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Europaudvalget 2025
KOM (2025) 0299
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EUROPEAN COMMISSION

Brussels, 5.5.2025

SEC(2025) 169 final

REGULATORY SCRUTINY BOARD OPINION

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE

COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE

COMMITTEE OF THE REGIONS

The European Defence Fund: supporting the development of the defence capabilities of

tomorrow Interim evaluation of the European Defence Fund

{COM(2025) 299 final}

{SWD(2025) 151 final}

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EUROPEAN COMMISSION

Regulatory Scrutiny Board

Brussels,

Ares(2025)

Opinion

Title: Evaluation/fitness check of the European Defence Fund

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context

The EUR 7.3 billion European Defence Fund (EDF) is the EU’s defence research and

development (R&D) funding programme for 2021-2027 which aims to strengthen the

competitiveness, efficiency, and innovation of the EU defence industry. It supports cross-

border collaboration, particularly among SMEs and mid-sized companies, and improves

defence supply and value chains. The EDF is designed to integrate co-financing thereby

leveraging national contributions.

The EDF builds on two precursor programmes: the 2017-2019 Preparatory Action on

Defence Research (PADR) and the 2019-2020 European Defence Industrial Development

Programme (EDIDP). In line with Article 29 of the EDF Regulation, the interim

evaluation covers the period 30 June 2021 until 31 July 2024.

(B) Key issues

The Board notes the additional information provided in advance of the meeting and

commitments to make changes to the report.

However, the report still contains shortcomings. The Board gives a positive opinion

with reservations because it expects the lead Service to rectify the following aspects:

(1) The analysis of the performance of the programme is not framed by an

intervention logic that fit for the purpose of the evaluation. The specific

objectives are insufficiently operationalised.

(2) The report does not provide sufficient reassurance on the effectiveness of the

monitoring and evaluation framework or that it will adequately support the

final evaluation. The data and data collection limitations are not properly

reflected in the conclusions.

(3) The presentation of the findings and data does not allow for a robust

appreciation of the programme's effectiveness and efficiency. It does not use

possible benchmarking to demonstrate the programme’s benefits. The

Rhomolo-based projection of the benefits is inappropriate for the purpose of

the evaluation or the specificities of the defence sector.

________________________________

This opinion concerns a draft evaluation which may differ from the final version.

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: [email protected]

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(4) The conclusions do not reflect the outcome of the analysis in a balanced way.

1) The report should review the programme’s intervention logic to ensure the European

Defence Fund's (EDF) specific objectives are sufficiently operationalised to be

precise enough and measurable. The report should reconstruct the intervention logic

to include causal links between its elements, allowing for a better assessment of the

programme's progress towards success, thereby preparing the ground for the final

evaluation. Against this backdrop, the report should discuss the validity of the

indicators set out in the Regulation’s Annex and the programme’s monitoring and

evaluation framework to ensure they are fit for future monitoring and capable of

providing meaningful results at the time of the final evaluation. This includes

assessing the framework's ability to track the programme's progress and propose

possible adjustments. The findings on evidence gaps on monitoring and reporting

arrangements should be reflected in the conclusions section. In the lessons learned

section of the report an analysis should be included whether and how the indicators

in the Regulations’ Annex and the monitoring and evaluation framework should be

amended.

2) The report should better link the findings with the corresponding evidence and

analytical methods. Given its wide reliance on the stakeholder consultations, the

report should transparently present views from different groups and data from all

affected parties, including non-participants to the programme whose feedback can

provide valuable insights into the programming and implementation shortcomings.

3) Further, the report should review the parts of the effectiveness and efficiency analysis

(and corresponding conclusions) that are based inappropriately on the

macroeconomic projections of the Rhomolo model, which – being an ex-ante

methodology – is conceptually misplaced for demonstrating benefits in retrospective

evaluations. The unsuitability of this model is further accentuated by the numerous

specificities of the defence sector which are not adequately considered by the model.

Instead, the report at this stage should establish effectiveness and efficiency using

other methods, complementing the output indicators with a comparison with the pre-

programme situation in the defence industry and the national approach to R&D in the

sector, benchmarking against earlier projects or approaches and/or explaining the

limitations of the possible points of comparison. The report should assess key

implementing modalities of the programme such as allocation of bonus points in the

project selection phase. Anecdotal evidence and flagship achievements, e.g. around

the prototypes envisaged and under development within the pipeline of ongoing

projects should be used to a greater extent to build the case as potential indicators of

the future programme’s success. The report should also better present the nature and

results of the increased cooperation and multinational partnerships in innovation,

discussing value added of reduced fragmentation and increased convergence and

impacts on competitiveness of the sector.

4) Regarding efficiency, the report should consider the costs associated with reporting

and project coordination accruing to the stakeholders. It should discuss the lead time

of its programming phases, accentuating the adequacy of the framework and

identifying justified potential for improving efficiency. The report should assess to

what extent the programme allows for sufficient agility and reactivity in the evolving

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dynamic geopolitical context with quickly emerging needs, notably through the lens

of the Russian war of aggression against Ukraine.

5) The report should draw conclusions, reflecting the outcome of the analysis of the

programme’s functioning, paving the way for the necessary adjustments.

Some more technical comments have been sent directly to the author Service.

(D) Conclusion

The lead Service should revise the report before launching the interservice

consultation.

Full title

Reference number

Submitted to RSB on

Date of RSB meeting

Interim evaluation of the European Defence Fund

PLAN/2023/1621

2 April 2025

30 April 2025

Electronically signed on 05/05/2025 17:34 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121