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When rules meet reality – balancing the control and support function of managing authorities to deliver “beneficiary-centric” simplification of Cohesion Policy investments

Public Policy
Regulation
Policy Implementation
Member States
Policy-Making
Yingyin Wu
Sciences Po Paris
Yingyin Wu
Sciences Po Paris

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Abstract

Implementing investments under EU Cohesion Policy illustrates the complexity of EU policymaking and policy implementation in a multi-layered governance system. Between 2021 and 2027, Cohesion Policy is set to channel over EUR 500 billion across 58 specific objectives through nearly 200 measures. Investments are implemented through different strategies and programmes, under the common provision regulations and other regulatory frameworks, delivered through a complex management and control system, including managing authorities, payment and certifying functions, audit authorities, and the beneficiaries - municipalities, businesses, NGOs, universities, etc. Building on case studies of six Cohesion Policy programmes and surveys among 1058 beneficiaries, this study revealed the obstacles faced by beneficiaries in investment implementation, notably administrative complexity, frequent regulatory changes, and a perceived lack of thematic expertise (e.g., social innovation, green transition). Inconsistent rule interpretation across authorities also fosters a climate of caution within the management and control system, contributing to a lack of clarity in implementation. Around 40% beneficiaries indicate that they struggle to keep up with legislative and regulatory changes – far more than beneficiaries struggling with compliance itself (20%). Beneficiaries need tools to manage risks and changes in project implementation, as well as overcome operational and regulatory hurdles. The study also found that beneficiaries present different capacity needs across a variety of parameters, including programmes (e.g. regional, national, transnational), organisational types (e.g. public, private), project size and experience with Cohesion Policy funds. Simplification efforts and beneficiary support need to be precisely tailored, addressing both the specific programme objectives and the needs of different beneficiary groups. Cohesion Policy investment processes must be “beneficiary friendly” to avoid sidelining high-quality projects owing to administrative complexities. Managing authorities play a critical role in delivering “beneficiary-centric” simplification. However, how beneficiary support and simplification are delivered is open to interpretation and often overshadowed by other roles and tasks – especially the control functions such as reducing irregularities, ensuring compliance and managing audit trails. Managing authorities sometimes find it difficult to strike a balance between their roles as fund controllers and beneficiary advisors. Being in a “sandwich position”, managing authorities may perceive ambiguity in their interactions and relationships with beneficiaries. This ambiguity can result in inconsistent levels of guidance, reluctance to provide support or overly cautious communication, ultimately limiting beneficiaries’ ability to build capacity and engage effectively. In addition, managing authorities operate in environments shaped by the regulatory framework and multilevel governance model of EU Cohesion Policy, as well as the broader institutional and political expectations. These EU and national level framework conditions and dynamics can influence how they interpret their role in beneficiary capacity building, whether they prioritise regulatory compliance oversight or invest more effort in supporting and guiding beneficiaries, and to what extent they position themselves as beneficiaries’ partners. Helping managing authorities strike a balance between the control and support functions and build trust-based partnership with their beneficiaries requires a clearer mandate for them from a higher level – regional, national, European, or all three.