2028-2034 MFF: Reinforcing competitiveness in the EU

Briefing 13-11-2025

The impact assessment (IA) acknowledges a deviation from the scope and the depth of analysis of standard IAs as defined in the Better Regulation Guidelines (BRG) and Toolbox by reference to Tool #9 (special case of preparing a new multiannual financial framework). While the Regulatory Scrutiny Board (RSB) acknowledged the applicability of Tool #9, it concluded that the draft IA report contained significant shortcomings spread across almost all sections. It appears that the recommendations of the RSB were only partially taken into account in the final IA. The IA, which relies on several data sources, provides a comprehensive description of the existing situation. The problem definition appears to rely on evidence from various data sources, including interim and ex-post evaluations of EU programmes. However, relevant elements of the evaluation's conclusions could have been stated more consistently throughout the IA. The description of the problems and their drivers could have been more structured and clearer. The IA presents three options in addition to the baseline scenario. The options are only partially linked to the problems, the problem drivers and the objectives, against the requirement by the BRG. It is questionable whether they all present fully realistic alternatives to the baseline. The IA presents the core elements of each option only briefly and does not clearly describe how they will contribute to reaching the objectives of the initiatives. When comparing and scoring the options against the BRG criteria of effectiveness, efficiency and coherence, the scoring method could have been further clarified. Proportionality is not addressed in the IA. The IA assesses the economic, social and environmental impacts of the options. The analysis encompasses both qualitative and quantitative components. However, the IA openly mentions the limitations constraining the completeness and consistency of the evidence base. The proposals appear to be coherent with the preferred policy option identified in the IA.