Background

The European Commission adopted its proposal ¹ for the next multiannual financial framework (MFF) for 2028‑2034 on 16 July 2025, including the first package of sectoral proposals, complemented by the second package on 3 September 2025. To strengthen Europe's sovereignty, competitiveness and resilience, the new MFF aims at addressing complexities, weaknesses and rigidities in the EU budget, and provides a more focused, impactful and simpler framework (fewer programmes). It recognises the need to increase the budget's flexibility and ability to respond to changing realities and emerging needs, and to streamline EU intervention in various policy areas in the new programmes. These objectives were announced in the Political Guidelines and the communication on the next multiannual financial framework.

Problem definition

The IA's analysis focuses on EU funding in the policy areas of cross-border education and training, solidarity, youth, media, culture and creative sectors, and values and civil society. It covers the following existing programmes: Citizens, Equality, Rights and Values (CERV); Creative Europe; Justice; Erasmus+; and European Solidarity Corps (ESC), as well as the multimedia actions financed through a dedicated budget line.² The IA describes these policy areas and EU funding in more detail in Annex 7 (pp. 132‑139), including other EU funding instruments which partially relate to the above‑mentioned policy areas, such as Horizon Europe, Digital Europe and European Social Fund+.

Referring to the mid‑term evaluations of the current EU programmes (2021‑2027) and the final evaluations of the previous ones (2014‑2020),³ the IA considers that the programmes have largely achieved their policy objectives and generated EU added value. For example, the Justice programme contributed to the mutual recognition of judicial decisions across EU Member States, while the CERV programme supported civil society organisations that often lacked other funding sources. The Erasmus+ and ESC programmes provided European added value for individuals and organisations, which was not possible to achieve at national level alone. The Creative Europe programme, as the 'only source of funding', enhanced transnational cooperation and mobility in the cultural, creative and audiovisual sectors (IA, p. 6; Annex 8, pp. 140‑148).

Alongside positive results, the evaluations also found areas for improvement. The IA mentions the need to expand the reach of the Justice, Erasmus+ and ESC programmes, and to further improve the identification of people with fewer opportunities (ESC, Erasmus+). Moreover, synergy should be improved and overlaps avoided, for example between Erasmus+ and ESC, as they both support youth initiatives. The IA also points out that the evaluations called for simplification and more flexibility to the funding rules (IA, pp. 6, 140‑148).

In line with the 'evaluate first' principle, the IA identifies three problems (P) – two relating to policy content and one to design of the financial intervention – affecting EU financial support to the policy areas (pp. 8‑9):

P1) 'Threats to democracy, fundamental rights and EU values, culture and cultural diversity, and shrinking civic and media spaces'. The IA notes that threats against EU values persist, resulting from the polarisation of society and rising extremism and populism, while the role of civil society organisations is shrinking due to weakening financial and political support. It mentions challenges to the rule of law and democratic institutions, discrimination (2023 Eurobarometer), gender‑based violence (survey by Eurostat, FRA and EIGE 2024) and an increase in online hate speech and harassment (2024 OSCE ODIHIR report). The IA refers to the significant economic costs for EU societies relating to violence, discrimination and inequality; for example, it notes that the costs from all grounds of discrimination are estimated at over €500 billion per year. The IA mentions challenges in the media sector, such as decreasing pluralism in the news media, revenues shifting to platforms, and competition in the audiovisual sector with non‑EU actors and technological dependence on them. Among the threats, the IA also draws attention to foreign information manipulation and interference (FIMI) targeting democratic processes, in particular elections (EEAS report 2025) (IA, pp. 8‑12, 150‑153).

P2) 'Shortfall of skills and key competencies for life and jobs'. The IA draws attention to various issues in the EU education and training sectors. It mentions, for example, the European Commission's comparative analysis of the 2022 PISA results showing that the EU is lagging behind other OECD countries in basic skills, e.g. mathematics (‑18 points) and reading (‑12 points). Furthermore, not all graduates from higher education or vocational education have the necessary skills required in working life, especially given the rapidly evolving technological development. Based on Eurostat data, more than half of employers found it difficult to recruit ICT specialists with the requisite skills in 2023. The IA also notes cross‑border mobility issues, resulting in a loss of jobs and learning opportunities, as the recognition of qualifications is not automatic and often requires complex administrative procedures between Member States. The IA stresses the importance of addressing the education and skills gap, given that almost 18 million young people are at risk of social exclusion (IA, pp. 8‑9, 12‑13, 154‑157, 169, 181‑182).

P3) 'Challenges to the design and architecture of the EU financing instruments to address the policy‑related problems'. Drawing on the evaluations mentioned above, the IA explains that EU funding complexity and lack of flexibility have resulted in funding gaps, which mean emerging needs cannot be addressed, e.g. in news media (disinformation) or justice policy areas (digitalisation demands). The IA mentions oversubscription, for example only 10 % of volunteering activities could be supported in the ESC. Since many funding instruments support the same policy areas, the IA considers that a more coordinated approach is needed, and untapped synergies, overlaps and complementarities should be addressed. The IA finds that the complexity of the funding rules is especially challenging for smaller actors with limited resources (IA, pp. 9, 12‑15; Annex 8, pp. 140‑148).

As required in the Better Regulation Guidelines (BRG), the IA identifies the problems and problem drivers and provides some estimates of the scale of the problems. In its analysis of the problem drivers' possible development, taking into account megatrends, the IA expects the drivers to persist and further intensify pressure on EU funding, unless the problem drivers are addressed (IA, p. 15; Annex 9, pp. 149‑150).

Overall, the information is quite scattered as the main text is at times rather general, and more detailed information can only be found in the annexes and endnotes. In addition, in several cases, the text refers to the endnotes, which then refer to the relevant annexes.⁴ While the analysis is mostly well referenced, some sources are not indicated in full (e.g. 'European Media Industry Outlook', 'Media Pluralism Monitor Report') or are missing (the description of the problem driver on obstacles to cultural cooperation and preservation of cultural heritage refers only to one EP resolution) (pp. 11, 153).

Subsidiarity/proportionality

The IA notes that the 'policy areas covered by this IA are firmly anchored in the EU Treaties' but does not specify the legal basis. When discussing the necessity and added value of EU action, the IA underlines the common challenges to Member States and the transnational dimension of several problem drivers. It considers that EU funding and EU action can strengthen the impact and response to the challenges and in some cases also fill the funding gaps (e.g. EU‑wide legal networks, civil society organisations). The IA substantiates the subsidiarity aspects by qualitative arguments, although it could perhaps have drawn on the evaluations and also provided quantified estimates to underpin its statements on the added value of EU action (e.g. pooling resources and larger scale projects versus smaller projects under different programmes) (IA, pp. 15‑19).

The IA aims to enhance proportionality by improving reactiveness to new challenges and minimising risks, formulated as one specific objective (p. 26). Proportionality is also discussed in the comparison of options – it is one criterion in the comparison (pp. 38‑43).

At the time of writing, no reasoned opinions had been submitted by national parliaments by the deadline on the proposals for the Erasmus+ programme (25 November 2025), the AgoraEU programme (28 November 2025) and the Justice programme (8 December 2025).

Objectives of the initiative

The IA defines three general objectives (GO), linked to the identified problems and problem drivers,⁵ to enhance and strengthen the EU's ability to (pp. 19‑20):

In addition, it presents several specific objectives (SO) linked to each GO (pp. 20‑26). For example, the following specific objectives would address GO3 (pp. 24‑26):

Contrary to the BRG recommendation, the IA does not present more detailed operational objectives for the preferred option in the monitoring and evaluation section. Instead, it explains the links between the specific objectives and areas of intervention, and provides examples of how success can be measured in Annex 10 (pp. 159‑164). The examples include possible output or result indicators, which appear measurable, in the areas of intervention concerning GOs 1 and 2; the success indicators do not cover GO3. Therefore, the objectives appear to meet the BRG SMART criteria (specific, measurable, achievable, relevant, timebound) only partially.

The IA explains the relevant United Nations Sustainable Development Goals (SDGs) relating to this initiative in Annex 3 (pp. 75‑76).

Range of options considered

The IA presents three policy options, linked to the specific objectives, comprising the baseline and two alternative options (IA, pp. 26‑28). The IA explains that the three policy options, based on an initial mapping and analysis of the existing programmes and policy areas, are distinct and mutually exclusive packages. The IA briefly describes the baseline 'from which options are assessed'; however, the policy options' description also includes the baseline as an option, which is assessed, compared to other options and included in the option ranking.

Option 1 (Dynamic baseline/continuity scenario): According to the IA, the baseline option presents a continuity scenario, where the existing programmes would continue to exist as stand‑alone programmes. The IA states that 'some incremental improvements could be introduced', based on the simplification measures introduced for the 2021‑2027 period (not specified).

Option 2 (Objective‑based consolidation) (the preferred option) would align programmes and instruments in two EU funding programmes (an objective‑based merger). To address GO1, it would merge the CERV and Creative Europe programmes and related budgetary prerogative line. The second merger would concern the Erasmus+ and European Solidarity Corps programmes to address GO2. These two merged EU funding programmes would be designed to comply with GO3 (adequacy of funding, simplification, coordination and synergy).

Option 3 (Full integration) would integrate all policies covered by the CERV, Creative Europe, Erasmus+ and European Solidarity Corps programmes into a single funding instrument. It would consolidate all policy‑oriented general and specific objectives and address all emerging challenges and new policy areas.

Regarding the discarded options, the IA explains that the Justice programme cannot be merged with other programmes for legal reasons as not all EU‑27 Member States participate in the Justice programme.⁶ In addition, discontinuing the existing EU funded programmes would contradict the evaluation findings (e.g. added value). The IA also refers to different, partial merging combinations across existing programmes and policies, which were analysed and discarded as they would not 'effectively align with political priorities, and/or would not adequately cater for the challenges … notably the need to reduce the fragmentation of funding, as they would offer less potential for synergies' (IA, p. 28).

It would have been helpful had the IA provided more detailed information about the discarded merging combinations, as it only mentions very briefly one example, namely merging the media strand of Creative Europe with the CERV programme. A more thorough explanation of the discarded merging combinations would have added transparency. Moreover, the IA could have clarified further the arguments for retaining or discarding policy options, as the IA notes that option 1 'would not be fully aligned with the political guidelines for 2024‑2029, nor with the ambition set for the MFF to build a more focused, simpler and more flexible EU budget. This option would not build synergies between programmes and would lack the flexibility to address new challenges' (IA, p. 42). These comments seem similar to the reasons for discarding different merging combinations. In addition, given that the description of option 1 vaguely refers to 'some incremental improvements' without providing any concrete information or examples, it is not quite clear why the baseline is considered a policy option.

Overall, the description of the options, which is very brief, would have benefited from more detailed explanations, including measures on how to address GO3 in all options. Annex 11 (pp. 165-168) provides more information on instruments, synergies and complementarities relating only to option 2 (the preferred option).

Assessment of impacts

The IA refers to Better Regulation Tool #9 which states that 'the special case of preparing a new multiannual financial framework is a unique process requiring a specific approach as regards scope and depth of analysis'. It explains that, as 'the structure of the new MFF will significantly differ from the current one, budget assumptions for each programme are unreliable at this stage'. Consequently, the IA notes that it excludes funding scenarios and provides only a qualitative cost‑benefit analysis (IA, p. 4).

As required in the BRG, the IA assesses the expected social, economic and environmental impacts of the policy options (IA, pp. 28‑37). The assessment is presented in a table format.

Regarding the social impact, the IA considers citizens' participation, democracy and societal resilience, social inclusion and cohesion. The assessment also describes the impact on young people. The youth dimension is embedded in the programmes in the cluster discussed in the IA, but its assessment is also required in the youth check.⁷ While all options would have a positive impact, the IA expects this to be limited under option 1 due to programme silos and lack of synergy. The IA considers that option 2 would generate a stronger positive impact, as it would enhance synergies and foster a more coordinated approach. The IA finds the impact of option 3 less positive than under option 2, resulting from a risk of policy dilution and complex governance (pp. 29‑32). The IA presents similar findings when considering the impact on fundamental rights and equality (p. 36).

The economic impact is assessed on costs and benefits, individuals' employability, competitiveness and SMEs. For example, the IA notes the higher implementation and transaction costs under option 1 due to fragmented and duplicated structures, while option 2 would generate benefits from reduced overlaps and administrative burden through streamlined processes, fewer committees and shared platforms, for instance. The IA finds that the complexity and reduced policy‑based accessibility (e.g. a unified approach, heterogeneous beneficiaries) could offset benefits under option 3, and that reorganisation (merging) may entail high transition costs. The IA does not provide quantification of the estimated costs and benefits (pp. 32‑35).

The IA finds that the environmental impact is limited in option 1, and 'positive though modest' in options 2 and 3 resulting from the increased potential to share practices or more environmental projects (IA, p. 35).

The IA also assesses the impact on digitalisation (the 'digital‑by‑default' principle, see Tool #11 and Tool #28) and draws attention to the untapped potential of digitalisation and to innovation shortcomings under option 1. It mentions that a coherent, cross‑sectoral digital strategy under option 2 could widen participation and outreach capacity, while a lack of thematic clarity due to centralisation of platforms under option 3 could reduce the use of digital tools (IA, pp. 35‑36).

The IA explains that all options would contribute to the UN Sustainable Development Goals (SDGs, namely 3‑5, 8, 10‑12 and 16‑17), and that options 2‑3 would enhance support to public access to information more efficiently than option 1 (IA, p. 36).

The IA compares the three policy options against effectiveness, efficiency, coherence and proportionality. The comparison is based on the social multi‑criteria evaluation model (SOCRATES) and underlying methodology, which is further explained in Annex 4 (pp. 77‑107; see also Better Regulation Tool #62).

The IA finds option 2 the most effective, as option 1 would not foster synergy. Option 3, despite offering the greatest flexibility, might dilute policy priorities and lose focus due to complexity. The efficiency assessment (qualitative only) considers option 2 the best as it would strike a balance between operational complexity and simplification of processes. According to the IA, option 2 would be the most coherent option, because its more focused structure would make it less prone to inefficiencies or conflicting priorities. It also scores highest on proportionality, as it balances flexibility and ways to address specific policy objectives (IA, pp. 38‑43).

The IA therefore concludes that option 2 is the preferred option, as it offers a balance between simplification and policy relevance. It also states that option 2 is congruent with stakeholders' requests for accessibility to funding, flexibility of resource allocation and maintaining the visibility of well‑established brands (IA, p. 43). When substantiating the preferred option, the IA could have clarified how widely different stakeholder groups support this option as this is not quite clear from the stakeholder consultation summary.

Overall, it would have been easier to follow the impact analysis and comparison of options had the IA explained the options in more detail. Moreover, the lack of quantification in the assessment of costs and benefits weakens the efficiency analysis.

Monitoring and evaluation

The IA very briefly refers to the monitoring and evaluation plans, according to which the initiative is monitored 'through the performance framework for the post‑2027 budget',⁸ without providing concrete information on the monitoring indicators, data collection, data sources or a timeline for the evaluation. The IA provides a description of the links between specific objectives and areas of intervention and presents examples of how success could be measured in Annex 10; however, it does not cover all the problem areas and specific objectives (IA, pp. 158‑164).

Stakeholder consultation

As required in the BRG, the IA summarises the stakeholder consultation in a dedicated Annex 2 (pp. 49‑63). The Commission conducted an open public consultation (OPC) between 12 February 2025 and 7 May 2025, meeting the BRG 12‑week requirement. It resulted in 5 845 replies, of which almost 50 % (2 780) were submitted by EU citizens (nearly half of whom were under the age of 30) and around 50 % (2 896) by organisations and institutions (e.g. academic and research bodies, NGOs, public authorities, companies and businesses). The IA includes a graph which shows the participation rate e.g. in terms of country, age group and company size. According to the IA, the most frequently flagged problems across all stakeholder groups were the administrative burden and complex, fund‑specific compliance rules.

In line with the youth check approach, the IA discusses the initiative's relevance to young people and their feedback in the OPC. According to the IA, the young respondents' high participation rate demonstrates how relevant the programmes are for them. In their feedback, young people advocated making EU programmes more inclusive e.g. by simplifying application processes, reducing burdensome compliance mechanisms and providing better support for marginalised groups. They also presented forward‑looking ideas, such as creating local support centres or digital hubs to connect under‑represented young people and those living in remote areas. The IA finds it justified to embed these considerations in the programme design and involve young people in the governance structures.

The consultation documents are not referenced or hyperlinked in the IA and only three of the consultation questions are mentioned. Therefore, it is not clear whether the policy options or SME‑specific questions were included in the consultation. In any case, it does not indicate the stakeholder groups' views on different policy options. Although the IA explained and used the methods to enable segmentation by respondent category and identify divergence by stakeholder type, the descriptions reporting the stakeholders' views are at times quite vague ('respondents', 'several stakeholders').

Supporting data and analytical methods used

The IA draws on various data sources in its analysis. Examples include the mid‑term evaluations of the existing programmes and the final evaluations of preceding programmes, stakeholder consultation, Eurobarometer surveys, 2024 strategic reports,⁹ the 2023 strategic foresight report and megatrends. No external study was commissioned to support the IA.

The IA explains the methods used in the analysis in Annex 4 (pp. 98‑107). It describes the SOCRATES (social multi‑criteria assessment of European policies) model and its underlying methodology in the assessment of the policy options' impacts and ranking of the options. The model is described in the modelling inventory and knowledge management system of the European Commission (MIDAS). In addition, a sensitivity analysis was used in the comparison of the options to verify the robustness of the result.

The IA openly acknowledges weaknesses in the analysis. As there were data limitations ('gaps at EU27 level'; not specified), the data available was used for the triangulation of the results to the extent possible (IA, p. 38). It mentions that the assessment of costs and benefits is only qualitative due to the uncertainties in the budget assumptions.

Follow-up to Commission Regulatory Scrutiny Board opinion

The RSB gave its opinion on a draft IA on 13 June 2025. The RSB notes the Better Regulation Tool #9 and the fact that the architecture of the new MFF will be significantly different from the existing structure. It states that 'given that at this stage the impact assessment lacks several key elements the Board has decided, exceptionally, to issue an opinion without qualification'.

The RSB flagged significant shortcomings throughout the draft IA and asked for clarifications regarding the scope of the initiative, problem definition, intervention logic and objectives, comparison of options, cost‑benefit analysis, governance mechanisms of the options, coherence, and monitoring and evaluation arrangements.

As required by the BRG, the IA provides information on how the RSB's comments were considered in the revised IA (Annex 1, pp. 44‑47). The revised IA appears to have made an effort to address the RSB's recommendations, but some issues remain, such as the need to further clarify the options and their comparison, and the lack of quantification in the analysis of costs and benefits. It can be noted that it is difficult to ascertain all the improvements made to the revised version of the IA, as the previous draft IA is not publicly available.

Coherence between the Commission's legislative proposals and IA

The legislative proposals appear to follow the IA's preferred option (policy‑based option 2).

This briefing, prepared for the Committee on Culture and Education (CULT), the Committee on Civil liberties, Justice and Home Affairs (LIBE) and the Committee on Legal Affairs (JURI), analyses whether the principal criteria laid down in the Commission's own Better Regulation Guidelines, as well as additional factors identified by the Parliament in its Impact Assessment Handbook, appear to be met by the IA. It does not attempt to deal with the substance of the proposal.