COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Austria Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10159/21; ST 10159/21 ADD 1; ST 10159/21 COR 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Austria
Date: 2023-10-19
Institutions: European Commission, Secretariat-General
Subjects: Austria, EU aid, 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) 344 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Austria Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10159/21; ST 10159/21 ADD 1; ST 10159/21 COR 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Austria {COM(2023) 674 final}  
 
 
Table of contents 
1. 

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

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

3. 

Summary of the assessment of the plan .............................................................................................. 8 

3.1. 

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

3.2. 

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

3.3.  Growth potential, job creation, economic, institutional and social resilience, European Pillar of 
Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence ...... 13 

3.4. 

The principle of ‘do no significant harm’ .................................................................................... 13 

3.5.  Green transition .......................................................................................................................... 14 

3.6. 

Digital transition .......................................................................................................................... 15 

3.7. 

Lasting impact of the plan ........................................................................................................... 16 

3.8.  Milestones, targets, monitoring and implementation................................................................ 16 

3.9. 

Costing ........................................................................................................................................ 17 

3.10.  Controls and audit ....................................................................................................................... 18 

3.11.  Coherence ................................................................................................................................... 20 

3.12.  REPowerEU ................................................................................................................................. 21 

3.13.  Cross-border or multi-country dimension or effect ................................................................... 23 

ANNEX I: Climate tracking and digital tagging ........................................................................................ 25 

1 

 
 
 
 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

The Austrian economy has recovered strongly  from the COVID-19 pandemic, but is  now 
facing headwinds. In 2022, Russia’s war of aggression against Ukraine and subsequent spikes 
in energy prices fueled inflation and suppressed growth. In light of these challenges, Austria 
submitted  to  the  Commission  a  modified  recovery  and  resilience  plan  (RRP)  including  a 
REPowerEU chapter on 14 July 2023. For the requested modifications of its RRP, Austria has 
relied  on  the  following  legal  bases:  Article  21(1)  of  Regulation  (EU)  2021/241  (the  “RRF 
Regulation”) requesting the Commission to make a proposal to amend the Council implementing 
decision  considering  that  its  RRP  is  partially  no  longer  achievable  because  of  objective 
circumstances  and  Article  21c  requesting  the  allocation  of  the  amount  available  from  the 
Emissions  Trading  System  (ETS)  revenues  for  the  REPowerEU  chapter.  The  modifications 
submitted by Austria under Article 21(1) affect 14 measures of the initial plan.  

The REPowerEU chapter submitted by Austria contains measures to help address the key 
energy challenges  that  Austria  is  currently facing. The four  proposed  measures  contain  two 
new reforms, one new investment as well as one scaled-up investment as follows: 

•  Reform 5.A.1 (Acceleration of permitting procedures for renewables) amends the 
national environmental impact assessment law, streamlining permitting procedures 
for renewable energy projects, in particular wind farms.  

• 

•  Reform  5.A.2  (Hydrogen  as  key  technology  to  climate  neutrality)  concerns  the 
national Hydrogen Strategy. The Hydrogen Strategy provides for a new policy and 
regulatory framework aimed at ramping up the production and use of hydrogen in 
Austria, setting a clear focus on renewable hydrogen and specific measures to be 
implemented. 
Investment 5.B.1 (Photovoltaic systems) is a subsidy scheme for private individuals 
and non-profit organisations supporting the installation and expansion of “rooftop” 
photovoltaic and electricity storage systems.  
Investment 5.B.2 (Scaled-up measure: Funding zero-emission commercial vehicles 
and infrastructure) scales up investment 1.B.4 (Zero-emission utility vehicles) of 
the initial plan and concerns a new funding scheme that targets heavy-duty zero-
emission commercial vehicles and related charging infrastructure, supporting the 
reduction of emissions in road transport.  

• 

The  outlined  measures  contribute  to  the  REPowerEU  objectives  of  increasing  the  share  and 
accelerating  the  deployment  of  renewable  energy,  of  increasing  the  production  of  renewable 
hydrogen and the uptake of hydrogen in hard-to-decarbonise sectors, of accelerating the integration 
of  renewable  energy  sources,  and  of  supporting  zero-emission  transport  and  its  infrastructure. 
Overall,  the  implementation  of  the  envisaged  measures  is  expected  to  contribute  to  reducing 
dependency on fossil fuels in line with the country-specific recommendation on energy (CSR 4 in 
2022 and 2023). The new measures in the REPowerEU chapter have a cross-border effect that is 
described further below. 

2 

 
 
 
 
 
Based on the assessment of the submitted modification and  the REPowerEU  chapter,  the 
Austrian  modified  plan  receives  an  A-rating  on  all  criteria  (including  the  two  additional 
criteria for the REPowerEU chapter), 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 (56%) 

A (36%) 

A 

A 

B 

A 

A 

A 

A 

2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

The modification to the Austrian RRP comes in response to the challenges that emerged since the 
original plan was formulated. In particular, Russia’s actions following its full-scale invasion of 
Ukraine on 24 February 2022 led to a surge in energy and commodity prices as well as overall 
inflation in Austria and the EU as a whole. Shortages of workers across skill levels and global 
supply chain disruptions compounded challenges to the implementation of the original plan. In the 
context of Austria’s current challenges, the proposed revision of its RRP is twofold: including a 
new REPowerEU chapter to the original plan and modifying existing measures in line with the 
provisions of the RRF Regulation. 

The Austrian modified RRP adds a new REPowerEU chapter pursuant to Article 21c of the 
RRF  Regulation.  To  deliver  on  the  REPowerEU  objectives,  it  includes  two  new  reforms  (on 
accelerating permitting procedures for renewables and on promoting hydrogen as a technology key 
to  climate  neutrality),  one  new  investment  (photovoltaic  systems)  as  well  as  a  scale-up  of  one 
existing investment related to zero-emission commercial vehicles. The REPowerEU chapter will 
further  support  Austria’s  green  transition  and  help  address  the  current  challenges,  in  particular 
those  identified  and  recommended  in  the  field  of  energy  to  Austria  in  2022  and  2023  in  the 
framework of the European Semester.  

Pursuant to Article 21(1) of the RRF Regulation, based on objective circumstances Austria 
requested  to  modify  existing  measures  of  the  plan  considering  that  they  were  no  longer 
achievable. These modifications address the need to factor in the high inflation experienced in 
2022 and supply chain disruptions. Austria proposed to modify four measures because they would 
otherwise not be achievable within the original timeline. Austria proposed to modify two measures 
in order to implement better alternatives to achieve their original ambition. Austria proposed to 
modify four measures due to increased construction costs, high inflation or disruption of supply 
chains.  Austria  proposed  to  modify  three  measures  due  to  lack  of  demand  from  potential  final 
recipients.  Furthermore,  Austria  proposed  to  modify  one  measure  due  to  delays  in  public 
procurement and one measure due to the effects of influx of refugees from Ukraine.  

3 

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

Component 1 (Sustainable Recovery) 

Austria proposed to modify ten milestones and targets in five measures on the basis of Article 21 
of the RRF Regulation.  

First, the achievement of the intermediary and final targets 4 and 5 related to the investment in 
exchange of oil and gas heating systems (1.A.2), originally planned for Q4 2023 and Q2 2026, has 
been frontloaded and the two targets have been merged to reflect the faster-than-expected progress 
in the implementation of the investment.  

Second, the description of the investment aimed at combating energy poverty (1.A.3) as well as 
its targets  7  and 8  have  been  amended  in  order  to support  Non-Profit  Organisations’  buildings 
sheltering vulnerable people instead of private family houses. This allows Austria to pursue a more 
effective measure to reach the desired policy objective, by exclusively targeting people at risk of 
energy poverty and more in need of protection.  

Third,  targets  15  and  16  capturing  the  investment  in  zero-emission  buses  (1.B.3)  have  been 
decreased  to  adjust  for  higher-than-estimated  costs,  by  proportionally  reducing  the  number  of 
buses and charging infrastructure granted to the final recipients. 

Austria  also  proposed  to  modify  targets  related  to  the  reform  of  the  renewable  expansion  law 
(1.D.1)  to  adjust  for  disruptions  in  supply  chains.  As  a  result,  a  110  MW  reduction  in  new 
renewable hydrogen production capacity in target 40 has been compensated by a 200 MW increase 
in additional generation capacity from renewable energy sources in target 39, while also slightly 
adjusting the timeline to account for the time needed to collect the data.  

Due  to  supply  chain  disruptions,  the  new  energy  policy  context  and  uncertainty  triggered  by 
Russia’s  war  of  aggression  against  Ukraine,  Austria  proposed  to  modify  the  investment  in 
transforming  industry  towards  climate  neutrality  (1.D.2).  The  modified  measure  focuses  on 
accelerating the decarbonisation of industry, switching to renewable energies, energy efficiency 
as well as other actions leading to a reduction in greenhouse gas emissions. Resource efficiency as 
well  as  hazardous  waste  treatment  are  removed  as  an  explicit  objective  from  the  measure 
description. It also adapts the intermediary target 42 from completion of projects to approval for 
funding, while keeping the final target 43 unchanged.  

Component 2 (Digital Recovery) 

Austria proposed to modify eleven milestones and targets in five measures on the basis of Article 
21 of the RRF Regulation.  

First, Austria proposed to amend targets 46, 47 and 48 of the investment into the deployment of 
the Gigabit-capable networks (2.A.2), turning the first two targets into milestones and reducing 
the number of households in the final target, since the original one was no longer achievable in 
full in the context of increased costs.  

4 

 
 
 
 
 
Second,  targets  54  and  55  of  the  investment  into  digital  devices  for  pupils  (2.B.2)  have  been 
amended, merged  and postponed  to  take into account  delays in public procurement.   The final 
target for the digital devices remains the same.  

Third, milestone 60 regarding the selection of projects under the Digitalisation Fund for public 
administration (investment 2.C.2) has been amended and expressed in terms of number of selected 
projects  to  reflect  the  lack  of  demand,  since  the  submitted  project  proposals  involved  a  lower 
amount of funds than specified in the original milestone.  

Fourth, the achievement of the intermediary and final targets 66 and 67 concerning the investment 
in support to companies for their digital investments (2.D.2), originally planned for Q1 2023 and 
Q1 2025, has been frontloaded and these two targets have been merged to reflect the faster-than-
expected progress in the implementation of the investment.  

Finally, Austria proposed to modify targets 70, 71 and 72, tracking green investment by enterprises 
(2.D.3) to address higher construction costs and a subsequent lack of demand for funding under 
the national investment premium scheme. The reduction of targets 70 and 72 with regard to the 
number of companies supported by investments in thermal renovation and in energy savings has 
been proportionately compensated by an increase in target 71 on investments in solar energy and 
electricity storage. 

Component 3 (Knowledge Based Recovery) 

Austria proposed to modify six milestones and targets in four measures on the basis of Article 21 
of the RRF Regulation.  

First, target 89 concerning the re-skilling and up-skilling of unemployed people (3.B.2.) has been 
achieved earlier than its indicative timeline of Q4 2024 and can therefore be frontloaded to Q4 
2022.  

Second and third, target 90 regarding pupils eligible for promotion from 5th school year and target 
91 on pupils from migration background having achieved secondary level II degree (3.C.1) are no 
longer  achievable  in  the  given  implementation  timeline  due  to  the  influx  of  displaced  people 
provoked by Russia’s war of aggression against Ukraine. Target 90 is replaced by new milestones 
90a and 90b aiming at fully implementing the national standardised assessments of the “Individual 
Competence Assessment PLUS” (iKMPLUS) and its extension with additional modules so that 
pupils have access to a standardised assessment providing them with feedback on their learning 
progress.  Target  91  is  replaced  by  the  new  milestone  91a  on  establishing  criteria  for  the 
specification  of  the  socio-economic  baseline  of  schools  which  is  based  on  the  socio-economic 
background  of  pupils  and  includes  having  a  migration  background  by  pupils,  and  guiding  the 
allocation of human resources to schools. The new milestones replacing targets 90 and 91 support 
the initial objective.  

Fourth and fifth, Austria proposed to postpone the implementation of target 95 on the increase in 
childcare quota for under 3-year-olds as well as of target 96 on the increase in offer of places in 
early childhood education institutions for children aged three to six years (3.C.3) by two years due 
to labour shortages, changes in working patterns of parents as well as to temporary closures of 

5 

 
 
 
 
 
kindergartens linked to the impact of the COVID-19 crisis as well as to remove the reference to 1 
percentage point increase per Land per year to focus the efforts on those Länder which are lagging 
behind in target 95.  

Finally, for the investment under the IPCEI Hydrogen (3.D.2), Austria proposed to replace target 
103 by targets 103a and 103b, in order to reflect the stage the IPCEI projects would reach and the 
increased investment uncertainties and disruptions in supply chains. Target 103a ensures that the 
available funding will have been fully committed for the approved projects, while the final target 
103b requires that all approved projects will have entered the first-industrial-deployment phase. 

Component 4 (Just Recovery) 

Austria proposed to modify ten milestones and targets in three measures on the basis of Article 21 
of the RRF Regulation.  

First,  regarding  the  investment  concerning  funding  of  primary  health  care  projects (4.A.2),  the 
number of ‘new’ primary health care projects was lowered in each of the three associated targets 
(targets 108, 109 and 110) due to an increase in  construction cost and resulting uncertainty for 
project owners.  

Second, the number of projects under the investment in climate-friendly town centres (4.B.3) is 
substantially  adjusted,  with  targets  123,  126  and  127  lowered,  and  targets  124,  125  and  128 
removed due to lack of demand in the funding scheme by municipalities. 

Third,  milestone  138  under 
the  Renovation  of 
Volkskundemuseum Wien and Prater Ateliers (4.C.3) was postponed by one year given an increase 
in construction costs.  

the  completion  of 

the  measure  on 

Component 5 (REPowerEU) 

Under the REPowerEU chapter and based on Article 21c of the RRF Regulation, Austria proposed 
measures amounting to EUR 210.3 million in total estimated costs for one new investment and a 
scale-up of an existing investment as well as two additional reforms that are not associated with 
any costs under the RRP. 

New reforms: 

•  Acceleration of permitting procedures for renewables (5.A.1) 

The  reform  of  the  national  environmental  impact  assessment  law  aims  at  streamlining  the 
permitting  process  and  thus  at  facilitating  the  implementation  of  renewable  energy  projects  in 
Austria. It introduces several key procedural simplifications, it deems investments in renewable 
energy as projects of particularly high public interest, it reduces the length of appeals and increases 
the use of electronic tools.  

•  Hydrogen as key technology to climate neutrality (5.A.2) 

The national  Hydrogen  Strategy provides for a  new policy and  regulatory framework  aimed at 
ramping  up  the  production  and  use  of  renewable  hydrogen  and  contributes  to  developing 
hydrogen-ready infrastructure in Austria, with a view to also enabling future hydrogen imports. It 

6 

 
 
 
 
 
outlines specific actions and measures to be adopted in eight policy areas and sets the objective to 
install 1 GW electrolyser capacity by 2030. 

New investment: 

•  Photovoltaic systems (5.B.1) 

The  subsidy  scheme  supports  investments  in  photovoltaic  systems  on  buildings  and  electricity 
storage. It aims to accelerate the expansion of renewable energy, and thus contributes to reducing 
greenhouse  gas  emissions.  It  helps  meeting  the  high  demand  for  support  in  the  segment  and 
promotes energy independence by targeting small-capacity plants. The investment also contributes 
to  other  environmental  objectives  by  supporting  installations  exclusively  on  buildings  to  avoid 
land use and by relying on equipment and components with high durability and recyclability. 

Scaled-up investment: 

•  Funding zero-emission commercial vehicles and infrastructure (5.B.2) 

The funding scheme supports investments in heavy-duty zero-emission commercial vehicles and 
charging infrastructure. It represents a scale-up of the existing investment in zero-emission light 
commercial vehicles (1.B.4), effectively increasing the level of its ambition. The investment aims 
to contribute to decarbonising the road transport, the sector in which it is most difficult to abate 
greenhouse gas emissions in Austria.  

Table of new and modified components and associated costs: 

Component 
1: Sustainable Recovery 
2: Digital Recovery 
3: Knowledge based Recovery 
4: Just Recovery 
5: REPowerEU 

Status 
Modified 
Modified 
Modified 
Modified 
New 

Costs (EUR million) 

1 507.525 
1 339.884 
868.320 
261.379 
210.305 

Other elements not covered by assessment criteria  

The  description  of  aspects  related  to  administrative  organisation,  gender  equality  and  equal 
opportunities for all, consultation process, security self-assessment for digital investments and the 
planned communication strategy as reflected in the previous Staff Working Document (2021) 160 
final remains relevant.  

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 

7 

 
 
 
 
 
 
 
(GBER) declaring certain categories of aid compatible with the internal market in application of 
Articles 107 and 108 TFEU1. When State aid is present and it requires notification, it is the duty 
of  the  Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance with Article 108(3) TFEU. In this respect, the State aid analysis carried out by Austria 
in the recovery and resilience plan cannot be deemed a State aid notification. In as far as Austria 
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 Austria 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 modified RRP including the REPowerEU chapter 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 Austrian plans’ components toward the six pillars is summarised 
in the Table below. All pillars are covered by at least one component, while a component may 
contribute to several pillars. 

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

Green 
transition 

Digital 
transforma-
tion 

Smart, 
sustainable & 
inclusive 
growth 

Social and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutional 
resilience 

Po 
licies for 
the next 
genera-
tion 

Component 1 Sustainable recovery 

● 
● 
● 

1.A Renovation wave 
1.B Eco-friendly mobility 
1.C Biodiversity and 
circular economy 
1.D Transformation 
towards climate 
neutrality 
Component 2 Digital recovery 

● 

● 

● 
● 

● 

1 Annex to the Communication to the Commission of 9 March 2023 on the Approval of the content of a draft for a 
Commission Regulation amending Regulation (EU) No 651/2014 declaring certain categories of aid compatible with 
the internal market in application  of Articles 107 and 108 of  the Treaty and Regulation (EU)  2022/2473 declaring 
certain categories of aid to undertakings active in the production, processing and marketing of fishery and aquaculture 
products  compatible  with  the  internal  market  in  application  of  Articles  107  and  108  of  the  Treaty;  available  at: 
https://competition-policy.ec.europa.eu/system/files/2023-
03/GBER_amendment_2023_EC_communication_annex_0.pdf 

8 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Green 
transition 

Digital 
transforma-
tion 

Smart, 
sustainable & 
inclusive 
growth 

Social and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutional 
resilience 

Po 
licies for 
the next 
genera-
tion 

● 

● 

● 

● 
● 

2.A Broadband expansion 
2.B Digitalisation of 
schools 
2.C Digitalisation of the 
public administration 
2.D Digital and ecological 
transformation of 
enterprises 
Component 3 Knowledge-based recovery 
● 
3.A Research 
● 
3.B Re-skilling and up-
skilling 
3.C Education 
3.D Strategic innovation 
Component 4 Just recovery 
4.A Health care 
4.B Resilient 
municipalities 
4.C Art and culture 
4.D Resilience through 
reforms 
Component 5 REPowerEU 
5.A Reforms 
5.B Investments 

● 
● 

● 
● 

● 
● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 
● 

● 
● 

● 
● 

● 

● 

● 
● 

● 

● 
● 

 ● 
 ● 

Green transition 

Austria’s modified plan - including the REPowerEU chapter - focuses significantly on supporting 
the green transition, with 9 sub-components dedicated to this pillar. Modifications of measures 
slightly affected the contribution of the revised plan to this pillar. It now stands at 56%, still well 
above the minimum threshold of 37%. 

The REPowerEU chapter includes reforms and investments that will help Austria to (i) increase 
the  share  and  accelerate  the  deployment  of  renewable  energy,  (ii)  ramp  up  the  production  of 
renewable  hydrogen  and  the  uptake  of  hydrogen  in  sectors  which  are  otherwise  difficult  to 
decarbonise, (iii) expand and accelerate the integration of renewable energy sources in its energy 
system as well as (iv) support zero-emission transport and its infrastructure. In addition, some of 
the REPowerEU measures also support other environmental objectives, for instance, by limiting 
land use and by relying on solar energy equipment that is easy to dismantle and to refurbish. 

Digital transformation  

9 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
 
 
 
 
  
 
 
  
 
The  digital  transformation  still  represents  a  significant  part  of  Austria’s  modified  plan.  The 
modified RRP continues to significantly contribute to promoting digital transformation in a variety 
of  areas,  including  connectivity,  public  administration  and  public  services,  private  sector, 
education, research and innovation, health, and culture. Modifications of measures have reduced 
the contribution of the modified plan to this pillar. The main impact of the revision concerns the 
investment into the deployment of the Gigabit-capable networks (2.A.2) and investment into the 
Digitalisation Fund for public administration (2.C.2), with a decrease in the contribution to the 
digital target of EUR 488 million. However, the digital contribution of the modified plan remains 
well-above the minimum threshold of 20% (i.e., 36%), testifying to the important contribution the 
implementation of the RRP will provide to the digital transformation. 

Policies for the next generation  

The sixth pillar remains covered by the measures and investments proposed mainly under  sub-
components 2.B, 3.B, 3.C, 4.A and 4.D. The main impact of the revision is that some targets are 
replaced with new milestones either because the original target is no longer achievable within the 
indicative timeline or due to the influx of displaced Ukrainian people. These concern measures on 
the  provision  of  digital  devices  to  pupils  (2.B.2),  improving  access  to  education  (3.C.1.)  and 
expansion of elementary education (3.C.3). Modifications of these measures did not change the 
contribution of the modified plan to this pillar. 

*** 

Taking into consideration all reforms and investments envisaged by Austria, 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 Austria 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 all, or a significant subset, of the challenges 
identified in the relevant country-specific recommendations (CSRs). As the maximum financial 
contribution for Austria has been adjusted upwards, all 2022 and 2023 structural recommendations 
are considered in the overall assessment. 

In the modified plan, the changes in the measure ‘Combating energy poverty’ (1.A.3) redesigned 
the target and the nature of the recipient pool. However, the new measure ensures that the final 
recipients are the most vulnerable. Moreover, the overall goal of component 1.A. of promoting the 
green  transition,  including  through  the  transition  to  more  sustainable  heating  (CSRs  2019.3.3, 
2020.3.7., 2022.4.3., 2023.4.4.), remains sufficiently addressed through the front-loading of two 
targets on the exchange of oil and gas heating systems (1.A.2.). The modification of investment 
1.B.3. (Zero-emission buses), which reduces the number of buses received by the final recipients 

10 

 
 
 
 
 
 
due to cost increases, is counterbalanced by an additional project on zero-emission commercial 
vehicles under the REPowerEU chapter, thereby  preserving the initial  ambition and effectively 
contributing to CSRs 2019.3.3. and 2020.3.6. Similarly, the reduction of the target on installation 
of  renewable  hydrogen  production  capacity  (target  40,  reform  1.D.1.  (Renewables  Expansion 
Law)) is compensated by the increase in the target on additional capacity from renewable sources 
(target 39), thereby preserving the overall ambition on expanding renewable energy production 
(CSRs  2019.3.3.,  2020.3.7.,  2022.4.1.,  2022.4.2.,  2023.4.1.,  2023.4.2.  and  2023.4.3.). 
Modifications and delays  concerning investment  1.D.2 (Transforming industry towards climate 
neutrality) reflect the prioritisation of dealing with the current energy crisis provoked by Russia’s 
war of aggression against Ukraine, thereby better targeting the most recent set of energy CSRs 
(2022.4.1., 2022.4.2., 2023.4.1., 2023.4.2. and 2023.4.3.), while preserving the initial ambition of 
the targets.  

With regard to addressing investments in the digital transition and CSRs 2019.3.2., 2020.3.5. and 
2020.2.2.,  the  modifications  of  investment  2.A.2.  (Widespread  availability  of  Gigabit  capable 
access networks and creation of new symmetric Gigabit connections) concerning the amendment 
of the targets on the number of households with access to broadband, preserve the ambition to 
address the digital transition since the amount of investment in the digital transition in the Austrian 
RRP  (which  is  well  above  the  20%  target)  remains  comparatively  high.  When  it  comes  to 
investment  2.D.3  (Green  investments  in  enterprises),  the  reduced  targets  for  the  number  of 
companies that have been granted support for energy savings (target 72) and thermal renovation 
(target 70) will be offset by the increased target 71 for companies that have been granted support 
for solar energy and electricity storage, thereby preserving the ambition of the plan vis-à-vis CSRs 
related to investment in the green transition (CSRs 2019.3.3., 2020.3.7., 2022.4.1., 2022.4.2. and 
2023.4.3.). 

Furthermore, the modified plan preserves the ambition on improved access to education and basic 
skills (CSRs 2019.2.4., 2020.2.1., 2020.2.2., 2023.3.2.) through replacing the target of pupils that 
have been promoted to the next grade or completed a school type, as well as the target of pupils 
from  migration  background  having  achieved  secondary  level  II  degree  under  reform  3.C.1 
(Improved access to education) with three new milestones improving the quality and accessibility 
of school  education in Austria. Regarding the modifications of targets related to increasing the 
quota of Austrian children in early childhood care towards the Barcelona target of 33% (investment 
3.C.3.  related  to  CSRs  2019.2.2.,  2019.2.3.,  2020.2.1.,  2020.2.2.,  2022.3.1.,  2023.3.1.),  the 
postponement of the targets does not reduce the overall ambition of the plan in addressing these 
challenges, in particular due to the fact that some regions in Austria have already overachieved the 
Barcelona target. Similarly, the modifications with regard to investment 3.D.2 (IPCEI hydrogen) 
does not reduce the overall ambition of the plan to increase the production and use of renewable 
energy  in  Austria  and  to  reduce  reliance  on  fossil  fuels  (CSRs  2019.3.1.,  2019.3.3.,  2020.3.5., 
2020.3.7., 2022.4.2., 2023.4.3.) and is also compensated by frontloading other milestones related 
to renewables expansion.  

On health and long-term care, the plan continues to help address some of the challenges identified 
regarding  the  adequacy  and  fiscal  sustainability  of  the  long-term  care  system  and  the  fiscal 

11 

 
 
 
 
 
sustainability  of  the  health  care  system  (2019.1.1.,  2020.1.2.,  2023.1.2.).  Investment  4.A.2 
concerning  funding  of  primary  health  care  projects was  adjusted  to  include  a  lower  number  of 
‘new’ primary health care projects due to the objective circumstance of increased construction cost 
and resulting uncertainty for project owners. While this lower availability of primary care services 
may  diminish  the  impact  of  the  measure  to  promote  primary  health  care  projects,  the  broader 
impact  of  the  subcomponent  4A  on  health  is  safeguarded  both  in  maintaining  the  number  of 
existing projects less affected by construction cost as well as the other measures included, notably 
the reform to promote primary health care projects (4.A.1). Concerning the modification of the 
targets under investment 4.B.3. (Climate-friendly town centres), Austria upgraded and simplified 
a national  funding  scheme due to  the urgency related to  the Russian war of aggression against 
Ukraine. Given the significant success of the national scheme, the original ambition of the measure 
in  the  plan  and  the  CSRs  related  to  reducing  greenhouse  gas  emissions  (2019.3.3,  2020.3.7.) 
remains intact.  

The addition of the REPowerEU chapter will contribute to reinforcing the ambition of the plan as 
regards  the  relevant  CSRs  related  to  the  energy  transition.  Notably,  efforts  to  accelerate  the 
expansion of renewable energy and reducing reliance on fossil fuels (CSRs 2019.3.3., 2020.3.7., 
2022.4.1.,  2022.4.2.,  2023.4.1.,  2023.4.2.  and  2023.4.3.)  include  the  reform  of  the  national 
environmental impact assessment law (reform 5.A.1), aimed at streamlining the permitting process 
and  thus  facilitating  the implementation  of  renewable  energy  projects.  The  investment  into  the 
subsidy scheme for installing and expanding “rooftop” photovoltaic systems (investment 5.B.1), 
incentivising  the  uptake  of  solar  energy,  are  expected  to  also  contribute  to  the  expansion  of 
renewable energy and investment in the green transition (CSRs 2019.3.3., 2020.3.7., 2022.4.2., 
2023.4.3.). Similarly, the national Hydrogen Strategy (reform 5.A.2) will contribute to increasing 
the  production  of  renewable  energy  in  Austria  and  reducing  reliance  on  fossil  fuels  (CSRs 
2019.3.1., 2019.3.3., 2020.3.5., 2020.3.7., 2022.4.2., 2023.4.1., 2023.4.2. and 2023.4.3.). Lastly, 
the funding scheme for heavy-duty zero-emission commercial vehicles and charging infrastructure 
(investment 5.B.2), aimed at reducing emissions in the road transport, will effectively address a 
number of challenges related to investment in the green transition and sustainable mobility as well 
as the reduction of emissions in the transport sector (CSRs 2019.3.3., 2020.3.6.). 

*** 

Taking into consideration the reforms and investments envisaged by Austria, 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 Austria. This would warrant a rating of A under criterion 2.2 in Annex V to the RRF Regulation. 

12 

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

*** 

The nature and extent of the proposed modifications to the Austrian RRP do not have an 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  assessment (rating of A) of the plan and detailed in the 
previous SWD (2021) 160 final under criterion 2.3 of Annex V to the RRF Regulation.  

3.4. The principle of ‘do no significant harm’  

In accordance with Article 19(3), point (d), of and Annex V, criterion 2.4, to the RRF Regulation 
the modified RRP including the REPowerEU chapter is expected to ensure that the measures for 
the implementation of reforms and investments projects included in this RRP do no significant 
harm to environmental objectives (Rating A) within the meaning of Article 17 of Regulation (EU) 
2020/852 (hereinafter the “Taxonomy Regulation”) of the European Parliament and of the Council 
5 (the principle of ‘do no significant harm’).  

Changes introduced by the modified RRP do not affect the assessment on the compliance with the 
principle of ‘do no significant harm’ carried out for the original RRP.  

As concerns the measures introduced by the REPowerEU chapter, Austria provided a systematic 
assessment  of  each  measure  in  line  with  the  Do  No  Significant  Harm  Technical  Guidance 
(2021/C58/01).  For  instance,  the  reform  of  the  national  environmental  impact  assessment  law 
(reform 5.A.1), while introducing procedural simplifications streamlining permitting procedure for 
renewable energy projects, also contains provisions against climate change, in particular aimed at 
strengthening soil protection and at avoiding excessive land use. The Austrian Hydrogen Strategy 
(reform 5.A.2) supports the decarbonisation of the energy system and aims at reducing Austrian 
dependency  on  fossil  fuels  imports.  While  setting  a  clear  focus  on  renewable  hydrogen  and 
excluding hydrogen produced with nuclear energy, it contains also measures aimed at the use of 
low-carbon  hydrogen  (produced  through  pyrolysis)  under  strict  conditions  ensuring  that 
greenhouse gas emissions are separated and fully captured. Whilst the investment (5.B.1) in the 
expansion  of  electricity  production  through  photovoltaic  systems  reduces  greenhouse  gas 
emissions,  it  contributes  also  to  other  environmental  objectives  by  supporting  installations 
exclusively  on  buildings  to  avoid  any  additional  land  use  and  by  relying  on  equipment  and 
components with high durability and recyclability that are easy to dismantle and to refurbish. The 
investment  supporting  the  expansion  of  zero-emission  commercial  vehicles  and  the  related 
infrastructure  (investment  5.B.2),  besides  contributing  to  the  decarbonisation  of  the  transport 

13 

 
 
 
 
 
 
sector,  will  require  recipients  to  comply  with  the  Taxonomy  Regulation  and  respect  ambitious 
standards  with  respect  to  reusability  and  recyclability.  Given  that  this  investment  represents  a 
scale-up of the existing investment in zero-emission light commercial vehicles (investment 1.B.4), 
the original DNSH assessment still holds.  

The information provided allows to conclude that the modified RRP is expected to ensure that no 
measure does significant harm. 

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Austria’s modified recovery and 
resilience  plan,  including  its  REPowerEU  chapter,  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’). This would warrant a rating of A under criterion 2.4 of 
Annex V to the RRF Regulation. 

3.5. Green transition 

The  modified  RRP  continues  to  significantly  contribute  to  the  green  transition  by  supporting 
investment  in  sustainable  mobility,  renewable  energy,  renovation  of  buildings  and  energy 
efficiency,  decarbonisation  of  industry  as  well  as  measures  promoting  biodiversity,  circular 
economy, and climate adaptation. The investment in sustainable mobility continues providing the 
largest contribution to the green transition objective.  

The main impact  of revisions in  the modified RRP  related to  the green transition  concerns the 
following  measures:  investment  1.A.3  (Combating  energy  poverty),  investment  1.B.3  (Zero-
emission buses), investment 1.D.2 (Transforming industry towards climate neutrality), investment 
2.D.3 (Green investments in enterprises), investment 3.D.2 (IPCEI Hydrogen), investment 4.B.3 
(Investment 
investment  4.C.3  (Renovation  of 
in  climate-friendly 
Volkskundemuseum Wien and Prater Ateliers).  

town  centres)  and 

Climate target  

The modification of these measures results in a decrease in the contribution of the revised RRP 
(without the REPowerEU chapter) to the green transition by EUR 34 million in total. Despite this 
decrease, the revised RRP maintains a strong ambition in  terms of its contribution to the green 
transition, which is significantly above the minimum target of 37% set in Article 19(3)(e) of the 
RRF Regulation and stands at 53% of the revised RRP’s total allocation of EUR 3 750 853 030 
(without the REPowerEU chapter). 

The  climate  contribution  of  the  REPowerEU  chapter  is  of  100%  of  the  total  estimated  cost  of 
measures in the REPowerEU chapter of EUR 210 304 520, which is well above the 37% target set 
out in the RRF Regulation.   

14 

 
 
 
 
 
 
In total, the climate contribution of the revised Austrian RRP (including the REPowerEU chapter) 
stands  at  56%  (EUR  2  208  118  488)  of  Austria’s  total  allocation  (including  the  REPowerEU 
chapter) of EUR 3 961 157 550, which is also well above the target of 37% required by the RRF 
Regulation. 

*** 

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

3.6. Digital transition 

The modified RRP continues to significantly contribute to the digital transition by supporting the 
deployment of Gigabit-capable networks, digitalisation of businesses and public administration, 
provision of digital devices and digital skills, and development of advanced digital technologies, 
such as quantum computing and microelectronics. 

The main impact of revisions in the modified RRP concerns two measures relating to the digital 
transition:  investment  2.A.2  (Widespread  availability  of  Gigabit  capable  access  networks  and 
creation of new symmetric Gigabit connections) and investment 2.C.2 (Digitalisation fund - public 
administration). The modification of these two measures results in a decrease in the estimated costs 
of the investments and their contribution to the digital transition by EUR 435 million and EUR 53 
million, respectively. Despite this decrease, the revised RRP maintains a strong ambition in terms 
of its contribution to the digital transition, which is significantly above the minimum target of 20% 
set in Article 19(3)(f) of the RRF Regulation and stands at 36% of Austria’s total allocation or 
EUR 1 339 754 242. None of the measures included in the REPowerEU chapter were identified as 
contributing to the digital transition. 

*** 

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

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 unexpected strong increase of inflation, as well as the prolonged impact of the 

15 

 
 
 
 
 
 
 
 
COVID-19 crisis. It also includes a new REPowerEU chapter which, in addition to the existing 
measures, is also expected to have lasting positive effects on the Austrian economy and further 
boost its green transition. In particular, the REPowerEU measures are expected to contribute to the 
green transition by reducing Austrian dependence on fossil fuels, expanding and accelerating the 
deployment of renewable energies and necessary infrastructure, and decarbonising the transport 
sector. The reforms in the REPowerEU chapter are also expected to have a long-lasting impact on 
Austria by simplifying and streamlining permitting procedures for renewables and increasing the 
production  and  uptake  of  renewable  hydrogen.  The  investments  will  support  the  expansion  of 
renewable energy and support zero-emission transport and its related infrastructure. 

*** 

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Austria  in  its  modified 
recovery and resilience plan, their implementation is expected, to a large extent to bring about a 
structural change in the administration or in relevant institutions and in relevant policies and to 
have a lasting impact. This would warrant a rating of A under criterion 2.7 of Annex V to the RRF 
Regulation. 

3.8.  Milestones, targets, monitoring and implementation 

The milestones and targets of the modified Austrian RRP enable an adequate monitoring of 
the plan’s implementation. The new REPowerEU chapter includes two additional reforms, one 
new investment and a scale-up of an existing investment.  

The performance of the investments included in the new REPowerEU chapter will be assessed by 
each public entity in charge of implementing the measures. The impact of the reform of the national 
environmental impact assessment law, which was adopted on 2 March 2023 and entered into force 
on 23 March 2023, will be evaluated in a report to the Austrian Parliament, with recommendations 
on how to further speed up permitting of projects relevant for Austria’s green transformation. For 
the national Hydrogen Strategy, a monitoring scheme by four working groups and a supervisory 
board is in place to ensure adequate governance.  

The adjustments made to the plan’s 59 original measures (27 reforms and 32 investments) and the 
additional 4 measures introduced under the REPowerEU chapter do not affect the plan’s overall 
level of ambition. On the contrary, in some cases they help making the achievement criteria more 
concrete and therefore improve monitoring and assessment procedures.  

*** 

The arrangements proposed by Austria 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.  

16 

 
 
 
 
 
 
 
3.9. Costing 

Austria  has  provided  detailed  information  on  the  estimated  costs  for  the  revised  RRP, 
including the investments in the REPowerEU chapter. Austria has also submitted individual 
justifications for all the measures whose modifications entailed a change in the cost estimates.  

The estimated costs of the measures included in the REPowerEU chapter are reasonable and 
in line with the nature and type of the envisaged reforms and investments. For both the new 
and the scaled-up investment, Austria has supported the analysis with scientific studies as well as 
references  to  actual  tender  data,  when  available.  All  costs  of  the  REPowerEU  chapter  will  be 
incurred after February 2022.  

Most  of  the  changes  in  the  cost  estimates  for  amended  measures  are  well  justified  and 
proportional. Most of the calculations are clearly explained and well substantiated by supporting 
documents, allowing to identify the methodology used. When the amendments to the measures 
were not fully proportional to the cost increases or the link was less clear, Austria provided detailed 
explanations to substantiate their proposal. In a few instances, complementary targets have been 
made more demanding to maintain the overall level of ambition of the Plan. 

Reasonable costs 

In most cases, Austria accompanied their claims with actual data and supporting evidence for unit 
cost estimates, together with adequate explanations of the calculation methodology. Overall, the 
assumptions used by Austria to estimate the costs of the new and modified measures provide a 
reasonable  explanation  of  the  key  cost  drivers  of  the  measures.  The  calculations  are  generally 
clearly  spelled  out  allowing  to  identify  the  methodology  used,  even  if  for  a  limited  number  of 
measures the information provided is more limited or less clear.  

The measures outlined in the REPowerEU chapter comply with the eligibility criteria set out in 
the RRF Regulation. No recurrent costs are included, and all costs will be incurred after February 
2022. Value-added tax (VAT) is not included in any of the cost estimates. 

The costs of the amended measures appear reasonable and well justified. In the case of measures 
being  amended  under  Article  21(1)  of  the  RRF  Regulation,  sufficient  information  has  been 
provided to justify the objective circumstances and the proportionality of the changes in the cost 
estimates  or  related  target.  Any  changes  in  unit  costs  due  to  inflation  were  justified  and  the 
underlining calculations appear clear. Whenever possible, these were supported by evidence from 
the  ongoing  projects.  When  the  amendment  was  not  clearly  linked  to  the  change  in  costs,  for 
instance when the higher costs caused a lack of demand from final recipients, further explanations 
were provided. 

Plausible costs 

Most of the estimated costs of the new and modified measures are in line with the nature and type 
of  the  envisaged  reforms  and  investments.  For  new  and  modified  measures,  actual  data  was 
provided,  whenever  available.  This  includes  data  from  past  and  ongoing  tenders,  individual  or 

17 

 
 
 
 
 
 
aggregated data from the implemented projects, data from national statistics and scientific reports 
complementing the proposals. In a limited number of instances, the comparability of past projects 
to the ones proposed in the plan could not be fully established, partially due to the novelty of the 
measures. Overall, the cost estimates of the new and modified measures of the RRP are assessed 
as plausible. 

No double Union financing 

Austria has indicated that the costs to be financed by the RRF will not be funded by other Union 
funding sources. More specifically, Austria committed to ensure that no double funding with other 
funding instruments will occur in the case that any complementary actions are undertaken under 
other Funds. 

Commensurate and cost-efficient costs 

The estimated total cost of the modified RRP is in line with the principle of cost-efficiency and 
commensurate to the expected national economic and social impact. The revised RRP, including 
the  REPowerEU  chapter,  is  expected  to  effectively  address  a  significant  subset  of  challenges 
identified in the country-specific recommendations (CSRs). In particular, the new measures in the 
REPowerEU chapter are expected to address challenges identified in CSRs in the field of energy 
and green transition, notably 2019.3.1., 2019.3.3., 2020.3.5., 2020.3.6., 2020.3.7., 2022.4.1., and 
2022.4.2., 2023.4.1. and 2023.4.2.).  

*** 

The justification provided by Austria 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.  

Austria 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  previous  assessment  on  the  adequacy  of  the  control  and  audit  arrangements  presented  by 
Austria in the RRP 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, had concluded that these arrangements 
are adequate. This warranted a rating of A under the assessment criterion 2.10 of Annex V to the 
RRF Regulation. 

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 Austrian 

18 

 
 
 
 
 
 
 
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 
Austria. 

In  light  of  this  information,  the  Commission  considers  that  the  internal  control  system  of  the 
Austrian RRP is overall adequate, but it has some deficiencies that must be addressed through a 
dedicated audit and control milestone. This relates to a weakness in the recording of data required 
by Art. 22 (2) (d) (i) – (iii) RRF, the checks for double-funding, also against other EU funding 
sources, and the documentation of these checks. 

Adequacy of control systems and other relevant arrangements  

While the original assessment regarding the adequacy of the control systems and other relevant 
arrangements remains mostly the same, in its audit on the protection of the financial interests of 
the Union (PFIU) the Commission found a weakness regarding the recording of the data required 
by  Art.  22  (2)  (d)  (i)  –  (iii)  of  the  RRF  Regulation.  Austria  uses  a  central  database  called  the 
Transparency Database (TDB) for the recording of grants and the data required by Art. 22 (2) d of 
the  RRF  Regulation.  This  database  is  also  used  in  their  double-funding  checks.  However,  the 
Commission found that there is only a legal obligation (legal base) to record the data required by 
the RRF Regulation for the federal governmental bodies. The federal government does cascade 
this obligation by means of legal agreements to their subordinated implementing bodies. However, 
there is no such legal obligation for the federal states and the implementing bodies subordinated 
to them. The latter two currently only do this recording into the database voluntarily. This finding 
was  confirmed  by  Austria.  As  some  milestones  and  targets  of  the  Austrian  RRP  are  partially 
implemented by the federal states and their subordinate bodies, it is hence not possible to legally 
ensure that the data recording obligations of Art. 22 (2) (d) (i) – (iii) of the RRF Regulation are 
fully respected. Hence, a milestone on audit and control needs to be introduced in order to remedy 
the weakness. 

Adequacy of arrangements to avoid double EU funding  

A very similar issue is true for the checks for double-funding. The Commission found in its PFIU 
audit and the subsequent consultations with Austria, that information on EU funding sources is 
only partially available in the Austria’s TDB. Moreover, while there is a legal obligation to perform 
double-funding checks for the federal government and its subordinated bodies, there is no such 
legal obligation for the federal states and their subordinate bodies. The latter perform such checks 
voluntarily, however there is no legal base that obliges them to do so. This creates the risk that 
double-funding  checks  are  not  taking  place  and  that  coordinating  bodies  cannot  enforce  them.  
Hence, a milestone on audit and control needs to be introduced in order to remedy the weakness.   

Conclusion 

The chapter on audit and control and the additional information provided gives a rather complete 
description of the arrangements for the implementation and control of the Plan in  Austria. The 

19 

 
 
 
 
 
chapter provides the details for all the entities and gives reasonable assurance that there is a sound 
structure in place to monitor, implement and control the allocated funds from the RRF. 

However, one new milestone will be introduced to address the missing elements. This milestone 
reads as follows: 

“Legally binding agreements shall be signed between the responsible bodies at federal level and 
the  implementing  bodies  which  are  fully  or  partially  responsible  for  the  RRF  implementation.  
Such agreements shall set out an obligation for these implementing bodies to (a) collect and ensure 
access to the data required by Article 22 (2) (d) (i) - (iii) of the RRF Regulation and (b) conduct 
appropriate  controls  of  double  funding  between  the  RRF  and  other  Union  programmes  and 
document these controls.  

Where the aforementioned obligations are already legal requirements no legally binding agreement 
shall be necessary.” 

*** 

The  arrangements  proposed  by  Austria  in  the  modified  RRP  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  Austria  is  structured  along  four  coherent  components, 
which support the common objectives of stimulating the recovery of the Austrian economy, 
addressing  long-lasting  structural  challenges  –  that  have  become  more  acute  during  the 
crisis. Furthermore, the investments and reforms are embedded in a coherent framework to make 
the Austrian economy  fit for the future, particularly as regards the green  and digital transition, 
innovation, competitiveness, and social cohesion. The modification of the RRP regards the four 
existing components, and brings an additional (5th) component, the REPowerEU chapter. 

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

Mutually reinforcing measures  

The  modifications  to  the  RRP  do  not  negatively  affect  the  components’  coherence,  nor  the 
coherence of the plan as a whole. They do not alter the way they are mutually-reinforcing. The 
additional REPowerEU chapter is fully in line with the measures deployed under the initial RRP 
to support the green transition and further reinforces the ambition of some of them, in particular 
with  the  scale-up  of  the  investment  in  zero-emission  commercial  vehicles  and  charging 
infrastructure. The modifications do not have contradictory aims or possible negative effects on 
one another.    

Complementarity of measures 

20 

 
 
 
 
 
 
The modifications made to the existing four components of the RRP do not negatively alter the 
complementarity  of  the  components.  The  additional  component  addressing  the  REPowerEU 
objectives brings a new complementarity layer as it includes measures that aims at reinforcing the 
reduction of greenhouse gas emissions further in addition to promoting renewable energy.  At the 
level of the modified plan, all components pursue complementary aims – with no contradictory 
aims.  

*** 

Taking  into  consideration  the  qualitative  assessment  of  all  components  of  Austria’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 

Austria’s  REPowerEU  chapter  contributes  to  the  objective  of  increasing  the  share  and 
accelerating the deployment of renewable energy in line with Article 21c (3), point (b) of the 
RRF Regulation.  

Lengthy permitting procedures remain an important challenge for the implementation of renewable 
energy projects in Austria. The reform of the national environmental impact assessment law aims 
to streamline the permitting process by (i) introducing several procedural simplifications, such as 
less  restrictive  planning  requirements  by  the  Länder  and  designation  by  municipalities,  and 
facilitated changes to the permit in case of technological development, (ii) deeming investments 
in  renewable energy  as  projects  of  particularly  high  public interest,  (iii) reducing  the length of 
appeals  by  setting  concrete  deadlines  for  objections  at  the  beginning  of  the  procedure  and 
removing the suspensive effect of the appeal in case of insufficiently substantiated complaints and 
(iv)  by  an  increased  use  of  digitalisation  through  electronic  proceedings  and  online  or  hybrid 
hearings. For wind power plants, the reform allows to issue permits also in the absence of energy 
area  planning  by  regional  and/or  municipal  authorities.  The  reform  is  expected  to  increase  the 
share of renewables in Austria’s energy mix, thus contributing to the REPowerEU objective of 
accelerating the deployment of renewable energy, in accordance with Article 21c (3), point (b) of 
the RRF Regulation. In 2024, the impact of the reform will be evaluated in a report to the Austrian 
Parliament, with recommendations on how to further speed up permitting of projects relevant for 
Austria’s green transformation. All these measures are expected to have a long-lasting impact. 

Austria’s REPowerEU chapter also contributes to the objective of increasing the production 
and  uptake  of  renewable  hydrogen  and  of  increasing  the  share  and  accelerating  the 
integration of renewable energy sources in line with Article 21c (3), point (b) and (e) of the 
RRF Regulation. The national Hydrogen Strategy, published on 2 June 2022, provides for a new 
policy and regulatory framework aimed at ramping up the production of renewable hydrogen, and 
also contributes to developing hydrogen-ready infrastructure in Austria with a view to enabling 
imports and transport of hydrogen. It outlines specific actions and measures to be adopted in eight 
policy areas (flagship projects, funding for production, incentives for hydrogen-enabled business 
models,  infrastructure,  green  mobility,  R&D,  stakeholder  dialogue,  and  EU  and  international 

21 

 
 
 
 
 
 
 
 
collaboration).  It also  sets  the objective to  install 1 GW electrolysis capacity by 2030 and lays 
down  a  plan  aimed  at  reducing  reliance  on  fossil  fuels  in  sectors  which  are  otherwise  hard  to 
decarbonise. The implementation of the strategy will be coordinated by four working groups and 
monitored by a supervisory board. To facilitate the implementation process, a national hydrogen 
platform will be established, allowing for a structured dialogue with research, energy, and industry 
stakeholders.  Other  key  deliverables  comprise  the  publication  of  an  integrated  national  energy 
infrastructure plan and the adoption of a regulatory framework for a national hydrogen certification 
scheme. In 2024, a first evaluation report on the implementation of the Hydrogen Strategy will 
have  to  be  provided.  Furthermore,  the  subsidy  scheme  supporting  investment  in  photovoltaic 
systems on buildings and electricity storage is expected to increase the uptake of solar energy in 
buildings  among  private  individuals  and  non-profit  organisations,  thus  also  contributing  to  the 
REPowerEU objective of accelerating the deployment of renewable energy in line with Article 
21c (3), point (b) of the Regulation. 

Austria’s REPowerEU chapter also contributes to the objective of supporting zero-emission 
transport and its infrastructure in line with Article 21c (3), point (e) of the RRF Regulation. 
The funding scheme supporting investment in heavy-duty zero-emission commercial vehicles and 
charging infrastructure aims to accelerate the decarbonisation of the road transport, which is the 
sector most difficult to abate, accounting for 28% of total national greenhouse gas emissions in 
Austria. 

Furthermore, the REPowerEU chapter is coherent with Austria’s original RRP and helps to 
extend the plan’s ambitions in terms of green transition. In addition to the two reforms, the two 
investments of accelerating the deployment of renewables, and zero-emission commercial vehicles 
and infrastructure complement measures in the original plan, namely  sub-component 1.B. Eco-
friendly  mobility  and  sub-component  1.D.  Transformation  to  climate-neutrality.  By  adding  a 
reform aimed at accelerating the permitting procedures for the deployment of renewables, Austria 
addresses an aspect of energy policy that was not touched upon in the original RRP. 

The REPowerEU chapter was prepared after an official consultation process that took place 
from 2 to 31 March 2023. That consultation was publicly advertised on the website dedicated to 
the Austrian RRP, with the social partners, stakeholders of civil society and youth organisations 
as well as representatives of regional and local authorities specifically invited to submit proposals. 
Following this consultation, the authorities integrated the feedback from the consultation process. 
Several  suggestions  were  taken  up,  for  instance  regarding  zero-emission  commercial  vehicles. 
Overall, the investments and reforms of the REPowerEU chapter largely reflect the results of the 
public consultation. 

Finally,  the  proposed  measures  within  the  REPowerEU  chapter  supporting  climate  objectives 
account for 100% of the chapter’s total estimated costs (i.e., more than the 37% required), based 
on the methodology for climate tracking set out in Annex VI.  

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 

*** 

22 

 
 
 
 
 
 
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 the measures included in Austria’s REPowerEU chapter have a multi-country or cross-
border  dimension  or  effect,  except  for  the  scaled-up  investment  providing  funding  for  zero-
emission vehicles and charging infrastructure.  

The reform of the national environmental impact assessment law to accelerate the permitting of 
renewable energy projects, the national Hydrogen Strategy aimed at ramping up the production 
and  use  of  renewable  hydrogen  and  at  developing  the  related  infrastructure,  as  well  as  the 
investment in photovoltaic systems and electricity storage on buildings are all expected to expand 
the production of renewable energy and to contribute to improving the storage infrastructure, and 
thus  to  reduce  demand  for  fossil  fuels.  Given  Austria’s  central  geographical  position  and  its 
electricity  and  gas  interconnectors  to  the  neighbouring  Member  States,  these  measures  will 
contribute to securing energy supply in the Union as a whole.   

The total costs of measures with a multi-country or cross-border dimension or effect account for 
more than 66.7% of the estimated costs of the REPowerEU chapter, thus exceeding the minimum 
target of 30%.  

*** 

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 to the RRF Regulation. 

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

Costs 
million) 

(EUR 

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

5.A.1.  Acceleration  of  permitting  procedures  for 
renewables 
5.A.2.  Hydrogen  as  key  technology  to  climate 
neutrality 
5.B.1. Photovoltaic systems 

0 

0 

n/a 

n/a 

140.3 

66.7% 

23 

 
 
 
 
 
 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging  

Measure/ 
Sub-
Measure 
ID 

1.A.2a 

1.A.2b 

1.A.2c 

1.A.3 

1.B.3 

1.B.4 

1.B.5a  

1.B.5b 

1.C.2 

1.C.3 

1.C.4 

1.C.5 

1.D.2 

2.A.2a 

2.A.2b 

2.A.2c 

Measure/Sub-Measure Name 

Exchange of oil and gas heating 
systems - biomass  
Exchange of oil and gas heating 
systems - district heating 
Exchange of oil and gas heating 
systems - other renewable energy 
Combating energy poverty 

Zero-emission buses 

Zero-emission utility vehicles 
Construction of new railway lines and 
electrification of regional railways — 
newly or upgraded TEN-T core 
network. 
Construction of new railway lines and 
electrification of regional railways — 
other newly or upgraded built railways 
Biodiversity fund 
Investments in reverse vending 
systems and measures to increase the 
reuse quota of beverage containers 
Retrofitting of existing and 
construction of new sorting facilities 
Promotion of the repairing of electrical 
and electronic equipment (repair 
bonus) 
Transforming industry towards climate 
neutrality 
Widespread availability of Gigabit 
capable access networks and creation 
of new symmetric Gigabit connections 
– administrative processing 
Widespread availability of Gigabit 
capable access networks and creation 
of new symmetric Gigabit connections 
– accompanying measures 
Widespread availability of Gigabit 
capable access networks and creation 
of new symmetric Gigabit connections 
– broadband 

Climate 

Digital 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. Field  Coeff. % 

53 

53 

53 

50 

256 

50 

030bis 

100% 

034bis
0 

100% 

032 

100% 

025bis 

074 
n/a[1] 

100% 

100% 

100% 

536.6 

064 

100% 

6 

50 

066bis 

100% 

050 

40% 

110 

042 

40% 

60 

042 

40% 

130 

042 

40% 

100 

024ter 

100% 

9.125 

9.125 

438 

24 

053 

100% 

053 

100% 

053 

100% 

 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ 
Sub-
Measure 
ID 

2.B.2 

2.C.2 

2.D.1 

2.D.2 

2.D.3a 

2.D.3b 

2.D.3c 

2.D.3d 

2.D.3e 

2.D.3f  

3.A.2 

3.A.3 

3.A.4 

3.B.2a 

3.B.2b 

3.B.2d 

3.D.1 

3.D.2 

4.A.3 

4.B.3a 

Measure/Sub-Measure Name 
Provision of digital end-user devices to 
pupils 
Digitalisation fund public 
administration 
Digitalisation of SMEs 

Digital investments in enterprises 
Green investments in enterprises - 
Thermal renovation of buildings   
Green investments in enterprises - 
grid-coupled photovoltaic installations 
and electricity storage  
Green investments in enterprises - 
energy saving in companies   
Green investments in enterprises - 
zero-emission mobility — sub measure 
Green investments in enterprises - 
other alternative fossil free drives 
Green investments in enterprises – 
investment in electronic charging 
station 
Quantum Austria — Promotion of 
Quantum Sciences 
Austrian Institute of Precision 
Medicine-Digital Share   
(Digital) Research Infrastructures 
Promoting re-skilling and up-skilling -  
basic qualification  
Promoting re-skilling and up-skilling - 
IT/care/environment 
Promoting re-skilling and up-skilling - 
youth coaching 
IPCEI Microelectronics and 
Connectivity 
IPCEI Hydrogen 
Development of the electronic mother 
child pass platform including the 
interfaces to the early aid networks 
Investment in climate-friendly town 
centres - building refurbishment of 
companies 

Climate 

Digital 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. Field  Coeff. % 

012 

011 

010 

010 

100% 

100% 

100% 

100% 

171.7 

106.9 

32 

69 

9.74 

024ter 

100% 

173.57 

029 

100% 

22.19 

024ter 

100% 

294 

072bis 

100% 

4 

072bis 

100% 

0.5 

077 

100% 

107 

13.7 

30 

81.25 

112.5 

19.8 

125 

125 

10 

021quater 

100% 

009bis 

100% 

021quater 

100% 

108 

108 

099 

100% 

100% 

40% 

055bis 

40% 

009bis 

100% 

022 

100% 

095 

100% 

2.12 

024ter 

100% 

25 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure/ 
Sub-
Measure 
ID 

4.B.3b 

4.B.3c 

4.B.3d 

4.C.3 

4.C.4 

4.C.5 

5.B.1 

5.B.2 

Climate 

Digital 

Measure/Sub-Measure Name 
Investment in climate-friendly town 
centres- connection to high-efficiency 
district heating 
Investment in climate-friendly town 
centres –- green façades projects  
Investment in climate-friendly town 
centres - brownfield land projects 
Renovation of Volkskundemuseum 
Wien and Prater Ateliers – energy 
efficiency measures 
Digitalisation wave cultural heritage 
Investment fund for climate-friendly 
cultural businesses 
Photovoltaic systems 
Funding zero-emission commercial 
vehicles and infrastructure 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

3.39 

030bis 

100% 

0.22 

037 

100% 

10 

046bis 

40% 

13.9 

026 

40% 

16.5 

15 

140.3 

024 

029 

40% 

100% 

70 

n/a[2] 

100% 

Int. Field  Coeff. % 

021bis 

100% 

While the estimated cost of Austria’s recovery and resilience plan exceeds the total allocation of 
non-repayable  financial  support  to  Austria,  Austria  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. 

[1] 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 zero-emission vehicles of all categories (this includes battery electric and fuel cell/hydrogen-powered 
vehicles). 

[2] see footnote no.1 above 

26