COMMISSION STAFF WORKING DOCUMENT EVALUATION of the Innovation Fund's operation
Date: 2026-07-17
Institutions: Directorate-General for Climate Action, European Commission
Subjects: EU Emissions Trading Scheme, EU emission allowance, clean technology, fund (EU), greenhouse gas, innovation, pollution control measures, project evaluation, reduction of gas emissions, renewable energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.7.2026  SWD(2026) 199 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the Innovation Fund's operation {SWD(2026) 228 final}  
 
 
TABLE OF CONTENTS 

1. 

Introduction ..................................................................................................... 4 

1.1.  Purpose and scope of the evaluation ..................................................... 4 

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

1.2.1.  Methodology applied ............................................................... 5 

1.2.2.  Methodological limitations and mitigation measures .............. 6 

2.  What was the expected outcome of the intervention? ..................................... 9 

2.1.  Description and objectives of the Fund ................................................. 9 

2.2.  Points of comparison ........................................................................... 13 

3.  How has the situation evolved over the evaluation period? .......................... 15 

3.1.  Activities .............................................................................................. 17 

3.1.1.  Calls for ‘regular’ grants........................................................ 17 

3.1.2.  Competitive bidding .............................................................. 19 

3.1.3. 

‘As-a-service’ schemes .......................................................... 20 

3.1.4.  Blending operations ............................................................... 22 

3.1.5.  Other activities ....................................................................... 22 

3.2.  Portfolio outcomes ............................................................................... 25 

3.2.1.  Geographical and sectoral distribution .................................. 27 

3.2.2.  Project implementation and disbursement ............................. 29 

4.  Evaluation findings ........................................................................................ 31 

4.1.  To what extent was the Innovation Fund successful and why? ........... 31 

4.1.1.  Effectiveness .......................................................................... 31 

4.1.2.  Efficiency............................................................................... 40 

4.1.3.  Coherence .............................................................................. 48 

4.2.  How did the Innovation Fund make a difference and to whom? ........ 51 

4.3. 

Is the Innovation Fund still relevant? .................................................. 53 

4.3.1.  EU climate and energy policy objectives .............................. 53 

4.3.2.  Mechanisms to ensure continued relevance .......................... 55 

5.  Conclusions ................................................................................................... 57 

6.  Lessons learned ............................................................................................. 60 

Annex I  Procedural information ........................................................................ 63 

Annex II 

Methodology and analytical models used ............................. 70 

 
 
 
Annex III 

questions 

Evaluation  matrix  and  details  on  answers  to  the  evaluation 
72 

Annex IV 

Overview  of  benefits  and  costs,  table  on  simplification  and 
burden reduction .......................................................................................... 142 

Annex V 

Stakeholder consultations .................................................... 149 

 
 
 
 
 
Glossary 

Acronym 

Meaning 

AaaS 

CCS 

CCU 

CINEA 

CISAF 

CO2 

EEA 

Auctions-as-a-service 

Carbon capture and storage 

Carbon capture and utilisation 

European climate, infrastructure and environment executive agency 

Clean Industrial Deal State Aid Framework  

Carbon dioxide 

European Economic Area 

EU ETS 

European Union emissions trading system 

FP7 

GaaS 

GHG 

IFEG 

KPI 

IT 

LIFE 

Seventh Framework Programme, EU funding’s instrument focused 
on technological research between 2007-2013 

Grants-as-a-service 

Greenhouse gas 

Innovation Fund Expert Group 

Key performance indicator 

Information technology 

EU’s funding instrument for the environment and climate action   

LSC, LSP 

Large-scale call or project 

MSC, MSP 

Medium-scale call or project 

NCP 

PDA 

National contact point 

Project development assistance 

SSC, SSP 

Small-scale call or project 

SME 

TRL 

Small and medium sized enterprise 

Technology readiness level 

 
 
 
 
 
Term 

Definition 

Accessibility 

Ensuring applicants' ability to navigate the requirements of the 
calls, prepare competitive proposals, and obtain the support needed 
to participate effectively. 

Blending 
operations 

Competitive 
bidding 

Leveraging or 
mobilising 
investment 

Project size 

Cooperation framework established between the Commission and 
other public finance institutions to combine forms of support and/or 
financial instruments and/or budgetary guarantees, and funding 
from the private sector. 

Mechanism used by the Innovation Fund to award funding to 
producers of low- or zero-carbon products through a selection based 
on the most competitive bid. 

Attracting and unlocking private and/or public capital to fund 
supported projects. 

The size of a project refers to the categorisation used in the Fund’s 
legal framework: ‘small-scale project’ refers to a project with a 
total capital expenditure not exceeding EUR 20 000 000; ‘medium-
scale project’ to a project with a total capital expenditure above 
EUR 20 000 000 and not exceeding EUR 100 000 000; and ‘large-
scale project’ for a project with a total capital expenditure above 
EUR 100 million. 

Relevant costs 

Costs eligible for Innovation Fund support (net extra costs borne by 
the applicant due to the application of the innovative technology 
proposed). 

Replicability 

A project’s technical and market potential for widespread 
application or reproduction, or for future cost reductions. Part of the 
calls’ award criteria. 

RFNBO 

Renewable Fuels of Non-Biological Origin 

State aid 

Synergies 

Any economic advantage granted by a public authority, using state 
resources, on a selective basis to entities engaged in economic 
activity that distorts (or threatens to distort) competition in the EU 
market. 

For this evaluation, synergies are the deliberate efforts to align, 
connect, and streamline different EU policies, programmes, and 
legislative acts to maximise their impact while minimising burdens. 

Technical 
assistance 

Targeted, non-financial expert support to Member States, helping 
them support potential applicants and funded projects. 

Topic 

Sub-category within a call for proposals with a specific focus on 
size (i.e. small-scale) or theme (i.e. manufacturing). 

 
 
 
1. 

INTRODUCTION 

1.1.  Purpose and scope of the evaluation 

The Innovation Fund (the Fund) is a key instrument of the EU’s climate policy, sourced from 
the auctioning of allowances under the EU ETS, and designed to finance the demonstration and 
deployment of innovative low-carbon technologies in energy-intensive industries, renewable 
energy  production,  energy  storage,  industrial  carbon  management,  buildings  and  transport 
sectors  (maritime,  aviation  and  road  transport).  An  interim  evaluation  of  its  operation  is 
required under Article 24 of Commission Delegated Regulation (EU) 2019/856 in 2025 and 
every five years thereafter. 

This evaluation focuses on how the Fund has contributed to the EU’s climate, industrial and 
energy  objectives,  particularly  by  reducing  GHG  emissions,  supporting  breakthrough 
technologies, and leveraging additional public and private investment. It also examines how the 
Fund  has  been  implemented  in  practice,  including  its  governance  structures,  disbursement 
mechanisms,  and  alignment  with  the  objectives  of  the  EU  ETS  Directive.  Finally,  it  also 
assesses  the  Fund’s  coherence  and  synergies  with  other  EU  funding  instruments,  such  as 
Horizon  Europe  and  LIFE,  and  explores  its  added  value  compared  to  national-level  support 
schemes. 

The evaluation covers the period from the Fund’s start of operations in 2020 to 2025 (1). This 
period allowed for an assessment of the Fund’s early implementation, providing insights into 
how  it  has  developed  over  time,  adapted  to  changing  policy  and  market  conditions,  and 
responded to external shocks such as the COVID-19 pandemic and the energy crisis. 

The evaluation covers all countries eligible for Fund support, namely all European Economic 
Area (EEA) countries. It captures the Fund’s operations across diverse national and regional 
contexts, 
innovation  capacities,  and 
administrative systems. Attention was paid to participation across Europe and the way the Fund 
has addressed regional disparities in access to funding opportunities. 

including  differences 

industrial  structures, 

in 

In  line  with  the  Commission’s  better  regulation  guidelines,  the  evaluation  assessed  five 
evaluation criteria: the effectiveness of the Fund in achieving its objectives, the efficiency of 
its governance and funding mechanisms, its coherence with other EU and national policies, its 
relevance  in  addressing  identified  needs,  and  its  EU  added  value  compared  to  action  at  the 
national level. 

Based  on  the  evaluation  results,  the  Commission  will,  where  necessary,  make  proposals  to 
ensure  that  the  Fund  progresses  towards  achieving  its  objectives  set  out  in  Directive 
2003/87/EC (2). The evaluation results will also inform the impact assessment of the revision 
of the EU ETS Directive. 

(1)  The data analysed covers information available up to the first quarter of 2025 (Q1 2025). This cut-off date 
reflects the project portfolio, budget monitoring and evaluation updates. In some cases, the latest figures 
from the Fund dashboard (including November 2024 updates) were used when they provided more recent or 
more granular information. 

(2)  Commission Delegated Regulation (EU) 2019/856 of 26 February 2019 supplementing Directive 2003/87/EC 
of the European Parliament and of the Council with regard to the operation of the Innovation Fund, Article 
24(2), available at: Delegated regulation - 2019/856 - EN - EUR-Lex 

 
 
 
 
1.2.  Methodology 

1.2.1.  Methodology applied 

To gather insights into the Fund’s performance since its start, external contractors conducted a 
supporting study (3). The study reviewed the Fund’s achievements to date and highlighted areas 
where its design and implementation could be strengthened to maximise its contribution to the 
EU’s 2030 and 2050 climate targets. The study combined desk research, interviews, surveys, a 
cost-benefit analysis and case studies to provide a comprehensive evidence base to inform the 
Fund’s evaluation. 

The evaluation employed a mixed-methods approach, combining quantitative and qualitative 
data to assess the five evaluation criteria. The methodology included: a ‘call for evidence’, a 
public  consultation  questionnaire,  targeted  interviews,  stakeholder  surveys,  and  workshops. 
This  multi-pronged  methodology  ensured  a  comprehensive  understanding  of  the  Fund’s 
performance from diverse perspectives, including applicants, beneficiaries, public authorities, 
National Contact Points (NCPs), and industry and civil society stakeholders. 

The data analysed covers information available up to the first quarter of 2025. This cut-off date 
reflects  the  project  portfolio,  budget  monitoring  and  evaluation  updates.  In  some  cases,  the 
latest figures from the Innovation Fund dashboard (including November 2024 updates) were 
used when they provided more recent or more granular information, or data from end of 2024 
when  later  data  was  not  available.  Data  was  collected  from  several  sources,  including  the 
quarterly  reports  (cut-off  date  Q1  2025),  an  internal  operational  document  on  ongoing  and 
terminated  projects,  the  Annual  Knowledge  Sharing  Report  on  projects’  challenges  and 
measures,  as  well  as  the  performance  framework  and  other  data  sources  such  as  progress 
reports, anonymised evaluation reports, EIB reports and legal frameworks (4). 

The  ‘call  for  evidence’  and  public  consultation  gathered  input  from  190  respondents, 
representing  businesses  (40–53%),  public  authorities,  NGOs,  and  citizens  across  EEA 
countries. These contributions highlighted broad support for the Fund’s role in decarbonisation 
but  also  identified  key  challenges,  such  as  administrative  burden  for  small-scale  projects, 
geographical imbalances, and the need for simplified application processes. Public authorities 
emphasised the disproportionate reporting requirements and suggested priority access to Project 
Development  Assistance  (PDA)  for  underserved  regions.  Complementary  position  papers, 
desktop research and case-specific feedback further enriched the evidence base. 

To  deepen  insights,  79  structured  interviews  were  conducted  with  beneficiaries,  EU 
Commission  staff,  members  of  the  Innovation  Fund  Expert  Group  (IFEG),  evaluators,  and 
financial partners (e.g. the European Investment Bank). These interviews explored operational 
challenges, success factors, and areas for improvement, with a focus on project implementation, 
blending  mechanisms,  and  strategic  alignment.  Additionally,  four  targeted  surveys  were 
deployed: 

(3)  Study for the evaluation of the operation of the Innovation Fund, contracted out to Ramboll, December 2025, 

link: https://data.europa.eu/doi/10.2834/5290243 

(4)  The evaluation’s support study provides a full overview of the methodology and data sources used. 

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–  A beneficiaries’ survey (124 responses) assessed the Fund’s added value; 

–  An unsuccessful applicants’ survey (154 responses) identified barriers to access; 

–  An NCP survey (27 responses); and 

–  A  survey  with  Horizon  Europe  beneficiaries  (79  responses)  examined  synergies 

between programmes. 

Finally, the Directorate General for Climate Action (DG CLIMA) organised a ‘reality check’ 
on  12  November  2025,  an  in-person  workshop  with  selected  practitioners  to  discuss  the 
preliminary  conclusions  and  lessons  learned  from  the  evaluation.  Annex  B  provides  further 
details on the methodology and analytical models used. 

1.2.2.  Methodological limitations and mitigation measures 

While the methodological approach is robust, some limitations should be acknowledged when 
interpreting findings. 

A first limitation relates to the timing of the evaluation. The Fund was launched in 2020, and 
many supported projects are still in the first stages of implementation and have not yet reached 
a  final  investment  decision.  These  early  and  limited  results  do  not  allow  for  any  valid 
conclusions about the overall portfolio performance in achieving GHG emissions avoidance. 
The  evidence  is  thus  largely  prospective  and  focuses  more  on  expected  outcomes  and  the 
efficiency of processes  rather than on realised outcomes,  such as GHG emissions reduction, 
replicability, or market transformation.  

A  second  and  related  limitation  concerns  data  availability  and  completeness.  While 
monitoring data, project documentation, surveys, and interviews generated valuable insights, 
not all the indicators necessary to answer the evaluation questions were consistently reported. 
Although  the  Fund’s  monitoring  system  (e.g.  quarterly  reports,  public  dashboard)  tracks 
information  on  project  implementation  and  characteristics,  some  economic  performance 
indicators (e.g. job creation, gross added value) are not collected. In some cases, confidentiality 
and  commercial  sensitivity  (although  intrinsic  to  the  Fund)  may  have  limited  beneficiaries' 
willingness  to  disclose  detailed  project  information  (especially  on  resources),  thereby 
restricting the depth of analysis of certain aspects.  Nonetheless, the level of detail provided 
was  still  sufficient  to  understand  the  most  important  aspects  of  project  implementation,  the 
challenges encountered and the reasons for termination. 

Similarly,  data  on  costs  for  various  stakeholders,  including  applicants,  has  not  been 
continuously  collected  since  the  beginning  of  the  evaluation  period.  In  the  2023  applicants 
survey, DG CLIMA started collecting data on the costs of applying to the Fund. The survey 
was further expanded in 2024. Hence, the two data sets were not comparable. This data gap was 
mitigated by introducing questions on application costs and administrative costs for reporting 
and monitoring across the surveys conducted for the evaluation to assess efficiency (see section 
4.1.2). However, the evolution of costs during the evaluation period could not be analysed to 
the same extent.  

Although  data  on  co-financing  is  available  at  the  application  stage,  it  is  most  reliable  when 
projects reach financial close. Indeed, beneficiaries must report information on other sources of 
financing  (public  and  private)  in  their  application.  They  are  then  required  to  update  these 

6 

 
 
sources of  co-financing  in their reporting obligations for financial close.  This  ‘lag’ between 
information provided at the application stage and at financial close limits the ability to assess 
the financing structure of supported projects and the Fund’s leverage at this time.  

Another challenge identified  stems  from  data management. Although data is  reported in  the 
relevant documents for each process, it has not yet been collected and stored in a structured 
database.  Therefore,  only  limited  data  is  currently  presented  in  the  public  dashboard  and  in 
knowledge sharing reports. The Fund had already identified this gap, as well as others, before 
the evaluation and initiated work to develop a Knowledge Sharing Digital Solution (KSDS) (5), 
expected to standardise data collection and create a single database for information collected 
from  projects.  Although  this  limitation  did  not  affect  the  evaluation’s  work,  introducing  a 
centralised data source will make monitoring and reporting more efficient. 

While surveys and interviews captured a broad range of perspectives, participation rates varied 
across stakeholder groups and sectors. Large companies and the hydrogen sector participated 
most frequently in these consultations.  This composition broadly mirrors the Fund’s portfolio 
and  application  patterns,  in  which  large  industrial  players  and  hydrogen-related  projects 
account  for a significant share of proposals and awarded projects. Their strong participation 
thus contributes to the representativeness of consultation findings.  

A slight geographical concentration is also evident among both beneficiaries and unsuccessful 
applicants.  Western  EEA  countries  along  the  corridor  from  Spain  to  Germany  were  well 
represented,  with  only  a  few  responses  from  central  and  eastern  EEA  countries.  While 
participation  rates  varied,  the  overall  reliability  of  the  evidence  base  remains  high.  The 
evaluation draws on multiple, complementary sources, which were systematically triangulated 
to validate findings and ensure that conclusions do not rely on a limited number of individual 
responses. 

These  imbalances  may  have  introduced  a  degree  of  selection  bias  (that  is,  a  potential 
overrepresentation of specific stakeholder groups) stemming from diversity within the Fund’s 
portfolio,  varying  capabilities  to  engage  in  consultations,  and  geographical  disparities  in 
innovation  ecosystems.  Indeed,  the  perspectives  of  larger,  better-resourced  actors  are  more 
prominently represented than those of smaller ones or stakeholders from countries with less 
advanced  innovation  ecosystems.  For  instance,  the  beneficiaries’  survey  achieved  a  high 
response rate: 124 respondents out of 188 who received invitations (66 %). Still, coverage of 
SMEs  and  micro-enterprises  was  limited:  26  entities  out  of  71  SMEs  participating  in  Fund 
projects by the end of March 2025. These 71 SMEs were participating in 50 projects. Among 
them, 35 are project coordinators.  

Similarly, the survey of unsuccessful applicants generated a sizeable sample (154 respondents). 
Yet nearly half of the respondents were large industrial actors (42 %, 65 out of 154), which may 
obscure the barriers faced by smaller or less conventional applicants. This selection bias was 
considered and mitigated throughout the analysis by selecting interviews and case studies to 
cover a range of sectors, technologies, and geographies. Still, practical constraints meant that 
some perspectives remained underrepresented. However, while valuable for offering in-depth 
qualitative insights, case studies are more illustrative than representative and so cannot capture 
the full diversity of experiences across the portfolio. 

(5)  The KSDS aims to collect information on project implementation. Its launch is planned for Q4 2026. 

7 

 
 
 
The reliance on self-reported evidence introduces further limitations. Survey and interview 
data  are  subject  to  recall  bias,  self-selection  effects,  and  potentially  strategic  framing. 
Respondents might also interpret the same survey questions differently, potentially affecting 
the comparability of responses. These risks were mitigated through drafting of questions and 
through triangulating consultations with desk research, project documentation, and monitoring 
data.  However,  the  potential  for  uneven  coverage  and  partial  perspectives  cannot  be 
disregarded. While consultation activities offered insights into prevailing themes, trends, and 
perceptions,  they  should  thus  be  interpreted  as  indicative  rather  than  representative  of  the 
Fund’s portfolio. 

A third limitation  concerns  the  attribution of effects. The  Fund’s support  is  one of several 
factors shaping project development, bankability and deployment, alongside national subsidies, 
private  financing,  or  other  EU  programmes  (such  as  Horizon  Europe,  LIFE,  InvestEU,  the 
Modernisation  Fund,  and  CEF).  Distinguishing  its  contribution  from  these  parallel  funding 
sources  is  complex.  This  challenge  is  compounded  by  the  unfeasibility  of  a  counterfactual 
impact  evaluation  design,  such  as  through  comparison  with  a  control  group.  Indeed,  Fund 
projects are unique and heterogeneous. They differ widely in technology, sector, composition, 
and geography, making it difficult to find a comparable control group. This risk was mitigated 
by  a  ‘reality  check’.  Although  a  valuable  tool  for  validating  practical  experiences,  ‘reality 
checks’ are not equally suited to all areas of the evaluation. They provide limited added value 
for  questions  that  rely  on  quantitative  analysis,  such  as  measuring  emissions  reductions, 
calculating induced investment ratios, or conducting cost–benefit assessments, which require 
comprehensive datasets and modelling. 

The  Fund  also  operates  within  a  complex  market  and  policy  environment  characterised  by 
overlapping support measures, evolving regulatory frameworks, and global market dynamics. 
These  attribution  challenges  are  also  intertwined  with  broader  contextual  factors  (such  as 
exogenous  shocks,  supply  chain  disruptions,  and  geopolitical  developments),  which  further 
complicate efforts to isolate the Fund’s specific effects from these factors. The evaluation thus 
relies  on  triangulation  of  qualitative  and  quantitative  evidence  to  approximate  the  Fund’s 
contribution. 

A  fourth  limitation  relates  to  the  points  of  comparison.  Assessing  the  Fund's  performance 
requires a benchmark, either against similar EU programmes, national schemes, or the Fund’s 
stated  objectives.  Each  has  drawbacks  that  are  important  to  consider  when  interpreting  the 
analysis. 

Other EU programmes can, by definition, only be compared to a limited extent with the Fund 
as they have different objectives, target groups, selection criteria, disbursement and monitoring 
requirements. For instance, while the Fund is primarily focused on GHG emissions reduction 
and project selection is largely based on this criterion, this is not the case for other programmes. 
National schemes vary significantly in scope, scale, and eligibility, and internal targets may not 
fully capture the Fund’s broader political ambition.  

Moreover, as the Fund is a new instrument, its performance cannot be directly compared with 
earlier cycles. Its predecessor programme (NER 300) provides historical context but differs in 
scope, objectives and design, limiting its utility as a benchmark. Therefore, these differences 
need to be considered when drawing conclusions based on these comparisons. 

Finally, contextual dynamics during the evaluation period posed external limitations. The 
Fund's implementation coincided with exogenous shocks, including the COVID-19 pandemic, 

8 

 
 
supply  chain  disruptions,  inflationary  pressures,  and  the  energy  price  crisis  triggered  by 
Russia’s  war  of  aggression  against  Ukraine.  Together  with  rising  capital  costs,  these 
developments affected projects’ costs, timelines, and investment conditions, making it difficult 
to disentangle the effect of the Fund’s design from broader market and geopolitical factors. 

To address these limitations and minimise their effects on the evaluation results, as outlined for 
each limitation, mitigation strategies were implemented. These include triangulating various 
evidence sources (desk research, surveys, interviews, case studies, and a public consultation) 
and validating findings through a ‘reality check’. As a result, the evaluation provides a credible 
and  balanced  assessment  of  the  Fund’s  performance  to  date,  while  acknowledging  the 
constraints imposed by timing, data availability, confidentiality, attribution challenges, and the 
lack of fully comparable benchmarks. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.  Description and objectives of the Fund 

The Fund was established through the 2018 revision of the EU ETS Directive (Directive (EU) 
2003/87/EC), supported by the corresponding Impact Assessment, which identified the need 
for a dedicated EU-level mechanism to accelerate the demonstration and deployment of low-
carbon  technologies.  The  impact  assessment  highlighted  that  achieving  the  EU’s  long-term 
climate objectives required substantial early investment in innovative technologies, well before 
their commercial maturity, particularly in hard-to-abate sectors and long-distance transport and 
justified the creation of the Fund. 

The  Impact  Assessment  accompanying  Delegated  Regulation  (EU)  2019/856,  which 
operationalised  the  Fund,  reiterated  this  need.  It  emphasised  that,  without  targeted  support, 
many  promising  solutions  (such  as  hydrogen  electrolysers,  industrial  electrification,  carbon 
capture  and  storage  (CCS),  carbon  capture  and  utilisation  (CCU),  and  innovative  industrial 
processes)  risked  remaining  stuck  in  the  ‘valley  of  death’  between  demonstration  and 
commercialisation (6). 

The Fund began operations with its first call for proposals in 2020. At that time, the EU had 
proposed to become climate-neutral by 2050 as part of the European Green Deal. To put the 
EU  on  the  path  to  climate  neutrality,  the  Commission  proposed  the  Fit  for  55  package  of 
legislative measures in July 2021, establishing the legal framework to reduce emissions by 55 
% by 2030. Meeting this enhanced level of ambition required both a rapid scale-up of mature 
renewables  (such  as  wind  and  photovoltaics)  and  an  accelerated  deployment  of  less  mature 
technologies needed for deep decarbonisation, including green hydrogen, advanced CCS/CCU, 
and innovative industrial processes (7). 

At the same time, many of the key technologies required for decarbonisation, notably renewable 
hydrogen,  CCS,  and  long-duration  energy  storage,  were  still  at  the  demonstration  or  early 
commercial readiness stage. These maturity constraints were reinforced by additional barriers: 

(6)  Muscio, A., Simonelli, F., & Vu, H. (2023). Bridging the valley of death in the EU renewable energy sector: 

Toward a new energy policy. Business Strategy and the Environment, 32(7), 4620–4635. 

(7)  IEA (2023), Energy Technology Perspectives 2023, IEA, Paris. 

9 

 
 
 
funding gaps, performance uncertainties, a lack of infrastructure (e.g. grids, storage, transport), 
and long lead times of up to a decade for industrial-scale implementation. 

The  enhanced  ambitions  also  meant  that  European  industries  faced  a  steeper  trajectory  to 
decarbonise while maintaining their global competitiveness. However,  the  absence of stable 
offtake  markets  and  demand-side  signals  limited  business  cases.  Financing  from  private 
investors  was  scarce.  National  support  mechanisms  existed  but  were  fragmented,  varied  in 
scale, and often insufficient to close investment gaps (8). Flexible financing tools, such as risk-
sharing, blending finance, or contracts for difference, were limited. Against this background, 
the  EU  needed  a  predictable,  large-scale  mechanism  that  could  de-risk  investments,  create 
competition  based  on  excellence,  accelerate  financial  close,  and  provide  confidence  to  both 
innovators and investors (9). 

These barriers could not be effectively addressed by national authorities acting alone. Many 
technologies  require  coordinated  cross-border  infrastructure  and  a  well-developed  internal 
market,  with  existing  demand  for  low-carbon,  innovative  products  (for  example,  hydrogen 
pipelines, electricity grids, or CO2 transport and storage networks) that no single Member State 
could develop in isolation. Fragmented national support risks duplication, uneven competition 
and an unlevelled playing field across the internal market. The EU also faced intensifying global 
competition,  as  Japan  advanced  hydrogen  solutions,  South  Korea  expanded  renewable 
deployment, and China gained strong positions in electric vehicles and batteries (10). Without 
an  EU-level  response,  the  EU  risked  missing  its  climate  targets  and  losing  industrial 
competitiveness  in  fast-growing  clean  technology  markets,  with  implications  for  industrial 
growth, job creation, and strategic autonomy (11). 

The Fund was designed to complement research-focused funding instruments (such as Horizon 
Europe)  by  supporting  the  later  stages  of  the  innovation  chain,  bridging  the  gap  from 
demonstration to commercialisation. It was designed not only to accelerate the deployment of 
low-carbon technologies but also to stimulate the creation of new markets for climate-neutral 
products,  thereby  reinforcing  the  EU’s  technological  leadership  in  the  global  transition  to 
climate neutrality (12). 

The Fund’s legal basis is anchored in the EU ETS Directive (13), with detailed operational rules 
set  out  in  Delegated  Regulation  (EU)  2019/856,  as  amended  by  Delegated  Regulation  (EU) 

(8)  Delors Centre (2025). Lost in implementation?, Jacques Delors Centre Policy Brief, April 2025; Green 

Finance Institute (2025). Financing Europe’s Industrial Decarbonisation 

(9)  World corporate top R&D investors – Paving the way to carbon neutrality (2021). 

(10)  World corporate top R&D investors – Paving the way to carbon neutrality (2021); DG CLIMA - Market 

testing for low-carbon innovation support to energy intensive industry and to power generation – Demand 
for innovation support (2018). 

(11)  Delors, J. & all, Making the Energy Transition a European Success, Report, Jacques Delors Institute, 

(2017). 

(12)  European University Institute (EUI), Debelke, J., Egenhofer, C., & Lamas, R., Options to finance the premium 

cost of climate-neutral products in the EU : the potential of the ETS and demand creation, (2022) 

(13) European Commission, Directive 2003/87/EC of the European Parliament and of the Council of 13 October 
2003  establishing  a  system  for  greenhouse  gas  emission  allowance  trading  within  the  Union  and  amending 
Council Directive 96/61/EC. Available at: https://eur-lex.europa.eu/eli/dir/2003/87/2024-03-01/eng 

10 

 
 
 
2023/2537. Together with the Impact Assessment (14) and Explanatory Memorandum (15), these 
documents justified the need for EU action to address the financial and technological barriers 
that prevent innovations from reaching the market, support climate objectives, and reinforce 
the EU’s competitiveness. 

The  Fund’s  overall  objective  is  to  support  innovation  in  low-  and  zero-carbon  techniques, 
processes and technologies that contribute significantly to the decarbonisation of the sectors 
covered by the EU ETS Directive and to zero pollution and circularity objectives, including 
projects  aimed  at  scaling  up  such  techniques,  processes  and  technologies  for  broad  roll-out 
across  the  EU.  Such  projects  must  have  significant  potential  to  reduce  GHG  emissions  and 
contribute to energy and resource savings, in line with the EU’s climate and energy objectives. 

With the 2023 revision of the EU ETS Directive (16), the EU ETS was extended to maritime 
transport  and  established  a  separate  ETS  (ETS  II)  covering  buildings  and  road  transport. 
Delegated  Regulation  (EU)  2019/856  was  amended  in  2023,  notably  with  provisions  on 
competitive bidding (Article 10b). These changes further anchored the Fund within the broader 
policy framework of the European Green Deal, European Climate Law, and the Clean Industrial 
Deal. 

The  Intervention  Logic  (Figure  1)  describes  how  the  Fund  combines  dedicated  resources, 
structured activities and targeted support mechanisms to generate outputs, results and long-term 
impacts.  By  mapping  the  pathways  from  inputs  to  impacts,  and  testing  the  underlying 
assumptions  and  risks,  the  intervention  logic  frames  the  evaluation  of  the  Fund’s  ability  to 
deliver on its intended objectives. 

The Fund was designed to conduct a wide range of activities to achieve its objectives, including 
calls for proposals (‘regular’ grants and auctions), technical assistance, support to applicants, 
PDA,  blending  operations,  ‘as-a-service’  schemes,  communication  and  knowledge  sharing 
activities. 

In the short-term, the  outputs of the intervention  (i.e. the  Innovation  Fund)  are expected to 
include the selection and implementation of projects, the disbursement of financial support, the 
provision of technical assistance to national authorities and applicants, and the production of 
communication materials (press releases, reports, training sessions, and workshops). 

(14)  European  Commission,  Commission  Staff  Working  Document:  Impact  Assessment  Accompanying  the 
Document  Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  on  the  Protection  of 
Undisclosed Know-How and Business Information (Trade Secrets) Against Their Unlawful Acquisition, Use 
and  Disclosure  (SWD(2015)  135  final,  28  November  2015),  Available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex:52015SC0135. 

(15)  European  Commission,  Communication  from  the  Commission:  (C(2019)  1492  final),  available  at: 

https://climate.ec.europa.eu/document/download/783eaa94-ef70-4679-909f-
e088a930ac3e_en?filename=c_2019_1492_en.pdf. 

(16)  European Commission, Directive (EU) 2023/959 of the European Parliament and of the Council of 10 May 
2023 amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading 
within  the  Union,  Official  Journal  of  the  European  Union  L  130,  16  May  2023,  available  at:  https://eur-
lex.europa.eu/eli/dir/2023/959/oj/eng 

11 

 
 
 
Figure 1: Intervention logic for the evaluation of the Innovation Fund 

12 

 
 
 
 
In  the  medium  term,  these  outputs  should  deliver  results  that  are  critical  to  the  Fund’s 
effectiveness. Supported projects are expected to reach milestones such as financial close and 
entry into operation (17) and to operate for at least 10 years, demonstrating their viability and 
replicability.  The  distribution  of  funding  is  expected  to  ensure  geographical  and  sectoral 
balance,  and  be  reinforced  by  targeted  assistance  and  simplified  procedures  to  broaden 
participation  from  underrepresented  EEA  countries  .  The  Fund  is  also  designed  to  mobilise 
additional  investment  from  public  and  private  sources  and  to  reduce  risks  associated  with 
innovative low-carbon technologies. Mechanisms such as auctions and ‘as-a-service’ schemes 
are intended to streamline processes and reduce administrative burden by eliminating the need 
for separate national calls, building on European-level competition, and offering a streamlined 
process for State aid notification by being in line with the applicable State aid rules. Finally, 
PDA  and  other  forms  of  support  aim  to  strengthen  the  technical  and  financial  maturity  of 
proposals to secure funding. 

The  results  are  intended  to  lead  to  long-term  impacts.  Supported  projects  are  expected  to 
deliver significant reductions in GHG emissions. By supporting first-of-a-kind and replicable 
projects, the Fund is designed to reinforce the competitiveness of EU industry, creating new 
value  chains  and  consolidating  the  EU’s  global  position  in  clean  technologies.  Anticipated 
broader  socio-economic  impacts  include  job  creation  and  the  development  of  new  skills, 
supporting a just and inclusive transition to a low-carbon economy. 

External factors could affect the intervention’s expected achievements as available resources 
depend on the price of carbon in the EU’s carbon market. On the project side, permitting delays, 
cost inflation, and operational risks are common for first-of-a-kind deployments. Broader risks, 
such as regulatory or political uncertainties and weak demand signals for low-carbon products, 
could also affect project viability and market uptake. 

2.2.  Points of comparison  

The evaluation requires reference points against which to assess progress. They describe the 
baseline situation at the Fund’s launch in 2020. Looking at the situation before the Fund was 
implemented  allows  to  show  what  might  have  happened  during  the  evaluation  period  if  the 
Fund had not been put in place. 

Before 2020, the situation for sectors covered by the EU ETS Directive was as follows (18): 

–  Low-carbon technology demonstration projects are inherently high-risk endeavours and 

tend to struggle to attract the required capital (19). 

(17)  Financial close refers to the stage when a project has secured all financing agreements and can continue to 

implementation. A project must reach this stage within four years of the award decision. Entry into 
operation refers to the start of its operational phase and should occur within five years after financial close, 
unless a longer period is justified by the project’s characteristics (Delegated Regulation (EU) 2019/856, Art. 
11(2)). 

(18)  European Commission, Staff Working Document SWD(2019) 85 final – Impact assessment, unless otherwise 

stated. 

(19)  Market  testing  for  low-carbon  innovation  support  to  energy  intensive  industry  and  to power  generation  – 
Demand for innovation support (2018); NER 300 lessons learnt – Executive summary, Publications Office, 
2018. 

13 

 
 
 
–  For energy-intensive industries, expert consultations showed a wide range of options 
(broadly categorised as process innovations, new products, and end-of-pipe solutions). 
Yet most were still in the development phase and required significant investment to be 
demonstrated at an industrial scale. Relevant projects were not undertaken, especially 
given the risks and the investments required to demonstrate their technical feasibility. 

–  Emerging  renewable  energy  technologies  such  as  ocean  energy,  floating  wind, 
geothermal, concentrating solar power technologies and advanced bioenergy continued 
to  struggle  to  achieve  the  critical  mass  demonstration  needed  to  enable  further  cost 
reductions and spur rollout at scale (20). 

–  Large-scale  demonstration  of  innovative  solutions  was  particularly  slow  in  the 
renewable  heating  and  cooling  technology  category,  including  electricity  storage, 
which is of high importance given that heating and cooling in buildings and industry 
account for half of the EU’s energy consumption. 

–  The  number  of  installed  CCS  facilities  was  much  lower  than  expected  because  the 
technology's cost had precluded widespread adoption. The technology requires higher 
carbon prices to be competitive. In addition, projects required integration into complex 
industrial  chains,  further  increasing  their  risks.  It  was  thus  important  to  maintain 
support  to  demonstrate  the  viability  of  projects  and  the  safe,  reliable  underground 
storage of carbon dioxide (CO2). 

For net-zero mobility and buildings (which were included in the scope of the Fund only since 
the revision of the EU ETS Directive), the situation before 2023 was as follows: 

–  Emissions reductions had been insufficient to put the EU on a firm path towards climate 

neutrality. Thus, a market incentive for investment was needed (21). 

–  The EU ETS did not yet cover maritime transport, and the sector’s contribution to EU 
emissions reductions remained minimal. Analysis projected maritime GHG emissions 
to rise by about 14 % by 2030. The revision of the EU ETS Directive included the sector 
and  enabled  the  Fund  to  finance  low-carbon  maritime  technologies,  such  as  green 
hydrogen, ammonia, and alternative fuels. At the end of Q1 2025, the number of Fund 
projects in maritime and aviation remained low (six in maritime and one in aviation, 
according  to  the  latest  quarterly  report),  making  it  difficult  to  compare  the  situation 
today with that before 2023 in a meaningful way. 

–  Aviation was already partly covered by the EU ETS,  but only for intra-EEA flights. 
Baseline  projections  showed  emissions  would  continue  to  grow,  underscoring  the 
limited  effectiveness  of  existing  measures.  The  revision  of  the  EU  ETS  Directive 
reduced airlines' free allowances and channelled additional revenues to the Fund. 

(20) European Commission, The Future of Food and Farming: For a sustainable European and global food system, 
COM(2019)  640  final,  2019,  https://op.europa.eu/en/publication-detail/-/publication/7fc3beff-2b55-11e9-
8d04-01aa75ed71a1/language-en. 

(21)  European Commission, ‘EU Emissions Trading System (ETS 2): Buildings, Road Transport and Additional 
Sectors’, Climate Action, available at: https://climate.ec.europa.eu/eu-action/carbon-markets/ets2-buildings-
road-transport-and-additional-sectors_en [accessed 24 June 2026] 

14 

 
 
 
Overall, low-carbon demonstration projects faced three main types of risks that were largely 
beyond the control of the individual project operator: 

–  Technology risks related to the demonstration of technologies not yet tested at large 
scale - even if they worked in the laboratory or at a pilot facility, they may have failed 
or underperform when scaled up. 

–  Market risks related to the development of carbon, energy, and commodity prices meant 
that  current  and  expected  price  levels  were  not  sufficiently  incentivising  private 
operators to invest in these projects. 

–  Risks related to policy changes were particularly relevant for investments in low-carbon 
technologies  that  may  operate  for  20  years  or  longer,  as  their  viability  depends  on 
specific policies (e.g. a carbon price or a feed-in tariff). 

Lessons learned from the experience with  NER 300 provided insights into the problems the 
Fund was meant to address at its inception: 

–  The NER 300 programme left the technology risk largely with the project operator, as 
the grant was fully paid out if at least 75 % of the planned emissions reductions were 
achieved, unless Member States guaranteed upfront funding. It did not de-risk projects 
during the first stages of development because it provided funding only after entry into 
operation, based on verified emission reductions. However, many projects encountered 
difficulties  during  the  first  stages,  especially  in  securing  additional  financing.  The 
promise of a grant disbursement upon entry into operation was not sufficient to entice 
third parties to provide additional upfront financing. 

–  Under NER 300, Member States were responsible for the pre-selection and nomination 
of projects, as well as for the signing and management of contracts. The Commission 
selected projects after the EIB conducted due diligence. The role of the Member States 
was  supposed  to  ensure  financial  and  regulatory  support  to  the  selected  projects. 
However,  this  support  materialised  only  to  a  limited  extent  and  led  to  complex 
interactions among different parties, including project proponents, national authorities, 
the EIB, and the Commission. 

–  The European Court of Auditors also found that “the design of the NER 300 limited the 
to  changing 

to  respond  effectively 

Commission  and  Member  States  ability 
circumstances” (22). 

For a full description of the points of comparison, please see Annex III. 

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

The Fund’s legal framework has evolved to align with the EU’s increasingly ambitious climate 
targets, respond to lessons learned from earlier programmes, and adapt to the dynamics of the 
carbon market. 

(22)  European Court of Auditors, Climate Action: Low-carbon economy – Significant reduction in greenhouse gas 
emissions from cars not yet in sight (Special Report No. 24/2018), Publications Office of the European Union, 
2018, https://op.europa.eu/webpub/eca/special-reports/climate-action-24-2018/en/ 

15 

 
 
 
The Fund’s foundation lies in the EU ETS Directive, which established the EU’s cap-and-trade 
system and earmarked auctioning revenues to support climate innovation: 

–  In 2018, an major amendment of the EU ETS Directive aligned the EU ETS with the 
then-agreed ambition of the 2030 climate and energy framework. It allocated the sale 
of 530 million EU ETS allowances to the Fund, at an estimated carbon price of EUR 
75 per tonne of CO2. As the cumulative emission cap for 2021-2030 is about EUR 12 
billion in allowances, the Fund thus represents 4.4 % of the EU ETS. 

–  The 2023 revision of the EU ETS Directive further tightened the emissions cap, setting 
the EU on a path to achieve 55 % emission reductions by 2030. It extended the EU ETS 
to new sectors, such as maritime and aviation, thereby broadening the Fund’s scope and 
resources. 

The Fund’s operational rules are set out in Delegated Regulation (EU) 2019/856, which defines 
eligibility  conditions,  award  and  selection  procedures,  milestone-based  disbursements,  and 
measures  to  support sectoral  and geographical  balance.  It  also  introduced PDA and enabled 
blending operations. Detailed arrangements for calls, submission and evaluation procedures, 
and  monitoring  requirements  are  further  specified  in  the  Commission’s  annual  Financing 
Decisions  and  in  the  delegation  of  tasks  to  CINEA.  The  2023  amendment  of  Delegated 
Regulation (EU) 2019/856 updated the Fund’s rules to align with the revised ETS Directive. 

Table 1: Innovation Fund budget 

Year 

2020 

2021 

2022 

2023 

2024 

2025 

IF auctioned 
allowances, in 
million 

Average carbon 
price, in 
EUR/tCO2e 

RePowerEU 
transfers, in 
billion EUR 

IF commitments, 
in billion EUR 

50 

40 

40 

40 

87 

87 

32.7 

80.7 

84.0 

83.3 

64.5 

73.5 

- 

- 

- 

1.5 

3.4 

3.8 

0.00 

0.15 

2.95 

3.54 

5.24 

5.05 

The total volume of Fund-auctioned  allowances  comprises both the allowances  auctioned to 
finance  the  Fund  and  those  whose  proceeds  are  earmarked  for  transfer  to  REPowerEU. 
Following an amendment in 2023 to the EU ETS Directive (23), EUR 12 billion from the  Fund's 
monetised resources will be made available to support REPowerEU actions by August 2026. 
This total includes allocations under the various funding streams, namely calls for proposals, 
PDA, and administrative expenditure. The figures reflect the Fund’s status at the end of Q1 
2025. 

(23)  European Comission, Regulation (EU) 2023/435 of 27 February 2023 Establishing a Framework for Ensuring 
a Secure and Sustainable Supply of Critical Raw Materials and Amending Regulations (EU) 168/2013, (EU) 
2016/1036, (EU) 2018/858, (EU) 2018/1724 and (EU) 2019/1020 [2023] OJ L 62/1, available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32023R0435. 

16 

 
 
 
 
3.1.  Activities 

The Fund uses two types of calls for proposals to allocate support: calls for ‘regular’ grants and 
auctions (i.e. competitive bidding). At the end of 2024, the Commission had launched nine calls 
for proposals. These calls had a combined budget of EUR 11.8 billion. 

Considering that, in line with Article 110(5) of Regulation (EU, Euratom) 2018/1046 and the 
updated Financial Regulation 2024/2509, the  annual financing decisions allowed the  Fund’s 
annual budgets to increase by 20 %, projects have been awarded a total of EUR 12.7 billion 
through calls for proposals. 

The  Fund  also  uses  blending  operations  with  the  EU-Catalyst  Partnership and  through 
InvestEU, as well as PDA and technical assistance. This section introduces the different types 
of implementing activities. 

3.1.1.  Calls for ‘regular’ grants 

Five calls for ‘regular’ grants were launched between 2020 and Q1 2025. These calls aimed to:  

–  support projects  demonstrating innovative technologies, processes, business  models or 
products  and  services,  that  are  sufficiently  mature  and  have  a  significant  potential  to 
reduce greenhouse gas emissions; and  

–  offer financial support tailored to market needs and risk profiles of eligible projects, while 

attracting additional public and private resources. 

3.1.1.1.  Evaluation phase 

Proposals  are  evaluated  based  on  a  set  of  award  criteria  (24),  set  out  in  each  call  document 
published on the EU Funding and Tenders Portal and following a standard staggered approach 
(submission  followed  by  evaluation).  An  evaluation  committee,  composed  of  independent 
experts  and  coordinated  by  CINEA,  assess  all  applications.  Proposals  are  first  checked  for 
admissibility  and  eligibility  requirements.  Proposals  found  admissible  and  eligible  are  then 
evaluated  against  the  award  criteria  and  ranked  by  score.  Proposals  that  pass  the  individual 
thresholds are considered for funding within the available budget (i.e. up to the budget ceiling). 
Other proposals are rejected or, if applicable, passed on to the national funding scheme (see 
‘as-a-Service’ section below). As of 2023, all proposals passing the individual thresholds are 
awarded the Strategic Technologies for Europe Platform (STEP) Seal, a quality label meant to 
help  projects  obtain  additional  or  alternative  funding,  from  private  and  public  investors  and 
including from EU funding schemes implemented at national level. 

The ‘degree of innovation’ criterion assesses how much a project advances beyond the current 
state of the art in its field, ranging from incremental improvements to breakthrough innovations. 
Projects  are  evaluated  based  on  their  novelty  compared  to  existing  solutions  at  the  EU  (or 
national) level. If a proposal is similar to previously funded projects, applicants must justify the 
new  innovative  elements,  such  as  scale,  application,  or  technical  differences.  Failure  to 
demonstrate sufficient innovation may result in a lower score. 

(24)  European  Commission, 

Innovation  Fund  2025  –  Call  Fiche 
https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/innovfund/wp-call/2025/call-
fiche_innovfund-2025-nzt_en.pdf. 

(Net-Zero  Technologies),  2025, 

17 

 
 
 
‘Project  maturity’  is  divided  into  three  sub-criteria:  technical,  financial  and  operational. 
Technical  maturity  evaluates  the  feasibility  of  achieving  the  project’s  expected  outputs,  the 
understanding of technical risks, and the proposed risk mitigation measures. Financial maturity 
assesses  the  project’s  ability  to  reach  financial  close  within  48  months  of  signing  the  grant 
agreement,  taking into account  the credibility  of the business  model,  the financial plan, and 
expected  profitability.  Operational  maturity  assesses 
the  project 
implementation  plan,  the  project  team's  relevance  and  track  record,  and  the  state  of  play 
regarding permits, licenses, and regulatory procedures. 

the  credibility  of 

The ‘cost efficiency’ criterion evaluates a project's cost efficiency by calculating the ratio of 
the requested grant to the absolute GHG emission reduction. The score is calculated using a 
formula that reduces points proportionally as the ratio increases. Additionally, the quality of the 
cost  calculation  ensures  that  the  cost  estimates  are  credible  and  meet  the  minimum 
requirements. Errors in cost calculations or incomplete submissions can lead to rejection. For 
most topics, projects with a cost-efficiency ratio exceeding 200 EUR/tCO₂e are rejected. This 
criterion has been adjusted in the past, such as for the ‘pilot’ topic during the IF24 Call, when 
the threshold was 2 000 EUR/tCO₂e. 

The  criterion  for  GHG  emission  avoidance  is  assessed  with  three  sub-criteria.  ‘Absolute 
avoidance’ measures the total GHG reductions over ten years compared to a reference scenario. 
‘Relative  avoidance’  assesses  the  efficiency  of  emission  reductions  relative  to  the  reference 
scenario. Finally, the ‘quality of calculation’ ensures methodological rigour, compliance with 
requirements  to  reduce  emissions  below  the  EU  ETS  benchmarks  and  sustainability 
requirements. 

The ‘replicability’ criterion evaluates a project’s potential for broader deployment and systemic 
impact.  It  includes  ‘replicability  in  terms  of  efficiency  gains  and  multiple  environmental 
impacts’,  which  assesses  resource  efficiency,  circularity,  and  environmental  benefits. 
‘Replicability in terms of further deployment’ examines plans for transferring the project or 
technology  to  other  sites.  Finally,  ‘contribution  to  Europe’s  industrial  leadership  and 
competitiveness’ considers the project’s role in developing new industrial ecosystems, supply-
chain resilience, and reducing dependencies on third-country inputs. For the maritime sector, 
emphasis is placed on enhancing European competitiveness and resilience. 

Maximum  score  and  bonus  points  per  criterion  and  per  topic  are  specified  in  each  call’s 
document published on the EU Funding and Tenders Portal. 

3.1.1.2.  Grant agreements and financing rates 

If a project passes evaluation and is ranked within the budget limit, it is invited to prepare a 
grant agreement with CINEA. This agreement sets the framework for the grant, including its 
terms and conditions, in particular regarding deliverables, reporting and payments.  

The  Fund  pays  up  to  60  %  of  the  relevant  costs,  calculated  according  to  the  methodology 
indicated in each call (usually covering capital and operational costs minus revenues over the 
first ten years of operation). The grants are disbursed as lump sums based on project financing 
needs, with disbursements tied to milestones achieved. For calls for ‘regular’ grants, up to 40 
%  of  the  grant can  be  disbursed  before  the  entire  project  is  fully  up  and  running,  based 
on predefined milestones. The key milestones are the signature of the grant agreement, financial 
close and entry into operation. 

18 

 
 
Figure 2: Key financing milestones for calls for ‘regular’ grants 

3.1.2.  Competitive bidding 

Since  2023,  competitive  bidding  through  auctions  has  been  introduced  as  a  complementary 
financing mechanism on the basis of Chapter IIb of the Innovation Fund Regulation. Funds are 
disbursed only at entry into operation, in the form of unit contributions.  

Participation in auctions has been strong, though subscription rates are moderating as the Fund 
matures: 

–  The IF23 Auction was launched in 2023 to support the production of RFNBO (Renewable 
Fuels of Non-Biological Origin) hydrogen (25). It attracted 132 bids from 17 countries. 
Six  projects  were  awarded  and  are  expected  to  produce  up  to  1.52  million  tonnes  of 
renewable hydrogen and avoid  over 10  million  tonnes of CO2 equivalent (mtCO2e)  in 
their first ten years of operation.  

–  The  IF24  Auction  continued  the  approach,  including  a  maritime  topic.  61  bids  were 
submitted  from  11  countries.  Within  this  auction,  12  proposals  were  initially  selected 
under the general topic and 3 under the maritime topic. 

3.1.2.1.  Evaluation phase 

Unlike calls for ‘regular’ grants, auctions award grants through a competitive bidding procedure 
on price. The bid price is the requested unit contribution (fixed premium) per kg of RFNBO 
hydrogen production payable for up to ten years. The bid price per unit is expected to cover the 
premium required by the producer, i.e. the difference between the expected revenue from the 

(25)  Renewable Fuels of Non-Biological Origin are liquid and gaseous renewable fuels (such as renewable 
hydrogen) produced from renewable energy sources, as defined in Article 2(36) of Directive (EU) 
2018/2001 (Renewable Energy Directive II). 

19 

 
 
 
 
 
sale  of  one  unit  and  the  unit’s  levelised (26)  cost  (i.e.  elements  such  as  production,  sale, 
transport, and storage can be priced into the bid).  

The  proposals  in  auctions  follow  the  standard  submission  and  evaluation  procedure  with 
evaluation by an independent committee. Such proposals are first checked for admissibility and 
eligibility requirements. If they pass this initial check, they are ranked from lowest to highest 
bid price in EUR per kg of produced hydrogen in a bid-curve (Figure 3). Proposals that fall 
within the auction’s budget are funded if they pass the award criteria of ‘relevance’ and ‘quality’ 
(on a pass/fail basis). 

Figure 3: IF24 Auction bid curve 

3.1.2.2.  Grant agreements and financing rates 

If  the  project  passes  evaluation,  it  is  invited  to  prepare  a  grant  agreement  with  CINEA. 
Payments are scheduled only during the project's operational (reporting) period. Up to 100 % of 
the relevant costs is covered, calculated according to the methodology indicated in each call for 
proposals (usually covering capital and operational costs minus revenues over the first ten years 
of operation). 

Unlike calls for ‘regular’ grants, auctions offer an additional completion guarantee: financial 
close must be reached within 2.5 years of the grant’s signature. If the milestone is not achieved 
in  time,  the  grant  agreement  may  be  terminated.  Additionally,  entry  into  operation  must  be 
reached within 5 years of the grant’s signature, at which point the project must demonstrate a 
nameplate capacity equal to the capacity expressed in its original bid.  

3.1.3. 

‘As-a-service’ schemes 

To avoid fragmentation at the early stage of the European hydrogen market’s formation and to 
save administrative costs associated with developing different hydrogen support schemes by 
the EEA, the Commission created the Auction-as-a-Service (AaaS) scheme in 2023 for the first 

(26)  Levelized cost means the average cost of producing per unit over the lifetime of a project, accounting for all 

capital, operating, and maintenance expenses. 

20 

 
 
 
 
 
hydrogen auction. As of 2024, this option is also offered for calls for ‘regular’ grants as ‘Grants-
as-a-Service’ (GaaS). 

EEA countries can use AaaS (27) and GaaS (28) to support ‘additional’ projects (in addition to 
projects  awarded  by  the  Fund)  through,  respectively,  auctions  or  calls  for  ‘regular’  grants. 
Projects  that  pass  all  evaluation  thresholds  but  cannot  be  funded  (because  they  exceed  the 
budget’s ceiling) may benefit from national funding if the project is located in an EEA country 
participating in AaaS or GaaS. EEA countries willing to participate must use resources from 
their national budgets, the Modernisation Fund or the Recovery and Resilience Facility. To be 
eligible, proposals must express their interest during the application stage. 

Figure 4: The Auction-as-a-Service scheme 

‘As-a-service’  schemes  eliminate  the  need  for  separate  national  calls  (and  thus  avoid 
duplication  of  effort),  reduce  the  administrative  burden  on  national  administrations  and 
applicants,  build  on  the  cost-discovery  and  efficiency  of  EU-level  competition,  and  offer  a 
streamlined process for State aid notification when they are closely aligned to the applicable 
State aid rules. 

AaaS  was  available  during  the  IF23  and  IF24  Auctions,  with  participation  from  Germany, 
Austria, Spain and Lithuania. Announced budgets in the latest auction ranged from EUR 36 
million in Lithuania to EUR 400 million in Austria or Spain. 

(27) European Commission, ‘Auctions-as-a-Service for countries in European Economic Area (EEA): Concept 
Note’, Version 0.5, 2 December 2024. 

(28)  European Commission, ‘Grants-as-a-Service (Gaas) possibility under the Innovation Fund (IF) ‘regular’ 

grants calls: Concept Note’, Version 0.1, 27 October 2025. 

21 

 
 
 
 
 
GaaS  was  introduced  in  2024  and,  in  2025,  was  extended  and  simplified  under  the  Clean 
Industrial Deal State Aid Framework (CISAF) (29) to make it more attractive. Despite this, GaaS 
has not yet been used by national autorities. 

These schemes matter because they help mobilise additional resources, thus increasing funding 
opportunities for innovative projects across Europe. They also reduce the administrative burden 
for national authorities and applicants by creating a single application and evaluation process. 
They  also  help  achieve  more  cost-efficient  allocation  of  funding  by  creating  EU-level 
competition. 

3.1.4.  Blending operations 

Blending  operations  combine  Fund  resources  with  other  EU  financial  tools  to  support  the 
deployment of clean technologies at various stages of development. So far, they have included 
two initiatives, both with guaranteed top-ups on InvestEU: the EU-Catalyst partnership and an 
initiative for the batteries value chain.  

The EU-Catalyst partnership is a joint initiative launched in 2023 by the Commission, the EIB, 
and Breakthrough Energy (30). Breakthrough Energy provides equity and grants, while the EIB 
offers  quasi-equity  and  venture  debt.  The  Commission  contributes  through  a  Fund’s  top-up 
guarantee  under  InvestEU  and  through  grants  from  Horizon  Europe.  By  late  2023,  the 
partnership had announced its first projects. 

The  InvestEU  top-up  for  batteries,  which  started  in  December  2024,  targets  the  EU  battery 
value  chain,  including  the  development,  recycling,  and  manufacturing  of  components.  It 
provides a Fund top-up guarantee to InvestEU, helping the EIB to provide venture debt to bridge 
the gap between R&D (31) and commercialisation. By the end of Q1 2025, no operations had 
been announced under this initiative. 

3.1.5.  Other activities 

3.1.5.1.  Technical assistance and support to applicants 

Technical assistance was introduced by the 2023 revision of the EU ETS Directive. It aims to 
build national capacity to support applicants and improve geographical coverage. Two forms 
of technical assistance exist. 

First,  all  Nantional  Contact  Points  (NCPs)  receive  dedicated  support,  including  training, 
workshops,  and  coordination  activities.  A  contract  between  DG  CLIMA  and  an  external 
provider was launched in 2023. It aims to support NCPs in promoting the Fund at the national 
level, advising applicants and facilitating cross-border cooperation.  

(29)  European Communication, Communication from the Commission – Framework for State Aid measures to 

support the Clean Industrial Deal (Clean Industrial Deal State Aid Framework) (C/2025/3602). 

(30)  Global network founded by Bill Gates and other investors to accelerate innovation in sustainable energy and 
support the commercialisation of technologies needed for net-zero emissions. More information on the 
partnership can be found on the Commission’s website. The partnership ended on request by Breakthrough 
Energy Catalyst at the end of 2025. 

(31)  Research and development. 

22 

 
 
 
Second,  technical  assistance  is  available  on  request  for  EEA  countries  with  low  effective 
participation in the Fund (as defined in Delegated Regulation (EU) 2019/856). The Commission 
defined a list of eligible EEA countries based on the lowest Fund support relative to their share 
of EU ETS verified emissions (2013–2020). As of 15 September 2023, the 20 EEA countries 
eligible  were  Austria,  Croatia,  Cyprus,  Czechia,  Denmark,  Estonia,  Germany,  Greece, 
Hungary,  Ireland,  Latvia,  Liechtenstein,  Lithuania,  Luxembourg,  Malta,  Norway,  Portugal, 
Romania, Slovakia, and Slovenia. Financing Decision C(2023)7827 allocated EUR 4 million 
to provide targeted capacity-building, proposal preparation, and regulatory guidance in these 
countries. 

NCPs  provide  support  to  applicants  through  awareness-raising  measures  such  as  national 
information days. Fifteen events were held between November 2023 and February 2024 (32), 
thirteen of which included orientation dialogues, allowing applicants to meet directly with DG 
CLIMA and CINEA. 

DG  CLIMA  and  CINEA  further  support  applicants  with  methodological  guidance  on  cost 
calculations  and  GHG  emissions  avoidance,  online  manual  and  FAQs,  webinars  (33)  and 
updates via the Clean Energy Newsletter. Call-specific Q&As and a dedicated helpdesk also 
reinforce support for applicants. For the 2022 calls, more than 1 000 queries were managed, 
mainly on GHG methodologies, relevant costs, and eligibility (34). The IF23 Call generated a 
similar volume of questions, with peaks in the final weeks leading up to closure. 

3.1.5.2.  Project development assistance (PDA) 

PDA resources increased significantly between 2020 and 2023. In the first Financing Decision, 
EUR 25 million was allocated to PDA for the following three years. Following lessons learned, 
PDA was simplified in the 2023 amendment to Delegated Regulation (EU) 2019/856, allowing 
projects to apply directly with the EIB for support. The 2023 Financing Decision supported this 
by allocating EUR 90 million to PDA over the next three years, underscoring its growing role 
in the Fund’s portfolio. As of 2025, PDA is being implemented with new eligibility conditions, 
as per the 2023 revision of Delegated Regulation (EU) 2019/856, aiming to ensure a wider pool 
of projects is available to the EIB. 

PDA has followed the same geographical spread as applications received. Most projects were 
concentrated  in  larger  industrialised  economies  such  as  Germany,  France,  Spain,  and  Italy, 
reflecting  their  sizeable  industrial  bases  and  larger  pipelines  of  potential  projects.  Smaller 
countries,  such  as  Bulgaria,  Croatia,  and  Latvia,  had  fewer  supported  projects,  although 
participation was recorded in almost all EEA countries. 

Energy-intensive  industries  make  up  the  largest  share  of  proposals  receiving  PDA, 
complemented by renewables, hydrogen, and industrial carbon management. PDA beneficiaries 
also include proposals in steel, cement, and chemical, followed by renewables (wind and solar), 
hydrogen  (production  and  storage)  and  CCS/CCU.  Low-carbon  transport  and  enabling 
technologies are also present, though in smaller numbers. 

(32)  European Commission website, accessed in October 2025. 

(33)  Such as how-to and orientation sessions as seen for instance on the European Commission website, accessed 

in October 2025. 

(34)  European Commission, Innovation Fund progress report – Report from the Commission to the European 

Parliament and the Council, August (2022,), Publications Office of the European Union, 2022. 

23 

 
 
 
PDA beneficiaries include both large industrial companies and smaller firms. Large enterprises 
represent around half of all selected proposals, while SMEs (35) account for about one-third. 
Mid-sized companies form a smaller but notable share. 

PDA also covers a wide range of advisory services tailored to project needs. The most frequent 
services include financial structuring and viability assessments, technical feasibility studies and 
market context analyses. Other services cover permitting and regulatory compliance, contract 
revisions, procurement and tendering strategies, and capacity-building for project management. 
In some cases, projects also received guidance on securing additional financing and addressing 
State aid compliance. 

As  of  2025,  PDA  is  being  implemented  with  new  eligibility  conditions,  as  per  the  2023 
amendment of Delegated Regulation (EU) 2019/856, aiming to ensure a wider pool of projects 
is available to the EIB. 

3.1.5.3.  Communication and knowledge sharing activities 

DG CLIMA and CINEA circulate press releases, articles, and monthly project stories. On social 
media, they promote information for upcoming events or project inauguration ceremonies, in 
addition to the previously listed materials. Between 2020 and 2023, 41 press releases and 144 
news articles (83 on DG CLIMA’s website, 61 on CINEA’s) were published. 

On  their  end,  beneficiaries  must  publicly  acknowledge  the  Fund’s  support  and  disseminate 
information about their projects. 

Knowledge sharing is mandated under the EU ETS Directive and Delegated Regulation (EU) 
2019/856.  Beneficiaries  must  submit  knowledge  sharing  plans  covering  the  full  project 
lifecycle, including management, financing, permitting, construction and performance. Closed-
door workshops allow beneficiaries to discuss project-specific issues such as financial close, 
permitting,  and  market  conditions.  At  the  same  time,  open-door  events  engage  broader 
stakeholder groups and promote synergies with other EU-funded projects (36). 

Between  2020  and  2023,  the  Fund  organised  more  than  ten  knowledge  sharing  events,  two 
Cleantech  Conferences  and  thematic  workshops.  In  2023,  thematic  events  focused  on  CO2 
transport  and  storage,  hydrogen,  energy  storage,  and  CCS,  while  earlier  sessions  addressed 
financing and permitting challenges (37). 

Participation levels in these activities vary by format and year. The IF23 Call info day recorded 
over 5 300 unique views, while the 2023 Cleantech Conference had more than 1 000 registered 
participants across in-person and online attendance. Other info days and workshops between 

(35)  Small and medium-sized enterprises. 

(36)  European Commission: European Climate, Infrastructure and Environment Executive Agency, Annual 
knowledge sharing report of the Innovation Fund – De-risking innovative low-carbon technologies, 
Publications Office of the European Union, 2024; Report from the Commission to the European Parliament 
and the Council on the implementation of the Innovation Fund, including the review referred to in Article 24 
of Regulation (EU) No 10311/2010. 

(37)  European Commission, Innovation Fund progress report – Report from the Commission to the European 

Parliament and the Council, (2022), Publications Office of the European Union 

24 

 
 
 
2021 and 2024 typically involved several hundred to thousands of participants, reflecting the 
scale of outreach across countries and stakeholder groups. 

3.2.  Portfolio outcomes 

The Fund has built a sizeable project portfolio in its first four years. By the end of March 2025, 
208 projects had been awarded grants (38): 202 through calls for ‘regular’ grants and 6 through 
auctions, totalling EUR 11.6 billion in committed support. Of these, 192 projects are ongoing, 
and 16 have been terminated (39). The portfolio spans a wide range of sectors, geographies and 
sizes, reflecting the increasing scope of successive calls and the introduction of new funding 
windows. However, most supported projects remain at an early stage of implementation and 
reported figures are prospective. 

The number of proposals received during calls has increased continuously since 2020 (Figure 
5). Moreover, the quality of proposals has also improved, as evidenced by the increasing share 
of proposals that pass all evaluation criteria (Figure 6). 

Figure 5: Evolution of number of proposals received through the evaluation stages per call 

(38)  ‘Awarded grants’ refers to the ‘awarded proposals’ (pre-selected proposals) who eventually signed a grant. 

(39)  16 projects during the evaluation period (up to end of March 2025). Additional projects were terminated later 
in 2025. ‘Terminated projects’ refers to projects which were terminated after they signed a grant agreement. 
Some pre-selected proposals may withdraw during grant agreement preparation. These are not included in 
terminated projects. 

25 

 
 
 
 
 
53%

55%

Figure 6: Share of proposals received passing all award criteria 

60%

55%

50%

45%

40%

35%

30%

25%

20%

42%

40%

35%

32%

22%

SSC-2020

SSC-2021

LSC-2021

SSC-2022

LSC-2022

NZT23

NZT24

Demand for support consistently exceeded available resources, with applicants requesting more 
than 7 times the available budgets, although the intensity of oversubscription has evolved (Table 
2). However, within each call, oversubscription in some topics (e.g. large-scale projects) has 
been offset by undersubscription in others (e.g. small-scale projects), enabling reallocation. 

Demand for support also became more differentiated as the Fund’s structure expanded. In 2023, 
topic-level variation in oversubscription rate widened: 

–  General large-scale projects experienced intense competition (with an oversubscription 
rate of 10.2), while manufacturing and medium-scale competitions were more moderate 
(respectively 2.4 and 2). General small-scale projects received fewer requests than their 
planned budget (0.5). 

–  Pilots, despite their novelty, displayed a moderate oversubscription rate (4). 

Table 2: Oversubscription rate per call (budget requested by evaluated proposals over budget 
available 

Year/Call 

Oversubscription rate 

SSC-2020 

LSC-2020 

2020 total 

SSC-2021 

LSC-2021 

2021 total 

SSC-2022 

LSC-2022 

7.4 

20.4 

19.2 

2 

7.7 

7.3 

1.8 

5.5 

26 

 
 
 
 
Year/Call 

Oversubscription rate 

2022 total 

IF23 auction 

IF23 general large-scale 

IF23 general medium-scale 

IF23 general small-scale 

IF23 manufacturing 

IF23 pilots 

2023 total 

5.4 

13.2 

10.2 

2 

0.5 

2.4 

4 

6.9 

In volume terms, the number of applications has followed a similar pattern, with high initial 
participation gradually giving way to more focused competition. The first large-scale call in 
2020 received 332 proposals (for the first stage) but funded only 7 (through the second stage), 
a 2 % success rate. Application numbers declined in later years, which can be explained by the 
novelty of the call, as applicants could not estimate their chances of success, and by the more 
limited effort required for the first application stage. This, on the other hand, resulted in a longer 
evaluation process and a longer time-to-grant.  

Nevertheless, success rates remained highly uneven across topics, ranging from just 8 % for 
general large-scale projects to 34 % for manufacturing in 2023. Several factors can explain this 
difference, including the novelty of some topics (and fewer potential applicants), the broader 
sectoral and technological eligibility of the general topics, and the size of the grants requested 
relative to the topic budget, which can result in fewer (but larger) projects being selected. 

3.2.1.  Geographical and sectoral distribution 

The Fund’s portfolio is dominated by energy-intensive industries, which account for more than 
half of all projects, reflecting the scope of the EU ETS and the required decarbonisation efforts. 
Alongside these, a significant share of projects targets renewables and energy storage, while 
industrial carbon management and mobility represent smaller components of the portfolio. 

Within energy-intensive industries, projects span a wide range of sectors, though hydrogen and 
chemicals  stand  out  as  the  largest  groups.  Cement,  refineries,  and  iron  &  steel  also  well 
represented, while other sectors (such as paper, glass, ceramics, aluminium and fertilisers) are 
represented to a lesser extent. 

The primary contributions to the decarbonisation of the mobility sector are for the production 
of  sustainable  fuels  and  vehicle  batteries.  When  these  investments  are  considered  from  the 
‘energy  intensive  industries’  sector,  then  ‘mobility’  accounts  for  more  than  one-third  of  the 
Fund portfolio (40). 

(40) European Climate, Infrastructure and Environment Executive Agency (CINEA), Mobility Factsheet, (2023). 

27 

 
 
 
 
Figure 7: Portfolio geographical distribution (number of projects and awarded funding) 

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Awarded EU funding (million EUR)

Number of projects

National portfolios show distinct sectoral profiles. Energy-intensive industry projects dominate 
Spain  and  Italy,  while  Sweden  and  France  have  more  balanced  portfolios  that  include 
renewables.  Central  and  eastern  European  projects  are  concentrated  in  industrial  and 
manufacturing initiatives. 

Projects are concentrated in larger industrial economies (Figure 7). Among the 208 awarded 
projects, Spain (29 projects), France (24), Italy (21) and Germany (20) account for the largest 
shares of supported projects, followed by Sweden (16), Belgium (13) and the Netherlands (12). 
Central  and  eastern  European  countries  such  as  Poland  (7)  and  Czechia  (3)  have  lower  but 
noticeable participation rates. In contrast, smaller countries, including Cyprus and the Baltic 
States,  are  represented  by  one  or  two  projects  each.  Funding  is  also  concentrated,  but  the 
differences are less pronounced than in the number of projects. Germany leads in total support 
(EUR 1.67 billion), followed by Spain and Belgium (EUR 1.28 billion each), Sweden (EUR 
1.19 billion) and Norway (EUR 1.12 billion).  

Beyond the project’s implementation  location, an analysis of the geography of beneficiaries 
(coordinators and participants) provides another perspective on the portfolio’s distribution. The 
Fund’s public dashboard identifies 480 participating entities across awarded projects, with the 
majority based in Spain (78), France (65), Germany (48), Italy (33), the Netherlands (32), and 
Norway (35). 

28 

 
 
 
 
Hence, although project sites are concentrated in a few countries, participation extends across 
a wider range of countries through multinational consortia. Several smaller countries (such as 
Iceland, Finland, Denmark, Ireland, and the Baltic States) appear more prominently, reflecting 
their involvement as partners rather than project hosts. 

Large-scale projects dominate the portfolio in terms of financial value. They account for around 
EUR 9.7 billion, the overwhelming share of Fund resources. By contrast, medium-scale projects 
received  EUR  1.2  billion  and  small-scale  projects  about  EUR  0.25  billion.  In  terms  of  the 
number of projects, all sizes are represented. Although the number of projects is similar between 
small- and large-scale projects, the amount of funding differs, due to the size of the projects and 
the relevant costs funded. 

Moreover, the weighting between large- and small-scale projects has shifted over time. Small-
scale projects were prominent in the early calls. However, their relative share has declined as 
the Fund increasingly channelled resources to larger, more mature initiatives, particularly after 
the introduction of new  topics in  2023 and a decline in  interest  in  the small-scale topic. As 
medium-scale,  manufacturing  and  pilot  topics  were  introduced  later  in  the  Fund’s  lifetime, 
these are de facto less represented in the portfolio at the end of Q1 2025. 

The distribution across sectoral categories shows distinct patterns. Energy-intensive industries 
dominate across all project sizes. Renewable energy projects are increasingly common in the 
small- and medium-scale segments, where technology innovation and demonstration are more 
prevalent. Projects in industrial carbon management, by contrast, are concentrated in the large- 
scale segment, reflecting their considerable costs, long development cycles, and infrastructure 
requirements. 

3.2.2.  Project implementation and disbursement 

Most projects are still at an early stage. By Q1 2025, 153 projects were before financial close, 
26 were between financial close and entry into operation, and 13 had  entered into operation. 
Among these 13 projects, 7 were in their first year, 4 in their second, and 2 in their third year 
of operations. 

Overall, large-scale projects take longer than small-scale projects, having higher funding needs 
and averaging 2.1 years to reach financial close and more than 4.6 years to enter into operation. 
Medium-scale projects are the fastest to reach financial close (just over 1 year) and entry into 
operation in about 3 years. Small-scale projects are close behind, taking around 1.4 years to 
reach financial close and 2.8 years to operation (Figure 9). 

Progression to financial close also differs across categories. Energy storage has advanced the 
most (more than 30 % of projects reaching that stage), followed by renewable energy (more 
than 25 %) and energy-intensive industries (close to 20 %). By contrast, none of the CCS or 
mobility projects had reached financial close at the time of reporting. 

Progression to milestones also varies by technology. Projects in industrial carbon management 
have the longest planned average time to financial close (just over 2 years) and to entry into 
operation (over 5 years). Energy-intensive industries average around 1.7 years to financial close 
and 3.7 years to operation. Renewable energy projects are faster on both counts. Mobility and 
energy  storage  projects  are  similar  to  renewables  in  reaching  financial  close,  but  they  take 
slightly longer to become operational. However, these averages are based on a small number of 

29 

 
 
projects that have reached financial close and may evolve as more projects advance through 
implementation. 

Figure 9: Average time to reach milestones 

Because the Fund is in its early years, most projects are yet to reach financial close. However, 
based on the status of ongoing projects and their planned milestones, the number of projects 
reaching financial close is projected to increase gradually, peaking in 2028. 

The status of funds disbursed to projects further underscores the Fund’s early implementation. 
As of Q1 2025, EUR 321.3 million of cumulative payments had been disbursed. Based on the 
most recent grant agreements, disbursements are planned to increase in 2026, 2027 and 2028, 
as more projects reach financial close (Figure 10). 

30 

 
 
 
 
Figure 10: Disbursement schedule, current and projected as of the end of Q1 2025 

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Latest Legal Data

4.  EVALUATION FINDINGS 

4.1.  To what extent was the Fund successful and why? 

4.1.1.  Effectiveness 

The evaluation of effectiveness relied on a combination of quantitative and qualitative evidence. 
Quantitative data included project metrics such as the number and quality of funded projects 
(based  on  GHG  reduction  potential,  Technology  Readiness  Level  (TRL)  progression,  and 
sectoral distribution), funding mobilised (public and private), and operational timelines (e.g. 
time to reach milestones). Financial indicators, like oversubscription rates, risk diversification, 
and revenue allocation efficiency, provided insights into the Fund’s operational performance 
and alignment with EU ETS objectives. 

Qualitative  evidence  was  derived  from  surveys,  interviews,  stakeholder  consultations  and 
annual knowledge sharing reports offering critical perspectives on challenges and successes. 
Beneficiaries,  unsuccessful  applicants,  NCPs,  and  public  authorities  shared  feedback  on 
administrative barriers, co-financing gaps, and geographical disparities. At the same time, case 
studies  and  expert  interviews  (e.g.  with  DG  CLIMA  and  evaluators)  examined  the  Fund’s 
strategic coherence and support mechanisms (e.g. PDA, auctions, blending operations). For a 
full overview of the evidence used to analyse the Fund’s effectiveness, please see Annex III. 

The Fund has been effective in selecting and financing innovative decarbonisation projects, 
both  ‘first-of-a-kind’  and  more  mature  ‘scale-up’  types,  with  high  potential  to  reduce  GHG 
emissions,  establishing  itself  as  a  cornerstone  of  EU  climate  finance.  The  Fund’s  design, 
notably  its  award  criteria  for  ‘regular’  grants  (innovation,  maturity,  replicability,  and  cost 
efficiency), has consistently recognised the strongest proposals. Scoring analysis confirms that 
awarded  proposals  consistently  outperformed  non-selected  ones  across  all  criteria.  During 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
interviews, evaluators also noted that the rigorous evaluation process identified proposals with 
strong potential for innovation and GHG emissions reduction. 

The Fund not only selects but also incentivises high-quality proposals. This indirect positive 
effect was not originally foreseen in the evaluation’s intervention logic. As became clear from 
the  survey  of  unsuccessful  applicants,  after  rejection,  applicants  often  revised  timelines, 
improved  business  and  financial  plans,  or  strengthened  their  teams  before  reapplying  and 
successfully securing funding.  

By  Q1  2025,  the  Fund’s  portfolio  comprised  208  signed  projects  expected  to  avoid  871 
mtCO2e  over  their  first  decade  of  operation.  Distributed  evenly  over  ten  years,  the  Fund’s 
portfolio is expected to avoid 87 mtCO2e annually. These emissions correspond to more than 7 
% of 2024 EU ETS-verified emissions (1 033 mtCO2e), with an additional 89 mtCO2e from 
maritime and 62 mtCO2e from aviation (41). This comparison highlights the scale of the Fund’s 
potential  impact,  even  without  accounting  for  replication  effects.  Respondents  to  the 
beneficiaries’ survey reported that their projects are expected to trigger innovations and open 
new  markets,  with  wider  sectoral  diffusion  extending  the  potential  for  emissions  reduction 
beyond the projects themselves. Interviews with DG CLIMA and CINEA, as well as evaluators 
and representatives of national authorities, confirmed these views, suggesting that the Fund’s 
impact extends beyond its supported portfolio. 

Oversubscription to calls for ‘regular’ grants has been recurring, attesting to the Fund’s 
success (Table 2). Applicants requested more than seven times the available budget between 
2020 and 2023, confirming  the Fund’s relevance. The gradual  reduction in  oversubscription 
rates (from 21.3 in 2020 to 5.6 in 2023) suggests improved targeting and alignment between 
supply  and  demand.  However,  the  sustained  imbalance  between  requested  and  available 
budgets  also  shows  that  many  high-quality,  above-threshold  proposals  remain  unfunded, 
particularly in energy storage, chemicals, and renewables. 

Meanwhile, auctions have received a strong market response. The IF23 Auction attracted 
132 bids  from  17 countries, with  its budget  being 19 times oversubscribed and yielding  bid 
prices well below the EUR 4.5/kg ceiling (EUR 0.20–0.60/kg). Auctions complement ‘regular’ 
calls by focusing on price competition for more mature decarbonisation technologies and, as an 
added  benefit,  enabling  market  price  discovery.  Auctions  also  offer  simplified  procedures, 
which  are  thus  faster,  as  confirmed  by  beneficiaries  who  found  them  simpler  and  more 
transparent than multi-award criteria calls. However, it is difficult to draw conclusions about 
the  broad  effectiveness  of  auctions  in  general  as  they  have  so  far  only  been  applied  to  the 
hydrogen sector, which is very capital-intensive and has faced several challenges (42). As for 
other sectors, the expansion in the share of energy from renewable energy sources has been 
significantly facilitated by auctions organised by Member States (43). 

(41)  EU 

ETS  Data  Viewer, 

European 

Environment  Agency, 

accessed 

February 

2026, 

https://www.eea.europa.eu/en/analysis/maps-and-charts/emissions-trading-viewer-1-dashboards. 

(42)  European Court of Auditors, Special Report 11/2024: The EU’s Industrial Policy on Renewable Hydrogen, 

June 2026, https://www.eca.europa.eu/en/publications?ref=sr-2024-11. 

(43)  European  Commission,  Recommendation  and  Guidance  on  Auction  Design  for  Renewable  Energy, 
Directorate-General  for  Energy,  June  2026,  https://energy.ec.europa.eu/publications/recommendation-and-
guidance-auction-design-renewable-energy_en. 

32 

 
 
 
The Fund has also been successful in mobilising substantial additional finance, particularly 
private  investment,  and  national  co-funding,  while  also  generating  synergies  with  other  EU 
programmes: 

–  The  Fund  has  leveraged  around  EUR  45.2  billion  in  total  investments  against  EUR 
11.08 billion in grants (a leverage ratio of about 1:4), with private financing accounting 
for  most  of  the  additional  resources  mobilised.  The  total  capital  expenditure 
(expected/planned) communicated by applicants in their applications serves as a proxy 
for  the  total  volume  of  investments  mobilised  by  Fund  grants.  Once  projects  reach 
financial  close,  more  accurate  data  on  the  investments  mobilised  is  available  for 
reporting. The data on mobilised investments is based on capital expenditure recorded 
at financial close. 

–  National co-funding has played a sizeable, though uneven, role across countries. 

–  Synergies  with  other  EU  funding  instruments  exist,  with  a  few  projects  reporting 
concurrent EU funding, partly due to the Financial Regulation’s strict rules prohibiting 
double funding (44). 

Nonetheless,  evidence  points  to  synergies  with  other  EU  programmes  beyond  additional 
financing. Among 38 projects previously funded by FP7, Horizon 2020 or Horizon Europe that 
applied to the Fund’s calls for proposals, 13 projects were eventually successful. Although the 
sample is yet limited, findings are promising: 

–  The success rate (45) of projects previously funded under these programmes is 32.5 %, 
well  above  the  overall  portfolio  success  rate  of  12  %.  These  13  projects  are  spread 
across several sectors: iron & steel (3 projects), followed by chemicals, wind energy, 
manufacturing  of  components,  and  other  (2  projects  each),  and  hydrogen  and  other 
energy storage (1 project each). 

–  During evaluation, most unsuccessful applicants failed to reach the minimum threshold 
under  financial  maturity  (14  projects),  followed  by  technical  maturity  (5  projects). 
Financial maturity is also the most common reason for failure for applicants overall. 

Stakeholders’ feedback (46) also points to complementarities with Horizon Europe. In the 
survey, beneficiaries and unsuccessful applicants named Horizon Europe as the most common 
complement. Indeed, several Fund projects build on earlier Horizon Europe or Horizon 2020 
results, illustrating strong sequential links along the innovation pipeline. Case study evidence 
also  confirms  that  Horizon  Europe  typically  supports  research  and  demonstration  at  lower 
TRLs,  while  the  Fund  finances  higher  TRLs,  large-scale  and  commercial  deployment. 
Stakeholders also indicated that prior support from Horizon Europe can strengthen applicants’ 
technical maturity and project design, thereby improving their success rate; however, this has 
not been systematically verified or supported by quantitative data. Although respondents to the 

(44)  The ‘no double-funding’ principle means that combined EU funding cannot exceed 100 % of the eligible 
costs, which is ensured by limiting the combined funding rates from the two programmes to 100 %. 
Additionally, the same costs cannot be funded twice by the EU budget. 

(45)  Success rate is defined as the number of funded projects divided by all proposals submitted during all calls 

for proposals until the IF23 Call. 

(46)  Surveys with beneficiaries (Q74, Q75), unsuccessful applicants (Q5), NCPs (Q63) and Horizon Europe 

beneficiaries (Q13). 

33 

 
 
 
public consultation called for more synergies between EU funding programmes, NCPs reported 
limited capacity to advise on combining instruments. 

Roll-out of technologies is progressing but remains at an early stage: 

–  The Fund primarily supports technologies at TRL 6, 7, or 8 (93 % of projects), with 
most projects targeting a final TRL of 9. The exceptions are hydrogen auction projects, 
which favour the further deployment of a proven commercial technology (already at 
TRL 9), and projects from the pilot topic, which usually start at TRL 6 and a minority 
at TRL 5 or 7. 

–  Rollout  has  already  begun,  with  new  solar  manufacturing  technologies,  solar-hybrid 
installations,  new  wind  turbine  generators,  low-carbon  glass  manufacturing,  and 
biomethane production techniques now in operation. Nevertheless, most projects are 
still before financial close or in construction, so rollout is still to come. 

The Fund’s portfolio is on track to achieve its objectives within the 15-year implementation 
horizon (47), and this horizon appears realistic. Quantitative evidence shows an average project 
duration of around 8.8 years, while case studies confirm that typical durations range from 7 to 
15 years. Recent calls show shorter timelines as project maturity improves. 

Nonetheless,  project  implementation  confirms  that,  even  with  rigorous  selection,  project 
delays, deviations (amendments) and terminations can occur. By the end of Q1 2025, 16 of 
208  supported  projects  (8  %)  were  terminated  prematurely.  Their  share  of  funding  was 
reallocated to projects from the reserve lists (if still open) or to future calls.  

Deviations from planned milestones are relatively common, particularly in early- and mid-stage 
development. About 40 % of projects report delays before financial close, and about 63 % of 
those that have already passed financial close experience delays before entry into operation. 
Deviations  occur  across  most  of  the  covered  sectors,  including  CCS,  hydrogen,  energy-
intensive industries, energy storage, and several manufacturing and renewable sectors.  

Reasons  for a project’s  withdrawal from  grant  agreement preparation vary (48). The primary 
cause is funding challenges driven by market pressure and changing market conditions. These 
include  sector  instability,  difficulties  in  raising  capital,  substantial  cost  increases,  and  the 
inability to secure off-take agreements, all of which often lead to an unviable business case. 
Other  reasons  included  a  lack  of  necessary  infrastructure,  significant  permitting  delays, 
withdrawal of a key partner in the consortium, supply chain disruptions and energy or feedstock 
availability constraints (49). 

Similarly,  once  the  grant  agreement  is  signed,  delays  in  meeting  milestones  and  early 
terminations cannot be linked to a single specific factor (such as insufficient project maturity). 
Rather,  as  with  withdrawals,  terminations  are  often  due  to  several  intertwined  external  and 

(47)  Fund projects must reach financial close within 4 years of grant agreement and typically face a mandatory 
operation/monitoring period of 3 to 10 years after entry into operation. This results in a potential timeline 
from grant agreement to completion of up to 14-15 years (4 years to financial close and up to 10 years of 
monitoring). 

(48)  Grant agreement preparations start 6 to 8 months after deadline for submission of applications. Economic and 

regulatory conditions may have changed for the project in this period. 

(49)  Interviews with DG CLIMA and CINEA. 

34 

 
 
 
market-related  challenges  that  fundamentally  alter  the  original  business  cases (50).  Key 
examples  include  the  disruptive  impacts  of  the  COVID-19  pandemic,  which  strained  global 
supply  chains,  and  the  economic  fallout  from  Russia’s  war    of  aggression  against  Ukraine, 
leading  to  unanticipated  inflation  and  cost  escalations  that  exceeded  planned  contingencies. 
Additionally, volatility in emerging green markets, such as green hydrogen, e-fuels, batteries, 
and solar photovoltaic, has been exacerbated by regulatory instability, competitive imports from 
third countries, shifting trade policies, and weaker-than-expected demand growth. While most 
projects had mitigation measures in place for foreseeable risks at the time of evaluation, many 
delays stem from unpredictable market headwinds or corporate strategic changes that were not 
identifiable during the application or grant agreement preparation phases.  

Furthermore, the 2025 annual knowledge sharing report identifies areas of challenges, common 
to all projects, as well as successful mitigation strategies, to a greater or lesser extent:  

–  Securing  off-take  agreements:  Projects  face  challenges  in  nascent  markets  due  to 
market uncertainty and the limited cost-competitiveness of innovative green products 
compared 
include  early 
establishment  of  off-take  agreements,  integration  of  key  partners  and  suppliers  into 
project consortia, diversification of off-take options, identification of backup off-takers, 
and continuous monitoring of international market trends. 

to  conventional  alternatives.  Successful  strategies 

–  Rising  costs:  Projects  face  significant  increases  in  material,  equipment,  and 
construction  costs,  alongside  more  stringent  technical  requirements.  Mitigation 
measures 
renegotiating 
agreements, and securing additional funding to maintain financial viability. 

financial  contingency  buffers, 

implementing 

include 

–  Supply chain constraints: Projects experience equipment shortages and cost increases, 
impacting timelines and budgets. Mitigation strategies include diversifying suppliers, 
renegotiating delivery schedules, exploring local sourcing options, and implementing 
strategic stock management. 

–  Permitting  and  regulatory  challenges:  Projects  are  hindered  by  complex,  lengthy 
permitting procedures that vary across countries and by regulatory uncertainty, leading 
to delays and increased costs. Mitigation efforts involve early stakeholder engagement, 
ongoing  dialogue  with  local,  regional,  and  national  authorities,  and  proactive 
environmental  impact  assessments.  In  interviews,  Fund  beneficiaires  suggest  further 
improvements  such  as  increased  capacity  of  permitting  authorities,  creation  of 
regulatory  sandboxes  for  innovative  solutions,  and  simplification  of  application 
processes. 

–  Dependence  on  external  infrastructure:  Projects  rely  on  the  timely  completion  of 
external infrastructure, such as grid connections, CO₂ transport and storage facilities, 
and  hydrogen/CO₂  pipelines,  which  are  beyond  their  direct  control.  Risk  mitigation 
includes  early  coordination  with  infrastructure  developers,  progress  monitoring,  and 
collaboration  with  local  authorities  to  design  and  develop  necessary  transportation 
infrastructure. 

These  challenges  are  often  intertwined,  and  the  reason  for  delays  or  terminations  cannot  be 
attributed  to  a  single  challenge.  Desk  research,  public  consultation,  survey  results  and 

(50)  Interviews with DG CLIMA and CINEA. 

35 

 
 
 
interviews  of  beneficiaries  confirm  that  financial  gaps  are  the  most  important  factor  behind 
delays. At the same time, administrative burden also contributes, but to a lesser degree.  

The Fund’s evaluation process is rigorous and methodically sound, ensuring only projects with 
demonstrated  maturity  are  selected.  While  early  calls  in  2020  may  have  reflected  overly 
optimistic  assumptions  due  to  market  conditions  at  the  time  and  the  Fund’s  novelty,  the 
methodology  has  since  been  refined  to  improve  and  strengthen  the  evaluation.  Evaluations 
cannot  anticipate  unforeseen  external  challenges  that  could  lead  to  project  delays  or 
terminations.  The  evidence  thus  suggests  that  the  Fund’s  selection  process  is  effective,  as 
milestone delays are rarely linked to aspects of the project detectable at the evaluation stage. 
However, the Fund’s continuous monitoring framework (combining milestone-based oversight 
with  continuous exchanges) enables early detection of issues and supports timely corrective 
action. As a result, most deviations are managed through amendments rather than leading to 
termination. 

Funded projects are expected to deliver substantial GHG emissions reductions, with a focus on 
hard-to-abate sectors. For the evaluation of the Fund’s effectiveness, only the expected GHG 
emission reductions of the 192 ongoing projects are considered: 

–  The largest  contributors  are the  cement & lime sector  (138 mtCO2e), hydrogen  and 
related manufacturing (169 mtCO2e), the iron & steel sector (82 mtCO2e) and chemicals 
(52 mtCO2e). 

–  Energy-intensive industries and industrial carbon management together account for the 
largest share of expected GHG emissions avoidance. Projects in renewables, storage, 
and  mobility  contribute  smaller  but  strategically  important  shares,  diversifying  the 
Fund’s technology portfolio. 

–  The  expected  large  abatement  in  energy-intensive  industries  and  industrial  carbon 
management  illustrates  the  Fund’s  relative  strength  compared  to  national  schemes, 
since  not  all  Member  States  can  finance  high-risk,  capital-intensive,  industrial 
decarbonisation projects at a comparable scale. 

–  The concentration of support in these sectors illustrates the Fund’s unique offer but also 
exposes it to delivery risks common to those sectors. Maintaining a diversified portfolio 
that  balances  large-scale  industrial  decarbonisation  with  mitigation  technologies  in 
other  sectors  (e.g.  clean  tech  manufacturing)  is  essential.  A  diversified  portfolio  not 
only diminishes risks associated with technological advancements but also promotes 
cross-sector collaboration and innovation. Clean tech manufacturing is a particular case 
which offers substantial potential for emission reductions through the introduction of 
novel production methods and sustainable materials across sectors.  

The Fund has managed its budget in line with the EU ETS Directive, ensuring (1) broad sectoral 
and geographical eligibility, (2) transparent and well-controlled financial governance, and (3) 
structured risk mitigation through milestone-based disbursements and continuous monitoring. 

(1)  Calls  have  progressively  spanned  sectors  covered  by  Annex  I  and  III  of  the  EU  ETS 
Directive, including CCS/CCU, renewables, hydrogen, and, more recently, maritime, aviation, 
batteries,  and  clean  tech  manufacturing.  Despite  broad  eligibility,  funded  projects  are  still 
concentrated  in  energy-intensive  industries,  cement  and  hydrogen,  and  in  larger  industrial 
economies, while smaller countries are still underrepresented: 

36 

 
 
–  Projects  have been awarded for implementation  in nearly all eligible countries,  with 
Germany, Spain, Belgium, Sweden, and Norway accounting for most of the awarded 
funding. 

–  Analysis  of  beneficiaries  shows  several  factors  that  contribute  to  success.  Still, 
participation continues to correlate most strongly with national industrial capacity, the 
availability of co-funding, and support during the application process (e.g. from public 
administration or the broader innovation ecosystem). 

–  Instruments such as PDA and technical assistance have improved access, supporting 
the entry of participants from countries including Denmark, Hungary, Slovakia, and the 
Baltic States. Yet, they have not fully offset disparities. 

–  When  benchmarked  against  countries’  economic  weight,  emissions  profiles  and 
industrial  value  added,  the  portfolio  appears  more  balanced,  although  disparities 
remain. 

(2) Internal procedures, including detailed audit trails, disbursement validation, and anti-fraud 
mechanisms, reinforce transparency and compliance with the EU ETS Directive. 

(3) Revenue allocation has been effective in committing available resources, with consistent 
use of the budgetary flexibility allowed by financing decisions. Financial risks are managed 
through  flexible  financing  and  structured  safeguards.  These  safeguards  have  strengthened 
accountability and enabled reallocation of unused resources, but have also limited flexibility 
for projects with weaker liquidity, particularly SMEs: 

–  A  milestone-based  payment  system  supports  timely  disbursements  (up  to  40  %  at 
financial  close  and  subsequent  instalments).  Funding  awarded  corresponds  to 
commitments  (grant  agreements  in  force),  while  actual  disbursements  depend  on 
project  progress  and  milestone  achievement,  reducing  the  risk  of  overcommitting 
resources. 

–  Case study evidence confirms that Fund grants were decisive in enabling financial close 
and  investor  confidence,  demonstrating  the  conversion  of  committed  resources  into 
bankable projects. However, the need to secure co-financing, given the 60 % funding 
rate (51), and the lack of support for operational expenditure for small-scale projects in 
earlier calls, delayed some projects (8 % of projects cite this as a main reason for the 
delay) and the mobilisation of total investment, especially in capital-intensive sectors. 
For auctions, market evolution in the hydrogen sector made resource requested under 
the bid insufficient. Delays in reaching milestones further illustrate that, while revenues 
are  effectively  committed,  their  translation  into  active  spending  is  not  always 
immediate. 

In parallel, broader structural obstacles, such as, fragmented national frameworks, simultaneous 
application of different legal frameworks (e.g. in the case of co-funding), inflationary pressures, 
high capital expenditure, long payback periods, and regulatory or permitting delays/bottlenecks, 

(51)  The 60 % funding rate ceiling was decided following a sensitivity analysis for possible funding rates for the 

Fund done in the Impact Assessment of the EU ETS Directive. Rates between 50 % and 75 % were 
compared and the graphs showed that with an increasing funding rate, the size of the funds that must be 
provided by an investor is reduced. 

37 

 
 
 
further constrain uptake, especially for SMEs and breakthrough innovators. While tools such 
as  PDA,  AaaS,  and  STEP  (Strategic  Technologies  for  Europe  Platform)  seals  (52)  have 
strengthened credibility and opened new pathways, their impact remains modest to date. 

The  Fund  has  effectively  operationalised  the  broader  mandates  of  the  EU  ETS  Directive, 
dedicating  tracks  for  small-  and  medium-scale  projects,  preferential  mechanisms  for  the 
maritime  sector,  measures  to  broaden  geographical  participation  and  substantial  support  for 
industries covered by CBAM (53): 

–  Procedural measures such as the creation of small- and medium-scale topics, PDA, and 
technical assistance have broadened access and improved maturity for smaller and less-
represented applicants. 

–  Dedicated provisions for the maritime sector demonstrate that tailored call design can 

increase visibility and access. 

–  Geographical participation has expanded to almost all eligible countries, supported by 

PDA and technical assistance. 

–  Substantial funding has been channelled into CBAM sectors (hydrogen, cement & lime, 
and steel), positioning the Fund as a key instrument for de-risking decarbonisation in 
hard-to-abate industries. 

However, outcomes remain uneven: 

–  SMEs continue to face financial and administrative burdens that limit their presence in 

the portfolio, indicating that dedicated measures have not yet yielded results. 

–  Maritime  support  is  in  its  early  stages,  but  results  remain  limited  due  to  immature 

pipelines, infrastructure gaps, and regulatory uncertainty. 

–  Awards  remain  concentrated  in  larger  EEA  countries  with  stronger  innovation  and 
funding landscapes (i.e. number of leading industrial companies, national funding for 
potential applicants available) reflecting also more advantageous electricity costs and 
existing  industrial  basis, while smaller countries  without those attributes continue to 
face structural disadvantages. 

–  Coverage  across  CBAM  sectors  is  incomplete.  Uneven  sectoral  coverage,  maturity 
challenges,  and  cost  pressures  persist.  Interviews  with  CINEA  and  member  of  the 
Innovation  Fund  Expert  Group  (IFEG)  representatives  confirm  that  CBAM-related 
sectors  have  consistently  been  supported,  though  only  hydrogen  benefited  from  a 
dedicated mechanism (e.g. auctions). 

Technical  assistance  has  strengthened  the  Fund’s  support  structure  by  enhancing  NCPs’ 
capacity,  expanding  outreach,  and  fostering  peer  learning  across  countries.  Training, 
communication  tools,  and  networking  have  improved  baseline  knowledge  and  guidance  on 

(52)  Strategic Technologies for Europe Platform is an initiative which focuses on accelerating projects in the 
development and manufacturing phases across digital and deep tech, clean and resource efficient tech, 
biotech and defence tech, link: Strategic Technologies for Europe Platform (STEP) | European Union 

(53)  Carbon border adjustment mechanism, link: Carbon Border Adjustment Mechanism - Taxation and Customs 

Union 

38 

 
 
 
application, and targeted support for countries with low participation rates has been launched 
to  address  structural  disparities.  Survey  results  and  interviews  of  NCPs  confirm  broad 
participation and generally positive views. However, the effect on application quality remains 
limited and uneven. While application quality has improved, NCPs underlined that challenges 
with timelines, technical depth, and the generic nature of some support continue to constrain 
impact. The new targeted support for countries with low participation rates is promising but too 
recent to show results. 

Project  Development  Assistance  (from  hereon  PDA)  has  been  effective  in  improving  the 
maturity  and  bankability  of  proposals  that  were  initially  unsuccessful.  Among  the  37  PDA 
beneficiaries  who  reapplied,  16  eventually  secured  a  Fund  grant,  or  a  43  %  success  rate. 
Although one could compare this rate with the success rate of resubmissions that did not receive 
PDA, it would not be a fair comparison, as proposals selected for PDA are generally among the 
best  proposals  that  did  not  make  it  to  the  final  selection.  The  PDA’s  tailored  financial  and 
technical  advisory  services  have  proven  effective  in  addressing  critical  maturity  gaps  and 
boosting investor confidence, as confirmed by survey results from unsuccessful applicants and 
interviews of the EIB. However, PDA’s overall reach remains limited, with uptake concentrated 
in  a  few  countries  and  sectors,  delivery  often  too  close  to  deadlines,  and  smaller  promoters 
being less likely to benefit from it. 

Blending operations under the Fund  are limited and considered  resource-intensive, making 
them  complementary  rather  than  central  instruments  of  the  Fund.  However,  they  promise 
benefits of broader governance, shared due diligence, and a possible larger impact in mobilising 
external capital, notably through the EU–Catalyst partnership and the InvestEU battery top-up. 
Very few projects have received support under those instruments, so it is too early to judge their 
overall impact. 

AaaS has enabled EEA countries to channel national funding to positively evaluated proposals 
for which there was no sufficient Fund budget, mobilising EUR 350 million in Germany under 
the  IF23  Auction  and  EUR  836  million  in  Austria,  Spain,  and  Lithuania  during  the  IF24 
Auction. The mechanism succeeded in reducing administrative burden and aligning national 
schemes  with  the  Fund’s  evaluation,  largely  thanks  to  the  close  alignment  of  the  EU-wide 
auctions to State aid rules. While the project awards did not materialise in Germany  (due to 
transferred projects deciding to withdraw from the grant agreement preparation) and Lithuania 
(due to the lack of Lithuanian bids submitted in the auction), there is a tangible impact in Spain 
and Austria, with nine additional projects to be awarded. 

The  Fund  has  developed  a  comprehensive  and  increasingly  mature  framework  for 
communication and knowledge sharing. Multi-channel communication, through Info Days, 
webinars,  press  releases,  social  media,  and  NCPs  outreach,  has  ensured  broad  visibility, 
especially  in  larger  EEA  countries  and  sectors  with  strong  pipelines.  Knowledge  sharing  is 
consistently implemented through project-level plans, structured closed-door and public events, 
thematic workshops, and systematic feedback loops between CINEA and DG CLIMA, which 
together support peer learning, policy refinement, and replication of early lessons. Satisfaction 
levels are generally positive, with recent events benefiting from improved coordination, timelier 
announcements,  and  more  consistent  documentation.  Nonetheless,  effectiveness  still  varies 
across audiences and sectors: smaller countries and SMEs face capacity constraints; helpdesk 
responsiveness remains uneven for some users; and the relevance of knowledge-sharing events 
depends strongly on technological alignment. While these challenges persist, the Commission 
has progressively addressed them. 

39 

 
 
To summarise, the Fund has largely achieved its objectives, while becoming a cornerstone of 
EU climate finance. It has been effective in selecting and financing innovative decarbonisation 
projects with significant  potential to reduce GHG emissions and advance the deployment of 
low-carbon technologies. 

The Fund's operations indicate a substantial influence in mobilising additional finance, notably 
private  investment,  alongside  national  co-funding.  Although  synergies  with  other  EU 
programmes, such  as  Horizon Europe,  are modest,  there is  evidence of sequential  links that 
support the innovation pipeline. 

Despite ongoing challenges, including project delays, unequal geographic representation, and 
structural disparities faced by smaller countries and SMEs, the Fund’s implementation remains 
on track to achieve its long-term objectives. The oversubscription of calls for proposals attests 
to its strong market relevance, though a sustained imbalance between requested and available 
budgets suggests room for expansion. 

While  the  Fund  has  successfully  managed  its  revenues,  maintained  broad  sectoral  and 
geographical  eligibility,  ensured  transparent  governance,  and  implemented  structured  risk 
mitigation, certain  constraints affect project uptake. These include permitting, infrastructure, 
and market constraints typical of innovative technologies. 

If  the  Fund  has  delivered  significant  progress  towards  helping  to  de-risk  investments, 
accelerating financial closure, and reinforcing Europe’s competitiveness in clean technology 
markets,  efforts  should  continue  to  address  funding  gaps  and  disparities,  ensure  greater 
coverage, and improve the effectiveness of measures for smaller participants. 

4.1.2.  Efficiency 

The evidence used to assess the Fund’s efficiency is linked to its ability to launch predictable 
calls, adapt to market developments, and introduce new instruments. This mixed evidence base 
highlighted the Fund’s balance between stability and adaptability: 

–  Performance data tracked resource use (e.g. administrative costs, staffing efficiency) 
and the uptake of new tools  such as auctions,  ‘as-a-services’ schemes, and blending 
operations. 

–  Stakeholder  inputs  from  beneficiaries,  NCPs,  and  managing  bodies  highlighted  the 
Fund’s  operational  flexibility  through  adjustments  to  award  criteria,  streamlined 
processes, and the launch of new instruments in  response to evolving priorities (e.g. 
hydrogen, maritime decarbonisation).  

–  Comparative  benchmarks  against  other  EU  programmes  (e.g.  Horizon  Europe  and 
LIFE)  further  assessed  whether  the  Fund  optimised  its  processes  while  maintaining 
predictability.  

–  Interviews and surveys also identified barriers to agility, such as administrative burdens 
and delays in  grant  preparation, as well as best practices (e.g. simplified application 
templates) to improve future efficiency. 

To  assess  the  Fund’s  efficiency  in  reducing  GHG  emissions,  the  expected  GHG  emission 
avoidance was used. Indeed, as most projects are still in early phases, actual GHG emissions 

40 

 
 
reductions  are  minimal,  although  the  budget  has  been  committed.  Calculating  the  cost-
efficiency of actual reductions would not have been representative of the Fund’s portfolio. 

Regarding  investment  mobilised,  the  total  volume  was  calculated  based  on  the  total 
expected/planned  capital  expenditure  communicated  by  project  promoters  during  the 
application  phase.  Once  a  project  reaches  financial  close,  more  accurate  data  on  actual 
investments  mobilised  is  available,  as  part  of  reporting  requirements.  Until  then,  the  high 
overall cost-efficiency remains potential. For a full description of the evidence used to analyse 
the Fund’s efficiency, please see Annex III.  

The Fund demonstrates high overall potential cost-efficiency in reducing GHG emissions and 
mobilising  investment.  Across  the  programme  funding  period  2020–2024,  the  Fund 
demonstrated  a  potential  to  achieve  an  average  cost-efficiency  of  EUR  13.36  per  expected 
tCO2e  avoided  (calculated  as  the  total  Fund  budget  spent,  direct  management,  and  indirect 
management divided by the potential GHG emissions avoidance to be achieved by the awarded 
projects), among the lowest observed across comparable national interventions. While leverage 
ratios  are  lower  than  those  of  funding  instruments  such  as  the  COSME  Equity  Facility  for 
Growth (21.00) or InnovFin Equity (14.23), this reflects the Fund’s design, which focuses on 
non-repayable grants that are needed for high-risk, first-of-a-kind projects where demonstration 
and innovation take precedence over financial returns..  

The  Fund  also  induced  EUR  4.85  in  direct  investment  (i.e.  capital  expenditure)  per  euro  of 
budget spent (EUR 56.3 billion total) and an additional EUR 4.7 in indirect investment (EUR 
54.6  billion).  Applicants  risk  penalties  if  they  overestimate  their  potential  to  reduce  GHG 
emissions.  During  evaluation,  unrealistic  or  poorly  substantiated  claims  may  lead  to  lower 
scores,  while  final  grant  amounts  are  tied  to  verified  emission  reductions,  meaning 
overestimates could result in reduced funding. These mechanisms act as strong disincentives 
against inflated projections. However, given the limited data available to date, it is too early to 
assess whether applicants’ calculations for GHG emissions avoidance proved accurate. 

Most beneficiaries consider the funding rate adequate to ensure projects’ financial viability 
(77 out of 124 respondents, or 61 %), but its adequacy is highly context-dependent, reflecting 
differences across project categories, technologies, and maturity levels (54): 

–  Among those who found the rate insufficient, the main reasons cited were that it does 
not  sufficiently  cover  high  upfront  costs  (37  respondents)  and  that  securing  the 
remaining 40 % from other sources is challenging (26 respondents). 

–  This  is  particularly  the  case  for  capital-intensive  or  operational-intensive  projects  in 
hard-to-abate sectors. For more mature technologies, such as renewables and energy 
storage, the rate was generally viewed as sufficient to enable realisation. 

Interviews and case studies report that inflation, disbursement procedures, and limited access 
to  complementary  national  or  regional  funding  are  frequently  cited  as  barriers  to  reaching 
financial close.  

The  Fund  runs  with  relatively  low  execution  costs  compared  to  other  EU  programmes,  but 
evidence  suggests  this  efficiency  is  partly  linked  to  understaffing.  Between  2020  and  2024, 

(54)  Surveys  with  beneficiaries  (Q9,  Q10),  unsuccessful  applicants  (Q16),  and  Horizon  Europe  beneficiaries 

(Q20); interviews of beneficiaries with CINEA and Hydrogen Europe; case studies. 

41 

 
 
 
direct management costs accounted for only 0.9 % of the Fund’s total budget – well below the 
3-4 % observed for LIFE and Horizon Europe programmes. Although total expenditures and 
staffing levels have grown in line with the Fund’s expansion, interviews with CINEA highlight 
persistent capacity shortages and heavy workloads. At the same time, low remuneration rates 
undermine CINEA’s ability to attract and retain external evaluators, increasing transaction costs 
due to repeated recruitment, training, and supervision. Inefficient information technology (IT) 
systems and outdated administrative tools further strain operational efficiency.  

Administrative costs for beneficiaries are high in absolute terms but low relative to the grant 
size: 

–  Beneficiaries spend an average of EUR 95 000 per small-scale project and EUR 240 
000 per large-scale project on application and reporting, reflecting the different nature 
of the projects in terms of size and maturity, as well as the larger average size of support 
available under the Fund. 

–  Administrative costs related to the application stage averaged EUR 36 000 for small-

scale projects and EUR 131 000 for large-scale projects.  

–  Administrative costs related to monitoring and reporting obligations were on average 

EUR 59 000 for small-scale projects and EUR 108 000 for large-scale projects.  

While the costs are considerable in total (Table 3), they constitute a small part compared to the 
grants  received. When only  the administrative  costs of the  application are considered, these 
represent 0.2 % of the grant value for large-scale projects, 0.4 % for medium-scale projects, 
and 1 % for small-scale projects, compared with 3-5 % in Horizon Europe (55). 

Table 3: Administrative costs for beneficiaries during application 

Instrument and evaluation period 

Administrative costs 
related to application vs 
grant received 

Average 
administrative costs 
for application 

Innovation Fund overall (2020-2024) 

0.5 % (56) 

EUR 85 000 (57) 

Small-scale projects 

Medium-scale projects 

Large-scale projects 

1.00 % 

0.40 % 

0.20 % 

EUR 36 000 

EUR 69 000 

EUR 131 000 

Horizon Europe (2021-2024) (58) 

3 – 5 % 

EUR 21 000 – 32 000 

(55)  The average grant size for Horizon Europe projects was EUR 2.9 million while for the Fund, the average grant 
size was EUR 7.3 million for small-scale projects, EUR 27.4 million for medium-scale projects, and EUR 
110.1  million  for  large-scale  projects.  (source:  Interim  Evaluation  of  the  Horizon  Europe  Framework 
Programme for Research and Innovation (2021 – 2024)). 

(56)  Weighted average of small-, medium- and large-scale projects. 

(57)  Weighted average of small-, medium- and large-scale projects. 

(58)  European Commission, Staff Working Document SWD(2025) 110 final – Interim Evaluation of the Horizon 

Europe Framework Programme for Research and Innovation (2021 - 2024). 

42 

 
 
 
 
Although  small-scale  projects  see  lower  average  administrative  costs  in  absolute  terms,  the 
reporting  and  documentation  requirements  and  add  to  the  perceived  burden,  particularly  for 
SMEs that rely on external consultants to meet compliance obligations. In addition, compared 
to the grant amount received, small-scale projects spend a larger percentage of their funds on 
application costs.  However, compared  with other programmes such  as Horizon Europe, this 
percentage remains low.  

Calculating  the  grant  received  per  euro  of  total  administrative  costs  further  highlights  the 
additional burden on small-scale projects  compared to large-scale projects (Table 3). Large-
scale  projects  receive  substantially  greater  grant  amounts  relative  to  administrative 
expenditures,  whereas  medium-scale  projects  achieve  moderate  efficiency,  and  small-scale 
projects  realise  the  lowest  returns.  This  discrepancy  stems  from  the  fact  that  administrative 
requirements, including application, reporting, and monitoring obligations, apply uniformly to 
all  projects,  with  only  minor  simplifications  for  the  small-scale  projects.  However,  grant 
amounts are proportionate to a project’s relevant costs, which vary considerably between small- 
and large-scale  projects. Consequently, small-scale projects  bear a disproportionately higher 
administrative burden relative to the funding they receive. 

Table 4: Grant received per administrative costs 

Instrument and evaluation period 

Grant received per EUR of total 
administrative costs (59) 

Innovation Fund overall (2020-2024) 

EUR 329 (60) 

Small-scale projects 

Medium-scale projects 

Large-scale projects 

EUR 56 

EUR 171 

EUR 463 

Based on data reported by projects at the end of Q1 2025, the Fund has the potential to generate 
high societal benefits, with total net quantifiable benefits estimated at EUR 279 billion over the 
programme  funding period 2020-2030 (61), with  a benefit-cost  ratio of 14.3 when measured 
against  the  EU  contribution (62)  and  2.5  when  all  costs,  including  national  and  private  co-
financing, are considered  (63). This means that for every euro of EU budget spent, EUR 14.30 
in benefits is generated (showing that the quantifiable benefits of funded projects exceed the 
EU’s contribution by more than 14 times) and that for every euro of total costs, EUR 2.50 in 
benefits is produced. 

(59)  Application, monitoring & reporting costs. 

(60)  Weighted average of small-, medium- and large-scale projects. 

(61)  EUR 66 billion for the evaluation period 2020-2024 and EUR 213 billion for 2025-2030. 

(62)  The benefit-cost ratio for EU contribution is calculated by dividing the total quantifiable benefits (monetised 
GHG emissions avoided) by the costs incurred by EU institutions, including Fund grants, public financing by 
other EU funds and programmes,  and other costs incurred by the Fund and related to direct  management, 
indirect management, and blending operations. 

(63)  The benefit-cost ratio for overall costs is calculated by dividing the total quantifiable benefits by the total costs 
of the fund, including all costs incurred by EU institutions, as well as additional public and private financing 
costs. 

43 

 
 
 
 
These results, based on an estimated budget of EUR 40 billion between 2020 and 2030 and on 
expected emissions avoidance, show that the Fund delivers strong value for money compared 
to other EU interventions: 

–  Even when all costs are included, the ratio remains robust at 2.5. This is lower than that 
of  programmes  such  as  LIFE  (4.7-7.1)  and  Horizon  Europe  (5.0-6.0),  which  can  be 
explained by the type of projects the Fund supports.  Although Fund projects require 
substantial  co-financing  with  a  60  %  funding  rate  ceiling,  in  reality,  the  Fund  often 
covers only around 25 % of total capital expenditure. Additionally, compared to LIFE 
and  Horizon  Europe,  the  projects  are  close  to  the  market  and  must  achieve  GHG 
emissions avoidance. 

–  Sensitivity  analyses  confirm  that  the  ratio  remains  positive  under  less  favourable 
assumptions, such as lower CO2 prices or reduced budgets, suggesting that the Fund’s 
long-term cost-efficiency is resilient to such external changes. 

In addition to quantifiable benefits, indirect qualitative benefits have been identified, including 
health and social benefits, although they could not be monetised (see Annex IV). 

However, efficiency varies across project sizes, categories, sectors and regions: 

–  Small-scale projects  show greater cost-efficiency in emission avoidance, while large-
scale projects are more efficient at leveraging additional financing. Small-scale projects 
perform  best  compared  to  both  EU  and  total  funding,  with  the  highest  benefit–cost 
ratios,  while  large-scale  projects  –  although  delivering  most  of  the  total  quantified 
benefits  –  show  lower  efficiency  due  to  their  capital  intensity.  Moreover,  projects 
located in eastern and northern Europe, regardless of size, show greater cost-efficiency 
in emission avoidace than the EU-average. 

–  Energy storage and renewable energy projects perform best on emissions avoidance, 
while energy storage, energy-intensive industries, iron & steel, and solar energy achieve 
above-average investment mobilisation. Sectoral patterns show that industrial carbon 
management  projects  generate  the  largest  absolute  GHG  emissions  savings,  while 
energy storage and renewable energy projects perform best relative to EU funding. 

–  Regional differences are also pronounced, with northern and eastern Europe achieving 
above-average benefit-cost ratios, reflecting competitive cost structures and supportive 
national conditions. 

Disbursements are well monitored and procedurally sound, but often slower than desired 
for project implementation. The design choice to release funds only after achieving milestones 
ensures  control  and  accountability.  Still,  it  leads  to  long  lead  times  and  liquidity  strain, 
particularly  for  capital-intensive,  first-of-a-kind  projects.  Once  milestones  are  reached, 
payments  are  processed  efficiently,  supported  by  clear  monitoring  tools  and  structured 
oversight from CINEA. Delays mostly stem from project-side challenges, such as permitting, 
financing, and market conditions, rather than administrative inefficiency. Compared with other 
EU mechanisms, the Fund’s milestone- and lump-sum-based model is viewed by beneficiaries 
as more transparent and disciplined, though less flexible and more burdensome than national 
programmes. 

44 

 
 
Recent  measures  have  improved  disbursement  efficiency,  though  administrative  effort 
remains  high.  CINEA  has  improved  guidance  and  support  through  webinars  and  helpdesk 
services,  while  clarifying  milestone  requirements  and  tightening  rules  on  postponements. 
Newer  approaches,  such  as  the  auction’s  simplified  payment  structure,  show  potential  to 
accelerate  disbursements  and  increase  flexibility.  Communication  between  CINEA  and 
beneficiaries  is  generally  effective  and  valued.  However,  variations  in  guidance,  occasional 
changes in project officers, and the rigidity of IT systems continue to cause delays and lead to 
a certain degree of confusion. Administrative costs remain low in budgetary terms but high in 
staff effort for both CINEA and beneficiaries. 

Additional  measures  have  been  taken  during  the  evaluation  period  to  ensure  efficient 
disbursement and limit the risk of holding assets that will be needed later for payments. Before 
2023, the Fund’s allowances were spread evenly over the years, and commitments were based 
on available resources.  To allow funds to be committed earlier and avoid  holding assets for 
longer, the 2023 amendment to the EU ETS Directive introduced the possibility of using annual 
instalments and frontloading the Fund’s resources for calls. This means that projects’ payment 
schedules are accounted for when defining the upcoming call’s budget. The commitments no 
longer need to be based solely on available resources, but instead follow a projection linked to 
expected future payments and inflows. This measure allows for frontloading Fund resources at 
an early point in time without selling allowances earlier. 

In practice, multi-annual actions can be financed through annual budgetary instalments linked 
to  grant  disbursements  (project  payments).  This  reduces  the  need  for  frontloading  Fund 
allowances  (selling  allowances  in  advance  to  cover  higher  call  budgets)  and  therefore  has 
limited/no  impact  on  the  EU  carbon  market  price  while  allowing  for  an  increase  in  yearly 
commitment  levels.  Although  resources  are  effectively  channelled  between  parallel  calls 
through this frontloading, there is still room for improvement, notably in the management of 
reserve  lists  to  increase  the  speed  of  budget  reallocation  and  in  maximising  the  opportunity 
costs of unused funds. 

The application and selection processes are transparent but remain demanding. Support tools 
are valued, yet their quality is uneven, and complex methodologies lead many applicants to rely 
on  consultants.  As  seen  in  Figure  9,  processing  times  have  increased,  reducing  efficiency 
despite  transparent  and  fair  award  criteria  and  a  well-organised  evaluation  and  selection 
process. This is due to the increased number of proposals received per call (Figure 5) and topics 
introduced (see 3.3 Project implementation).  

The preparation of grant agreements provides a solid basis for project implementation, as  
for example  relevant  documents are requested and project  milestones clearly defined, but is 
resource-intensive. The process ensures that risks are addressed. Yet beneficiaries experience 
duplication of effort and heavy workloads. CINEA's support is valued, and projects typically 
start quickly after grant agreements are signed. 

Communication  and  coordination  during  implementation  are  efficient  and  appreciated. 
CINEA is praised for its responsiveness and proactive contact, as reflected in the ‘partnership 
approach’. Both internal coordination within CINEA and coordination between DG CLIMA 
and CINEA are well-structured. Still, some beneficiaries call for clearer  guidance and more 
targeted knowledge sharing. 

45 

 
 
Monitoring  of  the  Fund  safeguards  accountability  but  creates  a  heavy  administrative 
burden.  Reporting  obligations  are  seen  as  disproportionate  and  sometimes  impractical, 
especially through the SyGMa portal. Beneficiaries rely on CINEA to navigate requirements, 
though  staff  turnover  sometimes  reduces  continuity.  While  administrative  burden  remains 
significant, there are clear opportunities for simplification: 

–  Evidence across surveys, interviews, and case studies consistently shows that the main 
burdens  stem  from  complex  GHG  and  financial  methodologies,  extensive  reporting, 
and the high resource intensity of the application preparation. These challenges affect 
all applicants but disproportionately impact SMEs with limited internal capacity. 

–  Simplification  measures  introduced  so  far  (such  as  streamlined  cost  calculation 
methods  and  structured  templates)  have  had  positive  effects  but  have  not  fully 
addressed the underlying issues. The persistence of heavy reporting and methodological 
complexity  suggests  that  simplification  efforts  should  focus  on  the  most  resource-
intensive processes rather than on procedural fine-tuning. 

There is potential for further simplification both during the application and implementation 
stages: 

–  Evidence indicates that measures such as clearer templates, staged applications, and, 
where  possible,  simplified  reporting  requirements  could  help  reduce  administrative 
effort while maintaining control and transparency. 

–  Improving  guidance,  ensuring  continuity  of  contact  points,  and  enhancing  technical 

workshops would help reduce reliance on external consultants. 

–  The  AaaS  experience  demonstrates 

that  centralisation,  standardisation,  and 
parallelisation  of  administrative  procedures  can  reduce  processing  time,  costs,  and 
duplication, though some of the burden is shifted rather than reduced. 

PDA  demonstrates  measurable  success  relative  to  its  advisory  purpose  and  resource  scale, 
though outcomes vary across projects. The total expenditure of EUR 23.6 million (about EUR 
380 500 per project) is modest compared to Fund grants (about EUR 58 million per project on 
average). It reflects a focused use of funds for targeted technical and financial support: 

–  About 26 % of supported proposals ultimately received Fund grants. When looking only 
at the 60 % of supported proposals which re-applied to a call for proposals, the success 
rate  reach  43  %,  with  additional  successes  through  national  or  private  financing, 
indicating strong leverage and catalytic impact. 

–  Due  to  a  lack  of  relevant  benchmarks  available  for  comparison,  PDA’s  overall  cost-
efficiency cannot be determined. Limitations in monitoring and data gaps on long-term 
outcomes also add uncertainty. However, alignment with call timelines, project maturity, 
and promoter capacity influenced the extent to which PDA could be applied effectively. 

Consistent practices and procedural learnings have improved the delivery of PDA, but timing 
and promoter engagement remain critical determinants for results: 

–  The  use  of  maturity  scorecards,  targeted  scoping,  framework-based  consultant 
mobilisation, and continuous oversight by the EIB have strengthened process discipline 
and reduced transaction costs. 

46 

 
 
–  Efficiency is highest when assignments begin early, have clearly defined scopes that 
are adequately targeted to a specific proposal’s needs, and benefit from active promoter 
participation. 

–  Conversely, late starts, limited internal capacity, or a less developed pipeline of eligible 

proposals in certain regions have reduced the return on PDA inputs. 

Since blending operations have only started recently and the total number of financed projects 
is  still  low,  limited  conclusions  can  be  drawn  on  their  cost-efficiency.  Financial  resources 
dedicated to blending operations totalled about EUR 420 million over the period 2020–2024. 
The EIB plays a key role in due diligence for projects eligible under such operations, but the 
number of human resources allocated to such operations is unspecified. Clear eligibility criteria, 
synchronised review procedures, and close coordination between the Commission, the EIB, and 
Breakthrough Energy ensure accountability, but implementation is slow. 

Although  the  Fund  has  already  adopted  best  practices,  the  broader  application  of  efficiency 
measures from other EU programmes could further strengthen its management processes: 

–  Lessons from Horizon Europe and LIFE show that simplifying application procedures, 
reducing  the  number  of  negotiation  stages,  and  adopting  more  flexible  electronic 
workflows can lower administrative burdens and speed up time-to-grant.  

–  The European Innovation Council’s programme uses interviews of applicants, which may 
reduce the burden on applicants and the need for external consultants when producing 
detailed  written  responses.  It  also  provides  evaluators  with  an  opportunity  to  seek 
clarifications from applicants. Like the Connecting Europe Facility, it offers multiple cut-
off dates that can be relevant for smaller projects that have less possibility to wait for an 
opportunity to apply for funding. 

However, the Fund’s focus on investments in market-ready innovations with high commercial 
viability and the high grant amounts mean that lessons learned from other programmes such as 
Horizon Europe and European Innovation Council cannot be directly transferred to the Fund. 
Even so, practices in other programmes, such as early financial maturity checks, pre-financing 
mechanisms,  and  simplified  reporting  requirements,  have  improved  cost-efficiency  in  those 
programmes, and their application in some form may be considered for the Fund. 

The analysis shows that changes in expectations about the time to reach financial close or in 
project operational aspects were cited as key reasons for amending or terminating a grant 
agreement: 

–  Financial close prospects changed mainly because of permitting and regulatory barriers, but 

adverse market and cost developments and partnership issues were also cited. 

–  Projects were terminated when these types of challenges became insurmountable. 

–  In  most  cases  of  termination,  projects  could  not  secure  financial  close  or  lost  economic 
viability, and redesigns were not possible if they would result in a fundamental change to 
the project. 

–  A change in the level of innovation, expected GHG emission avoidance, or replicability were 
rarely cited as reasons to amend or terminate a grant agreement. This implies that the Fund’s 

47 

 
 
selection  process  based  on  these  criteria  is  robust,  as  the  likelihood  that  implementation 
realities differ from the initial assessment for one of these reasons is small. 

4.1.3.  Coherence 

4.1.3.1.  Internal coherence 

The  Fund's  internal  coherence  is  characterised  by  strong  alignment  between  activities  and 
objectives, often confirmed in practice by the progress of projects towards high TRLs and early 
commercial readiness. Supporting mechanisms such as blending operations and ‘as-a-service’ 
schemes  also  show  moderate  alignment  but  high  potential  for  synergies,  complementing 
conventional pathways. 

However,  there  may  be  target  conflicts  between  the  Fund’s  objectives,  such  as  combining 
revenue management efficiency with geographical balance or broad technological coverage: 

–  A  primary  built-in  tension  is  the  conflict  between  supporting  innovative  solutions  and 
pushing for their large-scale deployment. The need for 'bankability' to attract private capital, 
combined with a focus on first-of-a-kind products, creates tension when infrastructure and 
functioning markets are lacking. 

–  Furthermore, a limited funding pool spread across different technologies and regions creates 
a  target  conflict,  potentially  leading  to  insufficient  support  for  specific  technologies  and 
processes. 

This indicates that activities’ high potential for synergies is often neutralised by market realities, 
design  choices  that  implicitly  favour  certain  technologies,  and  a  lack  of  stakeholder 
participation in sectors that the Fund appears to underfund: 

–  The most significant obstacle, as identified in surveys (64) and during the ‘reality check’, is 
linked  to  the  application  and  reporting  processes.  Although  beneficiaries  often  report 
satisfaction  with  the  support  they  receive,  the  complexity  of  the  application  process  and 
updates  to  award  criteria  between  calls  create  additional  financial  strain  and  risk, 
discouraging smaller promoters.  

–  Another operational barrier is the conflict between the Fund's risk-taking ambition and the 
limited  flexibility  of  its  financial  rules.  The  focus  on  capital  expenditure,  coupled  with 
disbursement rules, can create liquidity bottlenecks in the early stages of projects (which can 
be addressed through project amendments), often forcing promoters to self-finance crucial 
preparatory work. Adapting to changing market and technological conditions, particularly 
in  the  face  of  market  shocks,  can  create  friction  between  the  objective  of  successful 
decarbonisation and the aim of operational effectiveness, thereby limiting the ability of even 
highly aligned projects to reach completion. 

(64)  The beneficiaries’ survey (Q29, Q44), the unsuccessful applicants’ survey (Q21) and the survey with Horizon 
Europe beneficiaries (Q1) indicate dissatisfaction with the burdens of the application process. In Q30, Q45 
and Q48 of the beneficiaries’ survey, some respondents raised similar issues for monitoring and reporting. 

48 

 
 
 
4.1.3.2.  External coherence 

The evaluation of the Fund’s external coherence reveals a complex landscape. The Fund is 
highly aligned with EU policies and regulations, yet there are significant barriers to regulatory 
and funding coordination. 

The Fund’s legal framework (the Financial Regulation) encourages synergies with other EU 
and  national  programmes.  The  ‘no  double-funding’  principle  of  the  Financial  Regulation  in 
most of the cases means that combined EU funding cannot exceed the eligible costs, which is 
ensured by limiting the combined funding rates from two or more EU programmes to 100 %.. 
For State aid, the rules on combined support are established in relevant State aid frameworks 
(e.g. GBER, CEEAG, CISAF). In practice, however, cumulation is difficult to manage due to 
the complex calculations required to avoid double funding and to respect State aid   rules, as 
well as the different rules of different funding instruments.  

The introduction of ‘as-a-service’ schemes further strengthens the potential for synergies with 
national  funding.  Coherence  with  national  funding  schemes  is  best  achieved  by  allowing 
national  authorities  to  use  funds  from  other  public  schemes  through  ‘as-a-service’  schemes. 
Both AaaS and GaaS are also useful when a country lacks schemes to support decarbonisation 
projects. Rather than developing a new scheme ‘from scratch’, national authorities can rely on 
the Fund’s selection mechanism and benefit from the EU-level competition to identify the best 
national projects. For climate, environmental protection and energy 2022 (‘CEEAG’)  EU-level 
auctions  of ‘as-a-service’ schemes. 

By  2025,  AaaS  allowed  EUR  2.9  billion  from  national  resources  to  be  added  to  the  Fund’s 
budget: 

–  Spain was able to make use of resources from the Recovery and Resilience Facility (RRF). 
Using  the  AaaS  scheme,  Spain  achieved  a  strong  complementarity  with  its  H2  Valleys 
funding scheme. 

–  In 2025, Germany used AaaS to support the development of projects producing hydrogen 
beyond its borders (in Denmark) using the same principle, while supporting the development 
of infrastructure and off-takers with other funding schemes nationally. 

Besides the effect  of more projects  being  financed in  countries using AaaS, there  is also  an 
indication  that  the  number  of  bids  received  in  these  countries  increased.  Indeed,  in  general, 
more  bids  are  submitted  to  the  Fund  auction  from  a  particular  country  when  the  country 
participates in AaaS. For instance, during the IF24 Auction which had the AaaS for Austria, 
Austria received three times as many bids as during the IF25 Auction (when Austria did not use 
AaaS). Grants-as-a-Service has not yet been used by EEA countries 

When  it  comes  to  complementarities  with  other  EU  programmes,  the  Fund  encourages 
synergies (65): 

(65)  European Commission, Innovation Fund 2024 – Call Fiche (Net-Zero Technologies), Publications Office of 
https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-

the 
2024, 
2027/innovfund/wp-call/2024/call-fiche_innovfund-2024-nzt_en.pdf. 

European 

Union, 

49 

 
 
 
–  Horizon Europe is one of the instruments most complementary to the Fund (Section 4.1.1). 
As of the end of Q1 2025, 13 Fund projects were previously funded by FP7, Horizon 2020 
or  Horizon  Europe  (out  of  38  known  previously  funded  projects  that  applied  for  Fund 
support). Even though only a small number of projects applied, their success rate was 32.5%, 
compared  with  12%  on  average  for  the  overall  portfolio.  Stakeholders  also  confirmed 
Horizon Europe as the most common complement to the Fund (66). 

–  Because it contributes to STEP priorities by strengthening the competitiveness and resilience 
of the European economy, the Fund is authorised to award STEP Seals to help projects obtain 
additional  or  alternative  funding  from  other  sources,  including  EU  funding  programmes 
implemented at national and regional level (e.g. cohesion policy funds).  

–   In  practice,  proposals  scoring  above  all  evaluation  thresholds  during  calls  for  ‘regular’ 
grants are automatically awarded a STEP seal. To date, the Fund has awarded the quality 
label to 316 projects, more than any other funding programme in the scope of STEP. The 
Commission is working with Member States to promote these projects and unlock additional 
or alternative funding at both the EU and national levels. 

–  Complementarities  with  the  Modernisation  Fund  exist  and  could  be  further  amplified  if 
beneficiary countries used it to support innovative projects on their territory through ‘as-a-
service’ schemes (so far, only Lithuania has done so). 

–  The  Fund  also  complements  the  Connecting  Europe  Facility  (CEF).  Many  supported 
projects,  especially  in  CCS  and  hydrogen,  need  to  connect  to  new  infrastructure.  CEF  is 
supporting CO2 and hydrogen pipelines necessary for the development of full value chains 
for these new technological pathways. Closer coordination among project promoters could 
create greater synergies with CEF, as the instrument addresses residual needs and intervenes 
where market or other funding mechanisms are insufficient. 

–  Finally, Fund projects have been able to combine funding from the Just Transition Fund and 
the Recovery and Resilience Facility, albeit to a lesser extent due to the different scopes of 
these programmes. 

Funded projects and the Fund's objectives are also highly aligned with broader EU policies: 

–  The strong participation  of hydrogen-related projects  aligns with  the European Hydrogen 
Strategy and the Net-Zero Industry Act.  Projects  in  sectors such  as chemicals,  cement  & 
lime,  and  refineries  are  also  consistent  with  the  New  Industrial  Strategy  for  Europe,  the 
Circular  Economy  Action  Plan,  and  the  Industrial  Carbon  Management  Strategy. 
Furthermore, the numerous projects in renewables and energy storage align with the Solar 
and Offshore Energy Strategies, and the objectives of the Green Industrial Deal Plan and of 
the Strategic Technologies for Europe Platform (STEP). 

–  This  high  potential  for  synergies  is  enhanced  by  the  Fund's  ability  to  respond  quickly  to 
changes in technological demand, as it is funded by EU ETS revenues rather than conditional 
on the EU’s seven-year budget cycle. However, a focus on a few sectors in calls for proposals 

(66)  Surveys with beneficiaries (Q74, Q75), unsuccessful applicants (Q5), NCPs (Q63) and Horizon Europe 

beneficiaries (Q13). 

50 

 
 
 
could risk underfunding other needed emerging technologies and prevent potential synergies 
from materialising.  

The  Fund’s  objectives  are  also  highly  coherent  and  relevant  to  EU  climate  and  industrial 
legislation and regulations. By issuing annual calls for proposals, the Fund can quickly adapt 
to policy priorities. For instance, after the Net Zero Industry Act was adopted in 2024, calls for 
proposals were revised to align with it. Many projects address multiple sector-specific pieces 
of  legislation,  such  as  the  EU  ETS,  the  EU  Batteries  Regulation,  and  FuelEU  Maritime. 
However, the strong alignment in objectives does not necessarily translate into alignment in 
specific requirements, application and reporting processes. This  mis-alignment is viewed by 
both project promoters and stakeholders as a significant barrier to accessing finance.  

The alignment across countries is uneven and sometimes constrained. Stakeholder consultations 
highlight that regional cost structures, due to for example regional variation in permitting rules 
and administration as well as energy price within a country, can disadvantage some countries 
in  auctions,  and  survey  evidence  shows  outreach  often  favours  large  companies.  Some 
interviews further highlighted differences in administrative and eligibility frameworks, limited 
consultation  in  designing  calls,  and  weak  coordination  with  national  schemes,  all  of  which 
reduce the potential for systematic EU–national complementarity. Continuous work with NCPs 
and technical assistance to countries with low effective participation in the Fund are measures 
taken to make the geographical balance more even. 

At the same time, a fundamental tension exists because the Fund aims to support innovative 
solutions  before  the  regulatory  environment  is  fully  ready  for  them.  This  can  lead  to  less 
ambitious funding rounds in the future or to direct obstacles to legislation and funding, which 
could  contribute  to  relocating  technology  development  and  deployment  outside  Europe. 
Frictions between EU  and national  regulations, or  between EU regulation  and  their national 
implementation, can also negatively affect the success of projects, which depend on the speed 
and consistency of legislative adoption.  

For instance, a renewable methanol project reported financial-closure delay of over a year due 
to off-takers’ hesitation to commit before the final transposition of RED III in Spain. There is 
also  a  risk  of  funding  projects  that  are  already  'bankable'  through  conventional  financing, 
thereby diverting limited funds from innovative projects that are struggling to secure private 
capital.  Finally,  projects  partially  supported  by  the  Fund  could  fail  to  reach  financial  close, 
resulting in stranded investments, inefficient budget use, and blocked support capacity. 

4.2.  How did the Fund make a difference and to whom? 

The Fund provides EU added value by enabling large-scale, high-risk, capital-intensive climate 
innovation  projects  that  often  exceed  the  financial  and  regulatory  capacity  of  individual 
countries: 

–  While national initiatives provide substantial and broad-based support for innovation, the 
Fund’s  targeted  approach  and  substantial  budget  allow  it  to  bridge  funding  gaps,  de-risk 
emerging technologies, and catalyse systemic change, particularly in hard-to-abate sectors. 

–  Beneficiaries’  feedback  and  case  studies  highlight  the  Fund’s  pivotal  role  in  project 
realisation, with many initiatives unlikely to have proceeded without EU-level support. Its 
strategic  positioning,  EU-level  competitive  selection,  and  transnational  relevance  foster 

51 

 
 
ambition, quality, and knowledge spillovers, advancing collective progress toward climate 
goals. 

However,  the  Fund’s  added  value  is  not  always  indispensable,  as  some  beneficiaries  report 
access to alternative financing. Its impact may be diluted when supporting projects better suited 
to other EU or national instruments. Additionally, the Fund’s relevance may be less pronounced 
in  already  mature  technologies  and  competitive  sectors,  suggesting  that  other  support 
mechanisms  (performance  standards,  public  procurement,  or  tax  incentives)  may  be  more 
appropriate in such cases. 

The  Fund  delivers  meaningful  added  value  to  Europe’s  climate  innovation  landscape, 
particularly by supporting high-risk, large-scale projects that individual countries would 
struggle to fund or coordinate: 

–  While the Fund’s cumulative impact over ten years is notable (871 mtCO2e), it corresponds 
to a reduction of around 87 mtCO2e per year, a fraction of EU-wide reductions achieved by 
national efforts (120 mtCO2e per year on average between 2017 and 2023) (67). 

–  Its true strength lies in its ability to complement national efforts by targeting breakthrough 

technologies and systemic change, especially in hard-to-abate sectors. 

–  The  Fund’s  EU-level  structure,  characterised  by  competitive  grant  allocation,  substantial 
pre-financing, and transnational reach, enables the pooling of resources, fosters knowledge 
sharing,  and  accelerates  the  deployment  and  replication  of  innovative  solutions  across 
borders. This approach not only enhances cost efficiency but also ensures strategic coherence 
with  broader  EU  climate  objectives,  which  would  be  difficult  to  maintain  through 
fragmented national programmes. 

Additionally, the Fund pioneered several new policy features, adding to its EU added value: 

–  The last two calls for proposal (IF24 and IF25 Calls) included award criteria on projects’ 
contribution to European industrial competitiveness (‘resilience’ criterion). This criterion, 
introduced ahead of the Net Zero Industry Act, ensures that proposals are evaluated based 
on their contribution to the EU’s competitiveness. 

–  Similarly, ‘as-a-Service’ schemes are unprecedented at the EU or national level. Despite the 
emergence of robust national funding mechanisms in several countries, these initiatives are 
best viewed as complements rather than substitutes for EU-level action. 

The  Fund’s  alignment  with  the  European  Green  Deal  and  its  ability  to  attract  additional 
investment through policy signalling further amplifies its impact. Without the Fund,  the EU 
would  risk  a  slowdown  in  breakthrough  climate  innovation,  increased  fragmentation,  and 
reduced cross-border technology diffusion, ultimately undermining collective progress toward 
climate neutrality. While challenges remain in attributing outcomes to the Fund and ensuring 
additionality, and while some barriers persist for smaller applicants or in mature sectors, the 
Fund’s design and strategic focus make it a driver of technological progress and coordinated 
climate action in the EU. 

(67)  European Commission: Directorate-General for Climate Action, Climate action – Leading the way – From 
plans to implementation for a green and competitive Europe – Progress report 2024, Publications Office of 
the European Union, 2024. 

52 

 
 
 
The  Fund’s  impact  on  economic  growth  and  job  creation  is  evident,  with  beneficiaries 
anticipating substantial increases in turnover and employment. However, the lack of detailed 
employment  data  and  robust  counterfactuals  at  this  stage  limits  the  precision  of  these 
assessments. The Fund fosters skills development and workforce upskilling, primarily as a co-
benefit  of  deploying  innovative  climate  technologies,  with  training  and  capacity-building 
frequently cited by beneficiaries. 

By  positioning  the  EU  at  the  technological  frontier,  generating  demonstration  effects,  and 
building  industrial  ecosystems  around  clean  technologies,  the  Fund  strengthens  strategic 
autonomy and knowledge spillovers across the EU. However, its contribution to social and 
regional  cohesion  largely  depends  on  a  project's  location  and  its  alignment  with  local 
development strategies, suggesting that cohesion outcomes could be enhanced through more 
explicit territorial considerations. 

To  fully  realise  its  leveraging  potential  and  maximise  its  impact,  the  Fund  must  address 
systemic misalignments between the design of its calls and the risk profiles of proposals and 
improve coordination among EU, national, regional and private funding sources. 

4.3.  Is the Fund still relevant? 

The Fund’s objectives remain relevant in today’s climate and technology context. They 
are aligned with EU climate and industrial policy priorities, provide critical support for hard-
to-abate  sectors,  and  respond  to  the  pressing  need  to  scale  up  innovative  technologies.  By 
combining a technology-neutral design with targeted instruments when required, the Fund has 
positioned itself as a mechanism for bridging high-risk financing gaps at an industrial scale. 
The  persistent  underfunding  of  clean  technologies,  the  evidence  of  demand  for  the  Fund’s 
grants, and the importance of first-of-a-kind projects to lead the way for the climate transition 
confirm its continued fit with both current and foreseeable needs. 

At the same time, the Fund’s relevance is tempered by certain design frictions: 

–  While safeguards against funding uncertain projects are expected, unsuccessful applicants 
noted  that  strict  financial-maturity  requirements  can  disadvantage  SMEs  and  higher-risk 
innovations, limiting access for smaller actors. 

–  Some  sectors  remain  more  represented  in  the  Fund’s  portfolio  (Figure  7).  The  perceived 
concentration of support in the hydrogen and CCS sectors also raises questions about the 
balance of support between eligible sectors. 

The Fund’s continued relevance will depend on sustaining its flexible, broad call structure and 
strengthening  complementarity  with  other  EU  instruments,  such  as  Horizon  Europe,  whose 
early-stage  research  and  demonstration  projects  can  progress  to  the  Fund  once  their 
technologies reach higher market maturity. The scale of future investment needs, the risks of 
fragmented national approaches, and the levels of global competitiveness further underline the 
necessity of coordinated EU-level action. 

4.3.1.  EU climate and energy policy objectives  

The Fund broadly aligns with the decarbonisation needs of European industry but does not yet 
fully address the scale and diversity of these needs: 

53 

 
 
–  The Fund is particularly relevant for large-scale, capital-intensive projects at demonstration 
and early deployment stages. Its technology-neutral scope allows it to align with sectoral 
priorities across hydrogen, CCS, cement & steel, and other hard-to-abate sectors. Each call 
states how it aligns with EU policy objectives. 

–  The Fund’s ability to meet industry needs remains constrained by its financial design and 
limited scale relative to  demand  (as  evidenced by the oversubscription rates presented in 
Section 3.2). 

Although in its early phase, the Fund contributes to several climate policy targets relevant to 
the EU’s decarbonisation and innovation needs through the implementation of projects across 
various sectors: 

–  The  Net-Zero  Industry  Act aims to  scale net-zero industrial  capacity, with the 
Fund directly supporting its objectives through a dedicated EUR 1.4 billion topic 
for clean tech manufacturing under the IF23 Call. To date, the Fund has built a 
strong portfolio of projects advancing EU net-zero manufacturing, with 25 new 
clean tech manufacturing projects selected during the IF23 Call and 15 previously 
funded projects focused on manufacturing plants for energy storage, renewables, 
and energy-intensive industries:   This brings the Fund’s total support for EU net-
zero  manufacturing  to  EUR  2.4  billion,  targeting  8.1  GW/year  of  solar 
photovoltaic capacity and 11.6 GW/year of electrolyser production by the end of 
2024. 

–  Since 2020, 41 industrial carbon management projects have received over EUR 
5 billion, enabling up to 18.6 mt per year of CO₂ capture (37 % of the Net Zero 
Industry Act’s CCS target) and 11.7 mt per year of CO₂ injection capacity (23% 
of the injection target). 

The Fund aligns with the EU’s renewable energy goals, as outlined in the revised Renewable 
Energy  Directive,  the  European  Wind  Power  Action  Plan,  and  the  EU  offshore  renewable 
energy ambitions, by accelerating targeted technology deployments to boost renewables in the 
electricity mix and enhance energy security. By the end of 2024, the Fund supported 11 wind 
and wind manufacturing projects (EUR 375 million), 14 solar and solar manufacturing projects 
(EUR 607 million), 5 hydro and ocean energy projects (EUR 118 million), and 1 geothermal 
project (EUR 92 million). 

The  REPowerEU  plan  highlights  RFNBO  hydrogen  as  a  climate-neutral  option  for  hard-to-
decarbonise  sectors.  The  Fund  contributes  to  delivering  on  the  EU  hydrogen  strategy  by 
supporting hydrogen, notably through two dedicated auctions (IF23 and IF24). By the end of 
Q1 2025, 27 funded projects had the capacity to produce more than 750 kilotonnes of RFNBO 
and low-carbon hydrogen per year.  

The Fund also supports the development of alternative fuels, in line with ReFuelEU Aviation 
and  FuelEU  Maritime,  with  EUR  1.6  billion  awarded  to  fuel  projects,  including  EUR  612 
million  for  fuel  produced  exclusively  for  the  transport  sector.  These  include  14  projects  in 
hydrogen (EUR 522 million), 5 in e-methanol (EUR 273 million), 3  in ammonia (EUR 530 
million), 2 in sustainable aviation fuel (EUR 206 million), 2 in e-methane (EUR 87 million), 
and  1  in  bio-LNG  (EUR  4  million).  Additionally,  8  mobility  projects  planned  to  avoid  27 
mtCO2e. These include 6 projects in the maritime sector receiving dedicated support of EUR 
211 million and EUR 95 million for a project of electric aircraft.  

54 

 
 
The relevance of the Fund’s objectives at the national level emerges as generally strong, though 
it varies depending on the depth and design of domestic climate and energy policies. The Fund’s 
objectives  are  broadly  relevant  at  the  national  level,  aligning  with  core  industrial 
decarbonisation  priorities  and  complementing  national  climate  legislation  and  funding 
schemes. In countries with limited resources, the Fund often plays a critical enabling role. In 
contrast,  in  countries  with  stronger support frameworks, it adds value primarily by bridging 
large-scale financing gaps and signalling EU-wide priorities. 

4.3.2.  Mechanisms to ensure continued relevance 

The Fund is most effective in directing resources to hard-to-abate, capital-intensive industries, 
where GHG emissions reductions are both critical and costly. The introduction of dedicated 
tracks and sectoral allocations has further sharpened this focus, while efforts to consider broader 
climate impacts extend its reach. Yet, gaps remain, as underrepresented areas still face barriers 
to participation. 

In terms  of promoting innovation, the  Fund has become a central  instrument for supporting 
first-of-a-kind  projects  and  de-risking  breakthrough  technologies  at  the  EU  level.  Its 
technology-neutral and flexible design accommodates a wide variety of innovation pathways, 
as confirmed by industry stakeholders and beneficiaries. 

The Fund’s objectives are designed to adapt to future needs and emerging issues, but sustained 
flexibility and adaptability will require ensuring that structural rules do not narrow the space 
for  diverse  innovation  pathways.  The  Fund  ensures  selection  of  the  most  relevant  projects 
through its award criteria (see 3.1.1 Calls for ‘regular’ grants): 

–  To ensure alignment with the most relevant innovations in each technology and sector, the 
Fund  relies  on  external  expert  evaluators  to  design  and  evaluate  all  award  criteria.  For 
instance, selected specialists are hired to evaluate the ‘degree of innovation’ criterion in calls 
for  ‘regular’  grants  across  all  technology  areas  and  to  assess  each  project’s  novelty, 
scalability, and transformative potential. It is the criterion with the highest number of points 
available  in  each  call.  This  approach  ensures  that  only  the  most  impactful  and  forward-
looking solutions receive support.  

–  The ‘cost efficiency’ criterion measures the ratio of the requested grant to the absolute GHG 
emissions  avoided.  This  approach  ensures  that  public  funding  is  allocated  to  the  most 
impactful  and  economically  viable  decarbonisation  technologies,  maximising  the  Fund’s 
cost-efficiency, with significant variation between technologies (Table 5). While all funded 
projects meet the minimum thresholds, differences across sectors highlight that some require 
higher investments than others.  

These  differences  underscore  that  all  technologies  play  a  role  in  the  EU’s  decarbonisation 
strategy, and that the Fund’s threshold-based system ensures that only the most viable projects 
within each sector are selected. This system allows the Fund to remain technology-neutral and 
support a diverse portfolio of technologies, from mature solutions with high cost-efficiency to 
emerging innovations that, despite higher costs, are essential for long-term climate targets. 

55 

 
 
Table 5: Average cost-efficiency per sector 

Sector 

Average cost-efficiency 
score 

Manufacturing of components for energy intensive industries 

CO2 transport and storage 

Aviation 

Road transport 

Manufacturing of components for renewable energy or energy 
storage 

Manufacturing of components for energy storage 

Manufacturing of components for renewable energy 

Manufacturing of components for production of renewable energy 
or energy storage 

Cement & lime 

Chemicals 

Non-ferrous metals 

Use of renewable energy outside Annex I 

Maritime 

Refineries 

Other 

Glass, ceramics & construction material 

Hydrogen 

Biofuels and bio-refineries 

Renewable heating/cooling 

Iron & steel 

Wind energy 

Other energy storage 

Solar energy 

Pulp & paper 

Intra-day electricity storage 

Hydro/Ocean energy 

11.61 

11.50 

11.50 

11.50 

11.33 

11.25 

11.21 

9.85 

9.80 

9.07 

8.81 

8.60 

8.44 

8.25 

8.17 

7.91 

7.67 

7.31 

7.30 

6.96 

6.33 

6.06 

5.80 

5.75 

5.74 

4.45 

Geothermal energy 
The Fund’s objectives demonstrate a strong degree of anticipation of future needs, as they are 
regularly  updated  in  response  to  EU  climate  policy  reforms,  stakeholder  consultations,  and 
foresight on industrial priorities. Indeed, the Fund is structurally positioned to anticipate and 
remain  relevant  to  evolving  policy  and  market  contexts.  For  instance,  the  Fund  has 
demonstrated practical adaptability by expanding its scope to include emerging sectors, such as 
maritime,  aviation,  and  manufacturing,  when  new  decarbonisation  priorities  arose.  The 

4.33 

56 

 
 
flexibility of annual calls, combined with continuous stakeholder engagement and expert-driven 
assessments,  positions  the  Fund  to  effectively  address  evolving  challenges  while  remaining 
aligned with the EU’s long-term climate goals. 

At the same time, the flexibility of the Fund’s objectives is, in practice, moderated by design 
constraints.  Indeed,  strict  procedures,  maturity  requirements,  and  limited  scope  for  more 
disruptive or less mature innovation restrict the Fund’s full adaptability. 

Stakeholder  consultations,  experts’  input,  and  knowledge  sharing  mechanisms  are  used 
iteratively to ensure the Fund’s continued relevance: 

–  Stakeholder  workshops  gather  insights  on  decarbonisation  challenges  from  industry, 
public  authorities,  and  other  key  actors,  while  the  IFEG  provides  sector-specific 
guidance on emerging priorities and upcoming call design. This engagement ensures 
that the Fund remains responsive to real-world needs. 

–  Specific knowledge sharing requirements are also put in place, mandating that funded 
projects disseminate lessons learned, best practices, and technical insights through open 
and  closed  events,  annual  reports,  and  public  data  repositories  (e.g.  CINEA’s 
knowledge sharing webpage). These activities not only accelerate commercialisation 
and scalability of supported technologies but also inform future funding priorities by 
identifying gaps and opportunities in the decarbonisation landscape. 

–  Stakeholder feedback is also systematically incorporated into call planning and budget 
allocation,  ensuring  that  funding  reflects  evolving  technological,  economic,  and 
regulatory conditions. 

While  this  consultative  approach  aligns  the  Fund  with  current  decarbonisation  challenges, 
further structured analyses enhance its long-term strategic responsiveness: 

–  DG CLIMA and CINEA reinforce this alignment through regular portfolio analyses, 

monitoring of key performance indicators, market trends, and policy alignment. 

–  For instance, DG CLIMA reports annually to the Climate Change Committee on the 
implementation  of  the  Fund  via  annual  progress  reports,  while  CINEA  collects 
implementation feedback from projects for annual knowledge sharing reports. 

5.  CONCLUSIONS 

The  Fund’s  core  instruments  demonstrate  a  potential  to  achieve  the  Fund’s  objectives 
effectively, efficiently and coherently: 

–  The Fund's attractiveness stems from its unique position to bring innovative low-carbon 
technologies  to  commercial  application  and  to  overcome  technical,  commercial, 
regulatory, and infrastructural risks. Considering the benefit-cost ratios both regarding 
EU costs and total costs (including public and private financing), the Fund’s efficiency 
is high. 

–  The  effective  implementation  of  calls  for  proposals  enabled  the  identification  and 
support  of  projects  with  significant  potential  for  GHG  emissions  reduction  and 
mobilised substantial additional investment showcasing the Fund’s effectiveness. 

57 

 
 
–  Although  it  is  too  early  in  the  Fund’s  implementation  to  draw  conclusions  on  its 
efficiency in reducing GHG emissions, the mechanisms in place to mitigate the risk of 
overestimations  indicate  that  significant  expected  GHG  emissions  reductions  will 
materialise. 

–  Supported projects represent a diverse portfolio across sectors and technologies, driving 
large-scale  industrial  decarbonisation  and  the  deployment  of  key  mitigation 
technologies. 

–  Despite  their  early  stage,  ‘as-a-service’  schemes  and  blending  operations  enable  the 

mobilisation of substantial additional investment, showing future potential. 

–  Supporting and advisory activities (PDA, technical assistance) are consistent with the 

Fund’s objectives. 

–  Communication and knowledge sharing activities have expanded the Fund’s visibility, 

strengthened policy feedback, stakeholder engagement, and peer learning. 

–  The  Fund’s  disbursement  processes  are  transparent  and  well-controlled,  with 

milestone-based payments ensuring accountability. 

–  Application,  selection,  and  grant  preparation  procedures  are  transparent  and  robust. 
Monitoring  and  reporting  requirements  ensure  accountability.  The  milestones-based 
approach  enables  CINEA  to  help  project  developers  overcome  implementation 
challenges and act as a partner toward successful completion.  

–  The  IFEG  is  a  successful  example  of  stakeholder  engagement,  involving  national 
authorities  and  industry  representatives  in  governance  without  creating  substantial 
administrative costs. It provides a platform for receiving market feedback, especially 
on methodologies for GHG emission reductions and relevant costs.  

–  Evidence  points  to  complementarities  with  other  EU  financing  instruments,  such  as 

Horizon Europe, STEP, CEF, InvestEU and the Modernisation Fund. 

–  While evidence indicates sectoral and geographical imbalance in the portfolio, it also 
reflects the technological and commercial maturity of projects across various locations 
and sectors. 

However, operational and financial challenges impact the Fund’s efficiency: 

–  A high oversubscription rate leaves many proposals unfunded.  

–  At 

the  application  stage,  methodological  complexity  (particularly 

the  GHG 
methodology) and documentation requirements create heavy workloads for evaluators 
and applicants, especially SMEs, even if they are consistent with high grant amounts 
and help ensure the fair selection of the best proposals. 

–  The 60 % funding rate ceiling is perceived as adequate by most stakeholders, although 

views depend based on technology, maturity, and capital requirements.  

–  The  milestone-based disbursement approach  causes strain  for some capital-intensive 

projects and SMEs. 

58 

 
 
–  Monitoring and reporting requirements remain resource-intensive for both beneficiaries 
and  CINEA.  At  the  same  time,  certain  useful  data  for  evaluating  the  Fund’s 
performance are not collected (e.g. job creation and gross added value). 

–  While promising, it is too early to draw valid conclusions on the impact of supporting 

and advisory activities (PDA, technical assistance). 

–  Although the Fund effectively serves as a follow-up to Horizon Europe, synergies with 

other Union programmes could be further exploited. 

Simplification  measures  have  already  been  implemented  and  are  beginning  to  show  results: 
reducing  the  number  of  cost  calculation  approaches  from  five  to  two,  automating  financial 
templates  through  the  Financial  Information  File,  providing  clearer  guidance  for  GHG 
emissions  reductions  and  business  plan  templates,  and  simplifying  rules  for  the  hydrogen 
auction. Still, further potential remains, for instance by tailoring and simplifying application 
rules for SMEs, introducing staged applications (i.e. pre-check and full evaluation), requiring 
shorter, less overlapping templates during application, and more proportionate reporting during 
implementation  (notably  for  knowledge  sharing).  Stakeholders  also  cited  the  need  for  more 
user-friendly digital tools, including reporting portals enabling automatic data reuse to avoid 
repetitive  data  entry (68).  These  adjustments,  if  implemented,  could  better  align  the  Fund’s 
procedures with project needs while maintaining transparency and oversight. 

In  terms  of  coherence,  the  Fund  shows  strong  alignment  with  EU  climate  and  industrial 
policies.  Its  flexible  design  demonstrates  a  high  degree  of  adaptability  to  evolving  policy 
priorities and responsiveness to market realities, keeping it relevant and confirming its strategic 
role in delivering the EU’s decarbonisation objectives.  

Finally,  the  Fund  brings  benefits  that  could  not  have  been  achieved  without  the  EU’s 
intervention: 

–  The  Fund’s  answers  to  the  necessity  of  EU-level  coordination  to  complement 
fragmented  national  support  and  prevent  widening  disparities  between  countries. 
Evidence shows that national schemes alone cannot address underinvestment or ensure 
cohesion in industrial transition. 

–  The Fund’s catalytic effect on technological progress is evident in hard-to-abate sectors. 
By  de-risking  early  deployment,  it  advances  technologies  from  demonstration  to 
commercial  scale,  accelerates  replication,  and  generates  spillovers  that  national 
schemes alone could not achieve. Beneficiaries confirm its catalytic role in bridging 
funding gaps for capital-intensive innovations that would not otherwise materialise. 

–  By  fostering  EU-wide  competition,  the  Fund  drives  excellence,  cost-efficiency,  and 
technological ambition. While most projects are implemented nationally, competition 
raises standards and investor confidence, accelerating deployment timelines.  

–  Knowledge sharing requirements mandate the spillover of lessons learned and further 

accelerate the dissemination of technologies across Europe. 

(68)  Beneficiaries’ survey (Q41). 

59 

 
 
 
–  AaaS  has  demonstrated  clear  efficiency  gains  for  national  authorities  and  applicants 
alike, through the centralisation and standardisation of project selection, the reduction 
of duplication and timelines and the acceleration of State aid procedures thanks to the 
alignment of Fund’s auctions design with the CEEAG. 

6.  LESSONS LEARNED 

If  the  Fund  is  crucial  to  supporting  innovative,  first-of-a-kind  technologies  in  sectors  that 
currently lack  a technically and economically viable business  case, the evaluation  identified 
several areas for improvement. 

Resource allocation and portfolio diversification 

The evaluation highlighted an imbalance in project representation across countries, sizes and 
sectors  in  the  portfolio.  Although  a  variation  is  to  be  expected,  some  considerations  could 
accommodate a more diverse portfolio: 

–  Increased Fund resources, coupled with diversified instruments, such as thematic calls and 
topics and bonus points in the award criteria, help expand access, particularly for smaller 
countries, emerging sectors, and small-scale projects and SMEs  

–  If introduced, dedicated  measures must be accompanied by  tailored  guidance  and careful 
budget sizing to ensure a fair and balanced uptake across sectors and sizes. The Fund has 
already shown that dedicated topics or bonus points for technologies such as manufacturing, 
hydrogen or maritime can increase the number of projects in these sectors.  

Considering future calls specifically for SMEs could allow a simplified application process 
beyond  what  is  feasible  for  a  dedicated  topic  under  the  same  call.  At  the  same  time,  the 
diversification of calls should be coupled with an increased fund size to avoid creating too 
small pools of funds or unnecessary internal administrative burden. 

–  Project  development  assistance  and  technical  assistance  could  be  further  developed  to 

support the least mature innovative solutions. 

–  The  ‘as-a-service’  schemes  could  ensure  an  even  broader  mix  of  technologies  and 
geographies  in  the  portfolio.  However,  the  future  success  of  these  schemes  is  largely 
dependent  on  the  availability  of  national  budgetary  resources  and  commitments.  Further 
promoting the ‘as-a-service’ and supporting national authorities in the administrative process 
will be material.  

–  Leveraging  and  strengthening  existing  mechanisms,  such  as  the  National  Contact  Points 
network, the Innovation Fund Expert Group, and regular stakeholder consultations,  could 
ensure  continued  alignment  with 
the  EU’s 
decarbonisation objectives.  

technologies  needed 

to  achieve 

the 

–  Particularly for small-scale projects and SMEs, the Fund’s leverage could be increased by 
reducing  administrative  burden  during  application  and  implementation.  For  instance, 
simplified  evaluation  procedures,  improved  digital  tools,  and  proportionate  reporting 
obligations could ease this burden. However, any change in the application, evaluation and 
reporting phases must balance simplification with robust accountability. 

60 

 
 
Balancing data needs with administrative efficiency 

The evaluation highlighted several data gaps leading to methodological limitations. At the same 
time, administrative burden, especially for SMEs, is one of the Fund’s main challenges. The 
Fund  needs  to  balance  the  identified  needs  for  further  data  collection  and  reporting  with 
administrative efficiency, so that simplifications in the evaluation and reporting process do not 
come at the expense of institutional resilience. Future growth will require adequate staffing and 
stronger investment in IT tools. 

The  evaluation  underscores  the  need  for  smarter  data  collection  strategies  that  maximise 
insights without increasing burdens: 

–  Integrating  cost-tracking  into  existing  surveys  and  stakeholder  consultations  (rather  than 
introducing  new  reporting  requirements)  could  help  fill  identified  data  gaps  (e.g.  on 
administrative costs) while leveraging current processes. 

–  A  sustained  focus  on  high-impact  indicators  (e.g.  expected  GHG  emissions  avoidance, 
average  time  to  financial  close)  will  ensure  that  data  improvements  align  with  practical 
constraints. 

Furthermore,  knowledge  sharing,  data  collection  and  processing  practices  are  currently 
predominantly  manual,  relying  on  Excel  spreadsheets.  This  approach  poses  significant 
challenges  regarding data quality  and reliability, scalability,  data management and reporting 
efficiency. The fragmented and uncoordinated nature of data repositories and procedures also 
impairs effective project monitoring and the ability to extract and analyse relevant data, which 
is  critical  for  policy  feedback.  Digitalisation  will  be  key  in  ensuring  the  balance  between 
strengthening data collection and reducing administrative strain: 

–  The forthcoming Knowledge Sharing Digital Solution (KSDS) should help standardise and 
streamline data collection. This digital platform aims to address the challenges arising from 
limitations  observed  during  the  evaluation  and  thus  to  facilitate  effective,  reliable  and 
sustainable data collection, processing, visualisation, knowledge extraction and sharing. The 
tool should be able to improve, amongst others, the timely delivery and analysis of project 
implementation data to support strategic policy formulation and comprehensive oversight of 
the  portfolio,  further  ensuring  the  Fund’s  relevance  and  EU-added  value,  and  a  better 
understanding of the Fund’s effectiveness and efficiency.  

–  The KSDS should also aim to alleviate administrative burden for beneficiaries. It could do 
so  by  extracting  data  from  all  available  deliverables  and  documents  associated  with  the 
project/beneficiary  and  feeding  it  into  other  tools  and  reports  via  soft  links  (special  files 
pointing to other existing files). Such a tool would ensure that beneficiaries do not have to 
enter  the  same  information  multiple  times.  The  feature  of  simplified  reporting  for 
beneficiaries should be seen as a priority for the tool, especially to accommodate for SMEs.  

Despite  forthcoming  solutions,  some  data  gaps  may  remain  unaddressed.  For  instance, 
indicators of economic performance (e.g. such as number of jobs created or gross added value) 
and more accurate information on complementarities with other EU instruments would require 
additional effort from projects to collect and report on. Less quantifiable indicators, such as 
technological spillover and learning effects, might also be difficult to collect without imposing 
significant additional burden. 

61 

 
 
Although a difficult balancing act, developments to enhance data quality must go hand-in-hand 
with reduced administrative burden to remain effective and inclusive.  

Continued project support and implementation 

Premature terminations are rare (8 % of awarded proposals). They are often the consequence 
of unforeseeable external challenges connected to market conditions. At this stage of the Fund’s 
implementation, it is too early to draw any conclusions on this rate. However, the continued 
monitoring of project challenges and mitigation strategies (through annual knowledge sharing 
reports for instance) could inform the analytical needs of future evaluations. Although largely 
dependent  on  external  factors,  some  measures  could  be  considered  to  support  projects’ 
successful implementation: 

–  Greater flexibility in funding rules, including earlier or phased disbursements, would help 
balance innovation support with financial realism. However, this more proactive approach 
would need to account for the increased risk of funds disbursed without actual results. 

–  Introducing a completion guarantee for large-scale projects, similar to auctions, could ensure 
that only the most serious and mature proposals are selected, avoiding blocking budgets for 
projects withdrawing before financial close. 

–  More  generous  and  accessible  cumulation  rules  could  also  ease  liquidity  constraints  and 

improve the project’s financial viability while maintaining fiscal discipline. 

Despite an effective allocation of resources for calls for proposals (through frontloading) and 
grant disbursements (through annual budgetary instalments), there is room for improvement, 
notably on the management of reserve lists (to increase the speed of budget re-allocation) and 
on  maximising  the  opportunity  costs  of  unused  funds.  Increased  digitalisation,  through  for 
example  the  KSDS  tool,  could  be  considered  to  make  internal  processes  more  efficient  in 
identifying reallocation of unused funds. 

For auctions, adequate safeguards against non-delivery will continue to be necessary to ensure 
their future success. Completion guarantees could remain to support the Fund’s credibility. As 
competitive  bidding  has  proven  efficient  and  effective  to  support  hydrogen      producers,  the 
Fund could be used to support other sectors.  

Bridging  mechanisms,  such  as  the  STEP  Seal,  create  a  more  integrated  EU  climate  finance 
architecture. Further exploring blending operations and combining Fund grants with another 
funding  instrument  could  help  achieve  faster  implementation  and  mobilise  further    private 
capital towards green innovation.  

62 

 
 
Annex I  Procedural information 

Lead DG: Directorate General for Climate Action (DG CLIMA) 

Decide reference: PLAN/2024/864 

No exceptions from the usual ‘better regulation’ procedural requirements were made. 

1.  ORGANISATION AND TIMING 

On 25 March 2024, DG CLIMA sent a note inviting 17 Commission services to participate in 
an Inter-Service Group (ISG) to steer the preparation of the first evaluation of the Innovation 
Fund and the Modernisation Fund. 

By  the  end  of  April  2024,  all  services  invited  had  nominated  representatives  for  both 
evaluations: 

–  Budget (DG BUDG) 

–  Competition (DG COMP) 

–  Defence Industry and Space (DG DEFIS) 

–  Economic and Financial Affairs (DG ECFIN) 

–  Employment, Social Affairs and Inclusion (DG EMPL) 

–  Energy (DG ENER) 

–  Environment (DG ENV) 

–  Financial Stability, Financial Services and Capital Markets Union (DG FISMA) 

–  Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) 

–  Joint Research Centre (JRC) 

–  Legal Service (SJ) 

–  Maritime Affairs and Fisheries (DG MARE) 

–  Mobility and Transport (DG MOVE) 

–  Regional and Urban Policy (DG REGIO) 

–  Research and Innovation (DG RTD) 

–  Secretariat-General (SG) 

–  Reform and Investment Task Force (DG SG REFORM) 

63 

 
 
Representatives  from  DG  CLIMA’s  better  regulation  unit  and  the  executive  agency  for 
European climate, infrastructure and environment (CINEA) were invited to attend meetings and 
copied in communications. 

Although the ISG was consulted on both evaluations concurrently, the next table describes only 
the organisation and timing of the Innovation Fund evaluation. 

Milestone 

Establishment of the ISG 

Kick-off meeting with contractor (Ramboll) 

Creation of ISG’s collaborative workplace, invitations to 1st ISG 
meeting 

Draft ‘call for evidence’ 

Draft methodology (Ramboll) 

1st ISG meeting (‘call for evidence’ and consultation strategy) 

Launch of the ‘call for evidence’ and public consultation 
questionnaire on Have your say 

Close of the public consultation 

Publication of factual summary report and contributions to the 
public consultation questionnaire on Have your say 

2nd ISG meeting (evaluation updates, next steps) 

Draft evaluation study including synopsis report (Ramboll) 

Upstream RSB meeting 

Draft study shared with ISG for review 

‘Reality check’ 

Presentation of the evaluation preliminary findings to Innovation 
Fund Expert Group 

Final study including synopsis report (Ramboll) 

3rd ISG meeting (final study, draft evaluation report) 

Submission of documents to RSB  

RSB hearing 

Interservice Consultation end 

Publication 

Date 

25 March 2024 

14 November 2024 

6 January 2025 

6 January 2025 

15 January 2025 

28 January 2025 

15 April 2025 

08 July 2025 

04 September 2025 

8 October 2025 

14 October 2025 

27 October 2025 

12 November 2025 

13 November 2025 

12 December 2025 

22 January 2026 

18 February 2026 

11 March 2026 

15 June 2026 

15 July 2026 

2.  CONSULTATION OF THE REGULATORY SCRUTINY BOARD 

The  evaluation  was  selected  for  scrutiny  by  the  Regulatory  Scrutiny  Board.  Following  the 
hearing with the Board taking place on 11 March 2026, Board issued a positive opinion with 
reservations  on  13  March  2026.  The  comments  received  are  listed  below,  alongside  the 
reference to the section addressed and a summary of the amendments made.  

64 

 
 
 
RSB Opinion point 

SWD section 

Summary of revision 

(1) With the Innovation Fund being a 
the 
instrument, 
performance-based 
report  should  explain  upfront 
the 
different types of instruments and their 
mechanisms (when funds are disbursed 
conditions, 
and 
differentiating  grants  from  auctions 
measures).  
and 

under  which 

supporting 

The  report  should  also  better  explain 
the  mitigating  measures 
to 
address the methodological limitations 

taken 

(2)  The  report  should  clarify  what 
types  of  evidence  have  been  used  to 
analyse  the  Fund’s  effectiveness  and 
efficiency.  

The  report  should  describe  more 
clearly  how  project  withdrawals, 
and 
deviations 
terminations  have  been  interpreted  in 
terms of the Fund’s effectiveness and 
efficiency.  

(amendments) 

It should also analyse more in depth the 
possible  impacts  of  the  challenges 
early 
encountered 
in 
including 
implementation 
delays and their root causes. 

phase, 

this 

include  an 

introduction  of 

The  evaluation  report  has been  revised 
to 
the 
different  types  of  activities  and a  short 
description  of 
implementation 
their 
characteristics,  before  presenting  their 
state  of  play  including  which  activities 
started in 2020 and which were adjusted 
or  added  in  2023.  The  ‘as-a-Service’ 
feature  of  the  IF  (i.e.  ‘Auctions-as-a-
Service’  and  ‘Grants-as-a-Service’)  are 
presented. 
also 

clearly 

more 

The  report  has  been  revised  to  explain 
the  mitigation  measures  applied  and 
how  limitations  have  been  addressed, 
using  elements  from  the  supporting 
study (triangulation of evidence sources, 
validation through ‘reality check’). 

The  report  has  further  clarified  what 
different  types  of  evidence  has  been 
used for the effectiveness and efficiency 
analysis.  

reasons 

The report has further expanded on the 
several 
for  withdrawals, 
deviations  and  terminations,  including 
findings  in  the  Annual  Knowledge 
Sharing  Report  on  projects'  challenges 
and terminations. However, as these are 
often intertwined, their effects were not 
attributed  to  a  single  reason.  At  this 
stage 
programme’s 
the 
implementation,  it  is  too  early  to  draw 
any conclusions from such analysis. 

of 

Section 3.1. 
Activities 

Section 1.2. 
Methodology 

Section 4.1.1. 
Effectiveness 

Section 4.1.2. 
Efficiency 

Section 6. 
Lessons 
Learnt  

65 

 
 
 
 
 
 
 
 
 
 
RSB Opinion point 

SWD section 

Summary of revision 

(3)  The 
report  should  be  more 
informative on the costs for the various 
they  have 
stakeholders  and  how 
evolved  over 
the  period  under 
evaluation.  The  cost-benefit  analysis 
improved.  
should 

be 

should 

avoidance 

The calculation of the expected GHG 
emission 
be 
clarified,  and  the  report  should  not 
conclude on the efficiency of the Fund 
on the basis of such expected emission 
reduction  to  avoid  over-estimating  its 
efficiency. 

the 

The  assessment  of  administrative 
burden regarding both the preparation 
the 
and 
application 
of 
implementation  of 
the  project  by 
beneficiaries, should be reinforced, in 
particular for SMEs. 

Section 1.2. 
Methodology 

Section 4.1.2. 
Efficiency  

Section 6. 
Lessons 
Learnt 

The  analysis  of  efficiency  has  been 
reviewed to include further information 
to  stakeholders,  and  a 
on  costs 
clarification of data gaps and limitation 
in this regard. 

The report clarifies the choice made to 
look  at  potential  GHG  emissions 
avoidance  over  actual  reductions  when 
cost-efficiency. 
assessing 

The  report  has  added  some  further 
information  on  administrative  costs  for 
beneficiaries  during  application  and 
implementation phase. 

(4)  The  analysis  of 
the  Fund’s 
coherence  with  other  programmes, 
such  as  the  Recovery  and  Resilience 
Fund 
(RRF),  Connecting  Europe 
Facility  (CEF),  Horizon  Europe,  as 
well  as  with  national  schemes  should 
be strengthened. 

Section 4.1.3. 
Coherence 

When comparing the Fund’s efficiency 
with  other  EU  programmes  the  report 
has  included  information  presented  in 
the  support  study  on  the  limitations  of 
comparing  these  programmes.  A  short 
assessment 
other 
programmes  could  have  been  more 
appropriate  for  comparison  purposes 
(such as CEF or regional funds) was also 
added. Since all programmes have their 
ideal 
specificities, 
benchmark. 

whether 

none 

an 

of 

is 

The  coherence  chapter  has  been 
amended to further explain how the 'as-
a-Service' 
and 
features 
contribute to the Fund's coherence.  

operate 

66 

 
 
 
 
 
 
  
 
 
RSB Opinion point 

SWD section 

Summary of revision 

the 

(5) The report should make better use 
of  available  data  to  reinforce  the 
analysis of the relevance of the Fund, 
notably  as  regards 
the  focus  of 
supported  projects  in  terms  of  their 
alignment  with 
technologies 
for  decarbonisation.  The 
needed 
assessment  of  needs 
to 
decarbonisation  pathways  should  be 
based 
and 
observational  data,  including  on  the 
continuously updated data on globally 
available 
their 
technologies 
economic viability. 

opinion 

related 

both 

and 

on 

(6)  The  report  should  better  explain 
what  the  lessons  learned  are  for  the 
Fund, 
including  on  simplification 
potential  for  applicants  and  data 
collection  for  the  monitoring  and 
evaluation 
for  systemic 
impacts (catalytic effect, technological 
and 
spillovers, 
relevance. 

including 

learning 

effects) 

The report has further elaborated on the 
various  activities  performed  to  stay 
aligned  with  technologies  needed  for 
decarbonisation, 
further 
explain  how  the  Fund's  award  criteria 
functions in selecting the most relevant 
project in terms of their alignment with 
the 
for 
decarbonisation.  

technologies 

including 

needed 

and 

Relevance 
alignment  with 
technologies needed for decarbonisation 
has  further  been  exemplified  by  an 
additional comparison between relevant 
climate and energy targets compared to 
Fund backed projects' deliverables, such 
as  expected  GHG  emissions,  installed 
renewable energy capacity, NZIA CO2 
injection target and REPowerEU.  

for 

The  lessons  learnt  has  been  further 
to  address  simplification 
expanded 
potential 
further 
and  means 
improvements  in  data  collection  for 
monitoring  and  relevance.  Resource 
allocation  and  portfolio  diversification, 
notably for SMEs, has been highlighted, 
the  balance  between 
as  well  as 
administrative  efficiency  and  further 
data collection.  

Section 3.1. 
Activities 

Section 4.3. 
Relevance 

Section 6. 
Lessons 
Learned 

3.  EVIDENCE USED 

For  desk  research  purposes,  both  quantitative  and  qualitative  data  have  been  used.  The 
evaluation also uses data collected during stakeholder consultations. 

Quantitative data 

The evaluation mainly used publicly available monitoring and reporting data: 

Source 

Reliability 

The programme’s performance 
statement provides an overview of its 
implementation and performance, and 
data on key performance indicators. 

The data published is provided by DG CLIMA annually 
(with quality insurance also provided by CINEA). Annual 
results are compared with targets to assess progress. 
However, there is no baseline data and the nature of these 

67 

 
 
 
 
 
The annual progress reports (2021, 
2022, 2023) are prepared by the 
Commission to report to the Climate 
Change Committee, the EU Council 
and to the European Parliament on the 
progress made on implementation. 

The Innovation Fund project portfolio 
dashboard is an interactive reporting 
platform containing project data. 

The Fund initial Impact assessment 
proposes a list of indicators to monitor 
and evaluate the Fund’s impact and 
information on the NER 300 
programme. 

Country fiches offer an overview of the 
Fund’s implementation by country. 

Project factsheets present key details 
about supported projects. 

Quarterly reports (not publicly 
available) provide data on the portfolio 
of projects with grant agreements in 
force. 

targets is not clear since they depend on subscription to 
calls for proposals and the magnitude of funded projects. 

The reports are prepared by DG CLIMA annually (with 
quality insurance also provided by CINEA). They 
provide figures on KPIs. However, the data from the most 
recent report is showing the picture at end 2024 (due to 
the length of the publication process). 

The dashboard is linked to the corporate IT systems for 
grant management and is thus automatically updated 
based on the info put there. However, the data is not 
always up to date as the system is only updated once a 
process is finalised (such as an amendment) and once all 
the reporting obligations have been closed. 

Although indicators were not quantified for the most part, 
the initial impact assessment provided the baseline 
needed to capture the changes the Fund’s implementation 
brought. The lack of an evaluation of the NER 300 
programme’s operation also limits its utility as a 
benchmark. 

Country fiches are communication products aimed at the 
public. They are only updated after all grant agreements 
for one call are signed. 

Project factsheets are communication products aimed at 
the public. They contain information provided by 
beneficiaries during application. They are updated 
regularly and show the data in line with the dashboard. 

Quarterly reports are prepared by CINEA during its 
reporting exercise to DG CLIMA. They are the most 
accurate source for projects data, although their quarterly 
delivery means that the extracted information always 
refers to the previous quarter. 

Proposal database (not publicly 
available) provide data on all awarded 
and non-awarded proposals, budget 
committed, and project selection 

The proposal database is updated after the evaluation 
results of each call for proposal. It is the reference 
document for all previous applications received. CINEA 
ensures its accuracy. 

The EIB’s financial statements (not 
publicly available) provide information 
on asset management and project 
development assistance. 

Data from other related EU 
programmes (e.g. Horizon Europe, 
Modernisation Fund, European 
Hydrogen Bank) 

Official statistics from the International 
Energy Agency, Eurostat, and the 
European Environment Agency 
provide the latest data on the context 
the Fund  

The EIB reports annually to the Commission on its 
activities. The data is considered reliable. 

As published by the Commission. The data is considered 
reliable. 

As available online. These organisations are considered 
as a reliable independent source of data on the context in 
which the Fund evolves. 

68 

 
 
Qualitative data 

In  its  literature  review,  the  contractor  aggregated  information  from  Fund  documents,  either 
publicly  available  or  provided  by  DG  CLIMA:  financing  decisions,  calls  for  proposals, 
guidance on award criteria, evaluation summary reports, data on risk assessments conducted 
during project selection, quarterly reports, annual progress reports, knowledge sharing reports, 
and the EIB’s annual reports. The contractor also considered sectoral studies (e.g. on market 
failures and funding needs, on market readiness for new technologies). 

Stakeholder consultations 

The  contractor  collected  stakeholder  inputs  during  the  preparation  of  the  supporting  study 
through interviews (of beneficiaries, the Commission, CINEA, the EIB, NCPs, IFEG members, 
national authorities, and evaluators) and surveys (with beneficiaries, unsuccessful applicants, 
Horizon Europe beneficiaries and NCPs). 

4.  USE OF EXTERNAL EXPERTISE 

During the evaluation process, DG CLIMA sought expert advice on several occasions and as 
part of consultation activities (Annex V): 

–  signature of a procurement contract with Ramboll on 28 October 2024, resulting in a 
Support study by Ramboll delivered in December 2025 and published simultaneously 
with the Staff Working Document; 

–  publication of a ‘call for evidence’ and launch of public consultation on Have your say 

on 15 April 2025; 

–  organisation of a ‘reality check’ with selected practitioners on 12 November 2025; 

–  presentation  of  the  evaluation  preliminary  findings  to  the  Innovation  Fund  Expert 

Group on 13 November 2025. 

The supporting study conducted by the contractor will be published on the EU’s Publications 
Office website on Have your say.  

69 

 
 
 
 
 
 
 
Annex II  Methodology and analytical models used 

Throughout  the  evaluation  process,  DG  CLIMA  applied  the  principles  and  procedural  steps 
outlined  in  the  better  regulation  guidelines  and  toolbox  that  were  most  appropriate  for  the 
Innovation Fund’s evaluation. 

Mixed-methods analytical approach 

Mixed  methods  and  triangulation  of  data  sources  were  used  to  perform  the  analysis  of  the 
findings. The mixed methods and data sources included:  

–  An  extensive  literature  review  of  relevant  sources,  including  published  and  ongoing 

work by the Commission and other institutions and stakeholders. 

–  Data collection: For specific data sets (related to project implementation and proposal 
evaluation),  CINEA  was  involved.  The  agency’s  Business  Intelligence  team  first 
extracted  raw  datasets,  which  CINEA’s  project  officers  then  reviewed  for  quality 
assurance. DG CLIMA also performed a quality check before providing the data to the 
contractor. 

–  A comprehensive  consultation strategy including conduct of interviews, surveys and 
project-specific case studies (more details on these activities are presented in Annex V). 

Evaluation results were also tested with stakeholders: 

–  On  12  November  2025,  DG  CLIMA  first  organised  a  ‘reality  check’  with  selected 
practitioners.  The  event  took  place  in  the  Commission’s  premises  and  online.  DG 
CLIMA  invited  a  shortlist  of  stakeholders  who  had  made  the  most  significant 
contributions to the public consultation. Ramboll presented their preliminary findings 
and  posed  questions  to  gather  stakeholders’  feedback.  Following  the  event, 
stakeholders had an additional week to provide written feedback. 

–  On 13 November 2025, DG CLIMA invited Ramboll to give a presentation during an 
IFEG meeting. IFEG members also had an additional week to provide written feedback. 

Methodological strengths and weaknesses 

Robustness of evaluation analysis 

The  evaluation  relies  on  a  well-defined  intervention  logic  that  lays  out  the  causal  relations 
between the different expected outputs, results and impacts of the  Fund, both in terms of its 
actual objectives and in terms of the functioning, governance and processes. The intervention 
logic provided the basis for defining the key sub-questions, judgement criteria / hypotheses, 
and  indicators,  in  line  with  the  evaluation  questions  set  out  in  the  Tender  Specifications.  A 
comprehensive evaluation matrix was developed to guide and structure the systematic analysis 
undertaken in this evaluation. 

Comprehensive evidence base established through a systematic approach to data collection 

A  comprehensive  evidence  base  was  established  through  a  systematic  and  multi-layered 
approach to data collection. Evidence was gathered continuously throughout the evaluation by 

70 

 
 
combining literature and desk reviews, statistical analysis, and stakeholder consultations at both 
EU and EEA country level. This mixed-method design enabled the evaluation team to draw on 
a wide range of quantitative and qualitative inputs and perform robust triangulation, ensuring 
that findings could be cross-validated, inconsistencies identified, and conclusions grounded in 
strong evidence. 

While the methodological approach is robust, some limitations should be acknowledged when 
interpreting findings (see 1.2 Methodology). 

On certain aspects, the contractor did not assess why specific stakeholders raised concerns or 
whether those concerns were valid. In the final evaluation, some of the stakeholder concerns 
reported in the study have been nuanced: 

–  Although  cost-verification  rules  are  often  seen  as  constraints,  they  are  intended  to 
protect  the  Fund  against  non-advancing  (or  ‘ghost’)  projects  and  to  ensure  its 
credibility. 

–  The  Fund  does  allow  eligible  operational  expenditure  within  relevant  costs.  The 
perception of insufficient support for operational expenditure reflects implementation 
experiences  from  early  calls,  where  beneficiaries  reported  that  relevant  costs 
calculations  tended  to  emphasise  capital  expenditure  and  that  milestone  timing 
occasionally created short-term liquidity gaps. 

–  Contrary to what many stakeholders stated, there is some flexibility in the disbursement 
system: up to 40 % of the grant can be disbursed at early milestones, including before 
full operation. 

.

71 

 
 
Annex III Evaluation matrix and details on answers to the evaluation questions 

This  Annex  presents  the  evaluation  matrix,  which  served  as  the  organising  framework  for  the  evaluation,  and  factual  answers  to  the  questions  under  each 
evaluation criterion. The analysis and evidence presented provide the main points substantiating the assessment done in the evaluation report. 

Answers are summarised. For a full assessment, readers can refer to the external support study (Support for the evaluation of the Innovation Fund). 

1.  POINTS OF COMPARISON 

In line with Tool #46, the expected results and impacts of the preferred policy option presented in the Innovation Fund’s impact assessment have been used as 
points of comparison. The table below summarises the points of comparison used to assess the intervention. 

Evaluation criteria 

Points of comparison 

Indicators 

Effectiveness 

/Efficiency 

Coherence 

The Fund’s impact assessment indicates that the Fund’s success 
will be measured by the extent to which supported projects.  

- 
- 

succeed to financial close 
succeed to entry into operation 

deliver planned emission reductions. 

The impact assessment proposed a list of indicators used to 
monitor and evaluate the Fund’s impacts. During the 
evaluation, the hired contractor introduced additional 
indicators to complement the initial list and answer evaluation 
questions. These indicators are presented in Table 1 of the 
evaluation report. 

Because no quantitative targets were assigned to the Fund’s 
objectives, NER 300 is used as a baseline to assess 
performance in some of the points of comparison but not all. 

The impact assessment’s preferred options (timing of payments at 
variable milestones, multiple selection criteria) were identified as 
having a high degree of internal coherence as they were in line 
with the approaches used under other EU programmes (Horizon 
2020, Horizon Europe and InvestEU). 

The Fund’s performance is qualitatively assessed through a 
comparison with other scenarios not retained in the impact 
assessment, which most of the time was the baseline situation 
(NER 300). 

 
 
 
Similarly, a streamlined governance with a public implementing 
body (the EIB or an executive agency) was identified as having a 
high degree of internal coherence as higher synergies could be 
expected from a public operator running other programmes 
funding research or roll-out of low carbon technologies (such as 
Horizon Europe, CEF or InvestEU). 

Although the impact assessment did not identified areas of 
external coherence, the Fund’s performance statements include a 
section on how the Fund contributes to sustainable development 
goals (SDGs 7, 9 and 13) since 2023. 

The subsidiarity arguments put forward before the intervention 
can be found in the EU ETS impact assessment: 

Necessity  of  EU  action:  “Climate  change  is  a  trans-boundary 
problem  and  both  international  and  EU  action  can  effectively 
complement  and  reinforce  regional,  national  and  local  action. 
Increasing  the  2030  target  for  EU  GHG  reductions  will  impact 
many sectors across the EU economy and coordinated action at the 
EU level is therefore indispensable and has a much bigger chance 
of leading to the necessary transformation, acting as a strong driver 
for  cost-effective  change  and  upward  convergence.  Furthermore, 
many  of  the  policy  elements  assessed  in  this  initiative  have  an 
important  internal  market  dimension,  in  particular  the  options 
related to […] the low-carbon funding mechanisms. EU action can 
also inspire and pave the way for the development of market-based 
measures  at  global  level,  e.g.  as  regards  the  maritime  transport 
within IMO.” 

Added value of EU action: “As a carbon market, the ETS 
incentivises emission reductions to be made by the most cost-

73 

EU added value 

As a counterfactual situation is lacking (see limitations), the 
Fund’s performance is assessed as the extent to which: 

- 
- 

these arguments are still valid 
the expected changes resulting from EU action were 
delivered. 

The evaluation also analyses whether any contextual changes 
or other factors affected the assumption that such change could 
only be generated at EU level action. 

 
 
effective solutions first across the activities it covers, achieving 
greater efficiency by virtue of its scale. Implementing a similar 
measure nationally would result in smaller, fragmented carbon 
markets, risking distortions of competition and likely lead to 
higher overall abatement costs. The same logic holds for the 
extension of carbon pricing to new sectors.” 

Relevance 

According to the Fund’s impact assessment, the Fund was 
expected to “address the shortcomings of the NER300 programme 
and provide a better upside potential for projects, limit their 
downside risks, and be administratively simpler”. 

The Fund’s operational objectives were then defined in Delegated 
Regulation 2019/856, Article 3. 

The evaluation assesses how the needs and objectives of the 
Innovation Fund in the current situation compare to the ones 
initially identified. 

The evaluation also looks at how megatrends might have 
impacted the intervention and how the situation is likely to 
develop in the future (following new political priorities or 
external changes). 

The Fund builds directly on the experience gained from the NER 300 programme, which was set up under Directive 2009/29/EC amending the EU ETS Directive. 
NER 300 aimed to support the commercial-scale demonstration of CCS and innovative renewable energy technologies. It was financed through the monetisation 
of 300 million allowances from the New Entrants’ Reserve (69). Two calls for proposals  were launched in 2012 and 2014, distributing funds to a variety of 
renewables projects and one CCS project. 

However, the programme faced significant implementation challenges. The 2008–2009 financial crisis and the collapse in carbon prices that followed reduced 
available revenues and made the business case for CCS projects untenable. Regulatory revisions to the Renewable Energy Directive (70), the slow adoption of 
support schemes, and unfavourable market conditions for decarbonisation projects (e.g. decreasing/low fossil fuel prices) led to significant delays and a high rate 
of project withdrawals. As a result, unspent funds were reallocated to other financial instruments (the CEF Debt Instrument and the InnovFin EDP) and to the 
Fund. 

(69)  2010/670/EU 

(70)  The EU's Renewable Energy Directive (RED) was amended to address GHG caused by indirect land-use change (ILUC). 

74 

 
 
 
 
Reviews by the European Court of Auditors (71) and DG CLIMA (72) highlighted the programme’s shortcomings. NER 300 provided funding tied strictly to 
verified emission reductions but did not address the upfront financial and technological risks inherent to large-scale demonstration projects (unless the Member 
States  were  willing  to  guarantee  the  upfront  funding).  Moreover,  the  rigid  governance  model  offered  little  flexibility  to  adapt  to  changing  market  or  policy 
conditions. 

The Fund was designed to overcome these weaknesses. It introduced milestone-based disbursements, allowing up to 40 % of funding to be paid before projects 
begin delivering verified emission reductions, thereby supporting financial close. Its scope was expanded to new sectors, reflecting the broader decarbonisation 
challenge. Governance was streamlined to reduce administrative complexity. Selection criteria were reoriented to also give weight to innovation, project maturity, 
replicability, and GHG emissions-reduction potential in addition to cost efficiency, which was the sole criterion in the NER 300. Whereas NER 300 applied a 
‘maximum three projects per country’ rule to ensure geographical spread, the Fund allows EU-wide competition, complemented by simplified procedures for 
small-scale projects and targeted technical assistance. These adjustments were informed by extensive stakeholder consultations during the Fund’s design phase 
(73). 

Guidance for reading the evaluation question matrix: 

–  blue text indicates new indicators/sources or modifications to existing ones introduced during the evaluation 

–  strikethrough text indicates indicators/sources initially foreseen in the evaluation matrix but not used in the analysis (or for which no relevant information 

was found) 

2.  EFFECTIVENESS 

Evaluation question 

Evaluation sub-
question 

Indicator 

Points of 
comparison/Judgment 
criteria 

Data source 

1. How successful has the 
Fund been in supporting 
mature projects with 

1.a. Selecting and 
funding mature projects 
- How effective has the 

Number of awarded and non-
awarded proposals 

High innovation levels and 
significant GHG reduction 
potential 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals); 
data on success rate from Horizon Europe, 

(71)  Special report No 24/2018: Demonstrating carbon capture and storage and innovative renewables at commercial scale in the EU: intended progress not achieved in the past decade, 

European Court of Auditors, 2018.  

(72)  NER 300 lessons learnt – Executive summary (2018). 

(73)  Commission Staff Working Document SWD(2019) 85 final – Impact assessment. 

75 

 
 
 
significant potential to 
reduce GHG emissions, 
with the aim of scaling 
up innovative 
technologies, processes, 
or products for 
commercial deployment 
across the EU? 

Fund been in selecting 
and funding mature 
projects with substantial 
GHG reduction 
potential? 

Submitted, eligible and above 
threshold 

Amount of funding committed 
(total amount paid and total amount 
of grants requested) 

Quality of awarded and non-
awarded proposals (award criteria 
scores) 

1.b. Potential to reduce 
GHG emissions - What 
are the potential GHG 
emissions reductions 
from the projects 
funded by the Fund? 

Planned avoidance of GHG 
emissions (mtCO2e) 

Potential of emission reductions if 
the supported technology is scaled 
up 

1.c. Eligible categories - 
How effective has the 
Fund been in selecting 
and funding projects 
within eligible 
categories, i.e. energy-
intensive industries, 
renewables, energy 
storage, industrial 
carbon management, 
net-zero mobility and 
buildings? 

Number of projects (in pipeline, 
under development, operational) 

Planned/installed capacity across 
all eligible categories 

Geographical distribution of 
planned/installed capacity of each 
technology 

Percentage increase of 
planned/installed capacity of each 

76 

LIFE; data from CINEA on project selection 
and funding 

Desk research from qualitative sources: 
aggregate information from Fund documents 
(calls, criteria, evaluation summary reports, 
quarterly and progress reports) 

Surveys: beneficiaries, unsuccessful applicants 
NCPs 

Interviews: beneficiaries, NCPs, the 
Commission, CINEA national authorities, trade 
and business associations, the EIB 

Case studies 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals), 
Innovation Fund dashboard 

Substantial GHG reduction 
potential and achievement 
of targets 

Desk research from qualitative sources: Fund 
documents (e.g. quarterly and progress reports) 

Surveys: beneficiaries unsuccessful applicants 

Interviews: the Commission, CINEA, NCPs 
beneficiaries, national authorities, trade and 
business associations; the EIB 

Substantial contribution to 
energy-intensive industries, 
renewables, energy 
storage, industrial carbon 
management, net-zero 
mobility and buildings 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals) and 
official statistics from the International Energy 
Agency, Eurostat, the Environment Agency 

Desk research from qualitative sources: Fund 
documents (e.g. quarterly and progress reports) 

Surveys: NCPs beneficiaries, unsuccessful 
applicants 

 
 
 
technology per eligible country, as 
a result of funded projects 

1.d. Enabling 
commercial deployment 
- How effective has the 
Fund been in enabling 
the commercial 
deployment of these 
technologies, processes, 
or products across the 
EU? 

Expected duration in years from 
signature to financial close, to entry 
into operation 

Higher TRL after funding 

Successful 
commercialisation and 
broad roll-out of 
technologies without 
significant delays in terms 
of implementation 

1.e. Calls for ‘regular’ 
grants - How effective 
has been the use of calls 
for ‘regular’ grants? 

Number and success rate of 
projects funded through calls for 
‘regular’ grants  

Stakeholders’ views on 
appropriateness of calls criteria 
(e.g. degree of prescriptiveness) 

Planned investments mobilised 

1.f. Competitive 
bidding - How effective 
has been the use of 
auctions? 

Number and success rate of 
projects funded through auctions 

Stakeholders’ views on 
appropriateness of the instrument 

Planned investments mobilised 

77 

High success rate and 
quality of projects funded 
under calls for proposals 
and large contribution to 
the success of Fund (in 
terms of GHG reduction 
potential or upscaling of 
innovative technologies, 
processes or products) 

High success rate and 
quality of projects funded 
under auctions and large 
contribution to the success 
of Fund (in terms of GHG 
reduction potential or 
upscaling of innovative 

Interviews: trade and business associations, the 
Commission, CINEA beneficiaries, national 
authorities, the EIB 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals) 

Desk research from qualitative sources: Fund 
documents (e.g. reporting and progress reports) 
and the International Energy Agency database 
on low-carbon technologies 

Surveys: beneficiaries, Unsuccessful applicants 

Interviews: beneficiaries, national authorities, 
trade and business associations; the 
Commission, CINEA, the EIB 

Case studies 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals); 
Innovation Fund dashboard; data on success 
rate from Horizon Europe 

Desk research from qualitative sources: Fund 
documents (calls, criteria) 

Surveys: beneficiaries, unsuccessful applicants, 
NCPs 

Interviews: the Commission, CINEA 
beneficiaries, national authorities, NCPs, trade 
and business association, the EIB 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals); 
data on success rate from Horizon Europe 

Desk research from qualitative sources: Fund 
documents (calls, criteria) 

 
 
technologies, processes or 
products) 

Surveys: beneficiaries, unsuccessful applicants, 
NCPs 

2. How effective has the 
Fund been in mobilising 
additional EU funding, 
state aid, and private 
investment? 

2.a. Leveraging 
additional EU funding 
(i.e. Horizon Europe, 
IPCEIs, PCIs, 
InvestEU, CEF, EIB 
lending) - How 
successful has the Fund 
been in leveraging 
additional EU funding? 

2.b. Securing State aid - 
How effective has the 
Fund been in leveraging 
State aid for projects? 

2.c. Attracting private 
funding - How 
successful has the Fund 
been in attracting 
private funding? 

Amount of additional EU funding 
leveraged 

Significant increase in 
additional EU funding 

Amount of State aid secured 

Significant increase in 
State aid 

Amount of private funding 
attracted 

Significant increase in 
private funding 

78 

Interviews: national authorities, NCPs, trade 
and business association, the Commission, 
CINEA beneficiaries, the EIB 

Desk research from quantitative sources: Fund 
data (awarded proposals) 

Desk research from qualitative sources: Fund 
documents (reporting documents) 

Surveys: beneficiaries, NCPs, Horizon Europe 
beneficiaries, unsuccessful applicants 

Interviews: beneficiaries, NCPs, the 
Commission - unsuccessful applicants, national 
authorities, trade and business association, the 
EIB 

Case studies 

Desk research from quantitative sources: Fund 
data (awarded proposals) 

Desk research from qualitative sources: Fund 
documents (reporting documents) 

Surveys: beneficiaries, NCPs 

Interviews: beneficiaries, unsuccessful 
applicants, national authorities, NCPs, trade and 
business association, the Commission, CINEA, 
the EIB 

Case studies 

Desk research from quantitative sources: Fund 
data (awarded proposals) 

Desk research from qualitative sources: Fund 
documents (reporting documents) 

 
 
 
Surveys: beneficiaries, NCPs 

Interviews: beneficiaries, unsuccessful 
applicants, national authorities, NCPs, trade and 
business associations; the Commission, CINEA, 
the EIB 

Case studies 

Desk research from qualitative sources: Fund 
documents (reporting documents, data on risk 
assessments conducted during project 
selection), sectoral studies (e.g. on market 
failures and funding needs, on market readiness 
for new technologies) 

Desk research from quantitative sources: 
external data, dashboard, quarterly report, etc. 

Surveys: beneficiaries, unsuccessful applicants - 
NCPs 

Interviews: beneficiaries, the Commission, 
CINEA, the EIB - unsuccessful applicants, 
national authorities, NCPs, trade and business 
associations 

Case studies 

d. Challenges and 
solutions in mobilising 
funding- What 
challenges have been 
encountered in 
mobilising additional 
funding, and how have 
they been 
addressed? (74) 

2.d. Tailoring financial 
support - How well has 
the Fund tailored its 
financial support to 
market needs and risk 
profiles of eligible 
projects? 

Identification of challenges and 
solutions implemented 

Effective identification and 
mitigation of challenges 

Alignment of funded projects with 
priority sectors identified in the 
EU's decarbonisation goals and 
market studies 

Oversubscription rate (overall, per 
call, per sector) 

Ratio of applications received to 
funds allocated 

Percentage of projects awarded 
funding which enter into operation 

Proportion of projects that failed to 
meet milestones or defaulted due to 
risk-related issues 

High satisfaction and 
alignment with market 
needs while ensuring an 
effective assessment of risk 
profiles 

(74)  Challenges already commented under the specific questions on EU additional funding (a), State aid (b) and private funding (c). 

79 

 
 
 
3. How effectively are 
the Fund's revenues 
managed in compliance 
with the EU ETS 
Directive objectives? 

3.a. Sectoral and 
geographical coverage - 
Are the revenues of the 
Fund managed in line 
with the objectives of 
the Directive in terms 
of technology pathways 
and geographical 
coverage? 

3.b. Revenue 
management - How 
transparent is the 
management of the 
revenues for both direct 
and indirect 
management? How well 
do the revenue 
management practices 
for both direct and 
indirect management 
align with the 
objectives of Directive 
2003/87/EC? 

3.c. Efficiency of 
revenue allocation - 
How efficiently are 
Fund’s revenues 
allocated to projects? 

Percentage of funded projects 
classified as high-risk at the time of 
application 

Degree of risk diversification 
across funded projects 

Number of sectors and countries 
covered 

Number of cross-sectoral 
applications 

Number of cross-countries 
applications 

Availability and clarity of financial 
reports (if any) for direct and 
indirect management 

Stakeholders’ feedback on the 
clarity and transparency of revenue 
management (direct and indirect) 

Stakeholders’ feedback on degree 
of alignment with Directive 
objectives 

The management of the 
revenues of the Fund meet 
the objectives of the 
Directive in terms of 
technology pathways and 
geographical coverage 

Desk research from qualitative sources: Fund 
documents (reporting documents) 

Desk research from quantitative sources: 
external data, dashboard, quarterly report, etc. 

Interviews: CINEA, NCPs, the EIB 

High transparency and 
clear reporting, and strong 
alignment and positive 
stakeholder feedback 

Desk research from qualitative sources 

Interviews: national authorities, the 
Commission, CINEA, the EIB 

Proportion of funds allocated 

Time from revenue collection to 
project funding 

Timely and efficient 
allocation of funds 

Desk research from qualitative and quantitative 
sources 

Interviews: beneficiaries national authorities, 
the Commission, CINEA, the EIB 

Case studies 

80 

 
 
3.d. Management of 
financial risks - How 
well are the financial 
risks managed? 

Identification and mitigation of 
financial risks, contingency 
measures in place 

Effective risk management 
and mitigation strategies 

4.a. Representation of 
small and medium 
projects - How did the 
Fund specifically 
support small and 
medium-scale projects? 

Number of small/medium-scale 
projects funded, number of large-
scale projects 

Percentage of small, medium and 
large-scale projects 

Proportional representation 
of small/medium projects 

Desk research from qualitative sources 

Surveys: beneficiaries 

Interviews: the Commission, CINEA, 
beneficiaries national authorities, the EIB 

Case studies 

4. How effectively has 
the Fund implemented 
other mandates under the 
EU ETS Directive? 

4.b. Attention to 
maritime sector - How 
much special attention 
has been given to the 
maritime sector by the 
Fund (e.g. under the 
IF23 Call and IF24 
Auction)? 

4.c. Geographical 
participation - How 
successful has the Fund 
been in increasing 
geographical 
participation balance? 

4.d. Support for CBAM 
- How effective has the 
Fund been in supporting 
projects in sectors 
covered by CBAM? 

Number of maritime projects 
funded 

Amount of funding awarded to 
support renewable hydrogen 
production for the maritime sector 
(IF24 Auction) 

Number of calls dedicated to 
maritime sector 

Significant funding and 
progress in the maritime 
sector 

Geographic distribution of funded 
projects 

Balanced representation 
across European regions 

Desk research from quantitative sources: Fund 
data (awarded and non-awarded proposals); 
other EU funds data; data on success rate from 
Horizon Europe 

Desk research from qualitative sources: Fund 
documents (calls, criteria, progress reports) 

Surveys: beneficiaries, unsuccessful applicants, 
NCPs 

Interviews: beneficiaries, NCPs, trade and 
business associations, the Commission, CINEA 
national authorities, the EIB 

Case studies 

Number and quality assessment 
scores of projects in sectors 
covered by CBAM 

Effective support and 
implementation of CBAM 
projects 

81 

 
 
5. Will the Fund achieve 
its objectives within the 
planned timeline? 

Expected average time from project 
approval to completion 

Projects are expected to be 
completed within their 
expected duration 

Identification of internal factors 
(e.g. technological complexities, 
cash flow issues) causing delays 

Minimal delays due to 
internal factors 

Desk research from quantitative sources: Fund 
data (awarded) 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: beneficiaries 

Interviews: beneficiaries, the Commission, 
CINEA national authorities, trade and business 
associations, the EIB 

Case studies 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: beneficiaries 

Identification of external factors 
(e.g. political uncertainties, supply 
chain disruptions) causing delays 

Minimal delays due to 
external factors 

Interviews: beneficiaries, the Commission, 
CINEA, NCPs national authorities, trade and 
business associations, the EIB 

Case studies 

Desk research from quantitative sources: Fund 
data (awarded) 

Frequency and accuracy of project 
monitoring and reporting 

Effective monitoring and 
timely adjustments 

5.a. Achievement of 
Fund objectives within 
the implementation 
horizon - What are the 
typical timelines for 
projects from approval 
to completion? 

5.b. Internal factors 
causing delays - What 
are the key internal 
factors causing delays 
in project 
implementation? 

5.c. External factors 
causing delays - What 
are the key external 
factors causing delays 
in project 
implementation? 

5.d. Effectiveness of 
timeline management - 
How effectively are 
project timelines 
managed and 
monitored? 

6. How has the 
implementation of 
technical assistance, 
PDA, blending 
operations and AaaS 
improved the Fund's 

6.a. Support from 
technical assistance - 
How has technical 
assistance to NCPs 
supported project 

Number of NCPs receiving 
technical assistance 

Quality and number of guidance 
materials and tools provided to 
applicants 

Improved project 
development and 
implementation 

82 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: NCPs beneficiaries 

Interviews: NCPs beneficiaries, national 
authorities, the Commission, CINEA, the EIB 

 
 
effectiveness in meeting 
its objectives? 

development and 
application preparation? 

Quality and number of Info days 
organised 

6.b. Contribution of 
PDA to project 
readiness - How has 
PDA contributed to 
proposals readiness and 
success? 

6.c. Effectiveness of 
blending operations - 
How effective have 
blending operations 
been in leveraging 
additional funding? 

6.d. Effectiveness of 
’Auction-as-a-Service’ 
scheme - How effective 
has AaaS been in 
facilitating the support 
of national funding for 
Innovation Fund 
projects that could not 
be funded by the Fund 
due to budget 
limitations? 

Number of proposals with PDA 
agreement negotiation, PDA 
execution ongoing, and PDA 
execution completed 

Success rate of proposals receiving 
PDA 

Maturity and yield of proposals 
supported through PDA 

Increased proposal 
readiness and success rates 

Amount of additional funding 
leveraged through blending 
operations 

Significant increase in 
leveraged funding 

Share of Innovation Fund-
positively evaluated projects 
receiving national funding through 
AaaS 

Amount of national funding 
mobilised for such Innovation 
Fund-positively evaluated projects 

Stakeholders’ feedback on whether 
Innovation Fund positive 
evaluation of selected projects 
acted as a driver to unlock national 
funding 

83 

Significant 
complementarity between 
Innovation Fund and 
national funding 

Desk research from quantitative sources: Fund 
data (awarded) 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: unsuccessful applicants beneficiaries 

Interviews: the EIB beneficiaries, national 
authorities, the Commission, CINEA 

Desk research from quantitative sources: Fund 
data (awarded) 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: NCPs beneficiaries 

Interviews: the Commission, CINEA, private 
actors beneficiaries, national authorities, the 
EIB 

Desk research from quantitative sources: Fund 
data (awarded) 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Interviews: national authorities, the 
Commission, CINEA beneficiaries, the EIB 

Desk research from quantitative sources: Fund 
data (awarded) 

Surveys: Beneficiaries 

 
 
 
 
e. Impact on overall 
project success rate - 
What has been the 
impact of these support 
mechanisms on the 
overall project success 
rate? (75) 

6.e. Best practices and 
lessons learned - What 
best practices and 
lessons have been 
learned from the 
implementation of these 
support mechanisms? 
(76) 

7.a. Communication 
with stakeholders - 
How well has the Fund 
communicated its 
objectives, processes, 
and outcomes to 
stakeholders (including 
industry stakeholders 
and eligible countries)? 

7.b. Knowledge sharing 
facilitation - How 
effectively has the Fund 
facilitated knowledge 
sharing among 
stakeholders? 

7. How effective has the 
Fund been in executing 
communication, 
knowledge sharing, and 
publicity activities? 

Stakeholders’ feedback on success 
rate of projects with and without 
these support mechanisms 

Higher success rates for 
projects with support 
mechanisms 

Identification and documentation of 
best practices and lessons learned 

Clear documentation and 
application of best 
practices 

Clarity and frequency of 
communication, stakeholder 
awareness levels 

High clarity and frequent 
communication, high 
stakeholder awareness 

Desk research from quantitative sources: Fund 
data (awarded) 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: beneficiaries, NCPs 

Interviews: beneficiaries, national authorities, 
NCPs, the Commission, CINEA, the EIB 

Desk research from qualitative sources: Fund 
documents (progress reports) 

Surveys: beneficiaries, NCPs 

Interviews: national authorities, NCPs, the 
Commission, CINEA, the EIB beneficiaries 

Desk research from quantitative sources: Fund 
data (awarded) 

Desk research from qualitative sources: Fund 
documents (knowledge sharing) 

Surveys: beneficiaries, unsuccessful applicants, 
NCPs 

Interviews: beneficiaries, national authorities, 
NCPs, trade and business associations, the 
Commission, CINEA, the EIB 

Case studies 

Quality of knowledge sharing 
events 

Number of knowledge sharing 
events per year and number of 
participants 

High quality of events, 
high participation levels 

Desk research from quantitative sources: Fund 
data (knowledge sharing); data from other EU 
programmes such as Horizon Europe 

(75)  This sub-question is redundant as the impact of the different mechanisms is discussed under their respective questions. 

(76)  Best practices and lessons learned are discussed under their respective questions. 

84 

 
 
 
Stakeholders’ awareness on the 
scope, progress and results of 
Innovation Fund projects as 
communicated by beneficiaries 

Stakeholders’ feedback on how 
useful information on projects as 
shared by beneficiaries is for own 
needs (e.g. useful in decision-
making or project planning) 

High reach and 
engagement, positive 
media coverage 

Identification and documentation of 
best practices and lessons learned 

Clear documentation and 
application of best 
practices 

c. Publicity efforts - 
How successful have 
beneficiaries’ efforts 
been in communicating 
accurate and useful 
information about 
Innovation Fund 
projects and their 
outcomes? (77) 

7.c. Best practices and 
lessons learned in 
communication - What 
best practices and 
lessons have been 
learned from the 
communication, 
knowledge sharing, and 
publicity efforts? (78) 

Answers to evaluation sub-
questions 

Indicators 

Results 

EQ1. How successful has the Fund been in supporting mature projects with significant potential to reduce GHG emissions, with the aim of scaling 
up innovative technologies, processes, or products for commercial deployment across the EU? 

EQ1.a - The Fund has 
consistently identified and 
selected proposals that in their 

Number of awarded and non-
awarded proposals 

242 proposals awarded (15 % of total proposals received or 47 % of proposals which 
met all evaluation criteria) 

1347 non-awarded proposals 

(77)  Publicity efforts have been included under communications (sub-question 7.a.). 

(78)  Best practices and lessons learned are discussed under their respective questions. 

85 

 
 
 
 
proposal combine the highest 
levels of innovation, maturity, 
replicability, and cost-
efficiency. Yet, intense 
competition and persistent 
oversubscription left many 
high-quality proposals 
unfunded. 

Submitted, eligible and above 
threshold 

Total amount of funding 
committed (and total amount of 
grants requested) 

1589 proposals submitted 

1342 proposals eligible (85 % of total proposals received) 

517 proposals above threshold (33 % of total proposals received) 

Budget planned: 11.8 billion 

Budget awarded: EUR 12.7 billion 

Budget requested (by eligible proposals): EUR 87 billion 

Quality of awarded and non-
awarded proposals (award 
criteria scores) 

Awarded proposals consistently outperformed non-selected ones across all criteria in 
calls for ‘regular’ grants. 

Awarded projects cluster at the upper end of the innovation score distribution 
(typically above 4), while non-selected proposals scored lower on average. 

Awarded proposals were concentrated in the highest-scoring bands for GHG emissions 
avoidance (around 4 or above). 

In the beneficiaries’ survey, nearly 4 in 5 projects applied at the demonstration or 
scale-up stage (TRL 6-8). In comparison, many respondents to the survey of 
unsuccessful applicants were still at the pilot stage. 

Planned avoidance of GHG 
emissions 

Together, ongoing projects are anticipated to avoid 871 mtCO2e over their first decade 
of operation. 

EQ1.b - The Fund’s portfolio is 
expected to deliver substantial 
GHG emissions reductions 

Potential of emission 
reductions if the supported 
technology is scaled up 

This indicator could not be calculated with the evidence available. The Fund portfolio 
is still largely in demonstration and early deployment phases, and reliable data on 
replication, market uptake, and counterfactual deployment are not yet available. Any 
estimate of scale-up impacts at this stage would therefore be speculative rather than 
evidence-based. 

86 

 
 
EQ1.c - Although the Fund 
supports projects across all 
eligible categories, funding is 
concentrated in energy-
intensive industries. 

Category 

Number 
of 
projects 

Awarded 
funding 
(EUR) 

Before 
financial 
close 

Energy-
intensive 
industries 

Renewable 
energy 

Energy 
storage 

Industrial 
carbon 
management 

Net-zero 
mobility and 
buildings 

114 

42 

24 

21 

7 

6.2 
billion 

1.2 
billion 

739 
million 

3.1 
billion 

362 
million 

84 

27 

15 

20 

7 

Between 
financial 
close and 
entry 
into 
operation 

11 

9 

5 

1 

0 

Operational  Terminated 

8 

2 

3 

0 

0 

11 

4 

1 

0 

0 

These indicators could not be calculated with the available data. The majority of 
projects have not yet reached installation or operation, and comparable national 
baseline data by technology are limited. Attribution of capacity changes to Innovation 
Fund support would therefore be speculative at this stage. 

87 

Number of projects (in 
pipeline, under development, 
operational) 

Planned/installed capacity 
across all eligible categories 

Geographical distribution of 
planned/installed capacity of 
each technology 

Percentage increase of 
planned/installed capacity of 
each technology per eligible 
country, as a result of funded 
projects 

 
 
 
EQ1.d - Even if implementation 
and realised outcomes remain 
limited, given the programme's 
early stage, evidence suggests 
that the Fund has built a strong 
pipeline of projects progressing 
toward future roll-out. 

EQ1.e - Calls for ‘regular’ 
grants have been effective in 
selecting high-quality projects 
(see EQ1.a) and mobilising 
additional investments, but the 
evaluation phase can be 
challenging for both evaluators 
and applicants. 

EQ1.f - Auctions have proven 
effective in driving cost 
competition and market 
discovery, but firm conclusions 
cannot be drawn as auctions 
have only been applied to the 
hydrogen sector, which was in 
transition during the period in 
question. 

Expected duration in years 
from signature to financial 
close, to entry into operation 

Average time to expected financial close: 1.7 years 

Average duration from grant signature to expected entry into operation: 3.7 years 

Higher TRL after funding 

Number and success rate of 
projects funded through calls 
for ‘regular’ grants 

Stakeholders’ views on 
appropriateness of calls criteria 
(e.g. degree of 
prescriptiveness) 

Respondents to the beneficiaries’ survey expect significant commercial impacts, 
though realised outcomes are still limited given the early stages.  

Case studies also suggest TRL advancement: BBRT expects to move from pilot to full 
industrial scale, reaching TRL 9 with its first processed output, while InnoSolveGreen 
progressed from TRL 6–7 to 8–9, demonstrating its replicability in the Baltic region. 

220 proposals awarded out of 1396 proposals received (16 % success rate) 

Stakeholders’ views on the appropriateness of calls’ criteria differ: 

- 

In the beneficiaries’ survey, respondents valued the clarity of the award criteria 
and the support provided by CINEA through info days and the Fund’s website. 

-  Evidence from the public consultation and surveys with unsuccessful applicants 

and NCPs suggests that the award criteria are overly prescriptive. 

-  The two statements do not contradict each other: the criteria can be clear while 

still being prescriptive. 

Planned investments mobilised  EUR 41.8 billion (186 projects) 

Number and success rate of 
hydrogen projects funded 
through auctions 

22 proposals awarded out of 193 proposals received (11 % success rate) 

Stakeholders’ views on 
appropriateness of the 
instrument 

Although stakeholders do not question the appropriateness of auctions, they 
consistently emphasised the need for ongoing monitoring and stronger safeguards to 
ensure that cost competition translates into viable projects. 

Planned investments mobilised  EUR 3.4 billion (6 projects) 

88 

 
 
EQ2. How effective has the Fund been in mobilising additional EU funding, state aid, and private investment? 

Amount of additional EU 
funding leveraged 

EUR 420 million through the EU-Catalyst partnership 

EUR 200 million InvestEU top-up for the IF24 Call 

EUR 45.2 million (4 projects) 

EQ2.a - The Fund has 
developed frameworks for 
complementarities with other 
EU instruments, but actual 
financial leverage has been 
modest. 

Challenges identified 

Solutions implemented 

Although respondents to the public consultation called for more synergies between EU 
funding programmes, NCPs reported limited capacity to advise on combining 
instruments and difficulties in explaining methodological differences between Horizon 
Europe and the Fund. 

Beneficiaries do not consistently differentiate between EU and national/regional 
funding when declaring public investment mobilised in applications and during 
implementation. 

Beneficiaries do not consistently monetise EU support received. 

The Commission introduced recent tools aiming to better connect funding instruments, 
such as more explicit business-case requirements and Coordination and Support 
Actions in Horizon Europe’s 2023-24 work programmes, and the STEP Seal. If 
practical results remain scarce, a few instances have been reported. 

Amount of State aid secured 

EUR 4.1 billion (36 projects) 

EQ2.b - Projects were able to 
secure substantial State aid, but 
leverage depends on the 
national context and on further 
clarification about cumulation 
rules. 

Challenges identified 

National frameworks have a substantial impact on the success of the portfolio, and 
inconsistencies in the interpretation of cumulation rules and occasional withdrawal of 
expected support create bottlenecks. 

Stakeholders warned that cumulation rules are not flexible enough (but also too much, 
depending on the category of stakeholders) and that more guidance is needed. 

Beneficiaries do not consistently differentiate between EU and national/regional 
funding when declaring public investment mobilised in applications and during 
implementation. 

89 

 
 
 
Solutions implemented 

DG CLIMA publishes guidance on cumulation rules in the documents accompanying 
calls, clarifying how combined support should be reflected in applications and assessed 
by national authorities or other EU programme managers. 

Amount of private funding 
attracted 

EUR 45.2 billion in total investments for EUR 11.08 billion in grants, a leverage ratio 
of about 1:4 (roughly EUR 4 of private/public investment for EUR 1 grant) 

EUR 46.1 billion according to data reported by projects (169 projects) 

EQ2.c - The Fund has 
mobilised substantial private 
investment, though some 
barriers still limit its leverage 
potential. 

Challenges identified 

EQ2.d - The Fund has attracted 
demand far exceeding available 
resources, confirming strong 
alignment with market 
priorities but also revealing 
limits in tailoring support to 
diverse project needs and risk 
profiles. 

Solutions implemented 

Alignment of funded projects 
with priority sectors identified 
in the EU's decarbonisation 
goals and market studies 

Oversubscription rate (overall, 
per call, per sector) 

Ratio of applications received 
to funds allocated 

Percentage of projects awarded 
funding which enter into 
operation 

Projects are not commercially viable in the short-term, making them unattractive to 
risk-averse investors. 

Beneficiaries do not consistently report internal corporate financing as ‘additional 
funding’. 

PDA has demonstrably helped bridge some gaps. 

The ‘as-a-service’ scheme and the STEP Seal create new pathways for complementary 
support (although they have yet to be materialised). 

By design, the Fund thus targets sectors identified as having the most substantial 
potential for emissions reduction in the EU ETS Directive. 

Overall: 7.4 (see Table 6 in the supporting study) 

Budget requested by evaluated proposals / budget awarded = 6.8 

Almost a 1:7 ratio (EUR 7 requested for EUR 1 awarded) 

7 % (13 out of 192 projects) 

90 

 
 
Proportion of projects that 
failed to meet milestones or 
defaulted due to risk-related 
issues 

A combination of regulatory, financial, and administrative factors often results in 
delays in achieving milestones. Thus, it is not possible to single-out delays due to risk-
related issues. 

EQ3. How effectively are the Fund's revenues managed in compliance with the EU ETS Directive objectives? 

EQ3.a - The Fund's revenues 
have been managed to ensure a 
broad sectoral and geographical 
scope, in line with the 
objectives of the EU ETS 
Directive. However, funded 
outcomes remain concentrated 
in a few sectors and countries. 

EQ3.b - Revenue management 
is highly transparent and 
consistent, though the scope of 
publicly available information 
is limited. 

EQ3.c - Revenue allocation has 
been efficient in committing 
available resources. However, 
committed resources do not 
guarantee that projects will 
meet milestones and eventually 
receive funding. 

Number of sectors covered 

25 sectors represented in the portfolio 

Number of countries covered 

26 countries represented in the portfolio (out of 30 eligible) 

Availability and clarity of 
financial reports for direct and 
indirect management 

Internal financial reports for direct and indirect management are transparent and clear. 

External transparency depends on information made available by the Commission. 

Proportion of funds allocated 

Over 7 calls for proposals for ‘regular’ grants and 2 auctions, quantitative evidence 
shows that the Fund eventually awarded 107 % of its planned budget. 

91 

 
 
EQ3.d - Financial risk 
management is robust and 
procedurally mature, with 
flexible financing and 
structured safeguards, though 
funding rules and external 
shocks continue to challenge 
projects. 

Strict financial maturity checks during the evaluation phase. 

After selection, a milestone-based payment system provides firm financial discipline 
and protects the Fund against non-advancing projects. 

Identification and mitigation of 
financial risks, contingency 
measures in place 

CINEA also manages risks through structured early-warning tools, including a monthly 
monitoring table and a dedicated internal reporting tool developed outside the 
corporate IT systems (such as Sygma/eGrants) to capture deviations not yet visible 
there. 

Projects at risk are next escalated to DG CLIMA for mitigation or formal amendments. 

Amendments can extend timelines and adjust work plans. 

EQ4. How effectively has the Fund implemented other mandates under the EU ETS Directive? 

EQ4.a - Although procedural 
efforts have been made to 
ensure the representation of 
small- and medium-scale 
projects in the portfolio, the 
financial support they receive 
remains much lower than that 
of large-scale projects. 

EQ4.b - The Fund has given 
dedicated attention to the 
maritime sector by tailoring call 
design, but the number of 
funded projects remains 
modest. 

EQ4.c - The Fund has 
expanded its geographical 
coverage, but awards remain 
concentrated in larger industrial 
economies. 

Number and percentage of 
small-, medium- and large-
scale projects 

62 small-scale projects (33 % of the portfolio) 

43 medium-scale projects (22 %) 

87 large-scale projects (45 %) 

Number of maritime projects 
funded 

Number of calls dedicated to 
maritime sector and awarded 
funding 

9 maritime projects 

1 topic under the IF23 Call – EUR 198 million for 6 projects 

1 topic under the IF24 Auction – EUR 96 million for 3 projects 

Geographic distribution of 
funded projects 

By Q1 2025, projects were awarded in almost all eligible countries but concentrated in 
larger industrial economies (Spain, France, Italy and Germany accounting for almost 
half of the portfolio with 87 projects). 

92 

 
 
EQ4.d - The Fund has strongly 
supported certain CBAM 
sectors, but gaps remain in 
others. 

Number of projects in sectors 
covered by CBAM 

26 hydrogen projects 

16 cement & lime projects 

8 iron & steel projects 

Assessment of quality scores of 
these projects 

Quality scores are slightly below the portfolio average (36 vs 37.5), reflecting 
technological and financial immaturity, especially in hydrogen and cement. 

EQ5. Will the Fund achieve its objectives within the planned timeline? 

EQ5.a - The Fund’s portfolio is 
on track to achieve its 
objectives within the 15-year 
implementation horizon. 
Funded projects are planned 
within reasonable schedules, 
despite deviations and sector-
specific complexity. 

EQ5.b - Delays often arise from 
a combination of financial, 
administrative, and technical 
internal difficulties. 

EQ5.c - Externally, permitting 
and regulatory hurdles are 
recurring causes of delay across 
sectors. Macroeconomic 
instability and market 
immaturity have further 
undermined timelines. 

Expected average time from 
project approval to completion 

Quantitative evidence shows an average planned duration of about 8.8 years, well 
within the implementation horizon (15 years). 

Identification of internal 
factors causing delays 

Difficulties in gathering the evidence needed to validate a milestone. 

Technical redesigns, underestimated costs and governance issues in large consortia 
also compound delays. 

Identification of external 
factors causing delays 

Sector-specific hurdles: complex and unpredictable permitting procedures, lack, 
inadequacy or shortage of needed infrastructure (such as storage capacity and grid 
infrastructure), supply chains uncertainty, lack of EU standards and difficulty securing 
national co-financing. 

Structural challenges: inflation, war in Ukraine, COVID-19, increasing costs, supply 
chain shortages, weak offtake markets, delayed transposition of EU Directives, limited 
infrastructure capacity, policy uncertainty and fragmented implementation of EU 
legislation, immature demand-side incentives, commodity prices volatility. 

93 

 
 
EQ5.d - A robust monitoring 
system provides close oversight 
and timely risk detection. At 
the same time, beneficiaries 
experience reporting 
obligations as burdensome. 

Frequency and accuracy of 
project monitoring and 
reporting 

Project timelines are proactively managed. CINEA monitors projects through 
milestone validation, annual reporting and knowledge sharing deliverables. 

To ensure accuracy, CINEA combines formal reports with frequent informal 
exchanges, risk-based reporting cycles (every six months before financial close, 
annually afterwards) and joint financial–technical oversight. 

EQ6. How has the implementation of technical assistance, PDA, blending operations and AaaS improved the Fund's effectiveness in meeting its 
objectives? 

EQ6.a - Technical assistance 
has enhanced NCPs’ capacity 
and outreach, though its impact 
on application preparation 
remains emergent. 

Number of NCPs receiving 
technical assistance 

Quality and number of 
guidance materials and tools 
provided to applicants 

Quality and number of Info 
days organised 

Stakeholders’ feedback on 
success rate of projects with 
and without these support 
mechanisms 

Identification and 
documentation of best practices 
and lessons learned 

All NCPs receive dedicated support, including structured training, communication 
materials and network activities. 

Targeted technical assistance for countries with low participation rates is available on 
demand for 20 countries identified as having the lowest ratio of Innovation Fund 
support relative to their verified share of ETS emissions. 

By the end of 2024, 5 training sessions had been completed (out of 9 planned). 

Close to 60 % of NCPs surveyed (11 out of 19) are ‘very satisfied’ or ‘somewhat 
satisfied’ with the services provided by DG CLIMA directly or through contractors. 

15 events were held between November 2023 and February 2024. 

Survey and interview evidence confirm positive views, though satisfaction was uneven 
across countries. Many respondents judged technical assistance as only ‘somewhat’ 
improving application quality. 

Structured training and networking have improved baseline knowledge and peer 
learning, but there were delays in the delivery of some communication materials and 
uneven uptake by NCPs due to capacity constraints. 

These capacity constraints place a significant burden on this activity, as the resources 
available and the NCP’s role vary widely across countries. 

NCPs also underlined the importance of tailoring support. 

94 

 
 
EQ6.b - PDA contributes to 
project readiness and success 
by improving the maturity of 
promising proposals. However, 
its overall reach remains 
limited. 

EQ6.c - Blending operations 
have proven their value in 
mobilising additional resources 
and targeting sectors with acute 
financing barriers, but their 
overall impact remains modest. 

Number of proposals with PDA 
agreement negotiation, 
execution ongoing, and 
execution completed 

Over 6 calls for proposals (2020-2022), 87 proposals were eligible for PDA. The EIB 
selected 70 and eventually, 62 signed an agreement. All 62 assignments have been 
completed. 

Data for the IF23 Call onwards was not available at the time of reporting. 

Success rate of proposals 
receiving PDA 

By 2024, 37 PDA beneficiaries had reapplied to the Fund, with 16 successfully 
selected for grants, a 43 % success rate. 

Maturity and yield of proposals 
supported through PDA 

Stakeholders’ feedback on 
success rate of projects with 
and without these support 
mechanisms 

Identification and 
documentation of best practices 
and lessons learned 

Amount of additional funding 
leveraged through blending 
operations 

Stakeholders’ feedback on 
success rate of projects with 
and without these support 
mechanisms 

Eligible proposals must fulfil minimum thresholds for GHG emissions avoidance and 
degree of innovation, achieve at least 50 % of points under the project maturity 
criterion, and be identified by evaluators as having the potential to improve their 
maturity through tailored assistance. 

Survey evidence points to mixed satisfaction. 

PDA’s effectiveness depends on tailoring its scope to promoters’ needs, ensuring 
timely delivery, and improving accessibility across regions. 

EUR 420 million 

Awareness among applicants and NCPs remains limited. 

Identification and 
documentation of best practices 
and lessons learned 

Blending operations have demonstrated added value when strong institutional 
coordination is combined with targeted advisory support, though challenges in scale, 
timing, and attractiveness remain. 

95 

 
 
Share of Innovation Fund-
positively evaluated projects 
receiving national funding 
through AaaS 

Amount of national funding 
mobilised for such Innovation 
Fund-positively evaluated 
projects 

Stakeholders’ feedback on 
whether Innovation Fund 
positive evaluation of selected 
projects acted as a driver to 
unlock national funding 

Stakeholders’ feedback on 
success rate of projects with 
and without these support 
mechanisms 

EQ6.d - National contributions 
(via ‘as-a-service’ schemes) 
have proven effective in 
providing countries with a 
ready-made framework to fund 
positively evaluated but 
unsuccessful proposals. 
However, it is too early to 
assess their effectiveness. 

3 Spanish projects under the IF24 Auction 

EUR 1.2 billion from Germany, Austria, Spain and Lithuania during the IF23 and IF24 
Auctions. 

For AaaS only: reserve-list mechanics were identified as a best practice, enabling the 
smooth transfer of proposals when funding became available 

Not available.  

Identification and 
documentation of best practices 
and lessons learned 

Overall, transparent ranking, strong EU–national coordination, streamlined State aid 
procedures and flexible design worked well. In contrast, the needs for early budget 
clarity, stronger outreach, and adaptable rules remain to ensure broader and more 
effective uptake of the mechanism. 

EQ7. How efficiently has the Fund used its resources to achieve its objectives? 

96 

 
 
Clarity and frequency of 
communication, stakeholder 
awareness levels 

As of November 2024, 15 IFEG meetings had taken place. 

Institutional info days are organised by DG CLIMA and CINEA after each call 
opening to ensure the broadest dissemination of support. They attract strong 
participation. 

Between 2020 and 2023, DG CLIMA and CINEA issued 41 press releases and 144 
news articles. 

The Innovation Fund helpdesk is also open during each application window. For the 
2022 calls, more than 1 000 queries were managed. 

EQ7.a - The Fund has 
communicated its objectives, 
processes, and results through 
frequent and varied channels, 
ensuring high awareness among 
many stakeholders. Clarity, 
responsiveness and visibility 
could be improved. 

Stakeholders’ awareness on the 
scope, progress and results of 
funded projects as 
communicated by beneficiaries 

Stakeholders’ feedback on how 
useful information on projects 
as shared by beneficiaries is for 
own needs (e.g. useful in 
decision-making or project 
planning) 

Not available. 

See EQ7.b 

Identification and 
documentation of best practices 
and lessons learned 

Best practices identified across evidence sources include multi-channel and hybrid 
communication, presenting both successful and unsuccessful proposals, and publishing 
recordings and materials online. 

Lessons learned highlight the need for earlier event announcements, sector-tailored 
guidance, national-language sessions, and structured outreach beyond the usual 
applicant base to improve geographical and sectoral coverage. 

EQ7.b - The Fund has 
institutionalised knowledge 

Quality of knowledge sharing 
events 

Survey evidence shows that beneficiaries value these efforts, but their perceived 
relevance varies markedly across project types and sectors. 

97 

 
 
sharing as a core requirement 
and created numerous events 
and tools to foster exchange. 
Overall satisfaction with these 
activities is positive, though 
experiences vary across sectors 
and project sizes. 

Number of knowledge sharing 
events per year and number of 
participants 

Identification and 
documentation of best practices 
and lessons learned 

Between 2020 and 2023, the Fund organised more than 10 knowledge sharing events 
and thematic workshops. 

Recent feedback (2025 meetings) show that the Fund’s knowledge sharing framework 
is regarded as advanced and well-developed, highlighting the work already done by 
CINEA to address stakeholders’ feedback. 

Nonetheless, continuing to strengthen early coordination, cross-sector linkages, and the 
systematic integration of lessons learned into wider EU-level learning frameworks 
would help sustain and expand these improvements over time. 

98 

 
 
 
 
 
 
 
3.  EFFICIENCY 

Evaluation 
question 

8. How efficiently 
has the Fund used 
its resources to 
achieve its 
objectives? 

Evaluation sub-question 

Indicator 

Judgment criteria 

Data source 

8.a. Reduce GHG emissions - 
How well are resources being used 
to maximise GHG emission 
reduction? 

Total grants provided Total Innovation Fund 
budget spent 

Expected GHG emissions reduction  

=> GHG emissions / EUR grant provided 
Innovation Fund budget spent 

8.b. Induce investments - How 
well are resources being used to 
induce investments in mature, 
innovative projects with 
significant GHG reduction 
potential? 

8.c. Increase low-carbon 
technologies in eligible categories 
- How well are resources being 
used to increase low-carbon 
technologies in energy-intensive 
industries, renewable energy, 
industrial carbon management, 
energy storage net-zero mobility 
and buildings? 

Total grants provided Total Innovation Fund 
budget spent 

Total investments in projects supported by Fund 

=> EUR induced investment / EUR grant 
provided Innovation Fund budget spent 

GHG emissions / EUR grant provided 
Innovation Fund budget spent 

EUR induced investment / EUR grant provided 
Innovation Fund budget spent 

Total grants provided Potential/installed 
capacity of renewable energy, industrial carbon 
management, energy storage, net-zero mobility 
and buildings through projects supported by 
Fund 
=> respective indicators:  

Low-carbon technologies, renewable energy and 
buildings: MW/EUR grant provided  

CCS/CCU: mtonnes/EUR grant provided 

Energy storage: kWh/EUR grant provided 

99 

High expected GHG emission 
reduction per EUR grant 
provided 

Low EUR grant provided per 
expected tCO2e avoided 
(benchmark: other similar 
policy instruments (see EQ9), 
and ETS price) 

High induced investment per 
EUR grant provided 
(benchmark: other similar 
policy instruments (see EQ9) 

Low EUR grant provided per 
expected tCO2e avoided 

High induced investment per 
EUR grant provided High 
potential or installed capacity of 
for low-carbon technologies in 
energy-intensive industries, 
renewable energy, industrial 
carbon management, energy 
storage, net-zero mobility and 
buildings per EUR grant 
provided 

Desk research from 
quantitative sources: 
Fund data (awarded and 
non-awarded proposals, 
budget committed), 
Innovation Fund 
dashboard  

Desk research from 
qualitative sources: 
Fund documents (calls, 
criteria, budgets, 
quarterly and progress 
reports) 

Surveys: beneficiaries 

Interviews: 
beneficiaries, national 
authorities, trade and 
business associations; 
the Commission, 
CINEA, the EIB 

 
 
8.d. Efficiency of resource 
utilisation by project size, 
country/region, sector, year - How 
efficiently are the revenues 
allocated to different project sizes 
(small, medium, large-scale), 
countries/regions, sectors, and by 
year? 

Net-zero mobility (battery capacity): Ah/EUR 
grant provided 

By project size, country/region, sector, year: 

- expected reduction in GHG emissions / EUR 
grant provided Innovation Fund budget spent 

- EUR induced investment / EUR grant provided 
Innovation Fund budget spent  

8.e. Efficiency of the current 60 % 
Innovation Fund funding rate - Is 
the 60 % funding rate adequate for 
projects to reach final close or are 
(potential) projects over- or under 
subsidised by the Innovation 
Fund? 

% of projects reaching financial close 

% of applicants who indicate that mobilising the 
remaining funds is the main barrier for meeting 
the Innovation Fund requirements 

Distribution of private and public funding (see 
EQ2) 

9.a. Direct management 
(Commission and CINEA) - What 
are the costs related to direct 
management of the Commission 
and CINEA? 

Direct labour and financial costs related to (but 
not limited to): calls implementation, support to 
NCPs, guidance and tools for applicants 

Communication, knowledge sharing, and 
publicity 

9.b. Indirect management 
(Commission and CINEA EIB) - 
What are the costs related to 
indirect management of the 
Commission and CINEA EIB? 

Direct labour and financial costs related to PDA 
calls and implementation 
Contribution to blending operations 
AaaS 

c. Communication, knowledge 
sharing, and publicity 

Labour and IT costs related to communication, 
knowledge sharing, and publicity 

100 

High efficiency of resource 
utilisation across different 
project sizes, countries/regions, 
sectors, years 

Benchmarking against the 
average, thus expressing the 
relative efficiency of the 
different subcategories. 

High or low % of financial close 
(Innovation Fund over and 
under subsidising, respectively) 

High or low % of applicants 
indicating that mobilising 
funding is a main barrier 
(Innovation Fund under and 
over subsidising, respectively) 

Low ratio of costs to funding 

Benchmark: corresponding 
indicators for similar EU 
interventions under direct 
management (see EQ9) 

Low ratio of costs to funding 

Benchmark: corresponding 
indicators for similar EU 
interventions under indirect 
management (see EQ9), if 
applicable 

Low ratio of costs to funding 

Desk research from 
quantitative sources: 
Innovation Fund 
dashboard 

Surveys: beneficiaries, 
unsuccessful applicants 

Interviews and/or data 
requested from: national 
authorities, the 
Commission, CINEA, 
the EIB 

9. How efficiently 
has the Fund been 
implemented? 

 
 
 
(Commission, CINEA and project 
beneficiaries) - What are the costs 
related to communication, 
knowledge sharing, and publicity 
by the Commission, CINEA and 
project beneficiaries? 

d. Support and assistance (national 
authorities) - What are the costs 
sustained by national authorities to 
provide support and assistance to 
the Commission? 

9.c. Support and assistance 
(NCPs) - What are the costs 
sustained by NCPs to provide 
support and assistance to 
applicants? 

Direct labour costs related to (but not limited 
to): 
- support and assistance on implementation of 
Fund 
- acknowledgement of selected projects 

Direct labour costs related to (but not limited 
to): support to applicants, communication, 
knowledge sharing and publicity 

Supporting the preparation and submission of 
proposals  
Assisting in disseminating relevant updates and 
ensuring compliance with national regulations 
and fund requirements 

9.d. Administrative costs (project 
beneficiaries) - What are the 
administrative costs for project 
beneficiaries? 

Direct labour costs & costs of external services 
related to preparing the project proposal, 
complying with monitoring, and reporting 
obligations 

9.e. Administrative costs 
(unsuccessful applicants) - What 
are the administrative costs for 
unsuccessful applicants? 

Direct labour costs & costs of external services 
related to preparing the project proposal 

Low ratio of costs to funding 

Interviews and/or data 
requested from: national 
authorities 

Sufficient resources relative to 
the support needs  

Low ratio of costs to funding  

Surveys: NCPs 

Interviews and/or data 
requested from: NCPs, 
the Commission, 
CINEA, the EIB 

Low ratio of costs to funding 

Benchmark: corresponding 
indicators for similar EU 
interventions (see EQ9) 

Low average administrative 
costs per proposal 

Benchmark: corresponding 
indicators for similar EU 
interventions (see EQ9) 

Low ratio of costs to funding 

Surveys: beneficiaries 

Surveys: unsuccessful 
applicants 

10. How do the 
costs of the Fund 's 

10.a. Magnitude of cumulative 
costs and benefits (businesses, 

Total costs vs. total benefits 

Benefits outweigh costs 

101 

 
 
  
 
interventions 
compare to their 
benefits? 

administrations, 
citizens/consumers) - What are the 
total costs and benefits of the 
Fund interventions? 

b. Short-term v. long-term cost-
benefit outcomes - What are the 
short-term and long-term cost-
benefit outcomes of the Fund? 

10.b. Variation across project type 
- How do the cost-benefit 
outcomes vary by project type? 

10.c. Variation across funding 
schemes and services - How do 
the cost-benefit outcomes vary by 
funding scheme under direct and 
indirect management? 

10.d. Variation across 
categories/sectors - How do the 
cost-benefit outcomes vary by 
category/ sector? 

10.e. Geographic variation - How 
do the cost-benefit outcomes vary 
by country geographic region? 

10.f.  Indirect benefits - What are 
the indirect benefits of the 
Innovation Fund? 

Benefit-cost ratio 

Benefits: environmental (GHG emission 
reduction, increased renewable 
energy/CCS/CCU/storage), economic 
(stimulating innovation, job creation, increasing 
EU’s competitiveness in new technologies 
(qualitative), supporting local economies 
(qualitative)), and societal (improving air 
quality) 

Comparison of short-term (within 10 years) vs. 
long-term (> 10 years) benefits 

Based on aggregated project data 

High benefit-cost ratio 

Benchmark: corresponding 
indicators for similar EU 
interventions (see EQ9) 

Long-term benefits significantly 
outweigh short-term costs 

Benefit-cost ratios different project types (small, 
medium, large-scale projects) 

Favourable benefit-cost ratios 
across project types 

Benefit-cost ratios for different funding schemes 
and services (e.g. calls for proposals, technical 
assistance, PDAs, AaaS) 

Favourable benefit-cost ratios 
across various funding schemes 

Benefit-cost ratios for all eligible 
categories/sectors 

Favourable benefit-cost ratios 
across various categories/sectors 

Benefit-cost ratios for different EEA countries 
geographic regions 

Favourable benefit-cost ratios 
across various locations 

Indirect benefits quantified and qualified, based 
on aggregated project data 

Indirect effects in scope: environmental 
(stimulating green transition through increased 
renewable energy/CCS/CCU/storage), economic 

102 

Significant indirect benefits 
observed 

Costs: EQ2 

Benefits: 

- Desk research from 
qualitative sources: 
Fund documents 

- Desk research from 
quantitative sources: 
Fund data, Innovation 
Fund dashboard  

Surveys: beneficiaries 

Interviews: 
beneficiaries, national 
authorities, NCPs, trade 
and business 
associations; the 
Commission, CINEA, 
the EIB 

 
 
 
(stimulating innovation, job creation, increasing 
EU’s competitiveness in new technologies 
(qualitative), supporting local economies 
(qualitative) 

11. How efficiently 
have disbursements 
under the Fund been 
processed? 

11.a. Timeliness and monitoring 
of disbursements - How timely 
have the disbursements been made 
to project beneficiaries? How well 
are the disbursements monitored 
and controlled? 

Average time from approval to disbursement 

Monitoring and control frequency of 
disbursements 

Timely disbursement within 
expected timelines 

11.b. Reasons for delays - What 
are the main reasons for any 
delays in disbursement? 

Identification of reasons for delays 

Minimal delays and clear 
understanding of delay causes 

11.c. Comparative disbursement 
efficiency - How do the 
disbursement processes compare 
with those of similar funding 
mechanisms? 

Comparison of disbursement efficiency metrics 

Comparable or better efficiency 
than similar mechanisms 
(benchmark: other similar 
policy instruments (see EQ9) 

103 

Desk research from 
quantitative sources: 
Fund data (financial 
data) 

Desk research from 
qualitative sources: 
Fund documents 

Surveys: beneficiaries  

Interviews: 
beneficiaries, national 
authorities, trade and 
business associations; 
the Commission, 
CINEA, the EIB 

Desk research from 
quantitative sources: 
Innovation Fund 
dashboard 

Surveys: Beneficiaries  

Interviews: 
Beneficiaries, CINEA 

Desk research from 
qualitative data: 
literature review 

Desk research from 
quantitative data: data 
from NER 300 
programme and other 
related EU programmes 

 
 
 
 
Identification and effectiveness of improvement 
measures 

Effective measures leading to 
improved efficiency (time to 
pay) 

Frequency and quality of communication, 
stakeholder feedback 

Effective and clear 
communication 

(e.g. Horizon Europe, 
Modernisation Fund, 
European Hydrogen 
Bank) 

Surveys: Beneficiaries 

Interviews: 
beneficiaries, the 
Commission, CINEA, 
the EIB 

Desk research from 
qualitative data: 
literature review 

Interviews: the 
Commission, CINEA, 
the EIB 

Desk research from 
qualitative sources: 
literature review 

Surveys: beneficiaries, 
NCPs 

Interviews: 
beneficiaries, the 
Commission, CINEA, 
the EIB 

Ratio of administrative costs to total 
disbursements 

Low administrative costs 
relative to disbursements 

Interviews: the 
Commission, CINEA 

11.d. Disbursement improvement 
measures - What measures have 
been implemented to improve the 
efficiency of the disbursement 
process? 

11.e. Communication 
effectiveness - How effective are 
the communication channels 
between the Fund administration 
and beneficiaries on 
disbursements? 

11.f. Disbursement administrative 
costs - What are the administrative 
costs associated with the 
disbursement process? 

12. How efficiently 
have other Fund 
processes been 
executed? 

12.a. Application process - How 
efficient are the application and 
selection processes for Fund 
funding? 

Direct support for applicants: 

Short processing times, high 
stakeholder satisfaction 

Desk research from 
qualitative sources: 
literature review 

104 

 
 
 
 
 
–  provision  of  relevant  templates,  e.g. 
for  business  plans  and  feasibility 
studies 

–  provision 

of 

relevant 

cost 

methodologies 

–  provision of guidelines/methodology 
reduction 

estimation  GHG 

for 
potential 

Fitness of the award criteria 

Average time for application processing and 
selection 

12.b. Grant agreement signature - 
How effectively do the Fund 's 
process to prepare and sign grant 
agreements supports timely 
project implementation? 

Time from fund allocation to grant agreement 
signature to project initiation 

Stakeholder feedback on the grant agreement 
preparation phase 

Proportion of allocated funds that is used 

Timely allocation and 
stakeholder satisfaction high 
proportion of allocated funds 
used 

12.c. Stakeholder coordination and 
communication - How efficient is 
the communication and 
coordination between CINEA, the 
Commission and beneficiaries and 
national authorities during project 
implementation? 

12.d. Fund monitoring - How well 
are the funds monitored to ensure 
they are used as intended? 

Frequency and quality of communication and 
coordination, stakeholder satisfaction 

Efficient communication and 
coordination, high stakeholder 
satisfaction 

Frequency and thoroughness of financial audits, 
stakeholder satisfaction compliance rates 

Efficient and effective 
monitoring 

105 

Surveys: beneficiaries, 
unsuccessful applicants, 
NCPs  

Interviews: 
beneficiaries, NCPs, 
national authorities, 
trade and business 
associations; evaluators, 
the Commission, 
CINEA, the EIB 

Desk research from 
quantitative sources: 
Fund data  

Interviews: national 
authorities, trade and 
business associations, 
the Commission, 
CINEA 

Desk research from 
qualitative sources. 

Surveys: beneficiaries 

Interviews: 
beneficiaries, national 
authorities, CINEA 

 
 
13.a. Administrative burdens - 
What are the key administrative 
burdens faced by stakeholders? 

Stakeholder feedback on administrative 
processes 

Identification of key burdens 

13.b. Types of simplification 
measures - What simplification 
measures can be implemented to 
reduce administrative burdens? 

Identification and implementation of 
simplification measures (e.g. simplified GHG 
calculation for small-case projects, removal of 
knowledge sharing plan at application stage) 

Potential for effective reduction 
of administrative burdens 

13. What 
opportunities exist 
to simplify and 
reduce burdens 
within the Fund? 

13.c. Impact of ‘Auction-as-a-
Service’, which have been 
closelyaligned to the applicable 
State aid rules, on administrative 
burden - What has been the 
consequence of implementing 
AaaS in decreasing administrative 
burden? 

Perceived administrative burden 

Administrative burden metrics pre- and post-
implementation 

Significant decrease in 
administrative burden 

14. How cost-
efficient is the PDA 
in terms of success 
rate versus resources 
used? 

14.a. PDA resources used - What 
are the total and average resources 
(financial, human, etc.) used for 
providing PDA? 

Total cost and resource allocation for PDA 

Average costs and resources allocation for PDA 
per proposal 

Efficient resource allocation 

14.b. Comparison between PDA 
costs and success rate achieved - 
How do the costs of supported 
proposals compare to the success 
rate achieved? 

Cost-success rate ratio of supported proposals 

Success rate is proportionate to 
PDA costs  

106 

Surveys: beneficiaries, 
unsuccessful applicants, 
NCPs 

Interviews: 
beneficiaries, NCPs, 
national authorities, 
trade and business 
associations, the 
Commission, CINEA, 
the EIB 

Desk research from 
qualitative sources: 
Fund documents 

Interviews: 
beneficiaries, NCPs, 
national authorities, 
trade and business 
associations, the 
Commission, CINEA, 
the EIB 

Surveys: beneficiaries, 
unsuccessful applicants, 
NCPs 

Desk research from 
quantitative data: EIB 
financial statements  

Interviews: the 
Commission, the EIB 

Desk research: PDA 
annual reports 

Surveys: unsuccessful 
applicants 

 
 
14.c. PDA best practices - What 
best practices and lessons have 
been identified in terms of PDA 
cost-efficiency? 

Identification and documentation of best 
practices and lessons learned 

Clear documentation and 
application of best practices 

14.d. Cost-efficiency patterns - 
What are the specific patterns 
contributing to the cost-efficiency 
of PDA? 

15.a. Resources used in blending 
operations - What are the total 
resources (financial, human, etc.) 
used for blending operations? 

15.b. Comparison between costs 
of blending operations and success 
rate achieved - How do the costs 
of projects supported through 
blending operations compare to 
the success rate achieved? 

15.c. Blending operations best 
practices - What best practices and 
lessons have been identified in 
terms of blending operations cost-
efficiency? 

15. How cost-
efficient are 
blending operations 
on success rate 
versus resources 
used? 

Analysis of cost-efficiency patterns across 
project type, sector, geographic location, 
maturity 

Identification of key cost-
efficiency factors 

Total cost and resource allocation for blending 
operations 

Efficient resource allocation 

Cost-success rate ratio of blending operations-
supported projects 

Success rate is proportionate to 
costs of blending operations 

Identification and documentation of best 
practices and lessons learned 

Clear documentation and 
application of best practices 

107 

Desk research from 
qualitative sources: 
literature review, PDA 
annual reports 

Surveys: beneficiaries, 
unsuccessful applicants 

Interviews: 
beneficiaries, national 
authorities, trade and 
business associations, 
the Commission the EIB 

Surveys: unsuccessful 
applicants 

Interviews: the EIB, the 
Commission 

Desk research from 
quantitative data: Fund 
data 

Interviews: the 
Commission, CINEA, 
the EIB 

Surveys: Beneficiaries 
Interviews: 
beneficiaries, national 
authorities, trade and 
business associations; 
the Commission, 
CINEA, the EIB  

Desk research from 
qualitative sources: 
literature review 
Surveys: beneficiaries 
Interviews: 

 
 
15.d. Cost-efficiency patterns - 
What are the specific patterns 
contributing to the cost-efficiency 
of blending operations? 

Analysis of cost-efficiency patterns across 
project type, sector, geographic location, 
maturity 

Identification of key cost-
efficiency factors 

16. How do the 
Fund’s efficiency 
outcomes compare 
to similar 
interventions? 

16.a. National comparison - How 
do the efficiency of resource use, 
efficiency of the execution, and 
the cost-benefit ratio of the 
Innovation Fund compare to those 
of similar national interventions? 

16.b. EU comparison - How do 
the efficiency of resource use, 
efficiency of the execution, and 
the cost-benefit ratio of Fund 
projects compare to those of 
similar EU interventions? 

Comparative analysis against a pre-defined 
‘basket’ of similar national interventions of the 
following quantities: 

Resource use (expected reduction in GHG 
emissions per EUR granted, induced 
investments per EUR granted) 

Total costs and administrative costs 

Cost-benefit ratios 

Comparative analysis against a pre-defined 
‘basket’ of similar EU interventions of the 
following quantities: 

Comparable or better efficiency 
outcomes 

Resource utilisation (expected reduction in GHG 
emissions per EUR granted, induced investment 
per EUR granted) 

Comparable or better efficiency 
outcomes 

Total costs and administrative costs 

Total amount of people working on the Fund (in 
FTE) vs allocated grants 

108 

beneficiaries; national 
authorities, trade and 
business associations; 
the Commission, 
CINEA, the EIB 

Desk research from 
qualitative sources: 
literature review 

Surveys: beneficiaries 

Interviews: 
beneficiaries; national 
authorities, trade and 
business associations; 
the Commission, 
CINEA, the EIB 

Desk research from 
qualitative sources: 
literature review (e.g. 
focus on sources 
relevant to biggest 
countries in terms of 
funds received) 

Surveys: beneficiaries 

The selection of similar 
national and EU 
interventions will be 
made based on the 
survey for beneficiaries 
and literature search 

 
 
16.c. Lessons learnt - What 
lessons can be learned from the 
efficiency of similar 
interventions? 

17.a. Reasons for amending or 
terminating Gas - What have been 
the main reasons for amending or 
terminating GAs? 

b. GHG emission reduction 
potential - Has a change in the 
expected GHG reduction potential 
of projects been reason to amend 
or terminate grant agreements? 

c. Replicability - Has a change in 
the expectation of the replicability 
of projects been reason to amend 
or terminate grant agreements? 

d. Maturity - Has a change in the 
actual level of maturity of projects 
been reason to amend or terminate 
grant agreements? 

e. Financial close or project 
operational aspects - Has a change 
in the expectations about the time 
for financial close or a change in 
expectations on project 
operational aspects (e.g. 
technological, HR) been reason to 

Benefit-cost ratios 

Identification and documentation of best 
practices 

Clear documentation and 
application of best practices 

Reasons provided for amending or terminating 
grant agreements 

Assessing the following possible aspects: 
innovation level, GHG reduction potential, 
replicability, maturity, financial close or 
operational aspects, procedural reasons or other 
reasons 

Number of projects for which the project's GHG 
reduction potential has led to amending or 
terminating grant agreements 

Number of projects for which the project's 
replicability has led to amending or terminating 
grant agreements 

Number of projects for which the project's 
maturity has led to amending or terminating 
grant agreements 

Number of projects for which a change in the 
time for project's financial close or project 
operational aspects has led to amending or 
terminating grant agreements 

Substantial number of projects 
that were amended or 
terminated due to the listed 
reasons 

Substantial number of projects 
that were amended or 
terminated due to the project's 
GHG reduction potential  

Substantial number of projects 
that were amended or 
terminated due to the project's 
expected replicability 

Substantial number of projects 
that were amended or 
terminated due to the project's 
maturity 

Substantial number of projects 
that were amended or 
terminated due to change in the 
time of project's financial close 
or project operational aspects 

109 

17. What are the 
main reasons for 
amending or 
terminating grant 
agreements, and 
how is efficient fund 
use ensured? 

Desk research from 
qualitative data: Fund 
documents 

Surveys: beneficiaries 

Interviews: 
beneficiaries, the 
Commission, CINEA, 
the EIB 

 
 
amend or terminate grant 
agreements? 

f. Procedural reasons - Have there 
been any procedural reasons to 
amend or terminate grant 
agreements? 

g. Other reasons - Have there been 
other reasons to amend or 
terminate grant agreements? 

Number of projects for which procedural 
reasons have led to amending or terminating 
grant agreements 

Number of projects for which other reasons have 
led to amending or terminating grant agreements 

Substantial number of projects 
that were amended or 
terminated due to procedural 
reasons 

Substantial number of projects 
that were amended or 
terminated due other reasons 

Answers to evaluation sub-
questions 

Indicators 

Results 

EQ8. How efficiently has the Fund used its resources to achieve its objectives? 

EQ8.a - The Fund’s portfolio 
demonstrates a high potential 
efficiency for GHG emission 
reduction, with an overall potential 
efficiency of EUR 13.36 per 
expected ton of CO2e avoided. 

EQ8.b - The Fund demonstrates the 
capacity to mobilise investments 
beyond its direct financial support. 

Total Innovation Fund 
budget spent 

EUR 11.09 billion in awarded grants 

EUR 530 million in management costs 

Expected GHG emissions 
reduction 

871 278 371 tCO2e 

Total Innovation Fund 
budget spent 

EUR 11.6 billion 

Total induced investment 

EUR 56.3 billion in direct investment 

EUR 54.6 billion in indirect investment 

EQ8.c - The Fund’s efficiency 
varies substantially across 
categories, with energy storage 

Innovation Fund budget 
spent / expected GHG 
emissions reduction 

Category 

Euro budget spent 
per expected 
tCO2e avoided 

EUR induced 
investments (direct 

110 

 
 
 
 
performing best on GHG emissions 
avoidance and investment 
mobilisation. 

EUR induced investment / 
Innovation Fund budget 
spent 

EQ8.d - The Fund’s efficiency 
varies substantially across regions, 
project sizes, and sectors. 

Innovation Fund budget 
spent / expected GHG 
emissions reduction (by 
project size, country/region, 
sector, year) 

Energy-intensive industries 
Renewable energy 
Energy storage 
Industrial carbon 
management 
Net-zero mobility & 
buildings 
Total 

Type 

Specification 

Region 

Size 

Sector 

Eastern Europe 
Northern Europe 
Southern Europe 
Western Europe 
Small-scale 
Medium-scale 
Large-scale 
Manufacturing of 
components 
Hydrogen 
Chemicals 
Cement & lime 

+ indirect) per euro 
budget spent 
11.68 
8.57 
13.42 

5.52 

6.56 

9.55 

16.50 
10.71 
5.16 

13.92 

21.90 

13.36 

Euro budget 
spent per 
expected tCO2e 
avoided 
10.37 
10.17 
20.86 
13.91 
5.52 
16.60 
13.50 

EUR induced 
investments (direct + 
indirect) per euro 
budget spent 
4.40 
13.24 
9.46 
7.93 
2.99 
4.24 
10.40 

6.78 

35.62 
31.68 
18.51 

8.76 

8.96 
9.72 
4.76 

111 

 
 
 
EUR induced investment / 
Innovation Fund budget 
spent (by project size, 
country/region, sector, year) 

Glass, ceramics & 
construction 
material 
Refineries 
Intra-day 
electricity storage 
Iron & steel 
Other energy 
storage 
Solar energy 
Wind energy 
Maritime 
Other 

47.76 

24.54 

4.71 

9.59 

1.15 

4.93 
52.01 
149.04 
10.89 

5.04 

4.94 

4.86 

26.13 

5.40 

11.21 
9.61 
7.08 
7.04 

% of projects reaching 
financial close 

20 % of the portfolio (39 projects) 

EQ8.e - The 60 % funding rate 
appears to be appropriate. The 
funding rate was insufficient in 
certain sectorsdepending on capital 
needs and the availability of co-
funding sources.  

% of applicants who indicate 
that mobilising the 
remaining funds is the main 
barrier for meeting the 
Innovation Fund 
requirements 

30 % of the surveyed beneficiaries found the funding rate insufficient (37 
respondents out of 124). 

Distribution of private and 
public funding 

See EQ2. 

EQ9. How efficiently has the Fund been implemented? 

EQ9.a - Direct management costs 
amounted to EUR 78 million, 
representing only 0.9 % of the 
Fund’s total budget. 

Direct labour and financial 
costs for DG CLIMA and 
CINEA 

Specification 
Direct management DG CLIMA 
Direct management CINEA 
Total direct management (in 
million EUR2024) 

2020 
2.04 
0.01 

2021 
4.98 
7.73 

2022 
4.46 
9.19 

2023 
7.62 
11.20 

2024 
15.22 
15.13 

2.05 

12.71 

13.65 

18.82 

30.35 

112 

 
 
 
 
EQ9.b - Indirect management costs 
amounted to EUR 24 million, 
reflecting a relatively stable annual 
cost range of EUR 4 to 7 million. 

EQ9.c - NCPs incurred an estimated 
EUR 19 million in administrative 
costs to support applicants and 
beneficiaries, with annual 
expenditures rising from EUR 2 
million in 2020 to EUR 5 million in 
2024 as the number of active NCPs 
increased. 

EQ9.d - Beneficiaries incurred an 
estimated EUR 35 million in 
administrative costs, with an 
average of EUR 95 000 per small-
scale project and EUR 240 000 per 
large-scale project. Each euro spent 
on administrative activities 
generates roughly EUR 329 in 
grants received. 

EQ9.e - Administrative costs for 
unsuccessful applicants are similar 
to those of beneficiaries. However, 
unsuccessful applicants were more 
critical about the application 
process than beneficiaries. 

Direct labour and financial 
costs related to PDA calls 
and implementation 

EUR2024 24 million 

Direct labour costs related to 
(but not limited to): support 
to applicants, 
communication, knowledge 
sharing and publicity 

EUR2024 19 million 

Direct labour costs & costs 
of external services related 
to preparing the project 
proposal, complying with 
monitoring, and reporting 
obligations 

Direct labour costs & costs 
of external services related 
to preparing the project 
proposal 

EUR 35 million in administrative costs, with an average of EUR 95 000 per small-
scale project and EUR 240 000 per large-scale project. 

Administrative costs for unsuccessful applicants are similar to those of beneficiaries. 

EQ14. How cost-efficient is the PDA in terms of success rate versus resources used? 

EQ14.a - Between 2021-2014, a 
total of EUR 23.6 million was spent 

Total cost and resource 
allocation for PDA 

EUR2024 23.6 million 

113 

 
 
on PDA, corresponding to an 
average of about EUR 5.9 million 
per year. 

Average costs and resources 
allocation for PDA per 
proposal 

EUR 380 500 per proposal (total budget spent / 62 PDA beneficiaries) 

EQ14.b - A comparison between 
PDA costs and success rate shows 
that the financial inputs have 
generated measurable though varied 
outcomes. 

EQ14.c - To improve PDA’s cost-
efficiency, evidence highlights 
targeted scoping, standardisation, 
promoter engagement and 
flexibility as key success factors. 

EQ14.d - Several recurring patterns 
contribute to PDA’s cost-efficiency, 
notably relating to project selection, 
timing, scope, and promoter 
engagement. 

Cost-success rate ratio of 
supported proposals 

Of 62 proposals for which PDA was completed, around 37 reapplied to the 
Innovation Fund. 16 were awarded funding, a success rate of 43 % when considering 
only resubmissions (26 % in total). 

Identification and 
documentation of best 
practices and lessons learned 

PDA was most efficient when support focused on specific maturity gaps, aligned 
with evaluation feedback and when consultants where closely managed by the EIB. 
Clearly defined scopes and deliverables at the outset, along with flexibility to adapt to 
evolving project needs, were also crucial for maintaining relevance and cost-
efficiency of the PDA process 

Analysis of cost-efficiency 
patterns across project type, 
sector, geographic location, 
maturity 

PDA has achieved reasonable cost-efficiency as an advisory instrument, with limited 
financial resources producing measurable results in project maturity and eventual 
grant success. Resources were used most efficiently when targeted at mature 
proposals with engaged promoters, and delivered within well-timed, clearly scoped 
assignments. However, systematic impact tracking should be improved. 

EQ15. How cost-efficient are blending operations on success rate versus resources used? 

EQ15.a - Financial resources 
dedicated to blending operations 
totalled EUR 429 million over the 
period 2020–2024. 

EQ15.b - Because the number of 
projects financed by blending 
operations has been small so far, 
and their recent launch, evidence 
was insufficient to assess their cost-
success ratio. 

Total cost and resource 
allocation for blending 
operations 

EUR2024 429 million 

Cost-success rate ratio of 
blending operations-
supported projects 

Not available. 

114 

 
 
EQ15.c - The EU-Catalyst 
partnership has potential through 
close coordination, clear 
governance, and rapid decision-
making. Still, given the limited 
number of funded projects, this 
potential has not yet been realised. 

EQ15.d - Because the number of 
projects financed by blending 
operations has been small so far, 
and their recent launch, evidence 
was insufficient to establish cost-
efficiency patterns. 

Identification and 
documentation of best 
practices and lessons learned 

See answer. 

Analysis of cost-efficiency 
patterns across project type, 
sector, geographic location, 
maturity 

Not available. 

EQ11. How efficiently have disbursements under the Fund been processed? 

EQ11.a - Disbursements are tightly 
monitored and controlled. The 
conditionality of achieving 
milestones means that the 
disbursement cycle usually starts 
only after financial close. 

EQ11.b - Delays in disbursement 
stem from delays in achieving 
milestones, particularly financial 
close. 

EQ11.c - The Fund’s disbursement 
system is more structured and risk-
controlled than for NER 300, but 
also more complex and less flexible 
than other funding schemes. 

Average time from approval 
to disbursement 

Assuming the first disbursement takes place after financial close, the average 
expected time from grant signature to first disbursement is around 1.7 years. 

Monitoring and control 
frequency of disbursements 

See EQ12.d 

Identification of reasons for 
delays 

A combination of regulatory, financial, and administrative factors often results in 
delays in achieving milestones (see EQ5.b and EQ5.c), amendment procedures to 
adjust timelines and thus postponements of disbursements, especially for innovative 
or capital-intensive projects. 

Comparison of disbursement 
efficiency metrics 

For NER 300, the average time to first disbursement was around 5 to 7 years. For the 
First Call (awarded Dec 2012), most operational projects only began receiving funds 
around 2017–2019. 

115 

 
 
EQ11.d - Measures to improve the 
efficiency of the Fund’s 
disbursement process have focused 
on streamlining procedures and 
strengthening guidance. 

EQ11.e - Since the evidence did not 
distinguish communication on 
disbursements from general 
communication, an analysis of the 
effectiveness of communication on 
disbursements specifically was not 
possible. 

EQ11.f - Administrative costs 
related to the disbursement process 
are moderate in financial terms but 
substantial in time and effort for 
both CINEA and beneficiaries. 

Identification and 
effectiveness of 
improvement measures 

Support to applicants and beneficiaries has been consistently revisited to clarify the 
disbursement process. CINEA clarified milestones definition and the introduction of 
auctions also introduced a lighter disbursement process. 

Frequency and quality of 
communication, stakeholder 
feedback 

Ratio of administrative costs 
to total disbursements 

See answer. The effectiveness of overall exchanges is presented under EQ12.c 

Total direct management costs 
Innovation Fund budget spent 
Direct management costs vs 
budget spent 

2020 
2.05 
0 

2021 
12.71 
1 239 

2022 
13.65 
2 082 

N/A 

1.2 % 

0.7 % 

2024 
2023 
18.82  30.35 
3 513  5 124 
0.6 
% 

0.5 
% 

EQ12. How efficiently have other Fund processes been executed? 

EQ12.a – Although processing 
times are lengthening, the 
application and selection processes 
are increasingly efficient. 

Direct support for 
applicants: provision of 
relevant templates and 
guidance on relevant costs 
calculation and GHG 
emissions reduction 
methodology 

The range of direct support to applicants is vast, expanding and appreciated by 
stakeholders. 

Fitness of the award criteria 

Interviews confirmed that while the evaluation framework is transparent and 
supported by clear award criteria. 

Average time for application 
processing and selection 

The average time between the application deadline and the evaluation results has 
lengthened, from 3-4 months in the early years to 6.5 months for the IF23 Call. 

116 

 
 
 
 
EQ12.b - Grant agreement 
preparation is considered a critical 
but demanding step. It establishes a 
solid framework for implementation 
but also places significant burden 
on beneficiaries. 

EQ12.c - Communication and 
coordination between DG CLIMA, 
CINEA, and beneficiaries during 
project implementation is effective 
and appreciated, with strong 
satisfaction with the role of 
CINEA’s project officers. 

EQ12.d – Monitoring mechanisms 
are thorough and effective in 
safeguarding the use of funds and 
ensuring accountability. However, 
their efficiency is reduced by 
reporting obligations experienced as 
heavy by beneficiaries. 

Time from fund allocation to 
grant agreement signature to 
project initiation 

Stakeholder feedback on the 
grant agreement preparation 
phase 

Quantitative evidence shows that since 2022, projects have typically started between 
21 to 28 days after grant agreement signature 

The beneficiaries’ survey showed that the grant agreement preparation phase is more 
intense and condensed than many applicants anticipated, leading to dissatisfaction 
with this implementation phase. Nonetheless, beneficiaries highlighted the 
professionalism and responsiveness of CINEA’s project officers and noted that 
institutional support from DG CLIMA and CINEA helped them navigate the process. 

Frequency and quality of 
communication and 
coordination, stakeholder 
satisfaction 

Around two-thirds of surveyed beneficiaries reported being very satisfied with 
institutional communication and support. CINEA’s project officers are valued for 
their professionalism, responsiveness, and proactive approach. 

Frequency and thoroughness 
of financial audits, 
stakeholder satisfaction 

CINEA monitors project progress and disbursements through quarterly and monthly 
reports, which align payments with implementation milestones and function as early 
warning mechanisms for delays. External audits and strict rules on permissible 
project changes further ensure that funds are used as intended. However, reporting 
obligations are commonly perceived as burdensome. 

EQ10. How do the costs of the Fund 's interventions compare to their benefits? 

EQ10.a - The Fund is expected to 
generate EUR 279 billion in 
quantifiable societal benefits for the 
programme funding period 2020-
2030. 

Total costs vs. total benefits 

For the programme funding period (2020-2030): 

Total costs: EUR2024 187 billion  

Total benefits: EUR2024 466 billion 

Total net benefits: EUR2024 279 billion 

117 

 
 
Benefit-cost ratio 

Considering only the EU’s contribution (expected to total EUR 32 billion for 2020-
2030), the benefit-cost ratio amounts to 14.3. 

When considering overall costs, including national, private, and other public co-
financing, the benefit–cost ratio is 2.5 

Benefits: environmental, 
economic, and societal 

See EQ10.f 

Benefit-cost ratios different 
project types (small, 
medium, large-scale 
projects) 

For the period 2020-2024, small-scale projects achieved the most favourable benefit-
cost ratios, with 19.5 for the EU contribution and 3.0 for overall costs. Medium-scale 
projects followed with ratios of 13.7 and 4.2. Large-scale projects recorded 12.5 and 
1.9. 

Benefit-cost ratios for 
different funding schemes 
and services (e.g. calls for 
proposals, technical 
assistance, PDAs, AaaS) 

Call type 

Hydrogen Auctions 
Calls for ‘regular’ 
grants 

Benefit-cost ratio (EU 
contribution) 
2.5 

13.6 

Benefit-cost ratio (overall costs) 

0.4 

2.2 

EQ10.b - Large-scale projects 
account for most of the quantifiable 
benefits, totalling EUR 49 billion, 
or about 74 % of the total 
quantifiable benefits for 2020-2024. 

EQ10.c – As opposed to calls for 
‘regular’ grants, hydrogen auctions 
show a negative cost-benefit 
balance of -EUR 2.5 billion, 
resulting in a benefit-cost ratio of 
0.4 when overall costs are 
considered. For other activities, no 
data are currently available to 
quantify their benefits, making it 
impossible to calculate a benefit-
cost ratio. 

118 

 
 
 
EQ10.d - The cost-benefit analysis 
shows considerable variation in 
outcomes across eligible categories 
and sectors. 

Benefit-cost ratios for all 
eligible categories/sectors 

EQ10.e - Projects in northern and 
eastern Europe deliver the greatest 
benefits relative to the EU 
contribution, efficiently translating 
EU support into societal gains. 
When considering overall costs, 
projects in eastern Europe performs 
best, generating benefits that 
outweigh total investments. 

Benefit-cost ratios for 
different geographic regions 

Category 

Industrial carbon 
management 
Energy-intensive 
industries 
Energy storage 
Net-zero mobility and 
buildings 
Renewable energy 

Region 

Eastern Europe 
Northern 
Europe 
Southern 
Europe 
Western 
Europe 

Benefit-cost ratio (EU 
contribution) 

Benefit-cost ratio 
(overall costs) 

13.2 

10.5 

31.5 

8.0 

14.8 

3.2 

1.5 

3.0 

1.5 

2.3 

Benefit-cost ratio (EU 
contribution) 
16.3 

Benefit-cost ratio (overall 
costs) 
4.4 

17.0 

8.3 

12.5 

2.0 

1.6 

2.2 

EQ10.f – Beyond direct financial 
support, induced investments and 
potential GHG emission reductions, 

Indirect benefits quantified 
and qualified, based on 
aggregated project data 

Because indirect benefits are more difficult to quantify and monetise, they have been 
assessed primarily qualitatively in Annex B of the supporting study. 

119 

 
 
 
 
the Fund generates a broad range of 
indirect benefits, including 
contributing to stimulating the 
green transition and innovation, job 
creation, increasing the EU’s 
competitiveness, supporting local 
economies, and improving the 
health of people and the 
environment. 

Indirect effects in scope: 
environmental, economic, 
societal 

Survey evidence highlights that the Fund supports a range of indirect benefits, 
including enhanced reputation, improved technological expertise, and better access to 
finance for beneficiaries. 

EQ13. What opportunities exist to simplify and reduce burdens within the Fund? 

EQ13.a - Administrative burdens 
are substantial and stem from 
methodological complexity and 
extensive documentation 
requirements during the application 
phase, and heavy reporting 
obligations during implementation. 

EQ13.b – Although some 
simplification measures have been 
introduced, further adjustments 
could reduce administrative burden 
for applicants and beneficiaries, 
notably allowing for differentiated 
requirements. 

EQ13.c - The introduction of 
‘Auctions-as-a-Service’ has 
substantially reduced administrative 
burden for DG CLIMA and 
participating countries by 
centralising procedures and 
shortening timelines. 

Stakeholder feedback on 
administrative processes 

If the Fund’s administrative processes ensure accountability and control, stakeholders 
confirm they impose considerable burdens on applicants, beneficiaries, and support 
structures. 

Identification and 
implementation of 
simplification measures 

If efforts made to simplify the application process have improved clarity, they not 
fully alleviated the workload. Stakeholders suggest scaling administrative 
requirements to a project’s size and complexity and allowing more flexibility for 
SMEs. 

Perceived administrative 
burden 

The experiences gathered show that efficiency gains linked to the implementation of 
AaaS are considerable but partly depend on the institutional capacity and regulatory 
frameworks of participating countries. 

120 

 
 
EQ16. How do the Fund’s efficiency outcomes compare to similar interventions? 

EQ16.a - When compared with 
similar national interventions, the 
Fund shows strong relative 
efficiency. 

EQ16.b - When compared to other 
EU interventions, the Fund 
performs favourably relative to the 
EU contribution but shows lower 
efficiency when total costs are 
considered. The Fund also shows 
relatively lower leverage for 
induced investments. 

EQ16.c – Experience from other 
EU programmes highlights several 
efficiency best practices, 
particularly on financial maturity 
assessment, flexible funding 
mechanisms and simplification. 

The Fund’s potential efficiency (EUR 13.36/tCO2e) is higher than that of most 
comparable national interventions. But methodological and contextual differences 
limit the scope for direct comparison between instruments. 

See answer. 

For a comparison of administrative costs, see EQ9.d 

Comparative analysis 
against similar national 
interventions of resource use 
(expected reduction in GHG 
emissions per EUR granted) 

Comparative analysis 
against similar EU 
interventions of: 

Resource use, induced 
investment per EUR granted 

Total costs and 
administrative costs 

Total amount of people 
working on the Fund (in 
FTE) vs allocated grants 

Benefit-cost ratios 

Identification and 
documentation of best 
practices 

See answer. 

121 

 
 
EQ17.a – Delays in achieving 
milestones, due to a combination of 
factors, are the main reasons for 
amendments, sometimes leading to 
termination. 

Reasons provided for 
amending or terminating 
grant agreements 

As discussed in EQ5.b and EQ5.c, a combination of regulatory, financial, and 
administrative factors often results in delays in achieving milestones, and thus 
amendment procedures to adjust timelines, especially for innovative or capital-
intensive projects. 

Amendments are not always accepted, especially if they can change the scope of a 
project in a way that fundamentally alters its original design and could put into 
question the award decision. Changes in innovation level, GHG emissions reduction 
potential, or replicability were thus not identified as the main reasons for amendments 
or terminations. 

122 

 
 
 
 
 
Evaluation sub-question 

Indicator 

Judgment criteria 

Data source 

4.  COHERENCE 

Evaluation 
question 

18. How 
internally 
coherent are 
the 
components of 
the Fund? 

18.a. Internal goal alignment - 
How are the Fund 'activities' (e.g. 
calls for proposals, PDA, 
technical assistance, blending 
operations, AaaS) aligned with its 
objectives (business investment in 
clean energy and industry, boost 
economic growth, create future-
proof jobs, reinforce European 
technological leadership on a 
global scale e.g. awarding projects 
with significant GHG reduction 
potential, cost-effectiveness -
effectiveness, geographical 
balance in revenue management)? 

18.b. Barriers and target conflicts 
- Which of the Fund 'activities' 
constitute a barrier or target 
conflict with its objectives? 

19. How 
externally 

19.a. External goal certainty - 
What are the main, overarching, 

Alignment: number of sub-
objectives an activity is aligned 
to (0 to 9) 

Potential for synergies: number 
of other activities also 
contributing to sub-objectives (0 
to 16) 

Degree of internal synergy: 
triangulation between Fund data 
(e.g. correspondence between 
sectors of awarded proposals 
and objectives of the Fund) and 
stakeholders’ feedback 

Cohesiveness & 
complementarity: 8:8 matrix on 
whether activities facilitate the 
success of other activities and 
indirectly improve the outcomes 
of objective contributions 
(Scores 0, 1, or 2) 

Triangulation between literature 
review and stakeholders’ 
feedback 

Degree of internal impediment:  

Alignment of objectives: 
Triangulation between Fund 
123 

Indication of changes from 
concrete (i) corroborative findings, 
(ii) caveats and contradictions, (iii) 
new insights in 
surveys/interviews/case-studies 
compared to initial a priori 
assessment 

Minimum gaps between activities 
and objectives 

Indication of changes and 
identification of target conflicts and 
barriers from concrete evidence 
(surveys, interviews, case-studies) 
compared to initial a priori 
assessment 

Minimum barriers and conflicts 

Desk research from 
qualitative sources: Fund 
documents (e.g. progress 
reports), literature review 

Desk research from 
quantitative sources: Fund 
data (awarded proposals) 

Surveys: beneficiaries, 
Horizon Europe, NCPs, 
unsuccessful applicants 

Interviews: beneficiaries, 
national authorities, trade and 
business associations; the 
Commission, CINEA, the 
EIB 

Case studies 

Types and occurrences of synergy 
of calls with the main objectives of 

Desk research from 
qualitative sources: Fund 

 
 
documents, literature review and 
stakeholders’ feedback 

EU climate and energy 
policies/initiatives 

coherent is the 
Fund with 
other EU 
policies and 
initiatives? 

objectives of EU climate and 
energy policies/initiatives (Net 
Zero Industry Act, STEP, 
European Hydrogen Strategy, 
Integrated SET Plan, Industrial 
Technology Roadmaps, New 
Industrial Strategy for Europe, 
Green Deal Industrial Plan, 
Circular Economy Action Plan, 
Bioeconomy Strategy, EU 
Biodiversity Strategy for 2030, 
Industrial Carbon Management 
Strategy, Offshore energy 
strategy, EU Solar Strategy) and 
to which degree are there 
synergies with the Fund’s calls? 

19.b. Alignment with EU 
legislation - To which degree are 
calls for proposals aligned/with 
other relevant EU legislation (e.g. 
ETS Directive, European Climate 
Law, Batteries Regulation, 
REPowerEU, Renewable Energy 
Directive, ReFuelEU Aviation, 
FuelEU Maritime) 

Alignment of objectives: 
triangulation between literature 
review, analysis of relevant 
legislation and stakeholders’ 
feedback 

Degree of external alignment 

High alignment, i.e. Fund calls do 
not create frictions or overlaps with 
other EU legislation sharing similar 
objectives 

124 

documents (e.g. list of past 
and future calls), literature 
review 

Desk research from 
quantitative sources: Fund 
data (awarded proposals) 

Surveys: beneficiaries, 
Horizon Europe, NCPs, 
unsuccessful applicants 

Interviews: beneficiaries, 
national authorities, trade and 
business associations; the 
Commission, CINEA, the 
EIB 

Case studies 

Desk research from 
qualitative sources: Fund’s 
documents (e.g. list of past 
and future calls), literature 
review 

Desk research from 
quantitative sources: Fund 
data (awarded proposals) 

Surveys: beneficiaries, 
unsuccessful applicants, 
Horizon Europe, NCPs 

Interviews: beneficiaries, 
national authorities, trade and 
business associations; the 

 
 
19.c. Synergy with EU Funding 
and Research Programmes - To 
which degree do the Fund’s 
activities complement other EU 
programmes in such a way that 
they can function as a follow-up 
of projects with a low commercial 
readiness level and a suitable pre-
cursor for further 
commercialisation, funding and 
market success? (e.g. Horizon 
Europe, IPCEIs, Invest EU, CEF, 
Cohesion Fund)? 

Obstacles and factors that 
potentially enhance or reduce 
synergies between Innovation 
Fund and these EU programmes: 
triangulation between literature 
review and stakeholders’ 
feedback across the three 
funding instruments (calls, 
XaaS, blending operations 
compared to other EU 
programmes) 

Degree of external 
complementarity 

High complementarity, i.e. 
beneficiaries from Horizon Europe 
also apply for Fund, and 
beneficiaries from Fund also apply 
for Invest EU) 

Answers to evaluation sub-questions 

Indicators 

Results 

EQ18. How internally coherent are the components of the Fund? 

Commission, CINEA, the 
EIB 

Case studies 

Desk research from 
qualitative sources: Fund 
documents (e.g. progress 
reports), literature review 

Desk research from 
quantitative sources: Fund 
data (awarded proposals) 

Surveys: beneficiaries, 
unsuccessful applicants, 
Horizon Europe beneficiaries 

Interviews: beneficiaries, 
national authorities, trade and 
business associations, the 
Commission, CINEA, the 
EIB 

Case studies 

125 

 
 
 
 
EQ18.a - The Fund’s design shows strong 
internal coherence, with core mechanisms 
closely aligned to its decarbonisation 
objectives and complementary 
instruments effectively broadening its 
reach and coverage. 

Alignment: number of sub-
objectives an activity is 
aligned to (0 to 9) 

Potential for synergies: 
number of other activities 
also contributing to sub-
objectives (0 to 16) 

Activity 

Alignment 

Cohesiveness & 
complementarity 

Synergy Coherence 

A1: Calls for 
‘regular’ grants 
A2: Auctions 
A3: Technical 
assistance 
A4: Support to 
applicants 
A5: PDA 
A6: Blending 
operations 
A7: ‘as-a-service’ 
schemes 
A8: Knowledge 
sharing & 
communication 

high 

high 

very low 

low 

low 

low 

low 

low 

high  medium 

very high 

high 

very low 

low 

high 

very low 

low 

medium 

high  medium 

medium 

very low 

high 

low 

medium 

very low 

high 

low 

very low 

very high 

very low 

low 

low 

Total 
Funding activities  medium 
Supporting 
activities 

very low 

medium 
low 

medium  medium 
high  medium 

high 

low 

low 

EQ18.b – The most critical barriers to 
alignment between the Fund activities and 
its objectives stem from the Fund’s 
design, a demanding application process 
and systemic and structural issues. 

Cohesiveness & 
complementarity: 8:8 
matrix (Scores 0, 1, or 2) 

Triangulation between 
literature review and 
stakeholders’ feedback 

See above. 

E19. How externally coherent is the Fund with other EU policies and initiatives? 

126 

 
 
 
EQ19.a - The Fund has a high degree of 
external coherence with the main goals of 
EU climate and energy policies. 

Alignment of objectives: 
Triangulation between 
Fund documents, literature 
review and stakeholders’ 
feedback 

EQ19.b - The Fund demonstrates a high 
degree of external coherence with EU 
legislation, a finding consistently 
supported across qualitative desk 
research, surveys, and case studies. 

Alignment of objectives: 
triangulation between 
literature review, analysis 
of relevant legislation and 
stakeholders’ feedback 

EQ19.c - The Fund demonstrates a strong 
potential to function as a follow-up to 
Horizon Europe. Despite some 
operational friction, there are also 
possible synergies with programmes 
funding large-scale infrastructure (like 
CEF) or supporting lower-income 
Member States (like the Modernisation 
Fund). The Fund's activities show varying 
degrees of coherence with national 
programmes 

Obstacles and factors that 
potentially enhance or 
reduce synergies between 
the Fund and these EU 
programmes: triangulation 
between literature review 
and stakeholders’ feedback 
on funding activities 

Robust evidence observed from various sources. 

Robust evidence observed from various sources. 

High complementarity is anticipated due to common objectives. However, the 
Fund’ strong potential to function as a follow up to Horizon Europe has 
limitations, notably because of the differences between both programmes 
objectives and application cycles. 

127 

 
 
 
 
 
 
5.  RELEVANCE 

Evaluation 
question 

20. To what 
extent do the 
Fund’s 
objectives 
remain relevant 
given the current 
context of 
climate action 
and 
technological 
development 
needs? 

Evaluation sub-question 

Indicator 

Judgment criteria 

Data source 

20.a1. Relevance in the 
current policy context - To 
what extent do the scope and 
the objective of the Fund 
remain relevant over the 
implementation period? 

How do the Fund objectives 
still correspond to the current 
context of climate action? 

20.a2. Relevance in the 
current technology context - 
Do the Fund objectives still 
correspond to the current 
context of technology 
development needs? 

20.b. Future relevance 
projections - Will the Fund 
objectives remain relevant 
based on the expected 
evolution in the coming 
years? 

Persistence of the policy 
objective and degree of 
alignment with current EU 
policy goals: triangulation 
between literature review, 
analysis of policy documents 
and stakeholders’ feedback 

High relevance in the 
current context 

State of current technology 
development, existing 
technologies, current progress in 
technologies and maturity, and 
technology needs 

High relevance in the 
current context 

Existing projections, foresight 
analysis and trend changes 

Continued relevance in 
future contexts 

Desk research from qualitative sources: 
Fund documents and literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries 

Interviews: beneficiaries, national 
authorities, trade and business 
associations; the Commission, CINEA, 
the EIB 

Case studies 

Desk research from quantitative 
sources: data from the International 
Energy Agency, Eurostat, EEA, 
patents, venture capital 

Desk research from qualitative sources: 
Fund documents and literature review 

Surveys: beneficiaries; unsuccessful 
applicants, Horizon Europe 
beneficiaries 

Interviews: beneficiaries, national 
authorities, NCPs, trade and business 
associations; the Commission, CINEA, 
the EIB 

20.c. Necessity for EU-Level 
action - Do the 
problems/needs still require 

EU dimension of the problems 
that the Fund intends to address 
triangulation between literature 

128 

High necessity for EU-level 
action 

Desk research from qualitative sources: 
Fund documents and literature review 

 
 
action at the EU level? 
(linked to EU added value) 

review, policy documents and 
stakeholders’ feedback 

Persistence of the problems in 
case of non-EU action: 
triangulation between literature 
review, policy documents and 
stakeholders’ feedback 

21.a. Targeting high-potential 
sectors - How effectively 
does the Fund target sectors 
with the highest potential for 
GHG emissions reduction? 

Allocation of funds to high-
potential sectors 

Significant allocation to 
high-potential sectors 

21. How well do 
the Fund’s 
objectives 
address current 
challenges in 
reducing GHG 
emissions and 
promoting 
innovation? 

21.b. Promoting innovation 
in climate technologies - 
How relevant is the Fund in 
promoting innovation in 
climate technologies? 

Level of innovation in funded 
projects 

Investment gaps at TRL levels 
covered by the Fund 

Replicability of projects funded 
by the Fund 

Interviews: beneficiaries, national 
authorities, trade and business 
associations; the Commission, CINEA, 
the EIB 

Case studies 

Desk research from quantitative 
sources: data from the International 
Energy Agency, Eurostat, the 
Environment Agency, patents, venture 
capital 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries 

Desk research from qualitative sources: 
Fund documents and literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries 

Interviews: beneficiaries, national 
authorities, trade and business 
associations; the Commission, CINEA, 
the EIB 

High level of innovation 

Case studies 

Desk research from quantitative 
sources: data from the International 
Energy Agency, Eurostat, the 
Environment Agency, patents 

22. How 
adaptable are the 
Fund’s 

22.a. Anticipation of future 
trends - How well do the 
Fund objectives anticipate 

Degree of anticipation of future 
trends: triangulation between 

High anticipation of future 
trends 

Desk research from qualitative sources: 
Fund documents and literature review 

129 

 
 
objectives to 
future needs and 
emerging issues? 

future trends and challenges 
in climate policy? (link to 
1.b) 

literature review and 
stakeholders’ feedback 

22.b. Flexibility and 
adaptability - How flexible is 
the Fund in adjusting to new 
technological developments 
and policy changes? 

Stakeholders’ feedback on 
mechanisms for flexibility and 
adaptation through the different 
activities and objectives of calls 

High flexibility and 
adaptability 

23. How relevant 
are the Fund's 
objectives at the 
national level? 

23.a. Alignment with national 
policies - How well do the 
Fund objectives align with 
national climate and energy 
policies of eligible countries? 

Degree of alignment with 
national policies and plans: 
triangulation between literature 
review, policy documents at 
national level and stakeholders’ 
feedback 

High alignment with 
national policies 

24. How well do 
the Fund’s 
activities align 
with the current 
needs of 
European 
industry? 

24.a. Relevance to European 
industry needs - How well do 
the Fund’s activities meet the 
current needs of European 
industry? 

Needs of industry at the times of 
Fund launch 

Simplification measures 
compared to NER 300 
programme: triangulation 
between literature review, policy 
documents and stakeholders’ 
feedback 

Needs of industry beyond direct 
financial support 

130 

High relevance to industry 
needs 

Surveys: beneficiaries, unsuccessful 
applicants 

Interviews: beneficiaries, national 
authorities, trade and business 
associations; the Commission, CINEA, 
the EIB 

Desk research from qualitative sources: 
Fund documents and literature review 

Surveys: beneficiaries, NCPs, Horizon 
Europe beneficiaries 

Interviews: beneficiaries, national 
authorities, trade and business 
associations; the Commission, CINEA, 
the EIB 

Desk research from quantitative 
sources: data from Eurostat 

Desk research from qualitative sources: 
Fund documents and literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries 

Interviews: beneficiaries, national 
authorities, trade and business 
associations; the Commission, CINEA, 
the EIB 

Case studies 

 
 
 
Desk research from quantitative 
sources: Fund data on awarded and 
non-awarded proposals 

Answers to evaluation sub-
questions 

Indicators 

Results 

EQ20. To what extent do the Fund’s objectives remain relevant given the current context of climate action and technological development needs? 

EQ20.a.1 - Over the 
evaluation period, the Fund’s 
legal framework has evolved 
to align with the EU’s 
increasingly ambitious 
climate targets, thereby 
adapting to new policy 
contexts and proving its 
continued relevance. 

EQ20.a.2 - The Fund’s focus 
on highly innovative and 
mature solutions corresponds 
to current technology 
development needs, although 
some gaps remain. 

EQ20.b - The Fund’s 
objectives are expected to 
remain relevant in the coming 
years due to substantial 
investment gaps and long 
deployment cycles for 
industrial decarbonisation. 

Persistence of the policy 
objective and degree of 
alignment with current EU policy 
goals: triangulation between 
literature review, analysis of 
policy documents and 
stakeholders’ feedback 

State of current technology 
development, existing 
technologies, current progress in 
technologies and maturity, and 
technology needs 

Evidence sources confirm that the Fund’s objectives remain closely tied to the EU’s 
current policy framework and objectives. 

Evidence sources confirm the Fund’s continued relevance in the current context, whil 
pointing to a few gaps. 

Existing projections, foresight 
analysis and trend changes 

Desk research analysis estimates a financing gap of EUR 50-92 billion by 2030, 
especially for green steel, cement, CCS and long-duration storage. The Fund would 
serve as a key instrument to help close this gap. 

131 

 
 
 
 
EQ20.c - Evidence 
consistently points to the 
continuing need for EU-level 
action to address problems of 
scale, coordination and 
competitiveness in industrial 
decarbonisation. 

EU dimension of the problems 
that the Fund intends to address 
triangulation between literature 
review, policy documents and 
stakeholders’ feedback 

Persistence of the problems in 
case of non-EU action: 
triangulation between literature 
review, policy documents and 
stakeholders’ feedback 

Fragmented national investment efforts and limited fiscal capacity in several Member 
States risk widening industrial disparities, underscoring the need for stronger EU-level 
financing instruments (such as the Fund), to mobilise capital at scale and ensure 
cohesion in the transition. 

As above. 

EQ21. How well do the Fund’s objectives address current challenges in reducing GHG emissions and promoting innovation? 

EQ21.a - The Fund directs its 
support towards sectors with 
substantial potential for 
emissions reduction, though 
coverage is uneven. 

EQ21.b - The Fund is 
structured to promote high 
innovation in climate 
technologies. 

Allocation of funds to high-
potential sectors 

The EU ETS Directive covers sectors having the most substantial potential for 
emission reductions. By design, the Fund thus effectively targets sectors with the 
highest potential for GHG emissions reduction. 

Level of innovation and 
replicability of funded projects 

See EQ1.a 

Investment gaps at TRL levels 
covered by the Fund 

Survey responses from unsuccessful applicants indicate that not all advanced 
proposals (at TRL 6–8) could be supported, highlighting that available resources are 
not sufficient. 

EQ22. How adaptable are the Fund’s objectives to future needs and emerging issues? 

132 

 
 
EQ22.a - The Fund’s 
approach to anticipating 
future climate and policy 
challenges relies on its 
financial structure, 
consultation processes, and 
alignment with broader EU 
priorities. 

EQ22.b - The Fund’s 
flexibility in adjusting to new 
technological and policy 
changes is attested by its 
evolving regulatory 
framework, award criteria, 
and call structure (also see 
EQ20.a.1). 

Degree of anticipation of future 
trends: triangulation between 
literature review and 
stakeholders’ feedback 

Theoretically high. 

Stakeholders’ feedback on 
mechanisms for flexibility and 
adaptation through the different 
activities and objectives of calls 

The Fund’s calls for proposals are considered a strength, as they allow adjustments to 
new policy directions. Feedback loops between evaluators and CINEA have supported 
further refinements, making the programme more responsive over time. 

EQ23. How relevant are the Fund's objectives at the national level? 

EQ23.a - The Fund’s 
objectives align broadly with 
the national climate and 
energy policies of eligible 
countries, though the degree 
of complementarity varies. 

Degree of alignment with 
national policies and plans: 
triangulation between literature 
review, policy documents at 
national level and stakeholders’ 
feedback 

Despite a broad alignment, procedural and structural barriers can limit the Fund’s 
objectives effective integration with domestic strategies. 

EQ24. How well do the Fund’s activities align with the current needs of European industry? 

EQ24.a - Building on lessons 
learned from NER 300, the 

Needs of industry at the times of 
Fund launch 

During the Fund’s design phase, extensive consultations with industry stakeholders 
took place to inform adjustments compared to NER 300. 

133 

 
 
Fund was designed to meet 
industry needs at the time of 
its launch. It still addresses 
industry needs beyond direct 
financial support, but some 
gaps remain. 

Simplification measures 
compared to NER 300 
programme: triangulation 
between literature review, policy 
documents and stakeholders’ 
feedback 

Needs of industry beyond direct 
financial support 

The Fund introduced milestone-based disbursements, allowing up to 40 % of funding 
to be paid before projects begin delivering verified emission reductions, thereby 
supporting financial close. 

Governance was streamlined to reduce administrative complexity. 

The Fund allows EU-wide competition, complemented by simplified procedures for 
small-scale projects and targeted technical assistance. 

Surveys, including the public consultation and case studies, confirm that the Fund is 
perceived as relevant to priority sectors such as hydrogen, cement, steel, and 
chemicals, while also providing reputational and signalling benefits that strengthen 
investor confidence and partnerships. 

134 

 
 
 
 
6.  EU ADDED VALUE 

Evaluation 
question 

Evaluation sub-question 

Indicator 

Judgment criteria 

Data source 

25.a. Unique benefits of the Fund in 
terms of scale and scope - How does 
the scale and scope of the Fund 
compare to national initiatives? 

To what extend has the Fund allowed 
the supported projects to be realised? 
Would projects have happened 
without Fund support? 

Could the projects be realised through 
support by national authorities only 
(without the Fund)? 

25.b. Unique transnational benefits of 
the Fund - What are the transnational 
benefits (e.g. cross-border 
collaborations) facilitated by the 
Fund? 

25.c. Unique benefits of the Fund in 
terms of technological progress - How 
does the Fund foster innovation that 
would be unlikely at the national 
level? 

25. What unique 
benefits does the 
Fund provide that 
cannot be achieved 
by national 
initiatives alone? 

Desk research from qualitative sources: 
Fund documents, literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries, NCPs 

Interviews: beneficiaries, national 
authorities, NCPs, trade and business 
associations, the Commission, CINEA, 
the EIB 

Desk research from qualitative sources: 
Fund documents and literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries, NCPs 

High level of 
innovation unique to 
EU-level action 

Interviews: beneficiaries, national 
authorities, trade and business 
associations, the Commission, CINEA, 
the EIB 

Comparison of Fund’s scale 
and scope with similar 
national initiatives 

Larger scale and 
broader scope than 
national initiatives 

Number and quality of 
cross-border projects 

Significant 
transnational 
benefits 

Number (or value) of 
follow-on investments 
resulting from initial 
Innovation Fund financing 

Stakeholders’ feedback on 
likelihood of funding at 
national level for projects 
with similar innovation 
levels as funded projects 

Critical level of funding 
mobilised 

135 

 
 
26.a. Enhanced impact of climate 
action compared to national level - 
What are the cumulative GHG 
reductions achieved through the Fund 
compared to national efforts? 

Is it still valid to assume that the 
objectives of the Fund can best be met 
by action at EU level? 

What would be the most likely 
consequences of stopping the Fund? 

26.b. Pathways to enhanced impact of 
climate action at EU level - How does 
the Fund improve the cost-
effectiveness of climate action in the 
EU? 

27.a. Contribution to growth and job 
creation - How does the Fund support 
economic growth, competitiveness and 
job creation in the EU? 

27.b. Contribution to skills acquisition 
- How does the Fund support skills 
acquisition in the EU? 

26. How does the 
Fund enhance the 
overall impact of 
climate action 
across the EU? 

27. In what ways 
does the Fund 
contribute to EU 
policy objectives 
beyond the 
reduction of GHG 
emissions? 

Total expected GHG 
reductions (tons CO2e) 

Greater expected 
cumulative GHG 
reductions 

Cost per ton of CO2e 
reduced 

Lower cost per unit 
of GHG reduction 

Desk research from qualitative sources: 
Fund documents, literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries, NCPs 

Interviews: beneficiaries, national 
authorities, trade and business 
associations, the Commission, CINEA, 
the EIB 

Expected number of jobs 
created 
Expected increase in 
companies' turnovers 

Number of cross-sector or 
cross-border partnerships 
formed 

Number of workshops, 
seminars, or training 
sessions conducted as part 
of Fund projects 

Number of workers who 
received training or 
upskilling as part of Fund 
projects 

136 

Significant economic 
growth and job 
creation 

Significant 
acquisition of skills 
relevant to the EU 
climate objectives 

Desk research from qualitative sources: 
literature review 

Surveys: beneficiaries 

Interviews: beneficiaries, national 
authorities, trade and business 
associations, the Commission, CINEA, 
the EIB 

Desk research from qualitative sources: 
Fund documents, literature review 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries, NCPs 

Interviews: beneficiaries, national 
authorities, trade and business 

 
 
 
Evidence of reduced skill 
gaps in key sectors aligned 
with the Fund objectives 

27.c. Contribution to innovation in 
climate action - How does the Fund 
enhance the EU’s technological 
leadership in climate action? 

Number of new 
technologies developed and 
deployed 
Technological spillovers 
across sectors 

Significant 
advancements in 
technological 
leadership 

27.d. Contribution to social and 
regional cohesion - How does the 
Fund contribute to social and regional 
cohesion within the EU? (linked to 
relevance) 

Geographic distribution of 
funded projects 

Share of projects that aim to 
enhance local infrastructure 
(e.g. energy access, public 
facilities) 

Share of projects that aim to 
address community needs 
(e.g. healthcare, housing, 
education) 

Share of projects that aim to 
reduce social or regional 
disparities (e.g. bridging 
rural–urban gaps)  

137 

Improved social and 
regional cohesion 

associations, the Commission, CINEA, 
the EIB 

Desk research from qualitative sources: 
Fund documents (reporting), literature 
review 

Desk research from quantitative 
sources: Fund data on awarded 
proposals 

Surveys: beneficiaries, unsuccessful 
applicants, Horizon Europe 
beneficiaries, NCPs 

Interviews: beneficiaries, national 
authorities, trade and business 
associations, the Commission, CINEA, 
the EIB 

Desk research from qualitative sources: 
Fund documents (reporting), literature 
review 

Desk research from quantitative 
sources: Fund data on awarded 
proposals 

Surveys: beneficiaries 

Interviews: beneficiaries, national 
authorities, trade and business 
associations, the Commission, CINEA, 
the EIB 

 
 
27.e. Leverage of additional resources 
- How does the Fund enhance 
synergies with other EU funding 
programmes and policies? 

Number of projects 
benefiting from the support 
of multiple EU programmes 

Quality of synergistic 
projects 

Enhanced synergies 
with other EU 
programmes 

Desk research from qualitative sources: 
Fund documents (reporting) 

Desk research from quantitative 
sources: Fund data on awarded 
proposals 

Surveys: beneficiaries, unsuccessful 
projects, Horizon Europe beneficiaries, 
NCPs 

Interviews: beneficiaries, national 
authorities, trade and business 
associations, the Commission, CINEA, 
the EIB 

Answers to evaluation sub-questions 

Indicators 

Results 

EQ25. What unique benefits does the Fund provide that cannot be achieved by national initiatives alone? 

EQ25.a - Compared to similar national 
initiatives, the Fund stands out for its 
larger scale and its specific focus on the 
deployment of innovative net-zero 
technologies. 

EQ25.b - The Fund’s design (as an EU-
level mechanism to compete for 
funding) and its emphasis on projects 
with high replication potential enable 
unique transnational benefits (e.g. 
cross-border collaborations), driving the 
spread of innovation and fostering 
knowledge transfer across countries. 

Comparison of Fund’s scale and 
scope with similar national 
initiatives 

The comparative analysis (see EQ16.a), supported by interviews with 
policymakers and beneficiaries, confirms that while national programmes 
are substantial, the Fund’s scale, targeted focus and transnational reach 
provide unique benefits that could not be fully replicated only through 
national efforts. 

Number and quality of cross-
border projects 

Out of 1342 proposals evaluated as of end of Q1 2025, 25 were led by 
partners from multiple countries (out of which 6 projects were eventually 
awarded). 

138 

 
 
 
 
 
EQ25.c - The Fund plays a pivotal role 
in fostering innovation that would be 
unlikely at national level. However, it is 
difficult to assess if projects would have 
happened without the Fund’s support or 
with national funding only. 

Number/value of follow-on 
investments resulting from initial 
Innovation Fund financing 

Critical level of funding 
mobilised 

Stakeholders’ feedback on 
likelihood of funding at national 
level for projects with similar 
innovation levels as funded 
projects 

See EQ1.e 

80 % of surveyed beneficiaries (98 out of 124) stated they would not have 
been able to realise their project solely with the support of national-level 
programmes and initiatives. But there is also evidence that a substantial 
portion of projects might have been implemented without EU-level support. 
It remains difficult to quantify the EU’s added value relative to alternative 
national funding scenarios. 

EQ26. How does the Fund enhance the overall impact of climate action across the EU? 

EQ26.a - Although substantial, the 
Fund’s expected cumulative GHG 
emissions reductions remain a fraction 
of EU-wide reductions. The Fund’s 
added value lies in its capacity to 
support innovation in hard-to-abate 
sectors, thereby accelerating 
decarbonisation and systemic change. 

EQ26.b - The Fund improves the cost-
effectiveness of climate action in the 
EU by using a competitive process to 
allocate grants, thus ensuring that only 
the most innovative and cost-effective 
projects receive support. 

Total expected GHG reductions 
(tCO2e) 

As of the end of March 2025, 192 funded projects were anticipated to avoid 
over 870 mtCO2e over their first decade of operation. 

Cost per tCO2e reduced 

See EQ16.a 

EQ27. In what ways does the Fund contribute to EU policy objectives beyond the reduction of GHG emissions? 

EQ27.a – The Fund supports economic 
growth, competitiveness and job 

Expected number of jobs created 

The Fund supports employment creation and skills development, with an 
estimated 26 000 direct jobs created by the existing portfolio. 

139 

 
 
creation in the EU, particularly by 
targeting hard-to-abate sectors and 
supporting first-of-a-kind 
demonstrations designed for replication. 

EQ27.b - Skills acquisition occurs as a 
co-benefit of demonstrating first-of-a-
kind technologies, with workforce 
development appearing organically 
during project implementation. 

EQ27.c - The Fund is essential to 
enhance the EU’s technological 
leadership in climate action. 

Expected increase in companies' 
turnovers 

Many projects expecting annual turnover increases of over EUR 10 million. 

Number of cross-sector or cross-
border partnerships formed 

See EQ25.b 

Number of workshops, seminars, 
or training sessions conducted as 
part of Fund projects 

Number of workers who received 
training or upskilling as part of 
Fund projects 

Evidence of reduced skill gaps in 
key sectors aligned with the Fund 
objectives 

Number of new technologies 
developed and deployed 

Too early to assess. 

25 sectors represented in the portfolio 

Technological spillovers across 
sectors 

See EQ25. 

Geographic distribution of funded 
projects 

See EQ3.a 

140 

 
 
EQ27.d - Funded projects contribute to 
social and regional cohesion within the 
EU to some extent. 

EQ27.e - Funded projects effectively 
leverage additional resources, showing 
that the Fund enhances synergies with 
other EU funding programmes and 
policies, primarily through its de-
risking effect. 

Share of projects that aim to 
enhance local infrastructure (e.g. 
energy access, public facilities) 

Share of projects that aim to 
address community needs (e.g. 
healthcare, housing, education) 

Share of projects that aim to 
reduce social or regional 
disparities (e.g. bridging rural–
urban gaps) 

Number of projects benefiting 
from the support of multiple EU 
programmes 

Monitoring data is missing. 

Quarterly reports show that 38 projects (out of 208 projects awarded, so 18 
%) reported existing synergies with other EU initiatives. 

Quality of synergistic projects 

See EQ1.a 

141 

 
 
 
 
Annex IV Overview of benefits and costs, table on simplification and burden reduction 

142 

 
 
 
 
 
Table 1. Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Direct costs related to implementation (administrative costs, financial and labour costs) 

Impact assessment: 
Not applicable. 

Impact assessment: 
No costs for the citizens. 

Evaluation: 
Not applicable. 

Evaluation: 
No evidence to suggest any cost 
was passed to citizens or 
consumers since the start of the 
Fund. 

Impact assessment: 
A reduction compared to the 
baseline (NER 300). 

Evaluation: 
EUR2024 17.6 million  
(administrative costs related to 
monitoring and reporting for 
2020-2024) 

Recurrent 

Impact assessment: 
However, the baseline 
for institutional 
administrative costs 
was not quantified. 

Evaluation: 
[missing: share of 
admin budget (in 
relation to all grants 
disbursed) then 
compared to Horizon 
Europe, LIFE and 
NER 300] 

Impact assessment: 
Recurrent costs will involve 
reporting related to the 
achievement of milestones 
at the commissioning, ramp-
up and entry into operation, 
audits, and periodic 
reporting during the 
operation. However, the 
baseline was not quantified. 

Evaluation: 
This figure does not 
consider that beneficiaries 
are in any case preparing 
many of the documents 
required for other purposes, 
so the direct costs are likely 
to be exaggerated. 

Impact assessment: 
For EU institutions, low 
administrative costs compared 
to the baseline. For national 
authorities, access to 
simplified, faster and more 
efficient structure to support 
innovative projects compared 
to the baseline. 

Evaluation: 
EU institutions (2020-2024): 
DG CLIMA: EUR2024 34 
million 
CINEA: EUR2024 43 million 
EIB: EUR2024 23.7 million 
Innovation Fund grants: 
EUR2024 9.5 billion 
Co-financing with other EU 
initiatives: EUR2024 95 million 
Blending operations: EUR2024 
329 million 

National authorities (2020-
2024): 
NCPs activities: EUR2024 19 
million 
Co-financing: EUR2024 2.6 
billion 

One-off 

Impact assessment: 
Not applicable. 

Impact assessment: 
Not applicable. 

Impact assessment: 

Impact assessment: 

Impact assessment: 

Impact assessment: 

143 

Direct costs related to applying to the Fund 

 
 
                        
 
 
 
 
 
 
 
Evaluation: 
Not applicable. 

Evaluation: 
Not applicable. 

A reduction compared to the 
baseline. 

The baseline was not 
quantified. 

A reduction compared to the 
baseline. 

The baseline was not 
quantified. 

Evaluation: 
EUR2024 0.3 million 
(EIB) 

Evaluation: 
One-off administrative 
fee. 

Impact assessment: 
Not quantified. 

Evaluation: 
Not evaluated. 

Impact assessment: 
GHG reduction/avoidance 
achieved through the operation 
of the fund contributing to the 
achievement of national 
emission reduction targets, and 
of national renewables and 
energy efficiency targets. 
Opportunities for co-financing 
projects supported by the fund 
and the creation of parallel 
and/or synergetic funding 
mechanisms. 

Evaluation: 
Not applicable. 

Evaluation: 
EUR2024 17.7 million  
(administrative costs related to 
applying) 

Average EUR2024 120 000 costs 
for application (85 000 external 
and 35 000 internal costs, data 
based on survey results) 

Direct benefits 

Impact assessment: 
Estimated investment volume for 
low-carbon technologies: EUR 
55 to 68 billion. 

Evaluation: 
Innovation Fund grants: EUR2024 
9.5 billion 
Private investments mobilised: 
EUR2024 52 billion 
EIB: EUR2024 23.7 million 
Co-financing with other EU 
initiatives: EUR2024 95 million 
Blending operations: EUR2024 
329 million 

Evaluation: 
The application costs reflect 
the larger scale and greater 
complexity of the 
Innovation Fund’s 
requirements compared to 
other funds (Horizon 
Europe: EUR2024 35 000). 
The external costs of the 
application represent 0.15 % 
of the average contribution 
from the Fund (compared to 
3-5 % for Horizon Europe). 

Impact assessment: 
The investment volume, 
which the Fund will 
effectively be able to 
support, will critically 
depend on the carbon price. 

Evaluation: 
The private co-financing 
shows a leverage of over 5x 
of the private capital. 

144 

Recurrent 

Impact assessment: 
GHG emissions 
avoided by supported 
projects: EUR 608 to 
1400 investment 
related to each tonne 
of CO2e abated on a 
sample of 
technologies. 
From this we can 
calculate that for 
every EUR 1 million 
of investment 
between 714 and 1 
643 tCO2e was 
supposed to be 
abated. 

Evaluation: 
871.2 mtCO2e for 10 
years for 192 active 
projects. 

Impact assessment: 
Avoided emissions are a 
function of the undertaken 
investments. A comprehensive 
estimation was not possible for 
the expected emissions 
reductions. 
Generated employment is a 
function of the undertaken 
investments. A comprehensive 
estimation was not possible. 

Evaluation: 
The expected benefits have 
been realised and the costs per 
CO2e avoided related to them 
are in the higher end of what 
was anticipated. 
Beneficiaries’ survey responses 
indicate that almost all expect 
to create direct jobs. About 43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total capital 
expenditure: EUR 
56.4 billion, which 
results in EUR 647 
of investment related 
to each tonne of 
CO2e abated. 
Hence, for every 
EUR 1 million of 
investment, 1 547 
tCO2e is abated. 

Impact assessment: 
Positive externalities 
resulting from low-
carbon technologies 
passed on through 
the value chain and 
improving access to 
sustainable products 
and services for 
citizens. 
Positive 
environmental 
impacts (reduction of 
pollutants associated 
with fossil fuels 
combustion). 

Evaluation: 
The health benefits 
of the Fund’s 
activities manifest as 
improved air quality, 
resulting from the 
avoidance of GHG 
emissions from fossil 

% of respondents reported that 
their project would create at 
least 50 jobs. When aggregated 
and extrapolated to all 192 
ongoing projects, the survey 
results suggest the creation of 
an estimated 25 000 jobs. 
Since detailed information was 
not provided, the employment 
effect cannot be monetised. 

Impact assessment: 
Not quantified. 

Evaluation: 
Expected GHG emissions 
avoided should have a 
significant impact on air 
pollutants and hence on human 
health. However, no data on 
avoided non-GHG emissions 
(PM2.5, O3, NOx, or SO2) are 
available. It is thus not possible 
to estimate the reduction in 
these emissions linked to the 
Fund’s activities in a 
quantitative manner, nor to 
monetise the Fund’s impacts on 
human health. 
Reduced air pollution levels 
may also benefit the natural 
environment. The Fund may 
thus contribute to 
environmental health benefits 
through lower ozone and 
nitrogen emissions. 

Recurrent 

Indirect benefits 

Impact assessment: 
Roll-out of low-carbon 
technologies after 2030 (broader 
adoption due to demonstration 
effect and technology transfer). 
Increased competitiveness of EU 
industry (global leadership on 
low-carbon technologies). 
New opportunities in sustainable 
finance contributing to the 
achievement of sustainable 
finance targets, diversification of 
investment 
portfolio. Development of new 
markets and new business models 
and partnerships with technology 
service providers and cross-
fertilization through the creation 
of collaborative consortia for 
cross- 
sectorial technologies. 
Indirect benefits across value 
chains resulting from the 
adoption of low-carbon 
technologies; also, some 
potential for technology transfer. 

145 

Impact assessment: 
Not quantified 

Impact assessment: 
Not applicable. 

Impact assessment: 
Not applicable. 

Evaluation: 
Not applicable. 

Evaluation: 
Not applicable. 

Evaluation: 
On supporting local 
economies, the results 
suggest that while the Fund 
generates substantial 
investment leverage across 
Europe, its capacity to 
stimulate domestic 
economic activity varies by 
national context and 
industrial capacity. On 
competitiveness, the study 
reveals that the Fund’s 
support is necessary, but not 
sufficient, to enhance 
competitiveness in a 
structured way. Funding 
needs to be complemented 
by national policy actions. 
On the development of new 
markets, it is too early to 
assess. 

 
 
 
 
 
 
 
 
sources, which the 
Fund achieves. 

Evaluation: 
Not applicable. 

146 

 
 
 
 
 
 
TABLE 2:  Simplification and burden reduction (savings already achieved) 

Citizens/Consumers/Workers 

Businesses 

Administrations 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Direct compliance cost savings 

Recurrent 

Not applicable. 

Not applicable.  EUR 1.1-.3.8 million in savings 

to applicants, following the 
simplification applied for the 
IF24 call (compared to the IF23 
call). 

Not applicable.  Not 

applicable. 

The provided estimate of the achieved savings focuses on 
the difference between the IF23 and the IF24 calls for 
different reasons: 
(a) Before the IF23, the Fund was growing and adjusting, 
and comparison would not be consistent.  From 2023 
onwards, the same call’s structure is applied. 
(b) While there have been additional progressive 
simplifications to the application process over time, before 
the IF23, the specifics of these simplifications and their 
impact was not recorded in detail. 
(c) Auctions have a very different – and lighter - structure 
from calls for ‘regular’ grants, thus they are not 
comparable, hence not studied. 

Finally note that the analysis performed focuses solely on 
the application process. Administrative costs related to 
other phases of the funding lifecycle (e.g. contractual due 
diligence, reporting and monitoring) are not covered. 

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

Citizens/Consumers/Workers 

Businesses 

Administrations 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

On an annual basis, after the end of each call, the application process is reviewed and the stakeholders are consulted to identify ways to further improve the Innovation Fund, to 
simplify the application process and to reduce the associated burden to applicants. 

Recurrent 

Not applicable. 

Not applicable.  Very difficult to provide a 

specific number, but further 
simplifications could reduce the 
required hours to prepare an 
application up to 10 %. 

Assuming the average application 
cost  (internal+external)  of  IF24 

The average internal cost to apply to the IF24 is estimated 
at around EUR 53 300 per applicant. 

Not applicable.  Not 

applicable. 

When accounting for both the internal costs incurred by 
applicants, and the costs with hiring external consultants, 
the average cost becomes EUR 102 500 per applicant. 
This is dependent on many factors, like the topic, 

147 

 
 
               
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and assuming a similar number of 
applications  (around  360),  this 
could lead to an additional EUR 2-
4 million in savings. 

category, sector, company size, location, re-submission, 
etc. 
The  applicant  costs  can  be  reduced  with  further 
simplification  of  the  process,  especially  in  the  GHG 
methodology  which  is  considered  the  most  demanding 
criterion.  For  example,  one  possibility  that  has  been 
identified is the provision of equations to support the GHG 
calculation  for  selected  EII  sectors.  Additional  measures 
could  be  improved  support  from  the  NCPs  (who  benefit 
dedicated  technical  assistance  for  this  reason)  and  the 
introduction  of  mentorship  programmes  that  connect 
applicants with industry experts, who may help refine and 
enhance their proposals. 

148 

 
 
Annex V  Stakeholder consultations 

As part of the Innovation Fund evaluation, several consultation activities were conducted 
to gather information from a wide range of stakeholders. All consultation activities, their 
results and analyses are summarised in the evaluation report and this annex. 

Disclaimer: The contributions received during a public consultation published on Have 
your say cannot be regarded as the official position of the Commission and its services 
and  thus  do  not  bind  the  Commission.  Respondents  to  public  consultations  are  self-
selecting.  Data  gathered 
through  public  consultation  cannot  be  considered  a 
representative sample of the EU population. 

1.  CONSULTATION STRATEGY 

In  line  with  the  consultation  strategy  foreseen  in  the  ‘call  for  evidence’,  DG  CLIMA 
conducted  a  12-week  public  consultation  on  the  evaluation  of  the  Fund’s  operation  via 
Have your say, inviting representatives from eligible countries, National Contact Points 
(NCPs),  members  of  the  Innovation  Fund  Expert  Group  (IFEG),  beneficiaries, 
unsuccessful applicants and other stakeholders to participate. The public consultation was 
designed to gather broad stakeholder input on both the design and implementation of the 
Fund, and to provide evidence for the evaluation. DG CLIMA first published the ‘call for 
evidence’ on 14 April 2025. The public consultation questionnaire was published on 15 
April 2025. The consultation period was open until 8 July 2025. The questionnaire was 
available in all 24 official EU languages. DG CLIMA promoted the public consultation 
through  the  Commission’s  website,  social  media  and  direct  email  outreach.  On  4 
September  2025,  DG  CLIMA  published  the  consultation’s  factual  summary  report. 
Feedback received in response to the ‘call for evidence’ was automatically published as 
contributions when stakeholders uploaded its via Have your say. 

Between March and July 2025, the contractor conducted online interviews and surveys to 
complement the public consultation, under DG CLIMA’s supervision. 

In November 2025, DG CLIMA presented the evaluation’s preliminary findings during 
two hybrid workshops (‘reality check’ and IFEG meeting). 

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Industry stakeholders (outside of 
IFEG) 

2.  OVERVIEW OF THE RESULTS OF CONSULTATION ACTIVITIES 

2.1. 

‘Call for evidence’ 

97 contributions were posted online, representing: 

–  39  companies/businesses  (40  %),  28  business  associations  (29  %),  11  non-
governmental organisations, 5 EU citizens, 4 public authorities, 3 trade unions, 3 
‘others’,  2  consumer  organisations,  1  academic/research 
institution,  1 
environmental organisation (together accounting for the remaining 31 %). 

–  92 respondents from 16 EEA countries (95 %): Belgium (40 respondents), Italy 
(9), Ireland (6), Finland (6), France (5), Germany (5), Poland (3), the Netherlands 
(3), Spain (3), Denmark (3), Austria (3), Romania (2), Sweden (1), Portugal (1), 
Norway (1), Czechia (1). Additionally, 2 respondents from the United Kingdom, 
and 1 respondent each from Morocco, Canada and Brazil. 

30  respondents  submitted  additional  position  papers  and  reports  to  complement  their 
contributions. Overall, the evidence points to a broad consensus on the Fund’s critical role 
in delivering the EU’s decarbonisation objectives. However, it also reveals calls for greater 
clarity, simplification and alignment with wider policy frameworks to ensure the Fund's 
effectiveness and broad coverage (both sectoral and geographical). 

4  respondents  identified  as  ‘public  authority’:  three  NCPs  (Belgium,  Czechia, 
Denmark),  and  one  regional  authority  (Northern  Netherlands).  Among  them,  three 
submitted additional position papers. While all recognised the Fund’s critical role and the 
need to increase its budget, they also called for specific measures to ease the burden on 
small-scale projects (4 mentions) and to increase geographical balance (3 mentions). 

150 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.2.  Public consultation questionnaire 

93 respondents (79) completed the online survey, representing: 

–  49 companies/businesses (53 %), 21 business associations (23 %) and 7 public 
authorities, 4 EU citizens, 3 ‘others’, 3 non-governmental organisations, 3 trade 
unions, 2 academic/research institutions, 1 environmental organisation (together 
accounting for the remaining 24 %). 

–  90 respondents from 16 EEA countries (97 %): Belgium (25 respondents), Italy 
(13), France (11), Spain (7), Poland (5), Ireland (5), Germany (5), Norway (4), the 
Netherlands (3), Austria (3), Greece (2), Denmark (2), Sweden (1), Portugal (1), 
Finland (1), Estonia (1), Czechia (1). Additionally, 1 respondent each  for North 
Macedonia, the United Kingdom and Switzerland. 

–  When  asked  whether  they  were  familiar  with  the  Innovation  Fund,  89  %  of 
respondents (82 out of 92) indicated they had detailed knowledge of the Fund’s 
objectives  and  activities,  suggesting  that  the  public  consultation  engaged  well-
informed stakeholders. 

7  respondents  identified  as  ‘public  authority’:  four  NCPs  (Estonia,  Italy,  Norway, 
Denmark),  two  port  authorities  (Algeciras  Bay  in  Spain  and  Volos  in  Greece)  and  one 
region (France’s Provence-Alpes-Côte-d’Azur). Recurring issues concern a burdensome 
application process (3 mentions) and heavy reporting requirements during implementation 
(4  mentions).  Public  authorities  were  particularly  concerned  with  the  disproportionate 
burden on smaller entities (3 mentions), suggesting several solutions: a bonus point and 
decreased requirements  during calls  for proposals (4 mentions) and  a priority access  to 
PDA (1 mention). Nonetheless, they recognised efforts had already been made to simplify 
the application process and reduce the amount of documentation required (1 mention) and 
that  administrative  requirements  are  necessary  (1  mention).  The  Fund’s  alignment  with 
national  frameworks was  also  underscored (2 mentions). Several  additional suggestions 
were  made,  notably  to  increase  geographical  balance  (using  LIFE’s  indicative  national 
allocations) or add additional award criteria (strategic autonomy, contribution to circularity 
and other environmental objectives). 

2.3.  Interviews 

Ramboll conducted 79 online interviews (80): 

–  33 interviews of beneficiaries 

(79) One response was disregarded at the request of the submitting organisation, as it did not include  their 
Transparency  Register  number,  leading  to  a  total  of  92 responses  being  considered  in  this  report.  A 
suitability  check  was  conducted  with  no  exclusions  for  the  92  responses.  All  contributions  were 
manually reviewed to check for duplicates, accuracy and signs of coordinated responses or campaigns. 
Three sets of responses received additional scrutiny. One set came from a person with the same name 
but a different email and organisation; despite some similar answers, both submissions were accepted. 
Two other sets, one from the aviation sector and one from the pulp and paper sector, had similar open-
ended responses, but not enough to qualify as campaigns. Thus, all four responses were accepted. One 
contribution  from  Malta  was  sent  directly  to  the  contractor  and  was  excluded  as  not  part  of  the 
consolidated dataset (including it would have required manual entry with minimal impact on results). 

(80)  Each interview included two or more participants. Hence, the number of stakeholders interviewed is 

significantly larger than the total number of interviews 

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–  18 with staff from the Commission (including DG CLIMA and CINEA) 

–  7 with National Contact Points 

–  7 with IFEG members 

–  6 with evaluators 

–  3 with staff from the EIB 

–  2 with representatives from national authorities 

–  2 with contractors 

–  1 with Breakthrough Energy Catalyst 

The interviews each followed an interview guide developed for each specific stakeholder 
group in close collaboration with DG CLIMA. Interviews were either general or with a 
specific focus (33 interviews for case studies (81), 8 scoping interviews, and 2 on blending 
operations).  Interviews  conducted  as  part  of  the  case  studies  used  the  interview  guides 
intended  for  the  main  evaluation,  with  some  additional  questions  added  which  were 
specific to their project. 

2.4.  Surveys 

Four  online  surveys  were  designed  to  target  four  key  stakeholder  groups,  using 
EUSurvey. 

2.4.1.  Beneficiaries’ survey 

A first targeted survey was addressed to the Fund’s beneficiaries to assess the performance 
of the Fund from the perspective of organisations that have successfully received support, 
in  terms  of  effectiveness,  efficiency,  relevance,  coherence,  and  EU  added  value.  The 
survey was distributed by CINEA via email. 124 beneficiaries responded: 

–  Most  respondents  to  this  survey  represent  large  enterprises  (77  responses), 

followed by medium and small enterprises (19 responses each). 

–  All EU Member States except Estonia and Malta are represented. 

–  At  the  time  of  application,  most  projects  had  a  technological  readiness  level 
between  6  (demonstration)  and  8  (scale-up),  with  61  and  36  responses, 
respectively. 

2.4.2.  Unsuccessful applicants’ survey (including recipients of PDA) 

The unsuccessful applicants’ survey aimed to understand the barriers and challenges that 
prevented  them  from  securing  funding,  assess  perceived  fairness  and  transparency,  and 
capture outcomes achieved without the Fund. CINEA disseminated the survey via email. 
154 respondents participated: 

(81)  Only 30 case studies have been produced. For three of them, both the coordinator and the participant 

were interviewed. 

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–  The respondent sample was dominated by large enterprises, with SMEs following 

behind. 

–  Respondents represent all EEA countries except Malta and Iceland, for which no 

responses were received. 

–  A  third  of  respondents  come  from  the  hydrogen  sector,  followed  by  chemical, 
cement  &  lime,  refineries,  and  other  sectors  outside  the  scope  of  the  EU  ETS 
Directive. 

–  Most respondents (58 %, number) have only applied once for funding under the 
Innovation  Fund.  Among  those  who  applied  multiple  times,  most  have  applied 
twice (40 out of 63), some have applied three times (15), and a few have applied 
four times or more for funding (8). 

2.4.3.  NCPs’ survey 

The  NCPs’  survey  aimed  to  gather  insights  on  the  operational  aspects  of  the  Fund’s 
implementation,  focusing  on  their  role  in  guiding/supporting  applicants,  challenges  in 
dissemination, and views on accessibility and transparency. The survey was disseminated 
by  Ramboll  via  email.  All  NCPs  were  invited  to  complete  the  survey.  27  respondents 
participated,  with  only  Cyprus  and  Greece  not  participating, thus  providing  a 
representative perspective of this stakeholder group’s views: 

–  Most  NCPs  view  their  role  and  the  Fund  as  broadly  aligned  with  the  needs  of 
applicants.  However,  a  notable  minority  expressed  concerns  that  additional 
resources,  time,  and  simplification  of  procedures  would  be  needed  to  meet 
applicants’  needs  fully.  These  respondents  also  highlighted  national-level 
constraints, such as a lack of co-financing options or restrictive mandates. 

–  Across  the  surveyed  NCPs,  the  most  often  requested  support  activities  were  (i) 
advice on project and call alignment, and (ii) assistance with understanding call 
texts, rules, and procedures. These activities are offered by nearly all NCPs and 
are generally rated as effective. 

–  Nevertheless, some respondents noted challenges stemming from the complexity 
of Innovation Fund documentation, lack of expertise on technical issues (e.g. GHG 
methodologies, cost calculation), and limited information from both applicants and 
the DG CLIMA. 

–  In terms of dissemination, almost all NCPs reported using email communication 
and  self-organised  Innovation  Fund  events  as  their  main  tools, which  were  also 
rated the most effective. Despite these efforts, more than half of the respondents 
reported difficulties in reaching their entire target audience, with some citing a lack 
of comprehensive contact data for potential applicants. 

–  Moreover,  most  NCPs  indicated  insufficient  knowledge  of  the  performance  of 
supported projects (20 out of 26), both domestically and in other countries, citing 
limited structured information exchange and the absence of systematic feedback 
loops. 

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2.4.4.  Horizon Europe beneficiaries’ survey 

This survey aimed to explore complementarities and synergies between Horizon Europe 
and the Innovation Fund and identify barriers/enablers across the lifecycle of low-carbon 
innovation. 

A total of 79 responses were collected, covering a wide geographical and sectoral spread, 
with  representation  from  Spain  and  Greece, and  from  sectors  including  transport,  solar 
energy,  hydrogen,  wind,  bioenergy,  energy  storage,  carbon  capture,  aviation,  and 
maritime. Most of the projects under review were at advanced stages of development, with 
technology readiness levels (TRL) of 5–7, indicating proximity to market application. 

The survey highlighted that awareness of the Innovation Fund is relatively high, yet actual 
participation  remains  limited.  Only  a  single  respondent  reported  having  applied – 
unsuccessfully – to the Innovation Fund based on their Horizon Europe project, and most 
respondents  were  uncertain  about  future  applications  to  the  Innovation  Fund  across 
sectors. This suggests that, despite the Fund’s positioning as a natural follow-on to Horizon 
Europe,  the  practical  connection  between  the  two  instruments  is  not  yet  systematically 
established. 

Some beneficiaries identified several synergies between the programmes. At the project 
level,  stakeholders  recognised  the  Fund’s  potential  role  in  supporting  deployment  and 
market  introduction  of  technologies  initially  developed  under  Horizon  Europe,  thereby 
enabling  greater  CO₂  savings  and  accelerating  market  entry. At  the  programme  level, 
nearly  all  respondents  emphasised  the  importance  of  access  to  scaling-up  finance  and 
networking opportunities across sectors. The Innovation Fund was considered essential in 
bridging  the  gap  between  research  and  market  readiness  by  providing  late-stage,  large-
scale demonstration funding, complementing Horizon Europe’s earlier-stage support. 

Nevertheless,  concerns  were  raised  about  gaps  in  the  innovation  pipeline. Several 
respondents noted that Horizon Europe supports pilot projects to advance TRLs, while the 
Innovation Fund targets large-scale deployment. However, they perceived a ‘missing step’ 
between these stages, which leaves many technologies without adequate support during 
the transition from demonstration to commercialisation. This structural gap was described 
as contributing to high attrition rates in the European innovation landscape. 

Barriers  to  participation  in  the  Innovation  Fund  were  also  highlighted.  Respondents 
described  the  application  process  as  complex,  requiring  extensive  technical  and 
administrative documentation, including precise CO₂ calculations. Some expressed doubts 
about the cost–benefit balance of applying, particularly as most permits and co-financing 
must already be secured before applying. Insufficient co-financing, high prototype costs, 
and a lack of sector-specific guidance were identified as further obstacles. For SMEs in 
particular,  Horizon  Europe  was  perceived  as  a  more  accessible  programme  for 
collaboration, while the Innovation Fund was described as burdensome and poorly tailored 
to their needs. 

Stakeholders pointed to a few enablers that could strengthen synergies between Horizon 
Europe  and  the  Innovation  Fund  and  improve  accessibility.  These  included  clearer 
guidelines, standardised templates, simplified GHG accounting tools, and enhanced pre-
application support. Greater alignment between Horizon Europe and the Innovation Fund 
was  strongly  recommended, alongside  better  coordination  between  EU  and  national 
policies. 

154