Some ambitions of the legislators have not been fully met and warrant reflection for the future:
Investment platforms designed as a new form of intermediation to facilitate the support of smaller and local projects. Once the rules for investment platforms were codified, a significant number of them were established. However, the investment platform model has been most successful in Member States where there is a strong local national promotional bank as the implementing partner. Expectations that investment platforms could be a substitute for Member States having a strong national promotional bank have not been fulfilled.
Very few cross-border operations. This is true of both intra-EU deals and cross-border deals with non-member countries. With hindsight, the main obstacle to these projects is rarely ever the availability of financing. Rather it is red tape and diverging national legal or regulatory requirements. Here the third, regulatory Pillar of the Investment Plan for Europe is much more relevant than EFSI.
Blending of EFSI with EU or national grants and structural funds. This has been a qualified success, but is still hampered by diverging legal, reporting and other requirements between the different sources of public funds. The Omnibus Regulation —introduced in 2018 to clarify the way the Investment Plan for Europe interacted with other EU financial instruments—helped to some degree, but is not a silver bullet.
The European Investment Advisory Hub has provided hands-on support to many prospective project promoters, but has not had a strong link with EFSI financing. Linkage from project preparation to financing support with the public EFSI guarantee could be strengthened, if that is the political intention.