COMMISSION STAFF WORKING DOCUMENT EVALUATION Ex-post Evaluation for the Internal Security Fund - Borders and Visa (ISF-BV) for the 2014-2020 programming period
Date: 2026-03-03
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, Schengen Agreement, external border of the EU, fund (EU), migration control, project evaluation, public safety

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.3.2026  SWD(2026) 75 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Ex-post Evaluation for the Internal Security Fund - Borders and Visa (ISF-BV) for the 2014-2020 programming period {SWD(2026) 76 final}  
 
 
TABLE OF CONTENTS 

1 

Introduction ..................................................................................................... 7 

1.1  Methodology .......................................................................................... 9 

1.2  Limitations ........................................................................................... 10 

2  What was the expected outcome of the intervention? ................................... 10 

2.1  Policy context and development .......................................................... 10 

2.2  The ISF-BV (2014-2020) .................................................................... 13 

2.3  Points of comparison ........................................................................... 14 

2.4 

Intervention logic ................................................................................. 18 

3  How has the situation evolved over the evaluation period? .......................... 19 

3.1  Overall description of the implementation set-up ............................... 22 

3.2  Shared Management ............................................................................ 24 

3.3 

3.4 

Implementation at the National Programme Level ............................. 25 

Initial steps in implementation ............................................................ 25 

3.5  State of implementation at closure ...................................................... 26 

4 

Evaluation findings ........................................................................................ 27 

4.1  To what extent was the intervention successful and why? .................. 27 

4.1.1 

4.1.2 

4.1.3 

Effectiveness .......................................................................... 27 

Efficiency............................................................................... 44 

Simplification and reduction of administrative burden ......... 51 

4.1.4  Coherence and complementarity ........................................... 56 

4.2  How did the EU intervention make a difference and to whom? ......... 67 

4.2.1 

4.2.2 

EU added value ...................................................................... 67 

Sustainability ......................................................................... 72 

4.3 

Is the intervention still relevant? ......................................................... 79 

4.3.1  Relevance............................................................................... 79 

5  Conclusions and Lessons Learned ................................................................ 84 

5.1  Conclusions ......................................................................................... 84 

5.1.1 

5.1.2 

5.1.3 

Effectiveness .......................................................................... 84 

Efficiency............................................................................... 85 

Simplification and reduction of administrative burden ......... 86 

5.1.4  Coherence and complementarity ........................................... 87 

 
 
 
5.1.5 

5.1.6 

EU added-value ..................................................................... 89 

Sustainability ......................................................................... 89 

5.1.7  Relevance............................................................................... 90 

5.2  Lessons learned ................................................................................... 90 

ANNEX I: Procedural information ....................................................................... 93 

ANNEX II: Methodology and analytical models used .......................................... 94 

Methodology ................................................................................................. 94 

Limitations and mitigation measures ............................................................ 95 

ISF-BV Intervention Logic ........................................................................... 97 

ANNEX III: Evaluation Matrix ............................................................................. 98 

Additional information for the assessment of coherence ............................ 126 

ANNEX IV: Overview of benefits and costs ...................................................... 139 

ANNEX V: Stakeholder consultation – synopsis report ..................................... 153 

1  Consultation strategy ................................................................................... 153 

2  Results of the consultation activities ........................................................... 157 

2.4.2 

Substantial findings ............................................................. 164 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AMIF 

APR 

AWP 

CSOs 

DG BUDG 

DG HOME 

DG JUST 

DG RTD 

Asylum, Migration and Integration Fund 

Annual Performance Report 

Annual  Work  Programme  for  Union  Actions  and  Emergency 
Assistance 

Civil Society Organisations 

Directorate-General for Budget 

Directorate-General Migration and Home Affairs 

Directorate-General for Justice and Consumers 

Directorate-General for Research and Innovation 

DG TAXUD 

Directorate-General for Taxation and Customs Union 

EBCG 

European Border and Coast Guard 

EBCGA/Frontex 

European Border and Coast Guard Agency 

EBF 

EC 

EIBM 

EMAS 

EP 

ETIAS 

EU 

eu-LISA 

EUROPOL 

EUROSUR 

ILO 

IOM 

External Borders Fund 

European Commission 

European Integrated Border Management 

Emergency Assistance 

European Parliament 

European Travel Information and Authorisation System 

European Union 

European  Union  Agency  for  the  Operational  Management  of 
Large-Scale  IT  Systems  in  the  Area  of  Freedom,  Security  and 
Justice 

European Union Agency for Law Enforcement Cooperation 

European Border Surveillance system 

Immigration Liaison Officers 

International Organisation for Migration 

 
 
 
ISF 

ISF-BV 

ISF-P 

MFF 

MS 

Participating countries 

RA 

SACs 

SIS 

ToR 

UA 

UNHCR 

VIS 

Internal Security Fund 

Internal Security Fund – Borders and Visa 

Internal Security Fund - Police 

Multiannual Financial Framework 

Member States 

EU Member States participating in the ISF-BV (all Member States 
but  Ireland  and  the  then  member  United  Kingdom)  and  the 
Schengen Associated Countries (Iceland, Liechtenstein, Norway 
and Switzerland.) 

Responsible Authority, the authority in charge  of implementing 
the national programmes 

Schengen Associated Countries (Iceland, Liechtenstein, Norway 
and Switzerland) 

Schengen Information System 

Terms of Reference 

Union Action 

UNHCR United Nations High Commissioner for Refugees 

Visa Information System 

 
 
 
 
 
List of tables and figures 

Table 1 - Main Evaluation Questions ................................................................................. 8 
Table 2 - Detailed breakdown of initial EU contributions by management modes, as per 
the legal base .................................................................................................................... 23 
Table 3 - Breakdown of national programme allocations by Specific Objective ............. 24 
Table  4  -  Investment  priorities  within  top,  mid-tier,  and  low  performers,  based  on  the 
efficiency score ranking (SO1) ......................................................................................... 47 
Table  5  -  Investment  priorities  within  top,  mid-tier,  and  low  performers,  based  on  the 
efficiency score ranking (SO2) ......................................................................................... 48 
Table 6 - Management modes and funding components in the ISF-BV according to legal 
base illustrating the complementary purpose of the different components ...................... 56 
Table 7 -Assessment of the relevance of Union Actions objectives ................................ 81 
Table 8  - Mapping  of costs and benefits  entailed by the implementation  of the ISF-BV 
Fund ................................................................................................................................ 139 
Table  9  -  Investment  priorities  within  top,  mid-tier,  and  low  performers,  based  on  the 
efficiency score ranking (SO1) ....................................................................................... 150 
Table 10  -  Investment  priorities within top,  mid-tier, and low performers, based on the 
efficiency score ranking (SO2) ....................................................................................... 150 
Table 11: Overview of the stakeholders reached through each consultation tool / method
 ........................................................................................................................................ 152 
Table 12: EU-Level interviews conducted ..................................................................... 153 
Table 13: Number and type of stakeholders interviewed per country case study .......... 155 
Table 14: Number and type of stakeholders consulted per thematic case study ............ 156 

Figure 1 - Legal and irregular migration to the EU ........................................................ 15 
Figure 2 - Irregular arrivals to the EU - 2008-2024 ....................................................... 15 
Figure 3 - Schengen Visa Application trends (2014-2023) .............................................. 16 
Figure 4 - Breakdown of initial EU contributions by management modes, as per the legal 
base ................................................................................................................................... 17 
Figure 5 - Breakdown of EU contributions by management modes, as of final budget .. 18 
Figure 6 - Total allocations to national programmes (EUR millions) .............................. 19 
Figure 7 - Absorption rates of national programmes on the basis of amounts declared for 
clearance in the final accounts .......................................................................................... 21 
Figure 8 - SO1 components’ allocations & declared accounts ......................................... 22 
Figure 9 - Number of consular representations provided by Schengen countries (location x 
country covered) (2014 and 2024) ................................................................................... 23 
Figure 10 - SO1.NO2 Union Acquis (allocated amounts – EUR million) ....................... 25 
Figure  11  -  SO1.NO3  Consular  Cooperation  and  Specific  Actions  on  Consular 
Cooperation (allocated amounts – EUR million) ............................................................. 27 
Figure 12 - SO2 components’ allocations & declared accounts ....................................... 29 
Figure 13 - Commitments and financial implementation of EMAS by year (EUR million)
 .......................................................................................................................................... 36 
Figure 14 - EMAS’ main operational scope across MS ................................................... 36 
Figure 15 - Top 25% Member States with the highest efficiency score .......................... 42 

 
 
 
Figure  16  -  Assessment  of  contribution  ISF-BV  fund  structure 
to  ensuring 
complementarities and synergies, where relevant (N=14) ............................................... 54 
Figure 17 - Was an assessment conducted in your Member State to identify other funding 
instruments with similar or complementary objectives at the EU or national level in order 
to build complementarities/synergies and avoid overlaps/duplications with ISF BV ...... 55 
Figure 18 - Coherence between ISF-BV and AMIF (% responses) ................................. 58 
Figure 19 - Number of Member States that conducted needs assessment (N=16) ........... 74 
Figure 20 - ISF-BV flexibility to address changing needs ............................................... 75 
Figure 21 - Coherence between ISF-BV and AMIF (% responses) ............................... 128 
Figure  22:  Responses  to  the  survey  question:  In  your  opinion,  were  the  actions 
implemented  through  the  ISF-BV  and  BMVI  Instruments  coherent  with  and  non-
contradictory  (no  duplications  or  overlap)  to  other  EU  interventions  with  similar  or 
complementary objective................................................................................................ 138 
Figure 23 - Country Performance and absorption rate with expenditures for SO1 ........ 147 
Figure 24 - Country Performance and absorption rate with expenditures for SO2 ........ 147 
Figure 25 - Efficiency scores for SO1 ............................................................................ 149 
Figure 26 - Efficiency scores for SO2 ............................................................................ 149 
Figure 27: Respondents by Type of Stakeholders .......................................................... 163 
Figure 28: Respondents by Countries............................................................................. 164 
Figure 29: Respondents by organisation size ................................................................. 164 

 
 
 
 
 
1 

INTRODUCTION 

The instrument for financial support for external borders and visa (hereafter, “the ISF-BV” 
or “the Instrument” or “the Fund”), established by Regulation (EU) No 515/2014 (1) of the 
European Parliament and of the Council (henceforward, the “ISF-BV regulation”) applied 
as from 1 January 2014. 

The  general  provisions  concerning  the  implementation  of  the  three  Home  Affairs 
instruments  for  the  period  2014-2020  (AMIF (2),  ISF-BV  and  ISF-P (3)  together  also 
known as the “Home Affairs Funds”) were laid down in Regulation (EU) No 514/2014 of 
the European Parliament and of the Council (4) (“the Horizontal Regulation”). According 
to article 57 of the Horizontal Regulation, on the basis of the ex-post evaluation reports 
submitted by the participating  countries  on their national  programmes by 31 December 
2023,  the  Commission  is  to  submit  an  ex-post  evaluation  report  of  each  instrument  to 
the European Parliament, to the Council, to the European Economic and Social Committee 
and to the Committee of the Regions by 30 June 2024. 

The deadline of 30 June 2024 was extended by one year through the amendment of the 
Horizontal Regulation (5), following the Russian war of aggression against Ukraine on 24 
February 2022. The amendment extended the implementation of ISF-BV, as well as of the 
Internal  Security  Fund  –  Police (6)  and  the  Asylum,  Migration  and  Integration  Fund (7) 
(hereinafter, also jointly as the “Home Affairs Funds”), by one year, to allow the Member 
States  to  fully  use  any  unspent  amounts  from  their  national  programmes,  and,  where 
necessary,  to  swiftly  revise  the  implementation  of  their  programmes  to  address  the 
challenges arising from the invasion of Ukraine by the Russian Federation. 

(1)  Regulation  (EU)  No  515/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014 
establishing, as part of the Internal Security Fund, the instrument for financial support for external borders 
and  visa  and  repealing  Decision  No  574/2007/EC,  OJ  L  150,  20.5.2014,  pp.  143–167,  ELI: 
http://data.europa.eu/eli/reg/2014/515/oj. 
(2) Regulation (EU) 2021/1147 of the European Parliament and of the Council of 7 July 2021 establishing 
Integration  Fund.  OJ  L  251,  15.7.2021,  pp.  1–47,  ELI: 
the  Asylum,  Migration  and 
http://data.europa.eu/eli/reg/2021/1147/oj. 
(3)  Regulation  (EU)  No  513/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014 
establishing, as part of the Internal Security Fund, the instrument for financial support for police cooperation, 
preventing and combating crime, and crisis management and repealing Council Decision 2007/125/JHA. OJ 
L 150, 20.5.2014, pp. 93–111. ELI: http://data.europa.eu/eli/reg/2014/513/oj 
(4) Regulation (EU) No 514/2014 of the European Parliament and of the Council of 16 April 2014 laying 
down general provisions on the Asylum, Migration and Integration Fund and on the instrument for financial 
support for police cooperation, preventing and combating crime, and crisis management. OJ L 150 20.5.2014, 
p. 112, ELI: http://data.europa.eu/eli/reg/2014/514/2022-04-12. 
(5)  Regulation  (EU)  2022/585 of  the  European  Parliament  and  of  the  Council  of  6  April 2022  amending 
Regulations No 514/2014 laying down general provisions on the Asylum, Migration and Integration Fund 
and  on  the  instrument  for financial  support  for  police  cooperation, preventing  and  combating  crime,  and 
crisis  management,  (No)  516/2014  establishing  the  Asylum,  Migration  and  Integration  Fund  and  (EU) 
2021/1147  establishing  the  Asylum,  Migration  and  Integration  Fund.  OJ  L  112,  11.4.2022,  pp.  1–
5. ELI: http://data.europa.eu/eli/reg/2022/585/oj 
(6) Regulation (EU) No 513/2014. 
(7)  Regulation  (EU)  No  516/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014 
establishing  the  Asylum,  Migration  and  Integration  Fund,  amending  Council  Decision  2008/381/EC  and 
repealing Decisions No 573/2007/EC and No 575/2007/EC of the European Parliament and of the Council 
and  Council  Decision 
ELI: 
http://data.europa.eu/eli/reg/2014/516/2022-04-12. 

2007/435/EC,  OJ 

20.5.2014, 

168-194, 

150, 

p. 

L 

7 

 
 
 
As defined in the Evaluation Framework for the Home Affairs Funds (8), and in line with 
Better  Regulation  provision,  the  evaluation,  grounded  in  the  legal  provisions  of  the 
Horizontal Regulation (9), should report on the achievement of the specific objectives of 
the  ISF-BV  and  cover  the  following  evaluation  criteria:  effectiveness,  efficiency, 
Simplification and reduction of administrative burden, coherence, complementarity, 
EU added value, relevance and sustainability (10).  

The  evaluation  covers  the  entire  implementation  period  of  the  ISF-BV,  that  is,  from 
January 1, 2014, to June 30, 2024 (11).  It encompasses all Member States (except Denmark, 
Ireland  and  the  United  Kingdom  (which  ceased  to  be  a  Member  State  on  31  January 
2020) (12) as well as the  Schengen associated Countries (Norway, Iceland, Switzerland, 
and Liechtenstein, hereinafter also referred to as the “SACs”).In addition, third countries 
where the ISF-BV supported actions are implemented and which are impacted by funded 
activities are also considered through targeted interviews and documentary review (where 
relevant). 

The material scope of the evaluation covers activities under the three existing management 
modes: shared management, direct management and indirect management. 

The  evaluation  is  structured  around  the  key  evaluation  questions  listed  in  Annex  II  of 
Commission Delegated Regulation 2017/207 (Table 1). These questions guide the analysis 
of 
its 
the  Instrument’s  performance,  ensuring  a  comprehensive  assessment  of 
implementation and impact. 

Table 1 - Main Evaluation Questions 

Evaluation Criteria  Main Evaluation Questions 

Effectiveness 

How  did  the  Fund  contribute  to  the  achievement  of  the  following  specific 
objectives: Support a common visa policy to facilitate legitimate travel; Provide 
a  high  quality  of  service  to  visa  applicants;  Ensure  equal  treatment  of  third-
country nationals and tackle illegal migration? 

(8) Commission Delegated Regulation (EU) 2017/207 of 3 October 2016 on the common monitoring and 
evaluation framework provided for in Regulation (EU) No 514/2014 of the European Parliament and of the 
Council laying down general provisions on the Asylum, Migration and Integration Fund and on the 
instrument for financial support for police cooperation, preventing and combating crime, and crisis 
management. OJ L 33, 8.2.2017, pp. 1–13. ELI: http://data.europa.eu/eli/reg_del/2017/207/oj. 
(9) Article 57 of the Horizontal Regulation. 
(10) Annex II of Commission Delegated Regulation 2017/207. OJ L 33, 8.2.2017, pp. 1–13, 
http://data.europa.eu/eli/reg_del/2017/207/oj.  
(11) The implementation period of the Home Affairs Funds 2014-2020 (including of the ISF-BV) was extended in 
2022 by 1 year ( from 30 June 2023 to 30 June 2024) to allow the Member States to fully use any unspent 
amounts from those programmes, and, where necessary, to swiftly revise the implementation of their programmes 
to address the challenges arising from the invasion of Ukraine by the Russian Federation on 24 February 2022 
(See Regulation (EU) 2022/585 amending Regulation(EU) No 514/2014). 
(12) The ISF-BV Regulation is based on legal bases under Title V of Part Three TFEU, concerning the area 
of freedom, security and justice. It constitutes a development of the Schengen acquis. As a consequence, in 
accordance with Article 1 and 2 of Protocol No. 22, and without prejudice to Article 4 of that Protocol, the 
application of the ISF-BV Regulation to Denmark is subject to the provisions laid down in Protocol No 22 
annexed to the TEU and the TFEU. In accordance with Council Decision 2002/192/EC, the United 
Kingdom and Ireland are not bound by nor subject to the application of ISF-BV Regulation. 

8 

 
 
How did the Fund contribute to the following specific objectives:  
Supporting integrated border management, including promoting harmonisation of 
border  management-related  measures  in  accordance  with  common  Union 
standards and through the sharing of information between MS and between MS 
and the European Agency for the Management of Operational Cooperation at the 
External Borders of the MS of the EU?  
Ensuring, on one hand, a uniform and high level of control and protection of the 
external borders, including by the tackling of illegal immigration and, on the other 
hand,  the  smooth  crossing  of  the  external  borders  in  conformity  with  the 
Schengen acquis, while guaranteeing access to international protection for those 
needing it, in accordance with the obligations contracted by the MS in the field 
of human rights, including the principle of non-refoulement? 

Were the general objectives of the Fund achieved at reasonable cost? 

Did  the  objectives  of  the  interventions  funded  by  the  Fund  correspond  to  the 
actual needs? 

Were the objectives set in the national programme Fund coherent with the ones 
set in other programmes funded by EU resources and applying to similar areas of 
work? 

Was the coherence ensured also during the implementation of the Fund? 

Were  the  objectives  set  in  the  national  programme  and  the  corresponding 
implemented  actions  complementary  to  those  set  in  the  framework  of  other 
policies, in particular those pursued by the Member State? 

Efficiency 

Relevance 

Coherence 

Complementarity 

EU Added Value 

Was any value added brought about by the EU support? 

Are the positive effects of the projects supported by the Fund likely to last when 
the support from the Fund will be over? 

Were the Fund management procedures simplified, and the administrative burden 
reduced for its beneficiaries? 

Sustainability 

Simplification and 
reduction of 
administrative 
burden 

1.1  Methodology 

The  evaluation  is  mostly  based  on  an  external  study,  which  applied  a  mixed-method 
evaluation approach, incorporating both quantitative and qualitative research techniques. 
The methodological approach included: 

•  Desk Research 

•  Financial and Quantitative Analysis 

•  Stakeholder Consultation 

• 

Interviews  with  key  stakeholders,  including  European  Commission  officials, 
Member State representatives, and Frontex 

•  Targeted Surveys of national authorities, implementing bodies, and beneficiaries 

•  Case  Studies  on  selected  Member  States  (both  country  case  and  thematic  case 

studies) 

•  Public Consultation  

More detailed information is avaiable in Annex II. 

9 

 
 
1.2  Limitations 

The evaluation faced challenges related to data quality, availability, and consistency across 
Member States. Differences in the level of detail of Final Implementation Reports (FIRs) 
and national ex-post evaluations made cross-country comparisons difficult. In some cases, 
historical data gaps hindered the ability to evaluate developments in border management 
and visa policy throughout the evaluation period. Additionally, survey participation rates 
varied, affecting the representativeness of stakeholder feedback, while differences in the 
interpretation of evaluation indicators by the Responsible Authorities in the participating 
countries introduced inconsistencies in reporting. 

To  address  these  challenges,  the  study  applied  triangulation  methods,  cross-referencing 
multiple  sources  and  using  alternative  indicators  where  primary  data  was  incomplete. 
Interviews with stakeholders clarified discrepancies, while statistical analysis, including 
regression  models,  helped  validate  financial  and  operational  data.  While  minor 
inconsistencies in SFC (13) data remained, no major errors were identified. Despite these 
challenges,  the  evaluation  provides  a  comprehensive  assessment  of  the  ISF-BV’s 
effectiveness, efficiency, simplification and reduction of administrative burden, coherence, 
complementarity, EU added value, relevance, sustainability of the Instrument, and broader 
impact, ensuring well-founded conclusions for future policy and funding decisions. 

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1  Policy context and development  

The  common  management  of  external  borders  and  visas  in  Europe  is  fundamentally 
intertwined  with  the  creation  of  the  Schengen  area.  The  signature  of  the  Schengen 
Agreement in 1985 was indeed the first step towards an EU common policy for managing 
external borders, which became part of the EU legislative framework in  1999. The box 
below presents  the main stages in  the development  of EU support to  the Home Affairs 
Area. 

(13) SFC is the IT system for the programming, implementation and reporting of shared fund management in 
the European Union. 

10 

 
 
Figure 1 - Policy context 

The Schengen Area aims to allow for traveling without checks within its internal borders 
with the goal of ensuring unrestricted travel for over 425 million EU citizens, as well as 
non-EU citizens legally residing or visiting the EU for various purposes, such as tourism, 
education, or business. This freedom of movement allows any EU citizen to easily travel, 
work,  and  reside  in  any  EU  country.  The  Schengen  acquis  aims  at  facilitating  this  by 
allowing people to move within the area without border control at the internal borders (14). 

In these regards, the Schengen acquis has thus contributed to: 

a.  Establishing a single set of rules for external border checks on persons, through:  

o  The Schengen  Borders  Code (15), which  sets  out  rules  on  crossing  EU 
borders – both internal and external, including border control, border check 
and border surveillance of the Members States of the Union and those of 
the Schengen Associated Countries (SACs), facilitating entry for those with 
legitimate reasons to enter the EU, and  

o  A  common visa  policy, ensuring  consistent  guidelines  for  legal  entry  of 
non-EU nationals subject to Schengen visa to the EU for short stays (up to 
90 days in any 180-days period).  

(14) Schengen Area - European Commission (europa.eu). 
(15) Regulation (EU) 2016/399 of the European Parliament and of the Council of 9 March 2016 on a Union 
Code  on  the  rules  governing  the  movement  of  persons  across  borders  (Schengen  Borders  Code) 
(codification). OJ L 77, 23.3.2016, pp. 1–52. ELI: http://data.europa.eu/eli/reg/2016/399/oj 

11 

 
 
 
 
b.  Increasing security for citizens and travelers, through a variety of large-scale IT 

systems, meant to become interoperable among each other, and namely: 

o  Schengen Information System (SIS), which, since 1995, constitutes the 
cooperative  system  used  to  manage  security  and  border  management  in 
Europe. It allows each participating State to share information, biometrics, 
return decisions and issue alerts, for instance regarding terrorism offences.  

o  Visa information System (VIS), which, since 2004, has allowed Schengen 
States to exchange visa data. It is a central IT system and a communication 
infrastructure linking the central system to national systems.  

o  Two additional information systems, which have been designed in such a 
way  that  they  already  present  a  degree  of  interoperability  between 
themselves  and  with  the  VIS,  are  expected  to  start  operating  shortly: 
the Entry/Exit  System  (EES),  an  automated  IT  system  for  registering 
travellers from third countries, initially scheduled to commence operations 
in  the  latter  half  of  2024,  and  the European  Travel  Information  and 
Authorisation System (ETIAS), an IT system designed to identify security 
risks,  irregular  migration,  or  high  epidemic  risks  posed  by  visa-exempt 
visitors, initially expected to launch in mid-2025.  

Since the end of the 1990s, various funding programmes have been implemented to support 
the  Member  States  in  the  development  of  an  integrated  border  and  visa  management 
system: 
The  ODYSSEUS  Programme  (1998-2002) (16)  was  made  to  establish  a  framework  for 
training,  information,  study  and  exchange  activities  to  improve  the  effectiveness  of 
cooperation  between  the  administrations  of  the  Member  States  in  the  areas  of  asylum 
policy, the crossing of external borders of the Member States and immigration policy. With 
this first  multiannual  programming,  it aimed to  extend this cooperation to non-member 
countries applying for accession. 

The  ARGO  Programme  (2002-2006) (17)  had  three  objectives:  to  promote  cooperation 
between national agencies responsible for implementing Community rules and to ensure 
that proper account is taken of the Community dimension in their actions; to promote the 
uniform  application  of  Community  law;  and  to  increase  the  transparency  and  overall 
effectiveness of the actions taken by the national authorities.  

The External Borders Fund (EBF) (18), part of the Framework Programme, “Solidarity 
and Management of Migration Flows” for the period 2007-2013, was the first dedicated 
EU financial programme that supported external border management in the EU. With EUR 
1.82  billion  over  the  period  2007-2013,  its  objective  was  to  promote  burden-sharing 
between Member States. It aimed to support the efficient organisation of control of and the 

(16) Joint Action 98/244/JHA of 19 March 1998 adopted by the Council on the basis of Article K.3 of the 
Treaty on European Union, introducing a programme of training, exchanges and cooperation in the field of 
asylum,  immigration  and  crossing  of  external  borders  (Odysseus  programme)  -  (1998-2002).  OJ  L  99, 
31.03.1998. ELI: http://data.europa.eu/eli/joint_action/1998/244/oj 
(17)  Council  Decision  2002/463/EC  of  13  June  2002  adopting  an  action  programme  for  administrative 
cooperation in the fields of external borders, visas, asylum and immigration (ARGO programme). OJ L 161, 
19.6.2002, pp. 11–15. ELI: http://data.europa.eu/eli/dec/2002/463/oj 
(18) Decision No 574/2007/EC of the European Parliament and of the Council of 23 May 2007 establishing the 
External Borders Fund for the period 2007 to 2013 as part of the General programme “Solidarity and Management 
of Migration Flows”. OJ L 144, 6.6.2007, pp. 22–44. ELI: http://data.europa.eu/eli/dec/2007/574/oj. 

12 

 
 
 
management of the flows of persons at external borders (19),  as well as the management 
of consular services.  

In an effort by the Commission to rationalise the number of distinct funds and facilitate the 
administrative  management  of  beneficiaries,  the  EBF  was  repealed  by  the  Internal 
Security Fund (ISF) for the programming period 2014-2020. The ISF was composed of 
two instruments, one of which the “Borders and Visas” component (ISF-BV). The ISF-
BV general objective was to contribute to ensuring a high level of security in the Union 
while facilitating legitimate travel, through a uniform level of control of the external border 
and the effective processing of Schengen visas.   

The Border management and visa policy instrument (20) (BMVI) for the programming 
period 2021-2027  is part of the Integrated Border Management Fund (IBMF) forming a 
comprehensive framework for EU financial support in the filed of border manamgent and 
visa  policy  comprising  the  BMVI  and  the  Customs  Control  Equipment  Instrument 
(CCEI) (21). The BMVI  aims to support Member States  (i) in strengthening an effective 
European  integrated  border  management  at  the  external  borders,  to  faciliate  legitimate 
border crossing, to prevent and detect illegal immigration and cross-border crime and to 
effectively manage migratory movements; (ii) in the implementation of the common visa 
policy  to  ensure  an  harmonised  approach  in  the  issuance  of  visas  and  in  facilitating 
legitimate travel. 

2.2  The ISF-BV (2014-2020) 

To  achieve  its  objectives,  the  ISF-BV  was  implemented  through  the  three  methods  of 
Union  budget  implementation:  shared,  direct  and  indirect  management.  Under  shared 
management, national authorities were responsible for overseeing a significant portion of 
the funding, following guidelines set at the EU level. Under direct management, the ISF-
BV budget was allocated to Union actions as referred to in Article 13 of ISF-BV regulation, 
to Emergency Assistance referred to in Article 14 of that regulation and to the technical 
assistance  referred  to  in  Article  16(1)  of  that  regulation.  Union  actions  and  Emergency 
Assistance were also implemented, where appropriate, under indirect management, by 
entities entrusted by the Commission with budget implementation tasks.  

This structure enabled a flexible and coordinated response to the evolving challenges in 
border security and visa policy across the EU.  

Article 3 of  regulation 515/2014 sets out the general and specific objectives of ISF-BV. 
Its general objective is to “contribute to ensuring a high level of security in the Union 
while  facilitating  legitimate  travel,  through  a  uniform  and  high  level  of  control  of  the 
external borders and the effective processing of Schengen visas, in compliance with the 
Union’s commitment to fundamental freedoms and human rights” (22). 

(19) Article 3(1), (i) of Decision No 574/2007/EC 
(20) Regulation (EU) 2021/1148 of the European Parliament and of the Council of 7 July 2021 establishing, 
as  part  of  the  Integrated  Border  Management  Fund,  the  Instrument  for  Financial  Support  for  Border 
Management 
48–93. 
ELI: http://data.europa.eu/eli/reg/2021/1148/oj 
(21) Regulation (EU) 2021/1077 of the European Parliament and of the Council of 24 June 2021 establishing, 
as part of the Integrated Border Management Fund, the instrument for financial support for customs control 
equipment. OJ L 234, 2.7.2021, pp. 1–17. ELI: http://data.europa.eu/eli/reg/2021/1077/oj 
(22) Article 3 of ISF-BV regulation, paragraph 1. 

15.7.2021, 

Policy. 

Visa 

251, 

and 

pp. 

OJ 

L 

13 

 
 
 
Within the general objective, the ISF-BV pursued two specific objectives (SO) (23):  

SO1: Supporting a common visa policy to facilitate legitimate travel, provide a high quality 
of service to visa applicants, ensure equal treatment of third-country nationals and tackle 
illegal immigration; 

including  promoting 

integrated  border  management, 

SO2:  Supporting 
further 
harmonisation of border management-related measures in accordance with common Union 
standards  and  through  the  sharing  of  information  between  Member  States  and  between 
Member States and the Frontex Agency. It aims to ensure, on one hand, a uniform and high 
level of control and protection of the external borders, including by the tackling of illegal 
immigration  and,  on  the  other  hand,  the  smooth  crossing  of  the  external  borders  in 
conformity with the Schengen acquis, while guaranteeing access to international protection 
for those needing it, in accordance with the obligations contracted by the Member States 
in the field of human rights, including the principle of non-refoulement. 

The  ISF-BV  supported  a  range  of  activities  designed  to  strengthen  border  surveillance, 
enhance  risk  analysis  capabilities,  and  modernise  information-sharing  mechanisms. 
Funding  was  allocated  to  the  development  and  maintenance  of  large-scale  EU  security 
systems, including the Schengen Information System and the Visa Information System. 
Investments were also made in border control equipment, ICT infrastructure, and personnel 
training  to  ensure  harmonised  and  efficient  border  management  across  Member  States. 
Additionally, the ISF-BV sought to improve cooperation between border authorities, foster 
intelligence-sharing, and enhance operational coordination with Frontex. These measures 
were expected to lead to more effective border controls, a more efficient and harmonised 
visa  policy,  and  an  overall  reduction  in  security  vulnerabilities  at  the  Union  external 
borders. 

2.3  Points of comparison  

Comparison with the External Borders Fund (EBF)  

Prior  to  the  establishment  of  the  Visa  ISF-BV  in  2014,  the  Union  external  border 
management was supported by the External Borders Fund (24) (EBF) (2007–2013). The 
EBF was created as  the  Union’s first  funding instrument  for borders, launched in  2007 
under the Solidarity and Management of Migration Flows (SOLID) framework. It formed 
part of a broader policy package alongside measures such as the Frontex Agency and the 
Schengen Borders Code. Backed by a budget of EUR 1.82 billion, the EBF’s aim was to 
enhance the control and management of movements across the external borders, harmonise 
the application of EU rules on border crossings, and strengthen the organisation of consular 
activities.  In  practice,  the  EBF  fully  supported  five  priority  objectives (25),  including 
creating  a  common  integrated  border  management  system  for  the  surveillance  of  the 
external borders, issuing visas and tackling illegal immigration, establishing the IT systems 
required  to  implement  EU  border  and  visa  legislation,  and  promoting  the  effective  and 
efficient  application of EU border and visa legislation.  The EBF operated under shared 
management with Member States via annual national programmes, and it co-financed both 
national projects and certain transnational or “Community” actions managed directly by 
the European Commission. As highlighted in the preamble to the ISF-BV regulation and 

(23)  Article 3 of ISF-BV regulation, paragraph 2. 
(24)  Decision No 574/2007/EC of the European Parliament and of the Council of 23 May 2007. 
(25) Commission Decision 2007/599 /EC of 27 of August 2007 Implementing Decision No 574/2007/EC of 
the European Parliament and of the Council as regards the adoption of strategic guidelines for 2007 to 2013 

14 

 
 
its  proposal (26),  a  core  rationale  of  the  EBF  was  to  express  solidarity  by  financially 
assisting those Member States bearing the heaviest burden in controlling the EU’s external 
frontiers. However, the EBF’s scope was inherently bounded – focused mainly on border 
control and common visa policy – and it did not cover every emerging need in EU border 
management. 

Transition to ISF-BV – structural and strategic shifts 

The  ISF-BV  (2014–2020)  was  conceived  as  a  successor  that  builds  on  the  EBF’s 
achievements while addressing its gaps. Legislatively, the ISF-BV was established as part 
of a new two-pillar Internal Security Fund structure, replacing the old SOLID funds. This 
two-pronged framework (one instrument for borders and visa, and a separate instrument 
for  police  cooperation)  was  explicitly  designed  to  “contribute  to  the  simplification, 
rationalisation, consolidation and transparency” of EU home affairs funding (27). In other 
words, whereas the EBF had been one of four parallel funds, the ISF-BV became one of 
two  components  under  a  unified  Internal  Security  Fund,  allowing  for  more  coherent 
management. The new fund also introduced simplified implementation: under the EBF, 
each  country  implemented  a  multiannual  strategy  via  annual  programmes,  an  approach 
some  found  administratively  heavy (28).  In  ISF-BV,  this  was  streamlined  into  a  single 
multiannual national programme for 2014–2020, which speeds up the funding process and 
decreases  administrative  burden  by  giving  Member  States  more  flexibility  (e.g.  use  of 
national eligibility rules) (29). The Commission’s proposal, as well as the preamble to the 
Horizontal Regulation highlighted the need for flexibility and user-friendliness, noting that 
the ISF should provide increased flexibility and simplification while ensuring a fair and 
transparent  distribution  of  resources.  In  light  of  lessons  from  the  EBF (30),  the  ISF-BV 
Regulation also allows a higher degree of financial flexibility, for instance permitting shifts 
of resources between various objectives/instruments to respond to new pressures (all while 
maintaining  a  stable  core  allocation  for  each  national  programme).  Another  structural 
change was the handling of specific actions: under the EBF, there were centrally managed 
community  actions  and  specific  projects  overlapping  with  national  efforts.  ISF-BV 
abolished the separate specific-action funding at EU level and instead folded those actions 
into  the  regular  national  programmes,  giving  Member  States  more  ownership  and 
flexibility in using funds. 

Expanded scope and priorities under ISF-BV 

Substantively, the ISF-BV broadened the scope of Union border funding beyond what the 
EBF covered. The new instrument “builds on the capacity-building process developed with 
the assistance of the External Borders Fund […] and extends it to take into account new 
developments” (31).  Notably,  as  highlighted  in  the  2018  interim  evaluation (32)  of  the 

(26) Proposal for a Regulation of the European Parliament and of the Council establishing, as part of the 
Internal  Security  Fund,  the  instrument  for  financial  support  for  external  borders  and  visa,  EUbaR-Lex  - 
52011PC0750 - EN - EUR-Lex 
(27) Preamble to the Horizontal Regulation. 
(28) COMMISSION STAFF WORKING DOCUMENT Interim Evaluation of the Internal Security Fund - 
Borders and Visa 2014-2017 Accompanying the document Report from the Commission to the European 
Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 
on interim evaluation of the Asylum, Migration and Integration Fund and the Internal Security Fund 
(29) Ibid. 
(30)  Interim  Evaluation  of  the  Internal  Security  Fund  -  Borders  and  Visa  2014-2017,  EUR-Lex  - 
52018SC0340 - EN - EUR-Lex 
(31) Preamble to the Horizontal Regulation. 
(32)  COM(2018) 464 final 

15 

 
 
Instrument,  ISF-BV  addressed  a  number  of  needs  that  the  EBF  could  not  meet.  These  
included bolstering the development of the common integrated border management system 
(IBM)  and  enhancing  capacities  for  the  European  Border  Surveillance  System 
(EUROSUR), as well as ensuring the sustainability of large-scale IT systems for borders 
and visas. The EBF had supported initial steps in these areas, but some components, such 
as  advanced  information  systems  and  certain  internal  security  measures  fell  outside  its 
remit. The ISF-BV explicitly set out to fill those gaps, financing new IT initiatives, such 
as  the  Entry-Exit  System  (EES),  the  Registered  Traveller  Programme  (RTP),  and  the 
ongoing operation of second-generation systems like SIS II (Schengen Information System 
II) and the VIS (Visa Information System). It also enabled support for control measures 
within the area of free movement inside Schengen and greater inter-agency cooperation 
among national authorities under an internal security agenda. 

In  sum,  ISF-BV’s  mandate  went  beyond  the  external  border  perimeter  focus  of  EBF, 
recognizing that border security links with domestic security and requiring a more holistic 
approach.  ISF-BV  covers  a  broader  range  of  activities  than  the  EBF,  which  focused 
primarily on border control and visa policy. It enables the Union to support controls within 
the Schengen area and to foster cooperation between agencies operating within Member 
States' territories  –  areas that were not  addressed under the EBF. As the  Commission’s 
proposal  put  it,  the  new  instrument  aimed  “to  support  more  systematically  the  services 
provided by individual Member States in securing the border-free area (‘operating support 
mechanism’),  to  enhance  interagency  cooperation  between  border  and  other  law 
enforcement authorities and to increase the available specialised equipment […] for joint 
operations” (33). This operating support mechanism was a significant innovation of ISF-
BV - it provides full reimbursement of a choice of specific costs (e.g. staffing, maintenance 
or training costs) related to border control and visa management, forming an integral part 
of each national programme. The EBF, by contrast, had more restrictive eligibility and did 
not systematically fund ongoing operational costs of border agencies. By helping countries 
cover such expenditures, ISF-BV reinforced the principle that when a Member State guards 
the Union’s external border or processes visas, it carries out activities in the interest of and 
on behalf of all other Member States, performing a public service for the Union – and thus 
deserves tangible burden-sharing support, as expressed in the strategic priorities within the 
Commission’s proposal (34). 

Comparative insights – funding and solidarity 

In  financial  terms,  the  ISF-BV  represented  a  major  increase  in  resources  and  ambition 
compared  to  the  EBF.  Initially,  EUR  2.76  billion  were  allocated  for  all  management 
modes, reaching a total allocation of EUR 2.9 billion at the end of the programming period. 
Thereof, total allocations to Member State programmes, including national contributions, 
reached EUR 2.42 billion by the end of the implementation period in June 2024, 33% more 
than the amount of its predecessor’s EUR 1.82 billion envelope. This higher funding level 
reflected the broader scope (e.g. expensive IT system rollouts) and the Union’s heightened 
focus  on  internal  security  and  migration  challenges  in  that  period.  The  ISF-BV  also 
adjusted how funds were distributed to enhance solidarity and fairness. For instance, under 
EBF  smaller  Member  States  or  those  with  relatively  low  allocations  struggled  with 
disproportionately high management costs, whereas ISF-BV set a minimum threshold, so 
that each Member State is allocated a more appropriate amount of funding, relative to its 

(33)  Proposal  for  a  REGULATION  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL 
establishing, as part of the Internal Security Fund, the instrument for financial support for external borders 
and visa, EUR-Lex - 52011PC0750 - EN - EUR-Lex 
(34) Ibid. 

16 

 
 
needs,  and it slightly increased the portion of funds for technical  assistance to mitigate 
fixed  costs.  Furthermore,  to  encourage  investments  that  had  seen  limited  uptake  under 
EBF, such as joint  consular cooperation for visa issuance abroad,  ISF-BV introduced a 
higher co-financing rate – up to 90% Union funding for certain national actions – making 
it more attractive for Member States to pursue those collaborative projects (35).  

Overall,  the  design  of  ISF-BV  carried  forward  the  EBF’s  central  objective  of  shared 
responsibility for external border management, but with a more flexible, well-resourced 
and comprehensive toolkit. Recital  (34) of the Regulation  (EU) No 514/2014  explicitly 
acknowledges that in light of the experience gained with the External Borders Fund it is 
considered  appropriate 
the  new  Instrument’s 
introduce  more  flexibility 
implementation. In summary, the transition from EBF to ISF-BV involved a qualitative 
leap in the EU’s approach – streamlining funding structures, expanding policy coverage, 
boosting the available budget, and strengthening mechanisms to support Member States 
on the front line of the Union’s external borders. 

to 

in 

Key points of comparison  

EBF (2007–2013) 

ISF-BV (2014–2020) 

Part of a solidarity-driven 
framework to support 
Schengen external borders, 
with €1.82 billion devoted to 
five core priorities (integrated 
border management, 
EUROSUR development, visa 
processing, IT systems, and 
enforcing common border/visa 
rules). 

One of four separate funds 
under the SOLID programme, 
implemented through annual 
national programmes under 
shared management. 

Policy Context and 
Objectives 

Structure and 
Management 

Scope of Support 

Limited to external border 
control and common visa 
policy, focusing on 
infrastructure, equipment, and 
basic systems at the border 
crossing points. 

Built on EBF’s foundation, continuing 
the goal of a common integrated border 
management system, while extending it 
to new developments in border security 
and visa policy. 

In contrast, ISF-BV was established as 
one of two instruments under the 
Internal Security Fund, a new two-pillar 
structure intended to simplify and 
consolidate home affairs funding. ISF-
BV introduced a single multiannual 
programme per Member State (2014–
2020) instead of yearly programming, 
speeding up the funding process and 
decreasing administrative burden for 
national authorities. 

Broader scope, supporting measures 
within the area of free movement and 
inter-agency cooperation. New priority 
areas under ISF-BV included funding 
cutting-edge IT systems and sustaining 
existing large-scale databases (e.g. SIS 
II, VIS) that the EBF did not fund. ISF-

(35)  Interim  Evaluation  of  the  Internal  Security  Fund  -  Borders  and  Visa  2014-2017,  EUR-Lex  - 
52018SC0340 - EN - EUR-Lex 

17 

 
 
 
BV could also fund operational costs 
like border guard staffing, which were 
generally ineligible under the EBF. 

•  EUR 1.82 billion envelope. 

•  Total allocations to national 

programmes, including national 
contributions, reached EUR 2.42 
billion by the end of the 
implementation period in 2024. 

Funding Level and 
Solidarity 
Mechanisms 

•  No equivalent ongoing cost 

support. 

Issues of equal burden-sharing 

•  Both funds sought to spread 

responsibility fairly for protecting 
the Schengen area, but ISF-BV 
introduced enhanced solidarity 
tools. It offers an operating support 
scheme with full reimbursement of 
certain costs to help frontline 
Member States maintain key 
capabilities. 

•  Minimum national funding 

allocations and higher co-financing 
rates (up to 90%) for strategic 
priorities (such as joint consular 
services). 

Beyond  addressing  its  overarching  needs,  the  ISF-BV  fund  also  aimed  to  address  and 
tackle specific needs and priorities that EBF was unable to fully address, as well as new 
needs  that  emerged  due  to  the  new  policy  developments  and  external  factors  outlined 
above. These needs were identified in the impact assessment accompanying the proposal 
for the Home Affairs Funds in 2014-2020, the Regulation (EU) No 515/2014 establishing 
the ISF-BV, Member States’ annual implementation reports, and further confirmed by the 
stakeholders consulted as part of the mid-term and final evaluation of ISF-BV.  

2.4 

Intervention logic 

The intervention logic shows the overall general, specific and operational objectives, as 
well as the expected results and impacts of the Instrument.  

A detailed intervention logic is provided in Annex II. 

The intervention logic includes the following components. 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Needs: The original needs which the Instrument set out to address are established in the 
preamble to the Regulation and give rise to the Instrument objectives (see section 2.2.1, as 
well as section 4.1.1 on how this will be further developed).  

General objectives: these correspond to the overall objectives of the ISF-BV as expressed 
in its legal basis (Article 3(1) of ISF-BV regulation).  

Specific  objectives:  the  specific  objectives  relate  to  the  two  themes  of  visa  policy  and 
border management covered by the ISF-BV. The specific objectives reflect the intended 
outcomes that are expected through the ISF-BV funding according to Article 3(2) points 
(a)  and  (b)  of  ISF-BV  regulation.  These  are  essentially  the  two  core  policy  areas  the 
Instrument addresses.  

Operational objectives: these are laid down in Article 3 of Regulation (EU) No 515/2014 
paragraph 3 and correspond to the immediate outputs of the ISF-BV, i.e. the various actions 
implemented  by  projects  funded  and  implemented  through  shared,  direct  and  indirect 
management.  Expected outputs can be measured through quantitative indicators that have 
been defined in the annex IV of Regulation (EU) No 515/2014: they mainly relate to the 
number of operations for each type of action.  

Eligible actions: these correspond to the (types of) eligible actions supported through the 
ISF-BV as laid down in Article 4 of ISF-BV regulation.  

Outputs:  The  expected  outputs  are  short-term  results  which  can  be  assessed  through 
quantitative indicators (defined in the Annex IV of ISF-BV regulation).  

Results: The expected intermediate outcomes are typically less easy to quantify but are 
the medium-term intended effects of the intervention. Indicators for expected results for 
each specific objective are listed in the Annex IV of ISF-BV regulation.  

Impact: the impact of the ISF-BV is the contribution of the funding delivered to the policy 
objective (assessed over the long run). 

3  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

Evolving context and needs throughout the implementation of ISF-BV (2014-2020)  

In 2018, the Commission published its interim evaluation of the ISF-BV, taking stock of 
the progress made by the instrument  between 2014 and 2017. It concluded that the overall 
needs identified during the programming stage in 2014 had not changed during the 
Fund’s implementation; rather, it was the volume of issues to be addressed that increased. 
Stakeholders  consulted  as  part  of  this  ex-post  evaluation  (including  the  focus  group  of 
national  authorities,  EU  Agencies  and  International  Organisations)  highlighted  similar 
findings, noting that external events/factors such as the migration crisis or the onset of the 
COVID-19  pandemic  had  happened  against  a  backdrop  of  stretched  capacity,  which 
further reinforced the overarching need for an Union financial mechanism to provide for 
solidarity  and  responsibility  sharing  between  Member  States  and  the  Union  in  the 
management of external borders and visa. 

19 

 
 
 
External factors and policy changes that increased the need for ISF-BV between 2014-
2020  

•  The migration crisis (2014/2015): Conflicts that began in the aftermath of the Arab 
Spring destabilised the Middle East and North Africa (MENA) region, culminating in 
the 2015 migrant crisis when over a million migrants and refugees crossed into Europe, 
representing the largest movement of people into Europe since World War 2. The crisis 
highlighted the need for stronger external border controls. Frontex was reinforced, new 
systems like EUROSUR were enhanced to improve surveillance and coordination, and 
Emergency  Assistance  was  provided  under  ISF-BV  to  reinforce  the  Member  States 
most in need. However, despite these efforts, the crisis exposed significant weaknesses 
in the EU’s ability to maintain effective external border control and the sheer volume 
of arrivals overwhelmed existing systems, leading to gaps in security and processing 
capabilities.  

•  COVID-19 pandemic: Testing and quarantine requirements imposed to mitigate the 
spread of the virus significantly disrupted the movement of people within the EU. For 
instance,  during  the  peak  of  the  pandemic  in  2020,  Schengen  visa  applications 
plummeted  by  83%  compared  to  the  previous  year.  This  drastic  reduction  in  visa 
applications  reflected  the  severe  impact  of  pandemic  restrictions  on  regular  travel 
across Europe. While irregular border  crossings  and the pressure on Member States 
decreased  due  to  travel  restrictions,  they  were  not  eliminated  and  posed  a  dual 
challenge of balancing public health safety with managing migration flows effectively. 
Moreover, the COVID-19 pandemic also resulted in delays in implementing actions 
planned under ISF-BV, which carried on and were considered in the development of 
BMVI and Member States' national programmes. The pandemic underscored the need 
for adaptive border management strategies to respond to evolving health crises while 
maintaining robust security measures and upholding international obligations.  

•  Security Threats, including hybrid threats: The EU experienced several high-profile 
terrorist attacks, including those in Paris (2015), Brussels (2016), and Berlin (2016). 
These attacks highlighted the persistent threat of both jihadist and right-wing terrorism. 
Moreover,  between  2014  and  2020,  organised  crime  groups  continued  to  be  a 
significant and increasing threat, involved in activities such as drug trafficking, human 
trafficking, and money laundering. There was also a notable increase in cyberattacks 
targeting critical infrastructure, financial systems, and government institutions. 

•  Policy changes: Between 2014 and 2020, the Union implemented several significant 
policy changes in the area of border management and visa to address these emerging 
challenges.  These  included,  among  others,  an  amendment  to  the  Schengen  border 
codes in 2017 introducing systematic checks against relevant databases, updates to the 
rules on temporary internal border controls, enhanced border surveillance, including 
the use of advanced technology  and increased cooperation between Member States. 
Frontex  Regulation  was  also  amended  in  2016,  which  saw  the  formalisation  of 
integrated border management (which has since been developed further with the latest 
amendment  in  2019)  with  the  setting  up  of  the  European  Border  and  Coast  Guard 
(comprised  of  Frontex  and  the  EU  countries’  authorities  responsible  for  border 
management). The augmented mandate and tasks were geared towards providing the 
Agency  with  greater  authority  and  resources  to  proactively  manage  borders  and 
contribute  to  search  and  rescue  efforts,  rather  than  being  reliant  on  voluntary 
contributions by the Member States.   

20 

 
Trends in border management and visa between 2015-2020  

The number of irregular migrants entering the Union reached a peak in 2015, driven largely 
by the Syrian civil war and instability in neighbouring regions. Over 1.7 million irregular 
border crossings were detected in 2015 alone. While the number decreased in the following 
years, it remained higher than under EBF. The number of legal migrants also increased 
under the programming period 2014-2020 from 1.6 million in 2013 to 2.3 million in 2020, 
putting additional pressure on Member States’ capacity to manage their external borders.   

Figure 1 - Legal and irregular migration to the EU 

 Source: European Commission, Available at: Statistics on migration to Europe - European Commission  

The main routes for irregular migration also continuously shifted over the years. Initially, 
the Eastern Mediterranean route (Turkey to Greece) was predominant, but later, the Central 
Mediterranean route (Libya to Italy), the Western Mediterranean route (Morocco to Spain) 
and  the  Western  African  route  (to  the  Canary  Islands)  saw  increased  activity.  These 
shifting  migratory  routes  highlighted  the  need  for  a  flexible,  solidarity  Union  financial 
mechanism.  

Figure 2 - Irregular arrivals to the EU - 2008-2024 

Source: Council of the European Union, Available at: Irregular arrivals to the EU - 2008-
2024 - Consilium  

21 

 
  
The  number  of  visa  applications  between  2014  and  2019  remained  high,  with  over  16 
million applications yearly. There was a slight upward trend between 2014 and 2019, but 
it considerably dropped in 2020 as a result of the COVID-19 pandemic and its impact on 
international travel.  

Figure 3 - Schengen Visa Application trends (2014-2023) 

Source: European Commission, Schengen visa, Available at: Overview of Schengen Visa 
Statistics (2014 – 2023)  

3.1  Overall description of the implementation set-up 

The budgetary appropriations for the ISF-BV, as set in the in the ISF-BV regulation 
in  2014,  amounted  to  EUR  2  760  million  (calculated  without  the  potential  additional 
contributions from countries or international organisations for actions undertaken under 
indirect management).  

Under shared management, EUR 1 705 million were planned for operations (including 
funding for national programmes and the Special Transit Scheme in Lithuania), equalling 
61.8% of the total financial envelope.  

For  direct  management,  EUR  264  million  (9.6%  of  the  total  envelope)  were  initially 
allocated  covering  Emergency  Assistance,  Union  Actions  and  Technical  Assistance 
activities at the initiative of the Commission, with at least 30 % of this funding to be used 
for Union Actions.  

Under indirect management, a financial envelope for actions was not included in ISF-BV 
regulation.  

A total of EUR 791 million (28.7% of the total envelope) was set aside for the development 
and  deployment  of  large-scale  IT  systems  supporting  the  management  of  migration, 
European  Travel  Information  and  Authorisation  System  ETIAS,  the  Entry-Exit  System 
(EES), upgrade of Schengen Information System SIS – and was not initially allocated to 
any management mode in the ISF-BV Regulation. The majority of this amount has later 
been implemented under direct management, leading to a more significant role of this 
management mode in terms of budgets. Out of this total amount: 

-  EUR 325.7 million was later distributed as top-ups to national programmes for 

the development of EES and ETIAS, as well as for SIS recast.   

22 

 
  
-  EUR  64  million  was  re-allocated  to  other  programme  activities  (national 
programmes, Union Actions, Emergency Assistance and technical assistance at 
the initiative of the Commission. 

In the end, contributions to the ISF-BV for the period 2014-20 amounted to over EUR 2 
900 million (36) for funding actions channelled through the different management modes, 
as the shown in the figure below. 

Figure 4 - Breakdown of initial EU contributions by management modes, as per the legal base 

Source: Article 5 Regulation (EU) No 515/2014 (37). N.B.: the appropriation for the « Programme for setting 
up IT systems » has not been allocated to a specific management mode at the time of adopting the multi-
annual financial framework. 

Figure 5 - Breakdown of EU contributions by management modes, as of final budget 

Source: SFC2014, DG HOME Data 

The table below presents the planned initial breakdown of EU contributions as set out in 
the legal basis. Amounts relevant for the Schengen associated countries’ programmes were 

(36) Initially, the total allocation for ISF-Borders and Visa (2014-20) was €2.76 billion.  
(37) ISF-BV regulation. 

23 

 
 
 
 
not included in the Regulation, as the international agreements for their participation to the 
programme were adopted later. 

Table 2 - Detailed breakdown of initial EU contributions by management modes, as per the legal 
base 

Management mode 

EU 
(EUR) 

contribution 

As % of total 

Shared management 

1 705 000 000 

61.8 

National programmes 

1 551 000 000  56.2 

Special Transit Scheme 

154 000 000  5.6 

Direct management 

264 000 000 

9.6 

At least 30% of the 
amount for direct 
management 

Union actions 

Emergency Assistance 

Technical assistance 

Indirect management 

Not initially budgeted  - 

Not initially allocated to management modes  791 000 000 

Envelope for setting up IT systems 
supporting the management of migration 
flows across the external borders 

791 000 000 

28.7 

28.7 

TOTAL 

2 760 000 000 

100.0 

Source: Article 5 Regulation (EU) No 515/2014 

3.2  Shared Management 

Altogether, the total allocations to national programmes, including national contributions, 
reached EUR 2 420 million by the end of the implementation period in 2024. This amount 
is broken down by specific objectives as follows: 

Table 3 - Breakdown of national programme allocations by Specific Objective 

SO Code 

Specific 
Objective 
description 

Allocations 
million) 

(EUR 

As % of total 

SO1 – Common visa policy 

Visa policy 

152 923 358.49 

6.3 

SO2  –  Integrated  border 
management 

Borders 

1 617 137 529.81 

SO3 – Operating Support  

Operating Support  432 874 865.85 

66.9 

17.9 

Visa policy 

68 235 902.50  2.8 

Borders 

364 638 963.35  15.1 

SO4 – Technical Assistance 

SO8  –  Special  Transit 
Scheme 

Technical 
assistance  -  visa 
and borders 

Operating  support 
for  Special  Transit 
Scheme (LT) 

69 689 715.28 

2.9 

147 600 000 

6.1 

Total 

2 420 225 469.43 

100.0 

Source: European Commission - SFC2014 data 

24 

 
 
 
 
 
 
 
 
 
 
3.3 

Implementation at the National Programme Level 

In terms of total allocations to national programmes,  Greece (EUR 296 million), Italy 
(EUR 285 million), and Spain (EUR 260 million) received the highest levels of funding 
reflecting their position on the external borders of the EU that are most severely exposed 
to pressures from irregular migration. 

Figure 6 - Total allocations to national programmes (EUR millions) 

Source: European Commission - SCF2014 data 

Of the total budget allocated to National Programmes, EUR 2 071 629 285.04 had been 
committed to concrete operations, and declared eligible expenditure (accounts) amounted 
to EUR 2 264 530 152.32, as of final financial implementation data received from Member 
States in January 2025. 

3.4 

Initial steps in implementation 

The  Interim  Evaluation  of  the  ISF-BV  (2014-2017)  assessed  the  Instrument’s  initial 
performance and identified key achievements as well as areas requiring improvement. It 
found  that  implementation  varied  significantly  across  Member  States,  with  some 
experiencing delays in deploying planned border management infrastructure. Financial and 
administrative tasks were also noted, as high administrative burden and complex funding 
procedures limited accessibility to the Instrument in some cases. The interim evaluation 
emphasised that while the ISF-BV contributed to improving the setup of large -scale IT 
systems and interoperability, further progress was needed to fully integrate national and 
EU-level border management systems. 

One  of  the  key  challenges  highlighted  in  the  interim  evaluation  was  the  slow 
implementation  of  national  programmes,  which  delayed  the  achievement  of  expected 
outcomes.  Administrative  complexity  also  posed  difficulties,  as  different  national  rules 
hindered  joint  projects  between  Member  States,  and  reporting  and  monitoring 
requirements were seen as burdensome. While the Instrument effectively supported border 
control  infrastructure,  IT  systems,  and  training,  its  impact  on  consular  cooperation 
remained limited due to delayed implementation. Additionally, Emergency Assistance was 

25 

 
recognised  as  crucial  for  the  Instrument’s  responsiveness,  yet  its  efficiency  required 
improvement.  The  evaluation  emphasised  the  need  for  simplified  administrative 
procedures, clearer reporting guidelines, and a more structured monitoring framework to 
enhance the ISF-BV’s effectiveness. 

By the end of the programming period, the ISF-BV was expected to have contributed to a 
more secure and resilient Union border management system, with enhanced capacities for 
detecting irregular migration and cross-border threats.  The final  evaluation assesses  the 
extent  to  which  these  expectations  were  met  and  whether  the  ISF-BV  successfully 
addressed the shortcomings identified in the interim evaluation. 

3.5  State of implementation at closure 

In terms of the Instrument effective implementation, several participating countries (38) 
have very high absorption rates (the ratio of declared costs per budget allocations to the 
programme). According to the final budget allocation data received from the Commission, 
Greece,  Norway  and  Hungary  had  absorption  rates  over  100%,  i.e.  committing  to 
operations above initial funding ceilings, using additional national resources to cover the 
expenses.  In  Greece,  for  instance,  due  to  the  exhaustion  of  the  available  budget  for 
Operating Support and the need to continue actions addressing inflexible needs, additional 
funding was provided through national resources (39). Most Member States and associated 
countries  have  absorption  rates  between  80%  and  100%  utilisation  but  Austria, 
Slovenia,  Latvia  and  Luxembourg  have  absorbed  only  60-80%  of  their  allocated 
funds, and Liechtenstein has the lowest absorption rate with only 41%. 

In terms of the Instrument effective implementation, several participating countries (40) 
have very high absorption rates (the ratio of declared costs per budget allocations to the 
programme). According to the final budget allocation data received from the Commission, 
the absorption rate in Greece, Norway and Hungary has reached 100%. They were in 
fact  ‘overbooking’  their  allocations,  i.e.  committing  to  operations  above  initial  funding 
ceilings, using additional national resources to cover the expenses. In Greece, for instance, 
due  to  the  exhaustion  of  the  available  budget  for  Operating  Support  and  the  need  to 
continue  actions  addressing  inflexible  needs,  additional  funding  was  provided  through 
national  resources (41).  Most  Member  States  and  associated  countries  have  absorption 
rates  between  80%  and  100%  utilisation  but  Austria,  Slovenia,  Latvia  and 
Luxembourg have absorbed only 60-80% of their allocated funds, and Liechtenstein 
has the lowest absorption rate with only 41%. 

(38) Through this paper, “participating countries” refers to both EU Member States and Schengen Associated 
Countries participating in ISF-BV. 
(39) Greek Annual Implementation Report (2021.1). 
(40) Through this paper, “participating countries” refers to both EU Member States and Schengen Associated 
Countries participating in ISF-BV. 
(41) Greek Annual Implementation Report (2021.1). 

26 

 
 
Figure 7 - Absorption rates of national programmes on the basis of amounts declared for clearance 
in the final accounts 

Source: European Commission - SCF2014 data (42) 

Further details  on the utilisation  and progress of implementation  of the  ISF-BV budget 
under the shared, direct and indirect management modes are provided in the next sections.: 

4  EVALUATION FINDINGS  

4.1  To what extent was the intervention successful and why?  

4.1.1  Effectiveness 

The assessment of effectiveness evaluates the extent to which the ISF-BV has achieved its 
objectives and provides a basis for judging the role of Union action in driving the observed 
changes. The analysis identifies the extent of shortcomings and the factors contributing to 
the  lack  of  success  or  delay.  Furthermore,  it  examines  the  drivers  and  barriers  to 
achievement and explores their connection to Union intervention. 

How did the Instrument contribute to the achievement of the SO 1? 

The  ISF-BV  contributed  to  the  upgrading  of  consular  infrastructure  and  visa 
issuance practices across Member States and associated countries. It also contributed 

(42) The analysis on allocations reflects the National Programmes’ structure, which consist of the II of Specific 
Objectives (Article 3 of Regulation (EU) 515/2014) into National Objectives, as defined within Article 9 of the 
same Regulation, which address the needs and priorities of the Member States in the areas covered by the 
Regulation in terms of activities to be funded and results to be achieved. The figures above 100 percent for 
Greece, Norway and Hungary correspond to amounts declared in excess to the total allocation in the final 
accounts. Those excess amounts are not reimbursed to the country. 

27 

 
 
 
to  the  implementation of  the  common  visa  policy.  However,  its  role  in  driving  the 
geographical expansion of consular presence was more limited. 

Figure 8 - SO1 components’ allocations & declared accounts 

Source: European Commission - SCF2014 data 

Ensuring  better  consular  presence,  harmonised  practices  in  visa  issuance  and 
strengthening the implementation of the common visa policy 

The  ISF-BV  supported  these  improvements  to  a  large  extent,  as  suggested  by  national 
implementation  reports,  ex-post  evaluations  of  national  programmes,  survey  data,  and 
country case studies. The Instrument was particularly used to modernise consular offices 
through  infrastructure  and  IT  investments.  In  Romania,  for  instance,  the  ISF-BV 
contributed to the reconditioning of 130 consular offices, which, according to the country 
case study, led to better consular coverage and harmonised visa practices and more uniform 
visa processing standards across consular offices, ultimately improving service quality for 
visa  applicants (43).  Similar  renovations  were  reported  in  France,  Hungary,  Malta,  and 
Portugal.  These  physical  upgrades  contributed  to  improved  security,  accessibility,  and 
client experience, aligning with the ISF-BV common performance indicators (44). 

(43) Romania – country case study 
(44) Analysis of the ex-post evaluation reports of the national programmes  

28 

 
 
 
Figure 9 - Number of consular representations provided by Schengen countries (location x 
country covered) (2014 and 2024) 

In parallel to infrastructure upgrades, the Instrument supported the harmonisation of visa 
issuance  practices,  notably  through  training  and  modernisation  of  IT  systems.  Ex-post 
evaluation reports indicate that among the 13 Member States where harmonisation-related 
actions  were  identified,  eight  implemented  training  for  consular  staff.  This  covered 
document security, migration awareness, and Schengen visa rules, to promote consistent 
application of procedures and ensure equal treatment of applicants. 

The  modernisation  of  IT  systems  further  facilitated  the  harmonisation  of  visa 
issuance  practices  across  countries.  The  ISF-BV  funding  enabled  the  deployment  of 
modern  equipment  in  consulates,  the  alignment  of  security  standards  (especially  in 
Member  States  that  had  recently  joined  the  Schengen  Area),  and  provided  technical 
prerequisites for access to Schengen Information Systems. These actions further reinforced 
compliance  with  the Schengen  acquis  and enabled national  systems  to  be interoperable 
with  those  of  Schengen  partners,  ensuring  a  consistent  and  standardised  visa  issuance 
process  across  the  participating  countries.  As  a  positive  side  effect,  ex-post  evaluation 
reports  indicate  that  the  VIS  system,  with  its  application  VIS  Mail,  facilitated  direct 
exchanges  and  consultations  between  consulates  of  different  Member  States  on  visa 
applications.  This  enhanced  both  operational  cooperation  and  the  harmonisation  of 
decision-making,  contributing  to  a  more  coherent  implementation  of  the  common  visa 
policy. Overall, through its support for the modernisation of consular IT infrastructure and 
the rollout of large-scale systems such as VIS, the Instrument played a central role in 
promoting interoperability, consistency, and cooperation among Member States. 

Evidence from country case studies aligns broadly with the findings presented above, while 
also highlighting some differences in implementation across Member States. E.g. in Italy, 
the  Instrument  funded  the  implementation  of  the  Visa  Information  System  (VIS)  and 
broader digitalisation of visa procedures, including the development of a national database 
and the establishment of a centralised consular network.  

Case  studies  also  suggest  that  while  ISF-BV  contributed  to  improved  consular 
infrastructure  and  practices  in  several  countries,  the  depth  and  focus  of  support  – 

29 

 
 
particularly in terms of harmonisation – varied. For instance, Spain confirmed the rollout 
of VIS across most consulates, together with IT improvements and the use of VIS Mail 
functionalities  to  support  consistent  application  of  visa  rules.  Training  and  information 
exchange were also mentioned, though the level of detail was limited. In Norway, the ISF-
BV funded hands-on, practical  training for consular staff, alongside evaluation visits to 
promote good practices. In contrast, the case studies for Poland and Croatia point to more 
partial contributions. While both countries implemented training for consular personnel, 
neither provided detail on whether this supported harmonisation with Schengen standards.  

ISF-BV  played  a  limited  role  in  driving  the  geographical  expansion  of  consular 
coverage, according to both implementation and ex-post evaluation reports. Only a few 
Member States used the Instrument to expand their consular presence. According to the 
ex-post evaluations  and  implementation  reports,  expansion efforts  focused primarily on 
training  and  refurbishing  existing  offices  rather  than  opening  new  ones.  This  was  also 
highlighted  during  the  validation  workshop.  For  example,  in  2022,  only  10  out  of  30 
countries (45) reported actions to enhance consular presence abroad. These actions included 
the  deployment  of  visa  and  document  advisors  or  Schengen  cooperation  officers,  often 
based on bilateral  agreements, rather than the establishment of new consulates. Finland 
was a notable example regarding upgrading  the treatment  of visa applications, with  the 
development of liaison officers along with the establishment of visa application centres to 
support the processing of visa applications.  

An  exploratory  statistical  analysis  under  SO1  showed  a  weak  correlation  between  the 
establishment  of  new  consular  representations  and  ISF-BV  operations,  suggesting  that 
where such developments occurred, they were often independent of Union funding. 

Survey results provide partial triangulation of these findings. Among national authorities 
(55 respondents), 42% stated that ISF-BV contributed to the operational objective of better 
consular coverage and harmonised visa issuance practices either to a very large or large 
extent. A further 14.5% responded "to some extent," 7.3% "to a limited extent," 1.8% "not 
at  all,"  and  34.5%  "I  don’t  know  /  prefer  not  to  answer."  This  view  was  even  stronger 
among  other  stakeholders  (30  respondents),  where  54%  reported  a  large  or  very  large 
contribution, while 10% said "to some extent," 7% "to a limited extent," and 30% selected 
"I don’t know / prefer not to answer." Among beneficiaries (37 respondents), the perceived 
contribution was more muted, with only 22.3% reporting a large or very large contribution, 
11.1% "to some extent," 2.7% "to a limited extent," 8.3% "not at all," and 55.6% selecting 
"I don’t know / not applicable." These results suggest varied perceptions, with stronger 
recognition  among  institutional  actors,  and  limited  visibility  or  awareness  of  consular 
activities among final beneficiaries. 

Survey results also support the contribution of ISF-BV to the common visa policy. Among 
national authorities (55 respondents), 72.8% reported that the ISF-BV contributed either 
to  a  very  large  (27.3%)  or  large  extent  (45.5%).  An  additional  10.9%  indicated  some 
extent, while only 1.8% said to a limited extent and none said “not at all.” The remaining 
14.5% responded “I don’t know / prefer not to answer.” 

Other stakeholders (30 respondents) were similarly positive, with 70% indicating a large 
or very large contribution. Only 7% reported a limited contribution, and 20% were unsure. 
Among beneficiaries (37 respondents), perceptions were more mixed: 33.4% reported a 

(45) 30 ISF BV programmes, including for 26 MS (at the time, EU 28, excepting IE and UK for the 
implementation period) and 4 Schengen Associated Countries (NO, IS, LI, CH). 

30 

 
 
strong  contribution,  11.2%  to  some  or  limited  extent,  5.6%  not  at  all,  and  44.4%  were 
unsure or found the question not applicable. 

Overall,  the  ISF-BV-funded  operations  helped  Member  States  and  Schengen 
Associated Countries to address key infrastructure and system gaps, ensuring more 
consistent,  secure,  and  harmonised  implementation  of  the  common  visa  policy 
through updated and interoperable IT systems. 

Ensuring the application of the Union acquis on borders and visas  

Triangulated  evidence  from  implementation  reports,  ex-post  evaluations,  country  case 
studies, and survey responses indicates that the ISF-BV contributed to the more efficient 
and uniform application of the Union acquis on borders and visas. This contribution 
was  primarily  achieved  through  investments  in  IT  systems,  consular  infrastructure,  and 
targeted training. 

Figure 10 - SO1.NO2 Union Acquis (allocated amounts – EUR million) 

Source: European Commission - SCF2014 data 

Country  case  study  insights  generally  support  the  finding  that  ISF-BV  contributed  to  a 
more uniform application of the Union acquis on borders and visas, particularly through 
IT system upgrades and, to a more limited extent, staff training. The Romania case study 
provides the strongest evidence of acquis compliance, explicitly identifying the application 
of the acquis as a direct outcome of ISF-BV interventions. Romania’s development of the 
national VIS (N-VIS) and readiness for integration with the EU Central VIS clearly aligned 
with  Schengen  requirements.  In  Croatia,  ISF-BV  helped  modernise  IT  systems  and 
consular infrastructure, but the national evaluation highlighted underutilised opportunities 
for acquis-relevant staff training.  

Beyond  IT  investments,  the  ISF-BV  also  supported  actions  that  reinforced  the  correct 
application of EU rules, equal treatment of visa applicants, and consistent interpretation of 
legal  requirements.  Training  activities  -  such  as  those  improving  staff  knowledge  of 
Schengen rules - helped translate the acquis into daily practice. For example, in Estonia, 
training led to the review and adaptation of working instructions for visa processing (46). 
In  Croatia  and  Norway,  specialised  training  for  border  control  staff  and  identity 
verification experts helped ensure compliance with Schengen requirements (47). 0 

(46) Ex-post evaluation report on Estonia’s national programme of ISF 2014-2020. 
(47) Country case studies – Croatia, Norway. 

31 

 
 
 
While the full digitalisation of the Schengen visa process was formally proposed only in 
April 2022 and adopted under Regulation (EU) 2023/2667 (48), earlier ISF-BV support for 
IT system upgrades laid essential foundations for Member States to align with evolving 
acquis  requirements.  These  early  investments  increased  readiness  and  interoperability, 
thereby  easing  the  transition  towards  digital  visa  processing.  Survey  results  partially 
confirm this contribution. Among national authorities (55 respondents), 45.5% indicated 
that  the  ISF-BV  contributed  to  this  objective  to  a  very  large  or  large  extent,  with  20% 
selecting "to some extent," 7.2% indicating a limited or no contribution, and 27.3% stating 
"I don’t know / prefer not to answer." Responses from other stakeholders (30 respondents) 
were  even  more  positive,  with  63%  indicating  a  very  large  or  large  contribution.  In 
contrast, beneficiaries (37 respondents) showed more varied perceptions, with only 30.6% 
reporting a very large or large contribution, 19.4% to some extent, 8.3% not at all, and 
41.7% unsure or not applicable. 

Overall, the combination of training activities and IT modernisation contributed to 
improved procedural coherence, reduced the risk of errors, and supported a more 
uniform  application  of  the  Union  acquis  across  Member  States  and  Schengen 
Associated Countries. 

Cooperation between Member States operating in third countries  

Figure 11 - SO1.NO3 Consular Cooperation and Specific Actions on Consular Cooperation 
(allocated amounts – EUR million) 

Source: European Commission - SCF2014 data 

Evidence from  ex-post evaluation  and DG HOME internal  documents  suggests that the 
ISF-BV was used to promote more structured cooperation between member states 
and  authorities  in  third  countries,  but  the  scale  and  impact  of  this  cooperation 
remains modest. Among 24 countries reviewed, only 10 reported specific actions aimed 

(48)  Regulation  (EU)  2023/2667  of  the  European  Parliament  and  of  the  Council  of  22  November  2023 
amending  Regulations  (EC)  No  767/2008,  (EC)  No  810/2009  and  (EU)  2017/2226  of  the  European 
Parliament  and  of  the  Council,  Council  Regulations  (EC)  No  693/2003  and  (EC)  No  694/2003  and 
Convention implementing the Schengen Agreement, as regards the digitalisation of the visa procedure. 

32 

 
 
 
at  strengthening  cooperation  with  third  countries,  according  to  the  ex-post  evaluation 
reports on national programmes. 

Where  implemented,  the  ISF-BV-funded  activities  mainly  focused  on  capacity-
building and advisory deployments. For example, Austria and the Netherlands deployed 
visa and document advisers to third countries such as Jordan, India, Thailand, and Russia 
(pre-2022) as well as Burundi and São Tomé, in the context of supporting Schengen House 
visa centres (49). It  is  important  to  note, however, that not  all activities cited in  national 
reports were funded exclusively through ISF-BV. For example, while Malta supported the 
training  of  Libyan  authorities  to  disrupt  smuggling  networks  and  improve  border 
management,  this  particular  action  was  financed  through  the  Voluntary  Solidarity 
Mechanism rather than the ISF-BV (50).  

In addition, the deployment of regional coordination centres—within the framework of the 
EUROSUR network – represented another ISF-BV-supported mechanism for enhancing 
cooperation. These supported situational awareness and joint border actions, occasionally 
involving collaboration with third countries. However, such instances were limited and do 
not represent the majority of cases 

Despite the examples of cooperation, the overall scale and impact of these efforts remained 
modest.  According  to  DG  HOME  internal  documents  summarising  the  state  of 
implementation of consular cooperation supported by specific actions, around half of the 
planned projects were either abandoned or underachieved. The main challenges explaining 
such failures in delivery are, e.g., changing political decisions in Rwanda, security matters 
in Libya, or evolving needs in Kosovo. In this specific case, the visa liberalisation made 
the  need  for  consular  development  no  longer  relevant.  In  terms  of  impact,  challenges 
persisted  in  third  countries,  where  visa  applicants  continued  to  face  long  waiting 
periods, as noted in Commission reports on the implementation of Schengen rules 
between 2014 and 2024 (51). The COVID-19 pandemic further constrained cooperation, 
restricting cross-border mobility and hindering the deployment of Union advisers on the 
ground. 

Survey  results  confirmed  the  limited  scope  and  mixed  perceptions  of  this  type  of 
cooperation. Among national authorities (55 respondents), only 29.1% perceived ISF-BV's 
contribution as large or very large, with 18.2% selecting "to some extent," 18.2% reporting 
little or no contribution, and 34.5% stating "I don’t know / prefer not to answer." Among 
other stakeholders (30 respondents), 55% saw a large or very large contribution, while 21% 
indicated some contribution, and 24% were uncertain. Beneficiaries (37 respondents) were 
more divided: 27.8% reported a strong contribution, 13.9% to some extent, 8.3% not at all, 
and 47.2% selected "I don’t know / not applicable”. 

Operating support in SO1 

Operating  support  under  Article  10  of  the  ISF-BV  Regulation  proved  essential  for 
sustaining  visa  systems  in  a  small  group  of  Member  States  that  chose  to  activate  this 
funding mechanism. In those cases, this support enabled continuous operation of national 
infrastructures for consular services. Four countries explicitly referred to operating support 

(49) Ex-post evaluation report on Austria’s national programme of ISF 2014-2020, ex-post evaluation report on the 
Netherlands’ national programme of ISF 2014-2020. 
(50) Ex-post evaluation report on Malta’s national programme of ISF 2014-2020. 
(51) See European Commission, Staff Working Document, report from the commission to the European Parliament 
and the council a smarter visa policy for economic growth, 2014; European Commission, Staff Working 
Document, EU Visa Policy - evaluation of the Visa Code, 2024. 

33 

 
 
under Article 10 as crucial in achieving the common visa policy objective, according to 
the  ex-post  evaluation  reports (52).  Austria,  Cyprus,  Finland,  and  Germany  used  this 
funding  to  sustain  essential  consular  operations  and  visa-processing  systems (53).  For 
instance, Cyprus reports that operating support “co-financed the maintenance of VIS at the 
Ministry of Foreign Affairs, visa sections, and border crossing points”, and even covered 
routine  costs,  such  as  visa  stickers,  consulates  rentals,  and  local  staff  salaries,  thereby 
contributing horizontally to the common visa policy objective (54). In Finland, it has been 
likewise noted that operating support “contributed to the objective of the EU common visa 
policy  by  maintaining  and  safeguarding  the  existing  national  visa  system  and  common 
functionalities in the VIS Central System”, covering the ongoing “costs of maintenance 
and operation of the VIS” (55). This ensured visa systems remained fully functional even 
during periods of fluctuating demand (for instance, during the COVID-19 travel decline, 
when system upkeep had to continue despite fewer applications56). Austria highlights that 
the ISF-BV operating grant (around EUR 3.16 million) enabled the daily operation of its 
VISION and VIS Mail consular IT platforms, which prevented technical downtimes and 
allowed  real-time  data  exchange  between  Schengen  states  –  directly  improving  the 
“efficiency and reliability of the visa process” and helping to “strengthen security within 
the Schengen area” (57). Germany also attributed faster and more customer-friendly visa 
processing to ISF-funded enhancements of the VIS through a set of projects implemented 
as operating support (58). 

How did the Instrument contribute to the achievement of the SO 2? 

Figure 12 - SO2 components’ allocations & declared accounts 

(52) Ex-post evaluations report on national programmes of ISF-BV (2014-2020): Austria, Cyprus, Finland, 
Germany. 
(53) Ibid.  
(54) Ex-post evaluation report on Cyprus’ national programmes of ISF-BV (2014-2020). 
(55) Ex-post evaluation report on Finland’s national programmes of ISF-BV (2014-2020). 
56 Ibid. 
(57) Ex-post evaluation report on Austria’s national programmes of ISF-BV (2014-2020). 
(58) Ex-post evaluation report on Germany’s national programmes of ISF-BV (2014-2020).  

34 

 
 
 
Checks on persons and monitoring of border crossings  

The  ISF-BV  played  an  important  role  in  supporting  Member  States’  efforts  to 
enhance  external  border  management.  Its  contributions  included  co-financing 
infrastructure modernisation, accelerating IT system readiness, expanding biometric 
identity  verification,  and  improving  staff  training.  While  systemic  delays  and 
implementation  challenges  were  present,  the  Fund  clearly  enabled  a  wide  range  of 
national-level improvements that laid the groundwork for more secure and efficient border 
control in the Schengen area. 

Ex-post  evaluation  reports  across  23  countries  show  that  clear  progress  was  made  in 
enhancing external border control and improving the efficiency of border checks, with the 
ISF-BV  playing  an  important  role  in  supporting  these  developments.  Reported 
improvements  include  modernised  infrastructure,  deployment  of  advanced  IT  systems, 
upgraded  surveillance  equipment,  and  enhanced  document  and  identity  verification 
processes. However, the extent of progress varied across countries, with some exceeding 
targets and others facing delays or challenges in assessing effectiveness. While the pace 
and scope of activities varied, especially in IT systems, these differences largely reflect the 
shared Union-wide delays in deploying large-scale systems such as EES and ETIAS. In 
this  context,  the  relevant  benchmark  was  not  full  implementation,  but  national 
preparedness to meet future requirements. 

A major area of progress was the modernisation of border infrastructure, explicitly 
reported in 20 ex-post evaluation reports (59). ISF-BV funds were used to upgrade border 
crossing  points,  surveillance  equipment,  and  checkpoint  facilities,  ensuring  stronger 
external border control, in countries such as Germany, Malta or Norway.  

On the other hand, three countries (Belgium, Spain, and Switzerland) did  not explicitly 
report ISF-BV funded infrastructure investments, instead emphasizing other areas such as 
IT systems and operational measures.  

The implementation of large-scale Union border IT systems - such as SIS, EES, and ETIAS 
- was another strategic focus. Although 14 countries explicitly reported progress in national 
evaluations (60), this figure likely underrepresents actual implementation due to reporting 
limitations. All Member States received dedicated top-up funding for EES and ETIAS, and 
while these systems were not fully operational by 2020, efforts concentrated on achieving 
a high level of technical readiness. 

The introduction of Automated Border Control (ABC) gates was another area where seven 
countries  explicitly  reported  ISF-BV-supported  progress (61).  These  systems  facilitated 
faster and more secure processing at airports and external border checkpoints by reducing 
reliance on manual document checks and enhancing biometric screening. Additionally, at 
least  nine  countries  confirmed  investments  in  biometric  authentication  and  mobile 
verification devices, such as fingerprint and facial  recognition  scanners,  contributing  to 
more effective identity verification at borders (62).  

(59)Austria, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Hungary, Iceland, Italy, Liechtenstein, 
Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Slovakia, Slovenia, Sweden. 
(60) Austria, Czech Republic, Finland, Germany, Hungary, Iceland, Italy, Liechtenstein, Lithuania, Luxembourg, 
Malta, Slovakia, Slovenia, Sweden. 
(61) Estonia, Finland, Germany, Luxembourg, Malta, Slovakia, Switzerland. 
(62)  Belgium, Estonia, Finland, France, Germany, Hungary, Lithuania, Slovakia, Sweden. 

35 

 
 
Beyond  infrastructure  and  technology,  ISF-BV  also  contributed  to  border  personnel 
training in at least seven countries, ensuring that border management staff were equipped 
to handle risk analysis, document authentication, and biometric verification procedures (63). 
Notably, Cyprus implemented an extensive training  programme for border guards, with 
3,426 training courses focused on screening and debriefing techniques. However, in some 
cases, training-related indicators showed low implementation, such as in Spain, where the 
number of trained staff was below expectations. 

While system-wide delays in IT readiness were reported across Member States - especially 
concerning EES and ETIAS - these delays were structural and affected the entire Union. 
They  should  be  understood  in  the  context  of  long-term  system  phasing,  rather  than  as 
indicators of poor national performance. 

Survey  results  partly  confirm  the  positive  picture,  although  some  stakeholders 
presented  relatively  high  levels  of  uncertainty.  Among  national  authorities  (55 
respondents), 50.9% indicated that ISF-BV contributed to this objective to a very large or 
large extent. However, a further 14.5% saw only a limited or some contribution, and nearly 
a  third  (30.9%)  responded  “I  don’t  know  /  prefer  not  to  answer.”  Similarly,  among 
beneficiaries  (37  respondents),  only  27%  perceived  a  large  or  very  large  contribution, 
while  16.2%  saw  no  contribution  and  45.9%  were  uncertain  or  found  the  question  not 
applicable. Views from other stakeholders (30 respondents) were more positive, with 60% 
perceiving a strong contribution, though 20% were unsure. 

Country case studies reinforce the conclusion that ISF-BV contributed meaningfully 
to  the  effectiveness  of  checks  on  persons  and  border  monitoring.  For  instance,  in 
Croatia, the Fund enabled a combination of upgraded infrastructure, investments in SIS II 
and EUROSUR, enhanced monitoring of the green border, and training of police officers 
in line with Schengen standards (64). In Italy, ISF-BV supported targeted training for end-
users  and  pilots,  improving  the  efficiency  of  border  control  operations,  and  funded  the 
acquisition  of  document  fraud  detection  equipment,  directly  enhancing  the  quality  of 
identity  checks (65).  Norway  provides  a  particularly  illustrative  case,  where  ISF-BV 
investments in mobile digitised border check systems - referred to by national authorities 
as a transformative change - enabled automated identity verification at sea borders using 
biometric tools linked to international databases (66).  

The control of the Union external borders is the key to ensure the absence of controls at 
the internal borders.  Thus, all measures improving the management of the EU external 
borders  contribute  to  freedom  of  movement  in  the  Schengen  area,  and  thereby  to  the 
absence of controls at the internal borders, In line with recital 6 of the Schengen Borders 
Code “Border control is  in the interest not only of the Member State at whose external 
borders it is  carried out  but  of all Member States  which have abolished  internal  border 
control”. In addition to strengthening controls at the external borders, the analysis of ex-
post  evaluations  of  the  national  programmes  reveals  general  observations  on  ISF-BV-
funded activities that were indirectly linked to sustaining the absence of controls at internal 
borders. While such measures were not among the direct aims of SO-2, several countries 
reported actions that supported the Schengen acquis more generally. 

(63) Cyprus, Czech Republic, Finland, Hungary, Italy, Norway, Slovenia. 
(64) Country case study – Croatia. 
(65) Country case study – Italy. 
(66) Country case study – Norway. 

36 

 
 
Integrated management system for external borders 

Overall, the ISF-BV played a central role in supporting both the technical and structural 
foundations  of integrated external  border management, while also  enabling broader  EU 
cooperation mechanisms., as evidenced in national evaluations and stakeholder feedback. 
While 19 ex-post evaluations of the national programmes (67) reported ISF-BV supported 
measures  that  contributed  to  the  goals  of  integrated  border  management,  only  four 
countries (68) did not provide evidence of relevant ISF-BV funded progress in this area.  

Ex-post  evaluations  confirm  that  most  Member  States  reported  progress  toward 
establishing an integrated management system for external borders, with support from the 
ISF-BV.  These  included  coordinated  implementation  of  large-scale  and  interoperable 
systems  such  as  SIS,  EES,  and  ETIAS;  inter-agency  collaboration  between  border, 
customs, asylum, and law enforcement authorities; and internal flanking measures such as 
identity  management  and  document  security.  However,  only  a  nine  countries (69)  made 
explicit  references  to  the  principles  or  responsibility  in  this  context,  linking  their  ISF-
funded actions to the broader EU objective of shared border management responsibility.  

Survey findings broadly confirm that national authorities and other stakeholders perceived 
these interventions as meaningful contributions to integrated border management. Among 
national authorities, 56.3% reported that ISF-BV contributed to a large or very large extent 
to reinforcing external border checks and inter-agency cooperation, while 50.9% reported 
similarly  for  internal  flanking  measures  including  document  security  and  identity 
management.  Perceived  contribution  was  somewhat  lower  (43.6%)  in  the  area  of 
combating  cross-border  crime  related  to  border  movements  (e.g.  smuggling  and 
trafficking).  This  pattern  suggests  that  the  Fund  was  most  visible  and  impactful  in 
supporting the core operational and technical dimensions of border management. 

Among  other  stakeholders,  perceived  contribution  was  strongest  in  relation  to  flanking 
measures (66% reporting a large or very large extent), followed closely by inter-agency 
coordination  and  border  control  (60%)  and  crime  prevention  (66%).  Responses  from 
beneficiaries were more cautious across all dimensions: between 24% and 33% reported a 
large or very large contribution, while nearly half selected “I don’t know / not applicable,” 
indicating limited visibility of these measures at the end-user level. 

Further advancements were made in the maintenance and advancing surveillance and ICT 
systems for border control, improving the accuracy of border management through up-to-
date field data. Some of these systems were particularly innovative, as demonstrated by 
the case study undertaken in Italy. Maritime border surveillance was improved through the 
development  and  implementation  of  a  new  automated  information  system  designed  to 
provide "near real-time" updates to the National Situation Picture.  

The positive impact  of these investments  is  aligned with the findings of an exploratory 
regression analysis carried out for this evaluation which points to a statistically significant 
association between ISF-BV expenditure under SO-2 and increased detections of persons 
using fraudulent travel documents detected at the border crossing point, holding victims of 
trafficking in human beings, and total uniform visas issued constant after controlling for 

(67) Austria, Belgium, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Hungary, Iceland, Italy, 
Liechtenstein, Lithuania, Malta, Netherlands, Slovakia, Slovenia, Sweden, Switzerland. 
(68) Spain, Poland, Italy, Ireland. 
(69) Austria, Bulgaria, Czech Republic, Finland, Liechtenstein, Lithuania, Malta, Sweden, Switzerland. 

37 

 
 
key contextual variables (70). Statistically, the model used provides strong evidence that 
financial expenditure is positively associated with the dependent variable. In other words, 
changes in financial expenditure levels have a reliable, non-random effect on the outcome. 
Although the scale of impact is tiny per unit, it could accumulate over large changes, thus 
higher investment. However, this finding should be interpreted with caution due to data 
quality and availability limitations. 

According  to  the  ex-post  evaluation  reports,  a  key  area  of  development  was  the 
integration  and  modernisation  of  EU-wide  IT  systems,  particularly  the  Schengen 
Information System (SIS II), the Entry-Exit System (EES), and the European Travel 
Information and Authorisation System (ETIAS). While the full implementation of EES 
and  ETIAS  was  postponed  at  EU  level,  all  Member  States  were  required  to  take 
preparatory steps and develop national components under ISF-BV. At least 19 countries 
explicitly  reported  ISF-supported  enhancements  to  these  systems,  ensuring  improved 
border security, traveller verification, and international data exchange (71). Similarly, six 
countries  reported  investments  in  systems  such  as  the  Visa  Information  System  (VIS), 
European  Dactyloscopy  (EURODAC),  and  European  Criminal  Records  Information 
System  for  Third-Country  Nationals  (ECRIS-TCN) (72).  While  some,  such  as  Slovakia, 
invested in national components like N-VIS, others, including the Netherlands and Malta, 
allocated ISF funding for technical preparations and integration with EU-wide systems, 
thereby strengthening border management interoperability. 

Survey  results  align  with  this  overall  positive  assessment.  Among  national  authorities, 
72.8%  of  respondents  stated  that  ISF-BV  contributed  to  setting  up  and  operating  IT 
systems,  communication infrastructure,  and border surveillance equipment  to  a large or 
very large extent, with 0% reporting no contribution. Similarly, 70% of other stakeholders 
selected  a  large  or  very  large  extent,  while  only  3%  responded  negatively.  Among 
beneficiaries, 33.4% perceived a large or very large contribution, 5.6% responded “not at 
all”, and 44.4% selected “I don’t know / not applicable”. This disparity suggests that while 
infrastructure  investments  were  substantial,  they  may  have  been  less  visible  to 
beneficiaries not directly involved in border operations. 

Application of the Union's acquis on border management 

Overall, ISF-BV played a pivotal role in harmonizing border management practices 
across Member States, facilitating the adoption of EU-wide IT systems and training 
programmes, ultimately strengthening compliance with Union border management 
standards. the Fund contributed to aligning national border management systems with the 
evolving  legal  and  technical  requirements  of  the  Union’s  acquis.  In  their  ex  post 

(70) The model concludes that for each euro spent into the ISF-BV programme, the number of detections of 
fraudulent documents increase by 3.915. The necessary euro amount to be inputted in order to reach the 
detection of one person is 255,427.00 euro, holding other variables constant. However, this amount is not 
spent only on infrastructure related to detection, but also on trainings, fleet for irregular border crossings and 
coordination  centres.  The  most  important  finding  regarding  this  predictor  is  that  effect  of  the  ISF-BV 
investments is positive and statistically significant. The t-value is  2.3990 and the p-value is approximately 
0.0184779, which is significant at a 5% level. (Preparatory study for the evaluation, annex II.11). 
(71) Austria, Belgium, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Hungary, Iceland, Italy, 
Liechtenstein, Lithuania, Malta, the Netherlands, Slovakia, Slovenia, Sweden, Switzerland. 
(72) Cyprus, Finland, Lithuania, Luxembourg, Malta, the Netherlands. 

38 

 
 
evaluations,  18  participating  countries  explicitly  reported  progress  this  regard,  with  the 
Instrument playing a crucial role in this process (73). 

A key area of progress was the implementation of Schengen-related IT systems, which 
serve  as  essential  components  of  the  Union’s  legal  framework  for  border  management. 
Together, they support interoperability, facilitate real-time data exchange, and strengthen 
risk-based  control  procedures  at  the  Union  external  borders.  At  least  19  countries  have 
successfully  integrated  these  systems  to  enhance  compliance  with  EU  regulations (74). 
These  evaluations  of  the  national  programmes  highlight  that  ISF-BV  support  enabled 
countries to meet obligations related to the operational rollout of these systems, follow up 
on  Schengen  evaluation  recommendations,  and  align  with  European  Integrated  Border 
Management strategies. For instance, Slovakia and Slovenia used ISF-BV to implement 
Schengen recommendations and prepare for EES and ETIAS. Similarly, Italy modernised 
national  infrastructure  to  support  the  Schengen  server  room  and  standardised  entry 
systems. 

Survey responses support these findings. Among national authorities, 45.5% reported that 
ISF-BV contributed to the application of the Union’s acquis on borders and visas to a large 
or very large extent. Among other stakeholders, this figure rose to 63%. In contrast, only 
30.6% of beneficiaries reported a similar level of contribution, and 41.7% selected “I don’t 
know / not applicable” indicating more limited awareness of acquis-related activities at the 
end-user level. 

Training  and  capacity-building  initiatives  were  another  important  mechanism  for 
strengthening the application of the Union’s acquis in at least eight countries (75). Cyprus, 
Estonia, Finland, Germany, and Hungary used ISF-BV funding to train border guards and 
police  officers  on  EU  regulations,  document  verification,  and  risk  assessment 
techniques (76). Norway’s training programmes led to measurable improvements in staff 
competence, reinforcing EU standards in sea border control (77). 

Despite  this  progress,  challenges  in  full  implementation  were  noted.  Belgium,  Poland, 
Spain,  Switzerland,  and  the  Netherlands  either  did  not  explicitly  mention  progress  in 
applying the Union’s acquis or faced challenges in measuring ISF-BV impact. Switzerland 
maintained  compliance  with  Schengen  rules  but  did  not  attribute  any  ISF-BV-funded 
projects to acquis-related progress (78).  

Situational awareness at the external borders 

The  ISF-BV  contributed  substantially  to  reinforcing  situational  awareness  and 
reaction  capabilities  at  the  external  borders  by  supporting  the  modernisation  of 
border  control  processes,  the  acquisition  of  advanced  surveillance  and  ICT 
equipment,  and  the  establishment  of  interconnected  data  systems  across  Member 
States. Evidence from implementation reports, ex-post evaluation reports, survey data and 

(73) Austria, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Hungary, Iceland, Italy, Liechtenstein, 
Lithuania, Luxembourg, Malta, Norway, Slovakia, Slovenia, Sweden. 
(74) Austria, Belgium, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Hungary, Iceland, Italy, 
Liechtenstein, Lithuania, Malta, Netherlands, Slovakia, Slovenia, Sweden, Switzerland. 
(75) Cyprus, Czech Republic, Estonia, Finland, Germany, Hungary, Luxembourg, Norway. 
(76) Cyprus, Estonia, Finland, Germany, Hungary. 
(77) Norway. 
(78) Belgium, Netherlands, Poland, Spain, Switzerland. 

39 

 
 
case  studies  confirm  that  the  Instrument  supported  both  foundational  and  innovative 
actions in this regard. 

A key area of progress, as identified through the analysis of annual implementation reports, 
case  studies,  and  ex-post  evaluation  reports,  was  the  modernisation  of  border  control 
infrastructure and equipment, which enabled the digital and real-time registration of data 
at  border  crossing  points.  For  instance,  in  Norway  -  which  faces  the  challenge  of 
monitoring  an  extensive  and  remote  maritime  border  -  ISF-BV  funding  supported  the 
procurement  of  mobile  equipment  that  enables  automated  identity  and  travel  document 
checks,  linked  to  both  national  and  international  databases  (e.g.  Interpol).  These 
technological upgrades significantly improved Norway’s ability to monitor border activity 
and respond rapidly to irregular movements, even in remote locations. 

The Instrument also supported Member States in acquiring a broad range of surveillance 
technologies, as evidenced by the analysis of national inspection reports. These included 
cameras, mobile units, and automated systems for land, air, and sea monitoring. In Sweden, 
for example, the ISF-BV supported the introduction of automated license plate recognition 
systems. Such tools improved the quality and timeliness of border-related data, enabling 
faster and more informed operational responses. 

Moreover, evidence from the ex-post evaluations confirms that 22 countries progressed in 
reinforcing  situational  awareness  and  enhancing  reaction  capabilities  at  the  external 
borders, with strong support from the ISF-BV. A wide range of actions was implemented, 
including  the  development  of  EUROSUR  National  Coordination  Centres  (e.g.  Austria, 
Cyprus,  Finland,  Slovakia),  acquisition  of  surveillance  equipment  such  as  thermal 
cameras,  drones,  mobile  units  (e.g.  Bulgaria,  France,  Slovakia),  and  integration  of  risk 
analysis tools and situational picture systems (e.g. Czech Republic, Finland, Sweden,). The 
Instrument  also  financed  border  patrol  vessels,  aircraft,  and  mobile  units  to  enhance 
operational  response  in  countries  such  as  France,  Malta,  and  the  Netherlands.  Ex-post 
evaluation  reports  explicitly  linked  ISF-funded  investments  to  improved  real-time 
monitoring,  cross-border  coordination,  and  faster  incident  response.  For  instance, 
Germany  and  Lithuania  connected  national  centres  and  surveillance  systems  to 
EUROSUR, improving data flow and regional  coordination. Hungary and Luxembourg 
improved detection and preparedness through Common Integrated Risk Analysis Model 
(CIRAM) (79)and traveller pre-registration systems. 

This evidence is further supported by findings from country case studies. In Romania, ISF-
BV  funding  supported  the  development  of  regional  coordination  centres  linked  to 
EUROSUR, enhancing information sharing and real-time monitoring. Operating support 
also helped Romania maintain  and upgrade surveillance and  ICT systems, ensuring the 
continuity  and  reliability  of  critical  capabilities.  In  Spain,  ISF-BV  contributed  to  the 
expansion of EUROSUR and other IT frameworks, which stakeholders identified as key 
to shaping a more integrated approach to border management. Emergency Assistance 

Survey results partially triangulate these findings. Among national authorities, 47.2% of 
respondents indicated that ISF-BV contributed to reinforcing situational awareness at the 
external borders and the reaction capabilities of Member States to a large or very large 
extent, while only 1.8% responded “not at all.” Among other stakeholders, 56% reported 
a large or very large contribution, and no respondents selected “not at all.”  

(79) The objective of the Common Integrated Risk Analysis Model (CIRAM) is to provide a conceptual model 
to assist Frontex and EU and Schengen countries in the preparation of risk analyses. 

40 

 
 
Emergency situations requiring urgent action at external borders and the contribution 
of Emergency Assistance  

Between  2014  and  2020,  Emergency  Assistance  under  the  ISF-BV  was  mobilised  to 
support swift and targeted responses to migration and border management crises. EMAS 
was most heavily used during the 2015–2017 period in response to high irregular migration 
flows, particularly following the outbreak of the war in Syria. During this time, between 
18  and  23  EMAS-funded  projects  were  included  annually  in  the  Commission's  Annual 
Work  Programmes  (AWPs).  As  migration  pressures  subsided,  the  number  of  EMAS 
projects  decreased  to  between  2  and  6  per  year  from  2018  to  2020.  Over  the  full 
programming  period,  80  EMAS  projects  were  launched,  representing  a  total  EU 
commitment of EUR 472 million. By the end of 2022, all projects had been concluded. 
Pre-financing arrangements led to relatively high absorption rates early on, and by the end 
of the period, around EUR 415 million had been disbursed — corresponding to an overall 
absorption  rate  of  87.9%.  Emergency  Assistance  was  channelled  to  11  Member  State 
authorities, as well as to two international organisations (IOM and UNHCR) and two EU 
Agencies (EUAA and EUROPOL). 

Figure 13 - Commitments and financial implementation of EMAS by year (EUR million) 

Source: DG HOME data 

41 

 
 
Figure 14 - EMAS’ main operational scope across MS 

Source: DG HOME data 

Emergency Assistance under the Instrument contributed to crisis management in certain 
Member States, but its role remained limited across the EU, with most ISF-BV funding 
allocated to long-term border security investments rather than urgent emergency responses. 

While Emergency Assistance played a significant role in EU crisis response, analysis of 
national  ex-post  evaluations  found  explicit  insights  on  its  effectiveness  in  only  five 
countries.  These  cases  point  to  EMAS’s  added  value  as  a  flexible  and  rapidly 
deployable  tool,  although  a  broader  assessment  of  its  effectiveness  across  all 
beneficiaries would require more systematic reporting in national evaluations. This 
does not suggest that EMAS was underused across the Union. It rather reflects the fact that 
most  national  evaluation  reports  did  not  provide  relevant  information  on  Emergency 
Assistance. Where such information was included - notably in Greece, Italy, and Bulgaria 
-  EMAS-funded  interventions  were  described  as  instrumental  in  reinforcing  national 
border  management  infrastructure,  scaling  up  operational  capacity,  and  responding  to 
acute migration pressures (80).  

Country case studies provide concrete examples of how Emergency Assistance contributed 
to effective crisis response in Member States where it was activated. In Greece, EMAS 
was described by beneficiaries as the most successful component of the ISF-BV, enabling 
authorities to respond swiftly during the 2015–2016 migration crisis by covering urgent 
operational  and  running  costs (81).  At  the  same  time,  according  to  the  same  case  study, 
Commission stakeholders cautioned that some EMAS-funded actions may have addressed 
structural needs rather than short-term emergencies (82).. In Spain, EMAS helped bridge 
the gap before national programme funding became available, facilitating urgent actions 
at the start of the programming period (83). 

(80) Ex-post evaluation of the national programmes – Grece, Italy Bulgaria. 
(81) Country case study – Greece. 
(82) Ibid. 
(83) Country case study – Spain.  

42 

 
 
 
Conversely,  most  Member  States  did  not  report  ISF-BV-funded  emergency  actions, 
indicating  that  either  no  Emergency  Assistance  was  required,  or  alternative  funding 
sources were used. Luxembourg acknowledged the existence of EMAS mechanisms but 
stated  that  they  were  not  activated  during  the  evaluated  period.  While  Emergency 
Assistance  under  the  ISF-BV  was  not  widely  covered  in  national  ex-post  evaluations, 
available  qualitative  evidence  confirms  that  in  the  Member  States  where  it  was  used, 
EMAS  delivered  timely  and  targeted  support  to  strengthen  border  management  and 
migration response capacity. However, the overall assessment of its contribution across 
the EU remains constrained by the fact that many Member States either did not request 
EMAS or addressed emergency needs through other funding instruments. 

Operating support in SO2 

Operating  support  under  Article  10  of  the  ISF-BV  played  an  important  role  in 
maintaining the functionality of border control infrastructure and systems, however 
evidence for its effectiveness is available for only a limited number of countries. This 
form  of  funding  helped  cover  essential  recurring  costs  –  such  as  staffing,  system 
maintenance, and operational expenses, as suggested by ex-post evaluations of the national 
programmes, survey data, and country case studies. While not all Member States made use 
of this funding tool - often relying instead on national budgets or other EU instruments - 
those that did reported clear operational benefits.  

Analysis of national ex-post evaluation reports highlights that operating support was  an 
effective instrument for sustaining core border security activities in a limited number of 
Member States. All countries that applied operating support for visa or border management 
reported  positive  outcomes.  Furthermore,  operating  support  under  the  ISF-BV  allowed 
countries  to  “ensure  the  operational  readiness”  of  key  assets  and  thereby  “significantly 
contributed” to the progress made in border security and management (84). Four countries 
(Cyprus, Finland, Germany, Hungary) made extensive use of operating support to ensure 
the continuity and effectiveness of border control operations, by covering ongoing costs 
that go beyond discrete projects. Germany stands out for having allocated a large share of 
its  ISF-BV  programme  to  operating  support:  17  projects  related  to  border  management 
were “classified under operating support […] to support tasks to ensure the operational 
readiness of IT systems, the maritime fleet and border crossing infrastructure”, making up 
roughly  49%  of  border-management  projects  and  45%  of  the  funding  (over  EUR  23.5 
million)  in  Germany’s  programme (85).  This  operating  support  “made  a  significant 
contribution”  to  Germany’s  achievements  under  SO2 (86).  In  particular,  it  enabled  the 
implementation  of  automated  border  checks  via  the  EasyPASS  e-gates  at  airports  and 
financed the purchase and maintenance of necessary equipment  and supplies for border 
control and surveillance on a large scale (87).  

Finland provides another illustrative example of operating support contributing to border 
management goals.  Finland’s ISF programme treated operating support as an important 
tool  to  meet  “compulsory  costs  of  border  control  and  checks.  Moreover,  Finland  used 
operating  support  to  cover  staffing  and  maintenance  costs  for  its  EUROSUR  NCC (88). 
Cyprus similarly notes that a portion of its programme’s operating support was dedicated 

(84) Ex-post national evaluation Germany. 
(85) Ex-post evaluation report for Germany. 
(86) Ibid. 
(87) Ibid. 
(88) Ibid. 

43 

 
 
to maintenance of the national SIS/SIRENE system, including regular training for system 
users and purchase of software licences needed for its operation (89).  

These findings are supported by three national case studies. In Romania, operating support 
was  described  as  having  “significantly  contributed”  to  achieving  SO2  by  ensuring  the 
continuous  operation  of  surveillance  and  ICT  systems (90).  Croatia  reported  similar 
benefits,  using  the  Instrument  to  cover  operational  and  maintenance  costs  for  border 
surveillance (91). In Greece, operating support was quickly absorbed in the early years of 
the  programme  and  was  described  as  critical  for  sustaining  border  operations  during  a 
period of high  migratory pressure (92). However, the premature depletion of these funds 
later constrained the country’s ability to maintain that capacity. 

Survey data confirms that, among those familiar with the mechanism, operating support 
was viewed as an effective tool. Among national authorities, 63% reported that it helped 
border  and  visa  management  to  a  large  or  very  large  extent,  while  just  6%  found  its 
contribution  limited  or  non-existent.  Other  stakeholder  views  were  even  more  positive: 
77% reported a large or very large contribution.  

4.1.2  Efficiency 

Were the general objectives of the Instrument achieved at reasonable cost? 

Evidence of good practices in public procurement, cost control, and risk assessments 
indicates  that  some  Member  States  have  adopted  mechanisms  to  promote  cost-
effectiveness.  However,  the  available  information  does  not  provide  sufficient  basis  to 
determine  whether  these  practices  have  been  systematically  applied  across  all  Member 
States. Additionally, a series of factors influenced the efficiency of the interventions. 
Challenges such as delays in projects’ implementation caused by COVID-19, price surges, 
and administrative workload have impacted efficiency. The efficiency analysis shows that 
some countries (top-performing) have achieved substantial outcomes at low costs, while 
mid-tier and low performers varied in efficiency.   

Based on the targeted surveys conducted, the overall perception of the stakeholders is 
that the ISF-BV operations have been cost-effective. Over 70% of the consulted national 
authorities (93) acknowledged that the ISF-BV operations, especially those included in the 
national programmes, achieved their results at a reasonable cost. The survey targeting ISF-
BV beneficiaries (94) indicates a similar perception, although the limited number of answers 
to  this  survey (95)  does  not  allow  us  to  draw  a  generalised  conclusion.  Also,  while  the 
feedback from national authorities and beneficiaries is largely positive, it is important to 
consider that these perspectives may be influenced by their roles and experiences. National 
authorities, being closely involved in the implementation, may have a favourable view of 

(89) Ex-poste valuation report for Cyprus. 
(90) Romania – country case study. 
(91) Croatia – country case study. 
(92) Greece – country case study. 
(93) Targeted survey for National Authorities, Question 18: “To what extent do you consider the effects of the 
operations financed by the following components of the ISF-BV Instrument were achieved at a reasonable cost?”, 
53 respondents. 
(94) Targeted survey for beneficiaries, Question 15: “To what extent do you consider the effects of the operation(s) 
you implemented under the ISF-BV were achieved at a reasonable cost?”, 36 respondents. 
(95) 36 answers received. However, the limitation of the targeted survey is represented by the fact that the entire 
population targeted for the survey cannot be estimated, considering the survey for beneficiaries was distributed via 
National Authorities.  

44 

 
 
the outcomes. Similarly, beneficiaries, who directly benefit from the funding, might also 
perceive the results positively. 

Mechanisms to ensure cost-effectiveness have been implemented across the Member 
States, although the available information does not provide a comprehensive overview or 
a  systematic  use  of  cost-effectiveness  mechanisms  across  the  Member  States.  Insights 
drawn  from  the  desk  research  and  case  studies  highlight  that  in  some  cases  the  public 
procurement ensured the cost-effectiveness in the execution of projects and achieving the 
best  value  for  money.  For  example,  the  national  evaluation  of  Cyprus  specifically 
highlighted that public tendering for equipment supplies and infrastructure improvement 
ensured competitive pricing at market standards.  

The review of the interim national evaluations reveals good practices implemented by the 
Member States to foster efficiency in implementation, such as rigorous cost control, as 
detailed  out  in  Hungary's  approach  to  financial  oversight.  Comprehensive  risk 
assessment  was  a  key  strategy  in  Finland,  where  the  RA  conducted  detailed  economic 
evaluations  and  risk  assessments  for  each  project  before  granting  funds.  This  proactive 
approach allowed for the identification and mitigation of potential risks early in the project 
lifecycle.  Lean  project  management  was  conducted  in  Estonia,  where  projects  were 
managed  by  small  teams,  typically  1-2  persons.  This  approach  kept  personnel  costs 
minimal,  allowing  more  financial  resources  to  be  allocated  to  core  project  activities, 
ensuring efficient goal achievement and minimising administrative overheads.  

Moreover, the set-up of the ISF-BV instrument was designed in such a way that it allowed 
the  Member  States  to  adjust  funding  allocations  to  adapt  to  new  challenges  and 
requirements.  Apart  from  ensuring  the  relevance  of  the  programme,  this  was  also 
instrumental for ensuring efficiency in the implementation of the Instrument.  

The evaluation has also incorporated a cost-benefit analysis. This analysis, triangulated 
with other sources, provides a comprehensive perspective on both the cost efficiency and 
the benefits of the implemented interventions.  

With regard to the costs and benefits, a systematic methodology was applied (96) in order 
to  identify,  map  and  assess  the  costs  and  benefits  resulting  from  the  implementation, 
considering different types of stakeholders. Given the data limitations (97), the cost-benefit 
assessment focused on financial inputs (expenditures and absorption rate) while, for the 
outputs,  the  common  indicators  were  considered  the  best  possible  proxy  to  assess  the 
achieved results of the Instrument. Considering all the limitations of this analysis, these 
results should not be used to identify which types of projects are more cost-effective. 

(96) As a starting point, we mapped potential costs incurred by various stakeholders, collected relevant data 
via desk research and targeted consultations, and considered also financial data. The costs identified were 
categorised  by  stakeholder  type.  For  National  Authorities,  costs  included  financial  allocations,  technical 
assistance,  and  human  resources,  with 
indicators  derived  from  National  Programmes,  Annual 
Implementation Reports, and instrument monitoring data. Based on desk research and targeted consultation, 
beneficiaries  faced  administrative  and  compliance  costs,  facing  administrative  burdens.  However,  costs 
related to the number of FTEs deployed by the different stakeholders, as well as administrative burden have 
not been possible to monetise due to limited information. Therefore, the analysis we performed focuses on 
the financial costs, as further detailed below in this section and in Annex V.  
The  identification,  mapping,  and  assessment  of  benefits  followed  the  same  methodological  steps. 
Considering  the  Instrument’s  level  of  implementation,  the  analysis  of  benefits  focused  on  the  common 
indicators, as detailed in Annex V. 
(97) Costs related to the number of FTEs deployed by the different stakeholders, as well as administrative 
burden have not been possible to monetise due to limited information. Therefore, the analysis we performed 
focuses on the financial costs. 

45 

 
 
Instead, they should underline in which areas of intervention Member States have 
difficulties  in  selecting  cost-effective  projects.  This  is  because  the  types  of  projects 
funded reflect the specific needs of each Member State. To conduct the efficiency analysis, 
addressing also the limitations found, a two-step approach was applied (98): 

The first step consisted in identifying those Member States that, based on the available 
data, achieved the best results compared to financial resources spent and rank them 
according to top mid and low performers considering these variables.  

The second step aimed to identify patterns (i.e., types of projects) that could explain the 
results obtained under the first step.  

A short description of the approach used is presented below: 

Text Box 1. Description of the approach used for cost- benefits analysis 
For the first step, we designed an efficiency scoring system based on the following formula: 

𝐸𝑓𝑓𝑖𝑐𝑖𝑒𝑛𝑐𝑦 𝑆𝑐𝑜𝑟𝑒 =

𝑃𝑒𝑟𝑓𝑜𝑟𝑚𝑎𝑛𝑐𝑒 𝑆𝑐𝑜𝑟𝑒 × 𝐴𝑏𝑠𝑜𝑟𝑝𝑡𝑖𝑜𝑛 𝑅𝑎𝑡𝑒
𝐸𝑥𝑝𝑒𝑛𝑑𝑖𝑡𝑢𝑟𝑒𝑠

This  efficiency  score  was  calculated  based  on  the  achievement  percentage  of  the  a  number  of  output 
indicators included in the evaluation and monitoring framework. The values were those for the year 2022 
(cumulative values). For each indicator, the achieved value was compared to the initial target value to 
determine the achievement percentage: 

𝑂𝐼 𝐴𝑐ℎ𝑖𝑒𝑣𝑒𝑚𝑒𝑛𝑡 𝑃𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒 =(Achieved Value of Indicator / Target Value) × 100 
This analysis aimed to measure the extent to which each country met its goals for specific output indicators 
by the end of 2022. By calculating the achievement percentage for each indicator, we evaluate the degree 
of success relative to the targets set by each country. For countries without a target value (target = 0), 
the achievement percentage of 0% is marked as "NA" (Not Applicable), which does not affect averages 
or other statistics. Consequently, achievements are reported only for countries with a target value for the 
respective indicator, allowing for comparisons across indicators and countries.  
The efficiency score has been scaled to lie between 0 and 100, with 100 representing the highest efficiency. 
A  threshold  of  75  identified  the  top  performers,  representing  the  upper  quartile  of  scores.  While  this 
ranking  reflects  relative  rather  than  absolute  efficiency,  it  provides  valuable  insights  into  resource 
utilisation among Member States. This comparison is relevant as it identifies  best practices and areas 
where other Member States can improve by learning from the more efficient ones.  
For  the  second  step,  to  gain  more  insight  into  the  success  of  different  groups  of  countries  above,  we 
analysed the list of implemented projects based on the keywords the Member States used to describe the 
projects. The aim was to assess the investment priorities within the different groups of countries above, 
by considering the level of EU contribution. The insights must be treated with caution, due to several data 
and information limitations. 
This integrated approach has been applied to each of the two specific objectives of the ISF-
BV.  This  allowed  us  to  reach  a  ranking  illustrating  the  degree  to  which  countries  have 
achieved the expected results of the Instrument efficiently, optimising both performance 
and resource utilisation, defining their performance in relative terms – comparing countries 
to one another rather than in absolute terms. Based on this, countries were categorised into 
three performance categories: 

Top  performers  (i.e  countries  situated  in  the  first  25%  of  the  efficiency  ratio) 
demonstrate high efficiency, achieving substantial outcomes at a relatively low cost. 
The countries, for both SO, are presented in the accompanying figure.  

(98) Several approaches were tested. These approaches have not been successful since a high variation and 
inconsistencies in the way Member States set their indicator targets were found, leading to different results with 
each new approach tested. 

46 

 
 
 
Mid-tier  performers  show  moderate  efficiency,  implying  they  achieved  their  goals 
with reasonable resource usage. These countries achieved a satisfactory level of results 
but could explore strategies from top performers to enhance their efficiency. 

Low  performers  reflect  lower  efficiency  scores,  suggesting  a  potential  mismatch 
between financial input and output. In these cases, funds were less effectively absorbed or 
translated into high performance.  

Figure 15 - Top 25% Member States with the 
highest efficiency score 

The analysis of interventions under SO1 and SO2 has revealed  different patterns in the 
types of interventions that top-performing and mid-lower-performing Member States are 
focusing  on,  with  few  similarities 
between  the  two  categories.  As 
shown  in  the  table  below,  top 
performers  under  SO1  focused 
more on projects to support the visa 
application  process,  such  as  the 
development of information systems 
for 
coordination  of  visa 
applications, equipment/software for 
the  extraction  of  information  and 
consular  cooperation.  Mid  and  low 
performers 
significant 
invested 
efforts  in  consulate  construction  / 
/  equipment  and  IT 
renovation 
systems/interoperability 
of 
information 
Both 
categories of countries (top and low 
important 
targeted 
performers) 
investments  in  operations  related  to 
VIS.  

systems. 

the 

Source: Study team cost-effectiveness analysis, presented in 
Annex IV 

47 

© GeoNames, Microsoft, Open Places, OpenStreetMap, TomTomPowered by BingTop performers - SO1 Luxembourg, Estonia, Latvia, Poland, Finland, HungaryTop performers SO2 Sweden,Iceland, Switzerland, Belgium, Portugal, MaltaTop performers for both SO1  and SO2Netherlands 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 4 - Investment priorities within top, mid-tier, and low performers, based on the efficiency 
score ranking (SO1) 

Associated keywords 

%  of  EU  contribution  out  of  the  total  EU 
contribution to SO1 

Top 
performers 
(a) 

Mid-tier  and  low 
performers  
(b) 

Difference
s 
(a) - (b) 

Visa information system (VIS) 

Training in the common visa policy  

Support for visa application processing 

20% 

3% 

34% 

Schengen Information System (SIS) – general  9% 

IT  systems/interoperability  of 
systems 

information 

Information exchange 

Immigration liaison officers (ILO)  

Equipment/software 
information 

for 

the  extraction  of 

Entry - Exit System (EES) 

Document security/document advisors 

/ 

renovation 

/ 

Consulate  construction 
equipment  

Consular cooperation 

Consular coverage 

Construction  /  Renovation  /  Acquisition  of 
equipment BCPs 

Training for consular officials  

Unknown 

6% 

1% 

0% 

11% 

0% 

3% 

0% 

9% 

1% 

1% 

1 

0% 

40% 

3% 

4% 

12% 

11% 

0% 

0% 

4% 

1% 

3% 

-20% 

0% 

30% 

-3% 

-5% 

0% 

0% 

7% 

-1% 

0% 

12% 

-12% 

4% 

2% 

1% 

0 

1% 

5% 

-1% 

0% 

1 

-1% 

Source: Data extracted from financial and performance information in SFC. Cut-off date: 15.03.2024 

Complementing  this  analysis,  the  results  from  the  exploratory  analysis (99)  utilising 
descriptive statistics for SO1 indicate a weak correlation between the establishment of new 
consular representations and the corresponding ISF-BV operations. This finding suggests 
that  while  some  Member  States  effectively  leveraged  the  ISF-BV  to  establish  new 
cooperations, others pursued similar initiatives independently of the Instrument's support.  

These findings underscore the complexity of the relationship between costs and benefits, 
highlighting  the  necessity  for  a  nuanced  understanding  of  how  different  strategies 
employed by Member States can influence the efficiency of operations and the varying 
degrees of reliance on the ISF-BV programme.  

As regards SO2, top performers focused rather on maritime border surveillance and 
activities associated with EES, complemented by the development of Integrated Border 
Management, activities associated with ETIAS Regulation 2018/1240 (100), and initiatives 
aimed at enhancing the capabilities of immigration liaison officers. In contrast, the less 

(99) It should be noted that due to data limitation and constraints, the regression analysis was restricted to the 
period 2018–2022. It is also important to mention that the conclusions should be taken with caution as the 
analysis encountered several challenges, due to the constraints imposed by data quality and availability. 
(100)  Regulation  (EU)  2018/1240  of  the  European  Parliament  and  of  the  Council  of  12  September  2018 
establishing a European Travel Information and Authorisation System (ETIAS) and amending Regulations 
(EU) No 1077/2011, (EU) No 515/2014, (EU) 2016/399, (EU) 2016/1624 and (EU) 2017/2226, available at 
the link. 

48 

 
 
performing groups focused more resources on Frontex equipment and land border 
surveillance,  followed  closely  by  maritime  border  surveillance.  They  also  focused  on 
operations related to EES and investments for border checks.  

Table 5 - Investment priorities within top, mid-tier, and low performers, based on the efficiency 
score ranking (SO2) 

Associated keywords 

% of EU contribution out of 
the total EU contribution to 
SO2 

Top 
perfor
mers 
(a) 

low 

Mid-tier 
and 
performer
s  
(b) 

Diff
eren
ces 
(a)  - 
(b) 

Training  (e.g.  for  Employees  of  Border  Police  to  Ensure  and 
Uniformly Apply EU Law/ SIS/ VIS, for personnel Deployed in 
Third Countries for Border Control) 

Support to National Coordination Centre (NCC) – EUROSUR 

SIS Regulation (EU) 2018/1861 

Schengen Information System (SIS) - general 

Schengen  Information  System  –  Automated  Number  Plate 
Recognition (ANPR) 

Schengen  Information  System  -  Automatic  Fingerprinting 
Identification System (AFIS) 

Maritime border surveillance 

Land border surveillance 

IT systems/interoperability of information systems 

Information exchange 

Implementation of Schengen evaluation recommendations 

Immigration liaison officers (ILO) 

ETIAS Regulation 2018/1240 

Equipment/software for the extraction of information 

EES (Reg 2017/2226) 

EBCGA (FRONTEX) equipment 

Consulate construction / renovation / equipment 

Document security/document advisors 

Development of Integrated Border management (IBM) 

Construction / Renovation / Equipment BCPs 

Border  checks 
screening, debriefing, etc.) 

(identification, 

registration, 

fingerprinting, 

Automated Border Control (ABC) Gates 

Air border surveillance 
Victims of trafficking in Human beings 
Unmanned aerial vehicles (UAVs) 
Hotspot approach 
Further development of SIS/ SIRENE management 
Risk  analysis  /  support  to  Common  Integrated  Risk 
Analysis Model (CIRAM) 

0% 

2% 

2% 

2% 

0% 

0% 

29% 

5% 

4% 

0% 

0% 

6% 
7% 
0% 

18% 

5% 

0% 

1% 

7% 

1% 

3% 

2% 

1% 

0% 

0% 

0% 

0% 

0% 

49 

1% 

3% 

1% 

3%` 

0% 

0% 

12% 

14% 

3% 

1% 

0% 

0% 
3% 
1% 
11% 

19% 

0% 

1% 

2% 

4% 

6% 

2% 

6% 

0% 

1% 

2% 

1% 

0% 

-1% 

-1% 

1% 

-1% 

0% 

0% 

17% 

-9% 

1% 

-1% 

0% 

6% 

4% 

-1% 
7% 
-
14% 

0% 

0% 

5% 

-3% 

-3% 

0% 

-5% 

0% 

0% 

-2% 

-1% 

0% 

 
% of EU contribution out of 
the total EU contribution to 
SO2 

Associated keywords 

Top 
perfor
mers 
(a) 

low 

Mid-tier 
and 
performer
s  
(b) 

External dimension 
Unknown 
Source: Data extracted from financial and performance information in SFC. Cut-off date:_15.03.2024 

0% 

3% 

0% 

3% 

Diff
eren
ces 
(a)  - 
(b) 

0% 

0% 

While acknowledging the limitations of this analysis, it is important to note that the results 
should not be interpreted as definitive indicators of which types of projects are more cost-
effective. Instead, they underline in which areas of intervention Member States have more 
difficulties 
implementing  cost-effective  projects.  The  findings  that  certain 
interventions do not present an optimal cost-effectiveness ratio does not suggest that 
these interventions were unnecessary, but rather that the implementation may have 
been  influenced  by  the  unique  circumstances  faced  by  each  Member  State  or  could 
reflect capacity constraints.  

in 

The  regression  analysis (101)  complements  the  cost-benefit  analysis  in  that,  for  SO2,  it 
confirms a positive and statistically significant relationship between ISF-BV financial 
expenditure  and  achieved  benefits  of  increasing  the  detection  of  fraudulent 
documents at the border. Specifically, the analysis highlights that for every euro invested 
in  the  ISF-BV  programme  there  is  a  significant  increase  in  the  number  of  detected 
fraudulent  documents.  As  the  analysis  shows,  significant  investments  target  fraud 
detection infrastructure, encompassing a mix of interventions such as training, resources 
for managing irregular border crossings, and coordination efforts. This means that the level 
of effectiveness  and efficiency of the interventions found in the regression analysis 
cannot  be  attributed  only  to  one  specific  type  of  intervention,  but  to  a  mix  of 
interventions targeted and implemented at the Member State level.  

Finally, the analysis revealed that the efficiency of the interventions was impacted by a 
series  of  factors.  Evidence  collected  from  desk  research  and  stakeholder  consultations 
suggest that Member States encountered challenges throughout the implementation of 
projects,  which  affected  the  cost-effectiveness  and  cost-efficiency  of  the  Instrument’s 
implementation.  Notably,  the  COVID-19  pandemic  significantly  impacted  project 
timelines and indicator achievements, prompting adjustments in project management and 
monitoring  practices.  Moreover,  limited  staff  supply  often  caused  project  delays  and 
increased the burden on existing staff, affecting efficiency, as seen in Cyprus where there 
was  a  lack  of  personnel  to  implement  the  national  programme.  Price  surges  due  to 
inflation also affected cost-effectiveness.  

Public  procurement  is  another  factor  that  influenced  the  efficiency  of  the  ISF  BV 
instrument.  While  public  procurement  has  generally  promoted  cost-effectiveness,  the 
efforts to comply with all tendering rules has sometimes posed challenges at MS level. For 
example,  in  Slovakia’s  case,  based  on  the  summary  of  the  audit  findings  for  the  ISF 

(101) Should be noted that due to data limitation and constraints, the regression analysis was restricted to the 
period 2018–2022. It is also important to mention that the conclusions should be taken with caution as the 
analysis encountered several challenges, due to the constraint imposed by data quality and availability. 

50 

 
 
 
programme, the national ex-post evaluation concluded that there were several weaknesses 
in  the  procurement  process  during  implementation,  pointing  out  the  need  to  improve 
processes and increase transparency in project implementation.  

It is important to highlight that the minimum standards for public procurement are set at 
the European level, independent of the ISF-BV instrument. Furthermore, as confirmed by 
stakeholders  during  the  validation  focus  group,  these  EU  public  procurement  rules  are 
supplemented by a series of national regulations tailored to the specific context of each 
Member  State,  which  might  increase  the  administrative  efforts  at  the  level  of  National 
authorities  and  beneficiaries  (as  further  detailed  in  the  section  on  simplification  and 
administrative  burden).  While  Member  States  may  perceive  the  rules  as  complex,  it  is 
important  to  note  that  these  public  procurement  regulations  are  designed  to  ensure 
transparency, adherence to market-based practices, and the prevention of fraud. However, 
there remains an opportunity for Member States to ease the procurement process on their 
side. 

Efforts were made at the Union level for simplification and reduction of administrative 
burden, as further detailed in the section on simplification and reduction of administrative 
burden, 

4.1.3  Simplification and reduction of administrative burden 

Were the Instrument management procedures simplified, and the administrative burden 
reduced for its beneficiaries? 

The  analysis,  based  on  desk  research  (national  programmes,  annual  implementation 
reports,  national  ex-post  evaluations)  and  field  research  (surveys,  interviews,  and  case 
studies),  compares  the  2014-2020  period  to  2007-2013,  noting  that  the  implementation 
system  of  the  Home  Affairs  Funds,  with  particular  reference  to    Regulation  (EU)    No. 
514/2014,  has  established  a  set  of  significant  provisions  aimed  at  reducing  burden  and 
simplifying  funding  procedures  for  both  Responsible  /  Delegated  Authorities  and 
Beneficiaries  while  preserving  the  effectiveness  of  the  control  mechanism.  The  main 
elements are as follows (102): 

A single set of rules for Home Affairs Funds has been put in place in order to ensure a 
better  coordination  and  management  of  related  funds  as  well  as  the  harmonisation  of 
procedures. 

A  multi-annual  programming  has  been  introduced  with  a  view  to  guaranteeing  more 
flexibility in the management of national programmes, as it removes the need for drafting 
annual  programmes  and, at  the same time, enables the implementation  of projects  with 
longer life cycles. 

To  streamline  the  use  of  funding  and  minimise  the  risk  of  errors,  while  allowing  for 
necessary  differentiation  to  account  for  policy-specific  requirements,  it  was  deemed 
essential  to  establish  clear  forms  of  support  and  standardised  conditions  for 
expenditure eligibility, including simplified cost options (SCOs). In this regard: 

(102) Horizontal Regulation, Recital 19, despite simplification efforts, “the control mechanism should remain 
efficient, and therefore it is important to recall the applicable rules on the protection of the financial interests of 
the Union, providing for on-the-spot checks and audits which may be announced as well as unannounced”.  

51 

 
 
-  The possibility to use SCOs was intended to reduce administrative burden when 
declaring expenditure, simplify the control and audit process as well as fasten 
the processing of payment claims. 

-  The  introduction  of  national  rules  on  expenditure  eligibility  was  meant  to 
provide more flexibility in the management of national programmes in terms of 
adaptation  to  national  specificities  and  simplification  of  implementation  at 
national level. 

Within  the  framework  of  national  programmes  and  under  the  conditions  laid  down  in 
Article  10  of  ISF-BV  regulation,  Member  States  are  allowed  to  allocate  up  to  40%  to 
Operating  Support,  whereas  public  authorities  are  tasked  with  delivering  services 
essential to the EU’s public service mission This is supposed to reduce project-specific 
burden  on  national  authorities,  supporting  their  capacity  to  deliver  services  more 
efficiently. 

-  Furthermore,  Article  11(2)  of  the  Horizontal  Regulation  provides  that  –  in 
compliance with the principle of proportionality – administrative burdens in 
relation to reporting, evaluation, management and control, shall be proportional 
to the amount of support received, contributing to a more efficient execution of 
funded initiatives. 

-  Lastly,  the  simplification  and  reduction  of  administrative  burdens  is  clearly 
taken  into  account  within  the  common  monitoring  and  evaluation 
framework (Article 55(3) of the Horizontal Regulation). 

Multi-annual programming 

The introduction of the multi-annual programming aims to make Union funding more 
efficient  for  Member  States and  is  widely  considered  –  by  Responsible  and  Delegated 
Authorities – as a key simplification measure, as also explicitly highlighted in 9 ex-post 
evaluations  of  national  programmes (103).  Shifting  from  annual  to  multiannual 
programming  has  indeed  reduced  their  administrative  effort  by  allowing  better 
planning, decreasing frequent reapplications, and improving continuity of support. 
Member  States  gained  flexibility  to  design  and  implement  projects  over  an  extended 
timeline, facilitating a more structured allocation of resources across consecutive years and 
reducing  paperwork.  Such  a  transition  also  contributed  to  ensuring  a  stable  and 
predictable  funding  framework,  an  essential  aspect  for  tackling  complex  challenges 
within the sector. Additionally, longer-term funding cycles reduce the administrative 
effort associated with annual renewals and reporting, enabling more focus on achieving 
the  Instrument's  objectives.  Interestingly,  this  approach  also  provided  a  great  deal  of 
flexibility  in  project  prioritisation  and  clarity  on  strategic  objectives.  For  instance,  in 
Lithuania,  beneficiaries  highlighted 
the 
administrative burden, as it allowed decisions on multi-year projects, eliminating the need 
for annual reprogramming or reapplication processes that could have introduced additional 
complexity (104), according to evolving national security needs, and ensuring that resources 
were directed toward the most pressing objectives.  

this  flexibility  significantly  eased 

that 

Finally,  while  the  annual  programming  was  characterised  by  increased  costs  related  to 
application  submission,  contract  agreements,  reporting,  financial  clearance,  and 

(103) Austria, Cyprus, Finland, Italy, Lithuania, Luxembourg, Malta, Slovenia, and Switzerland ex-post evaluations 
of ISF-BV 2014-2020. 
(104) Lithuania ex-post national evaluation of ISF-BV 2014-2020. 

52 

 
 
compliance  checks,  the  adoption  of  the  multi-annual  programming  eliminated  this 
additional  administrative  effort.  In  this  regard,  an  international  comparative  analysis 
conducted  as  part  of  the  Swiss  ex-post  evaluation  concluded  that  it  reduced  the 
administrative  workload;  recognised  that  procurement  processes  often  require  a 
multiannual implementation phase and enabled more comprehensive and complex projects 
that integrate training and the adoption of new methodologies and processes beyond simple 
procurement (105).  

However, some persisting challenges have been identified, mostly related to complexity in 
the transition  phase and a lack of other combined simplification measures. It  should be 
noted  that  this  transition  initially  presented  significant  challenges  for  beneficiaries (106), 
who faced difficulties in drafting programme plans for the upcoming seven years while 
ensuring alignment with the Union common indicators. 

National Eligibility Rules and Simplified Cost Options (SCOs) 

National  Eligibility  Rules  provided  flexibility  and  adaptability,  particularly  in  terms  of 
financial management, staff costs, and project modifications. Evidence from 11 ex-post 
evaluations  of  national  programmes (107)  confirms  that  national  eligibility  rules  have 
played a crucial role in enhancing instrument management flexibility, streamlining 
administrative  processes,  and  improving  project  implementation  across  Member 
States. By allowing countries to tailor provisions within a common EU framework, these 
rules  enabled  more  context-specific  adaptations,  ensuring  that  funding  mechanisms 
aligned  with  national  priorities (108).  For  instance,  Slovakia's  approach  to  staff  costs, 
allowing  different  employment  contract  types  and  flexible  working  time  allocations, 
significantly eased financial reporting efforts for beneficiaries. Finland’s adoption of cost 
models  streamlined  indirect  cost  tracking,  reducing  the  complexity  of  financial  audits, 
while Lithuania’s IS VORAS digital system improved efficiency in fund administration, 
enabling better project monitoring and reporting. 

Collectively,  these  experiences  highlight  the  transformative  potential  of  well-structured 
national  eligibility  rules  in  enhancing  efficiency,  reducing  administrative  burden,  and 
ensuring strategic fund allocation. However, despite these, in the targeted survey only 17% 
of the ISF-BV’s National Authorities reported the use of simplification measures (109) 
and, at the same time, many Member States struggled to strike a balance between flexibility 
and compliance, resulting in a persistent high administrative effort.  

The ex-post  evaluation  of some participating  countries (110) identified the misalignment 
between national and Union implementing rules as a factor impeding the simplification of 
procedures in a number of aspects. In some cases, national eligibility rules failed to ease 
administrative pressures. 

Moreover, Member States could have adopted SCOs, which can indeed be highly effective 
in reducing administrative efforts by allowing beneficiaries to report standard unit costs, 
such  as  fixed  rates  for  direct  personnel  expenses,  streamlining  financial  reporting  and 

(105) Switzerland ex-post evaluation of ISF-BV 2014-2020. 
(106) E.g. Cyprus ex-post evaluation of ISF-BV 2014-2020. 
(107) Bulgaria, Cyprus, Estonia, France, Italy, Lithuania, Malta, Slovenia, Slovakia, and Switzerland ex-post 
national evaluations of ISF-BV 2014-2020. 
(108) Malta and Cyprus ex-post evaluations of ISF-BV 2014-2020. 
(109) Targeted survey for National Authorities, Question 28: “Were simplification measures (e.g., simplified cost 
options) used into the Programmes funded by ISF -BV and BMVI instruments?”. 
(110) Germany, Slovakia, Cyprus, Hungary and Belgium. 

53 

 
 
enhancing  the  predictability  of  project  expenditures.  In  this  regard,  stakeholder 
consultations  highlighted  the  need  for  a  stronger  commitment  to  SCOs (111),  as  they 
significantly  simplify  administrative  requirements,  resulting  in  clearer  and  faster 
reporting (112). The documentary review showed that a limited number of Member States 
(Cyprus,  Malta,  Spain,  Finland,  Germany,  Italy,  Slovenia  and  Switzerland)  used 
SCOs  during  the  2014-2020  programming  period,  mostly  by  applying  a  flat  rate  for 
indirect  costs  and  personnel  costs.  For  instance,  in  Cyprus,  SCOs  were  applied  for 
indirect  costs  for  the  verification  of  project  implementation  recognising  a  7%  flat  rate, 
contributing 
improving  project 
implementation control. At the same time, it was noted that a wider use of SCOs would 
not have been effective considering the relatively small size of the Cyprus’ allocation. As 
such, this limited utilisation of SCOs was due to the additional administrative burden and 
costs associated with the data collection and analysis required for projects under SCOs. 
Some  countries  explicitly  stated  that  the  limited  use  of  SCOs  in  their  2014-2020  NP 
represented  a  missed  opportunity  to  streamline  financial  management  and  ease 
administrative burden on beneficiaries. 

financial  management  and 

to  streamlining 

to 

Public procurement 

Stakeholders had mixed views regarding the administrative burden of public procurement 
processes  associated  with  the  Instrument.  However,  while  some  Member  States  have 
expressed  concerns  regarding  the  complexity  or  rigidity  of  procurement  rules,  it  is 
important  to  note  that  the  scope  for  modification  at  the  fund  level  is  limited.  Many 
challenges arise from national implementation or administrative practices rather than fund-
specific requirements. Member States may consider streamlining their internal procedures. 

Case  study  consultations  indicated  that  public  procurement  procedures  were  complex, 
requiring  detailed  methodologies  and,  in  some  cases,  external  support  for  their 
preparation (113).  Several  Member  States  have  implemented  more  flexible  procurement 
approaches, allowing for greater adaptability in complex projects. In Italy, for instance, 
centralised  procurement  coordination  within  the  National  Authority  has  been  indeed 
positively received, as it reduces the effort on individual beneficiaries, allowing for better 
management of tender documentation and contract oversight. In France, the establishment 
of specialised procurement units within Ministries has streamlined reporting and oversight, 
ensuring faster and more transparent procurement processes. Digitalisation and IT System 
Improvements  have  been  another  notable  step  forward  in  procurement  simplification. 
Some Member States, such as Estonia and Lithuania, have introduced digital systems to 
facilitate electronic procurement management, reducing manual paperwork. Additionally, 
discussions on risk-based procurement controls have gained traction. 

Despite these improvements, administrative complexity, particularly regarding the length 
and complexity of procurement procedures, remains a significant barrier for some Member 
States  in  fully  utilising  available  resources (114). For  example,  in  Slovakia, procurement 
was  identified  as  one  of  the  most  time-consuming  administrative  barriers,  with  lengthy 
validation  processes  and 
slowing  project 
implementation.  Similarly,  excessive  documentation  requirements  remain  a  widespread 
issue  across  several  Member  States.  In  Germany,  beneficiaries  reported  high  levels  of 
duplicative  reporting,  with  requirements  to  submit  both  electronic  and  hard  copy 

strict  documentation 

requirements 

(111) Targeted EU-Level Interview. 
(112) Case study consultation: Czech Republic. 
(113) Case study consultations: Czech Republic. 
(114) Targeted EU-level interview. 

54 

 
 
documents  for  procurement,  adding  unnecessary  bureaucratic  steps.  These  findings  are 
also supported by the targeted surveys conducted as part of this study, which show that 
National  Authorities (115)  found  procurement  procedures  (53%  of  respondents)  and 
information obligations (45% of respondents) particularly burdensome. By contrast, 
the most burdensome aspects for beneficiaries (116) were regulatory requirements (36% 
of  respondents)  and  time  spent  in  fulfilling  information  obligations  (33%  of 
respondents).  However,  the  limited  number  of  answers (117)  to  the  survey  among 
beneficiaries does not allow for a generalised conclusion.  

Operating Support 

Operating Support helps streamline instrument management by enabling authorities to 
focus  on  key  tasks  without  the  complexity  of  project-based  funding  procedures.  With 
specific regard to its objectives (118), this support covers operations, staff and service costs, 
the  upgrading  or  replacement  of  equipment,  real  estate  as  well  as  the  operational 
management of systems such as the SIS, the VIS, and any other systems to be implemented. 
Reportedly,  multiple  Member  States  used  operating  support  to  improve  the  IT 
infrastructure  and  ensure  system  stability  resulting  in  a  reduction  of  the  administration 
burden and a simplification of processes (119).  

For example, in Estonia, direct Operating Support enabled ongoing border management 
activities, with resources dedicated to technical maintenance and operational updates that 
bypassed the need for  recurrent, complex grant  applications.  Germany’s approach was 
similarly  strategic,  utilising  Operating  Support  to  enhance  the  VIS  and  EasyPASS 
automated  border  control  system.  This  allocation  toward  infrastructure  maintenance 
reduced the administrative demands associated with frequent reassessment and application 
processes,  streamlining  border  and  visa  processing.  In  Lithuania,  Operating  Support 
contributed  to  the  introduction  of  the  IS  VORAS  system  which  played  a  key  role  in 
reducing  administrative  burden  by  improving  project  management  and  monitoring  for 
beneficiaries. Although its initial rollout was delayed due to public procurement issues, its 
eventual  implementation  brought  significant  benefits,  allowing  users  to  track  progress, 
store  data,  and  streamline  reporting.  While  early  technical  issues  temporarily  increased 
workloads,  these  were  quickly  resolved,  and  beneficiaries  found  the  system  highly 
effective in improving transparency and efficiency. 

These cases collectively underscore how Operating Support within the ISF-BV framework 
effectively streamlined administrative processes, enabling Member States to focus on core 

(115) Targeted survey for National Authorities, Question 20: “To what extent were the following elements related 
to ISF-BV's Member State programme perceived as burdensome in the context of your institution?”, 53 
respondents. 
(116) Targeted survey for beneficiaries, Question 16: “To what extent were the following aspects perceived as 
burdensome in the context of the operation(s) you implemented under the ISF-BV?”, 36 respondents. 
(117) The total number of answers was 36. However, a limitation of the study is the fact that the entire population 
cannot be estimated 
(118) Objectives within the National Programmes are categorised as following: Objective 1. Promoting the 
development and implementation of policies ensuring the absence of any controls on persons, whatever their 
nationality, when crossing the internal borders, carrying out checks on persons and monitoring efficiently the 
crossing of external borders; Objective 2. promoting the development and implementation of the common policy 
on visas and other short-stay residence permits, including consular cooperation; Objective 3. Setting up and 
running secure IT systems, their communication infrastructure and equipment supporting the management of 
migration flows, including surveillance, across the external borders of the Union. 
(119) National Programmes: Belgium, France, Croatia, Sweden; Annual Implementation Reports: Hungary; Country 
case studies: Italy, Romania. 

55 

 
 
operational  capabilities  and  reduce  the  complexities  inherent  in  project-based  funding 
procedures. 

4.1.4  Coherence and complementarity 

Coherence refers to the extent to which the objectives set in the ISF-BV were consistent, 
mutually  reinforcing,  and  effectively  integrated  within  the  context  of  EU  funding.  It 
evaluated both the internal coherence – the consistency and reinforcement of the ISF-BV 
within the Instrument itself, both at EU and national levels – and the external coherence – 
the relationship with other EU programmes. 

4.1.4.1  Internal coherence 

The ISF-BV’s architecture has several funding components which support complementary 
objectives and deliver synergies. 

The  ISF-BV  supports  national  programmes,  which  are  delivered  through  shared 
management and support long-term structural needs (at national level). Support for these 
programmes  account  for  the  majority  of  funding  (56.2%).  In  addition,  under  direct 
management and, where appropriate, under indirect management, Emergency Assistance 
(EMAS)  addressed  urgent  and  specific  needs  in  emergency  situations,  while  Union 
Actions (UAs) financed transnational actions or actions of particular interest to the Union.  

The  table  below  outlines  the  complementary  purposes  of  the  ISF-BV  components  and 
management modes according to  the Regulation. It  confirms  how they  work to  address 
different  needs  (long-term  or  shorter-term/  more  urgent  or  emerging  needs),  and  at 
different levels (national or transnational level).  

Table  6  -  Management  modes  and  funding  components  in  the  ISF-BV  according  to  legal  base 
illustrating the complementary purpose of the different components 

Purpose 

Shared 

Direct 

Indirect 

management 

management 

management 

Primarily  serve  internal  Union  policy  in 
accordance with the specific objectives of 
the ISF-BV (Art. 9 and 12) in the national 
context 

National 
programmes (120) 

/ 

/ 

Transnational  projects  or  projects  of 
particular interest to the Union (Art. 13) 

/ 

Union actions 

(120) National programmes were complemented by: a) 4 top-ups in 2018, 2019 for the development and upgrade of 
large-scale IT systems (EUR 325.7 million for EES, ETIAS, SIS plus EUR 79.1 million IT systems in general) b) 
“specific actions” that are eligible for higher co-financing rates in order to encourage their take up (Art. 7). A list 
of specific actions for which Member States may receive an additional allocation to their programmes is provided 
in Annex II of the ISF BV Regulation, as amended by Commission Delegated Regulation (EU) 2020/446 of 15 
October 2019. Specific actions were launched on consular cooperation (2015), for the purchase of equipment by 
the Member States to be put also at Frontex’s disposal for operations at EU level in support of other Member 
States (2015, 2017, 2018), as well as to reinforce the “border control activities such as border checks and border 
surveillance measures in areas facing currently or potentially high or disproportionate migratory pressure, or both, 
including activities related to the establishment, development and operation of hotspot areas” (2019).  

56 

 
 
Address urgent and specific needs in the 
event  of  emergency  situations  following 
Art 2.f (Art. 14) 

/ 

Emergency Assistance 

Source: Regulation (EU) No 515/2014 *must be demarcated in the national programme as specific actions  

The complementary nature of the components – which may be suited to serving long-term 
or  short  term  /  urgent,  national  or  transnational  needs  can  be  observed  in  practice.  The 
Instrument-level  mid-term  evaluation  report  confirmed  that  the  Instrument  components 
were internally coherent and complementary to one another (121) which was also reflected 
in the national mid-term and final evaluation reports feeding into the overall assessment. 
Responses to the surveys of national authorities confirm this finding is valid for the latter 
half of the funding period (122). Stakeholders interviewed for the country case studies were 
also positive. 

The specific niche function of Union Actions and ways in which they complement other 
components  by  supporting  projects  with  high  EU  added  value  is  demonstrated  by  the 
sample  reviewed  for  the  in-depth  case  study  on  Union  Actions.  For  instance,  projects 
funded  through  the  Migration  Partnership  Facility  (run  by  the  International  Centre  for 
Migration  Policy  Development  -  ICMPD)  occupy  a  particular  niche:  one  such  project 
sampled in the case study was an example of a cooperation programme between an EU 
Member  State  and  third  country,  which  shared  a  land  border  with  the  EU  Schengen 
area (123).  Such  actions  /  projects  are  common  and  not  typically  pursued  under  national 
programmes. A challenge for Union Actions is that this can also be difficult for national 
administrations  to  administer  because  the  transnational  collaboration  required  (in  some 
cases) is atypical for them and can be perceived as a barrier to participation (124). 

There are (formal and informal) mechanisms  in  place to  ensure complementarities and, 
where relevant, synergies across the different components but these could be strengthened. 
Formal mechanisms are in place to ensure EMAS and Union Actions (delivered through 
Annual  Work  Programmes  developed  by  the  European  Commission)  complement  the 
support  delivered  through  the  national  programmes  (developed  by  Member  States  in 
consultation with the European Commission at the start of the programming period) at the 
EU and national levels:   

At the EU level the internal procedures ensured that financial and policy units within DG 
HOME,  as  well  as  other  Commission  services  where  appropriate,  feed  into  decision-
making processes (i.e. drawing up the Annual Work Programmes), allowing for possible 
complementarities  across 
through  different  components  and 
management modes from the outset. For the delivery of EMAS specifically, before funding 

funding  provided 

(121) The mid-term evaluation found: Internally, there is high coherence and complementarity between national 
programmes and EMAS, which have clearly supported each other and high coherence between national 
programmes and UAs (the latter being clearly designed to complement the national programmes). However, there 
appears to be room for improvement, especially with regard to UAs and EMAS, because most ISF-BV 
beneficiaries were not aware of other ISF-BV financed actions and considered coordination to be an informal 
initiative. There is clearly a need for more formalised information at project and national level. 
(122) The survey of national authorities showed the vast majority assessed the fund structure (both the management 
modes and different components) to contribute to ensuring complementarities.  
(123) In practice, the sampled action was abbreviated due to political circumstances completely outside the control 
of those involved. 
(124) As exemplified in discussions with national authorities in multiple countries for the country and thematic case 
studies, as well as in the focus group discussion confirming this is a general finding, not limited to a few countries 
or cases. 

57 

 
 
is  agreed,  there  was  an  informal  and  formal  process  of  review  to  avoid  duplication  or 
overlaps (125). 

At the national level, the extent to which complementarities are ensured depends on the 
day-to-day coordination mechanisms at national level, which are within the remit of the 
responsible authority for the ISF BV programme (126). The national mid-term evaluation 
and final reports analysis indicates that this is almost always assessed positively. However, 
as mentioned above, there may be differences observed at national level, and this may be 
perceived as weaker or stronger in some countries (127).. An additional layer of assurance 
is the Monitoring Committee, which has oversight of all the support delivered at national 
level and can thereby ensure complementarity. 

The above formal coordination mechanisms ensured a lack of duplication or overlap but 
the facilitation of synergies was a weakness identified at the mid-term evaluation of the 
ISF-BV. This has been rectified to some extent during the remainder of the funding period. 
For instance, this was observed through a more systematic coordination at national level 
for Specific Actions supported within national programmes (128), as well as efforts to ensure 
better  coordination  between  Union  Actions  and  national  programmes.  As  such,  the 
situation over the longer term (i.e. under the BMVI) was set to improve (129).   

4.1.4.2  External coherence  

This section is based on EU level desk research, the responses to the three targeted surveys 
(national  authorities,  beneficiaries  and  other  stakeholders),  EU  level  interviews,  and 
country case studies.  

Mechanisms for coordination 

Mechanisms  for  coordination  of  activities  and  funding  at  EU  and  national  level  exist, 
although they vary across the Member States. Different  mechanisms are in place at  the 
national level to ensure coordination of the ISF-BV funding with other EU funds at the 
programming stage. First and foremost, coordination takes place through the Monitoring 
Committee and regular coordination between the Responsible Authorities of the different 
funds. In addition, Member States have put in place additional means to ensure overlap is 
avoided and synergies are created. Three main mechanisms were focused in the evaluation: 

43% of respondents (6 out of 14) confirmed to have put in place monitoring mechanisms 
aimed to prevent the overlapping of financial instruments, whereas 29% stated they had no 
such  mechanism  in  place.  By  contrast,  almost  all  national  evaluation  reports  have 

(125) Applicants need to demonstrate that the funding is not available through other means (for example support 
from DG ECHO), and the review process and assessment of applications involves relevant units in DG HOME 
and (if relevant) Frontex. 
(126) It is the responsible authority who bears the main responsibility for the effective and efficient implementation 
of the Instrument. 
(127) Greece appears to be an example of strong coordination. In Greece, there were Coordination Mechanisms to 
ensure the coherence of the programme (i.e., consultation among key stakeholders and planning of actions to 
ensure that the actions of the programme respond to real needs and do not overlap with other actions).  
(128) A couple of concrete examples illustrate how this works in practice: in Germany detailed information at the 
project level facilitates the identification of the need for project-based collaboration on a case-by-case basis to 
ensure that projects with overlapping target groups / beneficiaries were mutually supportive and synergistic. In 
Finland proactive networking and knowledge-sharing was used to support synergies. 
(129) According to the draft findings of the parallel study supporting the mid-term evaluation of the BMVI.  

58 

 
 
mentioned the existence of a monitoring committee, a coordination committee or a central 
authority to avoid the overlapping of financing. 

36% of respondents (5 out of 14) confirmed that coordination mechanisms between the 
ISF-BV  and  other  funding  instruments  were  established  to  ensure  synergies  and  their 
complementarity for the implementing period, such as institutional arrangements, specific 
directorates, divisions, units, platforms, and committees set up to boost the coordination 
and synergies  with  other EU funds. This number was much higher in the final  national 
evaluations, with 10 countries having a defined institutional arrangement in order to avoid 
the duplication of funding.  

36% (5 out of 14) of the respondents confirmed that their Member State had conducted an 
assessment to identify other funding instruments with similar or complementary objectives 
at  the  EU  or  national  levels  in  order  to  build  complementarities/synergies  and  avoid 
overlaps/duplications.  

Across  all  three  mechanisms  covered  by  the  survey,  a  large  proportion  of  respondents 
replied,  “I  don’t  know  /  I  prefer  not  to  say”  (between  29%  and  50%  depending  on  the 
mechanism).  This  lack  of  awareness  could  also  indicate  that  such  mechanisms  are  not 
widely used/consulted within the relevant national authorities.  

Figure 16 - Assessment of contribution ISF-BV fund structure to ensuring complementarities and 
synergies, where relevant (N=14) 

Existence of different funding mechanisms (national
programmes, union actions, emergency assistance)
(n=14)

7%

21%

21%

7%

Contribution of different management modes in
ensuring complementary (n=14)

14%

21%

14%

7%

To a very large extent

To a large extent

To some extent

To a limited extent

Not at all

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

Source: survey of national authorities 

The  ex-post  national  evaluation  reports  mentioned  a  few  other  mechanisms  to  ensure 
synergies  and  avoid  duplication:  Three  Member  States  noted  that  the  identification  of 
synergies and overlaps lies with the applicant, with an obligation to disclose co-financing 
through other funding streams, or the funding of similar projects during the application 
stage. Another Member State explicitly mentioned the use of the CORDIS portal to check 
for  European  research  projects,  noting  Horizon  2020 (130)  projects  were  missing  in  this 
portal. 

A few national evaluation reports (the Czech Republic, Slovakia and Finland) mentioned 
that  there  is  room  for  improvement,  in  terms  of  the  practical  application  of  existing 
coordination  mechanisms,  in  order  to  better  capture  synergies.  Another  national  report 

(130) Regulation (EU) No 1291/2013 of the European Parliament and of the Council of 11 December 2013 
establishing  Horizon  2020  -  the  Framework  Programme  for  Research  and  Innovation  (2014-2020)  and 
repealing Decision No 1982/2006/EC Text with EEA relevance. OJ L 347, 20.12.2013, pp. 104–173. ELI: 
http://data.europa.eu/eli/reg/2013/1291/oj 

59 

 
 
 
(Belgium)  pointed  out  the  challenge  of  identifying  projects  directly  financed  by  the 
European Commission and recommended the creation of a database, although in fact this 
already exists (131), indicating the need for awareness raising. 

At  the  EU  level,  coordination  at  the  programming  stage  took  place  first  and  foremost 
through  the  Inter-Service  Consultation  (ISC).  In  relation  to  the  Home  Affairs  Funds, 
overlaps  are  avoided,  and  synergies  were  ensured  through  the  dedicated  unit  within 
DG HOME,  which  closely  coordinated  with  the  relevant  DG  HOME  policy  units.  The 
Commission  also  has  additional  tools  at  its  disposal,  including  in  the  first  place  the 
guidance  and  information  provided  through  the  HOME  Affairs  Committee  (where  the 
participating  countries  are  represented),  the  participation  of  DG  HOME  in  Monitoring 
Committee  meetings,  the  dialogue  between  DG  HOME  and  Responsible  Authorities, 
conducting on site visits, as well as audits carried out at EU level.  

Coherence and complementarity with national funding mechanisms and policies 

As regards formal mechanisms to ensure complementarity, the interim evaluation of 
the  ISF-BV  confirmed  that  most  Member  States (132)  had  carried  out  assessments  of 
complementarity  of  objectives  of  the  Instrument  with  objectives  of  the  national 
interventions  and  strategies.  The  remaining  Member  States  that  did  not  carry  out  any 
assessment (133)  stated  that  consistency  of  priorities  and  projects  was  ensured  by  wide 
stakeholder  consultation  during  the  programming  stage.  In  addition,  eighteen  Member 
States (134) reported putting in place mechanisms to ensure complementarity.  

The survey carried out for this study did not confirm the existence of formal mechanisms 
in most Member States. Only 36% (5 out of 14) of the ISF-BV respondents confirmed that 
an assessment in their Member State was conducted to identify other funding instruments 
with  similar  or  complementary  objectives  at  the  EU  or  national  level  in  order  to  build 
complementarities/synergies  and  avoid  overlaps/duplications  with  ISF  BV  (note:  the 
questions covered both national level and the EU level complementarity). As much as half 
of the ISF-BV respondents (7 out of 14) did not provide an answer to this question (see 
Figure below). 

Figure 17 - Was an assessment conducted in your Member State to identify other funding instruments with 
similar  or  complementary  objectives  at 
to  build 
the  EU  or  national 
complementarities/synergies and avoid overlaps/duplications with ISF BV 

in  order 

level 

(131) EU Funding and Tender Portal: https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/projects-
results?order=DESC&pageNumber=1&pageSize=10&sortBy=es_SortDate&isExactMatch=true  
(132) Austria, Belgium, Bulgaria, Switzerland, Cyprus, Czechia, Germany, Estonia, Greece, Spain, Finland, 
France, Hungary, Italy, Lithuania, Malta, Netherlands, Poland, Romania, Slovakia. 
(133) Belgium, Switzerland, Germany, Greece, Croatia, Italy, Luxembourg, Malta, Portugal, Slovenia. 
(134) Austria, Bulgaria, Switzerland, Cyprus, Czechia, Germany, Spain, Finland, France, Croatia, Hungary, Italy, 
Lithuania, Latvia, Malta, Netherlands, Poland, Slovenia. 

60 

 
 
 
However,  the  interim  evaluations,  the  stakeholder  consultations  and  the  case  studies 
carried  out  for  this  study,  provide  some  examples  of  mechanisms  in  place  in  Member 
States: 

•  Requiring  project  applications  to  demonstrate  coherence  and  complementarity:  For 
instance,  the  interim  evaluation  noted  that  in  Austria,  the  templates  for  project 
proposals  and  for  project  monitoring  and  reporting  included  questions  specifically 
aimed at avoiding double funding.  

•  Responsible  Authorities  and  Monitoring  Committees  playing  a  role  in  ensuring  the 
Instrument’s complementarity at national level: For example, in Bulgaria and Finland, 
the  ISF  Monitoring  committee  was  indicated  as  responsible  for  ensuring  the 
coordination between the relevant EU and national financing instruments. 

•  Organisation of dedicated working groups and meetings, in order to foster information 
sharing at the programming  stage:  E.g. in  Hungary, the Ministry of  Interior leads a 
ministerial working group that ensures the harmonisation of all the developments at 
borders  co-financed  by  the  EU  or  by  national  funds.  In  Greece,  a  dedicated  Policy 
Dialogue between key stakeholders was held in 2013 to define the national strategic 
guidelines and specific objectives of the ISF-BV national programme and ensure their 
alignment and complementarity with the government policies and initiatives. 

•  Use of a monitoring and evaluation information system: in Italy, such a system, which 
covered both the ISF and other programmes, was used to detect the possible duplication 
of projects from different financial instruments and to automatic generate alerts. 

These  examples  seem  to  suggest  that  complementarity  is  ensured  mainly  at 
programming stage, but it is unclear whether the focus of these mechanisms was on 
ensuring  complementarity  between  EU  financial  instruments,  rather  than  with 
national instruments. Nevertheless, stakeholders believed that the mechanisms were 
sufficient for preventing overlaps and duplications.  

The  interim  evaluation  of  the  ISF-BV  concluded  that  there  was  evidence  of 
complementarity between the objectives set in the ISF-BV national programmes and those 
set in national policies of Member States in the area of borders and visa. In this study, it 
was not possible to do an exhaustive analysis of all relevant financial instruments in the 
Member States. Instead, the evaluation focused on the main relevant policies and actions 
supported  by  other  EU  instruments  in  the  case  study  countries.  The  feedback  from 
stakeholders consulted within the case studies clearly confirmed that they acknowledged 
the ISF-BV’s complementarity with national-level policies and funding instruments.  

The case studies carried out within this evaluation confirmed the general complementarity 
of  the  ISF-BV  with  policies,  strategies  and  priorities  pursued  by  Member  States  in  the 
fields of visa policy and border management. For instance, all ICT actions proposed under 
the ISF-BV programme were in line with the Digital Growth Strategy for Greece and with 
Greece’s  National  Action  Plan  on  Migration  and  Asylum,  which  aimed  to  address  the 
challenges of migration and asylum.  

The ISF-BV was viewed as  contributing to high-level policy priorities. For instance, in 
Norway, the ISF-BV supported this country’s ability to fulfil the Schengen obligations, 
whereas  in  Croatia  and  Romania,  it  supported  the  country’s  accession  to  the  Schengen 
Area, a clear national  priority supported by multiple plans and programmes in  place to 
ensure adherence to this goal.  

61 

 
In the interim evaluation consultation activities, no Member State reported overlaps or 
duplication (135).  Similarly,  the  case  studies  and  stakeholder  consultations  also  did  not 
identify  any  cases  of  duplications  or  overlap  between  the  Instrument  and  the  national 
funding mechanisms. However, one EU level  stakeholder interviewed noted that it was 
difficult to ascertain, at least at the EU level, that there were no overlaps between the ISF-
BV and national actions funded in relation to third countries.  

The  interim  evaluation  also  concluded  that  “Very  little  information  was  available  as 
regards  the  complementarity  of  actions  implemented  under  direct  management  with 
national  policies  in  the  fields  of  visas  and  borders” (136).  The  national  final  evaluation 
reports  did  not  consistently  report  on  the  complementarity  of  the  funded  actions  with 
national funding instruments. However, some examples were noted in the case studies - 
for instance, pilots being trained through the ISF-BV funded actions, while the aircrafts 
used were purchased or modernised through the use of national funding. Another example 
was upgrades to IT systems using the ISF-BV funding and used with other IT systems or 
equipment financed with national resources. 

Coherence with other Home Affairs instruments (AMIF and ISF-Police) 

The ISF-BV is coherent with the objectives and activities funded under the other Home 
Affairs Instruments: AMIF 2014-2020 and the ISF-Police 2014-2020.  

While the ISF-BV, AMIF and ISF-Police contribute to similar EU level objectives in the 
field of migration, security and border management, provide funding to similar types of 
beneficiaries  and  can  fund  similar  types  of  activities,  they  cover  different  policy  and 
thematic areas. While the ISF-BV focuses on achieving a uniform and high level of control 
of the external borders and effective processing of Schengen visas, ISF-Police focus is on 
combatting cross-border, serious and organised crime and security-related risk and crisis. 
The  instruments  interlink  on  border-related  crimes  such  as  migrant  smuggling  and 
trafficking in human beings. Similarly, while the AMIF’s thematic focus differs from ISF-
BV’s by its focus on asylum and integration, the ISF-BV and AMIF interlink on topics 
such as legal migration and returns. In this context, a few interviewees noted that while it 
did not impact on the coherence of the instruments (in that legal migration and returns are 
solely funded under AMIF thereby avoiding the risk of overlap), it would have been more 
intuitive for the topic of returns to fall under the scope of the ISF-BV rather than AMIF. 

Stakeholders positively assessed the coherence between the ISF-BV and the other Home 
Affairs Instruments. 

In the survey, stakeholders were asked about the level of coherence of the ISF-BV with 
AMIF and ISF-Police. Of those that were able to answer the question (137), the majority 
were positive, noting the ISF-BV actions were coherent (some, large or very large extent) 
with AMIF and ISF-Police funded actions. For AMIF, only 7% of national authorities, and 

(135) European Commission, Interim Evaluation of the Internal Security Fund – Borders and Visa (2014-2017). 
Final Report, pp. 120-122. 
(136) Ibid., p. 121. 
(137) As can be seen in the figures in Annex, of the stakeholders consulted through the online survey, a large 
proportion (26-60% depending on the type of stakeholder and the fund) did not feel they could answer the 
question whether the actions implemented through ISF-BV were coherent with AMIF or ISF-Police. For 
beneficiaries and “other stakeholders” this could simply indicate a lack of awareness of these other DG HOME 
funds. For the responsible/implementing national authorities this could indicate a lack of available mechanisms in 
place to identify and exploit opportunities to create synergies between the actions funded between the three funds 
(as also noted above).  

62 

 
 
6% of beneficiaries thought this was not the case (answering “not at all”). For ISF-Police, 
14% of national authorities thought this was not the case (accounting for 2 respondents). 

Figure 18 - Coherence between ISF-BV and AMIF (% responses) 

Source: Targeted survey responses to: “In your opinion, were the actions implemented through the ISF-BV and BMVI 
Instruments coherent with and non-contradictory (no duplications or overlap) to other EU interventions with similar 
or complementary objectives? - Asylum, Migration and Integration” N= as indicated in figure . 

Note:  While  the  14  responses  from  national  authorities  only  include  those  relevant  to  ISF-BV,  the  answers  of 
beneficiaries and other stakeholders cover both programming periods (ISF-BV and BMVI funding)  

63 

 
 
 
Although  the  majority  of  national  evaluation  reports  provided  a  general  assessment  on 
external coherence and did not explicitly name other EU funding opportunities explicitly, 
eight national reports (Austria, Belgium, Germany, Spain, Finland, Malta, the Netherlands 
and  Sweden)  specifically  addressed  AMIF,  while  three  (Austria,  Luxembourg  and  the 
Netherlands)  also  made  reference  to  ISF-Police.  Their  overall  assessment  was  positive, 
with  monitoring  mechanisms  established  to  prevent  overlaps  and  promote  synergies 
whenever feasible. 

The EU level interviews, as well as those carried out as part of thematic and country case 
studies, did not note any overlaps, gaps, or inconsistencies between the activities funded 
by the ISF-BV with actions funded under AMIF or ISF-Police.  

Coherence with Frontex activities 

Coherence with Frontex activities is ensured through coordination with Frontex at 
the programming stage. The ISF-BV aims to strengthen the capacity of Member States 
and  Schengen  Associated  Countries  to  carry  out  their  tasks  and  responsibilities  in  the 
management of the EU external borders as one of the ‘legs’ of the European Border and 
Coast Guard. 

In line with the Regulation (EU) 2019/1896 on the European Border and Coast Guard, the 
national authorities of Member States responsible for border management, including coast 
guards  to  the  extent  that  they  carry  out  border  control  tasks,  the  national  authorities 
responsible for return and the European Border and Coast Guard Agency (‘the Agency’) 
shall constitute the European Border and Coast Guard.  

Such enhancement also includes supporting joint operations led by the Agency. Frontex 
was actively involved in programming national programmes to ensure the use of Frontex’s 
analytical  tools,  guidelines,  and  training  curricula  (Articles  9  and  12).  Draft  national 
programmes  were  shared  with  Frontex  for  input,  and  the  Agency  had  direct  access  to 
SFC2014. Additional coordination occurred through electronic data exchange on Frontex 
equipment  purchases  under  shared  management,  as  noted  in  the  interim  ISF-BV 
evaluation. Moreover, since the adoption of the 2019 EBCG Regulation (138) and EIBM 
Strategy (139),  Member  States  are  required  to  develop  national  capability  development 
plans, which then feeds into the funding needs. While the methodology and procedure for 
establishing these plans was adopted by Frontex Management Board in January 2021 (and 
reviewed in 2024), interviewees expected this to further increase the alignment between 
DG HOME funding and Frontex with respect to capability development planning.  

In  spite  of  all  this,  only  a  limited  number  of  national  evaluation  reports  specifically 
referenced  Frontex.  Cyprus  reported  that  coordination  among  beneficiaries,  national 
authorities,  and  the  Responsible  Authority  effectively  prevented  any  duplication  of 
funding. Additionally, the Spanish report indicated that efforts were made to seek synergies 
with  other EU funds and  EU decentralised agencies, including  Frontex, to optimise the 
utilisation of EU funding resources. 

(138) Regulation (EU) 2019/1896 of the European Parliament and of the Council of 13 November 2019 on 
the European Border and Coast Guard and repealing Regulations (EU) No 1052/2013 and (EU) 2016/1624 
(139) Frontex, Technical and operational strategy for European integrated border management, Publications 
Office of the European Union, 2019, https://data.europa.eu/doi/10.2819/76516  

64 

 
 
Coherence with other EU funding instruments  

The ISF-BV interacts with a number of other Union funds, and mechanisms exist to ensure 
duplications are avoided and that synergies are created. The detailed table in Annex III to 
this SWD presents a comparison of the objectives and scope of each of these Union funds, 
as well as the similarities with ISF-BV (potential areas of overlap and opportunities for 
synergies) and mechanisms in place to ensure synergies.  

Stakeholders  were  generally  positive  about  the  coherence  between  ISF-BV  and  other 
funding instruments, although some noted that coordination could be further strengthened 
in certain areas (e.g. Horizon 2020 and funds in the field of external action). In the survey, 
stakeholders  were  asked  about  the  level  of  coherence  of  the  ISF-BV  with  other  Union 
funding  instruments.  Of  those  14 national  authorities  involved  in  the  ISF-BV  that 
responded to the survey, more than half felt they could not answer the survey (similar to 
the question on coherence with AMIF and ISF-Police above). However, of those that were 
able to answer the survey question (approx. 7 national authorities), the majority of national 
authorities were positive, noting the ISF-BV actions were coherent (to a large or very large 
extent)  with  other  EU  funding  instruments.  Respondents  were  most  positive  about 
coherence  with  Horizon  2020.  The  survey  with  beneficiaries  and  “other  stakeholders” 
showed  similar  results,  with  the  majority  answering  they  “did  not  know”,  followed  by 
respondents that responded positively (and most positively about Horizon 2020 and ESIF).  

The interviews carried out for this evaluation (Union level and national level through the 
case studies) confirmed that overall, the ISF-BV was coherent with the other Union funds, 
and no overlaps had been identified. These findings have been further confirmed by the 
national  reports,  although  they  only  gave  a  general  assessment  on  external  coherence 
without  providing  an  in-depth  analysis  per  funding  instrument.  The  only  exception  is 
Horizon  2020  which  was  specifically  mentioned  by  several  countries  (for  example, 
Germany, Estonia, Spain, Finland, Lithuania, the Netherlands and Sweden).  

In relation to the different instruments, the following was noted: 

Horizon 2020:  The EU  level  interviews carried  out  for this  evaluation  highlighted that 
beyond the ISF-BV, no other funding mechanism existed to further build on the pipeline 
of  border  management-related  innovation  that  was  developed  under  the  Horizon  2020 
programme. In this context, the ISF-BV funding was seen as a crucial tool to ensure the 
concepts developed under Horizon would lead to longer-term testing and validation and 
eventually ensure these capabilities were available to procure on the EU market. However, 
interviews confirmed that Responsible Authorities are often unaware of the relevant R&D 
projects  funded  in  their  country, as  well as the relevant  stakeholders involved, and that 
generally follow up to Horizon 2020 was not prioritised by Member States under the ISF-
BV as they tended to focus on using funding to address more immediate needs.  

ESF/ERDF: EU level interviewees highlighted that the risk of duplication of interventions 
with ESF and ERDF was low.  

Funding  for  actions  in  relation  to  third  countries  (EU  external  action):    activities 
funded by the ISF-BV that are funded in, and in relation to, third countries should be “taken 
in  synergy  and  coherence  with  other  actions  outside  the  Union,  supported  through 
geographic and thematic Union external assistance instruments”. As can be seen in Annex 
III, EU external action is financed through a range of funds, including the Instrument for 
Pre-Accession Assistance 2014-2020 (IPA II), the European Neighbourhood Instrument, 

65 

 
(2014-2020), and the Partnership Instrument for Cooperation with Third Countries (2014-
2020). Interviews with DG INTPA, DG NEAR and EEAS confirmed that as far as they 
were aware, the number of projects funded under the ISF-BV relating to third countries 
had been limited, and hence consultations had been limited too. While they did not identify 
any actual cases of overlap or duplication between these funds and the ISF-BV, they did 
note that the broad nature of national programmes (lack of details on planned activities and 
in relation to which third countries at planning stage) made it difficult know whether and 
what  exactly  was  being  funded  in  relation  to  third  countries  under  the  ISF-BV.  In  this 
context, one interviewee noted that coordination with DG HOME had become much closer 
and  more  institutionalised  since  the  migration  crisis  of  2015  which  made  the  topic  a 
political priority. Since then, both sides had been more involved in each others planning, 
with  more  formalised  and  more  institutionalised  preparatory  meetings  and  information 
sharing meetings between DG NEAR, DG INTPA, EEAS and DG HOME.   

As far as coherence with external spending programmes is concerned. Several challenges 
in  the  current  funding  architecture  have  been  identified  including  notably  the  need  to 
further strengthen the link between internal and external priorities in the Union’s migration 
and  security  funding;  the  persistent  challenge  to  use  all  existing  (policy,  funding, 
investment and other) tools, both at the disposal  of the EU and its Member States, in a 
Team Europe spirit, to use strategically and timely leverage in relation to partner countries 
in  order  to  improve  cooperation  on  migration  and  security;  the  limitations  for  funding 
migration- and security-related actions in third countries, given that most of spending in 
the external dimension must comply with the criteria for development assistance eligibility 

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

4.2.1  EU added value 

The examination of this evaluation criterion served to determine the changes that were due 
to  the  EU  intervention,  over  and  above  what  could  have  been  expected  from  national 
actions by the Member States without the Union’s support. 

Financial support to Member States  

In 22 EU Member States plus Norway and Switzerland, the financial support provided by 
the ISF-BV enabled the acquisition, modernisation and deployment of critical equipment 
and  infrastructure  for  the  management  of  external  borders  and  implementation  of  the 
common  visa  policy  that  would  have  been  unattainable  through  individual  national 
budgets.  This  support  increased  the  overall  available  resources  for  border  control  and 
management  of  migration  flows  across  external  borders,  contributed  to  the  Union’s 
internal security, and enabled Member States to address increased pressure on borders. For 
instance,  Cyprus  was  able  to  enhance  its  surveillance  capabilities  to  manage  increased 
migration flows, while Malta deployed four Automated Border Control (ABC) gates which 
greatly improved the efficiency of document verification for EU and Schengen citizens, 
thereby  bolstering  border  security (140).  Moreover,  in  Belgium,  Switzerland,  Latvia, 
Lithuania,  France,  Finland,  Italy,  Liechtenstein,  and  the  Netherlands,  the  financial 
assistance  provided  by  the  Instrument  enabled  strategic  projects  focused  on  the 
modernisation and improvement of IT systems that enhanced these countries’ capacity to 

(140) AIR 2023. 

66 

 
 
 
meet  EU  requirements  and  standards (141).  In  Slovakia,  Poland,  the  Czech  Republic, 
Germany, Iceland, and Sweden the Instrument enabled the implementation of large-scale 
projects that would have been difficult to finance without EU support (142). 

Without the support of the Instrument, eight Member States report that they would have 
struggled  to  implement  essential  Union  policies  effectively.  In  Italy,  the  Ministry  of 
Foreign Affairs and International Cooperation reported that while some initiatives, such as 
the  VIS  system,  could  proceed  independently,  they  would  have  faced  notable  resource 
constraints  and  reduced  quality  standards (143).  The  Instrument  enabled  Italy  to  uphold 
Union-mandated  excellence  in  its  systems,  without  diverting  vital  resources  from  other 
priorities. Similarly, in Sweden, the digitalisation projects within the Swedish Customs and 
the  Radiation  Safety  Authority  would  likely  have  been  delayed,  limiting  Sweden’s 
capacity  for  compliance  and  strategic  growth  in  critical  areas (144).  This  difficulty  in 
independent  implementation  was  echoed  across  various  Member  States.  For  instance, 
Poland  highlighted  that  without  the  ISF-BV,  it  would  have  been  unable  to  meet  its 
extensive  needs  for  modernising  external  borders  infrastructure,  a  current  government 
priority (145).  Similarly,  Romania  reported  that  it  would  have  struggled  to  meet  the 
Schengen border control standards,  as national  budget  alone could  not  adequately have 
supported  essential  IT  and  infrastructure  needs (146).  Spain  reported  that,  without  the 
Instrument, only minimum border and visa requirements would have been met, far short 
of the efficiency and speed achieved with the ISF-BV support, such as the modern ABC 
gates  and  biometric  systems  that  enable  streamlined  border  crossings. (147).  Norway 
similarly noted that without the EU support provided through the ISF-BV, some projects 
would have been postponed or scaled down. This funding made it possible to prioritise key 
actions and maintain high standards in visa and border management (148). Notably, without 
the support provided by the Specific Actions, activities implemented by Belgium would 
reportedly  have  been  more  limited  and  would  have  lacked  the  broader  international 
collaboration  that  the  Union  framework  enabled (149).  Finally,  Croatia  highlighted  the 
importance of Union support, especially through EMAS as a critical solution for filling 
financial gaps resulting from changing activities at its external border (150). 

In seven Member States, essential actions to comply with EU policies would still have 
been undertaken, albeit with reduced reach, quality, and timeliness due to the absence of 
EU funding (151). For instance, while the Czech Republic, Germany, Estonia, Hungary, 
Lithuania,  Luxembourg,  the  Netherlands,  and  Slovakia  would  have  implemented 
necessary measures, the scale and efficiency of these actions would have been significantly 
compromised. Many activities would proceed at a slower pace, leading to delays in high-
priority projects and limited resources for critical IT systems and data sharing initiatives. 

(141) National ex-post evaluations for Belgium, Switzerland, Latvia, Lithuania, France, Finland, Italy, 
Liechtenstein, the Netherlands. 
(142) AIR 2023 for Slovakia, National ex-post evaluation for Poland, Czech Republic, Germany and Iceland. 
(143) Country case study: Italy. 
(144) National Ex-post Evaluation: Sweden. 
(145) Country case study: Poland. 
(146) Country case study Romania. 
(147) Country case study Spain. 
(148) Country case study Norway. 
(149) Thematic case study: Specific Actions. 
(150) Country case study: Croatia. 
(151) National ex-post evaluation for: Czech Republic, Germany, Estonia, Hungary, Lithuania, Luxembourg, the 
Netherlands, Slovakia. 

67 

 
 
Overall, the lack of EU support would hinder the effectiveness of compliance efforts across 
these countries. 

Notably, only Lichtenstein and Switzerland reported that they would have been able to 
carry  out  all  necessary  activities  to  comply  with  Schengen  requirements  without  the 
support of the ISF-BV, although in the case of Lichtenstein, these actions would have been 
less innovative (152). 

Consequences of an interruption of the support provided by ISF-BV 

Eighteen  Member  States  plus  Iceland  and  Norway  reported,  in  the  national  ex-post 
evaluations,  that  an  interruption  in  Instrument  support  would  pose  challenges,  risking 
setbacks to critical operations, while only Switzerland and Lichtenstein reported that an 
interruption of the Instrument would only have minor consequences (153).   

In  Italy,  for  example,  discontinuation  of  the  ISF-BV  could  force  a  cut  back  on 
technologically advanced tools and potentially a scaling down of operational scope (154). 
Sweden  would  also  see  diminished  capacity  for  crime  detection  and  international 
collaboration.  Projects  like  EUROSUR  II,  which  aim  to  enhance  national  reporting  to 
Frontex and contribute to the achievement of several Schengen requirements, are crucial 
for  Sweden's  secure  border  management.  A  funding  interruption  would  likely  diminish 
Sweden's  ability  to  comply  with  EU  border  control  standards (155).  Croatia  also  voiced 
concerns  over  reduced  efficiency  in  border  and  visa  management  should  the  ISF-BV 
funding cease. Beneficiaries noted that relying solely on national resources could lead to 
reduced  priority  actions  and  compromise  the  final  quality  of  outputs (156).  Romania 
emphasised that without the ISF-BV funding, the country would struggle to maintain its 
border surveillance capabilities along the EU’s Eastern frontier, critical for both Romanian 
and EU citizens’ security (157). Spain highlighted that the high-standard systems currently 
supporting swift border processing could not be maintained, risking delays in visa issuance 
and border crossings by reverting to outdated processes (158). Norway noted the importance 
of  the  ISF-BV  as  a  catalyst  for  otherwise  delayed  or  reduced  projects,  stressing  the 
operational setbacks that would accompany a funding interruption (159). 

Belgium, Estonia, Finland, Lithuania would face challenges in maintaining the scale of 
their IT projects, which are essential for meeting EU regulatory obligations and improving 
data sharing. Without EU funding, the pace of modernisation would slow down, reducing 
efficiency  in  border  management (160).  In  countries  such  as  Cyprus  and  the  Czech 
Republic, where national budgets are more constrained, the interruption of support would 
force authorities to scale down or delay essential investments in surveillance equipment, 
infrastructure, and training (161). In Luxembourg, Sweden and the Netherlands, although 
the national budget is not as constrained, initiatives would still need to be downsized (162). 
Germany, France, Hungary, Iceland, Malta, Poland would experience delays in high-

(152) National ex post evaluation for: Lichtenstein and Switzerland.  
(153) National ex-post evaluation. 
(154) National Ex-post Evaluation: Italy. 
(155) National Ex-post Evaluation: Sweden. 
(156) Country case study: Croatia. 
(157) Country case study: Romania. 
(158) Country case study: Spain. 
(159) Country case study: Norway. 
(160) National ex-post evaluation. 
(161) National ex-post evaluation.  
(162) National ex-post evaluation. 

68 

 
 
priority initiatives related to compliance with EU requirements, as well as limitations in 
information  exchange  and  data  infrastructure  development (163).  Non-permanent  tasks, 
which are often dependent on EU funding, would be particularly vulnerable. 

Union-level benefits resulting from actions funded by the Instrument 

The funded  actions  have collectively  contributed to  Union-level  benefits,  with  Member 
States achieving outcomes that reinforce the Schengen area’s operational stability. Sixteen 
Member States were able to enhance their border security, leading to an overall enhanced 
border  security  management  and  harmonisation  of  procedures  at  the  EU  level (164).  For 
example, Italy’s initiatives strengthened consular capacities and Schengen visa issuance 
procedures,  ensuring  seamless  operations  in  the  VIS  system  that  benefit  all  Schengen 
States (165). In Sweden, projects such as EUROSUR II improved intelligence sharing and 
response to border threats. The integration of these systems within EU security frameworks 
also  elevated  Sweden’s  and  the  EU's  collective  border  management  capabilities, 
reinforcing the European Area of Freedom, Security, and Justice (166). Greece’s use of the 
ISF-BV to support transnational actions and interoperability of IT systems has bolstered 
Union-wide benefits by improving cooperation on visa policies and border management. 
These  efforts  align  with  the  EU's  shared  responsibilities  under  the  EBCG  Regulation, 
ensuring a more integrated and efficient approach to  external  border control (167).  Spain 
underscored  the  ISF-BV’s  role  in  harmonising  border  security  approaches  across  the 
Schengen area, facilitated by advanced systems such as the SIS and VIS, creating faster 
interconnected processes that streamline border checks (168). Norway highlighted that in-
person  consular  training  enabled  by  the  Instrument  has  improved  service  quality,  with 
beneficiaries  reporting  that  face-to-face  engagement  fosters  ongoing  cross-border 
communication, which  in turn  enhances  EU-level  operational  coordination in  migration 
and visa policies (169). Moreover, as discussed in the answer to the previous EQ, the ISF-
BV initiatives resulted in enhanced cooperation among Member States, clearly providing 
benefits  at  the Union level,  as the enhanced cooperation led to  an improvement in  visa 
management and border control at the EU-level (170).  

11  EU  Member  States  reported  that  the  ISF-BV  implementation  led  to  enhanced 
cooperation  among  Member  States  at  the  EU  level (171).  In  addition,  Switzerland, 
Lichtenstein and Norway managed to strengthen their cooperation with the EU through the 
ISF-BV initiatives (172). With regard to cooperation beyond the EU, as confirmed by EU-
level  stakeholders, 
long-term  professional 
engagements between EU Member States and third countries (173). In this regard, Specific 
Actions  also  played  a  pivotal  role.  For  instance,  the  Consular  Cooperation  Mechanism 
(CCM) provided Belgium and other Member States with a framework to jointly address 
issues such as document forgery and visa shopping, further proving that shared resources 

implementation  fostered 

the  ISF-BV 

(163) National ex-post evaluation. 
(164) National ex-post evaluation for: Austria, Switzerland, Estonia, Spain, Finland, France, Iceland, Italy, 
Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Slovenia, Slovakia. 
(165) National Ex-post Evaluation: Italy. 
(166) National Ex-post Evaluation: Sweden. 
(167) Country case study: Italy, Greece. 
(168) Country case study:  Spain 
(169) Country case study: Norway. 
(170) National ex-post evaluation.  
(171) National ex-post evaluation for: Austria, Belgium, Germany, Finland, Luxembourg, Malta, Poland, Slovenia, 
Slovakia, Czech Republic, Sweden.  
(172) National ex-post evaluation for: Switzerland, Lichtenstein, Norway. 
(173) EU-level interviews: Interview 1, Interview 10.  

69 

 
 
and intelligence could strengthen the security and integrity of Schengen visas (174). This 
enhanced cooperation led to an improvement in visa management and border control at the 
EU-level, with clear benefits for the Union.  

Survey  results,  however,  show  a  lack  of  awareness  causing  a  limited  perception  of  the 
direct benefit of funded actions at the Union level (175). National Authorities, while largely 
unaware  of  specific  policy  changes  prompted  by  the  ISF-BV,  did  acknowledge  some 
impacts.  For  example,  Estonia  and  Lithuania  reported 
that  ISF-BV-supported 
advancements  led  to  alignment  with  Union  initiatives  such  as  EES  and  ETIAS,  which 
necessitated legal adjustments and infrastructure improvements to meet Union standards. 
However,  other  stakeholders  and  beneficiaries  were  generally  less  aware  of  ISF-BV’s 
policy influence. Although a few examples, such as Belgium’s adoption of the ETIAS law 
and France’s reference to the Community Visa Code, highlight some influence, the limited 
awareness across these groups suggests that ISF-BV contributions to Union-level benefits 
might be understated.  

Added value of operating support 

Operating support under the ISF-BV proved to be instrumental to ensuring the smooth and 
secure  operation  of  critical  border  management  and  visa  systems  across  the  EU.  This 
support encompassed expenses related to operations, personnel, and services, as well as 
the  enhancement  or  replacement  of  equipment,  real  estate,  and  the  management  of 
operational systems, including the SIS, VIS, and any systems to be introduced. Reportedly, 
multiple Member States used operating support to improve the IT infrastructure and ensure 
system stability (176). At the same time, the importance of operating support in maintaining 
service continuity above all in light  of 2022 events  was highlighted, when the Member 
States  were  dealing  with  both  COVID-19  challenges  and  heightened  border  control 
needs (177). In this regard, despite the pressures of pandemic restrictions on travel, funds 
allocated  to  operational  support  kept  systems  and  equipment  functioning  optimally, 
ensuring  that  security  and  visa-processing  capabilities  remained  uninterrupted.  The 
financial support provided by the  ISF-BV  for operational  costs  also  acts as a solidarity 
mechanism, assisting Member States with extensive external borders by subsidising high-
cost infrastructure and maintenance needs. By way of example:  

•  Finland:  Operating  support  helped  fund  new  automated  control  points  at  high-
traffic areas like Helsinki-Vantaa International Airport, which improved both visa 
and border control processing efficiency (178). 

•  Poland: Under operating support, the project “Purchase of mobile sets controllers 
for cooperation with SIS/VIS systems” enabled the replacement of equipment and 
software for border traffic control, thus enhancing state border protection (179). 

•  Romania: Operating support enabled the implementation of projects that enhanced 
border control and surveillance capabilities. In particular, these projects improved 

(174) Thematic case study: Specific Actions. 
(175) Targeted survey at National Authorities, Beneficiaries and Other Stakeholders: Q38 – Q26 – Q31. 
(176) National Programmes: Belgium, France, Croatia, Sweden; Annual Implementation Reports: Hungary; 
National ex-post evaluations: Austria, Germany. 
Country case studies: Czech Republic, Italy, Romania. 
(177) Annual Implementation Report: Finland. 
(178) Annual Implementation Report: Finland. 
(179) AIR 2023. 

70 

 
 
intervention  capacity  in  border  areas  and  contributed  to  the  Union  uniform  and 
high-quality control of external borders (180). 

•  Belgium:  Operating  support  enabled  sustainable  financing  for  strategic  projects, 
improving  the  quality  of  services  and  ensuring  that  Belgium  can  meet  its 
obligations effectively (181). 

•  Spain:  Operating  support  enabled  the  financing  of  essential  operational  costs, 
ensuring that public authorities can maintain and improve their services in line with 
EU objectives (182). 

• 

• 

In  Italy  and  Malta,  operating  support  provided  essential  funding  for  the 
maintenance and upgrading of border management systems (e.g. the VIS system), 
ensuring that both could meet their obligations effectively (183). 

In  Norway  and  Luxembourg, operating support improved the capacity of public 
authorities by funding the development of crisis management procedures and new 
IT systems (184). 

•  Lithuania: Operating support was used to upgrade IT and communication systems, 
ensuring  that  border  guards  and  visa  services  could  operate  effectively.  This 
includes  maintaining  and  updating  systems  essential  for  monitoring  and 
documentation verification (185). 

Overall, the main added value of operating support is that it ensures that both visa 
processing and border security systems are fully operational, contributing to simplified 
means to achieve the strategic goals of the ISF-BV programme and enhancing the EU’s 
border and visa management capabilities.  

4.2.2  Sustainability 

Are the positive effects of the projects supported by the Instrument likely to last when 
the support from ISF will be over? 

Available  evidence  suggests  that  the  positive  effects  of  ISF-BV-supported  projects  are 
likely to last beyond the funding period, particularly where sustainability was prioritised 
from  the  outset  through  capacity-building,  alignment  with  national  strategies,  and  the 
integration of project outputs into long-term operational frameworks. While the extent and 
consistency  of  these  efforts  varied,  most  Member  States  implemented  concrete 
mechanisms - such as maintenance planning, training programmes, and oversight tools - 
that support continued use of ISF-funded infrastructure, equipment, and systems. 

The  evaluation  identified  strong  sustainability  trends  in  Member  States  where  national 
authorities  required  sustainability  plans  at  the  application  stage,  embedded  post-
completion assessments into implementation frameworks, and allocated national funding 
to  ensure  continuity.  Capacity-building  efforts  -  notably  in  IT,  border  control,  and  visa 
management  -  also  contributed  to  long-term  impact,  though  follow-up  mechanisms  to 

(180) Country case study: Romania. 
(181) National ex-post evaluation: Belgium. 
(182) National ex-post evaluation: Spain. 
(183) National ex-post evaluation: Italy and Malta. 
(184) National ex-post evaluation: Norway and Luxembourg. 
(185) National ex-post evaluation: Lithuania. 

71 

 
 
assess knowledge  retention were often missing. The integration of  ISF-BV investments 
into national security strategies further reinforced their durability. At the same time, some 
challenges remain. The monitoring of sustainability was not systematic across all Member 
States,  and  in  some  cases,  reliance  on  national  budgets  for  maintenance  of  high-cost 
infrastructure – particularly of IT systems - poses a potential risk to long-term viability. 
Where reliance on Union funding is high, sustainability may be more fragile in the absence 
of structured financial  planning. The  Instrument’s  operating support instrument enables 
long-term use of infrastructure and systems by covering maintenance and staffing costs. 
Notably,  the  overlap  between  the  ISF-BV  and  the  BMVI  (2021–mid-2024)  ensures 
continuity  in  funding  for  infrastructure,  equipment,  and  large-scale  IT  systems.  This 
combination  of  flexible  funding  and  transition  mechanisms  was  critical  to  sustaining 
investments beyond the original project timeframe. A detailed analysis of the mechanisms 
and outcomes underpinning project sustainability is presented in the answers to the sub-
questions below.  

4.2.2.1  Assessment of mechanisms to ensure sustainability 

Evidence from country case studies, surveys, annual implementation reports, and ex-post 
evaluations  of  the  national  programmes  indicates  that  Member  States  integrated 
sustainability considerations directly into project planning phases, requiring beneficiaries 
to  present  sustainability  strategies  for  continued  impact,  although  the  depth  and 
consistency of these efforts varied. It is important to note that this analysis is based on the 
subset of countries for which relevant data on sustainability was available  – namely, all 
eight  country  case  studies,  five  of  the  90  annual  implementation  reports,  25  ex-post 
evaluation reports, and three online survey responses.  

Further evidence from ex-post evaluation reports of national programmes confirms that in 
addition  to  requiring  beneficiaries  to  plan  for  post-funding  sustainability,  four  Member 
States  embedded  sustainability  considerations  into  national  funding  strategies  from  the 
outset.  For  instance,  Finland (186)  and  Estonia (187)  required  applicants  to  submit 
sustainability plans when applying for the ISF-BV support, ensuring that operational costs 
would  be  covered  through  national  budgets  beyond  the  funding  period.  Similarly, 
Belgium (188) and the Netherlands (189) linked project selection to their integration within 
broader European and national security frameworks, reinforcing long-term sustainability 
through  institutional  anchoring.  For  other  Member  States,  the  available  reports  do  not 
explicitly indicate whether sustainability was embedded in national funding strategies from 
the  beginning.  While  various  sustainability  measures  were  implemented  during  project 
execution,  it  remains  unclear  whether  these  were  systematically  planned  at  the 
programming stage. These aspects are further analysed in the following paragraphs, where 
specific measures adopted during implementation are examined in more detail. 

Complementing these trends, evidence from interviews and individual country case studies 
also suggests that at the project design level, specific sustainability project outputs were 
embedded into the project application and selection process. For instance, in Bulgaria and 
Poland,  applicants  were  required  to  define  a  “sustainability  period”  during  which  the 
project would remain operational – typically three years for IT systems and up to ten years 
for  infrastructure  projects (190).  Sustainability  plans  were  formalised  during  project 

(186) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Finland. 
(187) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Estonia. 
(188) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Belgium. 
(189) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Netherlands. 
(190) Interview with Bulgarian responsible authority (Interim Evaluation of the ISF-BV). 

72 

 
 
planning  to  ensure  alignment  with  national  priorities  and  resources,  promoting  the 
integration  of  projects  into  long-term  frameworks.  In  Italy,  beneficiaries  were  asked  to 
describe  how  project  outcomes  would  be  sustained  over  a  five-year  period,  with  many 
indicating reliance on national funds (191). This approach aimed to align ISF-BV-funded 
actions  with  national  priorities  and  facilitate  their  integration  into  long-term  security 
planning, thereby laying the groundwork for continuity after the funding period. 

The analysis of ex-post evaluation reports of the national programmes has revealed that a 
common trend among 10 countries was the establishment of sustainability checks at the 
implementation stage through national oversight mechanisms. Estonia (192), Lithuania (193), 
and  Finland (194)  embedded  sustainability  monitoring  into  their  national  implementation 
programmes, requiring periodic project assessments beyond the funding period. Similarly, 
Luxembourg (195) and Malta (196) committed national budgets to finance operational costs 
where ISF funding was no longer available, ensuring the continued use of infrastructure, 
IT  systems,  and  security  equipment.  Furthermore,  the  Czech  Republic (197)  and 
Hungary (198) introduced project-level sustainability indicators, requiring beneficiaries to 
maintain performance levels through mandatory reporting and sample checks. Additional 
Member  States  implemented  sustainability  oversight  measures  through  structured 
evaluations,  reporting  requirements,  and  standardised  procedures.  Compliance  with 
sustainability  obligations  was  ensured  in  some  cases  through  ex-post  evaluations  on 
selected  ISF-funded  projects,  extending  monitoring  beyond  project  completion 
(Poland) (199).  Sustainability  assessments  were  also  embedded  into  final  reporting 
frameworks,  creating  a  formalised,  though  less  frequent,  mechanism  for  national-level 
oversight (Sweden) (200). In some cases, sustainability monitoring was reinforced through 
standardised  training  materials  and  procedural  guidelines,  helping  to  maintain  project 
results in the long term (Norway) (201). For other Member States, the available reports do 
not  provide  sufficient  details  on  whether  national  oversight  mechanisms  were 
systematically implemented. 

Evidence from five out of eight country case studies indicates that, at the implementation 
stage,  Member  States  implemented  mechanisms  to  monitor  and  verify  project 
sustainability  through  a  structured  framework.  In  Poland,  the  responsible  authority 
monitors the sustainability of projects with minimum operational period based on project 
type  (e.g.,  three  years  for  IT  systems,  five  years  for  vehicles,  and  ten  years  for  larger 
infrastructure).  In  some  cases,  such  requirements  also  reflected  EU-level  expectations, 
particularly for border surveillance equipment included in the Technical Equipment Pool 
(TEP) coordinated by Frontex. Through this monitoring mechanism, Poland ensures that 
equipment and infrastructure funded by the ISF-BV are maintained and remain functional 
well  beyond  the  project’s  end  date (202).  Similarly,  Romania  incorporated  ex-post 
verification, allowing for annual durability assessments that ensure infrastructure and IT 

(191) Country case study – Italy. 
(192) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Estonia. 
(193) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Lithuania. 
(194) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Finland. 
(195) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Luxembourg. 
(196) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Malta. 
(197) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Czech Republic. 
(198) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Hungary. 
(199) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Poland. 
(200) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Sweden. 
(201) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Norway. 
(202) Country case study – Poland. 

73 

 
 
systems remain functional for their intended lifespan (203). Another sustainability-focused 
approach  during  implementation  involved  provisions  for  technical  support  to  reduce 
ongoing maintenance costs, as well as staff training sessions that contributed to long-term 
sustainability  by  equipping  personnel  to  operate  new  equipment,  such  as  Coast  Guard 
vessels  (Greece) (204).  In  some  cases,  such  as  in  infrastructure  projects,  operational 
continuity was supported through ongoing staff training and operational support measures 
to maintain service delivery (205). This combination of technical support and skills transfer 
underlines the commitment to fostering the continued effectiveness of project outcomes 
post-ISF-BV. While some equipment, such as IT software, may need updates over time, 
beneficiaries had accounted for long-term maintenance by integrating these requirements 
into  national  budgets  (Croatia).  As  highlighted  in  the  Croatian  country  case  study, 
beneficiaries expressed confidence that these projects would remain effective beyond the 
ISF-BV  funding  period  due  to  their  alignment  with  larger  national  frameworks  and 
ongoing  projects,  such  as  active  2021-2027  BMVI  projects  that  build  upon  ISF-BV 
achievements (206). 

Evidence from four annual implementation reports covering two Member States illustrates 
how robust national monitoring frameworks can contribute to the long-term sustainability 
of  ISF-BV-supported  projects.  In  these  cases,  beneficiaries  were  legally  required  to 
maintain  achieved  target  values  and  meet  designated  monitoring  indicators,  subject  to 
regular compliance checks. In Poland, for instance, these sustainability obligations were 
enforced  through  administrative  and  on-site  inspections,  reinforcing  the  national 
commitment  to  post-project  impact (207).  In  the  2022  financial  year  alone,  six  project 
sustainability  audits  were  conducted  to  verify  compliance.  Similarly,  in  Czechia, 
beneficiaries were required to report on both set and statistical indicators throughout and 
after the project period, with the responsible authority tasked with overseeing and verifying 
reported outcomes (208). While limited to a small sample of Member States, these examples 
highlight  the  potential  role  of  structured  compliance  mechanisms  in  enhancing  the 
durability of project results. 

One of the trends observed in limited number of ex-post evaluation reports of the national 
programmes  across four  countries was  the  reliance on EU funding as a  complementary 
mechanism for long-term sustainability. While Slovenia (209) and Slovakia (210) highlighted 
that national budget constraints limited the ability to sustain projects at the same scale post-
ISF, they ensured continuity by integrating ISF-supported infrastructure and IT systems 
such  as  Germany (211)  and 
into  national  operations.  Additionally,  countries 
Liechtenstein (212) leveraged their obligations under Schengen regulations to maintain and 
update  security  systems,  ensuring  compliance-driven  sustainability  beyond  the  funding 
period. 

Online survey responses from national authorities within Member States suggests that the 
efforts were made to establish sound sustainability measures at both the programming and 

(203) Country case study – Romania. 
(204) Country case study – Greece. 
(205) Country case study – Spain. 
(206) Country case study – Croatia. 
(207) Annual implementation report for the financial year 2022 of Poland National Program ISF. 
(208) Annual implementation reports for the financial years 2020, 2021 and 2022 of Czech National Programme 
ISF. 
(209) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Slovenia. 
(210) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Slovakia. 
(211) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Germany. 
(212) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Lichtenstein. 

74 

 
 
implementation stages, although a majority either did not know or preferred not to answer. 
In  the  survey,  16%  of  respondents  confirmed  that  they  had  adopted  comprehensive 
measures,  and  an  additional  14%  had  moderately  adopted  measures  to  ensure  the 
continuity of ISF-BV project results, including long-term strategic planning, investments 
in infrastructure, and integration with national budgets. Some respondents highlighted the 
use of specific earmarking periods to sustain resources for up to ten years, depending on 
the type of project. For instance, as specified in the responses to the survey, IT equipment 
is often required to be maintained for a minimum of three years, while infrastructure assets 
are expected to remain operational for up to ten years (213). A further 10% indicated that 
they had not yet adopted such measures but planned to do so. 4% declared no consideration 
of  specific  sustainable  measures,  while  the  majority  -  57%  -  either  did  not  know  or 
preferred not to answer. 

In summary, these examples reflect a common strategy across the Member States to embed 
sustainability  measures  in  both  the  programming  and  implementation  phases,  thereby 
enhancing  the  likelihood  of  sustained  impact.  Through  mechanisms  like  required 
maintenance  plans,  alignment  with  national  priorities,  and  periodic  post-completion 
monitoring, Member States have taken structured steps to ensure that the benefits of ISF-
BV-funded projects extend well beyond the initial funding period. 

Evidence from the ex-post evaluation reports, country case studies, and online survey of 
national  authorities  suggests  that  capacity-building  and  training  activities  played  a 
meaningful role in enhancing the sustainability of ISF-BV supported projects. 

for 

IT  system  maintenance.  Finland (218) 

As explicitly highlighted in 12 ex-post evaluations of the national programmes, this trend 
was further reinforced by national strategies emphasising long-term knowledge retention. 
Norway (214)  and  Sweden (215)  standardised  training  materials  to  ensure  their  usability 
beyond the funding period, while Lithuania (216) and Luxembourg (217) developed technical 
training  programmes 
institutionalised 
sustainability reporting as part of project evaluations, ensuring that capacity-building was 
monitored  as  a  key  factor  in  project  impact.  Additionally,  Hungary (219)  introduced 
maintenance  reports  as  part  of  long-term  project  assessments,  verifying  that  trained 
personnel  continued to  apply  acquired skills.  Across  other Member States, training and 
capacity-building  efforts  were  widely  implemented,  but  their  integration  into  long-term 
sustainability strategies varied. In some cases, training was tied directly to specific ISF-
funded  projects,  ensuring  that  personnel  were  equipped  to  operate  new  systems  and 
technologies,  but  without  structured  follow-up  mechanisms  to  evaluate  long-term 
knowledge  retention  (Spain,  Estonia,  Malta) (220).  Germany  incorporated  training  into 
broader security frameworks, aligning it with existing institutional structures, yet without 
dedicated  follow-up  measures  to  assess  its  continued  impact (221). Some  Member  States 
assumed  that  skills  transfer  would  be  maintained  organically  by  integrating  trained 

(213) Results from the online survey. 
(214) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Norway. 
(215) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Sweden. 
(216) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Lithuania. 
(217) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Luxembourg. 
(218) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Finland. 
(219) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Hungary. 
(220) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Spain, Estonia, Malta. 
(221) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Germany. 

75 

 
 
personnel into national agencies or operational structures, but without formalised policies 
or monitoring frameworks to ensure continuity (Poland, Iceland) (222). 

Although  the  country  case  studies  did  not  provide  detailed  accounts  of  staff  training 
activities,  making  it  difficult  to  assess  their  overall  scale,  several  nonetheless  included 
examples suggesting that training contributed to project sustainability. In particular, cases 
from Greece, Spain, Poland, Romania, and Croatia highlighted how trained personnel were 
able to support the continued operation of systems and infrastructure beyond the funding 
period.  Many  trained  personnel  are  now  equipped  to  independently  manage  acquired 
systems  and  infrastructure.  Sustained  capacity-building  activities,  including  training  for 
border and coast guard personnel, were designed to create enduring knowledge and skill 
sets  that  could  be  leveraged  beyond  ISF-BV  support (223).  Training  programmes  were 
designed  not  only  to  improve  operational  skills  but  also  to  encourage  a  high  level  of 
knowledge  retention  and  institutional  expertise  within  the  national  authorities.  For 
instance, personnel trained in EU visa policy under the ISF-BV have taken on leadership 
roles in the Polish Ministry of Foreign Affairs, overseeing the implementation of EU IT 
systems  related  to  visa  processes (224).  However,  evidence  also  highlights  that  ongoing 
capacity-building  is  needed in  areas requiring regular updates and investments,  such as 
technical support for IT infrastructure and consular training due to changing regulations 
and staff rotations (225).  

Online survey feedback highlights the perceived effectiveness of training in supporting the 
sustainability of ISF-BV projects. Several survey respondents noted that training sessions 
provided  essential  skills  that  enabled  staff  to  independently  manage  acquired  systems, 
especially  in  areas  requiring  ongoing  technical  expertise  such  as  IT  infrastructure  and 
border security (226). 

4.2.2.2  Assessment of action and result sustainability 

Outcomes  from  ISF-BV  projects,  particularly  in  infrastructure  and  equipment,  show  a 
positive  trend  towards  sustainability.  Evidence  from  ex-post  evaluations  of  national 
programmes  confirms  this  positive  sustainability  trend  in  at  least  seven  countries (227), 
where  national  authorities  have  secured  operational  budgets  and  embedded  ISF-funded 
investments into routine operations. Infrastructure and equipment, including surveillance 
systems, border control technology, and IT solutions, have been integrated into national 
security  frameworks,  ensuring  their  continued  use (228).  In  Lithuania,  Norway,  and 
Luxembourg,  investments  in  fixed  assets  such  as  biometric  systems,  automated  border 
control,  and  mobile  identity  verification  devices  have  been  prioritised  for  long-term 
operational  planning (229).  Additionally,  Sweden (230)  has  ensured  sustainability  through 
structured  maintenance  agreements,  while  Iceland (231)  secured  operational  budgets, 
allowing continued functionality beyond the ISF-BV period. Malta has further reinforced 
sustainability  commitments  through  legally  binding  obligations  requiring  the  continued 
use  of  ISF-funded  infrastructure  for  extended  periods,  while  Luxembourg  has  ensured 

(222) Ex-post evaluation of the National Programme of the ISF 2014-2020 – Poland, Iceland. 
(223) Country case studies – Greece, Spain, Romania and Croatia. 
(224) Country case study – Poland. 
(225) Country case study – Norway. 
(226) Results from the online surveys. 
(227) Slovakia, Sweden, Lithuania, Norway, Luxembourg, Malta, and Iceland. 
(228) Ex-post evaluation of the National Programme – Slovakia, Sweden, Lithuania, Norway, Luxembourg, Iceland. 
(229) Ex-post evaluation of the National Programme – Lithuania, Norway, Luxembourg. 
(230) Ex-post evaluation of the National Programme – Sweden. 
(231) Ex-post evaluation of the National Programme – Iceland. 

76 

 
 
sustainability  through  long-term  commitments  integrated  into  national  and  EU  security 
frameworks  (232).  

Further case study evidence from Croatia, Greece, and Norway suggests that infrastructure 
investments in equipment and IT systems are designed to have enduring impacts, as these 
systems  were  explicitly  selected  based  on  national  needs  aligned  with  EU  security 
objectives. In Greece, staff training and technical support have helped ensure that the Coast 
Guard can continue operating new vessels acquired under the ISF-BV (233). Furthermore, 
Member States, such as Italy and Poland, have indicated commitments to utilise national 
funds for the maintenance of infrastructure and systems acquired through ISF-BV projects, 
highlighting  a  strategy  aimed  at  ensuring  long-term  sustainability  beyond  the  Union 
funding period (234). 

However, reliance on ISF-BV support for technical and operational expenses may present 
a sustainability challenge, especially for projects involving high-cost maintenance items 
such as IT systems  and specialised equipment.   The ex-post evaluations  of the national 
programmes of Spain and Cyprus highlight ongoing maintenance costs as a key concern, 
particularly where national budgets are constrained. Additionally, the ex-post evaluation 
of  Liechtenstein  notes  that  while  some  security  systems,  such  as  ETIAS  and  EES,  are 
expected to have a long-term impact, their sustainability cannot yet be determined with 
certainty, reinforcing the importance of structured national funding mechanisms to ensure 
continuity. 

Operating support mechanisms within the ISF-BV have proven essential for maintaining 
infrastructure and IT systems, yet stakeholder feedback highlights the need for improved 
long-term planning. 

The  analysis  of  all  ex-post  evaluations  of  national  programmes  further  emphasises 
measures  taken  to  ensure  the  continuity  of  ISF-supported  activities  through  operating 
support,  though  only  in  a  limited  number  of  reports.  As  previously  noted,  securing 
operational  budgets  and  establishing  structured  maintenance  agreements  have  allowed 
security-related  infrastructure  and  IT  systems  to  remain  functional  beyond  the  ISF-BV 
period (Sweden, Luxembourg) (235). Additionally, in Norway, maintenance costs for ISF-
funded  equipment  have  remained  manageable,  ensuring  continued  use  within  national 
security frameworks (236). Some Member States have further reinforced sustainability by 
embedding maintenance planning into national security policies or leveraging additional 
funding  sources  to  cover  ongoing  costs  (Luxembourg,  Cyprus).  However,  challenges 
persist where reliance on Union funding remains high, particularly for the upkeep of high-
maintenance  assets  such  as  surveillance  systems  and  border  management  technology, 
raising concerns over financial sustainability post-ISF-BV (Cyprus, Liechtenstein). 

The ISF-BV operating support was instrumental to covering the costs associated with the 
upkeep of critical infrastructure and IT systems, ensuring that project outcomes continued 
even after the end of initial funding. The operating support, as outlined in Regulation (EU) 
No 515/2014, allows Member States to allocate up to 40% of their national programme 
budgets  to  support  ongoing  operational  activities.  This  includes  funding  for  staff  costs, 
training,  maintenance  of  equipment,  IT  systems  management,  and  infrastructure 

(232) Ex-post evaluation of the National Programme – Malta, Luxembourg. 
(233) Country case studies – Croatia, Greece and Norway. 
(234) Country case studies – Italy and Poland. 
(235) Ex-post evaluation of the National Programme – Sweden, Luxembourg. 
(236) Ex-post evaluation of the National Programme – Norway. 

77 

 
 
upkeep (237). Notably, the practical overlap in the implementation periods of ISF-BV and 
the BMVI - spanning approximately three and a half years from 2021 to mid-2024 - has 
helped  to  ensure  continuity  in  funding  for  maintenance  costs  related  to  infrastructure, 
equipment, and large-scale IT systems. This overlap provided a bridge for Member States 
to continue financing essential functions beyond the original ISF-BV timeframe. 

Examples  from  three  country  case  studies  illustrate  how  operating  support  has  been 
effectively utilised to sustain critical functions. In Greece, for instance, operating support 
played  a  pivotal  role  in  ensuring  the  maintenance  and  repair  of  Coast  Guard  vessels 
acquired  through  the  ISF-BV.  These  vessels  were  essential  for  maritime  border 
surveillance, and the allocated funds ensured they remained fully operational even after 
the  initial  project  funding  had  ended.  Greek  stakeholders  emphasised  that  without  this 
operating support, the ability to maintain these high-cost assets would have been severely 
compromised,  potentially  undermining  border  management  efforts (238).  Similarly,  in 
Poland operating support was utilised to maintain critical IT systems essential for efficient 
border control and visa management. This included covering service costs, staff training, 
and  system  upgrades  necessary  to  keep  these  systems  operational  beyond  the  project 
funding  period (239).  In  Spain,  operating  support  was  also  leveraged  to  enhance  staff 
capabilities,  particularly  through  training  programmes  aimed  at  building  long-term 
institutional knowledge. The focus on capacity-building ensured that personnel managing 
border  control  systems  were  adequately  trained  to  handle  the  equipment  and  systems 
independently. Spanish authorities noted that this investment in human resources not only 
improved the immediate effectiveness of border management operations but also helped 
secure the long-term sustainability of these initiatives by reducing their reliance on external 
technical support (240). 

4.3 

Is the intervention still relevant? 

4.3.1  Relevance 

Did the objectives of the interventions funded by the ISF-BV correspond to the actual 
needs? 

4.3.1.1  Member States’ programmes’ objectives addressed identified needs. 

The  design  of  the  Member  States’  national  programmes  was  supported  by  a 
consultation process, which ensured that the programmes’ priorities and objectives 
responded to the key needs identified at the EU and national level at the time of their 
adoption. At the EU level, the consultation process consisted of a policy dialogue between 
the  Commission  and  the  Member  States,  which  took  into  account  the  difficulties 
encountered  during  the  EBF  programming  cycle  (2007-2013)  as  well  as  the  new  and 
emerging  needs  foreseen  at  the  time  of  the  ISF-BV.  At  the  national  level,  needs 
assessments were conducted with key national stakeholders to develop national objectives 
and prioritise the actions most relevant to their national needs. The process varied across 
Member  States  but  typically  included  an  assessment  of  national  strategic  documents 
defining  long-term  goals  and  priorities  and  consultations  with  potential beneficiaries  to 
collect their input. This  was confirmed through the country case studies and the survey 
with implementing national authorities, whereby respondents for 10 of the 13 countries 

(237) Annex III, of the ISF-BV regulation. 
(238) Country case study – Greece. 
(239) Country case study – Poland. 
(240) Country case study – Spain. 

78 

 
 
represented in the survey confirmed having conducted a needs assessment prior to drafting 
their national Programme (respondents of the remaining countries replied not knowing).  

Figure 19 - Number of Member States that conducted needs assessment (N=16) 

A needs assessment was conducted during the
implementation of the national programme…

A needs assessment was conducted prior to the
drafting of the national programme

0

2

4

6

8

10

12

14

16

18

Yes

No

I don't know

Source: survey of national authorities 

This  was  also  confirmed  by  country-level  evaluation  reports,  which  highlighted  the 
bottom-up approach to programme design, i.e. the involvement of relevant stakeholders 
and  potential  beneficiaries  that  allowed  for  the  identification  of  real  needs  and  the 
development  of  relevant  objectives  (for  instance  in  Austria,  Czechia,  Spain  and  the 
Netherlands). The programmes were also developed to address specific priorities, such as 
compliance with Schengen acquis (e.g., Iceland and Liechtenstein) or acquisition of digital 
technologies (Italy). 

The objectives and activities of Member States’ national programmes addressed the 
key needs of the EU and its Member States throughout the ISF-BV’s implementation. 
Stakeholders consulted confirmed the alignment of Member States’ national programmes 
with their needs, noting that the ISF-BV objectives and scope of activities were sufficiently 
broad to enable the national programmes to be tailored to the specific needs of Member 
States.  

Regarding the national programmes’ objectives, the stronger importance given to border 
management  compared  to  visas  was  positively  highlighted,  enabling  Member  States  to 
prioritise actions that respond to their more urgent needs related to the migration crisis at 
the time. In this light, all Member States’ national programmes allocated more resources 
under the objective on borders than visa.  

Regarding the type of activities funded under the national programmes’ objectives, these 
were also highlighted as relevant in addressing the specific needs identified in Member 
States’ national programmes, with activities deemed most relevant to national stakeholders 
receiving the most funding. As further detailed in the needs assessment annexed to this 
report, these  were activities related to  the development, upgrading,  implementation  and 
operationalisation of large-scale IT systems (and in particular, those required for border 
control and surveillance).  

The general relevance of the objectives of the national programmes was also confirmed in 
national-level  evaluation  reports.  Across  the  evaluations,  the  objectives  of  the  ISF-BV-
funded  interventions  were  largely  relevant  and  responsive  to  identified  needs.  Member 
States’ national programmes were based on a methodology that lacked sufficient foresight 
analysis to accurately plan for longer-term needs. In 2021, following the EBCG Regulation 
(EU)  2019/1896,  a  new  methodology  was  introduced  for  contingency  and  national 
capability plans based on a new planning framework that incorporated a needs assessment 

79 

 
 
based on scenarios derived from risk analysis through applying the Common Integrated 
Risk  Analysis  Model  (CIRAM).  These  scenarios  reflect  the  possible  evolution  of  the 
situation at the external borders regarding irregular migration, as well as the challenges 
identified in the multi-annual strategic policy cycle for EIBM. They consider both 1) short-
term needs in the case of operational and contingency planning and 2) mid- to long-term 
needs in the case of contingency and capability development planning (241). Under BMVI, 
Member States ensured that the needs identified in this exercise are reflected and addressed 
in  their  programmes.  In  contrast,  as  reported  by  interviewees,  under  ISF-BV,  needs 
assessments were not based on a forward-looking methodology but rather on past historical 
trends to plan for the coming years. As reported by stakeholders, this meant that Member 
States’  national  programmes  did  not  sufficiently  capture  and  plan  for  how  the  rapidly 
changing context of border management may evolve and impact their longer-term needs.  

However, despite the fact that ISF-BV programming was based on historical data, 
the flexibility of the national programmes ensured that their objectives and planned 
activities could be adapted to the evolving context of border management and thus 
better respond to evolving needs throughout the implementation of the  Instrument 
(2014-2020).  Most  implementing  national  authorities  consulted  through  the  survey 
considered the national programmes to be flexible to a “very large” (13%) or “large” (38%) 
extent (242). 

Figure 20 - ISF-BV flexibility to address changing needs 

Do you consider that the ISF BV was flexible
enough to address changing needs and emerging
challenges (e.g. COVID-19, the Russian war of
aggression in Ukraine, country-specific crisis,…

6%

25%

38%

19% 13%

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

To a very large extent

To a large extent

To some extent

To a limited extent

I don’t know / I prefer not to answer

The national-level evaluations noted that the ISF-BV demonstrated flexibility in adapting 
to changing circumstances and emerging needs. Some evaluations highlighted that during 
the  programming  period,  the  context  in  which  the  programme  operates  changed 
significantly, putting pressure on the flexibility of programme implementation. However, 
according to evaluations, the programme has been successfully amended during the period, 
in  some  cases  multiple  times  (e.g.,  in  Slovakia).  This  adaptability  contributed  to  the 
continued relevance of the objectives throughout the implementation period. Adaptability 
was also enhanced by reallocating funds to support critical projects, for instance in Cyprus. 
The programme also allowed for the extension of project duration in response to challenges 
to their timely implementation due to the COVID-19 pandemic. Similar findings from the 
case studies and interviews positively evidenced the flexibility of the design of the national 
programme with built-in mechanisms that ensure the national programmes can be adapted 
as  needed  in  order  to  better  respond  to  new  challenges,  needs  and  requirements  and 
maintain  their  relevance  over  time.  These  include:  Regular  consultation  with  national 
stakeholders  in  most  Member  States  in  order  to  assess  evolving  needs  and  adapt  the 

(241) Frontex, 2023, Contingency Planning. 
(242) 31% to “some extent”, 13% “don’t know/prefer not to say” and 6% to “a limited extent”. 

80 

 
 
 
national programmes accordingly (243)..The mid-term review mechanism also allowed for 
a  more  comprehensive  reassessment  of  needs  and  a  dialogue  with  the  Commission, 
including the possibility to amend the programme where necessary.  

Similar findings from the case studies and interviews positively evidenced the flexibility 
of  the  design  of  the  national  programme  with  built-in  mechanisms  that  ensure  that  the 
national  programmes  can  be  adapted  as  needed  in  order  to  better  respond  to  new 
challenges, needs and requirements and maintain their relevance over time. These include: 
Regular consultation with national stakeholders in most Member States in order to assess 
evolving needs and adapt the national programmes accordingly (244). The mid-term review 
mechanism also allowed for a more comprehensive reassessment of needs and a dialogue 
with the Commission, including the possibility to amend the programme where necessary. 
The mid-term review mechanism also allowed for a more comprehensive reassessment of 
needs  and  a  dialogue  with  the  Commission,  including  the  possibility  to  amend  the 
programme where necessary. Insights and recommendations from relevant actors such as 
the ISF Monitoring Committee or the Schengen Evaluation Committee (245). 

Changing  needs  based  on  these  mechanisms  were  addressed  through  minor  budgetary 
adjustments and transfers between the specific objectives of the national programme of up 
to 15 % of the basic allocation thanks to the flexibility clause in the legal base. This was 
considered by national authorities interviewed to be a useful tool that enabled adaptations 
to  the  changing  environment  and  fine-tuning  during  the  implementation  cycle.  While 
allowing flexibility to address needs at the national level, any significant changes that could 
impact  the  specific  objectives  or  introduce  new  national  objectives  were  subject  to  EU 
approval, ensuring that the national programme remained relevant to EU needs, priorities 
and objectives.  

The  objectives  of  the  Union  Actions  were  relevant  to  the  needs  of  the  EU  and  its 
Member States. As evidenced by the interim evaluation of ISF-BV and further confirmed 
by stakeholders consulted as part of this ex-post evaluation, Union Actions were relevant 
as a means to address transnational needs of particular interest to the Union as a whole 
(national-level evaluations did not provide specific assessment of the relevance of Union 
Actions). The table below demonstrates this relevance by cross-referencing the analysis of 
the Union Actions Annual Work Plan, which identified clusters of priorities and objectives 
pursued  by  Union  Actions  (first  column)  with  the  needs  assessment  (second  column), 
highlighting how each Union Action objectives respond to different needs.  

Table 7 -Assessment of the relevance of Union Actions objectives 

Objectives (clusters) 

Assessment of their relevance 

Border Control projects 
focusing on 
strengthening security 
measures at the external 
borders by integrating 

These projects target both physical and digital threats, enhancing the 
capabilities of border management systems through a combination of 
biometric  and  other  border  control  innovations.  They  aim  to  prevent 
unlawful  entries  while  maintaining  compliance  with  international 
obligations and enhancing surveillance capabilities. This is aligned with 

(243) Among the 13 countries represented in the survey, respondents for 8 out of these countries confirmed having 
conducted a needs assessment during the implementation of the national programme for ISF-BV. 
(244) Among the 13 countries represented in the survey, respondents for 8 out of these countries confirmed having 
conducted a needs assessment during the implementation of the national programme for ISF-BV. 
(245) Art. 12 of Regulation (EU) No. 515/2014 in accordance with Council Regulation (EU) No 1053/2013 of 7 
October 2013 establishing an evaluation and monitoring mechanism to verify the application of the Schengen 
acquis and repealing the Decision of the Executive Committee of 16 September 1998 setting up a Standing 
Committee on the evaluation and implementation of Schengen. 

81 

 
 
advanced technologies 
to detect and prevent 
unauthorised entries 

the needs and challenges identified as part of the needs assessment, 
which  evidenced  increased  security  threats,  including  terrorism  and 
hybrid  threats,  and  the  reported  need  by  stakeholders  consulted  for 
more  innovation  to  strengthen  border  management  IT  systems  and 
tools to better address these evolving threats. 

Document Security and 
Standardisation projects 
focus on enhancing the 
security and uniformity 
of essential travel and 
residency documents 
within the European 
Union. 

Migration Management, 
Cross-border 
Cooperation and 
Information Exchange 
projects aimed to foster 
collaboration among 
countries to improve 
border security and 
management. 

Training and Capacity 
Building projects aim to 
enhance the skills, 
knowledge, and 
operational capabilities 
of immigration and 
consular authorities by 
providing specialised 
training programmes 

These  initiatives  aim  to  improve  the  verification  processes  at  border 
controls, minimise the risk of fraud and counterfeiting, and streamline 
document recognition across Member States by introducing advanced 
technologies  and  standardised  formats.  As  above,  these  initiatives 
align  with  stakeholders’  needs  by  strengthening  the  uptake  of 
digitalisation (including systems, tools and databases) at the EU level, 
ensuring a more coherent and harmonised approach across the EU and 
the  areas  of  border 
enhancing  Member  States’  capacity 
management  and 
legitimate 
facilitating 
travel/migration and tackling irregular immigration. 

visa  policy, 

in 
thus 

These  projects  focus  on  integrating  surveillance  systems,  enhancing 
communication  channels,  and  building 
trust  among  border 
management  personnel.  As  evidenced  in  the  needs  assessment, 
improving  information  exchange  among  Member  States  and  with 
neighbouring countries was considered an  important  need as part of 
the four-tier EIBM model and in the area of visa policy. It improves real-
time data sharing, situational awareness, and coordination. This was 
tied to the above need for IT systems that address that gap and was also 
noted  as  a  need  and  “strategic  direction”  of  the  EU  in  the  2015 
European Agenda on Security (246). 

These initiatives focus on raising awareness, improving coordination, 
and  equipping  personnel  with  practical  tools  to  address  challenges 
related to migration, fraudulent visa submission and issuance, as well 
as  legal  migration  pathways.  Due  to  novelties  in  the  EU  acquis, 
technologies, and working methods, training was highlighted as a need 
in  several  Member  States'  national  programmes,  particularly  for 
consular  officials  and  visa  services  staff.  The  surveys’  results 
evidenced  similar  findings,  highlighting  training  as  a  relevant  action 
that  addressed  a  clear  need  within  Member  States  throughout  the 
implementation of the ISF-BV.  

Emergency Assistance addressed identified needs. 

EMAS provided funding in a flexible and tailored manner to respond to and mitigate 
the consequences of emergency situations with impact on EU external borders and its 
objectives addressed the EU and Member States’ needs for solidarity. The emergency 
situation  was  defined  as  “an  urgent  and  exceptional  pressure  where  a  large  or 
disproportionate number of third-country nationals are crossing or are expected to cross 
the  external  border  of  one  or  more  Member  States  or  any  other  duly  substantiated 
emergency requiring urgent action at the external borders” (247). That is, while migration 
(particularly  irregular)  can  result  from  long-term  megatrends  (demographic  change, 
climate change, etc.), it can also be driven by acute crises that are not predictable but need 
a swift, coordinated response, such as the 2015 migration crisis in Europe. The fast-moving 
and  unpredictable  nature  of  migration  means  that  Member  States  can  face  unforeseen 
events that risk overwhelming Member States’ capacities to manage their external borders 
or visa processes. Beyond surges in migration, constantly shifting migratory routes also 

(246) European Agenda on Security (2015) 
(247) Article 2(f) of the ISF-BV regulation. 

82 

 
 
 
make it difficult  to stem irregular migration to  the EU. It  requires flexibility to  support 
Member  States  and  SACs  in  response  to  shifting  needs/surges  in  migration  or  other 
emergency  situations  in  the  scope  of  the  Instrument.  As  evidenced  in  the  dedicated 
thematic case study on the topic, EMAS addresses this need by providing funding to assist 
Member States who most need it by reinforcing their capacity to cope with the evolving 
challenges in the management of their external borders. 

EMAS-funded actions remained relevant throughout the implementation of the ISF-
BV, providing EUR 471 million to 11 Member States, two international organisations, and 
one EU Agency across 79 actions to address emergencies related to the migration crisis 
and  its  impact  on  Member  States.  Most  actions  were  aimed  at  border  surveillance  and 
control,  migratory  pressure  management,  strengthening  first  reception  services, 
Operational  support,  Search  and  Rescue  Operations,  infrastructure  development  and 
provision for legal information/interpretation for the effective management of immigration 
flows.  Interviews  with  national  authorities  and  stakeholders  within  the  Commission 
confirmed the relevance of these priorities. They noted that EMAS actions helped bridge 
the gap and address Member States’ immediate needs, which could not be met through the 
actions under their national  programmes alone.  However, some stakeholders within the 
Commission  noted  that  some  Member  States  had  to  use  EMAS  to  address  longer-term 
structural needs as opposed to its intended purpose (i.e. to support MS during emergency 
situations  with  short-term  needs  and  provide  immediate  relief.).  For  this  purpose, 
additional funding to ISF BV programmes was provided following the specific action for 
support to border control activities, particularly in those Member States confronted with 
high migratory pressure at the external borders launched in 2019. 

5  CONCLUSIONS AND LESSONS LEARNED 

5.1  Conclusions 

5.1.1  Effectiveness 

The ISF-BV proved effective in supporting Member States in progressing towards 
their objectives in the areas of visa policy and external border management. National 
programmes  were  largely  completed,  with  high  absorption  rates  and  delivery  against 
targets. Despite major challenges - including the COVID-19 pandemic, Russia’s war of 
aggression against Ukraine, and shifting national priorities in migration and border policy 
-  ISF-BV  activities  remained  on  track.  The  one-year  extension  introduced  by  the 
Commission  was  acknowledged  as  instrumental  in  ensuring  the  continuation  and 
finalisation of key actions. 

The Instrument appears to have contributed effectively to the harmonisation of the 
EU visa policy. It supported the development of consular infrastructure, the deployment 
of IT systems, such as the Visa Information System (VIS), and to the training of consular 
staff.  These  efforts  facilitated  standardised  visa  processing  across  Member  States  and 
Schengen Associated Countries.  

ISF-BV contributed to the more effective and uniform application of the Union acquis 
on  visas,  primarily  through  investments  in  infrastructure  and  training  activities.  These 
interventions improved technical readiness, interoperability, service quality and procedural 
coherence in visa processing. However, the depth of implementation varied across Member 
States. Survey results support a generally positive perception of ISF-BV’s contribution, 
particularly among institutional stakeholders. 

83 

 
However,  the  Fund’s  role  in  expanding  the  geographical  coverage  of  consular  services 
remained limited. Most actions focused on improving existing offices rather than opening 
new representations, and the regression analysis suggests that consular expansion occurred 
largely independently of ISF-BV support. Progress in promoting consular cooperation in 
third  countries  was  uneven.  Only  a  subset  of  countries  reported  such  activities,  and 
examples of structured cooperation remained limited. 

The  ISF-BV  played  an  important  role  in  strengthening  the  monitoring  of  borders 
across Member States by supporting investments in infrastructure, biometric verification 
tools, and border guard training. These efforts resulted in tangible improvements to the 
effectiveness of border controls. One of the areas of progress was the preparatory work for 
large-scale Union-wide IT systems such as EES and ETIAS. While these systems were not 
yet operational by the end of the programming period, the delays observed were structural 
and Union-wide in  nature. Countries were not  expected to  operationalise  these systems 
during the 2014–2020 period but to reach a high level of technical readiness. Therefore, 
these  delays  should  not  be  interpreted  as  a  shortcoming  in  national  implementation. 
Instead, ISF-BV funding enabled countries to lay the groundwork for future integration, 
aligning their national systems with Union-wide requirements and ensuring preparedness 
for upcoming obligations. 

Documentary review, consultations and case studies confirm widespread improvements in 
border  control  effectiveness,  infrastructure  upgrades,  and  the  application  of  Union 
standards.  However,  some  Member  States  faced  delays  in  project  implementation  or 
difficulties in assessing effectiveness, particularly in IT-related actions.  

Emergency  Assistance  under  the  ISF-BV  played  a  targeted  and  timely  role  in 
addressing acute migration and border management crises between 2014 and 2020. 
EMAS was most intensively used during the peak of irregular migration flows in 2015–
2017, with  80 projects  implemented across 11  Member States  and several  international 
actors.  Although  national  ex-post  evaluations  provided  limited  systematic  feedback  on 
EMAS, available evidence from countries such as Greece, Spain, and Lithuania confirms 
that  the  Instrument  enabled  rapid  deployment  of  resources,  supported  operational 
continuity, and addressed urgent infrastructure and coordination needs.  

Operating support under Article 10 of the ISF-BV regulation played a key role in a limited 
number  of  Member  States,  where  it  was  used  to  sustain  essential  visa  and  border 
management  functions.  In  countries  such  as  Austria,  Cyprus,  Finland,  and  Germany,  it 
enabled  the  maintenance  of  IT  systems,  consular  operations,  and  border  infrastructure, 
particularly during periods of fluctuating demand, such as the COVID-19 pandemic. 

The  regression  analysis  indicates  that  ISF-BV  funding  may  have  had  a  positive 
impact  on  the  effectiveness  of  integrated  border  management.  Specifically,  a 
statistically significant correlation was observed between expenditure under SO2 and an 
increase  in  the  number  of  detections  of  fraudulent  travel  at  border  crossing  points. 
However, the analysis faced important limitations, particularly due to issues related to data 
quality and availability, which constrain the strength of the conclusions. As for SO1, the 
descriptive  statistical  analysis  revealed  only  a  weak  correlation  between  ISF-BV 
operations and the establishment of new consular representations. This suggests that while 
some Member States used ISF-BV to support such developments, others pursued similar 
actions independently of the Fund. 

84 

 
5.1.2  Efficiency 

The  evaluation  criterion  focused  on  assessing  the  efficiency  of  resource  utilisation  in 
achieving its objectives. Despite data limitations (248), findings indicate varying degrees 
of  efficiency  among  Member  States,  with  top-performing  countries  achieving 
substantial  outcomes  at  lower  costs,  while  mid-tier  and  low  performers  varied  in 
efficiency.  The  analysis,  conducted  for  Specific  Objectives  1  and  2,  revealed  that 
efficiency  is  influenced  not  only  by  the  type  of  intervention  but  also  by  the  specific 
contexts and needs of each Member State. 

Under SO1, projects supporting the visa application process, equipment and software for 
information extraction, and consular cooperation demonstrated higher efficiency compared 
to  other  interventions.  The  SO2,  top  performers  focused  rather  on  maritime  border 
surveillance  and  activities  associated  with  EES,  complemented  by  the  development  of 
Integrated  Border  Management,  activities  associated  with  the  ETIAS  Regulation,  and 
initiatives aimed at enhancing the capabilities of immigration liaison officers 

While acknowledging the limitations of this analysis, it is important to note that the results 
should not be interpreted as definitive indicators of which types of projects are more cost-
effective. Instead, they underline the areas of intervention in which Member States have 
more difficulties in implementing cost-effective projects.  

The  regression  analysis  complemented  the  conclusion  by  confirming  a  positive, 
statistically significant relationship between ISF-BV financial expenditure in SO2 and the 
benefits achieved, particularly in increasing the detection of fraudulent documents at the 
border. Nevertheless, as MS targeted various types of interventions, the effectiveness of 
the interventions was not solely attributable to one specific type of intervention but rather 
to a mix of interventions targeted and implemented at the Member State level. 

Mechanisms  such  as  rigorous  cost  control,  lean  project  management,  and 
comprehensive risk assessments were implemented at the MS level to enhance cost-
effectiveness.  However,  the  lack  of  comprehensive  data  limits  the  ability  to  determine 
whether these practices are consistently applied across all Member States. 

Nevertheless, the evaluation of the ISF-BV reveals a generally positive perception of 
its  cost-effectiveness  among  consulted  stakeholders,  with  over  70%  of  national 
authorities affirming that operations, particularly those within National Programmes, were 
achieved at reasonable costs. 

The efficiency of the interventions was influenced by a series of factors. The COVID-
19  pandemic  significantly  impacted  project  timelines  and  indicator  achievements, 
prompting  adjustments  in  project  management  and  monitoring  practices.  Moreover, 
limited staff supply often caused project delays and increased the burden on existing staff. 
Price  surges  due  to  inflation  also  affected  cost-effectiveness.  Public  procurement 
emerged as a significant factor influencing the implementation of the ISF-BV Instrument. 
While  public  procurement  generally  promoted  cost-effectiveness,  compliance  with 
tendering procedures posed challenges in some Member States, leading to project delays, 

(248) The analysis faced limitations due to insufficient data on the costs associated with the number of Full-
Time  Equivalents  (FTEs)  deployed  by  various  stakeholders.  Additionally,  quantifying  the  perceived 
administrative  burden  proved  challenging  due  to  a  lack  of  information  and  significant  variations. 
Inconsistencies in how Member States establish their indicator targets were also noted. 

85 

 
 
as explained in the next section. 

5.1.3  Simplification and reduction of administrative burden 

The  Instrument  introduced  a  set  of  significant  provisions  with  a  view  to  simplifying 
funding  procedures  and  reducing  administrative  burden.  Through  their  adoption, 
National  Authorities  and  Beneficiaries  experimented  an  effective  simplification  in  fund 
management. However, their implementation and impact were uneven.  

The introduction of the Multi-Annual Programming is widely considered the most 
successful simplification measure, despite the initial challenges posed by the transition 
from annual programming. It has indeed significantly reduced administrative burden by 
allowing long-term planning and resource allocation, thus ensuring a stable and predictable 
funding framework. Beneficiaries recognised that the possibility of designing multi-year 
projects  significantly  eased  administrative  burden,  eliminating  the  need  for  annual 
reprogramming or reapplication processes. Although Multi-Annual Programming provides 
flexibility and reduces the administrative burden, it also requires careful planning.  

National  eligibility  rules  have  been  essential  to  enhancing  the  flexibility  and 
adaptability of fund management, particularly in financial management, staff costs, and 
project modifications. Responsive and adaptive national eligibility rules ensured that funds 
remained  flexible  and  aligned  with  national  needs,  fostering  greater  agility  in  project 
implementation.  Despite  these  benefits,  challenges  remain,  such  as  the  need  to  balance 
flexibility with EU compliance, as well as misalignments between national and EU rules 
that still contribute to bureaucratic complexity.  

Several  Member  States  successfully  applied  SCOs  during 
the  2014-2020 
programming period. Their use has indeed proven to be an effective tool in reducing 
administrative  burden  for  both  Member  States  and  beneficiaries.  By  allowing  the 
reporting  of  standard  unit  costs,  such  as  fixed  rates  for  personnel  expenses,  SCOs 
streamline financial reporting, making fund management processes more efficient and less 
complex.  

Despite their widely recognised benefits, SCOs were not universally adopted. This was 
due to challenges such as the relatively small size of allocations in certain countries, where 
their benefits would have been outweighed by the costs and administrative burden of data 
collection  and  analysis.  In  this  regard,  the  absence  of  SCOs  in  some  countries  was 
recognised as a “missed opportunity” to reduce the complexity of fund management and 
there is room for encouraging their use. 

Both  national  authorities  and  beneficiaries  have  benefited  from  the  adoption  of  more 
flexible  procurement  approaches,  such  as  centralised  methodologies  and  dedicated 
procurement units, as well as from the introduction of digital procurement management 
systems. Despite these improvements, procurement often remains a significant challenge 
due  to  lengthy  procedures,  substantial  documentation  requirements,  and  rigid  rules 
(particularly in areas such as security and emergency response), which continue to slow 
project implementation in some Member States. In addition, public procurement rules are 
supplemented by national regulations tailored to the specific context of each MS, which in 
some cases increased the administrative efforts at the level of the national programmes. 

Operating  Support  has  proven  effective  in  streamlining  fund  management  by 
allowing  authorities  to  focus  on  essential  tasks,  such  as  maintaining  systems  and 
ensuring operational stability without the complexity of project-based funding procedures. 

86 

 
This support has reduced the administrative burden and simplified processes by funding 
ongoing operational activities, such as equipment maintenance, infrastructure upkeep, and 
technical updates, without the need for repetitive grant applications. The use of Operating 
Support has often resulted in a better streamlined fund management and might be better 
used to avoid bottlenecks in programme administration. 

5.1.4  Coherence and complementarity 

The  ISF-BV  is  considered  internally  coherent.  Different  components  serve  to  meet 
specific, differentiated needs. For example, the long-term structural needs at the national 
level are supported by nationally defined programmes for the entire funding period. While 
Specific Actions, Emergency Assistance and Union Actions allow for support to address 
emerging (and – in case of EMAS in particular - urgent) needs identified on an on-going 
basis  through  Annual  Work  Programmes  which  are  identified  at  either  (or  both)  the 
national and transnational level.  

There are formal and informal mechanisms in place at the EU and national levels to 
ensure  complementarities  and,  where  relevant,  synergies  across  the  different 
components of the ISF-BV. These mechanisms include formal consultation of the multi-
Annual  Work  Programmes  at  Union  level.  Meanwhile,  it  is  a  specific  function  of  the 
Monitoring Committee and Responsible Authority at the national level to ensure a lack of 
overlap or duplication.  

However, Union Actions appear to be a weaker link in this respect. At the same time, 
Union Actions serve a niche function and are managed either directly or indirectly by the 
Commission,  meaning  that  without  proactive  efforts  to  disseminate  and  ensure  the 
accessibility / transparency of what is supported, it is naturally harder to ensure synergies 
with national level funding during the implementation stage. 

In  terms  of  external  coherence,  coordination  mechanisms  to  ensure  the  coherence 
between the ISF-BV and other Union funds exist at the programming stage, inside 
the  Commission  and  through  the  HOME  Affairs  Committee.  However,  this  is  less 
clear at the implementation stage. The avoidance of overlaps is firstly ensured through 
coordination  at  the  national  level,  although  this  is  implemented  differently  across  the 
participating  countries  (e.g.  Monitoring  Committees,  shared  Managing  Authorities, 
additional reviews and assessment at programming stage). At the EU level, a robust inter-
service consultation ensures that overlaps are avoided, together with additional tools, such 
as the participation of DG HOME in Monitoring Committee meetings, dialogue between 
DG HOME and Responsible Authorities, conducting on site visits, as well as the audits 
carried out at Union level. Although the interim evaluation noted that “mechanisms have 
been put in place to ensure continued coherence at the implementation stage”, interviewees 
did not recall any specific formal coordination mechanism to ensure synergies and avoid 
duplication during the implementation of funded actions. 

While  different  examples  of  mechanisms  in  place  to  ensure  complementarity  with 
national initiatives were identified in the study, the study could not confirm formal 
mechanisms are in place across all Member States. Survey results only confirmed this 
for  just  over  a  third  of  Member  States,  and  the  national  reports  did  not  systematically 
mention formal mechanisms to support complementarity. Nonetheless the case studies did 
show  that  different  relevant  mechanisms  exist  in  the  Member  States  to  ensure 
complementarity at the programming stage. 

87 

 
The stakeholders consulted considered that the ISF-BV is complementary to national-level 
policies and funding instruments. The ISF-BV was viewed as contributing to high-level 
policy priorities, such as accession to and membership in the Schengen Area. 

The stakeholder consultations did not identify cases of duplication or overlap between 
the Instrument and national funding instruments.  

The ISF-BV is coherent with the objectives and activities of the other Home Affairs 
Funds (AMIF and ISF-Police), as well as other EU funds. An area seen to be important 
was  the  coherence  between  ISF-BV  and  the  Horizon  2020  programme.  They  study 
highlighted that beyond the ISF-BV, no other funding mechanism existed to further build 
on the pipeline of border management related innovation  that was developed under the 
Horizon 2020 programme.  

In  this  context,  the  ISF-BV  funding  was  seen  as  a  crucial  tool  to  ensure  the  concepts 
developed under Horizon would lead to longer term testing and validation and eventually 
ensure these capabilities were available to procure on the EU market. However, interviews 
confirmed that Responsible Authorities are often unaware of the relevant R&D projects 
funded in their country, as well as the relevant stakeholders involved, and that generally 
follow up to Horizon 2020 was not prioritised by Member States under the ISF-BV as they 
tended to focus on using funding to address more immediate needs.  

With regard to the ISF-BV funding in relation to third countries, no overlaps were 
identified  with  other  forms  of  EU  financial  support.  However,  a  few  EU  level 
stakeholders noted that the broad nature of the  National  Programmes  (lack of detail  on 
planned  activities  and  in  relation  to  which  third  countries  at  planning  stage)  made  it 
difficult  to  determine  whether  and  what  exactly  was  being  funded  in  relation  to  third 
countries under the  ISF-BV. At  the same time, it  was noted that coordination with  DG 
HOME had become much closer and more institutionalised since the migration crisis of 
2015  which  made  the  topic  a  political  priority.  Since  then,  both  sides  had  been  more 
involved  in  each  other’s  planning,  with  more  formalised  and  more  institutionalised 
preparatory meetings and information-sharing meetings between DG NEAR, DG INTPA, 
EEAS and DG HOME. However, issues remain regarding: the alignment of the Union’s 
external  migration  and  security  funding  with  the  Union  policies  in  these  areas;  the 
persistent challenge to use all existing (policy, funding, investment and other) tools, both 
at the disposal of the EU and its Member States, in a Team Europe spirit, to use strategically 
and  timely  leverage  in  relation  to  partner  countries  in  order  to  improve  cooperation  on 
migration and security; the limitations for funding migration- and security-related actions 
in third countries 

The  ISF-BV  is  finally  coherent  with  Frontex  activities  due  to  the  involvement  of 
Frontex at planning stage. The implementation of national capability planning is expected 
to further increase the alignment of DG Home funding and Frontex activities. 

5.1.5  EU added-value 

The implementation of the ISF-BV brought about significant added value and enhanced 
the  capabilities  of  Member  States  in  managing  external  borders  and  implementing  the 
common visa policy. 

The ISF-BV’s support increased the overall resources available for border control 
and migration management. For instance, Cyprus enhanced its surveillance capabilities, 
Malta deployed Automated Border Control gates, and Slovakia acquired advanced border 

88 

 
surveillance equipment. Additionally, the financial assistance provided by the Instrument 
enabled strategic projects focused on modernising and improving IT systems which may 
have not been developed, or fully developed, otherwise. 

Without  the  support  of  the  Instrument,  several  Member  States  reported  that  they 
would  have  struggled  to  implement  essential  Union  policies  effectively.  In  other 
Member  States,  essential  actions  to  comply  with  Union  policies  would  have  still  been 
carried out, but their overall reach, quality, and timeliness would have been reduced. Only 
Lichtenstein  and  Switzerland  reported  that  they  would  have  been  able  to  carry  out  all 
necessary activities to comply with Schengen requirements without the support of the ISF-
BV. 

An interruption of the Instrument would pose challenges for 18 Member States plus 
Iceland and Norway, risking setbacks in critical operations.  

Nonetheless, the survey results show that there is a limited perception of the direct benefit 
of  funded  actions  at  the  Union  level,  primarily  due  to  a  lack  of  awareness  among 
stakeholders.  

5.1.6  Sustainability 

Member States adopted a variety of mechanisms to promote the sustainability of ISF-BV 
project  results  at  both  the  programming  and  implementation  stages.  These  included 
requiring  sustainability  plans  in  funding  applications,  aligning  projects  with  national 
priorities,  and  setting  minimum  operational  periods  for  IT  systems  and  infrastructure. 
While the level of uptake varied, several countries embedded sustainability into national 
strategies from the outset, helping ensure continued relevance and use of project outputs.  

Structured monitoring and verification mechanisms were implemented by several Member 
States  to  track  sustainability  during  and  after  implementation.  These  included  post-
completion  evaluations,  periodic  inspections,  reporting  obligations,  and  maintenance 
requirements based on project type. However, these practices were not uniformly adopted 
across all Member States, and sustainability monitoring frameworks varied in depth and 
frequency.  

Training  and  capacity-building  activities  were  widely  implemented  and  viewed  by 
beneficiaries as key enablers of sustainability. In several cases, trained staff were able to 
independently  manage  infrastructure  and  IT  systems.  However,  long-term  impact  was 
difficult to assess due to limited follow-up mechanisms, and practices for institutionalising 
knowledge transfer varied considerably across Member States.  

Many ISF-BV-supported infrastructure and IT investments are expected to remain 
in use well beyond the funding period, particularly where national budgets or strategic 
frameworks  ensured  their  integration  into  core  operations.  However,  reliance  on  EU 
funding remains a concern for high-maintenance assets, particularly in Member States 
with budgetary constraints.  

5.1.7  Relevance 

The evaluation confirmed that the objectives and actions funded under ISF-BV were 
highly  relevant  to  the  identified  needs  of  Member  States.  The  design  of  national 
programmes was informed by an assessment of national strategic documents defining long-
term  goals  and  by  stakeholder  consultations,  ensuring  that  priorities  reflect  their  needs. 

89 

 
Policy dialogue between the Commission and the Member States allowed for addressing 
challenges encountered during the previous funding period. 

ISF-BV  demonstrated  significant  flexibility,  allowing  Member  States  to  adapt  their 
national programmes in response to evolving needs and emerging challenges in border 
management. This adaptability was crucial to maintaining the relevance of the programme 
throughout  its  implementation  period  (2014-2020),  particularly  in  light  of  unforeseen 
events such as the COVID-19 pandemic and shifting migratory patterns. 

Union Actions under ISF-BV were found to be relevant in addressing transnational 
needs  that  are  of  particular  interest  to  the  EU  as  a  whole  and  funding  through  EMAS 
effectively addressed urgent needs arising from crises at the external borders, providing 
timely and tailored support to Member States facing disproportionate migratory pressures. 

5.2  Lessons learned 

In view of the unequal implementation of both objectives, and the finding that a substantial 
part of activities related to SO1 may have happened without the intervention of the fund, 
future  instruments  may  need  to  consider  possible  incentives  and  clear  guidance  for 
activities in visa policy and, most particularly, the development of joint consular activities. 
In addition,  encouraging more strategic alignment  between national  consular expansion 
efforts  and  EU  funding  priorities  could  improve  the  overall  coherence  and  visibility  of 
Union-level support. 

In the case of the harmonisation and implementation of the acquis in the field of visa policy, 
awareness amongst stakeholders remained limited. More consistent integration of acquis-
related  objectives  into  training  design  and  evaluation  could  increase  its  impact.  Future 
efforts  would  benefit  from  encouraging  Member  States  to  link  training  more  clearly  to 
acquis implementation. 

The  evaluation  of  ISF-BV  highlights  the  importance  of  flexibility  and  adaptability  in 
funding border and visa management. The Instrument’s ability to remain effective despite 
unprecedented  challenges  illustrates  the  value  of  responsive  design.  Moreover,  the 
experience  of  the  ISF-BV  underscores  the  importance  of  sustained  investments  in  IT 
infrastructure and staff training as  foundational  elements  of a harmonised and effective 
visa and border management system. Moreover, the assessment of the ISF-BV's relevance 
is  positive,  indicating  that  major  changes  to  the  Instrument’s  design  are  not  necessary. 
However,  since  stakeholders  particularly  value  the  programme's  flexibility,  particular 
attention  should  be  paid  to  the  continuation  of  this  flexibility  margin  in  terms  of 
programming and funding, enabling a quick response to evolving needs and situations.  

In general, in order to improve the monitoring of actions and the steering towards enhanced 
improved  monitoring  and 
effectiveness,  future 
performance assessment mechanisms. This would allow to better capture and monitor the 
progress towards the achievement of the established objectives. 

instruments  might  benefit  from 

In terms of efficiency, there is room for streamlining administrative processes for reducing 
the burden on national authorities and beneficiaries. Simplifying reporting requirements 
and  administrative  procedures,  without  diminishing  the  quality  and  the  necessary 
quantitative  information  for  the  monitoring  of  the  implementation,  can  significantly 
enhance efficiency. By reducing  the administrative burden, Member States can allocate 
more time and resources to  implementing effective interventions,  achieve their planned 
outcomes and delivering results rather than navigating bureaucratic processes. 

90 

 
Also, in terms of efficiency, while the ISF-BV Instrument has demonstrated varying degree 
of cost-effectiveness and efficiency, ongoing challenges necessitate continued support for 
lower-performing  Member  States  to  enhance  project  management  practices  and  ensure 
optimal implementation of Union-funded investments. The findings underscore the need 
for a nuanced understanding of how various factors can influence operational efficiency 
and the importance of adapting interventions to the specific contexts of each Member State.  

In  this  regard,  establishing  a  systematic  data  collection  framework  could  reinforce 
efficiency  assessment  in  the  future.  A  robust  data  collection  framework  would  also 
facilitate transparency and accountability, ensuring that resources are utilised effectively 
to meet the diverse needs of Member States. 

There might be an added value as well in encouraging the exchange of good practice in 
terms of efficiency-oriented measures and public procurement. 

In terms of internal coherence, ways of strengthening coordination and synergies between 
Union Actions and national programmes could be explored, in order to ensure the access 
to the results of the actions and synergies with national level funding at implementation 
stage. 

There  is  also  room  to  encourage  the  development  of  structured  tools  for  assessing  the 
complementarity  between  EU-funded  interventions  and  national  policies  and  priorities, 
notably beyond the programming stage. This complementarity should go beyond avoiding 
overlaps and should aim at reinforced joint action in the achievement of objectives. 

As  far  as  coherence  with  external  spending  programmes  is  concerned,  and  notably  the 
NDICI,  enhanced  cooperation  and  coordination  on  programming  both  between  the 
Commission services and with EU Member States are needed.  

Also for the future, strenghtening the coherence between the ISF-BV and Horizon 2020 
should be considered, to ensure that the concepts developed under Horizon 2020 lead to 
long  term  testing  and  validation  and  ensure  capabilities  are  available  to  procure  on  the 
Union market. 

Finally regarding the added value of the funding, given its lack of visibility for stakeholders 
and citizens, it is worth considering increased action in terms of communication. 

91 

 
 
 
 
 
 
 
 
 
ANNEX I: PROCEDURAL INFORMATION 

This evaluation has been carried out by DG HOME, as responsible for the implementation 
of ISF-BV in the Commission. The evaluation was launched in May 2023. 

The evaluation has been carried out in accordance with the rules of Better Regulation, by 
applying the methods and requirements established in the Toolbox. The evaluation was 
also  based  on  the  requirements  set  in  the  monitoring  and  evaluation  framework  for  the 
2014-2020  Home  Affair  Funds,  as  defined  in  the  Commission  Delegated  Regulation 
2017/207. In this regard, the five standard criteria for evaluation defined Better Regulation 
(Effectiveness,  Efficiency,  Relevance,  Coherence  and  EU  Added  Value)  were 
complemented by two additional ones: Sustainability and simplification and reduction of 
administrative burden 

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

The first meeting of the Interservice Group was held on 30 June 2023. During the meeting 
were  discussed  the  Specifications  for  the  preparatory  study  to  be  carried  out  with  the 
assistance of external consultants. Additional meetings of the Interservice group took place 
to discuss the deliverables of the preparatory study on 11 March 2024, 13 May 2024, 23 
July 2024, 25 October 2024… and 15 July 2025.  

The preparatory study was confided to a consortium made up of EY France, Fondazione 
Brodolini and Tetra Tech, following an open call for tender launched on 3 October 2023. 
The contract was signed on 27 February 2024. The final report of the preparatory study 
was submitted to the Commission on 25 June 2025. 

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

92 

 
 
 
ANNEX II: METHODOLOGY AND ANALYTICAL MODELS USED 

This chapter presents the methodology employed for the mid term evaluation of the ISF-
BV 2014-2020 and the limitations encountered.  

Methodology 

The  evaluation  was  supported  by  an  external  study  that  was  divided  into  four  phases: 
inception,  interim,  data  collection  and  finalisation.  The  study  applied  a  mixed-method 
evaluation approach, incorporating both quantitative and qualitative research techniques 

The inception phase was used for preparing work to be done. This included preliminary 
desk research, scoping interviews, developing an intervention logic, and the refinement of 
the  methodological  approach  to  be  used.  The  inception  phase  concluded  with  the 
production of an inception report which was discussed during a meeting of the Steering 
Group, revised by the contractors to incorporate the Commission’s feedback, and later the 
final inception report was approved. 

The interim phase focused on gathering data by completing the desk research, providing 
an  in-depth  analysis  of  the  evaluation  questions  through  case  studies,  synthesising  and 
analysing  the  annual  performance  reports  submitted  in  2023  and  2024,  a  review  of  the 
Member State mid term evaluations, reviewing a sample of target setting methodologies, 
mapping  the  allocations  by  type  of  intervention  and  target  group,  and  an  open  public 
consultation. This phase concluded with an interim report which was discussed with the 
Steering Group, revised and then accepted.  

During the data collection phase, the focus was on collecting the remaining data necessary 
for  the  study.  This  included  obtaining  quantitative  and  qualitative  data  from  SFC2021, 
reviewing  EU  and  national  documents,  interviews  with  stakeholders,  and  conducting  a 
targeted survey.  

In the final phase, the ex post evaluations received from the Member States, as well as the 
Final Implementation Reports were factored in the analysis. The findings were synthesised 
and triangulated, to formulate replies to the evaluation questions and draw conclusions. 
Furthermore, the second EU level focus group was held to validate the evaluation findings 
and  develop  lessons  learned.  The  contractors  delivered  a  draft  final  report  which  was 
discussed in a meeting with the Steering Group.  

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

Regarding  the  data  collection  methods,  the  desk  research  included  the  review  of  EU 
legislation,  ISF-BV  planning  documents,  funding  documents,  documents  related  to  the 
implementation of the Instrument at national level, programming data, previous EU studies 
and evaluation reports, EU policy documents and other relevant documents.  

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

93 

 
 
 
Regarding  the  consultation  activities,  EU  level  interviews  were  conducted  with  the 
officials from DG HOME, DG NEAR, DG ENPL, Frontex, DG JUST, DG TAXUD, DG 
INTPA,  the  EEAS,  IOM,  UNHCR  and  ICMPD.  The  interviews  included  scoping 
interviews  and  semi-structured  interviews  to  gather  data  for  the  analysis,  including  the 
country case studies and thematic case studies. Further interviews were conducted for the 
case studies including with national authorities and beneficiaries.  

Two EU level focus groups were held during the study. The first EU level focus group 
was  held  in  person  on  the  25  June  2024.    The  focus  group  consisted  of  Managing 
Authorities  and  project  beneficiaries.  The  focus  group  consisted  of  presenting  the 
intervention logic, mapping needs, and understanding the extent to which needs were met 
by the Instrument. 

The  second  focus  group  was  held  on  15  October  2024  and  consisted  of  Commission 
officials, Managing Authorities, Frontex, ICMPD, and an NGO. The objective of the focus 
group was to validate the evaluation findings and further develop the lessons learned.  

The third focus group was held on 28 March 2025. It consisted of Commission Officials, 
Managing  Authorities,  Frontex, and  ICMPD. The objective was  to discuss  and validate 
the findings of the evaluation. 

In addition to the focus groups, three targeted surveys were launched to target various 
stakeholders (national authorities, beneficiaries and other stakeholders). The analysis of 
the survey results fed into the main analysis.  

The study included eight country case studies (HR, CZ, EL, IT, NO, PL, RO and ES) to 
dive  deeper  into  the  implementation  of  the  ISF-BV  to  identify  challenges  encountered, 
specific processes, and best practices. The study also included five thematic case studies 
on Union Actions, EMAS, the impact of the Russian war of aggression towards Ukraine, 
Specific Actions, and the contribution to horizontal priorities. The thematic case studies 
allowed  for  deep  dives  into  certain  aspects  of  the  Instrument  and  specific  topics  by 
reviewing specific projects.  

Based on the work described above, the final report for the ex-post evaluation was drafted 
and approved. 

Limitations and mitigation measures 

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

The first limitation was the inconsistent availability, quality and levels of granularity of 
data across the Member States. This made it difficult to conduct trend analysis and make 
comparisons across Member States.  The study team mitigated this challenge by seeking 
further information when needed and employing protocols to ensure data reliability.  

Secondly,  some  stakeholders  had  difficulty  distinguishing  between  the  2014-2020  and 
2021-2027 programming periods. The study made efforts to attribute the findings to the 
correct programming period.  

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

94 

 
Finally,  the  output  and  result  indicators  data  transmitted  by  the  Member  States  via 
SFC2021 included a number of omissions, clerical errors, and revealed differences in how 
Member States interpret, measure and report data. The data was reviewed for consistency 
and  plausibility,  and  corrected  where  possible.  Furthermore,  not  all  Member  States  set 
milestones and targets. Of those that did, there were varying levels of ability to set realistic 
milestones and targets.  

95 

 
 
 
 
ISF-BV Intervention Logic 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111 
Office: LX46 05/162 – Tel. direct line +32 229-62081 

Enrique.Garcia@ec.europa.eu 

Operational objectivesOutputsTo contribute to ensuring a high level of security in the Union while facilitating legitimate travel, through a uniform and high level of control of the external borders and the effective processing of Schengen visas, in compliance with the Union’s commitment to fundamental freedoms and human rightsEnsuring that Member States most in need, which are providing a public service for the EU as a whole, receivethe appropriate level of resources is paramount. This entails allocating sufficient financial support and assistance to enable these countries to effectively fulfilltheir responsibilities and obligations within the European Union framework.Contribution to strong + effective internal security within the Union, + free movement of persons within it(general objective) through achieving the specific objectives.NeedsEU’s New Pact on Migration +Asylum, the European Integrated Border Management (EIBM) strategic policyHome Affairs Funds (AMIF, ISF-police)CCEI, Customs policy + programme (DG TAXUD), JUST programme (DG JUST), Horizon 2020 +Horizon Europe(DG RTD), DG INTPA manages  NDICI-Global Europe Instrument+/or EEAS funded activitiesExternal factorsOther EU policies / interventionsGeneral objectiveSpecific objectives•Economic context (budgetary pressures on MS)•Geopolitical context + events / regional instability (e.g. migration crisisof 2015, terroristattacks,Covid-19,ongoing Russian war of aggression in Ukraine)•Megatrends (demographic change, climate change) •Technological change•Specific events (Brexit, EP elections)InputsSharedManagement –d Member State programmes (all EU MS except Ireland and UK + Iceland, Liechtenstein, Norway, +Switzerland) EUR 2.420 billionRelevance Effectiveness EfficiencyEU added value+Sustainability + SimplificationInternal coherenceExternal coherenceResultsImpactsActions implementedthroughdirectmanagementEUR 0.58 billionActions implementedthroughindirectmanagementEUR 4.624 millionCommon Provisions Regulation BMVI Regulation Financial, human and institutional resourcesSupport integrated border management, harmonising related measures and improving information sharing managementDeveloping common policy on visas, consular cooperation and harmonisation of practicesSupport a common visa policy to facilitate legitimate travel, provide a high quality of service to visa applicants Setting up and running IT systems, communication infrastructure and equipmentEnsuring uniform application of the EU acquis on borders and visasEnhancing cooperation between MS and/or third countriesReinforcing situational awareness at external borders and MS reaction capabilitiesEnsuring absence of internal borders controls; checks and monitoring at external bordersEstablishing an integrated system for management at the external border•Schengen acquis is implemented.•Member States have the required infrastructure, systems, and equipment to implement a common visa policy.•Migration management and internal security are further harmonized among Member States.•Third countries are provided with the means to facilitate and cooperate in the context of EIBM.•Information sharing on border and visa issues is facilitated through new, improved, and interoperable IT systems.•Through cooperation and burden-sharing, Member States have comparable capabilities to implement EIBM and a common visa policy.•The situational awareness of staff working with border and visa management is enhanced through training.•(Increase in) the number of IT functionalities and large-scale IT systems developed/ maintained/upgraded•Upgrade infrastructures, buildings, and systems at border crossing points and for better surveillance between crossing points.•Upgrade the secondment of immigration liaison officers in third countries and exchange and secondment of border guards.•Upgrade studies, training, pilot projects establishing external borders integrated management systems, operational cooperation, interoperability, and harmonization of systems.•(Increase in) the number of staff trained and the number of training courses in aspects related to border management with the help of the Instrument.•(Increase in) the number of border control (checks and surveillance) infrastructure and means developed or upgraded with the help of the Instrument.•(Increase in) the number of border crossings of the external borders through ABC gates supported by the Instrument out of the total number of border crossings.•(Increase in) the number of national border surveillance infrastructure established/further developed in the framework of Eurosur.•(Increase in) the number of incidents reported by Member States to the European Situational Picture.•(Increase in) the number of consular cooperation activities developed with the help of the Instrument.•(Increase in) the number of staff trained and the number of training courses in aspects related to the common visa policy with the help of the Instrument.•(Increase in) the number of specialized posts in third countries supported by the Instrument.•Upgrade the percentage and number of consulates developed or upgraded with the help of the Instrument out of the total number of consulates.IT and communication systems for management of migration flows across borders Eligible actionsIT and communication systems for the processing of visa applications and consular cooperationInfrastructures, buildings and operating equipment for the processing of visa applications, consular cooperation and actions to improve service quality to applicantsOperating equipment, means of transport for effective and secure border control and detection of peopleTraining in the use of equipment and systems and promotion of quality management standardsInfrastructures, buildings and operating equipment for border crossing points and surveillance 
 
 
 
 
 
 
 
ANNEX III: EVALUATION MATRIX 

The evaluation grids are structured according to eight evaluation criteria as presented in the following table.  

Evaluation criterion  
Effectiveness  
Efficiency  
Coherence  
EU Added Value  
Relevance  
Complementarity  
Sustainability  
Simplification  

Theme 

Effectiveness  

Acronym  
EFF  
EFF  
CO  
EUAV  
REL  
COMP  
SUS  
SIMPL  

97 

 
 
 
 
 
 
 
 
Action financed under ISF-BV 
have developed and facilitated 
legitimate travel through the 
common visa policy 

Sub-EQ1.1. What progress was 
made towards promoting the 
development and 
implementation of the common 
visa policy to facilitate 
legitimate travel, and how did 
the Fund contribute to 
achieving this progress? 

EQ1. How did the Fund 
contribute to the achievement 
of the following specific 
objectives (SO 1)?  
Support a common visa 
policy to facilitate legitimate 
travel 
Provide a high quality of 
service to visa applicants 
Ensure equal treatment of 
third-country nationals 
Tackle illegal immigration? 

Sub-EQ1.2. What progress was 
made towards ensuring better 
consular coverage and 
harmonized practices on visa 
issuance between MS, and how 
did the Fund contribute to 
achieving this progress? 

Actions supported by the funds 
contributed to better consular 
coverage on visa issuance 
between MS and promoted 
general harmonization among 
MS 

Quantitative: common 
indicators listed in Annex IV of 
Regulation (EU) 515/2014 and 
common result and impact 
indicators listed in Annex IV of 
Regulation (EU) 2017/207R:  
Total airport transit visas and 
uniform/short-stay visas issued 
(including multiple ATVs, 
MEVs and LTVs) (regression 
analysis) 
Not issued rate for airport transit 
visas and uniform/short-stay 
visas (regression analysis) 
Evidence of sharing best 
practices among MS 
Perception of key stakeholders 
Common indicators SO1 R2: 
number of consular cooperation 
activities developed with the 
help of the Instrument 
SO1 I1: number of visa 
applicants having to apply for a 
Schengen visa outside of their 
country of residence 
SO1 I2; number of visa required 
countries in the world where the 
number of MS present has 
increased 
Examples of information 
sharing between MS 
Perception of stakeholders in 
enhanced harmonization on visa 
issuance between MS 

DG HOME statistics 
SFC2014 (financial and 
physical implementation) 
Eurostat 
EU and MS programming and 
implementation documents (ex 
post evaluation reports, annual 
implementation reports of 
national programmes)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders  
Country case studies 
Focus groups 
Surveys  
Quantitative analysis 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 

98 

 
 
 
 
 
 
 
Sub-EQ1.3. What progress was 
made towards ensuring the 
application of the Union's 
acquis on visas and how did 
the Fund contribute to 
achieving this progress? 

Actions financed under ISF-BV 
have promoted a uniform 
application of Union’s acquis on 
Visa System policy in terms of 
skills acquired and general 
improvement 

Actions financed under ISF-BV 
have strengthened cooperation 
between MS operating in third 
countries as regards management 
of migrants flows as well as 
illegal immigration  

Sub-EQ1.4. What progress was 
made towards MS' contribution 
to strengthening the 
cooperation between MS 
operating in third countries as 
regards the flows of third-
country nationals into the 
territory of MS, including 
prevention and tackling of 
illegal immigration, as well as 
the cooperation with third 
countries, and how did the 
Fund contribute to achieving 
this progress? 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 
EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 

Common indicator SO1 R3: 
Number of staff trained and 
number of training courses in 
aspects related to the common 
visa policy with the help of the 
Instrument. 
Number of Schengen 
Evaluations recommendations in 
the area of visa addressed with 
the support of the Fund, as 
compared to the total number of 
recommendations issued 
(regression analysis) 
Perception of stakeholders 

Common indicators : 
Number of specialized posts in 
3rd countries supported by the 
Fund; 
SO1 R1: Number of Schengen 
Evaluation missions in the area 
of visa carried out with support 
of the Internal Security Fund 
("Fund") 
SO1 R5: Number of Schengen 
Evaluations recommendations in 
the area of visas addressed with 
the support of the Fund, as 
compared to the total number of 
recommendations issued (a/b) 
SO1 R6: Number of persons 
using fraudulent travel 
documents detected at 
consulates supported by the 
Fund 
Purchase of equipment at border 
crossing points; 
Examples of responses (capacity 
building, awareness raising, 

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Sub-EQ1.5. What progress was 
made towards supporting the 
common visa policy by setting 
up and running IT systems, 
their communication 
infrastructure and equipment, 
and how did the Fund 
contribute to achieving this 
progress? 

The fund supported MS in the 
setting-up of IT System and 
Communication Systems that 
effectively supported the visa 
system 

knowledge exchange) in 3rd 
countries to prevent illegal 
migration 
Perception of stakeholders on 
enhanced cooperation 

Total spending on IT systems 
and equipment purchased by 
MS through the fund  
Trained staff on IT systems and 
equipment 
Number of IT  systems that are 
developed, upgraded and 
maintained with the fund’s 
support 

Sub-EQ1.6. How did the 
operating support provided for 
in Article 10 of the Regulation 
(EU) No 515/2014 contribute 
to the achievement of the 
specific objective on border 
management? 

Authorities enabled to ensure the 
free movement of persons across 
internal borders with the support 
of the Fund 
Authorities enabled to efficiently 
monitor of persons crossing the 
EU’s external borders wit the 
support of the Fund 
With the fund support, IT 
systems, communication 
infrastructure and equipment are 
set up and running effectively 
(VIS, SIS). 

Value and number of projects 
financed under the operating 
fund 
Increase in the # of IT systems 
that are developed, upgraded 
and maintained for border 
management and visa control. 
Adequacy of operations 
financed under the OP 
Perception of stakeholders 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 
Document review (national 
evaluation reports, national 
programmes, national budgets, 
policy documents, etc) 
Quantitative analysis  
EU interviews  

100 

 
 
 
 
 
 
 
 
EQ2. How did the Fund 
contribute to the achievement 
of the following specific 
objectives (SO 2): 
Support integrated border 
management, including 
promoting further 
harmonisation of border 
management-related 
measures in accordance with 
common Union standards and 
through the sharing of 
information between MS and 
between MS and the 
European Agency for the 
Management of Operational 
Cooperation at the External 
Borders of the MS of the EU; 
Ensure, on one hand, a 
uniform and high level of 
control and protection of the 
external borders, including by 
the tackling of illegal 
immigration and, on the other 
hand, the smooth crossing of 
the external borders in 
conformity with the Schengen 
acquis, while guaranteeing 
access to international 
protection for those needing 
it, in accordance with the 
obligations contracted by the 
MS in the field of human 
rights, including the principle 
of non- refoulement? 

The fund supported the 
development of policies 
reducing controls for people 
crossing internal borders 

EQ2.1 What progress was 
made towards promoting the 
development, implementation 
and enforcement of policies 
with a view to ensure the 
absence of any controls on 
persons 
when crossing the internal 
borders, and how did the Fund 
contribute to achieving this 
progress? 

Number of border control 
(checks and surveillance) 
infrastructure and means 
developed or upgraded with 
the help of the Fund 
Examples of reduced internal 
controls with the aid of ISF-
BV funding 
Perception of stakeholders on 
effectiveness of measures and 
enhanced cooperation 

EQ2.2  What progress was 
made towards carrying out 
checks on 
persons and monitoring 
efficiently the crossing of 
external borders, and how did 
the Fund contribute to 
achieving this progress? 

Through the Fund the checks on 
persons and the monitoring of 
external borders have been 
improved 

SO2 C2: Number of border 
control (checks and 
surveillance) infrastructure and 
means developed or upgraded 
with the help of the Fund 
SO2 R2: Number of border 
crossings of the external 
borders through ABC gates 
supported by the Instrument 
out of the total number of 
border crossings 
SO2 I3: Number of irregular 
border crossings detected at 
EU external borders  
SO2 I5: Number of persons 
using fraudulent travel 
documents detected at the 
border crossing points 
Increase in the staff trained and 
training courses on border 
management in MS; 

101 

 EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 

 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
Examples of improved border 
security measures and 
equipment implemented. 
Total number of border 
crossings points 

SO2 R5: Number of equipment   
items used during Frontex 
Coordinated Operations which 
were purchased with support of 
the Funds as compared to the 
total number of equipment 
items used for Frontex 
Coordinated Operations (a/b). 
number of irregular border 
crossings detected at the EU 
external borders (b) at the 
border crossing points 
number of persons using 
fraudulent travel documents 
detected at the border crossing 
points 
Evidence of Establishing new 
or reinforcing existing 
integrated systems for border 
control (infrastructure, and 
operating equipment) 
Evidence of strengthened 
cooperation between MS to 
ensure a high level of control 
and protection of external 
borders 
SO2 R1: Number of staff 
trained and number of training 
courses in aspects related to 
border management with the 
help of the Instrument 
SO2 R3: Number of Schengen 
Evaluation missions in the area 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders  
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  

EQ2.3 What progress was 
made towards establishing 
gradually an 
integrated management system 
for external borders, based on 
solidarity and responsibility, 
and how did the Fund 
contribute to achieving this 
progress? 

Information sharing on border 
management and visa is 
facilitated through improved 
technology. (equipment and use 
of IT), trained staff and 
exchange of best practices 
between MS. 

EQ2.4 What progress was 
made towards ensuring the 
application of the Union's 
acquis on border management, 
and how did the Fund 
contribute to achieving this 
progress? 

Through the Fund, MS have 
been supported in the application 
of Union’s acquis on border 
management. 

102 

 
 
 
Member states have reinforced 
their reaction capabilities and are 
their awareness at external 
borders. 

EQ2.5 What progress was 
made towards contributing to 
reinforcing 
situational awareness at the 
external borders and the 
reaction capabilities of MS, 
and how did the Fund 
contribute to 
achieving this progress? 

Interviews with DG HOME 
stakeholders and other EU 
stakeholders  
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders  
Country case studies 
Focus groups 
Surveys 
Quantitative analysis 

of borders carried out with the 
support of the Fund 
SO2 R4: Number of Schengen 
Evaluation recommendations 
in the area of borders 
addressed with the support of 
the Fund, as compared to the 
total number of 
recommendations issued (a/b) 
Perception of stakeholders 
SO2 I1: Number of national 
border surveillance 
infrastructure 
established/further developed 
in the framework of Eurosur 
Number of incidents reported 
by the Member State to the 
European Situational Picture: 
Illegal immigration, including 
on incidents relating to a risk 
to the lives of migrants 
Number of incidents reported 
by the Member State to the 
European Situational Picture: 
Crisis situations 
Number of incidents reported 
by the Member State to the 
European Situational Picture: 
Cross-border crime 
SO2 I4: Number of searches in 
Schengen Information System 
(SIS II). 

EQ2.6 What progress was 
made towards setting up and 
running IT systems, their 
communication infrastructure 
and equipment that support 
border checks and border 
surveillance at the external 

The Fund has contributed to the 
innovation or upgrade of 
communication infrastructure 
and equipment that support 
border checks and border 
surveillance at the external 
borders 

Evidence of setting up IT 
systems for border crossing 
surveillance and management 
of migration flows. 
Number of cooperation 
activities between MS 
supporting the information 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  

103 

 
 
 
borders, and how did the Fund 
contribute to achieving this 
progress? 

EQ2.7 What progress was 
made towards supporting 
services to MS in duly 
substantiated emergency 
situations requiring urgent 
action at the external borders, 
and how did the Emergency 
Assistance contribute to 
achieving this progress? What 
type of emergency actions was 
implemented? How did the 
emergency actions 
implemented under the Fund 
contribute to addressing the 
urgent needs of the Member 
State? What were the main 
results of the emergency 
actions? 

EQ2.8 How did the operating 
support provided for in Article 
10 of the Regulation (EU) No 
515/2014 contribute to the 
achievement of the specific 
objective on border 
management? 

Through the fund, MS have duly 
substantiated emergency 
situations requiring urgent action 
at the external borders. 

exchange and cooperation with 
third countries in the 
neighbourhood region  
Perception of stakeholders 

Evidence of timely and 
effective Emergency 
Assistance  
Fund’s role in addressing 
urgent needs and crises. 
Evidence of successful results 
in crisis management. 
Perception of stakeholders 

Operating Support has been used 
coherently with objectives set 
out by the Regulation 
Operating Support schemes have 
supported Member States 

Adequacy of projects financed 
under the OP 
Perception of stakeholders 

Interviews with DG HOME 
stakeholders and other EU 
stakeholders 
Country case studies 
Focus groups 
Quantitative analysis 
Quantitative analysis 
EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including staff 
managing Fund, EU agencies 
involved at the operational level 
(e.g. Europol, Frontex, eu-LISA, 
EUAA), and relevant experts 
Country case studies 
Focus groups 
Surveys 

EU and MS desk research, 
including review of programme 
documents (performance 
documents, financial data, 
SFC2014-2020 data,  etc)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders  
Country case studies 
Focus groups 
Surveys 

104 

 
 
 
 
 
Efficiency 
Theme 
Question 
EQ3. Were the 
general objectives 
of the Fund 
achieved at 
reasonable cost? 

Efficiency 
Sub-questions 
To what extent were the 
expected results of the 
Fund achieved at 
reasonable cost in terms 
of deployed financial and 
human resources? 

Judgment criteria 
Appropriate arrangements were 
used to select cost-effective 
operations  

Indicators 
Stakeholder perception on the adequacy of the 
mechanism used to select the different operations 
(e.g., IT and communication systems; 
infrastructure building and operating systems; 
trainings);  

Sources 
Online survey 

105 

 
 
Financial allocation per MS and per types of 
actions 
Human resource allocated per MS and per types 
of actions 
Absorption rate per MS and overall 
Result and Output indicators as per Core 
performance Indicators (2014-2020). 
Cross-country analysis (National Programmes): 
data envelopment analysis (cost-effectiveness of 
each Programme will be measured by comparing 
financial resources used and an index composed 
by a set of result/output indicators. The distance 
of each MS from the efficiency frontier will 
allow a cross-country comparison. Consultation 
of stakeholders will be used to identify the 
causes of inefficiencies.) 
Stakeholder perception on the level of cost-
effectiveness of Union Actions   
Stakeholder perception of the Level of cost-
effectiveness of Emergency Assistance 
Perception of stakeholders regarding the 
adequacy of the administrative burdens 

Annual implementation 
reports 
SFC2014 
Thematic Case studies 
Literature and desk review 

Online survey  
Country Case studies 

The fund supported types of 
interventions that are known to be 
cost-effective, based on available 
evidence, including relevant 
literature or the ex-post evaluation 
of the previous Fund   

The administrative burden is 
proportionate for all implementing 
actors (Responsible Authorities and 
other delegated authorities), 
compared to the previous 
programming period similar 
services offered to comparable 
target groups without the support of 
the Fund   
The administrative burden is 
proportionate for all beneficiaries, 
compared to the previous 
programming period/ similar 
services offered to comparable 
target groups without the support of 
the Fund   
The administrative burden is 
proportionate for all end-users, e.g., 
compared to the previous 
programming period/ similar 

106 

 
 
 
services offered to comparable 
target groups without the support of 
the Fund 
Absence of ‘gold-plating’ at the 
national level (e.g., from 
Responsible Authorities, 
Intermediate Bodies, national Audit 
Authorities), i.e. requirements are 
not interpreted more  
Absence of ‘gold-plating’ at the EU 
level, i.e., requirements are not 
interpreted more restrictively then 
in the legal basis and unless a 
justified reason exists 
The management and control 
system of the MS, described as per 
the legal basis, ensures quality of 
the of the implementation of 
National Programmes and the 
prevention, detection and correction 
of irregularities, including fraud, 
and the recovery of amounts unduly 
paid, together with any interest on 
late payments   
The management and control 
system of the MS, described as per 
the legal basis, ensures quality of 
the of the implementation of 
National Programmes and the 
prevention, detection and correction 
of irregularities, including fraud, 
and the recovery of amounts unduly 
paid, together with any interest on 
late payments   

What measures were put 
in place to prevent, detect, 
report and follow up on 
cases of fraud and other 
irregularities, and how did 
they perform? 

What measures were put 
in place to prevent, detect, 
report and follow up on 
cases of fraud and other 
irregularities, and how did 
they perform? 

Number of mechanisms in place at MS level to 
report, detect and prevent fraud and irregularities 
(where possible, analysed by country) 

Online survey 
Annual implementation 
reports 

Number of mechanisms in place at MS level to 
report, detect and prevent fraud and irregularities 
(where possible, analysed by country) 

Online survey 
Annual implementation 
reports 

Relevance 
Theme 
Evaluation Question 

Relevance 

Sub-questions 

Judgment criteria 

Indicators 

Sources 

107 

 
 
 
 
EQ. 7 Did the objectives 
of the interventions 
funded by the Fund 
correspond to the actual 
needs? 

Sub-EQ 7.1 Did the objectives 
set by the Member State in the 
National Programme respond 
to the identified needs? 

The objectives set by the 
Member States in their National 
Programme responded to their 
identified needs  
At the time when the National 
Programmes were drafted 
In the course of the 
implementation of the National 
Programmes (evolving needs) 

Sub-EQ 7.2 Did the objectives 
set in the Annual Work 
Programme (Union Actions) 
address the actual needs? 

The objectives set in the Annual 
Work Programme (Union 
Actions) responded to the 
identified need for  transnational 
initiatives that benefit the EU as 
a whole 

108 

Documentary evidence and/or 
stakeholders feedback that the 
identification of key needs, 
priorities and objectives was built 
in the design of the national 
programmes (e.g., evidence of 
policy dialogue between the 
Commission and the Member 
States at the beginning of the 
programming stage) 
National authorities feedback on 
the extent to which they consider 
that the objectives and activities of 
the Fund addressed the needs of the 
EU, Member States, and citizens 
Documentary evidence and/or 
stakeholders feedback that the 
flexibility offered by the Fund (i.e., 
transfers of money between 
different objectives) helped to 
address changing needs and 
emerging challenges (e.g. COVID-
19 or country specific crisis) 
Sum allocated to the Member 
States national programme, per 
Member States and assessment of 
whether Member States’ with the 
greatest needs received the most 
funding 
EU and national authorities 
feedback on the extent to which 
they consider that the objectives set 
in the Union Action Work 
Programme addressed the needs of 
the EU, Member States, and 
citizens 
Evidence and stakeholders’ 
feedback on whether the Union 
Actions provided the Fund with 
sufficient flexibility to respond to 

Desk research including 
programme documentation and 
the ISF-BV interim evaluation 
as well as the evaluation of the 
External Borders fund (2007-
2013) 
Mapping of the scope of 
investments and target groups 
Focus Group 1 discussions 
Surveys of relevant national 
authorities within Member 
States 
Survey of other relevant 
national authorities, competence 
centers, experts at EU and 
national level 
Survey of beneficiaries  
Public Consultation 
Country and thematic case 
studies including related desk 
research and interviews 

Thematic case study on Union 
Actions  
Mapping of the scope of 
investments and target groups 
Focus Group 1 discusions 
Surveys of relevant national 
authorities within Member 
States 
Survey of other relevant 
national authorities, competence 

 
 
 
emerging/changing needs on a 
transnational level 
Sum allocated to the Union Actions 
to respond to emerging needs (as a 
% of the total ISF-BV fund) 

EU, national authorities and 
International Organisations’ 
feedback on the extent to which 
they consider that the objectives set 
in the Emergency Assistance Work 
Programme addressed the needs of 
the EU, Member States, and 
citizens 
Documentary evidence highlighting 
the flexibility of the Fund (e.g., 
examples that budget allocations 
were changed in the course of the 
implementation to better respond to 
needs)  
Stakeholders’ feedback on whether 
Emergency Assistance provided the 
Fund with sufficient flexibility to 
respond to emerging/changing 
needs 
Sum allocated to the EMAS to 
respond to emerging needs (as a % 
of the total ISF-BV fund) 
Documentary evidence that 
Member States (in the case studies 
selected) conducted continuous 
needs assessments on a regular 
basis or whenever there were 
relevant contextual changes at the 
national level (considering the 
National Programmes 
implementation) and at 

centers, experts at EU and 
national level 
Survey of beneficiaries under 
National Programmes 
Public Consultation 
Interviews with EU stakeholders 
and national stakeholders 
Country case studies (interviews 
with national authorities) 
Thematic case study on EMAS 
Desk research including 
programme documentation; EU 
policies and strategy documents; 
and the ISF-BV interim 
evaluation as well as the 
evaluation of the External 
Borders fund (2007-2013) 
Mapping of the scope of 
investments and target groups 
Focus Group 1  
Surveys of relevant national 
authorities within Member 
States 
Survey of other relevant 
national authorities, competence 
centers, experts at EU and 
national level 
Survey of beneficiaries under 
National Programmes 
Public Consultation 

Desk research including 
programme documentation; EU 
policies and strategy documents; 
and the ISF-BV interim 
evaluation as well as the 
evaluation of the External 
Borders fund (2007-2013) 
Mapping of the scope of 
investments and target groups 

Sub-EQ 7.3 Did the objectives 
set in the Annual Work 
Programme (Emergency 
Assistance) address the actual 
needs? 

The objectives set in the Annual 
Work Programme (Emergency 
Assistance) responded to the 
identified needs to address 
immediate and specific 
emergency situations requiring 
urgent action  

Sub-EQ 7.4 Which measures 
did the Member State put in 
place to address changing 
needs? 

Needs assessment were 
conducted on a continuous basis 
to ensure the continued relevance 
of the ISF-BV programme for its 
stakeholders (needs were 
identified)  

Appropriate mechanisms and 
processes (including the 

109 

 
 
partnership / monitoring 
committee) were put in place to 
address changing needs both at 
the programming and 
implementation phases, in a 
timely manner  

Focus Group 1  
Surveys of relevant national 
authorities within Member 
States 
Survey of other relevant 
national authorities, competence 
centers, experts at EU and 
national level 
Survey of beneficiaries under 
National Programmes 
Public Consultation 
Interviews with EU stakeholders  
Country case studies (interviews 
with national authorities, 
including the Monitoring 
Committees) 
Answers to coherence and 
complemetarity EQs regarding 
cooperation mechanisms and 
processes in place. 

transnational level (for Union 
Actions) 
Number of National Authorities 
who conducted needs assessment 
Documentary evidence and/or 
stakeholders opinion that the funds 
objectives rely on diagnosis/ 
studies/assessment of border 
management and visa policy needs 
in the EU and make direct reference 
to them (needs are identified) 
Evidence of mechanisms and/or 
consultative process, such as the 
partnership / monitoring committee, 
to engage with stakeholders and 
ensure the continued relevance of 
Fund to address changing needs by 
providing timely input on evolving 
needs and relevant developments 
on the ground (e.g., changes in 
migratory pressures, threats of 
cross-border crime, and the need to 
maintain a balance between 
security concerns and facilitating 
legitimate travel).  

Coherence  
The evaluation of coherence looks at a how well different actions with similar objectives work together. Complementarity is similar to coherence and can be considered a sub-
set of coherence (as stated in the Better Guidelines Toolbox, Tool #47). While coherence is broader, complementarity focuses more specifically on the extent to which EU 
policies and interventions support and usefully supplement other policies (particularly those pursued by the Member States). To avoid overlap between the evaluation questions 
dealing with coherence and complementarity, and in line with the evaluation questions in the ToR, we distinguished between coherence and complementarity as follow: 
coherencewill assess the internal coherence of the ISF-BV Fund management modes as well as the Fund’s external coherence with other programmes funded by the EU which 
have similar objectives. 
complementarity (see next criterion) will assess the external coherence/complementarity of the Fund with other funds, initiatives and policies pursued by the Member States 
and which have similar objectives. 

110 

 
 
 
The coherence criteria will assess whether the ISF-BV objectives (notably those of the National Programmes) were aligned with: 
The policy goals and priorities of the EU in the fields of visa policy and border management as well as humanitarian policy and EU’s external actions 
The objectives of other thematically relevant DG HOME funding instruments and initiatives (e.g., AMIF and ISF police)  
The objectives of other relevant EU funds which (potentially) overlap/complement ISF-BV such as such as DG TAXUD (Customs 2020), DG JUST (Justice 
Programme), and DG RTD (Horizon 2020 and Horizon Europe) and /or EEAS funded activities. 
The assessment will consider whether there were synergies or duplications/overlap at the programming phase as well as during the implementation period of the 
Fund (i.e., continued coherence) including whether appropriate mechanisms were put in place to monitor and address any potential duplications/overlap and 
ensure greater synergies where possible and relevant. 

As per the Better Regulation Toolbox 47, the assessment of the complementarity criteria will rely mostly on qualitative findings. It will look for evidence of 
synergies or inconsistency between ISF-BV and other initiatives and policies in the fields of visa policy and border management at the EU level which have the 
same or similar objectives and are expected to work together or inform one another.  

The approach will rely on desk research (e.g., review of a relevant sample of project documentation and broader overarching EU strategies and policy documents) 
together with targeted consultation of EU stakeholders (interviews and thematic case studies) and national authorities (country case studies and surveys).  

Coherence 

Theme 
Evaluation Question 
EQ4. Were the objectives 
set in the Fund coherent 
with the ones set in other 
programmes funded by EU 
resources and applying to 
similar areas of work?  
Note to DG HOME: We 
propose to remove the 
reference to "National 
Programme" in order to 
also look at other aspect of 
the Fund and incorporate 
the element on internal 
coherence. 

Sub-questions 
Sub EQ 4.1 Has the structures 
of the Fund ensured greater 
complementarities and, where 
relevant, synergies across the 
different management modes? 
(This is an additional sub-
question not originally foreseen 
in the ToR. It will enable the 
study to look more in depth 
into internal coherence. In 
addition, a similar question is 
included for the evaluation of 
BMVI which will allow the 
study to draw comparisons) 

Judgment criteria 
The structure and management 
mode of the Fund (into Direct, 
indirect and shared management 
as well as into national 
programmes, EMAS and Union 
Actions) and its internal 
organisational arrangements or 
coordination mechanisms ensured 
complementarities and, where 
relevant, synergies. 

Indicators 
Documentary evidence and/or 
stakeholders perception of 
complementarity or overlap 
between the Fund’s different 
implementation mechanisms 
(shared, direct and indirect) 
Document evidence and/or 
stakeholders perception of 
complementarity or overlap 
between the Fund’s 
implemetation mechanisms 
(national programmes, EMAS 
and Union Actions) 
Documentary evidence and/or 
stakeholders perception of 
internal mechanisms/structure to 
ensure synergies and prevent 
overlaps 

Sources 
EU level desk research 
including review of 
programme documents 
(e.g., regulation, Work 
Programme, existing 
coordination mechanisms, 
etc.) and the ISF-BV mid-
term evaluation 
Interviews with EU (DG 
HOME) and national 
stakeholders  
Thematic case studies on 
the different management 
modes 

111 

 
 
 
Sub EQ 4.2 Was an assessment 
of other interventions with 
similar objectives carried out 
and taken into account during 
the programming stage? 

DG HOME carried out 
assessments of other EU 
interventions with similar 
objectives during the 
programming phase to avoid 
duplication/overlap and build on 
synergies 

Documentary evidence of a 
mapping/assessment of other 
interventions conducted to 
maximise synergies and avoid 
duplications. 
Documentary evidence and/or 
stakeholders feedback that 
stakeholders from other EU 
interventions were consulted 
EU stakeholders’ opinions on 
whether the assessment of other 
interventions with similar 
objectives (if any was carried 
out) was sufficient, and 
sufficiently taken into account 
during the programming stage of 
ISF-BV 

EQ5. Was the coherence 
ensured also during the 
implementation of the 
Fund? 

Sub EQ 5.1 Were coordination 
mechanisms between the Fund 
and other interventions with 
similar objectives established? 

Coordination mechanisms and 
arrangements were used regularly 
and to good effect, by DG HOME 
to ensure: 
Continued alignment with EU 
policies and strategies in the realm 
of border management and visa 
policy as well as humanitarian 
policy and EU’s external actions 
(e.g., Pact on Migration and 
Asylum, Internal Security 
Strategy and Action Plan, EBCG 
Regulations) Coordination, 
complementarities and, where 
relevant, synergies across other 
EU funds, in particular DG 
HOME AMIF and ISF funds, 

Documentary evidence and/or 
stakeholders feedback on the 
existence of structural/ 
coordination mechanisms to 
ensure ongoing alignment with 
other EU funds/policies and 
adapt to changes and evolving 
needs accordingly (e.g., 
evidence of information 
exchange on the Fund’s actions 
and projects between the 
responsible authorities and other 
institutional actors responsible 
for other funds at different levels 
and with Frontex; institutional 
arrangements, specific 
directorates, divisions, units, 

112 

EU level desk research 
including review of the 
ISF-BV mid-term 
evaluation, and a review of 
programme documents to 
fill the gaps if any (e.g., 
study, mapping or 
assessment of other EU 
interventions conducted by 
DG HOME during the 
programming stage) 
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including 
Commission staff 
managing other funds, the 
Committee for the Home 
Affairs Funds, and EU 
Agencies in the field of 
Justice and Home Affairs  
Thematic case studies 
(interviews with EU 
stakeholders in particular) 
EU level desk research 
including review of the 
ISF-BV mid-term 
evaluation, and a review of 
programme documents to 
fill the gaps if any (e.g., 
documents on coordination 
mechanisms with other 
Funds)  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including 
Commission staff 
managing other funds, the 
Committee for the Home 
Affairs Funds, and EU 

 
 
cohesion policy, Customs 2020, 
EEAS actions, DG Justice 
Programme and ESIF. 

Sub EQ 5.2 Were the 
objectives and types of 
activities of the Fund coherent 
with and non-contradictory to 
other interventions with similar 
objectives? 
Note to DG HOME: As per 
BRG,  coherence should look at 
the objectives and not the 
actions, we therefore propose 
to rephase accordingly 

The objectives and types of 
activities funded through the ISF-
BV align with: 
EU (cross-cutting) policies and 
priorities (e.g. on migration, 
EIBM and visa as well as 
humanitarian policy and EU’s 
external actions)  
other EU actions/activities in the 
area of migration and border 
management including other 
Home Affairs Funds (e.g., AMIF 
and ISF Police)  
other relevant EU funds including 
Horizon, Customs 2020, EEAS 
actions, Justice Programme and 
ESIF 

platforms, and committees set up 
to boost the coordination and 
synergies with other EU funds; 
etc.) 
Stakeholders perception that the 
mechanisms and bodies in place 
are adequate to generate 
synergies and avoid duplication 
of effort 

Documentary evidence of 
alignment between ISF-BV 
objectives and type of activities 
with EU policies  
documentary evidence and 
stakeholders perception of 
synergies (cooperation and 
collaboration) and/or duplication 
between ISF-BV and other EU 
interventions with similar 
objectives (see judgement 
criteria). 
Number of stakeholders that 
positively assessed the 
coherence of the Fund with other 
EU policies and interventions 
with similar objectives. 

Agencies in the field of 
Justice and Home Affairs  
Thematic case studies 
(interviews with EU 
stakeholders in particular) 

EU level desk research 
including review of the 
ISF-BV mid-term 
evaluation, of programme 
documents (ISF-BV and 
other relevant EU 
interventions, including 
their midterm and expost 
evaluations) and relevant 
EU policy and strategy 
documents on border 
management and visa 
policy  
Interviews with DG HOME 
stakeholders and other EU 
stakeholders including 
Commission staff 
managing other funds, the 
Committee for the Home 
Affairs Funds, and EU 
Agencies in the field of 
Justice and Home Affairs  
Thematic case studies 
(interviews with EU 
stakeholders in particular) 

113 

 
 
 
 
EQ6.2 Would have the Member 
States carried out the actions 
required to implement the EU 
policies in the Fund areas 
without the financial support of 
the Fund? 

The financial support of the 
Fund proved to be pivotal 
towards the implementation of 
relevant actions by the Member 
States 

Number and type of new equipment 
and tools acquired 

Extent to which existing equipment 
have been enhanced 

Stakeholders’ perception 
(beneficiaries) on advantages / 
benefits in terms of their capacity 
and competence to prepare, 
implement and manage projects 

EQ6.3 What would be the most 
likely consequences of an 
interruption of the support 
provided by the Fund? 

The actions implemented through the Fund’s 
support contributed towards scope effects, 
scale effects, function/role/process effects, 
and the overall impact on Union-level 
objectives that would not have been achieved 
by Member States acting alone 

The discontinuity of the Fund’s financial 
support would reflect in most ongoing 
actions being interrupted and new actions not 
being confirmed 

Amount of national 
resources dedicated to 
borders and visas 

Number and type pf 
innovative solutions 
adopted throughout the 
ISF-BV 

Level of improvement 
of existing innovative 
solutions 

Documentary review: 
National programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 

Country case study 
interviews 

Thematic case study 
interviews 

Survey for end-
beneficiaries 

Interviews at MS level 
Documentary review: 
National programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 

Country case study 
interviews 

Thematic case study 
interviews 

Survey for end-
beneficiaries 

Interviews at MS level 

114 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EQ6.4 To what extent have 
actions supported by the Fund 
resulted in a benefit at the Union 
level? 

The results at the EU level would not have 
been achieved at all, would have been 
achieved to a smaller extent, or would have 
taken more time to materialise without EU 
funding 

The role of EU-level stakeholders would 
have been more limited without Fund’s 
backing 

Amount of national 
resources dedicated to 
borders and visas 

Stakeholders’ judgment 
(at EU-level) on 
whether their role 
would have been more 
limited without the ISF-
BV  

EQ6.5 What was the added 
value of operating support? 

Equipment and systems acquired and 
activated through Operating support allowed 
for a smooth implementation of the actions 

Number and type of 
new equipment and 
tools acquired 

Extent to which 
existing equipment 
have been enhanced 

Stakeholders’ 
perception 
(beneficiaries) on 
advantages / benefits in 
terms of their capacity 
and competence to 
prepare, implement and 
manage projects (in the 
framework of Operating 
Support) 

115 

Documentary review: 
National programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 

Country case study 
interviews 

Thematic case study 
interviews 

Survey for end-
beneficiaries 

Interviews at MS level 
Documentary review: 
National programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 
Operating Support 
specific project docs 

Country case study 
interviews 

Thematic case study 
interviews 

Survey for end-
beneficiaries 

Interviews at MS level 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Complementarity 

Complementarity 

Theme 
Evaluation Question 
EQ. 8 Were the objectives set 
in the national programme and 
the corresponding 
implemented actions 
complementary to those set in 
the framework of other 
policies, in particular those 
pursued by the Member State 

Sub-questions 
Sub-EQ 8.1 Was an assessment 
of other interventions with 
complementary objectives 
carried out and taken into 
account during the 
programming stage? 

Judgment criteria 
Member States carried out 
assessments of other EU 
interventions with similar 
objectives during the 
programming phase stage to avoid 
duplication/overlap and build on 
synergies 

Indicators 
Documentary evidence (in the 
case studies countries) and/or 
stakeholders feedback of an 
assessment of other 
interventions conducted by 
Member States to maximise 
synergies and avoid duplications 
Number of National Authorities 
that reported having conducted 
an assessment of 
otherinterventions 
Documentary evidence and/or 
stakeholders feedback of 
synergies (cooperation and 
collaboration) and/or duplication 
between ISF-BV and Member 
States funds/instruments at the 
design stage 
EU stakeholders’ opinions on 
whether the assessment of other 
interventions with similar 
objectives (if any was carried 
out) was sufficient, and 
sufficiently taken into account 
during the programming stage of 
ISF-BV 
Number of Member States that 
positively assessed the 
coherence of the Fund with other 
EU and national funds at the 
programing stage 

Sources 
Desk research (e.g., 
identification of 
challenges related to 
the assessment 
conducted reported in 
the Annual/ Final 
implementation 
reports)  
Country case studies 
(interviews with 
national authorities and 
desk review of 
assessment of other EU 
interventions if any 
carried out) 
Survey with national 
authorities (coherence 
and complementarity 
with national funds) 
Survey of other 
relevant national 
authorities, competence 
centers, and experts at 
EU and national level 
Survey of beneficiaries 
under National 
Programmes 
Interviews with EU 
stakeholders  

116 

 
 
 
 
Sub-EQ 8.2 Were coordination 
mechanisms between the Fund 
and other interventions with 
similar objectives established 
to ensure their complementarity 
for the implementing period? 

Coordination mechanisms and 
arrangements were used regularly 
and to good effect to ensure 
coordination, complementarities 
and, where relevant, synergies 
between ISF-BV and Member 
States instruments/initiatives. 

Number of Member States that 
have in place structural/ 
coordination mechanisms to 
ensure ongoing alignment with 
other EU funds/policies and 
adapt to changes and evolving 
needs accordingly (e.g., 
evidence of information 
exchange on the Fund’s actions 
and projects between the 
responsible authorities and other 
institutional actors responsible 
for other funds at different levels 
and with Frontex; institutional 
arrangements, specific 
directorates, divisions, units, 
platforms, and committees set up 
to boost the coordination and 
synergies with other EU funds; 
etc.) 
Stakeholder opinion on the 
mechanisms and whether they 
are  considered by the 
stakeholders to be effective in 
generating synergies and avoid 
duplication of effort. 

Desk research (e.g., 
identification of 
coordination 
mechanisms and 
structure set up 
reported in the Annual/ 
Final implementation 
reports)  
Country case studies 
(interviews with 
national authorities, 
including the 
Monitoring 
Committees (249) and 
desk review of 
coordination processes 
if any) 
Survey with national 
authorities (coherence 
and complementarity 
with national funds) 
Survey of other 
relevant national 
authorities, competence 
centers, and experts at 
EU and national level 
Survey of beneficiaries 
under National 
Programmes 
Interviews with EU 
stakeholders  

(249) Findings from the ISF-BV midterm evaluation: The MC includes, as members or as observers, representatives of institutions responsible for the use of other relevant funds. 
It holds regular meetings and continuously analyses the implementation status of ISF-BV projects 

117 

 
 
 
Sub-EQ 8.3 Were mechanisms 
aimed to prevent overlapping 
of financial instruments put in 
place? 

Coordination mechanisms and 
arrangements were used regularly 
and to good effect to avoid the 
overlap of financial instruments. 

The objectives and funded 
activities of the ISF-BV 
implemented by Member States 
aligned with those they 
implemented through other 
national and EU programme  

Sub-EQ 8.4 Were the actions 
implemented through the Fund 
coherent with and non-
contradictory to other 
interventions with similar 
objectives implemented by 
Member States? 
(Noted: We suggest to add this 
additional sub-question as the 
logical continuation of the 
previous sub-EQ (which look at 
whether coordination 
mechanism were established) 
to assess whether this 

118 

Number of Member States that 
have in place coordination 
mechanisms and bodies to 
prevent overlapping of financial 
instruments and ensure 
traceability and control of 
funding throughout the entire 
project lifetime; 
Documentary evidence and/or 
stakeholders feedback on the 
(regular) use and effectiveness 
of  these coordination 
mechanisms (e.g.,  
Documentary evidence and/or 
stakeholders feedback of 
synergies and overlap of 
financial instrument) 
Stakeholders opinion on whether 
the mechanisms and bodies in 
place are considered to be 
adequate in preventing the 
overlap of financial instruments. 

Documentary evidence of 
synergies (cooperation and 
collaboration) and/or duplication 
between ISF-BV and other 
interventions with similar 
objectives implemented by 
national authorities. 
Number of Member States that 
positively assessed the 
coherence of the ISF-BV Fund 
with other interventions with 
similar objectives implemented 
at the national level 

Desk research (e.g., 
identification of of 
coordination 
mechanisms and 
structure set up 
reported in the Annual/ 
Final implementation 
reports)  
Country case studies 
(interviews with 
national authorities, 
including the 
Monitoring 
Committees) 
Survey with national 
authorities (coherence 
and complementarity 
with national funds) 
Survey of other 
relevant national 
authorities, competence 
centers, and experts at 
EU and national level 
Interviews with EU 
stakeholders  

Desk research (e.g., 
identification of 
challenges related to 
duplication/overlap 
reported in the Annual/ 
Final implementation 
reports)  
Country case studies 
(interviews with 
national authorities, 
including the 
Monitoring 

 
 
 
 
mechanisms ensured 
coherence)  

EU added value 

Theme 
Questions 
EQ6. Was any value added 
brought about by the EU 
support? 

EU added value  

Sub-questions 
EQ6.1 What are the main types 
of added value resulting from the 
Fund support (volume, scope, 
role, process)? 

Judgment criteria 
The Fund contributed towards 
scope effects, scale effects, and 
function/role/process effects that 
would have not been achieved in 
the absence of the EU support 

Committees (250) and 
desk review of 
coordination processes 
if any) 
Survey with national 
authorities (coherence 
and complementarity 
with national funds) 
Survey of other 
relevant national 
authorities, competence 
centers, and experts at 
EU and national level 
Interviews with EU 
stakeholders  

Indicators 
Number of actions addressing a 
wider target groups / policy areas 
which were not considered in the 
programming phase 

Number and volume of actions 
per target group 

Perception of consulted 
stakeholders regarding the added 
value brought about by the Fund’s 
support 

Sources  
Documentary 
review: 
Annual 
Implementation 
Reports 
National 
Evaluations 
UA AWP 
EMAS 
EASO reports 
National policies on 
visa, border 
management, illegal 
immigration 

Country case study 
interviews 

(250) Findings from the ISF-BV midterm evaluation: The MC includes, as members or as observers, representatives of institutions responsible for the use of other relevant funds. 
It holds regular meetings and continuously analyses the implementation status of ISF-BV projects 

119 

 
 
 
 
 
 
 
 
EQ6.2 Would have the Member 
States carried out the actions 
required to implement the EU 
policies in the Fund areas without 
the financial support of the Fund? 

The financial support of the Fund 
proved to be pivotal towards the 
implementation of relevant 
actions by the Member States 

Number and type of new 
equipment and tools acquired 

Extent to which existing 
equipment have been enhanced 

Stakeholders’ perception 
(beneficiaries) on advantages / 
benefits in terms of their capacity 
and competence to prepare, 
implement and manage projects 

EQ6.3 What would be the most 
likely consequences of an 
interruption of the support 
provided by the Fund? 

The actions implemented through 
the Fund’s support contributed 
towards scope effects, scale 
effects, function/role/process 
effects, and the overall impact on 
Union-level objectives that would 
not have been achieved by 
Member States acting alone 

Amount of national resources 
dedicated to borders and visas 

Number and type pf innovative 
solutions adopted throughout the 
ISF-BV 

Level of improvement of existing 
innovative solutions 

120 

Thematic case 
study interviews 

Survey for end-
beneficiaries 

Interviews at MS 
level 
Documentary 
review: 
National 
programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 

Country case study 
interviews 

Thematic case 
study interviews 

Survey for end-
beneficiaries 

Interviews at MS 
level 
Documentary 
review: 
National 
programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 

 
 
 
 
 
 
 
 
 
 
 
 
The discontinuity of the Fund’s 
financial support would reflect in 
most ongoing actions being 
interrupted and new actions not 
being confirmed 

EQ6.4 To what extent have 
actions supported by the Fund 
resulted in a benefit at the Union 
level? 

The results at the EU level would 
not have been achieved at all, 
would have been achieved to a 
smaller extent, or would have 
taken more time to materialise 
without EU funding 

The role of EU-level stakeholders 
would have been more limited 
without Fund’s backing 

Amount of national resources 
dedicated to borders and visas 

Stakeholders’ judgment (at EU-
level) on whether their role would 
have been more limited without 
the ISF-BV  

EQ6.5 What was the added value 
of operating support? 

Equipment and systems acquired 
and activated through Operating 
support allowed for a smooth 
implementation of the actions 

Number and type of new 
equipment and tools acquired 

Extent to which existing 
equipment have been enhanced 

121 

Country case study 
interviews 

Thematic case 
study interviews 

Survey for end-
beneficiaries 

Interviews at MS 
level 
Documentary 
review: 
National 
programmes 
National Evaluation 
Reports 
UA AWP 
EMAS 
Selected EU-funded 
programmes 

Country case study 
interviews 

Thematic case 
study interviews 

Survey for end-
beneficiaries 

Interviews at MS 
level 
Documentary 
review: 
National 
programmes 
National Evaluation 
Reports 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Stakeholders’ perception 
(beneficiaries) on advantages / 
benefits in terms of their capacity 
and competence to prepare, 
implement and manage projects 
(in the framework of Operating 
Support) 

UA AWP 
EMAS 
Selected EU-funded 
programmes 
Operating Support 
specific project 
docs 

Sustainability  
Theme 

Question 
EQ9. Are the positive 
effects of the projects 
supported by the Fund 
likely to last when the 
support from ISF will be 
over? 

Sustainability 

Sub-questions 
Sub-EQ9.1. What measures 
were adopted by the Member 
State to ensure the 
sustainability of the results of 
the projects implemented with 
Fund support, both at the 
programming and 
implementation stage? 

Judgment criteria 
Measures to ensure sustainability 
of results adopted by MS during 
the programming stage provided a 
sound basis for the actions 

Measures adopted by MS during 
the implementation stage have 
supported sustainability of results 
of the implemented actions 

National Programmes supported 
the transfer or upscale of 
innovative projects 

Indicators 
Number of projects implemented 
through the Fund whose activities are 
set to continue without the EU funding 

Number of ISF-BV beneficiaries who 
have received financial resources by 
other EU Funds/ national Funds 

Stakeholders’ judgment on whether the 
measures implemented were adequate 
to support the projects sustainability.  

122 

Country case study 
interviews 

Thematic case 
study interviews 

Survey for end-
beneficiaries 

Interviews at MS 
level 

Sources 
Documentary 
review: 
National Evaluation 
Reports 
National 
Programmes 
Annual 
Implementation 
Reports 
Interviews: 
National RA 
Relevant 
Beneficiaries of 
funding EMAS, UA, 
NP 

 
 
 
 
 
 
 
 
 
 
Sub-EQ9.2. Were mechanisms 
put in place to ensure a 
sustainability check at the 
programming and 
implementation stage? 

Mechanisms to ensure 
sustainability of results adopted by 
MS during the programming stage 
provided a sound basis for the 
actions 

Mechanisms adopted by MS 
during the implementation stage 
have supported sustainability of 
results of the implemented actions 

Number of documents developed at EU 
Level and National level on 
sustainability 

Number of EU and national monitoring 
committee having sustainability as a 
topic in the agenda 

Stakeholders’ judgment on the 
adequacy of mechanisms carried out 

Sub-EQ9.3. To what extent are 
the outcomes/benefits of the 
actions sustained by the Fund 
expected to continue 
thereafter? 

Outcome and benefits of the 
projects funded through ISF BV 
are set to continue after the funding 
period 

Number of networks created through 
the Fund and still in place after the 
closure of the action 

Number of partnerships created through 
the Fund and still in place after the 
closure of the action 

Percentage of equipment acquired under 
the Fund in use after the end of the 
projects 

123 

Relevant EU 
agencies and EC 
DGs 
Survey 
Case Studies 

Documentary 
review: 
National Evaluation 
Reports 
National 
Programmes 
Annual 
Implementation 
Reports 
Interviews: 
National RA 
Relevant 
Beneficiaries of 
funding EMAS, UA, 
NP 
Relevant EU 
agencies and EC 
DGs 
Survey 
Case Studies 

Documentary 
review: 
National Evaluation 
Reports 
National 
Programmes 
Annual 
Implementation 
Reports 
Interviews: 
National RA 
Relevant 
Beneficiaries of 

 
 
 
 
 
 
 
 
  
Sub-EQ9.4. What measures 
were adopted to ensure the 
continuity of the activities 
carried out thanks to the 
operating support? 

Measures adopted provide a sound 
basis for the continuity of actions 
supported by the Fund 

Share of maintenance cost of equipment 
acquired under the Fund on the total EU 
contribution to actions co-finance by the 
Fund 

Retention of staff trained ex-ante and 
ex-post with respect to training 
delivered through the Fund 

Stakeholders’ judgment on whether 
outcomes/benefits of the actions 
sustained by the Fund are likely to 
continue thereafter 
Number of measures adopted to ensure 
the continuity of actions supported by 
the Fund 

Share of respondents who considered 
the measures as sound and adequate 

Consensus / divergence among the 
interviewees on the measures adopted to 
ensure the continuity of actions 
supported by the Fund 

funding EMAS, UA, 
NP 
Relevant EU 
agencies and EC 
DGs 
Survey 
Case Studies 

Documentary 
review: 
National 
implementation and 
evaluation reports 
Interviews: 
National RA 
Relevant 
Beneficiaries of 
funding EMAS, UA, 
NP 
Relevant EU 
agencies and EC 
DGs 
Survey 
Case Studies 

Simplification and reduction of administrative costs 

Theme 
Question 

Simplification and reduction of administrative costs 

Judgment criteria 

Indicators 

Sources  

124 

 
 
 
 
 
 
 
 
 
 
EQ.10. Were the Fund 
management procedures 
simplified and the 
administrative burden reduced 
for its beneficiaries? 

The use of simplified cost options reflected in 
simplification of procedures and reduction of 
administrative burden for the different 
stakeholders concerned 

Operating support was used in a cost-effective 
manner and reduced administrative burden for 
the actors involved 

Special schemes were used in a cost-effective 
manner and reduced administrative burden for 
the actors involved 

Number and type of simplification measures used 
into the National Programmes (e.g. simplified cost 
options)  
Level of financial resources used 
Number and type of special schemes used  
Level of operating support used 
financial resources used  
Variance in the use of simplified cost options across 
MS 
Perception of stakeholders regarding the cost-
effectiveness of simplified options in place 
Perception of consulted stakeholders regarding the 
extent to which operating support reduced 
administrative burden 

Documentary review: 
Annual Implementation 
Reports 
National evaluations 

Country case study 
interviews 

Thematic case study 
interviews 

Survey for end-
beneficiaries 

Interviews at MS level 

Additional information for the assessment of coherence 

Coherence with Home Affairs Funds - Overview of Home Affairs Funds (2014-2020) 

Fund  

Final buget 

Objectives 

ISF-Police 
(2014-2020) 

EUR 1,215 million out of which 
for MS programmes EUR 751.6 
million 

General objective: ensuring a high level of security in the EU.  
The funding instrument has two specific objectives: 
-Fight against crime: Combating cross-border, serious and organised crime 
including  terrorism,  and  reinforcing  coordination  and  cooperation  between 
law  enforcement  authorities  and  other  national  authorities  of  EU  States, 
including  with  EUROPOL  and  other  relevant  EU  bodies,  and  with  relevant 
non-EU and international organisations. 
-Managing risk and crisis: Enhancing the capacity of EU States and the Union 
for  managing  effectively  security-related  risk  and  crisis,  and  preparing  for 
protecting people and critical infrastructure against terrorist attacks and other 
security related incidents. 

125 

funded 

acquisition 

Types  of  activities  and 
beneficiaries 
include: 
Activities 
IT 
setting  up  and  running 
of 
systems, 
operational 
equipment, 
promoting  and  developing 
training schemes and ensuring 
administrative  and  operational 
coordination and cooperation. 
include:  state 
Beneficiaries 
and  federal  authorities,  local 
non-
public 
bodies, 
organisations 
governmental 

 
 
 
 
 
 
 
 
 
 
 
in 

funded 

education 

assistance 

and  private  and  public  law 
companies. 
include: 
Activities 
improvement 
of 
accommodation  and  reception 
services  for  asylum  seekers, 
information  measures  and 
campaigns 
non-EU 
countries  on  legal  migration 
and 
channels, 
language  training  for  non-EU 
nationals, 
to 
vulnerable  persons  belonging 
to  the  target  groups  of  AMIF, 
information  exchange  and 
cooperation 
EU 
States and training for staff on 
relevant topics of AMIF. 
include:  state 
Beneficiaries 
and  federal  authorities,  local 
public 
non-
bodies, 
governmental  organisations, 
organisations, 
humanitarian 
private 
law 
public 
companies and education  and 
research organisations. 

between 

and 

AMIF 
2020) 

(2014-

EUR  7,595  million  out  of 
which for MS programmes 
EUR 4,575.5 

General objective: promote the efficient management of migration flows and 
the  implementation,  strengthening  and  development  of  a  common  Union 
approach to asylum and immigration. 

The funding instrument has four specific objectives: 
-Asylum:  strengthening  and  developing  the  Common  European  Asylum 
System by ensuring that EU legislation in this field is efficiently and uniformly 
applied; 
-Legal migration and integration: supporting legal migration to EU Member 
States  in  line  with  the  labour  market  needs  and  promoting  the  effective 
integration of non-EU nationals; 
-Return:  enhancing  fair  and  effective  return  strategies,  which  contribute  to 
combating  irregular  migration,  with  an  emphasis  on  sustainability  and 
effectiveness of the return process; 
-Solidarity: making sure that EU States which are most affected by migration 
and asylum flows can count on solidarity from other EU States. 

Source: European Commission website on ISF-Police (251) and AMIF (252) 

(251) Internal Security Fund - Police (2014-2020) - European Commission 
(252) Asylum, Migration and Integration fund (2014-2020) - European Commission 

126 

 
 
 
 
 
 
Figure 21 - Coherence between ISF-BV and AMIF (% responses) 

Source: Targeted survey responses to: “In your opinion, were the actions implemented through the ISF-BV and BMVI Instruments coherent with and non-contradictory (no duplications or overlap) 
to other EU interventions with similar or complementary objectives? - Asylum, Migration and Integration” N= as indicated in figure . 

127 

 
 
Note: While the 14 responses from national authorities only include those relevant to ISF-BV, the answers of beneficiaries and other stakeholders cover both programming periods (ISF-BV and 
BMVI funding)  

128 

 
 
  
Funding 
Instrument  + 
Managing DG 

Customs  2020 
Programme, 
DG TAXUD 

Coherence with other EU funding instruments (2014-2020) 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

Inter-service 
Consultation, 
through  which  DG 
TAXUD  comments 
on the ISF-BV Work 
Programme 
Joint  meetings (256) 
and  DG  HOME  and 
DG  TAXUD  work 
on  documents  and 
guidelines 
co-
concerning 
operation  aspects  of 
border  guards  and 
customs services.  
DG  HOME  also  sits 
on  the  Horizon 2020 
Steering group (other 
DGs 
incl.,  DG 
OLAF,  DG  BUDG, 
DG  GROW,  DG 
ECFIN, 
and  DG 
REFORM)  to  ensure 
synergies  and  avoid 
overlaps. (257) 

2014-
2020 

€522.9 
million 

The  Customs  2020 
Programme 
supported 
the 
modernisation of the 
Customs  Union,  by 
increasing 
information and data 
between 
exchange 
customs 
national 
administrations 
to 
better detect the flow 
of  dangerous  and 
counterfeit goods; by 
supporting  customs 
in 
authorities 
the 
protecting 
and 
financial 
economic 
interests 
of the Union, as well 
the  correct 
as 
in 
of 
collection 
customs 
duties, 
import  VAT  and 
excise  duties,  by 
devising  better  risk 
management 
strategies  to  protect 
the  EU's  financial 
interests;  and  help 
better 
the 
respond  to  security 
threats 
and 
transnational  crime; 
and by continuing to 
facilitate 
growing 
levels of trade. (253) 

EU 

relation 

As  noted  in  the  Interim 
evaluation  of  the  ISF-
the  ISF-BV  and 
BV, 
2020 
Customs 
Programme 
share 
common 
objectives 
related to security as well 
as similar activities (such 
as 
training).  Customs 
authorities  have  a  broad 
range of supervisory and 
control 
responsibilities 
to  goods 
in 
imported  into  the  EU. 
They  cooperate  in  the 
fight 
fraud, 
against 
terrorism,  and  organised 
crime  together  with  law 
enforcement  authorities 
responsible  for  border 
internal 
and 
security. (254) 
The  ex-post  evaluation 
the  Customs  2020 
of 
confirmed 
Programme 
that  Commission  and 
national 
customs 
officials  acknowledged 
programme 
that 
with 
aligned 
initiatives 
broader  EU 
Internal 
including 
Security 
Fund 
 (255)  However, 
(ISF). 
the  evaluation  did  not 
provide  any  concrete 
examples of cooperation 
or complementarities. 

well 

the 

the 

Horizon 2020 

2014-
2020 

€75.6 
billion 

Horizon  2020  was 
the 
financial 
instrument 

The  ISF-BV  Regulation 
foresees  for  ISF-BV  to 
fund  Union  actions  that 

Inter-Service 
Consultation, 
through  which 

the 

(253) European Commission, ‘2014-2020 Customs programme’, European Commission website, accessed 13 
November 2024, https://taxation-customs.ec.europa.eu/eu-funding-customs-and-tax/customs-2020_en. 
(254) European Commission: Directorate-General for Taxation and Customs Union, ‘Study on the final evaluation 
of the Customs 2020 programme’, 13 December 2021, p. 109. 
(255) European Commission: Directorate-General for Taxation and Customs Union, ‘Study on the final evaluation 
of the Customs 2020 programme’, 13 December 2021, p. 111. 
(256) ISF-BV Interim evaluation 
(257) ISF-BV Interim Evaluation. 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111 
Office: LX46 05/162 – Tel. direct line +32 229-62081 

Enrique.Garcia@ec.europa.eu 

 
 
 
 
 
Funding 
Instrument  + 
Managing DG 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

implementing 
the 
Innovation  Union,  a 
Europe 
2020 
initiative 
flagship 
aimed  at  securing 
Europe's 
global 
competitiveness. (258) 

ESIF  (ESF  and 
ERDF) 

2014-
2020 

ERDF: 
€185 
billion (261) 

ESF: 
€74 
billion (262) 

the 
The  ESF  and 
ERDF 
help 
can 
facing  the  migration 
pressure experienced 
by 
by 
the  EU 
- 
supporting 

long 

the  objective 

to 
have 
particularly 
“support 
innovative 
projects 
developing new methods 
and/or technologies with 
a 
for 
potential 
transferability  to  other 
States, 
Member 
especially projects which 
aim  to  test  and  validate 
research projects”. (259)  
2020 
The  Horizon 
programme  can 
fund 
research  and  innovation 
in  the  field  of  security 
and border management. 
example, 
One 
highlighted 
the 
in 
interim  report,  included 
the 
« Societal 
call 
‘Secure 
Challenge 
Societies  —  protecting 
freedom  and  security  of 
Europe and its citizens’. 
The  ex-post  evaluation 
the  Horizon  2020 
of 
programme  noted 
that 
the  programme  helped 
make  Europe  more 
secure  by 
supporting 
crime  prevention  and 
terrorism 
counter 
improving 
initiatives, 
border  surveillance  and 
improving 
disaster 
resilience,  but  did  not 
the 
specifically  cover 
ISF-
coherence  with 
BV. (260) 
In terms of beneficiaries, 
the  authorities  involved 
in  ESF  and  ERDF  are 
different 
the 
beneficiaries  of  the  ISF-
BV.  However,  the  types 
of  activities  can  be 

from 

relevant  unit  with 
DG  HOME 
that 
managed 
security 
related  R&D  funded 
under  Horizon  2020 
can  comment  on  the 
ISF-BV 
Work 
Programmes 

Inter-Service 
Consultation, 
through  which  DG 
EMPL 
and  DG 
REGIO can comment 
on the ISF-BV Work 
Programmes 

(258) European Commission, ‘What is Horizon 2020?’, European Commission website, accessed 13 November 
2024, What is Horizon 2020? | Horizon 2020. 
(259) Article 13 (2)(i) ISF-BV Regulation 
(260) European Commission, ‘Ex post evaluation of Horizon 2020, the EU framework programme for research 
and innovation’, COM(2024)49, 29 January 2024, p. 4. 
(261) Regulation (EU) No 1301/2013 on the European Regional Development Fund and on specific rules about 
the investment for growth and jobs goal, ‘Summary’, EUR-Lex website, accessed 13 November 2024, European 
Regional Development Fund (2014-2020) | EUR-Lex. 
(262) European Parliament, ‘European Social Fund Plus’, European Parliament website, accessed 13 November 
2024, European Social Fund Plus | Fact Sheets on the European Union | European Parliament. 

130 

 
 
 
 
Funding 
Instrument  + 
Managing DG 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

ESF 

term  integration  of 
migrants. 
was 
The 
main 
Europe’s 
for 
instrument 
supporting 
jobs, 
helping  people  get 
and 
jobs 
better 
ensuring  fairer  job 
opportunities  for  all 
EU citizens. (263) 
The  ERDF  aims  to 
promote 
the  EU’s 
harmonious, 
balanced 
sustainable 
development 
by 
correcting  some  of 
in 
the  differences 
of 
levels 
development 
between 
regions. (264) 

and 

its 

2014-
2020 

€19.97 
billion 

The  DCI  was  the 
main 
financial 
instrument in the EU 
budget  for  funding 
aid 
to  developing 
countries. 

Development 
Cooperation 
Instrument 
(DCI) (lead: 
DG DEVCO, 
now INTPA 
but also EEAS 
and DG EAC) 

asylum 

similar  to  those  funded 
under  ISF-BV  (although 
more  closely  linked  to 
AMIF): 
ESF:  Similar  activities 
can be funded to similar 
target 
(e.g. 
groups 
trainings  and  capacity 
public 
building 
of 
administration 
and 
public services). 
ERDF:  in  the  field  of 
migration, the Fund aims 
at  integrating  migrants 
and 
seekers 
through  investments  in 
social, health, education, 
housing  and  childcare 
infrastructure. 
In 
exceptional 
the 
circumstances, 
ERDF  might 
support 
emergency measures that 
are  consistent  with  the 
ISF-BV.  With  regard  to 
the  specific  protection 
needs of unaccompanied 
children  and 
families 
with children, the ERDF 
can  provide  support  for 
building  or  extending 
reception  centres  and 
shelters  or  reinforcing 
reception 
capacity  at 
services, 
infrastructural 
development in hotspots, 
mobile  hospitals  as  well 
as  sanitation  and  water 
supply.  (265) 
ISF-BV  funding  in,  and 
in 
third 
countries 
As  per  the  preamble  of 
Horizontal 
the 
Regulation 
(EU) 
514/2014  (recital  8)  and 
ISF-BV 
Regulation 
(recital  36),  activities 
funded  by  ISF-BV  can 
fund actions « in, and in 

relation 

to 

The 
ISF-BV 
Regulation notes that 
coherence 
“full 
sought 
should  be 
the  principles 
with 
general 
and 
the 
objectives  of 
Union’s 
external 
action  and  foreign 
policy  related  to  the 
country  or  region  in 

(263) European Commission, ‘What is the ESF?’, European Commission website, accessed 13 November 2024, 
What is the ESF?. 
(264) Regulation (EU) No 1301/2013 on the European Regional Development Fund and on specific rules about 
the investment for growth and jobs goal, ‘Summary’, EUR-Lex website, accessed 13 November 2024, European 
Regional Development Fund (2014-2020) | EUR-Lex. 
(265) ISF-BV Interim Evaluation. 

131 

 
 
 
 
 
Funding 
Instrument  + 
Managing DG 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

the 

calls 

question”.  However, 
the  Regulation  does 
not  specify  how  this 
coordination  should 
take  place  and  with 
which actors.  
The key coordination 
the 
tool  has  been 
Inter-Service 
Consultation, 
through  which  DG 
and  DG 
NEAR 
INTPA can comment 
on  the  Annual  Work 
and 
Programmes 
for 
planned 
proposals and ensure 
there  is  no  overlap 
with 
actions 
funded.v-DG  INTPA, 
DG  NEAR  and  EEAS 
were  part  of  Steering 
Group 
ISF-BV 
of 
Migration  Partnership 
Facility,  with  active 
the 
involvement 
programming 
phase 
(e.g.  being  part  of  the 
decision board involved 
the  evaluation  of 
in 
proposals) 
Interviews confirmed 
coordination  during 
the 
implementation 
of the MPF was more 
limited 
to 
participation  in  the 
conference 
MPF 
Member 
where 
States 
third 
and 
countries  present  on 
the 
implementation 
progress. v 

in 

to 

to, 

third 

identify 
and 

relation 
countries ».  
While  the  data  does  not 
the 
allow 
in 
actions  «in, 
relation 
third 
to 
countries » funded by the 
National 
ISF-BV 
Programmes (266), 
the 
following ISF-BV Union 
Actions  appear  to  be  in, 
or  in  relation  to »  third 
countries » : 
Direct management: nine 
projects  under  direct 
management (amounting 
to  a  total  of  EUR  4.5 
million 
funded  under 
ISF-BV). (267),  
Indirect  management: 
ISF-BV 
Since  2016, 
for 
launched 
calls 
under 
proposals 
the 
Partnership 
Migration 
Facility  (MPF),  the  EU 
initiative  managed  by 
ICMPD 
that  aims  at 
strengthening  dialogue 
on 
cooperation 
and 
migration  and  mobility 
EU 
issues 
Member 
and 
countries. 
partner 
Overall, 13 projects were 
funded  relating  to  the 
following 
third 
countries : 
Armenia, 
Georgia, 
Belarus, 
Moldova,  and  Pakistan 
(amounting  to  a  total  of 
EUR  4.4  million  funded 
under ISF-BV). 
Interviews  with  DG 
INTPA,  DG  NEAR  and 
EEAS confirmed that : 
interviewees 
The 
confirmed that it was not 

between 
States 

(266) The financing plan of the programme (section 7) does not include a specific budget line for funding in and 
in relation to third countries. 
(267) Out of the 18 Union Actions under direct management funded, the following nine projects related to third 
countries: Regional Cooperation on Border Management among Turkey, Greece and Bulgaria - Phase I, 
Cooperation on Border Management among Turkey, Bulgaria and Greece - Phase II, Development of Information 
Exchange Gear of Baltic states (BSIEG 2), Improvement of the Security at the EU External Borders and Enhance 
the Cooperation with Turkey for Addressing the Migratory Pressure (PRIORITY), Enhancement of Immigration 
Liaison Officers’ activities in Vietnam/ EURLO Vietnam, CONSULASSIST, Common Airport Liaison Officers 
(CALO), Ghanaian Identity-Chain Capacity Building – Analytical evaluation (GIC_A), MigraSafe – Africa. 

132 

 
 
Funding 
Instrument  + 
Managing DG 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

In 

of 

that 

possible  to  provide  an 
border 
overview 
related 
management 
under 
these 
funding 
funds, 
a 
but 
migration  marker  had 
been  put  in  place  since 
2021 (under NDICI). 
There is limited potential 
for overlap and synergies 
between  the  actions  led 
by  DG  INTPA,  as  ISF-
BV  does  not  tend  to 
cover  the  same  regions 
(e.g.  Africa). 
this 
geographical  area  there 
are  more  synergies  with 
AMIF , also thematically 
in  terms of reintegration 
and return.  
There  is  more  potential 
for overlap and synergies 
between ISF-BV funding 
in 
the 
neighbourhood/countries 
that  share  a  border  with 
the  EU,  as  those  are  the 
same  countries  covered 
by DG NEAR. However 
here 
interviews 
highlighted that overlaps 
were  limited  too  as  in 
external 
the 
general 
action instruments cover 
the  heavier  equipment 
and  more 
purchases, 
expensive 
capacity 
the 
building,  while 
Home  Affairs  Funds 
tend 
fund  more 
operational coordination. 

to 

2014-
2020 

€17.57 
billion 

European 
Neighbourhood 
Instrument 
(ENI)  (EEAS, 
DG NEAR, DG 
ECFIN, 
DG 
DEVCO,  now 
INTPA) 

The  ENI  financed 
the 
European 
neighbourhood 
policy,  which  aimed 
supporting 
at 
political,  economic 
and  social 
reform 
processes in the EU's 
neighbouring 
countries.  

133 

 
 
 
 
Funding 
Instrument  + 
Managing DG 

Instrument  for 
Pre-accession 
II 
Assistance 
(IPA  II)  (DG 
NEAR, 
DG 
DEVCO,  now 
INTPA, EEAS) 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

2014-
2020 

€12.8 
billion (268) 

legal, 

General  objective  is 
to  help  the  IPA  II 
align 
beneficiaries 
themselves  with  EU 
standards, 
rules, 
policies 
and 
practices  to  prepare 
for  EU  membership 
by 
promoting 
political, 
institutional, 
administrative, 
social  and  economic 
reforms. 
The  most  important 
novelty of IPA II was 
its  strategic 
focus 
which provided for a 
stronger  ownership 
by  the  beneficiaries 
through 
integrating 
their own reform and 
development 
II 
agendas. 
reforms 
targeted 
within 
the 
framework  of  pre-
defined 
sectors 
which  covered  areas 
closely  linked  to  the 
enlargement 
as 
strategy, 
and 
democracy 
governance,  rule  of 
law, and growth and 
competitiveness. (269) 

such 

IPA 

European 
Instrument  for 
Democracy and 
Human  Rights 
(EIDHR)  (DG 
DEVCO,  now 
INTPA,  DG 
NEAR, 
DG 
ECHO,  EEAS 
and FPI) 

Partnership 
Instrument  for 
Cooperation 
with 

Third 

2014-
2020 

€1.25 
billion 

The EIDHR aimed at 
providing 
support 
for the promotion of 
democracy 
and 
human rights in non-
EU countries.  

2014-
2020 

€961.7 m 

The PI was the EU's 
first 
instrument 
specifically designed 
to  promote  the  EU's 

(268) European Commission, ‘Overview - Instrument for Pre-accession Assistance’, European Commission 
website, accessed 13 November 2024, Overview - Instrument for Pre-accession Assistance - European 
Commission. 
(269) European Commission, ‘Overview - Instrument for Pre-accession Assistance’, European Commission 
website, accessed 13 November 2024, Overview - Instrument for Pre-accession Assistance - European 
Commission. 

134 

 
 
 
 
 
 
 
 
Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

strategic 
worldwide 
reinforcing 
external 
policies 
initiatives. (270) 

interests 
by 
its 
strategies, 
and 

2014-
2020 

 €30.5 
billion (271) 

Funding 
Instrument  + 
Managing DG 

Countries  (PI) 
(FPI, 
DG 
DEVCO,  now 
INTPA) 

11th  European 
Development 
Fund 
(EDF) 
(DG  DEVCO, 
INTPA, 
now 
BUDG, 
DG 
EEAS, 
EIB, 
Investment 
Facility 

is 

the 
financing 

The  EDF 
largest 
instrument 
contributing  to  turn 
into 
the 
action 
European  Union's 
development  policy 
and  external  action. 
Its  objective  is  to 
help  79  countries  in 
the 
Africa, 
Caribbean  and 
the 
alleviate 
Pacific 
and 
poverty 
to 
25 
the 
support 
Overseas  Countries 
and  Territories  that 
all have a special link 
EU 
some 
with 
to 
Member  States 
improve 
their 
competitiveness  and 
their 
reduce 
vulnerability. (272) 
The 
Justice 
programme  covers: 
Judicial 
(1) 
cooperation  in  civil 
and criminal matters, 
(2)  Judicial  training, 
(3)  Effective  access 
to  justice  in  Europe, 
including  rights  of 
victims of crime and 
procedural  rights  in 
criminal 
proceedings,  and  (4) 
Initiatives in the field 
of 
policy 
(judicial  cooperation 

drugs 

Limited, 
Justice 
as 
Programme has a distinct 
covers 
and 
focus 
different 
beneficiaries 
(in the area of police and 
judicial cooperation).  

Inter-Service 
Consultation, 
through  which  DG 
JUST  comments  on 
the 
ISF-BV  Work 
Programme 
EU  level  interviews 
further  noted 
the 
following 
coordination 
mechanisms: 
-DG  JUST  supports 
beneficairies 
in 
navigating 
through 
the  EU  funds,  incl 
DG Home funds. 

Justice 
programme 
(DG JUST) 

2014-
2020 

€377.6 
m (273) 

(270) European Commission, ‘Global Europe: The Neighbourhood, Development & International Cooperation 
Instrument’, European Commission website, accessed 13 November 2024, Global Europe: The Neighbourhood, 
Development & International Cooperation Instrument - European Commission. 
(271) European Commission, ‘Evaluation of the 11th European Development Fund, Commission Staff Working 
Document’, SWD(2017)601, 15 December 2017, p. 2. 
(272) European Commission, ‘Evaluation of the 11th European Development Fund, Commission Staff Working 
Document’, SWD(2017)601, 15 December 2017, p. 2. 
(273) European Parliament, ‘Justice programme (2014-2020)’, Briefing, How the EU budget is spent, European 
Parliament website, February 2017, accessed 13 November 2024, Justice Programme (2014-2020). 

135 

 
 
 
 
 
Funding 
Instrument  + 
Managing DG 

Period  Budget 

in 

Description  

EUR 

area 

Possible 
of 
overlap/synergies  with 
ISF-BV 

Mechanism 
for 
coordination/ensure 
synergies 

and crime prevention 
aspects). (274) 

-DG HOME and DG 
JUST  sometimes  sit 
in each others' expert 
groups.  

(274) European Commission, ‘Justice Programme’, European Commission website, accessed 13 November 2024, 
Justice Programme - European Commission - DG Justiceunknown label. 

136 

 
 
 
 
 
Figure  22:  Responses  to  the  survey  question:  In  your  opinion,  were  the  actions  implemented 
through the ISF-BV and BMVI Instruments coherent with and non-contradictory (no duplications 
or overlap) to other EU interventions with similar or complementary objective 

Source: Targeted survey responses to: “In your opinion, were the actions implemented through the ISF-BV and BMVI 
Instruments coherent with and non-contradictory (no duplications or overlap) to other EU interventions with similar 
or complementary objectives? N= 14 responses from national authorities only include those relevant to ISF-BVlll 

137 

 
 
 
 
 
ANNEX IV: OVERVIEW OF BENEFITS AND COSTS 

The aim of this analysis was to identify, map, and assess the costs and benefits entailed by 
the implementation of the ISF-BV Fund, considering different types of stakeholders.  

In this sense, the following steps were implemented for the purposes of cost estimation: 

1.  Step 1. Mapping of costs: At this stage, we have identified and listed the potential costs 
entailed by the implementation of the ISF-BV for different categories of stakeholders. 

2.  Step  2.  Data  collection:  We  reviewed  Instrument  monitoring  data,  data  collected 
through  targeted  surveys  and  interviews  and  desk  research  (NPs,  AIRs,  Final 
implementation reports, mid-term and ex-post national evaluations)  

3.  Step 3. Estimation of costs: The purpose of this estimation had been to monetize the 

different types of costs identified under Step 1. 

In accordance with tools #56, #57 and #58 of the Better Regulation Toolbox, the types of 
costs that have been identified and mapped are included in the table below. Based on the 
Fund monitoring data, we were able to quantify the data related to financial allocations and 
spending  under  the  national  programmes,  as  well  as  the  value  of  the  technical 
assistance. (275) However, costs related to the number of FTEs deployed by the different 
stakeholders, as well as  perceived administrative burden could  not  be quantified due to 
limited information. Therefore, the analysis we performed focuses on the financial costs.  

The identification, mapping, and assessment of benefits followed the same methodological 
steps. Considering the Instrument’s level of implementation, the benefits analysis focused 
on the common indicators, as presented below. 

(275) Source: SFC2014_-ISF_NP_(Implementation_and_Absorption_Rates)_22.12.2023. 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111 
Office: LX46 05/162 – Tel. direct line +32 229-62081 

Enrique.Garcia@ec.europa.eu 

 
 
 
 
Table 8 - Mapping of costs and benefits entailed by the implementation of the ISF-BV Fund 

Cost or benefit 

Citizens/ 
consumers 

Businesses 

Administrations 

Other (direct beneficiaries of the Fund, 
other than citizens / businesses) 

Quantitative 

Comment  Quantitative  Comment 

Quantitative 

Comment 

Quantitative 

Comment 

ISF-  BV 
funding 
which: 

out 

total 
of 

One-off 

-  ISF BV Shared 
management 
funding 
(including TA) 

One-off 

-  ISF  BV  Direct 
management 
funding 

One-off 

-  ISF- 

BV 
Envelope 
for 
setting  up  IT 
systems 
supporting  the 
management of 
migration 
flows 
the 
borders 

across 
external 

One-off 

EUR 2 760 million out of which: 

EUR 1 705 million  

EUR 264 million  (with at least 30% 
for Union Actions) 

EUR 791 million 

Direct  compliance 
costs:  

-  Adjustment 

costs 

-  Administrative 

costs 

Recurrent   

Number  of  FTEs  dedicated  to  the 
administrative activities performed to 
administrative 
comply 
obligations included in legal rules  

with 

Number  of  FTEs  dedicated  to 
the 
and 
implementation 
reporting  progress  on    project 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111 
Office: LX46 05/162 – Tel. direct line +32 229-62081 

Enrique.Garcia@ec.europa.eu 

 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Citizens/ 
consumers 

Businesses 

Administrations 

Other (direct beneficiaries of the Fund, 
other than citizens / businesses) 

Quantitative 

Comment  Quantitative  Comment 

Quantitative 

Comment 

Quantitative 

Comment 

activities 
implemented projects 

/ 

number 

of 

-  Regulatory 
charges 

Enforcement  costs, 
costs 
meaning 
associated 
with 
activities  linked  to 
the  implementation 
of an initiative such 
as: 

Reccurent   

-  Monitoring 

-  Inspections   Recurrent   

-  Adjudication/ 
litigation 

Indirect compliance 
costs (related to the 
fact 
other 
that 
stakeholders  have 
comply  with 
to 
legislation) 

Other indirect costs:  

Direct benefits  

Number  of  FTEs  dedicated 
monitoring 
projects 

to 
implementation  of 

the 

Number  of  FTEs  dedicated 
inspections/audits  

to 

Enhanced capacity by: 

- 

- 

Increased number of staff trained 
and number of training courses in 
aspects  related  to  Common  visa 
policy 
Incresead number of staff trained 
and number of training courses in 

140 

 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost or benefit 

Citizens/ 
consumers 

Businesses 

Administrations 

Quantitative 

Comment  Quantitative  Comment 

Quantitative 
related 

aspects 
management 

to 

border 

Other (direct beneficiaries of the Fund, 
other than citizens / businesses) 

Comment 

Quantitative 

Comment 

Integrated border management by:  
-  Number of  consular cooperation 
activities developed with the help 
of the Instrument 

- 

-  Number  of  specialised  posts  in 
third  countries  supported  by  the 
Instrument 
and  number  of 
Percentage 
consulates 
or 
upgraded  with  the  help  of  the 
total 
Instrument  out  of 
number of consulates 

developed 

the 

Development  of  advanced  border 
infrastructure and technology by:  
-  Number  of  border 

control 
surveillance) 
(checks 
infrastructure 
means 
developed  or  upgraded  with  the 
help of the Instrument 

and 

and 

-  Number  of  national  border 
surveillance 
infrastructure 
established/further  developed  in 
the framework of EUROSUR 
Increased  number  of  border 
crossings of the external borders 
through  ABC  gates  supported 
from the Instrument 

- 

141 

 
   
Cost or benefit 

Citizens/ 
consumers 

Businesses 

Administrations 

Other (direct beneficiaries of the Fund, 
other than citizens / businesses) 

Quantitative 

Comment  Quantitative  Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Indirect benefits  

A high level of security 
within the Union, while 
safeguarding  the  free 
movement  of  persons 
within it 

for 

the 

Support 
harmonized 
implementation  of  the  Union  acquis 
and  stronger  and  more  effective 
European 
border 
management  at  the  Union’s  external 
borders 

integrated 

Increased  and  more  effective 
cross-country  cooperation 
in 
the  field  of  security,  border 
management and visa 

142 

 
   
 
 
 
 
 
   
   
The baseline, target, and achieved values of the common indicators were retrieved based 
on the Instrument monitoring data, covering the implementation period up to 31 December 
2022. (276) 

To address the evaluation question regarding the extent to which the expected results of 
the  Instrument  were  achieved  at  a  reasonable  cost—assessing  the  financial  and  human 
resources deployed—we require information on both the financial resources spent and the 
performance indicators reflecting outcomes. Currently, there is no available information 
on human resources; therefore, the only input we can consider is the expenditure amounts 
noted at the national level. Within the report, the expenditures have been quantified as the 
total amount spent by each country, cumulative 2022 values. 

In  terms  of  outcomes  for  SO1-support  a  common  visa  policy,  the  following  output 
indicators were used in the analysis: number of consular cooperation activities developed 
with the help of the Instrument (C1), number of staff trained in common visa policy related 
aspects with the help of the Fund (C2.1), number of specialised posts in third countries 
supported by the Instrument C3), percentage of consulates developed or upgrade with the 
help of the Instrument (C4.2) 

In  terms  of  outcomes  for  SO2-borders,  the  following  output  indicators  were  used: 
number  of  training  courses  in  borders  management  related  aspects  with  the  help  of  the 
Fund (C1.2), Number of border control (checks and surveillance) infrastructure and means 
developed or upgraded  with the help of the Fund (C2), number of border crossings of the 
external  borders  through  ABC  gates  supported  from  the  Fund  (C3.1),  total  number  of 
border  crossings  (C3.2),  number  of  national  border  surveillance 
infrastructure 
established/further developed in the framework of EUROSUR (C4), number of incidents 
reported by the Member State to the European Situational Picture (C5).  

To provide a response to our evaluation question, three approaches have been tested, as 
presented in the text box below. 

Text box 1. Tested approaches for conducting the cost-effectiveness analysis 

Dimensionality  reduction  on  output  indicators  to  synthesize  and  visualize  the  information 
contained in multiple output variables: 

4.  This approach is often used when the data set contains numerous variables, which can 
make  the  analysis  complex  and  obscure  meaningful  patterns.  By  reducing  the 
dimensions,  the  technique  condenses  the  data  into  a  smaller  set  of  representative 
variables, making it easier to interpret and visualize. The primary advantages include 
simplifying  the  data  structure,  enhancing  interpretability,  which  facilitates  more 
effective analysis and clearer insights without significant information loss. By reducing 
the dimensionality of the data, the analysis provides a clearer, synthesized view of output 
indicators, aiding decision-makers in assessing effectiveness of resource allocation and 
evaluating performance. 

5.  A limitation of applying dimensionality reduction on the output indicators was due to 
the sparsity of certain variables (e.g., the outcome indicator C1, "Number of consular 
cooperation activities developed with the help of the Fund") and the heterogeneity of 
others. This sparsity coupled with the presence of numerous NA values and a limited 

(276) Source: SFC2014_ISF_AIR_Indicators_report_23.02.2024. 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111 
Office: LX46 05/162 – Tel. direct line +32 229-62081 

Enrique.Garcia@ec.europa.eu 

 
 
 
 
sample size, restricts the effectiveness of multivariate analysis techniques, potentially 
reducing the robustness of the results. The primary challenge with the target variable, 
set  individually  by  each  country  for  each  output  indicator,  was  the  presence  of 
inconsistent values. These inconsistencies appeared as significant underestimations or 
overestimations, affecting the accuracy and relevance of the results. A limitation of the 
analysis  is  that  certain  countries  had  predefined  targets  for  specific  indicators,  while 
others did not set any targets (target 0), leading to inconsistencies and numerous NA 
values. This discrepancy hinders a comprehensive comparative analysis, as the absence 
of  uniform  target-setting  across  countries  introduces  variability  that  may  skew  the 
synthesized results. 

Cluster  analysis  to  group  countries  into  homogeneous  clusters  based  on  their  output 
indicators: 

6.  The  aim  was  to  identify  patterns  that  explain  differences  in  outcomes  and  assessing 

efficiency.  

7.  However,  due  to  extreme  heterogeneity  across  output  indicators  among  countries, 
drawing robust conclusions on performance is challenging, limiting the analysis's ability 
to provide clear insights into efficiency.  

Cluster analysis to identify distinct profiles based on the distribution of EU contributions 
across national priorities or specific action categories for each country: 

8.  These  profiles,  or  clusters,  group  countries  with  similar  focus  patterns  on  specific 
priorities.  Clustering  proved  ineffective  because,  from  the  perspective  of  output 
indicators, all countries—regardless of cluster—produced similar common indicators, 
varying only in magnitude. 

By  applying  this  variety  of  analytical  approaches,  it  was  found  that  none  adequately 
addressed the evaluation question. Each method encountered limitations that hindered their 
effectiveness  in  providing  a  robust  response.  All  approaches  suffered  from  variable 
rareness,  heterogeneity,  and  inconsistencies  in  target-setting,  leading  to  skewed  results.  
Thus,  we  proposed  a  different  approach  that  addresses  the  limitations  of  previous 
methods by ensuring that missing values (due to the absence of setting a non-zero target 
value for output indicators) do not result in the elimination of observations, and that the 
lack of set targets for certain output indicators does not penalize countries in performance 
assessment.  

The  analysis  comprises  the  achievement  percentage  of  the  above-mentioned  output 
indicators at the level of 2022 (cumulative values). For each indicator, the achieved value 
is  compared  to  the  initial  target  value  to  calculate  the  achievement  percentage:  OI 
Achievement Percentage = (Achieved Value indicator / Target Value) × 100 (1).  

With this analysis, we aim to measure the extent to which each country has achieved its 
goals for specific output indicators by the end of 2022. By calculating the achievement 
percentage for each indicator, we assess the degree of success relative to the targets initially 
set  by  each  country.  For  countries  with  no  target  value  for  an  OI  (target  =  0),  the 
achievement percentage of 0% was replaced with "NA" (Not Applicable). This clarifies 
that the country did  not  aim to  meet  that  objective, without affecting  averages or other 
percentage-based statistics.  Thus, achievements  were reported only  for countries with  a 
target  value  for  the  respective  indicator,  excluding  cases  marked  as  "NA".  This  metric 
provides insight into effectiveness by showing how close each country came to reaching 
its goals, enabling comparisons across indicators and countries.  

144 

 
Furthermore,  a  general  performance  score  was  calculated  as  an  average  score  of  OI 
achievement percentage at the level of each country and then this score has been scaled to 
lie between 0 and 100, where 100 is the country with the highest performance. 

7. 
Besides  the  overall  performance  score  of  each  country,  we  have  used  also  the 
absorption rate which provides a measure of the capacity to utilize available funds. A 
high  absorption  rate  suggests  that  funds  were  correspondingly  used,  without  leaving 
unused  resources.  A  low  absorption  rate  may  indicate  implementation  issues,  reduced 
project management capacity, delays, or administrative obstacles.  

Analysing the absorption rate in relation to the overall performance provides insights on 
the  discrepancies  between  countries.  If  the  absorption  rate  is  high  but  the  overall 
performance score is low, it suggests that funds were spent effectively (since the resources 
were  used)  but  not  efficiently  (as  the  desired  outcomes  were  not  fully  achieved). 
Conversely,  if  the  absorption  rate  is  low  but  performance  is  high,  this  indicates  high 
efficiency in resource utilization, as strong results were achieved with fewer resources.  

The following two graphics presented the distribution of countries in four quadrants with 
the following description: 

9.  Top-Right Quadrant (High Absorption Rate, High Performance Score): countries 
in this quadrant exhibit both high absorption rates and high-performance scores. 

10. Top-Left Quadrant (Low Absorption Rate, High Performance Score): countries 

with lower absorption rates but high-performance scores. 

11. Bottom-Right  Quadrant  (High  Absorption  Rate,  Low  Performance  Score): 

countries with high absorption rates but lower performance scores.  

12. Bottom-Left  Quadrant  (Low  Absorption  Rate,  Low  Performance  Score): 
countries in this quadrant have both low absorption rates and low performance scores. 

145 

 
Figure 23 - Country Performance and absorption rate with expenditures for SO1 

Figure 24 - Country Performance and absorption rate with expenditures for SO2 

Analysing the discrepancies between countries in terms of overall performance, absorption 
rate and allocation of resources(expenditures), several profiles can be highlighted: 

146 

 
 
 
13. High Performers with High Absorption Rates and Expenditures:  Countries with 
high performance scores also exhibiting high absorption rates (top-right quadrant) and 
larger expenditure amounts indicate that substantial funds were effectively managed, 
achieving the expected results. 

14. Efficient Performers with Moderate Resources: show strong performance scores 
and  high  absorption  rates  (top-left  quadrant)  with  moderate  expenditure  sizes, 
indicating  effective  use  of  available  funds.  This  suggests  that  even  with  relatively 
smaller  financial  deployments,  these  countries  achieved  significant  outcomes, 
showcasing cost efficiency. 

15. Balanced  but  Moderate  Performers:  Countries  that  have  mid-range  performance 
scores and absorption rates, along with moderate expenditures. These countries appear 
to  have  achieved  reasonable  results  given  their  financial  inputs,  indicating  a 
satisfactory balance between outcomes and costs. 

16. Underperformers with High Absorption Rates: countries with high absorption rates 
but relatively low performance scores (Bottom-Right Quadrant) implying that while 
funds  were  fully  utilized,  the  effectiveness  of  those  funds  in  achieving  high 
performance was limited.  

17. Low  Performers  with  Low  Absorption  and  Small  Expenditures:  Countries  that 
exhibit low performance scores and low absorption rates (Bottom-Left Quadrant) with 
smaller expenditures. Their limited results could be attributed to both low financial 
input  and  possible  inefficiencies,  indicating  a  need  for  targeted  interventions  to 
improve both fund utilization and outcome achievement. 

Furthermore,  an  efficiency  score  has  been  computed  by  incorporating  all  three 
variables—performance  score,  total  expenditures  and  absorption  rate.  The  challenge  is 
balancing  high  performance  and  absorption  with  the  level  of  spending,  as  high 
expenditures  may  suggest  efficiency  issues  despite  strong  outcomes.  To  compute  this 
measure, the following steps were undertaken:  

1. Normalize Each Variable: Standardize the expenditures variable to make it comparable 
with the others. 

2. Define Efficiency in Terms of Performance vs Expenditures: 

𝑬𝒇𝒇𝒊𝒄𝒊𝒆𝒏𝒄𝒚 𝑺𝒄𝒐𝒓𝒆 =

𝑷𝒆𝒓𝒇𝒐𝒓𝒎𝒂𝒏𝒄𝒆 𝑺𝒄𝒐𝒓𝒆 × 𝑨𝒃𝒔𝒐𝒓𝒑𝒕𝒊𝒐𝒏 𝑹𝒂𝒕𝒆
𝑬𝒙𝒑𝒆𝒏𝒅𝒊𝒕𝒖𝒓𝒆𝒔

This  formula  rewards  high  performance  and  high  absorption  rates  but  penalizes  high 
spending, balancing all three aspects. 

3. Furthermore, this efficiency score has been scaled to lie between 0 and 100, where 
100 is the country with the highest efficiency. In order to identify the top performers, we 
have used the threshold of 75. A threshold of 75 represents the upper quartile of a 100-
point scale, which is commonly used as a benchmark to separate high performers from the 
rest.  This  threshold  is  frequently  used  in  efficiency  analysis  to  signify  excellence,  as  it 
captures the top 25% of all scores. 

147 

 
 
Figure 25 - Efficiency scores for SO1 

Figure 26 - Efficiency scores for SO2 

148 

 
 
 
The chart presents a ranking of countries based on their efficiency scores, calculated from 
the interplay between performance and absorption rate relative to expenditures.  

From  a  policy  perspective,  this  ranking  highlights  the  degree  to  which  countries  have 
achieved the expected results of the Instrument efficiently, optimising both performance 
and resource utilization. 

Top  performers  demonstrate  high  efficiency,  achieving  substantial  outcomes  at  a 
relatively  low  cost.  Mid-tier  performers  show  moderate  efficiency,  implying  they 
achieved  their  goals  with  reasonable  resource  usage.  These  countries  achieved  a 
satisfactory level of results but could explore strategies from top performers to enhance 
their efficiency. Low performers reflect lower efficiency scores, suggesting a potential 
mismatch between financial input and output. In these cases, funds were less effectively 
absorbed or translated into high performance. 

In conclusion the extent to which the expected results of the Instrument were achieved at 
a reasonable cost varies significantly by country. While top performers illustrate successful 
and  efficient  use  of  resources,  the  variation  across  countries  signals  an  opportunity  for 
tailored policy measures to support lower-performing regions.  

To gain more insight into the success of different groups of countries above, we analysed 
the  list  of  implemented  projects  based  on  the  keywords  the  Member  States  used  to 
describe  the  projects. (277)  The  aim  was  to  assess  the  investment  priorities  within  the 
different groups of countries above, by considering the level of EU contribution.  

The following insights must be treated with caution, as a high share of the projects in the 
database had no keyword associated, while for the others the keyword associations have 
not  always  been  used  consistently  across  the  Member  States.  To  address  the  issue  of 
missing keyword associations, we removed from the analysis the share of projects with no 
keywords  associated.  For  the  remaining  projects  (covering  86%  of  the  total  EU 
contribution),  we  reviewed  the  project  titles  and  descriptions  to  ensure  an  accurate 
categorisation.  

Additionally,  we  focused  on  allocations  as  a  proxy  for  financial  input  due  to  the 
unavailability  of  detailed  expenditure  data  at  the  project  level.  While  this  approach 
provides an indication of financial commitment, it does not fully reflect actual spending 
and its efficiency. To enhance the robustness of future analyses, we recommend improving 
data collection to ensure more comprehensive and consistent reporting of both allocations 
and expenditures. 

As shown in the table below,  top performers under SO1 focused more on projects to 
support  the  visa  application  process,  such  as  development  of  information  systems  for 
coordination visa applications, equipment/software for the extraction of information and 
consular  cooperation.  Both  categories  of  countries  concentrated  their  efforts  for  the 
operations  related  to  Visa  information  system  (VIS).  Less  performing  countries 
concentrated their efforts also on consulate construction / renovation / equipment and IT 
systems/interoperability of information systems.  

(277) Based on the dataset provided by the EC Execution of Accounts Generic Board Cumulative, extracted at 
15.03.2024.  

149 

 
 
Table 9 - Investment priorities within top, mid-tier, and low performers, based on the efficiency score ranking (SO1) 

Associated keywords 

%  of  EU  contribution  out  of  the  total  EU 
contribution to SO1 

Top 
performers (a) 

Mid-tier  and 
performers  
(b) 

low 

Differences 
(a) - (b) 

Visa information system (VIS) 

Training in the common visa policy  

Support for visa application processing 

Schengen Information System (SIS) - general 

IT systems/interoperability of information systems 

Information exchange 

Immigration liaison officers (ILO)  

Equipment/software 
information 

for 

the 

extraction 

of 

Entry - Exit System (EES) 

Document security/document advisors 

Consulate construction / renovation / equipment  

Consular cooperation 

Consular coverage 

Construction 
equipment BCPs 

/  Renovation 

Training for consular officials  

UNKNOWN 

/  Acquisition  of 

20% 

3% 

34% 

9% 

6% 

1% 

0% 

11% 

0% 

3% 

0% 

9% 

1% 

1% 

1 

0% 

40% 

3% 

4% 

12% 

11% 

0% 

0% 

4% 

1% 

3% 

12% 

4% 

2% 

1% 

0 

1% 

-20% 

0% 

30% 

-3% 

-5% 

0% 

0% 

7% 

-1% 

0% 

-12% 

5% 

-1% 

0% 

1 

-1% 

Source: Execution_of_Accounts_Generic_Board_Cummulative_15.03.2024 

As  shown  in  the  table  below,  top  performers  under  SO2  focused  rather  on  maritime 
border surveillance and activities associated with EES (Reg 2017/2226). The development 
of  Integrated  Border  Management,  activities  associated  with  ETIAS  Regulation 
2018/1240,  and  initiatives  aimed  at  enhancing  the  capabilities  of  immigration  liaison 
officers are also operations of interest for top performers. In contrast, the less performing 
groups  focused  more  resources  on  Frontex  equipment  and  land  border  surveillance, 
followed closely by maritime border surveillance. They also focused on operations related 
to Entry - Exit System and investments for border checks. 

Table 10 - Investment priorities within top, mid-tier, and low performers, based on the efficiency score ranking (SO2) 

Associated keywords 

%  of  EU  contribution  out  of  the  total  EU 
contribution to SO2 

Top 
performers 
(a) 

Mid-tier and 
low 
performers  
(b) 

Differences 
(a) - (b) 

Trainings (e.g. for Employees of Border Police to Ensure 
and  Uniformly  Apply  EU  Law/  SIS/  VIS,  for  personnel 
Deployed in Third Countries for Border Control) 

Support 
EUROSUR 

to  National  Coordination  Centre  (NCC)  - 

SIS Regulation (EU) 2018/1861 

Schengen Information System (SIS) - general 

Schengen Information System – Automated Number Plate 
Recognition (ANPR) 

Schengen Information System - Automatic Fingerprinting 
Identification System (AFIS) 

Maritime border surveillance 

0% 

2% 

2% 

2% 

0% 

0% 

29% 

150 

1% 

3% 

1% 

3%` 

0% 

0% 

12% 

-1% 

-1% 

1% 

-1% 

0% 

0% 

17% 

 
Associated keywords 

%  of  EU  contribution  out  of  the  total  EU 
contribution to SO2 

Top 
performers 
(a) 

Mid-tier and 
low 
performers  
(b) 

Differences 
(a) - (b) 

Land border surveillance 

IT systems/interoperability of information systems 

Information exchange 

Implementation 
recommendations 

of 

Schengen 

evaluation 

Immigration liaison officers (ILO) 

ETIAS Regulation 2018/1240 

Equipment/software for the extraction of information 

EES (Reg 2017/2226) 

EBCGA (FRONTEX) equipment 

Consulate construction / renovation / equipment 

Document security/document advisors 

Development of Integrated Border management (IBM) 

Construction / Renovation / Equipment BCPs 
Border  checks  (identification,  registration,  fingerprinting, 
screening, debriefing, etc.) 
Automated Border Control (ABC) Gates 
Air border surveillance 
Victims of trafficking in Human beings 
Unmanned aerial vehicles (UAVs) 
Hotspot approach 
Further development of SIS/ SIRENE management 
Risk  analysis  /  support  to  Common  Integrated  Risk 
Analysis Model (CIRAM) 

External dimension 

Unknown 

5% 

4% 

0% 

0% 

6% 

7% 

0% 

18% 

5% 

0% 

1% 

7% 

1% 

3% 

2% 
1% 
0% 
0% 
0% 
0% 

0% 

0% 

3% 

14% 

3% 

1% 

0% 

0% 

3% 

1% 

11% 

19% 

0% 

1% 

2% 

4% 

6% 

2% 
6% 
0% 
1% 
2% 
1% 

0% 

0% 

3% 

-9% 

1% 

-1% 

0% 

6% 

4% 

-1% 

7% 

-14% 

0% 

0% 

5% 

-3% 

-3% 

0% 
-5% 
0% 
0% 
-2% 
-1% 

0% 

0% 

0% 

Source: Execution_of_Accounts_Generic_Board_Cummulative_15.03.2024 

Considering all the limitations of this analysis, these results should not be used to identify 
which types of projects are more cost-effective. Instead, they should underline in which 
areas of intervention Member States (MS) have more difficulties in implementing cost-
effective  projects.  The  existence  of  certain  interventions  that  do  not  present  an  optimal 
cost-effectiveness ratio does not suggest that these interventions were unnecessary; rather, 
the implementation may have been influenced by the unique circumstances faced by each 
Member State or could reflect capacity constraints.  

8. 
Our recommendation is, therefore, to support those Member States which seem to 
exhibit lower performance and efficiency in implementing project management practices, 
cost control, and risk assessment approaches systematically. This will ensure the optimal 
implementation of their EU-funded investments. 

151 

 
 
 
ANNEX V: STAKEHOLDER CONSULTATION – SYNOPSIS REPORT 

1  CONSULTATION STRATEGY 

Consultations included a call for evidence, an online survey, EU level interviews, a focus 
group, an open public consultation and case studies (country and thematic). The objective 
of  the  consultations  was  to  collect  relevant  information  and  insights  on  the  relevance, 
effectiveness, efficiency, coherence and complementarity, EU added value, sustainability 
and simplification of the ISF-BV as well as to collect inputs on lessons learned. To do so, 
a wide range of EU, international and national level stakeholders were consulted. 

1.1  Call for evidence 

Prior to the start of the ex post evaluation, in line with the Better Regulation Provisions, a 
call  for  evidence  was  launched  in  the  Have  Your  Say  platform.  3  contributions  were 
received (278): 
-  The  Spanish  Non-governmental  Organisation  RED  COGE  highlighted  possible 
irregularities  commited  by  the  Spanish  Authorities  in  the  application  of  the  EU 
legislation within the framework of the EU funds.  

-  A  non-EU  citizen  from  Ukraine  stated  that  the  weak  European  migration  system 

created favourable conditions for the infiltration of spies and terrorists.  

-  An anonymous individual from Slovakia stated that the situation at the EU borders has 

been difficult and more uncontrolled as of 2020. 

Table 11: Overview of the stakeholders reached through each consultation tool / method 

EU level 
Interviews 

Online 
surveys 

Focus Group 

Open public 
consultation 

Validation 
Workshop 
(Focus Group 3) 

Country 
case studies 

Thematic 
case studies 

x 

x 

x 

European 
Commission staff 

Migration and 
Home Affairs (and 
other relevant) 
Agencies 

National 
Authorities 

Participant / (end) 
beneficiaries 

Other SHs (EU 
bodies, IOs, NGOs, 
etc.) 

Expert groups, 
network, research 
centres and 
academics 

Wider public 
(including non-EU) 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

1.2  Online survey 

An online survey was launched to (i) collect information on the relevance, effectiveness, 
efficiency,  coherence  and  complementarity,  EU  added  value,  sustainability  and 
simplification of the ISF-BV, (ii) understand the problems/gaps affecting the functioning 

(278)  Internal Security Fund – Borders and Visa (ISF BV) for 2014-2020 – ex post evaluation 

152 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and  effects  of  the  ISF-BV,  as  well  as  (iii)  gather  suggestions  for  future-looking 
recommendations. Three different survey questionnaires were used, targeted respectively 
at National Authorities (34 total respondents), other stakeholders involved (28 total 
respondents) and beneficiaries (35 total  respondents). The survey ran from  June 17, 
2024, to September 16, 2024, and it has been administered and centrally managed by the 
evaluation team by using the Qualtrics tool. 

1.3  EU level interviews  

Between  July  and  November  2024,  the  Study  team  carried  out  21  in-depth  EU  level 
interviews  aimed  to  gather  relevant  information  and  insights  on  the  relevance, 
effectiveness, efficiency, coherence and complementarity, EU added value, sustainability 
and  simplification  of  the  ISF-BV.  The  response  rate  amounted  60%  as  21  out  35 
individuals  contacted  agreed  to  participate  in  an  interview.  Among  the  14  negative 
responses,  the  vast  majority  involved  individuals  redirecting  the  Study  team  to  a  more 
appropriate contact. Specifically, 2 requests went unanswered, 11 individuals referred the 
Study team to another interviewee, and 1 individual declined.  

Table 12: EU-Level interviews conducted 

European Commission staff 

DG HOME’s relevant Directorates 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Directorate A: International & Horizontal Affairs / Policy Coordination & Interinstitutional Relations (A1) 

Directorate B: Schengen, Borders & Visas / Schengen & External Borders (B1) 

Directorate B: Schengen, Borders & Visas / Schengen Governance (B2) 

Directorate B: Schengen, Borders & Visas / Visa Policy (B4) 

Directorate E: HOME Affairs Funds / Funds Coordination (E1) 

Directorate E: HOME Affairs Funds / Union Actions and Procurement (E4) 

Directorate E: HOME Affairs Funds / Budget & Reporting (E5) 

Directorate F: Innovation & Audit / Audit & Compliance (F1) 

Directorate F: Innovation & Audit / Innovation & Security Research (F2) 

10  DG TAXUD / Directorate A: Customs / Customs Policy (A1) 

11  DG NEAR / Migration (DGA2.01) 

Others relevant DGs 

12  DG NEAR / Rule of Law - Western Balkans Policy & Regional Strategy (D1) 

13  DG JUST / Coordinator of the Justice programme 

14  DG INTPA / Person in charge of NDICI-Global Europe Instrument 

15  DG EMPL / ESF+ Coordination Unit in charge of migration theme 

Migration and Home Affairs (and other relevant) Agencies 

16 

European Border and Coast Guard Agency (Frontex) 

EU Body 

17 

European External Action Service (EEAS) 

International Organisations 

18 

International Centre for Migration Policy Development (ICMPD) / Migration Partnership Facility (MPF) 

19  UNHCR Brussels 

20  UNHCR Liaison Office to Frontex 

21 

IOM Greece 

1.4  Focus Group 

153 

 
 
 
The focus group was held in person on June 25, 2024, in Brussels, as part of the Home 
Affairs Funds Conference. Moderated by the Study Team, this focus group aimed to gather 
direct  input  from  both  ISF-BV  and  BMVI  National  Authorities,  audit  authorities,  and 
beneficiaries, regarding the current and emerging needs in the area of border management 
and visa policy in their Member State. The discussions focused on mapping current and 
future needs, evaluating how well these needs have been met, and identifying any gaps in 
the  existing  instruments.  Twenty-one  participants  attended  the  focus  group  meeting, 
covering: 

•  managing authorities and beneficiaries from the following countries: AT, BE, 

DK, FI, FR, HU, HR, IS, LU, NL, SE, as well as CH, NO and LI.  
two EU agencies: Frontex and EUDA (279) 

• 
•  One NGO: ECRE.  

1.5  Open public consultation 

I. 

OBJECTIVE OF THE PUBLIC CONSULTATION 

The aim of the public consultation was to collect information, expertise and views from 
interested parties to arrive at an evidence-based and measured judgment of the progress 
made,  with  European  Union  (EU)  funding  support  to  the  Member  States (280)  and  the 
Schengen Associated Countries (SAC) (281), in the following two areas: a common visa 
policy and the European integrated border and EU external border management. 

The  public  consultation  was  part  of  the  study  supporting  the  ex-post  evaluation  for  the 
2014-2020 period of the Instrument for Financial Support for External Borders and Visa 
(ISF-BV). While the consultation primarily focused on the ex-post evaluation of ISF-BV, 
given  the  continuity  in  objectives  and  interventions,  elements  related  to  the  2021-2027 
Instrument for Financial Support for Border Management and Visa Policy (BMVI) might 
also be considered. 

II. 

APPROACH TO THE PUBLIC CONSULTATION 

This consultation provided a platform for stakeholders and the citizens to contribute their 
insights on the ISF-BV instrument aimed at supporting EU Member States and Schengen 
Associated  Countries  in  addressing  the  multifaceted  challenges  related  to  EU  border 
management and visa policy in the context of its funding. 

A questionnaire was developed and made publicly available for a period of 12 weeks. It 
aimed to gather views from a broad range of stakeholder groups. The following categories 
available  to  choose  from  included:  professionals  in  border  management,  including  in 
border  checks  and  surveillance  of  EU  external  borders,  common  visa  policy,  internal 
security,  and  representatives  of  academic/research  institutions,  business  associations, 
company/businesses  (e.g.,  air/  rail/sea  carriers,  tour  operators,  travel  agencies,  etc.), 
consumer  organisations,  environmental  organisations,  non-governmental  organisations 
(NGO), national authorities responsible for border management (this could include even 
various national authorities in the EU Member States and/or Schengen Associated Country 
depending on their national setting of roles/tasks and associated authorities) and of other 
public authorities. 

(279) Formerly EMCDDA  
(280) All EU Member States, except Ireland 
(281) Iceland, Norway, Switzerland and Lichtenstein 

154 

 
 
The questionnaire was designed to direct respondents to tailored sub-questions based on 
their  level  of  involvement  or  experience  with  ISF-BV  and  BMVI.  On  the  one  hand,  a 
questionnaire was tailored for respondents: 

-  Who  represented  a  public  body  involved  in  the  management,  coordination,  or 

supervision of the ISF-BV or the BMVI in their country. 

-  Who  represented  a  public  or  private  body,  an  entity  with  or  without  legal 
personality,  or  a  natural  person,  responsible  for  initiating  and/or  implementing 
operations funded by ISF-BV or BMVI. 

-  Who were or represented a legal or natural person receiving support from any of 

the two instruments (ISF-BV, BMVI) through a funded project.  

-  Who are knowledgeable about ISF-BV or BMVI in their personal or professional 

capacity. 

On the other hand, a shorter questionnaire was tailored for respondents that applied for a 
Schengen visa or for asylum in the EU and for those who did not belong to none of the 
categories.  

The  questionnaire  was  available  in  all  official  EU  languages  on  “Have  your  Say”.  The 
consultation period started on 29 August 2024 and ended on 21 November 2024, lasting 
12 weeks.  

1.6  Validation Workshop (Focus Group 3) 

A validation workshop was held on March 28, 2025, with 10 representatives from a sample 
of  national  authorities,  relevant  EC  stakeholders  as  well  as  from  International 
Organisations (ICMPD), to present the evaluation findings and related conclusions, and to 
discuss  the  feasibility  of  the  preliminary  recommendations  under  assessment.  The 
workshop  consisted  of  a  plenary  session,  where  the  evaluation  team  presented  the 
objectives of the study and the key evaluation findings, followed by a Q&A section with 
participants. 

1.7  Country and thematic case studies 

Eight  country  case  studies  were  conducted  in  Croatia,  the  Czech  Republic,  Norway, 
Poland,  Spain,  Greece,  Italy,  and  Romania.  These  countries  were  selected  to  provide 
meaningful  and  representative  coverage  of  ISF-BV  interventions  across  participating 
countries. Through these country case studies, a total of 74 stakeholders were consulted, 
including  EU  stakeholders,  responsible  authorities,  delegated  authorities,  monitoring 
committees and beneficiaries. 

Table 13: Number and type of stakeholders interviewed per country case study 

Stakeholders 

Croatia 

Czech 
Republic 

Greece 

Italy  Norway  Poland  Romania  Spain 

Total (per 
stakeholder) 

Commission 

Responsible 
Authority 

Delegated 
Authority 

Monitoring 
Committees 

Beneficiaries 

Total 

1 

5 

6 

1 

4 

2 

2 

9 

1 

1 

1 

1 

10 

14 

2 

2 

5 

9 

1 

1 

3 

5 

1 

1 

14 

16 

3 

13 

4 

5 

49 

74 

1 

2 

2 

6 

10 

4 

5 

155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Additionally,  four  thematic  case  studies  were  conducted  on  Emergency  Assistance, 
Specific Actions, Union Actions, the Russian war of aggression against Ukraine. (282) 34 
stakeholders were interviewed as part of the first four case studies.  

Table 14: Number and type of stakeholders consulted per thematic case study 

Stakeholders 

Commission 

Responsible 
Authority 

Monitoring 
Committees 

Beneficiaries 

Total 

Emergency 
Assistance 

Specific 
Actions 

Union 
Actions 

Russian war of 
aggression 

Total (per 
stakeholder) 

2 

3 

1 

4 (283) 

10 

2 

1 

9 

12 

5 

5 

5 

2 

7 

4 

9 

1 

20 

34 

2  RESULTS OF THE CONSULTATION ACTIVITIES 

2.1  Online Surveys 

Relevance 

The  ISF-BV  instrument  was  widely  recognised  for  its  relevance  and  adaptability  by 
national authorities, stakeholders, and beneficiaries. Most national authorities (10 out of 
13) reported conducting needs assessments before drafting their national programmes, and 
8 did so during implementation. Specific objectives of the programme were highly rated, 
with  most  respondents  from  national  authorities  considering  that  both  ISF-BV  specific 
objectives were relevant to a “very large” or “large” extent (69% for Specific Objective 1 
(11 out of 16 respondents) and 76% for Specific Objective 2 (12 out of 16 respondents). 
Stakeholders considered that both specific objectives were relevant to a “very large” or 
“large”  extent  (50%  for  Specific  Objective  1  (19  out  of  38  respondents)  and  47%  for 
Specific Objective 2 (18 out of 38 respondents). Most beneficiaries considered that both 
specific  objectives  were  relevant  to  a  “very  large”  or  “large”  extent  (60%  for  Specific 
Objective 1 (33 out of 55 respondents) and 61% for  Specific Objective 2 (34 out of 55 
respondents). IT and communication systems emerged as the most critical funded activity, 
followed  by  operating  equipment,  whereas  awareness-raising  (studies,  seminars, 
workshops and conferences), projects in third countries aimed at improving surveillance 
systems  to  ensure  cooperation  with  Eurosur,  ,  and  actions  relating  to  operational 
cooperation between Member States and third countries were rated as less relevant. Despite 
its relevance, 44% of national authorities identified unmet needs.  

There was a mixed feedback about the flexibility of the ISF-BV with over two third of 
beneficiaries  across both  categories  considering  ISF-BV to  be flexible to  at  lease some 
extent with a large share of respondents considering the Instrument to be flexible to a “very 
large”  or  “large”  extent.  However,  only  31%  of  national  authorities  and  28%  of  other 
stakeholders (11 out of 40) considered that the fund was flexible to a very large or large 
extent, while 18% (7 out of 40) of other stakeholders considered that fund was not flexible 
or were flexible to a limited extent. 

Effectiveness 

(282) The fifth thematic case study on horizontal priorities were conducted just in relation to BMVI. 
(283) Several of the project coordinators/beneficiaries were responsible for multiple projects. 

156 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interventions funded through ISF-BV’s National Programmes have generally contributed 
positively to operational objectives related to visa and border management across various 
stakeholders. National authorities largely acknowledged the support’s effectiveness, with 
62% of respondents confirming its positive impact, especially in areas such as IT systems, 
border surveillance, and cooperation on immigration management. However, uncertainty 
was present in some cases, with a portion of respondents unsure about the extent of the 
support.  Other  competent  authorities  also  reported  favorable  outcomes,  with  83% 
recognising the interventions’ effectiveness in managing visa and border responsibilities. 
Other  stakeholders  shared  a  similar  view,  with  79%  acknowledging  significant 
contributions to border security, visa policy development, and inter-agency collaboration. 
Beneficiaries,  while  generally  positive,  had  a  higher  proportion  of  uncertain  responses, 
reflecting the complexity or indirect nature of the interventions. 

Efficiency 

The  efficiency  of  ISF-BV  operations  reveals  a  mixed  but  generally  positive  perception 
among stakeholders. National authorities reported the highest cost-efficiency for National 
Programmes, with 79% considering the effects achieved at a reasonable cost. However, 
components like Specific Actions, Union Actions, and EMAS faced greater uncertainty, 
with a large portion of respondents unsure about their cost-effectiveness. Regarding the 
efficient  management  of  the  ISF-BV’s  National  Programmes,  IT  and  communications 
systems  were  deemed  the  most  appropriate  by  82%  of  respondents,  followed  by 
infrastructure  building  and  operating  systems.  Nevertheless,  a  considerable  share  of 
respondents expressed uncertainty, particularly about available training and infrastructure. 
When  assessing  burdens,  procurement  procedures  and  monitoring  requirements  were 
identified as the most burdensome, with over 70% finding them challenging. Beneficiaries 
also  reported  positive  results  in  line  with  planned  targets  and  milestones,  with  77% 
acknowledging 
findings, 
beneficiaries  noted  regulatory  requirements,  procurement  procedures,  and  information 
obligations  as  burdensome  elements.  Awareness  of  fraud  detection  and  prevention 
mechanisms varied, with a significant number of beneficiaries expressing uncertainty. 

reasonable  cost-effectiveness.  Despite 

these  positive 

Coherence and complementarity 

Although  43%  of  the  respondents  to  the  national  authorities  survey  did  not  provide  a 
response, the internal coherence of the ISF-BV was positively assessed by those national 
authorities who gave a rating (14 respondents), with no respondents indicating that ISF-
BV is “not coherent at all”. The majority of responses confirmed that the fund’s structure 
supports  complementarities  and  synergies.  Among  “other  stakeholders”,  over  half  of 
responses  confirm  the  fund’s  structure  supports  complementarity  either  to  a  very  large 
extent or large extent (i.e. 52-64%) (284). More respondents chose "To a very large extent" 
for Specific Actions (29%, 8 out of 28) than for Union Actions (14%, 4 out of 28). 

In  terms  of  coordination  mechanisms  to  ensure  the  external  coherence  of  the  ISF-BV, 
institutional  arrangements,  specific  directorates,  divisions,  units,  platforms,  and 
committees, were reported by 36% of respondents to the national authorities survey, while 
43% cited monitoring mechanisms to prevent overlap of financial instruments. Moreover, 
36%  of  national  authorities  conducted  assessments  to  identify  complementary  funding 
instruments, half of the respondents were unsure or did not answer. 

Respondents  were most  positive about  coherence with  other Home Affairs  Funds ,with 
43% answering to a large or very large extent in relation to the AMIF and 36% in relation 

(284)  64%  (or  14  out  of  22)  confirmed  the  existence  of  different  funding  mechanisms  supported 
complementarity and synergies to a very large or large extent. 52 (or 11 out of 21) confirm the contribution 
of different management modes supported complementarity and synergies to a very large or large extent.  

157 

 
 
to ISF-Police respectively. Coherence with Horizon 2020 and the European Structural and 
Investment  Funds  (ESF  and  ERDF)  was  also  confirmed.  Although  most  “other 
stakeholders” did not provide an answer, among those who did, ISF-Police received the 
most  positive  responses,  with  32%  (9  out  of  28)  indicating  coherence  to  a  "very  large 
extent" and 36% (10 out of 28) to "large extent, followed by AMIF, with 25% (7 out of 
28)  indicating  coherence  to  a  "very  large  extent"  and  also  25%  (7  out  of  28)  to  "large 
extent".  Beyond  the  Home  Affairs  Funds,  respondents  were  most  positive  about  the 
coherence between ISF-BV with ESIF (e.g. ESF and ERDF) and Horizon 2020. Similarly 
to  the  above,  most  beneficiaries  did  not  provide  an  answer  to  the  question  whether  the 
actions implemented through the ISF-BV were coherent with other EU interventions that 
have similar or complementary objectives (54% to 89% depending on the other EU fund 
listed). Among those who did  answer, respondents  were most positive about  the Home 
Affairs Funds: 37% (13 out of 35) indicating coherence to a "very large" or "large extent." 
With ISF-Police, and 28% (9 out of 35) for AMIF respectively 

EU Added Value 

The surveys indicate a generally positive perception of the EU added value of the ISF-BV 
across  various  domains  among  National  Authorities  and  stakeholders.  A  significant 
number of respondents recognised the Instrument’s contribution to the transfer of ideas, 
the  roll-out  of  innovative  approaches,  improvements  in  governance,  and  enhanced 
collaboration  among  stakeholders,  with  many  indicating  that  these  benefits  were 
substantial. Notably, while some authorities reported specific impacts on national policies, 
such  as  adaptations  to  align  with  EU  frameworks,  many  others  did  not  observe  any 
included 
significant  effects.  Positive  outcomes  attributed 
advancements  in  border  management  technology,  improved  working  conditions  for 
personnel,  and  strengthened  partnerships  among  stakeholders.  However,  a  considerable 
portion  of  respondents  also  expressed  uncertainty  or  a  lack  of  awareness  regarding  the 
Instrument’s  broader  impacts.  Overall,  while  the  ISF-BV  is  acknowledged  for  its 
contributions  to  various  areas,  the  recognition  of  its  effects  on  national  policies  and 
additional positive outcomes varies significantly among Member States. 

ISF-BV  projects 

to 

Sustainability 

Sustainability of ISF-BV’s outcomes reveal a mixed but generally positive outlook across 
stakeholders.  National  authorities  reported  varying  levels  of  engagement  in  ensuring 
sustainability, with 21% confirming the adoption of comprehensive measures, while 53% 
expressed  uncertainty.  Regarding  the  effectiveness  of  sustainability  measures,  15% 
considered  them  highly  effective,  while  35%  deemed  them  effective  to  a  large  extent. 
Other  stakeholders  also  showed  positive  assessments,  with  78%  viewing  sustainability 
measures as sound or adequate, although 43% expressed uncertainty. Among beneficiaries, 
23% confirmed the implementation of comprehensive measures, while a significant 46% 
were  uncertain  or  not  involved  in  sustainability  planning.  Overall,  beneficiaries  largely 
viewed the measures  positively, with  46% expressing confidence in their effectiveness. 
Despite  the  overall  positive  perception,  significant  uncertainty  remains,  particularly 
regarding the mechanisms in place to ensure long-term continuity. 

Simplification and reduction of administrative burden 

Simplification and reduction of administrative burden reveal a generally limited utilisation 
across stakeholders. Only 17% of National Authorities reported the use of simplification 
measures  (e.g.,  SCOs)  and  a  significant  portion  also  felt  the  time  and  complexity  were 
disproportionate to their responsibilities, with 56% stating the time required was excessive. 
Other stakeholders shared similar sentiments: while 18% (n=5) and 21% (n=6) considered 
the  time  spent  and  complexity  to  be  proportionate  to  their  role  and  responsibilities,  a 
significant share - 50% (n=14) for both factors - felt that obligations required more time 

158 

 
than justified. Finally, also a significant share of Beneficiaries - 40% (n=14) for complexity 
and 37% (n=13) for time spent - felt that obligations required more time than justified. 

2.2  EU level interviews 

Relevance 

The  feedback  collected  from  the  EU-level  interviews  on  the  relevance  of  ISF-BV  was 
limited,  as  most  of  the  stakeholders  consulted  were  only  able  to  provide  assessment  of 
BMVI, but not ISF-BV. Frontex noted that under ISF-BV, needs assessments were not 
based on a forward-looking methodology but rather on past historical trends to plan for the 
coming years. This meant that Member States' national programmes did not sufficiently 
capture and plan for how the rapidly changing context of border management may evolve 
and impact their longer-term needs. 

Effectiveness 

The effectiveness of ISF-BV was positively assessed by key stakeholders, though areas for 
improvement  were  highlighted.  DG  HOME  highlighted  examples  of  specific 
achievements  under  ISF-BV,  such  as  the  use  of  funds  to  upgrade  their  vehicles  with 
automatic  license  plate  recognition  systems,  allowing  for  quick  and  efficient  checks 
without needing to stop vehicles, making surveillance at cross-border areas much easier 
and ensures that potential threats flagged in systems like the Schengen Information System 
(SIS)  or  national  databases  are  identified.  DG  HOME  interviewees  also  noted  some 
challenges, such as the COVID-19 pandemic that constrained certain funded activities, or 
the  continued  perception  among  Member  States  that  the  use  of  ISF-BV  was 
administratively  complex.  Other  more  specific  challenges  mentioned  included  the  long 
waiting times for visa application appointments for third country nationals, due to a lack 
of  consular  staff,  despite  the  availability  of  European  funds  to  finance  these  positions. 
Other DGs interviewed could not comment on ISF-BV either because their position had 
only  started  as  the  ISF-BV  programming  period  came  to  an  end,  or  because  their  role 
focused narrowly on ensuring synergies between ISF-BV and another EU fund, and did 
not feel they were in a position to assess its effectiveness. International organisations like 
the ICMPD and IOM also reported positive impacts, including improved compliance with 
fundamental rights and enhanced reception facilities. Interviews also noted the importance 
of  peer-to-peer  relationships  and  the  ability  to  maintain  functional  operations  despite 
higher-level political issues. 

Efficiency  

The  feedback  collected  from  the  EU-level  interviews  on  the  relevance  of  ISF-BV  was 
limited, however, according to DG HOME, efficiency could be further enhanced by better 
integrating all funding streams. Furthermore, regarding the level of cost-effectiveness of 
Union Actions, it was emphasized that cost-effectiveness is a critical assessment element 
of the proposals, which are not funded unless they are deemed cost-effective. This aspect 
is scrutinised during the proposal evaluation to ensure that projects deliver results within a 
reasonable cost.  As for  Frontex, the agency noted that synergies and  cooperation were 
ensured  through  consultations  during  the  development  of  national  programmes  and 
specific  actions.  This  collaborative  approach  enhances  the  cost-effectiveness  of  the 
Instrument.  

Coherence and complementarity 

EU-level interviews with DG HOME officials confirmed the internal coherence of the 
ISF-BV, including the complementary nature of the different funding modalities following 
their legal base, the internal mechanisms within DG HOME (e.g. the coordination unit) to 
secure  internal  coherence,  as  well  as  the  potential  to  further  exploit  synergies  where 

159 

 
possible. For example, to build successful investments in Union Actions into national plans 
(either funded by the EU or funded nationally). 

In terms of the external coherence, EU level interviews confirmed that mechanisms are 
in place to ensure coordination between ISF-BV and other EU funding instruments, both 
at  EU  and  national  level.  EU  level  interviewees  noted  that  had  not  been  aware  of  any 
overlaps between ISF-BV and other EU funding instruments. 

The interviewees noted that ISF-BV had limited overlaps in scope with the ESF and ERDF, 
or the Justice Programme. In terms of the coherence of ISF-BV and EU funding in relation 
to  third  countries,  such  as  NDICI  Europe  and  IPAII,  some  interviewees  noted  only  a 
limited  number  of  proposals  under  ISF-BV  related  to  third  countries.  Some  EU  level 
stakeholders noted that the broad nature of the National Programmes (lack of details on 
planned activities and in relation to which third countries at planning stage) made it hard 
know whether and what exactly was being funded in relation to third countries under ISF-
BV.  However,  at  the  same  time,  it  was  noted  that  coordination  with  DG  HOME  had 
become much closer and more institutionalised since the migration crisis of 2015.   

ISF-BV funding was seen by several interviewees as a crucial tool to ensure the concepts 
developed under Horizon would lead to longer term testing and validation and eventually 
ensure  these  capabilities  were  available  to  procure  on  the  EU  market.  However, 
interviewees also confirmed that Responsible Authorities are often unaware of the relevant 
R&D projects funded in their country, as well as the relevant stakeholders involved, and 
that generally follow up to Horizon 2020 was not prioritised by Member States under ISF-
BV as they tended to focus on using funding to address more immediate needs. 

In  terms  of  complementarity,  the  EU-level  interviews  did  not  provide  any  relevant 
evidence. 

EU Added Value 

The  interviews  highlighted  the  ISF-BV’s  added  value  in  enhancing  Member  States' 
capabilities  and  fostering  cooperation  through  targeted  financial  support.  Without  EU 
funding,  Member  States  would  have  faced  severe  limitations  in  their  actions  due  to 
financial  constraints,  hindering  necessary  investments  in  resources  like  vessels  and 
helicopters  for  joint  operations.  This  financial  backing  not  only  strengthens  overall  EU 
security but also allows the Commission to guide investments effectively, ensuring higher 
added  value  while  respecting  shared  competencies.  Additionally,  instruments  beyond 
National  Programmes,  such  as  the  Union  Actions,  can  achieve  outcomes  that  national 
authorities  might  overlook  due  to  cost  considerations,  benefiting  a  broader  range  of 
stakeholders, including NGOs and private sector entities. These initiatives well exemplify 
how EU funds can facilitate transnational efforts, paving the way for cohesive policies, 
such  as  a  unified  visa  system  across  the  EU,  thereby  demonstrating  the  importance  of 
collaborative action for common objectives. 

Sustainability 

In terms of sustainability, the EU-level interviews did not provide any relevant evidence, 
apart  from  a  recognition  from  DG  HOME  that  –  while  funding  has  undoubtedly  had  a 
sustainable  impact  –  ongoing  investment  is  essential  to  maintain  and  enhance  border 
management capabilities. 

Simplification 

The interviews emphasised the need for a stronger commitment to simplified cost options 
to enhance efficiency and reduce administrative burdens. While the legal framework for 
simplification is robust, there is a lack of action to fully implement these options, which 
could streamline processes. Additionally, centralising procurement through the European 

160 

 
Commission  could  create  economies  of  scale,  benefiting  Member  States  by  reducing 
individual procurement  efforts.  Furthermore, the underutilisation of  European  funds (in 
particular, for consular staff) highlights a significant issue, as personnel expenditures deter 
some  Member  States  despite  the  availability  of  100%  financing.  The  complexity  of 
administrative  processes  is  frequently  cited  as  a  barrier,  indicating  a  critical  area  for 
improvement to maximise the effective use of available resources. 

2.3  Focus Group 

In terms of current needs, participants cited specific external events, e.g. 2015 migration 
crisis, Russian war of aggression against Ukraine as drivers for increased need / pressures 
for  border  management  against  a  backdrop  of  stretched  capacity.  IT  systems  featured 
heavily in the discussion of needs, there was mention of the need for innovation to allow 
for secure and smooth border process and efficiency, for development and maintenance of 
“big  IT  systems”  /  ”large  scale  IT  systems”,  and  “enhanced  security”  as  per  the  Smart 
Borders Package. In terms of new/emerging needs, participants highlighted a continued 
need  for  increased  border  surveillance  in  the  context  of  the  Russian  war  of  aggression 
against Ukraine, the new mandatory border procedures stemming from  the  EU Asylum 
and  Migration  Pact,  increased  needs  in  the  field  of  implementation  of  large-scale  IT 
systems, data management and AI, and the new EU rules to digitalise the visa procedure 
that  would  need  to  be  implemented  by  2031.  In  terms  of  the  relevance  of  types  of 
activities that could be funded under the BMVI, participants generally thought these were 
relevant, but noted a few examples of items they would have liked to see funded but were 
not  possible  under  the  current  fund  (or  were  not  funded  enough):  Participants  were 
generally positive about the flexibility of the fund,. Finally, some participants noted the 
need for better coordination on the EU funding across the different EU funds and agencies 
(e.g. Frontex). 

2.4  Responses to the open public consultation 

2.4.1  Respondent profile 

In  total,  28  stakeholders  participated  in  the  consultation.  Most  of  them  were  public 
authorities (78%, 22 out of 28 respondents) (285).  11% of respondents (2 out of 28) did not 
fit  into  the  predefined  categories  and  identified  themselves  as  "others”.  Finally,  7%  (2 
respondents) were from academic/research institutions, and 4% (1 respondent) were from 
companies/businesses.  Therefore,  business  associations,  consumer  organisations,  EU 
citizens, environmental  organisations, non-EU  citizens, non-governmental  organisations 
(NGO), and trade unions did not participate in the public consultation.  

Figure 27: Respondents by Type of Stakeholders 

(285) The percentages in the report are based on a total of 28 respondents (corresponding to 100% of the total 
response rate). 

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Specifically,  given  the  structure  of  the  consultation  tailoring  questions  based  on  the 
respondent's situation regarding EU funding for ISF-BV and BMVI and the similar type 
of stakeholders, most respondents answered the same questionnaire (98%, 26 respondents). 
They  either  represent  a  public  body  involved  in  the  management,  coordination,  or 
supervision of the ISF-BV or the BMVI in their Member State (36%, 10 respondents); a 
public  or  private  body,  an  entity  with  or  without  legal  personality,  or  a  natural  person 
responsible  for  initiating  and/or  implementing  operations  funded  by  ISF-BV  or  BMVI 
(29%, 8 respondents); represent a legal or natural person receiving support from either of 
the  two  instruments  (ISF-BV,  BMVI)  through  a  project  (21%,  6  respondents);  or  are 
knowledgeable about ISF-BV or BMVI in their personal or professional capacity (7%, 2 
respondents). Conversely, 7% (2 respondents) of respondents answered the other tailored 
questionnaire, declaring that they did not belong to any of the proposed categories.  

The respondents come from 13 different countries, including 12 from the European Union 
and one Schengen Associated Country: 21% (6 respondents) were from Switzerland (the 
only SAC represented),  followed by Hungary (18%, 5 respondents))., Bulgaria (14%, 4 
respondents), Portugal (11%, 3 respondents), and Romania (7%, 2 respondents). Finally, 
4% came from Malta, Latvia, Greece, Finland, Spain, the Czech Republic, Belgium, and 
Italy (1 respondent from each country). 

Figure 28: Respondents by Countries 

The  respondents  predominantly  come  from  large  organisations  (>250  employees),  with 
86%  of  respondents  reporting  they  work  in  this  type  of  organisation.  Only  11%  of 
respondents  and  3%  of  respondents  belong  to  medium-sized  organisations  (50  to  249 
employees) and micro-organisations, respectively. 

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Figure 29: Respondents by organisation size 

2.4.2  Substantial findings  

Questionnaire 1 

The limited number of respondents (2 out of 28) to the tailored questionnaire 1 does not 
allow to formulate significant conclusions. Nevertheless, it is observed that the respondents 
agree on the main issues that the EU faces today in managing external borders and ensuring 
a  smooth  visa  policy,  namely  the  inadequate  visa  procedures  and  the  inadequate  short 
stay/Schengen visa procedures. Conversely, they consider irregular immigration flows to 
be the least priority issue. 

Regarding the top priority for the contribution of EU funding to the management of the 
EU external borders, the two respondents have disparate views: one prioritizes ensuring 
secure  and  state-of-the-art  travel  documents  for  EU  citizens  and  residents,  as  well  as 
increased cooperation at national and EU levels to swiftly adapt to changing situations and 
challenges at EU external borders; the other prioritizes ensuring the fundamental rights of 
third-country nationals when subject to border management procedures. 

Similarly, for the top priority for EU funding for the common visa policy, one respondent 
prioritises the enhancement of security, the management of migratory pressures, and the 
fight  against  illegal  immigration,  while  the  other  prioritises  the  facilitation  of  legal 
immigration. 

Questionnaire 2 

Questionnaire 2 gathers responses from 98% of the respondents. The respondents have a 
generally  positive  opinion  of  the  ISF-BV.  54%  (14  respondents  believe)  the  ISF-BV 
effectively contributed to enhancing the management and security of EU external borders. 
The  remaining  46%  (12  respondents)  “somewhat  agree”  with  this  statement.  No 
respondents disagreed with this statement.  

Regarding the most effective actions or areas of intervention for the management of EU 
external borders funded with EU support, the respondents highlighted several key areas of 
effectiveness. The development and implementation of large-scale IT systems, such as the 
Entry/Exit  System  (EES),  the  European  Travel  Information  and  Authorization  System 
(ETIAS),  and  Interoperability  (IOP),  are  considered  highly  effective.  Additionally,  the 
enhancement of the Visa Information System (VIS), expected by 2026, is anticipated to 
improve  visa  application  management,  ensure  timely  data  exchange  between  Member 

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States,  reinforce  security  checks,  and  facilitate  legitimate  travel.  The  acquisition  of 
equipment  for  border  crossings,  including  automated  systems  and  Automated  Border 
Control (ABC) gates, as well as the improvement of border control and security at border 
posts  through  the  implementation  and  maintenance  of  information  systems  to  combat 
cross-border trafficking, are also noted as effective interventions. Furthermore, support for 
the  training  and  advanced  surveillance  technologies  to  strengthen  the  EU’s  capacity  to 
monitor  and  protect  its borders,  along  with  increasing  the  preparedness  level  of  human 
resources  through  support  for  border  police  training  systems,  are  highlighted.  The 
deployment  of liaison  officers, such as Airline Liaison Officers (ALOs)  and Document 
Advisors  in  third  countries,  is  also  recognized  as  a  significant  contribution.  Lastly, 
assistance  in  the  control  of  air  borders,  particularly  concerning  third-country  nationals 
(TCNs), is mentioned as an effective area of intervention. 

The respondents also have a positive view of the overall impact of the ISF-BV on the EU 
integrated management and on the EU common visa policy: 50% (12 out of 26) and 31% 
(8 out of 26) consider that the Instrument has a high impact in the respective areas, and 
42% (11 out of 26) and 34% (9 out of 26) find that the Instrument has some impact. Only 
two respondents in total expressed a limited negative opinion (low impact). 

Ad hoc contribution to the public consultation 

A public authority took the consultation procedure as an opportunity to issue its positive 
opinion about the ISF-BV in an ad hoc contribution. This public authority used ISF-BV 
for  the  procurement  of  document  verification  devices.  The  newly  acquired  document 
checking  devices  made  a  significant  contribution  to  carrying  out  border  controls  more 
efficiently and quickly, the authority declared. More specifically, the respondent declared 
that  ‘the  ISF-BV  played  ‘an  indispensable  role’  in  supporting  and  strengthening  anti-
police policies of the public authority, through targeted funding and promotion of projects 
and initiatives aimed at improving security infrastructure. 

2.5  Validation Workshop (Focus Group 3) 

Effectiveness 

The Commission's efforts to enhance consular cooperation through Specific Actions were 
largely unsuccessful, with only four out of eleven projects achieving success. This raises 
the need for a review of the necessity to expand consular coverage, as other mechanisms 
may already be addressing existing gaps. Additionally, the funding's primary focus is on 
external  border  control  rather  than  the  internal  dynamics  between  member  states. 
Clarification is needed regarding the absence of internal border control mentioned in the 
discussions, emphasising the importance of enhancing external capabilities. In terms of the 
Entry-Exit  System  (EES),  delays  in  projects  are  primarily  attributed  to  external  factors 
rather  than  issues  with  the  funding  structure.  Future  assessments  should  highlight  the 
achievements  made  in  systems  like  Eurodac  and  SIS,  acknowledging  that  significant 
progress has been made despite some preparatory projects remaining incomplete. Lastly, 
the notion of ABC gates as innovative tools is misleading; real innovation should focus on 
advanced  technology  and  collaborative  procurement  among  member  states,  rather  than 
merely developing basic tools. 

Efficiency and Simplification 

At the EU level, established mechanisms (OLAF) exist for corroborating information from 
member states  regarding payment requests, and it is advisable to refine the  conclusions 
drawn  from  these  processes.  Numerous  initiatives  are  in  place  to  raise  awareness  and 
provide training on anti-fraud measures, with national audit authorities playing a crucial 

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role in identifying irregularities, particularly in staff costs and public procurement. Reports 
should  concentrate  on  specific  issues  related  to  border  management  and  visa  policy,  as 
challenges often arise from expenditures occurring outside EU territory in consular offices. 
Furthermore, there is a pressing need to assist member states in streamlining procurement 
processes,  as  auditors  often  emphasize  the  burdensome  nature  of  open  competitive 
procedures. Finding ways to justify alternative, faster procedures is essential to alleviate 
pressure on managing authorities. Fostering a community of practice among member states 
could facilitate the sharing of best practices in procurement, thereby reducing unnecessary 
administrative burdens associated with tendering procedures. It is also important to note 
that procurement remains a high-risk area, necessitating stringent control over procurement 
processes. 

Coherence and Complementarity 

Establishing  a  clear  connection  between  transnational  projects  and  their  national 
counterparts  poses  significant  challenges.  While  efforts  are  being  made  to  increase 
awareness among managing authorities regarding certain EU actions, effectively bridging 
this gap remains complex and requires further attention. 

EU Added Value 

When considering transnational projects, it is essential to focus on developing common 
methodologies rather than merely funding individual member state activities, as each state 
is  responsible  for  its  own  systems.  Enhancing  existing  networks  and  activities  where 
member  states  can  share  best  practices  and  address  funding  challenges  would  be  more 
beneficial  than  pursuing  additional  transnational  projects.  While  there  are  already 
mechanisms in place for consultation with NGOs and civil society in border management, 
the real added value lies in fostering closer cooperation among member state authorities to 
share best practices and improve effectiveness, rather than increasing NGO involvement 
in practical information sharing. 

Relevance 

Participants did not share any views regarding relevance. 

Sustainability 

Sustainability conclusions should emphasize the need for flexible technical assistance that 
is consistently available. Long-term planning in border control requires the Instrument for 
Financial Support, which is crucial for the continuation of previously purchased equipment 
and  investments.  Integrating  flexibility  into  previous  conclusions  would  strengthen  the 
overall message. 

2.6  Country Case Studies 

Effectiveness 

The implementation of the ISF-BV instrument across various Member States has generally 
been effective, with significant achievements in enhancing border management and visa 
processing  capabilities.  Most  countries  successfully  met  their  specific  objectives, 
particularly  in  strengthening  external  borders,  improving  visa  issuing  procedures,  and 
upgrading IT systems to facilitate a common visa policy. Despite facing challenges such 
as  delays  due  to  the  COVID-19  pandemic,  natural  disasters,  and  geopolitical  events, 
stakeholders  reported  that  the  funding  contributed  to  substantial  modernisation  efforts, 
including the procurement of advanced surveillance equipment and the establishment of 
efficient operational frameworks. While some Member States experienced difficulties in 
project  execution  and  administrative  processes,  the  overall  perception  of  ISF-BV  is 
positive, with beneficiaries highlighting its critical role in addressing both immediate and 
long-term  needs  related  to  border  security  and  visa  management.  However,  common 

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concerns  included  issues  with  pre-financing  and  the  need  for  improved  mechanisms  to 
streamline project implementation and reporting. 

Efficiency 

The efficiency of the ISF-BV instrument across various Member States has generally been 
assessed positively, with significant achievements in utilising allocated funds effectively. 
Most countries reported high rates of fund utilisation, with many successfully completing 
projects that enhanced border management and visa processing capabilities. Stakeholders 
highlighted the cost-efficiency of projects,  attributing this to  robust public procurement 
procedures  and  proactive  support  from  responsible  authorities,  which  helped  navigate 
complex administrative processes. While some challenges were noted, such as delays due 
to  external  factors  like  the  COVID-19  pandemic  and  the  need  for  additional  budget 
allocations for certain strategic projects, the overall management and control systems were 
deemed effective in ensuring transparency and accountability. The flexibility of the ISF-
BV mechanism allowed Member States to prioritise pressing needs, particularly in border 
management,  while  Emergency  Assistance  funds  were  utilised  efficiently  to  address 
immediate operational challenges. Despite some bureaucratic hurdles and the complexity 
of  procurement  procedures,  the  implementation  of  ISF-BV  has  led  to  significant 
improvements  in  border  security and visa operations, demonstrating a strong alignment 
with the objectives of the Instrument.  

Coherence and complementarity 

The majority of countries confirmed that the ISF-BV was coherent with other programmes 
funded by EU sources. This coherence was achieved by different coordination mechanisms 
in the examined countries. More than half of the countries opted for an institutional setup 
to ensure coherence across various projects funded by both the ISF-BV and other European 
funding  sources.  In  Poland  the  ISF,  BMVI  and  AMIF  were  managed  by  the  same 
Managing  Authority and the same Delegated Authority, which also  made it possible to 
merge calls for projects which further facilitated the process and reduced administrative 
burden.  Similarly,  in  Croatia  the  ISF-BV  Managing  Authority  held  the  Managing 
Authority role for AMIF and all ISF activities too. In Greece the Responsible Authority 
also oversaw all three instruments (ISF-BV, ISF Police and AMIF). Moreover, a dedicated 
Policy Dialogue between key stakeholders was also held during the summer of 2013 to 
define  the  Greek  national  strategic  guidelines  and  specific  objectives  of  the  national 
programme and ensure their alignment and complementarity with the government policies 
and  initiatives.  This  was  complemented  with  a  series  of  bilateral  meetings  with  the 
competent authorities managing the other programmes and initiatives. In Italy an ad hoc 
organisational  unit  was  established  to  ensure  the  full  consistency  of  actions  financed. 
Additionally, annual programmes allowed this unit to have an overview of where budget 
was allocated, thus avoiding overlaps.  

In  Czechia  a  discussion  platform  served  to  approve  projects  and  themes  of  prepared 
programs and working groups of officials were established to check for program overlaps. 
The  connection  to  national  policies  was  monitored  by  a  strategy  department,  which 
oversaw the alignment of national and operational programs with the priorities of strategic 
documents  and  visions,  whether  departmental  or  nationwide.  Czechia  acknowledged 
challenges  related  to  complementarity,  which  stemmed  from  both  internal  and  external 
factors. Internally, there is a long-term need to enhance the quality of strategic documents 
and  improve  their  alignment  with  specific  projects  funded  by  national  sources  and 
operational programs. Externally, the impact of COVID-19 further complicated matters, 
leading  to  a  decline  in  interest  and  shifts  in  priorities  within  the  ministry's  senior 
management. 

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Spanish  stakeholders  also  noted  a  high  level  of  internal  coherence  within  ISF-BV  and 
considered  that  the  actions  included  in  the  National  Programme  fully  aligned  with  the 
European priorities and the directions received from the European Commission. Likewise, 
a  high  degree  of  complementarity  between  ISF-BV  and  other  funding  programmes  or 
instruments,  such  as  ISF-Police  and  AMIF  was  noted  as  well.  Norway,  as  a  Schengen 
Associated Country, did not participate in many other programmes funded by EU resources 
but stakeholders reported that ISF-BV funding was coherent with national funding.  

Overall,  the  findings  indicate  that  ISF-BV  has  successfully  established  coherence 
internally,  as  well  as  with  other  relevant  EU  and  national  initiatives,  enhancing  its 
effectiveness and ensuring that resources are utilised efficiently. The ISF-BV design and 
implementation reflect a commitment to complementing existing strategies and addressing 
the multifaceted challenges of border management and visa policies across member states. 

Relevance 

All eight countries assessed ISF-BV as relevant, with three countries (Greece, Croatia and 
Norway) assessing it very or highly relevant. Greece faced challenges in the development, 
maintenance,  and  operationalisation  of  IT  tools  and  systems  for  visa  and  border.  Such 
needs  served  as  evidence  of  the  relevance  of  ISF-BV.  Furthermore,  maritime  border 
management was highlighted as a major challenge for Greece at the time, underscoring the 
need  for  the  ISF-BV  instrument  to  support  Greece  in  addressing  these  gaps  but  also 
mentioning that the actual needs were two to three times greater than what the programme 
offered. Stakeholders in Spain also confirmed that it would have been very challenging to 
finance many of their actions exclusively from the national budget. Poland considered ISF-
BV  quite  detailed  yet  flexible  enough  to  adapt  to  specific  needs.  However,  Polish 
stakeholders underlined that the process for project changes for Specific Actions, which 
required approval from the European Commission, takes too much time and sometimes 
delayed the use of funds. Nevertheless, Polish stakeholders emphasised the importance of 
the funding provided within the ISF-BV to address the existing needs in the areas of border 
management and visa policy in Poland, particularly for the main beneficiary, the Border 
Guard  (whose needs were described  as “endless” in  the current international  situation). 
Norway's mid-term evaluation confirmed the Instrument's high relevance, particularly in 
supporting the modernisation of outdated IT systems. Moreover, the program's focus on 
addressing  evolving  needs  was  evident  as  Norwegian  authorities  revised  the  program 
several  times  to  align  with  changes  in  EU  information  systems  (SIS  recast,  EES,  and 
ETIAS).  

Overall, the evaluation findings suggest that the ISF-BV program has effectively identified 
and addressed the needs of national authorities across various countries. The programme's 
design and implementation have been guided in the majority of the countries by taking into 
consideration the beneficiaries’ actual needs in the form of preliminary assessments (Italy), 
needs assessment and consultation process (Greece), open call approach (Croatia), creation 
of working groups (the Czech Republic), or built-in mechanisms for revision (Romania). 
These  approaches  have  allowed  the  ISF-BV  programme  to  maintain  its  relevance  in 
addressing the challenges faced by the examined Member States. 

EU Added Value 

The EU added value of the ISF-BV instrument is widely recognised across Member States, 
with stakeholders affirming that many projects and initiatives would not have been feasible 
without this financial support. The funding has enabled significant advancements in border 
management and visa policy, allowing countries to meet EU standards and enhance their 
operational  capabilities.  Beneficiaries  noted  that  the  absence  of  ISF-BV  funding  would 
have  led  to  reduced  priorities,  lower  efficiency,  and  compromised  quality  in  project 
outcomes, as national resources alone would not suffice to address extensive needs. The 

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Instrument  has  facilitated  the  sharing  of  information  and  technology  among  Member 
States, contributing to a unified approach to security and migration policy. Additionally, 
the ISF-BV has been instrumental in developing staff competencies and skills, ensuring 
that  training  and  project  implementation  meet  high  standards.  Overall,  the  funding  has 
acted as a catalyst for essential measures, allowing for better resource allocation, improved 
infrastructure, and enhanced cooperation, ultimately benefiting both individual Member 
States and the EU as a whole. 

Sustainability 

The  sustainability  of  the  ISF-BV  instrument  across  Member  States  is  generally  viewed 
positively, with beneficiaries expressing confidence that the results of their projects will 
have lasting effects. Many projects have been designed with long-term maintenance plans, 
ensuring  that  equipment  and  systems  remain  functional  beyond  the  funding  period. 
Stakeholders  noted  that  training  initiatives  contribute  significantly  to  sustainability  by 
enhancing staff competencies, which helps maintain operational effectiveness. While some 
projects are inherently sustainable due to the nature of the investments in infrastructure 
and technology, others require ongoing support and resources to adapt to evolving needs. 
Challenges  to  sustainability  include  the  reliance  on  individual  knowledge  within 
organisations  and  the  need  for  strategic  planning  mechanisms,  which  are  still  being 
developed  in  some  cases.  Overall,  the  commitment  to  using  national  resources  and  the 
potential for leveraging future EU funding are seen as crucial for ensuring the continued 
impact of ISF-BV initiatives, with monitoring measures in place to assess the sustainability 
of funded projects over time. 

Simplification and reduction of administrative burden 

The  simplification  and  reduction  of  administrative  burden  associated  with  the  ISF-BV 
instrument  have  been  met  with  mixed  responses  across  Member  States.  While  many 
beneficiaries  appreciate  the  support  provided  by  Responsible  Authorities  in  project 
preparation  and  implementation,  challenges  remain,  particularly  in  public  procurement 
processes,  which  are  often  perceived  as  complex  and  burdensome.  Beneficiaries  have 
noted that centralised procurement offices can alleviate some administrative tasks, but the 
lack of online systems for documentation submission can delay processes. Some countries 
have reported improvements due to new information systems and simplified cost options, 
which  have  streamlined  reporting  and  reduced  complexity.  However,  issues  such  as 
excessive documentation requirements and rigid administrative procedures persist, leading 
to  frustrations  among  stakeholders.  In  certain  cases,  internal  procedures  have  been 
identified  as  contributing  to  the  high  administrative  burden,  rather  than  the  EU 
requirements  themselves.  Overall,  while  there  are  efforts  to  simplify  processes  and 
enhance  communication,  significant  administrative  challenges  remain  that  need  to  be 
addressed to improve the efficiency of the ISF-BV implementation. 

2.7  Thematic Case Studies 

Emergency Assistance 

Stakeholders consulted expressed positive views on the flexibility of EMAS in addressing 
gaps under  ISF-BV.  It  was  noted that the EMAS application and approval  process  was 
quick,  typically  taking  2-4  weeks,  and  was  less  burdensome  compared  to  national 
programme requirements, allowing for rapid funding once requested. This efficient process 
was crucial in crisis situations, where delays could have worsen issues and increased risks. 
However,  first-time  applicants  for  EMAS  reported  a  high  administrative  burden  and 
suggested  extending  the  reporting  period  from  3  months  to  6  months  due  to  their 
inexperience with EU funds and the lack of a dedicated management unit. 

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Interviewees  highlighted  that  EMAS  funding  was  versatile,  supporting  a  wide  range  of 
activities  necessary  for  emergency  responses,  although  it  did  not  cover  structural 
investments or long-term actions, which aligned with its intended purpose. The different 
management modes served complementary objectives: national programmes focused on 
structural  and  long-term  needs,  Union  actions  addressed  transnational  needs,  while 
Emergency Actions catered to immediate and specific requirements during emergencies. 
EMAS thus enhanced the capacity of Member States to respond to unforeseen needs not 
covered  by  national  programmes  or  Union  Actions,  leading  to  a  more  comprehensive 
response to emergencies. 

The evaluation of ISF-BV also confirmed the high internal coherence and complementarity 
between EMAS, national programmes, and Union Actions. EMAS was recognised for its 
significant role in addressing immediate needs that national programmes could not meet, 
particularly  during  crises  like  the  Migration  Crisis  in  Greece.  While  some  stakeholders 
pointed out instances of misuse of EMAS for longer-term issues, they did not view this as 
a duplication of efforts, as EMAS actions still supported national programme initiatives. 
Despite the overall positive assessment, the evaluation identified areas for improvement in 
maximising  synergies  between  Union  Actions  and  EMAS.  It  found  that  some  ISF-BV 
beneficiaries were unaware of other ISF-BV funded actions and viewed coordination as an 
informal initiative that could be strengthened to prevent potential overlaps.  

Specific Actions 

The selected Specific Actions assessed for this case study related to consular cooperation 
(SA 1) and the purchase of Frontex equipment (SA 2) from 2014 to 2021. Their outcomes 
reveal a landscape of mixed results. SA 1 demonstrated a variety of outcomes, with some 
projects achieving success, while others faced significant delays or cancellations due to 
administrative difficulties, security issues, and a lack of partner engagement, as seen in the 
Schengen houses in Kigali and Khartoum. Despite these challenges, SA 1 aligned with EU 
priorities by promoting consular cooperation and improving visa processing. Nevertheless, 
numerous projects struggled with local political and logistical hurdles, which limited their 
effectiveness.  At  the  same  time,  while  the  design  of  these  actions  allowed  for  some 
flexibility,  real-world  complexities,  such  as  local  regulations  and  security  risks,  often 
constrained  their  adaptability.  In  contrast,  SA  2  exhibited  significant  achievements, 
effectively addressing EU priorities by enhancing border security and supporting Frontex's 
operational capacity, despite facing procurement difficulties and budget constraints. Both 
SA 1 and SA 2 generally aligned with the operational needs of Member States, although 
the degree of alignment varied based on local conditions and implementation challenges. 
The  added  value  of  Specific  Actions  was  evident  in  SA  1,  which  provided  substantial 
benefits  through  collaborative  projects  that  pooled  resources  among  Member  States, 
improving service efficiency and addressing complex challenges that individual countries 
could not manage alone. Similarly, SA 2 enhanced solidarity in external border protection 
and interoperability among Member States, significantly contributing to the effectiveness 
of EU external border management. 

Union Actions 

National authorities confirmed that Union Actions contributed to a wide range of possible 
activities,  and  their  achievements  varied  in  line  with  the  specific  rationale  for  a  given 
action.  Union  Actions  were  perceived  as  providing  a  unique  opportunity  to  finance 
activities that paved the way for new and better ways of working when they were conceived 
to  develop  a  specific  concept  or  product  and  were  well  implemented.  They  provided 
significant  EU  added  value  and  were  more  efficient  than  if  all  Member  States  had 
conducted the activities independently.  

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However,  stakeholders  highlighted  certain  cases  where  the  appetite  to  deliver  activities 
was low for example due to sensitivities, which led to the Union's Actions not working out 
in practice. Furthermore, they acknowledged that, in certain instances, innovative projects 
and good practices were being developed, effectively communicated, and logical next steps 
were being pursued. However, there was a shared sentiment that additional efforts could 
be made to ensure that processes to ensure that possible synergies between Union Actions 
and actions at the national level are exploited in a more systematic manner. Stakeholders 
also confirmed that the Union Actions examined in the case study effectively demonstrated 
the  complementarity  with  indirectly  managed  actions  under  the  Migration  Partnership 
Facility, underscoring the interconnected nature of these funding initiatives. 

Union  Actions  involved  a  variety  of  activities  aimed  at  addressing  specific  needs, 
particularly  in  enhancing  capacity  through  training  and  operational  support,  such  as 
LATBEL.  While  these  actions  have  been  effectively  deployed,  challenges  such  as  the 
Covid  pandemic  and  migration  issues  have  impacted  their  implementation.  Procedural 
concerns, especially the administrative burden on smaller Member States and perceived 
financial  risks,  had  some  deterring  effect  on  national  authorities  from  participating. 
Interviews  indicated  that,  despite  interest,  managing  transnational  collaboration  was 
deemed to be too complex for some national authorities. The country case studies suggests 
that Member States often viewed Union Actions as additional work, preferring to focus on 
their national programmes due to the DG HOME representatives perceived Union Actions 
as coherent with other funding mechanisms, with no significant overlaps. However, they 
also  indicated  that  potential  synergies  may  be  overlooked  since  information  on  Union 
Actions is not systematically shared with national authorities.  

Russian war of aggression 

Consultation with national authorities suggested that the ISF-BV was not used to address 
the challenges faced in border management as a result of the Russian war of aggression 
against Ukraine. This was due to the fact, that all projects funded by ISF-BV were designed 
and  contracted  before  the  war,  and—even  after  it  started—they  continued  without  any 
changes  to  the  activities.  Because  of  that,  all  interviewed  Responsible  Authorities 
confirmed that the projects implemented by ISF-BV did not have any direct link with the 
response to the increased number of displaced persons from Ukraine. 

However,  following  the  adoption  of  the  Commission’s  proposal,  the  implementation 
period  for  the  funding  available  to  Member  States  under  the  2014-2020  Home  Affairs 
Funds, including ISF-BV, was extended by one year due to the Russian war of aggression. 
This allowed for the extension of the duration of ISF-BV funded projects.  

According  to  the  stakeholders  consulted,  the  extension  of  the  funding  period  was  very 
useful. It allowed accommodating some delays in projects, which were related not only to 
the Russian war of aggression but also to the COVID-19 pandemic (particularly in Poland) 
or delays in public procurement (particularly in Slovakia). The extension allowed the full 
implementation of projects. All interviewees confirmed it was beneficial for them and the 
implemented projects. However, one Responsible Authority noted that it also extended the 
overlap of the previous and the current funding period, which created an administrative 
burden  for  the  Authority,  which  has  limited  capacity  to  manage  two  programmes 
simultaneously. 

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