2028-2034 MFF: Budget expenditure-tracking and performance framework

Briefing 27-11-2025

The IA assesses a Commission proposal to establish an EU-wide expenditure-tracking and performance framework for the post-2027 MFF, aligned with the changes introduced by the 2024 recast of the Financial Regulation. The IA focuses on the implementation of the 'do no significant harm' (DNSH) and gender equality principles. It clearly identifies problems across the three pillars of the EU budget – programming, monitoring and reporting – and elaborates on their drivers. While the specific objectives are linked with the problems identified, they only partly satisfy the SMART (specific, measurable, achievable, relevant, and time-bound) criteria. The IA presents three option sets – one for each pillar – with their impacts analysed. The analysis is primarily qualitative due to acknowledged data gaps. The limited quantification of administrative costs for Member States and the Commission relies largely on Commission estimates and assumed reduction factors, with no quantified savings for beneficiaries because of insufficient data. The comparison of options shows that the preferred combination across the three pillars is the most effective, as well as the most efficient and coherent, indicating only limited trade-offs between options. The limited stakeholder feedback comes mainly from the open public consultation but is high-level and does not provide views on the proposed policy options. The monitoring and evaluation arrangements of the performance framework are insufficiently developed and only partially linked to operational objectives. While the Regulatory Scrutiny Board (RSB) acknowledged the applicability of Better Regulation Tool #9 (special case for preparing a new multiannual financial framework) and concluded that the draft IA report contained significant shortcomings spread across almost all sections, it appears that its recommendations were only partially taken into account in the final IA. Finally, although the proposal appears to follow the preferred combination of policy options, it introduces additional binding targets on climate biodiversity that are not presented in the IA report.