CSOs position on the potential merger of the NDICI-GE, IPA and HUMA
We have been informed of a proposal by DG BUDG to merge the EU’s development and international cooperation instrument (NDICI), humanitarian aid instrument (HUMA), and instrument for pre-accession (IPA) into a single instrument. This proposal includes a limited number of budget lines and an annual allocation process that would replace programming for the NDICI. This change is reportedly aimed at increasing flexibility.
While we acknowledge the need for the EU to adapt to global and domestic challenges, we believe such an overhaul risks undermining the EU's ability to achieve its objectives and honor its commitments. Flexibility is essential for responding to unforeseen challenges, but it must be balanced with predictable funding to ensure the EU can meet its long-term goals and maintain accountability for its expenditures.
We oppose this merger for several reasons:
1. IMPACT: the merger would reduce each instrument’s impact
Maintaining separate instruments enables the EU to effectively pursue its humanitarian, development, and enlargement objectives without compromising their integrity, focus, or visibility. It also provides the flexibility needed to tailor actions to specific contexts. Each instrument serves a distinct purpose and operates within dedicated principles and frameworks.
Merging these instruments into a single framework risks undermining their unique objectives and effectiveness:
Humanitarian action: Humanitarian aid addresses immediate, life-saving needs in crisis situations and adheres to the principles of neutrality, independence, and impartiality, as enshrined in the Treaty on the Functioning of the EU and the European Consensus on Humanitarian Aid. These principles are essential for maintaining trust and access in conflict zones. EU humanitarian aid must remain free from political, strategic, military, or economic objectives.
Integrating humanitarian aid with instruments like the NDICI-GE or IPA would risk politicizing it, undermining its neutrality, and damaging the EU's credibility as an impartial provider of assistance. Such a merger could obscure its distinct role in delivering humanitarian support, ultimately weakening its global reputation as a principled actor in emergencies.
Development: The NDICI-GE supports long-term development through multi-year funding programs aligned with the Sustainable Development Goals and frameworks like the European Consensus on Development. Maintaining a separate, programmable instrument—enhanced by flexibility features such as the cushion for emerging priorities—ensures greater impact and avoids the risk of diverting resources to short-term needs or unrelated policy areas.
A unified instrument could dilute the NDICI-GE’s focus, making it more difficult to achieve development goals, and reduce the visibility of the EU’s contributions to global challenges.
An annual allocation process would likely dismantle the Team Europe approach, reducing the coherence and impact of EU action. It would disrupt predictability, and hinder partner countries' ability to plan effectively, ultimately compromising long-term progress.
A merger would jeopardize the existence of benchmarks and targets that have been instrumental in steering funding toward long-standing EU development priorities. These benchmarks have also enhanced the EU’s visibility as a leader in areas such as gender equality and human development. Without them, the EU’s contributions to critical development objectives risk becoming more ad hoc, lacking a clear trajectory.
Pre-accession: IPA III is specifically designed to help candidate and potential candidate countries prepare for EU membership by supporting institutional reforms, alignment with EU laws, and capacity-building. This instrument ensures adherence to strict criteria for governance, democracy, and the rule of law.
Merging IPA with broader instruments risks redirecting funds to other priorities, potentially slowing enlargement progress.
Treating accession countries under the same framework as development partners could provoke resistance, as these countries have a more advanced and distinct relationship with the EU.
A unified approach could blur the EU’s role in enlargement, weaken its influence, and further delay integration.
2. FUNDING: The merger would force complex trade-offs and potentially reduce funding
If the European Commission consolidates three smaller instruments into one large framework, it might create the impression of substantial funding for external action. However, this approach increases the risk of budget cuts during negotiations, potentially leaving less funding available for each specific purpose.
On an annual basis, managing trade-offs would become increasingly complex. Humanitarian crises could require immediate reallocation of funds, potentially diverting resources from long-term development programs or pre-accession assistance. Accession-related needs - difficult to predict but expected to grow as the EU expands eastward - might further strain development and humanitarian aid budgets.
If Member States perceive that humanitarian aid is being compromised, they may choose to channel their contributions bilaterally, undermining the EU’s collective response.
3. CREDIBILITY: a single instrument could jeopardize the EU’s reputation as a credible and reliable partner, and well as erode EU’s citizens trust
The mid-term revision of the Multiannual Financial Framework demonstrated that reallocating long-term development funds from partner countries to address immediate political priorities poses significant reputational risks. Further reallocations, such as diverting development funds to support wealthier countries’ EU accession, could exacerbate criticism and distrust from external partners - at a time when strong partnerships are crucial for achieving the EU’s internal and external objectives.
A transactional approach that prioritizes short-term goals like migration management and investment risks alienating fragile states, undermining the EU’s soft power, and eroding trust in its commitment to development goals.
Jeopardizing the EU’s ability to act effectively in each of these areas also carries significant reputational risk with EU citizens. EU citizens are staunch supporters of external action, with 91% of citizens believing it is important that the EU funds humanitarian activities[1] and 75% believe it's important that the EU invests in partner countries[2]. Undermining the EU’s ability to act in these areas could affect citizens’ support for the EU overall.
4. GOVERNANCE: complexity in governance and oversight - who decides?
Maintaining separate instruments ensures clearer accountability, enabling more straightforward scrutiny of funds and their impact. It is unclear who would provide the strategic steer for implementing a single, merged external instrument. Currently, each instrument operates with its own governance structure and accountability mechanisms, which are essential for ensuring transparency and effectiveness.
A unified budget risks diluting this clarity, making it more challenging to assess the effectiveness of funding across development, humanitarian, and pre-accession areas.
Merging these instruments could introduce significant governance challenges. It could complicate oversight and increase bureaucracy, slowing down decision-making processes - particularly for crisis response and humanitarian aid. While a single framework might provide greater flexibility for the European Commission, it would reduce the number of budget lines, limiting the European Parliament's ability to exercise robust oversight.
Monitoring cross-cutting priorities like gender mainstreaming could become more complex, weakening the EU's commitment to these objectives.
Member States and their working parties would face greater difficulties in tracking whether funds are being used effectively and for their intended purposes.
Public accountability, including oversight by civil society organizations, would also be weakened, as it would become harder to trace how funds are allocated and aligned with their objectives.
What do existing evaluations say?
NDICI
European Court of Auditors (ECA) 2019 opinion[3]
- The NDICI-GE successfully simplifies ways of working, enhances the coherence and consistency of its interventions.
- It demonstrates greater flexibility in addressing unforeseen challenges and crises.
ECA2023 Special Report[4]
- The NDICI-GE addressed issues such as overlapping aid, diverging objectives, and lack of flexibility, offering a more strategic approach.
- A proper programming exercise is crucial to ensure that EU support addresses partner countries’ needs, while taking into account their commitment to carrying out reforms, their domestic capacity and contributions from other donors.
2024 independent mid-term evaluation of EU’s external instruments[5]
- The NDICI-GE remains fit for purpose, effectively delivering against its objectives.
- The NDICI-GE serves as a key tool to roll out the Global Gateway strategy and enables the EU to promote its internal policies and priorities in a more coherent manner to the external world.
- It brought significant added value by offering a more integrated, sizable, and coherent approach to external relations compared to the previous MFF, improving partner countries’ capacity to address joint priorities with the EU and tackle global challenges.
- Current instruments have increased the collective engagement of European actors in EU external cooperation through the Team Europe approach.
- The various flexibility features of the NDICI-GE have proven their relevance in pursuing EU priorities and providing support to partner countries.
- The important role of programming was also confirmed by the evaluation to identify shared priorities and set a strategic cooperation framework over a medium-term, thus giving some predictability to partner countries.
- The June 2024 Council Conclusions[6] on the NDICI-GE confirmed that the instrument enhances the EU’s geopolitical role.
IPA
The mid-term evaluation of EU’s external financing instruments[7] found IPA III to be a holistic policy-first instrument, which mirrors the EU priorities and policy developments in preparing countries for the future membership of the Union. It has been effective in promoting socio-economic development and leveraging necessary investments, and it was flexible in responding to exceptional external events. It was also coherent with other areas of external action and EU internal policies.
References
https://europa.eu/eurobarometer/surveys/detail/2976
https://europa.eu/eurobarometer/surveys/detail/2952
Opinion No 10/2018 (pursuant to Article 322(1) TFEU) concerning the proposal for a Regulation of the European Parliament and of the Council establishing the Neighbourhood, Development and International Cooperation Instrument [COM(2018) 460 final]
Programming the Neighbourhood, Development and International Cooperation Instrument – Global Europe Comprehensive programmes with deficiencies in the methods for allocating funds and impact monitoring
Evaluation of the European Union’s External Financing Instruments (2014-2020 and 2021-2027)
https://www.consilium.europa.eu/en/press/press-releases/2024/06/24/council-approves-conclusions-on-the-mid-term-evaluation-of-the-ndici-global-europe-external-financing-instrument/
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52024DC0208