COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Recovery and Resilience Facility: Two years on A unique instrument at the heart of the EU’s green and digital transformation
Date: 2023-02-21
Institutions: European Commission, Secretariat-General
Subjects: EU energy policy, EU environmental policy, EU financial instrument, EU financing arrangements, coronavirus disease, digital transformation, economic recovery, economic reform, epidemic, green economy, investment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.2.2023  COM(2023) 99 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Recovery and Resilience Facility: Two years on   A unique instrument at the heart of the EU’s green and digital transformation      
 
 
Recovery and Resilience Facility: Two years on 

A unique instrument at the heart of the EU’s green and digital transformation 

The two-year anniversary of the entry into force of the Regulation establishing the Recovery 
and  Resilience  Facility1  (‘RRF’)  is  an  opportunity  to  reflect  on  the  achievements  and 
challenges of this  unprecedented  instrument. The RRF,  at  the heart of the  EUR 800 billion 
NextGenerationEU recovery plan for Europe, was established in the midst of the COVID-19 
pandemic to help the Member States recover faster and become more resilient. It provides a 
powerful tool at the European level to support an accelerated and ambitious green and digital 
transition. Yet, its implementation is taking place in a constantly evolving context, marked by 
Russia’s unprovoked invasion of Ukraine, high inflation, and an energy crisis. 

The  RRF  remains  at  the  core  of  our  European  efforts  to  address  these  new  challenges  in  a 
changing  geopolitical  environment.  Now  is  the  time  to  take  stock  of  the  experience  gained 
over the past two years to ensure a continued successful rollout of the RRF.  

This Communication reviews the state of play of the implementation of the Facility, outlines 
further steps for supporting the continued successful implementation in the years to come and 
explains the methodology that will be applied in case a payment needs to be suspended.   

1.  Two-year  anniversary  of  the  Recovery  and  Resilience  Facility  –  an  innovative  and 

successful crisis-response tool  

1.1 The unique design of the Recovery and Resilience Facility 

The RRF is the centrepiece of the EUR 800 billion NextGenerationEU recovery plan for 
Europe and, as such, part and parcel of the EU’s response to the COVID-19 crisis. The 
Facility  was  created  to  mitigate,  in  the  near  term,  the  economic  and  social  impact  of  the 
pandemic and to support, over time, the EU recovery while making European economies and 
societies more sustainable, resilient and better prepared for future challenges. A common EU 
economic  response  was  also  decisive  to  protect  the  Single  Market  and  avoid  increased 
economic divergences in the Union. 

The Facility is an innovative, performance-based instrument, where payments are made 
to Member States, as beneficiaries, upon delivering reforms and investments pre-agreed 
in national recovery and resilience plans. The funds are therefore disbursed solely on the 
basis of the progress in the achievement of the reforms and investments that Member States 
committed to. Focused on the timely and efficient implementation of Member States’ plans, 
the  performance  logic  of  the  RRF  makes  payments  conditional  on  concrete  outcomes. 
Disbursements thus depend on the delivery of the pre-agreed investments and reforms rather 
than the final costs incurred. 

The RRF helps Member States to deliver on jointly identified policy priorities, including 
the green and digital transitions and the European Pillar of Social Rights.  The Facility 
supports long-lasting reforms and investments that directly contribute to the green and digital 

1 Regulation (EU) 2021/241 

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transitions, including the net-zero industrial transformation. About 40% of the total allocation 
of  the  plans  contributes  to  measures  aimed  at  reducing  net  greenhouse  gas  emissions  by  at 
least 55% by 2030, and more than 25% to measures of digital transformation of the European 
society  and  economy.  The  RRF’s  contribution  to  the  green  transition  is  further  reflected  in 
the mandatory respect of the “do no significant harm” principle, which is essential to ensure 
the compatibility of the Facility with the EU’s environmental objectives. Across the recovery 
and  resilience  plans,  which  have  been  positively  assessed  by  the  Commission  and  then 
adopted by the Council, around EUR 203 billion is allocated to climate expenditure and EUR 
131 billion to digital expenditure (respectively around 41% and 26% of the plans’ allocation). 
Moreover, the Facility also supports measures that are contributing to the implementation of 
the European Pillar of Social Rights, the Union of Equality, and the achievement of the 2030 
targets in terms of employment, skills and poverty reduction - with almost 30% of the plans’ 
allocation dedicated to social expenditure, or around EUR 138 billion.  

Member  States  have  flexibility  in  designing  and  implementing  the  measures  in  a  way 
that suits their national conditions, which increases their ownership of plans. Milestones 
and targets are designed individually to fit the specific investments and reforms the Member 
States commit to implement; this gives them full ownership to ensure a successful delivery. 
Investments and reforms are typically structured into a series of related milestones and targets 
spanning  over  multiple  payment  requests,  in  order  to  track  progress  with  the  delivery.  In 
contrast with most EU programmes, the RRF is characterised by the absence of co-financing 
requirements, thereby alleviating national budgets in times of economic strain.   

One of the main strengths of the RRF is  that investments are combined with reforms. 
The RRF supports Member States in  addressing  relevant  country-specific recommendations 
adopted by the Council as part of the European Semester. As such, the RRF provides political 
momentum and financial incentives for Member States to deliver on long-standing and newly 
emerging  reform  needs.  Meeting  such  needs  is  essential  to  enhance  the  resilience  and 
competitiveness of the European economy and to contribute to upward social and economic 
convergence. Reforms are typically designed to have an enabling effect for both public and 
private  investments,  by  setting  the  right  framework  conditions,  removing  absorption 
bottlenecks,  addressing  labour  market  mismatches  and  skills  shortages,  and  improving  the 
overall business environment. Reforms typically do not carry a large budgetary cost, but they 
must  also  be  delivered  by  the  Member  States.  Anchoring  national  recovery  and  resilience 
plans  in  the  European  Semester  cycle  ensures  their  continued  relevance,  as  possible 
modifications of plans are assessed against the latest country-specific recommendations.  

The  agenda  of  reforms  and  investments  supported  by  the  RRF  is  complementary  to 
other  Union  programmes  and  tools.  RRF-supported  investments  are  undertaken  in 
complementarity  with  the  implementation  of  the  cohesion  policy  funds.  In  addition,  the 
reforms implemented under the RRF also contribute to facilitating the roll-out of investments 
in  the  cohesion  policy  programmes.  RRF  investments  and  reforms  also  coherently  support 
Member States in achieving the objectives of other instruments like the National Energy and 
Climate Plans and the Just Transition Plans.  

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The RRF’s unprecedented agenda of 
already adopted reforms and completed investments2 

The RRF has triggered the implementation of major reforms across a wide range of policy 
areas.  More  than  one  third  of  all  measures  in  the  27  recovery  and  resilience  plans  are 
reforms (around 2187 reforms compared to 3780 investments). These reforms do not only 
make Member States more resilient in the long-term, but also improve the conditions for a 
successful  delivery  of  the  related  investments  under  the  RRF  as  well  as  the  Cohesion 
policy  Funds, for instance, by modernising regulatory frameworks in key sectors (digital, 
renewables,  transport),  improving  permitting  and  public  procurement  procedures  and 
strengthening the rule of law and anti-corruption safeguards.  

Some of the flagship reforms already adopted include: 

-  Reforms  to  digitalise  public  administration  (Slovakia)  and  ensure  cybersecurity 

(Romania). 

-  Reforms  of  civil  and  criminal  justice  systems  to  make  them  more  efficient  by 
reducing  the  length  of  proceedings  and  by  improving  the  organisation  of  courts 
(Italy, Spain). 

-  Labour market reforms and modernisation of active labour market policies (Spain). 
-  Reforms enhancing employment and social protection (Croatia). 
-  Reforms to foster scientific excellence and improve the performance of universities 
and public research organisations (Slovakia) and to enhance the predictability and 
stability of public research funding (Portugal). 

-  Reforms tackling corruption and ensuring protection of whistle-blowers (Cyprus).  
-  Licensing simplification reforms to boost the investments in offshore renewables or 
reforms  to  create  the  conditions  for  introducing  renewable  hydrogen  (Greece, 
Portugal, Spain).  

-  Reforms  to  support  the  roll-out  of  renewable  energy  and  sustainable  transport 

(Croatia, Romania). 

-  Reforms improving the quality of the legislative process (Bulgaria).  
-  Reform to improve affordable housing (Latvia). 

Some of the major investments with key steps already completed include: 

- 

Investments  to  support  the  decarbonisation  and  energy  efficiency  of  industry 
(Croatia EUR 91 million, France EUR 1.4 billion). 

-  Purchase  of  600  000  new  laptops  to  lend  to  teachers  and  pupils,  and  selection  of 
Digital Innovation Hubs to support companies in their digitisation efforts (Portugal, 
EUR 600 million). 

-  Funds  to  increase  the  competitiveness  of  firms  operating  in  the  tourism  sector, 

including 4000 SMEs (Italy, EUR 1.9 billion). 
Investments to support vulnerable people (Italy, EUR 1 billion). 

- 
-  Digitisation  of  public  administration  towards  digital,  simple,  inclusive  and  secure 

public services for citizens and businesses (Portugal, EUR 170 million). 

-  Broadband infrastructure development (Latvia, EUR 4 million). 

2  The  list  of  examples  covers  the  reforms  and  investments  whose  related  milestones  and  targets  have  already 
been  assessed  as  satisfactory  fulfilled  by  the  Commission  following  a  positive  opinion  of  the  Economic  and 
Financial Committee. The monetary amounts for each investment refer to the ex-ante estimation of costs at the 
time of approving each national recovery and resilience plans. 

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- 

Investment  plan  for  high-tech  equipment  in  the  National  Health  System  (Spain, 
EUR 796 million). 

1.2. Delivering on the EU's post-pandemic recovery and building long-lasting resilience  

Thanks to its unique design, the RRF can swiftly provide significant financial support to 
Member States to contribute to their economic and social resilience. The implementation 
of  the  RRF  is  now  firmly  underway,  with  all  national  plans  in  place  and  sixteen  payment 
requests already fully processed, another three already positively assessed and eight with an 
assessment ongoing. To date, the Commission has disbursed a total of over (EUR 144 billion) 
under the Facility, in both grants (EUR 96 billion) and loans (EUR 48 billion). These figures 
include  the  pre-financing  disbursed  to  Member  States  in  2021  (EUR  56.5  billion).  Pre-
financing  provided  fast  direct  support  to  Member  States,  playing  a  stabilising  role  in  the 
aftermath  of  the  unprecedented  economic  and  social  shock  caused  by  the  COVID-19 
pandemic,  thereby  also  helping  to  kick-start  the  recovery.  The  additional  pre-financing 
agreed by co-legislators in the context of REPowerEU seeks to achieve the same goals.3 

The  RRF  is  already  playing  a  visible  role  in  supporting  investment  levels  and  the 
quality of investments and reforms. The EU economy closed the gap with its pre-pandemic 
output levels in summer 2021, supported by the unprecedented, coordinated response to the 
COVID-19  pandemic,  including  under  NextGenerationEU.  In  2022,  the  EU’s  GDP  is 
forecasted to have grown by 3.5%4, and the unemployment rate has reached a historic low of 
6.1%  in  December,  despite  the  additional  shocks  brought  by  Russia’s  illegal  war  of 
aggression  against  Ukraine.  RRF  disbursements  and  implementation  are  set  to  reach  their 
highest  level  in  2023,  supporting  public  and  private  investment  and  reforms.  The  public 
investment to GDP ratio is projected to increase from 3.0% in 2019 to 3.4% of GDP in 20235. 
Half of this increase between 2019 and 2023 is supported by EU financing and RRF funding. 
In  parallel,  Member  States  are  seeing  an  unprecedented  delivery  of  structural  reforms  in 
response to the European Semester country-specific recommendations.  

The transformative dimension of investments and reforms under the RRF is expected to 
support  the  EU’s  economic  activity  as  well  as  increase  its  resilience.  As  regards  its 
potential  medium-term  impact,  the  Commission  estimated  that  the  investments  funded  by 
NextGenerationEU  could  boost  the  EU’s  GDP  by  around  1.5%  in  2024  and  stimulate  job 
creation.6 The implementation of the national recovery and resilience plans triggers positive 

3  Member  States  can  request  a  maximum  pre-financing  of  up  to  20%  (to  be  paid  in  two  tranches)  of  the 
additional  funding  required  to  finance  the  measures  in  their  REPowerEU  chapters,  subject  to  available 
resources.  The  additional  funding  eligible  for  pre-financing  can  encompass  additional  grants  from  Emission 
Trading System, Brexit Adjustment Reserve transfers, a, Cohesion Policy Funds transfers, increased allocation 
following the update in June 2022 and loans, to the extent that these sources finance the REPowerEU measures. 
To be eligible for pre-financing the Council Implementing Decision approving the relevant revised plan needs to 
be adopted before the end of 2023.  
4 Data based on Commission Winter Forecast 2023 
5 Data based on Commission Autumn Forecast 2022 
6 See  Pfeiffer P., Varga J. and in  ’t Veld J. (2021), “Quantifying  Spillovers of NGEU investment”, European 
Economy Discussion Papers, No. 144 and Afman et al. (2021), “An overview of the economics of the Recovery 

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spillover  effects  in  the  Single  Market:  according  to  the  Commission’s  simulations,  all 
Member  States  benefit  from  sizable  cross-border  spillover  effects  thanks  to  rising  demand 
across the integrated EU economy. Joint action yields higher growth effects than the sum of 
individual effects of Member States’ national plans. 

Funding the RRF has contributed to making the EU one of the largest issuers of euro-
denominated  bonds.  Driven  by  the  RRF  financing  needs,  in  2022  EU  gross  issuances 
amounted to EUR 119 billion in long-term instruments.7 The recent changes in bond market 
conditions have not altered the EU’s strong market access; the EU’s high credit rating and the 
Commission’s unified funding approach allow it  to borrow on advantageous conditions and 
minimise the cost of the related debt.  

The EU is well on track to be the largest issuer of green bonds worldwide. From October 
2021  to  December  2022,  the  Commission  had  raised  EUR  36.5  billion  in  green  bonds  to 
support eligible green expenditure under the RRF, showcasing the EU’s commitment to the 
green transition and the promotion of sustainable finance. To provide the utmost transparency 
to  investors,  the  Commission  has  published  the  NextGenerationEU  Green  Bond  dashboard 
and its first allocation report in December 20228. 

2.  Accelerating the RRF’s implementation: a Covid-19 crisis response tool paving 

the way to a net-zero future 

2.1. The RRF as an agile crisis-response tool: REPowering the Union for the net-zero age 

The second anniversary of the RRF coincides with the first year of Russia’s unprovoked 
military  aggression  against  Ukraine.  While  Member  States  were  recovering  from  the 
profound  economic  and  social  effects  of  the  COVID-19  pandemic,  Russia’s  war  against 
Ukraine  caused  renewed  pressures  on  supply  chains,  as  well  as  on  global  energy  and  food 
markets, which  have  resulted  in  high levels  of inflation, putting a strain on households and 
businesses. 

The REPowerEU Plan, proposed in May 2022 as the EU’s response to the global energy 
crisis, recognised the role of the RRF for achieving secure, affordable and green energy.  
Under  REPowerEU,  the  RRF  will  support  Member  States  in  putting  forward  additional 
reforms  and investments  to rapidly phase-out the  EU’s  dependence on  Russian  fossil fuels, 
accelerate  the  clean  energy  transition,  support  the  reskilling  of  the  workforce,  and  address 
energy poverty. These new or scaled-up measures, to be included in dedicated REPowerEU 
chapters, will come on top of the already ambitious green agenda of the existing recovery and 
resilience  plans,  which  already  include  support  to  environmental  priorities  such  as  the 
circular economy. 

and Resilience Facility”, Quarterly Report on the Euro Area (QREA), Vol. 20, No. 3 pp. 7-16. Both studies also 
highlight the sensitivity of the results to key assumptions. 
7 This includes borrowing for other programmes, such as SURE and MFA. 
8 NextGenerationEU Green Bonds Allocation Report, 16 December 2022, SWD(2022) 442 final (europa.eu) 

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The  EU’s  Green  Deal  Industrial  Plan9  makes  it  clear  that  both  the  RRF  and 
REPowerEU  are  at  the  centre  of  the  Union’s  plans  to  enhance  the  competitiveness  of 
Europe's  net-zero  industry  and  support  the  fast  transition  to  climate  neutrality.  The 
reforms  triggered  by  the  implementation  of  the  RRF,  including  on  accelerating  permitting, 
will  have  an  enabling  effect  on  investments  necessary  for  the  net-zero  transition,  including 
from the private sector. In addition, RRF funds will be available to Member States to finance 
further  measures  promoting  the  deployment  and  manufacturing  of  net-zero  technologies  in 
Europe, enhancing training and skills for all people to enable the green and digital transitions, 
supporting EU net-zero industry projects and the creation of quality jobs, incentivising R&I 
for new zero emission breakthrough technologies and assisting industries in the face of high 
energy prices, including through tax breaks. As large amounts of private capital will also be 
necessary,  advancing  the  Capital  Markets  Union  to  ensure  deep  and  integrated  capital 
markets in the EU is an essential complement to the RRF. 

To effectively sharpen Europe’s competitive edge, REPowerEU strengthened the RRF's 
financial firepower. Additional RRF grants  (EUR 20 billion)  funded by the EU Emissions 
Trading  System  will  be  available  to  Member  States  to  promote  REPowerEU  objectives. 
Member States may transfer a part or the whole of the Brexit Adjustment Reserve allocation 
(up to  EUR 5.4 billion)  as well  as up to  5%  of the cohesion  policy  funds  (up to  EUR 17.9 
billion) to dedicate grants to these objectives. Furthermore, Member States will be able to use 
the  remaining  RRF  loans  (EUR  225  billion)  with  substantial  pre-financing  for  the 
investments  and  reforms  Member  States  are  now  invited  to  present  in  their  REPowerEU 
chapters by 30 April 2023.10  

2.2. Pathway towards a successful implementation 

As  the  Facility  enters  into  the  second  half  of  its  lifetime,  adhering  to  the  timelines 
outlined in Member States' plans is increasingly important. Member States should make 
their  best  efforts  to  fully  use  the  opportunities  provided  by  the  RRF,  by  delivering  the 
investments  and  reforms  within  the  timelines  foreseen  in  the  Council  Implementing 
Decisions  approving  the  assessments  of  national  recovery  and  resilience  plans.  Respecting 
these  timelines  is  very  important  to  ensure  efficient  planning  of  funding  operations  on  the 
capital markets and timely disbursements.11  

Global instability, supply chain disruptions, the energy crisis and inflation are putting a 
strain  on  national  authorities,  making  the  implementation  of  recovery  and  resilience 
plans at times more challenging. Yet, at the same time, they also make the successful and 
timely  implementation  of  those  plans  even  more  crucial.  The  Commission  stands  by  its 
commitment to fully support all Member States to accelerate the implementation of the plans. 
From  the  outset,  one  of  the  important  features  of  national  plans  has  been  to  strengthen  the 
administrative capacity of Member States. Now, with new challenges requiring a new policy 

9 COM(2023) 62 final 
10 Guidance on Recovery and Resilience Plans in the context of REPowerEU, 1 February 2023 
11 In this regard, Member States must accurately forecast and update the Commission on any deviations from the 
timeline of expected payment requests. 

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response, this capacity needs to be further enhanced, including through the Technical Support 
Instrument12.  

The  revision  of  the  plans  and  the  addition  of REPowerEU  Chapters  in  spring  2023  is 
also an opportunity to take into account the experience gained during the first years of 
RRF  implementation.  The  Commission  will  support  Member  States  to  optimise  the 
implementation and monitoring of the plans while increasing their level of ambition with the 
additional funding available.  

The Commission will also continue to play its role in protecting the financial interests of 
the Union. To this end, the Commission ensures that national control systems are robust and 
implements its ambitious audit strategy, in line with its duties and responsibilities under the 
RRF  Regulation.  Member  States  submitting  revised  plans  will  be  asked  to  justify  precisely 
how the control structures put in place are still appropriate  and, where necessary, how they 
will be reinforced to ensure appropriate resources and structures. 

2.3. Increasing transparency and engagement with stakeholders 

The accelerated implementation goes hand in hand with a high level of transparency on 
the functioning of the Facility. Since the inception of the RRF, the Recovery and Resilience 
Scoreboard13 has served as a key transparency tool. It displays the contribution of the Facility 
under  the  six  policy  pillars,  including  granular  data  on  common  indicators  and  thematic 
analyses,  while  also  providing  real-time  information  on  the  disbursements.  The  RRF 
webpage14 contains the details of all 27 national plans as well as the detailed assessments of 
the satisfactory fulfilment of each of the milestones and targets pertaining to the reforms and 
investments  relevant  for  each  payment  request.  In  addition,  to  increase  public  awareness 
about the individual projects financed by the RRF, the Commission is working to produce an 
interactive  map  that  will  provide  a  visual  interface  to  explore  a  selection  of  RRF  measures 
and their locations in the Member States.  

The  transparency  of  the  RRF  framework  will  be  further  strengthened  by  the 
REPowerEU  Regulation,  on  which  a  political  agreement  was  reached  in  December  2022 
between  the  European  Parliament  and  the  Council,  requiring  Member  States  to  publish 
information on the 100 final recipients receiving the highest amounts of RRF funding. While 
the  beneficiaries  of  RRF  funds  are  the  Member  States,  the  information  on  the  largest  final 
recipients  of  RRF  funding  in  each  Member  State  will  provide  an  updated  overview  of  the 
entities  and  individuals  supported  the  most  from  the  measures  contained  in  the  national 
recovery  and  resilience  plans.  This  will  enhance  the  transparency  and  accountability  of  the 
Facility.  

The European Parliament has a pivotal role in the implementation of the RRF. Since the 
beginning  of  2021,  the  Commission  has  actively  participated  in  a  series  of  Recovery  and 

12 Recovery and Resilience Plans (europa.eu) 
13 Recovery and Resilience Scoreboard (europa.eu) 
14 Recovery and Resilience Facility (europa.eu) 

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Resilience  Dialogues,  as  well  as  a  variety  of  working  group  meetings  and  plenary  debates 
organised  by  the  European  Parliament.  During  each  of  these  meetings,  the  Commission 
provided  detailed  presentations  and  answered  the  questions  posed  by  the  Members.  The 
Commission diligently took note of the points raised by the Members and, to the best of its 
ability, addressed them in its ongoing work. This close collaboration between the Parliament 
and the Commission has significantly contributed to the successful rollout of the RRF during 
its first two years. 

Public consultation requirements have also been strengthened for the preparation of the 
REPowerEU chapters and remain key during the overall implementation of the plans.    
Member  States  will  have  to  consult  relevant  stakeholders  when  drafting  their  REPowerEU 
chapters. When Member States request to revise  their plans, they will have to submit to the 
Commission  a  summary  of  the  consultation  process,  including  information  on  the 
stakeholders consulted and a description of how their input has been reflected in the design of 
REPowerEU measures. Finally, Member States should ensure that relevant stakeholders, with 
a  particular  focus  on  local  and  regional  authorities  and  social  partners  remain  closely 
involved in the implementation of the RRF in a timely and meaningful way. In particular, the 
Commission  will  keep  organising  together  with  Member  States  joint  Annual  Events.  These 
are  key  communication  moments  bringing  together  institutions,  stakeholders  (in  particular 
social partners  and civil  society) and  recipients of RRF support to  discuss  the progress  and 
state  of  play  of  the  implementation  of  the  national  recovery  and  resilience  plans  in  each 
Member  State.  Member  States  should  also  continue  their  efforts  in  informing  the  general 
public about the concrete results of the RRF support on the ground. Overall, fostering joint 
ownership will further increase trust in the Facility, which is vital for a successful delivery. 

3.  An agile toolbox for the next phase of the implementation  

The  experience  gained  from  the  two  first  years  of  the  RRF  implementation  shows  that  the 
Facility’s continued success will depend on the ability of Member States to achieve, within 
the lifetime of the Facility, all milestones and targets included in their recovery and resilience 
plans. In that regard, it is essential that Member States continue to focus their resources and 
efforts to ensure a quick deployment of the measures, with the Commission providing hands-
on support as needed to help the Member States.  

While speed remains essential in the implementation of the RRF, so does the obligation for 
Member States to deliver on the mutually agreed milestones and targets. The implementation 
of  the  RRF  requires  flexibility  on  the  means  to  achieve  the  milestones  and  targets  while 
remaining firm on the delivery of the essential policy objectives of the measures agreed with 
the Member States. To this end, the Commission presents three implementation tools that will 
add predictability and transparency. These tools reflect more than a year of experience in the 
assessment of payment requests.  

3.1. Framework for assessing milestones and targets under the RRF Regulation 

The  milestones  and  targets  set  in  national  plans  are  at  the  core  of  the  RRF  as  they 
represent  commitments  made  by  the  Member  States  to  access  RRF  support.  The 
assessment of these commitments is based on clear conditions and requires a detailed analysis 
to determine if the Member States have fulfilled their obligations in a satisfactory way. The 

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Commission  is  responsible  for  making  this  assessment,  taking  into  account  the  opinions  of 
the Economic and  Financial Committee  and  under the control of Member States  within  the 
Committee  on  the  Recovery  and  Resilience  Facility.  The  status  of  fulfilment  of  the 
milestones  and  targets  as  well  as  the  related  payments  is  also  a  matter  that  the  European 
Parliament and the Commission may discuss during the Recovery and Resilience Dialogues. 

To foster transparency and equal  treatment amongst Member States, the  Commission 
has  published  all  preliminary  assessments15  of  the  payment  requests  submitted  by  the 
Member States. Today, the Commission takes another step in  this  direction, by publishing 
its  framework  for  assessing  the  satisfactory  fulfilment  of  the  milestones  and  targets  (see 
annex I). The Commission strongly believes that by making this framework public, national 
authorities,  stakeholders  and  the  wider  public  will  gain  a  better  understanding  of  how  the 
implementation of measures supported by the RRF is evaluated before each disbursement. 

The framework will continue to guide the RRF’s implementation for the period ahead. 
The  Council  Implementing  Decisions  approving  the  recovery  and  resilience  plans  are  the 
basis  for  evaluating  the  satisfactory  fulfilment  of  milestones  and  targets.  The  Commission 
relies  on  the  description  of  each  milestone  and  target  in  light  of  its  context  and  purpose  to 
determine the requirements that Member States must fulfil. It then establishes, based on the 
due justifications provided by the Member States, whether a specific milestone or target has 
been  satisfactorily  fulfilled.  In  a  limited  number  of  circumstances  and  in  line  with  the 
application  of  the  de  minimis  principle,  minimal  deviations  linked  to  the  amounts,  formal 
requirements, timing or substance can be accepted. 

3.2. Revision of the plans 

In 2023, most Member States  will  revise their plans  to add REPowerEU chapters and 
access  additional  funding  opportunities.  The  revision  of  the  plans  also  represents  an 
opportunity  to  reflect  on  the  lessons  learned  from  the  implementation  phase  and  take  them 
into account in the design of both new and revised measures, increasing the level of ambition 
of the plans. The Commission Guidance16 on the revision of the recovery and resilience plans 
in  the  context  of  REPowerEU  adopted  on  1  February  2023  explains  how  to  apply  various 
elements  of  the  Regulation  to  optimise  the  design  of  the  revised  plans  and  incorporate 
measures that can contribute the most to the RRF objectives. The Commission will support 
Member States to identify and tackle potential bottlenecks in the implementation of existing 
measures. 

The  Commission  also  strongly  encourages  Member  States  to  include  in  their 
REPowerEU chapters simple and effective measures to provide support to strategic net-
zero industries and boost their competitiveness in the context of the net-zero transition. 

15  Once  a  Member  State  submits  a  payment  request  to  the  Commission,  the  Commission  has  two  months  for 
assessing  the  satisfactory  fulfilment  of  the  relevant  milestones  and  targets.  To  conclude  its  assessment,  the 
Commission provides its positive preliminary assessment to the Economic and Financial Committee. Within 4 
weeks,  the  Economic  and  Financial  Committee  provides  an  opinion  on  these  findings,  after  which  the 
Commission implementing decision that authorises the disbursement is adopted.  
16 Guidance on Recovery and Resilience Plans in the context of REPowerEU (europa.eu) 

9 

 
 
 
 
 
 
 
                                                           
This in particular could include one-stop shops for permitting processes for net-zero projects 
or tax breaks for businesses undertaking clean-tech manufacturing investments. The Facility 
can  also  finance  investments  to  equip  the  workforce  with  the  skills  necessary  for  this 
industrial transition. Also, REPowerEU can finance investments in zero-emission mobility to 
help decarbonising the transport sector.  

At the same time, Member States should maintain the level of ambition of each recovery 
and  resilience  plan  and  avoid  backloading  measures.  In  assessing  the  modifications  put 
forward  for  each  plan,  the  Commission  will  pay  specific  attention  to  ensuring  that  the 
existing  ambition  of  reforms  and  investments  playing  an  important  role  in  addressing  the 
country-specific  recommendations,  as  well  as  the  priority  actions  for  fair  green  and  digital 
transitions,  are  preserved.  Furthermore,  the  Commission  will  promote  the  scaling  up  of 
measures  already  in  the  pipeline  to  reduce  the  risk  of  delays  in  the  implementation  of  the 
plans  and,  at  the  same  time,  ensure  continuous  consistency  between  disbursements  and  an 
effective and efficient funding planning. 

3.3 Payment suspension methodology  

The  RRF  Regulation  caters  for  adverse  and  unexpected  developments  and  allows 
partial  or  full  suspensions  of  payments  to  address  implementation  shortcomings. 
Member States might be confronted with delays in the implementation of measures, affecting 
the timely fulfilment of some milestones and targets. These situations should be exceptional 
and corrected as soon as possible. They should not, where justified, prevent payments from 
being made for milestones and targets that have been fulfilled. The RRF Regulation caters for 
such a situation where implementation issues for one or more of the milestones or targets of a 
payment  request  cannot  be  addressed  in  time  before  the  submission  of  a  payment  request. 
More specifically, the Regulation provides for the possibility for the Commission to suspend 
payments  partially  or  fully,  thereby  also  ensuring  compliance  with  the  principles  of  sound 
financial  management  as  foreseen  in  the  Financial  Regulation.  Partial  suspension  is  not 
possible in case of non-fulfilment of milestones or targets related to a Member State’s control 
system, which are necessary for the protection of the financial interests of the Union. Such a 
case always leads to the suspension of the full instalment and all future instalments, until the 
non-fulfilment is remedied.  

The  payment  suspension  procedure  favours  the  continued  implementation  of  the  plan 
and  provides  time  for  Member  States  to  lift  the  suspension  by  fulfilling  the  relevant 
milestone(s)  or  target(s)  within  a  period  of  six  months.  The  partial  suspension  of  a 
payment will give additional time to a Member State to tackle specific implementation issues 
while,  in  the  meantime,  benefitting  from  a  partial  payment  linked  to  the  milestones  and 
targets that have been satisfactorily fulfilled. The suspension decision opens a period of six 
months  where  the  Member  State  has  the  opportunity  to  complete  the  relevant  milestone  or 
target.  When  this  happens,  the  Commission  will  lift  the  suspension  through  a  positive 
assessment and subsequently pay the suspended amount following the positive opinion of the 
Economic and Financial Committee. Should there be a negative assessment, following the six 
months period, then the respective amount will be permanently suspended and deducted from 
the budget of the plan. 

10 

 
 
 
 
The Commission will determine the amount to be suspended if a milestone or target is 
not  satisfactorily  fulfilled,  in  full  respect  of  the  principles  of  equal  treatment  and 
proportionality.  The  Commission’s  methodology  (detailed  in  Annex  II)  is  necessary  to 
underpin  and  justify  its  decisions  as  regards  payments  suspensions.  It  provides  a  clear  and 
consistent approach to determine the relevant amounts, while retaining a margin of discretion. 

The  payment  suspension  methodology  reflects  the  performance-based  nature  of  the 
RRF and the unique combination of reforms and investments. Payments under the RRF 
are not linked to the estimated or actual costs of the relevant measures but rather reflect the 
relative importance attributed to  each  group of  measures,  and the  corresponding milestones 
and targets, in view of the challenges experienced by the Member State. The same principles 
must therefore be applied when determining the amount to be suspended when a milestone or 
target is not met.  

The  calculation  of  the  suspended  amount  will  reflect  the  fact  that  not  all  measures 
contribute equally to the realisation of the objectives of an RRP. For instance, a relatively 
minor individual investment cannot be attributed the same value as a large investment, or as 
the entry into force of a major reform. In addition, the relative significance of each milestone 
and  target  in  the  implementation  of  the  measure  will  be  taken  into  consideration.  For 
example, a final milestone or target will count more than an intermediary milestone followed 
by  subsequent  milestones  or  targets  related  to  the  same  investment.  This  explains  the 
differentiation in the methodology (detailed in Annex II) between investments and reforms, 
as well as the coefficients and the upward or downward adjustments applied to the amount to 
be suspended to reflect the importance of the milestone or target at stake.  

A contradictory procedure will ensure that the Member States can submit observations 
regarding  the  negative  assessment  by  the  Commission  underpinning  the  suspension 
decision.  The  Member  State  will  be  invited  to  provide  its  observations  regarding  the 
Commission’s  negative  assessment  on  the  satisfactory  fulfilment  of  a  milestone  or  target. 
Similarly,  should  the  Commission  conclude  that  the  Member  State  has  not  taken  the 
necessary  measures  to  ensure  a  satisfactory  fulfilment  of  the  milestone  or  target  within  six 
months  from  the  suspension  decision,  Member  States  may  also  present  their  observations. 
Finally,  Member  States  will  have  the  opportunity  to  discuss  and  vote  on  the  amount 
suspended in the context of the Comitology procedure regarding the disbursement decision. 

The  implementation  framework  presented  in  this  Communication  aims  to  create  the 
best  conditions  for  fast  absorption  of  RRF  funding,  while  ensuring  the  continued 
delivery of quality investments and reforms. The Member States should continue to ensure 
their  full  commitment  to  deliver  timely  on  the  milestones  and  targets  of  their  plans.  The 
Commission  will  remain  vigilant  to  ensure  that  plans  continue  to  address  country-specific 
recommendations and fulfil the green and digital targets. 

Conclusions 

The RRF has been a vital response to the COVID-19 pandemic. It is  a significant financial 
and policy effort, designed to support the EU's recovery. It provided a powerful boost to the 
EU economy, fast-forwarded the twin green and digital transition and strengthened the EU’s 
resilience for future challenges. It provides a unique approach, combining investments with 
reforms  and  giving  Member  States  flexibility  in  implementing  measures  that  best  suit  their 

11 

 
 
national  circumstances.  With  only  two  years  since  its  inception,  the  RRF  has  already 
delivered significant financial support and kick-started the EU's economic recovery. 

With  newly  emerging  challenges,  the  RRF  must  remain  agile  to  continue  to  efficiently 
support a fair and inclusive recovery of Member States and EU regions from the COVID-19 
crisis, while leading the EU towards a more sustainable and resilient future through ambitious 
investments and reforms. Thanks to its unique design and the strategic foresight embedded in 
its  priorities,  the  RRF  is  able  to  address  newly  emerged  pressing  challenges  linked  to  the 
EU’s energy security, sustainable industrial competitiveness, and the industrial transition to a 
net-zero economy while contributing to upwards social and economic convergence. 

Building on the valuable lessons learned in the past two years, the Commission stands ready 
to support Members States to ensure the continued success of the RRF implementation. The 
application  of  the  methodologies  for  assessing  the  satisfactory  fulfilment  of  milestones  and 
targets and the suspension of payments will also serve this purpose and continue to ensure the 
sound financial management of the Facility.  

The mid-term evaluation of the RRF next year will serve as another opportunity to take stock 
and assess the progress made with and lessons learnt from the implementation of the RRF. 

12 

 
 
 
 
ANNEX I - Framework for assessing milestones and targets under the RRF Regulation 

The  release  of  funds  under  the  Facility  is  contingent  on  the  satisfactory  fulfilment  of  the 
relevant  milestones  and  targets  by  the  Member  States  set  out  in  the  Council  Implementing 
Decisions. Such an assessment is conducted in accordance with Article 24(3) of Regulation 
(EU)  2021/241  (‘the  RRF  Regulation’).  The  Commission  has  two  months  to  assess  on  a 
preliminary  basis  whether  the  relevant  milestones  and  targets  have  been  satisfactorily 
fulfilled.  The  Commission  shares  afterwards  those  findings  with  the  Member  States  in  the 
Economic  and  Financial  Committee  for  their  opinion.  The  status  of  fulfilment  of  the 
milestones  and  targets  as  well  as  the  related  payments  is  also  a  matter  that  the  European 
Parliament and the Commission may discuss during the Recovery and Resilience Dialogues.  

To ensure transparency and equal treatment amongst Member States, the below methodology 
represents the framework that the Commission is relying upon for conducting the assessment. 
It  is  based  on  the  experience  that  the  Commission  has  gained  so  far  in  the  assessment  of 
milestones and targets under the RRF Regulation. 

1.  Establishing the requirements for a specific milestone or target 

  All  elements  of  the  milestone/target  and  the  description  of  the  measure  should  be 
considered  in  order  to  identify  the  requirements  for  a  specific  milestone/target.  The 
further  specifications  of  the  measure  in  the  operational  arrangements  should  also  be 
considered,  whilst  other  elements  in  the  operational  arrangements  (such  as  verification 
mechanisms and monitoring steps) should not.  

  Elements using non-obligatory language should not be considered as requirements. 

 

In relation to the description of the measure: 

o  elements that are directly or indirectly linked to that specific milestone/target should 

be considered as requirements of that milestone/target; 

o  elements that are not directly or indirectly linked to that milestone/target should not 

be considered as requirements; 

o  elements that are not directly or indirectly linked to any milestone/target  under that 
measure,  if  any,  should  be  explicitly  mentioned  as  such  in  the  context  of  the 
preliminary assessment of the final milestone/target. 

  To interpret the requirements of a specific milestone or target, it is necessary to consider 
their wording,  in  light  of its context  and their purpose. The context  and purpose can be 
derived by reviewing various sources, such as the national recovery and resilience plans, 
recitals of the Council Implementing Decision approving the assessment of the recovery 
and  resilience  plan,  the  Staff  Working  Documents  accompanying  the  Commission’s 
proposals  for  such  Council  Implementing  Decisions,  notes  to  the  file  during  the 
assessment,  records  of  exchanges  with  the  national  authorities  or  the  country  specific 
recommendations adopted by the Council linked to that measure.  

13 

 
 
 
 
2.  Establishing  on  the  basis  of  the  due  justification  put  forward  by  a  Member  State 

whether the specific milestone or target has been satisfactorily fulfilled  

 

In  line  with  the  application  of  de  minimis,  minimal  deviations  from  the  established 
requirements of the milestone/target, will be accepted in the following circumstances: 

o  Amounts:  where  there  is  a  minimal  deviation  from  amounts  specified  in  that 
milestone/target. Such minimal deviation is defined as around a 5% or less deviation. 

o  Formal requirements: where there is a minimal deviation from a formal requirement 
of  the  milestone/target  related  to  the  internal  procedures  of  Member  States,  which 
does not affect the progress towards the achievement of the reform or investment that 
the milestone/target represents. 

o  Timing:  limited  and  proportional  delays  between  the  publication  of  regulatory 
measures  and  their  effective  entry  into  force,  provided  that  the  certainty  of  their 
application  and  the  beginning  of  legal  effects  are  respected17.  Such  a  limited  and 
proportional  delay  should  be  assessed  considering  the  implementation  steps  that 
should be undertaken by the relevant authorities or the parties impacted by the reform 
to enable a reasonable application of the new regulatory measures, within the timeline 
of the Facility.  

o  Substance  requirements:  where  there  is  a  minimal  deviation  from  a  substance 
requirement of the milestone/target, which does not change the nature of the measure, 
and  which  does  not  affect  the  progress  towards  the  achievement  of  the  policy 
objective of the reform or investment that the milestone/target represents.  

The  Commission  will  continue  to  transparently  present  its  findings  on  the  satisfactory 
fulfilment of milestones and targets by publishing on its website the preliminary assessments 
related to all payment requests received from the Member States.  

17  This  is  without  prejudice  to  legislation  that  is  necessary  for  compliance  with  Article  22  of  the  RRF 
Regulation,  which,  given  its  nature  (necessary  to  ensure  compliance  with  the  RRF  Regulation),  cannot  be 
considered grounds for a limited or proportional delay. 

14 

 
 
 
 
 
                                                           
ANNEX II - Commission methodology for the determination of payment suspension 
under the Recovery and Resilience Facility Regulation18 

I. 

Principles of the methodology 

a)  Unit value per RRP 

The basis for the calculation of the suspended amount is the ‘unit value’ of a milestone 
or target. To ensure a clear relationship between the value that is attributed by the Union to 
the implementation  of the Recovery and Resilience Plan (RRP) and the suspended amount, 
the unit value of every milestone and target is calculated by dividing, for each RRP, its total 
value  by  the  number  of  milestones  and  targets  (total  RRP  allocation/number  of  milestones 
and targets). E.g.:  RRP maximum financial contribution of EUR40 billion / 175 milestones 
and targets = unit value of EUR229 million for each milestone or target. For those Member 
States  that  have  also  requested  a  loan,  there  will  be  two  different  unit  values,  one  for  the 
milestones  and  targets  foreseen  under  the  non-repayable  support  part  of  their  RRP  and  one 
for those milestones and targets foreseen under the loan part.  

b)  Coefficients and upward and downward adjustments 

To give due consideration to differences between the measures in the RRPs and between 
milestones  and  targets,  the  Commission  will  calculate  ‘corrected  unit  values’.  To  this 
end, the Commission  will  apply coefficients  to  the unit value. These coefficients  are set  by 
assessing  the  importance  of  each  unfulfilled  milestone  or  target  and  the  depth  of  the 
implementation gap they represent.  

Once corrected unit values are established, upward and downward adjustments will be made 
in the specific cases outlined below.  

The  final  amount  to  be  suspended  per  unfulfilled  milestone  or  target  will  be  equal  to  the 
corrected unit value subject to any upward and downward adjustment (‘suspension value’). 

Investments 

Coefficients applied to the unit value 

1)  A coefficient of 2 is applied for milestones and targets of  large investments 
(accounting for more than 10% of the non-repayable support or loan) with a 
limited number of milestones and targets (at or below 5). 

2)  A coefficient of 0.5 is applied to:  

  milestones  and  targets  of  the  smallest  investments  (accounting  for  less 

than or equal to 0.1% of the non-repayable support or loan); 

18 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing 
the Recovery and Resilience Facility. 

15 

 
 
 
 
                                                           
 

intermediary milestones (i.e. not targets) that are followed by subsequent 
milestones and/or targets related to the same investment. 

3)  For all other milestones and targets, a coefficient of 1 is applied. 

Adjustment of the corrected unit value 

1)  Proportional  reductions  to  the  corrected  unit  values  are  applied  in  the 

following cases: 

 

In  case  an  investment  target  has  not  been  satisfactorily  fulfilled,  the 
progress made towards achieving the target is assessed. The amount to be 
suspended is determined proportionally to the distance to the target. Such 
an  approach  is  particularly  relevant  for  targets  for  which  this  can  be 
assessed quantitatively.   

  For investment milestones, to the extent that it is possible to evaluate the 

share of what has been achieved.  

2)  Upward  adjustments  of  the  corrected  unit  values  are  applied  if  the 
investment  is  of  major  importance  to  justify  any  of  the  ratings 
underpinning the positive assessment of the RRP’. 

Reforms 

Coefficients applied to the unit value 

1)  A  coefficient  of  5  is  applied  for  milestones  and  targets  related  to  the  entry 
into force of a reform  or  the final  step for the implementation of a  non-
legislative reform.  

2)  A coefficient of 0.5 is applied for any other milestones and targets, such as 
the  ones  related  to  intermediary  steps  before  a  milestone  related  to  the  entry 
into  force  of  a  given  reform  (e.g.  publication  of  a  report)  or  to  ex-post 
procedural steps (e.g. evaluation of a reform). 

Adjustment of the corrected unit value 

1)  Upward adjustments of the corrected unit values are applied if: 

  The  implementation  of  the  reform  is  considered  by  the  Commission  of 
particular  importance  to  justify  the  rating  for  addressing  all  or  a 
significant  subset  of  challenges  identified  in  the  relevant  country-
thereof  and 
including 
specific  recommendations, 
recommendations  made  pursuant  to  Article  6  of  Regulation  (EU)  No 
1176/2011  where  appropriate,  addressed  to  the  Member  State  concerned, 
or challenges identified in other relevant documents officially adopted by 
the Commission in the context of the European Semester. 

fiscal  aspects 

2)  Downward  adjustments  of  the  corrected  unit  values  are  applied  in  the 

following cases:  

16 

 
 
  The  reform  is  of  less  importance  to  justify  any  of  the  ratings 

underpinning the positive assessment of the RRP. 

  For  reform  milestones  covering  one  or  more  than  one policy  objective 
or  dimension,  a  proportional  adjustment  will  be  applied  if  the  policy 
objective  of 
the 
objectives/dimensions  of  the  milestone  are  met  and  others  are  not.  In 
considering such a downward adjustment, the substantive progress towards 
the achievement of the overall objective of the reform will be assessed.   

is  partly  met  or 

the  milestone 

if  some  of 

Measures related to audit and control 

To  ensure  the  effective  use  of  RRF  funds  and  protect  the  financial  interests  of  the 
Union, the  non-fulfilment  of milestones or targets related to  a Member State’s  audit 
and  control  system  that  were  necessary  for  complying  with  Article  22  of  the  RRF 
Regulation  shall  lead  to  the  suspension  of  the  full  instalment  and  all  future 
instalments. 

II. 

Final remarks 

The  suspension  cannot  go  beyond  the  full  amount  of  the  instalment,  except  in  the  case  of 
non-fulfilment  of  milestones  and  targets  related  to  a  Member  State’s  control  system.  The 
Commission can review and amend this methodology as it gathers more experience with its 
application.  

In accordance with the RRF Regulation, measures that do not respect the principle of 'do no 
significant  harm'  (DNSH)  are  not  eligible  under  the  Facility.  Moreover,  the  milestones  and 
targets  of  measures  found  in  breach  of  DNSH  requirements  would  not  be  considered 
satisfactorily  fulfilled,  and  this  methodology  would  apply  to  determine  the  amount  to  be 
suspended. 

17