COMMISSION STAFF WORKING DOCUMENT EVALUATION European Maritime, Fisheries and Aquaculture Fund mid-term evaluation
Date: 2026-03-04
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: aquaculture, common fisheries policy, conservation of resources, fishery resources, fund (EU), maritime economy, project evaluation, resources of the sea, sea fishing, sustainable fisheries

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.3.2026  SWD(2026) 87 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  European Maritime, Fisheries and Aquaculture Fund mid-term evaluation {SWD(2026) 88 final}  
 
 
Contents 

1. 

INTRODUCTION 

1 

1.1. 

1.2. 

The European Maritime, Fisheries and Aquaculture Fund .............................................. 1 

Purpose and scope of the evaluation ............................................................................... 2 

1.3.  Methodological framework and data limitations ............................................................. 3 
5 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. 

2.2. 

Description of the intervention and its objectives ........................................................... 5 

Points of comparison ......................................................................................................11 
15 

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

4. 

3.1. 

EVALUATION FINDINGS 

State of play of the EMFAF shared management implementation .................................15 
27 
Effectiveness ..............................................................................................................27 

4.1 

4.2     Efficiency ......................................................................................................................33 

  4.3  Overall cost-effectiveness of the Fund…………………………………………………..37 

4.4 

Coherence ..................................................................................................................38 

4.5. 

How did the EU intervention make a difference and to whom? .....................................42 
EU added value .......................................................................................................................42 

4.6. 

Is the intervention still relevant? ....................................................................................48 
51 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

Conclusions ....................................................................................................................51 

5.1. 

5.2. 

Lessons learnt .................................................................................................................55 
58 
60 

6.  ANNEX I. PROCEDURAL INFORMATION 
7.  ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 
8.  ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO 

THE EVALUATION QUESTIONS (BY CRITERION) 

9.  ANNEX IV. OVERVIEW OF BENEFITS AND COSTS AND TABLE ON SIMPLIFICATION AND 

BURDEN REDUCTION 

10.  ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT 
11.  ANNEX VI. INFOSYS DATABASE 
12.  ANNEX VII. EMFAM INTERVENTION LOGIC AND THE MEF 
13.  ANNEX VIII. RESPONSE TO THE REGULATORY SCRUTINY BOARD 

71 

89 
95 
113 
117 
122 

 
 
 
 
 
 
 
 
Glossary 

Term or acronym 
AC 

Advisory Council 

Meaning or definition 

AMIF 

BMVI 

CAP 

CFP 

CINEA 

CLLD 

CMO 

CPR 

CR 

Asylum and Migration Fund 

Border Management and Visa Instrument 

Common Agricultural Policy 

Common Fisheries Policy 

Climate, Infrastructure, and Environment Executive Agency  

Community Led Local Development 

Common Market Organisation 

Common Provisions Regulation 

Common Result Indicator 

EAFRD 

European Agricultural Fund for Rural Development 

EIB 

EFF 

EMFAF 

EMFF 

European Investment Bank 

European Fisheries Fund 

European Maritime, Fisheries and Aquaculture Fund 

European Maritime and Fisheries Fund 

EMODNET  

European Marine Observation and Data Network  

ERDF 

ESF+ 

ESIF 

EU 

EUMOFA 

FAMENET 

European Regional Development Fund 

European Social Fund Plus 

European Structural and Investment Funds 

European Union 

European  Union  Market  Observatory 
Aquaculture products 

for  Fisheries  and 

Fisheries  and  Aquaculture  Monitoring,  Evaluation  and  Local 
Support Network 

FLAGs  

Fisheries Local Action Groups 

FIs 

Financial Instruments 

 
 
GES 

HEC 

ISF 

Good Environmental Status 

Horizontal Enabling Condition 

Internal Security Fund 

IUU Fishing 

Illegal, Unreported and Unregulated Fishing 

MAPs 

Multiannual Plans 

MAs 

MEF 

MFF 

Managing Authorities 

Monitoring and Evaluation Framework 

Multiannual Financial Framework 

MNSPAs 

Multiannual National Strategic Plans for Aquaculture 

MSFD 

OR 

Marine Strategy Framework Directive 

EU Outermost Regions 

RFMOs 

Regional Fisheries Management Organisation 

SCOs 

SDG 

SFPAs 

SME 

SO 

SSCF 

SWD 

Simplified Cost Options 

Sustainable Development Goals 

Sustainable Fisheries Partnership Agreements 

Small and Medium Enterprises 

Specific Objectives 

Small Scale Coastal Fisheries 

Staff Working Document 

SWOT  

Strengths, Weaknesses, Opportunities, and Threats 

TFEU 

UN 

Treaty on the Functioning of the European Union 

United Nations 

 
 
 
 
 
 
1. 

INTRODUCTION 

1.1.  THE EUROPEAN MARITIME, FISHERIES AND AQUACULTURE FUND 

The  European  Maritime  Fisheries  and  Aquaculture  Fund  (EMFAF)  established  under 
Regulation (EU) 2021/11391 (hereinafter referred to as the EMFAF Regulation) channels 
funding  from  the  Union  budget  to  support  the  Common  Fisheries  Policy  (CFP)2,  the 
Union’s maritime policy and the Union’s international commitments in the field of ocean 
governance. Such funding is a key enabler for sustainable fisheries  and aquaculture and 
the conservation of marine biological resources, for food security through the supply of 
aquatic food products, for the growth of a sustainable blue economy and for healthy, safe, 
secure, clean and sustainably managed seas and oceans. 

The  EMFAF  applies  from  2021  to  20273,  aligned  with  the  duration  of  the  multiannual 
financial framework (the ‘MFF 2021-2027’4) and supports EU and Member States action 
through shared management (87% of the budget) and direct and indirect management (13% 
of the budget):  

•  shared  management  –  €5.311  billion  allocated  to  the  Member  States5  and 
managed through national programmes cofinanced by the EU budget and Member 
States, for which the Common Provisions Regulation (CPR6) is applicable.  
The funding under shared management mostly supports the implementation of the 
CFP and is made conditional upon strict compliance with the CFP rules, restricted 
to  avoid  disbursement  of  harmful  subsidies7  and  subject  to  compliance  with  the 
horizontal enabling conditions (HECs)8 set out in the CPR.  
(in)direct management – €797 million managed directly by Commission. About 
half  of  this  is  dedicated  to  the  implementation  of  the  CFP  providing  support  to 
scientific advice, fisheries control, monitoring, and data collection (activities which 
are  also  covered  under  shared  management)  and  dissemination  and  provision  of 
market information. The maritime policy component covers the blue economy and 
international ocean governance. It includes support for reliable marine data, cross-
border  spatial  planning,  ocean  literacy,  skills,  sea-basin  cooperation,  maritime 

• 

1   Regulation (EU) 2021/1139 of the European Parliament and of the Council of 7 July 2021 establishing 
the European Maritime, Fisheries and Aquaculture Fund and amending Regulation (EU) 2017/1004. 
2   Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on 
the  Common  Fisheries  Policy,  amending  Council  Regulations  (EC)  No  1954/2003  and  (EC)  No 
1224/2009 and repealing Council Regulations (EC) No 2371/2002 and (EC) No 639/2004 and Council 
Decision 2004/585/EC. 

3   Article  63  of  Regulation  (EU)  2021/1060  defines  eligibility  period  for  shared  management  until 

31/12/2029 (N+2 rule). 

4   Regulation (EU, Euratom) 2020/2093 laying down the  multiannual financial framework for the years 

2021 to 2027. 

5   The budget is allocated in accordance with Annex V of the EMFAF Regulation.  
6   Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021 laying down 
common provisions on the European Regional Development Fund, the European Social Fund Plus, the 
Cohesion Fund, the Just Transition Fund and the European Maritime, Fisheries and Aquaculture Fund 
and financial rules for those and for the Asylum, Migration and Integration Fund, the Internal Security 
Fund and the Instrument for Financial Support for Border Management and Visa Policy. 
7  https://environment.ec.europa.eu/economy-and-finance/phasing-out-environmentally-harmful-

subsidies_en 

8   https://ec.europa.eu/regional_policy/policy/what/glossary/enabling-conditions_en 

1 

 
 
 
surveillance and innovation in SMEs. The rest is dedicated to meeting the aims of 
the EU’s maritime policy. 

1.2.  PURPOSE AND SCOPE OF THE EVALUATION 

Article  45(1)  of  the  CPR  stipulates  that  the  “Commission  shall  carry  out  a  mid-term 
evaluation to examine the effectiveness, efficiency, relevance, coherence and Union added 
value of each Fund by the end of 2024.” 

This evaluation covers the period from the start of the programming period until the first 
quarter  of  20249  and  covers  the  totality  of  EMFAF  direct  management  and  shared 
management including the 26 national EMFAF programmes10. It aims to provide a mid-
term  evaluation  of  how  EMFAF  is  delivering on  its  objectives,  taking  stock  of  the 
progress  halfway  through  its  seven-year  cycle  and  indicates  a  way  forward  to 
evaluate its impact in the future. It aims to inform the work on the design of the future 
EU  instrument  investing  in  fisheries,  aquaculture  and  maritime  policies  as  well  as  to 
identify  lessons  learnt  which  can  be  still  used  to  improve  the  implementation  of  the 
EMFAF 2021-2027 programming period.  

Given the timing of this evaluation, it does not deliver a fully-fledged impact evaluation, 
rather  it  reports  on  the  progress  made  to  date.  In  particular,  the  start  of  the  shared 
management component of the EMFAF programming has been marked by delays due to 
the  late  adoption  of  the  EMFAF  Regulation,  the  general  crisis  context  of  COVID-19, 
Brexit, the Russian military aggression against Ukraine, and the challenges for Member 
States in managing both the closure of the European Maritime and Fisheries Fund (EMFF), 
the  processor  of  the  EMFAF,  and  the  initiation  of  the  EMFAF,  among  others.  Most 
Managing Authorities cited the difficulty to manage both the closing the EMFF and start 
of  the  EMFAF  at  the  same  time  without  additional  support.  Additionally,  structural 
changes within organisations contributed to capacity constraints. The deterioration of the 
economic situation in relation to Russia’s military aggression  against Ukraine is reflected 
in the ability of beneficiaries to complete the implementation of their projects. Moreover, 
challenges  related  to  Brexit,  reduced  economic  activity,  and  conditions  stemming  from 
new  or  ongoing  environmental  regulations  further  hindered  the  effective  start  of  the 
implementation.  

Given that the evaluation comes too early to capture the EMFAF results and impacts, they 
will  be  assessed  in  the  retrospective  evaluation  due  in  2031.  On  the  other  hand,  the 
impacts  of  the  CFP  and  maritime  policy  are  subject  to  regular  stock-tacking  and 
reporting11 and a full evaluation of the CFP Regulation has been launched in 2024 
which  provides  concrete  elements  to  demonstrate  progress 
in  the  policy 
implementation  and  the  concrete  policy  objectives  to  which  the  EMFAF  is 
contributing.  

Therefore,  this  mid-term  evaluation  focuses  mostly  on  the  progress  in  the  EMFAF 
implementation at the end of 2023, and on the criteria of coherence and relevance. Under 

9   Where possible, in the context of the SWD the latest data of the third quarter of 2024 are provided. 
10   Representing all EU Member States except Luxembourg, which has no national EMFAF programme. 
11   AER Annual Communication, The 2024 annual economic report on the EU fishing fleet (STECF 24-07) 
Report  from  the  Commission  to  the  European  Parliament  and  the  Council  Implementation  of  the 
Technical Measures Regulation (Article 31 of Regulation (EU) 2019/1241) The EU blue economy report 
2024 

2 

 
 
the  criteria  of  effectiveness  and  efficiency,  given  the  above-mentioned  constraints,  it 
assesses  the  effects  of  changes  introduced  in  the  2021-2027  programming  period  to 
improve the fund’s implementation and performance. A particular emphasis is put on the 
effects  of  the  simplification  in  the  legislative  framework  on  the  programming  and 
implementation.  

1.3.  METHODOLOGICAL FRAMEWORK AND DATA LIMITATIONS 

This Staff Working Document draws on evidence from the supporting study carried out 
by the consortium formed by Tetra tech12. As regards the methodology used to process the 
data, the analysis relied on desk research, data analysis, extensive stakeholder consultation 
activities  and  case  studies.  The  study  team13  conducted  a  quantitative  and  qualitative 
analysis  of  data  gathered  through  the  different  consultation  activities.  The  quantitative 
analysis  included  a  descriptive  statistical  analysis  of  the  results  of  the  surveys  of  the 
EMFAF  target  group14  and  of  the  managing  authorities  in  the  Member  States. 
Methodological information on how the evaluation was conducted is detailed in Annex II, 
including a section on limitations and robustness of findings. 

This work has been complemented by extensive stakeholder consultation (see also Annex 
V): 

•  A survey of the managing authorities (26 responses), 
•  A survey of the EMFAF target groups (223 responses), 
•  14  interviews  with  26  key  stakeholders  at  the  European  level,  including 
representatives  from  DG  MARE,  the  Directorate-General  for  Environment  (DG 
ENV),  and  the  Fisheries  and  Aquaculture  Monitoring,  Evaluation  and  Local 
Support  Network  (FAMENET),  as  well  as  interest  groups  (social  partners)  and 
fisheries and aquaculture experts, 

•  Nine complementary interviews with national stakeholders, including intermediary 
bodies  and  (potential)  beneficiaries,  in  six  selected  Member  States  (Czechia, 
Denmark,  France,  Germany,  Latvia,  and  Spain)    on  specific  topics,  such  as 
innovation,  synergies,  etc.,  as  well  as  written  feedback  from  the  Estonian 
stakeholder consulted. 

Additional sources of the evaluation were several reports prepared by the Fisheries and 
Aquaculture  Monitoring,  Evaluation  and  Local  Support  Network  (FAMENET)15 
which supports the Commission and stakeholders in the implementation of the EMFF and 
EMFAF and in the set-up and implementation of the EMFAF’s monitoring and evaluation 
framework.  

12   The study will be published together with this Staff Working Document. 
13   Specific contract (3) implementing framework contract No: CINEA/2021/OP/0011 [Inter-Institutional 
multiple  framework  contract  for  supporting  better  regulation-related  activities,  with  reopening  of 
competition (LOT 1)] led by Tetra Tech International Development Sp. z o.o. The study team was tasked 
to provide support with a study according to the Terms of Reference (tender specifications). 

14   Key stakeholders at the European level, the social partners, advisory councils, EU-level interest groups 
from  fisheries  and  aquaculture  representative  organisations,  non-governmental  organisations  (NGOs), 
intermediary bodies, potential direct and indirect beneficiaries, namely EU, national, regional and local 
target groups, including fishers, fish farmers, processors and their representative organisations, relevant 
public bodies, research centres, etc. 

15   https://oceans-and-fisheries.ec.europa.eu/funding/famenet_en 

3 

 
 
For the analysis made, the Commission and FAMENET provided data based on the Infosys 
database16 covering all operations, both under shared and (in)direct management. Infosys 
is a unique, powerful and valuable database with constantly quality-checked and readily 
available data that can be used for information and evaluation purposes17 (see Annex VI). 
Moreover,  as 
the 
implementation of fisheries and maritime policies provide information illustrating concrete 
elements that demonstrate progress in delivery on the concrete policy objectives to which 
the EMFAF is contributing. 

the  Commission  and  scientific  reports  on 

indicated  above, 

Still,  this  stage,  information  is  mostly  available  on  outputs  rather  than  on  results  and 
impacts which will be assessed in full at the time of the ex-post evaluation. Particularly for 
investments, the results and impacts that have been achieved at the mid-term point cover 
initial  steps, such as a launch of calls for tenders, proposals  and projects, or signing of 
procurement contracts; whilst the final milestones and targets due in the second half of the 
Fund’s lifetime will increasingly cover final investment outputs.  

Overall,  the  evaluation  process  went  as  planned,  and  the  data  gathered  is  considered 
reliable. No significant difficulties were encountered in reaching key stakeholders involved 
in  the  design  and  implementation  of  EMFAF.  Therefore,  even  with  the  limitations 
linked  to  the  early  state  in  EMFAF’s  implementation,  the  conclusions  and  lessons 
learnt  can  be  considered  reliable  for  a  mid-term  evaluation,  especially  since  the 
Infosys tool which provides very detailed reporting has been used.  

The results of the evaluation help identify potential weaknesses in the design of the current 
Fund in view of taking necessary steps to improve implementation or correct identified 
problems, as well as providing perspectives for the design of future financial support to 
ensure  efficient  achievements  of  policy  objectives.  In  this  context,  the  timing  of  the 
evaluation is important to provide evidence to inform the design of support under the 
next EU Multi-annual Financial Framework period to start in 2028.  

16   Commission  Implementing  Regulation  (EU)  2022/79  of  19  January  2022  laying  down  rules  for  the 
application of Regulation (EU) 2021/1139 of the European Parliament and of the Council as regards the 
recording, transmission and presentation of operation-level implementation data. 

4 

 
 
 
 
 
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.  DESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES 

The Common Provisions Regulation (CPR)2 and the EMFAF Regulation for 2021-2027 
entered  into  force  in  July  2021.  The  EMFAF  is  a  funding  instrument  with  a  budget 
exceeding  EUR  6  billion  for  2021–2027.  Its  central  mission  is  to  advance  sustainable 
fisheries and aquaculture, support  healthy and resilient marine ecosystems,  and foster a 
robust and innovative blue economy. It is implemented through direct management and a 
shared management approach, empowering Member States to tailor national and regional 
programmes under a harmonized EU framework. 

EMFAF INTERVENTION LOGIC 

In view of the direct link to established and vastly regulated policies, the general objectives 
of the EMFAF were formulated with the aim to address the main challenges in the policy 
areas it supports (for graphical depiction of the Intervention Logic see Annex VII). The 
general priorities are translated into 10 specific objectives covering the policy areas (see 
table below. 

Table  1:  EMFAF  Priorities  and  Specific  Objectives  under  shared  management  (Annex  II  EMFAF 
Regulation) 

Priorities (P) 

Specific objectives  (SO) 

the 

P1: Fostering sustainable fisheries 
and 
and 
conservation of aquatic biological 
resources 

restoration 

Fostering 

activities, 

sustainable 
P2: 
aquaculture 
and 
processing  and  marketing  of 
fishery  and  aquaculture  products, 
thus  contributing  to  food  security 
in the Union 

P3:  Enabling  a  sustainable  blue 
economy  in  coastal,  island  and 
inland  areas,  and  fostering  the 
development  of 
and 
aquaculture communities 

fishing 

SO 1.1: Strengthening economically, socially, and environmentally 
sustainable fishing activities.  

SO 1.2: Increasing energy efficiency and reducing CO2 emissions 
through modernising or replacing fishing vessel engines.  

SO  1.3:  Adjusting  fishing  capacity  in  cases  of  permanent  or 
temporary cessation of activities.  

SO  1.4:  Fostering  efficient  fisheries  control,  enforcement,  and 
fighting IUU (Illegal, Unreported, and Unregulated) fishing, as well 
as reliable data for knowledge-based decision-making.  

SO 1.5: Promoting a level-playing field for fishery and aquaculture 
products from the outermost regions.  

SO  1.6:  Contributing  to  the  protection  and  restoration  of  aquatic 
biodiversity and ecosystems. 

SO  2.1:  Promoting  sustainable  aquaculture  activities,  especially 
strengthening the competitiveness of aquaculture production, while 
ensuring  that  the  activities  are  environmentally  sustainable  in  the 
long-term.  

SO 2.2: Promoting marketing, quality and added value of fishery and 
aquaculture products, as well as processing of those products. 

SO 3.1: Enabling a sustainable blue economy in coastal, island and 
inland  areas,  and  fostering  the  sustainable  development  of  fishing 
and aquaculture communities.  

5 

 
Priorities (P) 

Specific objectives  (SO) 

P4:  Strengthening 
international 
ocean  governance  and  enabling 
seas and oceans to be safe, secure, 
clean and sustainably managed  

Source: EMFAF regulation 

SO  4.1:  Strengthening  sustainable  sea  and  ocean  management 
through the promotion of marine knowledge, maritime surveillance 
or coast guard cooperation.  

EMFAF  Specific  Objectives  (SO)  at  regulation  level  are  necessarily  broad  to  cover  all 
aspects relevant to the fund and the Member States. They become specific through their 
operationalisation  in  the  Member  States  programmes.  For  each  specific  objective  the 
programmes define in the programme documents the following elements to make the SO 
specific and measurable (SMART): 

type of actions  (defined by the MS) 
type of intervention (selected) and related funding (set) and 

• 
• 
•  output indicator targets (set)  
•  common result indicators (selected and baselines and targets (set). 

Each MS programme intervention logic considers the following principles: 

•  EMFAF is structured along the priorities defined in the EMFAF regulation; MS can 

chose all or some of them 

•  each priority is broken down in specific objectives (see Annex section 3.1) 
• 

for each specific objective: 

o 
types of actions are defined 
o  main target groups are defined 
o 
o 
o  common result indicator are selected, and baseline and target values are set 

types of interventions are selected 
target values and milestones for output indicators are set 

Figure 1: Intervention logic EMFAF 2021-2027 

Source: DG MARE 

6 

 
Member  States  developed  their  national  EMFAF  Programmes  tailored  to  their  needs, 
choosing  from  the  Priorities  and  Specific  Objectives  (SOs)  set  out  in  the  EMFAF 
Regulation.  The  Programmes  were  based  on  SWOT18  analyses  and  needs  assessments 
conducted  by  each  MS.  For  each  Specific  Objective,  MS  Programmes  defined 
interventions, addressing some or all 4 Priorities and 10 Specific Objectives. 

During  the  implementation,  the  elements  above  become  more  specific  through  the 
provision of information at the level of the single operation (including type of beneficiary, 
type of operation etc.). This is the Monitoring and Evaluation Framework (MEF) (EMFAF 
regulation Article 46 and Commission Implementing Regulation 2022/79).  

The MEF has three different levels, one pursuant to Article 46 of the EMFAF and two 
pursuant to Article 42 of the CPR. 

1.  the operations’ level, that is Infosys in the narrow sense, pursuant to EMFAF Article 46 
is like the 2014-2020 Infosys (reporting twice a year, 31 January and 31 July every year) 
2.  the aggregated values of output indicators (Table 5 of Annex VII of CPR) and result 
indicators (Table 9 of Annex VII of CPR) based on Infosys (same reporting timing as 
Infosys, i.e. 31 January and 31 July every year) 

3.  the  aggregated  financial  data,  i.e.  the  number  of  all  selected  operations,  their  total 
eligible  cost,  the  contribution  from  the  EMFAF  and  the  total  eligible  expenditure 
declared by the beneficiaries to the MA, all broken down by specific objective (Table 1 
of  Annex  VII  of  CPR)  and  by  type  of  intervention  (Table  4  of  Annex  VII  of  CPR) 
(reporting  five  times  per  year,  31  January,  30  April,  31  July,  30  September,  30 
November. 

Figure 2: Timeline of CPR Article 42 and EMFAF Article 46 reporting 

Source: FAMENET 2023 

EMFAF CONTRIBUTION TO THE CFP 

Fisheries and aquaculture are an integral part of EU food production. Sustainability is the 
core principle of the CFP, allowing it to easily integrate under the European Green Deal 
and  be  the  basis  to  contribute  to  the  biodiversity  and  climate  objectives  and  targets  for 
marine and coastal areas. The CFP and EMFAF are moreover instrumental in guiding the 
energy transition of the sector in the coming years, whilst recognising the critical role of 

18   Strengths, Weaknesses, Opportunities and Threats 

7 

 
 
 
oceans  and  their  ecosystems  in  providing  services  beyond  the  fisheries  sector  –  where 
carbon sink functions should be well recognised and enhanced. 

The exclusive competence for the conservation of marine resources under the CFP puts a 
responsibility  on  the  Union  in  terms  of  policy  making  and  financing.  This  requires 
continued support to build up the evidence base for fisheries conservation and management 
decisions, including through support of the collection by Member States of scientific data, 
the  provision  of  scientific  advice  and  knowledge,  and  to  contribute  to  the  control  and 
enforcement of the policy through the implementation by Member States of the Control 
Regulation19. With negative externalities and fluctuating environmental factors being the 
norm for the fisheries sector, it is moreover especially important that the proper financial 
means are in place to support adaptation and transition when needed, as well as to provide 
a more strategic planning in terms of innovation, while promoting the sustainability agenda 
for fisheries and aquaculture.  

Moreover, the EMFAF provides support to the EU’s coastal communities which are the 
most exposed and vulnerable to climate change and need support especially in terms of 
adaptation.  

For  the  EU  Outermost  Regions  (OR),  the  fund  is  a  key  instrument  to  compensate  the 
additional costs that operators in fisheries, aquaculture and processing incur as compared 
to  mainland  Europe,  for  which  the  EMFAF  provides  a  substantial  ringfenced  budget 
allocation.  

Under (in)direct management, the EMFAF provides funding to finance the international 
cooperation  on  Regional  Fisheries  Management  Organisations  (RFMOs),  creating  the 
appropriate levers and enabling outcomes as well as promoting high global standards and 
advancing the EU agenda on ocean governance.  

Direct management support is moreover provided for the set up and the functioning of the 
11  Advisory  Councils  (ACs)20  under  the  CFP,  to  finance  the  European  Union  Market 
Observatory  for  Fisheries  and  Aquaculture  products  (EUMOFA),  which  performs  data 
collection on markets, and produces reports, studies and market analysis as well as actions 
under the maritime policy.  

EMFAF UNDER THE BROAD EU POLICY OBJECTIVES 

The EMFAF is well placed to help reduce the carbon footprint of fisheries and aquaculture 
through  measures  such  as  innovation  in  CO2  -efficient  technology  and  improving  the 
energy efficiency of fishing vessels and of aquaculture production systems, although the 
net impact of the reduction of CO2 resulting from the implementation of these measures is 
still to be seen. The fund will also contribute to  the target of providing 7.5% of annual 
spending under the multiannual financial framework to biodiversity objectives in 2024 and 

19   Regulation  (EU)  2023/2842  of  the  European  Parliament  and  of  the  Council  of  22  November  2023 
amending  Council  Regulation  (EC)  No  1224/2009  and  amending  Council  Regulations  (EC)  No 
1967/2006  and  (EC)  No  1005/2008  and  Regulations  (EU)  2016/1139,  (EU)  2017/2403  and  (EU) 
2019/473 of the European Parliament and of the Council as regards fisheries control. 

20   Articles 43 and 44 of Regulation (EU) 1380/2013 and Commission Delegated Regulation (EU) 2015/242 
laying  down  detailed  rules  on  the  functioning  of  the  Advisory  Councils  under  the  common  fisheries 
policy. 

8 

 
 
10%  of  annual  spending  under  the  multiannual  financial  framework  to  biodiversity 
objectives in 2026 and 2027.  

These objectives should be met quite comfortably. Based on currently available data from 
the Member State programmes21, 55% of the amount allocated to the EMFAF is planned 
to contribute to the climate change objective (coverage by Member State ranges from 41% 
to 77%). For biodiversity objectives, the corresponding contribution is 28%, ranging from 
14% to 56% at Member State level.  

The contribution of the EMFAF to EU climate and environmental objectives is tracked 
through  the  application  of  environmental  and  climate  markers  and  reported  on  in  the 
Transmission of Data reports22 within the monitoring framework of the fund.  

EMFAF has introduced “Rio markers”23 for tracing expenditure at the level of the national 
programmes  by  applying  standard  contribution  percentages  to  the  so-called  types  of 
intervention,  established  in  the  EMFAF  Regulation.  Furthermore,  the  level  of  detail 
included in the bi-annual Infosys reports24 allow for the evaluation of biodiversity-relevant 
projects at a more detailed level.  

The link between the types of interventions and the biodiversity coefficients is pragmatic 
but seems rather loose at the moment. A future case study of types of operations effectively 
supporting biodiversity (i.e. linking types of action with the contribution to the biodiversity 
strategy) can help to orient more precise future tools. 

In  addition,  the  EMFAF  can  improve  the  CFP  contribution  to  biodiversity  objectives 
through, for instance:  

• 

•  Continuing  to  ensure  that  fishing  activities  under  the  CFP  are  managed  in 
accordance with the principle of maximum sustainable yield (MSY), which aims to 
achieve a balance between harvesting fish stocks at sustainable levels and promote 
stocks recovery. 
Improving the financing, monitoring and management of Marine Protected Areas 
(MPAs). MPAs are essential to support biodiversity conservation targets and the 
sustainability of fisheries operators in the long term. 
Increasing  the  investment  in  scientific  research,  monitoring,  and  data  collection 
efforts to improve understanding of fish stocks and marine ecosystem functioning 
and the impacts of fishing/human activities on ecosystems. 

• 

When  it  comes  to  direct  management,  40%  of  the  budget  is  committed  to  actions  that 
contributed  to  a  Good  Environmental  Status  (GES),  including  nature  restoration, 
conservation, protection of ecosystems, biodiversity, animal health and welfare. In general, 
these are not on-the ground nature restoration projects but enablers that provide better data, 
improving spatial plans, supporting investment. 

Alignment  between  the  EMFAF  and  the  Multiannual  National  Strategic  Plans  for 
Aquaculture (MNSPAs) is also enhanced. In 2021, the EU updated the 2013 strategic 
guidelines for the sustainable development of aquaculture and according to these revised 

21   Aggregated percentages established via Infosys. 
22   https://sfc.ec.europa.eu/en 
23   https://capacity4dev.europa.eu/groups/public-environment-climate/info/short-guide-use-rio-markers_en 
24   The 
https://oceans-and-

Implementation 
fisheries.ec.europa.eu/system/files/2023-12/2023-FAMENET-EMFAF-implementation-report_en.pdf 

EMFAF 

Report 

2023: 

latest 

the 

is 

9 

 
 
guidelines,  the  EU  Member  States  reviewed  their  MNSPAs  accordingly.  The  EMFAF 
offers  an  opportunity  for  Member  States  to  support  the  sustainable  development  of 
aquaculture through targeted investments. Member States have elaborated both MNSPAs 
and national EMFAF programmes simultaneously. The analysis of a sample of project calls 
included in the supporting study confirmed that Member States have used selective criteria 
that emphasise environmental and socio-economic priorities when choosing aquaculture 
projects. Under shared management, the selection criteria are established by the Member 
States  and  tailored  to  the  type  of  support;  in  some  decentralised  countries  (e.g.  Spain, 
Belgium) the selection criteria are established at regional level to better address regional 
specificities. The use of scoring systems allows to prioritise operations that most closely 
align with the MS national aquaculture plans. Member States also set minimum overall 
passing scores for the selection criteria to ensure that only applications of sufficient quality 
are supported. 

THE EMFAF OFFERS BETTER ALIGNMENT WITH POLICY OBJECTIVES  

In  addition  to  the  changes  in  the  EMFAF  highlighted  above,  the  impact  assessment25 
highlighted some of the most important new concrete features of the EMFAF under its four 
priorities, as compared to  the previous programming  period, which have been taken up 
under the current legal framework: 

•  Aid intensity for small scale fisheries is increased from 80 to 100%. 
•  There is a stronger link to national strategic plans for aquaculture. 
•  Aid intensity for operations in relation to the landing obligation now ranging from 
75%  (infrastructure  and  marketing  for  unwanted  catches)  to  100%  (gear 
selectivity). 

•  Community-led local development (CLLD) extended to whole blue economy. 
• 

Increased  support  for  international  governance,  including  for  coast  guard 
cooperation. 

•  Action plans to be developed for the sustainable development of blue economy in 

outermost regions. 

•  The  scope  of  marine  knowledge  under  the  EMFAF  extended  from  covering  the 
Maritime  Strategy  Framework  Directive  and  the  Common  Information  Sharing 
System to also covering Maritime Spatial Planning, EMODNET and coast guard 
cooperation. 
Increased  synergies  between  fisheries  and  maritime  science  when  collecting 
scientific data. 

• 

Considering the sensitive nature of some types of support in view of the EU commitment 
to eliminate subsidies contributing to fisheries overcapacity and overfishing, the EMFAF 
prohibits  certain  types  of  support26  and  includes  a  financial  capping  of  certain  aid 
categories –referred to as “fleet measures”27. This includes support for the first acquisition 
of fishing vessels and specific investments related to fishing vessel operations, as well as 
the  permanent  and  temporary  cessation  of  fishing  activities,  are  financially  capped. 
Collectively, they cannot exceed 6 million Euro or 15% of each Member State’s allocated 
budget  (whichever is  higher) to  avoid  diverting funds from  higher value-added actions. 

25   12.6.2018 SWD(2018) 295 final. 
26   Article 13 of Regulation (EU) 2021/1139. 
27   Articles 17,18, 19 of Regulation (EU) 2021/1139. 

10 

 
 
The financial capping applies to the total of the Union financial support allocated to these 
operations. The distribution of financial resources across the five fleet measures is not ring-
fenced.  

Additionally,  with  a  view  to  prioritising  Member  States’  spending  in  support  of  the 
evidence base and control and enforcement, at least 15% of the budget for each Member 
State is ring-fenced and must be dedicated to two core areas of the CFP: the control of 
fishing activities and the collection of scientific data for fisheries management. 

2.2.  POINTS OF COMPARISON 

For the mid-term evaluation, the points of comparison reflect the comprehensive structure 
of objectives, priorities, and implementation mechanisms for EU fisheries and maritime 
policies 2021-2027: 

•  Effectiveness:  Degree  to  which  the  interventions  have  achieved  the  specific 
objectives:  sustainable  fisheries  and  reduction  in  EU  fishing  fleet  capacity, 
improvement in fleet competitiveness, and modernization efforts (e.g. health and 
safety, energy efficiency, product quality), improvement of scientific knowledge, 
enforcement, biodiversity conservation (such as the management of Natura 2000 
sites and marine litter), blue economy sectors, innovation, local development, GDP 
evolution,  and  job  creation  in  maritime/coastal  NUTS  3  regions  etc.  Alignment 
with  the  CFP,  contribution  to  international  ocean  governance,  and  horizontal 
impacts  such  as  marine  scientific  knowledge  and  cooperation  against  marine 
pollution. 

•  Efficiency:  Progress  on  simplification,  flexibility,  and  the  use  of  financial 
instruments  (loans,  guarantees,  repayable  grants)  relative  to  past  programming 
periods. Costs per output (e.g., cost of creating production capacity in aquaculture, 
costs for fleet measures), competition for grants, and use of simplified cost options. 
•  Relevance:  alignment  between  programme  priorities  and  actual  sectoral  needs, 
addressing identified gaps from stakeholder consultation (e.g., adequacy for small-
scale fisheries and regional sea-basin challenges. 

•  Coherence: degree of synergy with other EU funding programmes (ERDF, ESF, 
LIFE),  and  whether  the  intervention  supports  broader  EU  strategies  like  the 
European Green Deal and Farm to Fork. 

•  Administrative Implementation and Monitoring: implementation and use of the 
Common Monitoring and Evaluation System (CMES), the Infosys data reporting, 
and result/impact indicators (jobs created/maintained, surface of protected areas, 
aquaculture  value/volume,  shared  coastguard  operations).  Effectiveness  of 
baseline,  output,  and  result  indicators  between  the  current  and  previous 
programming periods. 

EMFAF performance at the EU level is measured by the Core Performance Indicators (see 
Table  2)  monitored  in  MFF  Performance  Results  Reports28.  These  indicators  represent 
some of the main results at the level of the operations to be achieved by the fund by 2029, 
therefore  they  are  used  as  the  quantitative  points  of  comparison  for  the  progress  in 
implementation.  

28   https://commission.europa.eu/document/download/4e8f26d1-6604-496f-87c4-

0b9a886adf29_en?filename=Core%20performance%20indicators%20%28new%29.pdf  

11 

 
 
Table 2: Overview of core performance indicators and their link with common result indicators/Infosys 

Core performance indicators  Unit 

Common result 
indicators/Infosys 

CI 01 - Businesses created 

Number of entities 

CR03 - Businesses created  

CI  02  -  Businesses  with  higher 
turnover 

Number of entities 

CR04  -  Businesses  with  higher 
turnover  

CI 03 - Jobs created 

Number of persons 

CR06 - Jobs created  

CI 04 - Jobs maintained 

Number of persons 

CR07 - Jobs maintained  

CI 05 - Persons benefitting 

Number of persons 

CR08 - Persons benefitting  

CI 06 - Actions contributing to a good 
environmental status, including nature 
restoration,  conservation,  protection 
of  ecosystems,  biodiversity,  animal 
health and welfare 

Number of actions 

CR10  -  Actions  contributing  to  a 
status, 
environmental 
good 
including 
restoration, 
nature 
of 
conservation, 
ecosystems,  biodiversity,  animal 
health and welfare 

protection 

CI  07  -  Energy  consumption  leading 
to CO2 emissions reduction 

CO2 
reduction 

emissions 

consumption 
CR18  –  Energy 
leading to CO2 emissions reduction  

CI 08 - Number of SMEs supported 

Number of SMEs 

CI  09  -  Number  of  fishing  vessels 
equipped with electronic position and 
catch reporting devices 

Number of vessels 

CI 10 - Number of local action groups  Number of LAGs 

Infosys 
manipulation 

data 

Infosys 
manipulation  

data 

extraction 

and 

extraction 

and 

FAMENET  will  contact  the  MS  to 
obtain this information. 

CI 11 - Number of small scale coastal 
fishing vessels supported 

Number 
vessels 

of 

SSCF 

Infosys 
manipulation 

data 

extraction 

and 

CI 12 - Usage of data and information 
platforms 

Number of page views  CR22 

-  Usage  of  data  and 

information platforms  

Source: Regulation (EU)) 2021/1139 (EMFAF), Annex I 

However, the EMFAF Midterm evaluation comes in a very early stage bearing in mind the 
delayed implementation of the EMFAF. Thus, there is only a limited number of outcomes 
which can be analysed. Due to the late adoption of the EMFAF and the CPR in July 2021 
the adoption of the EMFAF programmes was also delayed: 25 out of 26 national EMFAF 
programmes  were  adopted by the end of 2022 and one last programme  was adopted in 
March 2023. For this reason, it is considered appropriate to compare the implementation 
of EMFAF shared management up 30 June 2024 with the achievements of the EMFF up 
to 31 December 201629.  

29   Due to differences in the start of the implementation of the two programming periods, the timeline is 

approximative, and one-to-one comparison cannot be made at this point of the evaluation. 

12 

 
 
Therefore, throughout this Staff Working Document, the EMFAF is compared to the fund 
implemented in the previous programming period,  namely the EMFF (2014-2020). The 
effects of the changes in the design on programming and implementation are compared in 
qualitative and quantitative terms across the evaluation criteria.  

The  table  provides  the  link  between  EMFF  Union  Priorities  and  EMFAF  priorities 
comparable with each other.  

Table 3: EMFF Union Priorities, EMFAF Priorities  

EMFF Union Priorities 

EMFAF Priorities 

Union Priority 1  

Priority 1 excluding SO 1.4 

Union Priority 2 

Priority 2 SO 2.1 

Union Priority 3 

Priority 1 SO 1.4 

Union Priority 4 

Priority 3 

Union Priority 5 

Priority 2 SO 2.2 

Union Priority 6 

Priority 4 

Source: FAMENET 2025 

The table below provides indicators selected for the quantitative comparison. It is to be 
noted that this is a restricted selection made for the purposes of this initial analysis, whereas 
the Infosys contains very granular data for all the other EMFAF indicators, which can be 
further analysed in the context of the retrospective evaluation. At the same time, at this 
point in time the expected outcomes and objectives on aggregate level for the Fund cannot 
be  provided,  due  to  the  lack  of  counterfactual  analyses,  that  would  allow  for  casual 
attribution of impacts. The future actions to address this point in the final evaluation are 
laid down in section 4.1. 

Table 4: Selection of quantitative indicators 

Indicator 

Allocation for jobs created 

Allocation for jobs maintained 

Allocation for small-scale coastal fishing vessels supported 

Allocation for SMEs supported 

Period 

2014-2020 

2014-2020 

2014-2020 

2014-2020 

Allocation for local strategies selected by Fisheries Local Actions Groups 

2014-2020 

In Section 3.1, which describes the state of play of EMFAF during the evaluation period, 
their achievement in 2024 are compared to the values achieved in 2016 by the EMFF . 
Reference to Section 4.1 on effectiveness is also made.  

It should be noted that given the limited implementation of the EMFAF so far, the present 
comparison  between  the  EMFAF  and  the  EMFF  is  very  preliminary,  and  a  qualitative 

13 

 
 
comparison under section 4.2 (efficiency) is provided, highlighting key design shifts and 
delivery  improvements  that  differentiate  the  EMFAF  from  the  previous  Fund.  A  more 
comprehensive comparison with outputs and achieved targets at the level of results will be 
provided in the context of the retrospective evaluation of the EMFAF. 

14 

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

3.1. 

STATE OF PLAY OF THE EMFAF SHARED MANAGEMENT IMPLEMENTATION  

Based  on  transmission  of  data  info  for  the  reporting  period  until  30  June  2024, 
commitments reached 16% on average, with 10 Member States well below 10% and even 
4 Member States still at 0% commitments at 4 years into the programme period and 2 years 
after  programme  adoption.  The  level  of  commitments  is  calculated  against  the  total 
EMFAF allocation as provided in Member States’ EMFAF programmes. 

Figure 3: EMFAF Implementation rate- June 2024 

Source: DG MARE 

There is a high variability in the implementation between Member States and specific 
objectives. At the EU level Priority 1 has 59% of total committed amounts; Priority 2 – 
20%, Priority 3 – 8%, Priority 4 – 2% and Technical Assistance – 4%. Progress is visible 
particularly in operations implemented by public bodies, especially for data collection and 
control,  research  institutes  for  projects  on  innovation  and  improving  knowledge,  and 
ongoing progress to operationalise Local Action Groups (LAGs) is noted with differences 
across Member States.  

Beyond  activation  of  the  specific  objectives,  at  this  early  implementation  stage,  it  is 
possible to identify the following indicators’ values: the target 2029 value of CR10 Actions 
contributing to Good Environmental Status (GES), animal health and welfare, provided in 

15 

 
 
 
EMFAF programmes is 22 010, with 4 551 such actions indicated for selected operations 
and 1 534 actions already implemented. 

Significant progress has also been seen for the result indicator CR13 Cooperation activities 
between stakeholders: indicative result expected for already selected operations is 1 569 
operations  and  it  considerably  exceeds  the  number  of  actions  planned  in  programmes 
(891). From a socio-economic point of view, the target value in the programmes for new 
businesses created is 491, the indicative result expected for already selected operations – 
145  and  ex-post  result  –  49  new  businesses.  The  target  value  in  the  programmes  for 
businesses with higher turnover is 2 073 entities and the ex-post result – 145 entities. The 
evaluation findings also suggest that 3 498 jobs are planned to be created in programmes; 
the indicative result expected for already selected operations – 2 900 and ex-post result – 
254 new jobs. EMFAF programmes plan to maintain 17 266 jobs to be maintained; the 
indicative result expected for already selected operations – 2 391 and ex-post result – 425 
jobs maintained. 

The delay with the adoption of the EMFAF Regulation and the CPR are the main factors 
of this low implementation rate. The simultaneous finalisation of the EMFF and the start 
of EMFAF also contributed to implementation delays, which were further complicated by 
the lack of additional support with the same staff in the managing authorities managing 
both programmes in parallel and structural changes taking place within organisations at 
Member State levels. This situation was exacerbated further in the Member States strongly 
impacted by Brexit, where the managing authorities had to develop and implement State 
aid schemes under the Brexit Adjustment Reserve30 in the same period (2021-2023).  

The Member States that reported the most progress in the implementation of their national 
EMFAF  programme  during  the  evaluation,  identified  several  enabling  factors  that 
contributed to their capacity to make progress. These factors included having pre-existing 
procedures and processes, effective communication, and partnerships with the sector, and 
reduced administrative burdens for beneficiaries through SCOs and efficient IT application 
and management tools. 

Challenges in implementation 

2023 was the last year of EMFF implementation, causing the Managing Authorities (which 
manage both funds, which overlap in time) to focus heavily on maximising the absorption 
of the remaining available EMFF monies. This limited their ability to further accelerate 
the EMFAF programmes’ implementation. The speed of this process (notably the launch 
of calls for proposals, the assessment of applications, and the award of contracts) depends 
on national administrative procedures, which vary between Member States. DG Maritime 
Affairs and Fisheries is taking all reasonable steps to assist Member States in accelerating 
EMFAF programme implementation. 

Achievements and challenges regarding programme performance 

30   Regulation  (EU)  2021/1755  of  the  European  Parliament  and  of  the  Council  of  6  October  2021 
establishing the Brexit Adjustment Reserve (BAR). In the Member States where fisheries and aquaculture 
were  most  heavily  impacted  by  Brexit,  the  EMFF/EMFAF  managing  authorities  had  to  manage  the 
support schemes under the Brexit Adjustment Reserve in the same period. The eligibility period of the 
BAR ended on 31/12/2023, as the same as for the EMFF, thus coinciding fully in terms of management 
of support schemes in the period 2021-2023 with both EMFF and EMFAF. This concerned in particular 
the following Member States: Ireland, France, Belgium, the Netherlands, Denmark and Germany. 

16 

 
 
The  achievements  and  challenges  relating  to  performance  are  directly  tied  to  those  of 
implementation.  and  the  data  remain  very  limited.  The  picture  will  become  clearer  in 
subsequent years. 

The  initiatives  supported  were  in  the  field  of  maritime  policy,  scientific  advice, 
international ocean governance, regional fisheries organisations and activities delegated to 
the agencies under the United Nations’ umbrella. 

For shared management at the level of specific objectives, the highest commitment rates 
can be observed for the specific objectives ‘Technical assistance’ and ‘Control and data 
collection’, with 15.4% and 14.6% respectively of the total available allocations provided 
for these specific objectives.31 

COMPARISON BETWEEN IMPLEMENTATION RATE OF THE EMFF AND THE EMFAF 

The  absorption  rate  is  higher  (15.33%)  than  the  equivalent  absorption  rate  of  the 
EMFF (9.85%) for the same time-span of the programming period (beginning-until 
mid-term). This can indicate that even with the slow start of the EMFAF, Member States 
are better placed to advance on the implementation of their programmes than the position 
they were in the previous programming period. 

When  comparing  the  two  funds  per  EMFF  Union  Priority,  all  Priorities  but  especially 
Priority 1 and Priority 2 of the EMFAF have succeeded the EMFF commitments in the 
comparable timeframe.  

Table 5: Comparison of EMFF 2016 and EMFAF 2024 committed (selected and to be paid) EU support per 
priority  

Source: FAMENET based on Infosys data 

31   https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-

performance-statements/european-maritime-fisheries-and-aquaculture-fund-performance_en 

17 

 
 
 
FINANCIAL  ALLOCATION  BY  PRIORITY  AND  SPECIFIC  OBJECTIVE  UNDER  SHARED 
MANAGEMENT 

About half of the overall EMFAF financial allocation (51%) under shared management 
has been allocated to support sustainable fisheries and the restoration and conservation of 
aquatic biological resources (Priority 1). Within this priority, the focus is on data collection 
and control and enforcement (SO 1.4), with 21% of the total EMFAF financial allocation 
and 41% of the total financial allocation to Priority 1.  

The support to the sustainable development of aquaculture and to marketing and processing 
activities of fishery and  aquaculture products  (Priority 2) has received 35% of the total 
financial  allocation,  with  respectively  19%  for  aquaculture  and  16%  for  marketing  and 
processing activities. 

In comparison, 10% have been allocated to supporting the blue economy in coastal and 
rural  areas  (Priority  3)  and  2%  to  the  strengthening  of  international  governance  and 
maritime surveillance (Priority 4) (see figures below). 

Figure 5: Financial allocation per SO 

Source: National EMFAF programmes 

Figure 6:Breakdown of EMFAF committed under shared management by priority and specific objective 

Source: Infosys, 31 December 2023 

18 

 
 
 
Sustainable Fisheries and Data (SO 1.1, 1.4, 1.6): These areas receive the largest share 
of funding, aligning with the enduring sector need to tackle overcapacity, ensure scientific 
management, and conserve marine resources. Persistent challenges—such as overfishing, 
the need for improved data and control, and ecosystem-based management—justify the 
high allocations. The requirement that at least 15% of each country’s budget be dedicated 
to control and data collection was directly set to address these critical needs, especially in 
areas and basins facing stock declines or information gaps. 

Sustainable  Aquaculture  and  Processing  (SO  2.1,  2.2):  Substantial  investment  here 
matches the EU’s dependence on seafood imports and the strategic priority to boost self-
sufficiency  and  value-added  production.  Needs  assessments,  SWOT  analyses,  and 
stakeholder  consultations  highlighted  innovation,  competitiveness,  and  food  security  in 
aquaculture as major gaps, which the current allocations aim to fill. Special attention is 
given to financing innovation, environmental sustainability, and market development. 

Blue Economy and Local Development (SO 3.1): Funding for coastal and community-
led  development  addresses  persistent  social  and  demographic  decline  in  many  fishing 
areas, as well as the emerging need to diversify local economies. However, the allocation 
here  is  proportionally  smaller,  reflecting  both  the  scale  of  the  challenge  and 
complementary  support  available  from  other  EU  funds  (e.g.,  ERDF,  CAP  for  rural 
development). 

International Ocean Governance (SO 4.1): This has a minor allocation but still reflects 
a growing need for international cooperation, marine knowledge, and maritime security—
key themes in global ocean policy and crisis response. 

PROGRESS TOWARDS TARGETS BY MEMBER STATE 

Spain,  France,  Italy,  Poland,  Portugal,  and  Greece  have  the  highest  EMFAF  financial 
allocations, accounting when combined for almost two-thirds of the total EMFAF budget 
under  shared  management.  These  Member  States  have  a  slow  implementation  rate 
compared  with  their  milestones  and  targets  for  output  indicators.  In  Spain  the 
implementation  rate  is  below  5%  and  Poland  did  not  implement  any  operation  by  31 
December 2023. Four Member States have made no progress towards their milestones and 
targets, with no operations approved by 30 June 2024. For the remaining Member States, 
progress towards milestones at the level of outputs reaches up to 235% in Latvia, due to 
operations related to compensation types of actions, which were likely not considered in 
the initial milestone values. In addition, progress  towards targets  at the level of outputs 
only goes up to 24% in two Member States (Netherlands and Croatia). 

19 

 
Figure 7: Progress towards milestones at the level of outputs by Member States by 31 December 2023 

Source: National EMFAF programmes and Infosys 

Based on the financial allocations by year provided in the EMFAF programmes, it was 
possible to compare actual commitments to the cumulative financial allocations for the 
2021-2023 period. The figure below shows that commitment levels reach up to 33% in 
Czechia and 35% in Austria of their indicative EMFAF budget allocation for 2021-2023. 
In both Member States, the main progress has been made in SO 1.4 (data collection and 
control) and SO 2.1 (sustainable aquaculture). 

Figure 8: EMFAF expenditure committed by 2023 against the 2021-2023 budget allocation by Member State  

Source: National EMFAF programmes and Infosys, 31 December 2023 

There  is  distinct  difference  in  progress  made  in  Member  States  with  a  centralised 
versus a decentralised governance structure where those with centralised structures are 
more advanced as they started EMFAF implementation earlier than Member States with a 
more  decentralised  management  set-up.  This  discrepancy,  observed  in  previous 
programming  phases, is  mainly  attributed to the time needed for Member States with  a 
decentralised approach to establish governance structures and procedures at both central 
and regional levels, which also demonstrates the complexity in regionalised Member States 
to establish a national EMFAF programme.  

20 

 
 
 
Figure 9: Progress towards milestones and targets for centralised and decentralised Member States  

Source: National EMFAF programmes and Infosys, 31 December 2023 

IMPLEMENTATION BY PRIORITY BETWEEN MEMBER STATES 

Progress  in  EMFAF  implementation  is  underway  in  all  Member  States,  but  with 
differences. 

Priority 1: Fostering sustainable fisheries and the restoration and conservation of aquatic 
biological resources 

By  the  end  of  2023,  Denmark,  Germany,  Italy,  and  France  carried  out  71%  of  their 
commitments of the total financial allocations under this priority. On the contrary, seven 
Member States (Bulgaria, Estonia, Hungary, Ireland, Poland, Romania and Slovakia) had 
not started selecting projects under Priority 1. 

Germany, Austria, and Denmark have made the most significant progress with 41%, 39% 
and 32% of their total  financial allocations  to  P1 already  committed, respectively.  This 
progress is primarily due to the implementation of SO 1.4 (data collection and control) in 
these countries. 

Priority 2: Aquaculture, marketing and processing of fishery and aquaculture products 

By  the  end  of  2023,  ten  Member States  (Bulgaria,  Greece,  Croatia,  Hungary,  Ireland, 
Poland, Portugal, Romania, Slovenia, and Slovakia) had not started selecting projects for 
any of the specific objectives under Priority 2. Meanwhile, the commitments made by Italy, 
Latvia, France, and Denmark account for 65% of the total commitments of the financial 
allocations under Priority 2. 

Priority 3: Sustainable blue economy 

Only  eight  Member  States  have  planned  financial  allocations  and  started  implementing 
operations  under  Priority  3  by  the  end  of  2023.  Croatia  alone  accounts  for  77%  of  the 
commitments of the total financial allocation under Priority 3. Italy accounts for 11% of 
commitments while the remaining 12% of commitments is shared among Finland, France, 
Germany, Latvia, Lithuania, and Slovenia. 

21 

 
 
Priority 4: International ocean governance and sustainable management 

Only  three  Member  States  have  planned  financial  allocations  and  started  to  implement 
Priority  4  by  the  end  of  2023:  France  with  68%  of  the  commitments  of  the  financial 
allocation, Finland and Slovenia. National authorities explained the delay of implementing 
priority 4 with the need for familiarisation of this new area. 

FEEDBACK FROM MANAGING AUTHORITIES 

According to feedback from the survey of managing authorities carried out in the context 
of the supporting study, implementation levels are expected to increase in 2024, but with 
high variability between Member States and specific objectives. The specific objectives 
where the highest number of Member States expects to achieve milestones by the end of 
2024 are:  

•  SO 1.3 (cessation of fishing activities) 
•  SO 1.4 (data collection and control) 
•  SO 1.6 (biodiversity and ecosystems) 
•  SO 2.2 (marketing and processing) 
•  SO 3.1 (CLLD) 

In contrast, Member States reported significant challenges in implementing SO 1.2 (energy 
efficiency) often linked to the lack of balanced fleets which can be considered as eligible 
under the EMFAF legal framework, SO 4.1 (sustainable ocean management) and SO 1.5 
(compensation for ORs). Some managing authorities mentioned the fact that they are not 
familiar with areas under Priority 4, leading to delays in planning and committing budget 
for types of actions under this priority. In the French Outermost Regions, changes in the 
organisational structure for managing the fund were cited as the primary reason for delays 
in implementing SO 1.5. 

FINANCIAL EXECUTION ON SPECIFIC TOPICS 

Small scale coastal fisheries 

Small scale coastal fisheries (SSCF) received support32 through a total of 1 273 operations, 
with  EMFAF  planned  support  of  EUR  121.2  million  and  EMFAF  eligible  expenditure 
(incurred and paid) of EUR 47.9 million as of the end of 2023.  

Private  operators,  including  micro  and  SMEs,  predominantly  benefited  from  actions 
involving SSCF, accounting for 55% of the total  operations. However, research centres 
and public bodies received the majority of the EMFAF commitments, with 47% and 15% 
respectively of total EMFAF committed for operations involving SSCF. 

Specifically,  regarding  SO  1.4  (data  collection  and  control),  research  centres  and 
universities were the primary beneficiaries of the funding supporting projects benefiting 
SSCF in terms of funding. Despite micro private enterprises benefiting the most under this 
specific objective in terms of the number of operations (12 operations), the corresponding 

32   Based  on  Infosys  field  29  Operation  relevant  to  SSCF;  Table  1  of  Annex  I  of  CIR  (EU)  2022/79; 

calculation based on CFR number might differ. 

22 

 
 
EMFAF  commitment  was  relatively  low  (only  EUR  22  500),  attributed  to  the  small 
investments required for compliance with control requirements. 

The  same  observation  applies  to  SO  1.1  (sustainable  fishing  activities),  where  private 
enterprises  benefitted  from  the  largest  number  of  operations  (216  operations)  while  the 
largest amount of the EMFAF goes to research institutes and universities (EUR 4.3 million 
versus EUR 2.9 million). 

Focus on temporary cessation of fishing activities  

As SO 1.3 includes both temporary and permanent cessation of fishing activities, a total of 
640 operations had been approved by the end of 2023, including 420 operations fully paid, 
amounting to an EMFAF commitment of EUR 9.7 million, which represents only 7% of 
the total financial allocation. The EMFAF payments accounted for 4% of the total financial 
allocation (EUR 6.1 million). 

Focus on Energy transition  

Different SOs can contribute to energy transition, but this has to be looked in light of the 
very specific eligibility rules that concern balanced fleet segments. Based on the screening 
of projects descriptions for operations tagged as contributing to climate change mitigation 
and adaptation, only few operations could be identified as clearly contributing to energy 
transition mostly beyond the operations supported under SO 1.2, focusing on increasing 
energy efficiency and reducing CO2 emissions through the replacement or modernisation 
of engines of fishing vessels. Only 27 operations were carried out under this SO in Finland 
and France, representing 8% of the 2024 milestone for outputs and 2% of the final target. 
The  EMFAF  committed  for  this  SO  reached  EU  184  000  by  the  end  of  2023,  which 
represents 2% of the total financial allocation to this SO. 

DIRECT AND INDIRECT MANAGEMENT 

The  financial  envelopes  for  direct  management  (excl.  TA  at  the  initiative  of  the 
Commission)  for  FY  2021-2024  was  EUR  90  million  annually.Direct  management 
supports voluntary contributions to RFMOs and international organisations in order to:  

•  Promote the long-term sustainability of the stocks and the fishers that depend on 

them.  

•  Adopt  management  measures  based  on  transparent  and  independent  scientific 

advice.  

•  Promote  better  compliance  to  combat  illegal  unreported  and  unregulated  fishing 

activities.  

•  Promote better governance in the RFMOs including their administration decision-

making process and their progress.  

•  Promote  greater  participation  from  developing  countries  to  build  consensus  and 

improve acceptance and implementation of decisions taken. 

The annual budget need of the RFMO compulsory contributions is EUR 190 million. 

The 11 ACs were established under the 2013 CFP Reform. Under the EMFAF EUR 14.1 
million has been committed and EUR 12.5 million paid between 2021 and 2024. In line 
with  the  objective  of  moving  to  financial  instruments  and  simplified  cost  options,  the 

23 

 
Commission moreover changed the annual grant procedures for the AC to lump-sum based 
approach.  

The  EMFAF  direct  management  is  also  used  to  finance  the  EUMOFA  that  receives 
annually  EUR  3.648  million,  which  performs  data  collection  on  markets,  and  produces 
reports, studies and market analysis to the attention of sector’s stakeholders.  

the 

total  EMFAF 

The EUR 206.7 million of the EMFAF that has already been committed correspond to 26% 
of 
implemented  under 
(in)direct management.  While  65%  of  the  operations  have  been  implemented  under 
Priority 1, the highest committed amount is for operations under Priority 3 (54% of the 
total committed of the allocated budget so far). 

funding  available 

for  operations 

As such, the financial execution under the two-year work programmes does not show a 
slow rollout in the implementation of the Fund that is observed in the national EMFAF 
programmes, which relates to the differing nature of this management mode. 

24 

 
 
 
Result  indicators  have  already  been  reported  for  the  operations  under  (in)direct 
management. For example, 210 jobs were created (CR06) as a result of three operations 
(under  the  ‘Blue  careers  for  a  sustainable  blue  economy’  call33),  and  another  149 
maintained (CR07) as a result of 21 operations, while 4 906 people have benefitted (CR08) 
from 26 operations under (in)direct management as of 31 January 2024.  

Figure  9  shows  how  much  of  the  direct  management  budget  was  committed  for  each 
objective and Figure 10 indicates the type of action. The largest amount in each case was 
for the financial instrument to help SMEs develop innovative new products and services 
in  the blue economy. The figures only  include the EMFAF  share  and the  contributions 
from InvestEU are not included. 

Figure 10: Financing of specific objectives under (in)direct management as of November 2024 

Source: supporting study  

Figure 11: Types of action financed under (in)direct management as of November 2024 

Source: supporting study 

33   See European Commission, Eight EMFAF projects kickstarted their work to develop the next generation 
of  blue  skills,  available  at:  https://maritime-forum.ec.europa.eu/eight-emfaf-projects-kickstarted-their-
work-develop-next-generation-blue-
skills_en#:~:text=BLUE%20PORTS%20%2D%20BLUE%20CAREERS%20IN,Strategy%20until%20
2030%20and%202050. 

25 

 
 
 
 
IMPROVEMENTS IN EMFAF IMPLEMENTATION OVER THE EVALUATION PERIOD  

Since the adoption of the EMFAF Regulation, the Commission has been in close contact 
with Member States and also with other EU institutions, notably the European Parliament 
and European Court of Auditors, to discuss implementation challenges as they emerged. 
Against  the  background  of  constant  dialogue  and  feedback,  the  Commission  has  taken 
various steps, to improve the implementation of the Fund within the mandate of the legal 
framework. 

The Commission’s Geographical Units are constantly monitoring the implementation of 
the  EMFAF  programmes  and  assist  the  Member  States  in  solving  challenges  linked  to 
implementation. The same units have specifically addressed the low absorption rate of the 
EMFF operational programmes and have been closely monitoring the implementation of 
the  EMFAF  programmes  through  attending  Annual  Review  Meetings  and  Annual 
Performance  Review  Meetings,  Monitoring  Committee  Meetings,  specific  technical 
meetings,  seminars  and  workshops  with  national  authorities  and  stakeholders,  daily 
telephone  correspondence/video  conferences  with  Managing  Authorities  (MAs), 
addressing legal interpretation questions and sending official letters to call the attention of 
the MS to implementation issues. 

Despite the different pace of preparatory work by Member States during the programme 
preparation  period,  after  programme  adoption,  all  Member  States  have  made  efforts  to 
move forward with the implementation as quickly as possible. In this regard, the level of 
preparedness  varies  considerably  depending  on  the  administrative  capacity  of  each 
Managing  Authority  (and  their  Intermediate  Bodies),  the  Member  States’  internal 
administrative  and  political  priorities  and  the  level  of  advancement  of  the  EMFF 
Operational Programmes. 

26 

 
4.  EVALUATION FINDINGS 

4.1 EFFECTIVENESS  

This  section  presents  an  assessment  of  how  successful  the  EMFAF  has  been,  mid-way 
through its lifetime, in progressing towards the specific objectives and the extent to which 
the delivery system is effective.  

As explained, the start of the EMFAF has been marked by delays due to the late adoption 
of the EMFAF Regulation, the general crisis context of COVID-19, Brexit, the unjustified 
Russian  military  aggression  against  Ukraine,  and  the  challenges  for  Member  States  in 
managing both the closure of the EMFF and the initiation of the EMFAF, among others. 
Most Managing Authorities cited the difficulty to manage both the closing the EMFF and 
start of the EMFAF at the same time without additional support. Additionally, structural 
changes within organisations contributed to capacity constraints. The deterioration of the 
economic situation in relation to Russia’s military aggression  against Ukraine is reflected 
in the ability of beneficiaries to complete the implementation of their projects. Moreover, 
challenges  related  to  Brexit,  reduced  economic  activity,  and  conditions  stemming  from 
new  or  ongoing  environmental  regulations  further  hindered  effective  start  of  the 
implementation.  

Even though, it is too early to systematically assess the impact of the EMFAF, the analysis 
of the EMFAF programmes and feedback gathered from the Member States in the context 
of the evaluation show that the planned budget allocation and types of actions demonstrate 
both continuity with the EMFF and capitalisation on lessons learnt. 

The implementation of the EMFAF appears to be more advanced than the mid-term 
implementation  of  the EMFF.  Using  the  selected  performance  indicators  to  make  the 
comparison between the EMFF and the EMFAF (Table 1), it is evident that even if both 
Funds were faced with implementation delays, the EMFAF is progressing better than the 
EMFF in the middle of the programming period. The reason behind this is attributed to the 
fact  that  the  EMFAF  contains  various  novelties  in  its  delivery  system,  with  a  more 
simplified design, as explained in section 4.2  

Table 6: Comparison between EMFF (up to 31 December 2016) and EMFAF (up to 30 July 2024) at the 
level of outputs for certain key performance indicators. 

Source: DG MARE 

27 

SMEsNumber of Operations, with beneficiary = SME871                                   1.533                                   EMFF/EMFAF Support (EUR)82.235.382,08                 138.667.260,91                  EMFF/EMFAF Eligible Expenditure (EUR)3.050.400,22                   54.685.582,84                    SSCFNumber of Operations with vessel = SSCF1.811                                2.405                                   EMFF/EMFAF Support (EUR)10.143.410,93                 68.422.638,29                    EMFF/EMFAF Eligible Expenditure (EUR)811.107,60                      12.657.929,92                    CLLDNumber of Operations under Priority = UP4 (EMFF) or P3 (EMFAF)                                    161 363                                       EMFF/EMFAF Support (EUR)                 16.029.012,49 62.643.373,62                    EMFF/EMFAF Eligible Expenditure (EUR)                       204.195,26 3.681.559,60                      Employment, result achieved, with status = fully implementedEmployment created8254Employment maintained584425 
 
OUTPUT ACHIEVEMENTS 

Although the implementation is still at an early stage, some achievements can already be 
seen in the monitoring data concerning output indicators (see table below), even if these 
are behind the 2024 milestones for output indicators. These concern both economic and 
environmental  results  (e.g.,  actions  contributing  to  GES,  animal  health  and  welfare, 
cooperation between stakeholders, jobs created or maintained, etc.) (see table below).  

Table 7: Achievements of output indicators compared to the milestones in programmes 2024 

Priority 

SO 

Milestones for number of 
operations set in programmes for 
2023 

Number of Operations achieved 
2024 

% 

1 

1 

1 

1 

1 

1 

2 

2 

3 

4 

5 

1.1 

1.2 

1.3 

1.4 

1.5 

1.6 

2.1 

2.2 

3.1 

4.1 

5.1 

3 929 

355 

14 309 

1 635 

1 520 

2 174 

3 462 

2 092 

2 235 

101 

577 

938 

39 

2 916 

142 

1 524 

452 

819 

710 

363 

17 

52 

Totals 

32 386 

7 972 

Source: Infosys, 31 December 2024 

23,9% 

11,0% 

20,4% 

8,7% 

100,3% 

20,8% 

23,7% 

33,9% 

16,2% 

16,8% 

9,0% 

24,6% 

Sustainable Fisheries and Data (SO 1.1, 1.4, 1.6) receive the highest share of funding, 
ensuring that essential scientific data, monitoring capacity, and conservation actions are 
supported  across  all  Member  States.  The  regulation’s  requirement  for  each  country  to 
dedicate at least 15% of its budget to data collection and control helps close long-standing 
knowledge and enforcement gaps, particularly in regions with declining fish stocks. 

However,  progress  in  turning  this  funding  into  tangible  outputs  has  been  slow.  2024 
milestone achievements remain low—23.9% for sustainable fisheries, 8,7% for data and 
control, and 20.8% for biodiversity and ecosystems. This suggests that challenges lie less 
in budget allocation and more in administrative and operational execution. Streamlining 
procedures  and  accelerating  project  uptake  will  be  crucial  for  translating  this  strong 
financial foundation into measurable environmental and management results. 

Sustainable  Aquaculture  and  Processing  (SO  2.1,  2.2)  with  nearly  €1 billion  for 
aquaculture and €862 million for marketing and processing. Milestone progress, however, 
shows  uneven  implementation.  Aquaculture  (SO 2.1)  has  achieved  around 23.7% of  its 

28 

 
 
planned  milestones,  while  marketing  and  processing  (SO 2.2)  stand  at 34%.  The  faster 
progress in SO 2.2 partly reflects temporary crisis measures—such as compensation linked 
to the Ukraine war—rather than steady structural growth. 

Blue Economy and Local Development (SO 3.1) with around €528 million is dedicated 
to community-led local development (CLLD) in coastal regions. 

Progress so far is limited, with only 16.2% of milestones achieved. This delay is mainly 
procedural: local action groups take time to set up governance structures, draft territorial 
strategies,  and  launch  calls.  Still,  the  principle  of  bottom-up  development  remains 
central—empowering  communities  to  design  local  solutions  for  economic  renewal, 
environmental stewardship, and social inclusion. 

International  Ocean  Governance  (SO  4.1)  receives  a  relatively  small  budget—€91.9 
million.  The  low  milestone  achievement  rate  (9%)  is  in  line  with  the  nature  of  these 
activities, which often involve indirect action, long-term policy engagement, and complex 
multilateral initiatives. While the financial scale is modest, the value lies in the influence 
and coordination the EU can exercise globally—areas where tangible outputs are slow to 
materialize  but  critical  for  long-term  ocean  health  and  governance.  This  measured 
approach is appropriate given the challenges and timelines inherent in international ocean 
policy. 

RESULT ACHIEVEMENTS 

Although the implementation is still at an early stage, some results can already be seen in 
the monitoring data  (see table below), even if these are behind  the 2024 milestones  for 
output indicators. These concern both economic and environmental results (e.g., actions 
contributing to GES, animal health and welfare, cooperation between stakeholders, jobs 
created or maintained, etc.).  

On the achievement of results, a first analysis of the data reported by Member States on 
the common indicators sheds light on the overall progress made under the Fund. To date, 
the  data  of  four  Transmission  of  Data  reporting  rounds  have  been  reviewed  to  ensure 
comparability. Implementation data covering the progress achieved will be published on 
the  Open  Data  Platform  in  202534.  The  picture  will  evolve  once  the  implementation  of 
EMFAF  progresses  further  and  supported  operations  are  finalised  by  beneficiaries, 
allowing Member States to report more advanced and mature data on the result indicators 
in particular. Therefore, an assessment on the delivery of the targets at the level of the 
result indicators will only become possible towards the end of the programme period. 

Scientific literature35 which is available, suggests that support to types of actions on data 
collection, control and enforcement, the management of MPAs, and CLLD, can bring long-
term  benefits,  for  the  fisheries  sector.  However,  the  potential  long-term  economic, 
environmental,  and  social  impacts  of  the  Fund  will  depend  on  the  actual  projects 
supported  by  the  end  of  the  programming  period.  It  is  the  implementation  of  these 
projects included in the programmes, that will allow for an assessment of the full impact 

34   Open Data Portal for the European Structural Investment Funds - European Commission | Cohesion Open 

Data 

35   Skerritt  DJ,  Arthur  R,  Ebrahim  N,  Le  Brenne  V,  Le  Manach  F,  Schuhbauer  A,  et  al.  A  20-year 
retrospective  on  the  provision  of  fisheries  subsidies  in  the  European  Union.  ICES  Journal  of  Marine 
Science. 2020;77(7‑8):2741‑52. 

29 

 
 
of  the  Fund.  This  is  why  the  Commission  is  already  taking  steps  to  develop  impact 
pathways in order to analyse the cause-effect chain and estimate broader impacts of the 
Fund, especially in view of the ex-post evaluation of the EMFAF.  

The reflections among the Commission services have already started in order to identify 
specific case studies  and  counter-factual analyses  on different  policy dimensions which 
can provide an outlook into the long-term effects of the EMFAF.  

Stakeholder feedback 

Stakeholder respondents in surveys and interviews conducted during the supporting study 
emphasised  that  the  success  of  EU  fisheries  and  aquaculture  policies  depends  on 
establishing  clear,  measurable  sustainability  and  animal  welfare  indicators  to  track 
progress and ensure funding supports environmentally responsible practices. They stress 
that transitioning to low-impact, climate-smart fisheries requires targeted investments in 
vessel  modernisation,  energy-efficient  technology,  and  infrastructure.  Equitable  growth 
through the EMFAF relies on prioritising small-scale and coastal fisheries, which are both 
environmentally sustainable and financially vulnerable. Effective policy implementation 
also demands adaptability to regional conditions, including inland and outermost regions. 
Overall, public consultation participants viewed the EMFF and the EMFAF as reasonably 
effective  in  meeting  their  objectives,  particularly  in  supporting  the  Common  Fisheries 
Policy (see table below with summarized positive comments from the stakeholder survey). 

Table8 : Stakeholder opinions 

Type of stakeholder 

Positive Feedback:  

Managing Authorities 
(National & Regional) 

Fisheries & Aquaculture 
Sector 

Non-Governmental 
Organizations (NGOs) 

Producer Organizations & 
Trade Unions 

Research Institutions & 
Universities 

Market Actors & Supply 
Chain Stakeholders 

Source: EMFAF MTE ANNEX V 

•  Strong stakeholder involvement in programme design. 
•  Effective performance framework with historical data. 
•  High flexibility, enabling quick adaptation during crises (e.g., 

• 

COVID-19). 
Improved governance and administrative processes since the 
previous funding period (EMFF). 

•  Supports investment in production capacity, job creation, and 

innovation. 

•  Perceived economic benefits through increased competitiveness. 
•  Recognition of environmental and sustainability efforts. 
•  Fund aligns with EU Green Deal objectives. 

•  Financial support for fleet modernization and competitiveness. 
•  Strong focus on social sustainability (worker conditions, wages). 

•  Support for data collection, scientific studies, and innovation. 
•  Coordination with other EU-funded research projects. 

•  Acknowledged support for sustainable seafood supply chains. 

However, it is too early to assess the Member State programmes’ effectiveness towards 
reaching the specific objectives of the Fund in terms of results and impacts.  

Whether budget take-up will be better/quicker for the EMFAF than the EMFF will depend 
on the capacity and time needed for the Member States to adopt national legislation, work 

30 

 
with  different  delivery  models,  implement  the  calls,  selections,  manage  the  contracts, 
payments,  and  certifications.  Also,  the  economic  situation  and  prospects  of  private 
operators are key for their investment capacity and take-up of the fund.  

LIMITING FACTORS FOR THE EFFECTIVENESS OF THE FUND 

The EMFAF faces challenges, notably in terms of organisational capacity, and the need 
for consistent training and skills development, especially at the national level. Addressing 
these areas can further enhance the effectiveness of the EMFAF in achieving its goals of 
sustainable structural changes in the maritime and fisheries sectors.  

The study shows varied perceptions exist regarding staff capacity and resource allocation. 
Some authorities have had to hire external consultants, and simultaneous management of 
multiple funds (EMFAF, EMFF, BAR, state aid) has posed capacity challenges. There is 
a  recognised  need  for  updating  skills  and  training,  with  concerns  about  staff  turnover 
affecting  institutional  memory.  Managing  authorities  largely  view  their  governance 
structures as effective, with 77% rating them highly effective. However, application and 
selection procedures and monitoring systems show room for improvement. 

The study shows that stakeholder involvement during the preparation of national EMFAF 
programmes  has  been  largely  effective,  with  strong  support  and  satisfaction  for  the 
managing authorities. However, there is room for more innovative contributions and better 
alignment of stakeholder expectations with practical realities. 

There is room for more simplification at national level. While there is wide-spread appetite 
for  using  more  SCOs,  managing  authorities  have  limited  resources  and  find  it 
methodologically  challenging  to  develop  them.  There  is  also  concern  about  the  high 
control efforts that Member States have to apply; e.g. for real cost based support, many 
Member States still apply a 100% of invoices before payments to beneficiaries and they 
do not use risk-based approaches, often due to negative experiences with recoveries from 
beneficiaries in funding periods before 2014. 

There  are  cases  where  efficient  IT  tools  for  programme  management  take  long  to  be 
developed and are challenging to implement when they have to be linked up with existing 
national/regional IT tools. 

The  EMFAF  delivery  system  provides  enhanced  flexibility  to  accommodate  different 
governance  models  within  the  Member  States  and  achieving  a  high  level  of  perceived 
effectiveness.  However,  the  evaluation  findings  point  to  specific  areas,  particularly  the 
application and selection procedures, and monitoring and reporting systems, where there 
is  scope to  optimise the  EMFAF  delivery system's  effectiveness.  Seven  Member States 
have established intermediate bodies at the regional level to oversee the implementation 
and distribution of the fund, namely Belgium, France, Italy, Poland, Portugal, Austria and 
Spain.  In  Germany,  the  implementing  bodies  in  the  Lander  have  the  formal  status  of 
managing authority due to the federal constitutional set-up.  

In  contrast,  the  remaining  Member  States  opted  for  a  centralised  approach,  where  the 
central administration fully governs the fund’s management at the national level directly 
or  with  the  support  of  an  intermediate  body  at  the  National  level.  In  the  case  of 
decentralised  countries,  usually  intermediate  bodies  support  the  implementation  both  at 
central  and  regional  level.  These  differences  in  governance  structures  underscore  the 

31 

 
varying administrative frameworks within the EU but also illustrate the flexibility of the 
EMFAF delivery system.  

Stakeholder feedback 

According to the supporting study, the managing authorities’ feedback on the effectiveness 
of  the  structure  and  processes  administering  the  EMFAF  reveals  varying  perceptions 
across  different  aspects  (see  table  below  with  summarized  challenges  raised  by 
stakeholder).  

Table9 : Stakeholder opinions on challenges 

Type of stakeholder 

Challenges 

Managing Authorities (National & 
Regional) 

•  Administrative burden remains an issue despite simplification 

efforts. 

•  Resource constraints lead to implementation delays. 
•  Need for improved informal exchanges between managing 

authorities. 

Fisheries & Aquaculture Sector 

•  Bureaucratic complexity in applying for funding. 
•  Concerns over fund allocation and access for small-scale 

fishers. 

•  Regulatory inconsistencies between national and EU-level 

rules. 

•  Funding mechanisms favour large enterprises over small-scale 

initiatives. 

•  Lack of clear sustainability indicators to track real impact. 
•  Complex application process prevents some stakeholders from 

applying. 

•  Limited support for workforce renewal and youth entry into 

fisheries. 

•  Lack of incentives for small producers and micro-enterprises. 
•  Financial instruments are underutilized due to complexity. 
• 
•  Need for improved integration of research into policy 

Insufficient long-term research funding. 

decisions. 

•  Fund access is too complex for smaller market players. 
•  More transparency needed in distribution of financial 

resources. 

Non-Governmental Organizations 
(NGOs) 

Producer Organizations & Trade 
Unions 

Research Institutions & 
Universities 

Market Actors & Supply Chain 
Stakeholders 

Source: EMFAF MTE ANNEX V 

Most  managing  authorities  (20  out  of  26,  77%)  assessed  their  governance  structure  as 
highly effective. In addition, slightly more than half of the managing authorities (58%, 15 
out of 26), also rated the application and selection procedures as highly effective. However, 
a notable proportion (38%, 10 out of 26), rated its effectiveness as medium only, indicating 
some room for improvement of the application and selection procedures. Most managing 
authorities (64%, 16 out of 25) also rated the monitoring and reporting system as having a 
medium  level  of  effectiveness,  indicating  some  level  of  satisfaction  but  also  room  for 
improvement  in  terms  of  clarity  or  comprehensiveness  in  reporting  mechanisms.  In 
addition,  10  out  of  16  managing  authorities  (62%)  noted  improved  communication 
between  relevant  parties 
implementation,  fostering  better 
coordination and collaboration.  Regarding (in)direct  management, the EMFAF delivery 
system introduced flexible bi-annual work programmes, improving in this way planning 
and internal tracking, and consolidating monitoring efforts. 

in  EMFAF 

involved 

32 

 
 
Moreover, the EMFAF includes a list of ineligible operations (e.g. building new fishing 
vessels, increasing the power of fishing vessels) and a set of conditions to prevent harmful 
effects,  including  indirect  effects  (e.g.  certain  investments  can  be  supported  only  in 
segments  of  the  fishing  fleet  without  structural  overcapacity).  Member  States  have 
identified these legal restrictions as one of the reasons for the low absorption of the Fund36. 

4.2 EFFICIENCY  

This  section  addresses the efficiency of  the  EMFAF design  and management,  including 
potential  areas  for  further  simplification.  Due  to  the  low  levels  of  the  EMFAF 
implementation under shared management, it is not yet possible to compare the costs and 
outcomes  of  operations.  Whenever  possible,  the  impact  assessment  and  previous 
evaluations are used as point of comparison. 

The  2018  EMFAF  impact  assessment  identified  several  key  structural  and  operational 
challenges and the needs which the fund had to tackle. In relation to fisheries, it identified 
that  overcapacity  remained  a  significant  issue  in  many  segments,  particularly  in  the 
Mediterranean,  where  fishing  often  exceeds  sustainable  limits.  It  also  showed  that 
successful implementation of the CFP would depend on ongoing support for fisheries 
control, data collection, and combating illegal, unreported, and unregulated (IUU) fishing 
both  within the EU and internationally. Furthermore, the information  collected must be 
utilised for broader purposes (for surveillance and marine knowledge), necessitating more 
interoperable  systems.  Small-scale  coastal  fisheries,  representing  74%  of  all  active 
vessels in the EU, remain crucial for the resilience of coastal communities. While the sector 
was  profitable  in  2015  and  has  seen  increased  labour  productivity,  the  situation  varies 
regionally, with many small-scale fleets facing net losses. The fisheries sector’s lack of 
attractiveness,  due  to  safety  concerns  and  poor  working  conditions  requires  ongoing 
attention.  Although  the  core  issues  the  EMFAF  seeks  to  address  -  such  as  market 
failures  and  the  implementation  of  the  CFP-  remain  consistent  with  past 
programmes, lessons learnt have prompted adjustments in its delivery system.  The 
broader  regulatory  and  policy  environment  has  also  evolved,  requiring  updates  in  the 
Fund’s design. 

The EMFF ongoing ex-post evaluation37 also shows that the set-up of that fund did not 
allow for rapid reactions to crisis, as has been experienced in relation to the COVID-19 
crisis  and  the  Russian  aggression  in  Ukraine.  Unspent  funds  were  available  under  the 
EMFF, but they could not be easily redirected to help tackle the above-mentioned crises 
because of inflexible EMFF rules. 

In response to these needs and findings, the design of the EMFAF has been guided by the 
following principles: a more flexible and simplified fund including through greater use of 
financial instruments, more synergies and better alignment with EU policy objectives and 
international  obligations,  and  provisions.  Moreover,  in  response  to  the  finding  that  the 
EMFF  was  not  sufficiently  reactive  and  flexible  in  times  of  crisis  (ex.  COVID),  the 
EMFAF provides for the possibility to trigger a crisis mechanism in case certain conditions 
are  met,  which  would  result  in  compensation  in  case  of  exceptional  events  causing  a 
significant disruption of markets. 

36   Minutes of the Expert Group of 6 November 2024.  
37   To be finalised mid-2025. 

33 

 
 
A MORE FLEXIBLE AND SIMPLIFIED FUND  

The EMFAF’s four priorities broadly outline the scope of support in line with the fund's 
objectives. Specific objectives further clarify areas of support, and a more limited number 
of eligibility criteria are specified in the EMFAF Regulation, as compared to the EMFF. 
This approach created a flexible implementation framework, allowing Member States to 
pursue strategic national priorities based on their SWOT analysis and the Commission’s 
needs assessment by sea basin. In contrast to the EMFF, which relied on rigid financing 
descriptions and eligibility rules, and a detailed set of eligible “measures”, the EMFAF 
seeks to streamline delivery systems and enhance flexibility.  

A novelty of the EMFAF is its new architecture, namely a move away from predefined 
measures, allowing Member States greater flexibility to pursue strategic objectives based 
on an assessment of their needs. The analysis shows that despite the increased flexibility, 
in practice the national EMFAF programmes are broadly a continuation of the EMFF. The 
simplified structure of the EMFAF, particularly for its first two priorities, illustrates the 
simplification of the Fund’s set-up: 

Figure 13: Indicative illustrations of how the architecture of the EMFF compares with the EMFAF (Priority 
1) 

34 

 
 
 
Figure 14: Indicative illustrations of how the architecture of the EMFF compares with the EMFAF (Priority 
2) 

Source: extract from the supporting evaluation study 

Based  on  the  lessons  learnt  in  the  previous  programming  period  as  regards  operational 
management, EMFAF procedures became simpler, and the administrative burden lighter 
compared to the EMFF. Key sources of simplification include: 

•  The ability to reallocate budgets within specific objectives without revising national 

programmes. 

•  The use of simplified cost options and financing not linked to costs to streamline 
financial  management  and  reporting  both  in  the  areas  of  shared  and  direct 
management.   

•  The implementation of risk-based analysis to ease application procedures. 
•  The shift to digital processes aiming at reducing paperwork and enhancing project 

management efficiency. 

•  The streamlining of monitoring requirements through a reduction of the number of 

common result and output indicators. 

•  A simplified conditionality system with support being conditional upon compliance 
with the objectives and rules of the CFP and with the eligibility rules of the EMFAF 
regulation. 

In addition, the EMFAF-specific simplifications, the new CPR regulation also introduced 
several simplifications: 

•  Streamlining of ex-ante conditionalities into enabling conditions – The number 
of  conditionalities  was  reduced  from  36  ex-ante  conditionalities  to  20  enabling 
conditions  of  which  the  7  general  ex-ante  conditionalities  were  replaced  by  4 
horizontal enabling conditions on public procurement, State aid, the EU Charter of 
Fundamental  Rights  and  the  UN  Convention  on  the  Rights  of  Persons  with 
Disabilities which are also relevant for the EMFAF. 

•  Simplified identification of programme authorities – The process of designating 
managing,  certifying,  and  audit  authorities,  under  the  previous  programming 
period, was simplified for the new programming period which among others made 
it possible to “roll over” existing systems from the previous programming period 

35 

 
 
and, in particular in case of newly identified authorities, rely on early system audits 
for assurance. 

•  The  streamlining  and  simplification  of  evaluation  requirements:  all 
requirements have basically been reduced to a mid-term and an ex-post evaluation 
to  be  done  by  the  Commission  and  the  mid-term  evaluations  to  be  done  by  the 
Member States during programme implementation. 

•  Reduction  in  audit  and  control  requirements  –  a  risk-based  approach  for 
management verifications and audits was introduced, focusing on higher-risk areas 
rather than aiming for 100% coverage. In addition, the 'Single Audit' principle was 
the  administrative  burden  on  beneficiaries  and 
strengthened 
administrative  costs  as  well  as  to  avoid  duplication  of  audits  and  management 
verifications of the same expenditure declared to the Commission. 

to  reduce 

ADMINISTRATIVE COSTS 

Administrative  costs  represent  approximately  1.2–1.5%  of  the  total  EMFAF  public 
contribution  under  shared  management.  The  bulk  of  these  costs  arises  from  fulfilling 
reporting  and  auditing  obligations.  Administrative  costs  and  benefits  are  unevenly 
distributed across stakeholder groups: 

•  Managing Authorities and Intermediate Bodies bear the majority of recurrent 
administrative costs (labour, IT, and control mechanisms) but benefit from long-
term  system-level  efficiency  for  example  through  simplified  verification  and 
integrated IT tools. 

•  Project Beneficiaries experience reduced reporting load under SCOs  during the 
implementation. However, SCO require more effort in the preparation phase due to 
adaptation costs for digital tools and audit requirements. Respondents of the survey 
were quite positive. 67% responding the stakeholders survey stated that costs 
if administrative work are reasonable relative to  funding  value. However  Small-
Scale  Coastal  Fisheries  representatives  consider 
the  administrative  most 
burdensome. Most (63%*38) of the survey respondents spent more than three days 
on the application process, plus external costs for 31%, but a large majority (67%) 
considered the total cost reasonable compared with the amount of support received 
(compared with 10% who disagreed). Application processes tend to be more time- 
consuming for beneficiaries other than businesses (producer organisations (POs), 
research,  local  action  groups  setting  up).  Only  50%  of  respondents  other  than 
private  enterprises  agreed  that  the  application  costs  were  reasonable,  and  28% 
disagreed. The most negative assessments came from Research centres and POs  
•  Commission  and  EU-level  bodies  benefit  from  simplified  monitoring  through 
Infosys and data transparency, with reduced duplication in audit and reporting 
tasks. 

According  to  the  supporting  study,  future  EU  funds  regulations  should  include  flexible 
funding  mechanisms  that  allow  for  rapid  reallocation  of  resources  in  response  to 

38   French  outermost  regions  were  over-  represented  in  the  sample  and  provided  significantly  different 
answers from the rest of the respondents (see Annex V. Synopsis report). They are not included in the 
overall figures represented in the table. Their answers are coherent with the analysis above but indicate a 
heavier  administrative  cost,  which  could  be  related  to  the  fact  that  a  large  share  of  this  group  of 
respondents applied for investments. 82% of them agreed that applications costs were reasonable against 
6% who disagreed. 

36 

 
 
unforeseen (external) crises, such as economic downturns or environmental emergencies. 
Finally,  the  evaluation  recommends  that  future  programs  should  focus  on  reducing 
administrative burdens, providing more targeted technical assistance, and ensuring that the 
application and reporting processes are straightforward and user-friendly.  

The recent study on the Assessment of the administrative costs and burden of CPR funds 
2021-202739, found that the average administrative costs (i.e., costs for all tasks assigned 
to authorities to prepare and implement programmes) are estimated at 4.84% of allocated 
funds. ERDF, ESF+, and multi-fund programmes show lower costs, and Interreg, EMFAF, 
and HOME Funds report higher and more variable figures. The most resource-intensive 
tasks remain project selection and verification. Programmes with limited allocation have 
on average significantly higher costs per million EUR spent. The elevated costs in these 
programmes  are  attributable  to  their  complex  governance  structures,  cross-border 
requirements,  and,  in  the  case  of  EMFAF,  smaller  average  programme  budgets  which 
increase per-unit administrative intensity. On the administrative burden, the same study 
shows that the application process for ERDF, ESF+, Cohesion Fund, and EMFAF shows 
burden reductions of 42%, 53%, 89%, and 77%, respectively. 

The EMFF evaluation study also finds that the performance of the result indicators system 
was not fully optimal40 mainly due to the fact that the definition of the context and result 
indicators,  part  of  a  more  complex  monitoring  and  evaluation  system,  was  set  up  after 
adoption  of  the  operational  programmes  leading  to  poor  target-setting  in  2014-2015, 
raising challenges with the collection of reliable data.  

Notwithstanding some room for improvement overall the situation under the EMFAF has 
improved considerably through the early development of indicators in consultation with 
the  Member  States,  the  provision  of  guidance  on  the  indicators  and  the  performance 
framework  methodology  for  target  setting,  establishing  a  more  flexible Monitoring  and 
Evaluation Framework (see Annex VII).  

Thus,  the  EMFAF  is  expected  to  provide  more  reliable  data  and  show  more 
concretely how the Fund contributes to the objectives of the CFP as well as to the 
horizontal policy priorities of resilience, green and digital transition. These contributions 
are expected to become clearer in the context of the retrospective evaluation. 

4.3 OVERALL COST-EFFECTIVENESS OF THE FUND  

A cost-benefit analysis is not appropriate for EMFAF interventions because many of its 
objectives—such  as  environmental  protection,  regulatory  compliance,  and  social 
outcomes—cannot be easily monetized. Instead, cost-effectiveness analysis is preferred, 
as  it  focuses  on  achieving  the  best  results  for  the  resources  invested,  aligning  with  the 
fund’s emphasis on effectiveness, efficiency, and qualitative outcomes rather than strict 
economic  returns.  However,  in  the  absence  of  results  of  the  EMFAF  at  the  date  of  the 
evaluation it was not possible to provide a cost-effectiveness assessment. At the time of 
the  retrospective  evaluation  more  elements  may  emerge  for  feeding  any  cost-effective 
analyses and the Commission will take steps to advance on such analysis in the future. 

39 https://op.europa.eu/en/publication-detail/-/publication/1cacec43-d187-11f0-8da2-01aa75ed71a1 
40    See  also  Common  Monitoring  and  Evaluation  System for  the  European  Maritime  and  Fisheries  Fund 
reports 2017 (2018) and 2021 (2022), as required by the EMFF Regulation 508/2014, Article 107. 

37 

 
 
The  supporting  study  finds  though  that  21  Member  States  (out  of  26  with  a  national 
EMFAF programme) anticipate that the EMFAF will achieve more than the EMFF. The 
supporting study also indicates that operations are implemented at a reasonable cost to the 
administration and beneficiaries, but the data available also suggests a possible increase of 
the administrative costs for administrations in Member States, compared to the EMFF.  

Overall,  based  on  the  evaluation  findings,  the  administrative  burden  resulting  from  the 
programming,  management,  and  implementation  of  the  EMFAF,  is  assessed  to  be 
reasonable, compared with what has been observed for the EMFF and other  CPR 
Funds, during the previous programming period.  

The administrative burden for beneficiaries is also considered reasonable by most of the 
survey respondents in the supporting study and seems stable overall, with almost an even 
breakdown of the respondents to the target group survey between those who assess it has 
decreased, those who assess it is stable and those who assess it has increased. For Member 
States with low EMFAF budget, however, in particular the landlocked countries, the 
administrative  costs  remain  proportionately  significantly  higher  than  the  average. 
Specifically, the five Member States with the smallest public contributions (including three 
of the four landlocked countries) spent on average eight times more than other Member 
States  per  million  euros  of  EMFAF  public  contribution,  and  almost  2.5  times  more  for 
management and implementation. Nevertheless, the cost-effectiveness of the money spent 
under shared management cannot be assessed at this stage considering the small number 
of projects implemented.  

Figure 15: Distribution of recurrent administrative costs per Member State in relation with the total public 
contribution 

Source: supporting study, based on the survey of managing authorities 

4.4 COHERENCE  

The assessment of coherence considers the extent to which the EMFAF is internally and 
externally  coherent.  In  practice,  this  means  how  well  different  interventions  that  share 
common objectives work together. 

38 

 
 
ASSESSMENT OF THE INTERNAL COHERENCE 

The internal coherence of the EMFAF relates both to the internal coherence of the Fund 
interventions and the alignment of the EMFAF with the policy framework. The analysis 
focuses on the extent to which the different EMFAF interventions are complementary and 
coherent with the objectives and priorities of the CFP and the extent to which the EMFAF 
different interventions generate synergies and/or compensate trade-offs between them. 

As explained the EMFAF is the main financing instrument for the implementation of 
the  CFP.  The  CFP  aims  to  ensure  that  fishing  and  aquaculture  activities  are 
environmentally sustainable in the long-term and are managed in a way that is consistent 
with  the  objectives  of  achieving  economic,  social  and  employment  benefits,  and  of 
contributing to the availability of food supplies41. 

The alignment between the EMFAF and the CFP is reflected in the Member States EMFAF 
programme design,  both in  terms  of the  types of actions  included and the allocation of 
resources, as well linked reporting on these objectives through Transmission of Data and 
Infosys reports. 

The EMFAF supports the CFP objectives through the following main actions: 

•  Fostering sustainable fishing activities: support to the implementation of the landing 

obligation, promoting the use of selective gears, etc. 

•  Providing conditions for the fisheries sector to be competitive: support to improving 
quality  of  catches,  to  increase  energy  efficiency  to  reduce  operating  costs,  for  the 
development of skills and knowledge, etc. 

•  Supporting the structural management of fisheries and fishing fleets: promoting 
the 
balance  between  fishing  capacity  and  fishing  opportunities,  supporting 
implementation of conservation measures, including through operations of permanent 
and temporary cessation of fishing activities. 

•  Supporting  sustainable  aquaculture:  support  to  environmental  sustainability, 

productive investments, innovation, aquaculture stock insurance schemes, etc. 

•  Promoting an efficient market for fishery and aquaculture products: supporting 
the structuring of the sector and processing and marketing operations (e.g., structuring 
of the market through producer organisations, develop new market outlets, add value 
to products, etc.). 

•  Contributing  to  a  fair  standard  of  living  in  coastal  and  rural  areas:  supporting  the 

sustainable development of blue economy. 

•  Collecting scientific data to underpin management of economic activities: support 
data collection in line with the Data Collection Framework through shared and direct 
management and data collection operations to strengthen the sustainable management 
of the marine environment under direct management (e.g. EMODnet42). 

41   Article 2 of the CFP Regulation. 
42   https://emodnet.ec.europa.eu/en 

39 

 
 
•  Supporting the control of fishing activities: support to Member States and operators 

to implement the fisheries control system (e.g., investments in digital tools). 

The regulatory framework reinforces the internal coherence between the EMFAF and the 
CFP objectives by:  

•  Possibility of setting targets to specific CFP areas, such as biodiversity protection and 

minimum budget allocations for data collection and control. 

•  Establishing higher intensity aid for certain types of actions and beneficiaries, as 
provided by Annex III of the EMFAF Regulation. This includes operations related to 
the  landing  obligation  for  instance  (the  maximum  aid  intensity  rate  for  operations 
improving size selectivity of fishing gear is established at 100%), support for small-
scale coastal fisheries (maximum aid intensity rate of 100%) and support for ORs and 
other remote islands (maximum aid intensity of 85% vs 50% for other geographical 
areas). 

•  Establishing means to reinforce monitoring of EMFAF contributions to specific 
CFP areas. The contribution of the EMFAF to different CFP areas is tracked through 
the use of markers that are reported on a regular basis within the MEF. 

Member States’ budget  allocations further support this coherence by allocating budgets 
often  exceeding  the  mandatory  minimum  allocations.  For  instance,  while  the  financial 
framework mandates that at least 15% of each national allocation be allocated to fisheries 
control and data collection, data from national EMFAF programmes indicates that SO 1.4 
(data collection and control) received the highest  planned budget allocation, accounting 
for 21% of the total budget allocation for shared management.  

During  the  implementation  of  the  Fund,  internal  coherence  is  maintained  through  the 
application  of  eligibility  criteria  and  compliance  requirements  that  ensure  that  EMFAF 
beneficiaries and their projects adhere to CFP rules.  

Regarding direct management, the interim evaluation of the implementation of the direct 
management component of the EMFF has not revealed any major internal incoherence but 
recommends to develop more synergies with Horizon Europe and EMFF and to reinforce 
the development of a coordinated approach to maritime issues.  

ASSESSMENT OF THE EXTERNAL COHERENCE  

The  assessment  of  external  coherence  considers  the  complementarities  and  synergies 
between the EMFAF and other EU funding instruments, legislation and strategies, such as 
the  European  Green  Deal,  the  Habitats  and  Birds  Directives,  the  Marine  Strategy 
Framework Directive (MSFD), as well as international obligations and commitments such 
as the Paris agreement. 

The EMFAF aligns with and complements the other EU funds. Article 5(3) of the CPR 
mandates coordination, complementarity, and synergies between EU funds, and while the 
instruments’  legal  bases  and  programming  documents  include  provisions  to  foster 
complementarity between EMFAF and the other funds covered by the CPR, the degree of 
coherence  and  complementarity  varies  across  funds,  with  the  strongest  synergies  seen 

40 

 
between  the  EMFAF,  ERDF43  and  ESF+44.  The  EMFAF  has  the  same  rules  of 
management  and  programming  as  the  ERDF  and  ESF+,  and  includes  a  possibility  of 
implementing the multi-fund approach under the CLLD, even though there is very limited 
uptake across Member States. The complementarities between the EMFAF and the ERDF 
investments are particularly emphasised in the support to coastal communities, while with 
ESF+  there  are  synergies  on  the  support  to  skills,  training,  working  conditions  and 
attractivity of the sector. 

There  is  good  coherence  and  complementarity  between  the  objectives  of  the  Common 
Agricultural  Policy  (CAP)  funds45  but  some  overlapping  priorities  could  lead  to 
challenges in implementation: originally being an integral part of the CAP, the EMFAF 
has synergies with the CAP when it comes to providing food and it is a vital contributor to 
the overarching food security ambitions, maintaining a well-functioning internal market 
for fisheries and aquaculture products and sustainability (Common Market Organisation, 
similar  to  agriculture).  On  rural  development,  synergies  and  overlap  are  possible  when 
aquaculture activities are involved and/or coastal areas are concerned, but such support is 
still limited, and more efforts are necessary to reinforce these synergies. 

Overall good coherence is demonstrated between the EMFAF and Horizon Europe46 with 
good examples of synergies, but there is scope to improve coordination between the funds, 
in  particular  for  cluster  6  on  ’food,  bioeconomy,  natural  resources,  agriculture  & 
environment’. There is  also  a dedicated Mission  under Horizon Europe to ’Restore our 
Ocean and Waters by 2030’.  

There is potential to establish synergies with external action instruments, as the EMFAF 
has  an  international  cooperation  angle.  Nevertheless,  these  complementarities  are  not 
identified, which shows that there is still a lot of room for improvement. The same applies 
to the complementarity between the EMFAF and the AMIF47 where synergies can occur 
regarding  maritime  surveillance,  however  this  is  still  a  dimension  which  needs  further 
development. 

There  is  relatively  good  complementarity  between  the  EMFAF  and  the  LIFE 
programme48 as the EMFAF supports operations to protect and restore marine biodiversity 
and ecosystems in the framework of sustainable fishing activities.  

Finally, there is strong potential for synergies between the EMFAF and InvestEU as both 
funding  instruments  can  be  complementary,  and  the  Commission  is  already  working 

43   Regulation  (EU)  2021/1058  of  the  European  Parliament  and  of  the  Council  of  24  June  2021  on  the 

European Regional Development Fund and on the Cohesion Fund. 
44   Regulation (EU) 2021/1057 establishing the European Social Fund Plus. 
45   Regulation (EU) 2021/2115 – rules on support for strategic plans to be drawn up by Member States under 
the  common  agricultural  policy  (CAP  strategic  plans)  and  financed  by  the  European  Agricultural 
Guarantee Fund and by the European Agricultural Fund for Rural Development . 

46   Regulation (EU) 2021/695 of the European Parliament and of the Council of 28 April 2021 establishing 
Horizon Europe –  the Framework  Programme for Research and Innovation, laying down its rules for 
participation and dissemination, and repealing Regulations (EU) No 1290/2013 and (EU) No 1291/2013. 
47  Regulation (EU) 2021/1147 of the European Parliament and of the Council of 7 July 2021 establishing 

the Asylum, Migration and Integration Fund. 

48   Regulation (EU) 2021/783 of the European Parliament and of the Council of 29 April 2021 establishing 
a  Programme  for  the  Environment  and  Climate  Action  (LIFE),  and  repealing  Regulation  (EU)  No 
1293/2013. 

41 

 
 
together with the EIB in order to identify these possibilities and promote them further with 
the managing authorities. 

Coherence  is  further  reinforced  through  partnership  agreements  prepared  by  Member 
States  for  the  2021-2027  period,  which  include  orientations  on  the  efficient  use  of  the 
different EU funds, ensuring complementarities and synergies between them. In line with 
the mandatory template included in the CPR, complementarities and synergies are defined 
in the Partnership Agreements and then further detailed in the programmes. The principle 
of partnership - a key feature in the implementation of EU structural funds - builds on the 
multi-level governance approach and ensures the involvement of regional, local, and other 
public authorities, civil society, economic and social partners, research organisations and 
universities.  Member  States  must  involve  these  partners  throughout  the  preparation, 
implementation and evaluation of their EMFAF programme.  

The  implementation  of  the  partnership  principle  is  usually  well  respected  in  EMFAF, 
mainly due to the relatively small number of stakeholders (compared to other funds like 
ERDF). Consultations during negotiation and periodical  consultations foreseen by CPR 
are  carried  out  without  major  issues.  As  in  other  ESI  Funds,  EMFAF  programmes  are 
prepared through consultations among relevant stakeholders, and they are also represented 
in the Programmes’ Monitoring Committees.  

The  external  coherence  of  the  EMFAF  with  the  other  EU  policies  is  reflected  in  the 
importance of the contribution of the EMFAF to tackling climate change in line with 
the European Green Deal and the EU’s commitments to implement the Paris Agreement. 
The  EMFAF  contributes  to  reducing  the  carbon  footprint  of  fisheries  and  aquaculture 
through different types of actions, including replacing and modernising engines of fishing 
vessels, shifting to energy-efficient production methods in fisheries and aquaculture (e.g., 
CO2-efficient technology for the propulsion of fishing vessels, use of renewable energy in 
aquaculture, etc.). However, the use of EMFAF for these types of action is subject to strict 
eligibility rules to avoid overcapacity and overfishing, notably by allowing support only 
for fishing vessels that are part of a fleet segment for which fishing capacity is in balance 
with its fishing opportunities. 

The  EMFAF  also  aligns  with  the  Farm  to  Fork  Strategy  by,  supporting  sustainable 
(environmental,  economic  and  social)  fishing  and  aquaculture  activities,  biodiversity 
protection  and  restoration,  carbon  emissions  reduction  and  improvement  of  products 
quality. Finally, the EMFAF plays a role in preserving and restoring ecosystems and 
biodiversity by supporting environmental legislation, including the Habitat and Birds 
Directives  and  the  MSFD,  and  actions  within  the  Natura  2000  network.  The  EMFAF 
contributes  to  protecting  and  restoring  biodiversity  by  providing  support  to  promote 
circular  economy  or  activities  with  environmental  services  (e.g.  pond  farming); 
sustainable, low-impact  and low-carbon  fishing  activities and aquaculture practices  and 
sustainable and energy-efficient aquaculture production.  

4.5.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE AND TO WHOM?  

EU ADDED VALUE 

EU added value is the value that results from an EU intervention and that is additional to 
the value that Member States would have otherwise created individually.  

42 

 
Given the limitations related to the limited implementation, the absence of counter-factual 
analysis and the lack of mature data to measure the impact of the Fund, qualitative evidence 
in the study is used from the previous programming period and through interviews carried 
out with national stakeholders in the context of the evaluation, which provide preliminary 
indications regarding the EU added value of the EMFAF.  

With the CFP being an exclusive competence, the role of the EU in implementation 
and  funding  is  indispensable.  The  general  notion  of  the  common  policy,  the  mobile 
nature of fisheries, and the duty to manage the resources responsibly, means that without 
adequate oversight Member States would not be incentivised to manage the common 
resources.  Hence,  EU  intervention  is  essential  to  ensure  a  coherent  approach,  in 
complementing  to  the  strict  implementation  of  directly  applicable  legal  requirements, 
striving for a level playing field across all EU sea basins. EU funding opportunities are 
complementary  to  national  means,  but  importantly  also  help  to  strictly  frame 
conditionalities of use, in line with the common objectives.  

Similarly,  beyond  Union  waters,  EU  funds  provide  the  framework  for  following  up  on 
international  obligations,  but  also  protect  economic  interests  in  fisheries  worldwide. 
Again, leaving this up to individual Member States would likely not lead to desirable 
outcomes, with a lack of consistency in approach and the prioritisation of Member 
States aspirations rather than EU goals. 

Overall, the added value of the EMFAF is to promote sustainable fishing and aquaculture 
practices  and  to  sustain  the  competitiveness  of  fishing  and  aquaculture  enterprises.  In 
particular, through specific investments under Priority 3, EMFAF aims at supporting the 
coastal  fishing  communities  and  local  aquaculture  communities,  improving  their 
generational  renewal  and  enhancing  innovation  in  the  local  fisheries,  aquaculture  and 
maritime economies. The transitions (digital, environmental) that blue economy actors are 
facing  need to  be tackled at  international  level,  and the EMFAF  – through its different 
management  modes  –  makes  the  necessary  link  between  European  and  (sub)national 
interventions.  

Sustainable  fishing  means  catching  no  more  fish  than  stocks  can  reproduce  each  year. 
Thanks to the investments made by fishers and national administrations, and through the 
support  of  the  EMFF  and  in  continuation  of  the  EMFAF,  fishing  has  become  more 
sustainable and far fewer stocks are now overfished in the EU. In 2003, most stocks of 
commercial interest to the EU were heavily overfished (68% above the maximum rate in 
the Northeast Atlantic). The rate has since fallen, reaching the lowest value in 2021 at 24% 
below  the  maximum  rate.  In  the  Mediterranean  and  Black  Seas,  the  situation  has 
improved but the rate of overfishing is still too high, and more efforts are needed to 
restore  stocks  to  healthy  levels.  These  positive  trends  in  stock  recovery  would  not 
have  been  observed  without  EU  funds  aiding  implementation.  The  EMFF  and  in 
continuation the EMFAF helps creating a robust science base, incentivising fleet capacity 
reduction,  improving  selectivity  of  fishing  gear,  and  helping  to  implement  measures  to 
protect vulnerable marine species and habitats.  

Regarding why the EU should provide funds to implement the CFP instead of focusing 
solely on Member States’ contributions, there are several reasons supporting this approach:  

•  EMFAF promotes a level playing field for all EU stakeholders operating in the blue 

economy sectors.  

43 

 
•  All Member States receive support and are incentivized to support research, data 
collection efforts, fisheries control and facilitate the adoption of sustainable fishing 
practices.  

•  To ensure Member States’ compliance with CFP rules, the EU needs an effective 
system of control, inspection and enforcement. This should also include financial 
support  to  Member  States  for  them  to  develop  and  implement  comparable  and 
effective systems for control, inspection, and enforcement that would ensure a level 
playing field between Member States on fisheries control.  

•  To ensure implementation of the CFP the EU needs to support Member States in 
development of efficient data collection as an essential part of the establishment of 
a high-quality fisheries governance framework. 

•  The  Fund  works  as  a  leverage  for  the  negotiation  and  the  consequent 
implementation of the annually agreed fishing opportunities. As a matter of fact, 
the implementation of the Council agreements requires financial contributions to 
support  compliance  measures,  capacity-building  initiatives,  and  sustainable 
fisheries  management  efforts  at  the  EU  and  international  levels  (e.g.  GFCM49, 
WestMed MAP50). 

Based  on  stakeholders’  and  the  Managing  authorities’  feedback  in  the  context  of  the 
evaluation, there are additional benefits for the EMFAF: 

•  Having  a  common  fund  ensures  a  unified  approach  to  supporting  the  fisheries  and 
aquaculture sectors. This unified approach is crucial for the balanced sustainability and 
resilience  aimed  for  under  the  CFP  and  European  Green  Deal.  In  that  sense,  the 
EMFAF extends the coverage of EU policy objectives at the national level and offers 
increased  benefits  compared  with  the  EMFF,  according  to  managing  authorities’ 
feedback.  

•  The  EMFAF  emphasises  EU-added  value  by  enhancing  coordinated  efforts  and 
shared benefits across Member States. This focus makes interventions more effective 
and efficient compared with what Member States could achieve through national-level 
actions  alone.  Managing  authorities  responding  to  the  survey  indicated  that  the 
EMFAF marked a significant improvement over its predecessor in terms of EU-added 
value, reinforcing the effectiveness of a coordinated EU-level approach. 

•  The  EMFAF  fosters  networking  and  the  sharing  of  best  practices  among 
Member States,  creating  an  environment  of  mutual  learning  and  improvement  that 
national-level interventions are less likely to replicate. The EMFAF (or its predecessor) 
has  established  permanent  structures  and  platforms  for  collaboration  among 
Member  States.  This  includes  initiatives  like  FLAGs  and  FAMENET,  which  have 
diversified  local  tourism  and  supported  activities  such  as  seaweed  cultivation, 
according to stakeholders interviewed. 

•  The drafting of an action plan for the outermost regions and the allocation of resources 
reflects  the  unique  benefits  of  EU-level  strategic  planning.  This  strategic  approach 
allows the national EMFAF programme to address specific regional needs effectively 
by leveraging collective resources and expertise. Feedback from managing authorities 

49   www.fao.org/gfcm/en/ 
50   Regulation (EU) 2019/1022 of the European Parliament and of the Council of 20 June 2019 establishing 
a  multiannual  plan  for  the  fisheries  exploiting  demersal  stocks  in  the  western  Mediterranean  Sea  and 
amending Regulation (EU) No 508/2014. 

44 

 
 
indicates  that  this  strategic  EU-level  planning  has  enabled  the  EMFAF  to  achieve 
outcomes that would have been difficult or impossible for individual Member States to 
accomplish alone. 

Below,  two  examples  from  the  EMFF  illustrate  how  the  Fund  delivers  on  the  ground, 
indicating  that  the  EMFAF,  especially  due  to  its  new  design,  can  deliver  similar 
achievements. 

Text box 2: CLLD achievements under the EMFF 51 

Community-led Local Development (CLLD) was funded under the EMFF (2024-2020) 
in fisheries and aquaculture areas for the second programming period, and continues to 
receive  funding  under  the  EMFAF.  Approximately  10%  of  the  EMFF  budget  was 
allocated  to  CLLD  -  and  managed  by  348  Fisheries  Local  Action  Groups  (FLAGs). 
Together, these FLAGs financed 14,700 local projects in 19 Member States.  

In April 2024, FAMENET collected and analysed information to ascertain what CLLD 
under  the  EMFF  had  achieved  in  fisheries  and  aquaculture  areas.  The  results  of  the 
analysis  of  data  reported  by  Managing  Authorities  in  Infosys,  and  of  information 
provided  by  149  FLAGs  that  responded  to  a  survey  on  their  achievements  under  the 
EMFF demonstrate the following:  

Three  common  result  indicators  were  used  for  EMFF  CLLD:  jobs  created,  jobs 
maintained and businesses created. Data reported in Infosys by December 2023 for the 
EMFF funding period reveals: 

•  CLLD was by far the most effective EMFF measure for job creation. 4,245 new 
jobs  were  reported,  almost  five  times  as  many  jobs  created  than  under 
aquaculture  investments  (the  second  most  important  measure  for  job  creation 
with 880 jobs created). 

•  10,325 jobs were reported to have been maintained with FLAG support. This put 
CLLD  as  the  second  most  important  measure  for  maintaining  jobs  (behind 
fishing infrastructure with 19,250 jobs maintained).  

•  1,020  new  businesses  were  created  with  CLLD  support.  CLLD  was  the  only 

measure to report on the creation of new businesses. 

Qualitative information collected offers examples of these new businesses, ranging from 
the development of processing facilities to make use of unwanted by-catch, to the setting 
up  of  one  of  Europe’s  first  commercial  coral  farms  and  the  creation  of  Spain’s  first 
sailing school for people with disabilities.  

On  top  of  these  result  indicators  that  Member  States  were  obliged  to  report  on, 
FAMENET’s survey to FLAGs revealed a range of additional results:  

•  FLAGs  had  also  helped  local  companies  to  diversify  revenue  sources.  On 
average, responding FLAGs had each supported 12 companies to develop new 
sources of revenue through diversified activities. Extrapolated to all 348 FLAGs, 
this would imply over 4,000 companies that had developed new revenue sources.  
•  Local supply chains for fish and seafood were strengthened. On average, FLAGs 
had  supported  the  creation  of  two  new  local  sales  channels  in  each  area  and 
introduced or boosted sales of local fish in three existing local sales channels. In 

51   https://preview.mailerlite.com/c4f5n8g1j4/2631223102519908789/l6w0/ 

45 

 
 
total,  just over 600 sales channels had been  created or  extended their offer of 
local fish. Extrapolation to the whole FLAG community would put this figure at 
around 1,400 new or improved sales channels.  

•  Over  1,300  new  and/or  improved  activities  and  services  were  reported  in  the 
responding FLAG areas (on average 10 per local area), helping to improve the 
quality of life in these communities.  
FLAGs reported almost 700 actions to contribute to good environmental status, 
an extrapolation to the whole EMFF FLAG community would point to around 
1,600 environmental actions.  

•  FLAGs also reported over 700 local entities that had been supported to improve 
resource efficiency. Extrapolated to all FLAGs, this would imply around 1,600 
entities  that  have  introduced  measures  to  save  water,  energy  or  other  natural 
resources. 

Finally,  a  key  achievement  of  CLLD  has  been  to  generate  local  participation  in  the 
development and coordination of blue economy activities and increased collaboration 
between blue economy stakeholders. FLAGs estimated to have mobilised around 120 
people each to provide input to their local development strategies; extrapolated to all 
348 FLAGs, this would imply over 40 000 people EU-wide. They also estimated to have 
mobilised  an  average  of  520  young  people  each  for  education  and  awareness-raising 
activities, e.g. linked to the local fisheries sector, marine conservation, coastal heritage, 
etc. (extrapolation: 180,000 young people mobilised). 

The results of such networking, capacity building and collaboration can be seen through, 
for example: 

•  Four new or strengthened networks reported in each FLAG area. 
•  24%  of  all  projects  involving  stakeholders  from  two  or  more  sectors  (50%  of 

• 

which involve the fisheries and/or aquaculture sector) 
Small-scale fishers have been mobilised to play a leading role in developing the 
blue economy and have implemented approximately 23% of all CLLD projects. 
 Improved local governance in many areas, though more participative decision-
making and/or better coordination of blue economy activities. 64% of FLAGs 
reported  improved  governance  versus  24%  that  did  not  feel  governance  had 
improved due to the FLAG (12% no information). 

•  Cooperation  and  transfer  of  knowledge  across  the  EU  with  three  cooperation 

projects per FLAG with other fisheries and aquaculture areas. 

•  1,520  local  innovations  enabled  (50%  of  which  involving  product/service 
innovation, followed by process innovation, new technologies/digitalisation, and 
social innovation).  

•  New beneficiaries have gained access to EU funding: 30% of project promotors 

received EU funding for the first time, thanks to the FLAG.  

Despite significant differences from one FLAG to another, the overall picture of CLLD 
indicates that a relatively small amount of money (just under €2M per FLAG) can go a 
long way.  

FLAGs responding to the FAMENET survey reported funding an average of 44 local 
projects each and estimated that 15,100 people benefited per FLAG area. While “persons 

46 

 
  
 
benefiting” is subject to interpretation, the FLAGs’ estimation would imply that over 5 
million people benefited from CLLD projects funded by the EMFF.  

Under  the  EMFAF  (2021-2027),  not  all  LAGs  are  selected  and  operational  yet. 
However, just over 300 FLAGs are expected, in 18 Member States. The overall budget 
is broadly similar to that of the EMFF and FLAGs have gained in experience, leading to 
expectations  that  some  good  results  can  be  achieved  again  by  the  end  of  the 
programming period. 

Text box 3: Pesca tourism: a cooperation opportunity for mediterranean fisheries 

In  the  fishing  sector,  fishers  often  struggle  to  diversify  their  income.  In  the 
Mediterranean,  the  EMFF  addressed  this  problem  by  supporting  FLAGs  in  training 
fishers to diversify their incomes through pescatourism. Pescatourism comprises non-
commercial fishing activities that use marine aquatic resources for recreation, tourism, 
or sport. Pescatourism allows fishers the opportunity to demonstrate their way of life to 
the  general  public,  sharing  the  joy  of  preparing  the  fresh  catch  and  enjoying  a  meal 
together with tourists onboard their boat. By engaging in pescatourism fishers also keep 
their income steady, even in the harder fishing months of July and August. 

Recent changes to regulations on pescatourism in Greece have allowed fishermen to take 
tourists on their boats, boosting their income and offering an alternative to the practice 
of scrapping boats, which reduces the fleet and impacts Greece's rich maritime heritage. 
However, pescatourism has had a slow start, since fishers are unfamiliar with how to 
provide tourism services and many tourists are unaware of pescatourism.  

To bridge this gap, 18 FLAGs joined forces to  transform  pescatourism into a unique 
'slow  tourism'  experience,  with  the  support  of  the  EMFF.  The  FLAGs  launched  a 
comprehensive approach to promote pescatourism. They started by building rapport with 
fishermen through port visits and discussions. Informative sessions and surveys gauged 
fishermen's  knowledge,  interest,  and  obstacles.  As  interest  rose,  FLAGs  organised 
training on legalities finances, and marketing. 

To  support  fishers  even  further,  the  FLAGs  coordinated  with  Italian  counterparts, 
organising a study visit to learn from Sardinian fishers experienced in pescatourism. The 
visit  allowed  fishers  from  both  countries  to  connect  and  discuss  how  to  operate  a 
pescatourism business, along with the challenges and best practices.  

Increased awareness of pescatourism has breathed new life into the industry. Through 
this project, over 450 fishers explored pescatourism opportunities, while more than 100 
received specific training. In addition, as of September 2023, 48 fishers took steps to 
obtain pescatourism licenses, while 157 fishers are currently engaged in pescatourism 
activities.  

Pescatourism  also  reduces  pressure  on  local  fish  species.  For  example,  during  a 
pescatourism trip, a gillnet fisher sets around 0.5 kilometres of net, compared to around 
5 km for a day of professional fishing. The activity also provides opportunities for youth 
in the sector, preserving vital skills, as well as traditional vessels and the heritage they 
represent. 

47 

 
 
4.6. 

IS THE INTERVENTION STILL RELEVANT?  

To assess relevance, the objectives of the EMFAF are assessed to determine how well they 
reflected  needs  at  the  time  of  adoption  of  the  EMFAF  Regulation  and  if/how  they  still 
reflect current and future needs.  

The EMFAF was prepared in a policy context which was significantly different from the 
one in  which its implementation  started, mostly  due to  the Covid-19  pandemic and the 
impact of Russia’s war of aggression on Ukraine. The EMFAF programmes were prepared 
by taking into account the 2019-2024 political guidelines on the acceleration of the green 
and digital transition, resilience and EU added value. This is demonstrated on the summary 
of each EMFAF MS programme52. Moreover, the general political guidelines to ensure the 
fair transition of the sector, promote innovation and competitiveness53 remain relevant for 
the implementation of the EMFAF.  

The evaluation indicates that EMFAF continues to be a strategic instrument to address the 
EU  policy  priorities  and  national  needs.  The  flexibility  afforded  to  Member  States  to 
programme and reprogramme EMFAF under shared management in line with the changing 
policy context and priorities is a key factor ensuring the strand’s continuous relevance. For 
instance,  extensive  work  was  undertaken  during  the  programming  phase  by  the 
Commission to ensure the Fund’s relevance, including the impact assessment underpinning 
the Fund, the sea basin  needs analysis, as well as Member States’ process of designing 
their  national  EMFAF  programmes,  through  strategic  environmental  assessments,  and 
their SWOT and needs analyses. As demonstrated by the supporting study, the stakeholder 
consultation  on  the  structure  of  the  Fund,  its  priorities  and  objectives  were  positively 
assessed,  confirming  a  positive  perception  of  the  alignment  with  EU  policy  objectives 
including  more  explicit  focus  on  biodiversity  and  the  use  of  selective  criteria  when 
choosing aquaculture projects for instance.  

Since adoption in 2021, the EMFAF has broadened its relevance: 

•  The Fund’s crisis-adaptation flexibility, tested through compensation measures in 
Latvia  and  Cyprus,  has  proven  critical  in  maintaining  competitiveness  during 
market shocks. 

•  Emerging  needs  related  to  decarbonisation,  digitalisation,  and  generational 
renewal  have  become  central  to  the  Fund’s  design,  especially  through  projects 
promoting energy-efficient vessels and smart aquaculture. 

•  The  emphasis  on  innovation  and  research  under  Priority  2  and  3  directly 
addresses the structural weaknesses identified by the European Court of Auditors 
in EU aquaculture competitiveness. 

Sustainable Fisheries and Data (SO 1.1, 1.4, 1.6) directly reflect the EU’s key priorities 
of sustainable resource management, biodiversity protection, and regulatory compliance. 
These areas rightly receive the highest share of funding, ensuring that essential scientific 
data,  monitoring  capacity,  and  conservation  actions  are  supported  across  all  Member 
States.  

52   https://oceans-and-fisheries.ec.europa.eu/funding/emfaf-programmes-2021-2027_en 
53  https://commission.europa.eu/document/download/e6cd4328-673c-4e7a-8683-
f63ffb2cf648_en?filename=Political%20Guidelines%202024-2029_EN.pdf 

48 

 
 
Sustainable  Aquaculture  and  Processing  (SO  2.1,  2.2)  represent  the  Fund’s  strategic 
objective  to  improve  the  EU’s  seafood  security  and  market  competitiveness.  These 
objectives  address  core  needs:  reducing  import  dependence,  driving  innovation,  and 
building value chains with higher sustainability and quality standards. 

Blue Economy and Local Development (SO 3.1) plays a vital but comparatively modest 
role in the Fund’s structure. The smaller financial share reflects the expectation that other 
EU instruments, such as the ERDF and the CAP, will also contribute to coastal and rural 
diversification. 

Given increasing socio-economic pressures on coastal populations—aging, depopulation, 
and climate vulnerability—the current funding level should be closely monitored. If these 
pressures continue to grow, future adjustments may be needed to ensure CLLD receives 
the scale of support required to sustain viable and resilient coastal communities. 

International Ocean Governance (SO 4.1) receives a relatively small budget reflecting 
its specific, strategic focus rather than broad-scale investment. This funding supports the 
EU’s  role  in  global  ocean  management,  international  cooperation,  and  crisis  response, 
responding to needs like cross-border conservation, maritime security, and participation in 
international bodies and conventions. 

Overall, the allocation of EMFAF resources per SO broadly mirrors the most pressing and 
strategic  sectoral  needs  identified  by  the  Commission,  Member  States,  and  stakeholder 
consultations. The Fund’s architecture allows for targeted intervention in the highest-need 
areas while maintaining flexibility to address unexpected crises and regional differences. 
Effectiveness  in  meeting  all  needs  will  ultimately  depend  on  adaptive  management  as 
priorities evolve over the programming period. 

The  evaluation  found  that  managing  authorities  appreciated  that  their  programmes 
considered regional specificities, which ensured they were tailored to the unique conditions 
and  needs  of  local  communities.  The  delays  in  implementation  make  it  hard  to  assess 
whether the expected results match those anticipated in the intervention logic of the Fund 
since  there  are  limited  results  to  date,  which  may  even  be  influenced  by  the  level  of 
progress  made  by  particular  individual  Member  States.  Yet,  the  review  of  the  national 
EMFAF  programmes  confirms  that  the  EMFAF  support  is  foreseen  to  address  each 
specific  objective  activated  in  the  programme,  with  Member  States  providing  clear 
justifications for not selecting certain specific objectives. These decisions often stemmed 
from lessons learnt from previous programming phases, allowing for a strategic focus on 
the most pertinent objectives, ensuring a high level of relevance. 

There was almost unanimous agreement among the managing authorities that the national 
EMFAF programmes were drafted to leave room for uncertainty, either to a great or to 
some extent (just one managing authority disagreed), which shows that the new structure 
is  more  suited  to  adapt  to  changing  needs.  The  lessons  learnt  from  the  previous 
programming period, not least the knowledge that the national EMFAF programmes may 
need to be adapted in the event of crises (like COVID-19 or the Russian military aggression 
on  Ukraine),  has  been  built  into  the  EMFAF  Regulation  both  structurally  (with  the 
possibility for funding to compensate for unexpected events ) as well as materially (i.e. in 
the  national  EMFAF  programmes  themselves,  which  have  provisions  for  unexpected 
events). Indeed, the review of the national EMFAF programmes confirmed that 20 Member 

49 

 
States have specifically built-in flexibility to allow for changes in needs and uncertainty 
over the course of the programming period. 

Meanwhile, the two-year work programme delivered under (in)direct management is, by 
virtue of being shorter in time span, also able to adapt to emerging needs on a more regular 
basis and serves as a complement to the national EMFAF programmes in addressing needs 
that transcend national boundaries.  

Representatives of the EU fishing industry emphasised in the context of the evaluation, the 
importance  of  practical  adaptability  (i.e.  responding  to  emerging  unforeseen  needs), 
especially  during  crises  like  COVID-19  or  geopolitical  events  like  the  Russian  war  of 
aggression in Ukraine. While the EMFAF showed flexibility in the cases mentioned above, 
specific events, like the non-renewal of protocols implementing fishing agreements with 
third countries (e.g. Morrocco), were cited as a limitation.  

There is however room for improvement in addressing the EU policy priority related 
to the social dimension and how this was taken on board in the development of the legal 
proposal for the EMFAF Regulation54. Since the social aspects and challenges that the Fund 
seeks to address are expected to increase, this is a shortcoming and implies social dialogue 
continues to be critical to address sectoral needs. 

54   The opinion of the European Economic and Social Committee was that the EMFAF was the Commission 

proposal was not based on a detailed economic and social impact assessment. 

50 

 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  CONCLUSIONS 

EU  funding  for  maritime,  fisheries,  and  aquaculture  policy  has  evolved  gradually  over 
time. The results and impacts from the funding described often take years to materialise, 
making  it  difficult  to  draw  a  clear  line  between  results  of  different  funding  periods,  as 
results are also influenced by external factors beyond the programmes’ control. This is why 
the  first  general  conclusion  which  emerges  from  this  evaluation  is  that  the  regulatory 
deadline to deliver the evaluation was formulated rigidly and did not take into account the 
delay in the adoption and the implementation of the EMFAF, in particular for the shared 
management  strand.  In  consequence,  a  conclusive  analysis  of  the  Fund’s  intermediate 
results, which should feature a mid-term evaluation, was not possible. The assessment of 
effectiveness and efficiency of the changes introduced in the design of the EMFAF remain 
promising but not definitive due to the early stage of the implementation.  

Nonetheless, it is possible to draw some conclusions and lessons learnt to be taken into 
account for the ongoing implementation as well as for the preparation of the future funding 
instruments. The Commission services have started reflections55 on how impact pathways 
can be created for the future evaluation of the Fund, assessing effectiveness and efficiency 
through qualitative methods like case studies and by linking the detailed reporting through 
Infosys with the scientific and Commission reports concerning the implementation of the 
CFP  and  the  blue  economy.  The  retrospective  evaluation  can  be  built  on  several  data 
sources provided during the ongoing programming period: 

Infosys reports and additional analyses of specific sectors. 

• 
•  Results of this mid-term evaluation. 
•  Additional desk and field research into specific thematic sectors. 
•  Data provided by the Member States (Art 42 CPR), final performance reports (Art 
43 CPR) and the Member States’ impact evaluations finalised by 2029 (Article 44 
CPR). 

•  Scientific reports such as for example the annual reports on the state and economics 

of the fishing fleet, on the state of the fish stocks and the blue economy. 

•  The full evaluation of the CFP Regulation. 

While the midterm timeframe limits the depth of impact analysis, the available qualitative 
evidence already demonstrates promising EU added value. At the halfway point, EMFAF 
was designed to ensure strong coherence with the CFP, to introduce a new crisis response 
capacity, and to provide alignment with EU environmental and food system priorities.  

In any event, the qualitative evidence available so far provides first positive indications on 
the EU added value of the instrument at the half-way point. This evidence also provides 
potential  areas  for  further  exploration  and  suggestions  for  improvement  for  the  ex-post 
EMFAF evaluation.  

51 

 
 
 
EFFECTIVENESS 

The  EMFAF  appears  to  be  more  advanced  than  the  EMFF  in  the  middle  of  the 
programming  period,  indicating  that  Member  States  expect  to  make  considerable 
headway in 2025 in most cases. By early 2024, about 9 % of EMFAF’s total budget had 
been  committed  and  1 % paid.  Progress  towards  milestones  averaged 10 %,  with 
significant variation across Specific Objectives. Implementation has advanced most under 
SO 1.4  (data  and  control),  where  the  mandatory  15 % budget  share  ensured  early 
momentum. The SO 2.2 (marketing and processing) also performs above average, helped 
by  crisis-related  compensations.  Conversely,  investment-heavy  and  community-driven 
areas—SO 3.1 (blue economy/CLLD) and small-vessel modernisation—lag behind. This 
pattern shows that administrative complexity, not lack of relevance, is the main constraint 
on short-term effectiveness. 

Although  output  indicators  show  limited  progress,  the  EMFAF  has  laid  the 
groundwork  for  achieving  results  in  the  second  half  of  its  period.  The  integration  of 
previous lessons—especially stronger links between national monitoring systems and the 
EU  Infosys  database—has  improved  data  reliability  and  transparency.  Managing 
Authorities  that  proactively  used  feedback  mechanisms  from  the  EMFF  transition 
demonstrated better progress, underlining that institutional learning directly improves fund 
effectiveness. 

Programme  governance  has  improved,  but  several  Managing  Authorities  face 
capacity  and  staffing  challenges.  The  consolidation  of  EMFF  and  EMFAF  portfolios 
placed  temporary  strain  on  human  and  technical  resources.  Where  pre-existing  systems 
and IT tools were in place, implementation advanced faster, confirming that institutional 
continuity is a key success factor. Increased guidance from FAMENET and DG MARE 
has  supported  problem-solving,  but  further  capacity  development  is  needed  to  enhance 
delivery speed and quality control. 

However,  despite  the  increased  flexibility  of  the  EMFAF,  in  practice  the  national 
EMFAF programmes  are broadly  a continuation of the EMFF  with  certain  notable 
exceptions56.  The  EMFAF  also  faces  challenges,  notably  in  terms  of  organisational 
capacity,  and  the  need  for  consistent  training  and  skills  development,  especially  at  the 
national level. Addressing these areas can further enhance the effectiveness of the EMFAF 
in achieving its goals of sustainable structural changes in the maritime and fisheries sectors.  

Stakeholder  involvement  during  the  preparation  of  national  EMFAF  programmes 
has  also  been  largely  effective,  with  strong  support  and  satisfaction  for  the  managing 
authorities. However, there is room for more innovative contributions and better alignment 
of stakeholder expectations with the practical realities of the programmes. There is also 
more  room  for  simplification  and  optimisation  of  the  effectiveness  of  the  delivery 
system,  especially  with  enhanced  use  of  SCOs  and  FIs,  the  application  and  selection 
procedures, and optimisation of the Member States’ monitoring and reporting systems.  

56   For  instance,  the  introduction  of  compensation  types  of  action  for  exceptional  events  in  the  EMFAF 
Regulation, or the introduction of new types of actions at the national level, in particular under specific 
objective 1.6 (protection of biodiversity), or the possibility to fund large projects encompassing different 
types of activities (to support market development for instance). 

52 

 
 
EMFAF’s simplification measures embody a long-term cost–saving strategy, but early 
implementation unavoidably generated short-term cost growth due to transition, training, 
and  system  alignment.  These  expenditures  are  consistent  with  EU  policy  principles 
favouring proportionality, accountability, and sustainability in fund administration. Over 
time,  administrative  costs  could  eventually  decline  as  simplification  tools  mature  and 
economies of scale materialise across Member States.  

External  disruptions  (COVID-19,  Brexit,  and  Russia’s  war  against  Ukraine) 
substantially  affected  project  pipelines  and  economic  behaviour 
in  fisheries, 
aquaculture,  and  processing.  Internally,  prolonged  negotiations  over  partnership 
agreements  and  delayed  adoption  of  some  national  programmes  postponed  execution. 
Despite  these  setbacks,  EMFAF’s  flexible  design,  including  crisis  mechanisms  and 
reallocation capacity, has helped mitigate systemic risks and maintain momentum. 

EFFICIENCY 

Although the core issues the EMFAF seeks to address - such as market failures and the 
implementation of the CFP- remain consistent with past programmes, lessons learnt have 
prompted adjustments in its delivery system. The novel EMFAF architecture makes a shift 
from  predefined  measures  to  broad  types  of  actions  offering  Member  States  greater 
flexibility to pursue strategic objectives based on an assessment of their needs. Moreover, 
the CPR introduced flexibilities, such as the streamlining of the enabling conditions, the 
reduction in control and audit requirements and the simplified identification of programme 
authorities, aiming to make the programming and implementation of the CPR Funds more 
efficient. 

The EMFAF provides for the possibility to trigger a crisis mechanism, which would result 
in compensation in case of exceptional events causing a significant disruption of markets. 
Moreover,  the  EMFAF’s  MEF  has  improved  considerably  compared  to  the  previous 
programming period, through the early development of indicators in consultation with the 
Member  States,  the  provision  of  guidance  on  the  indicators  and  the  performance 
framework  methodology  for  target  setting.  The  EMFAF  is  designed  to provide  more 
streamlined data and show more  clearly how the Fund contributes to the objectives 
of the CFP as well as to the horizontal policy priorities of resilience, green and digital 
transition compared to the EMFF. These contributions are expected to become clearer 
in the context of the retrospective evaluation. 

Despite  steps  taken  at  the  EU  and  national  level  to  simplify  the  Fund  and  its 
implementation, administrative costs are assessed to have increased overall. While these 
costs  are  considered  justified  in  general  by  the  complexity  and  legal  restrictions  of  the 
Fund,  and  comparable  to  what  has  been  observed  for  other  CPR  Funds,  they  seem 
disproportionate  for  countries  with  a  lower  EMFAF  budget  allocation,  in  particular 
landlocked countries.  

COHERENCE 

On the internal coherence, the alignment between the EMFAF and the CFP is reflected 
in the Member States’ EMFAF programme design, both in terms of the types of actions 
included and the allocation of resources. The EMFAF establishes higher intensity aid for 
certain types of actions and beneficiaries, for instance on the implementation of the landing 
obligation,  support  for  small-scale  coastal  fisheries  and  support  for  ORs.  During  the 

53 

 
implementation of the Fund, internal coherence is maintained through the verification that 
EMFAF beneficiaries and their projects adhere to CFP rules.  

On the external coherence, the EMFAF aligns with and complements the other EU 
funds,  with  the  strongest  synergies  seen  between  the  EMFAF,  ERDF  and  the  ESF+, 
especially  on  support  to  coastal  communities,  skills,  training,  working  conditions  and 
attractivity of the sector. Coherence is further reinforced through partnership agreements 
prepared  by  Member  States  for 
the  2021-2027  period.  While  synergies  and 
complementarities with other Funds are identified, there is still room of reinforcing this 
aspect. 

The contribution of the EMFAF to tackling climate change is in line with the European 
Green Deal and the EU’s commitments to implement the Paris Agreement. The EMFAF 
also aligns with the Farm to Fork Strategy by, supporting sustainable (environmental, 
economic  and  social)  fishing  and  aquaculture  activities,  biodiversity  protection  and 
restoration, carbon emissions reduction and improvement of products quality. Finally, the 
EMFAF  plays  a  role  in  preserving  and  restoring  ecosystems  and  biodiversity  by 
supporting environmental legislation, including the Habitat and Birds Directives and the 
MSFD, and actions within the Natura 2000 network.  

With the CFP being an exclusive competence, the role of the EU in implementation and 
funding is indispensable and the general notion of the common policy, the mobile nature 
of  fisheries,  and  the  duty  to  manage  the  resources  responsibly,  means  that  without 
adequate oversight Member States would not be incentivised to manage the common 
resources. Thanks to the investments made by fishers and national administrations, 
and through the support of the EMFF and in continuation of the EMFAF, fishing has 
become more sustainable and far fewer stocks are now overfished in the EU. In the 
Mediterranean and Black Seas, the situation has improved but the rate of overfishing is 
still too high, and more efforts are needed to restore stocks to healthy levels, also with the 
help of the Fund.  

In the context of the evaluation study, the managing authorities pointed out that overall, 
the EMFAF promotes a level playing field for all EU stakeholders operating in the blue 
economy sectors, and provides the incentives to support research, data collection, fisheries 
control  and  facilitate  the  adoption  of  sustainable  fishing  practices.  The  Fund  can  also 
enhance  coordinated  efforts  and  shared  benefits  across  Member  States,  making 
interventions  more  effective  and  efficient  compared  with  what  Member  States  could 
achieve through national-level actions alone. 

RELEVANCE 

The  EMFAF’s  overall  intervention  logic  and  refinement  through  Member  States’ 
SWOT  analyses  ensured  that  resources  were  well  targeted  to  the  most  pressing 
sectoral needs—sustainable resource use, aquaculture competitiveness, and blue economy 
resilience. The intervention logic represents a clear improvement over the EMFF, where 
overly prescriptive measures reduced flexibility.  

The EMFAF remains a central strategic instrument for bridging EU policy priorities 
and national realities. Its design grants Member States greater flexibility in programming 
resources according to their specific circumstances and to adjust them as priorities evolve. 
Evaluation  findings  confirm  that  Managing  Authorities  value  this  adaptability:  national 

54 

 
programmes  now  reflect  local  and  regional  specificities,  ensuring  that  interventions  are 
tailored to each Member State’s environmental, economic, and social context.  

Notably, 20 Member States have included mechanisms to reprogramme funds during 
the  period,  allowing  adjustments  in  response  to  changing  market  conditions,  crises,  or 
policy shifts. This demonstrates a shift toward a more responsive, adaptive Fund capable 
of addressing on-the-ground challenges effectively. 

Under the two-year work programme framework for direct and indirect management, 
the EMFAF is also able to respond to emerging needs at the EU level more dynamically. 
This  approach  complements  national  programmes  by  funding  transnational  and 
cross-border 
initiatives—such  as  marine  knowledge,  maritime  surveillance,  and 
international ocean governance—that cannot be managed effectively at national scale. 

Nevertheless, some gaps persist. The social dimension of the blue economy—including 
employment  attractiveness,  labour  conditions,  gender  equality,  and  generational 
renewal—remains underdeveloped within both national and EU-level implementation. 
As  these  challenges  are  expected  to  intensify  with  demographic  shifts  and  the  ongoing 
energy  transition,  greater  attention  must  be  directed  toward  strengthening  the  social 
sustainability of fisheries and aquaculture. 

The EMFAF continues to be a strategic instrument to address the EU policy priorities 
and national needs, by providing flexibility to Member States to programme EMFAF in 
line  with  the  changing  policy  context  and  priorities.  The  evaluation  findings  show  that 
managing authorities appreciated that their programmes considered regional specificities, 
which ensured they were tailored to the unique conditions and needs of local communities. 
The review of the national EMFAF programmes confirmed that 20 Member States have 
specifically  built-in  flexibility  to  allow  for  changes  in  needs  and  uncertainty  over  the 
course  of  the  programming  period,  which  shows  that  the  Fund  is  now  more  flexible  in 
dealing with the reality on the ground. 

The two-year work programme delivered under (in)direct management is also able to adapt 
to  emerging  needs  on  a  more  regular  basis  and  serves  as  a  complement  to  the  national 
EMFAF programmes in addressing needs that transcend national boundaries.  

There is however room for improvement  and more efforts are needed  in addressing the 
social aspects and challenges of the sector which are expected to increase. 

5.2.  LESSONS LEARNT 

A key lesson emerging from this mid-term evaluation is that legislative deadlines should 
allow greater flexibility for conducting mid-term evaluations once implementation is 
sufficiently advanced. Fixed timelines did not reflect the severe delay in launching national 
programmes  (most  adopted  only  at  the  end of 2022).  As  a  result,  analysis  across  the 
Better Regulation  criteria  could  not  be  fully  completed.  Future  legislative  frameworks 
should therefore provide adaptable timelines, triggered either by implementation progress 
or by the availability of intermediate data (e.g., Infosys outputs), rather than fixed years in 
the regulation. 

55 

 
EFFECTIVENESS 

Member States explain that the main reasons for the slow implementation of the EMFAF 
are  due  to  the  lack  of  capacity,  staff  turnover  affecting  institutional  memory,  the 
institutional structure in the Member States, as well as the strict eligibility conditions of 
the fleet measures under the EMFAF. These issues indicate that further efforts are needed 
to ensure that the EMFAF delivery system builds on the necessary skills, capacities, and 
resources at the national level.  Member States identify administrative capacity and staff 
turnover as the principal drivers of delays. The EMFAF delivery system must continue to 
invest in the skills, stability, and institutional memory of Managing Authorities.  

Continuous stakeholder dialogue—particularly with small scale fishers, aquaculture 
producers, and environmental groups—should be formalised during implementation, 
not  only  at  programming  stage.  Broad  consultations  during  the  Fund’s  design  were 
decisive for relevance, yet there remains room to align stakeholder expectations with legal 
and operational realities.  

Ongoing exchanges between the Commission and Member States are encouraged to 
clarify flexibility within the current legal framework. Rigid eligibility conditions limit 
the take up of fleet modernisation and renewal actions.  

EFFICIENCY 

The evaluation finds that the use of SCOs, and in some cases of financial instruments have 
the potential to increase simplification and efficiency in the implementation of the Fund. 
Nevertheless, SCOs are still being set up in different Member States, while the use of 
financial instruments is still very limited, making it difficult at this stage to state whether 
they are working and to what extent they have improved the efficiency of the Fund. The 
same applies for the MEF, where Member States find its implementation challenging due 
to its newness, and raise concerns on the setting of indicators and targets.  

As  a  lesson  learnt,  the  Commission  will  continue  encouraging  knowledge-sharing 
among Member States and between the EU and Member States in the early stage of 
implementation of these tools and to investigate systematically what has worked, to what 
extent and the possible undesired effects. The Commission will also continue supporting 
the Member States in the setting-up and functioning of the MEF. 

COHERENCE 

Support  to  the  fisheries  sector  is  crucial  to  help  them  restructure,  innovate, 
modernize, help them to become resilient, ensure generational renewal, contribute to 
food  security  and  sustainable  management  of  marine  environment.  Research  and 
innovation in the maritime, fisheries, aquaculture and blue economy domain rely on the 
strong links established with Horizon Europe, including via Mission Ocean and EMFAF, 
with its dedicated support provided under Blue Invest and through InvestEU. Despite this, 
there is so far limited take-up of projects on research and innovation under the EMFAF.  

While there are strong synergies with ERD and ESF+ and good synergies with the CAP 
and  Horizon  Europe,  more  efforts  should  be  made  in  order  to  get  fishers  and 
aquaculture  farmers  to  work  directly  with  science  organisations,  to  build 
partnerships and participate in field work, e.g. to help bring the work financed under 

56 

 
Horizon Europe to real life applications and testing. This is why it is of great importance 
to find and develop further synergies with the relevant funding streams and instruments, in 
order to respond to these challenges and to support further the fisheries sector. 

operational 

Stronger 
and 
Blue Innovation Hubs could ensure that scientific insights are more rapidly transferred 
into practice. 

with  Mission Ocean, 

Blue Invest, 

links 

The Commission and Member States should aim to streamline governance structures 
to reduce duplication and clarify accountability between EU-level initiatives and national 
maritime  strategies.  The  proliferation  of  overlapping  blue  economy  strategies  and 
frameworks has made policy coordination increasingly complex.  

RELEVANCE 

Overall,  the  evaluation  finds  that  the  EMFAF  is  highly  relevant  and  effective  funding 
vehicle, especially given the explicit contribution to the CFP as well as on horizontal EU 
priorities such as the European Green Deal. In view of the sectoral needs served by the 
EMFAF, the assessment is that these will continue and likely grow over time.  

The EMFAF can also make a difference in developing new business opportunities in 
rural and coastal areas, enabling blue and circular economies, by supporting CLLD 
and helping coastal regions and communities adapt and mitigate the impacts of climate 
change. The recent FAMENET study demonstrates that EMFF-funded CLLD was by far 
the  most  effective  intervention  for  job  creation,  a  key  concern  in  many  coastal 
communities.  

The enhanced flexibility  of the programme is  positively assessed  as  contributing to  the 
relevance, and Member States have taken steps to build flexibility into their programmes 
based on lessons from the past. This implies a need to continue to ensure this flexibility 
also in view of the future funding instrument. 

The support for CLLD should remain a priority under the EMFAF and its achievements 
should be given more visibility. The CLLD has the ability to build connections and foster 
cooperation between stakeholders at local level, including with the small-scale fisheries 
sector which has benefited from almost a quarter of such projects under the EMFF. 

EU ADDED VALUE 

To  maximize  EU  added  value,  the  EMFAF  implementation  needs  further 
strengthening  of  policy  coordination  and  integration  with  complementary  EU 
instruments.  This  should  include  proactive  cooperation  to  address  emerging  priorities, 
enhance  competitiveness,  and  ensure  smooth  implementation.  Targeted  measures  to 
accelerate implementation timelines and overcome administrative delays will help EMFAF 
effectively  respond  to  both  EU  and  national  needs,  thereby  reinforcing  its  strategic 
relevance.  

57 

 
 
 
6.  ANNEX I. PROCEDURAL INFORMATION 

The  European  Commission  conducted  the  mid-term  evaluation  of  the  European  Maritime, 
Fisheries and Aquaculture Fund (EMFAF) in the programming period 2021-2027 by the end of 
2024, in line with Article 45 of the Common Provision Regulation (CPR) 2021/1060.57 

The Decide planning entry for the mid-term evaluation is PLAN/2024/30. The Call for evidence 
and the Public Consultation were published on ‘Have your say’ on 12 June 2024 and 21 June 
2024 respectively for a 12-week period (until 6 and 13 September 2024) for stakeholders and 
the general public to provide feedback.58 

The  evaluation  was  led  by  the  European  Commission's  Directorate-General  for  Maritime 
Affairs  and  Fisheries  (DG  MARE).  An  Interservice  Steering  Group  (ISSG)  was  set  up 
comprising  the  following  Commission  services:  DG  EMPL,  DG  ENV,  DG  HOME,  DG 
REGIO, SG. Several DG MARE colleagues also formed part of the ISSG. The ISSG helped 
ensure  the  representativity  of  the  evidence  considered,  the  validity  of  the  analysis  and  the 
reliability of the conclusions. In particular, the ISSG was consulted as follows: 

• 
• 
• 
• 
• 
• 
• 
• 
• 

In September 2023 on the technical specifications of the external study; 
In December 2023 on the kick-off meeting with the external contractor; 
In January 2024 on the Inception Report of the external study; 
In May 2024 on the Call for evidence and the Public Consultation questionnaire; 
In May 2024 on the Draft Final Report; 
In June 2024 on the Validation workshop; 
In July 2024 on the Final Report;  
In November 2024 on the draft SWD; and 
In XX59 2025 on the SWD and all its annexes. 

In  line  with  the  requirements  set  out  in  the Commission  Better  Regulation  Guidelines,60  the 
mid-term evaluation examined the effectiveness, efficiency, relevance, coherence and Union 
added value of EMFAF. The evaluation relied on the following component: 

1.  An  external  independent  supporting  study  (i.e.  the  supporting  study)  awarded  to  a 
consortium  consisting  of  Tetra  Tech,  AND  International,  Poseidon  Aquatic  Resource 
Management Europe Limited and F&S SARL. The service contract started on 11 December 
2023  and  ended  in  October  2024.  The  analysis  relied  on  desk  research,  data  analysis, 

57 

Regulation 

(EU) 
content/EN/TXT/?uri=CELEX%3A32021R1060. 

2021/1060. 

Available 

at: 

https://eur-lex.europa.eu/legal-

58 Call for Evidence and Public Consultation on the mid-term evaluation of the European Maritime, Fisheries and 
Aquaculture Fund (EMFAF) for 2021-2027. Available at: https://ec.europa.eu/info/law/better-regulation/have-
your-say/initiatives/14119-EU-Maritime-Fisheries-and-Aquaculture-Fund-EMFAF-2021-2027-midterm-
evaluation_en  

59   To be updated after the formal ISC. 
60   Better  Regulation:  guidelines  and  toolbox  https://commission.europa.eu/law/law-making-process/planning-

and-proposing-law/better-regulation/better-regulation-guidelines-and-toolbox_en. 

58 

 
 
 
extensive stakeholder consultation activities (interviews, survey and validation workshop) 
and case studies. 

For a full discussion on the evidence considered, including limitations faced and mitigations 
adopted, see Annex II. Annex V provides a full report of all consultation activities conducted. 

59 

 
 
7.  ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

OVERALL APPROACH TO THE EVALUATION 

The mid term evaluation of EMFAF is largely based on an external supporting study. Additional 
sources of information included JRC and FAMENET. DG MARE relied on the work of the 
contractor to (i) collect and analyse the relevant evidence (including consultation work); (ii) 
provide initial answers to all evaluation questions; and (iii) present evidence-based conclusions 
and  lessons  learnt.  The  study  followed  an  approach  based  on  mixed-method  data  collection 
approaches,  combining  qualitative  and  quantitative  research  methods.  The  overall 
methodological approach was guided by an Intervention Logic presented in the main body of 
this SWD and an evaluation matrix/framework presented in Annex III. 

In accordance with the terms of reference and the tasks described in there, an inception phase 
of the study was dedicated to fine-tuning and operationalising the methodology and preparing 
the data collection tools for the following phases.  

The  main  objective  of  Task  2  was  to  provide  an  overview  of  the  26  national  EMFAF 
programmes. The exercise provided key information on the delivery system and specificities of 
each programme. Task 2 also provided additional information to refine the intervention logic. 
This task was primarily based on the analysis of the national EMFAF programmes, in addition 
to  available  monitoring  data  and  FAMENET  documents.  The  survey  and  interviews  with 
managing authorities (Task 3) then complemented and validated this. 

INTERVIEWS WITH KEY STAKEHOLDERS AT THE EUROPEAN LEVEL 

These  interviews  allowed  for  gathering  of  feedback  from  different  types  of  stakeholders 
concerned by the shared and (in)direct management components of the EMFAF. 15 interviews 
with 27 key stakeholders were conducted at the European level. The list of selected (based on 
DG MARE and ISG feedback) stakeholder categories and subcategories is provided below: 

•  DG MARE: five interviews with seven stakeholders + four scoping interviews with 14 

desk officers 

•  CINEA: two interviews 
•  DG ENV: one interview, with two representatives 
•  ETF: one interview with two representatives 
•  Europeche: one interview 
•  WWF: one interview 

Each online interview lasted 45 minutes to 1 hour. The interviewee was informed in advance 
on the main topics and information sought to allow them to prepare. Interview guides for the 
three main stakeholder categories consulted were developed and disseminated. The interviewer 
tailored the corresponding guide to each organisation's intervention area. 

ADVISORY COUNCILS 

In addition, the contractor offered the 11 Advisory Councils the opportunity to provide written 
feedback, with a dedicated questionnaire, translated into French, Portuguese and Spanish upon 
their  request.  Nevertheless,  only  two  Advisory  Councils  provided  a  contribution:  the 
Aquaculture Advisory Council (AAC) and the Mediterranean Advisory Council (MEDAC). 

60 

 
SURVEY OF THE EMFAF MANAGING AUTHORITIES IN THE MEMBER STATES  

The objective of this survey was to build on the data and information already assessed as part 
of the review of the national programmes, Infosys and the MEF. The survey questionnaire was 
provided and approved with the inception report. 

26 responses from managing authorities were received, though the last ones were sent a month 
after the deadline. 

SURVEY OF EMFAF TARGET GROUPS 

A  second  survey  of  a  wider  group  of  stakeholders  was  used  by  the  contractor,  which  was 
disseminated broadly and in a tailored way at the national level, based on closed monitoring of 
responses. The target groups were the following: 

•  Direct  beneficiaries:  stakeholders  who  benefitted  from  EMFAF  funding  (including 
those whose applications are still in progress) could include economic operators (e.g., 
fishers,  aquaculture  producers  and  processors  of  fisheries  and  aquaculture  products), 
representative  organisations  of  fisheries  and  aquaculture  producers  (e.g.,  producer 
organisations), institutional stakeholders with different legal status (e.g., ports managing 
authorities,  Natura  2000  sites  managers,  public  administrations,  research  institutes, 
Community-Led Local Development NGOs). At this stage, we expected the number of 
beneficiaries  to  be  low,  especially  economic  operators,  as  the  national  EMFAF 
programmes were approved in the second half of 2022. 
Indirect  beneficiaries:  stakeholders  who  have  not  applied  but  have  benefited  from 
EMFAF funding (e.g., projects in ports or in auctions benefit indirectly all the users). 
•  Non-beneficiaries:  stakeholders  who  have  not  asked  for  EMFAF  support  or 

• 

unsuccessful applicants. 

The main objective of this survey was to collect complementary feedback on specific aspects. 

SPECIFIC METHODOLOGICAL TOOLS USED IN THE ANSWERS TO THE EVALUATION QUESTIONS 
- ASSESSMENT OF THE DURABILITY OF EMFAF INTERVENTIONS 

Interventions  durability  is  understood  as  the  ability  of  interventions  to  provide  long-term 
beneficial  impacts  (i.e.  after  the  end  of  the  funding),  either  at  individual  level  (e.g.  private 
investments) or at institutional and policy level (e.g. improve the general implementation of the 
CFP beyond the project supported). 

To categorise EMFAF interventions according to their level of ‘durability’, the study relied on 
the two classifications described below. 

The  classification  developed  by  Sumaila  et  al.  in  201061,  which  classifies  subsidies  to  the 
fisheries sector in three categories, based on their long term impact on the fishery resources:  

61   Sumaila, U.R., A.S. Khan, A.J. Dyck, R. Watson, G. Munro, P. Tydemers, and D. Pauly, ‘A Bottom-up Re-
Estimation of Global Fisheries Subsidies’, Journal of Bioeconomics, Vol. 12, No. 3, October 1, 2010, pp. 201–
225 

61 

 
 
•  Beneficial subsidies, which produce the “maximum long-term sustainable net benefits”: 
investments in natural capital assets (e.g. fisheries management program and services, 
R&D, MPAs);  

•  Capacity-enhancing  or  harmful  subsidies  which  contribute  to  overexploitation  of  the 
fishery resource: all form of capital inputs and infrastructure investments from public 
sources  that  reduce  cost  or  enhance  revenue  for  fishers  (e.g.  fuel  subsidies,  vessels 
modernisation  and  construction,  fishing  port  construction  and  renovation,  price  and 
marketing support, fishery development projects, foreign access agreements);  

•  Ambiguous subsidies, which may lead to long-term sustainability or to overexploitation 
depending on the objectives and implementation (e.g. vessel temporary and permanent 
cessation programs, CLLD). 

The Sumaila et al. classification has the advantage to provide a simple analytical tool to classify 
interventions based on their potential long-term impacts. It is also widely used in the literature. 
For instance, a recent article published in the ICES Journal of Marine Science (Skerritt et al., 
2020)62 used this classification to assess the sustainability of the EU fisheries funds from the 
Financial  Instrument  for  Fisheries  Guidance  (FIFG,  2000–2006)  to  the  EMFF  (2014-2020), 
with a preliminary assessment for the EMFAF. 

This classification has two main limits: 

• 

• 

its scope, both in terms of impacts, as it only considers impacts on fisheries resources, 
and in terms of sectoral coverage, as it cannot be applied to the support to aquaculture 
and processing activities; 
the fact that it does not take into account the quality of the management system in place. 

As regards the second limitation, the OECD argued in its 2017 report on levels and impacts of 
support to fisheries63 that the effect of support is “conditioned on, but not entirely mitigated by, 
the  quality  of  the  management  system  in  place”  and  that  whereas  an  effective  management 
system  could  prevent  overfishing,  it  did  not  completely  prevent  the  incentive  for  excess 
capacity. In other words, the Sumaila et al. classification remains relevant for fisheries but could 
be nuanced in countries where catch controls and effort controls are in place, which is the case 
for the EU.  

The  classification  used  in  the  OECD  Fisheries  Support  Estimate  database,  used  in,  which 
includes: 

•  Budgetary transfers to individual fishers, including: 

o  payments based on variable inputs;  
o  payments based on outputs; 
o  payments based on fixed input use;  
o  payments based on fishers’ income; 

62 

 Skerritt DJ, Arthur R, Ebrahim N, Le Brenne V, Le Manach F, Schuhbauer A, et al. A 20-year retrospective 
on  the  provision  of  fisheries  subsidies  in  the  European  Union.  ICES  Journal  of  Marine  Science. 
2020;77(7‑8):2741‑52 

63   OECD (2017), “Support to fisheries: Levels and impacts”, OECD Food, Agriculture and Fisheries Papers, No. 

103, OECD Publishing, Paris. http://dx.doi.org/10.1787/00287855-en 

62 

 
 
•  Budgetary 

transfers 

to  support  general  services  (e.g.  fisheries  management, 
enforcement,  marketing  and  promotion,  support  to  fishing  communities,  port 
investments...).  

•  Cost recovery, which consists in a transfer from fishers to the government to partially 

cover expenditures related to fisheries management.  

The  advantage  of  this  classification  is  that  it  is  also  fairly  simple  to  use.  Compared  to  the 
Sumaila  classification  it  can  also  be  transposed  to  some  extent  to  interventions  targeting 
aquaculture and processing activities. 

The main limit is that there is no direct link with sustainability or durability, but the OECD 
report concluded that Budgetary transfers to  support general  services is  often categorised as 
providing  long-term  beneficial  effects  in  terms  of  reducing  fishing  effort  and  improving 
sustainability, while budgetary transfers to individual fishers are more likely to result in long-
term over capacity (with varying effects depending on the type of transfer). 

The classification of types of intervention in the EMFAF regulation according to their expected 
contribution on the environment and climate issues: 

•  100% contribution (beneficial): types of intervention with a clear focus on environment 

and climate; 

•  40% contribution (ambiguous): types of intervention with an ‘ambiguous’ contribution, 
meaning they can have beneficial impacts on the environment, or not, depending on the 
actions  implemented,  i.e.  interventions  promoting  fishery,  aquaculture  and  the 
processing  sector,  as  well  as  animal  health  and  welfare,  maritime  surveillance  and 
CLLD implementation; 

•  0%  contribution  (neutral):  no  impact  expected  on  reducing  negative  environmental 

impacts or mitigating/adapting climate change. 

The advantage of this classification is that it is very simple, it is made for the EMFAF, and 
covers all possible interventions. 

The limits are that: 

• 

• 
• 

It relies on the assumption that 40% of the budget for what we call here ‘ambiguous’ 
types of intervention will effectively by allocated to actions with positive impacts on the 
environment and on the climate, which is not certain,  
It does not differentiate between short-term and long-term impacts; 
It  does  not  take  into  account  the  potential  negative  long-term  impacts  on  fishing 
capacity,  described  above.  The  risk  is  limited  by  the  CFP  rules  and  the  EMFAF 
eligibility criteria, but, based on the scientific literature, in the long-run, impacts may 
still be negative. 

To  assess  the  durability  of  the  EMFAF  interventions,  and  not  only  the  effects  on  the 
sustainability of fisheries resources and to encompass the full scope of the EMFAF, we mixed 
the different approaches above with an assessment of the potential duration of impacts after the 
end of funding, as follows: 

•  Long-term:  support  targeting  primarily  R&D,  fisheries  management  and  biodiversity 
conservation measures (SO 1.3 – permanent cessations, SO 1.4, SO 1.6 and SO 4.1); 

63 

 
•  Medium term: support targeting primarily private investments, training, general services 
to promote the sustainable development of the sector, etc.. (SO 1.1, 1.2, 2.1, 2.2, 3.1 and 
5.1) 

•  Short-term: mainly compensation measures (SO 1.3 – temporary cessations, SO 1.5) 

The  analysis  was  then  carried  out  at  the  level  of  SO  and  type  of  intervention  (cf.  Infosys 
nomenclature) in several steps: 

•  We first applied the Sumaila classification for each SO : beneficial, capacity-enhancing, 

ambiguous, not applicable, based on Skerritt et al. article; 

•  We then applied the EMFAF classification by type of intervention; 
•  For the environmental classification, we combined the two classifications above with 
the  following  priority  rules  in  case  of  contradictory  classifications  between  the  two 
approaches: 

o  Capacity-enhancing > ambiguous, beneficial or not applicable; 
o  Beneficial > ambiguous or not applicable; 
o  Ambiguous > not applicable. 

•  We  used  the  OECD  classification  of  budgetary  transfers  as  a  basis  to  differentiate 
between impacts at individual level (corresponding to budgetary transfers to individual 
operators)  and  impacts  at  institutional  level  (corresponding  to  budgetary  transfers  to 
general services). 

•  We applied the long-term/medium-term/short-term classification above; 

This classification resulted in the following matrix, which was crossed with the budget allocated 
by MS by type of intervention for each specific objective. We focused on planned expenditures 
rather than committed support considering that at this stage it would give a more comprehensive 
picture of potential impacts. To assess the durability of the EMFAF interventions, we calculated 
the  share  of  EMFAF  budget  by  category  along  the  three  dimensions  (environmental 
sustainability, duration, individual vs institutional levels). 

64 

 
Table10  : Classification for the assessment of the durability of EMFAF interventions 

Source: Contractor’s own elaboration 

65 

 
 
ESTIMATES OF MS ADMINISTRATIVE BURDEN RESULTING FROM THE EMFAF 

The approach to estimate the administrative burden resulting from the EMFAF is in line with 
the approach used by the 2018 DG REGIO study on the administrative costs of ESIF64, but not 
fully comparable as the scopes of the two studies and the level of detail of collected data are 
significantly different.  While detailed data per task were task, as well as data on both FTEs 
(Full Time Equivalents) and costs were collected for the DG REGIO study, the data collection 
for the present study focused on the number of FTEs at national level for broad categories of 
activities. Labour costs were not provided by MS but derived from the information gathered on 
FTEs and Eurostat labour cost data as explained below. 

Managing  authorities  were  asked,  in  an  email  survey,  a  series  of  semi-quantitative,  and 
qualitative  questions  (description,  evolution  compared  to  the  EMFF,  etc...  )  on  their 
administrative costs related to the EMFAF (see 5.Survey of managing authorities, section 3), 
including: 

•  Approximate range for the number of FTEs dedicated to the dedicated to the design and 

drafting of the EMFAF programme; 

•  Approximate range for the number of FTEs dedicated to the management of the EMFAF 

programme; 

•  Approximate range for the number of FTEs dedicated to processing applications; 
•  Approximate range for the number of FTEs dedicated to payments and control; 
•  External costs. 
•  Evolution between the EMFF and the EMFAF; 
•  Open comments on the organisation and the allocated resources. 

We assume here that the tasks included in those FTEs would not take place without the EMFAF, 
and therefore constitute the administrative burden resulting from the EMFAF and not business-
as-usual administrative costs. 

Information regarding resources used for the programming and drafting of the programme was 
fairly clear. All MS provided information on FTEs for 2020, 2021 and 2022 as well as detailed 
information on external costs.  

FTEs were then converted into monetary costs using the following formula: 

𝐶𝑜𝑠𝑡𝑠 𝑖𝑛 𝐸𝑢𝑟𝑜𝑠/ 𝑀𝑒𝑚𝑏𝑒𝑟 𝑆𝑡𝑎𝑡𝑒  =  𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝐹𝑇𝐸𝑠/ 𝑀𝑒𝑚𝑏𝑒𝑟 𝑆𝑡𝑎𝑡𝑒  ∗
 𝑛𝑎𝑡𝑖𝑜𝑛𝑎𝑙 𝑎𝑛𝑛𝑢𝑎𝑙 𝑙𝑎𝑏𝑜𝑢𝑟 𝑐𝑜𝑠𝑡/𝐹𝑇𝐸., where: 

𝑛𝑎𝑡𝑖𝑜𝑛𝑎𝑙 𝑎𝑛𝑛𝑢𝑎𝑙 𝑙𝑎𝑏𝑜𝑢𝑟 𝑐𝑜𝑠𝑡/𝐹𝑇𝐸  =  𝑎𝑛𝑛𝑢𝑎𝑙 𝑙𝑎𝑏𝑜𝑢𝑟 𝑐𝑜𝑠𝑡, 𝑤𝑎𝑔𝑒𝑠 𝑎𝑛𝑑 𝑠𝑎𝑙𝑎𝑟𝑖𝑒𝑠  +
 𝑜𝑣𝑒𝑟ℎ𝑒𝑎𝑑𝑠, where: 

Annual labour costs are estimated using the 2020 Eurostat series for labour cost, wages and 
salaries  for  employees  in  the  public  administration  and  defence,  and  compulsory  social 

64   European  Commission,  Directorate-General  for  Regional  and  Urban  Policy, New  assessment  of  ESIF 
Office, 
– 

Publications 

report, 

Final 

costs 

administrative 
2018, https://data.europa.eu/doi/10.2776/36663 

burden 

and 

66 

 
 
security65, adjusted with the 2023 labour cost index66 and overheads are estimated at 25% of 
labour costs. 

The  following  table  presents  the  average  estimates  for  the  total  FTEs  mobilised  for  the 
programming  and  drafting  of  national  programmes  between  2020  and  2023,  labour  costs, 
external costs and total costs. 

Table 11 : Estimated administrative burden for the programming and drafting of the national programmes (one-
off costs) 

MS 

FTEs 2020 

FTEs 2021 

FTEs 2022 

Average 
labour cost/ 
FTE (EUR) 

External costs 
(EUR) 

Euro spent/ 
Million euro 
of public cost 

EU Average 

3,6 

3,4 

3,3 

52 023 

110 500 

2 060 

Source: Contractor’s own estimates based on MA survey 

Regarding implementation and management, all MS provided some information, with varying 
levels  of  details.  However,  in  processing  the  information,  the  following  difficulties  were 
encountered: 

• 

•  MS reported that resources allocated generally include some full time staff, as well as a 
number  of  staff  who  only  work  partially  on  the EMFAF,  which  makes  it  difficult  to 
estimate the resources in FTEs. It can be assumed that full-time are correctly reported, 
but other resources may be under or overestimated; 
In some MS, intermediate bodies play a major role in the EMFAF implementation and 
managing authorities do not always have visibility on the staff dedicated to the EMFAF; 
•  The  breakdown  of  FTEs  between  management  and  implementation,  applications 
processing  and  payments  was  not  interpreted  consistently  by  MS.  In  some  cases  the 
answers indicated that the FTEs indicated for the three categories were the same or that 
the FTEs indicated for management and implementation included the FTEs for the two 
other categories; 

•  To make it easier for MS to answer, questions were presented as closed questions with 
the  following  ranges  of  FTEs  (<1;  1  to  2;  3  to  5;  more  than  5).  Based  on  additional 
information provided in the open comments, the number of FTEs was often significantly 
greater than 5. This range in itself was therefore difficult to interpret. 
Information  provided  on  external  costs  related  to  management  and  implementation 
turned out to be difficult to interpret in general and very partial and was not used. 

• 

In order to overcome these limitations, the study proceeded as follows: 

• 

• 

• 

It  estimated  a  minimum  and  a  maximum  number  of  FTEs  for  each  MS  to  take  into 
account the uncertainty 
It cross-checked the number of FTEs for application processing and payments with the 
number and types of operations committed and paid in Infosys for coherence checks 
It started to process data from MS, where the information was clear and easy to interpret 
(9 MS):  

•  MS which provided exact number of FTEs; 

 Labour cost, wages and salaries (including apprentices) by NACE Rev. 2 activity [lc_ncostot_r2] 

65 
66   Labour cost index by NACE Rev. 2 activity - nominal value, annual data [lc_lci_r2_a] 

67 

 
 
•  Ranges of FTEs below 5 FTEs ;  
•  MS  which  clearly  differentiated  the  FTEs  under  different  categories  of  tasks  (i.e. 

management, application processing and payment processing); 
•  MS which provided clear information commenting the figures. 
•  For MS where interpretation was more uncertain (13 MS), we made assumptions based 
on the answers on FTEs and other qualitative information provided (e.g. number of staff 
partially  involved,  number  of  intermediate  bodies,  feedback  from  complementary 
interviews with intermediate bodies, etc..)67: 

•  For MS where the data seemed incoherent or too incomplete (4 MS), we applied the 
number of FTEs observed in similar MS, based on the size of EMFAF in the MS, the 
organisation (centralised, decentralised) and the number of intermediate bodies when 
we had the information. 
It only estimated the overall number of FTEs for the programming phase (one-off costs) 
and  for  the  management  and  implementation  as  a  whole  (recurrent  costs)  as  the 
breakdown  between  management,  application  processing  and  payment  and  control 
seemed reliable only from a small number of MS, with significant differences among 
MS. 

• 

An  additional  limitation  for  the  estimate  of  management  and  implementation  costs  (i.e. 
recurrent costs), was that we could only rely on 2023, which was not a typical year, as MS were 
still transitioning between the EMFF and the EMFAF and some MS had not selected any project 
under the EMFAF yet. Some MS however who had no operation committed yet at the end of 
2023 provided information on staff allocated to EMFF/EMFAF considering that the allocation 
of resources would remain stable. When no information was available, we estimated the number 
of FTEs as explained above. 

For  comparison  purposes,  we  estimated  the  ratio  of  administrative  burden/Total  public 
contribution  under  the  EMFAF,  differentiating  one-off  costs  (programming  and  drafting  the 
programme) and recurrent costs (management and implementation).  

To estimate total recurrent costs, we multiplied the 2023 management and implementation costs 
by  7  years.  The  result  could  be  slightly  underestimated  based  on  the  MAs  feedback  on  the 
expected evolution of costs, but without a solid ground to estimate an evolution rate, it was 
assessed as the safest approach. On one hand, costs are expected to increase, as a result of full-
speed  implementation,  inflation,  increase  in  labour  costs,  additional  external  costs  (studies, 
evaluations,  etc.).  On  the  other  hand  MS  also  report  that  they  could  decrease  with  the 
implementation of simplified cost options, and the new IT systems. 

Finally, results were compared with the findings of a study carried out for DG REGIO in 2017-
2018 to assess the administrative costs of the ESIF, including the EMFF68, to cross-check the 
validity of the estimates. We found that our overall estimates are in the same order of magnitude 
as the ones found by the DG REGIO study, but higher, which is also coherent with MS feedback 
on the evolution of costs between the EMFF and the EMFAF.  

67   When MS answered more than 5 FTEs for a given category of costs, without further information, we counted 

between 5 and 10 FTEs as a conservative approach. 

68   European  Commission,  Directorate-General  for  Regional  and  Urban  Policy,  New  assessment  of  ESIF 
2018, 

Publications 

Office, 

burden 

report, 

Final 

– 

administrative 
costs 
https://data.europa.eu/doi/10.2776/36663 

and 

68 

 
 
The following table presents the estimates for the total FTEs (including in intermediate bodies) 
in  2023  (includes  staff  working  on  EMFF  in  some  cases)  for  the  implementation  and 
management  of  national  programmes,  as  well  as  total  estimated  labour  costs  for  the  period 
2023-2029 by MS (anonymised and in a random order).  

Table12 : Estimated administrative burden for the management and implementation of the national programmes 
(recurrent costs) 

Low hypothesis   High hypothesis 

Average nb of FTEs / MS 

42 

Nb of FTE / million euros of public contribution 

0.97 

49 

1.12 

Average labour cost / MS (EUR) 

58 351 178 

68 323 218 

Labour  cost  (EUR)  /  million  euros  of  public 
contribution 

51 386 

60 168 

Source: Contractor’s own elaboration, based on MA survey 

LIMITATIONS AND ROBUSTNESS OF FINDINGS 

The main limitations encountered in the research included the following: 

Given  the  early  stage  of  implementation  and  the  budget  allocated  to  the  study,  there  were 
limitations  to  what  it  could  achieve.  The  study  focused  on  the  early  achievements  but  also 
greatly  emphasised  the  programming,  design  of  the  national  EMFAF  programmes  and  the 
delivery system, and the perceived improvements compared with the  previous programming 
period under EMFF. In addition, while the study covered shared and (in)direct management, 
based on the terms of reference, the methodology emphasises the former, proportionately to the 
EMFAF expenditure, and in line with Article 34 of Regulation (EU, Euratom) 2018/1046 (the 
'Financial Regulation'). 

In addition, as the data collection included mainly desk-based research and online consultations, 
the information  on the  measures programmed and implemented at the national  and  regional 
level  relies  primarily  on the national  EMFAF  programmes, which provide varying levels  of 
detail, especially as regards the types of actions under broad specific objectives, such as SO 1.1 
(sustainable fishing activities), 1.6 (biodiversity and ecosystems), 2.1 (sustainable aquaculture) 
and  2.2  (processing  and  marketing).  The  full  descriptions  of  the  measures,  their  scope  and 
selection criteria were defined in national documents that were outside the scope of the study. 
To  address  this  shortcoming,  descriptions  in  the  national  EMFAF  programmes  were 
triangulated with the feedback gathered from the managing authorities, the EU desk officers 
and  the  complementary  interviews  in  a  set  of  purposively  selected  Member  States.  This 
provides an overall understanding  of what  has been planned in  the Member States and how 
different it is from the EU measures implemented under the EMFF. 

Feedback gathered during the complementary interviews also highlighted that the impacts of 
the  changes  in  the  delivery  system  are  still  difficult  to  assess  as  managing  authorities  and 
intermediate bodies are still finalising some of the procedures (e.g., risk-based analyses, SCOs, 
etc.), which are expected to have the most impact on simplification. 

69 

 
 
The  monitoring  data  (Infosys)  provide  valuable  information  on  EMFAF  commitments  and 
spending as of 31 January 2024 at the project level, which allowed to look at achievements by 
specific  objective,  type  of  operations,  type  of  interventions  and  several  other  characteristics 
related to the beneficiaries or the nature of the operations. Nevertheless, these preliminary data 
do not reflect the future potential impacts of the EMFAF. Result indicators are also presented 
but are difficult to interpret given the varying levels of execution, and commitment by Member 
States is often a driving factor and not necessarily representative of the expected results. 

The feedback gathered through the survey of target groups provides valuable information on 
stakeholders’ perceptions of the programme and the application process. However, the lack of 
access  to  a  database  of  beneficiaries  meant  it  was  disseminated  by  sending  the  link  to 
intermediaries  at  the  national  level.  The  results,  therefore,  can  hardly  be  considered  as 
statistically representative. In addition, following significant difficulties encountered with the 
application process in one of the French outermost regions, the local professional organisation 
campaigned for their members to answer the survey. As a result, the French outermost regions 
tend to provide particularly negative feedback and to be overrepresented among the respondents 
(8.5% of the total sample). We have, therefore, separated answers from those respondents from 
the rest of the sample where relevant. 

Finally, as the managing authorities’ responses to the survey were critical to carrying out the 
analyses, and some of them, including Member States with a significant share of the EMFAF 
budget,  could  not  provide  it  within  the  initial  timeframe,  so  the  data  collection  period  was 
extended. Feedback was eventually received from the 26 managing authorities a month after 
the initial deadline. This delayed the selection of the Member States and the implementation of 
the  complementary  interviews,  which  were  sequential  to  the  survey.  While  these  were 
eventually conducted, the latest one took place on 27 May, two days before the study report's 
submission.  This  created  significant  time  constraints  when  triangulating  the  data  for  the 
analysis.  Data  from  the  last  interview(s)  was  ready  to  validate  the  findings,  in  case  of  any 
remaining gaps after the validation workshop.  

70 

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

Question 

Judgment criteria 

Indicators 

Data sources 

EFFECTIVENESS 

KEQ 1: To what extent is support 
under the EMFAF able> achieve 
the  specific  objectives  of  the 
EMFAF Regulation, namely: 

addressing 

(JC  1.1)  The  EMFAF  support  is 
effectively 
each 
specific objective activated in the 
programme,  including  in  relation 
to the implementation of the CFP. 

•  Strengthen  economically,  socially,  and 
fishing 

sustainable 

environmentally 
activities (P1 SO (a)) 

•  Contribute  to  the  adjustment  of  fishing 
capacity to fishing opportunities in cases of 
permanent  cessation  of  fishing  activities 
and to a fair standard of living in cases of 
temporary  cessation  of  fishing  activities 
(P1 SO (c)) 

•  Foster  efficient  fisheries  control  and 
enforcement,  including  fighting  against 
Illegal,  Unreported  and  Unregulated 
fishing,  as  well  as  reliable  data  for 
knowledge-based decision-making (P1 SO 
(d)) 

71 

•  Number  of  Member  State  who  have 

•  Desk research 

activated each SO 

•  Total budget allocation, types of actions per 

SO 

•  Regulatory 
Regulation 

framework: 

EMFAF 

•  Core  performance 

indicators  of 

the 

•  Number of operations already carried out at 

EMFAF (EMFAF Regulation Annex I) 

Member State/SO 

•  Amounts  and  %  of  EMFAF  funding  by 
type of operation and type of intervention, 
progress towards funding targets. 

•  Progress  on  milestones  in  the  national 
EMFAF programmes and result indicators 
at  SO 
in  shared 
level  (i.e.  Infosys) 
management, is in-line with expectations. 

on 

data 

•  Monitoring 
achievements 
landing  obligation,  climate 
regarding 
(gender 
emergency,  non-discrimination 
equality  and 
rights  of  people  with 
disabilities)  and  additional  tonnage  of 
vessels. 

•  Feedback 

from 
Commission staff on: 

MA's/European 

data: 

•  Monitoring 

"Infosys",  Data 
transmitted  under  Art.42  CPR  via  SFC, 
Open Data Platform 

•  Field research 

•  Survey of managing authorities 

•  Interviews  with  key  stakeholders  at  EU 

level (interest groups) 

•  Complementary 

interviews  with  key 

stakeholders at national level 

•  Survey of target groups 

 
 
•  Contribute  to  a  level-playing  field  for 
fishery and aquaculture products from the 
outermost regions (P1 SO (e)) 

•  Contribute to the protection and restoration 
of aquatic biodiversity and ecosystems (P1 
SO (f)) 

•  Contribute 

to  sustainable  aquaculture 
the 
activities,  especially  strengthening 
aquaculture 
competitiveness 
production,  while  ensuring 
the 
activities  are  environmentally  sustainable 
in the long term (P2 SO (a)) 

that 

of 

•  Contribute to marketing, quality and added 
value of fishery and aquaculture products, 
as well as the processing of those products 
(P2 SO (b)) 

•  Contribute  to  enabling  a  sustainable  blue 
economy  in  coastal,  island  and  inland 
areas,  and  to  fostering  the  sustainable 
development  of  fishing  and  aquaculture 
communities (P3 SO) 

•  Contribute to strengthening sustainable sea 
and  ocean  management 
the 
promotion of marine knowledge, maritime 
surveillance,  or  coast  guard  cooperation 
(P4 SO). 

through 

(JC  1.2)  The  EMFAF  support  has 
lessons 
benefited 
from 
the 
learned/recommendations 
previous period. 

from 

(JC 1.3) The EMFAF support addresses 
different target groups adequately. 

•  planned delays 

•  enabling  and  limiting  factors  which 
impact  the  capacity  to  achieve  the 
objectives 

•  mitigation 
application 

strategies 

and 

their 

•  Feedback  from  beneficiaries  on  expected 

results 

•  Main  lessons  and  recommendations  from 
including  mid-term 
indirect 

previous  period, 
evaluation  of 
management part of the EMFF. 

the  direct  and 

•  National  programme  documents  include 
main  lessons  learned  /  recommendations 
from mid-term evaluations. 

•  European 

Commission 

stakeholders 
confirm  integration  of  lessons  within  the 
regulatory framework. 

•  MAs confirm integration of main lessons, 
factors limiting or enhancing uptake of key 
lessons, and early identified benefits. 

•  EU  and  national  stakeholder  feedback 
confirms  that  the  EMFAF  is  benefiting 
from  lessons  learned  from  the  previous 
period. 

•  Target groups listed in NPs (incl. direct and 
types  of 

indirect  beneficiaries),  and 
beneficiaries in Infosys 

•  Application  success  rates  per  Member 

State / per target group (if available) 

72 

•  Desk research 

•  Regulatory 

framework: 

EMFAF Regulation, EMFF Regulation 

•  EMFAF  documents:  national  EMFAF 

programmes  

•  Additional literature: previous studies and 

evaluations 

•  Field research 

•  Survey of managing authorities 

•  Interviews  with  key  stakeholders  at  EU 

level 

•  Complementary 

interviews  with  key 

stakeholders at national level 

•  Desk research 

•  EMFAF documents: Target groups per UP 

data: 

•  Monitoring 

"Infosys",  Data 
transmitted  under  Art.42  CPR  via  SFC, 
Open Data Platform 

 
•  MA  feedback  on  target  groups  with  low 

•  Field research 

•  Survey of target groups 

•  Interviews with key stakeholders at EU level 

•  Complementary 

interviews  with 

stakeholders  at  national 
groups) 

level 

key 
(interest 

success rates and explanations. 

•  Amount  of  EMFAF  per  beneficiary  type, 

including producer organisations 

•  Selection criteria, progress made on under-

represented groups. 

•  Implications  of  the  end  of  pre-defined 

measures at EU level 

•  EU  and  national  stakeholders,  applicants 

and beneficiaries report: 

•  possible  challenges  faced  by  some 
specific target groups to access EMFAF 
support 

•  adequacy  of  EMFAF  support  on  the 

application and contract process. 

(JC  1.4)  EMFAF  support  addresses  the 
durability  of  interventions  after  the  end 
of 
individual, 
the  funding,  both  at 
institutional and policy levels. 

•  Typology of types of operations funded at 
this  stage  based  on  their  potential  to  be 
durable, for example e.g. compensation has 
a low durability potential, training, control, 
capacity  building,  etc.  have  a  high 
durability potential) 

•  Levels  of  funding  allocated  to  most  and 
least durable types of operation. according 
to their likely durability 

•  Desk research 

•  EMFAF  national  EMFAF  programme 

documents 

•  Field research 

•  Survey of managing authorities 

•  Complementary 

interviews  with  key 

stakeholders at national level 

(JC1.5)  The  EMFAF  support  addresses 
visibility of the EMFAF interventions to 
the  public  (in  general  and  per  Member 
State  /  region  /  stakeholder  group  in 
particular). 

•  Managing 

a 
authorities 
communication  strategy  in  place,  with 
specific  objectives/targets,  target  groups, 
and monitoring arrangements. 

have 

• The  European  Commission  and  all 
managing  authorities  confirm  activities  to 
the  EMFAF 
support  the  visibility  of 

73 

•  Desk research 

•  Review  of  European  Commission  and  MA 

websites / social media 

•  EMFAF  documents:  Communication  and 
analytics, 

dissemination  material 
national EMFAF programmes 

and 

 
funding  opportunities/calls  and  results 
among (there is evidence on-line): 

•  Have an EMFAF website/webpages up and 

running 

•  Communicate  about  the  EMFAF  on  their 
website,  via  information  sessions,  social 
media 

•  Field research 

•  Survey of managing authorities 

•  Survey of target groups 

•  Interviews with key stakeholders at EU level 
(DG MARE, FAMENET, interest groups) 

•  Provide 

information 

policy 
objectives,  calls  for proposals,  criteria  for 
selection, FAQs, and results 

about 

•  Have  developed  tools  for  the  public: 

infographics, videoclips, etc. 

•  Beneficiaries,  applicants,  and  national 
stakeholder  confirm  expectations  met  re. 
the ease access, clarity of information and 
ease of application process, availability of 
support. 

•  Beneficiaries  confirm  understanding  of 
in 

undertaken 

visibility 
compliance with Article 60. 

activities 

The 

financial 
(JC1.6) 
instruments  are  effectively  addressing 
the objectives? 

EMFAF 

•  Data and feedback on number and quality 
of  applications  for  funding  from  different 
target groups, met targets set. 

•  Documentary evidence on: 

•  Desk research 

•  Number of Member States using financial 

•  Regulatory framework: EMFAF Regulation 

instruments  

•  EMFAF  documents:  national  EMFAF 

•  Number and types of financial instruments 

programmes 

most used per SO 

•  Number  of  projects  supported  through 
financial  instruments  per  Member  State, 
per SO 

•  Feedback from managing authorities on: 

•  Data from Infosys 

•  Field research 

•  Survey of managing authorities 

74 

 
(JC2.1)  The  EMFAF  delivery  system 
supported  structural  improvements  to 
allow  Member States 
their 
national  systems  to  better  support  their 
needs. 

tailor 

to 

KEQ  2:  To  what  extent  is  the  EMFAF 
programme delivery system effective? 

(JC2.2)  The  EMFAF  delivery  system 
builds  on  appropriate  structures  and 
processes. 

•  Appetite/interest  in  financial  instruments 
(loans/guarantees) in the Member State 

•  Complementary 

interviews  with 
stakeholders at EU and national level 

key 

•  Reasons  for  (not)  using  the  financial 

instruments 

•  Availability  of  private  investment  in  the 

Member States 

•  Evidence of changes to systems described 

in national programme documents. 

•  Feedback from managing authorities on: 

•  Types  of  structural  changes  since  the 

•  Desk research 

introduction of the EMFAF 

•  The 

impact/benefits  of  any  structural 

changes 

•  The take-up/effectiveness of an online data 

exchange platform/system. 

•  Reasons  why  structural  changes  were  not 

implemented and/or required. 

•  Potential 

structural 
sustainability  of 
changes  and  their  resilience  to  future 
challenges 

•  Impact  of  end  of  pre-defined  measures  at 

EU level. 

•  EMFAF documents: national programmes, 

•  Additional  literature:  previous  studies  and 

evaluations 

•  Field research 

•  Survey of managing authorities 

•  Interviews with key stakeholders at EU level 

•  Complementary 

interviews  with 

key 

stakeholders at national level 

•  Documentary 

evidence 

confirms 
governance structures in place, with clarity 
on  roles  and  responsibilities,  appropriate 
and timely decision-making chains, lack of 
bottlenecks. 

•  European  Commission  and  managing 
authority  assessments  of  the  effectiveness 
of the: 

75 

•  Desk research 

•  EMFAF documents: national programmes, 

•  Additional  literature:  previous  studies  and 

evaluations 

 
•  Governance 

structure 

(scale: 

high, 

medium, low) 

•  Procedures 

implemented 

(scale:  high, 

medium, low) 

•  System  for  "collection,  management  and 
use of data" (scale: high, medium, low) 

•  Procedures  for  the  evaluation  of  projects 

(scale: high, medium, low) 

•  Usefulness of comprehensive action plans 

for outermost regions. 

•  Feedback  on  national  administrative 
approaches,  which  enhance  or  hinder 
EMFAF processes. 

•  Review 

of 

framework 
performance 
methodology papers confirms adjustments 
made. 

•  Degree  to  which  the  EMFAF  delivery 
system  aligns  with  and  effectively 
implements  the  content  and  requirements 
the  national  performance 
specified 
framework methodology papers. 

in 

•  Desk research 

•  Regulatory 

framework: 

CPR, 

EMFAF Regulation 

•  EMFAF  documents:  National  programmes, 
Performance framework methodology paper 

•  Identification  of  the  good  practices  and 
lessons learned in the delivery system. 

•  Desk research 

•  Regulatory 

framework:  CPR,  EMFAF 

•  Feedback  from  European  Commission 

Regulation, EMFF Regulation 

staff / managing authorities on: 

•  EMFAF  documents:  national  EMFAF 

•  Main adjustments to the delivery system. 

programmes 

•  Main benefits identified. 

76 

(JC2.3)  The  EMFAF  delivery 
system  is  adequately  adjusted  to 
the  content  of  the  performance 
framework  methodology  paper 
national 
submitted 
authorities 
their 
EMFAF 
programme 
(shared management). 

the 
by 
together  with 

(JC2.4)  The  EMFAF  delivery  system 
benefits  from  lessons  learned  from  the 
previous period. 

 
•  Other consequences of integrating lessons 
learned  and  differences  in  experiences  by 
Member State. 

•  Additional  literature:  previous  studies  and 

evaluations 

•  Field research 

The 

2.5) 

of 
(JC 
stakeholders  was  effective 
the 
preparation of the EMFAF programmes. 

involvement 
in 

•  Documentary 

relevant 
evidence 
partners  were  identified  in  line  with  CPR 
Article 8 / consistency in the performance 
framework methodologies. 

that 

•  MA  feedback  that  relevant  stakeholders 
supported the identification of priorities. 

•  MA  feedback  that  target  values  for  the 
performance  framework  were  based  on 
reliable  data  or  evidence  and  supported 
effective implementation.  

•  Stakeholders’  feedback  their  involvement 
the  EMFAF 

the  preparation  of 

in 
programmes. 

(JC2.6)  The  EMFAF  delivery  system 
builds  on  the  necessary  organisational 
capacity  and  resources  (i.e.  consistency 
in the  allocation of budgetary resources 
to  the  objectives  of  the  programme)  to 
effectively manage the programme. 

•  Data on share of EMFAF allocated by SO, 
and 

consideration 
comparisons across Member State. 

ratio  EUR/project 

•  European  Commission  and  MA  staff 

perceptions of: 

•  Capacity  and  functioning  of  each  step  of 

the delivery system at national level; 

•  aspects  of  the  delivery  system  that  work 
inconsistent  or 

to 

less  well 
insufficient staff capacity. 

/  due 

•  Survey of managing authorities 

•  Interviews with key stakeholders at EU level 

•  Complementary 

interviews  with 

key 

stakeholders at national level 

•  Desk research 

•  Regulatory 
Regulation 

framework:  CPR,  EMFAF 

•  EMFAF  documents:  national  EMFAF 

programmes 

•  Field research 

•  Survey of managing authorities 

•  Interviews with European Commission staff 

•  Complementary 

interviews  with 

key 

stakeholders at national level 

(JC2.7)  The  EMFAF  delivery  system 
builds on staff with the necessary skills, 
to 
capacities,  and 

resources 

time 

•  Data  on  FTEs  and  comparison  between 
levels  of  staff  capacity  at  European 

•  Desk research 

77 

 
effectively  manage  the  programme  and 
implement simplification measures. 

Commission  and  Member  State 
(FTEs) and volume of funds allocated 

level 

•  Regulatory 
Regulation 

framework:  CPR,  EMFAF 

•  Data on external costs and comparison with 

•  EMFAF  documents:  national  EMFAF 

volume of funds per Member State. 

•  Managing authority feedback on: 

programmes 

•  Field research 

•  Adequacy of HR allocations/capacity. 

•  Survey of managing authorities 

•  Presence  of  dedicated  teams  or  units 
responsible for EMFAF implementation 

•  Specific  qualifications / level of expertise 
of  EMFAF 

charge 

of 
in 
staff 
implementation 

(JC2.8)  The  EMFAF  delivery  system 
builds on improved communication with 
potential  beneficiaries  compared  with 
the previous period. 

•  Appropriate training and capacity building 
in  charge  of  EMFAF 

the  staff 
for 
implementation 

•  Managing 

confirm 
authorities 
improvements to measures implemented to 
improve the communication of information 
among relevant parties involved in EMFAF 
implementation, 
between 
national  and  regional  authorities  and 
potential  beneficiaries,  which  might 
include: 

including 

•  Speed of response to queries 

•  Use of FAQs 

•  Availability of helplines 

•  Infodays and workshops 

•  Interviews with European Commission staff 

•  Complementary 

interviews  with 

key 

stakeholders at national level 

•  Desk research 

•  EMFAF  documents:  national  programmes 
and performance framework methodologies. 

•  Field research 

•  Interviews with European Commission staff 

•  Survey of managing authorities 

•  Complementary 

interviews  with 

key 

stakeholders at the national level 

•  Survey of target groups 

(JC  2.9)  The  EMFAF  delivery  system 
has  

appropriate quality assurance installed. 

•  Managing  authorities  confirm  that  they 
have  procedures  in  place  to  ensure  that 
the  eligibility 
selected  projects  meet 

•  Field research 

•  Survey of managing authorities 

•  Feedback from desk officers 

78 

 
the  Common  Provision 
criteria  of 
Regulation and of the EMFAF Regulation 

•  Evidence of improvements made to reduce 
the number errors during audit procedures 

Question 

Judgment criteria 

Indicators 

Data sources 

EFFICIENCY 

the 

KEQ 3: To what extent 
is 
EMFAF 
implementation  system 
efficient? 

(JC  3.1)  EMFAF  interventions 
are  implemented  at  a  reasonable 
cost  to  the  administration  and 
beneficiaries. 

Estimated  implementation  costs  (human  resources  and  external 
costs)  at  national  and  EU  level/Total  EMFAF  budget  and 
comparison  with  previous  programming  periods  and  other  EU 
Funds. 

support/job 

EMFAF 
or  maintained,  EMFAF 
support/business  created,  EMFAF  support/person  trained  and 
comparison with other EU funds 

created 

•  Managing authorities report: 

•    The 

level  of  administrative  burden 

in  programme 
management is appropriate compared with EMFF / other programmes, 
considered by Member State. 

involved 

•  Desk research 

•  EMFAF  documents:  national  programmes 

(information on governance) 

•  Infosys data 

•  EMFF evaluations 

•  Field research 

•  Survey of managing authorities 

•  Survey of target groups  

•  Interviews  with  EU 

and 
stakeholders (direct management) 

national 

•  Interviews  with 

selected  managing 

authorities 

79 

 
 
 
 
 
•    Applicants and beneficiaries report that  time spent on applications, 
and reporting / cost of external support is appropriate considering the 
funding made available. 

•    Potential unnecessary costs have been or are being addressed 

Inefficiencies 

(JC3.2) 
and 
obstacles  have  been  identified 
and  solutions  put  in  place  to 
overcome them. 

MAs  and  European  Commission  staff  report  that  they  have 
identified  solutions  to  inefficiencies  and  obstacles  at  EU  and 
national levels and solutions put in place since the launch of the 
programme. 

•  Field research 

•  Survey of managing authorities 

•  Interviews  with  European  Commission 

staff 

(We  have  moved  two  JCs  on 
lessons  learned,  including  from 
EMFF, from KEQ 4 and included 
them  as  an  indicator  to  support 
this JC). 

Insights from the previous programme and lessons learned have 
supported simplification measures / ways to address obstacles. 

•  List  of  process  improvements  by  Member  State  /  at  EU  level  as 

reported in interviews/ via the surveys 

(JC4.1)  EMFAF  implementation 
has  been  simplified  compared 
with the previous programme and 
simplification  measures  benefit 
from lessons learnt. 

Managing authorities confirm: 

•   Use of simplification measures 

•  Answer to KEQ 2 

•  Desk research 

•   Use  of  the  electronic  data  collection  system  has  reduced  admin 

burden. 

Indicators of increased programme efficiency 

•  Regulatory 

framework: 

CPR, 

EMFAF Regulation 

•  EMFAF  documents:  National  programmes, 
Performance framework methodology paper 

(JC4.2)  The  EMFAF  delivery 
system 
efficient 
implementation of simplification 
measures. 

assures 

an 

•  Descriptions/documentation 

on 
administrative processes and steps required 
for 
selection, 
implementation  and  reporting  compared 
with the previous programming period under 
shared/direct management 

application, 

project 

Reduced admin burden compared with the past (EMFF) 

Legal  requirements,  rules  of  procedures  or  practices  that  create 
disproportionate administrative burden at the EU or Member State 
level 

80 

KEQ 4: To what extent 
simplification 
are 
measures 
efficiently 
installed? 

(We  have  not  included 
the JC on simplification 
measures 
to  address 
different  target  group 
needs 
is 
under 
addressed 
relevance.) 

this 

as 

 
 
 
 
 
•  Additional 

literature:  previous  studies, 
including  on  the  impact  of  externalities  on 
the  seafood  sector,  FAME  SU  Working 
paper EMFAF simplified cost options 

•  Field research 

•  Survey of managing authorities 

•  Survey of target groups 

•  Interviews with key stakeholders at the EU 
level  (DG  MARE,  DG  ENV,  FAMENET, 
interest groups) 

•  Complementary 

key 
stakeholders at the national level (managing 
authorities, intermediate bodies) 

interviews  with 

(JC4.3) There were improvements 
to governance and implementation 
resulting from the simplification of 
processes 
administrative 
requirements, 
(application 
procedures, 
selection 
implementation 
reporting 
obligation)  and  of  the  monitoring 
system, which can be observed by 
strand (shared/direct). 

and 

(JC4.4) There are no (other) areas 
where  simplification  could  be 
pursued further, without impacting 
the  quality  of  results?  (We  have 
slightly amended this JC.) 

Evidence of external effects 

Positive stakeholder feedback 

Answer to KEQ 2 

European Commission staff and managing authority quantitative 
data on staff time / external costs, etc. 

European Commission staff and managing authority qualitative 
assessments of: 

•  feedback on reduced number of steps 

•  staff/decision-making, 

•  paperwork 

•  increased automation 

•  maintenance to quality standards 

•  identification of gaps, challenges and unexpected benefits that may 

have arisen, as a result of streamlining 

•  other possible options for simplification 

Satisfaction  of  applicants  and  beneficiaries,  feedback  on 
improved experience (faster, easier, processes, etc.).  

81 

 
 
 
 
 
 
Question 

RELEVANCE 

KEQ  6:  To  what  extent  is  the  delivery 
system able to respond to changing needs? 

Judgement criteria 

Indicators 

Data sources 

(JC6.1)  The  EMFAF  responds 
adequately  to  changing  needs  of 
different target groups (new types 
of expectations of next generation, 
new  skills  and  capacities,  new 
customer requirements) 

(To  avoid  repetition,  we  have  not 
included  Green  Deal  and  policy 
changes as these will be discussed 
under  coherence  and  external 
climate 
challenges:  war 
under 
change 
efficiency 
and 
flexibility 
financial 
instruments.) 

discussed 
(simplification 

and 

are 

of 

(JC6.2)  The  EMFAF  delivery 
system 
to 
support the EMFAF in responding 
international  dimension 
to 

flexible  enough 

the 

is 

•  Managing authorities confirm: 

•  Desk research 

•  mechanisms  exist  to  regularly  update  (or  whenever  there  are 

•  EMFAF 

relevant contextual changes) the needs assessment,  

•  Programmes have been drafted to leave room for uncertainty. 

•  Documentary evidence on 

•  the  implementation  measures  included  in  the  legal  framework 

addresses emerging needs. 

•  Stakeholders at EU and national level confirm: 

documents: 
intervention 
EMFAF 

programme 
logic, 
programmes  

national 

identified 

•  Additional  literature:  Studies 
trends  and 
Commission's 

on 
needs, 
Megatrends Hub 

•  the relevance of EMFAF SOs to current and emerging EU/national 

•  Field research  

priorities,  

•  Survey 

of 

managing 

•  that their feedback was considered in a timely way to support the 

authorities 

needs assessment and its updates 

•  The different target groups confirm that: 

•  The programme addresses the overall needs of the sector (including 

economic, social and environmental needs) 

•  implementation  measures  meet  expectations  and  are  suitable  for 
evolving  needs  among  potential/actual  beneficiaries,  including 
supporting  the  development  of  new  skill  sets,  the  needs  of  new 
types  of  beneficiaries,  including  relation  to  particular  crises 
COVID, economic crisis, energy crisis. 

•  Perceptions of the implications of the end of mandatory funding of 

POs 

•  There  is  data  to  confirm  capacity  to  respond  to  the  international 

dimension (voluntary contributions to RFMOs). 

•  MAs  provide  examples  to  approach  to  managing  voluntary 

contributions/enabling and limiting factors.  

82 

•  Survey of target groups 

with 

•  Interviews 

key 
stakeholders  at  EU  and 
national levels  

Survey  of  managing 
authorities 

 
 
 
with 

Interviews 
key 
stakeholders  at  EU/national 
level 

•  Desk research 

•  EMFAF  documents:  national 

EMFAF programmes 

•  Field research  

•  Survey 

of 

managing 

authorities 

with 

•  Interviews 

key 
stakeholders  at  EU/national 
level 

•  Complementary interviews at 

Member State level 

(voluntary 
RFMOs). 

contributions 

to 

and 

relevance 

(JC6.3)  Under  the  EMFAF,  the 
shape  and  scope  of  the  strand 
achieved 
(direct/indirect/shared) 
greater 
more 
the 
budgetary 
of 
management 
procedures/processes  (related  to 
application, selection, reporting) to 
respond  to  policy  priorities  and 
stakeholders' needs?  

flexibility 

in 

(We  slightly  reworded  this  JC  to 
enhance clarity.) 

strands 

identified 

The 
and 
involved  relevant  stakeholders  in 
its 
and 
governance 
implementation? 

•  Documentary  evidence/data  on  main 

to 
application  process,  selection  criteria,  and  reporting,  as  well  as 
budgetary  flexibility  to  respond  to  changing  stakeholder  needs  / 
policy priorities. 

types  of  changes 

•  Data  to  confirm  Member  States'  use  of  selective  criteria,  when 

choosing aquaculture and fisheries projects. 

•  Managing authorities, EU staff confirm: 

•  types of adjustments made to address changing beneficiary needs, 
the  external 

changing  policy  environments,  challenges 
environment, the international dimension. 

in 

•  adequate  use  of  the  Fund  to  achieve  the  objectives  of  EU 
the  multiannual  national  plans  for 

aquaculture  policy  and 
aquaculture. 

•  which changes were adopted by strand with what result; and 

•  enabling  and  limiting  factors  determining  the  flexibility  of  the 

EMFAF delivery system. 

•  Desk research and assessment of the: 

•  diversity  of  representation  of  different  groups  of  stakeholders 

involved in supporting governance; and 

•  frequency  of  consultation  processes 

to  gather 

input  from 

stakeholders on governance and implementation. 

•  European Commission staff, managing authority, EU and national 

stakeholder feedback on: 

•  pros and cons and areas for improvement in the stakeholder input 

process 

•  extent  to  which  stakeholders'  input  has  influenced  the  strand's 
decision-making,  resource  allocation,  relevance,  and  capacity  to 
identify and respond to change. 

83 

 
 
 
 
Question 

COHERENCE 

Judgement criteria 

Indicators 

Data sources and methods 

KEQ  7:  To  what  extent  is  the  EMFAF 
internally and externally coherent?  

(JC7.1.1)The 
EMFAF 
interventions  are  complementary  and 
coherent with the objectives of the CFP. 

different 

7.1  To  what  extent  is 
internally coherent? 

the  EMFAF 

(JC7.1.2)The 
EMFAF 
interventions  generate  synergies  and/or 
compensate trade-offs between them. 

different 

•  Documentary  evidence  and  data  confirms 
internal  coherence  between  the  objectives 
and priorities of the CFP and the objectives 
and priorities of the EMFAF programmes, as 
well the allocation of resources to inputs. 

•   

•  EU stakeholders' feedback on the coherence 
of the EMFAF direct management and with 
the CFP objectives and priorities. 

•  Desk research 

•  Intervention logic 

•  EMFAF  documents:  national  EMFAF 

programmes  

•  CFP Regulation Field research 

•  Survey of managing authorities 

•  Interviews with key stakeholders at EU and 

national levels 

•  Managing 

authorities', 

national 
stakeholder  feedback  on  synergies  and/or 
trade-offs between EMFAF interventions 

and 

7.2  To  what  extent  is 
externally coherent? 

the  EMFAF 

(JC  7.2.1)  EMFAF 
coherent with: 

interventions  are 

the national and regional objectives 

the objectives of the European Green Deal 
(including all policy initiatives/areas) 

Other  relevant  EU  policies  (Common 
Agriculture  Policy  strategy  plan,  ERDF, 
ESF,  EU 
legislation 
environmental 
(MSFD,  WFD,  Habitats  and  Birds 
Directives),  and  funds  (Horizon  Europe 
and LIFE, etc.) 

the  international  dimension  (voluntary 
contributions  of  Regional 
fisheries 
management organisations (RFMOs)) 

•  MAs and national stakeholders confirm that 
EMFAF  interventions  support  national  and 
generate 
regional 
objectives/may 
or 
synergies/there 
contradictions. 

overlaps 

are 

no 

•  Documentary  evidence  confirms  that  the 
EMFAF  design  is  aligned  with  other  EU 
policies and programmes. 

•  EU  stakeholders  and  staff  in  DG  ENV 
confirm  that  the  design  of  the  EMFAF 
complements  other  relevant  EU  policies 
(external coherence) and funds. 

•  MAs  and  European  Commission  staff 
confirm  the  assessment  of  coherence  was 
included  in  the  EMFAF  monitoring  and 
evaluation system 

•  Desk research 

•  Intervention logic 

•  EMFAF  documents:  national  EMFAF 

programmes  

•  Policy and programming documents relating 
to other relevant EU policies and funds. 

•  Field research  

•  Survey of managing authorities 

•  Interviews  with  key  stakeholders  at  EU 

level, DG ENV. 

•  Complementary interviews at Member State 

level  

84 

 
 
 
 
 
 
 
 
 
 
 
85 

 
 
 
Question 

Judgement criteria 

Indicators 

Data sources and methods 

EU ADDED VALUE 

KEQ 8: To what extent would outputs and 
results  be  achieved  without  EMFAF 
support/EU intervention? 

(JC  8.1)  Policy-related  outputs  and 
objectives would not be achieved without 
EMFAF interventions. 

(JC8.2) EMFAF is generating additional, 
earlier,  and  higher  quality  outputs  and 
results  than  individual  Member  States 
acting  on  their  own  at  the  national  or 
regional level. 

•  Documentary evidence on how the EMFAF 
adds value at national and regional level. 

•  Feedback 

from  managing 

authorities, 

national stakeholders, and beneficiaries: 

•  Desk research 

•  Additional  literature:  impact  assessment 
accompanying the proposal for a regulation 
on the EMFAF 

•  on  the  availability  of  other  equivalent 

•  Infosys 

funding sources 

•  that the EMFAF extends the coverage of EU 
policy objectives at national level, in relation 
to number and type of priorities/SOs that are 
funded at national level. 

•  Monitoring  data  confirms  that  results  are 

being achieved. 

•  Managing authorities confirm: 

•  that the overarching, homogenous approach 
provided  by  the  EMFAF  is  starting  to 
generates  outputs  and  results,  which  could 
not otherwise be achieved 

•  Evidence from answers to effectiveness and 

efficiency. 

•  Field research  

•  Survey of national authorities 

•  Interviews with key stakeholders at EU level 

•  Complementary interviews at Member State 

level 

•  programme  synergies,  and  lessons  learning 
regional 

enhancing  national 

and 

is 
approaches; 

•  the speed, quality and types of results being 
generated  through  the  EMFAF  could  not 
otherwise be achieved 

•  the 

consequences 
withdrawing EU intervention 

of 

stopping 

or 

86 

 
 
 
 
 
9.  ANNEX IV. OVERVIEW OF BENEFITS AND COSTS AND TABLE ON SIMPLIFICATION AND BURDEN REDUCTION 

Table 13: Overview of costs and benefits identified in the evaluation69 

Citizens/Consumers  

Businesses 

Administrations 

Quantitative   Comment 

Quantitat
ive  

Comment 

Quantitative  Comment  

Other 

Quan
titati
ve 

Comment 

Cost or Benefit description: 

compliance 

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

One-off 

compliance 

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

Recurrent 

Marginal 
compared  with 
the 
overall 
EMFAF 
budget 

Resources 
allocated at the EU 
level 
(DG MARE 
staff) 

58-68 million   Estimated 

resources  allocated 
to  managing  and 
implementing 
the 
programme/year  at 
the national level. 

(Partially 
funded 
through  EMFAF 

Administrative costs 
beneficiaries: 
for 
survey 
63% 
of 
respondents 
spent 
more than 3 days on 
application 
the 
plus 
process, 
external  costs 
for 
31%. 

than 

Administrativ
for 
e  costs 
beneficiaries 
other 
businesses. 
Application 
processes 
more 
consuming 

time-

69 Where there is a prior impact assessment, the table should contain as a minimum the costs/benefits identified in the IA with the information gathered on the actual cost/benefit. 
As  available,  the  table  should  include  the  monetisation  (€)  of  the  costs/benefits  based  on  any  quantitative  translation  of  the  data  (time  taken,  person  days,  number  of 
records/equipment/staff etc. affected or involved represented in monetary value – see Standard cost model, for example). For all information presented, it should be included in 
the comments section whether it relates to all Member States or is drawn from a subset. An indication of the robustness of the data should be provided in Annex II on Methodology 
and analytical models used. 

87 

 
 
 
 
 
 
 
 
 
 
 
 
 
Citizens/Consumers  

Businesses 

Administrations 

Quantitative   Comment 

Quantitat
ive  

Comment 

Quantitative  Comment  

Other 

Quan
titati
ve 

Comment 

technical 
assistance) 

67%  considered  the 
total cost reasonable 
compared  with  the 
amount  of  support 
received  (compared 
with 
10%  who 
disagreed). 

88 

than 

for 
beneficiaries 
other 
businesses 
(producer 
organisations 
(POs), 
research, 
local 
action 
groups setting 
Only 
up). 
50% 
of 
respondents 
other 
private 
enterprises 
agreed 
the 
application 
costs 
reasonable, 
and 
disagreed. 
The 
negative 
assessments 
came 
Research 

most 

from 

were 

than 

28% 

that 

 
 
Citizens/Consumers  

Businesses 

Administrations 

Quantitative   Comment 

Quantitat
ive  

Comment 

Quantitative  Comment  

Other 

Quan
titati
ve 

Comment 

centres 
POs. 

and 

Marginal 
compared  with 
overall 
the 
EMFAF 
budget 

Resources 
allocated at the EU 
(DG MARE 
level 
staff) 

It  could  not  be 
isolated  from  the 
administrative 
costs. 

Direct 
support 
through  investments 
and 
compensation 
measures 

Direct 
support 
through  funding  of 
collection, 
data 
control 
and 
enforcement 

Direct support 
through 
funding 
research 
projects, 
community-
led 

local 

89 

Recurrent 

costs 

(costs 
Enforcement 
associated with activities linked 
to  the  implementation  of  an 
initiative  such  as  monitoring, 
inspections,  and  adjudication/ 
litigation) 

Recurrent 

costs 

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

n/a 

Direct benefits 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Citizens/Consumers  

Businesses 

Administrations 

Quantitative   Comment 

Quantitat
ive  

Comment 

Quantitative  Comment  

Indirect benefits 

Actions  aimed  at 
protecting 
the 
environment  and 
mitigating  climate 
change 
benefit 
access  to  quality 
food from fisheries 
aquaculture 
and 
products. 

Support 
through 
transfers  to  general 
services  promoting 
the  development  of 
fisheries 
and 
aquaculture sectors 

measures, technical 
assistance 

for 

Support 
the 
implementation  of 
Common 
the 
Policy 
Fisheries 
(CFP) 
and 
integrated maritime 
policy (IMP) 

Other 

Quan
titati
ve 

Comment 

development, 
POs 
Production 
and 
Marketing 
Plans, etc 

for 

Support 
the 
implementati
on of the CFP 
and IMP 

90 

 
 
 
 
 
 
 
 
 
 
Table14: Simplification and burden reduction (savings already achieved)  

Citizens/Consumers/Workers 

Businesses 

Administrations 

Other 

Quantitative  

Comment 

Quantitative   Comment 

Quantitative 

Comment  

Quantitativ
e 

Due to early stage of implementation simplification and burden reduction (savings already achieved) of EMFAF operations could not be analysed. 

Type: One-off / recurrent (select) 

91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table15: PART II: II Potential simplification and burden reduction (savings)70. 

Citizens/Consumers/Workers 

Businesses 

Administrations 

Other 

Quantitative  

Comment 

Quantitative   Comment 

Quantitative 

Comment  

Quantitativ
e 

Due to early stage of implementation simplification and burden reduction (savings that could be achieved) of EMFAF operations could not be analysed 

Type: One-off / recurrent (select) 

70  This can be revisited in the context of the retrospective EMFAF evaluation foreseen for end 2031. 

92 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10.  ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

This annex summarises all stakeholder input from the consultation through “Have your say” on 
the  Call  for  Evidence  as  well  as  the  Public  Consultation  questionnaire.71  In  addition,  it 
summarises all consultation activities undertaken by the external study conducted on behalf of 
DG MARE to support the evaluation.  

Starting  with  the  consultation  through  “Have  your  say”,  in  line  with  Article  45(1)  of  the 
Common Provisions Regulation (EU) No 2021/1060, the Commission is required to carry out 
a mid-term evaluation of the EMFAF. In accordance with this obligation and in compliance 
with the Better Regulation Guidelines, DG MARE launched a public consultation aiming to 
gather  evidence  and  different  perspectives  on  the  management  and  use  of  the  funding.  The 
consultation started on the 6 June 2024 and ended on the 13 September 2024. This report should 
be regarded solely as a summary of the contributions made by stakeholders and citizens on the 
Call  for  evidence  and  also  on  the  basis  of  an  EU  survey  (questionnaire)  in  all  official  EU 
languages,  both  publicly  available  through  the  “Have  your  say”  portal.  It  cannot  in  any 
circumstances be regarded as the official position of the Commission or its services. Responses 
to the consultation activities cannot be considered as a representative sample of the views of 
the EU population. 

The feedback gathered by stakeholders is presented below following the 5 criteria under the 
Better Regulation  Guidelines (on the effectiveness,  efficiency, relevance, coherence and EU 
added value). 

THE RESPONDENTS 

Regarding the feedback  received on the Call for  evidence through “Have Your Say portal”, 
there were 42 comments from different organisations, ranging from public authorities to NGOs 
and  businesses  associations.  The  vast  majority  comes  from  Spain  with  a  26%  of  the  total, 
followed by France and Belgium with a 19% each of the total.  

Most of the contributions come from business associations accounting for 38% of the total (16 
comments), followed by non-governmental organisations accounting for 29% of the total (12 
comments) and public authorities accounting for 19% of the total (8 comments). 

71   Call for Evidence and Public Consultation on the mid-term evaluation of the European Maritime, Fisheries and 
Aquaculture Fund (EMFAF) for 2021-2027. Available at: https://ec.europa.eu/info/law/better-regulation/have-
your-say/initiatives/14119-EU-Maritime-Fisheries-and-Aquaculture-Fund-EMFAF-2021-2027-midterm-
evaluation_en 

93 

 
 
 
Figure 16: Response rate per country 

Source: supporting study carried out by the consortium formed by Tetra tech, 2024 

Regarding the feedback on the EU Survey, the Commission received 16 replies which half of 
them corresponded to programme managers (e.g. managing authorities or intermediate bodies).  

Figure 17: Type of participants in the survey and share of replies 

Source: supporting study carried out by the consortium formed by Tetra tech, 2024 

94 

 
 
Most of the answers came from Spain, with up to 32% of the share.  

Figure 18: Response rate per MS 

Source: Supporting study carried out by the consortium formed by Tetra tech, 2024 

95 

 
 
 
 
EFFECTIVENESS 

Respondents  stress  that  the  success  of  EU  fisheries  and  aquaculture  policies  hinges  on  the 
development  of  clear  and  measurable  sustainability  and  animal  welfare  indicators.  These 
metrics are essential for tracking progress toward environmental and welfare objectives while 
ensuring that funding aligns with sustainable practices. 

They also argue that the industry’s transition to low-impact, climate-smart fisheries requires 
targeted  investment  in  modernising  vessels,  adopting  energy-efficient  technologies,  and 
improving  infrastructure.  Without  such  structural  modernisation,  the  green  transition’s 
effectiveness will remain constrained. 

Achieving equitable growth through funds like the EMFAF is closely tied to prioritising support 
for small-scale and coastal fisheries. These operations are often more sustainable but financially 
vulnerable  and  directing  funds  to  them  is  seen  as  key  to  fostering  meaningful,  sector-wide 
impact. 

To be effective across all EU regions, funding must also adapt to regional conditions, such as 
the  unique  needs  of  inland  aquaculture  or  outermost  regions.  Tailoring  policies  in  this  way 
ensures they remain responsive and applicable to diverse environmental and economic contexts. 

Participants of the public consultation stated that the effectiveness of both EMFF and EMFAF 
in  achieving  desired  objectives  was  rated  as  reasonably  effective.  Specific  areas  like 
implementing the Common Fisheries Policy scored well (31.25% rated it 7 out of 10, 18.75% 
rated it 10 out of 10).  

EFFICIENCY 

Respondents across emphasise that the effectiveness of EU funding is hindered by a lack of 
transparency and insufficient monitoring. Strengthening tracking and auditing processes is seen 
as  crucial  to  ensuring  funds  are  allocated  and  utilised  as  intended,  minimising  waste  and 
inefficiencies. 

Improved efficiency could also be achieved by linking funding to sustainability benchmarks. 
Making  funding  conditional  on  meeting  these  standards  would  discourage  support  for 
unsustainable practices and prioritise resource allocation to operators who are sustainable and 
responsible. 

Another challenge identified is the administrative burden associated with fund applications and 
compliance,  particularly  for  small-scale  and  artisanal  fishers.  Simplifying  these  processes 
would  make  funding  more  accessible  and  efficient,  enabling  quicker  and  more  impactful 
resource distribution. 

Economic incentives play a vital role in enhancing efficiency as well. Focusing on low-cost, 
high-impact  investments,  such  as  offering  low-interest  loans  for  vessel  upgrades,  would 
accelerate the adoption of sustainable practices across the industry. 

On cost-effectiveness and timely results, 50% of the respondents believed objectives were met 
to some extent, while 31.25% saw only minor success. Burdensome processes like reporting, 
audits, and project implementation were noted with many scoring these processes between 6 
and 10 on a scale of burden intensity.  

96 

 
COHERENCE 

Respondents stress that funding for fisheries and aquaculture must align with the EU Green 
Deal, Biodiversity Strategy, and Marine Action Plan. Achieving coherence is essential to ensure 
that  investments  and  subsidies  actively  support  climate  and  environmental  objectives  rather 
than undermining them by financing high-impact practices. In this regard, strong coherence was 
identified  between  the  funds  and  other  EU  initiatives  like  the  LIFE  programme  (50% 
reinforcement) and ERDF/CF (43.75% reinforcement).  

There is widespread agreement that animal welfare should be integrated into the sustainability 
objectives for aquaculture. Failing to include welfare indicators creates a disconnect between 
welfare goals and the EU’s broader sustainability ambitions, undermining the consistency of 
policy objectives. 

Many participants argue that EU funds should prioritise small-scale, low-impact fisheries to 
better align with goals for environmental protection and resource efficiency. Supporting larger 
industrial  operations  is  often  viewed  as  contradictory  to  these  aims,  reducing  the  overall 
effectiveness of efforts to meet the sustainability targets of the Common Fisheries Policy. 

To  enhance  coherence,  respondents  also  advocate  for  harmonising  how  EMFAF  funding  is 
allocated and regulated across Member States. This would ensure a consistent application of 
environmental and social objectives, creating a more level playing field throughout the EU. 

RELEVANCE 

EU fisheries and aquaculture funding is recognised as crucial for addressing key challenges and 
supporting sustainable development. Funding like the EMFAF plays a central role in enabling 
modernisation, climate adaptation, and the continuation of rural and structurally weak areas’ 
fishing  activities.  There  is  a  strong  call  to  increase  allocations  to  meet  the  sector’s  needs, 
especially as rising costs from inflation and energy crises strain operations. 

The alignment of funding with EU environmental objectives is highlighted as essential, with an 
emphasis on eliminating harmful subsidies that support unsustainable practices, such as those 
linked  to  fossil  fuels.  Redirecting  funds  toward  transitioning  the  sector  into  a  low-impact, 
climate-smart industry is considered vital to preserving marine ecosystems and ensuring long-
term sustainability. 

Additionally, respondents stated that addressing generational renewal is considered critical for 
the sector’s future, requiring adjustments to funding regulations to remove barriers and improve 
operational  safety  and  efficiency.  These  measures  would  help  ensure  that  funding  not  only 
preserves  existing  activities  but  also  supports  innovation  and  sustainability  in  fisheries  and 
aquaculture across the EU. 

Up to 32% of the participants in the public consultation found the funds relevant in addressing 
regional and local economic needs, mostly regarding towns and villages. 

EU ADDED VALUE 

Respondents emphasise that EU funds deliver significant added value when they address gaps 
not covered by other funding sources. Supporting small-scale, coastal, and artisanal fisheries is 
one such area where EU intervention can make a substantial impact, helping to preserve local 

97 

 
communities and promote sustainable practices. A significant majority of the participants in the 
public consultation (43.75%) felt the funds enabled initiatives that would not have been possible 
without EU funding. 

Another area of added value lies in fostering generational renewal within the fisheries sector. 
Many suggest that EU funding can support young fishers entering the industry, encouraging 
them to adopt sustainable methods. This approach helps rejuvenate the workforce, ensuring the 
continuity of local fishing traditions and sustainable practices. 

EU funding also plays a critical role in advancing decarbonisation and climate adaptation within 
the  fisheries  sector.  Financial  support  for  transitioning  to  low-impact,  climate-resilient 
operations is seen as essential, particularly as these changes would be difficult for operators to 
achieve without external assistance. 

Investing  in  research  and  innovation  further  highlights  the  EU’s  value-added  contribution. 
Funding initiatives like the development of selective fishing gear or alternative feed sources 
fosters sector-wide sustainability by reducing  environmental impact  and  improving resource 
efficiency. These efforts are viewed as transformative in advancing sustainability within the 
industry. 

As regards the consultation activities undertaken by the external study conducted on behalf of 
DG MARE to support the evaluation, a qualitative and quantitative analytical overview of the 
results is provided below. It explains how and to which extent the stakeholder views have been 
considered in the study and the number of removed contributions. Its aim is twofold: 

•  To  inform  policymaking  on  the  outcome  of  all  consultation  activities  while 

differentiating the views of the different categories of stakeholders, 

•  To  inform  stakeholders  on  how  their  input  has  been  considered  and  to  explain  why 

specific suggestions could not be taken up. 

OUTLINE OF THE CONSULTATION STRATEGY 

The consultation objectives were two-fold: 

•  To  gather  primary  evidence  to  address  any  data  gaps  identified  following  the  desk 

review, 

•  To gather stakeholders’  views  regarding various  evaluation  criteria and  compare and 

integrate the evidence collected through other data collection activities. 

Notably, the survey of managing authorities aimed to enhance  the understanding of existing 
data  from  the  review  of  the  national  EMFAF  programmes,  Infosys,  and  the  Common 
Monitoring and Evaluation System (CMES). Interviews at the European level allowed the study 
team to collect specific information from different types of stakeholders concerned by shared 
and (in)direct management components of the EMFAF. 

The following stakeholder groups were identified as relevant for consultation: 

•  Key  stakeholders  at  the  European  level,  such  as  relevant  Commission  Directorate-
Generals  (DG  MARE  and  the  Directorate-General  for  Environment  (DG  ENV)  for 
example),  the  European  Climate,  Environment  and  Infrastructure  Executive  Agency 

98 

 
 
(CINEA),  the  Fisheries  and  Aquaculture  Monitoring,  Evaluation  and  Local  Support 
Network  (FAMENET).  the  social  partners,  namely  the  Association  of  National 
Organisations of Fishing Enterprises (Europêche) and the European Transport Workers 
Federation  (ETF),  and  other  EU-level  interest  groups  from  fisheries  and  aquaculture 
representative  organisations,  such  as  European  Association  of  Fish  Producers 
Organisations (EAPO), the European Federation of Aquaculture Producers (FEAP), and 
the  European  Fish  Processors  Association-European  Federation  of  National 
Organisations of Importers and Exporters of Fish (AIPCE-CEP), to non-governmental 
organisations (NGOs) such as the WorldWide Fund for Nature (WWF), 

•  Key  stakeholders  at  the  Member  States  level  (EMFAF  managing  authorities, 

intermediary bodies, etc.), 

•  Potential direct and indirect beneficiaries, namely EU, national, regional and local target 
groups, including fishers, fish farmers, processors and their representative organisations, 
relevant public bodies, research centres, NGOs, etc., 

•  Advisory Councils. 

The stakeholder consultation in the context of the midterm evaluation of the EMFAF included 
the following consultation methods and tools: 

•  A  survey  of  the  EMFAF  managing  authorities  based  on  a  Word  questionnaire 
disseminated by e-mail (5 March 2023 for them to provide one consolidated response 
per Member State within a month), 

•  An online survey of the EMFAF target groups administered (through Sphinx, launched 

on 5 March 2024 and open until 13 May 2024), 

•  A  targeted  consultation  of  the  Advisory  Councils,  using  a  Word  questionnaire 
disseminated by e-mail (5 March 2024, for them to provide one consolidated response 
per Advisory Council by 15 April 2024, translated into French, Portuguese and Spanish 
upon request), 

•  Semi-structured interviews with key stakeholders at the European level (including the 

scoping interviews carried out in the inception phase of the study), 

•  Complementary interviews at the national and local levels, 
•  A half-day validation workshop (on 17 June 2024). 

Annex II documents each consultation activity tool, including the questionnaires and interview 
guides used by the study team. 

As  regards  participation,  the  study  team  engaged  with  many  stakeholders  through  these 
consultation activities, given its scope. While it is not possible to provide the exact number of 
stakeholders consulted, given that some participated in several activities,  the study provided 
further details on the specific groups of stakeholders who provided data, views and experiences 
for the study below: 

•  The  survey  of  managing  authorities  generated  26  responses  from  the  26  EMFAF 

Member States. 

•  The  survey  of  target  groups  received  223  responses.  Figure  1  below  provides 

quantitative data on participants’ country of origin. 

•  The targeted consultation of the Advisory Councils led to two contributions from the 
Aquaculture  Advisory  Council  (AAC)  and  the  Mediterranean  Advisory  Council 
(MEDAC). 

99 

 
•  The study team carried out 14 interviews with 26 key stakeholders at the European level, 
including  representatives  from  DG  MARE,  DG  ENV,  and  FAMENET,  as  well  as 
interest  groups  (social  partners  and  one  environmental  NGO)  and  fisheries  and 
aquaculture experts. 

•  CINEA (EU agency) participated in the study through two interviews. The table below 
provides information on the main views and concerns they addressed, which we took on 
board wherever relevant. 

•  The study team carried out nine complementary interviews with national stakeholders, 
including  intermediary  bodies  and  (potential)  beneficiaries,  in  six  selected  Member 
States  (Czech  Republic,  Denmark,  France,  Germany,  Latvia,  and  Spain)  on  specific 
topics, such as innovation, synergies, etc., as well as written feedback from the Estonian 
stakeholder consulted. 

•  48 stakeholders joined the half-day validation workshop on 17 June 2024, including 17 
managing authorities (CZ, CY, IT, DE, DK, EE, FI, IT, LV, MT, NL, PL, PT, RO, SE, 
SI, SK), six Advisory Councils (AAC, BISAC, MAC, MEDAC, NWWAC, NSAC), and 
representatives from 4 DG MARE units. 

All the stakeholder groups and interests identified were given the opportunity to participate in 
the study. 

As regards the quantitative data on participation in the survey of target groups, 223 stakeholders 
from 19 Member States responded to the survey of target groups. 27% of the respondents (61 
out of 223) were from France, 14% from Sweden (31 out of 223), 11% from Czechia (25 out 
of 223), 9% from Spain (21 out of 223), 7% from Denmark (15 out of 223), 4% from Portugal 
(10 out of 223) and 4% from Italy (8 out of 223), and 23% from other countries (52 out of 223) 
– see Figure 1 below. 

Figure 19: Distribution of contributions by Member States 

Source: Survey of target groups, Source: Supporting study carried out by the consortium formed by Tetra tech, 
^2024 

100 

 
 
 
 
Contributions came from a wide range of stakeholders, including 46% of private enterprises 
(103  out  of  223),  17%  of  public  bodies  (37  out  of  223),  13%  of  producer  organisations, 
interbranch organisations  and associations of producer organisations (29 out  of 223), 8% of 
Local  Action Groups (17 out  of 223), 6% of individuals  (14 out  of 223), 5% of  NGOs  and 
association (12 out of 223) and research centres (4 out of 223). Among enterprises, 96% (99 
out of 103) of the respondents were SMEs, and 64% (66 out of 103) were micro-enterprises 
(one to nine employees). 

The respondents represented the different economic sectors, including fisheries for 48% (107 
out of 223), 23% aquaculture (51 out of 223), 5% processing and marketing (12 out of 223), 
3% other maritime activities (7 out of 223), as well as 6% integrated or multisectoral activities 
(13 out of 223). 6% of the respondents (14 out of 223) also work in activities related to the 
protection of the environment. Among respondents in the fisheries sector, 41% (44 out of 107) 
were vessel owners working on board. 

Notably, the French outermost regions were over-represented in the sample (16% of the total 
sample) and negatively influenced some of the results (on the relevance and application process 
in  particular).  Feedback  from  complementary  interviews  indicated  that  one  of  the  French 
outermost  regions  encountered  significant  difficulties  in  the  application  process,  which 
probably explains this feedback. Therefore, when relevant, the study team separated responses 
from the French outermost regions from others' responses. In this case, the study team discarded 
37 responses from the survey of target groups. 

As regards the methodology and tools used to process the data, the study team conducted a 
quantitative  and  qualitative  analysis  of  data  gathered  through  the  different  consultation 
activities. The quantitative analysis included a descriptive statistical analysis of the results of 
the surveys of the EMFAF target group and managing authorities in the Member States. 

The analysis of the input gathered in the context of the consultation work was conducted first 
at  the  individual  data  collection  tools  level.  Then,  the  study  team  triangulated  the  data  and 
contrasted  it  with  data  from  the  desk  research  to  produce  the  study  findings  and  develop 
overarching conclusions and recommendations. These were presented in the main study report.  

RESULTS OF THE STUDY’S CONSULTATION ACTIVITIES  

This  section  includes  the  results  of  each  consultation  activity,  including  qualitative  and 
interpretative analysis, highlighting consistencies or contradictions in relation to contributions 
and main stakeholder categories where relevant. Namely, the input from Managing Authorities; 
Target  Groups,  Advisory  Councils;  Key  stakeholders  at  the  European  level;  complementary 
interviews at the national and local level; an ad hoc contribution; the Validation workshop. 

All inputs were on the basis of the following 3 questions: 

•  To what extent has the EMFAF been successful and why? 
•  How has the EMFAF made a difference and to whom? 
• 

Is the EMFAF still relevant? 

Survey of the managing authorities: The results present below are based on the 26 responses 
to the survey of managing authorities.  

101 

 
To what extent has the EMFAF been successful and why? 

Managing authorities expressed strong satisfaction with stakeholder contributions, highlighting 
the collaborative development process that included diverse stakeholders. In open comments, 
they  also  supported  the  performance  framework's  target  values,  believing  them  to  be  well-
grounded  in  reliable  historical  data,  which  enhanced  their  credibility.  Involving  local 
authorities, fishers, and environmental organisations was emphasized to ensure the programme 
objectives were comprehensive, that they could effectively address local challenges, and that 
they had integrated sustainability goals. The programme was considered flexible to adapt to 
evolving  needs  and  the  ability  to  reallocate  funds  during  crises  like  COVID-19  to  support 
vulnerable sectors such as small-scale fisheries.  

Lessons  learned  from  the  previous  programming  period  (EMFF  2014-2020)  were  also 
implemented.  Some  specific  examples  of  how  earlier  experiences  had  informed  current 
practices included: streamlined application processes and enhanced communication channels 
between  the  authorities  and  stakeholders.  Several  managing  authorities  noted  that  these 
improvements  had  reduced  bureaucratic  delays  and  increased  the  efficiency  of  fund 
distribution, enabling quicker implementation of projects. 

Managing  authorities  rated  the  governance  structures  and  procedures  as  highly  effective, 
underscoring  the  robustness  of  the  administrative  framework  overseeing  programme 
implementation.  However,  opinions  varied  on  resource  allocation  compared  to  the  previous 
EMFF, with the majority perceiving it as stable. This suggested that there was continuity in 
resource allocation, reflecting a similar level of investment in program execution and oversight. 
The programme's adaptability and the mechanisms for quick response to crises were also noted 
as efficient  in  the open  comments.  These mechanisms ensured the programme could  handle 
unforeseen challenges, minimising disruptions and maintaining progress towards its objectives. 
The  vast  majority  of  managing  authorities  reported  this  adaptive  capacity  to  be  a  critical 
component  of  efficiency,  as  it  enabled  the  programme  to  remain  functional  and  effective  in 
dynamic and often unpredictable environments. 

The results of the coherence assessment included positive feedback on synergies with other EU 
funds, reportedly facilitated through national coordination meetings, common IT platforms, and 
joint  committees.  Numerous managing  authorities reported that these mechanisms enhanced 
the programme's coherence by ensuring that it worked in harmony with other initiatives and 
policies, avoiding duplication and maximizing resource utilisation. 

Most  managing  authorities  indicated  that  learning  from  other  Member  States  through 
established networks and expert meetings also contributed to coherence. However, there was 
room  for  improvement  in  informal  exchanges  and  direct  interactions  between  managing 
authorities. Enhancing these interactions could have further improved coherence by facilitating 
the  sharing  of  best  practices  and  innovative  solutions  across  different  contexts.  Generally 
speaking, this collaborative approach ensured that the programme was not operating in isolation 
but was integrated into a broader, cohesive framework of EU policies and initiatives, according 
to managing authorities. 

How has the EMFAF made a difference and to whom? 

Diverse perspectives on the influence of flexibility, budgetary allocations, and stakeholder input 
existed  during  the  programming  phase.  These  elements  contributed  significantly  to  the 

102 

 
enhanced effectiveness of the EMFAF by ensuring that it was responsive to a wide range of 
needs and priorities.  

Drafting an Action Plan for Outermost Regions and allocating resources reflected the unique 
benefits  of  EU-level  strategic  planning.  This  strategic  approach  enabled  the  programme  to 
address specific regional needs effectively, leveraging the collective resources and expertise of 
the EU. By operating at the EU level, the programme achieved outcomes that would have been 
difficult or impossible for individual Member States to accomplish alone. This added value was 
a  testament  to  the  programme's  design  and  implementation,  highlighting  the  benefits  of  a 
coordinated and strategic approach to addressing complex challenges across the EU. 

Is the EMFAF still relevant? 

The  survey  revealed  a  high  level  of  perceived  relevance  and  flexibility  in  the  national 
programme  to  address  future  needs,  indicating  that  the  programme  was  designed  with  an 
understanding of emerging challenges and is capable of evolving to meet them effectively 

Many  managing  authorities  highlighted  the  programme’s  ability  to  address  emerging  issues 
effectively. For instance, respondents mentioned that the programme’s objectives were aligned 
with the latest environmental and economic challenges, such as the increasing impact of climate 
change on fisheries and the need for sustainable practices. One managing authority noted that 
the  programme’s  focus  on  sustainability  and  resilience  is  critical  as  severe  environmental 
changes are more frequent. 

The  programme's  responsiveness  to  local  communities'  needs  was  highlighted  by  managing 
authorities, who appreciated its tailored approach to  regional specificities. This  ensured that 
interventions were precisely targeted to address local challenges effectively. Additionally, the 
programme's continuity in specific objectives with minor adjustments allowed it to stay aligned 
with current and emerging priorities, maintaining stability while adapting to new challenges as 
needed. 

Survey of target groups: The views expressed in the responses to the survey of target groups 
are provided below, which are not statistically representative. 

To what extent has the EMFAF been successful and why? 

The responses to the survey of target groups confirm the overall effectiveness of the delivery 
system.  

Responses to the survey of target groups show a generally positive outlook among applicants 
on the communication and the application process, except in the case of the French Outermost 
region mentioned above. While, without the French outermost regions, the average scoring on 
the  information  provided,  the  communication  with  the  administration,  delays  and  the 
application process in general reached 3.3 out of 5, for the French Outermost regions, it only 
reached 2 out  of 5. Except  in  this specific case,  respondents praised, in  particular, the good 
communication with their administration (72% of the respondents agreed, including 23% who 
strongly agreed and only 15% who disagreed) and were more critical of the level of complexity 
(only 42% agreed the application process was simple and 35% disagreed) and the timeliness of 
the application process (50% of respondents who agreed 21% who disagreed). 

The answers to  the target  group survey also  indicate the perceived relationship between the 
different  types  of  EMFAF  support  and  their  results  and  impacts.  The  answers  cannot  be 

103 

 
considered as fully representative of the results achieved at this stage, but they provide some 
insights  on  the  expected  results  from  the  perspective  of  the  beneficiaries,  in  particular  on 
investments, as 50% of the respondents applied for this type of support. Investments, as well as 
production and marketing plans, are related primarily related to increased production capacity 
and improved working conditions for both fisheries and aquaculture, and to a lesser extent to 
maintaining capacity and jobs, jobs creation, improved resource efficiency, innovations, and 
reduced  environmental  impacts.  The  survey  also  highlights  the  relationship  between  data 
collection and studies and biodiversity protection. Impacts on energy efficiency and reduced 
CO2 emissions tend to be more indirect but could be expected from a wide range of types of 
support. 

Finally, the survey indicates that the fund effectively contributes to the visibility of EU action 
as the vast majority of beneficiaries (80%) confirmed having communicated about the EMFAF 
fund one way or another, mainly through their website or through the display of the European 
logo  in  their  premises.  Only  8%  of  the  respondents  were  unaware  of  the  communication 
requirements (especially people from private enterprises), and 12% have not communicated yet. 

The survey also provided helpful information on administrative costs for applicants. It shows 
that costs vary significantly from a few hours to more than five days worth of work, but that a 
majority of respondents agreed that overall costs were reasonable compared to the amount of 
support received (65% of respondents, against only 14% who disagreed). Respondents among 
POs, LAGs, and research centres tend to disagree more, but the percentages may need to be 
more representative as there are only a small number of respondents. 

How has the EMFAF made a difference and to whom? 

The  wide  range  of  beneficiaries  among  the  respondents,  including  micro-enterprises  and 
individuals, the low rejection rate (4% among respondents) and the answers on reasons for not 
applying or not obtaining support indicate that the EMFAF successfully reaches out to all target 
groups.  The  eligibility  criteria  that  respondents  mention  as  a  problem  for  applying  or  more 
related to the type of support (e.g. age limit for the first acquisition of a vessel) than to a specific 
group of stakeholders. 

Is the EMFAF still relevant? 

The responses to the survey of target groups also show that stakeholders’ involvement in the 
preparation of the national EMFAF programme has resulted in a more positive perception of 
the programme's relevance. 

Targeted  consultation  of  the  Advisory  Councils:  The  findings  below  were  based  on  the 
targeted  consultation  of  the  Advisory  Councils,  which  led  to  two  contributions  from  the 
Aquaculture Advisory Council (AAC) and the Mediterranean Advisory Council (MEDAC). As 
their membership is wide, their response is submitted on behalf of their members. 

To what extent has the EMFAF been successful and why? 

According  to  the  Advisory  Councils  that  provided  feedback  for  this  study,  the  EMFAF  has 
shown some early signs of success but also faces significant challenges. 

Both Advisory Councils highlighted significant bureaucratic challenges that hinder the timely 
implementation  and  accessibility  of  the  EMFAF.  Excessive  control  requirements  and 
complicated administrative procedures often delay funding and project execution. The practical 

104 

 
effects of simplification measures have yet to be realised. The current administrative procedures 
remain complex and time-consuming, which affects the efficient use of the EMFAF. 

In  addition,  the  flexibility  given  to  Member  States  (see  4.3.3  below)  can  lead  to  uneven 
implementation, with varying levels of administrative capacity and priority given to aquaculture 
development, for instance. Some regions and target groups, such as those involved with towed 
gears or operating in administratively weak regions, face difficulties accessing the Fund. 

One Advisory Council also expressed concerns that the regulatory constraints at the national 
level  may  prevent  achieving  the  objective  of  increased  aquaculture  production  by  2030. 
Significant hurdles include ineffective spatial planning, complicated licensing procedures, and 
limited social acceptability. 

With an emphasis on sustainability and competitiveness, the EMFAF aligns with broader EU 
strategic  goals  like  the  Green  Deal  and  the  Farm  to  Fork  Strategy.  The  Fund's  focus  on 
environmentally  friendly  practices  and  market  competitiveness  is  crucial  for  the  long-term 
viability  and  resilience  of  the  EU's  fisheries  and  aquaculture  sectors.  Yet,  the  EMFAF’s 
objectives are sometimes at odds with other EU policies. For instance, the EU trade policy does 
not  always  promote  a  level  playing  field  for  EU-produced  seafood  versus  imports,  and 
environmental regulations can conflict with food production goals. 

Finally, there is a need for better monitoring and evaluation mechanisms to assess the impact 
of the EMFAF, including establishing sustainability and welfare indicators. For the Advisory 
Councils, this is crucial for ensuring that the Fund’s objectives are met effectively. 

How has the EMFAF made a difference and to whom? 

For the two Advisory Councils, the EMFAF has made a difference to the EU’s fisheries and 
aquaculture sectors in several key ways. It has made a notable difference by providing greater 
flexibility and responsiveness compared with previous funds, benefiting various stakeholders 
from  managing  authorities  to  small-scale  operators.  The  EMFAF  includes  provisions  for 
quickly mobilising  funds to  mitigate the impacts of crises, enhancing  the  sector's resilience. 
This has provided crucial support to businesses facing unexpected disruptions, helping them to 
maintain operations and livelihoods during difficult times. In addition, SMEs can benefit from 
measures  to  improve  competitiveness  and  resilience.  Yet,  the  practical  impact  is  limited  by 
administrative barriers and access issues in some regions. Addressing these issues is essential 
for  the  EMFAF  to  maximise  its  positive  impact  across  the  EU's  fisheries  and  aquaculture 
sectors. 

Is the EMFAF still relevant? 

Based  on  the  two  Advisory  Councils’  feedback,  the  EMFAF  remains  relevant  due  to  its 
increased flexibility, crisis response capabilities, and support for sustainable and competitive 
practices. 

The EMFAF’s structure allows Member States to design and activate measures that align with 
their specific needs, providing greater flexibility compared with the EMFF. This flexibility is 
intended to help Member States tailor their interventions more closely to local conditions and 
priorities,  potentially  leading  to  more  effective  and  relevant  use  of  the  Fund.  For  example, 
regions  with  unique  environmental  or  economic  challenges  can  create  bespoke  solutions 
without being restricted to a predefined list of eligible measures. So, although progress is yet to 
be fully assessed, the intent is to address the needs of various target groups. 

105 

 
The EMFAF includes provisions for addressing crises, such as the impacts of COVID-19 and 
energy crises, by allowing for the mobilisation of funds to support the resilience of the fisheries 
sector.  This  ability  to  respond  flexibly  to  crises  represents  a  significant  improvement  over 
previous funding mechanisms. 

While there are challenges, they highlight areas for improvement rather than detracting from 
the fund's overall relevance. By addressing these challenges, the EMFAF can continue to play 
a vital role in supporting the EU's fisheries and aquaculture sectors. 

Interviews with key stakeholders at the European level: The results presented below  are 
based on interviews with key EU-level stakeholders. As a reminder, the study team carried out 
14 interviews with 26 key stakeholders at the European level, including representatives from 
DG  MARE,  DG  ENV,  and  FAMENET,  as  well  as  interest  groups  (social  partners  and  one 
environmental NGO) and fisheries and aquaculture experts. 

To what extent has the EMFAF been successful and why? 

There was consensus among the European-level interviewees that the EMFAF has benefited 
from lessons from the EMFF. The transition towards a more flexible funding architecture was 
viewed  positively.  The  delivery  system  has  also  improved  in  terms  of  clarity  of  roles, 
coordination, and planning, particularly in direct management. 

The governance structure of the EMFAF has had varying impacts on the actual use of the Fund 
across  Member  States.  Some  struggled  more  with  implementation,  possibly  due  to 
administrative  burdens  and  differing  Fund-use  priorities.  Factors  that  facilitated  successful 
EMFAF  use  include  increased  levels  of  expertise,  adherence  to  best  practices,  geopolitical 
developments, and dedicated administrative assistance provided by DG MARE/CINEA. 

While in terms of working methods, direct expenditure under the EMFAF mirrors that of the 
EMFF, Member States increased flexibility in the delivery of their national programmes under 
shared  management,  reportedly  supporting  greater  creativity.  The  EMFAF  prioritises 
performance  and  results,  allowing  Member  States  the  freedom  to  determine  how  to  achieve 
specified goals, whereas the EMFF was more prescriptive. Interviewees considered that efforts 
were underway to facilitate collaboration and the expansion of successful initiatives, including 
collaboration  with  other  EU  funding,  like  the  EIB  Blue  Invest  platform.  Successful 
collaborations included presentations at expert group meetings and collaboration with other EU 
programmes like Horizon and LIFE. Additionally, interviewees (in CINEA and DG MARE) 
acknowledged incorporating references to biodiversity and climate change within the EMFAF 
as a significant advancement, contributing to accomplishments in these areas and bolstering the 
EU's reputation. 

In addition, interviewees considered EMFAF projects under direct management to be highly 
visible,  which,  in  turn,  significantly  contributed  to  CINEA's  visibility.  Communication 
initiatives were reported to address citizen concerns and proactively communicate across social 
media  platforms  like  Facebook,  Instagram,  LinkedIn,  and  YouTube.  This  digital-focused 
approach  reflects  the  EMFAF's  commitment  to  adaptability  and  reaching  wider  audiences 
effectively. Despite challenges like language barriers, efforts are underway to ensure effective 
communication  and  dissemination  of  EMFAF  opportunities.  Collaboration  with  other  DGs 
offers further avenues to enhance the visibility and awareness of EMFAF initiatives. 

106 

 
Despite  these  positive  aspects,  there  were  areas  for  improvement.  Notably,  interviewees 
suggested greater transparency and stakeholder involvement in project selection processes are 
needed  to  ensure  that  sustainability  criteria  are  adequately  applied,  particularly  in  the 
aquaculture  sector.  Challenges  include  difficulty  obtaining  information  and  implementation 
complexity,  particularly  regarding  (in)direct  management.  Despite  EMFAF's  crucial 
adaptability following crises like COVID-19, the Fund also needs provisions to address specific 
challenges, such as terminated fishery agreements. According to interviewees, barriers to the 
EMFAF’s success included external dynamics, technological limitations (e.g. for selectivity or 
decarbonisation), funding constraints, and conditionalities (e.g. capacity ceilings  and license 
definitions (GT, kW)) preventing the construction of larger vessels and may disincentive fishing 
companies to seek EMFAF support.  

Other areas for improvement mentioned by key stakeholders at the European level to enhance 
EMFAF's effectiveness were as follows: 

•  EMFAF  should  enhance  transparency  and  consistency  in  addressing  sustainability 
concerns. While the legal framework outlines sustainability goals, there is a need for 
more precise guidelines on how these goals are applied and projects selected, ensuring 
more active involvement of Member States in sustainability initiatives. 

•  Regarding  control  and  enforcement,  effective  communication  channels  between 
managing authorities and control authorities were highlighted as crucial for appropriate 
Fund  utilisation.  According  to  EU  stakeholders  from  the  Commission  and  interest 
groups,  increased  simplification  and  more  apparent  roles  and  responsibilities  could 
enhance the EMFAF's effectiveness in supporting fisheries control efforts. 

•  Emphasis on reshaping mindsets to prioritise SDG 14-related work and fortify the EU's 

credibility in international governance. 

•  Enhancing  departmental  collaboration,  delegating  measures  regionally,  addressing 
marine  litter,  navigating  political  dynamics,  and  maintaining  focus  on  economic  and 
social aspects. 

Different  viewpoints emerged regarding the proportionality  of costs. To address  concerns, a 
review  of  fund  allocation  was  reported  to  be  crucial  to  ensure  effective  resource  utilisation, 
support  for  fishers,  and  improved  access  to  funds  for  eligible  categories.  Additionally, 
consideration  should  be  given  to  incorporating  costs  related  to  public  awareness  efforts, 
provided they align with programme objectives. programme 

In  the  past,  Member  States  were  obligated  to  submit  annual  expenditure  reports  on  data 
collection for validation before receiving final payments from the Commission. However, this 
requirement was eliminated under the EMFAF as a simplification measure. Nevertheless, some 
Member States continue to request Commission validation before payment. In contrast, others 
consider report submission satisfactory for payment processing, showing that there is a bit of a 
learning curve involved in adjusting and realising the benefits of simplification. 

The  EMFAF  efficiently  prioritised  climate  adaptation  and  introduced  flexibility  to  address 
climate-related  challenges.  The  simplification  from  the  EMFF  was  viewed  as  a  major 
improvement,  and  its  adaptable  response  to  recent  crises  demonstrated  its  effectiveness. 
However, the focus on financing fisheries control could have been more extensive, with many 

107 

 
findings being incidental. Recommendations included periodic reviews to ensure efficient crisis 
responses and improved transparency in the allocation of fisheries control funding. 

Multiannual  work  programmes  and  better  coordination  within  DG  MARE  have  reportedly 
enhanced implementation efficiency. Planning and monitoring were also said to have improved 
with  the  transition  to  an  IT-based  grant  management  system,  and  a  centralised  database 
facilitates information sharing and helps prevent fraud or double funding. 

Interviewees  confirmed  that  the  EMFAF  was  able  to  support  various  EU  policies  and  the 
European  Green  Deal  to  some  extent.  For  instance,  direct  investments  in  community 
development  initiatives  promoted  social  cohesion  and  economic  well-being  in  line  with  EU 
policy priorities. Digitalisation projects like marine observation and data collection were also 
said to support EU environmental goals. However, concerns arose about funding adequacy for 
new objectives and evolving policy obligations. While the EMFAF aligns on paper with policies 
such as decarbonisation and biodiversity, some stakeholders (DG ENV and WWF) highlighted 
that more scrutiny was needed for implementation and funding. For them, despite theoretical 
alignment with policies like the CFP, practical challenges still need to be addressed, especially 
in  funding  for  research  and  data  collection.  Specific  policies,  such  as  those  concerning 
decarbonisation  and  biodiversity,  occasionally  extend  beyond  the  scope  of  the  EMFAF 
objectives, leading to possible coordination and resource allocation challenges. 

Interviewees  confirmed  that  the  EMFAF  fully  supports  the  CFP  and  strongly  focuses  on 
sustainability. Environmental concerns were well integrated into the design of the Fund, aiming 
to  avoid  harm  to  the  environment.  There  has  been  a  shift  towards  a  sustainable  economy 
narrative, moving away from purely growth-focused approaches. 

How has the EMFAF made a difference and to whom? 

According  to  those  consulted.  The  EMFAF  brings  significant  added  value  compared  to 
national-level actions, particularly in facilitating cross-border cooperation on maritime spatial 
planning  and  addressing  sector-specific  needs  like  aquaculture.  European  funding  has 
established  permanent  structures  and  platforms  for  collaboration  among  Member  States, 
fostering networking and sharing of best practices. Initiatives like FLAGs and FAMENET have 
further diversified local tourism and support activities like seaweed cultivation. Additionally, 
the  EMFAF  promoted  collaboration  on  aspects  requiring  common  intervention  or  policy 
development at the EU level, ensuring a level playing field and addressing international aspects 
beyond  the  scope  of  individual  Member  States.  Overall,  interviewees  explained  that  the 
EMFAF filled a niche by providing essential funding for initiatives that would otherwise see 
limited  action  at  the  national  level,  thereby  promoting  collaboration,  innovation,  and  policy 
development on a European scale. 

In particular, interviewees highlighted that the EMFAF's emphasis on cross-border cooperation 
and technology innovation enhances its European dimension, fostering impactful solutions at a 
European level. 

Is the intervention still relevant? 

According to interviewees, the objectives of EMFAF remain relevant. 

More specifically, the EMFAF was seen to prioritise climate adaptation, which is crucial for 
tackling  climate  challenges.  Its  design  reportedly  allows  flexible  resource  allocation  for 

108 

 
adaptation  needs.  However,  practical  adaptability  was  reported  to  be  key,  especially  during 
crises like COVID-19 or geopolitical events. While EMFAF showed flexibility in some cases, 
like responding to crises, in its present form, it needs to catch up in others, such as compensating 
fleets affected by terminated fishery agreements. This was viewed by specific stakeholders as 
problematic, even if it was a clear design choice.  

The EMFAF's specific objectives appeared highly relevant to current EU priorities, particularly 
regarding international aspects like Regional Fisheries Management Organisations (RFMOs). 
The  focus  on  sustainability,  scientific  research,  and  capacity  building  aligns  with  the  EU's 
commitment to  responsible global fisheries management. Examples such as the work of the 
North East Atlantic Fisheries Commission (NEAFC) and the Great Bluefin Year Programme 
demonstrated concrete efforts that contributed to achieving these objectives. 

The interest groups consulted indicated that the current support provided by EMFAF may not 
adequately address the needs of all target groups. While the programmes target small fishers 
and vessels under 24m, barriers prevented certain groups, such as small fishers and women, 
from accessing the funds effectively. Capacity building, broadening the target group criteria, 
strengthening women's networks, and addressing training and gender issues were reported to 
be  essential  to  ensure  that  EMFAF  support  effectively  reaches  all  intended  beneficiaries. 
Indeed,  one  interviewee  representing  an  interest  group  expressed  concerns  that  most  of  the 
funds are being allocated towards technical assistance for managing the funds instead of directly 
helping fishers with their applications. 

COMPLEMENTARY INTERVIEWS AT THE NATIONAL AND LOCAL LEVEL: 

To what extent has the EMFAF been successful and why? 

The interviewed intermediate bodies agreed that there is an enhanced simplification of both the 
programme and the delivery system. This simplification resulted from the learning process of 
the managing authorities and the flexibility provided by the legal framework in some specific 
topics (eligibility criteria for small vessels or the simplification for projects involving different 
dimensions).  Specific  examples  of  structural  changes  within  Member  States  were  also 
mentioned during interviews, as these are expected to deliver positive impacts in the future. For 
instance,  in  France,  the  management  of  biodiversity-related  operations  was  delegated  to 
regional intermediate bodies, allowing the implementation of local projects.  

Even  though  the  current  programming  phase  benefitted  from  lessons  learned  from  previous 
periods, feedback gathered suggested that several lessons learned still need to be implemented. 
This  is  because they emerged towards the end of the previous programming  period, leaving 
little time for their integration into the current programming period. 

Even though there is a consensus on the simplification of the delivery system during the current 
programming period, interviewed intermediate bodies highlighted an increased administrative 
burden due to the multiplication of verification steps and the growing volume of administrative 
work. This burden has been particularly challenging for smaller beneficiaries, though without 
preventing them from applying for the funds.  

Regarding the state of play and the programme's implementation, all the intermediate bodies 
interviewed mentioned delays in  the instruction. The majority of the projects  are still in  the 
instruction phase; few have been committed, and some payments have been made. 

109 

 
Some beneficiaries interviewed highlighted the new programme's greater flexibility and, thus, 
adaptability.  However,  several  beneficiaries  highlighted  important  delays,  posing  potential 
challenges for smaller beneficiaries.  

How has the EMFAF made a difference and to whom? 

When asked about the potential impact of withdrawing the EMFAF, responses varied by region. 
Beneficiaries in the outermost regions indicated they would no longer be competitive, as the 
cost of complying with EU norms is significant. Research institutes stated that they would seek 
alternative funding sources, but some projects (e.g., those providing scientific advice) would 
stop, as the EMFAF is their primary source of support. Beneficiaries in the production sector 
mentioned that they would continue their activities but would need to increase production to 
maintain  profitability  without  EMFAF  support.  This  could  lead  to  reduced  quality,  poorer 
working conditions, and decreased sustainability. 

Some beneficiaries also expressed concerns that implementation delays might result in a lower 
committed budget  than anticipated, potentially  leading  to  reduced budget  allocations for the 
next programming period. 

Is the intervention still relevant? 

Beneficiaries  estimated that the EMFAF addressed the needs of the sector to  a great  extent. 
However, some concerns were raised concerning inflexible criteria, which have led to excluding 
some projects from the EMFAF support, such as investments for new fishing vessels and some 
research projects. 

AD HOC CONTRIBUTIONS 

An ad hoc contribution outside the formal consultation context was received by the study team. 
A Latvian fisher expressed his views by email to the study team. It was indicated that fishers' 
primary need is to buy new boats and equipment, but the regulations are different in all Member 
States. In some cases, receiving EMFAF funding requires profits to increase significantly, or 
fishers must give the money back, while in other Member States, they give them some years to 
grow.  So,  there  is  a  need  for  local  governments  to  listen  to  fishers  more,  as  fishing  is  an 
uncertain sector. 

VALIDATION WORKSHOP 

The  validation  workshop  brought  together  54  participants,  including  the  study  team, 
representatives from DG MARE, Advisory Councils, and managing authorities.  

The  workshop's  objective  was  to  validate  the  initial  key  findings,  complement  consultation 
activities and address any remaining gaps in the analysis. Notably, the discussions during the 
workshop enabled the team to do precisely this: confirm with those present that there were no 
significant gaps, misunderstandings, or disagreements with the draft findings. The workshop 
allowed  the  team  to  develop  the  specific  aspects  in  more  detail,  with  specific  examples  or 
explanations of experiences with the Fund, for instance, elaborating the reasons for the delayed 
start  (which  were  indeed  linked  to  COVID-19  but  also  reflected  experiences  across  other 
funding periods) and to hear priorities for the future. Based on a preparatory survey, the focus 
of the validation workshop was determined to be efficiency and efficiency. 

110 

 
11.  ANNEX VI. INFOSYS DATABASE 

What is ‘Infosys’ and how does it work? 

Infosys  is  a  database  of  all  operations  selected  and  implemented  under  the  EMFAF,  in 
fulfilment  of  Article  46  of  the  EMFAF  regulation.  It  covers  all  operations,  both  under 
Shared Management and Direct/Indirect Management (implemented by DG MARE and 
related  agencies).  It  is  a  powerful  and  valuable  database  with  constantly  quality-
checked and readily-available data that can be used for information and evaluation 
purposes. 

financial  data,  contribution  of  an  operation 

The exact data to be gathered and reported for every operation in Infosys are defined in 
Commission  Implementing  Regulation  2022/7972 and include operation and beneficiary 
characteristics, 
towards  specific 
horizontal/policy goals (such as gender-equality), type of intervention and common result 
indicators  capturing  the  effects  of  operations.  Infosys  data  are  generated  by  EMFAF 
beneficiaries  and  reported  to  national  Managing  Authorities,  who  then  compile  and 
formally submit their national EMFAF operation data to the European Commission twice 
per year. 

Figure 20: Infosys data base system 

Source: FAMENET 2024 

The  Commission  has  developed  an  operational  methodology  in  linking  the  EMFAF 
objectives to the CFP objectives, and when Member States are reporting on the EMFAF 

72   Commission  Implementing  Regulation  (EU)  2022/79  of  19  January  2022  laying  down  rules  for  the 
application of Regulation (EU) 2021/1139 of the European Parliament and of the Council as regards the 
recording, transmission and presentation of operation-level implementation data. 

111 

 
 
 
 
 
 
objectives, to show how they also contribute to the CFP objectives  73. Table 4 illustrates 
how  EMFAF  support,  expenditure  and  number  of  operations  are  distributed  per  CFP 
objectives.  

Table16: EMFAF contribution to the CFP objectives– (in)direct and shared management 

EMFAF 
support 
Infosys 
31.12.2023 
(EUR) 

EMFAF 
expenditure 
Infosys 
31.12.2023 
(EUR) 

Number 
of 
operation
s 

39 407 649 

17 975 197 

682 

CFP objective 

Art. 2(2) CFP Reg. Ensure that exploitation of living 
marine  biological  resources  restores  and  maintains 
populations  of  harvested  species  above  levels  which 
can produce the 

maximum sustainable yield 

Art.  2(3)  CFP  Reg.  Ensure  that  negative  impacts  of 
fishing  activities  on  the  marine  ecosystem  are 
minimised  and  ensure  that  aquaculture  and  fisheries 
activities avoid the degradation 

of the marine environment 

164 826 932 

59 691 684 

Art. 2(4) CFP Reg. Collection of scientific data 

126 806 424 

11 663 111 

949 

30 

Art. 2(5)(a,b) CFP Reg. Gradually eliminate discards, 
by  avoiding  and  reducing  unwanted  catches,  and  by 
gradually  ensuring  that  catches  are  landed;  where 
necessary, make the 

best use of unwanted catches 

180 244 

32 922 

10 

Art.  2(5)(c)  CFP  Reg.  Provide  conditions  for 
economically  viable  and  competitive  fishing  capture 
and processing industry and 

land-based fishing-related activity 

78 534 029 

12 337 640 

362 

Art. 2(5)(d) CFP Reg. Adjust the fishing capacity of the fleets 

according to fishing opportunities 

Art.  2(5)(e)  CFP  Reg.  Promote  the  development  of 
sustainable aquaculture activities to contribute to food 
supplies and 

73 The methodology comprises a combination of: 

•  Specific Objective (Infosys field 06) 
•  Type of Intervention (Infosys field 25) 
• 
In few cases - also Type of operation (Infosys field 26) 
•  All possible combinations of fields 06 and 25 are created 
• 
•  Each combination is linked to a CFP objective 

In total 165 combination for shared management and 23 for direct management 

112 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
CFP objective 

EMFAF 
support 
Infosys 
31.12.2023 
(EUR) 

EMFAF 
expenditure 
Infosys 
31.12.2023 
(EUR) 

Number 
of 
operation
s 

security and employment 

31 723 448 

4 663 631 

525 

Art. 2(5)(f) CFP Reg. Contribute to a fair standard of 
living for 

10 634 193 

4 009 927 

535 

those who depend on fishing activities 

Art. 2(5)(g) CFP Reg. Contribute to an efficient and 
transparent 
fisheries  and 
aquaculture 

internal  market 

for 

40 970 514 

12 765 329 

549 

Art. 2(5)(h) CFP Reg. Take into account the interests 
of both 

3 831 623 

1 316 994 

33 

consumers and producers 

Art.  2(5)(i)  CFP  Reg.  Promote  coastal  fishing 
activities, taking 

into account socioeconomic aspects 

40 806 437 

555 667 

168 

Total23 

537 721 494 

125 012 102 

3 843 

113 

 
 
  
  
  
  
  
  
  
Figure 21: EU dashboard 

Source: European Commission 2024 

114 

 
 
 
 
12.  ANNEX VII. EMFAM INTERVENTION LOGIC AND THE MEF 

Figure 22: Intervention Logic EMFAF 

115 

 
 
Figure 23: Intervention Logic for Priority 1 

116 

 
 
Figure 24: Intervention Logic for Priorities 2, 3 and 4 

Source: Supporting study carried out by the consortium formed by Tetra tech, 2024

117 

 
 
REPORTING FRAMEWORK ON THE IMPLEMENTATION OF THE PROGRAMMES 

The Monitoring and Evaluation Framework (MEF) 2021-2027 has three types of common 
indicators: output indicators, result and core performance indicators.  

The  EMFAF  has  only  one  type  of  output  indicator:  “number  of  operations”.  Output 
indicators aim to measure output produced with EMFAF support. Member States define 
the target value for the number of operations for each specific objective in the EMFAF 
programme. That is the sum of all operations to be implemented for that specific objective 
(reported at MS level). 

There can be no specific objective in  a programme without at  least  one common result 
indicator (CR) out of the 22. Each operation has to be linked to a minimum of one suitable 
indicator with a defined baseline and target value. The indicators aim to demonstrate the 
gross effect74 of the EMFAF programme and are common to all Member States (reported 
at  MS  level).  For  each  operation  receiving  EMFAF  support  Member  States  report  via 
Infosys  a  value  for  at  least  one  CR  that  succinctly  captures  the  intended  effects  of  the 
operation. Only CRs relevant to the specific operation are reported, while Member States 
are encouraged to select as many CRs as necessary to ensure that the various results of the 
operation are adequately captured. 

The MEF also includes predefined 12 core performance indicators for EMFAF reporting 
which are used in compliance with the Commission’s reporting requirement pursuant to 
Article 41(3)(h)(iii) of Regulation (EU) No 2018/1046 (Financial Regulation)75 (reported 
at Commission level). 

Member States report each operation via Infosys twice a year. The Infosys report contains 
structured  data  as  defined  in  the  EMFAF  implementing  regulation  2022/7976.  This 
regulation provides for consistent and comparable data at the level of the single operation. 
For example, the indicator “jobs created” can be expanded to be for example “jobs created 
in aquaculture through energy efficiency investments in SMEs in remote areas” as needed. 
This  is  done  in  a  fully  consistent  and  comparable  way  through  all  Member  States  and 
allows for the extraction of conclusions. 

75 

74 Gross means that the indicator captures for example the number of jobs created at a company receiving a 
grant, without considering external influences. However, jobs created might not be entirely thanks to the 
grant, other factors (for example market growth) can contribute too. 
 Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on 
the  financial  rules  applicable  to  the  general  budget  of  the  Union,  amending  Regulations  (EU)  No 
1296/2013, (EU) No 1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) 
No  1316/2013,  (EU)  No  223/2014,  (EU)  No  283/2014,  and  Decision  No  541/2014/EU and  repealing 
Regulation (EU, Euratom) No 966/2012. 

76   Commission  Implementing  Regulation  (EU)  2022/79  of  19  January  2022  laying  down  rules  for  the 
application of Regulation (EU) 2021/1139 of the European Parliament and of the Council as regards the 
recording, transmission and presentation of operation-level implementation data. 

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Table 17: EMFAF common result indicators 

Source: The Commission publishes data on the implementation of Member States’ programmes using the 
data reported by the Member States. 

119 

 
 
 
 
 
 
 
 
 
13.  ANNEX VIII. RESPONSE TO THE REGULATORY SCRUTINY BOARD 

RSB 

1) Policy context 

The European Maritime, Fisheries and Aquaculture Fund (EMFAF) is a 
successor to long-standing fisheries support programmes in previous 
programming periods, to enable a sustainable blue economy, the 
conservation of marine resources and the supply of aquatic food 
products.  
Under the multiannual financial framework 2021-2027, EMFAF is 
implemented mainly (EUR 5.31 billion) under shared management in 
partnership between the Commission and Member States, and to a lesser 
extent (EUR 0.79 billion) under direct or indirect management by the 
Commission. 
The mid-term evaluation covers the period from 2021 until early 2024 
and is a legal requirement of the Common Provisions Regulation (EU) 
2021/1060 and of the EMFAF Regulation (EU) 2021/1139. The purpose 
of the evaluation is to inform the design of future EU instruments in this 
policy area, as well as to identify lessons learned to improve 
implementation in the current period. 

2) Key issues 

The objectives are not operationalised and measurable to assess 
expected achievements. The methodological approach does not 
demonstrate the causal links between inputs and the achievement of 
objectives. 

On effectiveness, the definition and presentation of outputs is not 
comprehensive, in particular in terms of activities supported 

Common result 
indicators/Infosys 

No action needed 

Section 2.1 

In the assessment of efficiency, the report does not sufficiently 
demonstrate how the increase of administrative costs is consistent with 
the simplification objective. 

Included in p. 36 

The analysis on relevance does not consider emerging needs and current 
political 
priorities, especially on competitiveness. 

Included throughout the 
document 

(C) What to improve 

(1) The objectives should be clearly defined and operationalised in 
SMART terms to enable an informed assessment and measurement of 
the expected outcomes and achievements.  

Answered with the 
section: Approach to 
overcome the current 
limitations on section 
2.2 

120 

 
 
 
 
 
 
 
The report needs to clearly define points of comparison and what would 
be considered a successful outcome of the intervention. If objectives are 
further specified through decisions made on the national level the report 
needs to compile and analyse evidence demonstrating how the 
objectives have been operationalised through such national decisions, 
and what the expected outcomes could be /said to be/ on aggregate level.  

A similar analysis should be provided regarding the societal needs that 
are to be identified through a SWOT analysis.  

The report should present a comprehensive narrative of how the 
intervention was expected to work, what it was planned to achieve and 
the causal links between problems, needs, inputs, outputs, results and 
impacts. There should be a clear link from the baseline to the 
achievement of the objectives through the EMFAF.  

The report should identify any data gaps, including data needed for 
counterfactual analyses, and where relevant draw lessons for monitoring 
and evaluation arrangements in order to allow for causal attribution of 
impacts in the final evaluation 

(2) To better assess effectiveness and efficiency the report needs to 
provide additional information beyond budget deployment, and views of 
stakeholders, as indicators of achievements.  

When operations are used as output indicators they need to be defined in 
specific and measurable terms.  

Thereafter, the number, frequency and relative importance of such 
operations need to be stated in the report, for example, in the form of 
quantitative tables or diagrams. In addition to reporting operations, it 
should be clear if and what kind of other activities or outputs have 
possibly been generated.  

Revision of the section 
2.2.Summary of the 
impact assessment and 
reference to the 
Performance indicators 
in Annex I of the 
EMFAF regulation.   

Description in section 
2.1 of how the EMFAF 
was developed by MS 
using SWOT.  

The intervention logic 
is described in section 
2.1 

Described under 2.2  

Stakeholder 
involvement is 
described in the 
methodology section 
1.3 and throughout the 
report.  

The little information 
available has been 
provided in quantitative 
tables in section 3.1  
and 4.1. 

Due to the lack of data 
the number and 
frequency and relative 
importance cannot be 
determined at the state 
of the MTE.  

The report should assess whether and why it can be assumed that the 
funds have been allocated to the highest value activities. 

To be addressed in the 
retrospective evaluation 

3) The report should present a more thorough analysis of the 
simplification objective and the seemingly contrasting increase of 
administrative costs, explaining why the latter is deemed reasonable. 
This analysis should go beyond restating the opinions reported from 
stakeholders and take into account Commission policies regarding 
reduction of administrative costs.  
The analysis also needs to demonstrate how such costs will be 
distributed among different categories of stakeholders 

Section 4.1 
Section 5.1 

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(4) The report should include an improved analysis of relevance. It 
should better cover competitiveness both as part of the objectives stated 
in the underlying regulation and emerging needs and priorities. The 
analysis should also reflect on the relative allocation of resources and 
the effects of the funding on competitiveness. 

Section 4.3  

(5) The report should present the views of different stakeholder groups, 
including beneficiaries, unsuccessful applicants, businesses, civil society 
and other stakeholders external to the Fund governance. 

Stakeholder views have 
been covered 
throughout the SWD 

(6) Any conclusions or lessons learned in the report need to be fully 
supported by evidence and analysis, or else omitted. 

Revision of the 
conclusions based on 
the changes made 
throughout the report.  

122