COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Denmark Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10154/21 INIT; ST 10154/21 ADD 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Denmark
Date: 2023-10-19
Institutions: European Commission, Secretariat-General
Subjects: Denmark, 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) 343 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Denmark Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10154/21 INIT; ST 10154/21 ADD 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Denmark {COM(2023) 673 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 .............................................................................................. 6 

3.1. 

Comprehensive and adequately balanced response to the economic and social situation ........ 7 

3.2. 

Link with country-specific recommendations and the European Semester ................................. 9 

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 ...... 10 

3.4. 

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

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

3.6. 

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

3.7. 

Lasting impact of the plan ........................................................................................................... 14 

3.8.  Milestones, targets, monitoring and implementation................................................................ 14 

3.9. 

Costing ........................................................................................................................................ 15 

3.10.  Controls and audit ....................................................................................................................... 17 

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

3.12.  REPowerEU ................................................................................................................................. 20 

3.13.  Cross-border or multi-country dimension or effect ................................................................... 22 

ANNEX I: Climate tracking and digital tagging ........................................................................................ 24 

1 

 
 
 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

On  May  31,  2023,  Denmark  submitted  to  the  Commission  a  modified  national  Recovery  and 
Resilience  Plan  (RRP),  where  the  only  modification  consists  of  the  addition  of  a  REPowerEU 
chapter in accordance with Article 21c of Regulation (EU) 2021/241. 

The Danish economy has experienced a prolonged period of robust growth, only interrupted by 
significant fluctuations in activity during the COVID-19 pandemic. Denmark’s per capita GDP (in 
purchasing power standard/PPS) was 135% of the EU average in 2021, the third highest in the EU. 
Inflation increased sharply following the Russian war of aggression against Ukraine from 1.9% in 
2021 to 8.5% in 2022, the highest rate of inflation recorded in Denmark since the early 1980s. 
Rising  energy,  food  and  commodity  prices  were  the  main  drivers  behind  the  initial  surge  in 
inflation. These pressures have become broader-based due to higher production costs and higher 
import prices, as also reflected in the considerable rise in core inflation. 

While Denmark has already successfully implemented a broad range of measures that support the 
green and digital transition and make the Danish economy and society more resilient, Denmark 
faces additional challenges, which concern in particular reducing dependence on fossil fuel and 
the improvement of its energy system. First, Denmark had the second highest household energy 
bills in the EU in 2022, which increased by 49% between 2019 and 2022 due to higher energy 
prices (from EUR 3 350/year to EUR 5 500/year). A substantial push at national and municipal 
levels to phase out of fossil fuel sources for heating purposes will contribute to reducing energy 
bills for final consumers. Scaled up energy efficiency measures in both public and private buildings 
would also contribute to reducing the energy bill. Second, permitting procedures for the roll-out 
of green heating solutions and renewable energy projects, especially on land, remain insufficiently 
streamlined  and  rather  time-consuming.  Third,  given  the  foreseen  increase  in  renewable 
generation, Denmark needs to improve the integration and connectivity of its electricity network, 
both at distribution and transmission levels. Lastly, in order to accompany the decarbonisation of 
the energy system, Denmark will need to upskill and reskill its workforce, as the lack of green 
skills is creating bottlenecks in the transition to the net-zero economy. 

For the modification of its RRP, Denmark has relied on the following legal base: Article 21c to 
include additional resources from ETS revenues or from the Brexit Adjustment Reserve (BAR) 
for its REPowerEU chapter. 

The revision of Denmark’s RRP only includes the addition of its REPowerEU chapter, which relies 
on Article 21c to include additional resources from ETS revenues or from the Brexit Adjustment 
Reserve (BAR). 

Under  this  revision,  Denmark  has  added  one  reform  sub-measure  which  aims  to  simplify  and 
shorten permitting and administrative procedures for the roll-out of district heating solutions and 
deployment  of renewable energy projects  on land, three investments on renewable energy, one 
investment on green upskilling, and has upscaled two existing investments, one on Carbon Capture 
and Storage (CCS) and one on replacing oil burners and gas furnaces. The total estimated cost of 
the REPowerEU component is EUR 196.9 million.  

2 

 
 
 
 
 
The measures under the chapter are aligned with Denmark’s policy framework aimed at reducing 
by 70% Denmark’s greenhouse gas emissions by 2030 (compared to 1990 level) and at achieving 
climate neutrality by 2045. REPowerEU measures will accelerate the deployment of renewable 
energy on land and offshore, especially by developing Denmark’s offshore wind energy capacity 
and reducing the barriers for the roll-out of renewable energy sources onshore. Moreover, they 
will  reduce  the  reliance  on  fossil  fuels  and  will  foster  the  development  of  innovative  Carbon 
Capture and Storage technologies aimed at decarbonising industry. Finally, the measures under 
this chapter will support Denmark’s green upskilling efforts. 

The modified RRP continues to represent a comprehensive and adequate response to the economic 
and  social  challenges  faced.  The  original  7  components,  with  the  addition  of  a  REPowerEU 
chapter, continue to address the six pillars of the RRF and either maintain or further strengthen the 
level of ambition of the plan. 

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

(1) 
Balanced 
Response 

(2) 
CSRs 

(3) 
Growth, 
jobs… 

(4) 
DNSH 

(5) 
Green 
target 

(6) 
Digital 
target 

(7) 
Lasting 
impact 

(8) 
M & T 

(9) 
Costing 

(10) 
Control 
Systems 

(11) 
Coherence 

(12) 
REPowerEU 

(13) 
Cross-
border  

A 

A 

A 

A 

A 

A 

A 

A 

B 

A 

A 

A 

A 

2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

On  31  May  2023  Denmark  submitted  to  the  Commission  a  modified  national  Recovery  and 
Resilience  Plan  (RRP),  where  the  only  modification  consists  of  the  addition  of  a  REPowerEU 
chapter in accordance with Article 21c of Regulation (EU) 2021/241. 

The measures under the chapter are aligned with Denmark’s policy framework aimed at reducing 
by 70% Denmark’s greenhouse gas emissions by 2030 (compared to 1990 level) and at achieving 
climate neutrality by 2045. REPowerEU measures will accelerate the deployment of renewable 
energy on land and offshore, especially by developing Denmark’s offshore wind energy capacity 
and reducing the barriers for the roll-out of renewable energy sources onshore. Moreover, they 
will  reduce  the  reliance  on  fossil  fuels  and  will  foster  the  development  of  innovative  Carbon 
Capture and Storage technologies aimed at decarbonising industry. Finally, the  measures under 
this chapter will support Denmark’s green upskilling efforts. 

2.1. New challenges in Denmark 

Denmark has committed to ambitious decarbonisation objectives. Its climate policy aims to reduce 
greenhouse gas emissions by 70% by 2030 compared to 1990 and achieve climate neutrality by 
2045  at  the  latest,  including  a  commitment  to  phasing  out  coal  completely  by  2028.  While 

3 

 
 
 
 
 
 
 
Denmark is a front runner in the uptake of renewable energy (44% of the energy mix in 2021) and 
clean  tech,  in  particular  wind  production,  faster  commissioning  of  projects  and  simplified 
permitting rules are essential to achieve national ambitions for offshore and onshore wind capacity. 

Denmark had the second highest household energy bills in the EU in 2022, which increased by 
49%  between  2019  and  2022  due  to  higher  energy  prices  (from  EUR  3  350/year  to  EUR  5 
500/year). A substantial push at national and municipal levels to phase out of fossil fuel sources 
for heating purposes will contribute to reducing energy bills for final consumers. In this context, 
boosting energy efficiency measures in buildings that combine insulation measures and the roll-
out of decarbonised heating sources could further reduce dependency on fossil fuels. 

Better energy connectivity, including energy islands in the Baltic Sea and North Sea, will facilitate 
cross-country  energy  interconnection  but  require  sufficient  grid  expansion  planning  at 
transmission and distribution level. In this sense, preparing integrated system planning for future 
grid expansion would be needed to respond to demand and flexibility needs both at transmission 
and distribution levels. This planning could also include backbones and storage for hydrogen and 
CO2 in view of Denmark’s growing ambitions on Power-to-X and carbon capture, utilisation and 
storage. 

Denmark  could  also  accelerate  its  transition  to  zero-  and  low-emission  mobility.  Charging 
infrastructure  remains  a  challenge  for  car  owners  living  in  dense  urban  areas,  especially  in 
Copenhagen,  due  to  a  lacking  availability  of  publicly  accessible  charging  points.  Charging 
infrastructure is also not sufficient for heavy duty vehicles, where incentives until 2025 remain 
lower than for light vehicles.  

Finally, some decarbonisation challenges remain for Denmark to reach its ambitious climate goals, 
especially on agriculture. In 2021, the sector was the largest source of Denmark’s greenhouse gas 
emissions under the EU Effort Sharing Regulation (38.4%), more than twice the EU average. 

2.2. Overview of the REPowerEU chapter 

The  REPowerEU  chapter  contains  measures  to  help  address  the  key  energy  challenges  that 
Denmark is currently facing. The REPowerEU chapter includes a reform to simplify and expedite 
administrative and permitting procedures for the deployment of renewable energy projects and the 
roll-out of green heating solutions (reform C8.R1); an investment for the preparation of tenders 
for  4  Gigawatt  (GW)  of  offshore  wind  energy  (investment  C8.I1.1);  an  investment  for  the 
screening  of  Denmark’s  offshore  wind  capacity  (investment  C8.I1.2);  an  investment  for  the 
installation and testing of offshore and onshore experimental wind turbines (investment C8.I1.3). 
These  measures  contribute  to  the  REPowerEU  objectives  of  boosting  energy  efficiency  in 
buildings, increasing the share and accelerating the deployment of renewable energy, accelerating 
the integration of renewable energy sources (Article 21c(3)(b) and (e) of the RRF Regulation). 
Moreover,  the  measures  contribute  to  addressing  energy  poverty  (Article  21c(3)(c)  of  the 
Regulation). The chapter also includes a measure on green upskilling (investment C8.I2), aiming 
at upskilling the Danish labour force in green skills that will be key for the Danish green transition 
(Article 21c(3)(f) of the RRF Regulation). 

4 

 
 
 
 
 
The chapter then upscales two measures in the original recovery and resilience plan. The first is a 
measure consisting of two investments aimed at subsidising households’ exit from fossil fuel. One 
investment subsidises households that replace oil burners with electric heat pumps while another 
compensates households for fees incurred for exiting from gas heating (Article 21c(3)(c) of the 
Regulation). Both subsidy schemes are described in the original plan and the REPowerEU chapter 
upscales these measures. The second is a measure on Carbon Capture and Storage (CCS), a pioneer 
green technology which will contribute to decarbonising Denmark’s industry (Article 21c(3)(b) of 
the RRF Regulation).    

The measures of the REPowerEU chapter are listed below.  

Component 8 – REPowerEU 

Reform C8.R1 - National energy crisis staff (NEKST) 

Investment  C8.I1.1  –  Preparation  of  a  Call  for  Tenders  for  4  Gigawatt  (GW)  Offshore  Wind 
Energy 

Investment C8. I1.2 – Screening of Denmark’s offshore wind capacity 

Investment C8. I1.3 – Support for the Commissioning of Experimental Wind Turbines 

Investment C8.I2 – Green upskilling 

Investment C8.I3 – Replacing oil burners and gas furnaces (upscale of measure C3.I1) 

Investment C8.I4 – Carbon Capture and Storage (CCS) Potential (upscale of measure C3.I5) 

Table of new and modified components and associated costs. 

Component 
8: REPowerEU  

Status 
New 

Costs (EUR million) 
197 

2.3. Other elements not covered by assessment criteria 

The description of the implementation and monitoring aspect of the plan, and impact on gender 
equality  as  reflected  in  the  previous  Staff  Working  Document  [SWD/2021/154  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 

5 

 
 
 
 
 
 
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 
Denmark in the recovery and resilience plan cannot be deemed a State aid notification. Insofar as 
Denmark 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 Denmark 
to ensure full compliance with the applicable rules. 

3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

The revision of Denmark’s RRP only includes the addition of its REPowerEU chapter, which relies 
on Article 21c of the RRF Regulation to include additional resources from ETS revenues or from 
the  Brexit  Adjustment  Reserve  (BAR).  The  focus  has  therefore  been  on  assessing  the  impacts 
deriving from this addition on the original assessment of the criteria spelt out in the Regulation. 

In  accordance  with  Article  19(3),  point  (a)  and  Annex  V,  criterion  2.1,  to  Regulation  (EU) 
2021/241,  the  RRP  continues  to  represent  to  a  large  extent  (Rating  A)  a  comprehensive  and 
adequately  balanced  response  to  the  economic  and  social  situation,  thereby  contributing 
appropriately to all of the six pillars referred to in Article 3 of that Regulation, taking the specific 
challenges faced by and the financial allocation for Denmark into account. 

The modification of the plan, which relates exclusively to the addition of a REPowerEU chapter, 
further strengthens the contribution of the RRP to the first pillar on the green transition and sixth 
pillar on policies for the next generation while, for the other pillars, the modification brings no 
additional impact. 

All  measures  included  in  the  REPowerEU  chapter  make  significant  contribution  to  the  green 
transition, in line with Denmark’s policy framework of reducing its greenhouse gas emissions by 
70% by 2030 (compared to 1990 levels) and achieving climate neutrality by 2045. 

The chapter also includes a new measure on green upskilling, which aims to improve the skills 
needed  for  the  green  transition  through  investments  in  the  continuous  part  of  the  vocational 
education and training (VET) system. This measure will contribute to ensuring that the short- term 

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 

6 

 
 
 
 
 
 
 
 
and labour market relevant VET programmes are adapted to the rising needs for qualified labour 
to support the green transition. 

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

situation 

The original assessment found that Denmark’s recovery and resilience plan represented to a large 
extent (Rating A) 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 Regulation 
(EU)  2021/241,  taking  the  specific  challenges  and  the  financial  allocation  of  Denmark  into 
account.  The  plan  included  measures  that  effectively  contributed  to  all  the  six  pillars,  with  a 
significant  number  of  the  plan’s  components  addressing  multiple  pillars  simultaneously.  The 
assessment also found that the recovery and resilience plan constituted a balanced, coherent and 
ambitious reply to Denmark’s challenges, and to key challenges linked to the recovery and future 
resilience of the Union, notably the green and digital transition. 

The Commission considers that the addition of a REPowerEU chapter to the original plan impacts 
the  assessment  of  the  contribution  of  the  RRP  to  the  first  and  sixth  pillars.  New  and  upscaled 
measures  under  component  8  further  i)  strengthen  the  focus  of  the  original  plan  on  the  green 
transition; and ii) contribute to improving policies for the next generation. The contributions of the 
new and upscaled measures to the identified pillars are outlined below. 

Pillar I: Green transition 

All  measures  included  in  the  REPowerEU  chapter  make  significant  contribution  to  the  green 
transition, in line with Denmark’s policy framework of reducing its greenhouse gas emissions by 
70% by 2030 (compared to 1990 levels) and achieving climate neutrality by 2045. The reform and 
investments on renewable energy will help Denmark expand and speed up the deployment of clean 
energy projects both onshore and offshore, with cross-border effects contributing to securing and 
diversifying the Union’s energy supply. The new measure on green upskilling aims to equip the 
labour  force  with  the  knowledge  and  expertise  to  develop,  implement,  and  maintain  green 
technologies and practices necessary for the green transition. The upscale of two measures (CCS, 
replacing  oil  burners  and  gas  furnaces),  which  were  already  assessed  in  the  existing  plan, 
contributes to the green transition and reinforces the plan’s ambition to reduce reliance on fossil 
fuels for heating purposes and to decarbonise the economy. 

Pillar VI: Policies for the next generation 

The modified plan includes a new measure on green upskilling, which aims to improve the skills 
needed  for  the  green  transition  through  investments  in  the  continuous  part  of  the  vocational 
education and training (VET) system. This measure will contribute to ensuring that the short- term 
and labour market relevant VET programmes are adapted to the rising needs for qualified labour 
to support the green transition.  

7 

 
 
 
 
 
For the other pillars, the nature and extent of the proposed additions to the RRP do not have any 
sizeable impact on the previous assessment.  

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

Green 
transition 

Digital 
transform
ation 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

REPowerEU chapter 

● 

Health, 
and 
economic, 
social and 
institution
al 
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 

Table X: Coverage of the six pillars of the Facility by the unchanged components 

Green 
transition 

Digital 
transform
ation 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

Strengthening the 
resilience of the 
healthcare system 
Green transition of 
agriculture and 
environment 
Energy efficiency, green 
heating and carbon 
capture and storage 
Green tax reform 
Sustainable road 
transport  
Digitalisation 
Investing in green 
research and 
development 

● 

● 

● 
● 

● 

● 

○ 

● 

○ 

○ 

○ 

● 

○ 

● 

● 

○ 

 ● 

● 

● 
○ 

*** 

Policies 
for the 
next 
generati
on 

○ 

Health, 
and 
economic, 
social and 
institution
al 
resilience 

● 

 ○ 

○ 

○ 

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Denmark,  the  modified 
Recovery  and  Resilience  plan  continues  to  represent,  to  a  large  extent,  a  comprehensive  and 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 Denmark into account. This would warrant a rating of A 
under the assessment criterion 2.1 in Annex V of the RRF Regulation. 

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

As the maximum financial allocation for Denmark has been adjusted downward and Denmark is 
not  proposing  to  modify other elements  of its original  recovery and resilience plan beyond the 
inclusion of the REPowerEU chapter, the 2022 and 2023 recommendations not related to energy 
challenges, such  as those on property taxation and circular  economy,  are not  considered in  the 
overall  assessment.  The  recommended  2023  CSRs  on  energy  were  taken  into  account  in  the 
proposed  modifications,  in  particular  recommendations  to  reduce  reliance  on  fossil  fuels,  to 
streamline  permitting  rules  for  renewable  energy,  to  ensure  a  better  roll-out  of  decarbonised 
heating sources and to improve the provision and acquisition of green skills.  

The  REPowerEU  Chapter  includes  an  extensive  set  of  mutually  reinforcing  reforms  and 
investments that contribute to effectively addressing a significant subset of Denmark’s economic 
and social challenges outlined in the country-specific recommendations addressed to Denmark by 
the Council in the context of the European Semester, notably reducing reliance on fossil fuels and 
increasing  the  share  of  renewables  in  the  energy  supply,  streamlining  the  applicable  permit-
granting rules for renewable, implementing additional measures that support energy efficiency in 
private and public buildings to reduce energy bills and energy system costs, ensuring a better roll-
out  of decarbonised heating  sources, and stepping up policy efforts aimed at  the provision  and 
acquisition of skills and competences needed for the green transition.  

The  REPowerEU  chapter  makes  significant  contributions  to  addressing  the  horizontal 
recommendation to “expand public investment for the green and digital transitions, and for energy 
security taking into account the REPowerEU initiative, including by making use of the Recovery 
and Resilience Facility and other Union funds.” (CSR 2022.1.2). The investments included in the 
chapter all contribute to the green transition, by expanding the use of renewable energy, investing 
in green technologies for industry decarbonisation such as Carbon Capture and Storage of biogenic 
and  atmospheric  CO2,  and  preparing  the  labour  force  to  adapt  for  the  challenges  of  the  green 
transition  through  green  upskilling.  The  scaled-up  measure  on  replacing  oil  burners  and  gas 
furnaces also contributes to energy security by replacing fossil fuels machinery with renewable or 
green sources of energy.  

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).  All  investments  under  the 
Renewable  energy  measure  contribute  to  “reduc[ing]  overall  reliance  on  fossil  fuels”  (CSR 
2022.4.1  and  CSR  2023.4)  and  “help[ing]  decarbonise  the  economy  by  accelerating  the 

9 

 
 
 
 
 
 
deployment  of  renewables  including  by  introducing  reforms  to  simplify  and  expedite 
administrative  and  permitting  procedures”  (CSR  2022.4.2).  The  National  Energy  Crisis  Staff 
(NEKST)  reform  is  expected  to  significantly  reduce  administrative  burdens  and  simplify 
permitting procedures for the deployment of renewable energy on land and for transitioning from 
gas  to  green  sources  of  heating.  Both  NEKST  and  the  scaled-up  measure  providing  a  support 
scheme for replacing oil burners and gas furnaces with district heating from renewable sources or 
electric heat pumps contribute to “improving energy efficiency” (CSR 2022.4.4) and “ensur[ing] 
a better roll-out of decarbonised heating sources” (CSR 2023.4). The measure on green upskilling 
is also expected to contribute to stepping up policy efforts aimed at the “provision and acquisition 
of skills and competences needed for the green transition” (CSR 2023.4). 

*** 

The nature and extent of the proposed modifications to Denmark’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 Denmark, as reflected in the previous SWD (SWD(2021)154). 

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  

Strengthening the growth potential, job creation, and economic, social and institutional resilience 
of the Member State: 

The REPowerEU chapter is expected to contribute positively to GDP growth and stimulate job 
creation  through  the  simplification  of  administrative  permitting  procedures  and  investments  in 
deployment of renewable energy projects, green heating solutions and CCUS technologies. Over 
the medium to longer term the investment in green upskilling will help improve productivity and 
competitiveness  and  ensure  business  have  access  to  the  necessary  competences  for  the  green 
transition.  The  measures  are  expected  to  reinforce  the  resilience  of  Denmark  by  further 
diversifying the energy supply and enhancing green skills to make Denmark better prepared for 
future crises.  

Overall, as the additional measures under the REPowerEU chapter represent EUR 197 million and 
amount to less than 15% of the envelope of the original RRP, the additional positive economic 
impact is expected to be limited.   

Contributing to the implementation of the European Pillar of Social Rights, including through the 
promotion of policies for children and youth: 

10 

 
 
 
 
 
 
 
The inclusion of a measure on green upskilling, which targets continuous VET and labour market 
training providers, contributes to the implementation of the European Pillar of Social Rights. It 
contributes to the principle of active support to employment and education, training and life-long 
learning. While the original  RRP contributed to  job creation and strengthening  of digital  skills 
through the Digital Strategy, the REPowerEU measure on green upskilling has a strong focus on 
continued  education  and  focused  and  dedicated  upskilling  and  on  helping  the  labour  market 
increase its resilience through the green transition.   

Mitigating  the  economic  and  social  impact  of  the  COVID-19  crisis,  thereby  enhancing  the 
economic, social and territorial cohesion and convergence within the Union: 

The REPowerEU chapter does not make additional contributions to mitigating the economic and 
social impact of the COVID-19 crisis.  

*** 

The nature and extent of the proposed modifications to Denmark’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 SWD(2021) 154. 

3.4. The principle of ‘do no significant harm’  

The modified Danish plan including REPowerEU chapter is expected to continue to ensure that no 
measure included does significant harm to environmental objectives under the RRF Regulation 
(2021/C 58/01). Denmark provided an adequate Do No Significant Harm (DNSH) assessment of 
all new reforms and investments included in component 8 (REPowerEU chapter).  

The DNSH assessment was performed in line with the methodology set out in the Commission´s 
technical  guidance  on  the  application  of  DNSH  under  the  RRF  Regulation  (2021/C58/01).  It 
covers  the  six  environmental  objectives  applying  a  two-step  approach.  The  first  step  assesses 
whether there is a risk that a measure could do significant harm to one or more of the environmental 
objectives.  When  there  is  no  risk  of  significant  harm,  the  measure  assessed  complies  with  the 
objective  of  the  Regulation.  When  a  risk  of  significant  harm  is  identified,  a  more  detailed 
assessment follows in step two, in which Denmark demonstrates the absence of significant harm.  

For the measures on renewable energy of Component 8 – REPowerEU, Denmark has provided 
comprehensive reassurances as to the DNSH compliance of the one reform and three investments. 
As  to  the  reform  related  to  the  deliverables  of  a  National  Energy  Crisis  Staff  (NEKST),  this 
measure does no significant harm to environmental objectives within the meaning of Article 17 of 
Regulation (EU) 2020/852 of the European Parliament and of the Council (the principle of ‘do no 
significant harm’). The measure has been specifically conceived to accelerate the deployment of 
renewable energy and reduce overall reliance on fossil fuels. This DNSH compliance assessment 

11 

 
 
 
 
 
holds true also for the three investment sub-measures on, respectively: 1) the preparation of tenders 
for 4 Gigawatt of offshore wind; 2) the screening of Denmark’s offshore wind capacity; 3) the 
commissioning  of  experimental  wind  turbines.  While  Denmark  acknowledged  that  the  three 
investments above are expected to have minor negative effects on marine resources, these effects 
are not assessed to be detrimental to the good status or the good ecological potential of bodies of 
water, including surface water and groundwater, or to the good environmental status of marine 
waters. An environmental impact assessment (EIA) is performed before installing a wind turbine 
and Denmark enforces strict environmental requirements.  

The measure on Carbon Capture and Storage (CCS) of Component 8 – REPowerEU is a qualitative 
upscale of a measure under Component 3 - Energy Efficiency, Green Heating and Carbon Capture 
and  Storage  of  the  original  RRP.  During  the  original  DNSH  assessment  process,  Denmark 
provided a detailed assessment for three of the six environmental objectives and confirmed that 
the measure will not lead to new oil/hydrocarbon extraction and that it will achieve compliance 
with the CCS Directive.  Given the qualitative nature of the upscale, a new and complementary 
DNSH self-assessment has been requested to Denmark. 

Denmark also assured that the scheme targets existing sources of biogenic and atmospheric CO2 
emissions and as such is not foreseen to lead to significant inefficiencies in direct and indirect use 
of natural resources. Furthermore, CO2-storage activities will take place in depleted gas and oil 
fields and/or aquifers in accordance with the safety requirements of the CCS Directive (Directive 
2009/31/EC), with extensive EIAs conducted for each CO2 store. 

This  quantitative  scale  up  of  a  measure  related  to  Replacing  Oil  Burners  and  Gas  Furnaces 
includes support schemes for households to  switch from  fossil-fuelled heating to green heating 
sources, such as heat-pumps and district heating from renewable sources. The original measure is 
included in Component 3 - Energy Efficiency, Green Heating and Carbon Capture and Storage of 
the original RRP, and its DNSH compliance was positively assessed. Denmark confirms that the 
‘replacement of oil burners and gas furnaces’ in terms of effects on circular economy and zero 
pollution would be aligned with the standards set out in the EU taxonomy Climate Delegated Act.  

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Denmark’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 the assessment 
criterion 2.4 of Annex V of the RRF Regulation. 

3.5. Green transition 

Denmark’s modified recovery and resilience plan, including its REPowerEU chapter, is expected 
to  continue  to  significantly  contribute  to  the  green  transition,  including  biodiversity,  as  the 
amended  plan  exclusively  adds  measures  further  strengthening  the  progress  towards  the 
achievement of the Union 2030 climate targets while complying with the objective of EU climate 

12 

 
 
 
 
 
neutrality by 2050. All measures of the REPowerEU chapter will contribute to this. The NEKST 
reform  and  the  investments  in  renewable  energy  sources  as  well  as  in  green  upskilling  and 
replacement of oil burners and gas furnaces as well as in  in  carbon capture and storage are all 
expected to contribute positively to this. The measures can be expected to have a lasting impact, 
as the strengthening of green skills, replacement of oil burners and gas furnaces and mapping the 
potential for offshore wind should all have effects significantly beyond the RRF horizon. 

Climate target 

On the basis of the assessment guidelines provided for in  sub-criterion 5b, the measures in the 
modified RRP (including the REPowerEU chapter) supporting climate change objectives account 
for 65% of the plan’s total allocation (i.e. above the 37% required), based on the methodology for 
climate tracking set out in Annex VI of the RRF Regulation. The most important contribution to 
this target continues to be the green tax reform.  

Additionally, the proposed measures within the REPowerEU chapter supporting climate change 
objectives account for 100% of the chapter’s total estimated costs, based on the methodology for 
climate tracking set out in Annex VI of the RRF Regulation. The most important contributions to 
this target are the replacement of oil burners and gas furnaces and the carbon capture and storage 
measure. 

*** 

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

3.6. Digital transition 

Digital target 

The revision of the RRP only includes measures under the REPowerEU chapter, which are not 
taken into account in the contribution to digital objectives. No measure under the REPowerEU 
chapter has a distinct digital component. 

*** 

The nature and extent of the proposed modifications to Denmark’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 and to the digital target, as reflected in the previous SWD SWD(2021) 154. 

13 

 
 
 
 
 
 
3.7. Lasting impact of the plan 

The modified plan will continue to have a lasting impact on Denmark beyond the timeframe of the 
Recovery and Resilience Facility. The REPowerEU chapter will contribute to the green transition, 
with the aim to contribute to the reduction of greenhouse gas emissions and to increase the share 
of renewables in the Danish energy mix. With the upscaling of the measure relating to replacing 
oil burners and gas furnaces, the plan can be expected to durably reduce greenhouse gas emissions 
of households and boost the shift from fossil fuels to more sustainable heating sources. Several of 
the sub-measures included in the Renewable Energy measure durably support the green transition 
beyond the timeline of the RRP. For example, the screening of the offshore wind capacity sub-
measure will lay the groundwork for Denmark to contribute to the EU’s ambitious target of 300 
GW  of  offshore  wind  by  2050.  The  reform  aiming  to  simplify  and  shorten  administrative 
procedures also improves the framework conditions for the uptake of renewables. In addition, the 
green upskilling measure strengthens the labour force’s ability to support the green transition, with 
skills that will be used beyond the timeframe of the instrument. 

The measures put forward by Denmark in its addendum are unlikely to have direct effects on the 
Danish budget beyond the timeframe of the plan. 

The relevant stakeholders are included in the implementation of the measures. Industry participants 
will be at the centre of implementation of the calls for CCS and experimental wind turbines. The 
relevant providers of vocational education and training will develop courses on green upskilling, 
in  line  with  the  observed  skills  gap  they  observe.  The  reform’s  working  group  NEKST  is 
comprised of  stakeholders at  all levels  of government,  civil  society, members of academia and 
private actors, all tasked with identifying and solving bottlenecks in relation to energy projects. 
With this collaborative approach, the reform has the potential to change the way administration is 
reviewed and revised. 

*** 

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

3.8. Milestones, targets, monitoring and implementation 

(i) the adequacy of the RRP’s implementation structure, arrangements for the monitoring of 
progress and reporting (incl. record-keeping)  

The implementation structure and arrangements for the monitoring of progress and reporting are 
not changed by the addition of the REPowerEU chapter. These arrangements are described in the 
original plan and were positively assessed in SWD(2021)154.  

(ii) the quality of the new or modified milestones, targets (in particular whether these are 
clear, relevant, acceptable and robust) and related indicators 

14 

 
 
 
 
 
The  milestones  and  targets  of  the  modified  plan  enable  adequate  monitoring  of  the  plan’s 
implementation. The original plan included 39 milestones and 38 targets. With the REPowerEU 
chapter, an additional 7 milestones and 7 targets are included in the modified plan, for a total of 
46 milestones and 45 targets. The overall number of milestones and targets remains balanced and 
manageable. 

The  milestones  and  targets  in  the  plan  are  clear  and  realistic.  The  milestones  and  targets 
appropriately  reflect  the  different  stages  of  implementation  of  the  reform  and  investments.  For 
most measures, initial milestones lay the groundwork for the implementation while one or more 
final output targets appropriately and realistically measure whether the objective of the measure 
has  been  achieved.  The  milestones  and  targets  are  therefore  consistent  with  the  long-term 
objectives of the measures. 

(iii)  the  overall  organisational  arrangements  with  a  focus  on  the  lead  body/bodies  for  the 
implementation  of  the  plan  (incl.  elements  related  to  the  necessary  legal  mandate  and 
necessary staff) 

The  administrative  arrangements  for  the  implementation  of  the  plan  are  not  changed  by  the 
addition of the REPowerEU chapter. These arrangements are described in the original plan and 
were positively assessed in SWD(2021)154.  

*** 

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

3.9. Costing 

Denmark  has  provided  cost  estimates  for  the  different  reform  and  investment  measures  in  the 
REPowerEU chapter except for the investment measures on the decoupling scheme and the district 
heating pool to replace oil burners and gas furnaces intended to scale up a similar measure in the 
original  RRP.  All  measures  are  implemented  after  1  February  2022  and  the  relevant  actions 
relating to their implementation are expected to be carried out by 31 August 2026 at the very latest.  

The  cost  breakdown  is  well  detailed.  The  tables  proposed  in  the  standard  template  were  duly 
completed and presented. The cost estimates were not validated by an independent public body 
such as a national productivity board or an independent fiscal institution. The assessment of the 
cost estimates and the supporting documents demonstrates that most of the costs are well justified, 
reasonable and plausible.  

Reasonable costs 

Denmark  provided  detailed  explanations  to  justify  the  reasonability  of  the  cost  estimates.  The 
analysis  of  supporting  evidence  is  not  consistent  throughout  the  chapter  and  cost  estimates  are 

15 

 
 
 
 
 
 
based on a variety of methods, including the use of unit prices, reference costs and market costs 
for the costing of the renewable measure, cost simulations for different technologies for the CCUS 
and reference costs for similar past schemes for the green upskilling measure. Nevertheless, there 
is no evidence that would give rise to doubt as to the costing estimates provided. It is therefore 
deemed that the reasonability of the cost estimates is fairly well established. 

Plausible costs 

Denmark used reference costs (with adjustments where needed) to justify the plausibility of its 
cost estimates. The analysis of the supporting evidence is not consistent throughout the plan. For 
measures where similar investment measures existed in the past, historical or comparative data for 
the key cost drivers were typically provided. For novel projects without past precedent (such as 
the  investment  in  testing  of  wind  turbines  and  the  investment  in  Carbon  Capture  Storage), 
Denmark argued that no comparative cost estimates can be provided. 

Considering the limitations of an ex-ante assessment of cost estimates, the amounts proposed for 
financing  were  deemed  appropriate  and  the  plausibility  of  the  cost  estimates  is  fairly  well 
established. 

No double Union financing 

According to the Danish authorities, the measures included in the REPowerEU chapter  are not 
benefitting from other EU funding. Any financing that was allocated for the measures before the 
REPowerEU chapter was solely national funding.  

The  Danish  authorities  also  informed  that  there  are  no  additions  or  changes  to  the  existing 
procedures and organizational set-up at national level to prevent double funding described in the 
original  RRP. Consequently, the description in  the original  plan of the governance and  control 
systems to prevent double funding remains valid also for the modified plan. 

There  are  possible  synergies  with  initiatives  under  the  ESF+  facility  with  regard  to  green 
upskilling, ERDF with regard to Carbon Capture and Storage and with the Just Transition Fund 
both in the area of Carbon Capture and Storage and of green upskilling. 

Commensurate and cost-efficient costs  

The REPowerEU chapter is expected to effectively help address the challenges identified in the 
CSRs for Denmark. Moreover, the plan contains investments and reforms to accelerate the green 
transition. The measures will contribute positively to growth potential and productivity, stimulate 
job creation and mitigate the adverse effects of the energy crisis. 

*** 

16 

 
 
 
 
 
 
 
 
The justification provided by Denmark 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.  

Denmark provided sufficient information and evidence that the amount of the estimated cost of 
the reforms and investments of the modified recovery and resilience plan to be financed under the 
Facility is not covered by existing or planned Union financing. 

This  would  warrant  a  rating  of  B  under  the  assessment  criterion  2.9  of  Annex  V  to  the  RRF 
Regulation. 

3.10. 

Controls and audit  

Robustness of internal control system and distribution of roles and responsibilities  

The internal control system described in the original assessment remains in force and applies to all 
measures. The outline of the Danish organizational structure with relevant actors involved, their 
roles and functions are defined. The Danish set-up consists of two levels for audit and control. The 
first,  central  level  is  additional  to  the  already  existing  audit  and  control  mechanisms  and 
encompasses audit and control work performed at the second, decentralized level. In addition to 
these two levels, the Danish RRF internal control system closely cooperates with other national 
authorities, such as the National Audit Office, the Danish Ombudsman, the Danish Data Protection 
Agency, and the whistle-blower functions in all line ministries. 

The role of Ministry of Finance is two-folded. While the Centre for Climate, Green Economy and 
the EU (Coordinating body) is responsible for the coordinating and monitoring the implementation 
of the RRP, the Office for Audit and Supervision (Audit body) oversees audit and control matters. 
This involves coordinating and ensuring that the audits and controls in the line ministries related 
to the RRP implementation are sound and well-functioning as well as performing controls on the 
line  ministries’  applications  for  funds  and  the  supporting  documentation  proving  a  satisfactory 
fulfilment of targets and milestones.   

As each line ministry is responsible for ensuring sufficient audit and control on the completion of 
the  milestones  and  targets,  they  have  the  flexibility  to  design  their  audit  and  control  set-ups 
individually. For that reason, the Audit body carries out an individual assessment of each set-up 
and conducts both, audits on the line ministry’s system and audits on the achievement of milestones 
and targets. The Commission’s audit work carried out so far indicated several deficiencies in the 
work  of  the  Audit  body  which  were  effectively  addressed  by  preparing  an  audit  manual.  In 
addition, each line ministry is obliged to prepare a sub-summary of audits based on which, the 
Audit body draws up a single summary of audits to be submitted to the Commission together with 
a request for payment.  

The system  presents  a  multi-stage process  and  structure, where the audit  and control roles and 
responsibilities are predominantly defined, and the relevant control functions are chiefly assigned. 

17 

 
 
 
 
 
 
Adequacy of control systems and other relevant arrangements  

The initial  RRP does not  include any milestones on audit and control, and states that there are 
procedures  in  place to  ensure compliance  with  applicable Union  and national  laws. To receive 
funding from the RRF, the line ministries shall put in place an internal control system in order to 
ensure that the funds are used in line with the Financing Agreement concluded between the Danish 
government and the Commission. 

Furthermore, the Danish system aims to tackle all serious irregularities (fraud, corruption, conflict 
of  interests)  and  double  funding  by  conducting  audits  and  controls  in  all  nine  responsible  line 
ministries. Each of them issues a RRF sub-management declaration and sub-summary of audits 
which are later complied by the Ministry of Finance into a single management declaration and a 
single summary of audits. The Commission’s audit work carried out so far indicates that not all 
line ministries have anti-fraud and anti-corruption strategies in place, and hence a specific audit 
and control milestone is proposed in this regard. 

The proposed measures related to anti-fraud and anti-corruption did not give a full assurance that 
there is an adequate level of control to prevent, detect and correct irregularities identified when 
using  funds  provided  by  the  RRF  as  there  is  a  risk  of  discrepancies  between  different  line 
ministries’ audit and control set-ups in this respect.  

Due to the decentralized character of the set-up, the RRP is implemented and monitored using a 
system that is specific to each line ministry. The collected information is later sent to the Audit 
body  who  feeds  all  the  data  into  the  F2  system,  a  formal  repository  system  of  the  Ministry  of 
Finance. The Commission’s audit work carried out so far indicates that the system to collect the 
data required by Article 22(2)(d) of the RRF Regulation is not fully functional and operational, 
and hence a specific audit and control milestone is proposed in this regard. 

Adequacy of arrangements to avoid double EU funding  

The RRP takes into consideration funding from other EU funds in order to ensure complementarity 
and  to  avoid  double  funding.  This  is  done  by  sub-management  declarations  in  which  the 
management in each responsible, implementing authority pledges to be able  to document at all 
times  that  double  funding  is  prevented  and  that  all  funds  have  been  implemented  according  to 
relevant national and EU regulation.  

Funds coming from both, the RRF and additional funding (e.g., national or European funds) are 
disbursed at  the central  level  in  the Budget  Bill.  The central  distribution ensures  that the same 
applicant  cannot  receive  double  funding  for  the  same  project  as  the  disbursement  of  funds  is 
handled within the same responsible ministry and unit. Furthermore, every line ministry has to 
design its financial accounts in a way that the RRF funding is distinct from other expenditure in 
the ministry.  

In order to provide knowledge of risk and to obtain assurance specifically on the risk of double 
funding, the Audit  body performs three types of controls: (1) checking  and comparing  the line 
ministry’s budget in the Ministry of Finance to ensure that the project in the relevant line ministry 
receives funds from only one EU fund; (2) checking the annual Budget Bill under the relevant line 

18 

 
 
 
 
 
ministry to check whether they receive any other EU funds, and (3) checking the annual report for 
each relevant line ministry or agency to confirm that they did not receive funds from any other 
sources, including other sources than EU funds. 

In addition, as a new initiative to avoid double funding, the Coordinating body has integrated the 
reporting  system  for  the  requests  for  payment  with  the  process  for  the  quarterly  expenditure 
reviews that each line ministry has to submit to the Ministry of Finance as a part of the standard 
budget process. This has been achieved by a dedicated RRF appendix to the expenditure review 
format that each line ministry needs to submit to the Ministry of Finance as a part of the budget 
follow-up. 

Overall, the Danish RRF internal control system aims to avoid, detect and prevent double funding 
at all stages of the projects’ lifecycle. 

Legal empowerment and administrative capacity of control function  

The Audit body reports directly to the permanent secretary in the Ministry of Finance. The office 
has an individual description of its role and functions, in which its special independent status is 
secured. An amendment to the description of functions has been made, specifically regarding the 
new mandate regarding control with the use of RRF funds. The amendment to the description of 
function for the Audit body regarding the specific RRF mandate is approved at the government 
level. The government’s economic committee has approved the extended mandate. The Audit body 
currently consists of a chief auditor with 15 years of experience from internal audits in the Ministry 
of  Finance.  Additionally,  the  OAS  has  eight  highly  experienced  employees  of  which  four  is 
specialized in auditing, two in cyber security, one in legal affairs, and one in financial affairs. Each 
of the employees in  the  office has more than 15  years of experience. All  the employees in  the 
office are continuously trained and upskilled. Nevertheless, there is an insufficient number of staff 
dedicated to the RRF audit work as for the RRF audits to be carried out as there are currently only 
two auditors.  

Moreover, in the context of the RRF, there is no explicit indication that the line ministries hired 
and/or  will  hire  (additional)  resources  in  the  context  of  implementation  and  monitoring  of  the 
investments. 

Roles and responsibilities of the actors for audits and controls are clear, relevant control functions 
are segregated and the independence of actors performing audits is ensured. The number of staff, 
however, should be further increased to better align with the RRF related workload. 

***  

The  arrangements  proposed  by  Denmark  in  the  RRP  to  prevent,  detect  and  correct  corruption, 
fraud and conflicts of interests 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 as acceptable, provided that the above-mentioned issues are tackled at the latest by the 
time of submission of the second request for payment to the Commission. This would warrant a 
rating of A under the assessment criterion 2.10 of Annex V of the RRF Regulation. 

19 

 
 
 
 
 
Therefore, the following audit and control milestones are proposed:  

- A repository system with the complete and reliable data set collected in accordance with Article 
22(2)(d) of the RRF Regulation; 

- Adoption of an action plan related to the anti-fraud and anti-corruption strategy; 

3.11. 

Coherence 

The measures under Denmark’s REPowerEU chapter are coherent with the efforts of Denmark to 
achieve the objectives set out in Article 21c (3), taking into account the measures included in the 
original  RRP  plan,  as  well  as  other  nationally  funded  and  Union-funded  complementary  or 
accompanying  measures.  The  measures  under  the  chapter  are  aligned  with  Denmark’s  policy 
framework aimed at reducing by 70% Denmark’s greenhouse gas emissions by 2030 (compared 
to 1990 level) and at achieving climate neutrality by 2045.  

Several of the measures are also mutually reinforcing. The National Energy Crisis Staff (NEKST) 
reform is expected to help reinforce the other measures in the Renewable energy measure through 
simplified and accelerated administrative procedures. This could also help speed up other green 
investments under the original recovery and resilience plan. The upscale of the CCS measure is 
also to be seen in complement with the original measure in Component 3, as well as the research 
partnership on CCS in Component 7 of the plan. 

Several measures included in the REPowerEU chapter complement other Union-funded measures 
under the European Regional Development Fund, Just Transition Fund and the European Social 
Fund Plus, such as green upskilling and CCS. 

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

*** 

Taking into consideration the qualitative assessment of all components of Denmark’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 of the RRF Regulation. 

3.12. 

REPowerEU 

The implementation of the measures included in the Denmark’s REPowerEU chapter are expected 
to contribute to the REPowerEU objectives spelt out in Article 21c(3), points (b), (c) and (f) of the 
RRF  Regulation  (Regulation  (EU)  2023/435).  The  expected  streamlining  and  simplification  of 
administrative and permitting procedures delivered by the National Energy Crisis Staff (NEKST) 
will  contribute  to  accelerating  the  deployment  of  renewable  energy  projects  and  the 
decarbonisation  of  households’  heating,  to  boosting  energy  efficiency  in  buildings,  and  to 
addressing  energy  poverty  (objectives  b  and  c).  The  investments  on  renewable  energy,  which 
consist in tendering for 4GW of offshore wind, screening of Denmark’s offshore wind potential 

20 

 
 
 
 
 
and  commissioning  of  experimental  wind  turbines,  will  increase  the  share  and  accelerate  the 
deployment of renewable energy (objective b). The upscaled measure to replace oil burners and 
gas furnaces for heating with heat pumps and district heating from renewable sources will boost 
energy  efficiency,  increase  the  share  and  accelerate  the  deployment  of  renewable  energy,  and 
address  energy  poverty  (objectives  b  and  c).  Investments  in  Carbon  Capture  and  Storage 
technologies  will  contribute  to  decarbonising  industry  (objective  b).  The  investment  in  green 
upskilling  will  contribute  to  supporting  all  the  other  objectives  through  an  accelerated 
requalification  of  the  workforce  towards  green  and  related  digital  skills,  as  well  as  support  of 
technologies linked to the green transition (objective f). 

The measures under Denmark’s REPowerEU chapter are coherent with the efforts of Denmark to 
achieve the objectives set out in Article 21c (3), taking into account the measures included in the 
original  RRP  plan,  as  well  as  other  nationally  funded  and  Union-funded  complementary  or 
accompanying  measures.  The  measures  under  the  chapter  are  aligned  with  Denmark’s  policy 
framework aimed at reducing by 70% Denmark’s greenhouse gas emissions by 2030 (compared 
to 1990 level) and at achieving climate neutrality by 2045, as well as its ambitious commitments 
to massively upscale its offshore wind capacity, in alignment with the Esbjerg and Marienborg 
declarations it signed in 2022 and the Ostend declaration in 2023.  

Several measures included in the REPowerEU chapter complement other Union-funded measures 
under the European Regional Development Fund, Just Transition Fund and the European Social 
Fund  Plus,  such  as  green  upskilling  and  CCS.  For  both  measures,  the  other  Union  funded 
programmes have a similar aim, but a complementary focus, as the beneficiaries or the targets of 
the programmes are different. 

The inclusion of the REPowerEU chapter will further underpin the lasting impact of the Danish 
plan beyond the timeframe of the Recovery and Resilience Facility. All measures contribute to the 
green transition of Denmark. The renewable energy investments participate to durably reduce its 
reliance  on  fossil  fuels  and  promote  clean  and  renewable  sources  of  energy.  Several  of  the 
measures are forward looking, including the screening of offshore wind capacity, the testing of 
innovative wind turbines, and the development of innovative biogenic and atmospheric Carbon 
Capture  and  Storage  technologies.  In  addition,  the  reform  aiming  to  simplify  and  shorten 
administrative  processes  and  procedures  should  have  a  durable  impact  on  the  administration's 
approach  to  permitting  for  renewable  energy  on  land  and  for  the  shift  to  sustainable  heating 
sources. The two upscaled measures increase and broaden the ambitions of the original plan. These 
relate to decarbonising industry through the use of CCS technology and boosting the shift from 
fossil fuels in heating to more sustainable sources. 

In  preparation  of  the  REPowerEU  chapter,  Denmark’s  Ministry  of  Finance  launched  an  online 
public consultation portal on the dedicated webpage of the Danish Recovery and Resilience Plan. 
The Ministry also  conducted a stakeholder meeting attended by representatives of civil  society 
organisation, trade associations and confederations, interest groups and other actors. The measures 
included in the plan reflect – within the limits of the available budget and the applicable timeline 
– the suggestions made in the consultation  process regarding investments in renewable energy, 

21 

 
 
 
 
 
streamlining  of  procedures  for  renewable  energy  projects,  phasing  out  of  gas  boilers  and 
accelerating CCS. 

*** 

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

3.13. 

Cross-border or multi-country dimension or effect  

Denmark’s REPowerEU chapter contributes to securing energy supply in the Union as a whole, 
including by addressing challenges identified in the Commission’s most recent needs assessment, 
in line with the objectives set out in Article 21c(3), taking into account the financial contribution 
available to Denmark and its geographical position.  

The measures under the chapter will significantly develop national renewable energy capacity with 
cross-border effects, thus contributing to the EU’s target of 300 GW of offshore wind energy in 
Europe  before  2050.  The  REPowerEU  chapter  also  contributes  to  reducing  the  dependency  on 
fossil fuels by fostering the deployment of renewable energy projects, by supporting households 
decoupling from gas and converting to green heating solutions, and by providing operational aid 
for  the  development  of  innovative  Carbon  Capture  and  Storage  technologies  having  a  great 
potential  for  industry  decarbonisation.  Carbon  Capture  and  Storage  technology  has  significant 
cross-border potential, as the areas for such storage on Danish territory might be utilised for storing 
CO2 from international sources and as the development of the technology might be exported. 

The measures considered to have a cross-border effect account for 53% of the estimated costs of 
the REPowerEU chapter, well above the 30% target. 

REPowerEU measure 

Costs 
million) 

(EUR 

Contribution  to  the 
target in % 

Renewable energy 
Replacing oil burners and gas furnaces 

60 
45 

30% 
23% 

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-

*** 

22 

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

23 

 
 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging 

Measure/ 
Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate2 

Digital 

1.2 

2.1 

2.2 

2.3 

2.4 

2.5 

2.6 

3.1 

3.2 

Digital solutions in the health care 
sector 

2 

095 

100% 

Organic farming 

11 

027 

100% 

Organic transition of public kitchens 

Organic Innovation Centre 

Plant based organic projects 

5 

5 

3 

027 

100% 

022 

100% 

027 

100% 

Climate technologies in agriculture 

27 

022 

100% 

Carbon rich soils 

89 

027 

100% 

Replacing oil burners and gas 
furnaces 

65 

025bis 

100% 

Energy efficiency in industry 

40 

024ter 

100% 

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

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate2 

Digital 

3.3 

3.4 

3.5 

4.1.1 

4.1.2 

4.2.1 

4.2.2 

4.3 

5.1 

5.3 

5.5 

5.6 

Energy renovations in public 
buildings 

40 

026bis 

100% 

Energy efficiency in households 

63 

025bis 

100% 

CCS-storage potential 

27 

022 

100% 

Investment window – green share 

163 

027 

100% 

Investment window – digital share 

163 

010bis 

100% 

Accelerated depreciation – green 
share 

33 

027 

100% 

Accelerated depreciation – digital 
share 

69 

010 

100% 

Expert group to prepare proposals for 
a CO2e-tax 

Re-prioritisation of the registration 
tax of vehicles and low electricity tax 
on charging electric vehicles 

1 

01 

100% 

141 

074 

100% 

Development test of road-pricing 

3 

022 

100% 

Analysis of test scheme with double 
trailers 

Analysis of the regulation on weight 
and dimensions to optimise heavy 
haulage 

0,1 

022 

100% 

0,1 

022 

100% 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate2 

Digital 

5.7 

5.8 

5.9 

6.1 

6.2 

6.3 

7.1.1 

7.1.2 

7.2 

8.1.1 

8.1.2 

8.1.3 

Scheme to infrastructure for electric 
bicycles 

Investments in bike paths in state 
roads and bicycle subsidy scheme for 
municipalities 

1 

075 

100% 

70 

075 

100% 

Subsidy scheme to green ferries 

27 

074 

100% 

Digital strategy 

Broadband pool 

67 

13 

011 

100% 

053 

100% 

SME's digital transition and export 

9 

010 

100% 

Incentives to boost R&D in 
companies – green share 

Incentives to boost R&D in 
companies – digital share 

15 

022 

100% 

59 

009bis 

100% 

Research in green solutions 

94 

022 

100% 

Renewable energy - National energy 
crisis staff (NEKST) 

2,6 

028 

100% 

Renewable energy - Preparations for 
4 GW offshore wind 

13,1 

028 

100% 

Renewable energy - Screening of 
Denmark’s offshore wind capacity 

028 

100% 

6,9 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR 
m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate2 

Digital 

8.1.4 

8.2 

8.3.1 

8.3.2 

8.4 

Renewable energy - Testing of wind 
turbines 

028 

100% 

6,3 

Green upskilling pool 

27,9 

01 

100% 

Replacing oil burners and gas 
furnaces (upscaling existing 
measure) - District heating pool 

Replacing oil burners and gas 
furnaces (upscaling existing 
measure) - Decoupling scheme 

25 

025bis 

100% 

50,6 

025bis 

100% 

Carbon Capture and Storage (CSS) 
(upscaling existing measure) 

64 

027 

100% 

27