Key findings

The nationally pre-allocated envelopes proposal is included in the post-2027 multiannual financial framework package (2028-2034 MFF). It aims to bring together current MFF programmes or strands and regroup them into a single national and regional partnership plan (NRPP) for each Member State. The IA refers to Tool #9 of the Better Regulation Toolbox, acknowledging 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, it explains that budget assumptions for each programme are unreliable at this stage, hence the assessment is only qualitative.

The IA provides an intervention logic to present the problems, drivers, objectives and two different strands of policy options. However, the description of the problems and their drivers, as well as their comparative relevance, could have been more structured and clearer. The IA describes the legal basis and explains the need for and added value of EU action. The IA should have established a clear link between the specific objectives, the problems identified and their drivers. The description of the options would have benefited from more detailed explanations, as it is not quite clear what kind of measures each option would comprise.

In general, a series of shortcomings have been identified concerning the range and assessment of options. The feedback from the consultation activities could have been better reflected and considered in the IA, particularly regarding the available policy options and their potential impact. The IA does not assess the economic, social and environmental impacts of the policy options, including any territorial impact, while it briefly touches upon the issue of fundamental rights. Its qualitative analysis only includes a very limited reference to associated impacts, and it does not adequately assess the costs and benefits of the options. The IA does not provide concrete information on the monitoring and evaluation plans, such as monitoring indicators, data sources or the evaluation timeline. The Regulatory Scrutiny Board decided to issue an opinion without qualification due to significant shortcomings in the draft IA. The revised IA appears to have made an effort to improve the quality of the assessment; however, not all points were addressed.

Background

The impact assessment is part of the first package of Commission proposals for the programmes under the 2028‑2034 MFF. The seven-year MFF is structured along main categories of expenditures ('headings'). The nationally pre-allocated envelopes¹ proposal envisages bringing together current MFF programmes or strands and regrouping them into a single national and regional partnership plan for each Member State.² These plans cover economic, social and territorial cohesion, agriculture, rural and maritime prosperity, and security. The proposal aims to increase synergies among policies and allow for increased flexibility.

The Commission has highlighted the need for a more focused, simpler, and more impactful long-term budget.³ The post-2027 MFF proposals were announced in the 2025 Commission work programme. The European Parliament, with its resolution of 7 May 2025,⁴ called for 'the next MFF to continue support for economic, social and territorial cohesion in order to help bind the Union together, deepen the single market, promote convergence and reduce inequality, poverty and social exclusion'. It further considered that the 'one national plan per Member State' approach as envisaged by the Commission, with the Recovery and Resilience Facility (RRF) model as a blueprint, cannot be the basis for shared management spending post-2027.

Concerning the scope and methodology, the IA acknowledges a deviation from the standard IAs as defined by the Commission's Better Regulation Guidelines (IA, p. 5). The IA outlines that 'impact assessments for programmes under the next multiannual financial framework focus on how to streamline the architecture of the EU budget', assessing 'policy choices' in the analysis of the context, problem definition and the objectives, while the options and their assessment are not policy-specific but horizontal for all policy areas under the initiative. Furthermore, the IA explains that the significant changes to the new MFF architecture would lead to unreliable assumptions about the budget of each programme. According to the IA, the uncertainty over the future budget allocations does not allow the development of funding scenarios or any quantification; hence, only qualititative cost-benefit analysis is possible. To support this choice, the IA refers to the Better Regulation Toolbox, specifically 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'. Therefore, the scope and depth of analysis is different compared to an IA accompanying a proposal outside the MFF context.

Problem definition

The IA starts by describing the initiative's political and legal context. It highlights that one of the major factors hindering the implementation of the current and previous EU programmes is the complexity of the funding architecture, which leads to inefficiencies and administrative burden for beneficiaries, Members States and the Commission. The IA states that 'the policy challenges that prompted the creation of these instruments remain relevant in today's world, while new challenges arising from recent geopolitical shifts have also emerged' (p. 5). However, it falls short of sufficiently identifying and analysing the overarching problem and its scale (in line with Tool #13 of the Better Regulation Toolbox).

The IA presents four problems, linked to seven problem drivers resulting, among other things, from fragmented programming, persistent weak administrative capacity, and low uptake of cross-border and multi-country projects (IA, pp. 6-18).

The analysis of problems appears to rely on evidence from various data sources, including desk research,⁵ studies and targeted examples of relevant mid-term and ex-post evaluations of EU programmes. However, the relevant critical remarks in the problems and in other parts of the analysis should be better supported by evidence.

The IA, with the help of a problem tree, presents seven problem drivers (IA, pp. 11-18, and Annex 7), outlining the relevant problems, problem drivers and their consequences. It notes that 'weaknesses in the current EU budget hamper its capacity to support Member States in delivering EU policy priorities'.

Nevertheless, the problem tree is not well presented, and its structure appears to be complicated and difficult to follow. Annex 7 provides further analysis to support the identification of problem drivers, but the identification and detailed presentation of problem drivers is not adequately evidenced. The analysis would have benefited from a more comprehensive overview of the underlying problems and problem drivers of all the funds, instead of discussing examples of problems with the current programmes. Furthermore, the description of the problems and their drivers could have been more structured and clearer (e.g. the problem drivers seem to partially overlap with each other and/or with the problems presented), while the IA does not consider the comparative relevance of the problems or drivers. The IA should have addressed the magnitude of the different problems and the extent to which each contributes to the problem definition. At the same time, the distinction between consequences and problem drivers is not always clear. They could have been discussed in a more detailed way to allow for a better understanding.

The problem analysis only partially identifies how the problems, drivers and consequences affect the stakeholder groups as per the Better Regulation Guidelines (BRGs) and Tool #13 of the Better Regulation Toolbox. It sporadically associates them with the most impacted stakeholder groups. Annex 3 (together with Annex 4 on the competitiveness check, and Annex 5 on the small and medium-sized enterprises (SME) check) briefly refers to stakeholders who will be directly (or indirectly) affected by the different policy options for this initiative. However, it does not refer to the problems, their drivers, and consequences, nor does it identify all impacted stakeholder groups (e.g. EU citizens and civil society are not mentioned).

The IA assesses how likely it is that the problems would persist without EU action (IA, pp. 18-20).

Subsidiarity/proportionality

The IA includes a section on subsidiarity (IA, pp. 20-22), where it describes the legal basis and explains the need for and added value of EU action. According to the IA, EU action is necessary to deliver on EU priorities across all Member States and regions. More specifically, the nationally pre-allocated envelopes would, among other things, play a vital role in promoting integration and cooperation, and reducing regional disparities within and between Member States (cohesion policy), in ensuring a level playing field among Member States in the agri-food sector (common agricultural policy), and in ensuring a common approach when implementing EU acquis and standards while fostering cooperation across borders (home affairs). The IA also states that EU funding is necessary to uphold EU values and fundamental rights. The initiative's EU added value lies in ensuring that support is focused on the specific needs of each Member States and its regions, while being consistent with EU priorities. According to the IA, EU funding enables EU-level coordination to address transnational challenges. EU funding would contribute to a more efficient delivery of EU common objectives.

The IA does not include a subsidiarity grid, as recommended by the Task Force on subsidiarity, proportionality and 'doing less more efficiently'. A reasoned opinion has been submitted within the deadline (4 November 2025) for the nationally pre-allocated envelopes proposal by the German Bundesrat. The Romanian Senate has sent a reasoned opinion for the common agricultural policy proposal (31 October 2025). No reasoned opinions were submitted by national parliaments by the deadline set for the European Fund for Regional Development proposal (31 October 2025), the common fisheries policy proposal (6 November 2025), the European Social Fund proposal (31 October 2025), the Asylum, Migration and Integration proposal (30 October 2025), the Schengen and Border Management proposal (30 October 2025), the internal security proposal (30 October 2025), and the Connecting Europe Facility proposal (30 October 2025). However, a few Member States have contributed, in the context of political dialogue, to the respective files.

Proportionality is not assessed in the IA, including in the comparison of the options. Only the proposal's explanatory memorandum contains a reference to the principle of proportionality (p. 7).

The proposal on nationally pre-allocated envelopes explains that the EU action is justified by a number of legal bases reflecting the different policy areas supported by the Fund (proposal, p. 7). The IA mentions Article 174 of the Treaty on the Functioning of the European Union (TFEU). Article 174 TFEU commits the EU to promoting economic, social and territorial cohesion, while Article 175 lists the Structural Funds that support this goal. Article 177 explains the role of the European Parliament and Council in defining the tasks, priority objectives and organisation of the Structural Funds, which may involve grouping the Funds. The European Social Fund and its objectives are covered by Article 162. The IA further lists Article 38 on a common agriculture and fisheries policy, with the objectives set by Article 39; the legislative proposal also refers to Articles 42(3) and 43(2) on agriculture. It does not list the legal bases for the different proposals supported by the IA, such as the articles linked to policies on border checks, asylum and immigration, judicial cooperation in criminal matters, development cooperation, and trans-European networks and energy. Annex 6 of the IA provides a more detailed description of the EU funds with nationally pre-allocated envelopes, but details of the legal basis of the sectoral policies within the scope of the proposals are not provided in the main report or in a separate annex.

Objectives of the initiative

The general objective outlined in the IA is to ensure that the EU budget is well-equipped to support Member States and regions in delivering on EU policy objectives and priorities and to maximise the impact of every euro spent (IA, p. 23).

The IA defines three specific objectives (SOs), which aim to help achieve the general objective and address the identified problem drivers (IA, pp. 23-24).

As suggested in the Better Regulation Toolbox (Tool #11), the IA presents the intervention logic (problem, drivers, objectives and options). The IA differentiates between the general objective and the specific objectives. However, the IA should have better explained how the success of the general objective 'to maximise the impact of every euro spent' will be measured, given that this aspect does not seem to be fully captured by the specific objectives.

In addition, the IA should have established a clear link between the specific objectives, the problems and the problem drivers, including their relation to the performance and monitoring framework. The intervention logic should have included clearly defined results and impacts and have been supported by relevant indicators to enable future performance monitoring. The analysis would have further benefited from a description of what the success is expected to be in relation to the different objectives in order to facilitate monitoring and evaluation.

The IA does not specifically set out operational objectives, which would define deliverables of specific policy actions after identifying the preferred option. The IA refers to the performance framework for the post-2027 budget, stating that 'the initiative will be monitored through the performance framework for the post-2027 budget, which is examined in a separate impact assessment' (IA, p. 24).⁶ It does not, however, present specific monitoring indicators relevant to the objectives in the IA's section on monitoring and evaluation, where it merely states that 'the Performance Regulation will provide ca. 900 performance output and result indicators that will enable to monitor the performance of the budget' (see section on 'Monitoring and evaluation' below). Therefore, it is not possible to conclude whether the objectives are specific, measurable, achievable, relevant and time-bound ('S.M.A.R.T' criteria, Tool #15 Better Regulation Toolbox).

According to the BRGs, an IA should include an assessment of the impacts on the relevant United Nations Sustainable Development Goals (SDGs). The IA notes that the proposal is expected to contribute to all SDGs, as it supports a broad spectrum of investments and reforms across the EU (Annex 3, pp. 71-73). It provides an overview of relevant SDGs as part of Annex 3, outlining how funding from pre-allocated envelopes can contribute to all SDGs. However, the IA does not strictly link the SDGs to the preferred option, and it does not explain how the preferred option would contribute to each of them. Instead, it mentions that 'the final list of SDGs to which the different policy options for this initiative will contribute will ultimately depend on the scope of the plans' (Annex 3, p. 71).

Range of options considered

The IA starts by stating that, under the baseline, 'EU funds with nationally pre-allocated envelopes would continue to be governed by separate fund-specific regulations and implemented through different programmes' (IA, p. 24). It explains its approach concerning the preparation and assessment of the plans, which has considered, among other things, the Commission's communication on the road to the next MFF, and the steering mechanism announced as part of the competitiveness compass communication of 2025.⁷

According to the IA, there is a need for a two-tier approach, as shown in Table 3. First, it is important to examine which design features are best suited to reach the objectives of the initiative. This covers a) the 'delivery model' (how payments are made), and b) the 'management mode' (how EU spending is implemented and overseen). The choices on the design of the plans will have an impact on the scope of the plans.⁸ Options related to the scope of the plans relate to a) a set of options focused on the scope of the plans as such, and b) a set of options to assess whether the plans are suitable to support cross-border/multi-country projects. The IA further states that cross-border and multi-country projects would continue to be eligible for support under several funds with different rules (direct and shared management).

The IA refers to an option discarded at an early stage (implementation of existing funds currently governed by separate fund-specific regulations within a single plan for each Member States) without providing additional explanation about the reasons behind that decision (IA, p. 26).

The IA does not adequately identify the full range of options to address all the problem drivers. It presents the core elements of each option (predominantly with regard to 'which of the current spending programmes is integrated in the new instrument', as stated in the IA, p. 29) rather briefly in the main text and does not clearly describe how they will help to achieve the objectives of the initiatives. Overall, it is questionable whether the options present fully realistic alternatives to the baseline as requested by the BRGs and Toolbox (Tool #16). This is especially the case for Option 1.

In general, a series of shortcomings have been identified concerning the range and assessment of options. For example, societal issues and territorial needs should be taken into consideration in the design and analysis of the models for delivery and scope, given the proposal's regional dimension. Additional shortcomings stem from the absence of adequate performance monitoring in relation to the preferred perfomance-based delivery model, and the need for a more detailed analysis of the preferred management mode and its impacts. In addition, it stills remains unclear what the 'strong focus on less developed regions' entails and how the disparities in technical and administrative capacities between the Member States and/or regions are intended to be addressed. Finally, the IA does not present, in a comprehensive way, the views of different stakeholder categories as part of the analysis of policy options.

The preferred option for the design of the plan is a delivery model against pre-agreed objectives (Option B of the delivery model), under shared management (Option D of the management model). Regarding the scope of the plan, the IA does not clearly define the preferred option. It concludes in a rather unclear way that Option 3b is the preferred option (IA, pp. 48, 50), but without presenting a comprehensive analysis. The IA does not explain (except in the 'Summary of the effectiveness of the options on the scope – qualitative assessment', Figure 4, p. 50) what criteria are used for comparing the options, and what comparative value each option delivers. Overall, a more detailed analysis would benefit the overall quality of the IA, and, in particular, the understanding of the proposed policy options/plans, which build on the baseline of the current funding landscape.

Assessment of impacts

The IA does not assess the economic, social and environmental impacts of the policy options, as defined in Chapter 3 of the Better Regulation Toolbox, nor does it assess any (direct or indirect) environmental impacts, as required by Tool #36 of the toolbox. The BRGs commit the Commission to analysing the environmental impacts of all policies in a proportionate manner and following the 'do no significant harm' principle.⁹

When it comes to economic impacts, the IA does not consider the specific focus of the proposed initiative and does not assess any territorial impact that would occur,¹⁰ as required by Tool #34 of the Better Regulation Toolbox, according to which 'impact assessments and evaluations should systematically consider territorial impacts when they are relevant and there are indications that they will be significant for different territories of the EU'. Hence, the IA does not identify or analyse policy-specific impacts. It only includes a qualitative analysis of the policy options, with very limited reference to associated impacts, and it does not adequately assess the costs and benefits of the options.¹¹

The IA uses modelling to analyse the options regarding the delivery model of the pre-allocated envelopes post-2027. It states that, given the assumptions on the budget would be unreliable at this stage, the impact will not include funding scenarios, and no cost benefit analyses will be carried out to assess the efficiency of the policy options proposed (IA, p. 27). As indicated above ('Background' section), the IA also refers to Tool #9 of the Better Regulation Toolbox, highlighting that preparing a new multiannual financial framework is a unique process requiring a specific approach as regards scope and depth of analysis.

According to the IA, in the absence of a dedicated analysis of costs, the quantitative analysis is based on data from the second interim report on the assessment of the administrative costs and administrative burden in the management of the CPR funds 2021-2027 (IA, p. 46). However, the impacts on administrative costs are only partially covered. More specifically, the IA (including Annex 10) does not analyse administrative costs for the options on the delivery model and management mode, but only for the options on the scope. The IA does not provide sufficient evidence to support its conclusion that the options would 'significantly' (IA, p. 47) (or 'massively', as mentioned in Annex 3, p. 70, and Annex 10, p. 110) reduce administrative costs for Member States compared to the status quo.

The IA does not provide a comprehensive assessment of the policy options' social impacts, although certain recitals and provisions of the proposed legislation acknowledge that the proposal is expected to have social impacts (recital 17, Articles 1, 3, and 22).¹² Importantly, it only touches upon the issue of fundamental rights under the subsidiarity section (IA, p. 21) and the policy options section (IA, p. 24), without providing a comprehensive and detailed analysis of their potential implications or the proposed regulation's 'strong safeguards to ensure that the funds are implemented in compliance with the Charter of Fundamental Rights' (Proposal, explanatory memorandum, p. 10).

The IA presents an overview of the SDGs (Annex 3, p. 72), but without illustrating how the objectives contribute to the relevant SDGs. It also notes that 'the final list of SDGs to which the different policy options will contribute will ultimately depend on the scope of the plans' (Annex 3, p. 71). Annex 3 briefly mentions stakeholders who will be directly (or indirectly) affected by the different policy options for this initiative. However, the IA does not refer to the problems, their drivers, and consequences, nor does it identify all impacted stakeholder groups.

The IA qualitatively assesses and scores the effectiveness of the different policy options on the design and the scope of the plans in relation to the specific objectives of the initiative. However, the scoring system is not explained in the IA. The score ranges from '+' to '+++' for the design of the plans, and from '+' to '++++' for the scope of the plans, from least effective to most effective.

Efficiency is not sufficiently considered in the comparison of the options, and quantification of costs and benefits is limited. The IA states that all the options would lead to the direct and indirect benefits (such as reduction of compliance costs to access EU funds and improved framework conditions) presented in Annex 3, but their magnitude depends on the extent of the plan's scope. Regarding the costs, Options 1 and 2a would bring the biggest reduction, followed by Option 2b. The IA does not assess the estimated costs for Option 3.

In the assessment of coherence, Option 1 would help to ensure better policy coherence across cohesion policy funds. Option 2a would also tackle the limited overlaps that exist in the EU budget's support to rural areas, and Option 2b would bring additional coherence to common agricultural policy spending. Option 3 would reduce the overlaps that currently exist with cohesion policy.

After comparing the options, the IA concludes that Option 3 is the most effective option, which would further contribute to enhancing efficiency and flexibility of nationally pre-allocated envelopes – with Option 3b providing more benefits than Option 3a.

Monitoring and evaluation

The IA does not present specific monitoring indicators relevant to the objectives of the proposed regulation. Instead, it refers to the performance framework for the post-2027 budget, which is examined in a separate impact assessment. The performance framework includes an implementation report during that phase of the programme, and an ex-post evaluation (IA, p. 53). According to the IA, the evaluation will be conducted in agreement with the BRGs and will be based on indicators relevant to the initiatives' objectives. However, it remains unclear how progress in achieving the objectives will be measured. Overall, the IA should have been clearer on how and which data will be collected, how the specific indicators will be identified and used to measure performance, and on the timeline for the evaluation.

Stakeholder consultation

As required by the BRGs, the Commission carried out several stakeholder consultation activities. A summary (synopsis report) of the stakeholder consultation and an overview of the stakeholder consultation activities as well as the targeted stakeholder groups (including public authorities, citizens, non-governmental organisation, academic and research institutions, businesses and business associations) are presented in a separate annex (IA, Annex 2).

The open public consultation (OPC) was carried out from 12 February to 7 May 2025, meeting the BRGs' 12-week requirement and resulting in 2 501 replies and 613 position papers. According to the OPC's factual summary report, all EU Member States were represented, though participation varied between countries. Furthermore, the Commission conducted targeted consultation activities with citizens, policymakers, think tanks, civil society organisation and businesses to engage stakeholders and gather input to inform the IA. However, the consultation does not cover sufficiently all relevant policy areas that the IA is supposed to cover (e.g. home affairs funds).

Overall, the annex on stakeholder consultation is informative and comprehensive, providing an insight into stakeholders' views (grouped by stakeholder activity). However, there is no systematic differentiation between preferences expressed by the various stakeholders. In addition, the stakeholders' views are not clearly presented and systematically referred to throughout the IA. The feedback from this consultation strategy could have been better reflected and considered in the IA, particularly regarding the available policy options and their potential impact.

Supporting data and analytical methods used

The IA does not include a dedicated annex to present the analytical methods used (Tool #11, Better Regulation Toolbox). Instead, it merely provides a list of sources under Annex 1, pp. 56-57. The analysis is primarily qualitative and relies on desk research complemented by a range of sources. Among them, the IA draws on the external study supporting the mid-term evaluation of the RRF (IA, pp. 13, 18, 34) and the study on the second interim report on the administrative costs in the management of the CPR funds 2021-2027 (IA, pp. 46, and Annex 10, pp. 108-109), stakeholders' feedback, programme evaluations, strategic reports,¹³ and other relevant documents. The data sources are not well referenced (with most not hyperlinked), and there is no supporting study underpinning this IA. Regarding modelling, the IA explains the use of the RHOMOLO model (Annex 11), which is well-referenced. A description of the use of the model is publicly available in the Commission's Modelling Inventory and Knowledge Management System (MIDAS). The RHOMOLO model was used to simulate the impact of cohesion policy interventions for 2021-2027 for the policy options (IA, p. 36).

Although the IA refers to limitations affecting the credibility and consistency of the evidence base, it lacks, overall, comprehensive quantification of costs and benefits, and robust evidence to support its analysis and findings. At the same time, the methodological assumptions for the quantitative analysis should have been provided transparently and justified with evidence.

Follow-up to Commission Regulatory Scrutiny Board opinion

The Regulatory Scrutiny Board (RSB) issued an opinion without qualification¹⁴ on the draft IA on 10 July 2025. The opinion refers to Better Regulation Tool #9 and states that 'given the lack of fundamental elements in this IA, the Board decided, exceptionally, to issue an Opinion without qualification' (RSB opinion, p. 1). This absence of quality scoring also concerns the other MFF-related IAs that the Commission published between July and September 2025. The RSB opinion was not published in the Register of Commission Documents as mandated by Tool #3 of the Better Regulation Toolbox.

The RSB flagged significant shortcomings throughout the draft IA and asked for clarifications regarding the scope of the initiative, the problems and the identification of problem drivers, the intervention logic and objectives, the options and their comparison, the cost-benefit analysis, the coherence, the governance mechanisms of the options, and the monitoring and evaluation arrangements. As required in the BRGs, the IA provides explanations on how the RSB's remarks were considered in the revised IA (Annex 1, pp. 54-56). It appears that efforts were made to address these recommendations, but the IA only partially incorporates the points raised by the RSB.

Coherence between the Commission's legislative proposal and IA

The legislative proposals appear to be aligned with the preferred policy option (Option 3b) identified in the IA.¹⁵

This briefing, prepared for the Committees on Budgets (BUDG), Regional Development (REGI), and Agriculture and Rural Development (AGRI), 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.