COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Sweden Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 7772/2022; ST 7772/2022 ADD 1) of 4 May 2022 on the approval of the assessment of the recovery and resilience plan for Sweden
Date: 2023-10-19
Institutions: European Commission, Secretariat-General
Subjects: EU aid, Sweden, digital transformation, economic and social cohesion, economic recovery, economic reform, energy policy, green economy, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.10.2023  SWD(2023) 342 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Sweden Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 7772/2022; ST 7772/2022 ADD 1) of 4 May 2022 on the approval of the assessment of the recovery and resilience plan for Sweden {COM(2023) 671 final}  
 
 
Table of contents 
1.  Executive summary ............................................................................................................................... 2 

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

3.  Summary of the assessment of the plan ................................................................................................ 4 

3.1.  Comprehensive and adequately balanced response to the economic and social situation ............ 4 

3.2. 

Link with country-specific recommendations and the European Semester .................................. 6 

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 ........ 7 

3.4. 

The principle of ‘do no significant harm’ ..................................................................................... 7 

3.5.  Green transition ............................................................................................................................. 9 

3.6.  Digital transition ......................................................................................................................... 10 

3.7. 

Lasting impact of the plan ........................................................................................................... 11 

3.8.  Milestones, targets, monitoring and implementation .................................................................. 11 

3.9.  Costing ........................................................................................................................................ 12 

3.10.  Controls and audit ....................................................................................................................... 13 

3.11.  Coherence ................................................................................................................................... 15 

3.12.  REPowerEU ................................................................................................................................ 15 

3.13.  Cross-border or multi-country dimension or effect .................................................................... 16 

ANNEX I: Climate tracking and digital tagging..................................................................................... 18 

1 

 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

In 2022, Sweden’s economy was confronted with the adverse effects of the Russian aggression 
against  Ukraine.  Even  if  the  direct  exposure  through  trade  linkages  was  rather  limited,  the 
increase in energy prices and ultimately inflation and the subsequent monetary tightening impacted 
the Swedish economy particularly hard because of the high private debt and short-interest fixation 
periods. As a consequence, private consumption declined and investment in construction dropped, 
leading to a decline in GDP. 

For the modification of the RRP, Sweden has relied on the following legal bases: Article 18(2) to 
take into account the updated maximum financial contribution, Article 21c to include additional 
resources from ETS revenues and from the Brexit Adjustment Reserve (BAR) for its REPowerEU 
chapter. 

The  modifications  submitted  by  Sweden  under  Article  18(2)  of  Regulation  (EU)  2021/241 
affect  two  measures  of  the  original  RRP.  In  particular,  the  investment  in  the  Strengthened 
Railway Support has been reduced, namely by taking out the replacement and upgrading of 160 
road  protection  facilities  and  the  upgrade  of  the  bridge  located  in  Vänersborg.  In  addition,  the 
modified RRP rectifies clerical errors in six measures.  

The REPowerEU chapter contains measures to help address the key energy challenges that 
Sweden  currently  faces.  The  proposed  measures  contain  a  reform  to  shorten  the  permitting 
process  for electricity grid construction and  the scaling-up of two measures  already part of the 
original  RRP:  investments  in  energy  efficiency  in  multi-dwelling  buildings  and  an  investment 
subsidy for rental and student housing respectively. The proposed REPowerEU chapter addresses 
four  out  of  the  six  objectives  pursued  by  the  Regulation.  The  implementation  of  the  proposed 
measures  is  expected  to  effectively  promote  energy  efficiency  in  buildings  and  critical 
infrastructure, tackle energy poverty, create incentives to reduce energy demand as well as address 
internal  and  cross-border  bottlenecks  in  energy  transmission  and  distribution.  The  measures 
contribute to addressing the country-specific recommendations adopted by the Council on 24 June 
2022 and on 14 July 2023 and, in particular, to the green and digital transition. New measures in 
the  REPowerEU  chapter  have  a  cross-country  dimension.  Based  on  the  assessment  of  the 
submitted modification and the REPowerEU chapter, the Swedish 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 (43.6%  A (21.2%) 

A 

A 

B 

A 

A 

A 

A 

2 

 
 
 
 
 
 
2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

2.1 New challenges in Sweden 

Sweden’s economy was hit midships in 2022 by the deterioration in its terms-of-trade and 
needed  policy  tightening  to  fight  inflation.  The  Russian  aggression  against  Ukraine  hit  the 
Swedish economy surprisingly hard. The direct exposure through trade linkages was rather limited 
and Sweden actually exports electricity on net. It was, however, the broader increase in energy 
prices and, ultimately, inflation and the subsequent monetary tightening that impacted the Swedish 
economy particularly hard because of the high private debt and short-interest fixation periods. As 
a consequence, private consumption declined and investment in construction dropped, leading to 
a decline in GDP. Relatively slow external demand developments further weighed on the economy. 
Sweden’s economy would, therefore, benefit from increasing its resilience by reducing imbalances 
related to high household debt related to high house prices while further insulating it from energy 
price shocks.  

The  Swedish  modified  recovery  and  resilience  plan  adds  a  REPowerEU  chapter  to  the 
original plan pursuant to Article 21(c) of the RRF Regulation and is a relevant response to 
the geopolitical and energy challenges faced by the European Union. The amendment of the 
RRF Regulation provides for additional support for reforms and investments helping to phase out 
imports of Russian fossil fuels and providing clean, affordable and secure energy to households 
and businesses across Europe. The modifications proposed under the plan and the newly integrated 
REPowerEU  chapter  are  aimed  at  addressing  a  significant  subset  of  the  country-specific 
recommendations for Sweden presented in the context of the European Semester 2022 and 2023 
cycle.  

Pursuant to Article 18(2) of the RRF Regulation, Sweden justified a part of its modifications 
by the decrease of its maximum financial contribution. The maximum financial contribution 
for Sweden was updated on 30 June 2022 and decreased from EUR 3 288 million to EUR 3 181 
million1.  To  take  this  reduction  in  the  allocation  into  account,  Sweden  proposes  to  reduce  the 
investment  in  the  Strengthened  Railway  Support  and  to  remove  two  related  measures:  the 
replacement and upgrading of 160 road protection facilities and the upgrade of the bridge located 
in Vänersborg. The table below lists the associated costs of the new and modified components, i.e. 
Component 1 “Green Recovery” and component 6 “REPowerEU”. 

2.2 The REPowerEU chapter 

Under the REPowerEU chapter and based on Article 21c of Regulation (EU) 2021/241, Sweden 
has requested to scale-up two investments and to add one new reform: 

1 This amount corresponds to the financial allocation after deduction of Sweden’s proportional share of the expenses of 
Article 6(2) of Regulation (EU) 2021/241, calculated in accordance with the methodology of Article 11 of that Regulation. 

3 

 
 
 
 
Component 6 (REPowerEU chapter): 

Scaled-up investment 6.1 Energy efficiency in multi-dwelling buildings 

The objective of this measure is  to  scale-up  Investment  3:  Energy efficiency in  multi-dwelling 
buildings, under component 1: Green recovery. This public support scheme aims to incentivize 
property owners to renovate multi-dwelling buildings. The investment subsidy to renovate these 
buildings  and make them  more energy efficient  is  an important  incentive in  absence of a clear 
business case (low profitability). The support scheme will be available for investments that achieve 
at  least  a  20%  reduction  in  the  primary  energy  demand  for  a  specific  building.  Smart  energy 
systems could be integrated in the renovation efforts to achieve energy efficiency improvement. 
With the scaling-up of the measure, the number of renovated square meters for energy efficiency 
purposes will increase in proportion to the additional funding becoming available. 

Scaled-up investment 6.2 Investment subsidy for rental and student housing 

The objective of this measure is to scale-up Investment 1: Investment aid for rental and student 
housing, under component 5: Investment for growth and housing. Through this investment, which 
is increasing the supply of new rental dwellings with a lower rent relative to new non-subsidised 
housing, Sweden tackles housing shortages, energy poverty and enhances the energy efficiency of 
its housing stock. Requirements for landlords in allocating the housing will make these dwellings 
economically accessible to a larger number of households, giving a better chance on the housing 
market to individuals in the lower half of the income distribution, students or people becoming 
active on the labor market. To cater in particular for those that are in an unfavorable position on 
the housing market, prone to energy poverty and have a relatively low income a maximum rent is 
set  together  with  the  before  mentioned  explicit  absence  of  income  requirements  for  potential 
tenants. To the benefit of both lower energy demand and lower energy costs, the support scheme 
will give support only to investments that achieve at least a 20% reduction in the primary energy 
demand at the level of the building compared to the requirements of the building regulation. The 
scale-up  of  the  measure  increases  the  number  of  completed  dwellings  for  rental  and  student 
housing.   Construction subsidies will be paid to houses that are completed in 2022 and 2023. 

Reform 6.3 to speed up the authorisation process in electricity grid construction 

The objective of this reform is to shorten the permitting process for electricity grid construction, 
in view of strengthening electricity networks within Sweden. The reform also aims to address 
domestic and cross-border bottlenecks in electricity transmission. The reform consists of 
legislation simplifying procedures for the construction of electricity network infrastructure. In 
this regard, the reform includes the following elements:  

•  a derogation from requirements for exemptions from local area protection as described in 

Chapter 7, Sections 11-b and 13-18h of the Swedish Environmental Code; and   

•  a presumption for the use of overhead line solutions over ground cable solutions when 
assessing technology choices at the highest voltage levels, which replaces the existing 
requirement that both types of solutions should be explored by default as described in in 
Chapter 2, Sections 12 and 17 of the Electricity Act. 

4 

 
 
The  measures  presented  under  the  REPowerEU  chapter  are  consistent  in  addressing  the 
main challenges set out by the REPowerEU plan according to the Regulation (EU) 2023/435. 
The  implementation  of  the  measures  included  in  the  REPowerEU  chapter  are  expected  to 
contribute notably to supporting four of the six objectives of Regulation (EU) 2021/241, namely 
those  in  Article  21c(3),  points  (b)  energy  efficiency  in  buildings,  (c)  energy  poverty,  (d) 
incentivising reduction of energy demand and (e) internal and cross-border energy transmission 
and distribution bottlenecks. 

Table 2.1: Components in the modified RRP and associated estimated costs2 (EUR million). 

Component 

1: Green recovery 
2. Education and transition 
3. Better conditions for addressing 
demographic challenges 
4. Broadband expansion and 
digitalisation of public administration 
5. Investment for growth and housing 
6. RePowerEU chapter 
TOTAL 

Existing Plan 
Financial 
contribution 
1 552 
504 

Addendum 
Financial 
contribution 
-70 
- 

452 

485 

296 
- 
3 289 

- 

- 

- 
283 
213 

Overall 
Total 

1 482 
504 

452 

485 

296 
283 
3 502 

Other elements not covered by assessment criteria  

The  description  of  the  implementation  and  monitoring  aspects  of  the  plan  as  well  as  the 
contribution to gender equality, as reflected in the previous Staff Working Document SWD(2022) 
102 final remains valid. 

State aid and competition rules fully apply to the measures funded by the Recovery and Resilience 
Facility. Union funds channelled through the authorities of Member States, like the RRF funds, 
become State resources and can constitute State aid. When this is the case and State aid is present, 
these measures must be notified and approved by the Commission before Member States can grant 
the aid, unless those measures are covered by an existing aid scheme or comply with the applicable 
conditions of a block exemption regulation, in particular the General Block Exemption Regulation 
(GBER) declaring certain categories of aid compatible with the internal market in application of 
Articles 107 and 108 TFEU3. When State aid is present and it requires notification, it is the duty 

2 The total estimated costs for measures to be supported by the financial contribution in the form of non-repayable 
support is in excess of the plan’s financial contribution of EUR 3 380 million (after deduction of Sweden’s 
proportional share of the expenses of Article 6(2) of Regulation (EU) 2021/241). 
3 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 

5 

 
 
 
 
 
 
 
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 Sweden 
in the recovery and resilience plan cannot be deemed a State Aid notification. In as far as Sweden 
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 Sweden 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 

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

Green 
transition 

Digital 
transfor
mation 

Smart, 
sustainable 
& inclusive 
growth 

Social 
and 
territorial 
cohesion 

Component 1 Green 
Recovery 
Component 6 
REPowerEU chapter 

● 

● 

○ 

○ 

○ 

○ 

○ 

○ 

Health, 
and 
economic
, social 
and 
institutio
nal 
resilience 

● 

Policies 
for the 
next 
generati
on 

○ 

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

Sweden’s  modified  plan  along  with  the  REPowerEU  chapter  includes  a  balanced  set  of 
reforms  and  investments  contributing  to  the  Union’s  economic,  social  and  territorial 
cohesion by referring to the six pillars of Article 3 of the Regulation (EU) 2021/241. The nature 
and  extent  of  the  proposed  modifications  to  the  RRP  do  not  have  an  impact  on  the  previous 
assessment of the plan’s comprehensive and adequately balanced response to the economic and 
social situation, and on its appropriate contribution to all six pillars referred to in Article 3 of the 
RRF Regulation, as reflected in Staff Working Document SWD(2022) 102 final.  

Green  transition  challenges  are  addressed  under  the  scaled-up  investment  support  for 
energy efficiency in multi-dwelling buildings and the investment subsidy for the construction 
of  energy  efficient  rental  and  student  housing.  These  investment  measures  top  up  existing 
investment measures in the original RRP. These measures were already identified as contributing 

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 

6 

 
 
 
 
 
 
 
to the green transition and the larger financial impulse will help to further advance Sweden’s green 
transition. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) that the plan represents  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  Sweden  into account, as reflected in  the 
previous Staff Working Document SWD(2022) 102 final. 

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

Overall, Sweden’s modified RRP represents a comprehensive and adequate response to the 
economic  and  social  challenges  faced  by  Sweden.  While  the  modified  plan  reduces  the 
investment in one measure in line with the lower financial allocation, it introduces a new reform 
and  scales  up  two  investments  from  the  original  RRP  that  imply  a  continued  coverage  of  a 
significant subset of the challenges identified in the country-specific recommendations (CSRs). 
As the maximum financial contribution for Sweden has been adjusted downwards, the 2022 and 
2023  recommendations  not  related  to  energy  challenges  are  not  considered  in  the  overall 
assessment. 

Sweden is proposing to modify only the elements of its original recovery and resilience plan related 
to the measure Strengthened Railway Support, as well the inclusion of the REPowerEU chapter. 
Therefore,  only  recommendation  2020.2,  recommending  to  focus  investment  on  sustainable 
transport and 2019.2, recommending to maintain investments in sustainable transport to upgrade 
the different transport modes, as well as and 2022 and 2023 recommendations related to energy 
challenges are considered in the overall assessment. 

The REPowerEU chapter contributes to addressing several challenges identified in energy-related 
country-specific  recommendations  made  in  2022  (CSR  2022.4),  as  well  as  the  energy-related 
country-specific  recommendations  made  in  2023  (CSR  2023.4).  The  second  recommendation 
consisted of proceeding with the implementation of its recovery and resilience plan, in line with 
the milestones and targets included in the Council Implementing Decision of 29 October 2021. 
(CSR 2, 2022) The recovery and resilience plan is relevant for the energy challenges Sweden faces 
through  its  energy-efficiency  and  other  climate-related  measures.  Finally,  Sweden  was 
recommended  to  reduce  the  overall  reliance  on  fossil  fuels  by  accelerating  the  deployment  of 
renewables  and  boosting  complementary  investment  in  network  infrastructure,  strengthening 
internal  grids  within  the  country  to  ensure  sufficient  network  capacity,  improving  energy 
efficiency,  and  further  streamlining  permitting  procedures  in  relation  to  renewable  energy 
projects).  

The  scaled-up  investments  and  the  reform  introduced  in  the  REPowerEU  chapter  will 
address  the  country-specific  recommendations.  In  particular,  they  will  increase  energy 
efficiency, help protect more vulnerable households against high energy prices and foster energy 

7 

 
 
security. The first scaled-up investment lowers the cost of energy efficiency investments in multi-
dwelling buildings, with a particular reference to investments that would otherwise not have taken 
place.  The  second  scaled-up  measure  concerns  investment  in  rental  and  student  housing  that 
alleviates the housing market shortage for rental apartments with apartments that are more energy 
efficient than the most recent standard for energy efficient buildings. The reform aiming to speed 
up the authorization process for expanding grid capacity will help raise energy security and help 
ensure sufficient network capacity. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on 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 Sweden, as reflected in the previous Staff Working Document SWD(2022) 102 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  

Sweden’s modified recovery and resilience plan can be expected to have a positive impact on 
social, institutional and economic resilience that is in accordance with its budget envelope. 
The easier authorisation procedure will immediately allow for new permit requests, expand the 
grid capacity and the speedier procedure will not easily be reversed as it responds to a broadly felt 
need in Sweden’s electrification strategy. The energy-efficiency improvements have a longer-term 
investment  horizon  which,  by  reducing  energy  consumption,  reduces  the  exposure  of  Swedish 
households and, through the reduction in total energy demand,  corporates from price volatility. 
The  investments  will  permanently  reduce  housing  shortages,  offering  more  chances  for  the 
relatively  less  well-off,  while  reducing  energy  demand  with  similar  impacts  as  the  energy 
efficiency  measure.  Offering  more  housing  to  students  lowers  travelling  time  and  can  improve 
their academic performance. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the plan’s impact on the 
growth potential, job creation, and economic, social and institutional resilience of the Member 
State, on contributing to the implementation of the European Pillar of Social Rights, including 
through the promotion of  policies for  children and youth,  and on mitigating the economic and 
social  impact  of  the  COVID-19  crisis,  thereby  enhancing  the  economic,  social  and  territorial 
cohesion and convergence within the Union, as reflected in the previous Staff Working Document 
SWD(2022) 102 final. 

8 

 
 
3.4. The principle of ‘do no significant harm’  

Sweden’s  modified  recovery  and  resilience  plan  including  the  REPowerEU  chapter  is 
expected to continue to ensure that no measure included in the plan does significant harm to 
environmental objectives, within the meaning of Article 17 of the Taxonomy Regulation. The 
modified plan assesses compliance with the ‘do no significant harm’ (DNSH) principle following 
the  methodology  set  out  in  the  Commission’s  technical  guidance  on  the  application  of  ‘do  no 
significant  harm’  under  the  Recovery  and  Resilience  Facility  Regulation  (2021/C58/01).  The 
assessment is done for the new reform taking into account that the reform directly contributes to 
the improvement of the energy infrastructure (REPowerEU’s first objective). The reform has no 
budgetary costs attached to it. The reform is assessed as necessary and proportionate to meet the 
security of supply needs, having no cleaner feasible alternatives and does not risk locking in fossil 
fuel usage. The Member State has undertaken satisfactory efforts to limit the potential  harm to 
environmental  objectives  where  feasible  and  to  mitigate  harm  through  other  measures.    The 
measure contributes to achieving the Union’s 2030 climate targets and the objective of EU climate 
neutrality by 2050. The measure is planned to be in operation by 31 December 2026. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not  have  a  material  impact  on  the  previous  assessment  (rating  of  A)  that  no  measure  for  the 
implementation  of  reforms  and  investment  projects  included  in  the  plan  is  expected  to  do  a 
significant harm to environmental objectives within the meaning of Article 17 of Regulation (EU) 
No 2020/852 (the principle of ‘do no significant harm’), as reflected in the previous Staff Working 
Document SWD(2022) 102 final. 

3.5. Green transition 

All three measures in the REPowerEU chapter are expected to contribute to the green transition as 
well as to the achievement of the Union 2030 climate targets and of EU climate neutrality by 2050.  

Green transition 

The modified Swedish plan includes measures supporting climate change objectives for an amount 
which  represents  43.6%  of  the  total  plan’s  allocation  (EUR  1  503.9  billion  out  of  EUR  3  447 
billion)  in  the  form  of  non-repayable  financial  contribution,  including  the  allocations  of  the 
REPowerEU chapter. Measures supporting climate change objectives represent 40% 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 the table in the annex. The largest contributions come from 
the  measures  included  in  the  green  recovery  component  (84.6%  of  the  overall  climate 
contribution).  

9 

 
 
The REPowerEU chapter – component 6 – presents investments amounting to EUR 282.5 billion 
that  scale-up  existing  investments  in  the  Initial  Plan  on  energy  efficiency  in  multi-dwelling 
buildings  and  investment  aid  for  energy-efficient  rental  and  student  housing.  The  chapter  thus 
directly  reinforces  the  investments  contained  in  the  Initial  Plan.  The  scaled-up  investments  are 
supported  by  a  newly  added  reform  accelerating  the  authorisation  process  for  electricity  grid 
expansion,  which  reinforces  investments  and  reforms  in  the  Initial  Plan  contributing  to  the 
electrification of the Swedish economy.   

Climate target 

The modified RRP of Sweden 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 

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; and 
the plan does not propose to increase the climate coefficients of the selected intervention 
fields for any measure. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan does 
not  change  the  previous  assessment  (rating  of  A)  of  the  contribution  of  the  plan  to  the  green 
transition  and  to  the  climate  target,  as  reflected  in  the  previous  Staff  Working  Document 
SWD(2022) 102 final. 

3.6. Digital transition 

On  the  basis  of  the  assessment  guidelines  provided  for  sub-criterion  6c,  the  reforms  and 
investments in the modified RRP (including the REPowerEU chapter)  contributing to the 
digital  transition  account  for  21.2%  (i.e.  above  the  20%  requirement)  of  the  plan’s  total 
allocation, based on the methodology for digital tagging set out in Annex VII. Four out of the six 
components  in  the  amended  plan  contribute  to  the  digital  objectives.  The  most  substantive 
contribution  to  the  digital  target  stems  from  the  measures  in  the  dedicated  component  4  on 
broadband expansion and digitalisation of public administration, which remain unchanged.  The 
measures related to digital skills in component 2 (education and training) are still the same as in 
the  original  RRP.  In  addition,  two  investments  related  to  energy  efficiency  of  buildings  in 
component 1 (green recovery) are scaled up  as  part of the REPowerEU  chapter. The scaled-up 
measures are part of component 6 in the CID annex. 

10 

 
 
The  REPowerEU  chapter  favours  synergies  between  tackling  the  green  and  digital 
transition. Scaled-up investment subsidies for rental and student housing in the component on the 
green  recovery  aim  to  support  the  use  of  digital  technologies  to  increase  energy  efficiency  of 
buildings. In particular, the schemes should incentivise applying smart energy systems as part of 
the renovation effort. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the contribution of the plan 
to the digital transition, as reflected in the previous Staff Working Document SWD(2022) 102 final. 

3.7. Lasting impact of the plan 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the lasting impact of the 
measures proposed by Sweden, as reflected in the previous Staff Working Document SWD(2022) 
102 final. 

3.8. Milestones, targets, monitoring and implementation 

The milestones and targets of the modified Swedish recovery and resilience plan enable an 
adequate monitoring of the plan’s implementation. The reform to the authorization process for 
expanding the electricity grid has one milestone to track the implementation of the reform. The 
scaled-up  investments  add  two  targets  to  the  plan.  The  amendment  in  light  of  the  reduced 
contribution will see one milestone and one target being eliminated from the plan. The milestones 
and targets contain the key elements of the measures and, thus, are relevant for the implementation 
of the proposed changes. The monitoring milestones and targets appear comprehensive and clear 
to ensure that their completion can be traced and verified. Sweden’s modified plan still corresponds 
to the original plan in terms of the overall level of ambition.  

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not  have  a  material  impact  on  the  previous  assessment  (rating  of  A)  of  the  adequacy  of  the 
arrangements proposed by Sweden to ensure the effective monitoring and implementation of the 
plan, as reflected in the previous Staff Working Document SWD(2022) 102 final. 

3.9. Costing 

Sweden has provided individual estimated costs for all the new measures that entail a cost in 
the recovery and resilience plan, including the REPowerEU chapter. There are no measures 
whose modifications would entail a change in the cost estimates or related target including on the 
proportionality of the related amendments. Sweden has not adjusted the cost calculations for price 
changes, instead maintaining the unit cost estimates from the original RRP. As a consequence, the 

11 

 
 
assessment still applies  and the costs of the two scaled-up investment  measures  continue to  be 
assessed as reasonable, plausible as well as commensurate to the objectives and cost efficient. The 
reassurances on avoiding double funding remain in place.  

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not  have  a  material  impact  on  the  previous  assessment  (rating  of  B)  of  the  reasonability  and 
plausibility  of  the  costs, their  additionality,  and  that  they  are  in  line  with  the  principle  of  cost 
efficiency and commensurate to the expected social and economic impact of the modified plan, as 
reflected in the previous Staff Working Document SWD(2022) 102 final. 

3.10. 

Controls and audit  

The previous assessment had concluded on the adequacy of the control and audit arrangements proposed 
by Sweden (Rating of A) under criterion 2.10 of Annex V to the RRF Regulation, subject to the timely 
fulfilment  of  the  milestones  pertaining  to  the  organisation  of  the  system  and  the  treatment  of  data  and 
organisation of audits. The additional assurances referred to in the annex to the initial Council Implementing 
Decision  –  namely  a  Government  decision  ensuring  an  effective  and  efficient  implementation  of  the 
Recovery  and  Resilience  Plan  through  establishing  the  relevant  legal  mandates  or  assignments  to  the 
authorities involved in the coordination, monitoring, control and audit of the implementation – are to be 
provided as part of Sweden’s first payment request. 

The modifications to the original plan and the introduction of the REPowerEU chapter as such do not affect 
the original assessment. However, in the context of the modification of the Swedish RRP, its audit and 
control system needs to be reassessed on the basis of criteria 2.10 of Annex V of the RRF Regulation. Since 
the original assessment, the Commission has had access to information on its actual implementation. This 
includes the preliminary findings of the audit on the protection of the financial interests of the Union (PFIU) 
performed by the Commission in Sweden. 

In light of this information, the Commission considers that the internal control system of the Swedish RRP 
is overall adequate, but it has some deficiencies that must be addressed through a strengthening of the audit 
and control milestone. This relates to a weakness in the procedures on: (i) conflict of interest, (ii) double 
funding, (iii) detecting fraud and corruption and (iv) collecting data.  

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the adequacy of the control 
and audit arrangements proposed by Sweden, as reflected in the previous Staff Working Document 
SWD(2022) 102 final. 

3.11. 

Coherence 

The modifications to the RRP display coherence within each component and show thematic 
interlinkages and synergies between the different components, in particular those related to 
the green transition and the newly added REPowerEU chapter. The reform in the REPowerEU 
chapter improved the coherence of the modified RRP by reinforcing the original measures in the 
original  RRP  like  the  climate  and  industry  leap.  In  addition,  scaling  up  investments  in  energy 

12 

 
 
efficiency of multi-dwelling buildings and rental and student housing furthers the coherence as 
these measures had links with other measures through the digital transition and addressing social 
cohesion. The modified recovery and resilience plan includes measures that are complementary 
with one another. This concerns the components related to green transition, sustainable transport 
and the new REPowerEU chapter. The modifications do not have contradictory aims or possible 
negative effects on one another. 

*** 

The nature and extent of the proposed modifications to Sweden’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the coherence of the actions 
proposed by Sweden, as reflected in the previous Staff Working Document SWD(2022) 102 final. 

3.12. 

REPowerEU 

The REPowerEU chapter contains measures to help address the key energy challenges that 
Sweden  currently  faces.  The  proposed  measures  contain  a  reform  to  shorten  the  permitting 
process  for  electricity  grid  construction,  an  investment  in  energy  efficiency  in  multi-dwelling 
buildings and an investment subsidy for rental and student housing. These last two measures were 
part of the original RRP. The measures included in the REPowerEU chapter address four out of 
the six  objectives pursued by the Regulation.  The implementation  of the  proposed measures is 
expected to effectively promote energy efficiency in buildings and critical infrastructure, tackle 
energy poverty, create incentives to reduce energy demand as well as address internal and cross-
border bottlenecks in energy transmission and distribution. 

Reform 6.3 will ease the authorization procedure for expanding the electricity grid. This will help 
Sweden  in  reducing  its  dependence  on  fossil  fuels  by  allowing  further  electrification  of  the 
economy. Electricity is already a relatively important energy source in Sweden when compared to 
other Member States. Its electricity is produced almost completely fossil-free and more than half 
is produced by renewable sources. The major challenge for Sweden to move to carbon-neutrality 
is  to  make  the  transport  sector  fossil-free  (see  Country  Report  Sweden  2020  by  the  European 
Commission4). Increased electricity needs imply higher demands on grid capacity which will need 
to be met by expanding grid capacity (see Sweden Country Report 20225). Activities under reform 
6.3  contribute  to  the  REPowerEU  objective  to  reduce  internal  and  cross-border  energy 
transmission  and  distribution  bottlenecks.  Reform  6.3  will  have  a  lasting  impact  as  the  easier 
authorisation procedure will immediately allow for new permit requests, expand the grid capacity 
and the faster procedure will not easily be reversed as it responds to a generally-supported need in 
Sweden’s electrification strategy. Reform 6.3 is coherent with other efforts of the Member State. 
In particular, there is synergy with measures in component 1 (Green Recovery). 

Investment 6.1 will strengthen the investments in energy-efficiency in multi-dwelling buildings. 
A more efficient use of energy in multi-dwelling buildings directly contributes to the REPowerEU 

4 2020 European Semester: Country Reports (europa.eu) 
5 2022 European Semester: Country Reports (europa.eu) 

13 

 
 
 
 
objective  of  increasing  energy  efficiency  in  the  wider  economy.  Housing-related  energy 
consumption from households was larger than transport in 2022, according to the Swedish System 
of Environmental and Economic Accounts. The reduction in energy demand also has multi-country 
effect in that the total energy demand in the EU is reduced. Activities under reform 6.1 will, thus, 
contribute to the REPowerEU objective of increasing energy efficiency in buildings with a cross-
border and multi-country dimension as defined by REPowerEU.  Investment 6.1 will have a lasting 
impact  because  the  energy-efficiency  improvements  have  a  longer-term  investment  horizon. 
Investment 6.1 is coherent with other efforts by the Member State and with other measures in the 
amended RRP, in particular the measures in component 1 “Green Recovery”. 

Investment 6.2 will enhance the investment subsidy for rental and student housing. Sweden has a 
persistent  housing  need,  also  for  rental  and  student  housing.  The  mismatch  between  supply  of 
housing and housing demand fosters imbalances in the housing market and in household debt that 
have macroeconomic implications. Students without wealthy sponsors or substantial income have 
to rely on the affordable rental accommodation but are placed on a waiting list. The waiting times 
can  run  into  several  years.  Higher  energy  efficiency  of  the  accommodation  than  the  current 
building regulation prescribes is expected to lower energy costs and, hence, living costs. With the 
requirements set in such a way that the target group – lower income, less access to the housing 
market – chances increase that the lower income group stands to benefit most. Activities under 
investment 6.2 will, thus, contribute to the REPowerEU objectives of increasing energy efficiency 
in buildings and to reduce energy poverty. The lifetime of the new buildings will secure that the 
measure has a lasting impact. Investment 6.1 is coherent with other efforts by the Member State 
and with other measures in the amended RRP, in particular measures in component 5 “Investment 
for growth and housing” and component 1 “Green recovery”. 

*** 

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

3.13. 

Cross-border or multi-country dimension or effect  

All  three  measures  in  the  REPowerEU  chapter  have  a  cross-country  or  multi-country 
dimension or effect. Whereas the reform will facilitate also new or improved cross-border grid 
capacity, the two investments contribute through their reduction in energy demand.  As a result, 
they contribute to reducing the dependency on fossil fuels and secure energy supply in the Union 

14 

 
 
as a whole and can therefore be considered as having a positive cross-border effect as established 
in the Commission’s guidance in the context of REPowerEU6. 

REPowerEU measure with cross-border or multi-
country dimension or effect 

Costs 
million) 

(EUR 

Energy efficiency in multi-dwelling buildings 
Rental and student housing 

164 
119 

TOTAL 

Contribution  to  the 
target  in  %  of  the 
REPowerEU  chapter 
estimated costs 

58% 
42% 

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/moderate extent, to have a cross-
border or multi-country dimension or effect. This would warrant a rating of A/B under criterion 
2.13 of Annex V to the RRF Regulation. 

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

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX I: CLIMATE TRACKING AND DIGITAL TAGGING  

Climate 

Digital 

(Sub-)Measure ID 

(Sub-)Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

1.1.1 

1.1.2 

1.1.3 

1.1.4 

1.1.5 

1.1.6 

1.1.7 

1.2.1 

1.2.1 

1.3 

1.4 

1.9 

2.3 

Local and regional climate 
investment – Conversion to 
renewable energy including 
bioenergy for heating in 
industry and agriculture 
Local and regional climate 
investment – Production of 
biogas and biofuels 
Local and regional climate 
investment – Transport 
(renewable fuel and refuelling 
points) 
Local and regional climate 
investment – Waste (including 
plastic recycling) 
Local and regional climate 
investment – Increased 
efficiency 
Local and regional climate 
investment – Charging stations 
for electric cars 
Local and regional climate 
investment – Infrastructure 
Climate investment in the 
industrial sector focusing on 
low carbon economy, 
resilience and adaptation to 
climate change 
Climate investment in the 
industrial sector focusing on 
circular economy  
Energy efficiency in apartment 
buildings 
Strengthened railway support 
Formal protection of forests 
with high natural values for 
biodiversity 
More study places in higher 
vocational education 

16 

229 

030bis 

100% 

194 

030bis 

100% 

140 

077 

100% 

89 

045bis 

100% 

68 

024ter 

100% 

58 

34 

077 

100% 

077 

100% 

244 

022 

100% 

43 

60 

78 

023 

40% 

025 

40% 

033 

40% 

069bis 

100% 

247 

050 

40% 

104 

016 

40% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Sub-)Measure ID 

(Sub-)Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

2.4 

4.1 

4.2 

5.1 

Resources to meet demands 
for education at universities 
and other higher education 
institutions 
Joint public administration 
digital infrastructure 
Broadband expansion 
Investment support for rental 
housing and housing for 
students 

308 

21 

464 

016 

40% 

011 

051 

100% 

100% 

296 

025ter 

40% 

REPowerEU Chapter 

6.1 

6.2 

Scale-up: Energy efficiency in 
multi-dwelling buildings 
Scale-up: Investment aid for 
rental and student housing 

164 

025 

40% 

033 

40% 

119 

025ter 

40% 

Note: While the total cost of the Swedish recovery and resilience plan exceeds the total allocation of non-repayable 
financial support to Sweden, Sweden will ensure that all spending related to the measures mentioned in this table as 
contributing to climate objectives are fully financed by the funds from the Recovery and Resilience Facility.] 

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 of the RRF Regulation 

17