COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Belgium Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Belgium
Date: 2021-06-23
Institutions: European Commission, Secretariat-General
Subjects: Belgium, EU aid, coronavirus disease, economic and social cohesion, economic recovery, economic reform, epidemic, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.6.2021  SWD(2021) 172 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Belgium Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Belgium {COM(2021) 349 final}  
 
 
Table of contents 
1. 

Executive summary ............................................................................................................................... 2 

2.  Recovery and resilience challenges: scene-setter ................................................................................ 5 

2.1.  Macroeconomic outlook and developments since the 2020 country report ............................... 5 

2.2. 
Challenges related to sustainable growth, cohesion, resilience and policies for the next 
generation ................................................................................................................................................. 9 

2.3. 

Challenges related to the green and digital transition ............................................................... 11 

Green dimension ................................................................................................................................. 11 

Digital dimension ................................................................................................................................ 15 

3.  Objectives, structure and governance of the plan.............................................................................. 21 

3.1.  Overall strategy of the plan ........................................................................................................ 21 

3.2. 

Implementation aspects of the plan ........................................................................................... 25 

4. 

Summary of the assessment of the plan ............................................................................................ 29 

4.1. 

Comprehensive and adequately balanced response to the economic and social situation ...... 29 

4.2. 

Link with country-specific recommendations and the European Semester ............................... 36 

4.3.  Growth potential, job creation, economic, institutional and social resilience, European Pillar of 
Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence ...... 47 

4.4. 

The principle of ‘do no significant harm’ .................................................................................... 60 

4.5.  Green transition .......................................................................................................................... 63 

4.6. 

Digital transition .......................................................................................................................... 69 

4.7. 

Lasting impact of the plan ........................................................................................................... 75 

4.8.  Milestones, targets, monitoring and implementation................................................................ 78 

4.9. 

Costing ........................................................................................................................................ 80 

4.10.  Controls and audit ....................................................................................................................... 82 

4.11.  Coherence ................................................................................................................................... 85 

Annex: Climate and digital tagging ............................................................................................................. 89 

References .................................................................................................................................................. 95 

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1.  EXECUTIVE SUMMARY  

The COVID crisis had a major impact on the Belgian economy and public finances. After 
GDP fell by 6.3% in 2020, economic growth is forecast to reach 4.5% in 2021 and 3.7% in 2022. 
The impact of the COVID-19 crisis on the Belgian labour market has been largely mitigated by 
significant  support  policy  measures.  The  expansion  of  total  employment  in  recent  years  was 
interrupted in 2020 and a 0.6% fall is expected in 2021. The unemployment rate is expected to 
rise  from  a  historical  low  of  5.4%  in  2019  to  6.7%  in  2021.  As  a  consequence  of  the  fall  in 
economic activity and of the measures taken by the government to tackle the impact of the crisis, 
the public deficit has deteriorated markedly from 1.9% of GDP in 2019 to 9.4% in 2020 and the 
public debt has increased from 98.1% of GDP in 2019 to 114.1% in 2020. 

To  support  the  country’s  economic  recovery,  Belgium  has  requested  EUR  5.9  billion  of 
non-repayable financial support under the Recovery and Resilience Facility. This financing 
offers  the  opportunity  to  strengthen  economic,  social  and  territorial  cohesion,  in  particular 
accelerate  the  green  and  digital  transition  mostly  through  public  investment  and  associated 
enabling  reforms,  and  to  address  core  challenges.  As  a  result  of  high  public  debt  and  policy 
choices  over  the  past  decades  to  save  less  on  current  expenditure  and  more  on  public 
investments,  the  public  capital  stock  has  seen  a  negative  growth,  eroding  the  quality  of  public 
infrastructure and dampening long-term economic potential. Belgium has important investment 
needs, notably in social housing, education, sustainable transport and energy. Moreover, Belgium 
lags  behind  in  digital  infrastructure  with  digital  public  services  underused,  hampering 
productivity  and  innovation.  Structural  reforms  in  the  areas  of  pensions,  taxation,  public 
spending,  the  labour  market  and  the  business  environment  are  needed  to  support  more 
sustainable and inclusive growth. 

The  proposed  Recovery  and  Resilience  Plan  of  Belgium  is  expected  to  contribute  to 
effectively  addressing  a  significant  subset  of  the  challenges  identified  in  the  relevant 
country-specific  recommendations  and  in  the  draft  Council  recommendation  on  the 
economic policy of the euro area.1 To improve the quality and efficiency of public spending, 
the plan includes the systematic integration of spending reviews in the budgetary planning cycles 
of all government levels. Against the background of increasing public pension expenditure, the 
plan includes a pension reform, which aims to improve the financial and social sustainability of 
the pension system. The Belgian recovery and resilience plan also includes several measures to 
address  labour  market  challenges  and  strengthen  the  social  and  labour  market  integration  of 
vulnerable  groups,  such  as  people  with  a  migrant  background,  women,  youth,  people  with 
disabilities, prisoners and people at risk of digital exclusion. The plan refers to a proposal for a 
broad tax reform, which could potentially tackle the financial disincentives to work embedded in 

1 
Pending final adoption by the Council, after endorsement by the European Council. The text agreed by the 
Eurogroup  on  16  December  2020  is  available  at:  https://data.consilium.europa.eu/doc/document/ST-14356-2020-
INIT/en/pdf 

2 

 
 
                                                           
the current tax system, green the taxation system and discourage the use of fossil fuels through 
appropriate price signals, but given the absence of clear timeline and commitment to adopt the 
reform,  it  could  not  be  included  as  a  measure  supported  by  the  Facility.  The  plan  contains  a 
reform of the company car tax scheme, geared towards the electrification of road transport. The 
reform  is  expected  to  contribute  to  reduce  greenhouse  gas  emissions,  but  does  not  limit 
congestion nor the budgetary impact of the scheme. 

The  plan  provides  a  comprehensive  and  adequately  balanced  response  to  the  six  policy 
pillars referred to in Article 3 of Regulation (EU) 2021/2412. Ten of the 17 components in the 
Belgian  plan  are  directly  related  to  the  green  transition  and  11  components  address  the  digital 
transformation  (pillars  1  and  2).  The  remaining  four  policy  pillars  are  addressed  adequately 
through additional measures to: (i) strengthen training and employment of vulnerable groups; (ii) 
introduce  spending  reviews  at  all  government  levels;  (iii)  reinforce  economic  activity  through 
R&D support; (iv) provide social housing and childcare infrastructure; (v) implement measures 
to digitalise public services; (vi) strengthen the education and training systems; and, (vii) reform 
the pension system. 

The  plan  is  expected  to  effectively  contribute  to  strengthening  the  growth  potential,  job 
creation, and economic, social and institutional resilience of Belgium and to mitigating the 
economic  and  social  impact  of  the  COVID-19  crisis,  although  the  direct  impact  on  job 
creation  could  have  been  enhanced  with  more  ambitious  reforms.  The  plan  is  expected  to 
have  a  positive  economic  impact  by  supporting  public  and  private  investment,  notably  in 
sustainable  transport  and  digital  infrastructure,  social  housing,  energy-efficient  building 
renovation,  alternative  energy  infrastructure  and  research  and  innovation.  By  contributing  to  a 
greener  and  digital  economy,  the  plan  intends  to  support  sustainable  growth  and  economic 
resilience. The sizeable investment in digitalisation of the public administration and of the justice 
system  is  expected  to  contribute  to  a  business-friendly  environment  and  thereby  support  the 
economic  recovery.  Moreover,  the  plan  is  expected  to  help  address  skills  mismatches  by 
strengthening  the  education  and  training  systems.  The  focus  on  improving  digital  skills  and 
fostering access to the labour market for vulnerable groups is expected to have a positive impact 
on employment and contribute to the implementation of the European Pillar of Social Rights and 
the Porto declaration adopted on 7 May 2020. 

The  Belgian  plan  strongly  supports  the  energy-efficient  renovation  of  buildings  and 
supports the decarbonisation of the energy, industry and transport sectors, which are areas 
with  major  needs  for  reaching  the  2030  energy  and  climate  targets.  The  building  sector 
accounts for more than 30% of non-ETS GHG emissions in Belgium, and ranks low in relation 
to  the  energy  performance  of  its  existing  housing  stock.  The  plan  includes  substantial 
investments  to  improve the energy efficiency of  public buildings, as well as private and social 

2 
the Recovery and Resilience Facility 

Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing 

3 

 
 
                                                           
housing. Moreover, it is expected to improve the system of renovation subsidies for households 
to  foster  private  investment.  The  plan  also  intends  to  support  several  clean  emerging  energy 
technologies  geared  towards  decarbonisation,  notably  in  the  areas  of  hydrogen  production  and 
transport. Overall, even if it includes only limited investments into renewable energy, the plan is 
expected  to  contribute  to  decarbonising  the  energy  sector.  Finally,  several  measures  aim  to 
restore  biodiversity,  protect  the  environment,  adapt  to  climate  change  and  develop  a  more 
circular economy. 

The  plan  also  aims  to  contribute  to  the  transformation  of  the  transport  sector,  which 
generates  35%  of  non-ETS  greenhouse  gas  emissions  in  Belgium.  Moreover,  Belgium  lags 
behind  in  electric mobility  and road congestion weighs on productivity  and local  air pollution. 
The plan includes substantial support to favour active modes of transport and promotes the use of 
public transport, with a particular focus on rail. It also supports investments in inland waterways 
transport. Several measures of the plan are expected to also support the electrification of public 
the  deployment  of  electric  charging 
and  private 
infrastructure. The plan also aims to improve Belgium’s resilience to climate change by investing 
in  more  rational  use  of  water  resources  and  in  the  protection  of  biodiversity.  The  measures 
contained  in  the  Belgian  recovery  and  resilience  plan  contributing  to  the  climate  objectives 
account for an amount which represents 49.6% of the plan’s total allocation. All measures in the 
Belgian plan have passed the ex-ante assessment of the ‘do no significant harm’ principle. 

including  by  accelerating 

transport, 

Moreover,  various  investments  and  reforms  support  the  digital  transition,  through  the 
digitalisation  and  equipment  of  public  services  and  the  roll-out  of  digital  infrastructure. 
The reinforcement of the digitalisation of the economy was identified as a promising avenue for 
boosting productivity and the innovation  capacity of Belgium. Reforms  both at the federal and 
regional  level  aim  to  remove  regulatory  bottlenecks  to  the  deployment  of  5G  and  ultra-fast 
connectivity  infrastructure,  such  as  fibre.  Investments  focus  on  the  digitalisation  of  the  public 
administration  and  include  the  roll-out  of  digital  infrastructure.  Finally,  investments  aim  at 
strengthening  the  overall  cyber  resilience  and  cyber  crisis  preparedness  of  the  Belgian  society. 
The  measures  contained  in  the  Belgian  recovery  and  resilience  plan  contributing  to  the  digital 
transition account for an amount which represents 26.6% of the plan’s total allocation. 

The  Belgian  plan  is  expected  to  have  a  lasting  impact  to  a  large  extent,  which  could  be 
enhanced  with  more  far-reaching  complementary  reforms.  The  reforms  proposed  in  the 
recovery  and  resilience  plan  are  expected  to  contribute  to  addressing  key  economic  challenges 
and impact on institutions and policies in a lasting manner. However, as some of the reforms are 
described in  rather  general  terms  in  the plan, it is difficult  to  anticipate their full effects  in  the 
long run. The reform of the pension system is a case in point. Moreover, while the plan refers to 
a  proposal  for  a  broad  tax  reform,  which  could  remove  disincentives  to  work  on  a  permanent 
basis and shift  taxes  towards energy products  in  order to provide appropriate price signals,  the 
plan  does  not  include  a  firm  commitment  to  its  adoption.  At  the  same  time,  Belgium  is  also 
expected to benefit from important spillovers of other Member States’ recovery plans. 

Finally,  the  plan  displays  a  mostly  coherent  set  of  reforms  and  investments.  However,  it 
could have better exploited the potential of some of the investments through more far-reaching 

4 

 
 
complementary  reforms  and  in  some  instances,  measures  could  have  been  more  coherent  and 
mutually-reinforcing. 

that 

to  ensure 

Belgium  has  proposed  organisational  arrangements 
the  plan’s 
implementation can effectively be monitored and has demonstrated that the estimated costs 
of  the  plan  are  reasonable  and  plausible.  While  complex,  the  governance  structure  and 
organisational  arrangements  for  the  implementation  of  the  plan  ensure  the  involvement  of  the 
responsible  actors  in  monitoring,  reporting  and  administrative  follow-up  of  the  reforms  and 
investments under their responsibility. Inter-federal coordination between the entities involved is 
ensured  at  both  political  and  administrative  level.  The  monitoring  indicators  are  in  general 
sufficiently clear and comprehensive to ensure that their completion can be traced and verified. 
The milestones and targets  chosen  cover  the key elements  of the measures and as such can be 
considered  relevant  for  their  implementation.  The  costing  information  presented  in  the  plan  is, 
for  the  most  part,  detailed  and  clear.  For  a  large  majority  of  measures,  there  is  sufficiently 
detailed information and comprehensive supporting evidence that the estimated total cost of the 
plan is reasonable and plausible, in line with the principle of cost-efficiency and commensurate. 
The  individual  components  do  not  all,  as  a  rule,  provide  detailed  information  about  additional 
investments  from  other  EU  funds.  Therefore,  an  adequate  milestone  to  ensure  coordination 
between all entities to avoid double funding has been included in the plan.  

Table  1  -  Ratings  received  by  the  Belgian  recovery  and  resilience  plan  under  the  eleven 
criteria 
(1) 
Balanced 
Response 

(10) 
Control 
Systems 

(3) 
Growth, 
jobs… 

(7) 
Lasting 
impact 

(11) 
Coherence 

(6) 
Digital 
target 

(5) 
Green 
target 

(9) 
Costing 

(8) 
M & T 

(4) 
DNSH 

(2) 
CSRs 

A 

A 

A 

A 

A 

A 

A 

A 

B 

A 

B 

2.  RECOVERY AND RESILIENCE CHALLENGES: SCENE-SETTER  

2.1. Macroeconomic outlook and developments since the 2020 country report  

The macroeconomic scenario underpinning Belgium’s Stability Programme and Recovery 
and  Resilience  Plan  (RRP)  projects  real  GDP  growth  of  4.1%  in  2021  and  3.5%  in  2022 
after  a  historic  drop  of  6.3%  in  2020  caused  by  the  COVID-19  crisis.  Belgium’s  open 
economy particularly suffered from the restrictions to free movement of goods and people which 
led to severe supply chain restrictions as exports account for more than 80% of Belgium’s GDP3. 
The macroeconomic projections of the recovery and resilience plan are based on the last Federal 
Planning Bureau’s forecast which was produced in February 2021. Growth is set to be supported 
by  the  recovery  of  domestic  demand  (public  consumption  and  household  investment  and 

3 

See Annual Single Market Report 2021, 5.5.2021, SWD(2021) 351 final. 

5 

 
 
 
                                                           
consumption). The contribution of net exports to GDP growth is expected to be slightly negative 
throughout  the  forecast  horizon,  as  imports  would  recover  more  strongly  than  exports. 
Afterwards,  real  GDP  growth  would  decelerate  at  3.5%  in  2022  and  would  converge  towards 
1.5% in 2024. Private consumption would grow by 6.1% in 2021 after the drop of 7.7% in 2020. 
The  purchasing  power  of  households  has  been  maintained  by  government  support  during  the 
crisis, which led to an increase in the saving rate to 20.3% in 2020. The saving rate would drop 
to  16.3%  in  2021.  Regarding  enterprises  investment,  the  Federal  Planning  Bureau  projects  the 
recovery to really start in 2022 after a slow growth of 1% in 2021. 

The macroeconomic forecast of the Belgian recovery and resilience plan is broadly in line 
with  the  2021  Spring  forecast  of  the  Commission.  According  to  the  Spring  forecast,  GDP 
growth  is  expected  to  reach  4.5%  in  2021  and  3.7%  in  2022.  The  main  differences  with  the 
forecast of the Federal Planning Bureau included in the recovery and resilience plan are coming 
from the inclusion of the impact of the recovery and resilience plan and from new data available 
since  the  Federal  Planning  Bureau’s  forecast,  notably  the  revision  of  figures  for  2020. 
Investment was severely hit by the COVID-19 crisis in 2020. However, the strong rebound in the 
second half of the year limited the drop in annual terms to -6.9%. According to the Commission 
Spring forecast,  improving business confidence,  favourable financing conditions,  and the entry 
into  force  of  the  Recovery  and  Resilience  Facility  (RRF)  are  set  to  continue  to  support 
investment, despite possible solvency and liquidity concerns. Furthermore, an increase in public 
consumption is forecast to contribute to GDP growth in 2021. Exports are set to recover thanks 
to  the  strength  of  the  external  environment.  Following  the  recovery  in  domestic  demand  and 
exports,  imports  are  also  forecast  to  rebound  strongly.  Real  GDP  is  projected  to  reach  its  pre-
crisis level in the first half of 2022. 

Regarding  the  labour  market,  job  and  business  support  measures  have  allowed 
employment  to  remain  broadly  steady  and  have  kept  bankruptcies  at  low  levels.  The 
gradual  expiry  of  some  of  these  measures  is  expected  to  contribute  to  an  increase  in 
bankruptcies. The Federal Planning Bureau projects a rise in unemployment from 5.6% in 2020 
to  6.8%  in  2021  and  2022,  before  gradually  improving  to  5.3%  in  2026,  consistent  with 
economic  growth.  According  to  the  Commission  Spring  forecast,  unemployment  would  reach 
6.7% in 2021 and 6.5% in 2022. 

The fall in economic activity and energy prices has depressed annual HICP inflation from 
1.2%  in  2019  to  0.4%  in  2020.  In  line  with  the  rebound  expected  in  both  oil  prices  and 
economic  activity,  annual  HICP  inflation  is  forecast  to  rise  to  1.8%  in  2021  according  to  the 
Commission  forecast.  It  is  then  projected  to  slow  down  to  1.5%  in  2022,  as  energy  prices 
stabilise. The Belgian Federal Planning Bureau expects HICP to reach 1.5% in 2021 and 2022, 
before  1.7%  in  2023  and  2024.  Overall,  the  macroeconomic  scenario  presented  in  the  Belgian 
plan  and  underpinning  the  budgetary  projections  for  2021  and  2022  in  the  2021  stability 
programme  is  realistic,  based  on  plausible  macroeconomic  assumptions  compared  to  the 
Commission 2021 Spring forecast. 

The  COVID-19  crisis  contributed  to  a  deterioration  of  the  financial  situation  of  Belgian 
companies.  A  large  number  of  non-financial  firms  experienced  a  depletion  of  their  liquidity 

6 

 
 
buffers as a result of a sudden stop in their activities, not counterbalanced by an equivalent stop 
in financial commitments. In response to the COVID-19 pandemic, measures have been adopted 
to preserve the economic fabric of the country, in particular by adopting measures to support the 
liquidity  of  firms  and  limit  the  number  of  bankruptcies.  These  extensive  support  measures 
adopted  by  the  public  authorities  have  contributed  to  mitigate  the  negative  effects.  A  recent 
analysis estimated that the support policy measures alleviated liquidity concerns and reduced the 
share  of  firms  with  an  outright  cash  deficit  from  20%  to  15%  (National  Bank  of  Belgium, 
2021a).  Nevertheless,  it  is  very  likely  that  a  large  share  of  firms  will  start  the  recovery  period 
with deleveraging pressures, which can have negative consequences on their ability to carry out 
investment plans. 

Households  have  been  less  financially  affected  than  companies  by  the  COVID-19 
pandemic. Over the first 11 months of 2020, households’ savings as measured by bank deposits 
increased by EUR 18.1 billion (against an average increase of EUR 12.1 billion between 2011 
and  2019).  Over  the  same  period,  housing  prices  have  continued  to  increase  alongside  the 
average  amount  of  real  estate  loans.  The  increases  in  housing  prices  occurred  in  spite  of  a 
tightening of lending conditions by banks, including stricter requirements in relation to the Loan-
to-Value  ratio.  Overall,  the  financial  situation  of  Belgian  households  appears  sound,  although 
there  remain  disparities  among  households.  While  the  tax-benefit  system,  combined  with  the 
emergency  measures  adopted  by  the  different  levels  of  government  to  protect  households’ 
income and to support economic activities, has played a significant role in cushioning the effect 
of  the  economic  downturn4,  some  vulnerable  groups  of  the  population,  with  an  already  weak 
financial position, risk to become more exposed as a consequence of the crisis. 

The COVID crisis has also had a strong impact on Belgium’s public finances. According to 
the  RRP’s  forecast,  the  public  deficit  has  deteriorated  from  1.9%  of  GDP  in  2019  to  9.7%  in 
2020,  as  a  consequence  of  the  fall  in  economic  activity  and  of  the  measures  taken  by  the 
government to tackle the impact of the crisis. It is forecast to improve to a still large deficit of 
7.0% in 2021. The public debt is expected to increase from 98.1% of GDP in 2019 to 114.8% in 
2020  and  to  115.9%  in  2021.  The  Commission  forecast  has  similar  numbers,  with  a  deficit  of 
7.6% in 2021 and a public debt of 115.3%. 

Belgium is currently assessed as facing high fiscal sustainability risks in the short, medium 
and long term. Short-term risks stem from the sharp deterioration of public finances in 2020 and 
the resulting surge in financing needs to 26% of GDP (European Commission, 2021). The latter 
should  however  decline,  to  around  21%  of  GDP  in  2021-2022.  Moreover,  the  ‘AA’  sovereign 
rating  from  the  three  major  credit  rating  agencies  as  well  as  the  historically  low  sovereign 
spreads mitigate short-term risks. High risks in the medium term reflect the fact that, under the 

4 
The findings in Christl et al. (2021) based on the Euromod model, suggest that the 2020 tax-benefit system 
in Belgium absorbed about 82% of the shock in market income, more than half of the cushioning effect due to the 
monetary compensation schemes. See also Almeida et al. (2020). 

7 

 
 
                                                           
baseline  assumptions,  government  debt  would  remain  above  120%  of  GDP  in  ten  years’  time, 
peaking at 125% in 2027. Alternative scenarios, both favourable and unfavourable, confirm these 
risks. 

In  the  medium  term,  Belgium  will  need  a  gradual  fiscal  consolidation  to  improve  public 
finances  in  structural  terms.  Already  before  the  outbreak  of  the  coronavirus  pandemic, 
Belgium  had  a  high  public  debt  and  faced  high  sustainability  challenges  in  the  medium  term. 
When  economic  conditions  allow,  it  will  be  time  to  target  fiscal  policies  towards  a  prudent 
medium term fiscal position. 

The  government  budgetary  strategy  for  the  coming  years,  as  announced  in  the  federal 
government’s coalition agreement, foresees the implementation of a fiscal rule with a fixed 
and variable component. This is understandable in the current environment of high economic 
uncertainty. However, the need for medium term fiscal sustainability, also in an environment of 
lower-than-expected  economic  growth  in  the  coming  years,  remains  important  considering  the 
already existing fiscal challenges. 

In the 2021 macro imbalances procedure, no imbalances were identified for Belgium. In the 
updated scoreboard including figures until 2019, out of fourteen headline indicators two, notably 
the  private  sector  debt  and  government  debt  indicators,  are  beyond  the  indicative  thresholds. 
Private  sector  indebtedness  remained  well  above  the  threshold  in  2019  and  is  expected  to 
increase further in 2020 to around 200% of GDP. This is mainly due to household indebtedness, 
largely reflecting mortgage debt, which continued to increase in 2019 on the back of a positive 
net credit flow. After a fall in the first semester due to the lockdown and confinement measures, 
housing investment is expected to rebound in the second half of 2020. House prices increased in 
2019, with indications of potential overvaluation. The already high level of government debt has 
increased substantially with the COVID-19 crises. At the end of 2020 it reached 114.1% of GDP, 
16  percentage  points  higher  than  in  the  previous  year.  Likewise,  with  the  COVID-19  crisis 
government and private sector indebtedness have increased and warrant monitoring. In its overall 
assessment, the Commission did not consider it necessary to carry out further in-depth analysis 
in the context of the 2021 macroeconomic imbalances procedure. 

Table 2: Comparison of macroeconomic developments and forecasts 

8 

 
 
2.2. Challenges  related  to  sustainable  growth,  cohesion,  resilience  and  policies  for  the 

next generation  

For  economic  growth  to  reach  its  full  potential,  several  challenges  need  to  be  addressed. 
The performance of the Belgian economy has been moderate over the last years and the COVID-
19  crisis  poses  new  challenges  in  the  short  term.  At  the  same  time,  however,  it  offers  the 
opportunity to accelerate the transition to a more sustainable and digital economy. 

Structural  reforms  and  well  targeted  investments  in  green  and  digital  infrastructure,  as 
well  as  skills,  are  expected  to  contribute  to  more  sustainable  and  inclusive  growth. While 
additional  investments  are  taking  place  in  public  transport,  there  remain  important  green 
investment  needs  in  mobility,  housing  and  energy.  Moreover,  Belgium  lags  behind  in  digital 
infrastructure and digital public services are under-used, hampering productivity and innovation. 
Structural reforms in the areas of taxation, the labour market and the business environment are 
needed  to  support  the  green  and  digital  transition,  by  addressing  bottlenecks,  removing 
environmentally harmful subsidies and providing the right price signals. 

The COVID-19 crisis has worsened the already poor labour market outcomes of the most 
vulnerable groups.  However, measures taken to cushion the impact  of the crisis  of the labour 
market have been rather effective and while the crisis has stunted the expansion of the Belgian 
labour market and the expected jump in the unemployment rate has not materialised.  According 
to the projections of the National Bank of Belgium unemployment is expected to peak at 6.0% in 
2022  (compared  to  the  historical  low  of  5.4%  in  2021)  (National  Bank  of  Belgium,  2021b). 
Nevertheless,  the  impact  of  the  crisis  is  expected  to  be  reflected  in  a  higher  number  of 
jobseekers, but also in a rising number of discouraged workers who drop out or do not enter the 
labour  market  because  of  declining  job  opportunities.  Persons  already  struggling  to  find 
employment  before  the  pandemic,  like  the  low-skilled,  young  people,  people  with  a  migrant 
background (in particular non-EU born women) and people with disabilities, are expected to see 
a further deterioration of their position on the job market. 

9 

20192023202420252026COMCOMRRPCOMRRPCOMRRPRRPRRPRRPRRPReal GDP (% change)1.8-6.3-6.24.54.13.73.51.71.51.31.1Employment (% change)1.60-0.1-0.6-0.60.80.61.00.90.70.6Unemployment rate5.45.65.66.76.86.56.86.35.75.55.3HICP inflation1.20.41.81.5General government balance (% of GDP)-1.9-9.4-9.7-7.6-7.0-4.9-5.0-5.0-5.1-5.0-5.2Government debt (% of GDP)98.1114.1114.8115.3115.9115.5115.7117.1118.8120.6122.6Source: [Commission Spring Forecast 2021] (COM); Recovery and Resilience Plan (RRP)202020212022 
 
 
 
Despite  the  crisis,  labour  demand  remains  strong  in  Belgium  as  reflected  by  the  high 
vacancy  rate,  which  remained  stable  at  2.9%  in  the  fourth  quarter  of  2020.  Employers  report 
having  difficulties  to  find  employees  with  the  appropriate  skills.  There  are  considerable 
shortages  in  professional,  technical  and  scientific  occupations,  due  to  the  low  number  of 
graduates  in  science,  technology,  engineering  and  mathematics  (STEM).  Shortages  are  also 
observed in health care, construction, education and training. Moreover, participation in lifelong 
learning remains low at 8.2%, although up-and re-skilling is a key pre-condition for a successful 
digital and green transition. 

The  COVID-19  crisis  has  lowered  general  educational  outcomes,  but  also  aggravated  the 
already high inequalities in the educational outcomes of vulnerable learners. This includes 
those  from  low  socio-economic  and  migrant  backgrounds.  It  has  also  affected  young  people’s 
well-being,  increasing  the  risk  of  dropout  from  education  and  training.  Crucial  reforms  to 
increase  the  performance  and  equity  of  the  education  and  training  systems  have  also  been 
postponed. Distance learning has highlighted the need for a qualitative high-performing digital 
education  ecosystem,  especially  ensuring  effective  teacher  training  and  equal  access  to  quality 
digital  education  and  its  learning  environment.  There  is  a  sense  of  urgency  to  roll  out  digital 
skills  and  competences  in  all  school  curricula.  Addressing  the  shortage  of  well-qualified 
teachers,  making  their  profession  more  attractive  and  investing  effectively  in  initial  teacher 
education  and  continuous  professional  learning  are  key  and  will  contribute  to  addressing  the 
above challenges and needed reforms. 

The  lack  of  sufficient  skilled  workers,  high wage  costs,  complex  labour  and  tax  laws  and 
regulatory restrictions weigh on investment, productivity and growth. Large private capital 
accumulation  and  strong  innovation  performance  in  some  sectors  (pharmaceuticals,  minerals, 
chemicals)  have  contributed  to  a  relatively  high  level  of  productivity  in  Belgium5.  However, 
already  before  the  crisis,  productivity  growth  had  slowed  down  in  Belgium  compared  to  its 
neighbouring  countries  (Dumont,  2021).  Moreover,  following  a  high  (private)  investment  rate 
before  the  crisis,  the  outlook  for  business  investment  is  a  slow  recovery  in  a  context  of  high 
uncertainty. The lack of sufficient skilled workforce in some sectors, such as the building sector 
in  view  of  the  renovation  wave,  and  the  relative  high  level  of  labour  costs  constitute  major 
barriers to investment. In addition, the complexity of tax and labour laws, as well as regulatory 
barriers  in  services  weigh  on  investment  and  competitiveness  and  lead  to  low  business 
dynamism. 

Weak  policy  coordination  and  evaluation  contributes  to  a  high  administrative  and 
regulatory burden weighing on competitiveness. Ineffective coordination between government 
levels leads to a complex regulatory environment and weighs on the delivery of a certain number 
of policies. Moreover, the lack of effective evaluation in the policy-making process can impact 

5 
(Bauer, P and other, 2020) 

Belgium firms in the market economy are on average 44% more productive than their peers in Europe 

10 

 
 
                                                           
the  quality  of  regulation  and  contribute  to  the  high  administrative  and  regulatory  burden.  The 
efficiency of the public administration could be reinforced, including by increasing the staff for 
enforcers in justice, regulation, market surveillance and competition. 

The  good  innovation  performance  of  Belgium  rests  on  a  few  sectors  and  on  a  limited 
number of firms, which can be a source of vulnerability. Belgium ranks 6th in the 2020 EU 
innovation  scoreboard  and  qualifies  as  a  “strong  innovator”.  Private  R&D  investment  is 
relatively high, and though mostly concentrated in a limited number of multinational companies, 
it is also made to a significant extent by SMEs, which invested 0.7% of GDP in R&D activities. 
Public  R&D  intensity,  however,  remains  below  comparable  Member  States.  The  efficiency  of 
the high level of public support for business R&D is not proven. The gap between the best and 
the  least  performing  firms  is  widening,  which  might  signal  an  insufficient  diffusion  of 
technological advances (National Bank of Belgium, 2017). Recent analysis also underlines that 
innovative firms are less affected by the crisis (Marques Santos et al., 2021). 

The  COVID-19  crisis  had  a  negative  impact  on  corporate  lending  but  the  phase-out  of 
liquidity  support  measures,  notably  the  credit  moratorium,  has  not  led  to  a  surge  in 
defaults in the absence of flanking measures. Corporate lending grew by 2.8% from February 
to September 2020, while the euro area benefited from a 6.4 percentage points surge. This may 
be partly due to the Belgian loan guarantee scheme providing support to businesses in the form 
of State  guarantees on new short-term loans that was implemented relatively late  and that was 
not particularly attractive compared to similar schemes in other Member States. The moratorium 
on loan repayments agreed between the Belgian authorities and the banking sector has been met 
with  a  significant  demand.  Loans  under  non-expired  and  expired  moratoria  represented 
respectively 0.9% and 4.0% of all loans to the private sector in December 2020. There is a trade-
off between extending support measures for too long, with the risk of zombie firms, delaying the 
timely recognition of losses in the banking sector and wasting public resources, and ending them 
too soon, which could generate an excessive number of defaults. The strengthening of equity in 
viable companies is therefore crucial to avoid a wave of bankruptcies. Another important action 
is to improve the efficiency of the insolvency framework. 

2.3. Challenges related to the green and digital transition  

Green dimension  

Further  efforts  are  needed  to  ensure  Belgium  is  on  the  path  to  achieve  the  objective  of 
climate  neutrality  by  2050.  Greenhouse  gas  emissions  in  Belgium  in  2019  were  13%  below 
2005 levels compared to a 2020 target of -15%. The Belgian National Energy and Climate Plan 
(NECP) includes additional measures that if implemented should nearly bridge the gap to reach 
the  -35%  2030  reduction  target.  In  the  Land  Use  Land  Use  Change  and  Forestry  (LULUCF) 
sector, Belgium intends to respect the no-debit rule by 2030 and the sector is expected to remain 
a net  sink  over the  period up to  2030. However,  the national  long-term  strategy does not  set  a 
reduction target but estimates the accumulated federated entity-specific measures in the non-ETS 
sectors to result in 85-87% domestic reductions by 2050 compared to 2005. 

11 

 
 
Belgium  is  not  on  track  to  reach  its  renewable  energy  targets.  The  share  of  energy  from 
renewable  resources  in  Belgium’s  final  energy  consumption  reached  9.9%  in  2019  and  is 
projected to have reached 11.7% in 2020, below the target of 13% set by the Renewable Energy 
Directive  (2009/28/EC,  ‘RED’).6  Belgium  aims  to  reach  17.5%  in  2030,  but  this  ambition  is 
significantly below the 25% share calculated using the formula in Annex II to Regulation (EU) 
2018/1999  on  the  Governance  of  the  Energy  Union  and  Climate  Action  (the  ‘Governance 
Regulation’). 

The Belgian contributions to the energy efficiency target lack ambition and flexible energy 
networks are needed. Based on the NECP, Belgium’s national contribution to energy efficiency 
for  2030  is  -15%  (primary  energy  consumption)  and  -12%  (final  energy  consumption)  versus 
PRIMES2007 projections for 2030. These energy efficiency contributions are considered to be of 
low ambition (European Commission, 2020). Given the nuclear phase out and electricity sector 
target  of  37.4%  renewable  electricity  by  2030,  the  development  of  the  different  sources  of 
flexibility and their access to markets, as well as enhanced grid connections will be necessary in 
the  country  and  across  borders,  to  integrate  the  rising  share  of  renewable  energy  into  the 
electricity system. In addition to the infrastructure for electrical vehicles charging, the transition 
of  industry  and  heavy-duty  transport  will  require  new  infrastructure  to  produce  and  distribute 
new energy vectors, such as hydrogen, as well as to support carbon capture use and storage. 

Table  3  gives  an  overview  of  Belgium’s  objectives,  targets  and  contributions  under  the 
Governance  Regulation.  Table  3  lists  some  of  Belgium’s  national  targets  in  terms  of 
greenhouse gas emissions, renewable energy, primary and final energy consumption, and level of 
electricity  interconnectivity,  comparing  the  latest  available  data  with  the  targets  for  2020  and 
2030.  It  shows  that  for  all  indicators,  except  for  greenhouse  gas  emissions  and  electricity 
interconnectivity,  the  2030  ambition  level  is  rather  low  for  Belgium.  Additional  policies  and 
measures  will  be  needed  to  sustain  further  improvements  until  2030  and  to  achieve  the  2030 
targets,  in  the  electricity  and  especially  in  the  housing  (heating  and  cooling)  and  transport 
sectors. 

Table  3  -  Overview  of  Belgium’s  objectives,  targets  and  contributions  under  the  EU 
Governance Regulation 

National targets and contributions  

Binding target for greenhouse gas 
emissions compared to 2005 under the 
Effort Sharing Regulation (%) 

Latest 
available 
data 

2020 

2030 

-11% 

-15%  

-35% 

Assessment of 
2030 ambition 
level 

As in Effort 
Sharing Regulation 

6 

The highest share of renewable energy in 2020 was achieved in the electricity sector, with more than 20%. 

12 

 
 
 
 
                                                           
National target/contribution for 
renewable energy: Share of energy 
from renewable sources in gross final 
consumption of 
energy (%) 

9.9% 
(2019) 

National contribution for energy efficiency: 

13% 
(Renewable 
Energy 
Directive 
target) 

17.5% 

Low vs.  25% 
(contribution 
according to 
formula for 2030 
in the Governance 
Regulation) 

Primary energy consumption (Mtoe) 

Final energy consumption (Mtoe) 

49.1 
(2019) 
35.8 
(2019) 

47.8 

36.0 

42.7  

35.2 

Low 

Low 

Level of electricity interconnectivity 
(%) 

24 

24 

33 

High 

Source: Commission Assessment of the final national energy and climate plan of Belgium, SWD (2020) 900 final. 

The energy-efficient renovation of buildings represents a major challenge for reaching the 
2030 targets. The building sector is responsible for more than 30% of non-ETS GHG emissions 
in  Belgium.  Belgium  ranked  low  in  relation  to  the  energy  performance  of  its  existing  housing 
stock, which is rather old with 80% of the stock built before the introduction of energy norms. 
Despite  supportive  measures,  notably  in  the  forms  of  grants  and  tax  incentives,  the  yearly 
renovation rate of the housing stock stood at only 0.4% in recent years.7 Renovation is also held 
back  by  bottlenecks  affecting  the  construction  sector  like  long  building  permit  delays  and 
shortages  in  adequately  skilled  construction  workers.  Low  taxes  on  heating  fuels  (oil  and  gas) 
combined  with  relatively  high  electricity  prices,  do  not  incentivise  households  to  invest  in 
energy-efficient heating solutions. 

Belgium  needs  to  invest  in  sustainable  transport  infrastructure  and  improve  transport 
regulation. The transport sector is responsible for 35% of non-ETS GHG emissions in Belgium. 
Road  transport  congestion,  fueled  in  part  by  harmful  tax  expenditures  and  the  absence  of 
consistent road pricing for passenger cars, weighs on productivity and air quality in Belgium is a 
cause  for  concern.  After  several  years  of  underinvestment,  government  entities  have  designed 
and  launched  major  multiannual  investment  plans  in  railways  and  urban  transport.  Belgium 
performs  well  in  port  and  rail  infrastructure,  but  lags  behind  the  best  performing  countries  in 
electric mobility. Belgium is also performing well in rail freight, but scores low in the quality of 
passenger rail services and needs to improve the supply of rural-urban public transport. There are 
important  investment  needs  in  rail  infrastructure,  in  terms  of  rail  traffic  management  system, 
suburban (RER/GEN), cross-border and port connections. Uncertainty remains over the extent to 
which passenger rail services will be opened to competition (a pilot project has been announced 

7 
12. 

Conseil Centrale de l’Economie, 2019, Etat des lieux en matière de soutenabilité environnementale, page 

13 

 
 
 
 
 
 
 
 
 
 
                                                           
to  allocate  public  service  contracts  in  two  transport  areas  by  way  of  tenders),  and  the  railway 
regulator is understaffed. 

Achieving  emission  reduction  in  industry  will  involve  substantial  investments.  Crucial  for 
Belgian’s economic resilience will be the climate transformation of energy-intensive industries, 
such as the major petrochemical pole around Antwerp and steel around Liège and Ghent, which 
will  require  important  investments  in  carbon  capture,  low-carbon  hydrogen  and  biomass-based 
feedstock production and related transmission/distribution infrastructures. 

There is room to mitigate the negative effects of certain tax schemes, such as the company 
car  scheme,  which  leads  to  undesirable  environmental  consequences  in  terms  of  road 
travel.  The  favourable  tax  treatment  of  company  cars  (EUR  3.75  billion  or  0.9%  of  GDP 
annually)  contributes  to  the  growing  road  traffic  volumes.8  Although  alternatives  like  the  cash 
for  car  system  (which  has  been  annulled  by  the  Constitutional  Court)  and  the  mobility  budget 
were introduced, their take-up rate is very low, since all favourable elements of the company car 
scheme  (deductibility  of  fuel  costs  for  private  travel;  special  regime  of  social  security 
contributions  for  benefit-in-kind;  low  valuation  of  benefit-in-kind)  remain  in  place.  Moreover, 
infrastructure  charges  are  low  and  disregard  externalities.  Progress  has  been  limited  as  well 
concerning the reduction of  congestion and promotion of more sustainable modes of transport. 
Plans for a Belgian-wide km charge for passenger cars to follow the km-charge for lorries was 
put on hold due to divergences between the three regions. Nevertheless the Brussels region plans 
the introduction of a road pricing system in Brussels, depending on an agreement with Flanders 
and Wallonia. 

Overall,  there  is  significant  room  to  make  tax  and  subsidy  structures  more  environment 
friendly. Belgium annually spends EUR 2.5 billion on fossil fuel subsidies9 compared with EUR 
1.5  billion  on  sustainable  energy  subsidies.  Taxes  on  energy  do  not  reflect  environmental 
externalities  and  therefore  discourage  the  use  of  clean  energy  products  as  compared  to  fossil 
fuels.  Professional  transporters  and  agriculture  benefit  from  reduced  excise  rates  on  diesel. 
Excise  duties  on  fossil  fuels  used  for  heating  (gas  oil,  natural  gas,  etc.)  are  set  at  the  EU 
minimum level. Retail electricity prices are significantly above the EU average, which is in large 
part due to distribution costs (“intercommunales”), but also to levies used to finance renewable 
energy  support  programmes  and  other  purposes.  The  lower  excise  duties  for  heating  affect  the 
price signal to incentivise low-carbon energy efficiency investment decisions by households, e.g. 
to  lower  energy  consumption  or  to  switch  to  more  energy-efficient  and  cleaner  technologies. 
Reflecting  to  a  greater  extent  the  respective  carbon  or  energy  content  and  the  full  life  cycle 

8 
Looking at taxes and charges paid by transport users (excluding fixed infrastructure costs), in Belgium, rail 
users  pay  109%  of  their  total  external  and  variable  infrastructure  costs,  whereas  freight  users  only  cover  20%  of 
those costs. Road users pay around 43% (passenger) and 27% (freight) of their external and variable infrastructure 
costs. 
9 
company car scheme.  

This  amount  does  not  yet  take  into  account  foregone  social  security  contributions  in  the  context  of  the 

14 

 
 
                                                           
greenhouse  gas  intensity  of  fuels  and  electricity  would  help  reduce  GHG  emissions,  foster 
energy efficiency and generate tax revenue. Targeted measures alleviating energy poverty risks 
would  also  need  to  be  integrated  in  the  design  of  such  a  green  tax  shift.  Dealing  with  air 
pollution remains a significant challenge especially in the Antwerp and Brussels conurbations. 

Belgium has a small Natura 2000 network. In Belgium, 74% and 49% of the assessments for 
habitats and species, respectively, indicate an “unfavourable-bad” status10. Intensive agriculture, 
together with a high population density and, in Flanders, large land occupation rates for housing 
in  rural  areas  is  putting  biodiversity,  land  use  and  water  bodies  under  pressure.  Flanders  faces 
acute  nitrate  and  phosphorus  water  pollution  from  manure  and  is  also  suffering  from  periodic 
drought  concerns.  Wallonia  still  misses  adequate  urban  wastewater  treatment  for  a  handful  of 
agglomerations. 

Digital dimension 

In  2015,  Belgium  still  ranked  fifth  in  the  European  Commission’s  Digital  Economy  and 
Society Index (DESI), but fell to ninth place in the DESI 202011. Belgium performs only close 
to  the  EU  average  for  most  indicators.  However,  Belgium  is  an  EU  frontrunner  for  the 
integration of digital technologies by businesses (EU digital Scoreboard, 2021). 

Belgium  shows  a  mixed  performance  for  ultrafast  connectivity,  lagging  behind  for  fibre 
and  5G  readiness.  Belgium  performs  well  in  deploying  fast  and  very  high  capacity  fixed 
networks, thanks to an upgrade of the cable network, but lags behind for fibre and 5G readiness. 
Fibre deployment relies mostly on private investment. The copper incumbent has accelerated its 
fibre rollout plan to cover 50% of households by 2025 and 70% by 2028 and a cable operator has 
upgraded its network to provide very high speed offers to 3 million households in Flanders and 
Brussels. The Brussels region intends to provide commercial access to its 400km fibre network. 
Nevertheless, enhanced mobile networks, especially 5G deployment, are delayed (5G readiness 
of 3% in Belgium vs. 39% in EU). To cushion the delay, temporary 5G licenses were awarded in 
July 2020. Moreover, in January 2021, the federal  government tabled a draft law to organise a 
nation-wide and long-term 5G auction, with the objective to reach a 99.5% 5G coverage by mid-
2024. This auction was not expected to take place before mid-2022. In addition, after the auction, 
the  effective  5G  deployment  will  require  coordinated  action  between  government  levels  to 
remove  important  regulatory  barriers,  such  as  stringent  regional  radiation  limits  and  long  lead 
times  to  obtain  regional  environmental  permits  for  5G  antennae.  Belgium  therefore  needs  to 
increase its efforts to reach the Gigabit society 2025 and 2030 targets. 

According to the data provided by Belgium in 2019 in the context of the 6-year reporting under the Birds 

10 
and Habitat Directives. 
11 

DESI | Shaping Europe’s digital future (europa.eu). 

15 

 
 
                                                           
 
Belgium  faces  shortages  in  a  digitally  skilled  workforce  and  a  significant  part  of  the 
population  does  not  have  basic  digital  skills.  For  several  years  now,  while  above  the  EU 
average, there have been no real improvements in terms of the basic digital skills of adults (61% 
vs. EU average 56%) (DESI, 2020). The level of digital skills among young people is low. The 
Belgium ICT sector has the highest vacancy rates of the EU for workers with ICT skills, and also 
outside the ICT sector digital skills are becoming increasingly important. While there are small 
improvements in terms of the number of ICT specialists, upskilling and reskilling of workers to 
meet  the  challenges  posed  by  digitisation  remains  an  issue.  A  study  from  the  Technology 
Federation  Agoria  shows  that  4.5  million  workers’  digital  and  related  skills  need  to  be 
strengthened and that without appropriate policies, by 2030, almost 540.000 jobs would remain 
vacant in Belgium (Agoria, 2020). The share of ICT (2.1%) as well as STEM tertiary education 
graduates  (17.6%  in  2019)  is  fairly  low,  especially  for  women.  Moreover,  although  at  the  EU 
average, the share of women specialised in ICT has been decreasing. Belgium suffers from a lack 
of  a  sufficiently  digitally  skilled  workforce,  also  among  teachers.  Overall,  more  coordinated 
action  is  needed  from  all  stakeholder  groups  –  both  public  and  private  -  to  address  the  digital 
skills shortage in the country. 

While Belgium is an EU frontrunner for using digital technology for business, more efforts 
are needed to fully reap the benefits of the digital transition. Belgium tops the ranking of the 
proportion  of  companies  sharing  electronic  information  internally.  A  significant  share  of 
companies  has  also  integrated  advanced  technologies  such  as  big  data  (23%)  or  cloud  (43%), 
well  above  EU  average  (respectively  14%  and  26%).  There  is  still  room  for  improvement 
however for Belgium to consolidate its position. Companies still lagging behind could notably be 
supported via Digital Innovation Hubs12. SMEs are also performing well, above the EU average, 
with 24% of them selling online, and with 15% of SMEs selling online across borders well above 
the  EU  average  of  8%.  To  help  Belgian  companies  reap  the  benefits  of  the  digital  transition, 
more  efforts  are  required  to  digitally  re-  and  upskill  the  workforce  and  to  improve  public 
services’ digitisation. 

While Belgium is on par with other Member States in terms of digital public services offer 
to businesses, its offer of digital public services to citizens is  below potential.  Belgium has 
rolled out several e-government initiatives. Belgium scores well regarding online pre-filled forms 
and  public  services  offered  to  businesses,  including  eID  for  businesses  cross-border  mobility13 
(70% vs. EU: 36% in 2020). However, Belgium scores relatively low on e-government services 

More 

information 

12 
strategy.ec.europa.eu/en/activities/edihs. 
13 
country 
https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=69461.   

services  Source: 

Innovation 

This  indicator  measures  the  extent  to  which  business  users  of  public  services  from  another  European 
at: 

eGovernment  benchmark  –  2020, 

the  online 

can  use 

available 

available 

here: 

https://digital-

Digital 

Hubs 

on 

16 

 
 
                                                           
to citizens14 (71% vs. EU: 75%). This offer should be enlarged, with a focus on user-centricity to 
sustain  and further improve the uptake of these  services by  citizens, an area where  Belgium is 
already  performing  above  the  EU  average  (66.1%  vs.  EU:  64.2%).  A  further  area  of 
improvement concerns the use of open data, where Belgium scores well below the EU average 
(62.4%  vs.  EU:  78.1%).  There  is  also  room  for  improvement  regarding  the  use  of  eID  and 
electronic  documents  by  citizens.  Challenges  related  to  the  digitalisation  of  the  justice  system 
also remain, as well as long delays for the issuance of building and environmental permits, the 
award  of  public  procurements  and  the  judicial  review  of  environmental  and  building  permits, 
which if digitised, could be further streamlined. 

region  participates 

Belgium  has  signed  all  EU  declarations  on  development  and  deployment  of  advanced 
digital technologies. As already mentioned, the  take-up of digital  technologies, like cloud  and 
AI, by companies is well advanced. Belgium is a member of the EuroHPC Joint Undertaking and 
the  Brussels-Capital 
in  LUMI  a  pan-European  high-performance 
supercomputer  project15.  In  2019,  major  action  plans  and  strategies  at  different  government 
levels (e.g. AI4Belgium, DigitalWallonia4AI, Flemish Artificial Intelligence Action  Plan) have 
been  adopted  to  further  boost  AI  development.  In  the  field  of  cybersecurity,  similar  initiatives 
have  been  put  forward,  underpinned  by  financial  support  measures.  Belgium  benefits  from  a 
strong digital high-tech ecosystem with world-class players such as IMEC. Belgium is therefore 
in a strong position to reinforce its industrial capacities in advanced technologies such as next-
generation cloud, microelectronics or cybersecurity. 

Greening  of  the  digital  sector  policies  remains  limited.  Both  Wallonia  and  Flanders  have 
strategies and public support oriented towards circular economy, sustainable energy production 
and  reduction  of  energy  consumption.  In  2020,  the  Belgian  Institute  for  Sustainable  IT  was 
created, though it seems  mostly active in  Wallonia and Brussels  for the moment.  The Brussels 
and  Flemish  region  have  also  introduced  mandatory  sustainability  criteria  in  its  public 
procurement  procedures. However, policies at regional or national  level that  specifically target 
the  reduction  of  the  ICT  sector’s  environmental  footprint  remain  limited.  Actions  such  as 
Flanders’  DUET  project  on  urban  digital  twins,  which  aim  at  helping  public  sector  decision-
making to become more democratic and effective, should be multiplied. 

14 
This  indicator  measures  the  average  of  the  national  and  cross-border  online  availability  for  basic  and 
extended  public  services  within  the  citizen-related  life  events  from  the  last  two  years  (Family,  Career,  Studying, 
Moving, Owning and driving a car and Starting a small claims procedure). EU Digital scoreboard. 
15 

For more information see :https://www.lumi-supercomputer.eu/ 

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DESI 2020 -  relative performance by dimension 

DESI

1 Connectivity

2 Human capital

3 Use of internet
services

4 Integration of digital
technology

5 Digital public
services

Belgium

EU

Note: EU aggregate corresponds to EU28, based on 2020 DESI report. 

Box 1: Progress towards the Sustainable Development Goals and the four dimensions 
underpinning the Annual Sustainable Growth Strategy 

The objectives of the Sustainable Development Goals are integrated in the European Semester since 
the 2020 cycle. This provides a strong commitment towards sustainability in coordination of economic 
and  employment  policies  in  the  EU.  In  that  respect,  this  section  outlines  Belgium’s  performance  with 
respect  to  SDGs  with  particular  relevance  for  the  four  dimensions  underpinning  the  2021  Annual 
Sustainable  Growth  Strategy  and  of  relevance  to  the  recovery  and  resilience  plans  (green  transition, 
fairness, digital transition and productivity, and macroeconomic stability), indicating possible areas where 
investments and reforms in line with the objectives of the Facility could further accelerate the progress on 
the SDGs. 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
Green Transition 

In  relation  to  waste  generation  and  management,  Belgium’s  performance  is  relatively  good  with 
production of waste per capita (415 kg per inhabitant) in 2019 well below the EU (502 kg). The measures 
included  in  the  circular  economy  component  aim  to  further  improve  the  use  of  resources  and  waste 
management, and therefore positively contribute to SDG 12. 

Belgium has well above-average nitrates and phosphate pollution problems, and there is high pressure on 
biodiversity.  The  measures  in  the  climate  and  environment  component  address  adaptation  to  climate 
change, improving resilience to droughts and heat waves but also aim at strengthening natural ecosystems 
and enhancing biodiversity in line with SDGs 13 and 15. The Blue Deal measure specifically addresses 
the problem of water scarcity targeted by SDG 6. It will support an increase in water use efficiency and 
actions  to  ensure  sustainable  withdrawals  and  supply  of  freshwater,  benefitting  different  sectors  of  the 
economy, such as agriculture, industry and water transport. 

Facing a big challenge to decarbonise the economy and achieve carbon neutrality in 2050, the measures 
included  in  the  emerging  technologies  component  of  the  plan  aim  at  reducing  the  CO2  footprint  of 
industry and heating sectors and stimulating clean hydrogen use and production. These measures should 
contribute positively to SDG 7. 

19 

 
 
 
Fairness 

Belgium  outperforms  the  EU  average  in  most  indicators  related  to  poverty,  inclusive  growth  and 
inequality (SDGs 1, 8, 10). Belgium is a good performer in reduced  inequalities (SDG 10) thanks to its 
tax and benefit system. Several measures in the plan contribute to reduce skills mismatches and address 
discrimination in the labour market to increase the employment rate of vulnerable groups in Belgium and 
further accelerate the progress on SDG 1 and 8. 

The  plan  also  contains  several  investments  in  social  housing  and  sustainable  mobility,  with  special 
attention  to  persons  with  disabilities,  contributing  to  the  delivery  of  SDG  11  in  this  way.  Dedicated 
investments  and  reforms  to  make  the  education  and  training  systems  across  communities  more  digital 
transition-proof are also included in the plan (SDG 4). 

While  Belgium  already  scores  above-EU  average  on  gender  equality  indicators  (SDG  5),  several 
measures  in  the  plan  are  likely  to  have  a  positive  impact  on  gender  equality  according  to  the  Belgian 
Institute  for  Equality  of  Women  and  Men,  e.g.  increased  investments  in  childcare  in  Wallonia  may 
support female labour participation, in particular as they are targeted towards municipalities with a high 
share of vulnerable households. 

Digital transition and productivity 

In  Belgium,  the  percentage  of  young  people  not  mastering  basic  skills,  STEM  and  digital  skills  can  be 
improved  and  the  gap  in  educational  outcomes  linked  to  socio-economic  and  migration  background  is 
high  (SDG  4).  Moreover,  the  adult  participation  in  life-long  learning  is  below  EU  average  (SDG  4). 
Several measures in the plan are expected to help address this challenge to ensure access to equitable and 
quality education is guaranteed through all stages of life. These include investments in upgrades of digital 
connectivity and equipment in schools in all three language communities to increase the effective use of 
technology and digital learning tools in schools. Reforms in the plan to boost life-long learning include 
the introduction of an individual learning account. 

Belgium’s 5G and fibre connectivity is lagging behind (SDG 9). The plan includes reforms that aim to 
remove regulatory bottlenecks to deploy the necessary very high-capacity connectivity infrastructure that 
are  important  building  blocks  for  Belgium’s  green  and  digital  transformation.  In  addition,  the  plan 
includes some  connectivity  investments  in  schools and  in  mostly  rural  areas,  contributing  to  affordable 
and equitable very high-capacity access for all in this way. The plan includes several measures to reduce 
the  impact  on  the  transport  sector  on  the  environment.  The  reform  of  the  company  car  scheme,  which 
excludes conventional cars from the scheme, is expected to provide a significant contribution to reach the 
targeted reduction in green-house gas emissions (SDG 9). The plan also includes a measure to promote 
effective  civil  society  partnerships  for  the  digital  transition (SDG  17),  by  promoting  the  co-creation  by 
citizen committees of human-centric AI technologies. 

Macroeconomic stability 

Belgium  performs  well  on  the  quality  of  its  institutions,  including  trust  in  institutions  (SDG  16). 
However, the digital transformation of the justice system in Belgium has been lagging behind. The plan 
includes measures to tackle this challenge, which are expected to contribute to the efficiency of the justice 
system. Moreover, the plan includes measures that contribute to better public digital access to information 
through investments in government open data platforms. 

Belgium also outperforms the EU average on indicators related to sustainable economic growth (SDG 8). 
However,  the  level  of  public  debt  is  high  and  increasing,  which  represents  a  risk  in  terms  of  fiscal 

20 

 
 
sustainability.  Moreover,  the  employment  rate is low  and the  sizeable  share  of young  people  neither in 
employment  nor  in  education  and  training  is  a  concern  in  Belgium,  in  particular  in  urban  areas.  In 
addition, the unemployment rate, which had declined in recent years, is now increasing again due to the 
crisis. The introduction of spending reviews at all government levels, as foreseen by the plan, is expected 
to improve the quality and composition of expenditure and enhance macroeconomic stability (SDG 8). 

3.  OBJECTIVES, STRUCTURE AND GOVERNANCE OF THE PLAN 

3.1. Overall strategy of the plan 

The National Plan for Recovery and Resilience of Belgium aims to accelerate the transition 
towards  a  more  sustainable,  low-carbon  and  climate-resilient  economy,  to  maximize  the 
benefits of the digital transformation and to ensure social cohesion and a high level of well-
being  for  citizens.  The  plan  also  intends  to  improve  connectivity  within  the  country,  boost 
labour market performance, innovation capacity of the economy and to improve the composition 
of  public  finances.  Moreover  the  plan  supports  the  objective  of  increasing  public  investment, 
contributing to close the gap created by a structural lack of public investment in the last decades. 

The plan is structured into six strategic axes and 17 components. The six strategic axes are 
(1) climate, sustainability and innovation, (2) digital transformation, (3) mobility (4) social and 
living  together,  (5)  economy  of  the  future  and  productivity  and  (6)  public  finances.  Under  the 
different  axes,  the  plan  presents  a  total  of  17  components  combining  reform  and  investment 
measures (Table 4). 

Table 4 – Axes, components and associated costs of the Belgian recovery and resilience plan 

Axes 

Component 

Climate, 
sustainability 
and innovation 
Digital 
transformation 

Mobility 

Social and 
living-together 

Economy of 
the future and 
productivity 

C 1.1 Renovation 
C 1.2 Emerging energy technologies 
C 1.3 Climate and environment 
C 2.1 Cybersecurity 
C 2.2 Public administration 
C 2.3 Optic fibre, 5G and new technologies 
C 3.1 Cycling and walking infrastructure 
C 3.2 Modal shift 
C 3.3 Greening road transport 
C 4.1 Education 2.0 
C  4.2  Training  and  employment  of  vulnerable 
groups 
C 4.3 Social infrastructure 
C 4.4 End of career and pensions 
C 5.1 Training and labour market 
C 5.2 Supporting economic activity 
C 5.3 Circular economy 

Costs 
(EUR million) 
1 012 
608 
400 
79 
584 
100 
411 
672 
209 
442 
165 

% of the 
total 
17.1% 
10.3% 
6.8% 
1.3% 
9.9% 
1.7% 
6.9% 
11.3% 
3.5% 
7.5% 
2.8% 

227 
0 
371 
439 
198 

3.8% 
0.0% 
6.3% 
7.4% 
3.3% 

21 

 
 
 
Public finances  C 6.1 Spending reviews 

8 
5 925 

0.1% 
100% 

Under the climate, sustainability and innovation axis (Axis 1), the plan aims at accelerating 
the  transition  to  a  decarbonised,  sustainable  and  climate-resilient  economy.  This  axis 
reinforces the National Energy and Climate Plan of December 2019 paving the way for a long-
term  transition  towards  climate  neutrality.  The  component  1.1  ‘Renovation  of  buildings’ 
proposes a large renovation programme focused on improving the energy efficiency of buildings. 
The  component  1.2  ‘Emerging  energy  technologies’  concerns  investments  in  research  and 
development and demonstration of new energy technologies, as well as hydrogen, CO2 and heat 
network  infrastructure,  along  the  adaptation  of  the  associated  regulatory  and  fiscal  framework. 
The  component  1.3  ‘Climate  and  environment’  aims  to  restore  biodiversity  and  strengthen 
adaptability  and  resilience  to  climate  change.  In  particular,  investments  will  focus  on  the 
accelerated  creation  of  a  coherent  set  of  natural  areas,  forests  and  riverbeds  acting  as  carbon 
sinks and mitigating the consequences of floods and droughts. 

The  digital  transition  axis  (Axis  2) 
intends  to  accelerate  the  country’s  digital 
transformation while making Belgium more resilient to the risk of cyber threats. The first 
component  of  this  axis,  ‘Cybersecurity’  (component  2.1)  aims  at  significantly  strengthening 
Belgium’s resilience to these new risks by developing protection tools and a real cybersecurity 
competence  hub.  Under  component  2.2  ‘Public  administration’  significant  investments  seek  to 
accelerate the digitalisation of public services to improve the efficiency of services provided to 
citizens and businesses at all levels of government, including local authorities. Digitalisation will 
also  be  pursued  for  the  benefit  of  the  healthcare  system  and  of  enterprises  in  the  media  and 
cultural sector. Component 2.3 ‘Optic fibre, 5G and new technologies' aims to resorb delays in 
5G  deployment  and  providing  universal  and  affordable  access  to  connectivity  in  all  urban  and 
rural areas. 

A  third  objective  of  the  plan  is  to  improve  mobility  and  better  connect  Belgian  regions, 
while  ensuring  a  modal  shift  in  transport  to  the  benefit  of  both  the  environment  and  all 
citizens (Axis 3). The first component of this axis focuses on the development of active modes 
of transport and soft mobility (component 3.1 ‘Cycling and walking infrastructure’). Investing in 
cycling infrastructure seeks to bring benefits in terms of jobs and growth and reduce health risks 
associated with sedentary lifestyles. Component 3.2 ‘Modal shift’ aims to improve the provision 
of  public  transport  services  to  make  public  transport  an  attractive  alternative  to  the  use  of 
personal cars and reduce congestion and greenhouse gas emissions. These investments also aim 
to improve public health through reduced pollution and noise, increased safety and more active 
lifestyles. Support is also proposed for a modal shift from road freight to inland waterways and 
rail  freight.  Component  3.3  ‘greening  road  transport’  presents  measures  to  accelerate  the 
transition  towards  cleaner,  mainly  electric,  car  and  bus  fleets.  Measures  proposed  include  a 
reform of the company car scheme and the introduction of new incentives for the electrification 
of  transport,  complemented  by  investments  in  the  development  of  charging  infrastructure  and 
greener bus fleets. 

22 

 
 
 
 
 
Strengthening  social  cohesion  and  living  together  by  ensuring  effective  and  inclusive 
education systems and the inclusion of the most vulnerable groups, is the fourth strategic 
focus  of  the  plan  (Axis  4).  Component  4.1  ‘Education  2.0’  aims  to  improve  the  overall 
performance  and  inclusiveness  of  education  systems  in  Belgium.  Particular  emphasis  is  placed 
on the acquisition of skills — including digital STEM skills — in line with labour market needs. 
The  component  also  aims  to  combat  early  school  leaving  and  support  those  who  have  fallen 
behind  at  school.  Component  4.2  ‘Training  and  employment  of  vulnerable  groups’  aims  at 
fostering  the  participation  of  vulnerable  groups  (low-skilled,  women,  people  with  a  migrant 
background, people with disabilities) to the labour market. The component includes measures to 
boost the employability of the most vulnerable groups, including by reducing digital inequalities. 
Component  4.3  ‘Social  infrastructure’  seeks  to  address  the  lack  of  social  housing  for  most 
vulnerable  groups  and  increase  early  child  care  provision,  in  particular  for  vulnerable 
households.  Component  4.4  ‘End  of  career  and  pensions’  focuses  on  reforming  the  pension 
system and end of careers, with a view to  increasing the activity and employment rate of older 
workers. 

The  fifth  axis  seeks  to  strengthen:  smart  and  sustainable  growth  by  improving  labour 
market  functioning,  the  competitiveness  of  businesses  by  supporting  research  and 
innovation,  and  the  circular  economy,  especially  for  businesses  (Axis  5).  Component  5.1 
‘Labour market and training’ aims to increase the employment rate while ensuring an inclusive 
labour market, with measures focused on skills acquisition in line with current and future labour 
market needs, including the green and digital transition. The plan refers to the preparation of a 
broad tax reform that notably aims at reducing labour taxation. However, no commitment on the 
adoption by the Parliament is provided in the plan for that reform. Labour market participation is 
to  be  stimulated  through  training,  activation  and  coaching.  Component  5.2  ‘Supporting  the 
economy’ supports research and innovation to develop the country’s future economic potential, 
and  foster  the  development  of  activities  that  offer  promising  opportunities  in  terms  of  added-
value  creation.  In  addition,  it  supports  the  implementation  of  efficient  production  processes 
based  on  emerging  technologies  and  the  transition  to  a  shorter,  more  sustainable  food  chain. 
Finally,  component  5.3  ‘Circular  economy’  fosters  the  transition  to  a  circular  economy  to 
address  climate  and  environmental  risks,  to  strengthen  resilience  to  international  price 
fluctuations  and  foreign  supply,  and  to  foster  social  resilience  by  creating  local  employment 
opportunities. 

The sixth main objective of the plan is to improve the composition of public expenditures 
(Axis  6).  Spending  reviews  conducted  at  all  level  of  governments  are  expected  to  support  this 
objective under the only component of this axis (component 6.1 ‘Spending reviews’). The aim is 
to  improve  expenditure  control  to  make  it  possible  to  release  resources  for  new  policies, 
including  growth-  and  environmentally  friendly  expenditure,  or  to  help  fiscal  consolidation, 
particularly in the context where fiscal space is limited, and to ensure Belgium’s fiscal resilience. 

The timeline of the plan is  somewhat frontloaded, as a large share of investments will  be 
made during the first years of the RRF period. However, there is still a share of investments 

23 

 
 
which are expected to be achieved only in 2026, which could in part be explained by the fact that 
some large-scale projects will take several years to be completed. 

24 

 
 
 
 
3.2. Implementation aspects of the plan 

Consistency with other programmes 

The Recovery and Resilience Plan of Belgium provides justification for its consistency with 
the objectives and priorities of other initiatives. The plan contributes to the objectives of the 
National  Energy  and  Climate  Plan  and  is  complementary  to  the  forthcoming  Partnership 
Agreement  with  Belgium  due  to  be  submitted  in  2021  and  the  programmes  for  the 
implementation of the Structural Funds, and the Youth Guarantee plans. 

As regards  the Multiannual  Financial Framework 2021-2027, the  Partnership Agreement 
with  Belgium  and  the  Operational  programmes  for  the  implementation  of  the  Structural 
Funds are still under preparation. The plan stipulates that their structure shall, among others, 
reinforce  and  complement  the  projects  supported  by  the  RRF  to  optimise  the  use  of  all  the 
European  funds  allocated  to  Belgium.  This  seems  particularly  relevant  for  areas  where 
investments  that  will  be  kick-started  with  RRF  support  could  also  benefit  from  support  under 
ERDF and ESF+ to increase their long-term impact. The plan intends to ensure complementarity 
of  funding  and  avoidance  of  double  funding  in  the  Regions  and  Communities.  The 
implementation of the Structural Funds will run in parallel with the RRF under their own rules 
and eligibility timeframe. 

The  investments  and  reforms  included  in  the  Belgian  recovery  and  resilience  plan  fit  a 
broader  national  recovery  strategy,  pursued  at  the  different  levels  of  government  in 
Belgium. The federal  investment  and reform projects  fall within the broader framework of the 
Federal government’s recovery strategy and will be integrated into the Investment Recovery Plan 
as provided for in the Government Agreement. The Federal  government has set up a EUR 750 
million  Transformation  Fund  within  the  Federal  Holding  and  Investment  Company  which  will 
invest  in  the  first  five  axes  defined  under  the  plan.  Flanders  defined  its  Resilience  plan 
‘Veerkracht  Vlaanderen’)  worth  EUR  4.3  billion  in  September  2020.  The  projects  worth  EUR 
2.25 billion of the Flemish Government as part of the Recovery and Resilience Plan are all part 
of  the  Flemish  resilience  plan.  The  Walloon  projects  under  the  Recovery  and  Resilience  Plan 
also  supports  Wallonia’s  own  recovery  strategy  ‘Get  Up  Wallonia’.  The  Brussels  government 
adopted its recovery  and redeployment plan  for the Brussels-Capital  Region in  response to  the 
COVID-19  crisis  in  July  2020,  complemented  by  additional  stimulus  and  redeployment 
measures. These investment projects were incorporated as a priority in the Belgian recovery and 
resilience plan. The German-speaking Community’s contribution to the Belgian recovery plan is 
linked  to  the  regional  strategic  development  plan  ‘Regionale  Entwicklungskonzept’  and  more 
specifically the strategic visions for ‘Ostbelgien Leben 2025’. 

25 

 
 
 
 
Consistency with the Commission Recommendation for a Council Recommendation on the 
economic policy of the euro area16  

The Belgian plan is  broadly  consistent with  the challenges and priorities identified  in the 
Commission  Recommendation  for  a  Council  Recommendation  on  the  economic  policy  of 
the  euro  area  (EAR).  It  contributes  to  EAR  1,  to  ensure  a  policy  stance  which  supports  the 
recovery, by pursuing reforms to strengthen the coverage, adequacy and sustainability of social 
protection systems, most notably in the area of pensions. The pension reform included in the plan 
aims to reinforce the insurance principle of the pension system by increasing minimum pensions 
and strengthening the link between contributions and benefits. To ensure the long-term financial 
sustainability of the system, different measures are being considered in the context of the reform 
to  incentivise  older  workers  to  remain  active  on  the  labour  market  such  as  the  introduction  of 
part-time  pensions,  the  introduction  of  a  pension  bonus,  increased  investment  in  life-long 
learning and the facilitation of career reorientation for older workers. The plan also contributes to 
the improvement of public finances management through the systematic integration of spending 
reviews in the budget planning cycles at regional, community and federal government levels with 
a view to improving public spending efficiency. With respect to EAR 2 to improve convergence, 
resilience and sustainable and inclusive growth, reforms and investments in the plan are expected 
to support overall productivity and an improved efficiency of the public administrations’ action. 
This  should  foster  private  investment  to  address  the  recovery  and  the  twin  green  and  digital 
transition.  In  parallel,  efforts  will  be  made  to  match  the  skills  of  human  capital  with  labour 
market  needs  through  the  modernisation  of  education  and  training  systems,  and  to  promote 
effective  active  labour  market  policies.  When  it  comes  to  EAR  3  to  strengthen  national 
institutional frameworks, the plan also provides for important measures to modernise and digitise 
public  administrations.  In  the  area  of  business  environment,  some  measures  aim  to  remove 
unnecessary or disproportionate administrative barriers to business creation and growth. 

Administrative organisation 

The  Secretary  of  State  for  Recovery  and  Strategic  Investments  is  responsible  for 
coordinating the implementation of the plan at inter-federal level. The Secretary of State will 
remain the technical contact point with the European Commission in the implementation phase 
of the recovery and resilience plan. The administrative follow-up of the plan will be carried out 
by  an  inter-federal  Monitoring  Committee,  composed  of  representatives  of  all  the  entities 
responsible for the reporting and administrative follow-up of projects under their responsibility. 
The Committee will be chaired by the permanent secretariat of the Federal Public Service Policy 
and  Support  (BOSA)  which  shall  ensure  continuity  of  overall  coordination  of  the  plan  and 
technical  contacts  with  the  European  Commission,  in  collaboration  with  the  Secretary  of  State 

16 
Pending final adoption by the Council, after endorsement by the European Council. The text agreed by the 
Eurogroup  on  16  December  2020  is  available  at:  https://data.consilium.europa.eu/doc/document/ST-14356-2020-
INIT/en/pdf 

26 

 
 
                                                           
for  Recovery  and  Strategic  Investments.  The  Monitoring  Committee  will  monitor  the 
implementation  and  achievements  of  the  plan,  coordinate  the  preparation  of  each  payment 
request,  identify  risks  of  not  meeting  milestones  and  targets  and  propose  solutions  if  risks 
materialise. 

Gender equality and equal opportunities for all 

With  regard  to  gender  equality  and  equal  opportunities  for  all,  the  plan  follows  a  dual 
approach  of  responding  to  the  consequences  of  the  pandemic  and  addressing  more 
structural factors leading to inequalities. Even though Belgium scored 3.5 points higher than 
the EU average on  gender equality in  2020, certain  challenges persist in areas including lower 
labour  market  participation  of  women,  in  particular  for  those  with  a  non-EU  migrant 
background.  Moreover,  considerably  less  women  have  STEM  degrees  and  use  digital  public 
services compared to the EU average.  The Belgian Institute for the Equality of Women and Men 
considers that 18% of investments under the plan will have a positive impact on gender equality 
and  about  52%  will  have  a  potential  positive  impact  on  gender  equality.  Considering  that  a 
number  of  investments  could  potentially  create  a  significant  short-term  demand  for  labour  in 
currently  male-dominated  sectors  like  the  construction  sector,  Belgium  should  effectively 
monitor  that  its  implementation  is  aligned  with  the  objective  of  promoting  gender  equality.  In 
this context, Belgium has indicated in the plan that the Consultation Committee will encourage 
all  entities  to  closely  monitor  the  impact  of  projects  on  gender  equality  and  to  consider  the 
necessary accompanying measures. The plan contains a number of dedicated measures to address 
challenges to ensure equal  opportunities for all  and to  reach the European Social Pillar Action 
Plan objectives by 2030. It promotes the integration of gender equality and equal opportunities in 
a  number  of  reforms  and  investments  across  the  plan,  including  in  relation  to  the  green  and 
digital transition. Although the plan falls short of presenting a holistic and integrated approach to 
support  social  and  labour  market  inclusion  for  vulnerable  groups,  it  does  include  a  set  of 
measures dedicated to supporting the inclusiveness of education systems and to promoting social 
integration and inclusion in the labour market. 

Consultation process 

As outlined in the plan, Belgium has consulted a wide range of stakeholders in the plan’s 
adoption  process  to  increase  national  ownership  of  the  plan.  The  different  Belgian  entities 
have  defined  autonomously  and  with  due  regard  to  their  competences,  the  arrangements  for 
involving  a  wide  range  of  stakeholders  including  social  partners,  civil  society  and  other 
stakeholders in the design of the measures under their responsibility. 

At  the  federal  level,  many  stakeholders  were  consulted,  including  social  partners,  civil 
society and the gender equality body. The federal government set up an advisory committee, 
consisting of the Central Economic Council (with the support sometimes of the National Labour 
Council) and the Federal Council for Sustainable Development, bringing together social partners 
and  civil  society  (environmental  organisations,  organisation  for  development  cooperation, 
consumer  organisation,  youth  organisations  and  the  scientific  world)  that  provided  advice  at 
different  stages  in  the  plan’s  preparation  process.  Moreover,  the  Institute  for  the  Equality  of 

27 

 
 
Women  and  Men  was  consulted  to  assess  the  impact  of  the  plan  on  gender  equality  and 
formulate recommendations. 

Regional and community governments consulted social partners on their respective reform 
and  investment  projects,  and  also  exchanged  with  regional  parliaments.  The  Flemish 
government consulted the Flemish social partners organised in the Social and Economic Council 
of Flanders (SERV) and exchanged with the Flemish Parliament on the Plan. In the context of a 
presentation  on  the  overall  Flemish  recovery  plan,  the  Flemish  government  also  answered 
stakeholders’  questions  on  projects  intended  to  be  financed  by  the  Recovery  and  Resilience 
Facility.  The  Walloon  government  requested  the  opinion  of  the  Economic,  Social  and 
Environmental Council of Wallonia, which brings together representatives of employers’, trade 
unions  and  environmental  organisations.  The  Walloon  government  also  addressed  questions 
from the Parliament of Wallonia on the process and substance of the plan. In the Brussels-Capital 
Region,  the  consultation  process  with  social  partners  (Brupartners)  was  organised  around  the 
elaboration  of  the  GO4Brussels  2030  Strategy,  and  its  adaptation  to  take  into  account  the 
measures for Brussels that were integrated in the plan. The French Community government also 
consulted stakeholders notably in the education field and exchanged with the entity’s parliament 
The German-speaking Community government consulted social partners (Economic and Social 
Council  of  the  German-speaking  Community),  as  well  as  other  relevant  stakeholders  and 
exchanged  with  the  Parliament,  in  the  course  of  committee  and  plenary  hearings.  Belgium  is 
committed to continue to reach out to social partners and civil society during the implementation 
phase of the plan. 

Cross-border and multi-country projects 

The Belgian plan contains a number of investment measures with a significant cross-border 
dimension. In component 1.2, this applies notably to the three measures (at federal, Flemish and 
Walloon  level),  which  jointly  focus  on  supporting  an  industrial  value  chain  in  the  field  of 
hydrogen  (I-1.15,  I-1.16,  I-1.17).  A  prominent  part  of  these  investments  will  form  part  of  the 
planned  wider  cross-border  Important  Projects  of  Common  European  Interest  (IPCEI)  on 
hydrogen. Likewise, the investment project ‘Backbone for H2 and CO2’ (I-1.14) of the federal 
level foresees creating future interconnections with neighbouring countries of the initial H2 and 
CO2  transport  networks  that  are  part  of  the  plan.  Finally,  the  investment  measure  ‘Off-shore 
energy  island’  (I-1.21)  aims  at  developing  a  multifunctional  offshore  energy  hub  (‘energy 
island’) in the Belgian part of the North Sea. Among other things, this energy hub is to facilitate 
the integration and import of more renewable energy in and around the North Sea by connecting 
to other countries or regions. In component 5.2, Flanders’ measure to strengthen R&D includes 
an envelope earmarked to finance the potential participation of Flemish businesses to the planned 
IPCEI on microelectronics. 

Communication strategy 

The Belgian plan outlines the main elements of its communication strategy. Each entity will 
remain  responsible  for  its  own  communication  strategy  and  for  ensuring  compliance  with  the 
communication requirements of the RRF Regulation and the Commission’s guidance. However, 

28 

 
 
to ensure communication consistency across entities, Belgium will set up a dedicated website for 
the  Belgian  recovery  and  resilience  plan  in  Dutch,  French,  German  and  English  to  present  the 
measures  and  the  components  of  the  plan  per  thematic  axis,  per  region/province  and  per 
competent entity in an interactive way. The website, which is expected to be operational by the 
end  of  July  2021,  will  be  regularly  updated  with  information  on  the  implementation  of  the 
measures.  In  addition,  the  plan  states  that  several  entities  can  organise  coordinated  outreach 
activities. In addition, a three-year recovery and resilience plan communication strategy will be 
developed,  consisting  of  strategic  annual  communication  plans  and  quarterly  operational 
planning of the communication items  to  be implemented (such  as the media plan, the types of 
outreach events to  be organised, the target audience, the objectives and format of the outreach 
events). Belgium intends to organise a launch event to give maximum visibility to the recovery 
and  resilience  plan  to  a  multitude  of  stakeholders  including  journalists,  civil  society 
organisations,  industry,  political  actors  (at  federal,  regional,  community  and  local  levels), 
financial actors, and EU institutions. In addition, Belgium aims to organise bi-annual events that 
are to coincide with the publication of interim EU implementation reports on the plan. 

State aid 

State  aid  and  competition  rules  fully  apply  to  the  measures  funded  by  the  Recovery  and 
Resilience Facility. Union funds channelled through the authorities of Member States, like the 
RRF funds, become State resources and can constitute State aid if all the other criteria of Article 
107(1)  TFEU  are  met.  When  this  is  the  case  and  State  aid  is  present,  these  measures  must  be 
notified and approved by the Commission before Member States can grant the aid, unless those 
measures are covered by an existing aid  scheme or comply  with  the applicable conditions  of a 
block  exemption  regulation,  in  particular  the  General  Block  Exemption  Regulation  (GBER) 
declaring certain categories of aid compatible with the internal market in application of Articles 
107 and 108 TFEU. When State aid  is  present  and it requires notification, it is  the duty of the 
Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance  with  Article  108(3)  TFEU.  In  this  respect,  the  State  aid  analysis  carried  out  by 
Belgium in the recovery and resilience plan cannot be deemed a State aid notification. In as far 
as Belgium considers that a specific measure contained in the recovery and resilience plan entails 
de  minimis  aid  or  aid  exempted  from  the  notification  requirement,  it  is  the  responsibility  of 
Belgium to ensure full compliance with the applicable rules. Measures in the plan should also be 
compatible with the EU’s international obligations, in particular under World Trade Organization 
rules. 

4.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

4.1. Comprehensive  and  adequately  balanced  response  to  the  economic  and  social 

situation  

The  plan  follows  a  holistic  approach  to  foster  the  recovery,  addressing  many  challenges 
related to all six pillars. The plan contains 140 measures (35 reforms and 105 investments) that 

29 

 
 
 
refer to the policy areas of European relevance structured in the six pillars on the basis of which 
the  scope  of  the  RRF  is  defined.  The  plan  is  expected  to  contribute  to  tackling  key  structural 
challenges and to contribute to the green and digital transition.The coverage of the six pillars by 
the  Belgian  plan’s  components  is  summarized  in  Table  5.  All  pillars  are  covered  by  several 
components while a component may contribute to several pillars. 

Table 5 – Coverage of the six pillars of the Facility by Belgian recovery and resilience plan 
components 

Components of the Plan 

Pillars of the Recovery and Resilience Facility 

Axis 1 

Axis 2 

Axis 3 

Axis 4 

Axis 5 

1.1.Renovation of buildings 
1.2.Emerging energy technologies 
1.3.Climate & Environment 
2.1.Cybersecurity 
2.2.Public administration 
2.3.Fibre optic, 5G and new technologies 
3.1.Cycling and pedestrian infrastructure 
3.2.Modal shift 
3.3.Greening road transport 
4.1.Education 2.0 
4.2.Training and employment for vulnerable groups 

4.3.Social infrastructure 
4.4.End of career and pensions 
5.1.Training and labour market 
5.2.Support for economic activity 
5.3 Circular Economy 
6.1.Spending reviews 

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Axis 6 
Key: “●” investments and reforms of the component significantly contribute to the pillar; “○” the component 
partially contributes to the pillar 

The plan is overall balanced and meets the minimum thresholds for the green and digital 
pillars. The plan is comprehensive in addressing the different pillars, in a broadly balanced way.  

1st Pillar: Green transition 

The plan extensively covers the ‘first pillar’, with more than half of its components (10 out 
of  17  components)  being  directly  related  to  the  green  transition.  Measures  in  the  plan  are 
expected to help accelerate the implementation of the Belgian National Energy and Climate Plan 
(NECP) for 2021-2030.  

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A broad range of measures contribute directly or indirectly to the green transition, favour 
biodiversity  and  environmental  protection.  In  order  to  implement  climate-related  policy 
measures,  such  as  in  the  areas  of  energy  transition  and  adaptation  to  climate  change,  the  plan 
envisages taking a broad range of measures that can be grouped in the following major areas: 

  Renovations  and  energy-efficient  constructions  of  buildings  (component  1.1,  as  well  as 

energy-efficient renovations of training facilities in component 5.1); 

  Emerging  energy  technologies  (component  1.2)  with  investments  in  renewable  energy 
(energy  island),  the  hydrogen  value  chain  and  a  hydrogen  and  carbon  backbone,  and 
accompanying legal and fiscal frameworks; 

  Sustainable mobility (components 3.1, 3.2, 3.3) with  measures developing soft mobility 
infrastructure, modal shift in particular towards rail and the greening of road transport; 
  Biodiversity  and  the  protection  of  the  environment  (Component  1.3)  in  particular  with 
projects on water management and biodiversity in Flanders and sustainability of forests 
and restoration of biodiversity in Wallonia; 

  Circular economy (component 5.3); 
  Support  to  economic  activity  (component  5.2)  with  measures  to  support  R&D  and  the 

green transition in the food sector; 

  Skills  for  the  green  transition  (component  5.1);  with  renovation  and  equipment  of 

training facilities notably in support of acquisition of skills for the green transition; 

  Social  infrastructure  (component  4.3)  through  the  energy-efficient  renovation  of  child 

care facilities. 

Measures contributing to the climate target exceed the minimum threshold required under 
the Recovery and Resilience Facility. Based on the methodology for climate tracking set out in 
Annex  VI  of  Regulation  (EU)  2021/241,  49.6%  of  the  plan  contributes  to  the  climate  target, 
measured  as  the  total  estimated  cost  of  the  contributing  actions  as  a  percentage  of  the  total 
allocation,  thereby  complying  with  the  minimum  threshold  of  37%,  with  a  direct  contribution 
from 10 of the 17 components. 

2nd Pillar: Digital transformation 

The  plan  covers  the  ‘second  pillar’  on  digital  transformation,  with  eleven  components 
directly contributing to Belgium’s digital transformation through investments and reforms. 
These measures are aligned with European digital policy initiatives such as the European digital 
strategy, the European skills agenda, the European Pillar of Social Rights, the European Single 
Digital  Gateway,  the  European  Education  Area  and  the  digital  education  action  plan  and  the 
European Health Data Space. 

The  plan  addresses  digital-related  challenges  in  the  three  components  in  the  digital 
transformation axis. The plan aims at developing cybersecurity capabilities (2.1), improving the 
efficiency of public services through digitalisation to the benefit of both individual and business 
end-users  (component  2.2),  and  developing  digital  gigabit  connectivity  (component  2.3). 

31 

 
 
 
Reforms  contained  in  component  5.2  also  contribute  to  develop  digital  gigabit  connectivity  by 
removing regulatory bottlenecks in line with the planned review of building and environmental 
permits procedures. 

Additional  components  contribute  to  developing  digital  skills  and  digital  inclusion  in 
Belgium.  The  plan  includes  measures  to  increase  the  effective  use  of  technology  and  digital 
learning tools in schools and higher education institutions (component 4.1), increase digital skills 
of the adult population,  including vulnerable  groups (component 4.2),  use technology in  social 
housing  to  delay  or  avoid  that  people  in  loss  of  autonomy  move  to  eldercare  facilities 
(component  4.3)  and  develop  training  facilities  and  training  programmes,  with  a  focus  on  the 
digital transition (component 5.1). 

Some measures under the mobility, productivity and sustainability axes also contribute to 
the digital transformation. Component 3.2 Modal shift is expected to contribute to the digital 
transformation,  thanks  to  measures  to  develop  mobility-as-a-service  and  smart  mobility. 
Measures  in  component  5.3  include  investments  in  digital  solutions  within  circular  economy 
projects  and  measures  including  possible  actions  on  eco-design  of  electronics  which  may 
contribute  to  the  greening  of  the  digital  sector.  Component  1.2  includes  investments  in  digital 
technologies to support the energy transition. 

Measures  contributing  to  the  digital  transition  exceed  the  minimum  threshold  required 
under the Recovery and Resilience Facility. Based on the methodology for digital tagging set 
out  in  Annex  VII  of  Regulation  (EU)  2021/241,  26.6%  of  the  plan  contributes  to  the  digital 
target, measured as the total estimated cost of the contributing actions as a percentage of the total 
allocation, therefore complying with the minimum threshold of 20%, with a direct contribution 
from 11 components out of 17. 

3rd  Pillar:  Smart,  sustainable  and  inclusive  growth,  including  economic  cohesion,  jobs, 
productivity,  competitiveness,  research,  development  and  innovation,  and  a  well-functioning 
internal market with strong SMEs 

The plan extensively covers the ‘third pillar’, with nearly all components contributing to its 
different policy areas. 

The  plan  contributes  to  ensuring  smart,  sustainable  and  inclusive  growth.  Several 
components are expected to enhance the productive capacity of the economy (2.1, 2.3, 5.1, 5.2), 
while components 1.1, 1.2, 1.3 and 5.3 promote sustainable growth, as well as climate mitigation 
and adaptation. Components 4.1, 4.2, 4.3 and 5.1 promote inclusive growth. 

Several  components  of  the  plan  are  expected  to  contribute  to  economic  cohesion,  jobs, 
productivity  and  competitiveness.  Components  5.1  and  5.2  have  the  potential  to  enhance 
productivity growth. Components 4.1, 4.2 and 4.3 relate to economic cohesion. 

Research,  development  and  innovation  measures  are  included  in  different  components  of 
the  plan.  While  component  5.2  directly  relates  to  research,  innovation,  new  technologies  and 
decarbonisation, component 4.1 is linked to the digital transformation of the education systems. 

32 

 
 
Components 1.2 and 5.3 relate to innovation and new technologies for clean energy production 
and the development of the circular economy. 

Finally,  the  plan  contains  several  measures  that  are  expected  to  contribute  to  a  well-
functioning internal market with strong SMEs. Component 2.2 promoting the digitalisation of 
public  services,  is  expected  to  improve  the  effectiveness  of  the  justice  system,  and  support  a 
well-functioning internal market (e.g. Single Digital Gateway, which facilitates the application of 
the ‘Only-Once principle’, and the interoperability of eID for cross-border suppliers and service 
providers).  The  component  also  contains  measures  to  support  the  digital  transformation  of  the 
social  security,  including  facilitating  the  communication  with  the  social  security  of  other  EU 
Member  States,  and  therefore  contributing  to  the  mobility  of  the  labour  force.  Component  2.1 
contributes to the digital transformation of SMEs through support to increase their cybersecurity 
readiness. Component 5.1 and 5.2 supports startups and SMEs, through incubation and support 
to  innovative  activities.  Component  1.2  supports  the  development  of  hydrogen  capacity  and 
transmission infrastructure. 

4th Pillar: Social and territorial cohesion 

The plan covers the ‘fourth pillar’, with a majority of components being directly related to 
‘social and territorial cohesion’. Strengthening social cohesion is one of the key objectives of 
the  plan,  in  particular  addressed  under  the  fourth  axis  of  the  plan  which  notably  aims  at  the 
inclusion  and  integration  of  disadvantaged  groups.  Territorial  cohesion  is  predominantly 
addressed  with  measures  tailored  to  meet  the  specific  challenges  that  each  region  faces  in 
Belgium,  although  more  efforts  could  have  been  made  to  ensure  coherence  in  the  plan.  A 
significant  part  of  the  measures  was  defined  at  regional  level  to  address  specific  regional 
challenges  and  the  share  of  the  fund  going  to  the  different  Regions  appears  broadly  adequate. 
Synergies with the upcoming Cohesion Policy programmes are also expected. 

The plan also includes measures intended to enhance territorial cohesion, notably thanks to 
investment  in  sustainable  mobility  and  digital  infrastructure.  Investments  into  railways, 
smart  mobility  and  cycling  and  walking  paths  cover  the  whole  territory  and  reinforce  the 
integration of transport networks. The development of inland waterways in Wallonia is expected 
to  improve  overall  connectivity  of  the  country.  Belgium  has  also  committed  to  complete  its 
cross-regional  suburban  rail  network  (measure  R-3.01).  The  deployment  of  charging 
infrastructure throughout Belgium is also supported. Finally, the plan intends to ensure the even 
roll-out of 5G infrastructure in all regions, notably by revising the regional radiation standards if 
considered necessary and recommended by the relevant committees. Moreover, the plan contains 
two  fibre  deployment  infrastructure  projects  in  white  zone  areas,  contributing  to  territorial 
cohesion between urban and rural areas in this way. 

Strengthening  social  cohesion  is  one  of  the  key  objectives  of  the  plan.  It  is  in  particular 
addressed  under  its  fourth  axis,  which  notably  aims  at  the  inclusion  and  integration  of 
vulnerable  groups.  Component  4.1  intends  to  improve  the  overall  performance  and 
inclusiveness  of  education  systems  in  Belgium.  Component  4.2  includes  measures  to  increase 

33 

 
 
 
participation  of  vulnerable  groups  in  the  labour  market  (low-skilled,  women,  people  with  a 
migrant background, people with disabilities). Component 4.3 contributes to addressing the lack 
of  social  housing  for  vulnerable  groups  early  childhood  care,  in  particular  for  vulnerable 
households. The reform of the pension and end of careers (component 4.4) would among others 
aim to ensure adequacy of social security while addressing fiscal sustainability concerns. 

The  plan  includes  investment  and  reform  measures  to  tackle  unemployment,  notably  by 
fostering training and life-long learning. The risk of poverty in Belgium is strongly correlated 
to  the  high  share  of  low  work  intensity  households.  The  plan  includes  several  measures  to 
strengthen  labour  market  participation,  notably  by  increasing  and  improving  the  training  offer, 
including  towards  jobs  in  shortages,  fostering  life-long  learning  and  adapted  support  to 
jobseekers by the public employment services (component 5.1). 

The  plan  includes  several  additional  components  which  are  expected  to  promote  social 
cohesion in particular through measures on digital inclusion (components 5.1 and 2.3), access to 
digital public services (component 2.2), renovation of social housing, schools, universities, sport, 
youth and cultural infrastructure, training facilities (component 1.1), and measures promoting a 
modal  shift,  by  decreasing  reliance  on  personal  use  of  motor  vehicles  whose  associated  costs 
contribute to poverty (component 3.2).  

5th Pillar: Health and economic, social and institutional resilience, with the aim of increasing 
crisis preparedness and crisis response capacity, among others 

The  plan  extensively  covers  the  ‘fifth  pillar’,  with  about  half  of  all  components  being 
directly related to it. 

Several measures, especially under the fifth axis of the plan, are expected to contribute to 
increasing economic resilience. The plan includes measures to strengthen productivity of firms, 
especially  SMEs  and  innovative  companies,  and  to  support  the  digital  transition,  R&D  and 
innovation  and  increase  competitiveness  (see  sub-section  on  smart,  sustainable  and  inclusive 
growth).  

The  digital  axis  of  the  plan  is  expected  to  help  improving  business  and  public  service 
continuity,  as  well  as  the  effectiveness  of  the  justice  system.  A  component  of  the  plan  is 
dedicated  to  increasing  resilience  to  cyberattacks  (component  2.1).  The  plan  also  contains 
measures to  accelerate the digitalisation of justice  and decreasing the administrative burden by 
digitalising public services (component 2.2). 

Social resilience should notably be promoted by the components under the fourth and fifth 
axes  which  are  oriented  towards  employability,  including  vulnerable  groups,  and 
enhancing skills. As discussed in the previous sub-section on social and territorial cohesion, the 
plan has a strong focus on building social resilience. 

34 

 
 
 
The plan includes investments in e-health solutions to reinforce the overall resilience of the 
health  system.  Moreover,  the  plan  aims  to  support  training  and  innovation  in  the  health  and 
biotech sector in Belgium. 

The plan contains measures that are expected to contribute  to increasing the institutional 
resilience  of  Belgium,  notably  through  development  of  cybersecurity  capabilities  (component 
2.3),  the  modernisation  and  digitalisation  of  public  services,  including  the  justice  system 
(component 2.2) and the introduction of spending reviews (component 6.1). 

35 

 
 
 
 
6th Pillar: Policies for the next generation, children and young people, such as education and 
skills 

The plan covers the ‘sixth pillar’, with several components directly related to it, therefore 
contributing adequately to its overall coherence. The plan presents a number of measures with 
a direct impact on children and young people, including: 

  The  development  of  global  action  plan  against  early  school  leaving  and  personalised 
support  for  pupils  in  school  in  the  Federation  Brussels-Wallonia,  and  of  an  agile  and 
future-proof higher education offer in the Flemish Community (component 4.1) 

  The  renovation  of  schools  and  universities,  as  well  as  the  renovation  of  sport 
infrastructure and of facilities for the youth in the French Community (component 1.1) 
Investment  in  the  digital  infrastructure  and  equipment  of  the  education  system 
(components 2.3 and 4.1) 

 

  Renovation and development of training facilities, as well as measures supporting digital 

 
 

inclusion and digital training offer in Wallonia (component 5.1) 
Increase in the capacity of childcare facilities in Wallonia (component 4.3) 
Increase in flexible temporary childcare for jobseekers in the Brussels-Capital Region, for 
parents and/or single parents having just found a job or enrolled in training (component 
4.2) 

  Cycling  infrastructure,  notably  benefiting  young  people  with  no  or  little  access  to 

personal cars (component 3.1) 

Conclusion 

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Belgium,  its  recovery  and 
resilience plan represents, to a large extent a comprehensive and adequately balanced response to 
the economic and social situation, thereby contributing appropriately to all six pillars referred to 
in Article 3 of the RRF Regulation, taking the specific challenges and the financial allocation of 
Belgium  into  account.  This  would  warrant  a  rating  of  A  under  the  assessment  criterion  2.1  in 
Annex V to the RRF Regulation. 

4.2. Link with country-specific recommendations and the European Semester  

The  plan  is  expected  to  effectively  contribute  to  addressing  a  significant  subset  of 
challenges faced by the Belgian economy. The plan introduces reforms and investments aimed 
at  providing  a  response  to  some  long-lasting  challenges  that  the  Belgian  economy  is  facing, 
notably  in  the  areas  of  public  finances  and  the  composition  and  efficiency  of  public  spending, 
overall labour market  performance and skills  development,  investment  in sustainable transport, 
the energy transition,  research, innovation  and new technologies  and digital  infrastructure. The 
plan also comprises reforms and investment intended to reduce the regulatory and administrative 
burden and improve the business environment. 

Table 6 - Mapping of country challenges identified in 2019-20 country-specific recommendations 
(CSR) and the Belgian recovery and resilience plan components 

36 

 
 
 
Associated 
CSR (2019-
2020) and 
European 
Semester 
recommend
ations 
2019.1 
2019.1 

Country challenges 
(as identified in Section 2) 

1
.
1
C

2
.
1
C

3
.
1
C

1
.
2
C

2
.
2
C

3
.
2
C

1
.
3
C

2
.
3
C

3
.
3
C

1
.
4
C

2
.
4
C

3
.
4
C

4
.
4
C

1
.
5
C

2
.
5
C

3
.
5
C

1
.
6
C

  ● 

  ●  ○   

  ○   
  ●   

  ●   

○ 

  ○ 

  ● 

2019.1 

2019.1 

  ●  ● 

2019.2, 
2020.2 
2019.2 

2019.2 
2019.2, 
2020.2 

Public debt sustainability  
Sustainability of pension 
regimes, end of career 
Efficiency of public spending, 
spending reviews 
Better coordination of fiscal 
policies 
Remove disincentives to work 
Strengthen effectiveness of 
active labour market policies in 
particular for the low skilled, 
older workers and people with 
a migrant background 
Address skills mismatches, 
improve training systems 
Improve the performance and 
inclusiveness of the education 
system 
Invest in sustainable transport 
infrastructure 
Reinforce incentives and 
remove barriers to increase the 
supply and demand of 
collective and low emission 
transport 
Clean and efficient production 
and use of energy 
Circular economy 
Digital infrastructure, i.e. 5G 
and Gigabit Networks 
Invest in research & 
innovation, in particular in 
digitalisation 
Improve the business 
environment 
Reduce the regulatory and 
administrative burden  
Competition in services 
Key: “●” investments and reforms of the component significantly address the challenge; “○” the component 
partially addresses the challenge 

2019.3, 
2020.3 
2020.3 
2019.3, 
2020.3 
2019.3, 
2020.3 

2019.3, 
2020.3 
2019.3, 
2020.3 

2019.4, 
2020.3 
2019.4 

●  ●  ● 

●  ●  ●   

●  ●  ○ 

  ●  ○ 

  ●   

●  ●   

  ●   

2019.4 

○   

●   

● 

● 

○ 

● 

  ●  ○   

  ●   

  ○  ●  ●   

  ○   

  ○    ○ 

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fiscal sustainability of long-term care and pensions systems 

Risks to the overall fiscal sustainability of public finances are significant in the medium to 
long-term in Belgium. The medium- and long-term sustainability of Belgium’s public finances 
is  at  risk  due  to  the  combination  of  a  high  debt-to-GDP  ratio  and  the  projected  rise  in  ageing 
costs, in particular those linked to pensions and long-term care. Public expenditure on pensions 
would  increase  by  3  percentage  points  of  GDP  by  2070,  mostly  during  the  next  two  decades 
(European Commission,  2021b). Public spending on long-term  care is  projected to  increase by 
2.1 percentage points of GDP by 2070, an above average increase starting from what is already 
one of the highest levels in the EU. 

Against  the  background  of  high  public  debt  and  increasing  public  pension  expenditure 
(CSR 1.4 2019), the plan includes a reform of the pension system as part of component 4.4. 
The  envisaged  pension  reform  aims  to  improve  the  financial  and  social  sustainability  of  the 
pension  system  and  to  reinforce  the  insurance  principle  by  increasing  minimum  pensions  and 
strengthening  the  link  between  contributions  and  benefits.  The  pension  reform  also  aims  at 
improving  the  gender  balance  and  at  ensuring  convergence  between  and  within  the  different 
pension systems, which may include limiting early exit possibilities from the labour market. 

A  number  of  the  envisaged  measures  is  expected  to  contribute  to  strengthening  the 
coverage  and  adequacy  of  the  pension  system.  Those  measures,  for  instance  the  increase  in 
minimum  pensions,  could  however  increase  pension  expenditure  in  the  medium  to  long  term, 
unless  offset  by  measures  contributing  to  financial  sustainability,  which  is  one  of  the  stated 
objectives  of  the  reform.  To  achieve  financial  sustainability,  the  Belgian  authorities  plan  to 
incentivise  older  workers  to  remain  active  on  the  labour  market.  Different  measures  are  being 
considered  in  the  recovery  and  resilience  plan  to  contribute  to  this  objective  such  as  the 
introduction of part-time pensions, the introduction of a pension bonus17, increased investment in 
life-long learning and the facilitation of career reorientation for older workers. 

The  pension  reform  is  described  in  general  terms,  without  providing  details  on  the 
envisaged measures. Therefore, whilst it is expected to provide some contribution to addressing 
CSR 1.4 2019, it will be possible to assess the extent of that contribution only when the concrete 
measures constituting the reform have been defined. 

The  plan  includes  some  measures  contributing  to  a  further  deinstitutionalisation  of  long-
term care (CSR 1.3 2019). Belgium’s density of residential beds for over-65 years old is among 
the  highest  in  the  EU.  Moreover,  indicators  show  that  a  non-negligible  share  of  independent 
users and those with low levels of dependency for whom institutionalisation may be unnecessary 
or at least premature, are currently receiving residential care. Specifically, in the Brussels-Capital 
Region and the Walloon Region approximately one third (34% and 31% respectively) of elderly 
people living in residential structures still have some autonomy, while this proportion amounts to 

17 

A pension bonus provides people who work beyond early retirement age with additional pension rights. 

38 

 
 
                                                           
20% in Flanders. Component 4.3 includes investment in social housing in Wallonia, some of it 
equipped with assistive technologies in order to support the independent living of persons with 
disabilities  and  elderly  people.  Prior  to  the  implementation  of  this  investment,  the  Walloon 
government will adopt a deinstitutionalisation strategy for long-term care. 

Composition and efficiency of public spending 

The plan is ambitious in systematically integrating spending reviews in the budget planning 
cycles  of  all  government  levels  to  improve  spending  efficiency  (CSR  1.5  2019).  Belgium’s 
high level of public spending coexists with a low level of public investment. Spending reviews 
could serve as an effective tool for reprioritising expenditure towards spending outlays that better 
meet the country’s economic and societal goals. By unlocking efficiency gains, they can generate 
savings  without  constraining  growth.  Component  6.1  contains  a  commitment  to  introduce  the 
structural  use  of  spending  reviews  at  all  layers  of  government.  In  line  with  the  relevant 
Eurogroup guidance18, the outcome of spending reviews will be systematically included into the 
annual  and  multiannual  budget  planning  as  of  the  preparation  of  the  2024  budgetary  law.  The 
scope and level of ambition of the various planned measures related to spending reviews differ 
between government entities, in line with their degree of progress in using  that instrument. All 
entities have benefited from technical support on spending reviews under the Technical Support 
Instrument (and previously under the Structural Reform Support Programme). 

Disincentives to work 

The plan refers to a proposal for a broad tax reform, notably aimed at increasing the net 
return from work. This proposal has to be seen against the backdrop of CSR 2.1 2019, which 
calls on Belgian to tackle existing disincentives to work. The Belgian tax system is characterised 
by a high tax wedge on labour for middle-income earners (52.3% in Belgium against 45.6% in 
the euro area on average in 2019) and includes several tax features creating specific disincentives 
to  work,  notably  the  interaction  between  narrow  tax  brackets,  the  special  social  security 
contribution  and  the  employment  bonus.  As  underlined  in  the  2019  European  Semester, 
removing  distortive  tax  features  and  reducing  the  tax  burden  on  labour  would  help  decreasing 
financial disincentives to work. The broader tax reform announced in the plan would include in 
particular measures aimed at  reducing taxes on labour, among others, the  participation tax rate 
(currently  higher  than  60%  in  some  cases)  and  the  current  marginal  income  tax  rates  of  more 
than 80% in the range of 50 to 70% of the average wage, as well as measures to broaden the tax 
base and simplify the taxation system. 

The  plan  does  however  not  provide  a  commitment  and  timeline  for  the  adoption  of  the 
announced tax reform. Whilst that reform has the potential to reduce the tax burden on labour, 
and  thereby  to  contribute  to  addressing  CSR  2.1  2019,  the  plan  announces  a  submission  of  a 
proposal to the Council of Ministers of the federal government, thus providing no full guarantee 

18 

See http://www.consilium.europa.eu/en/press/press-releases/2016/09/09-eurogroup-statement/ 

39 

 
 
                                                           
that the reform will be effectively enacted. In the absence of a clear timeline and commitment to 
adopt  the  reform,  the  reform  could  not  be  included  as  a  measure  of  the  plan  supported  by  the 
Facility. 

40 

 
 
 
 
Active labour market policies 

The  plan  contains  measures  intended  to  promote  more  effective  active  labour  market 
policies  and  to  improve  the  labour  market  performance  (CSR  2.1  2019  and  2.1  2020). 
Labour  market  participation  is  low  for  low-skilled,  people  with  a  migrant  background,  older 
workers  and  people  with  disabilities  in  Belgium.  This  suggests  that  both  structural  and  group-
specific factors hinder their integration in the labour market, while existing activation measures 
are  not  equally  effective  for  all  population  groups.  The  employment  rate  of  older  workers 
remains below the EU average and also people with a migrant background, in particular women, 
remain  underrepresented  on  the  labour  market.  The  plan  includes  a  reform  of  the  public 
employment  services  of  Wallonia  (R-5.05)  to  strengthen  employment  guidance  for  those  the 
furthest  from  the  labour  market.  The  investments  included  in  component  4.2  focus  on 
strengthening social and labour market integration of people with a migrant background, women, 
people  with  disabilities,  prisoners  and  people  at  risk  of  digital  exclusion.  Moreover,  some 
reforms  aim  at  tackling  discrimination  on  the  labour  market.  Specific  measures  aiming  at 
fostering  the  employability  of  older  workers  are  foreseen  to  be  included  in  the  reform  under 
component 4.4. 

Although several reforms and investments included in the plan strengthen the position of 
vulnerable groups on the labour market, the overall plan falls short of presenting a holistic 
and  integrated  approach  to  support  social  and  labour  market  inclusion  for  vulnerable 
groups. Moreover, the lack of a commitment and timeline for the adoption of the announced tax 
reform  risks  limiting  the  effectiveness  of  the  measures  taken  to  reinforce  the  activation  of 
vulnerable groups. 

Education and skills 

Several  reforms  and  investments  are  expected  to  contribute  to  improved  education  and 
training systems (CSR 2.2 2019 and 2.2 2020). The decline in educational performance and the 
existence of significant disparities in the education system are a concern in Belgium. The share 
of young people mastering basic skills is worrying and the gap in educational outcomes linked to 
socio-economic  and  migration  background  is  high.  Investments  and  reforms  included  in 
component  4.1  of  the  plan  aim  at  increasing  the  inclusiveness  of  education  systems  and 
improving their performance to ensure that skills taught better match those required by the labour 
market. The Higher Education Advancement Fund has the potential to contribute to modernising 
higher education to meet labour market and society needs. A large share of investments focuses 
on  increasing  digital  infrastructure  and  equipment  to  improve  digital  skills  at  all  levels  of  the 
education  system  (secondary  school,  higher  education  and  social  promotion  education). 
Investments  also  include  some  training  for  teachers  to  improve  their  digital  skills.  The  plan 
includes  a  global  action  plan  of  the  French  Community  against  early  school  leaving  and 
personalised support to 30 000 pupils in compulsory education through multi-disciplinary teams 
to  address  mental,  educational  and  pedagogical  difficulties  of  pupils,  their  lower  educational 
outcomes and early school leaving as a result of COVID-19. However, only few measures have 
as a specific objective to address the structural inequalities in the education system, including by 

41 

 
 
targeted investments in vulnerable pupils’ and teachers’ training, although several measures may 
indirectly contribute to this objective. 

The plan also includes training measures to address skills mismatches (CSR 2.3 2019 and 
2.2 2020). Despite several regional and federal measures to address skills shortages and increase 
activation,  labour  shortages  are  observed  in  several  sectors,  in  particular  in  information  and 
communication  technologies,  construction,  health  and  education  and  training.  Investments  in 
training included in components 4.2 and 5.1 aim at reducing skills shortages through training and 
activation in view of addressing current and future needs of the labour market. While aiming at 
covering a wide range of skills, including basic and green skills, investments focus strongly on 
increasing digital skills, thereby supporting the digital transition.  

Although  some  measures  have  been  included,  the  plan  does  not  present  a  comprehensive 
strategy  to  strengthen  participation  in  lifelong  learning,  focusing  in  particular  on  the 
vulnerable groups.  Investments  in  training  focus  strongly  on increasing  the training offer and 
less  on  measures  to  incentivise  participation  in  training  and  develop  a  learning  culture,  which 
were  identified  as  the  main  constraints  for  low  participation  in  lifelong  learning.  This  is 
especially  a  concern  in  Wallonia  where  the  investments  in  training  are  almost  exclusively 
targeted  to  the  construction  and  renovation  of  training  centres.  Moreover,  only  few  measures 
have  as  a  specific  objective  to  address  the  structural  inequalities  in  the  education  system,  for 
example by targeted investments in vulnerable pupils’ and teachers’ training. 

Several measures included in the plan aim at improving education systems and to address 
skills mismatches, but only to a limited extent basic and green skills. Although the focus on 
digital  skills  is  welcome  to  support  the  digital  transition,  some  types  of  skills  shortages  are 
expected to be less addressed, also since the plan does not provide for a comprehensive strategy 
to lifelong learning. 

Investment in sustainable transport 

The  plan  includes  ambitious  investments  in  sustainable  transport,  including  walking, 
cycling,  public  urban  transport  and  rail  infrastructure  (CSR  3.1  2019  and  3.5  2020).  The 
transport  sector  is  responsible  for  35%  of  non-ETS  greenhouse  gas  emissions  in  Belgium. 
Growing traffic volumes create congestion and put land transport infrastructure under pressure, 
while inland waterways infrastructure investments are low. Although it has a dense road and rail 
network,  Belgium  scores  rather  poorly  in  terms  of  road  quality  and  efficiency  of  rail  services. 
The  Belgian  plan  is  expected  to  make  a  considerable  contribution  towards  addressing  the 
recommendation to invest in sustainable transport, in particular railways. Investments included in 
component  3.1  include  substantial  support  to  favour  cycling  and  walking.  The  plan  also 
promotes the use of public transport and inter-modality, with a particular focus on enhancing rail 
transport (e.g. as it includes milestones on the completion of the RER/GEN suburban network in 
the measure R-3.01 on the performance contract of NMBS-SNCB and Infrabel). Component 3.2 
includes  substantial  investment  in  public  transport  services,  such  as  new  bus,  tram  and  light 
metro infrastructure, as well as digital tools to increase demand for sustainable transport. Also, 
rail transport is expected to be made more efficient and accessible. For freight transport, the plan 

42 

 
 
will finance infrastructure works to support the modal shift from road towards inland waterways 
and rail. 

Several measures of the plan are expected to support the electrification of transport (CSR 
3.1 2019 and 3.5 2020). Belgium is lagging behind in electric mobility, as the uptake of electric 
or  hybrid  electric  vehicles  remains  slow  and  there  is  a  need  for  considerable  infrastructure 
investments.  Investments  proposed  under  component  3.3  aim  at  fostering  electric  mobility, 
covering  both  public  and  private  transport.  Belgium  will  also  invest  in  greener  bus  fleets  and 
several  projects  support  the  deployment  of  electric  charging  infrastructure,  notably  in  Flanders 
(30.000  charging  points)  and  to  some  extent  in  Wallonia  (6.000  charging  points).  These 
investments  will  be  complemented  by  the  adoption  of  legislative  reforms  to  set  up  legislative 
frameworks for e-mobility in the three Regions. 

Incentives to collective and sustainable mobility 

Investments  in  low  emission  transport  are  accompanied  by  incentives  to  sustainable 
mobility, including a reform of the company car tax scheme (CSR 3.4 2019). Growing traffic 
volumes  have  long  been  boosted  by  high  commuting  subsidies,  like  the  company  car  tax 
advantage  embedded  in  the  corporate  income  tax,  personal  income  tax  (for  employees 
benefitting from a  company car), and employers’ and employees’ social security contributions. 
In  addition  to  its  economic  (congestion)  and  environmentally  harmful  effects,  this  tax  scheme 
entails a high budgetary cost and favours high-income earners. The plan includes a reform of the 
company  car  tax  scheme,  whereby  new  company  cars  need  to  be  zero  emission  from  2026 
onwards to benefit from the existing preferential  scheme. The reform is expected to reduce the 
greenhouse gas emissions related to the use of company cars, but not to address congestion nor 
to  reduce  the  budgetary  impact  of  the  scheme.  The  plan  also  includes  tax  incentives  for  the 
installation of private and semi-public charging stations and an increase of the mobility budget 
scheme. The plan also seeks to increase the quality and efficiency of railways. 

The  plan  proposes  therefore  a  coherent  package  of  reforms  and  investments  to  support  the 
development  of  sustainable  mobility  by  promoting  cycling  and  rail  transport,  greening  car  and 
bus fleets, deploying charging infrastructure and extending urban transport networks. However, 
the  plan  does  not  include  some  reforms  such  as  the  tendering  of  public  service  contracts,  for 
which the current coalition agreement of the federal government foresees pilot projects. 

Investment in the energy transition 

Belgium  earmarks  an  important  financial  envelope  under  the  RRF  to  energy-efficient 
renovation of private and public buildings (CSR 3.2 2019 and 3.6 2020). The building sector 
accounts  for  more  than  30%  of  non-ETS  GHGs  emissions  in  Belgium.  Belgium  ranks  low  in 
relation to the energy performance of its existing housing stock, since 80% of the stock was built 
before  the  introduction  of  energy  efficiency  standards  for  buildings.  Substantial  investments 
under  component  1.1  aim  to  improve  the  energy  efficiency  of  buildings,  including  public 
buildings, as well as  private ones and social  housing. Moreover, the plan includes measures to 
improve the system of renovation subsidies for households to foster private investment. 

43 

 
 
The  plan  also  includes  investments  to  ensure  the  transition  to  low  carbon  energy 
technologies  (CSR  3.2  2019  and  3.6  2020).  There  is  a  need  for  major  investment  in  power 
generation,  as  well  as  interconnection  capacity,  smart  grids  storage  and  energy  efficiency  in 
Belgium. Considerable investments under component 1.2 focus on clean and efficient production 
and  use  of  energy.  Investments  focus  on  industrial  sectors  and  cover,  for  example,  process 
electrification, green  and low-carbon hydrogen as raw material  and energy  carrier, capture and 
storage  of  carbon  with  investment  in  CO2  transport  and  pre-industrial  research  for  industrial 
applications,  renewable  heat  networks,  infrastructure  aimed  at  facilitating  the  connection  of 
offshore wind to the grid, etc.  

The plan contains measures to strengthen biodiversity and to anticipate the adverse effects 
of  climate  change  (CSR  3.5  2020).  Belgium  faces  important  investment  and  regulatory 
challenges  to  embrace  the  low-carbon  transition  and  anticipate  the  adverse  effects  of  climate 
change.  These  challenges  include  strong  pressure  on  land  and  biodiversity  due  to  intensive 
agriculture  and  relatively  high  population  density.  Investments  under  component  1.3  are 
expected to support the conservation and restoring of biodiversity to improve the carbon storage 
capacity and increase resilience to climate change effects. Moreover, several investments aim at 
addressing  drought  problems  in  a  structural  way  to  be  better  prepared  for  longer  periods  of 
drought and more frequent heat waves. 

The plan includes sizeable investments in the energy transition, notably to improve the energy-
efficiency  of  buildings,  support  low  carbon  energy  technologies  and  strengthen  biodiversity.  It 
remains  uncertain,  however,  how  the  ‘green  tax  shift’  part  of  the  announced  broad  tax  reform 
will be designed and to what extent it will further support investments in the energy transition. 

Investment in research and innovation and new technologies 

The  Belgian  plan  aims  at  boosting  investment  in  research  and  innovation,  including 
digitalisation  (CSR  3.3  2019  and  3.9  2020).  Research  and  development  activities  are 
concentrated in a few industries and there is insufficient diffusion of innovation to the rest of the 
economy.  Also,  regional  and  sub-regional  disparities  remain  high.  Large  R&D  investments 
included  under  component  5.2  aim  at  boosting  economic  recovery  through  the  twin  transition. 
Investments  include,  for  example,  the  implementation  of  more  efficient  production  processes 
based  on  emerging  technologies  in  energy  and  the  development  of  alternative  production 
processes  for  nuclear  medicine  for  cancer  treatment.  Component  2.3  includes  measures  to 
support  research  and  innovation  in  the  area  of  artificial  intelligence.  Innovative  digital 
technologies such as smart grids and ICT systems to deploy renewable energy are supported in 
component 1.2. The plan also finances innovative processes in the circular economy in Wallonia 
and Flanders in  component  5.3.  Investments  in  component 4.1 (Education 2.0) are expected to 
significantly  improve  the  digital  delivery  method  of  education  in  Belgium.  Innovations  in  the 
area of smart mobility aim to improve the offer of public transport services. In component 4.3, 
the plan foresees to use artificial intelligence in social housing to delay or avoid that people in 
loss of autonomy move too early to eldercare facilities. 

Investments in digital infrastructure, such as 5G and Gigabit Networks 

44 

 
 
The  plan  contains  mutually-reinforcing  very  high-capacity  connectivity  infrastructure 
reforms  and  investments,  which  are  essential  building  blocks  for  the  digital  and  green 
transition  in Belgium  (CSR  3.3  2019  and  3.8 2020).  The  reinforcement  of  digitalisation  was 
identified  as  a  promising  avenue  for  boosting  productivity  and  the  innovation  capacity  of 
Belgium.  The  plan  includes  both  reforms  and  investments  to  deploy  very  high-capacity 
connectivity infrastructure. 

The plan is expected to remove bottlenecks for critical reforms to enable and reinforce very 
high-capacity  connectivity  public  and  private  investments.  In  the  area  of  digital  policy,  the 
federal levels, regions and communities were recommended to find common ground for the roll-
out  of  5G,  where  Belgium  has  been  lagging  behind.  Components  2.3  and  5.2  contain  reforms 
both  at  the  federal  and  regional  level  that  aim  to  remove  regulatory  bottlenecks  for  the 
deployment of 5G and for the deployment of ultra-fast connectivity infrastructure, such as fibre. 
As part of the plan, Belgium intends to organise and implement the 5G spectrum auction under 
investment-friendly conditions by June 2022, with the required federal legislative framework in 
place by end 2021. The plan also contains regional reforms to revise radiation standards to allow 
for effective 5G spectrum deployment for both private and industrial use, provided those reforms 
have been found necessary and recommended by the relevant committees put into place by the 
respective regions. Even though the latter condition adds a certain contingency to 5G deployment 
in Belgium, those reforms have the potential to lift a significant hurdle to the large-scale rollout 
in  Belgium.  In  addition,  the  implementation  of  the  Connectivity  Toolbox19,  that  is  to  contain 
connectivity  best  practices  for  reducing  the  cost  of  deploying  electronic  communications 
networks and for efficient access to 5G radio spectrum tailored to Belgium, will be monitored in 
the  Belgian  plan.  The  implementation  of  the  Connectivity  Toolbox  will  include  a  national 
roadmap towards simplifying the licensing and permitting procedures relevant for the rollout of 
5G and very high-capacity networks, such as fibre. The reform, aiming to reduce the length of 
court proceedings relating to environmental permits by 6 to 9 months on average in Flanders, and 
investments to digitise urban planning permits in the Brussels-Capital and in the Walloon regions 
are also expected to be conducive to digital infrastructure investments. 

The plan also includes public ultra-fast connectivity investments. These investments include 
the fibre coverage of white areas in the German-speaking Community and of business parks in 
Wallonia (component 2.3). 

Business environment and regulatory and administrative burden 

To improve the business environment, the plan notably aims to support the digitalisation of 
the administration, including the justice system (CSR 4.1 2019 and 3.2 2020). There is room 

19 
Common  Union  Toolbox  of  26  March  2021  for  connectivity  pursuant  to  Commission  Recommendation 
(EU) 2020/1307 on a common Union toolbox for reducing the cost of deploying very high capacity networks and 
ensuring timely and investment-friendly access to 5G radio spectrum, to foster connectivity in support of economic 
recovery from the COVID-19 crisis in the Union. 

45 

 
 
                                                           
investments  and  reforms 

institutional  governance.  Significant 

to improve the take-up of digital public services, which is currently relatively low and the lack of 
digitalisation  of  the  justice  system  remains  an  important  challenge  for  business  investment  in 
Belgium.  The  digitalisation  of  public  services  and  justice  had  been  flagged  as  a  way  to  help 
included  under 
improve 
component 2.2 aim at digitalising public administration to improve the efficiency of its internal 
processes and of its interactions with citizens and businesses, notably through the Single Digital 
Gateway and investment in the digitalisation of the social security system. The digitalisation of 
building  and  environment  permits  procedures,  which  is  envisaged  in  the  plan,  is  expected  to 
contribute to reduce the lead time necessary to complete these procedures. These investments are 
accompanied by e-government reforms to simplify administrative procedures and to improve e-
procurement.  The  plan  is  also  expected  to  contribute  to  a  more  cyber  secure  business 
environment  in  Belgium,  notably  with  investments  in  cyber  awareness  and  cyber  resilience 
capabilities of SMEs and the self-employed (component 2.1). 

The  plan  partially  addresses  the  recommendation  to  reduce  the  regulatory  and 
administrative  burden  (CSR  4.1  2019  and  3.2  2020).  The  plan  is  intended  to  support  the 
implementation of the Single Digital Gateway, revising and simplifying the procedure to set  up 
and  to  manage  a  business  (component  2.2).  The  Single  Digital  Gateway  intends  to  apply  the 
“Once-Only”  principle  also  to  businesses  and  citizens  from  other  Member  States.  Flanders, 
Wallonia  and  Brussels  are  introducing  reforms  to  streamline  permit  and  environmental 
procedures20.  Spending  reviews  in  Flanders  will  also  focus  on  reducing  the  regulatory  burden, 
including  to  address  ‘gold-plating’  which  results  in  an  unnecessary  strict  implementation  and 
enforcement of the rules (component 6.1). However, the plan does not address the complexity of 
the  labour  law  nor  the  recommendation  to  remove  barriers  to  competition  in  services,  in 
particular regulated professions. 

The plan is expected to have a lasting impact on Belgian society’s overall cyber resilience 
and security and promotes the deployment of artificial intelligence (“AI”), contributing to 
the digital transition (CSR 3.3 and 4.1 2019 and 3.5 2020). Investments under component 2.1 
aim  at  strengthening  the  overall  cyber  resilience  and  cyber  crisis  preparedness  of  the  Belgian 
society. Investments include, for example, measures to strengthen the cyber capabilities of SMEs 
and to combat cyber criminality. The plan also contributes to the financing of a new AI Institute 
for the Common Good in Brussels that is to promote the use of AI to tackle societal challenges in 
areas including health, environment, mobility and energy. 

Conclusion 

20 
The  objective  of  the  reform  by  the  Flemish  Region  is  to  shorten  the  time  needed  for  the  completion  of 
procedure  and  to  increase  legal  certainty  about  its  length.  A  positive  impact  on  private  investment  is  expected. 
Component  2.2  includes  investment  by  the  Brussels-Capital  and  the  Walloon  Region  in  the  digitalisation  of  the 
building  and  environmental  permitting  and  urbanistic  procedures  with  a  potential  reduction  in  the  time  needed  to 
take a decision. 

46 

 
 
                                                           
Overall, the plan constitutes a comprehensive package of reforms  and investments  focusing on 
addressing the challenges identified in the country-specific recommendations. The Belgian plan 
focusses importantly on public investment and proposes sizeable investments to address country-
specific recommendations. 

Taking into  consideration the reforms  and investments envisaged by  Belgium, and  considering 
the  available  funding  under  the  RRF,  the  Belgian  recovery  and  resilience  plan  is  expected  to 
contribute  to  effectively  addressing  all  or  a  significant  subset  of  challenges  identified  in  the 
country-specific recommendations, or challenges in other relevant documents officially adopted 
by the Commission under the European Semester, and the recovery and resilience plan represents 
an  adequate  response  to  the  economic  and  social  situation  of  Belgium.  This  would  warrant  a 
rating of A under the assessment criterion 2.2 in Annex V to the RRF Regulation. 

4.3. Growth  potential,  job  creation,  economic,  institutional  and  social  resilience, 
European  Pillar  of  Social  Rights,  mitigating  the  impact  of  the  crisis,  and  social 
territorial cohesion and convergence  

The  Belgian  recovery  and  resilience  plan  aims  at  fostering  the  economic  recovery  while 
having a strong focus on the green transition and the digital transformation of the economy 
and improving resilience on the path towards a more sustainable and inclusive growth. It 
includes a number of investment and reforms, which are expected to have a positive effect on the 
aggregate demand. The main objectives of the plan are to improve Belgium’s growth potential, 
boost job creation, and increase economic, social and institutional resilience that will ultimately 
reduce  the  country’s  vulnerability  to  shocks.  The  plan  also  aims  at  contributing  to  the 
implementation of the European Pillar of Social Rights and to mitigating the economic and social 
impact of the COVID-19 crisis, thereby enhancing the economic, social and territorial cohesion 
and convergence within the EU. 

Fostering economic growth and jobs 

The  plan  aims  to  support  the  economic  recovery  and  resume  the  path  to  growth 
discontinued  due  to  the  COVID-19  pandemic.  In  2020  the  economic  output  contracted  by 
6.3%  compared  to  the  previous  year,  while  in  2021,  the  economy  is  forecasted  to  expand 
strongly by 4.5%. The economic impact of the plan on the Belgian economy is  expected to be 
overall commensurate to the amount of support that has been allocated to Belgium. The Belgian 
authorities  estimate  that,  at  its  peak  in  2022,  the  economic  impact  of  the  plan  is  expected  to 
increase GDP by 0.21 percentage point compared to the baseline scenario (no plan). The Belgian 
authorities  estimate  that  the  full  implementation  of  the  plan’s  measures  will  increase  GDP 
growth  by  0.14  percentage  points  on  average  per  year  during  the  period  2021-2026,  enabling 
Belgium to return to the pre-COVID-19 growth  trajectory already in 2022. However, these are 
lower bound estimates of the plan’s economic impact, as they do not factor in the impact of the 
plan’s  reforms  nor  the  spillover  impact  of  the  EU  wide  implementation  of  the  Recovery  and 
Resilience  Facility.  Several  reforms  included  in  the  plan,  such  as  the  simplification  of 
administrative procedures, the introduction of 5G, the reform of public employment services are 
expected  to  tackle  existing  bottlenecks  to  growth  and  employment  and  bolster  the  expected 

47 

 
 
impact  from  implementation  of  the  planned  investments.    The  Commission’s  2021  Spring 
forecast projects a higher output growth, as it reflects the impact of higher external demand due 
to the RRF’s implementation in neighbouring countries, which could be sizeable for a small open 
economy  such  as  that  of  Belgium.  Taking  into  account  the  above-mentioned  factors,  the 
macroeconomic  projections  underpinning  the  Belgian  plan  are  broadly  in  line  with  the 
Commission 2021 Spring forecast and appear overall plausible for the period 2021-2022. 

All investments in the plan financed through the RRF are expected to be fully additional to 
the baseline without the RRF.  The implementation of the plan is expected to increase capital 
expenditure, notably through public investment and incentives to private investment. The plan is 
expected to contribute to addressing the low level of public investment, which has been subdued 
for  a  prolonged  period.  Public  investment  reached  an  average  of  about  2.5%  of  GDP  in  2010-
2019, well below the EU average leading to an erosion of the quality of the public infrastructure.  
It is expected that the implementation of the recovery and resilience plan will lead to an average 
increase in public investment of 0.2 percentage of GDP over the period 2021-2026 compared to 
baseline  scenario  (no  plan).  A  large  share  of  the  planned  expenditure  (88%  of  the  total)  is 
planned to be spent on increasing the economy’s gross fixed capital formation, according to the 
analysis of the Federal Planning Bureau (2021). Two-thirds of this are expected to be invested in 
tangible fixed assets and one third in intangible assets (of which almost half is to be invested in 
R&D).  More  than  half  of  the  capital  expenditure  is  made  up  of  direct  public  investment,  the 
remaining  part  representing  investments  in  the  corporate  sector  (financed  by  capital  transfers 
received from the government and financed by the RRF) and, to a lesser extent, investments by 
households. It is important to recall that the plan is also expected have a significant crowding-in 
effect  for  private  investment,  as  several  investments  included  in  the  plan  will  require  co-
financing with the intervention of the private sector. 

An  important  share  of  investment  will  be  carried  out  on  construction  and  transport 
infrastructure,  expected  to  have  a  positive  impact  on  economic  growth,  wealth  and  jobs 
and  to  help  address  the  sectors’  challenges  such  as  greenhouse  gas  emissions,  congestion 
and  air  quality.  The  Commission,  the  OECD  and  the  IMF  have  estimated  the  cost  of  traffic 
congestion in Belgium in the range of 1-2% of GDP (Van Essen et al., 2011). Belgium is one of 
the three worst performing countries in the EU with regard to the average number of hours per 
year spent in traffic jams21. For example, in 2019, a person working in Brussels and dependent 
on individual road transport spent, on average, 140 hours per year in traffic jams22. Tackling the 
challenge of road congestion while limiting the negative impact of transport on the environment 
and  air  quality  entails  investment  in  rail,  but  also  in  urban  public  transport  and  clean  and 
sustainable mobility infrastructure for both passengers and freight. 

21 
22 

European Commission, Hours spent in road congestion annually. 
See https://inrix.com/scorecard/ 

48 

 
 
                                                           
In  this  regard,  the  federal  and  regional  authorities  have  plans  to  increase  investment  in 
sustainable transport infrastructure and to implement a modal shift in transport. The plan 
includes investment in cycling infrastructure23, new or more efficient electric or hybrid plug-in 
buses, tram and light metro infrastructure and digital tools with the aim of generating increased 
demand  for  sustainable  transport.  At  the  same  time,  investments  into  freight  transport24  are 
expected to support modal shift from road to more sustainable waterways and rail transport. The 
plan  is  also  expected  to  contribute  to  upgrading  rail  infrastructure,  in  a  context  where  20%  of 
railway  assets  have  already  exceeded  their  expected  lifespan.  Moreover,  the  reform  of  the 
favourable tax treatment for company cars is also expected to provide a significant contribution 
to the decarbonisation of transport. 

Construction  investment  focuses  mostly  on  improving  energy  efficiency  of  buildings.  The 
building  sector  is  responsible  for  more  than  30%  of  non-ETS  GHGs  emissions  in  Belgium. 
Belgium ranked low in relation to the energy performance of its existing housing stock25, which 
is rather old with 80% of the stock built before the introduction of energy norms. In this regard, 
all  entities  have  planned  investments  in  the  energy  efficiency  of  buildings.  The  intention  is  to 
boost the annual renovation rate that is currently low at 0.4% of existing building stock. In order 
to reach carbon neutrality of the sector by 2050, it has been estimated that the annual renovation 
rate should reach about 3%. While measures in the plan mostly concentrate on the renovation of 
public buildings and social housing, measures cover, as well, the reinforcement of incentives for 
the renovation of the stock of private buildings. 

The implementation of the plan is expected to contribute to reducing unemployment. The 
impact of the COVID-19 pandemic on the employment rate has been moderate and limited to -
0.1%,  mostly  thanks  to  the  very  significant  support  measures  adopted  by  the  government  to 
mitigate  the  impact  of  the  crisis,  such  as  the  short-term  unemployment  scheme  for  employees 
and the income replacement schemes for the self-employed. However, the impact of the crisis on 
the  labour  market  is  more  visible  from  the  number  of  average  hours  worked,  which  declined 
sharply in 2020. While in 2021 an increase in the unemployment rate is expected, mostly due the 
phase out of the short-term unemployment scheme and an increase in bankruptcies following the 
end  of  the  moratorium,  the  unemployment  rate  is  projected  to  return  to  a  downward  trajectory 
already in 2022, also thanks to the impact of the increase in economic activity to which the plan 
contributes  and  the  investments  in  up-  and  re-skilling.  According  to  the  Federal  Planning 
Bureau’s projections the implementation of the plan is expected to create a moderate amount of 
additional jobs in 2022 and over the period 2021-2026. This positive impact would in particular 
come from the construction sector, reflecting the large share of investments in the plan dedicated 

Plans are to build 188 km of new cycle infrastructure and renovate 1 356 km of additional infrastructure. 
In  the  field  of  rail  freight  transport,  the  Federal  Government’s  ambition  is  to  double  the  volume  of  rail 

23 
24 
freight by 2030 
25 
relation to the energy performance of its building stock. 

According  to  the  European  Commission’s  Building  Database  of  the,  in  2014  Belgium  ranked  25th  in 

49 

 
 
                                                           
to  construction  and  renovation  of  buildings  and  dwellings.  However,  as  for  the  impact  on 
economic growth, these estimates represent a lower bound as they do not factor in the impact of 
the  reforms  included  in  the  plan.  The  implementation  of  reforms  such  as  those  included  in 
component  4.2  and  5.1  is  expected  to  reinforce  the  impact  of  the  planned  investments  and  is 
expected to result in a larger number of new additional jobs. 

50 

 
 
 
 
Box 2: Stylised NGEU impact simulations with QUEST - Belgium 

Model simulations conducted by the Commission using the QUEST model show that the economic 
impact  of  Next  Generation  EU  (NGEU)  in  Belgium  could  lead  to  an  increase  of  GDP  of  between 
0.5%  and  0.9%  by  202626  and  this  impact  would  decrease  gradually  afterwards.  After  20  years, 
GDP could be 0.2% higher. Spillovers account for a large part of such impact.  According to these 
simulations, this would translate into up to 16,000 additional jobs. Cross border spillovers account for 0.5 
of pps of GDP in 2026, showing the value added of synchronised expenditure across Member States (line 
2  of  Table  1).  Even  in  a  scenario  with  a  lower  productivity  of  NGEU  funds,  it  would  still  lead  to  a 
significant impact (line 3).27 

Table : QUEST simulation results (deviation of real GDP level from non-NGEU case, linear 
disbursement assumption over 6 years) 

This stylised scenario does not include the possible positive impact of structural reforms, which can 
be  substantial.  A  model-based  benchmarking  exercise  shows  that  undertaking  structural  reforms  that 
would result in halving the gap vis-à-vis best performers in terms of indicators of structural reforms could 
raise  Belgium’s  GDP  by  16%  in  20  years’  time,  more  than  the  11%  found  for  the  EU  average,  the 
difference reflecting the relatively larger gaps towards best performers in Belgium (Varga & in 't Veld, 
2014). 

Due  to  the  differences  in  the  assumptions  and  methodology,  the  results  of  this  stylized  assessment 
cannot  be  directly  compared  to  the  numbers  reported  in  chapter  4  of  Belgium’s  recovery  and 
resilience plan. 

Productivity  is  expected  to  increase  following  the  implementation  of  the  measures  in  the 
recovery and resilience plan. Belgium’s productivity growth has stagnated in recent years due 
to  a  number  of  country-specific  factors.  Measures  in  the  plan  contribute  to  a  certain  extent  to 
address  these  factors.  The  plan  contains  a  number  of  investments  and  reforms  aimed  at 
improving  the  business  environment,  through  a  reduction  of  administrative  and  regulatory 

26 
Transition Fund, Rural Development and RescEU. 
27 
capital. 

RRF  amounts  to  roughly  90%  of  NGEU,  which  also  includes  ReactEU,  Horizon,  InvestEU,  Joint 

Technically,  the  low  productivity  scenario  considers  a  significantly  reduced  output  elasticity  of  public 

51 

Scenario 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2040 Baseline 0.5 0.8 0.8 0.8 0.9 0.9 0.7 0.6 0.5 0.4 0.2    of which spillover 0.4 0.5 0.5 0.5 0.5 0.5 0.4 0.3 0.2 0.1 0.0 Low productivity 0.3 0.4 0.4 0.5 0.5 0.5 0.4 0.3 0.2 0.2 0.1   
 
 
 
                                                           
burden, as well as investments in the digitalisation of the justice system. These measures address 
structural factors that hamper productivity growth. They are therefore expected to have a positive 
impact on productivity, and to contribute to boosting higher growth. 

A sizeable investment in the digitalisation and modernisation of the public administration 
is  expected  to  reduce  the  administrative  burden.  This  investment  intends  to  promote  the 
creation  of  a  more  ‘user-centric’  public  administration,  making  an  increased  use  of  modern 
digital tools. The aim is to provide citizens and businesses with access to services allowing them 
to communicate in a timelier and more effective manner with a number of services of the public 
administration. Combined with reforms at federal and regional level aiming, including inter alia, 
at  simplifying  administrative  procedures,  enhancing  e-procurement,    the  investment  in  the 
digitalisation  of  public  services,  inter  alia  the  push  for  a  wide  adoption  of  electronic  invoicing 
and the implementation of the ‘only once’ principle, is expected to contribute to reduce the cost 
of the administrative burden, which was estimated by the Federal Planning Bureau at some EUR 
7 billion (1.6% GDP), (Kegels , 2018). Investments in this regard are foreseen by all entities. 

An  effective  justice  system  is  an  important  structural  element  for  an  investment-  and 
business-friendly environment. A persistent lack of consistent, reliable and uniform court data 
remains, which hampers progress on the efficiency of the justice system. The overall efficiency 
of the justice system is expected to improve thanks to the investments included in the plan. The 
digital transformation of the justice system aims to reduce the time needed to process cases, so 
that the backlog of court cases can be progressively reduced. This is crucial to improve trust in 
the  justice  system  and  reduce  uncertainties  for  businesses.  Moreover,  the  rate  of  online 
publication  of  judgments  is  expected  to  increase  (2021  EU  Justice  Scoreboard),  which  should 
foster legal certainty for businesses and citizens. 

The reforms envisaged in the plan are expected to support the improvement of the business 
environment.  The  whole  procedure  to  set  up  and  to  manage  a  business  will  be  reviewed  and 
simplified  through  digitalisation.  The  existing  large  number  of  forms  to  modify  constitutive 
elements of an enterprise is expected to be drastically reduced. The implementation of the Single 
Digital  Gateway  will  allow  to  apply  the  “Once-Only”  principle  also  to  businesses  and  citizens 
from other Member States. 

Reforms and investments in the plan aim to address some of the remaining weaknesses of 
the  overall  well-performing  Belgian  R&D&I  system.  Initiatives  have  been  included  in  the 
plan  to  promote  the  dissemination  of  innovation,  especially  for  SMEs,  as  it  is  currently 
concentrated  in  a  rather  small  number  of  sectors  dominated  by  multinational  companies.  The 
plan includes a reform to broaden the innovation basis in Flanders which aims at reviewing the 
focus  and  the  conditions  to  use  R&D  support  instruments  and  at  adjusting  them  to  facilitate 
participation by SMEs (R-5.07). 

Measures in the plan also  aim to support the  transition to the post-COVID era.  This  will 
include  innovation  and  support  to  promising  sectors;  with  particular  attention  to  SMEs,  which 
make up the bulk of Belgium’s economic fabric and which have been particularly affected by the 
economic  crisis  caused  by  the  pandemic  and  the  restriction  measures  adopted  to  curb  the 

52 

 
 
expansion of the pandemic. For instance, component 5.2 contains a number of projects aiming to 
support the development of future-proof economic sectors. For instance, it contains a project to 
further  develop  nuclear  medicine  in  Belgium.  Another  project  aims  at  developing  the  Belgian 
know-how  on  the  treatment  of  waste  from  the  decommissioning  of  nuclear  plants,  which  is 
highly relevant as Belgium is committed to phase out its production of nuclear energy. 

The plan supports a shift to a greener and more digital economy. In the component 1.2 the 
plan  focuses  on  the  development  of  emerging  energy  technology  and  intends  to  support  the 
transition away from nuclear energy with a view to focusing on renewable sources of energy and 
advancing  the  development  of  the  hydrogen  economy.  A  positive  impact  on  growth  and 
employment is expected from the direct investment in (energy) infrastructure and investments in 
R&D. The plan also  contains measures to  accelerate the introduction of  5G in  Belgium and to 
support the related economy. 

Strengthening social cohesion 

Reforms to facilitate access to the labour market and investments focus on increasing the 
employment rate. The employment rate stood at 70.0% in 2020, lower than in the neighbouring 
countries and on average in the EU-27 (72.4%). In order to reach the federal government’s target 
of an employment rate of 80%, the greatest improvement is needed among the most vulnerable 
groups (people with  a migrant  background, the low-skilled, people with  disabilities) as  well as 
older workers. The recovery and resilience plan submitted by Belgium includes measures aiming 
at addressing relevant employment and social challenges, identified in previous country reports, 
country-specific  recommendations  and  monitored  through  the  Social  Scoreboard  (see  Box  3). 
These measures  have the potential to  contribute  to  implementing the European Pillar of Social 
Rights. 

To  foster  access  to  the  labour  market  and  address  skills  mismatches,  the  plan  aims  to 
modernise  the  higher  educational  system  and  strengthen  participation  in  adult  learning. 
Reforms and investments focus on extending and making the training offer and incentives more 
transparent,  including  by  establishing  individual  learning  accounts,  and  investing  in  education 
and training infrastructure. Higher education in Flanders is expected to be encouraged to develop 
a future-proof and flexible portfolio of courses, further develop lifelong learning and new digital 
forms of education to meet the demands of the labour market and society. In addition, some of 
the measures are intended to strengthen digital inclusion for vulnerable groups by combining the 
provision  of  digital  equipment  with  training  in  digital  skills  in  both  communities.  Measures  to 
fight the phenomena of early school leavers are also planned in the French Community. 

Specific  actions  are  foreseen  to  help  support  labour  market  integration,  in  particular  for 
vulnerable  groups.  This  is  done  by  changes  to  the  responsibilities  and  functioning  of  the 
regional  public  employment  services,  with  increased  provision  of  personalised  support  to 
vulnerable jobseekers in  Wallonia and further digitalisation in  Brussels  and Flanders. The plan 
includes  two  reforms  to  tackle  discrimination  on  the  labour  market,  which  is  in  particular 
relevant as regards the low employment rate of people with a migrant background. To strengthen 
further  incentives  to  work,  these  reforms  are  complemented  by  a  pension  reform.  The  plan 

53 

 
 
includes  also  some  investments  in  social  infrastructure,  including  in  the  renovation  and 
construction of social housing and childcare. 

In  several  areas,  the  plan  could  have  been  more  ambitious.  For  several  of  the  proposed 
reforms, like the pension reform, further information on their design and implementation strategy 
would  be  needed  to  fully  assess  their  potential  for  achieving  lasting  improvements.  Overall,  a 
more holistic strategy targeting vulnerable groups, including by the provision of more integrated 
and targeted support for social and labour market inclusion and participation in lifelong learning, 
would  have  been  welcome.  The  investments  to  digitalise  and  increase  the  training  offer, 
including  through  the  construction  or  renovation  of  schools  and  training  centres,  especially  in 
Wallonia, could be complemented by increased incentives to participate in lifelong learning. A 
reform of vocational education and training in French-speaking Belgium would have reinforced 
the  impact  of  these  investments  in  training  facilities.  Finally,  the  structural  challenges  of 
inequalities  in  the  education  system,  which  would  require  substantial  targeted  investments  in 
vulnerable pupils’ and teachers’ training, are addressed only to a limited extent in the framework 
of the plan. 

54 

 
 
Box 3:  Employment and social challenges in light of the Social Scoreboard 
accompanying the European Pillar of Social Rights 

The  Social  Scoreboard  supporting  the  European  Pillar  of  Social  Rights  points  to  some 
employment  and  social  challenges  in  Belgium.  Following  the  outbreak  of  the  COVID-19  crisis,  the 
federal and regional Belgian governments took several measures to dampen the impact of the crisis on 
employment. As a result, the initial impact on unemployment has been mitigated, at 5.6 % in 2020 (0.2 
percentage point higher than in 2019) but may rise further in 2021. This outbreak of the COVID-19 is 
expected to have interrupted the increasing trend in the employment rate, which stood at 70.0% in 2020, 
below the EU average (72.4%). There are indications that the COVID-19 crisis has had a more negative 
impact on the most vulnerable groups, including the low-skilled, people with a migrant background and 
people with disabilities. On the positive side, Belgium performs better than the EU average in terms of 
income inequality and childcare provision for children younger than three years. 

Low  labour  market  participation  contributes 
to  poor  social  outcomes  for  specific  groups. 
Although  slowly  declining,  the  share  of  people 
living  in  very  low-work  intensity  households 
(12.4%) is still well above the EU average (8.5%) 
and  the large  majority  of  them  (63.3%)  is  at risk 
of  poverty.  The  COVID-19  crisis  risks  reversing 
the  recent  positive  trend  as  it  is  expected  to 
worsen 
for 
the 
is 
In 
vulnerable  groups. 
preliminary  evidence  that  the  outbreak  of  the 
COVID-19  pandemic  and  the  subsequent  period 
of  distance  learning  has  further  worsened  the 
educational performance and existing educational 
inequalities linked to socio-economic background, 
as well as school dropouts.  

labour  market  perspectives 
there 

addition, 

for 

The  Recovery  and  Resilience  Plan  submitted 
by  Belgium  addresses  a  multitude  of 
employment  challenges  relevant 
the 
implementation of the Pillar. To foster access to 
the  labour  market,  the  plan  contains  measures 
aimed  at  strengthening  participation  in  adult 
learning,  including  by  establishing  individual 
learning  accounts,  developing  and  upgrading 
curricula reflecting labour market needs, including 
in  higher 
the 
transparency of the training offer. However, most 
investments 
focus  on 
upgrading  education  and  training  infrastructure, 
including  digital  infrastructure  and  equipment, 
and less on strengthening incentives to participate in training, in particular for vulnerable groups. This is 
in particular a concern in Wallonia. To improve the effectiveness of active labour market policies, the 
Belgian plan includes changes to the responsibilities and functioning of the regional public employment 

in  up-and 

education, 

re-skilling 

increasing 

and 

55 

Critical situationTo watchWeak but improvingGood but to monitorOn averageBest performersEqual opportunities and access to the labour marketDynamic labour markets and fair working conditionsSocial protection and inclusionSocial Scoreboard for BELGIUMEarly leavers from education and training (% of population aged 18-24) (2020)Youth NEET (% of total population aged 15-24) (2020)Gender employment gap (2020)Income quintile ratio (S80/S20) (2019)At risk of poverty or social exclusion (in %) (2019)Employment rate (% population aged 20-64) (2020)Unemployment rate (% population aged 15-74) (2020)Long term unemployment (% population aged 15-74) (2020)GDHI per capita growth (2019)Net earnings of a full-time single worker earning AW (2019)Better than averageUpdate of 29 April 2021. Members States are classified on the Social Scoreboard according to a statistical methodology agreed with the EMCO and SPC Committees. It looks jointly at levels and changes of the indicators in comparison with the respective EU averages and classifies Member States in seven categories. For methodological details, please consult the Joint Employment Report 2021; NEET: neither in employment nor in education and training; GDHI: gross disposable household income.Impact of social transfers (other than pensions) on poverty reduction (2019)Children aged less than 3 years in formal childcare (2019)Self-reported unmet need for medical care (2019)Individuals' level of digital skills (2019) 
 
services, with increased outreach to specific inactive groups and plans to strengthen career counselling 
in  Flanders,  increased  provision  of  personalised  support  to  vulnerable  jobseekers  by  the  public 
employment service in Wallonia and further digitalisation of the public employment service in Brussels. 

With more people likely to fall back on the basic safety nets due to the COVID-19 crisis, reforms 
on social inclusion are important in order to provide much needed support, in synergy with ESF 
funding.  The  plan  includes  a  number  of  investments  to  foster  social  inclusion,  in  particular  for 
vulnerable  groups,  but  comprehensive  reforms  and  targeted  measures  to  address  inequalities  of 
opportunities  are  missing.  Investments  in  this  area  are  mainly  aimed  at  enhancing  digital  inclusion, 
expanding  access  to  childcare,  reducing  early  school  leaving  and  catching  up  with  learning  delays  in 
secondary  schools  due  to  COVID-19,  as  well  as  social  housing  for  vulnerable  groups.  The  plan  also 
includes  measures  aimed  at  tackling  discrimination  on  the  labour  market,  such as  improving  the  legal 
framework,  the  tools  available  and  strengthen  targeted  checks  on  discrimination.  Nonetheless,  while 
relevant to address the investment needs related to social inclusion, the interventions remain fragmented 
and  a  comprehensive  strategy  addressing  inequalities  of  opportunities,  including  as  regards  labour 
market integration of vulnerable groups and education and social housing, is missing. 

Reducing vulnerability and increasing resilience 

Measures  in  the  plan  are  expected  to  have  a  positive  impact  on  addressing  potential 
vulnerabilities  to  shocks.  Different  components  in  the  plan  contain  measures  expected  to 
reinforce the structural resilience of the economy and to reduce its vulnerability to shocks.  The 
high  level  of  public  debt  combined  with  the  high  level  of  public  spending  and  a  low  level  of 
public investment constitute a major vulnerability of Belgium. 

A  modest  positive  impact  of  the  plan  on  public  finances  is  expected.    According  to  the 
analysis carried out by the Federal Planning Bureau the implementation of the measures included 
in the plan will have a positive impact on public finances, which will improve by 0.07 percentage 
points of GDP on average over the period 2021-2026 compared to a no-plan scenario. Likewise, 
the positive impact on public debt is estimated at 0.44 percentage points of GDP on average over 
the period 2021-2026 compared to a scenario of no-plan. In this regard, it is important to recall 
that this  estimation  does  not  factor in  the potential  impact  of the reforms included in  the plan. 
The plan includes indeed reforms that have the  potential to  increase the  positive impact  of the 
plan on public finances. Notably, the introduction of spending reviews and the implementation of 
the pension reform could entail a larger impact and free some budgetary space. 

The  spending  review  projects  included  in  the  plan  aim  at  improving  the  composition  of 
public expenditure at different levels of government. Spending reviews will be carried out on 
a potentially large share of public spending over the coming years. The commitment to roll out 
spending  reviews  has  been  confirmed  at  different  government  levels  (component  6.1).  The 
participation of all entities is essential to cover a large share of the total public spending as, since 
the sixth state reform in 2016, an increasing share of spending responsibilities has been devolved 
to the federated entities. 

Spending  reviews  have  the  potential  to  reprioritise  expenditure  towards  more  growth-
friendly  items  or  items  that  promote  long-term  sustainability,  including  environmental 

56 

 
 
 
sustainability. Several studies have showed that redirecting spending towards public investment 
could  have  a  positive  impact  on  economic  growth  and  sustainability  by  enabling  higher 
productivity  and  operational  efficiency.  By  improving  efficiency  or  by  reducing  ineffective  or 
low-priority  expenditures,  these  exercises  could  release  resources  for  new  policies  and 
investments,  which  is  especially  important  in  the  current  budgetary  context  characterised  by 
large deficits and an increasing level of public debt. 

Spending  reviews  will  be  anchored  in  the  annual  budgetary  process  of  the  different 
government levels. While the approach to conducting expenditure reviews could be different, in 
terms of spending coverage and resources allocated to the exercise, the integration of spending 
review in the budgetary process should ensure that the results of the review enter the formulation 
of  the  government  policies  in  a  structural  way,  and  be  pursued  beyond  the  timeframe  of  the 
Facility. In Flanders, which has already run some pilot review projects, the budgetary framework 
will also be complemented by the introduction of an expenditure norm. The exercise will focus 
as well on reducing the regulatory burden, including addressing ‘gold-plating’ which results in 
an unnecessary strict implementation and enforcement of the rules. 

The  pension  reform  aims  to  improve  the  financial  and  social  sustainability  of  public 
finances.  In  light  of  the  large  expected  increase  in  age-related  spending  and  the  high  level  of 
public  debt,  the  future  pension  reform  would  notably  focus  on  the  need  to  ensure  its  financial 
sustainability. In this regard, the plan includes a commitment to table a reform proposal by end 
2021 with a view to its adoption by mid-2024. 

Measures in the plan are expected to increase institutional resilience. The modernisation and 
the  digitalisation  of  the  public  administration  is  expected  to  increase  its  efficiency  and  its 
capacity to provide a prompt and informed reaction to shocks. Several projects are expected to 
increase  the  amount  of  data  available  to  policy  makers  and  in  this  way  they  are  expected  to 
contribute to reduce the time frame and increase the evidence base for policy decisions. 

Investment in future-proof economic activities will reduce vulnerability to shocks. Through 
investments  into  emerging  energy  technologies  (Component  1.2),  the  recovery  and  resilience 
plan  is  expected  to  contribute  to  reducing  the  country’s  dependence  on  import  of  fossil  fuels, 
which could increase in the short term in view of the projected phase out of nuclear-based power 
generation. Equipping the labour force with the skills required for supporting the transition to a 
greener and more digital economy is expected to reinforce the resilience of the economy, and in 
particular  of  the  labour  market,  to  shocks.  Measures  in  component  5.1  and  in  the  fourth  axis 
contribute  to  this  objective.  In  particular,  component  4.2  contains  measures  that  address  risks 
from the increasing digitalisation of society. The digital divide is already important. Almost 30 
% of the Belgian population has low digital skills and 5.9% of the population does not use the 

57 

 
 
Internet28. Moreover, component 1.3 is expected to improve resilience of the natural system, in 
particular by promoting the circular management of water. 

28 

Digital Economy and Society Index. 

58 

 
 
                                                           
Cohesion and convergence 

The  plan  contains  several  measures  to  reduce  inequalities  and  contribute  to  increasing 
social  cohesion  and  territorial  convergence.  Component  1.1  contains  measures  aiming  at 
improving the energy efficiency of buildings, both public and private. It contributes to reducing 
inequality  to  the  extent  the  renovation  of  social  housing  is  expected  to  reduce  energy  poverty. 
The  renovation  of  school  buildings  combined  with  the  upgrade  of  their  IT  infrastructure  as 
foreseen in components 2.3 and 4.1 are expected to increase social cohesion to the extent these 
measures contribute to guarantee equal opportunity of access to quality education. In particular, 
investments in digital infrastructure and equipment in schools and higher education institutions, 
linking the allocation of digital equipment to the quality of pedagogical plans and training (e.g. 
Wallonia  Digital  Schools)  or  embedded  in  a  comprehensive  digital  education  strategy  (e.g. 
Flanders  Digisprong),  are  expected  to  contribute  to  reducing  the  digital  divide  and  inequalities 
between students, with a positive impact on social and territorial cohesion. 

Several measures in the plan are expected to contribute to social cohesion by increasing the 
job  opportunities  for  workers  in  vulnerable  groups.  For  instance,  this  is  the  case  for  the 
foreseen  investments  aimed  at  strengthening  the  social  economy  in  Flanders  (I-5.04)  and 
Brussels  (I-4.07).  This  kind  of  investments  has  the  potential  to  create  new  jobs,  especially  for 
people with a low education level, fostering employment for groups less integrated in the labour 
market. 

Belgium’s Recovery and Resilience Plan contains a series of measures that are expected to 
positively impact the country’s challenges in the area of equal opportunities for all. These 
include  dedicated  measures  targeting  the  challenges  of  specific  groups  in  situation  of 
vulnerability,  such  as  persons  with  disabilities,  persons  with  a  migrant  background  or  older 
persons.  The  plan  includes  a  set  of  reforms  and  investments  contributing  to  supporting  the 
inclusiveness  of  education  systems  and  to  promoting  social  integration  and  inclusion  in  the 
labour  market.  The  provision  of  training,  with  a  focus  on  digital,  is  important  to  mitigate 
inequality  risks  stemming  from  an  increasing  digital  divide.  The  objectives  of  equal 
opportunities  for  all  are  also  integrated  in  other  measures  of  the  plan,  such  as  those  related  to 
social housing, mobility or digital inclusion. The plan includes a reform at the federal level that 
is  to  monitor  diversity  and  discrimination  in  the  labour  market  at  the  sectoral  level  and  also 
improve the regulatory framework of discrimination tests and the available tools and knowledge 
in administration, which could contribute to a higher employment rate of people with a migrant 
background.  However,  while several  measures  can  contribute directly or indirectly to reducing 
the existing inequalities in the labour market and society, the interventions are fragmented and 
fall short of setting out a comprehensive strategy for addressing inequalities of opportunities. 

Several measures in the plan are expected to contribute to more gender equality. The plan 
includes dedicated measures targeting the challenges to gender equality, such as women’s lower 
employment rate and a lower representation in the STEM fields.  Considering that a number of 
investments  could  potentially  create  demand  for  labour  in  currently  male-dominated  sectors  in 
the short term, it will be important that Belgium effectively monitors, as announced in the plan, 
that its implementation is aligned with the objective of promoting gender equality. Some projects 

59 

 
 
in  the  digital  component  are  expected  to  contribute  to  ensuring  that  policy  makers  are  better 
informed on the equality dimension through additional data or in-depth analysis on the state of 
equality. The Institute for the Equality of Women and Men is expected to use such an analysis of 
the labour market to contribute to mainstream gender equality. 

The plan also includes a measure that aims to increase the accessibility of railway stations 
to people with reduced mobility. The measure targets in particular persons with permanent or 
temporary disabilities, families with children, passengers with heavy luggage etc. Currently, only 
14%  of  network  stations  (29%  of  upland  passengers)  are  accessible  to  persons  with  reduced 
mobility. 

Conclusion 

Taking into consideration all reforms and investments envisaged by Belgium, its recovery 
and resilience plan is expected to have a high impact on strengthening the growth potential, 
job creation, and economic, social and institutional resilience of Belgium, on contributing to 
the implementation of the European Pillar of Social Rights, including through the promotion of 
policies for children and youth, and on mitigating the economic and social impact of the COVID-
19 crisis, thereby enhancing the economic, social and territorial cohesion and convergence within 
the Union. This would warrant a rating of A under the assessment criterion 2.3 of Annex V to the 
RRF Regulation. 

4.4. The principle of ‘do no significant harm’ 

The measures in Belgium’s recovery and resilience plan have been assessed to verify their 
compliance with the ‘do no significant harm’ (DNSH) principle. The assessment follows the 
methodology  set  out  in  the  Commission’s  technical  guidance  on  the  application  of  ‘do  no 
significant  harm’  under  the  Recovery  and  Resilience  Facility  Regulation  (2021/C  58/01) 
(‘DNSH Guidance’). It covers the six environmental objectives within the meaning of Article 17 
of Regulation (EU) No 2020/852, namely climate change mitigation, climate change adaptation, 
sustainable  use  and  protection  of  water  and  marine  resources,  circular  economy,  pollution 
prevention and control, and protection and restoration of biodiversity and ecosystems. 

Each  ‘do  no  significant  harm’  assessment  follows  a  two-step  approach.  The  first  step 
assesses whether there is a risk that a measure could do significant harm to one or more of the 
environmental  objectives.  In  some  cases,  the  assessment  concludes  that  there  is  no  risk  of 
significant harm, in  which case the measure is  assessed as compliant with this objective of the 
Regulation. In cases where the analysis identifies a risk, a more detailed assessment is performed 
in which the absence of significant harm is verified or measure safeguards are provided to ensure 
the absence of significant harm. 

The requirements of the DNSH  assessment are enshrined in the design of a measure and 
where needed, specified  in a milestone or target. This  ensures that any  disbursement for the 
respective measures can only be made once compliance with the DNSH principle is ensured. For 
instance,  regarding  measure  ‘Backbone  for  H2  and  CO2’(I-1.14),  to  ensure  that  only  activities 
that  are  in  compliance  with  the  DNSH  principle  receive  funding,  Belgium  will  include  in  the 

60 

 
 
criteria for funding CO2 infrastructure projects the requirements that the CO2 transported from 
the installation where it is captured to the injection point does not lead to CO2 leakages above 
0.5% of the mass of CO2 transported; that CO2 is delivered to a permanent CO2 storage site that 
meets  the  criteria  for  underground  geological  storage  of  CO2;  that  appropriate  leak  detection 
systems are applied and a monitoring plan is in place, with the report verified by an independent 
third  party.  This  commitment  has  been  integrated  into  the  corresponding  milestone.  The 
development of a H2 backbone, either by constructing new pipelines or by repurposing existing 
gas pipelines, is meant to transport 100% hydrogen and is therefore compliant with the DNSH 
principle. 

A  similar  approach  is  followed  for  other  broad  funding  schemes,  in  particular  R&D 
schemes.  This  includes  measures  such  as  ‘strengthening  R&D’  in  Flanders  (I-5.11).  For  this 
measure,  Belgium will include provisions in  the calls for projects  to  exclude the most harmful 
assets and activities, so as to  ensure that  the R&D projects  will target  processes that are either 
technologically  neutral  at  the  level  of  their  application  (i.e.  they  can  be  applied  across  all 
available technologies, so that they do not specifically target applications with negative impact) 
and exclude ‘brown’ R&D, for instance R&D related to fossil fuels, including their downstream 
use. A corresponding milestone linked to the calls for projects or tenders has been included in the 
plan. 

In terms of clean mobility, Belgium’s recovery and resilience plan includes the greening of 
public  transport  bus  fleets.  Belgian  investments  in  buses  comply  with  the  DNSH  principle 
since the measures concern only zero- and low emission buses. Flanders is retrofitting 250 low-
floor hybrid buses into plug-in hybrids of the category M3 and is purchasing 35 plug-in hybrid 
and 50 full electric buses (I-3.16). The buses that will run on the Bus Rapid Transit lane (‘High 
Level  Bus Service’) will be zero-emission (I-3.05). Brussels has ordered 50 articulated electric 
buses (I-3.17). 

For building renovation measures, the plan confirms compliance with the DNSH principle. 
Belgium’s recovery and resilience plan puts a particular focus on energy-efficient renovation of 
social housing, public buildings and residential buildings. While these have a positive impact on 
emission  reductions,  they  normally  create  significant  amounts  of  construction  waste.  Belgium 
ensures no significant harm to the circular economy objective by detailing in the plan for each of 
the waste components the recycling and recovery policy and actions foreseen and confirms that 
those  actions  ensure  that  at  least  70%  (by  weight)  of  the  non-hazardous  construction  and 
demolition  waste  generated  on  the  construction  sites  will  be  prepared  for  reuse,  recycling  and 
other material recovery. Belgium has provided a similar confirmation for all demolition works to 
be undertaken under other components (for instance mobility infrastructure works). 

The renovation measures in the plan do not include support for heating systems based on 
natural gas. Assurances were received from the Belgian authorities that the measures involving 
building  renovation  will  not  include  support  for  the  installation  of  gas-condensing  boilers.  To 
ensure  compliance  with  the  DNSH  principle  changes  were  made  to  the  design  of  some 
renovation measures in order to explicitly exclude gas-condensing boilers, also ensuring that no 
subsidies for such installations are provided. 

61 

 
 
An  important  part  of  Belgium’s  recovery  and  resilience  plan  is  focusing  on  emerging 
energy technologies having the potential to significantly reduce GHG emissions in energy 
production. Belgium will devote a share of the budget allocated to the off-shore energy island 
(I-1.21) to environmental studies in addition to those already prescribed by law for such projects. 
If  additional  mitigation  measures  are  needed  as  a  result  of  those  studies,  Belgium  commits  to 
implement  them.  A  further  share  of  the  budget  will  be  reserved  for  biodiversity  measures  in 
addition  to  the  mitigation  actions  required  for  obtaining  the  environmental  permits.  For  the 
development of renewable heat networks (I-1.20), Belgium will ensure that, whenever biomass is 
used, it meets the sustainability and greenhouse gas emission savings criteria set out in Articles 
29-31  and  the  rules  on  food-  and  feed-based  biofuels  set  out  in  Article  26  of  the  Renewable 
Energy Directive 2018/2001/EU (REDII), and related implementing and delegated acts. 

Under  measures  for  ‘an  industrial  value  chain  for  hydrogen  transition  (I-1.15,  I-1.16,  I-
1.17), ‘developing the low-carbon industry’ (I-1.18) and ‘Renewable heat networks’ (I-1.20) 
support  may  be  provided  to  installations  covered  by  the  EU  emissions  trading  system.  In 
this  case,  DNSH  compliance  is  ensured  by  excluding  from  eligibility  all  activities  under  the 
Emission  Trading  System  with  projected  CO2  equivalent  emissions  that  are  not  substantially 
lower than the relevant benchmarks established for free allocation. This has been reflected in a 
corresponding  milestone.  With  respect  to  the  production  of  hydrogen  by  methane  pyrolysis  as 
potential technology in demonstration projects (I – 1.15, I – 1.18), the use of fossil fuels for the 
production of hydrogen is not explicitly addressed in the DNSH Guidance for the RRF and was 
subject  to  a  detailed  assessment,  leading  to  the  conclusion  that  the  DNSH  principle  is  fully 
respected  for  the  measures  proposed  by  Belgium.  Indeed,  the  DNSH  compliance  of  the  joint 
production of hydrogen and carbon black by methane pyrolysis is supported by the fact that the 
life cycle CO2 emissions of this joint process are lower than the weighted sum of the emission 
thresholds of hydrogen and carbon-black productions for qualifying the processes as providing a 
‘substantial  contribution  to  climate  change  mitigation’  under  the  EU  Taxonomy  Climate 
Delegated  Act,  Annex129.  In  addition,  particular  attention  has  been  paid  to  the  origin  of 
electricity (if renewable, either thanks to a direct connection to a production unit from renewable 
sources,  or  a  power  purchase  contract  with  renewable  electricity  producers),  origin  of  the  gas 
(plan to use biogas and mine gas of closed mines for measure I-1-18) and the use of produced 
hydrogen (open for different applications in multiple industrial sectors for measure I-1.15). Also, 
to  prevent  lock-in  effects,  the  calls  for  projects  will  remain  open  to  all  zero  carbon  emission 
technologies. Green hydrogen projects are also eligible for the calls. 

The measures in the plan linked to industrial decarbonisation (the production of hydrogen 
based  on  electrolysis  under  measures  I-1.16  and  I-1.17)  and  linked  to  the  deployment  of 
recharging  stations  (under  measures  R-3.04  and  R-3.05,  I-3.18  and  I-3.19)  will  imply  a 

29 
The EU Taxonomy Climate Delegated Act (C(2021)2800) was formally adopted on 4 June and will enter 
into  force  at  the  end  of  the  scrutiny  period  of  co-legislators  (four  months  that  can  be  extended  by  another  two 
months), and it will apply from 1 January 2022. 

62 

 
 
                                                           
higher degree of electrification. These investments can be deemed as complying with DNSH in 
the area of climate change mitigation, provided that the greater electrification is accompanied by 
increased  renewables  generation  capacity.  Although  the  plan  does  not  directly  support  the 
production  of  renewable  electricity,  the  creation  of  the  offshore  energy  island  (I-1.21)  is 
expected to connect important new offshore electricity investments for an expected capacity of 
2,1  GW.  While  this  could  have  been  more  ambitious30,  Belgium  plans  an  increased  renewable 
generation capacity at national level by 2030 (17.5% vs 11.5%31 reached in 2020) (see also Table 
3). 

The necessary safeguards have been built in for measures targeting the aeronautics sector 
that  will  rely  on  calls  for  projects  for  their  implementation.  While  these  measures  can 
support the green transition linked to the aeronautics sector, they need to be appropriately framed 
to  avoid  supporting  and  promoting  conventional  aviation  based  on  fossil  fuels.  Belgium 
confirmed  that  the  aeronautics  part  of  the  measure  ‘Development  of  circular  economy  in 
Wallonia’  (I-5.16)  would  be  limited  to  the  dismantling  and  recycling  of  end-of-life  aircraft 
towards uses in other industries, and excluding the further use in conventional aircraft, as well as 
training  related  to  these  activities.  Future  terms  of  reference  for  calls  for  projects  will  need  to 
include specific criteria to prevent the selection of any projects that would include investments 
related  to  fossil  fuels,  including  their  downstream  use,  and  to  require  that  all  selected  projects 
comply with relevant EU and national environmental legislation. Within measure ‘R&D call for 
support  to  the  aeronautics  and  spatial  industries’  (I-5.09),  Belgium  will  limit  the  scope  of  the 
aeronautics  part  of  the  measure  to  ‘best  in  class  technologies’  with  the  least  environmental 
impact. These safeguards for both measures are reflected in the relevant milestones. 

Conclusion 

Taking into consideration the assessment of all the measures envisaged, no measure for the 
implementation  of  reforms  and  investments  projects  included  in  Belgium’s  recovery  and 
resilience  plan  is  expected  to  do  significant  harm  to  environmental  objectives  within  the 
meaning  of  Article  17  of  Regulation  (EU)  No  2020/852  (the  principle  of  ‘do  no  significant 
harm’). This would warrant a rating of A under the assessment criterion 2.4 of Annex V to the 
RRF Regulation. 

4.5. Green transition 

The Belgian plan correctly follows the methodology for climate tracking in accordance with 
Annex VI of the Recovery and Resilience Facility Regulation, by identifying intervention fields 
and  corresponding  coefficients  for  the  calculation  of  support  to  climate  change  objectives,  for 
each investment measure and the reforms supported by the RRF. It should be noted that: 

Belgium’s  indicative  contribution  for  2030  amounts  to  25%  according  to  the  formula  of  the  Governance 

30 
Regulation (EU) 2018/1999. 
31 

Share of energy from renewable sources in gross final consumption of energy. 

63 

 
 
                                                           
 

 

the  plan  does  not  identify  intervention  fields  for  reform  measures  that  do  not  have  any 
associated cost within the plan and thus cannot contribute to reaching the climate target. 
the measures of the plan often consist of several sub-measures – for most measures where 
that  is  the  case,  the  plan  indicates  an  intervention  field  for  each  sub-measure,  and 
provides a weighted average of contribution to the climate target for the whole measure, 
which is in accordance with the appropriate methodology. 

  The plan does not propose any increased climate coefficients for any measure. 

Overall,  the  Belgian  plan  includes  measures  supporting  climate  change  objectives  for  an 
amount which represents 49.6% of the plan’s total allocation, thus exceeding the minimum 
climate target of 37% by a significant margin. 

10 of the 17 components of the recovery and  resilience plan contribute to  climate change 
objectives, as shown in the Table 7 below. The largest contributions come from emerging energy 
technologies (component 1.2 - 21%), building renovations (component 1.1  - 19%), modal shift 
(component 3.2 - 18%) and cycling and walking infrastructure (component 3.1 - 14%). 

Table 7: Components of the Belgian plan contributing to the climate objectives 

Climate-related 
budget (EUR million) 

% of climate-related 
expenditures of total 
plan 

C1.1 Renovation of buildings 
C1.2 Emerging energy technologies 
C1.3 Climate and environment 
C3.1 Cycling and walking infrastructure 
C3.2 Modal shift 
C3.3 Greening road transport 
C4.3 Social infrastructure 
C5.1 Training and labour market 
C5.2 Supporting economic activity 
C5.3 Circular economy 
Sum 

545.1 
607.3 
348.8 
410.7 
536.9 
172 
72.7 
63.1 
112.4 
67.6 
2936.6 

19% 
21% 
12% 
14% 
18% 
6% 
2% 
2% 
4% 
2% 
100% 

The  plan  is  expected  to  contribute  to  the  achievement  of  the  Union  2030  climate  targets. 
However, continued initiatives will be needed to support a path towards carbon neutrality at the 
level of the Union in 2050. 

Climate and energy 

The reforms and investments of the recovery and resilience plan build on the ambitions of 
the National Energy and Climate Plan of December 2019 and are expected to contribute to 
the  transition  to  climate  neutrality  by  2050.  The  three  components  under  the  sustainability 
axis  (Axis  1)  support  this  objective:  the  renovation  of  buildings  (component  1.1),  the 
development  of  an  economy  based  on  hydrogen  (component  1.2),  and  the  restoration  of 
biodiversity (component 1.3). 

64 

 
 
 
 
 
A  considerable  share  of  the  plan  (about  17%)  will  be  invested  in  the  energy-efficient 
renovation  of  private  and  public  buildings  (component  1.1  in  particular).  The  building 
sector  is  a  non-ETS  sector  which  faces  a  binding  greenhouse  gas  reduction  target  of  35%  by 
2030 below 2005 levels. The NECP sets an emissions reduction objective of 41% for this sector 
and a national  reduction target  of 0,085 MtCO2e on average per  year until  2030. To reach the 
current  2030  objective,  the  renovation  rates  in  the  public  and  private  building  stock  should 
increase  from  the  current  0.5%  per  year  towards  around  3%  per  annum.  The  renovation 
investments and reforms included in the plan are expected to contribute to this objective to some 
extent,  although  the  estimated  impact  is  not  provided  in  the  plan.  The  measures  included  in 
component 1.1 target the energy-efficient renovation of about 1.300.000 m² of public buildings 
and  240.000  residential  dwellings  (including  social  housing)  with  sub-optimal  energy 
performance. Renovation of public buildings, including schools and universities, sports facilities, 
culture  buildings and  public  administration amounts  to  62%  of  the  budget  for  the  component, 
while 10% of the component  is  allocated to  renovation of social  housing. On average, about  a 
third of the allocated expenditures of the component will allow at least medium to deep energy-
efficient  renovations.  Public  renovations  of  training  facilities  in  Wallonia  and  renovation  of 
childcare  facilities  and  social  housing  are  also  included  in  other  components  of  the  plan 
(component 5.1 and component 4.3). 

Investments  in  support  of  the  energy-efficient  renovation  of  the  residential  housing  stock 
are accompanied by reforms of energy subsidy schemes. The main objective of the reformed 
schemes is simplification to enable increased renovation rates. Reforms in Flanders and Brussels 
also  consider  vulnerable  and  poor  consumers.  Flanders  will  reform  and  adapt  several  schemes 
that  will  channel  RRF  support  (R-1.01):  (i)  the  subsidy  regime  for  energy  efficiency  and 
renewable energy as well as the subsidy regime by target groups for improving housing quality 
which will be integrated into a single scheme, (ii) the energy label scheme, (iii) the demolition-
reconstruction  grant  complementing  the  federal  reduced  VAT  scheme  and  (iv)  the  renovation 
support  scheme  for  smart  control  of  heat  pumps,  electric  boilers,  electric  storage  heating  and 
home  batteries.  The  Brussels-Capital  Region  will  reform  the  energy  bonuses  and  housing 
renovation  premiums  into  a  single  regional  mechanism  for  individuals  as  from  2022,  bringing 
about simplification of the administrative procedure (R-1.02). The German-speaking Community 
will  introduce  a  new  system  of  energy  premiums  as  from  July  2021,  notably  aiming  at 
distinguishing  between  small  works,  allowing  access  to  financial  support  in  a  simplified  way, 
and  major  works,  which  will  require  more  detailed  administrative  procedures  (R-1.03).  The 
reform  organising  the  evaluation  and  optimisation  of  permit  procedures  in  Flanders  could  also 
contribute to fostering deep renovations (R-5.06). 

In support of the energy transition and system integration needed to reduce CO2 emissions, 
the plan invests in research and development into new energy technologies with a focus on 
industrial sectors. The plan is expected to considerably support emerging energy technologies 

65 

 
 
projects  such  as  the  electrification  of  industrial  processes,  green  hydrogen  as  raw  material  and 
energy carrier, CO2 capture, use and storage (CCUS), H2 and CO2 transport infrastructure, and 
renewable and waste heat networks. As such, it will actively contribute to the implementation of 
the updated EU industrial strategy.32 The Belgian plan further contains an important investment 
at  the federal  level  into an “Energy  Island” in  the North  Sea, worth  a total  investment  of circa 
EUR 450 million, of which EUR 100 million is included in the estimated costs of the plan. This 
multi-functional  offshore  energy  hub  will  enable  the  connection  of  2.1  GW  offshore  wind 
capacity  (the  future  Princess  Elisabeth  zone),  provide  options  for  the  North  Seas  Energy 
Cooperation (NSEC), including hosting interconnection cables with other countries, and serve as 
an operation and maintenance base for offshore activities. The investments in component 1.2 aim 
for the sustainable anchoring of industry and the development of new future-oriented sectors, all 
of which are part of an integrated energy system. 

Several  measures  in  the  Belgian  plan  have  the  purpose  to  support  low-carbon  hydrogen 
production  and the expansion of the use of hydrogen in different sectors of the economy. 
The investments aim to increase the electrolysis capacity by 2025 to at least 150 MW from 2026 
onwards  and  help  reduce  CO2  emissions  of sectors  that  are  more  difficult  to  decarbonise.  The 
measures  notably  entail  several  initiatives  to  support  innovation  in  the  field  of  low-carbon 
hydrogen  production  technologies  (such  as  electrolysis  or  pyrolysis).  The  national  targets  are 
being translated into 2030 targets in hydrogen strategies at all levels of government. However, a 
quantification  of  triggered  CO2  savings  is  missing  for  most  of  the  measures  in  component  1.2 
which makes the assessment of the additional contribution to Belgium’s 2030 climate and energy 
targets with respect to the NECP difficult. 

Investments into renewables in the plan are limited.  It essentially concerns the investment for 
the offshore energy island. This choice is motivated in part by the expectation that Belgium will 
in  the  future  have  to  rely  quite  substantially  on  the  import  of  renewable  electricity  or  other 
energy vectors (such as renewable hydrogen) from other EU member states given that it has, by 
comparison,  limited  domestic  options  to  build  large  renewables  capacities  to  meet  domestic 
demand.  A  further  investment  that  includes  renewable  energy  concerns  the  renewable  heat 
networks  in  Flanders.  In  any  event,  Belgium  will  have  to  promote  further  investments  in 
renewables outside the plan, particularly in view of the renewable energy target share of 17.5% 
to be reached by 2030 included in the NECP. 

The plan aims to restore biodiversity and increase resilience towards climate change.  The 
conservation, restoration and sustainable use of biodiversity and ecosystem services are essential 
to  strengthen  carbon  storage  capacity  and  improve  resilience  to  climate  change  as  a  buffer 
against floods, droughts and heat effects. Component 1.3 includes investments to accelerate the 
realisation of a  coherent  network of protected areas for nature and  climate-resilient forests, for 
the re-meandering of rivers in Wallonia (I-1.22 ‘Biodiversity and adaptation to climate change’) 

32 

See European Commission, Updating the 2020 New Industrial Strategy, COM(2021) 350 final, 05.05.2021 

66 

 
 
                                                           
and the creation of wetlands in Flanders (I-1.24 ‘Blue Deal’). Overall, investments in the Belgian 
plan are expected to contribute to the ecological value of at least 15.000 hectares of land. In the 
Walloon Region investments are foreseen to create two national parks, not only to enhance the 
conservation  of  biodiversity,  but  also  to  improve  the  quality  of  life  and  the  regional  economic 
development,  via  job  creation  in  the  tourism  sector.  Green  infrastructure  works  will  reconnect 
fragmented ecosystems in Flanders (I-1.23 Ecological defragmentation). 

The  Belgian  plan  includes  climate  adaptation  investments.  Belgium  has  a  high  population 
density and many water-intensive economic activities concentrated in a small area. To be better 
prepared for longer periods of drought and more frequent heat waves, the Blue Deal measure of 
Flanders (I-1.24)  will address  the drought  problems  in  a structural  way  with  a strong  focus on 
integrated  and  nature-based  solutions.  EUR  291  million  will  be  channelled  via  appropriate 
instruments,  involving  several  stakeholders  (industry,  farmers,  municipalities)  in  a  coordinated 
response  to  these  challenges.  Actions  will  include  circular  water  use  projects,  better  water 
retention  and  infiltration  through  the  creation  and  restoration  of  wet  nature  and  valleys  and 
increased  water  conservation  in  open  spaces.  Furthermore,  smart  monitoring  and  data  systems 
are expected to ensure better governance of existing infrastructures and water resources. 

Sustainable mobility 

The  plan  aims  to  reinforce  incentives  and  remove  barriers  to  increase  the  supply  and 
demand of collective and low-emission transport. The plan includes regional reforms aimed at 
supporting  e-mobility  and  deploy  electric  charging  points  –  Flanders  alone  wants  to  deploy 
30.000 charging points. Belgium also committed to improving the service quality and efficiency 
of its railway services. Moreover, Belgium will reform the mobility budget to incentivise the use 
of  collective  transport  and  introducing  incentives  to  install  private  and  semi-public  electric 
charging points. The plan also includes a reform of the company car tax scheme, whereby new 
company  cars  need  to  be  zero-emission  from  2026  onwards  to  benefit  from  the  existing 
preferential  scheme.  The  reform  is  expected  to  reduce  the  greenhouse  gas  emissions  related  to 
the use of company cars and to increase the supply of zero-emission vehicles on the second-hand 
market.  The  reform  is  however  not  expected  to  have  a  lasting  impact  on  congestion  or  to 
contribute positively to the modal shift over the medium-term. 

Belgium  is  using  the  plan  to  substantially  invest  in  its  cycling,  walking,  rail,  urban 
transport  and  inland  waterways  infrastructure.  All  regions  will  be  building  139  km  and 
upgrading 1.300 km cycling and walking infrastructure as part of the plan. Important investments 
will  be  taking  place  to  improve  the  railways  infrastructure,  including  stations,  whose 
accessibility  will  be  improved  for  bicycle  s  and  persons  with  reduced  mobility33.  Belgium  has 
also  committed  to  completing  the  suburban  railway  network  around  Brussels  in  the  future 
revised  SNCB-NMBS  performance  contract.  The  plan  will  support  the  completion  of  the  light 

33 
system for persons with disabilities and persons with reduced mobility (PRM TSI) 

In  line  with  the  technical  specifications  for  interoperability  relating  to  accessibility  of  the  Union's  rail 

67 

 
 
                                                           
metro of Charleroi, the Liège tram and the bus rapid transit system in Mons-Borinage. As part of 
the  plan,  Belgium  has  also  committed  to  covering  the  additional  operational  costs  of  these 
investments  in  the  future  public  service  contract  of  the  Organisme  de  Transport  de  Wallonie. 
Flanders  and  Brussels  will  use  the  plan  to  green  their  bus  fleets.  Important  works  will  also  be 
conducted  along  the  Albert  Canal,  connecting  the  port  of  Liège  with  Antwerp,  to  facilitate 
transport by larger barges.  

Circular economy 

Belgium is  taking advantage of the Recovery  and Resilience Facility to boost the circular 
economy.  Component  5.3  includes  measures  aiming  at  a  diverse  range  of  actions  for  a  better 
resource  management.  New  recycling  infrastructures  will  be  set  up  to  close  missing  parts  in 
different  value  chains,  such  as  textiles  and  mattresses,  and  make  local  circular  production 
possible  (I-5.14  ‘Recycling  Hub’).  Support  will  also  go  to  research  and  development,  for 
instance for the development of alternatives to the use of harmful chemicals, and to innovation 
partnerships, in particular for two priority value chains, metals and construction materials (I-5.15 
‘Belgium Builds Back Circular’ and I-5.17 ‘Circular construction and circular industry’). Other 
actions aim at promoting eco-design projects, the circular use of metals, batteries and minerals, 
or  raising  circular  economy  awareness  of  SMEs  (I-5.16  Deployment  of  circular  economy  in 
Wallonia).  Circular  economy  strategies  will  be  developed  at  different  levels  of  government  to 
guide  and  govern  the  different  investments  envisaged  as  well  as  other  initiatives  outside  of 
Belgium’s recovery and resilience plan. 

Lasting impact 

Many of the measures in the Belgian plan contributing to the green transition are expected 
to have a lasting impact. Due to the lifetime of buildings, the concrete actions on renovations of 
public and private buildings tend to have a lasting impact on the energy efficiency of the building 
stock,  in  particular  the  support  to  deep  renovations.  The  reforms  proposed  in  the  renovation 
component  should  simplify  the  access  to  energy  grants,  thereby  contributing  to  a  better 
investment environment when it comes to public and private renovations. Long lasting impacts 
can  be  expected  from  the  investments  in  new  energy  technologies,  which  tend  to  have  a  long 
technical  lifespan  and  a  multiplier  effect  for  future  investments  in  similar  innovative 
technologies.  Measures  in  the  area  of  transport  aim  to  set  the  sector  on  a  course  towards  low-
emission mobility in the coming decades. Long lasting impacts can finally be expected from the 
measures  for  adaptation  to  climate  change  in  component  1.3  on  water  management  practices, 
biodiversity  conservation,  forest  management  and  carbon  storage.  The  measures  for  improved 
water management contribute to economic resilience with a positive impact on economic activity 
in  sectors with  high dependency on  water (and forestry), such as agriculture, certain  industries 
and energy production, as well as ensuring transport via navigable waterways. 

Conclusion 

Taking into consideration the assessment of all the measures  envisaged, the recovery and 
resilience plan is expected, to a large extent, to make a significant contribution to the green 
transition or to address the challenges resulting from it and ensures that at least 37% of its total 

68 

 
 
allocation contribute to the climate target. This would warrant a rating of A under criterion 2.5 of 
Annex V to the RRF Regulation. 

4.6. Digital transition 

The  measures,  the  plan  correctly  follows  the  methodology  for  digital  tracking  set  out  in 
Annex  VII  of  the  RRF  Regulation,  by  identifying  intervention  fields,  and  corresponding 
coefficients for the calculation of support to the digital objectives, for each investment measure. 
It should be noted that: 

 

 

for the proposed reform  measures that do not  have any  associated  cost  within the plan, 
the  plan  does  not  identify  intervention  fields  for  them,  and  they  do  not  contribute  to 
reaching the digital target. 

the measures  of the plan often consist  of several  sub-measures  – for most measures for 
which that is the case, the plan indicates an intervention field for each sub-measure, and 
provides a weighted average of contribution to the digital target for the whole measure.  

 

the plan does not propose any increased digital coefficients for any measure. 

Overall, the plan contributes to digital objectives for 26.6% of Belgium’s allocation of EUR 
5.9bn,  and  as  such,  the  digital  target  of  20%  is  considered  to  be  met  with  a  margin.  The 
most  important  contributions  to  this  target  relate  to  reforms  and  investments  in  the  digital, 
inclusiveness and productivity axes. 11 out of the 17 components in the plan contribute to digital 
transition  objectives,  as  set  out  in  Table  8  below.  The  largest  contributions  are  from  the 
components in the digital axis (50% of overall digital contribution), with the component ‘public 
administration’  (37%)  contributing  most,  and  from  those  in  the  inclusiveness  axis  (30%  of 
overall  digital  contribution),  where  the  component  ‘Education  2.0’  (23%)  is  providing  a  large 
contribution. The productivity axis has a 9% share in the overall digital contribution of the plan. 
Several measures in the ‘modal shift’ component of the mobility axis (7%) also contribute to the 
digital  transition.  The  sustainability  axis  contributes  to  a  more  limited  extent  to  the  digital 
transition (6.3%). 

Table 8: Components of the Belgian plan contributing to the digital transition objectives  

C1.1 Renovation of buildings 
C1.2 Emerging energy technologies 
C2.1 Cybersecurity 
C2.2 Public administration 
C2.3 Optic fibre, 5G and new technologies 
C3.2 Modal shift 
C4.1 Education 2.0 

69 

Digital-related 
budget 
million) 

(EUR 

% of digital-related 
expenditures 
of 
total plan 

8.1 
92.2 
78.7 
584.5 
94.6 
108.3 
360.9 

1% 
6% 
5% 
37% 
6% 
7% 
23% 

 
 
 
 
C4.2 Training and employment for vulnerable groups 
C4.3 Social infrastructure 
C5.1 Training and Labour market 
C5.2 Supporting economic activity 
Sum 

92.4 
15.4 
93.1 
50.1 
1578.3 

6% 
1% 
6% 
3% 
100% 

Digital transition 

The plan contributes to the digital transition and to addressing associated challenges with a 
comprehensive,  cross-cutting  approach.  While  the  recovery  and  resilience  plan  contains  a 
dedicated  digital  transition  axis  to  digitise  public  administration  (component  2.2),  increase 
connectivity  (component 2.3) and cybersecurity  capabilities (component  2.1), several  measures 
in  the  sustainability  axis  (component  1.2),  mobility  axis  (component  3.2),  inclusiveness  axis 
(components 4.1, 4.2 and 4.3) and productivity axis (components 5.1 and 5.2) also tackle digital 
transition  challenges  in  Belgium  in  a  structural  way.  These  measures  are  aligned  with  various 
European  digital  policy  initiatives  such  as  the  European  digital  strategy34,  the  European  skills 
agenda,  the  European  Pillar  of  Social  Rights,  the  Digital  Single  Gateway,  the  European 
Education Area and the digital education action plan, the European Health Data Space, and the 
EU’s Cybersecurity Strategy for the Digital Decade. 

The plan contains critical reforms to help enable high-capacity connectivity infrastructure 
deployment  by  the  public  and  private  sector,  which  are  essential  building  blocks  for  the 
digital and green transition in Belgium. The plan is expected to importantly contribute to 5G 
readiness,  where  Belgium  has  been  lagging  behind,  thanks  to  structural  reforms  to  remove 
regulatory bottlenecks for the deployment of 5G (component 2.3). As part of the plan, Belgium 
will  organise  and  implement  the  5G  spectrum  auction  under  investment-friendly  conditions  by 
mid-2022, with the required federal legislative framework in place by end 2021. The plan also 
contains  regional  reforms  to  revise  radiation  standards,  which  shall  allow  for  effective  5G 
spectrum  deployment  for  both  private  and  industrial  use,  “if  deemed  necessary  and 
recommended  by  the  relevant  committees”.  The  latter  condition,  however,  adds  a  certain 
contingency to 5G deployment in Belgium. Indeed, whilst those reforms have the potential to lift 
a  significant  hurdle  to  the  large-scale  rollout  in  Belgium,  it  is  not  clear  whether  the  radiation 
standards will be revised to enable such development without entailing restrictions going beyond 
what is required for the necessary protection of health and the environment. 

These  federal  and  regional  reforms  tie  in  with  the  National  plan  for  fixed  and  mobile 
broadband,  which  aims  to  support  the  delivery  of  the  EU  2025  connectivity  targets  in 
Belgium. This plan has four objectives: map network coverage and white zones, facilitate fixed 
and  mobile  broadband  deployment,  support  investments  in  white  zones  and  create  fibre,  and 
increase 5G ownership among the Belgian population at large. In addition, the implementation of 

34 

See in particular: “Shaping Europe’s Digital Future”, COM(2020)67. 

70 

 
 
 
                                                           
the Connectivity Toolbox35, that is to contain connectivity best practices for reducing the cost of 
deploying  electronic  communications  networks  and  for  efficient  access  to  5G  radio  spectrum 
tailored  to  Belgium,  will  be  monitored  in  the  Belgian  plan.  The  implementation  of  the 
Connectivity  Toolbox  will  include  a  national  roadmap  towards  simplifying  the  licensing  and 
permitting  procedures  relevant  for  the  rollout  of  5G  and  very  high-capacity  networks,  such  as 
fibre. The reform aiming to reduce the judicial review lead time for environmental permits by 6 
to  9  months  on  average  in  Flanders  and  investments  to  digitise  urban  planning  permits  in  the 
Brussels-Capital Region and in the Walloon Region are also expected to facilitate investments in 
digital infrastructure (component 5.2). 

The  plan  also  includes  public  investments  in  connectivity  (component  2.3).  The  plan 
contributes  to  increasing  the  fibre  readiness  of  Belgium  in  the  German-speaking  Community 
territory and in  certain  business parks in areas  of the Walloon Region  where such investments 
are not deemed commercially viable. However, the plan underlines that there is no nation-wide 
fibre  deployment  in  Belgium.  Moreover,  there  is  no  public  financing  available  to  reach  the 
objectives of the National plan for fixed and mobile broadband, which is thus to rely solely on 
private  investment  for  its  execution.  The  plan  also  contains  investments  to  ensure  a  higher 
connectivity of schools in the Walloon Region that have not had access to adequate connectivity 
equipment so far. These investments are expected to increase the attractiveness of these regions 
for young people and SMEs alike, contribute to increasing their competitiveness and to reducing 
the  digital  divide  between  these  areas.  There  are  also  investments  to  test  5G  technology 
applications  in  different  business  sectors  including  smart  mobility  and  e-health  in  the  Walloon 
Region.  

The plan contributes to better digitally equipped and connected schools. The plan includes 
in  components  2.3  and  4.1  an  important  package  of  reforms  and  investments  providing  digital 
equipment  and  connectivity  support  to  schools.  Investments  by  the  Walloon  Region  target 
schools which have not benefitted so far from the Digital Schools equipment policy that supports 
digital school projects, linking the allocation of digital equipment to the quality of pedagogical 
plans  and  training.  These  investments  are  expected  to  improve  the  Walloon  Region  schools’ 
access to digital technology and internet access which is among the lowest in the EU.36 The plan 
includes  upgrades  of  digital  connectivity  and  equipment  in  schools  in  all  three  language 
communities  to  increase  the  effective  use  of  technology  and  digital  learning  tools  in  schools, 
which is comparatively low in Belgium. 

The plan is  also expected to help improve the digital performance of young people in the 
primary,  secondary  and  higher  education  systems.  Reforms  and  investments  under 

35 
Common  Union  Toolbox  of  26  March  2021  for  connectivity  pursuant  to  Commission  Recommendation 
(EU) 2020/1307 on a common Union toolbox for reducing the cost of deploying very high capacity networks and 
ensuring timely and investment-friendly access to 5G radio spectrum, to foster connectivity in support of economic 
recovery from the COVID-19 crisis in the Union. 
36 

2018 OECD Teaching and Learning International Survey. 

71 

 
 
                                                           
component  4.1  foster  the  transition  towards  an  Education  2.0  system  by  supporting  schools  in 
developing  ICT policies and the digital upskilling of teachers. This  comprehensive approach is 
expected  to  contribute  to  enhance  digital  skills  of  young  people,  which  is  lower  than  the  EU 
average in  Belgium and  has been worsening over the past  years. The measures build on wider 
educational reform policies already initiated in the French Community (i.e. Pact for an excellent 
education  and  the  Digital  Action  plan  for  schools)  and  the  Flemish  Community  (e.g.  Science 
Technology,  Engineering  and  Mathematics  action  plan,  Digisprong).  Investments  are 
strengthened  by  curriculum  reforms  for  pupils  with  more  attention  to  STEM  skills  and 
entrepreneurship  (in  Flanders),  and  some  investments  in  teachers’  digital  skills  and  dedicated 
support for schools and teachers for this digitalisation wave. 

The  plan  contains  measures  to  increase  digital  inclusion,  notably  for  vulnerable  groups. 
Dedicated measures in components 4.2 and 5.1 contribute to the digital inclusion of vulnerable 
groups,  such  as  combining  the  provision  of  digital  equipment  with  training.  For  example,  the 
‘digibanks’  project  in  Flanders  will  allow  to  tackle  digital  illiteracy  through  improved  digital 
access to essential public services, dedicated digital training and access to digital equipment and 
IT support. Furthermore, the plan supports the development of a digital platform for prisoners, 
which will allow them to participate in online training and hence contribute to their reintegration 
into  society.  In  component  4.3,  the  plan  foresees  the  equipment  of  social  housing  in  Wallonia 
with assistive technologies in order to support the independent living of persons with disabilities 
and  elderly  people.  The  plan  will  also  allow  about  9.450  vulnerable  households  to  receive 
refurbished computers and to equip 285 digital spaces open to the public. 

Digital re-skilling and upskilling measures and a focus on digital skills in lifelong-learning 
should contribute to greater job mobility, labour market integration and help address the 
shortage in digitally skilled workforce. Measures included in components 4.1, 4.2 and 5.1 are 
expected  to  help  address  the  skills  shortages,  in  particular  of  digital  skills,  that  hampers 
Belgium’s growth prospects. The plan, for example, includes reforms by the Public Employment 
Service of the Brussels-Capital Region to assess digital competences of job seekers and invest in 
their digital reskilling and upskilling. Reforms are also included at the federal level to encourage 
training  of  workers  in  sectors  with  shortages,  such  as  the  ICT  sector,  and  introduce  a  digital 
individual learning account for every citizen. In Flanders a digital career platform is being set up, 
with  reforms  introducing  individual  training  and  career  accounts  included  in  the  plan.  In  the 
Walloon Public Employment Service, job  seekers will receive digital  support to  consult  online 
job search instruments and the digital training offer will be enlarged. An EU Biotech School and 
Health Hub training center in Wallonia will be created to deliver digital transformation trainings, 
and  create  awareness  among  students  and  job  seekers  on  the  career  opportunities  of  STEM 
graduates in the health and biotech sector. The plan also foresees the renovation and equipment 
of training centers in Wallonia, notably equipping them with adequate digital infrastructure. 

The  plan  includes  measures  to  help  companies  reap  the  benefits  of  the  digital  transition. 
While  the  investments  directly  targeting  the  digitalisation  of  businesses  are  limited,  they  will 
benefit from the support to reinforced cybersecurity and from investments in skills and improved 
digital public services. In addition, the development of a digital and technological innovation hub 

72 

 
 
in  Wallonia  will  support  start-ups  and  host  innovative  collaborative  projects  (A6K).  Digital-
related investment in R&D will be financed. This includes R&D support in the Flemish Region 
to companies wishing to participate in the planned micro-electronics IPCEI, supporting the EU-
wide microelectronics supply chain in this way. 

The  plan  contains  investments  to  support  the  digitalisation  of  the  tourism,  culture  and 
media  sectors.  To  increase  the  resilience  of  the  Walloon  Region  tourism  industry,  the  on-line 
presence  of  tourism  operators  will  be  fostered,  allowing  them  to  reduce  their  dependency  on 
third-party  platforms  (component  5.2).  French-speaking  media  and  culture  actors  will  be 
supported to be more agile in a digital environment (component 2.2). 

Important investments are dedicated to e-government. Component 2.2 includes a wide array 
of digital investment measures to increase the efficiency and effectiveness of public services at 
various  levels  in  Belgium,  including  through  novel  technologies  such  as  AI.  These  are  mostly 
geared towards modernising and improving public administration processes and are sometimes 
in  certain  instances  accompanied  by  investments  in  civil  servants’  digital  skills.  These  digital 
training programmes are expected to also contribute to delivering a more attractive, future-proof 
and  dynamic  Belgian  civil  service.  Through  enhanced  service  delivery,  some  measures  are 
expected to positively impact the uptake of public services by citizens, an area where Belgium is 
currently scoring below EU average. The plan contributes to equipping public administration to 
implement  the  European  Digital  Identity  (eID)  for  authentication  by  national  and  cross-border 
users  and  accelerates  the  implementation  of  measures  relating  to  the  Single  Digital  Gateway. 
Component  2.2  also  includes  reforms  at  the  federal  level  to  digitalise  public  procurement 
processes, in co-creation with federal end-users, and to introduce e-government applications that 
aim to render public administrations’ service delivery more efficient. 

The  plan  fosters  open  data  use  of  public  administrations.  In  addition  to  providing  a  strong 
push to the digitalisation of public administration, component 2.2 also builds capacities for the 
use of large open databases collecting the data available across different public administrations. 
This  is  well  aligned  with  Belgium’s  challenges  in  this  area,  where  Belgium  scores  below  EU 
average,  and  is  expected  to  contribute  to  increased  data  transparency  towards  citizens  and 
businesses,  a better use  of these data, and to  better informed policy-making and higher-quality 
legislation, while respecting EU data privacy regulation. 

The plan includes investments to modernise the outdated digital infrastructure, judicial file 
management system and network security of the judiciary. Components 2.1 and 2.2 contain 
several  measures  that  are  to  importantly  contribute  to  the  digital  transformation  of  the  justice 
system, which has been importantly lagging behind in Belgium and is specifically called for by 
the  country-specific  recommendations.  These  investments  are  expected  to  also  have  a  positive 
impact  on  the  efficiency  of  the  justice  system  and  its  accessibility,  contributing  to  its  overall 
institutional resilience. A first measure, which is part of  a wider overall strategy in Belgium to 
digitise  justice,  focuses  on  the  digital  transformation  of  civil,  commercial  and  criminal  courts, 
equipment,  deploying 
including  modernizing 
videoconferencing capabilities, and introducing a digital case file (including a digital registry). In 
particular,  the  measure  is  to  tackle  the  current  limitations  of  the  justice  system  with  respect  to 

existing  hardware 

infrastructure 

and 

73 

 
 
case  management  and  data  collection.  This  measure  is  expected  to  reduce  the  time  needed  to 
process  cases,  which  could  lead  to  a  progressive  reduction  in  the  backlog  of  court  cases. 
Moreover, the rate of online publication of judgments is expected to increase (2021 EU Justice 
Scoreboard).  However,  the  federal  administrative  courts  fall  outside  the  scope  of  this  project. 
Another  measure  in  component  2.2  aims  to  have  a  digital  police  file  that  can  be  exchanged  in 
digital format with the justice system. The digitalisation and a higher effectiveness of the justice 
system are also targeted by measures in component 2.1 to increase cybersecurity capabilities of 
law  enforcement  agencies  to  ensure  that  private  communication  interception  operations  can  be 
carried out in a 5G environment and that such intercepted communications can be registered and 
shared with prosecutors in a digital format. 

Investments  in  e-health  solutions  are  expected  to  reinforce  the  overall  resilience  of  the 
health  system.  Component  2.2  targets  different  actions  in  the  area  of  e-health.  At  the  federal 
level,  an  authority  will  be  set  up  and  tasked  with  the  governance  of  health  related  data,  which 
will  be  used  to  better  inform  policy  decisions  on  health  matters  by  collecting,  processing  and 
using health data in a more comprehensive way. Through this investment, citizens should have 
better access to their own health data as well as to health services, thus empowering them to take 
a  more  active  role  in  managing  their  own  health.  Moreover,  it  will  enable  data  sharing,  in 
alignment  also  with  cross-border  EU  initiatives  like  the  European  Health  Data  Space.  Health 
professionals will be equipped with digital tools that provide a comprehensive overview of the 
health status of patients, in order to improve their diagnosis capabilities and enhance the quality 
of  prescriptions.  This  is  expected  to  contribute  also  to  a  reduction  in  the  costs  of  the  Belgian 
health system. For instance, tests that are redundant thanks to a better informed diagnosis will no 
longer need to be carried out. In the French Community, the digital transformation of ONE, the 
body covering childhood policies, protection of and support for the mother and child, is expected 
to improve the administrative management and overview of child and family support and inform 
policy-making,  by  creating  an  integrated  digital  environment  for  relevant  services  and 
comprehensive data collection and processing. 

The sustainability and mobility axes contain measures to support the development of smart 
mobility and new energy technologies. Component 2.1 contains investments in state-of-the-art 
technologies to support the energy transition. Component 3.2 includes measures to develop smart 
road signals, smart mobility and also mobility-as-a-service. 

The plan is expected to have a lasting impact on Belgian society’s overall cyber resilience 
and  security.  The  plan  contains  a  specific  component  2.1  dedicated  to  cybersecurity. 
Investments  target  increased  cyber  risk  awareness  and  management  capabilities  for  SMEs  and 
the  self-employed,  which  often  lack  the  means  and  capacities  to  address  cyber  risks  by 
themselves,  a  higher  resilience  against  phishing,  and  greater  trust  of  citizens  and  businesses  in 
online  services  thanks  to  a  registry  of  validated  websites.  This  is  expected  to  also  sustain  and 
further  improve  the  take-up  of  digital  public  services  by  citizens.  Incident-handling  of  cyber-
attacks on IT infrastructure and systems of government services, private businesses and citizens, 
as well as attribution capabilities of such cyber-attacks will be enhanced thanks to investments in 
cyber  security  capacities  of  the  Ministry  of  Defense  to  perform  these  services,  in  close 

74 

 
 
cooperation  with  the  Belgian  Centre  for  Cybersecurity  and  the  federal  police  Computer 
Emergency Response Team CERT. The Ministry of Defense is the Belgian administration’s hub 
of cybersecurity specialists where investigative cybersecurity activities are centralised. The RRF 
funding  will  not  be  used  for  any  military  operation.  This  measure  will  increase  Belgium’s 
preparedness  and response capacity to manage cyberattacks, including on critical infrastructure 
for the delivery of public services, contributing to Belgium’s overall economic and institutional 
resilience.  Investments  also  increase  cybersecurity  handling  capabilities  of  the  Ministry  of 
External  Affairs,  as  well  as  of  the  police  to  ensure  that  private  communication  interception 
operations can be continued in a 5G environment and such intercepted communications can be 
registered and shared with prosecutors in a digital format. The latter measures thus support the 
digitalisation  and  a  higher  effectiveness  of  a  part  of  the  criminal  justice  system,  thereby 
contributing to the overall objective of improving the level of digitalisation of the justice system. 
All investments are in line with the EU’s Cybersecurity Strategy for the Digital Decade. 

The plan also promotes the deployment of a human-centric use of AI. The plan contributes to 
the  financing  of  a  new  AI  Institute  for  the  Common  Good  in  Brussels  that  is  to  promote  the 
human-centric  use  of  AI  to  tackle  societal  challenges  in  areas  including  health,  environment, 
mobility and energy (components 2.3 and 4.3). The institute will deliver a range of AI services, 
including to local authorities in policy areas of European relevance covered by the six pillars of 
the Recovery and Resilience Facility. 

The  plan  includes  some  measures  that  aim  to  green  the  digital  sector.  Component  4.2 
contains  reforms  and  investments  in  Flanders  to  allow  citizens  to  borrow  digital  devices, 
boosting a more circular use of ICT devices, and encouraging repairing and recycling activities 
in  this  way.  The  support  of  the  Flemish  region  for  the  planned  micro-electronics  IPCEI  in 
component 5.2 is expected to contribute to addressing energy-efficiency of this sector. 

The  plan  does  not  include  a  security  self-assessment  for  investments  in  digital  capacities 
and connectivity. The relevant  connectivity investments  included in  the plan only concern the 
rollout of passive infrastructure and do not involve the deployment of public 5G networks. 

Conclusion 

Taking into consideration the assessment of all the measures  envisaged, the recovery and 
resilience plan is expected, to a large extent, to make a significant contribution to the digital 
transition or to address the challenges resulting from it and ensures that at least 20% of its total 
allocation  contribute  to  support  digital  objectives.  This  would  warrant  a  rating  of  A  under 
criterion 2.5 of Annex V to the RRF Regulation. 

4.7. Lasting impact of the plan  

The  proposed  reforms  and  investments  are  expected  to  have  a  lasting  positive  impact  on 
the  Belgian  economy  and  society.  The  recovery  and  resilience  plan  includes  a  package  of 
measures  aimed  at  addressing  challenges  identified  in  the  context  of  the  European  Semester, 
facilitating the green and digital transitions and strengthening the growth potential, job creation 
and economic and social resilience of Belgium. The measures presented in this respect comprise 

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structural  changes  to  the  administration  or  relevant  institutions  and  policies.  However,  more 
ambitious  reforms  and  a  reinforced  coherence  of  the  plan  between  investments  and  reforms 
could  have  led  to  a  greater  impact.  The  lasting  impact  of  the  plan  is  therefore  expected  to  be 
overall positive to a large extent. 

Structural change in administration and institutions 

The  plan  aims  to  introduce  a  number  of  structural  changes  in  the  country’s  public 
administration  or  related  institutions.  This  is  notably  the  case  for  spending  reviews 
(component  6.1),  education  (component  4.1),  R&D  (component  5.2),  active  labour  market 
policies (component 5.1) and digitalisation  of public administration as  well as promoting open 
access  to  government  data  (component  2.2).  The  measures  in  the  digital  axis  of  the  plan  are 
designed  to  increase  the  level  of  digitalisation  of  relevant  institutions,  and  this  is  expected  to 
have a lasting impact on the quality of services, the business environment and the optimal use of 
government  data.  This  concerns,  for  example,  the  justice  system,  social  security,  the  health 
system  or  platforms  to  improve  interactions  between  public  administrations  and  citizens  or 
businesses. 

Through spending reviews (component 6.1), the plan seeks to improve the quality and the 
composition  of  public  finances  in  Belgium.  By  offering  a  better  understanding  of  the  way 
public  resources  are  and  should  be  spent,  spending  reviews  will  help  strengthen  expenditure 
control,  cost  efficiency  and  appropriate  budgeting,  which  will  facilitate  rechanneling  of  public 
resources to strategic priorities prone to foster growth or long-term sustainability, including from 
an  environmental  point  of  view.  Spending  reviews  will  be  broadly  applied,  as  they  will  be 
implemented at all levels of government (federal and regional/community governments) and will 
also cover the social security system. The plan aims at creating political support, strengthening 
administrative capacities to perform the reviews, producing high quality reporting and ensuring 
the follow-up of recommendations. Comparative analysis will also be used to assess if political 
priorities  are reflected in the spending  and if these priorities are  executed in  the most efficient 
way.  Spending  reviews  are  planned  to  become  a  permanent  feature  of  Belgium’s  budgetary 
process. 

The  plan  sets  Belgium  on  a  firm  path  towards  digitalisation,  with  the  goal  to  reduce  the 
digital divide. A significant  build-up of public administration’s digital  capacity paves the way 
for  a  reduction  in  the  complexity  of  administrative  processes  and  procedures,  making  public 
administration more effective in the long term. In addition, this could lead to an increased take-
up  of  digital  public  services  by  citizens  and  businesses.  The  component  on  cybersecurity  will 
improve the resilience and crisis preparedness of institutions against cybersecurity risks. 

Open  use  of  government  data  could  contribute  to  higher  quality  legislation.  The  plan 
includes  investments  in  the  use  of  large  open  databases  collecting  the  data  available  across 
different public administrations. This will contribute to better use of these data, and can lead to 
better informed policy-making and higher-quality legislation. In addition, the plan includes some 
measures to mainstream equality considerations in policy-making.  

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The  plan  will  also  contribute  to  improving  the  performance  of  the  education  system  in 
Belgium (component 4.1), with potential long-term benefits notably on skills and productivity. 
The  plan  aims  at  strengthening  efforts  to  promote  the  acquisition  of  STEM,  digital  and  21st 
century skills in order to respond more adequately to labour market needs. It will also contribute 
to  the  digitalisation  of  education  and  the  upgrade  of  the  IT  equipment  in  schools  and  higher 
education  institutions.  Renovation  of  school  and  university  infrastructure  (component  1.1)  will 
provide 21st century buildings which are essential for high quality education. 

The component dedicated to social infrastructure (component 4.3) is  expected to improve 
the supply of childcare and social housing. It will create new affordable housing units in order 
to  address  the  exclusion  of  vulnerable  population  in  big  cities.  The  creation  of  new  places  in 
childcare  facilities,  in  particular  in  regions  with  a  high  share  of  vulnerable  households,  is 
expected  to  improve  the  activity  rate  as  care  responsibilities  are  one  of  the  obstacles  to 
employment for a part of the population. 

Structural changes in policies 

The  reforms  proposed  in  the  recovery  and  resilience  plan  are  expected  to  have  a  lasting 
impact,  although  in  some  cases  the  extent  of  the  impact  will  depend  on  their  further 
specification.  In  some  cases,  the  details  of  implementation  are  still  to  be  defined,  making  it 
difficult  to  anticipate  their  effects.  This  is  the  case  for  example  for  the  reform  of  the  pension 
system.  The  overall  direction  of  the  pension  reform  is  appropriate  as  is  its  twin  ambition  to 
improve adequacy and social fairness as well as long-term financial sustainability. With respect 
to the latter dimension, the focus on increasing labour market participation, and in particular of 
older workers is also appropriate given the low labour participation rate in the country. However, 
the  description  of  the  reform  is  not  sufficiently  precise  at  this  stage  to  forecast  its  effects  on 
pension expenditures. In the area of taxation, the reform of the company car scheme is expected 
to  contribute  to  the  decarbonisation  of  transport.  The  lack  of  commitment  to  reform  the  tax 
system limits the long-lasting effects which could have been achieved by removing disincentives 
to work on a permanent basis and by shifting taxes towards energy products in order to provide 
appropriate price signals. 

The plan is expected to have a lasting impact notably as structural changes in policies are 
envisaged. Many of these changes refer to the upscaling of the energy model for the transition to 
carbon neutrality. The transition is an opportunity to leverage the national economy in regard to 
sustainable  development  by  promoting  technological  advancement,  job  creation  and  the 
preservation  of  natural  resources.  This  entails  investments  and  measures  related  to  the  energy 
efficiency  of  buildings,  the  deployment  of  new  technologies  for  green  hydrogen,  the 
decarbonisation  of  industry  (with  the  development  of  carbon  capture,  utilisation  and  storage 
technologies),  the  reduction  of  energy  dependency,  or  sustainable  mobility.  However,  it  is 
uncertain how far the announced proposal for a broad tax reform will include measures to green 
the tax system and contribute to discourage the use of fossil fuels. To generate such effect, the 
reform would need to reinforce price signals in the non-ETS sectors, fostering environmentally 
friendly  production  and  consumption  patterns  and  providing  greater  incentives  to  invest  in 

77 

 
 
energy  saving  and  emissions  reduction,  and  be  accompanied  by  targeted  measures  to  alleviate 
energy poverty. 

Long term macroeconomic impact 

The assessment of the plan with the macroeconomic model QUEST (a dynamic stochastic 
general equilibrium model) by the Federal  Planning Bureau points to a long-term impact 
of the plan.  This  model takes  in account  the  effect  on the increase of the stock of capital  and 
R&D, which will increase productivity and competitiveness. The model estimates an impact on 
GDP of 0.22 pp in 2030 and of 0.14 pp in 2040 compared to the baseline scenario without RRF 
support. According to the same simulation by the Federal Planning Bureau, the plan is expected 
to contribute to the creation of a moderate additional number of jobs in 2030 and the increase in 
productivity is expected to result in an increase in wages. As noted above, these estimates do not 
factor in the impact of the reforms included in the plan. 

Conclusion 

Taking  into  consideration  all  the  reforms  and  investments  envisaged  by  Belgium  in  its 
recovery  and  resilience  plan,  their  implementation  is  expected,  to  a  large  extent  to  bring 
about  a  structural  change  in  the  administration  or  in  relevant  institutions  and  in  relevant 
policies  and  to  have  a  lasting  impact.  This  would  warrant  a  rating  of  A  under  criterion  2.7  of 
Annex V to the RRF Regulation. 

4.8. Milestones, targets, monitoring and implementation  

Monitoring of the implementation of the plan’s milestones and targets is to be carried out 
both  at  inter-federal  level  and  at  the  level  of  each  entity  in  charge  of  implementing  the 
measures of the plan, taken separately. The Secretary of State for the Recovery and Strategic 
Investments is responsible for coordinating the implementation of the plan at inter-federal level. 
Taken into account the broad scope of measures included in the plan, for which the competences 
are  spread  over  six  entities,  the  inter-federal  coordinator  has  an  important  responsibility  in 
monitoring a coherent implementation of the plan. The Secretary of State for the Recovery and 
Strategic  Investments  will  remain  the  technical  contact  point  for  the  Commission  in  the 
implementation of the recovery and resilience plan. 

Adequacy  of  the  structure  tasked  with  the  implementation  of  the  plan,  monitoring  of  progress 
and reporting 

The administrative follow-up of the plan will be carried out by an inter-federal Monitoring 
Committee. The Committee will be composed of representatives of all the entities  responsible 
for reporting and administrative follow-up of projects under their responsibility. The Committee 
will be chaired by the Permanent Secretary of the Federal Public Service BOSA. The secretariat 
of the Monitoring Committee will ensure continuity of the overall coordination of the plan and 
technical  contacts  with  the  Commission,  in  collaboration  with  the  Secretary  of  State  for 
the 
Recovery  and  Strategic 
implementation  and  achievements  of  the  plan,  coordinate  the  preparation  of  each  payment 

Investments.  The  Monitoring  Committee  will  monitor 

78 

 
 
request,  identify  risks  of  not  meeting  milestones  and  target  and  propose  solutions  if  risks 
materialise. 

An  Inter-ministerial  Conference  on  strategy  recovery  and  investment  will  approve  the 
payment  plan  and  all  requests  for  payments.  The  Inter-ministerial  Conference  for  Strategic 
Investments set up by a decision of the Consultation Committee of 7 November 2018 within the 
framework  of  the  National  Pact  for  Strategic  Investments,  will  be  renamed  as  ‘Recovery  and 
Strategic  Investments’  and  mobilised  for  the  implementation  of  the  plan.  The  Conference  is 
chaired by the Federal Government (State Secretary for Recovery and Strategic Investments) and 
is composed of representatives of the Federal State, the Regions and the Communities. The cover 
management  declaration  accompanying  each  national  payment  request  will  be  signed  by  the 
Secretary  of  State  for  Recovery  and  Strategic  Investments.  These  documents  will  be 
accompanied  by  a  management  declaration  drawn  up  by  each  of  the  entities.  Each  of  these 
declarations shall include a summary of the audits carried out in each entity and shall be signed 
by the competent authority. 

Each  entity  will  monitor  progress  of  investment  and  reform  projects  under  the  recovery 
and resilience plan.  Each government  level  will  set  up a central  coordination  unit responsible 
for  horizontal  monitoring  and  coordination  of  the  measures  under  its  responsibility.  The 
regional/community  central  coordination  levels  will  ensure  the  monitoring  and  reporting  in  a 
digital monitoring tool which will allow the inter-federal Monitoring Committee to follow-up on 
the implementation of the plan. 

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Milestones, targets and indicators 

The  milestones  and  targets  of  the  Belgian  plan  constitute  an  appropriate  system  for 
monitoring  the  plan’s  implementation.  The  monitoring  indicators  are  in  general  sufficiently 
clear  and  comprehensive  to  ensure  that  their  completion  can  be  traced  and  verified.  The 
milestones and targets chosen represent mostly the key elements of the measures and as such can 
be  considered  relevant  for  their  implementation.  They  reflect  adequately  the  overall  level  of 
ambition  of  the  plan  and  appear  realistic.  The  verification  mechanisms,  data  collection  and 
responsibilities  described  by  the  Belgian  authorities  appear  sufficiently  robust  to  justify  in  an 
adequate manner the disbursement requests once the milestones and targets are fulfilled. 

in  the 

Belgium also provided a broad range of detailed indicators, which will be used to monitor 
informally  progress 
individual  measures  between  the 
disbursement  requests.  These  indicators  provide  an  adequate  early  warning  system  to  ensure 
that Belgium can take corrective actions in time if necessary to avoid missing the objective set up 
in the relevant milestone/target. In addition, milestones and targets comprehensively cover sub-
investments so that all of the plan’s measures can be monitored. 

implementation  of 

Overall organisational arrangements 

The overall organisational arrangements for the implementation of the plan are clear and 
credible. Section 4 of the plan explains the inter-federal coordination mechanisms that have been 
established  to  monitor  and  implement  the  plan  next  to  a  detailed  overview  at  individual  entity 
level. 

Conclusion 

The arrangements proposed by Belgium in its recovery and resilience plan are expected to 
be  adequate  to  ensure  effective  monitoring  and  implementation  of  the  recovery  and 
resilience  plan,  including  the  envisaged  timetable,  milestones  and  targets,  and  the  related 
indicators. This would warrant a rating of A under the assessment criterion 2.8 of Annex V to the 
RRF Regulation. 

4.9. Costing 

The reforms and investments included in the plan comply with the eligibility criteria set out 
in  the  Regulation.  All  measures  are  set  to  be  implemented  and  generate  costs  only  after  1 
February  2020,  the  cut-off  date  for  eligible  costs.  According  to  the  planned  milestones  and 
targets and associated payments requests, no funding is planned to be requested after 31 August 
2026,  which  is  the  cut-off  date  for  eligible  funding  requests.  The  plan  generally  contains  a 
detailed  calculation  of  the  costs  showing  that  value-added  tax  (VAT)  has  not  been  included. 
Finally, the plan does not cover recurring costs, except in duly justified cases. 

Reasonable costs 

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Belgium  has  provided  individual  estimated  costs  for  all  investments  in  the  recovery  and 
resilience plan as well as for the reforms associated with costs, and the cost breakdown is 
generally relatively well detailed and substantiated. The estimates are for the most part based 
on  unit  costs  estimated  on  the  basis  of  comparisons  with  previous  procurement  contracts  for 
similar services or past investments of similar nature or based on actual offers. 

The  assessment  of  the  cost  estimates  and  supporting  documents  shows  that  for  the  vast 
majority  of  the  projects  the  costs  appear  to  be  reasonable.  For  the  most  part,  there  is 
sufficiently  detailed  information  and  evidence  that  the  estimated  total  cost  of  recovery  and 
resilience plan is reasonable as the calculations were clearly spelt out, and it is possible to clearly 
identify  the  methodology  and  underlying  assumptions  used.  Previous  projects  or  procurement 
contracts linked to the proposed investments are often presented to serve as a benchmark and to 
justify the unit cost estimates. 

In  some  cases,  the  costing  information  provided  is  not  satisfying.  For  some  investment 
projects the information provided is not sufficient to clearly justify the cost estimate. For a small 
subset  of  projects,  basic  description  of  the  calculations  underlying  the  costing  estimate  is 
missing. 

Plausible costs 

For most projects, Belgium provided sufficient information and comprehensive supporting 
evidence  that  the  amounts  proposed  are  in  line  with  the  nature  and  type  of  envisaged 
reforms  and  investments  (plausible).  In  most  cases,  Belgium  provided  information  either  on 
actual or similar past investment projects, or on comparative cost data for the main costs drivers 
that allow substantiating most cost estimates. For most projects the costing information includes 
clear supporting evidence or/and relevant references justifying reference unit costs. 

Clear  supporting  evidence  provided  is  incomplete  for  various  projects.  For  several 
investments, clear explanations were missing as to how the past similar projects presented as the 
basis for the estimates were used or adjusted to provide for the cost estimates presented. Without 
these explanations, it is difficult to verify how some of the documentation provided fits into the 
cost breakdown by category. In addition, for several investments,  the cost estimates though not 
implausible, are rather high compared to costs for similar projects having obtained EU funding in 
the past or referred to in studies. 

No double EU financing 

While the Commission has not identified cases where a high risk of double funding exists, the 
individual costing fiches for each component do not consistently provide clear information about 
additional investments from other EU funds. However, this is compensated by governance and 
control  systems,  as  described  in  the  following  section.  On  this  basis,  Belgium  is  considered  to 
have provided sufficient information and evidence that the amount of the estimated total cost of 
the recovery and resilience plan to be financed under the Facility is not covered by existing or 
planned Union financing. 

Commensurate and cost-efficient costs 

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The  recovery  and  resilience  plan  is  expected  to  help  address  challenges  identified  in  the 
country-specific  recommendations,  including  some  of  the  fiscal  aspects  of  the  country-
specific  recommendations.  Furthermore,  the  reforms  and  investments  in  the  plan  are  aligned 
with the European ‘flagship initiatives’ of the 2021 Annual Sustainable Growth Strategy. 

Moreover, the recovery and resilience plan contains measures to support economic growth 
and  economic  cohesion  in  an  inclusive  manner.  This  refers  in  particular,  to  addressing 
weaknesses of the Belgian economy, boosting the growth potential, stimulating job creation, and 
mitigating the adverse effects of the crisis. Several of these measures also contribute effectively 
to the implementation of the European Pillar of Social Rights, including through the promotion 
of policies for children and youth. 

Conclusion 

The  justification  Belgium  provided  on  the  amount  of  the  estimated  total  costs  of  the 
recovery and resilience plan is, to a medium extent, reasonable, plausible, in line with the 
principle of cost-efficiency and commensurate to the expected national economic and social 
impact. Belgium provided sufficient information and evidence that the amount of the estimated 
cost of the reforms and investments of the recovery and resilience plan to be financed under the 
Facility is not covered by existing or planned Union financing. This would warrant a rating of B 
under the assessment criterion 2.9 of Annex V to the RRF Regulation. 

4.10. 

Controls and audit  

Robustness of internal control system and distribution of roles and responsibilities 

The  Belgian  plan  adequately  describes  the  system  for  the  implementation  of  the  RRF  in 
Belgium.  The  plan  specifies  in  detail  the  internal  control  system  and  distribution  of  roles  and 
responsibilities 

At the inter-federal level 

The  Secretary  of  State  for  Recovery  and  Strategic  Investments  coordinates  the 
implementation  of  the  plan,  while  the  monitoring  is  performed  at  political  level  by  the 
Inter-ministerial  Conference  and  at  administrative  level  by  the  Inter-federal  Monitoring 
Committee. According to the plan, the Inter-ministerial Conference is chaired by the Secretary 
of  State  for  Recovery  and  Strategic  Investments,  and  is  composed  of  representatives  of  the 
Federal  State,  the  Regions  and  the  Communities.  The  Inter-federal  Monitoring  Committee  is 
chaired by the Permanent secretary (SPF BOSA - Service Public Federal Stratégie et Appui) and 
formed by representatives of all the entities responsible for the reporting and the administrative 
follow-up of the projects under their responsibility. Its permanent secretariat is hosted by the SPF 
BOSA, and in collaboration with the Secretary of State for Recovery and Strategic Investments, 
is  responsible  for  ensuring  the  continuity  of  the  Plan  coordination  and  the  contacts  with  the 
European Commission. 

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An  inter-federal  monitoring  tool  is  being  developed  for  the  plan,  as  well  as  common 
principles  for  audits  carried  out  in  each  entity.  The  Inter-federal  Monitoring  Committee  is 
also  responsible for the  aggregation of the data in a computerised monitoring tool. To develop 
the  monitoring  tool  for  the  Belgian  plan,  the  Belgian  authorities  have  launched  a  public 
procurement in March 2021. According to the information provided, the contract is expected to 
be awarded in June 2021 and a functional version of the monitoring tool is expected to be ready 
by the end of June 2021.With regard to the audit at the inter-federal level, the Belgian authorities 
have informed that “while the responsibilities in terms of audit fall under each entity's remit, a 
coordination is taking place within the Inspectorate of Finance to define common principles that 
would  be  followed  by  each  audit  authority,  in  parallel  with  specificities  in  their  own  audit 
strategy”. The audit authorities for the implementation of the Facility in Belgium, have agreed to 
set up a Belgian Recovery and Resilience Facility Audit Authority Committee. “This Committee 
will be chaired by the Head of the Finance Inspectorate ad interim, will not issue any binding 
instructions to its members but will seek, as far as possible, to harmonise methods. Each member 
of  the Committee may propose topics to  be included on the agenda of  subsequent  meetings.  In 
other words, it will be a forum to facilitate exchanges of good practice between audit authorities 
the development of proportionate methodologies and the resolution of any difficulties, drawing 
on the experience and expertise of each of its Finance Inspectors.” 

At the level of each entity 

The  Belgian  plan  identifies  the  different  bodies  in  charge  of  the  implementation, 
monitoring  and  control  of  the  projects  in  each  of  the  six  entities  (Federal  State,  Flemish 
Region,  Walloon  Region,  Brussels-Capital  Region,  French  Community  and  German-speaking 
Community).  Each  entity  is  responsible  for  collecting  the  data  of  the  projects  under  their 
responsibility, and ensure the regular update of their progress in their monitoring tools. However, 
the monitoring tools for  the Inter-federal Monitoring Committee, the Federal State, and for the 
French Community are being developed.  

The Belgian plan contains a general description of the audit purposes and approach. Two 
entities  are  appointed  as  Audit  Authorities,  Vlaamse  Auditautoriteit  (VAA)  for  the  Flemish 
Region, and Corps Interfédéral de l’Inspection des Finances (CAIF) for the Federal State and the 
remaining  regions  and  communities  (Brussels  Capital  Region,  Walloon  Region,  French 
Community and German-speaking Community). Both entities are also in charge of the audit of 
shared-management  EU  funds  and  are  independent  from  the  entities  implementing  the  RRF  in 
Belgium.  The  plan  specifies  that  the  assurance  model  is  based  on  the  combination  of  system 
audits and audits of operations, without detailing the frequency and the scope of the audit work 
to  be  performed.  However,  the  Belgian  authorities  have  subsequently  presented  the  audit 
strategies  for  the  Federal  State  Audit  Authority,  the  Flemish  Audit  Authority,  the  Walloon 
Region, the Brussels Capital Region, the French Community Audit Authority and the German-
speaking Community Audit Authority. 

Adequacy of control systems and other relevant arrangements 

83 

 
 
At  plan  level,  the  Belgian  authorities  have  detailed,  per  entity,  the  different  control 
procedures for the prevention, detection and correction of fraud, corruption and conflict of 
interest, which are considered adequate. The Belgian plan indicates the intention of all entities 
to use systemically the data-mining and risk scoring tool made available by the Commission. In 
the  Belgian  plan  and  in  the  additional  information  provided,  the  Belgian  authorities  have 
confirmed that all data required by Article 22(2) point (d) will be collected (i.e. not only at the 
level of the final recipient) and stored in the IT systems of the various entities implementing the 
RRF in Belgium. However, the development of the IT monitoring systems for the Inter-federal 
and  Federal  state,  and  for  the  French  Community  is  still  on-going.  In  order  to  provide  the 
Commission  with  reassurance  that  all  IT  systems  will  be  operational,  with  the  basic 
functionalities to track the milestones and targets, before the first payment request is made, and 
that, all categories of data required by the RRF Regulation will be collected, a milestone to that 
effect has been proposed to be included in the plan. For the reporting of serious irregularities, the 
Belgian authorities informed that these will be reported in  the Management  Declaration and to 
OLAF. 

Adequacy of arrangements to avoid double EU funding 

All the entities have defined their own procedures for avoiding EU double funding which 
are  described  in  the  Belgian  plan  and  in  the  additional  documentation  presented.  These 
measures  are  considered  adequate  and  include:  arrangements  at  the  final  recipient  level,  to  (i) 
submit a list with all the projects benefiting from other EU funding, (ii) keep for each project a 
clear trail of the different sources of funding, and (iii) a separate analytical accounting system per 
project or an accounting code identifying the costs and revenues covered by the co-financing. 

In  addition,  the  services  responsible  for  the  implementation  (Managing  Authorities),  audit  and 
control (Audit Authorities), are also in charge of the verifications of projects financed by other 
EU Funds, namely, ESF, ERDF, EAFRD and ETC, which allows them to have an overall view 
of the EU funding, and contributes to reduce the risk of double funding. 

Nonetheless,  as  each  entity  is  only  responsible  for  the  verification  at  their  level,  there  are  no 
cross-checks performed at the national level. The lack of coordination between the inter-federal 
level, the different entities and the different EU funds, increases the risk of double EU funding. 
An adequate milestone to deal with that issue has been included in the plan.  

Legal empowerment and administrative capacity of control function 

In  all  of  the  six  entities,  the  first  level  controls  (management  verifications)  have  been 
assigned to different public bodies that are part of the existing internal control framework 
for  the  implementation  of  the  budget  in  the  various  entities.  With  regard  to  the  audits,  the 
Belgian  plan  mentions  that  the  Flemish  Audit  Authority  (Vlaamse  Auditautoriteit)  has  been 
formally  designated  by  the  Flemish  government  on  26  February  2021,  and  that  the  Audit 
Authority for the remaining entities, Corps Inter-fédéral de l’Inspection des Finances (CAIF), is 
still to  be designated by a formal decision.  In the additional information  provided, the Belgian 
authorities have confirmed the legal mandate for all entities, following the approval decision of 
the Belgian plan by the Consultation Committee on 30 April 2021. Regarding the administrative 

84 

 
 
capacity, the Belgian authorities have confirmed the formal commitment of the governments to 
strengthen  the  administrative  capacity  of  the  Audit  Authorities.  For  the  Federal  Authority,  the 
Council  of  Ministers  has  instructed  the  Secretary  of  State  for  the  Budget  to  draw  up  control 
guidelines, and to assess the human/financial needs related to this system. Likewise, it instructed 
the  Inspectorate  of  Finance  (Federal  audit  unit  for  EU  funds)  to  devise  the  audit  strategy  and 
assess the human/financial needs related to it. 

Conclusion 

The chapter on audit and control  and the additional  information  provided gives a rather 
complete description of the arrangements for the implementation and control of the plan in 
Belgium. The chapter provides the details for all the entities and gives reasonable assurance that 
there is a sound structure in place to monitor, implement and control the allocated funds from the 
Facility. 

However, a couple of elements are missing and have been introduced as milestones: 

  For  the  inter-federal  coordinating  body,  the  Federal  authority  and  the  French  Community: 
implementation  before  the  first  payment  request  is  made  of  a  repository  system  for 
monitoring  the  implementation  of  the  RRF.  The  system  shall  include,  as  a  minimum,  the 
following  functionalities:  (a)  collection  of  data  and  monitoring  of  the  achievement  of 
milestones  and  targets;  (b)  collect,  store  and  ensure  access  to  the  data  required  by  Article 
22(2), point (d)(i) to (iii) of the RRF Regulation. A dedicated audit report on the system used 
shall  be  undertaken.  In  case  the  report  identifies  any  weaknesses,  the  audit  report  shall 
recommend  corrective  actions.  The  Belgian  authorities  should  ensure  the  greatest  possible 
compatibility with the monitoring tools developed at all levels of government. 

  The implementation  of adequate coordination arrangements, including  cross-checks,  should 
be put in place at the level of the coordinating body at inter-federal level allowing to avoid 
double  funding  from  the  Facility  and  other  Union  programmes  in  accordance  with  the 
principle of sound financial management. 

The  arrangements  proposed  by  Belgium  in  the  recovery  and  resilience  plan  to  prevent, 
detect  and  correct  corruption,  fraud  and  conflicts  of  interest  when  using  the  funds 
provided  under  the  Facility,  including  the  arrangements  aimed  to  avoid  double  funding 
from  the  Facility  and  other  Union  programmes,  are  assessed  to  be  adequate.  This  would 
warrant a rating of A under the assessment criterion 2.10 of Annex V to the RRF Regulation. 

4.11. 

Coherence 

The  Belgian  recovery  and  resilience  plan  displays  a  mostly  coherent  set  of  reforms  and 
investments. These support the objectives to stimulate the recovery of the Belgian economy, to 
contribute to its green and digital transition and to increase its resilience on the path towards a 
more  sustainable  and  inclusive  growth.  The  individual  measures  included  in  the  plan  are 
coherent  with  the overarching objectives announced. The plan does not  present  inconsistencies 

85 

 
 
 
or contradictions between the content of the different components. Moreover, due care was given 
to  ensure  that  implementation  timelines  of  reforms  and  investments  were  aligned  to  ensure 
successful delivery of the measures. 

Measures  within  components  are  mutually  reinforcing,  with  components  generally 
including a set of mostly balanced reforms and investments. Most components include a set 
of  reforms  that  accompany  the  investment,  facilitating  it,  making  plausible  and  increasing  its 
impact,  except  for  components  3.1  (cycling  and  walking)  and  component  2.1  (cybersecurity)37 
that  do  not  contain  reforms.  Component  6.1  (spending  reviews)  is  almost  exclusively  about 
reforms due to the nature of the topic that it covers. 

Overall, investment and reform measures within a component are reinforcing one another. 
In component 3.2, for example, the mobility budget is reinforced by the reform on the quality of 
railway  services,  including  the  commitment  to  complete  the  suburban  railway  services  around 
Brussels (RER/GEN). In component 3.3, the deployment of charging infrastructure supports the 
greening  of  the  company  car  scheme,  incentives  to  use  collective  transport  and  investments  in 
rail  and  urban  transport.  Finally,  in  component  1.2  measures  to  regulate  hydrogen  markets 
support the development of a hydrogen value chain. 

Many measures support and complement measures contained in other components related 
to the same policy area. For example, in component 3.2, the broadening of the mobility budget, 
the  construction  of  cycling  parking  areas  in  train  stations  and  the  integration  of  cycling  in 
Brussels’ mobility-as-a-service investment measure support the development of cycling paths in 
component 3.1. Component 2.1 contains investments that reinforce cybersecurity in 5G, whereas 
investments and reforms related to the latter are part of component 2.3. 

Investments in training and skills mutually reinforce investments across the whole plan as 
they  address  skills  shortages  and  translate  the  plan  in  job  opportunities.  Investments  in 
training and inclusion on the labour market included in components 4.2 and 5.1 aim at reducing 
skills shortages through training and activation in view of addressing current and future needs of 
the  labour  market.  While  aiming  at  covering  a  wide  range  of  skills,  including  basic  and  green 
skills,  investments  focus  strongly  on  increasing  digital  skills,  thereby  supporting  the  digital 
transition. 

Several  measures  of  the  plan  contribute  to  improving  the  business  environment  and 
support the translation of the various investments into concrete growth opportunities. The 
plan  contains  measures  in  component  1.2  to  support  the  emergence  of  a  hydrogen  value  chain 
and  in  component  5.2  to  support  several  sectors  (e.g.  aerospace).  Opening  of  public  data  in 
components  2.2  and  3.2  will  also  create  business  opportunities.  Component  2.2  contains 
measures to revise and simplify the whole procedure to set up and to manage a business and, as a 

37 
component, these are not qualified as specific measures being part of the plan. 

While  the  plan  does  contain  references  to  a  number  of  intended  reforms  in  the  description  of  this 

86 

 
 
                                                           
result, reduce the existing large number of forms to modify elements of an enterprise as well as 
to  apply  the  “Once-Only”  principle  also  to  businesses  and  citizens  from  other  Member  States 
(Single  Digital  Gateway).  Also  spending  reviews  in  Flanders  will  focus  on  reducing  the 
regulatory  burden,  including  to  address  ‘gold-plating’  which  results  in  an  unnecessary  strict 
implementation and enforcement of the rules. 

Measures  to  speed  up  the  delivery  of  environmental  and  building  permits  support  key 
investments in the green and digital transition. Measures to facilitate the granting of building 
and  environmental  permits  for  citizens  in  Brussels  (component  2.2)  and  Flanders  (component 
5.2) are essential to facilitate renovation investments thanks to the renovation subsidy schemes 
(component 1.2). Components 2.2, 2.3 and 5.2 contain reforms both at the federal and regional 
level that aim to remove regulatory bottlenecks for the deployment of 5G and for the deployment 
of  ultra-fast  connectivity  infrastructure,  such  as  fibre.  These  critical  reforms  are  expected  to 
enable  and  reinforce  the  ultra-fast  connectivity  public  investments  in  the  plan  set  out  in 
component 2.3 and also foster the necessary important private connectivity investments to ensure 
an effective digital transition. These include, for example, the coverage of fibre white areas and 
to test 5G technology applications in different business sectors. 

However,  the  plan  could  have  better  exploited  the  whole  potential  of  some  investments 
through  more  far-reaching  complementary  reforms.  For  example,  investments  in  education 
(e.g.  IT  infrastructure,  personalised  support  in  compulsory  education)  could  have  been 
complemented  by  reforms  enhancing  the  educational  benefits  of  such  investments  for  students 
such  as  reforms  in  initial  teacher  education  and  teachers’  professional  learning  development. 
Investments  in  training  facilities  in  Wallonia  could  have  been  complemented  by  a  reform  of 
vocational  education  and  training  in  cooperation  with  the  French  Community.  While  there  are 
measures included to enhance social and labour market inclusion, the plan falls short of setting 
out a holistic and comprehensive strategy targeting vulnerable groups. 

Moreover, the plan could have provided greater incentives to trigger private renovations in 
particular with a strong commitment to reform energy taxes on heating fuels with a view to 
sending the right price signals. An increase in excise duties on fossil fuels used for heating (oil 
and  gas)  would  have  increased  the  effectiveness  of  the  significant  investments  in  building 
renovation.  The  Belgian  Federal  Public  Service  Finance  recently  estimated  that  Belgium 
annually grants subsidies representing 2.8% of GDP to fossil fuel, of which more than a third is 
attributed to heating fuels38. The low excise duties on gas oil, set at the EU minimum level, were 
identified  as  a  major  cost  driver.  A  firm  commitment  to  reform  energy  taxes  in  line  with  the 
carbon and energy content of fuels could foster the most energy-efficient fuels and low-emission 
technologies,  and  would  provide  the  adequate  price  signal  to  incentivise  building  renovation. 
Finally,  further  developing  loan-based  financing  mechanisms  for  private  buildings  renovation 

38 
fossiles 

https://finances.belgium.be/fr/statistiques_et_analyses/analyses/inventaire-des-subventions-aux-energies-

87 

 
 
                                                           
and  encouraging  public-private  partnerships  for  public  buildings  renovation  still  holds  an 
important potential. 

Additionally, while there is complementarity of measures in the digital and mobility axes, 
there is room to improve the coherence of measures in the sustainability and productivity 
axes. The digital axis contains both connectivity investments and reforms removing critical 5G 
and  very  high  capacity  connectivity  bottlenecks  that  are  expected  to  benefit  all  aspects  of 
digitalisation.  The  cybersecurity  measures  contribute  to  the  resilience  of  the  investments  in 
digitalisation  of  public  administration  and  the  judiciary  in  this  axis.  In  mobility,  rail  and 
company  car  reforms  all  support  green  transport,  modal  shift  and  cycling.  In  the  sustainability 
axis,  measures  and  reforms  linked  to  hydrogen  and  CO2  capture  and  transport  are 
complementary;  however,  their  coherence  with  the  other  measures  of  the  sustainability  axis  is 
looser and measures aiming at improving sector coupling and energy efficiency have room to be 
further  integrated  with  the  other  measures  of  the  sustainability  axis  (including  with  the 
renovation  measures).  Despite  several  measures  aiming  at  a  higher  electrification  degree  and 
clean  hydrogen  production,  the  plan  envisages  rather  limited  measures  to  further  increase  the 
production  of  renewable  energy.  Similarly,  the  productivity  axis  is  composed  of  rather 
heterogeneous measures in training, circular economy, R&D and industrial support without clear 
synergies or complementarity. 

Many  reforms  and  investments  are  not  applied  uniformly  and  consistently  across  the 
country, which would be warranted. For example, reforms to reduce administrative burden are 
presented in  Flanders and Brussels,  but  not  in Wallonia. The plan foresees the development  of 
two  individual  learning  accounts  (one  at  the  federal  level  and  one  at  the  regional  level)  rather 
than creating one integrated account, which would increase the transparency towards citizens as 
regards  the  available  training  incentives.  The  Belgian  authorities  have,  however,  committed  to 
coordinating  in  the  implementation  of  these  measures.  In  order  to  promote  wider  coherence 
across  instruments,  notably  with  the  European  cohesion  policy  funds,  a  balanced  territorial 
allocation of resources is encouraged. 

Conclusion 

Taking  into  consideration  the  qualitative  assessment  of  all  components  of  Belgium’s 
recovery  and  resilience  plan,  their  individual  weight  (importance,  relevance,  financial 
allocation)  and  their  interactions,  the  plan  contains  measures  for  the  implementation  of 
reforms  and  public  investments  which,  to  a  medium  extent,  represent  coherent  actions. 
This  would  warrant  a  rating  of  B  under  the  assessment  criterion  2.11  of  Annex  V  to  the  RRF 
Regulation. 

88 

 
 
 
 
ANNEX: CLIMATE AND DIGITAL TAGGING 

Note: While the total cost of the Belgian recovery and resilience plan exceeds the total allocation of non-
repayable  financial  support  to  Belgium,  Belgium  will  ensure  that  all  spending  related  to  the  measures 
mentioned  in  this  table  as  contributing  to  climate  objectives  are  fully  financed  by  the  funds  from  the 
Recovery and Resilience Facility. 

Int. Field = intervention field 
Coeff. = Coefficient for the calculation of support to climate change objectives and to digital transition, 
on the basis of Annex VI and Annex VII of the RRF Regulation 

Measur
e/ Sub-
Measur
e ID 

R-1.01 

R-1.01 

R-1.02 

R-1.03 

I-1.01 

I-1.01 

I-1.02 

I-1.03 

I-1.04 

I-1.05 

 Measure/Sub-Measure Name 

Improved energy subsidy scheme of the 
Flemish Region (investment part) – smart 
control  
Improved energy subsidy scheme of the 
Flemish Region (investment part) – (except 
smart control)  
Improved energy subsidy scheme (investment 
part) – Brussels-Capital region  
Improved energy subsidy scheme (investment 
part) – German-speaking community  
Renovation of social housing of the Flemish 
Region - subsidies 
Renovation of social housing of the Flemish 
Region - loans 
Renovation of social housing of the Brussels-
Capital Region 
Renovation of social and residential housing 
of the German-speaking Community 
Renovation of the Palais de la Bourse – 
Federal State - energy efficiency measures   
Renovation of public buildings – Flemish 
Region 

I-1.07 

I-1.07 

I-1.06  Public building renovations – Walloon Region 
Public building renovations - Walloon Region 
– local authorities 
Public building renovations - Walloon Region 
- sport (energy efficiency related works)  
Public building renovations - Brussels-Capital 
region 
School renovation – Federation Wallonia-
Brussels - energy efficiency related  
construction and renovation works  
School renovation – Federation Wallonia-
Brussels - energy efficiency related works 

I-1.09 

I-1.09 

I-1.08 

 Budget 
(EUR m) 

Climate  

Digital  

Int. 
Field  

Coeff. 
%  

Int. 
Field  

Coeff. 
%  

20,35 

033 

100% 

033 

40% 

212,97 

025 
025ter 

40% 

16,00 

025 

40% 

5,00 

025bis 

100% 

30,00 

025bis 

100% 

5,00 

025 

40% 

43,44 

025bis 

100% 

20,00 

025bis 

100% 

6,32 

026bis 

100% 

20,00 

026 

40% 

59,54 

026bis 

100% 

73,00 

026bis 

100% 

55,18 

026 

40% 

32,00 

026bis 

100% 

71,66 

025ter 
026 

40% 

23,60 

026bis 

100% 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-1.11 

I-1.10 

achieving at least 30% average primary 
energy demand reduction (medium-deep) 
Public building renovations - sport & IPPJ - 
Federation Wallonia-Brussels - ADEPS et 
IPPJ (energy efficiency related works)  
Public building renovations - universities - 
Federation Wallonia-Brussels (share allowing 
at least 30% average primary energy demand 
reduction) 
Public building renovations - universities - 
Federation Wallonia-Brussels (energy 
efficiency related works) 
Public building renovations - culture - 
Federation Wallonia-Brussels (share allowing 
at least 30% average primary energy demand 
reduction) 
Public building renovations - culture - 
Federation Wallonia-Brussels (energy 
efficiency related works) 
I-1.13  Renovation of buildings - Renolab 

I-1.11 

I-1.12 

I-1.12 

I-1.14 

I-1.15 

I-1.16 

I-1.16 

I-1.16 

I-1.16 

I-1.16 

I-1.17 

I-1.18 

I-1.19 

I-1.20 

Backbone for H2 and CO2 of the Federal 
State 
An industrial value chain for hydrogen 
transition - Federal State 
An industrial value chain for hydrogen 
transition of the Flemish Region - R&D&I 
projects 
An industrial value chain for hydrogen 
transition of the Flemish Region - production 
from renewable energy 
An industrial value chain for hydrogen 
transition of the Flemish Region - 
transmission, distribution, storage and energy 
systems 
An industrial value chain for hydrogen 
transition of the Flemish Region - end user 
refuelling & transport 
An industrial value chain for hydrogen 
transition of the Flemish Region - end user 
industrial  
An industrial value chain for hydrogen 
transition’ of the Walloon Region – IPCEI 
and non IPCEI projects 
Developing the low-carbon industry of the 
Walloon Region –R&D&I projects 
Research platform for energy transition of the 
Walloon Region 
Renewable heat networks of the Flemish 
Region 

90 

21,07 

026bis 

100% 

15,00 

026bis 

100% 

25,00 

026 

40% 

20,68 

026bis 

100% 

18,64 

026 

40% 

13,43 

026 

40% 

95,00 

033 

100% 

033 

40% 

50,00 

022 

100% 

47,86 

022 

100% 

27,39 

032 

100% 

36,54 

033 

100% 

033 

40% 

8,07 

077 

100% 

5,15 

027 

100% 

117,20 

032 

100%  

50,00 

022 

100% 

26,44 

022 

100% 

44,30 

034bis0  100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
99,00 

033 

100% 

033 

40% 

I-1.21 

I-1.21 

I-1.22 

I-1.22 

I-1.23 

I-1.24 

Off-shore energy island of the Federal State - 
projects 
Off-shore energy island of the Federal State – 
biodiversity studies and impact assessment 
Biodiversity and adaptation to climate change 
of the Walloon Region – Forests & 
Remeandering 
Biodiversity and adaptation to climate change 
of the Walloon Region – Protected areas & 
National parks 
Ecological defragmentation of the Flemish 
Region 
Blue Deal of the Flemish Region (Projects A-
B-C-E-F-G-H-I) 

I-1.25  Blue Deal of the Flemish Region (Project D) 
Cybersecurity and resilient digital society of 
the Federal State 

I-2.01 

I-2.02  Cybersecurity of the Federal State - 5G 

I-2.03 

Cybersecurity of the Federal State: 
NTSU/CTIF interception and safeguard 
I-2.04  Digitalisation IPSS of the Federal State 

1,00 

049 

40% 

34,00 

035 
037 

100% 

50,00 

050 

40% 

050 

037 
022 
047 

40% 

100% 

40% 

24,70 

280,96 

10,00 

52,29 

8,26 

18,18 

60,00 

I-2.05  Digitalisation Federal administration services 

217,73 

I-2.06 

I-2.07 

I-2.08 

eHealth Services et Health Data of the Federal 
State 
Digitalisation of ONE of the French 
Community 
Digitalisation of the cultural and media sector 
of the French Community 

I-2.09  Digitalisation of the Flemish Government 

I-2.10 

I-2.11 

I-2.12 

I-2.13 

I-2.14 

I-2.14 

Regional data exchange platform of the 
Brussels-Capital Region 
Digitalisation of citizen-business processes of 
the Brussels-Capital Region 
Digitalisation of regional and local 
government of the Walloon Region 
Coverage of white areas by developing very 
high-speed fibre optic networks of the 
German-speaking Community 
Development of an AI institute in the 
Brussels-Capital Region - Digital skills 
development 
Development of an AI institute in the 
Brussels-Capital Region - Smart 
specialization skills development 

40,00 

31,41 

16,00 

120,56 

17,67 

33,14 

47,96 

19,50 

1,47 

8,44 

I-2.15  Improving (internal) connectivity of schools 

70,30 

91 

100% 

100% 

100% 

100% 

100% 

021qui
nquies 
021qui
nquies 
021qui
nquies 
011 
011 
012 
011quat
er 
027bis 

013 

100% 

011 

100% 

021bis 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

051 

100% 

108 

100% 

016 

40% 

053 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and business parks in the Walloon Region – 
Fibre connectivity of 35 business parks; 5G 
connectivity; Internal connectivity of schools; 
and Education 2.0 

009bis 
053 
011 

I-3.01  Cycling infrastructure of the Flemish Region 
Cycling infrastructure – Corridors Vélo of the 
Walloon Region 

I-3.02 

345,46 

075 

100% 

13,74 

075 

100% 

I-3.03  Cycling infrastructure – Vélo Plus  
I-3.04  Cycling infrastructure – Schuman  
I-3.06  Tram extension Liège  
I-3.07  Metro extension Charleroi 
I-3.08  Smart road signals – Walloon Region 

I-3.09 

I-3.09 

I-3.10 

I-3.10 

I-3.10 

I-3.11 

Accessible and multimodal train stations of 
the Federal State – urban stations  
Accessible and multimodal train stations of 
the Federal State – rural stations  
Rail renovation – efficient network of the 
Federal State (TEN-T and electric/zero 
emission) 
Rail renovation – efficient network of the 
Federal State (other rail renovation) 
Rail renovation – efficient network of the 
Federal State – automatisation of the Traffic 
Management System 
Canal Albert and Trilogiport of the Walloon 
Region 

34,10 

17,40 

105,00 

60,00 

26,64 

075 

075 

073 

073 

100% 

100% 

100% 

100% 

084bis 

40% 

084bis 

100% 

59,29 

073 

100% 

15,71 

079 

40% 

239,00 

26 

067 
068 
069bis 
066 
069 

100% 

40% 

10,00 

070 

40% 

070 

100% 

25,93 

079 
082bis 

40% 

I-3.12  Rail – Smart mobility of the Federal State 

15,00 

070 

40% 

070 

100% 

I-3.13 

I-3.14 

Mobility-as-a-Service (MaaS) deployment of 
the Brussels-Capital Region 
Modal shift grants of the Brussels-Capital 
Region 

5,65 

076bis 

40% 

076 

100% 

8,00 

048 

40% 

I-3.15  Smart move of the Brussels-Capital Region 

51,00 

I-3.16  Greening the bus fleet of the Flemish Region 

55,50 

063bis 
047 
077 

40% 

063bis 

100% 

100% 

I-3.17 

Greening the bus fleet of the Brussels-Capital 
Region 

I-3.18  Charging stations of the Federal State 

I-3.19  Charging stations of the Flemish Region 

55,00 

074 

100% 

32,00 

077 

100% 

29,46 

077 

100% 

I-4.01  Digisprong of the Flemish Community 

I-4.04 

I-4.05 

Digital strategy for higher education and adult 
learning of the French Community 
Digital turnaround for Brussels schools of the 
Brussels-Capital Region 

318,16 

32,00 

5,20 

92 

055 
108 
012 
011 

108 

100% 

100% 

012 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-4.06 

Digital transformation of education of the 
German-speaking community 

I-4.08  E-inclusion for Belgium of the Federal State 

I-4.09 

Digital platforms for prisoners of the Federal 
State 

I-4.11  Digibanks of the Flemish Region 

5,50 

30,00 

12,40 

50,00 

012 

100% 

012 

100% 

012 

100% 

012 

100% 

I-4.12 

I-4.12 

I-4.13 

I-4.13 

I-5.01 

I-5.02 

I-5.03 

I-5.04 

I-5.04 

Development of public utility housing and 
housing for vulnerable persons of the Walloon 
Region -Volets 1&2_Building 
Development of public utility housing and 
housing for vulnerable persons of the Walloon 
Region -Volet 4_Technologies 
Creation and renovation of early childcare 
infrastructure of the Walloon Region – 
construction & renovation 
Creation and renovation of early childcare 
infrastructure of the Walloon Region – 
Software for managing immovable property 
A6K/E6K Digital and Technological 
Innovation and Training Hub of the Walloon 
Region 
EU Biotech School and Health Hub of the 
Walloon Region 
Upgrading of advanced training infrastructure 
of the Walloon Region 
Learning and career offensive —Flemish 
Community - support to social economy 
Learning and career offensive – Flemish 
Community – On-line training offer  

I-5.06  Digital skills of the Flemish region 

I-5.07 

Digital lifelong learning of the Walloon 
Region 

I-5.08  Nuclear medicine of the Federal State 

I-5.09 

I-5.09 

I-5.10 

I-5.11 

I-5.11 

Call for proposals in support of R&D of the 
Federal State - R&D support of the 
aeronautics sector 
Call for proposals in support of R&D of the 
Federal State - R&D support of the space 
sector  
R&D: Minimization of waste during 
dismantling of the Federal State 
Strengthen R&D of the Flemish Region - 
R&D&I projects and strengthening industrial 
research fund 
Strengthen R&D of the Flemish Region - 
Bioeconomy impulse program and scientific 
and technological infrastructure 

93 

120,80 

025ter 

40% 

15,00 

013 

100% 

61,00 

025ter 
026 

40% 

0,42 

011 

100% 

86,80 

025ter 
026 

40% 

24,80 

025ter 

40% 

46,25 

025ter 

40% 

12,00 

18,26 

43,21 

26,80 

25,00 

044 

40% 

25,00 

024 

40% 

016 

40% 

012 

100% 

012 

100% 

012 

100% 

10,00 

009bis 

100% 

25,00 

044 

40% 

42,00 

018 
021 

40% 

120,00 

023 

40% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-5.11 

I-5.11 

I-5.12 

Strengthen R&D of the Flemish Region - 
Impulse program value chain microelectronics 
Strengthen R&D of the Flemish Region - 
Business Projects ETS Innovation Fund & 
CCS-CCU 
Relocation of food and development of 
logistics platforms of the Walloon Region 

I-5.13  Digitalisation of the Walloon touristic sector 

I-5.14  Recycling Hub of the Flemish Region 

I-5.15 

Belgium Builds Back Circular of the Federal 
State 

I-5.16 

I-5.17 

Deployment of the circular economy’ in the 
Walloon Region 
Circular economy & circular construction of 
the Flemish Region 

20,00 

021quat
er 

100% 

011 

100% 

10,00 

022 

100% 

61,00 

047 

40% 

3,29 

30,00 

28,97 

85,00 

044 

023 
047 

023 
044 

40% 

40% 

40% 

25,00 

047 

40% 

94 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REFERENCES 

Almeida,  V.,  Barrios,  S.,  Christl,  M.,  De  Poli,  S.,  Tumino,  A.,  Van  der  Wielen,  W.  (2020): 
“Households´  income  and  the  cushioning  effect  of  fiscal  policy  measures  during  the  Great 
Lockdown”, JRC Working Paper on Taxation and Structural Reforms, 06/2020. 

Agoria, 2020, White paper: 'Be The Change' (agoria.be). 

Bauer, P., Fedotenkov, I., Genty, A., Hallak, I., Harasztosi, P., Martinez Turegano, D., Nguyen, 
D.,  Preziosi,  N.,  Rincon-Aznar,  A.  and  Sanchez  Martinez,  M.,  Productivity  in  Europe:  Trends 
and drivers in a service-based economy, JRC, 2020. 

Christl, M., De Poli, S., Figari, F., Hufkens, T., Leventi, C., Papini, A.  and Tumino, A. (2021) 
“The  cushioning  effect  of  fiscal  policy  in  the  EU  during  the  COVID-19  pandemic”,  JRC 
Working Papers on Taxation and Structural Reforms, 02/2021 (forthcoming). 

Van  Essen,  H.,  Schroten,  A.,  Otten,  M.,  Sutter, D.,  Schreyer,  C.,  Zandonella,  R.,  Maibach,  M. 
and Doll, C. (2011), External Costs of Transport in Europe, CE Delft. 

Marques Santos, A.; Haegeman, K.; Moncada-Paternó-Castello, P. (2021). “Impact of Covid-19 
and  earlier  crises  on  firms’  innovation  and  growth:  a  comparative  analysis”,  JRC  Working 
Papers  on  Territorial  Modelling  and  Analysis  (forthcoming).National  Bank  of  Belgium,  2017, 
Economic Review, September 2017. 

National Bank of Belgium, 2021a, Liquidité et solvabilité des entreprises Belges face à la crise 
du  COVID-19:  une  évaluation  après  la  première  vague,  June  2021  Economic  Review, 
forthcoming. 

National  Bank  of  Belgium,  2021b,  Economic  projections  for  Belgium  –  Spring  2021,  Revue 
Economique, June 2021.  

European Commission 2020, Commission SWD (2020) 926 final of 14.10.2021, Assessment of 
the final national energy and climate plan of Belgium.  

European 
https://ec.europa.eu/info/sites/info/files/economy-finance/ip143_en.pdf. 

Commission, 

2021, 

2020 

Debt 

Sustainability 

Monitor, 

European Commission, 2021b, Ageing Report, available at : The 2021 Ageing Report: Economic 
and  Budgetary  Projections  for  the  EU  Member  States  (2019-2070)  |  European  Commission 
(europa.eu). 

Dumont,  M.,  2021,  Business  dynamism  and  productivity  growth  in  Belgium,  Federal  Planning 
at: 
available 
Paper 
Bureau, 
https://www.plan.be/uploaded/documents/202105270757390.WP_2105_12427.pdf. 

Working 

5/2021, 

Varga,  J,  in  't  Veld  J.  (2014),  “The  potential  growth  impact  of  structural  reforms  in  the  EU:  a 
541. 
benchmarking 
http://ec.europa.eu/economy_finance/publications/economic_paper/2014/pdf/ecp541_en.pdf. 

Economic 

exercise", 

Economy 

European 

Papers 

no. 

95 

 
 
Chantal Kegels, 2018, "Les charges administratives en Belgique pour l'année 2016", Planning 
paper 116-18, Federal Planning Bureau, Belgium. 

DESI 2020, Digital Scoreboard - Data & Indicators (digital-agenda-data.eu), Eurostat, 
Government benchmark - 2020 

Federal Planning Bureau, 2021, Macroeconomic and fiscal effects of the draft National Recovery 
and Resilience Plan  -  Report to  the Secretary of  State for Recovery  and Strategic  Investments, 
at: 
REPORT 
https://www.plan.be/uploaded/documents/202104301033290.FPB_RRP_Economic_impact_124
01_E.pdf. 

(C1.001/D1.001), 

available 

12401 

2018 OECD Teaching and Learning International Survey. 

96