EU financing through cohesion policy and the recovery and resilience facility : a comparative analysis.
Date: 2023-02-15
Institutions: European Court of Auditors
Subjects: EU Member State, EU aid, EU budget, EU financial instrument, comparative analysis, coronavirus disease, economic and social cohesion, economic recovery, multiannual financial framework, performance audit, report

Review

01

EN

EU financing 
through cohesion 
policy and the 
Recovery and 
Resilience Facility: 
A comparative 
analysis

2023

Contents 

Executive summary 

Introduction 

Scope and approach 

The overall framework 

Similar priorities, but RRF funding is more closely linked to 
reforms 

Similar priorities presented differently 

RRF funding is intended to be more closely linked to reforms included in the 
CSRs, but some important elements remained unaddressed 

Different allocation method of funds and financing through bond 
issuance for the RRF 

The allocation methods of cohesion policy funds and RRF differ 

The RRF is financed through bond issuance 

The RRF eligibility period is shorter, and does not extend beyond 
the instrument’s end 

Governance and management 

The RRF and cohesion policy funds are managed as part of the EU 
budget, but RRF disbursements require Council involvement 

Both cohesion policy funds and RRF grants are part of the EU budget, but 
not RRF loans 

The Commission must consult the Council before disbursing RRF funds 

The Parliament discharge does not cover RRF loans 

Cohesion policy funds and the RRF are implemented under 
different management modes, necessitating additional 
administrative effort 

Cohesion policy is deployed under a common EU framework, while the RRF 
is implemented through national systems 

2 

Paragraph 

I-IX 

01-05 

06-10 

11-24 

11-16 

11-13 

14-16 

17-21 

17-20 

21 

22-24 

25-32 

25-28 

25 

26-27 

28 

29-32 

29 

 
 
Additional administrative efforts at national level are required to implement 
both systems in parallel 

Programming of spending 

RRF programming is more centralised 

RRF is based on a single programming  document for each Member State 
and, at EU level, requires Council approval 

The cohesion policy’s partnership principle is not a prerequisite for the RRF 

Different approaches to assessing programming documents 

3 

30-32 

33-54 

33-38 

33-36 

37-38 

39-44 

The Commission’s assessment of draft RRPs is based on pre-defined criteria 

39-41 

The scope of the Commission’s assessment differs between the two 
instruments 

The parallel programming of cohesion policy funds and the RRF 
led to particular challenges for the Member States 

Two thirds of the RRPs were adopted within six months while the 
preparation  and negotiation of cohesion policy programmes  was delayed 
even more than in previous periods 

Coordinating the simultaneous implementation of the two instruments and 
avoiding the risk of double funding is part of the programming exercise 

Absorption of cohesion policy funds will be influenced by the RRF, but also 
by other factors 

Conditions for making payments 

RRF financing is not linked to costs 

The RRF  finances reforms and investments based on the achievement of 
milestones and targets 

Cohesion policy finances operations primarily based on the reimbursement 
of incurred costs 

Different application of the FNLTC model for the two instruments 

The extent to which RRF financing is more performance-based than cohesion 
policy funds remains to be seen 

The RRF can allow faster disbursement of funds 

Higher pre-financing rates under the RRF compared to cohesion policy 

For both instruments, the management declarations are linked to their 
conditions for payment 

No national or private co-financing required for the RRF 

42-44 

45-54 

45-47 

48-51 

52-54 

55-72 

55-65 

55-59 

60-61 

62 

63-65 

66-72 

67-68 

69-70 

71 

 
 
Under the RRF, decommitments only take place at the end of the eligibility 
period 

Monitoring and cost of implementation 

Different monitoring, reporting and evaluation provisions 

RRF monitoring is linked to milestones and targets 

Performance disconnected from financial reporting for cohesion policy 

Efforts were made to increase transparency  of monitoring data,  but other 
issues remain 

Ex-post evaluations come too late to inform the legislative proposals for the 
next period for both instruments 

The cost of implementation will be difficult to assess for both 
instruments 

Control and audit 

Different control and audit provisions 

Cohesion policy checks mainly focus on the regularity of expenditure 
declared 

RRF checks focus on the satisfactory fulfilment of milestones and targets 

The method for applying suspensions or making partial payments for the 
non-attainment of milestones and targets under the RRF awaits clarification 

The application of the measures to protect the EU’s financial 
interests for the RRF needs to be further clarified 

Payment retentions to protect the EU budget are needed for the cohesion 
policy funds 

4 

72 

73-88 

73-85 

74-76 

77-78 

79-83 

84-85 

86-88 

89-111 

89-99 

91-93 

94-97 

98-99 

100-111 

100-101 

For cohesion policy funds, the Commission can apply payment suspensions 
and financial corrections to protect the EU’s financial interests 

102-104 

For the RRF the Commission relies more on the effectiveness of national 
systems to protect the EU’s financial interests 

Member States can use different systems to report irregularities detected 
for cohesion policy funds and the RRF 

105-107 

108-109 

Potential for using integrated data mining and risk-scoring tools not yet fully 
exploited by cohesion policy and the RRF 

110-111 

Closing remarks 

112-113 

 
 
5 

Annexes 

Annex I – Previous ECA reports 

Annex II – The planned contribution of the RRF to the six pillars 
broken down by Member State 

Annex III – Allocation of the 2021-2027 cohesion policy funds, the 
RRF grants (provisional and final allocation) and the RRF loans 
activated 

Acronyms and abbreviations 

Glossary 

ECA team 

 
 
 
 
6 

Executive summary 

I This review provides a comparative analysis of the 2021-2027  cohesion policy funds 
and the Recovery and Resilience Facility (RRF), with a view to contributing to post-2027 
Multiannual Financial Frameworks. We have examined the similarities and differences 
between the two instruments, focusing on their overall framework, governance and 
management arrangements. 

II In July 2020,  the European Council agreed on the NextGenerationEU (NGEU) 
instrument, a temporary instrument intended to mitigate the impact of the COVID-19 
pandemic on citizens and businesses and enhance the resilience of the EU  and its 
Member States against future shocks. The RRF, a mechanism under which Member 
States can apply for grants and loans, accounts for the bulk of NGEU spending. 
Member States are expected to use the RRF to finance reforms linked more directly to 
country-specific recommendations issued within the framework of the European 
Semester, but also investments, like cohesion policy. This may lead to overall EU 
funding increasing from around 1 % up to 3 % of the EU GDP in the years to come. 

III Financial support under the RRF is provided through grants, like the bulk of 
cohesion policy programmes, and additionally through loans that have to be repaid by 
the Member States. Cohesion policy funding is allocated to Member States using a 
method which takes account of regional disparities. These disparities are not, 
however, taken into account in the distribution of RRF financial support. 

IV The RRF runs concurrently with EU cohesion policy funding mechanisms. This 
allows Member States to choose to finance investments using either the RRF or the 
cohesion policy funds. The RRF is implemented under direct management, while 
cohesion policy funds are implemented under shared management. This means that 
EU and Member State authorities have different responsibilities in connection with 
each source of funding. Regardless of the management mode, the Commission is 
ultimately responsible for implementing the EU budget. The multi-level governance 
structure and the partnership principle applicable to cohesion policy funds do not 
apply to the RRF. The involvement of local and regional authorities, economic and 
social partners and civil society organisations is not required to the same extent as for 
the cohesion policy funds. 

 
 
7 

V The number and rationale of the programming documents for the two instruments 
differ considerably, as do the approval and assessment procedures. Coordinating the 
parallel implementation is part of the programming exercise of both instruments and 
Member States are required to ensure that the two instruments complement rather 
than duplicate each other. During the 2014-2020  period, the European Regional 
Development Fund and the Cohesion Fund provided an equivalent of around 10  % of 
total public investment across the EU-27.  In the current period, the RRF will further 
increase the share of EU-financed public investments in Member States. Where this 
share is already high, the additional RRF funding may further add to the pressure on 
Member States’ ability to spend the funds available to them. 

VI Member States must provide cost estimates for the measures included in their 
Recovery and Resilience Plans (RRPs) to the Commission. The Commission verifies the 
reasonability and plausibility of these estimates in its assessment of the plans, but the 
RRF payments are not linked to these costs. This has a significant impact on the 
manner in which interventions are programmed and planned in the Member States, 
progress is monitored and reported to the Commission, and disbursements are made 
for the satisfactory fulfilment of milestones and targets. Nevertheless, the extent to 
which RRF financing as such is more performance-based than cohesion policy funds 
remains to be seen. The RRF funds are also disbursed under more flexible payment 
conditions than the vast majority of expenditure under cohesion policy funds. 

VII The two instruments also have different provisions governing monitoring, 
reporting and evaluation. The RRF monitoring is based on the achievement of 
milestones and targets, whereas for cohesion policy, the performance information is 
not taken into account in financial reporting. For both instruments, most indicators 
used for monitoring purposes are specific to each programme and each national RRP 
rather than common indicators applicable across the board. Such indicators cannot, 
however, be aggregated to measure performance at EU  level or to make comparisons 
between and across different cohesion policy programmes and the RRPs. Evaluations 
scheduled for both instruments in 2024  need to be closely coordinated, also with the 
mid-term review of cohesion policy in 2025,  for the preparation of the post-2027 
cohesion policy framework. 

 
 
8 

VIII At EU level, the control and audit arrangements for the RRF focus on the 
satisfactory fulfilment of milestones and targets. For cohesion policy funds, control and 
audit arrangements at both Commission and Member State level mainly focus on the 
regularity of incurred expenditure, when expenditure is reimbursed based on real 
costs. For the RRF, the Commission must ensure that the financial interests of the EU 
are effectively protected; to do so, the Commission should receive sufficient assurance 
from Member States that the RRF is implemented in compliance with the EU  and 
national law. In addition, Member States must collect data on final recipients of funds 
and a list of funded measures for the purpose of audit and control. 

IX This comparative analysis is a review, not an audit. In the coming years, the 
simultaneous deployment of the cohesion policy programmes and the RRF will show 
how differences in the regulatory framework affect implementation and results.  

 
 
 
 
9 

Introduction 

01 The Multiannual Financial Framework (MFF) for the 2021-2027  period 1 will 
provide €1  211  billion in funding2. Cohesion policy funding, distributed under the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF) 3 and European 
Social Fund Plus (ESF+) 4, will account for €361  billion of this amount and is distributed 
mostly through grants to Member States (see Box 1). 

Box 1 

Cohesion policy: the EU’s main long-term investment policy 

Cohesion policy is the main long-term investment policy in the EU budget. 
Originally known as “regional policy”, it was introduced by the Treaty of Rome. In 
1988,  the structural funds were integrated in one overarching EU cohesion policy, 
whose objective was to “strengthen economic and social cohesion by reducing 
disparities in the level of development between regions”5. 

02 In early 2020,  the COVID-19 pandemic spread from China to Europe triggering an 
economic downturn that was significantly greater than the one caused by the financial 
crisis of 2008.  At the end of 2021,  the Commission expected a return to pre-pandemic 
levels of economic growth by early 20236.  However, the Russian invasion of Ukraine 
and subsequent rise in energy costs again dampened economic forecasts and further 
delayed economic recovery 7 (see Figure 1). 

1  Council Regulation (EU, Euratom) 2020/2093 laying down the multiannual financial 

framework for the years 2021 to 2027. 

2  The EU’s 2021-2027 long-term budget and NGEU, Facts and figures, 2021, p. 6. 

3  Regulation (EU) 2021/1058 on the European Regional Development Fund and on the 

Cohesion  Fund (the “ERDF/CF Regulation”). 

4  Regulation (EU) 2021/1057 establishing the European Social Fund Plus and repealing 

Regulation (EU) No 1296/2013 (the “ESF+ Regulation”). 

5  Article 174 of the Treaty on the Functioning of the European Union (TFEU). 

6  European Economic Forecast, Autumn 2021, paper 160, 2021, p. 24. 

7  European Economic Forecast, Summer 2022, paper 183, 2022, p. 18. 

 
 
                                                             
Figure 1 – EU-27 GDP volume index, 2006 – summer 2022 (in percent) 

10 

Source: ECA, based on Commission data. 

03 To mitigate the impact of the pandemic on citizens and businesses, boost the 
recovery and foster the resilience of the EU  and its Member States, the Council 
adopted a temporary instrument, NextGenerationEU (NGEU) 8. From 2021  to 2026, 
NGEU will make €807  billion available to the Member States 9. Around 90  % of NGEU 
funding (€724 billion) will be channelled through the Recovery and Resilience Facility 
(RRF) 10. The RRF will provide both grants (€338  billion) and loans (€386 billion) that the 
Member State may request11. Of the remaining €83  billion of NGEU funds €51  billion 
topped up the 2014-2020  cohesion policy programmes through REACT-EU12 (see 
Box 2). 

8  Article 1 of Council Regulation (EU) 2020/2094 establishing a European Union Recovery 
Instrument to support the recovery in the aftermath of the COVID-19 crisis (the “NGEU 
Regulation”). 

9  All amounts in the report are in current prices. 

10  Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility (the “RRF 

Regulation”). 

11  Article 15(2) of the RRF Regulation. 

12  Regulation (EU) 2020/2221 amending Regulation (EU) No 1303/2013 as regards additional 
resources and implementing arrangements to provide assistance for fostering crisis repair 
in the context of the COVID-19 pandemic and its social consequences  and for preparing a 
green, digital and resilient recovery of the economy (the “REACT-EU” Regulation). 

 
 
 
                                                             
11 

Box 2 

RRF: a one-off temporary instrument for economic recovery 

The RRF is a one-off temporary instrument set up under the economic, social and 
territorial cohesion title of the Treaty on the Functioning of the European Union 
(TFEU) 13. The RRF is intended to contribute to recovery from the economic crisis 
caused by the COVID-19 pandemic by encouraging sustainable growth and 
building resilience against future shocks. 

04 Figure 2 presents the overall EU financial support available through the NGEU 
and the MFF in the coming years. 

Figure 2 – EU financial support available through the NGEU and MFF 

NextGenerationEU
€807 bn

2021-2027
Long-term budget
€1 211 bn

Source: ECA, based on Commission data published in April 2021. 

in current prices 

€51 bn

REACT EU

€361 bn

Cohesion policy funds
(ERDF/CF and ESF+)

Recovery and Resilience 
Facility 
€724 bn, of which 
€338 bn for grants and 
€386 bn for loans

€338 bn
grants

€165 bn
activated loans

€221 bn
non-activated loans

Other EU funds

€32 bn

€850 bn

Other policy areas

13  Recital 2 of the RRF Regulation. Article 175 TFEU. 

 
 
 
                                                             
12 

05 There is a single project pipeline for planned investments to be financed from the 
EU budget. As both the RRF and cohesion policy funds are being implemented in 
parallel, the legislation underlying both instruments requires investments to be 
planned and implemented in such a way that the two instruments complement rather 
than duplicate each other. In particular, the legislation requires programming 
documents to specify how such complementarity is envisaged 14. At the same time, any 
double funding is prohibited 15. 

14  Article 28 of the RRF Regulation. Articles 11 and 22(3)(a) of Regulation (EU) 2021/1060 

laying down common provisions  (Common  Provisions  Regulation, the “CPR”). 

15  Recital 62 of the RRF Regulation. 

 
 
 
 
                                                             
13 

Scope and approach 

06 This review provides a comparative analysis of the 2021-2027  cohesion policy 
funds and the RRF, with a view to contributing to post-2027  MFFs. We looked at this 
topic because of the importance of the two instruments for the economic recovery in 
the EU Member States following the COVID-19 pandemic as well as the interest in the 
RRF’s delivery mechanism. We have examined the similarities and differences between 
the two instruments, focusing on their overall framework, governance and 
management arrangements, as well as their interlinkages and the risks and challenges 
arising from the parallel implementation in the coming years. 

07 We compared the legislation underlying the RRF with that underlying the 
cohesion policy funds (ERDF, the CF, ESF+, excluding REACT-EU, the Just Transition 
Fund and the Connecting Europe Facility) for the 2021-2027  period. We also analysed 
RRF-related guidance issued by the Commission and conducted interviews with staff 
members from Directorate-General for Regional and Urban  Policy (DG REGIO, 
Directorate-General for Employment, Social Affairs and Inclusion (DG EMPL) and 
Directorate-General for Economic and Financial Affairs (DG ECFIN), as well as the 
Secretariat-General’s RECOVER task force. 

08 At Member State level, we conducted interviews with the national RRF 
coordinating authorities and other bodies involved in drawing up and implementing 
the national recovery and resilience plans (RRPs) under the RRF and partnership 
agreements for the 2021-2027  period. We selected Germany, Spain, France, Italy, 
Romania and Slovenia for our review, to include both federally and centrally organised 
Member States within the scope. Spain and Italy are also the two biggest recipient 
countries, in terms of combined funding for cohesion policy and the RRF. The RRPs of 
the Member States in our sample had been adopted by the end of September 2021, 
when we started our work. 

09 We also drew on more than 200  publicly available studies and publications by 
other EU institutions, research institutes, academics and think tanks, as well as 
numerous own reports (see Annex I). 

10 This is a review, not an audit. At the time of our work, the RRF was in its second 
year of implementation, whereas the implementation of the cohesion policy funds for 
the 2021-2027  period gradually started in March  2022.   

 
 
14 

The overall framework 

Similar priorities, but RRF funding is more closely linked to 
reforms 

Similar priorities presented differently 

11 Both the RRF and the cohesion policy funds aim at contributing to the EU’s 
political priorities of fostering digital transformation and the green transition 16. They 
also both support “Cohesion, resilience and values” investments under heading 2 of 
the MFF. This overlap gives Member States a great deal of discretion in choosing which 
instrument will finance a given investment. 

12 Spending priorities of the RRF and the cohesion policy funds are structured and 
presented differently. The RRF groups EU  policy areas into six pillars 17, whereas the 
2021-2027  cohesion policy funds support five policy objectives 18 (see Figure 3 and 
Annex II for more details on the planned spending as of October 2022). 

Figure 3 – Cohesion policy objectives and RRF pillars 

Source: ECA, based on the CPR and the RRF Regulation. 

16  Political guidelines of the Commission  2019-2024, 16.7.2019. 

17  Article 3 of the RRF Regulation. 

18  Article 5(1) of the CPR. 

 
 
 
                                                             
15 

13 There are specific differences in how EU funding can be allocated under the RRF 
and the cohesion policy. 

—  The RRF sets budget allocation targets of at least 37  % for the green transition and 
at least 20  % for digital transformation 19. All Member States’ RRPs envisage 
exceeding both thresholds 20. 

—  The 2021-2027  cohesion policy has a thematic concentration requirement. Under 
this requirement, similarly to the RRF, a minimum proportion of ERDF and CF 
funding must be allocated to innovation (at least 25 %, rising to 85 % for the most 
developed regions) and the green transition (at least 30 %) 21; for ESF+, to social 
inclusion (at least 25  %), youth employment (at least 12.5  %), tackling child 
poverty (at least 5 %) and supporting the most deprived persons (at least 3 %) 22. 
Cohesion policy does not finance public administration reforms, with some 
exceptions, such as the targeted reforms of labour market institutions and 
services under the ESF+23. However, it requires the fulfilment of enabling 
conditions, as a prerequisite for the implementation of cohesion policy funds 24. 

Both instruments require Member States to uphold the conditionality for the 
protection of the EU budget25 and to fund only those investments which do no 
significant harm to the environment26. 

19  Articles 18(4)(e) and 18(4)(f) of the RRF Regulation. 

20  Recovery and Resilience Scoreboard. 

21  Article 4 of the ERDF/CF Regulation. 

22  Article 7 of the ESF+ Regulation. 

23  Article 4(1)(b) of the ESF+ Regulation. 

24  Article 15 of the CPR. 

25  Regulation (EU, Euratom) 2020/2092 on a general regime of conditionality for the 

protection of the Union budget. 

26  Article 17 of Regulation (EU) 2020/852 on the establishment of a framework to facilitate 

sustainable investment, and amending Regulation (EU) 2019/2088. 

 
 
                                                             
16 

RRF funding is intended to be more closely linked to reforms included in 
the CSRs, but some important elements remained unaddressed 

14 As part of the European Semester, the Commission analyses structural reform 
and investment needs in the Member States and issues country-specific 
recommendations (CSRs) 27 which provide tailored guidance on macroeconomic, 
budgetary and structural policies 28. 

15 Both the RRF and the cohesion policy require Member States to address the 
challenges and priorities set out in the 2019  and 2020  CSRs 29. As for cohesion policy 
funds, investment priorities are defined during the programming process 30, taking 
account of the CSRs. In the past, we found that Member States had often not 
implemented their CSRs in full, and that the link between EU spending and CSR 
implementation over the 2011-2018  period was weak 31. The Commission recently 
analysed the extent to which the 2019-2020  CSRs had been implemented. It found that 
some or limited progress had been made in respect of 85 % of them, and substantial 
progress in respect of 11  %. Only 1 % of CSRs had been implemented in full. For 3 %, no 
progress had been made 32. 

16 The RRF Regulation links EU funding with national structural reforms more 
directly than the cohesion policy. It requires Member States to address in their RRPs 
“all or a significant subset” of challenges included in CSRs. Furthermore, the reporting 
requirements of the RRF were integrated into the 2022  European Semester. If the 
Commission considers that reforms in the RRPs do not sufficiently address the 

27  Regulation (EU) No 1175/2011 amending Council  Regulation (EC) No 1466/97 on the 
strengthening of the surveillance of budgetary positions  and the surveillance and 
coordination of economic policies. 

28  Articles 121 and 148 TFEU. 

29  Article 17(3) of the RRF Regulation. Article 12(1) of the CPR. 

30  Annex D of the 2019 country reports. 

31  Special report 16/2020: “The European Semester – Country Specific Recommendations 
address important issues  but need better implementation”, paragraphs 41-44 and 60. 
Opinion No 06/2020 concerning the proposal for a regulation of the Parliament and of the 
Council establishing a Recovery and Resilience Facility (COM(2020) 408), paragraph 46. 

32  Commission  communication on the 2022 European Semester – Spring Package, 

COM(2022) 600, Appendix 2, p. 18. 

 
 
                                                             
challenges that Member States are facing, it can propose additional CSRs 33. As we have 
recently reported, some important structural reforms of the 2019  CSRs remained 
unaddressed in RRPs we have examined so far34.  

17 

Different allocation method of funds and financing through 
bond issuance for the RRF 

The allocation methods of cohesion policy funds and RRF differ 

17 Cohesion policy funds and the RRF use different methods to allocate funding to 
Member States. The allocation of cohesion policy funds takes into account national 
and regional disparities, and is based on a well-established formula, the Berlin 
formula35. The method for allocating funds under the RRF was agreed in July 202036. 
This method considers development disparities existing before the pandemic at 
national level, but not at regional level. Some Member States’ GDPs declined because 
of the pandemic. This meant that structural pre-pandemic disparities were a bigger 
factor in determining the allocation of RRF grants than the economic impact of the 
pandemic, even though mitigating the latter was one of the RRF’s primary objectives 
(see Box 3). 

33  The European Semester in the time of the RRF. 

34  Special report 21/2022: “The Commission’s  assessment of national recovery and resilience 

plans: overall appropriate but implementation risks remain”, paragraph 53. 

35  Rapid case review 2019: “Allocation of cohesion policy funding to Member States for 2021-

2027”, March 2019, paragraph 4. 

36  Conclusions  of the special meeting of the Council, EUCO 10/20, 21.7.2020. 

 
 
                                                             
18 

Box 3 

Funding allocation methods 

The main allocation criterion for cohesion policy funds is regional GDP and gross 
national income (GNI) per capita, i.e. relative prosperity compared to the EU 
average, adjusted for purchasing power37. Other factors taken into account are 
unemployment rates, education levels, net migration from outside the EU, and 
greenhouse gas emissions 38. Some final adjustments are applied to ensure that 
enough funds reach the least developed regions 39. 

70  % of the grant component of the RRF is allocated based on the Member State’s 
population, its 2019  GDP per capita, and its average five-year unemployment rate 
for 2015-2019.  The remaining 30 % was provisionally allocated based on the 
estimated fall in GDP in 2020  and 2021,  a provision intended to reflect the 
economic impact of the pandemic40. Price differences between Member States 
are not taken into account for the RRF 41. A cap is applied to prevent funds from 
being concentrated excessively in some Member States 42. 

This estimated maximum allocation of the 30 % of the RRF grant component based 
on GDP decline 43 was updated in June 202244  based on actual GDP changes 45. 

Member States whose grant amount was revised upwards must propose new 
reforms and investments by submitting new RRPs in case they want to use the 
grants, whereas Member States whose final maximum financial contribution was 
decreased are encouraged to continue to implement their original RRPs relying on 
alternative sources of funding, including national funds and the request of a RRF 
loan 46. 

37  Article 108(2) and Annex XXVI of the CPR. 

38  Annexes XXVI(1) to (7) of the CPR. 

39  Annexes XXVI(10) to (17) of the CPR. 

40  Annexes I, II and III of the RRF Regulation. 

41  Annex I of the RRF Regulation. 

42  Annex I of the RRF Regulation. 

43  Annex IV of the RRF Regulation. 

44  Commission  note on the update of the RRF maximum financial contribution, 30.6.2022. 

45  Article 11(2) of the RRF Regulation. 

46  Part I, section II.2.A and B of Commission  guidance on Recovery and Resilience Plans in the 

context of REPowerEU, 2022/C 214/1. 

 
 
                                                             
19 

A maximum RRF loan amount of 6.8 % of 2019  GNI applies in each Member 
State 47. However, the amount of the loan support can be increased in exceptional 
circumstances and subject to availability of resources, i.e. other Member States 
have not used their loan component in full 48. In practice, RRF loans are most 
attractive to those Member States that borrow with an interest rate higher than 
that of the Commission.  

18 In June 2022,  the amounts allocated under the RRF were updated. This update 
resulted in 19  Member States receiving less than initially estimated. The grant amounts 
for Belgium, the Netherlands and Hungary decreased the most, by 24 %, 22  % and 
19  % respectively. Portugal received the largest increase (12 %), followed by Spain 
(11 %) and Germany (9 %). Spain and Italy were the two largest recipients of the RRF 
grant component, together receiving 43 % of the final RRF allocation. Poland is the 
largest recipient of 2021-2027  cohesion policy funding (20 %), followed by Italy (12 %) 
and Spain (10 %) (see Annex III and Figure 4). 

47  Article 14(5) of the RRF Regulation. 

48  Article 14(6) of the RRF Regulation. 

 
 
                                                             
Figure 4 – Cohesion policy funding and final allocation of RRF grants by 
Member State 

In million euros, current prices 

20 

Source: ECA, based on Commission data, including ETC and excluding the amounts transferred to CEF, 
extracted in July 2022 for the RRF and published in April 2021 for the cohesion policy funds. 

19 RRF loans can be requested up to August 202349.  By October 2022,  loans had
been requested by just seven Member States 50, amounting to €165  billion (43 % of the 
total available loan amount). Italy, Greece and Romania were the only Member States 
which requested the maximum amount. 

49  Article 14(2) of the RRF Regulation. 

50  Greece, Italy, Cyprus, Poland, Portugal, Romania and Slovenia. 

21 

20 If the RRF’s loan component is used in full, the proportion of public spending 
financed by the EU in Member States will increase from around 1 % to up to 3 % of 
EU GDP. The RRF will further increase the proportion of EU-financed public 
investments in Member States. In 2021,  the Commission expected public investment 
to increase from 3 % in 2019  to 3.5 % of EU GDP in 2023.  The RRF will account for a 
large part of this increase 51. 

The RRF is financed through bond issuance 

21 Spending under the EU  budget, including through the cohesion policy funds, is 
primarily financed from Member State contributions and, to a lesser extent, other 
specific revenue 52. In contrast, NGEU  – and thus the RRF – is entirely financed by 
borrowing on capital markets 53. Issuing common debt on such a scale is a major 
novelty for the EU (see Box 4). 

51  European Economic Forecast, Autumn 2021, paper 160, p. 35. 

52  Articles 2(1) of Council Decision (EU, Euratom) No 2020/2053 on the system of own 

resources of the EU. 

53  Article 5(1) of Council  Decision (EU, Euratom) No 2020/2053. 

 
 
                                                             
22 

Box 4 

Financing through bond issuance 

By 2026,  the Commission will raise funds for the NGEU by issuing EU bonds 54.  
The bond terms will vary. The longest terms will be 30 years, but other bonds will 
be issued for much shorter terms, including short-term ‘EU bills’ with maturity 
periods shorter than a year. All NGEU debt will be paid back by 205855.  The EU 
budget will bear the repayment of the principal and the related interest for the 
funds used as grants. RRF loans and the costs related to the borrowing of funds, 
including the interest, will be repaid by the Member States receiving the loan 56.  
By end of October 2022,  the Commission had issued €226  billion in bonds 57 and 
disbursed €81.4 billion in grants and €34.2 billion in loans. 

We are currently working on an audit on the NGEU debt management by the 
Commission. We plan to publish our report in 2023. 

The RRF eligibility period is shorter, and does not extend 
beyond the instrument’s end 

22 The eligibility period for the 2021-2027  cohesion policy funds is nine years 58.  
For the 2014-2020  period, the eligibility period is ten years 59. The RRF’s eligibility 
period is shorter, at six and a half years. During this period, the agreed milestones and 
targets must be attained and the related payments can be made until the end of 
202660.  As well as being longer, the cohesion’s policy eligibility period runs beyond the 
end of the programming period, while the RRF’s does not. Like for cohesion policy 

54  Articles 4 and 7 of Commission  Implementing Decision C(2021) 2502 final establishing the 
necessary arrangements for the administration of the borrowing operations under Council 
Decision (EU, Euratom) 2020/2053 and for the lending operations related to loans granted 
in accordance with Article 15 of the RRF Regulation. 

55  Article 6 of Council Decision (EU, Euratom) No 2020/2053. 

56  Article 5(2) of Council  Decision (EU, Euratom) No 2020/2053. Article 15(3) of the RRF 

Regulation. Article 220(5)(e) of the Financial Regulation. 

57  The EU as a borrower – investor relations. 

58  Article 63(2) of the CPR. 

59  Article 65(2) of Regulation (EU) No 1303/2013 laying down common provisions  (the “2014-

2020 CPR”). 

60  Articles 17(2), 18(4)(i) and 24(1) of the RRF Regulation. 

 
 
                                                             
funds, Member States are however not obliged to spend all available RRF funding until 
the end of the period (see Figure 5). 

Figure 5 – The eligibility periods of the cohesion policy funds and the RRF 

23 

CP 2014-2020

finances

NGEU

REACT – EU

RRF

February 
2020

August 
2026

CP 2021-2027

Period prior to the adoption of the relevant regulation for which measures already 
implemented can be financed retroactively
Additional spending period after end of the programming period

Source: ECA, based on the 2014-2020 and 2021-2027 CPR, RRF, and REACT-EU Regulations. 

23 Under the cohesion policy, expenditure can be declared for reimbursement after
the programming period ends. This introduces an overlap between periods: the 
eligibility period for one programme extends over the beginning of the following 
programming period, and may discourage the timely starting of the subsequent 
period. 

24 Moreover, as we have pointed out in the past, such a l ong timeframe makes it 
more difficult to define investment needs when negotiating partnership agreements 
and programmes 61. To address this, if justified, cohesion policy programmes can be 
amended during the course of the programming period 62. For the RRF no 
disbursements will be made by the Commission after the end of 2026. 

61  Special report 36/2016: “An assessment of the arrangements for closure of the 2007-2013 

cohesion and rural development programmes”, paragraphs 58-64 and 128-130. 

62  Special report 24/2021: “Performance-based financing in Cohesion  policy: worthy 

ambitions, but obstacles remained in the 2014-2020 period”, paragraph 82. 

24 

Governance and management 

The RRF and cohesion policy funds are managed as part of the 
EU budget, but RRF disbursements require Council involvement 

Both cohesion policy funds and RRF grants are part of the EU budget, but 
not RRF loans 

25 Cohesion policy funds are part of the EU’s annual budget and accounts 63. 
Although the NGEU budget was adopted outside the MFF, RRF grants are part of the 
EU’s annual budget and the consolidated accounts 64. RRF loans are not part of the  
EU budget, but included in the consolidated accounts 65. Nevertheless, for transparency 
purposes, the Commission also presents information on the loan component in the 
draft budget66. 

The Commission must consult the Council before disbursing RRF funds 

26 The Commission, more specifically DG REGIO and DG EMPL, shares the 
responsibility with the Member States for managing cohesion policy funds 67.  
The situation for the RRF is different. The Secretariat-General’s Recovery and 
Resilience task force (RECOVER) and DG ECFIN manage the RRF directly 68. The 
Commission coordinates the work of its different departments internally to ensure 
consistency between the two instruments. 

63  Article 10 of the Regulation (EU, Euratom) 2018/1046 on the financial rules applicable to 

the general budget of the Union (the “Financial Regulation”). 

64  Article 21(6), 83(1)(b)(i)  and 244(1)(a) of the Financial Regulation. 

65  Commission  communication on the consolidated annual accounts of the European Union 

for the Financial Year 2021, COM(2022) 323 final, Note 2.4.1.1, p. 65. 

66  Commission  Statement of Estimates for the financial year 2022, p. 17. 

67  Article 7 of the CPR. 

68  Article 8 of the RRF Regulation. 

 
 
                                                             
25 

27 The Commission alone is responsible and accountable for approving
disbursements under cohesion policy programmes. The arrangements for the RRF are 
different here as well. Before adopting the decision authorising any disbursements 
under the RRF, the Commission must submit its preliminary assessment and take into 
account the opinion of the Council’s Economic and Financial Committee. A committee 
of Member States’ representatives has to examine the Commission’s decision and can 
overturn it with a qualified majority 69. 

The Parliament discharge does not cover RRF loans 

28 There is a clear separation of responsibilities for cohesion policy funds between 
the Parliament and the Council (as the budgetary and discharge authority) and the 
Commission (in charge of implementing the budget). The EU’s annual budget is 
approved by the Parliament, with the agreement of the Council 70. The Commission 
draws up annual accounts, for which it must seek approval – or “discharge” – from the 
Parliament. The Parliament may grant discharge, based on the recommendation of the 
Council 71. The Parliament’s power to grant discharge to the Commission also applies to 
the RRF 72. This discharge, however, does not cover the loan component of the RRF. 

69  Articles 24(4) and 24(5) of the RRF Regulation. 

70  Article 314 TFEU. 

71  Article 319 TFEU. Article 261(1) of the Financial Regulation. 

72  Annex I, point 39 of the Interinstitutional Agreement between the Parliament, the Council 
and the Commission  on budgetary discipline, on cooperation in budgetary matters and on 
sound financial management, as well as on new own resources, including a roadmap 
towards the introduction of new own resources. 

26 

Cohesion policy funds and the RRF are implemented under 
different management modes, necessitating additional 
administrative effort 

Cohesion policy is deployed under a common EU framework, while the 
RRF is implemented through national systems 

29 There are clear differences in how the instruments are implemented on the
ground. For example, the responsibilities of national and regional administrations are 
different. Cohesion policy funds are implemented by all Member States and regions 
based on the framework set out in the Common Provisions Regulation (CPR). The RRF 
is implemented through national systems, which by definition are specific to each 
Member State (see Box 5). 

Box 5 

The responsibilities of administrations in the Member States 

Cohesion policy funds are implemented under shared management, through both 
national and regional programmes. Hundreds of national and regional authorities 
in the Member States are involved in programming, implementation, monitoring 
and audit. Beneficiaries of EU funds can be public or private bodies, entities with 
or without legal personality, or natural persons that are responsible for initiating 
or both initiating and implementing operations 73. 

The RRF is implemented under direct management, and Member States are the 
beneficiaries74. At the same time, they are responsible for ensuring compliance 
with key principles of sound financial management. At Member State level, a lead 
authority (the “RRF coordinator”) has overall responsibility and acts as the single 
point of contact  for the Commission 75. Ministries or regions may be entrusted with 
implementing projects and reporting to this coordinator on their progress. 

73  Article 2(9) of the CPR. 

74  Article 22(1) of the RRF Regulation. 

75  Commission  guidance to Member States on RRPs (Part 1/2), SWD(2021) 12 final. p. 46. 

27 

Additional administrative efforts at national level are required to 
implement both systems in parallel 

30 Implementing the RRF in parallel with the cohesion policy funds may exacerbate
administrative capacity problems. In half of the Member States in our sample, the 
same bodies are responsible for designing and implementing both cohesion policy 
funds and the RRF 76. In these cases, the RRF is drawing on capacity developed by 
national authorities for implementing cohesion policy funds. Such arrangements also 
help to mitigate the risk of double funding. 

31 Two of the Member States in our sample (Italy and Romania) included specific 
measures in their RRPs to address administrative capacity issues. Also, some of the 
Member States in our sample (Italy, Romania and France) have indicated to us that 
they intend to employ additional staff to implement the RRF (see Box 6). 

Box 6 

Administrative capacity measures in Italy 

Italy, one of the largest recipients of RRF, REACT-EU and cohesion policy funds, 
envisages a number of actions to increase its administrative capacity: 

— 

— 

— 

the creation of a new technical and operational support service to provide 
a pool of multidisciplinary experts from different public bodies from whom 
central, regional and local administrations involved in the RRF can seek 
specialist expertise; 

the introduction into national law of measures that simplify and accelerate 
the award and implementation of public contracts; and 

the recruitment of 2 800  public servants for bodies involved in the 
implementation of EU funds. 

76  Spain, Romania and Slovenia out of the Member States in our sample. 

28 

32 Technical assistance is envisaged under both instruments, but in different forms. 
For cohesion policy funds, Member States can use technical assistance for preparation, 
training, management, monitoring, evaluation, visibility and communication 
purposes 77. The maximum possible amount of technical assistance for the 2021-2027 
period amounts to around €14  billion. In addition, for both instruments, Member 
States can make use of the Technical Support Instrument (TSI) 78 with a total budget of 
€864  million. The TSI supports public administration in designing, developing and 
implementing reforms, and in preparing investments. 

77  Article 36 of the CPR. 

78  Regulation (EU) 2021/240 establishing a Technical Support Instrument. 

 
 
 
 
                                                             
29 

Programming of spending 

RRF programming is more centralised 

RRF is based on a single programming document for each Member State 
and, at EU level, requires Council approval 

33 RRF programming is based on one a single document for each Member State.  
This document, the RRP, details the investments and reforms supported by the RRF 
grants and, where relevant, loans. This is assessed by the Commission, which provides 
a proposal for a Council Implementing Decision (CID) setting out a binding set of 
measures, the associated milestones and targets to be achieved, and the number and 
amount of instalments. Once the CID is adopted, it is complemented by operational 
arrangements dealing with technical implementation issues 79, the financing 
agreements on which the budgetary commitments are based 80, and the loan 
agreements 81, if applicable. 

34 For cohesion policy funds, each Member State signs a partnership agreement 
with the Commission, which sets out the strategic orientation of the funding and the 
arrangements for using it82. It contains details of national or regional programmes 
intended to address the main challenges facing the country or the region 83. The 
Commission adopts implementing acts to approve both the partnership agreement 
and the programmes 84. 

79  Articles 18(1) and 20(6) of the RRF Regulation. 

80  Article 23 of the RRF Regulation. Article 7(3) of the Financial Regulation. 

81  Article 15 of the RRF Regulation. 

82  Article 10(1) of the CPR. 

83  Article 22(3) of the CPR. 

84   Articles 12(4) and 23(4) of the CPR. 

 
 
                                                             
30 

35 Figure 6 summarises the assessment and approval process for the programming 
of spending. 

Figure 6 – Programming of spending process 

PROCESS 

COHESION POLICY 

RRF 

DESIGN 

Member States draft 
their programming 
documents 

SUBMISSION 

Member States submit 
their programming 
documents to the 
Commission 

ASSESSMENT 

The Commission assesses 
the programming 
documents and 
discusses them with 
each Member State 

ADOPTION 

The programming 
documents are adopted 

Several national and 
regional points of contact 
in the Member States; 
Directorates-General 
responsible: DG REGIO and 
DG EMPL 

One partnership 
agreement at national level 
and one or several 
programmes (national or 
regional) 

A single entity in the 
Member States acting as 
the national coordinator 
and point of contact for 
the Commission. 
Responsible bodies 
within the Commission: 
RECOVER and DG ECFIN 

One main programming 
document, the RRP 

Three months to submit 
observations (for 
partnership agreement and 
programmes) 

Two months to complete 
the assessment process, 
but can be extended. 
One month for the 
Council to approve 

The Commission adopts 
the partnership agreement 
within four months and the 
programme within five 
months from their official 
submission through 
implementing acts 

Commission 
endorsement and Council 
adoption through Council 
Implementing Decision 

Source: ECA, based on the CPR and the RRF Regulation. 

 
 
 
 
 
 
 
 
 
 
 
 
31 

36 Changes to cohesion policy programmes only require the assessment and 
approval of the Commission 85. Changes to RRPs require the Commission’s assessment 
and a Council’s approval as well 86. This creates a safeguard to ensure that Member 
States intend to follow their commitments as set out in the RRPs. We have noted 
previously that amendments to cohesion policy programmes, including budget 
reallocations within the limits authorised by the CPR, occur frequently during 
implementation 87. 

The cohesion policy’s partnership principle is not a prerequisite for the 
RRF 

37 For cohesion policy funds, Member States must apply the partnership principle in 
accordance with the European code of conduct on partnership 88. Public authorities at 
regional, local and urban level, civil-society organisations, and economic and social 
partners can all contribute to drawing up partnership agreements, and to preparing, 
implementing and evaluating each programme 89. This aims to ensure that funds 
address the needs and challenges that were brought forward. 

38 The procedure used for the RRF is different. When drawing up RRPs, national 
authorities are only required to consult local and regional authorities, social partners, 
civil society, and youth organisations to the extent required by domestic legislation. 
The consultation procedure is summarised in the RRPs themselves90. 

85  Articles 13(4) and 24(4) of the CPR. 

86  Article 21(2) of the RRF Regulation. 

87  Special report 24/2021, paragraphs 53-57 and 120. 

88  Commission  Delegated Regulation (EU) 240/2014 on the European code of conduct on 

partnership in the framework of the ESI Funds. 

89  Article 8 of the CPR. 

90  Article 18(4)(q) of the RRF Regulation. 

 
 
                                                             
32 

Different approaches to assessing programming documents 

The Commission’s assessment of draft RRPs is based on pre-defined 
criteria 

39 Under cohesion policy, the Commission assesses whether partnership 
agreements and programmes comply with the CPR and the relevant fund-specific 
rules 91. Instead, for the RRF, the Commission carries out an ex ante assessment in 
which it applies 11 broad and generic qualitative criteria, such as whether the RRP 
represents a comprehensive and adequately balanced response to the economic and 
social situation, and whether the total estimated costs are in line with the principle of 
cost efficiency and commensurate with the expected national economic and social 
impact92. 

40 Previously, we have noted that the Commission has some flexibility in 
interpreting and rating these criteria, and that such an exercise necessarily involves 
qualitative judgements 93. In a recently published report, we examined the 
Commission’s assessment of the RRPs for a sample of Member States. We found that 
the assessment 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 payment profiles being the result of negotiations, milestones 
and targets lacking clarity, and monitoring and control systems not yet being fully in 
place at the time of the assessment94. 

41 Also, transparency requirements differ. The Commission’s assessments of 
adopted RRPs are publicly available 95, whereas those of cohesion policy partnership 
agreements and programmes are only shared with the national and regional 
authorities concerned. 

91   Articles 12(1) and 23(1) of the CPR. 

92   Articles 19(3)(a) and 19(3)(i) of the RRF Regulation. 

93  Opinion No 06/2020, paragraph 44. 

94  Special report 21/2022, paragraphs 112-113. 

95  The Commission  prepared a summary of the assessment of the RRPs, available here. 

 
 
                                                             
33 

The scope of the Commission’s assessment differs between the two 
instruments 

42 The Commission’s Better Regulation Guidelines 96 set out five criteria: 
effectiveness, efficiency, relevance, coherence and EU added value. Four of these are 
used for assessing both RRPs under the RRF and partnership agreements and 
programmes under cohesion policy. Meanwhile, the scope of the Commission’s 
assessment differs for each instrument (see Figure 7). 

96   Commission  Staff Working Document, ”Better Regulation Guidelines”, SWD(2021) 305, 

pp. 23 and 26. 

 
 
                                                             
34 

Figure 7 – The scope of the assessment  

CRITERIA 

EFFECTIVENESS 

Article 11(1)(b) of the CPR 

Article 19(3)(g) and 
criterion 2.7 in Annex V of 
the RRF Regulation 

EFFICIENCY 

Articles 11(1)(c) and 
22(3)(g) of the CPR 

Article 19(3)(i) and 
criterion 2.9 in Annex V of 
the RRF Regulation 

RELEVANCE 

Article 22(3)(a) of the CPR 

Article 19(3)(c) and 
criterion 2.3 in Annex V of 
the RRF Regulation 

COHERENCE 

Articles 5(3) and 11(1)(b) 
of the CPR 

Article 19(3)(k) and 
criterion 2.11 in Annex V 
of the RRF Regulation 

COHESION POLICY 

RRF 

The partnership agreement 
describes the main results 
expected for each fund and 
the expected contribution 
to the selected policy 
objectives 

The proposed preliminary 
financial allocation respects 
the rules on thematic 
concentration and provides 
data by policy objective at 
national and regional level 

The main challenges to be 
addressed stem from 
economic, social and 
territorial disparities 

Coordination and 
coherence between the 
funds and between the 
national and regional 
programmes, 
complementarities and 
synergies with other EU 
instruments (including the 
RRF) for each selected 
policy objective 

RRP is intended to have a 
lasting impact in terms of 
structural changes in the 
administration or policies 

Estimated total costs are 
reasonable and plausible. 
No examination of support at 
regional level 

RRP contributes to the 
economic, social and 
institutional resilience of the 
Member State by reducing 
economic vulnerability to 
shocks and increasing the 
capacity of economic and 
social structures and 
institutions to adjust and 
withstand shocks 

Internal coherence of the 
measures included in the 
RRP, i.e. the measures 
proposed reinforce and 
complement each another 

Source: ECA, based on the CPR and the RRF Regulation. 

 
 
 
 
 
 
 
 
 
 
 
 
35 

43 Member States must provide cost estimates for the measures included in their 
RRPs to the Commission. In its assessment of RRPs, the Commission verifies the 
reasonability and plausibility of these estimates and examines whether the proposed 
support will complement other EU  financing97. It also checks whether the support will 
substitute recurring national expenditure 98. To inform broader estimates on the 
investment level, Member States were required to provide the average level of 
national public expenditure each year from 2017  to 2019  for investments similar to 
those in the RRPs 99. 

44 In cohesion policy, EU added value was assessed under the concept of
additionality: the requirement that cohesion policy funds may not replace recurring 
national expenditure 100. However, since 2007, the requirement for Member States to 
demonstrate this has been gradually lifted. In the 2021-2027  period, the Commission 
will no longer verify additionality when assessing partnership agreements and 
programmes (see Box 7). 

97  Articles 9, 19(3)(i) and criterion 2.9 in Annex V of the RRF Regulation. 

98  Article 5(1) of the RRF Regulation. 

99   SWD(2021) 12, Part 1/2, p. 55. 

100 Article 95(2) of the 2014-2020 CPR. 

36 

Box 7 

The additionality requirement for the cohesion policy 

During the 2007-2013  period, Member States with regions covered by the 
convergence objective, i.e. those whose per capita GDP was less than 75 % of the 
EU average, were required to maintain the same level of public or equivalent 
structural expenditure throughout the period in each region concerned 101. 

During the 2014-2020  period, the additionality requirement was deemed to be 
fulfilled as long as Member States maintained the same level of public structural 
expenditure throughout the period at national level. No reference was made to 
regional expenditure levels. This requirement was verified only for those Member 
States whose less developed regions covered at least 15  % of their total 
population, under certain conditions 102. 

For the 2021-2027  period, as a simplification measure, the Commission no longer 
requires Member States to demonstrate the additionality of programmes 103. 

The parallel programming of cohesion policy funds and the RRF 
led to particular challenges for the Member States 

Two thirds of the RRPs were adopted within six months while the 
preparation and negotiation of cohesion policy programmes was delayed 
even more than in previous periods 

45 In previous MFF periods, the Commission’s negotiation of partnership 
agreements and programmes was delayed, and never completed before the end of the 
first year of the MFF. These delays were due to the late adoption of the MFF package, 
which in turn delayed the adoption of the cohesion policy package, which is a 
prerequisite for programming at Member State level 104. 

101 Article 15(2) of Council  Regulation (EC) No 1083/2006 laying down general provisions  on 
the ERDF, the ESF and the Cohesion  Fund and repealing Regulation (EC) No 1260/1999. 

102 Article 95(4) of the 2014-2020 CPR. 

103 Simplification Handbook, measure No. 16, p. 3. 

104 Special report 17/2018: “Commission’s and Member States’ actions in the last years of the 
2007-2013 programmes tackled low absorption but had insufficient focus on results”, 
paragraphs 14-18 and 83. 

 
 
                                                             
37 

46 For the 2021-2027  period, delays lasted even longer: as we have reported 
previously, the CPR and fund-specific regulations were adopted in mid-2021, 
six months after the start of the MFF period 105. Managing authorities were also 
involved in programming REACT-EU, and in implementing other emergency measures 
such as the RRF, the Coronavirus Response Investment Initiatives (CRII and CRII+) 106 
and Cohesion’s Actions for Refugees in Europe (CARE and CARE+) 107. This means that 
their administrative capacity was spread even more thinly. The preparation of 
partnership agreements and programmes and their negotiation with the Commission 
therefore slowed down significantly in almost all Member States during 2021.  One 
consequence of this delay is that Member States will have to absorb their allocated 
cohesion policy funds for the 2021-2027  MFF in a shorter timeframe. We have 
previously noted that absorption patterns vary across Member States 108 and that there 
have been delays in absorbing the 2014-2020  cohesion policy funds 109. 

47 For the RRF, programming and adoption were quicker. In the six months between 
February (when the RRF Regulation was adopted) and July 2021,  18  RRPs were 
adopted 110. This rapid finalisation of the negotiations was intended, because the RRF’s 
objective was to respond to an acute and imminent crisis. Furthermore, the lower 
number of RRF programming documents, compared to the almost 400  partnership 

105 2021 Annual reports, paragraph 2.6. 2020 Annual reports, paragraphs 2.24-2.25. Special 

report 14/2021: ”Interreg cooperation: The potential of the European Union’s cross-border 
regions has not yet been fully unlocked”, paragraph 92. Special report 24/2021, 
paragraphs 83 and 124. 

106 Regulation (EU) 2020/460 amending Regulations (EU) 1301/2013, (EU) 1303/2013 and (EU) 
508/2014 as regards specific measures to mobilise  investments in the healthcare systems of 
Member States and in other sectors of their economies in response to the COVID-19 
outbreak. Regulation (EU) 2020/558 amending Regulations (EU) 1301/2013 and (EU) 
1303/2013 as regards specific measures to provide exceptional flexibility for the use of the 
European Structural and Investments Funds  in response to the COVID-19 outbreak. 

107 Regulation (EU) 2022/562 amending Regulations (EU) No 1303/2013 and (EU) No 223/2014 
as regards Cohesion’s  Action for Refugees in Europe. Regulation (EU) 2022/613 amending 
Regulations (EU) No 1303/2013 and (EU) No 223/2014 as regards increased pre-financing 
from REACT-EU resources and the establishment of a unit cost. 

108 2021 Annual reports, paragraph 2.16. Special report 17/2018, paragraphs 27 and 28. 

109 2021 Annual reports, paragraphs 2.26. 

110 Belgium, Czechia, Denmark, Germany, Ireland, Greece, Spain, France, Croatia, Italy, Cyprus, 

Latvia, Lithuania, Luxembourg, Austria, Portugal, Slovenia and Slovakia. 

 
 
                                                             
38 

agreements and national and regional programmes, helped the Commission to 
conclude its assessment in a timely manner (see Box 8). 

Box 8 

Adoption and implementation status 

By October 2022: 

—  26  RRPs had been adopted by the Council, 8 more than by the July 2021. 

The remaining one of Hungary was still being assessed by the Commission; 

—  17  operational arrangements had been signed by the Commission and the 

Member States; 

—  12 applications for payment had already been validated and paid, with the 
Commission expecting that around 32  % of the grant amounts will be paid 
during 2022111; 

— 

In the following months, some of the RRPs will be amended by the Member 
States and resubmitted for endorsement by the Commission and adoption by 
the Council as a result of the adjusted maximum grant allocation of June 2022 
(see Box 3). 

In comparison, for the cohesion policy funds: 

—  23 of the 27  partnership agreements and 185  of the 371  programmes in the 
scope of this review had been approved by the Commission for the 2021-
2027  period; 

—  no interim payment request had yet been submitted for the 2021-2027 

period. In 2022,  pre-financing payments make up the bulk of the amount 
expected to be paid; 

— 

the Commission has made payments corresponding to 72 % of the funds for 
the 2014-2020  period. The Netherlands, Denmark and Croatia had absorbed 
less than 58  % of their allocations (including REACT-EU), and Belgium, 
Germany, Italy, Malta, Slovakia and Spain had absorbed less than 65 %. 

111 Based on data in the Commission  Statement of Estimates for the financial year 2022, p 34. 

39 

Coordinating the simultaneous implementation of the two instruments 
and avoiding the risk of double funding is part of the programming 
exercise 

48 Member States were required to describe in their RRPs how they would
coordinate the parallel implementation of the instruments, taking into account the 
amounts involved, the availability and timeline of mature projects, and the level at 
which the institutional and legal framework sets the responsibility for implementing  
a reform or investment112. This is also a requirement for partnership agreements and 
programmes under the cohesion policy. 

49 Complementarities and synergies are achieved either by financing different 
operations that build on each other, or by using the two instruments to finance 
different elements of the same operation. In most cases, the descriptions given in the 
RRPs were general and brief, partly because the 2021-2027  partnership agreements 
and programmes had not yet been drawn up. As a result, national authorities had to 
take the content of their RRPs into account in their 2021-2027  cohesion policy 
partnership agreements. This exercise was easier for Member States that had 
established a strategic demarcation framework beforehand (see Box 9). 

Box 9 

The demarcation framework in France 

To analyse potential overlaps between the RRF and the 2021-2027  cohesion policy 
funds, clarify which type of investments were to be financed by which fund, the 
French authorities have indicated to us that they set up a demarcation framework, 
which was later published in a guide 113. 

Four main criteria were used as the basis: 

—  a timing criterion, absorbing funds on a sequential basis by using, first, the 

RRF or remaining funds from the 2014-2020  period, including REACT-EU and, 
second, the 2021-2027  cohesion policy funds; 

—  a theme criterion, depending on the eligible themes covered; 

—  a beneficiary criterion, using the RRF for specific types of beneficiaries; 

112 SWD(2021) 12, Part 1/2, p. 43. 

113 The guide published  by the French authorities is available here. 

40 

—  a territorial criterion, allocating the RRF and cohesion policy funds to 

separate territories in accordance with preselected investment priorities by 
geographical area. 

Although the existence of such a framework does not remove the need for 
further coordination during implementation at regional and project level, it 
helps to establish the main principles. 

50 In its assessment of the RRPs, the Commission had to examine complementarity
and coordination with other EU funds 114. The operational arrangements signed with 
each Member State for the RRF also provide for an annual event to be held in each 
Member State to discuss the implementation of both the RRP and other EU 
programmes 115. 

51 An operation can be financed by both instruments as long as the same cost is
covered only once, and as long as the RRF does not cover the mandatory national co-
financing of cohesion policy projects 116. All Member States we consulted reported that 
they had considered this risk and taken measures to mitigate it. The Commission had 
to assess ex ante whether the RRPs contained such measures 117. 

Absorption of cohesion policy funds will be influenced by the RRF, but 
also by other factors 

52 Following the adoption of the RRF, Member States can spend significantly more
money on investments than previously for the economic, social and territorial 
cohesion. Six countries can spend at least twice as much as they did in the 2014-2020 
period 118; seven countries at least three times as much 119; and two countries, 
Luxembourg and the Netherlands, seven times more. 

114 SWD(2021) 12, Part 1/2, p. 44. 

115 Commission  report on the implementation of the Recovery and Resilience Facility, 

COM(2022) 75, pp. 7 and 57. 

116 Article 9 of the RRF Regulation. SWD(2021) 12, Part 1/2, p. 42. 

117 Article 19(3)(j) and criterion 2.10 in Annex V of the RRF Regulation. 

118 Bulgaria, Germany, Ireland, Greece, Cyprus, and Finland. 

119 Belgium, Denmark, Spain, France, Italy, Austria and Sweden. 

41 

53 During the 2014-2020  period, the ERDF and the CF provided funding equivalent 
to around 10 % of total public investment across all 27  EU Member States. In 
10  Member States 120, funding from the ERDF and the CF accounted for more than a 
third of all public investments 121. For these Member States, absorbing significantly 
more EU funds in the 2021-2027  period will be a particular challenge 122. 

54 Pressure to absorb funds increases towards the end of the eligibility period, as we
have already reported previously 123. This can lead to less consideration being given to 
the added value of investments, possibly at the expense of observing certain eligibility 
rules and achieving good value for money 124. However, for the 2021-2027  period, a 
number of aspects changed. These may mitigate some of the absorption challenge for 
cohesion policy funds. 

—  Large-scale infrastructure projects are often financed in multiple consecutive 
periods. This is often necessary because of the amount of time needed to put 
such projects into service. But as we have noted in the past, it can also be a 
consequence of delays during planning and construction 125. After 2026,  no further 
disbursements from the RRF will be made to the Member States. In case certain 
RRF investments are not completed and require additional financing, such funding 
may be found in cohesion policy programmes. This also illustrates the need for 
coherence in the programming of the two instruments. 

—  The CPR allows Member States to reallocate up to 5 % of their initial national 

envelopes for each cohesion policy fund to any other instrument under direct or 
indirect management, including their RRPs. This also takes into account possible 

120 Bulgaria, Estonia, Croatia, Latvia, Lithuania, Hungary, Poland, Portugal, Romania, and 

Slovakia. 

121 Commission,  8th cohesion report, p. 243. 

122 2016 Annual report, paragraphs 2.24 and 2.25. 

123 Rapid case review 2019: “Outstanding commitments in the EU budget – A closer look”, April 

2019, paragraphs 20 and 34-39. Special report 17/2018, paragraphs 20-21 and 83-84. 

124 Special report 17/2018, paragraphs 15 and 87. 

125 Review 05/2021: ‘The EU framework for large transport infrastructure projects: an 

international comparison’, paragraphs 52-53, p. 27. Special report 10/2020: “EU transport 
infrastructures: more speed needed in megaproject implementation to deliver network 
effects on time”, paragraphs 45-48 and 84-86. 

42 

transfers to InvestEU programme126 at partnership agreement level or through 
programme amendments. In May 2022,  the Commission proposed to increase 
this to 12.5 %, under certain conditions 127, as one of the REPowerEU measures 128. 
We have provided an opinion on this proposal 129. 

—  Lastly, both the RRF and the 2021-2027  cohesion policy funds will be 

implemented in a context of higher prices due to inflation. For the RRF, this will 
put additional pressure on Member States to control costs or commit additional 
national funds to complete RRF investments and reforms. For cohesion policy 
funds, financing is generally based on actual costs incurred. As the increased costs 
will be borne partly by the EU budget, this will likely result in a higher absorption 
rate. 

126 https://investeu.europa.eu/index_en  

127 Commission  communication on the REPowerEU Plan, COM(2022) 230 final, paragraph 4.3. 

128 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131  

129 Opinion No 04/2022 concerning the proposal for a Regulation of the Parliament and of the 
Council amending Regulation (EU) 2021/241 as regards REPowerEU chapters in recovery 
and resilience plans and amending Regulation (EU) 2021/1060, Regulation (EU) 2021/2115, 
Directive 2003/87/EC and Decision (EU) 2015/1814 [2022/0164 (COD)]. 

43 

Conditions for making payments 

RRF financing is not linked to costs 

The RRF finances reforms and investments based on the achievement of 
milestones and targets 

55 The Financial Regulation sets out three forms of EU financial support 130:

— 

— 

‘Reimbursement of costs actually incurred’ involves EU funding being reimbursed 
based on the real costs incurred by the beneficiary. These costs must be 
substantiated by supporting documents. 

‘Simplified cost options’ (SCOs) reimburse expenditure at a rate calculated in 
advance. Standard scales of unit costs and lump sums can link payments to 
outputs, but not necessarily to results 131. 

—  Under the ‘financing not linked to costs’ (FNLTC) model, an operation receives  

EU funding when it achieves results or meets conditions established previously in 
legislation. FNLTC was first introduced in 2018,  when the Financial Regulation was 
revised. 

56 The FNLTC model is mandatory for the RRF: it supports Member States to
implement reforms and investments entirely based on the achievement of milestones 
and targets. It does not apply to individual operations, for which Member States may 
choose any suitable financing model in accordance  with their national rules. The 
achievement of milestones and targets is the only criterion for authorising a 
payment132. 

57 Before the first payment request is submitted, the Commission and the individual
Member States sign operational arrangements. These are documents which contain 
details of how the CID will be monitored, and what evidence the Commission expects 

130 Article 125(1) of the Financial Regulation. 

131 Special Report 24/2021, paragraph 90. 

132 Recital 18 and Articles 4(2) and 24(3) of the RRF Regulation. 

44 

to see to demonstrate that each milestone and target has been achieved 133. Before 
any RRF disbursement, the Commission must assess whether the Member State has 
satisfactorily fulfilled all milestones and targets linked to the specific payment 
request134. In addition, the Member State must provide assurance to the Commission 
that it has taken measures to protect the EU’s financial interests. This is however not 
checked by the Commission before it authorises the disbursement. It is only 
subsequently that the Commission carries out ex post verifications and audits on a 
sample basis in the Member States. 

58 Operational arrangements are drawn up by the Commission and the Member 
State concerned. The RRF Regulation provides only limited information about their 
content. The Commission prepared a template for operational arrangements, but 
issued it only in October 2021,  after most CIDs had been adopted. 

59 The Commission also intends to apply the RRF financing model to other areas of
the budget. It has already proposed replicating the main principle of the RRF financing 
in the new Social Climate Fund 135, intending to manage it using Member States’ plans, 
and where payments are expected to be made upon achievement of pre-agreed 
milestones and targets. Similarly, from 2023  onwards, the delivery model of the 
common agricultural policy will follow an approach based on outputs 136. 

Cohesion policy finances operations primarily based on the 
reimbursement of incurred costs 

60 For cohesion policy funds, the conditions for payment are fulfilment of the
relevant enabling conditions, and the submission of the assurance package on the 
regularity of the expenditure declared by the Member State 137. The Commission pays 
the amount requested by the Member State, provided it is below the EU  contribution 
approved for the respective priority under the programme and meets all eligibility 

133 Article 20(6) of the RRF Regulation. SWD(2022) 12 final, p. 34. 

134 Article 24(3) of the RRF Regulation. 

135 Proposal for a Regulation of the Parliament and of the Council establishing a Social Climate 

Fund, COM(2021) 568 final. 

136 Recital 28 and article 37 of Regulation (EU) 2021/2116 on the financing, management and 

monitoring of the common agricultural policy and repealing Regulation (EU) No 1306/2013. 
Commission  impact assessment, SWD(2018) 301, annex 4, section 2.3. 

137 Article 15(5), 91(2) and 98(1) of the CPR. 

45 

conditions for the expenditure declared. This also applies when programmes make use 
of SCOs or FNLTC models. 

61 We previously reported 138 that only a small part of 2014-2020  cohesion spending 
had been reimbursed using performance-based funding models, almost entirely 
through SCOs under ESF. So far, almost all ERDF and CF programmes were exclusively 
implemented based on the reimbursement of incurred costs. The FNLTC model was 
piloted for just one ERDF project in Austria. For the 2021-2027  period, SCOs have 
become mandatory for ERDF and ESF+ funded operations up to €200  000139. The 
Commission also expects that the FNLTC model will be used more than in previous 
programming periods. 

Different application of the FNLTC model for the two instruments 

62 During the 2021-2027  period, the FNLTC model is used differently under the RRF 
than it is under the cohesion policy. In particular, there are differences in how the 
terms “milestones” and “targets” are used, and in the way disbursements for achieving 
them are justified by underlying costs (see Box 10). 

138 Special report 24/2021, paragraphs 93, 101 and 127 and Box 8. 

139 Article 53(2) of the CPR. 

46 

Box 10 

Differences in applying the FNLTC model under the two instruments 

Disbursements under cohesion policy funds for the 2021-2027  period are: 

— 

related to individual intermediate steps towards expected results; 

—  based on milestones and targets set in the programmes, which both must be 

quantitative 140. Disbursements may also be linked to conditions, which may 
have qualitative aspects 141; 

—  determined on the basis of an ex ante cost estimate, and not on the basis of 

the actual costs incurred 142. 

Disbursements under the RRF are 143: 

—  paid in pre-defined instalments set out in the CID; 

—  dependent on the achievement of a group of milestones and targets set out 

in the CID, whereby milestones measure qualitative, and targets quantitative 
progress towards achievement of reforms and investments 144; 

— 

linked neither to the ex ante estimated costs for each measure, nor to actual 
costs incurred 145 (see paragraph 43). 

Under both instruments, it is up to the Member States to decide whether the 
model will also apply between the managing authority and the beneficiary, for 
cohesion policy funds, or the Member State and final recipient, for the RRF 146. 

140 Article 2(11) and 2(12) of the CPR. 

141 Article 51(a) of the CPR. 

142 Article 95(1) and Annex V – Appendix 2 of the CPR. 

143 Article 4(2) and recitals 18, 30, 51 and 52 of the RRF Regulation. 

144 Article 2(4) of the RRF Regulation. 

145 SWD(2021) 12 final, Part 1/2, p. 35. 

146 Recital 41 and Article 95(3) of the CPR. Recital 18 of the RRF Regulation. 

47 

The extent to which RRF financing is more performance-based than 
cohesion policy funds remains to be seen 

63 Performance budgeting is the systemic use of information about outputs, results 
and/or impacts to inform, influence and/or determine the allocation of public funds 147. 
The Organisation for Economic Co-operation and Development (OECD) defines three 
broad categories of performance budgeting148 (see Box 11). 

Box 11 

OECD classification on performance budgeting 

The OECD identifies three broad categories of performance budgeting systems: 

—  presentational performance budgeting, whereby performance information is 
produced and shown alongside funding allocations, but not necessarily used 
to take spending decisions; 

—  performance-informed budgeting, where such information explicitly 

influences the allocation of resources; and 

—  performance-based budgeting, in which funding is linked to outputs and 

outcomes. 

64 In a previous report149, we concluded that much has been done during the 2014-
2020  period to strengthen the performance orientation of cohesion policy, but that 
performance-based financing has not yet become a reality. According to a 2018 
Commission study, budget support and a more performance-based financing could 
constitute a simple and effective mechanism for those parts of the cohesion policy 
funds where outputs can clearly be attributed to the funding 150. 

147 OECD, Incentivising performance in public investment policies delivered at national and 

subnational levels: Managing across temporal and institutional horizons, 31 March 2017, 
pp. 8-9. 

148 OECD, Budgeting and performance in the European Union: A review by the OECD in the 
context of EU budget focused on results, OECD Journal on Budgeting, Volume 2017/1, 
section 1.2.1. 

149 Special report 24/2021, paragraph 107. 

150 Commission  (Ramboll, Ecorys, CSIL): “Feasibility study for a potential use of Budget Support 

to deliver ESI Funds”, 2018, pp. 3 to 7. 

 
 
                                                             
48 

65 The extent to which RRF financing is more performance-based than cohesion
policy funds remains to be seen. In any case, as some of the milestones and targets 
specified in the RRPs relate to inputs or outputs rather than outcomes 151, the RRF 
financing does not entirely meet the OECD criteria for performance-based budgeting 
systems.  

The RRF can allow faster disbursement of funds 

66 There are several other differences between the two instruments in the way that
payments are disbursed. Payments made so far also indicate that the Commission may 
disburse funds faster under the RRF than it can for cohesion policy programmes. This is 
mainly due to payment requests being based on pre-agreed instalments grouping the 
milestones and targets and differences in how these requests are assessed. This makes 
checks before disbursements less time consuming. Following a risk assessment, the 
Commission may however carry out more detailed verifications at a later stage, to 
address the risks to sound financial management 152 (see Figure 8). 

151 Special report 21/2022, paragraphs 87-89. 

152 2021 Annual reports, paragraph 10.12. 

49 

Figure 8 – Conditions for making payments 

CONDITIONS 

COHESION POLICY 

RRF 

PRE-FINANCING 

Member States receive 
pre-financing 

Yearly pre-financing of 0.5 % of 
the total allocation from 2021 to 
2026 for each fund 

One pre-financing payment 
of up to 13 % only for the 
RRP adopted by the Council 
in 2021 

PAYMENT REQUEST 

Sent to the Commission, 
accompanied by a 
management 
declaration 

ASSESSMENT 

Of the payment request 
by the Commission 

VALIDATION and 
PAYMENT 

To the Member States 

POTENTIAL LOSS 

Of funds not used 

Maximum of six payment 
requests per year per 
programme 
Requests based on the costs 
actually incurred unless use is 
made of SCOs and FNLTC  
National co-financing rates of at 
least 15 % – 60 % depending on 
the fund and the level of 
development of the supported 
region 

Assessment of the expenditure 
declared by the Member State in 
the assurance package 

The Commission validates the 
payment 

Gradual loss of the yearly 
committed funds for which a 
payment request is not made 
within three years (from 2021 to 
2026) or within two years (for 
2027) (decommitment 
procedure) 

Maximum of two payment 
requests per year per 
Member State 
Requests based on pre-
agreed instalment amounts 
grouping the milestones and 
targets 
Projects are 100 % financed 
by EU funds 

Assessment based on the 
satisfactory fulfilment of the 
milestones and targets 
The Commission adopts 
decision authorising 
disbursement taking into 
account Council’s opinion 

Funds not paid to the 
Member State by the end of 
2026 are lost 

Source: ECA, based on the CPR and the RRF Regulation. 

Higher pre-financing rates under the RRF compared to cohesion policy 

67 The level of pre-financing – in other words, the proportion of the allocation paid
to a Member State before formal payments linked to payment conditions are made – 
differs between the RRF and cohesion policy funds. The RRF pre-financing rate is 
significantly higher. For both instruments, pre-financing payments are cleared against 
future payments 153 (see Box 12). 

153 Article 90(5) of the CPR. Article 13(2) of the RRF Regulation. 

50 

Box 12 

Pre-financing 

Under cohesion policy funds, Member States are entitled to receive yearly pre-
financing instalments of 0.5  % of the total support from 2021  to 2026.  The 
Commission will clear the pre-financing for 2021  and 2022  annually, and for 2023 
to 2026  by the time of closure of the programmes at the latest 154. 

Under the RRF, a one-off pre-financing rate of up to 13  % of the grant and, if 
applicable, the loan, is available to Member States 155. In 2021,  all Member States 
except Ireland requested it. 

68 Under the RRF, the Commission may also recover any pre-financing if no tangible 
progress is made towards any relevant milestones and targets within the 18 months 
after the CID is adopted 156. However, by October 2022,  the meaning of “tangible 
progress” had still not been defined by the Commission. 

For both instruments, the management declarations are linked to their 
conditions for payment 

69 To proceed with a payment request, the Commission requires a management 
declaration for both instruments. This certifies that the information submitted is 
complete, accurate and reliable, and confirms that the underlying expenditure was 
used for the intended purpose, and complied with all the applicable rules: 

—  For cohesion policy funds, the managing authority submits one management 
declaration for each accounting year, irrespective of the number of payment 
applications 157. It certifies that the expenditure declared has been legal and 
regular, and provides information about the results of the interventions. 

—  As a prerequisite for disbursement under the RRF, each payment request must be 
accompanied by a management declaration to certify the achievement of the 
milestones and targets linked to the payment request. In addition, the Member 

154 Articles 90(2) and 90(5) of the CPR. 

155 Article 13(1) of the RRF Regulation. 

156 Article 24(9) of the RRF Regulation. 

157 Articles 74(1)(f) and 98(1)(b) and Annex XVIII of the CPR. 

 
 
                                                             
51 

State must also provide for each payment request a summary of the audits 
carried out, the weaknesses identified and any corrective actions taken 158. 

70 There are also differences in the frequency of payment requests. Member States
can submit up to two RRF payment requests to the Commission each year, compared 
to up to six for cohesion policy funds 159. 

No national or private co-financing required for the RRF 

71 The national co-financing rate of an instrument indicates the proportion of costs
not covered by EU funding. Traditionally, mandatory national or private co-financing 
guarantees a Member State’s or beneficiary’s commitment and ownership, and 
ensures value for money in EU-supported interventions. This has also been the general 
principle for cohesion policy funds. In contrast, the RRF requires no national or private 
co-financing (see Box 13). 

Box 13 

National co-financing 

The national co-financing rates for cohesion policy funds range from 15 % to 60 %, 
depending on the fund and the level of development of the supported region 160.  
In the past, there have been some instances where Member States received 100  % 
EU financing from cohesion policy funds because of exceptional circumstances, 
such as the financial crisis of 2008-2009161,  and for mitigating the effects of 
COVID-19 pandemic for the 2020-2021  accounting year162. 

There are no co-financing requirements for RRF and REACT-EU  funding163. 

158 Article 22(2)(c) of the RRF Regulation. 

159 Article 24(2) of the RRF Regulation. Article 91(1) of the CPR. 

160 Article 112 of the CPR. 

161 Article 77(2) of Council  Regulation (EC) 1083/2006. 

162 Article 2 of the Regulation (EU) 2020/558. 

163 Article 20(4) of the RRF Regulation. Article 92b(12) of the REACT-EU Regulation. 

52 

Under the RRF, decommitments only take place at the end of the 
eligibility period 

72 In cohesion policy programmes, funding that has not been spent within a certain
timeframe is automatically lost. This practice, called ‘decommitment’, is intended to 
encourage financial discipline in the implementation of programmes, as any lost 
funding reduces the potential impact of the policy. This gradual decommitment during 
the eligibility period applies only to cohesion policy funds, not to the RRF (see Box 14). 

Box 14 

Decommitment rules 

Cohesion policy funds are committed yearly at the start of the period to each 
Member State, and are lost if they are not used within three years (for 2021  to 
2026),  and within two years (for 2027) 164. 

Under the RRF, the commitment of financial support is frontloaded in the initial 
years of the eligibility period. The Commission must commit 70 % of the grants by 
the end of 2022,  and the remaining 30 %, including the loan component, by the 
end of 2023165.  Any funds not committed by these time limits, because CIDs were 
not adopted or because loans were not requested, will be lost. 

Under the RRF, once funds are committed, Member States do not run the risk of 
losing any unused funds during the implementation period of the RRF. All 
milestones and targets must be met by 31  August 2026166.  Funds not paid by the 
end of 2026  will be decommitted 167.  

164 Article 105 of the CPR. 

165 Recitals 46-47 and Articles 12 and 14 of the RRF Regulation. 

166 Articles 18(4)(i) and 20(5)(d) of the RRF Regulation. 

167 Article 24(1) of the RRF Regulation. 

53 

Monitoring and cost of 
implementation 

Different monitoring, reporting and evaluation provisions 

73 Monitoring, reporting and evaluation are necessary to ensure that funds
contribute to the objectives set, to identify issues so that they can be addressed in 
good time, and to gain an overview of progress at EU level. Different provisions apply 
to the two instruments (see Figure 9). 

Figure 9 – Monitoring, reporting and evaluation requirements 

REQUIREMENTS 

COHESION POLICY 

RRF 

MEMBER STATES 

Monitoring and 
reporting 
arrangements 

COMMISSION 

Monitoring and 
reporting 
arrangements 

Monitoring by programme, 
using indicators that are not 
linked to the payment 
requests 
Prescriptive rules on the role 
of the monitoring 
committee 

Submission to Commission: 
o Financial data: five times 

a year

o Performance data: twice 
a year, including data on 
common indicators
o Mid-term review (2025)
Annual performance review 
meeting 
Annual Management and 
Performance Report to the 
Parliament, in the context of 
the discharge procedure 
Display aggregated data on 
the Open Data platform 
Report on the outcome of 
the mid-term review to the 
Parliament and Council 
(2026) 

Monitoring at central level, using 
pre-agreed milestones and targets 
linked to the payment requests 
Member States can use their 
existing monitoring systems 

Submission to Commission: 
o Progress on milestones and 
targets, accompanying each 
payment request: maximum 
twice a year

o Two-yearly reports, updating 
data on common indicators

Monitoring embedded in the 
European Semester 
Analysis and appraisal of the data 
sent with the payment request 
Annual report on implementation 
addressed to the Parliament and 
the Council 
Posting of aggregated data on the 
RRF Scoreboard 

COMMISSION  

Evaluation 

During implementation, at 
the end of 2024 
Ex-post evaluation (2031) 

During implementation, in 
February 2024 
Ex-post evaluation (2028) 

Source: ECA, based on the CPR and the RRF Regulation. 

54 

RRF monitoring is linked to milestones and targets 

74 The Commission’s monitoring of the implementation of the RRPs differs
significantly between Member States. This is because milestones and targets, and the 
evidence needed to assess progress made towards them, are specific to each RRP. All 
Member States must nominate a central authority that provides consolidated 
reporting to the Commission and bears overall responsibility for monitoring the 
implementation of the RRP. 

75 There are various reporting requirements associated with the RRF.

—  Member States must report bi-annually to the Commission, in April and October, 
on the progress made with their RRP, specifically on the milestones and targets. 
This falls under the framework of the European Semester, April’s report being 
part of the National Reform Programme 168. 

— 

In the context of the European Semester, Member States must also report bi-
annually, in February and August, on the common indicators established for the 
RRF by a Delegated Act169. 

—  The Commission reports annually on the implementation of the RRF to the 
Parliament and the Council 170. The Commission’s first annual report was 
published in March  2022;  it concluded that implementation was underway 171. 

—  As planned, the Commission provided a one-off review report to the Parliament 

and the Council at the end of July 2022172,  according to which the implementation 
of reforms and investments of the Member States’ RRPs is underway 173. 

168 Article 27 of the RRF Regulation. 

169 Article 2(3) of the Commission  Delegated Regulation (EU) 2021/2106 on supplementing 
Regulation (EU) 2021/241 of the Parliament and of the Council establishing the RRF by 
setting out the common indicators and the detailed elements of the recovery and resilience 
scoreboard. 

170 Article 31 of the RRF Regulation. 

171 COM(2022) 75, p. 64. 

172 Article 16 of the RRF Regulation. 

173 Commission  review report on the implementation of the RRF, COM(2022) 383 final, p. 30. 

55 

—  The Parliament may invite the Commission to a “recovery and resilience dialogue” 

meeting every two months 174. By October 2022,  seven such meetings had taken 
place. 

76 In our recent report, we noted that the RRF milestones and targets are output-
(or even input-) rather than outcome-oriented. This limits the possibility of measuring 
the performance of measures and ultimately their impact on the EU policy objectives 
of the RRF 175. 

Performance disconnected from financial reporting for cohesion policy 

77 Performance-monitoring arrangements for cohesion policy funds are set out in 
the CPR. These arrangements are binding for all Member States and are disconnected 
from payments, both in terms of the timing and the process, except in the case of 
output-based SCOs and FNLTC: 

—  The monitoring committee of each programme meets at least once a year and 

examines, among other things, progress made in implementing the programme 
and achieving its milestones and targets 176. 

—  The Commission examines performance with each Member State at an annual 

performance review meeting177. 

—  Each programme will undergo a mid-term review in 2025  to determine allocation 

of half of the funding for 2026  and 2027,  examining, inter alia, progress in 
achieving the milestones taking into account major difficulties encountered in the 
implementation 178.  

—  Progress in achieving programme objectives is also examined based on the 

final performance report179. 

174 Article 26 of the RRF Regulation. 

175 Special report 21/2022, paragraphs 88-89. 

176 Articles 38(1), 38(3) and 40(1) of the CPR. 

177 Article 41(1) of the CPR. 

178 Articles 18 and 86(1) of the CPR. 

179 Article 43 of the CPR. 

56 

78 Member States must report data on cohesion policy programme implementation 
to the Commission more frequently than they do for the RRF; they must electronically 
transmit financial implementation data five times a year, and performance data twice 
a year180. The CPR does not require the Commission to report annually to the 
Parliament and the Council, but information is included in the programme statements 
attached to the draft budget181 and in Annual Management and Performance Report 
as part of the discharge procedure 182. 

Efforts were made to increase transparency of monitoring data, but 
other issues remain 

Similar approaches  to ensure transparency  in the use of EU funding 

79 The Commission has adopted similar approaches to both instruments to ensure 
transparency in the use of EU  funding and to demonstrate progress in implementation. 
In the case of the RRF, the Commission has set up an online platform called the 
Recovery and Resilience Scoreboard, which is publicly accessible 183. It fulfils a function 
similar to that of the open data platform under the cohesion policy funds (see Box 15). 

180 Article 42(1) of the CPR. 

181 Article 41(3)(h) of the Financial Regulation.  

182 Article 318 TFEU. 

183 Commission  Delegated Regulation (EU) 2021/2106. 

 
 
                                                             
57 

Box 15 

Online public platforms for performance data 

The RRF’s Recovery and Resilience Scoreboard 184 gives an overview of progress 
made in programme implementation. It includes data on the achievement of 
milestones and targets, committed and disbursed funds, the trend in common 
indicators within the structure of the six pillars, and thematic analyses 185. The 
Commission is legally required to update the scoreboard at least twice a year 
using the data submitted by Member States in the context of the European 
Semester186. In fact, it is updated more frequently than this: it provides live data 
on payments and fulfilled milestones and targets. 

The cohesion open data platform is a publicly available website that visualises 
data on the financing and achievements of cohesion policy funds 187. For the  
2014-2020  period, it presents the latest data available for the programmes with 
the planned amounts, daily updates on EU payments, annual information on the 
achievement of common indicators, and thematic analyses. Since October 2022, 
it displays planned investment and indicator targets from adopted 2021-2027 
programmes. 

80 The Commission considers that “Member States are the beneficiaries of the RRF 
funds, which, once disbursed, enter the national budget”188. However, the use of the 
RRF funds must still comply with all applicable EU and national rules. Member States as 
the beneficiaries and borrowers of the funds, together with the Commission, must 
take appropriate measures to ensure that. Member States must also ensure that final 
recipients acknowledge that they have received EU funding189. However, not every 
measure contributing to investments and reforms supported under the RRF is specified 
in detail in the RRPs or in the CIDs. This carries the risk that EU  financial support 
provided through the RRF may not be visible to recipients and citizens. 

184 Recovery and Resilience Scoreboard. 

185 Article 1 of Commission  Delegated Regulation (EU) 2021/2106. 

186 Articles 27 and 30 of the RRF Regulation. 

187 Cohesion  Open Data Platform. 

188 COM(2022) 75, p. 60. 

189 Article 34(2) of the RRF Regulation. 

 
 
                                                             
58 

Limitations of the monitoring data 

81 Monitoring data is used to measure the progress and achievements of EU 
interventions. The most important sources of data are the common output and result 
indicators together with their baselines, milestones and targets, as applicable (for the 
cohesion policy programmes), and the milestones and targets (for the RRPs). We have 
previously commented on the large number of programme-specific indicators 190, 
which can neither be aggregated to measure performance at EU level nor be used for 
comparisons between and across different cohesion policy programmes and RRPs 191. 
The same applies to the milestones and targets for the RRF. There is only a limited 
number of common indicators to measure the overall performance of both 
instruments at EU level (see Box 16). 

190 Special report 24/2021, paragraph 42. Briefing paper 2018: “Future of EU finances: 

reforming how the EU budget operates”, February 2018, paragraph 38. Special report 
02/2017: “The Commission’s  negotiation of 2014-2020 Partnership Agreements and 
programmes in Cohesion: spending more targeted on Europe 2020 priorities, but 
increasingly complex arrangements to measure performance”, paragraphs 106-109, 113-
115, 131, 147. 

191 Briefing paper 2018: “Simplification in post-2020 delivery of Cohesion  Policy”, May 2018, 

paragraph 59. 

 
 
                                                             
59 

Box 16 

Monitoring data 

Programme- and RRP-specific indicators: 

—  Over the 2014-2020  period, more than 22 000  programme-specific indicators 
were set. The number of programme-specific indicators for the 2021-2027 
period will be known when all programmes are adopted. 

—  A large number of milestones and targets were created for the RRPs by the 

Council so far: 5 889 in total, 2 166 for reforms and 3 723 for investments 192. 
In some cases, these are complemented by intermediary steps, further 
increasing their total number193. 

Common indicators : 

—  The fund-specific regulations set 87 common indicators for the 2014-2020 
period. Member States selected the ones that were relevant to their 
cohesion policy programmes, and set targets to be achieved by the end of the 
period. The number of common indicators for the 2021-2027  period has 
increased to 234.  All programmes will report on all common indicators 
regardless of whether targets have been set for them or not. 

—  The Commission was required to adopt a delegated act establishing common 
indicators to show the overall results of the RRF 194. The Regulation defined 14 
common indicators, of which the majority were the same as those in the 
cohesion fund-specific regulations 195. However, they do not have associated 
targets to be achieved, and are not systematically linked to each RRP. They 
therefore give an overview of the RRF’s performance. 

192 Data from the RRF scoreboard as at October 2022. 

193 Commission  Staff Working Document, “Identifying Europe’s recovery needs”, SWD(2020) 
98 final, p. 36. Out of the selected Member States, intermediary steps were used in Spain 
and Romania. 

194 Article 29(4) of the RRF Regulation. 

195 Annex to Commission  Delegated Regulation (EU) 2021/2106. Annexes I and II of the 

ERDF/CF Regulation. Annex I of the ESF+ Regulation. 

 
 
 
                                                             
60 

82 In the past, we have highlighted the difficulty in striking a good balance between 
the need to obtain meaningful monitoring data and the need to produce it at a 
reasonable cost196. Collecting, storing and reporting data for these indicators 
contributed significantly to administrative costs. Nevertheless, for the RRF, each 
milestone or target measures progress towards achieving a specific reform or 
completing an investment, and is used as a basis for disbursements. 

83 DG ECFIN checks the monitoring data for the RRF, and DGs REGIO and EMPL for
the cohesion policy funds. Since an operation can be financed by both instruments, 
and since there are no checks to ensure that monitoring data is not disclosed twice, 
there is a risk that achievements may be doubly reported. 

Ex-post evaluations come too late to inform the legislative proposals for 
the next period for both instruments 

84 The Commission must carry out evaluations of both instruments in the course of
implementation in 2024, and ex-post evaluations two years after the end of the 
eligibility periods to assess the long-term impact 197. Member States must also carry 
out evaluations assessing one or more of the criteria set out in the Better Regulation 
Guidelines 198 (or other relevant criteria) and the impact of each programme 199. 

85 The ex-post evaluations of both instruments will be available after the
Commission’s legislative proposals for the post-2027  cohesion policy framework have 
been drawn up. This means that only the evaluations and reviews carried out in the 
course of the implementation can inform the legislative proposals for the next 
period 200. However, as we have pointed out previously 201, the Regulations do not 
require the Commission to coordinate the evaluations during implementation for the 
RRF and the mid-term review of cohesion programmes planned in 2024  and 2025 

196 Special report 02/2017, paragraphs 131-132 and 154. Briefing paper 2019: “Delivering 

performance in Cohesion”, June 2019, paragraph 49. 

197 Article 32 of the RRF Regulation. Article 45(2) of the CPR. 

198 SWD(2021) 305, p. 23. 

199 Article 44(1) and 44(2) of the CPR. 

200 Briefing paper 2019: “Delivering performance in Cohesion”, June 2019, paragraphs 107 and 

109. 

201 Special report 24/2021, paragraphs 81 and 124, and recommendation 2(b). 

61 

respectively, despite the lessons that could be learnt from an integrated approach 
covering both instruments. 

The cost of implementation will be difficult to assess for both 
instruments 

86 The cost of implementing an instrument includes various administrative
expenditure (see Box 17). 

Box 17 

Costs of implementing an instrument 

The activities involved in preparing and implementing an instrument generate 
administrative costs at: 

—  Commission level: expenditure connected with programme approval and the 
supervision and verification of programme implementation, such as staff 
costs, studies, evaluations, analyses, dissemination of information actions 
and consultancy; 

—  Member State level: expenditure for programme preparation and 

management, monitoring, evaluation, information and communication, and 
control and audit activities, such as staff costs, consultancy, and IT costs. 

87 Calculating the cost of implementing the cohesion policy funds is not easy. The
technical assistance provided to support Member States is a cost reimbursed from the 
EU budget, so it is a known amount. However, there is little or no information available 
on other administrative costs. The Commission carries out studies to estimate these 
global administrative costs; the last one was published in 2018202.  In the past, we have 
found that cohesion policy is implemented at a comparatively low cost to other 
European and international programmes. However, we also noted that the data 
underlying these studies was incoherent, inconsistent and incomplete 203. 

202 Commission  (Spatial Foresight and t33), “New assessment of ESIF administrative costs and 

burden”, 2018. 

203 Special report 07/2020: “Implementing Cohesion  policy: comparatively low costs, but 
insufficient information to assess simplification savings”, paragraphs 41 and 67. 

88 Similarly, it will be difficult to estimate the cost of implementing the RRF, not
least because the RRF Regulation does not require administrative costs to be reported 
to the Commission. 

62 

63 

Control and audit 

Different control and audit provisions 

89 The design of the control and audit framework must ensure that EU  funds are
implemented in line with the principles of sound financial management 204, are legal 
and regular205 and that the EU’s financial interest is protected 206. It must be adapted to 
the risks identified for the form of EU financial support specific to each instrument. 

90 For both cases, Member States implement a control and audit framework
designed to provide the Commission with assurance that it may release payments, 
while the Commission conducts additional checks to verify the reliability of the 
framework in the context of preparing its annual activity reports and the declaration of 
assurance contained therein for the discharge procedure (see Figure 10). 

204 Article 33 of the Financial Regulation. 

205 Article 36(2) of the Financial Regulation. 

206 Article 135 of the Financial Regulation. 

64 

Figure 10 – Control and audit 

BY TYPE 

COHESION POLICY 

RRF 

INTERNAL CONTROL AND AUDIT 

BEFORE PAYMENT 

Member States provide assurance on 
the set-up of their management and 
control systems 

Member States describe their 
internal control systems in their 
RRP’s 

The Commission assesses Member 
States’ control systems when 
approving partnership agreements and 
programmes 

The Commission assesses 
Member States’ control systems 
and sets further milestones 
where necessary 

Member State level 
o Legality and regularity of 

payments is based on the accuracy 
and veracity of expenditure, and 
compliance with the applicable EU 
and national rules

o Managing authorities carry out 
first-level checks on operations 
and exclude irregular expenditure
declared by beneficiaries
o Audit authorities provide 
assurance on expenditure 
declared, management and 
control systems and the accounts

The Commission carries out control 
and audit activities, including systems 
audits and audits on a sample of 
operations 

The Commission:  
o Carries out compliance audits in 
respect of the legality and 
regularity of expenditure declared, 
and system audits

o Suspends payments associated 
with expenditure affected by an 
irregularity or serious deficiency

Member State level 
o Legality and regularity of 
payments in based on 
achievement of milestones 
and targets.

o Compliance with the 

applicable EU and national 
rules to protect the EU 
financial interests

The Commission assesses 
whether milestones and targets 
have been satisfactorily fulfilled, 
failing which payment is 
suspended in part or in full 

The Commission carries out:  
o ex post audits of milestones 
and targets, reported by the 
Member States following a 
risk assessment 
o system audits of the

monitoring data collection 
systems (before or after 
payment)

o system audits of measures 
to protect the EU financial 
interests, and ad hoc audits 
where serious irregularities 
are suspected 

AT PAYMENT 

AFTER PAYMENT 

EXTERNAL AUDIT 

By the ECA 

By the ECA 

Source: ECA, based on the CPR and the RRF Regulation. 

65 

Cohesion policy checks mainly focus on the regularity of expenditure 
declared 

91 In cohesion policy, control and audit focus mainly on the eligibility of costs
incurred by beneficiaries and declared by managing authorities for each of the 
programmes. The Member States have specific responsibilities in connection with the 
checks to be carried out 207 (see Box 18). 

Box 18 

The control and audit framework for cohesion policy funds at 
Member State level 

The programme authorities in the Member States must fulfil detailed 
requirements. 

—  Managing authorities, when expenditure is reimbursed based on real costs, 
must check that expenditure complies with the applicable legislation, 
including public procurement and state aid rules, and the conditions for 
support of the programme 208. For SCOs and the FNLTC model, management 
verifications are exclusively intended to verify that the conditions for 
reimbursement by the Commission have been satisfied 209. Managing 
authorities should also have data on the beneficial owners of the recipients 
of the funds 210, and publish the list of operations selected, including the 
beneficiaries211. 

—  Audit authorities must provide the Commission with an annual control report 
and an audit opinion that provides assurance as to the legality and regularity 
of declared expenditure, the effective functioning of the management and 
control systems and the completeness, accuracy and veracity of the 
accounts 212. 

92 The Commission’s assurance for making a payment comes mainly through checks
on the regularity of the expenditure declared performed by the national authorities as 

207 Article 63(1) of the Financial Regulation. Recital 55 of the CPR. 

208 Articles 74(1)(a) and 95(3) and recital 34 of the CPR. 

209 Articles 94(3) and 95(3) of the CPR. 

210 Article 69(2) of the CPR. 

211 Article 49(3) of the CPR. 

212 Article 77(3) and recital 63 of the CPR. 

66 

well as by the system audits carried out by them. The Regulation is also specific about 
the audit work required at Member State level, including the establishment of a clear 
audit trail, templates, and an audit timetable 213. The Commission plays a supervisory 
role and, through its own audit work, satisfies itself that the systems set up by 
Member States function effectively and efficiently 214. 

93 We have previously highlighted weaknesses in the work of audit authorities in the
Member States and the Commission’s supervision thereof 215, affecting a significant 
share of the assurance packages 216. Recently, we also noted a need for further 
clarification of the arrangements for providing assurance to the Commission when the 
FNLTC model is applied 217. 

RRF checks focus on the satisfactory fulfilment of milestones and targets 

94 The control and audit framework for the RRF focuses on the satisfactory
fulfilment of milestones and targets. It also reflects Member States’ responsibility for 
ensuring that the instrument is implemented in compliance with EU and national rules 
(see Box 19). 

213 Articles 70, and 77 to 82 and Annexes XIII, XIX to XXII of the CPR. 

214 Article 70(1) of the CPR. 

215 Special report 26/2021: “Regularity of spending in EU Cohesion policy: Commission 

discloses  annually a minimum estimated level of error that is not final”, paragraphs 26, 29, 
39 and 84. 2020 Annual reports, paragraph 5.38. 2019 Annual reports, paragraph 5.39. 

216 2021 Annual reports, paragraphs 5.41-5.42.  

217 Special report 24/2021, paragraph 128 and recommendation 4. 

67 

Box 19 

The control and audit framework under the RRF at Member State 
level 

—  Member States are required to set up an internal control system to ensure 
that the use of RRF funds complies with the applicable EU and national law. 
They may use their own national budget management system to do this 218. 
They must also keep track of data on RRF final recipients and a list of funded 
measures 219, even if this information is not made publicly available. This 
information can be requested for audit and control purposes by the 
Commission, OLAF, EPPO and the ECA 220. 

—  Audit is also part of Member States’ control responsibilities. Member States 
must state in their RRPs which national body is responsible for audit. 
A summary of the audits carried out, including weaknesses and corrective 
actions taken, must accompany each payment request 221. 

95 In the RRP approval process, the Commission assessed the control and audit
framework described by Member States in their RRPs 222. This assessment does not 
cover risks associated with non-compliance with public procurement and state aid 
rules. All 26 frameworks of the RRPs adopted by October 2022  were assessed as 
adequate. In 19 cases the Commission agreed spe cific milestones with the 
Member State to remedy deficiencies identified before the first disbursement is 
made 223, excluding the pre-financing. 

96 The Commission had also shared a self-assessment checklist on control systems 
with the Member States in March 2021,  before any RRP was submitted. However, 
some aspects of the Commission’s audit methodology for the RRF, such as the audit 
trail and sampling methods, were finalised only after t he RRPs were adopted. The 
Commission finalised its audit methodology as late as December 2021,  after the first 
payment requests were submitted. This may have created uncertainty regarding 

218 Article 22(1) of the RRF Regulation. 

219 Article 22(2)(d) of the RRF Regulation. 

220 Article 22(2)(e) of the RRF Regulation. 

221 Article 22(2)(c)(ii)  of the RRF Regulation. 

222 Article 19(3)(j), Article 24(3), Recital 18 and criterion 2.10 in Annex V of the RRF Regulation. 

223 SWD(2021) 12, Part 1/2, p. 48. COM(2022) 75, p. 61. 

68 

responsibilities and the scope of controls and audits, which may in turn have led to 
inconsistent implementation across the Member States. 

97 The Commission’s assurance for payments comes primarily from its desk checks
on the satisfactory fulfilment of milestones and targets for e ach installment. During 
the implementation period, the Commission also carries out system audits of the 
monitoring da ta collection system in the Member States. These  audits maybe 
carried out before or after the disbursements are made. In addition, the Commission 
may also carry out ex-post audits on the reporting of milestones and targets in the 
Member States; these audits are only carried after the disbursement has been made. 
We are currently working on an audit on the design of the RRF audit and control 
framework. We plan to publish our report in 2023. 

The method for applying suspensions or making partial payments for the 
non-attainment of milestones and targets under the RRF awaits 
clarification 

98 In cohesion policy, as we  previously reported, there are no preventive  measures
or financial corrections for underachievement of results 224. This is also the case for the 
2021-2027  period. However, the Commission must carry  out an annual performance 
review meeting for ea ch programme together with t he Member State to monitor 
progress towards the agreed milestones and targets. Where  there are significant 
deviations that could affect the implementation of the programme, the Member State 
must adopt remedial measures and inform the Commission within three months 225. 

99 This is different for the RRF where the Commission must suspend all o r part of a 
payment if it considers that one or more milestones and targets have not been 
satisfactorily achieved. Once such a suspension is made, unless the Member State 
remedies the situation within six months, the Commission must reduce the amount of 
financial support 226. However, the Commission s till needs to clarify the m ethod to 

224 Special report 04/2017: “Protecting the EU budget from irregular spending: The 

Commission  made increasing use of preventive measures and financial corrections in 
Cohesion  during the 2007-2013 period”, paragraph 25. Special report No 36/2016: “An 
assessment of the arrangements for closure of the 2007-2013 cohesion and rural 
development programmes”, paragraph 48. 

225 Article 41 of the CPR. 

226 Articles 24(6) and 24(8) of the RRF Regulation. 

69 

determine the share of a payment that is to be suspended or reduced for the non-
attainment of milestones and targets, as we have also highlighted in our 2021  annual 
report227. The absence of a clearly set out  method carries the  risk that partial 
payments may not be consistently applied to Member States. 

The application of the measures to protect the EU’s financial 
interests for the RRF needs to be further clarified 

Payment retentions to protect the EU budget are needed for the 
cohesion policy funds 

100 Payment retentions protect the EU budget from the financial consequences of
errors in Member States’ cost declarations which may be detected after disbursement. 
In cohesion policy, the Commission applies such retentions to each interim payment. 
For the 2021-2027  period, the percentage decreased to 5 % 228, compared to 10 % in 
the previous period. In the past we have recommended a legislative r eview to ensure 
that the retained payment is adequately p rotected before it is released 229. 

101 No such mechanism is in place for the RRF, as the Commission agrees on the
conditions for disbursement in advance when it negotiates the RRP, and only assesses 
whether the relevant m ilestones and targets have been met before authorising 
payment.  

For cohesion policy funds, the Commission can apply payment 
suspensions and financial corrections to protect the EU’s financial 
interests 

102 Measures to protect the EU budget aim to ensure that only regular spending is
financed. Primarily, it is the Member States’ responsibility to detect, correct and 
prevent irregularities 230. If this is not adequately done, the Commission may use 
a series of additional measures to protect the EU budget. 

227 2021 Annual reports, paragraph 10.28 and recommendation 10.2. 

228 Article 93(2) of the CPR. Article 130(1) of the 2014-2020 CPR. 

229 Special report 26/2021, paragraph 77 and recommendation 1. 

230 Article 103 of the CPR.  

70 

103 For cohesion policy funds, the Commission can suspend payments until
Member States have taken the necessary corrective actions and, if necessary, impose 
financial corrections (see Box 20). 

Box 20 

Use of financial corrections and suspensions to protect the EU 
budget under cohesion policy 

Under cohesion policy, financial corrections are imposed when an irregularity has 
been declared or accepted by the Member State. The Commission may impose 
them in the case of serious deficiencies in the Member State’s management and 
control systems which have led to systemic errors or for individual irregularities231. 
Depending of the seriousness of the deficiencies, the Commission may impose a 
flat-rate correction of 5 %, 10  %, 25 % or even 100  %232. However, this does not 
necessarily lead to a reduction of the amount of support made available to a 
programme, as other regular expenditure can be claimed for other measures 233. 
Whether this happens in practice, however, depends on the Member States’ 
ability to declare additional expenditure. The competent authority in the Member 
State must recover any irregular amounts paid to beneficiaries234. 

Net financial corrections in cohesion policy are used when an irregularity was not 
adequately corrected by the Member State. Only a net financial correction implies 
the loss of financial support for the Member State by the EU budget 235. 

Finally, the Commission can also apply payment interruptions and suspensions as 
preventive measures 236. These result in a deferral of payments from the EU 
budget, putting additional pressure on the Member States to take the necessary 
corrective action 237. 

231 Article 104(1) of the CPR. 

232 Article 104(1) and Annex XXV of the CPR. 

233 Article 104(4) of the CPR. 

234 Article 69 of the CPR. 

235 Article 104(1) and 104(4) of the CPR. 

236 Articles 96 and 97 of the CPR. 

237 Special report 04/2017, paragraphs 14-17 and Box 1. 

71 

104 In the past, for cohesion policy funds, we have noted that the Commission 
made increasing use of preventive measures and financial corrections in the 2007-
2013  period. We have also noted that the regulatory provisions of the 2014-2020 
period significantly increased the Commission’s ability to protect the EU budget from 
irregular expenditure238. Until 2021,  as we have reported, the Commission has not 
imposed any net financial corrections on Member States for the 2014-2020  period 239. 

For the RRF the Commission relies more on the effectiveness of national 
systems to protect the EU’s financial interests 

105 For the RRF, the Commission also has the power to proportionately reduce the
financial support allocate d to Member States and to recover any amount due or to ask 
for early repayment of loans. The Commission can do so for serious i rregularities 
related to fraud, corruption, conflict of interest or a serious breach of obligations, as 
well as cases of incorrect information regarding the fulfilment of milestones and 
targets being provided by Member States 240.   

106 To recover or ask early repayment of loans, the Commission must establish that
irregularities or serious breaches of obligations have occurred. If a deficiency i n the 
control system of a Member State for the RRF leads to a serious breach of the 
financing agreement, the Commission may reduce the EU financial support and 
recover 5 %, 10 %, 25  % or even 100  % of the financial contribution allocated to the 
Member State, or in case of a loan ask for early repayment 241. However, unlike for 
cohesion policy funds, there is n o common control f ramework as Member States use  
their national systems for implementing the RRF. In the absence of further criteria and 
guidance on the application of recoveries by the Commission, there remains a risk that 
these flat rates may not be consistently applied to Member States. 

107 Regardless of the management mode, the Commission is ultimately responsible 
for implementing the EU budget 242. In particular, the Commission must ensure that the 
financial interests of EU are effe ctively protected; to do so, it must obtain sufficient 

238 Special report 04/2017, paragraphs 141-143 and 149. 

239 2021 Annual reports, paragraph 1.44. 2020 Annual reports, paragraph 1.43. 

240 Article 22(5) of the RRF Regulation. 

241 Article 22(5) of the RRF Regulation. Article 19 of the financing agreements. 

242 2021 Annual reports, paragraph 1.33. 

72 

assurance from Member States that they implement the RRF in compliance with the 
EU and national law. As compared to cohesion policy funds, it also relies to a higher 
degree on the  effectiveness of national systems to prevent, dete ct and correct 
irregularities and the timely information thereof reported by the Member States. 
Nevertheless, the Commission considers that it can authorise disbursements as long as 
milestones and targets are achieved 243 , even if  it may be aware of irregularities in 
using the funds detected at Member State level.  

Member States can use different systems to report irregularities 
detected for cohesion policy funds and the RRF 

108 The protection of the EU’s financial interests also involves measures taken to
counter any illegal activities that may affect the EU budget 244. This requires a system to 
be in place to counter fraud, corruption and conflicts of interests at Member State 
level, and involves checks being performed by the Commission as laid down in the RRF 
audit strategy.  

109 For cohesion policy funds, Member States must report irregularities they detect
in the Commission’s Irregularity Management System (IMS)245, and expenditure under 
examination is excluded from the accounts 246. The required information includes the 
identity of the beneficiaries involved. For the RRF, Member States are not legally 
obliged to report irregularities in the IMS, but may do so on a voluntary basis. Instead, 
all Member States must report suspected fraud cases in their management declaration 
that accompanies the payment request. 

Potential for using integrated data mining and risk-scoring tools not yet 
fully exploited by cohesion policy and the RRF 

110 Nearly 10  years ago, the Commission created a single data-mining and risk-
scoring tool, ‘Arachne’, for uploading details of risky economic operators 247. The 
Commission recommended that Member States use Arachne in connection with both 

243 Article 24 of the RRF Regulation. 

244 Article 325 TFEU. 

245 Article 69(12) of the CPR. 

246 Article 98(6) and Annex XVIII of the CPR. 

247 Article 22(4) of the RRF Regulation and recital 72 of the CPR. 

73 

instruments. Its usefulness, however, depends on the data uploaded by Member 
States, and so far not all of them use it248. So far, 19  Member States have committed 
to using Arachne for the RRF. By October 2022,  it was not yet clear how many Member 
States had committed to using it for the 2021-2027  cohesion policy programmes. 

111 In the past, we have highlighted Arachne’s potential as an effective fraud 
prevention tool 249. However, recently we found that the utility of Arachne was limited 
by its restricted scope of application in the context of shared management 250. For 
example the IMS is not linked to Arachne. The revision of the Financial Regulation will 
provide an opportunity to make the use of integrated data mining and risk-scoring 
tools mandatory for all methods of EU budget implementation in the post-2027  period. 

248 Annual Activity Report 2020 – Directorate-General Regional and Urban Policy, p. 55. Special 

report 01/2019: ”Fighting fraud in EU spending: action needed”, paragraph 86. 

249 Special report 01/2019, paragraphs 85-88 and recommendation 3.3. Special report 

10/2015: ”Efforts to address problems with public procurement in EU cohesion expenditure 
should  be intensified”, paragraphs 90-94 and recommendation 6. 

250 Special report 11/2022: ”Protecting the EU budget – Better use of blacklisting needed”, 

paragraph 85. 

 
 
 
 
                                                             
74 

Closing remarks 

112 Our review illustrates that the Recovery and Resilience Facility (RRF) and the 
cohesion policy funds have considerable similarities. At the same time, both 
instruments differ in many respects due to their different purposes. Cohesion policy is 
the EU's main long-term investment policy to promote the economic, social and 
territorial development of Member States and regions, and the RRF is a temporary 
crisis-response tool to mitigate the impact of the COVID-19 pandemic on Member 
States’ economies and to enhance the resilience of the EU  and its Member States 
against future shocks. 

113 Both the 2021-2027  cohesion policy funds and the RRF are still in their early 
stages of implementation. Deploying the RRF simultaneously with the cohesion policy 
funds will provide additional insights in how the differences in the regulatory 
framework affect implementation and results.  

This review was adopted by the Court of Auditors in Luxembourg at its meeting of 
8 December 2022. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
75 

Annexes 

Annex I – Previous ECA reports 

Special reports 

—  Special report 10/2015:  “Efforts to address problems with public procurement in 

EU cohesion expenditure should be intensified” 

—  Special report 36/2016:  “An assessment of the arrangements for closure of the 

2007-2013  cohesion and rural development programmes” 

—  Special report 02/2017:  “The Commission’s negotiation of 2014-2020  Partnership 
Agreements and programmes in Cohesion: spending more targeted on Europe 
2020  priorities, but increasingly complex arrangements to measure performance” 

—  Special report 04/2017:  “Protecting the EU budget from irregular spending: The 

Commission made increasing use of preventive measures and financial 
corrections in Cohesion during the 2007-2013  period” 

—  Special report 17/2018:  “Commission’s and Member States’ actions in the last 

years of the 2007-2013  programmes tackled low absorption but had insufficient 
focus on results” 

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

—  Special report 07/2020:  “Implementing Cohesion policy: comparatively low costs, 

but insufficient information to assess simplification savings” 

—  Special report 10/2020:  “EU  transport infrastructures: more speed needed in 

megaproject implementation to deliver network effects on time” 

—  Special report 16/2020:  “The European Semester – Country Specific 

Recommendations address important issues but need better implementation” 

—  Special report 14/2021:  “Interreg cooperation: The potential of the European 

Union’s cross-border regions has not yet been fully unlocked” 

—  Special report 24/2021:  “Performance-based financing in Cohesion policy: worthy 

ambitions, but obstacles remained in the 2014-2020  period” 

 
 
76 

—  Special report 26/2021:  “Regularity of spending in EU Cohesion policy: 

Commission discloses annually a minimum estimated level of error that is not 
final” 

—  Special report 11/2022:  “Protecting the EU budget – Better use of blacklisting 

needed” 

—  Special report 21/2022:  “The Commission’s assessment of national recovery and 

resilience plans: overall appropriate but implementation risks remain” 

Reviews and briefing papers 

—  Briefing paper 2018:  “Future of EU  finances: reforming how the EU budget 

operates”, February 2018 

—  Briefing paper 2018:  “Simplification in post-2020  delivery of Cohesion Policy”, 

May 2018 

—  Rapid case review 2019:  “Allocation of cohesion policy funding to Member States 

for 2021-2027”,  March  2019 

—  Rapid case review 2019:  “Outstanding commitments in the EU budget – A closer 

look”, April 2019 

—  Briefing paper 2019:  “Delivering performance in Cohesion”, June 2019 

—  Review 05/2021:  “The EU framework for large transport infrastructure projects: 

an international comparison” 

Annual reports 

—  2016  Annual report, chapter 2 

—  2019  Annual reports, chapter 5 

—  2020  Annual reports, chapter 2 

—  2021  Annual reports, chapters 1, 2 and 10 

Opinions 

—  Opinion No 06/2020  concerning the proposal for a regulation of the Parliament 

and of the Council establishing a Recovery and Resilience Facility 

 
 
77 

—  Opinion No 04/2022  concerning the proposal for a Regulation of the Parliament 

and of the Council amending Regulation (EU) 2021/241  as regards REPowerEU 
chapters in recovery and resilience plans and amending Regulation (EU) 
2021/1060,  Regulation (EU) 2021/2115,  Directive 2003/87/EC  and Decision (EU) 
2015/1814  [2022/0164  (COD)] 

 
 
 
78 

Annex II – The planned contribution of the RRF to the six pillars broken down by Member State 

Pillar 1 
Green transition 

Pillar 2 
Digital 
transformation 

Pillar 3 
Smart, sustainable 
and inclusive 
growth and jobs 

Pillar 4 
Social and 
territorial 
cohesion 

Belgium 
Bulgaria 
Czechia 
Denmark 
Germany 
Estonia 
Ireland 
Greece 
Spain 
France 
Croatia 
Italy 
Cyprus 
Latvia 
Lithuania 
Luxembourg 
Hungary 
Malta 
Netherlands 
Austria 

64  % 
64  % 
66  % 
59  % 
47  % 
42  % 
56  % 
44  % 
50  % 
53  % 
76  % 
46  % 
52  % 
39  % 
44  % 
65  % 

55  % 
71  % 
52  % 

30  % 
33  % 
24  % 
24  % 
53  % 
22  % 
32  % 
23  % 
30  % 
21  % 
26  % 
30  % 
25  % 
22  % 
36  % 
33  % 

23  % 
26  % 
41  % 

32  % 
47  % 
40  % 
86  % 
51  % 
71  % 
40  % 
86  % 
42  % 
53  % 
45  % 
48  % 
65  % 
46  % 
53  % 
43  % 

28  % 
52  % 
44  % 

48  % 
27  % 
33  % 
18  % 
11  % 
21  % 
49  % 
29  % 
56  % 
28  % 
26  % 
50  % 
25  % 
54  % 
25  % 
46  % 

41  % 
37  % 
45  % 

Pillar 5 
Health, economic, 
social and 
institutional 
resilience 
11  % 
18  % 
23  % 
13  % 
29  % 
43  % 
10  % 
12  % 
14  % 
21  % 
15  % 
15  % 
19  % 
26  % 
25  % 
13  % 

34  % 
7 % 
9 % 

Pillar 6 
Policies for the 
next generation 

15  % 
11  % 
14  % 

9 % 
1 % 
13  % 
5 % 
8 % 
23  % 
12  % 
12  % 
13  % 
13  % 
18  % 

19  % 
7 % 
9 % 

Pillar 1 
Green transition 

Pillar 2 
Digital 
transformation 

Pillar 3 
Smart, sustainable 
and inclusive 
growth and jobs 

Pillar 4 
Social and 
territorial 
cohesion 

Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Finland 
Sweden 
EU average 

56  % 
55  % 
57  % 
57  % 
51  % 
54  % 
56  % 
55  % 

23  % 
23  % 
21  % 
23  % 
21  % 
35  % 
29  % 
28  % 

24  % 
48  % 
42  % 
33  % 
48  % 
50  % 
18  % 
47  % 

68  % 
47  % 
46  % 
36  % 
24  % 
39  % 
67  % 
38  % 

79 

Pillar 6 
Policies for the 
next generation 

9 % 
8 % 
13  % 
15  % 
17  % 
1 % 
15  % 
12  % 

Pillar 5 
Health, economic, 
social and 
institutional 
resilience 
21  % 
19  % 
22  % 
36  % 
38  % 
21  % 
14  % 
20  % 

Source: ECA, based on the estimated primary and secondary contribution of RRF funds planned for each measure towards two of the six pillars as reported by the 
Commission in the ‘Recovery and Resilience Scoreboard’ for 25 of the 26 RRPs adopted by the Council by end of October 2022. 

80 

Annex III – Allocation of the 2021-2027 cohesion policy funds, the RRF grants (provisional and final 
allocation) and the RRF loans activated 

COHESION  POLICY FUNDS  2021-2027 

Provisional Allocation until 30.6.2022 

Final Allocation as of 30.6.2022 

RRF GRANTS* 

RRF LOANS 
ACTIVATED 

ERDF 

ESF+ 

CF 

ETC 

TOTAL 

70 % of 
the 
amount 
available 

30 % of 
the 
amount 
available 

TOTAL 

70 % of 
the 
amount 
available 

30 % of the 
amount 
available 

TOTAL 

Belgium 
Bulgaria 
Czechia 
Denmark 
Germany 
Estonia 
Ireland 
Greece 
Spain 
France 
Croatia 
Italy 
Cyprus 
Latvia 
Lithuania 
Luxembourg 
Hungary 
Malta 
Netherlands 
Austria 
Poland 
Portugal 

1.1 
5.7 
10.4 
0.1 
10.9 
1.7 
0.4 
11.5 
23.5 
9.1 
5.4 
26.6 
0.5 
2.5 
3.5 
0.0 
13.4 
0.5 
0.5 
0.5 
47.4 
11.5 

1.2 
2.6 
2.7 
0.1 
6.5 
0.5 
0.5 
5.8 
11.2 
6.7 
2.0 
14.5 
0.2 
0.7 
1.1 
0.0 
5.5 
0.1 
0.4 
0.4 
14.9 
7.5 

0.4 
0.1 
0.3 
0.3 
1.0 
0.1 
0.3 
0.1 
0.7 
1.1 
0.2 
1.0 
0.0 
0.0 
0.1 
0.0 
0.2 
0.0 
0.4 
0.2 
0.6 
0.1 

1.3 
6.4 

0.8 

3.0 

1.2 

0.2 
1.0 
1.4 

2.6 
0.2 

9.3 
3.4 

2.7 
9.8 
19.8 
0.5 
18.4 
3.1 
1.2 
20.4 
35.4 
16.8 
8.7 
42.1 
0.9 
4.3 
6.1 
0.1 
21.7 
0.8 
1.3 
1.1 
72.2 
22.5 

3.6 
4.6 
3.5 
1.3 
16.3 
0.8 
0.9 
13.5 
46.6 
24.3 
4.6 
47.9 
0.8 
1.6 
2.1 
0.1 
4.6 
0.2 
3.9 
2.2 
20.3 
9.8 

2.3 
1.6 
3.5 
0.2 
9.3 
0.2 
0.1 
4.3 
22.9 
15.0 
1.7 
21.0 
0.2 
0.3 
0.1 
0.0 
2.5 
0.1 
2.0 
1.2 
3.6 
4.1 

5.9 
6.3 
7.1 
1.6 
25.6 
1.0 
1.0 
17.8 
69.5 
39.4 
6.3 
68.9 
1.0 
2.0 
2.2 
0.1 
7.2 
0.3 
6.0 
3.5 
23.9 
13.9 

3.6 
4.6 
3.5 
1.3 
16.3 
0.8 
0.9 
13.5 
46.6 
24.3 
4.6 
47.9 
0.8 
1.6 
2.1 
0.1 
4.6 
0.2 
3.9 
2.2 
20.3 
9.8 

0.9 
1.1 
4.1 
0.1 
11.7 
0.1 

3.9 
30.6 
13.1 
0.9 
21.1 
0.1 
0.2 
0.0 
0.0 
1.2 
0.1 
0.8 
1.5 
2.3 
5.8 

4.5 
5.7 
7.6 
1.4 
28.0 
0.9 
0.9 
17.4 
77.2 
37.4 
5.5 
69.0 
0.9 
1.8 
2.1 
0.1 
5.8 
0.3 
4.7 
3.7 
22.6 
15.6 

12.7 

122.6 
0.2 

11.5 
2.7 

in billion euros 

Cohesion 
Policy Funds 
2021-2027, 
RRF grants 
(final 
allocation) 
and RRF 
loans 
activated 
7.2 
15.3 
27.4 
1.9 
46.4 
4.0 
2.1 
50.5 
112.6 
54.3 
14.3 
233.6 
2.0 
6.0 
8.2 
0.1 
27.5 
1.1 
6.0 
4.8 
106.3 
40.8 

COHESION  POLICY FUNDS  2021-2027 

Provisional Allocation until 30.6.2022 

Final Allocation as of 30.6.2022 

RRF GRANTS* 

RRF LOANS 
ACTIVATED 

ERDF 

ESF+ 

CF 

ETC 

TOTAL 

70 % of 
the 
amount 
available 

30 % of 
the 
amount 
available 

TOTAL 

70 % of 
the 
amount 
available 

30 % of the 
amount 
available 

TOTAL 

Romania 
Slovenia 

17.1 
1.5 

Slovakia 
Finland 
Sweden 
Technical 
Assistance 
Transnational 
Cooperation 
Interregional 
Innovation 
European 
Urban Initiative 
Interregional 
Cooperation 
TOTAL  EU 

10.2 
1.3 

4.6 
1.7 
2.9 

4.0 
0.5 

1.7 
0.4 
0.4 

14.2 
1.8 

6.3 
2.1 
3.3 

10.2 
1.3 

4.6 
1.7 
2.9 

1.9 
0.2 

1.4 
0.2 
0.3 

12.1 
1.5 

6.0 
1.9 
3.2 

14.9 
0.7 

3.5 
0.7 

1.6 

0.4 
0.1 

0.2 
0.2 
0.4 

0.1 

0.0 

8.2 
0.7 

2.4 
0.6 
0.7 

0.3 

0.2 

0.6 

29.2 
3.1 

12.4 
1.7 
1.9 

1.3 

0.2 

0.6 

0.6 

0.6 

8.1 
0.9 
0.8 

0.8 

0.6 

0.6 

104 
* Note to RRF grants: pursuant to Article 11 of the RRF Regulation, the calculation of the maximum financial contribution for the 30 % of the allocated grant amount per
Member State was updated on 30 June 2022. This was done to take into account the latest data on the GDP for 2020 and 2021.

217 

234 

104 

338 

361 

338 

234 

165 

98 

37 

9 

864 

Source: ECA, based on Commission data, Annex IV of the RRF Regulation and the Commission note to the Council and Parliament ‘RRF: update of the RRF maximum financial 
contribution‘ of 30.6.2022. The amounts are rounded for presentation purposes. 

81 

Cohesion 
Policy Funds 
2021-2027, 
RRF grants 
(final 
allocation) 
and RRF 
loans 
activated 
56.2 
5.2 

18.3 
3.6 
5.2 

1.2 

0.2 

0.6 

0.6 

0.6 

82 

Acronyms and abbreviations 

CEF: Connecting Europe Facility 

CF: Cohesion Fund 

CID: Council Implementing Decision 

CPR: Common Provisions Regulation 

CRII: Coronavirus Response Initiative 

CSR: Country-Specific Recommendations 

DG ECFIN: Directorate-General for Economic and Financial Affairs 

DG EMPL:  Directorate-General for Employment, Social Affairs and Inclusion 

DG REGIO: Directorate-General for Regional and Urban  Policy 

ERDF:  European Regional Development Fund 

ESF+: European Social Fund+ 

ETC: European Territorial Cooperation 

FNLTC: Financing Not Linked To Costs model 

GDP: Gross Domestic Product 

GNI: Gross National Income 

MFF: Multiannual Financial Framework 

NGEU: NextGenerationEU 

OECD: Organisation for Economic Co-operation and Development 

RRF: Recovery and Resilience Facility 

RRPs: Recovery and Resilience Plans 

SCOs: Simplified cost options 

TFEU: Treaty on the Functioning of the European Union 

 
 
 
 
83 

Glossary 

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

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

European Pillar of Social Rights: Framework for delivering new and more effective 
social rights for EU citizens. 

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

Milestone: For cohesion policy, intermediate value in relation to an output indicator 
used under a specific objective, to be achieved by a pre-determined date. For the RRF, 
qualitative measure of progress towards the achievement of a reform or an 
investment. 

Multiannual financial framework:  The EU's spending plan setting priorities (based on 
policy objectives) and ceilings, generally for seven years. It provides the structure 
within which annual EU  budgets are set, limiting spending for each category of 
expenditure. 

Partnership agreement: An agreement between the Commission and a Member State 
or third country/-ies in the context of an EU  spending programme, setting out, for 
example, strategic plans, investment priorities or the terms of trade or development 
aid provision. 

Single project pipeline: The number of projects that a Member State intends/can 
implement, which are in the process of ‘maturing’ with the studies required for their 
implementation. 

Target:  For cohesion policy, pre-agreed final value to be achieved in relation to an 
indicator used under a specific objective. For the RRF, quantitative measure of 
progress towards the achievement of a reform or an investment. 

 
 
 
 
84 

ECA team 

This report was adopted by Chamber II Investment for cohesion, growth and inclusion 
spending areas, headed by ECA Member Annemie Turtelboom. The task was led by 
ECA Member Ladislav Balko, supported by Branislav Urbanic, Head of Private Office 
and Zuzana Frankova, Private Office Attaché; Friedemann Zippel, Principal Manager; 
Chrysoula Latopoulou, Head of Task; Cristina Jianu, Deputy Head of Task; 
Marion Boulard, Mariya Zhekova, Francisco Carretero Llorente and Lena Rangus, 
Auditors. Alexandra  Mazilu and Agnese Balode provided graphic design support. 

From left to right: Francisco Carretero Llorente, Lena Rangus, Chrysoula Latopoulou, 
Branislav Urbanic, Ladislav Balko, Friedemann Zippel, Marion Boulard. 

 
 
 
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PDF 

ISBN 978-92-847-9400-3  doi:10.2865/67831  QJ-08-23-003-EN-N 

This review provides a comparative analysis of 
cohesion policy funds and the Recovery and 
Resilience Facility (RRF).
The two instruments have considerable similarities, 
but also differ in many respects. The cohesion policy 
is the EU’s main long-term investment policyto 
promote economic, social and territorial 
development, while the RRF is an ad hoc, temporary 
‘crisis response’ tool. It aims to mitigate the impact 
of the COVID-19 pandemic on the EU economy and 
to enhance the resilience of the EU and its Member 
States against future shocks.
Both the 2021-2027 cohesion policy funds and the 
RRF are still in their early stages of implementation. 
In the coming years, simultaneous deployment of 
the two instruments will show how their different 
approachesachieve their respective objectives.  

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