kom (2018) 0460 - Bilag 2: Høringssvar vedr. forordning om De Eksterne Finansielle Instrumenter under EU's næste flerårige finansielle ramme (MMF), 2021-2027

Europaudvalget 2017-18
KOM (2018) 0460 Bilag 2
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[email protected]

CVR-nr.: 20 70 02 11

Ministry of Foreign Affairs

Att. Lars Kjellberg

16-08-2018

Danish Red Cross input to the EU Multiannual Financial Framework (MFF) 2021-

2027 and programme proposals

Danish Red Cross appreciates the opportunity to provide input to the ongoing negotiations for the

next EU Multiannual Financial Framework 2021-2027. Please find our recommendations for the

budget for EU’s humanitarian and development assistance under Heading IV: Neighbourhood and the

World outlined below.

Overall, Red Cross appreciates that the proposed funding envelope for External Actions will be kept at

the same level as the current MFF and hope that this will be maintained. However, given the nature

and extent of humanitarian crises across the world, Red Cross recommends that further resources are

allocated to humanitarian assistance. We hope the Danish Government will work towards this in the

coming negotiations. We welcome the continuous prioritization of climate change related challenges,

and the proposed provision of 25% of the NDICI’s spending target to step-up efforts on addressing

climate change. We also see the inclusion of the European Development Fund for ACP countries in the

MFF as positive, allowing for greater accountability towards the European Parliament.

In relation to the Neighbourhood, Development and International Cooperation Instrument (NDICI),

Red Cross has the following recommendations:



Red Cross recommends that the MFF 2021-2027 budget for external aid, in accordance with

the objectives outlined in EU Treaties and the European Consensus on Development, is kept

separate from security and migration political objectives.

While the proposed merging of the existing 12 funding instruments into one single instrument

may promote flexibility, there is great risk that this coupled with the ear-marking of a

relatively large proportion of the budget towards ‘emerging challenges’ may compromise

predictability, transparency and accountability of aid and undermine the realization of the

specific objectives of the current individual instruments. Red Cross therefore recommends:



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kom (2018) 0460 - Bilag 2: Høringssvar vedr. forordning om De Eksterne Finansielle Instrumenter under EU's næste flerårige finansielle ramme (MMF), 2021-2027

The MFF should maintain separate financial instruments for humanitarian assistance,

civil protection, human rights and democracy, and peace building.

It is important that the flexibility build into the MMF concerns flexibility in the

implementation

for the partners, and is not focused on flexibility for the Commission.

Red Cross are positive towards the establishment of Trust Funds and other

mechanisms for pooling of funds with the objective of promoting more flexibility and

efficiency. However, the experience of implementation under the current MFF has not

resulted in flexibility and efficiency for partners nor beneficiaries. On the contrary the

processes has become longer, more complicated, more centralized as well as less

transparent. This should be addressed in the discussions of the NDICI.

The Commission’s mandate and objectives for International Cooperation and

Development as per the European Consensus on Development must remain the key

objective. This requires clear and transparent criteria and prioritization of the multiple

objectives under NDICI. The current proposal with flexible funding structure leaves

the instrument open to future political pressure, making it more vulnerable to

instrumentalisation for short-term political objectives. Reducing poverty must be the

overarching objective.

The implementation of the NDICI should be an opportunity to increase transparency

and public access to information on the different projects implemented in third

countries, especially for the activities to be implemented in the framework of the

flexibility cushion.



Red Cross welcomes the introduction of a rapid-response pillar and a stronger focus on the

humanitarian-development nexus in the proposal. However, Red Cross would like to see a

stronger focus on and explicit mentioning of fragile states in these budget lines to ensure that

the resources can be allocated according to the developments in needs in these contexts. The

budget line should also clearly supplement and be complementary to ECHO funding:

The rapid-response pillar should be used to support when a crisis is emerging. Trigger

based action/forecast based financing should guide the use of the rapid-response

pillar. It would be important though to ensure that when the triggers indicate a full-

blown emergency, that ECHO takes over, and the rapid-response pillar ends.

Also, it is important that a rapid-response pillar when used in a worsening

humanitarian crisis is monitored closely, not least to ensure respect for the

humanitarian principles.

This also implies consideration of the full humanitarian cycle from triggers, through

the emergency, and to the recovery phase, for consistency in adherence to the

humanitarian objectives and principles, as this is key to continued safe access and the

safety and security of humanitarian staff.



A clearer description and presentation is needed on the Investment framework. The Red

Cross do recognize that support to EFSD+ and other programmes is under this heading,

however it is not clear why that is part of the NDICI budget. Also, the external action

guarantee is just a guarantee and governments tend to treat guarantees as off-budget

and off-balance sheet contingent liabilities, rather than recognize them in financial

statements or budgets.

The Red Cross questions the set-up of a guarantee as according to the Danish export

council, the availability of funding for investments in Africa and other higher risk areas are

not a concern, while the absence of profitable proposals are. The Red Cross would like to

see a clearer and stronger recognision of the need for more innovative approaches to

financing initiatives to improve the efficiency and effectiveness of humanitarian

interventions while also mobilizing non-traditional pools of private sector capital. Indeed,

a sample of innovative financial mechanisms that the Red Cross would like the investment

framework to support would include outcome-based financing and guarantees for

Humanitarian and Development Impact Bonds, catastrophe bonds, a combination of

16-08-2018 / Danish Red Cross input to the EU Multiannual Financial Framework (MFF) 2021-2027 and

programme proposals

rødekors.dk

kom (2018) 0460 - Bilag 2: Høringssvar vedr. forordning om De Eksterne Finansielle Instrumenter under EU's næste flerårige finansielle ramme (MMF), 2021-2027

grants and concessional loans, disruptive fintech and distributed ledger technology, and

crowdfunding.

In relation to Humanitarian Aid and Civil Protection, Red Cross has the following recommendations:



The management and delivery of humanitarian aid needs to remain principled, unconditional

and based on needs. While Red Cross recognizes the need for strengthened coherence,

coordination, and complementarity with non-humanitarian actors, it cannot compromise the

respect for impartial, neutral and independent humanitarian assistance, requiring

acknowledgement and respect for the differences in purpose, mandate and principles. are

acknowledged and respected.

It should therefore be recognized that a call for greater alignment towards shared collective

outcomes or common strategic objectives, as well as more joint analysis and programming,

must be in respect of the humanitarian principles and the Good Humanitarian Donorship

Initiative. Humanitarian and Development assistance budgets and funding instruments must

therefore remain separated and independent.

A clear distinction between humanitarian aid and policy objectives that aim to control and

reduce irregular migration is key to continued humanitarian access and humanitarian assistance

in accordance with the humanitarian principles. There has been an increased tendency of ECHO

funding allocations to countries along the migratory routes in recent years, while funding for

crises and countries with greater humanitarian needs, but hosting less migrants has been

reduced. To continue to be able to respond to humanitarian crises and needs, Red Cross

recommends that a needs-based approach towards budget allocations is applied.

The EU, together with its Member States, is the world’s biggest donor of humanitarian aid. It is

key that the EU increases the amount allocated to external actions in order to fulfil its

commitment to bring help to the people in need. If an increased budget is allocated from the

start, it will increase the effectiveness and efficiency of the aid by allowing for a better planning

and by reducing the administrative burden that regular funding amendments represent. Red

Cross therefore recommends that the budget for humanitarian aid is increased to address the

rising needs worldwide.

Red Cross welcomes DG ECHO’s efforts to make humanitarian aid more effective and cost

efficient. Cost effectiveness can be best achieved through non-duplication, and the efficient

mapping of available tools, as well as reinforcing regional and local response mechanisms. Due

to the different nature of civil protection instruments and humanitarian aid, they should remain

separate and specialised in their respective domains. At the same time, synergies may be

established between civil protection and humanitarian actors, by mapping their respective

strengths and capabilities and developing practical methods of cooperation. EU civil protection

interventions outside the territory of the European Union must be fully guided by the European

Consensus on Humanitarian Aid. Red Cross recommends that there will continue to be separate

instruments for Humanitarian Aid and Civil protection, but strongly recommend that Civil

Protection remain under Neighbourhood and the World, and is not moved to Security and

Defence.

The current Emergency Aid Reserve, which comes

increasingly been allocated to address unforeseen

including this reserve and increasing its budget

flexibility to secure rapid access to funding in case

on top of the humanitarian aid budget, has

crises in non-EU countries. We recommend

in the next MFF. This would help ensure

of unpredictable crises.



Red Cross would encourage significant strengthening of the focus on civil society in the proposal. Civil

society plays a key role in the implementation of the EU external actions in relation to humanitarian

assistance, development, peace building, human rights and democracy, not least in fragile and

complex settings where other actors may have limited access. The financing instruments must be

accessible to a broad range of civil society actors, and this should be reflected in the regulations of all

instruments. This is also key if the civil society should be able to perform its role as a watch dog to

help ensure transparency and accountability towards the beneficiaries.

16-08-2018 / Danish Red Cross input to the EU Multiannual Financial Framework (MFF) 2021-2027 and

programme proposals

rødekors.dk

kom (2018) 0460 - Bilag 2: Høringssvar vedr. forordning om De Eksterne Finansielle Instrumenter under EU's næste flerårige finansielle ramme (MMF), 2021-2027

Red Cross hopes that the budget line Neighbourhood and the World will remain a strong priority of

the EU and that Denmark as a minimum will work to keep it at the currently proposed level.

Red Cross is of course available to discuss the above in more detail, and we look forward to continue

the dialogue under the ongoing negotiations of the MFF.

Best regards,

Jakob Harbo

Heaf of Partnership & Compliance

Tel +45 31 32 01 19 / [email protected]

16-08-2018 / Danish Red Cross input to the EU Multiannual Financial Framework (MFF) 2021-2027 and

programme proposals

rødekors.dk