COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of the Netherlands Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 12275/22 INIT; ST 12275/22 INIT ADD 1) of 4 October 2022 on the approval of the assessment of the recovery and resilience plan for the Netherlands
Date: 2023-09-29
Institutions: European Commission, Secretariat-General
Subjects: EU aid, Netherlands, economic recovery, economic reform, energy policy, fiscal policy, investment, labour market, stability programme, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.9.2023  SWD(2023) 324 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of the Netherlands Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 12275/22 INIT; ST 12275/22 INIT ADD 1) of 4 October 2022 on the approval of the assessment of the recovery and resilience plan for the Netherlands {COM(2023) 574 final}  
 
 
Table of contents 

3.1 

3.2 

Comprehensive and adequately balanced response to the economic and social situation ........ 8 

Link with country-specific recommendations and the European Semester ............................... 10 

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 ...... 11 

3.4 

3.5 

3.6 

3.7 

The principle of ‘do no significant harm’ .................................................................................... 11 

Green transition .......................................................................................................................... 12 

Digital transition .......................................................................................................................... 13 

Lasting impact of the plan ........................................................................................................... 13 

3.8  Milestones, targets, monitoring and implementation................................................................ 13 

3.9. 

Costing ........................................................................................................................................ 14 

3.10  Controls and audit ....................................................................................................................... 16 

3.11  Coherence ................................................................................................................................... 17 

3.12  REPowerEU ................................................................................................................................. 17 

3.13  Cross-border or multi-country dimension or effect ................................................................... 19 

ANNEX: Climate tracking and digital tagging .......................................................................................... 20 

1 

 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY 

In 2022 the Dutch economy was hit by high inflation due to strongly rising energy prices and 
a high reliance on fossil fuels. In light of these challenges, in particular related to the Netherlands’ 
low share of renewable energy, the country submitted a modified Recovery and Resilience Plan 
(RRP) along with a REPowerEU chapter on 6 July 2023. The Netherlands proposed modifications 
to its RRP pursuant to two legal bases. Firstly, in accordance with Article 21(1) of Regulation (EU) 
2021/241, the Netherlands considered the RRP to be partially no longer achievable due to objective 
circumstances and made a reasoned request to the Commission to make a proposal to amend the 
Council  Implementing  Decision.  Secondly,  in  accordance  with  Article  21c  of  Regulation  (EU) 
2021/241, the Netherlands included a REPowerEU chapter in its national RRP. In addition, the 
Netherlands also notified the Commission that it had updated its audit and control chapter to reflect 
the ongoing work to streamline the monitoring, implementation and audit set-up. 

The  modifications  submitted  by  the  Netherlands  under  Article  21(1)  of  Regulation  (EU) 
2021/241 concern ten measures. The Netherlands has requested to amend nine measures of the 
initial  plan and  to  introduce one new measure.  In addition,  the submitted plan rectifies clerical 
errors  in  four  measures.  The  amendments  include  removing  a  measure  that  was  no  longer 
achievable  and  its  replacement  by  a  new  measure,  postponing  the  achievement  of  targets  and 
reductions of intermediate targets while keeping the total ambition constant, replacing targets that 
are  not  fully  achievable  with  better  alternatives  and  the  reduction  of  targets  due  the  impact  of 
labour shortages and/or increased costs.  

The REPowerEU chapter contains measures to help address the energy related challenges 
that  the  Netherlands  is  currently  facing.  The  proposed  measures  contain  a  scale-up  of  the 
existing energy efficiency subsidy ‘Investment subsidy for sustainable energy and energy savings’ 
from component 3 of the existing plan. The proposed chapter also includes a reform aiming to 
tackle  challenges  that  the  Dutch  energy  markets  are  facing.  The  reform  aims  to  facilitate 
investments  into  grid  infrastructure,  tackle  congestion  on  the  Dutch  electricity  grid  and  to 
accelerate permitting procedures for renewable energy projects. Both measures contribute to the 
REPowerEU  objective  of  increasing  the  share  and  accelerating  the  deployment  of  renewable 
energy, while the latter measure also contributes to addressing energy transmission and distribution 
bottlenecks. By contributing to an increase in the share of renewable energy in the country’s energy 
mix and by addressing congestion on the electricity grid, the chapter is in line with the country-
specific recommendations on energy (CSRs 4 in 2022 and 2023). All measures in the REPowerEU 
chapter have a cross-border or multi-country dimension or effect. 

Based on the assessment of the submitted modification and the REPowerEU  chapter,  the 
Netherlands’ 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). 

2 

 
 
 
(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 (55%)  A (26%) 

A 

A 

B 

A 

A 

A 

A 

2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN 

In 2022, Russia’s invasion of Ukraine led to a surge in energy and commodity prices in the 
Netherlands and the EU as a whole. Inflation in the Netherlands reached 11.6% in 2022 and was 
among the highest in the EU. Thanks to robust employment growth, an increase in wage growth 
and  extensive  measures  taken  by  the  government  to  support  households’  purchasing  power, 
consumption  remained  strong  and  the  economy  grew  significantly  at  4.3%  despite  very  high 
inflation. The 2023 Country Report for the Netherlands identified challenges related to the housing 
market, labour market segmentation as well as renewable energy deployment and the transition to 
sustainable agriculture. The low share of renewable energy in the Netherlands’ energy mix is of 
particular concern in light of strongly rising prices for fossil fuels and their lacking security of 
supply over 2022. Supply chain disruptions, a very tight labour market as well as restrictions due 
to excessive nitrogen emissions have also impacted the Dutch economy over the past year. 

Pursuant  to  Article  21(1)  of  the  RRF  Regulation,  the  Netherlands  has  justified  the 
modification  of  nine  measures  and  the  introduction  of  one  new  measure  due  to  objective 
circumstances. Among other reasons, the Netherlands invokes technological progress, increased 
costs due to high energy prices, higher interest rates, persistent wide-spread labour shortages and 
better  alternatives  as  objective  circumstances  that  require  modifications  to  a  limited  set  of 
measures.  

The Netherlands’ modified recovery and resilience plan adds a REPowerEU chapter to the 
original plan pursuant to Article 21(c) of the RRF Regulation and is a strong response to the 
geopolitical and energy challenges that the European Union has faced since the end of 2021 
and beginning of 2022. The amendment of the RRF Regulation provides for additional support 
for reforms and investments helping to phase out imports of Russian fossil fuels and providing 
clean,  affordable  and  secure  energy  to  households  and  businesses  across  Europe.  The 
modifications proposed under the plan and the newly integrated REPowerEU chapter are following 
the country specific recommendations for the Netherlands presented in the context of European 
Semester 2022 and 2023 cycles. 

The  main  elements  of  the  amended  RRP  and  REPowerEU  chapter  are  listed  below  by 
component:  

Component 1 (Promoting the green transition): 

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands has proposed to  amend the 
measure C1.1 R1  ‘Energy taxation reform’. 

The Netherlands proposes to specify that the changes made to the tariffs on the use of gas 
and electricity shall be done in real terms. Due to high inflation, the yearly indexation of the 

3 

 
 
 
aforementioned tariffs could for a significant degree off-set the intended impact of the original 
measure. Requiring that the adjustments to the tariffs shall be done in real terms prevents this and 
ensures that at least the original level of ambition in terms of making the use of gas more expensive 
and  the  use  of  electricity  cheaper  is  achieved.  With  this  change,  the  Netherlands  proposes  the 
amended measure as a manifestly better alternative in the way of monitoring than the measure in 
its original form. 

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands has proposed to amend two of 
the targets for measure C1.1 I3 ‘Inland waterway energy transition, project Zero Emission Services 
(ZES)’. 

The Netherlands proposes that the unit of measure for target 24 is changed from the number 
of  Modular  Energy  Containers  (MECs)  to  the  realised  capacity  in  terms  of  kWh.  Due  to 
technological  advancements,  the  capacity  of  the  MECs  has  increased  from  2  to  2.9  kWh  per 
module. This means that fewer MECs are needed than originally envisaged (75) to achieve the 
desired capacity of 150 kWh. The target is proposed to be changed to 150 kWh to reflect this, 
leaving the overall level of ambition for this target the same.  

The Netherlands proposes that the unit of measure for target 26 is changed from the number 
of ships converted to be emission free to the total tonnage transported by converted emission 
free ships. Additionally, NL proposes to reduce the total tonnage to be converted to zero emission 
electric propulsion due to higher than anticipated price increases for ship components. Initially, it 
was  envisaged  to  convert  standard-sized  container  ships  to  be  emission-free.  Due  to  changing 
demand for the subsidy, the Netherlands argues that ships of various different formats and sizes 
may  be  converted  to  be  emission-free.  Tracking  the  total  tonnage  is  therefore  a  more  suitable 
measure than the number of ships. The target is therefore proposed to be changed from the number 
of emission-free ships (45) to the total loading capacity (TEU) of emission-free ships (6161 TEU). 

Component 2 (Accelerating the digital transformation): 

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands has proposed to amend three 
of the targets for measure C2.2 I3 ‘Intelligent roadside stations (iWKS)’. 

The Netherlands proposes to reduce the number of roadside stations to be installed under 
targets 55 and 56 and to delay targets 56 and 57, while keeping the overall ambition of the 
measure constant. The installation of roadside stations has been delayed due to higher material 
costs,  increased  delivery  times  and  lack  of  specialist  staff.  According  to  the  proposal  by  the 
Netherlands, 152 roadside stations will be installed by Q4 2023 instead of 591 under target 55. 
Target 56 is moved from Q4 2024 to Q4 2025 and the cumulative number of roadside stations 
reduced to 953. Target 57 with an unchanged cumulative target of 1906 roadside stations is moved 
from Q4 2025 to Q2 2026. 

Component 3 (Improving the housing market and making real estate more energy efficient): 

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands  has  proposed to  amend the 
measure C3.1 I1 ‘Unlocking new construction projects’.  

4 

 
 
The Netherlands proposes to remove the first target of the measure, reduce the number of 
construction starts to be achieved under  targets 77 and 78 and to increase  target 79.  The 
cumulative ambition of the measure to achieve 100 000 construction starts by Q2 2026 remains 
the  same.  Due  to  increased  construction  costs,  high  interest  rates  as  well  as  restrictions  to 
construction activity due to environmental regulation related to excessive nitrogen emissions, the 
Netherlands  argues  that  construction  progresses  slower  than  anticipated  at  the  time  of  the 
submission of the plan. Target 77 is therefore proposed to be changed from a cumulative target of 
42 000 construction starts to 10 000 and target 78 from a cumulative target of 71 000 to 31 000. 
The remaining 69 000 construction starts are therefore expected to be achieved under target 79. 

Based on Article 21 of  Regulation (EU) 2021/241, the Netherlands has proposed to  amend the 
measure C3.2 I2  ‘Investment subsidy for sustainable energy and energy savings’. 

The  Netherlands  proposes  to  remove  the  reference  to  ‘owners  of  real  estate’  to  allow  a 
broader group of applicants to benefit from the subsidy and to add the installation of electric 
stoves  to  the  list  of  eligible  interventions  from  2023  onwards.  With  these  two  changes,  the 
Netherlands proposes the amended measure as a manifestly better alternative than the measure in 
its original form. The proposal by the Netherlands foresees the same target of 225 000 interventions 
by Q1 2026 as the original measure. 

Component 4 (Strengthening the labour market, pensions and future-oriented education): 

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands has proposed to  amend the 
measure C4.1 I1 ‘NL continues to learn’. 

The Netherlands proposes to lower the target for the creation of sectoral pathways. Due to 
persistent wide-spread labour shortages, there was an unexpected drop in the demand for trainings 
to  prevent  unemployment  in  specific  sectors.  The  unforeseen  tightness  in  the  labour  market 
following the COVID-19 crisis is widespread across sectors, particularly in those sectors where 
the scheme (notably the creation of sectoral pathways) was foreseen to be able to help to address 
unemployment.  Therefore, the Netherlands has requested to lower the target from 30 to 21 sectoral 
pathways.  

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands has proposed to  amend the 
measure C4.1 R3 ‘Reform of the second pillar of the pension system’. 

The  Netherlands  has  proposed  to  introduce  an  additional  target  to  ensure  that  a  binding 
decision, i.e. approved by the supervisor, will be taken on the transfer of the pension assets 
of  at  least  66%  of  policy  holders  to  the  new  pension  system.  The  aforementioned  binding 
decisions would not cover all policy holders in the second pillar pension system due to bottlenecks 
in  the  implementation  of  the  pension  reform  resulting  from  limited  administrative  capacity.  In 
particular, the Netherlands argues that an extension of the transitional period to  beyond end of 
2026 is needed because a new survey shows that pension funds are expected to transition to the 
new system around the same period, mostly in 2026, leading to an unforeseen peak in workload 
for the bodies responsible for assisting pension funds in the implementation of the reform. 

5 

 
 
The Netherlands has proposed to remove the ‘Regional Mobility Teams’ measure from its 
RRP, based on Article 21 of Regulation (EU) 2021/241, and to  replace it with a new measure 
through which an up and reskilling budget is offered to unemployed persons with a weak labour 
market position. Contrary to what was expected when the original scheme was set up, the labour 
market  situation  quickly  recovered  from  the  initial  deterioration  at  the  start  of  the  COVID-19 
pandemic. This led to a lower-than-expected take-up of services by employment agencies under 
the Regional Mobility Teams scheme. The Netherlands has proposed that the remaining resources 
freed  up  by  this  removal  are  used  for  a  new  measure.  This  new  measure  aims  to  increase  re-
employment  of  persons  who  receive  temporary  unemployment  benefits  and  who  have  a  weak 
labour market position with a high risk of long-term unemployment. Under this measure, funding 
is provided to the Netherlands’ Employment Insurance Agency (UWV). The UWV will select the 
people entitled to receive up- and reskilling based on a questionnaire which identifies whether a 
person has a weak labour market position as well as on UWV counsellor’s assessment of the needs 
of the unemployed. Agreements have been made in various sectors between UWV and employers 
to  enable  the  participants  to  match  employers’  needs  with  the  targeted  up  and  reskilling.  This 
alternative measure has a permanent character and can be expected to support persons at the margin 
of the labour market in a more structural and targeted way than the scheme it replaces, which was 
a temporary one, open for both employed and unemployed persons. 

Component 5 (Strengthening public health care and pandemic-preparedness): 

Based on Article 21 of Regulation (EU) 2021/241, the Netherlands has proposed to  amend the 
C5.1 I1 measure ‘Temporary additional human resources capacity for care in times of crisis’.  

The Netherlands has proposed to replace the ‘extra hands in care’ and ‘coronajobs’ schemes 
by a more effective scheme to structurally address labour shortages in the health care sector. 
Through vocational education and ‘on the job training’, the scheme aims to increase the number 
of healthcare staff recruited and to reduce the outflow of care workers. This alternative measure 
can therefore be expected to address the labour shortage in the healthcare sector in an even more 
structural way than the measures it replaces, which was focused on temporary recruitment of health 
and support staff during crisis times. The alternative scheme in addition aims to stimulate regional 
cooperation between healthcare institutions in addressing labour shortages.   

The  proposed  target  for  the  new  scheme  consists  of  8325  individuals  who  started  the 
programme  for  vocational  education  and  on  the  job  training  in  2023-2024.  In  addition,  to 
prove  the  structural  character  of  the  scheme,  the  Netherlands  has  proposed  a  milestone  for  the 
adoption by Q4 2024 of a new framework, permanently embedding training in the healthcare sector 
in a larger programme to address labour shortages in the sector. 

Component 8 (REPowerEU): 

Under  the  REPowerEU  chapter  and  based  on  Article  21c  of  Regulation  (EU)  2021/241,  the 
Netherlands has proposed measures for one scaled-up investment and one new reform:  

Investment 8.1 ‘Investment subsidy for sustainable energy and energy savings’: The objective 
of this measure is to scale-up the existing measure of the same name in component 3. It subsidises 
energy efficiency interventions of homeowners and small businesses. The eligible interventions 

6 

 
 
are the installation of (hybrid) heat pumps, solar water heaters and electric cooking installations as 
well as connections to the heat grid and insulations. The goal is to incentivise households and small 
businesses to  reduce their dependency on natural  gas and  reduce overall energy demand in  the 
Netherlands.  

Reform  8.2  ‘Energy  market  reform  package’:  The  reform  aims  to  tackle  congestion  on  the 
Dutch electricity grid and to achieve the climate neutrality of energy systems. It has three sub-
parts. The first sub-part contains specific actions taken under the National Action Programme Grid 
Congestion.  These  include  changes  to  the  electricity  grid  rules  allowing  greater  flexibility  for 
market  participants  in  the  allocation  of  grid  capacity.  Another  element  of  this  sub-part  is  the 
completion of provincial electricity grid investment programmes. These programmes are intended 
to  prioritise  energy  infrastructure  projects  at  the  provincial  level.  Under  the  second  part,  the 
government commits to adapting the framework within which network operators prioritise their 
investments to ensure that those investments into the electricity grid are made that are most needed 
to  reduce  congestion  (taking  into  account  the  provincial  infrastructure  programmes  drawn-up 
under  the  first  sub-part).  The  third  sub-part  contains  a  modification  of  the  Environment  and 
Planning  Act,  with  the  aim  of  accelerating  judicial  procedures  dealing  with  appeals  against 
permitting decisions by government bodies. 

The measures presented under the REPowerEU chapter are consistent with the REPowerEU 
objectives set out in the RRF Regulation. The implementation of the measures included in the 
REPowerEU  chapter  are  expected  to  contribute  notably  to  supporting  the  objectives  in  Article 
21c(3),  points  (b)  (boosting  energy  efficiency  in  buildings  and  critical  energy  infrastructure, 
decarbonising  industry, increasing  the production and uptake of sustainable biomethane and of 
renewable or fossil-free hydrogen, and increasing the share and accelerating the deployment of 
renewable  energy)  and  (e)  (addressing  internal  and  cross-border  energy  transmission  and 
distribution  bottlenecks,  supporting  electricity  storage  and  accelerating  the  integration  of 
renewable energy sources, and supporting zero-emission transport and its infrastructure, including 
railways)  of  that  Regulation.  The  energy  efficiency  subsidy  scheme  substantially  reduces  the 
financial burden for subsidy applicants to reduce their energy demand and allows for a broad set 
of energy saving interventions. The energy market reform package aims to address the issue of 
grid congestion in the short term and climate neutrality of the energy systems in the longer term 
and  addresses  country-specific  recommendations  made  in  2022.  Making  the  allocation  of  grid 
capacity more flexible is expected to have a direct impact on energy transmission and distribution 
bottlenecks in the Netherlands as well as accelerating the integration and deployment of renewable 
energy sources. The latter will also be supported by the acceleration of permitting procedures for 
renewable energy projects as well as a better prioritisation of grid investments.  

Other elements not covered by assessment criteria 

The description of the administrative organisation, gender equality, security self-assessment and 
communication as reflected in the previous Staff Working Document (2022) 292 remains valid. 

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, 

7 

 
 
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 TFEU1. When State aid is present and it requires notification, it is the duty 
of  the  Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance with Article 108(3) TFEU. In this respect, the State aid analysis carried out by  the 
Netherlands in the recovery and resilience plan cannot be deemed a State aid notification. In as far 
as the Netherlands 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 
the Netherlands to ensure full compliance with the applicable rules. 

Table 1: new and modified components and associated costs. 

Component 
C1: Promoting the green transition 
C2: Accelerating the digital transformation 
C3:  Improving  the  housing  market  and  making  real 
estate more energy efficient 
C4:  Strengthening  the  labour  market,  pensions  and 
future-oriented education 
C5:  Strengthening  public  health  care  and  pandemic 
preparedness 
C8: REPowerEU 

Status 
Modified 
Modified 
Modified 

Costs (EUR million) 
1836.3 
1071.8 
1387.3 

Modified 

241.2 

Modified 

171.7 

New 

735.0 

3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

3.1 Comprehensive  and  adequately  balanced  response  to  the  economic  and  social 

situation 

The Netherlands’ modified plan along with the REPowerEU chapter includes a balanced set 
of  reforms  and  investments  contributing  to  the  Union’s  economic,  social  and  territorial 
cohesion  by  referring  to  the  six  pillars  of  Article  3  of  the  Regulation  (EU)  2021/241.  The 
modification of the plan along with the REPowerEU chapter only impacts the assessment of the 

1 Annex to the Communication to the Commission of 9 March 2023 on the Approval of the content of a draft for a 
Commission Regulation 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;  available  at: 
https://competition-policy.ec.europa.eu/system/files/2023-
03/GBER_amendment_2023_EC_communication_annex_0.pdf 

8 

 
 
 
 
 
 
contribution  of the plan to  pillar 1 on the green transition.  For the other pillars, the nature and 
extent of the proposed modifications to the RRP do not have an impact on the previous assessment 
of  the  plan’s  comprehensive  and  adequately  balanced  response  to  the  economic  and  social 
situation, and on its appropriate contribution to all six pillars referred to in Article 3 of the RRF 
Regulation, as reflected in Staff Working Document SWD(2022) 292 final. Regarding the green 
transition  pillar, the Netherlands’ modified RRP along  with  the REPowerEU chapter addresses 
green challenges in particular under Component 1 (Promoting the green transition), Component 3 
(Improving the housing market and making real estate more energy efficient) and Component 8 
(REPowerEU).  

The measures in the REPowerEU chapter contribute to the attainment of the Union’s 2030 
climate  targets  and  the  objective  of  EU  climate  neutrality  by  2050  by  contributing  to 
significant energy demand reductions and the deployment of renewable energy. The energy 
efficiency  subsidy  ‘Investment  subsidy  for  sustainable  energy  and  energy  savings’  from 
component 3.2 has been expanded substantially under the REPowerEU chapter and is expected to 
reduce energy demand by 30% on average. The energy market reform package includes actions to 
accelerate and facilitate the deployment of renewable energy in the Netherlands.  

*** 

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

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

Green 
transition 

Digital 
transform
ation 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

Health, 
and 
economic, 
social and 
institution
al 
resilience 

Policies 
for the 
next 
generati
on 

C1: Promoting green 
transition 
C2: Accelerating digital 
transformation 
C3: Improving the 
housing market and 
sustainably built 
environment 
C4: Strengthening the 
labour market, pensions 

● 

○ 

● 

● 

● 

● 

○ 

● 

9 

● 

● 

○ 

○ 

● 

● 

○ 

● 

 
 
 
 
 
 
 
 
 
 
 
 
and future-oriented 
education 
C5: Strengthening the 
public health sector and 
pandemic preparedness 
C8: REPowerEU 

● 

● 

● 

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

3.2 Link with country-specific recommendations and the European Semester  

Overall, the Netherlands’ modified RRP represents a comprehensive and adequate response 
to the economic and social challenges faced by the Netherlands. By replacing and modifying a 
small number of measures and introducing a new reform and a scaled-up investment, the modified 
plan continues to address all or a significant subset of challenges identified in the relevant country-
specific recommendations (CSRs). 

The modified RRP takes into account country-specific recommendations formally adopted 
by  the  Council  prior  to  its  submission.  It  continues  to  address  the  2022  country-specific 
recommendations.  The  2023  CSRs  on  energy  were  taken  into  account  in  the  proposed 
modifications, in particular by expanding the energy efficiency subsidy from component 3.2 and 
by  addressing  distribution  bottlenecks  in  the  Dutch  electricity  grid  through  an  energy  market 
reform package in the REPowerEU chapter.  

The  2022  CSRs  for  the  Netherlands  covered  several  policy  areas.  The  Netherlands  was 
recommended  to  reduce  distortions  in  the  housing  market  which  is  characterised  by  its  long-
standing  bias  towards  debt-financed  home  ownership  and  inelastic  supply  contributing  to  high 
prices  and  high  rents  on  the  private  rental  market.  The  Netherlands  was  also  recommended  to 
implement its pension reform. On the labour market, the Netherlands was recommended to reduce 
the incentives for flexible types of employment, improve the position of self-employed without 
employees, reduce labour shortages and improve up- and reskilling, in particular of those at the 
margins of the labour market. Lastly, the Netherlands was recommended to reduce its reliance on 
fossil  fuels  by  increasing  the  share  of  renewable  energy  and  boosting  network  infrastructure 
investments and to facilitate the transition to sustainable agriculture and transport.  

The modifications of measures in components 1, 2, 3 4 and 5 do not materially change their 
contribution  to  addressing  a  significant  subset  of  the  challenges  identified  in  the  relevant 
CSRs. Despite delays to the implementation of some of the measures, the overall ambition of most 
of  the  modified  measures  remains  the  same.  The  modification  of  component  4,  through  the 
introduction of an up- and reskilling budget for unemployed persons with a weak labour market 
position, addresses the 2022 CSR 3 on strengthening up- and reskilling opportunities, notably for 
those at the margins of the labour market. The new element on vocational education and ‘on the 
job training’ under component 5 in the amended health care measure is expected to facilitate an 
increase in the number of staff recruited. It is set to address the labour shortage in healthcare in a 

10 

 
 
 
 
 
 
 
 
 
 
  
 
more structural way, thereby reinforcing the contribution to the fulfilment of CSR 3 in 2022 on 
labour shortages in health care and up- and reskilling opportunities. 

New  measures  included  in  the  REPowerEU  chapter  of  the  Dutch  plan  expand  public 
investment for the green transition and contribute to reducing energy demand and tackling 
congestion  on  the  electricity  grid.  Under  the  REPowerEU  chapter,  investments  into  energy 
efficiency  in  buildings  are  expanded  significantly,  more  than  doubling  the  energy  efficiency 
interventions foreseen in the original plan. This is expected to further reduce energy demand and 
reliance on fossil fuels in the Netherlands, contributing to address CSRs 4 of 2022 and 2023. These 
CSRs are also expected to be addressed by the energy market reform package through a facilitated 
deployment of renewables, enhanced framework conditions for investments into electricity grids, 
improvements to permitting procedures for renewable energy projects, as well as changes to the 
rules governing capacity allocation of the electricity grid, contributing to reducing congestion.    

*** 

Taking into consideration the reforms and investments envisaged by the Netherlands, 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 the Netherlands. 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 nature and extent of the proposed modifications to the Netherlands’ recovery and resilience 
plan do not have a material impact on the previous assessment (rating of A) of the plan’s impact 
on  the  growth  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 the previous SWD (2022) 292. 

3.4 The principle of ‘do no significant harm’  

***   

The nature and extent of the proposed modifications to the Netherlands’ recovery and resilience 
plan do not have a material impact on the previous assessment (rating of A) that no measure for 

11 

 
 
 
 
the implementation of reforms and investment projects included in the plan is expected to do a 
significant harm to environmental objectives within the meaning of Article 17 of Regulation (EU) 
No  2020/852  (the  principle  of  ‘do  no  significant  harm’),  as  reflected  in  the  previous  SWD 
(2022)292. 

3.5 Green transition 

Both measures in the REPowerEU  chapter are expected  to significantly contribute to the 
green  transition,  or  to  addressing  the  challenges  resulting  therefrom,  as  well  as  to  the 
achievement  of  the  Union  2030  climate  targets  while  complying  with  the  objective  of  EU 
climate neutrality by 2050.  

One investment will subsidise energy efficiency improvements in the built environment, such 
as  insulation  measures,  the  installation  of  solar  boilers,  heat  pumps  and  electric  cooking 
installations and connections to the heat grid. These interventions have the objective of reducing 
primary energy demand by 30% on average. This measure is a scale up of an existing measure in 
component 3 of the existing plan, which thanks to the REPowerEU chapter, more than doubles the 
total number of interventions. It thereby provides a significant contribution to reducing emissions 
stemming  from  the  built  environment  in  the  Netherlands,  which  in  total  accounted  for  15%  of 
greenhouse gas emissions in the Netherlands in 2021.2 In addition to increasing the target of the 
measure, the modified plan also broadens the scope of the measure. Both for the existing part of 
the  measure  as  well  as  the  scaled-up  part  electric  stoves  are  added  to  the  list  of  eligible 
interventions and the subsidy is no longer restricted to property owners, but also associations of 
owners and small businesses.  

The  reform  in  the  REPowerEU  chapter  is  expected  to  facilitate  the  integration  of  energy 
from renewable sources into the system, a metric on which the Netherlands is lagging the 
rest of the EU. As the Dutch electricity grid is heavily congested in some regions of the country, 
more flexibility to reallocate capacity and incentives to reduce capacity demand are expected to 
alleviate congestion to some degree. The reform also includes better prioritisation and coordination 
of  energy  infrastructure  investments,  also  at  regional  level.  Lastly,  permitting  procedures  for 
renewable energy projects are expected to contribute to an accelerated take up of renewable energy 
in the country, directly contributing to the green transition.  

Climate target 

On the basis of the assessment guidelines provided for in sub-criterion 5b, the measures in 
the modified RRP (including the REPowerEU chapter) supporting climate change objectives 
account for 54,9% of the plan’s total allocation (i.e. above the 37% required), based on the 
methodology  for  climate  tracking  set  out  in  Annex  VI  to  Regulation  (EU)  2021/241. 
Additionally, the proposed measures within the REPowerEU chapter supporting climate change 

2 Source: Statistics Netherlands 

12 

 
 
 
 
 
objectives account for 100% of the chapter’s total allocation (i.e., more than the 37% required), 
based on the methodology for climate tracking set out in Annex VI of that Regulation. The only 
investment of the chapter, a subsidy for energy efficiency improvements in the built environment, 
fully accounts for this contribution. 

*** 

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 contributes 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 to the RRF Regulation. 

3.6 Digital transition 

*** 

The nature and extent of the proposed modifications to the Netherlands’ recovery and resilience 
plan do not have a material impact on the previous assessment (rating of A) of the contribution 
of the plan to the digital transition and to the digital target, as reflected in the previous SWD 
(2022)292. 

3.7 Lasting impact of the plan 

*** 

The nature and extent of the proposed modifications to the Netherlands’ 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 the Netherlands, as reflected in the previous SWD (2022)292. 

3.8 Milestones, targets, monitoring and implementation 

The  modification  of  the  Netherlands’  recovery  and  resilience  plan  also  includes  a  limited 
update  of  the  monitoring  and  implementation  framework  to  reflect  the  ongoing  work  to 
further streamline the monitoring and implementation set-up. Most of the aspects of the set-
up,  which  relies  on  a  decentralised  system  of  intermediary  declarations,  remain  the  same  and 
modifications  are  limited.  The  Programme  Directorate  for  the  RRF  in  the  Ministry  of  Finance 
remains the coordinating body which prepares general guidelines which define how milestones 
and  targets  are  to  be  reported  and  accompanied  by  additional  evidence.  In  addition,  these 
guidelines will also be included in the government budget regulation which will be updated each 
year instead of in a model annex.  The RRP measures remain integrated into the internal control 
cycle of the various ministries involved in the implementation of the RRP and will be included in 
their annual reports, but they will not be included as a separate appendix in their annual reports. 

13 

 
 
 
  
These changes have no impact on the milestone which had already been included in the plan on 
the development of a central reporting tool nor on the milestones related to the legal mandate of 
the coordinating and audit body. Overall, the nature and extent of the proposed modification do 
not have a material impact on the previous assessment. 

The  milestones  and  targets  of  the  modified  Dutch  recovery  and  resilience  plan  enable  an 
adequate monitoring of the plan’s implementation. The milestones and targets contain the key 
elements of the measures and thus are relevant for the implementation of the proposed changes. 
The  monitoring  milestones  and  targets  appear  comprehensive  and  clear  to  ensure  that  their 
completion  can  be  traced  and  verified.  In  addition,  the  Netherlands  has  described  the  relevant 
verification mechanisms, data collection systems and responsibilities sufficiently. They can also 
be qualified as clear, robust and effective to ensure effective completion of milestones and targets.  

*** 

The arrangements proposed by the Netherlands 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 

The Netherlands has provided individual estimated costs for all the new measures that entail 
a cost in the recovery and resilience plan, including the REPowerEU chapter. The Netherlands 
has  also  provided  individual  justifications  for  all  the  measures  whose  modifications  entailed  a 
change  in  the  cost  estimates  or  related  target  including  on  the  proportionality  of  the  relevant 
amendments.   

The  cost  information  provided  by  the  Netherlands  is  generally  detailed  and  well 
substantiated. The Netherlands provided detailed estimates and assumptions on costs using 
the  standard  template  table,  which  was  intended  to  summarise  the  key  information  and 
evidence on costing. Moreover, the Netherlands submitted separate documents including more 
elaborate descriptions of the methodology underlying the cost calculations. Lastly, the Netherlands 
submitted  a  dedicated  file  outlining  the  key  drivers  and  changes  in  the  costs  of  the  amended 
measures and their proportionality. 

The assessment of the cost estimates and inherent supporting documents shows that the majority 
of the costs of the new measures are well justified, reasonable, plausible and do not include costs 
covered by existing or planned EU financing and are commensurate to the expected economic and 
social  impact  of  the  envisaged  measures.  Moreover,  the  changes  in  the  costs  estimates  of  the 
amended measures are justified but not always proportional to the change in target. 

14 

 
 
 
 
Reasonable costs 

Overall,  the  assumptions  used  by  the  Netherlands  to  estimate  the  costs  of  the  new  measures, 
including  those  in  the  REPowerEU  chapter,  provide  a  reasonable  explanation  of  the  key  cost 
drivers of the measures. The calculations are generally clearly spelled out allowing to identify the 
methodology  used,  even  if  for  a  small  number  of  measures  this  information  is  not  as  detailed. 
Nevertheless, there is no evidence that would allow doubting the costing estimates provided.  

The  new  measures  included  in  the  Dutch  recovery  and  resilience  plan,  including  those  in  the 
REPowerEU chapter, comply with the eligibility criteria set out in the RRF Regulation. All costs 
are  incurred  for  reforms  and  investments  after  February  2020  and  after  February  2022  for  the 
measures in the REPowerEU chapter. Value-added tax (VAT) is not included in any of the cost 
estimates.  

The reasonability of the costs of the amended measures have changed from the initial assessment 
of these measures, as the changes in the cost estimates were duly justified but not always fully 
proportional to the change in target. In the case of measures being amended under Article 21(1) of 
Regulation (EU) 2021/241 for cost-related reasons, sufficient information has been provided to 
justify the objective circumstances of the changes in the cost estimates or related target. In this 
context, the reasonability of the cost estimates, taking into account the new measures, including 
those in the REPowerEU chapter, and the amended measures, has been established to a medium 
extent. 

Plausible costs  

The amount of the estimated costs of new measures, including those in the REPowerEU chapter, 
is in line with the nature and type of the envisaged reforms and investments. For most of these 
measures,  the  Netherlands  provided  supporting  documents  and  links  to  online  sources  to 
substantiate  the  cost  estimates,  including  explanations  of  how  past  projects  relate  to  the  cost 
estimates of the new measures.  

The plausibility of the costs of the amended measures has changed from the initial assessment of 
these measures, as the changes in the cost estimates for all of them are duly justified but not always 
fully proportional to the change in target. Sufficient information has been provided to justify the 
objective circumstances of the changes in the cost estimates or related target. 

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

No double funding 

The  Netherlands  has  indicated  for  each  individual  new  measure,  including  those  in  the 
REPowerEU chapter, that the costs to be financed by the RRF will not be funded at the same time 
by  other  Union  funding  sources.  Furthermore,  the  set-up  to  prevent,  detect  and  correct  double 
funding has not been altered by the modification of the plan.  

15 

 
 
 
Commensurate and cost-efficient costs 

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

*** 

The justification  provided by the Netherlands  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.  

The Netherlands 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  

The control system and arrangements proposed in the RRP of the Netherlands are based on 
robust  processes  and  structures  used  in  the  existing  national  framework.  Actors  and  their 
roles and responsibilities for the performance of the internal control tasks are clearly described in 
the RRP. A dedicated Programme Directorate for the Facility in the Ministry of Finance is planned 
to be assigned as the coordinating body and as such has the responsibility for the protection of the 
Union’s financial interests. Via intermediary-declarations, implementing bodies such as ministries, 
agencies or consortia are to confirm the protection of the Union’s financial interest and the validity 
of the reported data on milestones and targets. Those intermediary-declarations are to be verified 
and  signed  by  the  financial  economic  affairs  directorates  of  each  ministry.  The  audit  authority 
‘auditdienst rijk’, an independent service within the Ministry of Finance, is to carry out regular 
audits of the management and control systems, including substantive testing.   

The modification of the Netherlands’ recovery and resilience plan also includes an update of 
the control and audit framework to reflect the ongoing work in the Netherlands to further 
streamline the relevant processes. It includes an update of the procedure for preventing double 

16 

 
 
 
funding, notably with regards to the use of Arachne. Arachne will not be mandatory. If a policy 
department chooses not to use Arachne, it is obliged to use an alternative method to avoid the risk 
of conflict of interest or non-compliance with State aid rules or the operational, administrative and 
financial  capacity  of  companies  to  carry  out  operations  co-financed  by  the  European  Union. 
Concerning  the  declaration  on  the  absence  of  double  funding  signed  by  the  relevant  policy 
department, this will be covered in the management declarations that will be signed at measure 
level.  Therefore,  to  avoid  duplication  a  separate  declaration  per  policy  directorate  on  double 
funding  has  been  removed.  Other  procedures  related  to  double  funding  and  more  broadly  the 
protection  of  the  financial  interest  of  the  European  Union  remain  in  place  and  are  considered 
adequate  and  robust  as  reflected  in  the  previous  SWD  (2022)  292.  The  chapter  also  includes 
additional  clarifications  on  how  compliance  with  applicable  Union  and  national  law  will  be 
ensured.  In  addition,  several  references  have  been  added  in  relation  to  CEDAR  (Central  IT 
repository for which a separate milestone has been included in the original plan) and the central 
collection of data for monitoring of the achievement of milestones  and  targets,  as well  as data 
related to art. 22(2), point (d) of the RRF Regulation in line with the original milestone description. 

*** 

The arrangements proposed by the Netherlands 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 Union programmes, are assessed to be adequate. This would warrant a rating 
of A under the assessment criterion 2.10 of Annex V to the RRF Regulation. 

3.11 Coherence 

*** 

The nature and extent of the proposed modifications to the Netherlands’ recovery and resilience 
plan do not have a material impact on the previous assessment (rating of A) of the coherence of 
the actions proposed by the Netherlands, as reflected in the previous SWD(2022)292. 

3.12 REPowerEU 

The REPowerEU chapter measures directly contribute to the deployment and integration 
of renewable energy sources. As a result, they help reduce reliance on fossil fuels and 
contribute to increasing energy security and diversification of the Union’s energy supply. 

In the implementation of the modified plan including the REPowerEU chapter, the stakeholders 
are  consulted  for  the  adoption  of  the  relevant  implementing  acts  for  each  measure  as  well  as 
regularly updated on the progress of the implementation of the plan in the Netherlands’ annual 
event on the implementation of the Dutch RRP. To ensure ownership by the relevant actors, it is 
crucial  to  involve  all  local  authorities  and  stakeholders  concerned,  including  social  partners, 

17 

 
 
 
 
throughout  the  implementation  of  the  investments  and  reforms  included  in  the  modified  RRP 
including  the  REPowerEU  chapter.  The  energy  market  reform  package  has  been  developed  in 
cooperation with a citizen’s council that adopted a number of recommendations to the government 
on the development of energy markets in the Netherlands.   

Investment  8.1  subsidises  several  interventions  to  improve  energy  efficiency  in  the  built 
environment (open to households, landlords and small businesses). The eligible interventions 
to  be  subsidised  under  the  measure  are  insulation  interventions,  heat  pumps,  solar  boilers, 
connection  to  the  heat  grid  as  well  as  electric  cooking  installations.  These  interventions  are 
expected  to  decrease  energy  demand  and  contribute  to  the  electrification  of  heat  generation, 
thereby supporting the decarbonisation of the Dutch energy generation and the uptake of renewable 
energy. The investment is expected to have a lasting impact due to the longevity of the subsidised 
installations and their long-term impact on energy demand. Contrary to the original part of the 
measure in component 3, the scaled-up part has two intermediate targets which ensures that a large 
part of the interventions is finalised already in 2022, 2023 and 2024. The investment is a scale-up 
of an existing measure in component 3. The Netherlands also explained that it is also coherent with 
other policy efforts by the Netherlands not included in the RRP.  

Reform 8.2 is a package of actions to help reduce congestion on the Dutch electricity grid 
and facilitate the decarbonisation of energy production. The reform consists of three sub-parts. 
The first part contains a national action programme to tackle grid congestion. The rules governing 
grid capacity allocation  on the Dutch electricity  code  are amended to  allow more flexibility  to 
market  participants  to  reallocate  capacity  as  well  as  incentives  to  reduce  demand  for  capacity. 
Additionally, provinces are expected to draw up provincial infrastructure investment programmes. 
These programmes are intended to prioritise investment plans by grid operators. Under the second 
part,  the  Netherlands  commits  to  setting  up  a  framework  to  prioritise  investments  into  the 
electricity  grid  by  grid  operators.  This  framework  ensures  that  national  as  well  as  provincial 
infrastructure  investment  programmes  (drawn-up  under  the  first  sub-part)  are  the  basis  for 
prioritising investments by grid operators. This is expected to accelerate those investments that are 
necessary to address congestion of the grid in some regions of the country. The framework will 
enter  into  force  in  2023  by  means  of  ministerial  decree  and  will  be  anchored  in  law  more 
permanently with entry into force of the ‘Energy law’, which is included as a reform in component 
1. Lastly, the measure foresees changes to the Dutch environmental and planning law simplifying 
legal procedures in administrative cases dealing with renewable energy projects. The changes to 
the law are expected to shorten the duration of such cases and therefore contribute to the quicker 
deployment of renewable energy in the Netherlands. Overall, the reform package is a coherent set 
of actions that tackle grid congestion and the low share of renewables in the Dutch energy mix 
from different angles – with both short-term legal modifications to speed up investments as well 
as the formulation of long-term strategies with concrete steps. It also complements the existing 
measure ‘Energy law’ in component 1 as it anticipates some of its elements and includes actions 
that support the objectives of the law.  

While the above-mentioned reforms  do  not  directly tackle energy poverty, the Netherlands has 
explained that a number of national measures have been taken in 2022 and 2023 to cushion the 

18 

 
 
impact  of  energy  price  increases  for  households  and  businesses  that  are  coherent  with  the 
REPowerEU objectives and complementary to the measures contained in the 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  

All measures in the REPowerEU chapter and therefore 100% of its estimated costs have a 
cross-country or multi-country dimension or effect. As described in detail above, the measures 
in the REPowerEU chapter will directly contribute to the integration of renewable energy sources 
and the reduction of energy demand. As a result, they contribute to reducing the dependency on 
fossil fuels and secure energy supply in the Union as a whole and can therefore be considered as 
having  a positive  cross-border  effect  in line with the Commission’s guidance in  the  context of 
REPowerEU.3 

*** 

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. 

REPowerEU measure 

Investment  subsidy  for  sustainable  energy  and 
energy savings 

(EUR 

Costs 
million) 
735 

Contribution  to  the 
target in % 
100% 

TOTAL:  735 

100% 

3 Commission Notice Guidance on Recovery and Resilience Plans in the context of REPowerEU 2023/C 
80/01, pages 21-22 

19 

 
 
  
 
 
 
 
ANNEX: Climate tracking and digital tagging  

(Sub)-Measure 
ID 

(Sub-)Measure 
Name 

Cost (EUR 
mln) 

Climate 
Int. Field  Coeff. % 

Digital* 

Int. Field 

Coeff. % 

P1.1I1-1 

P1.1I1-2 

P1.1I1-3 

P1.1I1-4 

P1.1I2-1 

P1.1I2-2 

P1.1I2-3 

P1.1I3 

P1.1I4-1 

260 

074 

100% 

60 

077 

100% 

131 

050 

40% 

243 

050 

40% 

30 

34 

5 

56 

10 

032 

100% 

022 

100% 

01 

100% 

074 

100% 

022 

100% 

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

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Sub)-Measure 
ID 

(Sub-)Measure 
Name 

Cost (EUR 
mln) 

Climate 
Int. Field  Coeff. % 

Digital* 

Int. Field 

Coeff. % 

P1.1I4-2 

P1.2I1 

P1.2I2 

P2.1I1 

P2.1I2-1 

P2.1I2-2 

P2.1I3 

P2.1I4 

P2.2I1 

P2.2I2 

P2.2I3 

P2.3I1 

P2.3I2 

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

19 

027 

100% 

714 

275 

264 

44 

16 

209 

36 

049 

049 

40% 

40% 

021quater 

100% 

021ter 

100% 

108 

100% 

012 

100% 

084bis 

40% 

084bis 

100% 

149 

071 

40% 

071 

100% 

55 

076bis 

40% 

076bis 

100% 

129 

063bis 

40% 

063bis 

100% 

94 

75 

011 

100% 

011quater 

100% 

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Sub)-Measure 
ID 

(Sub-)Measure 
Name 

Cost (EUR 
mln) 

Climate 
Int. Field  Coeff. % 

Digital* 

Int. Field 

Coeff. % 

P3.1I1 

P3.1I1 

P3.1I1 

P3.2I1 

P3.2I2 

P4.2I1 

P4.2I5 

P5.1I3 

P5.1I4 

P8.I1 

Unlocking new 
construction 
projects – 
removal of 
bottlenecks 
Unlocking new 
construction 
projects – 
reducing nitrogen 
deposition 
Unlocking new 
construction 
projects – climate 
change adaptation 
Subsidy scheme 
for sustainability 
of public sector 
real estate 
Investment 
subsidy for 
sustainable 
energy and 
energy savings 
(ISDE) 
National 
Education Lab AI 
Laptops and 
tablets for online 
and hybrid 
education to 
combat and 
mitigate learning 
losses 
SET COVID-19  

Health Research 
Infrastructure 
(HRI) 
Scaled-up 
measure: 
Investment 
subsidy for 
sustainable 
energy and 
energy savings 
(ISDE) 

109 

048 

40% 

3 

049 

40% 

191 

037 

100% 

225 

026bis 

100% 

624 

025bis 

100% 

36 

24 

50 

22 

735 

025bis 

100% 

22 

012 

012 

100% 

100% 

013 

013 

100% 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
*  Reforms and investments in the REPowerEU chapter are not taken into account when calculating the 
plan’s contribution to the digital target requirement set by Regulation (EU) 2021/241 

23