OBJECTIVES
Testing whether the system is ready to scale up
European Structural and Investment Funds are entering a new phase. The traditional model, based on reimbursing documented expenditure, is gradually giving way to a results-based approach: paying not for what has been spent, but for what has been achieved. This logic, defined in EU regulations as “financing not linked to costs” (FNLC), needs robust, measurable and verifiable indicators to work effectively.
The European Commission (DG REGIO) tasked t33 – now part of the OpenEconomics group – with answering a specific question: are the common indicators already used by 204 ERDF and Cohesion Fund programmes 2021–2027 suitable to become payment conditions in an FNLC system?
THE SOLUTION
A four-stage analysis covering 204 programmes
The study developed a four-step methodology, applied sequentially:
• Quantitative analysis: assessment of all common ERDF/CF indicators in terms of frequency (how often they are used), relevance (which financial allocations they are associated with) and consistency (whether programmes with similar allocations set similar targets).
• Qualitative analysis: in-depth review of 43 selected indicators and 35 methodological documents under Article 17 CPR, to verify consistency with Commission definitions and homogeneity of implementation across programmes and Member States.
• Comparative analysis: comparison between the ERDF/CF indicator system and the milestones and targets of the Recovery and Resilience Facility (RRF), to identify strengths and weaknesses of each system from an FNLC perspective.
• Applied testing: development of Investment Action Matrices (IAM) for each type of investment, combining process, output and result indicators to provide an operational blueprint for triggering FNLC payments.
RESULTS
Ninety per cent of indicators are already fit for purpose. The bottleneck is operational
The analysis delivered clear and directly usable findings for the Commission and the Member States:
• 43 common indicators, out of more than 100 analysed, show sufficient frequency, methodological robustness and consistency to be used as payment triggers in an FNLC system.
• 90% of the indicators examined respond positively to the key criticisms raised by the European Court of Auditors on the RRF monitoring system.
• The ERDF/CF system displays a degree of standardisation and cross-country comparability that the RRF – with targets negotiated country by country – does not structurally provide.
• The Investment Action Matrices developed for five thematic areas (energy efficiency, SMEs, transport, education/health, territorial development) provide ready-to-use operational schemes for managing authorities and beneficiaries.
• The study also sets out the limitations and enabling conditions for effective implementation: always combining the three levels (process, output, result), updating aggregation rules and measurement timelines, and putting in place independent verification mechanisms.
A solid basis for designing the 2028–2034 programmes
The regulatory proposals appear to have taken on board a significant number of elements emerging from, or recommended by, the study.
First, a substantial share of the Commission’s common indicators has been integrated into the list of performance indicators included in the draft regulation. In particular, around 65% of output indicators and 40% of result indicators in the proposal are identical, or very close, to the common indicators. This is a significant result, especially considering that the scope of the new partnership plans will be markedly broader than that of the ERDF.
Moreover, the framework proposed in the study – which includes process indicators – also seems to have been reflected in the new proposal for future national and regional Partnership Plans (2028–2034). In the current template for future plans, each chapter requires measures to be accompanied by both qualitative and quantitative targets, in line with the study’s recommendations.
The study was published by the European Commission in September 2025 and is available at this link.
.png){kind=small}
.png){kind=small}