The European Commission drew up seven impact assessments (IAs) in support of 18 programme proposals for the 2028-2034 multiannual financial framework (MFF) and the proposed regulation on a horizontal performance framework. The broad scope of these IAs does not allow individual programme proposals to be assessed in any detail – as is particularly salient in the case of the IA on the national and regional partnership plans, covering nine legislative proposals. All IAs acknowledge a deviation from the scope and depth of a standard IA as defined by the Better Regulation Guidelines (BRG). This is justified with Tool #9 of the BR Toolbox, which indicates the specificity of the MFF, but does not define how related IAs should be carried out. As a result, the application of the better regulation principles varies widely across the MFF IAs. They are similar insofar as the Commission chose for all of them a mostly horizontal rather than policy-specific approach and did not include any budgetary considerations and scenarios. These choices affect the quality of key sections of the IAs considerably, albeit to varying extents. The problem definition often lacks specificity and substantiation. Similarly, the IAs’ objectives remain largely unspecific, which, in turn, affects the IAs’ monitoring and evaluation provisions and risks hampering the future measuring of the objectives’ achievement. The description of policy options is in most cases short and vague, which weakens the impact analysis. The depth to which economic, social and environmental impacts are assessed varies across the sampled IAs. The analysis remains predominantly qualitative, with quantification largely lacking. All seven MFF initiatives are deemed relevant for small and medium-sized enterprises (SME) and are thus listed in the ‘SME filter’. The IAs state that they place great emphasis on simplification and burden reduction. None of them is accompanied by a subsidiarity grid, and they discuss subsidiarity, European added value and proportionality rather briefly. While the IAs differ considerably in terms of quality and transparency when it comes to their evidence base and methodology, all of them acknowledge certain limitations and a lack of data (notably quantitative data). Consultation activities were largely limited to open public consultations. The Regulatory Scrutiny Board (RSB) found significant shortcomings in all seven draft IAs, prompting it, exceptionally, to issue opinions without qualification. The persisting flaws in the final IAs suggest that the RSB recommendations have at best been partially addressed. Altogether, the limited quality of the MFF IAs appears to reflect a missed opportunity to provide policymakers with high-quality and transparent evidence for one of the most important policy packages to be negotiated in the coming months and years.
Source : © European Union, 2026 – EP
