COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Germany Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10158/21 and ST 10158/21 ADD 1) on the approval of the assessment of the recovery and resilience plan for Germany
Date: 2023-11-16
Institutions: European Commission, Secretariat-General
Subjects: EU aid, Germany, digital transformation, economic recovery, economic reform, energy policy, green economy, hydrogen, investment, structural adjustment, sustainable mobility

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.11.2023  SWD(2023) 371 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Germany Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10158/21 and ST 10158/21 ADD 1) on the approval of the assessment of the recovery and resilience plan for Germany {COM(2023) 726 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 ................................................................................................ 5 

3.1.  Comprehensive and adequately balanced response to the economic and social situation ............ 5 

3.2. 

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

3.3.  Growth potential, job creation, economic, institutional and social resilience, European Pillar of 
Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence ........ 7 

3.4. 

The principle of ‘do no significant harm’ ..................................................................................... 8 

3.5.  Green transition ............................................................................................................................. 8 

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

3.7. 

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

3.8.  Milestones, targets, monitoring and implementation .................................................................. 12 

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

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

3.11.  Coherence ................................................................................................................................... 14 

ANNEX I: Climate tracking and digital tagging ........................................................................................ 16 

1 

 
 
 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

After having recovered from the COVID-19 pandemic, the German economy is currently 
showing  weak  growth  performance,  under  exceptional  economic  circumstances, 
characterised by the war of aggression against Ukraine and the need to accelerate the green 
energy transition. Russia’s war of aggression against Ukraine has led to a surge in energy and 
commodity prices in Germany as well as to a higher awareness of the need of energy security and 
autonomy. At the same time, the maximum financial contribution available for Germany under the 
Recovery and Resilience Facility (RRF) was updated on 30 June 2022 and resulted in an increased 
contribution  for  Germany.  On  15  September  2023,  Germany  submitted  a  request  to  update  its 
recovery and resilience plan. For the update of its recovery and resilience plan (RRP), Germany 
has relied on Article 18(2) of Regulation (EU) 2021/241 as the legal basis to take into account its 
updated maximum financial contribution with the aim to accelerate its green and energy transition 
and  address  its  current  challenges,  including  those  identified  in  the  country  specific 
recommendations to Germany in 2022 and 2023.  

The  update  of  German  RRP  includes  one  new  investment  and  two  scaled-up  investments  as 
follows: 

• 

Investment 1.1.6 (Federal support for efficient heat networks) is a new measure. It consists 
of a funding scheme to invest in the construction, expansion and transformation of district 
heating systems to integrate renewable energy and waste heat. 

•  Amendments to investment 1.2.1 (Support for the construction of charging infrastructure) 
in order to scale up the existing investment by adding an additional  289 000 recharging 
points in residential buildings. 

•  Amendments to investment 1.2.3 (Support for the replacement of the private vehicle fleet) 
in order to scale up the existing investment by promoting an additional 399 450 electric 
vehicles. 

Based on the assessment of the submitted modification, the German modified plan receives 
an A-rating on all criteria, except for costing, where the plan receives a B-rating (unchanged 
from the original plan assessment).  

(1) 
Balanced 
Response 

(2) 
CSRs1 

(3) 
Growth, 
jobs… 

(4) 
DNSH2 

(5) 
Green 
target 

(6) 
Digital 
target 

(7) 
Lasting 
impact 

(8) 
M & T3 

(9) 
Costing 

(10) 
Control 
Systems 

(11) 
Coherence 

A 

A 

A 

A 

A  
(47.0%) 

A 
(48.1%) 

A 

A 

B 

A 

A 

1 Country specific recommendations. 
2 Do no significant harm. 
3 Milestones and targets. 

2 

 
 
 
 
 
 
 
 
2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

2.1 The updated plan addresses Germany’s newly emerged challenges.  

In 2022, Russia’s war of aggression against Ukraine led to a surge in energy and commodity prices 
in Germany and the EU as a whole as well as to a higher awareness of the need of energy security 
and autonomy. In line with the country specific recommendations 2022.4 focusing on reducing 
overall reliance on fossil fuels and improving energy efficiency and 2023.4 focusing on energy 
efficiency  measures  in  building,  including  through  investment  in  heating  systems,  the  updated 
RRP contributes towards the decarbonisation of the heating systems. 

The new and upscaled measures add a significant additional contribution to the green transition 
pillar  by  reducing  the  reliance  on  fossil  fuels  and  increasing  energy  efficiency  and  security. 
Therefore, the RRP continues to address the main challenges identified in relevant country-specific 
recommendations. 

2.2 Overview of the new and modified components and their associated estimated costs. 

The main elements of the updated RRP are listed below by component.  

Component 1.1 Decarbonisation using renewable hydrogen in particular:  

New investment 1.1.6 Federal support for efficient heat networks: 

The investment in green district heating networks is designed to encourage the development of 
customized strategies to decarbonise and develop district heating networks. The measure consists 
of financial support to investment projects to decarbonise existing district heating systems, as well 
as investment projects for the construction of new district heating networks, expanding the share 
of heat from renewable sources and waste heat.  

Component 1.2 Climate friendly mobility 

Scaled-up investment:1.2.1 Support for the construction of charging infrastructure 

In accordance with Article 18(2) of Regulation (EU) 2021/241, Germany proposes to increase the 
ambition of this investment by increasing the target of recharging points in residential buildings 
from 400 000 in the original plan to 689 000 in the revised plan.  

Scaled-up investment:1.2.3 Support for the replacement of the private vehicle fleet 

In accordance with Article 18(2) of Regulation (EU) 2021/241, Germany proposes to increase the 
ambition of this investment by promoting an additional 399 450 vehicles under the measure.  

Table 1: New and modified components and associated costs  

Component 
1.1  Decarbonisation  using  renewable  hydrogen  in 
particular 
1.2. Climate friendly mobility 

Status 
Modified 

Modified 

Costs (EUR million) 

570  

1 820 

3 

 
 
 
 
 
 
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 
the  previous  Staff  Working 
planned 
Document (2021) 163 final/2 remains valid. 

communication 

reflected 

strategy 

as 

in 

Consultation process 

The updated RRP explains that consultations with stakeholders (Länder, social partners, welfare 
organisations,  environmental  associations,  representatives  of  civil  society)  have  taken  and  will 
continue to take place over the course of the implementation of the plan on a regular basis.  

In  preparation  of  the  updated  plan,  the  German  authorities  held  meetings  with  the  Länder  (29 
August 2023), social partners and welfare organisations (22 March 2023 and 7 July 2023) as well 
as environmental associations (26 April 2023). During these meetings the measures envisaged for 
the update of the plan were presented to the stakeholders and discussed. Individual questions were 
answered, and comments and suggestions were taken into account when finalising the measures 
for the plan. 

Feedback received during the original consultation process, most notably with regard to the need 
to invest in the expansion and transformation of district heating systems to integrate renewable 
energy and waste heat, has been considered in the new measure 1.1.6 Federal support for efficient 
heat networks. To ensure ownership by the relevant actors, it  will remain crucial to involve all 
local  authorities  and  stakeholders  concerned,  including  social  partners,  throughout  the 
implementation of the investments and reforms included in the updated RRP. 

State aid 

State aid and competition rules fully apply to the measures funded by the Recovery and Resilience 
Facility. Union funds channelled through the authorities of Member States, like the RRF funds, 
become State resources and can constitute State aid. When this is the case and State aid is present, 
these measures must be notified and approved by the Commission before Member States can grant 
the aid, unless those measures are covered by an existing aid scheme or comply with the applicable 
conditions of a block exemption regulation, in particular the General Block Exemption Regulation 
(GBER) declaring certain categories of aid compatible with the internal market in application of 
Articles 107 and 108 TFEU4. 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 
Germany in the recovery and resilience plan cannot be deemed a State aid notification. In as far as 

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

4 

 
 
 
 
 
 
Germany 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 Germany 
to ensure full compliance with the applicable rules. 

3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

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

situation  

The modifications to Germany’s RRP do not change, and rather confirm and strengthen the 
previous assessment that the RRP is a comprehensive and adequately balanced response to 
the economic and social situation. With the modifications, Germany does not remove nor reduce 
any  investment  or  reform  but  reinforces  two  existing  investments  and  adds  one  additional 
investment  contributing  to  the  first  pillar,  green  transition.  The  updated  RRP  still  covers  in  a 
comprehensive manner the six pillars structuring the scope of application of the Facility (Article 
3 of Regulation (EU) 2021/241), namely: (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 
German plan’s components towards the six pillars is summarised in Table 2. All pillars are covered 
by at least one component, while a component may contribute to several pillars. 

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

Green 
transition 

Digital 
transition 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutional 
resilience 
○ 

Policies for 
the next 
generation 

Components  

1.1. Decarbonisation using 
renewable hydrogen in particular 

1.2. Climate-friendly mobility 

1.3. Climate-friendly renovation 
and construction 

2.1. Data as the raw material of the 
future 

2.2. Digitalisation of the economy 

3.1. Digitalisation of education 

4.1. Strengthening social inclusion 

5.1. Strengthening a pandemic-
resilient healthcare system 

6.1. Modern public administration 

6.2. Reducing barriers to 
investment 

● 

● 

● 

○ 

○ 

○ 

● 

● 
● 

○ 

● 

● 

○ 

● 

● 

○ 

● 

○ 
● 

○ 

● 

○ 

○ 

Key:  

‘●’ investments and reforms of the component significantly contribute to the pillar;  
‘○’ the component partially contributes to the pillar. 

5 

○ 

○ 
● 

● 

○ 

○ 

● 

○ 

○ 
○ 

● 

● 

○ 

○ 
● 

● 

○ 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Green transition 

Germany’s  updated  plan  focuses  significantly  on  supporting  the  green  transition,  with  three 
components dedicated to this pillar and three other components also contributing. Modifications 
of both new and scaled-up measures increase the contribution of the revised plan to this pillar. The 
climate contribution now stands at 47.0%, compared to 42.4% in the original plan, that was already 
above the target of 37%. 

Digital transformation  

The  digital  transformation  still  represents  a  significant  part  of  Germany’s  updated  plan.  The 
updated  RRP  continues  to  significantly  contribute  to  promoting  the  digital  transformation  in  a 
variety  of  areas,  including  public  administration  and  public  services,  private  sector,  education, 
research  and  innovation,  health.  The  increased  importance  of  measures  without  digital  aspects 
have reduced the contribution of the updated plan to the digital pillar from 52.6% in the original 
plan to 48.1%, yet this remains more than double the target of 20%. 

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not  have a material impact  on the previous  assessment  (rating  of  A)  and the modified  plan 
represents  a  comprehensive  and  adequately  balanced  response  to  the  economic  and  social 
situation, thereby contributing appropriately to all six pillars referred to in Article 3 of the RRF 
Regulation, taking the specific challenges and the financial allocation of Germany into account. 

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

The modifications to  Germany’s RRP confirm  and strengthen the previous assessment that the 
RRP  is  contributing  to  effectively  addressing  all  or  a  significant  subset  of  the  country-specific 
recommendations addressed to Germany. As the maximum financial contribution for Germany has 
been adjusted upwards, all 2022 and 2023 country-specific recommendations are considered in the 
overall assessment.  

Notably, the updated plan contributes to addressing the country-specific recommendations 2023.4 
and 2022.4 to step up energy efficiency measures in buildings. It does so through investments in 
new  and  existing  heating  systems  and  by  funding  feasibility  studies  and  transformation  plans, 
which enable operators of district heating networks to develop long-term strategies to decarbonise. 
The  scheme  provides  investment  aid  for  district  heating  networks,  renewable  heat  generation 
facilities and measures needed to integrate renewable heat and waste heat, including efficiency 
measures  and  storage  units,  and  incentivises  the  implementation  of  decarbonisation  strategies. 
Efficient district heating can contribute to reducing emissions and boosting energy efficiency in 
the  energy,  industry  and  buildings  sector.  The  measure  is  in  line  with  the  country-specific 
recommendations to step up efforts to save energy and substitute fossil fuels.  

In line with the country-specific recommendations 2022.4 focusing on reducing overall reliance 
on fossil fuels and improving energy efficiency and country-specific recommendation 2023.4 to 
step  up  energy  efficiency  in  the  transport  sector,  the  updated  plan  makes  a  sizeable  effort  to 

6 

 
 
 
 
 
accelerate  investments  in  climate-friendly  mobility.  The  original  RRP  contains  measures  to 
promote  the  sale  of  electric  vehicles,  supporting  battery–electric  vehicles.  This  effort  was 
complemented  by  support  for  the  construction  of  charging  infrastructure.  The  updated  plan 
includes a scale up of the measures 1.2.1 “Support for the construction of charging infrastructure” 
and  1.2.3  “Support  for  the  replacement  of  the  private  vehicle  fleet“.  The  measures  under 
component 1.2 Climate-friendly mobility are expected to support Germany in reaching its GHG 
emission  reduction  targets  in  the  transport  sector.  The  support  scheme  for  e-vehicles  (1.2.3)  is 
expected to directly boost demand for these types of passenger cars by means of targeted support, 
while measure 1.2.1 is expected to improve the necessary charging infrastructure. 

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not  have a material impact  on the previous  assessment  (rating  of  A)  and the modified plan 
contributes 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 Germany. 

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

As  part  of  the  modification  of  the  RRP,  Germany  has  reinforced  support  for  the  charging 
infrastructure  and  replacement  of  the  private  vehicle  fleet  and  committed  to  a  new  measure 
expanding district heating. All modifications contribute to reducing reliance on fossil fuels and 
considering  the  geopolitical  concerns  regarding  the  availability  of  fossil  fuel  sources,  this  also 
contributes to increasing the socio-economic resilience of Germany. 

Stylised  simulations  by  the  Commission  services  estimate  that  the  updated  RRP,  including  the 
increased  financial  contribution,  together  with  the  rest  of  measures  of  the  European  Union 
Recovery Instrument, have the potential to increase the GDP of Germany by between 0.4 % and 
0.8% by 2025, not explicitly including the possible positive impact of structural reforms. 

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) and the modified plan does 
not  alter  the  plan’s  impact  on  the  growth  potential,  job  creation,  and  economic,  social  and 
institutional resilience of Germany, 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.  

7 

 
 
 
 
 
3.4. The principle of ‘do no significant harm’  

Germany has submitted two scaled up measures, one related to the support to electric vehicles and 
one  related  to  charging  infrastructure  for  electric  vehicles  that  have  already  been  assessed  as 
compliant with the do-no-significant-harm principle under the original RRP. In fact, the ambition 
of the measures supporting electric vehicles has increased by restricting the scope of the measure 
to purely electric vehicles as per the new funding guidelines from 17 November 2022 and entering 
into force as of 1 January 20235.  

In  addition,  a  new  measure  has  been  submitted  that  provides  support  for  green  district  heating 
systems. The measure does not provide support to heat sources using fossil fuels and focuses on 
the integration of waste heat and renewable heat sources, such as thermal solar, heat pumps and 
sustainable biomass. New green district heating networks have to be supported by at least 75% 
renewable energy sources and waste heat, an ambition that goes beyond the definition of “efficient 
district heating systems” as set out in Article 2(41) of the Energy Efficiency Directive. Beyond 
this, the measure has been assigned a 100% climate coefficient under Intervention Field 034bis0 
in accordance with the methodology set out in Annex VI to the RRF Regulation.  

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Germany’s modified recovery and 
resilience plan is expected to do a significant harm to environmental objectives within the meaning 
of Article 17 of Regulation (EU) No 2020/852 (the principle of ‘do no significant harm’). This 
would warrant a rating of A under criterion 2.4 of Annex V to the RRF Regulation.” 

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

3.5. Green transition  

The updated plan continues to fulfil the elements corresponding to the assessment criterion 2.5 of 
Annex V to the RRF Regulation6. The updated plan continues to contain measures that effectively 
contribute to the green transition, notably the climate change objectives.  

The  modified  measures  aid  emission  reduction  and  improve  the  sustainability  in  the  transport 
sector  through  the  timely  deployment  of  zero-emission  vehicles  and  electric  charging 
infrastructure.  The  measure  on  federal  funding  for  efficient  heating  networks  aids  emission 
reduction  in  the  heating  and  cooling  sector  through  enabling  the  replacement  of  higher-carbon 
alternatives, notably coal cogeneration plants, with heat from renewable sources and waste heat, 

5 BAnz AT 09.12.2022 B1. 
6 Regulation (EU) 2021/241. 

8 

 
 
 
 
 
 
 
 
 
 
and  through  decarbonising  and  expanding  district  heating  and  systems,  thus  increasing  the 
sustainability of energy infrastructure.7 The modified elements have indirect positive effects on 
biodiversity  through  decreasing  the  emission  of  air  pollutants  both  in  the  transport  and  in  the 
heating and cooling sectors and through their contribution to climate change mitigation. 

In accordance with Article 17 of Regulation (EU) 2021/241, the updated RRP is consistent with 
the information included in the National Energy and Climate Plan 2021-2030 (NECP). The federal 
funding programme for efficient heating networks is explicitly mentioned in the NECP8 and aims 
to contribute to achieving net-zero greenhouse gas emissions in the heating and cooling sector as 
well as related sectors (building and industry) by 2045 as well as interim targets in the NECP and 
the targets in Articles 23 and 24 of the revised Renewable Energy Directive9.  

In its recovery and resilience plan, Germany provides a table indicating for each measure whether 
it contributes 0%, 40% or 100% to climate change or environmental objectives. Germany indicated 
that the current climate and digital tracking should continue to apply to modified measures and 
provided an additional table as well as justification for the new measure on federal funding for 
efficient  heating  networks.  The  climate  tracking  of  the  modified  elements  at  100%,  have  been 
assessed  by  the  Commission  as  having  been  correctly  assigned  in  accordance  with  the 
methodology set out in Annex VI to the RRF Regulation (see also Annex 1 on climate tracking 
and  digital  tagging).  Thereby,  the  climate  contribution  of  the  plan  increases  from  the  original 
42.4% to 47.0%.  

Table 3: Climate contribution per component  

Component 

Total 
cost 

Climate 
related 

(EUR million) 

Climate contribution 

(% of cost of 
component) 

(% of non-
repayable 
allocation) 

1.1 Decarbonisation using renewable 
hydrogen in particular 
1.2 Climate-friendly mobility 
1.3 Climate-friendly renovation and 
construction 
2.1 Data as the raw material of the 
future 
2.2 Digitalisation of the economy 
3.1 Digitalisation of education 
4.1 Strengthening social inclusion 

3 708 
7 149 

2 574 

2 684 
3 019 
1 206 
1 174 

3 708 
6 326 

100.0% 
88.5% 

2 523 

98.0% 

150 
460 
0 
0 

5.6% 
15.2% 
0.0% 
0.0% 

13.2% 
22.6% 

9.0% 

0.5% 
1.6% 
0.0% 
0.0% 

7  As  supporting  evidence  to  the  submission  of  the  modified  plan,  Germany  provided  a  scientific  study  on  the 
envisioned district heating measure. As about three-quarters of district heating production is attributable to the direct 
use of fossil fuels, in particular coal and gas power plants, and renewable energies for district heating are more costly 
than fossil fuel alternatives (scientific study on district heating, p. 6), the investments envisioned under this measure 
can be expected to make a targeted contribution to decarbonisation. 
8 German Integrated National Energy and Climate Plan (2019), p. 44. 
9 Renewable Energy Directive (2018/2001/EU). 

9 

 
 
 
 
 
 
Component 

Total 
cost 

Climate 
related 

(EUR million) 

Climate contribution 

(% of cost of 
component) 

(% of non-
repayable 
allocation) 

5.1 Strengthening of a pandemic-
4 275 
resilient healthcare system 
2 920 
6.1 Modern public administration 
42 
6.2 Reduction of barriers to investment 
28 750 
Total 
Note: The table shows the cost of the components without VAT. For some measures Germany indicated that the 
gross costs may include VAT, which for this table was deducted assuming that the full VAT rate of 19% applies. 
This results in a potentially lower estimate for the measure cost without VAT. Reflecting this, the contribution to 
climate purposes is estimated to be at least 47.0%. For further details, please see the tagging at measure level in 
Annex 1.  

0 
0 
0 
13 167 

0.0% 
0.0% 
0.0% 
45.8% 

0.0% 
0.0% 
0.0% 
47.0% 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not  have a material impact  on the previous  assessment  (rating  of  A)  and the modified plan 
contributes to the green transition and to the climate target. 

3.6. Digital transition 

*** 

The  modified  German  RRP  continues  to  follow  the  methodology  for  digital  tagging  set  out  in 
Annex  VII  to  the  RRF  Regulation,  by  identifying  intervention  fields,  and  corresponding 
coefficients for the calculation of support to the digital objectives, for each measure (the table in 
Annex I presents the detailed application of the digital tagging methodology). It should be noted 
that the tagging and the estimated expenditure of existing measures has not been altered. On this 
basis  the  assessment  as  reflected  in  the  previous  SWD(2021)  147  final  is  maintained  for  all 
measures.  The  measures  supporting  digital  objectives  account  for  an  amount  which  represents 
48.1% of the modified RRP’s total allocation calculated in accordance with the methodology set 
out in Annex VII of that Regulation.  

Table 4 –Digital contribution per component  

Component 

1.1 Decarbonisation using renewable 
hydrogen in particular 
1.2 Climate-friendly mobility 

Total 
cost 

Digital related 

Digital contribution 

(EUR million) 

(% of cost of 
component) 

(% of non-
repayable 
allocation) 

0 
0 

0.0% 
0.0% 

0.0% 
0.0% 

3 708 
7 149 

10 

 
 
 
 
 
 
 
Component 

Total 
cost 

Digital related 

Digital contribution 

(EUR million) 

(% of cost of 
component) 

(% of non-
repayable 
allocation) 

0 

0.0% 

0.0% 

2 574 

2 684 
3 019 
1 206 
1 174 

1.3 Climate-friendly renovation and 
construction 
2.1 Data as the raw material of the 
future 
2.2 Digitalisation of the economy 
3.1 Digitalisation of education 
4.1 Strengthening social inclusion 
5.1 Strengthening of a pandemic-
resilient healthcare system 
6.1 Modern public administration 
6.2 Reduction of barriers to investment 
Total 
Note: The table shows the cost of the components without VAT. For some measures Germany indicated that the gross costs may 
include VAT, which for this table was deducted assuming that the full VAT rate of 19% applies. This results in a potentially 
lower estimate for the measure cost without VAT. Reflecting this, the digital contribution is estimated to be at least 
48.1%. For further details, please see the tagging at measure level in Annex 1.  

100.0% 
88.2% 
100.0% 
27.2% 

86.2% 
100.0% 
0.0% 
46.9% 

3 684 
2920 
0 
13 476 

4 275 
2920 
42 
28 750 

13.1% 
10.4% 
0.0% 
48.1% 

2 684 
2 664 
1 206 
319 

9.6% 
9.5% 
4.3% 
1.1% 

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) and the modified plan does 
not alter the contribution of the plan to the digital transition and to the digital target. 

3.7. Lasting impact of the plan  

The updated RRP is expected to have an additional lasting impact in particular with regard 
to the green transition. The modified RRP increases the ambition of the initial plan as a whole, 
notably, the increased support for expanding the charging infrastructure and replacing the private 
vehicle  fleet  may  increase  scale  effects  through  accelerating  the  transition.  The  expansion  of 
district heating networks results in the provision of infrastructure contributing to energy efficiency 
with a long lifetime. It aims to ensure the carbon neutrality of the heating network by 2045.  

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) and the modified plan does 
not alter the lasting impact of the measures proposed by Germany. 

*** 

11 

 
 
 
 
 
 
3.8. Milestones, targets, monitoring and implementation  

The original assessment regarding ensuring effective monitoring and implementation of the 
RRP  remains  mostly  the  same.  The  existing  monitoring  and  control  system  for  the  updated 
German RRP enables an adequate monitoring of the plan’s implementation. The structure tasked 
with the implementation, monitoring and reporting of the RRP is still in place, the coordination 
unit in the Federal Ministry of Finance and the line Ministries continue to have clearly assigned 
responsibilities  and  adequate  structure  for  implementing  the  plan,  monitoring  progress  and 
reporting.  The  overall  arrangements  proposed  by  Germany  in  terms  of  organisation  of  the 
implementation of the reforms and investments remain credible. The milestones and targets that 
accompany  the  new  and  modified  measures,  are  clear  and  the  proposed  indicators  for  those 
milestones and targets are relevant, acceptable, and robust. 

At the same time, in its audit on the protection of the financial interests of the Union (PFIU) the 
Commission found shortcomings regarding the staffing level of the coordinating body, and noted 
that  even  if  the  coordinating  body  created  an  overview  of  measure  implementation,  it  still  has 
difficulties  to  closely  monitor  and  control  the  implementing  bodies’  activities,  potentially 
emerging risks or hurdles related to the particular measures.  

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) and the modified plan does 
not  alter  the  adequacy  of  the  arrangements  proposed  by  Germany  to  ensure  the  effective 
monitoring and implementation of the plan. 

3.9. Costing  

Germany has  provided detailed information on the estimated costs for the  updated RRP, 
including  the  new  investment  measure  in  component  1.1.  The  estimated  costs  of  the  new 
investment and the scaled-up investments are reasonable and in line with the nature and type of 
the envisaged investments. Most of the calculations are clearly explained and well substantiated 
by supporting documents, allowing to identify the methodology used. 

Reasonable costs 

Germany accompanied its claims with actual data and supporting evidence for unit cost estimates, 
together with adequate explanation for the calculation methodology. Overall, the assumptions used 
by Germany to estimate the costs of the new and for the two measures where the level of required 
implementation has been increased 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.   

Plausible costs 

12 

 
 
 
 
 
 
Most  of  the  estimated  costs  of  the  new  and  the  two  measures  where  the  level  of  required 
implementation  has  been  increased  are  in  line  with  the  nature  and  the  type  of  the  envisaged 
investments. Overall, the cost estimates of the new measure and the measures where the level of 
required implementation has been increased, are assessed as plausible.  

No double funding Germany has indicated that the costs to be financed by the RRF will not be 
funded by other Union funding sources. More specifically, Germany committed to ensure that no 
double funding with other funding instruments will occur in the case of complementary actions 
are  undertaken  by  other  Funds  as  it  may  be  the  case  with  the  complementary  funding  by  the 
European Regional Development Fund (for energy efficiency measures /heat networks).   

Commensurate and cost-efficient costs 

The estimated total costs of the updated RRP are in line with the principle of cost-efficiency and 
are  commensurate  to  the  expected  national  economic  and  social  impact.  The  updated  RRP, 
including the new investment and the two up-scaled measures, is expected to effectively address a 
significant  subset  of  challenges  identified  in  the  country-specific  recommendations  (CSRs).  In 
particular  the  new  measures  and  the  up-scaled  measures  are  expected  to  address  challenges 
identified in CSRs in the field of energy and green transition, notably the modified plan addresses 
the country-specific recommendations 2023.4 and 2022.4 focusing on energy efficiency measures 
in  buildings,  including  through  investment  in  heating  systems  as  well  as  the  country-specific 
recommendation  2022.4  focusing  on  reducing  overall  reliance  on  fossil  fuels  and  improving 
energy  efficiency  and  country-specific  recommendation  2023.4  specifically  mentioning  energy 
efficiency in the transport sector.  

*** 

The justification provided by Germany 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 the cost-efficiency and is commensurate to the expected national economic and social impact.  

Germany 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 
Germany 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. 

13 

 
 
 
 
 
 
 
The modifications to the original plan as such do not affect the original assessment. However, in 
the  context  of  the  modification  of  the  German  RRP,  its  audit  and  control  system  needs  to  be 
reassessed on the basis of criteria 2.10 of Annex V of the RRF Regulation.  

Robustness of internal control system and distribution of roles and responsibilities 

The original assessment finding that the internal control system is robust, with a clear distribution 
of roles and responsibilities, and the bodies are independent in their functioning, remains the same.  

Adequacy of control systems and other relevant arrangements 

The  original  assessment  regarding  the  adequacy  of  the  control  systems  and  other  relevant 
arrangements remains mostly the same.  

Adequacy of arrangements to avoid double EU funding 

The  original  assessment  regarding  the  adequacy  of  the  control  systems  and  other  relevant 
arrangements remains mostly the same.  

Legal empowerment and administrative capacity of control function 

The  original  assessment  regarding  the  adequacy  of  the  control  systems  and  other  relevant 
arrangements remains mostly the same. 

Conclusion 

The chapter of the plan on audit and control and the additional information provided gives a rather 
complete description of the arrangements for the implementation and control of Germany’s RRP. 
The 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.  

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) and the modified plan does 
not alter the adequacy of the control and audit arrangements proposed by Germany. 

3.11. 

Coherence  

The original RRP is structured around 10 components. Within each component, the reforms and 
investments are targeted to achieve coherent objectives and their expected results reinforce each 
other. The planned actions in the different components are also coherent and complementary, with 
structural reforms accompanying planned investments in order to reinforce their impact. Further, 
there  is  consistency  and  intrinsic  complementarity  among  the  measures  from  different 
components. In order to promote greater consistency among instruments, and in particular with the 
European cohesion policy funds,  a balanced territorial  allocation of resources  was encouraged. 
The original assessment concluded that the RRP included to a high extent (Rating A) measures for 
the implementation of reforms and public investment projects that represent coherent actions. 

14 

 
 
 
 
 
The modification to the RRP concerns two of the existing components, including one new measure 
and  the  scaling  up  two  existing  measures.  The  proposed  modifications  made  to  the  existing 
components do not alter the overall coherence of the plan, considering the way the components 
are  mutually  reinforcing  and  complementary.  The  proposed  modifications  further  reinforce  the 
reduction  of  greenhouse  gas  emissions  and  promote  the  use  of  renewable  energy,  which  is 
particularly important in the context of reducing dependency on fossil fuels. The modifications do 
not have contradictory aims or possible negative effects on one another. 

*** 

The nature and extent of the proposed modifications to Germany’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) and the modified plan does 
not alter the coherence of the actions proposed by Germany. 

15 

 
 
 
 
 
 
ANNEX I: CLIMATE TRACKING AND DIGITAL TAGGING 10  

Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR m)  

Climate 

Digital 

Int. Field  Coeff.  

Int. 
Field 

Coeff.  

1.1.1.1 

1.1.1.2 

1.1.1.3 

1.1.2 

1.1.3 

1.1.4 

1.1.5 

1.1.6 

1.2.1 

1.2.2.1 

1.2.2.2 

1.2.3.1 

1.2.3.2 

1.2.4 

1.2.5 

1.2.6.1 

1.2.7.1 

1.2.7.2 

1.3.2 

Hydrogen projects within the framework 
of IPCEIs: part 1 
Hydrogen projects within the framework 
of IPCEIs: part 2 
Hydrogen projects within the framework 
of IPCEIs: part 3 
Funding programme for decarbonisation 
in industry  
Pilot scheme for climate action contracts 
based on the principle of Carbon 
Contracts for Difference  
Project-related climate protection 
research  
Flagship projects for research and 
innovation in the context of the National 
Hydrogen Strategy  
Federal support for efficient heat 
networks (BEW) 

Support for the construction of charging 
infrastructure 
Funding for the development of electro-
mobility: R & D, mobility concepts 
Funding for the development of electro-
mobility: zero-emission vehicles 
Support for the replacement of the private 
vehicle fleet: zero-emission vehicles 
Support for the replacement of the private 
vehicle fleet: hybrid vehicles. 
Extension of the initial registration period 
for granting the ten-year tax exemption 
for purely electric vehicles 
Support for purchases of buses with 
alternative propulsion 
Support to promote alternative rail 
propulsion: electric rolling stock 
Promotion of the industries involved in 
hydrogen and fuel cell applications in 
transport: part 1 
Promotion of the industries involved in 
hydrogen and fuel cell applications in 
transport: part 2 
Municipal living labs for the energy 
transition 

500 

500 

500 

449.3 

550 

50.4* 

588.2* 

022 

027 

033 

022 

027 

022 

022 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

570 

034bis0 

100% 

960.1 

42* 

21* 

2  764 

1 296 

077 

022 

n/a** 

n/a** 

n/a** 

100% 

100% 

100% 

100% 

40% 

295 

n/a** 

100% 

1  085 

na** 

100% 

182 

072bis  

100% 

229.4* 

022 

100% 

229.4* 

n/a** 

100% 

57 

025 

40% 

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

16 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Measure 
ID 

Measure/Sub-Measure Name 

1.3.3 

2.1.1.1 

2.1.1.2 

2.1.1.3 

2.1.1.4 

2.1.1.5 

2.1.1.6 

2.1.1.7 

2.1.1.8 

2.1.1.9 

2.1.1.10 

2.1.1.11 

2.1.1.12 

2.1.1.13 

2.1.2 

2.1.3.1 

2.1.3.2 

2.2.1.1 

2.2.1.2 

Building renovation: federal funding for 
energy-efficient buildings 
Innovative data policy for Germany: 
overall strategy high-performance 
computing  
Innovative data policy for Germany: ideas 
competition and piloting of data 
fiduciaries 
Innovative data policy for Germany: 
research network depersonalisation  
Innovative data policy for Germany: 
support programme anonymisation 
Innovative data policy for Germany: 
National Research Data Infrastructure 
(Nationale Forschungsdaten-
infrastruktur) and data literacy 
Innovative data policy for Germany: PhD 
programme in data sciences  
Innovative data policy for Germany: 
incentives for the after-use of data  
Innovative data policy for Germany: 
long-term competence monitoring  
Innovative data policy for Germany: data 
literacy courses for students  
Innovative data policy for Germany: 
toolbox data literacy  
Innovative data policy for Germany: 
innovation process ‘architectures, 
institutions and spaces for the data 
society’ 
Innovative data policy for Germany: 
establishment of data cooperations  
Innovative data policy for Germany: data 
literacy in the federal administration: data 
laboratories, Chief Data Scientists and 
competence building  
IPCEI microelectronics and 
communication technologies 
IPCEI Next Generation Cloud 
Infrastructure and Services (IPCEI CIS): 
emission reduction and energy efficiency 
criteria 
IPCEI Next Generation Cloud 
Infrastructure and Services (IPCEI CIS) 
Vehicle manufacturer/supply industry 
investment programme: digitalisation of 
production as a boost for productivity and 
resilience: greenhouse gas emission 
reduction or energy efficiency criteria 
Vehicle manufacturer/supply industry 
investment programme: digitalisation of 

Budget 
(EUR m)  

Climate 

Digital 

Int. Field  Coeff.  

Int. 
Field 

Coeff.  

2 500 

025bis  

100% 

21* 

45.4* 

37.8* 

25.2* 

50.4* 

5.5* 

4.2* 

8.0* 

8.8* 

8.4* 

6.7* 

11.3* 

200.8* 

1 500 

375 

055bis  

40% 

375 

021quat
er 

100% 

009bis 

100% 

009bis  

100% 

009bis  

100% 

108 

100% 

108 

108 

108 

108 

108 

100% 

100% 

100% 

100% 

100% 

108 

100% 

011 

100% 

108 

100% 

021quat
er 

021quat
er 

021quat
er 

100% 

100% 

100% 

650 

010ter  

40% 

010ter  

100% 

427.1 

17 

010ter  

100% 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR m)  

Climate 

Digital 

Int. Field  Coeff.  

Int. 
Field 

Coeff.  

production as a boost for productivity and 
resilience  
Vehicle manufacturer/supply industry 
investment programme: new innovative 
products as the key to vehicles and 
mobility of the future - automated driving 
Vehicle manufacturer/supply industry 
investment programme: finding joint 
solutions, building regional innovation 
clusters 
Federal programme ‘Building continuing 
education and training networks (CET 
networks)’ 
Digitalisation and Technology Research 
Centre of the Bundeswehr (dtec.bw) 
Promoting the digitalisation of rail by 
replacing conventional interlocking/fast-
track programmes to speed up the roll-out 
of the ‘Digital Rail Germany’ (SLP)’ 
Investment programme for teacher 
devices  
Education platform 
Educational centres of excellence  
Modernisation of the Federal Armed 
Forces’ educational and training facilities  
Apprenticeships support  
Digital pension overview  
Strengthening the digital and technical 
resources of the public health service  
Programme to future-proof hospitals  
European identity ecosystem  
Digitalisation of the administration – 
implementation of the Online Access Act  
Digitalisation of the administration – 
modernisation of registers 

2.2.1.3 

2.2.1.5 

2.2.2 

2.2.3 

2.2.4 

3.1.1 

3.1.2 
3.1.3 

3.1.4 

4.1.3 
4.1.5 

5.1.1 

5.1.2 
6.1.1 

6.1.2 

6.1.3 

392.67 

232.4 

31.9* 

588.2* 

 009bis  

100% 

019 

40% 

016 

40% 

009bis  

100% 

500 

070 

40% 

070 

100% 

420.2* 

529.4* 
172.3* 

84* 

725 
28.8* 

684* 

3 000 
168.1* 

2 521* 

231.1* 

012 

012 
108 

012 

099 
011 

011 

095 
011  

011 

100% 

100% 
100% 

100% 

40% 
100% 

100% 

100% 
100% 

100% 

011 

100% 

* Budget figures are rounded to hundred thousands. The table shows the cost of the measures without VAT. For most measures 
this equals the cost included in the recovery and resilience plan. However, for measures marked with an asterisk (*), Germany 
indicated that their cost may include VAT, and in this table the cost is shown while taking away the full amount of potential VAT 
for these measures (assuming that the maximum VAT rate of 19% fully applies). For the original plan in 2021 Germany submitted 
two cost estimates. Using the same categories, the amended RRP has a gross value of EUR 30 181 006 986  that includes VAT for 
some measures, while a net value of at least EUR 28 749 958 599 excludes VAT. 
** 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); a 40% climate contribution coefficient for plug-in hybrid light-
duty vehicles; and, in line with the criteria under the Taxonomy Regulation, a 100% climate coefficient for low-emission heavy-
duty vehicles. 

18