For over three decades, Bankwatch has been deeply involved in the programming and monitoring of European Union (EU) funds at both the EU and national levels. As Bankwatch’s national coordinator in Bulgaria since 2020, my specific role has been to represent environmental non-governmental organisations on the monitoring committee for Bulgaria’s national transport programme. Beyond this, I’m also responsible for overseeing other programmes, partnership agreements, and relevant strategic documents and processes.
When the European Parliament and Council of the European Union adopted the 2021–2027 legislative package for cohesion policy, including the Common Provisions Regulation, no one could have foreseen the series of crises Europe would go through during this period. However, predicting that policy and development challenges, as well as their solutions, might evolve from those identified in 2020, the Regulation anticipated a time for reflection in the form of a mid-term review of national spending plans.
As set out in Article 18 of the Regulation, the managing authorities of each EU Member State are required to submit a mid-term review report. The purpose of this exercise is to assess progress and correct course if necessary. In theory, this provision offers an opportunity to respond to emerging challenges, integrate the European Commission’s country-specific recommendations, and advance progress towards reaching the EU’s climate and social targets. In practice, however, this task has proved to be a considerable challenge – particularly in Bulgaria.
The disconnect between national implementation and EU policy goals
After many years observing the implementation of EU funds in Bulgaria, it’s clear that the national approach applied by managing authorities is not fit for purpose. Programmes rarely align with overarching EU policy goals, and the operations underlying them frequently lack the necessary level of project maturity. In fact, many of the deficiencies flagged in the country-specific recommendations and independent evaluations often go unaddressed – which is what we’re seeing now for the third programming period in a row. By allowing these recurring problems to persist, managing authorities have placed themselves in an extremely difficult position. Under Article 73 of the Regulation, they’re expected to ensure operations are consistent and align with EU policy objectives. But that’s a tall order when the foundations are so shaky.
A tool for reform or reinforcing the status quo?
The mid-term review was intended as a mechanism to address implementation issues and reallocate resources to priority areas. In reality, however, it has taken a very different turn. Instead of using the review to raise ambition and improve programming quality, Bulgaria’s managing authorities have used it to quietly lower expectations, scaling down large-scale strategic investments into smaller-scale fragmented projects just to ensure funds don’t go unused.
Even before the Commission announced its new mid-term review proposal in April 2025, it was already clear to many of us that the current framework was falling short, especially in countries like Bulgaria. The Commission’s proposal includes revisions to cohesion policy and Just Transition Fund allocations, which would shift resources towards dual-use defence infrastructure, water resilience, affordable and social housing, and decarbonisation support for large enterprises. And while these adjustments may create new opportunities, they also risk diverting and delaying critical funding away from the just transition, social cohesion, and climate action – policies so crucial for modernising central and eastern European economies. This potential shift requires careful scrutiny to ensure the EU stays true to its long-term goals.
Unfortunately, our attempts to improve the mid-term review process in Bulgaria, which have seen us submit recommendations to both the responsible managing authorities and the central coordination unit for EU funds, have been largely ignored. In addition, the monitoring committees tasked with overseeing the use of these funds have not provided the necessary counterbalance we had hoped for. Instead of demanding better planning, stronger performance, and more transparency, they’ve remained passive, offering support to the managing authorities rather than holding them to account.
Strategic funds, missed opportunities
The 2021–2027 Transport Connectivity Programme – with a budget exceeding EUR 2 billion – is Bulgaria’s largest EU-funded initiative under the current Multiannual Financial Framework. The programme included a strategic road rehabilitation project – the Ruse–Veliko Tarnovo motorway – intended to enhance Bulgaria’s integration into the Trans-European Transport Network (TEN-T) and strengthen links to NATO corridors. Yet during the mid-term review process, this flagship project was considered high-risk due to significant delays. As a result, two of its sections were cancelled. In their place, the government redirected funds to another route: European route E85 to the Serbian border, channelling traffic towards a non-EU country. This has increased costs for citizens and businesses in the form of border controls and rising motorway tolls.
Witnessing for so long the same mistakes repeated in Bulgaria, we strongly recommend the following changes for the next EU funding cycle:
- Set stronger obligatory standards for the mid-term review process, including standardised questions and assessment criteria;
- Ensure these are discussed not only with the European Commission and relevant monitoring committees, but also shared with citizens through open consultation;
- Reassess the impact of EU funding in Bulgaria under shared management and how it has contributed to EU policy objectives in Bulgaria over the last three programming periods;
- Identify systemic issues and propose concrete reforms to ensure alignment with the EU’s policy framework and improve the quality of planning and implementation;
- Reform the national programming model given the complete inadequacy of the current model, which fails to fully realise the potential of EU funds in supporting the Union’s long-term strategic goals.
As we cannot expect any drastic changes to the national administration’s approach, my personal conviction is that, under the current circumstances, more inclusive and meaningful public participation is one of the most effective ways of improving how EU funds support the implementation of EU policies and how national programmes adapt to the real needs of Bulgarian citizens.