COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Spain Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10150/2021; ST 10150/2021 ADD 1 REV 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Spain
Date: 2023-10-02
Institutions: European Commission, Secretariat-General
Subjects: Spain, economic recovery, economic reform, energy policy, fiscal policy, housing policy, renewable energy, stability pact, stability programme, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 2.10.2023  SWD(2023) 326 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Spain Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10150/2021; ST 10150/2021 ADD 1 REV 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Spain {COM(2023) 576 final}  
 
 
Table of contents 
1. 

Executive summary ............................................................................................................................... 3 

2.  Objectives of the modification of the plan ........................................................................................... 4 

2.1 

 The modified plan addresses Spain’s main newly emerged challenges ...................................... 4 

2.2   Overview of new and modified components................................................................................ 5 

2.3 

 Other elements not covered by assessment criteria ................................................................. 27 

Consistency with other programmes .................................................................................................. 27 

Consistency with the challenges and priorities identified in the most recent euro area 
recommendation ................................................................................................................................ 27 

National arrangements for the implementation of the plan .............................................................. 28 

Gender equality and equal opportunities for all ................................................................................ 28 

Consultation process ........................................................................................................................... 28 

Digital security self-assessment .......................................................................................................... 29 

Communication Strategy .................................................................................................................... 29 

State aid .............................................................................................................................................. 30 

3. 

Summary of the assessment of the plan ............................................................................................ 30 

3.1. 

Comprehensive and adequately balanced response to the economic and social situation ...... 30 

3.2. 

Link with country-specific recommendations and the European Semester ............................... 32 

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 ...... 34 

3.4. 

The principle of ‘do no significant harm’ .................................................................................... 35 

3.5.  Green transition .......................................................................................................................... 37 

3.6. 

Digital transition .......................................................................................................................... 39 

3.7. 

Lasting impact of the plan ........................................................................................................... 42 

3.8.  Milestones, targets, monitoring and implementation................................................................ 43 

3.9. 

Costing ........................................................................................................................................ 44 

3.10.  Controls and audit ....................................................................................................................... 46 

3.11.  Coherence ................................................................................................................................... 47 

3.12.  REPowerEU ................................................................................................................................. 47 

3.13.  Cross-border or multi-country dimension or effect ................................................................... 49 

ANNEX I: Climate tracking and digital tagging (new measures compared to original plan are 
highlighted) ............................................................................................................................................. 50 

1 

 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

Spain weathered well the effects of Russia’s war of aggression against Ukraine. Real GDP grew 
by 6.4% last year and employment grew by 3.1% to above pre-pandemic levels. However, despite 
low direct exposure to the disruption of energy supply from Russia, Spain’s large external energy 
dependence resulted in a surge in energy prices which contributed to increased inflation, reaching 
an average of 8.3% in 2022.  

In this context, effective policies to promote a green transition are even more necessary, notably 
to improve energy efficiency and decarbonisation, and clean and sustainable mobility, to scale up 
manufacturing of clean technologies, to improve water and waste management, and to support the 
reskilling and upskilling of the workforce. Structural factors like low private R&D expenditure 
and shortfalls in the business environment keep hampering productivity growth. The energy crisis 
also  led  to  social  challenges  affecting  disproportionately  vulnerable  households.  The  effects  of 
population ageing will pose an increasing challenge to ensuring public debt sustainability.  

In light of the socio-economic challenges that Spain has been facing since the beginning of 2022, 
the country submitted a modified Recovery and Resilience Plan (RRP) along with a REPowerEU 
chapter on 6 June 2023. For the modification of its RRP, Spain has relied on the following legal 
bases:  Article  14(2)  to  include  additional  loan  support,  Article  18(2)  to  take  into  account  the 
updated  maximum  financial  contribution,  Article  21  to  amend  the  RRP  due  to  objective 
circumstances and Article 21c to include additional resources from  the EU’s Emission Trading 
System (ETS) revenues or from the Brexit Adjustment Reserve (BAR) for its REPowerEU chapter.  

The modifications submitted by Spain under Article 21(1) of Regulation (EU) 2021/241 affect 52 
measures  in  total.  Spain’s  proposed  REPowerEU  chapter  includes  one  reform  and  eight 
investments for a total estimated expenditure of EUR 6 917 million (of which EUR 5 217 million 
under  non-repayable  support  and  EUR  1  700  million  under  loan  support).  In  addition  to  the 
measures included in the REPowerEU chapter, Spain proposes 32 new or changed measures (23 
investments  and  nine  reforms)  on  the  basis  of  Article  18(2)  of  Regulation  (EU)  2021/241  to 
account for an upward revision of the grant allocation. Moreover, Spain proposes 27 new measures 
(20 investments and seven reforms) on the basis of Article 14 (2) of Regulation (EU) 2021/241 to 
account for loan support. 

Based on the assessment of the submitted modification and the REPowerEU chapter, the Spanish 
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 (39.9%) 

A 
(25.9%) 

A 

A 

B 

A 

A 

A 

A 

2 

 
 
 
 
 
 
2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

2.1 

 The modified plan addresses Spain’s main newly emerged challenges 

In 2022, Russia’s war of aggression against Ukraine led to a surge in energy and commodity prices 
in Spain and the EU as a whole. The 2023 Country Report1  for Spain identified challenges related 
to its reliance on fossil fuels, limited availability of social and affordable energy-efficient housing, 
circular  economy,  business  environment  and  skills  shortages.  In  addition,  Spain  also  faces  the 
challenge of ensuring public debt sustainability given the unfavourable initial fiscal position and 
higher health and pension expenditure due to population ageing, while at the same time increasing 
the  capacity  of  social  transfers  to  reduce  income  inequality  and  poverty,  narrowing  the  gap 
between  regions  and  ensuring  the  quality  of  public  services.  Against  this  backdrop,  Spain’s 
modified RRP adds measures to address its current challenges, increases the level of ambition of 
some existing measures included in the initial RRP, includes a REPowerEU chapter and modifies 
existing measures in line with the provisions of the RRF Regulation.  

Pursuant to Article 14(2) of Regulation (EU) 2021/241, Spain included in the submitted modified 
RRP a request for loan support amounting to EUR 83 160 060 000, to support 20 new investments, 
some of which build on existing measures, to stimulate private investment in the green and digital 
transition and nine new reforms. In addition, part of the requested loan support would be used in 
two new REPowerEU investments. Pursuant to Article 18(2) of Regulation (EU) 2021/241, Spain 
requested  modifications  due  to  the  increase  of  its  maximum  net  financial  contribution  from 
EUR 69 512 589 611 to EUR 77 213 906 801. The revision is part of the June 2022 update to the 
RRF grants  allocation key and  reflects Spain’s  relatively  less favourable economic outcome in 
2020  and  2021  than  initially  foreseen.  Therefore,  several  new  investments  have  been  added  or 
allocated to increase the level of ambition of existing measures. These adjustments amount to a 
total of EUR 7 701 317 190. Spain has notably added or changed 32 measures under Article 18(2) 
of Regulation (EU) 2021/241 which are new or increase the ambition of existing measures. 

The  Spanish  modified  RRP  adds  a  new  REPowerEU  chapter  pursuant  to  Article  21  (c),  of 
Regulation (EU) 2021/241. The REPowerEU includes one new reform, a scaled-up investment 
from  two  measures  under  component  7  (Development  and  integration  of  renewable  energy 
sources)  and  from  one  measure  under  component  8  (Electricity  infrastructure,  smart  grids  and 
deployment of flexibility and storage) and seven new investments in renewable hydrogen, in the 
value chain for renewable energy, in electricity networks and in the decarbonisation of industry. 
This chapter will deliver on the REPowerEU objectives, contribute to Spain’s green transition and 
help address the current challenges, in particular those identified in the ‘energy’ recommendation 
addressed to Spain in 2022 and 2023 in the framework of the European Semester. 

Pursuant to Article 21(1) of Regulation (EU) 2021/241, Spain has justified the modification of 52 
existing  measures  of  the  plan  based  on  objective  circumstances.  The  objective  circumstances 
invoked  are  mostly  related  to  the  need  to  factor  in  the  effects  of  supply  chain  disruptions, 

1 SWD(2023) 609 final 

3 

 
 
 
 
 
 
 
insufficient demand and price increases due to the high inflation experienced in 2022 and 2023, 
unexpected legal and administrative difficulties. Most of the proposed amendments relate to the 
postponement  of  the  timeline  for  completion.  Other  proposed  amendments  are  related  to  the 
modification of the targets to account for the changed circumstances and the need to redesign the 
original  measures as  the existing  ones are no longer attainable.  In addition,  errors of  a clerical 
nature  have  been  identified  in  the  text  of  the  Council  Implementing  Decision  and  have  been 
corrected.  

2.2   Overview of new and modified components 

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

Component  1  (Sustainable,  safe  and  connected  mobility  shock  plan  in  urban  and 
metropolitan environments), substantial modification: 

Reform C1.R2 (Sustainable Mobility Law): In accordance with Article 21(1) of Regulation (EU) 
2021/241, Spain has proposed to delay the completion of the milestone with sequential number 3, 
namely the entry into force of a Law on sustainable mobility, by one year. This responds to delays 
caused by a lengthier than anticipated legislative process, notably due to the need to extend the 
period  granted  during  the  public  consultations  phase  of  the  Law  and  to  subsequent  extend  the 
period for the submission of amendments in the Parliament. Spain has also proposed to replace a 
sub-measure of the Law, namely the set-up of a payment mechanism for the use of the State’s 
roads according to the ‘polluter-pays’ principle, with provisions promoting rail freight transport 
aimed  at  reducing  global  emissions  from  land  freight  transport.  This  responds  to  the  severe 
disruptions in the energy markets recorded over the past two years, resulting in an increase in the 
monetary costs borne by road users for the circulation of State’s roads, as well as to the envisaged 
introduction from 2027 of the revised Emission Trading System (ETS) at EU level, representing a 
partial overlap with the scope of the previous milestone. The partial change in the scope of the 
milestone keeps the level of ambition of the milestone unaltered, contributing to the reduction of 
greenhouse gas emissions stemming from road transport, while also addressing country-specific 
recommendations  2019.3.4  and  2020.3.7.  The  name  of  the  Law  and  of  the  reform  is  amended 
accordingly.  Moreover,  in  accordance  with  Article  18(2)  of  Regulation  (EU)  2021/241,  Spain 
proposed to increase the level of ambition of the reform by adding two new sub-measures, namely 
the development of a software application for the implementation of the cost-benefit analysis for 
infrastructure  investment,  as  well  as  the  effective  operationalisation  of  the  sandbox  office  to 
facilitate  innovations  in  the  mobility  and  transportation  sector  and  their  implementation  in  the 
market.  These  new  sub-measures  build  on  measure  C1.R2.  This  contributes  to  addressing  the 
country-specific recommendations 2020.3.3 to foster research and innovation, clean and efficient 
production and use of energy, energy infrastructure, water and waste management and sustainable 
transport.  

Reform  C1.R3  (Royal  Decree  regulating  minimum  criteria  of  low-emission  zones):  In 
accordance with Article 14(2) of Regulation (EU) 2021/241, Spain proposed a new reform which 
provides for the mandatory establishment of Low Emission Zones (LEZs) for municipalities with 

4 

 
 
 
 
 
more than 50 000 inhabitants and island territories, including the minimum requirements that the 
LEZs must comply with.  

Investment C1.I2 (Incentive scheme for the installation of recharging points, the purchase of 
electric  and  fuel  cell  vehicles  and  innovation  in  electro-mobility,  recharging  and  green 
hydrogen): In accordance with Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to 
delay  the  completion  of  target  with  sequential  number  12,  namely  the  deployment  of  238 000 
electric  vehicles  and  recharging  points,  by  two  years  and  to  add  milestone  419  to  extend  the 
implementation of the measure aimed at preserving its original level of ambition. This responds to 
delays caused by supply chain disruptions affecting the components of electric vehicles and related 
infrastructure.  

Component  2  (Implementation  of  the  Spanish  Urban  Agenda:  Urban  Rehabilitation  and 
Regeneration Plan), substantial modification:  

Investment C2.I1 (Rehabilitation programme for economic and social recovery in residential 
environments):  In  accordance  with  Article  21(1)  of  Regulation  (EU)  2021/241,  Spain  has 
proposed  to  delay  intermediate  target  with  sequential  number  27  by  one  year,  namely  the 
completion of at least 231 000 residential dwelling renovation actions in at least 160 000 unique 
dwellings, achieving on average at least a 30 % primary energy demand reduction. In addition, 
Spain has proposed a change in wording to allow not only the finalisation of renovation works, but 
also the decision to grant aid for carrying out such works, in order to reach the intermediate target. 
This responds to delays caused by slow uptake of the aid lines for renovation, as inflation and high 
raw  material  prices  led  to  lower-than-expected  demand  for  renovation  works.  Moreover,  in 
accordance with Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to lower target 
with sequential number 29 to account for the higher costs of relevant inputs, as a result of inflation 
and a shift in demand towards more expensive renovations that achieve more energy savings.  

Investment C2.I4 (Regeneration programme and demographic challenge): In accordance with 
Article  21(1)  of  Regulation  (EU)  2021/241,  Spain  proposed  to  amend  target  with  sequential 
number 34, reducing from 26 000 buildings to 4 300 buildings the target for renovating buildings 
but also committing to renovate 230 000 m2 of buildings in the tertiary sector (in municipalities 
with less than 5 000 inhabitants). As in many regions, the use of heating in residential dwellings 
is low due to climatic conditions, Spain has proposed to add buildings in the tertiary sector, which 
use more heating and cooling and therefore are in higher demand for energy efficiency measures. 
Additionally, Spain proposes to reduce the ambition of the target (for which demand was lower 
than expected) while increasing the ambition of the measure overall, by doubling the target with 
sequential  number  35,  covering  clean  energy  projects  in  municipalities  with  less  than  5 000 
inhabitants, from 250 to 500 projects (for which demand was higher than expected).    

Reform  C2.R7  (Programme  of  measures  to  promote  the  supply  of  rental  housing):  In 
accordance with Article 14(2) of Regulation (EU) 2021/241, Spain proposed an amendment of the 
Land and Urban Rehabilitation Law to help speed  up planning procedures associated with building 
rehabilitation actions and construction of buildings for the purpose of social housing, as well as a 
the publication of a guide with recommendations and best practices to simplify and speed up urban 
the  country-specific 
planning 

licensing  procedures.  This  contributes 

to  addressing 

5 

 
 
 
 
 
recommendations 2023.3.5 and 2022.4.8 to increase the availability of energy-efficient social and 
affordable housing, including through renovation. 

Investment  C2.I7  (Programme  for  the  construction  of  social  rented  housing  in  energy-
efficient  buildings):  In  accordance  with  Article  14(2)  of  Regulation  (EU)  2021/241,  Spain 
proposed to set up a Loan Facility for the Promotion of Social Housing for EUR 4 billion, a public 
investment  into  a  Facility  to  improve  access  to  finance  in  the  construction  and  renovation  of 
energy-efficient social and affordable housing. This contributes to addressing the country-specific 
recommendations 2023.3.5 and 2022.4.8 to increase the availability of energy-efficient social and 
affordable housing, including through renovation. 

Component  3  Environmental  and  Digital  Transformation  of  the  Agri-food  and  fisheries 
system, substantial modification: 

Reform C3.R2 (Development and review of the regulatory framework for the environmental 
sustainability  of  livestock  farming):  In  accordance  with  Article  18(2)  of  Regulation  (EU) 
2021/241,  Spain  proposed  to  enhance  the  scope  of  this  measure,  by  introducing  additional 
regulations on the improvement of the biosecurity of livestock transport and on the sustainable use 
of  antibiotics  in  livestock  species.  This  contributes  to  addressing  the  country-specific 
recommendations 2019.3.2 on the efficient use of resources, 2023.1.3, 2022.1.2 and 2020.3.4 on 
increasing investment in the ecological and digital transition. 

Reform  C3.R7  (Law  on  the  prevention  of  food  losses  and  food  waste):  In  accordance  with 
Article  14(2)  of  Regulation  (EU)  2021/241,  Spain  proposed  to  introduce  a  new  reform,  which 
relates to a new law on the prevention of food losses and food waste. This contributes to addressing 
the  country  specific  recommendation  2022.3.1  on  increasing  recycling  rates  to  achieve  the  EU 
objectives.  

Reform C3.R8 (Regulation of the farm information system): In accordance with Article 14(2) 
of Regulation (EU) 2021/241, Spain proposed to introduce a new measure, including a regulation 
on farm information systems to manage the agricultural and livestock policies. This contributes to 
addressing  the  country  specific  recommendations  2019.3.2  on  the  efficient  use  of  resources, 
2023.1.3, 2022.1.2 and 2020.3.4 on increasing investment in the ecological and digital transition. 

Investment C3.I1 (Plan to improve efficiency and sustainability in irrigation): In accordance 
with Article 18(2) of Regulation (EU) 2021/241, Spain proposed to increase the ambition of this 
investment to increase the number of hectares of irrigation system modernised in terms of water 
savings and energy efficiency with an increase in the estimated cost of the investment of EUR 150 
million. This contributes to addressing the country-specific recommendations 2023.1.3, 2022.1.2 
on investing in the green and digital transition  and 2020.3.6 on investing in the ecological and 
digital transition in particular in the management of water resources and waste.  

Investment C3.I2 (Plan to boost the sustainability and competitiveness of agriculture and 
livestock farming (I)): Modernising animal and plant health laboratories): In accordance with 
Article 21(1) of Regulation (EU) 2021/241, Spain asked to delay the entry into operation of the 

6 

 
 
 
 
 
biosecurity laboratories by two and a half years. This responds to delays and supply-side constrains 
due to the complexity of the construction of level 3 biosecurity laboratories.  

Investment C3.I3 (Plan to boost the sustainability and competitiveness of agriculture and 
livestock farming (II)): Strengthen capacity building and biosecurity systems in nurseries, 
cleansing  and  disinfection  centres):  In  accordance  with  Article  21(1)  of  Regulation  (EU) 
2021/241,  Spain  asked  to  delay  the  strengthening  of  training  and  biosecurity  systems  of 
disinfection  centres  and  plant  reproduction  material  production  systems  by  nine  months.  This 
responds to lack of demand in some regions in the first call for projects.  

Investment C3.I6 (Plan to promote sustainability, research, innovation and digitalisation in 
the  fisheries  sector  (I)):  Modernisation  of  the  network  of  marine  reserves  of  fisheries 
interest): In accordance with Article 21(1) of Regulation (EU) 2021/241, Spain has asked to delete 
the  requirement  to  acquire  at  least  four  pieces  of  night  vision  equipment  to  detect  prohibited 
activities  (milestone  with  sequential  number  55),  due  to  lack  of  supply  derived  from  the 
geopolitical context. This requirement represents 2% of the overall cost of the measure and does 
not materially affect the overall level of ambition of the measure.   

Investment C3.I12 (Plan to improve efficiency and sustainability in irrigation): In accordance 
with Article 14(2) of Regulation (EU) 2021/241, Spain proposed a new investment of EUR 260 
million  to  increase  the  amount  of  hectares  of  irrigation  system  modernised  in  terms  of  water 
savings and energy efficiency. This new measure builds on investment C3.I1. This contributes to 
addressing the country-specific recommendations 2023.1.3 and 2022.1.2 on investing in the green 
and digital transition and 2020.3.6 on investing in the ecological and digital transition in particular 
in the management of water resources and waste. 

Component 4 (Ecosystems and Biodiversity), substantial modification: 

Reform C4.R4 (National Strategy to combat desertification): In accordance with Article 14(2) 
of Regulation (EU) 2021/241, Spain proposed to introduce a new measure, relating to the National 
Strategy to combat desertification and its associated Action Plan for the period 2022/2026. The 
strategy  creates  a  new  framework  to  combat  desertification  and  promote  coordination  and 
cooperation among relevant agents, and create the National Committee to combat desertification, 
the  National  Council  to  combat  desertification  and  a  technical  unit  for  this  purpose  within  the 
Directorate  General  of  Biodiversity,  Forest  and  Desertification  of  the  Ministry  for  Ecological 
Transition and Demographic Challenge.  

Investment  C4.I1  (Digitalisation  of  knowledge  and  natural  heritage):  In  accordance  with 
Article  21(1)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to  delete  from  the  target  with 
sequential  number  66  the  reference  to  the  completion  of  the  upgrade  and  update  of  at  least  10 
special purpose aircrafts for firefighting. This is due to a legal issue with the provider that prevents 
the Spanish authorities from fulfilling this part of the milestone on time. The completion of the 
update  and  upgrade  of  the  aircrafts  will  be  substituted  by  a  flight  with  an  existing  precision 
airplane, to produce a mapping of 75% of the Spanish territory.  

7 

 
 
 
 
 
Investment C4.I3 (Restoration of ecosystems and green infrastructure): In accordance with 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential 
number 71 by one year. This responds to delays caused by extreme weather events.  

Investment  C4.I4  (Sustainable  forest  management):  In  accordance  with  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to delay some elements included in the milestone 
with sequential number 73 to Q2 2026. These elements are the renovation of fire brigade bases 
and  the  completion  of  forest  management  actions.  This  responds  to  delays  caused  by  price 
increases and extreme weather events. In addition, Spain has proposed to delete from the measure 
description  the  reference  to  the  acquisition  of  new  airplanes  or  helicopters  for  firefighting, 
maintaining only the reference to firefighting equipment. This responds to supply chain issues with 
the provider. 

Component 5 (Coast and water resources), substantial modification: 

Investment C5.I1 (Implementation of treatment, sanitation, efficiency, savings, re-use and 
infrastructure safety (DESEAR) actions): In accordance with Article 18(2) of Regulation (EU) 
2021/241 Spain has proposed to increase the ambition of the investment, to carry out additional 
actions  on  waste  water  treatment,  sanitation  and  re-use.  As  a  consequence,  Spain  proposes  to 
extend the deadline for implementing the measure by two years and nine months. This contributes 
to addressing the country-specific recommendations 2020.3.6 on water management and 2022.3.2 
to enhance water reuse. 

Investment  C5.I2  (Monitoring  and  restoration  of  river  ecosystems,  aquifer  recovery  and 
flood risk mitigation):  In accordance with Article 21(1) of Regulation (EU) 2021/241, Spain has 
proposed delaying the target with sequential number 78 by one year and a half. This responds to 
delays  caused  due  to  price  increases  and  an  unsuccessful  call.  In  addition,  in  accordance  with 
Article 18(2) of Regulation (EU) 2021/241, Spain has proposed to increase the ambition of the 
investment,  to  implement  photovoltaic  energy  to  produce  and  distribute  alternative  resources 
(desalinated water) for aquifer recovery. As a consequence, Spain proposed to extend the deadline 
for implementing the measure by two years and a half. This contributes to addressing the country-
specific recommendations 2019.3.3 on fostering energy efficiency and 2020.3.5 promoting clean 
and efficient production and use of energy. 

Investment C5.I3 (Digital transition in the water sector): In accordance with Article (21)1 of 
Regulation  (EU)  2021/241,  Spain  has  proposed  lowering  the  ambition  of  the  milestone  with 
sequential number 79 to achieve the “award of contracts” instead of the “entry into service”. Spain 
has however proposed an additional milestone to achieve the “entry into service” by Q2 2026. This 
responds to supply chain issues with the provider and price increases. In addition, Spain proposed 
to  extend  the  deadline  of  the  measure  by  two  years  and  a  half,  to  capture  the  new  milestone. 
Furthermore,  on  basis  of  Article  18(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to 
increase the ambition of the investment, to increase the scope of actions for the digitalisation of 
the  urban  water  cycle  and  irrigation  communities.  This  contributes  to  addressing  the  country-
specific  recommendations  2020.3.4  on  investment  for  the  green  and  digital  transitions  and 
2020.3.6 on water management. 

8 

 
 
 
 
 
Investment  C5.I4  (Adapting  the  coastline  to  climate  change,  and  implementing  Marine 
Strategies  and  Maritime  Spatial  Planning  Plans):  In  accordance  with  Article  18(2)  of 
Regulation (EU) 2021/241, Spain has proposed increasing the ambition of the measure target by 
restoring 45 additional kilometres of coastline restored by Q4 2025.   

Investment  C5.I5  (Aquifer  recovery):  In  accordance  with  Article  14(2)  of  Regulation  (EU) 
2021/241,  Spain  has  proposed  to  a  new  investment  for  aquifer  recovery.  This  contributes  to 
addressing the country-specific recommendations 2020.3.6 on water management and 2022.3.2 to 
enhance water reuse. 

Investment C5.I6 (PERTE Digitalisation of water uses): In accordance with Article 14(2) of 
Regulation (EU) 2021/241, Spain has proposed a new investment for the digitalisation of the urban 
water  cycle  and  industry.  This  contributes  to  addressing  the  country-specific  recommendations 
2020.3.4 on investment for the green and digital transitions and 2020.3.6 on water management. 

Component 6 (Sustainable mobility, long-distance), substantial modification: 

Investment C6.I1 (National transmission network: European Corridors) In accordance with 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to introduce additional flexibility 
for the  corridors  under  which the projects  can be awarded under  the milestone with  sequential 
number 85. The measures are no longer achievable in the specific terms envisaged in the original 
plan because of different market circumstances, including inflation. 

Investment C6.I4 (Support programme for sustainable and digital transport): In accordance 
with  Article  21(1)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to  introduce  additional 
flexibility for the action lines under which the projects can be supported under the milestone with 
sequential number 99. The measures are no longer achievable in the specific terms envisaged in 
the original plan because of different market circumstances, including inflation. 

Reform C6.R3 (Indicative Rail Strategy): In accordance with Article 14(2) of Regulation (EU) 
2021/241, Spain has proposed a new reform relating to the Strategy for Energy Efficiency in the 
State  Road  Network.  This  contributes  to  addressing  the  country-specific  recommendations 
2019.3.3 on energy efficiency and 2020.3.5 on clean and efficient production and use of energy. 

Component  7  (Deployment  and  integration  of  renewable  energy  sources),  targeted 
modification: 

Reform  C7.R3  (Development  of  energy  communities):  In  accordance  with  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential number 111 by 
one year because of delays caused by lengthier procedures than initially anticipated. 

Investment  C7.I2  (Sustainable  energy  in  islands):  In  accordance  with  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential number 119 by 
one year, because as a discrepancy in the level of ambition between the original RRP and the CID 
Annex had led Spain to underestimate the number of calls required to meet the necessary level of 
ambition. Spain had planned to complete 500 actions instead of the required 600 actions.  

9 

 
 
 
 
 
Component 8 (Electricity infrastructure, Smart grids and deployment of flexibility and 
storage), targeted modification: 

Investment  C8.I1  (Development  of  energy  storage):  In  accordance  with  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to increase the targets with sequential number 125 
and 126 in view of higher demand for storage projects to compensate for lower demand in research 
and development projects whose reference has been deleted from the description of the measure. 

Component 10 (Just Transition), targeted modification: 

Investment  C10.I1  (Investment  in  Just  Transition):  In  accordance  with  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to reduce the ambition of the target with sequential 
number 141 due to lower demand and unexpectedly large reskilling and upskilling offer provided 
by the private sector. To adapt to this change, Spain also proposed to delay the deadline of target 
with sequential number 141 by one year and nine months. Spain proposed to allocate the budget 
of this measure and create a consecutive target to target with sequential number 140 and increase 
the ambition of the line of action. =Furthermore, in accordance with Article 21(1) of Regulation 
(EU) 2021/241, Spain has proposed to delay the deadline of the target with sequential number 142 
by three years. This responds to delays caused by supply chain disruptions.  

Component 11 (Modernisation of public administrations), substantial modification: 

Reform C11.R1 (Reform for the modernisation and digitalisation of the administration): In 
accordance with Article 18(2) of Regulation (EU) 2021/241, Spain has proposed to increase the 
level of ambition of this reform by adding two new elements: namely the entry into force of a law 
on  transparency  that  regulates  the  relations  between  lobbyists  and  the  public  sector,  creating  a 
public  and  mandatory  register  of  interest  groups,  and  the  update  of  the  National  Security 
Framework  to  adapt  it  to  the  current  context  and  better  respond  to  cybersecurity  trends.  In 
accordance with Article 21 of Regulation (EU) 2021/241, Spain has proposed to modify milestones 
with sequential numbers 145, 147 and 148 to reflect a change in the legal instruments with a view 
to a faster and more efficient implementation of the reform.  

Reform C11.R2 (Reform to boost the rule of law and the efficiency of the justice system): In 
accordance  with  Article  21  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to  change  the 
description of this reform to reflect  changes in its timeline due to the unexpected length of the 
preparatory procedures, as well as in the type of legal instruments to be adopted for a faster,  more 
efficient  and  comprehensive  implementation  of  the  reform.  In  line  with  the  description  of  the 
measure and to correct the previous existence of three sub-measures without milestones associated, 
Spain has proposed to merge the entry into force of two royal decree-laws on procedural efficiency 
and digital efficiency into milestone 152 (due by Q2 2022) and introduce two additional milestones 
(due by Q2 2024) referring to the entry into force of: i) a law on organisational and procedural 
efficiency of justice, which contributes to the efficiency of the justice system; and ii) a law on the 
right to defence (as a replacement to the amendment of the code on criminal procedure) which  
develops and enhances the right to a fair trial, thus ultimately boosting the rule of law. 

10 

 
 
 
 
 
Reform  C11.R3  (Reform  to  modernise  the  institutional  architecture  of  economic 
governance): In accordance with Article 18(2) of Regulation (EU) 2021/241, Spain has proposed 
to increase the level of ambition of this reform by adding two new elements: namely the entry into 
force of a law on customer care services to guarantee consumers the exercise of their rights, and 
the publication of a green book  to  promote sustainable finance. The green book is  expected to 
contain several measures, including the publication of the Biennial Climate Change Risk Report 
for the Financial System and the creation of a ‘Sustainable Finance Council’ to promote public-
private collaboration in the field of sustainable finance. 

Investment C11.I3 (Digital transformation and modernisation of the Ministry of Territorial 
Policy and the Civil service, the National Health Service, and of the administration of the 
Autonomous  Communities  and  the  local  authorities):  In  accordance  with  Article  18(2)  of 
Regulation  (EU)  2021/241,  Spain  has  proposed  to  increase  the  ambition  of  this  measure  by 
introducing    the  expected  completion  of  seventeen  pilot  projects  of  personal  digital  healthcare 
plans  aimed  at  increasing  the  resilience  and  sustainability  of  the  health  system,  supporting 
healthcare professionals  and improving the quality of care  and the fairness  of the system. This 
contributes  to  addressing  the  country-specific  recommendations  2020.1.2  to  strengthen  the 
resilience  and  capacity  of  the  health  system,  in  the  areas  of  health  workers,  critical  medical 
products and infrastructure, and to improve resource and energy efficiency. 

Investment  C11.I4  (Energy  transition  plan  in  the  General  State  Administration):  In 
accordance with Article 21 of Regulation (EU) 2021/241, Spain has proposed to lower the target 
with sequential number 170 due to cost increases regarding vehicles. Spain has also proposed to 
redistribute to  target  with sequential  number 172  part of the original  costing  associated to  new 
target with sequential number 439 (concerning the implementation of solar photovoltaic systems 
or other renewables energies) to cover the cost increases in the field of construction. 

Investment  C11.I6  (Cybersecurity  and  Security  and  Resilience  Fund):  In  accordance  with 
Article  14(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  a  new  investment  with  two 
elements: i) the ‘Cybersecurity programme’ to reinforce the public administration’s cybersecurity 
capabilities in the fields of prevention, protection, detection and response to cyberthreats; and ii) 
the ‘Security and Resilience Fund’, a public investment in a new Facility to incentivise private 
investment  and  improve  access  to  finance  in  Spain’s  security,  defence,  aeronautics  and  space 
sectors and to develop capital markets in these areas.  

Component 12 (Industrial Policy), substantial modification: 

Reform C12.R2 (Waste policy and boosting the circular economy): In accordance with Article 
18(2) of Regulation (EU) 2021/241, Spain has proposed to add additional elements to reform 2 to 
directly  address  the  country  specific  recommendation  2022.3.1,  in  particular  to  enhance  the 
coordination among all levels of organisation and competence in waste management to improve 
the implementation of the legislation and make progress in reducing waste generation, as well as 
improving the management of waste, whose generation cannot be avoided.  

Investment  C12.I3  (Plan  to  support  the  implementation  of  waste  legislation  and  the 
promotion  of  the  circular  economy):  In  accordance  with  Article  18(2)  of  Regulation  (EU) 

11 

 
 
 
 
 
2021/241,  Spain  has  proposed  to  increase  the  ambition  of  the  investment  by  adding  additional 
resources to increase municipal recycling rates. This contributes to addressing the country specific 
recommendation 2022.3.1 on the need to increase recycling rates to meet EU targets and promote 
the circular economy. 

Investments C12.I4 (PERTE Chips - Strengthening of the value chain for semiconductors): 
In accordance with Article 18(2) of Regulation (EU) 2021/241, Spain has proposed a new measure 
to  support  strategic  projects  in  the  semiconductors  sector.  This  contributes  to  addressing  the 
country specific recommendation 2020.3 on the need to focus investment on the green and digital 
transition.   

Investment  C12.I5  (Subsidy  scheme  to  support  the  circular  economy):  In  accordance  with 
Article 18(2) of Regulation (EU) 2021/241, Spain has proposed a new investment into a subsidy 
scheme to promote the circular economy in three key sectors of the economy: textiles and fashion, 
plastics and renewable energy equipment. This measure directly contributes to address country-
specific recommendation 2022.3.1. 

Investment C12.16 (Subsidy scheme to support strategic projects for electric and connected 
vehicles): In accordance with Article 14(2) of Regulation (EU) 2021/241, Spain has proposed to 
add a new investment, which consists of a subsidy scheme implemented by ENISA with a view to 
providing further support through grants to strategic projects in value chain for electric vehicles. 
This  contributes  to  addressing  the  country-specific  recommendations  2023.3.1  and  2022.4.1  to 
reduce overall reliance on fossil fuels. 

Investment C12.17 (Support scheme to strategic projects in the value chain of electric cars 
and  agrifood  (in  the  form  of  loans):  In  accordance  with  Article  14(2)  of  Regulation  (EU) 
2021/241,  Spain  has  proposed  to  add  a  new  investment  which  consists  of  a  support  scheme 
implemented by ENISA with a view to providing support through loans to strategic projects in the 
value  chain  for  electric  vehicles  and  in  the  agrifood  sector.  This  contributes  to  addressing  the 
country-specific recommendations 2023.3.1 and 2022.4.1 to reduce overall reliance on fossil fuels. 

Component 13 (Support to SMEs), substantial modification: 

Reform C13.R1 (Improving business regulation and climate): On the basis of Article 18(2) of 
Regulation (EU) 2021/241, Spain has proposed to increase the level of ambition of this measure, 
by  amending  the  competition  law  and  its  regulations  streamlining  resolution  proceedings, 
introducing a settlement procedure for antitrust cases and enhancing the sanctioning system. 

Reform  C13.R2  (Strategy  Spain  Entrepreneurial  Nation):  On  the  basis  of  Article  18(2)  of 
Regulation (EU) 2021/241, Spain has proposed to increase the level of ambition of this measure, 
by  streamlining  migration  procedures  for  workers  with  the  aim  of  attracting  foreign  talent  and 
addressing labour market shortages in certain economic activities. 

Reform C13.R3 (Revision of Securities Markets and Investment Services Law): On the basis 
of Article 18(2) of Regulation (EU) 2021/241, Spain has proposed a new reform, which reflects 
the approval of the revision of Securities Markets and Investment Services Law. This contributes 

12 

 
 
 
 
 
to  ensure 
to  addressing 
implementation of measures to provide liquidity to SMEs and the self-employed. 

the  country  specific  recommendation  2020.3.1 

the  effective 

Investment  C13.I1  (Entrepreneurship):  On  the  basis  of  Article  21(1)  of  Regulation  (EU) 
2021/241, Spain has proposed a one-year delay of completion for targets 193 and 195, respectively, 
because  of  longer  than  expected  administrative  procedures  and  the  need  to  adjust  the  call  for 
interest due to lack in demand.  

Investment C13.I2 (Growth): On the basis of Article 21(1) of Regulation (EU) 2021/241, Spain 
has  proposed  a  one-year  delay  of  completion  for  target  197  because  of  longer  than  expected 
administrative procedures.  

Investment C13.I3 (Digitalisation and innovation): On the basis of Article 21(1) of Regulation 
(EU)  2021/241,  Spain  has  proposed  one-year  delays  of  completion  for  targets  204  and  208, 
respectively, because of lack of demand. Spain has also proposed a change in target 208, with a 
reduction in the number in SMEs or self-employed supported (at the same time as including larger 
firms) due to administrative costs and lack of demand.  

Investment C13.I6 (ICO Green Fund and Enterprises and Entrepreneurs Fund): On the basis 
of  Article  14(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  public  investments  in  two 
Facilities,  the  ICO  Green  Line  and  the  ICO  Enterprises  and  Entrepreneurs  Line,  in  order  to 
incentivise private investment and improve access to finance in Spain’s green sectors and sectors 
related to the economic activity of the enterprise as well as to develop capital markets in these 
areas. These Facilities will  contribute to  the green and  digital transitions and to  addressing the 
country-specific recommendations 2023.1.3, 2022.1.2 and 2020.3.4.  

Investment  C13.I7  (Next  Tech  Fund):  On  the  basis  of  Article  14(2)  of  Regulation  (EU) 
2021/241,  Spain  has  proposed  public  investments  in  a  Facility  in  order  to  incentivise  private 
investment  and  improve  access  to  finance  in  Spain’s  technological  sector.  The  Facility  will 
contribute  to  the  digital  transition  and  to  addressing  the  country-specific  recommendations 
2023.1.3, 2022.1.2 and 2020.3.4.  

Investment  C13.I8  (Co-Investment  Fund):  On  the  basis  of  Article  14(2)  of  Regulation  (EU) 
2021/241,  Spain  has  proposed  a  public  investment  in  a  Facility  in  order  to  incentivise  private 
investment and promote access to finance in Spain’s strategic economic sectors, including those 
tied to the green and digital transitions and the PERTEs, via co-investment with third party foreign 
and  multilateral  institutional  investors.    This  contributes  to  addressing  the  country-specific 
recommendation  2023.1.3,  2022.1.2  and  2020.3.4  to  foster  public  investment  in  the  green  and 
digital transitions.  

Investment C13.I9 (Solvency Support Fund for Strategic Enterprises): On the basis of Article 
14(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to  support  a  financial  instrument  to 
enhance the solvency of strategic enterprises affected during the COVID-19 pandemic.  

Investment  C13.I10  (Covid-19  Companies  Recapitalisation  Fund):  On  the  basis  of  Article 
14(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to  support  a  financial  instrument  that 
enhanced the solvency of medium sized companies during the COVID-19 pandemic. .   

13 

 
 
 
 
 
Investment C13.I11 (Guarantee Instrument SGR-CERSA): On the basis of Article 14(2) of 
Regulation (EU) 2021/241, Spain has proposed to support a re-guarantee scheme to support access 
to finance for SMEs. This contributes to addressing the country specific recommendation 2020.3.1, 
ensure  the  effective  implementation  of  measures  to  provide  liquidity  to  SMEs  and  the  self-
employed.  

Investment C13.I12 (Entrepreneurship and Small and Medium-sized Enterprises Fund): On 
the  basis  of  Article  14(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  a  fund  to  support 
innovative projects carried out by small and medium enterprises, through the State Company for 
Innovation (Empresa Nacional de Innovación Sociedad Anónima). This contributes to addressing 
the country-specific recommendation 2020.3.1, ensure the effective implementation of measures 
to provide liquidity to SMEs and the self-employed.  

Investment C13.I13 (Regional Resilience Fund): On the basis of Article 14(2) of Regulation 
(EU) 2021/241, Spain has proposed a public investment in a Facility in order to incentivise public 
and private investment and promote access to finance in  the regions of Spain, covering  social and 
affordable  housing  and  urban  regeneration,  sustainable  transport,  industrial  and  SME 
competitiveness, research, development and innovation, sustainable tourism, care economy, water 
and  waste  management,  and  energy  transition,  as  well  as  to  develop  capital  markets.    This 
contributes to addressing the country specific recommendations 2023.1.3, 2022.1.2 and 2020.3.4 
to foster public investment in the green and digital transitions.  

Component  14  (Plan  for  the  Modernisation  and  Competitiveness  of  the  Tourism  Sector), 
targeted modification: 

Investment  C14.I1  (Transformation  of  the  tourism  model  towards  sustainability):  On  the 
basis of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to amend the way in which 
the  climate  contribution  is  captured  in  the  measure,  and  related  further  specifications,  while 
keeping the overall contribution to the climate target unchanged (targets with sequential number 
217, 218, 219 and 220).  

Component 15 (Digital connectivity, boosting cybersecurity and 5G deployment), substantial 
modification: 

Investment  C15.I1  (Fostering  territorial  backbone  through  the  deployment  of  networks: 
Ultra-fast broadband extension). On the basis of Article 21(1) of Regulation (EU) 2021/241, 
Spain has claimed it can achieve the objectives of the milestone with sequential number 236 with 
a lower expected cost than initially planned. The resulting resources are reallocated to increase the 
level of ambition of C15.I6. 

Investment C15.I2 (Strengthening connectivity in focal points, socio-economic drivers and 
sectoral  digitalisation  projects).  On  the  basis  of  Article  21(1)  of  Regulation  (EU)  2021/241, 
Spain  has  proposed  a  one-year  delay  of  completion  because  of  supply  chain  disruptions  and 
scarcity of providers of connectivity infrastructure works.  

14 

 
 
 
 
 
Investment C15.I3 (Connectivity bonds for SMEs and vulnerable groups).  On the basis of 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed a one-year delay of completion 
due to a more complex implementation timeline than anticipated. 

Investment C15.I4 (Infrastructure renewal and sustainability). On the basis of Article 21(1) 
of  Regulation  (EU)  2021/241,  Spain  has  proposed  a  one-year  delay  of  completion  because  of 
supply  chain  disruptions  and  scarcity  of  providers  of  connectivity  infrastructure  works,  with  a 
reduction in the target with sequential number 240 due to cost increases and the need to increase 
aid intensity. 

Investment  C15.I5  (Deployment  of  cross-border  digital  infrastructures).  On  the  basis  of 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed a one-year delay of completion 
and 6 month delay on milestones with sequential numbers 241 and 242, respectively, due to a more 
complex implementation timeline than anticipated. 

Investment C15.I6 (Deployment of 5G: networks, technological change and innovation). On 
the basis of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed a one-year delay of 
completion and a 6-month delay on milestones with sequential numbers 243 and 244, respectively, 
because of supply chain disruptions and scarcity of providers of connectivity infrastructure works. 
Spain has also proposed an increase in the expected cost of this measure (due to a re-allocation 
from C15.I1), increasing a target of sites with new backhaul.  

Investment C15.I7 (Cybersecurity: Strengthening cybersecurity capacities of citizens, SMEs 
and  professionals;  boosting  the  ecosystem  of  the  sector).  On  the  basis  of  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to create a new milestone to capture a part of the 
original budget associated with milestone with sequential number 245, due to delay resulting from 
the need to award part of the projects with competitive open procedures. On the basis of Article 
21(1) of Regulation (EU) 2021/241 Spain has also proposed to  advance the completion date of 
target with sequential number 247 from Q4 2023 to Q4 2022, since it has already been completed. 

Investment C15.I8 (PERTE Chip: Strengthening the scientific and technological ecosystem. 
Increased design capabilities). On the basis of Article 18(2) of Regulation (EU) 2021/241, Spain 
has  proposed  a  new  investment  to  support  a  new  strategic  initiative  aimed  at  developing  the 
scientific,  design  and  production  capacities  of  Spain’s  microelectronics  and  semiconductor 
industry  to  generate  a  significant  multiplier  effect  in  the  Spanish  economy  as  a  whole.  This 
contributes to addressing the country-specific recommendation 2023.1.3, 2022.1.2 and 2020.3.4 
to foster public investment in the green and digital transitions.  

Investment C15.I9 (PERTE Chip: Increasing the capacity of the fabless and manufacturing 
industry). In accordance with Article 14(2) of Regulation (EU) 2021/241, Spain proposed a new 
public investment in a Facility, the CHIP Financing  Mechanism, in order to incentivise private 
investment and promote access to finance in Spain’s  semiconductor industry, including fabless 
and  semiconductor  manufacturing.    This  contributes  to  addressing  the  country-specific 
recommendation  2023.1.3,  2022.1.2  and  2020.3.4  to  foster  public  investment  in  the  green  and 
digital transitions.  

15 

 
 
 
 
 
Component 16 (Artificial Intelligence), substantial modification: 

Reform C16.R1 (National Artificial Intelligence Strategy): On the basis Article 18(2) of the 
Regulation (EU) 2021/241, Spain has proposed to further increase the ambition of this measure to 
establish a national agency for the surveillance of AI systems; and to strengthen the development 
of quantum chips by supporting R&D in new quantum technologies that allow progress towards 
the next generation of chips. This contributes to addressing the country-specific recommendations 
2020.3.4  on  expanding  public  investment  in  the  green  and  digital  transitions  in  the  context  of 
R&D&I. 

Component 17 (Science, Technology and Innovation), substantial modification:  

Investment  C17.I2  (Strengthening  the  capacity,  infrastructure  and  equipment  of  State 
System for Science, Technology and Innovation): On the basis of Article 18(2) of Regulation 
(EU) 2021/241, Spain has proposed to increase the ambition of this investment to support projects 
to enhance the capacity, infrastructure and equipment of the State System for Science, Technology 
and  Innovation  in  the  field  of  microelectronics  and  semiconductors,  with  a  particular  focus  on 
clean rooms, and on actions to strengthen capacities in the field of semiconductors associated with 
supercomputing. 

Investment  C17.I3  (New  private,  interdisciplinary,  public  R&D&I  projects,  concept  tests 
and the award of aid as a result of international competitive calls. Cutting-edge R&D geared 
to societal challenges. Pre-commercial public procurement): On the basis of Article 18(2) of 
Regulation  (EU)  2021/241,  Spain  has  proposed  to  increase  the  ambition  of  this  investment  to 
support R&D&I projects in the field of semiconductors and through the development of proof-of-
concept investments in the field, with an increase in the estimated cost of the investment of EUR 90 
million.  

Investment C17.I4 (New scientific career): On the basis of Article 18(2) of Regulation (EU) 
2021/241, Spain has proposed to increase the ambition of this investment to introduce a specific 
research start-up in the field of semiconductors and microelectronics.   

Investment C17.I6 (Health): On the basis of Article 18(2) of Regulation (EU) 2021/241, Spain 
has  proposed  to  increase  the  ambition  of  this  investment  to  strengthen  and  internationalise  the 
industrial capacities of the health sector by supporting the Spanish participation in  R&D multi-
country projects aimed at recovering capacity and strategic autonomy in the health sector, R&D to 
obtain precision diagnosis in rare diseases, support to R&D&I in personalised precision medicine 
in daily clinical practice, development and upgrade of Patient Oriented Clinical Research Units 
and to finance the non-reimbursable part of the health loan under C17.I10.   

Investment C17.I7 (Energy storage R&D centre): On the basis of Article 21(1) of Regulation 
(EU) 2021/241, Spain has proposed to delay milestone with sequential number 269 by two years, 
namely  the  completion  of  the  building  and  equipment  of  an  energy  storage  R&D  centre  in 
Extremadura with the aim of spurring technological and scientific response to the management of 
include  experimental 
green  energy  production  (including  hydrogen).  The  centre  will 

16 

 
 
 
 
 
demonstration  facilities  for  testing  and  validating  energy  storage  solutions.  It  will  be  equipped 
with the necessary scientific and technical equipment.  

Investment  C17.I9  (Aerospace):  On  the  basis  of  Article  18(2)  of  Regulation  (EU)  2021/241, 
Spain  has  proposed  to  increase  the  ambition  of  this  investment  to  invest  in  R&D&I  and  the 
industrial scaling of its results, productive capacities, digitisation needs, green technologies and 
the technological modernisation of the aerospace industry, and to finance the non-reimbursable 
part of the aerospace loan under C17.I10.  

Investment C17.I10 (Loan support to the health and aerospace sector): On the basis of Article 
14(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  a  new  investment  to  strengthen  the 
scientific, technological and innovation capacities of the health sector, including companies, the 
national  health  system  and  universities.  There  are  also  actions  to  invest  in  venture  capital  of 
technology-based  or  innovative  companies  in  the  health  sector.  Finally,  there  are  measures  to 
finance  R&D,  productive  capacities,  digitisation,  green  technologies  and  technological 
modernisation of the aerospace industry.  

Component  18  (Renewal  and  expansion  of  the  capacities  of  the  National  Health  System), 
substantial modification: 

Investment C18.I3 (Health increased capacities to respond to health crises): On the basis of 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to delay milestone with sequential 
number 281 by two years, concerning the implementation of the information system of the Public 
Health Surveillance Network. This change is justified by stakeholder consultations, which revealed 
that it was necessary to broaden the scope of the measure to effectively achieve its objectives. This 
resulted in the need for additional legislative and procedural steps that extended the timeline for 
implementation. This contributes to addressing the country-specific recommendations 2020.1.2  to 
strengthen the resilience and capacity of the health system. 

Investment C18.I4 (Training of health professionals and resources to share knowledge and 
other  investments  to  improve  healthcare  for  patients  with  rare  diseases):  On  the  basis  of 
Article 18(2) of Regulation (EU) 2021/241, Spain has proposed to increase the ambition of this 
investment to build capacity to support the treatment of complex diseases in the National Health 
Service.  This  contributes  to  addressing  the  country-specific  recommendations  2020.1.2  to 
strengthen the resilience and capacity of the health system. 

Investment C18.I5 (Plan to rationalise the consumption of pharmaceuticals and promote the 
sustainability  and  consolidation  of  personalised  medicine  in  healthcare  provision):  On  the 
basis of Article 18(2) of Regulation (EU) 2021/241, Spain has proposed to increase the ambition 
of this investment with additional resources to build capacity to expand the personalised medicine 
and genomic services portfolio in the National Health Service. 

Component 19 (Digital skills), targeted modification: 

Investment C19. I1 (Transversal digital skills): On the basis of Article 21(1) of Regulation (EU) 
2021/241, Spain has proposed to delay the target with sequential number 288 by half a year. This 

17 

 
 
 
 
 
responds to the adaptation of the legal framework to facilitate an optimal implementation of the 
measure. 

Investment C19.I2 (Completion of actions for the digital transformation of education): On 
the basis of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the target 
with sequential number 290 by more than a year; and to reduce its level adding a new target with 
sequential number 292a for trainings conducted in the remit of the Ministry of Labour and Social 
Economy.  This  responds  the  adaptation  of  the  legal  framework  to  facilitate  an  optimal 
implementation of the measure. 

Investment  C19.I3  (Digital  training  for  employment):  On  the  basis  of  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential number 292 by 
half  a  year.  This  responds  to  the  adaptation  of  the  legal  framework  to  facilitate  an  optimal 
implementation of the measure. 

Component 20 (Strategic Plan to boost vocational training), targeted modification: 

Investment  C20.I1  (Reskilling  and  upskilling  of  the  labour  force  linked  to  professional 
qualifications): On the basis of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed 
to  delay the target  with  sequential  number  297 by one year,  and to  decrease its ambition. This 
responds  to  a  lack  of  demand  due  to  accreditation  not  increasing  as  fast  as  expected  despite 
incentives  and  communication  efforts  from  the  authorities.    Moreover,  freed  resources  coming 
from decreased ambition in this target will be earmarked for increased ambition in C20.I2 (Digital 
transformation of vocational training), converting extra classrooms into applied technology spaces, 
which  requires  delaying  its  implementation  by  one  year,  and  for  C20.I3  (Innovation  and 
internationalisation of vocational training). 

Investment C20.I3 (Innovation and internationalisation of vocational training): On the basis 
of  Article  21(1)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to  delay  the  target  with 
sequential  number  302  by  one  year  and  to  increase  its  ambition.  This  responds  to  increased 
capacity within regions. 

Component 21 (Modernisation and digitalisation of education, including early education 0-
3), substantial modification: 

Investment C21.I1 (Promoting early childhood education and care (ECEC)): On the basis of 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential 
number  309  by  one  year  due  to  supply-side  constrains  and  to  reduce,  if  necessary  to  meet  the 
investment target, the budget initially allocated to financing operating expenditure in view of the 
increase in construction and renovation costs. 

Investment C21.I6 (Plan for the development of university micro-credentials): On the basis 
of Article 18(2) of Regulation (EU) 2021/241, Spain has proposed a new investment to develop a 
strategy for the provision of micro-credentials by the university system with the aim of supporting 
lifelong learning and the re-skilling of adult population, in line with the Council Recommendation 
adopted in June 2022 on a European approach to micro-credentials.  

18 

 
 
 
 
 
Component 22 (Shock plan for the care economy and reinforcement of inclusion policies), 
substantial modification: 

Reform  C22.R6  (Law  4/2022,  of  25  February,  on  the  protection  of  consumers  and  users 
against situations of social and economic vulnerability): In accordance with Article 14(2) of 
Regulation (EU) 2021/241, Spain proposed to introduce a new Law on the protection of consumers 
and users against situations of social and economic vulnerability. 

Investment C22.I1 (Long-term support and care plan: deinstitutionalisation, equipment and 
technology): On the basis of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to 
change the specification and delay the target with sequential number 322 by one year and three 
months. This responds to specifications on home telecare services that are less ambitious than the 
policy  objectives  of  this  measure.  Moreover,  on  the  basis  of  Article  21(1)  of  Regulation  (EU) 
2021/241, Spain has proposed to reduce the level of ambition of target with sequential number 
323, and to delay it by two and a half years. This responds to regulatory changes that limit the 
number of places by facility, and supply-side constraints combined with high inflation that have 
delayed implementation.  On the basis of Article 18(2) of Regulation (EU) 2021/241, Spain has 
proposed to partially replace national resources to support investments in deinstitutionalisation, 
equipment and technology. 

Investment  C22.I2  (Plan  for  the  Modernisation  of  Social  Services:  Technological 
transformation, innovation, training and strengthening of child care):  On the basis of Article 
21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential number 
325 by two years. This responds to delays caused by inflation, supply bottlenecks and problems in 
tendering.  On  the  basis  of  Article  18(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to 
partially  replace  national  resources  to  support  investments  in  ttechnological  transformation, 
innovation and training in social services and in strengthening childcare. 

Investment  C22.I3  (Spain  Accessible  Country  Plan):    On  the  basis  of  Article  21(1)  of 
Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential number 326 by 
one  year.  This  responds  to  delays  caused  by  inflation,  supply  bottlenecks  and  problems  in 
tendering.  On  the  basis  of  Article  18(2)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to 
partially replace national resources to support investments in improving accessibility to services 
and physical spaces. 

Investment C22.I4 (Plan Spain protects you against sexist violence):  On the basis of Article 
21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the target with sequential number 
327 by one year, namely from Q4 2023 to Q4 2024. This responds to delays caused by inflation, 
supply bottlenecks and problems in tendering. On the basis of Article 18(2) of Regulation (EU) 
2021/241,  Spain  has  proposed  to  partially  replace  national  resources  to  support  investments  in 
services for victims of sexual violence.  

Investment C22.I5 (Increasing the capacity and efficiency of the reception system for asylum 
seekers):  On the basis of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to delay 
the target with sequential number 328 by one and a half year, namely from Q4 2024 to Q2 2026. 

19 

 
 
 
 
 
This responds to delays caused by the increased migratory pressure, inflation, supply bottlenecks 
and problems in tendering. 

Investment  C22.I6  (Social  Impact  Fund):  On  the  basis  of  Article  14(2)  of  Regulation  (EU) 
2021/241, Spain has proposed a new investment in the form of a public investment in a Facility, 
the Social Impact Fund,  in order to incentivise private investment and improve access to finance 
in  projects  with  a  measurable  social  or  environmental  impact  that  contribute  to  social  and 
environmental solutions, taking into account the impact measurement and management procedures 
established  by  the  European  Taxonomy.  This  contributes  to  addressing  the  country-specific 
recommendation  2019.2.1  to  ensure  that  employment  and  social  services  have  the  capacity  to 
provide effective support.  

Component 23 (New public policies for a dynamic, resilient and inclusive labour market), 
targeted modification: 

Investment  C23.I1  (Youth  Employment):  On  the  basis  of  Article  21(1)  of  Regulation  (EU) 
2021/241, Spain has proposed to amend the definition of milestone with sequential number 342 to 
enlarge  the  scope  of  beneficiary  entities,  including  State  public  sector  entities  as  well  as 
associations, foundations and other non-profit entities. This responds to insufficient demand. 

Investment C23.I3 (New skills for the green, digital and productive transition): On the basis 
of Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to amend the  description of 
milestone with sequential number 344 to incorporate as a target group to the trainings employed 
workers  on  top  of  the  unemployed.  This  responds  to  insufficient  demand  from  firms  to  train 
unemployed  workers.  In  order  to  increase  take  up,  firms  will  be  no  longer  obliged  to  hire  the 
unemployed. 

Investment C23.I5 (Governance and boost of policies to support activation): On the basis of 
Article 21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the completion of target 
with sequential number 347 by one year. This responds to  complex and lengthy administrative 
procedures  as  the  general  government  must  retain  the  ownership  of  the  centres.  Increased 
construction costs due to inflation also delayed the preparatory works to make the centres fully 
operational. 

Investment C23.I6 (Comprehensive plan to boost the social economy): On the basis of Article 
21(1) of Regulation (EU) 2021/241, Spain has proposed to delay the completion of milestone with 
sequential number 349 by 1.5 years to allow social economy enterprises to adapt to the call and 
legal  framework  and  ensure  the  full  implementation  of  the  measure.  This  responds  to  tight 
deadlines  and  the  inability  of  social  economy  enterprises  to  develop  and  execute  quality  and 
innovative projects on time.  

Component 24 (Cultural Industry) targeted modification: 

Investment  C24.I2  (Conservation,  restoration  and  enhancement  of  the  Spanish  cultural 
heritage):  On  the  basis  of  Article  21(1)  of  Regulation  (EU)  2021/241,  Spain  has  proposed  to 
reduce  the  level  of  the  target  with  sequential  number  356  adding  a  new  target  with  sequential 
number 474 for the pending site (“Tabacalera”) as to delay the implementation by two and 2.5 

20 

 
 
 
 
 
years for the respective targets. This responds to disruptions in the supply chain of construction 
materials. Spain has also proposed to delay the completion of target with sequential number 358 
by one year. 

Component 25 (Spain Audiovisual Hub) substantial modification: 

Investment C25.I2 (PERTE Economy of the Language): On the basis of Article 14(2), Spain 
has proposed to finance projects for the digitalisation and dissemination of content and information 
by  the  media  in  Spanish  and  co-official  languages,  including  the  incorporation  of  new 
technological tools in its management and processing. This contributes to addressing the country-
specific recommendations 2023.1.3, 2022.1.2 and 2020.3.4 on expanding public investment in the 
green and digital transitions. 

Investment  C25.I3  (Audiovisual  Fund):  On  the  basis  of  Article  14(2)  of  Regulation  (EU) 
2021/241,  Spain  has  proposed  public  investments  in  a  Facility  in  order  to  incentivise  private 
investment and improve access to finance in Spain’s audio-visual sector and to develop capital 
markets in these areas. This Facility will contribute to the digital transition and to addressing the 
country-specific  recommendations  2023.1.3,  2022.1.2  and  2020.3.4  on  expanding  public 
investment in the green and digital transitions.  

Component 26 (Promotion of Sports), targeted modification: 

Investment C26.I1 Digital Plan for Sports: On the basis of Article 21(1) of Regulation (EU) 
2021/241, Spain has proposed to delay the completion of target with sequential number 370 for 
digitalisation  of  the  sports  sector  and  target  with  sequential  number  372  for  completion  of  IT 
projects  in  High  Performance  Centres  and  in  Antidoping  Administration  by  three  quarters, 
following supply chain issues and shortages in staff due to the COVID-19 pandemic, which caused 
delays in the work of the responsible ministry, including for launching the relevant tenders.   

Component 28 (Adaptation of the Tax System to the Reality of the 21st century), substantial 
modification: 

Investment C28.I1 Tax incentives: On the basis of Article 14(2) of Regulation (EU) 2021/241, 
Spain  has  proposed  to  reinforce  the  existing  measures  in  the  RRP  (Components  1  and  2)  by 
adopting amendments to personal income taxation  to create tax incentives that i) support energy 
efficiency  renovations  by  households  in  2024  and  2025;  and  ii)  support  purchase  of  electric 
vehicles and charging stations by households from 2023 to 2025. This contributes to addressing 
the country-specific recommendations 2023.1.3, 2022.1.2 and 2020.3.4  on increasing investment 
in  the ecological  and digital transition, 2023.3.5 and 2022.4.8.  on increasing the availability of 
energy-efficient 
renovation  and 
social  and  affordable  housing, 
recommendations 2023.3.7 and 2022.4.5 on electrification of transport.  

including 

through 

21 

 
 
 
 
 
Component 31 (REPowerEU chapter), new or scaled-up: 

Under the REPowerEU chapter and in accordance with Articles 21c of Regulation (EU) 2021/241, 
Spain has proposed measures for seven new investments and one scaled-up investment. Spain has 
also proposed one new reform:  

Reform  C31.R1  (Reform  improving  permitting  for  renewable  energy  production projects 
and  electricity  network  infrastructure):  This  reform  aims  to  facilitate  the  deployment  of 
renewable energy sources and to streamline the processing of permitting applications. In particular, 
the reform simplifies the procedures related to new renewable energy projects and new electricity 
network infrastructure, and sets up of a new administrative unit within the central administration 
to  assist  processing permitting  applications. This  contributes to  addressing the country-specific 
recommendations 2023.3.1 and 2022.4.1 to reduce overall reliance on fossil fuels and 2023.3.2 
and 2022.4.2 to accelerate the deployment of renewable energy by further streamlining permitting 
procedures and improving access to the grid. 

Investment C31.I1 (Investment promoting self-consumption (based on renewable energy and 
behind-the-meter storage) and energy communities): This measure is a scaled-up investment 
of measures C7.R3 (Development of energy communities) which supports initiatives carried out 
by  energy  communities,  C7.I1  (Development  of  innovative  renewable  energies,  integrated  into 
buildings  and  production  processes)  which  supports  self-consumption  applications  based  on 
renewable  energy  sources  and  C8.I1  (Deployment  of  energy  storage)  which  supports  energy 
storage.  This  contributes  to  addressing  the  country-specific  recommendations  2023.1.1  and 
2022.4.1  to  reduce  overall  reliance  on  fossil  fuels  and  2023.3.2  and  2022.4.2  to  accelerate  the 
deployment of renewable energy.  

Investment C31.I2 (Support scheme for the production and uptake of renewable hydrogen): 
This measure includes a public investment in a support scheme to support the production and use 
of  renewable  hydrogen.  This  contributes  to  addressing  the  country-specific  recommendations 
2023.3.1  and  2022.4.1  to  reduce  overall  reliance  on  fossil  fuels  and  2022.4.6  to  accelerate  the 
deployment  of  renewable  hydrogen  and  2023.3.2  to  accelerate  the  deployment  of  renewable 
energy.  

Investment  C31.I3  (Support  scheme  for  the  value  chain  of  renewable  energy  sources  and 
storage):  This  measure  includes  a  public  investment  in  a  support scheme  designed  to  improve 
access to finance in the value chain in the design, manufacturing, storage, recycling or research & 
development  of technologies and  components relevant  for the transition  to a net-zero-emission 
economy.  This  contributes  to  addressing  the  country-specific  recommendation  2023.3.1  and 
2022.4.1 to reduce overall reliance on fossil fuels.  

Investment C31.I4 (Investment to support electricity network infrastructure): This measure 
will  support  investments  in  electricity  transmission  networks  to  integrate  larger  volumes  of 
renewable  energy  and  to  connect  to  the  electricity  network  new  net-zero  industrial  sites.  This 
contributes to addressing the country-specific recommendations 2023.3.1 and 2022.4.1 to reduce 
overall  reliance  on  fossil  fuels  and  2023.3.3  and  2022.4.3  to  support  investment  in  network 
infrastructure. 

22 

 
 
 
 
 
Investment C31.I5 (Investment to support industrial decarbonisation in the form of grants): 
This investment which is part of the strategic project for industrial decarbonisation, aims to support 
the decarbonisation of industrial processes in all sectors. The objective of this measure is to support 
the decarbonisation of industrial processes. The measure consists of the implementation of projects 
aiming at the decarbonisation of the manufacturing industry, for instance projects that aim at GHG 
emission  reduction,  as  well  as  the  development  of  new  highly  efficient  and  decarbonised 
manufacturing  facilities.  This  contributes  to  addressing  the  country  specific  recommendations 
2023.3.1 and 2022.4.1 to reduce overall reliance on fossil fuels.  

Investment  C31.I6  (Subsidy  scheme  for  decarbonisation  projects  (grants)):  This  measure 
consists of a public investment in a public subsidy scheme to be implemented by ENISA. This 
investment  aims  to  support  the  decarbonisation  of  industrial  processes  in  all  sectors  and  the 
development  of  new  highly  efficient  and  decarbonised  manufacturing  facilities  in  the  context  of  the 
DECARB strategic project (PERTE), and it is linked to  Investment C31.I5. This contributes to 
addressing the country-specific recommendations 2023.3.1 and 2022.4.1 to reduce overall reliance 
on fossil fuels.  

Investment C31.I7 (Investment to support industrial decarbonisation in the form of loans): 
The objective of the investment, which is part of the strategic project for industrial decarbonisation, 
is  to  grant  support  in  the  form  of  loans  to  projects  that  aim  at  the  decarbonisation  of  the 
manufacturing industry. This investment measure consists of at least one of three different lines of 
action: (a) support to projects implementing the decarbonisation of the manufacturing industry, for 
instance  projects  that  reduce  GHG  emissions;  (b)  completion  of  a  pilot  project  on  the 
implementation of a fund to incentivise companies to undertake investment with high associated 
costs  in  large  industrial  decarbonisation  investment  projects  and  substantial  GHG  emission 
reductions by paying a fixed carbon price over a given period (carbon contract for differences); 
and  (c)  support  for  the  development  of  new  highly  efficient  and  decarbonised  manufacturing 
facilities. This investment aims to support the decarbonisation of industrial processes in all sectors, 
and  it  is  linked  to  Investment  C31.I5.  This  contributes  to  addressing  the  country  specific 
recommendations 2023.3.1 and 2022.4.1 to reduce overall reliance on fossil fuels.  

Investment C31.I8 (Support scheme for decarbonisation projects in the form of loans): This 
measure consists of a public investment in a public loan scheme managed by ENISA. The objective 
of this measure is to promote the decarbonisation of industrial processes, and the development of 
new  highly  efficient  and  decarbonised  manufacturing  facilities  in  the  context  of  the  Strategic 
project  for  the  decarbonisation  of  industry  (PERTE  DECARB),  and  it  is  linked  to  Investment 
C31.I5.  This  contributes  to  addressing  the  country  specific  recommendations  2023.3.1  and 
2022.4.1 to reduce overall reliance on fossil fuels. 

23 

 
 
 
 
 
 
 
Table 1: Components in the modified RRP and associated estimated costs2 (EUR million). 

Existing Plan 
Financial 
contribution 

Addendum 
Loans 

Financial 
contribution 

Total 

Overall  
Total 

Component  

01. Sustainable mobility 
(urban) 
02. Renovation 
03. Agri-food and 
fisheries 
04. Ecosystems and 
biodiversity 
05. Coast and water 
resources 
06. Sustainable mobility 
(long-distance) 
07. Renewables 
08. Electricity 
infrastructure 
09. Hydrogen 
10. Just transition 
11. Public administration 
12. Industrial policy 
13. Support to SMEs 
14. Tourism 
15. Digital connectivity 
16. Artificial Intelligence 
17. Science, technology 
and innovation 
18. Reform of health 
system 
19. Digital skills 
20. Vocational training  
21. Education 
22. Care economy, 
equality and inclusion  
23. Labour market 
24. Cultural industry 
25. Audiovisual 
26. Sports 
27. Prevention of tax 
fraud 
28. Tax system 
29. Effective public 
spending 
30. Pension system 
reform 
31. RePowerEU chapter 
TOTAL 

6 536 

6 820 

1 051 

1 642 

2 091 

6 667 

3 165 

1 365 

1 555 
300 
4 239 
3 782 
4 894 
3 400 
3 999 
500 

3 457 

1 069 

3 593 
2 076 
1 648 

2 492 

2 363 
325 
200 
300 

- 

- 

- 

- 

- 

- 

- 

- 
- 
130 
1 050 
- 
- 
621 
40 

734 

100 

- 
- 
50 

- 

- 

150 

- 

- 

4 000 

260 

- 

6 536 

4 000 

10 820 

410 

1 461 

- 

- 

1 642 

1 250 

1 805 

3 055 

5 146 

- 

- 

- 

- 
- 
2 157 
1 200 
58 103 

10 750 

- 

- 

- 

- 
- 
2 287 
2 250 
58 103 
- 
11 371 
40 

6 667 

3 165 

1 365 

1 555 
300 
6 526 
6 032 
62 998 
3 400 
15 370 
540 

570 

1 304 

4 761 

- 

- 
- 
- 

100 

- 
- 
50 

1 000 

400 

1 400 

- 
- 
- 
- 

- 

- 

- 

- 

- 
1 712 
- 

- 

483 

- 

- 

- 
1 712 
- 

- 

483 

- 

- 

1 169 

3 593 
2 076 
1 698 

3 892 

2 363 
325 
1 912 
300 

- 

483 

- 

- 

- 
69 528  

5 217 
10 342 

24 

1 700 
83 160 

6 917 
93 502 

6 917 
163 030 

 
 
 
 
 
 
 
 
 
 
2.3 

 Other elements not covered by assessment criteria  

Consistency with other programmes 

The modified RRP of Spain provides detailed justification for its consistency with the objectives 
and priorities of other initiatives, such as the National Reform Programme of Spain, the Partnership 
Agreement with Spain, the National Energy and Climate Plan and the European Digital Agenda.  

In 2022, the Commission adopted the Partnership Agreement for the shared management funds in 
Spain in 2021-2027 and the related ERDF and ESF+ programmes. The modified RRP of Spain 
explains how these funds and the RRP would cover different projects, sectors and types of actions. 
Spain further provided evidence justifying that the funds allocated to financial instruments were 
commensurate  with  the  investment  gaps  in  the  targeted  sectors,  also  taking  into  account  the 
contributions from other EU funds targeting the same sectors.  

Consistency  with  the  challenges  and  priorities  identified  in  the  most  recent  euro  area 
recommendation 

The  modified  plan  is  aligned  with  the  Commission  Recommendation  for  a  Council 
Recommendation  on  the  economic  policy  of  the  euro  area  adopted  by  the  Council  on  16  May 
2023.3 

• 

• 

• 

• 

• 

In line with recommendation 1, the modified plan aims at ensuring debt sustainability and 
raising  potential  growth  in  a  sustainable  manner,  contributing  to  gradual  fiscal 
consolidation. 
In  line  with  recommendation  2,  the  modified  plan  introduces  additional  measures  to 
strengthen economic resilience and support the green and digital transition, including for 
greater energy efficiency and for the transition to renewable energy sources. 
In line with recommendation 3, the modified plan increases the ambition of measures that 
address skills shortages. 
In  line  with  recommendation  4,  the  modified  plan  introduces  additional  measures  to 
preserve  the  level  playing  field  and  the  integrity  of  the  single  market,  benefitting  in 
particular for small and medium-sized enterprises. 
In line with recommendation 5, the modified plan allocates EUR 75.97 billion to financial 
instruments. 

National arrangements for the implementation of the plan 

The previous description of the implementation and monitoring aspects of the plan, as reflected in 
the  previous  Staff  Working  Document  SWD(2021)  147  final  remains  valid.  Concerning  the 

2 The total estimated costs for measures to be supported by the financial contribution in the form of non-repayable 
support is marginally in excess of the plan’s financial contribution of EUR 79 854 million (after deduction of 
Spain’s proportional share of the expenses of Article 6(2) of Regulation (EU) 2021/241). 
3 COM(2022) 782 final, available at COM_2022_782_1_EN.pdf (europa.eu) 

25 

 
 
 
 
 
 
 
EUR 75.97 billion allocated to financial instruments in the modified RRP, the management of the 
instruments  will  be  the  responsibility  of  entities  with  a  proven  track  record  and  operational 
capacity. The governance arrangements will ensure that the instruments are managed in a manner 
that is transparent, independent, and market-conforming.   

Gender equality and equal opportunities for all 

The previous description of the Spanish RRP’s focus on gender equality and equal opportunities 
for all, as reflected in the previous Staff Working Document SWD(2021) 147 final, remains valid. 
In addition, the modified RRP contains a new strategy for the provision of micro-credentials by 
the university system which strengthens equal opportunities for young people. 

Consultation process 

The modified plan underlines the importance of consultation and co-governance for the effective 
implementation of the revised plan of Spain.  

The modified plan explains that the Spanish government has carried out  a consultation process 
with social partners, regions and local entities and political groups during the preparation of the 
addendum of the RRP. In particular, the modified plan refers to a multitude of meetings with social 
agents,  sectorial  conferences  and  their  committees,  nine  parliamentary  hearings  on  the  RRP 
attended by the first Vice-President of the Government and Ministry of the Economy, bilateral 
communications with political parties, as well as sectoral consultations through high-level forums 
and consultations with businesses and citizens. These meetings had the purpose of improving the 
implementation  of  the  initial  plan  and  preparing  the  modified  one.  Moreover,  the  revised  plan 
explains that the draft addendum was published on 22 December 2022, which allowed regions, 
social partners, political parties and other entities to get acquainted with the key elements of the 
plan and to put forward suggestions. In line with the requirements laid down in Article 18(4)(q) of 
the  Recovery  and  Resilience  Facility  Regulation,  the  revised  plan  includes  a  summary  of  the 
different structures and processes used for stakeholder dialogue. It also mentions how the different 
elements stemming from the consultation to social agents, regions, local entities, and other political 
forces  were  integrated  in  the  submitted  addendum.  Finally,  the  document  recalls  the  novel  use 
made by Spain of calls of expression of interest, with 33 carried out so far, to gather input from 
business and stakeholders on the design of investments. As regards reforms included in the initial 
RRP,  the  document  recalls  the  usual  prior  consultation  and  public  hearing  procedures  that  are 
followed  for  all  legislative  proposals,  in  line  with  the  national  legal  framework.  The  above 
description also applies to the new REPowerEU chapter. In addition, Section 3.12 includes specific 
information on the consultation process in the context of the REPowerEU Chapter. In this context, 

26 

 
 
 
 
 
the  submitted  document  also  highlights  the  importance  of  co-governance  for  the  effective 
implementation of the Plan.4 

Digital security self-assessment 

Spain  has  provided  a  security  self-assessment  for  investments  in  digital  capacities  and 
connectivity. In Component 15 (Digital Connectivity) of the plan, Spain explains that, as part of 
the two reforms envisaged under the component, it will adopt the recommendation of the European 
Commission  on  Connectivity5  and  the  law  on  the  requirements  to  ensure  the  security  of  5G 
electronic communications networks and services, which will include the key recommendations 
of the European Commission Communication of 29 January 2020 “Secure 5G deployment in the 
EU — Implementation of the EU toolbox”6. For investments in data spaces, Spain explains that 
the security assessment will align to the evolving work programmes of the European Union on 
cybersecurity certification, as laid down in Regulation (EU) 2019/881 of the European Parliament 
and  of  the  Council  on  ENISA  (European  Cybersecurity  Agency)  and  on  information  and 
communications  technology  cybersecurity  certification.  Strategic  measures  mentioned  in  the 
security  self-assessment  would  need  to  be  closely  monitored  during  the  implementation  of  the 
plan.  In  Component  16  (Artificial  Intelligence)  of  the  plan,  Spain  explains  that  the  activity 
generated as  a result of the  progressive adoption of artificial intelligence will be subject  to  the 
conclusions to be determined in the European Union’s rolling work programmes on cybersecurity 
certification, as laid down in Regulation 2019/881 of the European Parliament and of the Council 
on  ENISA  (European  Agency  for  Cybersecurity)  and  Information  and  Communication 
Technology cybersecurity certification. Concerning artificial intelligence, and without prejudice 
to applicable European legislation, certification schemes (i.e., “AI quality label”) will be promoted 
to boost a trustworthy and human-centric artificial intelligence.   

Communication Strategy 

The submitted addendum contains a detailed description of the ambitious communication strategy 
that  the  Spanish  authorities  have  been  carrying  out  at  national  level  through  different 
communication  channels.  The  campaign  seeks  to  keep  potential  beneficiaries  informed  of  the 
opportunities that the plan offers to them, to give visibility to the impact that the Recovery and 
Resilience  Facility  is  having  in  promoting  the  green  and  digital  transition  and  to  reach  out  to 

4 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 
5 C (2020) 6270 
6 COM (2020) 50 

27 

 
 
 
 
 
 
 
various groups of stakeholders with an interest in the measures in the plan, including implementing 
authorities. 

State aid 

State  aid  and  competition  rules  fully  apply  to  the  measures  funded  by  the  RRF.  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 shall 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 TFEU7. 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  Spain  in  the 
recovery and resilience plan cannot be deemed a State aid notification. In as far as Spain 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  Spain  to  ensure  full 
compliance with the applicable rules. 

3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

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

situation 

The modifications to Spain’s RRP do not change, and rather confirm and strengthen the previous 
assessment that the RRP is a comprehensive and adequately balanced response to the economic 
and social situation, since Spain does not remove and does not significantly reduce any investment 
or reform, but adds additional investments and reforms. 

The modified RRP including the REPowerEU chapter still covers in a comprehensive manner the 
six pillars structuring the scope of application of the Facility (Article 3): (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 coverage of the Spanish plan’s components toward the six pillars is summarised 

7 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 

28 

 
 
 
 
 
 
 
in Table 2. All pillars are covered by at least one component, while a component may contribute 
to several pillars.  

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

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 

● 

● 
● 

● 

● 

● 

● 
● 

● 
● 

○ 
○ 
○ 
○ 

○ 

01. Sustainable mobility 
(urban) 
02. Renovation 
03. Agri-food and 
fisheries 
04. Ecosystems and 
biodiversity 
05. Coast and water 
resources 
06. Sustainable mobility 
(long-distance) 
07. Renewables 
08. Electricity 
infrastructure 
09. Hydrogen 
10. Just transition 
11. Public administration 
12. Industrial policy 
13. Support to SMEs 
14. Tourism 
15. Digital connectivity 

16. Artificial Intelligence 
17. Science, technology 
and innovation 
18. Reform of health 
system 
19. Digital skills 
20. Vocational training  
21. Education 
22. Care economy, 
equality and inclusion  
23. Labour market 
24. Cultural industry 

○ 

○ 

○ 

○ 
● 
○ 
● 
● 

● 

● 

● 

○ 

● 
● 

● 

○ 

● 
○ 

● 

● 
● 
● 
● 

● 

● 
● 
○ 

● 
● 

29 

○ 

○ 

○ 

○ 
○   

● 
○ 

○ 

○ 
○ 

○ 

● 

○ 

○ 

● 

○ 

○ 

○ 

 ○ 
● 

● 

○ 

○ 

○ 

● 

● 
● 
● 

○ 

 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

25. Audiovisual 
26. Sports 
27. Prevention of tax 
fraud 
28. Tax system 
29. Effective public 
spending 
30. Pension system 
reform 
31. REPowerEU chapter  ● 

○ 

● 

○ 

● 

● 
● 

● 

● 

○ 
○ 

● 

○ 

● 

○ 
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 Spain, 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 Spain into account. This would warrant a rating of A under criterion 2.1 in 
Annex V to the RRF Regulation. 

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

The modified plan continues to effectively address a significant subset of the challenges identified 
in the relevant country-specific recommendations (CSRs). As the maximum financial contribution 
for Spain has been adjusted upwards and as the size of the plan increased following a loan request, 
intended  to  be  used  not  exclusively  for  REPowerEU  objectives,  all  2022  and  2023  structural 
recommendations are considered in the overall assessment. At the same time, the modifications to 
Spain’s  RRP  confirm  and  strengthen  the  previous  assessment  that  the  RRP  is  contributing  to 
effectively  addressing  all  or  a  significant  subset  of  the  country-specific  recommendations 
addressed  to  Spain  for  the  years  2019  and  2020,  since  Spain  does  not  remove  and  does  not 
significantly reduce any investments or reforms but adds additional investments and reforms. 

Notably, the modified plan addresses the country specific recommendations 2023.1.3 and 2022.1.2 
to  expand  public  investment  in  the  green  and  digital  transitions  through  public  investments  in 
facilities to incentivise private investment and improve access to finance (the two ICO Business 
Support Funds, the Next Tech Fund, the Co-Investment Fund and the Regional Resilience Fund, 
the CHIP Financing Mechanism) which are expected to significantly boost the green and digital 
transition  in  Spain.  In  addition,  further  investments,  including  in  the  audio-visual  sector,  also 
address the country specific recommendations 2023.1.3 and 2022.1.2 to expand public investment 
in the green and digital transitions.  

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In line with  the country- specific  recommendation 2022.3.1 to  increase recycling rates to  meet 
Union targets and to promote the circular economy and enhance water reuse, a waste management 
reform in the modified plan improves the coordination among all levels of administration. This is 
achieved  through  the  creation  of  a  coordination  committee  and  the  approval  of  secondary 
legislation included in the “Waste Package”. A new subsidy scheme for circular economy in key 
Spanish  sectors  (Plastics,  textiles  and  fashion  and  RES  equipment)  is  to  contribute  to  enhance 
circularity in these sectors. Additional transfers to the regions will contribute directly to achieving 
a minimum of 30% of separately collected municipal waste. Additional investments in wastewater 
treatment will contribute to increasing water reuse.  

In  line  with  the  country-specific  recommendation  2022.3.2  to  enhance  water  reuse  by  the 
implementation of investments to promote projects related to purification, sanitation and reuse of 
water, improvement of water efficiency and reduction of water losses, through the digitalisation 
of water users.  

The  REPowerEU  chapter  reinforces  the  ambition  of  the  plan  as  regards  most  of  the  relevant 
country-specific recommendations in the field of energy (CSRs 2023.3 and 2022.4), notably to 
reduce reliance on fossil fuels, to accelerate the deployment of renewable energy sources, to invest 
in energy storage and network infrastructure, and to deploy renewable hydrogen. The REPowerEU 
chapter  contains  a  reform  improving  the  permitting  framework  for  renewable  energy  projects 
(2023.3.2  and  2022.4.2)  and  investments  on  self-consumption,  energy  storage,  energy 
communities, renewable hydrogen (2023.3.2 and 2022.4.2), electricity transmission infrastructure 
(2023.3.3 and 2022.4.3) and industrial decarbonisation (2023.3.1 and 2022.4.1) . Several proposed 
measures  included  in  the  modified  plan  will  also  contribute  to  the  country-  specific 
recommendations 2023.3.7 and 2022.4.5 in the field of electrifying buildings and transport (via a 
new fiscal incentive for the purchase of electric vehicles and support of electric vehicle industry), 
and  to  the  recommendations  2023.3.5  and  2022.4.8  on  increasing  the  availability  of  energy-
efficient social and affordable housing (via an extended fiscal incentive for renovation works, the 
Housing  Fund  and  the  programme  of  measures  to  promote  the  supply  of  rental  housing).  The 
Strategy for Energy Efficiency in the State Road Network contributes to addressing the country-
specific  recommendations  2019.3.3  on  energy  efficiency  and  2020.3.5  on  clean  and  efficient 
production and use of energy. 

Many  of  the  new  or  modified  measures  help  further  address  those  country-specific 
recommendations  that  are  already  partly  addressed  by  the  initial  RRP.  Notably,  in  addition  to 
previous recommendations related to the green and digital transition, circular economy and energy, 
the modified plan helps address the country specific recommendations 2020.3.4 to foster research 
and innovation, clean and efficient production and use of energy, energy infrastructure, water and 
waste  management  and  sustainable  transport.  This  recommendation  is  addressed  through  the 
effective operationalisation of the regulatory sandbox in the field of transport and mobility, a new 
investment to modernise irrigation systems in terms of water savings and energy efficiency and 
the measures mentioned above in relation to country specific recommendations of 2020 (such as 
financial  instruments  ICO  Business  Support  Funds).  A  new  regulation  on  farm  information 
systems  to  manage the agricultural  and livestock policies contributes to  addressing the country 
specific  recommendation  2019.3.2  on  resource  efficiency.    New  investments  in  healthcare 

31 

 
 
 
 
 
contribute  to  addressing  the  country-specific  recommendations  2020.1.2  to  strengthen  the 
resilience and capacity of the health system. The new Entrepreneurship and Small and Medium-
sized Enterprises Fund contributes to addressing the country-specific recommendation 2020.3.1 to 
implement  measures  to  support  SMEs.  The  Social  Impact  Fund  contributes  to  addressing  the 
country-specific recommendation 2019.2.1 to ensure that employment and social services have the 
capacity to  provide effective support.  A modified measure which increases  the ambition of the 
investment to carry out additional actions on waste water treatment, sanitation and re-use of water 
and another two contributing to the digitalisation of the urban water cycle, industry and irrigation 
communities  contribute  to  the  country-specific  recommendations  2022.3.2  on  water  reuse  and 
2020.3.6 on water management. The new allocation to the modified measure and the new measure 
for the digitalisation of water users, and new investments for digitalisation and support of private 
investment  in  the  audio-visual  sector  also  contribute  to  the  country-specific  recommendation 
2020.3.4 on investment for the green and digital transition. A modified measure which increases 
the  ambition  of  an  investment  to  implement  photovoltaic  energy  to  produce  and  distribute 
alternative  resources  for  aquifer  recovery  contributes  to  country-specific  recommendation 
2019.3.3 fostering energy efficiency and 2020.3.5 promoting clean and efficient production and 
use of energy.  

Taking into consideration the reforms and investments envisaged by Spain, 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 Spain. Therefore, the proposed modifications to  Spain’s recovery and resilience plan  do not 
change, and rather confirm and strengthen the previous assessment (rating of A) of the contribution 
of the plan to 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  of  the  adequacy  of  its  response  to  the  economic  and  social 
situation of Spain, as reflected in the previous SWD(2021) 147 final. 

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 

As  part  of  the  modification  of  the  RRP,  Spain  has  put  forward  further  reforms  aimed  at 
strengthening business competition, attracting foreign talent and accelerating the energy transition 
and the implementation of investments. In particular, Spain is proposing reforms in the area of 
renewable  energy  permitting.  Such  reforms  are  key  to  reach  the  objectives  of  REPowerEU,  to 
accelerate  the  green  transition,  and  ensure  resilience  against  further  energy  shocks.  The 
modification  of  the  plan  also  includes  sizeable  resources  to  financial  instruments  to  stimulate 
private investment, including to support the green and digital transition, and to enhance strategic 
industrial projects in the green and digital transition. The REPowerEU chapter includes additional 
resources to scale-up existing measures promoting self-consumption of renewable energy, energy 
storage and energy communities; and new investments in renewable hydrogen, the value chain for 

32 

 
 
 
 
 
renewable  energy,  in  electricity  networks  and  in  the  decarbonisation  of  industry.  In  view  of 
reforms and investments put forward as part of the modification of the RRP, the initial positive 
assessment of the impact of the plan on growth potential, job creation, and territorial and social 
cohesion is positively assessed. 

Stylised simulations by the Commission services estimate that the modified RRP, including the 
increased financial contribution and the request for loans, together with the rest of measures of the 
European Union Recovery Instrument, have the potential to increase the GDP of Spain by between 
2.7  %  and  3.5  %  by  2025,  not  explicitly  including  the  possible  positive  impact  of  structural 
reforms. 

The  nature  and  extent  of  the  proposed  modifications  to  Spain’s  recovery  and  resilience  plan 
confirm and strengthen 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(2021) 147 final. 

3.4. The principle of ‘do no significant harm’  

The modifications of the measures included in the RRP do not have an impact on the assessment 
of the principle of ‘do no significant harm’ which remains identical. 

Spain’s  REPowerEU  chapter  includes  a  systematic  assessment  of  each  measure  against  the 
principle of ‘do no significant harm’ (DNSH), for each of the six environmental objectives within 
the meaning of Article 17 of the Taxonomy Regulation. While Spain’s assessment often stresses 
the environmental and climate benefits of measures in this assessment, it also provides information 
allowing  to  assess  that measures  will  comply  with  the  ‘do  no significant  harm’  principle  –  for 
instance  by  providing  reassurance  that  the  implementation  of  the  existing  EU  and  Spanish 
legislative framework will prevent any significant harm, or by indicating that any measure that 
could have had a significant impact has been carved out from funding under the Recovery and 
Resilience Facility. 

For the financial instruments,  where it is not known ex-ante which projects are to be financed, 
adherence with the ‘do no significant harm’ principle is ensured by introducing specific safeguards 
in the measure description and in the related milestones and targets, to monitor the implementation 
of the measures. This is of relevance for financial instruments under Component 13, such as ICO 
Green and the Regional Resilience Fund, due to the broad nature of the activities to be financed 
under these funds. 

For some measures where calls for projects or calls for interest are necessary to select specific 
projects, adherence with the ‘do no significant harm’ principle is ensured by introducing specific 
safeguards in the milestones associated with each measure, to monitor the implementation of the 
measures. This is the case for instance for the investments to support industrial decarbonisation 
(measures C31.I5, C31.I6, C31.I7 and C31.I8). Specific safeguards have also been introduced for 

33 

 
 
 
 
 
measures included in the Plan that could potentially lead to investments being made in installations 
falling within the scope of the EU Emission Trading System (ETS). This is the case in particular 
for the above-mentioned investments to support industrial decarbonisation and for investments to 
support the value chain of renewable energy sources and storage (C31.I3).  

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Spain’s modified RRP, including 
its 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 criterion 2.4 of Annex V to the RRF Regulation. 

No measure under the Spanish RRP neither the REPowerEU chapter falls under Article 21c (3), 
point (a) of Regulation (EU) 2021/241.

34 

 
 
 
 
 
3.5. Green transition 

Climate target 

The modified RRP of Spain continues to correctly follow the methodology for climate tagging set 
out  in  Annex VI  to  the  RRF  regulation,  by  identifying  intervention  fields,  and  corresponding 
coefficients for the calculation of support to the climate  objectives, for each measure (the table in 
Annex I presents the detailed application of the climate tagging methodology). It should be noted 
that:  

a)  the tagging and the estimated expenditure of existing measures has not been modified, on 
this basis the assessment as reflected in the previous SWD(2021) 147 final  is maintained 
for those measure. 

b)  For the new measures of the modified plan: 

o 

o  when they consist of several sub-measures the plan indicates an intervention field 
for each sub-measure, and climate tagging is computed at sub-measure level 
the  choice  of  intervention  fields  for  the  green  transition  is  well  justified  and  it 
reflects  the  nature,  focus,  objective,  or  expected  outcome  of  the  investments 
included in the component 
the  plan  does  not  propose  to  increase  the  climate  coefficients  of  the  selected 
intervention fields for any measure. 

o 

The modified Spanish plan includes measures supporting climate change objectives for an amount 
which represents 39.9% of the total plan’s allocation (EUR 65.0 billion out of EUR 163.0 billion) 
in  the  form  of  loan  and  non-repayable  financial  contribution,  including  the  allocations  of  the 
REPowerEU chapter. Measures supporting climate change objectives represent 75% of the total 
estimated costs of measures in the REPowerEU chapter, according to the methodology for climate 
tracking set out in Annex VI to the Recovery and Resilience Facility Regulation. Therefore, the 
climate change contribution of the total plan, as well as of REPowerEU, exceeds the minimum 
climate target of 37% as set out in that Regulation. The climate change contribution of each of the 
components of the plan is set out in Table 3.5.1 below. The largest contributions come from the 
components on SME support (42.4% of the overall climate contribution), Renovation component 
(11.9%  of  the  overall  climate  contribution)  and  REPowerEU  (8%  of  the  overall  climate 
contribution).  

The REPowerEU chapter – Component 31 – presents investments amounting to EUR 6.9 billion 
that aim to  accelerate the deployment  of renewable energy sources,  energy storage and  energy 
communities,  to  invest  in  renewable  hydrogen,  to  strengthen  the  value  chain  for  the  net-zero 
industry, to invest in additional electricity network infrastructure and to decarbonise industry. This 
chapter reinforces the investments contained in the initial plan for industrial decarbonisation and 
renewable energy and hydrogen.  

35 

 
 
 
 
 
 
Table 3 Climate contribution by component  

Component 

Estimated 
Costs 
(EUR m) 

Climate 
contribution 
(EUR m) 

Climate 
contribution as 
percentage of 
component costs 

01. Sustainable mobility (urban) 

02. Renovation 

03. Agri-food and fisheries 

04. Ecosystems and biodiversity 

05. Coast and water resources 

06. Sustainable mobility (long-distance) 

07. Renewables 

08. Electricity infrastructure 

09. Hydrogen 

10. Just transition 

11. Public administration 

12. Industrial policy 

13. SME support 

14. Tourism 

15. Digital connectivity 

16. Artificial Intelligence 

17. Science, technology and innovation 

18. Reform of health system 

19. Digital skills 

20. National vocational training 

21. Modernisation of education 

22. Care economy, equality and inclusion 

23. Labour market 

24. Cultural industry 

25. Spain Audiovisual Hub 

26. Sports 

27. Prevention of fiscal fraud 

28. Tax system 
29. Improving the effectiveness of public 
spending 
30. Pensions 

4,737 

7,713 

582 

759 

2,448 

4,937 

3,165 

1,365 

1,555 

150 

1,071 

2,218 

27,550 

655 

0 

0 

49 

0 

0 

158 

0 

0 

222 

0 

0 

134 

0 

343 

0 

0 

6,536 

10,820 

1,461 

1,642 

5,146 

6,667 

3,165 

1,365 

1,555 

300 

6,526 

6,032 

62,998 

3,400 

15,370 

540 

4,761 

1,169 

3,593 

2,076 

1,698 

3,892 

2,363 

325 

1,932 

300 

0 

483 

0 

0 

36 

72.5% 

71.3% 

39.8% 

46.2% 

47.6% 

74.1% 

100.0% 

100.0% 

100.0% 

50.0% 

16.4% 

36.8% 

43.7% 

19.3% 

0.0% 

0.0% 

1.0% 

0.0% 

0.0% 

7.6% 

0.0% 

0.0% 

9.4% 

0.0% 

0.0% 

44.7% 

0.0% 

71.1% 

0.0% 

0.0% 

Climate 
contribution 
as percentage 
of the plan’s 
total 
allocation* 
2.9% 

4.7% 

0.4% 

0.5% 

1.5% 

3.0% 

1.9% 

0.8% 

1.0% 

0.1% 

0.7% 

1.4% 

16.9% 

0.4% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.1% 

0.0% 

0.0% 

0.1% 

0.0% 

0.0% 

0.1% 

0.0% 

0.2% 

0.0% 

0.0% 

 
 
 
 
 
Component 

Estimated 
Costs 
(EUR m) 

Climate 
contribution 
(EUR m) 

Climate 
contribution as 
percentage of 
component costs 

Climate 
contribution 
as percentage 
of the plan’s 
total 
allocation* 

31. REPowerEU 

6,917 

5,187 

75.0% 

3.2% 

39.9% 
163,030 
Total 
* The plan’s total allocation is the sum of the financial contribution in the form of non-repayable support 
and of the loan support, for a total of EUR 163,014 million. 

64,997 

39.9% 

Green transition 

The modified RRP contains reforms and investments that are expected to significantly contribute 
to the green transition, including biodiversity, addressing the country specific recommendation as 
well as to the achievement of the Union climate target by 2030 and climate neutrality by 2050.  

The modified plan does not modify previous measures contributing to the green transition, in terms 
of  estimated  expenditure.  Beyond  the  modifications  on  the  basis  of  Article  21,  the  new  plan 
includes 30 additional measures that contribute to the green transition, with an estimated additional 
climate  contribution  of  EUR 37.4  billion  (compared  to  the  original  plan),  bringing  the  green 
contribution to EUR 65.0 billion.  

In particular, the modified plan includes significant new measures related to the decarbonisation 
of industry and deployment of renewable energy and hydrogen. These investments are included in 
components  Component  12  (Industrial  Policy)  and  Component  31  (REPowerEU).  Significant 
investments, structured as financial instruments and subsidy schemes, will also support sustainable 
transport,  energy  efficiency,  renewable  energy,  industry  decarbonisation,  water  management, 
circular economy, climate change adaptation and sustainable tourism. The financial instruments, 
such as ICO Green and the Regional Resilience Fund, are covered in Component 13 (Support to 
SMEs)  and  the  subsidy  schemes  are  covered  in  Component  12  (Industry  Policy)  and  31 
(REPowerEU). Other investments will support water management and re-use by the digitalisation 
of  different  users  such  as  irrigation  communities,  industry  and  the  urban  water  cycle.  These 
investments are included in Component 5 (Coast and water resources).  

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. 

37 

 
 
 
 
 
3.6. Digital transition 

Digital tagging  

The modified RRP of Spain continues to correctly follow the methodology for digital tagging set 
out  in  Annex VII to the  RRF  Regulation,  by identifying intervention fields, and  corresponding 
coefficients for the calculation of support to the digital objectives, for each measure (the table in 
Annex I presents the detailed application of the digital tagging methodology). It should be noted 
that:  

a)  the  tagging  and  the  estimated  expenditure  of  existing  measures  has  not  been  modified, 
except for C23.I5 which was incorrectly not tagged in the initial analysis. On this basis the 
assessment as reflected in the previous SWD(2021) 147 final is maintained for all measures 
but for C23.I5 which is tag with Intervention Field 108 - Support for the development of 
digital skills (100% digital contribution). 
b)  For the new measures of the modified plan: 

o  when they consist of several sub-measures the plan indicates an intervention field 

o 

o 

for each sub-measure, and digital tagging is computed at sub-measure level 
the  choice  of  intervention  fields  for  the  digital  transition  is  well  justified  and  it 
reflects  the  nature,  focus,  objective,  or  expected  outcome  of  the  investments 
included in the component 
the  plan  does  not  propose  to  increase  the  digital  coefficients  of  the  selected 
intervention fields for any measure. 

The modified Spanish plan includes measures supporting digital objectives for an amount which 
represents  25.9%  of  the  plan’s  total  allocation  in  the  form  of  loan  and  non-repayable  financial 
contribution, excluding the estimated costs of the investments included in the REPowerEU chapter 
(EUR 40.4  billion  out  of  EUR 156.1  billion,  excluding  RePowerEU).  Therefore,  the  digital 
contribution of the plan exceeds the minimum digital target of 20% as set out in the Regulation.   

As it can be observed from Table 4, 22 out of 30 components (excluding the REPowerEU chapter) 
have  a  digital  contribution  that  has  been  tagged  accordingly  to  the  methodology  set  out  in 
Annex VII  to  the  RRF  regulation,  notably  in  the  modified  plan  also  Component  17  (Science, 
Technology and Innovation) provides a contribution to the digital objective. 

38 

 
 
 
 
 
 
Table 4: Digital contribution by component  

Component 

Estimated 
cost (EUR 
m) 

Digital 
contribution 
(EUR m) 

Digital 
contribution 
as percentage 
of component 
costs 

Digital 
contribution 
as percentage 
of the plan’s 
total allocation 
(excl. 
RePowerEU)* 

01. Sustainable mobility (urban) 

02. Renovation 

03. Agri-food and fisheries 

04. Ecosystems and biodiversity 

05. Coast and water resources 

06. Sustainable mobility (long-distance) 

07. Renewables 

08. Electricity infrastructure 

09. Hydrogen 

10. Just transition 

11. Public administration 

12. Industrial policy 

13. SME support 

14. Tourism 

15. Digital connectivity 

16. Artificial Intelligence 

17. Science, technology and innovation 

18. Reform of health system 

19. Digital skills 

20. National vocational training 

21. Modernisation of education 

22. Care economy, equality and inclusion 

23. Labour market 

24. Cultural industry 

25. Spain Audiovisual Hub 

26. Sports 

27. Prevention of fiscal fraud 

28. Tax system 

119 

0 

62 

138 

1,880 

445 

0 

546 

0 

0 

4,452 

1,152 

7,850 

523 

15,370 

540 

364 

100 

1.8% 

0.0% 

4.2% 

8.4% 

36.5% 

6.7% 

0.0% 

40.0% 

0.0% 

0.0% 

68.2% 

19.1% 

12.5% 

15.4% 

100.0% 

100.0% 

7.6% 

8.6% 

3,593 

100.0% 

208 

147 

500 

328 

96 

1,867 

76 

0 

0 

10.0% 

8.6% 

12.8% 

13.9% 

29.5% 

96.7% 

25.2% 

0.0% 

0.1% 

0.0% 

0.0% 

0.1% 

1.2% 

0.3% 

0.0% 

0.3% 

0.0% 

0.0% 

2.9% 

0.7% 

5.0% 

0.3% 

9.8% 

0.3% 

0.2% 

0.1% 

2.3% 

0.1% 

0.1% 

0.3% 

0.2% 

0.1% 

1.2% 

0.0% 

0.0% 

0.0% 

6,536 

10,820 

1,461 

1,642 

5,146 

6,667 

3,165 

1,365 

1,555 

300 

6,526 

6,032 

62,998 

3,400 

15,370 

540 

4,761 

1,169 

3,593 

2,076 

1,698 

3,892 

2,363 

325 

1,932 

300 

0 

483 

39 

 
 
 
 
 
 
Component 

Estimated 
cost (EUR 
m) 

Digital 
contribution 
(EUR m) 

Digital 
contribution 
as percentage 
of component 
costs 

Digital 
contribution 
as percentage 
of the plan’s 
total allocation 
(excl. 
RePowerEU)* 

29. Improving the effectiveness of public 
spending 

30. Pensions 

0 

0 

0 

0 

0.0% 

0.0% 

25.9% 
Total 
* The plan’s total allocation excluding the estimated costs of the investments included in the REPowerEU 
chapter is the sum of the financial contribution in the form of non-repayable support and of the loan support 
minus EUR 6,917 million, for a total of EUR 156,098 million. 

156,113 

40,353 

25.8% 

Digital transition 

The modified recovery and resilience plan contains investments and reforms that are expected to 
have a long-lasting impact in the digital transformation of the economic and social  sectors and 
significantly  contribute  to  addressing  the  challenges  resulting  from  the  digital  transition.  The 
expected impact of the initial plan is further strengthened by the new measures included in the 
modified plan. 

The  modified  plan  does  not  modify  previous  measures  contributing  to  the  digital  transition,  in 
terms  of  estimated  expenditure.  Beyond  the  modifications  made  on  the  basis  of  Article  21  of 
Regulation  (EU)  2021/241,  the  modified  plan  includes  18  new  measures  that  contribute  to  the 
digital transition with an estimated additional digital contribution of EUR 20.7 billion bringing the 
total digital contribution of the modified plan to EUR 40.4 billion.  

The modified plan includes significant new measures in the area of advanced digital technologies 
with  investments  in  the  entire  value  chain  of  advanced  microprocessors  from  R&D  to 
manufacturing.  These  investments  are  included  in  several  components  such  as  Component  15 
(Chips), Component 12 (Industrial Policy), Component 17 (Science, Technology and Innovation), 
Component 16 (Artificial Intelligence). Significant investments will also support the scaling up of 
technological start-ups and other investments will support SMEs in the development of a Spanish 
Natural  Processing  Language  environment  using  computer  science  and  Artificial  Intelligence 
technologies,  both  under  Component  13  (Support  to  SMEs).  Other  investments  will  further 
strengthen the digitalisation of the water sector under Component 5 (Coast and water resources), 
and of the public administration, including with investments in cybersecurity under Component 
11  (Public  administration).  Finally,  other  resources  have  been  allocated  to  further  develop  the 
investments  under  the  framework  of  the  Spanish  audio-visual  sector  under  Component  25 
(Audiovisual Hub). 

The nature and extent of the proposed modifications to Spain’s recovery and resilience plan do not 
have a material impact on, and rather confirm and strengthen the previous assessment (rating of 

40 

 
 
 
 
 
 
 
 
A) of the contribution of the plan to the digital transition and to the digital target, as reflected in 
the previous SWD(2021) 147 final. 

3.7. Lasting impact of the plan 

The modified RRP does not reduce the ambition of the initial plan as a whole. It takes into account 
the prolonged impact of the COVID-19 crisis, inflation and supply chain disruptions, as well as 
some  unexpected  legal  or  technical  difficulties  or  the  availability  of  better  alternatives  for  the 
implementation  of  some  measures  by  modifying  measures  in  accordance  with  Article  21(2)  of 
Regulation (EU) 2021/241. It also includes additional measures as a result of the increase in the 
maximum financial allocation and the request of loan support and includes a REPowerEU chapter. 
These  additional  measures,  in  addition  to  the  existing  measures,  are  expected  to  have  lasting 
positive effects on the Spanish economy and further boost its green and digital transition.  

New reforms included in the modified RRP are expected to have a long-lasting impact on Spain, 
as 16 reforms have been introduced or enhanced to strengthen the competition framework, attract 
foreign  talent  and  facilitate  the  entry  into  the  country  of  skilled  migrant  workers,  improve  the 
regulatory framework for the financial sector, improve the animal and human health standards for 
transport and sustainable use of antibiotics in the livestock industry, reduce food waste, promote 
the  circular  economy,  combat  desertification,  increase  the  supply  of  and  facilitate  access  to 
housing,  develop  low-emission  areas,  improve  the  energy  efficiency  of  the  road  network, 
operationalise a regulatory sandbox in the field of transport and mobility, improve the regulatory 
framework for the protection of financial clients, promote transparency in the field of lobbying 
activities,  foster  public  sustainable  finances,  and  update  the  regulatory  framework  for  digital 
security  and  national  security.  The  REPowerEU  chapter  moreover  includes  a  new  reform  to 
streamline permitting procedures for renewable energy projects. 

New  investments  included  in  the  modified  RRP are  expected  to  have  a  long-lasting  impact  on 
Spain  by  stimulating  private  investments  with  14  financial  instruments,  including  investments 
supporting the green and digital transition. The REPowerEU chapter includes investments to scale-
up  existing  measures  supporting  self-consumption,  energy  storage  and  energy  communities,  as 
well  as  new  investments  in  renewable  hydrogen,  the  value  chain  for  renewable  energy,  in 
electricity networks and in the decarbonisation of industry. 

The nature and extent of the proposed modifications to Spain’s recovery and resilience plan do not 
have a material impact, and rather confirm and strengthen the previous assessment (rating of A) of 
the lasting impact of the measures proposed by Spain, as reflected in the previous SWD(2021) 147 
final. 

3.8. Milestones, targets, monitoring and implementation. 

The modified RRP includes an update of the monitoring and implementation framework, including 
a description of  additional measures introduced  by Spain  since the approval  of the initial  RRP 
which  have  contributed  to  the  reinforcement  of  the  monitoring  and  implementation  set-up.  In 
particular, the national  arrangements  as  set  out  in  Royal  Decree-Law 36/2020 of 30 December 

41 

 
 
 
 
 
approving  urgent  measures  for  the  modernisation  of  the  public  administration  and  the 
implementation  of the Recovery Plan remain in  place. Additionally, Spain  has  approved Order 
HFP/1031/2021 defining the procedures and format of the information to be shared for monitoring 
of the RRP and accounting execution of expenditure and put in place the Recovery and Resilience 
Facility  Integrated  Information  System  (‘Coffee’)  facilitating  the  monitoring  of  the  RRP 
implementation  and the production of management  declarations, audit summaries and payment 
requests. The Commission made a positive preliminary assessment of the milestones concerning 
these measures in the context of the first payment request. The modified RRP also includes an 
extension of the monitoring framework to align with the introduction of new measures consisting 
of the set-up of financial instruments and the set-up of subsidy schemes combining grants with 
financial  instruments.  Spain  will  sign  an  Implementing  Agreement  or  equivalent  with  the 
implementing partner, or approve a regulatory framework, that should contain the description of 
the  monitoring  systems  of  the  implementing  partner,  and  -  where  relevant  -  of  financial 
intermediaries,  to  report  on  the  investment  mobilised.  This  requirement  will  not  be  applicable 
when the implementing partner or financial intermediary is the EIB, the EIF or the EBRD. The 
entities entrusted with the management of the financial instruments and subsidy schemes have a 
proven-track record in management of similar funds. They also have the financial and operational 
capacity  to  manage  the  proposed  instruments  or  have  committed  to  increase  it  by  recruiting 
additional staff (ENISA) and/or by resorting to external experts (Group SEPIDES and the State 
Company for Microelectronics and Semiconductors (SEMyS).  

The existing  monitoring  and control system,  including  the amendments  proposed in  relation  to 
financial instruments for the modified Spanish recovery and resilience plan enable an adequate 
monitoring of the plan’s implementation. The nature and extent of the proposed modifications to 
Spain’s  recovery  and  resilience  plan  do  not  have  an  impact  on  the  original  assessment  of  the 
effective monitoring and implementation of the recovery and resilience plan. The structure tasked 
with  the  implementation,  monitoring  and  report  of  the  RRP  is  still  in  place  and  the  overall 
arrangements proposed by Spain in terms of organisation of the implementation of the reforms and 
investments remain credible. The milestones and targets that accompany the new and modified 
measures, including those in the REPowerEU chapter, are clear and the proposed indicators for 
those milestones and targets are relevant, acceptable, and robust. The administrative capacity of 
the  additional  implementing  agencies  helps  ensure  the  effective  absorption  of  the  additional 
incoming funds. The arrangements proposed by Spain 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 to the 
RRF Regulation. 

3.9. Costing 

Spain  has  provided  individual  cost  estimates  for  all  the  amended  or  new  investments  of  its 
modified recovery and resilience plan. Spain has provided sufficient information and evidence to 
consider  that  costs  are  overall  reasonable  and  plausible.  In  addition,  the  majority  of  costs  are 
backed by appropriate justification and explanations that the amounts do not include costs covered 

42 

 
 
 
 
 
by existing or planned Union financing. Costs are also commensurate to the expected economic 
and social impact of the envisaged measures.  

Spain has relied on a number of sources to justify the costs of investments and reforms. Estimates 
of costs included in the plan are generally detailed, well-substantiated and based on a variety of 
sources. These include calls of interest specifically launched for the purposes of the plan during 
its preparation phase (Component 12 (Industrial Policy)), information on the use of tax benefits 
(Component  28  (Adapting  the  Tax  System  to  the  Reality  of  the  Twenty-First  Century)),  
procurement  contracts  referred  to  similar  services  or  past  investments  of  similar  nature 
(Component  2  (Housing),  Component  5  (Coast  and  water  resources)  Component  17  (Science, 
Technology and Innovation), Component 18 (Health)), examples of similar investments conducted 
in  other  Member  States  (Component  15  (Chips)),  and  data  on  investment  needs  and  market 
financing gaps (Component 2 (Housing), Component 11 (Security), Component 13 (Support to 
SMEs), Component 15 (Chips) Component 22 (Social)). For each component, Spain has provided 
specific  documents  describing  the  costing  methodology  and  identifying  the  underlying  costing 
information submitted. 

Reasonable costs  

Cost estimates for most of the measures in the plan  revision are deemed reasonable. Spain has 
provided detailed evidence backing the eligibility of measures. Firstly, all costs are incurred after 
1 February 2020, and 1 February 2022 for the REPowerEU chapter. Secondly, in accordance with 
Article  5  of  Regulation  (EU)  2021/241,  costs  do  not  substitute  recurring  national  budgetary 
expenditure. Finally, VAT has not been included in the costs estimates as a general rule. Recital 
18  of  the  Recovery  and  Resilience  Facility  Regulation  provides  for  Member  States  to  use 
simplified cost options. Simplified costs can be based on lump sum costs, unit costs or flat rates.  
Spain has provided unit costs estimates across several measures, including simplified cost options 
for some measures. The use of unit costs was dependent on whether a specific technology permits 
establishing costs per unit, on whether the information is available and is relatively standardised, 
homogenous and available to be used. 

Plausible costs  

The amount of the estimated total costs of the plan revision is in line with the nature and type of 
the envisaged reforms and investments. Spain has submitted extensive additional costing evidence 
underpinning  the  claims  presented  in  the  plan.  These  documents  broadly  substantiate  the  cost 
estimates.  

Cost estimates have been deemed overall plausible. The amounts proposed for financing have been 
deemed appropriate for most of the measures, whilst taking into account the limits of an ex-ante 
based assessment of cost estimates. In particular, Spain has provided evidence that costs are in line 
with previous projects and initiatives undertaken in the country. In this regard, the output targets 
provided  in  the  plan  for  investment  are  commensurate  with  the  costing  justifications  and 
assumptions provided.  

43 

 
 
 
 
 
No double funding  

As a rule, individual measures do not consider the support of additional financing from other Union 
programmes. Spain has confirmed that the same cost will not be covered at the same time by the 
recovery and resilience plan and by existing or planned Union financing, in line with the provisions 
of Article 9 of Regulation (EU) 2021/241. As the planning documents for the implementation of 
the European Structural and Investment Funds (ESIF) have been finalised and agreed, Spain has 
provided  documents  outlining  the  complementarity  and  synergies  between  the  two  sources  of 
Union funds and confirmed that double funding is not expected. 

Spain has confirmed that specific arrangements have been put in place to avoid double funding, 
including  from  ESI  funds,  during  the  implementation  phase  (see  further  details  on  the 
arrangements to prevent double-funding under Section 4.10 Controls and Audits). 

The justification provided by  Spain  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.  

Spain 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 criterion 2.9 of Annex V to the RRF Regulation. 

3.10. 

Controls and audit  

The  internal  control  system  described  in  the  original  RRP  was  based  on  robust  processes  and 
structures. It identified the actors and their roles and responsibilities for the performance of the 
internal  control  tasks  clearly.  The  actors  responsible  for  controls  have  legal  empowerment  to 
exercise their foreseen roles and tasks, as well as administrative capacity. Altogether, the control 
system and other relevant arrangements, including for the collection and making available of data 
on final recipients, were considered adequate with regard the requirements under Regulation (EU) 
2021/241. To complete the internal control system, Spain was required to develop an integrated 
information system for the implementation and to approve a related piece legislation prior to the 
first regular payment under the RRF. 

The modified RRP comprises an update of the audit and control framework, including a description 
of  additional  measures  introduced  by  Spain  since  the  approval  of  the  initial  RRP  which  have 
contributed to the reinforcement of the framework. In particular, as confirmed by the Commission 
in the framework of the preliminary assessment of the third payment request,  Spain has improved 
the collection of data on beneficial owners of foreign companies that have no power of attorney in 
Spain, both for already concluded contracts, as well as for future contracts and has developed an 
additional risk scoring IT tool called Minerva for the systematic control and prevention of conflict 
of interest, making use of beneficial owner’s data. The modified RRP also includes an extension 
of the control and audit framework to align with the introduction of new measures consisting of 
the  set-up  of  financial  instruments  and  the  set-up  of  subsidy  schemes  combining  grants  with 
financial instruments. In accordance with the modifications, Spain should sign an Implementing 

44 

 
 
 
 
 
Agreement or equivalent with the implementing partner, or approve a regulatory framework, that 
should contain the description of the audit and control systems of the implementing partner, and 
when relevant of the financial intermediaries. These audit and controls requirements will ensure 
the  prevention,  detection  and  correction  of  fraud,  corruption  and  conflict  of  interests,  the 
verification  of  the  eligibility  of  every  operation  before  committing  to  financing,  and  the 
implementation of risk-based ex-post audits in accordance with an audit plan. In those cases where 
the implementing partner or financial intermediary is the EIB, the EIF or the EBRD, the obligation 
to describe the audit and control systems will not apply but these bodies will be required to provide 
to the relevant national authorities an annual audit report prepared by their external auditors. 

The  arrangements  proposed  by  Spain  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 modified RRP presented by Spain is structured as 31 coherent components, which support the 
common objectives of stimulating the recovery of the Spanish economy, contributing to the twin 
transition and increasing Spain’s resilience to meet the challenges of the twenty-first century on 
the path of sustainable and inclusive growth. 

Each  component  is  built  around  consistent  packages  of  both  reforms  and  investments,  with 
mutually reinforcing or complementary measures.   

In accordance with Article 19(3), point (k), of and Annex V, criterion 2.11, to Regulation (EU) 
2021/241, the modified RRP including the REPowerEU chapter includes to a high extent (Rating 
A)  measures  for  the  implementation  of  reforms  and  public  investment  projects  that  represent 
coherent actions.  

The modification to the RRP concern 28 of the existing components and includes an additional 
component, the REPowerEU chapter. The modifications made to the existing chapters do not alter 
the  overall  coherence  of  the  plan,  taking  into  account  the  way  the  components  are  mutually 
reinforcing and complementary in particular those related to the green and digital transitions and 
the  newly  added  REPowerEU  chapter.  For  example,  the  measures  in  the  REPowerEU  chapter 
reinforce existing green transition measures and notably Components 7, 8, 9 and 12 by scaling up 
or  complementing  measures  in  the  original  RRP  on  energy  communities,  self-consumption  of 
renewable  energy,  energy  storage  and  the  decarbonisation  of  industry.  The  new  investments 
supporting  renewable  hydrogen,  transmission  network  infrastructure  and  the  value  chain  for 
renewable energy also reinforce existing green transition measures. The REPowerEU chapter also 
adds a reform to improve permitting for new renewable energy projects and electricity network 
infrastructure. This reform is frontloaded to the first months of implementation of the modified 
plan and therefore will facilitate the implementation of the investments, notably those related to 
renewable energy and electricity network infrastructure.  

45 

 
 
 
 
 
In  order  to  promote  wider  coherence  across  instruments,  notably  with  the  European  cohesion 
policy funds, a balanced territorial allocation of resources is encouraged. 

Taking  into  consideration  the  qualitative  assessment  of  all  components  of  Spain’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. 

3.12. 

REPowerEU 

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),  (e)  and  (f)  of 
Regulation  (EU)  2021/241.  The  implementation  of  the  investments  to  decarbonise  industry 
(C31.I5,C31.I6,  C31.I7  and  C31.I8),  the  scale-up  of  the  investments  to  deploy  additional 
renewable  energy  and  energy  storage  (C31.I1),  a  public  investment  in  a  scheme  to  support 
renewable  hydrogen  (C31.I2)  and  the  reform  to  simplify  permitting  procedures  for  renewable 
energy projects (C31.R1) are expected to contribute to the objective set out in Article 21c (3), point 
(b)  of  the  Regulation,  that  is,  to  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.  The  implementation  of  the  investment  in  new  electricity 
transmission  infrastructure  (C31.I4)  is  expected  to  contribute  to  addressing  internal  and  cross-
border  energy  transmission  and  distribution  bottlenecks,  and  accelerating  the  integration  of 
renewable energy sources, that is, the objective in Article 21c (3), point (e) of the Regulation. The 
implementation of the public investment into a scheme to support the value chain of the net-zero 
industry  (C31.I3)  is  expected  to  contribute  to  the  objective  in  Article  21c  (3),  point  (f)  of  the 
Regulation. The REPowerEU chapter also addresses the need to diversify away from fossil fuels, 
notably by accelerating the deployment of renewable energy, renewable hydrogen, decarbonising 
industry and investing in the value chain for the net-zero industry. 

The  measures  in  the  REPowerEU  chapter  are  therefore  coherent  with  the  efforts  of  Spain  to 
achieve the objectives set out in Article 21c (3) of Regulation (EU) 2021/241. 

In particular the government adopted in October 2022 a Plan reinforcing Spain’s energy security 
(‘Plan  Más  Seguridad  Energética’)  which  lays  down  73  measures  grouped  in  six  categories:  i) 
energy savings; ii) energy transition; iii) protecting vulnerable consumers; iv) tax rebates to protect 
energy consumers; v) energy independence and vi) solidarity with other EU member states.  The 
measures in the REPowerEU chapter are also coherent with the initial RRP as the REPowerEU 
measures notably increase the original RRP ambition to increase the share of renewable energy 
sources. 

Furthermore,  targeted  consultations  were  held  with  relevant  stakeholders  in  relation  to  the 
REPowerEU  chapter.  Social  agents,  representatives  of  regional  authorities  and  relevant 
stakeholders  in  the  sector  were  informed  of  priorities  and  consulted  on  reform  and  investment 
measures included in the chapter, to collect suggestions concerning measures to be included in the 

46 

 
 
 
 
 
chapter.  Consulted  stakeholders  highlighted  the  importance  of  reinforcing  investments  in  self-
consumption, energy communities and renewable hydrogen.  

Finally, Spain used as an input for drafting the REPowerEU chapter the extensive work carried 
out under the Technical Support Instrument (Project title “Support to REPowerEU”) which had 
helped Spain identifying relevant measures to meet the objectives set out in  the REPowerEU’s 
Communication. 

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,  energy 
efficiency, an increase of energy storage capacities, and the 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  

Most  measures  included  in  Spain’s  REPowerEU  chapter  have  a  multi-country  or  cross-border 
dimension. 

The  REPowerEU  chapter  contributes  to  reducing  dependency  on  fossil  fuels  and  to  reducing 
energy demand. In particular, a majority of the measures in the REPowerEU chapter supports the 
deployment of renewable energy sources, renewable hydrogen, electricity network infrastructure 
and decarbonising industry.  

The investment related to the production and use will include projects with a multi-country and 
cross-border dimension or effect. Furthermore, the implementation of the investments supporting 
self-consumption,  electricity  transmission  infrastructure  and  industrial  decarbonisation  are 
expected to reduce Spain’s reliance on fossil fuels.  

The estimated costs of the measures included in the REPowerEU chapter represent 85% of the 
total costs, which is significantly above the 30% indicative target and therefore justifies rating the 
chapter as expecting to have, to a large extent, a cross-border effect. 

Table 5: Contribution of the REPowerEU measures to the cross-border effect  

REPowerEU measure 

Estimated Cost 
(EUR m) 

Contribution to the target 

Self-consumption and energy communities 

Renewable hydrogen 

Value chain 

Electricity transmission infrastructure 

Investment in decarbonisation (grants) 

666 

1 600 

1 000 

931 

590 

47 

100% 

100% 

0% 

100% 

100% 

 
 
 
 
 
REPowerEU measure 

Estimated Cost 
(EUR m) 

Contribution to the target 

Subsidy scheme for decarbonisation (grants) 

Investment in decarbonisation (loans) 

Support scheme for decarbonization (loans) 

430 

650 

1050 

100% 

100% 

100% 

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 or multi-
country dimension or effect. This would warrant a rating of A under criterion 2.13 of Annex V of 
the RRF Regulation.

48 

 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging (new measures compared to original plan are highlighted) 

Measure/Sub-
Measure ID 

C1.I1a  

C1.I1b.i  

C1.I1b.ii  

Measure / Sub-Measure Name  

Low emission zones and transformation of urban and 
metropolitan transport (Autonomous Community 
actions): line of action 1 

Development of low-emission zones and projects for the 
sustainable transformation of urban and metropolitan 
transport (municipal actions): Lines of action 2a and 2b 
(except for cycling infrastructure), and digitalisation 
(municipal actions) line of action 2d 

Development of low emission zones and sustainable 
transformation projects for urban and metropolitan 
transport (municipal actions): Lines of action 2a and 2b 
(cycling infrastructure), and fleet transformation to zero 
emissions vehicles and recharging points (municipalities) 
line of action 2c 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

900 

048 

40% 

1.190 

048 

40% 

310 

0778 

100% 

8 This measure also includes investment in zero emission vehicles. For that part the ‘Methodology for climate tracking’ annexed to the Recovery and Resilience 
Facility Regulation does not set out intervention fields that would allow for climate or environmental tracking of electric vehicles or plug-in hybrid vehicles, except 
for vehicles for urban transport falling under intervention field 074. According to Article 18(4)(e) of the Regulation, the methodology should however ‘be used 
accordingly for measures that cannot be directly assigned to an intervention field listed in Annex VI’. In this context, the Commission has applied a 100% climate 
contribution coefficient for the zero-emission vehicles of all categories (this includes battery electric and fuel cell/hydrogen-powered vehicles) included in this 
measure. This measure also includes investments in cycling infrastructure (075) as well with a 100% climate coefficient. 

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C1.I1d  

C1.I2  

Improvement actions in urban environments (crossings) 
on the State Road Network to promote the mobility of 
pedestrians and cyclists, and other new forms of mobility 
(scooters), with the aim at reducing vehicle speed, 
reducing both air emissions and noise pollution: line of 
action 4 

Scheme of incentives for the installation of recharging 
points, the purchase of electric and fuel cell vehicles and 
innovation in electro-mobility, recharging and renewable 
hydrogen 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

105 

048 

40% 

2.000 

n/a9 

100% 

C1.I3a  

Investments in railway infrastructure 

1.502 

069bis 

100% 

C1.I3b  

C2.I1.a.i  

C2.I1b.i  

Digitalisation of security, information and access control 
systems at railway stations providing PSO services 

Energy rehabilitation of buildings with on average 
primary energy savings of at least 30 % 

Energy rehabilitation of buildings with on average 
primary energy savings of at least 30 % 

119 

070 

40% 

070 

100% 

856 

025bis 

100% 

1.716 

025bis 

100% 

9 The main part of this measure concerns incentive for the purchase of zero emission vehicles or for the development on innovative projects in zero emission 
vehicles/mobility The ‘Methodology for climate tracking’ annexed to the Recovery and Resilience Facility Regulation does not set out intervention fields that 
would allow for climate or environmental tracking of electric vehicles or plug-in hybrid vehicles, except for vehicles for urban transport falling under intervention 
field 074. According to Article 18(4)(e) of the Regulation, the methodology should however ‘be used accordingly for measures that cannot be directly assigned to 
an intervention field listed in Annex VI’. In this context, the Commission has applied a 100% climate contribution coefficient for the zero-emission vehicles of all 
categories (this includes battery electric and fuel cell/hydrogen-powered vehicles) included in this measure. This measure also includes investment in alternative 
fuel infrastructure (077) that would also have a 100% climate coefficient. 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

C2.I1b.ii  

C2.I1c  

C2.I2  

C2.I3  

C2.I4  

C2.I5a  

C2.I7a  

C2.I7b  

C3.I1  

C3.I1a  

C3.I12  

Measure / Sub-Measure Name  

Existing building book/Rehabilitation projects to improve 
energy efficiency 

Favourable environment to rehabilitation activity (tax 
incentives): line of action 3 

New programme to promote affordable housing, which 
are energy efficient (at least 20 % lower primary energy 
demand compared to the NZEB requirements) 

Energy Rehabilitation of Buildings Programme (PREE), 
aligned with energy efficiency criteria with on average 
primary energy savings of at least 30 % 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

278 

025 

40% 

450 

025bis 

100% 

1.000 

025ter 

40% 

300 

025bis 

100% 

Energy transition programme and demographic challenge 
with on average primary energy savings of at least 30 % 

1.000 

025bis 

100% 

Energy rehabilitation of public buildings with on average 
primary energy savings of at least 30 % 
ICO Loan Facility for the Promotion of Social Housing 
(New buildings) 
ICO Loan Facility for the Promotion of Social Housing 
(Building renovation) 
Plan for improving efficiency and sustainability in 
irrigation 

Plan for improving efficiency and sustainability in 
irrigation. PERTE AGRO 

Plan for improving efficiency and sustainability in 
irrigation. PERTE AGRO- Loans 

758 

026bis 

100% 

3.130 

025ter 

40% 

870 

563 

150 

260 

025bis 

100% 

040 

40% 

040 

40% 

040 

40% 

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

C3.I3  

C3.I4  

C3.I5a  

C3.I5b  

C3.I5c  

C3.I5d  

Plan to promote the sustainability and competitiveness of 
agriculture and livestock farming (II): Strengthen capacity 
building and Biosecurity systems in Nurseries and 
livestock farms 

Plan to promote the sustainability and competitiveness of 
agriculture and livestock farming (III): Investments in 
precision agriculture, energy efficiency and circular 
economy and in the use of renewable energy and gases in 
the agriculture and livestock sector 

Strategy for the digitalisation of the agrifood and forestry 
sector and the rural environment. Technology-based 
entrepreneurship line 

Strategy for the digitalisation of the agrifood and forestry 
sector and the rural environment. Creating a Digital 
Innovation Hub for businesses in the agrifood sector 

Strategy for the digitalisation of the agrifood and forestry 
sector and the rural environment. Establishment of an 
observatory for the digitalisation of the agricultural sector 

Strategy for the Digitisation of the Agri-Food and 
Forestry Sector and the Rural Environment. Creation of a 
platform of AKIS advisors 

38 

027 

100% 

307 

047 

40% 

30 

4 

1 

3 

010 

100% 

010 

100% 

010 

100% 

010 

100% 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

C3.I6a  

Measure / Sub-Measure Name  

Plan to boost the sustainability, research, innovation and 
digitalisation of the fisheries sector (I): Purchase of ICT 
for marine reservoirs (radiolink Faro de Alborán, night 
vision equipment and drones) 

C3.I6b  

Plan to boost the sustainability, research, innovation and 
digitalisation of the fisheries sector (I): Other actions k est 

C3.I7  

C3.I8  

C3.I9  

C3.I10  

Plan to boost the sustainability, research, innovation and 
digitalisation of the fisheries sector (II): Boosting 
fisheries and aquaculture research and supporting training 
to improve the monitoring of fish stocks 

Plan to boost the sustainability, research, innovation and 
digitalisation of the fisheries sector (III): Technological 
development and innovation in the fisheries and 
aquaculture sector 

Plan to boost the sustainability, research, innovation and 
digitalisation of the fisheries sector (IV): Digitalisation 
and use of ICTs in the fisheries sector 

Plan to boost the sustainability, research, innovation and 
digitalisation of the fisheries sector (V): Supporting the 
fight against illegal, unreported and unregulated fishing 

C4.I1a  

Digitalisation of natural heritage knowledge 

C4.I1b  

Digitalisation of natural heritage knowledge: Other 
actions  

53 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

3 

7 

049 

40% 

011 

100% 

049 

40% 

14 

050 

40% 

021 

40% 

11 

023 

40% 

021 

40% 

11 

44 

61 

77 

011 

100% 

050 

40% 

050 

050 

40% 

40% 

011 

011 

100% 

100% 

 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C4.I2  

Conservation of terrestrial marine biodiversity 

C4.I3a  

C4.I3b  

C4.I4a  

Recovery of areas affected by mining with efficiency 
criteria 

Other ecosystem restoration actions to protect nature and 
biodiversity, natural heritage and resources, and develop 
green and blue infrastructure  

Sustainable forest management for the prevention and 
management of climate related risks: Fire extinguishing 

C4.I4b  

Other actions of sustainable forest management  

C5.I1a  

Materialisation of Purification, Sanitation and Reuse 
Actions for water collection and treatment compliant with 
energy efficiency criteria 

C5.I1b  

Improving efficiency and reducing losses in water use 

C5.I1c  

Investments to improve the safety of dams and reservoirs 

C5.I1d  

C5.I2a  
C5.I2b  
C5.I2c  

C5.I2d  

Implementation of purification, sanitation, efficiency, 
savings, reuse and infrastructure safety (DSEAR). PERTE 
digitalising the water cycle. 

Monitoring and restoration actions in river ecosystems 
Actions to mitigate flood risk 
Measures to reduce groundwater abstraction 

Monitoring and restoration of river ecosystems, aquifer 
restoration and flood risk mitigation. PERTE digitalising 
the water cycle. 

54 

Climate 

Digital 

Estimated 
costs (EUR 
m) 
552 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

050 

40% 

131 

046bis 

40% 

421 

050 

40% 

170 

231 

036 

050 

100% 

40% 

475 

041bis 

40% 

100 

67 

040 

040 

40% 

40% 

200 

041bis 

40% 

225 
225 
350 

285 

040 
035 
040 

40% 
100% 
40% 

040 

40% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Climate 

Digital 

Coeff. % 

Int. Field 

Coeff. % 

Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C5.I3a  

Improving knowledge and use of water resources 

C5.I3b  

Action to monitor rainfall in river basins and coastlines10 

C5.I3c  

C5.I3d 

C5.I4  

C5.I5  

C5.I6  

C6.I1  

C6.I2a  

Improving meteorological observation and monitoring 
and prevention of climate risks11 

Digital transition in the water sector. PERTE digitalising 
the water cycle. 

Adaptation of the current to climate change and 
implementation of Marine Strategies and Maritime 
Spatial Planning Plans 

Aquifer recovery with alternative resources – (Loans) 

PERTE Digitalisation of water uses – (Loans) 

National rail transport network: Rail investment on the 
core European Corridors 

Construction and modernisation of new rail infrastructure 
(TEN-T comprehensive network) 

C6.I2b  

Digitalisation of the State Road Network 

C6.I2c  

Noise Reduction Action Plans on the State Road Network 

Estimated 
costs (EUR 
m) 
225 

55 

100 

765 

Int. 
Field 

040 

035 

40% 

100% 

035 

100% 

040 

40% 

269 

037 

100% 

1.070 

735 

2.988 

040 

040 

064 

40% 

40% 

100% 

1.010 

065 

100% 

35 

302 

048 

40% 

011 

011 

011 

011 

100% 

100% 

100% 

100% 

010 

100% 

063 

100% 

10 This is a digital investment that is also 100% contributing to the adaptation to climate change, and prevention and management of climate related risks. For this 
reason, the measure receives a 100% coefficient for both the climate change and digital objectives. 
11 This is a digital investment that is also 100% contributing to the adaptation to climate change, and prevention and management of climate related risks. For this 
reason, the measure receives a 100% coefficient for both the climate change and digital objectives. 

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C6.I2f  
C6.I2g  

C6.I3a  

C6.I3b  

C6.I3d  
C6.I4a  

C6.I4d  

C6.I4e  

C6.I4g  

Single European Sky: Digitalisation 
Digital transformation of MITMA 

Development of strategic intermodal and logistic 
terminals on TEN-T network 

Inland access to Spanish ports and terminals (rail 
investments) 

Improving the internal rail accessibility of ports 
ERTMS on-board traffic management systems 

Construction, adaptation or upgrading of cargoes and 
intermodal rail-road terminals and their connections 

Support to multimodal sustainable freight transport (rail 
and maritime) based on ECO-INCENTIVES to supply 
and demand 

Actions to support the renewal or adaptation of railway 
tractor equipment with other material using alternative 
fuels such as hydrogen or electricity 

C6.I4i  

Intelligent transport services for the road sector (ITS) 

C6.I4k  

C6.I4o  

Actions supporting the renewal or upgrading of means 
and men for the expansion of sustainable road 
development with reduced carbon footprint and noise 
reduction 

Projects for the digitalisation of passenger and freight 
transport services at regional and local level 

Climate 

Digital 

Int. 
Field 

Estimated 
costs (EUR 
m) 
107 
50 

Coeff. % 

Int. Field 

Coeff. % 

084 
011 

100% 
100% 

217 

408 

177 
12 

75 

078 

40% 

064 

064 
071 

079 

100% 

100% 
40% 

40% 

120 

079 

40% 

072bis 

100% 

048 

40% 

64 

20 

3 

220 

071 

100% 

063 

100% 

010 

100% 

56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

C7.R3  

Development of energy communities contributing to the 
low carbon economy and to resilience to climate change 

100 

027 

100% 

C7.I1  

C7.I2  

C8.I1  

C8.I2  

C8.I3  

C9.I1  

C10.I1a  

C10.I1b  

C10.I1c  

C10.I1d  

C11.I1  

Development of innovative renewables, integrated into 
buildings and production processes 

Sustainable energy on islands 

Breakdown of energy storage, with contribution to green 
and digital transitions 

Digitalisation of distribution networks to align them with 
the energy transition 

New business models in the energy transition, with 
contribution to green and digital transitions 

Renewable hydrogen: a country project 

Environmental restoration plan for closed or abandoned 
mining sites and deteriorated land adjacent to thermal or 
nuclear power stations, compliant with efficiency criteria  

Digital, social and environmental infrastructure plan in 
just transition territories 

Projects of R&D&I in energy storage and energy 
efficiency 

Plan to support the re-skilling and employability of 
workers and people affected by the energy transition 

Digital transformation and modernisation of the General 
State Administration 

2.365 

700 

684 

525 

156 

1.555 

029 

029 

033 

100% 

100% 

100% 

033 

100% 

027 

022 

100% 

100% 

150 

046bis 

40% 

100 

050 

40% 

022 

100% 

01 

100% 

30 

20 

960 

033 

033 

033 

40% 

40% 

40% 

011 

100% 

57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C11.I2  

C11.I3  

C11.I3a  

C11.I4  

C11.I5  

Projects for the digitalisation of the General State 
Administration 

Digital transformation and modernisation of the Ministry 
of Territorial Policy and the Civil Service and the 
administration of the Autonomous Communities and the 
local authorities 

Digital transformation and modernisation of the Ministry 
of Territorial Policy and the Civil Service, the National 
Health Service and the administrations of the 
Autonomous Communities and Local Authorities.  
PERTE Health  

Energy Transition Plan in the General State 
Administration with on average primary energy savings 
of at least 30 % 

Contribution to transformative projects for the 
digitalisation of strategic productive sectors 

C11.I6a  

Cybersecurity programme (ciber) 

C12.I1  

Sectoral data spaces (contribution to transformative 
projects for the digitalisation of strategic productive 
sectors) 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

1.205 

1.000 

130 

1.071 

026bis 

100% 

3 

1.157 

400 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

021  
quinquies 

100% 

021 quarter 

100% 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

C12.I2.a.i  

C12.I2.a.ii  

C12.I2.a.iii  

Measure / Sub-Measure Name  

Processes of research, technology transfer and innovation 
and for business-to-business cooperation with a focus on 
the low-carbon economy and climate change adaptation 
of the Spanish industrial sector 

Processes of research, technology transfer and innovation 
and for cooperation between enterprises, with a focus on 
the circular economy and the Spanish industrial sector 
Projects to improve energy efficiency in the industrial 
sector (SMEs and large enterprises) 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

457 

022 

100% 

457 

023 

40% 

914 

024 

40% 

C12.I2.a.iv  

Digitalisation of the industrial sector (SMEs and large 
enterprises) 

457 

010 

100% 

C12.I2b  

Support to process and organisational innovation projects 
in key areas for the industrial transition: line of action 2 

118 

024 

40% 

C12.I2c  

C12.I2e  

C12.I3  

C12.I3 

Support to smaller scale projects for the implementation 
of digitalisation in processes and the organisation of 
industrial companies: line of action 3 
Support to sustainable industrial infrastructure: line of 
action 5 

Plan to support the implementation of waste legislation 
and the promotion of the circular economy 

Plan to support the implementation of waste legislation 
and the promotion of the circular economy. Circular 
Economy PERTE 

95 

13 

026 

40% 

850 

042 

40% 

300 

042 

40% 

010bis 

100% 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

Estimated 
costs (EUR 
m) 

Int. 
Field 

C12.I4  

C12.I5  

C12.I6  

C12.I7  

C13.I1  

C13.I3  

PERTE CHIP. Strengthening the industry of the whole 
semiconductor value chain.  

Circular Economy Subsidy Scheme. PERTE Circular 
Economy 

Subsidy scheme to support strategic projects in the value 
chain for electric cars (grants) 
Support scheme to support strategic projects for Industrial 
Transition in the value chain for electric cars and agrifood 
(loans) 
Support to entrepreneurship including digital transition 
action 
Digitalisation and Innovation of SMEs 

C13.I6a  

ICO-Green Line - I Sustainable transport  

C13.I6a  

C13.I6a  

C13.I6a  
C13.I6a  

C13.I6.b  

ICO-Green Line - II Energy efficiency and renewable 
energies 
ICO-Green Line - III Networks, industrial 
decarbonisation and climate change mitigation and 
adaptation 
ICO-Green Line - IV Circular Economy  
ICO-Green Line - VI Water Management  

ICO Enterprises and Entrepreneurs Line - I PERTE NEW 
ECONOMY OF LANGUAGE 

C13.I7  

Technology startups fund: Next Tech 

C13.I12.b  

ENISA Entrepreneurship and SME Fund - SMEs Natural 
Language Processing Projects PERTE NEL 

60 

Climate 

Digital 

Coeff. % 

Int. Field 

Coeff. % 

021 quarter 

100% 

200 

300 

250 

042 

40% 

047 

40% 

480 

027 

100% 

329 

100 

0% 

3.548 

5.000 

5.000 

073 

029 

100% 

100% 

5.000 

022 

100% 

042 
039bis 

40% 
40% 

3.500 
3.500 

150 

4.000 

20 

100 

010 

40% 

100% 

009bis 

010 

010 

100% 

100% 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

9.750 

024ter 

100% 

Measure/Sub-
Measure ID 

C13.I13a  

C14.I1.a.i  

C14.I1.a.ii  

C14.I1b  

C14.I1c  

C14.I2  

C14.I4b  

C15.R1  

C15.R2  

Measure / Sub-Measure Name  

Regional Resilience Fund (FRA). Contribution to climate 
transition 
Actions in the field of green and sustainable transition 
(100% coefficient) Adaptation to climate change of 
destination and its infrastructure: development of 
knowledge and development of plans in relation to 
climate change adaptation and risk prevention, including 
early warning, monitoring and assessment systems, 
promotion of investment for the prevention and 
management of specific risks on the territory 
Actions in the field of green and sustainable transition 
(40% coefficient) Circular economy, management of 
natural resources, protection and enhancement of natural 
ecosystem. 
Sustainable mobility and energy efficiency actions for 
tourism destinations 

Actions in the field of the digital transition 

Digitisation and intelligence programme for destinations 
and tourism sector 

139 

035 

100% 

139 

050 

40% 

073 

100% 

372 

186 

337 

Energy efficiency and circular economy in tourism 
enterprises 

220 

024 

40% 

Reforming the Telecoms Regulatory Framework: General 
Law, Regulatory Instruments and Implementation 
Instruments 

Roadmap 5G: Spectrum management and assignment, 
deployment burden reduction, Cybersecurity Act 5G and 
Support to Local Authorities 

8 

110 

61 

011 

010 

100% 

100% 

011 

100% 

054bis 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

C15.I1  

C15.I2  

C15.I3  
C15.I4  
C15.I5  
C15.I6  

C15.I7  

C15.I8  

C15.I9  

C16.R1b  

C16.R1  

C17.I2a  

Fostering territorial cohesion through network 
deployment: Ultra-fast broadband extension and mobility 
coverage of 30 Mbps 
Reinforcing Connectivity in Reference Centres, Socio-
Economic Drivers and Sectoral Digitalisation Tracking 
Projects 
Connectivity vouchers for SMEs and vulnerable groups 
Data infrastructure renewal and sustainability 
Deployment of cross-border digital infrastructure 
Deployment of 5G networks, and 5G innovations 
Cybersecurity: Strengthening the capacities of citizens, 
SMEs and professionals; Improving the sector’s 
cybersecurity ecosystem 
Strengthening the scientific and technological ecosystem. 
Increased design capabilities. PERTE CHIP 

Increased capacities of the fabless and manufacturing 
industry. PERTE CHIP. Loans 

National AI Strategy. PERTE CHIP 
National Artificial Intelligence Strategy, including R&I in 
AI and talent development  

Strengthening the capacity, infrastructure and equipment 
of SECTI actors. PERTE CHIP 

752 

480 

80 
80 
500 
1.465 

524 

621 

10.750 

40 

500 

264 

054bis 

100% 

053 

100% 

012 
052 
055 
054bis 

054  
quinquies 

021  
quarter 

021  
quarter 

009bis 

100% 
100% 
100% 
100% 

100% 

100% 

100% 

100% 

001 

0% 

009bis 

100% 

009bis 

100% 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

C17.I3a  

C17.I4a  

C17.I7  

C17.I8  

C18.I6  
C19.I1  
C19.I2  
C19.I3  
C19.I4  

C20.I1b  

C20.I1d.i  
C20.I2  

C21.I5  

C22.I1b  

Private, interdisciplinary public R & D & I projects, Proof 
of concept and grant of aid following international 
competitive calls. Cutting-edge R & D addressing societal 
challenges. Public pre-commercial purchase. PERTE 
CHIP 

New scientific career. Post-doctoral researcher 
consolidation programme. PERTE CHIP 
R&D + R & I actions linked to environmental protection, 
the fight against climate change, new energy sources and 
key technologies and materials for the energy transition  
R & D + R & I actions linked to sustainable automotive 
(PTAS) 
Creation of a “Data Lake” for the Health sector 
Transversal digital skills 
Digital Transformation of Education 
Digital skills for employment 
Digital Professionals 
Reskilling and upskilling of the labour force linked to 
professional qualifications: Digital modular offer for 
employed persons associated with competence units of 
the National Catalogue of Professional Qualifications 
Contribution reskilling and upskilling to green transition 
Digital transformation of vocational training 

Improvement of digital infrastructure, equipment, 
technologies, teaching and university assessment 
E-Health services and applications: teleassistance for 
long-term care and support 

90 

10 

82 

40 

100 
735 
1.412 
1.256 
190 

92 

158 
290 

147 

240 

63 

023 

40% 

024 

40% 

01 

100% 

009bis 

100% 

009bis 

100% 

095 
108 
108 
108 
108 

108 

016 

108 

013 

100% 
100% 
100% 
100% 
100% 

100% 

40% 

100% 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Climate 

Digital 

Coeff. % 

Int. Field 

Coeff. % 

Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C22.I2b  

Technological transformation of social services 

Estimated 
costs (EUR 
m) 
216 

Int. 
Field 

C22.I3b  

C22.I4b  

C22.I5b  

C23.I1b  

C23.I1c  

C23.I2b  

C23.I3b  

C23.I4b  

C23.I5  

C24.I1c  

Improving accessibility of AGE websites and mobile 
applications 
Improving comprehensive improvement of control device 
services 
Digital investment host system 

JOVEN-TánDEM EMPLOYMENT Programme with 
allocation for green / digital skills 

Programme First professional experience in public 
administrations with allocation for green / digital skills 

Support line for women in rural and urban areas with 
allocation for green / digital skills 

Training for workers in ERTE with allocation for green / 
digital skills 
Entrepreneurship and micro-enterprises: New territorial 
projects addressing the demographic challenge and 
facilitating productive transformation, in particular 
towards a green and digital economy 
Governance and support of active labour market policies  
Strengthening the competitiveness of cultural industries /  
Competitiveness and professionalisation and support for 
cultural accelerators including boosting the 
transformation to digital culture and the incorporation of 
new technologies into cultural and creative industries 

12 

26 

14 

30 

37 

26 

107 

01 

01 

01 

01 

100% 

100% 

100% 

100% 

55 

047 

40% 

106 

25 

12 Clerical error corrected from SWD(2021) 147 

64 

011 

020 

011 

011 

108 

108 

108 

108 

016 

108 

100% 

40% 

100% 

100% 

100% 

100% 

100% 

100% 

40% 

100%12 

018 

40% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

C24.I1d  

C24.I1e  

C24.I1f  

C24.I2d  

C24.I3c  

C24.I3d  

C24.I3e  

C24.I3f  

Strengthening the competitiveness of cultural industries 
supporting projects to digitise intellectual property rights 
management operators 

Strengthening the competitiveness of cultural industries / 
Digitalisation of intellectual property management 
systems / Digital transformation of administrative units 
with intellectual property competence 

Strengthening the competitiveness of cultural industries 
(promotion and digitisation of the book sector) 
Promoting culture along territorials (purchase of licences 
for digital books) 
Digitalisation of major cultural services: National Library 
of Spain 

Digitalisation and boosting major cultural services: Plan 
for digital access to bibliographic heritage 
Digitalisation and boosting major cultural services: 
Digitalisation, capacity building and interoperability of 
archiving systems 
Digitalisation and boosting major cultural services: 
Measures to modernise public management tools and put 
in place an integrated system for digitisation and 
cataloguing of INAEM’s resources, assets, structures and 
infrastructure 

15 

1 

25 

13 

7 

3 

18 

11 

010 

100% 

011 

100% 

010 

100% 

021bis 

40%13 

011 

011 

100% 

100% 

011 

100% 

011 

100% 

13 A coefficient of 40% is applied because the measure is not fully dedicated to digital books but also includes paper books. 

65 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure / Sub-Measure Name  

C25.I1a  

C25.I3a  

C25.I3.b  

C26.I1  

C26.I2a  

C26.I2b  

C26.I3a  

C28.I1a  
C28.I1b  

C31.I1  

Programme for the promotion, modernisation and 
digitisation of the audiovisual sector 
Spain Audiovisual Hub Fund 

Spain Audiovisual Hub Fund. PERTE New Language 
Economy 

Digitisation of the sport sector 

Modernisation of sport facilities to improve their energy 
performance  according to energy efficiency criteria  
Modernisation of high performance sport centres to 
improve their energy performance according to energy 
efficiency criteria 

Modernisation of sports installations to improve energy 
efficiency according to  energy efficiency criteria 
Fiscal Reform Fund. Renovation of housing 
Fiscal Reform Fund. Electrification of mobility 
Investment promoting self-consumption (based on 
renewable energy and behind-the-meter storage) and 
energy communities 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

021bis 

 021bis 

 021bis 

011 

100% 

100% 

100% 

100% 

155 

1.500 

212 

76 

34 

73 

28 

250 
233 

666 

026bis 

100% 

026bis 

100% 

026bis 

100% 

025bis 
n/a14 

100% 
40% 

029 

100% 

14 This measure includes investment in hybrid and zero-emission vehicles. For this investment the ‘Methodology for climate tracking’ annexed to the Recovery 
and Resilience Facility Regulation does not set out intervention fields that would allow for climate or environmental tracking of electric vehicles or plug-in hybrid 
vehicles, except for vehicles for urban transport falling under intervention field 074. According to Article 18(4)(e) of the  Regulation, the methodology should 
however ‘be used accordingly for measures that cannot be directly assigned to an intervention field listed in Annex VI’. In this context, the Commission has applied 
a 40% climate contribution coefficient for the zero-emission vehicles of all categories (this includes battery electric and fuel cell/hydrogen-powered vehicles) and 
the plug-in hybrid vehicles included in this measure.  

66 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

C31.I2  

C31.I3a  

C31.I3  

Measure / Sub-Measure Name  

Scheme to support the production and uptake of 
renewable hydrogen 

Subsidy scheme to support the value chain of RES and 
storage. Lines 1 (solar PV value chain), 2 (storage value 
chain) and 4 (other renewable value chains) 

Subsidy scheme to support the value chain of RES and 
storage. Line 3 Adaptation of ports for the deployment of 
offshore renewable energy.  

C31.I4  

Investment to support electricity network infrastructure 

C31.I5  

Investment to support industrial decarbonisation (grants).  

C31.I6  

Subsidy scheme for decarbonisation projects (grants).  

C31.I7  

 Investment to support decarbonisation projects (loans) 

Climate 

Digital 

Estimated 
costs (EUR 
m) 

Int. 
Field 

Coeff. % 

Int. Field 

Coeff. % 

1.600 

022 

100% 

838 

029 

100% 

162 

081bis 

40% 

931 

590 

430 

650 

033 

024 

024 

024 

100% 

40% 

40% 

40% 

C31.I8  

Support scheme for decarbonisation projects (loans) 

1050 

024 

40% 

Int. Field = intervention field 

Coeff. % = Coefficient for the calculation of support to climate change objectives and to digital transition, on the basis of Annex VI and Annex VII 
to the RRF Regulation 

67