COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of the Netherlands Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for the Netherlands
Date: 2022-09-08
Institutions: European Commission, Secretariat-General
Subjects: EU aid, Netherlands, coronavirus disease, economic and social cohesion, economic recovery, economic reform, epidemic, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 292 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of the Netherlands Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for the Netherlands {COM(2022) 469 final}  
 
 
1.  Executive summary ............................................................................................................................... 2 

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

2.1.  Macroeconomic outlook ............................................................................................................... 5 

2.2.  Challenges related to sustainable growth, cohesion, resilience and policies for the next 
generation .................................................................................................................................................. 7 

2.3.  Challenges related to the green and digital transition ................................................................... 8 

3.  Objectives, structure and governance of the plan ............................................................................... 14 

3.1.  Overall strategy of the plan ......................................................................................................... 14 

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 ................................ 25 

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 ...... 30 

4.4. 

The principle of ‘do no significant harm’ ................................................................................... 37 

4.5.  Green transition ........................................................................................................................... 39 

4.6.  Digital transition ......................................................................................................................... 43 

4.7. 

Lasting impact of the plan ........................................................................................................... 46 

4.8.  Milestones, targets, monitoring and implementation .................................................................. 48 

4.9.  Costing ........................................................................................................................................ 50 

4.10.  Controls and Audit ...................................................................................................................... 52 

4.11.  Coherence ................................................................................................................................... 55 

Annex: Climate and Digital Tagging Table ................................................................................................ 57 

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1.  EXECUTIVE SUMMARY       

The  Dutch  economy  has  recovered  quickly  from  the  COVID-19  pandemic,  although  new 
headwinds are on their way and structural challenges remain. Economic activity in 2020 saw, 
compared to other EU Member States, a relatively small contraction with a decrease in GDP of 
3.8%.  In  2021  the  economy  rebounded  quickly  to  pre-pandemic  levels,  with  GDP  growing  by 
4.9%. The recovery in global trade resulted in strong exports and net trade making a significant 
contribution to GDP growth. However, after strong GDP growth in 2021, the Dutch economy is 
facing new headwinds. Russia’s invasion of Ukraine has resulted in further increases in commodity 
prices and additional supply chain disruptions. 

The Dutch government announced substantial increased spending in early 2022 to address 
key structural  challenges.  In 2020, the  government deficit to  GDP ratio reached 3.7% due to 
elevated spending on healthcare related to the COVID-19 pandemic and on support measures to 
protect employment and maintain household purchasing power. In 2021, the deficit to GDP ratio 
declined below the EU threshold of 3%. In the next four years, the government plans to increase 
spending by EUR 79 billion (9.2% of 2021 GDP), to address challenges such as climate change, 
biodiversity and water management, rising energy prices and insufficient housing supply.   

The Dutch recovery and resilience plan (RRP) amounts to an estimated EUR 4.7 billion. This 
is  to  be  financed  through  non-repayable  financial  support  from  the  Recovery  and  Resilience 
Facility  (RRF)1,  which  allocates  a  maximum  financial  contribution  of  EUR  4.7  billion  to  the 
Netherlands. The country has not requested RRF loans. The plan is well-aligned with the Dutch 
government’s 2021-2025 coalition agreement and other sectoral strategic documents. A key focus 
of the plan is on the green and digital transitions, with measures to improve energy efficiency, 
develop  renewable  energy,  increase  the  sustainability  of  transport  and  mobility,  and  support 
companies in the twin transition. The plan includes measures to improve the functioning of the 
housing  market,  reform  the  labour  market,  implement  the  agreed  pension  system  reform  and 
increase the labour market relevance of the education and training system, notably as regards green 
and digital skills. The RRP also contains measures to improve the resilience and accessibility of 
the health system and to tackle aggressive tax planning and money laundering. Equal opportunities 
and social and territorial cohesion are important cross-cutting themes in the plan.  

The RRP includes adequate measures to help address the key challenges the Netherlands is 
facing. The challenges identified in the most recent country-specific recommendations pertain to 
the following broad policy areas: the green transition and the digital transformation, the debt bias 
in the housing market, labour market, pensions, education and up- and reskilling, strengthening 
public  healthcare  and  pandemic  preparedness  and  tackling  aggressive  tax  planning  and  money 
laundering. The Dutch RRP includes a set of mutually reinforcing reforms and investments that 
are expected to contribute to effectively addressing the identified challenges to varying degrees, 
proportionally with the scale and size of the RRP and its financial allocation. The plan is consistent 
with the challenges and priorities identified in the most recent euro area recommendation.2  

1 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the 
Recovery and Resilience Facility 
2 Council Recommendation of 5 April 2022 on the economic policy of the euro area 2022/C 153/01 

2 

 
                                                           
The  RRP  comprehensively  covers  the  six  policy  pillars  as  referred  to  in  Article  3  of 
Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility (henceforth “the 
RRF Regulation”), 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 six components address 
the  six  pillars,  focussing  on  the  green  transition,  digital  transition,  human  capital,  as  well  as 
enhancing the broad resilience of the Dutch economy, in particular through ensuring the integrity 
of the financial system, and improving the working of the housing market.  

The measures  envisaged in the Dutch RRP are expected to have a sizeable impact on the 
economy’s  growth  potential  and  economic,  social  and  institutional  resilience.  Measures  to 
promote a green and digital economy are expected to have a positive impact on growth potential 
and job creation. Through the development of green and digital skills and support to companies 
and sectors to adapt to and drive the digital transition, as well as green technology development 
programmes, the plan is expected to promote the economic growth potential of the Netherlands as 
well as its economic resilience. Measures aimed at supporting the labour market and the uptake of 
skills should support the green and digital transition and social resilience, while tackling aggressive 
tax planning and the strengthening of the framework to fight money laundering should contribute 
to improved institutional resilience. Furthermore, each of the components in the plan is expected 
to contribute to social and/or territorial cohesion.  

The RRP proposes reforms in the labour and housing markets, in the area of education and 
for the digital transition, which are expected to contribute to the Netherlands’ economic and 
social cohesion. Social cohesion will be supported by measures relating to housing, health care, 
social  protection  coverage  of  the  self-employed,  and  promoting  digital  skills.  Some  of  these 
reforms will be accompanied by investments which are expected to contribute to expanding the 
supply  of  housing,  the  capacity  of  intensive  care  and  foster  the  acquisition  of  skills  through 
education and training, thereby contributing to social cohesion. 

The green transition is a key priority of the Dutch RRP. The measures included in the plan are 
expected to contribute to the Netherlands’ decarbonisation and energy objectives as identified in 
the  National  Energy  and  Climate  Plan  2021-2030  and  are  important  steps  to  achieve  climate 
neutrality  by  2050.  At  least  47.8%  of  the  financial  contribution  is  expected  to  go  to  measures 
supporting climate change objectives. Dedicated reforms and investments in the area of climate 
action  include  significant  efforts  supporting  the  deployment  of  renewable  energy  sources,  the 
development of a functional hydrogen infrastructure, adaptation of residential neighbourhoods to 
the  consequences  of  climate  change,  the  improvement  of  energy  efficiency  in  the  built 
environment, the rollout of climate-friendly mobility solutions, the restoration of biodiversity in 
natural habitats and the shift towards sustainable agriculture. None of the measures in the Dutch 
plan are expected to cause significant harm to the environment.  

The measures supporting digital objectives account for 25.6% of the plan’s total allocation 
calculated in accordance with the methodology of Annex VII to Regulation (EU) 2021/241. 
The  contribution  of  the  Dutch  RRP  to  the  digital  transition  focuses  on  accelerating  the  digital 
transformation.  The  implementation  of  the  plan  should  help  long-term  sustainable  economic 
growth and technological innovations, with investments in digital technologies, infrastructure and 
processes.  The  plan  is  also  expected  to  maximise  the  potential  of  artificial  intelligence  while 
removing specific bottlenecks. Investments related to quantum computing will specifically support 

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start-ups  and  are  expected  to  lead  to  advances  in  research  and  development,  networking  and 
sensing. Other aspects of the digital transition are also addressed to varying extents in the plan. 
This notably includes the support of sustainable mobility by improving signalling systems in the 
country's motorway network and by digitalising key logistics processes. On the institutional side, 
the plan contains measures to digitalise the criminal justice system, to improve the government's 
internal IT systems and to improve the transparency of publicly institutions.  

The measures envisaged in the RRP are expected to have a lasting impact on the economy 
and institutions. In particular, the envisaged measures that aim at fostering the twin transitions 
are  expected  to  have  a  positive  impact  on  the  resilience,  growth  potential  and  economic 
transformation, through improved efficiency of public administration, innovation and productivity 
growth and job creation. This notably includes investments aiming to deploy digital solutions in 
the  transport  sector,  investment  in  AI  technology,  as  well  as  reforms  fostering  digital  public 
services.  Measures  promoting  energy  efficiency  and  fostering  the  development  and  uptake  of 
innovative  green  technologies,  as  well  as  those  reducing  regulatory  barriers  for  investment  in 
renewables are expected to unlock private investments. In addition, measures related to (digital) 
skills are expected to bring about change in education and training policy and support the twin 
transition.  

The  milestones  and  targets  of  the  Dutch  plan  are  generally  evenly  distributed  across  the 
implementation period and adequately reflect the overall level of ambition of the plan and 
appear realistic. It should be noted that the implementation of a number of key reforms is only 
planned for 2025 or 2026 and some of the largest investments, for example in wind energy and the 
housing market, are expected to take their full effect in 2025 and 2026. The implementation of the 
49 measures in the plan is tracked through 127 milestones and targets. The milestones and targets 
represent  the  key  elements  of  the  measures  and  are  necessary  steps  to  achieve  for  their 
implementation. 

The plan includes adequate audit and control arrangements. The arrangements in the RRP 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 justification the Netherlands has provided on the amount of the estimated total costs of 
the  RRP  is  broadly  reasonable  and  plausible.  The  Netherlands  has  provided  individual  cost 
estimates for all investments included in the recovery and resilience plan. For the large majority 
of the individual cost estimates the calculations behind the cost estimates are comprehensive and 
based on sound underlying assumptions. The cost estimates are substantiated by reference costs 
for the key cost drivers, which are supported by evidence and in line with comparable investments. 
However, for some measures the calculations of and the link between the cost and the justification 
thereof is not entirely clear. Overall, the assessment of the cost estimates and inherent supporting 
documents show that costs are justified and reasonable to a medium extent. The plan contains some 
recurrent costs, such as personnel costs and maintenance costs, which are essential for the success 
of  the  underlying  reform  or  investment  and  which  do  not  impose  a  significant  burden  on  the 
national  budget  (most  are temporary and the non-temporary  ones lead to  a limited cost  for the 
future),  making  them  all  duly  justified  and  acceptable.  Finally,  the  estimated  total  cost  of  the 

4 

 
recovery and resilience plan is in line with the principle of cost-efficiency and is commensurate to 
the expected national economic and social impact.  

The RRP displays coherence within each component and shows thematic interlinkages and 
synergies between the different components. The recovery and resilience plan presented by the 
Netherlands is structured around six coherent components, which support the common objectives 
of  stimulating  the  recovery  of  the  Dutch  economy,  contributing  to  the  twin  transition  and 
increasing the country’s resilience.  The plan is coherent  across its  components, with consistent 
reforms and investments reinforcing and strenghtening one another. The components reflect the 
plan’s overall ambition to boost progress on the twin transition in recovering from the COVID-19 
crisis. Components 2 and 3 on the digital transition and the housing market also contribute to the 
green transition. Measures to further improve digitisation of the Dutch economy are also found 
throughout  the  plan,  notably  in  Component  4  on  education.  Several  components  contribute  to 
increase  fairness,  social  cohesion  and  resilience,  notably  in  the  areas  of  self-employment, 
education, aggressive tax planning, health and affordable access to housing. 

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

(1)  
 Balanced 
Response  

(2)  
 CSRs  

(3)  
 Growth, 
jobs…  

(4)  
 DNSH  

(5)  
 Green 
target  

(6)  
 Digital 
target  

(7)  
 Lasting 
impact  

(8)  
 M & T  

(9)  
 Costing  

(10)  
 Control 
Systems  

(11)  
 Coherence  

A  

A  

A  

A  

A  

A  

A  

A  

B  

A  

A 

2.  RECOVERY AND RESILIENCE CHALLENGES: SCENE-SETTER 

2.1. Macroeconomic outlook    

The  Dutch  economy  has  shown  to  be  resilient  in  2020  and  2021.  The  high  degree  of 
digitalisation  of  the  economy  and  the  timely  introduction  of  government  support  measures 
cushioned the economic impact of COVID-19 related confinement measures. Economic activity 
in 2020 saw, compared to other EU Member States, a relatively small contraction with a decrease 
in  GDP  of  3.8%.  In  2021  the  economy  rebounded  quickly  to  pre-pandemic  levels,  with  GDP 
growing  by  4.9%.  The  recovery  in  2021  was  driven  by  a  swift  rebound  in  private  consumer 
spending as the vaccination campaigns allowed the economy to open up again. The economy also 
benefitted  from  a  rebound  in  exports,  with  net  trade  making  a  significant  contribution  to  GDP 
growth.  

Growth in the second half of 2022 and in 2023 is expected to be subdued as the economy is 
facing new headwinds. Russia’s invasion of Ukraine has increased uncertainty and has resulted 
in  further  increases  in  commodity  prices  and  additional  supply  chain  disruptions.  Consumer 
confidence has dropped sharply while businesses are faced with tightening financial conditions. 
Growth in consumer spending in the second half of 2022 and 2023 is expected to be relatively 
weak due to the surging inflation affecting households’ disposable income. Investment growth is 
also expected to be negatively affected, with weakening demand, tightening financial conditions 
and labour shortages weighing on investment decisions of businesses.  

5 

 
 
Overall, the Commission’s Summer Interim Forecast projects GDP growth of 3.0% for 2022, 
of which 2.2% is carry-over from 2021. Growth in 2023 is expected to remain subdued at 1.0%, 
despite benefitting from  the planned increase in  government  consumption and investment.  The 
Dutch government announced in early 2022 that it would increase spending by EUR 79 billion 
(9.2% of 2021 GDP) during its mandate. This additional spending is planned to address challenges 
such as climate change, excessive nitrogen deposits, rising energy prices and insufficient housing 
supply. 

Inflation picked up in the second half of 2021 (to 2.8% for the year) and surged further in 
2022  following  Russia’s  invasion  of  Ukraine.    Annual  inflation  in  2022  is  forecast  at  9.4%. 
Especially gas and oil price increases have a large impact on the Dutch economy given the energy 
mix,  which  relies  heavily  on  these  two  energy  sources.  However,  more  than  half  of  Dutch 
households have electricity and gas contracts that are longer than a year, which will cushion the 
impact of rising prices on disposable income to some degree. In addition, the government has taken 
measures  to  ease  the  impact  of  higher  energy  prices  on  household  budgets  by,  among  other 
measures, lowering taxes on energy. The drivers of inflation have broadened in recent months, 
with especially food prices increasing substantially, while core inflation has also increased to well 
above 4%. In the course of 2023, energy prices are expected to start to decrease more markedly, 
which would bring down annual inflation to 3.3%.  

The Dutch labour market is increasingly tight, with unemployment continuing to decrease 
and the number of vacancies well exceeding the number of unemployed. As a result, employers 
face  increasing  difficulties  to  find  people  with  the  right  skills.  Wage  growth  has  been  lagging 
behind the economic recovery in 2021 but has been picking up in recent months. Given the tight 
labour market and high inflation rate, the trend of increasing nominal wage growth is expected to 
continue in 2022 and 2023.  

The projected GDP growth in the plan is 3.6% for 2022 and 1.7% for 2023. Similar to the 
Commission, the plan expects that higher inflation rates, persisting supply chain bottlenecks and 
the increased uncertainty due to Russia’s invasion of Ukraine will pose challenges to the Dutch 
economy.  The  differences  between  the  Commission’s  summer  interim  forecast  and  the 
macroeconomic scenario underpinning the plan are due to differences in cut-off date – with the 
forecast  underpinning  the  plan  being  finalized  when  especially  the  inflation  outlook  was  more 
benign. This results in a more benign outlook for GDP for 2022 and 2023. 

Table 2: Comparison of macroeconomic developments and forecasts 

Sources: Commission Summer Forecast 2022 for real GDP and HICP inflation and Commission Spring Forecast 2022 

6 

 
for other variables (COM). Recovery and resilience plan and CPB CEP 2022 (RRP). *COM figures based on total 
employment in FTE, RRP figures based on total hours worked. 

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

next generation 

Despite  its  overall  good  performance,  the  Dutch  economy  faces  a  set  of  interconnected 
challenges. The Netherlands is among the most advanced countries in the EU in terms of GDP 
growth  dynamics,  sound  public  finances,  living  standards,  productivity  and  connectivity. 
Nevertheless, intertwined challenges exist in several areas, with the key areas being the labour and 
housing market. In addition, structural reforms and well targeted investments in green and digital 
infrastructure, as well as skills, are needed to contribute to a more sustainable and inclusive growth. 

The Dutch labour market is performing well overall but is still experiencing significant skills 
and labour shortages in many sectors. Ensuring the availability of skilled workers is one of the 
main challenges for the Netherlands, including in information and communication technologies, 
construction and the hospitality sector. Although shortages were already part of the challenges the 
Dutch labour market was facing before, the COVID-19 pandemic has increased both their intensity 
and impact on additional sectors. This shortage of skilled workers calls for continuous investments 
in up- and re-skilling, also in view of the green and digital transitions. 

Overall labour market performance is good, with high participation and low unemployment, 
but important challenges remain with regard to labour market segmentation. The high level 
of  flexible  employment  requires  further  attention  in  terms  of  equal  opportunities  in  the  labour 
market, fair working conditions and adequate social protection. Certain groups (mostly the young, 
low(er) skilled, people with a migrant background or disabilities), along with the self-employed 
without  employees,  were  hit  hardest  during  the  pandemic  and  faced  a  (considerable)  drop  in 
income. In addition, the Netherlands has a high share of women in part-time employment (62.5% 
in 2021), which results in one of the largest gender pay (and pension) gaps in the EU. 

While the pension system performs well on pension adequacy and fiscal sustainability, the 
occupational  (second  pillar)  pension  system  has  drawbacks  in  terms  of  intergenerational 
fairness, transparency of pension rights and flexibility. Second-pillar pension contributions are 
high and potentially large adjustments to contributions could be needed to absorb imbalances in 
pension funds’ balance sheets. The large mandatory savings also contribute to the current account 
surplus.  The  implementation  of  the  reform  of  the  pension  system  agreed  between  the  social 
partners and the government could make pension funds more resilient to shocks. 

The Covid-19 pandemic has aggravated housing shortages while distortions in the housing 
market  have  contributed  to  rapidly  rising  house  prices.  This  rise  in  house  prices  has  been 
fuelled by low interest rates and, in 2021, by increased household budgets due to excess savings 
that  were  accumulated  during  the  pandemic.  The  mortgage  indebtedness  in  the  Netherlands  is 
higher than the average rate in the EU Member States, with households borrowing large amounts 
in relation to the value of their new home and to their income. These high mortgage debts make 
households financially vulnerable to changes in property prices and interest rates. This reinforces 
the cyclicality of the Dutch economy. 

The 2022 Commission’s Macroeconomic Imbalances Procedure (MIP) identified two macro-
economic imbalances which the Netherlands faces: high private sector debt level and large 

7 

 
current account surplus.3 The high mortgage debt substantially contributes to the high private 
sector  debt  level  in  the  Netherlands.  Besides  mortgage  debt,  the  intra-group  debt  of  large 
multinationals also contributes to the large debt position of the private sector. The other macro-
economic imbalance identified in the MIP concerns the large current account surplus, which, at 
8.4% on average in the past three years, well exceeds the relevant benchmark (6% of GDP). From 
a sectoral perspective, high savings and low domestic investment of non-financial corporations are 
the main structural drivers of the continued high current account surplus. 

Decreases  in  educational  performance  and  the  existence  of  significant  disparities  in  the 
education system are a concern in the Netherlands. The gap in educational outcomes linked to 
socio-economic  and  migration  background  is  high.  Investments  are  lacking  to  increase  the 
inclusiveness of education systems and improving their performance to ensure that skills taught 
better  match  those  required  by  the  labour  market.  The  COVID-19  crisis  hit  hardest  vulnerable 
groups  that  lack  necessary  basic  and  professional  skills.  It  has  lowered  general  educational 
outcomes,  but  also  aggravated  the  already  high  inequalities  in  the  educational  outcomes  of 
vulnerable learners.  

The Dutch health system fared comparably well in coping with the unprecedented pressures 
from the pandemic, but the pandemic has also highlighted some shortcomings. The crisis has 
shown that a more resilient health system would not only help to manage potential future shocks, 
but also to tackle more structural challenges, such as a shortage of certain health workers.  While 
the Dutch healthcare system performs very well in terms of universal access to quality healthcare 
at reasonable cost, the COVID-19 pandemic highlighted difficulties to provide e-health services 
due to a lack of relevant e-health tools.4  

The Netherlands is among the countries with the largest flows of inward and outward foreign 
direct  investment  worldwide  and  faces  significant  money  laundering  risks.  Although  the 
Dutch  government  has  taken  several  measures  to  combat  the  misuse  of  company  and  legal 
structures for money laundering purposes several important challenges remain when it comes to 
compliance with anti-money laundering. The Netherlands is identified as one of the Member States 
whose  tax  rules  are  used  by  companies  engaging  in  aggressive  tax  planning.  The  fight  against 
aggressive tax planning is essential to make the Dutch tax system more efficient and fairer.  

2.3. Challenges related to the green and digital transition 

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 
should  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. They should 
also contribute to meeting environmental targets for waste, water, pollution control, biodiversity 
protection and restoration, marine and water resources, and support the transition to sustainable 

3 In-depth review for the Netherlands, SWD(2022) 636 final 
4 In this context, it is important to take into account the Commission proposal for a Regulation of the European 
Parliament and of the Council on the European Health Data Space (COM/2022/197 final). 

8 

 
 
                                                           
food systems as well as to a circular economy as appropriate, while ensuring that nobody is left 
behind.  

Greenhouse gas emissions  

The Netherlands has made good progress in reducing greenhouse gas (GHG) emissions, but 
more is needed to reach EU and national targets. The major challenge for the Netherlands in 
terms of meeting climate targets relates to the presence of relatively large energy-intensive industry 
and transport sectors. In addition to electrification, these sectors will need to rely on other energy 
carriers such as renewable hydrogen to become climate neutral. The Netherlands has overachieved 
its 2020 target of reducing emissions in sectors not covered by the EU Emission Trading System 
(ETS) by 13 percentage points (see Table 3), although this is partially attributable to the impact of 
the  pandemic  rather  than  structural  reductions.  Furthermore,  total  GHG  emissions  (excluding 
LULUCF and including international aviation) in 2020 were about 24% lower compared to 1990. 
By 2030, total GHG emissions are estimated to be 38% to 48% below 1990 levels with current 
policies. The Dutch government 2021-2025 coalition agreement has increased the ambition and 
aims at having at least 55%, whilst aspiring to achieve 60% lower net emissions in 2030 compared 
to 19905.  

Renewable energy 

The Netherlands is amongst the Member States with the lowest share of renewable energy 
in gross inland consumption. Fossil energy carriers continue to account for the majority of the 
energy mix with 39% oil and petroleum and 44% natural gas. In addition, the Netherlands has one 
of the largest gaps between 2020 shares of renewables (14%) and the EU 2030 target (27%).  

Realizing the full potential of renewable energy sources in the North Sea  faces number of 
key  challenges.  Recently,  the  government  has  increased  the  target  for  offshore  wind  energy 
production  by  2030  from  11.5  GW  to  21  GW.  However,  meeting  this  target  will  require 
overcoming challenges related to the ecological integration of offshore wind parks into the North 
Sea  environment,  the  use  of  North  Sea  space  by  many  different  actors  and  the  integration  of 
offshore wind parks into the onshore energy system.  

The Netherlands has the potential to be a frontrunner in the production of green hydrogen 
in Europe but scaling up remains a challenge. The government has set a target of 3-4 GW of 
electrolysis  capacity  by  2030  and  is  looking  to  increase  this  ambition  in  light  of  the  European 
Commission’s proposal for the revision of the EU Renewable Energy Directive and the ambitions 
set out in the REPowerEU Communication6. The achievement of this target requires additional 
innovation and scaling up efforts to substantially decrease costs throughout the entire supply chain 
from production to storage to use.  

Growing capacity constraints in the Dutch electricity grid delay the implementation of new 
onshore renewable energy projects. Capacity constraints are especially acute in the provinces of 
Flevoland, Drenthe and Limburg and additional investments in network infrastructure as well as 
technical  staff  are  needed  to  overcome  network  bottlenecks.  The  lack  of  a  sufficiently  ‘smart’ 

5 Indicative target of 25.4-31 Mton fewer emissions by 2030. 
6 Communication on REPowerEU: Joint European Action for more affordable, secure and sustainable energy,  
COM(2022) 108 final, (8.3.2022) 

9 

 
                                                           
energy grid to accommodate variable renewable energy further limits the effectiveness and speed 
of the energy transition.  

The deployment of additional renewable energy source capacity is limited by complex and 
lengthy  administrative  procedures.  The  government  has  already  taken  several  measures  in 
recent years to simplify the permitting of energy projects, but bottlenecks remain, notably at local 
level, to authorize renewable energy projects, given the high density of population.  

Energy efficiency 

The Netherlands has made good progress towards meeting its energy efficiency targets but 
efforts need to be kept up to ensure it remains on track for achieving its 2030 targets, in 
particular as regards primary energy consumption. While its 2020 final energy consumption 
target was easily reached, its primary energy consumption target would not have been met without 
the impact of the COVID pandemic. Despite a wide range of energy efficiency policies and support 
programmes  in  all  sectors,  care  has  to  be  taken  that  a  narrow  policy  focus  on  GHG  emission 
reductions does not jeopardise the implementation of energy efficiency measures, which are often 
the most cost-efficient way to reduce emissions, in particular in industry. Energy efficiency will 
also be crucial in supporting the achievement of other objectives, specifically regarding security 
of gas supply and renewables7. 

CO2 emissions from the built environment decreased substantially between 1990 and 2021, 
but need to be reduced at a much faster pace to meet the 60% reduction target by 2030 set 
by the Dutch government 2021-2025 coalition agreement. The energy consumption of buildings 
continues to be a major source of CO2 emissions in the Netherlands due to the combustion of fossil 
fuels to generate energy and heat. Additional efforts to reduce the energy consumption of buildings 
as well as to install alternative energy generation solutions are therefore needed to reduce the CO2 
emitted by the built environment from the current 22 Mton to the national objective of 10 Mton in 
2030.   

Biodiversity and water management 

Excessive  nitrogen  deposits  in  agriculture  are  harming  the  environment,  with  more  than 
three quarters of the protected habitats and species having unfavourable conservation status. 
The nitrogen surplus in the Netherlands is four times the EU average, with ammonia emissions per 
hectare  being  among  the  highest  in  Europe  (60  kg  NH3/ha).  Nitrogen  deposition  exceeds  the 
Nitrates  Directive  thresholds,  hinders  biodiversity  objectives  and  affects  the  quality  of  water. 
Following a ruling of the Council of State in 2019, the government was urged to take action to 
reduce  nitrogen  deposits  in  Natura  2000  areas  and  surrounding  areas.  The  ruling  has  affected 
existing  and  new  building  permits,  constraining  construction  activity  in  2020  and  creating 
uncertainty for agricultural activity. Against this background, there is urgency for the Netherlands 
to  substantially  strengthen  its  nitrate  action  programme  in  line  with  the  obligations  under  the 
Nitrates Directive. Additional efforts are also needed to ensure that the objectives of the Water 
Framework Directive, Natura 2000 and air quality legislation are achieved. 

7 Shnapp, S., Paci,  D. and Bertoldi,  P., Untapping  multiple  benefits:  hidden  values in environmental and building 
policies, EUR 30280 EN, Publications Office of the European Union, Luxembourg, 2020, ISBN 978-92-76-19983-0, 
doi:10.2760/314081, JRC120683. 

10 

 
                                                           
The  shift  toward  sustainable  agriculture  remains  a  challenge  but  is  necessary  to  reduce 
nitrogen deposits. The Netherlands is the country with the largest livestock density in the EU and 
the agricultural sector as a whole is responsible for 45% of nitrogen deposits.  

Sustainable mobility 

The Netherlands has a very dynamic deployment of zero-emission vehicles and a high share 
of electrification in its railway network, but further investments in sustainable mobility could 
help  to  remove  bottlenecks.  The  Netherlands  is  a  frontrunner  in  the  roll-out  of  charging 
infrastructure  for  electric  road  vehicles.  In  addition,  the  country  is  also  leading  in  efforts  to 
decarbonise inland waterway transports. At the same time, the Dutch rail and road infrastructure 
is among the most congested in Europe, mostly due to intensive use. Investments in sustainable 
mobility solutions will not only address transport bottleneck but may also have positive spillover 
effects for the single market,  given the importance of Dutch transport hubs such as the Port of 
Rotterdam and Schiphol airport.  

The table below gives an overview of the Netherlands’ 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. 

Table 3: Overview of the Netherlands’ energy and climate objectives, targets and 
contributions 

National targets and contributions  

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

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

Latest 
available 
data 
29%  
(2020 proxy 
data) 

2020 

2030 

Assessment of 2030 
ambition level 

-16% 
(ESD 
Target) 

-36% 
(ESD 
Target 

As in ESR 

14% 

14% 

27% 

Sufficient ambition 

National contribution for energy efficiency: 

Primary energy consumption (Mtoe) 

Final energy consumption (Mtoe) 

58.42 
(2020) 

45.54 

60.7 

46.6 

Sufficient ambition 

52.2 

43.9 

Modest ambition 

Level of electricity interconnectivity (%) 

>15% 

>15% 

37% 

N.A. 

Source: Assessment of the final national energy and climate plan of the Netherlands, SWD (2020) 918 final. 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
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,  while  ensuring  inclusiveness 
throughout. 

DESI 2022 - relative performance by dimension

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DESI

1. Human Capital

2. Connectivity

3. Integration of
digital technoloiges

4. Digital Public
Services

NL

EU

Note: EU aggregate corresponds to EU27, based on 2022 DESI report 

The Netherlands is one of the top performers in the digital domain in the EU. It ranks third 
among EU Member States in the overall ranking of the 2022 Digital Economy and Society Index 
(DESI).  The  Netherlands  performs  particularly  well  on  the  uptake  of  digital  technologies  by 
enterprises and use of online services. It also performs well in connectivity, with a high level of 
5G  and  Very  High-Capacity  Network  coverage.  However,  despite  the  high  5G  coverage,  the 
quality,  dependability  and  capacity  of  the  Dutch  5G  network  can  be  further  improved  by 
accelerating  the  assignment  of  the  remaining  frequencies.  Moreover,  broadband  prices  in  the 
country are consistently higher than the EU average.  

The Dutch population has generally high levels of basic and advanced digital skills. At the 
same time, however, the country also faces a persistent shortage of digitally skilled professionals, 
including  in  artificial  intelligence,  data  and  cybersecurity.  Even  though  the  proportion  of  ICT 
specialists in the workforce is above the EU average, the share of ICT graduates is the fifth lowest 
in the EU. This adds to the difficulty for companies to find digitally qualified personnel and, as a 
result, the share of enterprises reporting difficulties to fill ICT vacancies remains very high (71.3% 
compared to 55.4% at EU average in 2020). The proportion of female ICT specialists has been 
increasing slowly over recent years but is still slightly below the EU average.  Addressing these 
challenges through suitable investments in digital skills education and in digital skills development 
more generally can contribute to maintaining the Netherlands' position as a digital leader. 

12 

 
 
 
 
 
 
 
 
Box 1: Progress towards the Sustainable Development Goals 

Overview of the Sustainable Development Goals and the four dimensions underpinning the 
Annual Sustainable Growth Strategy

The  objectives  of  the  Sustainable  Development  Goals  are  integrated  in  the  European 
Semester  since  the  2020  cycle.  This  provides  a  strong  commitment  towards  sustainability  in 
coordination of economic and employment policies in the EU. In that context, this section outlines 
the  Netherlands’  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 

The  Netherlands  performs  very  well  on  several  SDG  indicators  related  to  environmental 
sustainability (SDG 2, 9, 11, 12, 13 and 15) and is improving on the indicator on affordable 
and clean energy (SDG 7). With respect to addressing ‘Affordable and clean energy’ (SDG 7) 
the  country  has  made  considerable  progress  on  the  share  of  renewable  energy  in  total  energy 
consumption, which increased from 5.7% in 2015 to 14% in 2020 but is still below the EU average 
(22.1% in 2020). The Netherlands also improved on indicators like ‘primary energy consumption’ 
and ‘final energy consumption’, but consumption remains above the EU average. Further reduction 
of  ammonia  emissions  from  agriculture  production  would  lead  to  progress  on  SDG  2 
‘Environmental impacts of agricultural production’.  

13 

 
 
Fairness 

The  Netherlands  ranks  generally  high  on  indicators  assessing  the  fairness  of  society  and 
economy (SDG 1, 2, 3, 4, 5, 8 and 10). The country outperforms the EU average in most indicators 
related  to  poverty,  health  and  education  (SDGs  1,  3,  4).  It  historically  performs  very  well  on 
economic growth and employment (SDG 8). The employment rate increased from 77.9% in 2016 
to 81.7% in 2021, which makes the Netherlands one of the best performers in the EU (EU average: 
73.1% in 2021). 

Digital transition and productivity 

The Netherlands performs better than the EU average in nearly all the indicators related to 
productivity (SDG 4, 8, 9). For instance, the country has the highest share of people with at least 
basic digital skills (79% in 2021, compared to the EU average of 54%), and one of the highest 
shares of adult participation in learning (SDG 4). The share of households with  access to high-
speed internet in 2021 (90.6%) is well above the EU average (70.2%) and represents significant 
progress on this indicator since 2016 (31.2% in 2016). The Netherlands has increased its share of 
GDP on R&D from 2.1% in 2015 to 2.3% in 2020 and now meets the EU average (2.3% in 2020).  

Macroeconomic stability 

The Netherlands performs very well on SDG indicators related to macroeconomic stability 
(8 and 16). In particular, the indicators on “peace, justice and strong institutions” (SDG 16) have 
further  improved.  The  country  also  outperforms  the  EU  average  on  indicators  related  to 
employment and decent work (SDG 8). Although the percentage of the population reporting crime, 
violence or vandalism decreased from 17.4% in 2014 to 15.7% in 2020, it is still above the EU 
average (11% in 2019) (SDG 16). 

3.  OBJECTIVES, STRUCTURE AND GOVERNANCE OF THE PLAN 

3.1. Overall strategy of the plan 

The Dutch recovery and resilience plan aims to act as a catalyst for more sustainable, smarter 
and  inclusive  growth,  strengthening  social  cohesion  and  making  the  Dutch  society  more 
resilient to crises (such as pandemics) and climate change. The dimensions of sustainable and 
resilient growth complement each other in the RRP. Measures to achieve productivity growth and 
macroeconomic  stability  also  contribute  to  environmental  sustainability.  The  Dutch  broader 
reform and investment agenda, which includes the RRP, has been shaped in accordance with these 
principles.  

The RRP is structured according to six priorities, which cover all six pillars of the RRF Regulation. 
The six priorities of the Dutch RRP, which are described in 6 components, are: (1) Promoting the 
green transition, (2) Accelerating the digital transformation, (3) Improving the housing market and 
making buildings more energy efficient, (4) Strengthening the labour market, pensions and future-
oriented  education,  (5)  Strengthening  public  healthcare  and  pandemic  preparedness,  and  (6) 
Tackling aggressive tax planning and money laundering. 

14 

 
Table 4: Overview of components and associated costs. 

Component 

Promoting the green transition 

Accelerating the digital 
transformation 

Improving the housing market 
and making buildings more 
sustainable 
Strengthening the labour 
market, pensions and forward-
looking education 
Strengthening public health 
care and pandemic 
preparedness 
Tackling aggressive tax 
planning and money laundering 
Total 

1.1 Speeding up climate and energy transition 
1.2 Addressing nitrogen 
2.1  Promotion  of  innovative  technologies  and 
digital skills 
2.2 Future-proof mobility 
2.3 Future-proof IT in public administration 
3.1 Improving the housing market 
3.2 Making buildings more sustainable 

4.1  Strengthening  the  labour  market  and  a  good 
pension 
4.2 Future-proof education and research 
5.1 Strengthening the public health sector and 
pandemic preparedness 

6.1 Tackling aggressive tax planning and money 
laundering 

Costs 
(EUR 
million) 
1 836 

1 072 

1 387 

241 

172 

0 

4 708 

The first component of the plan aims at promoting the green transition and reducing GHG and 
nitrogen emissions. One of the main reforms included in the component, the Energy Law, is of 
particular relevance for the Netherlands to be able to move to a greener economy. This reform is 
accompanied  by  fiscal  reforms  in  the  fields  of  energy  taxation,  car  taxation,  industrial  CO2 
emission taxation and air travel taxation, all intended to stimulate the greening of the economy. 
The investments ‘Offshore wind’ and ‘Green power of hydrogen’ aim to support the production of 
more  sustainable  energy  and  increase  the  share  of  energy  consumed  from  renewable  energy 
sources  in  the  Netherlands.  The  component  also  includes  investments  to  move  towards  more 
sustainable transport, by supporting the transition towards cleaner technology in both air and water 
transport.  The  component  contributes  to  reducing  nitrogen  emissions,  by  investing  in  nature 
restoration and supporting the rehabilitation of pig farms.  

The  second  component  focuses  on  accelerating  the  digital  transformation.  This  component 
focusses on innovation and improving scientific research and includes a package of investments 
promoting advanced technologies, such as quantum technology and artificial intelligence. Further 
digitalisation  in  education  and  the  logistics  sector  are  supported  by  targeted  investments.  The 
component  also  addresses  the  Dutch  challenges  related  to  transport  bottlenecks  by  supporting 
investments  in  rail  traffic  (advancing  the  implementation  of  the  European  Rail  Traffic 
Management System) and road traffic (improving roadside stations and smart mobility solutions). 
These investments are expected to lead to increased energy efficiency, security and digitalisation 
in  infrastructure.  In  addition,  government  IT systems  are planned to  be  modernised which will 
improve the efficiency, transparency and accessibility of the public administration. To enable this, 

15 

 
 
 
the component includes a reform in the public administration as well as further digitalisation of 
the criminal justice system and updating the IT systems of the Ministry of Defence.   

The third component aims at improving the housing market and make buildings more energy 
efficient. This component includes a package of reforms expected to speed up the construction of 
housing and to make the housing market fairer and more accessible for all. A first reform aims to 
make social rent more income-dependent by allowing higher rent increases for tenants with higher 
incomes  whereas  a  duo  of  tax  reforms  will  increase  the  vacant  possession  value  ratio8 
(“leegwaarderatio”) in the Dutch tax system as well as the tax exemption of gifts to finance home 
purchases for young households. The remaining two reforms will promote the supply of housing 
by  setting-up  binding  agreements  with  provinces  and  municipalities  for  the  realisation  of  new 
dwellings and removing bottlenecks in the planning and permitting procedures for construction 
processes  in  the  Netherlands.  The  construction  of  new  dwellings  is  further  supported  by  an 
investment aimed to provide the means to municipalities to undertake the necessary investments 
before residential construction can start. Lastly, the component includes two investments that aim 
to contribute to the energy efficiency of the built environment: a subsidy scheme to improve the 
energy efficiency of public real estate and an investment subsidy scheme to building owners for 
the implementation of energy savings measures 

The  fourth  component  aims  at  strengthening  the  labour  market,  the  pension  system  and 
education. This component contains several important reforms such as the reduction of the tax 
deduction  for  self-employed,  the  introduction  of  a  mandatory  disability  insurance  for  self-
employed, and measures to tackle bogus self-employment (including an amendment to the law to 
better define employment relationships). The combined effect of these measures should lead to 
improved social and institutional resilience and help level the playing field between self-employed 
and  employees,  fostering  equal  opportunities  for  all.  Another  major  reform  included  in  this 
component  is  the  reform  of  the  pension  system,  which  should  lead  to  a  more  adequate  and 
transparent pension system. Investments in human capital are planned to support people to develop 
their careers and find jobs through reskilling, contributing to addressing labour market and skills 
shortages and fostering the green and digital transitions. The component aims at making education 
and  research  suited  for  the  future  by  investing  in  a  national  education  lab  and  by  supporting 
vulnerable  students  (by  providing  more  finances  to  schools  to  support  newcomers,  last  year 
students and online education).   

The  fifth  component  focuses  on  strengthening  the  public  health  sector  and  pandemic 
preparedness. It includes investments to reduce the shortage of human resources in the care sector 
in  times  of  a  health  crisis  and  to  increase  the  Intensive  Care  capacity  during  the  COVID-19 
pandemic.  In addition,  measures are planned to  enable remote healthcare through the  use of e-
services and to strengthen data exchange between health institutions and for research.  

The  sixth  and  final  component  focuses  on  tackling  aggressive  tax  planning  and  money 
laundering. This component includes a reform package to combat tax avoidance. In particular, 
the  reforms  aim  at  tackling  tax  avoidance  by:  (i)  imposing  a  conditional  withholding  tax  on 
interests, royalties and dividends paid to low-tax jurisdictions, (ii) introducing a law on countering 

8 The vacant possession value ratio adjusts the appraisal value of rented property, effectively introducing a tax 
discount for buy-to-let owners of property. Increasing the ratio will reduce the tax discount or eliminate it 
completely (as the ratio is raised to 100% in most cases). 

16 

 
                                                           
mismatches in the application of the arm’s length principle, (iii) preventing an exemption via a 
specific interest deduction limitation, (iv) limiting liquidation and cessation arrangements, and (v) 
limiting loss relief. In order to achieve decisive results, the measures against tax avoidance aim to 
go beyond the requirements of the European Directives (ATAD1 and ATAD2). This component 
also includes a reform aimed at reducing money laundering.  

The timeline of the plan is relatively balanced with reforms and investments being fairly evenly 
distributed over the RRF period. 

3.2. Implementation aspects of the plan 

Consistency 

The plan is aligned with key national and European programmes and initiatives. The RRP 
ensures consistency, and leverages synergies, with:  

- 
- 

the National Climate Agreement and Fund (section 2.1); 
the  digitalisation  priorities  expressed  in  the  Dutch  government  2021-2025  coalition 
agreement (section 2.2); 
the National Housing Agenda (section 2.3); 

- 
-  priorities identified by the Commission for the Regulation of Work (section 2.4); 
- 
- 

the Dutch health policy, prioritising e-health and pandemic preparedness (section 2.5); and 
the national policy on tax avoidance, following the recommendations from the Advisory 
Committee on Taxation of Multinational Enterprises (section 2.6) 

The plan is broadly consistent with the challenges and priorities identified in the most recent 
Council Recommendation on the economic policy of the euro area.9 Major investments focus 
on the green agenda and digital transition, thus supporting fiscal measures towards investments 
that promote a sustainable and inclusive recovery, consistent with the green and digital transitions 
(euro area recommendation 1). The reforms in the plan on tackling aggressive tax planning and 
money laundering counter tax evasion and tax avoidance to ensure fair and efficient tax systems 
(euro  area  recommendation  2).  Reforms  and  investments  in  the  area  of  the  labour  market  and 
education are intended to mitigate to a certain degree labour shortages, contribute to the upskilling 
and reskilling of the work force and strengthen inclusive quality education and training systems 
(euro area recommendation 2).  

The Technical Support Instrument (TSI) provides expertise in building capacities to implement 
the  plan  in  a  number  of  areas  relevant  for  the  green  and  digital  transitions,  such  as  hydrogen-
powered transport and mobility and cybersecurity education. 

Administrative organisation  

The  programme  directorate  at  the  Ministry  of  Finance  is  responsible  for  monitoring  and 
coordinating  the  implementation  of  the  plan.  This  includes  reporting  on  progress  with  the 
implementation of milestones and targets, monitoring the implementation of the audit and control 

9 Council Recommendation of 5 April 2022 on the economic policy of the euro area (OJ C 153, 7.4.2022, p.1) 

17 

 
 
                                                           
strategy, quality control of all financial data and submitting payment requests. The directorate is 
further responsible for identifying and correcting early on any potential undesirable developments. 
To  this  end,  but  also  to  ensure  coherence  with  the  use  of  other  sources  of  Union  funding,  the 
directorate is in close contact with the line ministries that are in the lead on the implementation of 
specific  reforms  and  investments.  It  will  remain  the  technical  contact  point  with  the  European 
Commission in the implementation phase of the recovery and resilience plan.  

Gender equality 

The RRP contains measures that are expected to help the Netherlands address the challenges 
in  the  area  of  gender  equality  and  equal  opportunities  for  all.  The  plan  describes  these 
challenges in the field of gender equality and explains how reforms and investments in the plan 
will be instrumental to address them and further improve on past achievements, e.g. the relatively 
high  employment rate of women.  The  plan  contains  three measures in  the digital  area, namely 
‘Quantum Delta NL’, ‘AiNed and AI Learning Communities’ and ‘National Education Lab AI’ 
that,  among  other  goals,  aim  to  increase  the  participation  of  women  in  this  sector.  Equal 
opportunities  are  a  cross-cutting  theme  in  the  plan.  Measures  that  are  designed  to  improve  the 
labour  market  by  reducing  institutional  differences,  notably  between  self-employed  and 
employees,  are  expected  to  contribute  to  providing  more  equal  opportunities  for  all.  Equal 
opportunities are also expected to be reinforced by investments supporting education and access 
to employment of youth through career advice and training activities. 

Stakeholder consultation 

Based on the framework set out in the Dutch government 2021-2025 coalition agreement of 
10 January 2022, a first concept of the RRP was published on 28 March 2022. During the 
subsequent consultation process, advice and information was sought from relevant stakeholders. 
This  included meetings  with  co-authorities (municipalities,  provinces and  water boards), social 
partners and organisations working to promote gender equality and equal opportunities for all. In 
addition, an internet consultation was launched where every citizen was able to his/her views and 
give input on the first concept of the Dutch recovery plan. 

The Dutch authorities state in the RRP that the meetings with co-authorities proved to be 
valuable in determining trade-offs in the process of reducing the size of the RRP and they 
led to more balanced measures in the areas of the housing market, renewable energy and 
energy  efficiency.  In  the  consultation  process,  municipalities  and  provinces  stressed  the 
importance of their involvement in the implementation of the reforms and investments included in 
the RRP.  

Civil society organisations working on  gender equality and equal opportunities, stressed the 
importance  of  monitoring  the  positive  or  negative  impact  of  policy  interventions  on  inequality 
during the implementation phase of the RRP. Since the publication of the first draft of the Dutch 
RRP,  the  plan  was  discussed  several  times  in  the  regular  consultation  structure  between  the 
Government (chaired by the Ministry of Social Affairs and Employment) and the social partners, 
contributing especially to the measures for the labour market, pension reform and education.  

A public internet consultation on the RRP was held on the Dutch authorities’ webpage for 
official  internet  consultations  (www.internetconsultatie.nl)  from  28  March  2022  to  6  May 
2022. The social media channels of the Ministry of Finance drew the attention of stakeholders and 

18 

 
interested parties to this consultation. A total of 38 replies were received to the consultation. The 
responses  came  from  a  wide  range  of  (interest)  organisations  active  in  different  areas  such  as 
energy, transport and elderly care givers. The Ministry of Finance held a technical briefing on the 
first version of the plan in the Dutch Parliament, later on followed by debates with MPs (both in 
the plenary and in the Finance Committee). 

Cross-border and multi country projects 

The plan does not include cross-border or multi-country projects, but several projects have 
positive spillover effects on other Member States. This applies notably to the measures in the 
green transition component, such as the investment ‘Aviation in transition’ which addresses the 
strategically  important  issue  of  reducing  emissions  from  aviation.  Another  relevant  investment 
concerns the European Rail Traffic Management System to align the Dutch system to the European 
standard for train protection and control. 

Security self-assessment 

In accordance with  the  RRF Regulation,  the plan identified  cybersecurity as a significant 
concern for one measure in the plan (updating the IT systems of the Ministry of Defence). 
The plan does not provide a detailed security self-assessment for this measure but confirms that 
appropriate cybersecurity systems are already in place and that the relevant strategies are up-to-
date for the implementation of this investment. This specific investment includes the design of a 
Security Operations Centre, including a monitoring system, identification and access management, 
digital access control and additional security measures for strictly confidential work. It complies 
with NATO standards and is also explicitly linked to the EU’s open strategic autonomy by making 
careful choices in IT service providers and diversifying key supply chains.  

The plan also references the Dutch Cybersecurity Agenda, which includes several initiatives  to 
safely  seize  the  economic  and  societal  opportunities  of  digitalisation  and  to  protect  national 
security in the digital domain.   

No measures regarding 5G and high-speed connectivity are included in the plan. 

Communication 

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  all  information 
regarding  the  implementation  of  the  plan  and  the  labelling  of  projects  as  financed  by  the  RRF 
(‘funded by the European Union – NextGenerationEU’). 

In its communication, the Netherlands aims to increase awareness of the RRF background 
and objectives and of the content and process of the national RRP. Communication will focus 
on substantively affected stakeholders, such as social partners, civil society organisations and local 
government,  and  the  general  public.  Messages  and  developments  will  be  placed  on  multiple 
channels so that communications are mutually reinforcing:  

  Social media (Twitter, LinkedIn and Instagram) will focus on reaching the general public 
and stakeholders involved in content. A key objective of this commitment is knowledge 
sharing, for example during the process of achievement of milestones.  

19 

 
  The  website  www.rijksoverheid.nl/financienEU  will  serve  as  a  basic  platform  for  all 
communications on the RRF and Dutch RRP. It will contain a separate page which will list 
all official documents, major developments and results.  

  Specific (visual) content will continue to be developed in the coming years to contribute to 

the achievement of communication goals.  

  For all projects receiving funding through the RRF and the Dutch plan, arrangements are 

under way to mention the role of the EU under the RRF and NextGenEU. 

Once a year, the results of the communication will be measured by means of media reviews 
and  figures  on  social  media  and  the  website.  This  will  assess  the  extent  to  which  the 
communication  objectives  are  being  achieved  and  what  additional  actions,  if  any,  are  needed. 
Throughout the implementation of the plan, the Dutch authorities should continue to review the 
focus of its communication activities and notably how cooperation with the European Commission 
can contribute to this. 

State aid 

State aid and competition rules fully apply to the measures funded by the RRF. 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  the  Netherlands  in  its  RRP  cannot  be  deemed  a  State  aid 
notification. In as far as the Netherlands considers that a specific measure contained in the RRP 
entails de minimis aid or aid exempted from the notification requirement, it is the responsibility of 
the Netherlands 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. 

4.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

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

situation 

The  plan  follows  a  holistic  approach  to  foster  the  recovery,  addressing  many  challenges 
related to all six pillars referred to in Article 3 of the RRF Regulation. The plan aims to support 
the recovery and potential growth of the Dutch economy, 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. All pillars are covered 
by  at  least  one  component,  while  some  components  contribute  to  several  pillars.  The  range  of 
actions  of  the  plan  corresponds  to  the  one  of  the  Facility  with  an  appropriate  overall  balance 

20 

 
between  pillars.  The  coverage  of  the  Dutch  plan’s  components  compared  to  the  six  pillars  is 
summarised in Table 5. 

Table 5: Coverage of the six pillars of the Facility by the Dutch RRP components  

Green 
transition 

Digital 
transformati
on 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

Policies for 
the next 
generation 

Health, and 
economic, 
social and 
institutional 
resilience 

● 

○ 

● 

C1: Promoting 
green transition 
C2: Accelerating 
digital 
transformation  
C3: Improving the 
housing market 
and sustainably 
built environment 
C4: Strengthening 
the labour market, 
pensions and 
future-oriented 
education 
C5: Strengthening 
the public health 
sector and 
pandemic 
preparedness 
C6: Tackling 
aggressive tax 
planning and 
money laundering 

● 

○ 

● 

● 

● 

● 

● 

● 

● 

○ 

○ 

● 

○ 

● 

● 

● 

● 

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

Green transition 

Facilitating the green transition is one of the main policy objectives underlying the plan and 
is addressed by investments and reforms in Component 1 and 3.  

The  plan  supports  reaching  the  Netherlands’  decarbonisation  objectives  as  set  out  in  the 
National Energy and Climate Plan. Several measures contribute to achieving the 2030 and 2050 
climate  and  energy  objectives  and  to  reducing  the  country’s  energy  dependency  on  Russia.  In 
particular, Component 1 contains  dedicated measures to  accelerate the  green transition  and the 
climate transition of industry, through investments in green technologies (enabling the building of 
wind turbines and supporting research into green hydrogen) and reforms (increasing CO2 taxation 
for industry and reforming other aspects of energy taxation). A dedicated measure is also expected 
to reduce the amount of nitrogen emissions in agriculture, in particular near Natura 2000 areas.  

Moreover,  investments  in  Component  1  are  expected  to  support  the  development  of 
innovative technologies such as green hydrogen,  zero-emission aviation and shipping, and 

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
sustainable mobility solutions. In addition, Component 3 includes investment support for energy 
efficiency improvements in housing and for public building renovations.  

Digital transformation 

Investments  and  reforms  in  Components  2,  4  and  5  support  the  digital  transition  of  the 
economy.  

Most digital measures are included in Component 2, which has ten reforms and investments 
to support long-term sustainable economic growth through technological innovations, with 
investments in digital technologies, infrastructure and processes. The plan aims to maximise 
the potential of artificial intelligence (AI) by removing specific bottlenecks such as slow speed of 
innovation or lack of data exchanges and by including a talent programme for AI researchers. The 
‘Quantum Delta NL’ programme will specifically support digital start-ups and is expected to lead 
to  advances  in  quantum  computing  research  and  development,  networking  and  sensoring.  The 
‘Digital Infrastructure Logistics (DIL)’ initiative aims to accelerate and facilitate the digitalisation 
and decarbonisation of the logistics sector and hence its sustainable growth.  

The plan also supports the digital transformation in mobility, thereby promoting sustainable 
mobility  covering  various  means  of  transport.  Component  2  supports  the  rollout  of  digital 
infrastructure in the traffic management system of trains (ERTMS). Investments are planned in 
digital road side stations and in facilitating the transition to smart mobility.  

The  digital  transition  is  also  supported  through  measures  aiming  at  improving  the 
digitalisation  of  public  administration  and  services  and  a  better  access  to  information 
(Component 2). The plan provides for a completely renewed IT infrastructure of the Ministry of 
Defence.  The  entry  into  force  of  the  ‘Open  Government  Act’,  part  of  the  measure  ‘Public 
information  management’,  is  expected  to  improve  citizens’  access  to  information  via  a  digital 
platform while the digitalisation of the criminal justice chain is designed to help citizens to access 
the criminal justice system.  

Additional  investments  contribute  to  developing  digital  skills  at  different  levels  of  the 
education system and digital inclusion in both education and health in the Netherlands. The 
plan contains measures to foster digitalisation in vocational and higher education institutions and 
to improve students’ and teachers’ digital skills through the establishment of “Centres for Teaching 
and  Learning”  (Component  2).  A  dedicated  investment  in  Component  4  also  aims  to  improve 
education  by  discussing  and  proposing  scalable  artificial  intelligence  solutions  for  the  learning 
process in primary and secondary education. The plan also supports the development of nationally 
integrated  health  data,  research  infrastructure  and  e-health  applications  through  a  dedicated 
measure in Component 5. 

Smart, sustainable and inclusive growth 

The plan contributes to ensuring smart, sustainable and inclusive growth, with measures in 
Components 1, 2, 4 and 6.  

Measures  in  these  components  are  expected  to  enhance  the  productive  capacity  of  the 
economy and promote sustainable growth, as well as climate mitigation and adaptation. The 
support to the development and application of new technologies in the green domain (Component 
1) should help the Dutch economy to grow in a smart and sustainable way. Component 6 contains 

22 

 
a  comprehensive  package  of  reforms  that  tackle  tax  avoidance  and  aim  at  addressing  money 
laundering related challenges, which will contribute to creating a sustainable economy that works 
for all with a fair tax system.  

Component 4 of the plan is expected to contribute to economic cohesion, inclusive growth, 
productivity and competitiveness via skill acquisition. By equipping the labour force with skills 
for  the  future,  the  plan  aims  to  improve  the  employability  of  workers  facilitating  job-to-job 
transitions  and  is  thus  expected to  enable citizens to  make use of the opportunities of the twin 
transition.  

Research, development and innovation measures are included in different components of the 
plan. A measure is included in Component 4 linked to the digital transformation of the education 
systems. Measures in Component 1 relate to innovation and new technologies for clean energy 
production.  Measures  in  Component  2  are  expected  to  develop  the  potential  of  artificial 
intelligence and quantum technology for the Dutch economy and society. A dedicated investment 
in Component 5 aims to stimulate innovation in life sciences and the health sector.  

Social and territorial cohesion 

The plan includes several measures in Components 2, 3 and 4 intended to enhance social and 
territorial cohesion. Territorial cohesion will be fostered through measures in Component 2 with 
investments into railways and smart mobility which are expected to reinforce the integration of 
transport networks and to promote safe, sustainable and smart mobility for both people and goods. 
Investments to substantially upgrade the railway network in the Netherlands (Component 2) will 
make it more attractive for citizens and enterprises to use the railways as a means of transport and 
strengthen territorial cohesion by improving connectivity between regions.  

Social  cohesion  will  be  fostered  through  education  and  training  measures,  directly 
contributing  to  the  implementation  of  the  European  Pillar  of  Social  Rights.  Measures 
targeting education (Component 4) are expected to have a positive impact on social cohesion, with 
measures  focusing  on  students  in  their  last  year  and  students  who  recently  migrated  to  the 
Netherlands (“newcomers”). Component 4 also includes investments to increase up- and reskilling 
opportunities to facilitate participation in the labour market of vulnerable groups.   

Social cohesion will be further strengthened through investments in the housing market and 
the reform of the pension system. Dedicated measures in Component 3 are designed to make the 
housing market fairer and reduce inequality by removing distortions and by both unlocking and 
accelerating construction activities with a focus on affordable housing. Additionally, rent paid by 
tenants in the social rental sector will become more income-dependent by allowing higher rent 
increases  for  middle-and  high-income  tenants.  Through  a  strengthening  of  the  long-term 
sustainability of the pension system (Component 4), the plan is expected to also improve social 
cohesion by making the pension system more transparent, fairer and better suited for a changing 
labour market. 

Health, and economic, social and institutional resilience, with the aim of, inter alia, increasing crisis 
preparedness and crisis reaction capacity 

The resilience of the Dutch social, health, economic and institutional system is expected to 
improve as a result of the measures proposed in Components 2, 4, 5 and 6. The resilience of 
the Dutch health system in times of an acute crisis is expected to be improved through targeted 

23 

 
measures in Component 5. These measures aim to reduce staff shortages in the care sector in times 
of a health crisis and to increase the intensive care capacity during the COVID-19 pandemic. In 
addition, investments are planned to enable remote healthcare through the use of e-services and to 
strengthen  data  exchange  between  health  institutions  and  for  research.  A  stronger  and  more 
resilient health system will thus be better placed to absorb surges in healthcare demand. 

The resilience of the Dutch economy is expected to be improved with measures tackling to 
some extent inefficiencies in the housing market in Component 3. Several reforms related to 
the housing market and the rental market are expected to moderate the demand for buying a house. 
At the same time, several supply side measures are aimed at increasing the supply of (affordable) 
housing  and  are  expected  to  contribute  to  a  dampening  of  the  strong  house  price  increases. 
Although distortions in the housing market are expected to remain, the combined set of reforms 
and investments in the plan are expected to contribute to a more stable housing market, thereby 
improving macroeconomic resilience.   

Component 4 includes three important reforms aiming to reduce the risks of labour market 
segmentation, as far as self-employed (notably those without employees) are concerned, thus 
helping  to  strengthen  economic  and  social  and  institutional  resilience.  The  plan  includes 
measures  to  level  the  playing  field  between  employed  and  self-employed  in  particular  via  the 
reduction of the tax deduction for self-employed and measures to reduce bogus self-employment 
by providing clarity on the definition of employment and increasing enforcement as well as the 
abolishment of the enforcement moratorium of the 2016 Employment Relationships Deregulation 
Act (“Wet deregulering beoordeling arbeidsrelaties, wet DBA”). In addition, it includes measures 
to improve social protection coverage for the self-employed via the introduction of a mandatory 
disability  insurance.    In  combination,  these  labour  market  reforms  will  decrease  institutional 
differences between categories of workers on the Dutch labour market. In addition, an important 
reform is included to address key vulnerabilities of the pension system. Together these measures 
are expected to make the labour market and pension system less vulnerable to economic shocks. 

Institutional  resilience  will  be  supported  through  actions  to  ensure  efficient  public 
administration  and  sound  governance.  Component  6  contains  a  comprehensive  package  of 
reforms that tackle tax avoidance and address money laundering related challenges. Component 2 
also  aspires  to  promote  institutional  resilience  by  accelerating  the  digitalisation  of  the  Dutch 
government, in particular the digitalisation of the criminal justice chain and upgrades to the IT 
systems of the Ministry of Defence. 

Policies for the next generation, children and the youth, such as education and skills 

The Dutch RRP contains policies for the next generation, children and the youth through its 
dedicated  measures  on  training  and  education  in  Component  4  and  several  measures  in 
Component 2. Additional resources for education will benefit the next generation. Component 4 
contains measures aimed at newcomers and students in the last year, to combat the education losses 
during the COVID-19 pandemic. These measures are complemented by an investment to equip 
pupils with laptops or tablets. Dedicated measures are included to help match students’ skills with 
demand from the labour market through training and learning activities. The future generation is 
also expected to benefit from an investment in Component 2 which aims to equip students and 
teachers  with  digital  skills  in  secondary  and  higher  education  and  one  in  Component  4  on 
developing AI solutions for learning processes in primary and secondary education.  

24 

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

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

The Dutch RRP is expected to address a significant subset of the challenges identified in the 
relevant  2019,  2020  and  2022  country-specific  recommendations.  The  plan  includes  an 
extensive set of mutually reinforcing reforms and investments aimed at fostering the green, digital 
and energy transitions, supporting sustainable agriculture, transport and research and innovation. 
These measures are expected to boost the growth potential of the economy in a sustainable manner. 
The plan includes measures to improve the resilience of healthcare, tackle aggressive tax planning, 
to reform the pension system and increasing the social protection coverage for self-employed. As 
such and taking into account the size of the financial contribution, the plan satisfactorily addresses 
most of the 2019, 2020 and 2022 country-specific recommendations (CSRs). However, in some 
cases,  the  measures  in  the  plan  alone  are  not  sufficient  to  ensure  that  the  CSRs  are  addressed 
adequately.  This  is  notably  the  case  for  the  CSR  related  to  the  debt  bias  and  distortions  in  the 
housing market which has only been addressed in a partially satisfactory manner as the plan does 
not  sufficiently  address  the  debt  bias  in  the  housing  market,  where  generous  mortgage  interest 
deductibility  remains  in  place.  In  addition,  while  important  reforms  are  included  to  reduce 
incentives for workers to be self-employed, the plan lacks sufficient measures or envisaged policy 
options  to  reduce  the  incentives  to  use  flexible and  temporary  employment.  Although  the  plan 
contains  several  measures  to  increase  digital  skills,  the  focus  of  the  plan  on  labour  and  skills 
shortages in general is more limited. Limited attention is given to comprehensive life-long learning 
and  up-  and  reskilling  of  the  inactive  and  those  at  the  margins  of  the  labour  market.  The 
Netherlands has also taken additional measures outside the scope of the plan that address policy 
challenges  in  the  areas  of  anti-money  laundering,  wages  and  wage  development  and  skills 
development. The latter is also expected to be followed-up by use of other EU funding programs, 
notably the Just Transition Fund (JTF) and the European Social Fund Plus (ESF+). See table 6 for 
a mapping of the challenges identified in the 2019-2020-2022 CSRs and the components in the 
Dutch RRP.  

Several reforms are included in the plan aimed at tackling more effectively aggressive tax 
planning and money laundering (CSR 1 in 2019 and CSR 4 in 2020) in the Netherlands.  The 
RRP includes several reforms, like the introduction of a withholding tax on dividends, interests 
and royalty payments to low-tax jurisdictions and in situations that constitute tax abuse under the 
Dutch anti-abuse regulations, aiming at tackling tax avoidance via the Netherlands. Some of the 
measures taken, which focus primarily on tax avoidance, also broaden the tax base and ensure a 
more balanced taxation of multinationals. The Netherlands is among the countries with the largest 
flows of inward and outward foreign direct investment worldwide and therefore subject to high 
money laundering risks. In the area of anti-money laundering the plan describes in its narrative the 
various measures taken by the Netherlands to tackle money laundering. Measures are included in 
the plan which aim at deterring criminals from laundering money and strengthening investigation, 
improving the effectiveness of the gatekeeper function and prosecution capacity. 

25 

 
The  pension  reform  included  in  the  plan  aims  to  address  the  main  shortcomings  in  the 
second-pillar pension system (CSR 1 in 2019 and CSR 1 in 2022).  The planned reform will 
maintain  the  strengths  of  the  Dutch  pension  system  while  addressing  the  key  vulnerabilities  in 
terms of inter-generational fairness, transparency and shock resilience. The plan specifies that the 
legislative process is expected to be finalised in 2022, with the new legislation entering into force 
in 2023 and the new system gradually being phased in thereafter. 

The plan includes investments and reforms to accelerate the development of renewables and 
improving energy efficiency, in particular in buildings (CSR 3 in 2019, CSR 3 in 2020 and 
CSR 4 in 2022).  The plan focuses on further developing energy from offshore wind and renewable 
hydrogen.  An  ambitious  investment  programme  (‘Offshore  wind’)  aims  at  increasing  the  wind 
power generation in the North Sea ensuring the necessary entry and integration costs of offshore 
wind  farms  whilst  also  limiting  negative  externalities  on  the  environment.  The  deployment  of 
additional  capacity  from  renewable  energy  sources  is  also  supported  by  the  ‘Energy  Law’,  a 
comprehensive  reform  providing  the  legal  framework  for  necessary  investments  by  system 
operators to modify the grid to accommodate the expected increase in the transmission of energy 
generated  by  renewable  energy  sources.  Moreover,  the  reform  aims  to  optimise  permitting 
procedures  for  renewable  energy  projects.  The  transition  towards  clean  and  efficient  energy 
generation  and  use  is  further  reinforced  by  a  package  of  fiscal  greening  reforms  which  aim  to 
influence  the  behaviour  of  citizens  and  businesses  towards  supporting  the  green  transition.  A 
substantial financial envelope is reserved in the plan to improve the energy efficiency of the built 
environment. In particular, via the measure ‘Subsidy scheme for sustainability of public sector real 
estate’, which promotes renovations focusses on improving the energy efficiency of public sector 
buildings,  and  the  investment  ‘Investment  subsidy  for  sustainable  energy  and  energy  savings 
(ISDE)’, which awards grants for investments in small-scale heat pumps, solar boilers, insulation 
and heat connections.  

Important  measures  are  included  to  accelerate  investments  in  sustainable  transport  and 
sustainable agriculture (CSR 3 in 2019 and CSR 4 in 2022). Excessive nitrogen deposits are 
harming  the  environment  and  holding  back  construction.  The  plan  includes  two  investments 
supporting  the  mitigation  of  the  impact  and  root  causes  of  nitrogen  emissions,  the  ‘Nature 
programme’ and the ‘Aid scheme for the rehabilitation of pig farms’. These measures are expected 
to have a positive impact on the recovery of biodiversity and to enable the shift towards a more 
sustainable  agriculture  in  the  Netherlands.  When  it  comes  to  sustainable  transport,  the  plan 
includes  important  steps  towards  the  deployment  of  ERTMS  in  the  Dutch  railway  system. 
Moreover,  the  projects  ‘Inland  waterway  energy  transition,  project  ZES’  and  ‘Aviation  in 
transition’ will promote the development and use of zero emission vehicles used for water and air 
transport. In addition, investments are included to promote safe and sustainable mobility including 
intelligent traffic control systems and digital data mobility systems and the roll-out of intelligent 
roadside stations to improve traffic flows. 

The plan contains various measures aimed at increasing public and private investment and 
promoting research and innovation (CSR 3 in 2019 and CSR 3 in 2020). In the area of housing, 
the plan includes an investment project aimed at unlocking housing construction. The plan also 
contains measures to unlock investments in the green transition, including by removing obstacles 
for the development of offshore wind farms and by stimulating the roll-out of heat pumps. With 
regard to the digital transition, the plan includes measures that promote research and innovation 
which aim to leverage private investments in AI and quantum technology. Furthermore, the plan 

26 

 
contains investment support for green hydrogen projects, including support for small and large-
scale demonstration projects as well as a research programme focusing on the production, storage, 
transport and use of green hydrogen and investments to support the development of lightweight 
structures and electrical systems for flying hydrogen combustion and hydrogen fuel cell electric 
demonstrators. In 2020, the Dutch government announced the launch of a National Growth Fund 
(NGF).  The  aim  of  the  fund  is  to  support  projects  aimed  at  increasing  the  long-term  growth 
potential of the Dutch economy. Several NGF projects have been selected to receive funding under 
the RRP, thereby increasing their ambition by setting their goals in concrete milestones and targets.   

The plan contains measures to address the pandemic and to strengthen the resilience of the 
health system, including by tackling the existing shortages of health workers and stepping 
up the deployment of relevant e-health tools (CSR 1 in 2020). The plan includes investments 
which are expected to mitigate the shortage of human resources in the care sector in times of a 
health crisis via for example the establishment of a national care reserve and the increase of the 
Intensive  Care  capacity  during  the  COVID-19  pandemic.  In  addition,  measures  are  planned  to 
enable remote healthcare through the use of e-services and to strengthen data exchange between 
health institutions and for research. 

The plan partially addresses the need for investment in skills, education and training (CSR 
2 in 2019, CSR 3 in 2020 and CSR 3 in 2022).  The plan includes measures focussed on digital 
skills developments and contributes to addressing the shortage of ICT professionals by investing 
in the digital capacity of teachers and students at different levels of education, as well as by funding 
postgraduate and postdoctoral research in AI and quantum technology. The plan includes measures 
to improve access to digital public services via for example the digitalisation of criminal justice 
chains and the reform of transparency requirements for public bodies, but the Netherlands will 
need to pay continued attention to the accessibility of digital services for all citizens. The plan 
includes investments via the ‘Regional Mobility Teams’ and the ‘Netherlands continues to learn’ 
programme to strengthen up- and reskilling opportunities, for instance through the provision of 
career advice. However, given the remaining challenges related to labour and skills shortages and 
the  need  to  support  the  green,  digital  and  energy  transitions,  further  investments  to  strengthen 
comprehensive  lifelong  learning  opportunities  are  needed  and  targeted  support  for  up-  and 
reskilling remains necessary, in particular for the inactive and those at the margins of the labour 
market. The Netherlands has indicated that it aims to also use support via ESF+ and JTF to promote 
up- and reskilling activities for persons at the margins of the labour market (ESF+) or affected by 
the climate transition (JTF and, to a lesser extent, ESF+). Furthermore, (new) policy measures to 
strengthen comprehensive lifelong learning are expected to be announced in the autumn of 2022.  

Reforms and investments related to the functioning of the labour market, including measures 
to reduce the incentives for self-employed without employees, partially address the structural 
challenges as identified (CSR 2 in 2019, CSR 2 in 2020 and CSR 3 in 2022). The combined 
effect of the labour market reforms included in the plan is expected to help level the playing field 
between employed and self-employed, contribute to tackling bogus self-employment, including 
via increasing public enforcement, and increase the social protection coverage of self-employed 
(by  extending  it  with  a  disability  insurance).  Therefore,  these  measures  in  combination  are 
expected  to  contribute  to  address  the  identified  structural  challenges  related  to  reducing  the 
incentives  for  self-employed  without  employees.  However,  further  measures  will  be  needed  to 
reduce the incentives to use flexible or temporary employment contracts (in line with CSR 3 in 
2022). The plan includes specific measures to temporarily  alleviate the shortage of health care 

27 

 
workers in times of an acute crisis but does not sufficiently address labour shortages in many other 
sectors of the Dutch economy, nor the structural labour shortages in the health sector.  

The plan partially addresses the challenges related to the housing market and high private 
debt  in  the  Netherlands  (CSR  1  in  2019  and  CSR  1  in  2022).  The  plan  contains  extensive 
proposals  to  boost  housing  supply,  through  investment  support  and  reforms  to  speed  up  the 
planning process. On the demand side, the possibility of tax-free donations for house purchases is 
abolished, thereby lowering the incentive to take a large debt to purchase a house. The plan also 
contains measures with regard to the rental market, to reduce distortions in the social rental market 
and  reform  the  taxation  of  private  rental  houses.  However,  several  distortions  in  the  housing 
market remain unaddressed by the plan. The debt bias created by the generous mortgage interest 
deductibility remains in place, despite a gradual reduction in the deductibility rate in recent years. 
Borrowing  limits  also  remain  high  in  international  comparison.  This  creates  incentives  for 
households  to  hold  large  debt  positions,  which  makes  them  vulnerable  to  economic  shocks. 
Finally, the plan does not contain measures to significantly expand the private rental market, which 
is expected to remain small and therefore rather expensive.  

The recommendation to support wage growth and increase disposable income has not been 
addressed in the plan, but is expected to be partly accommodated by measures taken outside 
of  the  plan  (CSR  1  2019).  While  no  specific  measures  to  boost  wage  growth  and  disposable 
income are included in the plan, the authorities took measures in 2020 to reduce the tax burden on 
labour; they also decided on an extra minimum wage increase in 2023. Moreover, the authorities 
introduced measures in 2022 to cushion the impact of high inflation on households’ purchasing 
power and boost disposable income. 

European flagship initiatives  

The reforms and investments of the plan are aligned with the European “flagship initiatives” 
of  the  2021  Annual  Sustainable  Growth  Strategy:  power  up  (for  example  via  the  projects 
‘Offshore wind’ and ‘Green power of hydrogen’), renovate (for example via the subsidy schemes 
’Investment subsidy for sustainable energy and energy savings (ISDE)’  and ‘ Subsidy scheme for 
sustainability  of  public  sector  real  estate’),  recharge  and  refuel  (for  example,  the  ‘Aviation  in 
transition’ project and the measure ‘ Inland waterway energy transition, project ZES’), modernise 
(for example via the  ‘Digitalisation of the  criminal justice chain’  and investments in E-health), 
scale-up  (for  example  via  investments  under  ‘Quantum  Delta  NL’)  and  up-  and  reskilling  (for 
example via the ‘Regional Mobility Teams’ and the ‘Netherlands continues to learn’). 

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

28 

 
 
 
Table 6: Mapping of country challenges identified in 2019-2020-2022 country-specific 
recommendations and the Dutch recovery and resilience plan components [1] 

Country challenges 
(as 
in 
identified 
section 2) 

Associated 
CSR 
(2019-
2020-2022)  and 
European 
Semester 
recommendatio
ns 

Renewable 
energy,  energy 
infrastructure  & 
networks   

CSR 2019.3 
CSR 2020.3 
CSR 2022.4 

CSR 2019.3 
CSR 2022.4 

CSR 2022.4 

CSR  2019.1 
[2] 

CSR 2019.3 
CSR 2020.3 

Transport 

and 

Environmental 
policy 
resource 
management  – 
sustainable 
agriculture 
Wages  &  wage 
setting 

Research and 
Innovation and 
public and 
private 
investment 

Pension  systems 
and 
active 
ageing 

CSR 2019.1 
CSR 2022.1 

Housing 

Functioning  of 
labour 
the 
and 
market 
poverty 
and 
social inclusion  
Skills, 
Vocational 
Education 
and 
Training & adult 
learning 

CSR 2019.1 
CSR 2022.1 
CSR 2019.2 
CSR 2020.2 
CSR 2022.3 

CSR 2019.2 
CSR 2020.3 
CSR 2022.3 

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● 

Country challenges 
in 
identified 
(as 
section 2) 

Associated 
(2019-
CSR 
2020-2022)  and 
European 
Semester 
recommendatio
ns 

CSR  2019.1 
[3]CSR 
2020.4 [3] 

Tax 
administration, 
tax  evasion  & 
tax 
avoidance 
and  Anti-money 
laundering  

Healthcare 

CSR 2020.1 

● 

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. The Netherlands has generally responded adequately and sufficiently to the immediate 
need to support the economy through fiscal means in 2020, 2021 and 2022, in line with the provisions of the General 
Escape Clause. 

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

[3] This CSR was also addressed by the adoption of a substantial set 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.  Reforms  and investments  are 
fairly  evenly  distributed  over  the  timeframe  of  the  RRF.  Some  of  the  largest  investments,  for 
example on wind energy and the housing market, are expected to take their full effect in 2025 and 
2026. Key labour and energy market reforms will be implemented in 2025 and 2026. According 
to the plan, the short-term growth impact will be limited, with only a noticeable positive impact 
on GDP growth of 0.1% in 2021. However, many channels through which the plan is expected to 
contribute to growth both in the short and the longer term according to the national  qualitative 
impact assessment are not reflected in the national quantitative modelling. For example, neither 
spillover effects of other member states’ RRPs are considered, nor the productivity improvements 
due to public investments. According to the qualitative assessment, in the medium and longer term, 
the plan is indeed expected to enhance productivity and contribute to long-term growth, due to 
measures related to education, research and development and the further digitalisation of the Dutch 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
economy as well as energy and labour market reforms. There is no national estimate of the long-
term growth impact of the measures. According to the Commission’s QUEST model, the positive 
long-term real GDP effect is 0.2% of GDP in 2030 and 0.1% in 2040 (see Box 2). The national 
impact assessment also  cites the Commission’s estimates. The direct impact of the plan on job 
creation is estimated to  be rather limited. However, some measures in the plan are expected to 
support the supply of labour through education and training and will contribute to more efficient 
matching between supply and demand. 

Box 2: Stylised NGEU impact simulations with QUEST – The Netherlands 

Model simulations conducted by the Commission using the QUEST model show that the economic 
impact of Next Generation EU (NGEU) in the Netherlands  could lead to an increase of GDP of 
between 0.4% and 0.6% by 202610 and this impact would decrease gradually afterwards. After 20 
years, GDP could be 0.1% higher. Spillovers account for a large part of such impact. 11  

According to these simulations, which assume spending to have started in 2021 and spread over 6 years, 
this would translate into up to 22,000 additional jobs, about 0.2% of total jobs in the Netherlands in Q2 
2022.  Cross  border  spillovers  account  for  0.4  of  pps  of  GDP  in  2026,  showing  the  value  added  of 
synchronised expenditure across Member States (line 2 of Table 7). Even in a scenario with a lower 
productivity of NGEU funds, it would still lead to a significant impact (line 3).12 

Table 7: QUEST simulation results (deviation of real GDP level from non-NGEU case, linear 
disbursement assumption over 6 years)   

Scenario 

Baseline 

   of which 
spillover 

2021 

2022  2023  2024  2025  2026  2027  2028  2029  2030  2040 

0.4 

0.6 

0.6 

0.6 

0.6 

0.6 

0.5 

0.4 

0.3 

0.2 

0.1 

0.3 

0.4 

0.5 

0.5 

0.5 

0.4 

0.4 

0.3 

0.2 

0.1 

0.0 

Low productivity 

0.2 

0.3 

0.3 

0.3 

0.4 

0.4 

0.3 

0.2 

0.2 

0.1 

0.0 

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 

10 RRF amounts to roughly 90% of NGEU, which also includes ReactEU, Horizon, InvestEU, Joint Transition Fund, 
Rural Development and RescEU. 
11 Pfeiffer, P., Varga, J., in ‘t Veld, J. (2021), “Quantifying Spillovers of Next Generation EU Investment”, ECFIN 
Discussion paper 144. https://ec.europa.eu/info/sites/default/files/economy-finance/dp144_en.pdf. For consistency 
reasons, the simulations are based on the allocations assumed in Pfeiffer et al. (2021). In June 2022, 30% of the 
allocation of non-repayable financial support has been updated on the basis of outturn data. This resulted in a final 
allocation to the Netherlands of EUR 4.7 billion compared to the allocation of EUR 6 billion assumed in the 
simulation. Therefore, the direct effects of the NGEU stimulus in the Netherlands (i.e. the impact that does not stem 
from spillovers) can be about 20% lower than indicated in Table 7. 
12 Technically, the low productivity scenario considers a significantly reduced output elasticity of public capital. 

31 

 
                                                           
could raise the Netherlands’ GDP by 11% in 20 years’ time, in line with what was found for the EU 
average (Varga & in 't Veld, 2014).13 

Due  to  the  differences  in the  assumptions  and  methodology,  the  results  of  this  stylized  assessment 
cannot be directly compared to the numbers reported in chapter 4 of the Dutch RRP.  

Strengthening social and territorial cohesion and convergence 

The  plan  is  expected  to  further  improve  social  cohesion  in  the  Netherlands,  through 
investments into education and training, directly contributing to the implementation of the 
European  Pillar  of  Social  Rights,  as  well  as  in  energy  efficiency  and  affordable  housing. 
Social cohesion will be supported through measures aiming at education and training, targeting 
disadvantaged groups or pupils with educational deficits caused by the pandemic (Component 4). 
The same component also includes investments to increase the up- and reskilling opportunities to 
facilitate participation in the labour market of vulnerable groups.  

In light of recent energy price hikes, social cohesion is also expected to be strengthened by 
two large measures increasing investments into energy efficiency (Component 3). They are 
expected to increase jobs and investments temporarily while permanently reducing energy bills, 
which account for a larger proportion of income of less wealthy households’ than that of wealthier 
ones. Improving energy efficiency is also a cost-efficient way of realising the country’s target of 
achieving climate neutrality by 2050.  

The measures to improve conditions on the housing market (Component 3) are expected to 
contribute to social cohesion. Strong increases in house prices over recent years have worsened 
housing affordability significantly and measures in Component 3 are expected to increase supply 
of housing and thereby improve affordability by limiting future price increases. The abolishment 
of tax-free donations to first-time home buyers, a subsidy that mainly supported individuals from 
better-off families in acquisition of property for own use, is also expected to level the playing field 
on the demand side of the housing market to some degree.  

The plan includes measures that aim at enhancing territorial cohesion, in part by investing 
in digital infrastructure and sustainable mobility (Component 2). Investments into railways 
and smart mobility cover the whole territory and reinforce the integration of transport networks. It 
will  promote  safe,  sustainable  and  smart  mobility  for  both  people  and  goods.  Investments  to 
improve the digital  infrastructure and digital  skills  can support territorial  cohesion  by allowing 
more members of society to reap the benefits of working arrangements that are no longer tied to 
physical office spaces in cities. 

Investments  in  the  health  sector  are  also  expected  to  foster  territorial  cohesion  and 
convergence (Component 5). An investment included in the plan supported the use of e-health 
applications during the pandemic allowing vulnerable groups to receive health care at a distance. 

13  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.  

32 

 
 
                                                           
A more widespread use of e-health tools not only fostered social cohesion during the pandemic 
but may also contribute to territorial cohesion when applied in less densely populated areas.  

Reducing vulnerability and increasing resilience 

By  further  developing  digital  infrastructure  and  digital  skills,  the  plan  makes  the  Dutch 
economy more resilient to external shocks. The Netherlands’ advanced digital infrastructure has 
helped  the  country  weather  the  pandemic  relatively  well  economically.  Measures  in  the  plan 
related to digitalisation of public administration (Component 2) are expected to improve its ability 
to adjust to shocks. Digital skills in the population can be expected to further  improve through 
investments to provide pupils with better IT equipment and by introducing a systematic approach 
to the inclusion of digital education at different levels of the education system (Components 2 and 
4).  

Several measures in the plan contribute to reduce vulnerabilities linked to energy crises and 
the consequences of climate change. Investments into renewable energy and increased incentives 
to decarbonise the economy (Component 1) will make the country less dependent on fossil fuel 
energy  imports  while  investments  into  renovations  and  energy  efficiency  improvements 
(Component  3)  are  expected  to  reduce  energy  demand  substantially.  Resilience  against  the 
consequences of climate change is improved by investments into climate change adaptation in the 
public space (Component 3). 

The plan also includes reforms to improve the resilience of the pension system and the labour 
market. The combination of the proposed labour market reforms in Component 4 will decrease 
institutional  differences  on  the  labour  market  between  employed  and  self-employed  and  are 
therefore expected to contribute to more equal opportunities for all on the labour market while also 
improving social protection coverage for the self-employed. In addition, by reducing the incentives 
for self-employed and tackling bogus self-employment, these reforms are expected to make the 
labour market less vulnerable to shocks. Furthermore, the reform of the second pillar of the pension 
system is expected to contribute to make pension funds more resilient to shocks.  

Several measures in the plan support the public health sector and help to make it pandemic 
prepared (Component 5). This includes measures to expand intensive care during the COVID-
19 pandemic. The plan further builds on the experience gained during the COVID-19 pandemic 
and creates a national reserve of former health care professionals and equipment to deal with future 
pandemic  crises  and  emergencies.  At  the  same  time,  the  plan  supports  the  development  of 
nationally integrated health data, research infrastructure and e-health applications. These measures 
have helped increase resilience in the short term during the pandemic and are expected to make 
the health system more resilient in the future for acute crises.  

Finally, the plan contains several measures to reduce vulnerabilities related to aggressive tax 
planning and money laundering. Measures in Component 6 are expected to broaden the tax base 
including  by  ensuring  a  more  balanced  taxation  of  multinationals.  Anti-money  laundering 
measures included in  the same component are also expected to  contribute to  more institutional 
resilience.  Together,  these  measures  are  expected  to  ensure  efficient  public  administration  and 
sound governance. 

Taking into consideration all reforms and investments envisaged by the Netherlands, its recovery 
and resilience plan is expected to have a high impact on strengthening the growth potential, job 

33 

 
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 COVID19 
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. 

34 

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

The European Pillar of Social Rights provides the compass for upward convergence towards better 
working and living conditions in the European Union. The implementation of its twenty principles on 
equal  opportunities  and  access  to  the  labour  market,  fair  working  conditions,  social  protection  and 
inclusion, supported by the 2030 EU headline targets on employment, skills and poverty reduction, will 
strengthen the Union’s drive towards a digital, green and fair transition. This box provides an overview 
of the Netherlands' progress in achieving the goals under the European Pillar of Social Rights. 

The  Dutch  labour  market  performs  well  overall,  but  significant  challenges  remain  in  terms  of 
labour  market  segmentation  and  the  unfavourable  employment  and  social  situation  of  certain 
groups. The employment rate in the Netherlands is well above the EU average (82.5% versus 74.5% in 
Q1 2022). However, the high level of both non-standard flexible and temporary contracts and the number 
of self-employed without employees, which have been growing strongly over the last decade, remain a 
concern and require further attention in terms of challenges related to equal opportunities, fair working 
conditions  and  adequate  social  protection.  The  COVID-19  pandemic  exacerbated  risks  in  an  already 
highly segmented labour market. People with flexible contracts (in particular young people, lower skilled, 
people  with  a  migrant  background  and/or  with  disabilities)  were  among  the  groups  hit  the  hardest, 
together with the self-employed without employees. While the gender employment gap is on average 8.2 
pps in 2021, part-time employment remains widespread, in particular among women. As a result, the 
gender pension gap in the Netherlands is one of the largest in the EU. Under the European Social Fund 
Plus (ESF+), the Netherlands will continue to invest in the active inclusion of vulnerable groups, among 
which  people  with  a  migrant  background.  ESF+  resources  will  be  used  to  provide  up  and  reskilling 
opportunities to workers at the margins of the labour market and to prevent job losses.  

Increasing  labour  and  skill  shortages  and  inequalities  in  terms  of  access  to  education,  adult 
learning and up- and reskilling pose challenges, also in view of the green and digital transition. 
Improving  the  labour  market  outcomes  of  groups  in  an  unfavourable  employment  and/or  vulnerable 
social  situation  would  also  help  tackle  labour  shortages  and  activate  the  untapped  labour  and  skills 
potential. After several years of weak growth, adult participation in learning over the past four weeks 
decreased in 2020, but much less than in most countries (by 0.7 pps compared to 2019), and at 18.8% it 
was still more than double the EU average (9.1%). Following a break in time series, the participation rate 
increased  to  26.6%  in  2021  (EU  10.8%).  However,  outreach  to  those  in  a  vulnerable  labour  market 
situation  poses  a  challenge.  Continued  investment  in  improving  basic,  technical  and  digital  skills, 
increasing cross-sector mobility and employability, as well as strengthening the quality and inclusiveness 
of education and training for all, is key for the Netherlands to contribute to reaching the 2030 EU headline 
target on skills. The Netherlands committed to ensuring at national level that by the end of the decade at 
least 62% of adults will have participated in learning each year in the preceding 12 months. 

While the at-risk-of-poverty or social exclusion rate in the Netherlands is stable and well below the 
EU average, challenges remain for specific groups, such as people with a migrant background and 
those  with  disabilities.  In  2020,  36%  of  the  non-EU-born  living  in  the  Netherlands  were  at  risk  of 
poverty  or  social  exclusion,  22.5 pps  higher  than  among  the  native-born.  For  people  with  a  non-EU 
migrant background, the gap is driven by a more prevalent risk of poverty (29.7% versus 11.1% for the 
native-born),  linked  partly  to  a  more  unfavourable  employment  situation,  by  a  higher  rate  of  severe 
material deprivation (8.9% versus 1.1%) as well as greater prevalence of in-work poverty (14.9% versus 
4.6%). More than a quarter (29.3%) of children with foreign-born parents were at risk of poverty in 2020, 
which is over three times higher than for children with native born parents (9%). In addition, 24.9% of 
people with disabilities were at risk of poverty or social exclusion in 2020 (versus 12% of those without). 
In-work poverty risks are higher for people on flexible and/or temporary contracts as well as for the self-

35 

 
 
 
 
employed without employees. Challenges in terms of access to adequate social protection also remain 
for  the  self-employed  without  employees,  while  the  planned  introduction  of  a  mandatory  disability 
insurance for self-employed is an important step in the right direction. The Netherlands committed to lift 
163 000 people out of poverty or social exclusion by the end of the decade to contribute to reaching the 
2030 EU headline target on poverty reduction.  

Social Scoreboard for THE NETHERLANDS 

Equal opportunities and access to the 
labour market 

Dynamic labour markets and fair 
working conditions 

Social protection and inclusion 

Early leavers from education and training 
(% of population aged 18-24) (2021) 

Individuals' level of digital skills (% of 
population 16-74) (2021) 
Youth NEET 
(% of total population aged 15-29) (2021) 
Gender employment gap (percentage 
points) (2021) 
Income quintile ratio (S80/S20) (2020) 
Employment rate 
(% population aged 20-64) (2021) 
Unemployment rate 
(% population aged 15-74) (2021) 
Long term unemployment 
(% population aged 15-74) (2021) 

5.3 

79.0 

5.5 

8.2 

4.2 

81.7 

4.2 

0.8 

GDHI per capita growth (2008=100) (2020) 

106.9 

At risk of poverty or social exclusion (in %) 
(2020) 
At risk of poverty or social exclusion for 
children (in %) (2020) 
Impact of social transfers (other than 
pensions) on poverty reduction (% 
reduction of AROP) (2020) 

16.0 

15.8 

36.8 

Disability employment gap (ratio) (2020) 

25.4 

Housing cost overburden (% of population) 
(2020) 
Children aged less than 3 years in formal 
childcare (% of under 3-years-olds) (2020) 
Self-reported unmet need for medical care 
(% of population 16+) (2020) 

8.3 

67.6 

0.2 

Critical 
situation 

To watch 

Weak but 
improving 

Good but to 
monitor 

On average 

Better than 
average 

Best performers 

As presented in annex 12 of the 2022 Country Report for the Netherlands (SWD/2022/621 final). Members States are 
classified on the Social Scoreboard according to a statistical methodology agreed with the EMCO and SPC Committees. It 
looks jointly at levels and changes of the indicators in comparison with the respective EU averages and classifies 
Member States in seven categories. For methodological details, please consult the Joint Employment Report 2022. Due 
to changes in the definition of the individuals' level of digital skills in 2021, exceptionally only levels are used in the 
assessment of this indicator; NEET: neither in employment nor in education and training; GDHI: gross disposable 
household income. 

36 

 
 
 
4.4. The principle of ‘do no significant harm’ 

The Regulation establishing the RRF stipulates 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  Regulation14.  In  line  with  the  RRF 
Regulation and the Technical Guidance on the Application of ‘do no significant harm’ under the 
RRF  Regulation  (hereafter  ‘DNSH  Technical  Guidance’15),  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. The Netherlands has submitted a detailed 
DNSH assessment for each measure included in its plan. 

The  evidence  provided  on  the  criteria  used  for  the  selection  and  design  of  measures  is 
sufficient  to  conclude  that  no  measure  in  the  plan  is  expected  to  do  significant  harm  to 
environmental  objectives.  Many  measures  included  in  the  plan  contribute  substantially  to 
environmental  objectives,  or  have  no  or  an  insignificant  foreseeable  impact  on  environmental 
objectives, and are therefore considered DNSH compliant from the outset (e.g. certain measures 
in  education  and  training,  labour  market,  public  administration,  and  health  care).  Other  (sub-) 
measures are designed in such a way to ensure compliance with DNSH, such as the subsidy scheme 
to produce green hydrogen and the investment programme to ensure shipping safety near offshore 
wind  parks.  For  measures  requiring  a  ‘substantive  DNSH  assessment’  according  to  the  DNSH 
Technical Guidance (e.g. sustainable mobility, industrial policy, digitalisation), the Netherlands 
has provided an assessment and substantiated that the measures do not lead to significant harm. 

For measures whose impact on the six environmental objectives necessitate close scrutiny, 
the  description  of  measures,  milestones  and  targets  defines  the  specific  safeguards  and 
commitments that are required during their implementation. In particular, for the emergency 
response towing vessels under ‘Offshore wind’, DNSH compliance is safeguarded by the inclusion 
of specific conditions in the measure description specifying that: (a) the vessels shall exclusively 
use green methanol compliant with the Renewable Energy Directive (EU) 2018/2001 (RED II), 
(b) the green hydrogen  used for the production of green methanol  shall comply with  life cycle 
greenhouse gas emissions savings requirement of 73.4% for hydrogen and (c) the green methanol 
shall achieve at least 70% emissions savings in accordance with RED II and related implementing 
and  delegated  acts.  For  the  ‘Nature  programme’  and  ‘Offshore  wind’  measure  safeguards  are 
included  to  ensure  that  Environmental  Impact  Assessments  (EIA)  shall  be  completed  in 
accordance  with  Directive  2011/92/EU  (Environmental  Impact  Assessment  Directive).  For  the 
hydrogen demonstration facilities under ‘Green power of hydrogen’ the target description specifies 
that  the  measure  shall  support:  the  production  of  hydrogen  from  electrolysis  using  renewable 
energy sources as defined in Directive (EU) 2018/2001 (Renewable Directive) or electricity from 
the electricity grid, or hydrogen activities that meet the requirement of 73.4% life-cycle savings of 
greenhouse  gas  emissions  for  hydrogen  (resulting  in  life-cycle  GHG  emissions  below  3  t. 
CO2e/tH2) and 70% for hydrogen-based synthetic fuels compared to a fossil fuel comparator of 

14  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. 
15 COM (2021) C58/01, Technical Guidance on the Application of ‘do no significant harm’ under the Recovery and 
Resilience Facility Regulation 

37 

 
                                                           
94g  CO2e/MJ,  similar  to  the  approach  set  out  in  Article  25  (paragraph  2)  of  and  Annex  V  to 
Directive (EU) 2018/2001.  

The measures ‘Green power of hydrogen’ and ‘Investment subsidy for sustainable energy 
and energy savings (ISDE)’ could potentially lead to investments being made in installations 
falling within the scope of the EU Emission Trading System (ETS). DNSH compliance of these 
measures is ensured by the safeguard that only projects with emissions substantially below ETS 
benchmark are eligible for support under the measures. The DNSH Technical Guidance sets out 
that for economic activities where there is no technologically and economically feasible alternative 
with  low  environmental  impact,  Member  States  may  demonstrate  that  a  measure  does  no 
significant harm by adopting the best available levels of environmental performance in the sector. 
In  the  context  of  the  EU  ETS,  this  is  particularly  relevant  for  the  climate  change  mitigation 
objective. Among other conditions, the Netherlands has sought to ensure DNSH compliance by 
making the selection of supported projects conditional upon achieving GHG emissions that are at 
least  below  the  relevant  benchmarks  established  for  the  free  allocation  of  ETS  emission 
allowances16.  Where  the  emission  reductions  are  not  substantially  lower  than  the  relevant 
benchmarks,  the  Netherlands  has  committed  to  provide  an  explanation  on  why  this  level  of 
emission reductions cannot be achieved.  

The building construction and renovation measures included in the  plan comply  with the 
DNSH principle. Whereas these measures have a positive impact on emission reductions, they 
generally  create  construction  waste.  In  the  DNSH  self-assessment  for  these  measures,  the 
Netherlands  invokes  national  legislation  (in  particular  Article  8.8  of  the  Building  Decree 
“Bouwbesluit”,  Article 10.4  of  the  Environmental  Protection  Act  “Wet  Milieubeheer”  and  the 
Waste  Landfills  and  Prohibition  of  Landfill  Decree  “Besluit  Stortplaatsen  en  Stortverboden 
Afvalstoffen”), to ensure that no significant harm is done to the circular economy objective and 
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. In this 
regard,  the  Netherlands  also  confirms  that  is  has  a  99.9%  ratio  of  construction  and  demolition 
waste which is  prepared for re-use, recycled or subject  to  material  recovery, including through 
backfilling  operations.  The  Netherlands  has  provided  a  similar  confirmation  for  all  demolition 
works to be undertaken as part of the ‘Aid scheme for the rehabilitation of pig farms’. In addition, 
the  plan  highlights  that  the  measures  involving  building  construction  and  renovation  will  not 
include  support  for  the  installation  of  gas-condensing  boilers.  The  ‘Investment  subsidy  for 
renewable  energy  and  energy  savings  (ISDE)’  finances  only  the  heat  pumps  for  producing 
renewable energy and not the gas boiler in the case of a hybrid installation. 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation  of  reforms  and investments  projects included in  the  Netherlands’ 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 to the RRF 
Regulation. 

16 Benchmarks as set out in the Commission Implementing Regulation (EU) 2021/447. 

38 

 
                                                           
4.5. Green transition 

Climate target 

The Dutch plan dedicates EUR 2.25 billion to the climate objectives, which represents 47.8% 
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 8 presents the contribution of all 
measures  that  contribute  to  the  climate  change  objectives.  The  investments  included  in  the 
Component ‘Promoting the Green Transition’ (Component 1) make up the largest share of the total 
climate contribution of the plan. These investments contribute towards climate change objectives 
through a variety of interventions, ranging from broad investments supporting the deployment of 
offshore  wind  energy  and  the  restoration  of  Natura  2000  areas,  to  more  specific  investments 
upscaling the production of green hydrogen and introducing sustainable mobility solutions. These 
investments are complemented by a package of fiscal greening reforms having the objective  of 
setting a fair price for GHG emissions and energy consumption so that citizens, businesses and 
social institutions have a stronger incentive to adapt their behaviour towards supporting the green 
transition.  

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.  Whenever  a  selected  intervention  field  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 conform to the conditions set out in Annex VI to the RRF Regulation. The Dutch 
plan does not propose to increase the climate coefficient for any of the measures. 

39 

 
 
 
Table 8: Contribution to climate objectives per measure  

Measure 

P1.1I1  Offshore wind 
P1.1I2  Green power of hydrogen 
P1.1I3 

Inland waterway energy 
transition, Project ZES 

P1.1I4  Aviation in transition 
P1.2I1  Nature programme 
P1.2I2  Aid scheme for the rehabilitation 

of pig farms 

P2.1I3  Digital Infrastructure Logistics 

(DIL) 

P2.2I1  European Rail Traffic 

Management System (ERTMS) 

P2.2I2  Safe, smart and sustainable 

P2.2I3 

mobility 
Intelligent Roadside Stations 
(IWKS) 

P3.1I1  Unlocking new construction 

projects 

P3.2I2 

P3.2I1  Subsidy scheme for sustainability 
of public sector real estate 
Investment Subsidy Scheme for 
Renewable Energy and Energy 
Saving (ISDE) 
Total 

Cost  
(EUR mln) 
693.7 
68.5 
56.0 

28.7 
714.3 
275.1 

36.2 

149.0 

55.3 

128.9 

538.0 

225.3 

624.0 

Climate contribution 
(EUR mln) 

469.48 
68.5 
56.0 

28.7 
285.7 
110.0 

14.5 

59.6 

22.1 

51.6 

236.2 

225.3 

624.0 

Climate 
contribution (%)* 
10.0 
1.5 
1.2 

0.6 
6.1 
2.3 

0.3 

1.3 

0.5 

1.1 

5.0 

4.8 

13.3 

3 358.6 
* Please note that the climate contribution (%) is calculated based on the Netherlands’ total allocation 
(EUR 4,707 million) 

2 251.8 

47.8 

The recovery and resilience plan contributes to the Netherlands’ 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. The 
measures included in the plan will increase investments in the climate transition of industry as well 
as  energy  efficiency  in  housing,  contribute  to  the  development  of  renewable  energy  sources, 
encourage sustainable transport modes, restore biodiversity in natural habitats and support the shift 
toward sustainable agriculture. Investments and reforms also address the following flagships as 
put forward in the 2021 Annual Sustainable Growth Strategy: power up (‘Offshore wind’, ‘Energy 
Law’),  renovate  (‘Subsidy  scheme  for  sustainability  of  public  sector  real  estate’,  ‘Investment 
subsidy for renewable energy and energy saving (ISDE)’) and recharge and refuel (‘Aviation in 
transition’,  ‘Inland  waterway  energy  transition,  project  ZES’).  Moreover,  the  investments  and 
reforms  included  in  the  plan  will  contribute  towards  reaching  the  ambitions  set  out  in  the 
REPowerEU Communication. 

Renewable energy  

The  plan  includes  investments  to  support  renewable  energy  generation  and  use.  The  plan 
focuses on further developing energy from offshore wind and renewable hydrogen. An ambitious 
investment programme aims at increasing the wind power generation in the North Sea by 10.7 
gigawatts (GW) to a total of 21.0 GW. Rather than focusing on the construction of offshore wind 

40 

 
parks  themselves,  which  is  expected  to  be  covered  by  private  investments  indirectly  financed 
through the electricity price, the programme focuses on the entry  and integration costs and the 
mitigation of negative externalities that are prerequisites for the deployment of these parks, such 
as ensuring shipping safety, nature enhancement and species protection as well as the integration 
of the power connection to land. The Netherlands will also invest considerably in the development 
of the green hydrogen ecosystem in the Netherlands with the objective of testing the feasibility of 
large-scale electrolysis, to further develop the technology and to ensure sufficient supply of trained 
personnel.  The  upscale  of  green  hydrogen  production  is  expected  to  result  in  significant  price 
reductions  for  businesses  and  consumers.  Finally,  the  deployment  of  additional  capacity  from 
renewable  energy  sources  is  also  supported  by  the  ‘Energy  Law’,  a  comprehensive  reform 
providing the legal framework for necessary investments by system operators to modify the grid 
to accommodate the expected increase in the transmission of energy generate by renewable energy 
sources.  Moreover,  the  reform  aims  to  optimize  permitting  procedures  for  renewable  energy 
projects. 

Green fiscal policy 

The transition towards clean and efficient energy generation and use is further reinforced 
by  a  package  of  fiscal  greening  reforms.  An  ambitious  ‘Energy  taxation  reform’  seeks  to 
incentivise  businesses  and  households  to  switch  to  more  climate-friendly  energy  sources  by 
simultaneously increasing the tariff for gas consumption and decreasing the tariff for electricity 
consumption.  In  addition,  the  reform  also  abolishes  tax  exemptions  for highly  emitting  sectors 
such as glasshouse horticulture as well as metallurgy and mineralogy. The energy transition by 
industry is supported by the measure ‘Introduction and tightening of the CO2 levy for industry’, 
defining a minimum price for CO2 emissions by industry (in case the price set by the European 
Emissions Trading System is lower than this price floor), with an expected CO2 reduction target 
of 18.3m tonnes by 2030. Finally, the ‘Reform of car taxation’ and the increase in the rate for the 
‘Increase in the Air Travel Tax (ATT)’ are expected to reduce GHG emissions by road and air 
transport. GHG emissions by road transport are also expected to be reduced by the digital mobility 
solutions included in Component 2 (Digital Transformation) that have the objective to optimise 
traffic flows (‘Safe, smart and sustainable mobility’, ‘Intelligent  roadside  stations’ and ‘Digital 
Infrastructure Logistics (DIL)’). 

Energy efficiency 

The plan earmarks a substantial financial envelope to improve the energy efficiency of the 
built environment. The ‘Subsidy scheme for sustainability of public sector real estate’ aims to 
incentivise  the  owners  of  buildings  with  a  social  function  (i.e.  local  and  regional  authorities, 
educational institutions, health institutions and other cultural and welfare institutions) to improve 
the energy performance of their buildings through renovation actions. The ‘Investment subsidy for 
renewable  energy  and  energy  savings  (ISDE)’,  providing  grants  for  investments  in  small-scale 
heat pumps, solar boilers, insulation measures and heat connections, is extended using RRF funds 
to increase the subsidy rate for heat pumps from 20% to 30% per installation.  By reducing the 
energy consumption of buildings and using alternative forms of energy generation in buildings, 
both measures contribute towards the Netherlands’ objective to achieve maximum CO2 emissions 
by the built environment of 10 Mton in 2030. 

41 

 
 
 
Sustainable mobility 

Several measures in the plan are dedicated to promoting the development and use of zero 
emission vehicles  used for water and air  transport.  The ambitious project  ‘Inland waterway 
energy  transition,  project  ZES’  provides  investment  support  for  the  use  of  interchangeable 
Modular  Energy  Containers  (MECs),  which  can  be  charged  with  green  electricity  at  several 
loading sites in new and converted inland waterway vessels. Breaking away from the traditional 
model wherein a skipper owns an entire vessel including the propulsion system, the project aims 
to offer a future-proof, affordable and scalable solution for zero emission inland shipping. ZES is 
not only expected to reduce CO2 emissions per vessel by an average of 1250 tonnes but is also 
expected to benefit the Netherlands’ structural approach to nitrogen, given that vessels making use 
of MECs do not emit nitrogen. The measure ‘Aviation in transition’ promotes the development of 
ultra-efficient aircrafts using hydrogen as an energy carrier. This includes investment support for 
the development and modification, in-flight testing and demonstration of components and systems 
in flight based on hydrogen combustion or hydrogen fuel cells. The programme will contribute 
towards making the aviation sector more sustainable, in view of achieving climate neutrality of 
the sector by 2050.  

The transition towards sustainable mobility is also supported by measures discouraging the 
use of road and air transport. The ‘Reform of car taxation’ will introduce a system of pay-for-
use by making the car tax rate for cars and vans dependent on the number of kilometres driven. In 
addition, the reform will phase out the purchase tax exemption for fossil-fuelled commercial vans, 
while maintaining the exception for electric vans. With an expected CO2 reduction of 2.5m tonnes 
in 2030, the reform is expected to contribute significantly towards reaching the national reduction 
target that has been set for the mobility sector. The flat rate charged to travellers using air transport 
‘Increase in the Air Travel Tax (ATT)’ leads to relatively high costs for short distance flights and 
is  expected  to  increase  the  attractiveness  of  the  international  trains  as  an  alternative  means  of 
transport.  Finally,  the  implementation  of  the  ‘European  Rail  Traffic  Management  System 
(ERTMS)’  will  increase  rail  network  capacity  and  make  it  easier  and  faster  for  trains  to  cross 
national borders, making the use of trains even more attractive. 

Climate change adaptation and mitigation through biodiversity actions 

Making residential neighbourhoods in the Netherlands more resilient to the consequences of 
climate change is supported by a measure in Component 3. The main purpose of the investment 
‘Unlocking new construction projects’  is  to  help  municipalities finance public infrastructure to 
enable private residential construction projects to start. In many cases, these necessary works in 
the public space include ambitious climate change adaptation actions regarding flooding, but also 
against heat, drought and to improve nature inclusiveness. 

The plan aims to restore biodiversity and reduce nitrogen depositions, which is one of the 
main  environmental  challenges  the  Netherlands  is  facing.  The  comprehensive  ‘Nature 
programme’  aims  to  contribute  towards  achieving  favourable  or  improved  conservation  status 
conditions for all species and habitats under the Birds and Habitats Directives. The programme 
includes a measure to restore nature, with a particular focus on system restoration in and around 
congested  nitrogen-sensitive  Natura  2000  sites.  The  ‘Aid  scheme  for  the  rehabilitation  of  pig 
farms’ aims at reducing the odour nuisance attributable to livestock manure for nearby residents 
and nitrogen depositions by providing subsidies to pig farmers who permanently and irrevocably 
cease their pig farming activities.  

42 

 
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. 

4.6. Digital transition 

Digital tagging  

Reforms and investments contributing to digital objectives account for 25.6% of the plan’s 
total allocation. A substantial contribution stems from Component 2 focusing on accelerating the 
digital transformation. This component consists of three sub-components: (i) promoting innovative 
technologies and digital skills, (ii) developing smart mobility solutions and (iii) modernising IT in 
public  administration.  In  addition,  measures  on  digital  education  (Component  4)  and  e-health 
(Component 5) are expected to make notable contributions to facilitating the digital transition. 

The plan correctly follows the methodology for digital tagging set out in Annex VII of the 
RRF regulation, by identifying intervention fields, and applying corresponding coefficients for 
the calculation of support to the digital objectives, for each measure (the table in Annex presents 
the detailed application of the digital tagging methodology).  The Dutch plan does not propose to 
increase the digital coefficient for any of the measures. It should be noted that some measures of 
the  RRP  have  been  split  into  sub-measures.  For  each  sub-measure,  the  intervention  field  is 
indicated and the digital contribution is computed. This concerns in particular a measure on AI in 
Component 2 of the plan, which consists of separate sub-measures for developing AI applications 
for  the  economy  as  well  as  for  academic  programmes  promoting  further  research  into  AI.  The 
choice of intervention fields for the digital transition is well justified and reflects the nature, focus, 
objective or expected outcome of the investments. 

43 

 
 
 
Table 9: Contribution to digital objectives per measure  

Measure 

Cost (EUR mln)  

Digital 
contribution (EUR 
mln) 

Digital 
contribution (%)* 

P2.1I1  Quantum Delta NL 
P2.1I2  AiNed and applied AI learning 

communities 
P2.1I3  Digital education impulse  
P2.1I4  Digital Infrastructure Logistics 

(DIL) 

P2.2I1  European Rail Traffic 

P2.2I2 

P2.2I3 

Management System (ERTMS) 
Safe, smart and sustainable 
Mobility 
Intelligent Roadside Stations 
(IWKS) 

P2.3I1  Groundbreaking IT (GrIT) 
P2.3I2  Digitalisation of the criminal 

justice chains 
P4.2I1  National education lab AI 
P4.2I5  Laptops and tablets for online and 

hybrid education to combat and 
mitigate learning losses 
Set COVID-19 

P5.1I3 
P5.1I4  Health Research Infrastructure 

(HRI) 

Total 

263.9 
59.9 

209.4 
36.2 

149.0 

55.3 

128.9 

94.1 
75.2 

36.0 
24.0 

50.0 
22.0 

263.9 
59.9 

209.4 
36.2 

149.0 

55.3 

128.9 

94.1 
75.2 

36.0 
24.0 

50.0 
22.0 

5.6 
1.3 

4.4 
0.8 

3.2 

1.2 

2.7 

2.0 
1.6 

0.8 
0.5 

1.1 
0.5 

1 203.8 

1 203.8 

25.6 

* Please note that the digital contribution (%) is calculated based on the Netherlands’ total allocation 
(EUR 4,707 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.  The  plan  focusses  on 
promoting innovative technologies, digital education, digital mobility and upgrading IT systems 
used  by  the  public  sector.  This  includes  measures  to  foster  digitalisation  in  lower  and  tertiary 
education,  quantum  computing,  artificial  intelligence,  digital  logistics  management,  ERTMS, 
improving the efficiency and safety of passenger transport, digitalisation of the justice system and 
e-health.  Investments  and  reforms  also  address  the  following  flagships  as  put  forward  in  the 
Annual Sustainable Growth Strategy: modernise (’Groundbreaking IT (GrIT)’, ‘Digitalisation of 
the  criminal  justice  chain’)  and  up-  and  reskilling  (‘Digitalisation  education  impulse’,  ’Digital 
Infrastructure Logistics (DIL)’).  

The actions put forward in the plan are coherent with the relevant national strategies and 
plans  in  the  digital  domain.  Investments  in  quantum,  AI,  digitalisation  of  the  justice  system, 
improvement of IT systems in the public sector, and investment in digital skills and education are 
in  line  with  the  actions  set  out  in  the  Dutch  Digitalisation  Strategy,  first  adopted  in  2018,  and 
updated in 2019, 2020 and 2021 by the Ministry of Economic Affairs and Climate Policy17. This 

17 https://www.nederlanddigitaal.nl/documenten/publicaties/2021/06/22/the-dutch-digitalisation-strategy-2021-eng 

44 

 
                                                           
strategy brings together all central government policy on digitalisation, in close conjunction with 
the Dutch Cybersecurity Agenda and the Digital Government Agenda. Current priorities of the 
strategy are (i) artificial intelligence, (ii) better and responsible use of data, (iii) digital government, 
(iv) digital connectivity, (v) digital security and resilience, and (vi) digital skills and inclusion. To 
prepare its population for future developments, the Netherlands has launched a foresight report 
‘Digitalisation 2030’18, which describes major economic, technological and societal trends likely 
to be impacted by the digital transition. 

The measures in the plan are expected to contribute to three of the four strategic priorities 
identified  at  EU  level.    These  were  also  reaffirmed  in  the  recent  communication  on  Europe’s 
Digital  Decade19:  digital  skills,  digital  infrastructures  digital  transformation  of  businesses  and 
digitalisation of public services. The plan does not contain any planned participation in Important 
Projects of Common European Interest (IPCEI) for advanced technologies, even though it includes 
investment measures in quantum and artificial intelligence.  

The  plan  foresees  several  measures  to  make  best  use  of  the  opportunities  of  the  digital 
transition in the public sector. A reform of the law on open government aims to make all public 
authorities and semi-public authorities more transparent. The law is expected to make public sector 
information  more  easily  findable,  interchangeable  and  easy  to  access  digitally  for  citizens, 
journalists, Members of Parliament and staff. Investments into the justice system aim to digitalise 
relevant steps in criminal proceedings. These investments will enable the sharing of documents 
digitally and it will make audio and video material related to cases available to all parties involved. 
The  investments  aim  to  increase  the  efficiency  of  criminal  proceedings  by  doing  away  with 
existing inefficiencies, in particular those linked to processing of the relevant paperwork. The plan 
also includes an investment aimed to renew the IT infrastructure of the Ministry of Defence by 
setting up a new IT infrastructure to enable the Ministry to use reliable, secure, future-proof and 
flexible systems. 

The Dutch plan contains notable measures to support the development of digital skills and 
the application of new digital solutions could help mitigate skills and labour shortages. In the 
area  of  education,  the  Dutch  plan  contains  measures  that  will  improve  students’  access  to  IT 
equipment and introduce a systematic approach to the inclusion of digital education at different 
levels  of  the  education  system.  These  measures  are  expected  to  improve  the  ICT  skills  of  the 
workforce in the long term, which could contribute to meeting some of the unmet demand for ICT 
professionals across the different sectors of the economy. 

The plan includes investments in innovative technologies that are fundamental to the digital 
transition.  In  particular,  the  plan  allocates  sizeable  funding  to  quantum  technologies  and  AI. 
Regarding AI, the Netherlands is committed to European cooperation and appropriate ethical and 
legal  frameworks.  The  Netherlands  seeks  to  connect  with  other  EU  Member  States  through  a 
learning approach to develop and exploit AI on a human-centric basis and by involving SMEs in 
order to make the best use of AI. The measure on quantum technology will contribute to the already 
strong quantum ecosystem in the Netherlands. The Quantum Delta NL foundation coordinates the 

18 https://www.rijksoverheid.nl/documenten/kamerstukken/2021/04/26/toekomstverkenning-digitalisering-2030 
19 COM(2021) 118 - 2030 Digital Compass: the European way for the Digital Decade, 9 March 2021 

45 

 
                                                           
national  quantum  technology  agenda,  which  facilitates  cooperation  between  and  innovation  by 
students, researchers, engineers and entrepreneurs.  

Investments  in  digital  mobility  are  expected  to  help  addressing  accessibility  and 
sustainability in a densely populated country that is prone to congestion. The digital logistics 
measure aims to improve cooperation between logistics firms to make more efficient use of goods 
transport capacity. Digitalisation in this sector could achieve efficiency gains and prevent trucks 
from  driving  empty. The measures  ‘Safe, smart  and sustainable mobility’, ‘Intelligent  roadside 
stations’ and ‘European Rail Traffic Management System (ERTMS)’ focus on a more efficient use 
of existing infrastructure, which is expected to reduce the distance driven and reduce congestion. 

Finally, the digital measures included in the plan will make the Netherlands more resilient. 
In  particular,  many  of  the  digitalisation  measures  included  in  the  plan  pay  attention  to  cyber 
security aspects. This is relevant for the digital systems of the public sector, in particular in the 
case  of  the  investment  in  the  digital  systems  of  the  Ministry  of  Defence  (‘Groundbreaking  IT 
(GrIT)’),  but  also  in  highly  innovative  and  competitive  areas  of  digital  enterprise,  including 
investments  in  quantum  computing  and  artificial  intelligence.  The  proposed  reforms  and 
investments aim at improving the efficiency of public services, including the justice system, and 
at  improving  the  security  of  hybrid  working  by  public  officials.  Furthermore,  investment  in  e-
health are expected to improve the resilience of the healthcare system.  

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 

Structural change in administration and institutions 

Measures  included  in  the  digital  component  of  the  plan  are  expected  to  lead  to  a  lasting 
improvement in efficiency of public services (Component 2). Investments into the digitalisation 
of  the  criminal  justice  system  are  expected  to  result  in  efficiency  gains.  Investments  in  the  IT 
systems  of  public  institutions  will  improve  their  efficiency  both  internally  and  in  dealing  with 
external stakeholders. 

Structural change in policies 

The Dutch energy market is expected to undergo structural changes as a result of the reform 
included in the plan. The “Energy Law” (Component 1) is expected to facilitate investments into 
the  electricity  grid,  allowing  consumers  to  sell  self-produced  energy  and  harnessing  data  for 
smarter  electricity  grids.  The  reform  as  a  whole  is  expected  to  lead  to  a broad  overhaul  of  the 
regulatory framework of the Dutch electricity and gas market. 

Other measures in Component 1 imply changes in green fiscal policy which have structural 
effects. The tax incentives framework will be influenced for years to come by the fiscal reforms 
that are designed to dis-incentivize the use of fossil fuels and reduce greenhouse gas emissions. 
The  ‘Energy  taxation  reform’,  ‘Introduction  and  tightening  of  the  CO2  levy  for  industry’,  the 

46 

 
‘Reform of car taxation’ and the ‘Increase in the Air Travel Tax’ are expected to contribute durably 
to behavioural changes resulting in lower fossil fuel consumption and less road congestion.  

The plan contains several measures to address features of the Dutch tax system that facilitate 
aggressive  tax  planning.  As  part  of  its  RRP  (Component  6),  the  Netherlands  is  structurally 
addressing  the  aggressive  tax  planning  features  of  the  Dutch  tax  system  by  implementing 
withholding taxes on interest, royalties and dividends paid to low-tax countries. At the same time, 
the  plan  describes  the  Dutch  action  plan  on  anti-money  laundering,  from  which  two  actions, 
namely the introduction of a limit for cash payments and the expansion of the efforts of the Dutch 
Financial Intelligence Unit, will be implemented as part of the RRP. 

Many reforms and investments included in the RRP are key priorities of government policy 
over the next years. All commitments taken in the RRP by the Netherlands are consistent with 
and  backed  up  by  the  agenda  of  the  Dutch  government  expressed  in  its  2021-2025  coalition 
agreement. The pension reform in  Component 4 is the result of intensive negotiations between 
social partners and the government. The impact of the reform will be felt over the next decades. 
Reforms on the housing market are also expected to have effects well beyond the time frame of 
the RRF (Component 3). The reform ‘Centralised planning to increase housing supply’ foresees 
binding agreements between the government and local governments to build 900 000 dwellings 
until 2030. Measures to speed up the residential construction process are also expected to have an 
impact on housing supply in the Netherlands beyond the time frame of the RRF. 

Lasting impact 

The measures included in the plan are expected to have lasting positive effects on the Dutch 
economy  and  boost  its  green  and  digital  transitions.  The  plan  is  expected  to  strengthen  the 
growth potential of the economy and to facilitate job creation, innovation and competitiveness by 
investments into renewable energy, the further digitisation of the Dutch economy as well as the 
education system.    

The digital and technology-oriented measures in the plan are expected to provide benefits to 
the Dutch economy over the longer term. Future-oriented investments into the digitalisation of 
the Dutch economy, for example through more widespread use of AI or quantum computing are 
expected  to  have  a  long-lasting  impact  on  competitiveness  and  productivity,  while  measures 
supporting  digital  skills  development  may  contribute  to  addressing  the  shortages  of  ICT 
professionals in many sectors of the economy in the medium term.  

The measures in the plan are expected to strengthen the growth potential of the economy 
and  its  inclusiveness  by  levelling  the  playing  field  in  the  labour  market  and  making  the 
education and research systems future proof. For example, the reforms related to self-employed 
people will tackle some of the structural challenges identified, while stimulating up- and reskilling 
opportunities  will  contribute  to  creating  a  labour  pool  able  to  quickly  adapt  to  changing 
circumstances. The focus on education and research will benefit the economy in the long-term. 

The  plan  also  includes  measures  that  contribute  to  a  structural  reduction  of  nitrogen 
emissions from agriculture, industry and transport with the aim of meeting the legislated 
nitrogen targets. For example, the ‘Aid scheme for the rehabilitation of pig farms’ aims to reduce 
nitrogen depositions providing subsidies for pig farmers who permanently and irrevocably cease 

47 

 
their  pig  farming  activities.  The  ‘Nature  programme’  aims  to  realize  a  lasting  favourable 
conservation status of overloaded nitrogen-sensitive habitats and species.  

Taking into consideration all reforms and investments envisaged by the Netherlands 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  the  Dutch  recovery  and  resilience  plan  will  be  based  on  the 
Netherlands’  existing  system  of  budgetary  management  and  governance.  In  line  with  this 
system, the policy directorates in the various ministries are the primary bodies responsible for the 
implementation of the measures in the RRP. The milestones and targets of the measures included 
in the RRP will be included in an annex to the annual plans of the various ministries.  The financial 
economic affairs directorates (FEZ) of the various ministries will monitor the policy directorates 
in relation to the progress of the milestones and targets and the monitoring process of the policy 
directorates. A dedicated RRF Programme Directorate in the Ministry of Finance will act as the 
coordinating body and will in that role be responsible for the overall coordination of the Dutch 
recovery and resilience plan, reporting on the progress of milestones and targets, submitting the 
payment requests and drawing up of the management declaration. As a result, and in accordance 
with  existing  structures,  the  Programme  Directorate  will  rely  on  a  decentralised  system  of 
departmental budgets and sub declarations. A milestone to be achieved before the first payment 
request relates to the formalisation of the role of the coordinating body as foreseen in the plan (see 
also 4.10).  

The plan describes the institutional actors that are responsible for the implementation of the 
individual  reforms  and  investments  at  component  level.  The  various  actors  that  will  be  in 
charge of the implementation of the measures, mainly policy directorates in various ministries and 
authorities under their control, are indicated in the description of the components of the plan. Close 
technical cooperation between the Ministry of Finance, various ministries and independent public 
bodies  will  be  critical  for  the  plan’s  implementation.  More  broadly,  involving  the  national 
Parliament, local authorities, social partners and civil society will be key to ensure the successful 
implementation of the reforms and investments under the plan. 

The  plan  describes  adequately  the  intended  monitoring  and  reporting  mechanisms.  The 
Programme Directorate will prepare general guidelines for a model annex which will define how 
milestones and targets are to be reported, accompanied by additional evidence. This annex will 
become part of the annual reports of the various ministries, and it will be integrated in the internal 
planning and control cycle. The Financial Economic Affairs Directorates (FEZ) of each ministry 
will supervise the implementing bodies on the progress of the milestones and targets. Via the annex 
and sub declarations implementing bodies will have to provide information on the progress related 
to  milestones  and  targets.  The  information  is  systematically  maintained  in  the  departmental  IT 
systems  and  shared  with  the  Programme  Directorate  on  biannual  basis  as  part  of  the  reporting 
obligations  and  to  ensure  consistency  and  continuity.  The  data  will  also  be  stored  in  a  central 

48 

 
repository.  This  central  repository  will  be  developed  and,  as  far  as  possible,  linked  to  existing 
European and national IT systems. A milestone is included in the plan for the development of the 
central repository system (see also 4.10). 

The necessary administrative resources for the management and supervisory function of the 
plan will be provided mostly within the institutions’ existing resources.  The administrative 
capacity of the central services charged with implementation and coordination of the RRP, namely 
the Programme Directorate for the recovery and resilience facility of the Ministry of Finance, the 
policy directorates and the financial economic affairs directorates (FEZ) is adequate to conduct 
their  foreseen  roles  and  tasks.  The  control  and  monitoring  task  required  for  the  RRF  will  be 
integrated  in  the  standard  planning  and  control  cycle.  Therefore,  the  resources  and  knowledge 
already  in  place  related  for  these  tasks  at  the  national  level  can  be  capitalised  on.  This  should 
ensure smooth and appropriate implementation as the institutions involved possess the necessary 
knowledge and skills, while not creating a disproportionate administrative and financial burden. 
Furthermore, the administrative capacity of the coordinating body  central service charged  with 
implementing and coordinating the RRP are sufficiently detailed in the RRP (see also 4.10).    

Milestones and targets 

The plan includes 72 milestones and 55 targets that are relatively evenly distributed across 
the  implementation  period.  The  21  reforms  and  28  investments  included  in  the  RRP  are 
supported  by  milestones  and  targets  spread  throughout  the  implementation  period,  although  it 
should be noted that the implementation of a number of key reforms is only planned for 2025 or 
2026 and some of the largest investments, for example on wind energy and the housing market, 
are expected to take their full effect in 2025 and 2026. The milestones and targets reflect the key 
steps  towards  the  implementation  of  reforms  and  investment  and  are  considered  realistic  and 
sufficiently ambitious to address the relevant challenges. 

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 the Netherlands. The number of milestones and/or targets per measure is a 
realistic reflection of the different  elements and stages of implementation  of  the corresponding 
reforms  and  investments.  Milestones  generally  describe  the  main  elements  and  objectives  of 
planned reforms and reflect the decisive steps towards the complete implementation of a specific 
reform. They 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.  In  some 
instances,  milestones  refer  to  the  publication  of  a  law  with  subsequent  milestones  covering  its 
implementation. The performance of investments is mainly captured by the achievement of targets 
that generally refer to concrete outputs such as the number of ships converted to zero emission 
vessels, the number of intelligent roadside stations installed and the number of energy efficiency 
measures subsidised.  

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

49 

 
4.9. Costing 

The  Netherlands  has  provided  individual  estimated  costs  for  all  investments  and  reforms 
that entail a cost in the recovery and resilience plan. 

The cost breakdown is generally detailed and well-substantiated. For almost all cost estimates 
the assumptions used are well described and clear. The Netherlands 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. The estimates are mainly based on 
actual  data,  business  cases,  market  research  and  comparisons  with  past  investments  of  similar 
nature.  The  Netherlands  did  not  provide  an  independent  validation  of  the  cost  estimates  by  an 
independent  fiscal  institute  but  several  of  the  measures  have  been  reviewed  by  relevant 
independent committees. 

The  assessment  of  the  cost  estimates  and  inherent  supporting  documents  shows  that  the 
majority of the costs are well justified, reasonable, plausible and 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. 

Reasonable costs  

To support the cost estimates, the Netherlands provided an extensive list of documents to 
justify and explain the amounts proposed and gave explanations on how those amounts were 
computed. 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. For the most part, previous projects, business cases, pilot projects or other 
comparative cost data for the main cost drivers were used as a basis for deriving cost estimates. 
While  the  calculations  were  generally  clearly  spelled  out  and  it  was  possible  to  identify  the 
methodology used, for a limited number of investments the information provided was less clear. 
Nevertheless, there is no evidence that would shed doubts on the costing estimates provided.  

The reforms and investments included in the Dutch 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 the agreed 
milestones and targets are set in such a way that no RRF funding is to be requested after 31 August 
2026. Value-added tax (VAT) is not part of the cost estimates. The plan contains several recurrent 
costs, such as personnel costs and maintenance costs. These are duly justified and acceptable. The 
plan provides justifications to show that these costs are essential for the success of the reforms and 
investments to which they correspond and that they do not represent a significant burden on the 
national budget. Most of these costs are temporary and the non-temporary ones lead to a limited 
cost for the future.  

In this context, it is deemed that the reasonability of the cost estimates has been established to a 
medium extent. 

Plausible costs  

The amount of the estimated total costs of the recovery and resilience plan is in line with the 
nature and type of the envisaged reforms and investments. The Netherlands provided a large 

50 

 
set of documents and links to online sources to substantiate the cost estimates. For the most parts, 
explanations were added to how past projects or market research for key cost drivers relate to the 
cost estimates of the investments in the RRP, enabling a full assessment of the plausibility of the 
costs. Nevertheless, in a limited number of instances the comparability of past projects to the ones 
proposed in the plan could not be established, partially due to the novelty of the measure. For some 
investments  the  costing  was  deemed  relatively  high  compared  to  costs  of  similar  investments. 
Depending on the significance of the shortcomings identified, these limited set of measures, are 
assessed as having “medium” or “low” plausibility.  

Considering the limitations of an ex-ante assessment of cost estimates, the submitted evidence and 
the overall amounts proposed for financing were deemed appropriate and seen as establishing the 
plausibility of the cost estimates to a medium extent.  

No double EU financing  

The  individual  components  provide  clear  information  about  additional  investments  from 
other Union funds. The Netherlands 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 Dutch recovery and resilience plan, assurance is given that, the necessary 
procedures and arrangements for the prevention of double funding are put in place to ensure that 
the reforms and investments included in the plan do not finance the same costs as other Union 
funds. For each measure, a funding sheet and a declaration from the project manager that there is 
no double funding will be prepared. In the funding sheet, the policy directorates will also provide 
information on possible co-financing. This will help to identify the measures for which there may 
be a risk of double funding (see also 4.10).  

The  2021-2027  Partnership  Agreement  and  Programme  has  been  agreed  but  several 
programmes are still under negotiation, and as such a completely developed delineation is 
not possible at this moment. However, the Commission did a preliminary check to reduce the 
risks of double Union financing, and no evidence of clear risks has been identified.  

Commensurate and cost-efficient costs  

The total estimated cost of the plan is commensurate with the expected social and economic 
impact of the envisaged measures. The recovery and resilience plan is expected to effectively 
help address a significant subset of challenges identified in the country-specific recommendations 
(CSRs). Moreover, the recovery  and resilience plan contains measures supporting the recovery 
from the COVID-19 crisis and laying the foundation for long-term growth. The main objectives 
of  the  plan  are  to  foster  the  twin  transition,  improve  the  Netherlands’  growth  potential  and 
economic, social and institutional resilience, thereby reducing vulnerability to shocks. The plan 
contributes to strengthening social cohesion and social protection and to the implementation of the 
European Pillar of Social Rights. The plan enhances the economic, social and territorial cohesion 
and convergence within the Union. The economic and social impact of the plan in combination 
with  the  positive  cost  assessment,  indicates  that  the  cost  is  in  line  with  the  principle  of  cost-
efficiency. 

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

51 

 
impact.  The  Netherlands  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 

for 

the  overall 

responsibility 

(“systeemverantwoordelijk”) 

The monitoring, control and audit systems put in place for the implementation of the RRP 
are based on robust existing national structures which follow a more decentralized approach. 
The authorities responsible for planning, implementing and verifying the recovery and resilience 
plan are part of the national management and control system. A dedicated Programme Directorate 
for the RRF in the Ministry of Finance will be appointed as the coordinating body and as such will 
have 
the  monitoring  and 
implementation of the plan and the protection of the Union’s financial interests. It will also hold 
the  responsibility  for  submitting  the  payment  requests  and  for  drawing  up  the  management 
declaration. Policy directorates in the relevant ministries and agencies/consortiums are specified 
to  ensure  the  reporting  and  implementation  of  the  measures  mentioned  while  the  Financial 
Economic  Affairs  Directorates  (FEZ)  of  each  ministry  will  supervise  and  monitor  the  policy 
directorates and in  particular progress  towards the milestones and targets.  Via sub declarations 
(management Declaration at the level of the implementing organisation) implementing bodies will 
confirm the respect of the sound financial management and confirm the reliability of the reported 
data  on  the  milestones  and  targets.  These  sub  declarations  will  be  verified  and  signed  by  the 
financial economic affairs directorates of each ministry. The audit authority ”Auditdienst Rijk”, 
an  independent  service  within  the  Ministry  of  Finance,  will  carry  out  regular  audits  of  the 
management and control systems including substantive testing. It will also prepare a summary of 
the audits carried out which will be included in the payment requests. The anti-fraud coordination 
service is part of the Ministry of finance and will have central role in fraud coordination under the 
RRP in the Netherlands.  

Adequacy of control systems and other relevant arrangements 

Robust audit arrangements have been put in place. The role of audit authority is assigned to 
the “Auditdienst Rijk”, which is also the responsible body for auditing structural funds. The audit 
authority will prepare the audit strategy and will carry out regular audits of the management and 
control systems and substantive testing. In particular, the audits of the management and control 
system will assess that the monitoring and implementation arrangements provide complete and 
reliable data on the indicators defined in the RRP and that the implementation system ensures that 
funds are managed in accordance with the rules and capable of preventing, detecting and correcting 
fraud, conflict of interests, corruption and double financing. During the implementation of the plan 
on a regular basis, system audits will take place to prepare the summary of audits.  Furthermore, 
as a first  step a baseline check of the data system  for milestones and targets  will  take place to 
ensure that possible issues with double funding or conflict of interest can be detected in an early 

52 

 
stage.  Serious  irregularities  will  be  included  in  the  management  declaration.  The  Netherlands 
Court of Audit (“de Algemene Rekenkamer”), an external independent body, will act as an extra 
layer of control.   

All information related to the implementation and monitoring of the plan will be stored in a 
central  repository  system  that  will  be  developed  for  the  implementation  of  the  RRP.  The 
implementing bodies will collect and store all the data as referred to in article 22(2) point d) of the 
RRF regulation. The information will be stored in the departmental IT systems and shared with 
the coordinating body on a six-monthly basis as part of the reporting obligations and to ensure 
consistency and continuity. The Netherlands also confirmed that they will apply the appropriate 
solutions to verify information related to foreign contractors and final recipients. Furthermore, the 
data shall also be stored in a central repository system. This repository will be developed and, as 
far as possible, linked to existing European and national IT systems. A milestone is included in the 
Plan  for  the  development  of  this  central  repository  system  that  will  be  used  at  the  level  of  the 
coordinating body. The repository system will contain the information related to milestones and 
targets and collect, store and ensure access to the data in line with article 22(2) point d) of the RRF 
regulation. The Netherlands has also committed to use Arachne, the Commission’s data mining 
and risk scoring tool. The central repository system that will be developed will also be linked to 
Arachne. 

The institutional framework and processes put in place to prevent, detect and correct fraud, 
corruption and conflict of interest give sufficient assurances.  Several measure and actions are 
already or will take place to prevent fraud, corruption and conflict of interests. This also includes 
a  complete  risk  analysis  which  will  be  done  by  the  policy  directorates  to  prevent  conflicts  of 
interest,  fraud,  corruption  and  double  funding.  This  risk  analysis  will  then  feed  into  concrete 
actions and additional supervision to facilitate the early detection of problems. A first workshop 
with policy directorates and financial economic directorates already took place.  The policies as 
laid out in the general administrative law act form the basis for the corrective measures as required 
under the RRF regulation. Additional measures should be taken in case of suspicion of fraud or 
abuse.  This  could  possibly  lead  to  a  declaration,  so  that  the  case  can  be  examined  in  criminal 
proceedings. In the event of actual fraud or abuse, or in case the suspicions are serious, the case 
shall  be  transferred  to  the  criminal  justice  actors.  All  criminal  law  issues  will  in  principle  be 
referred to the European Public Prosecutor’s Office (EPPO), which will proceed with the case, 
unless the EPPO decides to leave it to the National Public Prosecutor’s Office. The EPPO will 
have access to the Central Data Repository upon request. In addition, the audit authority will also 
verify that the system put in place can prevent, detect and correct cases where there is a risk of 
conflict of interest, corruption or fraud. 

Adequacy of arrangements to avoid double EU funding 

Adequate arrangements to avoid double EU funding are put in place.  In a dedicated chapter 
of the Dutch recovery and resilience plan, assurance is given that the necessary procedures for the 
prevention of double funding are put in place to ensure that the reforms and investments included 
in the plan do not finance the same costs as other Union funds. For each measure, a funding sheet 
and a declaration from the project manager that there is no double funding will be prepared. In the 
funding fiche, the policy directorates will also provide information on possible co-financing. This 
will help to identify the measures for which there is a risk of double funding. On the basis of this 
information, risk analyses can be carried out. In addition, all final beneficiaries should provide on 

53 

 
a regular basis an updated overview of other external sources of funding, outside the RRF, which 
they  receive  as  an  entity.  It  should  be  clearly  stated  in  the  grant  decisions  that  the  policy 
directorates  and  audit  bodies  will  have  access  to  all  the  necessary  information.  For  existing 
arrangements it will be verified which information is available and this will be included in the risk 
analysis, additional measures can be taken to prevent, detect and/or correct double funding.  

In  order  to  avoid  double  financing,  a  central  data  system  will  be  developed  in  which 
information on the final beneficiaries of the RRF funds is kept. This central data system, in 
combination with Kohesio and the Financial Transparency System (FTS), will be used to verify 
that that there is no risk of double funding. Additional checks will be carried out by the Financial 
Economic Affairs Directorates, the Programme Directorate and the audit body. In the event that 
double funding actually occurred, appropriate action will be taken and if needed the case will be 
sent to the European Public prosecutor. A case of double funding will be reported in the summary 
of audits. 

Legal empowerment and administrative capacity of control function 

The  RRP  provides  adequate  information  regarding  the  administrative  capacity  of 
coordinating and implementing bodies. The administrative capacity of the coordinating body, 
the program directorates for the RRF, is sufficiently detailed. 13 FTE are currently assigned to the 
program directorate for the RRF, the coordinating body, and it will be evaluated on an ongoing 
basis if the administrative capacity is sufficient. Guarantees have been given that the necessary 
financial resources will be made available. The capacity of the financial economic directorates in 
the implementing bodies which are responsible for the supervision and control of the recovery and 
resilience plan has increased significantly in 2021. In addition, given the integration of the control 
and monitoring task required for the RRF in the standard planning and control cycle, the resources 
and  knowledge  already  in  place  related  for  these  tasks  at  the  national  level  can  be  used.  Staff 
responsible for monitoring and ensuring compliance with the provisions of the RRF Regulation 
will  receive  training  to  familiarise  them  with  the  specificities  of  the  programme,  including  for 
example the use of Arachne. A preliminary assessment has been made by the Audit body which 
indicated a need for 10 extra FTE to perform the required task. Additional funding will be made 
available to provide for these extra resources. 

The formalisation of the legal mandate of the audit body and the coordinating body will take 
place before the first payment request. The mandates of the audit body (“Auditdienst Rijk”) and 
the coordinating body (“Programme Directorate”) -will be adjusted to ensure that they have the 
legal mandate as foreseen in the description of the plan. For these purposes, additional milestones 
have  been  defined  and  added  to  the  plan  which  should  be  completed  before  the  first  payment 
request. 

The arrangements  proposed by the Netherlands 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 subject to the enactment of the regulation setting 
out the legal mandate of the different bodies involved in the implementation of the plan before the 
first payment request. This would warrant a rating of A under the assessment criterion 2.10 of 
Annex V of the RRF Regulation. 

54 

 
4.11. 

Coherence 

The  Dutch  RRP  is  structured  around  six  coherent  components,  which  support  the  common 
objectives of stimulating the recovery of the Dutch economy, contributing to the twin transitions 
and  increasing  the  country’s  resilience.  Each  component  is  built  around  sub-components 
containing reforms and investments of mutually reinforcing or complementary nature as explained 
hereafter. 

Mutually reinforcing measures 

The plan is coherent within its components, with consistent reforms and investments  that 
reinforce and strengthen one another.  In Component 1, reforms of taxation and energy markets 
provide incentives for electrification, greenhouse gas emission reduction and sustainable mobility 
that support investments in hydrogen, zero-emission vessels and aviation. Measures to improve 
the environment  complement the actions to  accelerate the energy  and climate transition.  In the 
digital component (Component 2), the actions put forward are expected to contribute to the four 
strategic priorities identified at EU level and reaffirmed in the recent communication on Europe’s 
Digital Decade20: skills, infrastructures, digital transformation of businesses and digitalisation of 
public  services.  Component  3  contains  both  measures  that  increase  the  supply  of  housing  and 
remove elements of the tax system that distort the demand for housing. The measure included in 
Component 4 are expected to contribute to equal opportunities for all and a comprehensive package 
to reduce the incentives for self-employed without employees is included. The various measures 
that deal with health (Component 5) and taxation (Component 5 6) do not contradict each other or 
negatively affect each other within their component. 

Complementarity of measures 

All components together reflect the plan’s overall ambition to boost progress with the twin 
transitions in recovering from the COVID-19 crisis, while contributing to increasing fairness 
and social resilience.  

The  measures  in  Component  2  and  3  contribute  to  the  green  transition.  In  Component  2, 
investments in the digitalisation of logistics and ERTMS support sustainable mobility. The ’Digital 
Infrastructure  Logistics  (DIL)’  initiative  aims  to  accelerate  and  facilitate  the  digitalisation  and 
decarbonisation  of  the  logistics  sector  and  hence  its  sustainable  growth.  The  deployment  of 
ERTMS in railways in the digital component increases railway capacity thereby supporting green 
transportation. In Component 3, the ‘Investment subsidy for sustainable energy and energy savings 
(ISDE)’ will allow for support in the installation of heat pumps and isolation to improve energy 
efficiency.   

Measures to further improve digitisation of the Dutch economy are found throughout the 
plan.  The  education  sub-component    includes  not  only  the  provision  of  digital  equipment  in 
schools  but  also  the  development  of  national  AI  laboratory  for  education,  complementing 
investments in the digitalisation of the education system as well as the development of learning 
communities  in  artificial  intelligence  that  are  part  of  the  digital  components.  Furthermore,  in 

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

55 

 
                                                           
Component 5 reforms are planned to enable remote healthcare through the use of e-services and 
to strengthen data exchange between health institutions. Finally, the reform of the ‘Energy Law’ 
in Component 1 will allow to open up energy data, creating new opportunities for digitalisation.   

Several components contribute to increase fairness and social resilience. Component 3 and 6 
contain several reforms related to moderate the demand for buying a house and increase the supply 
of (affordable) housing  and are  expected altogether to  contribute to  a dampening of the strong 
house price increases. Component 4 contains measures to level the playing field between employed 
and  self-employed,  to  reduce  bogus  self-employment  and  to  improve  the  social  protection 
coverage  for  the  self-employed  via  the  introduction  of  a  mandatory  disability  insurance.  Sub-
component  4.2  includes  several  measures  to  support  learning  deficiencies  of  school  pupils. 
Component 5 includes measures to increase the capacity of the health system in case of a health 
crisis. Component 2 reinforces the provision of digital public services, including the justice system. 
Finally, Component 6 contains measures to tackle tax avoidance and that aim at addressing money 
laundering related challenges.  In order to promote wider coherence across instruments, notably 
with  the  European  cohesion  policy  funds,  a  balanced  territorial  allocation  of  resources  is 
encouraged. 

Taking  into consideration the qualitative assessment  of  all the components  of  the Netherlands’ 
plan, their individual weight (importance, relevance, financial allocation) and their interactions, 
the plan contains measures for the implementation of reforms and public investments, which, to a 
high extent, represent coherent actions. This warrants a rating of A under assessment criterion 
2.11 in Annex V to the RRF Regulation.

56 

 
ANNEX: CLIMATE AND DIGITAL TAGGING TABLE 

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

(Sub)-Measure 
ID 

(Sub-)Measure 
Name 

Cost 
(EUR 
mln) 

Climate 
Int. Field  Coeff. % 

Digital 

Int. Field 

Coeff. % 

P1.1I1-1 

P1.1I1-2 

P1.1I1-3 

P1.1I1-4 

P1.1I2-1 

P1.1I2-2 

P1.1I2-3 

P1.1I3 

P1.1I4-1 

260 

074 

100% 

60 

077 

100% 

131 

050 

40% 

243 

050 

40% 

30 

032 

100% 

34 

5 

56 

10 

022 

100% 

01 

100% 

074 

100% 

022 

100% 

Offshore wind – 
ensuring shipping 
safety 
Offshore wind – 
electric re-charging 
points at sea and in 
the quay 
Offshore wind – 
strengthening and 
protecting the North 
Sea ecosystem 
Offshore wind – 
proper integration of 
the power 
connection to land 
Green power of 
hydrogen – 
demonstration 
facilities 
Green power of 
hydrogen – research 
programme 
Green power of 
hydrogen – human 
capital agenda 
Inland waterway 
energy transition, 
project ZES 
Aviation in 
transition – 
development and 
modification, in-
flight testing and 
demonstration of 
components and 
systems in flight 
technology 
demonstrators based 

57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Sub)-Measure 
ID 

(Sub-)Measure 
Name 

Cost 
(EUR 
mln) 

Climate 
Int. Field  Coeff. % 

Digital 

Int. Field 

Coeff. % 

P1.1I4-2 

P1.2I1 
P1.2I2 

P2.1I1 
P2.1I2-1 

P2.1I2-2 

P2.1I3 

P2.1I4 

P2.2I1 

P2.2I2 

P2.2I3 

P2.3I1 

P2.3I2 

P3.1I1 

P3.1I1 

P3.1I1 

on hydrogen 
combustion 
Aviation in 
transition – floating 
vision 
Nature programme 
Aid scheme for the 
rehabilitation of pig 
farms 
Quantum Delta NL 
AiNed and applied 
AI learning 
communities – 
development of 
highly specialised 
AI support services 
AiNed and applied 
AI learning 
communities – 
development of 
digital skills  
Digitalisation 
education impulse 
Digital 
Infrastructure 
Logistics (DIL) 
European Rail 
Traffic Management 
System (ERTMS) 
Safe, smart and 
sustainable mobility 
Intelligent Roadside 
Stations (IWKS) 
Groundbreaking IT 
(GrIT) 
Digitalisation of the 
criminal justice 
chain 
Unlocking new 
construction 
projects – removal 
of bottlenecks 
Unlocking new 
construction 
projects – reducing 
nitrogen deposition 
Unlocking new 
construction 
projects – climate 
change adaptation 

19 

027 

100% 

714 
275 

264 
44 

16 

209 

36 

049 
049 

40% 
40% 

021quater 
021ter 

100% 
100% 

108 

100% 

012 

100% 

084bis 

40% 

084bis 

100% 

149 

071 

40% 

071 

100% 

076bis 

063bis 

40% 

40% 

55 

129 

94 

75 

076bis 

100% 

063bis 

100% 

011 

100% 

011quater 

100% 

109 

048 

40% 

3 

049 

40% 

191 

037 

100% 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Sub)-Measure 
ID 

(Sub-)Measure 
Name 

Cost 
(EUR 
mln) 

Climate 
Int. Field  Coeff. % 

Digital 

Int. Field 

Coeff. % 

P3.2I1 

P3.2I2 

P4.2I1 

P4.2I5 

P5.1I3 
P5.1I4 

Subsidy scheme for 
sustainability of 
public sector real 
estate 
Investment subsidy 
for sustainable 
energy and energy 
savings (ISDE) 
National Education 
Lab AI 
Laptops and tablets 
for online and 
hybrid education to 
combat and mitigate 
learning losses 
SET COVID-19  
Health Research 
Infrastructure (HRI) 

225 

026bis 

100% 

624 

026bis 

100% 

36 

24 

50 
22 

012 

012 

013 
013 

100% 

100% 

100% 
100% 

59