COMMISSION STAFF WORKING DOCUMENT EVALUATION Ex-post Evaluation of the Internal Security Fund - Police (ISF-P) for the 2014-2020 programming period
Date: 2026-03-03
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU police cooperation, crisis management, critical infrastructure security, financial control, fund (EU), information security, organised crime, prevention of delinquency, project evaluation, terrorism

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.3.2026  SWD(2026) 79 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Ex-post Evaluation of the Internal Security Fund - Police (ISF-P) for the 2014-2020 programming period {SWD(2026) 83 final}  
 
 
Table of contents 

1. INTRODUCTION ............................................................................................... 1 

1.1. Policy context and development .............................................................................. 3 

1.2. Methodology ............................................................................................................ 5 

1.3. Limitations ............................................................................................................... 6 

2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ..... 6 

2.1. Description of the ISF-P and its objectives ............................................................. 6 

2.2. Intervention logic ..................................................................................................... 7 

2.3. Points of comparison ............................................................................................. 10 

3.  HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 
PERIOD ......................................................................................................... 11 

3.1. Overall description of the implementation set-up ................................................. 11 

3.2. ISF-P Implementation: Financial Progress ............................................................ 12 

4. EVALUATION FINDINGS ............................................................................. 19 

4.1. To what extent was the intervention successful and why? .................................... 19 

4.1.1. Effectiveness ....................................................................................................... 19 

4.1.2. Efficiency ............................................................................................................ 31 

4.1.3. Simplification and Reduction of Administrative Burden ................................... 39 

4.1.4. Coherence and Complementarity ....................................................................... 42 

4.2. How did the EU intervention make a difference and to whom? ............................ 50 

4.2.1. EU Added Value ................................................................................................. 50 

4.2.2. Sustainability ...................................................................................................... 54 

4.3. Is the intervention still relevant? ............................................................................ 57 

5. WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ............... 66 

5.1. Conclusions ............................................................................................................ 66 

5.1.1. Effectiveness ................................................................................................... 66 

5.1.2. Efficiency and Simplification and reduction of administrative burden .......... 67 

5.1.3. Coherence and complementarity ..................................................................... 67 

5.1.4. EU added value ............................................................................................... 68 

5.1.5. Sustainability ................................................................................................... 69 

5.1.6. Relevance ........................................................................................................ 69 

5.2. Lessons Learned .................................................................................................... 70 

ANNEX I.  PROCEDURAL INFORMATION .................................................... 72 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ........... 73 

 
 
ANNEX III. EVALUATION MATRIX ............................................................... 76 

ANNEX IV. OVERVIEW OF BENEFITS AND COST .................................... 100 

ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT ..... 103 

 
 
 
 
 
Abbreviations 

Term or acronym 

Meaning or definition 

AI 

AMIF 

BMVI  

CEPOL  

CIPS 

DG DIGIT 

DG HOME 

DG INTPA 

DG MARE 

DG REGIO 

DG RTD 

EMAS 

EMPACT 

EU  

Europol 

Eurostat 

IPA 

ISEC 

ISF 

ISF-BV 

ISF-P  

JHA 

Artificial Intelligence 

Asylum Migration and Integration Fund 

Border Management and Visa Instrument 

European  Union  Agency  for  Law  Enforcement 
Training 

Specific  programme  ‘Prevention,  Preparedness  and 
Consequence  Management  of  Terrorism  and  Other 
Security-related Risks’ 

Directorate-General for Digital Services 

Directorate-General for Migration and Home Affairs 

Directorate-General for International Partnerships 

Directorate-General for Maritime Affairs and Fisheries 

Directorate-General for Regional and Urban Policy 

Directorate-General for Research and Innovation 

Emergency Assistance 

European Multidisciplinary Platform Against Criminal 
Threats 

European Union 

European Union Agency for Law Enforcement 

Statistical Office of the European Union 

Instrument for Pre-accession Assistance 

Specific programme ‘Prevention of and Fight against 
Organised Crime’ 

Internal Security Fund 

Internal Security Fund – Borders and Visa 

Internal Security Fund – Police 

Justice and Home Affairs 

 
 
JIT 

JRC 

Joint Investigation Teams 

Joint Research Centre 

MAOC-N 

Maritime Analysis and Operations Centre – Narcotics 

MS 

NO 

OLAF 

PNR 

SCOs 

Member States 

National Objective 

European Anti-Fraud Office 

Passenger Name Record 

Simplified cost options 

SFC2014 

System for Fund Management in the European Union    

SG 

SJ 

SWD 

TEU 

TFEU 

Secretariat-General 

Legal Service 

Staff Working Document 

Treaty on the European Union 

Treaty on the Functioning of the European Union 

 
 
 
 
 
List of tables and figures 

17 

Table 1 - Specific Objective – fight against crime: Number of actions per national 
objective 
Table 2 – Specific Objective – fight against crime: Achievement per main indicator18 
Table 3 - Specific Objective – fight against crime: Comments per indicator  19 
Table 4 -  Specific Objective – risk management: Number of actions per national 
objective 
25 
Table 5 - Specific Objective – risk management: Achievement per main indicator 26 
Table 6 - Shared management: Technical assistance absorption rate by Member State34 
Table 7 - Summary of differences affecting administrative burden between the 
Instruments 
Table 8 - Complementarity of the funding components 
Table 9 - Alignment between the Specific Objectives of the ISF-P and the EU Internal 
Security Policy 
42 
Table 10 - Overview of needs identified in the National Programmes per policy 
fields58 
Table 11 – Description of targeted stakeholders 

37 
40 

100 

11 

4 
6 
10 

Figure 1 - Development of Home Affairs Funds 
Figure 2 - Intervention Logic of the ISF-P 
Figure 3 - Total allocation of the ISF-P 
Figure 4 - Financial Progress of the ISF-P: Distribution of Allocated, Committed and 
Paid Resources by Management Mode in EUR 
Figure 5 - Implementation rate per Specific Objective under shared management  12 
Figure 6 - Allocation of paid resources by policy field in shared management 12 
13 
Figure 7 - Total allocated resources by Member State (EUR in millions) 
Figure 8 - Distribution of ISF-P allocated resources by Specific Objective across 
14 
Member States 
15 
Figure 9 - Absorption rate per Member State 
Figure 10 - Distribution of Allocations under Direct and Indirect Management (in 
millions of EUR) 
Figure 11  – Timelines for Specific Objective – fight against crime 
Figure 12 - Stakeholder answers to the question: ‘To what extent have the funded 
actions resulted in the following outcomes, which strengthened your country’s 
capacities in preventing and combating cross-border, serious and organised crime, 
including terrorism?23 
Figure 13 - Stakeholder answers to the question: ‘To what extent do you agree that the 
ISF-P contributed to…’ 
Figure 14 - Timelines of Specific Objective – risk management 
Figure 15 - Stakeholder answers to the question: ‘To what extent have funded actions 
resulted in the following outcomes, ultimately enhancing the capacity of Member 
States to manage effectively security-related risks and crises and to protect people a28 
Figure 16 - Replies to the question  “In your opinion, to what extent were the results 
achieved by the ISF-P reached in a cost-effective manner?” 
Figure 17 - Number of replies to the survey question “To what extent have the 
following points represented a challenge in managing national programmes and 
33 
related application procedures?” 

24 
25 

15 
17 

31 

 
 
 
 
Figure 18 - Number of replies to the survey question “To what extent had the 
following changes in procedures introduced by the ISF-P resulted in the simplification 
of administrative burden for the beneficiaries of the Fund?“ 
40 
Figure 19 - Stakeholder responses on the extent the outcomes and benefits of the 
projects funded under ISF-P (2014-2020) have been sustainable over time.  53 
Figure 20 - Allocation of paid resources under shared management by policy field and 
by Member State 
Figure 21 - Distribution of responses by stakeholder type 
Figure 22 - Breakdown of responses by stakeholder group 
Figure 23 - Breakdown of responses by country of origin 
Figure 24 -  Breakdown of responses by geographic scope of business 
Figure 25 - Breakdown of responses by organisation type 
Figure 26 - Degree to which the following points represented a challenge in managing 
Member States Programmes and related application procedures 

60 
102 
104 
105 
106 
106 

108 

 
 
 
 
1. INTRODUCTION 

The  Internal  Security  Fund  –  Police  (‘ISF-P’  or  the  ‘Instrument’)  was  established  by 
Regulation (EU) No 513/20141 (ISF-P Regulation) for the 2014-2020 programming period 
and  is  applicable  as  of  1  January  2014  to  all  Member  States  except  Denmark2  and  the 
United Kingdom3.  

This  Staff  Working  Document  (SWD)  presents  the  ex-post  evaluation  of  the  ISF-P 
(hereafter “the Evaluation”). The purpose of this evaluation is set out in Article 57(2)(b) 
of  Regulation  (EU)  No  514/2014  (Horizontal  Regulation)4,  which  requires  the 
Commission to carry out an ex-post evaluation by 30 June 2024 to assess the effect of the 
ISF-P and Horizontal Regulations following the close of the national programmes.  

The deadline of 30 June 2024 was extended by one year through the amendment of the 
Horizontal Regulation5, following the Russian war of aggression against Ukraine on 24 
February 2022. The amendment extended the implementation of ISF-P, as well as of the 
Internal  Security  Fund  –  Borders  and  Visa6  and  the  Asylum,  Migration  and  Integration 
Fund7 (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 513/2014 of the European Parliament and of the Council of 16 Abril 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. 
2 In accordance with Articles 1 and 2 of Protocol No 22 on the position of Denmark, annexed to the TEU 
and to the TFEU, Denmark is not taking part in the adoption of this Regulation and is not bound by it or 
subject to its application. In accordance with Article 3 of Protocol No 21, Ireland has notified its wish to take 
part in the adoption and application of Regulations (EU) No 513/2014 and 514/2014.  
3 In accordance with Articles 1 and 2 of Protocol No 21 on the position of the United Kingdom in respect to 
the area of freedom, security and justice, annexed to the TEU and to the TFEU, the United Kingdom is not 
taking part in the adoption of this Regulation and is not bound by it or subject to its application.  
4 Regulation (EU) No 514/2014 of the European Parliament and of the Council of 16 Abril 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, pp. 
112–142. ELI: http://data.europa.eu/eli/reg/2014/514/oj 
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 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 
143–167. 
OJ 
ELI: http://data.europa.eu/eli/reg/2014/515/oj 
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 2007/435/EC, OJ L 150, 20.5.2014, p. 168-194, ELI: http://data.europa.eu/eli/reg/2014/516/2022-
04-12. 

574/2007/EC. 

20.5.2014, 

Decision 

150, 

pp. 

No 

L 

1 

 
 
 
The Evaluation covers the period from 1 January 2014 to 30 June 2024. The material scope 
covers activities under the three existing management modes: shared management, direct 
management  and  indirect  management.  The  geographical  scope  includes  all  ISF-P 
participating  Member  States,  i.e.  all  Member  States  except  Denmark  and  the  United 
Kingdom8. The material scope of the evaluation covers activities under the three existing 
management modes: shared management, direct management and indirect management. 

The  Evaluation  primarily  focuses  on  assessing  the  main  evaluation  criteria  of 
effectiveness,  efficiency,  relevance,  coherence,  complementarity,  EU  added  value, 
sustainability,  simplification  and  reduction  of  administrative  burden.  The  evaluation 
questions, as well as the result and output indicators to be used in this evaluation9, were 
defined in the Commission Delegated Regulation (EU) 2017/20710 setting out a common 
monitoring and evaluation framework for the 2024-2020 programming period applicable 
to the ‘Home Affairs Funds’.  

The  Evaluation  is  based  on  ten  evaluation  questions  organised  around  these  eight 
evaluation criteria11, as follows:  

8 The ISF-P Regulation is based on legal bases under Title V of Part Three TFEU, concerning the area of 
freedom, security and justice. As a consequence, the application of the Regulation to Denmark, the United 
Kingdom and Ireland is subject to the provisions laid down in Protocol No 21 and Protocol No 22 annexed 
to the TEU and the TFEU. In accordance with Articles 1 and 2 of Protocol No 22, Denmark does not take 
part in the adoption of the ISF-P Regulation and is not bound by or subject to its application.  In accordance 
with Articles 1 and 2 of Protocol No 21, the United Kingdom and Ireland do not take part in the adoption of 
the ISF-P Regulation and are not bound by or subject to its application. Pursuant to Article 3 of Protocol No 
21, Ireland notified its wish to take part in the adoption and application of the ISF-P Regulation.  
9 There was no obligation to report on core indicators for direct and indirect management during the 2014-
2020 programming period.  
10  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 
11 The Evaluation questions are developed in Annex III. Evaluation matrix. 

2 

 
 
Effectiveness

• How did the Fund contribute to the achievement of Specific Objective –
fight against crime?
• How did the Fund contribute to the achievement of Specific Objective –
risk management?

Efficiency

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

Relevance

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

Coherence

•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?

Complementarity

• 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?

EU Added Value

• Was any value added brought about by the EU support?

Sustainability

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

Simplification

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

1.1. Policy context and development 

Article 67 of the Treaty on the Functioning of the European Union (TFEU) sets out that 
the European Union (EU) shall constitute an area of freedom, security and justice and shall 
endeavour  to  ensure  a  high  level  of  security.  The  objective  of  ensuring  a  high  level  of 
security  is  to  be  achieved  inter  alia  through  measures  to  prevent  and  combat  crime, 
measures for coordination and cooperation between law enforcement authorities and other 
Member States’ national authorities (including coordination and cooperation with relevant 
Union  agencies  and  other  relevant  Union  bodies,  and  with  relevant  third  countries  and 
international organisations).  

The Internal Security Strategy for the European Union (‘2010 Internal Security Strategy’), 
adopted  by  the  Council  in  February  201012,  constituted  a  shared  agenda  for  tackling 
common internal security challenges for the 2010-2015 period. This Strategy’s principles 
and  guidelines  were  later  translated  into  concrete  actions  by  the  Commission 
Communication  of  22  November  2010  entitled  ‘The  EU  Internal  Security  Strategy  in 
Action: Five steps toward a more secure Europe’13.  

For  the  2015-2020  period,  the  Commission,  the  Council  and  the  European  Parliament 
defined common priorities as set out in the European Agenda on Security of April 201514. 
The common priorities set out in the European Agenda were reaffirmed by the Council in 
the renewed Internal Security Strategy of June 2015 and by the European Parliament in its 

12 7120/10. 
13 COM(2010) 673 final 
14 COM(2015) 185 final. 

3 

 
 
 
Resolution of July 2015, namely by preventing and combating terrorism and radicalisation, 
serious and organised crime and cybercrime.  

To achieve an effective high level of internal security throughout the EU, Member States 
were provided with adequate financial support from the Union. The first EU funding for 
internal  security  purposes  was  the  Framework  Programme  on  Police  and  Judicial 
Cooperation in Criminal Matters (AGIS)15 running between 2003-2007, which was later 
followed by the General Programme on Security and Safeguarding Liberties covering the 
Specific Programmes ‘Prevention of and Fight against Crime’16 (ISEC) and ‘Prevention, 
Preparedness  and  Consequence  Management  of  Terrorism  and  other  Security  related 
risks’17  (CIPS)  during  the  2007-2013  programming  period.  These  programmes  were 
adopted  during  the  pre-Lisbon  intergovernmental  period  of  EU  police  and  security 
cooperation based on Articles 30, 31 and 34(2)(c) of the Treaty on European Union.  

In particular, the ISF-P was established for the 2014-2020 programming period with the 
objective  to  support  measures  aimed  at  preventing  and  fighting  serious  and  organised 
crime,  terrorism  and  radicalisation,  corruption  and  cybercrime,  and  at  assisting  and 
protecting victims of crime. 

Funding from the EU budget focuses on actions for which Union intervention can bring 
greater added value compared with action by Member States alone.  

The figure below presents the main stages in the development of EU support to the Home 
Affairs  policy  areas  of  migration,  border  management  and  internal  security  from  2002 
through 2027. 

15 Council Decision 2002/630/JHA. 
16 Council Decision No 2007/125/JHA. 
17 Council Decision 2007/124/EC. 

4 

 
 
 
 
 
 
 
 
 
Figure 1 - Development of Home Affairs Funds 

Framework Programme on Police and 
Judicial Cooperation in Criminal Matters  

2002-2006: EUR 65 million 

ARGO Programme 

For administrative cooperation in the fields of 
external borders, visas, asylum and 
immigration 
2002-2006: EUR 25 million 

Framework Programme on Securing Liberties 
(SSL) 

Framework Programme Solidarity and Management of Migration 
Flows 

2007-2013 

2007-2013 

Prevention and 
Fight against 
Crime (ISEC) 

EUR 600 million 

CIPS 
Prevention, Preparedness and 
Consequences Management of 
Terrorism and other Security 
related risks 
EUR 140 million 

European 
External 
Borders Fund 
EUR 1.82 
billion 

European 
Return Fund 

EUR 676 
million 

European 
Refugees 
Fund 
EUR 614 
million 

European Fund for 
the integration of 3rd 
Country Nationals 

EUR 825 million 

Internal Security Fund 
2014-2020 

Asylum, Migration and 
Integration Fund 

Borders and Visa 

Police 

2014-2020: EUR 3.13 billion 

EUR 2.9 billion 

EUR 1.21 billion 

Integrated Border Management Fund 

2021-2027 

Border Management 
and Visa Policy 
Instrument 

Customs Control 
Equipment 
Instrument 

EUR 6.24 billion 

EUR 1 billion 

Internal Security 
Fund 

2021-2027: EUR 
1.93 billion 

Asylum, Migration and 
Integration Fund 

2021-2027: EUR 9.88 billion 

5 

 
 
 
 
1.2. Methodology  

The preparatory work for this Evaluation was conducted by a consortium led by ECORYS 
on  behalf  of  the  Commission.  The  methodology  used  primary  and  secondary  data 
collection as well as quantitative and qualitative methods. Data collection included scoping 
interviews,  desk  research  and  targeted  consultations  (i.e.  interviews  with  stakeholders, 
targeted  surveys  and  focus  groups).  It  included  data  analysis  concerning  country  and 
thematic case studies to provide additional input for the analysis of the different Instrument 
components. The data collected were triangulated to validate consistency across sources 
and provide well-founded insights and responses to the evaluation questions. A complete 
description of the methodology applied is included in Annex I. 

As  the  Commission  was  also  requested  to  provide  a  mid-term  evaluation  report  of  the 
successor  of  the  ISF-P,  the  Internal  Security  Fund  (ISF)18,  by  December  2024,  the 
Commission decided to carry-out both the evaluations of the ISF-P (ex post) and ISF (mid-
term)  simultaneously,  to  facilitate  the  exchange  of  information  and  the  use  of  common 
findings and analysis.  

1.3. Limitations 

The evaluation faced challenges related to data quality, availability, and consistency across 
Member States. Differences in the level of detail in the Annual Implementation Reports, 
Final  Implementation  Reports  and  national  ex-post  evaluations  made  cross-country 
comparisons  difficult.  Data  on  result  and  impact  indicators  transmitted  by  the  Member 
States via System  for Fund Management  in  the  European Union (SFC2014) included  a 
number  of  omissions,  clerical  errors,  and  revealed  differences  in  how  Member  States 
interpret,  measure  and  report  data.  Additionally,  turnover  within  key  stakeholders 
impacted  institutional  memory  and  the  continuity  of  information.  To  address  these 
challenges, the study applied triangulation methods and cross-referenced multiple sources. 

2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Description of the ISF-P and its objectives 

The  Internal  Security  Fund  for  the  2014-2020  programming  period  is  a  comprehensive 
financing framework composed of two separate acts setting up the different Instruments of 
the  Fund  and  laying  down  the  objectives,  eligible  actions  and  envelopes  of  each 
component19: 

• Regulation (EU) No 513/2014 setting up, as part of the Fund, the component for police 
co-operation, preventing and combating crime, and crisis management (ISF-P);  

• Regulation (EU) No 515/2014 setting up, as part of the Fund, the border management 
and common visa policy component (ISF-BV). 

18  Regulation  (EU)  2021/1149  of  the  of  the  European  Parliament  and  of  the  Council  of  7  July  2021 
establishing the Internal Security Fund. 
19 COM(2011) 753 final. 

6 

 
 
The  general  objective  of  the  ISF-P  is  to  contribute  to  ensuring  a  high  level  of  security 
within the Union. Within this objective, the Instrument shall contribute to the following 
two specific objectives20:  

‘Specific Objective – fight against crime’:  crime prevention, combating cross-border, 
serious  and  organised  crime  including  terrorism,  and  reinforcing  coordination  and 
cooperation between law enforcement authorities and other national authorities of Member 
States,  including  with  Europol  or  other  relevant  Union  bodies,  and  with  relevant  third 
countries and international organisations 

‘Specific Objective – risk management’: enhancing the capacity of Member States and 
the Union for managing effectively security-related risks and crises and preparing for and 
protecting  people  and  critical  infrastructure  against  terrorist  attacks  and  other  security-
related incidents. 

2.2. Intervention logic 

The Intervention Logic forms the basis of the evaluation framework and shows the overall 
general, specific and operational objectives as well as the expected intermediate results of 
the instrument.  

The intervention logic includes the following components. 

Needs: were established in response to the need to develop an area of freedom, security 
and justice while also effectively addressing crime and terrorism and crisis-related issues 
and increase cooperation and coordination between Member States. 

General objective: these correspond to the overall objective of the ISF-P as expressed in 
its legal basis.  

Specific  Objectives:  the  specific  objectives  reflect  the  intended  outcomes  that  are 
expected through the ISF-P funding. These are essentially the six core policy areas this 
Instrument addresses (see Section 3.1).  

Operational objectives: the ISF-P Regulation sets out seven operational objectives21, i.e. 
the various actions implemented by projects funded and implemented under shared, direct 
and indirect management.  

Inputs:  are  translated  as  the  main  funding  interventions  which  are  divided  into  shared 
management and direct/indirect management. 

Activities: are the direct results/deliverables, which can be reflected in the implemented 
actions22 in the form of, e.g. projects, trainings, acquisition of equipment,  cooperation and 
coordination of law enforcement authorities. 

Outputs:  can  be  identified  in  the  number  of  operations  carried  out  by  enforcement 
authorities across Member States, the number of trained or upskilled people, or the number 
of  communication  activities  such  as  workshops,  conferences  or  the  number  of  EU  and 

20 Articles 3(2)(a) and Article 3(2)(b) of the ISF-P Regulation.  
21 Article 3(3) of the ISF-P Regulation. 
22 Article 4 of the ISF-P Regulation.  

7 

 
 
national  IT  systems  acquired.  The  outputs  are  based  on  the  list  of  common  indicators 
outlined in the Annex II to the ISF-P Regulation.  

Results:  measure  the  intermediate  to  short-term  changes  and  relate  to  the  specific 
objectives of the intervention. The results in the intervention logic correspond to the list of 
common indicators for the measurement of the specific objectives listed in Annex II to the 
ISF-P Regulation and Annex IV(c) and (d) of the Delegated Regulation (EU) 2017/207. 

Expected  intermediate  effects:  are  identified  as  short-term  impacts  derived  by  the 
activities introduced by the ISF-P. They are linked to the results and identified needs.   

8 

 
 
 
 
 
Figure 2 - Intervention Logic of the ISF-P 

9 

 
 
2.3. Points of comparison  

Comparison with ISEC and CIPS 

The main benchmark of comparison for this ex-post evaluation is the performance between 
the  ISF-P  and  its  predecessors,  i.e.  the  two  Specific  Programmes  under  the  General 
Programme on Security and Safeguarding Liberties. The ex-post evaluations of CIPS and 
ISEC (the Programmes)23 and the Impact Assessment accompanying the 2014-2020 Home 
Affairs Funds Regulations proposals (the ‘2011 Impact Assessment’)24 highlighted several 
shortcomings  of  the  Specific  Programmes  design  and  delivery.  The  main  structural 
differences between the ISF-P and its predecessors are the following: 

•  CIPS  was  established  by  Council  Decision  No  2007/124/EC25,  while  ISEC  was 
established  by  Council  Decision  No  2007/125/JHA26.  For  the  2014-2020 
programming period, the ISF-P was established by the ISF-P Regulation, and the 
general provisions applicable to that Regulation were laid down in the Horizontal 
Regulation,  with  the  rationale  to  ensure  a  better  coordination  and  management 
between  the  Home  Affairs  Funds.  The  Commission  Delegated  Regulation  (EU) 
2017/207 sets out the common monitoring and evaluation framework provided for 
in the Horizontal Regulation.  

•  both ISEC and CIPS were exclusively implemented under direct management via 
actions under the 2007-2013 Annual Work Programmes via projects supported by 
Commission  grants,  contracts  for  services  concluded  following  calls  for  tenders 
published  by  the  Commission  or  through  administrative  arrangements  with  the 
Joint  Research  Centre  (JRC).  The  ISF-P  interim  evaluation27  confirms  that  the 
administrative  burden  under  these  Programmes  was  significant  for  both  the 
Commission and the beneficiaries. To allow Member States more equal access to 
funding and improve their participation, a shift towards shared management was 
introduced  for  the  ISF-P,  where  all  three  management  modes  were  applied  (see 
Section 3.1).  

• 

the 2011 Impact Assessment concluded that more flexibility would be needed in 
the area of internal security, as CIPS and ISEC did not cover emergency measures 
in crisis situations where flexibility is key in view that certain events require a quick 
and effective responsive at EU level (e.g. terrorist attacks, large scale cyber-attacks 
and  mass  counterfeiting  of  the  Euro).  The  ISF-P  introduced  the  Emergency 
Assistance (EMAS) which is an emergency response mechanism enabling the EU 
to release funding for the rapid deployment of financial support. 

• 

the ex-post  evaluations  of CIPS and  ISEC  reported that an absence of technical 
assistance budget has negatively affected the effectiveness of the Programmes. To 

23 SWD(2018) 331 final and SWD(2018) 332 final, respectively. 
24 SEC(2011) 1358 final. 
25  Council  Decision  of  12  February  2007  establishing  for  the  period  2007  to  2013,  as  part  of  General 
Programme on Security and Safeguarding Liberties, the Specific Programme Prevention, Preparedness and 
Consequence Management of Terrorism and other Security related risks.  
26  Council  Decision  of  12  February  2007  establishing  for  the  period  2007  to  2013,  as  part  of  General 
Programme on Security and Safeguarding Liberties, the Specific Programme Prevention of and Fight against 
Crime.  
27 SWD(2018) 341 final. 

10 

 
 
 
• 

• 

• 

counter  this  shortcoming,  the  ISF-P  introduced  a  dedicated  technical  assistance 
budget.   

the  2011  Impact  Assessment  identified  that  both  ISEC  and  CIPS  had  complex, 
time-consuming systems which combined a multiannual framework with Annual 
Work  Programmes.  The  high  number  of  annual  programmes  resulted  in  an 
administrative workload for both the Commission and Member States. To increase 
flexibility and establish a more results-oriented approach to shared management, 
the  ISF-P  moved  to  multiannual  programming  and  a  single  seven-year  funding 
cycle thus  removing  the need to  draft annual  programmes and enabling projects 
with longer life-cycles28 (see Section 4.1.3). 

the  2011  Impact  Assessment  identified  operational  limitations  in  the  delivery 
mechanism of the programmes. In response, the ISF-P sought to improve reporting 
by  introducing  common  indicators  and  a  Common  Monitoring  and  Evaluation 
Framework29 to ensure consistent and uniform reporting across Member States. The 
ISF-P  also  introduced  simplified  cost  options  (SCOs)  as  a  means  of  reducing 
administrative burden and improving the efficiency of the Instrument (see Section 
4.1.3). 

the ISF-P benefits from a larger financial allocation compared to its predecessors, 
with an initial total EU contribution of ca. EUR 1 004 million for the 2014-2020 
programming  period  compared  to  ca.  EUR  142.17  million  (CIPS)  and 
EUR 607.36 million (ISEC) for the 2007-2013 programming period. 

3. HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD 

3.1. Overall description of the implementation set-up 

The  ISF-P  is  implemented  under  shared  management,  direct  management  and  indirect 
management. The global resources are implemented through the different components of 
the Instrument: national programmes of the Member States, Union Actions, EMAS and 
technical assistance30.   

Shared management receives the largest share of the global resources, accounting for ca. 
66% of the initial budget allocation. At the beginning of the programming period, Member 
States design their programmes (national programmes) to directly address national and EU 
objectives.  To  implement  their  programmes,  Member  States  have  to  establish  a 
management  and  control  system31.  The  Commission  follows  the  implementation  under 
shared  management  by  examining  the  Annual  Implementation  Reports32  and  accounts 
submitted once a year by the Member States.  

The  share  of  the  budget  managed  by  the  Commission  is  subject  to  Annual  Work 
Programmes which explains how the budget allocated for Union Actions and EMAS will 
be spent. Union Actions, EMAS  and technical assistance are implemented under direct 
and indirect management33 and account for ca. 34% of the initial budget allocation.  

28 COM(2011) 753 final. 
29 Commission Delegated Regulation (EU) 2017/207. 
30 Article 5(3) of the ISF-P Regulation.  
31 Regulation (EU) No 514/2014, Section 2. 
32 Article 54 of the Horizontal Regulation. 
33 Article 5(4) of the ISF-P Regulation.  

11 

 
 
 
Union  Actions  are  transnational  projects  or  actions  of  particular  interest  to  the  Union 
concerning the general, specific and operational objectives of the ISF-P.34 Union Actions 
are implemented under direct and indirect management.  

Emergency Assistance has the aim of strengthening the Union’s capacity to immediately  
react to security-related incidents or newly emerging threats to the Union35. Despite Article 
5(4) of the ISF-P Regulation setting out that EMAS can be implemented under direct and 
indirect management, in practice, all EMAS funded during the 2014-2020 programming 
period have been implemented under direct management.  

Technical Assistance should enable the Member States to support the implementation of 
their national programmes and assist beneficiaries in complying with their obligations and 
the  Union  acquis,  and,  where  appropriate,  cover  the  costs  incurred  by  the  competent 
authorities in third countries36. Technical assistance may be at the initiative of and/or on 
behalf of the Commission and at the initiative of a Member State37.  

3.2. ISF-P Implementation: Financial Progress  

The global resources of the ISF-P was initially EUR 1 004 million, of which: 

•  EUR 662 million for national programmes 
•  EUR 342 million for Union Actions, EMAS and Technical Assistance 

The amount to the national programmes was increased by EUR 92 million owing to a top-
up that took place in 201738. 

Financial progress across components and management modes is presented only in terms 
of EU contribution (national co-financing excluded) 39.  

The total allocated resources amounted to ca. EUR 1 216 million40. This includes shared 
management  (62%)  and  direct/indirect  management  (38%),  which  is  broken  down  into 
Union Actions (action grants and procurement), EMAS, and other actions, which include 
administrative arrangements with the JRC and or procurements by the Directorate-General 
for Digital Services (DIGIT) and the Statistical Office of the European Union (Eurostat) 
under cross-delegated ISF-P funds.  

34 Article 8(1) of the ISF-P Regulation. 
35 Recital (28) of the ISF-P Regulation.  
36 Recital (14) of the Horizontal Regulation.  
37 Articles 9(1) and 9(2) of the ISF-P Regulation.  
38 An additional sum of EUR 70 million was added to support the Implementation Plan for Directive (EU) 
2016/68138 on the use of passenger name record (PNR) data, the so-called ‘PNR top-up’, and EUR 22 million 
was directed at the development of information exchange and interoperability tools. DB2021. 
39 Through this document, the following terminology is used when it comes to financial progress: 
Allocated resources correspond to the resources that have been designated to each  Specific Objective and 
each Member State. They represent the programming stage of the ISF-P. 
Committed resources represent, in broad terms, the commitment of resources to the beneficiaries, i.e. to those 
responsible  for  initiating/  implementing  the  operations.  In  shared  management,  this  corresponds  to  the 
eligible cost of operations that have been selected for support by the Responsible Authorities. For direct and 
indirect  management,  it  corresponds  to  the  value  of  grants,  contracts  or  agreements  with  beneficiaries, 
contractors and partner entities. 
40 The amount of EUR 1 216 million is calculated as the sum of the shared management allocations, based 
on  the  latest  national  programmes  adopted  and  shared  with  the  consortium  by  the  Commission;  and 
direct  and  indirect  management  allocations,  derived  from  the  sum  of  the  latest  revised  Annual  Work 
Programmes. 

12 

 
 
 
Figure 3 - Total allocation of the ISF-P 

1,2%

0,7% 0,8%

9,6%

38%

26%

62%

61,6%

Shared management

Direct/ Indirect management

Action Grants

Procurement

Other

Indirect Management

EMAS

Source: Annual Work Programmes and National Programmes 

At the level of the ISF-P, 77.3% have been disbursed by the Commission.  

Under shared management, 88.7% of resources have already been paid to Member States. 
However, as closure of the national programmes is ongoing, this percentage is expected to 
rise and could virtually reach 100% once the process is complete.  

In turn, under direct and indirect management, only 59% of the total resources have been 
paid. It should be noted that the relatively lower percentage under direct management may 
partially  result  from  differences  in  reporting  timelines  and  the  availability  of  the  most 
recent data – thus, the financial progress may likely be higher than currently reflected.    

13 

 
 
Figure  4  -  Financial  Progress  of  the  ISF-P:  Distribution  of  Allocated,  Committed  and  Paid 
Resources by Management Mode in EUR 

72.965.254
(6%)

202.691.846
(16,7%)

42.489.230
(5,7%)
42.466.749
(5,7%)

941.257.016
(77,3%)

666.607.729
(88,7%)

30.476.024
(5,2%)

160.225.097
(27,6%)

389.407.070
(67,1%)

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

ISF-P

Shared Management

Direct/Indirect Management

Paid

Committed not yet paid

Allocated not paid nor committed

Source: Preparatory study  

Implementation under shared management 

Figure  5  indicates  strong  financial  progress  under  shared  management,  with  ‘Specific 
Objective  –  fight  against  crime’  and  ‘Specific  Objective  –  risk  management’ 
demonstrating implementation rates (the proportion of resources committed compared to 
the resources allocated) of 95.8% and 104%, respectively. An implementation rate over 
100%  suggests  that  commitments  surpassed  initially  planned  allocations,  which  may 
occur where Member States committed to operations above the initial funding ceilings 
by using additional national resources to cover the expenses.  

to 

In turn, the financial implementation rate for technical assistance is slightly lower at 80%, 
possibly  due 
limited  administrative  capacity.  The  comparatively  higher 
implementation rate for ‘Specific Objective – fight against crime’ and ‘Specific Objective 
– risk management’  suggests that technical  assistance may not  have been treated as a 
priority by Member States. 

14 

 
 
Figure 5 - Implementation rate per Specific Objective under shared management 

e
l
t
i
T
s
i
x
A

100%

80%

60%

40%

20%

0%

95,8%

104%

80%

Fight against crime                    Risk Management                    Technical Assistance

Committed

Allocated not committed

Source: Preparatory study based on SFC2014 data as of 10 February 2025 

The  policy  field  with  the  highest  amount  of  paid  resources  (ca.  EUR  218  million)  is 
counter-terrorism (incl. measures to prevent radicalisation and safeguard public spaces and 
critical infrastructure), followed by preventing and combating organised crime (ca. EUR 
170 million) and information exchange (ca. EUR 164 million).  

Certain initiatives did not fully align to a specific policy field and were thus categorised 
under “other actions”, and include measures such as victim support or the acquisition of 
specialised equipment (EUR 30 million).  

Figure 6 - Allocation of paid resources by policy field in shared management 

Counter-terrorism, including prevention of radicalisation, protection
of public spaces, critical infrastructure/entities

Organised crime (including drugs trafficking, THB, firearms
trafficking, migrant smuggling, corruption, money laundering)

Information exchange

218

171

164

Cybercrime, including Child Sexual Abuse

65

Law enforcement cooperation

50

Technical assistance

31

Other

30

EUR  0

EUR  100

EUR  200

Millions

Source: Preparatory study based on SFC2014 data as of 15 March 2025 

15 

 
 
 
 
s
n
o

i
l
l
i

M

Implementation at the national programme level 

Within shared management, the largest Member States (Germany, France, Italy and Spain) 
show the highest amount of allocated resources (39% of the total).  

Figure 7 - Total allocated resources by Member State (EUR in millions) 

100

90

80

70

60

50

40

30

20

10

0

DE FR

IT

ES PL RO BG NL SE HU GR HR PT BE CZ LV

LT

FI

SK EE AT

SI

IE MT CY

LU

Source: Preparatory study based on the most recent national programmes (10 February 2025). 

National  programmes  show  significant  differences  in  prioritisation41  to  ‘Specific 
Objective – fight against crime’ and ‘Specific Objective – risk management’.  

For ‘Specific Objective – fight against crime’, the allocated EU average is 74.6%, and it 
was  prioritised  by  all  Member  States  (Luxembourg  excepted).  Ireland  (91.1%),  Malta 
(88.7%), and Czechia (87.5%) show the highest level of prioritisation.  

For  ‘Specific  Objective  –  risk  management’,  the  allocated  average  is  20.6%.  Ireland 
(2.1%), Malta (5.9%) and Czechia (6.5%) each allocated under the minimum threshold of 
10%42, while Croatia (10%), Slovenia (10.3%), Belgium (10.5%), Lithuania (11.4%), and 
Germany (11.6%) barely met or slightly exceeded this threshold. 

By contrast, technical assistance, was distributed quite evenly across the Member States 
with an average of 4.8%, with only five Member States exceeding 6% (IE, FI, SK, AT and 
CY). Despite some Member States exceeding the 5% threshold, the committed amounts 
remain below the legal ceiling of 5% of total allocation plus EUR 200 000.     

41  It  should  be  noted  that  the  level  of  prioritisation  of  the  ISF-P  to  a  certain  Specific  Objective  is 
complementary to the policy fields/objectives prioritised by national budgets.    
42 Article 5(6)(b) of the ISF-P Regulation.  

16 

 
 
 
Figure 8 - Distribution of ISF-P allocated resources by Specific Objective across Member States 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Fight against 
crime 

 SO-5

Risk 
management 

SO-6

Technical 
Assistance 

TA

Source: Preparatory study on the national programmes 

In terms of the instruments’ effective implementation, several participating Member States 
have very high absorption rates43.  

The majority of the Member States (20) have absorption rates over 95%, and only three 
Member  States  remain  below  90%,  i.e.  Belgium  (77.5%),  France  (84.5%)  and  Austria 
(85%).  

Cyprus, Romania, Malta and Hungary have absorption rates over 100%, i.e. these member 
States committed to operations above the initial funding ceilings, using additional national 
resources to cover the expenses.  

43  The  proportion  of  resources  paid  by  the  Commission  to  the  Member  State  compared  to  the  initial 
allocations per Member State. 

17 

 
 
 
 
 
 
 
 
Figure 9 - Absorption rate per Member State 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

BE FR AT BG DE SE SK CZ IE GR PT FI HR LV EE PL NL SI

IT LT ES LU CY RO MT HU

Declared

Allocated but not declared

Source: Preparatory study based on SFC2014 data of 10 February 2025 

Implementation under Direct and Indirect Management  

Of the ca. EUR 465.3 million allocated under direct and indirect management, 68% was 
channelled  to  action  grants  (EUR  315  million),  ca.  25%  to  procurement  (EUR  117.2 
million), ca. 3% to indirect management (EUR 14.6 million), ca. 2% to EMAS (EUR 8.5 
million) and ca. 2% to Other Actions (ca. EUR 10 million).   

Figure 10 - Distribution of Allocations under Direct and Indirect Management (in millions of 
EUR) 

s
n
o

i
l
l
i

M

300

250

200

150

100

50

0

315,0

117,2

14,6

8,5

10,1

Action Grants

Procurement

Indirect
Management

EMAS

Other

Source: Preparatory study based on the most recent Annual Work Programmes, as per 10 February 2025 

18 

 
 
 
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-P has achieved its 
objectives and provides a basis for judging the role of EU action in driving the observed 
changes. The analysis identifies the extent of the success as well as the factors contributing 
to its lack or delay. Furthermore, it examined the factors driving and hindering progress 
and examined how they are linked to the ISF-P. 

How did  the Instrument  contribute to  the achievement  of  the  ‘Specific  Objective  - fight 
against crime’? 

The ISF-P contributed to ‘Specific Objective – fight against crime’ by enhancing Member 
States’  capabilities  to  combat  cross-border,  serious  and  organised  crime,  including 
terrorism, through investments in modernising law enforcement tools, intelligence sharing, 
and  cross-border  operational  projects  such  as  joint  investigations  and  training.  It  also 
reinforced cooperation between national authorities, Europol, and international partners by 
supporting IT interoperability, data exchange (e.g. Passenger Name Record systems), and 
liaison structures.  

At EU level, the combined indicator target values for most ‘Specific Objective – fight 
against crime’ indicators (excepting those on training) were achieved.  

At national level, depending on the indicator in question, between 5 and 13 Member States 
did not achieve their targets (see Table 3). Nevertheless, the national ex-post evaluation 
reports, and the qualitative input via surveys, public consultation, and interviews largely 
support  the  conclusion  that  the  ISF-P  positively  advanced  ‘Specific  Objective  –  fight 
against crime’.  

There  were  251  actions  under  this  Specific  Objective  in  the  2014-2020  programming 
period. The planning of the actions largely started on time with ca. 60% of them having 
already been  planned in  the first  two years of the programming  period (149 out  of 251 
actions). Implementation also started promptly, with ca. 80% of actions starting between 
2014 and 2017. Closing of actions took more time, as only ca. 16% of the actions were 
closed in the 2014-2019 period. Closure of the actions increased in 2020, but dropped in 
2021, likely due to the COVID-19 pandemic. More than 50% of the actions were closed in 
2022-2023.   

19 

 
Figure 11  – Timelines for Specific Objective – fight against crime 

87

71

0
2015

62

19

5

2014

64

25

7

56

46

3

53

9
7

29

27

12
9

17
14

2

2016

2017

2018

2019

2020

2021

79

49

1
2022

2023

Start of planning

Start of implementation

Start of closing

Source: Preparatory study based on the submitted Final Implementation Reports 

Table 1 presents the distribution of actions per national objective (NO). Member States 
prioritised actions under the objectives  ‘Prevention and combating cross-border, serious 
and organised crime, including terrorism’ and ‘Exchange of information’ (each NO with 
72 actions) and all of them (Luxembourg excepted44) had actions under both these NOs. 
Actions on training were also numerous (55) with only three Member States not reporting 
NOs  (Latvia,  Luxembourg,  and  Malta).  ‘Victim  support’  (20  MS)  and  ‘Threat  and  risk 
assessment’ (11 MS) had the least number of actions.  

Member States with the highest number of actions under ‘Specific Objective – fight against 
crime’ were Hungary (15), Croatia (14) and Spain/Sweden (13), while Luxembourg (3) 
and Latvia (5) had the lowest number of actions. On average, Member States had over 9 
actions under this Specific Objective.   

Table 1 - Specific Objective – fight against crime: Number of actions per national objective 

National objective 

Number of actions 

Percentage45 

NO1 - C - prevention and combating cross-border, 
serious and organised crime, including terrorism 
NO2 - C - exchange of information 

NO3 - C – training 

NO4 - C - victim support 

NO5 - C - threat and risk assessment 

Total 

72 

72 

55 

32 

20 

251 

29% 

29% 

22% 

13% 

8% 

100% 

Source: Preparatory study based on the submitted Financial Implementation Reports 

44 Luxembourg only reported actions under ‘exchange of information’ (NO2). 
45 Some of these percentages have been rounded up. 

20 

 
 
 
Table 2 – Specific Objective – fight against crime: Achievement per main indicator 

Summary Indicators 

Target 

Achieved 

% achievement 

C2.1.a - 
Terrorism 

C2.1.b - THB 
and  sexual 
exploitation of 
women and 
children 

C2.1.c - Illicit 
drug 
trafficking 

C2.1.d - Illicit 
arms 
trafficking 

C2.1.e - 
Money 
laundering 

C2.1.f - 
Corruption 

C2.1.g - 
Counterfeiting of 
means of payment 

C2.1.h - 
Computer 
crime 

C2.1.i - 
Organised 
crime 

                      375  

174% 

                91 969  

72% 

15.6%46 

5.0% 

20.9% 

0.3% 

1.7% 

7.4% 

0.3% 

7.2% 

22.8% 

              183 650  

93% 

                      536  

 415 936 901  

                      160  

6.4%47 

24% 

31% 

143% 

160% 

120% 

2.8% 

2.2% 

0.1% 

11.2% 

5.0% 

0.1% 

14.4% 

31.3% 

7% 

2% 

9% 

4% 

2% 

2% 

6% 

5% 

4% 

2% 

1% 

0% 

10% 

13% 

37% 

41% 

216  

128 110  

198 075  

375  
260 436 8
36  

134  

C1 - Number of joint investigation 
teams and EMPACT operational 
projects supported by the Fund, 
including the participating 
Member States and authorities 
C2.1 - Number of law enforcement 
officials trained on cross-border-
related topics with the help of the 
Fund 
C2.2 - Duration of the training 
(carried out) on cross-border 
related topics with the help of the 
Instrument (person days) 
C3.1 - Number of projects in the 
area of crime prevention 
C3.2 - Financial value of projects 
in the area of crime prevention 
C4 - Number of projects supported 
by the Fund, aiming to improve 
law enforcement information 
exchanges which are related to 
Europol data systems, repositories 
or communication tools (e.g. data 
loaders, extending access to 
SIENA, projects aiming to 
improving input to analysis work 
files etc.) 

Source: Preparatory study based on the submitted Final Implementation Reports 

The combined indicator target values for most ‘Specific Objective – fight against crime’ indicators were achieved. The number of joint investigation teams (JITs) and EMPACT projects, the number/value of projects in the 
area of crime prevention, and in aiming to improve law enforcement information exchanges were all overachieved. The indicators related to the number of law enforcement officials trained on cross-border-related topics and the 
duration of the training were not achieved. Nevertheless, the number of law enforcement officials trained is significant, i.e. more than 90 000. 

The areas most prioritised across Member States are organised crime and terrorism (see Table 2). In terms of number of law enforcement officials trained, illicit drug trafficking were also a key area (ca. 21%). As to the number 
of projects and financial value of projects in crime prevention, the third most prominent area (after terrorism and organised crime) was computer crime. The least prioritised areas were counterfeiting of means of payment and 
illicit arms trafficking. 

46 The values for this indicator do not sum to 100% because there is also disaggregation according to: C2.1.j - Area of law enforcement: information exchange and C2.1.k - Area of law enforcement: operational cooperation 
47 Idem 

21 

 
 
                     
 
 
 
 
 
 
 
 
 
            
            
                     
                     
 
 
 
 
 
 
 
 
 
 
The analysis at Member State level shows a more nuanced picture (see Table 3):  

•  While the general values show overachievement  for most indicators, at  Member 
State  level,  many  Member  States  did  not  manage  to  meet  their  targets  per 
indicator. The lowest percentage of achievement is for the indicator ‘Number of 
JITs and EMPACT operational projects supported by the Fund’ (35%).  

•  Only 11 Member States reported achievements on the indicator ‘Number of JITs 
and  EMPACT  operational  projects  supported  by  the  Fund’,  while  20  Member 
States had envisaged target values. This shows that despite the high percentage of 
overall achievement, the number of JITs and EMPACT projects was much lower 
than planned.  

•  The highest percentage of achievement was for indicator ‘Number of projects in 
the  area  of  crime  prevention’  (80%),  for  which  all  Member  States  had  planned 
values and reported achievements of this indicator. 

•  There are considerable discrepancies between target and achieved values, i.e. 
there are several cases of overachievement of these target values, at times showing 
achievement of several thousand per cent. 

• 

Inconsistent reporting of the sub-indicators: for instance, for indicator C1 some 
Member States added the sub-indicators when providing the overall value (Austria, 
Bulgaria, Slovenia and Slovakia) while others did not (Germany and Finland). 

Table 3 - Specific Objective – fight against crime: Comments per indicator 

Specific Objective – 
fight against crime:  
Summary Indicators 
C1  -  Number  of  JITs 
and 
EMPACT 
projects 
operational 
supported by the Fund, 
including 
the 
participating  Member 
States and authorities 

Comment 

11 Member States reported values (excluding zeros), while 20 Member States 
had envisaged target values.  

7 Member States achieved their targets (AT, BG, DE, FI, LT, LV, RO), while 
13 Member States did not (BE, CY, CY, CZ, ES, FR, HR, HU, IE, IT, PT, SE, 
SL), i.e. ca. 35% of Member States achieved their targets. 

The percentage of achievement varies significantly (from 0 to almost 2 000%). 

Austria and Germany reported 138 projects each (much higher than the planned 
values of 7 and 8, respectively). 

Romania  reported  the  highest  number  of  projects  as  a  leader  (36  out  of  36), 
followed by Germany (14 out of 138). 

C2.1  -  Number  of  law 
enforcement 
officials 
trained on cross-border-
related  topics  with  the 
help of the Fund 

22 Member States reported values (excluding zeros), while 24 Member States 
had envisaged target values. 

14 Member States achieved their targets (BG, CY, DE, EE, FI, HU, IE, LT, PL, 
PT, RO, SE, SK, SL), while 10 did not (AT, BE, EL, ES, FR, HR, IT, LT, LV, 
NL) 48, i.e. ca. 58% of Member States achieved their targets. 

The percentage of achievement varies significantly (from 0 to above 1 000%). 

48 While its target was 0, Czechia reported 703 trained staff. 

22 

 
 
 
The highest number of staff trained was in Romania, Hungary and Poland. 

C2.2  -  Duration  of  the 
training (carried out) on 
cross-border 
related 
topics  with  the  help  of 
the  Instrument  (person 
days) 

21 Member States reported values (excluding zeros), while 23 had  envisaged 
target values. 

13 Member States (BG, DE, EE, EL, ES, FR, HU, IT, LT, PL, RO, SE, SK) 
achieved their targets, while 10 Member States did not (AT, BE, CY, HR, IE, 
LU, LV, NL, PT, SL)49, i.e. ca. 57% of countries achieved their targets. 

C3.1 
-  Number  of 
projects  in  the  area  of 
crime prevention 

The  percentage  of  achievement  varies  significantly  (from  0  to  above 
34,000%50). 

The  highest  number  of  person  days  was  reported  by  Poland,  Slovenia,  and 
France. 

This indicator shows the best proximity between planning and achievements. 

25  Member  States  reported  values  (no  zeros),  while  25  Member  States  had 
envisaged target values (excluding LU). 

20 Member States achieved their targets, while 5 Member States did not (CY, 
EL, IT, PT, SI), i.e. 80% of Member States achieved their targets. 

The percentage of achievement varies (from 40% to above 800%). 

The highest number of projects was reported by Germany (61), Lithuania (56), 
and Spain (50). 

C3.2  -  Financial  value 
of projects in the area of 
crime prevention 

25  Member  States  reported  values  (no  zeros),  while  25  Member  States  had 
envisaged target values (excluding LU). 

18 Member States achieved their targets, while 7 Member States did not (AT, 
CY, CZ, IT, NL, PT, SI), i.e. 72% of countries achieved their targets. 

The percentage of achievement varies (from 2% to above 2,000%). 

The  highest  values  of  projects  was  reported  by ES  (ca.  EUR  70  million), IT 
(over EUR 47 million), and DE (ca. EUR 40 million). 

20 Member States reported values (excluding zeros), while 22 Member States 
had envisaged target values. 

12  Member  States  (AT,  BE,  DE,  EL,  FI,  FR,  HU,  LV,  PL,  RO,  SE,  SK) 
achieved their targets, while 10 did not (BG, CY, ES, HR, IE, IT, LT, MT, PT, 
SI), i.e. ca. 55% of Member States achieved their targets. 

The percentage of achievement varies significantly (from 0 to 1,000%). 

The majority of projects had the objective of improving input to analysis work 
files (73 projects in 15 Member States), followed by data loaders (44 projects 
in 11 Member States) and extending access to SIENA (20 projects in 9 Member 
States). 

C4 
of 
-  Number 
projects  supported  by 
to 
the  Fund,  aiming 
law 
improve 
enforcement 
information  exchanges 
which  are  related  to 
Europol  data  systems, 
repositories 
or 
communication tools  

Source: Preparatory study 

Member States reported that cases of underachievement of some target values were due to 
procurement delays and the COVID-19 pandemic (particularly concerning indicators on 
training). Nonetheless, transitioning traditional in-person meetings to virtual meetings led 

49 While their target was 0, Czechia reported 2,974 and Finland – 7,158 person days. 
50 For this particular case,  Greece  reported the following in SFC 2014 “it is noted that indicator C2.2 of 
Specific  Objective  –  fight  against  crime  is  reflected  in  seminar  hours  and  not  in  man-days”,  which  can 
partially explain the very high overachievement.  

23 

 
 
 
to the overachievement of the number/duration of training sessions in some Member States 
(e.g. Hungary and Italy). 

The  ISF-P  significantly  contributed  to  strengthening  Member  States’  capacities  in 
crime  prevention,  combating  cross-border,  serious  and  organised  crime,  including 
terrorism, and reinforcing cooperation between Member States.  

The  national  ex-post  evaluation  reports  evidence  that  the  ISF-P  has  contributed  to  the 
operational objectives51 by: 

•  modernising law enforcement capabilities, enhancing intelligence sharing, and 
improving  IT  infrastructure.  Examples  of  such  projects  include:  a  Rapid 
Response  Mechanism  to  combat  smuggling  (Austria);  expansion  of  the  Police 
Information and Analysis Network (PIAV) to tackle organised crime (Germany); 
and improvements in biometric data sharing and surveillance through projects like 
Prüm (Fingerprints),52 the National Surveillance Unit (Ireland); the development 
of  an  advanced  Passenger  Name  Record  (PNR)  system  to  track  airline  data  for 
terrorism  prevention  (Sweden);  and  the  upgrading  of  forensic  databases  and  IT 
systems to enhance cross-border investigations (Bulgaria). 

•  significant progress in enhancing administrative and operational coordination 
among Member States’ public authorities, Europol, with third countries and 
international  organisations  by  supporting  projects  advancing  information 
exchange,  law  enforcement  capabilities,  and  cross-border  cooperation.  Member 
States focused on IT system development to ensure seamless interoperability with 
EU information-sharing networks (DE, EE and NL) and strengthened cooperation 
through  PNR  systems  and  data  exchange  mechanisms  with  Europol  and  other 
partners  (FI,  IE  and  SE).  The  ISF-P  also  supported  operational  activities  (joint 
investigations  and  training  programmes),  such  as  initiatives  that  fostered 
collaboration  in  combating  organised  crime  and  smuggling  (AT,  BE,  SI); 
prioritizing cross-border law enforcement training and international coordination 
of  investigations  on  anti-corruption  and  financial  crime  (BG  and  CY);  and 
modernizing  police  operations  and  enhancing  cooperation  with  third  countries 
through liaison officers and joint operational centres (CZ and SK).  

• 

the  development  of  training  schemes  aimed  at  enhancing  technical  and 
professional skills and knowledge of human rights and fundamental freedoms 
across  various  Member  States.  Many  Member  States  implemented  law 
enforcement training programmes, focusing on anti-corruption, cross-border crime 
prevention,  cybercrime,  and  prevention  of  trafficking  in  human  bring.  Austria, 
Belgium,  and  Bulgaria  prioritised  specialised  training  on  organised  crime,  anti-
corruption  measures,  and  undercover  operations,  ensuring  law  enforcement 
officials  were equipped  with  both  theoretical  and operational  skills. Finland and 
Slovakia  focused  on  cybercrime  and  forensic  sciences,  with  Finland’s  Police 
University  College  running  multiple  cybercrime-related  training  initiatives.  The 
Netherlands  and  Cyprus  implemented  the  Law  Enforcement  Training  Scheme 
(LETS) focusing on international and intercultural competencies, while Estonia and 

51 Article 3(3)(a) to (d) of the ISF-P Regulation.  
52 PR/0002 – the Prüm (Fingerprints) project. 

24 

 
 
Czechia  developed  exchange  programmes  and  conduct  international  missions  to 
enhance knowledge-sharing.  

• 

the  development  of  measures,  safeguard  mechanisms,  and  best  practices  for  the 
identification,  protection  and  support  of  witnesses  and  victims  of  crime53. 
Several  Member  States  created  specialised  victim  support  services,  awareness 
raising  and  improved  facilities  and  technical  capabilities  for  victim  protection. 
These  measures  included:  witness/victim  protection  programme  exceeded  its 
targets (Austria), awareness raising campaign, which was coherent and supported 
the  state-coordinated  victim  support  service  and  a  human  trafficking  advisory 
hotline  (Estonia);  anti-trafficking 
launched 
educational  projects  and  Ireland  improved  victim  identification  through  data 
collection systems. Several Member States used ISF-P funds to improve facilities 
and technical capabilities for victim protection.  

initiatives  by  which  Finland 

Survey results (Figure 12) – comprising responses from all types of stakeholders, incl. 
beneficiaries of projects funded under national programmes and Union Actions) – found 
that increased knowledge and skills of training participants in crime prevention/forensics 
(78%)54 and growing stakeholder involvement in information sharing and data collection 
(74%) were seen as effective.  

On  the  other  hand,  preparedness  for  monitoring  witnesses  and  victims  of  crime  (41%), 
increased number of protected or assisted crime victims (42%), increased number of JITS 
and  EMPACT  operations  (44%)  were  rated  lower  in  perceived  effectiveness.  Notably, 
these categories also had higher percentages of respondents who answered ‘Don't know’ 
(ranging from 23% to 35%), suggesting some uncertainty about their impact. 

53 The extent of the implementation of this operational objective was considered lowered when compared to 
that of other operational objectives under Specific Objective – fight against crime.  
54 Combined % of “to a large extent” and “to some extent”. 

25 

 
 
Figure 12 - Stakeholder answers to the question: ‘To what extent have the funded actions resulted 
in  the  following  outcomes,  which  strengthened  your  country’s  capacities  in  preventing  and 
combating cross-border, serious and organised crime, including terrorism? 

 Increased knowledge and skills of training participants in
the area of crime prevention/forensic field (e.g. use of
systems of data extraction)

Growing number of stakeholders involved in the sharing of
information, study and data collection

 Improved sophistication of vigilance tools, improved
routines and recommended method support in response
to crime events

Harmonised practices and validation protocols required
(e.g. under Prüm, SIENA, EIS, PNR, SIS)

43%

41%

35%

4%

17%

33%

11%

2%

13%

32%

30%

12%

2%

23%

37%

23%

6%

3%

31%

 Increased number of JITS and EMPACT operations

21%

23%

10%

5%

40%

Increased number of protected or assisted crime victims

16%

26%

16%

5%

35%

 Improved preparedness and conditions that allow
effective monitoring of witnesses and victims of crimes,
aiming to increase their safety, protection and support

17%

24%

17%

6%

36%

0%

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

To a large extent

To some extent

To a limited extent

Not at all

Don't know

Source: Preparatory study based on the stakeholder survey 

Interviewees  noted  that  the  funded  actions  have  contributed  to  prevent  cross-border, 
serious  and  organised  crime  and  reinforce  coordination  among  law  enforcement 
authorities. Various projects have enhanced investigative capabilities, such as targeting car 
theft  networks  and  the  PNR  system  for  tracking  terrorist  movements.  Investments  in 
cybersecurity, forensic services, and specialised equipment, incl. explosive disposal robots 
and canine units, have strengthened crime prevention and counter-terrorism efforts.  

According  to  interviewees,  cross-border  cooperation  was  facilitated  through  JITs  and 
EMPACT operations, and secure data exchange systems like the ‘Explosives Control and 
Protection System to Prevent and Fight against Terrorism’ (SCEPYLT). 

Public  consultation  results  (Figure  13)  are  also  generally  positive  concerning  the 
effectiveness of the ISF-P, particularly on its contribution to prevent and fight organised 
crime  (21  responses  ‘to  a  large  extent’  out  of  34)  and  to  enhance  cross-border  law 
enforcement cooperation (20 responses ‘to a large extent’ out of 33).  

Nonetheless,  participants  in  the  public  consultation  were  less  positive  about  the 
contribution  of  the  ISF-P  towards  fighting  corruption  and  money  laundering  (8  and  9 
responses, respectively ‘to a large extent’ out of 32). 

26 

 
 
Figure  13 -  Stakeholder  answers to the question: ‘To  what extent  do  you  agree  that the ISF-P 
contributed to…’ 

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

Preventing and fighting organised crime

The enhancement of cross-border law enforcement
cooperation

Preventing and fighting cybercrime and sexual
exploitation of children

Preventing and fighting drug trafficking

Preventing and fighting terrorism and radicalisation

Preventing and fighting trafficking in human beings and
migrant smuggling

The protection of critical infrastructures and public spaces

Preventing and fighting money laundering

Preventing and fighting corruption

Preventing and fighting trafficking of firearms

21

20

9

7

2

2

9

8

9

1

2

7

4

4

8

3

11

10

4

2

11

3

4

4

7

7

10

9

11

9

10

10

15

13

12

11

10

9

8

8

To a large extent

To some extent

To a limited extent

Not at all

I don't know

Source: Preparatory study based on the public consultation 

How  did  the  Instrument  contribute  to  the  achievement  of  ‘Specific  Objective  -  risk 
management’? 

The ISF-P contributed to ‘Specific Objective – risk management’ by enhancing the 
Member  States’  capacity  to  manage  security-related  risks  and  crises  through 
investments in crisis management centres, early warning systems, and protection of critical 
infrastructure, including advancements in cybersecurity and CBRN-E threat responses.  

Most indicator targets were overachieved, notably with over 1 200 tools implemented 
for  infrastructure  protection  and  more  than  3 700  expert  events  organised.  Similarly  to 
‘Specific  Objective  –  fight  against  crime’,  the  national  ex-post  evaluation  reports  and 
stakeholder  feedback  confirm  improved  administrative  and  operational  preparedness, 
inter-agency coordination, and enhanced skills of competent authorities across the EU.  

There were 204 actions under ‘Specific Objective – risk management’ in the 2014-2020 
programming period. Similarly to ‘Specific Objective – fight against crime’ timelines, the 
planning of the actions started on time with ca. 62% of them having been planned in the 
first two years of the programming period (126).  

Implementation  started  somewhat  slower  than  for  ‘Specific  Objective  –  fight  against 
crime’, with ca. 69% of actions starting between 2014 and 2017. Closing of actions also 
took  more  time,  as  only  ca.  20%  of  the  actions  were  closed  in  the  2014-2019  period. 
Closure of actions was equally high in 2020 and 2022 (ca. 50%), with a significant drop in 
2021 (largely due to the pandemic). More than 40% of the actions were closed in 2022-
2023.   

27 

 
 
Figure 14 - Timelines of Specific Objective – risk management 

86

43

40

14

11

46

39

3

38

14

6

21

18

10

39

11

4

50

50

38

25

5

2014

2015

2016

2017

2018

2019

2020

2021

1
2022

2023

Start of planning

Start of implementation

Start of closing

Source: Preparatory study based on the submitted Final Implementation Reports 

The distribution of actions per national objective was more balanced, with ‘Prevention and 
combating’ (20 MS) and ‘Infrastructure’ (19 MS) being the most numerous actions (42 
actions each), followed by ‘Training’ (19 MS) with 39 actions. ‘Exchange of information’ 
was much less prominent under ‘Specific Objective – risk management’ with 20 actions.  

Member  States  with  the  highest  number  of  actions  under  this  Specific  Objective  were 
Portugal  (17),  Croatia  (16)  and  Spain  (15),  while  Ireland  (1),  Luxembourg  (2)  and 
Germany (2) had the lowest number of actions. On average, Member States had close to 8 
actions under ‘Specific Objective – risk management’.   

Table 4 -  ‘Specific Objective – risk management’: Number of actions per national objective 

National objective 

Number of actions 

Percentage55 

NO1 - R - prevention and combating 

NO2 - R - exchange of information 

NO3 - R - training 

NO4 - R - victim support 

NO5 - R - infrastructure 

NO6 - R - early warning and crisis 

NO7 - R - threat and risk assessment 
Total 

42 

20 

39 

8 

42 

30 

23 
204 

21% 

10% 

19% 

4% 

21% 

15% 

11% 
100% 

Source: Preparatory study based on the submitted Final Implementation Reports 

The combined indicator target values for this Specific Objective were achieved (see Table 
5). The target for the ‘number of tools to facilitate the protection of critical infrastructure 
by Member States’ was overachieved more than twice.  

55 Some of these percentages have been rounded up.  

28 

 
 
 
At  national  level,  almost  all  Member  States  reported  values  for  this  indicator,  with  the 
exception  of  Belgium  (0,  even  if  5  tools  were  planned),  Ireland  and  Luxembourg  (no 
targets and no reporting). Only six out of the 24 Member States did not achieve the targets. 
It  should  be  noted  that  targets  and  reported  achievements  vary  significantly  between 
Member States – from 2 (Austria, Germany and Malta) to 433 (Hungary) – which is likely 
due to a different understanding of what “tools” precisely entail/comprise.  

The  number  of  projects  relating  to  the  assessment  and  management  of  risks  in 
internal security was largely in line with what Member States’ envisaged. Twenty-two 
Member States reported achieved values for this indicator, even if only 20 of them had 
envisaged target values. Thirteen Member States achieved their targets, while 7 did not. 
The level of variation is lower between Member States when compared to other indicators, 
as the number of projects is not an indicator prone to misinterpretation. 

The  number  of  expert  meetings,  workshops,  seminars,  conferences,  publications, 
websites and (online) consultations was overachieved more than 4 times, with most of 
these  events  being  related  to  critical  infrastructure  protection  (2 780),  while  700  were 
dedicated to crisis and risk management56. Twenty-three Member States reported values 
for  this  indicator  (different  from  0),  while  24  had  envisaged  target  values.  Seventeen 
Member States achieved or were very close57 to achieve their target values. The achieved 
values vary significantly between Member States with some reporting in the hundreds and 
thousands (AT, DE, FI, PL, RO), while others reported double-digit numbers. To a large 
extent, the disparity can be attributed to a different understanding of what this indicator 
entails, but also due to its “catch-all” characteristics (it combines many different project 
outputs). 

Table 5 - Specific Objective – risk management: Achievement per main indicator 

Indicator 

C1 - Number of tools put in place or upgraded with the 
help  of  the  Instrument  to  facilitate  the  protection  of 
critical infrastructure by Member States in all sectors of 
the economy 
C2 - Number of projects relating to the assessment and 
management  of  risks  in  the  field  of  internal  security 
supported by the Fund 
C3 - Number of expert meetings, workshops, seminars, 
(online) 
conferences,  publications,  websites  and 
consultations organised with the help of the Fund 

Target 
value 

478 

Cumulative 
value 
1 216.56 

% 
achievement 
255% 

109 

129.1 

118% 

893 

3759 

421% 

Source: Preparatory study based on the submitted Final Implementation Reports 

At Member State level, the most frequently reported reasons for the underachievement of 
some  target  values  were  the  restrictive  measures  imposed  by  the  COVID-19  pandemic 
(particularly concerning face-to-face events). At the same time, only a few explanations 
for the deviations actually explained the reasons for the under or overachievement beyond 
just  stating  the  percentage  deviation  (e.g.  Germany  and  Greece).  As  concerns 
underachievement,  Austria  reported  that  the  original  target  figures  were  probably 

56 These events do not sum to 3,759 likely due to insufficient granularity of reporting. 
57 Croatia and Greece with 95% achievement each. 

29 

 
 
too  optimistically,  while  Poland  offered 

estimated 
the  opposite  argument  for 
overachievement - the planned target values were (too) low in retrospect  due to lack of 
practical experience and inconclusive basis in the context of data collection.  

The Final Implementation Reports show that the ISF-P implementation under ‘Specific 
Objective  –  risk  management’  contributed  to  enhancing  crisis  and  risk  management 
capabilities  of  the  Member  States.  Key  achievements  include  the  establishment  and 
modernization  of  crisis  management  centres, 
improved  protection  of  critical 
infrastructures, advancements in cybersecurity, and the development of systems to counter 
CBRN-E  threats.  Despite  challenges  such  as  procurement  delays  and  COVID-19 
disruptions, Member States reported that most projects met their objectives. 

The national  ex-post evaluation reports evidence the same findings and  highlight the 
significant  progress  across  Member  States  in  enhancing  administrative  and  operational 
capacities  for  crisis  management,  critical  infrastructure  protection,  and  risk  assessment. 
Among  the  key  achievements  reported  by  the  ex-post  evaluation  reports  are  the 
establishment of early warning systems, cybersecurity centres, and specialised units such 
as CBRN and cybercrime centres. The reports also concluded that the concrete benefits of 
projects  were  difficult  to  quantify,  while  the  defined  indicators  were  largely  met  or 
exceeded (e.g. the evaluation of Austria).  

Survey results (Figure 15) – comprising responses from all types of stakeholders, incl. 
beneficiaries of projects funded under national programmes and Union Actions) – show 
that stakeholders generally perceive ISF-P actions to be effective in enhancing the capacity 
of  Member  States  to  manage  security-related  risks,  crises,  and  protect  critical 
infrastructure. The most positively rated outcome is  ‘increased communication between 
information  systems  and  coordination  between  authorities’,  with  76%  of  respondents 
rating  it  positively  (41%  "to  a  large  extent"  and  35%  "to  some  extent").  Similarly, 
‘increased capacity and skills of competent authorities for responding to security-related 
incidents’ received a high combined positive rating of 68%.  

Figure 15 - Stakeholder answers to the question: ‘To what extent have funded actions resulted in 
the following outcomes, ultimately enhancing the capacity of Member States to manage effectively 
security-related risks and crises and to protect people a 

Increased communication between information systems
and coordination between authorities

Increased capacity and skills of competent authorities for
responding to internal security related accidents and
incidents

Increased preparedness to analyse, manage and
investigate hazardous cases, including future threats

Upgraded systems and tools increased and facilitated early
warning analysis and risk management capacity of critical
infrastructure and public spaces

41%

35%

7%

2%

15%

38%

30%

7%

2%

22%

33%

30%

10%

5%

23%

30%

32%

9%

3%

26%

To a large extent

To some extent

To a limited extent

Not at all

Don't know

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

Source: Preparatory study based on stakeholder survey 

30 

 
 
Challenges identified 

The ISF-P faced several recurring implementation challenges. One of the most common 
challenges was delays in project implementation due to managing lengthy procurement 
procedures,  which  slowed  down  the  implementation  of  essential  projects  (e.g.  the 
acquisition of specialised equipment  for crime detection)58. In some cases, these delays 
were exacerbated by complex decision-making processes within public institutions which 
lacked sufficient personnel for administrative tasks.  

The COVID-19 pandemic significantly disrupted project timelines, training activities, and 
operational measures across multiple Member States. Restrictions on travel and in-person 
gathering required adjustments, such as transitioning from traditional in-person to hybrid 
or virtual formats and/or extensions of project duration.  

Staffing shortages/issues due to high turnover and increased workloads  which delayed 
administrative processes, such as project approvals and payments. 

Shifting geopolitical and security priorities, such as the Russian war of aggression against 
Ukraine, migration crises, and increasing threats from violent extremism led some Member 
States to reallocate resources or adapt internal security strategies during the programming 
period.  The  war  in  Ukraine  had  mostly  indirect  effects  on  the  ISF-P  implementation. 
Some Member States reported delays or increased costs affecting procurement, logistics, 
and availability of supplies and labour (Hungary, Poland and Slovakia), while others (the 
Netherlands, Slovakia and Latvia) highlighted increased costs for equipment and materials 
due to global supply chain disruptions linked both to the pandemic and the Russian war of 
aggression against Ukraine. 

Despite these challenges, evidence did not identify major  issues affecting the achievement 
of objectives, thus underscoring the robustness of ISF-P in addressing such obstacles.  

The extension by one year of the implementation of the Home Affairs Funds pursuant to 
Article 1(5) of Regulation (EU) 2022/585, as a response to the Russian war of aggression, 
contributed to achieving the ISF-P specific objectives and was recognised by stakeholders 
as  playing  a  crucial  role  in  ensuring  the  effective  and  successful  delivery  of  the  ISF-P 
activities at national level. 

4.1.2. Efficiency  

The assessment of efficiency examines the extent to which the resources used by the ISF-
P are used to their best and whether the costs are strictly necessary to reach its objectives.  

Based on the national ex-post evaluation reports59, interviews, surveys, public consultation 
and case studies, there is a general consensus that the ISF-P supported cost-effective 
interventions. The national ex-post evaluation reports60 highlight that in: 

58 Ex-post evaluation reports from Austria, Cyprus and Slovakia; interim evaluation reports from Croatia, 
Romania and Slovakia. 
59 Ex-post evaluations of Austria, Belgium, Bulgaria, Germany, Estonia, Finland, Hungary, Ireland, Italy, 
Lithuania, Luxembourg, the Netherlands, Sweden, Slovenia, and Slovakia. 
60 See Annex V.  

31 

 
 
Austria61: the Responsible Authority managed the ISF-P implementation effectively and 
cost-effectively.  Despite  measurement  challenges, the  Instrument’s objectives were met 
using justified financial and human resources within the allocated budget. 

Belgium:  ISF-P-funded  projects  met  expectations  at  a  reasonable  cost,  particularly 
regarding planned achievements and financial and human resource efficiency. 

Bulgaria: the ISF-P demonstrated a high level of efficiency with most objectives being 
met  or  even  surpassing  indicator  targets,  despite  challenges  such  as  delays,  project 
cancellations,  and  financial  constraints.  While  inflation  and  global  price  fluctuations 
affected  procurement  contracts,  cost  savings  were  achieved  in  trainings  (shift  from  in-
person to digital formats) and reduced international visits.  

Croatia:  successfully  implemented  its  ISF-P  programme  with  sufficient  financial  and 
human resources. 

Hungary: the ISF-P’s expected results were largely achieved at a reasonable cost. 

Ireland:  the  expected  results  of  the  Instrument  were  generally  cost-efficient.  Evidence 
from  project  stakeholders  and  programme  documentation  confirmed  that  projects  were 
delivered within the budget. Public procurement of equipment and services were utilised 
for  projects  such  as  Interpol  FIND,  Prüm  (Fingerprint)62.  Similarly,  the  Cyber  Crime 
Bureau  and  ‘Air  Support  Unit  –  Role  Equipment’  project  also  relied  on  competitive 
tendering with a focus on cost-effectiveness in procuring works, equipment, or services. 
Although expenditures related to the National Surveillance Unit were subject to security 
derogations  and  niche  market  constraints,  budget  constraints  and  close  knowledge  of 
suppliers  helped  maintain  cost  vigilance.  Further  efficiencies  were  achieved  through 
internal  training,  moderate  technical  adaptations  at  no  extra  cost,  and  savings  from 
leveraging contractors’ existing expertise.  

Italy:  high  implementation  efficiency,  projects  were  cost-effective  as  acquisitions 
followed  public  tender  procedures,  ensuring  compliance  with  financial  and  operational 
standards.  Human  resource  effectiveness  was  particularly  evident  in  projects  such  as 
PASSIM  3,  where  flexible  personnel  allocation  enhanced  efficiency.  Overall,  the 
objectives  of  the  ISF-P  were  met  through  a  proportional  deployment  of  financial  and 
human resources.  

Luxembourg: ISF-P investments were well-justified, providing benefits such as enhanced 
safety.  The  cost-benefit  ratio  was  deemed  positive,  reflecting  the  efficient  allocation  of 
financial and human resources.  

Poland:  efficient  use  of  funds  was  facilitated  by  a  well-planned  management  and 
monitoring system. Oversight mechanisms ensured optimal financial resource allocation, 
leading to high cost-effectiveness.  

The Netherlands: successfully met the ISF-P objectives at a reasonable cost. While the 
human resources deployed were substantial, they were considered appropriate to meet EU 

61 Ex-post evaluation report and interviews with beneficiaries. 
62 PR/0002 – the Prüm (Fingerprints) project 

32 

 
 
project implementation standards. Union Actions beneficiaries found the investment to be 
proportionate to the grants received.  

Czechia,  Estonia,  Latvia,  and  Germany:63  the  ISF-P  national  programmes  were 
implemented  efficiently,  with  most  objectives  met  despite  financial  and  administrative 
challenges  (especially  for  smaller  projects).  These  Member  States  prioritised  larger 
projects (in IT and specialised equipment) to maximise funding effectiveness. Cost-saving 
measures, such as online training and framework agreements for procurement, contributed 
to overall efficiency.  

The  public  consultation  confirmed  the  findings  from  the  national  ex-post  evaluation 
reports and interviews: overall 56% of the respondents (19 out of 34) stated that the results 
were achieved in  a cost-effective manner  "to a large extent,"  while 41% (14 out  of 34) 
believed they were cost-effective "to some extent."  

Figure 16 - Replies to the question  “In your opinion, to what extent were the results achieved by 
the ISF-P reached in a cost-effective manner?” 

14

I don’t know /Prefer not to say

To a large extent

To some extent

19

Source: Source: Preparatory study based on the public consultation 

The majority of respondents (65%), i.e. 29 out of 45, considered the administrative burden 
brought by the ISF-P to be proportionate to the benefits achieved.  

Proportionality of administrative burden 

Despite the ISF-P demonstrating strong financial management, findings across Member 
States revealed a mixed picture regarding administrative efficiency. Some Member States 
benefited from streamlined processes and flexible fund allocation, while others struggled 
with high administrative burden, complex procedures, and personnel constraints. Efforts 
to digitalise reporting, introduce Artificial Intelligence (AI) driven management tools, and 
reduce bureaucratic hurdles have been suggested to improve cost-effectiveness and ensure 
a more balanced approach to fund administration in the future. 

63 Interviews and ex-post evaluation reports of Member States. 

33 

 
 
 
 
 
 
 
 
 
 
 
Interviews  and  national  ex-post  evaluation  reports  indicate  that  the  administrative 
burden associated with the ISF-P implementation varied across Member States, with 
some  reporting  proportionate  costs  while  others  faced  challenges  due  to  complex 
procedures and resource constraints.  

While  the  implementation  of  the  ISF-P  remained  effective  in  achieving  its  objectives, 
national  ex-post  evaluation  reports  show  that  there  is  room  for  further  continued 
simplification  of  administrative  procedures 
improve  cost-effectiveness.  More 
specifically, in: 

to 

Belgium:  highlighted  a  disparity  between  workload  and  funding,  with  only  55%  of 
respondents considering the administrative burden proportionate to the level of financing 
provided.  

Bulgaria:  the  management  and  control  system  functioned  well,  ensuring  effective 
cooperation  among  bodies  through  clearly  defined  responsibilities.  Although  the  ISF-P 
provided necessary financial resources, additional human resources and capacity-building 
were still required. 

The  Netherlands:  the  case  study  identified  complexities  arising  from  national-level 
requirements, leading to duplicated administrative efforts. For  instance, applications for 
the  government-wide  Framework  Agreement,  which  already  included  ISF-P  funding 
requests, had to undergo multiple additional checks imposed by the Intermediary and Audit 
Authorities.  In  contrast,  funding  applications  to  the  Commission  (for  ISF-P  funding), 
Europol, or Horizon programmes were perceived as more transparent and straightforward. 

Germany: the case study indicates significant challenges in recruiting staff. The internal 
security sector’s financial needs exceeded the ISF-P budget, and costs on administrative 
and human resources were high. Germany called for EU-wide indicators to measure fund 
management  efficiency  and  suggested  improvements  such  as  AI-driven  processes, 
streamlined reporting and fewer control bodies.  

Malta:  project  beneficiaries  reported  a  high  administrative  burden,  with  an  average  of 
9.2%  of  project  budgets  spent  on  administration.  While  accountability  was  ensured, 
substantial  administrative  costs  were  often  absorbed  by  national  budgets.  Despite 
achieving  the  expected  results,  the  financial  and  human  resources  was  considerable, 
suggesting a need for simplified administrative procedures. 

Estonia:  successfully  met  the  objectives  of  the  Instrument  at  a  reasonable  cost,  with 
administrative  burden  being  proportionate  except  for  indicator  reporting.  Project 
implementation followed planned budgets and schedules. 

Spain:  the  case  study  highlights  reporting  challenges  and  challenges  on  preparing 
accounting  records  due  to  limited  digitisation.  To  counter  this,  a  new  application, 
GESTIONA, was introduced to simplify documentation uploads and verifications, making 
fund management more efficient.  

Latvia:  experienced  frequent  and  extensive  reporting  requirements  under  the  ISF-P, 
making the process burdensome.  

Survey findings (Figure 17) indicate that stakeholders who worked on the implementation 
of ISF-P only or of both the ISF and ISF-P, reported mixed experiences. Based on a total 

34 

 
of 53 respondents, designing direct and competitive awards was reported as challenging 
‘to some extent’ by 19 respondents and ‘to a large extent’ by 14, while 6 respondents faced 
no challenge at all. Respecting timelines followed a similar pattern, with 13 respondents 
indicating challenges ‘to a limited extent’, 14 ‘to some extent’, and 9 ‘to a large extent’. 
The use of digital platforms was defined as challenging by 26 respondents (“To a large 
extent” and “To some extent”).  

Figure 17 - Number of replies to the survey question “To what extent have the following points 
represented a challenge in managing national programmes and related application procedures?” 

Managing payments

7

0

Adhering to reporting timelines

Adhering to reporting requirements

Providing sufficient support to beneficiaries

Use of the digital platform for application

Respecting the timelines

Contractualization

3

2

11

12

7

8

13

12

6

17

14

2

13

14

17

17

5

2

9

5

14

9

4

8

8

4

Designing direct and competitive award

6

14

0

10

20

19

30

14

40

50

60

Not at all

To a limited extent

To some extent

To a large extent

Don't know

Source: Preparatory study based on the responses of the stakeholder survey 

To estimate the average time spent on the ISF-P implementation, the number of man-days 
a full-time employee dedicated to the tasks was employed. Based on survey responses, the 
numbers vary significantly across respondents64.  

•  For direct and competitive awards (i.e. information to applicants, preparing calls 
and guidelines, and contractualisation), respondents indicated ca. 30 to 40 person-
days required.  

•  For  the  evaluation  of  proposals/projects  (screening  and  selecting  applications) 
under the ISF-P, respondents indicated that the process involves between 9 to 30 
person-days.  

•  The estimates for monitoring programme implementation indicate that most tasks 

require between 8 to 30 person-days. 

•  For reporting ISF-P activities, the majority of estimates include 20, 25, 30 and 50 

man-days, i.e. 30 person-days on average.  

• 

In terms of efficiency of time spent by beneficiaries for the  preparation of one 
project proposal, most respondents reported approximately 30 to 35 person-days. 

64  It  should  be  noted  that  the  survey  results  presented  challenges  in  aggregation  and  averaging  due  to 
differences in how questions were interpreted by stakeholders, thus, outliers were excluded. 

35 

 
 
 
For Union Actions, beneficiaries reported a range between 30 to 90 person-days 
for the preparation of one project proposal. 

The perception of administrative burden in the implementation of the ISF-P varied across 
Member States, reflecting differences in resource availability, procedural complexity and 
national  administrative  structures.  Croatia,  Cyprus,  Czechia  and  Estonia  highlighted 
improvements  in  cost-effectiveness  compared  to  the  2007-2013  programming  period, 
attributing this to increased flexibility in fund allocation and streamlined processes. On the 
other hand, Germany and Malta faced significant administrative and personnel challenges, 
extensive reporting requirements and delays in project implementation.  

Efforts  to  enhance  efficiency,  including  digitalisation,  simplified  reporting,  and  cost-
saving measures, have proven beneficial in some cases. Nonetheless, the administrative 
workload remains a concern, particularly for smaller projects. The diverse estimates of 
person-days spent on tasks, such as project preparation, monitoring, reporting, and auditing 
highlight the difference in administrative burden across Member States.  

Technical Assistance 

The  national  ex-post  evaluation  reports  show  that  the  cost-effectiveness  of  technical 
assistance  differ  across  Member  States.  For  instance,  in  Germany,  technical  assistance 
does not fully cover actual costs, likely due to the country’s high wages, whereas in Italy, 
beneficiaries  expressed  high  satisfaction with the technical  assistance highlighting  their 
role in ensuring smooth project management and timely completion of projects.  

Table 6 - Shared management: Technical assistance absorption rate by Member State 

Member 
State 
AT 
BE 
BG 
CY 
CZ 
DE 
EE 
ES 
FI 
FR 
GR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 

Absorption rate (Total 
accounts/NP allocation) % 

Total Allocated Amount (Euro) 

95.24% 
57.52% 
97.69% 
100.00% 
96.81% 
67.92% 
97.34% 
59.34% 
100.00% 
25.55% 
67.69% 
99.88% 
96.55% 
101.40% 
93.57% 
N/A65 
0% 
100.11% 
49.44% 

892.660,95 
1 219.566,40 
1 426.369,00 
605.862,85 
1 169.777,60 
4 727.667,05 
874.013,45 
1 540.000,00 
1 093.087,40 
3 398.780,37 
1 033.900,00 
1 154.771,00 
688.643,00 
716.380,00 
3 031.587,05 
0,00 
102.689,00 
1 164.791,45 
548.955,25 

65 Absorption rate not calculable as allocation was zero 

36 

 
 
Member 
State 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Absorption rate (Total 
accounts/NP allocation) % 

Total Allocated Amount (Euro) 

100.00% 
97.56% 
96.47% 
40.70% 
134.24% 
98.16% 
99.66% 

1.996.188,50 
2.437.752,40 
1.134.655,20 
2.057.505,25 
1.252.857,00 
521.300,52 
991.099,80 

Source: Preparatory study 

Union Actions 

The  case  study  on  Union  Actions  shows  its  efficiency  as  projects  provide  significant 
benefits  (e.g.  innovative  practices  and  training  materials)  which  are  disseminated  to  all 
Member States. If each Member State were to achieve these results individually, this would 
have required much larger funding. 

Beneficiaries ensured efficiency by conducting market research for cost-effective products 
and services, regularly monitoring and adjusting budgets, adhering to national procurement 
procedures, and implementing cost-saving measures. 

Union  Actions  beneficiaries66  report  that  project  outcomes  were  largely  successful  and 
delivered  at  a reasonable cost  by detailed task schedules, careful planning  of personnel 
needs, and support from the Commission. More precisely, one Union Action beneficiary67 
implemented several measures to maintain reasonable costs, such as remote work and cuts 
in  office  expenses,  use  of  pro  bono  service  where  feasible,  minimised  travels  and 
implementation of online or hybrid events and use of online publications instead of printed 
and paper formats. Project leaders made consistent efforts to adhere to EU and national 
regulations, with the use of subcontractors and regular financial reporting helping to ensure 
cost efficiency. 

Emergency Assistance 

The  case  study  on  EMAS  evidence  that  beneficiaries  generally  found  the  application 
process simple and straightforward. EMAS applications can be initiated by any security-
related incident or emerging threat which has or may have a significant adverse impact on 
the internal security in one or more Member States. The application requires submitting a 
simplified application and budget forms with an expedited review process. 

Overall, the application procedure for EMAS was considered lighter and easier compared 
to  other  ISF-P  proposals  and  applications  under  other  funding  programmes  (e.g.  Union 
Actions and Horizon 2020). No unreasonable administrative burden for implementing the 
project was perceived. Two EMAS stakeholders reported that administrative costs were 
considerably lower than those of other ISF-P funded projects.68  

66 Six interview with Union Actions beneficiaries were conducted.  
67 In-depth interviews with a beneficiary from the Netherlands. 
68 In-depth interviews on EMAS 

37 

 
 
The managers of four EMAS projects noted that the ISF-P Regulation and the Commission  
Annual  Work  Programmes  broadly  define  emergencies,  providing  flexibility  to  tailor 
projects to specific needs, such as those following the Brussels terrorist attacks in 2016. 

The  EMAS  projects  EU-SIUTEx,  EU  Hotspots  (Europol  Guest  Officers)  and  HORUX 
demonstrated strong efficiency and cost-effectiveness69.  

The  EU-SIUTEx  project  efficiently  developed  and  implemented  three  information  and 
communications technology (ICT) applications aimed at supporting Special Intervention 
Units in addressing terrorist threats. Two applications are fully integrated and in active use 
by the Belgian Federal Police, enhancing real-time communication and data accessibility. 
The third tool required extra time for integration but is  being completed and accessible 
EU-wide via the ATLAS network. The project capitalised on results from a previous EU 
initiative  (EU-ACTION),  which  helped  streamline  development  efforts  and  avoided 
duplications.  

The  EU  Hotspots  project  enabled  the  rapid  deployment  of  278  Guest  Officers  from  24 
Member States to migration hotspots in Greece and Italy. By leveraging trained personnel 
from  across  the  EU  rather  than  creating  new  permanent  structures,  the  project  was 
considered highly cost-effective.  

Lastly, the HORUX project minimised costs by developing tools which serve both national 
and  EU-wide  purposes  and  by  facilitating  the  sharing  of  intelligence  between  Member 
States. 

Measures to prevent fraud and other irregularities 

Overall,  Member  States  agree  that  Responsible  Authorities  effectively  managed  the 
implementation  of  the  ISF-P.  Findings  from  ex-post  national  evaluation  reports, 
interviews with stakeholders, and case studies highlight overarching aspects identified to 
prevent fraud across all Member States.  

Bulgaria:  the  Responsible  Authority  implemented  rules  to  manage  irregularities  and 
ensure efficient resource use.  

Croatia:  the  Responsible  Authority  raised  concerns  that  despite  stringent  control 
mechanisms ensuring compliance, they created additional administrative burden and made 
processes  more  rigid,  potentially  undermining  operational  efficiency.  While  substantial 
auditing complexity were observed in some cases, there was no evidence of “gold-plating” 
that would impose additional administrative burden on beneficiaries.  

Czechia:  ISF-P  projects  were  audited  under  the  same  procedures  as  Cohesion  Fund 
projects, making the auditing process more cumbersome than initially planned. This led to 
national funding programmes – which tended to have fewer requirements – being preferred 
over EU funding. 

Estonia:  control  measures  identified  irregularities  (negligence  or  lack  of  awareness  in 
public procurement), but no fraud was detected.  Cooperation between beneficiaries and 
the Responsible Authority enabled flexible and efficient project implementation.  

69 Case study on EMAS.  

38 

 
 
Finland:  the  Responsible  Authority  assessed  project  costs  for  reasonableness  before 
implementation  and  applied  strong  financial  controls  and  competitive  procurement 
processes to ensure cost-effectiveness. 

Slovakia: effective measures were in place to prevent  fraud and irregularities, although 
public procurement issues arose. These issues were addressed with increased controls to 
ensure transparency and recommendations to improve procurement processes. 

Spain: the ISF-P Procedures Manual 2014-2020 provided detailed guidelines to prevent, 
detect,  and  manage  irregularities,  which  were  deemed  sufficient  and  in  line  with 
Commission  recommendations.  These  measures  allowed  for  the  identification  of  and 
addressing irregularities, particularly those related to eligibility rules with various controls 
and verifications to protect the EU budget. 

The  ISF-P  has  generally  demonstrated  effective  management  and  control 
mechanisms  and  were  efficient in safeguarding  the EU’s financial interests. Strong 
collaboration and clear communication between Responsible Authorities and beneficiaries 
were identified as key enablers of timely and cost-effective project delivery. The measures 
in place to prevent fraud and irregularities and the cooperation between national authorities 
and beneficiaries have largely contributed to the efficient use of resources.  

Nonetheless,  there  are  areas  for  improvement,  such  as  the  importance  of  achieving  a 
balance  between  the  need  for  robust  oversight  on  the  one  side  and  streamlined 
administrative procedures to further operational agility (Section 4.1.3), on the other side.  

4.1.3. Simplification and Reduction of Administrative Burden 

This evaluation criterion assesses the extent to which the simplification and reduction of 
administrative burden contributed to achieving the objectives of the ISF-P. 

This analysis compares the 2007-2013 to the 2014-2020 programming period noting that 
the  ISF-P  and  the  Horizontal  Regulations  have  introduced  several  changes  aimed  at 
simplifying  the  ISF-P  management  and  reducing  administrative  burden.  The  main 
elements are:  

• 

• 

• 

the  Horizontal  Regulations  lays  down  general  rules  necessary  for  enabling  the 
implementation  of  all  Home  Affairs  Funds  with  the  aim  of  ensuring  better 
coordination and management between them and to harmonise their procedures;  

the introduction of multiannual programming  and a single seven-year funding 
cycle  which  increased  flexibility  and  removed  the  need  to  drafting  annual 
programmes and enabled projects with longer life-cycles; 

the introduction of simplified cost options (SCOs) and – in accordance with the 
principle  of  subsidiarity  –  national  rules  on  expenditure  eligibility  by  the 
Member States70;  

•  Despite simplification efforts, control mechanisms should remain efficient, thus 

guaranteeing the protection of the EU financial interests. 

70 Recital (36) of the Horizontal Regulation.  

39 

 
 
Table 7 - Summary of differences affecting administrative burden between the Instruments 

Structure 

CIPS and ISEC (2007-2013) 
Two Instruments addressing 
internal security 

ISF-P (2014-2020) 
One Instrument 

Programming cycle 

Two strategic cycles (2007-2010 
and 2011-2013) 

A singular seven-year cycle and 
multiannual programming 

Implementation measures 

National rules on expenditure 
eligibility and SCOs 

The  vast  majority  of  Member  States71  reported  that  these  elements  have  streamlined 
processes and reduced administrative burden. Many Member States underline that despite 
procedures remaining cumbersome and further simplification being necessary, the ISF-P 
is  perceived  as  less  burdensome  in  comparison  to  the  Programmes  in  the  2007-2013 
programming period.  

The following section indicates the main evidence concerning the elements introduced to 
simplify procedures and reduce administrative burden. 

Multiannual programming 

The introduction of multiannual programming aimed at making EU funding more efficient 
and tailored by allowing long-term planning and resource allocation for Member States72. 
It has been seen as a positive development and several Member States73 highlighted its 
benefits  in  allowing  for  long-term  planning,  reducing  administrative  burden  associated 
with  annual  adoptions,  and  increasing  flexibility  in  fund  allocation.  However,  a  few 
Member  States  noted  initial  difficulties  in  drafting  multiannual  plans  in  line  with  EU 
indicators (Cyprus), and that while the concept was beneficial, the administrative burden 
remained significant due to complex implementation processes (Hungary and Slovakia). 

The  flexibility  of  national  programmes  was  seen  as  a  key  advantage  by  some  Member 
States  which  highlighted  that  more  adaptable  national  programmes  allowed  for  quicker 
responses to changing needs and facilitated efficient project adjustments (Hungary, Italy, 
Lithuania  and  Luxembourg)  and  emphasised  that  flexibility  in  programme  design 
contributed  to  effective  financial  planning  and  minimized  disruptions  (Lithuania). 
However,  Cyprus  and  Slovakia  reported  that  rigid  national  objectives  set  within  the 
programmes made mid-term adjustments difficult, adding to the administrative burden. 

National Eligibility Rules and Simplified Costs Options 

Several Member States74 have benefited from the introduction of national eligibility rules 
as it has created a more flexible framework as they have been tailored to the respective 
specific  national  contexts,  thus,  facilitating  their  comprehension  by  beneficiaries  and 
increasing  efficiency.  Nonetheless,  Hungary  and  Slovakia  indicated  that  the  practical 
impact of these rules was limited as the administrative burden remained high, particularly 
in public procurement and personnel expenditure. 

71 Interviews and ex-post evaluation reports of Member States. 
72 Recital (7) of the Horizontal Regulation.  
73 Cyprus, Czechia, Finland, Ireland, Italy, Lithuania, Luxembourg, Malta, Slovakia, and Sweden 
74 Bulgaria, Cyprus, Italy, Lithuania, Luxembourg, Malta and Romania. 

40 

 
 
 
 
 
 
Under the framework of national eligibility rules, Member States had the option to adopt 
SCOs to reduce administrative burden by simplifying the control and audit processes. The 
adoption and implementation of SCOs varied across Member States. While some Member 
States (CZ, FI, IT, LT, SE and SI) reported that SCOs contributed to streamlined financial 
management and reduced administrative burden, others (AT, BE, HU, MT and SK) faced 
challenges in their adoption and either did not use SCOs or only to a limit extent due to 
perceived administrative complexity, lack of training, or feasibility concerns.  

Reporting mechanisms 

The CIPS and ISEC ex-post evaluations highlighted the need for more detailed reporting 
from  project  beneficiaries  to  strengthen  overall  programme  efficiency.  The  ISF-P 
introduced  more  structured  reporting  mechanisms,  including  Annual  and  Final 
Implementation Reports under different management modes, to improve monitoring and 
accountability.  

The national ex-post evaluation reports of several Member States75 show that reporting 
and  indicators  remained  a  challenge  for  many  beneficiaries  and  indicate  a  high 
administrative burden linked to  reporting requirements, complex indicator systems,  and 
extensive  documentation  obligations.  Belgium  highlighted  that  annual  reporting  and 
expenditure  documentation  increased  administrative  burden,  with  many  beneficiaries 
finding it disproportionate to the funding received.  

Based  on  the  interviews,  beneficiaries  must  provide  full  documentation,  from  fund 
allocation agreements to final invoices, to verify project expenditures. Nonetheless, while 
the process is demanding, the reports considered it necessary to ensure accountability and 
transparency (e.g. proper documentation of purchases and distribution and helping track 
progress and compliance).  

Survey  results  provided  input  on  stakeholder’s  perceptions  of  the  simplifications 
measures  introduced  by  the  2014-2020  legal  framework  (Figure  18).  These  findings 
confirm that multiannual programming, the introduction of national eligibility rules and 
increased  flexibility  in  national  programmes  brought  simplification  and  reduced 
administrative burden “to some extent” and “to a large extent” (agreed by 30 respondents).  

Survey  respondents  have  expressed  mixed  views  concerning  the  adoption  and 
implementation  of  SCOs  at  national  level  (23  respondents  found  it  did  not  bring 
simplification or only “to a limited extent”). 

75 National ex-post evaluation of Belgium, Czechia, Germany, Hungary, Malta, the Netherlands, Spain and 
Slovakia. 

41 

 
 
Figure 18 - Number of replies to the survey question “To what extent had the following changes in 
procedures introduced by the ISF-P resulted in the simplification of administrative burden for the 
beneficiaries of the Fund?“ 

Use of simplified cost option

Multiannual programming

Introduction of national eligibility rules

More comprehensive national programmes allowing for
flexibility

1

14

14

16

10

6

4

7

6

12

11

9

10

10

11

12
12

10

19

18

Don't know

To a large extent

To some extent

To a limited extent

Not at all

0

2

4

6

8

10

12

14

16

18

20

Source: Preparatory study based on survey answers 

The effectiveness of the changes aimed at simplifying the ISF-P management and reducing 
administrative burden varied across Member States. While some Member States benefited 
from  streamlined  administrative  mechanisms,  others  faced  challenges  with  their 
complexity, extensive documentation requirements, and difficulties in fully implementing 
simplification  measures.  Despite  some  progress,  further  steps  are  needed  to  enhance 
efficiency  and  ensure  administrative  processes  are  proportionate  to  the  funding 
provided.  

4.1.4. Coherence and Complementarity 

The examination of coherence serves to assess the extent to which the objectives set in the 
ISF-P were consistent, mutually reinforcing and effectively integrated within the broader 
context of EU funding. It evaluated both internal coherence (coherence of the components 
and  management  modes  and  how  interventions  generate  synergies  through  formal  or 
informal  cooperation)  and  the  external  coherence  (complementarities  and  synergies 
between ISF-P and other EU policies and priorities, other Home Affairs Funds and EU 
funding instruments). 

Internal Coherence 

The ISF-P is considered generally coherent with other initiatives within its policy domain 
and  across  management  modes  (shared,  direct  and  indirect).  Coherence  is  also  present 
between the Instrument’s components (national programmes, Union Actions and EMAS), 
although some challenges remain.  

The components of the ISF-P were designed to complement each other and to minimise 
potential  overlaps  and  risks  of  duplication.  National  programmes  support  long-term 
structural needs at national level, Union Actions respond to emerging needs and supports 
projects which require a transnational approach, while EMAS facilitates actions that are 

42 

 
 
difficult to implement within national programmes by addressing urgent and unpredictable 
needs arising from emergency situations.  

Table 8 outlines the complementary purposes of the ISF-P components and management 
modes. The complementary nature of these components – which may be suited to serving 
long-term or short term/urgent, national or transnational needs can be observed in practice.  

Table 8 - Complementarity of the funding components 

Purpose 

Fund component/Management mode 

Contribute to the achievement of the ISF-P general 
objective  by  including  actions  addressing  all 
specific objectives – Recital (27) 

Transnational  actions  or  actions  of  particular 
interest to the Union – Art. 8 (1) 

Provide  assistance to urgent and specific needs in 
the event of an emergency situation – Article 10(1) 

Source: ISF-P Regulation  

National programmes (shared management mode) 

Union Actions (direct/indirect management modes) 

EMAS (direct management mode)76 

Formal  mechanisms  are  in  place  to  ensure  EMAS  and  Union  Actions  (delivered  under 
Annual  Work  Programmes  developed  by  the  Commission)  complement  the  support 
delivered  under  the  national  programmes  (developed  by  Member  States  in  consultation 
with the Commission at the start of the programming period) at EU and national levels. 

At  EU  level,  the  internal  procedures  ensure  that  financial  and  policy  units  within  DG 
HOME, as well as other Commission services, where appropriate, feed into the decision-
making  processes  (i.e.  drawing  up  the  Annual  Work  Programmes).  Thus,  possible 
complementarities across funding provided under different components and management 
modes should be ensured from the outset.  

At Member State 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-P programme. 

Despite  there  being  formal  and  informal  coordination  mechanisms  in  place  to  ensure 
complementarities and the lack of duplication or overlaps, the ISF-P interim evaluation 
and ISF-P beneficiaries highlighted the need for improved awareness of projects under 
this Instrument. In this sense, two Responsible Authorities reported that communication 
between Responsible Authorities and the Commission – on the selection of projects and 
beneficiaries under national programmes and Union Actions – has room for improvement. 
This has been rectified to a certain extent through efforts between national authorities to 
ensure better coordination between national programmes and Union Actions.  

Coherence with the EU internal security policy  

Over  the  past  years,  the  EU  has  developed  consecutive  security  strategies  to  address  a 
spectrum of developments and threats within its internal security. The overarching strategy 
at the time, the 2010 Internal Security Strategy provided a strategic direction for the ISF-

76  Despite Article 5(4) of the ISF-P Regulation setting out that EMAS can be implemented under direct and 
indirect management, aAll ten ISF-P funded EMAS have been implemented through direct management.  

43 

 
 
P. Within this framework, the EU has devised various thematic strategies and action plans 
aimed at combating the most prominent trends in internal security. 

Table 9 provides an overview of the strategic priorities and objectives outlined in the 2010 
Internal Security Strategy and the European Agenda for Security relevant to the 2014-2020 
programming period. The priorities and objectives in the 2010 Internal Security Strategy 
are  echoed  in  the  specific  objectives  and  policy  fields  of  the  ISF-P,  demonstrating 
coherence between the two frameworks.  

The ISF-P specific objectives are closely aligned with the strategic priorities outlined in 
the 2010 Internal Security Strategy. ‘Specific Objective – fight against crime’ of the ISF-
P is derived from strategic objectives of the 2010 Internal Security Strategy to disrupt crime 
networks  (Objective  1),  prevent  terrorism  and  address  radicalisation  and  recruitment 
(Objective  2),  and  raise  levels  of  security  for  citizens  and  businesses  in  cyberspace 
(Objective  3).  ‘Specific  Objective  –  risk  management’  of  the  ISF-P  corresponds  to  the 
strategic objectives of the 2010 Internal Security Strategy to Increase Europe's resilience 
to crises and disasters (Objective 5).  

The specific objectives of ISF-P are further translated to operational objectives, strategic 
priorities  and  higher-level  policy  objectives  in  the  field  of  internal  security.  This 
demonstrates  the  coherence  and  complementarity  of  the  ISF-P  within  the  broader 
framework of the Internal Security Strategy.  Furthermore, the specific objectives of the 
ISF-P are well aligned with the strategic priories outlined in the subsequent 2016 European 
Agenda on Security.  

44 

 
Table 9 - Alignment between the Specific Objectives of the ISF-P and the 2010 Internal Security Policy 

on 

European 
Agenda 
Security 
Strategic 
Priorities 
Tackling 
terrorism and 
preventing 
radicalisation 

EU  Internal 
Security 
Strategy 
Objectives 

Disrupt 
international 
criminal 
networks 

Prevent 
terrorism and 
radicalisation 
and 
recruitment 

Strategic 
priorities  

Union 

Strategic Priorities 

Fighting cross-border, 
serious and organised 
crime, in particular projects 
implementing relevant 
policy cycles 
Preventing and combating 
cybercrime/raising the 
levels of security for 
citizens and business in 
cyberspace 
Preventing and combating 
terrorism and addressing 
radicalisation/recruitment 

Raise levels 
of security for 
citizens and 
businesses in 
cyberspace 

Raise Member States’ 
administrative and 
operational capability to 
protect critical 
infrastructure 

Disrupting 
organised crime 

Increasing the Union’s 
resilience to crisis and 
disaster 

Achieve a closer 
partnership between the 
Union and third countries 

Fighting 
cybercrime  

Increase 
Europe's 
resilience to 
crises and 
disasters 

ISF-P 

ISF-P 

Specific Objectives 

Operational objectives 

Specific Objective – fight against 
crime 
Crime prevention, combating cross-
border, serious and organised crime 
including terrorism, and reinforcing 
coordination and cooperation between 
law enforcement authorities and other 
national authorities of Member States, 
including with Europol or other 
relevant Union bodies, and with 
relevant third countries and 
international organisations 

Specific Objective – risk 
management 
Enhancing the capacity of Member 
States and EU to effectively manage 
security-related risks and crises and 
preparing for and protecting people 
and critical infrastructure against 
terrorist attacks and other security-
related incidents.  

Promote and develop measures strengthening Member States’ capability to prevent  
and combat cross-border, serious and organised crime incl. terrorism, through public-
private partnerships, exchange of information and best practices, access to data, 
interoperable technologies, public communication and awareness raising. 

Promote  and  develop  administrative  and  operational  cooperation,  mutual 
understanding and exchange of information among Member States’ law enforcement 
authorities,  other  national  authorities,  Europol  or  other  relevant  Union  bodies  and, 
where appropriate, with third countries and international organisations. 

Promote  and  develop  training  schemes,  incl.  technical  and  professional  skills  and 
knowledge on  respect for human rights and fundamental freedoms, in implementation 
of  European  training  policies,  incl.    through  Union  law  enforcement  exchange 
programmes to foster a genuine European judicial and law enforcement culture 
Promote and develop measures, safeguards, mechanisms and best practices for early 
identification,  protection  and  support  of  witnesses  and  victims  of  crime,  including 
victims of terrorism, and in particular for child witnesses and victims, especially those 
who are unaccompanied or otherwise in need of guardianship. 

Strengthen Member States’ administrative and operational capability to protect critical 
infrastructure  in  all  sectors  of  economic  activity,  including  through  public-private 
partnerships and improved coordination, cooperation, exchange and dissemination of 
know-how and experience within the Union and with relevant third countries. 
Secure links and effective coordination between existing sector-specific early warning 
and crisis cooperation actors at EU and national levels, incl. situation centres to enable 
the quick production of comprehensive and accurate overview in crisis situations. 
Strengthening the administrative and operational capacity of the Member States and 
EU  to  develop  comprehensive  threat  and  risk  assessment.  These  must  be  evidence-
based and  consistent with priorities and initiatives identified at EU level to enable the 
EU to develop integrated approaches based on common and shared approaches to crisis 
situations. 

45 

Taxonomy  used 
for  the  current 
evaluation 
Policy fields 

Counter-terrorism, 
including 
prevention of 
radicalisation, 
protection of public 
spaces, critical 
infrastructure and 
entities 

Organised crime 
(incl. drugs and 
firearms 
trafficking, THB, 
migrant smuggling, 
corruption, money 
laundering) 

Cybercrime, 
including 
Sexual Abuse 

Child 

Law enforcement 
cooperation 

Information 
exchange 
Cooperation  with 
third countries 

 
 
 
 
External Coherence 

Support  provided  under  the  ISF-P  complements  national  and  regional  intervention  as 
national security remains a competence of the Member States. In doing so, the ISF-P aims 
to  enhance  the  Union’s  contribution  to  achieving  its  objectives  in  areas  which  require 
cooperation and coordination at EU level. 

Mechanisms for coordination at the programming and implementation phases 

The Horizontal Regulation sets out the obligation for  the Commission and the Member 
States to ensure that the support provided under the Specific Regulations and by Member 
States  is  complementary  to  other  Union  instruments.77  Furthermore,  its  lays  out  that 
Member States  shall  take into consideration the partnership principle in  the preparation 
and implementation of the national programmes78.  

Member States implemented several different coordination mechanisms at national level 
during the programming and implementation phases to ensure the coherence of activities 
with other programmes funded by EU Instruments with similar objectives to those of the 
ISF-P79.  

Several national ex-post evaluation reports80 show that the key coordination mechanism 
in  ensuring  coherence  between  the  ISF-P  and  other  EU  interventions  is  played  by  the 
Monitoring  Committees,  which  gathers  representatives  from  national  institutions  and 
beneficiaries  with  the  objective  of  fostering  coherence  and  limiting  overlaps  between 
interventions.   

Other  mechanisms  employed  are  the  regular  coordination  between  the  Responsible 
Authorities  of  the  different  funds,  inter-institutional  working  groups  and  consultation 
platforms.  By  including  representatives  from  various  stakeholders,  including  national 
ministries, local authorities and EU bodies, these committees ensure that all activities are 
aligned with national and EU priorities. Furthermore, the employment of risk assessments 
or  analyses  throughout  the  implementation  period  of  the  funding  Instruments  also 
contributed to supporting coherence between interventions and limiting overlaps (Czechia 
and Ireland).81  

The survey results corroborate these findings: 

•  82% of Responsible Authorities confirmed coordination mechanisms were put in 
place  in  the  programming  and  implementation  phases  of  the  ISF-P  to  ensure 
coherence with other EU-funded initiatives;  

•  76% of survey respondents mentioned that establishing a Monitoring Committee 

alone is a means of coordinating with other interventions,  

77 Article 3(2) of the Horizontal Regulation. 
78 Article 12(3) of the Horizontal Regulation.  
79  National  ex-post  evaluation reports  of Belgium,  Bulgaria,  Cyprus,  Czech  Republic,  Germany,  Estonia, 
Greece, Finland, Ireland, Lithuania, Luxembourg, Latvia, Malta, the Netherlands, Romania, Slovenia and 
Slovakia; 82% of the Responsible Authorities in the survey confirmed this.  
80  Belgium,  Bulgaria,  Cyprus,  Czechia,  Estonia,  Finland,  France,  Germany,  Greece,  Ireland,  Lithuania, 
Latvia and Malta. 
81 National interim evaluation report for Czechia and Ireland. 

46 

 
 
 
•  One  of  the  most  frequently  employed  measures  included  coordination  and 
exchanges with coordinators of other funds and EU-funded initiatives, i.e. between 
relevant  ministries,  or  conducting  assessments  of  interventions  with  similar 
objectives. 

At times, these coordination mechanisms were employed simultaneously. For instance, in: 

Slovenia:  introduced  a  three-level  verification  mechanism  involving  Monitoring 
Committees, interministerial working groups, and project-level reviews to ensure that the 
objectives set forth in the national programme are coherent with other EU instruments.82  

Finland: there is also a structured approach where centralised coordination and regular 
consultations help maintain coherence.  

Romania: targeted training and specific project ensure coherence. 

Poland:  experienced  management,  partnership  with  relevant  authorities,  and  ongoing 
consultations help maintain coherence during implementation.  

Spain: an interview with the Spanish Responsible Authority reports strategic cooperation 
with  other  interventions  to  ensure  coherence  and  avoid  duplication  and  overlaps. 
Interventions  funded  by  different  instruments  fostered  informal  knowledge  of  other  
interventions  as  well  as  engagement  between  a  wide  range  of  stakeholders  at  the 
programming stage. 

Germany83: several coordination mechanisms were mentioned including the coordination 
role  of  the  Responsible  Authority  and  the  establishment  of  coordination  committees. 
Informal information-sharing settings between Member State institutions and units were 
cited in the case study on Germany between the Federal Criminal Police (BKA) and the 
Federal Office for Migration and Flight (BAMF) during meetings and other networking 
events. 

Thirteen  Member  States84  explicitly  mention  having  conducted  an  assessment  of  other 
interventions  at  programming  stage.  For  example,  surveys  were  circulated  with 
beneficiaries  (Italy),  Responsible  Authorities  engaged  with  relevant  stakeholders 
(Bulgaria, Cyprus and the Netherlands). Nonetheless, case studies  on Croatia, Germany 
and Spain suggest stakeholders have limited awareness of assessments carried out in the 
programming stage.  

Coherence with the other Home Affairs Funds (AMIF and ISF-BV) 

The  Home  Affairs  Funds  play  a  key  role  in  tackling  changes  related  to  the  efficient 
management of migration, the EU’s external borders, and ensuring a high level of security 
within the EU. The general provisions for all Home Affairs Funds are under a common 
framework  (i.e.  the  Horizontal  Regulation)  which  ensures  coordination,  coherence  and 
synergies between them. 

82 National ex-post evaluation report of Slovenia. 
83 National ex-post evaluation report for Germany and Case study on Germany. 
84 National ex-post evaluation reports of Belgium, Czechia, Finland, France, Germany, Greece, Hungary, 
Ireland, Italy, Lithuania, Luxembourg, Malta and Slovenia. 

47 

 
 
 
 
 
 
Almost  all  Member  States  indicate  that  their  programmes  are  coherent  with  other  EU 
initiatives and EU funds85. Most national ex-post evaluation reports positively assessed 
the coherence between the Home Affairs Funds, and over half of them (17)86 explicitly 
refer  to  having  implemented  coordination  mechanisms  to  ensure  synergies  and  avoid 
overlaps between them.  

In  several  Member  States,  the  Monitoring  Committee  played  a  key  role  in  overseeing 
coordination and avoiding duplications, meeting regularly to discuss project proposals and 
share information on funding opportunities. For instance, Slovenia reports discussion in 
the Monitoring Committee on the coherence between AMIF and ISF-P to ensure synergies 
and to avoid duplication. 

Coherence with other EU funding Instruments 

Some  beneficiaries  acknowledged  connections  between  ISF-P  and  other  EU  funding 
programmes, such as Horizon 2020, noting that the ISF-P remained distinct in its focus on 
operational support for law enforcement, while Horizon 2020 concentrated on research and 
innovation. However, one interviewee highlighted potential overlaps between ISF-P and 
Horizon 2020 and expressed uncertainty about the relationship between the two funding 
instruments.87  This  concern  was  also  reflected  in  the  survey  results,  where  a  share  of 
respondents  from  Responsible  Authorities  indicated  that  Horizon  2020  did  not 
complement ISF-P activities (17%).  

Concerning  Fiscalis  2020,  the  survey  results  show  that  actions  organised  by  this 
cooperation programme were perceived to complement ISF-P actions to a limited extent 
(26%)  and  to  some  extent  (28%).  This  view  was  also  shared  by  a  small  portion  of 
beneficiary respondents (7%).88 

The Annual Implementation Report from Slovenia mentions that the complementarity of 
ISF-P  projects  with  other  EU  funds  or  EU  financial  instruments  is  discussed  at  the 
Monitoring Committee sessions.  

In  Romania,  targeted  training  for  Ministry  of  Internal  Affairs  personnel  and  coherent 
projects, such as those conducted under the European Anti-Fraud Office’s (OLAF) Hercule 
III programme89, ensured that the objectives remained aligned with broader EU goals.90 In 
the Netherlands, information-sharing mechanisms between the Responsible Authority for 
ISF-P and Horizon 2020 points of contact were put in place.91   

Union Actions have been coherent with actions supported by other EU instruments, such 
as Horizon 2020 and ISF-BV. Furthermore, the objectives and activities of Union Actions 
projects complement and are coordinated with EU-level agencies and bodies (e.g., project 
MAOC-N combatting maritime drug trafficking) and Europol-led initiatives.  

85 National ex-post evaluation reports.  
86 National ex-post evaluation reports of Belgium, Bulgaria, Cyprus, Czechia, Germany, Estonia, Greece, 
Finland, Ireland, Lithuania, Luxembourg, Latvia, Malta, the Netherlands, Romania, Slovenia and Slovakia. 
87 Country case study on the Netherlands. 
88 See Annex V. 
89  Regulation  (EU)  No 250/2014  of  the  European  Parliament  and  of  the  Council  of  26 February  2014 
establishing a programme to promote activities in the field of the protection of the financial interests of the 
European  Union  (Hercule  III  programme)  and  repealing  Decision  No 804/2004/EC.  OJ  L  84,  pp.  6–13. 
ELI: http://data.europa.eu/eli/reg/2014/250/oj. 
90 National ex-post evaluation report from Romania. 
91 Case study on Netherlands; Ex-post evaluation report for the Netherlands. 

48 

 
 
 
 
Coherence with the EU external policy 
Under ‘Specific Objective – fight against crime’, the ISF-P shall contribute to improving 
and  facilitating  the  exchange  of  information  where  relevant  with  third  countries  and 
international  organisations.  The  Horizontal  Regulation  sets  out  that  measures  in  and  in 
relation to third countries supported through the Specific Regulations should be taken in 
synergy and coherence with other actions outside the Union supported through Union (both 
geographic  and  thematic)  external  assistance  instrument.92  More  concretely,  the 
Commission and the Member States, together with the European External Action Service, 
in  accordance  with  their  respective  responsibilities,  must  ensure  that  actions  in  and  in 
relation to third countries93: (a) are coherent with the Union’s external policy, respect the 
principle  of  policy  coherence  for  development  and  are  consistent  with  the  strategic 
programming  documents  for  the  region  or  country  in  question;  (b)  focus  on  non-
development-oriented measures; and (c) serve the interests of the Union’s internal policies 
and are consistent with activities undertaken inside the Union. 

With regards to Union Actions in relation to and in third countries, the  following actions 
are  supported94:  actions  improving  police  cooperation  and  coordination  between  law 
enforcement  authorities;  networking,  mutual  confidence,  identification,  exchange  and 
dissemination  of  know-how,  experience  and  best  practice,  information  sharing,  shared 
situation awareness and foresight, contingency planning and interoperability; acquisition, 
maintenance  and/or  further  upgrading  of  technical  equipment  (incl.  ICT  systems); 
exchange, training and education of staff and  experts of relevant  authorities; awareness 
raising, dissemination and communication activities; threat, risk and impact assessments; 
and studies and pilot projects.  

From  the  perspective  of  external  action  instruments,  while  the  general  objective  of  the 
Instrument for Pre-accession Assistance (IPA II) remains broad, its specific objectives and 
the  thematic  priorities  show  a  degree  of  similarity  to  the  ISF-P  specific  objectives  in 
relation  to  reinforcing  and  promoting  security  and  the  fight  against  corruption  and 
organised crime.95 Under IPA II, ensuring coherence and avoiding duplication with other 
types  of  EU  or  Member  States  assistance  are  of  key  importance.96  Accordingly,  the 
Commission and the Member States cooperate closely through consultations, and frequent 
exchanges of information during the different  phases of the assistance cycle, especially 
during the programming processes.97 

There appears to be limited complementarity between the ISF-P and other existing 
EU instruments with an EU’s external action dimension, as only few Member States 
specifically  report  coordination  between  ISF-P-funded  actions  in  or  in  relation  to  third 
countries.98  

Thus,  as  far  as  coherence  with  external  spending  programmes  is  concerned,  enhanced 
cooperation and coordination on programming both between the Commission services and 
with Member States are needed. Several challenges in the current funding architecture have 
been identified, including notably: the need to further strengthen the link between internal 

92 Recital (8) and Article 3(4) of the Horizontal Regulation. 
93 Article 3(5) of the Horizontal Regulation. 
94 Article 8(3) of the ISF-P Regulation. 
95 Articles 1 and 2 of Regulation (EU) 231/214, respectively. 
96 Articles 5(3) and 5(4) Regulation (EU) 231/2014 
97 Article 5(4) Regulation (EU) 231/2014. 
98 National ex-post evaluation reports.  

49 

 
 
and external priorities in the Union’s external 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  to  improve  cooperation  on  security;  the  limitations  for 
funding  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 intervention make a difference and to whom? 

4.2.1. EU Added Value 

The  ISF-P  has  generated  substantial  EU  added  value  at  EU  level,  primarily  through 
fostering  a  unified  framework  for  addressing  cross-border  internal  security  challenges, 
encouraging  knowledge  exchange  and  the  promotion  of  best  practices.  Its  capacity  to 
harmonise  national  internal  security  efforts  with  EU-wide  priorities  creates  a  cohesive 
approach to crime prevention and internal security.  

The ISF-P fostered cooperation and synergies among Member States, enhancing collective 
responses to internal security threats.  

Findings suggest that the ISF-P achieves EU added value across Member States under three 
main  aspects:  in  a  higher  volume  of  services  offered  (volume  effect),  new  types  of 
intervention  tackled  (scope  effect)  and  increased  the  capacities  of  Member  States  and 
public authorities to manage the funding (role and process effect).  

National  interim  and  ex-post  evaluation  reports99  show  that  ISF-P  support  has  brought 
significant added value across various Member States by enhancing the scope and volume 
of security-related projects (both in project value and investment levels) and increasing the 
speed of project implementation (e.g. MEDOCI4 project).100  

ISF-P support enhances roles and processes through the acquisition of equipment (e.g. IT 
hardware and software development), enhanced infrastructure capabilities (e.g. systems to 
enable data sharing across Member States), and a better understanding of processes and 
know-how for beneficiaries, strengthening their project management skills, capacity for 
information sharing and advancing international cooperation101  

In the case study on Germany, beneficiaries report that ISF-P funding allows projects to 
evolve  over  time  by  enabling  further  development  of  standardised  solutions  and 
involvement of different stakeholders and provide support to prevention and training in the 
field of organised crime enabling the implementation of projects that would not have been 
possible absent ISF-P funding. 

Union  Actions  generate  EU  added  value  by  supporting  initiatives  for  which  national 
funding would not have been available and by producing outputs and results for the benefit 
of all Member States. Union Actions beneficiaries emphasised the crucial importance of 
ISF-P funding for developing and introducing innovative tools and practices as funding for 

99  The  ISF-P  interim  and  national  ex-post  evaluation  reports  for  Bulgaria,  Croatia,  Cyprus,  Czechia, 
Germany, Estonia, Greece, Ireland, Lithuania, Luxembourg, Malta, Spain and Sweden. 
100 National ex-post evaluation report from the Netherlands. 
101 Case study for Spain, Croatia and Germany, and  ex-post evaluations for Austria, Czechia, Germany, 
Estonia, Spain, Finland, Hungary, Ireland, Iceland, Italy, Lithuania, Luxembourg, Malta, Sweden, Slovenia, 
and Slovakia. 

50 

 
 
this purpose was not available in the same amount and timeframe as under Union Actions 
grants.   

EMAS  have  generated  EU  added  value  through  increased  international  cooperation, 
information  exchange  between  Member  States  against  terrorist  threats,  and  crisis 
management  in  the  aftermath  of  terrorist  attacks.  Given  the  transnational  nature  of  
organised crime and terrorism, EMAS projects benefited Member State in advancing the 
protection  of  public  spaces,  the  increased  capacity  to  collect  intelligence  and  the 
development of exercises.  

Consequences of absence of ISF-P funding 
Absent  ISF-P  funding,  several  Member  States  would  struggle  to  carry  out  actions  to 
support the implementation of EU policies in internal security102. Findings show that in 
some Member States, certain projects would have been difficult to implement or would not 
have been implemented absent ISF-P support (e.g. equipment purchases such as explosive 
ordnance disposal  robots)103. In other Member States,  certain  projects  would have been 
prioritised to ensure compliance with the EU acquis, while others would have received less 
to no funding due to national budgetary constraints104.   

The ISF-P supported Member States with national budgetary constraints, enabling them to 
implement  projects  critical  in  strengthening  their  internal  security  capabilities  and 
infrastructure. For instance, Bulgaria’s law enforcement authorities, have greatly benefited 
from long-term ISF-P investments in infrastructure and crime prevention, while Croatia 
has  enhanced  its  internal  security  infrastructure,  ensuring  its  alignment  with  EU 
requirements despite national financial constraints.  

Nonetheless, a few Member States would have been able to secure national funding. For 
instance,  the  Netherlands  reports  that  absent  ISF-P  support,  projects  relating  to  the 
implementation  of  Regulation  (EU)  98/2013105  on  the  marketing  and  use  of  explosive 
precursors  and  Directive  (EU)  2016/681106  on  the  development  of  a  national  Passenger 
Information Unit would have been carried out with national funding107. 

As highlighted in the case study on Union Actions, beneficiaries agreed that absent ISF-P 
funding, it would have been impossible to implement their projects in the same scale and 
timeframe, and that the financial support generated EU added value that no Member State 
would have been able to achieve on its own.  

Consequences of interruption of ISF-P funding 
National ex-post evaluation reports show that interrupting ISF-P support would have had 
disruptive  consequences  across  Member  States  to  varying  degrees,  ranging  from  an 

102  The  national  ISF-P  interim  evaluation report  for  Latvia,  Portugal,  Romania;  ISF-P  ex-post  evaluation 
reports for Belgium, Hungary, Ireland, Italy, Latvia, Romania and Spain. 
103 Case studies for Croatia and Spain; ex-post evaluation reports for Belgium, Bulgaria, Hungary, Ireland, 
Italy, Lithuania and Slovenia. 
104 Ex-post evaluation report for Czechia, Germany, Finland, Luxembourg, Malta, Sweden and Slovakia. 
105 Regulation (EU) No 98/2013 of the European Parliament and of the Council of 15 January 2013 on the 
marketing  and  use  of  explosives  precursors  Text  with  EEA  relevance.  OJ  L  39,  9.2.2013,  pp.  1–11. 
ELI: http://data.europa.eu/eli/reg/2013/98/oj. 
106 Directive (EU) 2016/681 of the European Parliament and of the Council of 27 April 2016 on the use of 
passenger name record (PNR) data for the prevention, detection, investigation and prosecution of terrorist 
offences and serious crime. OJ L 119, 4.5.2016, pp. 132–149. ELI: http://data.europa.eu/eli/dir/2016/681/oj. 
107 Case study on the Netherlands.  

51 

 
 
inability  to  meet  regulatory requirements to  the  reduced efficiency  and effectiveness  of 
specific individual projects due to changes in priorities.  

The case study on Spain indicates that the interruption of ISF-P support would likely result 
in  slower  progress,  reliance  on  outdated  resources,  and  challenges  in  sustaining  and 
adapting projects. Many projects would not continue, although essential projects might still 
have been implemented, albeit less efficiently and at a slower pace. For instance, Spanish 
beneficiaries stated that the Civil Guard would have to assume the costs of maintaining 
equipment like robots, leading to reliance on obsolete means and slower implementation.  

The case study on Croatia evidence that an interruption in ISF-P support would likely lead 
to  significant  disruptions  in  implementing  internal  security  projects  as  many  projects 
would not proceed, given national budget constraints.  

The case study on Germany evidence that operating costs of the respective investments  
(e.g.  IT  systems,  equipment  or  vehicles)  would  have  been  secured  by  national  budgets  
should  the  support  have  been  interrupted.  Nonetheless,  projects  involving  research 
organisations or civil society organisations would likely have no longer received funding 
and some cuts relating to personnel could have taken place following an interruption of the 
ISF-P funding. 

Benefits of ISF-P support at EU level  
Across  Member  States,  benefits  identified  at  EU  level  primarily  relate  to  information-
sharing, data interoperability, cooperation and networking.108 For instance, the ISF-P has: 

• 

facilitated the exchange of knowledge and resources, acting as a catalyst for further 
EU actions and supporting innovation (Belgium);  

•  supported training and information  exchange programmes that would have been 

less frequent and intensive without EU support (Finland);  

• 

improved  security  and  information  exchange  procedures  between  Latvian 
institutions and other Member States, facilitating better cooperation in combating 
cybercrime and other internal security threats (Latvia); 

•  strengthened  cooperation  with  other  Member  States  through  projects  like  the 
“Prüm Exchanges,” which enhanced information sharing and interoperability at EU 
level (Luxembourg);  

•  advanced  the  adoption  of  standardised  processes  across  Member  States,  which 

resulted in wider benefits at EU level (France).   

As highlighted in the case study, Union Actions projects have generated EU added value 
at EU level, by:  

•  having a strong transnational component both in terms of the geographic scope of 
their  beneficiaries  and  in  the  impact  of  their  activities.  Union  Actions  projects 
produce outputs and results which benefit multiple Member States and/or the EU 

108 Case study on Croatia and Germany; national interim and ex-post evaluation reports for Austria, Belgium, 
Germany,  Greece,  Ireland,  Italy,  Lithuania,  Luxembourg,  Malta,  The  Netherlands,  Portugal,  Slovenia, 
Slovakia and Spain. 

52 

 
 
as  a  whole  when  new  expertise  or  skills  are  generated.  For  instance,  the 
advancement of facial recognition investigation techniques (TELEFI), training on 
law enforcement response to potential terrorist attacks by drones (SKYFALL), and 
open information platforms containing EU-wide data on violent incidents involving 
firearms (INSIGHT).  

•  supporting  the  uninterrupted  operation  of  established  and  newly  emerging 
transnational law enforcement networks which play a critical role in enhancing the 
cooperation  in  several  policy  fields  by  bringing  together  practitioners  from  all 
Member  States  interested  in  a  specific  field  (e.g.  forensics,  anti-corruption,  and 
crime prevention). 

•  being the primary instrument for enhancing cooperation with third countries and 
international  organisations.  For  instance,  the  Common  Operational  Partnerships 
(SCOPE) project sought to enhance collaboration and information sharing with law 
enforcement  agencies  in  Türkiye  and  Western  Balkan  countries  against  illegal 
migrant  smuggling.  Other  forms  of  cooperation  with  third  countries  were 
implemented  under  indirect  management,  e.g.  contribution  contracts  with  UN 
bodies, such as the United Nations Office on Drugs and Crime (UNODOC) and the 
United Nations Interregional Crime and Justice Research Institute (UNICRI).  

•  promoting  innovation  and  transfer  of  best  practices  by  developing  training 
materials for building new skills and expertise (SKYFALL, EXIT EUROPE), and 
exploring  new  approaches  and  tools  to  tackle  emerging  challenges  (TELEFI, 
INSIGHT, CICERO). For instance, the AIRPOL network contributes to enhancing 
the  security  of  airports  and  the  aviation  sector  by  exploring  and  disseminating 
innovative practices and providing training in behaviour detection, insider threats 
and reaction to serious incidents at airports. 

•  contributing to the involvement of civil society and private sector stakeholders in 
most  of  the  policy  fields,  and  particularly,  concerning  counterterrorism  and 
prevention of radicalisation, combating cybercrime and child sexual abuse, where 
most projects were initiated and coordinated by beneficiaries from the private and 
non-profit sectors.  

EMAS has generated substantial EU added value as it supported individual Member States 
in  managing  specific  internal  security  incidents  or  emerging  threats  (e.g.  heightened 
terrorist threats). It also significantly strengthened operational cooperation and information 
exchange  across  the  EU  through  strengthened  protection  of  public  spaces,  enhanced 
prevention of terrorist  attacks, and improved  crisis  management in  response to  terrorist 
incidents or attacks on critical infrastructure.109 

EMAS actions such as the project of the French Ministry of Interior110, EU-ACTION, EU-
SIUTEx,  HORUX,  and  COMPSAT  generally  enhanced  the  capacities  of  police  and 
intelligence  services  in  Belgium,  Spain  and  France  to  gather  and  exchange  intelligence 
data,  process  and  analyse  large  volumes  of  video  data  by  acquiring  or  developing 
innovative tools. These projects achieve EU added value to several Member States. First, 
by raising awareness about effective new approaches, ICT tools, and crisis management 

109 Case study on EMAS. 
110 Project ‘Acquisition d'une solution informatisée d'analyse des données vidéo de masse’. 

53 

 
 
solutions  and  transfer  of  accumulated  experience  and  results  to  other  countries.  For 
example, the results of EU-ACTION and EU-SUITEx projects were shared within the EU 
Special Intervention Units Working Group ATLAS. Second, acquired tools also allow the 
running of common operations/exercises between EU special intervention and supporting 
units with the acquired new tools.  

As  highlighted  in  the  case  study  on  EMAS,  projects  also  benefited  EU  citizens  since 
criminal  investigations  of  such  complex  crimes  as  terrorism  and  organised  crime  are 
usually the result of operational cooperation between Member States, whereby enhanced 
capacities in one Member State enhance the investigative capacities of the other Member 
States. For instance, a project implemented by the French Ministry of Interior where the 
acquired mass video processing device to speed up the investigation of the terrorist attack 
in Paris was also used by the Belgian police authorities for the investigation of the terrorist 
attack in Brussels. The French Ministry of Interior shared the gained experience with the 
police and gendarmerie authorities in all Member States and announced that the tool will 
also be available to other interested partners. Similarly, the OSINT tool acquired by the 
Guardia  Civil  within  project  HORUX  is  regularly  employed  during  joint  investigations 
with other EU law enforcement agencies.  

4.2.2. Sustainability 

The examination of sustainability serves to assess whether the positive effects of projects 
supported by the ISF-P are likely to endure once its support ends.  

Findings suggest that the positive effects of ISF-P funded projects are likely to last 
beyond the programming period.  

Member States put in place strategies to ensure more sustainable outcomes and benefits of 
ISF-P-funded  projects,  e.g.  allocation  of  national  funds  for  maintenance  support, 
commitments  to  maintain  key  infrastructure,  and  the  establishment  of  networks  for 
ongoing  collaboration.  Trainings  developed  during  ISF-P  funded  projects  are  often 
integrated and continued as part of the daily work of national law enforcement authorities.  

Overall, stakeholders have reported that many actions and positive effects funded under 
the  ISF-P  are  likely  to  last.  Nevertheless,  seven  Member  States  authorities  (Bulgaria, 
Estonia,  Finland,  Germany,  Malta,  Poland  and  Spain)  and  some  Union  Actions 
beneficiaries reported certain difficulties in measuring the sustainability of project results 
with quantitative indicators. Project results are not always quantifiable, and stakeholders 
stated that oftentimes, the evaluation of long-term impact should be complemented with 
qualitative  assessments,  such  as  projects  with  significant  components  on  trainings  and 
awareness-raising111.  

Specific and horizontal mechanisms to ensure sustainability 
To  ensure  sustainability,  Member  States  have  set  mechanisms  at  both  the 
programming  and  implementation  stages.  The  national  ex-post  evaluation  reports, 
country  case  studies  and  interviewed  stakeholders  show  that  specific  and  horizontal 
mechanisms  were  in  place  to  phase  out  EU  funding  after  the  ISF-P  support  has  been 
exhausted. 

111 First focus group. 

54 

 
 
At  the  programming  stage,  national  authorities  required  the  alignment  of  ISF-P-funded 
projects with national strategic priorities and national programmes. National programmes 
have  often  been  developed  in  broad  consultation  with  stakeholders  and  beneficiaries 
thereby,  allowing  targeting  the  relevant  needs  and  ensuring  sustainability112  before 
submitting the national programmes to the Commission’s approval.  

The national ex-post evaluation reports of Belgium, Bulgaria, Germany, Finland, Lithuania 
and  the  Netherlands  reported  that  significant  emphasis  is  placed  on  checking  whether 
project  proposals  align  with  national  and  EU  level  objectives,  thus  allowing  for  the 
continuation of funding from national budgets after the end of an ISF-P funded project. 
Moreover, the selection process focused mainly on project proposals targeting trainings, 
development  of  IT-systems,  investing  in  equipment  and  strengthening  national 
institutional  capacities.113  Concrete  examples  include  projects  involving  technological 
innovations and the development of databases to be integrated into the existing national 
systems (Estonia, Germany and Spain).  

The national ex-post evaluation reports show that: 

•  Member States often invest in equipment to ensure sustainability after funding from 

ISF-P has been exhausted; 

•  Sustainability checks include application forms  where  applicants  are required to 
provide  statements  on  how  sustainability  will  be  ensured  (Bulgaria,  France, 
Germany,  Italy,  Slovenia  and  Slovakia),  and  to  provide  information  on  further 
development and possible follow-up projects after a project ends (Croatia, Finland, 
Germany, Hungary, Italy and Poland). 

• 

In Belgium, Bulgaria, Estonia, Spain, Finland, Luxembourg, Malta and Slovakia, 
national  funds  were  allocated  for  maintenance  of  systems  and  equipment  at  the 
programming  stage  to  ensure  their  sustainability  after  ISF-P  funding  ends.  For 
instance, Malta allocated budgetary resources to ensure the continued operation and 
maintenance of ISF-funded infrastructure and equipment, while Luxembourg has 
made commitments to maintain critical response capabilities (e.g. its involvement 
in  the  ATLAS  Group  for  CBRN  responses,  ensuring  that  it  aligns  with  EU 
standards for continued preparedness). 

During  the  implementation  stage,  Member  States  have  introduced  sustainability  checks 
which  range  from  strict  requirements  to  informal  check-ins.  The  national  ex-post 
evaluation reports evidence that beneficiaries are often required to commit to the continued 
use and maintenance of infrastructure and equipment after the programming period ends. 
Some  Member  States  conduct  regular  check-ins  and  process  project  evaluations  to 
maintain sustainability (Austria, Belgium, Germany, Italy and Poland) and require written 
declarations  on  continued  use  of  funded  infrastructure  and/or  equipment  and  on-site 
follow-up checks (Malta). On the other hand, the national ex-post evaluation reports of 
Cyprus, Finland, the Netherlands, Slovenia and Slovakia indicate informal discussions and 
check-ins are preferred over formal sustainability checks. 

112 National ex-post evaluation reports of Member States, and case studies on Germany and Croatia. 
113  The  case  studies  on  Germany  and  Croatia;  Ex-post  evaluation  reports  of  Austria,  Bulgaria,  Cyprus, 
Czechia, Estonia, Spain, Finland, Ireland, Lithuania, Luxembourg, Netherlands, Poland, Sweden, Slovenia. 
Additional interviews with Finland, France, Italy and Bulgaria. 

55 

 
 
Dependencies on EU funding 

The  analysis  of  national  ex-post  evaluation  reports,  case  studies  and  interviews  with 
stakeholders demonstrate varying degrees of dependency on EU funding.  

In  some  Member  States114,  the  continuation  of  ISF-P  projects  has  been  secured  with 
national funding, while in others, the ISF (Croatia and Slovenia) or other EU funds, such 
as Horizon 2020, Border Management and Visa Instrument (BMVI) and AMIF (Finland, 
Italy and Latvia) have been used to secure funding for projects started with ISF-P support. 

National ex-post evaluation reports and stakeholder views show that actions and results 
are expected to continue after the funding under ISF-P has been exhausted and projects 
have ended.115 Many projects across the different fund components (national programmes, 
Union Actions  and EMAS)  have been replicated, upscaled,  continued and/or integrated 
into existing systems and tools.  

Survey  responses  support  this  finding  (Figure  19),  whereby  46%  of  201  respondents 
considered the outcomes and benefits of the project to have been sustainable over time to 
a large extent and 32% to some extent, whereas only 4% of respondents  answered  to a 
limited extent. 

Figure 19 - Stakeholder responses on the extent the outcomes and benefits of the projects funded 
under ISF-P (2014-2020) have been sustainable over time. 

To what extent have the outcomes and benefits of the projects funded under 
ISF-P (2014-2020) been sustainable over time?

1% 4%

17%

32%

46%

Not at all

To a limited extent

To some extent

To a large extent

I don't know

Source: Preparatory study based on survey responses 

Several  Member  States’  projects  have  been  transferred,  replicated  or  upscaled.  In 
Germany the project ‘Warning the Population’ entailed the ability to extend the number of 
users receiving alerts to connect to neighbouring countries (Belgium). In Spain, projects 
on the integration of databases into national systems have produced expertise that can be 

114 Estonia, France, Germany, Slovakia and Spain. 
115 National ex-post evaluation reports; additional interviews with Member States and UA-projects. 

56 

 
 
 
applied  to  similar  projects  in  the  future.  In  Croatia,  a  project  in  the  Service  for  Crime 
Operations involved purchasing software which offers extensive educational activities in 
the field of cybersecurity and criminal intelligence. Finally, in Croatia, Cyprus, Finland 
and Germany, knowledge and experiences from training courses are transferred to police 
officers at various levels and units.  

Union  Actions  projects  have  demonstrated  sustainability,  particularly  those  focused  on 
networking and cross-border cooperation, which provide a platform for the sharing of best 
practices, knowledge, and resources, further embedding sustainability into the project from 
the  onset. For  instance,  the  Vulnerability  Assessment  Tool  was  tested  through  funding 
under  Union  Actions  and  is  still  used  in  cities  within  the  EU.  A  handbook  was  also 
developed to accompany the tool, and demonstrations were organised to showcase its use. 
It was also used in the QROC project116 and closely linked to the ProTECT project, both 
of which serve as the basis for the Secu4All-project.117 This example showcases three UA-
projects building upon the respective results, which highlights the sustainable nature of the 
projects.  

Some Union Actions projects that received ISF-P funding118 (ENLETS, AQUAPOL, @ON 
Network, MAOC-N, and SCOPE) have also been successful in securing funding under the 
ISF, which indicates the support for sustaining their achievements. Nonetheless, the case 
study on Union Actions indicate that certain challenges remain in ensuring sustainability, 
such as difficulties in maintaining project outputs (websites and online platforms) due to 
their need for ongoing maintenance. 

The inherent design of EMAS projects is to address immediate needs. The case study on 
EMAS  evidence  that  despite  their  short-term  duration,  most  projects  have  maintained 
sustainability through several mechanisms, such as:  

• 

• 

the use, integration and further development of tools (e.g. projects EU-ACTION, 
EU-SUITEx and EU-SIUEV),  

the continuance of operations and experience sharing as illustrated by Europol’s 
initiatives  in  which  it  established  a  lasting  presence  in  migration  hotspots 
expanding  from  a  few  stations  in  Greece  and  Italy  to  31  stations  across  11 
countries, and 

• 

focus on IT solutions and information exchange systems.  

Member States have prioritised the development of skills and expertise to ensure that the 
benefits of ISF-funded projects persist over time. Training programmes have been integral 
in ensuring that personnel are equipped with the knowledge and capabilities to effectively 
use and maintain new systems and technologies in the long run.  

4.3. Is the intervention still relevant?  

The  ISF-P  has  largely  addressed  the  needs  identified  at  the  time  of  its  adoption  and 
remained fit to address the changes and needs which emerged during its implementation.  

116 The case study on The Netherlands. 
117 Additional interview with Secu4All. 
118 The case studies on Croatia, the Netherlands and on Union Actions; Additional interview with ENLETS. 

57 

 
 
This Instrument was set up to contribute to ensuring a high level of security within the EU. 
Within this general objective, the ISF-P shall further two specific objectives. First, its aims 
at preventing and combating cross-border, serious and organised crime including terrorism 
(‘Specific  Objective  –  fight  against  crime’).  To  achieve  this,  the  ISF-P  focused  on 
reinforcing  coordination  and cooperation between law enforcement  authorities. Second, 
the ISF-P aims at managing risks and crisis. This objective is centred on  enhancing the 
capacity  of  Member  States  and  the  EU  to  manage  security-related  risks  and  crises 
effectively. It also entailed preparing for and protecting people and critical infrastructure 
against  terrorist  attacks  and  other  security-related  incidents  (‘Specific  Objective  –  risk 
management’). 

To  effectively  address  the  internal  security  challenges,  in  2010,  the  Council  of  the 
European Union stressed the need for a more integrated approach to EU internal security. 
This is in line with the Stockholm Programme, which called for the creation of a Fund to 
support  the  implementation  of  the  Internal  Security  Strategy  and  a  coherent  and 
comprehensive approach to internal security.119  The ISF-P was designed to respond to the 
2010 Internal  Security Strategy for the European Union adopted by the Council, which 
identified  the  internal  security  threats  and  challenges  faced  across  Member  States. 
Furthermore, the ISF-P was designed with the aim of overcoming the limitations of ISEC 
and CIPS and better respond to evolving internal security threats. To this end, the following 
key policy areas were identified: 

•  Counterterrorism,  incl.  prevention  of  radicalisation,  protection  of  public 
spaces,  critical  infrastructure:  Since  the  early  2000s,  protecting  citizens  from 
terrorist  threats  has  remained  central  to  the  EU  political  agenda.  The  EU  and 
Member States cooperated closely and increased their counterterrorism efforts over 
time  by  pre-empting  and  disrupting  terrorist  attacks,  coordinating  efforts, 
preventing radicalisation, and sharing information. At the time of the adoption and 
during  the  implementation  of  the  ISF-P,  terrorist  threats  were  marked  by  an 
increasing  cross-border  dimension,  and  a  corresponding  need  to  enhance  and 
coordinate  actions  of  Member  States’  relevant  authorities,  enacting  targeted 
terrorism  and  prevent 
legislation, 
radicalisation,  and  limiting  terrorists’  access  to  CBRN-E  materials,  as  well  as 
protecting critical infrastructure.120  

implementing  action  plans 

tackle 

to 

•  Organised  crime  (drug  trafficking,  THB,  firearms  trafficking,  migrant 
smuggling, corruption and money laundering): When the ISF-P was adopted, 
organised  crime  networks  had  become  more  transnational  and  professionalised. 
Globalisation  and  technological  advancements  had  enabled  the  development  of 
more  sophisticated  criminal  structures  by  organised  criminal  groups,  which  was 
increasingly  coupled  with  corruption,  money  laundering  and  the  subsequent 
infiltration into the legal economy. The ISF-P was set to significantly contribute to 
the prevention of and fight against cross-border organised crime and was part of 
the EU's response to tackling new forms of organised crime.  

•  Cybercrime  and  child  sexual  abuse:  The  exponential  increase  in  internet 
connectivity and subsequent interconnectedness of different parts of the world has 
allowed the increase in cyber-attacks and cybercrime. Similarly, child sexual abuse 

119 The Stockholm Programme – An open and secure Europe serving and protecting citizens, 2010/C 115/01.  
120 SEC(2011) 1358 final. 

58 

 
 
has  become  more  prevalent  during  the  rise  of  online  platforms  and  digital 
communications,  and  law  enforcement  authorities  faced  difficulties  in  gathering 
evidence in the online environment. The ISF-P was designed to better tackle the 
rise in cyber-attacks and cybercrime.  

•  Law  enforcement  cooperation  (cross-border  operational  cooperation): 
Criminal  activities  have  increased  their  cross-border  dimension,  and  criminal 
groups  cross  borders  and  jurisdictions  to  exploit  the  gaps  left  by  non-fully 
integrated  national  systems.  To  deliver  on  the  priorities  identified  by  the  2010 
Internal Security Strategy, the ISF-P aimed to provide support to Member States to 
effectively  tackle  cross-border  crimes,  enhance  operational  cooperation  between 
national law enforcement authorities, and support the development of the necessary 
capabilities.  

•  Information  exchange:  The  increased  cross-border  nature  of  serious  and 
organised  crime  requires  a  continuous  exchange  of  information  among  Member 
States’  competent  authorities.  The  2010  Stockholm  Programme  highlighted  the 
need to further develop law enforcement cooperation instruments in the EU.121 The 
2015 European Agenda on Security reiterated this priority, highlighting the need 
to further develop and maintain existing information exchange systems. In light of 
internal security concerns increasingly having a cross-border nature, the ISF-P had 
the  objective  to  improve  information  exchange  between  law  enforcement 
authorities.  

•  Cooperation with third countries: The links between EU internal and external 
security threats have become more apparent during the ISF-P programming period. 
Events  occurring  outside  the  EU  had  spill-over  effects  on  the  EU’s  internal 
security. The  ISF-P aimed at strengthening the links and coherence between the 
internal and external security. 

During the 2014-2020 programming period, major events led to changes in the EU internal 
security landscape, which prompted revisions in  the internal  security  approaches at  EU 
level and in the national programmes of Member States. The terrorist attacks in Europe 
highlighted  the  need  for  the  EU  to  provide  a  quick  response  to  these  significant 
challenges122, and formulated the European Agenda on Security. 

The  interim  evaluation  of  the  ISF-P  concluded  that  its  objectives  were  relevant  and 
comprehensive to the main internal security challenges at both national and EU level. ISF-
P-funded projects delivered relevant results in counterterrorism and radicalisation, serious 
and organised crime, responding to the increasing need of Member States and the EU to 
respond to the internationalisation and professionalisation of organised criminal networks 
in a changing security environment. The interim evaluation also found that changes in the 
internal  security  landscape  occurring  during  the  programming  period  were  considered 
during the implementation  of the  ISF-P.  For instance, in  view of evolving needs, some 
Member States adjusted their national programmes.  

Correspondence of the objectives of the ISF-P funded interventions to actual needs 

121 Council document 17024/09 of 1-2/12/2009; The Stockholm Programme.  
122 SWD(2018) 341 final. 

59 

 
 
The  objectives  of  the  ISF-P  generally  corresponded  to  the  actual  needs  identified  by 
stakeholders when addressing the main internal security challenges. Some adjustments to 
the initially set priorities were made at EU and national levels to  ensure adaptability to 
emerging needs during the Instrument’s implementation  

National Programmes 

Member States designed their national programmes and submitted them to the Commission 
for their assessment and approval to ensure that the programmes priorities and objectives 
responded  to  the  key  needs  and  policy  priorities  identified  at  EU  and  national  level123. 
Furthermore,  the  programmes  provided  information  specific  to  their  internal  security 
national context (national strategies, policies and legislation).  

Prior  to  submitting  the  national  programmes  for  Commission  approval,  a  consultation 
process took place at EU and national level.  

At  EU  level,  the  consultation  process  consisted  of  a  policy  dialogue  between  Member 
States and the Commission124 to ensure alignment of the national mapping of needs/trends 
with the ISF-P’s objectives and with those identified at EU and national levels. These high-
level policy dialogues were considered particularly useful and offered the opportunity to 
exchange views and highlight specific policy fields/activities that should be considered in 
the preparation and approval of the national programmes125. 

At  national  level,  Member  States  conducted  needs  assessments  and  consulted  relevant 
stakeholders  to  ensure  that  national  programmes  reflected  key  needs  and  policy 
priorities.126  Three  Member  States  (Cyprus,  Czechia  and  Italy)  reported  that  the 
consultation process mostly involved national authorities active in the ISF-P policy fields 
as they had a better understanding of the issues at stake and could better contribute to the 
identification  of  needs127  The  consultation  of  civil  society  organisations  in  the  needs 
assessment (and implementation of ISF-P projects) took place in certain policy fields, such 
as the fight of human trafficking, where these organisations are often involved. 

The  ISF-P Regulation  required each Member State to  allocate the amounts for national 
programmes  (indicated  in  Annex  III)  as  follows:  at  least  20  %  for  actions  relating  to 
‘Specific Objective – fight against crime’; and at least 10 % for actions relating to ‘Specific 
Objective  –  risk  management’.128  Member  States  may  depart  from  these  minimum 
percentages provided that they include an explanation in the national programme as to why 
allocating resources below that level would not jeopardise the achievement of the relevant 
objective129.  

There are also certain limitations on the total allocation under national programmes, i.e. 
Member  States  shall  not  use  more  than  8%  of  their  total  allocations  under  the  national 
programme for the maintenance of EU and national IT systems, and not more than 8% for 

123 Articles 14(3) and 14(5) of the Horizontal Regulation.  
124 Article 13(1) of the Horizontal Regulation. 
125 See Annex V. 
126 Country case study on Spain and additional interviews with the Responsible Authorities from Italy, Spain 
and Latvia. 
127 Additional interviews with the Responsible Authorities from Cyprus, Czechia and Italy. 
128 Articles 5(6)(a) and 5(6)(b) of the ISF-P Regulation. 
129 Articles 5(6) of the ISF-P Regulation. 

60 

 
 
actions in relation to or in third countries which implement the strategic Union priorities 
set out in Annex I to the ISF-P Regulation130. 

The national programmes were prepared in line with the respective key EU and national 
strategies adopted by national governments. A comprehensive needs analysis conducted 
at national level provides an overview of the Member States’ key needs in the relevant 
policy fields, with a particular focus on counterterrorism and organised crime.  

Table 10 - Overview of needs identified in the National Programmes per policy fields 

MS  Counter-terrorism, 

Organised crime, 

Cybercrime, 

Law 

Information 

Cooperation 

incl. prevention of 

incl. drug and 

incl. child 

enforcement 

exchange  

with third 

radicalisation, 

firearms 

protection of public 

trafficking, s, 

sexual 

abuse 

spaces, critical 

migrant 

infrastructure/ 

entities 

smuggling, 

corruption, 

money laundering 

cooperation 

countries 

(cross-

border 

operational 

cooperation  

AT 

BE 

BG 

CY 

CZ 

DE 

EL 

EE 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Source: Preparatory study based on the analysis of national programmes 

130 Article 7(2) of the ISF-P Regulation.  

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  national  ex-post  evaluation  reports  confirm  that  the  objectives  set  by  the  Member 
States’ national programmes responded to the identified needs.  

Some Member States expressed the preference to focus strategically on a limited number 
of policy fields and activities based on their national context given the limited resources of 
the ISF-P and to avoid dispersion of resources among all possible fields.131   

There is a general consensus among stakeholders that the ISF-P-supported activities 
adequately  addressed  the  needs  of  various  target  groups  involved  in  internal 
security.132 The national interim evaluation reports evidence that the objectives of the ISF-
P-funded  projects  generally  corresponded  to  the  needs  identified  in  Member  States 
programmes.  

The  Final  Implementation  Reports  evidence  that  Member  States  adopted  varied 
approaches  to  engage  stakeholders  and  ensure  transparency  in  the  programming  and 
implementation phase, as well as to ensure alignment of objectives with actual needs. For 
instance, in Austria, Poland and Romania, the alignment of objectives with actual needs 
was ensured through the early involvement of (potential) beneficiaries133.  

The COVID-19 pandemic posed some challenges to the consultation of stakeholders and 
functioning  of  the  Monitoring  Committees,  necessitating  swift  adaptations,  such  as 
adopting digital communication tools to keep the stakeholders connected and informed, 
and transitioning from traditional in-person meetings to virtual meetings.134 

The  national  ex-post  evaluation  reports,  the  Annual  and  Final  Implementation  Reports 
highlighted changes in needs throughout the 2014-2020 programming period. As a result, 
several Member States dedicated allocations to organised crime (13)135 and exchange 
of  information  (14)136,  with  many  national-level  projects  setting  up  and/or  further 
developing national ICT capabilities to respond to internal security concerns.  

Figure 20 provides an overview of allocations under shared management per policy field 
and Member State during the entire implementation period.  

131 Additional interviews with the Responsible Authorities from Cyprus, Czechia and Italy. 
132 Survey question Q7: ‘Which approach did you follow to define your strategy and identify your needs 
when preparing the National/ Member State Programme for your country?’. 25 responses for option: ‘The 
needs  assessment  and  programme  strategy  was  done  primarily  based  on  consultations  with  relevant 
stakeholders’. 
133 National interim evaluation reports. 
134 Based on the review of the Annual and Final Implementation Reports. 
135 BG, CZ, DE, EL, ES, FI, FR, HR, NL, PL, RO, SI, and SE. 
136 CZ, EE, ES, FI, HU, IT, LT, MT, NL, PL, PT, SK, SI, and SE. 

62 

 
 
Figure 20 - Allocation of paid resources under shared management by policy field and by Member 
State 

Source: Preparatory study 

Measures to address changing needs 

the 

During 
implementation  period,  Member  States  amended  their  national 
programmes to respond to the changing internal security environment and emerging 
needs.  

The interim evaluation of the ISF-P reported that the scope of the national programmes 
were  sufficiently  broad  and  flexible  to  accommodate  changing  needs  in  the  internal 
security landscape. 

The  ISF-P  original  rationale  and  objectives  were  still  relevant  in  the  aftermath  of  the 
migratory and related security challenges confronted by the EU. Monitoring and evaluation 
mechanisms  played a significant  role in  maintaining  the relevance of  its objectives  and 
ensuring national programmes effectively responded to evolving policy needs.  

The mid-term review also allowed for a more comprehensive reassessment of needs and a 
dialogue with the Commission, including the possibility to amend the national programme 
where  necessary137.  Member  States  have  performed  needs  assessments  on  a  regular 
basis,  and  several  of  which  have  reviewed  and  updated  their  respective  national 
programmes during the mid-term review process.138 For instance, in Latvia changing needs 
included the construction of new training facilities and a laboratory for ballistic and the 
growing interest in training and information exchange.  

Furthermore,  additional  amounts  were  allocated  to  the  Member  States  national 
programmes to adapt to changes and evolving needs, i.e. to support the Implementation 

137 Articles 10, 13(4) and 15(1) of the Horizontal Regulation.  
138  Country  case  studies  on  Germany,  Croatia  and  Spain;  interim  evaluation  reports  and  Annual 
Implementation Reports of Croatia, Germany, Hungary and Latvia. 

63 

 
 
 
Plan  for  Directive  (EU)  2016/681  and  the  development  of  information  exchange  and 
interoperability tools (Section 3.3).  

While  acknowledging  the  Instrument’s  flexibility,  the  interim  evaluation  of  the  ISF-P 
reported that Member States called for more room for manoeuvre by way of not requiring 
minimum allocations to ‘Specific Objective – fight aganst crime’ and ‘Specific Objective 
– risk management’.  

The national interim evaluation reports of Austria, Estonia, Germany, Latvia, Slovenia and 
Slovakia highlight that structured governance frameworks overseeing the implementation 
and monitoring of ISF-P projects have been established. Monitoring Committees were set 
up to support the implementation of the national programmes and facilitate coordination 
and  discussion  of  evolving  national  needs  among  various  stakeholders,  including 
governmental bodies, civil society organisations, and beneficiary entities.  

During  the  implementation  phase,  some  Member  States  faced  challenges  in  fully 
addressing  all  relevant  needs  due  to  budget  constraints  (Greece  and  Portugal),  and 
consequences  of  the  COVID-19  pandemic  and  the  Russian  war  of  aggression  against 
Ukraine,  such  as  inflation  (Finland,  Malta  and  Poland),  limited  availability  of 
(construction)  materials139  delays  in  public  procurement  procedures  (e.g.  to  acquire 
specialised equipment and/or services).140 The Annual and Implementation Reports of 18 
Member States141 report delays and difficulties in continuing projects during the pandemic 
which led to extending projects to ensure completion.  

Union Actions 

The  ISF-P  financed  transnational  actions  or  actions  of  particular  interest  to  the  Union 
concerning the general, specific and operational objectives under primarily direct and, to 
a lesser extent, indirect management. Union Actions complemented the support provided 
under shared management.   

The Commission defined in the Annual Work Programmes the priorities and objectives for 
each  year,  including  the  priorities  for  the  calls  for  proposals.  The  objectives  set  in  the 
Annual Work Programmes142 for Union Actions were in line with those of the EU Internal 
Security Strategy, the European Agenda on Security and also addressed the actual needs 
identified in the key policy fields based on threat assessments.  

To deliver on the Annual Work Programmes objectives, the calls for proposals focused on 
supporting projects capable of delivering results. Nonetheless,  the interim evaluation of 
the  ISF-P  reported  that  some  stakeholders  raised  concerns  on  the  definition  and 
presentation of the rationale for the selection of priorities and calls for proposals, which 
were considered by some stakeholders as not sufficiently clear. 

Support  was  provided  via  action  grants  (calls  for  proposals  and  direct  awards), 
procurement contracts and delegation agreements. The bulk of funding under action grants 
was given to projects tackling counterterrorism and organised crime, while procurement 

139 Final Implementation Report for EE, IE, MT and PL. Additional interview for the ISF-P: CY MA. 
140 Review of Final Implementation Report for IT, LV, PT, and SK, and additional interview with responsible 
Authorities of Czechia and Italy. 
141 Austria, Belgium, Cyprus, Czechia, Estonia, Finland, Germany, Hungary, Ireland, Italy, Latvia, Lithuania, 
Poland, Portugal, Romania, Spain, Slovakia and Sweden. 
142 2014-2020 Annual Work Programmes. 

64 

 
 
contracts was channelled to the prevention of radicalisation, combatting organised crime 
and  corruption  and,  particularly,  to  counterterrorism  by  ensuring  the  functioning  of  the 
Radicalisation Awareness Network (RAN).143  

The case study on Union Action evidence that in addition to law enforcement authorities, 
the  implementation  of  projects  had  the  involvement  of  civil  society  organisations  and 
academic and research institutions as projects’ coordinators and partners. Private sector 
actors contributed expertise in developing advanced technologies, particularly in projects 
focused on using AI and other digital solutions. These initiatives have strengthened the 
capacity of law enforcement authorities to conduct criminal investigations, process large 
volumes of data, and apply innovative methods such as facial recognition and encrypted 
communication analysis. 

As  highlighted  in  the  thematic  case  study  for  Union  Actions,  all  ISF-P  participating 
Member  States  (excepting  Luxembourg  and  Slovakia)  had  at  least  one  organisation 
coordinating  Union  Actions  projects  based  in  their  territory.  The  involvement  of 
coordinators from most Member States indicates that the objectives of the calls responded 
well to the needs of beneficiaries, and that organisations capable of initiating and managing 
Union Actions projects existed in every Member State. 

Union  Actions  played  an  important  and  indispensable  role  in  addressing  the  needs 
identified in the EU strategic documents and those of beneficiaries and proved instrumental 
in enhancing the EU’s internal security and responding to emerging changes. The funded 
projects strengthened the capabilities to respond adequately to internal security threats and 
fostered meaningful cooperation among national law enforcement authorities, relevant EU 
agencies and the private sector, enhancing the EU’s collective resilience.144 

Projects successfully delivered on the key needs in counterterrorism and organised crime. 
The nature of the challenges addressed by Union Actions often required a  transnational 
approach. The case study on Union Actions evidence that projects advanced the sharing of  
knowledge and skills; deploying innovative practices, technologies, and tools that aided 
stakeholders  (particularly  law  enforcement  authorities)  in  addressing  complex  internal 
security challenges; and benefitted multiple Member States and/or the Union as a whole.  

Despite these positive results, two issues were raised during the interim evaluation of the 
ISF-P: limitations in funding for certain policy fields (e.g. cybercrime) and a geographical 
imbalance, with some Member States less active in securing grants, potentially affecting 
the uniformity of the projects’ impact across the EU.  

Emergency Assistance 

Overall, EMAS-funded projects aligned well with the ISF-P objectives, enhancing internal 
security response capabilities and collective efforts against organised crime and terrorism, 
and  proved  essential  in  addressing  urgent  internal  security  needs  within  the  EU  and 
Member  States.  The  thematic  study  on  EMAS  evidence  that  rapid  financial  assistance 
allowed Member States to mobilise resources promptly, supporting their ability to protect 
public  spaces,  prevent  terrorist  attacks,  and  manage  critical  infrastructure  crises.  As 
highlighted  in  the  thematic  case  study  on  EMAS,  beneficiaries  confirmed  that  grants 
enabled them to meet urgent and specific needs efficiently. This finding was supported by 

143 Thematic case study on Union Actions. 
144 Thematic case study on Union Actions. 

65 

 
 
consulted  stakeholders  via  survey,  who  also  reported  positive  outcomes  from  EMAS-
funded projects.145  

Despite  the  overall  positive  results,  several  challenges  were  noted,  such  as  complex 
procurement procedures were perceived as an obstacle, which often delayed and hampered 
effective project implementation. Delays in the review and approval processes for EMAS 
funding were flagged as limitations to providing rapid emergency response. However, it 
should  be  noted  that  the  limited  timeframe  is  inherent  to  the  emergency  aspect  of  this 
funding component, which is not intended to support projects of a structural nature.  

As highlighted in the case study on EMAS, during the 2014-2020 programming period, a 
total of ten projects were funded under the EMAS component of the ISF-P amounting to 
EUR 12 026 708. Seven of these projects were implemented as action grants by Member 
States  and  three  by  Europol  and  Interpol.  The  international-level  projects  managed  by 
Europol and Interpol also expanded their focus to address counter-terrorism efforts.  

5. WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1. Conclusions  

5.1.1. Effectiveness 

The ISF-P proved effective in supporting Member States in progressing towards their 
objectives of preventing and combating cross-border, serious and organised crime, 
including  terrorism  and  to  enhance  their  capacity  to  effectively  manage  security-
related risks and crises.  

The ISF-P contributed to ‘Specific Objective – fight against crime’ by enhancing Member 
States’  capabilities  to  combat  cross-border,  serious  and  organised  crime,  including 
terrorism, through investments in modernising law enforcement tools, intelligence sharing, 
and  cross-border  operational  projects.  It  also  reinforced  cooperation  between  national 
authorities, Europol and international partners by supporting IT interoperability and data 
exchange.  

At  EU  level,  the  combined  indicator  target  values  for  most  ‘Specific  Objective  –  fight 
against crime’ indicators were achieved. At Member State level, the analysis shows that 
depending on the indicator, between 5 and 13 Member States did not meet their targets. 
There  were  at  times  discrepancies  between  target  and  achieved  values  and  inconsistent 
reporting of sub-indicators.  

Findings indicate positive levels of perceived overall effectiveness in furthering ‘Specific 
Objective – fight against crime’ across different security-related actions. The national ex-
post evaluation reports concluded that the funded actions have contributed to preventing 
cross-border, serious and organised crime, as well as reinforcing coordination among law 
enforcement authorities.  

The  ISF-P  contributed  to  ‘Specific  Objective  –  risk  management’  by  enhancing  the 
Member States’ capacity to manage security-related risks and crises through investments 

145 Survey question: Your country received EMAS under the ISF-P and/or ISF. To what extent do you believe 
it generated the intended results? 

66 

 
 
in  crisis  management  centres,  early  warning  systems,  and  protection  of  critical 
infrastructure, including advancements in cybersecurity and CBRN-E threat responses.  

At  EU  level,  the  combined  indicator  target  values  for  ‘Specific  Objective  –  risk 
management’ indicators were all overachieved. At Member State level, the analysis shows 
that depending on the indicator, between 5 and 7 Member States did not meet their targets. 
The most frequently reported reasons for the underachievement of some target values of 
indicators  were  the  restrictive  measures  imposed  in  many  areas  by  the  COVID-19 
pandemic (particularly in the case of face-to-face events).  

The findings all confirm that ISF-P actions were effective in furthering ‘Specific Objective 
–  risk  management’  and  highlight  the  significant  progress  across  Member  States  in 
enhancing  administrative  and  operational  capacities  for  crisis  management,  critical 
infrastructure protection, and risk assessment.  

The ISF-P faced recurring challenges –  procurement issues, COVID-19 pandemic and the 
Russian  war  of  aggression  against  Ukraine  –  which  at  times,  led  to  delays  in  project 
implementation  due  to  disrupting  project  timelines,  training  activities,  and  operational 
measures. Despite these challenges, evidence did not identify major  issues affecting the 
achievement of objectives, thus underscoring the robustness of ISF-P in addressing such 
obstacles.  

5.1.2. Efficiency and Simplification and reduction of administrative burden 

The  ISF-P  implementation  was  efficient,  with  projects  across  Member  States 
generally  meeting  their  objectives  within  reasonable  budgets.  Cost  savings  were 
achieved  through  digitalisation,  procurement,  and  efficient  allocation  of  financial  and 
human resources, particularly in areas such as training and IT system development. The 
use of public tendering processes ensured transparency and compliance with financial and 
operational standards, strengthening overall cost-effectiveness. 

While the Instrument achieved its intended objectives, the administrative burden varied 
across Member States, with some facing inefficiencies due to complex procedures and high 
personnel  costs,  and  stakeholders  highlighting  excessive  reporting  requirements  and 
bureaucratic hurdles.  

The  ISF-P  has  demonstrated  effective  management  and  control  mechanisms  that  were 
efficient  to  safeguard  the  EU’s  financial  interests.  Strong  collaboration  and  clear 
communication between Responsible Authorities and beneficiaries were identified as key 
means of timely and cost-effective project delivery. The measures in place to prevent fraud 
and  irregularities  and  cooperation  between  national  authorities  and  beneficiaries  have 
largely contributed to the efficient use of resources.  

The ISF-P and the Horizontal Regulations introduced several changes aimed at simplifying 
the  ISF-P  management  and  reducing  administrative  burden,  such  as  the  introduction  of 
multiannual  programming,  national  eligibility  rules  and  SCOs.  Overall,  Member  States 
perceived these changes as a positive development.  

5.1.3. Coherence and complementarity 

The national programmes and Annual Work Programmes are coherent with other national 
and EU funding instruments.  

67 

 
The  architecture  of  the  ISF-P  was  fit  for  purpose  as  it  enhances  internal  coherence  by 
fostering  complementarity  across  components.  The  combination  of  fund  components 
(national programmes, Union Actions and EMAS) and management modes (shared, direct 
and indirect) enables flexible fund management.  

Member States implemented several different coordination mechanisms at national level 
during the programming and implementation phases to ensure the coherence of activities 
with other programmes funded by EU Instruments with similar objectives to those of the 
ISF-P.  The  findings  show  that  the  key  coordination  mechanisms  in  ensuring  coherence 
between the ISF-P and other EU interventions is played by the Monitoring Committees, 
which  gathers  representatives  from  national  institutions  and  beneficiaries  with  the 
objective of fostering coherence and limiting overlaps between interventions.  

As  far  as  coherence  with  external  spending  programmes,  there  appears  to  be  limited 
complementarity  between  the  ISF-P  and  other  existing  EU  instruments  with  an  EU’s 
external  action  dimension,  as  only  few  Member  States  specifically  report  coordination 
between ISF-P-funded actions in or in relation to third countries, which are also supported 
by national foreign policy with a view to ensuring coherence and complementarity.  

5.1.4. EU added value 

The  ISF-P  has  generated  substantial  EU  added  value  at  EU  level,  primarily  through 
fostering  a  unified  framework  for  addressing  cross-border  internal  security  challenges, 
encouraging knowledge exchange, and the promotion of best practices.  

Findings suggest that the ISF-P achieves EU added value across Member States under three 
main  aspects:  in  a  higher  volume  of  services  offered  (volume  effect),  new  types  of 
intervention  tackled  (scope  effect)  and  increased  the  capacities  of  Member  States  and 
public authorities to manage the funding (role and process effect).  

The ISF-P achieves EU added value by enabling a higher volume of investment or funding, 
supporting projects with a larger scope and streamlining of internal and external processes, 
the  development  of  standards  supporting  cooperation,  information  sharing  and  the 
adoption of good practices.  

The consequence of the absence or interruption of ISF-P would affect Member States to 
varying degrees, ranging from an inability to meet regulatory requirements to the reduced 
efficiency  and  effectiveness  of  specific  individual  projects  due  to  changes  in  priorities. 
Whereas  a few larger member States consider that  some projects  could  still be funded, 
though  potentially  at  a  slower  pace  and  smaller  scale,  other  Member  States  report  that 
absent  ISF-P  support,  they  would  have  received  less  to  no  funding  due  to  national 
budgetary constraints. 

At EU level, benefits under national programmes primarily relate to information-sharing, 
data interoperability, cooperation and networking. Union Actions projects have created EU 
added value due to having a strong transnational component, supported the uninterrupted 
operation  of  transnational  law  enforcement  networks,  enhanced  cooperation  with  third 
countries  and  international  organisations,  promoted  innovation  and  transfer  of  best 
practices,  and  has  contributed  to  the  involvement  of  different  stakeholders.  EMAS  has 
strengthened  operational  cooperation  and  information  exchange  across  the  EU  through 
strengthened  protection  of  public  spaces,  enhanced  prevention  of  terrorist  attacks,  and 

68 

 
improved  crisis  management  in  response  to  terrorist  incidents  or  attacks  on  critical 
infrastructure. 

5.1.5. Sustainability 

The sustainability of ISF-P funded projects is underpinned by a multifaceted approach that 
integrates financial planning, operational continuity, personnel training, and international 
cooperation.  Overall,  stakeholders  have  reported  that  many  actions  and  positive  effects 
funded under ISF-P are likely to last. During the programming stage, there seems to be 
rather coherent approaches across Member States in ensuring that project proposals align 
with  national  and  EU  objectives  and  priorities.  This  contributes  to  the  sustainability  of 
selected projects, as they are relevant to the objectives and national priorities at national 
and EU-levels. During the implementation stage, the use of sustainability checks is more 
fragmented, ranging from strict requirements to informal check-ins and to no sustainability 
checks at all. Furthermore, some Member States demonstrate dependencies on EU funding 
and consider it the main option for the continuation of projects funded under ISF-P. 

In  general,  Member  States  have  prioritised  the  development  of  skills  and  expertise  to 
ensure  that  the  benefits  of  ISF-funded  projects  persist  over  time.  Training  programmes 
have  been  integral  in  ensuring  that  personnel  are  equipped  with  the  knowledge  and 
capabilities to effectively use and maintain new systems and technologies in the long run. 
Similarly, Union Actions projects that have demonstrated sustainability over time are often 
focused on networking and cross-border cooperation. These networks provide a platform 
for  the  sharing  of  best  practices,  knowledge,  and  resources,  further  embedding 
sustainability into the fabric of the project from the beginning.  Regarding EMAS, despite 
the short-term duration of these projects, the integration and further development of tools 
have  been  continued  after  the  projects  formally  ended.  Moreover,  the  continuance  of 
operations  and  experience  sharing  has  been  a  key  strategy  in  contributing  to  the 
sustainability of EMAS projects. 

5.1.6. Relevance 

The ISF-P has largely addressed the needs identified at the beginning of the programming 
period to achieve the overall objective of ensuring a high level of security in the Union 
through  the  fight  against  organised  crime  and  managing  risk  and  crises.  It  has  also 
demonstrated adaptability to evolving needs and challenges throughout the implementation 
period.  

At  EU  level,  the  consultation  process  consisted  of  a  policy  dialogue  between  Member 
States and the Commission to ensure alignment of the national mapping of needs/trends 
with the ISF-P’s objectives and with those identified at EU and national levels.  

At national  level,  the ISF-P supported Member  States in  implementing targeted actions 
under shared management,  as national  programmes were structured to  address  country-
specific  internal  security  needs  and  were  developed  through  needs  assessments  and 
stakeholder  consultations,  ensuring  alignment  with  both  EU-level  policy  priorities  and 
national security requirements.  

Union Actions played a crucial role by funding transnational projects producing outputs 
and results which bring high EU added value to multiple Member States and the EU as a 
whole which proved essential in strengthening cooperation between stakeholders, thereby 
enhancing the EU’s collective resilience to internal security threats.  Furthermore, it has 

69 

 
supported the uninterrupted operation of established and newly emerging transnational law 
enforcement networks which play a critical role in enhancing the cooperation in all policy 
fields,  it  is  the  primary  instrument  for  enhancing  cooperation  with  third  countries  and 
international  organisations,  promotes  innovation  and  transfer  of  best  practices,  and  has 
contributed to expanding the involvement of different stakeholders such as civil society 
and  the  private  sector.  EMAS-funded  projects  significantly  enhanced  internal  security 
response  capabilities,  enabling  Member  States  to  mobilise  resources  quickly  in  crisis 
situations.  

5.2. Lessons Learned 

Member States have a general dissatisfaction with the ISF-P indicator system as defining, 
applying and reporting on indicators has proven to be very challenging. In particular, the 
ISF-P indicators have been criticised for their poor and late definition and weak correlation 
with the intended objectives. Future instruments may benefit from improved monitoring 
and  performance  assessment  mechanisms  to  better  capture  and  monitor  the  progress 
towards the achievement of the established objectives.  

The  one-year  implementation  extension  to  all  Home  Affairs  Funds  for  the  2014-2020 
programming period contributed to achieving the two specific objectives of the ISF-P. This 
flexibility was praised for allowing the completion of projects and helping to overcome 
certain delays particularly caused by the COVID-19 pandemic. The positive impact of the 
one-year  extension  highlights  the  importance  of  adaptable  timelines  in  ensuring 
programme continuity and completion during crisis situations. Future instruments should 
retain  the  flexibility  to  respond  to  external  events  through  mechanisms  such  as  the 
extension of the implementation period.  

Overall,  Member  States  perceived  efforts  to  further  simplification  and  reduce 
administrative  burden  as  a  positive  development.  Nonetheless,  some  Member  States 
encountered  challenges  related 
to  burdensome  documentation  requirements  and 
difficulties in effectively implementing SCOs. Thus, despite some progress having been 
made, additional efforts are necessary to further simplification and reduce administrative 
burden. For instance, the use of SCOs could be further encouraged and promoted. 

While the architecture of the ISF-P was fit for purpose, there is room for strengthening the 
complementarity between Union Actions and national programmes to improve awareness 
and knowledge of the other’s respective projects.  

The  ISF-P  has  particularly  enabled  Member  States  with  limited  financial  resources  to 
implement  critical  internal  security  projects  in  line  with  EU  standards.  For  instance, 
projects  under  the  certain  national  programmes  support  Member  States  in  overcoming 
national budgetary limitations which posed significant challenges for enhancing internal 
security via needed long-term investments in IT infrastructure and crime prevention. The 
Instrument’s  ability  in  supporting  Member  States  underlines  its  importance  in  not  only 
generating several benefits at EU level beyond those Member States could achieve on their 
own but also in supporting Mmeber States in implementing the EU acquis which at time 
could not been implemented absent ISF-P funding.   

Union Actions have particularly contributed to creating benefits at EU level due to having 
a strong transnational component with projects producing outputs and results which bring 
high EU added value to multiple Member States and the EU as a whole. Furthermore, it 
has supported the uninterrupted operation of established and newly emerging transnational 

70 

 
law enforcement networks which play a critical role in enhancing the cooperation in all 
policy fields, it is the primary instrument for enhancing cooperation with third countries 
and international organisations, promotes innovation and transfer of best practices, and has 
contributed to expanding the involvement of different stakeholders such as civil society 
and the private sector. The ability of Union Actions to swiftly adapt to emerging internal 
security challenges further underlined their relevance within the ISF-P framework. 

71 

 
 
 
 
 
 
 
 
ANNEX I.  PROCEDURAL INFORMATION 

This evaluation has been carried out by DG HOME, as responsible for the implementation 
of the ISF-P in the Commission.  

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 (EU) 
2017/207.  In  this  regard,  the  five  standard  criteria  for  evaluation  defined  in  the  Better 
Regulation (Effectiveness, Efficiency, Relevance, Coherence and EU Added Value) were 
complemented  by  three  additional  ones:  simplification  and  reduction  of  administrative 
burden, complementarity and sustainability 

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, 
SJ, OLAF, DG BUDG, DG JUST, DG INTPA, DG REGIO, DG EMPL, DG MARE, DG 
RTD, DG DEFIS, JRC and DG ECHO. 

The  first  meeting  of  the  Interservice  Group  was  held  on  30  June  2023.  The  meeting 
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 29 February 2024, 26 April 2024, 22 July 2024, 
15 November 2024 and 8 April 2025. The draft version of this Staff Working Document 
was submitted to the Interservice Group in written consultation on 1 July 2025, and the 
final meeting with the Interservice Group was held on 15 July 2025. 

The  preparatory  study  was  confided  to  a  consortium  made  up  of  ECORYS,  Rand, 
Wavestone and the Centre for the Studies of Democracy 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 19 May 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.  

72 

 
 
 
 
 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

This  Annex  presents  the  methodology  employed  for  the  Evaluation  of  the  ISF-P  2014-
2020 and the limitations encountered. 

Methodology 

The  evaluation  was  supported  by  an  external  study  that  was  divided  into  four  phases: 
inception, data collection, analysis and finalisation.  

The inception phase was characterised by preparing the work to be done. This included 
preliminary desk research, a literature review, scoping interviews, stakeholder mapping, 
developing an intervention logic, and the refinement of the methodological approach to be 
used. The 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 data collection phase focused on gathering data by by synthesising and analysing the 
annual implementation reports and the final implementation reports, a review of the ex-
post  evaluations  of  the  national  programmes,  reviewing  a  sample  of  target  setting 
methodologies, mapping the allocations by type of intervention and target group, launching 
a targeted survey and public consultation, and conducting semi-structured interviews and 
focus groups.  

During the analysis phase, the focus was on collecting the remaining data necessary for the 
study as well as answering the evaluation questions. This included obtaining quantitative 
and qualitative data from SFC2021 and creating an overview of costs and benefits. The 
data was then triangulated to develop replies to each evaluation question.  

In  the  final  phase,  the  findings  were  synthesised,  a  synopsis  covering  the  consultation 
activities was drafted. Furthermore, the third EU level focus group was held to validate the 
evaluation findings and develop lessons learned.  

Furthermore, data on financial allocations, financial progress and implementation progress 
was  extracted  from  SFC2014.  The  data  was  reviewed  by  management  mode,  specific 
objective, Member State and field of intervention to develop the state of play.  

Regarding the consultation activities, EU level interviews were conducted with officials 
from  DG  HOME  units  D1,  D2,  E1,  E2,  E3  and  E4.  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 on the ISF-P were held during the study (first and third focus 
groups). 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,  for  a  total  of  50-60 
participants. After a plenary session the participants were divided into six break-out groups 
to facilitate more targeted discussions. The aim of the focus group was to collect views on 
whether and how well the ISF-P is addressing needs while also supporting activities that 
generate EU added value.  

The  third  focus  group  was  held  on  3  April  2025  and  aimed  to  collect  feedback  from 
relevant  stakeholders  (total  of  60  participants)  and  validate  the  findings  of  the  study, 
ensuring that the conclusions presented in the Draft Final Report for the ex-post evaluation 

73 

 
of  the  ISF-P  are  accurate  and  comprehensive  and  reflect  the  perspectives  of  all  key 
stakeholders.  

In  addition  to  the  focus  groups,  two  targeted  surveys  were  launched  to  target  various 
stakeholders  (one  for  Member  State  authorities  and  another  for  beneficiaries  of  Union 
Actions and the national programmes). The results of the survey fed into the main analysis.  

The study included five country case studies (Croatia, Germany, Latvia, the Netherlands 
and  Spain)  to  dive  deeper  into  the  implementation  of  the  ISF-P  to  identify  challenges 
encountered, specific processes, and best practices. The study also included two thematic 
case studies on Union Actions and EMAS. The thematic case studies allowed for deep-
dives  into  certain  aspects  of  the  instrument  and  specific  topics  by  reviewing  specific 
projects.  

Based on the described methodology, the final report for the ex-post evaluation was 
drafted. 

Limitations and mitigation measures 

The evaluation faced challenges related to data quality, availability, and consistency across 
Member States. Differences in the level of detail in the Annual Implementation Reports, 
Final  Implementation  Reports  and  national  ex-post  evaluations  made  cross-country 
comparisons  difficult.  Data  on  result  and  impact  indicators  transmitted  by  the  Member 
States  via  SFC2014  included  a  number  of  omissions,  clerical  errors,  and  revealed 
differences  in  how  Member  States  interpret,  measure  and  report  data.  Additionally, 
turnover  within  key  stakeholders  impacted  institutional  memory  and  the  continuity  of 
information.  To  address  these  challenges,  the  study  applied  triangulation  methods  and 
cross-referenced multiple sources. 

Indicators for the evaluation of the specific objectives of ISF-P Regulation146 

1. Indicators by specific objectives 

(c)  Crime  prevention,  combating  cross-border,  serious  and  organised  crime  including 
terrorism,  and  reinforcing  coordination  and  cooperation  between  law  enforcement 
authorities  and  other  national  authorities  of  Member  States,  including  with  Europol  or 
other  relevant  Union  bodies,  and  with  relevant  third  countries  and  international 
organisations:  

(i) results of actions supported by the Fund leading to the disruption of organised crime 
groups;  

(ii) number/value of frozen, seized and confiscated criminal assets as a result of actions 
within the scope of Regulation (EU) No 513/2014;  

(iii) number of police-recorded offences, suspects, prosecutions and convictions resulting 
from actions falling within the scope of Regulation (EU) No 513/2014;  

(iv) quantity of drugs seizure within the scope of the Fund on organised crime;  

(v) number of protected or assisted crime victims;  

146 Annex IV of Commission Delegated Regulation (EU) 2017/207. 

74 

 
 
(vi) volume of exchange of information in the Prüm framework (based on the measurement 
of total number of DNA matches per year; total number of fingerprint matches per year; 
total number of vehicle registration data matches per year);  

(vii)  volume  of  exchange  of  information  in  the  Secure  Information  Exchange  Network 
Application (SIENA) framework (based on the measurement of SIENA cases initiated per 
year by Member States, Europol and third parties; SIENA messages exchanged per year 
by Member States, Europol and third parties);  

(viii) volume of sharing of data via the Europol Information System (EIS) (based on the 
measurement of number of persons and objects inserted in the EIS by Member States per 
year;  number  of  person  and  objects  inserted  in  the  EIS  by  Member  States  per  year 
(suspects, convicts); number of EIS searches performed by Member States per year).  

(d)  Enhancing  the  capacity  of  Member  States  and  the  Union  for  managing  effectively 
security-related  risks  and  crises,  and  preparing  for  and  protecting  people  and  critical 
infrastructure against terrorist attacks and other security-related incidents:  

(i) volume of terrorist attacks (based on the measurement of failed, foiled and completed 
terrorist attacks; number of casualties resulting from terrorist attacks). 

75 

 
 
 
 
 
 
ANNEX III. EVALUATION MATRIX 

Effectiveness 

Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

1. How did the Fund 

1.1 What progress was 

1.1.1 Output indicators 

1.1.1 OI SO-fight against crime C3: Number of projects in the area of 

•  Mapping of allocations (Task 

contribute to the      

made towards the 

related to combatting cross-

crime prevention 

achievement of the 

achievement of the 

border, serious and 

(i) 

following specific 

expected results of 

organised crime, including 

1.1.1 OI: SO-fight against crime R1: Number of joint investigation 

objectives: 

strengthening Member 

terrorism, have achieved 

teams (JITs) and European Multidisciplinary Platform against Criminal 

Prevention of cross-

States' capacity to 

their targets, provided these 

Threats (EMPACT) operation projects supported by the Fund, 

border, serious and 

combat cross-border, 

were correctly defined and 

including the participating Member States and authorities 

1b) 

•  Review of methodology for 
target setting (Task 1c) 

• 

• 

Synthesis of implementation 

reports (Task 1d) 

Systematic review of MS 

organised crime, including 

serious and organised 

in line with evolving needs 

1.1.1 OI: Number of projects supported by the Fund, aiming to 

evaluations (Task 1e) 

terrorism?; 

crime, including  

1.1.2 Result indicators 

improve law enforcement and information exchange, which are related 

Reinforcement of the 

terrorism and to 

related to combatting cross-

to Europol data systems, repositories, or communication tools (SO-

coordination and 

reinforce their mutual 

border, serious and 

fight against crime C4) (i) 

cooperation between law 

cooperation in this field, 

organised crime, including 

1.1.1 OI: (SO-fight against crime  R2) Number of law enforcement 

•  Quantitative analysis (Task 1f) 
• 
Final project reporting (UAs 

and EMAS) (Task 1f) 

• 

Interviews/survey with MS 

enforcement authorities 

and how did the Fund 

terrorism, have achieved 

officials trained on cross-border related topics with the help of the 

authorities (RA, IB), 

and other national 

contribute to the 

their targets, provided these 

Fund, and the duration of their training (person days) (i) 

authorities of Member 

achievement of this 

were correctly defined and 

1.1.1 OI: Number of studies/platforms/guidance/risk and threat 

States, including with 

progress? 

in line with evolving needs 

assessments reports 

Europol or other relevant 

Union bodies, and with 

relevant third countries 

and  international 

organisations? 

1.1.3 Impact indicators 

1.1.1 OI: Number of expert meetings, workshops, seminars, 

related to combatting cross-

conferences, publications, websites and online consultations organised 

border, serious and 

with the help of the Instrument 

organised crime, including 

1.1.1 OI: Number of EU/national equipment and IT systems acquired 

terrorism, have achieved 

ex.: n. of laptops, software, apps, video surveillance 

their targets, provided these 

1.1.1 Output indicators for EMAS and Union actions (see revised ILs) 

beneficiaries, and participants 

•  Case studies (Task 4) 
• 
•  Desk research on indicators 

Public consultation (Task 2d) 

76 

 
 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

were correctly defined and 

1.1.2 RI: Number of protected or assisted crime victims (SO-fight 

in line with evolving needs 

against crime  I4) 

1.1.3 Stakeholder 

1.1.2 RI: Number of Member States and authorities participating in 

perception on Funds 

investigations teams and platform operation (JIT, EMPACT) (SO-fight 

contribution to achievement 

against crime R1) (i) 

of expected results  

1.1.2 RI: EU agencies involvement in the area of crime prevention, 

1.1.4 Contribution of Fund 

data systems or communication tools (EUROPOL, CEPOL, Frontex, 

measures to strengthening 

Eurojust) 

MS capacities to combat 

1.1.2 Result indicators for EMAS and Union actions (see revised ILs) 

cross-border serious and 

1.1.3 II: Improved coordination, cooperation and cross-border 

organised crime, including 

information exchange between MSs and EU agencies, institutions such 

terrorism, (positive 

as Europol (ex: PNR data exchange) (d) 

contribution of the Fund to 

1.1.3 II: More strategic and operational intelligence, strengthening 

the trend of any impact 

capabilities and investigation activities to prevent and fight crime, 

indicators) 

terrorism and support to victims of crime 

1.1.5 Identification of 

1.1.3 II: Increased awareness and responsiveness to challenges linked 

factors hampering the 

to radicalisation, or crime/cyber crime 

achievement of intended 

1.1.3 Impact indicators for EMAS and Union actions (see revised ILs) 

objectives 

1.1.4 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

1.1.4. Strength of linkages between output, results and impact 

indicators 

1.1.5. Challenges identified that affect implementation and the progress 

towards the objectives of the fund 

1.1.5 Identified delays in implementation of actions  

1.2 What progress was 

1.2.1 

Output indicators 

1.2.1 OI: Number of projects supported by the Fund, aiming to 

•  Mapping of allocations (Task 

made towards 

developing 

related to developing 

improve law enforcement and information exchange, which are related 

1b) 

administrative operational 

77 

 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

administrative and 

coordination and 

to Europol data systems, repositories, or communication tools (SO-

operational coordination 

operational cooperation 

fight against crime C4)  

and cooperation among 

have achieved their targets, 

1.2.1 (i) Output indicators for EMAS and Union actions (see revised 

Member States' public 

provided these were 

ILs) 

Data Source and analytical 
tool 

•  Review of methodology for 
target setting (Task 1c) 

• 

Synthesis of performance and 

implementation reports (Task 

authorities, Europol or 

correctly defined and in line 

1.2.2 RI: Number of joint investigation teams (JITs) and European 

1d) 

other relevant Union 

with evolving needs 

Multidisciplinary Platform against Criminal Threats (EMPACT) 

• 

Systematic review of MS 

bodies and, where 

1.2.2 

Result indicators 

operation projects supported by the Fund, including the participating 

evaluations (Task 1e) 

appropriate, with third 

related to developing 

Member States and authorities (SO-fight against crime R1) (i) 

countries and 

international 

administrative operational 

1.2.2 RI: Growing number of stakeholders involved in the sharing of 

coordination and 

information, study and data collection 

•  Quantitative analysis (Task 1f) 
• 
Final project reporting (UAs 

and EMAS) (Task 1f) 

organisations, and how 

cooperation have achieved 

1.2.2 RI: Harmonised practices and validation protocols (e.g. under 

• 

Interviews/survey with MS 

did the Fund contribute 

their targets, provided these 

Prüm, SIENA, EIS) (d) 

authorities (RA/MA, DA/IB), 

to the achievement of 

were correctly defined and 

1.2.2 Result indicators for EMAS and Union actions (see revised ILs) 

beneficiaries, and participants 

this progress? 

in line with evolving needs 

1.2.3 II: Improved coordination, cooperation and cross-border 

1.2.3 

Impact indicators 

information exchange between MSs and EU agencies, institutions such 

related to developing 

as Europol (ex: PNR data exchange) (d) 

administrative and 

1.2.3 Impact indicators for EMAS and Union actions (see revised ILs) 

operational coordination 

1.2.4 Degree of supporting evidence from consultations (opinion of 

and cooperation among MS 

stakeholders) 

1.2.4 

Stakeholder 

1.2.5 Challenges identified that affect implementation and the progress 

perception on Funds 

towards the objectives of the fund 

contribution to achievement 

1.2.5 Identified delays in implementation of actions 

•  Case studies (Task 4) 
• 
•  Desk research on indicators 

Public consultation (Task 2d) 

of expected results  

1.2.5 

Identification of 

factors hampering the 

achievement of intended 

objectives 

78 

 
 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

1.3 What progress was 

1.3.1 

Output indicators 

1.3.1 OI: Number of law enforcement officials trained on cross-border-

•  Mapping of allocations (Task 

made towards 

related to developing 

related topics with the help of the Instrument, and the duration of their 

1b) 

developing training 

training schemes have 

training (person days) (SO-fight against crime R2) (i) 

schemes, such as those 

achieved their targets, 

1.3.1 OI, UA: Number of technical visits and thematic workshop with 

regarding technical and 

provided these were 

involvement of key-stakeholders 

•  Review of methodology for 
target setting (Task 1c) 

• 

Synthesis of performance and 

professional skills and 

correctly defined and in line 

1.3.1 OI, UA: Number of training material, guidance addressing 

implementation reports (Task 

knowledge of 

with evolving needs 

different law enforcement authorities needs (ECTEG) (i) 

1d) 

obligations on human 

1.3.2 

Result indicators 

1.3.1 OI, UA and EMAS: Number of trainings/trained staff (i) 

• 

Systematic review of MS 

rights and fundamental 

related to developing 

1.3.1 OI, EMAS: Number of guidance produced at the end of 

evaluations (Task 1e) 

freedoms, in 

training schemes have 

workshops, seminars, missions, meetings, conferences etc. 

implementation of EU 

achieved their targets, 

1.3.1 OI, EMAS: Number of technical guidance, studies, manuals 

training policies, 

provided these were 

methodologies best practices developed 

•  Quantitative analysis (Task 1f) 
• 
Final project reporting (UAs 

and EMAS) (Task 1f) 

including through 

correctly defined and in line 

1.3.2 RI: Increased knowledge and skills of training participants in the 

• 

Interviews/survey with MS 

specific Union law 

with evolving needs 

area of crime prevention/forensic field (e.g. use of systems of data 

authorities (RA/MA, DA/IB), 

enforcement exchange 

1.3.3 

Impact indicators 

extraction) (d) 

programmes, and how 

related to developing 

1.3.2 RI, UA: Increased exchange of best practices or qualitative 

did the Fund contribute 

training schemes 

knowledge for preventing crime, terrorism and radicalisation (ex.: 

to the achievement of 

1.3.4 

Stakeholder 

ESCN) (d) 

beneficiaries, and participants 

•  Case studies (Task 4) 
• 
•  Desk research on indicators 

Public consultation (Task 2d) 

this progress? 

perception on Fund’s 

1.3.2 RI, UA: Increased awareness and civic engagement on the issues 

contribution to achievement 

surrounding radicalisation and violent extremism 

of expected results 

1.3.2 RI, EMAS: Improved knowledge about the methods and means 

1.3.5 

Identification of 

used by terrorists due to information dissemination 

factors hampering the 

1.3.2 RI, EMAS: Improvement of capabilities for the exchange of 

achievement of intended 

information and coordination 

objectives 

1.3.3 II: More strategic and operational intelligence, strengthening 

capabilities and investigation activities to prevent and fight crime, 

terrorism and support to victims of crime (d) 

79 

 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

1.3.3 II, UA: Increased awareness, cooperation and referral amongst 

frontline professionals to quickly identify criminal activities (d) 

1.3.4 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

1.3.5 Challenges identified that affect implementation and the progress 

towards the objectives of the fund 

1.3.5 Identified delays in implementation of actions 

1.4 What progress was 

1.4.1 

Output indicators 

1.4.1 OI: Number of introduced programmes or infrastructure for 

•  Mapping of allocations (Task 

made towards putting in 

related to putting in place 

victim support (e.g. psychological assistance, modernisation of control 

1b) 

place measures, 

measures, safeguard 

system of centres of witnesses and victims) (i) 

safeguard mechanisms 

mechanisms achieved their 

1.4.1 OI, UA: Number of specialised support services for victims of 

and best practices for 

targets, provided these were 

crime (i) 

•  Review of methodology for 
target setting (Task 1c) 

• 

Synthesis of performance and 

the identification and 

correctly defined and in line 

1.4.2 RI: Number of protected or assisted crime victims (SO-fight 

implementation reports (Task 

support of witnesses and 

with evolving needs 

against crime I4) (i) 

1d) 

victims of crime, 

1.4.2 

Result indicators 

1.4.2 RI: Improved preparedness and conditions that allow effective 

• 

Systematic review of MS 

including victims of 

related to putting in place 

monitoring of witnesses and victims of crimes, aiming to increase their 

evaluations (Task 1e) 

terrorism, and how did 

measures, safeguard 

safety, protection and support (d) 

the Fund contribute to 

mechanisms achieved their 

1.4.3 II: More strategic and operational intelligence, strengthening 

•  Quantitative analysis (Task 1f) 
• 
Final project reporting (UAs 

the achievement of this 

targets, provided these were 

capabilities and investigation activities to prevent and fight crime, 

and EMAS) (Task 1f) (where 

progress? 

correctly defined and in line 

terrorism and support to victims of crime (d) 

relevant) 

with evolving needs 

1.4.4 Degree of supporting evidence from consultations 

1.4.3 

Impact indicators 

(opinion of stakeholders) 

• 

Interviews/survey with MS 

authorities (RA/MA, DA/IB), 

related to putting in place 

1.4.5 Challenges identified that affect implementation and the progress 

beneficiaries, and participants 

measures,  safeguard 

towards the objectives of the fund  

mechanisms and best 

1.4.5 Identified delays in implementation of actions 

practices for the 

identification and support of 

•  Case studies (Task 4) 
• 
•  Desk research on indicators 

Public consultation (Task 2d) 

80 

 
 
 
Indicator 

Data Source and analytical 
tool 

Question 

Sub-question 

Indicative judgement 
Criteria 

witnesses and victims of 

crime 

1.4.4 

Stakeholder 

perception on Funds 

contribution to achievement 

of expected results 

1.4.5 

Identification of 

factors hampering the 

achievement of intended 

objectives 

2. How did the Fund 

2.1 What progress was 

2.1.1 Output indicators 

2.1.1 OI: Number and tools put in place and/or further upgraded with 

•  Mapping of allocations (Task 

contribute to improve the 

made towards 

related to reinforcing 

the help of the Instrument to facilitate the protection of critical 

1b) 

capacity of Member States 

reinforcing Member 

Member States' 

infrastructure by Member States in all sectors of the economy (SO-risk 

to manage effectively 

States' administrative 

administrative and 

management R1) (i) 

security-related risks and 

and operational 

operational capability to 

2.1.1 OI: Number of trained staff (i) 

•  Review of methodology for 
target setting (Task 1c) 

• 

Synthesis of performance and 

crises, and protecting 

capability to protect 

protect critical 

2.1.1 OI, UA: Number of transnational/cross border collaborations or 

implementation reports (Task 

people and critical 

critical infrastructure in 

infrastructure in all sectors 

platforms established (i) 

1d) 

infrastructure against 

all sectors of economic 

of economic activity 

2.1.1 OI, UA: Number and type of partners and beneficiaries reached 

• 

Systematic review of MS 

terrorist attacks and other 

activity, including 

2.1.2 Result indicators 

(i) 

security-related 

through public-private 

related to reinforcing 

2.1.1 OI, UA: Number of technical equipment, infrastructure, ICT 

incidents? 

partnerships and 

Member States' 

systems acquired, provided or upgraded (i) 

improved coordination, 

administrative and 

2.1.1 OI, EMAS: Number of hotspot manned (i) 

cooperation, exchange 

operational capability to 

2.1.1 OI, EMAS: Number of referrals/security checks (i) 

and dissemination of 

protect critical 

2.1.1 OI, EMAS: Number of investigations supported (i) 

know-how and 

infrastructure in all sectors 

2.1.1 OI, EMAS: Number of staff deployed (i) 

experience within the 

of economic activity 

2.1.2 RI: Upgraded systems and tools increased and facilitated early 

Union and with relevant 

2.1.3 Impact indicators 

warning analysis and risk management capacity of critical 

third Countries, and how 

related to reinforcing 

infrastructure and public spaces (d) 

evaluations (Task 1e) 

•  Quantitative analysis (Task 1f) 
• 
Final project reporting (UAs 

and EMAS) (Task 1f) 

• 

Interviews/survey with MS 

authorities (RA/MA, DA/IB), 

beneficiaries, and participants 

•  Case studies (Task 4) 
• 
•  Desk research on indicators 

Public consultation (Task 2d) 

81 

 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

did the Fund contribute 

Member States' 

2.1.2 RI, UA: Increased effectiveness and efficiency of infrastructure 

to the achievement of 

administrative and 

(e.g. airports, rails) controls (d) 

this progress? 

operational capability to 

2.1.2 RI, UA: Number of ICT systems made interoperable within and 

protect critical 

beyond the MS (d) 

infrastructure in all sectors 

2.1.3 RI, EMAS: Improved secondary security checks in hotspots (d) 

of economic activity 

2.1.3 II: Enhanced administrative and operational capacity to protect 

2.1.4 Stakeholder 

critical infrastructure and related facilities (d) 

perception on Funds 

2.1.3 II, UA: Improved protection of public spaces and critical 

contribution to achievement 

infrastructures (d) 

of expected results 

2.1.3 II, UA: Fostered cooperation between private entities and law 

2.1.5 Identification of 

enforcement authorities 

factors hampering the 

2.1.3 II, EMAS: Addressed emergency issues through enhanced 

achievement of intended 

international cooperation and between bodies/authorities (e.g. Europol, 

objectives 

Frontex etc.)  (d) 

2.1.4 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

2.1.5 Challenges identified that affect implementation and the progress 

towards the objectives of the fund 

2.1.5 Identified delays in implementation of actions 

2.2. What progress was 

2.2.1 Output indicators 

2.2.1 OI: Number of projects relating to the assessment and 

•  Mapping of allocations (Task 

made towards 

related to establishing 

management of risks in the field of internal security supported by the 

1b) 

establishing secure links  

secure links and effective 

Instrument (SO- risk management C2) (i) 

and effective 

coordination between early 

2.2.1 OI: N. of studies/platforms/risk assessment produced (i) 

coordination between 

warning and crisis 

2.2.1 OI: Number of trained staff (i) 

•  Review of methodology for 
target setting (Task 1c) 

• 

Synthesis of performance and 

existing sector-specific 

cooperations actors 

2.2.1 OI, UA: Number of transnational/cross border collaborations or 

implementation reports (Task 

early warning and crisis 

platforms established (i) 

1d) 

82 

 
 
 
 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

cooperation actors at 

2.2.2 Result indicators 

2.2.1 OI, UA: Number of events, conferences organised, and public-

• 

Systematic review of MS 

Union and national 

related to establishing 

private partnership established (i) 

level, and how did the 

secure links and effective 

2.2.1 OI, EMAS: Number of developed and acquired tools (i) 

Fund contribute to the 

coordination between early 

2.2.2 RI: Improved preparedness for future threats by developing 

evaluations (Task 1e) 

•  Quantitative analysis (Task 1f) 
• 
Final project reporting (UAs 

achievement of this 

warning and crisis 

know-how e.g. in the sphere of chemical, nuclear materials and 

and EMAS) (Task 1f) 

progress? 

cooperations actors 

explosives (d) 

• 

Interviews/survey with MS 

2.2.3 Impact indicators 

2.2.2 RI: Increased participation of different organisations and 

authorities (RA/MA, DA/IB), 

related to establishing 

associations in risk management operations (e.g. CBRN operations) (d) 

beneficiaries, and participants 

secure links and effective 

2.2.2 RI: Increased operative readiness of response and capability to 

coordination between early 

analyse and investigate hazardous cases (d) 

warning and crisis 

2.2.2 RI: Increased communication between external information 

cooperations actors 

systems and coordination between authorities (d) 

Public consultation (Task 2d) 

•  Case studies (Task 4) 
• 
•  Desk research on indicators 
•  Database review (Task 1d 

2.2.4 Stakeholder 

2.2.2 RI, UA: Increased cross-border investigations and wider EU 

Synthesis of evaluation reports) 

perception on Funds 

variety law enforcement cooperation (d) 

contribution to achievement 

2.2.2 RI, UA: Growing amount of networks interest and members, 

of expected results 

fostered cooperation (including PPPs) (d) 

• 

• 

Portfolio analysis (annual 

implementation reports) 

Interviews/survey with MS 

2.2.5 Identification of 

2.2.2 RI, EMAS: Increased information exchange among Special 

authorities (RA/MA, DA/IB), 

factors hampering the 

Intervention Units across Europe and facilitated direct access to data 

achievement of intended 

(d) 

beneficiaries, and participants 
•  Case studies (geographical and 

objectives 

2.2.3 II: Improved information sharing mechanism between Member 

thematic) 

States (d) 

2.2.3 II, UA: Fostered innovative approaches (incl. ICT/AI) to tackle 

security threats (d) 

2.2.3 II, UA: Increased awareness, cooperation and referral amongst 

frontline professionals to quickly identify criminal activities 

2.2.3 II, UA: Increased international operational cooperation between 

networks of national law enforcement authorities (ATLAS, AIRPOL) 

83 

 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

2.2.3 II, EMAS: Addressed immediate needs for improved information 

exchange for threats or crisis situations on issues such as terrorist 

attack prevention 

(d) 

2.2.4 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

2.2.5 Challenges identified that affect implementation and the progress 

towards the objectives of the fund 

2.2.5 Identified delays in implementation of actions 

2.3 What progress was 

2.3.1 

Output indicators 

2.3.1 OI: Number of trained staff (i) 

made towards 

improving the 

related to improving 

2.3.1 OI: Number of expert meetings, workshops, seminars, 

administrative and 

conferences, publications, websites and online consultations organised 

administrative and 

operational capacity of the 

with the help of the Instrument (SO-risk management R2) (i) 

operational capacity of 

Member States 

2.3.1 OI, UA: Number of new or tested developed detection and 

the Member States and 

2.3.2 

Result indicators 

investigation methodologies (i) 

the Union to develop 

related to establishing 

2.3.1 OI, UA: Number of expertise, information sharing, cooperation 

comprehensive threat 

secure links and effective 

and coordination activities (i) 

and risk assessments, 

coordination between early 

2.3.1 OI, UA: Number of communication campaigns launched (i) 

and how did the Fund 

warning and crisis 

2.3.1 OI, UA: Number of studies and pilot projects conducted (ex.: 

contribute to the 

cooperations actors 

EPRIS) (i) 

achievement of this 

2.3.3 

Impact indicators 

2.3.1 OI, UA: Number of technical visits and thematic workshops with 

progress? 

related to establishing 

involvement of key stakeholders (i) 

secure links and effective 

2.3.1 OI, UA: Number of specialised support services for victims of 

coordination between early 

crime (i) 

warning and crisis 

2.3.1 OI, UA: Number of training material, guidance addressing 

cooperations actors 

different law enforcement authority’s needs (ECTEG) (i) 

2.3.4 

Stakeholder 

2.3.1 OI, EMAS: Number of staff trained (i) 

perception on Fund’s 

84 

 
 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

contribution to achievement 

2.3.1 OI, EMAS: Number of guidance produced at the end of 

of expected results 

workshops, seminars, missions, meetings, conferences etc. (i) 

2.3.5 

Identification of 

2.3.1 OI, EMAS: Number of technical guidance, studies, manuals 

factors hampering the 

methodologies best practices developed (i) 

achievement of intended 

2.3.1 OI, EMAS: Number of participants in workshops, seminars, 

objectives 

events etc. (i) 

2.3.2 RI: Increased capacity and skills of competent authorities for 

responding to accidents and incidents (d) 

2.3.2 RI: Increased awareness among stakeholders regarding best 

practices and threats (e.g. radicalisation) (d) 

2.3.2 RI, UA: Increased exchange of best practices or qualitative 

knowledge for preventing crime, terrorism and radicalisation (ex.: 

ESCN) (d) 

2.3.2 RI, UA: Increased awareness and civic engagement on the issues 

surrounding radicalisation and violent extremism (d) 

2.3.2 RI, UA: Improved preparedness and skills of law enforcement 

authorities to investigate crime threats or launch joint operations in EU 

(d) 

2.3.2 RI, UA: Increased capacity of personnel, including for 

information and data exchange (e.g., PIU interconnectivity of PNR 

data) 

2.3.2 RI, EMAS: Improved knowledge about the methods and means 

used by terrorists due to information dissemination (d) 

2.3.2 RI, EMAS: Improvement of capabilities for the exchange of 

information and coordination (d) 

2.3.2 RI, EMAS: Improved trust between law enforcement officers and 

increased awareness (d) 

85 

 
Question 

Sub-question 

Indicative judgement 
Criteria 

Indicator 

Data Source and analytical 
tool 

2.3.3 II: Increased capabilities of police services to intervene in crisis 

and catastrophe situations caused by terrorist attacks (d) 

2.3.3 II, UA: Fostered innovative approaches (incl. ICT/AI) to tackle 

security threats (d) 

2.3.3 II, UA: New investigations and administrative responses to 

crime-related irregularities (d) 

2.3.3 II, EMAS: Improved crisis management response to terrorist 

attacks and protection of critical infrastructure, particularly from 

attacks from foreign terrorist fighters (d) 

2.3.4 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

2.3.5 Challenges identified that affect implementation and the progress 

towards the objectives of the fund 

2.3.5 Identified delays in implementation of actions 

Efficiency 

Question 

Sub-

Indicative judgement Criteria 

Indicator 

Data Source and analytical tool 

question 

3. Were 

3.1 To what 

3.1.1 The fund supported types of interventions that are known 

3.1.1 Application of cost-effectiveness analysis 

the 

extent were 

to  be cost-effective, based on available evidence 

in designing measures under the ISF-P 

general 

the expected 

3.1.2 Appropriate arrangements were used to select cost-

3.1.1 MS authorities / Beneficiaries / end 

objectives 

results of the 

effective operations 

beneficiaries’ opinion on cost-effectiveness 

Systematic review of MS evaluations (Task 1e) 

Synthesis of implementation reports (Task 1d) 

• 
• 
•  Quantitative analysis (Task 1f) 
•  Calls for proposals documents / ISF-P 

of the 

Fund 

Fund 

3.1.3 The evidence coming from the operations indicates that 

3.1.2 Evidence of cost-effectiveness 

Guidance documents at EU/national level 

achieved at 

the     cost per unit is in line or below existing benchmarks and 

arrangements in the ISF-P Guidance documents 

• 

Interviews/survey with MS authorities 

achieved 

reasonable 

estimates 

at 

cost in terms 

/ Calls for proposals 

(RA/MA, DA/IB), beneficiaries, and target 

population  

86 

 
 
Question 

Sub-

Indicative judgement Criteria 

Indicator 

Data Source and analytical tool 

question 

reasonable 

of deployed 

3.1.4 The differences in the cost per unit among similar 

3.1.3-3.1.4 Unit costs – e.g. costs per person 

•  Operations budgets (portfolio analysis of 

cost? 

financial and 

operations within the fund can be explained and justified (e.g. 

trained, cost per event / overall absorption rate 

human 

by differences in the intensity or quality of the support offered, 

3.1.5 Costs for Responsible Authorities and 

resources? 

innovativeness, purchase power, emergency context etc.) 

other delegated authorities 

operations and to be extracted in case studies) 
•  Data sheet on costs Responsible Authorities / 
Managing Authorities, Delegated Authorities / 

3.1.5 The administrative burden is proportionate for all 

3.1.5 Costs for the EC (for direct and indirect 

Intermediate bodies, COM (to be considered) 

implementing actors (Responsible Authorities and other 

management) 

delegated authorities), compared to the previous programming 

3.1.6 Costs for beneficiaries 

period similar services offered to comparable target groups 

3.1.7 Costs for end users (if any) 

•  Evaluations / budgetary information for 
previous programming period / services 

•  Case studies data on timelines and the 

without the support of the Fund  

3.1.5-3.1.7 Benchmarking with previous 

application of the ISF-P procedures (Task 4) 

3.1.6 The administrative burden is proportionate for all 

programming period / services 

beneficiaries, compared to the previous programming period/ 

3.1.8-3.1.9 Stakeholders’ interpretation (at 

similar services offered to comparable target groups without 

national and EU level) of the ISF-P 

the support of the Fund  

requirements and experience in applying them 

3.1.7 The administrative burden is proportionate for all end-

3.1.8-3.1.9 Timelines and requirements of the 

users, e.g. compared to the previous programming period/ 

ISF procedures 

similar services offered to comparable target groups without 

3.1.10 (i) Number of Full Time Equivalent in 

the support of the Fund  

the Responsible Authority, the Delegated 

3.1.8 Absence of ‘gold-plating’ at the national level (e.g. from 

Authority and the Audit Authority working on 

Responsible Authorities, Intermediate Bodies, national Audit 

the implementation of the Fund and paid by the 

Authorities), i.e. requirements are not interpreted more 

technical assistance or national budgets as 

restrictively than the legal basis or relevant documents 

compared to the number of projects 

providing methodological advice to the MS and unless a 

implemented and to the amount of the Funds 

justified reason exists  

claimed for the financial year;  

3.1.9 Absence of ‘gold-plating’ at the EU level, i.e. 

(ii)  technical assistance plus the administrative 

requirements are not interpreted more restrictively then in the 

(indirect) cost of projects as compared to the 

legal basis and unless a justified reason exists  

amount of funds claimed for the financial year; 

87 

 
 
 
Question 

Sub-

Indicative judgement Criteria 

Indicator 

Data Source and analytical tool 

question 

3.2 What 

measures 

3.2.1 The management and control system of the MS, 

3.2.1 MS authorities / Beneficiaries / 

•  Documents describing the management and 

described as per the legal basis, ensures quality of the of the 

participants’ opinion on the quality of the 

control system of the MSs 

were put in 

implementation of national programmes and the prevention, 

management and control system 

place to 

prevent, 

detection and correction of irregularities, including fraud, and 

3.2.1 Audit authorities and EU institutions’ 

the recovery of amounts unduly paid, together with any 

opinion on the quality of the management and 

•  Audit reports 
• 
• 

Systematic review of MS evaluations (Task 1e) 

Interviews/survey with MS authorities 

detect, report 

interest on late payments 

control system 

(RA/MA, DA/IB), beneficiaries, and 

and follow 

3.2.2 The management and control systems do not inflict 

3.2.2 MS authorities / Beneficiaries / 

participants 

up on cases 

unnecessary administrative burden 

of fraud and 

other 

irregularities, 

and how did 

they 

perform? 

Relevance 

participants’ opinion on the administrative 

burden related to the management and control 

system 

Question 

Sub-

Indicative judgement Criteria 

Indicator 

question 

4. Did the 

4.1 Did the 

4.1.1 A needs assessment is performed and updated on a 

4.1.1 Evidence on current and emerging threats not covered 

objectives of 

objectives set 

regular basis or whenever there are relevant contextual 

by the Regulation  

the 

by the 

changes 

interventions 

Member 

4.1.2 The partnership / monitoring committee is able to 

4.1.2 Extent to which needs and objectives are set in National 

funded by the 

State in the 

provide timely input on evolving needs and relevant 

Programmes  

Fund 

National 

developments on the ground 

correspond to 

Programme 

4.1.3 There is an adequate degree of flexibility in the design 

4.1.3 Extent to which the identified needs and projects are 

the actual 

respond to 

of the    projects, call for proposals, procurement 

implemented in MSs 

Data Source and analytical 

tool 

•  Needs assessment (Task 1a) 
•  Mapping of allocations (Task 

1b) 
•  Calls for 

proposals/procurement/awards 

documents 

• 

Systematic review of MS 

evaluations (Task 1e) 

needs? 

88 

 
 
 
 
 
Question 

Sub-

Indicative judgement Criteria 

Indicator 

question 

the identified 

4.1.4  Where necessary, non-substantial changes to the 

4.1.4 Degree of supporting evidence from consultations 

needs? 

programme strategy and work programmes can be applied 

swiftly 

4.1.5 Trends of criminality rate/organised crime/terrorist 

4.1.5 There are rules and procedures in place that ensure that 

attack at EU and national level yearly 

the substantial adjustments of the programme can be 

Data Source and analytical 

tool 

• 

• 
• 

Project reporting (UAs and 

EMAS) (Task 1f) 

Public consultation (Task 2d) 

Surveys/thematic interviews 

with Responsible authorities / 

implemented in due time if new needs arise 

4.1.6 Degree of flexibility for the design or revisitations of 

Managing and relevant 

4.1.6 If there have been changes in the needs after the 

the programmes 

programme adoption, the programme strategy or operations 

Delegated Authorities / 

Intermediate Bodies in the 

have been adapted in due time  

4.1.7 Degree of supporting evidence from consultations 

Member States 

4.1.7 The National programmes funded by the initiative 

adequately cover the specific objectives of the fund 

4.2 Did the 

4.2.1 A needs assessment is performed and updated on a 

4.2.1 Evidence on current and emerging threats not covered 

objectives set 

regular basis or whenever there are relevant contextual 

by the Regulation 

in the 

Annual 

Work 

changes 

4.2.2 The partnership / monitoring committee is able to 

Annual Work Programme for Union Actions 

4.2.2 Extent to which needs and objectives are set in the 

Programme 

provide timely input on evolving needs and relevant 

(Union 

Actions) 

developments on the ground 

4.2.3 Extent to which needs and projects actually are 

implemented 

address the 

4.2.3 There is an adequate degree of flexibility in the design 

actual needs? 

of the    projects, call for proposals, procurement 

4.2.4 Degree of supporting evidence from consultations 

(opinion from stakeholders) 

4.2.4  Where necessary, non-substantial changes to the 

programme strategy and work programmes can be applied 

swiftly 

• 

Surveys/thematic Interviews 

with Beneficiaries of the 

National programmes 
•  EUROPOL SOCTA 
•  Desk research 
•  Case studies (Task 4) 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Question 

Sub-

Indicative judgement Criteria 

Indicator 

question 

Data Source and analytical 

tool 

4.2.5 There are rules and procedures in place that ensure that 

the substantial adjustments of the programme can be 

implemented in due time if new needs arise 

If there have been changes in the needs after the programme 

adoption, the programme strategy or operations have been 

adapted in due time or, alternatively, the new needs have 

been duly addressed via the thematic facility  

The UA Work programmes adequately cover the specific 

objectives of the fund 

4.3 Did the 

4.3.1 A needs assessment is performed and updated on a 

4.3.1 Evidence on current and emerging threats not covered 

objectives set 

regular basis or whenever there are relevant contextual 

by the Regulation 

in the 

Annual 

Work 

changes 

4.3.2. Extent to which identified needs and objectives are set 

in the Annual Work Programme for emergency 

4.3.2 The partnership / monitoring committee is able to 

assistance 

Programmes  

provide timely input on evolving needs and relevant 

(EMAS) 

developments on the ground 

4.3.3 Degree of alignment between identified needs and 

address the 

projects actually implemented in Member States 

actual needs? 

4.3.3 There is an adequate degree of flexibility in the design 

of the  projects, call for proposals, procurement 

4.3.4 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

4.3.4  Where necessary, non-substantial changes to the 

programme strategy and work programmes can be applied 

swiftly 

4.3.5 There are rules and procedures in place that ensure that 

the substantial adjustments of the programme can be 

implemented in due time if new needs arise 

90 

 
 
 
 
 
 
 
 
 
Question 

Sub-

Indicative judgement Criteria 

Indicator 

question 

Data Source and analytical 

tool 

4.3.6 If there have been changes in the needs after the 

programme adoption, the programme strategy or operations 

have been adapted in due time  

4.3.7 The EMAS Work programmes adequately cover the 

specific objectives of the fund 

4.4 Which 

4.4.1  A needs assessment is performed and updated on a 

4.4.1 Frequency of needs assessment  

measures did 

regular basis or whenever there are relevant contextual 

the Member 

changes 

4.4.2 Type of measures put in place to address changing 

State put in 

place to 

address 

4.4.2 The partnership / monitoring committee is able to 

needs 

provide timely input on evolving needs and relevant 

4.4.3 Degree of supporting evidence from consultations 

changing 

developments on the ground 

(opinion of stakeholders) 

needs? 

4.4.3 There are rules and procedures in place that ensure that 

the substantial adjustments of the programme can be 

implemented in due time if new needs arise 

Coherence 

Question 

Sub-question 

Indicative judgement 

Indicator 

Criteria 

5. Were the 

 Was an assessment 

5.1.1 Adequate degree of 

5.1.1 Number and type of other EU interventions covered in 

objectives set in 

of other 

assessment of other 

the assessments 

the national 

interventions (e.g. 

interventions carried out 

Data Source and analytical 

tool 

• 

Synthesis of implementation 

reports (Task 1d) 

91 

 
 
 
 
 
 
 
 
 
 
Question 

Sub-question 

Indicative judgement 

Indicator 

Criteria 

programme 

AMIF, ISF-BV, 

during the programming 

5.1.1 Extent to which the assessment affected the design of the national 

Fund coherent 

Fiscalis 2020, 

phase. 

programme 

with the ones set 

Horizon 2020, 

in other 

Hercule, ESF, 

programmes 

ERDF, etc) with 

funded by EU 

similar objectives 

resources and 

carried out and 

applying to 

taken into account 

similar areas of 

during the 

5.1.1 Degree of supporting evidence from consultations (opinion of stakeholders) 

work? 

6. Was the 

coherence 

programming stage? 

Were coordination 

6.1.1 Structures, 

6.1.1 Number of MS with coordination mechanisms 

mechanisms 

organisational arrangements 

Established 

ensured also 

between the Fund 

or coordination mechanisms 

during the 

and other 

were used to ensure 

6.1.2 Frequency of coordination 

implementation 

interventions (e.g. 

coordination, 

of the Fund? 

AMIF, ISF-BV, 

complementarities and, 

6.1.2 Assessment of different instruments/Funds’ synergies 

Fiscalis 2020, 

Horizon 2020, 

Hercule, ESF, 

where relevant, synergies 

across the different 

6.1.3 Mechanisms ensure there are no/few overlaps or 

management modes of the 

Duplications 

ERDF, etc.) with 

same Fund 

similar objectives 

6.1.1-6.1.3 Degree of supporting evidence from consultations 

established for the 

6.1.2 Coordination 

(opinion of stakeholders) 

implementing 

mechanisms and 

period? 

arrangements were used 

regularly and to good effect 

6.1.3 Alleged overlaps were 

in fact justified on objective 

92 

• 

• 

• 

Data Source and analytical 

tool 

Systematic review of MS 

evaluations (Task 1e) 

Final project reporting (UAs 

and EMAS) (Task 1f) 

Interviews/survey with MS 

authorities (RA/MA, DA/IB), 

beneficiaries, and target 

population 

• 

Project reporting (union actions 

and emergency actions); 

additional studies and literature 

• 

Joint monitoring reports or 

cross-check of individual 

(project level) monitoring 

reports  

•  Desk analysis, at aggregate 
level as well as a sample of 

projects-level information 

Interviews with EU officials 

Focus groups (validation) 

• 
• 

 
 
 
 
 
 
 
 
 
 
 
 
Data Source and analytical 

tool 

Question 

Sub-question 

Indicative judgement 

Indicator 

Criteria 

grounds (e.g. same target 

group but different type of 

measure/ different need 

addressed/ different readiness 

of the type of funding 

support chosen) 

Were the actions 

6.2.1 The fund is coherent 

6.2.1 Mechanisms ensure there are no/few overlaps or 

implemented 

with the current policy 

Duplications 

through the Fund 

agendas at EU and national 

coherent with and 

level 

non-contradictory to 

other interventions 

6.2.2 The knowledge 

6.2.1-6.2.2 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

with similar 

objectives? 

generated by the fund 

6.2.2 Extent to which synergies have been realised 

provided feedback in to the 

policy making 

Complementarity 

Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

7. Were the 

7.1 Was an assessment 

7.1.1 Adequate degree of 

7.1.1 Number and type of other EU interventions covered in 

objectives set in 

of other interventions 

assessment of other interventions 

the assessments 

the national 

with complementary 

carried out during the programming 

programme and 

objectives carried out 

phase 

7.1.1 Extent to which the assessment affected the design of the national 

the 

and taken into account  

corresponding 

during the 

implemented 

programming stage? 

actions 

programme 

Degree of supporting evidence from consultations (opinion of 

stakeholders) 

93 

Data Source and analytical 

tool 

Synthesis of implementation 

reports (Task 1d) 

Systematic review of MS 

evaluations (Task 1e) 

Final project reporting (UAs 

and EMAS) (Task 1f) 

Interviews/survey with MS 

authorities (RA/MA, DA/IB), 

• 

• 

• 

• 

 
 
 
 
 
 
 
 
 
Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

Data Source and analytical 

tool 

complementing 

7.2 Were coordination 

7.2.1 Structures, organisational 

7.2.1 Mechanisms ensure coordination, complementarities and 

beneficiaries, and target 

and supporting 

mechanisms between 

arrangements or coordination 

synergies across other EU funds 

those set in the 

the Fund and other 

mechanisms were used to ensure 

population 

• 

Project reporting (union actions 

framework of 

interventions (e.g. 

coordination, complementarities 

7.2.1-7.2.3 Degree of supporting evidence from consultations 

and emergency actions); 

other policies, in 

AMIF, ISF-BV, Fiscalis 

and, where relevant, synergies 

(opinion of stakeholders) 

particular those 

2020, Horizon 2020, 

across other EU funds, in particular 

pursued by the 

Hercule, ESF, ERDF, 

the AMIF and the ISF-BV, but also 

7.2.3 – 7.2.4 Extent to which synergies have been realised 

Member States 

etc) with similar 

cohesion policy, Fiscalis 2020, 

objectives established 

Horizon 2020, Hercule, and EU’s 

to ensure their 

external action 

complementarity for 

the implementing 

7.2.2 Coordination mechanisms and 

period? 

arrangements were used regularly 

and to good effect 

additional studies and literature 

• 

Joint monitoring reports or 

cross-check of individual 

(project level) monitoring 

reports  

•  Desk analysis, at aggregate 
level as well as a sample of 

projects-level information 

Interviews with EU officials 

Focus groups (validation) 

• 
• 

7.2.3 The Fund offers support to 

cross cutting policy agendas by 

complementing the support offered 

by other EU funds 

7.2.4 The knowledge generated by 

the Fund provided feedback into    the 

policy making 

7.3 Were mechanisms 

7.3.1 Alleged overlaps were in fact 

7.2.1 Mechanisms ensure there are no/few overlaps or 

aimed to prevent 

justified on objective grounds (e.g. 

Duplications 

overlapping of financial  

same target group but different type 

instruments put in 

of measure/ different need 

7.2.1-7.2.3 Degree of supporting evidence from consultations 

place? 

(opinion of stakeholders) 

94 

 
 
 
 
 
 
 
 
 
Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

Data Source and analytical 

tool 

addressed/ different readiness of the 

type of funding support chosen) 

7.4 Are the objectives 

7.4.1 Evidence of complementarity 

7.4.1 Degree of supporting evidence from consultations 

set in the national 

of national programme objective 

(opinion of stakeholders) 

programme 

complementary with other policies 

complementarity to 

pursued by MS 

other policies pursued 

by MS? 

EU Added Value 

Question  Sub-question 

Indicative judgement Criteria 

Indicator 

8. Was 

8.1 What are the main 

8.1.1 Evidence of additionality  

8.1.1 – 8.5.1 Established evidence on volume, scope effects, role 

any 

value 

added 

types of added value 

resulting from the Fund 

support (volume, scope, 

brought 

role, process)? 

and 

process effects 

8.1.1 – 8.5.1 Existence of national funds available for policy 

about by 

the EU 

support? 

8.2 Would the Member 

8.2.1 Evidence demonstrates that the fund 

State have carried out 

achieved additionality; it successfully 

8.1.1 – 8.5.1 Evidence of funding influencing national policy 

the actions required to 

mobilised resources and reached areas that 

implementation 

implement the EU 

would have otherwise been inaccessible 

• 

• 

• 

Data Source and analytical tool 

Synthesis of implementation 

reports (Task 1d) 

Systematic review of MS 

evaluations (Task 1e) 

Final project reporting (UAs and 

EMAS) (Task 1f) 

•  Quantitative analysis (Task 1f) 
• 
Interviews/survey with MS 

authorities (RA/MA, DA/IB), 

policies in the Fund 

without the fund. 

8.1.1 – 8.5.1 Assessment of contribution from each instrument 

beneficiaries, and target 

areas without the 

financial support of the 

Fund? 

8.1.1 – 8.5.1 Degree of supporting evidence from consultations 

(opinion of stakeholders) 

population 

95 

 
 
 
 
 
 
 
Question  Sub-question 

Indicative judgement Criteria 

Indicator 

8.3 What would be the 

8.3. 1 Evidence demonstrates that the fund 

Data Source and analytical tool 

• 

Project reporting (union actions 

most likely 

achieved additionality; it successfully 

8.1.1 – 8.5.1 Evidence of decrease/weakened policy 

and emergency actions); 

consequences of an 

mobilised resources and reached areas that 

implementation if interruption 

interruption of the 

would have otherwise been inaccessible 

additional studies and literature 
•  Desk analysis, at aggregate level 

support provided by the 

without the fund. 

8.1.1 – 8.5.1 Evidence of unchanged policy implementation if 

as well as a sample of projects-

Fund? 

interruption 

8.4 To which extent 

8.4.1 The Fund focuses on areas, interventions 

have actions supported 

and target groups where the results at the EU 

8.1.1 – 8.5.1 Likely scenario consequences at different levels 

by the Fund resulted         in a 

level can go beyond what can be  achieved by 

(EU/MS/beneficiary/target group) 

benefit at the EU level? 

the MS acting on their own.  

8.4.2 There is evidence of scope effects, i.e. of 

(opinion of stakeholders) 

8.1.1 – 8.5.1 Degree of supporting evidence from consultations 

level information 

Interviews with EU officials  

Focus groups 

• 
• 

additional target groups addressed or 

additional types of intervention offered 

8.4.3 There is evidence of scale effects, i.e. of 

a higher volume of services offered/end-users 

addressed 

8.4.4 There is evidence of 

function/role/process effects, i.e. of learning 

and increased capacity to manage the 

provision of public support within the 

administrations involved 

8.4.5 There is evidence of 

function/role/process effects, i.e. of learning 

and increased capacity to manage the 

96 

 
 
 
 
 
 
 
 
 
Question  Sub-question 

Indicative judgement Criteria 

Indicator 

Data Source and analytical tool 

provision of public support within the 

administrations involved 

8.5 What was the added 

8.5.1 The knowledge generated by the Fund 

value of operating 

provided feedback into the policy making 

support? 

Sustainability 

Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

9. Are the 

9.1 What were the main 

Adequate arrangements put in place to check the        

9.1.1 Number and type of measure adopted to ensure 

positive 

measures adopted by the 

sustainability of the project proposals 

sustainability at programming stage 

Data Source and 

analytical tool 
•  Calls for proposals 
documents / ISF-P 

effects of 

Member State to ensure 

There is no evidence of dependency, i.e. of 

9.1.1 Number and type of measures adopted to ensure 

Guidance documents at 

the 

the sustainability of the 

systematic lack of investment based on national 

sustainability at implementation stage 

projects 

results of the projects 

resources for relevant services that are provided 

9.1.1 Absorption rate of the Fund  

supported 

implemented with the 

entirely through support from EU funds.  

9.1.1 Absorption rate at project level 

EU/national level 
•  Targeted survey to MS 

competent authorities and 

by the 

Fund 

Fund support (both at 

programming and 

likely to 

implementation stage)? 

9.1.2 Number of projects with exist strategies (plan for 

beneficiaries. 

phasing out of external support) 

• 

Interviews with: EU 

Agencies (Europol, 

CEPOL); MS competent 

last when 

the 

support 

from the 

9.2 Were mechanisms put 

9.2.1 Evidence of employed mechanisms to ensure 

9.2.1 Examples of sustainability checks at programming stage 

in place to ensure a 

sustainability  

9.2.1 Examples of sustainability checks at implementation stage 

and responsible 

sustainability    check at 

9.2.2 Securing the training of personnel for the 

9.2.2 Evidence of investments in adequate and regular in-house 

programming and 

services involved in the implementation of actions 

staff training 

authorities; Beneficiaries 

and target population. 

ISF-P will 

implementation stage? 

9.2.3 Degree of supporting evidence from 

9.2.3 Degree of supporting evidence from consultations (opinion 

• 

Systematic review of MS 

be over? 

consultations (opinion of stakeholders) 

of stakeholders) 

evaluations (Task 1e) 

97 

 
 
Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

9.3 To what extent are the 

9.3.1 

Evidence of projects transferred, replicated 

outcomes/benefits of the 

or upscaled 

9.3.1 

9.3.2 

Examples of projects replicated at national level 

Equipment in use 2 years after their acquisition/number 

Data Source and 

analytical tool 
•  Case studies (Task 4) 
• 

Public consultation (Task 

actions sustained by the 

9.3.2 

Examples of sustainability of results at 

of equipment acquired under the Fund (> than EUR 10 000); 

2d) 

Fund expected to continue 

EU/MS/beneficiary level 

thereafter? 

9.4 What measures were 

9.4.1 Adequate arrangements put in place to check 

9.4.1 Evidence of extended lifespan of equipment delivered with 

adopted to ensure the 

the sustainability of the project proposals 

the fund support 

continuity of the activities 

carried out thanks to the 

operating support? 

Simplification and reduction of administrative burden 

Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

10. Were the 

10.1 Did the innovative procedures 

10.1.1  SCOs were used were relevant and created simplification for the 

10.1.1 Application of SCOs in 

Data Source and 

analytical tool 

• 

Systematic review 

Fund 

introduced by the Fund (simplified 

different stakeholders concerned  

implementing measures under the 

off2,0evaluations 

management 

cost option, multiannual 

10.1.2  The national programmes allowed steering resources towards 

ISF 

(Task 1e) 

procedures 

programming, national eligibility 

new and emerging needs at a low administrative cost  

10.1.2 MS authorities / Beneficiaries 

•  Case studies (Task 

simplified and 

rules, more comprehensive national 

10.1.3  Operating support was used in a cost-effective manner and 

/ participants’ opinion on the 

4) 

the 

programmes allowing for flexibility, 

reduced administrative burden for the actors involved  

administrative burden related to 

• 

Project reporting 

administrative 

operating support and Special 

10.1.4  Special schemes were used in a cost-effective manner and 

changes in national programmes 

(union actions and 

burden 

Transit Scheme for Lithuania) bring 

reduced administrative burden for the actors involved  

(allowing flexibility) 

reduced for its 

about simplification for the 

beneficiaries? 

beneficiaries of the Fund? 

10.1.2 Change in number of FTE to 

emergency 

actions). 

manage the Fund (compared to 2007-

• 

Interviews/survey 

2013) 

with MS 

98 

 
 
 
Question 

Sub-question 

Indicative judgement Criteria 

Indicator 

Data Source and 

analytical tool 

10.1.3 Evidence of cost-effectiveness 

authorities 

arrangements in the use of operating 

(RA/MA, DA/IB), 

support 

beneficiaries, and 

10.1.4 Evidence of cost-effectiveness 

participants 

arrangements in the use of special 

schemes 

99 

 
 
 
 
 
 
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COST 

The  table  provides  an  indication  of  the  main  costs147  and  benefits  of  the  ISF-P  implementation.  As  mentioned  in  the  Efficiency  section:  Overall,  the 
proportionality of administrative burden in ISF-P implementation varied across Member States, reflecting differences in resource availability, procedural 
complexity, and national administrative structures.  

Cost or benefit  

Citizens/consumers  

Businesses  

Administrations  

Other?  

Quantitative   Comment   Quantitative   Comment   Quantitative  

Comment  

Quantitative   Comment  

One-off   

ISF-P 
funding (overall 
financial envelope) 

ISF-P funding 
(already planned) 

One-off   

ISF-P funding 
(paid) 

Direct compliance 
costs (adjustment 
costs, 
administrative 
costs, regulator 
charges)  

Recurrent  

Recurrent  

The financial envelope for ISF -
P initially set at EUR 1 004 
million, increased to 
approximately EUR 1 138 
million  

EUR 1 219 414 116 

EUR 940 025 997 

Approx. 30-40 person-days per 
call 

Typically between 9-30 person-
days per project. 

Direct and competitive 
awards (i.e. info to 
applicants, preparing 
calls and guidelines)148  

Costs for MAs for 
evaluation of proposals/ 
projects (screening and 

147 Based on information received from Responsible Authorities and beneficiaries through the conducted targeted survey. 
148 The costs for Responsible Authorities vary across member States: Some provided specific figures per call, such as 6 man-days per call, while others reported total time spent, ranging 
from 15 to 60 man-days. One estimate mentioned 15-20 man-days, while another stated 15 man-days for 57 procedures. A few responses indicated longer durations, such as 40 or 60 
man-days.  

100 

 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
Recurrent  

One-off 

Approx. 30 person-days.  

The most common value 
reported is 30 FTE. 

n/a  

Indirect costs 
(compliance costs 
or other indirect 
costs such as 
transaction costs)  

Direct (short-term) 
benefits 

Direct (mid-term) 
benefits (expected) 

Strengthened Member States’ 
capacities to combat cross-
border, serious, and organised 
crime, including terrorism, and 
reinforcing mutual cooperation 

101 

selecting applications) 
under the ISF-P 

Time spent on reporting 
per year by a full-time 
employee  

The time spent by 
beneficiaries for the 
preparation of one 
project proposal varies 
significantly. 

The effects cannot be 
quantified and are 
assessed in mostly 
qualitative terms and 
through output 
indicators, e.g. Number 
of law enforcement 
officials trained on 
cross-border-related 
topics with the help of 
the Fund.  

 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
  
  
 
  
 
 
 
Enhanced capacity of Member 
States to manage security-related 
risks, crises, and protect critical 
infrastructure 

The results of the 
synthetic control method 
suggest positive effects 
of participation in ISF-P 
on the exchange of 
information between 
MS. 

The effects cannot be 
quantified and are 
assessed in mostly 
qualitative terms and 
through output 
indicators, e.g. Number 
of tools put in place or 
upgraded with the help 
of the ISF-P to facilitate 
the protection of critical 
infrastructure by 
Member States in all 
sectors of the economy 

102 

Indirect (long-term) 
benefits (expected)  

Increased 
internal 
security in 
the EU 

 
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT 

Call for evidence 

Prior to the start of the evaluation, in line with the Better Regulation Provisions, a call for 
evidence  was  launched  in  the  Have  Your  Say  platform  from  28  August  2023  to  25 
September 2023. No contributions were received149.  

Consultation strategy and methodology 

The consultation strategy for this ex-post evaluation included the targeted interviews and 
surveys, a public consutation and two focus groups. The objective of the consultations was 
to collect relevant information and insights on the effectiveness, efficiency, simplification 
and  reduction  of  administrative  burden,  coherence,  complementarity,  EU  added  value, 
sustainability and relevance of the ISF-P, as well as to collect inputs on lessons learned. 
To  this  end,  a  wide  range  of  stakeholders  were  consulted,  including  Member  States, 
Commission officials, implementing partners and beneficiaries.  

Table 11 provides a short description of the targeted stakeholder per each activity and the 
number of participants. 

Table 11 – Description of targeted stakeholders 

Activities 

Stakeholder targeted 

Timing, stakeholder engagement 

Public 
consultation 

Targeted 
surveys 

The public consultation was open to a wide audience, including 
those who have been involved in the management, coordination 
and supervision of the ISF-P, those who have benefitted from the 
ISF-P  (e.g.,  police  station  which  has  received  equipment 
purchased 
for 
implementing and/or initiating a project supported by the ISF-P 
(beneficiary) and citizens. 
Survey 
for  National  authorities  within  Member  States 
(Managing Authorities, Delegated Body, audit Authority, other 
relevant national authority 

the  Fund), 

responsible 

through 

those 

Survey for beneficiaries, experts, civil society and businesses 

Interviews  

Stakeholders  covered  with  scoping  interviews  (ISF-P  and  ISF 
combined): 
EU institution (DG HOME) 
Member State Responsible Authority 

Stakeholder categories targeted via the interview programme for 
ISF-P and ISF (combined):150 

The public consultation was open for a period 
of  12  weeks  between  29  August  2024  -  21 
November  2024.  The  survey  was  designed 
using  EU  Survey.  It  was  published  on  the 
“Have Your Say” portal.  

8  August  2024  -  18  September  2024,  
53 respondents (45 involved in ISF-P or both 
ISF-P and ISF) 

8  August  2024  –  18  September  2024,  
165  respondents  (123  involved  in  ISF-P  or 
both ISF-P and ISF) 

June 2024 – March 2025 

Number of interviews:  

• 

Total scoping interviews for ISF-P 
and ISF: 5.  

149 Internal Security Fund (ISF) Police 2014-2020 – ex post evaluation. 
150  Section  3.3  of  the  Synopsis  Report  presents  a  breakdown  of  interviews  (intro  three  major  groups). 
Interviews were grouped into targeted interviews for country case studies, targeted interviews for thematic 
case studies, and additional interviews for the ex-post evaluation of the ISF-P. For the country case studies, 
interviews  covered  the  assessment  of  the  ISF  and  the  ISF-P  (combined).  For  the  thematic  case  studies, 
interviews cover the ISF and the ISF-P separately, unless beneficiaries received funding under both the ISF-
P and the ISF. Additional ISF-P interviews solely covered the ISF-P period.  

103 

 
 
 
 
 
Activities 

Stakeholder targeted 

Timing, stakeholder engagement 

EU institutions; 
Member State Managing/Responsible Authorities; 
Monitoring Committee members; 
Beneficiaries of national programmes (ISF-P)  
Beneficiaries of Union Actions; 
Beneficiaries of EMAS; 
Final recipients, participants and representatives of stakeholders 
not directly involved 

• 

• 

Total targeted interviews for ISF-P 
and  ISF  (combined):  89  (out  of 
these,  two  are  scheduled  for  the 
week of the 24 March 2025).  

Targeted  interviews  covering  the 
ISF-P (see section 3.3):  

- 

- 

- 

as  part  of  the  country  case 
studies;  

as  part  of  the  thematic  case 
studies;  

additional 

ISF-P 
as 
to  21 
interviews  (12  up 
March  2025;  remaining  two 
scheduled for the week of 24 
March 2025) 

Focus 
Groups 

EU agencies; 
(selection  of  Responsible 
Relevant  national  authorities 
Authorities,  Delegated  Authorities,  Intermediate  Bodies,  and 
Audit Authorities in Member States); 
Beneficiaries  under  the  ISF  and  ISF-P  components:  National 
Programmes,  Emergency Actions and Union Actions. 

First  Focus  Group151:  25  June  2024,  77 
participants 

Second  Focus  Group:  only  on  ISF:  20 
November 2024 

Third Focus Group on ISF-P: 3 April 2025, 60 
participants  

Source: Preparatory study 

Results of the consultation activities 

Feedback from the public consultation 

In total, 45 stakeholders responded to the public consultation.  The largest proportion of 
respondents, 73% (33 out of 45), represented public authorities. Other stakeholder groups 
included academic or research institutions (7%, 3 out of 45), NGOs (2%, 1 out of 45), EU 
citizens (9%, 4 out of 45), and those who identified as "Other" (9%, 4 out of 45).  

151 The First Focus Group covered mostly the ISF, but participants were invited to share their experiences 
with the ISF-P when presenting comparisons, if relevant.   

104 

 
 
 
 
 
Figure 21 - Distribution of responses by stakeholder type 

3; 7%

Academic/Research
Institution

2; 4%

3; 7%

4; 9%

1; 2%

4; 9%

33; 73%

EU Citizen

5; 11%

NGO (Non-
governmental
organisation)

Other

10; 22%

Public authority

Responsible for
implementing and/
or initiating a
project supported
by the ISF-P
(beneficiary)

Management/coordi
nation/supervision
of the ISF-P

25; 56%

None of the above/
I am not familiar
with the ISF-P

Responses  were  received  from  a  diverse  range  of  EU  Member  States.  The  highest 
representation  came from  France (13%, 6 out  of 45),  Hungary (13%, 6  out  of 45),  and 
Bulgaria  (11%,  5  out  of  45).  Other  countries  with  multiple  responses  included  Greece, 
Italy, and Romania (each with 11%, 5 out of 45), while individual responses were recorded 
from several other Member States. 

Among  the  respondents,  the  majority  (56%,  25  out  of  45)  had  been  responsible  for 
implementing or initiating a project supported by the ISF-P. Another 22% (10 out of 45) 
were involved in the management, coordination, or supervision of the Fund, while 7% (3 
out of 45) had directly benefitted from the ISF-P. A smaller proportion (11%, 5 out of 45) 
stated they were not familiar with the Fund, and 4% (2 out of 45) selected "Other." Most 
beneficiaries participated as representatives of law enforcement authorities, with 67% (2 
out of 3) indicating they represented police agencies.  

When asked to evaluate the importance of various security challenges, the overwhelming 
majority  of  respondents  (91%,  41  out  of  45)  regarded  organized  crime,  terrorism  and 
radicalisation,  and  cybercrime  (including  child  sexual  exploitation)  as  highly  important 
challenges. Similarly, drug trafficking (78%, 35 out of 45), corruption (78%, 35 out of 45), 
and money laundering (76%, 34 out of 45) were also considered critical. Other issues such 
as firearm trafficking (73%, 33 out of 45) and the protection of critical infrastructure and 
public spaces (78%, 35 out of 45) were also highlighted as significant concerns. 

A large majority of respondents (93%, 42 out of 45) believe that EU Member States should 
cooperate on internal security matters, while only 2% (1 out of 45) believe Member States 
should  cooperate  "to  a  limited  extent."  When  asked  whether  EU-funded  initiatives 
effectively contribute to improving internal security, 76% (25 out of 33) responded "to a 
large extent," while 24% (8 out of 33) stated "to some extent." 

Respondents largely agreed that ISF-P had a positive impact on key security areas. For 
example, 47% (21 out of 45) believed that ISF-P contributed to preventing and fighting 
organized crime “to a large extent”, while 20% (9 out of 45) rated it as having contributed 
"to some extent." Similarly, 44% (20 out of 45) rated ISF-P's contribution to cross-border 
law enforcement cooperation as highly effective. 

105 

 
 
 
When asked about the cost-effectiveness of ISF-P, 56% (19 out of 34) stated that the results 
were achieved in  a cost-effective manner "to a large extent,"  while 41% (14 out  of 34) 
believed  they  were  cost-effective  "to  some  extent."  The  majority  of  respondents, 
specifically 65% (29 out of 45), considered the administrative burden brought by ISF-P 
proportionate  to  the  benefits.  However,  qualitative  feedback  indicated  concerns  about 
excessive  bureaucracy,  with  some  respondents  suggesting  a  need  for  simplification  in 
procedures. 

A  strong  majority  (76%,  25  out  of  33)  believed  EU-funded  initiatives  significantly 
contributed  to  internal  security,  with  some  respondents  emphasizing  that  cooperation 
mechanisms improved considerably. Most respondents expressed strong support for EU-
funded initiatives, with many highlighting their role in fostering international cooperation, 
improving  intelligence  sharing,  and  supporting  law  enforcement  capabilities.  Several 
responses  emphasized  the  necessity  of  EU-wide  coordination  in  tackling  cross-border 
crime. However, a few respondents suggested that while the initiatives are valuable, their 
effectiveness could be enhanced by reducing administrative burdens, increasing funding 
for law enforcement agencies, and improving coordination between EU-level and national-
level initiatives. 

82% (27 out of 33 responses) believed that ISF-P activities sufficiently addressed the needs 
of law enforcement authorities, while views were more divided regarding civil society and 
private entities, with 30% (10 out of 33) stating these groups were only addressed "to some 
extent."  73%  (24  out  of  33)  agreed  that  ISF-P-supported  activities  were  necessary  for 
improving operational cross-border cooperation, with 61% (20 out of 33) emphasizing the 
importance of information exchange mechanisms. 

Regarding the complementarity of ISF-P with initiatives at different levels, 40% (18 out 
of  45)  found  it  to  be  highly  complementary  at  the  EU  level,  while  33%  (15  out  of  45) 
believed  it  was  complementary  at  the  national  level.  Regional  and  international 
complementarity was perceived as slightly lower. 

A notable 59% (20 out of 34) indicated that projects funded under ISF-P would have been 
implemented on a smaller scale or with lower quality without the Fund’s support. Only 3% 
(1 out of 34) believed the projects would have been carried out in full without ISF-P, while 
35% (12 out of 34) stated they would not have taken place at all. 

Feedback from targeted surveys 

Two targeted surveys were launched on 7 August 2024 and closed the 18 September 2024. 
One  of  the  targeted  surveys  addressed  the  key  Member  States  competent  authorities 
involved  in  the  management,  coordination,  and  supervision  of  the  ISF,  while  the  other 
targeted survey aimed at targeting the Union Actions beneficiaries and national programme 
beneficiaries. The total number of responses amounts to 218. The majority of respondents, 
98 (45%), come from law enforcement authorities such as police or customs (Figure 21). 
There is also a notable representation of NGOs (9%, 19 respondents) and other relevant 
national authorities (6%, 13 respondents). The smallest groups include businesses (2%, 5 
respondents), audit authorities (1%, 3 respondents), and international organisations (1%, 3 
respondents).  Half  of  the  respondents  (50%,  108  respondents)  have  dealt  with  both  the 
2014-2020  and  2021-2027  programming  periods  of  the  ISF-P  and  ISF.  A  quarter  of 
respondents (26%, 56 respondents) have experience solely with the ISF-P, and only a small 
proportion of respondents (2%, 4 respondents) did not know or refused to answer. 

106 

 
Figure 22 - Breakdown of responses by stakeholder group 

0

20

40

60

80

100

98

Law enforcement authority (e.g., police, customs)

Responsible Authority / Managing Authority

Research organisation, university, think tank or other research-
oriented institution

Non-governmental organisation

Other relevant national authority (please specify) not acting as
Responsible Authority/Managing Authority, Audit Authority or…

Other (please specify)

Company/ Business

Don’t know/refuse to say

Intermediate Body / Delegated Body

Audit Authority

International Organisation

32

24

19

13

11

45%

15%

11%

9%

6%

5%

5

2%

2%

5

4

2%
3
1%
3

1%

Count

Percentage

N=218 

The largest number of respondents are located in Italy, with 31 respondents (15%). France 
follows with 18 respondents (9%), while Belgium ranks third with 13 respondents (6%). 
Countries like Finland (11 respondents, 5%) and Bulgaria (10 respondents, 5%) are also 
relatively  well-represented.  Countries  with  fewer  responses  include  Latvia,  Ireland, 
Luxembourg,  Slovakia,  and  Slovenia,  with  only  1%  or  2%  of  total  respondents.  This 
distribution demonstrates a balanced representation across several EU Member States, but 
with a slight concentration in southern and western European countries. Italy, France, and 
Belgium  collectively  account  for  30%  of  the  total  responses,  indicating  significant 
participation from these regions (Figure 22).  

107 

 
 
Figure 23 - Breakdown of responses by country of origin 

31

35

30

25

20

15

10

5

0

n=218 

18

13

11

10 10 10

9

9

8

8

8

8

8

6

5

5

5

4

4

4

3

3

2

2

2

Data shows that most respondents are beneficiaries, benefitting either from Union Actions 
or  Member  State  Actions  (Figure  23).  32%  of  respondents  (68  respondents)  identified 
themselves as beneficiaries of projects funded by Union actions within the ISF-P or both 
ISF-P and ISF. Another 19% (41 respondents) have been beneficiaries of projects funded 
by national programmes within the ISF-P or both ISF-P and ISF. 21% (45 respondents) 
have been involved in the management, coordination, or supervision of the ISF-P and both 
ISF-P and ISF. A smaller proportion of respondents indicated familiarity with the Funds 
from their work for EU agencies, bodies and offices or international organisations (2%, 3 
respondents). 152 

152 It should be noted that, while 21% (45 respondents) are involved in the management and coordination of 
the Funds, only 10% (21 respondents) identified as Managing Authorities, while 1% (2 respondents) said 
they were an Delegated/Intermediate Body and 1% (1 respondents) were an Audit authority. This means that 
a maximum of 10% (21 respondents) were involved in the management, coordination and supervision of the 
Funds in line with the intended meaning of the response to the question “What best describes your role or 
relationship to the ISF and/or ISF-P? Please select the option that most closely matches your situation.”152. 
The original responses of survey respondents have not been changed. It is possible that respondents to the 
survey have changed their affiliation in the meantime and were providing responses in the role of a managing 
or supervising body even though they know find themselves working for a different organisation. Another 
possibility  is  that  respondents  wrongly  interpreted  the  response  to  mean  management  or  supervision  of 
projects, in which case they should have selected the role of beneficiary under the same question.  

108 

 
 
 
 
 
Figure 24 -  Breakdown of responses by geographic scope of business 

Role

0%

5%

10% 15% 20% 25% 30% 35% 40% 45%

40%

28%

24%

I am a beneficiary - I have implemented projects funded by Union
actions (a call for proposal launched by the European Commission)
within the ISF and/or ISF-P

I am a beneficiary  - I have implemented projects funded by the 
Member States’ programme (calls for proposals launched by a 
managing authority in my country under ISF and/or ISF-P)

I have been involved in the management/coordination/supervision of
the ISF and/ or ISF-P

Other (please, specify)

5%

I am familiar with the Fund(s) in my professional capacity (e.g.,
practitioner, expert, researcher)

I am familiar with the Fund(s) from my work for EU agencies, bodies
and offices or international organisations

1%

1%

I am familiar with the Fund(s) in my personal capacity (e.g. expert,
researcher)

0%

Percentage

N=218 

The largest group of respondents, 43% (43 respondents), participated in Fund actions as 
representatives of the police. This is followed by staff of ministries or national agencies at 
14% (14 respondents) and NGOs at 13% (13 respondents). Academia or researchers also 
make  up  a  significant  portion,  at  10%  (10  respondents).  Other  groups,  such  as  private 
entities  (5%,  5  respondents),  border  police  (2%,  2  respondents),  and  customs  (2%,  2 
respondents), represent smaller portions of the respondents. 

Figure 25 - Breakdown of responses by organisation type 

Representative of...

0%

5%

10% 15% 20% 25% 30% 35% 40% 45% 50%

Staff of a ministry or national agency

Police

NGO

A representative of the academia / researcher

Other (please, specify)

A private entity/individual

Local and/or regional authority

Border Police

Customs

Judicial authority

N=214 

Percentage

109 

 
 
 
The largest share of beneficiaries have implemented actions in the field of terrorism and 
radicalisation (33 out of 186, 18%), organised crime (27 out of 187, 15%), and cybercrime, 
including child sexual abuse (20 out of 187, 11%). 

Survey for Competent authorities 

The survey targeting Member State Competent authorities gathered 53 responses from 23 
Member States.  

Effectiveness 

Actions  promoting  collaboration,  knowledge  sharing  and  operability  are  seen  as  the 
most effective in enhancing the EU’s internal security (66%, 35 respondents indicating “to 
a large extent”). Exchange, training, and education of staff and experts is viewed as highly 
effective, with 53% (28 out of 53) indicating it was effective "to a large extent.". Efforts 
related  to  analytical,  monitoring  and  evaluation  activities  as  well  as  actions  concerning 
third countries are also recognised for their contribution, though to a much lesser degree 
(respectively 19%, or 10 out of 53 and 17%, or 9 out of 53, indicating relevance to a large 
extent). 

the 

the  programming, 
involvement  of  relevant  partners  during 
As  concerns 
implementation,  monitoring  and  evaluation  of  the  Programme,  ensuring  the active 
participation of partners during the implementation was considered as a major challenge 
to a large extent  (19% of respondents, 10 out of 53). 

While the control systems and anti-fraud mechanisms are viewed positively to some 
extent, there is a considerable proportion of respondents unsure about some aspects of this 
mechanism. Coordination with relevant bodies is seen as effective "to a large extent" by 
19% (10 respondents), and follow-up actions on fraud detection received similar feedback, 
with 45% indicating effectiveness to a large or to some extent (24 out of 53). While fraud 
prevention training is seen as adequate by 19%, many respondents (10) indicate challenges 
"to a limited extent." The majority of respondents (64%, 34 out of 53) believe that effective 
fraud  detection  mechanisms  have  been  established  in  their  country,  i.e.  there  are  clear 
procedures for reporting fraud and irregularities have been established. The timelines of 
reporting requirements are considered adequate, with 64% of respondents indicating they 
are  effective  to  a  large  or  to  some  extent  (31  out  of  53).  Among  those  countries  that 
benefitted from EMAS, 26% feel it was effective "to a large extent" (5 out of 19 responses) 
while 21% see it working "to some extent” (5 out of 19). 

Efficiency 

Respecting timelines emerged as the most significant issue in managing Member States 
Programmes and related application procedures, with 64% of respondents (28 out of 53 
respondents) finding it difficult to adhere to deadlines to some extent and to a large extent 
jointly, particularly concerning reporting and program management. Second, adhering to 
reporting requirements and timelines also proved challenging, with 53% of participants 
(23 out of 53 and 24 out of 53, respectively) reporting difficulties, while 45% (22 out of 
53)  struggled with payment management. Lastly, providing support to beneficiaries and 
using  digital  platforms  were  notable  issues.  A  substantial  40%  (21  out  of  53)    of 
respondents  indicated  challenges  in  offering  adequate  support  to  beneficiaries,  with  the 
same percentage reporting obstacles in using the digital platform for applications (21 out 

110 

 
of 53), and 23% of respondents (12 out of 53), finding this challenge relevant to a large 
extent.  

Figure 26 - Degree to which the following points represented a challenge in managing Member 
States Programmes and related application procedures 

Designing direct and competitive award

13%

21%

Contractualization

4%

30%

40%

38%

9%

17%

9%

19%

Respecting the timelines

4%

25%

43%

21%

8%

Use of the digital platform for application

Providing sufficient support to beneficiaries

15%

15%

28%

30%

Adhering to reporting requirements

6%

30%

Adhering to reporting timelines

8%

28%

19%

26%

11%

30%

15%

9%

36%

36%

17%

11%

17%

11%

 Managing payments

13%

26%

36%

9%

15%

0%

50%

100%

Not at all

To a limited extent

To some extent

To a large extent

Don't know

N=53 

The estimated number of person-days spent by a full-time employee on preparing direct 
and  competitive  awards  under  ISF-P  varies  significantly  across  respondents.  Some 
provided specific figures per call, such as 6 person-days  per call, while others reported 
total time spent, ranging from 15 to 60 person-days. One estimate mentioned 15-20 person-
days, while another stated 15 person-days for 57 procedures. A few responses indicated 
longer  durations,  such  as  40  or  60  person-days.  Estimates  for  monitoring  programme 
implementation under ISF-P range widely, from 2 to 120 person-days. Some reported 8 
person-days per year, while others cited 10, 20, 30, 60, or 70 person-days. Estimates for 
reporting activities vary from 2 to 120 man-days. Some reported 20 person-days per year, 
while others cited 10, 25, 30, 50, or 60 person-days. One estimate detailed 2 person-days 
for 9 financial accounts and 20 person-days for 8 Annual Implementation Reports. Another 
mentioned for both monitoring programme implementation and reporting two employees 
for eight months.  The estimate for the average number of person-days spent on auditing 
and  on-the-spot  controls  of  ISF-P  projects  varies:  60  person-days  per  project  for  35 
projects, 60 person-days for 5 projects, 70 person-days for 2 projects, and 120 person-days 
for 2 employees over 8 months.  

The  majority  of  Managing  Authorities  consider  the  administrative  burden  of  the  ISF-P 
proportionate to its benefits (38%, or 20 out of 53) and to the burden associated with 
other EU funding sources (28%, or 15 out of 53) to some extent. In contrast, a significant 
portion  of  Managing  Authorities  view  the  ISF-P's  burden  as  proportionate  to  that  of 
activities funded solely from national sources only to a limited extent or not at all (42%, 
or 22 out of 53).  

The most common approach typically followed by the Managing Authorities to gauge the 
cost-effectiveness of the projects selected for support is the assessment of market prices 

111 

 
 
for  similar  products  and  services  (29  out  of  94  responses,  30%)153,  followed  by  the 
estimates from prospect beneficiaries (22, 23%) and the qualitative explanations on cost-
effectiveness from prospect beneficiaries (20 out of 94, 21%). 

Relevance 

Responses showed that 26% of respondents involved in managing and coordinating the 
fund  (14  out  of  53)  believed  that  the  Fund  had  been  flexible  to  a  large  extent  in 
responding  to  crises.  Another  32%  (17  out  of  53  respondents)  felt  that  the  Fund  was 
flexible "to some extent." Another notable proportion (26%, 14 respondents of 53) felt the 
Fund was flexible "to a limited extent," while only 2% (1 respondent) felt it had not been 
flexible at all.  

Regular  dialogue  and  consultation  activities  with  stakeholders  and  potential 
beneficiaries  (if  coming  from  channels  other  than  the  Monitoring  Committee)  was  the 
most common mechanism to ensure that the operations funded by the Funds best match 
the evolving needs in the Member States (27 out of 94 responses, 29%)154, followed by the 
regular  feedback  from  the  Monitoring  Committee  (16  out  of  94  responses,  14%)    and 
establishing  baselines,  and  monitoring  and  evaluation  mechanisms  to  track  changes  in 
needs over time (12 out of 94, 13%). 

The Funds’ activities sufficiently address the needs of law enforcement authorities with 
respect to their role in internal security matters to a large extent for 74% of respondents 
(39 out of 53). Similarly, it addresses the needs of relevant union agencies and bodies to a 
large extent for 25% of respondents (13 out of 53), but with another significant portion of 
respondents indicating to some extent (36%, 19 out of 53). For 28% of respondents (15 out 
of 53), the needs of the private sector are addressed to a limited extent, with 17 respondents 
(32%, 17 out of 53), believing that the needs are not addressed at all.  

Respondents who have been involved in the management, coordination or supervision of 
the  ISF-P  generally  support  maintaining  the  current  funding  thresholds  for  most 
areas in the 2014-2020 period. Some support for slight increases is evident, particularly 
for  crime  prevention,  combating  cross-border  crime,  and  maintaining  IT  systems.  A 
significant portion of respondents (17 out of 53, 32%) favour keeping the 5% maximum 
for technical assistance unchanged, while 12 respondents (23%) support a slight increase. 
Only 2 respondents indicated a preference for a slight decrease. For the minimum of 20% 
allocated to crime prevention and combating serious and organised crime, respondents are 
evenly split between maintaining the threshold (15 out of 53, 28%) and supporting a slight 
increase (15 out of 53, 28%), while only a small minority (2 out of 53) suggest a decrease. 
The allocation for enhancing the capacity to manage security-related risks (minimum 10%) 
sees  the  strongest  support  for  maintaining  the  current  level  (20  respondents  out  of  53, 
38%), with 11 respondents (21%) preferring a slight increase. While 12 respondents (23%) 
support keeping it unchanged the minimum allocation of 8% for IT system maintenance, 
14 (26%) favour a slight increase, and a smaller proportion (3 respondents) suggest a slight 
decrease. While 15 respondents (28%) support maintaining the current allocation of 8% 
maximum  for  third-country  actions,  a  notable  portion  (6  respondents)  advocate  for  a 
decrease, and 9 (17%) favour an increase. 

153 Multiple choice question. 
154 Multiple choice question. 

112 

 
 
Coherence 

Among the most common measures implemented during the programme  designing and 
implementation phase to ensure coherence with other programmes funded by EU resources 
in  similar  areas  of  work,  the  coordination  with  other  EU-funded  initiatives  (e.g., 
exchanges  with  coordinators of other funds  and  between relevant  ministries) stood out, 
with  38%  of  Managing  Authorities  indicating  it  (32  out  of  83  responses),  followed  by 
assessing interventions with similar objectives (21 out of 83 responses, 25%), and the 
establishment  of  a  Monitoring  Committee  or  inter-institutional  group  (19  out  of  88, 
23%)155. 

According to responses from the Managing Authorities, most respondents (37%, or 20 out 
of 53) indicated that national interventions complement ISF-P activities to some extent, 
while 26% (14 out of 53) reported a large extent of complementarity. On the other hand, 
actions organised by the AMIF and the Integrated Border Management Fund (IBMF) were 
seen to not at all complement ISF-P activities to some extent by 22% of respondents (12 
out of 53) and actions supported by the BMVI and the Instrument for Financial Support 
for  Customs  Control  Equipment  were  noted  as  complementary  to  a  limited  by  25%  of 
respondents (13 out of 53).   

A significant share of respondents observed that the EU structural funds complemented 
ISF-P activities to some extent (36%, or 19 out of 53).  Similarly, actions organised by 
Horizon 2020 are seen to not at all complement ISF-P activities by 17% (9 out of 53). 
Actions organised by Fiscalis 2020 are perceived to be complementing ISF-P actions to a 
limited (26%) and some extent (28%). 

EU added value 

For more than half of the Managing Authorities (57% of the respondents, 30 out of 53) the 
projects  funded  under  the  ISF  and  or  ISF-P  (e.g.  for  improving  cooperation  and 
coordination  between  different  Member  States,  exchange  of  information,  and  joint 
operations) would not have been carried out without the support of the Fund. On the 
other hand, 38% of the Managing Authorities (20 out of 53) believe these projects would 
have been carried out without the support of the Fund, but on a smaller scale of quality, 
for example, involving fewer Member States or with fewer participants. 

The  exchange  of  best  practices  is  the  most  common  choice  as  the  main  value  added 
brought by the Fund according to Managing Authorities (45 responses out of 212, 21%), 
followed by the increased operational cross-border cooperation (41 responses out of 
212,  19%),  and  the  improved  mutual  trust  and  confidence  between  law  enforcement 
authorities and other national authorities of Member States (34 responses out of 212, 16%). 
The  establishment  of  public-private  partnerships  (14  out  212,  6%)  figured  as  the  least 
selected option among Managing Authorities.156 

With regards to the sustainability of results, the majority of Managing Authorities indicated 
that the outcomes and benefits of the projects funded under ISF-P have been sustainable 
over time (with 48, or 90% of respondents, rating it to some or to a large extent). 

155 Multiple choice questions. 
156 Multiple choice questions. 

113 

 
 
Survey for beneficiaries  

The survey received responses from 147 beneficiaries, both implementing projects funded 
by the Union actions (87, 59%) and the national programmes (60, 41%), where respondents 
represented all Member States except for Luxembourg.  

Effectiveness 

Actions promoting collaboration, knowledge sharing and interoperability are seen as 
the most effective in enhancing the EU’s internal security according to beneficiaries (63%, 
93  beneficiaries  indicating  “to  a  large  extent”  out  of  147).  Exchange,  training,  and 
education of staff and experts is viewed as highly effective, with 53% (78 respondents out 
of 147) indicating it was effective "to a large extent.". Similarly, actions improving police 
cooperation and coordination, including with relevant Union bodies, are also viewed by 
beneficiaries as highly effective (79 out of 147, 54%). 

Beneficiaries  pointed  out  that  the  ISF-P  funded  activities  resulted  to  a  large  extent  in 
increased  knowledge  and  skills  of  training  participants  in  the  area  of  crime 
prevention/forensic  field    (59  out  of  147,  40%),  to  a  growing  number  of  stakeholders 
involved in the sharing of information, study and data collection (66 out of 147, 52%) and 
improved sophistication of vigilance tools, improved routines and recommended method 
support in response to crime events (44 out of 147, 30%).  

implemented  by  beneficiaries  resulted 

The  ISF-P  funded  actions 
increased 
communication between information systems and coordination between authorities for the 
largest  share  of  respondents  (44%,  66  out  of  147),  to  increased  capacity  and  skills  of 
competent authorities for responding to internal  security related accidents and incidents 
(59 out of 147, 40%). These actions ultimately contributed to enhancing the capacity of 
Member States to manage effectively security-related risks and crises and to protect people 
and critical infrastructure against terrorist attacks and security-related incidents. 

in 

According  to  a  majority  of  beneficiaries  (52%,  or  31  out  of  60  responses),  the  current 
indicators  effectively  capture  their  projects'  benefits  to  a  large  extent.  However,  they 
identify several opportunities for improvement in the evaluation framework. Beneficiaries 
suggest enhancing the system by giving project teams more flexibility to define success 
metrics  aligned  with  their  specific  objectives.  They  particularly  emphasise  the  value  of 
longer  assessment  periods,  especially  for  specialised  projects  such  as  financial  crime 
investigation training, to better measure sustained impact. Additionally, they recommend 
developing  more  targeted  indicators  for  different  project  types,  such  as  infrastructure 
upgrades  and  technology  implementations,  to  provide  more  meaningful  insights  into 
project value and effectiveness. 

Efficiency 

39%  of  beneficiaries  (58  out  of  147)  pointed  out  that  the  ISF  is  proportionate  to  its 
benefits to a large extent, and more than half of the respondents (51%, 75 out of 147) 
believe that the Fund is proportionate to the burden associated with other EU fundings 
(rating to some or to a large extent) and with national interventions (50%, 73 out of 147). 
The  majority  of  beneficiaries,  across  both  shared  management  and  Union  Actions, 
expressed that the timelines for reporting requirements were generally adequate and 
deadlines allowed for sufficient time for comprehensive reporting,  ensuring that the 
necessary information could be gathered and reviewed. Specifically, according to 58% (83 

114 

 
respondents  out  of 147 respondents) of beneficiaries, the timelines were adequate “to  a 
large extent” and “To some extent” according to 27% (39 replies out of 100 responses) of 
respondents.  

Beneficiaries  of  actions  funded  by  national  programmes  see  the  coordination  with  the 
Responsible authority as timely and effective (48 out of 60, 80%) and the beneficiaries 
implementing  projects  funded  by  Union  Actions  view  the  coordination  with  the 
Commission as timely and effective (51 out of 87, 60%).  

For project proposals, the estimated time ranges from 1 to 45478 man-days, with typical 
estimates around 60, 50, 40, and 30 man-days, depending on the project’s complexity, the 
number of people involved, and the role within the project (e.g., coordinator vs. partner). 
In  some  cases,  teams  of  3  people  worked  full-time  for  2  to  4  months  on  proposal 
preparation.  

For  annual  reporting,  the  estimates  range  from  2  to  1800  hours,  with  reports  typically 
requiring 20 to 100 man-days. The time spent on reporting also depends on factors like the 
complexity of the project  and the number of partners in  a consortium, with  some cases 
requiring  significant  administrative  tasks  (e.g.,  gathering  timesheets,  invoices,  and 
procurement documents). For larger consortia, up to one person per year may be dedicated 
to  reporting.  Some  responses  indicate  that  the  time  required  can  vary  widely,  with  one 
report mentioning 365 days for an entire year. 

Relevance 

The majority of Member States’ actions beneficiaries agree to a large extent that the Fund 
has been flexible in responding to new challenges and crisis situations, which emerged 
in the EU during its implementation (50%, 30 out of 60). Similarly, a significant portion 
of Union Actions beneficiaries believe to a large extent that the fund has been flexible in 
responding to new challenges and crisis situations (38 out of 87, 44%). The majority of 
beneficiaries pointed out that organised crime and terrorism and radicalisation are some of 
the most important challenges for safeguarding the internal security of the EU (119 out of 
147 responses each, 81%). Challenges like money laundering and firearm trafficking are 
seen as critical but receive slightly less emphasis, with 57% (84 respondents out of 147) 
and 53% (78 respondents out of 147) rating them as important "to a large extent." 

According to beneficiary survey responses, the Funds effectively meet internal security 
needs,  but  the  level  of  support  varies  significantly  across  different  groups.  Among 
beneficiaries, 63% (92 out of 147) indicate that law enforcement authorities' needs are well 
addressed. For Union agencies and bodies, 33% of beneficiary respondents (48 out of 147) 
report their needs are met to a large extent. However, beneficiaries indicate lower support 
levels for civil society and private organisations, with only 25% (37 out of 147) and 13% 
(19 out of 147) respectively reporting their needs being met to a large extent. 

Coherence 

Beneficiaries  of  Union  Actions  and  national  programmes  indicated  that  national 
interventions complement the activities provided by the ISF-P to a large extent (27 and 
23 respectively, out of 147, 34%).157 On the other hand, most beneficiaries indicated that 
actions organised by the AMIF do not complement at all ISF-P funded initiatives (11 out 

157 With the exception of “I don’t know”.  

115 

 
 
of 147, 7%) and actions organised by the BMVI and the Instrument for Financial Support 
for Customs Control Equipment to some extent (13 out of 147, 9%).  158The majority of 
beneficiaries is unsure whether ISF-P funded actions complement with Cohesion Policy 
Funds (90 out of 147, 62%), and actions organised by Horizon 2020 not at all complement 
ISF-P funded actions to some extent (10 out of 147, 7%). 

EU added value 

More than half of the Union  Actions and Member States’ beneficiaries believe that the 
projects funded under the ISF-P would not have been carried out without the support 
of the Fund (76 out of 147, 52%), while 36% of respondents (54 out of 147) pointed out 
that projects would have been carried out but in a smaller scale or quality, i.e. involving 
fewer Member States or fewer participants.  

Also among Union Actions beneficiaries, the survey shows that the majority of responses 
(117 out of 514, 23%) see the exchange of best practices as the main value added by the 
Fund. Increased cross-border cooperation (95, 18%), fostered innovative solutions to 
tackle  internal  security  threats  (84,  16%)  and  improved  mutual  trust  and  confidence 
between law enforcement authorities and other national authorities of Member States (79, 
15%) also figure as prominent results brought by the Fund.159  

The  survey  shows  that  beneficiaries  have  widely  transferred  the  knowledge  and  skills 
gained  through  their  projects  to  colleagues.  A  significant  number  of  beneficiaries  (?) 
distributed materials developed as part of the project (97) and made a presentation at an 
internal workshop in their institution (82).160 Formal training courses for colleagues who 
have  not  participated  in  the  project  are  the  least  common  activity  performed  by 
beneficiaries (50). 

With regards to the sustainability of results, the majority of beneficiaries indicated that the 
outcomes and benefits of the projects funded under ISF-P have been sustainable over time 
(with 48, or 80% of Member States’ actions beneficiaries and 67, or 77% of Union Actions 
beneficiaries rating it to some or to a large extent). 

Summary of the interviews 

In line with the stakeholder consultation strategy, the study team conducted an extensive 
interview programme (simultaneously covering the ISF and ISF-P).  

At the inception stage of the study, five scoping interviews161 were organised to gather a 
better  understanding  of  the  context  in  which  the  ISF  operates  and  any  key  elements  to 
consider for the research.  

Targeted interviews were grouped into: 

•  Targeted interviews for five country case studies; 

158 With the exception of “I don’t know”. 
159 Multiple choice question. The total number of respondents is 100. 
160 Multiple choice question.  
161  One  interview  with  a  Member  State  National  Authority  and  four  interviews  with  a  number  of 
representatives of DG HOME (cumulative interviews with different Units). 

116 

 
 
•  Targeted interviews for four thematic case studies; 

•  Targeted additional interviews for the ex-post evaluation of ISF-P (to address data 

gaps faced during the research and following the Interim Report).  

The study team selected the stakeholders to be interviewed in close cooperation with the 
Commission and developed the interview questionnaires jointly. The questionnaires were 
targeted to relevant stakeholder categories and included questions covering the ISF-P (and 
the  ISF,  when  relevant  and  covering  both  funding  periods).  The  interviews  were  semi-
structured,  and  appropriate  questions  were  selected  depending  on  the  interviewees' 
backgrounds and knowledge. 

Targeted interviews for country case studies 

The  objective  of  these  interviews  was  to  collect  country-specific  insights  on  what  has 
worked, and what has not with the implementation of the ISF-P (and of the ISF) at the 
Member  State  level  in  five  selected  Member  States  (Croatia,  Germany,  Latvia, 
Netherlands, and Spain). They also served to identify opportunities and challenges in the 
implementation of the ISF, as well as recommendations for future implementation.  

For the country case studies, interviews covered the assessment of the ISF and the ISF-P 
(combined). 

In total, the study team conducted 29 interviews with various stakeholder groups as part of 
the five country case studies, including: 
•  six interviews for Croatia; 
•  11 interviews for Germany; 
• 
three interviews for Latvia; 
• 
five interviews for the Netherlands; and, 
• 
four interviews for Spain. 

Targeted interviews for thematic case studies  

For the thematic case studies, interviews cover the ISF and the ISF-P separately, unless 
beneficiaries received funding under both the ISF-P and the ISF.  

In total, the study team conducted 37 interviews with various stakeholder groups as part of 
the thematic case studies, notably:  

• 
• 

interviews for the Union Actions case study; 
interviews for the EMAS case study;  

Additional interviews for the ex-post evaluation of ISF-P 

These additional interviews aimed to  address  the information  gaps that became  evident 
after submitting the Interim Report. The study team selected the stakeholders and the topics 
of discussion closely with the Commission.  

The selection included:  

•  seven interviews with the Responsible Authorities of (seven) Member States; 

117 

 
 
 
•  one interview with the members of the Monitoring Committee of a Member State; 
•  one interview with a beneficiary of EMAS; 
• 
• 

two interviews with beneficiaries of Union Actions; 
two  interviews  with  two  beneficiaries  under  the  national  programme  (to  be 
conducted during the week of 24 March 2025);  
•  one interview with a beneficiary of direct grants. 

Based  on  the  information  gaps,  the  interviews  included  (will  include)  the  following 
specific questions, among others: 

•  Comparisons of the ISF-P with preceding programmes (ISEC, CIPS), and with the 

ISF; 

•  Coherence with other initiatives; 
•  Complementarity of the ISF-P’s components; 
•  Difference in the distribution of resources to the specific objectives; 
•  Rationale behind the differences in the absorption rate; 
•  Effects of the extension of the implementation deadline; 
•  Gold-plating in relation to National Programmes; 
•  Systems  in  place  to  detect  fraud  and  irregularities  and  the  functioning  of 

Responsible Authorities;  
Information on admin requirements, specifically monitoring and reporting; 

• 
•  Use of technical assistance; 
•  Results of projects under Union Actions and EMAS; 
•  Sustainability of ISF-P projects; 
•  EU added value of the ISF-P (e.g. what actions have brought the most cooperation 

between Member States and replicable results). 

In total, 12 interviews were conducted up to 21 March 2025, and the remaining two will 
be carried out during the week of 24 March 2025.  

Summary of interviews 

The following sections present an overview of stakeholders’ views on the the functioning 
of the ISF-P following evaluation criteria: effectiveness, efficiency, relevance, coherence, 
complementarity,  EU  added  value,  sustainability,  simplification,  and  reduction  of  the 
administrative burden.  

Effectiveness 

According to the interviews, the ISF-P contributed significantly to achieving its objectives 
in  enhancing  Member  States'  capacity  to  combat  cross-border,  serious,  and  organised 
crime,  including  terrorism,  and  improving  coordination  and  cooperation  among  law 
enforcement authorities. 

Several beneficiaries highlighted that tools developed with projects funded by the ISF-P 
were crucial in addressing organised crime. For example, the PRoTECT project162 used 
vulnerability assessment tools to assist local authorities, while explosive disposal robots 

162 Country case study interview with the beneficiary of the Union Action from the Netherlands 

118 

 
 
 
 
played a key role in counterterrorism efforts and the prevention of cross-border crime in 
another Member State.163 

Many stakeholders emphasised the Fund’s role in improving cooperation and coordination 
among Member States. In this respect, two beneficiaries reported improved cross-border 
information  exchange  and  coordination  in  fighting  organised  crime,  significantly 
increasing intelligence sharing between national authorities, Europol, and other relevant 
bodies.164  One  beneficiary  implemented  projects  that  brought  together  government, 
private-sector,  and  civil  society  organisations  to  protect  children  from  online  sexual 
abuse.165 Similarly, another beneficiary worked with a range of sectors to strengthen the 
fight against cross-border crime, demonstrating the value of a multi-stakeholder approach 
in enhancing internal security.166 

Training  and  knowledge  transfer  were  also  identified  by  several  beneficiaries  as  key 
contributions  of  the  fund.  For  example,  AIRPOL  trained  over  200  officers  annually167, 
while  the  facial  recognition  training  implemented  by  another  beneficiary168  became  a 
significant  platform  for  sharing  expertise  and  improving  criminal  investigations  across 
Europe.  These  training  initiatives  were  essential  in  strengthening  law  enforcement 
capabilities. 

Two stakeholders highlighted the key contribution of the ISF-P to improve the capabilities 
of Member States, with funding allocated to acquiring specialised equipment and building 
crucial infrastructures, such as IT systems for information exchange169, and equipment for 
rescue operations, which significantly enhancing preparedness and response to crises.170 

Another  key  area  covered  by  the  ISF-P  projects  was  countering  terrorism  and 
radicalisation.  In  particular,  one  Managing  Authority  reported  the  success  of  anti-
radicalisation programs implemented by third-sector organisations,171  while a beneficiary 
stressed  the  importance  of  specialised  counter-terrorism  training,172  both  of  which 
supported national efforts to prevent and respond to terrorist threats. 

Regarding  the  ISF-P’s  capacity  to  engage  a  wide  range  of  stakeholders,  several 
interviewees  expressed  challenges  in  involving  civil  society  organisations,  research 
institutions and/or the private sector. This was also considering that national authorities 
were mainly active in the ISF-P policy fields as they better understood the issues at stake. 
The involvement of other categories of stakeholders, such as civil society organisations 
and research institutions, was not considered a priority given the limited expertise in the 
policy  fields  and  knowledge  of  challenges  experienced  by  Member  States  at  a  more 
operational level.173  

163 Country case study interview with the beneficiary of the National Programme from Spain 
164 Country case study interview with the beneficiary of the National Programme from Croatia; Thematic 
case study interview with the beneficiary of the Union Action from Belgium 
165 Thematic case study interview with the beneficiary of the Union Action from the Netherlands 
166 Thematic case study interview with the beneficiary of the Union Action from Belgium 
167 Thematic case study interview with the beneficiary of the Union Action from Sweden 
168 Thematic case study interview with the beneficiary of the Union Action from Estonia 
169 Additional interview with the Managing Authority from Bulgaria 
170 Country case study interview with the beneficiary of the National Programme from Latvia 
171 Additional interview with the Managing Authority from Finland 
172 Country case study interview with the beneficiary of the National Programme from France 
173 Additional interviews for the ISF-P: CY MA, CZ MA, IT MA. 

119 

 
 
Many consulted stakeholders shared that the ISF-P projects had a positive impact (29).174 

Efficiency 

While  the  funded  projects  achieved  the  objectives  to  a  significant  degree,  stakeholders 
stressed  the  challenges  in  the  projects’  implementation  related  to  the  availability  and 
management of human and financial resources. The ISF-P foresaw the implementation of 
systems to ensure cost efficiency, though the complexity of these systems often increased 
workloads. 

Several  Managing  Authorities  emphasised 
to 
administrative  tasks,  particularly  the  personnel-intensive  nature  of  managing  European 
funds.175 One Managing Authority176 reported the need for additional staff at the national 
level to deal with the complexities of the ISF-P.   

the  significant  challenges  related 

Beneficiaries  under  the  national  envelope  highlighted  the  cost-effectiveness  of  their 
projects but also noted challenges in resource allocation and reporting. One beneficiary 
stated that the implementation, monitoring, and reporting of projects required significant 
involvement  from  the  entire  project  team.177  Another  beneficiary178  pointed  out  the 
frequent  and  extensive  reporting  requirements,  which  were  burdensome  and  led  to 
significant  administrative  effort.    A  beneficiary  also  pointed  out  that  the  complexity  of 
procurement procedures made the entire process time-consuming. 179 

Due  to  the  COVID-19  pandemic,  cost  savings  were  achieved  in  areas  such  as  training, 
where digital formats replaced in-person activities.180  

Beneficiaries of Union Actions projects and EMAS provided mixed feedback on efficiency 
and cost-effectiveness, underlining the need for improving reporting and cost management. 
One  beneficiary181  explained  that  reporting  requirements  could  be  streamlined  by 
providing advance notice of data collection needs, which would help to speed up the final 
reporting  process.  Similarly,  a  beneficiary182  shared  that  while  results  were  achieved  at 
reasonable costs, the rush to complete reporting at the end of the project was a challenge. 

A  beneficiary  appreciated  the  guidance  and  assistance  from  the  Commission  and  a 
dedicated financial manager which helped keep the projects cost-effective.183   

174 Country case study interviews with the Managing Authorities from Spain (2), Croatia and Germany 
Country case study interview with one beneficiary of the Union Action from the Netherlands 
Country case study interviews with the beneficiaries of the National Programme from Croatia (2), Spain, 
Latvia  and  Germany;  Thematic  case  study  interviews  with  the  beneficiaries  of  the  Union  Action  from 
Sweden, Belgium, Estonia, Netherlands, Italy (2) and one on the EU level; Thematic case study interviews 
with the beneficiaries of the EMAS from Belgium, Spain and on one the EU level; additional interviews with 
the  Managing  Authority  from  Bulgaria,  Italy,  Finland,  France  and  Latvia;  additional  interview  with  one 
beneficiary of the National Programme from France; and additional interviews with the beneficiaries of the 
Union Action from the Netherlands (2) and Greece. 
175 Country case study interview with the Managing Authority from Spain 
176 Additional interview with the Managing Authority from Italy. 
177 Country case study interview with the beneficiary of the National Programme from Croatia. 
178 Country case study interview with the beneficiary of the National Programme from Latvia. 
179 Country case study interview with the beneficiary of the National Programme from France. 
180 Additional interview with the Managing Authority from Bulgaria. 
181 Country case study interview with the beneficiary of the Union Action from Croatia. 
182 Thematic case study interview with the beneficiary of the Union Action from Belgium. 
183 Thematic case study interview with the beneficiary of the Union Action from Estonia. 

120 

 
 
Other beneficiaries mentioned that the stringent financial rules created challenges for law 
enforcement, which had to reduce costs and limit spending to minimise financial risks.184  

Many stakeholders believed the results were achieved efficiently, with reasonable costs 
and human resources.185 

Relevance 

Most  consulted  stakeholders  considered  the  ISF-P’s  objectives  generally  aligned  with 
policy needs, and it could address the needs identified at the time of its adoption and adapt 
to evolving ones during its implementation period.186 

The  ISF-P’s  objectives  generally  aligned  with  policy  needs,  with  sufficient  financial 
resources  to  address  them  as  mentioned  by  one  Managing  Authority187  and  mid-term 
reviews enabling adjustments mentioned by another.188 One beneficiary expressed how the 
Fund helped to focus on their needs related to crime prevention, crisis management, cross-
border  cooperation,  and  equipping  law  enforcement,189  while  another  also  mentioned it 
supported  security  cooperation  among  EU  Member  States  and  international  partners.190 
Another  beneficiary  mentioned  the  objectives  met  the  EU  and  national  priorities  in 
combating  child  sexual  exploitation  but  lacked  broader  resilience-building  efforts. 
Stakeholders emphasised the need to address general crime, insecurity, and victimisation 
beyond terrorism.191   

The objectives set by Member States in the National Programme were generally considered 
relevant to the needs identified at national level. A Managing Authority192 noted that before 
drafting the Operational Programme, a needs assessment was conducted at the beneficiary 
level to inform funding decisions. Another Managing Authority193 Stated that, while some 
adjustments  were  made  overtime,  the  initial  needs  were  largely  financed.  A  Managing 
Authority194  highlighted  that  funding  was  instrumental  in  promoting  priorities  within 
respective  policy  areas,  while  another  Managing  Authority195  emphasised  the  direct 
engagement between the Managing Authority and national authorities to ensure that the 

184 Additional interview with the beneficiary of the Union Action from the Netherlands. 
185 Country case study interview with one Managing Authority from the Netherlands; Country case study 
interview with one beneficiary of the National Programme from Latvia; Country case study interview with 
one beneficiary of the Union Action from Croatia; Thematic case study interviews with the beneficiaries of 
the Union Action from Belgium, Estonia, the Netherlands and Italy (2); Thematic case study interviews with 
the beneficiaries of the EMAS from Spain and one on EU level; Additional interviews with the Managing 
Authorities from Bulgaria, Cyprus, Italy, Latvia, Finland and France; and Additional interviews with one 
beneficiary of the Union Action from Greece. 
186 Country case study interviews with the Managing Authority from Spain, Germany (2), Croatia and Latvia; 
Country case study interviews with beneficiaries of the National programme from Spain and Croatia (2); 
Country case study interview with one beneficiary of the Union Action from Croatia; Thematic case study 
interviews with beneficiaries of the Union Action from Sweden, Belgium, Estonia, Netherlands (2), and Italy 
(2); Additional interview with the Managing  Authority from Bulgaria; and  Additional interview with the 
beneficiary of the Union Action from Greece. 
187 Country case study interview with the Managing Authority from Spain.  
188 Country case study interview with the Managing Authority from Germany. 
189 Country case study interview with the beneficiary of the National Programme from Croatia 
190 Thematic case study interview with the beneficiary of the Union Action from Sweden 
191 Thematic case study interview with the beneficiary of the Union Action from the Netherlands 
192 Country case study interview with the Managing Authority from Spain. 
193 Country case study interview with the Managing Authority from Latvia. 
194 Interview with the Managing Authority from Cyprus. 
195 Interview with the Managing Authority from Italy. 

121 

 
 
National  Programme  responded  to  current  needs.  However,  a  Managing  Authority196 
pointed out that the Programme’s focus was sometimes unclear, as it was structured around 
activities rather than thematic priorities, making it challenging to determine its exact focus. 
Overall, all respondents (17)197 agreed that the needs were met. 

In  the  case  of  Union  Actions,  the  objectives  set  in  the  Annual  Work  Programme  were 
considered to significantly address actual needs. However, financial limitations restricted 
the full scope of work. A beneficiary stated that, while needs were partly covered, financial 
resources were insufficient to meet all work requirements.198  Another beneficiary noted 
that the objectives effectively addressed both national and EU-level needs, contributing to 
the  organisation's  activities.199    Many  respondents  (12)200  agreed  that  the  objectives 
addressed the identified needs. 

For EMAS, the objectives were generally relevant, but this component lacked sufficient 
flexibility,  especially  when  compared  with  the  EMAS  under  the  ISF.201  A  beneficiary 
pointed  out  that,  although  despite  the  lack  of  a  clear  definition  of  what  constituted  an 
emergency situation, it was possible to adapt funding to the applicants’ needs.202  

For shared management, several measures were taken to adapt the National Programme to 
changing needs. A Managing Authority described the implementation of a pilot framework 
project,  allowing  committees  to  decide  on  relevant  topics  and  tailor  projects  to  current 
needs.203 Another Managing Authority reported that needs were reassessed, and operations 
that no longer provided value were replaced with those aligned with EU policy priorities.204 
A beneficiary205 highlighted that their project required continuous adaptation to evolving 
threats appearing on social media trends to address new challenges, such as online hate. A 
Managing  Authority206  explained  that  the  ISF-P  framework  allowed  for  procedural 
adjustments,  including  alignment  with  EU  frameworks  such  as  the  Passenger  Name 
Record  (PNR)  and  adapting  to  online  meetings  during  COVID-19.  However,  some 
projects, such as knowledge-sharing initiatives, were cancelled due to resource constraints.  

Despite the flexibility, a Managing Authority noted that making changes to the National 
Programmes to ensure their relevance to evolving needs and priorities was administratively 
burdensome, as amendments required approval at several levels.207  

196 Interview with the Managing Authority from Finland. 
197 Country  case  study  interviews  with  the  Managing  Authorities  from  Spain  (2),  Germany  and  Croatia; 
Country case study interviews with the beneficiaries of the National programme from Croatia, Latvia (2), 
and  Spain;  Country  case  study  interview  with  one  Monitoring  Committee  from  Germany;  Additional 
interviews with the Managing Authority from Bulgaria, Cyprus, Italy, Latvia, Czechia, Finland and France. 
198 Thematic case study interview with the beneficiary of the Union Action from the Netherlands. 
199 Thematic case study interview with the beneficiary of the Union Action from Italy. 
200 Case study interviews with the Managing Authorities from Spain, Germany and Latvia. 
Thematic case study interviews with the beneficiaries of the Union Action from Sweden, Estonia, Germany, 
Italy (2), Netherlands and on the EU level; Additional interviews with the beneficiary of the Union Action 
from Greece. 
201 Thematic case study interview with the beneficiary of the EMAS on the EU level. 
202 Thematic case study interview with the beneficiary of the EMAS from Belgium. 
203 Country case study interview with the Managing Authority from Germany. 
204 Country case study interview with the Managing Authority from Spain. 
205 Country case study interview with the beneficiary of the National programme from Germany. 
206 Country case study interview with the Managing Authority from Czechia. 
207 Country case study interview with the Managing Authority from Finland. 

122 

 
 
Regarding the Union Actions component, projects demonstrated significant adaptability, 
especially due to the COVID-19 emergency, and necessary adjustments were made.208  

Coherence 

Most consulted stakeholders indicated that the ISF-P aligned with  other relevant  policy 
initiatives and maintained coherence with other EU funds. Coherence was ensured through 
coordination  mechanisms,  strategic  alignment  with  other  EU  funding  instruments,  and 
internal collaboration among the Commission, Managing Authorities and beneficiaries.  

Consulted stakeholders highlighted coordination efforts to ensure internal coherence, i.e. 
within  the  ISF-P,  among  the  different  components,  and  external  coherence,  with  other 
initiatives.  

On the internal cohere, during the consultation, two stakeholders reported concerns about 
the communication and alignment between the Managing Authorities and the Commission 
regarding  the  selection  of  projects  and  beneficiaries,  respectively,  under  shared 
management  and  the  Union  Actions  component.209  One  stakeholder  indicated  that  the 
Managing Authority generally had a more limited scope to make changes to the National 
Programme  and  to  the  selection  of  projects  that  were  foreseen  at  the  beginning  of  the 
funding period to align with the relevant needs identified at the national level.  

Regarding  external  coherence,  some  beneficiaries  acknowledged  connections  between 
ISF-P and other EU funding programmes like Horizon, noting that ISF-P remained distinct 
in its focus on operational support for law enforcement. In contrast, Horizon focused more 
on research and innovation.210  

Managing Authorities in several Member States actively worked to align funding priorities 
and  avoid  duplication.  For  example,  one  Ministry  of  Interior  established  coordination 
mechanisms to collect information on project ideas from various institutions and ensure 
coherence with national and EU funding instruments.211  

For Union Actions and EMAS, interviewed beneficiaries found that ISF-P funding aligned 
well with other initiatives. Some beneficiaries leveraged multiple funding sources, such as 
national  co-financing,  to  sustain  project  results.212  Effective  coordination  with  similar 
initiatives was emphasised to avoid redundancy, and collaboration with EU-level agencies 
helped  ensure  coherence,  as  seen  in  the  work  of  MAOC-N,  which  coordinated  with 
agencies to avoid overlapping activities during operations.213  

208 Country case study interviews with the Managing Authorities from Germany, Croatia, Spain; Country 
case study interviews with beneficiaries of the National programme from Germany and Croatia; Additional 
interview with one beneficiary of the Union Action from the Netherlands; and Additional interviews with 
the Managing Authority from France and Czechia. 
209 Additional interview with the Managing Authority from Czechia and Latvia. 
210 Country case study interviews with the beneficiaries of the National Programme from Croatia, Latvia and 
Spain. 
211 Country case study interview with the Managing Authority from Latvia. 
212 Country case study interview with the beneficiary of the Union Action from Croatia. 
213 Thematic case study interview with the beneficiary of the Union Action on the EU level. 

123 

 
 
However,  one  beneficiary  pointed  out  potential  overlaps  between  ISF-P  and  Horizon, 
particularly around internal security themes, and expressed uncertainty about how the two 
funding instruments related to each other.214  

Overall, a high number of stakeholders agreed that coherence was ensured throughout the 
funding period (12).215 

Complementarity 

Member States  and the  Commission  generally ensured complementarity  between  ISF-P 
projects and other funded components.  

For example, one Managing Authority highlighted the coordination of border surveillance 
equipment, which was used for both border protection (ISF-BV) and internal security (ISF-
P), optimising resources and avoiding duplication.216 Another Managing Authority noted 
that a Project Coordination Committee was established to harmonise projects’ ideas and 
prevent overlap with other funding sources.217 One Managing Authority218 also mentioned 
the  importance  of  internal  coordination  within  ministries  and  collaboration  with  the 
Commission to maintain complementarity.219 However, one beneficiary under the National 
Programme mentioned that equipment was not mutually used between different funds.220  

To ensure complementarity, one beneficiary under the Union Actions component reported 
that  their  project  was  built  on  existing  research  and  networks,  aligning  with  national 
programs.221 

Overall, many stakeholders222 acknowledged alignment with other instruments, although 
some concerns about overlapping activities remained, particularly regarding coordination 
between police bodies and different funds.223 

214 Country case study interview with the beneficiary of the Union Action from the Netherlands. 
215 Country case study interviews with the Managing Authorities from Spain, Latvia, Czechia and France. 
Country case study interviews with the beneficiaries of the National Programme from Latvia, Croatia and 
Spain;  Country  case  study  interview  with  the  beneficiary  of  the  Union  Action  from  the  Netherlands; 
Thematic case study interview with the beneficiary of the Union Action from Italy and one on the EU level. 
Thematic case study interview with the beneficiaries of the Emergency Action from Spain and one on the 
EU level. 
216 Country case study interview with the Managing Authority from Spain. 
217 Additional interview with the Managing Authority from Latvia. 
218 Additional interview with the Managing Authority from France. 
219 Additional interview with the Managing Authority from France. 
220 Country case study interview with the beneficiary of the National Programme from Croatia. 
221 Thematic case study interview with the beneficiary of the Union Action from Italy. 
222  Country  case  study  interviews  with  the  Managing  Authorities  from  Spain  (2x),  Latvia  and  Croatia; 
Country case study interview with one beneficiary of the National Programme from Croatia; Thematic case 
study interview with one beneficiary of the EMAS from Belgium; Thematic case study interview with one 
beneficiary  of  the  Union  Action  from  Italy;  Additional  interviews  with  the  Managing  Authorities  from 
Finland and France; Additional interview with the beneficiary of the National Programme from France. 
223  Country  case  study  interviews  with  the  Managing  Authorities  from  Spain  (2x),  Latvia  and  Croatia; 
Country case study interview with one beneficiary of the National Programme from Croatia; Thematic case 
study interview with one beneficiary of the EMAS from Belgium; Thematic case study interview with one 
beneficiary  of  the  Union  Action  from  Italy;  Additional  interviews  with  the  Managing  Authorities  from 
Finland and France; Additional interview with the beneficiary of the National Programme from France. 

124 

 
 
EU added value  

Overall,  consulted  stakeholders  widely  agreed  that  the  ISF-P  provided  significant  EU 
added  value,  especially  by  enhancing  cross-border  cooperation  and  improving  the 
exchange of information between the authorities of Member States.  

Three stakeholders (Managing Authorities)224 emphasised that the financial support of ISF-
P  allowed  for  the  successful  implementation  of  critical  projects  that  would  have  been 
difficult to carry out with only national level or other EU funds. They pointed out that the 
ISF-P resources enabled the implementation of projects vital to addressing national-level 
security challenges, including developing new practices, which otherwise would not have 
been possible. Nine stakeholders  agreed they  could  not  have implemented their actions 
without the ISF-P support.225  

For beneficiaries, the ISF-P played a crucial role in enabling cross-border cooperation and 
making possible initiatives that national budgets alone could not have supported. Several 
beneficiaries reported that while some projects might have been possible without the EU 
funding,  their  implementation  would  have  been  significantly  more  challenging  due  to 
financial constraints at the national level.226 In particular, projects like EU-SUITEx, which 
focused  on  international  cooperation  and  technical  tool  development,  were  realised 
primarily because the EU covered most of their costs.227 Several beneficiaries (8) indicated 
that they would not be able to implement projects without the support of ISF-P.228  

Some stakeholders acknowledged the ISF-P's value in fostering transnational cooperation 
and  enhancing  law  enforcement  capabilities.  Two  (two  Managing  Authorities)229 
highlighted the importance of experience exchange and improved information exchange 
between  Member  States.  Another  (a  Managing  Authority)  noted  that  ISF-P  enhanced 
internal  security  in  their  territory and the EU, with  interconnected security policy areas 
positively affecting multiple Member States.230 

Most  stakeholders  agreed  that  ISF-P  contributed  substantially  to  EU-level  security  and 
cooperation (37 respondents).231 

224 Country case study interviews with the Managing Authorities from Spain, Finland and Germany. 
225 Country case study interviews with the Managing Authorities from Spain, Germany (2), Croatia (2) and 
Latvia; Country case study interviews with beneficiaries of the National Programme from Croatia (2) and 
Latvia. 
226 Thematic case study interview with one beneficiary of the Union Actions from Germany. 
Thematic case study interviews with the beneficiaries of the EMAS from Spain, Belgium and one on the EU 
level. 
227 Thematic case study interview with one beneficiary of the EMAS from Belgium. 
228  Thematic  case  study  interviews  with  beneficiaries  of  the  Union  Actions  from  Germany  and  Italy; 
Thematic case study interviews with the beneficiaries of the EMAS from Spain, Belgium and one on the EU 
level. 
Additional interviews with the beneficiaries of the Union Action from Greece and France. 
229 Country case study interviews with the Managing Authorities from Spain and Croatia. 
230 Additional interview with the Managing Authority from Italy. 
231 Case study interviews with the Managing Authorities from Spain (2), Germany (2), Croatia and Latvia 
(2); Case study interviews with the beneficiaries of the National Programme from Croatia (2), Latvia (2), 
Spain  (2)  and  Germany;  Thematic  case  study  interviews  with  beneficiaries  of  the  Union  Actions  from 
Belgium, Estonia, Germany, Hungary, Netherlands, Malta, Italy (2), and one on the EU level; Thematic case 
study interviews with beneficiaries of the EMAS from Belgium, Finland and one on the EU level; Country 
case  study  interview  with  relevant  members  of  the  Monitoring  Committee  from  Croatia;  Additional 

125 

 
 
 
Sustainability  

According  to  consulted  stakeholders,  the  ISF-P  projects  have  demonstrated  significant 
long-term results, with many continuing to impact beyond completion.232  

Several collaborations and cooperation between stakeholders have extended beyond their 
initial funding period.233 Specialised equipment procured with the ISF-P, such as armoured 
vehicles  and  drones  for  law  enforcement,  has  been  in  use  for  years  to  support  law 
enforcement efforts and improve public security across Member States.234  

The  deliverables  of  training  projects,  such  as  manuals  and  the  know-how  acquired  by 
participants,  are  being  shared  across  Member  States,  used  during  participants'  lifelong 
careers,  and  have  lasting  effects.235  Tools,  such  as  the  firearms  monitor,  are  regularly 
updated to track firearm incidents,236 and interactive tools for civil society and journalists 
continue  to  be  maintained,  though  funding  challenges  persist.237  Equipment  acquired 
through ISF-P also continues to support law enforcement efforts to improve public security 
across Member States.238 

To  ensure  the  sustainability  of  projects,  applicants  were  to  provide  sustainability  plans 
before  the  projects’  approval,239  while  social  media  projects  within  the  National 
Programme reuse content across platforms to maintain relevance for training.240 

Additionally, longer durations for EU-level grants have helped organisations focus on their 
core  missions,  reducing  the  need  for  constant  reapplications  and  supporting  long-term 
impact.241 

Simplification and reduction of administrative burden 

Consulted Managing Authorities generally found the monitoring and reporting (including 
dedicated communication systems) functional, with regular reports and digital platforms 
ensuring proper documentation.242 However, concerns were raised about the administrative 
burden  such  monitoring  and  reporting  mechanisms  would  impose  on  Managing 
Authorities and beneficiaries.  

interviews  with  beneficiaries  from  the  Union  Actions  from  the  Netherlands  (2)  and  Greece;  Additional 
interviews with the Managing Authorities from Bulgaria, Cyprus, Italy, Latvia, Czechia, France and Finland. 
232 Country case study interviews with the Managing Authorities from Germany, Croatia and Spain; Country 
case  study  interviews  with  the  beneficiaries  of  the  National  Programme  from  Spain,  Croatia  and  Latvia; 
Thematic case study interviews with the beneficiaries of the Union Action from Italy and Belgium; Thematic 
case  study  interviews  with  the  beneficiaries  of  the  Emergency  Assistance  from  Belgium  (2);  Additional 
interviews with the Managing Authorities from Bulgaria, Cyprus, Italy, Latvia, Finland, France and Czechia; 
Additional  interviews  with  the  beneficiaries  of  the  Union  Actions  from  the  Netherlands  and  Greece; 
Additional interview with the beneficiary of the EMAS from France. 
233 Country case study interview with the Managing Authority from Germany 
234  Country  case  study  interview  with  Managing  Authority  from  Croatia;  Additional  interview  with  the 
Managing Authority from Italy. 
235 Country case study interview with the Managing Authority from Spain. 
236 Thematic case study interview with the beneficiary of the Union Action from Belgium. 
237 Additional interview with the beneficiary of the National Programme from Latvia. 
238 Additional interview with the Managing Authority from Italy. 
239 Country case study interview with the Managing Authority from Croatia. 
240 Country case study interview with the beneficiary of the National Programme from Germany. 
241 Thematic case study interview with the beneficiary on the EU level. 
242 Country case study interview with the Managing Authority from Croatia. 

126 

 
 
Challenges were reported concerning the definition and quality of the indicators, which 
were  not  always  easily  applicable  to  specific  projects  and  required  adaptation.243  Some 
authorities found the need for continuous amendments burdensome, as they had to revise 
projects’ descriptions and interventions based on external decisions rather than their own 
planning.244 Others highlighted the necessity of maintaining traceable communication at 
every step due to audit requirements, though this slowed processes significantly.245 While 
a dedicated desk officer from the Commission helped streamline procedures, monitoring 
and reporting obligations remained demanding, especially considering the limited capacity 
of national authorities.246 

Several  stakeholders  criticised especially  the complexity of shared management, noting 
excessive  justification  requirements  for  even  minor  project  adjustments247  and  frequent 
regulatory  changes  that  created  inefficiencies.248  Others  pointed  out  that  the  heavy 
administrative workload discouraged applicants, particularly national authorities, who had 
limited capacity for operational tasks (such as police forces).249 Some welcomed certain 
measures adopted during the implementation of the Fund, such as the deadline extensions 
for projects250 but overall, simplification efforts were seen as insufficient.251 

Most  consulted  Managing  Authorities  agreed  that  the  management  procedures  had  not 
been significantly simplified (5).252 While some flexibility was noted in adapting indicators 
to projects’ goals,253 and SCO, 254 the overall administrative burden remained high.  

Beneficiaries  under  the  National  Programmes  found  administrative  monitoring  and 
reporting requirements highly demanding, particularly due to the extensive documentation 
required to use allocations, including proof of fund allocation and distribution.255 Police 
officers  implementing  operational  support  projects  faced  significant  administrative 
burdens, as expenses, such as daily fees and fuel costs, had to be meticulously documented, 
leading to excessive paperwork, which is not usually required for national funding.256 A 
stakeholder  acknowledged  that  reporting  is  inherently  burdensome;  they  considered  it 
necessary to justify large funding amounts and ensure transparency.257 Another stakeholder 
pointed out that audits were particularly difficult, requiring a large volume of additional 
documentation to be submitted within short timeframes.258 

The  impact  of  innovative  procedures  on  simplification  for  beneficiaries  of  National 
Programmes  was  mixed.  While  multiannual  programming  was  seen  as  beneficial  in 

243 Country case study interview with the Managing Authority from Germany. 
244 Country case study interview with the Managing Authority from Cyprus. 
245 Country case study interview with the Managing Authority from Croatia. 
246 Country case study interview with the Managing Authority from Latvia and France. 
247 Case study interview with the Managing Authority from the Netherlands. 
248 Case study interview with the Managing Authority from Cyprus. 
249 Case study interview with the Managing Authority from France. 
250 Case study interview with the Managing Authority from Italy. 
251 Case study interview with the Managing Authority from Finland. 
252 Country case study interviews with the Managing Authorities from Croatia, Finland, Netherlands, Cyprus 
and Italy. 
253 Case study interview with the Managing Authority from Germany. 
254 Case study interview with the Managing Authority from Croatia. 
255 Country case study interview with the beneficiary of the National Programme from Croatia. 
256 Country case study interview with the beneficiary of the National Programme from Croatia. 
257 Country case study interview with the beneficiary of the National Programme from Germany. 
258 Country case study interview with the beneficiary of the National Programme from Spain. 

127 

 
 
reducing administrative burden by some,259 others found it challenging to predict needs 
over a seven-year period, especially in a rapidly changing security environment.260 Strict 
procurement laws further complicated implementation by prolonging tender processes.261 
Shared  management  was  perceived  as  more  administratively  complex  than  direct 
management, which, despite requiring multi-Member State participation, was considered 
more  straightforward  to  implement.262  Overall,  few  beneficiaries  of  the  National 
Programme stated that there was no simplification.263  

Beneficiaries  of  Union  Actions  and  EMAS  generally  reported  fewer  administrative 
difficulties.  Overall,  a  little  over  half  of  the  respondents  agreed  that  the  administrative 
burden was manageable (11 out of 18).264 Some described the process as straightforward, 
although  complex.265  Beneficiaries  with  experience  on  EU-funded  projects  did  not 
consider the administrative workload unreasonable.266.  

Summary of the First Focus Group 

The results of the First Focus Group were reported in the Synopsis Report for the study 
supporting the ex-post evaluation of the ISF-P.   

Summary of the Third Focus Group (ISF-P) 

The  third  Focus  Group  took  place  on  3  April  2025  (online  format).  It  aimed  to  collect 
feedback from relevant stakeholders and validate the findings of the study, ensuring that 
the conclusions presented in the Draft Final Report for the ex-post evaluation of the ISF-P 
are accurate and comprehensive and reflect the perspectives of all key stakeholders. A total 
of  60  participants  (including  eight  members  of  the  study  team)  took  part  in  the  Focus 
Group. Participants reflected the various stakeholder groups. The study team presented the 
key findings of the Draft Final Report and reported the results per evaluation criterion.   

Stakeholders  provided  a  range  of  insights  regarding  the  effectiveness  of  the  ISF-P, 
highlighting  both  enduring  and  emerging  challenges.  A  National  Programme 
representative noted that the ISF-P differs from previous funds, such as the ISEC and CIPS, 
due to its shared management structure, and clarified that reductions in law enforcement 
training  were  largely  driven  by  the  COVID-19  pandemic.  Persistent  issues  around 
procurement  and staffing, particularly  affecting final  beneficiaries, were  emphasised by 
both National Programme beneficiaries and Responsible Authorities, with the restrictions 
around  the  security  component  adding  complexity.  Challenges  related  to  the  use  and 
interpretation of indicators were also raised, including the rigidity and level of required 
details of the evaluation template and insufficient training on the use of indicators, which 
hinder  effective  progress  tracking.  One  Responsible  Authority  reported  that  delayed 

259 Case study interview with the beneficiary of the National Programme from Spain. 
260 Case study interview with the beneficiary of the National Programme from Croatia. 
261 Case study interview with the beneficiary of the National Programme from Croatia. 
262 Case study interview with the beneficiary of the National Programme from France. 
263 Country case study interviews with the beneficiaries of the National Programme from Spain and Croatia. 
Additional interview with one beneficiary of the National Programme from France. 
264  Country  case  study  interviews  with  the  Managing  Authorities  from  Croatia,  Latvia,  Spain  and  Italy; 
Thematic  case  study  interview  with  the  beneficiary  of  the  EMAS  on  the  EU  level;  Country  case  study 
interviews with the beneficiaries of the National Programme from Latvia (3); Additional interviews with the 
beneficiaries of the Union Action from the Netherlands (2) and Greece. 
265 Thematic case study interview with the beneficiary of the EMAS on the EU level; Additional interviews 
with one beneficiary of the Union Action from the Netherlands. 
266 Additional interviews with one beneficiary of the Union Action from Greece. 

128 

 
 
project  closures  should  not  be  viewed  negatively.  The  ISF-P  started  in  2014,  however, 
most of the projects started in 2016 or 2017, inevitably delaying their closure. Additionally, 
stakeholders  expressed  strong  support  for  the  Commission-level  initiatives  calls,  under 
Union  Actions,  as  they  allow  for  addressing  emerging  needs  that  are  not  necessarily 
captured in national programmes at the time of their adoption, such as the Russian war of 
aggression against Ukraine and the pandemic.  

Stakeholders highlighted a variety of challenges and observations related to the efficiency 
of the ISF-P. A Responsible Authority agreed with the findings of the efficiency analysis 
but pointed to difficulties with procurement in the security field, where national security 
concerns  complicate  standard  procedures.  They  noted  divergences  in  interpretation 
between  Member  States  and  the  Commission  on  appropriate  procurement  methods, 
emphasising the need for clearer procedural differentiation. Issues with digitalisation of 
procedures  were  also  raised  by  a  Union  Action  beneficiary,  who  considered  the 
Commission  Funding  Portal  to  be  unintuitive  and  difficult  to  navigate,  citing  problems 
with  communication,  reporting,  amendments,  and  procedural  complexity.  The 
administrative burden of Union Actions is seen differently from the burdens that are under 
shared management, given that they are managed directly by the Commission without the 
involvement  of  the  Responsible  Authority.  A  Union  Action  beneficiary  found  ISF-P-
funded actions more efficient due to their shorter duration, simpler implementation under 
the Commission management, and absence of intermediary administrative layers. Some 
concerns included delays and shifting strategies that influenced project costs, and the need 
to  consider  the  link  between  procurement  and  gold-plating.  One  Responsible  Authority 
warned against attributing efficiency to understaffing, as it could compromise the long-
term sustainability of programmes. 

Participants  generally  supported  the  findings  related  to  simplification  and  reducing 
administrative  burdens  under  the  ISF-P,  though  challenges  remain.  One  Responsible 
Authority stressed the simpler management of national funding compared to EU funding.  
Another Responsible Authority reported that SCOs had only been applied to indirect costs, 
citing  difficulties  in  defining  direct  costs  in  advance.  They  recommended  greater 
transparency  and  information-sharing  among  Member  States,  specifically  proposing  a 
shared  list  of  already  adopted  SCOs  to  enhance  efficiency  and  guide  national-level 
implementation based on existing best practices. 

Regarding relevance, both a Responsible Authority and a National Programme beneficiary 
confirmed that ISF-P funding was highly beneficial in supporting the achievement of key 
objectives, especially in areas such as cybercrime and ICT systems. While the findings on 
relevance were generally supported, another Responsible Authority noted the difficulty in 
assessing this aspect in depth, given that the original programming period began over ten 
years ago, making it challenging for stakeholders to recall specific details from that time. 

Participants generally agreed with the findings on coherence. One Responsible Authority 
explained that coherence in their Member State is facilitated by centralising all EU funding 
under  a  single  ministry  and  assigning  both  AMIF  and  ISF  to  the  same  Responsible 
Authority, with  regular  updates to  Monitoring  Committees helping to  prevent  overlaps. 
However,  another  Responsible  Authority  highlighted  that  this  setup  is  not  universal;  in 
their country, the Responsible Authority operates under the Police Authority rather than a 
ministry,  which  creates  coherence  challenges.  To  address  these,  they  maintain  close 
collaboration  with  the  Department  of  Justice  and  ensure  ongoing  engagement  with  the 
Monitoring Committee. 

129 

 
Participants  agreed  with  the  overall  findings  on  complementarity.  One  Responsible 
Authority highlighted the crucial role of Monitoring Committees in  ensuring alignment 
and  avoiding  overlap  between  funding  sources.  Another  Responsible  Authority  pointed 
out that the actions selected for their national programme were intentionally designed to 
prevent double funding from other EU instruments, thereby reinforcing complementarity 
across instruments. 

On  EU  added  value,  participants  overall  agreed  with  the  overall  findings.  One  Union 
Action  emphasised  the  importance  of  Union  Actions,  highlighting  the  potential  for 
exchanging best practices and bringing together stakeholders from different EU Member 
States to develop tools and guidelines.  

Participants  generally  agreed  with  the  findings  related  to  sustainability.  They  shared 
several  perspectives  on  sustainability,  particularly  in  relation  to  the  implementation  of 
National Programmes. One Responsible Authority highlighted key measures to maintain 
positive outcomes over time, including enhanced cooperation with EU agencies such as 
Eurojust, Europol, CEPOL, and Frontex, as well as ongoing training for service personnel 
involved in delivery. Another Responsible Authority pointed to the potential of leveraging 
Horizon funding to develop innovations that could later be implemented under ISF-P to 
support long-term sustainability.  

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