COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Sweden Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Sweden
Date: 2022-03-29
Institutions: European Commission, Secretariat-General
Subjects: EU aid, Sweden, coronavirus disease, economic and social cohesion, economic recovery, economic reform, epidemic, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.3.2022  SWD(2022) 102 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Sweden Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Sweden {COM(2022) 152 final}  
 
 
Table of contents 
1.  Executive summary ......................................................................................................................... 2 

2.  Recovery and resilience challenges: scene-setter .......................................................................... 4 

2.1.  Macroeconomic outlook and developments since the 2020 country report ......................... 4 

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

2.2. 
generation ........................................................................................................................................... 8 

2.3. 

Challenges related to the green and digital transition ........................................................... 9 

2.3.1. 

Green dimension ............................................................................................................. 9 

2.3.2. 

Digital dimension .......................................................................................................... 12 

3.  Objectives, structure and governance of the plan ........................................................................ 16 

3.1.  Overall strategy of the plan .................................................................................................. 16 

3.2. 

Implementation aspects of the plan ..................................................................................... 17 

4. 

Summary of the assessment of the plan ....................................................................................... 20 

4.1. 

Comprehensive and adequately balanced response to the economic and social situation  20 

4.2. 

Link with country-specific recommendations and the European Semester ......................... 24 

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 ...................................................................................................................................... 28 

4.4. 

The principle of ‘do no significant harm’ .............................................................................. 32 

4.5.  Green transition .................................................................................................................... 34 

4.6. 

Digital transition .................................................................................................................... 36 

4.7. 

Lasting impact of the plan ..................................................................................................... 39 

4.8.  Milestones, targets, monitoring and implementation.......................................................... 41 

4.9. 

Costing .................................................................................................................................. 42 

4.10. Controls and audit ........................................................................................................................ 44 

4.11 Coherence ..................................................................................................................................... 47 

Annex: Climate and Digital Tagging Table ............................................................................................. 50 

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1.  EXECUTIVE SUMMARY  

The  COVID-19  pandemic  has  had  a  significant  impact  on  the  Swedish  society  and  its 
economy  although  other  Member  States  have  been  hit  much  harder.  Sweden’s  economy 
contracted  by  2,9%  year-on-year  in  2020,  with  private  consumption  experiencing  the  largest 
decline. From the beginning of 2021, a strong recovery started, driven by private consumption and 
exports. With the pandemic receding somewhat and as policy support remained in place, real GDP 
grew by 4,8% in 2021. Already in the second quarter of 2021, Sweden’s economy had surpassed 
the pre-pandemic level. The existing macroeconomic imbalances have remained with house prices 
and private debt further increasing. 

An unprecedented policy response supported the economy. The budget balance went from a 
surplus of 0,6% of GDP in 2019 to a deficit of 2,8% in 2020. Several amending budgets contained 
measures addressing the fall-out from the crisis and the budget for 2021 already included response 
measures  to  be  funded  through  the  Recovery  and  Resilience  Facility  (RRF).  The  direct  fiscal 
support reached around 3,5% of GDP in 2020 and around 2,5% of GDP in 2021, while liquidity 
and guarantee measures amounted to around 19% of GDP for both years combined. Public debt 
increased from 35% of GDP in 2019 to 39,7% in 2020.  

Sweden’s recovery and resilience plan amounts to EUR 3.3 billion. Sweden has requested only 
the non-repayable financial support under the RRF. This represents some 0,7% of 2019 GDP. The 
plan is structured along five components aimed at tackling Sweden’s structural challenges, which 
the  COVID-19  crisis  exacerbated.  Measures  included  in  the  plan  complement  the  national 
economic  measures  introduced  by  Sweden  in  response  to  the  COVID-19  pandemic  and  the 
economic fall-out and are consistent with the 2021 National Reform Programme. The plan consists 
of 27 measures (12 investments and 15 reforms). 

The plan addresses a significant subset of structural challenges as identified in the relevant 
country-specific recommendations addressed to Sweden by the Council in 2019 and in 2020. 
It introduces reforms and investments to support the green and digital transitions, to increase the 
resilience of the health care system, to reduce the risk of money laundering, to lift the education 
and skills level as well as to strengthen research, development and innovation. The CSR related to 
the macroeconomic imbalances due to overvalued housing prices and high private indebtedness 
has only been addressed in a partly satisfactory manner.  

Sweden’s  recovery  and  resilience  plan  covers  comprehensively  the  six  policy  pillars  as 
referred to in Article 3 of Regulation (EU) 2021/241, structuring the scope of application of 
the Recovery and Resilience Facility, with an appropriate overall balance between pillars. 
The  plan  follows  a  comprehensive  approach  to  support  recovery  and  potential  growth,  while 
improving  socio-economic  and  institutional  resilience.  The  plan  explains  in  detail  how  its  five 
components  address  the  six  pillars,  focussing  on  the  green  transition,  digital  transition,  human 
capital, as well as enhancing the broad resilience of the Swedish economy, in particular through 
tackling demographic challenges, ensuring the integrity of the financial system, and improving the 
functioning of the housing market.  

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The reforms and investments included in the plan can be expected to significantly contribute 
to  the  green  transition.  Overall,  44,4%  of  the  recovery  and  resilience  plan’s  total  allocation 
contribute to the climate objectives. The climate measures are in line with the challenges identified 
in the National Energy and Climate Plan  2021-2030 and are expected to contribute to the 2030 
energy and climate targets. The plan expands on existing efforts within the national carbon pricing 
framework through investments to decarbonise the industrial sector (‘Industry Leap’), investments 
in local and regional projects to reduce greenhouse gas (GHG) emissions (‘Climate Leap’), energy 
efficiency in buildings, investments in sustainable transport, as well as reforms increasing the price 
of carbon emissions and raising the renewable share in transport fuels. All measures in the Swedish 
plan have passed the ex-ante assessment of the ‘do no significant harm’ principle. 

The  digital  transition  is  expected  to  be  accelerated  through  the  plan’s  measures.  Overall, 
20,5% of the recovery and resilience plan’s total allocation contribute to digital objectives.  The 
planned expansion of broadband is expected to further increase high-speed internet access whereas 
the  government’s  common  digital  infrastructure  should  accelerate  the  public  services’  digital 
transition.  This  is  complemented  by  investments  in  vocational  and  higher  education,  with  a 
particular  focus  on  digital  skills  to  meet  the  labour  market  needs  of  the  future.  The  plan  also 
incentivises the use of smart energy systems as part of building renovations, thereby making the 
best use of the synergies between the green and digital transition. 

The reforms and investments in the plan are expected to have lasting socio-economic impacts. 
Effects  of  reforms  should  contribute  positively  to  higher  employment  levels,  improved  human 
capital formation and an extension of working life. Further, through competence development and 
labour market inclusion, the plan contributes to improving social cohesion and inclusion. Support 
to the roll-out of broadband in rural areas will help ensure that all citizens have access to high-
speed connectivity and, thus, foster territorial cohesion. The implementation of the plan’s measures 
is expected to foster structural change in the economy. The prolongation of working life through 
adjusting the age limits in social security and tax systems should have a lasting impact on public 
finance sustainability and economic performance.  

The  implementation  of  the  plan  will  be  monitored  by  the  Swedish  Ministry  of  Finance. 
Appropriate arrangements have been or will be put in place conditional on meeting the milestones 
setting  out  the  responsibilities  of  ministries  and  agencies  in  charge  of  the  implementation, 
monitoring, and reporting of the measures.  

The  milestones  and  targets  of  the  Swedish  plan  constitute  an  appropriate  system  for 
monitoring  the  plan’s  implementation.  The  monitoring  indicators  are  sufficiently  clear  and 
comprehensive  to  ensure  that  their  completion  can  be  traced  and  verified.  The  milestones  and 
targets represent 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 
Swedish authorities appear sufficiently robust to justify adequately the disbursement requests once 
the  milestones  and  targets  are  completed.  The  number  of  milestones  and  targets  appears 
commensurate to the size of the reform and investment package. 

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Based on the assessment of individual cost estimates and related supporting documents, the 
estimated total cost of the plan appears to be reasonable and plausible to a medium extent. 
In the plan, the large majority of the individual cost estimates are assessed to be reasonable to a 
high  extent  because  the  calculations  behind  the  cost  estimate  are  comprehensible  and  based  on 
sound underlying assumptions. The majority of cost estimates in the plan are deemed plausible to 
a high extent because the cost estimates are substantiated by reference costs for the key cost drivers, 
which are in turn supported by clear evidence and in line with comparable reforms or investments. 
However,  for  some  measures  the  calculations  of  and/or  the  link  between  the  cost  and  the 
justification thereof is not entirely clear, precluding a rating of ‘A’ for costing at the plan level. 
Overall, the amount of the estimated total cost of the plan is commensurate to the expected national 
economic and social impact and is in line with the principle of cost-efficiency. 

The plan includes adequate audit and control arrangements. The arrangements 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 conditional on 
the completion of predefined milestones prior to the submission of the first payment request.  

The overall strategy and the measures contained in the plan are coherent. The five components 
form a coherent package of investments and reforms, supporting the objectives to stimulate the 
recovery  of  the  economy  and  foster  sustainable  and  inclusive  growth,  to  contribute  to  the  twin 
transition and to increase resilience. Within each component, measures support and reinforce each 
other and reforms and investments across components are well aligned.  

Table 1: Summary of the Swedish recovery and resilience plan assessment for the 11 criteria 
set by the Recovery and Resilience Facility regulation 

(1) 
Balanced 
Response 
A 

(2) 
CSRs 

A 

(3) 
Growth, 
jobs… 
A 

(4) 
DNSH 

A 

(5) 
Green 
target 
A 

(6) 
Digital 
target 
A 

(7) 
Lasting 
impact 
A 

(8) 
M & T 

(9) 
Costing 

A 

B 

(10) 
Control 
Systems 
A 

(11) 
Coherence 

A 

2.  RECOVERY AND RESILIENCE CHALLENGES: SCENE-SETTER 

2.1. Macroeconomic outlook and developments since the 2020 country report 

The Swedish economy has proved more resilient than the EU average during the COVID-19 
pandemic.  This  is  partly  due  to  the  strong  macroeconomic  starting  position,  but  also  reflected 
structural characteristics such as a favourable sectoral structure which, for instance, allowed large-
scale teleworking and facilitated the operation of supply chains supporting total economic activity. 
In addition, in Sweden restrictions in response to the pandemic were less stringent than in several 
other EU Members States, while substantial  and timely  fiscal  stimulus coupled with  supportive 
measures by the monetary and macroprudential authorities helped cushion the pandemic-induced 
fall  in  economic  activity  and  supported  the  recovery.  Nevertheless,  the  initial  impact  of  the 
pandemic led to a sharp contraction in real GDP in the second quarter of 2020 due to confinement 
measures,  supply  chain  disruptions  and  the  pandemic-related  fall  in  trade  volumes  with  major 
trading  partners,  whereas  fixed  capital  formation  and  the  housing  market  proved  resilient.  The 

4 

 
 
 
subsequent  recovery  unfolded  in  2021,  driven  by  strong  private  consumption,  investment  and 
exports,  with  the  time  profile  shaped  by  the  easing  of  restrictions,  extent  of  supply-chain 
disruptions, progress with vaccination, and the pace of improvement in the economic situation in 
major trading partner countries. In all, after a drop in real GDP of 2,9% in 2020, economic activity 
expanded by 4.8% in 2021, stronger than foreseen in the macroeconomic scenario outlined in the 
recovery and resilience plan (see Table 2). Real GDP is set to further expand by 3,8% in 2022 
according to the Commission Winter Forecast 2022, in line with expected growth according to the 
macroeconomic  scenario  outlined  in  the  plan.  The  fully  fledged  Commission  Autumn  Forecast 
2021 (Table 2) expected a somewhat lower real GDP growth of 3,5% in 2022. 

Table 2: Comparison of macroeconomic developments and forecasts 

The Swedish government has put in place timely and appropriate measures to mitigate the 
negative economic and social impact of the crisis. Emergency measures included covering the 
costs of temporary unemployment and sick leave, fiscal support to cover turnover losses and fixed 
costs for firms and the self-employed, increased transfers to the regions and municipalities that are 
largely responsible for the provision of health care and social security coverage, as well as liquidity 
support and tax payment deferrals. The combined amount of direct fiscal support is estimated to be 
around 3½% of GDP in 2020 and around 2½% of GDP in 2021, while the liquidity and guarantee 
measures  amounted  to  the  equivalent  of  around  19%  of  GDP  for  both  years  combined.  The 
combination of support offered by the pre-existing tax-benefit system and the emergency policy 
measures in response to the pandemic are estimated to have cushioned the impact of the pandemic 
in  unemployment  and  households’ income as  well as  on poverty and inequality to  a significant 

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degree.1 In line with the relatively modest size of the plan, the estimated direct impact of fiscal 
support measures in the plan is relatively limited (at a cumulative 0,5% of GDP) and chiefly reflects 
direct-short term expenditure effects. 

The macroeconomic scenario contained in Sweden’s recovery and resilience plan expected a 
rebound of economic growth in 2021 following the COVID-19 induced contraction in 2020. 
The plan projects an increase in real GDP of 3,2% in 2021, picking up somewhat to 3,8% in 2022, 
before falling back to a more moderate rate of 1,9% in 2023 and 1,6% in 2024. According to the 
plan  scenario,  real  GDP  growth  is  driven  by  a  recovery  in  private  consumption  and  exports. 
Inflation is set to remain contained and stay between 1% and 2% in the plan’s economic forecast.  

Against this backdrop, the macroeconomic scenario expects unemployment to peak at 8,7% 
in  2021  before  falling  to  7,0%  in  2026.  The  plan  underlines  that  the  COVID-induced 
unemployment and related income losses as an immediate consequence of the pandemic affected 
up to 1 million Swedish residents (around 10% of the population), in spite of extensive support 
measures. Persons already struggling to find employment before the pandemic like the low-skilled, 
young,  and  newcomers  from  non-EU  countries  face  the  highest  risk  of  a  deterioration  in  their 
position on the job market. The low-skilled and non-EU migrants also face the largest risk of social 
exclusion  and  poverty.  While  the  negative  impact  of  the  pandemic  on  individuals  could  be 
substantial,  the  plan  expects  the  overall  increase  in  income  inequality  and  long-term  negative 
effects on overall skills levels to remain limited. This should be due to a combination of improved 
employment  opportunities  in  the  wake  of  the  expected  recovery  and  the  effects  of  a  range  of 
supportive  policy  measures  –  which  are  broader  than  those  included  in  the  plan  –  aimed  at 
mitigating not only negative employment and income effects but also at promoting education and 
training.  For  2021,  the  plan  expects  that  supporting  measures  for  the  economy  reduced  the 
unemployment rate by 1,3%. Employment is forecast to have grown slightly by 0,3% in 2021 and 
is expected to only revert back slowly to pre-crisis levels.  

Sweden remains a relatively equal society, with income inequality set to remain below the EU 
average over the horizon covered by the plan. The share of people at risk of poverty or social 
exclusion (17,7% in  2020) is  below the EU average (21,94%). However,  vulnerable  groups are 
more  likely  to  be  at  risk  of  poverty  or  social  exclusion,  including  non-EU  born,  children,  low-
skilled workers,  and  people  with  disabilities.  The  crisis  is  expected  to  further  accentuate  those 
discrepancies inter alia in light of a lack of affordable housing.  

Government finances have been negatively impacted by the COVID-19 crisis. Nevertheless, 
the 2020 budget deficit of 2,8% of GDP was among the smallest in the EU. The plan does not 
present  figures  on  fiscal  aggregates  over  the  full  horizon  it  covers  while  the  fiscal  measures 
included in the plan form only a part of all support measures put in place by the authorities. After 
an increase in the debt-to-GDP ratio in the wake of the crisis due to the combined effect of shrinking 

1 See 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. 

6 

 
 
                                                           
 
GDP and fiscal stimulus, the Commission 2021 Autumn forecast expected the general government 
debt ratio to start falling still in 2021 as the recovery takes hold. The Commission services project 
debt to remain well below 60% of GDP in 2030.2 Hence, Swedish public debt continues to be on a 
sustainable path.  

Macroeconomic  imbalances,  chiefly  rooted  in  high  household  debt  and  sharp  increases  in 
house  prices,  remain  a  risk.  House  prices  accelerated  significantly  from  the  onset  of  the 
pandemic, including in the main urban areas where prices were already high. Credit to households 
continued to expand briskly, contributing to the household debt ratio rising further above prudential 
thresholds. Going forward, rising interest rates could put a strain on the finances of households that 
are  exposed to  high mortgage loans with  variable interest  rates.  Policies implemented in  recent 
years have not been sufficient to address these imbalances. 

The plan specifies a number of risks to the macroeconomic scenario. The plan notes that the 
macroeconomic  and  fiscal  outlook  continues  to  be  affected  by  high  uncertainty  related  to  the 
COVID-19  pandemic  and  its  economic  consequences.  The  downside  risks  identified  include 
persistence of unemployment leading to reduced matching in the labour market and negative effects 
of lower risks appetite on investment and productivity growth. Upside risks include impulses from 
enhanced schooling, digitalisation and reforms to  lengthen the  active working life.  On balance, 
risks are seen to be tilted to the upside.  

Compared  with  the  fully-fledged  Autumn  2021  Commission  forecast,  the  macroeconomic 
scenario  in  the  plan  is  somewhat  more pessimistic for 2021 and broadly  in line for 2022.3 
Similar  to  the  Plan,  the  Commission  expected  domestic  demand  to  be  the  main  growth  engine 
behind the recovery, foreseeing a somewhat stronger rebound in 2021. The differences between 
the Commission Autumn 2021 forecast and the macroeconomic scenario underpinning the plan are 
due  to  a  combination  of  differences  in  external  assumptions,  in  the  assessment  of  budgetary 
measures and their impact on economic agents, and also to different cut-off dates. Labour market 
projections in the plan are more cautious than in the Commission forecast, whereas the path for 
expected  inflation  is  very  similar,  allowing  for  differences  in  external  assumptions.  The 
macroeconomic scenario of the plan is cautious. Since the submission of the plan, the Swedish 
authorities  have  revised  their  overall  forecast  in  the  direction  of  a  stronger  recovery,  similar  to 
upward revisions in the Winter 2022 Commission forecast, allowing for the inclusion of additional 
outturn data and updated forward-looking indicators.  

2 European Commission, Debt sustainability monitor 2020, Institutional Paper 143. February 2021. Brussels. 
3 Based on outturn data, Sweden’s economy grew by 4,8% in 2021 better than expected by the projections in the plan 
at the date of submission and the comparable Commission Autumn 2021 forecast. The latest Commission Winter 2022 
forecast has very similar real GDP growth compared to the plan for 2022 and 2023. 

7 

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

generation  

The Swedish economy is among the most advanced within the EU in terms of wealth, equal 
opportunities, care for the environment and innovative capacity. Nevertheless, challenges exist 
across all policy areas and they are intertwined.  

Smart, sustainable and inclusive growth 

Labour  market  challenges  include  the  integration  of  low-skilled  people,  non-EU  migrants 
and  people  with  disabilities,  as  well  as  labour  shortages  and  a  widening  skills  gap.  Skills 
mismatches, a long-standing issue, is  expected to lead to  continued labour shortages in a broad 
range of sectors (including, but not limited to education, health care, social work, ICT, industry 
and construction) in the coming years. The COVID-19 crisis has increased the risk of long-term 
unemployment for groups that were finding it difficult to get and remain in employment already 
pre-COVID. Reskilling and upskilling will be important to allow unemployed to find permanent 
employment.  

Social and territorial cohesion 

Further integration of foreign-born requires an integrated approach to social, educational 
and employment policies linked with access to services. Specific attention is necessary for the 
obstacles foreign-born women face. Non-EU born people are more exposed to the risk of poverty 
or social exclusion than on average in the EU and this risk has increased in recent years. The gender 
gap  is  wide  for  foreign-born  women,  due  to  both  higher  inactivity  and  unemployment.  Better 
integrating foreign-born into the labour force would support productivity growth in the longer run, 
social cohesion and equality of opportunities.  

Health, economic, social, and institutional resilience 

Macroeconomic imbalances in the housing market and high private debt persist. Sweden has 
received repeated  country-specific recommendations  over the last  years concerning the housing 
market, the risk of high household indebtedness linked to the mortgage interest deductibility, as 
well as the need to foster investment in housing and increase the efficiency of the housing market. 
Sweden is one of the very few EU countries with tax relief on the full amount of mortgage interest 
paid.  

At the same time, there is a housing shortage, and in particular a lack of affordable housing. 
Despite the shortage, the number of people who are eligible for social housing, or who can receive 
housing benefits, is limited. Allowing more people access to housing benefits would potentially 
reduce homelessness and housing exclusion. It  would also encourage more labour mobility and 
allow for people to move to a different location for studies/training. Reforming the rental market, 
while  addressing  incentives  in  the  tax  system  favouring  owner-occupation  over  renting,  would 
increase economic resilience over the medium-term.  

Sweden  has specific weaknesses with respect  to the  risk of money laundering. Sweden has 
allocated more resources to the competent institutions, strengthening in particular the capacity of 
its Financial Supervisory Authority. However, the Authority’s capacity is still low compared to the 

8 

 
 
size of the Swedish financial sector. Challenges remain and the risk-based approach still needs to 
be fully implemented.  

Sweden has a good, tax-funded and generally effective healthcare system with a strong focus 
on outpatient and long-term care. The total healthcare spending as a share of GDP is higher than 
the EU average (10,9%; EU average 9,9%). Nevertheless, the availability of medical personnel and 
coordination between different levels of care could be further improved. The COVID-19 pandemic 
has  highlighted  existing  structural  weaknesses,  such  as  shortages  of  healthcare  workers, 
coordination gaps between different entities of the health administration as well as different levels 
of care (including long-term care) and geographical imbalances in the distribution of health care 
services.  Immediate  issues  have  been  effectively  resolved  in  Sweden’s  crisis  response. 
Nevertheless,  in  the  medium  term,  Sweden  could  benefit  from  improving  the  availability, 
qualifications and working conditions of healthcare workers, especially care assistants and nurses, 
and from further development of eHealth solutions and IT systems for healthcare coordination.  

Policies for the next generation, children and young people, including education and skills.  

The main challenges for Sweden in the education area are a separation of native- and foreign-
born students in different schools (leading to an educational gap between these two groups) 
and a growing teacher shortage. The move to distance education due to the COVID-19 pandemic 
has also had a stronger negative effect on the foreign-born students, due to language problems and 
lack of computers, internet access and IT skills.  In addition, the accessibility of digital learning 
resources, their use by teachers, and access to technical and educational support varied significantly 
across schools. These developments have come on top of existing structural shortcomings. About 
20% of teachers are not formally qualified. The share is even higher, over 50%, among teachers 
under 30, while participation in the formal qualification programme is, at 5,1%, far lower than the 
EU average (EU-22: 14,7%)4. Teacher shortages are the most pressing in rural areas of northern 
Sweden, and unqualified teachers are more common in schools with a higher share of non-native 
born pupils. 

Specific  challenges  related  to  policies  for  the  next  generation  relate  to  labour  market 
integration and housing affordability. With youth unemployment standing at 24% in December 
2021, investments and reforms appear needed to support their job search, employment and bridge 
between  education  and  the  labour  market.  In  addition,  the  housing  shortage,  especially  in  the 
segment of affordable housing and student housing, is posing a challenge to the younger generation. 

2.3. Challenges related to the green and digital transition  

2.3.1.  Green dimension  

The recovery and resilience plan should contribute to the green transition and at least 37% 
of the financial allocation needs to contribute to climate objectives. The measures in the Plan 
shall contribute to achieving the 2050 climate neutrality objective, and the 2030 energy and climate 
targets,  taking  into  account  Member  States’  National  Energy  and  Climate  Plans.  The  measures 

4  OECD  (2019),  TALIS  2018  Results  (Volume  I):  Teachers  and  School  Leaders  as  Lifelong  Learners,  TALIS 
(http://www.oecd.org/education/talis/) 

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should  also  contribute  to  meeting  environmental  targets  for  waste,  water,  pollution  control, 
sustainable  mobility,  biodiversity  protection  and  restoration,  marine  and  water  resources,  and 
support the transition to sustainable food systems as well as to a circular economy as appropriate, 
while ensuring that nobody is left behind. 

Sweden has been able to combine sustained economic growth with lowering greenhouse gas 
emissions over a longer period. Between 1990 and 2019, Sweden’s GHG emissions fell by 29% 
whilst its real GDP per capita increased by 54%. Sweden is among the EU Member States with the 
lowest GHG emissions per capita and is on course to meet its current EU 2030 targets under the 
Effort Sharing Regulation to reduce GHG emissions in sectors outside the EU’s Emission Trading 
System  by  40%  from  2005  levels.  However,  Sweden’s  national  objectives  are  even  more 
ambitious:  Sweden  has  set  a  national  2030  target  to  achieve  at  least  a  50%  reduction  of  GHG 
emissions in its effort sharing sectors compared to 2005. To reach its long-term domestic targets, 
Sweden would need to increase the annual rate of emission reductions. 

Transport is a key target for emissions reduction. The sector accounted for 31% of the national 
greenhouse gas emissions in 2020. While emissions from the industry and domestic transport have 
decreased, domestic transport is lagging behind industry and remains the single most important 
source of carbon emissions. The aim is for emissions from domestic transport (aviation excluded) 
to decrease by at least 70% by 2030 compared to 2010.  

Land use, land use change and forestry (LULUCF) is an important sector in Sweden due to 
its large forest area. The sector is a significant carbon sink and is considered an integral part of 
Sweden’s climate strategy. It is also a key contributor to the economy, providing renewable energy 
sources, harvested wood products and other materials. The intensification of logging in Sweden 
has raised concerns for both the climate and biodiversity, in particular where logging may target 
old-growth forests.  

Greenhouse gas emissions vary widely regionally, mainly due to differences in the business 
structure. The steel industry in Upper Norrland is an important industry and emitter, but is in a 
transformation process to become fossil-free by 2035. Fossil carbon dioxide emissions from the 
steel  industry  mainly  come  from  the  production  process  and  internal  transport,  leaving  further 
scope for the rollout of innovative and low-emission processes (e.g. hydrogen). 

Renewable share 

Sweden has the highest share of renewables in energy consumption in the EU. The share of 
renewable resources in final energy consumption increased from 41% in 2005 to 60,1% in 2020.  

Biofuels are the largest renewable source and used mostly for heating, whereas hydropower 
is  the  dominant  renewable  source  for  electricity  generation.  Hydropower  is  not  expected  to 
provide  additional  renewable  energy  sources,  but  Sweden  will  rather  expand  other  renewable 
technologies to increase its share of renewable energy and to contribute to the EU’s 2030 target for 
renewable energy5 by reaching 65% of renewable energy.  

5 As a share of gross final energy consumption. 

10 

 
 
 
                                                           
Energy efficiency 

Sweden has presented a comprehensive set of energy efficiency measures for the buildings 
sector in its national long-term renovation strategy. Implementing this strategy will go a long 
way in increasing energy efficiency, but as the final energy consumption in 2020 was higher than 
the target value, more efforts are needed to reach energy efficiency targets. In addition, Sweden 
plans  to  carry  out  the  renovation  of  its  building  stock  in  stages,  depending  on  the  age  of  the 
building.  In particular, priority  would  need to be given to  improve  the  energy efficiency of the 
worst performing buildings and to reduce energy poverty6.  

Sweden  intends  to  be  carbon-neutral  by  2045  and  have  net  zero  emissions  thereafter. 
Achieving  this  objective  will  require  sizeable  investments,  notably  in  the  buildings  sector,  in 
infrastructure for the electrification of road transport and in innovative low-carbon technology in 
energy-intensive industry sectors, such as steel7. On the government’s initiative, several energy-
intensive sectors of the industry have come forward with roadmaps for becoming climate neutral 
by 2045 while also increasing their competitiveness.  

Environment 

In July 2020, the Swedish government adopted a national strategy for a circular economy. It 
sets out the direction and ambition for a long-term and sustainable transition of the Swedish society. 
The strategy  fits  in  with  the country’s  goal  of becoming the world’s first  fossil-free country.  It 
focuses on sustainable production and sustainable ways of consuming.  

The shift from a linear to a circular economy  model  should promote  the use of safe, non-
polluting  and  sustainable  materials  and  processes.  Sweden  is  advanced  as  regards  waste 
management,  but  more  effort  is  needed  to  comply  with  EU  recycling  targets  for  the  post-2020 
period, for example through lowering energy recovery from waste, shifting municipal waste away 
from incineration and towards recycling. Construction and renovation initiatives in Sweden need 
to further encourage material efficiency and life-cycle processes.  

To enhance its overall good environmental performance, Sweden needs to improve air and 
water  quality  and  support  biodiversity  related  measures.  These  measures  concern  habitats 
restoration (grassland, wetlands, marine ecosystems), as these areas still remain challenging from 
environmental and human health perspective. 

Table  3  below  gives  an  overview  of  Sweden’s  objectives,  targets  and  contributions  under 
Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 
on the Governance of the Energy Union and Climate Action. 

6 Castellazzi, L., Zangheri, P., Paci, D., Economidou, M., Labanca, N., Ribeiro Serrenho, T., Zancanella, P. and 
Broc, J., Assessment of second long-term renovation strategies under the Energy Efficiency Directive, 2019, JRC. 
7 Economidou, M., Ringel, M., Valentova, M., Zancanella, P., Tsemekidi Tzeiranak, S., Zangheri, P., Paci, D., 
Ribeiro Serrenho, T., Palermo, V. and Bertoldi, P., National Energy and Climate Plans for 2021-2030 under the EU 
Energy Union, 2020, JRC122862. See also Tsemekidi-Tzeiranaki, S., Paci, D., Cuniberti, B., Economidou, M. and 
Bertoldi, P., Analysis of the Annual Reports 2020 under the Energy Efficiency Directive, 2020, JRC122742. 

11 

 
 
 
                                                           
Table 3: Overview of Sweden’s energy and climate objectives, targets and contributions 

National targets and contributions  

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

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

Latest 
available 
data 

2020 

2030 

-29 

-17 

-40 

60.1 

49 

65 

Assessment of 2030 
ambition level 

More ambitious 
National target of at 
least -50 

Sufficiently 
ambitious 
(Above RES 
Formula level of 64) 

National contribution for energy efficiency: 

Primary energy consumption (Mtoe) 

Final energy consumption (Mtoe) 

41.7 

30.9 

43.4 

40.2  Modest ambition 

30.3 

29.7  Modest ambition 

Level of electricity interconnectivity (%) 

26 

28 

27 

N/A 

Note: Preliminary data for 2020 indicate that Sweden’s GHG emissions under the Effort Sharing 
legislation dropped by 29% in 2020 compared to 2005. 

Sources: Assessment of the final national energy and climate plan of  Sweden, SWD-(2020) 926 
final and Eurostat data from specific years, Commission staff working document accompanying 
the Climate Action Progress Report 2021, SWD(2021) 298 final. 

2.3.2.  Digital dimension  

The recovery and resilience plan should contribute to the digital transition and at least 20% 
of the financial allocation needs to contribute to digital objectives. The measures in the plan 
should,  inter  alia,  contribute  to  the  digital  transformation  of  the  economic  and  social  sectors 
(including public administration, public services, and the justice and health systems). The objective 
of  the  measures  in  the  plan  should  be  to  improve  not  only  the  competitiveness,  but  also  the 
resilience, agility and security of companies and public actors, all while ensuring inclusiveness. 

Sweden is one of the top-performing EU countries as regards the digital dimension according 
to  the  European  Commission’s  Digital  Economy  and  Society  Index  (DESI).  72%  of  the 
population has at least basic digital skills and 46% has above basic digital skills.  8 In 2017, the 
Swedish government adopted the Digitalisation Strategy, which sets out the pathway for Sweden 
to become the world leader in harnessing the opportunities offered by digitisation in skills, security, 
innovation and infrastructure.  

8 European Commission (2021), Digital Economy and Society Index (DESI) 2021.  

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Sweden’s human capital is one of its strongest competitive advantages, but the country needs 
to address the unmet demand for digital experts to keep its technological edge. Irrespective of 
a  high  digital  skill  level  among  the  broad  population  and  a  high  number  of  information  and 
communication technology (ICT) specialists (7,5% of individuals), 55,1% of enterprises who tried 
to recruit ICT specialists report hard-to-fill vacancies (EU average: 55,4%), constraining growth 
and  productivity.  Additional  efforts  and  investments  are  needed  to  allow  higher  education 
institutions to attract more students, offer new courses and further increase the number of graduates 
in science, engineering and computing, to further improve Sweden’s top  standing in innovation 
and digital technologies. 

Sweden is also a front-runner for ultrafast connectivity in Europe, but still faces challenges 
in the roll-out of broadband and coverage of remaining sparsely populated areas, as well as 
the timely assignment of 5G bands. To reach its goal of 98% coverage of high-speed internet 
access by 2025, Sweden would need to address the difficulties of ensuring roll-out and coverage 
of  the  remaining  sparsely  populated  areas.  To  this  end,  an  existing  public  funding  scheme  will 
continue to support projects deploying high-speed broadband infrastructure with a speed of at least 
1 Gbps in areas where there is no existing Next Generation Access (NGA) network or where no 
NGA deployment is planned within 3 years. The successful deployment of 5G in Sweden depends 
on the timely availability and assignment of the 5G pioneer bands. In January 2021, the Post and 
Telecom Authority successfully resumed and completed the 5G spectrum auction through which it 
awarded  frequencies.  This  is  an  important  step  for  the  5G  rollout  in  Sweden.  It  will  also  have 
synergies  with  Sweden’s  intention  to  improve  connectivity  on  trains,  which  demand  stable 
connectivity to improve conditions for telework and commuting.  

The public sector is digitally mature, but there is room for improvement on open data and 
the reuse of public data. E-government services are widespread in Sweden, with 88% of internet 
users able to submit forms online in 2020. E-identification is also prevalent. However, in 2021 the 
country was for the first time over the EU average with 84% of the maximum score on open data. 
Many initiatives in the digitalisation strategy aim at harnessing the availability of open data and 
increasing the innovative use of digital technologies to create value-adding services both to the 
public and to businesses. The Agency for Digital Government (DIGG), which was established in 
2018, has together with other agencies been assigned several tasks related to open data and the use 
of new technologies. DIGG has now been tasked to coordinate and support digitisation across the 
public sector in order to make it more efficient and fit for purpose. 

Sweden  encourages  SMEs  to  embrace  new  technologies  faster.  The  Swedish  smart  industry 
strategy supports the digital transformation of SMEs. Although the share of Swedish firms planning 
high-growth as a result of increased digitalisation is above the EU average9, overall SMEs need to 

9 Benedetti Fasil, C, Domnick, C, Fako, P, Flachenecker, F., Gavigan, J. P., Janiri, M. L., del Rio, J-C, Stamenov, B. 
and Testa, G., High Growth Enterprises in the COVID-19 Crisis Context demographics, environmental innovations, 
digitalization, finance and policy measures, European Commission, JRC, 2021. 

13 

 
 
                                                           
become more aware of the advantages of digital technologies and speed up their adoption as they 
are  behind  large  enterprises  when  it  comes  to  digital  intensity  and  ICT  skills  of  their  staff.10 
Innovative solutions and upskilling their workforce would enable Swedish SMEs to participate to 
the fullest in the Single Market.  

Investments in (sustainable) technologies can enhance Sweden’s competitiveness during the 
green  transition,  including  expanded  innovative  solutions  in  energy,  production  and 
distribution.  Starting  from  2021,  Sweden  is  strengthening  research  and  innovation  into 
digitalisation until 2024 with the Research and Innovation Bill. The bill, which is financed by the 
national budget outside the RRP, indicates the cross-cutting societal challenges on which research 
and  innovation  in  Sweden  will  focus.  These  are  climate  and  environment,  health  and  welfare, 
digitalisation, skills supply and working life, and a democratic and empowered society. The R&I-
related  digitisation  efforts  include  research  on  the  societal  implications  of  digitalisation,  an 
innovation  programme  in  the  fields  of  business  and  AI,  research  into  information  and 
cybersecurity,  and  collaborative  programmes  in  the  field  of  digitalisation,  as  well  as  e-
infrastructure investments.  

Figure 1: Digital Economy and Society Index 2020 – relative performance by dimension 

DESI 2020 - relative performance by dimension

h
t
i

w
y
r
t
n
u
o
C

e
r
o
c
s

t
s
e
h
g
h

i

t
s
e
w
o

l

h
t
i

w
y
r
t
n
u
o
C

e
r
o
c
s

DESI

1 Connectivity 2 Human capital

3 Use of
internet services

4 Integration of
digital
technology

5 Digital public
services

Sweden

EU

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

10 According to DESI, 75% of large enterprises have high levels of digital intensity compared to 25% of SMEs in 2020. 
Moreover, only 31% of SMEs provide training for their staff to develop or upgrade their ICT skills compared to 79% 
in large companies. Although not directly addressed at scale in the digitalisation strategy, SMEs stand to benefit both 
from the use of innovative solutions and from upskilling their workforce. SMEs could also benefit more from selling 
online and cross border, an area where Swedish SMEs are behind other countries. 31% of SMEs sell online and only 
10% sell cross border. 

14 

 
 
 
 
                                                           
 
 
 
 
 
 
Box 1: Progress towards the Sustainable Development Goals  

Overview table of the overlap between the Sustainable Development Goals and the four 
dimensions underpinning the recovery and resilience plan. 

The objectives of the Sustainable Development Goals (SDGs) 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 
Sweden’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. 

Green Transition 

Sweden performs well on many SDGs related to the green transition. For instance, Sweden is 
among the EU Member States with the lowest per capita net greenhouse gas (GHG) emissions (1.2 
tonnes in 2020), well below the EU average (7 tonnes). The share of renewable energy in gross 
final  energy  consumption  is  relatively  high  in  Sweden  (60,1%  in  2020),  compared  to  the  EU-
average  (22,1%).  Further  reducing  the  carbon-intensity  of  the  Swedish  economy  would  lead  to 
progress on SDG 7 ’Affordable and clean energy’ and SDG 13 ’Climate action‘.  

15 

 
 
 
 
 
Fairness 

Sweden  shows  generally  high  rankings  on  indicators  assessing  the  fairness  of  society  and 
economy. For instance, Sweden performs well with respect to SDG 1  'No poverty'. The rate of 
people at risk of poverty or social exclusion (17,7% in 2020) is below EU average (21,9%). Sweden 
is also among the best performing Member States on ‘Good health and well-being’ (SDG 3), while 
its performance has deteriorated recently on ‘Reduced inequalities’ (SDG 10). Sweden shows good 
performance on ‘Quality education’ (SDG 4), with comparably low rates of young people neither 
in employment nor training/education, and high rates of adult participation in learning. The gender 
employment gap (SDG 5) is very low in Sweden.  

Digital transition and productivity 

Sweden  performs  well  what  concerns  ‘Decent  work  and  economic  growth’  (SDG  8)  and 
‘Industry, innovation, and infrastructure’ (SDG 9). With 3,5% of GDP allocated to R&D in 
2020, Sweden has the highest R&D spending in the EU. The investment share is also higher than 
the EU average (24,8% in 2020, compared to 22,3%). By intensifying policy efforts, Sweden could 
make further progress on the SDGs related to the digital transition and productivity.  

Macroeconomic stability 

Sweden  performs  very  well  on  SDG  8  and  achieves  good  scores  on  indicators  measuring 
‘peace, justice, and strong institutions’ (SDG 16), although some indicators relating to ‘peace 
and personal security’ have declined slightly. 

3.  OBJECTIVES, STRUCTURE AND GOVERNANCE OF THE PLAN 

3.1. Overall strategy of the plan  

The plan is part of the country’s large restart package to support the socio-economic recovery 
and long-term development after the COVID-19 pandemic. The fiscal support measures in the 
package, contained in the 2020, 2021 and 2022 budgets and budget amendments, aims to foster a 
climate-friendly and highly digitalised society, supporting inclusion and facilitating people to get 
back into employment.  

Reforms and investments should accelerate the green transition and digitalisation supporting 
lasting structural improvements. Funds allocated in the plan, which are in addition to the national 
funds, will help stimulate the economy and support jobs and companies in the short term while 
helping speed up the green transition, digitalisation, social priorities and regional cohesion in the 
medium to long term.  

The plan is made up of five components, focussing on (i) the green recovery, (ii) education 
and transition, (iii) better conditions for addressing demographic challenges, (iv) broadband 
expansion  and  digitalisation  of  public  administration,  and  (v)  investment  for  growth  and 
housing.  The  plan  has  a  strong  focus  on  the  green  transition,  with  dedicated  reforms  and 
investments  aimed  at  inter  alia  carbon-intensive  sectors,  such  as  transport  and  industry,  thus 
contributing to the national climate target for Sweden to have no net emissions of greenhouse gases 
by  2045.  A  dedicated  component  contains  measures  to  improve  employment  opportunities  by 
increasing  human  capital  among  the  unemployed,  educating  and  training  the  labour  force, 
16 

 
 
complemented  by  a  set  of  reforms  to  increase  flexibility  in  the  labour  market  and  increase  the 
transition into employment. The plan also aims at addressing demographic challenges and securing 
the integrity of the financial system, with reforms in the health sector, the pension system and the 
fight  against  money  laundering.  A  digital  component  provides  for  the  roll  out  of  high-speed 
broadband in rural and sparsely populated areas as well as further digitalisation of the Swedish 
public administration. Finally, the plan has also dedicated measures to improve housing supply and 
foster investments in the housing market.  

The plan does not include cross-border or multi-country projects.  

The reforms and investments in the plan are well in line with the Facility’s objectives to promote 
cohesion,  by  including  fostering  growth  and  employment,  strengthening  social  and  territorial 
cohesion and supporting the green and digital transformation.  

Table 4: Overview of the plan, its components and associated estimated costs 

Component 
I: Green recovery 
II: Education and transition 
III: Better conditions for addressing demographic 
challenges 
IV: Broadband expansion and digitalisation of public 
administration  
V: Investment for growth and housing 

3.2. Implementation aspects of the plan 

Governance 

Costs (EUR million) 

1552 
504 
452 

485 

296 

The Ministry of Finance will oversee coordination, monitoring and reporting on the plan’s 
implementation. Sweden's recovery and resilience plan is based on goals and instruments decided 
by the Parliament. The Riksdag's Committee on Finance was on two occasions, on 6 and 27 April 
2021, informed by the Government about the design of the plan. The Ministry of Finance ensures 
compliance  with  Union  law,  monitors  the  full  and  timely  fulfilment  of  the  plan’s  strategic  and 
operational objectives through milestones and targets, prepares and submits requests for payment 
based on the necessary information from the competent authorities and reports to the Commission, 
ensures the evaluation of the results of the plan and the dissemination of outputs; and provides the 
competent authorities with technical assistance. The Ministry of Finance will also be responsible 
for  coordinating  control  and  audit  systems,  for  issuing  the  management  declarations,  for  the 
preparation  and  submission  of  the  requests  for  payment  to  the  European  Commission,    for 
conducting controls on the line ministries’ implementation of the recovery and resilience plan, and 
for handling and ensuring a central reply to requests for information and access to data on final 
recipients.  Specific  mandates  have  been  issued  to  the  Swedish  National  Financial  Management 
Authority (ESV) to ensure coherence of audit and control aspects across the decentralised Swedish 
governance  system,  as  well  as  to  develop  an  audit  strategy  covering  all  RRF.  The  ESV  is 
responsible  for  collecting  the  data  for  monitoring  the  achievement  of  milestones  and  targets, 
thereby assisting the Ministry of Finance in its overall coordination responsibilities.  

17 

 
 
 
implementing  the 

While  in  its  capacity  as  overall  coordinating  entity  the  Ministry  of  Finance  monitors  the 
implementation  of  the  plan  and  is  responsible  for  exchanges  with  the  Commission,  the 
responsibility  for 
individual  components  (including  operational 
responsibility for audit and control) lies with the public authorities (myndigheter). The main 
part of the government policies is carried out by the public administration. The number of state 
authorities in Sweden is relatively large and entities have a high degree of autonomy. Although the 
authorities report to the Government, they are not organisationally part of the Government Offices. 
The authorities responsible for managing and monitoring the use of EU funds in Sweden other than 
RRF funds will thus have a key role for the effective and efficient implementation of the plan. The 
authorities  that  have  the  greatest  role  in  that  work  are  the  Swedish  Agency  for  Economic  and 
Regional Growth (responsible for ERDF), and the Swedish Energy Agency (manages the “Industry 
Leap”).  Their  experience,  capacity  and  technical  expertise  should  facilitate  the  effective 
implementation  of the recovery plan. Through contacts  between directly responsible authorities 
and other relevant bodies, the plan is expected to be implemented effectively, in accordance with 
the requirements of applicable Union law. Funding from the RRF and additional national or Union 
funds should be disbursed at central level. The Technical Support Instrument (TSI) can provide 
expertise in building capacities to implement the plan in a number of areas such as energy, green 
transition, healthcare, education or anti-money-laundering. 

Equality 

Sweden’s Recovery and Resilience Plan (RRP) has a strong focus on gender equality, as the 
impact  of  every  measure  on  women  and  men  is  carefully  assessed.  Sweden  describes  existing 
national challenges in terms of gender equality, whether they result from the pandemic - young and 
foreign-born women are particularly affected - or are more structural. The plan describes to a lesser 
extent challenges related to equal opportunities for all, with an emphasis on the access to the labour 
market  for  young  people,  foreign-born  and  persons  with  disabilities.  The  plan  presents  the 
mechanisms and governance structures ensuring that equality will be duly taken into consideration 
during  its  implementation.  Those  include  gender  budgeting,  gender  mainstreaming  in  public 
authorities  and  higher  education  institutions  and  state  authorities’  responsibility  for  the 
implementation  of disability policies. The plan presents  to  a large extent data disaggregated by 
gender. 

Consultation process 

Sweden carried out stakeholder consultations. In April 2021, the parliamentary Committee on 
Finance was informed about the design of plan. A broad range of stakeholders were consulted along 
the preparation of the plan and provided proposals for measures Government entities at various 
levels as well as the main social partners were involved in the preparation within the framework of 
the  national  co-ordination  on  the  European  Semester,  including  two  high-level  meetings  with 
representatives from these main social partners and meetings with representatives of the regions 
(under the auspices of Association of  Local  Administrations and Regions). Finally,  a  dedicated 
meeting has also been held with representatives of civil society. Where applicable, the stakeholders 
will continue to be involved in the implementation of the respective measure, to ensure that the 
authorities have ongoing contact with e.g. companies, municipalities and regions. 

18 

 
 
 
Communication strategy 

The Government has made it possible for the public to access information about Sweden's  
plan by publishing it on its website (www.regeringen.se). The Government will follow up with 
information  about  future  reports  made  to  the  Commission  and  keep  the  website  updated  as 
Sweden's  plan is implemented. The Government will commission authorities and executive bodies 
involved making the RRF funding visible to the public. For projects supported by the RRF, the 
relevant authorities will be instructed, when applicable, to show the emblem of the Union and an 
the  words  “Funded  by  European  Union  - 
appropriate  declaration  of  funding  with 
NextGenerationEU” through appropriate communication channels. The Government also intends 
to take the necessary decisions to ensure that the provisions of Article 22(2), point (f) and Article 
34(2) of the RRF Regulation are complied with in the implementation of the measure for all actions. 

The plan indicates a clear commitment by the authorities to meeting the RRF Regulation’s 
requirements  on  communication.  This  refers  in  particular  to  making  public  information 
regarding  the  implementation  of  the  Plan  and  the  labelling  of  projects  as  financed  by  the  RRF 
(‘funded by the European Union  – NextGenerationEU’). The implementation of the plan could 
give rise to additional communication opportunities; it will be up to the Swedish authorities, in 
cooperation with the Commission, to seize such opportunities. 

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 Sweden in  the recovery and 
resilience plan cannot be deemed a State aid notification. In as far as Swede 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 Sweden to ensure full compliance with the 
applicable rules. In addition to complying with the EU’s State aid rules, measures taken under this 
framework should be compatible with the EU’s international obligations, in particular under World 
Trade Organization rules. 

Security self-assessment 

The  plan  does  not  explicitly  indicate  the  use  of  security  self-assessments.  However,  related 
concerns are alleviated by the fact that there is no measure that would relate to 5G deployment.  

19 

 
 
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 recovery and reinforcing socio-economic resilience, 
taking into account the specific challenges and financial allocation of Sweden. The plan aims 
to support the recovery and potential growth, while improving socio-economic and institutional 
resilience. The plan explains in detail how it addresses the six pillars referred to in Article 3 of the 
RRF Regulation, namely: (i) green transition, (ii) digital transformation, (iii) smart, sustainable and 
inclusive  growth,  (iv)  social  and  territorial  cohesion,  (v)  health  and  economic,  social  and 
institutional resilience, and (vi) policies for the next generation. The plan contains 27 measures (15 
reforms and 12 investments) divided into five components, focusing on the green transition, digital 
transition, human capital, as well as enhancing the broad resilience of the Swedish economy, in 
particular through tackling demographic challenges, ensuring the integrity of the financial system, 
and  improving  the  functioning  of  the  housing  market.  Sweden  submitted  its  National  Reform 
Programme  on  28  May  2021.  The  information  provided  in  the  National  Reform  Programme  is 
being considered and jointly assessed in this Staff Working Document together with the recovery 
and resilience plan. 

All  pillars  are  covered  by  at  least  one  component,  while  a  component  may  contribute  to 
several  pillars. The range of actions  of the plan corresponds  to  the one of the Facility with  an 
appropriate  overall  balance  between  pillars.  The  coverage  of  the  Swedish  plan’s  components 
toward the six pillars is summarised in Table 5.  

Table 5: Coverage of the six pillars of the Facility by the Swedish recovery and resilience plan 
components 

Green 
transition 

Digital 
transformation 

Smart, 
sustainable & 
inclusive 
growth 

Social and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutional 
resilience 

Policies for 
the next 
generation 

C1: Green 
recovery 
C2: Education, 
training and 
conversion 
C3: Better 
conditions to 
meet the 
demographic 
challenge and 
ensure the 
integrity of the 
financial system 
C4: Broadband 
roll-out and 
digitalisation of 
public 
administration  
C5: Investment 
for Growth and 
Housing 

● 

○ 

○ 

● 

● 

○ 

○ 

● 

○ 

○ 

○ 

○ 

○ 

● 

○ 

● 

○ 

○ 

● 

● 

● 

Key:   “●” investments and reforms of the component significantly contribute to the pillar;  

“○” the component partially contributes to the pillar. 

20 

 
 
 
 
 
 
 
 
 
 
 
 
Green transition 

Facilitating  a  green  recovery  is  one  of  the  main  policy  objectives  underlying  the  plan. 
Measures focus on decarbonising the industry and transport in Sweden. In particular, component 1 
contains dedicated measures to decrease process-related emissions and decarbonise the industry 
through  research  and  development  projects  and  to  support  local  and  regional  projects  on  CO2 
emission reductions, including electric charging stations. Moreover, component 1 is expected to 
help  protect  valuable  nature  and  thus  biodiversity  in  Swedish  forests  by  establishing  formally 
protected areas of nature reserves. In addition, component 5 includes investment support for energy 
efficiency  and  building  renovation,  to  reduce  primary  energy  consumption  and  carbon  dioxide 
emissions in the housing sector.  

Digital transformation 

The  Swedish  plan  has  a  strong  digital  dimension,  with  three  of  its  five  components 
contributing  to  the  second  pillar  of  the  RRF  Regulation.  A  dedicated  component  4  should 
support investment into high-speed broadband networks, with a focus on filling connectivity gaps 
in less populated areas, which is expected to increase opportunities and preserve economic activity 
in those areas. The plan is also expected to support e-government, digital public services and local 
digital ecosystems with investments into a joint digital infrastructure for public administration 

Measures in the plan are expected to foster digital skills, with a focus on professions that will 
play  a  key  role  in  the  digital  transition.  Component  2  on  education  and  training  includes 
measures to support human capital and digital skills by supporting both higher vocational education 
as well as universities and other higher education institutions. A focus is put on fields relating to 
data/IT or other areas that are expected to foster the digital transition in Sweden, which is expected 
to help re- and up-skill the labour force for the challenges and requirements of the labour market 
in a digitalised society.  

Measures fostering the green recovery are also expected to contribute to the digital transition. 
In particular, component 1 includes public support to incentivise the use of smart energy systems 
as part of building renovations, which will make best use of the synergies between the green and 
digital  transition.  Overall,  the  Swedish  plan  is  expected  to  contribute  to  pillar  2  in  all  relevant 
dimensions, with targeted measures to make both businesses, citizens, and the public sector fit for 
the digital age. 

Smart,  sustainable  and  inclusive  growth,  including  economic  cohesion,  jobs,  productivity, 
competitiveness, research, development and innovation, and a well-functioning single market with 
strong SMEs 

The plan extensively covers the third pillar as all components are expected to contribute to 
smart  and  sustainable  growth.  The  support  to  the  development  and  application  of  new 
technologies in the green domain is expected to help the Swedish economy to grow in a smart and 
sustainable way. This includes both support to research and innovation in key technologies for the 
decarbonisation of industry, as well as support to incentivise the application of new technologies, 
for instance in the area of building renovations.  

21 

 
 
 
Specific support for re- and upskilling will help ensure inclusive growth for all. By equipping 
the labour force with the necessary skills for the future (component 2), the plan will help improve 
the  labour  market  transition  and  thus  contribute  to  allow  all  citizens  to  make  best  use  of  the 
opportunities of the twin transition. A strong and competitive labour force also lays the foundation 
for  future  technological  advances  and  is  thus  fundamental  to  ensure  productivity  growth  in  the 
long-run.  

Measures aimed at tackling the demographic challenges will help ensure the sustainability of 
the Swedish economic and social model. Notably, this includes measures related to the pension 
age limit and social security and tax systems (component 3), which aim at making the Swedish 
model future-proof in light of increasing life expectancy.  

SMEs can benefit from horizontal support schemes  to help them better achieve the green 
transition. This includes the “Industry Leap” and the “Climate Leap” measures, which provide 
investment support to promote research and development projects on decarbonising the industry, 
as well as support for local and regional projects to reduce CO2 emissions. Furthermore, SMEs 
would benefit indirectly from the comprehensive measures to increase the number of study places 
in higher education and foster vocational training and education.  

Social and territorial cohesion 

Several  components  in  the  plan  support  social  and  territorial  cohesion.  In  particular,  the 
measure aimed at supporting the broadband roll-out in rural areas will help ensure that all citizens 
have access to high-speed connectivity and thus enable them to reap the benefits of digitalisation 
independently of their location (component 4). Digital connectivity is a prerequisite for an inclusive 
digital  transition  and the  expansion of high-speed broadband networks is expected to  provide a 
substantial  contribution  with  a  view  to  territorial  cohesion  in  that  regard.  Investments  to 
substantially upgrade railway in Sweden (component 1) will allow more citizens and enterprises to 
use railway as a means of transportation, thus fostering territorial cohesion.  

Social cohesion will be fostered through measures aiming at education and training, directly 
contributing to the implementation of the European Pillar of Social Rights. In particular, the 
measures targeting vocational education (component 2) are expected to have a positive impact on 
social  cohesion,  especially  for  adults  in  transition  and  for  foreign-born  individuals  looking  for 
permanent  employment.  By ensuring the long-term  sustainability of the pension system  and by 
improving the skills of staff in elderly care centers (component 3), the plan will also contribute to 
ensure the welfare of older people and thus help improve social cohesion. Measures to increase the 
housing supply (component 5) have the potential to make housing more affordable, with positive 
consequences for social cohesion.  

Health, and economic, social and institutional resilience 

The  resilience  of  the  Swedish  health  system  is  expected  to  be  improved  through  targeted 
measures in the plan. In particular, the plan includes a reform to incentivise municipalities to offer 
vocational  training  in  health-  and  social  care  in  combination  with  Swedish  language  training 
(component 2). This measure is expected to shorten the study period and foster the transition into 
employment and thus help to increase the supply of properly trained staff in the Swedish health 
and social sector.  

22 

 
 
The resilience of the Swedish economy is expected to be improved with measures tackling to 
some extent inefficiencies in the housing market. The interplay of the Swedish housing market 
and private indebtedness is a crucial factor from a viewpoint of economic resilience. The measures 
in the dedicated component 5 on the housing market are expected to contribute to addressing these 
inefficiencies, by increasing housing supply in the rental market and student housing, increasing 
competition in housing construction and reducing bottlenecks in the permit procedure.  

The plan is expected to contribute to social resilience by fostering the transition prospects on 
the labour market. To this extent, the measures aiming at re- and up-skilling both foreign and 
Swedish-born as well as increasing study places and resources of higher educational institutions 
will contribute to a competitive labour force with higher transition probabilities into and between 
jobs  and  thus  foster  social  resilience  (component  2).  Transition  into  employment  will  also  be 
fostered  through  the  reform  and  modernisation  of  the  employment  protection  legislation 
(component  2).  Measures  aimed  at  timely  addressing  the  impact  of  changing  demographics,  in 
particular  the  elderly  care  initiative  and  the  pension  age  adjustment,  will  also  contribute  to 
economic and social resilience (component 3). 

Measures to foster the digitalisation within the public administration will benefit institutional 
resilience, as it will  help prepare public institutions  for the challenges within a digitalised 
society  (component  4).  Efforts  to  combat  money  laundering  and  financing  of  terrorism 
(component  3)  will  also  contribute  increasing  institutional  resilience  by  ensuring  that  relevant 
authorities have the necessary rights and information to better enforce the regulatory framework. 

Policies for the next generation 

The Swedish plan is expected to contribute to pillar 6 through its dedicated component 2 on 
training and education. For the programme combining Swedish language training with vocational 
training within elderly care, priority will be given to recently unemployed or young people with no 
prior job experience. Additional resources for education at universities and other higher education 
institutions will also benefit the next generation, by enabling a greater number of full-time students 
and  help  match  peoples’  skills  with  demand  from  the  job  market  (including  the  Elderly  Care 
initiative in component 3). This measure is complemented by an investment scheme to increase the 
supply of student  housing (component 5).  The reform  of the  employment  protection legislation 
(component 2) is also expected to benefit those without extensive professional experience and will 
thus help increase job prospects for the younger generation.  

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Sweden,  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 
Sweden into account. This would warrant a rating of A under the assessment criterion 2.1 in Annex 
V of the RRF Regulation. 

23 

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

The plan is expected to address a significant subset of the challenges identified in the relevant 
country-specific recommendations. The plan addresses most of the outstanding country-specific 
recommendations (CSRs) from the 2019 and 2020 exercises in a satisfactory manner. It introduces 
reforms  and  investments  aimed  at  addressing  the  green  and  digital  transitions,  the  resilience  of 
healthcare, and research and development. As such, and taking into account the size of the financial 
contribution,  the  plan  contributes  to  a  large  part  of  the  economic  and  societal  challenges  that 
Sweden  faces.  However,  the  country-specific  recommendation  related  to  the  macroeconomic 
imbalances of overvalued houses and continued rise in household debt has only been addressed in 
a partly satisfactory manner. Sweden has also taken additional measures outside the scope of the 
plan that address policy challenges covered by the recommendations in 2019 and 2020, such as in 
the policy areas of anti-money laundering, research and innovation and resilience of the health care 
system. 

The plan only partially addresses the macroeconomic imbalances in the housing market and 
private debt (CSR 1 of 2019). The latest in-depth review identified overvalued house price levels 
coupled with a continued rise in household debt as house prices increased fast in 2020. The plan 
contributes  somewhat  to  addressing  these  risks  through  a  few  measures  that  aim  to  increase 
mobility and reduce housing costs. The plan has a focus on the supply-side of the housing market 
through investment subsidies for rental and student housing and easing building regulation. On the 
demand side, the initiatives leading to lower taxes on deferred capital gains should foster demand 
but  may  also  contribute  to  higher  prices,  while  they  can  be  expected  to  help  promote  housing 
mobility to some extent. In all, the measures in the plan can be expected to have only a  limited 
impact on the dynamics of the housing market and household debt.  

Measures to improve on education and skills (CSR 2.1 of 2019 and CSR 2.2 2020) are included 
in  its  plan.  The  plan  has  investment  measures  to  both  increase  the  number  of  study  places  in 
vocational training and in higher education as well as an increase in the number of training places. 
Specifically for health care, the plan foresees training for existing staff in the Elderly Care initiative 
to  increase  their  education  and  skill  level.  The  measure  modernising  labour  law,  and  adapting 
employment protection legislation, will provide further incentives to scale up human capital.  At 
the same time, additional efforts will be needed in the future to address specific further challenges, 
notably the educational disadvantage of pupils with a migrant background and growing teacher 
shortages. 

Investment  in  sustainable  transport  is  strengthened  in  the  plan,  in  particular  in  railways 
(CSR  2.2  of  2019,  CSR  2.7  and  CSR  2.8  of  2020).  The  plan  foresees  EUR  148  million  in 
investments  to  upgrade  railway  infrastructure  over  2021-2023.  The  investments  should  lead  to 
increased reliability and capacity of the railway infrastructure, supporting the transition from road 
to  rail.  Several  reforms  in  Component  1  (Green  recovery)  aim  at  increasing  the  environmental 
taxation  of  conventional  fuels,  thereby  encouraging  the  consumption  and  production  of  more 
sustainable alternatives. 

24 

 
 
The plan contains several measures to support the digital transition (CSR 2.3 of 2019 and 
CSR 2.1 of 2020). The plan includes expansion of the broadband network to more remote areas 
and the digitalisation of public administration. Investments in the broadband network will improve 
the  conditions  for  the  digital  transition  in  larger  parts  of  Sweden.  The  digitalisation  of  public 
administration directly contributes to the digitalisation of the public sector but will also make the 
use of digital services more common.  Educational measures will support the digital transition by 
enhancing  digital  skills  and  providing  skilled  labour  for  the  professions  related  to  the  digital 
transition.  The  5G  network’s  auction  in  early  2021  is  deemed  key  for  the  digital  transition  is 
addressed  outside the plan (CSR 2.6) as are the  investments  in  research  and innovation  via the 
Research and Innovation Bill financed from the national budget (CSR 2.5). 

The  plan  contains  two  measures  to  reduce  the  risk  of  the  financial  system  being  used  for 
money laundering that complement steps taken outside of the plan (CSR 3 2019 and CSR 3 
2020).  For  the  first  measure,  an  inquiry  commission  has  identified  the  remaining  gaps  in  the 
financial  supervision  to  prevent  money  laundering.  The  second  measure  addressed  an  earlier 
identified opportunity to enhance efficiency in the information exchange by establishing a database 
for holders of accounts and deposit boxes of financial undertakings that can be checked directly by 
the  supervisory  authorities.  The  information  that  financial  undertakings  are  obliged  to  make 
directly  and  immediately  available  in  the  system  will  enhance  the  effectiveness  of  financial 
supervision on money laundering. 

The plan includes measures aimed at increasing the accessibility and capacity  of the health 
care system (CSR 1.2 of 2020). The Swedish government has taken many measures outside the 
plan to address the COVID-19 crisis and started to address the limitations that became obvious 
through  the  pandemic.  In  the  plan,  Swedish  health  care  benefits  from  training  of  elderly  care 
professionals, the augmented number of study places in Vocational Education and Training (VET 
- Yrkesvux) and in introducing a protected title for assistant nurse to make health care jobs more 
attractive.  

The  plan  contributes  to  the  overall  policy  package  designed  to  use  the  pandemic  as  an 
opportunity  for  transformative  investments  (CSR  1.1  and  CSR  1.2  of  2020).  The  funds 
received from the RRF are part of a larger stimulus package designed to address the pandemic and 
make the economy fitter and more resilient. Public investments are mostly directed in the plan to 
the  green  recovery  (climate  leap,  industrial  leap,  rail  infrastructure)  with  investments  in  the 
industrial  leap  are  expected  to  contribute  to  green  innovation.  The  investment  developing  and 
establishing  a  joint  digital  infrastructure  for  public  administration  is  another,  albeit  modest, 
addition  to  public  investment.  The  aid  for  energy  efficiency  in  multi-dwelling  buildings  (green 
recovery  component),  the  broadband  deployment  investment  aid  (digitalization  and  broadband 
component) and investment aid for rental and student housing (housing component) should work 
to strengthen private investment. 

The green transition is a core element of the plan, via dedicated investments (including on 
research  and  development)  and  reforms  (CSR  2.3  2019,  CSR  2.1  of  2020  and  CSR  2.5  of 
2020). Investments envisaged in the plan aim to further decarbonize the economy with 44,4% of 

25 

 
 
spending funded by the RRF allocated to the green transition.  The plan contains investments in 
research  and  development  to  decarbonize  the  industrial  sectors  and  investments  in  local  and 
regional projects to reduce CO2 emissions. The plan also aims to reduce GHG emissions through 
investments to improve the energy performance of multi-dwelling buildings, protection of valuable 
nature and the upgrading of the rail infrastructure. The plan contains several reform measures to 
promote  the  green  transition:  an  increase  in  the  energy  tax,  adjusting  the  calculation  of  the  car 
benefit in taxation to reflect better the car’s carbon footprint and increasing the renewables shares 
in fossil fuels used by the transport sector.  

The reforms and investments of the plan are aligned with the European “flagship initiatives” 
of  the  2021  Annual  Sustainable  Growth  Strategy:  power  up  (including  the  promotion  of 
innovative  technologies  for  fossil-free  solutions  in  energy-intensive  industries),  renovate 
(including aid for energy efficiency improvements in multi-dwelling buildings as well as for rental 
and student housing), recharge and refuel (including a package of reforms that discourage the use 
of  polluting  cars),  connect  (including  the  rollout  of  rapid  broadband  services),  modernise 
(including  the  digitalisation  of  public  administration),  and  reskill  and  upskill  (including  the 
promotion of the development of digital skills).  

Taking  into  consideration  the  reforms  and  investments  envisaged  by  Sweden,  its  recovery  and 
resilience plan is expected to contribute to effectively addressing 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 Sweden. 
This  would  warrant  a  rating  of  A  under  the  assessment  criterion  2.2  in  Annex  V  of  the  RRF 
Regulation. 

Table  6:  Mapping  of  country  challenges 
recommendations and the Swedish recovery and resilience plan components[1] 

identified 

in  2019-20  country-specific 

Country challenges 

(as identified in 
Section 2) 

Associated CSR (2019-2020) and 
European Semester recommendations 

Component 
1- Green 
recovery 

Component 
2- Education 
and 
transition 

Component 
3- Better 
conditions 
for 
addressing 
demographic 
challenges  

Component 4- 
Broadband 
expansion and 
digitalisation 
of public 
administration 

Component 
5- 
Investment 
for growth 
and housing 

Macroeconomi
c imbalances in 
the housing 
market and 
household debt 

2019 CSR 1 Address risks related 
to high household debt by gradually 
reducing the tax deductibility of 
mortgage interest payments or 
increasing recurrent property taxes. 
Stimulate investment in residential 
construction where shortages are 
most pressing, in particular by 
removing structural obstacles to 
construction. Improve the 
efficiency of the housing market, 
including by introducing more 

26 

○ 

 
 
  
  
  
  
 
Country challenges 

(as identified in 
Section 2) 

Associated CSR (2019-2020) and 
European Semester recommendations 

Component 
1- Green 
recovery 

Component 
2- Education 
and 
transition 

Component 
3- Better 
conditions 
for 
addressing 
demographic 
challenges  

Component 4- 
Broadband 
expansion and 
digitalisation 
of public 
administration 

Component 
5- 
Investment 
for growth 
and housing 

flexibility in rental prices and 
revising the design of the capital 
gains tax 
2019 CSR 2 focus investment 
related economic policy on 
education and skills 
2020 CSR 2 support education and 
skills development. 

2019 CSR 2 maintaining  
investment in sustainable transport 
to upgrade the different transport 
modes, in particular railways, [2] 
2020 CSR 2 focus investment on 
sustainable transport. 
2019 CSR 2 focus investment 
related economic policy on 
research and innovation, taking into 
account regional differences 
2020 CSR 2 Foster innovation.  
2020 CSR 2 high tech and 
innovative sectors [3]  
2019 CSR 3 Ensure effective 
supervision and the enforcement of 
the anti-money laundering 
framework[4]. 
2020 CSR 3 Improve the 
effectiveness of anti-money 
laundering supervision and 
effectively enforce the anti-money 
laundering framework.[5] 
2020 CSR 1 Enhance the resilience 
of the health system, including by 
ensuring sufficient critical medical 
products and addressing the 
shortage of health workers.[6] 
2020 CSR 2 Focus investment on 
the green and digital transition, in 
particular on clean and efficient 
production and use of energy, […], 
5G networks 

Education and 
skills 

Sustainable 
transport 

Research and 
development 

Anti-money 
laundering 

Health care 

Green and 
digital 
transition 

 ● 

● 

● 

● 

● 

 ● 

● 

 ● 

● 

Key: “●” investments and reforms of the component significantly address the challenge;           “○” 
the component partially addresses the challenge 

[1] The recommendations related to the immediate fiscal policy response to the pandemic can be considered as being 
addressed  outside  the  plan.  Sweden  has  generally  responded  adequately  and  sufficiently  to  the  immediate  need  to 
support the economy through fiscal means in 2020 and 2021, in line with the provisions of the General Escape Clause.  

[2] This CSR was addressed by the adoption of measures not included in the plan. 

27 

 
 
 
  
 
 
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
 
  
  
 
  
  
  
  
 
 
 
 
 
  
[3] This CSR was partially addressed by the adoption of measures not included in the plan. 

[4] This CSR was addressed by the adoption of measures not included in the plan. 

[5] This CSR was addressed by the adoption of measures not included in the plan. 

[6] This CSR was addressed by the adoption of measures not included in the plan. 

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  

Fostering economic growth and jobs 

The plan is  expected to contribute positively to GDP growth.  The measures are frontloaded 
with an emphasis on 2021-2023, when the direct positive impact of the plan on growth is expected 
to  be  stronger  as  firms  are  expected  to  benefit  from  the  investment  incentives  and  from 
government-financed training and skilling facilities. According to the plan, additional spending is 
set to increase GDP by about 0,5% in 2021-2023, reflecting mainly the direct expenditure effects. 
From 2024 onwards, the GDP growth effect is expected to be limited, due to the expiration of the 
largest part of supportive expenditure under the RRF. Over the medium and longer term, the plan 
is  expected  to  enhance  productivity  and  contribute  to  long-term  growth.  There  is  no  national 
estimate of the long-term impact. According to the Commission’s QUEST model, the long-term 
real GDP effect is 0,1% (see box below). The plan is also expected to contribute to employment, 
notably in 2021-2022. The most significant persistent positive effects on growth, productivity and 
fiscal sustainability over the medium to long run should stem from reforms in the plan, notably 
reforms of social security and pensions and changes in labour market legislation. Their impact is, 
however, difficult to quantify and the plan does not present estimates. Overall, the plan is expected 
to actively contribute to the implementation of the EU update of the 2020 new industrial strategy.11 

Box 2: Stylised NGEU impact simulations with QUEST – Sweden 
Model simulations conducted by the Commission using the QUEST model show that the economic 
impact of the NGEU in Sweden could lead to an increase of GDP of between 0,2% and 0,3% by 
2026[1] After 20 years, GDP could be 0,1% higher. Spillovers account for a substantial part of such 
impact.  
According to these simulations, this would translate into more than 4000 additional jobs. Cross border 
(GDP)  spillovers  account  for  0,1  pps in  2026, showing  the  value  added  of  synchronised  expenditure 
across Member States (line 2). Even in a scenario with a lower productivity of NGEU funds, it would 
still lead to a significant impact (line 3).[2] 

Table 1: QUEST simulation results (% deviation of real GDP level from non-NGEU case) 

Scenario 
Baseline 
   of which spillover 
Low productivity 

2021  2022  2023  2024  2025  2026  2027  2028  2029  2030  2040 

0.1 
-0.1 
0.0 

0.2 
0.0 
0.1 

0.3 
0.1 
0.1 

0.3 
0.1 
0.2 

0.3 
0.1 
0.2 

0.3 
0.1 
0.2 

0.3 
0.1 
0.1 

0.2 
0.1 
0.1 

0.2 
0.1 
0.1 

0.2 
0.1 
0.1 

0.1 
0.1 
0.0 

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

28 

 
 
 
 
  
                                                           
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 Sweden’s GDP by 3½% in 20 years’ time[3] 
Due  to  the  differences  in the  assumptions  and  methodology,  the  results  of  this  stylised  assessment 
cannot  be  directly  compared  to  the  numbers  reported  in  chapter  4  of  Sweden’s  recovery  and 
resilience plan.  

[1]  RRF  amounts  to  roughly  90%  of  NGEU,  which  also  includes  ReactEU,  Horizon,  InvestEU,  JTF,  Rural 
Development and RescEU. 
[2] Technically, the low productivity scenario considers a significantly reduced output elasticity of public capital. 
[3] Varga, J, in 't Veld J. (2014), “The potential growth impact of structural reforms in the EU: a benchmarking 
exercise", European Economy Economic Papers no. 541.  
http://ec.europa.eu/economy_finance/publications/economic_paper/2014/pdf/ecp541_en.pdf. 

Strengthening social cohesion 

The plan addresses social disparities that have increased during the COVID-19 pandemic. 
Investments  and  reforms  in  education,  digitalisation,  and  health  are  proposed  to  address  these 
disparities, thus contributing in several ways to equal opportunities and better access to the labour 
market, in line with the guidelines of the European Pillar of Social Rights. In the short  run, limited 
distributional effects are expected once new measures are in place. However, the long-run full-
scale  positive  impact  of  the  investments  made  in  education  and  training,  going  beyond  the 
implementation of the plan, is likely to be more marked, as is inherent to investments in human 
capital. The proposed labour market reform is expected to help increase labour market chances of 
the more vulnerable groups.  

Scaling  up  vocational  education  and  higher  education  potentially  boosts  employment,  in 
particular  among  disadvantaged  groups  and  in  areas  with  labour  shortages.  Expenditure 
aimed at increasing the supply of vocational education across the country is partly directed at the 
non-EU  born  population,  which  has  a  high  share  of  people  in  a  disadvantaged  labour  market 
position  (lower  occupational  levels,  higher  barriers  of  entry  to  employment,  lack  of  relevant 
skills/education). In addition, higher education, as well as vocational education measures assign a 
strong emphasis to the digital dimension with the aim of alleviating the shortages and improving 
the  transition  opportunities  for  the  unemployed.  Together,  these  measures  should  support 
employment and productivity. 

Sweden’s  plan  contains  a  series  of  measures  that  are  expected  to  effectively  address  the 
country’s  challenges  in  the  area  of  gender  equality  and  equal  opportunities  for  all.  These 
include several reforms and investments in the area of education, training and reskilling targeted at 
young people and foreign born, in particular women. Provisions are also foreseen to support access 
to  education  for  students  with  disabilities,  for  instance  by  providing  specific  pedagogical 
assistance. Reforms and investments in the health and care sector aim at improving the quality of 
care and lives for older persons. Measures to improve skills and staffing of elderly care and the 
regulation of the profession of nurse are expected to benefit women and foreign born, who represent 

29 

 
 
  
 
 
 
the large majority of health and social workers. Investments in student housing are targeting young 
people.  While  many  measures  contribute  to  equal  opportunities  for  all,  equality  considerations 
could have been integrated even more comprehensively throughout the plan and presented more 
prominently,  for  instance  in  the  case  of  measures  dealing  with  the  green  transition  and  digital 
transformation. 

All individual investments and reforms are assessed against their impact on gender equality. 
However, Sweden does not detail the overall impact of its plan on the gender employment and 
gender pay gaps.  

Dedicated measures are addressed to the older and younger generations. The increased supply 
and quality of the long-term care services expected after the successful training period of the staff 
working in the municipal elderly care centres should positively impact the lives of the old, while 
the  special  supportive  measures  targeting  students  and  low-income  families  taken  under  the  5th 
Component (Housing), should improve the standing of these two groups in the housing market.  

Reducing vulnerability and increasing resilience 

Further progress with digital and green transition should help to improve resilience against 
external shocks. Due to its advanced digital infrastructure, Sweden was able to rely on distance 
working  and  continued  service  activity  across  several  sectors.  The  emphasis  in  the  plan  on 
measures  conducive  to  digitalisation,  such  as  broadband  expansion  give  a  further  boost  to  the 
digital transition of work that should reduce vulnerabilities to supply-chain disruptions. Measures 
on the digitalisation of public administration can increase the institutions’ ability to adjust to and 
withstand shocks. The measures to improve matching on the labour market and close skill gaps 
should help to maintain Sweden’s strong competitiveness and facilitate adjustments in the event of 
adverse  economic  circumstances.  In  addition,  and  not  least  important,  the  plan’s  emphasis  on 
environmentally  sustainable  initiatives  can  be  deemed  to  reduce  exposure  to  unsustainable 
economic activities at risk of obsolescence. In all, the plan contributes to the wider range of trends 
and  policies  that  has  put  Sweden  on  a  comparatively  advanced  trajectory  for  green  and  digital 
transitions,  promoting  an  industry  structure  heavy  in  agile  and  innovative  economic  activities, 
conducive to resilience. 

Cohesion and convergence 

The initiatives in the plan to promote learning, digitalisation and innovation, including on 
green  technologies,  are  conducive  to  territorial  cohesion  and  convergence.  In  comparison, 
regional disparities in Sweden are less marked than in several other EU countries. The plan contains 
several measures that contribute to a balanced regional development. Broadband expansion is tilted 
towards outer regions  without connections. Expanding broadband  should  improve access  to  the 
labour  market  and  scope  for  businesses  to  interact  with  suppliers  and  customers  regardless  of 
location.  Training  and  schooling  programmes  in  the  educational  component  of  the  plan  are 
accessible  in  less  densely  populated  areas  across  the  country  while  upgrading  transport 
infrastructure should also help diminish regional dispersion. Initiatives focusing on innovation and 
the green transition could provide fresh impulses to growth, jobs and innovation in parts of the 
country outside the historical economic centres, thus enhancing territorial cohesion. For example, 
the launch of fossil fuel-free steel production has propelled Sweden to global leadership in green 

30 

 
 
innovation in the steel industry. The pioneering production facilities are located in the north of the 
country, contributing to a dynamic new regional growth pole.  

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Sweden,  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 the Member State, 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 of the 
RRF Regulation. 

Box 3: Employment and social challenges in light of the Social Scoreboard 
accompanying the European Pillar of Social Rights 
Sweden performs well on most of the indicators of the Social Scoreboard supporting the European Pillar of 
Social Rights. Although it has slightly declined after the initial impact of the COVID-19 crisis, the employment 
rate remains among the highest in the EU at 81,0% (Q3 2021). There has been an increase in the unemployment 
rate of 0,9 percentage points, from 7,2% in January 2020 to 8,1% in January 2022. On the other hand, long-term 
unemployment has increased significantly, from 1.1% in Q1 2020 to 2.2% in Q3 2021.  

The  level  of  digital  skills  among  the  population  is 
very high. The good overall results reflect Sweden’s 
advanced welfare model with efficient active labour 
market  policies,  a  robust  social  protection  system, 
long-standing  and  well-established  social 
and 
dialogue.  However,  already  before  the  crisis  the 
country faced challenges in terms of increasing the 
labour  market  participation  of  the  low-skilled  and 
foreign-born, in particular women. These groups are 
also  among  the  most  impacted  by  the  COVID-19 
crisis.  In  Q3  2021,  the  unemployment  rate  of  the 
low-skilled  was  28.1%  compared  to  4.3%  of  the 
high-skilled,  while  unemployment  of  the  non-EU 
born  stood  at  22.5%  against  5%  of  those  born  in 
Sweden. 

labour  market 

Sweden  continues  to  improve  its  policies  to 
facilitate 
integration.  Public 
employment services have long been implementing 
policies  to  make  the  labour  market  more  inclusive 
and  to  encourage  enrolment  in  education  and 
training. The previously announced “intensive year” 
(intensivår) 
for  newly  arrived  migrants  was 
launched in April 2021. The intensive year is based 
on a personalised plan of activities developed by the 
Public  Employment  Service  together  with  the 
participant.  Participants  can  for  example  study 
Swedish at a  fast pace or do an intensive full-time 
internship  in  order  to  find  work  quickly.  They  are 
also  be  encouraged  to  meet  up  with  a  mentor  and 
take  part  in  other  activities  in  their  spare  time  that 

31 

Critical situationTo watchWeak but improvingGood but to monitorOn averageBest performersDynamic labour markets and fair working conditionsSocial protection and inclusionAt risk of poverty or social exclusion for children (in %) (2020)Disability employment gap (2020)Better than averageAt risk of poverty or social exclusion (in %) (2020)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 (2020)Update of 13 January 2022. 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 proposal for a Joint Employment Report 2021, COM(2020) 744 final; NEET: neither in employment nor in education and training; GDHI: gross disposable household income.Impact of social transfers (other than pensions) on poverty reduction (2020)Children aged less than 3 years in formal childcare (2020)Self-reported unmet need for medical care (2020)Housing cost overburden (2020)Equal opportunities and access to the labour marketSocial Scoreboard for SWEDENEarly leavers from education and training(% of population aged 18-24) (2020)Youth NEET(% of total population aged 15-29) (2020)Gender employment gap (2020)Income quintile ratio (S80/S20) (2020)Individuals' level of digital skills (2019) 
 
will  help  them  learn  Swedish.  After  finishing  the  Intensive  Year,  participants  will  be  given  a  certificate  of 
knowledge, which describes what they have achieved and their language and occupational skills.  

The  recovery  and  resilience  plan  submitted  by  Sweden  addresses  some  of  the  employment  and  social 
challenges relevant for the implementation of the Pillar. To foster equal opportunities and access to the labour 
market, the plan focuses heavily on VET and higher education. As there is a large skills mismatch in Sweden, with 
many of the  unemployed lacking the  necessary  skills, focusing on upskilling and reskilling is key. Some of the 
measures proposed in the plan include  increased study places in higher vocational education and regional adult 
vocational education, as well as the creation of shorter higher vocational education courses and programmes to ease 
job transitions. To ensure a better integration of migrants, the plan also includes a measure to increase compensation 
for vocational training in combination with courses in Swedish for Immigrants and Swedish as a second language. 
The plan also envisages measures to support affordable housing, with investment in construction of houses with 
special  requirements  ensuring  favourable  rental  conditions.  This  should  benefit  students,  people  in  socially 
vulnerable situations who need rental support to access the regular housing market, as well as young people below 
31 years old. However, the educational disadvantage of pupils with a migrant background and the challenges of the 
teaching profession are not addressed. 

4.4. The principle of ‘do no significant harm’ 

The Regulation establishing the Recovery and Resilience Facility provides that no measure 
included in the recovery and resilience plan should lead to significant harm to any of the six 
environmental objectives within the meaning of Article 17 of the Taxonomy Regulation12. In 
line with the RRF Regulation and the Technical Guidance on the Application of ‘do no significant 
harm’  under  the  Recovery  and  Resilience  Facility  Regulation  (hereafter  ‘DNSH  Technical 
Guidance’)13, Member States provide a ‘do no significant harm’ (DNSH) assessment, on which 
basis  the  Commission  assesses  whether  each  measure  of  the  plan  complies  with  the  DNSH 
principle. Sweden has included a detailed DNSH assessment for each measure included in its plan. 

The evidence provided on the design of measures is sufficient to conclude that no measure in 
the plan is expected to do significant harm to any of the environmental objectives. By selecting 
measures  that  either  contribute  substantially  to  environmental  objectives,  or  have  no  or  an 
insignificant foreseeable impact on environmental objectives, many measures in the plan can be 
considered DNSH compliant from the outset. This includes, for example, measures on education, 
labour  market,  public  administration  and  anti-money  laundering.  For  measures  requiring  a 
substantive DNSH assessment in accordance with the DNSH Technical Guidance (e.g. sustainable 
mobility and broad support schemes), Sweden has provided evidence and assurances substantiating 
that the measures will not lead to significant harm to any of the six environmental objectives. 

As a first step, Sweden seeks to ensure that the activities supported by the plan comply with 
DNSH  by  committing  to  the  application  of  all  relevant  EU  and  national  environmental 
legislation. The national environmental code contains provisions applicable to individuals as well 
as businesses that ensure the protection of the environment through several principles that notably 

12 The six environmental objectives comprise (1) climate change mitigation, (2) climate change adaptation, (3) 
sustainable use and protection of water and marine resources, (4) the circular economy, (5) pollution prevention and 
control, and (6) protection and restoration of biodiversity and ecosystems. 
13 COM (2021) C58/01, Technical Guidance on the Application of ‘do no significant harm’ under the Recovery and 
Resilience Facility Regulation. 

32 

 
 
 
                                                           
transpose relevant EU Directives. These include, but are not limited to, the precautionary principle, 
principles  to  prevent  or  discourage  an  activity  from  causing  harm  to  human  health  or  the 
environment, principles to save and reduce waste and energy, using renewable energy as a priority. 
The  environmental  code  also  contains  environmental  quality  standards  that  set  a  minimum 
acceptable  quality  for  soil,  water,  air  and  the  environment.  Moreover,  the  environmental  code 
stipulates  that certain  measures must be subject  to  an environmental impact  assessment, in  line 
with the Environmental Impact Assessment Directive14.  

Component 1 (Green recovery) of the plan foresees investment support in projects at local 
and regional level to reduce CO2 emissions (‘Climate Leap’) and investments in innovative 
R&D projects to reduce industrial emissions (‘Industry Leap’). For any action funded by these 
programmes  that  may  fall  under  the  EU  Emissions  Trading  System  (ETS),  Sweden  has  among 
other conditions sought to ensure DNSH compliance by showing that the selection of supported 
projects  is  conditional upon achieving GHG  emissions that are  substantially  below the relevant 
benchmarks established for free allocation15. 

With one exception, activities covered by the EU ETS are not eligible for funding from the 
‘Climate Leap’. Waste heat in industry for use in district heating is eligible as Sweden considers 
waste  heat  to  be  a  resource-efficient  way  of  meeting  heating  needs,  which  is  not  sufficiently 
incentivised by existing instruments, including the EU ETS. Waste heat is expected to indirectly 
reduce  GHG  emissions  as  it  often  replaces  fossil  fuels,  electricity  and  fuels  from  biomass  by 
feeding into the district heating network and replacing more emission-intensive heat production. 
Any such funding for waste heat shall have projected greenhouse gas emissions significantly below 
the  heat  benchmark  established  in  Commission  Implementing  Regulation  (EU)  2021/447. 
Furthermore, (i) activities and assets related to fossil fuels, including downstream use; (ii) activities 
and assets related to waste landfills, incinerators  and mechanical biological treatment plants; and 
(iii) activities and assets where the long-term disposal of waste may cause harm to the environment 
are also excluded from financing. 

Investments under the ‘Industry Leap’ may concern activities under the EU ETS but do not 
distort  the  price  signals  put  in  place  by  the  ETS.  The  objective  of  the  ‘Industry  leap’  is  to 
radically shift the industry sector to become fossil-free and contribute to the set ambitious climate 
goals  in  line  with  Sweden’s  target  of  achieving  net  zero  emissions  by  2045.  Such  industrial 
transition requires investments in completely new technologies that are costly and for which the 
allowance price in the EU ETS is currently well below what is needed for such investments. It is 
therefore considered that the ‘Industry Leap‘ is an additional policy instrument that does not distort 
the price signals put in place by the ETS. 

Moreover, the selection criteria for projects that can receive funding from the ‘Climate Leap’ 
or the ‘Industry Leap’ are sufficiently stringent to ensure that no project includes fossil fuels 
(including  downstream  use).  It  should  be  noted  that  (i)  activities  and  assets  related  to  waste 
landfills,  incinerators  and  mechanical  biological  treatment  plants;  and  (ii)  activities  and  assets 

14 Directive 2011/92/EU of the European Parliament and of the Council of 13 December 2011 on the assessment of 
the effects of certain public and private projects on the environment 
15 Benchmarks as set out in the Commission Implementing Regulation (EU) 2021/447. 

33 

 
 
                                                           
where the long-term disposal of waste may cause harm to the environment, are also excluded from 
financing.  

In order to ensure full compliance with DNSH, the plan specifies that certain measures shall 
comply with DNSH requirements as outlined in the DNSH Technical Guidance. This is the 
case, for example, for measures supporting innovative R&D projects (‘Industry Leap’) that may 
cover  installations  under  the  EU  Emissions  Trading  System  (ETS)  in  Component  1  (Green 
recovery) and broad support schemes spanning across sectors and activities (‘Climate Leap’) in 
Component  1.  The  DNSH  compliance  of  these  measures  is  included  in  the  description  of  the 
measures in the Council Implementing Decision. 

The plan also includes measures to improve the energy efficiency of buildings. Although these 
type  of  measures  have  a  positive  impact  on  the  reduction  of  emissions,  they  are  susceptible  to 
creating significant amounts of construction waste. Sweden ensures no significant harm  will be 
done to the circular economy objective by detailing in the plan for each of the measures 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.  

Taking  into  account  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Sweden’s recovery and resilience 
plan is expected to do significant harm to environmental objectives within the meaning of Article 
17 of the Taxonomy 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 of the Recovery and 
Resilience Facility Regulation. 

4.5. Green transition 

Climate target 

The Swedish plan dedicates EUR 1.46 billion to the climate objectives, which represents 44,4 
% of the plan’s total allocation in non-repayable financial support. This exceeds the minimum 
climate target of 37% as set out in the RRF Regulation. Table 7 below presents the contribution of 
all  measures  that  contribute  to  the  climate  change  objectives.  The  investments  included  in  the 
‘green‘ component (Component 1) make up for the largest share of of the total climate contribution 
of the plan. These investments contribute towards the climate change objectives through a variety 
of interventions, ranging from broad schemes supporting the decarbonization process of emission-
intensive industries and financing local / regional investments in CO2 emission reductions, to more 
specific  investments  aimed  to  improve  the  energy  efficiency  of  apartment  buildings  and  the 
upgrade  of  railways.  These  investments  are  complemented  by  reforms  which  increase  the 
environmental taxation of conventional fuels. 

The tagging is based on a correct application of the methodology for climate tracking as set 
out in Annex VI to the RRF Regulation, by identifying intervention fields, and corresponding 
coefficients for the calculation of support to climate change objectives. For broad measures, 
the  climate  contribution  is  computed  at  sub-measure  level  to  ensure  that  intervention  fields  are 
accurately  selected  and  to  avoid  any  overestimation  of  the  overall  contribution  of  individual 
measures to the climate objectives. This applies in particular to the ‘Climate Leap’ measure, with 
different 7 sub-measures representing 4 intervention fields. Whenever a selected intervention field 

34 

 
 
includes specific additional conditions, these are substantiated in the description of the respective 
measure as well as reflected by specific provisions in the milestones and targets to ensure that the 
characteristics  of  the  measures  are  conform  the  conditions  set  out  in  Annex  VI  to  the  RRF 
Regulation. The Swedish plan does not propose to increase the climate coefficient for any of the 
measures. 

Table 7: Contribution to climate objectives per measure  

1.1 

1.2 

1.3 

Measure 

Local and regional climate 
investment 

Climate investment in the 
industrial sector 

Energy efficiency in apartment 
buildings 

1.4 

Strengthened railway support 

1.9 

Protection of Valuable Nature 

5.1 

Investment support for rental 
housing and housing for students 

Cost  
(EUR mln) 

Climate contribution 
 (EUR mln) 

Climate 
contribution (%)* 

811.1 

286.4 

59.8 

148.1 

246.9 

296.3 

811.1 

260.6 

23.9 

148.1 

98.8 

118.5 

24,7% 

7,9% 

0,7% 

4,5% 

3,0% 

3,6% 

Total 

1848.6 

1461.0 

44,4% 

*  Please  note  that  the  climate  contribution  (%)  is  calculated  based  on  Sweden’s  total  allocation  
 (EUR 3.289 million) 

Green transition 

The  recovery  and  resilience  plan  contributes  to  Sweden’s  green  transition,  addresses  the 
related challenges and is well aligned with the priorities of the European Green Deal and its 
2030 climate target plan as well as the goal to make the EU climate-neutral by 2050. In this 
regard, the green component aims at tackling challenges to Sweden’s objective of achieving carbon 
neutrality  by  2045.  The  measures  included  in  the  component  will  increase  investments  in  the 
climate  transition  of  industry  as  well  as  energy  efficiency  in  housing,  encourage  sustainable 
transport modes and restore biodiversity in forests.  

The  plan  has  a  strong  focus  on  sector-specific  measures  to  decarbonize  industry  and 
transport, and contributes towards meeting the Commission’s guidance to Sweden as set out 
in  the  National  Energy  and  Climate  Plan  (NECP).  The  industry  and  transport  sectors  are 
considered  priority  sectors  for  climate  mitigation  in  the  NECP  and  are  also  the  main  targeted 
sectors for the green transition in the Swedish plan. The green component contains measures that 
aim to decrease the quantity of process-related emissions, which are relatively expensive to reduce 
since  the  technology  is  not  readily  available  on  the  market  today.  In  view  of  this,  the  Swedish 
recovery and resilience plan recognizes a need for further research, innovation, demonstration and 
implementation  of  such  technological  solutions  on  a  larger  scale.  The  plan  aims  to  meet  this 
challenge  by  increasing  the  resources  available  for  the  ‘Industry  Leap’  measure,  an  existing 
investment scheme aiming to decarbonise industry via the promotion of research and development 

35 

 
 
projects.  The  component  also  increases the resources available for the Climate  Leap to  support 
local and regional projects that reduce CO2 emissions, such as electric charging stations. Lastly, 
the component also contains a package of reforms that discourage the use of polluting cars, which 
are part of a broader green tax reform aiming to shift taxation from labour to the environment. The 
measures are expected to contribute to reaching the Green Deal objectives to support industry to 
invest in innovation, become global leaders in the green economy, and roll out cleaner, cheaper 
and healthier forms of private and public transport16. 

The plan also includes measures to improve the energy efficiency of buildings by providing 
aid for energy efficiency improvements in multi-dwelling buildings as well as for rental and 
student housing. These measures are expected to help reducing carbon dioxide emissions in the 
housing sector. The sector emits 11 million tonnes of carbon dioxide per year, mainly coming from 
electricity  and  space  heating  in  homes.  The  two  investments  in  energy  efficiency  and  building 
renovation correspond with the overall objectives of the European Green Deal and the measures 
are expected to result in average primary energy savings or greenhouse gas reduction by at least 
30%. 

With  respect  to  the  plan’s  contribution  to  tackling  environmental  challenges,  including 
biodiversity,  the  measures  in  the  plan  introduce  an  adequate  level  of  environmental 
mainstreaming.  The  plan  responds  to  some  of  the  major  challenges  for  Sweden  in  terms  of 
environmental  protection,  including  decreasing  emissions  in  industry  and  providing  support  to 
sustainable transport with measures such as the ‘Industry Leap’ and the investment in railways. 
These  measures  will  benefit  amongst  others  air  quality.  The  energy  efficiency  of  buildings 
measures foreseen by the plan as well as some of the projects envisaged by the ‘Industry Leap’ are 
expected to have a positive impact on the circular economy. The ‘Protection of Valuable Nature’ 
measure is expected to directly support the objective of preserving biodiversity, by establishing 
nature reserves for the protection of valuable natural habitats, including forests. This measure is 
especially appropriate given that more than half of Sweden’s territory is covered by forests and 
Sweden has the largest forest area of all EU Member States.  

The  measures  in  the  recovery  and  resilience  plan  will  help  Sweden  to  leverage  the  green 
transition and introduce changes to the economy with lasting impacts. The investments are 
expected to lay the ground for sustainable infrastructure and housing. The reforms are expected to 
contribute to a lasting change in production and consumption, which should in turn contribute to a 
sustainable  economy  in  line  with  Sweden’s  long-term  strategy.  In  particular,  the  reforms  and 
investments  in  sustainable  transport  are  expected  to  contribute  to  significant  reductions  in 
greenhouse-gas emissions and air pollution from transport, thus ensuring a better environment for 
people and better conditions for economic operators both in the short and long term. 

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

16 See European Commission, The European Green Deal, COM(2019) 640 final, 11.12.2019.  

36 

 
 
                                                           
4.6. Digital transition  

Digital tagging 

Reforms and investments contributing to digital objectives account for 20,5% of the plan’s 
total allocation. Three out of the five components in the plan contribute to digital objectives. A 
substantive  contribution  stems  from  the  measures  in  the  dedicated  component  4  on  broadband 
expansion and digitalisation of public administration.  In addition, investments related to  energy 
efficiency of buildings in component 1 (green recovery) as well as measures related to digital skills 
in  component  2  (education  and  training)  are  expected  to  contribute  to  the  digital  transition  or 
address the challenges resulting from it.  

The plan correctly follows the methodology for digital tagging 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  measure  (the  table  in  the  Annex 
presents  the  detailed  application  of  the  digital  tagging  methodology).  The  choice  of 
intervention fields for the digital transition is well justified and reflects the nature, focus, objective 
or expected outcome of the investments. The plan does not propose an increase in coefficients.  

Table 8: Contribution to digital objectives per measure  

1.3 

2.3 

2.4 

4.1 

Measure 

Energy efficiency in apartment 
buildings 

More study places in higher 
vocational education 

Resources to meet demands for 
education at universities and other 
higher education institutions 
Joint public administration digital 
infrastructure 

4.2 

Broadband expansion 

Total 

Cost  
(EUR mln) 

Digital contribution 
(EUR mln) 

Digital 
contribution (%)* 

59.8 

104.3 

307.7 

20.7 

464.2 

956.7 

23.9 

41.7 

123.1 

20.7 

464.2 

673.6 

0,7% 

1,3% 

3,7% 

0,6% 

14,1% 

20,5% 

*  Please  note  that  the  digital  contribution  (%)  is  calculated  based  on  Sweden’s  total  allocation  
 (EUR 3.289 million) 

Digital transition 

The plan contains several measures that are expected to contribute to the digital transition 
and to address challenges resulting from it in a lasting manner. A substantial share of the digital 
expenditure  will  support  the  expansion  of  broadband  connectivity.  The  plan  will  also  support 
digital  public  services  and  local  digital  ecosystems  with  investments  into  a  joint  digital 
infrastructure  for  public  administration  and  investments  into  digital  technologies  to  support  the 
energy efficiency of buildings. Finally, the plan will support digital skills and thus human capital 

37 

 
 
 
accumulation  with  measures  to  increase  study  places  in  higher  vocational  education  and  by 
increasing the necessary resources for universities and other higher education institutions.  

Investments  and  reforms  also  link  to  the  following  flagships  as  put  forward  in  the  2021 
Annual  Sustainable  Growth  Strategy:  connect  (rollout  of  rapid  broadband  services), 
modernise  (digitalisation  of  public  administration),  reskill  and  upskill  (supporting 
development  of  digital  skills)  and  renovate  (promotion  of  digital  technologies  to  increase 
energy  efficiency  of  buildings).  The  measures  in  the  plan  are  also  expected  to  contribute  to 
strategic priorities identified at EU level and reaffirmed in the recent communication on Europe’s 
Digital Decade17: skills, infrastructures, and digitalisation of public services. 

The actions put forward in the plan are coherent with the relevant national strategies and 
plans in the digital domain. The measures in the digital domain are consistent with  Sweden’s 
Digital Strategy, launched by the Government in 2017. The overall goal is for Sweden to be world 
leader in the digital transformation. In particular, the strategy sets objectives in the area of digital 
skills, digital security, digital innovation, digital infrastructure and digital leadership. Measures in 
the plan correspond to each of these dimensions. The measures put forward in the plan in the area 
of broadband connectivity are also coherent with the national broadband strategy, which includes 
the  that  95%  of  all  households  and  businesses  should  have  access  to  broadband  at  a  minimum 
capacity of 100 Mbps by 2020. Furthermore, by 2025 all of Sweden should have access to high-
speed broadband, according to the strategy. 

Investments in digital infrastructure are expected to reduce connectivity gaps and to meet 
the needs of an increasingly digital society. Given that Sweden has an overall well-developed 
broadband  infrastructure,  financial  support  should  be  used  to  accelerate  broadband  roll-out  in 
sparsely populated areas and to close remaining connectivity gaps. To that aim, Sweden aims to 
invest in fixed high-speed broadband networks in areas where access would not be provided on 
commercial basis alone.  

RRF funding would be used to foster digital skills and address labour shortages in specific 
professions. Within the component “Education and training”, investments are planned to be made 
to increase the number of study places in higher vocational education, with a special focus on fields 
of data/IT or other areas that contriute to the digital transition. In addition, Sweden  aims to use 
RRF  funds  for  investments  to  scale-up  the  education  at  universities  and other  higher  education 
institutions, with a substantive share going to programmes that increase digital skills.  

Sweden aims to support the digitalisation of its public administration. Investments should be 
financed  to  develop  new  digital  services  and  upgrading  and  modernising  existing  ones.  In 
particular, Sweden aims to develope a national framework for basic data, new and improved digital 
services, as well as elements for the exchange and handling of information and a common trust and 
security framework. This would lead to standardised solutions for citizens and businesses across 
the public administration.  

Finally,  the  Swedish  plan  aims  to  foster  synergies  between  tackling  the  green  and  digital 
transition. Investments in the component on the green recovery aim to support the use of digital 

17 COM(2021) 118 - 2030 Digital Compass: the European way for the Digital Decade, 9 March 2021 

38 

 
 
                                                           
technologies  to  increase  energy  efficiency  of  buildings.  In  particular,  a  public  support  scheme 
should incentivise property-owners to renovate multi-dwelling buildings and apply smart energy 
systems as part of the renovation effort.  

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 2.6 of 
Annex V of the RRF Regulation. 

4.7. Lasting impact of the plan 

The  reforms  and  investments  in  the  plan  are  expected  to  have  a  lasting  impact  over  the 
medium  and  longer  term  on  policies  by  permanently  enhancing  innovation  capacity, 
environmental  sustainability,  human  capital,  digital  skills  and  labour  force  participation. 
Effects  of  reforms  should  contribute  positively  to  higher  employment  levels,  improved  human 
capital  formation  and  an  extension  of  working  life,  and  to  prudent  long-term  fiscal  positions. 
Further,  through  competence  development  and  labour  market  inclusion,  the  plan  contributes  to 
improving social cohesion and inclusion.  

The  implementation  of  the  plan’s  measures  is  expected  to  foster  structural  change  in  the 
economy.  For  example,  the  reform  of  environmental  taxes  raises  the  price  of  environmental 
damage and increases the  share of environmental taxes,  contributing to  climate goals  and other 
environmental  goals,  thus  accelerating  the  green  transition  of  the  economy.  The  promotion  of 
innovative technologies for fossil-free solutions in energy-intensive industries (‘Industry  Leap’) 
should have a long-lasting impact, aimed at accelerating growth of emerging sectors and creating 
further opportunities for sustainable growth.  

The digitalisation of public services and administration is expected to work towards a modal 
shift in communication between authorities and the public. This constitutes progress towards 
creating  the  digital  public  sector  of  the  future  by  a  continuous  modernisation  of  the  digital 
infrastructure, meeting the needs of all citizens and businesses, and strengthening connectivity. The 
green  and  digital  elements  of  the  plan  support  the  green  transition  and  promote  ICT-driven 
innovation. Raising the age limits in pension, social security and tax systems in accordance with 
the change in life expectancy should help maintain the sustainability of public finances.  

Several  components  in  the  plan  support  social  and  territorial  cohesion  and  convergence, 
which is  expected to have an  impact  also  in the long term.  The broadband measure is  tilted 
towards  outer  regions  (the  regions  still  not  having  broadband  connection)  and,  thereby,  helps 
promote regional cohesion in relation to less densely populated areas across the country. This will 
enable  a broader public  to  take part in  the upward social  and  economic  convergence driven by 
digitalisation. The investments in education, largely targeting vocational education, including for 
adults and in combination with Swedish for immigrants and Swedish as a second language, can be 
expected to have impact on social cohesion and integration. 

Promoting  growth  and  employment,  strengthening  social  and  regional  cohesion  and 
supporting green and digital transitions could be singled out as the most important envisaged 
results of the plan, with specific measures such as the adjustments of the age limits in pension 

39 

 
 
and social security systems, investments made in vocational, higher vocational and tertiary 
education, labour market reform, broadband expansion and efforts towards the reduction of 
the  GHG  emissions  emerging  as  particularly  relevant.  Notwithstanding  its  limited  envelope 
(around 0,7% of the 2019 GDP), Sweden strikes an appropriate balance between investments and 
reforms, allowing for lasting impact on certain environmental, economic, and societal areas. 

Structural changes in administration and institutions 

Structural  changes  in  administration  and  institutions  are  expected  to  take  place  once  the 
projects presented under the investment “Joint public administration digital infrastructure” 
will be carried out. With the aim of enhancing the efficiency, security, and interoperability of the 
public administration’s digital infrastructure, the investment will work towards a modal shift in the 
communication between the citizens and the relevant public authorities, marking progress towards 
a more integrated approach in data management. 

Structural change in policies 

Changes in fiscal policy follow from the context imposed by demographic factors. Sweden has 
maintained a disciplined budgetary policy over a sustained period, notable in this regard being a 
consolidated  gross  public  debt  anchor  of  35%,  a  surplus  target  for  the  general  government,  an 
expenditure ceiling for the central government, and the requirement for the local governments to 
pursue balanced budgets. However, in the absence of reforms, the demographic trend of increased 
life expectancy, coupled with the slow-paced growth in working-age population, will put a strain 
on the public pension system, affecting the sustainability of public finances. To mitigate the risks 
posed by this trend, Sweden has included within the framework of its recovery and resilience plan 
non-funded  reforms  aimed  at  ensuring  a  prudent  medium  and  long-term  fiscal  position.  The 
“Adjusted age limits in social security and tax systems” reform aims at: (1) lengthening the working 
life by increasing the minimum age limits for retirement and tying them to a benchmark age aligned 
with average life expectancy and; (2) expanding the scope of the social security system by aligning 
the contributions age limits with those for retirement. Such adaptations to pension, social security 
and tax systems in accordance with changes in life expectancy should thus help improve the long-
term  sustainability  of  public  finances  The  foreseen  cumulative  impact  of  this  reform  is  a  gross 
government debt reduction by EUR 1.6 billion in 2027 (around ¼% of GDP).  

Measures under the green component imply changes in environmental policy which are also 
deemed to have durable effects. The tax incentives framework will be  influenced for  years to 
come  by  the  new  reforms  designed  to  reduce  greenhouse  gas  emissions.  Regulations  requiring 
biofuels to be blended in conventional fuels (“Changes in the reduction of fossil fuels obligation”), 
the gradual phasing-out of the energy tax reduction on fuels consumed for heating or the operation 
of  stationary  engines  (”Adjustments  in  the  reduction  obligation  of  energy  tax  on  fuel”),  and 
downwards adjustments of the taxable benefits of owning a personal car (“Adjusted taxable benefit 
rates for passenger cars”) are expected to contribute to lower fossil fuels consumption, a reduced 
number of cars, less road congestion, and higher revenue from environmental taxes.  

Other lasting impacts 

Beyond the structural changes envisaged in terms of institutional, administrative, and policy 
framework, some societal aspects and part of economic activity are expected to be positively 

40 

 
 
impacted in the long-term. The investments made under the educational component are expected 
to bring a lasting impact on productivity and social cohesion through contributing to a higher stock 
of human capital and improved matching in the labour market. RRF funds dedicated to more study 
places in regional and higher vocational education centres, and reforms for scaling up the education 
at universities and other higher education institutions, should support labour force participation and 
productivity  (with  special  attention  for  individuals  coming  from  the  lower  end  of  the  income 
distribution and for the non-EU born). An example of a green transition with long-lasting impact 
is the promotion of innovative technologies for fossil-free solutions in energy-intensive industries, 
that  will  accelerate  growth  of  emerging  sectors,  creating  further  opportunities  for  sustainable 
growth.  

Furthermore,  given  the  fact  that  the  broadband  roll-out is  directed  towards  more  remote 
areas (the regions still not having complete broadband coverage), regional cohesion should 
be positively impacted. With investments made in human capital for the staff working in elderly 
care centres across the country, the long-term care safety and quality of services are expected to 
improve. Lastly, measures to secure an increased supply of new houses and reduced transaction 
costs are expected to contribute to a better functioning housing market. However, more ambitious 
additional efforts aimed at addressing the existing imbalances stemming from household debt and 
the housing market  with a wider range of instruments  would help  limit  risks to  a  balanced and 
sustainable growth path over the longer term. 

Taking into consideration all reforms and investments envisaged by Sweden in its Recovery and 
Resilience plan, their implementation is expected, to a large extent, to bring about a structural 
change in relevant policy areas and to have a lasting economic and societal impact. This warrants 
a rating of A under criterion 2.7 in Annex V to the RRF Regulation. 

4.8. Milestones, targets, monitoring and implementation 

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

The  implementation  of  Sweden’s  recovery  and  resilience  plan  will  be  based  on  Sweden’s 
regular system of budgetary management and governance. The existing statutes and decisions 
governing the measures in the plan assure that there are already requirements for the authorities to 
monitor and verify the correct use of disbursed public funds. In addition, the Swedish government 
is  committed  to  introducing  certain  organisational  changes,  which,  together  with  the  existing 
system, will create robust processes and structures to protect the financial interests of the Union.  

The bodies implementing the plan are either national authorities or state agencies that are 
responsible for the implementation of policy in certain thematic areas. These authorities and 
agencies enjoy a high degree of autonomy and have resources allocated to them through the regular 
budgetary process. One or more authority/agency will be tasked with the implementation of each 
reform  and investment,  will have the responsibility to  ensure the achievement of the respective 
milestones and targets and will report to the government on progress achieved and on associated 
audit and control aspects. The government will take the necessary decisions to adapt the regulatory 
framework  and  give  authorities  the  necessary  additional  mandates  to  ensure  that  measures  are 
implemented in accordance with the RRF Regulation. The government will also ensure that the 
authorities have sufficient financial resources to carry out their tasks.  

41 

 
 
Milestones and targets 

The plan includes 23 milestones and 33 targets that appropriately reflect the lifecycle of the 
measures. The timing of the milestones and targets is front-loaded towards the first four years of 
the period that the plan covers, with 82% of the milestones and targets relating to 2020-2023. The 
milestones and targets that will only be met after 2023 mainly concern demand-driven schemes.  

The milestones and targets in the plan are clear and realistic and the proposed indicators are 
relevant, acceptable and robust. Milestones and targets are realistic and in line with the costing 
estimates  provided  by  Sweden.  The  number  of  milestones  and/or  targets  per  measure  (ranging 
between one and five) is a realistic reflection of the different stages of implementation of reforms 
and investments. Milestones mostly concern reforms taking the form of a legal act and refer to the 
entry  into  force  of  a  new  piece  of  legislation  to  capture  the  actual  implementation  of  new 
provisions. The targets generally refer to concrete outputs such as the number of registered students 
in  higher  education,  the  kilometers  of  railway  upgraded  and  the  number  of  buildings  having 
broadband access. Only a few targets relate to the budgetary execution of allocated funds. These 
targets concern investments having dedicated budgetary envelopes that are based on future calls 
for tenders. Given that the precise content of these measures is often decided at a later stage of 
implementation and the number of beneficiaries is not known ex-ante, final targets are based on 
the completion of the calls and financing decisions permitting the funds to be contracted.  

The level of ambition for the proposed milestones and targets is adequate, reflects the cost 
estimates  and  takes  into  account  potential  risks  of  delays  in  the  implementation  of  each 
measure. This also applies to measures characterised by higher levels of uncertainty concerning 
their  outcome,  such  as  demand-driven  schemes  and  investments  pertaining  to  research  and 
development  projects.  To  ensure  the  successful  achievement  of  these  measures,  intermediate 
milestones and targets have been added to enable Sweden to take corrective actions early on in the 
implementation process if necessary.  

Overall organisational arrangements  

The Swedish National Financial Management Authority (ESV) is entrusted with the task of 
to  monitor  and  audit  the  achievement  of  the  milestones  and  targets.  The  authority  is 
responsible for (a) collecting information on the achievement of milestones and targets from the 
authorities responsible for the respective measures in the Swedish recovery and resilience plan, (b) 
examining  whether  the  reported  targets  and  milestones  are  met,  (c)  carrying  out  audits  on  the 
measures  included  in  the  plan,  and  (d)  providing  the  relevant  information  to  the  Swedish 
government. In addition, state authorities are required to submit a management declaration to the 
Government  once  per  year,  as  well  as  to  report  on  the  progress  of  the  relevant  milestones  and 
targets.  

The  arrangements  proposed  by  Sweden  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 of the RRF Regulation. 

42 

 
 
4.9. Costing  

Sweden has provided individual cost estimates for all investments and reforms in its recovery 
and resilience plan for which it requested funding through the RRF. The costing information 
and  supporting  evidence  provided  by  Sweden  is  sufficient  to  consider  that  costs  are  overall 
reasonable, plausible, do not include costs covered by existing or planned EU financing and are 
commensurate  to  the  expected  economic  and  social  impact  of  the  envisaged  measures.  For  the 
majority  of  measures  included  in  the  Swedish  plan,  Sweden  provided  detailed  information  and 
evidence  on  costs  using  the  standard  template  tables,  which  was  supplemented  by  separate 
documents  including  more  elaborate  descriptions  of  the  methodology  underlying  the  cost 
calculations  as  well  as  the  budgetary  implications  of  measures.  Sweden  did  not  provide  an 
independent validation for any of the cost estimates proposed. 

The reforms and investments included in the Swedish recovery and resilience plan comply 
with the eligibility criteria set out in the RRF Regulation. All costs supported by the RRF are 
incurred for reforms and investments (to be) implemented after 1 February 2020 and according to 
the agreed milestones and targets no RRF funding is to be requested after 31 August 2026. Value-
added tax (VAT) is not part of the cost estimates and costs that could have a recurrent nature are 
not included in the plan.  

Reasonable costs 

Sweden provided sufficient information to justify the reasonability of the cost estimates of a 
significant majority of measures. The evidence supporting cost estimates provides a reasonable 
explanation of the key cost drivers of the proposed measures, even though the degree and depth of 
the evidence provided varies across measures. Sweden mostly relied on the costing information of 
similar past or parallel projects as a basis for deriving cost estimates. The Swedish plan contains a 
number  of  demand-driven  schemes,  that  are  characterized  by  having  a  certain  budget  to  be 
allocated to final recipients on the basis of calls for interest or proposals, for which ex-ante cost 
estimations are less obvious. In support of these measures, Sweden provided evidence showing that 
the projected number of recipients and the overall amount to be spent is in line with the funding 
needs of the sectors targeted.  

Plausible costs 

The  estimated  total  costs  of  the  Swedish  recovery  and  resilience  plan  are  in  line  with  the 
nature and type of the envisaged investments. For the majority of measures included in the plan, 
Sweden  has  provided  information  on  comparative  and/or  historical  measures  in  support  of  the 
plausibility of key cost drivers. Nevertheless, in a limited number of instances the comparability of 
past  projects  to  the  ones  proposed  in  the  plan  could  not  be  established.  Depending  on  the 
significance of the shortcomings identified, these measures, representing a minority, are assessed 
as having “low” or “medium” plausibility.  

No double Union financing 

Sweden has indicated for each individual measure that the costs to be financed by the RRF 
will not be funded at the same time by other Union funding sources. In a dedicated chapter of 
the Swedish recovery and resilience plan as well as in the technical annex attached to the plan, 

43 

 
 
Sweden  provides  the  assurance  that,  to  the  extent  that  procedures  for  the  prevention  of  double 
funding are not already present within the existing regulatory framework governing the measures 
in the plan, such procedures will be put in place to ensure that the reforms and investments included 
in the plan do not finance the same costs as other Union funds.  

Commensurate and cost-efficient costs 

The total estimated cost of the Swedish recovery and resilience plan is commensurate to the 
expected social and economic impact of the envisaged measures. The plan is expected to address 
a significant subset of challenges identified in the European Semester, including country-specific 
recommendations (CSRs) and previous Semester country reports. Furthermore, the plan contains 
measures that support economic growth and economic cohesion in an inclusive manner including 
to a certain degree measures aimed at reducing inequalities in vocational education and enhancing 
the integration of vulnerable groups in the labour market. Moreover, the plan addresses weaknesses 
of the Swedish economy, boosting growth potential, stimulating job creation and mitigating the 
adverse effects of the crisis.  

The justification provided by Sweden on the amount of the estimated total cost of the recovery and 
resilience  plan  is  to  a  medium  extent  reasonable,  plausible,  in  line  with  the  principle  of  cost-
efficiency and is commensurate to the expected national economic and social impact.  

Sweden 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  

A robust national internal control system should ensure the protection of the EU financial 
interests  (prevent,  detect  and  correct  fraud,  corruption,  double  funding  and  conflicts  of 
interest), as well as ensure the accuracy of the data underlying milestones and targets.  

Robustness of internal control system and distribution of roles and responsibilities  

The internal control system as set out in its plan is based on robust processes and structures. 
This includes clarity on the roles and responsibilities of the actors (bodies/entities) for control and 
audit,  assurance  that  the  relevant  control  functions  are  appropriately  segregated  and  that  the 
independence of actors performing audits is ensured. In the decentralised Swedish system it is the 
government  that  decides  on  the  policies  while  specific  government  departments,  executive 
agencies, local bodies and other public entities involved in the execution of policies will be given 
a specific mandate and get the resources allocated to allow them to pursue their obligations. The 
Parliament has to endorse these by agreeing on the budget acts (including amendments).  

The implementing bodies are either national authorities (at central, regional, local level) or 
state  agencies/bodies  responsible  for  implementation  in  certain  policy  areas.  These 
implementing  entities  are  allocated  resources  as  foreseen  in  the  budget,  are  given  a  specific 
mandate on the task they are required to execute and must implement their activities in a highly 

44 

 
 
independent manner within the limits of attributed resources and following the specific executive 
mandates delegated by the government, with ensuing accountability and reporting obligations. This 
means that each implementing body bears responsibility for audit and control aspects in fulfilling 
their  tasks.  The  decentralised  system  of  execution  implies  a  variety  of  control  systems  and 
dedicated repositories.  

The  coordination  and  preparation  requests  for  payment  and  their  annexes  is  the 
responsibility of the Ministry of Finance. The central coordinating capacity for the Swedish plan 
is the international and economic department within the Ministry of Finance. To ensure coherence 
in the implementation of the plan and assist the Ministry of Finance with its overall coordination 
duties, the overarching audit authority is the Swedish National Financial Management Authority 
(ESV). To allow ESV to fulfil these tasks, specific mandates have been granted by government 
decision since the submission of the plan. ESV has been given the authority to obtain information 
on the achievement of milestones and targets from the  implementing bodies responsible for the 
respective measures in the plan; carry out audits on the measures in the recovery plan and provide 
a summary of these. Moreover, ESV has been tasked to develop an overarching audit strategy for 
RRF execution. The central coordinating capacity within the Ministry of Finance is responsible for 
handling  and  ensuring  a  central  reply  to  requests  for  information  and  access  to  data  on  final 
recipients. The  collection  and  storage  of  such  data  is  ensured  by  the  authorities  responsible  for 
implementing the RRP. 

Allowing  these  mandates  to  be  fully  functional  for  requests  for  payment  requires  further 
adaptations  to  regulations  and  mission  statements  of  the  implementing  bodies.  These 
adaptations had to be formalised within the Swedish system, by giving mandates to the various 
authorities to report on objectives, milestones and targets to ESV and to the central coordinating 
capacity within the Ministry of Finance, to provide the associated management declarations and to 
give visibility to Union funding. For these purposes, additional milestones have been defined and 
added to the plan.  

The National Audit Office (NAO) will also support assurance with their recurrent audits on 
whether  the  implementing  bodies  comply  with  directives  and  rules,  whether  they  achieve 
their objectives and whether government action is effective and efficient. However, the NAO 
acts  independently  from  the  government  in  executing  its  mandate  given  by  Parliament  and  is 
therefore  not  directly  responsible  for  ensuring  compliance  in  executing  the  requirements  of  the 
RRF.  

Adequacy of control systems and other relevant arrangements  

The  control  systems  in  place  are  adequate,  subject  to  the  implementation  of  additional 
measures  to  enhance  coordination  and  clarify  the  mandates  of  all  entities  involved  in  the 
implementation of the plan. The plan together with its technical annex and additional information 
provided  (including  details  on  the  adjusted  mandates  for  ESV  and  other  implementing  bodies) 
describes how the control system and other arrangements (including audit) will prevent, detect and 
correct fraud, corruption and conflicts of interest when using funds provided by the RRF.  

Several  legal  acts  underpin  the  Swedish  control  systems  including  the  administrative 
procedures Act, budget circular, budget law, public access to documents provisions, as from 
2021 the register of public contracts, freedom of whistle-blowers and freedom of press Act, 

45 

 
 
as well as the public procurement anti-corruption law. Each implementing body has to follow 
the Internal Audit Ordinance and the Ordinance (2007: 603) on internal governance and control. 
Since  1999,  authorities  managing  EU  funds  have  worked  (and  will  continue  working)  closely 
within the framework of the Council for the Protection of the European Union’s Financial Interests 
(SEFI). The SEFI Council is responsible for coordinating measures within Sweden to prevent fraud 
and other misuse of EU-related funds.  

These  ordinances  and  legal  acts  are  in  place  to  prevent  and  detect  irregularities,  fraud, 
corruption and conflict of interest and to avoid double funding. Taken together, the systems in 
place appear adequate, on fulfilment of the additional specific milestones such as the one for the 
ESV authorising it to obtain all necessary data on the achievement of milestones and targets. The 
Ministry  of  Finance  is  responsible  for  ensuring  a  central  reply  to  requests  for  information  and 
access  to  data  on  final  recipients  from  information/data  provided  bythe  implementing  bodies. 
Sweden  makes  use  of  the  central  government  Accounting  system  HERMES  to  capture  data  on 
milestones and targets, but does not have a central repository for data on final recipients, which 
renders it more difficult for the ESV to consolidate the data from the implementing bodies for the 
purpose of verification of data reliability, double funding, reporting and audits. 

Adequacy of arrangements to avoid double EU funding  

Several  elements  of  the  existing  Swedish  governance  system  reduce  the  risk  of  double 
funding. The plan covers the responsibilities of several government councils. Decisions are taken 
jointly by the government, which means that no government decision can be taken until all relevant 
ministries  have  been  consulted,  and  all  agree  on  the  content  and  consequences  of  the  specific 
decision. The Government decides on the prescriptions for each authority’s activities. In addition, 
the  state  budget  is  divided  into  appropriations  and  appropriations  may  not  have  overlapping 
activities.  Furthermore,  there  is  a  good  cooperation  between  the  authorities  responsible  for  the 
implementation of the measures in the plan. Under the Authority’s Ordinance, the authorities are 
to continuously develop their activities and to collaborate with each other and other actors involved 
to deliver the benefits that can be gained for individuals and for the State as a whole. Nevertheless, 
an enhanced degree of coordination and demarcation of responsibilities will be required to ensure 
a coherent implementation of the plan. 

For this purpose, managing authorities have been issued specific additional mandates to the 
implementing  bodies  responsible  for  managing  and  monitoring  the  use  of  EU  funds  in 
Sweden,  in  particular  RRF  funds,  through  enhanced  cooperation.  In  order  to  avoid  double 
funding, projects financed by other EU funds must report on any links with other EU programmes 
and applications must certify that no EU grant has been received to cover the same costs. Applicants 
must  immediately  inform  the  authorities  if  there  are  simultaneous  applications  and  grants  from 
different sources covering the same action or the same project.  

Where there is a risk of double financing procedures will be put in place and measures taken 
to ensure that the reforms and investments included in the recovery plan do not finance the 
same costs as  other EU fund and that access  to data on final  recipients is  ensured.  As the 
implementation of the plan is the direct responsibility of the authorities involved, the implementing 
bodies  will  be  tasked  with  setting  up  appropriate  systems  to  avoid  double  financing  and  for 
thorough checks on beneficiaries.  

46 

 
 
The Swedish internal and external control systems which will be overseen by the ESV, and 
to which the NAO contributes in its own role, will further reduce the risk of double funding. 
The authorities responsible for the implementation of the plan are thus judged to be able to comply 
with the EU acquis on the protection of the Union’s financial interests. The specific audit mandate 
to the ESV includes examining whether established systems and processes contribute to reliable 
management in accordance with the applicable regulations, which implies that measures shall be 
in place to prevent and manage fraud, conflicts of interest and double funding, and that reported 
results are reliable. The arrangements to avoid double funding are therefore assessed as adequate, 
taking into account the milestone for the audit strategy for ESV.  

Legal empowerment and administrative capacity of control function  

The  plan  provides  adequate  information  on  all  key  areas  covering  the  empowerment  and 
administrative capacity of the lead coordinating capacity within the Ministry of Finance and 
the  main  coordinating  audit  and  control  body  (ESV).  The  plan  includes  milestones  on  the 
formalisation of legal mandates and on adaptations needed of the regulations and missions covering 
the activities of the implementing bodies. These need to be fulfilled for the control and audit system 
to be adequate and functioning. Budget reinforcement has been obtained in order for the ESV to 
cope with the additional tasks.  

Due to the legal setup in Sweden, many of the new mandates and legal adaptations for the 
implementing  bodies  have  been  formally  adopted  by  Parliament  through  the  budgetary 
procedure  by the end of 2021.  

The arrangements proposed by Sweden 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  conditional  on  the  completion  of  the  additional 
milestones set. This warrants a rating of A under the assessment criterion 2.10 of Annex V of the 
RRF Regulation. 

4.11 Coherence 

The plan is coherent across its components, with consistent reforms and investments. There 
are no instances of proposed measures contradicting or negatively affecting each other. The 
measures in all components contribute to stimulating the Swedish economy and promoting a green 
recovery.  The  reforms  underpin  and  complement  the  planned  investments.  The  reforms  and 
investments  in  the plan are coherent  and mutually  reinforcing. They often aim at  achieving the 
same or complementary objectives for the challenges that are covered in the plan. For example, the 
measures in component 1 (green recovery) form a framework for a number of other measures in 
the plan, thereby creating a coherent narrative. The investments concerned contribute to the green 
transition in the economy and reaching Sweden’s greenhouse gas emission targets, including by 
promoting sustainable transport.  Investments  in  climate-neutral  and non-toxic circular solutions 
throughout  the  country  reduce  carbon  dioxide  emissions,  lay  the  foundation  for  new  jobs  and 
strengthen Sweden's competitiveness. The reform of increased environmental taxes raises the share 
of environmental taxes, which contributes to climate goals and other environmental goals being 

47 

 
 
achieved. Green transition measures in the plan are in many cases based on digital solutions which 
also contribute to increasing skills of the workforce and this also contribute to other components. 

Components  2  (education  and  adjustment)  and  3  (better  conditions  for  meeting  the 
demographic challenge and ensuring the integrity of the financial system) are closely linked 
and together contribute to ensuring elderly care and health care of good quality. Component 
2 contributes to increasing the availability and capacity of the health care system by ensuring more 
places  in  regional  health  professional  capacity,  thus  enhancing  access  to  care.  The  measure  in 
component  2  also  contributes  to  facilitating  broader  structural  change,  raising  the  level  of 
competence in the labour force and increasing flexibility in the labour market. They allow for more 
training  places  and  for  more  people  studying,  thereby  raising  their  skills  levels  as  well  as  for 
broader opportunities for study financing which supports the investments and reforms in other parts 
of the Plan.  

The measures in component 2 contribute in a coherent way to ensuring welfare, especially 
for the elderly. Investments are cross-cutting and interconnected, allowing better access to care 
for  vulnerable  members  of  the  population.,  The  investments  and  reforms  together  contribute  to 
higher-quality care, where new and existing staff can undergo training during paid working hours, 
and  the  assistant  nurse  profession  by  introducing  an  additional  protected  professional  title.  The 
reform  of  extended  working  life  and  adjusted  age  limits  in  the  pension  system  contributes  to 
securing welfare and to creating space for higher pensions. The measures in the plan also contribute 
to increased opportunities for education and better job-matching for people that are detached from 
the  labour  market.  The  reform  of  changes  in  the  labour  law  and  increased  opportunities  for 
adjustment means that labour regulations become better adapted to today's labour market while 
maintaining  a  basic  balance  between  protection  and  incentives  for  work  that  can  be  broadly 
supported by social partners. The combination of increased opportunities for education, adjustment 
and increased flexibility in the labour market as well as increased opportunities for residence where 
the jobs are located (Component 4) adds to the coherence of the plan are expected to contribute to 
better  matching  in  the  Swedish  labour  market.  The  reforms  in  the  area  of  money  laundering 
contribute to maintaining a wider sense of trust in society. 

The measures to promote the digital transition are  coherent. The different work streams  to 
digitalise the economy  and the public administration, and to  provide workers with  digital  skills 
pursue complementary and mutually reinforcing aims. The measures in components 4 (expansion 
of broadband and digitalisation of public administration) and 2 contribute to the broad promotion 
of digitalisation, through investments in faster broadband expansion, which improves the digital 
infrastructure throughout the country. The structural change, especially the digital transformation, 
places demands on opportunities for retraining when the workforce no longer has the skills that are 
in demand in the labour market. The measures in component 2 promote the digital changeover by 
raising digital competence and contributing to the supply of skills. Through increased knowledge 
and  skills  of  the  workforce,  the  potential  of  digitalisation  can  be  better  utilised,  regardless  of 
geographical location. 

48 

 
 
The  combination  of  measures  can  positively  contribute  to  giving  the  whole  country  the 
opportunity  to  grow  and  to  reducing  regional  disparities.  When  designing  measures  for 
investments in and improving the quality of railways, regional differences and the need to address 
regional  disparities  are  taken  into  account.  In  component  4,  the  access  to  digital  infrastructure 
throughout  the  country  is  strengthened  through  faster  broadband  expansion.  The  measures  in 
component 2 make a coherent response to strengthening the opportunities for education throughout 
the country, and regional needs have been taken into account in the design of all measures. In this 
way, the components thus jointly make up a coherent narrative of promoting regional cohesion, not 
least via lowering barriers to access work and education. 

The  measures  in  components  2  and  4  constitute  a  coherent  response  to  the  challenge  of 
matching  problems  in  the  Swedish  labour  market,  while  the  measures  in  component  5 
(investments for growth and housing construction) aim at addressing supply side issues in the 
housing market by stimulating  increased construction. A well-functioning housing market  is  a 
prerequisite for mobility in the labour market,  as it means that people can more easily move to 
where their jobs are and affect the opportunities to participate in education. In that light, given the 
extent of housing and household-debt related imbalances, the measures in the plan contribute only 
modestly  to  their  unwinding,  however.  Broader  measures  to  reduce  these  imbalances  would  be 
conducive to balanced sustainable growth. 

Complementarity of measures 

The  components  embody  the  plan’s  consistent  vision  of  leveraging  the  twin  transitions  in 
recovering from the Covid crisis. Synergies can be found throughout the Plan between different 
components,  in  particular  as  regards  the  complementarity  of  their  objectives.  In  particular, 
component 1 contributes to the objective of reducing greenhouse gas emissions and the measures 
therein, with similar and reinforcing objectives, complement each other to help accelerate the green 
transition in Sweden. Among the specific measures, the Climate and Industry Leaps constitute a 
major push for the green transition by, respectively, supporting climate investment to address local 
and regional challenges in reducing greenhouse gas emissions and supporting the large investments 
in new technology that has not yet been developed or commercialized, which are required for the 
industry  to  be  able  to  contribute  to  climate  neutrality.  Complementing,  the  support  energy 
efficiency  in  multi-dwelling  housing  will  also  improve  energy  efficiency  and  contribute  to  the 
Swedish emission targets.  

The coherence within and between components assures that the Sweden’s Recovery and resilience 
plan coherently contributes to the fulfilment of RRF's overall goals. In view of the challenges to be 
addressed, the Recovery and Resilience Plan constitutes a balanced approach between reforms 
and  investments.  Taking  into  consideration  the  qualitative  assessment  of  all  the  components  of 
Sweden’s plan, their individual weight and their interactions, the plan contains measures for the 
implementation  of  reforms  and  public  investments,  which,  to  a  high  extent,  represent  coherent 
actions.  This  warrants  a  rating  of  A  under  assessment  criterion  2.11  in  Annex  V  to  the  RRF 
Regulation. 

49 

 
 
 
ANNEX: CLIMATE AND DIGITAL TAGGING TABLE 

[Note: While the total cost of the Swedish recovery and resilience plan exceeds the total allocation of non-repayable 
financial support to Sweden, Sweden 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 

Climate 

Digital 

(Sub-)Measure ID 

(Sub-)Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

1.1.1 

1.1.2 

1.1.3 

1.1.4 

1.1.5 

1.1.6 

1.1.7 

1.2.1 

1.2.1 

1.3 

1.4 

Local and regional climate 
investment – Conversion to 
renewable energy including 
bioenergy for heating in 
industry and agriculture 
Local and regional climate 
investment – Production of 
biogas and biofuels 
Local and regional climate 
investment – Transport 
(renewable fuel and refuelling 
points) 
Local and regional climate 
investment – Waste (including 
plastic recycling) 
Local and regional climate 
investment – Increased 
efficiency 
Local and regional climate 
investment – Charging stations 
for electric cars 
Local and regional climate 
investment – Infrastructure 
Climate investment in the 
industrial sector focusing on 
low carbon economy, 
resilience and adaptation to 
climate change 
Climate investment in the 
industrial sector focusing on 
circular economy  
Energy efficiency in apartment 
buildings 
Strengthened railway support 

50 

229 

030bis 

100% 

194 

030bis 

100% 

140 

077 

100% 

89 

045bis 

100% 

68 

024ter 

100% 

58 

34 

077 

100% 

077 

100% 

244 

022 

100% 

43 

023 

40% 

60 

148 

025 

40% 

033 

40% 

069bis 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Sub-)Measure ID 

(Sub-)Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

1.9 

2.3 

2.4 

4.1 

4.2 

5.1 

Formal protection of forests 
with high natural values for 
biodiversity 
More study places in higher 
vocational education 
Resources to meet demands 
for education at universities 
and other higher education 
institutions 
Joint public administration 
digital infrastructure 
Broadband expansion 
Investment support for rental 
housing and housing for 
students 

247 

050 

40% 

104 

308 

21 

464 

296 

025ter 

40% 

016 

40% 

016 

40% 

011 

051 

100% 

100% 

51