COVER TO BE INSERTED

Synthetic Report

Future EU funding to support the integration of refugees

and migrants
May 2019

Alexander Wolffhardt, MPG

1
Synthetic Reports are the final outcome of ReSOMA’s activities related to one of the most
pressing topics in the EU migration, asylum and integration debate. Bringing together find-
ings and results of previous ReSOMA Discussion Briefs and Policy Options Briefs, they provide
an overview of key controversies, available evidence and proposed policy alternatives.
Drawing on ReSOMA’s dialogue with policymakers, stakeholders and research, the Syn-
thetic Reports point to viable reform paths in order to fill crucial policy gaps in line with real-
ities on the ground, the rule of law and human rights. They have been written under the
supervision of Sergio Carrera (CEPS/EUI) and Thomas Huddleston (MPG).

Download this document and learn more about the Research Social Platform on Migration
and Asylum at: www.resoma.eu

LINGUISTIC VERSION
Original: EN

Manuscript completed in May 2019

Unless otherwise indicated, the opinions expressed in this document are attributable only to
the authors and not to any institution with which they are associated, nor do the opinions
necessarily represent the official position of the European Commission.

Reproduction and translation for non-commercial purposes are authorised, provided the
source is acknowledged and the publisher is given prior notice and sent a copy.

Contact: [email protected]

This project has received funding from the European Union’s Horizon 2020
research and innovation programme under grant agreement 770730

2
 ReSOMA Final Synthetic Report

Future EU funding to support the

integration of refugees and migrants*

1. INTRODUCTION

1.1. Overview including cities and civil society organisa-

tions are key stakeholders in these policy
Funding support through EU programmes debates, whose oucomes will be decisive
and their objectives is the EU’s main lever for the availability of means both for early
to promote the integration of migrants and longer-term integration, and on local
and refugees. Next to the soft law embod- level as much as for mainstreaming inte-
ied in policy guidelines like the Common gration across all relevant policy areas.
Basic Principles of immigrant integration, it
is the amounts, binding provisions and This report synthesizes previous ReSOMA
concrete spending rules of instruments briefs in the area of integration that have
such as the Asylum-, Migration and Inte- focused on the unfolding MFF debate. Fol-
gration Fund (AMIF) or the structural funds lowing an overview of the 2018 Commis-
including the European Social Fund (ESF) sion proposals which set out scope and
that define EU policy and a joint European structure of the future EU instruments
approach in the integration domain. In a (chapter 1.2), it presents twelve policy de-
number of Member States, EU funds are bates related to the ‘what’ and the ‘how’
even the sole or nearly only source of sup- of EU support for integratin and their
port for integration measures and -poli- stickicking points from a local level and
cies, rendering them crucially important civil society perspective (chapter 2). Partly
for the outlook and opportunities of mi- refering to the discourse responding to re-
grants and refugees in many places cent policy trends and how they became
across Europe. Against this background, incorporated in the Commission pro-
the proposals and negotiations on the up- posals, partly referring to long-standing
coming Multiannual Financial Framework debates between stakeholders and EU in-
(MFF), i.e. the 2021 to 2027 EU programme stitutions, the chapter offers an abridged
and funding period, have become the fo- version of key topics of debate as identi-
cal point of the EU integration debate fied in the previous ReSOMA Discussion
since 2018. Local level integration actors Briefs on ‘Cities as providers of services to

* By Alexander Wollfhardt, Migration Policy Group

3
migrant populations’, ‘Sustaining main- For each of these options main proposals
streaming of immigrant integration’ and are listed as voiced by stakeholder organ-
‘The social inclusion of undocumented mi- isations in the field, including the ReSOMA
grants’. partners ECRE, EUROCITIES, PICUM and So-
cial Platform. The chapter also shows, in
Against the background of these conver- each of the options, how the European
sations and controversies, stakeholders
Parliament has amended the Commission
came forward with numerous proposals to proposals, thus illustrating the uptake by
improve and amend the Commission pro- Parliament of solutions advocated for by
posals to better address their concerns. stakeholders. References to the previous
The European Parliament in 2018 has been ReSOMA Policy Options Briefs on ‘High lev-
the key arena of decision-making towards
els of EU support for migrant integration,
the 2021 to 2027 MFF, with MEPs able to implemented by civil society and local au-
amend the proposed legislation based on
thorities’ and ‘Comprehensive and main-
the concerns driving the policy controver- streamed, longer-term support for the inte-
sies and offering stakeholders the oppor- gration of migrants’ point to more in-depth
tunity to advocate for their own proposals. information on the evidence base sup-
Chapter 3 shows how the suggestions for
porting these proposals, the details of the
alternative solutions brought forward con- various stakeholders positions and a map-
verge around four mayor policy options ping of the EP amendments.
for the future of EU spending on integra-
tion: Chapter 4.1 sheds light on the state of play
as of spring 2019, with the EP positions on
 Adequate funding – to ensure suffi- the key EU instruments all decided before
cient and flexible spending on integra- the EP elections and clarified at time when
tion according to changing needs MFF negotiations are gearing up in the in-
across all Member States tergovernmental Council arena. Compro-
 Meaningful needs assessment – to mises among Member States and with the
base AM(I)F national programming
European Parliament are expected to be
and Partnership Agreements on struc- reached in late 2019/early 2020. Next to
tured and standalone assessment of highlighting current debate among gov-
needs and challenges ernments, the chapter stresses the im-
 Mainstreamed, longer-term policies – portance of the preparations taking place
to promote comprehensive integration already now on Member State level in
policies with a long-term orientation terms of programming and priority setting.
and mainstreaming them on Member How the national AM(I)F and ESF+ pro-
State and EU level grammes are shaping up even now, in ad-
 Broader participation – to ensure funds vance of final EU-level decisions on the
can be accessed by civil society and scope of the instruments, is crucially im-
local/ regional authorities, and that
portant for the future availability of EU
these actors are fully involved in the means for integration support and the
funds’ governance
possibilities of key actors to benefit from

4
programmes. Across all levels, govern- This recommendation to set up a new, en-
ments, the Commission, European Parlia- hanced quality monitoring mechanism
ment and integration stakeholder are not only responds to a core gap identified
called upon to act accordingly, to ensure in activities and analyses of stakeholders,
full exploitation of the new instruments’ but also builds on ReSOMA’s dialogue with
potential for integration support, comple- local level and civil society experts, policy-
mentarity in programme planning, com- makers and researchers. In a very con-
prehensive compliance with the partner- crete way ReSOMA suggests the contours
ship principle and a need-based ap- of a transnational mechanism that brings
proach to the services funded. together implementation monitoring,
qualitative evaluation, empowerment
Drawing the consequence from the lack
and capacity building of stakeholders, as
of realtime evidence on the actual up- well as EU-wide benchmarking and mu-
take of EU instruments supporting integra- tual exchange.
tion and on the practice of partnership-
led implementation, the Synthetic Report 1.2. The post-2021 agenda: MFF pro-
culminates in a proposal for a new, inde- posals of the European Commission
pendent EU-wide quality monitoring
mechanism (chapter 4.2). Led by civil so- Commission preparations for the 2021 to
ciety and local level stakeholders across 2027 Multiannual Financial Framework
the EU, the mechanism would provide for were informed by the experiences since
ongoing, regular monitoring of how the the peak of arrivals in 2015/16, a compre-
partnership principle is observed, national hensive spending review and positions
programmes are implemented, different voiced by the European Parliament, Mem-
funds are used, and of the quality of coor- ber State governments and various stake-
dination and coherence among the in- holders. (EC 2017a, 2018a, ECA 2018b, EP
struments. Quality assessment of content 2018a). The eventual Commission pro-
and effectiveness of projects funded posals for the 2021 to 2027 MFF, published
would improve the evidence base for fu- in May and June 2018 (EC 2018b-f), in-
ture AM(I)F midterm reviews and alloca- clude the following key changes relevant
tion decisions for the second tranches of for the integration of migrants and refu-
the fund. The new mechanism would thus gees:
aim to generate the necessary
 Structural Funds will continue to be
knowledge for pushing towards
spent and programmed across all, in-
 compliance with the partnership prin- cluding higher developed, EU regions;
ciple, ensuring that all Member States are
 purposeful use of AM(I)F and structural covered by ERDF- and ESF-sourced
(ESF+) funds to support integration, programmes that offer funding oppor-
 coordination and collaboration tunities for migrant integration.
among the implementing authorities,  The merging of the ESF, YEI (Youth Em-
 robust mid-term review procedures. ployment Initiative), FEAD, EaSI and
Health Programme into one fund, the

5
 ESF+, with the goal of a more compre- grammes after a mid-term re-calcula-
hensive, less fragmented overall instru- tion based on recent migration statis-
ment in the social policy area aligned tics.
with the European Pillar of Social  Explicit provisions to use the AMF The-
Rights, including higher responsiveness matic Facility (biannually programmed
to unexpected challenges. At least by the Commission) to support early in-
25% of national ESF+ would have to be tegration measures implemented by
earmarked for social inclusion and local and regional authorities or civil
fighting poverty; with at least 2% dedi- society organisations, relevant for its
cated to measures targeting the most ‘Union actions’ strand and compo-
deprived. nents regarding emergency assis-
 The European Social Fund is to be- tance, ‘solidarity and responsibility ef-
come, as ESF+, a major EU funding forts’ (related to a reformed Dublin reg-
source for medium and long-term inte- ulation) and resettlement; and coming
gration, with a newly established pro- with an increased co-financing rate of
gramme priority (‘specific objective’) 90%.
that includes the promotion of the so-  A general focus on labour market inte-
cio-economic integration of third gration, and related to that, issues of
country nationals. Member States will qualification, training and skill recogni-
have to address the objective as part tion that has already underpinned the
of the overall 25% allocation of na- 2016 Action Plan; visible e.g. in the ad-
tional ESF+ funds to the social inclusion vancement of the mainly employ-
policy area. ment-oriented ESF to a major funding
 Simultaneously, the restructuring of instrument for medium- and long-term
AMIF to an Asylum and Migration Fund integration, as well as specific AMF
(AMF), to fund early integration support to assessment of skills and qual-
measures for newly arrived third-coun- ifications acquired in a third country.
try nationals; with a reinforced partner-  Simplification of implementation and
ship principle and a financial scope of financial management rules, through a
national programmes with euro 6.25 bn Common Provisions Regulation (CPR)
more than doubled compared to the that will cover all funds under shared
2014-2020 period. management (by Member States and
 Higher flexibility in the AMF to increase the Commission, implying national pro-
its ability to react to unexpected de- grammes implemented on Member
velopments, by allocating only 50% up- State level), including AMF, ESF+, and
front to Member States and other parts ERDF;
subsequently to specific priorities as  Harmonisation across funds of the pro-
part of a Thematic Facility (proposed visions on the so-called partnership
at euro 4.17 bn, representing 40% of principle (which stipulates the partici-
overall funds), and by allocating the pation of stakeholders such as NGOs or
remaining 10% to national pro- local and regional authorities in the
programme and implementation of

6
 the instruments) through the CPR, im- newly emerging EU level policy initia-
plying a strengthening of the partner- tives. Policy challenges of Member
ship principle in the AMF and align- States identified in the European Se-
ment with the standards achieved un- mester process are to inform program-
der the Structural Funds. ming of the funds at the start and mid-
 The inclusion of reception of migrants term of the 2021 to 2027 period.
in the allocation criteria of Structural  Synergies between integration funding
Funds on the regional level (for the under ESF+ and the EU Social Open
ERDF and ESF+), contributing to a shift Method of Coordination as well as the
of funds from central European to EU Education and Training strategic
southern Member States and creating framework, to which the European So-
a long-term incentive to accept the cial Fund contributes;
sharing of responsibilities in the asylum  Increased use of conditionalities in the
field. Structural Funds (‘enabling condi-
 A stronger alignment of the ESF+ (and tions’), i.e. the existence of adequate
ERDF) with the European Semester to regulatory and policy frameworks in
support reforms and increase the Member States before funding is re-
funds’ leverage, and to better coordi- leased, to ensure that performance of
nate the programme framework with all co-financed operations is in line with
EU policy objectives.

7
 2. KEY TOPICS OF DEBATE: 12 CONTROVERSIES AROUND THE WHAT AND
THE HOW OF EU SUPPORT FOR MIGRANT INTEGRATION

Varying commitment and denial of mi- while the ESF+ budget would roughly stay
grant integration as policy priority among the same as the combined ESF and FEAD
Member States. The EU integration frame- budget in the 2014 to 2020 period (CPMR
work calls for concentrated efforts at ena- 2018b, EC 2018d, ECRE 2018a, EUROCITIES
bling and supporting the inclusion of mi- 2018b, EP 2018b, EPRS 2018). As opposed
grants and refugees in European societies. to this de-facto stagnation of available ESF
Policy principles promoted by the EU and means, AMF funds are planned to sharply
funding to support their implementation increase, but it remains to be seen what
build on the recognition that integration is the spending shares dedicated to integra-
a process of mutual adaptation of the re- tion in national programmes will be.
ceiving society and migrants; and that mi-
gration is a major factor shaping society, ESF+ as main EU integration fund: incentive
for mainstreaming in Member States or
resulting in needs for adjustment and re-
empty claim? With its cross-cutting objec-
form of general policies and policy-mak-
ing, public institutions and public services. tives, including access to employment,
In the political reality of Member States, training, education, equal access to ser-
however, this very notion is widely con- vices, social inclusion and poverty relief,
tested, and longer-term integration and the ESF represents a significant tool to po-
tentially support medium- and long-term
mainstreaming may not make it to gov-
ernment policy agendas due to constrain- integration. Another obvious advantage is
the fund’s broad definition of target
ing public attitudes, dominance of a
groups (based on Art. 162 TFEU), where all
denying political discourse or electoral
considerations. What is still at stake in persons enjoying legal access to the la-
bour market include third-county nation-
many EU Member States, is whether
broad-scale integration efforts and main- als in the same way as nationals with a mi-
streaming are necessary at all – or even, gration background or migrants from
whether they are desirable in view of per- other EU countries. Locating the topic un-
ceived pull effects. der the remit of social affairs and inclusion
policies also allows for a more compre-
In this vein, it is not a surprise that the es- hensive approach than closely linking in-
tablishment of immigrant integration as an tegration to admission and migration
EU policy goal worth of a spending priority management policies under home affairs
that would deduct available EU funds portfolios (cf. ECRE 2018a). Most im-
from other objectives is contested as well. portant, the ESF is already widely used to
As proposed by the Commission, in the support migrant integration in a number of
2021 to 2027 MFF Member States will be Member States, and on the ground often
asked to allocate part of ESF+ funding to represents the most obvious and for many
the integration of third country-nationals, actors most accessible EU funding source

8
for e.g. labour market insertion, skill valida- amounts within the social inclusion objec-
tion and training measures for migrants tives, according to the proposed provi-
and refugees (EC 2015, 2017d, Rietig sions on objectives and thematic concen-
2016). tration. The same risk regards regional gov-
ernments, as a large share of ESF opera-
However, to what extent precisely the ESF tional programmes are drafted and imple-
is used for migrant integration in the imple-
mented at regional level. In this light, the
mentation practice of Member States, is proposed mechanism to take into ac-
widely unknown (Ahad and Schmidt 2019, count Country-Specific Recommenda-
Beirens and Ahad 2019, ECA 2018a). Only tions may not have much effect on unwill-
in the upcoming programme period out- ing governments either, as long as these
put indicators on ‘third country nationals’
recommendations have to be agreed by
and ‘participants with a foreign back- the Member States (ESN 2016, 2017). Over-
ground’ (disentangled from other target
all then, the claim that ESF+ will become
groups) will be introduced according to the EU’s foremost funding source for me-
the proposed ESF+ regulation. Crucially, it dium- and long-term integration stands on
is not clear at all from the Commission pro- shaky grounds. If AMF national pro-
posal how it will be ensured that ESF+ will
grammes in practice turn out to concen-
actually support integration on a broad trate on early integration in a strict sense,
basis across all Member States: The fund’s
the threat is of a major future funding gap
general objective expressly does not refer
for medium/long-term integration in such
to migrant integration (EC 2018d, Art. 3). Member States which at the same time
Socio-economic integration of third-coun-
chose not to concentrate ESF+ resources
try nationals is being introduced as part of on migrant target groups.
the specific objective that includes other
marginalised communities (Art. 4.1.viii). Priority for early integration and availabil-
Although the Commission suggests that ity of supporting EU funding. One of the
Member States have to programme this most contested policy debates revolves
objective by taking into account third- around early integration, and at what
country nationals (Art. 7 on thematic con- point public support measures are to kick
centration), no ring-fencing of means is in. Nowhere is this debate as pronounced
foreseen for this specific objective, which as in the refugee integration area. In par-
is only part of the sub-set of social inclusion ticular cities pursue – and support in na-
objectives (Art. 4.1.vii to xi) for which at tional and EU policy debates – 'integration
least 25% of national allocations will have from day one', striving for the provision of
to be dedicated. language support, education, recognition
of skills, labour market insertion and, gen-
At any case, it can be assumed that Mem- erally, interaction with the receiving soci-
ber States willing to tap the ESF+ for inte- ety as quickly as possible after arrival. As
gration purposes would do so anyway, in
an early intervention approach, such poli-
line with current practice. Member States cies aim to avoid the demotivation and
not wishing to use ESF+ means for migrant deprivation seen by people who are left in
target groups, on the other hand, could a social and legal limbo, possibly for years,
get away with dedicating only token
9
after arrival, including long delays before a broad range of essential early integra-
the accession to rigths to labour market. tion measures that are effective starting
They accept higher costs in the short term points for long-term integration (EC
for preventive measures which invest in 2018e).
the ability of migrants to adapt and inte-
grate quickly, rather than postpone costs EU-funded support for the social inclusion
of the undocumented. The EU has ex-
to later, reactive interventions to deal with
the results of ‘failed’ integration. tremely limited funding instruments openly
available to support the inclusion of un-
This policy mindset, however, conflicts with documented migrants. Only FEAD—the
the policy approach stressed by many na- Fund for European Aid to the Most De-
tional governments, suspicious of early in- prived—in principle allowed co-funding
tegration as creating additional pull ef- for measures supporting the undocu-
fects, and which in the asylum field draws mented. Comparatively small in scale,
a clear line between a pre-integration re- FEAD is designed to help people take first
ception phase (however long procedures steps out of poverty and social exclusion
last) and the provision of integration sup- by addressing their most basic needs. Im-
port only to recognised beneficiaries of in- plemented through national programmes,
ternational protection. For the sake of Member States can provide material assis-
speedier procedures, administrative effi- tance in the context of social inclusion
ciency and lower costs – and often better measures or non-material assistance to
control of asylum seekers' movements, help people integrate better into society.
control of civil-society based (legal) sup- However, Member States have wide dis-
port for asylum seekers, and deterrence cretion in their national programmes, in
effects – this alternative policy approach terms of priorities, the definition of target
typically aims for centralised accommo- groups and actual funding decisions, such
dation in large reception centres. Widely as whether or not to include the undocu-
shared criticism point to resulting rudimen- mented. Migrants in an irregular situation
tary education and language support, iso- were not explicitly mentioned in any of the
lation from the receiving society, higher Member States Operational Programmes
crime rates, contempt for human dignity, and related performance indicators. No
stigmatisation of asylum seekers, demoti- clear overview exists of the actual uptake
vation and delayed start of integration of FEAD in terms of undocumented mi-
processes. grants. Other EU funding programmes ex-
clude irregular migrants in their eligibility
The conflict between these contrary pol- rules. The ESF as a matter of principle tar-
icy approaches and visions for the recep- gets persons with legal labour market ac-
tion phase are played out on EU level as cess, thus excluding persons without the
well, not least in the debates on integra- right to work (EC 2015). People not holding
tion-related support from EU funds. A stick-
a regular residence status are very rarely
ing point is the precise definition, scope included in programmes, and only in cer-
and overall framing of ‘early integration’, tain Member States. The same holds true
as funded from AMF in particular, and the for the other major EU financial instruments
availability of EU instruments which support
10
on social inclusion, such as the Youth Em- Capacity of EU instruments to support and
ployment Initiative (YEI) and the Employ- encourage policy innovation. During and
ment and Social Innovation fund (EaSI). In in the wake of the 2015/16 arrivals, the lo-
practice, national reporting and auditing cal level has become a testing ground for
requirements on listing final recipients of- new, innovative approaches and policies
ten decide on whether e.g. ESF actions related to immigrant integration. A large
aimed at access to services or provision of share of this innovation has been civil-soci-
information may benefit persons without ety driven, resulting from the wave of vol-
regular residence status. AMIF’s focus on untarism seen during this time, or emerged
integration only includes third country na- from social entrepreneurship. This innova-
tionals with regular residence. tion has led to new solutions to providing
integrated support services, e.g. with re-
Strict eligibility rules excluding the undocu- gard to language learning, social mentor-
mented have led to complaints from or-
ship, training and labour market insertion.
ganisations and projects working on social (EUROCITIES 2016, 2017b,d, EWSI 2016, FRA
inclusion, as their target groups often in- 2018, Jeffrey 2018, OECD 2018). EU funding
clude persons with diverse, often fluid, res- instruments and Commission engagement
idence status. The EU social NGOs have
have played a certain role in these new
therefore stressed in a joint statement that types of local integration initiatives, e.g.
the requirement in EU funding to report im-
through integration-specific calls under
migration status “represents not only an
the Urban Innovation Action (UIA) instru-
additional burden on civil society, but also ment and measures included in the 2016
compromises the establishment of a trust-
EU Action Plan on the integration of third
ful relation between service providers and country nationals (EC 2016).
users, justifies the division of families and
leads to many errors” (Social Platform Nevertheless, the capacity of EU instru-
2018a:11). The merger of FEAD into ESF+, ments to foster community involvement
as proposed by the Commission, on the and local innovation is widely questioned.
one hand could theoretically allow the For small-scale projects carried by civil so-
access of these to social services (as basic ciety organisations or voluntary initiatives,
health assistance), but on the other hand EU funds are difficult to access or outright
further threatens to increase the obstacles unattractive due to financial requirements
for social inclusion of the undocumented and complex programme rules. Commu-
(EC 2018d). While the hitherto definition of nity building efforts, early integration initia-
most deprived target groups within na- tives or school-related activities have nu-
tional programmes is kept in the proposal, merous EU options (from AMIF to Erasmus+,
a key point of debate is whether the cur- Europe for Citizens, as well as the Rights,
rent ‘low threshold’ approach to FEAD will Equality and Citizenship programmes), but
be upheld, or whether the potential use of in reality often fail to access funds (ECRE &
EU co-funding for inclusion measures to UNHCR 2017 and 2019, EUROCITIES 2016,
the benefit of undocumented will be- 2017 b,c, Urban Agenda 2018a, Social
come further reduced (Social Platform Platform 2018a). A key question thus has
2018a). been how in future more civil society-

11
driven projects enabled by EU funds can integration debates, such controversy re-
take place, with lower thresholds for small- verberates, too. Member States political
scale projects and funding instruments discourse often concentrates on the bal-
geared towards non-public/non-profit ance between providing access to wel-
project carriers. fare provisions (like social assistance/in-
come support) and a ‘demanding’ ap-
Comprehensive social policies versus
proach that sees the integration effort and
competitiveness paradigm. A long-stand- responsibility for labour market success or
ing controversy around the intervention language acquisition primarily on the side
logic of EU instruments in the social policy of the migrant. Policy preferences of na-
domain – and one that will gain im- tional governments in such debates are
portance as the ESF is poised to become
relevant in the European context, as gov-
a major funding source for migrant inte- ernments will first decide on the future ESF+
gration – refers to the underlying cohesion
instrument, its priorities and underlying in-
philosophy. Ever since the EU adopted tervention logic, and then set their priori-
overall economic and social develop- ties in national implementation pro-
ment strategies focused on improved grammes.
competitiveness and the knowledge
economy, EU programmes have been EU policies to support, not constrain, urban
geared towards an empowering and en- level social investments and integration
abling approach, helping individuals to efforts. In its most critical variant, debate
participate in the labour market. Typical on the EU’s role in facilitating migrant inte-
policy goals have been human capital gration and the provision of adequate
development, vocational training and life- public services on the local level has fo-
long learning. Critics of this approach cused on the constraints emanating from
have been pointing out that a focus on la- various EU policies. In countries most af-
bour market activation alone is not suffi- fected by the financial and sovereign
cient to tackle complex cohesion chal- debt crisis over the last decade, EU-
lenges, including material deprivation, agreed austerity policies have led to con-
poverty, precarious and atypical employ- siderable spending cuts, decline in social
ment, lack of affordable housing and dis- investments and limitated capacities to
crimination. Cities and their interest organ- address social cohesion issues including
isations have mostly shared this critique, migrant integration, while at the same
e.g. pointing out that it is cities where such time problems and needs multiplied. EU
problems arise first and are felt hardest. economic crisis responses and their local
impact aside, social housing represents
A concern stressed by many stakeholders another long-standing policy controversy
is that if the future ESF+ does not over- between cities and the EU with implica-
come the binary focus on employ- tions for migrant integration. Pointing to
ment/unemployment, it will be of limited
the role of public housing for combatting
use as an integration support instrument spatial segregation on local level and so-
(EAPN 2016, ESN 2017, EUROCITIES 2014, cially mixed neighbourhoods, local level
2018a, Social Platform 2018a). In national stakeholders have consistently pushed for

12
the availability of Structural Funds for hous- excluded from AMIF funds as a conse-
ing stock refurbishment and social infra- quence. Local authorities therefore have
structures, and generally for considering been asking to become directly eligible
social housing as a service of general eco- for Emergency Assistance and/or auto-
nomic interest (SGEI) with limited applica- matically receive a certain share of avail-
bility of EU competition and state aid rules. able funding for integration based on ob-
jective criteria (ECRE & UNHCR 2017 and
Against this history of cities’ discontent with 2019, EUROCITIES 2015, 2016, 2017 b,c, HLG
certain EU policies, it is not surprising to see 2017, Urban Agenda 2018, Social Platform
urban representatives call for a general 2018a).
turn of EU economic strategy to more pub-
lic spending and investment-based poli- In the case of ESF, the current programme
cies; and in particular ample possibilities to period has seen improvements insofar as
support social investments under the EU Member States were encouraged to use
funding instruments in the 2021 to 2017 MFF the EU Structural Funds for so-called ‘inte-
(Fransen et al. 2018, Jeffrey 2018). Being grated actions for sustainable urban de-
able to leverage EU co-funding for new velopment’, leading to an estimated third
schools, childcare services, vocational of the new urban strategies to include ESF
and skills centres, and enlargement or re- funding. This and the requirement to use
furbishment of public housing stock is seen part of the national ERDF allocation for
by many cities as inherently linked to their these integrated actions led to more fre-
capacity to address challenges of migrant quent direct responsibility of cities in the
integration. management of ESF funds. Notwithstand-
ing these developments, cities continue to
Ability to set policy priorities on urban level point out that Operational Programmes
and direct access to EU funds. Cities fre- and calls leave key local challenges not
quently strive for a regulatory and funding addressed, that target groups and indica-
environment that allows for autonomous tors do not match the local reality, and
policy responses in line with their responsi-
that coordination gaps exist at the
bilities vis-à-vis migrant populations. In the ESF/ERDF nexus (EUROCITIES 2018a, HLG
EU programme context, distinct local pri- 2017, Urban Agenda 2018, Social Platform
orities lead to the call for direct access to 2018a).
EU funds, as cities usually access EU funds
through Member State authorities. In the Stronger role for civil society and local au-
case of AMIF, in the 2014 to 2020 period thorities in the governance of EU funds im-
cities in many Member States have not plementation. A focal point of stakeholder
been able to act as co-beneficiaries from efforts at stronger involvement in plan-
AMIF emergency support, and national ning/implementing EU programmes is the
AMIF funds may not be readily available so-called partnership principle. With a
to meet the needs of local stakeholders long-standing tradition in the Structural
due to the National Programmes’ specific Funds programmes it refers to the close in-
priorities and calls. In some Member volvement of civil society, local govern-
States, cities have reported to be widely ments and other relevant actors in the
preparation, implementation, monitoring
13
and evaluation of Partnership Agreements Conduct (EC 2018c). Welcomed by stake-
and Operational Programmes. A ‘Euro- holders, this was bound to be controversial
pean Code of Conduct on the Partnership with governments that have preferred to
Principle (ECCP)’, adopted as EU Dele- keep civil society and other stakeholders
gated Act in 2014, has further strength- at arm lengths' when implementing na-
ened the principle by clearly defining the tional AMIF programmes. Stakeholder also
objectives and criteria Member States pointed out inconsistencies in terminology
have to observe (EC 2014), although it its between the ECCP and the new pro-
implementation is not binding. posals (e.g. concerning the role of Moni-
toring Committees in programme report-
Notwithstanding this improvement, in ing and reviews), and in how the ECCP re-
practice only a handful of countries have
fers to the specific funds and programmes
fully involved local and regional authori- to which it applies (ECRE & UNHCR 2018b).
ties and civil society organisations in the
process in all stages. Under the AMIF, the Coherent, simplified and flexible EU instru-
partnership principle is even less estab- ments in line with local needs. Drawing
lished. Reflecting the intergovernmental from different EU funding sources for the in-
roots of EU policies in the migration policy tegration of migrants and refugees (AMIF,
domain, the principle has never been ESF, FEAD, ERDF, EaSI, Erasmus+, REC), lo-
more than a recommendation to Member cal authorities, civil society stakeholders
States and cities and civil society stake- and potential beneficiaries in cities are
holders report ignorance for their con- faced with overlapping priorities, target
cerns in AMIF national programming in a groups and policy objectives. Partly this is
number of countries (CEMR 2015, CPMR a result of lacking adjustment among EU
2018a,b, ECRE & UNHCR 2017 and 2019, instruments, partly it is a mirror of unaligned
EPRS 2017, ESF Transnational Plat- priorities at local, regional or national lev-
form/AEIDL 2018b, Fondazione Brodolini et els as the programmes are implemented
al. 2016, Social Platform 2016, Sweco et al. within Member States. In particular actors
2016, Urban Agenda 2018). with limited administrative resources strug-
gle to navigate EU funding processes with-
As proposed by the Commission, in the out guidance on how to best leverage re-
2021 to 2027 programme period the AMF sources and which funds to apply for.
will become part of the newly harmonised
rulebook across all funds under shared Technical differences in deadlines and el-
management funds, implying a strength- igibility, reporting and financial accounta-
ening of the partnership principle and bility rules across the different EU funds can
alignment with the standards achieved create major obstacles and render EU
under the Structural Funds. Requirements funds unattractive. The divergent defini-
in the proposed future Common Provisions tion of target groups in various pro-
Regulation (CPR), equally referring to grammes leads to especially grave prob-
ERDF, ESF+ and AMF include a binding pro- lems when colliding with realities. For ex-
vision to carry out partnership organisation ample, AMIF interventions can only focus
in accordance with the 2014 Code of on third-country nationals, whereas under
ESF in principle a much wider population
14
of citizens with migration background (in- provision lacks a direct link with the fulfill-
cluding newly arrived EU citizens or sec- ment of the integration-related objective
ond-generation nationals) are able to viii of ESF+. In other words, increase in allo-
benefit. However, the definition of the ESF cation to the regions which have wel-
target group has been very diversified comed a higher number of third country
across Member States, creating confusion nationals, will not grant per se more invest-
and difficulties in comparing the quality of ments in integration. For cities in the poten-
measures provided and the number of re- tially negatively affected countries, fre-
cipients served. Moreover, programmes to quently committed to a more inclusive ap-
foster inclusion and social cohesion typi- proach to integration than their national
cally include the receiving community, governments, these proposed condition-
meaning that eligibility rules need to ac- alities are a double-edged sword: While
commodate all citizens (Ahad and underlining their political stance of more
Schmidt 2019, EC 2015, 2018e, ECA 2018b). openness, eventually less cohesion fund-
Stakeholders have therefore consistently ing would be available on local level. Mu-
called for simplification, less administrative nicipalities, together with civil society
burden, better harmonisation of rules, flex- stakeholders, feel threatened to be taken
ibility and possibilities to blend funding hostage by the anti-immigration stance of
from different funds (EUROCITIES 2017b,c, their governments and to lose out in ur-
Urban Agenda 2018). gently needed investments that depend
on EU co-funding.
Reception of migrants, an indicator on
which to lose or to gain from EU Structural In view of these potential effects, the
Funds? The envisaged broadening of re- Commission proposals are also far away
gional allocation criteria of Structural from the idea of a new EU instrument of-
Funds (incl. ERDF and ESF+) to include, fering direct financial support to cities in
next to regional per-capita GDP, the re- return for receiving refugees and asylum
ception of migrants has proven to be seekers, floated among others by the Eu-
highly controversial. To better reflect ropean Parliament in early 2018 (EP 2018a,
needs and challenges on regional level, Knaus & Schwan 2018, Bendel et al. 2019).
the Commission proposes to take into ac- Under such an incentive scheme, possibly
count net migration from outside the EU linked to resettlement programmes, mu-
since 2013 as one in a set of additional in- nicipalities would apply directly to receive
dicators when calculating available means for the integration of refugees
amounts in the 2021 to 2027 MFF (EC whom they wish to welcome.
2018c, Annex XXII). This would entail a re-
channelling of funds among Member Contested necessity of more binding Euro-
States and create an incentive (of sorts) in pean governance in integration field. An
the long term to accept and accommo- overriding question with regard to the EU’s
role in the integration field is whether EU
date more immigration, but also provide
resources to better include those who policies can, or should, go beyond the ex-
have accepted to accommodate more isting ‘soft’ governance aimed at inspiring,
asylum seekers in the past. However, this enabling and facilitating mainstreaming in
Member States, and move towards a
15
more binding framework. As proposed by among Member States in terms of their ca-
the Commission, mainstreaming of inte- pacity and commitment to integrate mi-
gration in the 2021 to 2027 MFF would be- grants and refugees, and to respond with
come more strongly entwined with overall efficient policies. With stronger incentives,
EU economic and social governance, i.e. conditionalities related to migration and
the European Semester and national re- integration in funding programmes and
form programme process. More flexible under peer pressure, the hope is that also
and cyclical governance of the more reluctant governments would de-
ESF+would be part of this shift, providing a velop and implement comprehensive,
new EU lever to influence Member State broad-based integration policies. How-
policy priorities. Annual Country-Specific ever, given the contested nature of the
Recommendations (CSRs) in the European policy objectives underlying the EU’s sys-
Semester cycle (increasingly also referring tem of social and economic governance,
to migrant integration) are proposed to be political attitudes among some Member
taken into account at least at the begin- State governments, as well as the legal
ning of the programming period and for constraints of the EU mandate in the inte-
the mid-term review (assessing progress gration policy field, any plans for a more
after five years; EC 2018d). binding EU governance framework for in-
tegration are set to be contested.
The main rationale for such a more bind-
ing frame, from a Commission perspec-
tive, is to level out the existing differences

16
 3. FROM DEBATE TO PROPOSALS: POLICY OPTIONS PROMOTED BY
STAKEHOLDERS AND THE EUROPEAN PARLIAMENT

3.1 Policy option adequate funding – to management and -control. Proposals are
ensure sufficient and flexible spending also driven by growing reluctance in some
on integration according to changing Member States to create favourable con-
needs across all Member States ditions for migrants and refugees in gen-
eral, and the varying propensity of Mem-
Advancing this policy option is informed ber States to let migrants and refugees
by lacking, or patchy, public spending on benefit from various EU programmes
migrant and refugee integration seen in (structural funds, education programmes
many Member States. Across Europe, the etc.). Pushing for adequate levels of EU in-
attention given to integration policies var- tegration funding is therefore not only
ies dramatically. Comparably high levels about maintaining and expanding what is
of financial support provided in wealthier available from EU programmes, but also
and/or long-standing destination coun- about making sure, through programme
tries contrast with much lower levels in rules, that Member States eventually take
more recent destination countries or up the potentially available means.
Member States where public finances
Stakeholder proposals
have been under strain. In most countries,
however, policy gaps related to specific Specific stakeholder proposals put for-
and sectoral challenges exist, together ward as reaction to the Commission pro-
with a lack of national spending in such ar- posals and relevant for this policy option
eas. In this overall context, EU funds repre- include:
sent a key mechanism to instigate and lev-
erage higher spending on migrant and  At least 30% of national AMF pro-
refugee integration according to actual grammes under shared management
needs. In addition, they provide an oppor- to be allocated to, and actually
tunity to strengthen the principle of early spend, on integration and legal migra-
integration ‘from day one’, in line with the tion actions;
EU policy approach.  allocation of AMF funds to Member
States solely based on numbers of
Proposals put forward by stakeholder or- third-country nationals who arrived
ganisations start from the fact that tradi- (and not on returns), to match the
tionally EU funding dedicated to integra- needs in the asylum and integration ar-
tion has been comparatively low (i.e. eas;
mostly under AMIF in the current pro-  50% of the AMF to be managed by the
gramme period). In addition, there is a European Commission under the The-
sense that existing spending levels need to matic Facility, to increase the Commis-
be defended and reinforced in view of re- sion’s possibilities to address integration
cent EU priorities focused on migration needs in Member States;
17
 the possibility to reabsorb AMF funds proposals cf. chapter 2.1.3 of the same
and spend them under the Thematic Policy Options Brief
Facility in case a Member State under-
Support in the European Parliament
spends the funding allocated to its na-
tional programme; In the European Parliament, as co-legisla-
 explicit inclusion in the scope of AMF of tor of the future EU funds in the 2021 to
the early identification of victims of vi- 2027 MFF, a wide range of stakeholder po-
olence and torture, and support to sitions have been taken up in the ongoing
specialized civil society organisations negotiations. The legislative resolution on
through the Thematic Facility; the AMF regulation resulting from the ple-
 publication of the annual AMF perfor- nary vote of 13 March 2019, based on the
mance reports as well as mid-term report of the Civil Liberties, Justice and
evaluations, to increase the transpar- Home Affairs (LIBE) Committee, addresses
ency on how funds are used and facil- most of the above-mentioned concerns
itate monitoring; and will be the Parliament’s starting point
 at least 30% of national ESF+ pro- in the upcoming negotiations with Council
grammes under shared management and Commission. Notably, it proposes to
to be spent on social inclusion and re- amend the integration objective of the
ducing poverty, including for integra- fund, deleting the focus on early integra-
tion of third-country nationals; tion foreseen by the Commission, and stip-
 socio-economic integration of third- ulates to maintain the fund’s hitherto
country nationals as a distinct specific name, ‘Asylum, Migration and Integration
objective of ESF+, to ensure attention Fund (AMIF)’ (EP 2018 e,f, 2019a). With a
to the target group; view to proposals put forward by stake-
 at least 4% of national ESF+ pro- holders, Parliament has settled on:
grammes to be spend on the two spe-
cific objectives addressing social inclu-  A minimum allocation of 10% of funds
sion of the most deprived and material to integration and legal migration
deprivation; each in national AMF programmes
 European Social Charter and Sustaina- (however not including a requirement
ble Development Goals as additional on actual minimum spending); to-
references for ESF+, to ensure its scope gether with a minimum allocation un-
includes asylum seekers and persons der the Thematic Facility of 10% each
with an irregular status. to integration and legal migration
spending;
 for details on the various stakeholder  deletion of provision that 40% of na-
positions cf. chapter 3.1 (Annex) of the tional AMF means are to be allocated
Policy Options Brief on ‘High levels of EU to Member States according to criteria
support for migrant integration, imple- related countering irregular migration
mented by civil society and local au- including returns;
thorities’  strengthened provisions concerning
 for in-depth information on the evi- vulnerable groups, through adding
dence base supporting stakeholder protection measures for vulnerable
18
 persons to the measures implemented on ‘High levels of EU support for mi-
through the fund; and adding to the grant integration, implemented by civil
scope of AMF support the early identi- society and local authorities’
fication of vulnerable persons as well
as the provision of psycho-social and
rehabilitation services; 3.2 Meaningful needs assessment – to
 increased transparency on how funds base AM(I)F national programming
are used and facilitated monitoring of and Partnership Agreements on struc-
programme implementation through tured and standalone assessment of
publication of actions, beneficiaries needs and challenges
and annual performance reports and
detailed provisions on mid-term and Advancing this policy option is informed
retrospective evaluation reports. by the frequent under-use of AMIF for inte-
gration purposes, neglecting needs in
Concerning the ESF+ regulation, the Member States and overtly focusing on
amendments adopted by the European migration management. It aims to forego
Parliament on 16 January 2019, based on flawed needs assessments at the begin-
the report of the Employment and Social ning of the programming phase that fail to
Affairs Committee, embodies Parliament’s capture the full range of needed support
eventual stances on the proposals put for- action in the process of formulating Part-
ward by stakeholders (EP 2018c,d, 2019b): nership Agreements (PAs) and national
programmes. Pursuing this option seems
 At least 27% of national ESF+ pro-
even more urgent, as previous standards
grammes under shared management
in priority-setting for asylum and migration
to be spent on social inclusion and re-
funds are questioned under the future
ducing poverty, including for integra-
AM(I)F. As proposed by the Commission
tion of third-country nationals;
(and not fundamentally amended by the
 socio-economic integration of third-
European Parliament), provisions on needs
country nationals to become a sepa-
assessement are not very detailed and
rate specific objective of ESF+ in the so-
would give considerable leeway to Mem-
cial inclusion policy area;
ber States in deciding their spending prior-
 at least 3% of national ESF+ pro-
ities.
grammes to be spend on the two spe-
cific objectives addressing social inclu- Alternative proposals put forward by
sion of the most deprived and/or ma- stakeholder organisations react to these
terial deprivation; setbacks for evidence-based policymak-
 sustainable Development Goals as ad- ing (ECRE & UNHCR 2018a: 51-56). While
ditional reference for ESF+, to ensure its the current AMIF has foreseen a formal,
scope includes asylum seekers and high-level Policy Dialogue between Mem-
persons with an irregular status. ber States and the Commission to establish
strategic priorities for national program-
 for details on the EP amendments to ming, the AMF proposal makes no refer-
the Commission proposals cf. chapter ence to such a process. Instead, the pro-
3.1 (Annex) of the Policy Options Brief posed regulation tasks Member States
19
with preparing Partnership Agreements, to the Commission proposals and relevant for
be approved by the Commission. Without this policy option include:
a formal Policy Dialogue process also the
 Standalone assessment of needs and
current levels of transparency (e.g. the
challenges relevant to implementation
Commission duty to present the outcome
of Policy Dialogues to the European Parlia- of shared management funds (follow-
ing an amended Partnership Agree-
ment) will decrease. With regard to the
PAs, there is no requirement foreseen ask- ment template) as a basis for program-
ing for a standalone assessment of needs ming, in the form of a baseline situation
and challenges that would serve as justifi- including statistical and qualitative
cation for particular policy objectives in data from independent sources;
 Commission approval of PAs and Na-
these basic documents of national pro-
grammes. In contrast, the 2014 to 2020 tional Programmes based on an as-
sessment of how far selected priorities
AMIF requires programming to be based
on an assessment of needs present in and objectives address the needs and
Member States at a particular date, challenges identified in the needs as-
where possible supported by statistical sessment;
 Scrutiny of EU agency programming in-
data. With regard to the national pro-
grammes, no guidance on assessment of puts by national Monitoring Commit-
tees, and a process by which agency
challenges is foreseen either on which to
input can be challenged if thought to
base national programming; leaving
Member States with a lack of clarity on the extend beyond their areas of compe-
tence;
overall approach to be used. In addition,
the templates for PAs and national pro-  Reinstatment of the formal, high-level
Policy Dialogue process previously
grammes do not require Member States to
draw on specific types of data or evi- seen under AMIF for the future AM(I)F,
dence to justify policy choices. Stakehold- together with a strengthening of the
scrutiny role of the European Parlia-
ers point out the danger that politically
ment.
motivated priority-setting takes prece-
dence in this context. Last not least, the Support in the European Parliament
AM(I)F proposal newly introduces an asso-
ciation of EU agencies (EASO/EUAA and In the ongoing legislative process struc-
Frontex/EBCG) to the process of national tured needs assessment in programming
programme development, but without has not featured prominently in the
any requirement of their input and subse- amendments put forward by MEPs and in
quent programme amendments to be positions of the European Parliament.
made public or open to the scrutiny of na- Amendments to the Common Provisions
tional Monitoring Committees. Regulation, adopted by the European
Parliament in February 2019 (EP 2019c)
Stakeholder proposals with regard to preparation, content and
Specific stakeholder proposals (ECRE & approval of PAs and national pro-
UNHCR 2018b) put forward as reaction to grammes (Art. 7 to 9 and 16 to 18) con-
cerned mainly the partnership principle
20
(c.f 3.4 below) and time limits. Vaguely, on social inclusion goals in overall EU eco-
the EP added an “integrated approach to nomic and social governance, and how
address the demographic challenges these goals translate into specific objec-
and/ or specific needs of regions and ar- tives of EU programmes conceived to fa-
eas” as element of PAs and to be set out cilitate integration.
in national programmes (EP 2019c). Con-
Proposals put forward by stakeholder or-
cerning the AM(I)F, MEPs’ efforts at
amending the Commission proposal with ganisations address the fact that EU inte-
regard to programming (Art. 13 AMF regu- gration funding up to now focuses on short
lation) mostly focused on adding the EU term needs related to the arrival and re-
Agency for Fundamental Rights to the EU ception context in many Member States,
with comparatively little funding used for
agencies that are to be associated at an
early stage to the development of pro- e.g. long-term labour market integration.
grammes (EP 2018 e,f, 2019a). Moreover, governments have wide discre-
tion on whether EU funds implemented on
3.3 Policy option mainstreamed, national level become available for
longer-term policies – to promote longer-term integration measures or would
comprehensive integration policies in any way contribute to mainstreaming of
with a long-term orientation and main- migrant integration across policies. As a
result, measures that receive EU support
streaming them on Member State and
often are peacemeal, poorly integrated
EU level
into coherent, longer-term strategies and
Advancing this policy option is informed not linked to an all-of-government and all-
by the overtly short-term character of inte- of-society response to immigration. What is
gration policies and the weak considera- more, policies aimed at longer-term and
tion of integration objectives across rele- more comprehensive integration are un-
vant policy areas in many Member States. der threat where governments perceive
EU funding programmes have the poten- them as creating pull factors or being un-
tial to improve the quality of integration popular with the own citizens.
policies in terms of their long-term orienta-
Stakeholder proposals
tion and of mainstreaming them into all ar-
eas which impact on the integration out- Specific stakeholder proposals put for-
look and well-being of migrants and refu- ward as reaction to the Commission pro-
gees – such as housing, employment, ed- posals and relevant for this policy option
ucation and health. On Member State include:
level, the policy option stresses EU support
for ongoing, seamless and well-integrated  A proper balance among social and
measures aimed at enabling the inclusion macroeconomic objectives in the Eu-
of migrants and refugees in all walks of life, ropean Semester process, to ensure
with no funding gaps emerging along the adequate investment for social inclu-
integration pathway. On EU level, the pol- sion and poverty reduction;
icy option relates to a stronger emphasis

21
 more regular monitoring through the Support in the European Parliament
social aspects of the European Semes-
ter of how Member States implement In the European Parliament a number of
the concerns brought forward by stake-
enabling conditions, including the ap-
holder organisations have been taken up.
plication of the EU Charter of Funda-
mental Rights; With regard to the ESF+ regulation,
amendments adopted by Parliament in
 mainstreaming of integration support
across the ESF+, with third country na- the plenary vote on 16 January 2019
tionals as recipients of measures under (based on the Report of the Employment
all the specific objectives and an en- and Social Affairs Committee) reflect Par-
hanced equality clause; liament’s eventual positions on the legisla-
tive proposals tabled by the Commission
 strong coordination on EU level and
between Managing Authorities in (EP 2018 c,d, 2019b). With a view to the
stakeholder proposals, these amend-
Member States of the actions and pri-
ments refer to:
orities implemented under AMF, ESF+
and ERDF shared management, to the  The inclusion of challenges identified in
point of establishing cross-Fund na- the Social Scoreboard under the Euro-
tional integration Monitoring Commit- pean Semester in the provisions on the-
tees; matic concentration of national ESF+
 priorities of the European Action Plan spending;
on the integration of third country na-  additional general objectives of the
tionals to be addressed in national op- ESF+ stressing inclusive societies, the
erational programmes for ESF+ imple- quality of employment, education and
mentation; training, integration and social cohe-
 ongoing, effective support for early sion, eradication of poverty, non-dis-
and long-term integration and forego- crimination and access to basic ser-
ing of possible funding gaps due to the vices, among others;
way Member States implement AMF  additional specific objectives of the
and ESF+. ESF+, among others related to the in-
clusiveness of education and training
 for details on the various stakeholder systems, services for access to housing,
positions cf. chapter 3 (Annex) of the and access to equal social protection,
Policy Options Brief on ‘Comprehen- including for disadvantaged groups
sive and mainstreamed, longer-term and the most deprived people;
support for the integration of migrants’  highlighting of integration challenges
 for in-depth information on the evi- as the context in which the ESF+ will be
dence base supporting stakeholder implemented, and acquisition of lan-
proposals cf. chapter 2.3 of the same guage skills, reduction of segregation
Policy Options Brief and non-discriminatory education sys-
tems, among others, as goals of the
fund;
 compulsory inclusion of Managing Au-
thorities in coordination mechanisms
22
 with other EU funds, in order to deliver  arrangements for implementation of
integrated approaches; with specific the European Pillar of Social Rights as
reference to coordination of ESF+ with horizontal enabling condition, applica-
the AMF but also ERDF and the Rights ble to all specific ESF+ objectives;
and Values programme;  provision that enabling conditions are
 inclusion of the EU Action Plan on the also seen as prerequisite for inclusive
integration of third country nationals in and non-discriminatory (and not only
the Union initiatives whose implemen- effective and efficient) use of EU sup-
tation is to be supported from ESF+; port;
 a seperate specific objective of ESF+  access to non-segregated education
solely dedicated to the promotion of and training as part of the national
long-term socio-economic integration strategic policy framework for the edu-
of third country nationals, including mi- cation and training system which is re-
grants; quired as thematic enabling condition;
 clarification of the scope of integration  a concrete action plan to combat
measures supported from ESF+ as fo- segregation through access to quality
cusing on legally residing third-country services for migrants and refugees as
nationals or on those in the process of part of the ‘national strategic policy
acquiring legal residence, including framework for social inclusion and pov-
beneficiaries of international protec- erty reduction’ which is required as
tion. thematic enabling condition.

Amendments to the Common Provisions Amendments to the AMF regulation in the

Regulation, adopted by the European EP legislative resolution of 13 March 2019,
Parliament on 13 February 2019 based on based on the report of the Civil Liberties,
the report of the Committee on Regional Justice and Home Affairs (LIBE) Commit-
Development (EP 2019c), refer to: tee, further address some of the above-
mentioned stakeholder concerns (EP
 Inclusion of the overall policy objec- 2018e,f, 2019a):
tives of the Structural Funds (including
implementation of the European Pillar  Stress on the complementarity, coordi-
of Social Rights) in the needs assess- nation and coherence among AMF
ment leading to Partnership Agree- and the Structural Funds when imple-
ments between Commission and menting the specific objective related
Member States, thus going beyond to integration and social inclusion of
Country-Specific Recommendations; third-country nationals, as well as in the
 progress in support of the European Pil- annual performance reports of Mem-
lar of Social Rights, territorial needs and ber States;
demographic challenges to be taken  scope of AM(I)F defined as supporting
into account in reporting of Structural integration measures for third-country
Funds’ implementation, mid-term re- nationals and actions supporting
views and adjustments following mid- Member States’ capacities in the field
term reviews; of integration that are generally imple-

23
 mented in the early stages of integra- lasting integration strategies on local level,
tion, complemented by interventions pursued by public bodies and NGOs. Cit-
to promote the social and economic ies, regions and civil society thus are key
inclusion of third-country nationals fi- stakeholders and potential beneficiaries
nanced under the structural funds. of EU funding instruments for the integra-
tion of migrants and refugees.
 for details on the EP amendments to
the Commission proposals cf. chapter Proposals put forward by stakeholder or-
3 (Annex) of the Policy Options Brief on ganisations respond to a reality that by far
‘Comprehensive and mainstreamed, does not live up to the actual role of civil
longer-term support for the integration society and local/regional authorities in
migrant integration. While NGOs are
of migrants’
widely recognised as main beneficiaries of
EU funding in the integration area, their
3.4 Policy option broader participation participation in EU programmes is often
– to ensure funds can be accessed by hampered by specific funding rules devel-
civil society and local/ regional author- oped by Member States for programmes
ities, and that these actors are fully in- implemented on national level (under
‘shared management’). Other barriers to
volved in the funds’ governance
participation relate to EU rules, including
Advancing this policy option is informed on co-financing and administrative bur-
by the ambition of local actors, both pub- dens that are problematic especially for
lic and societal, to autonomously pursue smaller organisations. In what concerns
integration priorities in line with the needs municipalities, they have been grossly un-
on the ground. The local level is where suc- derrepresented as beneficiaries of recent
cess or failure of integration processes is EU integration funding in spite of their de-
determined, with key public services such cisive role in handling the 2015/16 peak in
as housing and early childhood educa- arrivals. Moreover, they have experienced
tion, but also policies to combat poverty serious obstacles in accessing EU funds re-
or social exclusion widely in the hand of sulting from national implementation
municipalities. Civil society, local and re- structures and -decisions. In the govern-
gional authorities are uniquely placed to ance of the relevant programmes, the
offer early integration support, pursue voice of local and regional authorities,
community building among newcomers civil society and social partners is un-
and citizens, and shape the social climate derrepresented or even absent, leading
in which reception and integration take to little involvement of these actors in pro-
place. However, local integration actors gramme planning, implementation and
often do not have enough leeway to fully monitoring.
exploit their potential due to various con-
What is more, the payment of technical
straints that often are related to lack of
assistance resources to Member States
funding. EU programmes, their funds as
can be critical for the capacity of organi-
much as their concepts and objectives,
sations and entities to access national pro-
can be crucial to galvanize effective and

24
gramme resources and/or effectively im- national resources and a recommen-
plement actions for which they have al- dation to provide 100% grant funding
ready received funding. As proposed by wherever possible;
the Commission, common rules for the  the extension of the proposed 90% co-
shared management Funds will introduce financing rate for integration actions
a flat rate mechanism for the payment of led by civil society and local/regional
technical assistance resources to Member authorities across all AMF objectives;
States, in which these funds are paid in the  removal of the flat rate mechanism for
form of a 2.5-6% top up of each interim the payment of technical assistance
payment. The payment of technical assis- and of the link between implementa-
tance is thus linked to progress in imple- tion progress and payment of tech-
mentation, with Member States imple- nical assistance; instead payments to
menting programmes more slowly receiv- be undertaken as for other pro-
ing less resources to build the capacity of gramme priorities/objectives based on
programme partners. Linking technical as- reporting of eligible expenditure;
sistance to progress in implementation in  earmarking for local authorities and
the manner set out in the new proposals civil society of a significant part of
therefore risks withholding support from funding from the AMF Thematic Facil-
the contexts and partners amongst which ity, to support integration and recep-
the need for it is most acute. tion actions implemented locally;
 a strong and mandatory Partnership
Stakeholder proposals
Principle in all relevant funds, to ensure
Specific stakeholder proposals put for- meaningful multi-stakeholder and
ward as reaction to the Commission pro- multi-level programming, implementa-
posals and relevant for this policy option tion, monitoring and evaluation;
include:  an EU-level Partnership Principle, ap-
plied to the AMF Thematic Facility and
 A new EU funding instrument offering with regular stakeholder consultations
direct financial support to cities in re- on the planning and implementation
turn for receiving refugees and asylum of activities;
seekers, linked to resettlement and/or  inclusion of civil society stakeholders in
EU relocation programmes; the ESF+ Committee, to reflect their key
 reasonable minimum allocations for lo- role in the design and delivery of the
cal authorities and civil society organi- fund, in line with the idea of an EU-level
sations across all priorities within na- Partnership Principle.
tional AMF programmes under shared
management;  for details on the various stakeholder
 a maximum EU co-financing rate of positions cf. chapter 3.2 (Annex) of the
80% for national AMF programmes and Policy Options Brief on ‘High levels of EU
encouragement of matching national support for migrant integration, imple-
funds, with Member States required to mented by civil society and local au-
provide a minimum of 50% of the na- thorities’
tional co-financing contribution from
25
 for in-depth information on the evi- work programmes of the Thematic Fa-
dence base supporting stakeholder cility; and to consult concerning ac-
proposals cf. chapter 2.2.3 of the same tions eligible for higher co-financing
Policy Options Brief and the further development the mon-
itoring and evaluation framework.
Support in the European Parliament
With regard to the ESF+ regulation, the
In the ongoing legislative process, most of amendments adopted by the European
the stakeholder positions have been taken Parliament also reflect key proposals put
up by Members of the LIBE Committee. forward by stakeholders (EP 2018c,d,
The EP’s legislative resolution on the AMF 2019b):
regulation of March 2019 stipulates (EP
2018e,f, 2019a):  Enshrining of a far-reaching partner-
ship principle in the ESF+ regulation,
 Establishment and development of re- asking for meaningful participation of
gional/local integration strategies, as social partners, civil society organisa-
well as capacity building of integration tions, equality bodies, national human
services provided by local authorities rights institutions and other relevant or
added to the fund’s scope of support;
representative organisations;
however, no provisions on minimum al-  appointment to the ESF+ Committee of
locations of national AMF programmes Member State representatives of civil
to civil society organisations and lo- society, equality bodies or other inde-
cal/regional authorities; pendent human right institutions, as
 encouragement of Member States to
well as of a Union level civil society rep-
provide matching national co-financ-
resentative;
ing to EU-funding of at a maximum 75%
 allocation of 2% of the ESF+ funds in
of eligible expenditure;
shared management to the support
 a minimum allocation of between 5% and capacity building of partners (as
of the AMF Thematic Facility to local civil society organisations, etc).
and regional authorities implementing
integration actions;  for details on the EP amendments to
 enshrining of a strong partnership prin- the Commission proposals cf. chapter
ciple in the regulation in addition to the
3.2 (Annex) of the Policy Options Brief
provisions of the Common Provisions on ‘High levels of EU support for mi-
Regulation, with partnerships to in- grant integration, implemented by civil
clude local and regional authorities as society and local authorities’
well as NGOs, human rights institutions
and equality bodies;
 the Commission to regularly engage
with civil society organisations in the
development and implementation of

26
 4. WAY FORWARD: SUSTAINED EFFORTS AND QUALITATIVE MONITORING

4.1 Needs for action at a critical junc- With regard to the ESF+ as well, Member
ture State positions are still wide apart, ranging
from ideas for mandatory integration
Preparations for the upcoming Multian- spending going even beyond the EP posi-
nual Financial Framework have reached a tion, as floated by e.g. Finland, the Neth-
critical stage as of spring 2019. While Com- erlands and Sweden, to questioning the
mission, Council and Parliament start en- very existence of an ESF+ strand targeting
gaging in the final stages of negotiations, the most deprived (ex-FEAD), as voiced by
there are still some persisting disagree- some net contributor Member States. In-
ments on the overall architecture and tense Council debate also has taken
governance of the funds. Among others, place about the inclusion of AM(I)F in the
Member States are still divided about the Common Provisions Regulation and impli-
scope of integration objectives and the cations for the partnership principle. Gov-
extent of Member States’ obligation to use ernments reluctant to give civil society
EU funds for integration purposes. Both and local/regional authority stakeholders
with regard to AM(I)F and ESF+, these con- a say in programme development and -
troversies crystallise in debates on required implementation have been pressing hard
minimum allocations to integration objec- to remove AM(I)F from the binding provi-
tives in national programmes. To ensure sions foreseen in the proposed CPR. Not
that the integration of migrants and refu- the least, strong linkages exist between
gees remains a core objective of the pro- the debates on internal and external fund-
posed AM(I)F regulation, stakeholders ing. In particular, Member States are di-
continue to point out that the suggested vided about the respective priorities and
weighting key for the allocation of AMF objectives of the NDCI fund and the artic-
funding to the Member States for their na- ulation of the external dimension of the
tional programmes should be revised, so three JHA funds.
that allocation based on integration and
legal migration indicators (weighting 30% At the same time, on national level, Mem-
as proposed by the Commission and un- ber States are gearing up planning and
changed in the EP position) is not over- operational preparations for the imple-
taken by allocation based on return indi- mentation of the new generation of EU in-
cators (weighting 40% as proposed by the struments. Already now, governments dis-
Commission and unchanged in the EP po- cuss priorities, define objectives and start
sition). They also continue to insist that min- drafting Partnership Agreements. Within
imum allocation requirements for the inte- the next one-and-half year, in each Mem-
gration objective in national programmes ber State the groundwork will be laid and
should be included to ensure that Mem- key decisions be taken on how much,
ber States adequately invest in these ar- where and how EU funding will be availa-
eas.

27
ble for the integration of migrants and ref-  to ensure comprehensive compliance
ugees far into the next decade. The chal- with the partnership principle and
lenge is fourfold: same high consultation standards in
AM(I)F and ESF+; for local and regional
 to fully exploit the potential for in-
authorities, civil society organisations
creased use of AM(I)F, ESF+ and other and refugees/migrant-led organisa-
instruments for the integration of mi-
tions to have a say in the national and
grants and refugees, and in particular operational programmes, as well as in
to ensure the use of ESF+ in Member their monitoring and evaluation – fol-
States which up to now have made lowing the policy option described in
only little or no use at all of ESF+ for this chapter 3.4;
purpose – following the policy option
described in chapter 3.1; To meet these challenges, at this juncture
 to promote a need-based approach all key actors need to commit and follow
to the services funded through AM(I)F up on a specific course of action:
and ESF+, avoiding the establishment
 The Commission, to make every effort
of barriers to certain target groups on
to promote the enhanced opportuni-
the basis of their residence status (e.g.
through unnecessary reporting indica- ties under the next MFF to Member
tors which would dissuade people with State authorities and integration stake-
irregular status from accessing ser- holders, inform Managing Authorities,
vices) – following the policy option de- facilitate joint and coordinated pro-
gramme planning, push for full imple-
scribed in chapter 3.2.
 to ensure complementarity and coher- mentation of the partnership principle
ence in programme planning with a and encourage meaningful involve-
view to long-term integration support ment of civil society and local and re-
and avoiding funding gaps – following gional authorities in the needs assess-
the policy option described in chapter ments that inform Member States’ pro-
gramming;
3.3. One way to achieve this is proper
coordination among the implementa-  Member States, to explore and em-
tion structures of the various funds brace the opportunities provided by
within Member States, ideally involving the future instruments, to anticipate
joint monitoring committees on inte- ways for strategic, long-term use of the
gration assessing proposals for more funds in order to leverage objectives of
than one fund. In line with good prac- national integration policies, to tackle
tices in some countries that could be cross-ministerial and cross-fund coordi-
scaled up and extended to the rest of nation challenges in the preparation,
the Union, another way to ensure com- implementation, monitoring and eval-
plementarity and coherence is to in- uation of programmes, to
acknowledge the potential for more
stall a single ministerial authority re-
sponsible for the integration priority efficient and better embedded poli-
across funds; cies that comes with structured in-
volvement of local/regional and civil
society actors, and to allow for early
28
 and meaningful participation of stake- 4.2 Towards a stakeholder initiative for
holders in decisions on the strategic ori- a sustainable, comprehensive evi-
entation of the national programmes; dence base supporting partnership-
 The European Parliament, in the up- led programme implementation
coming trilogue negotiations in au-
tumn 2019 to hold to the improvements Currently, in many Member States integra-
in terms of stronger partnership provi- tion stakeholders in civil society and on lo-
sions and coordination among the cal level lack resources to advocate in a
funds achieved in the first reading; timely and sustained manner for purpose-
among them the high consultation ful use of EU funds for migrant integration,
standards introduced in the AM(I)F and to push for meaningful participation
and ESF+ regulations independent in programme development and imple-
from the CPR provisions, EU-level part- mentation. Realtime evidence is lacking
nership consultations, as well as man- on the Europe-wide uptake of EU instru-
datory coordination among the Man- ments for migrant integration and the
aging Authorities of AM(I)F and the state of play concerning partnership-led
Structural Funds; implementation. Today, assessments of
 Integration stakeholders in civil society the partnership principle and how funds
and on local/regional levels to devote are used are done on an ad-hoc basis,
their full attention to the develop- mostly in form of one-off surveys con-
ments, actively contribute to national ducted through stakeholder membership
debates, point out efficient ways of us- organisations or as retrospective analyses
ing the funds for comprehensive and of the programme planning and evalua-
long-term integration support and insist tion reports produced by Member States
on meaningful and regular involve- and the Commission. As things stand, it is
ment in needs assessments, pro- difficult to obtain, and keep up to date,
gramme development, implementa- comprehensive knowledge about the
tion and evaluation. A joint, transna- state of programme implementation and
tional initiative can help to better play the consultation standards applied across
this role. Member States.

To fill this gap, an EU-wide mechanism

should be developed for ongoing, regular
monitoring of how stakeholders are in-
volved and different funds are used, and
of the quality of coordination and coher-
ence among the instruments, including
the empowerment of partners through ca-
pacity building and resources to partici-
pate in monitoring committees. Transna-
tionally networked, this initiative would
provide the improved evidence base for
pushing towards compliance with the

29
partnership principle, purposeful use of an initiative could entail four major com-
AM(I)F and structural (ESF+) funds to sup- ponents:
port integration, and coordination and
 Implementation monitoring compo-
collaboration among the implementing
nent, with annual ‘barometer reports’
authorities. Moreover, it would contribute
to a qualitative monitoring of programme on the quality of partnership-led imple-
mentation, coherence and coordina-
implementation, where e.g. AM(I)F mid-
term reviews would also be based on con- tion among funds as well as conclu-
tent and effectiveness of the projects. sions about their effective use; based
on a monitoring and assessment tool
By this it would resemble a proposal with a few core questions or indicators
for regular analysis (possibly imple-
floated by the Dutch government in the
ongoing negotiations, to amend the mid- mented through a survey among
stakeholders with a revised European
term review as foreseen in the draft AM(I)F
regulation with a view to strengthening its Code of Conduct on Partnership as
role and added value for the allocation of benchmark, supplemented by qualita-
the second tranche of funding. The allo- tive interviews, reflection and valida-
tion roundtables);
cation should not solely be determined by
the degree of Member States’ under-  Financial and material empowerment
and capacity building component,
spending but instead be based on a qual-
providing adequate resources and
titative analysis of Member States’ efforts,
in combination with an updated analysis with national meetings to inform civil
society and local/regional level stake-
of the actual needs of Member States.
With limited chances to win wider support holders about their role in partnership-
based needs assessment and pro-
among governments, this proposal can
nevertheless inspire a stakeholder-led EU- gramming as well as the potentials of
wide mechanism fulfilling the function of the funds to support integration; em-
qualitative monitoring. ploying coordinators in each Member
State as multipliers and drivers of a sus-
If established across Member States, such tained and continuous conversation;
a mechanism could become a powerful  Qualitative evaluation component,
instrument. It would ensure that robust gathering evidence on quality, impact
mid-term review procedures are in place and long-term effectiveness of funded
and would provide a source of infor- activities, leading to conclusions about
mation for stakeholders and other EU ac- the funds’ utilisation to comprehen-
tors on how funding instruments are utilised sively support integration in a long-
to support integration. It would enable in- term perspective, and producing evi-
tegration stakeholders to move to a more dence for the mid-term review pro-
proactive involvement, better fulfil their cess;
watchdog function in regard to the part-  Transnational benchmarking and mu-
nership principle and feed into advocacy tual exchange component, with EU-
for better use of EU funds for integration of wide benchmarking of compliance
migrants and refugees. In practice, such with the partnership principle and of

30
proper use of funds; including regular ganisations to coordinate and man-
European platform meetings for EU- age the process in Member States;
level agenda-setting and recommen- possibly supported by a European net-
dations for EU actors, as well as mutual work node. Discussions among the po-
exchange and information on good tential carriers of such an initiative are
practices. in order to clarify its funding, project
partnership and operational imple-
As an initiative independent from the mentation perspectives. If imple-
Commission and Member State au- mented as self-sustained civil society
thorities, the mechanism would be and local level network, sponsorship
based on the collaboration of integra- questions need to be solved. If imple-
tion stakeholders including civil society
mented through EU funding, a legisla-
organisations, refugees/migrant-led or- tive initiative would be necessary to
ganisations and local and regional au-
provide a manadate and the re-
thorities. It would need to build on the sources that would ensure full inde-
commitment among stakeholder or- pendence.

31
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