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Fundación Secretariado Gitano

FSG

Fundación Secretariado Gitano is a Spanish non-profit promoting equal opportunities for Roma people.

Lobbying Activity

Response to Report on the progress made in the implementation of national Roma strategic frameworks

11 Dec 2025

The EU Roma Strategic Framework constitutes an essential, though insufficient, step toward closing the persistent inequality gap between Roma and the broader EU population. To advance genuine equality, the Framework must be reinforced and explicitly integrated into upcoming EU policy initiativesparticularly the future EU Anti-Poverty Strategy, the EU Affordable Housing Plan, and the revised EU Anti-Racism Strategy. Within the ongoing Child Guarantee, it is crucial that Roma children be explicitly recognized as a distinct target group, as current measures fail to adequately respond to their specific vulnerabilities. Efforts to reduce Roma inequality cannot rely solely on national strategies; Roma inclusion should be systematically mainstreamed across all EU and national sectoral policies. The next Multiannual Financial Framework (MFF) must therefore set social inclusion and equality as clear prioritiesaligned with the objectives of the European Social Fund Plus (ESF+)and identify Roma as a vulnerable group warranting targeted measures. Future MFF regulations should explicitly promote investment in Roma equality and prevent Member States from neglecting this area, which would risk deepening exclusion rather than alleviating it. ESF+ should remain the main policy and financial instrument supporting Member States implementation of the EU Roma Strategic Framework, particularly in areas such as education, employment, gender equality, and non-discrimination. Spain offers a strong example of effective Roma inclusion policy by imposing specific conditions on the use of ESF funding to ensure strategic, large-scale investments rather than fragmented short-term projects. This approach demonstrates how funding conditionality can drive measurable social outcomes and should serve as a model for EU-wide Roma inclusion strategies. Spain has also introduced pioneering national legislation, notably the State Employment Plan for the Roma population (20252028), which seeks to guarantee equal opportunities and tackle structural inequalities in the labour marketwhere Roma unemployment rates remain approximately three times higher than the national average. This plan reflects an enduring political and social commitment to Roma equality, demonstrating how cross-party engagement and tailored legal instruments can catalyse progress. Other Member States could benefit from adopting similar targeted frameworks. Nevertheless, despite positive steps in Spain, the overall European picture remains concerning. Major structural challenges persist, such as widespread slum conditions and segregated settlements disproportionately inhabited by Romahalf of them children. These living conditions, representing one of the starkest forms of social exclusion in Europe, demand urgent and coordinated EU action. The forthcoming European Affordable Housing Plan represents a strategic opportunity to address these realities and ensure equitable access to decent housing, a precondition for effective social inclusion. To fulfil the Roma Frameworks objectives by 2030, the EU and Member States must secure long-term, stable investments focused on systemic reforms rather than isolated initiatives. Sustained political commitment and robust financial mechanisms are essential to guarantee continuity and impact. If the ESF+ were to be discontinued or diluted in the future MFF, it would strip Roma equality efforts of their primary tool for structural transformation and risk reversing hard-won progress. The EUs path forward must combine mainstreaming with targeted action: integrating Roma inclusion into all major EU strategies while maintaining dedicated instruments and monitoring systems. Only through coordinated, long-term investment and strong political will can Europe ensure that Roma citizens enjoy equal opportunities, adequate living conditions, and full participation in society by 2030.
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Response to EU’s next long-term budget (MFF) – EU funding for civil protection, preparedness and response to crises

7 Nov 2025

Fundación Secretariado Gitano welcomes the recognition of vulnerable groups, particularly people from minority backgrounds such as Roma, within the EUs crisis, preparedness and disaster response frameworks. Anticipation and preparedness are decisive to ensure equitable responses in times of crisis, especially for those living in conditions of severe social exclusion. Across the EU, many Roma communities still live in precarious contexts including informal settlements and slums where exposure to crises and disasters is intensified. These living conditions, often lacking adequate infrastructure and basic services, leave entire families, and particularly children, at risk of suffering disproportionate social, health, and environmental impacts during emergencies. We call for the proposed EU regulation on anticipatory and preventive disaster measures to explicitly include such contexts among its target environments. The focus should be on minimising the adverse effects of crises on the most vulnerable populations and acknowledging the specific conditionss by developing anticipatory approaches that take into account the structural vulnerabilities of disadvantaged groups from the outset. Tailored preventive measures should be developed and implemented in synergy with existing EU financial instrument, mainly from the ESF+ and ERDF and the RRF. Coordination and synergies between these EU instruments would ensure that responses to crises effectively prevent the widening of existing inequalities and promote inclusion as an integral part of resilience planning. Experience has repeatedly demonstrated the essential role of NGOs in mitigating the negative impact of crises on vulnerable communities. During the COVID19 pandemic, for example, NGOs acted swiftly to address immediate needs where public systems faced delays. In Spain, Fundación Secretariado Gitano was able to mobilise quickly thanks to the structural support provided by the ESF+ within a long-term national framework focused on Roma inclusion and social advancement. This consistent funding allowed FSG to provide rapid educational support, employment advice, and emergency assistance to Roma families, maintaining continuity with its established ESF+ programmes. That is why we insists that future EU disaster-preparedness and resilience mechanisms must explicitly recognise and integrate the role of NGOs as operational partners in reaching those most at risk. Their experience, community presence, and capacity for quick response are vital assets that public authorities alone cannot replace. Ensuring coherence and complementarity among funding instruments, particularly between ESF+ and any new crisis-preparedness mechanisms, is indispensable for maintaining a strong social dimension within EU resilience policies. We would like to also express our concern about provisions allowing the reallocation or carryover of unused appropriations intended for response actions. Such flexibility shoudl include safeguards to ensure that funds targeting disadvantaged populations remain protected and not subject to be used for crisis reponses. Finally, we strongly recommend that the Unions disaster resilience goals explicitly integrate cross-sectoral impact analysis specifically in relation to disadvantaged populations, including Roma. Such analysis should inform the design of measures to strengthen resilience to crises and disasters. Ensuring genuine synergies with other EU instruments, especially ESF+ and ERDF, is indispensable to both anticipate and respond effectively to future crises. The crucial role of NGOs must be recognised and formally integrated into the regulation. Failing to do so would mean failing to protect those who are most at risk.
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Meeting with Ana Carla Pereira (Director Justice and Consumers)

30 Oct 2025 · Roma priorities and challenges in the context of upcoming Commission initiatives.

Meeting with Borja Giménez Larraz (Member of the European Parliament, Rapporteur) and European Ventilation Industry Association

1 Oct 2025 · HOUS Draft Report

Meeting with Ana Carrero (Cabinet of Commissioner Piotr Serafin) and Caritas Europa and

23 Jul 2025 · Exchange of views on the Multiannual Financial Framework proposal

Meeting with Sonia Vila Nunez (Cabinet of Executive Vice-President Roxana Mînzatu) and Caritas Europa and

23 Jul 2025 · Social inclusion of most vulnerable groups – overview of policies and post-2027 MFF perspectives.

Response to Anti-racism Strategy

8 Jul 2025

The European Network on Roma Equality under EU Funds (EURoma Network) welcomes the new EU Anti-Racism Strategy 2026-2030, which should be crucial in building a more inclusive and equitable society that upholds the fundamental rights of all individuals, including Roma. Based on experience of implementing the Anti-Racism Action Plan 2020-2025, the new strategy should strengthen the protection of rights holders (in cases of institutional and interpersonal racism) and develop targeted policies and measures to address structural racism and discrimination in key areas such as employment, education and housing. While the current Plan was an important step forward in putting racial discrimination in the political agenda and acknowledging Roma as one of the groups affected, there is a feeling that it has had limited added value in addressing discrimination against Roma and antigypsysim. Despite some overall progress, the Roma still face widespread and persistent racism and discrimination, particularly in employment, education, healthcare and housing (in some cases, the situation has even worsened). The 2023 Eurobarometer survey on discrimination in the EU shows that Roma people experience the most widespread discrimination of all the groups considered. EU Agency for Fundamental Rights (FRA) reports also reveal alarming data on discrimination against the Roma in the different fields. In light of this, EURoma puts forward five proposals: 1.Inclusion of a dedicated chapter on discrimination against Roma and antigypsyism to ensure a more targeted focus/action. It should provide information and data illustrating the racism and discrimination experienced by Roma in various areas and set out specific measures to address the challenges identified. MS should also include a dedicated chapter in their NAPARs/anti-racism measures. The specific situation of Roma women should be acknowledged. 2.Enhance governance mechanisms to improve coordination and cooperation. Future Strategy's objectives must align with existing frameworks and initiatives (such as EU Strategic Framework for Roma Equality, Inclusion and Participation and EU Child Guarantee) and future strategies/plans (e.g. Affordable Housing Initiative and EU Anti-Poverty Strategy). Stronger and more effective governance mechanisms for coordination/cooperation between bodies in charge of the Strategy and those responsible for these sectoral policies are essential to this end. In particular, the bodies responsible for future Strategy should establish regular, meaningful and formal dialogue and coordination processes with National Roma Contact Points for programming, implementing and monitoring actions. Coordination with the ESF+/ERDF authorities is also important to ensure alignment with EU Funds. 3.Advancing legislative developments that specifically address antigypsyism. Anti-racist legislation needs to be developed further to include antigypsyism and introduce the latest human rights standards in the fight against different forms of discrimination, including intersectional discrimination, online hate speech and algorithmic bias. 4.Strengthening of victim support services. This element must be given greater prominence and its effective implementation must be ensured. It includes robust legal provisions guaranteeing sufficient competencies (including increased capacity for strategic litigation) and adequate funding. Roma people must be explicitly recognised and targeted programming of specific measures, actions and indicators implemented. 5.Strengthen EU-level support and monitoring of how antigypsyism is addressed in NAPARs. EC should increase its support and cooperation with MS in implementing future NAPARs, including facilitating mutual learning/exchange of practices. EURoma will continue to play its role as a platform for engaging partners in this mutual learning and exchange. A harmonised approach to equality data collection across the EU, including disaggregated data is also crucial.
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Meeting with Javier Zarzalejos (Member of the European Parliament, Committee chair)

18 Dec 2024 · Reunión Fundación Secretariado Gitano

Meeting with Estrella Galán (Member of the European Parliament)

18 Dec 2024 · Meeting with Rafael Saavedra Rodríguez, international department of the Fundación Secretariado Gitano

Response to Directive of the European Parliament and of the Council on a Quality Framework for Traineeships

19 Jun 2024

Fundación Secretariado Gitano (FSG) is a Spanish national, intercultural, non-profit social organisation that has been working for more than 40 years for the equality and promotion of the Roma people. It develops, among others, programmes to improve the education, employment and housing of Roma people in Spain and Europe, as well as political advocacy to place the Roma issue on the European political agenda. FSG has been developing the Acceder Programme promoting employment inclusion through personalised labour market inclusion pathways for more than 20 years. This programme is co-financed by the ESF+. Through it, we have extensive experience in organising our own training actions (ad hoc training) that include traineeships in companies. These actions are typically designed by social entities to ensure a high degree of adaptation (usually not found in mainstream training) to the vulnerable situation of the beneficiaries and the needs of the companies. They are target actions specifically designed with the aim of training people in vulnerable situations and increasing their chances of finding a job. These actions have evolved over time from being very short to longer-term formats, and from focusing almost exclusively on low-skilled occupations in certain sectors, to covering a wider range of occupations. Even so, they keep being ad hoc training, due to the lack of adaptation and flexibility of the system of professional certificates. According to our experience, these certificates are far from the reality and possibilities of vulnerable groups and are not usually demanded by the sectors and companies in which these people are most commonly inserted. During this time, FSG has trained more than 45 000 people in these training courses. FSG welcomes the proposed directive on traineeships, as we believe that it can contribute to improving the quality of these activities and the working conditions of trainees. At the same time, we believe that it should contain inclusive measures that favour opportunities for the most disadvantaged people, such as Roma. Based on more than 20 years of experience in the organisation of training through the Acceder programme, we propose that the design and implementation of training programmes with traineeships may allow official bodies to approve ad hoc training programmes (normally developed by social entities). In such a way that contributions to the social security system are authorised for trainees or that they can be covered by training contracts, mechanisms that improve the conditions and quality of the traineeships for the beneficiaries. In this context, this measure would also facilitate longer training courses that are recognised by public bodies. By way of example, at FSG we are developing an employment and training action that could be understood as example of this proposal: - The "TándEM" programme of training in alternation with employment (12 months of training, more than 1 500 hours) in the framework of the Recovery, Transformation and Resilience Plan with funding from Next GenerationEU, which allows, as an alternative to training based on professional certificates, that the ad hoc training usually developed by social entities includes training contracts. This is possible through a guarantee from the State Public Employment Service (SEPE). https://www.gitanos.org/actualidad/archivo/137285.html.en Further information: https://www.gitanos.org/que-hacemos/areas/employment/acceder.html
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Response to ESF+ mid-term evaluation

13 Feb 2024

We would like to share our views for the ESF+ mid-term evaluation, focusing in particular on the use of ESF+ for vulnerable groups (especially Roma) in Spain (for full contribution, see document attached). We have a positive view of the way in which ESF+ has been programmed in Spain at national level. We also acknowledge some progress at regional level (Autonomous Communities), although we would have liked to see an increased use in regional programmes of the opportunities offered by the ESF+ to address the situation of groups/people in situations of greater exclusion and vulnerability, such as the Roma. At national level, the model of support adopted in the 2021-2027 programming period for disadvantaged groups, such as the Roma, maintains the elements that have proved to be effective and to have had an impact in previous periods, while at the same time strengthening and extending them (in terms of budget, areas covered...). Key elements include: 1) Specific, tailored and sustained investment in the most vulnerable groups, including Roma (with the allocation of a specific budget through Specific Objective (j)); 2) In line with the National Roma Inclusion Strategy, focus on the key areas of employment, education, gender and anti-discrimination (recognising the gap that still exists in these areas and their transformative power), while expanding to other areas. Particular importance is also given to discrimination and Roma women, with specific investments, as well as their consideration in a cross-cutting manner in the aforementioned areas; 3) Long-term approach to the design of calls for proposals and the selection of investments (allowing projects/interventions for the entire programming period without interruption); 4) Large scale in terms of dimension, budget, geographical coverage (national level, several localities, several regions/territories...), etc.; 5) Interventions based on approaches and methodologies that have proved their worth; 6) Involvement of specialised CSOs working with the specific target groups in the management and implementation of funds. At regional level, although we would have liked to see further progress, it is encouraging to find a greater number of programmes that specifically mention the Roma population and include actions aimed at them (from a targeted or mainstream approach). It remains to be seen how they will be implemented in practice and whether the experience and lessons learned from the use of ESF for disadvantaged groups in national programmes over the last three programming periods will be taken into account. Having said this, there are a number of elements and challenges that we consider important to address in order to ensure that this favourable framework translates into interventions which lead to a real change in the lives of disadvantaged groups/Roma, including: 1) The actual implementation of what is set out in the programming documents, ensuring that this is done in a way that promotes the greatest effectiveness, efficiency and impact. To this end, it is crucial to consider the experience and lessons learned from previous programming periods; 2) The combined use of ESF+ with ERDF (within the same or different calls) in order to allow for comprehensive, multidimensional and integrated actions covering different fields (such as employment, education and training, health, housing or anti-discrimination, poverty or anti-discrimination) and different types of investments/expenditure, e.g. human resources, equipment, infrastructure, etc.; 3) An increased use of ERDF to promote Roma equality and inclusion, in line with the objectives set in the National/Regional Roma Inclusion Strategies; 4) Ensuring the adequate conditions for the involvement of beneficiary/implementing organisations, particularly relevant for CSOs (e.g. in terms of payments, co-financing rates, administrative requirements/arrangements, investments in the infrastructures used to implement the action, etc.).
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Response to Assessing the implementation of the Member States' national Roma strategic frameworks

2 Feb 2024

Fundación Secretariado Gitano (FSG) shares its views,with particular attention to the areas in EC's 2023 report and those related to EU Funds (European Cohesion Policy Funds and Next Generation) (see document attached for more details). Firstly, it should be noted that the Operational Plan 2023-2026 of the Spanish NRSF clarifies many of the aspects in ECs report -actions, competent authorities, possible funding sources (although with no specific amounts). Spanish NRCP has worked, together with other bodies, to implement planned actions (and others) and to promote the consideration of Roma in mainstream policies/initiatives (including within Spanish EU Presidency). Various legislative, political and financial initiatives of relevance to Roma have been developed. It now remains to be seen how they are implemented (and funded) in practice, both at national and, when relevant, at the level of Autonomous Communities, which hold some of the competences in the different fields. And, above all, to ensure that these initiatives lead to a significant improvement in the living conditions of Roma. Among them, we stress: - Spanish EU Presidency. An important impetus has been given with initiatives such as the Council Conclusions on measures to ensure equal access for Roma to adequate and desegregated housing, and to address segregated settlements". We trust that these Conclusions will contribute to tackling the eradication of slums (in Spain and in EU) and they will lead to the adoption of a European action plan for the elimination of settlements by 2030, as set in European Parliaments Resolution. - Law on the Right to Housing, which prioritises groups in situations of poverty, social exclusion and other forms of vulnerability (with a focus on children) for actions of public institutions as regards housing. It also includes key issues to prevent and tackle slums and substandard housing. It should go hand in hand with the State Housing Plan, which also addresses the eradication of shantytowns and provides resources for it. - Employment Act, which includes a specific article (50) on "Priority groups for employment policy", including "Roma". As such, specific attention should be paid to the persons belonging to these groups in the planning, design and execution of employment policies. -Report from the Subcommittee for a State Agreement against Antigyspyism and the Inclusion of Roma people of the Congress of Deputies, which contributed to put the situation of Roma on the agenda. We trust it does not remain a mere declaration of intent but a roadmap for action. As regards EU Funds: -There is a positive framework for programming period 21-27, notably for ESF+. ESF+ at national level has adopted a model of support for disadvantaged groups, such as Roma, that maintains elements that proved positive in previous periods, while reinforcing and extending them (e.g. budget, areas covered, etc.). It features calls covering the whole programming period; large scale in terms of budget and geographical scope; focus on key areas of employment, education, gender, discrimination; CSOs working with target groups as beneficiaries/implementers, etc. Therefore ESF+ will give greater impetus to achieving NRSF's objectives. Concerning ERDF, it remains to be seen whether investments foreseen with a potential impact on Roma concretise and whether and how they contribute/are aligned with NRSF objectives (alone or in combination with ESF+). Alignment of ERDF with NRSF as well as combination between ESF+ and ERDF investments are areas for further progress in this period (Interfunds Committee could contribute to this). It is also positive that a greater number of programmes (ESF+ and ERDF) at Autonomous Communities' level specifically mention Roma and foresee actions (target or mainstream). Finally, RRFs are being used for different initiatives aimed at Roma (e.g. in innovation, minimum income, training-employment. SEE ALSO DOCUMENT ATTACHED
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Response to 2014-2020 Ex post evaluation of ESF and YEI

23 Jan 2024

ESI Funds, and especially ESF, have proven to be crucial instruments for addressing the situation of groups/people in situations of greater exclusion/vulnerability, such as the Roma. Characteristics such as duration, scale (in terms of budget, dimension & geographical coverage) make possible to design and implement interventions with a high potential for impact and social change. Furthermore, ESF allows for specific, tailored and sustained investment in the most vulnerable groups, promoting equal opportunities. Finally, it plays a key role at the policy level, by making it possible to implement and test interventions related to public policies not developed before. In this context, and in line with the feedback already provided through online questionnaire, Fundación Secretariado Gitano would like to stress certain factors that, based on our experience of more than 20 years implementing ESF programmes, are fundamental in promoting an effective and efficient use of the ESF, notably for vulnerable groups. 1. The importance of entrusting the management of funds/ implementation of actions to the actors best placed to design and implement interventions/projects with effectiveness and impact (whether public or private, national, regional or local). The wide geographical coverage and the specialisation of the actors are other relevant elements. In Spain, the participation of specialised CSOs in ESF management/implementation for vulnerable groups has proved to be decisive factor of success. This model should be maintained while ensuring the conditions for their involvement under best conditions for efficiency (e.g. payments, co-financing rates, administrative requirements...), see point 4. 2. The use of funds according to specific criteria that have been proven to achieve efficiency, effectiveness and impact, including: targeted focus on disadvantaged groups and methodological adaptations (e.g. a consistent methodology adapted to the profile of the target group, individualised pathways, integrated and comprehensive interventions...); large scale (dimension, budget, geographical coverage, with several localities/regions...), etc.; sustainability/long-term perspective of interventions/projects (throughout the programming period without interruption); focus on employment interventions, but also broadening the scope to include education and discrimination elements; flexibility to respond to changes in socio-economic context and lessons learned from implementation, and to introduce innovation; ability to scale up interventions that prove successful. 3. The relevance of complementarity of funds (ESF and ERDF as well as others) to address the significant and complex needs of vulnerable groups such as Roma, which require comprehensive, multidimensional and integrated actions across different fields (such as employment, education and training, health, housing or anti-discrimination, poverty or anti-discrimination) and involving different types of investments/expenditure, e.g. human resources, equipment, infrastructure... 4. Further progress in administrative arrangements to allow implementation under optimum conditions. Although progress has been made as reagards EU requirements, challenges remain such as: 1) Simplification, in many cases complexity lies in the fact that EU requirements have to be combined with those set by national/regional/local legislation/authorities, which are different and usually do not follow the same simplification approach; 2) Delays in payments, which oblige beneficiaries to advance funds over a long period and request loans with interests that are not eligible under the ESF; 3) Need for more clarity and homogeneity on co-financing, notably in national programmes (implemented in different regions) targeting disadvantaged groups. 5. ESF-funded projects with proven value based on evaluations: Acceder employment/training programme and Calí Programme for Roma women. See document attached for more details
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Meeting with Lívia Járóka (Member of the European Parliament)

30 Nov 2023 · 16th European Platform for Roma Inclusion

Response to Interim evaluation of the European Education Area

15 Sept 2023

At Fundación Secretariado Gitano (FSG) we welcome and assess positively the progress made towards the configuration of a European Education Area (EEA). The EEA has as first priority area the quality, equity, inclusion and success in education and training, which is an adequate approach to tackle discrimination and inequality still suffered by many vulnerable and socially excluded groups across Europe. However, the strategic framework towards the EEA lacks specific mentions to Roma, the largest minority group in Europe and one of the most discriminated against and in need of specific measures that improve their educational situation. Following EC's Communication "Progress towards the achievement of the European Education Area", actions seem to be developing in the right direction to reach the proposed objectives (decrease of early school leaving, the increase of young people with tertiary level qualifications; increase of participation in early childhood education). However, some structural problems persist, (as a high disengagement from the education system or a low performance in basic skills). The same Communication confirms that "socio-economic background is still the most important predictor of education outcomes. Considering these inputs, and focusing on vulnerable groups and/or at risk of social exclusion, data on the socio-economic level of Roma from FRAs Roma in 10 European Countries (2021) are highly worrying: -83% at risk of poverty -85% children (0-17 years) living at risk of poverty -45% severe material deprivation -48% children (0-17 years) living in households in severe material deprivation -21% household cannot afford to keep its home adequately warm Comparing the objectives set for the EEA with data on education from the aforementioned FRA survey, it is clear that the reality of the Roma community is far, not only from the objectives set, but also from the reality experienced by the general European population: By 2030, at least 96% of children between 3 years old and the starting age for compulsory primary education should participate in early childhood education and care. The latest overall average for Europe is 93%. In contrast, only 38% of Roma in this age group attend pre-primary education. By 2030, the share of early leavers from education and training should be less than 9%. The most recent European average is 9.7%. The figure for Roma aged 18-24 is 70% of early leavers from education or training. Other data from the FRA report, clearly indicate that the situation of Roma in terms of education and training is significantly worse than that of the majority of society, keeping them far away from the rest of the objectives proposed for the EEA (more related to post-compulsory studies, lifelong learning, general performance in studies and ICT performance): -45% of Roma children aged 6-15 years attend schools where all or most of schoolmates are Roma -28% had difficulties in accessing distance learning during COVID-19 -56% Roma aged 16-24 who are neither in employment, education or training (NEETs) -80% of Roma that achieved an educational level lower than upper secondary, vocational, post-secondary and short-cycle tertiary education (ISCED 3 to 5) These data show the high levels of educational inequality suffered by Roma children and highlight the need to include specific measures towards EEA objectives. Special attention should be paid to improving the general educational levels of Roma children and alleviating early school leaving, favouring equalisation with European average levels and with the objectives of the Area, eradicating the educational segregation particularly suffered by Roma, and to favouring proposals that enable Roma students to access educational resources (including technological and digital). The European Social Fund+ and the Child Guarantee offer the proper framework and opportunities for Member States to articulate measures to fight against inequality education of Roma children.
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Response to Boosting European learning mobility for all

28 Apr 2023

Learning mobility has come to be a highly valuable stage in education and training pathways, providing skills, knowledge, values, network and more to the young people that experience it. Policies, initiatives and projects on learning mobility should deeply consider the particular situation of vulnerable and socially excluded people (where the Roma community is usually overrepresented) and design the calls in an inclusive and comprehensive way. According to data from our soon to be published study The educational situation of Roma students in Spain and from the "Comparative study on the situation of the Roma population in Spain in relation to employment and poverty" (FSG, 2018), regarding young Roma: - 63% (16-29) are NEETs (compared to 15% in the general population) - The net enrolment rate for those between 16 and 24 is 15.9% (compared to 63.3%) - 17% have finished compulsory secondary education (compared to 80%) - The school dropout rate (people between 16 and 24 who have not graduated from compulsory secondary education) is 68.2% compared to 4% - At the end of the secondary compulsory education, only 14.3% continue their studies (compared to 71.2%) - The employment rate is 30%, being 47% of workers self-employed - 86% of Roma are at risk of poverty - Gender gap: Roma women show worse results than Roma men and that non-Roma women in every area FRAs Roma survey 2021 provides similar data in different European countries. Considering this data and the experience in our programmes, from FSG, we believe that learning mobility should reinforce the following aspects: - Accompaniment to students belonging to socially excluded groups to facilitate the sensitisation/motivation, the application process, documentation processing and guidance and support in the process of the experience. In our experience we find higher lack of autonomy and independence in such young people. Without proper motivation and accompaniment socially excluded youngsters may not take part (or drop out) of the programmes. - Language learning, both before and during the experience. - Sufficient financial provision even for the student not to be a burden on the family. In the case of students at post-compulsory levels, sometimes the family demands that them to enter the world of work so that they can contribute to the family economy. From our point of view, and by way of example, in the FSG Luis Sáez Scholarship project aimed at Roma women students at the university, items related to housing (including family housing), pocket money and other concepts are contemplated to replace a possible economic contribution that these students could make to their families if they were working. Continuing their studies should not have an economic impact on the family and continuity should be facilitated as much as possible through sufficient financial provision. - Mobility pathways of different lengths. Shorter pathways are very useful as a contact point for later participation in longer pathways, which the most vulnerable people tend to demand more. - Consider a wide range of possible experiences: work, knowledge of policies (e.g. educational policies), cultural, participation, etc. Add to these points, when focusing on learning mobility opportunities for young people in employment, we find that there should be: - A clear support for companies that collaborate in the mobility initiatives, to facilitate the incorporation of vulnerable trainees, who can start from lower levels of skills, need longer learning periods and more intensive mentoring and monitoring. - Clarity and flexibility in the legislative frameworks for traineeships of the different countries involved, to make it possible for students to undertake traineeships in companies without necessarily having to be linked to a formal training curriculum. Making it easier for companies to take on people who are on an ad hoc training pathway that is flexible and built around the needs and circumstances of the individuals.
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Response to Draft Commission Delegated Regulation on the provision of EU-wide multimodal travel information services

2 Dec 2022

The Fundación Secretariado Gitano (FSG) is an intercultural social organisation which has been working for 40 years for the overall advancement of the Roma community, with a focus on cultural diversity. It delivers projects and services to reduce social inequalities and to defend the rights of Roma people, mainly in the fields of employment, education, health and housing. It also aims to promote more active policies for the social inclusion of the Roma population, to fight discrimination and to achieve equal opportunities in Spain and across Europe. https://www.gitanos.org/ FSG considers the Recovery and Resilience Facility (RRF) a key instrument to support the recovery after the covid-19 pandemic and to make this recovery highly inclusive. However, considering the development of this initiative so far and the situation of poverty and discrimination of the Roma community that still remains across Europe, we would like to share some inputs and recommendations: - The preparation and design of the plans and projects under NextGeneration EU funding should also include civil society actors in a more transparent way. Our experience in Spain is that this process lacked a more proactive approach to count with the participation of these civil society stakeholders, which are essential to bring knowledge on the reality of the living conditions of vulnerable and socially excluded people, such as the Roma, to the design and/or implementation of projects on-the-ground. -As it is also the case for EU Cohesion Funds, there should be a formalised structure for dialogue, follow up and monitoring of the design and implementation of RRF at national level where all relevant stakeholders can participate. So far, only social partners have been included in this dialogue, while in the RRF regulation it stresses the need to involve also civil society. - Explicit mention to social exclusion must be added to the national recovery and resilience plans. Usually, when these plans refer to the category of vulnerable people, they tend not to include those persons that suffer from social exclusion, who end-up out of the scope of implemented activities. We would like to call the attention to the need to explicitly mention the socially excluded people to avoid this gap (e.g., people living in deprived/segregated spaces, without access to electricity or water, children living in extreme poverty and attending segregated schools, etc.). This explicit mention is a must to target the problems and to assure the provision of resources to tackle them. - Concrete operative description of the concept leave no one behind would be needed in order to make this motto operational. Investments around the social component of the national recovery and resilient national plans are necessary but should not limit how these funding instruments and reforms serve to tackle poverty and social exclusion. In this regard, there should be further straightforward synergies and coherence with the other investment components, namely, the digital and green ones. Leaving no one behind should be understood and operationalised as a cross-cutting question in every component. In the innovative and green plans and projects, there should be explicit opportunities described for vulnerable and socially excluded people to be able to take advantage of the training and employment opportunities, for example, in the form of social clauses. - Long-term perspective and continuity in the plans. In Spain, for example, a specific project funding inclusion pathways for people receiving the Minimum Income is planned only for the short term (1 year) and with unclear continuity. In our experience in employment, education and social inclusion programmes, significative deep transformation that really changes the lives of vulnerable and socially excluded people demands long-term interventions.
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Response to Developing social economy framework conditions

30 Sept 2022

Fundación Secretariado Gitano (FSG) is an intercultural social non-profit organisation that provides services for the development of the Roma community in Spain and in Europe. The mission of the FSG is the integral promotion of the Roma community on the basis of respect and support for their cultural identity. Regarding social economy, in Spain the model of Work Integration Social Enterprises (WISEs) is of special interest to improve the social inclusion of the Roma community. We understand a WISE as a limited company whose main objective is to foster the inclusion of vulnerable people into the labour market through the development of sheltered employment as a transition to the ordinary (or "unprotected") labour market. Given their social value, it should be public authorities who value most the goods and services produced by WISEs. In addition, WISEs generate an important social and economic return to the administration in the form of savings in social benefits, minimum income, tax payments. Despite being formulas specially designed to facilitate the labour market inclusion of groups in situations of exclusion, in Spain the Roma population is hardly benefiting from them. There is a clear need for compensatory and support measures to facilitate the access of Roma to WISEs, especially taking into account the high levels of discrimination suffered by Roma. In Spain, only 3 WISEs, promoted by FSG (Nabut, Vedelar and Uzipen), specifically (although not exclusively) offer inclusion pathways addressed to Roma . Since 2008 360 people have obtained a sheltered job in these companies. However, beyond the impact that this may have within the geographical or operational scope of the company, it is necessary for Roma to be able to access sheltered employment in general to the same extent and under the same conditions as other vulnerable groups. Considering the experience of FSG in this area, a series of recommendations are set out below: The adoption and implementation of the European Commission’s social economy action plan, which should include a specific section defining the diverse models existing in the social economy. The establishment of proper mechanisms to assure that these opportunities reach Roma, supporting the Member states and companies to hire a quota of people in social exclusion. Support mechanisms for contracting WISEs. Due to the social objective of these companies, they are usually not so competitive as other companies in their environments. In this sense, when WISEs compete in the open market, it can happen that they are expelled of it. Public authorities should promote the contracts with WISEs in their tenders and encourage the companies they contract to use the services of WISEs when subcontracting. This “market reserve” should contemplate the differences between the diverse models of social economy, to assure that the WISEs have opportunities to provide their services not having to take on larger more competitive social companies. E.g., in Spain the Special Employment Centres are bigger more established social companies with better chances to win tenders if the kind of social economy company is not specified. Direct support mechanisms in the form of subsidies and grants to WISEs should be implemented, for these companies to be able to focus on their social targets and in the delivery of their services without the pressure of being as highly competitive in the market as other companies which only need to focus on their economic objectives. These direct mechanisms should also facilitate the creation of new social economy companies, not only supporting the already existing ones. In this sense, public authorities should support the new companies assuring the training resources for the workers and providing a business quota to start, avoiding this way that the company needs to compete in the open market from the beginning. Specific actions must be planned to promote the creation of social companies that include Roma.
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Response to Improving the provision of digital skills in education and training

16 Sept 2022

Considering the FSG’s experience on the assessment and training of skills with vulnerable groups, and especially with Roma people, we consider that the European Digital Competence Framework (DigComp) includes not the actual skills levels of many people without digital literacy or without the resources that the framework implicitly contemplates. In this sense, we believe that the DigComp could be more inclusive, and include lower initial levels of skills. Therefore, when developing the digital skills of this type of low-skilled people, longer training pathways must be designed, to be able to reach adequate levels of digital skills. The relation between the digital skills and other basic skills should also be contemplated in the designing of the DigComp and any other initiative involving digital education. Some basic skills (such as communication or basic math) that may be taken for granted are not always present in people with lower levels of skills, becoming an obstacle to the acquisition of the digital skills. The contents and skills included in the digital education must contemplate the gender perspective, the cultural diversity and a human rights approach. Contents and competencies on protection data must also be included in a specific manner, as well as those related to digital health and safe use of the technology, particularly, the privacy, the use of social media, time spent online, etc. In the case of young people, they can be considered to be digital natives and that they are fully aware of these questions, but in fact, many digital natives are not necessarily digital literates. This aspect affects particularly families who have not the resources to coach and monitor the activities of their children online. The digital transformation must include the proper accompaniment, understood from a two-fold perspective: - The teachers and trainers must be comprehensively trained and up-skilled to assure that they can carry out the activities foreseen in a digital education ecosystem. The present level of digital skills is not enough to meet the demands of the digital world and of the students. Besides, this particular digital training must be included organically in the academic curriculum and must make a special emphasis on the pedagogic needs of the most vulnerable groups, including the Roma. In this sense, we perceive a lack of investment in actual change management that accompanies the incorporation of technology in the education, being in many occasions the civil society which must serve as an intermediary in new processes that involve the use of digital tools (e.g., to support the families filling in digital forms). - Vulnerable people, such as the Roma, usually need specific accompaniment, due to the multiple education (and others) divide that they suffer. In this sense, before the proliferation of digital and online spaces, these students and trainees might benefit from hybrid proposals that support them with face-to-face solutions in the digital world. Besides, due to the stated limited access to the needed technological tools and connectivity, the acquisition of equipment (specially laptops) and the connectivity to the internet should be funded to facilitate the access of families to the technology.
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Response to Enabling factors for digital education

16 Sept 2022

Roma people live in a situation of vulnerability and inequality prior to Covid-19. In our 2018 study we found that poverty and social exclusion affected more than 80% of Roma people, with 46% living in extreme poverty. The child poverty rate stood at 89%, with 51% in a situation of extreme poverty. Only 17% of Roma over the age of 16 have completed compulsory secondary education or higher education. Six our of ten Roma children do not finish compulsory secondary education. To understand the impact of Covid-19 on Roma in Spain, we carried out a telephone survey that showed that 1/3 of Roma children cannot carry out the learning tasks being set by their schools, in most cases because they lack the necessary equipment (58.8%) and/or access to educational materials (48.7%). Only 1/3 of children have access to a computer, and more than 40% of students do not have internet access or have limited data allowances. The tools, approaches and new possibilities offered by the digital word need to asure they reach out most vulnerable groups, instead of a creating new divide. Regarding contents of the digital education, a special effort must be made to assure the inclusion of the gender perspective, cultural diversity & human rights approach. Also contents related to digital health and safe use of the technology, contemplating the particular reality and context of vulnerable people and their surroundings. Digital transformation must include the proper accompaniment from a two-fold perspective: - Teachers/trainers must be comprehensively trained & up-skilled to assure they considering the pedagogic needs of the most vulnerable groups, such as Roma. There is a lack of investment in actual change management that accompanies the incorporation of technology in the education, being often NGOs the intermediaries (e.g., to support the families filling in digital forms, etc). - Vulnerable people, as Roma, usually need specific accompaniment, due to the multiple education (and others) divide. Due to limited access to the needed technological tools & connectivity, the acquisition of equipment (specially laptops) & connectivity to internet should be funded to facilitate access of the families to technology.
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Response to Recommendation on minimum income

1 Apr 2022

Fundación Secretariado Gitano very much welcomes the initiative for an EU Recommendation on the minimum income. We would like to provide some feedback in relation to how a regulation on the minimum income should better consider the specific situation and needs of the Roma population in the EU. The first step in this regard would be to include in the definition of the political context and problem definition, data about the situation of Roma , the largest ethnic minority in Europe with 12 million people who suffer from greatest levels of poverty and inequality gap: 80% of Roma are at risk of poverty rate (general population 16.8%, gap of 63.2 pps); 85% of Roma children are at risk of poverty (general population 19.6%, gap of 65.4 pps); 78% of Roma live in overcrowded households; 50% of Roma children face nutritional risk and exhibit inadequate child growth (41% of Roma children live in a household where at least one person in the household went to bed hungry at least once in a month). In this sense we believe there needs to be an accurate definition of the target group of “those in need” including and desegregating the specific situation of most disadvantaged groups such as Roma and migrants among others. Moreover, schemes providing minimum income should adapt the definition of potential beneficiary households taken into consideration the concept of extended families of Roma or migrants, where several family units live under one roof. Requisites for receiving minimum income should not exclude persons (family units) that live together in same households with parents/grandparents who receive pensions themselves, since otherwise, this blocks the access of Roma/migrants individuals living in impoverished household to minim incomes. Requisites for the minimum age of potential beneficiaries of minimum income should also be adapted and start at the age of 18 since may young Roma/ migrants start a family at an early age than the average of the population. As regards the efficiency in the implementation of the minimum income, the combination of income coverage and access to activation measures should be reinforced. Active measures need to be guaranteed as a mechanism to break the generational dependency circle where many persons (including Roma) are trapped. Educational and employment pathways need to be put in place, supported by individual accompaniment. In this processes, specialised NGO can play a crucial role in: assuring the outreach of most disadvantaged groups (Roma and migrants); providing direct and adapted information; providing support for the application process, facilitating the administrative procedures for accessing to and maintaining the minimum income (particularly important before ongoing entries and exits); in designing and implementing trainings and individual pathways. The application process of these minimum income for most disadvantaged groups is particularly complex and would need to be adapted since they lack basic and digital competences and often lack digital equipment and internet connectivity: support from NGO in this regard guarantees equal access to minimum income rights. There needs to be more flexibility to enter and exit from minimum income scheme and the capacity to combine it with salaried incomes without penalising or disincentivising those people with low incomes. In sum, a minimum income scheme should consider the specific situation and characteristics of the most disadvantaged groups across the EU (such as Roma and migrants) if it aims to be an effective tool to have an impact in eradicating poverty and social exclusion. NGO can certainly add value to achieving such an important social impact.
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Response to European Year of Youth (2022)

15 Dec 2021

La Fundación Secretariado Gitano es una ONG social e intercultural de ámbito estatal que trabaja desde hace casi 40 años por la igualdad de derechos y la inclusión social de la población gitana en España y en Europa que presta servicios a las personas gitanas, lucha contra la discriminación y aboga por políticas públicas más inclusivas por mejorar la imagen social de las personas gitanas, realiza campañas de sensibilización, etc. En los documentos marco europeos de políticas gitanas encontramos referencias significativas sobre los motivos para una inclusión de la juventud gitana en el Año Europeo de la Juventud. Por ejemplo, en la Recomendación del Consejo de 12 de marzo 2021 sobre la igualdad, la inclusión y la participación de la población gitana (2021/C 93/01) se indica que “Al hablar de la población gitana, es importante reconocer las necesidades o vulnerabilidades específicas de determinados grupos dentro de esa población, en particular las mujeres, la juventud, …”. También se explicita la importancia de “crear oportunidades y utilizar el potencial no aprovechado de la juventud gitana aumentando su participación activa en programas y las medidas dirigidas a la población juvenil”. Las personas gitanas son significativamente más jóvenes que la población mayoritaria. Según nuestro estudio sobre empleo y pobreza en la población gitana 2018*, “el 66% de la población es menor de 30 años, mientras que solo el 30% de la población general en España está por debajo de esa edad”. A falta de datos fiables similares a nivel europeo, cabe esperar cifras similares en toda Europa. Además, la situación de la juventud gitana, por comparación con la juventud europea mayoritaria, es de mayor precariedad. Según el informe de derechos fundamentales 2021 de la FRA** “la situación de las personas jóvenes es sustancialmente peor: de media, el 63% de las personas gitanas entre 16 y 24 años no están empleadas, ni estudian ni se están formando en el momento en que se realizó la encuesta, comparado con el 12% de media de ninis en Europa para el mismo grupo de edad”. La cuestión del género también parece relevante. Las jóvenes gitanas sufren una situación aún más precaria que la de los hombres gitanos: “para este grupo de edad, los resultados muestran una considerable brecha de género, con el 72% de las mujeres gitanas no empleadas, ni estudiando o formándose, comparado con el 55% de los hombres gitanos”. La juventud gitana es, en definitiva, más vulnerable, por lo que consideramos que deben dedicarse esfuerzos políticos y financieros específicos para mejorar su situación. También debe reforzarse esta mirada a la juventud gitana por el valor intrínseco que supone su aportación en términos de diversidad. Creemos que, para alcanzar un objetivo realmente rico e inclusivo en el Año Europeo de la Juventud, ha de potenciarse de manera explícita y proactiva la participación de todas las diversas voces que componen la heterogénea juventud europea, incluyendo a la juventud gitana, no simplemente declarando la importancia de la participación, sino estableciendo los cauces y facilitando los medios potenciar una participación diversa y significativa. Echamos en falta un mayor énfasis en la cuestión educativa relacionada con la juventud gitana. Siguiendo el informe de la FRA, “sólo la mitad aproximadamente (55%) de los y las niñas gitanas entre tres años y la edad de la escolarización obligatoria participan en educación temprana para la infancia... Casi dos tercios de la juventud gitana entre 18 y 24 años abandonaron la educación o la formación antes de completar la educación secundaria. Además, los niños y niñas gitanas frecuentemente sufren bulllying y acoso motivado por el odio mientras se encuentran en el colegio. La segregación escolar de la infancia gitana continúa siendo una preocupación”. * https://www.gitanos.org/actualidad/archivo/129382.html.en ** https://fra.europa.eu/en/publication/2021/fundamental-rights-report-2021
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Response to Evaluation of the Council Recommendation on Upskilling Pathways

8 Feb 2021

The employment situation of the Spanish Roma is characterised by low labour market inclusion, low employment rate (30% among Roma which is 20% lower than for the total population), a high unemployment rate (52%), great job insecurity and weak employment protection (large amount of self-employment and low quality of salaried work, with rates of temporary work standing at 70% and 16% of paid workers not having a contract). The lack of qualifications among the great majority of Roma entering the labour market explains the fact that they are concentrated in sectors with inferior employment protection and lower pay rates. More than 70% of unemployed Roma are in long-term unemployment while 35% are in a situation of very long-term unemployment. The Spanish situation can be very well translated into the overall European picture where data is even worse (see latest FRA’s report). The level of education is the main determinant of employment status and is therefore a determinant of the socioeconomic inequality suffered by the Roma. Only 17% of the Roma aged over 16 have completed compulsory secondary education or higher education compared with 80% of the general population. The Fundación Secretariado Gitano (FSG) is a Spanish intercultural NGO promoting equal rights and social inclusion of the Roma community for over 35 years, providing services in the field of education, employment, social inclusion and fight against discrimination, and advocating for more inclusive public policies and for improving the social image of Roma. It works at national, regional and local level (based in 70 localities) and also at European level. Since 2000 the FSG develops the employment programme Acceder that promotes the incorporation and inclusion of the Roma in the labour market as an open door to the social inclusion, through employment personalised pathways with an intercultural approach and special focus on the improvement of the participants’ skills, as well as fostering the partnership with key private companies. As part of the individualised employment pathways, an initial assessment on every participant´s skills is carried out, to be later compared with the skills demanded in the specific job that is the participant’s inclusion objective (the job-skills profiles are defined in close cooperation with companies). As a result of this comparison concrete skills are identified as those that should be improved, and they are developed through specific skills training and included in vocational training courses. This system was consolidated in the project Together for the Employment of the Most Vulnerable of Accenture Foundation. The specific investment from the ESF, that long-term projects like this demand, is key to develop a deep social impact and an actual change in the society. Based on our 20-year experience of personalised pathways with Roma and acknowledging the lack of projects focused on Roma as reflected in the 2019 document Taking stock of implementation measures, we believe that employment policies should increase the offer tailored solutions to improve the skills of adult Roma, in order to ensure their labour market inclusion. These solutions should pay special attention to the improvement of the adults’ digital skills and knowledge, since they are key in the present and future labour market. In order to develop these digital skills, the access to equipment and technology should be facilitated to the vulnerable, including the Roma, that usually have less access to them. A specific effort should be made to facilitate adult Roma to obtain the compulsory education, essential to get a job and continue their studies. A first and necessary step in this direction is to explicitly mention Roma adults and their specific situation/needs, to further establish the elements that should be considered in the drafting of Upskilling Pathways so that they become real new opportunities for all adults across Europe, including Roma.
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Meeting with Mónica Silvana González (Member of the European Parliament)

25 Jan 2021 · Diversidad

Response to Digital Education Action Plan

15 Jul 2020

The Fundación Secretariado Gitano (FSG) is an intercultural social organisation working for over 35 years for the advancement and equal opportunities of the Roma community in Spain and in the rest of Europe. The FSG intervenes in 83 locations in Spain and counts with 872 workers that have attended to more than 130.000 participants throughout its history. The situation of vulnerability and inequality affecting the Roma population was already alarming before the Covid-19 crisis. Based on a 2018 study, poverty and social exclusion affected more than 80% of Roma people, with 46% living in extreme poverty. The child poverty rate stood at 89%, with 51% in a situation of extreme poverty. In order to gather information about the home situations of our programme participants during Covid-19, we carried out a telephone survey (full in the annex document) aimed to gather objective evidence of the Roma families situation in Spain. The results of this survey show the difficulties of Roma families to cover basic necessities (40% of the participants experience difficulty in accessing food), that the situation of two thirds of Roma people in paid employment has worsened and 97% of the street vendors are unable to continue their activity during the crisis, and that one third of Roma children cannot carry out the learning tasks being set by their schools, in most cases because they lack the necessary equipment (58.8%) and/or access to educational materials (48.7%). Only a third of children participating in our educational programmes have access to a computer, and more than 40% of students do not have internet access or have limited data allowances. Considering this information and the experience gathered in the intervention delivered by our teams during the Covid-19 crisis, we find there are deficiencies in the access of Roma people to the opportunities of the digital world and in their possibilities of developing full citizenship. We consider that special focus should be made in the areas of education and employment in the following aspects: Low level of digital skills for personal, educational and professional life: although many Roma people (including youngsters) are able to use a digital mobile phone, they are not literate in the use of the technology for educational or professional purposes. Many Roma children have serious difficulties to navigate through the digital contents since they lack the skills to really understand the cloud, the use of the e-mail, the search for information in the digital world, etc. The increasing digitalisation of the work is also a barrier for the Roma population, since they lack the basic skills to manage their job profiles in the labour market but also specific digital skills to relate with companies and to have the opportunity to access more qualified jobs (including the IT sector). Limited access to the needed technological tools and connectivity: the technology to which Roma people have access to is usually a mobile phone, usually with low connectivity. To be efficient in the world of work and education, and to access all opportunities in equal conditions, it is clearly an insufficient tool. In order to assure the access of every Roma child to technology, the acquisition of equipment should be funded, specially laptops, since tablets and other mobile choices are not usually enough for the kind of tasks required in online platforms. The connectivity to internet should also be facilitated to the families to be able to access contents. Low adaptation of digital resources to the reality of vulnerable people: many Roma people need accompaniment and adjustments in their access and use of educational and labour purposes. Roma children usually need help to carry out learning tasks. Online platforms and learning spaces need to reinforce the mechanisms to facilitate this help. The best performance of the most vulnerable should be assured also through the balance between the online & offline.
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Response to Multiannual Financial Framework – European Social Fund Plus (ESF+)

2 Aug 2018

EURoma (European Network on Roma inclusion under ESI Funds) welcomes progress made in the current proposal and the opportunities created to advance Roma equality. We are particularly satisfied with the presence of a specific objective and a common input indicator on Roma. We welcome the alignment with the European Pillar of Social rights and the European Semester and the use of CSR as a key tool for guiding ESF+ investments, as well as the establishment of enabling conditions that have to be fulfilled throughout the whole programming period. Here is an outline of EURoma´s main recommendations: • EU Funds’ investments need to be also fully aligned with national mainstream policies and legislation and also with National Roma Integration Strategies. • ESF+ should concentrate and intensify large-scale/long-term support investments at national/regional level as a requisite for prompting policies aiming to achieve social change, particularly in the case of Roma. • ESF+ Regulation should also make a specific mention to mobile EU Roma citizens. • Roma need to be explicitly targeted and also mainstreamed through all ESF+ investments. E.g. The 10% ESF+ thematic concentration to support youth employment in the context of the Youth Guarantee needs to ensure young Roma are included. • While the ESF + Regulation proposal advances in the promotion of the integrated approach by including a range of thematic priorities, the architecture in different fund strands does not seem to contribute to the implementation of an integrated approach on the ground. The management of different strands and/or with other funds appears to be a complex process which would need to be eased so that a combination of actions can be jointly developed. • The expected complementarities with other funds can also contribute to facilitating, for example, the much-needed integrated approach for Roma inclusion (mainly with ERDF in relation to housing), but also access of young Roma to the digital world and to gaining new skills and increase the quality of their education and training (mainly through Erasmus and Digital Europe Programmes). • While discrimination on different basis, including ethnic origin, is mentioned several times throughout the Regulation, further emphasis on how such horizontal criteria will be operated should be given. Unless the Regulations specifically lay down the requirement to establish specific measures (and eligible actions such as those related to the support of victims, litigation etc…), and indicators to measure advancements regarding horizontal criteria, the impact will be very limited. • The link between all EU funding and fundamental rights should be reinforced by linking rights with policies and overall EU funding, beyond ESF+. • Increase to 30% of the ESF+ earmarked for social inclusion and tackling poverty. • Searching for innovative solutions to deeply-rooted exclusion and discrimination should be a core concern of innovative actions within ESF+. Explicit mention to the focus on particularly disadvantaged groups such as Roma should be included as a way to ensure they are not excluded. • There should be a stronger emphasis on the need to establish mechanisms to upscale and give continuity to innovative initiatives that have been proven effective. • Activation of transnational cooperation as a key tool for social innovation. • A revision of the Regulation proposed indicators should be done as an exercise to better match main ESF+ priorities and expected results and outcomes. • The effective implementation of the partnership principle should be advanced throughout the ESF+ programming period. • The European Commission should have a stronger supervisory role to ensure the values underlying the Regulations are respected on the ground. Please read the full contribution attached
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