provided under the PSLF are ongoing and one has finalised. Six 
target public sector entities and cover five Member states: including Greece, Spain, Bulgaria, 
Czechia and Romania. Three assignments are linked to capacity building, three to project 
advisory,  and  one  is  about  market  development.  The  assignments  cover  a  wide  range  of 
sectors  but  are  mostly  linked  to  energy  and  environment.  A  list  of  PSLF  advisory 
assignments paid by the PSLF budget is presented in Annex VII. 

In addition to the PSLF advisory support available under the InvestEU Advisory Hub, public 
entities in the concerned regions can benefit from other technical assistance sources paid by 
other  Union  programmes.  Greece  has  benefitted  from  technical  assistance  under  the 
Technical Support Instrument22 (TSI), the Project Advisory Support (PASSA)23 and under 
JTP Groundwork24 to submit project proposals to PSLF. At their request, other EU Member 
States such as Slovakia and Czechia have received external consultancy services financed 
by  cohesion  policy  funds  resources  to  disseminate  information  about  the  PSLF  and  to 
develop potential project proposals.  

21 Including both awarded and undergoing EIB due diligence.  
22 The Technical Support Instrument (TSI) is an EU programme that provides tailor-made technical expertise 
to EU Member States to design and implement reform. More information is available at: 
https://commission.europa.eu/funding-tenders/find-funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en  
23  Project  Advisory  Support  Service  Agreement  (PASSA)  is  a  bilateral  Agreement  between  EIB  and  the 
Hellenic  Republic  to  support viable  projects  in  the fields  of  Climate  Action  and  Just  Transition.  PASSA  – 
Project Advisory Support Service Agreement. 
24  JTP Groundwork is a capacity building support which helps TJTP regions to implement their TJTPs, 
delivering tailored support, based on the needs that regions have identified.  

15 

 
 
 
Communication activities 

The Commission, in close cooperation with CINEA and the EIB, raised awareness about the 
PSLF through joint actions. From July 2022 until January 202525, there were 79 meetings 
with  representatives  of  25  Member  States  at  national,  regional  and/or  local  levels,  39 
meetings  within  EU  institutions  (e.g.  different  services  of  the  European  Commission, 
Committee  of  Regions)  and  with  external  stakeholders  (think-tanks,  civil  society 
organisations,  associations,  national  promotional  banks  and  institutions).  PSLF  was 
presented during 31 topic-related events (presentations, Q&A sessions, dedicated stands). It 
was also included in 2 brochures, 185 posts in topic-related newsletters and websites as well 
as social media, 76 FAQs on Funding & Tenders portal, four video messages recorded by 
the Commissioner in charge of Regional and Urban Policy and two Info Days, each with 
around  300  participants.  The  CINEA  public  dashboard  also  presents  all  programmes  it 
currently manages with information on approved projects26.  

Decrease in the PSLF budget 

The PSLF Regulation provides for a total maximum budget of EUR 1.525 billion of Union 
support for the grant component of the Facility (including technical assistance and advisory 
support) combined with a maximum of EUR 10 billion of EIB loans. However, in February 
2024, in the context of the mid-term revision of the Multiannual Financial Framework, an 
overall EUR 1.1 billion redeployment was decided from the direct and indirect management 
components of CAP and Cohesion policy funds. Consequently, the budget of the PSLF grant 
component was reduced by EUR 150 million and the PSLF national shares were reduced 
proportionally.  After  these  redeployments,  the  maximum  budget  available  for  the  PSLF 
grant component was recalculated at EUR 1.3125 billion together with the estimated EIB 
loan contribution ranging between a maximum of EUR 6 billion and EUR 8 billion.  

Efforts to facilitate the accessibility of the PSLF for smaller beneficiaries and projects, as 
well as to have more intermediated loans with National Promotional Banks and Institutions 
(NPBIs) have been undertaken jointly by the Commission and the EIB by revising the initial 
rules  of  the  PSLF.  Firstly,  the  minimum  intermediated  loan  amount  was  decreased  in  an 
agreement between the Commission and the EIB from EUR 3 million to EUR 1 million since 
September 202327. Secondly, the limitation included in the administrative agreement related 
to NPBIs involvement in the implementation of the PSLF as EIB financial intermediaries 
has been lifted. To that end, the administrative agreement between the Commission and the 
EIB was amended.  

25 External awareness raising activities with potential beneficiaries started after the parameters for PSLF 
implementation were agreed. 
26 CINEA Project Portfolio - Welcome | Sheet - Qlik Sense (europa.eu) 

27 See the amendment to the PSLF call for proposals introduced on 25 September 2023. 

16 

 
 
 
Delegation of the PSLF implementation to CINEA 

The  management  of  certain  aspects  of  the  PSLF  was  delegated  by  the  Commission  to 
CINEA,  in  particular  those  related  to  the  management  of  the  calls  for  proposals,  grant 
implementation  and  monitoring,  and  awareness  raising  about  the  call  for  proposals, 
including organising Information Days and other promotional events in coordination with 
the Commission and the EIB. The division of tasks between the Commission and CINEA 
was  established  by  a  Memorandum  of  Understanding  signed  on  5  September  2022.  The 
Commission remains fully responsible for all policy-related aspects.  

CINEA  has  implemented  its  tasks  in  line  with  the  abovementioned  Memorandum  of 
Understanding. It is worth mentioning that the time taken by CINEA to inform applicants of 
the outcome of the evaluation of their applications after they have been submitted them to 
the  call  for  proposals  has  been  on  average  3  months,  which  is  lower  than  the  maximal 
duration of 6 months stipulated in the Financial Regulation. The average time to grant is 3 
months and is subject to the time taken by EIB’s due diligence of the application (up to 18 
months).  An evaluation of all executive agencies  including  CINEA has been launched  in 
2024. 

4.  TO WHAT EXTENT WAS THE INTERVENTION SUCCESSFUL AND WHY?  

4.1. Effectiveness 

This  section  examines  the  implementation  of  the  PSLF’s  budget,  advisory  support, 
communication  activities  and  the  operationalisation  of  the  regulation  by  the  European 
Commission.  

Implementation of the PSLF budget 

This  section  aims  to  address  article  17(2)(a)  of  the  PSLF  Regulation  indicating  that  “the 
interim evaluation shall in particular assess […] (a) the extent to which the Union support 
provided under the Facility contributed to address the needs of territories implementing the 
territorial just transition plans.” 

The selected projects28, submitted up to January 2025 are expected to mobilise approximately 
EUR 228 million in grants (17% of the budget of the grant component) and EUR 1.4 billion 
in  loans  from  the  EIB.  Eligible  applications  have  been  submitted  by  applicants  from  6 
Member States. This uneven geographic demand is affected by  a varying combination of 
factors which have been identified based on the literature review and interviews:  

•  Overlap with other co-financing sources offering better conditions for the same type 
of investments: the first years of PSLF implementation have coincided with (i) the 

28 Including both awarded and undergoing EIB due diligence.  

17 

 
 
 
final  years  of  the  implementation  of  2014-2020  cohesion  policy  funds  where 
unconsumed  funds  were  at  risk  of  decommitment,  (ii)  the  launch  of  the  RRF,  a 
performance-based  instrument,  for  which  failure  by  Member  States  to  fulfil  pre-
agreed milestones and targets may lead to decommitment of Next Generation EU29 
funds  in  2027  and  (iii)  the  beginning  of  the  2021-2027  programming  period  for 
cohesion funds, including the JTF. Besides the time constraints, these instruments  
offer  a  higher  grant  co-financing  rate  for  similar  investments,  often  making  them 
more  attractive  than  the  PSLF.  Furthermore,  in  some  MS  such  as  Germany, 
stakeholders  can  benefit  from  favourable  funding  conditions  from  a  national 
instrument. 

•  Administrative capacity crunch: the pressure on administrative capacity of Member 
States’ public authorities caused by the management of the abovementioned funds 
also  plays  a  role,  leading  some  Member  States,  such  as  Romania  and  Poland,  to 
prioritise  the  funding  instruments  facing  tighter  time  constraints  and/or  offering  a 
higher grant co-financing rate over the PSLF.  

•  Project pipeline maturity: the unavailability of a mature project pipeline before the 
PSLF  was  launched  may  have  delayed  its  implementation,  as  does  the  limited 
planning  or  programming  for  the  just  transition  before  the  PSLF  Regulation  and 
TJTPs were adopted. 

•  Potential applicants’ financial constraints: potential beneficiaries’ pre-existing levels 
of  indebtedness  as  well  as  restrictive  legal  frameworks  affect  their  capacity  to 
subscribe to additional loans in the framework of the PSLF. Furthermore, applicants 
are required to co-finance PSLF supported investments, which they may not be in a 
position to do. 
Ineligibility  of  projects  benefitting  from  co-financing  from  other  EU  sources: 
projects receiving an EU grant under the PSLF cannot receive co-financing under 
other  Union  programmes.  Interviews  with  potential  beneficiaries  and  other 
institutional  actors  suggest  the  combination  of  PSLF  with  other  EU  instruments 
could have facilitated the uptake of the Facility.  

• 

•  Timing of the adoption of TJTPs: most TJTPs were adopted in the last  quarter of 
2022, i.e. after the publication of the call for proposals and after the first submission 
deadline which also explains the low number of proposals submitted within the first 
submission deadlines. 

The EIB has also highlighted a number of constraints with potentially severe impact on the 
deployment of the Facility due to its demand driven nature, namely the timing of adoption 
of  the  TJTPs  (which  is  completed  in  the  meantime),  geographical  fragmentation  and 
expected  small  project  size,  lack  of  financial  attractiveness  given  the  low  grant  rate  and 

29  NextGenerationEU  is  a  groundbreaking  temporary  recovery  instrument  to  support  Europe’s  economic 
recovery from the coronavirus pandemic and build a greener, more digital and more resilient future. 

18 

 
 
 
prohibited combination  with  other  JTM pillars  and EU  funding sources,  and  the national 
shares which are applicable until 2025, limiting PSLF’s ability to follow market demand. 

Figure  6  as  presented  below,  which  is  based  on  the  survey  of  stakeholders,  shows  the 
perception of the relative importance of factors and how they might have influenced PSLF 
uptake.  Responses  have  been  examined  using  an  index30.  Higher  values  mean  a  greater 
influence of the factor. The findings should be interpreted with caution because the survey 
was completed by a sample of stakeholders that is non-representative and self-selected. This 
limitation is due to the restricted pool of informed stakeholders available for consultation on 
the PSLF. Additional details on this issue are provided in Annex II. 

Figure  6:  The  extent  to  which  the  uptake  of  the  PSLF  has  been  influenced  by  evolving 
circumstances.  

Source: Supporting Study.  

62% (33 out of 53) of the surveyed local, regional and national authorities indicated that the 
PSLF uptake is affected by their insufficient administrative capacity to a (very) large and 
some extent. 55% (29 out of 53) of them said that PSLF uptake is affected by the overlap 
with other funding sources offering better financing conditions to a (very) large and some 
extent. 66% (35 out of 53) of them reported that PSLF uptake is affected by the availability 
of limited mature projects to a (very) large and some extent.  

30 The index rates how much each circumstance influenced the uptake of PSLF on a scale from one (‘to no 
extent’) to five (‘to a very large to extent’). Each response is rated from one (‘to no extent’) to five (‘to a very 
large extent’), and the sum is divided by the total number of responses. 

19 

2.472.552.782.792.963.063.263.383.53 Shortage of skills and labour. PSLF eligible sectors not in line with investment prioritiesof the EU Member State at national, regional or local level. Energy crisis and high construction prices. High loan interest rates. No other sources of co-financing available to combine withthe PSLF grant and the PSLF loan. Regulatory/legal restrictions to subscribe to debt. Limited mature projects available to absorb the availablefunding. Overlap of the PSLF with other funding sources offeringbetter financing conditions. Difficulty to apply/insufficient administrative capacity toapply to the PSLF. 
 
 
 
There  is  currently  no  conclusive  evidence  concerning  how  these  factors  affect  some 
territories more than others, in particular concerning how they affect less developed regions 
in contrast to other regions. Most of the eligible applications submitted to the PSLF (18 out 
of 30) relate to less developed regions, which at least allows to conclude that these regions 
can access the PSLF.  

In  addition  to  the  above-mentioned  factors  affecting  the  implementation of  the  PSLF,  an 
unintended effect which has been identified in France is the concentration of investments at 
MS level in one sector. Projects awarded under the first call of proposals (2022-25) were 
mainly  green  mobility  projects  in  France,  in  particular  the  renewal  of  rolling  stock.  This 
unintended focus of the PSLF in France likely arose because such investments were excluded 
in the scope of cohesion policy funds and other national or European instruments but could 
be covered by the PSLF.   

Overall,  in  terms  of  the  expected  sectoral  allocation  of  applications  and  investments, 
surveyed  stakeholders  indicated  that  they  are  implementing  PSLF  supported  projects  or 
intend to request PSLF support mainly for projects related to renewable energy and energy 
efficiency,  but  also  for  other  sectors  such  as  urban  infrastructure,  social  infrastructure 
including social housing, transport and digitalisation among others.  

Figure 7: Sectors in which surveyed PSLF stakeholders intended implement or implement 
project supported by the PSLF.  

Source: Supporting Study. 

20 

122333556918Other.Circular economy.Land and ecosystem restoration.Up-skilling, reskilling and training.Environmental infrastructure.District heating networks.Digitalisation.Transport.Social infrastructure, including social housing.Urban infrastructure.Renewable energy and energy efficiency. 
 
 
The  inclusion  of  the  PSLF  in  the  TJTPs  has  created  a  clear,  understandable  and  formal 
reference for policy makers, national and regional authorities and potential applicants. The 
TJTPs set an indispensable just transition strategy for PSLF applicants to refer to and with 
which their applications should be in line. TJTPs also guide the EIB’s work on identifying a 
project pipeline for the PSLF. 

Interviews  with  the  Commission  and  EIB  institutional  representatives,  local  and  national 
authorities, and the literature review highlight specific factors limiting the use of debt-based 
instruments.  In  Romania,  local  authorities  and  especially  smaller  municipalities,  have 
existing debt that hinders their access to PSLF. Romanian local authorities can exceed the 
legal borrowing limit if the funds are used to co-finance projects supported by EU Funds. 
However, this exception does not apply to PSLF, and interviewees reported that this issue is 
being analysed. Similar concerns emerged regarding Czechia, where the use of debt-based 
instruments  largely  depends on the regional/local fiscal  situation.  In general,  pre-existing 
levels of debt, in particular when its level reaches legal ceilings, may discourage or forbid 
local  authorities  from  applying  for  PSLF.  As  highlighted  in  the  case  study,  Czech  debt 
thresholds limit the budget capacity of local authorities, especially smaller ones. 

National  legislation  and  institutional  organisation  regarding  the  use  of  debt  by  public 
authorities also affects the uptake of debt-based or blended instruments such as the PSLF. 
As  an  example,  the  Greek  legislative  framework  stipulates  that  the  EIB  can  sign  a  loan 
agreement  only  with  the  Ministry  of  Finance  at  national  level.  For  local  authorities, 
according to  interviewees, this curtails their ability  to  establish a loan agreement directly 
with the EIB. 

For signed projects, the grant has covered between 5% and 18% of the total investment costs, 
while the loan has covered between 31% and 73% of the total costs. It follows that the main 
driver of the PSLF’s value for its beneficiaries are the parameters of the EIB loan. Potential 
applicants will compare the interest rate, the loan duration, the amount of financing and the 
overall adequacy of the EIB loan negotiation process in meeting their needs compared to the 
loan parameters offered by commercial banks. While the PSLF is in principle well placed to 
offer more attractive repayable financing conditions by combining EIB loans and EU grants, 
commercial banks are typically quicker to provide a loan, offer simpler procedures and can 
benefit from established relationships with their public sector clients.  

In line with the EIB’s lending policies, the amount requested for EIB framework loans and 
investment  loans  should be  at  least  EUR  12.5  million.  This  usually  covers  up  to  50%  of 
project costs of about EUR 25 million. While this EIB policy is not specific to the PSLF, it 
can  be  a  significant  entry  barrier  for  municipalities  with  small  projects  and  limited 
administrative capacity preventing them from taking up a coordinating role. For framework 
loans,  in  addition  to  the  minimal  EUR  12.5  million  amount,  one  organisation  has  to 
coordinate and negotiate the loan for a group of beneficiaries, which requires administrative 

21 

 
 
capacity, or one beneficiary needs to have a set of its own projects that reach the minimum 
budget.  However,  smaller  projects  are  benefitting  from  PSLF  support:  out  of  17  projects 
selected  to  date,  5  projects  receive  intermediated  loans  ranging  from  EUR  1.5  million  to 
EUR 12 million. Framework loans signed in Greece and Sweden relate to sets of smaller 
projects. Moreover, efforts have been made to more easily reach smaller beneficiaries by 
lowering the floor which was defined at the outset of PSLF implementation, EUR 3 million, 
to EUR 1 million as explained in Chapter 3. 

A possible solution to high minimum loan size and coordination issues could be a higher 
engagement  from  NPBIs  and  a  higher  use  of  financial  intermediation.  At  this  stage, 
intermediated lending is only available in France and Czechia. Loans requested through EIB 
financial intermediaries can be as low as EUR 1 million, significantly reducing the threshold 
for  smaller  size  projects.  While  initial  results  from  Czechia  seem  promising,  no  NPBIs 
outside of Czechia and France have informed the Commission of their interest in offering 
intermediated lending under the PSLF, despite multiple contacts between the Commission 
and  NPBIs.  This  was  explained  by  NPBIs  primarily  by  the  fact  that  they  are  perceiving 
limited demand for PSLF funding from their clients and/or by limited incentives for NPBIs 
to  get  involved  in  the  implementation  of  the  PSLF,  due  to  factors  such  as  the  terms  of 
financial intermediation set by the EIB and the onboarding costs which NPBIs would have 
to incur to begin offering PSLF supported financial products. 

Concerning the future uptake of the Facility, it is challenging to assess whether there will be 
sufficient applications submitted to absorb the budget available. While the full use of the 
grant allocation is not expected to be achieved within the first call for proposals (open until 
2025), it is still possible within the second call for proposals. Factors supporting the uptake 
of the PSLF from 2026 will be that national shares will no longer apply and that the Facility 
will  be  better  known  among  potential  applicants  thanks  to  the  numerous  communication 
activities undertaken to date. The extent to which other overlapping EU and national funds 
are programmed or consumed will also be a decisive factor. However, the second call will 
only be open for two years (2026-27), leaving potential applicants with less time to apply 
compared  to  the  first  call.  In  addition,  given  the  challenges  facing  the  Facility,  the  EIB 
anticipated  the  risk  that  financing  volumes  and  investment  mobilised  might  fall  short  of 
political expectations. 

Application of eligibility conditions under PSLF 

This  section  addresses  the  eligibility  conditions  under  PSLF  responding  in  particular  to 
Article  17(2)(d)  of  the  PSLF  Regulation  indicating  that  “the  interim  evaluation  shall  in 
particular assess […] (d) the application of the eligibility conditions set out in Article 9”. 

The eligibility conditions as set out in Article 9 of the PSLF Regulation are part of the multi-
annual  call  for  proposals  (2022-2025)  which  is  aligned  with  PSLF  applicable  legal 
framework,  including  the  PSLF  Regulation  and  the  Financial  Regulation.  The  call  for 

22 

 
 
proposals explicitly refers to the general and specific objectives of the PSLF regulation. It 
specifies  the  type  of  investments  that  are  eligible  for  funding  under  PSLF  following 
preamble  6  of  PSLF  Regulation.  It  also  includes  types  of  investment  which  are  not 
necessarily mentioned in the call but are in line with approved TJTPs and are not excluded 
by Article 9 of the PSLF Regulation. The PSLF call for proposals is also in line with the 
PSLF  regulation’s  requirements  for  horizontal  principles  and  introduces  prioritisation 
criteria  as  stipulated  in  the  Regulation  (Article  14(2)).  The  call  text  also  excludes  those 
projects that do receive support under any other Union programme and do generate sufficient 
streams of revenues to cover their investments costs. Beyond ensuring that PSLF supported 
investments reach the entities and sectors targeted by the Regulation, no specific benefits, 
shortcomings or unintended effects have been identified during the application of the PSLF’s 
eligibility conditions.  

Effectiveness of advisory support 

The advisory component of PSLF is implemented by the EIB as part of its InvestEU advisory 
Hub  mandate  which  is  a  joint  EIB-EU  programme  established  under  the  InvestEU 
Regulation31. Advisory support can be provided in the forms of (1) project advisory for the 
identification, preparation, development and implementation of eligible projects, including 
assistance  in  preparing  PSLF  grant  applications;  (2)  capacity  building  to  eligible 
beneficiaries; and (3) market development by raising awareness of potential beneficiaries 
and relevant stakeholders. 

The  effectiveness  of  the  InvestEU  Advisory  Hub  as  a  whole  has  been  assessed  in  the 
framework of the interim evaluation of the InvestEU programme concluding that it is too 
early  to  assess  given  that  many  advisory  assignments  are  still  in  progress  or  under 
preparation.  The  early  implementation  stage,  combined  with  the  lack  of  availability  of 
quantitative data on assignments, together with the limited time and budget available has 
restricted the depth of analysis of individual advisory Hub initiatives, including under the 
PSLF. 

Although the PSLF advisory support is free of charge for the beneficiaries, its demand is low 
in  comparison  to  the  available  resources  with  6  ongoing  advisory  assignments  and  one 
completed  in  January  2025.  The  only  completed  assignment,  provided  to  the  A  Coruña 
Public University Hospital, had the objective of supporting the applicant to draft its PSLF 
grant application. The corresponding application was subsequently submitted and selected 
by the PSLF evaluation committee.  The other 6 assignments have not been evaluated yet 
because they were only recently launched, between July 2023 and November 2024, and all 
of them are still ongoing. 

31 Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the 
InvestEU Programme and amending Regulation (EU) 2015/1017, available at: Regulation - 2021/523 - EN - 
EUR-Lex 

23 

 
 
 
According  to  the  EIB,  the  main  challenge  for  PSLF  advisory  support  has  been  the  low 
demand for repayable financing instrument, coupled with the fact that early beneficiaries of 
PSLF were able to present already mature projects with no need for comprehensive advisory 
support. As a result, demand for advisory support has fallen short of initial expectations. 
Preliminary findings from several interviews with actors from EU institutions and the EIB 
suggested that an increased use of advisory support would help increase the uptake of PSLF 
and the quality of applications, especially for smaller local public authorities. In Romania 
for  example,  advisory  services  are  expected  to  mobilise  local  actors  and  support  the 
development of a PSLF project pipeline in Romania.  

Additional evidence about the EIB advisory services has been collected within the remit of 
the  interim  evaluation  of  the  InvestEU  programme32.  This  evaluation  did  not  analyse  the 
implementation of PSLF assignments in particular and it indicates that it is too early to fully 
assess  the  impact  of  the  Advisory  Hub.  However,  preliminary  findings  highlight  its 
beneficiaries’ satisfaction with the quality of the services provided by the EIB. 

The EIB Group Evaluation of EIB advisory activities in the European Union from 202333, 
another related evaluation, mentions that advisory support has contributed to improving the 
quality  of  project  documentation  and  design,  and  that  projects  supported  by  advisory 
activities were better aligned with EU policy priorities and embedded into wider sectoral or 
spatial development strategies. Both evaluations conclude, however, that the EIB’s advisory 
offer lacks visibility, which may affect the effectiveness of advisory support available under 
the PSLF. 

It is too soon to assess the impact of advisory on administrative capacity of beneficiaries. It 
is however expected that there will be a limited number of assignments focused specifically 
on administrative capacity supported under the PSLF given the limited demand for this type 
of assignment up to now. Currently, the demand for PSLF advisory is focused on application 
support, market analysis, project identification and investment planning. 

Effectiveness of communication  

This section assesses the effectiveness of communication and aims to respond in particular 
to Article 17 (2)(d) of the PSLF Regulation indicating that “the interim evaluation shall in 
particular assess […] (d) how the visibility obligations were applied.”  

PSLF is a new instrument in the 2021-2027 programming period, therefore communication 
and  information  actions  were  key  to  promoting  its  uptake.  Survey  results  suggest  that 

32Commission  Staff  Working  Document  SWD(2024)  229,  available  at:  https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13770-InvestEU-programme-interim-evaluation_en    
33Evaluation  of  EIB 
(2023), 
https://www.eib.org/en/publications/20230211-evaluation-of-eib-advisory-activities-in-the-eu  

the  European  Union 

activities 

available 

advisory 

in 

at: 

24 

 
 
 
 
communication  has  been  effective,  with  67%  of  respondents  (47  of  70)  feeling  informed 
about PSLF to a large or to some extent. 75% (27 of 36) respondents from a TJTP territory, 
feel informed to a large or some extent. 62% (33 out of 53) of the surveyed local, regional 
and national public authorities feel informed about the PSLF to a (very) large and to some 
extent, while 26% (14 out of 53) of them feel informed to little or no extent.   

Figure 8: The extent to which respondents feel informed about the PSLF.  

Source:  Supporting Study. Note: the absolute number of responses is in brackets. 

Most respondents received information from the Commission and/or CINEA (38 of 69). This 
is  followed by the EIB (25 of  69).  In this regard, the combination of an  already  existing 
network within the Commission under the shared management funds and the EIB network 
of representative offices across the EU has been instrumental to raise awareness about the 
PSLF. Some respondents received information from national (13 of 69), regional (12 of 69) 
and local authorities (10 of 69).  

25 

To a very large extent.To a large extent.To some extent.To little extent.To no extent.27% (19)36% (25)27% (19)6% (4)4% (3) 
 
Figure 9: From whom information about the PSLF was received. 

Source: Supporting Study. 

The ability to communicate with the Commission in their native language was  highlighted 
as positive by national, regional and local public authorities and beneficiaries appreciated 
the  availability  of  contact  persons  to  address  questions  about  the  grant  applications.  
However,  despite  multiple  efforts  by  the  Commission  and  CINEA  to  accommodate  the 
language needs of potential applicants, feedback suggests that the language barrier remains 
a challenge for some stakeholders.  

Before  communication  activities  took  place,  the  TJTPs  created  a  first  step  of  awareness 
raising  about  the  PSLF  in  the  eligible  just  transition  regions.  Cohesion  policy  managing 
authorities  and  other  national  contact  points  were  engaged  with  the  plans  which,  in  turn, 
helped spread awareness and information about the PSLF. In addition, the involvement of 
civil society and other actors in the adoption process of the TJTPs might have also further 
increased knowledge about the PSLF.  

Member States help raise awareness about the PSLF, but their level of involvement varies 
since the PSLF is implemented in direct management mode with no formal role for national 
authorities (unlike shared management). As shown by the survey, there is an indication that 
some  national  authorities  are  less  engaged  in  PSLF  implementation  since  respondents 
receive relatively less information about PSLF from national, regional or local authorities 
(as explained above). 

Where national authorities support the PSLF uptake, project applications seem to be mature 
and  successful.  For  example,  the  Swedish  Agency  for  Economic  and  Regional  Growth 
(Tillväxtverket) was very important to explain how PSLF works to Swedish stakeholders. In 
supported  PSLF 
Greece, 

the  Regional  Administration  of  Western-Macedonia 

26 

3510121325380510152025303540Third-party interest groupOther.Local authority of EU Member State.Regional authority of EU Member State.National authority of EU Member State.EIB.European Commission and/or CINEA. 
 
  
implementation by acting as a beneficiary and co-signing the grant agreement of the first 
PSLF project.  

Finally,  visibility requirements to  be implemented by beneficiaries of the PSLF have not 
been assessed as a part of this evaluation because of the early stage of implementation of 
their projects.  

Horizontal principles and gender impact 

This section aims to respond to Articles 17(2) of the PSLF Regulation indicating that “the 
interim evaluation shall in particular assess […] (b) how the horizontal principles referred to 
in  Article  4  were  taken  into  account”  and  (c)  “the  need  to  carry  out  a  gender  impact 
assessment”. 

Article 4 of the PSLF Regulation states that SDGs, the ‘polluter pays’ principle, the Paris 
Agreement  and  the  ‘do  no  significant  harm’  principle  should  be  taken  into  account 
throughout the preparation and implementation of eligible projects. Respect for fundamental 
rights  and  compliance  with  the  Charter  of  Fundamental  Rights  of  the  European  Union 
(‘EU’), in particular gender equality and accessibility for persons with disabilities are also 
to  be  ensured.  Horizontal  principles  described  in  the  PSLF  Regulation  (Article  4)  are 
integrated in the implementation and the management of the PSLF in four ways:  

•  Applicants must provide a declaration of compliance with eligibility requirements.  
•  Applicants are required to outline measures to be taken and the policies in place to 
guarantee full compliance with the EU values mentioned in Article 2 of the Treaty 
on the European Union  and Article 21 of the EU Charter of Fundamental  Rights, 
explain  the  project’s  impact  on  gender  equality,  how  it  will  ensure  to  avoid  any 
discrimination based on gender racial or ethnic origin, religion or belief, disability, 
age or sexual orientation throughout the implementation of the project  and how  it 
will  ensure  gender  mainstreaming  in  the  project  activities.  The  evaluators  assess 
proposals concerning compliance with the do no significant harm principle on the 
basis of the “relevance and impact” criterion defined in the call for proposals. 

•  Horizontal principles are enshrined in grant agreements. Articles on ethics and values 
provide the legal framework to assess and potentially terminate agreements which 
would be in violation of horizontal principles. 

•  Finally, beneficiaries must report on the implementation of their project in line with 
their  signed  Grant  Agreements.  In  particular,  beneficiaries  must  indicate  how  the 
compliance with horizontal principles was ensured.  

Applicant’s declarations and the beneficiaries’ approach to horizontal principles are assessed 
during the evaluation of the proposals and during implementation via the periodic reporting 
submitted by the beneficiaries themselves and on the spot monitoring missions.  

27 

 
 
In  addition,  as  part  of  its  sustainability  policy  in  due  diligence  procedures34  35,  the  EIB 
appraises and monitors all projects and intermediated operations based on environmental, 
social and governance (‘ESG’) criteria. Only activities that meet  EIB’s sustainability due 
diligence requirements and serve EU policy objectives for smart, sustainable and inclusive 
growth can be financed.  

For some signed grant agreements, a clear gender mainstreaming approach is incorporated. 
For example, the green mobility project in Nantes (FR) will take several actions towards an 
integrated equality approach, in particular to ensure a gender security dimension in the use 
of public transport, but also to achieve a gender balanced participation in employment and 
training.  The  housing  project  in  Skelleftea  (SE)  intends  to  align  the  project  with  its 
overarching policy for gender equality. Other types of projects signed under PSLF concern 
interventions that will not have a direct bearing on gender equality. This is for example the 
case for the reconstruction of the railway bridges in Usti nad Labem region (CZ). 

Two  regulatory  KPIs  provide  data  which  is  disaggregated  by  gender.  In  terms  of  the 
estimated number of jobs created by the PSLF for the signed grant agreements, 50% (2870 
out of the 5745) are intended by applicants to be filled by women. In terms of the individuals 
which should be reached by the signed PSLF projects, 52% (1.237.232 out of 2.450.527) are 
estimated to be women. These figures however do not reveal the type and quality of the jobs, 
nor the impact expected to be reached on gender by the PSLF. More generally, due to early 
stage of implementation, a gender impact assessment is not possible yet.  

Whenever relevant, signed PSLF projects declare they will take the necessary accessibility 
measures,  taking  into  account  EU  and  national  standards  applicable  in  this  regard.  An 
example is the Ostrava Concert Hall project (CZ), for which the beneficiary intends to take 
several targeted actions during the construction and the implementation phase of the project 
to  ensure the  accessibility of the building  and its outdoor areas  for persons  with  reduced 
mobility.  

Contribution to environmental objectives 

This section aims to respond to article 17(2)(e) of the PSLF Regulation indicating that “the 
interim evaluation shall in particular assess […] (e) on the basis of the projects supported by 
the Facility, the extent to which the Facility contributed to the environmental objectives laid 
down  in  Article  9  of  Regulation  (EU)  2020/852  of  the  European  Parliament  and  of  the 

Investment  Bank  Environmental 

34European 
https://www.eib.org/en/publications/eib-environmental-and-social-standards   
35EIB  Group  Sustainability  Report 
https://www.eib.org/en/publications/20230334-eib-group-sustainability-report-2023  

and  Social  Standards 

published 

2023 

July 

25 

on 

(2022), 

available 

at: 

2024, 

available 

at: 

28 

 
 
 
Council36,  taking  into  account  the  applicable  screening  criteria  provided  for  in  that 
Regulation.” 

It is important to note that not all investments supported under the PSLF will directly lead 
to reduction of CO2 emissions.  Just transition investments enable the multiple transitions 
needed  to  address  the  socio-economic  impact  of  the  green  transition,  responding  to  local 
needs. The underlying investment projects will therefore concern climate action for some 
projects  and  be  climate-neutral  or  at  least  do  no  significant  harm  for  others.  Some  just 
transition projects that do not lead to a direct reduction in CO2 emissions might still score 
high on environmental sustainability by contributing to the EU’s objectives regarding the 
green transition. 

Four out of the seven projects supported by the PSLF declare that they will contribute to 
CO2 emissions reduction. The framework loan for socioeconomic transition in the Greek 
region  of  Western  Macedonia  will  increase  public  infrastructure  energy  efficiency  and 
renewable energy production using photovoltaic panels in public buildings (estimated 8.650 
tonnes per year CO2 reduction). The three transport projects in France all support the use of 
energy efficient public transport and public infrastructure, as well as cycling paths (estimated 
127.155 tonnes per year CO2 reduction).  

Two out of the seven projects supported by the PSLF will not contribute directly to CO2 
emissions  reduction  because  they  consist  in  the  construction  of  new  buildings:  the 
construction of a concert hall in Czechia and of housing in Sweden. However, these new 
buildings will have environmental standards exceeding legislative requirements, and include 
innovative features maximising their energy efficiency, use of renewable energy resources, 
and features of circular economy. 

The remaining project focusing on the improvement of the operability of railway lines for 
daily  commuting  in  the  Usti  nad  Labem  region  does  not  declare  a  contribution  to  the 
attainment  of  environment  objectives,  besides  a  slight  reduction  in  sound  pollution.  The 
expected  enhancement  of  the  quality  and  safety  of  both  passenger  and  freight  railway 
transport  could  however  support  the  use  of  public  transport  instead  of  more  polluting 
alternatives. 

The  project  to  extend  the  North-South  tramway  line  in  Marseille,  France  also  intends  to 
provide  further  types  of  contribution  to  environmental  objectives,  such  as  landscaping  to 
promote thermoregulatory spaces, increasing green spaces by 65% in highly urbanised areas 
and promoting biodiversity.  

36  Regulation  (EU)  2020/852  of  the  European  Parliament  and  of  the  Council  of  18  June  2020  on  the 
establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088, 
available at: Regulation (EU) 2020/852 of the European Parliament and of t... 

29 

 
 
 
Effectiveness of the PSLF’s monitoring framework 

The monitoring framework of the PSLF is described in annex VIII of this SWD.  

The  implementation  of  the  PSLF  is  demand  driven  and  has  a  wide  sectoral  eligibility, 
therefore the precise type of projects and sectors by which it will “address serious social, 
economic and environmental challenges deriving from the transition towards the Union’s 
2030 climate and energy targets and the objective of climate neutrality in the Union by 2050” 
was not known at the time of the adoption of the PSLF Regulation, nor is it known now. The 
possibility of monitoring an extensive list of every possibly relevant KPI is burdensome and 
provides little added value or possibility of aggregation generating meaningful data on the 
achievement of the PSLF’s objectives. Therefore, the PSLF Regulation is focused on two 
cross cutting  KPIs to  measure  the impact  of  its  general  objective which  go to  the  central 
elements of just transition: job creation and greenhouse gas emissions reduction.   

Furthermore,  given  the  limited  budget  of  the  PSLF  per  MS  and  its  supported  projects, 
recurring to the use of macro-economic indicators such as (un)employment, activity levels 
(gross value added), etc. is not feasible due to the methodological challenge of establishing 
a  clear  link  of  causality  between  the  proportionally  small  impact  of  the  PSLF  on  such 
indicators. Even in the case of France, where the entire national share was consumed during 
the first call for proposals via an unexpected concentration of investments in the sector of 
transport  and  mobility,  the  aggregated  effect  of  the  three  PSLF  supported  projects  is  not 
expected to have a measurable impact on macro-economic indicators. This assessment is not 
expected to change as the implementation of PSLF progresses, since the distribution of PSLF 
resources among sectors and Member States is highly likely to remain broad. 

However, the specific objective to “increase public sector investments (...) by facilitating the 
financing  of  projects  that  do  not  generate  sufficient  streams  of  revenues  to  cover  their 
investment costs, in order to prevent the replacement of potential support and investment 
from alternative resources” is appropriately measured, in particular through KPIs related to 
the  “overall  investment  mobilised”.  Data  on  the  sector  and  location  of  the  investments 
supported will also be collected. As such, it will be possible to differentiate impact analysis 
across levels of execution and sectors of the investment. 

As indicated under point 2.1, the Facility can fund critical projects that upgrade and develop 
infrastructure  needed  for  a  low-carbon  economy.  While  the  development  of  public 
infrastructure is identified as a milestone or outcome at the project level in grant agreements, 
the monitoring framework currently lacks a program-level metric to gauge support for public 
infrastructure.  The  final  evaluation  will  also  provide  a  comprehensive  analysis  of  the 
quantity and types of public infrastructure supported, along with their alignment with the 
just transition  strategies  specified in  the Territorial  Just Transition  Plans.  In addition,  the 
utilisation rate (the extent to which the infrastructure's full capacity is used over a specific 
period) of the supported infrastructures should be measured  to monitor the use of funded 

30 

 
 
public  infrastructure.  This  is  also  expected  to  be  carried  out  in  the  context  of  the  final 
evaluation  given  that  the  Commission’s  support  usually  ends  once  the  infrastructure 
becomes operational, leaving to means to monitor the utilisation rate during implementation 
to the Commission. 

Finally, “ensuring advisory support for the preparation, development and implementation of 
eligible projects, where necessary, including support for the preparation of projects prior to 
the submission of the application” is not measured by regulatory KPIs but appropriate data 
on  the  assignments  as  described  in  annex  VIII  of  this  SWD  will  be  available  via  data 
provided by the InvestEU Advisory Hub.  

An overall weakness of the PSLF monitoring framework is that the general objective, the 
specific objective and the KPIs do not currently have targets. This shortcoming is further 
addressed in annex VIII to the SWD, where targets are put forward for several of the PSLF’s 
regulatory  KPI,  including  for  the  volume  of  grants  awarded,  the  overall  investment 
mobilised, the number of projects receiving financing under the Facility,  Greenhouse gas 
emission reductions and job creation. 

Furthermore, the monitoring framework of the PSLF does not feed into a results framework 
of the JTM allowing to measure the implementation of TJTPs. The Just Transition Fund is 
implemented under shared management as a cohesion policy fund, governed by the rules of 
the Common Provisions Regulation. Its reporting, monitoring and evaluation is conducted 
in this context and integrated within the monitoring framework of the European Regional 
Development Fund and the Cohesion Fund. The InvestEU dedicated scheme is implemented 
under the rules of the InvestEU Regulation in indirect management. The PSLF has its own 
results framework.    

4.2. Efficiency 

This  section  of  the  report  assesses  the  efficiency  of  the  PSLF’s  delivery  model,  its 
application  process  and  the  leverage  effect  of  the  PSLF  grants.  A  partial  Cost  Benefit 
Analysis of the PSLF is available in annex IV of this SWD. 

Efficiency of the PSLF delivery model 

Ensuring that potential beneficiaries could access PSLF support was subject to the launch of 
the first PSLF call for proposals. To this end, the completion of several preparatory steps 
was required, including: the adoption of the financing decision, the adoption of a decision 
on  the  use  of  financing  not  linked  to  costs,  the  delegation  of  the  implementation  of  the 
Facility  to  CINEA,  the  signature  of  the  administrative  agreement  with  the  EIB  and  the 
establishment of the advisory support under the InvestEU Advisory Hub. In addition, the 
adoption of a sufficient number of TJTPs was required.  

31 

 
 
The PSLF call for proposals, which could theoretically have been launched shortly after the 
adoption of the PSLF Regulation in July 2021, was instead launched in July 2022. This delay 
is  considered  an  inefficiency,  not  only  in  making  the  funds  available  to  potential 
beneficiaries  but  also  in  providing  them  with  clarity  on  the  precise  rules  governing  their 
allocation.  The  postponement  of  the  call  for  proposals  launch  was  mainly  caused  by  the 
delayed adoption of the TJTPs, which were a necessary condition for PSLF support to be 
awarded.  

Another  inefficiency  related  to  the  inclusion  of  the  PSLF  in  the  TJTP  framework  is  that 
potential applicants’ needs might not be known in detail to JTF Managing Authorities and 
consequently not included in the relevant sections of the TJTPs. This potentially creates the 
need for TJTPs to be amended when a Member State considers that one or more types of 
investments which were not initially included in the section on PSLF of the TJTP should 
become eligible. In this sense, TJTPs create an additional layer of administrative burden for 
all parties involved. However, this has occurred in only two occasions until January 2025, 
i.e.  for  Sweden  and  Spain.  In  both  cases,  the  respective  TJTPs  were  amended  to  allow 
additional sectors to be eligible under the PSLF.    

Concerning the organisation of the call for proposals itself, it is a multiannual call with 3 
submission deadlines (in January, April and September) per year. The multiannual character 
of the call compared to an annual call has allowed to reduce the administrative burden caused 
by its management and ensure a predictable framework for all stakeholders. The timing of 
the  submission  deadlines,  which  are  4  months  apart  from  each  other  on  average,  allows 
applicants to submit applications at regular intervals.  

Application process and project implementation 

Interviews  have  helped  to  identify  inefficiencies  in  the  application  process.  The  most 
relevant is the separate application procedures for the grant and the loan, which is perceived 
as less efficient compared to a single application for both the loan and the grant. This concern 
was  shared  by  some  national,  regional  and  local  public  authorities  and  external 
consultancies. Separate reporting to the CINEA and the EIB require beneficiaries to report 
twice  on  the  implementation  of  their  projects.  From  the  involved  institutions’  (the 
Commission,  EIB,  CINEA)  point  of  view,  the  implementation  of  the  PSLF  has  required 
considerable coordination to set up and implement. However, some beneficiaries noted that 
the grant application process was relatively easier and faster compared to other EU direct 
funds applications. 

Another element which can impact the efficiency of the instrument is the gap between the 
time applicants submit their grant applications and the time they sign the grant agreement. 
As  described  in  the  call  for  proposals,  the  grant  evaluation  process  can  take  up  to  three 
months from the time of submission of the application, and the EIB subsequently can take 
up to 15 months to finalise its due diligence concerning the loan component of the project 

32 

 
 
application, bringing the total evaluation of applications time to a maximum duration of 18 
months. Analysis of PSLF implementation indicates that, on average, the evaluation of the 
grant has taken around two months, and that the adoption of the grant award decision has 
taken between 6 and 13 months. To ensure transparency and manage expectations, potential 
applicants are provided with detailed information regarding the estimated timeline for the 
application process, allowing them to plan accordingly and understand the various stages 
involved from submission to the final agreement. The length of the entire process is mostly 
affected  by  the  maturity  of  the  loan  parameters  at  the  time  of  submission  of  the  grant 
application. 

Advisory support holds the potential of supporting the efficiency of the application process 
by improving the quality of submitted applications or even by defining adequate investment 
plans upstream which could also potentially lead to quality applications. In turn, this should 
reduce  the  time  needed  for  the  Commission  and  EIB  application  evaluation  process. 
Interviews  with  stakeholders,  including  NPBI,  beneficiaries  and  external  consultants, 
highlight that the technical assistance which was provided at the request of Czechia for the 
benefit of the eligible just transition regions has been useful to develop quality of the project 
proposals received from Czechia. Seven applications submitted which have benefited from 
this  assistance  have  been  selected  by  the  evaluation,  five  of  which  proceeded  to  the 
preparations of a grant agreement.  

As explained above and as per Article 11 of the PSLF Regulation, the PSLF grant component 
takes the form of FNLC. Recital 10 of the PSLF Regulation stipulates in this regard that ‘that 
form of financing should help incentivise project promoters to participate and contribute to 
the achievement of the Facility’s objectives in an efficient way relative to the size of the 
loan’. The information collected for this evaluation is not sufficient to confirm the expected 
simplification  benefits.  In  particular,  the  impact  on  administrative  costs  of  the  PSLF’s 
simplification measures has not been estimated due to the limited number of applications 
received and grant agreements signed at this stage. However, FNLC and the high percentage 
of the total grant paid by the pre-financing payment (70%) are highly appreciated by French 
and  Greek  beneficiaries.  They  are  perceived  as  simplification  measures  concerning  the 
administrative burden related to beneficiaries’ monitoring and reporting responsibilities.  

Finally, in shared management, especially concerning the European Union's structural and 
investment  funds,  managing  authorities  and  implementing  bodies  are  pivotal  in 
administering and executing EU-funded programs. Although the PSLF operates under direct 
management  and  does  not  formally  involve  these  authorities  and  bodies,  some  have 
voluntarily  leveraged  their  resources  to  aid  the  PSLF's  implementation.  This  support, 
ranging  from  raising  awareness  to  identifying  projects  and  project  promoters,  allows  the 
PSLF to benefit, at no additional cost, from the established structures designed for shared 
management, thereby enhancing its efficiency. 

33 

 
 
Leverage effect of PSLF grants 

This  report  focuses  on  the  first  seven  awarded  projects.  The  leverage  effect,  also  called 
multiplier effect in the context of the PSLF, is the ratio between one or more projects’ total 
budget and the amount of the corresponding grant(s). Administrative costs, including EIB 
costs, are not taken into account for its calculation. 

The average multiplier is 12, ranging from a minimum of 5.5 and going up to 21.3. This 
means that EUR 1 of PSLF grant brings on average EUR 12 of investments at the level of 
beneficiaries, including the EIB loan37. However, it is early to project these values for the 
entire PSLF grant  envelope. The leverage  effect of the  combined EIB and EC  support is 
lower  than  that  of  EC  support  alone,  which  is  an  inherent  consequence  of  the  higher 
proportion  of  funding  involved.  Based  on  the  same  set  of  projects,  the  leverage  value  of 
EIB/EC stands at 1.7.Based on the current parameters of implementation of the Facility, the 
lowest multiplier will be found in less developed regions where PSLF beneficiaries obtain 
the highest possible combined EIB/EC financing, equalling 90% of the investment costs. In 
these  cases,  the  multiplier  will  be  equal  to  5.5.  For  other  regions,  the  maximum  EIB/EC 
financing which can be obtained is a combined 57% of investments costs, with a multiplier 
equal to 13.3. The average multiplier of the Facility will therefore be partly determined by 
the regional distribution of the supported projects and by the proportion of the investment 
which is covered by other sources than the combined EIB/EC support. 

The  current  calculation  of  the  multiplier  value  has  not  been  compared  to  those  of  other 
instruments  due  to  the  lack  of  comparable  financial  instruments.  The  PSLF  has  a  broad 
eligibility scope, and no other financial instruments with similar objectives and beneficiaries 
were  identified  for  comparative  purposes  in  this  evaluation.  The  JTF,  which  is  a  similar 
programme  in  terms  of  sectors  and  objectives,  primarily  distributes  funds  through  grants 
which have a substantially higher rate of grant co-financing. This inherently leads to a lower 
multiplier than that of the PSLF, making any comparison redundant, except for reinforcing 
the principle that lower grant co-financing rates lead to higher multipliers. 

4.3. Coherence 

The PSLF  stems  from the European Green Deal, a comprehensive policy with  ambitious 
objectives for countering climate change and for environmental protection. Several other EU 
funding instruments in direct and shared management such as RRF, cohesion policy funds – 
European  Social  Fund  Plus  (‘ESF+’)38,  European  Regional  and  Development  Fund 

37 As indicated in the introduction to this report, PSLF is expected to mobilise up to EUR 8 billion  in loans 
from the EIB and some EUR 6 billion of additional resources by contributing up to EUR 1.3 billion of grants 
from the European Commission, totalling EUR 15.3 billion of public investment.  
38  ESF+ is  a  shared  management  fund.  It  provides  an  important  contribution  to  EU  employment,  social, 
education  and  skills  policies,  including  structural  reforms  in  these  areas. More  information  is  available  at: 
https://european-social-fund-plus.ec.europa.eu/en. 

34 

 
 
 
(‘ERDF’)  and  Cohesion  Fund  (‘CF’),  Connecting  Europe  Facility  (‘CEF’),  and  LIFE39 
programme contribute to the Green Deal’s objectives. The coherence of advisory financed 
by the PSLF with advisory financed under other sources will also be covered in this section. 

Coherence of the PSLF with others pillar of the JTM in the TJTP framework 

The PSLF is the third Pillar of the Just Transition Mechanism (JTM) alongside Pillar I, the 
JTF and Pillar II, the InvestEU JTS. The JTF is a new cohesion policy fund introduced in 
the 2021-2027 programming period in the context of the European Green Deal. It provides 
tailored support to specific territories and social categories among the most affected by the 
climate-neutral  economy  transition  challenges.  The  JTS  under  the  InvestEU  programme 
supports economically viable investments by private and public-sector entities aligned with 
just transition objectives.  

As  part  of  the  JTM,  the  PSLF  has  a  clear  conceptual  role  as  a  blending  facility  targeted 
towards  public  authorities,  combining  grants  and  EIB  loans  under  direct  management 
specifically  for  public  investments,  next  to  the  JTF  under  shared  management  and  the 
budgetary guarantee under the InvestEU JTS. The coherence of the three Pillars should be 
ensured by the TJTP framework. The review of TJTPs confirmed that all documents outline 
the sectors to be financed under JTF, PSLF and InvestEU JTS to foster coherence between 
all of them, albeit with a low level of detail for the PSLF40.  

The  extent  to  which  coherence  is  ensured  depends  on  how  cohesion  policy  managing 
authorities have approached their TJTPs. This is also confirmed by the mid-term evaluation 
of the Cohesion Policy Programmes 2021-202741. In comparison with the JTF, a wider scope 
of eligible investments can be observed for the PSLF in several TJTPs. This also confirms 
that Member States have approached the PSLF in a more flexible manner than the JTF.  

Survey results show that the PSLF is perceived as having the greatest synergies with the JTF 
and  to  a  lesser  extent  with  the  InvestEU  JTS.  At  the  operational  level,  stakeholder 
consultation  has  revealed  that  JTF  implementation  has  usually  been  prioritised  over  the 
PSLF. Considerable human resources within Member States were allocated to plan the JTF’s 
implementation and were therefore less available for the PSLF. As indicated in section 4.1, 
besides  the  JTF’s  specific  time  constraints,  it  offers  a  higher  grant  co-financing  rate  for 
similar investments, which leads potential beneficiaries to prioritise it. In this context, the 
implementation of the PSLF could be expected to lag behind the implementation of the JTF, 
which is confirmed by current figures: 30.2% of available resources under the JTF had been 

39 LIFE is a direct management fund entirely dedicated to environmental, climate and energy objectives. More 
information is available at: LIFE programme - European Commission 
40 More information on the TJTPs is in the case studies. 
41  Mid-term  evaluation  of  Cohesion  Policy  Programme  2021-2027  financed  by  the  European  Regional 
Development Fund (ERDF), the Cohesion Fund (CF) and the Just Transition Fund (JTF) (2024), forthcoming. 

35 

 
 
 
selected (data on implementation as of 31/10/2024, extracted 09/12/2024)42, while 17% of 
the  budget  available  for  the  PSLF  grant  component  has  either  been  awarded  or  is  under 
assessment in January 2025.  

Most  Member  States  ensured  that  at  least  one  paragraph  of  their  TJTPs  mentions  PSLF 
eligible  investments  in  their  TJTPs,  citing  the  sectors  included  in  recital  6  of  the  PSLF 
Regulation. However, interviews with national and local authorities as well as actors within 
EU  institutions  suggest  that  they  did  not  identify  investments  eligible  under  PSLF  and, 
therefore,  did  not  put  forward  opportunities  of    synergies  between  the  JTM  Pillars.  The 
context in which Member States were developing their TJTPs was challenging, as they were 
navigating new terrain with the JTM and tight deadlines, significant financial stakes, and 
substantial challenges, including setting concrete climate targets for the first time, which led 
to lengthy and complex negotiations both internally and with the EU.  

But there are examples where complementarity between the JTM Pillars were considered. 
The Swedish just transition process made a distinction between transition needs faced by the 
economy  to  be  covered  by  the  JTF  and  those  faced  by  the  public  sector  to  be  addressed 
through  PSLF.  Also,  the  Dutch  TJTP  makes  a  clear  distinction  by  referring  to  concrete 
projects which could be subject for funding under the PSLF.  

TJTPs were prepared together with local and regional authorities and other stakeholders. In 
some Member States (e.g. Romania) the authorities responsible for PSLF and TJTP planning 
differ  to  those  managing  the  JTF,  which  might  have  added  complexity  regarding 
complementarity of the three pillars within the TJTPs. 

Therefore, coherence between the three pillars of the JTM in terms of sectors and types of 
investments  has  only  partly  been  predetermined  by  the  TJTPs  and  will  rather  ultimately 
depend on the proposals which are submitted for PSLF support and their level of coherence 
with  the  investments  supported  under  the  two  other  pillars.  This  raises  questions  on  the 
strategic approach adopted by MS on their intended use of the PSLF. An upstream definition 
of  sectors  or  projects  to  be  supported  by  PSLF  in  TJTPs  could  have  promoted  a  more 
strategic  approach  to  the  PSLF  oriented  towards  the  most  urgent  and  impactful  needs  in 
complementarity with other EU and national funds. The unrestrictive framework provided 

42 This figure is extracted from the latest 2021-2027 DG REGIO Implementation Report number 8 and will be 
updated  based  on  the  latest  data  transmission  of  31-01-2025,  with  cut-off  date  31-12-2024  in  the next  DG 
REGIO  Implementation  Report.  The  JTF  is  comparable  to  the  PSLF  in  terms  of  its  overall  budget  as  it  is 
expected  to  mobilise  EUR  27billion,  including  EUR  19.7  billion  JTF  only  of  investments  (+  national 
cofinancing  of  27  billion),  while  the  PSLF  is  expected  to  mobilise  EUR  13.3  billion.  JTF  is  also  a  newly 
introduced instrument structured by TJTPs. In addition, it is focused on fossil-fuel dependent economies and 
carbon intensive regions to alleviate the socio-economic impact of the transition in most affected regions which 
makes  its  type  of  support  to  a  large  extent  also  comparable  with  that  of  the  PSLF.  However,  the  JTF  is 
implemented in shared management and primarily focuses on awarding support through grants offering higher 
rates of co-financing. 

36 

 
 
 
by the TJTPs for the PSLF means that coherence is evaluated on a case-by-case basis, per 
project application submitted. 

Coherence with other EU and national funding sources 

The eligibility scopes of the RRF and the PSLF allow them to support similar investments. 
The extent to which there is potential overlap depends on the coherence between Member 
States’ Recovery and Resilience Plans (‘RRPs’) and TJTPs. While the PSLF mainly targets 
public  sector  entities,  the  RRF  covers  more  types  of  beneficiaries.  The  RRF  provides 
performance-based payments to Member States to support a wide variety of grant and loan 
measures which vary across the RRPs. As stated by the annual implementation report of the 
PSLF in 202443, the RRF is seen by potential applicants as  a more attractive EU funding 
instrument. As such, the PSLF is not expected to be the preferred option for applicants in 
Member  States  that  have  access  to  RRF  funding.  The  Romanian  case  study  presents  a 
specific instance where the PSLF was considered for an investment, but for which the RRF 
was  finally  prioritised.  However,  the  Romanian  case  study  also  offers  an  example  of 
potential  synergies  between  the  PSLF  and  the  RRF.  Crucially,  the  RRF  supports  both 
investments and reforms, allowing for synergies which increase the overall impact of the 
programme.  The  establishment  of  the  Romanian  national  promotional  bank,  which  is  a 
required reform under the RRF framework (expected to be fully operational in 2025), may 
benefit future PSLF uptake via intermediated lending. 

The 2021-27 EU funds under cohesion policy, in particular the ERDF, the ESF+, and the CF 
also share overlapping sectoral eligibility with the PSLF, though they are implemented under 
shared  management.  Similar  to  the  RRF,  these  funds  could  have  a  broader  scope  of 
investments, depending on the negotiations with Member States. In terms of coverage, these 
funds also have more favourable funding conditions than PSLF, with grant co-financing rates 
going up to 100% of the project value44. 

There are numerous synergies between economic and social cohesion on the one hand and 
the just transition on the other. First, in terms of the objective, both focus on economic and 
social development. Second, in terms of areas of intervention, both call for a broad-based, 
multisector approach to smart specialisation were enabling infrastructure (digital, transport 
and energy networks) as well as innovation and skills take centre stage, and where climate 
action can be a source of revenues and savings. Third, in terms of policy implementation, 

43  Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the  implementation  of  the 
public sector loan facility under the Just Transition Mechanism in 2024, COM(2024) 424 final, 30.09.2024, 
available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52024DC0424  

 44 Rules of cohesion policy EU co-financing ceilings differ by category of region and fund and can vary across 
programmes and projects. The ceilings can be found at https://ec.europa.eu/regional_policy/funding/financial-
management_en. 

37 

 
 
 
they are also close to one another through (i) a common legislative framework, (ii) similar 
beneficiaries, mainly regional and municipal authorities, and (iii) similar finance providers. 

As also previously explained regarding the RRF, the programming and implementation of 
the ERDF, ESF+ and CF has required considerable efforts from Member State authorities. 
Some are striving to meet tight spending deadlines and reform requirements to access the 
funds. This might have also influenced their coherence with PSLF in terms of their limited 
capacity to coordinate its implementation, in particular due to the eligibility condition of the 
PSLF which does not allow it to be combined with other EU funding sources. 

CEF is another EU funding instrument delivering the European Green Deal and an important 
enabler for the Union’s decarbonisation objectives for 2030 and 2050. In addition to grants, 
CEF offers support through innovative financial instruments such as guarantees and project 
bonds attracting further funding from the private sector and other public sector actors. Both 
CEF  and  PSLF  can  support  public  sector  entities  targeting  infrastructure  investments  in 
transport, digitalisation and energy. This can be also demonstrated by several projects that 
have applied for funding under PSLF such as those projects covering mobility and transport 
in France and energy and transport infrastructure in Czechia45. 

In pursuing the objectives of the European Green deal, the LIFE programme contributes to 
the shift towards a sustainable, circular, energy-efficient, renewable energy-based, climate 
neutral and resilient economy. These objectives are also, to some extent, overlapping with 
PSLF  objectives.  While  PSLF  projects  can  contribute  to  environmental  objectives,  LIFE 
support targets environmental objectives. Broader than PSLF, LIFE supports a wide range 
of stakeholders including NGOs, local authorities and private entities. 

Both CEF and LIFE can create synergies with the PSLF in some sectors, such as energy and 
transport. Transport and mobility have been an important focus of PSLF support to date, and 
the investments in local mobility supported by PSLF should be complementary and synergic 
with investments supported under CEF.  

45 See current state of PSLF implementation in Chapter 3. 

38 

 
 
 
Figure 10: Synergies between the PSLF and other EU programmes. 

Source: Supporting Study. Note: The index rates synergies of PSLF on a scale from one (‘to 
no extent’) to five (‘to a very large extent’). Each response is rated from one (‘to no extent’) 
to five (‘to a very large extent’), and the sum is divided by the total number of responses. 

In summary, there is overlapping sectoral eligibility between the abovementioned funds and 
the PSLF. These similarities potentially create synergies, with different actions supported by 
different funds providing complementary support. This is the case for example of the PSLF 
housing project in Sweden, which will aid in the accommodation of workers needed for the 
development of new industries being supported by other EU Funds. The TJTP framework is 
another  example  of  a  synergy,  where  the  three  pillars  of  the  JTM  benefit  from  the  same 
strategic planning process.  

However, similar strategic frameworks can also create ‘competition’ between the different 
funds  for  the  same  projects  and  for  the  administrative  capacity  of  the  public  authorities 
responsible for the development of those projects. When the attractiveness of EU funding is 
evaluated on the basis of their grant co-financing rate, PSLF is crowded out. Furthermore, 
the  overlap  of  different  funding  opportunities  creates  additional  complexity  for  potential 
beneficiaries  and  coordinating entities as they must  discern the most appropriate  funding 
instrument for each investment and understand different instruments’ specific rules for each 
investment, adding further stress on their administrative capacity.  

Concerning coherence of the PSLF with national programmes, one overlapping fund with 
similar objectives46 has been identified and may partly explain the limited implementation 

46As already mentioned in EQs 1, 2, 3 and 9, PSLF sectors are perceived in line with national priorities. 

39 

2.312.522.953.183.363.61Life programme.Connecting Europe Facility.Recovery and Resilience Facility.Just Transition Mechanism Pillar 2 (InvestEU"Just Transition" scheme).Cohesion Policy funds (European Social FundPlus, European Regional and DevelopmentFund, Cohesion Fund).Just Transition Mechanism Pillar 1 (JustTransition Fund). 
 
 
 
of  the  PSLF  in  Germany.  The  ‘Coal  Regions  Investment’  Act  (‘Investitionsgesetz 
Kohleregionen’) of 202047 offers grant rates up to 90% of project costs and its conditions of 
access  within  public  entities’  national  framework  may  be  more  familiar  to  potential 
applicants.  

The varying levels of coherence per MS between the PSLF and other funding instruments 
has resulted in the full national shares of the MS with the largest national shares remaining 
available, while other MS could have made use of more resources. In France, the national 
share was insufficient to cover demand and some applications had to be rejected due to lack 
of available resources. Interviewees have also indicated that applicants from other MS, such 
as  Sweden,  did  not  apply  or  delayed  their  applications  due  to  the  insufficient  remaining 
budget under their respective national shares. Additionally, in MS where the national share 
was perceived as being too low (e.g. Luxembourg and Malta), there was less incentive for 
MS and applicants to invest resources in supporting or developing applications to the PSLF. 
In Luxemburg and Malta, the amount of the national share is insufficient to reach 15% (EUR 
1.875.000) of the amount of the minimal investment loan or framework loan with the EIB 
(i.e. EUR 12.5 million). The EIB also indicated that the national share earmarked for each 
Member States may not necessarily reflect market demand.  

The  co-legislators  anticipated  the  possibility  that  not  all  national  shares  would  be  fully 
consumed,  as  detailed  in  recital  18  of  the  PSLF  Regulation:  “in  order  to  reconcile  that 
objective  with  the  need  to  optimise  the  economic  impact  of  the  Facility  and  its 
implementation,  such  national  shares  should  not  be  pre-allocated  for  the  period  after  31 
December  2025.  Thereafter,  the  remaining  resources  available  for  the  grant  component 
should be provided without any pre-allocated national share and on a competitive basis at 
Union level, while ensuring predictability for investment and following a needs-based and 
regional convergence approach.” As a consequence, the second PSLF multi annual call for 
proposals (2026-2027) will be launched without ring fenced national shares. 

Coherence of advisory and technical assistance offered under the PSLF 

An  unintended  effect  of  the  PSLF  related  to  advisory  is  that,  in  addition  to  the  advisory 
financed by the PSLF, other sources of funding have been mobilised by PSLF stakeholders 
to support the implementation of the PSLF. Public entities in TJTP regions can benefit from 
several types of technical assistance paid by the Commission, such as TSI, Just Transition 
Platform Groundwork, C4T GROUNDWORK, and Joint Assistance to Support Projects in 
European Regions (JASPERS). Another type of technical assistance is delivered in TJTP 
regions  through  the  Initiative  for  Coal  Regions  in  Transition,  including  START  and 

47German  Federal  Ministry  of  Justice 
https://www.gesetze-im-internet.de/invkg/index.html  

(n.  y.). 

Investitionsgesetz  Kohleregionen,  available  at: 

40 

 
 
 
TARGET.  Beneficiaries  can  also  finance  additional  technical  assistance  using  national 
resources.  

Greece is an illustrative example. In addition to support from the InvestEU Advisory Hub, 
Greece has benefitted from diverse types of advisory and technical assistance funded by the 
Commission and other resources. This includes technical support funded by the Structural 
Reform Support Programme (SRSP), with the World Bank as a technical support provider, 
to develop a just transition process. Furthermore, support was provided via PASSA with EIB 
to develop a project pipeline, procedures and capacity building for PSLF implementation. 
Additional  support  was  received  under  TSI  to  implement  the  just  transition  in  Greece, 
including  development  and  implementation  of  the  TJTP  for  the  Western  Macedonia  and 
Megalopolis regions and support PSLF implementation, as well as via JTP Groundwork to 
identify  PSLF  projects  in  Megalopolis.  While  projects  funded  by  the  TSI  have  been 
concluded, other services are still ongoing. The support and assistance varied from needs 
assessment  to  developing  a  project  pipeline  and  support  for  the  PSLF  application. 
Beneficiaries from Greece have submitted a successful application to the PSLF and Greek 
public authorities have indicated that they intend to submit more.  In December 2024, the 
Commission approved a multi-country  advisory support request  for Greece (covering all 
TJTP regions) and Cyprus submitted to the InvestEU Advisory Hub.  

As  some  advisory  and  technical  assistance  initiatives  are  still  ongoing  and  others  have 
recently concluded, conclusions on the impact and complementarity of the initiatives cannot 
be  reached  at  this  stage.  However,  in  Greece,  a  combined  and  sequenced  approach  to 
advisory and technical  assistance services  was  intended to build the capacity of potential 
beneficiaries, from needs assessment to developing a project pipeline and preparing a PSLF 
grant application, which suggest at least an intended complementary and coherent approach 
towards using different advisory and technical assistance sources.  

In  the  cases  of  Slovakia  and  Czechia,  the  Commission  provided  external  consultancy 
services  to  raise  awareness  and  develop  potential  project  proposals.  In  Slovakia,  the  TSI 
financed  the  assignment  “project  preparation  and  implementation  of  the  Just  Transition 
Mechanism in Slovakia” implemented by PricewaterhouseCoopers (PwC). In Czechia, the 
assignment  “Support  to  Czech  Authorities  in  Improving  Their  Capacity  to  Implement 
Projects under Pillar III of the Just Transition Mechanism”, implemented by PwC as well, 
was financed by cohesion policy funds. The range of services included awareness raising 
and mobilisation of potential beneficiaries in TJTP regions, as well as publishing handbooks 
in  national  languages,  as  explained  by  the  annual  implementation  report  of  the  PSLF  in 
202348. For example, support in Czechia included disseminating information about PSLF, 

48  Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the  implementation  of  the 
public sector loan facility under the Just Transition Mechanism in 2023, COM(2023) 713 final, 21.11.2023, 
available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023DC0713  

41 

 
 
 
reviewing and assessing project ideas from potential promoters and hands-on support for the 
PSLF  grant  application.  Similar  TSI  technical  support  was  also  provided  in  Slovakia  to 
support implementation of the JTM, including PSLF. Case studies confirm the importance 
of these services to prepare PSLF project proposals in Czechia. Coherence between these 
sources  of  technical  assistance  and  advisory  financed  by  the  PSLF  was  supported  by  the 
involvement of the EIB in the assignments’ monitoring meetings. In the case of Czechia, it 
is  important  to  note  that  the  EIB  was  also  involved  in  the  assignment’s  governance. 
According to interviews with potential beneficiaries and other national and regional public 
authorities,  coordination  between  those  external  consultancy  services  and  the  advisory 
services under PSLF is very important to avoid duplicated efforts.  

Interviews with stakeholders, including beneficiaries,  from Czechia indicate that awareness 
raising  and  communication  activities  which  took  place  within  the  framework  of  PSLF 
advisory  support  and  the  other  technical  assistance  assignments  deployed  by  other 
consultants have contributed to increasing the knowledge about the PSLF. 

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

4.4. EU added value 

This  section  covers  the  expected  EU  added  value  of  PSLF  in  comparison  to  potential 
achievements by Member States on their own or other EU funding programmes with similar 
objectives.  

According to  the survey,  PSLF is  adding  value. Figure  11 shows that 82% of the survey 
respondents (74 of 90) indicate that PSLF is creating at least some added EU value for the 
just  transition,  with  48%  stating  the  added  value  was  ‘high’  or  ‘extremely  high’  (43 
responses).  

42 

 
 
Figure 11: The EU added value of the PSLF for the just transition in EU Member States49 

Source: Supporting Study. Note: The number of responses is in brackets. 

The PSLF is also adding value by making additional resources available to address transition 
needs in just transition regions. For instance, in France, the high uptake of the Facility seems 
to be connected to the absence of alternative funding resources to support investments in 
rolling stock for urban mobility at the EU and national level. As confirmed by the Swedish 
PSLF beneficiary, the PSLF creates a new opportunity for local public entities to cover just 
transition investments which would not be possible only through their own resources at the 
local and national level. The Greek PSLF beneficiary stressed that project investments in the 
Western Macedonia region could not have materialised without the resources made available 
under the PSLF. 

It is early to conclude about the effect of the PSLF grant on the likelihood that projects would 
materialise without PSLF support because of the limited number of grants awarded. But its 
effect ultimately depends on a combination of factors.  

Firstly, PSLF grants covered between 5% and 18% of their respective total investment costs. 
It is assumed that higher rates of co-financing would lead to more substantial anticipated 
impacts  on  projects’  materialisation.  However,  given  the  challenges  in  securing  public 
resources  for  supporting  just  transition  projects,  the  volume  of  individual  grants  is  also 
crucial, even if they represent a lower percentage of the total investment costs. For instance, 

49 Low added value means that national/regional policies would fully pursue PSLF objectives, while high added 
value means that national/regional policies would not – or to a limited extent – pursue PSLF objectives in 
the absence of PSLF interventions. 

43 

Extremely high added value of the PSLF.High added value of the PSLF.Some added value of the PSLF.Not so much added value of the PSLF.No added value of the PSLF.39% (35)34% (31)11% (10)7% (6)9% (8) 
 
 
although  the  PSLF  grant  covers  only  5%  of  the  total  investment  costs  for  the  Marseille 
Tramway Extension project, the grant amounts to EUR 15 million, a significant funding gap. 

Secondly,  the  grant  is  perceived  by  some  PSLF  stakeholders  as  a  source  of  additional 
funding  to  increase  the  scope  of  an  otherwise  bankable  project.  In  other  words,  some 
applicants  could  carry  out  their  project  without  PSLF  support,  however,  potentially 
unprofitable activities with a high social value would be dropped from the project without 
PSLF support.  

Thirdly, in addition to the PSLF’s co-financing role, PSLF advisory can, in certain cases, 
enhance project delivery by increasing the quantity, improving the quality, and accelerating 
the timeline of projects, all while addressing administrative capacity challenges by providing 
relevant  expertise.  Beyond  merely  creating  a  project  pipeline,  PSLF  advisory  has  the 
potential to assist applicants in developing more effectively designed projects. 

Fourthly, when assessing the EU added value of the PSLF, it is important to consider the 
extent to which retroactive co-financing is requested. Although the PSLF Regulation permits 
support for projects that have already commenced, the fact that these projects began prior to 
securing PSLF funding suggests that they might have been feasible without it. However, this 
assumption  cannot  be  applied  universally,  as  project  implementation  often  deviates  from 
initial plans. Factors such as underestimation of the initial budget, increased costs, reduced 
availability  of  other  co-financing  sources,  or  changes  in  the  project's  scope  may  arise, 
necessitating additional support. 

Finally,  PSLF  co-financing  can  influence  the  timing  of  project  implementation.  The 
additional  funding  provided  by  the  PSLF  may  enable  project  promoters  to  commence 
implementation earlier than they would have otherwise. Specifically, the PSLF grant offers 
immediate  liquidity  to  beneficiaries,  with  an  initial  pre-financing  payment  of  70%  of  the 
grant  amount  disbursed  after  the  grant  agreement  is  signed.  However,  there  could  be  a 
contradictory  effect  where  project  implementation  is  delayed  due  to  the  time  required  to 
apply for PSLF support, especially when compared to other funding sources that might be 
more readily accessible. 

Additional insight into the PSLF and its added value can be obtained by comparing the scale 
of its projects with similar types of projects supported under other EU funding instruments. 
A  comparative  analysis  with  ERDF  similar  type  of  projects  (exported  via  the  Kohesio 
database) has been conducted. However, this comparison does not provide a clear trend in 
this  regard. In  comparison  with  ERDF,  PSLF  seems  to  provide  funding  for  larger  size 
mobility  projects  in  France,  and  similar  size  projects  in  Poland  and  Greece.  No  similar 
projects  were  found  in  the  Netherlands  and  Sweden,  and  the  comparison  was  also  not 
possible in Czechia.   

44 

 
 
Is the intervention still relevant? 

4.5. Relevance 

This section examines the relevance of the PSLF for just transition needs, its relevance in 
the context of the 2024-2029 Commission priorities, and adaptation to recent changes.  

PSLF relevance for just transition needs  

The PSLF Regulation provides support for a broad spectrum of public investments linked to 
the just transition, provided that the projects are consistent with TJTPs. Since the adoption 
of the PSLF Regulation in 2021, TJTPs are therefore the main factor driving the relevance 
of the PSLF for identified just transition needs. Most of them were adopted in 2022 and are 
currently  being  reviewed  in  the  context  of  the  mid-term  review  of  cohesion  policy 
programmes according to Article 18 of the Common Provisions Regulation50. The relatively 
recent adoption of the TJTPs combined with the currently ongoing mid-term review support 
the continued relevance of the PSLF to meet current needs. 

A wide range of stakeholders were consulted concerning the relevance of the PSLF grant 
component to support a just transition in Member States.  

Figure 12: The extent to which the grant component of the PSLF is relevant to support just 
transition in EU Member States. 

Source: Supporting Study. 

As shown in figure 12, for most respondents, the PSLF grant component is relevant. 36% of 
respondents (33 of 93), indicate PSLF is relevant ‘to a very large extent’ and 25% (23 of 93) 

50  Common  Provisions  Regulation,  EU  Regulation  2021/1060,  Article  108(2),  available  at:  https://eur-

lex.europa.eu/eli/reg/2021/1060/oj/eng 

45 

To a very large extent.To a large extent.To some extent.To little extent.To no extent.36% (33)25% (23)32% (30)6% (6)1% (1) 
 
 
 
‘to a large extent’. 32% (30 of 93) reveal that PSLF is relevant ‘to some extent’, and ‘to little 
extent’ for 6 respondents, and ‘to no extent’ for only 1 respondent. Of the 93 respondents, 
27 are implementing projects benefiting from PSLF or intend to submit a proposal. Of these 
27, more than 50% say the grant component is relevant ‘to a very large extent’ and for 33% 
‘to a large extent’. Interviews show a wide consensus between institutional actors, national 
representatives and potential and actual beneficiaries that PSLF objectives are relevant.  

As part of its Mid-term Review of the JTM, the EIB acknowledges the relevance and the 
soundness  of the JTM legislative framework focussing on geographical  vulnerability and 
sectoral relevance. The EIB is also committed to increasing synergies between its climate 
action and broader work on social development by investing in projects that simultaneously 
support climate action and foster socio-economic development.  

PSLF Relevance with the 2024-2029 Commission priorities 

Just transition policy sits at the crossroads of various EU policies and initiatives. The policy 
debate on the future of just transition support is intensifying, and increasing consensus seem 
to emerge on its relevance for the future. This is also reflected in Commission's 2024-2029 
priorities.  By funding projects that enhance public services and social infrastructure such as 
health, sports, and culture, the PSLF is expected to ensure that all citizens have an effective 
right to stay in the communities they call home. This objective, highlighted in the mission 
letter to Executive Vice-President for Cohesion and Reforms51 Raffaele Fitto, is particularly 
crucial for regions most affected by the transition to a low-carbon economy, as it addresses 
their communities' evolving needs.  

PSLF also delivers on the mission of the Executive Vice-President-designate for a Clean, 
Just  and  Competitive  Transition52  Teresa  Ribera  Rodríguez,  by  supporting  a  socially 
sustainable decarbonization in the regions which have traditionally been dependent on the 
fossil fuel industry. A flagship PSLF project exemplifying how a polluted industrial city can 
transform into a vibrant hub for the cultural and creative sectors is the Ostrava Concert Hall. 
The groundbreaking ceremony for this project was attended by Czech President Petr Pavel 
in  July  2024,  which  underpinned  the  significance  of  the  project  for  the  entire  region.  In 
addition, 5 745 jobs (full-time equivalents, FTE) are expected to be created by the seven 
projects  already  signed  under  the  PSLF.  This  underscores  the  economic  relevance  of  the 
Facility in regions often characterised by economic decline and shrinking employment.  

von 

der  Leyen’s  mission 

51President 
https://commission.europa.eu/document/download/a4d2cdf4-a055-419d-92f7-
a161962d79dd_en?filename=mission-letter-fitto.pdf  
52President 
https://commission.europa.eu/document/download/33d74e86-3a17-472c-ba93-
59d1606bbc20_en?filename=mission-letter-ribera_0.pdf  

der  Leyen’s  mission 

to  Teresa  Ribera 

to  Raffaele  Fitto 

letter 

letter 

von 

(2024), 

available 

at: 

(2024), 

available 

at: 

46 

 
 
 
The  implementation  of  the  PSLF  aligns  closely  with  the  political  guidelines  of  the  new 
Commission outlined by its President in July 2024, while advancing the long-term objectives 
established  in  the  European  Green  Deal  in  2019.  The  Commission  has  committed  to 
maximizing public investment in close cooperation with EIB. The implementation of this 
blending facility is expected to provide valuable lessons for shaping EU investment policies 
in the post-2027 financial perspective. 

The political guidelines also introduced the first-ever European Affordable Housing Plan, to 
be  developed  in  partnership  with  the  EIB.  Notably,  one  of  the  inaugural  PSLF-financed 
projects supports the construction of affordable housing in Skellefteå, Sweden, providing a 
solid foundation for this initiative. 

The  implementation  of  the  PSLF  is  poised  to  support  the  competitiveness  component 
outlined  in  the  European  Commission's  political  guidelines  for  2024-2029.  By  providing 
targeted financial support to public sector entities, the facility aims to address the economic 
and social challenges arising from the transition towards climate neutrality, thereby fostering 
a more competitive and resilient European economy. 

Central  to  the  competitiveness  agenda  is  the  Clean  Industrial  Deal,  which  seeks  to 
decarbonize industries and reduce energy costs, thereby creating quality jobs and enhancing 
the EU's industrial base. The PSLF can drive this transformation by financing projects that 
facilitate the adoption of clean technologies and sustainable industrial practices. Investments 
in infrastructure and energy efficiency, for example, will help industries reduce their carbon 
footprint and operational costs, aligning with the objectives of the Clean Industrial Deal. 

Furthermore, the facility supports the broader goal of enhancing the EU's Single Market by 
enabling  projects  that  improve  digital  and  transport  infrastructure,  critical  for  boosting 
productivity  and  business  growth.  By  financing  projects  that  promote  digitalization  and 
innovation, the facility will aid in overcoming structural barriers to competitiveness. This 
aligns  with  the  political  guidelines'  emphasis  on  using  digital  technologies  to  drive 
productivity and increase the EU's global competitiveness. Overall, the public sector loan 
facility  serves  as  a  crucial  financial  instrument  in  realizing  the  European  Commission's 
vision of a competitive and sustainable European economy. 

Adaptation to recent changes 

Post-COVID-19 and in particular after the Russian aggression against Ukraine in 2022, an 
extended  period  of  international  and  internal  instability  for  Europe  has  affected  the 
availability and price of raw materials and gas, with consequences for inflation, energy and 
construction. These changes have reinforced the  importance of diversifying the economy 
and specifically the energy sector, increasing the relevance of the PSLF. Increased energy 
prices bring additional challenges to the green transition process with  EU Member States 
facing additional pressure to provide sufficient affordable energy.  

47 

 
 
The  European  Court  of  Auditors  Special  Report  on  ‘EU  support  to  coal  regions’53  only 
briefly  mentions  PSLF  in  a  description  of  the  JTM.  Its  findings,  however,  hint  at  less 
relevance for instruments in coal regions as the Russian invasion of Ukraine may delay a 
coal phase-out. The Institute for European Environmental Policy  however indicates that the 
Russian  invasion  of  Ukraine  may  push  Members  States  to  reduce  their  reliance  on  fossil 
fuels, specifically gas.  

The  instability  affecting  PSLF  beneficiaries  therefore  has  contradictory  effects  on  the 
relevance  of  the  Facility.  The  same  contradictory  dynamics  would  apply  to  the  relative 
increase of interest rates compared to the period between 2016 and 2022. The PSLF requires 
co-financing from public entities while the EU political and strategic agenda is challenged 
by fiscal sustainability due to higher interest rates and central bank interventions affecting 
all public policies. However, higher interest rates could also make the PSLF more relevant, 
given the fact that it is well positioned to offer attractive conditions compared to loans which 
could be negotiated with private banks at market rates.  

Relevance of PSLF advisory services 

The evaluation of the relevance of the advisory support under the Facility presents certain 
limitations. Notably, no prior impact assessment was conducted specifically for the advisory 
component, and beneficiary needs were not quantified at the outset.  

Initially, evaluating the advisory component was particularly  challenging due to the slow 
uptake of the Facility. At that stage, the demand for advisory support was limited, and its 
relevance and added value appeared less evident.  

Encouragingly,  demand  for  advisory  services  has  increased.  The  increase  in  assignments 
indicates  a  positive  trend,  suggesting  that  the  relevance  of  this  support  may  be  rising  in 
parallel with implementation needs. While these findings are still preliminary, they provide 
early lessons on the relevance of the PSLF advisory support. 

It is also widely recognised in research and policy documents that administrative capacity 
remains  a  persistent  barrier  to  the  timely  and  effective  implementation  of  quality 
investments.  In  this  context,  advisory  support  can  play  a  crucial  role  in  helping  public 
authorities  and  beneficiaries  navigate  complex  application  procedures  and  effective 
implementation. This is equally true for the PSLF, where its advisory services can support 
beneficiaries and public authorities in overcoming administrative  capacity limitations and 
enhancing the quality and efficiency of PSLF project implementation.  

53 European Court of Auditors, Special Report 22/2022: EU support to coal regions – limited focus on socio-
economic and energy transition, available at: https://www.eca.europa.eu/en/publications?did=62373  

48 

 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1 Conclusions 

Effectiveness 

Since the launch of the multi annual call for proposals in July 2022 until 31 January 2025, 
46  project  proposals  have  been  received,  30  out  of  these  (65%)  were  found  eligible  and 
admissible,  and  17  were  selected  for  funding  by  the  PSLF  evaluation  committee.  The 
selected  projects  submitted  are  expected  to  mobilise  approximately  EUR  228  million  in 
grants, corresponding to 17% of the grant component budget, and EUR 1.4 billion in total 
investments including the grants, the loans and additional sources of financing. 

Eligible  applications  have  been  submitted  by  applicants  from  Greece,  Sweden,  France, 
Czechia,  the  Netherlands,  Poland,  Spain,  Latvia  and  Ireland,  but  not  from  the  remaining 
Member States. Several factors are affecting the uptake of the Facility which include, among 
others, the overlap with other financing sources offering better conditions for the same type 
of investments, the administrative capacity of public authorities, the availability of mature 
project pipelines, financial constraints of potential applicants and the ineligibility of projects 
benefitting from other EU funds since there is a condition under PSLF  that PSLF project 
cannot receive support from other Union programmes.  

Other challenges faced by PSLF potential beneficiaries relate to (i) the minimum threshold 
for EIB direct lending and (ii) the requirements for beneficiaries to obtain framework loans 
which can be a significant entry barrier for municipalities with small projects and limited 
administrative  capacity  preventing  them  from  taking  up  a  coordinating  role.  Different 
solutions and supporting measures by the Commission and the EIB have been undertaken to 
mitigate the situation.  

The future uptake of the Facility is challenging to assess. While full grant budget absorption 
is unlikely to happen in the first call, the second call (2026-27) presents an opportunity. This 
is in particular the case since awareness about the PSLF has increased and national shares 
will no longer apply beyond 2025. However, the extent to which other EU and national funds 
are programmed or consumed will be a decisive factor in this regard. 

The inclusion of the PSLF in the TJTPs framework has created a clear, understandable and 
formal  reference  for  policy  makers,  national  and  regional  authorities,  and  potential 
applicants.  While  TJTPs  place  less  emphasis  on  the  PSLF  than  the  JTF,  they  establish  a 
crucial just transition strategy that PSLF applicants should align with and refer to in their 
applications. In addition, TJTPs have created a first step of awareness raising about the PSLF 
in the eligible regions.  

For signed projects, the grant has covered between 5% and 18% of the total investment costs, 
while the loan has accounted for between 31% and 73%. This suggests that the key factor 

49 

 
 
driving  the  PSLF’s  value  for  beneficiaries  is  the  structure  of  the  EIB  loan.  Potential 
applicants  will  assess  the  interest  rate,  loan  duration,  financing  amount,  and  the  overall 
effectiveness of the EIB loan negotiation process in addressing their needs, compared to the 
terms  offered  by  commercial  banks.  Although  the  PSLF  is  generally  well-positioned  to 
provide more favourable financing conditions by combining EIB loans with an EU grant, 
commercial banks often have the advantage of quicker loan processing, simpler procedures, 
and established relationships with public sector clients. 

The advisory support provided by the EIB for the PSLF is delivered through the InvestEU 
Advisory  Hub.  By  31  January  2025,  six  assignments  are  ongoing,  and  one  is  completed 
covering  a  wide  range  of  sectors  including  energy,  mobility,  environment  and  social 
investments. Although the PSLF advisory support is free of charge for its beneficiaries, the 
demand was initially low which is likely correlated to the overall limited uptake of the PSLF. 
Therefore, the impact of the InvestEU Advisory Hub cannot yet be assessed. Preliminary 
findings  suggest,  however,  that  the  use  of  advisory  support  and  technical  assistance  help 
increase the uptake of the PSLF and the quality of applications.  

PSLF is a new instrument, therefore communication and information actions were key to 
promoting  its  uptake.  The  Commission,  in  close  cooperation  with  CINEA  and  the  EIB, 
raised  awareness  about  the  PSLF  through  many  joint  actions  targeting  several  types  of 
potential beneficiaries.  Although  various level  of  awareness  raising are  revealed, there is 
some evidence that communication about the PSLF has been effective.  

Support for PSLF implementation and how much national authorities inform, communicate 
and promote opportunities under the PSLF varies by Member State that do it on a voluntary 
basis. National authorities seem to be involved in PSLF communication and implementation 
when they have sufficient  administrative capacity and/or when they perceive PSLF to  be 
relevant  for  them  depending  on  the  national  context.  Where  national  authorities  support 
PSLF uptake, project applications seem to be mature and successful. 

The horizontal principles referred to in Article 4 of the PSLF Regulation are integrated in 
the implementation and the management of the PSLF in several ways. The implementation 
of horizontal principles relies mainly on the declarations and commitments made by PSLF 
beneficiaries  which  are  assessed  during  the  evaluation  of  the  proposals  and  during 
implementation via periodic reporting and on the spot missions. The EIB also appraise and 
monitor  all  projects  and  intermediated  operations  based  on  environmental,  social  and 
governance  criteria.  Only  those  activities  that  meet  EIB’s  sustainability  due  diligence 
requirements are financed. 

For some signed grant agreements, a clear gender mainstreaming approach is incorporated, 
while other types of projects signed under PSLF concern interventions that will not have a 
direct  bearing  on  gender  equality.  The  current  level  of  implementation  of  PSLF  projects 
however does  not  allow to  carry out  an impact  assessment yet.  In terms  of the estimated 

50 

 
 
number of jobs created by the PSLF for the signed grant agreements, 50% (2870 out of the 
5745) are declared by applicants to be intended for women. In terms of the individuals which 
should  be  reached  by  the  signed  PSLF  projects,  52%  (1.237.232  out  of  2.450.527)  are 
estimated by beneficiaries to be women.  

Concerning the contribution to environmental objectives, not all investments under the PSLF 
will  directly  contribute  to  CO2  reduction.  The  broad  range  of  eligible  sectors  imply  that 
some investment projects will concern climate action, and some will be climate-neutral or at 
least do no significant harm for others. Some just transition projects that do not lead to a 
direct  reduction in  CO2  emissions might  still score high  on environmental  sustainability. 
Four out of the seven project supported by the PSLF declare that they will contribute to CO2 
emissions reduction (estimated 135.805 tonnes per year CO2 reduction). The other projects 
supported  under  PSLF  will  have  some  environmental  impact  such  as  promoting  circular 
economy and biodiversity.  

An overall weakness of the PSLF monitoring framework is that the general objective, the 
specific objective and the KPIs do not currently have targets. This shortcoming is further 
addressed in annex VIII to the SWD, where targets are put forward for several of the PSLF’s 
regulatory  KPIs,  including  for  the  volume  of  grants  awarded,  the  overall  investment 
mobilised,  the  number  of  projects  receiving  financing  under  the  Facility,  greenhouse  gas 
emission reductions and job creation.    

Efficiency 

The launch of the first call for proposals was delayed due to  the delayed adoption of the 
TJTPs,  which  were  a  necessary  condition  for  PSLF  support  to  be  awarded  and  the 
completion of several other preparatory steps. This has had a direct impact on the timing and 
efficiency of the PSLF implementation. 

Another  inefficiency  may  stem  from  the  TJTP  framework  because  potential  applicants’ 
needs  might  not  be  known  in  detail  to  JTF  Managing  Authorities  and  consequently  their 
needs were not included in the section concerning PSLF in the TJTPs. This has created the 
need to amend the TJTPs in Sweden and Spain creating an additional layer of administrative 
burden for all parties involved. 

The multiannual character of the call compared to an annual call has allowed to reduce the 
administrative burden caused by its management and ensure a predictable framework for all 
stakeholders. The timing of the submission deadlines, which are 4 months apart from each 
other on average, allows applicants to submit applications at regular intervals. 

On the other hand, the separate application and reporting procedures for the grant and the 
loan are perceived as less efficient, compared to a single application for both the loan and 
the grant.  

51 

 
 
Analysis of PSLF implementation indicates that, on average, the evaluation of the grant has 
taken  around  two  months,  and  that  the  adoption  of  the  grant  award  decision  has  taken 
between 6 and 13 months. The length of the entire process is mostly affected by the maturity 
of the loan parameters at the time of submission of the grant application. 

The  information  collected  for  this  evaluation  is  not  sufficient  to  confirm  the  expected 
simplification benefits related to the use of Financing Not Linked to Costs. The impact on 
administrative costs of the PSLF’s simplification measures have not been estimated due to 
the  limited  number  of  applications  received  and  grant  agreements  signed  at  this  stage. 
However, FNLC and the high percentage of the total grant paid by the pre-financing payment 
seem to be highly appreciated by the PSLF beneficiaries so far.  

PSLF  implementation  has  benefitted  from  the  network  of  cohesion  policy  managing 
authorities and implementing bodies which already exists in the Commission and from the 
EIB wide network of local offices which has also supported the efficient implementation of 
the PSLF. 

While it is too early to project the value of the PSLF multiplier effect for the entire PSLF 
envelope, focusing on the seven awarded PSLF projects,  the average ratio of investments 
and PSLF grant amount to 12, ranging from 5.5 for less developed regions to 21.3 for more 
developed and in transition regions. 

Coherence 

The coherence of the three JTM pillars is outlined in the TJTPs, though they provide limited 
details on the PSLF. While many Member States mention PSLF-eligible sectors, they often 
lack  specification  or  clear  synergies  between  pillars.  Ultimately,  coherence  depends  on 
submitted  proposals  rather  than  a  predefined  strategy,  with  the  flexible  TJTP  framework 
allowing  alignment  to  be  assessed  on  a  case-by-case  basis.  At  the  operational  level,  JTF 
implementation has usually been prioritised over PSLF.   

Coherence between PSLF and RRF which provides funding for similar types of investments 
depends on the extent to which there is potential overlap and complementarity between the 
RRPs  and  TJTPs.  The  RRF  also  supports  institutional  reforms  which  may  provide 
complementarities  with  the  PSLF.  The  RRF  is  seen  by  potential  applicants  as  a  more 
attractive.  

The EU funds under cohesion policy (ERDF, ESF+, and CF) also share overlapping sectoral 
eligibility with the PSLF, have more favourable funding conditions with higher grant co-
financing rates and has required considerable efforts from Member State authorities striving 
to  meet  tight  spending  deadlines  and  reform  requirements  to  access  cohesion  funds.  
Altogether, this has also influenced their coherence with PSLF creating both synergies but 

52 

 
 
also competition between both instruments. When the attractiveness of different EU funding 
sources is analysed on the basis of their grant co-financing rates, PSLF is crowded out. 

The overlap of different  funding opportunities creates additional complexity for potential 
beneficiaries  and  coordinating entities as they must  discern the most appropriate  funding 
instrument for each investment and understand the functioning of the different EU funds. 

PSLF can also overlap with national programmes, for example the overlapping fund with 
similar objectives in Germany which could partly explain the limited implementation of the 
PSLF in this EU Member State.  

More generally, there is a mismatch between the allocated national shares and demand for 
the PSLF. While the full national shares of the Member States with the largest national shares 
remains available,  other Member States, such as  France which has exhausted its national 
share, could make use of additional resources from the PSLF. 

In addition to the PSLF advisory support available under the InvestEU Advisory Hub, public 
entities in the concerned regions have recurred to several types of technical assistance paid 
by  the  Commission  within  the  remit  of  other  Union  programmes  such  as  TSI  and  JTP 
Groundwork.  As  some  advisory  and  technical  assistance  initiatives  are  still  ongoing  and 
others  have  recently  concluded,  conclusions  on  the  impact  and  complementarity  of  the 
initiatives cannot be reached at this stage. There is evidence that the awareness raising and 
communication activities which took place within the framework of PSLF advisory support 
and  the  other  technical  assistance  assignments  deployed  by  other  consultants  have 
contributed to increasing the knowledge about the PSLF.  

EU Added value 

Preliminary feedback suggests that PSLF is  adding value by making additional resources 
available to address transition needs in just transition regions. It is creating a new opportunity 
for local public entities to cover just transition investments which would not be possible only 
through their own resources at the local and national level. 

The impact of the PSLF grant on project materialization remains uncertain due to the limited 
number of grants awarded, but its influence is contingent upon several factors, such as the 
exact  PSLF  co-financing  date  or  the  volume  of  the  grant.  Moreover,  the  grant  serves  as 
additional funding to expand project scopes, potentially ensuring the inclusion of socially 
valuable but otherwise unprofitable components. PSLF advisory services enhance project 
delivery  by  improving  quality  and  accelerating  timelines,  even  addressing  administrative 
constraints. 

PSLF  co-financing  also  impacts  project  timelines,  offering  immediate  liquidity  to  begin 
projects earlier than otherwise possible. Nonetheless, applying for PSLF support might delay 
implementation  compared  to  more  accessible  funding  sources.  Comparative  analyses  of 

53 

 
 
PSLF  projects  against  similar  projects  funded  by  instruments  like  the  ERDF  reveal 
differences in project scale across countries but do not establish a definitive trend. 

Relevance 

The relatively recent adoption of the TJTPs combined with the currently ongoing mid-term 
review of cohesion policy (including TJTPs) support the continued relevance of the PSLF to 
meet  current  needs.  Stakeholder  engagement  resulted  in  a  wide  consensus  between 
institutional actors, national representatives and potential and actual beneficiaries that PSLF 
objectives are relevant. 

The  implementation  of  the  PSLF  aligns  closely  with  the  political  guidelines  of  the  new 
Commission outlined by its President in July 2024, while advancing the long-term objectives 
established in the European Green Deal in 2019. The PSLF is delivering on EU objectives 
ensuring that all citizens have an effective right to stay in the communities they call home 
and supporting a socially sustainable decarbonization in the regions which have traditionally 
been dependent on the fossil fuel industry.    

5.2 Lessons learned 

Mismatch of national shares with potential beneficiaries’ needs 

For the first call for proposals lasting until 2025, national shares were established following 
the budget allocation key defined for the JTF. This has affected the uptake and coherence of 
the PSLF with  other  funding  sources, highlighting  the limitations of not  considering that 
demand for repayable financing could differ from the JTF allocation method. While the full 
national shares of MS with the largest national shares remain available, others could have 
made use of more resources. Additionally, in MS where the national share was the lowest, 
there  was  less  incentive  for  MS  and  applicants  to  invest  resources  in  supporting  or 
developing applications to the PSLF.  

The PSLF has a limited capacity to support smaller projects 

While smaller projects  are benefitting from  PSLF support, including  5 projects  receiving 
intermediated loans ranging from EUR 1.5 million to EUR 12 million, intermediated lending 
in only available in two MS. In other MS, the minimum loan amount is EUR 12.5 million, 
which is a substantial threshold for smaller projects, potentially exceeding their total funding 
needs.  Framework  loans  offer  the  possibility  to  meet  the  loan  size  threshold  by  pooling 
multiple  projects  together,  but  this  inherently  increases  the  complexity  of  the  application 
process,  demanding  coordination  between  multiple  stakeholders  or  project  beneficiaries. 
Smaller entities may not have the requisite experience or resources to undertake this level of 
coordination efficiently. Without the ability to break down loans into smaller sizes through 
financial intermediaries, smaller projects face exclusion from PSLF options. 

54 

 
 
A possible solution to high minimum loan size and coordination issues could be a higher 
engagement from NPBIs and a higher use of financial intermediation, however the PSLF 
must offer them adequate incentives to get involved. In any case, the selection of financing 
partners for future financial instruments must be closely aligned with the needs and profiles 
of potential beneficiaries. Particular attention should be given to engaging partners that have 
the  institutional  capacity  and  operational  frameworks  necessary  to  support  smaller 
beneficiaries  if  they  are  targeted  by  the  blending  instrument.  These  partners  should  also 
possess in-depth knowledge of local financing conditions to ensure that support is tailored, 
relevant, and accessible. 

The PSLF’s delivery model 

The delivery model of the PSLF provides several advantages that contribute to its appeal. 
One of the key strengths of the PSLF is its facilitation of direct access to European Union 
level  funding  for  local  public  bodies  capable  of  efficiently  navigating  the  model. 
Furthermore,  the  PSLF  employs  a  blended  finance  approach,  combining  EU  grants  with 
loans  from  the  European  Investment  Bank  (EIB)  and  additional  funding  sources.  This 
method potentially amplifies the financial resources available to projects,  with EUR 1 of 
PSLF grant bringing on average EUR 12 of investments.  

However,  the  PSLF's  dual-application  structure,  necessitating  separate  applications  for 
grants  and  loans,  renders  the  application  process  complex  and  time-consuming.  The 
combined timing for the entire PSLF application process, from submission to the signing of 
final agreements, can extend up to an overall duration of 18 months, which might not be 
adequate for all beneficiaries’ project implementation timeframes.  

A system that would allow the EIB and the EC to reuse data submitted by applicants to each 
other could have potentially increased efficiency. Although this idea was explored by DG 
REGIO and the EIB during talks for the EC/EIB administrative agreement on implementing 
the  PSLF,  it  was  deemed  impractical.  This  is  mainly  because  both  organisations  operate 
under distinct rules, procedures, and processes that are not aligned. 

For example, the EC’s structured grant application process mandates that applicants submit 
forms  by  specific  deadlines.  These  submissions  are  then  evaluated  based  on  established 
criteria,  without  further  input  from  the  applicants.  On  the  other  hand,  the  EIB's  loan 
negotiation  process  is  more  flexible,  lacking  predetermined  application  deadlines  and 
allowing for ongoing communication between the EIB and potential borrowers. Loan terms 
are shaped through negotiation rather than predetermined like EC grants, making automated 
data reuse significantly complex. 

The data requirements and timelines differ between the EC and the EIB, as do the procedures 
and regulations regarding data acquisition and sharing. For instance, the EIB might already 
have data on certain projects before they are considered for PSLF support. Moreover, any 

55 

 
 
data exchanged between the EC and EIB would have to comply with data protection laws 
and undergo quality control checks. 

Although better data sharing between the EC and its financial partners should be explored 
for  future  financial  instruments,  establishing  the  necessary  systems  and  processes  would 
require  substantial  resource  investment  and  must  align  with  the  planned  rollout  of  the 
instrument. 

In addition, it is advisable that the submission of the grant application only takes place after 
the loan has been signed, or at least after the loan request has been approved by the finance’s 
partner  responsible  authority.  While  a  project  may  still  evolve  during  the  negotiations 
between a project promoter and a finance partner, a grant application submitted to the EC 
cannot  be  subject  to  changes  after  its  submission,  making  this  sequence  more  efficient. 
However, it is important to note that this arrangement would mean the EC fully delegates 
the project filtering process to the finance partner. As a result, the EC might not become 
aware of certain projects it might have supported, as these projects could be filtered out by 
the finance partner's prioritisation process before they ever reach the EC. 

A possible avenue for simplifying future blending instruments could be to calculate the grant 
amount based on the total project budget, rather than the loan amount as is done with the 
PSLF.  Since  the  loan  amount  requested  by  a  project  promoter  may  change  during 
negotiations  with  the  finance  partner,  the  EC  may  need  to  adjust  the  grant  when  it  is 
calculated as a percentage of the loan. Calculating the grant based on the total project budget 
could  eliminate  the  need  for  such  adjustments,  reducing  the  need  for  resource-intensive 
coordination between the entities managing the grant and loan components. 

Alternative delivery models, in which a single entity manages the blended financing sources, 
could be explored for future financial instruments to streamline the application process and 
enhance the EU's added value. Although the costs for all parties involved in the PSLF have 
not been estimated, alternative models could result in higher expenses for the Commission. 
Unlike  the  PSLF,  these  alternative  models  might  require  the  Commission  to  pay 
management fees to its partners. 

Finally,  both  the  grant  and  loan  parameters  must  be  carefully  calibrated  for  any  future 
financial instruments. The grant parameters should be proportionate to the nature and scale 
of  the  investments  and  in  particular  provide  a  meaningful  incentive  to  apply  for  the 
instrument,  while  the  loan  parameters  (interest  rates,  repayments  conditions,  loan 
negotiation process, etc.) should be attractive enough compared to market conditions in order 
to incentivise uptake. 

56 

 
 
PSLF advisory support 

With Member States prioritising the use of funding offering higher grant co-financing over 
the repayable financing provided by the PSLF, demand for advisory services under the PSLF 
was initially limited. Only one advisory assignment has finalised, constraining the evaluation 
of  the  impact  and  the  relevance  of  advisory  accordingly.  However,  requests  for  advisory 
services have  followed an upwards trend. The advisory component of the PSLF is carried 
out by the InvestEU Advisory Hub, established under the InvestEU Regulation. Although 
the interim evaluation of the InvestEU programme deemed it premature to fully assess the 
Hub's  effectiveness,  owing  to  many  assignments  still  being  underway  and  the  limited 
availability of data, the final evaluation will be crucial in understanding the impact of the 
PSLF  advisory.  Cross-cutting  analysis  of  advisory  work  led  by  the  EIB  across  different 
mandates will provide deeper insight into the overall performance and EU added value of 
advisory services, including those under PSLF. 

If  current  trends  persist,  the  PSLF  advisory  is  anticipated  to  have  a  limited  impact  on 
enhancing administrative capacity, considering the low demand for assignments explicitly 
aimed  at  this  area.  At  present,  requests  for  PSLF  advisory  services  are  centered  around 
application support, market analysis, project identification, and investment planning. 

For  advisory  assignments  with  a  specific  administrative  capacity  component,  the  final 
evaluation will have to analyse, on a case by case basis, if the assignments have allowed to 
introduce  durable  changes  leading  to  an  increase  in  the  administrative  capacity  of 
beneficiaries.  For  other  types  of  assignments,  the  InvestEU  Advisory  Hub  monitoring 
framework will play a key role in assessing  the PSLF advisory’s overall effectiveness and 
added value. 

The PSLF’s monitoring framework 

The  implementation  of  the  PSLF  is  demand  driven  and  has  a  wide  sectoral  eligibility, 
therefore the precise type or projects and sectors by which it will “address serious social, 
economic and environmental challenges deriving from the transition towards the Union’s 
2030 climate and energy targets and the objective of climate neutrality in the Union by 2050” 
was not known at the time of the adoption of the PSLF Regulation, nor is it fully predictable 
now.  Consequently,  the  co-legislators  defined  two  cross  cutting  KPIs  to  measure  the 
achievement of the PSLF’s general objective which go to central elements of just transition: 
job creation and greenhouse gas emissions reduction. In turn, the specific objective of the 
facility  to  “increase  public  sector  investments”  is  measured,  in  particular  through  KPIs 
related to the “overall investment mobilised.”  

A weakness of the PSLF monitoring framework is that the KPIs associated to the general 
objective  and  the  specific  objective  do  not  currently  have  targets.  This  shortcoming  is 

57 

 
 
addressed in  annex  II to the SWD, where targets for the PSLF’s  regulatory KPIs are  put 
forward.  

The management of the loan component by the EIB could not be included in the scope of 
this evaluation. Specific aspects concerning the loan component are instead covered in the 
framework of this evaluation relying on evidence from the supporting study, as well as other 
evaluations  undertaken by the EIB such as  the EIB Mid-Term Review of the EIB Group 
support to the Just Transition Mechanism54. For future evaluations, the Commission and the 
EIB should explore possible ways how to jointly evaluate the Facility as a whole taking into 
account the legal framework and the applicable procedures and rules of both institutions. In 
the framework of this  evaluation, the assessment of  the simplification and administrative 
costs  for  beneficiaries  and  applicants  was  not  carried  out  due  to  the  early  stage  of 
implementation and the very limited number of beneficiaries and applicants involved in the 
PSLF to date. The results of such an assessment would have been based on a very reduced, 
unrepresentative sample. The current monitoring framework of the PSLF in place does not 
collect data about beneficiaries’ costs. This analysis should take place in the context of the 
final  evaluation  rather  than  during  the  implementation  phase,  once  a  sufficient  pool  of 
applicants and beneficiaries is available. 

The advisory component under the PSLF is implemented as part of the InvestEU Advisory 
Hub  mandate,  which  is  a  joint  EIB-EU  programme  established  under  the  InvestEU 
Regulation. The effectiveness and EU added value of the InvestEU Advisory Hub as a whole 
has been assessed in the framework of the interim evaluation of the InvestEU programme 
(see here) concluding that it is too early to assess given that many advisory assignments are 
still in progress or in the pipeline. The early implementation stage, combined with the lack 
of availability of quantitative data on assignments, together with the limited time and budget 
available has restricted the depth of analysis of individual advisory Hub initiatives, including 
under the PSLF. The findings of the final  evaluation of the InvestEU Advisory Hub will 
certainly  be  closely  complementary  to  the  final  evaluation  of  the  PSLF,  providing  an 
additional source of analysis on the added value of advisory. For example, the evaluation of 
all  the  work  undertaken  by  the  EIB  across  its  multiple  advisory  mandates  will  allow  for 
cross-advisory  initiatives  analysis.  This  would  also  offer  better  insight  into  the  overall 
performance and added value of the InvestEU Advisory Hub as a whole, including the PSLF 
advisory services as an integral part. The monitoring framework put in place to capture the 
added value of the PSLF advisory is explained under Box 1. 

The established indicators from  the  InvestEU  Advisory Hub, such  as expected mobilised 
investments and participants’ satisfaction, will be fully used to measure the added value of 
advisory  services.  Continuous  tracking  of  these  indicators  can  yield  insights  into  the 

54 EIB (2024) Mid-Term Review of the EIB Group Support to the Just Transition Mechanism (not published 
yet, but forthcoming).  

58 

 
 
 
effectiveness and impact of advisory support, thereby enhancing the overall evaluation of 
benefits derived from EU-funded initiatives. 

Gender impact 

The PSLF call for proposals currently lacks a reference framework for applicants concerning 
gender equality. To support applicants to improve their understanding of the Commission’s 
expectations  in  terms  of  gender  equality  and  to  support  the  quality  of  their  applications, 
additional measures towards promoting the implementation of gender equality will be taken 
within the framework of the second PSLF call for proposals which is now under preparation. 
The  toolkit  for  just  transitions  regions  with  the  title  “considering  gender  in  regional 
transformations”55 which was recently developed by the Commission will provide guidance 
on managing the gendered impacts of the just transition at the local and regional level.  

55 European Commission (2023), Considering gender in regional transformations. A toolkit for just transition 
regions, 
https://ec.europa.eu/regional_policy/sources/funding/just-transition-fund/toolkit-
considering%20gender%20in%20regional%20transformations.pdf  

available 

at: 

59 

 
 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

The European Commission conducted the interim evaluation of the PSLF required by 30 June 2025, in line with Article 17 of the PSLF Regulation. The 
Decide planning entry for the interim evaluation is PLAN/2023/2184. 

The Call for Evidence was published on ‘Have your say’ on 02 February 2024 for a four-week period until 01 March 2024 for the general public to provide 
public feedback. 

The evaluation was led by the European Commission’s Directorate-General for Regional and Urban Policy (DG REGIO). An interservice Steering Group 
(ISSG) was set up comprising a broad range of Commission Services: SG, DG REFORM, DG ECFIN, DG CLIMA, DG ENV, SJ, DG EMPL, DG GROW, 
DG ENER and CINEA. The ISSG was involved in all key steps of the evaluation and helped providing information and expertise while ensuring the quality, 
representativeness and credibility of the evaluation and its coherence with other related EU policies. 

In particular, the ISSG was consulted several times: 

- 
- 
- 
- 
- 
- 
- 

In December and January 2024 on the Call for evidence and the technical specifications of the supporting study; 
In May 2024 on the Inception Report of the supporting study; 
In October 2024 on the Intermediate Report of the supporting study; 
In November 2024 on the Draft Final Report of the supporting study; 
In January 2025 on the Final report of the supporting study;    
In March 2025 on the draft SWD and all its annexes 
In 202556 on the SWD and all its annexes  

In  line  with  the  requirements  set  out  in  the  Commission  Better  Regulation  Guidelines,  the  interim  evaluation  examined  the  effectiveness,  efficiency, 
relevance, coherence and EU added value of the PSLF.  

56 The exact date to be updated. 

60 

 
 
 
The evaluation relied on two main components: 

1.  In-house expertise and documentation about the functioning of the Facility. In addition, in-house consultation was carried out to collect input and 
feedback from staff within DG REGIO working in the geographical desk units which are also involved in the PSLF implementation. Counterparts 
working in the EIB and CINEA on the implementation of the PSLF were also consulted in the framework of this exercise. 

2.  A supporting study (i.e. the supporting study) awarded to a consortium of T33 Srl and Prognos AG. The service contract started at the end of April 
2024 and ended in January 2025, covering a period of around 9 months. The analysis relied on literature review, stakeholder consultation (interviews 
and an online survey) and case studies. The quality of the report was assessed as good by the ISSG.  

The interim evaluation of the PSLF was also subject to scrutiny by the Regulatory Scrutiny Board (RSB). An upstream meeting was held on 16 December 
2024, followed by a meeting with RSB on 14 May 2025. The RSB gave a positive opinion on 16 May 2025, while providing recommendations for improving 
the report. The table below presents the RSB recommendations and the actions taken to address them.  

Table 1:  RSB recommendations and actions taken to address them. 

RSB recommendations. 

Actions taken. 

The report should improve the intervention logic to present more clearly the 
sequence of outputs, results and impacts and consider ways how to assess 
utilisation of supported infrastructure. 

The  intervention  logic  (Figure  3)  and  its  accompanying  text  have  been 
revised for greater clarity and precision. The updates now more accurately 
categorise inputs, activities, outputs, results, and impacts. Additional details 
and clearer wording have been incorporated where necessary. The design 
of the intervention logic has been modified to enhance readability, and the 
accompanying text offers a clearer understanding of its sequential flow. To 
assess  the  effectiveness  of  supported  infrastructure,  measuring  its 
utilisation rate is prescribed as an evaluation method. 

The  report  would  benefit  from  a  clearer  presentation  of  the  specific 
problems  and challenges, arising  from  the transition  to  achieve the EU’s 
2030 climate target  and climate neutrality by 2050 and how the PSLF is 
intended to help address them. 

Section  2.1  has  been  further  refined  to  offer  a  clearer  depiction  of  the 
intervention's context and objectives. It now effectively outlines the specific 
problems and challenges associated with the transition toward achieving the 
EU’s 2030 climate target and climate neutrality by 2050. Additionally, the 

61 

 
The report should clarify the rationale, intended use and added value of the 
proposed indicator targets in future implementation. 

The  report  should  explain  the  terminology  and  the  methodology  for  the 
calculation of the PSLF ‘multiplier effect’. It should assess the leverage of 
the grant component and of the Facility as a whole. The report should also 
explain whether/how the administrative costs, including the EIB costs, are 
taken into account. 

The  data  needs  regarding  costs  to  beneficiaries  and  applicants  should  be 
reflected in lessons learned. 

section  provides  a  detailed  explanation  of  how  the  Public  Sector  Loan 
Facility (PSLF) aims to address these challenges. 

The  rationale,  intended  use  and  added  value  of  the  proposed  indicator 
targets in future implementation has been further described in Annex VIII. 
No  specific  methodology  was  required  to  establish  the  calculation  of 
indicator targets because the results will be derived directly from existing, 
readily available data. 

The  terminology  and  the  methodology  for  the  calculation  of  the  PSLF 
multiplier effect are now described in section 4.2. It presents the combined 
EIB/EC leverage of the Facility as a whole and explains that administrative 
costs, including EIB costs, are not taken into account for its calculation. 

Data concerning beneficiaries and applicants’ costs will be collected in the 
framework of the final evaluation. The report has been updated to clarify 
the underlying rationale to this approach. 

The  report  should  assess  the  feasibility  and  costs  to  streamline  the  dual 
(Commission and EIB) application process, including automated reuse of 
applicants’ data. 

Section 5.2 “lessons learned” has been updated to assess the feasibility and 
costs  of  streamlining  the  dual  application  process,  including  automated 
reuse of applicants’ data.  

The report should analyse the impact of advisory services and their potential 
for developing administrative capacity in target regions. 

Section 5.2 “lessons learned” has been updated to provide information on 
the  impact  of  advisory  services,  in  particular  concerning  administrative 
capacity.  

The evaluation of the impact and added value of the advisory services under 
PSLF is limited in this evaluation, given The reduced demand for advisory 
services under the PSLF. 

62 

 
It  should  draw  early  lessons  on  the  relevance  for  the  needs  of  potential 
beneficiaries of advisory services. 

Early  lessons  should  be  also  developed  on  the  EU-level  approach  to 
blending of grants and loans, to better inform future design and allocation 
to maximise return on every euro spent including the approach to ‘socially 
valuable but otherwise unprofitable components’ 

The evaluation of the relevance of the advisory support under the PSLF is 
limited  because  only  one  of  the  six  ongoing  advisory  assignments  has 
finalised. Nevertheless, the relevance section and the lessons learned have 
been updated to reflect those early findings and lessons learned about PSLF 
advisory services. 

Section 5.2 “lessons learned” has been updated to provide early lessons on 
blending  and  in  particular  to  better  inform  future  design  of  financial 
instruments.  

The approach towards assessing the social value in the evaluation report is 
primarily anecdotal and based on qualitative information collected within 
the  framework  of  the  stakeholder  consultation.  Given  the  very  limited 
number of implemented  projects  and beneficiaries, the development  of a 
quantitative methodology was deemed premature and of limited practical 
value at this stage.  

In this context, the report includes illustrative examples that demonstrate 
how  PSLF  grants  can  generate  social  value.  For  example,  for  a  Dutch 
project,  the  PSLF  beneficiary  declared  that  the  grant  made  it  possible  to 
increase the scope of the project by connecting additional social housing 
units to the district heating network. This component, which would not have 
been financially viable through repayable financing alone according to the 
applicant,  illustrates  how  the  PSLF  can  increase  the  social  impact  of 
projects.  

63 

 
 
  
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

Overall approach  

This annex provides an overview of the evaluation methods used in this evaluation, alongside the challenges, limitations and the lessons learned for future 
evaluation of the instrument. This is followed by a list of references appearing in the SWD. The cut-off date of the data and information collection is 31 
January 2025.   

The evaluation was designed to respond to the evaluation questions based on a mix of qualitative and quantitative input obtained via the following methods: 

internal expertise and knowledge (via inhouse-documentation and consultation) 

- 
-  Stakeholder consultation strategy (via semi-structured interviews, online survey and case studies) 
-  An analysis of the PSLF implementation data, supporting the qualitative information to the extent possible; and 
-  Triangulation of findings (an evaluation question was  answered using  various sources of collected information, expertise, data and stakeholder 

points of view) 

Overview of the evaluation methods 

The information and data were collected using the following tools: 

Internal expertise and knowledge  

Given the limited implementation of the PSLF, it was decided to rely significantly the in-house expertise of the PSLF team working within DG REGIO on 
implementation of the PSLF to carry out this evaluation. The collection of information and data was carried out internally, feeding into the supporting study 
and the Staff Working Document. 

Inputs from staff working in the different geographical desk units of DG REGIO with extensive knowledge about the just transition situation across the 
different EU member states was also collected, in particular about the programming and implementation of other EU cohesion policy funding instruments. 
Staff working within the EIB and CINEA directly on the PSLF as implementing partners were also asked to contribute. Altogether, this provided meaningful 
insights into the early functioning, achievements and challenges facing the PSLF. The assessment of the cost and benefits related to the PSLF was also 
carried out internally via the information in-house.  

64 

 
Supporting study 

The supporting study combined different activities which include: 

Document/literature review 

An extensive document and literature review has been carried out in the context of the supporting study. The review covered various sources of information, 
including legal and policy documents (e.g. European Green Deal Investment Plan, the Just Transition Mechanism, PSLF Regulation, PSLF Call Document, 
TJTPs, PSLF work programme, PSLF yearly implementation reports, etc.), academic studies and other relevant documents such as national, regional and 
local documents. The review and analysis informed the design, implementation and the performance of the PSLF. The review allowed the comprehensive 
understanding of key areas of the PSLF and informed the design and conduct of the survey and the semi-structured interviews. It was also used to inform 
the case studies. The list of key references is included below. 

Analysis of the implementation data 

An analysis of the data relating to the submitted, selected and signed PSLF projects was also carried out in the context of the supporting study. The analysis 
informed the output and early performance of the PSLF to the extent possible. It was based on a limited data set which was transmitted by the European 
Commission to the contractor including data on the submitted application by PSLF applicants, Evaluation Summary reports (ESRs), Rejection/approval 
letters, award decisions and grant Agreements with the beneficiaries, etc. 

Survey  

An online targeted survey was carried out in the context of the supporting study between 9 July 2024 and 13 September 2024. It was designed with questions 
gathering feedback and views about PSLF relevance, effectiveness, efficiency, coherence and its EU added value. It targeted different type of PSLF relevant 
stakeholders consisting of national, regional and local public authorities, other public and quasi-public organisations, private bodies (with a public mission), 
PSLF applicants and beneficiaries, European Commission representatives, European Investment Bank representatives, NPBIs, research and academia and 
third-party interest groups57.  

57 Such as non-governmental organisations, trade unions, social partners 

65 

 
 
The survey was sent  to  a sample of  around 750  potential respondents  representing the type of stakeholders  as summarized here-above58.  Overall,  102 
responses to the survey were received: 

•  24 respondents from local public authorities;  
•  15 from national public authorities; 
•  14 from regional public authorities; 
•  12 respondents representing the European Commission and/or CINEA; 
•  8 respondents from the EIB; 
•  7 respondents representing national promotional banks and institutions (NPBIs); 
•  6 third-party interest groups, including NGOs and trade unions;  
•  3 respondents representing applicant/beneficiary groups and other public or quasi-public organisations;  
•  2 answers representing research and academia; and  
•  1 answer representing a private body with a public service mission. 

The highest participation came from Poland with 15 submissions, followed by Belgium with eleven and Romania with nine. France and Luxembourg each 
had seven submissions. Czechia, Slovenia, and the Netherlands are represented by five submissions each. Germany, Croatia, Italy, and Portugal each had 
four submissions. Spain had three, while Sweden had two. Cyprus, Denmark, Hungary, Ireland, and Greece are each represented by one submission. 

The Commission acknowledges the non-representativeness of this sample and therefore conclusions based on it should be understood in this context. As 
outlined previously in the report, the pool of stakeholders capable of providing meaningful feedback on the PSLF is limited due to its novelty and initial 
stage of implementation. This is particularly true for EU Member States where the PSLF has not yet been implemented. 

The sample is also partially self-selected. Most PSLF stakeholders could be identified by DG REGIO, which provided their contact information to the 
contractor in charge of the supporting study for interviews and surveys. DG REGIO intended for this sharing of contacts to be exhaustive and aimed to 
ensure no prioritisation of certain views over others. The contractor faced no restrictions regarding whom to contact. The challenge, instead, was to identify 
informed stakeholders which had the resources to be consulted. This limitation is connected to the broader challenge of evaluating a programme with 
limited implementation, but is expected to persist in the context of the final evaluation. 

58 A list of potential candidates was prepared by the contractor in cooperation with DG REGIO. It included contact points of  DG REGIO’s PSLF team with whom they have been in 
contact for PSLF design and implementation, contact points collected in the framework of the 2 PSLF days, contact points of managing authorities (publicly available), other relevant 
contact points recommended by the contractor based on previous stakeholder engagement.  

66 

 
 
 
It is important to highlight, also, that the data from the survey is not the sole source of information for the report. To enhance the diversity of perspectives, 
the report also incorporates information from other sources, including interviews with national, regional, and local actors, beneficiaries, and applicants, as 
well as a comprehensive literature review. 

The survey used optional questions and skip logic to tailor questions based on responses. Consequently, the number of replies to specific questions varies 
across the survey. 88% of respondents (38 out of 43) answered that they were located in a TJTP territory, while 12% (5 out of 43) were not. Regarding the 
question ‘To what extent are you familiar with the PSLF?’ 16% of respondents (15 out of 96) were familiar ‘to a very large extent’, 26% (25 out of 96) ‘to 
a large extent’, 33% (32 out of 96) ‘to some extent’, 20% (19 out of 96) ‘to little extent’ and 5% (five out of 96) ‘to no extent’. An overview of the main 
findings of the survey is represented in the synopsis report (as per Annex V).  

Interviews 

In the framework of the supporting study, a total of 39 interviews were conducted between 4 July and 11 November 2024. The interviews allowed to collect 
the views and perspectives from  different  types  of stakeholders providing insights  on overall issues related to  the relevance, effectiveness,  efficiency, 
coherence and EU added value of the PSLF. 

In the first  round of interviews (July  -  August 2024), 8 interviews were  conducted with  staff from  the European Commission/CINEA working  on the 
implementation of the PSLF. 8 interviews were carried out with staff from the EIB working on the implementation of the loan component of the PSLF 
(including the advisory component of the PSLF). In a second round (September-November 2024), interviews were carried out with 13 representatives from 
national, regional and local authorities involved in the design and implementation of the PSLF, of which 5 interviews were with PSLF beneficiaries. Over 
the whole period, 10 interviews were conducted with other stakeholders such as consultants 59. 

The results of the semi-structured interviews provide meaningful and detailed insights in the functioning of the PSLF complementing insights from the 
survey. It gives also more information about the context in which PSLF operates, including administrative, fiscal and procedural challenges faced when 
applying for PSLF. The analysis also enriches and deepens the comparison of context-dependent factors in different Member States and regions as well as 
specific challenges faced by less developed regions. An overview of the main findings of the interviews is represented in the synopsis report (as per Annex 
V). Annex V of the supporting study presents the full results. 

59 Such as consultants who are involved in the technical assistance services related to PSLF and or NGOs closely following the implementation of the PSLF or helping with increasing 
the awareness about it. 

67 

 
 
Case studies  

Five case studies collecting information, views and feedback about PSLF relevance, effectiveness, efficiency, coherence and its EU added value in Czechia, 
Romania Greece, Poland and France  were carried out in the context of the supporting study. The  5 case studies were carefully collected based on the 
following considerations: (i) the level of PSLF comparing those countries with high (FR, EL, CZ) and low uptake (RO, PL), (ii) with high national shares 
under  the  PSLF,  (iii)  which  received  advisory  support  by  the  EIB  or  other  type  of  technical  assistance  (RO,  EL,  CZ),  (iv)  with  (potential)  use  of 
intermediated lending type of projects (CZ, FR).  

Among those selected case studies, France have already fully consumed its national share under the PSLF, Greece has a framework loan project approved, 
and Czechia have submitted several projects which are selected for funding under PSLF. On the other hand, Poland and Romania present cases which have 
their national shares under PSLF still almost fully available. The national shares allocated to these Member States represent almost 50% of the PSLF grant 
budget. Greece and Czechia represent cases which have made use of advisory support either offered by the EIB or by other consultants in the framework 
of other technical instruments. A similar focus on advisory is also applied for Romania. Czechia also represents a case with use of intermediated projects.  

The case study analysis uses a mix of evaluation tools, including literature review, semi-structured interviews with representatives from the selected EU 
Member  States  along  other  relevant  other  stakeholders,  such  as  EIB  representatives  and  technical  assistance  consultants.  The  case  studies  provide 
meaningful in-depth insights into local, regional and national context in which PSLF operates in the 5 selected EU Member States, alongside the nature of 
the submitted, selected and signed projects, types of applicants and sectors covered. The case studies are also accompanied by a cross-Member State analysis 
covering the following key areas of the PSLF:  

1)  Complementarity of EIB advisory support via the InvestEU advisory Hub and other technical assistance. 
2)  Complementarity between PSLF and other EU and national/regional funding opportunities. 
3)  Factors affecting PSLF uptake. 
4)  Awareness raising and communication activities.  

An overview of the main findings of the case studies is represented in the synopsis report (as per Annex V). Annex V of the supporting study presents the 
full results. 

Challenges, limitations and lessons learned to inform future evaluation approaches 

The PSLF Regulation was adopted in July 2021. The PSLF call for proposals was launched on 19 July 2022. Since then, 7 grant agreements have been 
signed and 12 other PSLF projects are still under grant agreement preparation. It is therefore premature to fully assess their contributions to achieving PSLF 

68 

 
 
general and specific objectives. The same applies to the advisory support available under the PSLF with only 1 assignment completed and 6 others just 
recently started and under implementation. This presents an important limitation of this interim evaluation which instead focuses on the analysis of initial 
activities and outputs of the Facility. Data on the results and the impacts of the PSLF are not available yet. This context has oriented methodological choices 
for the evaluation, excluding the possibility of defining a control group, or conduct macro-economic analysis. 

The early stage of implementation also has an impact on stakeholder engagement. While the range and amount of stakeholders is potentially large given 
the eligibility requirements of the PSLF and its focus on just transition, in practice the relevant stakeholder population is limited. Most involved public 
entities must have the administrative capacity to gain familiarity with the PSLF while also managing other EU funds with larger resources such as cohesion 
policy funds or the RRF. Even less stakeholders other than those directly concerned by awarding or benefitting from PSLF support had the capacity to gain 
a granular knowledge of the PSLF allowing them to make a critical assessment of its implementation.  

Knowledge about the Facility was largely generated by the Commission through its counterpart public authorities in the EU MS and by the EIB through 
the relation between EIB lending officers and their clients. This focused awareness raising about the PSLF on cohesion policy stakeholders accustomed to 
shared management and public entities with existing relations with the EIB. This generates a risk of stakeholder bias in terms of the PSLF being judged in 
contrast to shared management EU funding or other EIB lending rather than being judged on the basis of its own merits. 

The specific nature of the PSLF as a blending instrument aimed at public sector entities in just transition territories suggests that its main stakeholders are 
the public sector authorities in those territories. However, given the limited administrative capacity of public authorities in these territories and in particular 
the limited resources they can allocate to the understanding and prioritising of certain sources of EU funding over others, it is perhaps more important for 
the PSLF to be visible and known by the actors which support public sector authorities and public service providers with the financial structuring of their 
projects. This includes national authorities, regional authorities, National Promotional Banks and Institutions and advisory initiatives. In addition, to public 
sector entities in just transition territories, these stakeholders were specifically targeted by the evaluation. 

In this context, while the pool of PSLF stakeholders is expected to expand, it will remain limited and this will still be a challenge for the final evaluation. 
There  is  substantial  consultation  fatigue  among  PSLF  stakeholders,  which  poses  a  significant  challenge  to  effective  engagement.  In  addition,  those 
unfamiliar with the PSLF often perceived their input as insufficiently relevant, which further reduced their willingness to participate. Data obtained through 
surveys and interviews should therefore be triangulated with other sources of information, including a literature review. Other methods of stakeholder 
engagement should be considered as well.   

To  capture  the  effects  of  awareness-raising  efforts  more  accurately  on  the  target  audience,  the  final  evaluation  could  leverage  existing  just  transition 
stakeholder forums, such as the Just Transition Platform or the Coal Regions in Transition initiative. Engaging with stakeholders through these channels 

69 

 
can minimise additional administrative burdens and provide a more favourable context for consultation. For instance, organising a dedicated panel during 
a stakeholder meeting or conducting a brief survey at the beginning of a panel could be effective strategies. 

Another limitation of this evaluation concerns the loan component of the Facility. The legal framework in the PSLF Regulation has not created an obligation 
for the EIB to be subject to Commission evaluations, and after negotiating the terms of implementing and managing the PSLF, the EIB has also not agreed 
to be subject to the Commission evaluations, nor to carry out a joint evaluation. In addition, the EIB manages the loan component with its own resources. 
Therefore, this evaluation does not assess how the EIB carries out its loan procedures, rules and policies. Instead, evidence regarding the functioning of the 
PSLF as a blending Facility, including the interaction between its EIB loan and EU grant component is collected on the basis of documents  produced by 
the EIB,  including , among others, the EIB Group Evaluation of EIB advisory activities in the European Union60 and the EIB Mid-Term Review of the EIB 
Group support to the Just Transition Mechanism61. 

Given the broad scope of the ‘just transition’, the Facility’s general and broad objectives are defined in broad terms. Instead, the success of the Facility will 
be measured in the light of its capacity to support public investments and their contribution to the transition process in the context of the above-mentioned 
territories.  

Data and methodology limitations 

Methods 

Limitations 

Literature/document review 

One limitation is that there are limited documents which provide direct and detailed feedback about the PSLF. This is 
due to the novelty of the PSLF. Instead, this evaluation collected rich information based on the literature resources that 
could be collected from academic studies and other relevant documents about the wider topic of the just and green 
transition. 

Survey  

A limitation is that the survey could not delve into many details about some specific aspects that would have require 
more detailed feedback given the wide range of stakeholders and the wide range of evaluation questions covered. To 

60 Evaluation of EIB advisory activities in the European Union (2023),  available at: https://www.eib.org/en/publications/20230211-evaluation-of-eib-advisory-activities-in-the-eu  
61 EIB (2024) Mid-Term Review of the EIB Group Support to the Just Transition Mechanism (not published yet, but forthcoming).  

70 

 
 
 
accommodate this limitation, the specific feedback from interviews was asked to complement the general trends about 
the PSLF that were collected in the framework of the survey providing more the necessary explanations where relevant.  

Even though the overall response rate to the survey was good, it is important to acknowledge that the size of each group 
of stakeholders varied. Another difficulty faced is the timing of the survey, which was published during the summer 
period, but this issue was mitigated by extending the deadline of the survey for a longer period. The consultation fatigue 
of the relevant authorities which receive a lot of such consultation requests is another factor which limited the response 
rate  for  the  survey.  Nevertheless,  the  overall  response  rate  of  the  survey  can  be  considered  good  providing  useful 
insights into the PSLF. 

A difficulty faced with semi-structured interviews is that not all interviewees had deep knowledge and understanding 
about the PSLF. This is again natural given the novelty of the PSLF.  

The case study provides a deep dive into some selected Member States, however the difference in level of PSLF uptake 
between EU Member States concerned and the availability of limited number of stakeholders who could be interviewed 
especially in those Member States with very limited uptake of PSLF such as PL have constrained the depth of (cross-
country) analysis of the case studies.  

The analysis of costs and benefits provides a partial analysis looking into the ‘direct’ costs and benefits that could be 
presented. Due to the early stage of implementation of the PSLF, many costs and benefits have not materialised yet. 
Even if materialised, it was not feasible to collect such evidence because it was either not quantifiable or because it 
was simply not possible to receive the data from the stakeholders involved due to their willingness, availability or other 
time and budget constraint. Therefore, this interim evaluation did not include a specific methodology to estimate the 
actual (administrative) costs and benefits related to PSLF implementation. A full cost-benefit analysis will be instead 
part of the final evaluation of the PSLF.  

Interviews 

Case studies 

Analysis  of 
benefits 

the  costs  and 

While the pool of PSLF stakeholders is expected to expand, it will remain limited and this will still be a challenge for the final evaluation. Data obtained 
through  surveys  and  interviews  should  therefore  be  triangulated  with  other  sources  of  information,  including  a  literature  review.  Other  methods  of 
stakeholder engagement should be considered, as explained in Box 3.   

71 

 
 
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European Commission (forthcoming), Evaluation Report of the Mid Term Evaluation of ERDF, CF and JTF 

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European Court of Auditors (2024), Absorption of funds from the Recovery and Resilience Facility. Progressing with delays and risks remain regarding 
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from 

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FTJ 2021-2027 HAUTS-DE-FRANCE. 

Study  supporting  the  mid-term  Evaluation  of  the  Recovery  and  Resilience  Facility,  Prepared  by  ECORYS,  CEPS, CSIL,  NIESR  (2023),  available  at: 
https://commission.europa.eu/document/download/7fff9205-b77a-4a3f-ad85-8a4c88cb6503_en?filename=study-supporting-the-mid-term-evaluation-of-
the-recovery-and-resilience-facility_0.pdf  

Zografia Andreosatou (2024), Energy poverty and gender nexus – A case study analysis from Greece, JUSTEM project. 

Up  to  date  data  on  the  Recovery  and  Resilience  Facility  in  each  Member  State  is  available  at:  Recovery  and  Resilience  Scoreboard  - 
https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/index.html 

Up to date data on Cohesion Policy Funds for each Member State is available at: Cohesion Open Data Platform - https://cohesiondata.ec.europa.eu/  

79 

 
 
 
ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Evaluation questions  

Judgement criteria  

Indicators/descriptors 

Effectiveness 

EQ1.  How  successful  has  the  PSLF  been  in  (or 
progressing towards) achieving its objectives?  

Implementation progress of PSLF 

• 
•  Extent to which implementation is successful  

•  Analysis of implementation data 
•  Output and results indicators  
•  Stakeholder feedback on PSLF implementation  
•  Case studies feedback on PSLF implementation 

in specific EU Member States 

EQ2. Does the Call for proposals adequately reflect 
the  objectives  and  requirements  of  the  PSLF 
Regulation?   

•  Comparison of PSLF Call for Proposals with 

the PSLF Regulation  

•  Analysis of the Call for Proposals 
•  Analysis of the requirements of the PSLF 

Regulation  

EQ3.  Have  less  developed  regions  been  able  to 
access  PSLF  as  much  as  transition  and  more 
developed  regions?  What  factors  have  driven  or 
hindered this?  

•  Capacity of less developed regions to access 

• 

PSLF  

Internal expertise on factors influencing uptake 
in less developed regions  

•  Comparison with transition and more 

•  Analysis of implementation data of less 

developed regions  

developed regions 

EQ3.1 Are the measures designed to support PSLF 
implementation in less developed regions (i.e. bonus 
points, 
technical 
  higher  grant  coverage  and 
assistance) been effective?  

EQ3.2 has administrative capacity been a hindering 
factor for PSLF uptake? 

EQ4.  To  what  extent  have  PSLF  potential 
beneficiaries and applicants been able to access the 
advisory support offered under PSLF by the EIB?  

•  Extent to which PSLF potential beneficiaries 
and applicants have been able to access PSLF 
advisory support by the EIB 

•  Analysis of relevant studies regarding 

administrative capacity of less developed 
regions  

•  Stakeholder feedback on factors influencing 

uptake in less developed regions 

•  Case studies feedback on factors influencing 

uptake in less developed regions in specific EU 
Member States   

Internal expertise on advisory support by EIB  

• 
•  Analysis of implementation data of PSLF 

advisory support by EIB  

•  Analysis of recent studies about advisory 

services of the EIB  

•  Stakeholder feedback about PSLF advisory 

services by EIB  

80 

 
 
 
 
EQ5.  To  what  extent  have  the  communication  and 
information actions affected PSLF implementation?  

•  Extent to which communication and 
information actions affect PSLF 
implementation 

EQ5.1.  which  communication  and 
channels have been most effective? 

information 

EQ5.2.  to  what  extent  have  potential  beneficiaries 
and  applicants  been  able  to  receive  answers  to 
questions related to PSLF? 

EQ5.3. How are the visibility obligations applied?  

EQ6. What internal and external factors can explain 
the difference in PSLF uptake between EU Member 
States?  

• 

Internal and external factors explaining the 
difference in PSLF between EU Member States 

•  Analysis of relevant legal and policy 

documents related to PSLF 

•  Case studies feedback about PSLF advisory 
services by the EIB in specific EU Member 
States 

• 

Internal expertise on communication and 
information related to PSLF 

•  Analysis of communication and information 

related documents 

•  Stakeholder perception on information and 

communication related to PSLF 

•  Case studies feedback on information and 

communication related to PSLF in specific EU 
Member States  

•  Stakeholder feedback on factors explaining 

difference in PSLF uptake 

•  Case studies feedback regarding factors 
explaining difference in PSLF uptake in 
specific EU Member States  

Internal expertise on TJTPs 

• 
•  Analysis of TJTPs 
•  Stakeholder perception on PSLF in TJTPs 

EQ7. Has the inclusion of PSLF in TJTPs framework 
benefited its implementation?  

•  Benefits from PSLF inclusion in TJTPs 

EQ8. To what extent can the objectives of PSLF still 
be achieved in time?  

•  Extent  to  which  PSLF  objectives  can  still  be 

achieved in time 

•  Analysis of data implementation 
•  Analysis of relevant legal and policy documents  

EQ9.  What  are  the  expectations  for  PSLF  project 
pipelines in the different EU Member States?  

•  Expectations of PSLF project pipelines in 

different EU Member States  

• 
Internal expertise on PSLF project pipelines 
•  Analysis of relevant national and EU policy 

documents   

81 

 
 
EQ10.  Are  there  any  unexpected  or  unintended 
effects  that  have  occurred,  and  which  drove  or 
hindered PSLF progress?  

•  Unexpected and unintended effects hindering 

•  Stakeholder feedback on effects hindering 

PSLF progress 

PSLF progress 

•  Case studies feedback on effects hindering 

PSLF progress in specific EU Member States 

EQ11. How have EU Member States been supporting 
PSLF implementation?  

•  EU Member States support to PSLF 

implementation 

Internal expertise of EU Member States support  

• 
•  Stakeholder feedback on EU Member States 

•  Stakeholder feedback on PSLF project 

pipelines  

EQ12.  To  what  extent  has  PSLF  contributed  to 
environmental objectives62?  

•  Contribution to environmental objectives 

support to PSLF 

•  Case studies feedback on EU Member States 

support to PSLF in specific  EU Member States 

•  Analysis of implementation data 
•  Case studies feedback on contribution to 
environmental objectives in specific EU 
Member States 

EQ13.  To  what  extent  is  there  a  need  to  carry  out 
gender impact assessment?  

•  Extent to which there is need for gender impact 

assessment   

Internal expertise of the gender aspect of PSLF 

• 
•  Analysis of implementation data 

EQ14.  To  what  extent  are  KPIs63  allowing  proper 
assessment of PSLF? 

•  Extent to which KPIs allow proper assessment 

of PSLF  

Internal expertise of PSLF KPIs 

• 
•  Analysis of legal and policy documents  

Efficiency  

EQ15.  To  what  extent  are  the  costs  appropriately 
sized to achieve the benefits?  

•  Extent to which costs are sized to achieve 

benefits 

•  Use and adequacy of financial and human 

resources 

Internal expertise of PSLF costs 

• 
•  Cost-benefit analysis 
•  Stakeholder perception on use and adequacy of 

financial and human resources 

EQ15.1  Are  the  available  financial  and  human 
resources  adequate  to  achieve  the  objectives?  Are 

62 art. 9 EU Regulation 2020/852 
63 Annex II PSLF Regulation  

82 

 
 
 
 
 
 
they  used  in  an  optimal  manner  to  deliver  PSLF 
objectives? 

EQ16.  What  is  the  leverage  ratio  and  multiplier  of 
PSLF contribution?  

•  Leverage and multiplier of PSLF 

•  Analysis of implementation data 

EQ17. Have any inefficiencies been identified? What 
is the potential simplification and cost-reduction of 
the PSLF? 

Inefficiencies of PSLF 

• 
•  Potential simplification and cost-reduction  

•  Analysis of legal and policy documents 
•  Feedback perception on inefficiencies  
•  Case studies perception on inefficiencies in 

specific EU Member States  

EQ18.  How  timely  and  efficient  is  the  PSLF 
reporting and monitoring system?  

•  Efficiency of PSLF reporting and monitoring 

• 

system 

Internal expertise of PSLF monitoring and 
reporting system 

•  Analysis of legal and policy documents 
•  Stakeholder perception on PSLF reporting and 

monitoring system 

EQ19. Is the application process well understood by 
potential  applicants  and  conducive  to  submit  high 
quality applications?  

•  Potential applicants’ understanding of the 

application process 

•  Quality of the applications 

Coherence  

EQ20. To what extent is PSLF coherent with other 
EU  and  national 
funding 
interventions  and 
programmes that have similar objectives? 

•  PSLF coherence with EU funding programmes 

• 

•  Analysis of the quality of applications 
•  Stakeholder 

feedback  on 

the  applicants’ 

understanding of the application process 

Internal expertise of PSLF coherence with other 
EU and national funding programmes and 
interventions  

•  Analysis of legal and policy documents 
•  Stakeholder perception of PSLF coherence with 
other EU and national funding programmes and 
interventions  

•  Case studies feedback on PSLF coherence with 
other EU and national funding programmes and 
interventions in specific EU Member States  

and interventions 

•  PSLF coherence with national funding 

programmes and interventions  

83 

 
 
EQ21. To what extent is PSLF coherent with other 
JTM  Pillars  (i.e.  JTF  and  InvestEU  just  transition 
scheme)?  

•  PSLF coherence with other JTM Pillars 

• 

Internal expertise of PSLF coherence with other 
JTM Pillars 

•  Analysis of legal and policy documents 
•  Stakeholder feedback about PSLF coherence 

with other JTM Pillars 

•  Case studies feedback about PSLF coherence 

with other JTM Pillars 

EQ22. To what extent does TJTP framework support 
coherence between investments supported under the 
JTM Pillars? 

•  TJTP framework support to coherence between 

JTM Pillars  

Internal expertise of TJTP framework  

• 
•  Analysis of TTJPs 

EQ23. To what extent has technical support provided 
under  other  EU  instruments  and  funds  for  the  just 
transition  have  been  complementary  to  advisory 
support services under PSLF by EIB?  

•  Complementarity of other technical support 
with EIB advisory services under PSLF  

EU added value  EQ24. Would the objectives of PSLF be pursued in 
its  absence?  What  is  the  expected  added  value  of 
PSLF  compared  to  what  could  be  reasonably 
achieved by EU Member States on their own and/or 
by other available EU funding instruments?  

•  Expected added value of PSLF 

EQ25.  Would  projects  financed  by  the  PSLF 
materialise  without  the  grant  component  of  the 
PSLF?  

•  Expected added value of the grant of PSLF 

• 

Internal expertise of coherence between 
technical assistance for the just transition and 
EIB PSLF advisory services 

•  Analysis of policy documents 
•  Stakeholder perception of coherence between 

technical assistance and EIB PSLF advisory 
support  

•  Analysis of implementation data 
•  Analysis of policy documents 
•  Stakeholder feedback on PSLF added value 
•  Case studies feedback on PSLF added value in 

specific EU Member States 

•  Analysis of implementation data 
•  Stakeholder  feedback  on  added  value  of  the 

grant  

•  Case  studies  feedback  on  added  value  of  the 

grant in specific EU Member States 

84 

 
 
 
Relevance  

EQ26. To what extent is PSLF still relevant for the 
just transition needs of the TJTP regions? 

•  PSLF design in line with the needs of TJTP 

regions 

•  PSLF objectives in line with the needs of TJTP 

regions  

Internal expertise on PSLF relevance  

• 
•  Analysis of TJTPs regarding PSLF 
•  Analysis of the relevance of the design and 

objectives of the PSLF 

•  Stakeholder perception on the relevance of the 

PSLF  

•  Case studies feedback on the relevance of 

PSLF in specific countries  

EQ27.  How  well  adapted  is  PSLF  to  changes  and 
developments that have emerged since its inception?  

•  PSLF adaptation to changes and developments 

• 

emerging since inception  

Internal expertise on PSLF changes and 
developments that have emerged since 
inception 

•  Analysis of TJTPs and other recent studies 
about changes and developments that have 
emerged since inception  

•  Comparison of PSLF implementation with 

recent Commission Guidelines and priorities  

•  Stakeholder feedback on changes and 

developments regarding PSLF 

•  Case studies feedback on changes and 

developments regarding PSLF  

EQ28. Are PSLF beneficiaries able to make use of 
PSLF as a debt-based instruments? Is their capacity 
limited by factors such as pre-existing level of debts, 
legislation  or  credit  exposure  with 
national 
EIB/financial intermediaries?  

•  PSLF beneficiaries’ ability to use PSLF as 

•  Analysis  of 

relevant 

literature 

(national 

debt-based instruments 

legislation, debt levels, etc.) 

•  Stakeholder feedback on beneficiaries’ capacity 

to make use of PSLF  

•  Case studies feedback on beneficiaries’ capacity 

to make use of PSLF  

85 

 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

Following the Commission’s Better Regulation Guidelines, this Annex aims to outline the actual costs and benefits of the PSLF programme and assess 
their proportionality. It should be noted that due to the early stage of implementation of the PSLF, many costs and benefits have not materialised yet. During 
the  timeframe  defined  for  this  evaluation,  none  of  the  grant  agreements  that  have  been  already  signed  had  to  report  any  results  yet.  Considering  all 
limitations, this annex presents only a partial analysis looking into some  ‘direct’ and administrative costs and benefits of the Facility that can be presented 
at this stage of implementation. A full cost-benefit will be part of the final evaluation. 

In addition, it should be also noted that it was not feasible to quantify the administrative costs linked to the projects in the scope of this evaluation, nor it 
was feasible to quantify any simplification, burden reduction and cost savings (potential or achieved) at this stage of implementation due to the same reasons 
as explained above. 

Direct costs of the PSLF programme64  

Cost to the EU budget 

Costs include mainly staff resources with 4 FTEs operating in the Commission’s Directorate DG REGIO to implement the PSLF and 6 FTEs working at 
CINEA.  

DG REGIO staff’s activities relate to programme management, encompassing a range of tasks such as: 

-  Preparing the Facility’s financing decisions and work programmes.  
-  Raising awareness about the PSLF and other communication and promotion activities. 
-  Evaluating proposals together with CINEA staff. 
-  Contributing to modifications of the TJTPs. 
-  Setting up agreements and liaising with CINEA and the EIB (lending and advisory) to implement the PSLF, including participation in the Policy 

Dialogues of the InvestEU Advisory Hub.   

-  Liaising with geographical units. 
-  Monitoring and reporting about the Facility’s implementation, including Issuing the implementation report in accordance with Article 16 of the 

PSLF Regulation. 

64 Data January 2025 

86 

 
 
-  Conducting evaluations in accordance with Article 17 of the PSLF Regulation. 
-  Financial management of the programme. 

The overall staff costs within DG REGIO are calculated were EUR 1.038.728 over the period 2022-24. 

The delegation of the PSLF implementation to CINEA and the allocation number of staff allocated to the agency were decided in 2020 following a dedicated 
cost-benefit analysis exercise. CINEA current staff resources amount to 5 operational and 1 management and support FTEs of which activities encompass 
a range of tasks related to calls for proposals management, such as: 

Information to applicants and preparation of the award decisions and individual Grant Agreements. 
Information to DG REGIO on the Grant Agreements signed. 

-  Preparation and publication of the PSLF Call for Proposals. 
-  Evaluation and selection procedure. 
-  Follow up of the Evaluation Committee and information of the Finance Partner. 
- 
- 
-  Amendments of Grant Agreements. 
- 
-  Feedback to policy and synergies. 
- 
-  Raising awareness about the PSLF and other communication and promotion activities.  
-  Contribution to evaluation of the PSLF.  

IT support systems, including e-Grants and QlickSense. 

Implementation of the Grant Agreements. 

The  decision  to  delegate  the  implementation  of  the  PSLF  to  CINEA  was  taken  on  basis  of  the  Commission’s  2014-20  MFF  experience  which  had 
demonstrated that Brussels based agencies worked efficiently and produced budgetary savings in the implementation costs of the programmes. In addition, 
CINEA would support DG REGIO which had limited experience in managing calls for proposals implemented in direct management. 

It is important to note that the current number of FTEs remains under CINEA maximum allocation of staff (17 FTEs in 2024)65 which was initially estimated 
and agreed from 2022 onwards. This is due to the limited and delayed uptake of PSLF and a lower number of grant agreements to manage compared to the 
initial estimation.   

65  An increasing number from 4 in 2021 to 31 in 2027 was agreed for the implementation of PSLF.  

87 

 
 
 
Next to staff related expenditure, the operating budget for CINEA also covers infrastructure and operating expenditure as well as other programme related 
support expenditure such as communication, translation and other costs. The overall budget which was contributed to CINEA over the past period 2021-
24, including staff costs,  amounts to EUR 3.191 million. 

Finally, the PSLF programme also entails a number of additional costs such as: 

-  Costs related to missions of PSLF staff. 
-  Costs related to onboarding eGrants. 
-  Costs related to communication and awareness raising activities. 
-  Costs related to other technical and administrative expenditure such as evaluation. 

Table 2: Other PSLF costs – budget utilisation 

Cost item 

Missions 

Commitments (2022-24) 

54.300 

eGrants+SEDIA 

302.450 

Communication 
awareness raising  

and 

5.034 

Evaluation  

128.000 

Source: European Commission. 

Administrative costs and burden for advisory and financing partner of the PSLF 

Regarding the advisory services delivered by the EIB under the InvestEU Advisory Hub, it is important to note that the costs of providing the advisory 
support are fully covered by the Commission. Hence, no additional costs are anticipated on the side of the EIB as the advisory partner.  

88 

 
 
Concerning  the  implementation  of  the  loan  component  of  the  PSLF,  all  its  costs  are  fully  covered  by  the  EIB.  No  fees  are  paid  to  the  EIB  for  the 
implementation  of  the  loan  Facility.  The  internal  rules  and  procedures  of  the  EIB  are  not  within the  scope  of  this  evaluation  and  thus  the  cost  of the 
implementation of the loan component are not covered here.  

The cost of the implementation of the loan component by the EIB’s financial intermediaries, in particular NPBIs, was not collected either. This limitation 
stems from the fact that the period in which the study collected evidence (between end of April 2024 and end of October 2024) coincided with the submission 
of most intermediated lending PSLF projects which were submitted under the 6th (17 April 2024) and 7th cut-off date (19 April 2024). By the end of the 
study, these intermediated lending projects had only just been approved by the PSLF Evaluation Committee. None of these intermediated lending PSLF 
projects had been signed at the time of the analysis, and until today, they are still awaiting the approval of the loan component. As a consequence, the NPBI 
engagement was in very preliminary stages, making it too early to assess any outcomes or cost-related effects.  

Administrative costs and burden for applicants and beneficiaries  

Applicants  and  final  beneficiaries  of  the  PSLF  invest  effort,  time  and  resources  to  prepare  advisory  requests  and  project  and  loan  applications  and  to 
implement projects. This includes also reporting requirements in compliance with the legal obligations as set out in the grant and loan agreements of the 
related PSLF projects. Given the limited sample size of PSLF applicants and beneficiaries, the evaluation did not include a specific methodology to estimate 
the actual costs related to their involvement in the PSLF. Instead, this will be part of the future evaluation. 

Administrative costs and burden for MS administrations 

MS administrations invest effort, time and resources to help implement the PSLF. This support can range from raising awareness to identifying projects 
and  project  promoters  and  type  of  related  activities.  Given  the  limited  scope  of  this  evaluation,  these  costs  have  not  been  estimated  at  this  stage  of 
implementation. Instead, this will be part of the future final evaluation. 

Benefits of the PSLF programme  

This section provides a summary of the 'direct' benefits that can be observed at this early stage of implementation. While comprehensive KPIs data remains 
limited, preliminary evidence of the PSLF's reach is presented here, covering the period 2022-24. As previously noted, estimating the 'wider' benefits of 
the PSLF is not yet feasible and will be subject to the final evaluation. 
Early evidence of the PSLF collected on the basis of the KPIs (as per Annex II of PSLF Regulation) is presented below: 

•  7 projects have received PSLF financing.  
•  Four countries are concerned: Sweden (1), France (3), Greece (1), and Czechia (2). 

89 

 
•  3.450 million of people across Europe are expected to be reached by these projects. 
•  5745 jobs are expected to be created following implementation of these projects. 
•  135.805 metric tons per year is the expected reduction in CO2 following implementation of these projects. 

Overview of costs and benefits  

The table 3 below provides a summary overview of the costs and benefits that could be assessed at this stage of implementation. As previously explained, 
the evaluation can only provide an incomplete picture due the early stage of the implementation of the programme as well as non-availability of data. 

Table 3: overview of the costs and benefits 

Table. Overview of costs and benefits identified in the evaluation 

 Citizens/EU society 

Applicants/ Beneficiaries 

Finance partner (EIB) 

MS administrations 

Quantitative  

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Administrative 
costs of 
implementing 
PSLF 

Recurrent 

10 FTEs 
+  Other costs 
such as 
communication, 
evaluation and e-
Grants 

of 
and 

Administrative 
costs 
applicants 
beneficiaries  
participation 
the PSLF 

in 

One off  

Not estimated  Applicants 

final 
and 
beneficiaries 
invest effort, 
and 
time 
money 
to 
apply, 
implement, 
monitor  and 
report 
on 
PSLF 
projects  

90 

 
 
 
                        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Not estimated  All  costs  are 
covered  by 
the  EIB  (no 
fee 
agreement 
with 
European 
Commission) 

the 

Not estimated   MS 

administrations 
spend  effort,  time 
to 
and  resources 
PSLF 
support 
implementation. 

Administrative 
costs of finance 
partner (EIB) 

Recurrent    

Administrative 
costs of MS 
administrations   

Recurrent    

Benefits: 
Direct benefits  

Short and 
long term 

7 projects 
received 
financing  

Around 3.450 
mln people are 
expected to  be 
reached. 

Around 5745 jobs 
are expected to be 
created  

Around 135.805 
metric tons  per 
year is the 
expected 
reduction in CO2  

Indirect benefits  Long 
term 

Not estimated  

91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TABLE.  Simplification and burden reduction (savings already achieved)  

Citizens/EU society  

Applicants/ Beneficiaries 

Finance partner (EIB) 

MS administrations 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative  Comment  

Quantitative  Comment 

Use of Financing Not Linked to Costs (direct compliance cost savings) 

Type: recurrent 

N/A. 

The use of Financing 
Not  Linked  to  Costs 
impact  on 
has  no 
citizens. 

Not 
estimated.   

Not estimated.    The use of 

Financing Not 
Linked to Costs 
is positively 
perceived by 
French and 
Greek 
beneficiaries but 
no quantification 
has taken place.  

N/A.   

The 
use 
Financing  Not 
Linked to Costs 
has  no  impact 
on 
MS 
administrations. 

The  use  of 
financing  not 
linked  to  costs 
to calculate the 
amount  of  the 
grant  based  on 
loan 
the 
amount 
improves 
the 
visibility of the 
the 
into 
EIB 
final allocation 
of 
co-
financing 
sources 
PSLF 
supported 
investments. 

for 

PART II: II Potential simplification and burden reduction (savings) 

Citizens/EU society 

Applicants/ Beneficiaries 

Finance partner (EIB) 

MS administrations 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment   Quantitative 

Comment 

Description: N/A (none identified) 

Type:  One-off / recurrent (select) 

N/A. 

N/A. 

N/A. 

N/A. 

N/A. 

N/A. 

N/A. 

N/A. 

92 

 
 
               
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

The stakeholder consultation was based on a strategy that involved a public Call for Evidence (launched by the European Commission as part of the Better 
Regulation cycle), a targeted survey (through EU Survey), interviews and feedback collected during dedicated PSLF events.  

Table 4: Overview of the consultation strategy. 

Consultation activity 

Call for Evidence  

Stakeholders targeted 

Timing 

Individual citizens, academic and research institutions, 
NGOs, consumer and social organisations, individual 
economic operators and representatives as well as public 
authorities. 

2 February 2024 - 1 March 
2024; 2 responses 

Survey 

Different categories were targeted:  

9 July 2024 - 13 September 
2024; 102 submissions 

•  National, regional and local public authorities; 
•  Other public or quasi-public organisations; 
•  Private bodies (with a public service mission); 
•  Applicants/beneficiaries; 
•  European Commission and/or CINEA; 
•  European Investment Bank (EIB); 
•  National and regional promotional banks and 

institutions; 

•  Research and academia; 
•  Third-party interest groups (non-governmental 
organisations, trade unions, social partners). 

93 

 
 
Interviews 

Three groups were interviewed: 

4 July 2024 - 11 November 
2024; 39 interviews 

•  EU institutional actors; 
•  Beneficiaries, applicants and  national, regional and 

local authorities; 
•  Other stakeholders. 

Workshop ‘Translating just transition from plans into 
investments: combining grants, financing and advisory’ in 
the context of the European Week of Regions and Cities 
202466 

Cohesion policy managing authorities, NGOs, academic 
and research institutions, staff from EU institutions, and 
other cohesion policy stakeholders. 

8 October 2024 

Session ‘Third Pillar of the Just Transition Mechanism – All 
You Want to Know’ in the context of the 10th Just 
Transition Platform Conference67 

JTF managing authorities, NGOs, academic and 
research institutions, and other just transition relevant 
stakeholders.  

16 October 2024 

Source: Supporting Study. 

Call for Evidence 

The Call for Evidence supported the preparation of the PSLF interim evaluation. It was open for feedback from 2 February 2024 to 1 March 2024.  The 
Commission received only two responses which were unrelated to the topic of the consultation. One comment was removed as it did not comply with the 
European Commission's rules for publishing feedback and suggestions. 

66 European Investment Bank & European Commission (2024). Translating Just Transition from plans into investments: Combining grants, financing and advisory support. Workshop 
organised by the European Investment Bank and the European Commission in the European Committee of the Regions as part of the European Week of Regions and Cities. Background 
note. Retrieved from  https://regions-and-cities.europa.eu/sites/default/files/webform/multimedia_center/42490/ewrc-session-outline_8-oct-2024_final.pdf (last accessed on  10  October 
2024). 
67 See https://app.swapcard.com/event/10th-just-transition-platform-conference/planning/UGxhbm5pbmdfMjA1NDM0Ng== (last accessed on 10 October 2024). 

94 

 
 
Overview of the survey findings  

Relevance 

35% (33 out of 93) of the respondents indicated  that the grant is relevant ‘to a very large extent’ for them. 25% (23 out of 93) accounts for ‘to a large 
extent’,  while  32% (30 out of 93) indicated the grant to be relevant only  ‘to some extent’. 6% (6 out of 93) of the respondents answered that the grant is 
relevant ‘to little extent’ and 1% (1 out of 93) ‘to no extent’.  

Looking  into  stakeholders  that  could  be  eligible  for  support  under  the  PSLF  (including  local/regional/national  authorities,  private  bodies  (with  public 
mission), applicants and beneficiaries and other public/quasi-public organisations), the picture is even more favourable with 43% (24 out of 56) indicating 
it is relevant ‘to a very large extent’, while for 30% (17 out of 56) it is ‘to a large extent’. ‘To some extent’ has 18% (10 out of 56), ‘to little extent’ 7% (4 
out of 56), and ‘to no extent’ 2% (1 out of 56). 

In comparison, the 20 responses from the Commission, CINEA and EIB were less optimistic. The category ‘to a very large extent’ saw 15% (3 out of 20). 
‘To a large extent’ accounts for 20% (4 out of 20), while ‘to some extent’ includes 60% (12 out of 20). ‘To little extent’ was 5% (1 out of 20). 

47% (27 out of 58) are either implementing projects benefiting from PSLF or intend to submit a proposal to a PSLF call. Of those 27 participants, more 
than 50% responded that the grant component is relevant ‘to a very large extent’ and for 33% ‘to a large extent’. 

Figure 13 indicates that ‘renewable energy and energy efficiency’ projects are the most common, with 18 out of 27 respondents indicating they intend to 
implement or are implementing projects. ‘Urban infrastructure’ follows with 9 projects, followed by ‘social infrastructure, including social housing’ with 
6 intended to be implemented or implemented. Other significant categories include ‘digitalisation’ and ‘transport’, each with 5 projects. There are fewer 
responses for ‘circular economy’ (2) and ‘land restoration’ (2). 

For those not implementing projects or none are planned, many have indicated that they have limited capacity, high loan thresholds and that the application 
process is rather complex. Additionally, they find it difficult to manage large-scale projects due to their limited own budgets.  

95 

 
Figure 13: areas in which stakeholders intend to implement or are implementing projects supported under PSLF 

Source: Supporting Study.  

Effectiveness 

11% (10 out of 92) of the respondents answered that PSLF is effective in addressing the social, economic and environmental objectives of the transition ‘to 
a very large extent’, 22% (20 out of 92) ‘to a large extent’, 35% (32 out of 92) ‘to some extent’, 24% (22 out of 92) ‘to little extent’ and 8% (8 out of 92) 
‘to no extent’. 

96 

122333556918Other.Circular economy.Land and ecosystem restoration.Up-skilling, reskilling and training.Environmental infrastructure.District heating networks.Digitalisation.Transport.Social infrastructure, including social housing.Urban infrastructure.Renewable energy and energy efficiency. 
 
 
Figure 14: the extent to which PSLF has been effective in addressing the challenges of the transition. 

Source: Supporting Study. 

Looking  into  stakeholders  that  could  be  eligible  for  support  under  the  PSLF  (including  local/regional/national  authorities,  private  bodies  (with  public 
mission), applicants and beneficiaries and other public/quasi-public organisations), 21% (10 out of 48) of them indicated PSLF is effective ‘to a very large 
extent’, while for 27% (13 out of 48)) said it is effective ‘to a large extent’,  29% (14 out of 48) ‘to some extent’, 15% (7 out of 48) ‘to little extent’, and 
8% (4 out of 48) ‘to no extent’.  

In comparison, the 20 responses from the Commission, CINEA and EIB were less optimistic. 15% (3 out of 20) account for ‘to a large extent’, 40% (8 out 
of 20) ‘to some extent’, 35% (7 out of 20) ‘to little extent’ and 10% (2 out of 20) ‘to no extent’. 

When the participants were asked to explain their assessment, the key points that were raised concerns the following: 

97 

To a very large extent.To a large extent.To some extent.To little extent.To no extent.11% (10)22% (20)35% (32)24% (22)8% (8) 
 
 
 
 
 
 
 
 
 
 
 
-  PSLF is seen as crucial for supporting just transition in regions aiming to reach climate objectives and for providing financial resources for the just 

transition.  

-  PSLF is essential for making investments feasible, particularly in negatively affected regions by the green transition  
- 

10% (7 out of 70) indicated that PSLF is needed for larger grants to reduce financial burdens on public authorities and better align with other funding 
sources.  

-  PSLF is less attractive compared to other EU funds. 
- 

Figure 15 shows the circumstances influencing the uptake of the PSLF. This includes among others ‘difficulty to apply/insufficient administrative capacity’ 
with a score of 3.53 in an index68 created to compare the responses. This is followed by ‘overlap of the PSLF with other funding sources offering better 
financing conditions’ with 3.38. The item ‘limited mature projects available to absorb the available funding’ scores 3.26. ‘PSLF sectors not in line with 
investment priorities’ and ‘shortage of skills and labour’ seem to be less influencing factor for the uptake of PSLF with score of 2.55 and 2.47 respectively.  

68 The index rates how much each circumstance influenced the uptake of PSLF on a scale from one (‘to no extent’) to five (‘to a very large to extent’). Each response is rated from one 
(‘to no extent’) to five (‘to a very large extent’), and the sum is divided by the total number of responses. 

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Figure 15: The extent to which the uptake of the PSLF been influenced by evolving circumstances. 

Source: Supporting Study 

Regarding the extent to which stakeholders feel informed about the PSLF, figure 16 shows that 27% (19 out of 70) responded ‘to a large extent’, 36% (25 
out of 70) ‘to some extent’, and 27% (19 out of 70) ‘to little extent’, while 6% (4 out of 70) answered ‘to no extent’. Respondents from TJTP territories 
seem to be informed as much as those outside with 6% (2 out of 36) indicating they are informed ‘to a very large extent’, 19% (7 out of 36) ‘to a large 
extent’ and ‘to some extent’ accounts for 50% (18 out of 36). 

99 

2.472.552.782.792.963.063.263.383.53 Shortage of skills and labour. PSLF eligible sectors not in line with investment prioritiesof the EU Member State at national, regional or local level. Energy crisis and high construction prices. High loan interest rates. No other sources of co-financing available to combine withthe PSLF grant and the PSLF loan. Regulatory/legal restrictions to subscribe to debt. Limited mature projects available to absorb the availablefunding. Overlap of the PSLF with other funding sources offeringbetter financing conditions. Difficulty to apply/insufficient administrative capacity toapply to the PSLF. 
 
Figure 16: The extent to which respondents feel informed about the PSLF. 

Source: Supporting Study. 

Most respondents (38 out of 69) received information about the PSLF from the European Commission and/or CINEA. This is followed by the EIB (25 out 
of 69), national authorities (13 out of 69), regional authorities (12 out of 69) and local authorities (10 out of 69) of EU Member States. A few respondents 
received information about the PSLF from other sources (5 out of 69) or from a third-party interest group (3 out of 69). 

The  information  was  mostly  received  through  e-mails  (44  out  of  71),  followed  by  meetings  (33  out  of  71),  website/online  material  (30  out  of  71), 
involvement in preparing the TJTP (21 out of 71), events (16 out of 71), and social media/newsletter (12 out of 71). 

60% of respondents (37 out of 62) were aware of the advisory and technical assistance services available for PSLF, while 40% (25 out of 62) were not. Of 
the 24% (8 out of 34) who made use of advisory and technical assistance, it was mostly for ‘project preparation and development’ (4 out of 34), followed 
by ‘project identification/generation’ (2 out of 34) and ‘other’ (2 out of 34). Both ‘financial structuring’ and ‘market development activities’ were mentioned 
once each. Of the 8 who used the services, 25% (2 out of 8) were satisfied ‘to a very large extent’, while 50% (4 out of 8) and 25% (2 out of 8) were 
satisfied ‘to a large’ and ‘to some extent’. 

100 

To a very large extent.To a large extent.To some extent.To little extent.To no extent.27% (19)36% (25)27% (19)6% (4)4% (3) 
  
 
 
 
 
 
 
 
Efficiency 

Figure 17 shows specific obstacles regarding the process to apply for the PSLF. ‘Awareness about the PSLF, call for proposals, and support available’ 
account for 41 responses, followed by ‘project preparation, regulatory and permitting processes’ (40) and ‘limited public resources which can be leveraged 
by the PSLF’ (30). ‘Accessing technical assistance for the preparation of the project’ and the ‘duration of the application’ are less of an obstacle with 19 
and 17 responses respectively.  

Figure 17: obstacles regarding the application process of the PSLF 

Source: Supporting Study. 

23% (19 out of 84) responded that such obstacles prevent them from applying for PSLF ‘to a very large extent’. In comparison, 46% (39 out of 84) indicated 
‘to a large extent’, 25% (21 out of 84) ‘to some extent’, 2% (2 out of 84) ‘to little extent’ and 4% (3 out of 84) ‘to no extent’. 

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13171923282929304041051015202530354045Other.Duration of the application process.Accessing technical assistance for the preparation of theproject.Coordinating among various stakeholders involved.Obtaining financing by the EIB or its financialintermediaries (e.g., difficulty to take up an EIB loan…Complexity of the application process.Understanding of the PSLF’s scope of support, including eligibility.Limited public resources which can be leveraged by thePSLF.Project preparation, regulatory and permitting processes.Awareness of the PSLF’s existence, calls for proposals and support available. 
 
 
 
 
 
 
 
 
 
 
To improve PSLF implementation, the qualitative feedback emphasises the need for better integration between grant  and loan components, simplified 
processes  and  clearer  communication  from  the  European  Commission/CINEA.  Suggestions  also  include  expanding  eligibility  to  more  public  entities, 
increasing the grant share and offering more training on the application process. Many respondents call for greater flexibility to accommodate smaller 
projects and to combine PSLF with other funds that share a similar objective. More local support from national and regional bodies with improved outreach 
and promotion of PSLF were also suggested. 

Coherence 

The  index69  to  compare  responses  on  synergies  between  PSLF  and  other  EU  instruments  had  a  score  of  3.61  for  synergies  with  the  ‘Just  Transition 
Mechanism Pillar 1 (Just Transition Fund)’. Following this, ‘Cohesion Policy funds (European Social Fund Plus, European Regional and Development 
Fund, Cohesion Fund)’ scored 3.36. The ‘Just Transition Mechanism Pillar 2 (InvestEU 'Just Transition' scheme)’ scored 3.18,  ‘Recovery and Resilience 
Facility’ 2.95, while ‘Other’ scored 2.71. Fewer synergies exist with CEF (2.52), and LIFE (2.31). 

69 An index has been calculated that rates the synergies on a scale from one (‘to no extent’) to five (‘to a very large to extent’). Each response is rated from one (‘to no extent’) to five (‘to 
a very large extent’), and the sum is divided by the total number of responses. 

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Figure 18: The extent to which there are synergies between the PSLF and the following EU instruments and funds at the intervention level70. 

Source: Supporting Study. 

EU added value 

Figure 19 shows that 39% (35 out of 90) of the respondents indicated PSLF to have a ‘high added value’, 34% (31 out of 90) ‘some added value’, 11% (10 
out of 90) ‘not so much added value’ and 7% (6 out of 90) ‘no added value’. 

70 Responses vary across the options, 67 referring to LIFE, 73 to CEF, 76 to RRF, 78 to JTM Pillar II, 82 to JTF, 83 to cohesion policy funds. 

103 

2.312.522.953.183.363.61Life programme.Connecting Europe Facility.Recovery and Resilience Facility.Just Transition Mechanism Pillar 2 (InvestEU"Just Transition" scheme).Cohesion Policy funds (European Social FundPlus, European Regional and DevelopmentFund, Cohesion Fund).Just Transition Mechanism Pillar 1 (JustTransition Fund). 
 
 
 
 
 
 
 
 
 
 
 
Looking  into  stakeholders  that  could  be  eligible  for  support  under  the  PSLF  (including  local/regional/national  authorities,  private  bodies  (with  public 
mission), applicants and beneficiaries and other public/quasi-public organisations), 12% (6 out of 50) of them replied there is an ‘extremely high added 
value of the PSLF’. In comparison, ‘high added value of the PSLF’ accounts for 32% (16 out of 50), ‘some added value of the PSLF’ includes 36% (18 out 
of 50), ‘not so much added value’ represents 12% (6 out of 50), and ‘no added value of the PSLF’ comprises 8% (4 out of 50).  

30% (6 out of 20) of the responses from the Commission, CINEA and EIB reveal that PSLF add ‘high value’. In comparison, ‘some added value’ accounts 
for 45% (9 out of 20), with ‘not so much added value’ representing 15% (3 out of 20).  

The survey indicates that PSLF has a high potential to support the transition towards EU climate objectives, especially for projects that otherwise would 
not be funded. However, the added value of the PSLF seem to be limited by administrative capacity, the lack of mature projects and alternatively by more 
attractive available funding sources. 

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Figure 19: The EU added value of the PSLF for the just transition in EU Member States71 

Source: Supporting Study. Note: The number of responses is in brackets. 
Overview of the interview findings 

Relevance 

Feedback suggests that PSLF is highly relevant for addressing just transition needs, particularly given the substantial investments needed to counter  climate 
change (actors with EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and 
civil society). The PSLF is seen as a critical financial instrument to complement the limited financial resources available at the level of EU Member States 
(actors within EU institutions). Moreover, it is seen as an instrument which can diversify the sources of funding available at the EU level (actors within EU 
institutions). 

71 Low added value means that national/regional policies would fully pursue PSLF objectives, while high added value means that  national/regional policies would not – or to a limited 

extent – pursue PSLF objectives in the absence of PSLF interventions. 

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Extremely high added value of the PSLF.High added value of the PSLF.Some added value of the PSLF.Not so much added value of the PSLF.No added value of the PSLF.39% (35)34% (31)11% (10)7% (6)9% (8) 
 
 
 
 
 
 
 
 
 
It was confirmed that the scope of  support is broad enough to cover PSLF objectives in line with the objectives of the European Green Deal (actors with 
EU institutions, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). This is also 
proved by the scope of the PSLF projects which were received so far aiming at among others   reducing CO2 emissions, diversifying the  economy of just 
transition  regions,  and  retaining  young  people  in  those  regions  by  creating  jobs  and  making  those  regions  more  attractive  for  them  (actors  with  EU 
institutions, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society).  

It was also noted that the PSLF is relevant, though its uptake varies significantly across the different Member States (actors within EU institutions, EIB, 
national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). This depends among others  
on their progress on just transition (actors with EU institutions, other third-party actors such as consultants and civil society).  

Stakeholders also pointed out the limited fiscal capacity of the public sector and country-specific rules and procedures for taking on additional debt that 
generally restricted the use of debt-based instruments like PSLF (actors with EU institutions, EIB, national, regional and local actors, beneficiaries and 
applicants, other third-party actors such as consultants and civil society). While PSLF could be attractive for larger municipalities or entities with more 
experience in handling loans, smaller municipalities might struggle to meet the requirements due to financial and administrative constraints (actors within 
EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). The 
responses highlight the diversity of municipalities, particularly in Romania and Poland (other third-party actors such as consultants and civil society). Some 
municipalities can access financial markets and may find PSLF irrelevant, while others, especially those in transition and less developed regions, seek 
simpler options for project support (actors with EU institutions, EIB, national, regional and local  actors, beneficiaries and applicants, other third-party 
actors such as consultants and civil society). Some beneficiaries, applicants and other authorities indicated that they however prefer support from JTF due  
to its simpler application process, higher grant coverage and lower own contribution. 

Several stakeholders pointed out that PSLF can be relevant for several types of investments (beneficiaries and applicants, other third-party actors such as 
consultants and civil society). However, the complex application process and the related conditions, including repaying loans, can discourage potential 
applicants (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants 
and civil society). Targeted outreach and informative campaigns could help increase awareness and understanding of the PSLF, making it a more appealing 
instrument for municipalities (actors with EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors 
such as consultants and civil society). 

Respondents generally agree that the relevance of PSLF has not significantly changed since its inception  (actors within EU institutions, EIB, national, 
regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). It was suggested however that PSLF 

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may become more relevant once the funding available from other sources such as JTF is absorbed (actors within EU institutions, EIB, other third-party 
actors such as consultants and civil society).  PSLF seems also relevant for local public sector bodies, particularly in Member States that have less resources 
of EU funding available (actors within EU institutions, EIB, beneficiaries and applicants). PSLF being implemented in direct management enables local 
public bodies to access PSLF directly at EU level (actors within EU institutions, national, regional and local actors, beneficiaries and applicants, other third-
party actors such as consultants and civil society).  

Effectiveness 

Interviews  confirm  a  slow  and  challenging  start    of  PSLF  implementation  (actors  within  EU  institutions,  EIB,  national,  regional  and  local  actors, 
beneficiaries and applicants, other third-party actors such as consultants and civil society). Many stakeholders note that it is too early to assess results due 
to  the early stage of implementation (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party 
actors  such  as  consultants  and  civil  society).  Few  projects  are  signed  and  many  of  them  have  just  recently  started  implementation  (actors  within  EU 
institutions). Some stakeholders highlighted that the disbursement of funds has been significantly lower than anticipated.  

The  separate  application  processes  required  for  the  PSLF  EIB  loan  component  and  PSLF  European  Commission  grant  component  have  led  to  some 
confusion and delays for submitting project proposals which can discourage  potential applicants, especially those with limited administrative capacity 
(actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil 
society). Institutional actors highlight that detailed evaluation of applications is critical to ensuring the quality of projects and the soundness of funding 
decisions, as many applications have had difficulty in demonstrating the ability to repay the loan (actors within EU institutions, EIB).  

The example of  France with very high PSLF uptake gives an indication that more developed regions can access PSLF funding more easily (actors with 
EU institutions, EIB).  Another challenge which was highlighted is the administrative capacity of applicants (actors within EU institutions, EIB, national, 
regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). In particular, small regions struggle 
with their administrative capacity to be able to apply for PSLF (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and 
applicants, other third-party actors such as consultants and civil society). Other stakeholders reported that small entities often lack the human resources and 
financial expertise needed to engage effectively with a blending mechanism like PSLF (EIB, national, regional and local actors, beneficiaries and applicants, 
other third-party actors such as consultants and civil society). Therefore, they may prefer other types of funding instruments which they are familiar with 
rather than navigating the novelty of PSLF (EIB, national, regional and local actors, other third-party actors such as consultants and civil society). 

The language of the documents and limited maturity of project pipelines were identified as other challenges for the uptake of the PSLF (actors within EU 
institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). For instance, 

107 

 
 
 
 
 
the interview with the authority from Croatia highlighted the limited project pipeline to address just transition needs, but also the availability of funding 
from other EU sources which limited their engagement with PSLF (national, regional and local actors).    

Beneficiaries, applicants and Member State authorities also pointed to limited fiscal capacity of the public sector and country-specific rules and procedures 
for taking on additional debt that generally restricted the use of debt-based instruments like PSLF (actors within EU institutions, EIB, national, regional 
and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). 

Stakeholders have highlighted the availability and accessibility of advisory services either by the EIB or other sources as crucial for increasing  effectiveness 
of PSLF (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants 
and civil society). Efforts such as developing  handbooks in own language were appreciated (beneficiaries and applicants, other third-party actors such as 
consultants and civil society). It was suggested that  support should be available at all times and is crucial for in particular smaller size entities (actors 
within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society). 

Efficiency 

Interviews confirm that the separate application process for the EIB loan component and the European Commission grant component is perceived as less 
efficient by some stakeholders (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors 
such  as  consultants  and  civil  society).  The  option  of  one-stop-shop  was  considered  during  negotiations  of  the  administrative  agreement  between  the 
European Commission and EIB but was not found feasible (actors within EU institutions, EIB).  

The use of financing not linked to costs and pre-financing of project costs has lightened the administrative workload for the European Commission/CINEA 
and was appreciated by the beneficiaries of the PSLF (actors within EU institutions, beneficiaries and applicants). Another element which was highlighted 
is that CINEA is using fewer human resources than initially expected due to limited implementation (actors within EU institutions). 

Some applicants submitted project proposals with low quality which resulted in the need to revise and resubmit their proposals which have also affected 
the efficiency of the implementation (actors within EU institutions, EIB). The need for clear guidance and dedicated support to fill in the application form 
was highlighted in this regard (actors within EU institutions, EIB, beneficiaries and applicants, other third-party actors such as consultants and civil society). 

The time required to complete applications was highlighted, particularly in relation to the expiry of national shares by the end of 2025 after which grants 
will be awarded on a 'first come first served' basis (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other 
third-party actors such as consultants and civil society). This could result in a competitive atmosphere for applicants where only a limited number of projects 

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can secure funding (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-party actors such as 
consultants and civil society). 

Beneficiaries in Greece and France already anticipate a positive assessment of the monitoring and reporting requirements of the PSLF due to the FNLC 
conditions  which do not require them to  report  on the related project  costs (actors  within  EU institutions,  beneficiaries  and applicants).  However, the 
separate reporting and monitoring for the EIB loan component and the European Commission  grant component are anticipated to be less efficient by the 
same beneficiaries (beneficiaries and applicants). 

The role of the EIB advisory services and other type of technical assistance deployed has been highlighted in improving the knowledge about the grant 
application process and thus improving the quality of the project proposals basis (actors within EU institutions, EIB, national, regional and local actors, 
beneficiaries and applicants, other third-party actors such as consultants and civil society). Prior experience with other EU funding instruments has been 
identified as another factor which has helped beneficiaries progressing with their project proposals (actors within EU institutions). 

Coherence 

The provided feedback reveals a complex landscape of overlaps, synergies and challenges. PSLF objectives are to some extent similar and overlapping 
with the JTF, CF, ERDF and RRF. Therefore, projects may struggle to determine the most suitable funding source (actors within EU institutions, EIB, 
national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and civil society).  

Interviews also suggest that PSLF competes with other EU funding resources that  provide more favourable conditions. Among others, the higher coverage 
of EU grants, greater familiarity with application procedures, etc. were highlighted (actors within EU institutions, EIB, national, regional and local actors, 
beneficiaries and applicants, other third-party actors such as consultants and civil society). Some stakeholders reported that some managing authorities find 
JTF easier to access and administer than PSLF, resulting in a preference for the former (other third-party actors such as consultants and civil society).  

Interviews highlighted that while some Member States have a more flexible approach towards the eligible areas of support for PSLF in their TJTPs, others 
have been more precise in identifying the sectors eligible for funding under PSLF, such as the Netherlands, ensuring complementarity between the three 
JTM Pillars (actors within EU institutions, national, regional and local actors, beneficiaries and applicants, other third-party actors such as consultants and 
civil society). 

Stakeholders also pointed out the challenge that PSLF cannot be combined with other sources of funding (actors within EU institutions, EIB, national, 
regional and local actors, beneficiaries and applicants). The involvement of consultants  for advisory and technical assistance services has helped potential 

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applicants to prepare applications for PSLF (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, other third-
party actors such as consultants and civil society). In practice, different forms of advisory support have joined forces through joint events and training to 
coordinate and enhance the support provided for the PSLF (beneficiaries and applicants, other third-party actors such as consultants and civil society).  

EU added value 

Institutional actors recognise significant advantages of providing support through an EU-level blending instrument like PSLF (actors within EU institutions, 
EIB). This includes more resources for just transition territories that might otherwise lack access to adequate funding (actors within EU institutions, EIB). 
The EU's role helps to address investment gaps in specific areas, particularly for projects related to just transition (actors within EU institutions, EIB). PSLF 
is noted for its flexibility and place-based approach, enabling a targeted response to the unique needs of territories most affected by transition, particularly 
decarbonisation and climate adaptation (actors within EU institutions, EIB). This is highlighted as a key advantage over national or regional solutions, 
which may not always adequately consider the local context (actors within EU institutions, EIB).  

The evaluation of project proposals by institutional actors raises the standard of projects due to the rigorous requirements for applying (actors within EU 
institutions, EIB). The grant enhances attractiveness compared to national funding options, which may lack similar incentives (actors within EU institutions, 
EIB, beneficiaries and applicants). There is  recognition of the complexity introduced by the blending mechanism itself and by having multiple, partly 
overlapping funding sources and instruments at EU level (actors within EU institutions, EIB, national, regional and local actors, beneficiaries and applicants, 
other third-party actors such as consultants and civil society).  

Beneficiaries, applicants and Member State authorities recognise the PSLF added value and indicate that it complements other EU, national and regional 
sources, filling gaps where those may not be applicable or attractive (national, regional and local actors, beneficiaries and applicants). In addition, some 
respondents hope that projects funded through PSLF could be models for other regions, showcasing the use of blended finance and inspiring additional 
local and regional projects (actors within EU institutions, EIB, other third-party actors such as consultants and civil society). Experience from navigating 
the PSLF process is considered valuable for institutions with limited knowledge of blended finance models. This is expected to contribute to capacity 
building and a more comprehensive understanding of how to manage complex financial instruments (actors within EU institutions, EIB, beneficiaries and 
applicants, other third-party actors such as consultants and civil society). 

Interviews acknowledge the PSLF’s EU added value to channel resources to the just transition regions (actors within EU institutions, EIB, beneficiaries 
and applicants, other third-party actors such as consultants and civil society). They welcome the emphasis on small public authorities, municipalities instead 
of regional centres, which are prevalent in just transition territories. PSLF can drive local engagement and ensure a wider range of stakeholders can access 

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funding, enhancing the local impact of EU investments (actors within EU institutions, EIB, beneficiaries and applicants, other third-party actors such as 
consultants and civil society). 

PSLF events 

Two PSLF dedicated events, i.e. ‘Translating just transition from plans into investments: combining grants, financing and advisory’ and ‘Third Pillar of 
the Just Transition Mechanism – All You Want to Know’ took place on 8 October 2024 and 16 October 2024 respectively and delivered additional feedback 
about the functioning of the PSLF.  

The speakers highlighted the importance of thorough project preparation. In addition, effective good collaboration with different entities involved was also 
mentioned as a crucial factor, alongside a long-term planning to ensure the economic and financial sustainability of investments. PSLF added value has 
been confirmed and lies in supporting economic diversification of the regions. In addition, the session also underscored the role of advisory services for 
improving understanding about the application process and raising awareness about the PSLF. In addition, the added value of the PSLF for funding all 
these projects have been highlighted. Also, a good preparation of the project with the help of PSLF advisory services or other available technical assistance 
has been stressed.   

Overview of the case study findings 

PSLF case study Czechia 

The review of the sectors covered by the TJTP ensures a wide eligibility of potential projects under the Facility. The broad range of areas of intervention 
covered in the Czech TJTPs appears to be in line with just transition needs in Czechia. However, regional and local authorities may have difficulties to 
access the PSLF mainly depending on their fiscal (debt) situation.  

The feedback about funding opportunities under the PSLF varied among the CZ project promoters, with some more interested than others. The grant can 
help  smaller  authorities  become more  familiar  with blended financial instruments  such  as the PSLF. Other programmes  with  higher  funding rates are 
however considered more attractive.  

Czechia has the most PSLF submitted projects to date. This uptake has been facilitated by EIB intermediate lending. Stakeholders from Czechia informed 
that additional projects are in the pipeline with the perspective of absorbing the entire national grant allocation by end 2025. The projects are expected to 
address social, economic and environmental challenges deriving from the transition.  

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Czechia has requested advisory support from the EIB via the InvestEU advisory Hub available under the PSLF as well as from other consultants via other 
EU funded technical assistance (at the request of Czech Ministry of Environment) which has been helpful for the uptake of PSLF. In particular, guidance 
in the national language which was developed to inform and guide potential beneficiaries about PSLF has been effective. The latter is one of factors which 
explain the PSLF uptake in Czechia.  

The communication efforts undertaken in Czechia are considered to be effective. Evidence shows that all stakeholders from Czechia feel informed about 
PSLF.  All  Czech  stakeholders  indicated  the  European  Commission,  CINEA  and  the  EIB  as  their  main  sources  of  information,  and  others  referred  to 
communication under the technical assistance financed by the Commission. 

Municipalities in the three TJTP regions seem to have different perceptions of their role in the green transition which might have influenced their PSLF 
uptake. For instance, in Karlovy Vary region stakeholders seem less engaged in the transition, whereas in the Usti region municipalities emphasised stronger 
involvement. In Moravia-Silesia, municipalities viewed the transition as focused on larger industries, with their role being limited. 

Czech stakeholders seem to have a good understanding of the application process of the PSLF.  

Respondents from Czechia believe there are stronger synergies of PSLF with cohesion policy funds and RRF. Synergies are less with the InvestEU ‘Just 
Transition’ scheme, CEF and LIFE. Submitted projects from Czechia seem to complement support from JTF. 

It was stressed that national and regional sources do not support large-scale investments as much as PSLF, indicating that PSLF closes a funding gap in 
Czechia. 

PSLF case study France 

The six French TJTPs have approached the areas of intervention for PSLF differently. The areas of intervention covered by the French TJTP for PSLF 
seem in line with the objectives and ambitions of the regions. The PSLF seems highly relevant in France for green and sustainable mobility and transport. 

As shown by implementation, there is a high interest in France for PSLF. One factor explaining this high uptake could be the high interest rates in general 
in France making the EIB loans attractive. Another element is that PSLF financing enables local authorities to support large investments in sectors such as 
transport  that  are  expected  to  have  a  long-term  impact  for  the  just  transition  in  France.  Potential  beneficiaries  seem  to  be  able  to  access  debt-based 
instruments without any significant barriers. The factors highlighted the most which could explain the high uptake of PSLF in France relate to administrative 
capacity in the authorities and their experience of applying for other EU or national funding resources. Moreover, France had a project pipeline ready for 
PSLF. 

112 

 
Most awareness raising initiatives about PSLF were local, promoted by the Commission and coordinated by the country. French beneficiaries underline the 
streamlined information and awareness raising by regional authorities. In addition, communication and regular exchanges with the EIB, Commission and 
CINEA during the application process were also positive. Communication and awareness raising also contributed to PSLF high uptake in France. 

French beneficiaries initially faced challenges with unclear monitoring and reporting requirements, but since PSLF projects have started, the processes have 
become  more  transparent.  They  also  consider  the  application  process  to  be  complex,  but  well  understood.  Complexity  is  mostly  due  to  the  separate 
application procedures for the loan and grant components which makes PSLF less efficient. Collaboration between several city departments was crucial to 
the successful grant application. 

PSLF seems to be coherent with other EU and national funding instruments. The French partnership agreement under EU cohesion funds excludes renewed 
rolling stock which made PSLF a coherent instrument to fill this gap. The project in Nantes seems also coherent with CEF and Horizon Europe programme. 

In France, PSLF has added value with high uptake, which is also due to a lack of alternative funding resources to support investments in rolling stock. 

PSLF case study Greece  

The scope for PSLF in Greek TJTPs is broad and allows for a wide variety of projects. The higher grant rate of PSLF of 25% applied to almost all Greek 
TJTPs provides an additional incentive for potential beneficiaries to apply for PSLF.  

Greek potential beneficiaries seem to face challenges when using debt-based instruments such as PSLF. This is mainly due to their existing debt which 
makes it difficult to obtain additional loans. In addition, the central ministry must approve projects before applying for EU funding instruments like PSLF. 
While this coordination requirement can add an additional layer of administrative complexity, it can also bring some benefits such as reinforced support 
and exchanges of information ensuring coordinated projects.  

There is interest in framework loan projects under PSLF in Greece, but this requires considerable coordination among multiple potential beneficiaries and 
sometimes projects with different level of maturity under one framework loan. It seems these obstacles are preventing and delaying potential beneficiaries 
in Greece from applying.  

PSLF uptake in Greece is limited but encouraging. Some factors that explain PSLF uptake in Greece relate to limited administrative capacity in the regions. 
In addition, as explained above, applying for an EU funding instrument requires coordination and approval from the central authorities, which also affects 
uptake of the Facility. However, with the first awarded project under PSLF, the EIB and the central authorities have built a partnership which is expected 

113 

 
to facilitate further uptake in Greece. More projects from Greece should be submitted by the next PSLF planned cut off dates. These projects are being 
prepared with JTP Groundwork support. 

The application for the grant component was perceived as efficient and accessible by the Greek interviewees. Despite the possibility of applying in Greek, 
they decided to submit it in English which might have influenced the quality of the application. The advisory support could answer questions regarding the 
application which helped them. Even though the project is still in an early implementation phase, monitoring and reporting related to the grant component 
are perceived as efficient by the beneficiary. This is especially due to the FNLC condition as actual costs of the project do not need to be reported.  Another 
measure which makes  the PSLF work efficiently is  the 70% grant  pre-financing   in  the first  year of the  project.  Therefore,  monitoring and reporting 
requirements under PSLF are perceived as relatively simple compared to other EU funding instruments. 

Greek  stakeholder  consultations  suggest  that  RRF  and  PSLF  are  coherent.  While  RRF  is  managed  centrally,  PSLF  is  a  funding  opportunity  for  local 
beneficiaries. Also, Greek national funds seem to be coherent with PSLF as they generally finance smaller projects, while PSLF can support considerably 
larger projects. For projects with similar objectives, JTF is generally preferred since it has a higher grant intensity. However, JTF in Greece has narrower 
areas of implementation compared to the TJTP, suggesting opportunities for synergy between JTF and PSLF. 

Coordination between the different types of technical assistance support being deployed in Greece is key to avoid duplicated efforts. 

The added value of PSLF for Greece is confirmed since it can support larger projects addressing just transition needs compared to national support. There 
is no substitute for PSLF at the local and regional level. The Greek beneficiary stressed that projects in the Western Macedonia region could not materialise 
without additional PSLF resources.  

PSLF case study Poland  

PSLF uptake has been limited in Poland, with only one Polish project selected for funding but withdrawn. There are several reasons which might explain 
the limited uptake in Poland. One aspect is the lack of awareness of the PSLF and its functioning, but also the limited capacity of regions to deal with 
different EU funds being implemented in the same period. National and local Polish authorities stressed that they are focused on implementing RRF and 
cohesion policy funds including JTF. The latter have higher grant rates and tighter deadlines. Another factor is that PSLF projects cannot receive support 
from other EU programmes, preventing PSLF from being combined complementing other EU funding sources.  

114 

 
 
In addition, although borrowing has increased over recent years in Poland72, it seems local authorities have little interest in taking up loans and using blended 
instruments  such as PSLF. Some already have significant  debts  preventing them from  taking  up additional loans. Moreover, there is  no possibility of 
integrating smaller intermediated projects (as in Czechia) as the conditions for a financial intermediary in Poland are not yet in place. There also seems to 
be little interest from commercial banks to finance potential beneficiaries in the just transition regions. Additional barriers and costs related to the local 
currency  might  also  contribute  to  less incentive  for  smaller  municipalities  to  take  up  loans.  The  possibility  of  framework  loans  under  PSLF  has  been 
investigated but it was not deemed suitable. 

The timing of PSLF implementation is less coherent with the implementation of other EU funding  sources such as JTF and RRF in Poland. The strict 
deadlines for RRF with the need to start the cohesion policy programming period and higher grant rates diverted attention from PSLF for local and regional 
actors. 

There are mixed opinions on the EU added value of PSLF in Poland. Some Polish stakeholders argue that PSLF seems challenging to access and not well-
suited for financially constrained smaller public entities in Poland. 

PSLF case study Romania 

The TJTP review confirms the areas of intervention are in line with transition needs which are also in line with the plans for green transition in Romania. 
All Romanian TJTP regions are less developed and therefore can receive a grant of 25% of the loan amount under the PSLF generating some interests, but 
without tangible results yet. 

There are no PSLF proposals submitted or awarded yet in Romania. Some factors could explain the limited uptake of PSLF there. Existing transition needs 
do not always translate in a strategic approach  and therefore often do not lead to concrete projects. Potential public beneficiaries tend to plan projects 
according to available funds, rather than creating a pipeline of projects ready for financing. Moreover, RRF and cohesion policy are more attractive than 
PSLF and thus prioritised. Other issues such as existing debt also affect beneficiaries’ ability to take up additional loans and therefore their ability to use 
PSLF. For sectors such as transport and energy, public services are performed by state-owned companies which are already heavily indebted. Other factors 
that can influence the uptake of PSLF in Romania are the limited administrative capacity of the less developed regions involved and their need to deal with 
multiple projects funded by other EU or other national resources. 

72 For instance, the EIB committed over EUR 100 million of framework loans to local authorities in the TJTP eligible territories over 2022-2024. 

115 

 
 
 
 
 
 
 
 
There is a high awareness of PSLF in Romania thanks to multiple awareness raising and communication efforts. The role and efforts undertaken by the 
Ministry of Finance which is facilitating PSLF implementation are complementary and useful to increase uptake in Romania. 

Romania is receiving advisory support under the InvestEU Advisory Hub; however, the 2 assignments have just recently started. It is also promising that 
the advisory assignment is helping to identify eligible intermediated projects. 

Romanian stakeholders highlighted that the application process is considered more complicated than a simple grant, because PSLF requires a separate 
application process for the grant and the loan. 

A significant challenge to identifying demand for PSLF is that it must compete with the substantial grant financing available for infrastructure investments 
under EU Cohesion Policy funds and the RRF. In terms of complementarity with JTM pillars, it appears that JTF has also been prioritised over PSLF due 
to its higher funding rates. Projects initially directed towards JTF financing could benefit from Pillar III, though the two pillars cannot be combined. 

Romanian stakeholders highlighted that the just transition needs are significant, making an additional source of funding like PSLF potentially beneficial 
for Romania. PSLF could be an opportunity to decentralise the just transition allowing local authorities to be directly involved in this process.  

Cross-country analysis 

PSLF demonstrates coherence with EU and national funding in Czechia, France, and Greece by complementing other funding sources and addressing gaps. 
In Czechia, it serves as an additional funding source for smaller projects, leveraging national programmes. However, in Poland and Romania, other EU 
funds are preferred due to higher funding rates and shorter implementation timelines. 

The uptake of Public Sector Loan Facility (PSLF) in countries like Czechia, Greece, Poland, and Romania is influenced by several factors: 

1.  Limited borrowing capacity: smaller public entities often face challenges in borrowing and using debt-based instruments like PSLF.  
2.  National  requirements,  for  example,  in  Greece,  the  central  ministry's  project  approval  requirement  adds  complexity  but  offers  benefits  like 

coordinated projects and information sharing. 

3.  Project size: the larger size of PSLF projects have been highlighted as a barrier. Framework loans, which bundle smaller projects, have been effective 

in Greece but face coordination challenges elsewhere. In Czechia, intermediate lending facilitated PSLF smaller projects.  

4.  Perceptions about the green transition: varied regional perceptions of their roles in the green transition impact engagement with PSLF. 

116 

 
 
 
 
 
 
 
5.  Advisory and Technical Assistance: Support initiatives have helped potential beneficiaries understand PSLF and identify projects, boosting uptake 

in countries like Czechia and Greece. 

6.  Administrative Capacity: High administrative capacity and familiarity with EU funding in France support PSLF uptake.  Limited administrative 

capacity in Romania and Poland hampers PSLF uptake 

Overall, the mix of the PSLF awareness raising and communication activities seem useful suggesting that further awareness-raising and communication 
efforts could help increase PSLF uptake. Coordination between different advisory support provided under PSLF is key to avoid duplications and ensure 
coherence. 

117 

 
 
 
ANNEX VI. SUPPORTING STUDY  

See separate annex.  

118 

 
 
 
ANNEX VII. LIST OF PSLF SELECTED PROJECTS (INCLUDING BOTH AWARDED AND UNDERGOING EIB DUE DILIGENCE) AND ADVISORY ASSIGNMENTS 

Table 5: List of PSLF selected projects (including both awarded and undergoing EIB due diligence) 
Budget 

Description of the project 

Region/ 

Sector 

Status 

Submission 
deadline 

Type of loan 

Estimated 
CO2 
reduction 

Estimated 
Job 
creation 

Estimated 
Persons 
reached 

Territory 

CZ 

20 
September 
2023 

Moravian-
Silesian  

Title  of  the  project:  Ostrava  Concert 
Hall. 

is 

to 

the  project 

The  subject  of 
the 
construction of the Ostrava Concert Hall 
with world-class acoustics and a capacity 
of  up  to  1300  seats.  This  project  will 
the  development  of  cultural 
support 
infrastructure  and  contribute 
the 
revitalisation of Ostrava, a former mining 
city  which  still  maintains  the  traditional 
production of steel. The establishment of 
a  new  cultural  venue  will  strengthen  the 
city’s attractiveness to both its inhabitants 
and  visitors.  It  will  support  the  region’s 
the  socio-
broader  plans  aiming  at 
economic transformation of the region. 
Title  of  the  project:  Modernisation  of 
selected parts of railway infrastructure in 
the Ústí nad Labem Region. 

The  project,  aims  to  reconstruct  the 
following  three  railway  infrastructure 
sections:  
•  A 

in  Litoměřice, 
including  construction  of  noise 

railway 

line 

CZ 

April 

17 
2024 

nad 

Usti 
Labem 

urban 
infrastructure, 
urban renewal 
and 
regeneration, 
energy 
efficiency 

(tonnes 
per year)  

N/A 

32 

151 200 

Grant 
agreement 
signed 

Total  costs: 
EUR 
115.5 
mln (100%) 

Standalone 
project 
(investment 
loan) 

EIB 
loan: 
EUR  84  mln 
(73%) 

PSLF  grant: 
EUR  21  mln  
(18%) 

Own 
financing:  
EUR 
mln (9%) 

10.5 

sustainable 
mobility 

Grant 
agreement 
signed 

Total  costs: 
EUR 
12.4 
mln (100%) 

Standalone 
project 
(Investment 
loan) 

N/A 

0 

165 860 

EIB 
loan: 
EUR 9.4 mln 
(76%) 

119 

 
 
 
 
 
 
 
 
 
 
and 
barriers 
Libochovany; 

a 

fly-over 

in 

•  A railway bridge in Usti nad Labem; 
•  A railway bridge in Teplice.  

The  project  will  help  ensure 
the 
operability  of  crucial  railway  lines  for 
daily  commuting  in  the  Usti  nad  Labem 
region.  It  will  enhance  the  quality  and 
safety  of  both  passenger  and  freight 
railway  transport  while  reducing  noise 
pollution  caused by  railway  transport by 
4-6 decibels. 
Title  of  the  project:  Sustainable  and 
Affordable  Housing  for  the  New  Green 
Industry and Society (SHERIS). 

SE 

April 

19 
2023 

Väster-
botten 

PSLF  grant: 
EUR  1.6  mln 
(13%) 

Own 
financing:  
EUR  1.4  mln 
(11%) 

housing, 
energy 
efficiency  

Grant 
agreement 
signed 

Total  costs: 
EUR 
141.8 
mln (100%) 

Framework 
loan 
scheme) 

(loan 

N/A  

1000 

44 000 

by 

the 

need 

supporting 

The  project  will  address  the  growing 
Skelleftea 
housing 
of 
municipality 
the 
construction of 7 housing complexes with 
around  750  energy-efficient  affordable 
housing  units.  The  housing  programme 
will  mainly  target  the  incoming  workers 
of the new battery gigafactory Northvolt 
as  well  as  students,  refugees  and  people 
with low income or special needs. 

FR 

20 
September 
2023 

Pays  de  la 
Loire  

Title  of  the  project:  The  Sustainable 
for  Low 
Infrastructures 
Mobility 
Emissions 
qualitative  Service 
and 
(SMILES). 

sustainable 
mobility 

Grant 
agreement 
signed 

The  project  consists  of 
sustainable 
Nantes by:  

transport 

improving 
in 

infrastructure 

120 

loan: 
EIB 
EUR  71  mln 
(50%) 

PSLF  grant: 
EUR 
10.6 
mln  (7%) 

60,2 

Own 
financing:  
EUR 
mln (43%) 
Total  costs: 
EUR 405 mln 
(100%)  

EIB 
loan: 
EUR 200 mln 
(50%)  

21 000  

106 

1 672 420 

Standalone 
project 
(investment 
loan) 

 
 
 
 
 
 
 
 
 
 
•  Upgrading  and  renovating  3  tram 

lines.  

•  Renewing  the  tram  fleet  (46  new 

vehicles).  
•  Constructing 

a 

and 
operational  centre  and  multimodal 
relay/exchange hub.  

technical 

•  Developing 38 km of cycling paths.  

develop 

The results of the project will improve the 
performance  and  quality  of  the  tram 
network, 
inter-modality, 
diversify  the  public  transportation  offer 
and reduce road congestion. 
Title  of  the  project:  MEL  in  GREEN 
Mobility (Greenmo). 

FR 

April 

19 
2023 

Hauts 
France  

de 

the 

through 

tram  network 

The project will target various parts of the 
Lille  Metropolitan  area  public  transport 
infrastructure. It covers the modernisation 
of 
the 
replacement of 30 trams, the roll out of 42 
hydrogen-powered 
the 
improvement  of  platforms,  depots  and 
other  related  transport  facilities.  It  will 
also  support  the  development  of  an 
related 
ambitious  cycling  plan  and 
infrastructure 
improve  safety  for 
to 
cyclists. 

buses 

and 

PSLF  grant: 
EUR  30  mln 
(7%)  

Own 
financing: 
EUR 175 mln 
(43%) 

sustainable 
mobility 

Grant 
agreement 
signed 

Total  costs: 
EUR    420,5 
mln (100%)  

Standalone 
project 
(investment 
loan) 

90 155  

4 332 

1 182 250 

EIB 
loan: 
EUR 210 mln 
(50%)  

PSLF  grant: 
EUR 31.5mln 
(7%)  

179  

Own 
financing: 
EUR 
(43%) 
Total  costs: 
EUR 320 mln 
(100%)  

16 000 

75 

84800 

Standalone 
project 
(investment 
loan) 

FR 

April 

19 
2023 

Provence-
Alpes-
Côte 
d'Azur 

Title of the project: Marseille Tramway 
Extension project (ETNS1). 

sustainable 
mobility 

Grant 
agreement 
signed 

The project aims to:   
•  Extend the North-South tramway line 

of Marseille by 6.2 km. 

121 

 
 
 
 
 
 
 
 
 
EL 

April 

19 
2023 

Western 
Macedonia  

•  Construct  storage,  maintenance,  and 
technical buildings for rolling stock. 

•  Carry  out  landscape  works  around 
the  new 
infrastructure  and 

the 
tramway stations. 

The project will improve the performance 
and  the  quality  of  the  tram  network  in 
Marseille,  strengthen  the  quality  and 
diversity  of  the  public  transport  services 
in  the  area,  offering  an  alternative  to 
private  cars,  encouraging  soft  mobility 
and behavioural changes for the local and 
regional 
a  more 
sustainable urban mobility. 
Title  of  the  project:  Socioeconomic 
Transition of Western Macedonia. 

towards 

citizens 

The project brings together 15 projects in 
(Argos  Orestikou, 
six  municipalities 
Kozani,  Kastoria,  Florina,  Eordaia  and 
Grevena), related to:  
• 
8 – energy efficiency  
• 
1 – road infrastructure  
• 
2 – health care  
• 
1 – culture  
•  1 – tourism 

loan: 
EIB 
EUR 100 mln 
(31%)  

PSLF  grant: 
EUR  15mln 
(5%)  

Own 
financing: 
EUR 205 mln 
(64%) 

Grant 
agreement 
signed 

Total  costs: 
EUR 
80.5 
mln (100%) 

Framework 
loan 
scheme) 

(loan 

8 650 

200 

150 000 

loan: 
EIB 
EUR  58  mln 
(72%) 

PSLF  grant: 
14,5 
EUR 
mln (18%)  

Own 
financing: 
EUR  8  mln 
(10%) 

energy 
efficiency, 
renewable 
energy, public 
utilities, 
social 
infrastructure, 
health, 
transport,  
road 

122 

 
 
 
 
 
 
 
 
  
 
Total for awarded projects 

NL  19 

April 

2023 

Zuid- 
Limburg 

Title of the project: Mijnwater scale up 
Masterplan phase 1. 

The project will support the Dutch green 
supplier  Mijnwater 
energy 
the 
development  of 
innovative  5th-
its 
generation heating and cooling grid in the 
Zuid-Limburg area. 

in 

sustainable 
district 
heating 
cooling 

and 

Grant 
agreement 
in 
preparation 

135 805 

5 745 

3 456 275 

**Not available yet 

Standalone 
project 
(investment 
loan) 

Total  costs: 
EUR  1  495.7 
mln (100%) 

EIB 
loan: 
EUR 732 mln 
(49%) 

PSLF  grant: 
124.2 
EUR 
mln (8%)  

Own 
financing: 
EUR 
mln (42%) 

639.1 

loan 

EIB 
requested: 
EUR 90 mln   

PSLF  grant 
requested: 
EUR 
mln  

13.5 

CZ 

April 

17 
2024 

Moravia-
Silesia 

Title of the project: Student dormitory - 
University  of  Ostrava  -  increasing  the 
quality  and  expanding  capacity  of 
affordable student housing. 

education, 
social 
infrastructure 

Grant 
agreement 
in 
preparation 

loan 

EIB 
requested: 
EUR 12 mln 

Intermediated 
lending  

123 

 
 
  
 
 
 
 
 
 
 
 
 
CZ 

April 

17 
2024 

nad 

Usti 
Labem 

CZ 

April 

17 
2024 

nad 

Usti 
Labem 

The  project  will  expand  the  student 
housing  by  building  an  additional 
dormitory  with  332  beds,  including  6 
places for people with special needs and 8 
apartments for families with children. 
Title  of  the  project:  “Peace  Square 
Postoloprty.” 

The project will improve infrastructure in 
the historical town centre. Reconstruction 
of roads, pavements and upgrade of street 
lighting. 
Title  of  the  project:  Renovation  of  the 
historical part of Podmokly - stage D. 

The  project  will  revitalise  the  historical 
part  of  the  Podmokly  neighbourhood. 
Landscaping  including  the  adaptation  of 
terrain, 
spaces, 
creation  of  green 
extension  and  upgrade  of  pavements, 
creation of cycle paths and parking areas, 
creation of new recreational areas such as 
sports  grounds 
and  multifunctional 
spaces,  upgrade  of  street  lighting,  re-
organisation  and  re-furnishment  of  a 
commercial street. 

CZ 

17 
2024 

April 

Usti, Děčín  Title of the project:  EPC Děčín. 

The  project  will  contribute  to  energy 
Performance Contracting (EPC) measures  
on  16  public  buildings  (schools,  cultural 
and 
-  Areas  of 
intervention: Heating, lighting and water 
management. 

facilities) 

sport 

PSLF  grant 
requested: 
EUR 3 mln 

loan 

EIB 
requested: 
EUR 2.2 mln 

PSLF  grant 
requested:  
EUR 0.5 mln 
loan 
EIB 
requested: 
EUR 2.3 mln 

PSLF  grant 
requested: 
EUR 
mln  

0.58 

Intermediated 
lending 

Intermediated 
lending 

sustainable 
tourism, 
urban 
regeneration 

Grant 
agreement 
in 
preparation 

Grant 
agreement 
in 
preparation 

urban 
regeneration, 
sustainable 
mobility, 
sustainable 
tourism 

energy 
efficiency, 
sustainable 
water 
management 

Grant 
agreement 
in 
preparation 

Intermediated 
lending 

loan 

EIB 
requested: 
EUR 1.5 mln  

PSLF  grant 
requested: 
EUR 
mln 

0.39 

124 

 
 
 
 
 
 
 
 
 
CZ 

17  January 
2024 

Usti 
Labem 

nad 

Title  of  the  project:  Usti  nad  Labem 
Public Transportation. 

ones; 

The  project  will  a)  purchase  of  around 
6000 LED street light lamps to replace the 
outdated 
b) 
sodium-vapour 
Construct an energy-efficient building for 
to 
trolleybus  drivers 
an 
administrative  building, 
including  a 
the  employees’ 
facility 
daycare 
children. 
Title  of  the  project:  Reconstruction  of 
selected  passenger  buildings 
the 
Karlovy Vary Region. 

adjacent 

for 

in 

CZ 

19 
September 
2024 

Karlovy 
Vary 

The  project  will  reconstruct  three  train 
stations  in  the  towns  of  Bečov  nad 
Teplou, Františkovy Lázně and Cheb.   

CZ 

19 
September 
2024 

Moravia-
Silesia 

Title  of  the  project:  Reconstruction  of 
selected  passenger  buildings 
the 
Moravian-Silesian Region. 

in 

The  project  will  reconstruct  two  train 
stations in the towns of Ostrava-Vítkovice 
and Kopřivnice. 

CZ 

19 
September  
2024 

nad 

Usti 
Labem  

Title  of  the  project:  Reconstruction  of 
selected  passenger  buildings  in  the  Usti 
nad Labem Region. 

The  project  will  reconstruct  passengers’ 
buildings  in  3  train  stations  (Lovosice, 
Bohemia, Roudnice nad Labem). 

sustainable 
mobility, 
energy 
efficiency 

Grant 
agreement 
in 
preparation 

Intermediated 
lending 

loan 

EIB 
requested: 
EUR 1.7 mln 

PSLF  grant 
requested: 
EUR 
mln 

0.43 

Standalone 
project 
(investment 
loan) 

Standalone 
project 
(investment 
loan) 

Standalone 
project 
(investment 
loan) 

EIB 
requested: 
EUR 
mln 

loan 

39.5 

PSLF  grant 
requested: 
EUR 9.8 mln 
EIB 
loan 
requested: 
EUR 
mln 

14.2 

PSLF  grant 
requested: 
EUR 3.5 mln 
EIB 
loan 
requested: 
EUR 38 mln 

PSLF  grant 
requested: 
9.5 mln 

Grant 
agreement 
in 
preparation 

Grant 
agreement 
in 
preparation 

Grant 
agreement 
in 
preparation 

sustainable 
mobility, 
urban 
infrastructure, 
renovation 
and 
conversion  of 
buildings 
sustainable 
mobility, 
urban 
infrastructure, 
renovation 
and 
conversion  of 
buildings 
sustainable 
mobility, 
urban 
infrastructure, 
renovation 
and 
conversion  of 
buildings 

125 

 
 
 
 
 
 
 
 
 
 
ES 

19 
September 
2024 

Galicia 

Title  of 
CHUAC 
Universitario A Coruña). 

the  project:  PROYECTO 
Hospitalario 

(Centro 

public 

The  project  will  expand  and  modernise 
the 
Hospitalario 
Centro 
Universitario  A  Coruña  (new  CHUAC 
hospital)  by  constructing  new  buildings 
and 
existing  buildings 
energy 
according 
efficiency standards, and by modernising 
its medical facilities and equipment. 

contemporary 

refurbishing 

to 

Total for selected projects still undergoing EIB due diligence 

Social 
infrastructure, 
health 

Grant 
agreement 
in 
preparation 

Standalone 
project 
(investment 
loan) 

loan 

EIB 
requested: 
EUR 450 mln 

PSLF  grant 
requested: 
59.3 mln 

loan: 
651.4 

EIB 
EUR 
mln  

PSLF  grant: 
EUR 
100.5 
mln  

Source: European Commission 

Table 6: List of PSLF advisory assignment under the Invest Advisory Hub  

Assignment name   Final 

beneficiary 

EU 
Member 
State 

Type 
support 

of 

Sector 
assignment 

of 

Start date 

Status 

to 

Support 
the 
implementation  of 
decarbonisation  of 
electricity 
the 

public 
authorities 

EL 

capacity 
Building 

energy, mobility  

02 July 2024 

in progress 

126 

 
 
 
  
 
 
in 

Just 
supply 
Transition  insular 
regions in Greece. 

PSLF - Supporting 
transition 
energy 
transport 
in 
the 
in 
infrastructure 
de 
Campo 
Gibraltar. 

PSLF  support  for 
A 
Coruna 
Hospital, Spain. 

Transition  of  the 
East 
Maritsa 
Complex. 

Electrica  Group 
Financial Model. 

PSLF  support  to 
Usti  nad  Labem, 
Czechia. 

Public Sector Loan 
Facility 
JTM 
Romania. 

public 
authorities 

ES 

project 
advisory 

energy, 

environment, 

mobility 

in progress 

11 
September 
2024 

public 
authorities 

ES 

project 
advisory 

social 
investments 

08  August 
2024 

public 
authorities 

BG 

project 
advisory 

Environment 

13  February 
2024 

completed, 
30 
November 
2024 

in progress 

corporates 

RO 

public 
authorities 

CZ 

capacity 
Building  

capacity 
building  

public 
authorities 

RO 

Market 
development  

Energy 

May 

in progress 

22 
2024 

in  progress 

24 
November 
2024 

26 July 2023 

in progress 

energy; 
mobility; 
social 
investments 

cultural,  creative 
and 
sectors 
media; 
digital 
connectivity 
infrastructure; 
energy; 
environment; 

127 

 
 
 
site 

industrial 
rehabilitation; 
mobility; 
research, 
development  and 
innovation; social 
investments; 
tourism. 

Source: European Commission. 

128 

 
 
 
ANNEX VIII. PSLF MONITORING AND REPORTING FRAMEWORK 

Reporting and monitoring of advisory assignments 

Advisory funded under the PSLF is implemented by the EIB in the framework of the InvestEU Advisory Hub. As such, advisory assignments are launched, 
managed and monitored in line with the InvestEU Advisory Hub’s rules and procedures.  

All  proposed  assignments  with  an  estimated  cost  of  above  EUR  500,000  must  be  submitted  by  the  EIB  to  the  Commission  for  prior  approval.  The 
information  package includes  the advisory request,  beneficiary identification, estimated delivery cost,  implementation  period and eligibility within the 
PSLF. 

The EIB delivers an annual technical report on its implementation of advisory in the InvestEU Advisory Hub framework, including the PSLF. In addition, 
it delivers semi-annual reports focused on data and KPIs. The following KPIs are monitored for the PSLF advisory assignments: 

-  Number of advisory assignments. 
-  Start/end date of the advisory assignments. 
-  Type of final beneficiary. 
-  Member State of assignment. 
-  Type of support. 
-  Sector of assignment. 
-  Budget of the assignment.  
-  Expected mobilised investments as a result of the received advisory support for projects supported. 
-  Project maturity and progress to financing/ investment stage. 
-  Follow-up on investment/ financing status of completed advisory assignments. 
-  Estimated contribution to the greenhouse gas reduction of the projects receiving advisory support, where relevant. 
-  Estimated reduced energy consumption and/or energy produced from renewable energy sources (RES) for projects that received advisory support, 

where relevant.  

-  Estimated contribution to the NOx emission reduction, modal shift and saved time for projects that received advisory support, where relevant. 
-  Number of capacity building activities by type.  
-  Participants’ satisfaction in capacity building activities. 
-  Number of final beneficiaries, people trained and training days delivered by type of final beneficiary. 

129 

 
-  Number of awareness raising events by location and number of participants registered and attending. 
-  Participants’ satisfaction in awareness-raising events. 

Finally,  the  EIB  updates  monthly  the  InvestEU  Advisory  Hub  Management  Information  System  (MIS),  which  is  a  databased  on  ongoing  advisory 
assignments. It contains the following data:  

-  Status of Assignment 
-  Start Date of Assignment 
-  End Date of Assignment 
-  Report Date 
-  Final Beneficiary 
-  Assignment Name 
-  Assignment Description 
-  Budget Utilisation 
-  Type of Support 
-  Eligible Area 
-  Countries   

Reporting and monitoring of projects after grant signature 

The management of the PSLF calls for proposals, the preparation and signature of grant agreements and the management of grant agreements, including 
reporting and monitoring, is delegated to CINEA.  

CINEA employs a structured approach to monitor and report on its projects, guided by Grant Agreements (GA) based on the EC’s model grant agreement 
for lump sums. They serve as the legal basis for project implementation. The Grant Agreement includes several annexes which outline the Description of 
the Action, and an Annex for KPIs. The whole process from evaluation of proposal to GA preparation as well as monitoring and payments are done through 
the Commission’s grant management system ‘e-Grants’. 

Reporting requirements are divided into continuous and periodic reporting in e-Grants:  

130 

 
 
-  Continuous reporting involves yearly technical reports on project progress, which are not linked to payments, in addition to continuously updating 
eGrants  with  information  on  deliverables,  milestones,  risks,  indicators  and  any  other  relevant  documents  due  during  project  implementation. 
Beneficiaries are responsible for updating the continuous reporting on-line in e-grants. 

-  Periodic Reporting involves submitting a detailed periodic report that combines both a technical and financial part. It is linked to payments. The 
technical part includes structured tables and a narrative section that addresses any differences in planned versus actual project progress, such as 
delays or budget overruns. The financial part consists of individual financial statements for each beneficiary and a summary financial statement. 
After assessment of the final period report, a final payment is processed, that can correspond to the amount requested by the beneficiary or a lower 
amount in case of Work Packages not fully completed.  

In this context, the monitoring of the PSLF’s Key Performance Indicators (KPIs) as listed in the Regulation is crucial, allowing for comparisons between 
planned indicators at the submission stage and those achieved during the project's reporting stage. 

Box 1: PSLF Key performance indicators 

1.Volume of grants awarded 

2. Volume of loans signed 
2.1 Individual loans 
2.2 Loan schemes 

3. Overall investment mobilised, divided as follows 
3.1 Amount of private financing mobilised 
3.2 Amount of public financing mobilised 

4.Number of projects receiving support, broken down by 

4.1 Country 
4.2 NUTS 2 region 
4.3 Just transition territory supported 

5.    Number of projects receiving financing under the Facility 

131 

 
 
 
 
 
 
 
 
6.    Number of projects by sector 

6.1 Transport 
6.2 Social infrastructure 
6.3 Public utilities (water, wastewater, district heating, energy, waste management) 
6.4 Direct support to facilitate the transition towards climate neutrality (renewable 
energy, decarbonisation, energy efficiency) 
6.5 Environmental objectives 
6.6 Urban infrastructure and housing 
6.7 Others 

7.    Greenhouse gas emission reductions, where relevant 

8.    Job creation, where relevant 

In addition to these KPIs, specific indicators are defined for each project based on its particular goals. However, these indicators cannot be aggregated at 
the level of the PSLF given that the precise type of projects and sectors the PSLF will support was not known at the time of the adoption of the PSLF 
Regulation, nor is it known now. Monitoring an extensive list of every possibly relevant KPI is burdensome and it is not possible to anticipate which 
indicators in the list will finally provide a possibility of aggregation generating meaningful data on the achievement of the PSLF’s objectives. 

Finally, an on-site visit typically occurs once per project at its end, to verify that the results of the projects as defined in the GA have been achieved.  

Monitoring of the achievement of the PSLF’s objectives 

The overall monitoring of PSLF activities, outputs, results and impact is based on the intervention logic presented as Figure 3 in the main body of this 
document.  Specific outputs and results are measured via the PSLF KPIs. 

132 

 
 
 
 
 
 
An overall weakness of the PSLF monitoring framework is that PSLF’s KPIs as listed in box 1 do not currently have targets. Given that this mid-term 
evaluation is an opportunity to inform and improve the final evaluation, including regarding the effectiveness of the monitoring framework, KPI targets are 
put forward in Table 7. They are not formulated in the legal base of the Facility and are meant to capture specific elements related to the implementation 
of the Facility. 

Table 7: KPI targets 

KPI 

Target 

Comments 

1. Volume of grants awarded. 

Targets proposed: 

(a) EUR 1.3125 billion of grants awarded. 

(b) 100% of the PSLF budget available for grants 
awarded. 

2. Volume of loans signed 
2.1 Individual loans 
2.2 Loan schemes 

No targets are put forward.  

133 

The  target  is  to  allocate  entirely  the  budget 
available for grants under the PSLF, in order to 
achieve  its  highest  possible  impact  within  the 
limits of the resources available.  

The  target  is  measured  both  as  (a)  the  current 
budget of the PSLF for grants after its reduction 
from  EUR  1.4595  in  the  context  of  the  MFF 
Review  and  (b)  as  the  full  allocation  of  the 
available budget for grants.  

The distinction is made given that the final budget 
available for grants under the PSLF will depend 
on 
the  amount  of  reflows  from  financial 
instruments made available for the PSLF.  

Loans  are  provided  by  the  EIB  in  line  with  its 
rules, policies  and procedures. The EIB has not 
put forward a target for  the volume of its PSLF 

 
 
3. Overall investment mobilised, divided as 
follows 

3.1 Amount of private financing mobilised 
3.2 Amount of public financing mobilised 

No targets are put forward. 

related  lending,  and  the  EC  does  not  have  the 
authority to put forward a target on behalf of the 
EIB.  

in 

from 

financing 

Setting  a  target  could  be  misleading  due  to  the 
variance 
investment  mobilisation  across 
regions.  Based  on  the  current  parameters  of  the 
Facility’s  implementation,  regions  where  PSLF 
beneficiaries  receive  the  maximum  possible 
the  European 
combined 
Investment  Bank  (EIB)  and 
the  European 
Commission  (EC)—up  to  90%  of  investment 
costs—will  have  the  lowest  overall  multiplier 
effect,  which  equates  to  5.5.  In  contrast,  other 
regions can receive EIB/EC financing up to 57% 
of investment costs, yielding a higher multiplier 
of 13.3. Consequently, the investment mobilised 
will be influenced by the regional distribution of 
supported  projects  and  the  share  of  investments 
covered  by  sources  other  than  the  combined 
EIB/EC support. 

Setting  targets  for  this  KPI  could  inadvertently 
skew priorities. Instead, the focus of the PSLF is 
to  facilitate  a  balanced  approach  that  addresses 
region-specific 
enforcing 
misleading performance goals. 

needs  without 

134 

 
 
4.Number of projects receiving support, broken 
down by 

No targets are put forward. 

4.1 Country 
4.2 NUTS 2 region 
4.3 Just transition territory supported 

5.    Number of projects receiving financing 
under the Facility 

Targets proposed: 

(a)  Projects  are  financed  in  at  least  50%  of  EU 
MS. 

135 

Regarding  the  distribution  of  private  versus 
public  financing  mobilised,  the  PSLF  has  no 
specific targets concerning this allocation. Thus, 
setting targets for the exact amounts of private or 
public financing would lack justification.  

For the purpose of this KPI, “support” should be 
understood as advisory support. 

No  targets  have  been  defined  for  the  specific 
number  of  projects  receiving  advisory  support 
from  the  PSLF,  given  that  there  is  no  basis  to 
consider  that  a  certain  number  of  projects, 
countries,  NUTS  2  regions  or  just  transition 
territories would be more impactful/in line with 
the PSLF’s objectives than another.  

The  quality  of  advisory  assignments  will  be 
monitored in line with the advisory assignments 
KPIs  defined  previously,  such  as  “Project 
maturity  and  progress  to  financing/  investment 
stage”  or  “Follow-up  on  investment/  financing 
status of completed advisory assignments”.  

In line with KPI 4, no targets have been defined 
for  the  specific  number  of  projects  receiving 
financing  from  the PSLF, given that there is  no 
basis to consider that a certain number of projects 

 
 
 
(b)  At  least  25%  of  the  projects  receiving 
financing  under 
less 
developed regions.  

the  Facility  benefit 

is  more  impactful/in  line  with  the  PSLF’s 
objectives than another.  

However: 

- 

a  target  is  proposed  concerning  the 
percentage  of  MS 
in  which  PSLF 
financing  is  received,  to  reflect  the  co-
legislators’  decision  to  ensure  that  all 
Member  States  are  able  to  benefit  from 
the grant component of the PSLF via the 
definition of national shares. If, upon full 
implementation,  only  a  minority  of 
Member  States  receive  support  from  the 
PSLF, the Facility's objectives might still 
be  achieved.  However,  the  indicator 
limited 
target  would  quantify 
contribution  across 
the  majority  of 
Member States, highlighting an important 
finding. 

this 

-  A  target  is  proposed  concerning  the 
percentage of projects receiving financing 
under  the  Facility  which  benefit  less 
developed  regions,  to  reflect  the  co-
legislators’ decision to prioritise projects 
benefitting  less  developed  regions.  If, 
upon  full  implementation,  less  than  a 

136 

 
6.    Number of projects by sector 

No targets are put forward. 

6.1 Transport 
6.2 Social infrastructure 
6.3 Public utilities (water, wastewater, 
district heating, energy, waste management) 
6.4 Direct support to facilitate the transition 
towards climate neutrality (renewable 
energy, decarbonisation, energy efficiency) 
6.5 Environmental objectives 
6.6 Urban infrastructure and housing 
6.7 Others 

7.    Greenhouse gas emission reductions, where 
relevant 

Target proposed: 

At least 50% of projects contribute directly to the 
achievement  of  the  Union’s  2030  climate  and 

137 

quarter of projects concern less developed 
regions,  the  Facility's  objectives  might 
still be achieved. However, the indicator 
limited 
target  would  quantify 
contribution,  highlighting  an  important 
finding. 

this 

The  implementation  of  the  PSLF  is  demand 
driven  and  has  a  wide  sectoral  eligibility, 
therefore the precise type of projects and sectors 
by which it will “address serious social, economic 
and environmental challenges deriving from the 
transition towards the Union’s 2030 climate and 
energy  targets  and  the  objective  of  climate 
neutrality in the Union by 2050” was not known 
at  the  time  of  the  adoption  of  the  PSLF 
Regulation, nor is it known now. 

There  is  no  basis  to  consider  that  a  certain 
distribution per sectors is more impactful/in line 
with the PSLF’s objectives than another.  

In  line  with  the  comments  made  for  KPI  6,  the 
precise type of projects and sectors which will be 
financed  by  the  PSLF  is  not  known,  therefore 
there  is  no  basis  to  estimate  their  potential  for 
greenhouse gas emission reduction. 

 
 
energy  targets  and  the  objective  of  climate 
neutrality in the Union by 2050. 

8.    Job creation, where relevant 

Target proposed: 

At least 50% of projects financed by the Facility 
directly contribute to job creation.  

138 

However,  a  target  is  proposed  concerning  the 
percentage  of  projects  financed  by  the  Facility 
which  contribute  to  greenhouse  gas  emission 
reductions  to  reflect  the  co-legislators’  decision 
to prioritise projects that contribute directly to the 
achievement  of  the  Union’s  2030  climate  and 
energy  targets  and  the  objective  of  climate 
neutrality in the Union by 2050.  

The  target  is  set  at  50%  to  assess  whether  a 
majority of supported projects contribute to these 
objectives. If these targets are not met upon full 
implementation of the Facility, the objectives of 
the  Facility  might  still  be  achieved,  but  the 
indicator  target  would  highlight  its  limited 
contribution to environmental sustainability. 

In  line  with  the  comments  made  for  KPI  6,  the 
precise type of projects and sectors which will be 
financed  by  the  PSLF  is  not  known,  therefore 
there is no basis to estimate their potential for job 
creation. 

However,  a  target  is  proposed  concerning  the 
percentage  of  projects  financed  by  the  Facility 
which contribute to job creation. 

The  target  is  set  at  50%  to  assess  whether  a 
majority of supported projects contribute to this 
objective.  If  the  target  is  not  met  upon  full 

 
 
 
implementation of the Facility, the objectives of 
the  Facility  might  still  be  achieved,  but  the 
indicator  target  would  highlight  its  limited 
contribution to job creation. 

139