Warsaw: The mid-term review of the European Union’s 2021-2027 cohesion programmes is moving from background paperwork to live political theatre, with managing authorities across the bloc now finalising the reallocation requests that will determine where the unspent billions in the current envelope eventually land. In Poland, where structural and cohesion funds account for the largest absorption pipeline of any member state, the Ministry of Development Funds and Regional Policy has spent the past six weeks consulting with voivodeship marshals on which operational programmes need topping up and which can spare resources for higher-priority files. The exercise is repeating itself, in different keys, across all twenty-seven capitals.
The Commission’s reading of the mid-term reviews, which it began collecting in March and must conclude by 31 March 2027 under the Common Provisions Regulation, will shape the trajectory of the remainder of the programming period. Member states have until 31 March 2026 to submit their amended programmes, and the Commission has nine months to approve or modify them. The arithmetic is not trivial. Roughly nineteen to twenty-two percent of the cohesion envelope had been disbursed by the end of 2025, depending on the fund, leaving a substantial pot that can in principle be shifted between thematic objectives provided the reallocations respect the concentration thresholds set out in the original regulation.
The political pressure is coming from three directions at once. First, the security and defence agenda, formalised in the STEP regulation amendments and now reinforced by the bloc’s broader rearmament push, has opened the door to cohesion funding for dual-use infrastructure and skills programmes that would have been ineligible two years ago. Several central and eastern member states are quietly pivoting parts of their European Regional Development Fund envelopes toward defence-adjacent investments, even though most managing authorities remain wary of the political optics. Second, the rising bill for the energy transition, particularly the renewables rollout and the building renovation wave, is generating bottom-up demand from regional authorities for new operational windows. Third, the social challenges crystallised during the post-pandemic recovery, from labour market activation to skills, are pulling resources toward the European Social Fund Plus.
The Commission’s preliminary monitoring data, presented at the Cohesion Forum in March, showed considerable variation in absorption rates between regions. Several southern Italian regions and parts of Greece are running at less than twelve percent disbursement, while a handful of central European regional authorities have already absorbed more than twenty-eight percent. The Directorate-General for Regional and Urban Policy has signalled that it will use the mid-term review to push for stronger conditionalities where absorption has stalled, including potential decommitments of unallocated funds in 2027 if managing authorities cannot demonstrate credible delivery plans.
The shadow of the next Multiannual Financial Framework looms over the whole exercise. Parliament’s interim position, adopted on 28 April, defends a separate cohesion envelope against the Commission’s proposed shift toward national and regional partnership plans. Member states benefiting most heavily from current cohesion flows are watching the mid-term review as a test of whether the existing architecture can demonstrate the flexibility critics demand. If the 2026 amendments succeed in directing money to security, energy and skills without dismantling the regional governance model, the case for a stand-alone cohesion budget after 2027 strengthens. If the exercise stalls or produces only marginal adjustments, the Commission’s reform proposal gains ammunition.
Behind the scenes, the European Investment Bank’s interaction with managing authorities is intensifying as financial instruments take a growing share of cohesion delivery, particularly for small and medium-sized enterprise support and energy-efficiency renovations. The Investment Committee’s recent guidance on combining cohesion grants with EIB lending is being read closely in regional capitals. The mid-term review’s quieter consequence may be a structural shift in how cohesion money actually reaches projects on the ground, with blended finance becoming the default rather than the exception for a growing share of programmes.




