A quarter of the EU’s long-term budget flows through three cohesion policy funds. Halfway through the 2021-2027 programming period, the European Commission has put them to the test: the mid-term evaluation (MTE) shows those who manage or receive the funds where programmes are working and where, instead, they are stalling. One of the two pillars of the evaluation is a study by a consortium that includes T33, a company of the OpenEconomics Group, whose findings on how to make programmes more efficient look ahead to the next multiannual financial framework (MFF) for 2028-2034.
Cohesion programmes: a mid-term check
The Treaty on the Functioning of the European Union gives cohesion policy a precise task: to reduce disparities between regions. According to the latest Commission report, those disparities have narrowed, but unevenly. Some regions still lag behind in income, employment and infrastructure.
For 2021-2027, the European Regional Development Fund (ERDF), the Cohesion Fund (CF) and the Just Transition Fund (JTF) have mobilised around €282.5 billion. The start was difficult. The COVID-19 pandemic, Russia’s war against Ukraine, the energy crisis and inflation delayed the adoption of the rules and drew resources away from administrations.
The Common Provisions Regulation (CPR) requires the Commission to review the programmes at mid-term against five criteria: effectiveness, efficiency, relevance, coherence and EU added value. The tool for this is the MTE.
The MTE and the T33 study
The Commission published the MTE as a staff working document, with the aim of assessing the progress of cohesion policy. The evaluation combines two strands of work: an internal analysis by the Directorate-General for Regional and Urban Policy (DG REGIO) and a supporting study entrusted to an external consortium led by T33.
Carried out between January and September 2024, the study reviewed more than 500 documents relating to 90 programmes: 78 ERDF, CF and JTF programmes, covering more than 60% of the resources, and 12 Interreg programmes under European territorial cooperation. It collected 618 responses covering 297 programmes.
T33 evaluates European programmes at two levels. For Managing Authorities, the administrations that run the programmes, it works on regional and national programmes, mainly in Italy and Romania, and on Interreg programmes from the Baltic to the Black Sea and the Mediterranean. For the Commission, it carries out studies as well as mid-term and ex post evaluations.
Five criteria, five assessments
The MTE applies the five criteria of the EU Better Regulation guidelines. For each one, the Commission gives an assessment and identifies a critical issue.
Effectiveness
Implementation started late, largely for external reasons, but according to the Commission it caught up with the levels of the previous financial period in 2024. The JTF is gaining pace, and the territorial just transition plans were prepared with broad involvement of the territories concerned. The enabling conditions, the prerequisites for receiving funding, are fulfilled for 98% of the thematic conditions and for all horizontal conditions but one.
The critical issue concerns administrations: effectiveness depends on the quality of governance and on administrative capacity.
Efficiency
Administrative simplification is delivering results. The new measures and the mandatory electronic exchange of documents are reducing costs and administrative burden compared with 2014-2020. The monitoring system has improved, and the enabling conditions are clearer than the ex ante conditionalities of the previous period.
Two tools, however, remain underused: simplified cost options (SCOs), which reimburse on the basis of standard amounts rather than actual expenditure, and financing not linked to costs (FNLC). Reporting and audit requirements weigh on programmes, as does the application of the General Block Exemption Regulation (GBER) on State aid. Project data published on the Kohesio portal are hard to harmonise and poorly suited to counterfactual analysis, which measures the net effect of an intervention.
Coherence
All the funds examined have coordination mechanisms with other EU instruments, which are strongest with Horizon Europe, the Connecting Europe Facility, the European Social Fund Plus and Interreg. On climate, allocations exceed the minimum requirements: around 33% of the ERDF against a 30% target, 56% of the CF against 37%, and 100% of the JTF, more than double the 2014-2020 level.
The critical issue is the relationship with the Recovery and Resilience Facility (RRF), which funds the national recovery and resilience plans. Some mature projects were moved to the recovery plans, which probably contributed to the delay. Other burdens are the proliferation of strategic documents, with overlaps, and centralised approaches that sometimes fail to reflect local objectives.
EU added value
The Commission identifies four dimensions of EU added value: continuity of investment beyond national political cycles, additionality of resources, a place-based approach built on partnership, and stronger administrative capacity. The funds also support European public goods such as climate action, digitalisation and trans-European transport. Without them, the Commission notes, these interventions would receive slower and more limited support.
Relevance
Resources are concentrated where territorial disparities are greatest: around 72% of the ERDF goes to less developed regions. The programmes are aligned with the priorities of the European Semester, the Council’s Strategic Agenda and the Draghi report, with marked thematic and geographical variations. The 2025 mid-term review is the tool for realigning them with competitiveness, decarbonisation, defence, affordable housing, water resilience and the energy transition.
From delay to recovery
The study and the Commission’s evaluation capture two different moments. At the end of June 2024, the study still recorded a delay compared with the 2014-2020 period at the same stage of implementation. Resources allocated to selected projects stood at 20% of the budget for the ERDF (€62.7 billion), 23% for the CF (€11.2 billion), 22% for the JTF (€5.8 billion) and 34% for Interreg (€4.7 billion). Expenditure declared by beneficiaries ranged from 0.5% for the JTF to 3.8% for the CF, and 63% of output indicators showed no progress. Even so, the authors considered the most difficult phase to be over.
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Six months later, using December 2024 data, the Commission found that the delay had been made up. The MTE now serves as the baseline for the ex post evaluation of the current period, due by the end of 2031. The delay has been recovered. What remains to be proven is real effectiveness on the ground, through funding that is spent well.
The recommendations
The recommendations are concrete. The Commission suggests enabling conditions tailored to individual territories and new conditions linked to the policy objective “A Europe closer to citizens” and to the JTF, the fund that supports the territories most affected by the transition towards climate neutrality. It also considers a single approach to enabling conditions and the reforms set out in the national recovery and resilience plans. For the 2028-2034 budget, more automated data transmission at the level of individual operations is being considered. The study calls for a stable regulatory framework throughout the period, clear guidance from the outset, codes of conduct and training for partnership, and more precise territorial monitoring of added value.
What it means for programme managers
According to the evaluation, cohesion policy delivers results where administrations have the capacity to sustain it. For Managing Authorities, the most immediate room for improvement lies in two areas: using simplification tools that are already available but still underused, and improving the quality of project data, on which the measurement of impact will depend. The 2031 ex post evaluation will show how far this room for improvement has been used.
For funds worth a quarter of the EU’s long-term budget, the MTE is a map of the critical issues: useful for those preparing the next period and for those looking for funding opportunities.
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