Background

The IA describes the political and legal context of EU external action. According to the IA, 'the EU's external action is in a changing international landscape' (IA, p. 5), including geopolitical tensions, Russia's war of aggression against Ukraine and the situation in the Middle East. In addition, the IA explains how the current volatile global context makes it difficult to build sustainable partnerships with third countries and international organisations.

Concurrently with the proposal, the Commission also published its proposal for a regulation laying down the multiannual financial framework (MFF) for the years 2028 to 2034. The proposal suggests a complete revamping of the current 2021-2027 MFF architecture.¹ It presents the next EU long-term budget for 2028 to 2034 worth €1.763 trillion in total. The third chapter is on Global Europe, with a proposed amount of €182.9 billion, representing 10.4 % of the total.²

The proposed regulation establishing the Global Europe instrument replaces the regulations that form the legal framework for the 2021-2027 period and correspond to the scope of the scrutinised IA, namely:

According to the IA (IA, p. 8), these regulations will expire at the end of 2027 (except for humanitarian aid), at the same time as the 2021-2027 MFF.³ Therefore, the IA states that 'a proposal for a more integrated successor instrument is thus needed'.

Problem definition

The IA stresses the geopolitical context in which the EU operates, the global economic governance, the dependencies and vulnerabilities of the EU economy, the increasing levels of poverty and inequalities, the migratory pressures and challenges of forced displacement (IA, pp. 13-16). However, it is difficult to identify the problem and to estimate its scale as requested in the Better Regulation Toolbox, Tool# 13.

In line with the Better Regulation Guidelines, the IA identifies three problem drivers and relates them to the most affected stakeholders. These are at the level of the architecture of the external financing instruments, specifically (IA, pp. 16-17):

In addition, the IA describes policy-specific challenges in more detail, such as the slow progress of socioeconomic convergence (IA, p. 18), the specific challenges affecting the EU's neighbouring countries (IA, p. 19-20), international partnerships and Sustainable Development Goals (SDGs) financing gaps (IA, p. 20-22), humanitarian aid (IA, p. 22), and the EU engagement with high-income countries (IA, p. 23).

The IA provides an intervention logic (IA, p. 26) but the problem definition remains vague, and only the problem drivers are described explicitly. The IA notes several times that the lack of flexibility is an obstacle; this could therefore be considered the main problem. Although reference is made to the open public consultation, which accommodates some empirical evidence, the findings of previous evaluations could have been further integrated, and more evidence could have been provided to support the problem definition.

Subsidiarity/proportionality

The IA describes in Chapter 3 the reasons for which the EU should act, i.e. why and how common coordinated policies can achieve greater impact (IA, p. 23). In Annex 6, the IA provides additional information on the EU added value generated through external financing instruments policy by policy: enlargement, eastern and southern Neighbourhood, Middle East, north Africa and the Gulf, international partnerships and humanitarian aid. The IA does not include a subsidiarity grid, as recommended by the Task Force on subsidiarity, proportionality and 'doing less more efficiently' (Tool #5).

In its subsidiarity subsection, the proposal briefly mentions the EU's coordinated multilateral approach with Member States through financial instruments, budgetary guarantees and blending operations. It also mentions that the EU incentivises public and private investments and triggers collaboration among development financial institutions, and that macro-financial assistance provides financing for countries experiencing balance of payments crises.⁴

The IA does not assess proportionality, nor is it considered in the comparison of options. The proposal merely states that 'the proposed Regulation does not go beyond what is necessary to achieve its objectives'.⁵

Objectives of the initiative

The initiative's general objective is to design external financing instruments that effectively advance the EU's strategic interests while being responsive to fragility and crisis situations (IA, p. 24). The IA (pp. 25-30) lists three specific objectives (SO), each broken down in sub-objectives, as shown in Table 1.

In accordance with the Better Regulation Guidelines, the IA differentiates between the general objective and the specific objectives. However, the interrelation between problem drivers and specific objectives could have been clearer and more detailed in the intervention logic (IA, p. 26). In addition, it is not mentioned how the Global Europe instrument will contribute to the MFF objectives. The IA details neither separate operational objectives nor potential evaluation indicators. The IA expresses that 'the indicators of the future instrument will focus on societal objectives as has been the case until now under NDICI – Global Europe and IPA III. These indicators are specified in the future Performance Regulation' (IA, p. 57). Therefore, it is not possible to conclude that the objectives are specific, measurable, achievable, relevant and time-bound (S.M.A.R.T).

Finally, the IA explains in Annex 3 (pp. 77-79) and on pp. 53-56 how the IA's preferred option would help in achieving five SDGs: SDG 1 on poverty reduction (also a Treaty obligation and the EU development cooperation policy's primary objective); SDG 2 on zero hunger; SDG 3 on good health and wellbeing; SDG 6 on clean and water sanitation; and SDG 10 on reducing inequalities. According to the IA, the preferred option enables supporting and contributing to all 17 SDGs (IA, p. 79).⁶

Range of options considered

The IA starts the section on the available policy options assessing those for the 2021‑2027 financing period, which can be understood as the baseline scenario, and briefly describes the results of the mid-term evaluation of external financing instruments.

In addition, the IA reflects on the Ukraine Facility (IA, pp. 32-33), the Reform and Growth Facility for the Western Balkans (IA, p. 33), and the Reform and Growth Facility for the Republic of Moldova (IA, p. 34).

The IA presents three policy options (POs) in addition to the baseline scenario (see Table 2).

The IA assesses only three options. In option 1, Ukraine support needs are above MFF ceilings. The main difference between options 2 and 3 is that for Ukraine, option 2 envisages a single funding source, above MFF ceilings, which supports economic accession requirements and post-war economic recovery and reconstruction. This meets specific objective 2.4 by ensuring there is a specific leeway for funding the needs in Ukraine. In option 3, Ukraine funding is from two different budget sources: Ukraine pre-accession needs would be covered, inside MFF ceilings, and Ukraine reconstruction needs would be above MFF ceilings. This possibility introduces the difficulty of drawing a distinction between pre-accession and reconstruction financing for Ukraine. Therefore, this option does not meet specific objective 2.4 (IA, pp. 42-43).

Consequently, the three options present different 'equilibriums' between financial and operational flexibility. For example, option 1 would ensure full flexibility, both financial and operational, and would not include spending targets (IA, p. 36). Option 2 proposes a balance between flexibility and predictability, with programmable and non-programmable interventions and the inclusion of an Official Development Assistance target (IA, pp. 36-37). Option 3 duplicates option 2 but includes Ukraine's programmable allocations inside MFF ceilings, which ensures an equal budget treatment for all candidate and potential candidate countries (IA, p. 37).

The options have common elements, as well. The design of all three includes cooperation with enlargement partners, the eastern and southern Neighbourhood, sub-Saharan Africa, Asia and the Pacific, Latin America and the Caribbean, as well as macro-financial assistance. They also envisage humanitarian funding (IA, pp. 35-37).⁸

Overall, the description provides relevant details on all options' economic, social and environmental impacts (IA, pp. 38-44). The IA does not detail the options discarded at an early stage but mentions the limitations in estimating performance at intervention level or at a more 'macro' level (IA, p. 38).

Assessment of impacts

In accordance with Chapter 3 of the Better Regulation Toolbox, the IA assesses the economic, social and environmental impacts of the policy options (IA, pp. 37-57). The analysis is qualitative; it includes neither a cost-benefit nor a cost-effectiveness analysis but only an overview of the preferred option's costs and benefits on intangible factors. The IA explains the limitations in Annex 3 (pp. 74-77), specifying that impacts are considered at a high level of aggregation (IA, p. 38). In addition, it also explains that none of the options consider specific policies driving EU external action, and that the IA does not aim to measure the impact of EU contributions in specific areas (IA, p. 38).

In terms of the economic impact, the IA considers two types of costs: (i) administrative costs that refer to the 'geographisation'⁹ of NDICI – Global Europe and/or the involvement of EU delegations; and (ii) political and reputational costs, as the EU could be perceived as neglecting environmental and social concerns in the EU's partner countries (IA, p. 76). According to the IA, beneficiaries would benefit from a more effective use of resources through flexible planning, and from predictability that facilitates building an investment horizon, thus contributing to long-term partnerships. In addition, the preferred option, option 2, can attract private-sector investment, as the EU's capacity to cover financial risk would act as leverage (IA, pp. 76-77). This benefit can neither be achieved in option 1 nor in option 3. The IA notes that EU taxpayers would also benefit from possibly lower costs under the single instrument in a form of single support measure and technical assistance under a mutually beneficial package, among other improvements (IA, pp. 76‑77). However, the IA does not provide any estimate of these benefits or costs.

In the assessment of the social impact, the IA assesses those associated with SDG goals; in particular, on vulnerable populations and in terms of employment opportunities for young people and social development in partner countries (IA, p. 41). The IA considers that option 2 – with predictable and stable partnerships with partner countries and indicative financial allocations for regions and countries – favours a more integrated approach to social development (IA, pp. 40-41). However, these benefits are neither quantified nor monetised, and the IA acknowledges that 'the current external financing instruments do not provide a stable evidence base for drawing hypotheses to be tested quantitatively in the context of the preferred option'' (IA, p. 75).

The IA expects option 2 to lead to a more integrated approach to environmental development (IA, p. 42), as this option ensures predictable and stable funding for environmental challenges. The IA affirms that option 1 has a reduced ability to support sustainable development owing to the prioritisation of flexibility. Option 3 appears to be better than option 1 but less favourable than option 2 (IA, pp. 39-44).

The IA refers to human rights instead of fundamental rights, as this IA comprises an external dimension. The IA affirms that the preferred option would support and promote democracy, the rule of law and respect for human rights (civil, political, economic, social and cultural) (IA, p. 79).

The IA compares and scores the three policy options with the baseline and against the criteria of effectiveness, efficiency, coherence and economic, social and environmental sustainability. In this comparative analysis, the IA visualises the relation to the baseline with (++) for significant upgrade, (+) for upgrade, no specific sign for neutral, (-) for downgrade, and (--) for significant downgrade (IA, p. 45). For both the effectiveness and the efficiency assessment, options 2 and 3 provide added value over the baseline. This also applies for coherence and economic, social and environmental sustainability (IA, pp. 50-55).

The IA concludes that option 2 is the preferred option. It finds that options 2 and 3 stand out for their flexibility and predictability 'that best supports' the objectives. Moreover, the IA finds that option 2 provides benefits by simplifying regulatory frameworks, and that it 'can best help design an external financing instrument' that strengthens efficiency and adaptability (IA, p. 57).

Monitoring and evaluation

The IA reflects on future monitoring and evaluation arrangements. According to the IA, this initiative will be monitored and evaluated through the performance framework for the post-2027 budget (IA, p. 57). The IA clarifies that the specific objectives mentioned do not constitute the basis for operational objectives and indicators. Furthermore, the IA mentions that the indicators are specified in the future performance regulation and will focus on societal objectives in accordance with the current NDICI – Global Europe and IPA III (IA, p. 57). Overall, the IA remains unclear on how, and how often, progress on achieving the objectives will be measured; there is no reference on how data will be collected and no reference on which indicators will be used for measuring performance.

Stakeholder consultation

As required by the Better Regulation Guidelines, the IA provides in its Annex 2 a description of the stakeholder consultation (IA, pp. 62-74). The open public consultation was carried out from 12 February to 7 May 2025, meeting the Better Regulation Guidelines' 12-week requirement. It resulted in 730 replies from across 82 countries and from a diverse range of stakeholders: EU citizens, non-governmental organisations, public authorities, business associations and academic institutions.

According to the IA, the feedback was supportive. For example, a large share of respondents, 69.3 %, agreed that EU external funding should contribute to EU policy objectives for human rights, democracy and the rule of law (IA, pp. 62-63). In addition, 11.92 % of respondents agreed that the merging of several instruments has largely brought improvements, and 38.77 % considered it has somewhat brought improvements.

In terms of objectives, most respondents, 59.4 %, considered that EU funds should help to further develop partnerships with third countries, notably in Africa, Asia and Latin America. In addition, it was also clearly recognised that it is important for the EU to encourage private sector investment to increase the total funding for development and humanitarian assistance (IA, pp. 63‑64).

The annex to the IA provides an overview of the open-ended questions and a breakdown of stakeholders' views and impacts (pp. 70-74). Nevertheless, the IA could have better factored in the results of the public consultation.

Supporting data and analytical methods used

In a dedicated annex, the IA briefly mentions the analytical methods used (Annex 4, p. 80). The annex states that the IA is qualitative and based on multi-criteria analysis (IA, p. 80). It indicates that the specific objectives have been used to compare the options against the baseline, and to assess the options' economic, social and environmental impacts (IA, p. 80). However, the IA could have used the results of previous evaluation reports and supported its findings with more robust evidence.

Follow-up to the Commission Regulatory Scrutiny Board opinion

The Regulatory Scrutiny Board (RSB) issued an opinion without qualification on the draft on 13 June 2025.¹⁰ This absence of a quality scoring also concerns the other MFF-related IAs the Commission released between July and September 2025. In its opinion, the Board remarked that Better Regulation Tool #9 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'.

Therefore, given the lack of fundamental elements in this IA, the Board decided to issue an opinion without qualification. Furthermore, it drew attention to:

The IA provides a table (Annex 1, pp. 58-61) with explanations on how the RSB recommendations have been addressed. The IA seems to have made efforts to address the RSB's comments on the intervention logic, and to explain the limited options presented. However, more could have been done regarding the monitoring and evaluation arrangements and the problem definition, among other key areas.

Coherence between the Commission's legislative proposal and the IA

The legislative proposal establishing the Global Europe instrument appears follows the preferred option, a flexibility-predictability equilibrium.¹²

This briefing, prepared for the Committee on Foreign Affairs (AFET) and the Committee on Development (DEVE), 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.