Two years after Mario Draghi told the European Parliament that Europe faced a choice between paralysis, exit and integration, there is now a table that shows which parts of the European Commission chose which. EPIC's Draghi Implementation Index (draghiwatch.eu), which tracks how many of the report's 383 recommendations have become binding EU law, published its first ranking of directorates-general in its July 2026 update. The top of the table is DG TRADE, with 41.7% of its recommendations strictly implemented. The bottom is DG EMPL, on 0.0%. In between sits DG ENER on 2.7% — the department responsible for the single competitiveness gap Draghi described most vividly.
The Index, run by the European Policy Innovation Council with the Greek think tank KEFIM and edited by Antonios Nestoras, has produced headline percentages since its launch in September 2025. Its July 2026 reading put strict implementation of the full report at 15.7% — 60 of 383 recommendations — and strict-plus-partial at 41.3%, or 158 recommendations. Those are modest numbers, but they are averages, and averages hide the interesting part.
The DG ranking is the interesting part. It attributes each recommendation to the department that owns it and asks how much of that department's Draghi homework is done. Trade, at 41.7%, is almost three times the Commission-wide figure. Energy, at 2.7%, is barely above nothing. Employment, at 0.0%, has not turned a single recommendation in its chapter into binding law in the twenty-two months since the report was published.
The obvious explanation is that trade is a Commission monopoly. Under the treaties, the common commercial policy is an exclusive EU competence: the Commission negotiates, the Council and Parliament approve, and no national parliament or ministry gets a veto over the substance. Draghi's trade recommendations — on defensive instruments, on economic security, on diversifying supply — land in a department that can execute them without waiting for twenty-seven capitals to agree on who pays.
Energy is the mirror image. Draghi's report told MEPs in September 2024 that "EU companies face electricity prices that are 2-3 times higher than those in the United States and in China." That sentence is the report's most-quoted line for a reason. But the energy mix, grid planning, taxation and most of the levers that set the price of a megawatt-hour remain national. EPIC's January 2026 audit already found energy the laggard among the moving sectors at 22.9% strict-plus-partial, with most measures still "in progress"; by July the department that owns them had converted 2.7% into strict law. The recommendations exist. The competence to deliver them largely does not.
Employment tells the same story in its purest form. Labour law, pensions, skills and wage-setting are member-state territory, and the Commission's tools are recommendations and coordination rather than regulations. A 0.0% strict score is what a department looks like when the report asks it to do things the treaties do not let it do.
There is one sector where the EU has no exclusive competence and still moved fast: defence. EPIC's January 2026 audit recorded defence implementation jumping from 35.7% to 78.6% between the September 2025 baseline and January — the biggest mover in the entire index — and the July update logged the €90 billion Ukraine defence loan (Regulation 2026/467) as fully implemented. EPIC's own reading of the pattern, repeated in its July report, is that the EU moves fastest where competitiveness fuses with security and slowest on the structural reforms that force market outcomes. Defence is the case where member states chose to hand over the pen. Trade is the case where they handed it over decades ago.
If the Commission delivers most where it holds exclusive power, then the department at the top of EPIC's table is also the one that has been under the most political fire. It is DG TRADE that negotiated the July 2025 framework with Washington — the deal Gabriel Attal, launching his French presidential bid on Friday, described as "accepted without complaint" and contrasted with Mark Carney's refusal to bow. It is DG TRADE that will handle whatever emerges from this week's Trump–Xi summit in Washington, and from Donald Trump's tariff threat against the EU–Canada rapprochement EU Insider reported last week. High delivery on Draghi's trade chapter and high exposure to American pressure are not contradictions. They are the same fact: the one part of Europe that acts as a single actor is the one part the rest of the world can negotiate with, and lean on.
The Index also confirms that the system as a whole is slowing. The Commission-wide strict score rose by 0.6 points between January and July 2026; strict-plus-partial rose 2.4 points, against 7.5 points in the previous half-year. Thirty-four acts were assessed in the February–June window. The easy wins — the ones a single DG could push through alone — appear to be running out.
EPIC's ranking is the most useful thing the Draghi Observatory has produced, because it reframes the question. "Is Europe implementing Draghi?" has an unhelpful answer: a bit. "Where is Europe implementing Draghi?" has a precise one: wherever Brussels does not need permission. That makes the slowdown a structural forecast rather than a passing lull. The remaining 323 recommendations are concentrated in energy, labour markets, capital markets and the Single Market — the areas where the pen sits in national capitals, including a Berlin whose chancellor, after this weekend, has less room to move than at any point in his term. The next full review of the Index is due this month; it will show whether any member state has been willing to hand over another pen.
