The Commission’s assessment of national recovery and resilience plans : overall appropriate but implementation risks remain. Special report No 21, 2022.
Date: 2022-12-07
Institutions: European Court of Auditors
Subjects: EU strategy, aid evaluation, community resilience, economic consequence, economic recovery, financial control, performance audit, report, social impact

EN 

2022 

21 

Special report  The Commission’s assessment of 
national recovery and resilience 
plans 
Overall appropriate but implementation risks 
remain 

 
 
 
Contents 

Executive summary 

Introduction 

The Recovery and Resilience Facility 

Recovery and resilience plans 

Roles and responsibilities in the process of preparation and 
assessment of the RRPs 

Member States 

The Commission 

The Council 

State of play of submission and assessment of the recovery and 
resilience plans by 1 June 2022 

Audit scope and approach 

Observations 

Internal procedures and support to Member States were 
adequate but not always traceable and were subject to time 
constraints 

The Commission’s internal procedure was adequate but not always 
traceable 

The Commission’s guidance and support to Member States was adequate 
but subject to time constraints 

Recovery and resilience plans are likely to contribute to the six 
pillars but gaps remain in addressing country-specific 
recommendations 

The Commission’s assessment verified that the recovery and resilience plans 
contribute to the six pillars but the extent of the contribution varies 

The recovery and resilience plans address country-specific 
recommendations, but gaps remain 

Assessment of key conditions within the Recovery and Resilience 
Facility was appropriate but not entirely transparent 

2 

Paragraph 

I-X 

01-16 

01-03 

04-08 

09-15 

09-10 

11-13 

14-15 

16 

17-22 

23-111 

23-39 

24-33 

34-39 

40-53 

40-44 

45-53 

54-76 

 
 
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56-61 

62-65 

66-72 

73-76 

77-96 

79-81 

82 

83-84 

85-86 

87-89 

90-96 

97-111 

98-105 

106-111 

112-121 

The Commission’s assessments acknowledged compliance with the “do no 
significant harm” principle, but milestones or targets for compensating 
measures were not systematically included 

The Commission verified the sampled measures’ contribution to the green 
and digital transitions 

The rating for the estimated costs reflected a lack of information for certain 
measures 

Disbursement profile was a result of negotiations rather than a reflection of 
costs of underlying milestones and targets 

The Commission’s assessment improved the quality of milestones 
and targets, but some important issues remained unaddressed 

The Commission’s assessment process was comprehensive 

Certain milestones and targets lack clarity 

Coverage of key stages of implementation in milestones and targets is in 
some cases incomplete 

Milestones and targets for certain measures indicate that they will be 
completed after 31 August 2026 

Commission’s guidance gives preference to indicators measuring output 
rather than impact 

Approach to defining milestones and targets differs across Member States 

The Commission’s assessment of monitoring and control 
arrangements was comprehensive but partly based on systems 
not yet in place 

The Commission’s assessment of Member States’ monitoring and 
implementation arrangements was comprehensive, but partly based on 
systems not yet in place 

The Commission’s assessment of audit and control arrangements was 
adequate, but often conditional upon requirements still to be fulfilled 

Conclusions and recommendations 

Annexes 

Annex I – Assessment criteria and rating for the recovery and 
resilience plans 

Annex II – State of play of submission and assessment of the 
recovery and resilience plans, by 1 June 2022 

Annex III – Overview of the main features of the recovery and 
resilience plans for the six Member States in the audit sample 

 
 
4 

Annex IV – The measures we selected in the six sampled Member 
States 

Annex V – Six pillars and components of the recovery and 
resilience plans assessed by the Commission as significantly 
contributing to them, for the six Member States in the audit 
sample 

Annex VI – Overview of shortcomings identified by the 
Commission in relation to estimated total costs of the recovery 
and resilience plans, for six Member States in the audit sample 

Annex VII – Overview of monitoring and implementation 
structures in Member States, for the six Member States in the 
audit sample 

Annex VIII – Overview of specific milestones related to 
implementation, monitoring and control systems, for the six 
sampled Member States 

Annex IX – The maximum financial contribution from the 
Recovery and Resilience Facility compared to the absorption rate 
and allocations in the European Structural and Investment Funds 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
5 

Executive summary 

I In July 2020, in response to the COVID-19 pandemic, the European Council agreed a 
more than €800 billion recovery fund – NextGenerationEU. Its centrepiece is the 
Recovery and Resilience Facility amounting to up to €723.8 billion (in current prices) in 
total. The purpose of the Recovery and Resilience Facility is to mitigate the economic 
and social impact of the pandemic and make EU economies and societies more 
sustainable and resilient for the future, with a specific focus on the green and digital 
transition. 

II To benefit from the support under the Recovery and Resilience Facility, Member 
States submitted their draft national recovery and resilience plans to the Commission. 
The Commission is responsible for assessing the recovery and resilience plans based on 
criteria stipulated in the Recovery and Resilience Facility Regulation and for providing 
guidance and support to Member States in that respect. 

III This audit is the first in a series of ECA audits on the Recovery and Resilience 
Facility. We selected a sample of six Member States and examined the appropriateness 
of the Commission’s assessment of the recovery and resilience plans, and verified 
whether the assessment process and guidance to Member States was managed 
effectively, ensured that the recovery and resilience plans are relevant to address the 
objectives of the Recovery and Resilience Facility and that they are compliant with the 
conditions defined in the Recovery and Resilience Facility regulation. This audit could 
feed into any future assessment of the Commission, particularly in relation to the 
submission of amended recovery and resilience plans, and it highlights the risks and 
challenges that might affect their implementation. 

IV We conclude that the Commission’s assessment of the recovery and resilience 
plans was overall appropriate given the complexity of the process and the time 
constraints. However, we identified a number of weaknesses in the process and risks 
for the successful implementation of the Recovery and Resilience Facility.  

V The Commission’s assessment was based on comprehensive internal guidelines and 
checklists but assessors used them not systematically or uniformly for the qualitative 
assessment. The key documents supporting the Commission’s final assessment were 
available but not always easily traceable. The Commission provided support to the 
Member States when they drafted the recovery and resilience plans and issued 
guidance documents. However, a more active role of the Commission in promoting 
exchange of good practice between Member States would have facilitated the process. 

 
 
6 

VI Regarding the policy objectives of the Recovery and Resilience Facility, we 
conclude that the Commission’s assessment verified that the recovery and resilience 
plans are likely to contribute to all six pillars and thereby the policy areas relevant to 
the Facility, but the extent varies and the impact remains to be seen in practice. Some 
important aspects of the country specific recommendations remained unaddressed 
across the Member States, in particular those of 2019, representing recurrent 
structural changes.  

VII As for the compliance with key conditions of the Facility, the Commission’s 
assessment led to the result that none of the measures in our audit sample is likely to 
do significant harm to the environment. However, measures to mitigate the 
environmental impact have not been systematically included in form of a milestone or 
target in the recovery and resilience plans, and measures incompliant with the “do no 
significant harm” principle may be financed outside the Facility. The Commission’s 
assessment of the estimated costs reflected a lack of information for certain measures. 
The disbursement profiles were a result of negotiations rather than a reflection of the 
underlying costs. It also verified that the sampled measures contributed to the green 
and digital transition, where relevant.  

VIII The Commission’s assessment improved the quality of the milestones and 
targets, but some of them lacked clarity or did not cover all key stages of 
implementation of a measure. We also noted that the milestones and targets are 
generally limited to measure output rather than impact and that the approach in 
setting milestones and targets was not always harmonized across Member States.  

IX The Commission’s assessment of the monitoring and control arrangements 
proposed by Member States correctly identified gaps and deficiencies requiring 
additional measures. However, the assessment was to some extent based on the 
description of systems which were yet to be set up. We also note that some Member 
States decided not to use the Commission’s data-mining and risk scoring tool, which 
may both decrease its overall usefulness and increase the risk of non-detection of 
fraud and double-funding in the Member State concerned.  

 
 
7 

X Based on these findings, we recommend that the Commission:  

o 

o 

o 

o 

o 

o 

improves assessment procedures and documentation; 

promotes exchange of good practices amongst Member States; 

follows-up on the contribution of the implemented measures to the country-
specific recommendations; 

improves transparency and monitoring of the “do no significant harm” principle; 

ensures clear verification mechanisms of milestones and targets and their 
adequate definition; 

verifies compliance with the specific milestones for monitoring and control and 
encourages the use of the Commission’s data-mining and risk scoring tool. 

 
 
 
 
8 

Introduction 

The Recovery and Resilience Facility  

01 In July 2020, in response to the COVID-19 pandemic, the European Council agreed 
a more than €800 billion (in current prices) temporary recovery instrument – 
NextGenerationEU. Its centrepiece is the Recovery and Resilience Facility (RRF). 
Amounting to a maximum of €723.8 billion in total (in current prices) of which up to 
€338.0 billion in grants and up to €385.8 billion in loans, it is equivalent to about two 
thirds of the new multiannual financial framework 2021-2027 by value and is the 
largest EU instrument to date. 

02 The purpose of the RRF is to mitigate the economic and social impact of the 
COVID-19 pandemic and make European economies and societies more sustainable, 
resilient and better prepared for the challenges and opportunities of the green and 
digital transitions. It will finance investments and reforms in policy areas of EU-wide 
relevance, structured into six pillars 1 (see Figure 1). 

Figure 1 – Policy areas addressed by the RRF (six pillars) 

Green 
transition

Digital
transformation

Smart, 
sustainable and 
inclusive 
growth

Social and 
territorial 
cohesion

Health, and 
economic, 
social and 
institutional 
resilience

Policies for the 
next 
generation,
children and 
the youth

Source: ECA based on the RRF Regulation. 
Photos: ©Depositphotos. 

1  Article 3 of the Regulation (EU) 2021/241 on the Recovery and Resilience Facility. 

 
 
 
                                                        
9 

03 The financial contribution per Member State is established in accordance with an 
allocation key set out in Annexes I to III of the RRF Regulation. According to the RRF 
regulation, the RRF is a performance-based instrument, and Member States will 
receive funding based on the achievement of qualitative milestones and quantitative 
targets. 

Recovery and resilience plans 

04 To benefit from RRF support, Member States submitted their draft national 
recovery and resilience plans (RRPs) to the Commission from mid-October 2020 
onward and the final RRPs from the moment the RRF Regulation entered into force on 
12 February 2021 2, in accordance with certain criteria and conditions. RRPs consist of a 
set of measures, either investments or reforms, grouped into thematic components 
(e.g. climate friendly mobility or digitalisation of education).  

05 The Commission’s assessment of the RRPs is based on 11 criteria, as stipulated in 
Article 19(3) of the RRF Regulation (see Table 1).  

Table 1 – RRP assessment criteria  

Category 

Criteria 

Criterion 1 – contribute to all six pillars; 

Relevance 

Criterion 2 – effectively address the challenges identified in the European 
Semester, in particular the 2019 and 2020 country-specific recommendations 
(CSRs); 

Criterion 3 – contribute to strengthening growth potential, job creation and 
resilience; 

Criterion 4 – contain only measures that comply with the “do no significant 
harm” principle (DNSH); 

Criterion 5 – contribute to the green transition (minimum 37 % of the total 
estimated cost for climate spending); 

Criterion 6 – contribute to the digital transition (minimum 20 % of the total 
estimated cost); 

Criterion 7 – through its measures the RRP will have a lasting impact; 

Effectiveness 

Criterion 8 – provide arrangements to monitor their implementation, including 
milestones, targets and related indicators; 

2  Regulation (EU) 2021/241. 

 
 
                                                        
10 

Category 

Criteria 

Efficiency 

Criterion 9 – provide a reasonable and plausible justification of their total 
estimated costs; 

Criterion 10 – provide control systems and arrangements that prevent, detect 
and correct corruption, fraud, irregularities, conflict of interest and double 
funding; 

Coherence 

Criterion 11 – contain measures that represent coherent actions. 

Source: ECA based on the RRF Regulation. 

06 In line with the assessment guidelines3, the Commission can generally rate each 
criteria as either ‘A’, ‘B’ or ‘C’, with ‘A’ being the highest and ‘C’ the lowest rating. For 
two out of the 11 criteria, the “do no significant harm” principle (DNSH) and the 
control systems, only ‘A’ or ‘C’ rating is possible (an overview of the rating is provided 
in Annex I).  

07 For an RRP to receive a positive assessment, it must at least achieve the following 
final ratings: 

o 

o 

o 

an ‘A’ for criterion 2 (CSRs), criterion 3 (growth potential, job creation and 
resilience), criterion 5 (green) and criterion 6 (digital); 

a majority of ‘A’s for the other seven criteria; 

no ‘Cs’. 

08 RRPs may be assessed on several occasions. In addition to the Commission’s 
initial assessment which is covered by this audit, RRP will be assessed when an update, 
revision or amendment is submitted by the Member State, specifically: 

o  when a Member State updates its plan following the update of the maximum 

financial contribution for the non-repayable support in June 2022; or 

o 

asks for an amendment of the originally submitted RRP on the basis that the RRP 
including relevant milestones and targets is no longer achievable, either partially 
or totally, because of objective circumstances (Article 21 (1) RRF Regulation); or 

3  Annex V of Regulation (EU) 2021/241. 

 
 
                                                        
11 

o 

requests RRF loan support. Member States may request loan support at the time 
of the submission of a RRP, or at a different moment in time until 31 August 2023. 
In the latter case, the request shall be accompanied by a revised RRP, including 
additional milestones and targets (Article 14 (2) RRF Regulation). 

Roles and responsibilities in the process of preparation and 
assessment of the RRPs 

Member States 

09 The Member States are responsible for preparing the national RRPs in accordance 
with Article 18(4) of the RRF Regulation. Member States have to cooperate with the 
Commission during the preparation and assessment of their RRPs and provide the 
Commission with any additional information requested.  

10 Member States may also amend or revise their RRPs at a later stage, in case the 
RRPs are no longer achievable or should include additional milestones and targets for 
the use of loan support (see paragraph 08). 

The Commission 

11 The Commission is responsible for assessing RRPs in close cooperation with 
Member States. It provides guidance and support to Member States, to ensure 
compliance with the different criteria and conditions set out in the RRF Regulation. 

12 The assessment process is based on a continuous dialogue, which already starts 
before the official submission of the RRPs. After submission of the RRP, the 
Commission has two months to, together with the Member State, solve remaining 
issues and request further information or changes, before finalising its assessment and 
issuing its official proposal for a Council decision. The Member States concerned and 
the Commission may agree to extend this deadline for assessment by a reasonable 
period if necessary4. 

4  Article 19 (1) of Regulation (EU) 2021/241. 

 
 
                                                        
12 

13 After the Council approval, the Commission concludes an operational 
arrangement with each Member State including detailed and technical aspects of 
implementation, such as the timeline, additional interim steps to the milestones and 
targets, and arrangements for providing access to the underlying data. 

The Council 

14 Based on the Commission’s proposal, the Council should approve the assessment 
of the RRP in a Council Implementing Decision within four weeks5. Amended and 
revised plans (see paragraph 08) should also be adopted by the Council. 

15 For Council Implementing Decisions adopted by 31 December 2021, the Member 
State could request a pre-financing of 13 %. All subsequent payments are based on the 
progress reported by the Member State (and assessed by the Commission) in 
implementing the RRP. For disbursement, the Commission shall provide its preliminary 
assessment to the Economic and Financial Committee and ask for its opinion. The 
Commission shall take the opinion into account for its assessment, as stipulated in 
Article 24(4) of the RRF Regulation. 

5  Article 20 of Regulation (EU) 2021/241. 

 
 
                                                        
13 

State of play of submission and assessment of the recovery and 
resilience plans by 1 June 2022 

16 By 1 June 2022, all Member States but the Netherlands had officially submitted
their RRPs. The Commission had assessed 25 of the RRPs positively, with the ratings 
reported in Figure 2, while the assessment for Hungary was still ongoing at the time of 
the audit (see Annex II).  

Figure 2 – Rating of RRPs, state of play by 1 June 2022 

Member State

No.

AT

BE

BG

CZ

CY

DE

DK

EE

EL

ES

FI

FR

HU

HR

IE

IT

LT

LU

LV MT

NL

PL

PT

SE

SI

SK

RO

Assessment criteria

(1)

Balanced Response

(2)

CSRs

(3)

Growth, resilience and 
social impact

(4)

DNSH

(5)

Green target

(6)

Digital target

(7)

Lasting impact

(8)

Monitoring and 
implementation

(9)

Costing

(10)

Control Systems

(11)

Coherence

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

B

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

B

B

A

B

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

B

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

A

A

A

A

A

A

A

A

B

A

A

Source: ECA based on Commission Staff Working Documents. 

14 

Audit scope and approach 

17 This audit responds to the ECA’s priority to address the EU’s response to the 
COVID-19 pandemic across various policy dimensions, including economic governance, 
by examining whether the largest EU instrument to date was set on the right track. The 
audit will provide an insight to stakeholders about the assessment of the recovery and 
resilience plans (RRPs). It aims to feed into any necessary future amendments of the 
assessment process, particularly in relation to the submission of amended or revised 
RRPs. Although this report focuses primarily on the Commission’s assessment work, it 
also highlights the risks and challenges that might affect the implementation of RRPs. 

18 This audit is the first in a series of audits we plan on the NextGenerationEU and 
the Recovery and Resilience Facility (RRF). It does not cover the Commission’s proposal 
for amending the RRF Regulation as regards REPowerEU chapters in the RRPs6. We set 
out to examine the appropriateness of the Commission’s assessment of the RRPs by 
assessing whether: 

o 

the Commission’s internal procedures were clear and were applied, guidance to 
the Member States was sufficient and followed, and support for the Member 
States was effective; 

o 

the Commission’s assessment ensured that:  

— 

— 

the RRPs contribute adequately to the six pillars and to effectively addressing 
all or a significant subset of challenges identified in the CSRs; 

the measures in the RRPs comply with the key conditions stipulated in the 
RRF Regulation (green and digital, DNSH, costs); 

— 

the milestones and targets are clear and realistic; 

— 

the proposed monitoring and control arrangements are appropriate. 

19 Our audit criteria derive from: 

o 

o 

regulatory requirements (in particular the RRF Regulation); 

the Commission’s internal rules and procedures (e.g. instructions and guidelines). 

6  Commission’s proposal for amending the RRF Regulation as regards REPowerEU chapters in 

the RRPs, COM(2022) 231. 

 
 
                                                        
15 

20 Our assessment is based on a sample of six Member States: the four with the 
largest grant allocation in absolute terms (Germany, Spain, France and Italy) and the 
two with the largest grant allocation relative to their 2020 gross domestic product 
(Greece and Croatia). The six RRPs are different in various respects. Annex III presents 
some of their characteristics. In addition, we made a judgement sample and selected 
seven measures in each of the six Member States in our sample on the basis of 
materiality (highest cost) and from the following thematic areas: ‘transport’, ‘green’, 
‘digital’, ‘health’ and ‘other’ for investments, and ‘fiscal’ and ‘social’ for reforms. The 
42 sampled measures are presented in Annex IV. We also carried out a general 
analysis of the milestones and targets in the six sampled RRPs with the objective of 
getting some insight on the nature and timely distribution of milestones and targets as 
well as the Member States’ approach in defining them. 

21 For these six Member States, we examined the Commission’s assessment 
process, from the initial submission of draft RRPs to their final assessments and 
proposal for a Council Implementing Decision, based on 8 out of 11 assessment criteria 
(1, 2, 4-6, 8-10; see Table 1). The audit therefore covered the period from October 
2020 (when first draft RRPs were submitted) to June 2022. The audit did not cover the 
Council’s approval process of the proposal for a Council Implementing Decision.  

22 We analysed the documentation provided by the Commission, including relevant 
correspondence with the six Member States during the assessment process. We also 
interviewed staff from the Commission and the relevant national authorities. In 
addition, we discussed the main observations of the report with a panel of experts. 

 
 
 
16 

Observations 

Internal procedures and support to Member States were 
adequate but not always traceable and were subject to time 
constraints 

23 The novelty and complexity of the recovery and resilience plans (RRPs) requires 
adequate internal procedures for the Commission as well as appropriate support to 
Member States in preparing their RRPs. We examined whether the Commission had: 

o  managed its internal procedures effectively to mobilise its in-house knowledge 
and ensure consistent and transparent application of its internal guidelines; 

o 

provided clear and timely guidance and support to Member States. 

The Commission’s internal procedure was adequate but not always 
traceable 

24 The political governance of the RRF takes the form of a high-level steering board, 
chaired by the President of the European Commission and composed of the three 
Executive Vice-Presidents, the Commissioner for Economy, the Secretary-General, the 
Head of the new Recovery and Resilience Task Force (RECOVER) and the Director-
General for Economic and Financial Affairs (DG ECFIN). The steering board oversees all 
steps, from early engagement with Member States on draft RRPs to implementation of 
the final RRPs and fulfilment of their milestones and targets. It reports regularly to the 
College of Commissioners on its discussions. The College is responsible for approving 
the proposal for a Council Implementing Decision.  

25 The RECOVER task force was established on 16 August 2020 within the 
Secretariat-General and is jointly with DG ECFIN responsible for steering the RRF’s 
implementation and for coordinating it with the European Semester. RECOVER and 
DG ECFIN are also responsible for involving the other policy DGs at all stages of the 
process as necessary. 

26 For this purpose, RECOVER and DG ECFIN held weekly coordination meetings and 
regularly engaged with other DGs through ‘country teams’. These country teams build 
on existing European Semester teams, but also include specialists from all relevant DGs 
to provide the required expertise on the different policy areas covered by RRPs. 

 
 
17 

27 Interactions with the Member States are managed by 27 negotiating teams 
consisting of the (Deputy) Heads of the relevant country units in RECOVER/DG ECFIN as 
well as selected members of the country teams from policy DGs, depending on the 
expertise needed. They are responsible, in particular, for analysing (draft) RRPs, 
preparing assessments and implementing acts related to the RRPs and payment 
requests, and monitoring implementation progress. Generally, two Director-level lead 
negotiators, one each for DG ECFIN and RECOVER, oversee the country team’s work. 

28 Finally, joint RECOVER-DG ECFIN horizontal teams were set up to deal with 
general aspects linked to green transition (including DNSH), digital transformation, 
costing, and milestones/targets. They provided guidance on evaluating the most 
important areas under their responsibility. 

29 Combining representatives from the RECOVER/DG ECFIN country units and the 
policy DG’s country teams in the negotiating teams ensured that the assessment was 
based on staff expertise in the different policy areas as well as on geographical 
aspects. Our analysis of the Commission’s assessment of the sampled measures (see 
paragraph 20) confirmed the involvement of all relevant DGs in the process. 

30 The assessment process included several stages (see Figure 3).  

Figure 3 – Three stages in the RRP assessment process 

The completeness check assesses whether the RRP 
contains all the elements required by the RRF 
Regulation.

The eligibility check assesses whether the RRP meets 
the formal eligibility criteria stipulated in Article 17.

The qualitative assessment considers the relevance, 
effectiveness, efficiency and coherence of each RRP, 
based on the eleven criteria set out in the Regulation.

Source: ECA based on the Commission internal guidelines on the RRP assessment. 

 
 
 
18 

31 To facilitate the assessment and the discussion with Member States, the 
Commission developed general internal guidelines and checklists. For economic and 
social impact, milestones and targets, costs and DNSH these general internal guidelines 
were complemented by more detailed technical guidelines.  

32 Internal guidelines and checklist standardise the assessment process and 
contribute to an equal treatment of different RRPs. The internal guidelines and 
checklists provided a comprehensive set of considerations for the assessors in the 
country teams to conduct and document their assessments. However, the use of the 
checklists was only mandatory for the completeness and eligibility assessment. As a 
result, they were not systematically or uniformly used for the qualitative assessment of 
the 11 assessment criteria. At times, the assessors had provided only minimal 
information, while at others they had drafted notes or other working documents 
without any standard structure.  

33 Although our audit of sampled measures confirmed that key documents resulting 
from the Commission’s work and supporting its final assessments were available and 
recorded, the documentation leading to the conclusions in the Staff Working 
Documents (SWDs) was not always easily traceable. 

The Commission’s guidance and support to Member States was 
adequate but subject to time constraints  

34 The Commission was responsible for providing Member States with the necessary 
guidance and support while they were preparing their RRPs. It provided such 
assistance already from an early stage through guidance documents and discussions, 
while the RRF Regulation was still under discussion by the co-legislators.  

35 The Commission adopted several guidance documents to assist Member States in 
drafting their RRPs: 

o 

o 

general guidance to Member States’ RRPs adopted on 17 September 2020, which 
was amended and replaced by a new version on 22 January 2021; and 

technical guidance on the application of the DNSH criterion 7, published on 
12 February 2021. 

7  Commission technical guidance on the application of “do no significant harm” under the 

Recovery and Resilience Facility Regulation”, C(2021) 1054. 

 
 
                                                        
19 

In addition, these documents were complemented by self-assessment checklists for 
national control systems. 

36 Due to the tight timeframe for drafting the RRPs and for drafting and adopting 
the RRF Regulation, the Commission partly had to develop its guidance documents 
before the legal text was finalized, and in parallel with Member States preparing their 
RRPs. For this, the Commission published two versions of its main guidance document 
on RRP drafting (see paragraph 35). This, in some cases, led to Member States having 
to adjust their RRPs during the process. This was in particular the case for the DNSH 
guidance, which was adopted at the same time as the RRF Regulation, and required 
Member States to complete a DNSH checklist for each reform and investment in their 
RRPs.  

37 We found that RRP assessments were largely based on continuous dialogue 
between the Commission and the Member States, consisting of bilateral meetings, 
communication, and exchanges of information. To further facilitate such information 
sharing, the Commission also established an online question and answer platform on 
the RRF, providing Member States with additional explanations and guidance. During 
our interviews, Member State authorities confirmed the usefulness of this support. 

38 Article 18(5) of the RRF Regulation also stipulates that Member States may 
request the Commission to organise an exchange of good practice with other Member 
States. We welcomed this possibility in our opinion on the proposal for a regulation 
establishing the RRF8. According to the Commission, only one Member State (outside 
of our audit sample) has formally requested such an exchange but subsequently 
withdrew it.  

39 However, most Member State authorities we interviewed would have welcomed 
more interaction with the other Member States during the RRP negotiation process. 
Some Member States organised informal bilateral meetings on their own initiative but 
an active role of the Commission to foster synergies amongst RRPs of Member States 
would have facilitated the process and encouraged the inclusion of cross-country 
projects in the RRPs.  

8  Opinion 06/2020 (pursuant to Article 287(4) and 322(1)(a), TFEU) concerning the proposal 
for a regulation of the European Parliament and of the Council establishing a Recovery and 
Resilience Facility (COM(2020) 408), paragraph 38. 

 
 
                                                        
20 

Recovery and resilience plans are likely to contribute to the six 
pillars but gaps remain in addressing country-specific 
recommendations 

The Commission’s assessment verified that the recovery and resilience 
plans contribute to the six pillars but the extent of the contribution 
varies  

40 We examined how the Commission had assessed whether recovery and resilience 
plans (RRPs) contribute appropriately to all six pillars in line with the criteria set out in 
the RRF Regulation (see Box 1). 

Box 1 

Elements for the assessment of RRP’s contribution to the six pillars  

o 

the RRP contributes in a comprehensive and adequately balanced manner to 
all six pillars …, considering the specific challenges of the Member State 
concerned and taking into account the financial contribution of the Member 
State concerned and the requested loan support. 

Source: Annex V, section 2.1 of the RRF Regulation. 

41 The Commission assessed RRPs’ contribution to the six pillars based on a detailed 
mapping, assessing for each component whether it contributed significantly or at least 
partly to each pillar (see Annex IV). It concluded that all sampled RRPs contributed in a 
comprehensive and adequately balanced manner to all six pillars and granted an ‘A’ 
rating in this area for all of them.  

42 The Commission’s mapping confirmed that all six pillars were addressed by at 
least one of the components for all RRPs in our sample. The Commission’s mapping 
was carried out at the level of components with individual measures being considered 
to determine the (main) pillars the component contributes to. We note however that 
not all measures in a component contribute directly to the pillar in question.  

43 Many components included in the RRPs address more than one pillar and the 
causal connection between the components and pillars, and thereby the extent to 
which components are likely to contribute, varies. In general the link between 
components and pillars is closer for the more specific pillars like “Digital” and “Green” 

 
 
21 

than for the broader and more general pillars like “Smart, sustainable and inclusive 
growth” and ”Social and territorial cohesion”. 

44 Moreover, as each component includes reforms which may have no cost, it is 
difficult to determine, which proportion of funds is contributing to each of the six 
pillars. Consequently, from a financial perspective, it is unclear whether the six pillars 
are addressed in an “adequately balanced manner” as requested by the RRF 
Regulation. In addition, the Regulation does not provide a definition of what actually 
constitutes an “adequately balanced” response in this context.  

The recovery and resilience plans address country-specific 
recommendations, but gaps remain 

45 The European Semester, introduced in 2011, is the EU’s cycle of economic, fiscal, 
labour and social policy coordination. In this context, the Commission analyses 
economic and social developments in the Member States and the challenges facing 
them. To tackle these challenges, the Council each year issues CSRs to every Member 
State, based on proposals by the Commission, which are the main output of the 
European Semester. Whereas in the past the policy coordination under the European 
Semester and the implementation of CSRs were not linked to any financial allocations, 
this has changed with the inclusion of measures adressing CSRs in the RRPs.  

46 The RRF Regulation requires that RRPs contain measures addressing all or a 
significant subset of 2019 and 2020 CSRs. In its assessment, the Commission takes into 
account four elements (see Box 2).  

 
 
22 

Box 2 

Criteria for the assessment of RRP’s contribution to addressing the 
2019 and 2020 CSRs  

o 

o 

o 

o 

the RRP is expected to contribute to effectively addressing all or a significant 
subset of challenges identified in the relevant CSRs…, taking into account the 
financial contribution of the Member State concerned and the requested 
loan support…; 

the RRP represents a comprehensive and adequate response to the economic 
and social situation of the Member State concerned; 

the challenges addressed by the RRP are considered as significant to boost 
the growth potential of the economy of the Member State concerned in a 
sustainable manner; 

following the completion of the proposed reforms and investments, the 
related challenges would be expected to have been resolved or addressed in 
a manner that significantly contributes to their resolution. 

Source: Annex V, section 2.2 of the RRF Regulation. 

47 We checked whether the Commission assessment ensured that measures 
included in the sampled Member States’ RRPs contribute to addressing the relevant 
CSRs, and interviewed Member State authorities to gain more information on the 
process of introducing CSR-relevant measures in their RRPs.  

48 During the assessment of the draft RRPs, the Commission identified gaps for 
some elements of the CSRs and asked Member States to propose additional measures. 
This has been more successful in some cases (e.g. assessment of the quality of public 
expenditure in France, spending review in Italy or judiciary and anti-corruption 
measures in Croatia) than in others, as some subparts of CSRs (mostly those of 2019) 
remained unaddressed in the final RRPs.  

49 For the submitted RRPs, the Commission carried out a mapping exercise included 
in its SWD showing the extent to which CSRs had been sufficiently addressed and 
identifying those which had not. Like for the six pillars, this exercise was carried out for 
components (sets of measures, see paragraph 04), with individual measures being 
considered where relevant. For the six sampled Member States, the Commission’s 
assessment concluded that all 2019 and 2020 CSRs had either partially (with remaining 
gaps) or fully (without any remaining gap) been addressed, and all final RRPs in our 

 
 
23 

sample were therefore granted an ‘A’. Table 2 gives an overview of the remaining gaps 
identified by the Commission. 

Table 2 – Gaps in addressing the 2019 and 2020 CSRs, as identified by the 
Commission 

Member State 

Gaps identified in the RRPs 

Germany 

•  Very high capacity broadband networks (CSR 2019.1.2) – the RRP does not 

include measures to support the deployment of very high-capacity 
broadband networks. 

•  Competition in business services and regulated professions (CSR 2019.1.4) – 
the RRP does not include measures to strengthen competition in business 
services and regulated professions. 

•  Disincentives to work for second earners (CSR 2019.2.1) – further efforts are 

needed in the coming years on to address this challenge. 

•  Pension system (CSR 2019.2.2) – the RRP provides a description of the 

pension system, including the private pension scheme Riester Rente, but 
without binding milestones and targets or specific reforms of the pension 
system. 

Greece 

No gap has been identified.  

Spain 

•  Pension system (CSR 2019.1.4) – the reform of the pension system might 

increase pension expenditure in the medium to long term. The overall fiscal 
impact of increased pension expenditure might need to be further mitigated 
by commensurate fiscal adjustments in the future. 

•  Electricity interconnections (CSR 2019.3.5) – the RRP does not include 

measures addressing this CSRs.  

•  Research and innovation policies (CSR 2019.3.6) – the RRP is still unclear on 
how policy and strategic coordination will be orchestrated between the 
different levels of regional governance. 

•  Primary health care (CSR 2020.1.2) – the RRP presents plans for the roll-out 
of the primary care reform, but it does not include associated investments in 
this area. 

•  Pension system (CSR 2019.1.4) – the reform of the pension system is 
discussed in the RRP, but it is not included in a measure and thus not 
associated to milestones or targets. 

•  Production of renewable energy (CSR 2019.3.2 and 2020.3.5) – the RRP does 
not contain direct support measures to increase the production of renewable 
energy.  

France 

•  Cross-border electricity interconnections (CSRs 2019.3.2 and 2020.3.6) – the 

RRP does not contain any initiative on cross-border electricity 
interconnections.  

•  Regulatory restrictions in the services sector (CSRs 2019.4.2 and 2020.4.1) – 
the RRP does not include any measure to reduce the regulatory restrictions in 
the services sector, in particular on regulated professions and retail, except 
the facilitation of the on-line sales of medicines by pharmacists. 

 
 
24 

Member State 

Gaps identified in the RRPs 

Croatia 

No gap has been identified.  

Italy 

Tax evasion (CSR 2019.1.4) – a comprehensive reform of personal income taxes 
is mentioned in the RRP, but is not included as a measure and thus not 
associated to milestones or targets. 

Source: ECA based on Commission Staff Working Documents. 

50 Our own mapping exercise carried out at measure level arrived at broadly the 
same result for the CSRs as the Commission’s. The main differences concern Italy for 
which we identified additional gaps for some elements of the CSRs (reforms of the 
cadastral and the pension system, as well parts of the financial sector reform), which 
were not included in the Commission’s SWD (see Table 3).  

Table 3 – ECA’s assessment of the extent to which sampled RRPs address 
CSRs for 2019 and 2020 

CSRs 

2019 

2020 

Member State 

Category 

Substantially addressed 

Substantially addressed 
apart from minor 
elements 

Partially addressed, with 
one or more subparts not 
addressed 

Not addressed  

Total number CSRs 

DE 

EL 

ES 

FR 

HR 

IT 

DE 

EL 

ES 

FR 

HR 

IT 

0 

0 

2 

0 

2 

2 

0 

0 

0 

2 

2 

0 

2 

0 

4 

1 

2 

1 

0 

4 

4 

0 

0 

0 

4 

3 

0 

1 

1 

5 

2 

0 

0 

0 

2 

4 

0 

0 

0 

4 

3 

1 

0 

0 

4 

3 

1 

0 

0 

4 

4 

0 

0 

0 

4 

4 

0 

0 

0 

4 

Note: Due to the activation of the Stability and Growth Pact’s “general escape clause” in the context of 
the COVID-19 pandemic, the 2019 CSRs on compliance with the Stability and Growth Pact and the 2020 
CSRs to make sufficient progress towards their medium-term budgetary objectives, were no longer 
relevant and thus not considered a gap. 

Source: ECA based on Commission Staff Working Documents. 

51 We found that the 2020 CSRs were generally covered in the sampled RRPs. 
However, there are still some remaining gaps concerning certain elements of the CSRs, 
for example, the health care system (Spain) or investments and regulatory 
environment (France), which are planned to be addressed outside the RRF. It was 
however not always clear why these were not included in the RRPs instead, in 
particular in the case of important cross-border measures (e.g. the electricity 
interconnections between Spain and France), which by definition would be well suited 
to the RRF.  

 
 
25 

52 Most of the gaps identified concern the 2019 CSRs, which in large parts represent 
recurring structural challenges Member States have been facing for years. For 
example, the German RRP does not include any measure to strengthen competition in 
business services and regulated professions, which has been included in the CSRs for 
Germany since 2011. In addition, various RRPs did not address the elements of CSRs 
related to sustainability of pensions (Germany, France, Italy and partially Spain) or 
taxation (Germany and Italy).  

53 Overall, we consider that the Commission’s assessment resulted in RRPs 
contributing to most of the 2019 and 2020 CSRs. However, some important elements 
of the CSRs remained unaddressed across the Member States in our audit sample, 
largely related to recurring structural challenges Member States have been facing for 
years. Furthermore, the assessment of what constitutes a “significant subset” of CSRs 
having been adressed has neither been defined in the RRF Regulation nor by the 
Commission. The assessment therefore remains to some extent judgemental, 
especially in cases where the Commission identified several and/or serious gaps. 

Assessment of key conditions within the Recovery and 
Resilience Facility was appropriate but not entirely transparent  

54 To evaluate whether the Commission’s assessment of the “do no significant 
harm” principle (DNSH), green and digital tagging and cost estimates was appropriate, 
we selected seven measures in each of the six Member States in our sample (see 
paragraph 20). 

55 For the measures sampled, we examined whether the Commission had 
appropriately assessed whether: 

o 

o 

any measure included in the recovery and resilience plan (RRP) does significant 
harm to environmental objectives within the meaning of Article 17 of the 
Taxonomy Regulation9 (compliance with the DNSH principle); 

the implementation of the envisaged measures is expected to effectively 
contribute to the green and digital transition, including the tagging of measures 
and the coefficients applied; 

9  Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable 

investment. 

 
 
                                                        
26 

o 

the estimated costs were reasonable, plausible, commensurate with expected 
economic and social benefits and not covered by other EU funding. 

The Commission’s assessments acknowledged compliance with the “do 
no significant harm” principle, but milestones or targets for 
compensating measures were not systematically included  

56 For an RRP to be approved, all measures must comply with the DNSH principle 
(see Box 3). 

Box 3 

Criteria for the assessment of compliance of measures with the 
DNSH principle  

o 

no measure for the implementation of reforms and investments projects 
included in the RRP does significant harm to environmental objectives (the 
principle of “do no significant harm”). 

Source: Annex V, section 2.4 of the RRF Regulation. 

57 The Commission issued a technical guidance on the application of the DNSH 
principle when assessing RRPs (see paragraph 35 and 36). It required Member States 
to provide a DNSH checklist for each measure in their RRPs. 

58 The Commission then assessed the measures submitted and their corresponding 
DNSH checklists and provided additional feedback or stipulated conditions that were 
included in the final set of milestones and targets agreed in the Council Implementing 
Decision. For the sampled measures we found that the Commission had: 

o 

o 

o 

ensured that checklists addressed the environmental objectives; 

requested further information when necessary, given feedback and suggested 
changes or the exclusion of certain measures, including with regard to the 
wording for specific measures and the corresponding milestones or targets; 

correctly requested for various RRPs the exclusion of certain parts of measures it 
considered incompliant with the DNSH principle. These were subsequently 
removed from the RRPs. However, in some cases they may be financed outside 
the RRF instead, which contradict the concept of the DNSH principle; 

 
 
27 

o 

ensured, for measures likely to have an environmental impact, that the checklists 
completed by Member States provided explanation on how significant harm 
would be avoided. This includes suggesting mitigating measures. 

59 We note, however, that the Commission’s assessment documentation of the 
DNSH checklists was spread across multiple working papers and lacked a summary list 
showing all DNSH assessments for every measure to back up its overall conclusion in 
the SWD and its final assessment.  

60 In addition, the nature and scale of the impact of potentially harmful measures 
was not quantified in the checklist or in any other form. This made it difficult to assess 
whether the explanations provided and the mitigating measures suggested were 
sufficient to ensure compliance with the DNSH principle.  

61 Furthermore, in those cases where mitigating measures were needed to grant a 
positive DNSH assessment, the mitigating measures have not systematically been 
included in form of a milestone or target in the RRPs. Consequently, their fulfilment is 
not a payment condition and there is no legal basis to impose or follow-up their 
implementation. 

The Commission verified the sampled measures’ contribution to the 
green and digital transitions 

62 The Commission’s assessment on whether the RRPs contribute to the green and 
digital transition was based on several elements (see Box 4). 

 
 
28 

Box 4 

Criteria for the assessment of RRPs’ contribution to the green and 
digital transitions  

Green transition 

o 

the implementation of the envisaged measures is expected to effectively 
contribute to the green transition…thereby contributing to the achievement 
of the Union 2030 climate targets while complying with the objective of EU 
climate neutrality by 2050; 

o  Member States apply a methodology consisting of assigning a specific 

weighting to the support provided, which reflects the extent to which such 
support makes a contribution to climate objectives; 

o 

the implementation of the envisaged measures is expected to have a lasting 
impact. 

Digital transition 

o 

o 

the implementation of the envisaged measures is expected to significantly 
contribute to the digital transformation of economic or social sectors; 

the implementation of the envisaged measures is expected to significantly 
contribute to address the challenges resulting from digital transition; 

o  Member States apply a methodology consisting of assigning a specific 

weighting to the support provided, which reflects the extent to which such 
support makes a contribution to digital objectives; 

o 

the implementation of the envisaged measures is expected to have a lasting 
impact. 

Source: Annex V, sections 2.5 and 2.6 of the RRF Regulation. 

63 We verified the Commission’s assessment for our sample of 42 measures (see 
paragraph 20). For these measures we checked whether the Commission’s assessment 
of the intervention fields and coefficients (100 % for full contribution to green/digital 
transition, 40 % for partial contribution or 0 % for no contribution), was in line with the 
RRF Regulation and the final tags assigned to measures appropriate.  

 
 
29 

64 We found that: 

o 

o 

o 

the Commission had carried out a detailed assessment of the intervention fields 
and coefficients applied by Member States for different measures. In particular, 
the DGs for Energy, Climate Action, Competition, Regional and Urban Policy and 
the Joint Research Centre, as well as horizontal green and digital teams, had been 
consulted for different measures in the sample; 

for several of the measures sampled, the Commission had given Member States 
feedback during the drafting phase on whether they had used incorrect 
intervention fields or whether it required a further breakdown of measures (into 
either separate measures or sub-measures) with different coefficients. In all 
cases, the Member States had made the required changes in their draft RRPs and 
the Commission considered the final versions compliant in this respect; 

for some types of measures, the RRF Regulation did not provide intervention 
fields or green coefficients. However, to ensure a consistent assessment, the 
Commission provided additional internal guidance on how to treat such measures 
(e.g. those relating to electric and hybrid cars) in line with the Taxonomy 
Regulation; 

o 

the Commission had reported the final list of measures contributing to the green 
and digital transitions in its SWD for each Member State. 

65 It remains however to be seen to what extent the measures included in the RRPs 
will contribute to the EU climate objectives in practice. For example, in one of our 
recent reports, we concluded that the climate contribution of key sub-sectors such as 
rail transport, electricity and biomass in relation to the EU budget was overestimated, 
and the reported spending was not always relevant to climate action10.  

The rating for the estimated costs reflected a lack of information for 
certain measures 

66 The assessment of estimated costs in the RRPs is of particular relevance as, 
different from other EU instruments, RRF funding is solely based on the achievement 
of milestones and targets instead of reimbursement of costs. Consequently, the 
estimated costs of measures included in the RRPs are only assessed at the time the 

10  Special report 09/2022: “Climate spending in the 2014-2020 EU budget: Not as high as 

reported”. 

 
 
                                                        
30 

Commission assesses the RRP and have no impact on the actual disbursement of funds 
during the implementation of the RRF.  

67 The Commission had to assess the estimated total cost of each RRP according to 
the assessment criteria stipulated in the RRF Regulation (see Box 5).  

Box 5 

Assessment criteria for the estimated total costs of the RRPs 

o 

the Member State provided sufficient information and evidence that the 
amount of the estimated total costs of the RRP: 

o 

o 

o 

is appropriate (reasonable); 

is in line with the nature and the type of the envisaged reforms and 
investments (plausible); 

to be financed under the Facility is not covered by existing or planned 
Union financing; 

o 

the amount of the estimated total costs of the RRP is commensurate to the 
expected social and economic impact of the envisaged measures included on 
the Member State concerned. 

Source: Annex V, section 2.9 of the RRF Regulation. 

68 In line with the RRF Regulation, the Commission assessed the estimated total 
costs on the basis of the criteria mentioned in Box 5. The RRF Regulation does not 
specify how these four criteria should be consolidated into an overall rating for costs. 
However, the Commission developed a rating system for each of the four criteria as 
well as for the consolidated overall rating. 

69 To date, all RRPs have been rated ‘B’ for costing. We noted that the requirement 
to achieve an ‘A’ rating on each of the criteria as well as for the RRP as a whole were 
relatively ambitious and relatively low for a ‘C’ rating, making it unlikely that anything 
other than a ‘B’ rating would be given. As a result, despite differences in the frequency 
and severity of shortcomings identified by the Commission in the Member States in 
our sample, they were all granted the same rating (‘B’). These shortcoming range from 
a lack of information for some measures at the planning stage to underlying 
assumptions not being fully plausible for every single measure (see Annex VI). In 

 
 
31 

addition, as certain investments are innovative, their costing in the RRPs is largely 
based on professional judgement rather than historical data. 

70 For the 42 measures sampled (see paragraph 20), we checked the costing 
information provided by the Member States, the additional information on costs 
requested by the Commission, the Commissions’ own internal working papers on the 
assessment of estimated total costs, and Commission’s conclusions on costing in the 
SWDs.  

71 Member States produced information sheets for each measure, indicating costing 
information such as underlying cost assumptions, reference costs such as historical or 
comparative data, and information on whether the RRF funding is additional to the 
support provided under other EU programmes and instruments, and does not cover 
the same costs. 

72 The Commission requested further information when necessary, in particular 
regarding the methodology and the underlying assumptions. For the sampled 
measures, we found that they obtained information to verify the estimated costs. For 
those cases, where the Commission, did not obtain sufficient information, it reflected 
this in its assessments and ratings. During this process, relevant DGs (including for 
Energy, for Mobility and Transport and for Employment, Social Affairs and Inclusion) 
were consulted when needed, in line with the internal guidelines on the costing 
assessment. We consider that the ‘B’ rating correctly reflects the lack of information in 
some areas and identified shortcomings related to costing.  

Disbursement profile was a result of negotiations rather than a 
reflection of costs of underlying milestones and targets 

73 The amount paid in a specific instalment is not necessarily based on the 
estimated costs for achieving the milestones and targets included in the payment 
request, but rather a result of the negotiations with the Member State in question. 
These negotiations take into account the proportion of milestones and targets as well 
as their relative importance.  

74 In the EU-27, the total number of instalments (for non-repayable support) ranges 
from four (Cyprus) to ten (Belgium, Croatia, Italy, Portugal, Romania, Slovakia and 
Slovenia) with the number of milestones and targets to be achieved for each 
instalment ranging from two (Czechia - seventh instalment) to 114 (Portugal - ninth 
instalment).  

 
 
32 

75 However, being the result of a negotiation, the process for determining the 
disbursement profiles lacked transparency. Although not necessarily an issue for the 
assessment of the RRPs, this will be problematic during the RRF implementation given 
that any partial achievement of milestones and targets would need to be reflected in 
the payment to the Member State in question. The fact that the payment amount in 
each instalment is the result of a negotiation rather than reflecting underlying costs, 
will make it difficult to determine which reduction would be appropriate. At the time 
of the audit, the Commission had not yet defined a methodology for calculating the 
partial reduction or of payments. 

76 In practice, for the six sampled Member States we note a significant 
heterogeneity in disbursement profiles in terms of both the proportion of total funding 
in each instalment and the number of milestones and targets to be achieved for each 
instalment (Figure 4).  

 
 
33 

Figure 4 – Payment profile and underlying milestones and targets, for 
the six sampled Member States 

Installment No:

1

2

3

4

5

6

7

8

9

10

Share of 
each 
instalment as 
a percentage 
of the total 
financial 
allocation 
(grants and 
loans)

Number of 
milestones 
and targets 
falling under 
each 
instalment 

40 %

35 %

30 %

25 %

20 %

15 %

10 %

5 %

0 %

120

100

80

60

40

20

0

Germany

Greece

Spain

France

Croatia

Italy

Source: ECA based on the annexes to Council Implementing Decisions. 

The Commission’s assessment improved the quality of 
milestones and targets, but some important issues remained 
unaddressed 

77 In line with the RRF Regulation, milestones and targets should measure the 
progress towards the achievement of a reform or an investment, with milestones 
being qualitative achievements and targets being quantitative achievements. The 
achievement of milestones and targets are the basis for the payment requests 

 
 
 
34 

submitted by Member States, making them a key element in the implementation of 
the RRF.  

78 In accordance with the RRF Regulation and the guidance to Member States11, the 
Commission had to assess milestones and targets as part of criterion 8 “arrangements 
to monitor their implementation, including milestones, targets and related indicators” 
(see Box 6). 

Box 6 

Sub-criterion for the assessment of milestones and targets  

o 

the proposed milestones and targets are clear and realistic and the proposed 
indicators for those milestones and targets are relevant, acceptable and 
robust. 

Source: Annex V, section 2.8 of the RRF Regulation. 

The Commission’s assessment process was comprehensive 

79 We audited the Commission’s assessment of milestones and targets on the basis 
of a sample of 42 measures in six RRPS. For these measures, we assessed whether the 
final milestones and targets agreed in the Council implementing decision met the 
above criteria. In addition, we carried out a more general analysis of the milestones 
and targets in the six sampled RRPs, with the objective of getting some insight on the 
nature and timely distribution of milestones and targets as well as the Member States’ 
approach in defining them. 

80 For the 42 sampled measures we conclude that overall the assessment process of 
the sampled milestones and targets was comprehensive, following a series of 
exchanges between the Commission and Member States. In particular, the 
Commission had requested clarifications in the descriptions of milestones and targets, 
which had led to clearer descriptions of intended deliverables, and in some cases 
suggested more precise wording. Furthermore, the Commission required the number 
of milestones and targets to be lowered to make certain RRPs more manageable and in 

11  Commission guidance to Member States Recovery and resilience plans, SWD(2021) 12, 

PART 1/2. 

 
 
                                                        
35 

other cases required more granular milestones and targets to cover different stages of, 
in particular, large measures. 

81 However, the documentation trail is generally fragmented and the analyses are 
contained in multiple working papers of the Commission for different components of 
the RRPs. In addition, there was no overview of all draft milestones and targets during 
the negotiations. The Commission applied a qualitative assessment of each RRP against 
the standards of the RRF Regulation and not a comparative assessment, which would 
have facilitated identifying best practices across Member States.  

Certain milestones and targets lack clarity 

82 In our audit, we focused on the clarity of milestones and targets, as a prerequisite 
for measuring the progress of measures and justifying the disbursement of funds. In 
our general analysis of milestones and targets, we found that all six RRPs included 
milestones and targets lacking clarity (see some examples in Table 4). The absence of 
clear milestones and targets implies the risk that these milestones and targets are 
difficult to assess and the related risk that the initially aimed at objective was not 
fulfilled. 

Table 4 – Examples of milestones and targets lacking clarity 

Member 
State 

Measure 

Relevant 
milestone or 
target  

Description of 
milestone or target 

Verification 
mechanism 

France 

C3.I7 
Strengthening 
the resilience of 
electricity grids 

Beginning of 
projects 

(Milestone) 

Beginning of the 
projects on the 
electricity grids in 
rural areas. 

Germany 

2.1.1 Reform: 
Innovative data 
policy for 
Germany 

Start of projects 

(Milestone) 

Greece 

14 - 4.3. Improve 
the efficiency of 
the justice 
system – 16575 
Accelerating the 

Justice Police 
Operational 

(Milestone) 

All projects and 
activities of the 
measure have 
started. Wherever 
relevant, selection 
procedures have 
been completed and 
selected projects 
have started. 

Operationalisation of 
the judicial police in 
all its competences, 
both at central 
administration level 

Summary document 
with a description of 
the projects, the 
state of 
advancement of the 
work and the 
location. 

N/A (Operational 
arrangement not 
published at the time 
of the audit) 

Report by the 
Ministry of Justice, 
including: 

(a) Organigrams both 
at the central 

 
 
Member 
State 

Measure 

Relevant 
milestone or 
target  

Description of 
milestone or target 

Verification 
mechanism 

36 

administration 
of justice 

and at regional level 
within the courts. 

Spain 

Investment 2 
(C24.I2) - 
Boosting culture 
across the 
territory 

Boosting cultural 
and creative 
initiatives 

(Target) 

Boost cultural 
activity of profit and 
non-profit 
organisations in non-
urban areas (at least 
400 initiatives). 

administrative level 
and at the regional 
level, per court; 

(b) a written 
confirmation of the 
completion of all 
staffing actions and 
the procurement, 
installation and 
operationality of all 
relevant 
infrastructure. 

(a) list of actions 
including a name and 
a brief description;  

(b) official reference 
of the award 
resolution proving 
the project or action 
has been funded;  

(c) the entities that 
have received 
funding;  

(d) the region; and  

(e) the type of 
action. 

Source: ECA based on the annexes to Council Implementing Decisions and operational arrangements. 

Coverage of key stages of implementation in milestones and targets is in 
some cases incomplete 

83 The Commission’s internal practical guidance requires that milestones and 
targets should reflect the key stages in implementation of the measure in question 
(start – interim – final). In our general analysis of milestones and targets we noted that 
the average number of milestone/target ranged from 1.7 per measure in Croatia to 3.2 
in Germany (see Table 5).  

 
 
37 

Table 5 – Average number of milestones and targets per measure 

Member State 

(1) 

Spain 

Italy 

France 

Germany 

Greece 

Croatia 

Total number of 
measures 

Total number of 
milestones and 
targets 

Average number of 
milestones and 
targets per measure 

(2) 

212 

190 

92 

40 

175 

222 

(3) 

416 

527 

175 

129 

330 

372 

(3:2) 

2.0 

2.8 

1.9 

3.2 

1.9 

1.7 

Source: ECA based on the annexes to Council Implementing Decisions. 

84 Covering key stages of implementation is particularly relevant for investments, 
which are often complex and implemented over a longer period and therefore require 
sequential milestones and targets to monitor their progress. However, in our general 
analysis of milestones and targets in the six sampled RRPs, we found investments 
including only one milestone or target (see some examples in Table 6).  

Table 6 – Examples of investments including only one milestone or target 

Investment 

C2.I4 Biodiversity 

(France) 

Milestone or 
target 

Number of projects 
supported in the 
fields of ecological 
restoration and 
protected areas  

Timeframe 

Description of the milestone or target 

By Q4 2022 

Number of projects related to ecological 
restoration, and preservation of 
biodiversity in protected areas. 

C1.4. R1- I4 
Reporting control 
system for road 
passenger and 
freight transport 

(Croatia) 

Establishment of a 
well-functioning 
reporting control 
system for road 
passenger and 
freight 

By Q4 2024 

A well-functioning reporting control 
system for road passenger and freight 
transport shall be put in place, which 
shall connect data from the Tachograph 
Central Processing System (SOTAH) and 
the national records of tachograph cards 
and related records under the 
responsibility of the Ministry of the Sea, 
Transport and Infrastructure. 

Source: ECA based on the annexes to Council Implementing Decisions. 

 
 
38 

Milestones and targets for certain measures indicate that they will be 
completed after 31 August 2026 

85 The RRF was designed as a response to the COVID-19 pandemic and it is 
therefore important that the RRF is implemented within a reasonable timeframe. The 
Commission states on its website, that “Member States present plans on reforms and 
investments to be implement by 2026…”12. The RRF Regulation further specifies that:  

o 

o 

the RRP shall be duly reasoned and substantiated. It shall in particular set out the 
following elements: … envisaged milestones, targets and an indicative timetable 
for the implementation of the reforms, and investments to be completed by 
31 August 2026 (Article 18 (4i)), and 

the Commission proposal…shall also lay down…. the time limit, which should be 
no later than 31 August 2026, by which the final milestones and targets for both 
investment projects and reforms must be completed (Article 20 (5d)).  

86 However, some of the measures in the sampled RRPs include an initial or 
intermediary milestone or target in the last months before the end of the RRF 
implementation period. This may result in the investment not being completed by 
31 August 2026 (see Table 7), which is not compliant with the RRF Regulation (see 
paragraph 85). 

Table 7 – Examples of milestones and targets indicating implementation 
beyond 2026 

Measure 

Relevant milestone or 
target 

Timeframe 

Description of milestone or 
target 

Investment C1.2. R1-I3 
Hydrogen use and new 
technologies 

(Croatia) 

Investment 1.2.5 
Support for purchases 
of buses with 
alternative propulsion 

(Germany) 

Public tender launched 
for additional hydrogen 
capacity (Milestone) 

By Q2 2026 

Orders of buses with 
alternative propulsion 
(Target) 

By Q3 2026 

Public tender launched for 
construction of installation 
that would install 20MW of 
hydrogen power production 
capacity, by electrolysis.  

At least 2 800 buses with 
alternative propulsion have 
been ordered with support 
from the scheme. 

Source: ECA based on the annexes to Council Implementing Decisions. 

12  Recovery and Resilience Facility – From Plans to Payments website.  

 
 
                                                        
39 

Commission’s guidance gives preference to indicators measuring output 
rather than impact 

87 The Commission’s guidance to Member States13 states that:  

o  milestones and targets …can reflect different stages of the implementation of 

reforms and investments, either based on input indicators ... or preferably output 
indicators; 

o 

impact indicators…should be avoided given the unpredictability of such indicators 
and their dependence on other factors outside the control of the Member State. 

88 In line with the guidance, most milestones and targets included in the six RRPs in 
our audit sample are output-oriented (e.g. number of buildings renovated/kilometres 
of railways renovated/charging stations installed). However, at least half of the 
sampled RRPs included measures with input indicators, generally referring to spending 
of a certain amount of funds (e.g. Germany, Spain and France).  

89 Impact indicators have by definition a longer time horizon, which may not be well 
suited to the limited timeframe for implementing the RRF. We note however, that 
avoiding impact indicators, focusing on output indicators and even including input 
indicators for milestones and targets will considerably limit the possibility of measuring 
the performance of measures and ultimately their impact on the rather general EU 
policy objectives of the RRF.  

Approach to defining milestones and targets differs across Member 
States 

90 A lack of harmonized approach in setting milestones and targets affects 
comparability across Member States and poses a risk in terms of equal treatment. 
Although the Commission encouraged a harmonized approach, in particular through 
providing guidance and examples of reforms and investments, they did not carry out a 
comparative analysis of the different plans on the basis that the situation differs in 
each Member State. In our general analysis of milestones and targets, we found 
differences across RRPs in setting milestones and targets, which are illustrated in the 
following paragraphs.  

13  Commission guidance to Member States Recovery and resilience plans, SWD(2021) 12, 

Part 1/2, page 34. 

 
 
                                                        
40 

Distinction between milestones and targets not always clear 

91 In the six RRPs sampled, the total number of milestones and targets ranges from 
129 in Germany to 527 in Italy and the ratio of milestones to targets ranges from 2:3 in 
France and Italy to 4:1 in Greece (see Figure 5).  

Figure 5 – Number and ratio of milestones to targets in the six Member 
States in our sample (grants and loans) 

265
(81 %)

220
(53 %)

196
(47 %)

314
(60 %)

213
(40 %)

203
(55 %)

169
(45 %)

74
(58 %)

55
(42 %)

66
(19 %)

105
(60 %)

70
(40 %)

DE

EL

ES

FR

HR

IT

Source: ECA based on the annexes to Council Implementing Decisions. 

Milestones

Targets

92 Whilst the total number of milestones and targets is largely determined by the 
funds allocated and the scope of the RRP, the difference in the ratio of milestones to 
targets may also indicate a different approach in defining milestones and targets and 
the distinction between the two across Member States. Whereas in most RRPs the 
completion of an investment was generally measured in form of a quantifiable target 
(number of houses renovated, areas reforested, etc.), in particularly the Greek plan 
frequently included a non-quantifiable milestone in form of completion report instead. 
These milestones were however sometimes quantified in the description section in the 
Council Implementing Decision or the “verification mechanism” described in the 
operational arrangement.  

 
 
 
41 

93 Article 2 (4) of the RRF Regulation defines milestones as being qualitative 
achievements and targets as being quantitative achievements. Deviating from this 
distinction poses the following risks:  

o 

o 

in those cases where milestones were quantified in the description/verification 
mechanism, there is some legal uncertainty regarding the extent to which such 
quantification forms part of the payment condition due to the fact that 
milestones are by definition not quantified and their achievement is measured 
through a qualitative indicator; 

in those cases where a milestone has been included for a quantifiable 
achievement and there is no quantification in the description/verification 
mechanism, it might be challenging to determine the extent to which it has been 
successfully implemented. In addition, including non-quantified milestones (e.g. 
presentation of a completion report) instead of a quantified target (e.g. 
renovation of a certain number of houses) poses a risk in terms of equal 
treatment as the latter may be more difficult to achieve. 

Milestones in cross-border projects not necessarily harmonized 

94 Cross-border projects play a specific role in terms of a harmonized approach. 
Because they are by definition similar, they would particularly benefit from a 
harmonized approach. However, cross-border projects did not necessarily result in 
setting similar milestones and targets (see Table 8). 

 
 
42 

Table 8 – Examples of different milestones and targets for the same 
cross border project 

Measure 

Milestones 

Targets 

IPCEI project on hydrogen 
Investment: 1.1.1 – Hydrogen 
projects within the framework 
of IPCEIs 

(Germany) 

IPCEI project on hydrogen 
Investment: C4.I2 – Develop 
decarbonised hydrogen 

(France) 

•  Completion of expression of 

interest procedure 
(companies have submitted 
project sketches by Q2 2021) 

•  Issuance of first grant 
decisions (Q1 2022) 
•  Publication of evaluation 
report of the support 
programme (by Q4 2025) 

•  Award of the contracts 
under the support 
mechanism (publication on 
webpage by Q3 2022) 
•  Signature of decision to 

attribute financial support to 
private promoters 
(publication on webpage by 
Q3 2022) 

•  Commitment of at least 

€500 000 000 (by Q2 2024) 

•  Commitment of 

€1 500 000 000 (by Q3 2026) 
•  Creation of at least 300 MW 
of electrolysis capacity (by 
Q3 2026) 

•  Volume of hydrogen 

supported - cumulative 
(12 000 tonnes by Q4 2022) 

•  Volume of hydrogen 

supported - cumulative 
(100 000 tonnes by Q4 2025) 

•  Electrolyser production 

capacity (by 140 MW/year 
by Q4 2025, financed 
through the IPCEI on 
hydrogen) 

Source: ECA based on the annexes to Council Implementing Decisions. 

Differences in the definition of milestones and targets  

95 Furthermore, we noted a lack of a harmonized approach in defining milestones 
and targets. The shortcomings identified in terms of measures being implemented 
beyond August 2026 and measures with input indicators did not occur to the same 
extent in all sampled RRPs:  

o  milestones and targets indicating that the respective measure will be 

implemented beyond 2026 were included in some RRPs (e.g. Greece and Croatia) 
but not in others (e.g. Spain);  

o 

similarly, input indicators were considerably more frequent in some RRPs (e.g. 
Germany and Spain).  

96 Although we agree with the Commission, that the specific circumstances in each 
Member State need to be taken into account in the assessment, we note a lack of 
comparative analysis.  

 
 
43 

The Commission’s assessment of monitoring and control 
arrangements was comprehensive but partly based on systems 
not yet in place 

97 To assess the Commission’s role in promoting the adoption of an appropriate 
monitoring and control framework in the Member States, we examined whether it had 
appropriately assessed: 

o 

o 

the monitoring and implementation arrangements proposed by Member States in 
their recovery and resilience plans (RRPs); 

the audit and control arrangements proposed by Member States for preventing 
and detecting corruption, fraud, conflicts of interests and double-funding. 

The Commission’s assessment of Member States’ monitoring and 
implementation arrangements was comprehensive, but partly based on 
systems not yet in place 

98 The RRF Regulation 14 requires the Commission to assess, based on a set of 
elements, the arrangements proposed by the Member States for effective monitoring 
and implementation of their RRPs (Box 7). 

Box 7 

Elements for assessing Member States’ monitoring arrangements 
and implementation requirements 

o 

o 

a structure is tasked within the Member State with: (i) the implementation of 
the RRP; (ii) the monitoring of progress on milestones and targets; and 
(iii) the reporting; 

the overall arrangements proposed by the Member States in terms of 
organisation (including provision to ensure sufficient staff allocation) of the 
implementation of the reforms and investments, are credible. 

Source: Annex V, section 2.8 of the RRF Regulation.  

14  Article 19(3) (h) of Regulation (EU) 2021/241. 

 
 
                                                        
44 

99 We checked whether the Commission had assessed the sampled Member States’ 
monitoring and implementation arrangements, in particular their structures, the roles 
and responsibilities of their different bodies, and the capacity required.  

100 Structures for monitoring and implementing of RRPs in the six sampled 
Member States vary significantly, depending on the complexity of Member State’s 
structure, and on whether it relies on existing systems and bodies (Germany,France, 
Croatia) or needs to introduce new ones (Greece, Spain, Italy). Annex VII summarises 
the systems proposed by the six sampled Member States.  

101 We found that the Commission’s assessment, as documented in the SWDs, 
sufficiently described sampled Member States’ structures and systems for 
implementation, monitoring and reporting, as well as their organisational 
arrangements and roles and responsibilities, and outlined the outstanding risks. The 
Commission’s assessment concluded that the monitoring and implementation 
arrangements proposed by the Member States were adequate and therefore granted 
an ‘A’ rating15.  

102 To mitigate the risks to effective RRP monitoring and implementation detected 
for some Member States during the assessment, the Commission proposed specific 
milestones to be achieved before the first payment (with the exception of pre-
financing) to five of the six Member States in the sample. These were introduced in the 
annexes to Council Implementing Decisions (see Annex VIII). Example for these specific 
milestones are “to perform a workload analysis for the institutions involved in 
implementation to mitigate capacity concerns” (Croatia) or “to undertake important 
public administration reforms… in order to set up coordination structures, monitoring 
systems and enforcement mechanisms, and provide staff and assistance for 
monitoring and implementation” (Italy). 

103 Although we generally agree with the Commission’s assessment, it was partly 
based on systems not yet in place at the time of the assessment. This poses risks, in 
particular in cases where the outstanding elements are important. Not having a fully 
functional monitoring system in place implies the risk that milestones or targets in 
reality may not have been achieved until these milestones are fulfilled. 

15  According to Annex V of Regulation (EU) 2021/241, section 2.8, this part could be rated 

with an ‘A’ (adequate arrangements), a ‘B’ (minimum arrangements) or a ‘C’ (insufficient 
arrangements). 

 
 
                                                        
45 

104 Furthermore, the fact that the monitoring systems or implementing bodies 
were partly not yet in place at the time the RRPs were approved also limited the 
Commission’s assessment of their administrative capacity. In some cases the 
Commission relied on Member States’ confirmation that they had sufficient capacity to 
implement and monitor the RRP effectively (for example, Germany and France), while 
in others it expressed concerns about the administrative capacity of the national 
implementing bodies (for example, Croatia). 

105 In some of our recent opinions16, we noted that Member States need to have 
sufficient time and appropriate administrative capacity to absorb EU funds. Some of 
the Member States with the lowest absorption in the 2014-2020 programming period 
will receive a substantial support from the RRF in the coming years (see Annex IX). In 
our Annual Report for 202017, we also highlighted that the level of administrative 
resources needed to manage the substantial increase of funds may not be sufficient. In 
particular for those Member States where a high share of public investments are 
already financed by the EU, this may increase the risk that they may not be able to 
spend the funding available to them and deliver value for money.  

The Commission’s assessment of audit and control arrangements was 
adequate, but often conditional upon requirements still to be fulfilled 

106 In line with the RRF Regulation, the Commission has to ensure that Member 
States have put in place the appropriate control systems to protect the EU’s financial 
interests (see Box 8)18. The RRF’s audit and control setup relies mainly on the 
corresponding systems of each Member State. Member States need to submit 
sufficient information on the control systems they will put in place, in particular to 
ensure compliance with key principles of sound financial management. 

16  Opinion 04/2020 regarding the proposed REACT-EU regulation and Common Provisions 
Regulation governing the ESI funds, 14 July 2020; and opinion 06/2020 (pursuant to 
Article 287(4) and 322(1)(a), TFEU) concerning the proposal for a regulation of the 
European Parliament and of the Council establishing a Recovery and Resilience Facility 
(COM(2020) 408). 

17  2020 annual report, Chapter 2. 

18  Article 19(3) (j) of Regulation (EU) 2021/241. 

 
 
                                                        
46 

Box 8 

Criteria for assessing Member States’ control arrangements 

o 

o 

o 

o 

the internal control system described in the RRP is based on robust processes 
and structures, and identifies clear actors (bodies/entities) and their roles 
and responsibilities; it ensures appropriate segregation of relevant functions; 

the control system and other relevant arrangements, including for the 
collection and making available of data on final recipients described in the 
RRP, in particular to prevent, detect and correct corruption, fraud and 
conflicts of interests when using the funds provided under the RRF are 
adequate; 

the arrangements described in the RRP to avoid double funding from the RRF 
and other EU programmes are adequate; and 

the actors (bodies/entities) responsible for controls have the legal 
empowerment and administrative capacity to exercise their foreseen roles 
and tasks. 

Source: Annex V, section 2.10 of the RRF Regulation. 

107 We checked whether the Commission had assessed the Member States’ control 
arrangements, in particular the clarity of their structures, the roles and responsibilities 
of their different bodies, the systems and processes planned and the capacity required. 

108 The Commission drafted guidance for Member States19 and provided a self-
assessment checklist. We found that: 

o 

o 

the Commission had addressed important aspects of the control systems of the 
six sampled Member States and used a comprehensive internal checklist to verify 
the compliance with all the criteria of the RRF Regulation (see Box 8). For the 
RRPs in our sample, we found an appropriate analysis and a sufficiently detailed 
documentation supporting the assessment; 

it had consulted the relevant DGs with regard to control arrangements in these 
Member States (e.g. DG for Budget, DG for Employment, Social Affairs and 
Inclusion, DG for Regional and Urban Policy). 

19  Commission guidance to Member States Recovery and resilience plans, SWD(2021) 12, 

PART 1/2. 

 
 
                                                        
47 

109 The Commission gave an ‘A’ rating to all six Member States in the sample whilst 
flagging, where relevant, gaps or deficiencies requiring additional measures to be 
implemented before the first payment (see Annex VIII). The specific milestones 
consisted in, for example, specifying the roles and responsibilities of the different audit 
and control bodies (for example, in France),the scope of their mandate (for example, in 
Greece), or the adoption or amendment of audit bodies’ strategies in order to setup 
dedicated units in charge of the RRF (for example, in Croatia). Similarly to the 
monitoring and implementation system (see paragraph 103), this poses a risk as the 
Commission was not yet able to assess the systems in place at the time of the 
assessment.  

110 Furthermore, not all Member States will make use of the Commission’s data-
mining and risk-scoring tool for identifying projects, beneficiaries and contractors at 
risk of fraud, conflict of interest and irregularities under the RRF. Five of the Member 
States in our audit sample (Greece, Spain, France, Croatia and Italy) will use the 
Commission’s data mining and risk scoring tool, whose importance we highlighted in a 
previous audit20. The use of the tool was not compulsory, as decided by the Council, 
and therefore not required for a positive assessment of a Member State’s control 
systems. However, a common data-mining and risk-scoring tool is a key element in 
protecting the EU’s financial interests and, more specifically, in preventing fraud, 
conflicts of interest and double funding, and in increasing transparency and 
accountability. 

111 Although the Commission’s assessment of the Member States’ control systems 
was comprehensive, the fact that specific milestones were needed indicates that both 
the Commission and the Member States acknowledged that the controls systems in 
the sampled Member States at the time of the assessment were partly not yet in place. 
Therefore the ‘A’ rating for all RRPs in this area is at least partly explained by the fact 
that the RRF Regulation only allowed for either an ‘A’ (adequate) or a ‘C’ (insufficient) 
rating with a ‘C’ resulting in the rejection of the RRP as a whole. Not having a fully 
functional control system in place implies the risk that the financial interests of the EU 
are not sufficiently protected until these milestones are fulfilled. 

20  Special report 01/2019: “Fighting fraud in EU spending: action needed”. 

 
 
 
 
                                                        
48 

Conclusions and recommendations 

112 We conclude that the Commission’s assessment of recovery and resilience 
plans was overall appropriate given the complexity of the process and the time 
constraints. However, we identified a number of weaknesses, risks and areas for future 
attention such as e.g. payment profiles being the result of negotiations, milestones and 
targets lacking clarity or monitoring and control systems not yet fully in place at the 
time of the assessment (see subsequent paragraphs). 

113 We found that the Commission managed the assessment process effectively. 
The organizational set-up and the shared responsibility within the Commission ensured 
the involvement of all relevant actors. The assessment followed comprehensive 
internal guidelines and checklists, but assessors used them not systematically or 
uniformly for the qualitative assessment. The key documents resulting from the 
Commission’s work and supporting its final assessment were available and recorded 
but not always easily traceable (paragraphs 24-33). 

Recommendation 1 – Improve assessment procedures and 
documentation 

The Commission should:  

(a) 

further improve the procedure in future assessments to ensure all steps of the 
process are followed and qualitative parts of the assessment are fully considered; 

(b)  ensure that the documentation of the final assessment and the reasons leading to 
it are well documented and key documents easily traceable to increase the 
transparency and efficiency of the process. 

Target implementation date: for any future assessments. 

114 The Commission provided support to the Member States throughout the 
drafting phase of the recovery and resilience plans and issued guidance documents to 
facilitate the process. Due to the limited time available, the guidance were prepared in 
parallel with recovery and resilience plans, requiring in some cases adjustments to the 
recovery and resilience plans throughout the process. The Commission also provided 
training sessions and an on-line question and answer platform, which facilitated 
sharing of information. The Commission had a limited role in promoting exchange of 
good practice between Member States, which would have facilitated the assessment 

 
 
49 

process and encouraged the inclusion of cross-country projects in the RRPs 
(paragraphs 34-39). 

Recommendation 2 – Promote exchange of good practices 
amongst Member States 

To promote the exchange of good practices amongst Member States during the 
implementation of the recovery and resilience plans, the Commission should 
proactively facilitate exchanges of views between Member States’ authorities on 
matters of common concern. 

Target implementation date: during the implementation of the recovery and 
resilience plans. 

115 The Commission’s assessment acknowledged that the recovery and resilience 
plans addressed the key policy objectives of the Recovery and Resilience Facility, 
including the six pillars, after a mapping carried out at the level of components, but not 
including an analysis of all individual measures (see paragraphs 40-44). The extent to 
which components are likely to contribute varies and the impact remains to be seen in 
practice.  

116 We found that the Commission’s assessment led to the recovery and resilience 
plans generally addressing the 2019 and 2020 country-specific recommendations and 
the related challenges identified in the European Semester framework. However, some 
important aspects of country-specific recommendations remained unaddressed in the 
coverage of in particular the 2019 country-specific recommendations. In more general 
terms, the assessment of what constitutes a “significant subset” of country-specific 
recommendations remains to some extent judgemental (paragraphs 45-53). 

 
 
50 

Recommendation 3 – Follow-up on the contribution of the 
implemented measures to the country-specific 
recommendations  

During the implementation of the recovery and resilience plans, the Commission 
should: 

(a)  align the progress reporting on the Recovery and Resilience Facility with the 
reporting in the context of the European Semester to ensure that all country-
specific recommendations, including those not directly addressed in the recovery 
and resilience plans, are adequately followed-up; 

(b) 

in the existing European Semester reporting framework, provide information on 
the extent to which the Recovery and Resilience Facility is contributing to the 
implementation of country-specific recommendations. 

Target implementation date: as from 2022. 

117 The Commission’s assessment led to the result that adopted recovery and 
resilience plans included only measures that complied with the “do no significant 
harm” principle, or accompanied by mitigation measures if they are likely to have an 
environmental impact, as observed for the measures in our sample. However, the 
documentation lacked a summary list to back the Commission’s overall conclusion in 
its final assessment. Moreover, for those measures likely to have an environmental 
impact, the impact was in many cases not quantified. Also, mitigating measures have 
not been systematically included with a milestone or target in the recovery and 
resilience plans. Consequently, their fulfilment is not a payment conditions and there is 
no legal basis to impose or follow-up their implementation. Finally, measures 
incompliant with the “do no significant harm” principle may be financed outside the 
Recovery and Resilience Facility, which contradicts the concept of the ‘do no significant 
harm’ principle (paragraphs 56-60). 

 
 
51 

Recommendation 4 – Improve transparency and monitoring of 
the “do no significant harm” principle  

The Commission should: 

(a)  ask Member States to provide, whenever relevant, a quantitative estimate of the 
environmental impact of measures for future self-assessments of the “do no 
significant harm” principle and if provided, take this into account in the 
assessment; 

Target implementation date: for any future assessment. 

(b) 

include mitigating measures in milestones and targets, where they are considered 
relevant for the positive assessment of the measure with regard to the “do no 
significant harm” principle, and check the fulfilment of the conditions included in 
these milestones and targets during the implementation. 

Target implementation date: for any future assessment and as from 2022. 

118 The Commission’s assessment of the estimated total costs of the recovery and 
resilience plans was appropriate. In all cases, the ‘B’ rating reflected the 
unprecedented nature of some measures and, consequently, the lack of information 
available for them. Furthermore, the methodology used to determine the amount to 
be paid in a specific instalment lacks transparency as it is based on negotiated terms 
with Member States. The frequency and severity of shortcomings identified by the 
Commission varies across sampled Member States, in spite of the fact that they were 
granted the same rating (‘B’). In addition, at the time of the audit, the Commission had 
not yet defined a methodology for calculating the suspension or partial reduction of 
payments (see paragraphs 66-76).  

119 The Commission’s assessment contributed to improving the quality of 
milestones and targets. Our audit work nevertheless showed that a number of 
milestones and targets are not sufficiently clear, do not cover key stages of 
implementation or indicate that certain measures might not be completed by end 
August 2026. We also noted a lack of comparability across Member States because of a 
non-harmonised approach in setting milestones and targets. In addition, as 
recommended by the Commission, the milestones and targets are generally output or 
even input related rather than measuring impact. The shortcomings we identified in 
terms of milestones and targets (see previous subsections) did not occur to the same 
extent in all sampled recovery and resilience plans (paragraphs 77-96). 

 
 
52 

Recommendation 5 – Ensure clear verification mechanisms of 
milestones and targets and their adequate definition 

The Commission should: 

(a) 

include clear verification mechanisms in the operational arrangement for 
milestones and targets to allow for an unambiguous assessment of their 
fulfilment; 

Target implementation date: mid-2023. 

(b)  ensure that milestones and targets are adequately defined, in particular that they 
are sufficiently clear, reflect key stages of implementation and are defined 
consistently across Member States, while respecting the specificities of each 
recovery and resilience plan. 

Target implementation date: for any future assessment. 

120 The Commission assessment of Member States’ proposed monitoring and 
control arrangements was comprehensive and identified a number of weaknesses, 
mainly related to insufficient administrative capacity to implement and monitor the 
recovery and resilience plans and control structures that were only partly in place at 
the time of the assessment. These weaknesses have been addressed by including 
specific milestones agreed with the respective Member States which have to be 
implemented before the first payment from the Commission can be made. Therefore, 
the Commission’s assessment was to some extent based on a commitment rather than 
on the systems actually in place at the time (paragraphs 98-112).  

121 We also note that the decision of some Member States not to use the 
Commission’s data-mining and risk scoring tool may both decrease its overall 
usefulness and increase the risk of non-detection of fraud and double-funding in the 
Member State concerned (paragraph 110). 

 
 
53 

Recommendation 6 – Verify compliance with the specific 
milestones for monitoring and control and encourage the use of 
Commission’s data-mining and risk scoring tool  

The Commission should:  

(a)  closely scrutinise the satisfactory fulfilment and timely implementation of the 

specific milestones related to monitoring and control systems; 

(b)  encourage all Member States to use the Commission’s data-mining and risk 

scoring tool. 

Target implementation date: end 2023. 

This Report was adopted by the Court of Auditors in Luxembourg on 21 July 2022. 

For the Court of Auditors 

Klaus-Heiner Lehne 
President 

 
 
 
 
 
 
 
 
54 

Annexes 

Annex I – Assessment criteria and rating for the recovery and 
resilience plans 

Category 

Criteria 

Possible rating 

Required 
minimum 
rating 

Criterion 1 – contribute to all six pillars; 

B – to a moderate extent  

B* 

A – to a large extent  

Criterion 2 – effectively address the 
challenges identified in the European 
Semester, in particular the 2019 and 
2020 CSRs; 

Relevance 

Criterion 3 – contribute to 
strengthening growth potential, job 
creation and resilience; 

C – to a small extent 

A – effectively addresses all or a 
significant subset of CSRs  

B – partially addresses all or a significant 
subset of CSRs  

C – does not address any challenges 
identified in the CSRs 

A – high expected impact  

B – medium expected impact  

C – low expected impact 

Criterion 4 – contain only measures that 
comply with the “do no significant 
harm” principle; 

A – no measure does significant harm  

C – one or more measure does 
significant harm  

Criterion 5 – contribute to the green 
transition (minimum 37 % of the total 
estimated cost); 

Criterion 6 – contribute to the digital 
transition (minimum 20 % of the total 
estimated cost); 

Criterion 7 – through its measures the 
RRP will have a lasting impact; 

A – to a large extent  

B – to a moderate extent  

C – to a small extent 

Effectiveness 

Criterion 8 – provide arrangements to 
monitor their implementation, including 
milestones, targets and related 
indicators; 

A – adequate arrangements  

B – minimum arrangements  

C – insufficient arrangements  

Efficiency 

Criterion 9 – provide a reasonable and 
plausible justification of their total 
estimated costs; 

Criterion 10 – provide control systems 
and arrangements that prevent, detect 
and correct corruption, fraud, 
irregularities, conflict of interest and 
double funding; 

Coherence 

Criterion 11 – contain measures that 
represent coherent actions. 

A – to a high extent  

B – to a medium extent  

C – to a low extent 

A – adequate arrangements  

C – insufficient arrangements 

A – to a high extent  

B – to a medium extent  

C – to a low extent 

*Additional requirement: majority of As for the seven criteria 1, 4 and 7-11.  
Note: For criteria 4 and 10, only ‘A’ or ‘C’ rating is possible. 

Source: ECA based on the RRF Regulation. 

A 

A 

A 

A 

A 

B* 

B* 

B* 

A 

B* 

 
 
55 

Annex II – State of play of submission and assessment of the recovery and resilience plans, by 
1 June 2022 

Member State 

RRP submitted by the 
Member State 

RRP approved by the 
Commission 

Council Implementing 
Decision adopted by 
the Council 

Pre-financing 
disbursed 

Operational 
arrangement signed 

First payment request 
submitted to the 
Commission 

First payment 
disbursed by the 
Commission 

Austria 

1 May 2021 

21 June 2021 

7 July 2021 

28 September 2021 

Belgium 

1 May 2021 

23 June 2021 

6 July 2021 

3 August 2021 

Bulgaria 

15 October 2021 

7 April 2022 

4 May 2022 

Croatia 

15 May 2021 

8 July 2021 

20 July 2021 

28 September 2021 

9 February 2022 

15 March 2022 

Cyprus 

17 May 2021 

8 July 2021 

20 July 2021 

9 September 2021 

Czechia 

2 June 2021 

19 July 2021 

31 August 2021 

28 September 2021 

Denmark 

30 April 2021 

17 June 2021 

6 July 2021 

2 September 2021 

Estonia 

18 June 2021 

5 October 2021 

29 October 2021 

17 December 2021 

22 March 2022 

Finland 

27 May 2021 

4 October 2021 

29 October 2021 

21 January 2022 

France 

29 April 2021 

23 June 2021 

6 July 2021 

19 August 2021 

25 November 2021 

26 November 2021 

4 March 2022 

Germany 

28 April 2021 

22 June 2021 

6 July 2021 

26 August 2021 

Greece 

28 April 2021 

17 June 2021 

6 July 2021 

9 August 2021 

21 December 2021 

29 December 2021 

8 April 2022 

Hungary 

12 May 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Member State 

RRP submitted by the 
Member State 

RRP approved by the 
Commission 

Council Implementing 
Decision adopted by 
the Council 

Pre-financing 
disbursed 

Operational 
arrangement signed 

First payment request 
submitted to the 
Commission 

First payment 
disbursed by the 
Commission 

Ireland 

28 May 2021 

16 July 2021 

31 August 2021 

Italy 

Latvia 

1 May 2021 

22 June 2021 

6 July 2021 

13 August 2021 

22 December 2021 

30 December 2021 

13 April 2022 

30 April 2021 

22 June 2021 

6 July 2021 

10 September 2021 

16 February 2022 

56 

Lithuania 

15 May 2021 

2 July 2021 

20 July 2021 

17 August 2021 

5 May 2022 

Luxembourg 

30 April 2021 

18 June 2021 

6 July 2021 

3 August 2021 

Malta 

13 July 2021 

16 September 2021 

28 September 2021 

17 December 2021 

Netherlands 

Poland 

3 May 2021 

1 June 2022 

Portugal 

22 April 2021 

16 June 2021 

6 July 2021 

3 August 2021 

18 January 2022 

25 January 2022 

9 May 2022 

Romania 

31 May 2021 

27 September 2021 

29 October 2021 

2 December 2021 

1 June 2022 

Slovakia 

29 April 2021 

21 June 2021 

9 July 2021 

13 October 2021 

16 December 2021 

29 April 2022 

Slovenia 

1 May 2021 

1 July 2021 

20 July 2021 

17 September 2021 

31 March 2022 

Spain  

30 April 2021 

16 June 2021 

6 July 2021 

17 August 2021 

9 November 2021 

12 November 2021 

27 December 2021 

Sweden 

28 May 2021 

29 March 2022 

4 May 2022 

Source: ECA based on Commission Recovery and Resilience Scoreboard (https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/index.html) and the 
official Recovery and Resilience Facility website (https://ec.europa.eu/info/business-economy-euro/recovery-coronavirus/recovery-and-resilience-facility_en#national-
recovery-and-resilience-plans). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
57 

Annex III – Overview of the main features of the recovery and 
resilience plans for the six Member States in the audit sample 

Member 
State 

RRF allocation 
(grants and 
loans, € billion) 

Number of 
components 

Croatia 

6.3 

5 + 1 initiative 

Total number of 
measures 
(reforms – 
investments) 

Total number of 
indicators 
(milestones – 
targets) 

222 

372 

(76-146) 

(166-206) 

France 

39.4 

Germany 

25.6 

Greece 

30.5 

Italy 

191.5 

Spain 

69.5 

9 

10 

18 

16 

30 

91 

(21-70) 

40 

(15-25) 

175 

175 

(70-105) 

129 

(55-74) 

331 

(67-108) 

(266-65) 

190 

527 

(58-132) 

(213-314) 

212 

416 

(102-110) 

(221-195) 

Disbursement profile 

Milestones 
frontloaded and 
targets backloaded. 

Both milestones and 
targets frontloaded. 

Milestones 
frontloaded and 
targets backloaded. 

Both milestones and 
targets backloaded. 

Milestones 
frontloaded and 
targets backloaded. 

Milestones 
frontloaded and 
targets backloaded. 

Note: The term “frontloaded” implies that most of the milestones or targets is planned to be completed 
in the first three years of the implementation of the RRF, while the term “backloaded” means that their 
implementation will take place in the last three years of the RRF implementation period. 

Source: ECA based on the annexes to Council Implementing Decisions. 

 
 
58 

Annex IV – The measures we selected in the six sampled Member States  

Policy area 

Germany 

Greece 

Spain 

France 

Croatia 

Italy 

Investments 

Transport 

Green 

Digital 

Health 

Other 

C1.2.I3: Support for the 
replacement of the private 
vehicle fleet (1.2.3) 

C.4.6.I2 (ID 16628): Central 
Greece Highway E-65: 
Trikala- Egnatia Section 

C1.3.I3: Building renovation: 
federal funding for energy-
efficient buildings (1.3.3) 

C1.2.I1 (ID: 16872): Energy 
renovation on residential 
buildings 

C.1.I1: Low-emission areas 
and transformation of 
urban and metropolitan 
transport 

C2.I1: Rehabilitation 
programme for economic 
and social recovery in 
residential environments 

C.3.I1: Support to the 
railway sector 

C1.4. R5-I2: Research, 
development and 
production of new mobility 
vehicles and supporting 
infrastructure 

C1.I3: Thermal renovation 
of public buildings 

C6.1. R1-I1: Energy 
renovation of buildings 

C2.2.I1: Vehicle 
manufacturer/supply 
industry investment 
programme (2.2.1) 

C2.2.I1 (ID 16778): 
Digitisation of archives and 
related services  

C13.I3: Digitalisation and 
Innovation 

C9.I1: Catching up on 
technical standards for 
digital health 

C1.2. R1-I1: Revitalising, 
building and digitising the 
energy system and 
supporting infrastructure to 
decarbonise the energy 
sector 

M2C2.I4: Sustainable local 
transport, cycle paths and 
rolling stock renewal 

M2C3.I3: Strengthening of 
the Ecobonus and 
Sismabonus until 110 % for 
energy efficiency and 
building safety 

M1C2.I1: Transition 4.0 

C5.1.I1: Programme to 
future-proof hospitals 
(5.1.2) 

C.3.3.I1 (ID 16795): Health 
Infrastructure  

C18.I1: Investment plan for 
high-tech equipment in the 
National Health System 

C9.I2: Modernisation and 
restructuring of hospitals 
and health care supply 

C5.1. R2-I1: Procurement of 
equipment for prevention, 
diagnosis and treatment of 
cancer patients 

M6.C1.I1: Proximity 
networks, facilities and 
telemedicine for territorial 
healthcare assistance 

C1.1.I1: Hydrogen projects 
within the framework of 
IPCEIs (1.1.1) 

C 1.4.I3 (ID 16846): Urban 
Wastewater and Sludge 
Management 
Infrastructures from 
Wastewater Treatment  

C9.I1: Renewable hydrogen, 
a country project 

C4.I2: Develop 
decarbonised hydrogen 

C1.3. R1-I1: Public 
Wastewater Development 
Program 

M2C2.I3: Promotion of 
hydrogen production, 
distribution and end-uses 

 
 
59 

Policy area 

Germany 

Greece 

Spain 

France 

Croatia 

Italy 

Reforms 

Fiscal policy / 
public 
administration 

C6.1.R2: Digitalisation of the 
administration – 
implementation of the 
Online Access Act (6.1.2) 

Labour market / 
education 

C3.1.R1: Education platform 
(3.1.2) 

Source: ECA. 

C4.1.R1 (ID 16610): 
Promoting the acceleration 
of VAT refunds  

C29.R1: Public spending 
review and evaluation 
process 

C7.R5: Assessment of the 
quality of public 
expenditure 

C.2.7. R1: Improving fiscal 
planning and reporting 

M1C1.R13 Reform of the 
spending review framework 

C3.2.R1 (ID: 16913): A New 
Strategy for Lifelong Skilling: 
Modernising and Upgrading 
Greece’s Upskilling and 
Reskilling System 

C23.R6: Permanent 
mechanism for internal 
flexibility, job stability and 
reskilling of workers in 
transition 

C8.R4: Reform of the 
unemployment insurance 

C4.1. R1: Development and 
implementation of new 
targeted active employment 
policy measures for the 
needs of green and digital 
labour market transition 

M5C1.R1: The Active Labour 
Market Policies (ALMPs) 
and Vocational Training 

 
 
 
 
Annex V – Six pillars and components of the recovery and resilience plans assessed by the Commission as 
significantly contributing to them, for the six Member States in the audit sample  

Member 
State 

Green transition 

Digital transformation 

Smart, sustainable & 
inclusive growth 

Social and territorial 
cohesion 

Health, and economic, 
social and institutional 
resilience 

Policies for the next 
generation 

60 

•  2.1. Data as the raw 

material of the future 
•  2.2. Digitalisation of the 

•  1.1 Decarbonisation using 
renewable hydrogen  

•  1.2 Climate-friendly 

•  1.1 Decarbonisation using 
renewable hydrogen  

economy 

•  1.2 Climate-friendly 

•  3.1. Digitalisation of 

Germany 

mobility 

•  1.3 Climate-friendly 
renovation and 
construction 

education 

•  5.1. Strengthening a 
pandemic-resilient 
healthcare system 
•  6.1. Modern public 
administration 

mobility 

•  2.1. Data as the raw 

material of the future 

•  3.1. Digitalisation of 

education 

•  5.1. Strengthening a 
pandemic-resilient 
healthcare system 

•  3.1. Digitalisation of 

education 

•  4.1. Strengthening social 

inclusion 

•  5.1. Strengthening a 
pandemic-resilient 
healthcare system 
•  6.1. Modern public 
administration 

•  3.1. Digitalisation of 

education 

•  4.1. Strengthening social 

inclusion 

Greece 

•  1.1 Power Up: resilience, 
capacity and storage 
capabilities of the 
electricity network 
•  1.2 Renovate: urban and 
spatial planning and 
renovation of buildings 
•  1.3 Recharge and refuel: 
electric vehicle charging 
equipment and 
infrastructure 

•  1.4 Sustainable use of 
resources, climate 
resilience and 
environmental protection 

•  2.2 Modernise: new 

technologies, tools and 
infrastructure in the public 
sector, improved services 
to citizens and businesses 

•  2.1 Connect: fibre optic 

infrastructure, broadband 
connections and 5G 
technology and space 
technologies and 
applications. 
•  2.2 Modernise: 

incorporation of new 
technologies, tools and 
infrastructure in the public 
sector, and provision of 
improved services to 
citizens and businesses 

•  1.4 Sustainable use of 
resources, climate 
resilience and 
environmental protection 

•  2.3 Digitalisation of 

businesses 

•  3.1 Increasing job creation 
and participation in the 
labour market 

•  3.2 Education, vocational 
education, training, and 
skills 

•  4.2 Modernise the public 

•  2.3 Digitalisation of 

administration 

businesses 

•  3.1 Increasing job creation 
and participation in the 
labour market 

•  4.3 Improve the efficiency 
of the justice system 
•  4.5 Promote research and 

innovation 

•  1.1 Power Up: resilience, 
capacity and storage 
capabilities of the 
electricity network 
•  1.2 Renovate: urban and 
spatial planning and 
renovation of buildings 
•  1.4 Sustainable use of 
resources, climate 
resilience and 
environmental protection 

•  2.2 Modernise: 

incorporation of new 
technologies, tools and 
infrastructure in the public 
sector, and  

•  3.3 Improve resilience, 

accessibility and 
sustainability of 
healthcare 

•  3.4 Increase access to 
effective and inclusive 
social policies 

•  3.4 Increase access to 
effective and inclusive 
social policies 

•  4.1 Making taxes more 
growth friendly, and 
improving tax 
administration and tax 
collection 

•  2.3 Digitalisation of 

businesses 

•  3.1 Increasing job creation 
and participation in the 
labour market 

•  3.2 Education, vocational 
education, training, and 
skills 

•  3.4 Increase access to 
effective and inclusive 
social policies 

•  4.5 Promote research and 

•  4.2 Modernise the public 

innovation 

•  provision of improved 
services to citizens and 
businesses 

administration 

•  4.3 Improve the efficiency 
of the justice system 

 
 
61 

Policies for the next 
generation 

Health, and economic, 
social and institutional 
resilience 

•  4.4 Strengthen the 

financial sector and capital 
markets 
•  4.7 Improve 

competitiveness and 
promote private 
investment and trade 

Member 
State 

Green transition 

Digital transformation 

Smart, sustainable & 
inclusive growth 

Social and territorial 
cohesion 

•  3.1 Increasing job creation 
and participation in the 
labour market 

•  3.2 Education, vocational 
education, training, and 
skills 

•  4.6 Modernise and 

improve resilience of key 
economic sectors 

•  3.2 Education, vocational 
education, training, and 
skills 

•  3.3 Improve resilience, 

accessibility and 
sustainability of 
healthcare 

•  4.3 Improve the efficiency 
of the justice system 

•  4.6 Modernise and 

improve resilience of key 
economic sectors 

•  3.3 Improve resilience, 

•  4.7 Improve 

competitiveness and 
promote private 
investment and trade 

•  Loan Facility 

accessibility and 
sustainability of 
healthcare 

•  3.4 Increase access to 
effective and inclusive 
social policies 

•  4.1 Making taxes more 
growth friendly, and 
improving tax 
administration and tax 
collection 

•  Loan Facility 

•  4.2 Modernise the public 

•  3.1 Increasing job creation 
and participation in the 
labour market 

•  3.2 Education, vocational 
education, training, and 
skills 

•  3.4 Increase access to 
effective and inclusive 
social policies 
•  4.6 Modernise and 

improve resilience of key 
economic sectors 

administration 

•  4.3 Improve the efficiency 
of the justice system 

•  4.4 Strengthen the 

financial sector and capital 
markets 

•  4.5 Promote research and 

innovation 

•  4.6 Modernise and 

improve resilience of key 
economic sectors 

•  Loan Facility 

Spain 

•  01. Sustainable urban 

mobility  

•  0.2 Renovation  
•  0.3 Agri-food and fisheries  
•  0.4 Ecosystems and 

biodiversity  

•  08. Electricity 
infrastructure  

•  11. Public administration 
12. Industrial policy  
•  13. Support to SMEs  

•  02. Renovation 
•  11. Public administration  
•  12. Industrial policy  
•  13. Support to SMEs  
•  14. Tourism  
•  15. Digital connectivity  
•  16. Artificial Intelligence 

•  02. Renovation 
•  10. Just transition 
•  14. Tourism  
•  15. Digital connectivity  
•  22. Care economy, 

equality and inclusion 
•  23. Labour market reform 

•  04. Ecosystems and 

biodiversity  

•  05. Coast and water 

resources  

•  11. Public administration  
•  12. Industrial policy  
•  13. Support to SMEs  

•  19. Digital skills  
•  20. Vocational training  
•  21. Education 

 
 
Member 
State 

Green transition 

Digital transformation 

Smart, sustainable & 
inclusive growth 

Social and territorial 
cohesion 

Health, and economic, 
social and institutional 
resilience 

Policies for the next 
generation 

•  0.5 Coast and water 

•  14. Tourism 15. Digital 

•  17. Science, technology 

•  30. Pension system 

•  18. Reform of health 

62 

resources  

•  0.6 Sustainable long 
distance mobility  
•  0.7 Renewable energy  
•  0.8 Electricity 
infrastructure  
•  0.9 Hydrogen  
•  10. Just transition 
•  12. Industrial policy 
•  28. Tax system reform 

•  Component 1 – Building 

renovation 
•  Component 2 – 

Biodiversity, circular 
economy, agriculture and 
forestry 

•  Component 3 – Green 
infrastructures and 
mobility 

•  Component 4 – Green 

energy and technologies 

connectivity 16. Artificial 
Intelligence 
•  19. Digital skills 
•  22. Care economy, 

equality and inclusion 

and innovation 
•  24. Cultural industry  
•  25. Audiovisual 

system 

•  22. Care economy, 

equality and inclusion 
•  27. Prevention of tax fraud  
•  28. Tax system reform  
•  29. Effective public 

spending 

•  Component 6 – 

Technological sovereignty 

•  Component 7 – 

Digitalisation of the State, 
territories, businesses and 
support to the cultural 
sector 

•  Component 5 – Business 

support 

•  Component 6 – 

Technological sovereignty 

•  Component 8 – 

Employment, Youth, 
Disability, Professional 
training 

•  Component 9 – R&D, 
health, territories 

•  Component 7 – 

Digitalisation of the State, 
territories, businesses and 
support to the cultural 
sector 

•  Component 8 – 

Employment, Youth, 
Disability, Professional 
training 

•  1.1 Resilient, green and 

digital economy 

•  1.2. Energy transition for a 
sustainable Economy 
•  1.3 Improving water 

management and waste 
management 

•  1.4. Development of a 
competitive, energy 
sustainable and efficient 
transport system 

•  1.4. Development of a 
competitive, energy 
•  sustainable and efficient 

transport system 

•  1.5. Improving the use of 
natural resources and 
strengthening the food 
supply chain 

•  2.3. Digital transformation 
of society and public 
administration 

•  1.1 Resilient, green and 

•  1.3 Improving water 

digital economy 
•  1.6. Developing 

sustainable, innovative 
and resilient tourism 
•  2.1 Strengthening the 
capacity to design and 
implement public policies 
and projects 

•  2.9. Strengthening the 
public procurement 
framework 

management and waste 
management 
•  4.1 Improving 

employment measures 
and the legal framework 
for the modern labour 
market and the economy 
of the future 

•  4.2 Improving the pension 
system through increased 
pension adequacy 

•  2.1 Strengthening the 
capacity to design and 
implement public policies 
and projects 

•  2.2. Further improving the 
efficiency of the public 
administration 
•  2.4. Improving the 

management of state 
Property 

•  2.5. Modern justice fit for 

future Challenges 

•  3.1 Reform of the 
education system 

•  3.2. Boosting research and 

innovation capacity 

France 

Croatia 

 
 
Member 
State 

Green transition 

Digital transformation 

Smart, sustainable & 
inclusive growth 

Social and territorial 
cohesion 

Health, and economic, 
social and institutional 
resilience 

Policies for the next 
generation 

63 

•  2.1 Strengthening the 
capacity to design and 
implement public policies 
and projects 
•  6.1 Renovation of 
buildings Initiative 

•  5.1 Strengthening the 
resilience of the health 
system 

•  3.2. Boosting research and 

•  4.3. Improving welfare 

•  2.6. Preventing and 

innovation capacity 

systems 

Italy 

•  M2C1. Circular economy 

and sustainable 
agriculture  

•  M2C2. Renewable energy, 

hydrogen, grid and 
sustainable mobility 
•  M2C3. Energy efficiency 
and renovation of 
buildings  

•  M2C4. Protection of land 
and water resources 
•  M3C1. Investments in the 

rail network 

•  M4C1. Strengthening the 
provision of education 
services: from crèches to 
universities 

•  M4C2. From research to 

business 

•  M1C1. Digitalisation, 

innovation and security in 
the PA  

•  M1C2. Digitalisation, 
innovation and 
competitiveness in the 
production system 

•  M3C1. Investments in the 

rail network 

•  M4C1. Strengthening the 
provision of education 
services: from crèches to 
universities 

•  M4C2. From research to 

business 

•  M5C1. Employment 

policies 

•  M6C2. Innovation, 

research and digitalisation 
of the national health 
service 

•  M1C1. Digitalisation, 

•  M1C1. Digitalisation, 

innovation and security in 
the PA  

•  M1C2. Digitalisation, 
innovation and 
competitiveness in the 
production system 
•  M1C3. Tourism and 

culture 4.0 

•  M2C1. Circular economy 

and sustainable 
agriculture  

innovation and security in 
the PA 

•  M2C1. Circular economy 

and sustainable 
agriculture  

•  M2C3. Energy efficiency 
and renovation of 
buildings  

•  M2C4. Protection of land 
and water resources 
•  M3C1. Investments in the 

•  M2C2. Renewable energy, 

rail network 

hydrogen, grid and 
sustainable mobility 
•  M2C3. Energy efficiency 
and renovation of 
buildings  

•  M2C4. Protection of land 
and water resources 
•  M3C1. Investments in the 

rail network 

•  M4C1. Strengthening the 
provision of education 
services: from crèches to 
universities 

•  M5C1. Employment 

policies 
•  M5C2. Social 

infrastructure, 
households, the 

combating corruption 
•  2.7. Strengthening the 
fiscal framework 

•  2.8 Strengthening the anti-

money laundering 
framework 

•  4.3. Improving welfare 

systems 

•  5.1 Strengthening the 
resilience of the health 
system 

•  M1C1. Digitalisation, 

innovation and security in 
the PA 

•  M1C2. Digitalisation, 
innovation and 
competitiveness in the 
production system 
•  M1C3. Tourism and 

culture 4.0 

•  M3C1. Investments in the 

rail network 

•  M3C2. Intermodality and 
integrated logistics 
•  M5C1. Employment 

policies 
•  M5C2. Social 

infrastructure, 
households, the 
community and the third 
sector  

•  M5C3. Special 

interventions for 
territorial cohesion 

•  M1C1. Digitalisation, 

innovation and security in 
the PA 

•  M4C1. Strengthening the 
provision of education 
services: from crèches to 
universities 

•  M4C2. From research to 

business 

•  M5C1. Employment 

policies 

•  M5C3. Special 

interventions for 
territorial cohesion 

 
 
64 

Policies for the next 
generation 

Health, and economic, 
social and institutional 
resilience 

•  M6C1. Local networks, 

facilities and telemedicine 
for local health care  

•  M6C2. Innovation, 

research and digitalisation 
of the national health 
service 

Member 
State 

Green transition 

Digital transformation 

Smart, sustainable & 
inclusive growth 

Social and territorial 
cohesion 

•  M3C2. Intermodality and 
integrated logistics 
•  M4C1. Strengthening the 
provision of education 
services: from crèches to 
universities 

•  M4C2. From research to 

business 

community and the third 
sector  

•  M5C3. Special 

interventions for 
territorial cohesion 
•  M6C1. Local networks, 

facilities and telemedicine 
for local health care  

•  M5C1. Employment 

•  M6C2. Innovation, 

research and digitalisation 
of the national health 
service 

policies 
•  M5C2. Social 

infrastructure, 
households, the 
community and the third 
sector  

•  M5C3. Special 

interventions for 
territorial cohesion 

Source: ECA based on Commission Staff Working Documents.  

 
 
65 

Annex VI – Overview of shortcomings identified by the 
Commission in relation to estimated total costs of the recovery 
and resilience plans, for six Member States in the audit sample 

Member 
State 

Germany 

Greece 

Spain 

Reasons for a “B” rating for costing 

•  “Overall, the costing information presented in the plan complies with the minimum requirements on 
costing ... The costing information provided in the plan shows varying degrees of detail and depth of 
calculations.”  

•  “… reasonability, plausibility or additionality of costs … are proven to a sufficient extent. However, 
more detailed estimations could have increased the level of assurance that these principles are 
fulfilled.” 

•  “A limited number of projects is not sufficiently substantiated with cost of comparable project or the 

evidence cited could not be accessed.” 

•  “… for a relatively low share of the costs, the methodology used is not sufficiently well explained and 

the link between the justification and estimated costs is not sufficiently clear to deem that the costs are 
reasonable.” 

•  “… for a relatively low share of the costs, there are not sufficient historical or comparative data for key 

cost drivers to deem that the costs are plausible.” 

•  “France submitted the table on costing included in the standard template, though some information, 

notably on comparative costing data, has not been filled in.”  

•  “France has not provided an independent validation for any of the cost estimates proposed.”  

•  “There are some shortcomings in the costing description for certain measures such as the description 
and justification of costs not covering all sub-measures, no calculations being provided for arriving at 
the total cost; or supporting documentation, in case reference is made e.g. to studies or past projects, 
in some cases not being provided.” 

•  “An issue concerns measures consisting of several sub-measures, where the methodology for allocating 

France 

costs to each sub-measure is not always entirely clear.” 

•  “For a small number of measures, no calculations for arriving at the total cost are provided, or those 
calculations do not reconcile to the requested funding or the associated milestones or targets.” 

•  “Costing information is generally backed by expert analysis or previous experience. For some measures, 
clear explanations were missing as to how the past projects presented or studies carried out as the 
basis for the estimates were used or adjusted to arrive at the cost estimates presented ... For other 
measures, the supporting documentation was not provided.” 

•  “An ex-ante cost assessment of these [demand-driven] measures inevitably has limitations, since it is 

not always knowable beforehand what will precisely be achieved.” 

•  “There are deficiencies in the costing description for a number of measures such as the description and 
justification of costs not covering all sub-measures; methodology and calculations provided not always 
matching the proposed amounts; and some failure to provide supporting documentation, in case 
reference is made e.g. to studies or past projects.” 

•  “Croatia has not provided an independent validation for any of the cost estimates proposed.” 

Croatia 

•  “A recurring issue concerns measures consisting of several sub-measures, where the methodology for 

allocating costs to each sub-measure is frequently not entirely clear.” 

•  “For a certain number of measures, no calculations for arriving at the total cost are provided, or those 

calculations do not reconcile to the requested funding or the associated milestones or targets.” 

•  “A limited number of projects is not sufficiently substantiated with cost of comparable project or the 

evidence cited could not be accessed.” 

Italy 

•  “The information provided by Italy´s recovery and resilience plan in some cases refers to specific type of 
cost expected to be financed by the various Union programmes, but details are not always clear enough 
or simply not provided.” 
Source: ECA based on Commission Staff Working Documents. 

 
 
66 

Annex VII – Overview of monitoring and implementation 
structures in Member States, for the six Member States in the 
audit sample 

Member 
State 

Coordinating 
body 

Description of the systems in the Staff Working Documents 

Croatia 

Central 
Coordinating Body 
under the Ministry 
of Finance 

France 

General Secretariat 
of European Affairs 

Germany 

Federal Ministry of 
Finance 

Greece 

Recovery and 
Resilience Facility 
Coordination 
Agency 

Multi-level governance, monitoring and implementation structure:  

•  Steering board responsible for the political leadership and monitoring of the 

implementation of the RRP; 

• 

Implementation Committee responsible for the overall monitoring and 
implementation of the RRP;  

•  Body, planned to be set up by the end of 2021, under the Ministry of Finance, and 

tasked with the operational coordination and monitoring of the RRP;  

•  National Fund under the Ministry of Finance, responsible for drawing up and 

submitting payment requests and management declarations;  

• 

• 

Implementing bodies and agencies responsible for the implementation of each 
specific measure as well as the monitoring of the projects’ progress.  

Implementation administratively led by the Ministry of Economy, Finances and 
Recovery, in close cooperation with the General Secretariat;  

•  General Secretariat coordinates and is supported in the implementation and 

monitoring process by the “Recovery Secretariat”, which is directly attached to the 
Prime Minister and the Minister of Economy, Finance and Recovery;  

•  The Recovery Secretariat is monitoring the implementation at the level of each 

measure, in close cooperation with regional prefects and Heads of each Ministry; 

• 

Implementation of the reforms is closely monitored by each relevant Ministry;  

•  The controls on the milestones and targets are delegated to the Ministries in charge of 
the implementation of the components. Each ministry sets out the internal control 
system defined by the Ministry of the Economy, Finance and Recovery;  

•  Verification, inspection and audit missions shall be organised to ensure the 

effectiveness of these systems and to control the quality of the data transmitted;  

•  The management and verifications to be carried out by the line ministries shall be 

featured in the “chartes de gestion”, still under development. 

•  A dedicated unit within the Ministry of Finance will monitor the implementation as 

well as coordinate the monitoring and reporting of progress in cooperation with other 
line ministries.  

• 

It will perform qualitative controls on all financial data and submit payment requests.  

•  The coordinating function of the unit is based on established national mechanisms 

and regulations. 

•  The unit consists of a team of economists and budgetary controlling experts with the 

relevant experience and knowledge. 

•  Main body for the coordination of the implementation and the monitoring will be the 
recently established Recovery and Resilience Facility Coordination Agency, which acts 
as the (single) liaison between the European Commission and the Greek authorities 

• 

It is responsible for verifying the completion of milestones and targets, actively 
monitoring the progress of the projects and the submission of the payment requests 
to the European Commission upon verification of their completion.  

•  The overall responsibility for the implementation of each specific measure falls under 

the competency of the relevant Ministry. 

•  All measures in the RRP shall be implemented by national bodies (“implementing 

bodies”) appointed by the competent Ministry. 

•  Finally, the Financial Audit Committee which is part of the General Secretariat for 
Fiscal Policy (State General Accounting Office) of the Ministry of Finance, shall 
safeguard the observance of the principles of sound financial management. 

 
 
Member 
State 

Coordinating 
body 

Description of the systems in the Staff Working Documents 

67 

A number of coordinating structures are to be created for the monitoring and 
implementation of the RRP:  

•  a steering committee established at the Presidency of the Council of Ministers to steer 

and coordinate the implementation of the RRP;  

•  a consulting body for social dialogue, composed of representatives of social partners 

and other relevant stakeholders including local entities;  

•  a technical secretariat established at the Presidency of the Council of Ministers to 
support the activities of the steering committee and of the consulting body;  

•  a central coordination structure at the Ministry of Economy and Finance to perform 
the overall coordination and monitoring of the implementation of the RRP (including 
in relation to milestones and targets), the control of the regularity of procedures and 
expenses and the reporting, and the technical and operational support to the 
implementation phases. It shall also act as a single point of contact at national level 
for the European Commission.  

•  The Ministry of Economy and Finance ensures the evaluation of the results of the RRP.  

•  Coordination structures at the level of each central administration shall be identified 
and tasked with the management, monitoring, reporting and control on the relevant 
interventions, including the supervision of implementation and progress towards the 
achievement of milestones and targets.  

•  Recruitment of temporary personnel is envisaged to strengthen administrative 

capacity for the monitoring and implementation;  

•  a new integrated IT system (“ReGiS”) will be set-up and the current systems adapted 

until ReGiS becomes operational;  

•  The existing audit service Inspectorate General for Financial Relations with the 

European Union, within the Ministry of Economy and Finance, shall be tasked with the 
coordination of the audit systems and conducting the controls with the support of the 
State Territorial Accounts Office.  

•  A Commission for Recovery, Transformation and Resilience, chaired by the President 

of the Government, shall monitor the implementation of the RRP; 

• 

Its work will be assisted by a Technical Committee of 20 members of the public 
administration chaired by the Secretariat-General for European Funds. Secretariat-
General for European Funds will draw up the requests for payment;  

•  Newly set up Secretariat-General for European Funds within the Ministry of Finance is 

the responsible authority vis-a-vis the European Commission. It will be key in 
monitoring the submission of payment claims;  

•  Ministry responsible for each measure in charge of taking action to achieve the 

related milestones and objectives  

•  General Comptroller of the State Administration will carry out checks to certify the 

achievement of milestones and objectives, as well as the results achieved.  

Italy  

Central 
coordination 
structure at the 
Ministry of 
Economy and 
Finance 

Spain  

Secretariat-General 
for European Funds 
within the Ministry 
of Finance 

Source: ECA based on Commission Staff Working Documents. 

 
 
 
 
68 

Annex VIII – Overview of specific milestones related to 
implementation, monitoring and control systems, for the six 
sampled Member States 

Member 
State 

Germany 

•  No additional milestone. 

Specific milestones 

Greece 

Spain 

France 

•  Entry into force of the audit authority’s legal mandate and establishment of the audit and control 

system that shall (a) ensure the collection of data and monitoring of the achievement of milestones and 
targets; (b) allow for the preparation of management declarations and the audit summary as well as 
payment claims and (c) establish the necessary procedures to collect and store data on beneficiaries, 
contractors, subcontractors, and beneficial owners in accordance with Article 22 of the RRF Regulation, 
before the first payment request is made. A dedicated audit report on the system set up shall be 
undertaken. In case that the report identifies any weaknesses, the audit report shall recommend 
corrective actions. [19-16968 Technical Assistance] 

•  The implementation of an integrated information system that shall allow (a) for the upload of the RRP 
and of the information on implementation and monitoring of the achievement of milestones and 
targets; (b) for the preparation of management declarations and the audit summary as well as payment 
claims and (c) to collect and store data on beneficiaries, contractors, subcontractors, and beneficial 
owners in accordance with Article 22 of the RRF Regulation. A dedicated audit report on the system 
used shall be undertaken. In case that the report identifies any weaknesses, the audit report shall 
recommend corrective actions. [C11.I5] 

•  Entry into force of the Order defining the procedures and format of the information to be shared for 

monitoring the RRP and accounting execution of expenditure. [C11.R5] 

•  Establishment of controls and audit procedures through the two following elements: (a) signature of a 
circular by the Prime Minister which shall set out the roles and responsibilities of the coordinating body 
and of ministries and the procedure of collection and storing of data pertaining to indicators, including 
ensuring their reliability and access to the data collected of all types of final recipients; (b) finalisation 
of a report that shall provide a description of the envisaged audit strategy including a description of the 
audit work on the payment claims. 

•  Amendments to statutes of the Agency for the Audit of European Union Programmes Implementation 
System shall define the mandate of the Agency to set up and carry out system audits and control 
related to the national RRP. [C2.1. R2] 

•  Establishment of the implementation, audit and control system for the RRP: the decision on the bodies 
in the RRP system shall define the competent authorities and responsibilities for carrying out the tasks 
in the implementation of the RRP. [C2.1.R2] 

Croatia 

•  Assessment of the administrative capacity: workload analyses shall be carried out for the institutions 
involved in the respective management and control systems, also taking into account the burden 
arising from the RRF. [C2.1.R2] 

•  A repository system for monitoring the implementation of the RRF shall be in place and operational. 
The system shall include, as a minimum, the following functionalities: (a) collection of data and 
monitoring of the achievement of milestones and targets; (b) collect, store and ensure access to the 
data required by Article 22(2)(d)(i) to (iii) of the RRF Regulation. [C2.1. R2] 

Italy 

•  A repository system for monitoring the implementation of the RRF shall be in place and operational. 

The system shall include, as a minimum, the following functionalities: (a) collect data and monitor the 
achievement of milestones and targets; (b) collect, store and ensure access to the data required by 
Article 22(2)(d)(i) to (iii) of the RRF Regulation. [M1C1-68, reform 1.9] 

Source: ECA based on Commission Staff Working Documents. 

 
 
 
 
69 

Annex IX – The maximum financial contribution from the 
Recovery and Resilience Facility compared to the absorption 
rate and allocations in the European Structural and Investment 
Funds 

 
 
 
 
70 

Abbreviations 

CSR: Country specific recommendation 

DG ECFIN: Directorate-General for Economic and Financial Affairs 

DNSH: “Do no significant harm” principle 

RECOVER: Secretariat General Recovery and Resilience Task Force 

RRF: Recovery and Resilience Facility 

RRP: Recovery and Resilience Plans 

SWD: Commission Staff Working Document 

 
 
 
 
71 

Glossary 

Commission’s data-mining and risk scoring system: Data-mining and risk-scoring tool 
developed by the Commission to support managing authorities in the administration 
and management of the European Structural and Investment Funds and the Common 
Agricultural Policy funds. 

Country-specific recommendation: Annual guidance which the Commission issues, as 
part of the European Semester, to individual Member States on their macroeconomic, 
budgetary and structural policies. 

Digitalisation: The shift towards incorporating and using digital technology and 
digitised information to make processes and tasks simpler, faster, more efficient 
and/or more economic. 

Do no significant harm: Principle that investment measures should have no major 
detrimental environmental impact. 

European Semester: Annual cycle which provides a framework for coordinating the 
economic policies of EU Member States and monitoring progress. 

NextGenerationEU: Funding package to help EU Member States recover from the 
economic and social impact of the COVID-19 pandemic. 

Recovery and Resilience Facility: The EU’s financial support mechanism to mitigate the 
economic and social impact of the COVID-19 pandemic and green and digital 
transformation. 

Recovery and resilience plan: Document setting out Member State’s intended reforms 
and investments under the Recovery and Resilience Facility. 

Staff working document: A non-binding Commission document produced for 
discussion, either internally or outside the institution. 

 
 
 
 
72 

Replies of the Commission 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=61946  

Timeline 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=61946  

 
 
 
 
 
 
 
 
 
 
73 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies and 
programmes, or of management-related topics from specific budgetary areas. The ECA 
selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming 
developments and political and public interest. 

This performance audit was carried out by Audit Chamber IV Regulation of markets 
and competitive economy, headed by ECA Member Mihails Kozlovs. The audit was led 
by ECA Member Ivana Maletić, supported by Sandra Diering, Head of Private Office 
and Tea Japunčić, Private Office Attaché; Sabine Hiernaux-Fritsch, Principal Manager; 
Giuseppe Diana, Head of Task; Daniela Hristova, Marion Schiefele and 
Jacques Sciberras, Auditors. Michael Pyper provided linguistic support. 

Ivana Maletić

Sandra Diering

Tea Japunčić

Giuseppe Diana

Marion Schiefele

Jacques Sciberras

Michael Pyper

 
 
 
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ISSN 1977-5679 

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In February 2021, the European Parliament and the Council 
adopted the regulation establishing the Recovery and Resilience 
Facility, whose purpose is to mitigate the economic and social 
impact of the COVID-19 pandemic. To benefit from the EU 
financial support, Member States have to submit national 
recovery and resilience plans. We examined the Commission’s 
assessment of these national plans and found that it was overall 
appropriate given the complexity of the process and the time 
constraints. However, we identified a number of weaknesses in 
the process and risks for the successful implementation of the 
plans. We make several recommendations to improve the 
Commission’s procedures for future assessments and limit the 
risks and challenges that might affect the implementation of the 
plans. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU.