18/ read my recommendations for the ECF here: bst-europe.eu/competitiven...

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17/ As a result, much of the emphasis will fall on the financial instruments side (particularly via the InvestEU instrument) where magical multipliers and financial alchemy are expected to produce eye-watering figures from limited true funding.

16/ Money is key. Horizon successor will keep most of its pillars - with a bigger role for ERC and EIC. Meaning the ECF will only consolidate a limited share of funding. If the next MFF does not come with more money for competitiveness, the ECF will likely have limited actual money to throw around.

15/ In fact, COM discretion is even stronger than anticipated: via the work programmes, larger flexibility margins and the intervention mechanism. This centralisation raises familiar concerns about the balance of power between EU institutions. EP's limited role will likely be a point of contention.

14/ Overall, the proposal is coherent and ambitious. Many of my core recommendations are reflected: competitiveness-driven consolidation, sensible thematic windows, the exclusion of basic research and "widening" measures, and greater COM agility.

13/ Composition and mechanism of the CCT remain to be clarified. The CCT is expected to expand beyond the ECF itself and play a role in aligning broader EU industrial policy - covering areas such as state aid frameworks, IPCEIs, FP10, and the ECF. It will be crucial to get this tool right!

12/ The CCT is supposed to align the work programmes across the four policy windows, ensure coherence between grant-based and financial instruments and manage interlinkages with other EU funds.

12/ Coordination and steering: There will be a Stakeholder Board, which provides non-binding expert input. However, the main steering body will be the Commission, which ensures coordination of design and implementation through the somewhat ominous Competitiveness Coordination Tool (CCT).

11/ While the regulation states that such interventions are supposed to be time-limited, no specific duration is defined. This setup suggests a high degree of COM autonomy in reprogramming and budget allocation.

10/ There will also be a specific emergency tool for enhanced flexibility: the intervention mechanism. It allows the COM to reallocate funding at its discretion whenever it determines that an "urgent situation which affects the Union's competitiveness" has occurred.

9/ Additionally, the work programmes offer greater flexibility in the design of grant-based instruments compared to the standard annual budgetary procedure - normally used for directly managed programmes, such as in Horizon Europe.

8/ Flexibility is central to the ECF design. A 20% flexibility margin is introduced, allowing reallocation of budget across windows and between instruments (we had proposed 15%). Note: This applies only to financial Investment guidelines.

7/ this means Parliament and Council retain more control (they can revoke delegated powers), making this process more politically accountable than the Work Programmes.

6/ The ECF aims to make full use of the EU's financial toolbox (guarantees, loans, etc). Financial instruments are not designed via the Work Programmes, but defined in a second pillar of governance: the Investment Guidelines. These guidelines are adopted via delegated acts, not comitology.

5/ This model prevents annual budget gridlocks, enhances flexibility, allows for expert-driven decisions rather than politically negotiated compromises.
Still, sidelining the European Parliament reduces democratic oversight and will likely intensify concerns about a “power grab” by the Commission.

4/ this sidelines the European Parliament. States retain more oversight, particularly in defence, where the use of the examination procedure gives them more direct control, as any implementing act would need to pass by qualified majority vote. For other windows, only the advisory procedure applies.

3/ Non-financial instruments (essentially all grant-based funding) are defined via Work Programmes adopted via comitology. Instead of going through the annual budgetary procedure, this setup grants the COM significant autonomy and flexibility in designing instruments and allocating funds.