Response NL government to the public consultation of the ex-post evaluation of the
European Fund of Regional Development (ERDF) and the Cohesion fund 2014 - 2020
Experience with the ERDF and the Cohesion fund
This input from the Dutch government is based on the experience as overall coordination body of
the Dutch ERDF and Interreg programmes:
• 4 ERDF programmes: North, East, South, West.
• 4 Interreg A programmes: Flanders-Netherlands, Germany-Netherlands, Maas Rijn,
Two Seas
• 4 Interreg B&C programmes: North Sea Region, North West Europe, Europe and
Interact
2. Evaluation of the effects of the ERDF
2.1. Effectiveness
For the Netherlands it is essential that cohesion policy remains as focussed as possible, both
geographically and thematically. Geographically, this means that the Netherlands believes that
most support should be directed towards those regions that need it most. Thematically, cohesion
policy should primarily be focused at structural reforms and investments in the following priorities:
•
•
•
•

Innovation
Digitalisation
Climate Action
Skills

These matters are not only the biggest common challenges, but also offer the greatest
opportunities for all European regions. Structural investments that prepare EU regions for a green
and digital future, will have the potential to contribute most to the resilience and strength of their
regional economies. This will in turn benefit the European internal market as a whole, for example
by stimulating socioeconomic convergence, but also by contributing to the EU’s open strategic
autonomy.
The Netherlands supports the RIS3 as a tool to focus the priorities of all regional programmes in
a certain region. The Netherlands believes that the innovative approach that is carried out with the
RIS3 serves all regions, by providing them with opportunities to leverage on their competitive
advantages. Through its partnership and bottom-up approach, smart specialization brings together
local authorities, academia, businesses and the civil society, to work together to implement longterm growth strategies. This partnership approach also enhances collaboration between the
different levels of government within a country. A good next step in cohesion policy could be to
better connect regions based on their RIS3, and have those regions with matching RIS3 profiles to
collaborate under cohesion policy. One good example of this in the 2021-2027 programming period
are the interregional innovation investments (I3). In this programme, cross-border cooperation is
based on similarities in RIS3, which makes for optimised cooperation schemes between regions.
Cohesion policy is most effective when it goes hand in hand with governance- and economic
reforms. The Netherlands would like to underline in that respect the importance of the rule of
law. Therefore, as already called for in the Council’s conclusions on the 8th Cohesion Report 1, all
EU investments should be done in accordance with the EU charter of Fundamental Rights. Economic
reforms can help economies to better prepare for cohesion policy investments which will then yield
more returns. This way, cohesion policy investments can contribute to address the economic
vulnerabilities mentioned in the country specific recommendations of the European Semester, in
order to strengthen the resilience of the regions and the European Union as a whole.
In conclusion, the Netherlands would like to underline the good work that has been done within the
RIS3 framework and calls for continued efforts to gather evidence on how to use the RIS3 for the
development of regional economies. Focus, both geographically and thematically, is paramount.

Council Conclusions (8980/22) on the Communication on the 8th Cohesion report “Cohesion in Europe
towards 2050”
1

2.2. Efficiency
A survey in a report by the Netherlands Court of Audit 2, showed that recipients of EU funding were
concerned about the administrative burden of applying for EU funding. Approximately two thirds of
all interviewees had contracted a third party to apply for funding. The Netherlands therefore wants
to reiterate the importance of simplification of all cohesion policy funding options, while
maintaining sound financial management.
In the 2014-2020 period, considerable efforts were made to explore and work with simplified costs
options. The Netherlands welcomes the fact that good experiences resulted in a (regulatory)
framework that further promotes and facilitates the use of simplified costs options. The
Netherlands encourages the European Commission to continue those efforts, including ways of
promoting financing not linked to costs and approaches of result-based financing.
Nevertheless, The Netherlands would like to underline that simplification goes beyond the use of
simplified cost options. Other administrative requirements can result in unnecessarily high
administrative burden. This includes for example the considerable amount of administrative data
that needs to be provided.While the Netherlands acknowledges that some administrative
requirements from the 2014-2020 period were dropped or simplified (such as the role of the
certifying authority), other requirements were maintained or even added (such as data collection
on ultimate beneficial owners and publicity requirements).
In some instances, we also see considerable discrepancies between requirements for programmes
under direct/indirect management and shared management. To further enhance synergies between
different funding streams and to alleviate the administrative burden of beneficiaries, it is important
to mainstream those administrative processes and requirements as much as possible. In this
regard we note positively that the combination of funds under the common provisions regulation in
the 21-27 period has harmonised funds under shared management. We encourage the Commission
to continue this process of harmonisation in order to enhance possibilities for synergies
between funds.
Both the internal and external coordination and the final approval of the partnership agreement
proved to be an intensive process. Despite efforts to improve the process for the 2021-2027
period, we consider that more steps can be taken to simplify the procedure. The Netherlands would
therefore invite the Commission to critically examine how the partnership agreements have
actually contributed to more coherence between funding, especially for Member States with smaller
national budgetary envelops, in order to possibly alleviate some of this administrative burden in the
future.
2.3. Coherence/synergies
For the Netherlands, it is very important that overlap between European funding is avoided as
much as possible. Different funds should have distinctive goals without running the risk to compete
with each other. In line with this, the MFF should be kept simple. In the 2014–2020 MFF, but even
more so in the current MFF, several instruments (e.g. RRF, BAR, JTF) have been established that
overlap to a certain extent with the ERDF and the Cohesion fund. The lack of a clear view of
different instruments creates unwanted competition instead of synergy. Also, a plethora of funds
and programmes makes it more difficult for applicants to find and access the funding they need.
Therefore completely new instruments, both under and outside Cohesion policy, should be
avoided. The use of existing instruments, like was done in the case of the Covid pandemic with
REACT-EU is to be preferred.
Furthermore, we notice that the regulatory requirements for Interreg as an instrument under ERDF
are not always well adapted to the diverging (multi-country) governance structures and setup of
those programmes. One example are the ill-fitting indicators in the 2014-20 period. We have seen
improvements with the 2021-27 programming period but encourage the European Commission to
further progress in this regard.
The Netherlands welcomes the earmarking of Cohesion policy funds within other programmes with
significant EU added value, such as is currently the case for the earmarked funding from the
Cohesion Fund within the Connecting Europe Facility. The Netherlands would in light of the above
invite the European Commission to focus part of its evaluation on the extent to which
investments from the ERDF and the Cohesion fund are complementary to other European
2

Added Value of EU Grants in the Netherlands | Report | Netherlands Court of Audit (rekenkamer.nl)

funds, and where there is overlap. More synergies between EU programmes is a prerequisite for a
better functioning EU research and innovation landscape. Synergies happen often only on an adhoc basis and the Netherlands believes that if administrative practices of funds under shared and
(in)direct management are better aligned, much more could be achieved in this respect.
We have experienced numerous crises hitting our continent, of which covid-19 and the Russian
aggression against Ukraine were the latest. This has resulted in cohesion funding (especially at the
end of the 2014-2020 period) being used as a crisis instrument. One example is the creation of the
“Coronavirus Response Investment Initiative (CRII)”. The Netherlands did not make use of CRII,
because of the limited amount of funds available, which were at that time already committed to a
large extent. The Netherlands underlines EU solidarity, especially in these exceptional
circumstances, and sees the ability of cohesion policy to quickly respond to crises. However, the
Netherlands believes cohesion policy should keep its focus on the long term impact. Flexibility
measures must always be of exceptional and temporary nature and preferably contribute to the
feasibility of cohesion policy. Therefore we invite the Commission to continuously examine
the effects on regional development of using cohesion policies for crises.