Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the European Education and Culture Executive Agency (EACEA). Neither the European Union nor EACEA can be held responsible for them.
Due to its private-sector focused approach, the Global Gateway contradicts the development narrative initially promoted by the European institutions and breaches the NDICI-GE Regulation within which it is embedded. This policy paper argues that the profits accrued by European companies, the lack of investments in key development sectors in beneficiary countries, the limited volume of grants and the growing use of export credit facilities within the framework of the initiative turn it into a vehicle for advancing trade and commercial interests rather than a genuine development policy. Key recommendations include the official framing of the Global Gateway as a trade policy rather than a development finance initiative, the establishment of a specific unit in DG Trade upholding the EU principles of subsidiarity, the creation of EU export credit facility dedicated for the Global Gateway, the reinforcement of the mutual and industrial partnerships and a revision of the Export Credit Regulation 1233/20111.
1 European Parliament and the Council of the European Union, ‘Regulation (EU) No 1233/2011 of the European Parliament and of the Council of 16 November 2011 on the Application of Certain Guidelines in the Field of Officially Supported Export Credits and Repealing Council Decisions 2001/76/EC and 2001/77/EC’ <https://eur-lex.europa.eu/eli/reg/2011/1233/oj/eng>.
NatoliN Policy PaPers series
Unpacking the Global Gateway’s financial structure: a critical look at the development logic by Gracia María Pérez Vico & Thomas Pelletier
Bibliography table of coNteNts
Executive Summary
List of Abbreviations
Introduction Problem Description Policy options
Conclusion and recommendations
Unpacking the Global Gateway’s financial structure: a critical look at the development logic
BRI: Belt and Road Initiative (BRI)
DFIs: Development Finance Institutions
DG Trade: Directorate-General for Trade
DG INTPA: Directorate-General for International Partnerships
EAG: External Action Guarantee
WTO: World Trade Organization list of abbreviatioNs
ECA: European Court of Auditors
ECAs: Export Credit Agencies
EFSD+: European Fund for Sustainable Development Funds Plus
EIB: European Investment Bank
EIF: European Investment Fund
EU: European Union
HR/VP: High Representative of the Union for Foreign Affairs and Security Policy/Vice-President of the European Commission
IFIs: International Finance Institutions
MFF: Multiannual financial framework
NDICI-GE: Neighbourhood, Development and International Cooperation Instrument - Global Europe
ODA: Official Development Assistance
oECD: organisation for Economic Cooperation and Development
SDGs: Sustainable Development Goals
SME: Small and medium-sized enterprises
The Global Gateway, a global infrastructure strategy launched by the European Union (EU) in 2021, was designed as a response to China’s Belt and Road Initiative (BRI), with the aim of asserting the EU’s influence in global infrastructure development and fostering sustainable growth. However, despite ambitious goals, the Global Gateway has faced a considerable amount of criticism since its inception, with concerns spanning across various dimensions of its design and implementation. Among the key criticisms is the relatively modest amount of funding earmarked for the initiative, which stands at €300 billion2 in comparison to China’s BRI, which has within ten years mobilised over $1 trillion3. This contrast in financial commitment has raised questions about whether the EU’s strategy can effectively match up to China’s far more substantial infrastructure investments.
However, beyond the issue of funding, a fundamental critique of the Global Gateway revolves around its financial structure, which some argue is inherently contradictory to its stated developmental objectives, since it is financially based on the Neighbourhood, Development and International Cooperation Instrument - Global Europe (NDICI-GE) and operationally on the Team Europe approach4. Critics point out that the financing model, which relies mostly on guarantees, blended finance and concessional loans, could place additional financial burdens on already highly indebted poor countries rather than offer them sustainable, grant-based support5. Additionally, there is growing concern over the lack of transparency regarding how funds are allocated, leading to accusations of insufficient oversight and accountability in the management of the initiative6.
In the contexts of the rising economic competition with China, Trump administration’s turn to protectionism and, at the EU level, the publication of the Draghi report and the preparations of the next EU’s Multiannual financial framework (MFF), this policy paper aims at unpacking the financial structure of the Global Gateway in order to make recommendations for its improvement. The paper comprises three parts: the description of the main problem, policy options, and conclusions and recommendations addressed to the European Commission, specifically
2 Ricart, Raquel Jorge and Otero-Iglesias, Miguel, ‘The Global Gateway: It’s Not the Money, It’s the Strategy’ (Elcano Royal Institute, 9 February 2022) <https://www.realinstitutoelcano.org/en/commentaries/ the-global-gateway-its-not-the-money-its-the-strategy/> accessed 23 October 2025.
3 Christoph Nedopil Wang, ‘China Belt and Road Initiative (BRI) Investment Report 2023 – Green Finance & Development Center’ (5 February 2024) <https://greenfdc.org/china-belt-and-road-initiative-bri-investment-report-2023/> accessed 23 October 2025.
4 Alexandra Geramsimcikova and Farwa Sial, ‘Who Profits from the Global Gateway? The EU’s New Strategy for Development Cooperation’ (2024) <https://counter-balance.org/uploads/files/GG-report.pdf>.
5 Øygunn Sundsbø Brynildsen, European Network on Debt and Development (2025) <https://www.eca-watch. org/publications/exporting-goods-or-exporting-debts>.
6 Geramsimcikova and Sial (n 4).
to DG Trade and DG INTPA. The main recommendation of the paper is the official framing of the Global Gateway as a trade policy rather than a development finance initiative. In other words, Draghi in his report proposed to move the scope of the Global Gateway from promoting “investment in third countries” to prioritizing “EU’s strategic needs and developing joint strategies with other buyers from strategically aligned countries”. This implies a shift from a purely development-oriented logic toward a more interest-driven approach, aligning infrastructure investments with the EU’s geopolitical and economic objectives. It signals a clear intention to use the Global Gateway not just as a tool for partnership, but as a means to strengthen the EU’s global positioning in an increasingly competitive environment.
ProBLEM DESCrIPtIoN
The main problem of the Global Gateway lies in its financial structure that runs counter legal and rhetorical narratives about its developmental objectives. In 2021, the European institutions presented the initiative as development-focused by embedding it legally within the scope of the NDICI-GE, the EU’s main financial instrument dedicated to global development, neighbourhood policy and international partnerships. The programme should in this regard respect the NDICI-GE Regulation, which states that “the primary objective of the Union’s development cooperation policy, (…) is the reduction and, in the long term, the eradication of poverty”7, and the realisation of the Sustainable Development Goals (SDGs) as defined in the 2030 Agenda for Sustainable Development. More precisely, the financial arm of NDICI-GE and the Global Gateway, the European Fund for Sustainable Development Funds Plus (EFSD+), is supposed to contribute to the SDGs. However, several findings counter this narrative of the Global Gateway to be genuinely focused on development.
First, a 2024 study by Counter Balance and Eurodad has found that big European companies – such as Siemens or SUEZ – make profits out of the Global Gateway’s developmental funds8. Similarly, the December 2024 opinion of the European Court of Auditors (ECA) on the evaluation of the EU External Action Guarantee (EAG) echoes these concerns. The ECA has indeed questioned whether the EFSD+ pays sufficient attention
7 European Parliament and EU Council, ‘Regulation (EU) 2021/947 of the European Parliament and of the Council of 9 June 2021 Establishing the Neighbourhood, Development and International Cooperation Instrument’ <https://enlargement.ec.europa.eu/regulation-eu-2021947-european-parliament-and-council-9-june-2021-establishing-neighbourhood-0_en>. 8 Geramsimcikova and Sial (n 4).
to least developed countries9. Seen as riskier to invest in, these countries attract relatively less profits-oriented European companies.
On the other hand, Counter Balance and Eurodad highlight the risks of debt imposition, corporate land appropriation, and the decline of skilled jobs in the Global South, thus raising concerns of a neocolonial approach, where rich countries and their companies benefit from resources and profits at the expense of local development10. The presence of big polluting companies from larger European countries with a colonial past (such as the French Total Energies or the Italian Enel) is also reflected in the composition of the Business Advisory Group of the Global Gateway, whose goal “is to assist the European Commission to strengthen cooperation on Global Gateway strategy and implementation with the European private sector”11. This reinforces both the neo-colonial narrative against the EU in its external action as well as the unfair competition among the EU Member States due to the lack of presence of smaller and medium-sized enterprises (SME) from a more diverse range of EU countries12. While their presence in the Group alone does not constitute definitive proof of a postcolonial approach, it reflects broader structural trends in which larger Western European corporations disproportionately benefit from the initiative. Such dynamics fuel external perceptions of neo-colonialism, such as for the Lobito Corridor project, advancing primarily the strategic and economic interests of the EU over uncertain added value for the local population13. Internal asymmetries are also reinforced in the process, as SMEs from smaller or newer EU member states often lack the capacity or access needed to compete on equal terms14
Moreover, the report revealed that, as a result of the profits-oriented approach of the companies, only 16 percent of all Global Gateway projects in 2023-2024 supported key development sectors like health, education and research, while 49% focused on climate and energy, 22% on transport, and 13% on digital. This further the risks of violating the NDICI-GE Regulation. Indeed, while the initiative may operate across a broad range of areas, this disproportionately low investment in foundational social sectors raises concerns about its alignment with the
9 European Court of Auditors, ‘EU Auditors Give Their Opinion on the Evaluation of the External Action Guarantee’ (Official Website of the european Union, 12 December 2024) <http://www.eca.europa.eu/en/news/ news-op-2024-03> accessed 23 October 2025.
10 Geramsimcikova and Sial (n 4).
11 European Commission, ‘Global Gateway Business Advisory Group - International Partnerships’ <https:// international-partnerships.ec.europa.eu/policies/global-gateway/governance/global-gateway-business-advisory-group_en> accessed 24 March 2025.
12 Geramsimcikova and Sial (n 4).
13 ibid.
14 European Entrepreneurs CEA-PME, ‘SMEs as Part of the Global Gateway Strategy: A Position Paper of the European Entrepreneurs CEA-PME’ <https://www.european-entrepreneurs.org/position-paper-smesas-part-of-the-global-gateway-strategy/>.
NDICI-GE Regulation’s core development mandate. Rather than placing human development and capacity-building at the centre, the initiative appears to prioritize sectors – such as energy, digital infrastructure, and transport – where EU companies hold strong commercial interests. This sectoral skew shifts the focus away from partner countries’ long-term development needs and toward advancing the EU’s own economic agenda.
Furthermore, out of all the €300 billion spendings planned under the Global Gateway, only 18 billion are grants. The remainder are guarantees and loans, meaning that the country’s beneficiaries will have to pay off their debts, whereas it has been proved that most of them are already highly indebted15. While financial instruments like loans and guarantees can form part of a legitimate development finance strategy, their developmental value depends heavily on concessionality, risk-sharing, and how burdensome the repayment terms are for the recipient countries. If many of the countries targeted by the initiative already face high levels of debt distress, it raises concerns that these mechanisms could exacerbate their financial vulnerabilities rather than support sustainable development. This displays the lack of will of the Member States and the EU to contribute to developmental funds as understood as money including direct transfers without contributing to the beneficiaries’ debt burden.
The export credit facilities, the financial mechanism increasingly put forward by the European institutions for the Global Gateway to “de-risk investments”, contribute to the consolidating trend of financialisation of the development policy16, where private-sector instruments overshadow traditional development aid. A key role in this is played by the 25 national Export Credit Agencies (ECAs), which operate under the framework of the EU’s EAG, as these agencies support large-scale infrastructure and energy projects, typically by providing loans and guarantees to facilitate access of its businesses to overseas markets. Their explicit role is the promotion of national commercial interests, and the European Commission has found out that they increasingly shift from merely offering trade facilitation to actively promoting trade creation and investment17. Moreover, the 25 ECAs across the EU operate under different national standards providing weaker or inconsistent financial guarantees compared to their counterparts in countries like China or the US. As a result, EU companies may struggle to compete for international contracts, particularly
15 Geramsimcikova and Sial (n 4).
16 Luis Mah, ‘The Financialization of EU Development Policy: Blended Finance and Strategic Interests (2007–2020)’, Financializations of Development: Global Games and Local Experiments (1st edn, Routledge 2023) <https://www.taylorfrancis.com/books/9781003039679> accessed 23 October 2025.
17 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP), ‘Joint Staff Working Document: Main Outcomes of the Mapping of External Financial Tools of the EU’ in Wessel Ramses A (2023) <https://data.consilium.europa.eu/doc/document/ST-8157-2023-INIT/ en/pdf> accessed 23 October 2025.
in high-risk markets, putting them at a disadvantage globally18 . In this context, Gerasimcikova urged the ECAs to have “no role” within development finance as for the majority of them their “current accountability, transparency and due diligence policies are insufficient, allowing for human rights violations, environmental damages and negative impacts on livelihoods of local communities”19.
In addition, the EU has pledged in 2021 that at least 93% of the NDICIGE should be reportable as Official Development Assistance (ODA) as part of its international commitment to the Organisation for Economic Co-operation and Development (OECD) 20. Given that the Global Gateway is embedded within the NDICI-GE, this implies that non-developmental funds are being counted as ODA, thereby crowding out the mobilisation of genuinely developmental funds. In practice, this means that the vast majority of the EU’s external financial support should directly contribute to economic development and welfare improvements in partner countries, primarily through grants or highly concessional loans. The ODA classification is meant to ensure development objectives take precedence over purely commercial or geopolitical goals. However, the increasing reliance on non-grant instruments such as export credit guarantees and blended finance mechanisms under the Global Gateway raises concerns about whether the initiative still aligns with this target in substance, even if it does so formally. This tension underscores the ambiguity between the EU’s development commitments and its economic interests abroad. This, in turn, illustrates the lack of political will on the EU’s part to truly prioritise and mobilise development finance.
Finally, the Global Gateway’s limited success in mobilising investment highlights the mismatch between its development narrative and its actual structure and objectives. As of the end of 2023, only around €8 billion in investment operations had been signed under the initiative21, far below the €300 billion planned initially. While this figure also pales in comparison to China’s Belt and Road Initiative, whose cumulative commitments exceeded $1 trillion by 202322, the issue lies less in the volume itself but more in the ambiguous nature of the policy. The slow rollout of Global Gateway instruments, as illustrated by the delayed delivery of the first EFSD+ guarantee in Latin America and the Caribbean
18 European Commission, ‘Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions: A Green Deal Industrial Plan for the Net-Zero Age’ (2023) COM (2023) 62 final <https://eurlex.europa.eu/legal-content/EN/TXT/? uri=CELEX%3A52023DC0062>.
19 Alexandra Gerasimcikova, Marius Troost and Chiara Casati, ‘No Role for Export Credits in the EU’s Development Finance’ [2024] Counter Balance 3.
20 European Commission, ‘Factsheet: Neighbourhood, Development and International Cooperation Instrument (NDICI) – “Global Europe”’ (2021) <https://international-partnerships.ec.europa.eu/system/ files/2021-07/factsheet-global-europe-ndici-june-2021_en.pdf>.
21 European Court of Auditors (n 9).
22 Wang (n 3).
in December 202423, undermines both its impact and visibility. This inefficiency suggests that continuing to present the initiative as a development tool is counterproductive. Instead, the EU should acknowledge Global Gateway’s de facto trade-oriented logic and officially reframe it as an economic strategy, one focused on promoting European competitiveness abroad while maintaining responsible engagement with partner countries.
Policy oPtioNs
Draghi report mentions the Global Gateway as a trade-focused strategy in a paragraph that describes its vision of a decarbonised and competitive EU trade policy. He depicts it as a way of leveraging the necessary investment for “establishing industrial partnerships with third countries in the form of offtake agreement across the supply chain or co-investment in manufacturing projects” 24. Moreover, Draghi proposes to move the scope of the Global Gateway from promoting “investment in third countries” to prioritizing “EU’s strategic needs and developing joint strategies with other buyers from strategically aligned countries”25 These allusions to the character of the Global Gateway are different from the developmental nature described in the Joint Communication of 2021 and reflect the need for a formal redefinition of the strategy itself.
Reflecting the interest in improving the EU’s competitiveness, export credit support within the EU has been specifically outlined in the Council Conclusions on “A Globally Connected Europe” and the Joint Communication on Global Gateway 26. The European Commission (2023) proposed the creation of “an export credits strategy including an EU export credit facility and enhanced coordination of EU financial tools”27 to improve the coherence of EU policies that focus on funding infrastructure projects that support the transition to net-zero emissions like the Global Gateway. The EU export credit facility is envisaged to complement existing national export credit schemes and strengthen the EU’s capacity in this field. This initiative aims to provide a fairer competitive environment for EU companies operating in international markets, where they often face foreign competitors benefiting
23 Press and information team of the Delegation to ECUADOR, ‘Global Gateway: The European Union Delivers the First EFSD+ Guarantee in Latin America and the Caribbean | EEAS’ (Delegation of the European Union to Ecuador, December 2024) <https://www.eeas.europa.eu/delegations/ecuador/global-gateway-european-union-delivers-first-efsd-guarantee-latin-america-and-caribbean_en?s=161> accessed 23 October 2025.
24 Draghi, Mario (ed), The Future of European Competitiveness: Part A: A Competitiveness Strategy for Europe (Publications Office 2025) 52 <https://commission.europa.eu/document/97e481fd-2dc3-412d-be4cf152a8232961_en>.
25 ibid 58.
26 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17).
27 ibid.
from substantial government support. By doing so, the facility would enhance their ability to engage in infrastructure projects abroad28
An example that could serve as a precedent in the development of this EU export credit facility could be the Ukraine Export Credit Facility announced by the European Commission and the European Investment Bank (EIB) in June 2024. With this facility, the European Investment Fund (EIF) can now leverage the InvestEU programme to assist European SMEs in exporting goods and services to Ukraine29. EIB President Nadia Calviño emphasized that this initiative will help mitigate risks for EU exporters while providing essential supplies such as materials, machinery, and technology to support Ukraine’s resilience and reconstruction.
As for the above-mentioned enhanced coordination, the Council conclusions on export credits highlighted the valuable expertise and crucial role of national ECAs in leveraging private capital and engaging key stakeholders essential for the effective implementation of the Global Gateway30. The enhanced coordination aims to improve information exchange and collaboration between national ECAs, participating EU institutions, and potentially private stakeholders to facilitate better alignment of projects with key EU policy objectives31. In this context, as previously mentioned, the Global Gateway Business Advisory Group was created in September 2023 to support the European Commission in enhancing collaboration with the European private sector and maximising the effectiveness of Global Gateway investments by incorporating business insights in a structured manner32
Even though member states already have mechanisms to enhance coordination between ECAs33, such as co-insurance and reinsurance agreements, further harmonization of practices—through “a standard reinsurance agreement, a common definition of European content, or the promotion of credit insurance market solutions”34—could improve
28 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP), ‘Joint Communication to the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank The Global Gateway’ in Wessel Ramses A (2021) 9 <https://www.eeas.europa.eu/sites/default/files/joint_communication_global_gateway.pdf> accessed 23 October 2025.
29 European Investment Bank, ‘European Commission and EIB Group Pave the Way for New €300 Million Export Credit Guarantee Facility to Support Exports by European Companies to Ukraine’ (European Investment Bank, 21 June 2024) 2 <https://www.eib.org/en/press/ all/2024-215-european-commission-and-eib-group-pave-the-way-for-new-eur300-million-export-creditguarantee-facility-to-support-exports-by-european-companies-to-ukraine> accessed 23 October 2025.
30 European Commission, ‘Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions: A Green Deal Industrial Plan for the Net-Zero Age’ (n 18) 33.
31 ibid 5.
32 European Commission, ‘Global Gateway Business Advisory Group – International Partnerships’ (n 11).
33 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17).
34 ibid 14.
the effectiveness even more. Moreover, the establishment of a European association of ECAs that encompasses the EU principles of subsidiarity and additionality35 could support these efforts by facilitating the exchange of best practices and discussions on EU regulations, including state-aid rules, export credit provisions, and capital requirements. It could also constitute a cooperative entity to provide technical assistance, particularly for smaller ECAs, in areas like ESG assessments, risk management, and underwriting. The association would thus not only foster greater cooperation and stimulate the development of whole-of-government approach across the EU but also address gaps in export support for EU businesses36. With this approach, export finance aspects will be coordinated in a more coherent way “across key EU institutions and rules, including mechanisms ensuring that the perspective of Member States ECAs are brought into the EU’s external strategic agenda”, maximizing the impact of financing tools37
The Green Deal Industrial Plan and the Critical Raw Materials Communication also advocate for the development of an EU export credit facility along with an export credit strategy38 in order to “foster coherence with EU policies (...) which pledged to invest in infrastructures aligned with pathways towards net-zero emissions”39. The current European Commission’s strategy to advance the Global Gateway and strengthen EU’s position in the global investment competition relies on the alignment of development finance and the private sector. The EU Commissioner for International Partnerships Jozef Síkela advocates for a “Team Europe” approach, “bringing together European credit agencies, development finance institutions, and the private sector”40
Efforts are underway to improve the coordination of external financial tools, potentially creating an EU financial instrument to support national export credit agencies in strategic situations where they lack sufficient capacity41. However, given a lack of concrete results so far, this trend towards the centralisation of export credit finance, following the example of what is working in China42, seems not yet to be the main interest of the Member States43. Creating formal EU-level coordination between “Member States’ export credit agencies and EU funded projects run by IFIs [International Finance Institutions] or national DFIs [Development
35 ibid 28.
36 ibid 14.
37 ibid 15.
38 Gerasimcikova, Troost and Casati (n 19).
39 European Commission, ‘Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions: A Green Deal Industrial Plan for the Net-Zero Age’ (n 18).
40 Rob Merrick, ‘Salvation or Sellout? EU Aid in Spotlight over Export Credits’ (Devex, January 2025) <https://www.devex.com/news/sponsored/salvation-or-sellout-eu-aid-in-spotlight-over-export-credits-109003> accessed 23 October 2025.
41 ibid.
42 Yunnan Chen, ‘Levelling the Playing Field: OECD Responses to China’s Overseas Finance | ODI: Think Change’ (ODI Global, 11 April 2024) <https://odi.org/en/insights/levelling-the-playing-field-oecd-responses-to-chinas-overseas-finance/> accessed 23 October 2025.
43 Gerasimcikova, Troost and Casati (n 19) 4.
Finance Institutions]”44 could boost the export share of EU companies. However, it would also require adjustments to “existing structures and decision-making processes”45 that would lead EU Member States to agree on the level of EU coordination for tools that presently prioritise their national industries.
Nevertheless, the European Commission identified potential legal challenges in a Joint Staff Working Document in 2023 concerning the inclusion of ECAs under Export Credit Regulation 1233/201146 in development finance, noting that “aid must not operate as an export credit”47, as it could not be recognised as ODA and might violate World Trade Organisation (WTO) rules, potentially being considered an illegal export subsidy if it does not follow the OECD Arrangement. Hence, as European Commission and HR/VP (2023) state, “the enhanced coordination cannot mix export credit support and the Commission development investment support in a way that would make provision of development aid contingent upon sourcing from EU exporters” but there can be an “information exchange and transparency”48 that could allow ECAs to participate in EU aid projects, provided international laws are upheld49
However, the fact that ECAs do not have development objectives as their ultimate goal does not mean that they should not be better aligned with the values of the EU and the realisation of sustainable development projects. In fact, ECAs are already meant to uphold the political directives and global obligations of their respective national governments, including those outlined in international agreements like the Paris Agreement50. Yet, at the moment, there are still shortcomings in the ECAs’ policies51. Better alignment with the EU’s values and policies is essential also because, as Gerlo and Troost state, ECAs are progressively seeking methods to assist businesses involved in what they term “green projects” overseas52. These initiatives are driven by market principles yet are framed within the context of the climate crisis and energy transition. This can be observed in the fact that “ECAs are increasingly being considered an instrument to
44 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17) 39.
45 ibid.
46 European Parliament and the Council of the European Union (n 1).
47 Merrick (n 40).
48 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17) 36.
49 Merrick (n 40).
50 Igor Shishlov, Philipp Censkowsky and Laila Darouich, ‘Aligning Export Credit Agencies with the Paris Agreement’ (Perspectives Climate Group, 6 September 2021) 8 <https://perspectives.cc/publication/aligningexport-credit-agencies-with-the-paris-agreement/> accessed 23 October 2025.
51 Davide Maneschi, ‘Key Considerations for Sustainable European Export Finance’ (Swedwatch 2023) <https://swedwatch.org/wp-content/uploads/2023/04/swedwatch-2023-key-considerations-for-sustainable-eu-export-credits.pdf>.
52 Julia Gerlo and Marius Troost, ‘The Foreign Financiers of Argentina’s Lithium Rush. Export Credit Agencies’ Support for Lithium Mining’ (2023) <https://www.bothends.org/uploaded_files/document/ The_foreign_financiers_of_Argentina_s_lithium_rush.pdf>.
finance renewable and mining projects, as is evidenced by processes at OECD and EU levels”53
Furthermore, “the EIB and its subsidiary EIF have some experience with cooperation with export credit agencies”54. For instance, Enel, EIB Global and SACE “joined forces to support the development of renewable energy and energy efficiency programmes in Brazil, Colombia and Peru”55. In Colombia, they provided an up to $300 million loan to Enel Colombia, which is officially intended for supporting the construction of power grids and renewable energy generation under the Global Gateway Investment Agenda, creating more business opportunities for Enel56, as well as contributing to the attainment of the SDGs57. However, with continuous finance of fossil fuels, SACE is not aligned with the Paris Agreement, underscoring the necessity to ensure coherence across all EU policies58
CoNCLuSIoN AND rECoMMENDAtIoNS
Considering the problems and policy options described above, particularly the limited financial volume, the structural inefficiencies of the current funding model, and the growing gap between the EU’s stated development goals and its strategic actions, it is essential to recalibrate the Global Gateway’s framing and operational focus. To enhance both impact and credibility, the EU should rethink how it positions the initiative in global affairs, ensuring greater alignment between its instruments, objectives, and geopolitical realities.
In the context of the negotiations of the next MFF, our policy recommendations to the European Commission, the DG INTPA and the DG Trade for improving the financial structure of the Global Gateway include:
53 ibid 3.
54 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17) 21.
55 European Investment Bank, ‘Enel Agrees on €600 Million Facility with the EIB and SACE for Sustainability-Linked Financing in Latin America’ (European Investment Bank) 1 <https://www.eib.org/en/ press/all/2022-195-enel-agrees-on-eur600-million-facility-with-the-eib-and-sace-for-sustainability-linkedfinancing-in-latin-america> accessed 23 October 2025.
56 European Investment Bank, ‘Colombia: EIB Global Provides Enel Colombia with $300 Million Loan for Renewable Energy Generation and Power Grid Improvements’ (European Investment Bank, 10 October 2024) 1 <https://www.eib.org/en/press/all/2024-371-eib-global-provides-enel-colombia-with-usd300-million-loan-for-renewable-energy-generation-and-power-grid-improvements> accessed 23 October 2025.
57 ibid 2.
58 Marius Troost, ‘EU ECA Fossil Fuel Phase-out Tracker Reveals EU Member States’ Lagging Commitment to Paris Agreement Goals in Export Credit Policies’ (Both ENDS, April 2024) <https://www. bothends.org/en/Whats-new/News/EU-ECA-fossil-fuel-phase-out-tracker-reveals-EU-Member-Stateslagging-commitment-to-Paris-Agreement-goals-in-export-credit-policies/> accessed 23 October 2025.
• The framing of the Global Gateway as a trade policy rather than a developmental policy. This would lead to the decoupling of the EFSD+ off the Global Gateway and to its reallocation under a new regulation away from the development-focused NDICI-Regulation to an export-credit type of finance. In turn, this would allow the decoupling of the Global Gateway away from the European’s ODA commitments and therefore mobilise genuine funds dedicated to development within the ODA.
• Based on the final report of the DG Trade on the feasibility study on an EU Strategy on Export Credits59, on a necessary prior assessment of the Ukraine Export Credit Facility, and in line with the Green Deal Industrial Plan and the Critical Raw Materials Communication, the EU and its Member States could explore further the possibility of the creation of an EU export credit facility for the Global Gateway. The creation of this facility could be supervised by DG Trade in cooperation with the Member States and the ECAs and would help ensure that ECAs follow the highest standards in terms of respect of environment, human rights and transparent due diligence. Such a facility could help European exporters compete globally by incentivizing participation by offering reinsurance and policy-backed guarantees for projects aligned with EU’s sustainability and strategic priorities so as to ensure that projects meet EU’s policy goals. An enhanced coordination between the current Directorate-Generals responsible for the Global Gateway, the DG INTPA and DG Trade should be prioritised to ensure a coherent delivery and communication of the Global Gateway’s objectives before transferring the supervision of the strategy to DG Trade.
• In addition, the creation of this EU export credit facility should go hand in hand with the establishment of a specific unit in DG Trade upholding the EU principles of subsidiarity and additionality. Indeed, this new body would improve coordination, risk-sharing and strategic financing for the Global Gateway, ensuring that EU-backed infrastructure projects can compete globally while upholding sustainability, transparency, and economic viability. Since the Global Gateway focuses on high-impact infrastructure in developing markets, ECAs might face higher risks, making it essential to develop risk mitigation mechanisms. At the same time, this body could ensure that ECAs do not contribute to additional debt burden in low-income countries60. A coordinated European ECA network would enable EU Member States to pool resources, mitigate risks, and enhance the EU’s competitiveness in financing strategic projects while respecting national competencies.
59 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17).
60 Brynildsen (n 5).
Moreover, the creation of a centralised EU advisory service to provide technical assistance, capacity-building, and policy guidance to ECAs and European exporters engaged in Global Gateway projects would address the fragmentation and coordination issues while harmonising best practices and ensuring a coherent EU-wide strategy.
• In line with the concepts of mutual and industrial partnerships defended by the European institutions in its comments on the next MFF61 and Mario Draghi’s report62, the Global Gateway should ensure mutual benefits via an increased participation of the national and local beneficiaries. As the initiative increasingly intersects with EU trade and industrial strategies, it is essential to strike a balance between commercial interests and developmental objectives. The Global Gateway should then pursue the financing of projects that not only serve EU strategic interests but also create sustainable jobs and better living conditions of the local population, in addition to developing the local productive capacities and value chains. This would allow the EU to counter the neo-colonial narrative and the beneficiaries to preserve their sovereignty within the partnership. The involvement of national and local authorities as well as the civil society for strategic guidance may require a lengthier process but can help avoid future delays and obstructions in project implementation due to unforeseen issues or negative impacts. By taking into account broader and necessary contributions, it would also help the EU to remain aligned with the values that it seeks to pursue and enhance its reputation. The establishment of a clear export credit strategy should follow the existing dual-track model that combines national and EU-level efforts. While member states are in charge of creating national policies to advocate their exporters, additional EU-level actions could enhance the ability of member states’ ECAs to better support their exporters and investors. In this manner, the strategy should be developed collaboratively between “[m]ember [s]tates (and their ECAs) and the Commission”63 taking into account SMEs and also local enterprises.
• For the latter, their participation could be further ensured in the consultation, implementation and procurement processes of the projects, and by facilitating their access to export credit and offering technical assistance to meet international standards.
A revision of the Export Credit Regulation 1233/2011 is necessary to align it with the EU’s evolving policy priorities, particularly regarding climate
61 Paul A Mudde and others, Feasibility Study on an EU Strategy on Export Credits: Final Report (Publications Office of the European Union 2023) <https://data.europa.eu/doi/10.2781/662916>.
62 Draghi, Mario (n 24) 52.
63 European Commission and High Representative of the Union for Foreign Affairs and Security Policy (HR/VP) (n 17) 110.
commitments and human rights. The current framework is obsolete and lacks the necessary safeguards to ensure that ECAs operate in full compliance with EU policies and obligations64. As recommended by Raza et al.65, to enhance transparency and accountability in the Global Gateway’s financial framework, the EU can take the lead by unilaterally mandating more ambitious reporting requirements among its member states even without a reached consensus within the OECD. The establishment of a centralised EU database that publicly tracks all ECA activities, providing disaggregated data detailing “the financial value of all projects” – both approved and pending – “their risk classification”, sectoral and geographical distribution, “basic project descriptions”, “involved parties, relevant standards and complaint mechanisms”, and their contributions to policy goals66. This proposal is consistent with the objectives of the Omnibus package, which seeks to improve the EU’s external financial architecture by making sustainability
reporting more accessible, efficient and coherent 67. By embedding transparency into the financing structure, the EU can ensure that the shift to export credit aligns with sustainable investment principles while enhancing credibility and sustainability.
As stated in the “White Paper on public export finance in the EU. Take action or fall behind!”, to remain competitive and achieve its ambitious international goals, the EU must recalibrate, adapt and rethink how to use the capacity of the public export systems to best support its exporters and businesses abroad”68. In doing so, however, the EU must strike a careful balance between maintaining global economic competitiveness and upholding its commitment to developmental and social goals, and ensure that credit export finance does not undermine, but rather reinforces, the broader objectives of sustainable development, inclusive growth, and respect for human rights. After all, what is the value of strategic influence if it comes at the expense of the very values the EU claims to defend?
64 Gerasimcikova, Troost and Casati (n 19).
65 Werner Raza, Lukas Schlögl and David Pfaffenbichler, ‘Aligning European Export Credit Agencies with EU Policy Goals’ <https://www.europarl.europa.eu/RegData/etudes/IDAN/2023/702590/EXPO_ IDA(2023)702590_EN.pdf>.
66 ibid 28.
67 European Commission, ‘Commission Proposes to Cut Red Tape and Simplify Business Environment
– European Commission’ <https://commission.europa.eu/news-and-media/news/commission-proposes-cut-red-tape-and-simplify-business-environment-2025-02-26_en> accessed 6 May 2025.
68 ExFi Lab, ‘White Paper on Public Export Finance in the EU’ [2021] ExFi Lab 9 <https://www.eifo.dk/ media/55dlei4h/re-issue_white_paper_on_public_export_finance_in_the_eu_april-2021.pdf>.
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