Considerations on COM(2025)84 - Amendment of Regulations (EU) 2015/1017, (EU) 2021/523, (EU) 2021/695 and (EU) 2021/1153 as regards increasing the efficiency of the EU guarantee under Regulation (EU) 2021/523 and simplifying reporting requirements

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(1) The Union faces massive financing needs to deliver on its objectives in the areas of innovation, the clean and digital transition, and social investment and skills, while a complex backdrop affecting the Union’s competitiveness and industrial base characterised by changing global dynamics, slow economic growth, accelerated climate change and environmental degradation, technological competition and rising geopolitical tensions needs to be addressed.

(2) The Draghi report assesses the combined additional investment needs in Europe at EUR 750-800 billion per year by 2030. This includes a substantial amount for the green and digital transition. Ensuring sufficient public and private investment is critical to boost productivity growth and achieve Union’s goals, leverage private investments with the objective to decarbonise industry, accelerate the production, storage and deployment of clean energy and electrification, strengthen interconnections and grids, advance sustainable and circular business models, foster building renovation, develop clean tech manufacturing as well as digital technologies and their diffusion across economic sectors.

(3) The InvestEU Fund is the main EU-level tool to leverage public and private funding to support a broad range of Union policy priorities. Through its comprehensive network of implementing partners, including the European Investment Bank (EIB), the European Investment Fund (EIF), other international financial institutions and national promotional banks and institutions, the InvestEU Fund is delivering much-needed financing through its risk-sharing capacity. The InvestEU interim evaluation highlighted that budgetary guarantees are inherently efficient for the EU budget and confirmed that the programme is well on track to mobilise investment, with a notable expected impact on the real economy. However, approvals of financing and investment operation under InvestEU were heavily frontloaded, and as a result, if no action is taken to address the issue, new approvals for some financial products may cease after 2025.

(4) The financial capacity of InvestEU Fund should be increased and used even more efficiently in combination with resources that will become available under the European Fund for Strategic Investments (EFSI) and other legacy instruments (CEF Debt Instrument and InnovFin Debt Facility) implemented by the EIB Group. These combinations potentially reduce the budget revenues from legacy instruments. However, they would also create the possibility for an increased volume of guarantee cover to be provided for strategic investments in key Union priority areas for an additional investment of around EUR 25 billion that can be expected to be mobilised and by leading to an increased diversification of risks and thus not substantially increasing the risks for the Union budget.

(5) With the EUR 2.5 billion increase of the EU guarantee underpinned by the additional reflows of EUR 1 billion, and the efficiency measures implemented by combining the capacities of the legacy instruments with the InvestEU Fund, it is expected that around EUR 50 billion in additional investment could be mobilised. The financial contribution of the EIB Group should be proportionally adjusted to the share of the increased EU guarantee allocated to them.

(6) In order to enhance the attractiveness of the Member State compartment under the InvestEU Fund, it should be made possible for Member States to contribute also in a fully funded manner through an InvestEU financial instrument in addition to the existing option of contributing to the EU guarantee. The support from InvestEU financial instrument should, to the extent possible, be implemented following the same principles as those of the EU guarantee. Through the InvestEU financial instrument, non-euro Member States could benefit from the InvestEU programme financially more efficiently in their own currency.   

(7) In line with an overall objective of simplification so as to alleviate the administrative burden for final recipients, financial intermediaries and implementing partners, reporting requirements, including those relating to key performance and monitoring indicators, should be reduced, where appropriate, in particular those that affect small businesses and small-size operations. The application of the definition of an SME should be adjusted to remove complexities to the extent possible. Specific attention should be paid to social economy enterprises and micro finance institutions.

(8) The frequency and scope of reports should also be reduced for the InvestEU programme and its predecessor, the EFSI programme.

(9) For the Commission’s accounting, implementing partners should provide for combinations audited financial statements in line with Article 212(4) of the Financial Regulation, clearly delineating the amounts related to the different legal basis.

(10) Regulations (EU) 2015/1017, (EU) 2021/695 and (EU) 2021/1153 should be amended to allow for combinations of support under those Regulations and the EU guarantee under this Regulation.

(11) Since the objectives of this Regulation, namely to address Union-wide and Member State specific market failures and the investment gap within the Union, to accelerate the Union’s green and digital transition, enhance its competitiveness and strengthen its industrial base cannot be sufficiently achieved by the Member States, but can be better achieved at Union level, the Union may adopt measures in accordance with the principle of subsidiarity as set out in Article 5 of the Treaty on European Union. In accordance with the principle of proportionality as set out in that Article, this Regulation does not go beyond what is necessary to achieve those objectives,