COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Portugal Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10149/2021; ST 10149/2021 ADD 1) of 6 July 2021 on the approval of the assessment of the recovery and resilience plan for Portugal
Date: 2023-09-22
Institutions: European Commission, Secretariat-General
Subjects: EU loan, Portugal, economic recovery, economic reform, energy policy, fiscal policy, investment, stability pact, stability programme, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 22.9.2023  SWD(2023) 318 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Portugal Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10149/2021; ST 10149/2021 ADD 1) of 6 July 2021 on the approval of the assessment of the recovery and resilience plan for Portugal {COM(2023) 555 final}  
 
 
Table of contents 
1. 

Executive summary ............................................................................................................................... 2 

2.  Objectives of the modification of the plan ........................................................................................... 3 

2.1.  Main newly emerged challenges .................................................................................................. 3 

2.2.  Main elements of the modified RRP and REPowerEU chapter ..................................................... 4 

3. 

Summary of the assessment of the plan ............................................................................................ 13 

3.1. 

Comprehensive and adequately balanced response to the economic and social situation ...... 13 

3.2. 

Link with country-specific recommendations and the European Semester ............................... 15 

3.3.  Growth potential, job creation, economic, institutional and social resilience, European Pillar of 
Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence ...... 18 

3.4. 

The principle of ‘do no significant harm’ .................................................................................... 19 

3.5.  Green transition .......................................................................................................................... 20 

3.6. 

Digital transition .......................................................................................................................... 21 

3.7. 

Lasting impact of the plan ........................................................................................................... 22 

3.8.  Milestones, targets, monitoring and implementation................................................................ 23 

3.9. 

Costing ........................................................................................................................................ 24 

3.10.  Controls and audit ....................................................................................................................... 26 

3.11.  Coherence ................................................................................................................................... 26 

3.12.  REPowerEU ................................................................................................................................. 31 

3.13.  Cross-border or multi-country dimension or effect ................................................................... 32 

ANNEX I: Climate tracking and digital tagging ........................................................................................ 34 

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1.  EXECUTIVE SUMMARY 

Portugal’s  substantial  post-pandemic  economic  recovery  fuelled  by  a  strong  rebound  in 
tourism has slowed. The Portuguese  GDP grew strongly in 2021 and 2022 and is expected to 
continue  growing  moderately  in  the  medium  term.  Labour  market  developments  are  positive, 
although youth unemployment remains high and regional disparities persist. Despite limited direct 
effects,  the  indirect  effects  of  Russia’s  invasion  of  Ukraine  are  significant,  due  to  Portugal’s 
dependency on imported fossil fuels.  

Portugal submitted a modified recovery and resilience plan, which reflects the increase in its 
final allocation, along with a REPowerEU chapter that contains measures to accelerate the 
green transition and decrease reliance on fossil fuels. For the modification of its RRP, Portugal 
relied  on  four  legal  bases.  First,  the  modification  considers  the  updated  maximum  financial 
contribution  published  on  30  June  2022  in  accordance  with  Article  18(2)  of  Regulation  (EU) 
2021/241 that led to an increase in Portugal’s  maximum financial contribution from EUR 13.9 
billion to EUR 15.5 billion. Second, the modification also relies on a request of additional loans in 
accordance  with  Article  14(2)  of  Regulation  (EU)  2021/241.  Third,  several  elements  of  the 
modification are built upon the legal basis of Article 21(1) of Regulation (EU) 2021/241, having 
considered  delays  due  to  objective  circumstances,  and  having  made  a  reasoned  request  to  the 
Commission  to  make  a  proposal  to  amend  the  Council  Implementing  Decision.  Finally,  in 
accordance with Article 21c of Regulation (EU) 2021/241 to include additional resources from 
ETS revenues and the Brexit Adjustment Reserve (BAR), Portugal included a REPowerEU chapter 
in its recovery and resilience plan.  

The modifications submitted by Portugal under Article 14(2), Article 18(2) and Article 21(1) 
of Regulation (EU) 2021/241 affect 17 out of the 20 components of the initial plan. Portugal 
also requested to rectify some clerical errors. No investment or reform has been removed from the 
initial recovery and resilience plan. Under Article 18(2) and Article 14(2), Portugal proposes 32 
new or scaled up investments and five new reforms. The proposed additional reforms concern the 
simplification and enhancement of the efficiency of the social protection system and  of the tax 
system, the promotion of circular economy and waste management, and further boosting the digital 
transition of the public administration. Under Article 21(1), Portugal proposes to modify several 
investments  to  factor  in  the  effects  of  supply  chain  disruptions  and  higher  costs.  Amendments 
relate notably to the postponement of the timeline for completion of milestone and targets.  

The REPowerEU chapter contains measures to help address the key energy challenges that 
Portugal  is  currently  facing  and  to  increase  Portugal’s  renewable  energy  potential.  The 
proposed measures comprise six reforms and 16 investments, focussing on energy efficiency in 
buildings,  green  industry,  renewables  and  renewable  gases,  sustainable  transport,  and  the 
electricity grid. The proposed reforms range from streamlining the permitting of renewables to the 
adoption of a biomethane action plan and a set of legislative actions which will help the take-up 
of biomethane and renewable hydrogen in the country. The chapter also includes strategic reforms 
and investments to decarbonise transport both in the mainland and in the autonomous regions, to 
improve green skills, to set up a scheme for financing the production of net-zero technologies, to 
scale up an existing investment in renewable gases, as well as to build storage capacity to increase 
the flexibility of the energy system. Additional investments in the chapter aim at strengthening 
energy efficiency in residential, service and public buildings, combined with the development of 

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a one-stop-shop model for energy efficiency interventions. In addition, an observatory for energy 
poverty will be set up to monitor and help setting policies to aid households in need. Finally, the 
chapter contains measures aiming at decarbonising industry in Portugal.  

The REPowerEU measures will help reduce energy demand and increase renewable energy 
and gases production, hence contributing to the resilience and sustainability of the Union’s 
energy system and to the diversification of the energy supply of the EU. The Portuguese RRP 
will support building further flexibilities in the electricity network, increasing the resilience and 
security  of  the  electricity  system  of  the  EU.  Investment  in  the  green  industry  to  produce 
technologies related to renewable energy, decarbonisation, and energy efficiency will also support 
the security of supply of critical technologies for the green transition of the Union.  

Based on the assessment of the submitted modification and the REPowerEU  chapter,  the 
Portuguese modified plan receives an A-rating on all criteria, except for costing, where the 
plan receives a B-rating (unchanged from the original plan assessment).  

(1) 
Balanced 
Response 

(2) 
CSRs 

(3) 
Growth, 
jobs… 

(4) 
DNSH 

(5) 
Green 
target 

(6) 
Digital 
target 

(7) 
Lasting 
impact 

(8) 
M & T 

(9) 
Costing 

(10) 
Control 
Systems 

(11) 
Coherence 

(12) 
REPowerEU 

(13) 
Cross-
border  

A 

A 

A 

A 

A 

A 

A 

A 

B 

A 

A 

A 

A 

2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN 

2.1. Main newly emerged challenges 

In 2022, Russia’s invasion of Ukraine led to a surge in energy and commodity prices in the EU 
and  significantly  affected  Portugal  indirectly  via  global  supply  chain  disruptions  and  high 
commodity prices, constraining growth. Notwithstanding the various support measures adopted by 
Portugal to cushion the impact of energy price inflation on households and businesses, inflation 
remained high at +8.1% in 2022. After a peak in the first quarter of 2022, growth rates slowed 
down in the following quarters due to supply bottlenecks, rising energy and commodity prices, 
and  supply  shortages.  While  Portugal’s  public  finances  improved  in  2022,  the  country  faces 
macroeconomic imbalances, which are assessed in the in-depth review1, related to high level of 
public,  private  and  external  indebtedness.  In  the  context  of  Portugal’s  current  challenges,  the 
proposed modification of its RRP is twofold: including a REPowerEU chapter  in the plan; and 
modifying existing measures in line with the requirements of the RRF Regulation.  

The Portuguese modified recovery and resilience plan adds a new REPowerEU chapter pursuant 
to Article 21(c) of the RRF Regulation covering measures related to energy efficiency in buildings, 
green industry, renewables and renewable gases, sustainable transport, and the electricity grid. It 
includes  reforms  and  investments  to  deliver  on  the  REPowerEU  objectives.  This  chapter  will 

1 In-depth review for Portugal, SWD(2023) 641, 23 May 2023 

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further enhance Portugal’s renewable energy potential, reduce energy demand and help address 
the  current  decarbonisation  challenges, 
the  ‘energy’ 
recommendation addressed to Portugal in 2022 in the framework of the European Semester. 

in  particular 

identified 

those 

in 

Pursuant to Article 18(2) of the RRF Regulation, Portugal has requested modifications to its RRP 
due to the upward revision of its maximum financial contribution, from EUR 13.9 billion to EUR 
15.5 billion. The increase is part of the June 2022 update to the RRF allocation key. Portugal has 
also  requested  additional  EUR  3.2  billion  in  loans  pursuant  Article  14(2).  To  support  the 
investments  and  reforms  in  the  REPowerEU  chapter,  Portugal  has  requested  to  transfer  all  its 
remaining  provisional  allocation  from  the  resources  of  the  Brexit  Adjustment  Reserve  to  the 
Facility2 (EUR 81.4 million) and to use the revenue from the emission trading system3 (EUR 703.4 
million).  Beyond  the  REPowerEU  chapter,  the  revised  RRP  includes  32  new  or  scaled  up 
investments and six new reforms across several components of the plan and new RRF funding will 
also cover the cost increases faced by Portugal. Overall, the total estimated costs of the modified 
plan, including the REPowerEU chapter, amounts to EUR 22.2 billion. 

Pursuant to Article 21(1) of the RRF Regulation, Portugal requested to amend existing measures 
of the plan based on objective circumstances. These include the need to  factor in  supply chain 
disruptions and higher costs due to the high inflation experienced in 2022 and 2023.  

Overall, Portugal increased by 8.15% the estimated costs of its total initial plan, an increase equal 
to  EUR 1.3 billion. A corresponding amount in loans is requested to cover those higher financial 
needs. To avoid requesting support for the same measure partly with the financial contribution and 
partly with loans, Portugal shifted eleven measures (for a total amount of EUR 924 million) of the 
existing plan from the non-repayable to the loan support; and allocated only EUR 37 million from 
the additional financial contribution to cover for the resulting difference in costs for the measures 
supported by the financial contribution.  

2.2. Main elements of the modified RRP and REPowerEU chapter 

Component 1 National Health Service 

Under Article 18(2), Portugal proposes a new investment and the reinforcement of the investment 
C01-i01: Primary Health Care with more answers. The new investment consists in the acquisition 
of  heavy  medical  equipment  for  hospitals  of  the  National  Health  Service.  The  reinforcement 
consists in the construction of 24 additional health care units and the renovation of another 21. 

2 Article 4a of Regulation (EU) 2021/1755 of the European Parliament and of the Council of 6 October 2021 
establishing the Brexit Adjustment Reserve (OJ L 357 8.10.2021, p. 1). 
3 Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for 
greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC (OJ L 
275, 25.10.2003, p. 32–46). 

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Under Article 21, Portugal proposes to amend five investments. The main amendment refers to 
diversion  of  grants  scheduled  to  be  used  for  the  acquisition  of  equipment  in  the  East  Lisbon 
Hospital towards the construction of part of the same hospital.  

Component 2 Housing  

Under Article 21, Portugal proposes to modify the six investments in this component. The main 
modifications  relate  to  the  reduction  of  intermediate  targets  and  amending  the  scope  of  the 
investments (e.g., change to the number of dwellings under intervention).  

Under Article 14(2), Portugal proposes to scale up the loan financed investment (C02-i06: Student 
accommodations at affordable prices) with 3 000 additional beds and the shift of 3 640 houses 
under  the  support  for  social  housing  (C02-i01:  Support  Programme  for  Access  to  Housing)  to 
loans. Under Article 18(2), Portugal also proposes two additional investments, which consist in 
the allocation of 145 parcels of land aiming to enable the selected candidates to construct their 
own houses at affordable prices, and the construction of 126 new social houses, both taking place 
in the Autonomous Region of the Azores. 

Component 3 Social responses  

Under Article 21,  Portugal  asks  to  modify  three investments,  delaying some  measures.  For the 
investment C03-04-RAA: Implementing the Regional Strategy for Combatting Poverty and Social 
Exclusion, Portugal proposes to decrease the target of Social Integration Income (RSI) families in 
Azores receiving training from 13 000 families to 4 000 individuals, albeit maintaining the same 
number of trainings.  

Under Article 18(2), Portugal proposes to scale up two investments and add one investment. The 
first scaled-up investment provides for the creation of additional places in social care centres and 
additional  equipment  for  Home  Support  Services  in  mainland  Portugal.  The  second  scaled  up 
investment provides for additional places to the investment Ageing in Place in the Autonomous 
Regions of the Azores. A new investment for the expansion and renovation of elderly care centres 
in Azores is proposed.  

Portugal  also  includes  an  additional  reform  to  simplify  Portugal’s  social  security  system  toa 
enhance its effectiveness and improve the take-up of social benefits. 

Component 4 Culture  

Under Article 18(2), Portugal proposes to scale up the two investments. The scale up of the first 
measure, C04-i01: Cultural Networks and Digital Transition – Digital Archive of Media Bodies 
consists in  the digitisation of audio-visual  material  with  historical,  cultural,  social and political 
relevance and making it publicly available. The scale up of the second measure, C04-i02: Cultural 
heritage consists in (i) the rehabilitation, conservation and restoration of 29 historical and cultural 
sites, and (ii) the construction of a new building for the National Archive of Sound. 

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Component 5 Investment and Innovation 

Under Article 21, Portugal proposes to modify two investments. The timeline for the targets for 
the Banco Portugues de Fomento’s capitalisation fund (C05-i06: Capitalisation of companies and 
financial resilience/Banco Português de Fomento) is notably modified. Other changes include (i) 
the reduction of supported farm-restructuring projects from 200 to 178 (C05-i05-RAA: Economic 
Recovery  of  Azorean  Agriculture);  and  (ii)  postponement  due  to  cost  increases  of  the 
construction/requalification  of  three  slaughterhouses  in  the  Azores  (C05-i05-RAA:  Economic 
Recovery of Azorean Agriculture). 

Under Article 18(2), Portugal proposes to include two new investments): (i) a credit support and 
guarantee scheme for enterprises in Madeira (C05-i07-RAM);  and (ii) the 'more digital science' 
programme (C05-i08: More Digital Science), consisting of 6 actions to accelerate the process of 
digital transformation and digitalisation of the national Science & Technology System.  

Portugal also proposes, under Article 18(2) as well as under Article 14(2), to support additional 
research  and  innovation  agendas  ('Mobilising  Agendas'  and  ‘Green  Agendas’)  to  increase  the 
number of products, processes or services.  

Component 6 Qualifications and Skills 

Under Article 18(2), Portugal proposes three new investments: (i) Capacities in science (C06-i06) 
with two programmes to promote research, knowledge transfer and internationalisation of higher 
education institutions, (ii) More digital Impulse (C06-i07) to support the modernisation of agrarian 
and  medical  sciences  and  strengthen  digital  skills,  (iii)  and  the  extension  of  the  Science  and 
Technology Centre building in Madeira (C06-i08-RAM). 

Under Article 14(2), Portugal proposes to build and renovate primary and secondary schools (C06-
i09: New or renovated schools). 

Under  Article  21,  Portugal  proposes  changes  to  three  existing  measures.  For  Modernisation  of 
vocational education and training institutions (C06-i01) Portugal proposes to add the network of 
tourism schools of Portugal as one of the beneficiaries and reduces the interim target (but not the 
final one) due to inflation, higher energy prices, and supply-chain issues. Portugal also proposes 
to  amend  one  investment  (C06-i02:  Investment  Commitment  for  sustainable  employment).  The 
measure provides hiring subsidies for permanent contracts and particularly benefits disadvantaged 
groups. Given the much better than foreseen labour market developments in Portugal, the program 
will need to be extended by an additional year to reach the same target. For the Adult Qualification 
and Lifelong Learning (C06-i05-RAA), Portugal proposes to specify further the beneficiaries.  

Component 7 Infrastructure 

Under Article 21, Portugal asks to modify one road project investment in the Azores by postponing 
the completion of the work by six months.  

Under Article 14(2), Portugal proposes to transfer two investments (C07-i03: Cross-border links 
and C07-i04: Business Reception Areas — Road accessibility) to be financed by loans. 

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Component 8 Forests 

Under Article 21, Portugal proposes changes to two investments. In investment C08-i04:  Means 
of preventing and combating rural fires, Portugal proposes to reduce the number of helicopters 
purchased  (because  smaller  helicopters  will  be  substituted  by  fewer  larger  helicopters)  and  to 
postpone the final target by two quarters for the installation of dual polarisation radars. The delay 
is attributed to litigation proceedings in the tendering process and supply chain constraints.  

In the investment C08-i05: MAIS Forest Programme, Portugal proposes to amend a measure to 
have a unified expenditure target for vehicles and equipment.  

Component 9 Water Management 

Under  Article  21,  Portugal  proposes  to  delay  measures  in  all  three  investments.  For  two  sub-
measures of one of the measures (C9-i01: Algarve Water Efficiency Regional Plan), due to the 
prolonged droughts, the design of the measure is also changed.  

For the Crato dam investment (C09-i02: Hydraulic multi-purpose enterprise of Crato), Portugal 
proposes to bring forward milestone 9.10 by 7 quarters to Q4 2023 instead of Q3 2025. At the 
same time, the final milestone 9.11 has been pushed back from Q4 2025 to Q2 2026.  

Moreover,  Portugal  proposes  to  split  the  Crato  dam  investment  in  two:  the  planning  phase 
(milestone  9.9)  and  the  construction  phase  (milestones  9.10  and  9.11).  Under  Article  14(2), 
Portugal proposes to transfer the construction phase to be financed by loans.  

Component 10 Sea 

Under  Article  21,  Portugal  proposes  modifications  for  three  investments.  For  the  Blue  Hub, 
Network  of  Infrastructure  for  the  Blue  Economy  (C10-i01),  Portugal  proposes  to  change  the 
'construction of a building' to ‘renovation of a building’. For the Atlantic defence Operations centre 
and Naval platform (C10-i03), Portugal proposes a delay along with amendments to the measure 
description to remove the purchase of the Remotely Operated Vehicle (ROV) and the Autonomous 
unmanned vehicle (AUV) due to the increased in costs of the Multi-naval Platform, as well as the 
removal  of  the  dual-fuel  engine  using  ammonia  due  to  a  lack  of  market  availability.  For  the 
investment C10-i04-RAA: Development of the ‘Cluster do Mar dos Açores’, Portugal requests the 
postponement of the three milestones.  

Under  Article  14(2),  Portugal  proposes  to  transfer  the  investment  C10-i03:  Atlantic  defence 
Operations  centre  and  naval  platform  to  be  financed  by  loans.  Portugal  also  proposes  a  new 
investment  on  Green Shipping  (C10-i07) which  includes interventions to  accelerate the energy 
transition of maritime freight and passenger transport. 

Under Article 18(2), Portugal proposes to scale up the measure on the Development of the Cluster 
do Mar dos Açores (C10-i04-RAA) with the acquisition of two additional modules. Portugal also 
proposes two  new investments. The investment  C10-i05-RAA:  Energy transition, digitalisation 
and reduction of environmental impact in the fisheries and aquaculture sector will support the 
financing of projects aimed at innovation, process modernisation, carbon footprint reduction and 
the circular economy throughout the fisheries and aquaculture sector in the Azores. The investment 

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C10-i06-RAM: Oceanic technologies addresses infrastructure needs in marine scientific research 
in Madeira. 

Component 11 Decarbonisation of Industry 

Under Article 18(2), the investment C11-i01: Decarbonisation of industry is scaled-up to support 
additional projects. 

Component 12 Bioeconomy 

Portugal proposes a new reform (C12-r39: Promoting circular economy and more efficient waste 
management)  to  promote  the  circular  economy  and  to  improve  the  waste  management  notably 
through the introduction of legal framework for the establishment of a deposit and refund system 
for packaging and metals.  

Component 14 Hydrogen and Renewables 

Under Article 21, Portugal proposes to modify the three investments. For the investment C14-i01: 
Hydrogen and renewable gases, Portugal proposed to postpone the final target because of delays 
in the delivery of electrolysers. In addition, Portugal proposes to reduce the final target from 264 
MW of renewable gases produced to 200 MW, due to inflation. For the investments C14-i02-RAM: 
Renewable  electricity  potentiation  in  the  Madeira  Archipelago  and  C14-i03-RAA:  Energy 
transition in the Azores, Portugal proposes to delay the targets due to supply chain issues.  

Component 15 Sustainable Mobility  

Under Article 21, Portugal proposes to change four measures. The expansion of the Lisbon metro 
network (C15-i01) includes delays with the final target being pushed back due to injunctions and 
other  technical  difficulties.  Similarly,  the  expansion  of  Porto  metro  network  (C15-i02)  has 
milestones postponed due to litigation issues. Concerning the Light Rail Transit Odivelas – Loures 
(C15-i03), Portugal proposes a redesign of the measure. The Boavista bus rapid transit in Porto 
(C15-i04) is being delayed by three quarters due to supply chain issues, including the delivery of 
electrolysers and buses.  

Under  Article  14(2),  Portugal  proposes  to  transfer  the  investment  C15-i03:  Light  Rail  Transit 
Odivelas - Loures to be financed by loans. 

Under Article 18(2), Portugal proposes a new investment (C15-i06: Digitisation of Rail Transport) 
to help digitalise rail transport by replacing electronic signalling systems.  

Component 16 Enterprises 4.0 

Under Article 21,  Portugal  proposes  to  modify  three  measures.  In investment  C16-i01:  Digital 
Empowerment of Enterprises, Portugal proposes to reduce the target of training participants having 
completed a digital skill training module in the Portugal Digital Academy from 800 000 to 125 000 
and to also open the program to the general population. Portugal proposes to monitor the creation 
of 50 MOOC (massive open online course) on digital skills and to monitor the delivery of 500 000 
diagnostic  of  digital  skills.  For  the  sub-measure  Employment  +  Digital  fully  online  training  is 
added in addition to physical training, maintaining the same level of course requirements. For the 

8 

 
 
 
 
 
measure Digital transition of enterprises (C16-i02) Portugal requests to delay two targets by one 
year  and  to  reduce  three  targets  (related  to  test  bed  pilot  products  and  services  and  to  SMEs 
supported by digital commerce accelerators) because of cost increases, need to redesign the actions 
and lower than expected take ups.  

Under Article 18(2), Portugal proposes to scale up the investment C16-i02: Digital Transition of 
Enterprises with  the  digitalisation of additional shopping  areas  in  the  action  Digital  commerce 
neighbourhood. Portugal also proposed three new investments: (i) an investment to support digital 
transformation projects (C16-i04: Industry 4.0); (ii) a system of incentives to digitalise firms and 
an  investment  in  two  scientific  and  technological  parks  in  the  Azores  (C16-i05-RAA:  Digital 
Capacity and Transformation of Enterprises in the Azores); (iii) and an investment to support the 
digital transition of enterprises in Madeira (C16-i06-RAM:  Enterprise 4.0).  

Component 17 Quality and Sustainability of Public Finances 

Portugal proposes a new reform of its tax system (C17-r40: Simplification of the Tax System). This 
reform  includes  the  creation  of  a  technical  unit  (Unidade  Técnica  de  Avaliação  Tributária  e 
Aduaneira, U-TAX) to monitor and evaluate new and existing tax benefits and to contribute to the 
design, implementation and impact evaluation of public policies in the area of taxation. The reform 
also presents measures for the revision of the tax benefits’ legal framework to simplify and reduce 
the number of existing tax benefits.  

Under Article 21 Portugal proposes to postpone by 6 months the conclusion of the implementation 
of the State Accounting Entity (milestone 17.9). 

Component 19 Digital Public Administration 

Under Article 21, Portugal proposes to modify three investments. For the investment on critical 
digital infrastructures (C19-i04: Efficient, secure and shared critical digital infrastructure), the 
intermediary milestone 19.12 is postponed by one quarter. For the digital transition of Madeira's 
public administration (C19-i05), Portugal  asks  to  implement  a private 5G network instead of a 
public one. Portugal also proposes to reduce (by around 15%) the number of public employees 
trained in the investment C19-i07: Public administration empowered to create public value.  

Under  Article  18(2),  the  revision  includes  the  introduction  of  a  new  investment  aiming  at 
supporting  the  implementation  of  smart  territory  policies  (C19-i08:  Intelligent  Territories).  In 
addition,  the  revision  includes  the  bolstering  of  three  investments  regarding  public  services  in 
citizen shops (C19-i01: Redesign of public and consular services), the digital transition in Azores 
(C19-i06-RAA)  and  the  development  of  data  management  and  processing  solutions  in  Madeira 
(C19-i05-RAM: Digital transition of Madeira’s public administration). 

Furthermore, two additional reforms are proposed. They aim at deepening the digital accessibility 
to public services (C19-r41: Access to Public Services: harmonise and consolidate-in-person and 
online access) and at enhancing the professional development and attractiveness of careers within 
the  public  service  (C19-r42:  New  evaluation  system  to  empower  and  rejuvenate  the  public 
administration workforce). 

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Component 20 Digital school 

Under Article 21, Portugal proposes to modify two measures. For the measure Digital transition 
in education (C20-i01) Portugal proposes to delay three targets by one year (from 2023 to 2024). 
For the measure Digital education in Azores (C20-i02-RAA) Portugal proposes to substitute some 
equipment under two targets and remove one requirement due to different needs than what was 
foreseen at the time of submitting the plan.  

Under Article 18(2), Portugal proposes to scale up two investments: (i) Digital education in Azores 
(C20-i02-RAA), and (ii) Accelerating the digitalisation of the education programme in Madeira 
(C20-i03-RAM).  For  both  investments,  the  aim  is  to  support  private  and  public  educational 
institutions  in  their  digital  transition  by  investing  in  digital  equipment,  digital  educational 
resources, and connectivity.  

REPowerEU chapter 

Under the REPowerEU chapter and based on Article 21c of Regulation (EU) 2021/241, Portugal 
has  proposed  measures  amounting  to  EUR  855  million  in  total  costs  using  the  financial 
contribution and loans for six new reforms, five upscaled investments and eleven new investments, 
focusing on energy efficiency in buildings, decarbonisation of industry, renewables and hydrogen, 
sustainable transport and the electricity grid.  

In terms of reforms, the chapter includes a reform to streamline permitting, including the creation 
of a one-stop-shop for licencing renewables projects and the training of public employees dealing 
with  renewables  permitting  (C21-r48:  Simplification  of  the  legal  and  regulatory  framework 
applicable to renewable energy projects), the adoption a set of actions which will help the take-up 
of  biomethane  and  renewable  hydrogen  in  the  country  (C21-r46:  Regulatory  framework  for 
renewable  hydrogen  and  C21-r47:  First  auction  for  sustainable  biomethane  and  bio-methane 
action plan), the creation of a new body to monitor and help setting policies to aid households in 
situation of energy poverty (C21-r43: National Energy Poverty Observatory), the development of 
energy efficiency one-stop shops for citizens (C21-r44) and a reform to promote green skills across 
several categories of workers and unemployed (C21-r45: Green Skills).  

The chapter includes investments to support and facilitate the development of renewables. Portugal 
proposes investments in renewables in Madeira and Azores (C21-i10-RAA: System of incentives 
for the purchase and installation of renewable energy storage systems in the Azores and C21-i11-
RAM: System of incentives for the production and storage of energy from renewable sources in 
Madeira and Porto Santo), a set of technical studies essential for the development of offshore wind 
energy (C21-i07: Technical studies for offshore energy potential), a digital one-stop-shop platform 
for  permitting  and  monitoring  renewable  energy  projects  (C21-i09:  One-stop-shop  for  the 
licensing  and  monitoring  of  renewable  energy  projects)  and  a  large-scale  investment  to  build 
storage capacity to increase the flexibility of the energy system (C21-i08: Network flexibility and 
storage).  

Portugal  also  proposes  to  invest  in  the  decarbonisation  of  transport,  supporting  notably  the 
purchase of zero-emission public transport buses in Madeira (C21-i13-RAM: Decarbonisation of 

10 

 
 
 
 
 
transport)  and  of  zero-emission  ferries  in  Azores  (C21-i15-RAA:  Acquisition  of  two  electric 
ferries),  the  installation  of  recharging/refuelling  stations  and  the  construction  of  a  funicular  in 
Nazaré (C21-i16: Nazaré Funicular) as well as the construction of a Bus Rapid Transit system in 
Braga (C21-i14: Bus Rapid Transit Braga).  

The REPowerEU chapter includes additional investments to increase energy renovation in public 
buildings in Madeira (C21-i04-RAM: Energy efficiency in public buildings in Madeira) and to set-
up of a scheme for financing  the production of  net-zero technologies  (C21-i05: Support to  the 
Development of Green Industry). 

Additional  funds  will  also  be  provided  for  scaling-up  measures  aimed  at  further  decarbonising 
industry processes and production (C21-i01: Scaled-up measure: Decarbonisation of Industry) as 
well as public transport (C21-i12: Scaled-up measure: Decarbonisation of Public Transport), at 
strengthening energy efficiency in residential, service and public buildings (C21-i02: Scaled-up 
measure:  Energy  efficiency  in  residential  buildings  and  C21-i03:  Scaled-up  measure:  Energy 
efficiency in buildings used by the services sector) and at increasing the production of renewable 
gases (C21-i06 Scaled-up measure: Hydrogen and renewable gases).  

Table 1: New and modified components and associated costs 

Component 
C1 National Health Service 
C2 Housing 
C3 Social Responses 
C4 Culture 
C5 Investment and Innovation 
C6 Qualifications and Skills 
C7 Infrastructure 
C8 Forests 
C9 Water Management 
C10 Sea 
C11 Decarbonisation of Industry 
C12 Bioeconomy 
C13 Energy Efficiency in Buildings 
C14 Hydrogen and Renewables 
C15 Sustainable Mobility 
C16 Enterprises 4.0 
C17 Quality and Sustainability of Public Finances 
C18 Economic Justice and Business Environment 
C19 Digital Public Administration 
C20 Digital School 

Status 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Unchanged 
Modified 
Modified 
Modified 
Modified 
Unchanged 
Modified 
Modified 

11 

Costs (EUR million) 
1,689 
3,226 
1,045 
319 
4,912 
1,959 
790 
615 
461 
389 
737 
145 
610 
406 
1,262 
763 
406 
267 
684 
674 

 
 
 
 
 
 
Component 
REPowerEU 

Status 
New 

Costs (EUR million) 
855 

Other elements not covered by assessment criteria 

The  description  of  the  plan  of  the  consultation  process,  security  self-assessment  for  digital 
investments and the planned communication strategy as reflected in the previous Staff Working 
Document (SWD) (2021) 146 final remains valid.  

Portugal  has  explained  that  several  measures  added  in  the  Recovery  and  Resilience  Plan  for 
Portugal, including the inclusion of the REPowerEU chapter, will have a positive impact on gender 
equality  and  equal  opportunities  for  all.  This  is  notably  the  case  in  Component  3  (Social 
Responses) where new measures have been included intended to contribute to ensuring sufficient 
and effective social protection for  all and  favour equal  participation  of  women and men in  the 
labour market. Strengthened investment of Component 1 (National Health Service) will further 
strengthen  person-centred  and  community-based  primary  health  care,  contributing  to  equality 
between women and men. The additional energy efficiency measures and the new National Energy 
Poverty  Observatory  are  expected  to  contribute  to  equal  opportunities  for  all  groups  of  the 
population and women in particular, as they are relatively more prone to energy poverty. Measures 
in  the  area  of  sustainable  transport  are  also  expected  to  increase  accessibility  for  persons  with 
disabilities and other mobility restrictions. 

State aid and competition rules fully apply to the measures funded by the Recovery and Resilience 
Facility. Union funds channelled through the authorities of Member States, like the RRF funds, 
become State resources and can constitute State aid. When this is the case and State aid is present, 
these measures must be notified and approved by the Commission before Member States can grant 
the aid, unless those measures are covered by an existing aid scheme or comply with the applicable 
conditions of a block exemption regulation, in particular the General Block Exemption Regulation 
(GBER) declaring certain categories of aid compatible with the internal market in application of 
Articles 107 and 108 TFEU4. When State aid is present and it requires notification, it is the duty 
of  the  Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance with Article 108(3) TFEU. In this respect, the State aid analysis carried out by Portugal 
in the recovery and resilience plan cannot be deemed a State aid notification. In as far as Portugal 
considers that a specific measure contained in the recovery and resilience plan entails de minimis 
aid or aid exempted from the notification requirement, it is the responsibility of Portugal to ensure 
full compliance with the applicable rules. 

4 Commission Regulation (EU) 2023/1315 of 23 June 2023 amending Regulation (EU) No 651/2014 declaring certain 
categories  of  aid  compatible  with  the  internal  market  in  application  of  Articles  107  and  108  of  the  Treaty  and 
Regulation (EU) 2022/2473 declaring certain categories of aid to undertakings active in the production, processing 
and marketing of fishery and aquaculture products compatible with the internal market in application of Articles 107 
and  108  of 
the  Treaty,  OJ  L  167,  30.6.2023,  p.  1–90,  available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1315. 

12 

 
 
 
 
 
 
 
 
3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

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

situation 

The modified RRP,  including  the REPowerEU  chapter,  continues  to  cover in  a comprehensive 
manner the six pillars structuring the scope of application of the Facility, i.e. (i) green transition, 
(ii) digital transformation, (iii) smart, sustainable and inclusive growth, (iv) social and territorial 
cohesion, (v) health and economic, social and institutional resilience, and (vi) policies for the next 
generation. The modified elements do not affect the assessment of this criterion compared to the 
original RRP. The coverage of the Portuguese revised plan’s components toward the six pillars is 
summarised in Table 2. For the components 1 to 20, the contribution to the six pillars has not been 
modified  in  this  table  compared  to  the  original  RRP.  All  pillars  are  covered  by  at  least  one 
component, while a component may contribute to several pillars. 

The measures included in the REPowerEU chapter contribute to the following pillars:  

Green transition 

The  RRP  revision  presents  reforms  and  investments  intending  to  deploy  to  decarbonise  its 
economy  and  to  strengthen  its  independence  and  energy  efficiency.  The  REPowerEU  chapter 
increases  the  ambition  of  five  investments  contained  in  the  initial  plan,  e.g.,  for  the  energy 
efficiency  in  service  and  residential  buildings.  In  addition,  it  also  contains  new  investments  in 
green  industry,  renewables  and  biogas,  sustainable  transport  and  the  electricity  grid.  Strategic 
reforms and investments are directed to the development of green skills in Portugal, the financing 
the  production  of  net-zero  technologies  and  the  building  of  storage  capacity  to  increase  the 
flexibility of the energy system. Such investments are combined with a set of reforms aimed at 
streamlining  permitting,  establishing  a  one-stop-shop  for  licensing  renewables  projects, 
accelerating the uptake of renewable gas and hydrogen in the country. The combination of reforms 
and  investments  of  the  REPowerEU  chapter  will  advance  Portugal’s  transition  to  a  greener 
economy. 

Smart, sustainable and inclusive growth 

The  additional  and  scaled-up  measures  will  also  boost  the  competitiveness  of  the  Portuguese 
industry. For instance, the revision includes a substantial scale up of research Agendas to foster 
innovation, notably for the green transition. A new measure aims at supporting the development 
of the Green Industry in Portugal, for industrial investments in strategic technologies and value 
chains  for  the  green  transition.  The  REPowerEU  chapter  also  provides  increased  funding  to 
support industrial SMEs to adopt low carbon processes and technologies and energy efficiency 
measures. These measures will enhance the productive capacity of the Portuguese economy, while 
promoting sustainable growth and climate adaptation though research and innovation. 

Social and territorial cohesion 

13 

 
 
 
 
 
Portugal  aims  at  establishing  a  National  Energy  Poverty  Observatory  to  monitor  and  support 
through targeted policies households in need. Households will also benefit from the services of 
Citizen Energy Spaces, which will help them implement energy efficiency interventions. These 
measures are expected to increase social cohesion. In addition, the REPowerEU chapter entails six 
new investments directed to the outermost regions of Madeira and the Azores. These investments 
will help the regions to build their energy independence, through the building of renewable energy 
generation  and  storage  capacity,  and  to  cut  their  emissions  thanks  to  the  improved  energy 
efficiency  and  the  decarbonisation  of  transport.  These  investments  will  favour  the  economic 
development of the regions and benefit the local communities.  

Table 2: Coverage of the six pillars of the Facility by the RRP components 

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14 

1 National Health Service 

2 Housing 

3 Social Responses 

4 Culture 

5 Investment and Innovation 

6 Qualifications and Skills 

7 Infrastructure 

8 Forests 

9 Water Management 

10 Sea 

11 Decarbonisation of Industry 

12 Bioeconomy 

13 Energy Efficiency in Buildings 

14 Hydrogen and Renewables 

15 Sustainable Mobility 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
16 Enterprises 4.0 

17 Quality and Sustainability of Public 
Finances 
18 Economic Justice and Business 
Environment 

19 Digital Public Administration 

20 Digital School 

21 REPowerEU 

○ 

● 

● 

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● 

● 

● 

● 

● 

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● 

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● 

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● 

● 

● 

○ 

● 

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

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Portugal,  its  modified 
recovery  and  resilience  plan  continues  to  represent,  to  a  large  extent,  a  comprehensive  and 
adequately  balanced  response  to  the  economic  and  social  situation,  thereby  contributing 
appropriately to all six pillars referred to in Article 3 of the RRF Regulation, taking the specific 
challenges and the financial allocation of Portugal into account. This would warrant a rating of 
A under the assessment criterion 2.1 in Annex V of the RRF Regulation. 

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

The  addendum  of  the  plan  along  with  the  REPowerEU  chapter  and  the  additional  loan 
request, is addressing a significant subset of challenges identified in the European Semester. 
As the maximum financial allocation for Portugal has been adjusted upwards and as the size of the 
plan  increased  following  an  additional  loan  request  intended  to  be  used  not  exclusively  for 
REPower objectives, all 2022 and 2023 structural recommendations are considered in the overall 
assessment.  In  the  2022  and  2023  Country  Specific  Recommendations  (CSRs),  Portugal  was 
recommended to act on four main policy areas. Portugal’s tax and social benefit systems requires 
improvement  in  their  effectiveness,  by  simplifying  both  frameworks  and  strengthening  the 
efficiency of their respective administrations (CSR 1.5 2023; CSR 1.4 2022; CSR 2.2 2020; CSR 
2.4  2019).  Portugal  also  would  benefit  from  to  strengthening  the  transition  towards  a  circular 
economy with particular focus on waste prevention, recycling and reuse (CSR 3 2022 and 2023). 
CSR 4 2022 and 2023 relates to the reduction in reliance on fossil fuels (CSR 4.1 2022 and 2023), 
including in the transport sector (CSR 4.2 2022) and the acceleration of deployment of renewables 
through the upgrade of energy infrastructure and electricity storage (CSR 4.3 2022 and 4.4 2023). 
Streamlining permitting of renewables (CSR 4.4 2022 and 4.2 2023), strengthening the incentive 
framework for energy efficiency in buildings (CSR 4.5 2022 and 4.6 2023) and increasing energy 
connections (CSR 4.6 2022 and 4.3 2023) should also be prioritised.  

The modified RRP includes new measures with the objective to improve the effectiveness of 
the  tax  and  social  protection  system,  also  promoting  the  long-term  sustainability  of 
Portugal’s public finances (CSR 1.5 2023; CSR 1.4 2022; CSR 1.1, 1.2 and 1.4 2021; CSR 2.4 
2019; CSR 2.2 2020). Under Component 17 – Quality and Sustainability of Public Finances, the 
modified  RRP  includes  a  new  fiscal-structural  reform  on  the  simplification  of  Portugal’s  tax 

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
system, with a focus on tax benefits. It defines the creation of a permanent technical tax policy unit 
(Unidade  Técnica  de  Avaliação  Tributária  e  Aduaneira,  U-TAX)  with  the  mandate  to 
systematically monitor and evaluate tax benefits, and to contribute to the design, implementation 
and impact evaluation of public policies in the area of taxation. The legal framework of tax benefits 
is  also  foreseen  to  be  revised  under  cost-benefit  considerations  based  on  the  recommendations 
formulated by U-TAX. This reform is also expected to contribute to the long-term sustainability 
of Portugal’s public finances. A new reform on Component 3 – Social responses aims at improving 
the effectiveness of the social protection system, improving its adequacy, coverage and take-up. 
These objectives are to be achieved via the simplification of the social benefit system, with the 
creation  of  a  Unique  Social  Benefit  (Prestação  Social  Única)  and  the  revision  of  its  legal 
framework (Código das Prestações Sociais). 

A new measure in the modified RRP contributes to the transition towards a circular economy 
(CSR  3  2022  and  2023).  The  reform  promotes  circular  economy  and  more  efficient  waste 
management  by  harmonising  the  definition  for  the  eco-modulation  in  financial  benefits  in 
integrated  systems  and  the  review  of  the  Waste  Management  Rate  (WSR)  as  well  as  the  legal 
framework establishing a deposit and refund system for non-reusable plastic bottles, ferrous metals 
and aluminium. 

Various new measures contribute to the reducing the reliance on fossil fuels, including the 
entire  REPowerEU  Chapter  (CSR  4.1  2022  and  2023).  Other  additional  measures  in  the 
addendum targeting the reduction of fossil fuels include the interventions to improve efficiency in 
fuel consumption and energy of freight and transport vessels, and the interventions in fishing fleet 
and  energy  performance  of  the  aquaculture  sector  in  the  Azores  in  Component  10  –  the  Sea. 
Additionally, the measures relating to green buses, to the Nazaré funicular and to the BRT in Braga 
contribute to the reduction in fossil fuels specifically in the transport sector (CSR 4.2 2022). To 
accelerate  the  deployment  of  renewables,  upgrading  electricity  distribution  grids  is  targeted  in 
REPowerEU  by  the  investment  on  improving  the  flexibility  in  the  electricity  grid,  through  the 
installation of battery storage systems on the scale of transmission and distribution networks (CSR 
4.3 2022 and 4.4 2023). Together with the incentive systems for the production and storage of 
renewable energy in Madeira and the Azores, these measures contribute to investing in electricity 
storage (CSR 4.3 2022 and 4.4 2023). The reform simplifying the legal and regulatory framework 
for  renewable  energy  projects  complemented  by  the  one-stop-shop  for  the  licensing  and 
monitoring  of  renewable  energy  projects,  contribute  to  streamlining  permitting  procedure  for 
renewable  energy  (CSR  4.4  2022  and  4.2  2023).  The  scale-up  energy  efficiency  measures  in 
buildings and the energy efficiency interventions in cultural sites within Component 4 – Culture, 
complemented by reforms on the National Observatory on Energy Poverty and the Citizen Energy 
Space  within  REPowerEU,  all  contribute  to  strengthening  the  energy  efficiency  investments 
framework (CSR 4.5 2022 and 4.6 2023). The reform on green skills aims to develop a long-term 
training offer, contributing to the provision and acquisition of skills and competences needed for 
the green transition (CSR 4.7 2023). No measures in the modified plan aim to address the increase 
of energy interconnections (CSR 4.6 2022 and 4.3 2023). 

16 

 
 
 
 
 
Some new measures contribute at addressing other CSRs, including in areas on healthcare, 
social  protection  and  labour  market.  The  National  health  service  (SNS)  technological 
modernisation programme aims at addressing the resilience of the healthcare system by improving 
and modernising its diagnostic and therapeutic technologies (CSR 1.2 2020). Measures targeting 
effective social safety net include the scale up of affordable student housing and the new measure 
helping young people with self-construction of their household by providing aid for the preparation 
of land for construction as part of Component 2 – Housing, and the requalification and expansion 
of the network of  residential  structures for older people  from  Component  3 – Social responses 
(CSR 2.2 2022, CSR 2.4 2019). The measure relating to sustainable employment commitment in 
Component  6  -  Qualifications  and  skills  contributes  to  addressing  labour  market  segmentation 
(CSR 2.1 2019, CSR 2.1 2020) while the new training measures in Component 6 and Component 
19 - Digital Public Administration contribute to improve the skills level of the population (CSR 
2.2 2019 and CSR 2.3 2020).  

Some new measures support companies, especially through the investment to boost firms’ 
competitiveness  (CSR  2.4  2020),  including  the  scaling  up  of  mobilising  agendas  for  business 
innovation  in  Component  5  –  Investment  and  Innovation,  and  the  training  and  digital 
transformation  of  Azores  companies  and  the  Industry  4.0  measure  supporting  the  digital 
transformation and environmental sustainability of companies from Component 16 – Enterprises 
4.0. The measure on the capitalisation instruments for companies aims at helping the liquidity of 
firms  of  small  and  medium-sized  enterprises  (SMEs)  (CSR  3.1  2020).  Other  measures  target 
investments to further green and digital transformations including, but not limited to, the new green 
agendas  for  business  innovation  from  Component  5  –  Investment  and  Innovation  and  the  new 
measures  in  REPowerEU  relating  to  regulatory  frameworks  of  renewable  energy  and  the 
management  of  hydrogen  production,  as  well  as  the  modified  measure  on  digital  business  in 
Component  16  –  Enterprises  4.0  and  the  digitisation  of  rail  transport  in  Component  15  – 
Sustainable Mobility (CSR 3.4 2020). The reform for public service on consolidating the use of 
digital and face-to-face channels in Component 19 – Digital Public Administration, contributes to 
the  reduction  of  administrative  and  regulatory  burden  on  businesses  through  the  increased 
efficiency of public administrative processes (CSR 4.2 2019). 

Various measures contribute to addressing investment in research and innovation (CSR 3.1 
2019) including the scale-up of the research vessel in the Azores and the new research vessel in 
Madeira, within Component 10 – the Sea, and the scientific and technological pole of Madeira in 
Component 6 – Qualifications and skills while the measures on the agendas within REPowerEU 
and Component 5 – Investment and Innovation also contribute to addressing the CSR (CSR 3.1 
2019).  

Portugal’s modified RRP continues to address all or a significant subset of challenges identified 
in the relevant country specific recommendations (CSRs). The priorities of the plan are coherent 
with  progress  on  the  relevant  country-specific  recommendations.  As  a  result  of  the  proposed 
reforms and investments addressing the most imminent challenges to the Portuguese economy and 
society, the priorities of  the plan  focus  on the  relevant  issues  and  are expected to  significantly 
contribute to the resolution of these challenges. 

17 

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

3.3. Growth  potential,  job  creation,  economic,  institutional  and  social  resilience, 
European  Pillar  of  Social  Rights,  mitigating  the  impact  of  the  crisis,  and  social 
territorial cohesion and convergence 

The  modified  RRP  including  the  REPowerEU  chapter  continues  to  contribute  to  economic 
cohesion and to address vulnerabilities of the economy. The main contributions to both growth 
and  employment  are  expected  to  come  from  investments  and  reforms  concerning  innovation, 
education,  including  digital  skills  and  vocational  training,  the  decarbonisation  of  industry,  the 
digitalisation  of  enterprises,  the  capitalisation  of  businesses  and  housing,  which  are  now 
strengthened. Measures in the REPowerEU chapter are also expected to contribute to sustainable 
growth. It is the case for instance for the support to the green economy, to green skills and to the 
development of renewable energy sources. 

The modified RRP including the REPowerEU chapter continues to contribute to social cohesion. 
The  revised  RRP  includes  significant  strengthened  measures  to  address  long-standing  social 
challenges.  These  cover  the  responsiveness  and  accessibility  of  healthcare  and  long-term  care 
services,  and  the  access  to  affordable  and  social  housing.  Social  vulnerabilities  should  also  be 
addressed through provision of a wide range of social services focusing on the elderly, people with 
disabilities,  ethnic  minorities  and  migrants,  and  through  integrated  programmes  to  support 
disadvantaged communities in deprived metropolitan areas. A new reform will simplify the social 
benefits  system  to  facilitate  their  coverage.  In  the  REPowerEU  chapter,  a  new  National 
Observatory will also contribute to address energy poverty. Additional investments in sustainable 
public transport networks are also particularly relevant for disadvantaged commuting workers, and 
reinforce labour rights, especially for atypical labour contracts linked to the digital economy. These 
measures will help deliver on the implementation of the European Pillar of Social Rights Action 
Plan endorsed at the Porto Summit of 7 May 2021 and are expected to contribute to improving the 
levels of the indicators of the Social Scoreboard. 

Measures targeted at children and young people are also reinforced, such as measures to raise the 
capacity  of  kindergartens  and  childcare  services.  The  revised  RRP  should  also  foster  higher 
education  institutions  and  the  enrolment  in  tertiary  education  courses.  Additional  housing  for 
students is also created. Measures should also further support the integration of digital technologies 
in the primary and secondary education system with the use of digital resources in classrooms, the 
digitalisation of educational contents. 

The nature and extent of the proposed modifications to Portuguese recovery and resilience plan 
do not have an impact on the previous assessment (Rating of A) of the plan’s impact on the growth 

18 

 
 
 
 
 
potential, job creation, and economic, social and institutional resilience of the Member State, on 
contributing to the implementation of the European Pillar of Social Rights, including through the 
promotion of policies for children and youth, and on mitigating the economic and social impact of 
the  COVID-19  crisis,  thereby  enhancing  the  economic,  social  and  territorial  cohesion  and 
convergence within the Union, as reflected in SWD (2021)146. 

3.4. The principle of ‘do no significant harm’ 

Portugal’s  modified  recovery  and  resilience  plan  assesses  compliance  with  the  ‘do  no 
significant  harm’  (DNSH)  principle  for  each  of  the  six  objectives  under  Article  17  of  the 
taxonomy  Regulation.  The  assessment  follows  the  methodology  set  out  in  the  Commission’s 
technical  guidance  on  the  application  of  ‘do  no  significant  harm’  under  the  RRF  Regulation 
(2021/C 58/01). It covers the six environmental objectives within the meaning of Article 17 of 
Regulation (EU) No 2020/852. The environmental impact is assessed per reform or investment. 
All new and revised reforms and investments in Portugal’s revised recovery and resilience plan re 
reflected in ‘do no significant harm’ assessments. No measures of the REPowerEU chapter makes 
use  of  the  targeted  exemption  for  those  reforms  and  investments  that  contribute  to  the  first 
REPowerEU objective of improving energy infrastructure and facilities to meet immediate security 
of supply needs. 

Portugal’s modified recovery and resilience plan puts a particular focus on energy-efficiency 
renovations (e.g., in Components 1, 2, 3, 4, 5, 6, 13 and 16). While these have a positive impact 
on emission reductions, they normally create significant amounts of construction waste. Portugal 
ensures no significant harm to the circular economy objective by detailing in the plan for each of 
the measures that at least 70% (by weight) of the non-hazardous construction and demolition waste 
generated on the construction sites are set to be prepared for reuse, recycling and other material 
recovery.  

The modified plan also includes a number of regulatory reforms, including the simplification 
of  the  legal  and  regulatory  framework  applicable  to  renewable  energy  projects  and  the 
reform  on  mechanisms  for  the  development  of  biomethane.  The  DNSH  assessment  has 
confirmed  that  their  environmental  impacts  are  rather  negligible,  ensuring  that  they  do  no 
significant harm to any of the six environmental objectives. 

For some measures where calls for projects or calls for interest are necessary to select specific 
projects in the future, ensuring adherence with the ‘do no significant harm’ principle will 
require introducing specific safeguards in the milestones associated with each measure, to 
monitor the implementation of the measures. For instance, under Component 5 – Investment 
and  Innovation,  the  additional  innovation  and  green  agendas,  the  new  financial  instrument 
supporting  companies  in  Madeira  and  the  more  digital  science  measure  will  all  require  further 
safeguards  to  ensure  that  no  environmental  objective  is  affected  by  their  implementation.  To 
ensure compliance with the DNSH principle, the eligibility criteria of upcoming calls for projects 
are set to exclude harmful activities and require that only activities that comply with relevant EU 
and national environmental legislation can be selected. Another example is Component 10 – the 
Sea,  the  Green  shipping  measure,  Portugal  was  required  to  specify  that  none  of  the  vessels 

19 

 
 
 
 
 
renovated would carry fossil fuels and that the fuel used to run the vessels complied with RED II 
directive. 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in the modified Portugal’s recovery 
and  resilience  plan,  including  the  REPowerEU  chapter,  is  expected  to  do  significant  harm  to 
environmental objectives within the meaning of Article 17 of Regulation (EU) No 2020/852 (the 
principle of  ‘do no significant  harm’). This  would  warrant a rating of  A  under the assessment 
criterion 2.4 of Annex V to the RRF Regulation. 

3.5. Green transition 

The modification of the plan increased its contribution to the green transition, with respect 
to the initial assessment. The modified Recovery and Resilience plan continues to significantly 
contribute to the green transition, including biodiversity, as well as to the achievement of the Union 
2030 climate targets while complying with the objective of EU climate neutrality by 2050.  

The new measures introduced, together with the REPowerEU chapter, bring a significant effort to 
supporting  further  the  green  transition  of  Portugal,  while  the  measures  whose  ambition  was 
reduced due to increased costs do not impact the green transition ambition of the plan5. 

The main green investments included in the modified plan are: (i) the strengthening of Portugal’s 
scientific  and  technological  capabilities  through  the  deployment  of  ambitious  research  and 
innovation agendas based on business-academia consortia focusing on the green transition; (ii) the 
implementation  of  a  Bus  Rapid  Transit  (BRT)  system  in  the  city  of  Braga,  mostly  with 
decarbonised vehicles; (iii) the modernisation of 75 public educational establishments, promoting 
the construction and renewal of physical spaces aligned with the objectives of the green and digital 
transition;  (iv)  the  promotion  of  energy  renovation  and  resource  efficiency  through  different 
measures in privately owned residential buildings; and (vi) the introduction of means of flexibility 
in the public service electricity grid (RESP) to optimise and improve the flexible management of 
the electricity system. Such measures are expected to have lasting impact for the green transition. 

The climate ambition of the revised plan without the REPowerEU chapter increases compared to 
the initial plan and stands at EUR 8.37 billion or 39.2% of the revised RRF allocation, compared 
to 37.9% for the original plan.  

The  green  transition  contribution  of  the  REPowerEU  chapter  is  deemed  ambitious,  as  all  the 
investments  aim  at  reducing  the  reliance  on  fossil  fuels,  contributing  to  one  or  more  of  the 
RepowerEU objectives of increasing energy efficiency, fighting energy poverty, incentivising the 
reduction of energy demand, addressing internal and cross-border bottlenecks and accelerating the 
retraining of the workforce. The climate contribution of the REPowerEU chapter is of 91,1% of 

5 Annex I presents the detailed application of the climate tagging methodology for all measures and sub-measures 
with a climate contribution. 

20 

 
 
 
 
 
 
 
the total estimated costs of the measures included in the REPowerEU chapter, above the 37% target 
set out in the Regulation.  

In total, the whole Recovery and Resilience plan (including revised measures and the REPowerEU 
chapter)  contributes  for  41,2%  (EUR  9,15 billion)  of  Portugal’s  total  revised  allocation  to  the 
climate target, above the target of 37% required by the Regulation. 

Taking into consideration the assessment of all the measures envisaged, the modified recovery and 
resilience  plan,  including  its  REPowerEU  chapter,  is  expected,  to  a  large  extent,  to  make  a 
significant contribution to the green transition or to address the challenges resulting from it and 
ensures that at least 37% of its total allocation contribute to the climate target. At least 37% of 
the total estimated costs of the REPowerEU chapter contribute to the climate target. This would 
warrant a rating of A under criterion 2.5 of Annex V of the RRF Regulation. 

3.6. Digital transition  

Overall, the modified plan’s (excluding the REPowerEU chapter) contribution toward the 
digital objectives amounts to 21.1% of the plan’s allocation, and as such, the digital target of 
20% continues to be met6.  

As was the case in the existing plan, the most important contribution in the modified plan relates 
to  Component  6  –  Qualification  and  Skills,  Component  16  –  Enterprises 4.0,  Component  19  – 
Digital Public Administration and Component 20 – Digital School. As for the existing plan, other 
components  that  contribute  significantly  to  the  digital  objective  are  Components  20  –  Digital 
school,  Component  1  –  National  Health  Service  and  the  components  on  the  modernisation  of 
public administration (Components 17 to 19). Notably, Component 5 – Investment and innovation 
received a significantly higher allocation of resources that contribute to the digital transition.  

In the original plan 14 out of 20 components contained some measures that contribute to the digital 
transition.  Following  the  revision,  two  more  components  contribute  to  the  digital  transition: 
Component  15  –  Sustainable  mobility  with  a  measure  to  digitalise  the  railways  system  and 
Component  21  –  REPowerEU  with  a  one-stop-shop  digital  platform  for  the  permitting  and 
monitoring of renewable energy projects.  

The  measures  contributing  the  most  to  the  increased  ambition  in  the  digital  transition  include: 
Components 20 – Digital school, with measures to support the transition to digital education in the 
Autonomous Regions of Azores and Madeira; Component 16 – Enterprises 4.0, with additional 
measures to foster the digitalisation of businesses, in particular with the adoption of Industry 4.0 
technologies in the mainland and in the Autonomous Regions of Azores and Madeira; Component 
19  –  Digital  public  administration  with  additional  measures  to  manage  and  process  data  from 
different  sources  and  to  adopt  data-driven  public  policies;  Component  5  –  Investment  and 
innovation with additional measures to develop research and innovation agendas with a focus on 

6   Annex I presents the detailed application of the digital tagging methodology for all measures and sub-measures 

with a digital contribution. 

21 

 
 
 
 
 
 
 
the digital field, as well as to increase the digitalisation of scientific and technological research; 
Component 6 – Qualification and Skills with additional measures to provide computer services 
and  applications  for  digital  skills  and  inclusion  in  schools,  to  support  R&I  activities  related  to 
digitalisation, and to support the development of digital skills of persons already in employment. 

The measures in the modified Portuguese plan continue contributing to the digital transition or 
helping to address the related challenges and are aligned, at national level, with the Portugal 2030 
strategy.  The  modified  plan  continues  to  significantly  address  the  digital  transition  challenges 
faced  by  Portugal  in  the  areas  of  human  capital  and  digital  skills,  digitalisation  of  businesses, 
adoption of advanced digital technology, digital related innovation, digital public services. 

Taking into consideration the assessment of all the measures  envisaged, the modified Recovery 
and Resilience plan is expected, to a large extent, to make a significant contribution to the digital 
transition or to address the challenges resulting from it and ensures that at least 20% of its total 
allocation  (excluding  the  measures  in  the  REPowerEU  chapter)  contribute  to  support  digital 
objectives. This would warrant a rating of A under criterion 2.6 of Annex V of the RRF Regulation. 

3.7. Lasting impact of the plan 

The modified recovery and resilience plan includes new measures that are expected to have 
lasting positive effects on the Portuguese economy, increasing the ambition of the initial plan 
as a whole. The modified plan takes into account the increased grant allocation, the impact of the 
COVID-19 crisis, inflation and supply chain disruptions, and includes a new REPowerEU chapter 
which, in addition to the existing measures, is also expected to have lasting positive effects on the 
Portuguese economy and further boost its green transition.  

New or upscaled investments and reforms included in the revised plan are complementary to the 
existing ones, are in line with the country-specific recommendations and can be expected to have 
a  lasting  impact.  They  address  the  root  causes  of  the  challenges  identified  and  not  just  the 
symptomatic issues. New reforms aim at simplifying the social and tax benefit systems, promoting 
the circular economy and more efficient waste management, and reforming the public service to 
make it more efficient. New investments will, among other things, support the purchase of medical 
equipment which will increase the quality of diagnoses and treatments, and introduce technical 
innovation  in  the  national  healthcare  system.  They  will  also  increase  the  domestic  supply  of 
affordable student accommodation, thereby enabling better access to higher education. The support 
will be channelled also to public authorities to create a new, data-driven system for planning and 
managing cities and territories. In addition, comprehensive support will be dedicated to companies 
for their digital transition and environmental sustainability.  

The  impact  of  the  COVID-19  crisis,  inflation  and  supply  chain  disruptions  is  reflected  in  the 
modifications of existing measures. Inflation-driven cost increases have impacted the ambition of 
some of the pre-existing measures, without however affecting the long-lasting effects of the Plan.  

In  particular,  the  REPowerEU  measures  are  expected  to  contribute  to  the  green  transition  by 
supporting  the  enhancement  of  energy  efficiency  (e.g.,  through  the  “energy  efficiency  in 
buildings” measure), combatting energy poverty (among others, by developing and implementing 

22 

 
 
 
 
 
a citizen energy space model as well as a national energy poverty observatory), incentivising the 
reduction  of  energy  demand  (e.g.,  measures  on  the  decarbonisation  of  transports  and  on  the 
decarbonisation of industry), addressing internal and cross-border bottlenecks (through measures 
such  as  the  “green  mobilising  agendas”  and  the  implementation  of  a  low-emission  Bus  Rapid 
Transit in Braga), and accelerating the retraining of the workforce (e.g., measure on the support of 
the development of the green industry). All of these measures combined will have a lasting impact 
on the economy and society as a whole.  

The nature and extent of the proposed modifications to Portugal’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the lasting impact of the 
measures proposed by Portugal, as reflected in SWD (2021)146.  

3.8. Milestones, targets, monitoring and implementation  

The  task  force  Recuperar  Portugal  remains  the  structure  tasked  by  Portugal  with  the 
implementation, monitoring and reporting of the RRP. The task force has been granted greater 
decision-making autonomy with the Council Regulation no. 93/2022 of 18 October. In addition, 
the Decree-Law no. 61/2023 of 24 July aims at revising the composition and powers of the political 
coordination, monitoring and audit and control bodies of the governance model of the RRP, in 
order to clarify the levels of intervention of each of those bodies and to ensure that their respective 
competences  are  effectively  exercised.  The  above-mentioned  decree-law  broadens  notably  the 
tasks of the National Monitoring Commission and the Audit and Control Committee to strengthen 
the mechanisms for monitoring and better prevent duplication of financing, risks of conflicts of 
interest, corruption and fraud.  

The milestones and targets of the modified Portuguese recovery and resilience plan enable 
an adequate monitoring of the plan’s implementation. The performance of new reforms, new 
and scaled-up investments, as well as the investments included in the REPowerEU Chapter, will 
be captured by the achievement of milestone and targets monitored by each entity in charge of 
implementing the measures. The milestones and targets chosen – some of which build on existing 
targets  for  upscaled  measures  –  are  consistent  with  the  objectives,  cost  estimates  and 
implementation schedule of each measure and are reflected in specific qualitative or quantitative 
indicators.  

For reforms taking the form of a legislative act, the milestone is the publication on the Official 
Gazette (Diario da Republica), as in the case of establishment of Umer 2030 (RP-C14-r48), or the 
entry into force of the new piece of legislation, as in the case of the revision of competency profiles 
associated with performance assessments (TD-C19-r47). Such type of milestone allows to capture 
the  actual  implementation  of  new  provisions.  Other  milestones  for  reforms  are  based  on  the 
achievement of decisive steps in the implementation process, such as the approval by the Council 
of Ministers of the report on the creation of a Social Benefits Code (RE-C03-r48) or the publication 
of the ‘Biomethane action plan’ (RP-C14-r47). These milestones are clear and realistic as they 
reflect decisive steps towards the complete implementation of each reform.  

23 

 
 
 
 
 
The  REPowerEU  chapter  includes  a  set  of  43  new  milestones  and  targets  (reforms  will  be 
monitored by 11 milestones and 4 targets, investments by 12 milestones and 16 targets).  

Aside from the changes relating to the REPowerEU chapter and new reforms and investments, the 
adjustments made to the plan’s 341 original milestones and targets do not affect the  relevance, 
acceptability and robustness of the existing milestones and targets. In some cases, the amendments 
correct  clerical  errors  and  help  to  align  the  intent  of  the  original  plan  and  the  description  of 
investment and reforms with the content of milestones and targets to better assess the achievement 
of measures. The totality of milestones and targets for the revised plan sums up to 463, of which 
202 milestones and 261 targets.  

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

3.9. Costing  

Reasonable costs 

Portugal claimed cost increases for 69 measures  or sub-measures. For these measures and sub-
measures, the ambition of the final targets has been preserved in almost all cases, but a request was 
made to cover the increased costs with additional non-repayable support or loans. 

For 67 out of 69 measures Portugal justified the cost increases based on Eurostat official inflation 
data (three different indexes, for the years 2021 and 2022) and the European Commission inflation 
forecast. 

For 42 measures (40 in full and two partially), related to the construction of new buildings and or 
renovations  across  several  components  of  the  existing  RRP,  Portugal  claims  that  the  original 
milestones and targets are no longer attainable due to the widespread cost increases and shortage 
of  raw  materials  experienced  in  the  construction  sector.  For  these  investments,  the  Eurostat 
construction price index is used as a conservative proxy to estimate the expected cost increases 
and the corresponding need for additional resources. 

For 14 measures (13 in full and one partly), related to purchase of equipment or electric vehicles 
in  the  areas  of  healthcare,  social  services,  education,  among  others,  Portugal  claims  that  the 
original milestones and targets are no longer attainable due to the widespread cost increases and 
shortages  in  the  procurement  of  the  planned  equipment.  For  these  investments,  the  Eurostat 
producer price index is used as a conservative proxy to estimate the expected cost increases and 
the corresponding need for additional resources. 

For  another  12  measures  (11  in  full  and  one  partly),  related  to  measures  in  healthcare,  social 
services, housing, education, skills – among others – Portugal claims that the original milestones 
and targets are no longer attainable due to the widespread cost increases reflected in the general 
increase of prices and wages. For these investments, the Eurostat harmonised consumer price index 

24 

 
 
 
 
 
is used as a conservative proxy to estimate the expected cost increases and the corresponding need 
for additional resources. 

Overall,  the  evidence  provided  by  Portugal  for  the  67  measures  in  the  first  case  supports  the 
existence of objective circumstances that made the existing measures and their related milestones 
and  targets  no  longer  attainable.  Once  the  objective  circumstances  were  established,  the 
methodology  proposed  by  Portugal  to  estimate  the  related  cost  increases  is  assessed  to  be 
reasonable.  Based  on  official  inflation  statistics  and  forecasts,  they  are  correctly  applied  to  the 
updated  estimated  cost  profile,  taking  into  account  the  initial  inflation  forecast  assumed  in  the 
existing plan as well. 

For the other two measures, the metro in Odivelas-Loures and the naval platform, it is considered 
that Portugal provided a credible explanation of the objective circumstances that made the existing 
measures and their related milestones and targets no longer attainable. For both measures the cost 
increase computations proposed by Portugal are also considered reasonable as they are based on 
specific independent studies that document the extent of the increased costs. 

Regarding the new and scaled up investments, including those in the REPowerEU chapter, the cost 
estimates are deemed to be largely reasonable. Portugal provided an extensive list of documents 
to justify and explain the amounts proposed as new investments and gave explanations on how 
those  amounts  were  computed.  For  the  scaling  up  of  some  existing  measures,  estimates  and 
evidence were based on the 2021 cost estimates where unit costs are the same. 

Plausible costs  

Concerning  the  request  for  modifications  under  Article  21,  the  cost  increase  claims  made  by 
Portugal and the related cost increase calculations are assessed to be plausible, as they are based 
on third party indexes and studies. 

For  the  new  and  scaled  up  investments,  including  those  in  the  REPowerEU  chapter,  the  cost 
estimates have been deemed, to a medium extent, as plausible. Some investments lacked a clear 
explanation  as  to  how  the  past  projects  presented  as  the  basis  for  the  estimates  were  used  or 
adjusted to determine the cost estimate. 

No double Union financing 

Portugal  has  indicated  that  new  and  modified  measures,  including  those  in  the  REPowerEU 
chapter,  funded  under  the  RRF  will  not  be  financed  by  other  Union  funding.  Furthermore,  the 
systems set up to prevent, detect and correct double funding from the Facility and other Union 
programmes, as described in the previous Staff Working Document (SWD) (2021) 146, remain 
valid.  

Commensurate and cost-efficient costs 

The total cost of the modified RRP is commensurate to the expected social and economic impact 
of  the  envisaged  measures.  The  new  and  modified  measures  are  expected  to  help  effectively 
address  a  significant  subset  of  challenges  identified  in  the  country  specific  recommendations 
(CSRs) in accordance with the initial plan. In addition, new measures, including the REPowerEU 

25 

 
 
 
 
 
chapter are also expected to address challenges identified in climate and energy relevant CSRs. 
Furthermore, the modified plan is expected to strengthen social cohesion and social protection and 
the implementation of the European Pillar of Social Rights in line with the initial plan, while the 
new measures aim to bolster the green transition. Therefore, the modified RRP is assessed as being 
in line with the principle of cost-efficiency and is commensurate to the expected national economic 
and social impact.  

The justification provided by Portugal on the amount of the estimated total costs of the modified 
recovery and resilience plan is to a medium extent reasonable, plausible, in line with the principle 
of  cost-efficiency  and  is  commensurate  to  the  expected  national  economic  and  social  impact. 
Portugal provided sufficient information and evidence that the amount of the estimated cost of the 
reforms  and investments  of  the modified  recovery and resilience plan  to be financed under the 
Facility is not covered by existing or planned Union financing. This would warrant a rating of B 
under the assessment criterion 2.9 of Annex V to the RRF Regulation. 

3.10. 

Controls and audit 

In the context of the modification of the Portuguese Recovery and Resilience Plan (RRP), its audit 
and control system needs to be reassessed on the basis of criteria 2.10 of Annex V of the RRF 
Regulation. Since the original assessment, which was established on the proposed audit and control 
system, the Commission has had access to information on its actual implementation. This includes 
the preliminary findings of the audit on the protection of the financial interests of the Union (PFIU) 
and the findings of the combined system audit on milestones and targets and audit on milestones 
and targets performed by the Commission in Portugal.  

In  light  of  this  information,  the  Commission  considers  that  the  internal  control  system  of  the 
Portuguese RRP is overall adequate, but it has some deficiencies that must be addressed through 
dedicated audit and control milestones. These relate to the lack of a fraud risk assessment and the 
subsequent  action  plan  at  the  level  of  all  Portuguese  implementing  bodies  and  the  insufficient 
arrangements to cross-check the information related to the receipt of funds in order to avoid and 
detect double funding. 

Robustness of internal control system and distribution of roles and responsibilities 

The governance model of the Portuguese RRP was created by the Decree-law 29-B/2021, which 
defined the four levels of coordination of the RRP governance model, as follows: 

•  Strategic level of political coordination, ensured by the Interministerial Commission for 

the RRP; 

•  Monitoring level, ensured by the National Monitoring Commission; 

26 

 
 
 
 
 
 
 
 
•  Technical  coordination  and  monitoring  level,  carried  out  by  the  task  force  "Recuperar 
Portugal" (EMRP)7, the Development and Cohesion Agency, I. P. (Agency, I.P.), and the 
Planning,  Strategy,  Evaluation  and  International  Relations  Office  of  the  Ministry  of 
Finance; 

•  Audit and control level, ensured by an Audit and Control Committee (CAC). 

On 24 July 2023, the Decree-law 61/2023, altered the composition and competences of the political 
coordination, monitoring and audit and control bodies of the RRP, in order to clarify the levels of 
intervention  of  each  of  these  bodies  and  ensure  the  effective  fulfilment  of  their  respective 
competences. In addition, and in the context of the reprogramming and reinforcement of the RRP's 
ambition, it extended the powers of the National Monitoring Committee and the Audit and Control 
Committee. Finally, it clarified some rules applicable on double funding, established the system 
for recovering funding and clarified the procedure for the payment of the amount equivalent to the 
value added tax on projects financed by the RRP. 

The  national  management  of  the  recovery  and  resilience  plan  is  centralised  in  the  task  force 
Recuperar Portugal, Coordinating Body, and its execution is entrusted to a set of public entities, 
which  assumes  responsibilities  for  the  management  and  implementation  of  investments  at  a 
decentralised level. These are denominated direct or indirect beneficiaries. 

Considering the recommendations issued by the Inspectorate General of Finance - Audit Authority 
(IGF-AA), the Portuguese Court of Auditors and the opinions of the Audit and Control Committee 
(CAC),  the  task  force  Recuperar  Portugal  reviewed  and  updated  its  control  measures  and 
instruments. This includes the publication of the Code of ethics and conduct, Anti-Fraud Policy 
Statement, Technical Orientation n. 7, Whistleblower Procedure and the update of the Description 
of  the  Internal  Control  Management  System,  Management  Plan  for  Risks  of  Corruption  and 
Related Infringements, Risk Management Manual, Manual of Procedures (latest version January 
2023) and of the Declaration of Absence of Conflict of Interest. It should also be highlighted the 
publication of the Technical Orientations n. 8, 9, 10, 11, 12 and 13 after the communication of the 
preliminary findings of the two audit reports issued by the Commission mentioned above. These 
documents are available on EMRP’s website8. 

Adequacy of control systems and other relevant arrangements 

In order to mitigate and prevent situations of conflict of interest and with a view to strengthening 
the internal control system, according to the revised plan, the EMRP adopted the data mining tool 
Arachne, developed and made available by the Commission. In this sense, EMRP has updated the 
terms of the Declaration of Absence of Conflict of Interest to include the collection of personal 
data at the level of the date of birth of the beneficiaries and to mention that these personal data can 
be  used  in  order  to  identify  on  the  basis  of  a  set  of  risk  indicators  the  projects,  beneficiaries, 

7 Estrutura de Missao Recuperar Portugal. Created by the RCM 46-B/2021 and amended by RCM 93/2022. 
8 https://recuperarportugal.gov.pt/sistema-de-controlo-interno/ and https://recuperarportugal.gov.pt/orientacoes-
tecnicas/  

27 

 
 
 
 
 
 
 
contracts  and  contractors  likely  to  entail  risks  of  fraud,  conflict  of  interest,  double  funding  or 
irregularities. 

Other  initiatives  foreseen  in  the  revised  plan,  are  the  collaboration  protocols  signed  between 
EMRP  and  the  European  Public  Prosecutor’s  Office  (EPPO)  and  between  EMRP  and  Central 
Department for Investigation and Prosecution (DCIAP), and a think tank initiative with the same 
organisation  (DCIAP)  with  a  view  to  developing  strategies  to  prevent  and  combat  fraud  with 
European funds. 

At the level of the beneficiaries, protocols were established with the Professional Associations of 
Auditors (OROC) and Certified Accountants (OCC), with a view to ensuring their contribution to 
the monitoring and supervision of contracted investments, including the internal control systems 
of the RRP beneficiaries. Currently, the Commission is informed that 37 out of 68 beneficiaries 
have requested access to the Arachne tool. 

As  per  Article  22(1)  of  the  RRF  Regulation  and  Article  11(1)(a)  and  (b)  of  the  Financing 
Agreement, in order to protect the financial interests of the Union, Portugal is under the obligation 
to  regularly  check  that  the  financing  provided  has  been  properly  used  in  accordance  with  all 
applicable rules, and that any measure for the implementation of reforms and investment projects 
under the RRP has been properly implemented in accordance with all applicable rules in particular 
regarding the prevention, detection and correction of fraud, corruption and conflicts of interests, 
and  double  funding.  They  are  also  obliged  to  take  appropriate  measures  to  prevent,  detect  and 
correct  fraud,  corruption,  and  conflicts  of  interests,  and  double  funding  affecting  the  financial 
interests of the Union.  

As previously mentioned, during the PFIU audit performed by the Commission, it was noted as a 
systemic issue the lack of a fraud risk assessment for all the beneficiaries of the RRP. Corrective 
action is needed to address this significant weakness in key controls, affecting the reliability of a 
significant part of the internal control system to protect the financial interests of the Union.  

Adequacy of arrangements to avoid double EU funding  

On  28  July  2023,  EMRP  issued  a  new  Technical  Guidance  number  11  “Mitigating  the  risk  of 
double funding - RRP beneficiaries” considering the note on “Double funding under the Recovery 
and Resilience Facility”, issued by the Commission on 06.02.2023. This Guidance states that the 
risk of double funding is mitigated by combining three levels of checks: 

1st level - Systematic analyses of European funding from Portugal 2020 and Portugal 2030, 
carried out by the Agency, I.P.; 

2nd  level  -  Beneficiary  declarations,  based  on  the  Questionnaire/Declaration  of 
Commitment collected by the EMRP from the beneficiaries of the RRP; This questionnaire 
must be fill in at least annually (self-declaration). 

3rd  level  -  Monitoring  actions  and  control  actions  on  operations,  including  the  issue  of 
double funding, reflected through follow-up actions following systematic analyses by the 

28 

 
 
 
 
 
Agency,  I.P.  and  specific  control  actions  included  in  the  Recovering  Portugal  Control 
Action Plan (PACRP).  

The revised plan also states that a Transparency Portal, which was foreseen in the original plan, 
was set  up centralising  information  on European funds by integrating all systems  and schemes 
implemented in Portugal and covering the recovery and resilience plan.  

Following the audit performed by the Commission, it was identified that there are no cross-checks 
in place to verify the information provided by the beneficiaries in reply to the questionnaire and it 
is not clear how this information is used to effectively detect double funding.  In this sense, the 
arrangements described in the revised RRP to avoid double funding from the Facility and other 
Union programmes are in place, but some elements are still missing.  

Legal empowerment and administrative capacity of control function  

The  legal  empowerment  of  EMRP  and  of  the  actors  responsible  for  controls  (IGF-CAC)  are 
provided in Article 3(c)(d), Article 6(f)(g) and Article 7 of DL 29-B/2021, point 3 (h)(i)(j) of RCM 
46-B/2021 and RCM 93/2022.  

The administrative capacity of both the EMRP and the Audit Authority (IGF-CAC) are ensured. 
As per request of DG ECFIN’s R4 unit, the EMRP provided a list of staff on 16.05.2023 where it 
had 59 staff members with the necessary expertise and years of experience and 5 members to be 
recruited. According to page 8 of their Audit Strategy of 6 June 2022, the administrative capacity 
of the audit authority will be ensured either through an internal allocation, or through recourse to 
external auditors or experts hired. 

Conclusion 

The chapter on audit and control and the additional information provided gives a rather complete 
description of the arrangements for the implementation and control of the Plan in Portugal. The 
chapter provides the details for all the entities and gives reasonable assurance that there is a sound 
structure in place to monitor, implement and control the allocated funds from the RRF.  

However,  two  new  milestones  will  be  introduced  to  address  the  missing  elements.  The  first 
milestone requires an amendment in the financing contracts between the Coordinating Body and 
the implementing bodies to add a legal obligation to perform a fraud risk assessment and, where 
the fraud risk assessment identifies risks that are not addressed by the existing controls, to develop 
a subsequent action plan. The second milestone requires the introduction of effective systematic 
cross-checks on applications for potential funding within the RRF and between the RRF and other 
Union programmes. 

The arrangements proposed by Portugal in the modified recovery and resilience plan to prevent, 
detect and correct corruption, fraud and conflicts of interest when using the funds provided under 
the Facility, including the arrangements aimed to avoid double funding from the Facility and other 

29 

 
 
 
 
 
 
 
 
 
Union  programmes,  are  assessed  to  be  sufficient.  This  would  warrant  a  rating  of  A  under  the 
assessment criterion 2.10 of Annex V to the RRF Regulation. 

3.11. 

Coherence 

The  modifications  to  the  RRP  display  coherence  within  each  component  and  show  thematic 
interlinkages  and  synergies  between  the  different  components.  The  modified  recovery  and 
resilience plan presented by Portugal is structured as 21 coherent components, which support the 
common objectives of stimulating the recovery of the Portuguese economy, contributing to the 
twin  transition  and  increasing  Portugal’s  resilience  to  meet  the  challenges  of  the  twenty-first 
century  on  the  path  of  sustainable  and  inclusive  growth.  The  modification  of  the  plan  amends 
eighteen out of twenty existing components, and brings an additional component, the REPowerEU 
chapter.  

Mutually reinforcing measures 

The  modifications  to  the  RRP  do  not  negatively  alter  the  components’  coherence,  nor  the 
coherence of the plan as a whole. They do not alter the way they are mutually-reinforcing. Reforms 
newly included in the plan enable and underpin the planned investments, while investments aim 
at operationalising the reforms. For example, the new investment C05-i08 - More Digital Science, 
under  component  5,  supports  other  investments  in  this  component  by  reinforcing  the  bridge 
between academia and business as regards innovation.  

The additional REPowerEU chapter is fully in line with the measures deployed under the initial 
RRP  to  support  the  green  transition  and  further  reinforces  the  ambition  of  some  of  them,  for 
example the decarbonisation of  public transport, the energy renovation of public buildings, the 
production of renewable gases. The REPowerEU chapter is built around a consistent package of 
both reforms and investments that are mutually reinforcing to contribute for a decrease of energy 
demand, an increase in energy efficiency and support the clean energy transition.  

Complementarity of measures 

The modifications made to the eighteen existing components of the RRP do not negatively alter 
the  way  these  components  are  complementary.  For  example,  the  new  investment,  C21-i05  – 
Support to the development of the Green Industry, under the REPowerEU chapter, complements 
the investments related to the clean energy transition in components 11, 13 and 14. At the level of 
the modified plan, all components pursue complementary aims – with no contradictory aims. 

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

30 

 
 
 
 
 
 
 
3.12. 

REPowerEU 

Portugal’s REPowerEU chapter contributes to objective 21c(3)(b), through a set of reforms 
and investments aimed at increasing Portugal’s renewable energy potential. These include: 
(i) a reform to streamline permitting combined with the creation of a one-stop-shop for licencing 
renewables projects and the training of public servants dealing with renewables permitting; (ii) the 
implementation  of  an  action  plan  for  the  development  of  biomethane;  as  well  as  (iii)  a  set  of 
legislative  actions  to  help  the  take-up  of  biomethane  and  renewable  hydrogen  in  the  country. 
Portugal also plans to invest in energy efficiency in residential, service and public buildings, set-
up a national observatory on energy poverty and develop a one-stop-shop model to facilitate the 
implementation of energy efficiency interventions. The chapter also includes: (i) strategic reform 
to support the development of green skills in Portugal; (ii) the creation of a scheme for financing 
the production of net-zero technologies; (iii) the scale-up of an existing investment in renewable 
gases, and (iv) building storage capacity to increase the flexibility of the energy system.  

Energy poverty, under objective 21c(3)(c), is addressed through two new reforms and the 
upscaling of energy efficiency in residential buildings. Portugal will establish a National Energy 
Poverty Observatory to monitor and support through targeted policies households in need. It will 
also develop and implement a Citizen Energy Space model – which consists of a one-stop-shop 
model for energy efficiency interventions – combined with a scaled-up investment to boost energy 
efficiency in residential buildings, helping households improve the energy class of their dwellings 
and save on their energy bills. 

Several  investments  will  contribute  to  objective  21c(3)(d)  reducing  Portugal’s  energy 
demand.  In  particular,  the  chapter  includes  upscaling  of  the  “Decarbonisation  of  Industry” 
investment,  aiming  at  financially  supporting  industrial  SMEs  to  decarbonise  their  processes, 
improve their energy efficiency, and adopt renewable energy. It also includes a new investment to 
support to the development of green industry, through the set-up of a scheme for financing the 
production of net-zero technologies and related infrastructure that can help reduce energy demand, 
such as electric wiring, specialised operating and maintenance equipment and heat pumps. 

Portugal  also  invests  in  improving  electricity  storage  and  decarbonising  transport, 
contributing to objective 21c(3)(e). The REPowerEU chapter includes the investment in storage 
capacity to enable the optimisation and flexible management of the electricity system, especially 
in view of the electrification of the industry and transport, coupled with the development of the 
renewable hydrogen sector and the associated renewable electricity generation capacity. Portugal 
is  also  investing  in  the  decarbonisation  of  transport,  supporting  the  purchase  of  zero-emission 
public transport buses, the installation of recharging/refuelling stations, as well as the construction 
of new infrastructure for zero-emission transportation.  

The retraining of the workforce for the green transition, under objective 21.3(f), is addressed 
through a new reform and a set of new and upscaled investments. Portugal proposed a reform 
for Green Skills, which aims to create a vocational training offer for the development of green 
skills. The investments for the development of the Citizen Energy Space model and the creation 
of a one-stop-shop for licencing renewables projects will entail the training of public servants. In 

31 

 
 
 
 
 
addition, the investment to support Green Industry and the upscaling of investments in renewable 
gases will further enhance green competences of workers in the private sectors. 

Moreover,  the  REPowerEU  measures  will  have  a  long-term  effect  as  they  are  part  of 
Portugal’s wider efforts  to  cut emissions in view of the EU’s 55% 2030 climate reduction 
target and to achieve carbon neutrality by 2045, as Portugal pledged at COP 27 in Sharm el 
Sheik in November 2022. The new measures are fully aligned with Portugal’s National Energy 
and Climate Plan 2030 (NECP) – which aims to achieve 80 % of renewable sources in electricity 
generation;  as  well  as  with  the  Carbon  Neutrality  Roadmap  2050  (RNC  2050)  and  the  Basic 
Climate Law – which set a mandatory target of at least a 90 % reduction in greenhouse gases by 
2050 compared to 2005 and the achievement of carbon neutrality. Moreover, the investments to 
decarbonise  industry,  improve  energy  efficiency  in  buildings  as  well  as  boost  the  national 
renewable energy production capacity contribute to the objectives of the European Green Deal and 
the Net Zero Industry Act. Portugal’s investment in renewable hydrogen will also contribute to 
meet  the  European  target  for  10  million  tonnes  of  renewable  hydrogen  to  be  domestically 
produced. 

Consultations  were  held  with  stakeholders  in  the  drafting  of  this  chapter.  The  Portuguese 
government  ensured broad  participation  by consulting  civil  society stakeholders, including: the 
Standing Committee for Social Dialogue; the Economic and Social Council; the Coordination and 
Regional  Development  Committees  and  the  National  Association  of  Municipalities.  Thematic 
discussions were held with relevant actors in their fields, also collecting inputs from the National 
Monitoring Commission and political parties. Around 150 organisations and individuals submitted 
written contributions, which were considered in the design of the REPowerEU chapter.  

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged  in  the  REPowerEU 
chapter, the chapter is expected, to a large extent, to contribute effectively to energy security, the 
diversification of the Union’s energy supply, an increase in the uptake of renewables and energy 
efficient, an increase of energy storage capacities or the necessary reduction of dependence on 
fossil fuels before 2030. This would warrant a rating of A under criterion 2.12 of Annex V of the 
RRF Regulation. 

3.13. 

Cross-border or multi-country dimension or effect 

The  majority  of  the  measures  included  in  Portugal’s  REPowerEU  chapter  have  a  multi-
country or cross-border dimension. The investments related to the production and storage of 
renewable  energy  are  aimed  at  reducing  the  dependency  of  Portugal  from  fossil  fuels  and  at 
increasing the potential of exports of clean energy to Europe. The scale-up of the production of 
renewable  hydrogen  will  also  put  Portugal  in  a  position  to  contribute  to  the  country  and  the 
continent’s decarbonisation. In addition, by scaling-up measures for energy renovations in public 
and service buildings, the plan contributes to reducing dependency on fossil fuels and reducing 
energy demand. These measures are complemented by the measure on the development of green 
industry and the scale-up of the measure aiming at decarbonising companies, which also aim to 
reduce both dependency on fossil fuels and energy demand in the industry sector.  

32 

 
 
 
 
 
 
The total costs of these measures account for a total of 608,9 million euros, representing 71% of 
the estimated costs of the REPowerEU chapter, far above the indicative target of 30%. 

REPowerEU measure 

Costs 
(EUR 
million) 

Contribution 
to the target 
in % 

C21-i01: Scaled-up: Decarbonisation of Industry 
C21-i02: Scaled-up: Energy efficiency in residential buildings 
C21-i03:  Scaled-up:  Energy  efficiency  in  buildings  used  by  the 
services sector 
C21-i04-RAM: Energy efficiency in public buildings in Madeira 
C21-i05: Support to the Development of Green Industry 
C21-i06: Scaled-up: Hydrogen and renewable gases 
C21-i07: Technical studies for offshore energy potential 
C21-i08: Network flexibility and storage 
C21-i10: System of incentives for the purchase and installation of 
renewable energy storage systems in the Azores 
C21-i11-RAM: System of incentives for the production and storage 
of energy from renewable sources in Madeira and Porto Santo 
TOTAL 

100 
120 

80 

14 
50 
70 
50 
100 

6 

18,9 

608,9 

11,7% 
14,0% 

9,4% 

1,6% 
5,8% 
8,2% 
5,8% 
11,7% 

0,7% 

2,2% 

71,2% 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged  in  the  REPowerEU 
chapter, the measures in the chapter are expected, to a large extent, to have a cross-border of 
multi-country dimension or effect. This would warrant a rating of A under criterion 2.13 of Annex 
V of the RRF Regulation. 

33 

 
 
 
 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging 

Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C01]-I[i01.1] 

C[C01]-I[i01.2] 

C[C01]-I[i01.3] 

C[C01]-I[i01.6] 

C[C01]-I[i01.7] 

C[C01]-I[i02.1] 

C[C01]-I[i03.2] 

C[C01]-I[i04.2] 

243 

025ter 

40% 

13 

026bis  100% 

171 

026 

40% 

29 

074 

100% 

7 

095 

100% 

227 

025ter 

40% 

59 

026bis  100% 

100 

025ter 

40% 

Primary health care with more 
answers — Construction of new 
energy efficient buildings 

Primary health care with more 
answers — Medium-depth energy 
efficiency renovation 

Primary health care with more 
answers — Energy efficiency 
renovation 

Primary health care with more 
answers — Purchase of electric 
cars associated with the provision 
of health care 

Primary health care with more 
answers — Tele-
medicine/telehealth care 

National Network of Integrated 
Continued Care and National 
Network of Palliative Care — 
Strengthening the response 
capacity of the national networks 
of integrated continued care and 
palliative care services in 
inpatient and outpatient care 

Completion of the mental health 
reform and implementation of the 
dementia strategy — Medium-
depth energy efficiency 
renovation 

Construction of East Lisbon 
Hospital and equipment for 
hospitals in Lisbon and Vale do 
Tejo - Construction of the East 
Lisbon Hospital 

34 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C01]-I[i05-RAM.1] 

C[C01]-I[i05-RAM.2] 

Strengthening Madeira’s 
Regional Health Service — 
Increase in the number of places 
in integrated continued care 
services in Madeira’s Regional 
Health Service 

Strengthening Madeira’s 
Regional Health Service — 
Energy renovation of health 
facilities in Madeira’s Regional 
Health Service 

52 

025ter 

40% 

27 

026 

40% 

C[C01]-I[i06] 

Digital Health Transition 

300 

095 

100% 

C[C01]-I[i07-RAM] 

Digitalisation of Madeira’s 
Regional Health Service 

C[C01]-I[i08-RAA] 

Digital Hospital in the Azores 

15 

35 

095 

100% 

095 

100% 

C[C02]-I[i01.1] 

C[C02]-I[i01.2] 

C[C02]-I[i02.1] 

C[C02]-I[i02.3] 

C[C02]-I[i03-RAM.1] 

C[C02]-I[i03-RAM.2] 

C[C02]-I[i03-RAM.3] 

Support Programme for Access to 
Housing - Renovations 

Support Programme for Access to 
Housing - Construction - green 

420 

025 

40% 

598 

025ter 

40% 

National Emergency and 
Temporary Accommodation 
Grant - Constructions green I 

National Emergency and 
Temporary Accommodation 
Grant - Renovations 

Strengthening of the supply of 
social housing in the 
Autonomous Region of Madeira - 
Constructions 
Strengthening of the supply of 
social housing in the 
Autonomous Region of Madeira - 
Renovations 

Strengthening of the supply of 
social housing in the 
Autonomous Region of Madeira - 
Information technology 

35 

166 

025ter 

40% 

21 

025 

40% 

129 

025ter 

40% 

6 

025 

40% 

2 

11 

100% 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C02]-I[i04-RAA.1] 

C[C02]-I[i04-RAA.2] 

Increasing housing conditions in 
the housing stock of the 
Autonomous Region of the 
Azores - Constructions 

Increasing housing conditions in 
the housing stock of the 
Autonomous Region of the 
Azores - Renovations 

17 

025ter 

40% 

27 

025bis  100% 

C[C02]-I[i05.1] 

Affordable public housing stock - 
Renovations 

296 

025 

40% 

C[C02]-I[i05.2] 

C[C02]-I[i06.1] 

C[C02]-I[i06.2] 

C[C02]-I[i06] 

C[C02]-I[i08-RAA] 

C[C02]-I[i09.1] 

C[C02]-I[i09.2] 

C[C03]-I[i01.1] 

C[C03]-I[i01.2] 

C[C03]-I[i01.4] 

Affordable public housing stock - 
Constructions 

604 

025ter 

40% 

Student accommodations at 
affordable prices - Renovations 

Student accommodations at 
affordable prices - Constructions 

Student accommodations at 
affordable prices 

Reinforcement of the social 
housing stock 

Support Programme for Access to 
Housing (loans) - Renovations 

Support Programme for Access to 
Housing (loans) - Construction - 
green 

New generation of equipment and 
social responses - Construction of 
social equipment 

New generation of equipment and 
social responses - Renewal of 
social equipment 

New generation of equipment and 
social responses - Electric Cars to 
provide social community 
support services 

356 

025bis  100% 

159 

025ter 

40% 

0 

025ter 

40% 

16 

025ter 

40% 

76 

025ter 

40% 

120 

025ter 

40% 

261 

025ter 

40% 

143 

026 

40% 

77 

074 

100% 

36 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C03]-I[i01.5] 

C[C03]-I[i03-RAM.1] 

C[C03]-I[i03-RAM.2] 

C[C03]-I[i04-RAA.2] 

C[C03]-I[i04-RAA.3] 

C[C03]-I[i04-RAA.4] 

New generation of equipment and 
social responses - IT equipment 
needed to provide social 
community support services 

Strengthening social responses in 
the Autonomous Region of 
Madeira (ARM) - Construction of 
social facilities 

Strengthening social responses in 
the Autonomous Region of 
Madeira (ARM) - Renovation of 
social facilities 

Implementing the Regional 
Strategy for Combating Poverty 
and Social Exclusion — Social 
Support Networks (ARA) - 
Electric Cars for the provision of 
community support social 
services 

Implementing the Regional 
Strategy for Combating Poverty 
and Social Exclusion — Social 
Support Networks (ARA) - 
Construction of social facilities 

Implementing the Regional 
Strategy for Combating Poverty 
and Social Exclusion — Social 
Support Networks (ARA) - 
Renewal of social facilities 

22 

013 

100% 

41 

025ter 

40% 

50 

026 

40% 

- 

- 

4 

074 

100% 

- 

10 

025ter 

40% 

- 

5 

026 

40% 

- 

C[C03]-I[i05] 

Platform + Access 

3 

011 

100% 

C[C03]-I[i07-RAA.01] 

C[C03]-I[i07-RAA.02] 

Upgrading and expanding the 
network of residential care homes 
for the elderly (ERPIs) - 
Construction 

Upgrading and expanding the 
network of residential care homes 
for the elderly (ERPIs) - 
Renovation 

37 

8 

025ter 

40% 

4 

026 

40% 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C04]-I[i01.1] 

Cultural Networks and Digital 
Transition - 1 

89 

129 

0% 

011 

100% 

C[C04]-I[i01.2] 

Cultural Networks and Digital 
Transition - 2 

4 

129 

0% 

011 

100% 

C[C04]-I[i01.3] 

Cultural Networks and Digital 
Transition - 3 

10 

129 

0% 

011 

100% 

C[C04]-I[i02.1] 

Cultural Heritage - Renovation of 
cultural installations 

210 

26 

40% 

C[C04]-I[i02.2] 

Cultural Heritage — Saber Fazer 

C[C04]-I[i02.3] 

Cultural Heritage - National 
Archive of Sound 

2 

5 

047 

40% 

025ter 

40% 

C[C05]-I[i01.02] 

Green Agendas/Alliances for 
business innovation 

372 

022 

100% 

C[C05]-I[i02.1] 

C[C05]-I[i02.2] 

C[C05]-I[i03.1] 

Interface mission — renewal of 
the scientific and technological 
support network and guidance for 
productive fabric - Green 

Interface mission — renewal of 
the scientific and technological 
support network and guidance for 
productive fabric - Digital 

Research and innovation agenda 
for sustainable agriculture, food 
and agro-industry [Innovation 
Agenda for Agriculture 20 30] - 
Green projects 

82 

022 

100% 

104 

021 

40% 

45 

022 

100% 

38 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C05]-I[i03.2] 

C[C05]-I[i03.3] 

C[C05]-I[i05-RAA.1] 

C[C05]-I[i08.01] 

C[C05]-I[i08.02] 

C[C05]-I[i08.03] 

C[C05]-I[i08.04] 

C[C05]-I[i08.05] 

C[C05]-I[i08.06] 

Research and innovation agenda 
for sustainable agriculture, food 
and agro-industry [Innovation 
Agenda for Agriculture 20 30] - 
Digital projects 

Research and innovation agenda 
for sustainable agriculture, food 
and agro-industry [Innovation 
Agenda for Agriculture 20 30] - 
Renovation of hubs 

Economic Recovery of Azorean 
Agriculture - projects 

More Digital Science - Campus 
Science XXI 

More Digital Science - Science 
Desk 

More Digital Science - National 
Advanced Computing Centre 
(CNCA) 

More Digital Science - R&D 
programme in public 
administration 

More Digital Science - National 
Platform for Mass Online 
Courses (NAU) 

More Digital Science - National 
Open Science and Research Data 
Programme (PNCADAI) 

36 

050 

40% 

12 

009 

100% 

20 

047 

40% 

4 

2 

22 

9 

3 

9 

009 

100% 

009 

100% 

055 

100% 

009 

100% 

021 

0% 

021 

100% 

055 

100% 

C[C05]-I[i10] 

Green Agendas/Alliances for 
business innovation (2) 

319 

022 

100% 

0 

0% 

C[C05]-I[i11.01] 

C[C05]-I[i12] 

Mobilising Agendas/Alliances for 
Business Innovation (Loans) - 
Digital Innovation 

Green Agendas/Alliances for 
business innovation (Loans) 

649 

008 

0% 

008 

40% 

533 

022 

100% 

39 

 
 
 
 
 
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C06]-I[i01.1] 

C[C06]-I[i01.2] 

C[C06]-I[i01.3] 

C[C06]-I[i01.4] 

Modernisation of supply and 
vocational education and training 
institutions — Construction of 
vocational training centres 

Modernisation of supply and 
vocational education and training 
institutions— Renewal of 
vocational training centres 

Modernisation of supply and 
vocational education and training 
institutions— Equipment for 
digital skills 

Modernisation of supply and 
vocational education and training 
institutions— Skills for the green 
economy 

C[C06]-I[i04] 

Youth impulse – STEAM 

C[C06]-I[i05-RAA.2] 

C[C06]-I[i05-RAA.4] 

C[C06]-I[i07.01] 

C[C06]-I[i07.02] 

Adult Qualification and Lifelong 
Learning (ARA) - Digital skills 

Adult Qualification and Lifelong 
Learning (ARA) - Requalification 
of the professional schools 
network 

More digital impulse - 
Technological and digital 
modernisation of agrarian 
sciences 

More digital impulse - 
Modernisation of medicine 

26 

025ter 

40% 

127 

026bis  100% 

521 

108 

100% 

36 

01 

100% 

147 

14 

108 

100% 

108 

100% 

8 

026bis  100% 

15 

009 

0% 

016 

40% 

30 

009 

0% 

095 

100% 

C[C06]-I[i07.03] 

More digital impulse - 
Strengthening digital skills 

20 

108 

100% 

C[C06]-I[i07.05] 

More digital impulse - Innovation 
and pedagogical modernisation in 
higher education (ICT) 

20 

009 

0% 

012 

100% 

C[C06]-I[i08-RAM] 

Extension of the CITMA building 

18 

025ter 

40% 

40 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

C[C06]-I[i09.01] 

C[C06]-I[i09.02] 

New or renovated schools - 
Construction 

New or renovated schools - 
Renovation 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

45 

025ter 

40% 

383 

026bis  100% 

Digital 

Int. Field  Coeff. % 

C[C06]-I[i09.03] 

New or renovated schools - IT 

23 

012 

100% 

C[C07]-I[i01.1] 

C[C07]-I[i01.2] 

C[C07]-I[i01.3] 

C[C07]-I[i01.4] 

C[C07]-I[i01.5] 

C[C07]-I[i01.6] 

C[C08]-I[i01] 

C[C08]-I[i02] 

C[C08]-I[i03] 

C[C08]-I[i04] 

Business Reception Areas — 
Renewable energy production 
and storage systems (solar 
energy) 
Business Reception Areas — 
Renewable energy production 
and smart storage (energy 
systems); 

Business Reception Areas — 
Pilot interventions to improve 
energy stability 

Business Reception Areas — 
Sustainable mobility 

36 

029 

100% 

38 

033 

100% 

033 

40% 

15 

024 

40% 

7 

077 

100% 

Business Reception Areas — 
Strengthening coverage with 5G 

10 

051 

100% 

Business Reception Areas — 
Active fire prevention and 
protection 

Landscape Transformation in 
Vulnerable Forest Areas - 
Investment 

Rural property registry and Land 
Cover Monitoring System 

Fuel management breaks — 
primary network 

Means to prevent and combat 
rural fires 

3 

036 

100% 

270 

036 

100% 

86 

036 

100% 

011 

100% 

120 

036 

100% 

89 

50 

036 

100% 

036 

100% 

237 

040 

40% 

C[C08]-I[i05] 

More Forest Programme 

C[C09]-I[i01] 

Algarve Water Efficiency 
Regional Plan 

41 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C09]-I[i03-RAM] 

C[C09]-I[i04.1] 

C[C09]-I[i04.2] 

C[C09]-I[i04.3] 

C[C09]-I[i04.4] 

C[C09]-I[i04.5] 

C[C09]-I[i04.6] 

C[C10]-I[i01.1] 

C[C10]-I[i01.2] 

C[C10]-I[i01.3] 

Plan for water efficiency and 
strengthening of supply and 
irrigation systems of Madeira 

Hydraulic multi-purpose 
enterprise of Crato, construction 
phase - Dam construction work 

Hydraulic multi-purpose 
enterprise of Crato, construction 
phase - Construction of mini 
hydro 
Hydraulic multi-purpose 
enterprise of Crato, construction 
phase - Dam inflow enhancement 
system 

Hydraulic multi-purpose 
enterprise of Crato, construction 
phase - Irrigation block 
infrastructure and monitoring 

Hydraulic multi-purpose 
enterprise of Crato, construction 
phase - Strengthening supply of 
Povoa and Meadas dam 

Hydraulic multi-purpose 
enterprise of Crato, construction 
phase - Environmental 
expropriation and compensation 

Blue Hub, Network of 
Infrastructure for the Blue 
Economy — Digital 
infrastructure and equipment 

Blue Hub, Network of 
Infrastructure for the Blue 
Economy — Skills for the Green 
Transition 

Blue Hub, Network of 
Infrastructure for the Blue 
Economy — Protection of nature 
and biodiversity 

42 

82 

040 

40% 

51 

040 

40% 

2 

032 

100% 

17 

040 

40% 

55 

040 

40% 

6 

040 

40% 

9 

040 

40% 

2 

008 

0% 

055 

100% 

5 

01 

100% 

39 

050 

40% 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C10]-I[i01.4] 

C[C10]-I[i01.5] 

C[C10]-I[i01.6] 

Blue Hub, Network of 
Infrastructure for the Blue 
Economy — Construction of 
buildings 

Blue Hub, Network of 
Infrastructure for the Blue 
Economy — Building renovation 

Blue Hub, Network of 
Infrastructure for the Blue 
Economy — Adaptation 
measures to climate change 

43 

025ter 

40% 

4 

026bis  100% 

7 

037 

100% 

C[C10]-I[i02] 

Green and Digital Transition and 
Security in Fisheries 

21 

024 

40% 

C[C10]-I[i03.1] 

C[C10]-I[i03.2] 

C[C10]-I[i04-RAA.1] 

C[C10]-I[i04-RAA.2] 

C[C10]-I[i04-RAA.3] 

C[C10]-I[i05-RAA] 

Atlantic Defence Operations 
Centre and naval platform — 
Nature and biodiversity 
protection 

Atlantic Defence Operations 
Centre and naval platform — 
Skills for the green transition 

Development of the ‘Cluster do 
Mar dos Açores’ — Protection of 
nature and biodiversity 

Development of the ‘Cluster do 
Mar dos Açores’ — Construction 
of buildings 

Development of the ‘Cluster do 
Mar dos Açores’ — Research 
Vessel Modules 

Energy transition, digitalisation 
and reduction of environmental 
impact in the fisheries and 
aquaculture sector 

148 

050 

40% 

2 

01 

100% 

23 

050 

40% 

16 

025ter 

40% 

6 

050 

40% 

5 

024 

40% 

C[C10]-I[i07.02] 

Green Shipping - Information 
system 

1 

084bis 

40% 

084bis 

100% 

C[C11]-I[i01] 

Decarbonisation of Industry 

737 

024ter  100% 

43 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

C[C12]-I[i01.1] 

C[C12]-I[i01.2] 

C[C12]-I[i01.4] 

C[C13]-I[i01] 

C[C13]-I[i02] 

C[C13]-I[i03] 

C[C14]-I[i01] 

C[C14]-I[i02-RAM] 

C[C14]-I[i03-RAA] 

C[C15]-I[i01] 

C[C15]-I[i02] 

C[C15]-I[i03] 

C[C15]-I[i04] 

C[C15]-I[i05] 

Bioeconomy - Research and 
Innovation 

Bioeconomy - Training and 
Awareness Raising 

Bioeconomy - Forest 
Management 

Energy efficiency in residential 
buildings 

Energy efficiency in central 
government buildings 

Energy efficiency in buildings 
used by the services sector 

Hydrogen and renewable gases 
Renewable electricity 
potentiation in the Madeira 
Archipelago 
Energy transition in the Azores 

Expansion of the Lisbon Metro 
Network — Red Line to 
Alcântara 

Expansion of the Porto Metro 
Network — Casa da Música-
Santo Ovídio 

Light Rail Transit Odivelas - 
Loures 

Bus Rapid Transit Boavista – 
Império 

Decarbonisation of public 
transport 

C[C15]-I[i06] 

Digitalisation of rail transport 

C[C16]-I[i01] 

Digital Empowerment of 
Enterprises 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

120 

022 

100% 

Digital 

Int. Field  Coeff. % 

3 

01 

100% 

16 

036 

100% 

300 

025bis  100% 

240 

026bis  100% 

70 

024ter  100% 

185 

032 

100% 

84 

032 

100% 

137 

032 

100% 

358 

073 

100% 

352 

073 

100% 

390 

073 

100% 

66 

48 

49 

100 

073 

100% 

074 

100% 

070 

40% 

070 

100% 

108 

100% 

C[C16]-I[i02] 

Digital Transition of Enterprises 

475 

010 

100% 

C[C16]-I[i03] 

Catalyst for the Digital Transition 
of Enterprises 

C[C16]-I[i04] 

Industry 4.0 

100 

60 

010 

100% 

010 

100% 

44 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C16]-I[i05.01-RAA] 

C[C16]-I[i05.02-RAA] 

C[C16]-I[i05-RAA] 

Digital Capacity and 
Transformation of Enterprises in 
the Azores - System of incentives 
for the digital transition of 
enterprises 

Digital Capacity and 
Transformation of Enterprises in 
the Azores - Amplification of the 
Science and Technology Park 
TERINOV 

Digital Capacity and 
Transformation of Enterprises in 
the Azores 

C[C16]-I[i06-RAM] 

Enterprise 4.0 

C[C17]-I[i01] 

C[C17]-I[i02] 

C[C17]-I[i03] 

C[C18]-I[i01] 

C[C19]-I[i01.1] 

C[C19]-I[i01.2] 

C[C19]-I[i01.3] 

Public Financial Management 
Information Systems 

Modernisation of the information 
systems of the Tax and Customs 
Authority for rural property 
taxation 

Digital transition of Social 
Security services 

Economic justice and business 
environment - Investment 

Redesign of public and consular 
services- Services recorded and 
available in the enhanced Entity 
and Services Catalogue 

Redesign of public and consular 
services - New consular 
management model 

Redesign of public and consular 
services - Increasing Citizen 
Spaces and Shops (Lojas e 
Espaço Cidadão) 

20 

010 

100% 

2 

025ter 

40% 

0 

6 

163 

43 

200 

267 

182 

010 

100% 

010 

011 

100% 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

26 

025ter 

40% 

15 

011 

100% 

C[C19]-I[i02] 

Sustainable electronic services 

70 

011 

100% 

45 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

C[C19]-I[i03] 

C[C19]-I[i04] 

C[C19]-I[i05-RAM] 

C[C19]-I[i06-RAA] 

Strengthening the overall 
cybersecurity framework 

Efficient, secure and shared 
digital critical infrastructures 

Digital transition of Madeira’s 
public administration 

Digital transition of the public 
administration in Azores 

C[C19]-I[i07] 

Public administration empowered 
to create public value 

C[C19]-I[i08.1] 

Intelligent Territories 

C[C19]-I[i08.2] 

Intelligent Territories 

C[C19]-I[i08] 

Intelligent Territories 

52 

83 

81 

33 

83 

54 

6 

0 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

016 

40% 

011 

100% 

108 

100% 

011 

100% 

C[C20]-I[i01] 

Digital transition in education 

609 

012 

100% 

C[C20]-I[i02-RAA] 

Digital education (Azores) 

C[C20]-I[i03-RAM] 

C[C21]-I[01] 

C[C21]-I[02] 

C[C21]-I[03] 

C[C21]-I[04]-RAM 

C[C21]-I[05] 

C[C21]-I[07] 

Accelerating the digitalisation of 
ARM education 

Scaled-up measure: 
Decarbonisation of Industry 

Scaled-up measure: Energy 
efficiency in residential buildings 

Scaled-up measure: Energy 
efficiency in buildings used by 
the services sector 

Energy efficiency in public 
buildings in Madeira 

Support to the Development of 
Green Industry 

Technical studies for offshore 
energy potential 

43 

22 

012 

012 

100% 

100% 

100 

024ter  100% 

120 

025bis  100% 

80 

024ter  100% 

14 

026bis  100% 

50 

50 

027 

100% 

027 

100% 

C[C21]-I[08] 

Network flexibility and storage 

100 

033 

100% 

46 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ Sub-Measure 
ID 

Measure/Sub-Measure Name 

C[C21]-I[09] 

C[C21]-I[10-RAA] 

C[C21]-I[11-RAM] 

C[C21]-I[12] 

C[C21]-I[13-RAM] 
C[C21]-I[14] 
C[C21]-I[15-RAA] 
C[C21]-I[16] 

One-stop-shop for the licensing 
and monitoring of renewable 
energy projects 

System of incentives for the 
purchase and installation of 
renewable energy storage systems 
in the Azores 

System of incentives for the 
production and storage of energy 
from renewable sources in 
Madeira and Porto Santo 

Scaled-up measure: 
Decarbonisation of public 
transport 
Decarbonisation of transport 
Bus Rapid Transit Braga  
Acquisition of two electric ferries 
Nazaré Funicular 

Budget 
(EUR 
m) 

Climate 

Int. 
Field 

Coeff. 
% 

Digital 

Int. Field  Coeff. % 

10 

011bis 

40% 

011bis 

100% 

6 

033 

100% 

033 

40% 

19 

033 

100% 

033 

40% 

90 

074 

100% 

12 
100 
25 
10 

074 
073 
074 
073 

100% 
100% 
100% 
100% 

47