On 12 January, the European Court of Auditors (ECA), the EU body responsible for providing independent scrutiny of the Union’s budget, governance and finances, released two opinions on the European Competitiveness Fund (ECF) and the next EU framework programme for research and innovation, Framework Programme 10 (FP10). These opinions form part of a broader set of analyses feeding into discussions on the EU’s next Multiannual Financial Framework (MFF) for 2028–2034, within which both FP10 and the ECF would be financed.

Overall, the ECA criticises the proposals for their lack of clarity on key concepts and implementation mechanisms. In particular, it finds that both the ECF and FP10 proposals lack clear and consistent definitions of core notions such as “EU added value”, which is presented as a guiding principle. While the MFF is intended to prioritise areas where spending at EU level delivers greater added value than national action, the proposals do not explain how this concept would be defined or assessed in practice. The ECF proposal also fails to clarify how its spending objectives would be aligned with other EU policy priorities, including those related to addressing the Union’s strategic dependencies.

The ECA also finds that the Commission needs to strengthen provisions on compliance, transparency, accountability and traceability of EU spending beyond what is currently foreseen. It notes, in particular, that the ECF proposal does not include mandatory requirements for implementation reporting and ex post evaluation, despite these being core elements of the performance framework governing EU expenditure in the post-2027 budget. In addition, the Court recalls that research and innovation funding is considered a higher-risk spending area from a budgetary oversight perspective, given the complexity of projects and the number of beneficiaries involved and therefore requires robust financial management even where procedures are simplified. In this context, the ECA calls for clearer justification of how the proposed simplification measures would concretely benefit beneficiaries.

The opinions also examine specific instruments proposed by the Commission. For example, the new “Competitiveness Seal”, intended to identify projects eligible for simplified procedures and easier access to funding, is found to require further clarification. The ECA questions how this mechanism would operate in practice and how it would interact with existing schemes such as the Sovereignty Seal and the Seal of Excellence, which pursue similar objectives. Moreover, the Court warns that the combination of such instruments with increased budgetary flexibility could weaken the coherence of the EU’s state aid framework and the principle of equal treatment, potentially leading to market distortions. It therefore calls for stronger alignment between EU funding tools and competition rules in order to avoid fragmentation of the single market.

In addition, the opinions carefully evaluate the two separate proposals for FP10 and the ECF, and how they work together. While the EU’s auditors consider that the European Commission should further clarify its reasons for presenting two separate proposals, fearing risks of fragmentation, overlaps and administrative complexity, it underlines potential benefits of establishing clear and separate mandates, allowing more flexibility. To optimise the work of FP10 and the ECF, the ECA recommends putting in place a well-designed governance structure promoting coordination, coherence and information exchange, and to further clarify the impacts for beneficiaries of EU research funds.  

With regard to FP10, the ECA finds that the proposal should more clearly explain how the principle of excellence would be applied across all four pillars of the programme. While excellence is presented as a core foundation of the EU’s framework programme for research and innovation, the Court notes that it is not explicitly referenced under Pillars II and III — covering collaborative research and the European Innovation Council — which together account for more than half of FP10’s proposed budget.

EERA, together with several other stakeholders from the European research community, has already echoed a number of concerns raised by the ECA through a range of advocacy and policy positioning activities. Among a broader set of issues, this includes calls for clearer explanations of how the European Competitiveness Fund would interact with FP10, and what the proposed instruments would mean for the role of excellence within the EU’s future research and innovation framework—areas that are central to EERA’s ongoing engagement.