The OCTA, the Association of the Overseas Countries and Territories of the EU, made its position known in August 2018, in the context of the public consultation organised by the European Commission. The OCTA welcomed the option to retain the main features of the cooperation and to integrate OCT funds into the EU general budget, while retaining the flexibility of the EDF. However, the OCTA regretted that the proposal does not sufficiently address challenges such as climate change. It disapproved of the discrepancy between the increase in the external action budget as a whole and the decrease in allocations for the OCTs (see Figure 2 for Parliament’s calculations). The OCTA pointed out that EU programme implementation remains a challenge. The OCTA recalled the OCTs ‘comparative disadvantages’ (‘size, remoteness and isolation, diseconomies of scale, limited or inexistent industrial base, lack of economic diversification, high exposure to extremely devastating natural hazards, etc.’). Moreover, the OCTA disagreed with the proposal to transfer responsibility for annual reporting from the Commission to the OCTs, especially since the Commission has most of the data, and because responsibility for annual reporting would impose an additional burden on OCTs.