Brussels – As the EU returns to full operations, co-legislators and analysts are faced with a mammoth dossier left by the European Commission just before the summer break: the 2028–2034 Multiannual Financial Framework (MFF), the next EU budget.
Of the overall €1.9 trillion budget, €215 billion is allocated to the external action pillar—a substantial increase, but not without its concerns. One major worry is the potential for a new, hidden conditionality tied to the Global Europe Instrument: non-cooperation by third countries on migration control and returns could lead to the freezing of external funds in the 2028–2034 MFF.
According to Article 12.3, in the event of “serious shortcomings” in a partner country, related “in particular to the obligation to readmit its own nationals” from the EU member states, the Commission “may suspend payments or the implementation of a programme.” The only safeguard is that “under no circumstances shall the suspension affect humanitarian assistance.”
“The framing of the wording opens the door for the conditionality, which I find worrisome,” confirms Anita Käppeli, Director of Policy Outreach Europe at the Center for Global Development (CGD), in an interview with The New Union Post. With migration a priority for both member states and the Commission, and conditionalities increasingly seen as a way to safeguard external action funding, “it wasn’t a surprise as such.” Nevertheless, migration conditionality could pose a serious risk from a development cooperation perspective: “We don’t know what would happen to those programmes,” she adds.
This decision could have serious consequences for ordinary citizens in third countries, and it may also create unpredictable challenges for the EU’s credibility as a reliable external partner. While framing migration cooperation as a tool of strategic leverage reflects European political realities, it could backfire. “Some partner countries may turn to other geopolitical actors, where support comes with far fewer strings attached,” Käppeli warns.
Risks and benefits of increased flexibility in the EU budget
Analysing the overall proposal for external funds in the next EU budget, Käppeli underlines that she was “pleasantly surprised” both by the ambition of the allocated budget and the balance struck between a geopolitical Europe and the EU as a reliable long-term development partner. “Of course, we will have to wait and see the final outcome after negotiations,” she cautions.
Flexibility seems to be the key word in the 2028–2034 MFF, which will apply to external action through the merger of the main instruments into the Global Europe Instrument. As CGD’s Director of Policy Outreach Europe points out, “it is almost as if we have gone from one extreme to the other.” Whereas NDICI—Global Europe currently encompasses a wide range of instruments—for humanitarian aid, neighbourhood policy, and development cooperation—all these policy areas will be consolidated into a single instrument in the next EU budget.

This proposal comes with both potential benefits and risks. On one hand, Käppeli notes that it could “reduce fragmentation, improve coherence between the different areas, speed up the disbursement of funds, and increase flexibility.” Flexibility is precisely the central issue in this assessment, as the Commission “has learned lessons from COVID-19 and Ukraine about the risk that the flexibility instrument could be exhausted before a major crisis,” highlighting the need for a crucial cushion for unforeseen events.
On the other hand, there is a risk in the shift from ex ante control—where the Commission had to justify in advance how it would use multi-year programmes of the EU budget—to ex post control, which reduces accountability and oversight also by the European Parliament. “Reducing this democratic control is a trade-off for flexibility, and the balance has clearly tilted towards flexibility,” Käppeli warns. It is true that excessive earmarking “increases the likelihood of box-ticking exercises,” Käppeli says, but too little thematic earmarking “can reduce transparency and squeeze out human development and other global priorities.”
Poverty reduction provides a clear example, as it could be overshadowed by geopolitical and security considerations in the 2028–2034 MFF, despite being at the heart of the EU’s external action according to the Treaties. The ultimate risk is that, by eliminating the thematic pillars and keeping only geographical areas in the Global Europe Instrument, “some investment may tilt towards geopolitical interests,” such as competitiveness, industrial strategy, and critical minerals, with the neighbourhood remaining the primary focus.






























