COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Belgium Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10161/21 and ST 10161/21 ADD 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Belgium
Date: 2023-11-16
Institutions: European Commission, Secretariat-General
Subjects: Belgium, EU aid, digital transformation, economic and social cohesion, economic recovery, economic reform, energy policy, green economy, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.11.2023  SWD(2023) 376 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Belgium Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10161/21 and ST 10161/21 ADD 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Belgium {COM(2023) 731 final}  
 
 
Table of contents 
1.  Executive summary ............................................................................................................................... 2 

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

2.1.  Main newly emerged challenges ................................................................................................... 3 

2.2.  Main elements of the modified RRP and REPowerEU chapter .................................................... 4 

3.  Summary of the assessment of the plan .............................................................................................. 14 

3.1.  Comprehensive and adequately balanced response to the economic and social situation .......... 14 

3.2. 

Link with country-specific recommendations and the European Semester ................................ 19 

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 ...... 21 

3.4. 

The principle of ‘do no significant harm’ ................................................................................... 21 

3.5.  Green transition ........................................................................................................................... 22 

3.6.  Digital transition ......................................................................................................................... 23 

3.7. 

Lasting impact of the plan ........................................................................................................... 24 

3.8.  Milestones, targets, monitoring and implementation .................................................................. 25 

3.9.  Costing ........................................................................................................................................ 26 

3.10.  Controls and audit.. ..................................................................................................................... 27 

3.11.  Coherence ................................................................................................................................... 28 

3.12.  REPowerEU ................................................................................................................................ 30 

3.13.  Cross-border or multi-country dimension or effect .................................................................... 31 

ANNEX I: Climate tracking and digital tagging..................................................................................... 33 

1 

 
 
 
 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY 

In 2022, Russia’s invasion of Ukraine led to a surge in energy and commodity prices in Belgium. 
Inflation remained high  and economic growth slowed sharply due to  supply  chain  bottlenecks, 
rising energy and commodity prices, and supply shortages. Belgium submitted to the Commission, 
on  20  July  2023,  a  modified  national  Recovery  and  Resilience  Plan  (RRP),  including  a 
REPowerEU chapter, with the aim of taking into account the effects of those challenges in the 
implementation of its original RRP. For the modification of its RRP, Belgium has relied on the 
following legal bases: Article 18(2) of Regulation (EU) 2021/241 (RRF Regulation) to take into 
account the updated maximum financial contribution published on 30 June 2022, and Article 21(1) 
of  the  RRF  Regulation,  requesting  the  Commission  to  make  a  proposal  to  amend  the  Council 
implementing decision considering that Belgium’s RRP is partially no longer achievable because 
of objective circumstances. Belgium has also requested loans pursuant to Article 14(2) of the RRF 
Regulation predominantly to finance its REPowerEU chapter. In addition, with a view to support 
measures  of  its  REPowerEU  chapter,  Belgium  relied  on  both:  (i)  Article  21c  of  the  RRF 
Regulation, requesting the allocation of the amount available from the Emissions Trading System 
(ETS) revenues; and, (ii) Article 21b(2), in order to use the resources transferred from the Brexit 
Adjustment Reserve (BAR) under Article 4a of Regulation (EU) 2021/1755. 

The modification submitted by Belgium affects 43 measures on the basis of Article 18(2) of the 
RRF Regulation, and 34 measures on the basis of Article 21(1) of the RRF Regulation. For some 
proposed modifications, Belgium has relied on more than one legal basis. In addition, 14 errors of 
a clerical nature that do not reflect the content of the initial RRP submitted by Belgium have been 
identified in the text of the Council Implementing Decision, and Belgium proposed corrections. 

The REPowerEU chapter submitted by Belgium includes four new reforms, 17 new investments, 
one scaled-up measure, and seven transferred measures (with or without modifications) from the 
initial RRP that increase the resilience, security and sustainability of the Union’s energy system. 
The proposed reforms range from a federal reform of the administrative appeal procedures at the 
Council of State, to regional obligations for large energy consumers in Flanders, for buildings in 
Brussels, and for wind energy infrastructure in Wallonia. The new investments focus on the energy 
renovation  of  public  buildings,  support  for  emerging  energy  technologies,  the  production  of 
renewable energy, and the development of sustainable mobility. The scaled-up measure concerns 
energy renovation subsidies in the Flemish Region. Finally, the transferred measures relate to new 
emerging energy technologies and renewable energy, as well as charging infrastructure. 

Based on the assessment of the submitted modification and the REPowerEU chapter, the Belgian 
modified  RRP  receives  an  A-rating  on  all  criteria  (including  the  two  additional  criteria  for  the 
REPowerEU  chapter),  except  for  costing  and  coherence,  where  the  plan  receives  a  B-rating 
(unchanged from the assessment of the initial RRP). 

(1) 
Balanced 
Response 

(2) 
CSRs 

(3) 
Growth, 
jobs… 

(4) 
DNSH 

(5) 
Green target 
51% 

(6) 
Digital target 
27% 

(7) 
Lasting 
impact 

(8) 
M & T 

(9) 
Costing 

(10) 
Control 
Systems 

(11) 
Cohe 
rence 

(12) 
REPower 
EU 

(13)  
Cross-
border  

A 

A 

A 

A 

A 

A 

A 

A 

B 

A 

B 

A 

A 

2 

 
 
 
 
 
2.  OBJECTIVES OF THE MODIFICATION OF THE RRP 

2.1. Main newly emerged challenges 

In 2022, Russia’s invasion of Ukraine led to a surge in energy and commodity prices in Belgium 
and the EU as a whole. Belgium’s inflation reached record highs, hitting +10.3% in 2022, and the 
Belgian government’s measures helped cushion the impact of the energy crisis on both households 
and businesses. However, economic growth slowed down, amid high energy prices and inflation. 
The  2023  Country  Report1  for  Belgium  identified  challenges  related  to  the  high  tax  burden  on 
labour, labour shortages and skills mismatches, the industry’s decarbonisation, the deployment of 
renewable  energies,  the  extensive  renovation  of  buildings,  and  skills  necessary  for  the  green 
transition, among others. The implementation of spending reviews in the RRP are expected to help 
curb  public  expenditure  and  put  public  debt  on  a  sustained  downward  trend.  In  addition,  the 
implementation of investments to support the green transition in the RRP will be key to boosting 
the energy-efficient renovation of buildings, the deployment of clean mobility and the hydrogen 
value chain. In the context of Belgium’s current challenges, the proposed revision of its RRP is 
threefold:  (i)  adding  a  new  REPowerEU  chapter  to  the  original  plan;  (ii)  modifying  existing 
measures in line with the provisions of the RRF Regulation; and, (iii) including a loan request. 

Belgium’s modified  RRP adds  a new REPowerEU chapter  pursuant  to  Article 21c of the RRF 
Regulation. It includes four new reforms and 17 new investments to deliver on the REPowerEU 
objectives, as well as the upscale of an existing measure and the transfer of seven measures from 
the initial RRP. This chapter will help advance Belgium’s green transition and help address the 
current  challenges,  in  particular  those  identified  in  the  ‘energy’  recommendations  addressed  to 
Belgium in 2022 and 2023, in the framework of the European Semester. 

Pursuant  to  Article  18(2)  of  the  RRF  Regulation,  Belgium  requested  modifications  due  to  the 
downward  revision  of  its  maximum  financial  contribution,  from  EUR 5.9  billion  to  EUR 4.5 
billion. The revision is part of the June 2022 update of the maximum financial contribution and 
reflects  Belgium’s  comparatively  better  economic  outcome  in  2020  and  2021  than  initially 
foreseen. Therefore, Belgium requested the removal or downsizing of several investments. 

Pursuant to Article 21(1) of the RRF Regulation, Belgium requested to modify existing measures 
of the RRP, considering that they were no longer achievable based on objective circumstances. 
These  include  the  need  to  factor  in  the  high  inflation  experienced  in  2022  and  supply  chain 
disruptions, impacting 16 measures. In addition, Belgium proposed to modify 11 measures due to 
unexpected legal or technical difficulties, one measure due to a failed procurement process and six 
measures in order to implement better alternatives to achieve or increase their original ambition.  

Pursuant to Article 14(2) of the RRF Regulation, Belgium requested loan support to finance six 
investments (for a total amount of EUR 264 million). Five of these measures were transferred from 
the non-repayable support of the initial RRP to a newly requested loan support, in order to cover 

1   SWD(2023) 610 final. 

3 

 
 
 
 
 
 
 
for the downward revision of Belgium’s maximum financial contribution. A new investment was 
added. Three of the six measures under loan support were included by Belgium in its REPowerEU 
chapter. 

2.2. Main elements of the modified RRP and REPowerEU chapter 

The main elements of the amended RRP and REPowerEU chapter are listed below and summarised 
in Table 1. 

AXIS 1 – CLIMATE, SUSTAINABILITY AND INNOVATION 

Component 1.1 – Renovation 
Belgium  proposes  to  remove  two  investments:  (i)  the  support  for  innovative  energy-efficient 
renovation in the Brussels-Capital Region (I-1.13); and, (ii) the renovation of public buildings in 
the Walloon Region (I-1.06), on the basis of Article 18(2) of the RRF Regulation. Belgium also 
suggests to  change the investment  part of two  measures  related to  energy subsidy schemes:  (i) 
scale-up  measure  R-1.01  of  the  Flemish  Region  under  the  REPowerEU  chapter  (additional 
EUR 51 million); and, (ii) transfer the investment part of measure R-1.03 of the German-speaking 
Community  to  the  REPowerEU  chapter.  Several  investments  in  social  and  public  building 
renovations of different federated entities were suggested to be downsized on the basis of Article 
18(2)  of  the  RRF  Regulation,  and  to  be  further  reduced  to  account  for  high  inflation  based  on 
Article 21 of the RRF Regulation. Other suggested changes are aimed at correcting clerical errors 
in the Council Implementing Decision, relating to elements mistakenly added, although they are 
not  relevant  to  any  of  the  milestones  or  targets.  Moreover,  Belgium  proposes  to  correct 
inconsistencies between the figures mentioned in the measure descriptions and the related targets 
in the Council Implementing Decision, and to specify climate tagging requirements in the measure 
descriptions  and  targets  for  the  sake  of  clarity  and  avoiding  diverging  interpretations.  Targets 
covering investments of several federated entities were suggested to be split into indicative sub-
targets to clarify what is expected from each entity to reach the overall target and which part of the 
targets is covered by a climate tagging requirement. 

Component 1.2 - Emerging energy technologies 
Belgium proposes to split the reform of the regulatory framework for the H2 and CO2 markets of 
the federal state (R-1.04) into separate reforms, following clarifications obtained on the division 
of competences in those two areas between the federal state and the regions. As a result, Belgium 
proposes one reform for the H2 markets at federal level, and regional reforms for the CO2 markets 
of the Flemish Region and Walloon Region (R-1.05 and R-1.06), on the basis of Article 21 of the 
RRF  Regulation,  as  this  is  more  conducive  to  meeting  the  objectives  of  the  RRF  Regulation. 
Belgium proposes to entirely remove the investment in renewable heat networks of the Flemish 
Region (I-1.20) and to transfer three investments (namely, I-1.19 ‘Research platform for energy 
transition’ of the French Community, and I-1.21 ‘Offshore energy island’ and ‘Backbone for H2 
and CO2, both of the federal state) to the REPowerEU chapter, with some modifications. Other 
investments (I-1.16 an I-1.17, both related to a regional industrial value chain for the hydrogen 
transition)  are  suggested  to  be  downsized,  on  the  basis  of  that  same  Article  18(2)  of  the  RRF 
Regulation, and slightly modified, under Article 21 of the RRF Regulation. 

4 

 
 
 
 
 
Component 1.3 - Climate and environment 
Belgium  proposes  modifications  based  on  Article  18(2)  of  the  RRF  Regulation,  to  reflect  a 
reduction  of  the  corresponding  maximum  financial  contribution,  and  Article  21  of  the  RRF 
Regulation,  for  several  modifications  relating  to  the  measure  Biodiversity  and  adaptation  to 
climate change of the Walloon Region (I-1.22). The main reason to suggest modifying the targets 
of  this  measure  relates  to  high  inflation.  Furthermore,  a  clerical  error  identified  in  the  Council 
Implementing  Decision  is  proposed  to  be  corrected  for  a  sub-target  on  resilient  forests.  It  is 
suggested that the measure of the Flemish Region ‘Blue Deal’ be revised to reflect a reduction in 
budget by EUR 100 million, under Article 18(2) of the RRF Regulation.  

AXIS 2 – DIGITAL TRANSFORMATION 

Component 2.1 – Cybersecurity 
Belgium proposes to make changes to two targets of the investment related to the cybersecure and 
resilient digital society projects (I-2.01). For one target, Belgium proposes to modify the technical 
means through which one of the cybersecurity projects (‘Validated Web Sites’) in the target will 
be achieved, on the basis of Article 21 of the RRF Regulation. Belgium explained that, after the 
approval of the original RRP, it discovered a better and more cost-effective alternative to achieve 
the  objective  of  the  project.  For  the  other  target,  Belgium  proposes  to  correct  clerical  errors 
identified in the Council Implementing Decision, thereby postponing the timing for the completion 
of the target by one year. 

Component 2.2 - Public Administration 
Belgium  proposes  to  modify  one  reform  based  on  Article  21  of  the  RRF  Regulation.  More 
specifically, Belgium proposes to modify the reform related to e-government for businesses (R-
2.01)  to  reflect  a  better  and  more  cost-effective  alternative  to  achieving  the  objective  of  the 
milestone.  While  not  eliminating  the  existing  forms  as  originally  envisaged  by  the  milestone, 
Belgium will achieve the same result by creating a new digitalised system (encompassing three 
online forms) to allow the creation, modification and dissolution of legal persons, through three 
online forms. The new digitalised system will be an alternative administrative channel that citizens 
can use and that all local administrations will be required to accept, making the existing forms de 
facto redundant. The change is implemented through a cooperation agreement between the federal 
and regional governments, rather than through a law, as original envisaged. This will enable the 
uniform  application  of  the  digital  solution  across  the  Federal  State  and  the  federated  entities. 
Belgium  also  proposes  modifications  to  six  investments.  Belgium  proposes  to  postpone  the 
deadline of an investment relating to the Single Digital Gateway (I-2.05 S10) to 2025, on the basis 
of Article 21 of the RRF Regulation. Belgium explains that the postponement is due to unforeseen 
difficulties in hiring the specialised staff needed to implement the measure. Belgium also proposes 
to  change  five  other  investments  on  the  basis  of  Article  18(2)  of  the  RRF  Regulation:  one  is 
removed from the RRP, one will be financed by RRF loans instead of non-repayable support, and 
three are scaled down. 

Component 2.3 - Optic Fibre, 5G and new technologies 
Firstly, Belgium proposes to make a minor modification based on Article 21 of the RRF Regulation 
to  the description of investment  ‘Coverage of white areas  by developing very high-speed fibre 

5 

 
 
 
 
 
optic networks’ (I-2.13), concerning the structure of the public-private cooperation that was set up 
for this investment. Secondly, Belgium proposes to reduce the budget allocated to the investment 
improving the connectivity of schools and business parks in Wallonia (I-2.15), based on Article 
18(2)  of  the  RRF  Regulation.  Several  targets  and  a  milestone  are  removed  accordingly,  and  a 
change is made to the name of the measure. Belgium also proposes to correct clerical errors in the 
Council Implementing Decision with respect to this investment. 

AXIS 3 - MOBILITY 

Component 3.1 - Cycling and walking infrastructure 
Belgium proposes to modify four measures in this component. Belgium proposes to reduce the 
ambition of the investment related to cycling infrastructure of the Flemish Region (I-3.01) due to 
the decreased  financial  contribution   and unexpected price increases  in  the construction sector, 
under  Article  18(2)  and  Article  21  of  the  RRF  Regulation,  respectively.  Also,  in  view  of  that 
decrease,  Belgium  proposes  to  transfer  the  investment  related  to  cycling  and  pedestrian 
infrastructure around Schuman (I-3.04) and the investment in cycling infrastructure Vélo Plus (I-
3.03b) of the federal state to the loan support, under  Article 14(2) of the RRF Regulation. On the 
back of the unexpected increases in construction prices, Belgium proposes to decrease the ambition 
of  the  investment  in  cycling  infrastructure  Vélo  Plus  of  the  Brussels-Capital  Region  (I-3.03a). 
Belgium also proposes to review the target of investment ‘Corridors Vélo’ of the Walloon Region 
(I-3.02), thereby removing from the target the cycling infrastructure financed by national funds, as 
well as addressing road safety requirements and cost increases. 

Component 3.2 - Modal shift 
Belgium proposes to remove the investment in the high service level bus of the Walloon Region, 
due to  the  decreased financial  contribution, under Article 18(2) of the RRF Regulation.  It  also 
proposes to remove the investment in the Liege tram, under Art 21 of the RRF Regulation, since 
it  received  a  proposal  for  one  of  planned  works  significantly  above  the  estimated  costs.  This 
requires BE to renogotiate the respective private-public partnership agreement. The delay caused  
by  re-negotiation  procedures  makes  it  impossible  to  meet  the  timeframe  of  the  RRF.  BE  has 
proposed instead to invest in a fleet of electric buses (I-3.20). In addition, Belgium proposes to 
revise  four  other  measures  in  this  component.  Belgium  proposes  to  reduce  the  ambition  of  the 
investment related to modal shift subsidies of the Brussels-Capital Region (I-3.14) proportionally 
to the decrease of its contribution, under Article 18(2) of the RRF Regulation. To compensate for 
that decrease, Belgium  proposes to  support one of the rail freight interventions included in  the 
investment  ‘Rail  –  efficient  network’  (I-3.10)  also  as  part  of  the  REPowerEU  chapter.  This 
intervention concerns the electrification of lines 11 and L223. To reflect the original intention and 
commitment,  Belgium  also  proposes  to  rectify  the  targets  mentioned  in  the  description  of  the 
investment  to  correct  clerical  errors  identified  in  the  Council  Implementing  Decision.  Belgium 
also proposes to clarify that the railway stations subject to the works included in investment Rail-
Accessible and multimodal railway stations’ of the Federal state (I-3.10) come from a pool of 28 
stations, identifying each one of them. Finally, Belgium proposes to postpone the deadlines of the 
investment related to the Albert-canal and the Trilogiport of the Walloon Region (I-3.11), under 
Article 21 of the RRF Regulation, due to unexpected technical implementation difficulties.  

6 

 
 
 
 
 
Component 3.3 - Greening the road transport 
Belgium proposes to revise four measures in this component. Due to price increases and supply 
chain  disruptions,  Belgium  proposes,  under  Article  21  of  the  RRF  Regulation,  to  reduce  the 
ambition of the reform in the Wallon Region to incentive the deployment of charging stations (R-
3.04),  as  well  as  the  ambition  of  the  investment  of  the  Federal  State  to  also  incentivise  the 
deployment  of charging  stations (I-3.18).  Due to the decreased financial  contribution,  Belgium 
proposes, under Article 18(2) of the RRF Regulation, to reduce the number of electric buses to be 
acquired under the investment ‘Greening of the bus fleet’ of the Brussels-Capital Region (I-3.17), 
and to remove the installation of the charging stations from this investment. Both these reductions 
will,  however,  be  compensated  in  the  REPowerEU  chapter.  As  mentioned  above,  Belgium 
proposes, under Article 21, to substitute the extension of the tram in Liege by new fleet of electric 
bus  fleet,  with  their  respective  charging  stations  and  a  new  bus  depot.  Finally,  Belgium  also 
proposes to rectify the targets mentioned in the description of the investment ‘Greening the bus 
fleet - VLA’ of the Flemish Region’ (I-3.16), to correct a clerical error identified in the Council 
Implementing Decision. 

AXIS 4 – SOCIAL AND INCLUSIVE 

Component 4.1 - Education 2.0 
Belgium proposes to change two reforms on the basis of Article 21 of the RRF Regulation. First, 
the reform of the digital education framework in Flanders (R-4.01) is proposed for modification 
due  to  the  annulment  by  the  Constitutional  Court  in  2022  of  the  initial  decree  defining  new 
educational  attainment  levels.  The  unexpected  annulment  – outside  the  control  of  the  Belgian 
authorities –  led  to  a  year’s  delay  in  adopting  the  decree  and  adjusting  the  description  of  the 
milestone in line with the ruling of the Constitutional Court. Second, it is proposed that the reform 
of  the  decree  framework  to  address  school  dropout  in  the  French  Community  (R-4.03)  be 
postponed  for  a  year  and  a  half  (end-2024)  due  to  extended  stakeholder  negotiations.  The 
investment  related  to  the  digital  equipment  of  schools  in  the  Flemish  Community  (I-4.01)  is 
downsized on the basis of Article 18(2) of the RRF Regulation. The remaining changes are of a 
clerical nature. 

Component 4.2 - Training and employment of vulnerable groups 
On the basis of Article 21 of the RRF Regulation, Belgium proposes to change a reform (R-4.05) 
and to  delay  by one year  the  adoption of  a decree to  promote the labour market  integration of 
vulnerable  groups  in  Brussels,  due  to  extended  stakeholder  negotiations.  Moreover,  one  of  the 
three  elements  of  the  reform  will  be  implemented  by  convention  rather  than  by  decree. 
Modifications to investments, proposed on the basis of Article 21 of the RRF Regulation, relate to 
the  existence  of  a  more  efficient  implementation  tool  (I-4.07)  and  unexpected  implementation 
issues (I-4.08). 

7 

 
 
 
 
 
Component 4.3 - Social infrastructure 

Belgium proposes to downsize the investment to develop public utility housing in the Walloon 
Region (I-4.12), on the basis of Article 18(2) of the RRF Regulation, and to further reduce the 
number of housing units to be built, due to inflation and increased construction costs, on the basis 
of Article 21 of the RRF Regulation. The remaining changes are of a clerical nature. 

AXIS 5 – ECONOMY OF THE FUTURE AND PRODUCTIVITY 

Component 5.1 - Training and labour market 
Belgium proposes to change two reforms on the basis of Article 21 of the RRF Regulation and 
five investments on the basis of Article 18(2) and Article 21 of the RRF Regulation, as well as to 
correct a small number of clerical errors in the Council Implementing Decision. The objectives of 
measure R-5.01 can be better achieved by using a different legal instrument as a vehicle for this 
reform. The quantitative target of 25 000 temporary long-term unemployed workers trained as part 
of measure R-5.03 cannot be achieved, given that it was based on peak temporary unemployment 
numbers in this category during the pandemic. Those numbers have since decreased substantially 
and,  therefore,  the  initial  target  is  no  longer  reachable.  For  investment  I-5.03  ‘Upgrading  of 
advanced training infrastructure’ and investment I-5.07: ‘Digital lifelong learning’ of the Walloon 
Region, Belgium proposes to reduce the ambition due to the decreased financial contribution and 
unforeseen price increases in  the construction sector,  under Article 18(2) and Article 21 of the 
RRF  Regulation,  respectively.  For  investments  I-5.04:  ‘Learning  and  career  offensive’  of  the 
Flemish Region, and I-5.05: ‘Strategy for relaunching the labour market’ of the Brussels-Capital 
Region,  Belgium  proposes  to  remove  sub-projects  on  the  basis  of  Article  18(2)  of  the  RRF 
Regulation, to account for the decrease in the financial allocation. Both Article 18(2) and Article 
21 of the RRF Regulation are invoked for investment I-5.06: ‘Digital skills’ of Flemish Region, to 
account for the reduction of budget and shortages of qualified IT profiles, respectively. 

Component 5.2 – Supporting economic activity 
Investment I-5.09 ‘Support of R&D of the aeronautics and space sector’ is entirely removed under 
Article 18(2) of the RRF Regulation. Under the same legal basis, the measure ‘Strengthen R&D 
of the Flemish Region’ (I-5.11) is reduced in budget and its related target is proportionally adapted. 
Measure I-5.13 ‘Digitisation of the Walloon tourism sector’ is reduced in ambition under Article 
18(2) of the RRF Regulation, and the related target is revised also taking into account inflation, 
using Article 21 of the RRF Regulation as a legal basis. It is proposed to correct a clerical error in 
the  Council  Implementing  Decision  by  revising  the  target’s  baseline.  Article  21  of  the  RRF 
Regulation  is  invoked  for  the  different  modifications  to  the  measure  ‘Relocation  of  food  and 
development of logistics platforms of the Walloon Region’ (I-5.12). Objective circumstances have 
led to delays in the fulfillment of milestones and targets (supply chain disruptions); increase in 
costs (high  inflation)  combined with  objective circumstances  (an investment  partner pulled out 
suddenly) has led to revise the target in terms of the size and the number of constructed logistic 
hubs, while increasing the ambition of the project by including energy relevant investments in the 
two  remaining  hubs.  Article  21  of  the  RRF  Regulation  is  used  to  remove  one  of  the  three 
subprojects of the nuclear medicine measure, since it proved not to be technically or economically 
viable  and  was  stopped.  This  subproject  is  partly  replaced  by  a  new  nuclear  medicine  project. 

8 

 
 
 
 
 
Another new measure is introduced for the remainder of the available budget, ‘SMELD’, which 
aims  at  maximising  the  recycling  of  metals  resulting  from  future  nuclear  decommissioning 
operations. It concerns industrial R&D and the building of a melting furnace. 

Component 5.3 - Circular economy 
Belgium entirely removes the investment ‘Flanders Circular economy & circular construction’ of 
the  Flemish  Region  (I-5.17),  on  the  basis  of  Article  18(2)  of  the  RRF  Regulation.  Another 
investment, ‘Deployment of the circular economy in Wallonia’ (I-5.16), is reduced in ambition 
using  the  same  legal  basis,  removing  two  subparts  of  the  measure.  The  related  milestones  and 
target are adapted accordingly. 

AXIS 6 – PUBLIC FINANCES 

Component 6.1 - Spending Reviews 
No modifications are requested by Belgium for the measures in this component. 

AXIS 7 - REPOWEREU 

Under the REPowerEU  chapter and based on Article 21c of the RRF  Regulation,  Belgium  has 
proposed measures amounting to EUR 726 million in total estimated costs for 17 new investments, 
one  scaled-up  investment,  seven  transferred  investments  from  the  initial  RRP,  and  four  new 
reforms.  Belgium’s  REPowerEU  measures  are  distributed  in  four  new  components:  7.1 
‘Renovation of buildings’, 7.2 ‘New emerging energy technologies’, 7.3 ‘Renewable energy’, and 
7.4 ‘Mobility’. 

Component 7.1 – REPowerEU – Renovation of buildings 
New reform 
•  R-7.01: ‘Revision of the code on air, climate and energy’ of the Brussels-Capital Region. This 
reform amends the Brussels code on air, climate and energy (COBRACE), to introduce new 
obligations on building renovation, and it contributes to objective 21c(3)(b), (c) and (d) of the 
RRF Regulation. 

New investments 
• 

I-7.01:  ‘Improved  energy  subsidy  scheme’  of  the  Brussels-Capital  Region.  This  investment 
accompanies  R-7.01  and  consists  of  subsidies  for  renovations  achieving  primary  energy 
demand reduction for the benefit of low-income households. 
I-7.04:  ‘Renovation  of  social  housing’  of  the  Walloon  Region.  This  investment  consists  in 
equipping social housing units with solar panels and heat pumps, and it contributes to objective 
21c(3)(b), (c) and (d) of the RRF Regulation. 
I-7.05:  'Energy-climate  measures  in  public  buildings'  of  the  Federal  state.  This  investment 
consists in equipping federal public buildings with charging stations, solar panels and LED 
lights, and it contributes to objective 21c(3)(b) of the RRF Regulation. 
I-7.06: ‘Renovation of public buildings’ of the Flemish Region. This investment consists in the 
energy-efficient renovation of four public buildings: (1) Martelaarsplein 7, Martelaarsplein 19 
and Kreupelenstraat 2, Brussel, (2) Winston Churchillkaai 2, Oostende, (3) Justitiehuis, Ieper, 

• 

• 

• 

9 

 
 
 
 
 
• 

• 

• 

• 

(4)  Koolstraat  35,  Brussel.  This  measure  contributes  to  objective  21c(3)(b)  of  the  RRF 
Regulation. 
I-7.07: ‘Energy measures for public schools’ of the Flemish Region. This investment consists 
in the deployment of solar panels on public schools, and it contributes to objective 21c(3)(b) 
of the RRF Regulation. 
I-7.08:  ‘Energy  measures  for  the  care  buildings’  of  the  Flemish  Region.  This  investment 
consists in: (1) performing energy audits; and, (2) completing energy measures in residential 
care  centres  and  (psychiatric)  hospital  buildings.  This  measure  contributes  to  objective 
21c(3)(b) and (d) of the RRF Regulation. 
I-7.09:  ‘Energy  measures  for  the  VRT  building’  of  the  Flemish  Region.  This  investment 
consists  in  completing  energy  measures  for  the  new  VRT  (Vlaamse  Radio  en  Televisie) 
building, like the installation of heat pumps, solar panels and LED lights, and it contributes to 
objective 21c(3)(b) of the RRF Regulation.  
I-7.10:  ‘Energy  measures  for  the  AWV  buildings’  of  the  Flemish  Region.  This  investment 
consists  in  completing  energy  measures  in  the  AWV  (Agentschap  Wegen  en  Verkeer) 
buildings, like the installation of heat pumps, roof insulation, solar panels and LED lights. It 
contributes to objective 21c(3)(b) of the RRF Regulation.  

Upscaled measure 
• 

I-7.02: 'Improved energy subsidy scheme' of the Flemish Region. This investment scales up 
reform R-1.01 (i) in component 1.1, increasing the budget per beneficiary for energy efficient 
renovations of low-income private housing.  The measure contributes to  objective 21c(3)(b) 
and (d) of the RRF Regulation.  

Transferred measure 
• 

I-7.03:  ‘Energy  grants  for  private  housing’  of  the  German-speaking  Community.  This 
investment  consists  in  granting  energy  premiums  for  the  renovation  of  private  and  social 
housing, and it contributes to objective 21c(3)(b) and (d) of the RRF Regulation. 

• 

Component 7.2 – REPowerEU – New emerging energy technologies 
New investments 
• 

I-7.12:  ‘Energy  import  infrastructure’  of  the  Federal  State.  This  investment  consists  in 
supporting demonstration or R&D projects with the aim of optimising the infrastructure for the 
import of hydrogen or electricity, to ensure long-term security of energy supply and enable the 
energy transition.  
I-7.13:  ‘Call  for  the  decarbonisation  of  industry’  of  the  Walloon  Region.  This  investment 
consists in providing financial incentives for energy investments in Walloon industries and for 
the  development  of  new  industries  in  green  technologies.  These  investments  could  cover 
projects on energy efficiency, such as the management of industrial heat, on carbon capture 
and storage (CCS) where CO2 captured stems  from  unavoidable process  emissions,  on fuel 
switching, on the production of renewable energy, or the set-up of new industrial elements of 
the  value  chain  of  technologies  with  a  proven  interest  for  reaching  the  objectives  of 
REPowerEU,  such  as  the  batteries’  value  chain  (in  production  or  in  critical  materials 
management) and the renewable or fossil-free hydrogen’s value-chain. 

10 

 
 
 
 
 
• 

I-7.14: ‘Call for climate action in agriculture’ of the Flemish Region. This investment consists 
in  supporting  energy-saving  techniques,  green  heat  and  renewable  energy  projects  in  the 
agricultural sector. 

Transferred measures 
• 

I-7.11:  ‘Research  platform  for  energy  transition’  of  the  French  Community.  This  measure 
consists of investments in a series of large R&D facilities and equipment for the benefit of 
‘trans-
French-speaking  universities  willing 
technological’) cooperation platform to develop research actions on complex energy systems. 
I-7.15: ‘Backbone for H2’ of the Federal State. This investment consists in the development of 
a hydrogen transport network, with primary focus on the main industrial clusters of Flanders 
(Antwerp, Ghent), Wallonia (Hainaut, Liège), and Brussels. 

interdisciplinary  (and 

to  establish  an 

• 

Component 7.3 – REPowerEU – Renewable energy 
New reforms 
•  R-7.02: 'Reform of the appeal procedures of the Council of State’ of the Federal State. This 
reform  of  the  Council  of  State  consists  in:  (1)  reducing  the  time  taken  to  deal  with  appeal 
procedures relating to decisions on energy investments and renewable energy projects; and, 
(2) granting priority to the treatment of energy transition files. 

•  R-7.03: ‘PV-obligation for large consumers’ of the Flemish Region. This reform introduces an 
obligation to install solar photovoltaic panels for private buildings located in Flanders with an 
electricity consumption of more than 1 gigawatt-hour per year and for public bodies’ buildings 
located in Flanders with an electricity consumption of more than 250 megawatt-hours per year.  
•  R-7.04: ‘Accelerating the energy transition’ of the Walloon Region. This reform consists of 
facilitating and shortening permitting procedures for renewable energy through: (1) the review 
of  the  2013  Wind  Reference  Framework;  (2)  the  review  of  the  development  and  permit 
framework; (3) the reform of the Nature Conservation Act; and, (4) the ban on coal and heating 
oil for heating and domestic hot water from buildings. 

New investments 
• 

I-7.16: ‘Floating solar’ of the Federal State. This investment consists of studying the technical, 
economic and financial feasibility of floating solar panels in the North Sea, and aims to increase 
their technology readiness level from of 4 to 7 (on a 9-level scale).  
I-7.17: 'Optimisation of energy distribution’ of the Walloon Region. This investment consists 
of supporting the two main electricity network operators in the Walloon Region (OROs and 
RESA) to make grids ‘smarter’.  
I-7.18:  ‘Innovative  renewable  energy  production  initiatives’  of  the  Flemish  Region.  This 
measure concerns the awarding of grants to companies investing in research and development 
activities related to the production of innovative technologies in the field of photovoltaic cells 
and solar energy, as well as to companies investing in the electrification of port infrastructure 
in Flanders (shore-side electricity).  
I-7.19: ‘Removing barriers to renewable energy’ of the Federal State. This measure targets the 
reduction  of  the  restrictions  in  the  vicinity  of  airports  (e.g.  distance  from  radars,  height 

• 

• 

• 

11 

 
 
 
 
 
restrictions, area and location of exclusion zones) imposed by air traffic control services on the 
building of wind turbines, in view of accelerating the deployment of renewable energies. 

Transferred measure 
• 

I-7.20: ‘Off-shore energy island’ of the Federal State. This investment aims at developing an 
offshore energy hub (‘energy island’) in the Belgian part of the North Sea. The creation of this 
energy hub has two main objectives. First, it will allow the connection of 3.15 to 3.5 GW of 
future  offshore  wind  energy  to  the  onshore  electricity  grid.  Second,  it  will  facilitate  the 
integration and import of more renewable energy in and around the North Sea, by connecting 
to other countries or regions. 

Component 7.4 – REPowerEU – Mobility 
New investments 
• 

I-7.23: ‘Public LED lighting' of the Flemish Region. This investment consists of replacing old 
luminaires  (high  and  low-pressure  sodium  lamps)  with  LED  luminaires  on  motorways  and 
LED lamps in tunnels in the Flemish Region. 
I-7.25: 'Charging infrastructure for busses' of the Brussels-Capital Region. Belgium proposes 
to  reduce  the  ambition  of  investment  I-3.17  ‘Greening  of  the  bus  fleet  –  RBC’  in  the  non-
REPowerEU part of the RRP. In particular, Belgium proposes to remove the installation of 
charging  infrastructure  from  that  investment.  Under  the  REPowerEU  chapter,  Belgium 
proposes  not  only  to  compensate,  but  also  to  install  more  infrastructure  than  originally 
committed. This investment consists of the installation of overnight charging stations in three 
bus depots (for 106 buses) and opportunity charging stations in five bus line terminals. 

Transferred sub-measures 
• 

I-7.21: ‘Greening of the bus fleet – RBC’ of the Brussels-Capital Region. Belgium proposes to 
reduce  the  ambition  of  investment  I-3.17  ‘Greening  of  the  bus  fleet  –  RBC’  in  the  non-
REPowerEU part of the RRP. To compensate for that reduction, Belgium proposes to acquire 
additional  electric  buses  under  the  REPowerEU  chapter.  This  investment  consists  of  the 
acquisition of 45 additional electric buses: 32 M3 low floor articulated and 14 standard electric 
buses.  
I-7.22:  'Charging  stations  -  FED'  of  the  Federal  State.  This  investment  transfers  part  of 
investment  I-3.18  ‘Charging  stations  –  FED’,  as  it  allows  for  the  deployment  of  1832  bi-
directional  charging  stations  for  electric  cars.  The  tax  incentive  scheme,  mentioned  in 
investment I-3-18 ‘Charging stations –FED, is revised to include the deduction of the cost of 
these bi-directional charging stations. 
I-7.24: ‘Rail – efficient network’ of the Federal State. To compensate for the reduction of the 
non-repayable financial contribution, Belgium proposes to support one of the interventions in 
rail freight under investment I-3.10 – ‘Rail Efficient network of the Federal State’ also under 
the REPowerEU chapter . This project is, therefore, partially transferred to the REPowerEU 
chapter. This concerns the elecrification of railway lines 11 and L223. 

• 

• 

• 

12 

 
 
 
 
 
 
 
Table 1 - New and modified components and associated costs 

Axes 

Component 

Climate, 
sustainability and 
innovation 
Digital 
transformation 

Mobility 

Social and living-
together 

Economy of the 
future and 
productivity 
Public finances 
REPowerEU 

1.1. Renovation 
1.2. Emerging energy technologies 
1.3. Climate and environment 
2.1. Cybersecurity 
2.2. Public administration 
2.3. Optic fibre, 5G and new technologies 
3.1. Cycling and walking infrastructure 
3.2. Modal shift 
3.3. Greening road transport 
4.1. Education 2.0 
4.2.  Training  and  employment  of  vulnerable 
groups 
4.3. Social infrastructure 
4.4. End of career and pensions 
5.1. Training and labour market 
5.2. Supporting economic activity 
5.3. Circular economy 
6.1. Spending reviews 
7.1. Renovation of buildings 
7.2. New emerging energy technologies 
7.3. Renewable energy 
7.4. Mobility 

Status 

Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 
Modified 

Modified 
Unchanged 
Modified 
Modified 
Modified 
Unchanged 
New 
New 
New 
New 

Costs 
(EUR 
million) 
824 (-19%) 
247 (-59%) 
289 (-28%) 
79 
448 (-23%) 
44 (-56%) 
284 (-31%) 
622 (-7%) 
164 (-22%) 
395 (-11%) 
157 (-5%) 

202 (-11%) 
0 
319 (-14%) 
369 (-16%) 
124 (-37%) 
8 
188 
209 
221 
101 
5 300 

% of the 
total 

15.5% 
4.7% 
5.5% 
1.5% 
8.3% 
0.8% 
5.4% 
11.7% 
3.1% 
7.5% 
3.0% 

3.8% 
0.0% 
6.0% 
7.0% 
2.3% 
0.1% 
3.5% 
3.9% 
4.2% 
1.9% 
100% 

Other elements not covered by assessment criteria 

The  description  of  aspects  related  to  administrative  organisation,  gender  equality  and  equal 
opportunities  for  all  and  the  planned  communication  strategy  as  reflected  in  the  previous Staff 
Working Document (2021) 172 final remain relevant. 

With  respect  to  the  consultation  process,  Belgium  carried  out  additional  consultations  of 
stakeholders  in  the  context  of  the  amendment  of  the  RRP  and  for  the  preparation  of  the 
REPowerEU chapter, in line with the Commission’s guidance in the context of REPowerEU (the 
“REPowerEU Guidance”)2 (See Section 3.12). 

As regards the security self-assessment for digital investments, Belgium submitted a security self-
assessment  for  one  of  the  investments  included  in  the  REPowerEU  chapter  (namely  I-7.17: 
'Optimisation  of  energy  distribution’  of  the  Walloon  Region).  In  its  self-assessment,  Belgium 
outlined the measures that have been and will be put in place to mitigate the possible risks related 
to the activities of the electricity network operators in the Walloon Region (OROs and RESA) that 
will be supported with this investment. 

2   Commission Notice, ‘Guidance on Recovery and Resilience Plans in the context of REPowerEU’, 2023/C 80/01. 

13 

 
 
 
 
 
 
 
 
 
 
State aid and competition rules fully apply to the measures funded by the Recovery and Resilience 
Facility (RRF). Union funds channelled through the authorities of Member States, like the RRF 
funds, become state resources and can constitute State aid. When this is the case and State aid is 
present, these measures must be notified and approved by the Commission before Member States 
can grant the aid, unless those measures are covered by an existing aid scheme or comply with the 
applicable conditions of a block exemption regulation, in particular the General Block Exemption 
Regulation  (GBER)  declaring  certain  categories  of  aid  compatible  with  the  internal  market  in 
application of Articles 107 and 108 TFEU3. When State aid is present and it requires notification, 
it is the duty 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 Belgium in the RRP cannot be deemed a State aid notification. In as far as Belgium considers 
that  a  specific  measure  contained  in  the  RRP  entails  de  minimis  aid  or  aid  exempted  from  the 
notification  requirement,  it  is  Belgium’s  responsibility  to  ensure  full  compliance  with  the 
applicable rules. 

3.  SUMMARY OF THE ASSESSMENT OF THE RRP 

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

situation  

The  modified  RRP,  including  the  REPowerEU  chapter,  comprehensively  covers  the  six 
pillars that structure the scope of application of the Facility (Article 3): (i) green transition; (ii) 
digital  transformation;  (iii)  smart,  sustainable  and  inclusive  growth;  (iv)  social  and  territorial 
cohesion; (v) health and economic, social and institutional resilience; and, (vi) policies for the next 
generation. The coverage of the Belgian RRP components across 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. 

The range of actions of the modified RRP, including the REPowerEU chapter, corresponds 
to  the  objectives  of  the  Facility,  with  an  appropriate  overall  balance  between  pillars.  The 
allocations  to  the  green  and  digital  transitions  (respectively,  51%  and  27%)  exceed  the 
requirements of the RRF Regulation (respectively, 37% and 20%), and, therefore, the modified 
RRP significantly contributes to these pillars. 

Green transition 

Belgium’s modified RRP, including the REPowerEU chapter, continues to focus significantly on 
supporting the green transition, with now 14 components (out of 21) directly related to this pillar. 

3   Commission  Regulation  (EU)  2023/1315  of  23  June  2023  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, OJ L 167, 30.6.2023, p. 1–90. 

14 

 
 
 
 
 
 
 
The  REPowerEU  chapter  includes  reforms  and  investments  with  estimated  costs  amounting  to 
EUR 726 million that Belgium intends to deploy in order to reduce its reliance on fossil fuels and 
increase energy efficiency. The chapter will also accelerate the deployment of renewable energy 
with  a  new  component,  comprising,  notably,  measures  to  facilite  and  shorten  permitting 
procedures,  accelerate  appeal  procedures  concerning  decisions  on  energy  investments,  and 
eliminate  certain  restrictions  on  the  building  of  wind  turbines.  New  investments  on  the 
optimisation  of  energy  distribution,  research  and  development  in  the  production  of  innovative 
technologies in the field of solar energy and photovoltaic cells, and studies on the technical and 
economic feasibility  of floating solar panels  in  the North  Sea complete the new component  on 
renewable energy. 

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

Pillars of the Recovery and Resilience Facility 

Components of the Plan 

Axis 1 

Axis 2 

Axis 3 

Axis 4 

Axis 5 

Axis 6 

Axis 7 
REPo
werE
U 

1.1.Renovation of buildings 
1.2.Emerging energy technologies 
1.3.Climate & Environment 
2.1.Cybersecurity 
2.2.Public administration 
2.3.Fibre optic, 5G and new technologies 
3.1.Cycling and pedestrian infrastructure 
3.2.Modal shift 
3.3.Greening road transport 
4.1.Education 2.0 
4.2.Training and employment for vulnerable groups 
4.3.Social infrastructure 
4.4.End of career and pensions 
5.1.Training and labour market 
5.2.Support for economic activity 
5.3 Circular Economy 
6.1.Spending reviews 

7.1. Renovation of buildings 

7.2. New emerging energy technologies 

7.3. Renewable energies 

7.4. Mobility 

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

Several measures concerning the renovation of buildings included in the original RRP (component 
1.1) were either removed or downsized to  reflect  the reduced allocation  or to  account  for high 

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
inflation  in  the  sector.  Some  of  the  measures  in  this  area  were,  however,  tranferred  to  the 
REPowerEU  chapter,  where  additional  reforms  and  investments  supporting  renovations  were 
added (e.g. investments to equip social housing units with solar panels in Wallonia, support the 
energy efficient renovation of four public buildings in the Flemish Region, and equip federal public 
buildings  with  charging  stations,  solar  panels  and  led  lights).  With  respect  to  emerging  energy 
technologies,  the reduced budget  allocated to  measures in  this area within component 1.2 (e.g. 
measures on the hydrogen value chain) is counterbalanced by the inclusion in the REPowerEU 
chapter of measures supporting the deployment of new energy technologies (e.g. R&D projects 
for optimising the infrastructure for hydrogen import and energy saving techniques, green heat and 
renewable  energy  projects  in  the  agricultural  sector  in  Flanders).  In  the  transport  and  mobility 
sectors, although some measures are removed from the RRP (e.g. the investment in the high service 
level bus of the Walloon Region) or downsized (e.g. support to modal shift in the Brussels-Capital 
Region), the REPowerEU chapter will reinforce investments in the area (e.g. support to greening 
the bus fleet of the Brussels-Capital Region and charging stations). 

In  conclusion,  while  the  proposed  modification  of  the  RRP  reduces  the  ambition  of  certain 
measures regarding the green transition, notably due to the significant reduction in the maximum 
financial  contribution  allocated  to  Belgium,  with  the  inclusion  of  the  REPowerEU  chapter, 
Belgium’s modified RRP bolsters its green ambition and responds to REPowerEU objectives (see 
also 3.5 ‘Green Transition’). 

Digital transformation 

The  digital  transformation  still  represents  a  significant  part  of  Belgium’s  modified  RRP.  The 
proposed  modifications  to  measures  related  to  the  digital  transformation  reduce  the  RRP’s 
contribution  to  this  pillar,  but  the  decrease  is  less  than  proportional  to  the  reduction  of  the 
maximum  financial  contribution  allocated  to  Belgium.  With  respect  to  the  components  of  the 
digital axis of the RRP, the proposed modifications consist of downsizing the budget allocated to 
a few measures due to the reduced allocation, postponing the deadline for the completion of two 
measures, and removing one measure supporting the digitalization of the Walloon government and 
one  sub-measure  supporting  the  connectivity  of  schools.  Despite  these  changes,  the  RRP  still 
includes  key  measures  in  the  digital  sphere,  including  investments  to  foster  the  resilience  of 
companies  and  public  administrations  against  cybersecurity  threats,  measures  to  support  the 
digitalization of the public administrations (including of justice) and reforms that will contribute 
to the deployment of 5G and of ultra-fast connectivity infrastructure, such as fibre. 

Furthermore, the RRP still includes measures to support digital inclusion and the digitalisation of 
education (component 4.1), as well as the digital skills of the labour force (component 5.1). 

In sum, the digital contribution of the modified RRP remains similar to the one of the initial RRP, 
as the adjustments brought by the revision are broadly proportional to the decrease in allocation. 
The digital challenges identified for Belgium – such as connectivity, skills, and digitalisation of 
businesses – are still covered by the modified RRP (see also section 3.6). 

Smart, sustainable and inclusive growth 

16 

 
 
 
 
 
The RRP continues to cover this pillar extensively, with nearly all components contributing to its 
different policy areas. 

The  modifications,  removals  or  budget  reductions  of  some  measures  have  resulted  in  a  slight 
reduction of the contribution of the modified RRP to this pillar. This includes, for example, the 
removal of a measure supporting R&D in the aeronautical and space sector (I-5.09), the removal 
or  downsizing  of  some  measures  supporting  building  renovation  and  construction  (component 
1.1). 

Despite these changes, the modified RRP still includes several measures spread across different 
components  that  are  expected  to  support  smart,  sustainable  and  inclusive  growth  and  improve 
research,  development  and  innovation.  Furthermore,  measures  supporting  the  digitalization  of 
education and the enhancement of digital skills of the workforce are still included in the RRP and 
are  expected 
jobs,  productivity  and 
competitiveness. The RRP also still includes several measures expected to contribute to a well-
functioning internal market with strong small and medium-sized enterprises (SMEs), for example, 
measures  to  support  the  digital  transformation  of  social  security,  including  facilitating  the 
communication with the social security services of other EU Member States, and thus contributing 
to the mobility of the labour force.  

to  enhancing  economic  cohesion, 

to  contribute 

Overall,  investments  and  reforms  in  the  areas  of  green  transition,  research,  innovation  and 
digitalisation  are  set  to  bring  about  an  immediate  positive  effect  on  GDP  growth.  Moreover, 
beyond  their  short-term  effects  on  growth  derived  from  higher  investment  expenditure,  the 
measures in  the RRP  in the areas of digitalisation and research  and innovation  are expected to 
entail positive effects on total factor productivity and on labour productivity and, thus, on overall 
potential growth. According to RRP’s estimations, the positive impact of its implementation would 
peak in the medium term (5 years ahead) by when GDP is expected to be 0.18 percentage points 
higher than in the case the RRP would not have been implemented. The impact of the RRP will 
persist as in the long term (more than 20 years) GDP is still expected to be 0.12 percentage point 
higher than in the case of the RRP would not have existed. 

Social and territorial cohesion 

Strengthening social cohesion continues to be one of the key objectives of the RRP, in particular 
addressed under its fourth axis, which notably aims at fostering the inclusion and integration of 
disadvantaged  groups  and  is  not  subjet  to  significant  proposed  modifications.  The  bulk  of 
investments  and  reforms  tackling  unemployment,  notably  by  fostering  training  and  life-long 
learning  (component  5.1)  remains  in  the  RRP,  with  some  limited  proposed  modifications. 
Similarly, component 4.3, which contributes to addressing the lack of social housing for vulnerable 
groups  and  the  lack  of  early  childhood  care,  in  particular  for  vulnerable  households,  remains 
broadly unchanged. 

With respect to territorial cohesion, a significant part of the measures in the RRP was defined at 
regional  level  to  address  specific  regional  challenges,  with  funds  allocated  across  the  different 
regions. This continues to be the case following the modification of the RRP and the inclusion of 
the  REPowerEU  chapter.  Important  measures  fostering  sustainable  mobility  (e.g.  Belgium’s 

17 

 
 
 
 
 
commitment  to  complete  its  cross-regional  suburban  rail  network  within  component  3.1)  and 
digital infrastructure (e.g. the roll-out of 5G infrastructure in all regions and two fibre deployment 
infrastructure projects in white zone areas within the scope of component 2.3) remain in the RRP 
and will continue to contribute to this pillar, significantly fostering territorial cohesion. 

Health, and economic, social and institutional resilience  

Measures of the initial RRP that contribute to health, notably investments in e-health solutions to 
reinforce the overall resilience of the health system (component 2.2.) and support for training and 
innovation in the health and biotech sector (component 5.1) have not been altered. 

Economic resilience is fostered by several measures across various components of the RRP that 
aim at strengthening the productivity of firms, especially SMEs and innovative companies, and at 
supporting  the  digital  transition,  R&D  and  innovation  and  increasing  competitiveness.  Despite 
some limited proposed  modifications,  the support  provided by  the  RRP to  economic  resilience 
remains broadly unchanged.  

As discussed in the section on social and territorial cohesion, the RRP continues to focus heavily 
on building social resilience, with components under the fourth and fifth axes oriented towards 
employability, including of vulnerable groups, and enhancing skills. 

Lastly,  measures  supporting  the  introduction  of  spending  reviews  (component  6.1)  and  the 
enhanced resilience of Belgian public administrations in the face of cyber-attacks (component 2.1) 
remain broadly unchanged. Furthermore, despite the downsizing of the budget allocated to a few 
measures  due  to  the  revised  downward  allocation,  the  postponement  of  the  deadline  for  one 
investment  (I-2.05,  10)  and  the  removal  of  one  measure  supporting  the  digitalisation  of  the 
Walloon government, the RRP (component 2.2) still strongly supports the digitalisation of public 
services, including the justice system. The RRP's contribution to increasing institutional resilience 
and efficiency remains adequate. 

Policies for the next generation 

The sixth pillar remains covered by reforms and investments in various components, and the RRP 
still includes several measures with direct impact on children and young people. 

The removal or downscaling of measures supporting the renovation of public buildings (including 
schools)  in  different  federated  entities  (component  1.1)  reduced  the  RRP’s  contribution  to  this 
pillar,but  is  partly  compensated  by  the  inclusion  in  the  REPowerEU  chapter  of  a  measure  to 
support the deployment of solar panels in public schools. 

Furthermore,  despite  the  downscaling  of  measures  supporting  the  renovation  and  upgrading  of 
training facilities (component 5.1) and the removal of a measure to improve the connectivity of 
schools (component 2.3), access to quality education, youth employment and training continue to 
be  one  of  the  focuses  of  the  RRP.  Measures  to  counter  early  school  leaving  and  provide 
personalised support to pupils (component 4.1), measures to support the increase in the capacity 
of childcare facilities, as well as flexible temporary childcare for jobseekers (components 4.2 and 
4.3), investment in the digital infrastructure and equipment of the education system components 

18 

 
 
 
 
 
2.3.  and  4.1),  and  the  renovation  and  development  of  training  facilities  (component  5.1)  will 
remain unchanged. 

Conclusion 

Overall, the measures proposed in Belgium’s modified RRP pursue the general objective of the 
Facility by promoting the Union’s economic, social, and territorial cohesion, structured in the six 
pillars of Article 3 of the RRF Regulation. 

*** 
Taking into consideration all reforms and investments envisaged by  Belgium, its modified RRP 
– including its REPowerEU chapter – is expected to represent to a large extent a comprehensive 
and  adequately  balanced  response  to  the  economic  and  social  situation,  thereby  contributing 
appropriately to all six pillars referred to in Article 3 of the RRF Regulation, taking the specific 
challenges and the financial allocation of Belgium into account. This would warrant a rating of A 
under the assessment criterion 2.1 in Annex V to the RRF Regulation. 

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

The modified RRP continues to effectively address all or a significant subset of the challenges 
identified in the relevant country-specific recommendations (CSRs). As compared to the initial 
RRP’s  assessment,  the  recommendation  on  providing  liquidity  to  SMEs  (CSR  2020.3.1)  was 
considered fully implemented in the latest 2023 CSR assessment and, thus, it is no longer relevant. 
Belgium has also made substantial progress on a number of recommendations, which renders them 
no longer relevant for the assessment of the modified RRP: 

•  Focus investment on research and innovation (CSR 2019.3.3, 2020.3.9); 
•  Reinforce the overall resilience of the health system (CSR 2020.1.2); 
•  Mitigate the employment and social impact of the COVID-19 crisis (CSR 2020.2.1); 
•  Expand public investment for the green and digital transitions (CSR 2022.1.2). 

However,  the  finalisation  of  the  investments  and  reforms  in  the  revised  RRP  (including  those 
present in the REPowerEU chapter), could help to further address these challenges. 

Despite  the  significant  reduction  in  the  maximum  financial  contribution  allocated  to 
Belgium,  only  seven  measures  are  completely  removed  from  the  RRP  (without  being  re-
introduced  into  the  REPowerEU  chapter  and/or  under  the  new  loan  support),  without 
affecting the coverage of the 2019 and 2020 CSRs. Two of the removed measures pertain to the 
renovation of buildings, but large investments in renovation remain (CSR 2019.3, 2020.3, 2022.4, 
2023.4). An investment in renewable heat networks is removed, but the new measures included in 
the REPowerEU  chapter address  the same  recommendations (CSR 2019.3, 2020.3, 2022.4 and 
2023.4), as explained in the section below. An investment in the digitalisation of regional and local 
governments in Wallonia is removed, but large investments in e-governance remain (CSR 2019.4, 
2020.3). The same  applies  to  the removed investment in  a high-service bus  lane (CSR 2019.3, 

19 

 
 
 
 
 
 
2020.3), for R&D support for the aeronautical and space sector (CSR 2019.3.3, 2020.3.9), and an 
investment in the circular economy and circular construction (CSR 2020.3).  

The  proposed  scale-downs  of  investments  in  response  to  the  reduction  of  the  maximum 
financial contribution are also distributed among the different components in such a way as 
not to significantly affect the balance of the RRP, including the coverage of the 2019 and 2020 
CSRs, taken into account in the assessment of the original RRP. The rest of the revision does not 
have a significant impact on the RRP’s coverage of the 2019 and 2020 CSRs. 

Moreover, as the maximum financial contribution allocated to Belgium has been adjusted 
downwards, the 2022 and 2023 recommendations not related to energy challenges are not 
considered  in  the  overall  assessment4.  Most  of  the  loans  requested  are  earmarked  for  the 
REPowerEU chapter and address the energy CSRs mentioned below, whilst the remaining part of 
the loan support (EUR 49 million) is used to finance three existing measures transferred from the 
non-repayable  support  of  the  initial  RRP,  one  of  which  is  only  slightly  modified.  These  three 
measures  continue  to  address  CSR  2020.3.5  (sustainable  transport  and  digitalisation  of  public 
administration). 

New  measures  proposed  by  Belgium  in  the  REPowerEU  chapter  adequately  cover  the 
different  subparts  of  the  energy  CSRs  of  2022  and  2023,  which  are  broadly  similar. 
Component  7.1  ‘Renovation  of  buildings’  contains  measures  for  the  renovation  of  private 
(including social) and public housing aimed at improving the energy efficiency of buildings, in 
particular through thermal renovation and the installation of solar panels and heat pumps (CSR 
2022.4.2, 2023.4). Component 7.2 ‘Emerging energy technologies’ includes measures aimed to 
stimulate the decarbonisation of industry (CSR 2022.4.1, 2023.4), as well as projects to effectively 
and  sustainably  support  energy  grid  infrastructure  (CSR  2022.4.4,  2023.4),  in  particular  for 
hydrogen, or research projects on energy transition. Component 7.3 ‘Renewable energy’ focuses 
on investing in renewable energy generation capacity, through investments in offshore wind and 
solar,  and  by  reforming  the  regulatory  framework  to  stimulate  the  installation  of  photovoltaic 
panels and reduce the time required to bring legal proceedings for energy infrastructure projects 
(CSR 2022.4.4, 2023.4). Finally, component 7.4 ‘Greening the road transport’ responds to public 
transport recommendations (CSR 2022.4.3, 2023.4), with measures focusing in particular on the 
purchase of low-emission rolling stock for public transport. 

*** 
Taking into consideration the reforms and investments envisaged by Belgium, its modified RRP is 
expected to contribute to effectively addressing all or a significant subset of challenges identified 
in  the  country-specific  recommendations,  or  challenges  in  other  relevant  documents  officially 
adopted by the Commission under the European Semester, and the RRP represents an adequate 
response to the economic and social situation of Belgium. This would warrant a rating of A under 
the assessment criterion 2.2 in Annex V to the RRF Regulation. 

4   OJ, C 80, 3.3.2023, p. 1. 

20 

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

The proposed modifications to the Belgium RRP consist mostly of reducing and, in certain cases, 
removing some measures in line with the revised financial allocation, while retaining the overall 
ambition of  the initial  RRP. As such the proposed modifications  do not  have an impact  on the 
previous assessment (Rating of A) of the RRP’s impact on the growth potential, job creation, and 
economic,  social  and  institutional  resilience  of  the  Member  State.  Likewise,  the  amended  RRP 
continues to contribute 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. This is reflected in the previous assessment (rating 
of A) of the plan and detailed in the Staff Working Document (2021) 172 under criterion 2.3 of 
Annex V to the RRF Regulation. 

3.4. The principle of ‘do no significant harm’ 

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

Belgium’s REPowerEU chapter includes a systematic assessment of each measure against 
the principle of ‘do no significant harm’ (DNSH), for each of the six environmental objectives 
within the meaning of Article 17 of the Taxonomy Regulation. DNSH assessments have also 
been added or updated for new or modified measures in the non-REPowerEU part of the RRP. The 
assessments  follow  the  methodology  set  out  in  the  Commission’s  technical  guidance  on  the 
application  of  ‘do  no  significant  harm’  under  the  Recovery  and  Resilience  Facility  Regulation 
(2021/C  58/01)  (‘DNSH  Guidance’),  and  apply  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. In cases where the analysis identifies a risk, a more detailed assessment is performed 
in which the absence of significant harm is verified, or measure safeguards are provided to ensure 
the absence of significant harm. 

While Belgium’s assessment often stresses the environmental and climate benefits of measures in 
this  assessment,  it  also  provides  information  allowing  to  assess  that  measures  are  expected  to 
comply with the ‘do no significant harm’ principle. 

The  renovation  measures  in  the  REPowerEU  chapter  do  not  include  support  for  heating 
systems based on natural gas. Assurances were received from the Belgian authorities that the 
measures involving building renovation will not include support for the installation of gas boilers. 

21 

 
 
 
 
 
 
 
For  some  measures,  where  calls  for  projects  or  calls  for  interest  are  necessary  to  select 
specific projects, ensuring adherence with the ‘do no significant harm’ principle will require 
introducing specific safeguards in the milestones associated with each measure, to monitor 
their  implementation.  Specific  safeguards  have  been  introduced  for  measures  included  in  the 
RRP that could potentially lead to investments being made in installations falling within the scope 
of the EU Emission Trading System (ETS). This is the case in particular for the measure ‘Call for 
the decarbonisation of industry’ of the Walloon Region (I-7.13). In this case, compliance with the 
‘do no significant harm’ principle is ensured by excluding from eligibility all activities under the 
Emission Trading System with projected CO2 equivalent emissions that are not substantially lower 
than  the  relevant  benchmarks  established  for  free  allocation.  This  has  been  reflected  in  a 
corresponding milestone. 

*** 
Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation  of  reforms  and  investments  projects  included  in  Belgium’s  modified  RRP, 
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 to the RRF Regulation. 

3.5. Green transition 

The  modifications  did  not  substantially  impact  the  contribution  of  the  RRP  to  the  green 
transition, as well as the initial assessment. With the REPowerEU chapter, Belgium responds to 
the  REPowerEU  objectives  and  increases  its  ambitions  regarding  the  green  transition,  overall 
compensating  for  the  withdrawn  or  reduced  measures.  The  modified  RRP  continues  to 
significantly contribute to the green transition, including biodiversity, as well as to the achievement 
of the Union 2030 climate targets, while complying with the objective of EU climate neutrality by 
2050 (see Annex). 

The REPowerEU chapter provides an ambitious contribution to the green transition since 
all the reforms and investments it includes fully contribute to reducing the reliance on fossil fuels, 
increasing energy efficiency, and accelerating the deployment of renewable energies, notably by 
improving the framework conditions for wind energy, and by further streamlining the permitting 
procedures and accelerating appeal procedures. 

For the climate target, the main impact concerned: (1) the withdrawal or reductions in budget of 
measures in the renovation component, notably concerning the renovation of public buildings in 
the Walloon Region (reduction in contribution of EUR 69 million); (2) the reduced budget for the 
measures  on  the  hydrogen  value  chain  (reduction  of  EUR 96 million)  and  withdrawal  of  the 
investment in heat networks in the Flemish Region (EUR 44.3 million); (3) the reduction of the 
budget of the Blue Deal (by EUR 100 million); and, (4) a reduction in climate contribution of Axis 
5  of  around  EUR 50 million  due  to  the  withdrawal  of  two  measures,  ‘Support  of  R&D  in  the 
aeronautics  and  space  sector’  of  the  Federal  State  (I-5.09)  and  ‘Circular  economy  &  circular 

22 

 
 
 
 
 
 
construction’ of the Flemish Region (I-5.17), and the reduction in budget of measure ‘Deployment 
of the circular economy’ in the Walloon Region (I-5.16). This reduction is broadly in line with the 
decrease in financial contribution. The climate contribution of the revised existing part of the RRP 
(without  REPowerEU  chapter)  thus  remains  much  higher  than  the  minimum  required,  even  if 
reduced compared to the one of the initial RRP, standing at EUR 2.1 billion or 45% (against 50% 
for the original RRP) of the updated RRF financial contribution. 

The  climate  contribution  of  the  REPowerEU  chapter  is  88%  (EUR 637 million)  of  the  total 
estimated cost of the REPowerEU chapter of EUR 726 million, which is well above the 37% target 
set out in the RRF Regulation. 

In total, the whole RRP (including revised measures and the REPowerEU chapter) contributes to 
the  climate  target  at  51%  (EUR 2.7 billion)  of  Belgium’s  maximum  financial  contribution 
(including the REPowerEU allocation amount, the transfer from the Brexit Adjustment Reserve 
and the loan support) of EUR 5.3 billion, which is also well above the target of 37% required by 
the RRF Regulation. 

*** 
Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  the  modified  RRP, 
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 maximum financial contribution 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 to the RRF Regulation. 

3.6. Digital transition 

The modification of the RRP does not materially impact its ambition towards the digital transition, 
nor the initial assessment. The modified RRP continues to significantly contribute to the digital 
transition  with  a  cross-cutting  approach,  by  supporting  cybersecurity,  the  digitalisation  of 
businesses  and  public  administration,  and  (high-speed)  connectivity.  It  also  contributes  to  the 
digitalisation of the transport sector, to increasing the digital skills of the workforce, pupils and 
the population more broadly (including vulnerable groups). The reforms and investments are still 
expected to have a lasting impact.  

Many of the measures contributing to the digital transition remain unmodified or retain the same 
financial allocation. The measures completely withdrawn (which are only a few) or reduced do not 
materially impact on the overall ambition of the RRP regarding the digital transition, as they also 
reflect the decreased total allocation to the Belgian RRP. The main impact of the revision concerns 
measures  from  components  2.2  and  2.3,  as  well  as  4.1  and  5.1.  The  total  decrease  in  the 
contribution to the digital target amounts to approximately EUR 331 million. This decrease caused 
by  the  revision  of  the  RRP  is  less  than  proportional  to  the  decrease  in  the  maximum  financial 
contribution (approximately EUR 1.4 billion). Therefore, the contribution to the digital transition 
of the modified RRP (excluding the REPowerEU chapter) stands at 27% (EUR 1 247 million) of 

23 

 
 
 
 
 
 
Belgium’s revised maximum contribution of EUR 4 574 million (including RRP loans), which is 
above the required target of 20% set out in the RRF Regulation. 

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

3.7. Lasting impact of the RRP 

In spite of the material reduction in the maximum financial contribution, the modified RRP only 
marginally reduces the ambition of the initial RRP as a whole. It takes into account the reduced 
financial contribution, the prolonged impact of the COVID-19 crisis5, inflation and supply chain 
disruptions, as well as some unexpected legal or technical difficulties for the implementation of 
some measures. Belgium has decided to use the possibility to ask for loans in order to mitigate the 
impact  of  the  reduction  in  the  maximum  financial  contribution  on  the  level  of  ambition  of  the 
original  RRP.  The  majority  of  the  loans  will  be used  to  finance  the  new  REPowerEU  chapter, 
while the remainder will be mostly used to finance measures previously supported by the financial 
contribution. The REPowerEU chapter, in addition to the existing measures, is also expected to 
have  lasting  positive  effects  on  the  Belgian  economy  and  further  boost  its  green  transition.  In 
particular,  the  REPowerEU  measures  are  expected  to  contribute  to  the  green  transition,  by 
supporting  Belgium’s  decarbonisation  effort,  the  greening  of  its  transport  network,  energy 
transition, and reduce its energy dependence. The REPowerEU measures for the decarbonisation 
of industry and energy renovation of private and public buildings are expected to have a lasting 
impact on the reduction of greenhouse gas emissions. The chapter contains new investments on 
the optimisation of energy distribution, research, and development on the production of innovative 
technologies  in  the  field  of  solar  energy  and  photovoltaic  cells,  studies  on  the  technical  and 
economic feasibility of floating solar panels in the North Sea, which will contribute to the green 
transition. Reforms included in the REPowerEU chapter are also expected to have a long-lasting 
impact on Belgium, notably by improving the framework conditions for renewable energy and by 
further streamlining the permitting procedures and accelerating appeal procedures. 

*** 
The nature and extent of the proposed modifications to the Belgian RRP do not have an impact on 
the previous assessment (rating of A) of the lasting impact of the RRP under criterion 2.7 of Annex 
V to the RRF Regulation. 

5   The prolonged impact of the COVID-19 crisis for example delayed construction works (for example for investment 
C8.I7 boarding schools for excellence) or prevented the organisation of in-person trainings (for example related to 
investment C8.I22 on the increase of Pôle Emploi). 

24 

 
 
 
 
 
 
 
 
3.8. Milestones, targets, monitoring and implementation 

The  milestones  and  targets  of  the  modified  Belgian  RRP  enable  an  adequate  monitoring  of  its 
implementation. Each of the new reforms and investments introduced under the new REPowerEU 
chapter includes at least one target and/or milestone that contains the key elements of the measure 
and allows for the assessment of the achievement of its objectives. This new chapter includes a set 
of 36 new milestones and targets. For reforms taking the form of a new legal act, such as the federal 
reform of the administrative appeal procedures at the Council of State (R-7.02), the milestone is 
the entry into force of the new piece of legislation, thereby capturing the actual implementation of 
the new provisions. 

The performance of the investments included in the new REPowerEU chapter will be assessed on 
the basis of the achievement of multiple milestones and targets monitored by each public entity in 
charge of implementing the measures. The targets chosen – some of which build on existing targets 
for the upscaled measure – are consistent with the objectives, cost estimates and implementation 
schedule of each measure, and quantified by specific indicators reflecting the result of the works 
undertaken (for example, the number of housing units renovated, or the number of LED luminaires 
installed  on  motorways).  Where  appropriate,  the  level  of  ambition  is  also  verified  (e.g. 
achievement of at least 30% energy savings, for the renovation measures qualifying for a 100% 
climate tagging). 

Apart  from  the  changes  made  under  Article  18(2)  of  the  RRF  Regulation,  which  reflect  the 
downward revision of Belgium’s maximum  financial contribution, the adjustments made to the 
RRP’s 210 original milestones and targets do not affect the plan’s overall level of ambition and 
may, in some cases, help clarify monitoring procedures and better assess the achievement of some 
key  measures.  The  modified  RRP,  for  instance,  specifies  more  clearly  the  climate  tagging 
requirements  in  the  milestones  and  targets  of  the  renovation  component  (C1.1),  to  allow 
identifying the part of the various investments to which the 30% energy savings condition applies. 

The  initially  assessed  overall  organisational  arrangements  for  the  implementation  of  the  plan 
remain the same, with inter-federal coordination mechanisms that have been established to monitor 
and implement the plan next to arrangements at individual entity level (see also 3.10 Controls and 
audit). 

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

*** 

3.9. Costing 

In general, Belgium provided clear information and evidence on costs, including references 
to actual tender data. For modified measures, the proportionality of the cost modifications was 
assessed, based on the estimated unit costs in the original RRP. For reductions in costs proportional 
to  the  reduction  in  ambition  of  the  relevant  milestones  and  targets,  the  estimated  costs  were 

25 

 
 
 
 
 
 
generally  considered  to  be  reasonable,  plausible,  cost-efficient  and  commensurate  with  the 
expected national economic and social impact, in accordance with the cost assessment of the initial 
RRP. Measures with a non-proportional modification of the costs were assessed further together 
with the costs of new measures, for which Belgium submitted estimates and information on the 
methodology used to develop them. Belgium also provided further information and evidence upon 
request. 

The assessment of these cost estimates and supporting documents shows that the majority of the 
costs of the new measures are well justified, reasonable, plausible and do not include costs covered 
by existing or planned EU financing, and are commensurate to the expected economic and social 
impact of the envisaged measures. 

Reasonable costs 

Belgium provided actual data and evidence supporting unit cost estimates, together with adequate 
explanations of the calculation methodology in most cases. For modifications under Article 21, 
any variations in unit costs due to objective circumstances, such as inflation, were duly justified 
and supporting evidence provided. For modifications under Article 18, where the proportionality 
of the reduction was not immediately apparent, more detailed information on the breakdown of the 
measure was provided, in order to ascertain whether it was indeed a proportional reduction. In the 
case of non-proportional reductions, additional information, justifications and calculations of the 
estimated  unit  costs  were  provided,  supported  by  actual  data  or  indications  of  the  information 
sources. 

For the REPowerEU chapter, the cost estimates for the new investments were justified using actual 
data, and a breakdown of the costs by sub-measure was provided where relevant. The cost-related 
information in the REPowerEU chapter was sufficiently exhaustive, with explanations related to 
the methodology used to derive cost estimates. 

Thus, the modified and new measures are assessed as having high or medium reasonability. The 
new  measures  included  in  the  Belgian  RRP,  including  those  in  the  REPowerEU  chapter,  also 
comply  with  the  eligibility  criteria  set  out  in  the  RRF  Regulation.  No  recurring  national 
expenditure is included in the new measures. All costs are incurred for reforms and investments 
started after February 2020, and for the measures in the REPowerEU chapter after February 2022, 
except in some cases where they are transferred from the initial RRP or scale-ups of such measures. 
Value-added tax (VAT) is not included in any of the cost estimates. 

Plausible costs 

The estimated costs are in line with the type of  investments envisaged. For modified measures 
under Articles 18 and 21 of the RRF Regulation, actual data were provided, including tender data 
and national statistics. Links to evidence were provided for the scaled-up measure, demonstrating 
the increase in costs. Overall, the cost estimates of the new and modified measures of the RRP are 
assessed as plausible. 

No double Union financing 

26 

 
 
 
 
 
Belgium has indicated that the new measures, including those in the REPowerEU chapter, funded 
under the RRF, will not be financed by other Union funding. For modified measures that are also 
financed  by  other  EU  funds,  Belgium  has  indicated  those  other  EU  financing  sources  and 
delineated the part of the investment funded under the RRF. 

Commensurate and cost-efficient costs  

The total cost of Belgium’s modified RRP is commensurate with the expected social and economic 
impact of the envisaged measures. The new and modified measures are expected to help effectively 
address  a significant subset of challenges identified in the CSRs, in accordance with the initial 
plan. In addition, new measures in the REPowerEU chapter are also expected to address challenges 
identified in  climate  and energy  relevant  CSRs.  Furthermore, the modified  RRP is  expected to 
strengthen social cohesion and social protection and the implementation of the European Pillar of 
Social Rights, in line with the initial plan, while the new measures under the REPowerEU chapter 
aim to bolster Belgium’s green transition and reduce its energy dependence. Therefore, Belgium’s 
modified RRP is assessed as being in line with the principle of cost-efficiency and is commensurate 
with the expected national economic and social impact. 

*** 
The justification provided by Belgium on the amount of the estimated total costs of the modified 
RRP is to a medium extent reasonable, plausible, in line with the principle of cost-efficiency and 
is  commensurate  with  the  expected  national  economic  and  social  impact.  Belgium  provided 
sufficient  information  and  evidence  that  the  amount  of  the  estimated  cost  of  the  reforms  and 
investments of the modified RRP 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 

The  original  assessment  of  the  robustness  and  adequacy  of  the  control  system  and  other 
arrangements included in the Belgian RRP had concluded that these arrangements are adequate 
subject  to  the  timely  fulfillment  of  two  milestones  pertaining  (a)  to  a  repository  system  for 
monitoring the implementation of the RRP, including the minimum functionalities; and (b) to the 
implementation of adequate coordination arrangements, including cross-checks, at the level of the 
coordinating body at inter-federal level, allowing to avoid double funding from the Facility and 
other Union programmes, in accordance with the principle of sound financial management. This 
warranted a rating of A under the assessment criterion 2.10 of Annex V to the RRF Regulation.  

The Belgian authorities have confirmed that the internal control system, as well as arrangements 
for the prevention, detection and correction of fraud, corruption, conflict of interest and double 
funding as previously assessed remain in place.  

The modifications to the original plan and the introduction of the REPowerEU chapter as such do 
not affect the original assessment. However, in the context of the modification of the Belgian RRP, 
its audit and control system need to be reassessed on the basis of criteria 2.10 of Annex V to the 

27 

 
 
 
 
 
 
RRF Regulation. Since the original assessment, the Commission has had access to information on 
its actual implementation. This includes the findings of the audit on the protection of the financial 
interests of the Union performed by the Commission in Belgium. 

In  light  of  this  information,  the  Commission  considers  that  the  internal  control  system  of  the 
Belgian  RRP  is  overall  adequate,  but  it  has  some  deficiencies  that  must  be  addressed.  In  this 
context, two audit and control milestones have been introduced to remedy the weaknesses.  

Robustness of internal control system and distribution of roles and responsibilities 

The  previous  assessed  arrangements  as  regards  the  roles  and  responsibilities  of  the  actors  for 
control and audit, segregation of functions and independence of actors performing audits remain 
adequate in the revised RRP.  

Adequacy of control systems and other relevant arrangements 

The control system and other arrangements to prevent, detect and correct fraud, corruption and 
conflicts of interest when using funds provided by RRF continue to appear overall adequate. 

The collection and storage of the data required by Article 22(2)(d)(i)-(iii) of the RRF Regulation 
are decentralised at the level of each competent government. All repository systems at federal level 
and at the level of each federated entity have been audited by their respective audit authorities, 
prior  to  the  submission  of  the  first  payment  request,  under  assessment  by  the  Commission’s 
services at the time of drafting this document. The legislative framework6 has been amended to 
allow all competent bodies, at all levels of government, to have direct access to the data recorded 
in  the  Belgian  Ultimate  Beneficial  Owner  register,  since  17  February  2023,  with  a  view  to 
collecting data on beneficial owners. 

Nevertheless, systemic issues were identified in relation to anti-fraud and anti-corruption policies, 
functional whistleblowing channels, on the spot verifications targeting PFIU matters, procedures 
on reporting irregularities to OLAF and other competent bodies, ex-ante verifications for conflict 
of  interest,  procedures  within  the  implementing  bodies  with  regard  to  the  verification  of 
compliance with  Union and national  law, as well  as the procedures in  place at  the level  of the 
bodies  signing  the  management  declarations  ensuring  that  they  obtain  assurance  that  the  funds 
were managed in accordance with all applicable rules, in particular rules on avoidance of conflicts 
of interest, fraud, prevention of corruption and double funding.  

Hence, two milestones have been proposed to be included in the RRP for this purpose. The first 
one shall cover the adaptation of the manuals of procedures documents outlining management and 
control  systems  by  the  coordinating  bodies,  in  collaboration  with  the  implementing  bodies  if 
necessary,  and  issue  related  instructions  to  the  implementing  bodies  with  the  objective  to 
strengthen the framework to prevent, detect, and correct any serious irregularities such as fraud, 
conflict of interest, corruption and double funding, including as a minimum provisions requiring 

6   Amendment of the Law of 18 July 2017 on the prevention of money laundering and terrorist financing and the 
restriction of the use of cash and amendment the royal decree of 30 July 2018 on the operating modalities of the 
UBO register. 

28 

 
 
 
 
 
 
 
law, 

anti-fraud and anti-corruption strategies, functional internal and external whistleblowing channels, 
on-the-spot  verifications,  procedures  on  the  reporting  of  irregularities  to  OLAF  and  other 
competent authorities, and procedures with regard to the verification of compliance with Union 
in  particular  concerning  public  procurement  and  state  aid.  The 
and  national 
manuals/documents shall include procedures in relation to obtaining assurance for the signature of 
the management declarations accompanying the payment request submitted to the Commission. In 
addition, where the Inspectorate of Finances has been tasked with responsibility of such controls, 
the  relevant  coordinating  bodies  shall  adopt  and  send  a  communication  to  the  Inspectorate  of 
Finance with regard to the ex-ante verifications on compliance with Union and national law and 
on the protection of the financial interests of the Union to be conducted in line with Regulation 
(EU)  2021/241.  The  second  milestone  shall  cover  the  instructions  issued  by  the  coordinating 
bodies  to  all  implementing  bodies  with  regard  to  ex-ante  verifications,  before  the  signature  of 
contracts or award of grants, of the risk for conflict of interest in the implementation of measures. 
This shall include mandatory declarations on the absence of conflict of interest from the persons 
involved at all stages of the selection procedures for both calls for tenders and calls for projects, 
and, on a risk basis, the use of an appropriate risk assessment tool in view of performing the checks 
on conflict of interest outlined in the instructions. The instructions shall define conflict of interest 
in line with Article 61 of the Financial Regulation. 

Adequacy of arrangements to avoid double EU funding 

All entities have described their own procedures for avoiding double EU funding in the documents 
submitted  in  the  context  of  the  revised  RRP.  The  governance  model  for  the  management  and 
monitoring of the RRP is decentralised following Belgium’s federal structure, where each entity 
exercises its powers autonomously in its areas of competence and organises the implementation of 
the plan, including to avoid double EU funding. These arrangements are considered to be adequate 
subject to fulfillment of audit and control milestone (M210) prior to  the first payment request. It 
concerns the need to  ensure that the implementation  of appropriate  coordination  arrangements, 
including cross-checks, be put in place at the level of the coordinating body at inter-federal level, 
making  it  possible  to  avoid  double  funding  from  the  Facility  and  other  Union  programmes,  in 
accordance with the principle of sound financial management. The fulfillment of this milestone is 
under assessment at the time of drafting this document. 

Legal empowerment and administrative capacity of control function 

In  all  six  entities,  the  first-level  controls  (management  verifications)  have  been  assigned  to 
different  public  bodies  that  are  part  of  the  existing  internal  control  framework  for  budget 
implementation in the various entities. Belgium did not communicate any changes in these aspects 
when submitting the revised RRP. Likewise, the mandates of the audit bodies remain in place.  

Conclusion 

The  arrangements  proposed  by  Belgium  in  the  modified  RRP  to  prevent,  detect  and  correct 
corruption,  fraud  and  conflicts  of  interest  when  using  the  funds  provided  under  the  Facility, 
including  the  arrangements  aimed  to  avoid  double  funding  from  the  Facility  and  other  Union 
programmes, are assessed to be adequate. This would warrant a rating of A under the assessment 
criterion 2.10 of Annex V to the RRF Regulation. 

29 

 
 
 
 
 
3.11. 

Coherence 

The Belgian RRP displays a mostly coherent set of reforms and investments. The modified 
RRP presented by Belgium is structured along seven coherent axes, which support the common 
objectives of stimulating the recovery of the Belgian economy, contributing to the twin transition 
and increasing Belgium’s resilience to face the challenges of the twenty-first century on the path 
to a sustainable and inclusive growth. The modification of the RRP amends five out of six existing 
axes, and brings an additional (seventh) axis, the REPowerEU chapter. The RRP does not present 
inconsistencies or contradictions between the content of the different axes. 

Measures within axes are mutually reinforcing, with components generally including a set of 
mostly balanced reforms and investments, as explained hereafter. 

Mutually reinforcing measures  

The modifications to the RRP do not negatively alter the axes’ coherence, nor the coherence 
of the plan as a whole. They do not alter the way in which they reinforce each other. The additional 
REPowerEU chapter is broadly consistent with the measures deployed under the initial RRP to 
support the green transition and further reinforces the ambition of some of them, in particular the 
investments  in  projects  aimed  at  reducing  its  overall  energy  dependency  by  stimulating 
decarbonisation of industry and domestic renewable energy production. The REPowerEU chapter 
is built around a mostly consistent combination of mutually reinforcing reforms and investments 
to  support  energy  renovation  of  buildings,  emerging  new  technologies,  renewables  and  the 
greening of road transport in Belgium. However, it is rather dispersed, with many new investments 
of limited size, whilst there is only one scale-up of an existing measure already included in the 
initial RRP. 

Complementarity of measures 

The modifications made to existing axes of the RRP do not negatively alter the way in which 
these axes complement each other. The additional axis related to REPowerEU’s objectives, 
in turn, brings a new layer of complementarity, as it includes new and transferred measures, 
arranged  into  four  complementary  components:  (i)  renovation  of  buildings;  (ii)  new  emerging 
energy technologies; (iii) renewable energy; and, (iv) greening road transport. Several measures 
(reforms and investments) aim to accelerate the development of renewable energy, in particular by 
streamlining  permitting  procedures  and  shortening  the  handling  of  appeals  against  permits. 
Furthermore, other new reforms and investments stimulate energy renovation of buildings, support 
the installation of heat pumps and solar panels, or aim at the decarbonisation of industry. Three 
transferred investments from the original plan target sustainable mobility. Yet, the REPowerEU 
chapter is rather fragmented, with many small new measures that occasionally, pursue unrelated 
objectives. 

At the level of the modified RRP, all axes pursue complementary aims, with no contradictory 
goals. At the same time, some complementarity concerns expressed regarding the initial RRP 
still hold. Firstly, the plan could have better exploited the potential of some investments through 

30 

 
 
 
 
 
 
more  far-reaching  complementary  reforms.  For  example,  investments  in  education  (e.g.  IT 
infrastructure) could have been complemented by reforms enhancing the educational benefits of 
such  investments  for  students,  such  as  reforms  in  initial  teacher  education  and  teachers’ 
professional learning development. Likewise, investments in training facilities in Wallonia could 
have been complemented by a reform of vocational education and training in the French-speaking 
Community.  Secondly,  the  productivity  axis  is  composed  of  rather  heterogeneous  measures  in 
training,  circular  economy,  R&D  and 
industrial  support,  without  clear  synergies  or 
complementarity.  Thirdly,  many  reforms  and  investments  are  not  applied  uniformly  and 
consistently across the country, which would be warranted. For example, reforms to reduce the 
administrative  burden  are  presented  in  Flanders  and  Brussels,  but  not  in  Wallonia.  The  RRP 
foresees the development of two individual learning accounts (one at the federal level and one at 
the regional level), rather than the creation of one integrated account, which would increase the 
transparency towards citizens as regards the available training incentives. The Belgian authorities 
have, however, committed to coordinating the implementation of these measures. 

*** 
Taking  into  consideration  the  qualitative  assessment  of  all  components  of  Belgium’s  modified 
RRP, their individual weight (importance, relevance, financial allocation) and their interactions, 
the plan contains measures for the implementation of reforms and investments which, to a medium 
extent, represent coherent actions. This would warrant a rating of B under the assessment criterion 
2.11 of Annex V to the RRF Regulation. 

3.12. 

REPowerEU 

The measures included in the REPowerEU chapter (see Section 2.2) will contribute to a large 
extent to the objectives pursued by the RRF Regulation. The implementation of the envisaged 
measures  is  expected  to  effectively  contribute  to  boosting  energy  efficiency  in  buildings, 
decarbonising industry, increasing production and uptake of renewable and fossil-free hydrogen, 
and increasing the share and accelerating the deployment of renewable energy. The reform of the 
Council  of  State  should  facilitate  the  granting  of  permits  and  favour  the  rapid  deployment  of 
renewable energy. Component 7.1: Renovation of Buildings addresses the REPowerEU objectives 
of increasing the energy efficiency of buildings (Article 21c(3), point (b) of the RRF Regulation), 
and also contributes to the sub-objectives of reducing energy poverty (Article 21c(3), point (c) of 
the RRF Regulation) and reducing energy demand through incentives (Article 21c(3), point (d) of 
the  RRF  Regulation).  Component  7.2:  New  Emerging  Energy  Technologies  aims  to  improve 
energy infrastructure and installations to increase the share of renewable energy in the energy mix 
(Article 21c(3), point (b) of the RRF Regulation), supports decarbonising the economy (Article 
21c(3),  point  (b)  of  the  RRF  Regulation),  contributes  to  reducing  energy  demand  through 
incentives (Article 21c(3), point (c) of the RRF Regulation), and supports the development of a 
value  chain  in  green  transition  technologies  (Article  21c(3),  point  (f)  of  the  RRF  Regulation). 
Component  7.3:  Renewable  Energy  addresses  the  objective  of  increasing  the  share  and 
accelerating the deployment of renewable energy (Article 21c(3), point (b) of the RRF Regulation), 

31 

 
 
 
 
 
 
the objective of accelerating the integration of renewable energy sources (Article 21c(3), point (e) 
of  the  RRF  Regulation),  and  the  objective  of  supporting  the  development  of  a  value  chain  in 
technologies  related  to  the  green  transition  (Article  21c(3),  point  (f)  of  the  RRF  Regulation). 
Component 7.4: Greening Road Transport is in line with the objective of supporting zero-emission 
transport and its infrastructure (Article 21c(3), point (e) of the RRF Regulation), and help to reduce 
energy demand (Article 21c(3), point (d) of the RRF Regulation). 

There are some gaps in terms of geographical coverage, such as decarbonisation of industry, 
which is only addressed in Wallonia, and public transport, only addressed in Brussels. However, 
the decarbonisation of industry is also indirectly stimulated by the transferred investment in the H2 
transport network and by the new investment in the energy import infrastructure for H2 (both at 
federal level). 

Moreover, the measures in the REPowerEU chapter are part of Belgium’s broader efforts to 
reach  greater  energy  sovereignty  and  reduce  its  greenhouse  gas  emissions,  in  view  of  the 
EU’s 2030 climate reduction target of 55%. The envisaged measures also respond to the need 
for more ambitious climate policies (including, inter alia, the European Climate Law, the Fit For 
55 package and its implementation), an accelerated energy transition and greater energy security, 
while leaving ‘no one behind’. 

Finally, it must be noted that consultations were held with stakeholders in the preparation 
of this chapter, which have followed different steps across the various entities (i.e. the federal 
government, the three regions and the three linguistic communities). Belgium provided a summary 
of the stakeholder consultation process carried out in the context of the amendment of the RRP 
and for the preparation of the REPowerEU chapter. 

*** 

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

3.13. 

Cross-border or multi-country dimension or effect 

The  majority  of  the  measures  included  in  Belgium’s  REPowerEU  chapter  have  a  multi-
country or cross-border dimension (Table 3). The REPowerEU chapter contributes to reducing 
dependency on fossil fuels and to reducing energy demand by improving the energy efficiency of 
buildings, supporting the decarbonisation of industry, and developing the production of renewable 
energy. The measures included in the REPowerEU chapter to boost the production of renewable 

32 

 
 
 
 
 
 
energy  also  contribute  to  the  exports  of  clean  energy  to  other  parts  of  Europe.  Similarly,  the 
measures to decarbonise industry are also expected to contribute to Europe’s decarbonisation. The 
total estimated costs of these measures account for a total of EUR 658 million, representing 90,6% 
of the estimated costs of the REPowerEU chapter, above the indicative target of 30%. 

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged  in  the  REPowerEU 
chapter, the measures in the chapter are expected,  to a large extent, to have a cross-border of 
multi-country dimension or effect. This would warrant a rating of A under criterion 2.13 of Annex 
V to the RRF Regulation. 

Table 3 - Cross-border or multi-country dimension or effect of REPowerEU measures 

Cost 
(EUR 
million) 

Contribution to 
target  in  %  of 
REPowerEU 
estimated costs 

5.02 
50.97 
2.4 
30 
5.5 
25.48 
25.48 
24.02 
10.19 
8.41 
23.54 
14.00 
71.46 
5.00 
95.00 
12.50 
76.00 

19.02 

13.50 
100.00 
39.50 

657.98 

0.69% 
7.02% 
0.33% 
4.13% 
0.75% 
3.51% 
3.51% 
3.31% 
1.40% 
1.15% 
3.24% 
1.93% 
9.85% 
0.68% 
13.10% 
1.72% 
10.48% 
2.62% 

1.86% 
13.79% 
5.44% 

90.61% 

REPowerEU measures 

Improved energy subsidy scheme of the Brussels-Capital Region 
Improved energy subsidy scheme of the Flemish Region 

I-7.01 
I-7.02  
I-7.03  Energy grants for private housing of the German-speaking Community 
I-7.04  Renovation of social housing of the Walloon Region 
I-7.05  Energy-climate measures in public buildings of the Federal state 
I-7.06  Renovation of public buildings of the Flemish Region 
I-7.07  Energy measures for public schools of the Flemish Region 
I-7.08  Energy measures for the care buildings of the Flemish Region 
I-7.09  Energy measures for the VRT building of the Flemish Region  
I-7.10  Energy measures for the AWV buildings of the Flemish Region 
I-7.11  Research platform for energy transition of the French Community 
I-7.12  Energy import infrastructure of the Federal State 
I-7.13  Call for the decarbonisation of industry of the Walloon Region 
I-7.14  Call for climate action in agriculture of the Flemish Region 
I-7.15  Backbone for H2 of the Federal State 
I-7.16 
I-7.17  Optimisation of energy distribution’ of the Walloon Region 

Floating solar of the Federal State 

I-7.18 

Innovative renewable energy production initiatives of the Flemish Region 
(VLAIO) 

I-7.19  Removing barriers to renewable energy of the Federal State  
I-7.20  Off-shore energy island of the Federal State - projects 
Public LED lighting of the Flemish Region 
I-7.23 

Total 

33 

 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging7 

New or modified measures compared to the original plan are highlighted in the table below. 

Measure
/ Sub-
Measure
 ID 

R-1.01 

R-1.01 

R-1.02 

I-1.01 

I-1.02 

I-1.03 

I-1.04 

 Measure/Sub-Measure Name 

Improved energy subsidy scheme of the Flemish Region - 
home batteries 
Improved energy subsidy scheme of the Flemish Region 
(investment part) – (except home batteries)  
Improved energy subsidy scheme (investment part) – 
Brussels-Capital region  
Renovation of social housing of the Flemish Region - 
subsidies 
Renovation of social housing of the Brussels-Capital 
Region 
Renovation of social and residential housing of the 
German-speaking Community 
Renovation of public buildings of the Federal State - Stock 
Exchange building (works achieving at least 30% average 
primary energy demand reduction) 

 Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. % 

Int. 
Field 

Coeff. % 

20,05 

033 

100% 

033 

40% 

205,35 

025 

40% 

16,00 

025 

40% 

30,00 

025bis 

100% 

31,26 

025bis 

100% 

15,00 

025bis 

100% 

6,32 

026bis 

100% 

I-1.05  Renovation of public buildings – Flemish Region 

20,00 

025 

40% 

I-1.07 

I-1.07 

Public building renovations - Walloon Region – local 
authorities 
Public building renovations - Walloon Region - sport 
(energy efficiency related part)  

71,80 

026bis 

100% 

46,73 

026 

40% 

I-1.08  Public building renovations - Brussels-Capital region 

29,00 

026bis 

100% 

I-1.09 

I-1.10 

I-1.10 

I-1.11 

I-1.11 

I-1.12 

I-1.12 

Renovation of public buildings - schools – French 
Community – construction of new energy efficient 
buildings  
Renovation of public buildings - sport & IPPJ - French 
Community ((works achieving at least 30% average 
primary energy demand reduction))  
Renovation of public buildings - sport & IPPJ - French 
Community (construction of new energy efficient 
buildings)  
Public building renovations - universities - French 
Community (works achieving at least 30% average 
primary energy demand reduction) 
Public building renovations - universities - French 
Community (other energy efficiency related works) 
Public building renovations - culture - French Community 
(works achieving at least 30% average primary energy 
demand reduction) 
Public building renovations - culture - French Community 
(energy efficiency related works) 

158,00 

025ter 

40% 

16,56 

026bis 

100% 

10,65 

025ter 

40% 

12,44 

026bis 

100% 

20,74 

026 

40% 

18,79 

026bis 

100% 

19,39 

026 

40% 

7   While  the  estimated  cost  of  Belgium’s  RRP  exceeds  the  country’s  total  allocation  of  non-repayable  financial 
support, Belgium will ensure that all spending related to the measures mentioned in this table as contributing to 
climate objectives are fully financed by the funds from the RRF. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-1.15 

I-1.16 

I-1.16 

I-1.16 

I-1.17 

I-1.18 

I-1.22 

I-1.22 

An industrial value chain for hydrogen transition - Federal 
State 
An industrial value chain for hydrogen transition of the 
Flemish Region - production from renewable energy 
An industrial value chain for hydrogen transition of the 
Flemish Region - transmission, distribution, storage and 
energy systems 
An industrial value chain for hydrogen transition of the 
Flemish Region - end user refuelling & transport 
An industrial value chain for hydrogen transition’ of the 
Walloon Region – IPCEI projects  
Developing the low-carbon industry of the Walloon 
Region –R&D&I projects 
Biodiversity and adaptation to climate change of the 
Walloon Region – Forests & Remeandering 
Biodiversity and adaptation to climate change of the 
Walloon Region – Protected areas & National parks 

I-1.23  Ecological defragmentation of the Flemish Region 

I-1.24 

Blue Deal of the Flemish Region (Projects A-C-F-G-I) & 
Research and innovation (subproject B) 

I-1.24  Blue Deal of the Flemish Region (Project D) 

I-2.01 

Cybersecurity and resilient digital society of the Federal 
State 

I-2.02  Cybersecurity of the Federal State - 5G 

I-2.03 

Cybersecurity of the Federal State: NTSU/CTIF 
interception and safeguard 

I-2.04  Digitalisation IPSS of the Federal State 

50,00 

022 

100% 

7,77 

032 

100% 

62,90 

033 

100% 

033 

40% 

4,34 

077 

100% 

87,42 

032 

100%  

022 

035 
037 

050 

050 
037 
022 
047 

100% 

100% 

40% 

40% 

100% 

40% 

34,32 

24,05 

50,00 

24,70 

180,13 

10,00 

52,13 

8,26 

18,18 

60,00 

I-2.05  Digitalisation Federal administration services 

217,73 

I-2.06  eHealth Services et Health Data of the Federal State 

I-2.07  Digitalisation of ONE of the French Community 

I-2.08 

Digitalisation of the cultural and media sector of the 
French Community 

I-2.09  Digitalisation of the Flemish Government 

I-2.10 

I-2.11 

I-2.13 

I-2.14 

I-2.14 

I-2.15 

Regional data exchange platform of the Brussels-Capital 
Region 
Digitalisation of citizen-business processes of the Brussels-
Capital Region 
Coverage of white areas by developing very high-speed 
fibre optic networks of the German-speaking Community 
Development of an AI institute in the Brussels-Capital 
Region - Digital skills development 
Development of an AI institute in the Brussels-Capital 
Region - Smart specialization skills development 
Improving (internal) connectivity of schools and business 
parks in the Walloon Region – Fibre connectivity of 35 
business park.  

40,00 

16,12 

8,56 

54,50 

17,67 

33,14 

19,50 

1,47 

8,44 

15,00 

I-3.01  Cycling infrastructure of the Flemish Region 

210,91 

075 

100% 

35 

021qui
nquies 
021qui
nquies 
021qui
nquies 
011 
011 
012 
011quat
er 
027bis 
013 

011 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

021bis 

100% 

011 

011 

100% 

100% 

011 

100% 

051 

100% 

108 

100% 

016 

40% 

053 

100% 

 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-3.02 

Cycling infrastructure – Corridors Vélo of the Walloon 
Region 

I-3.03  Cycling infrastructure – Vélo Plus  

I-3.04  Cycling infrastructure – Schuman  

I-3.07  Metro extension Charleroi 

21,24 

34,10 

17,40 

60,00 

075 

075 

075 

073 

100% 

100% 

100% 

100% 

I-3.08  Smart road signals – Walloon Region 

26,64 

084bis 

40% 

084bis 

100% 

I-3.09 

I-3.09 

Accessible and multimodal train stations of the Federal 
State – urban stations  
Accessible and multimodal train stations of the Federal 
State – rural stations  

I-3.10 

Rail renovation – efficient network of the Federal State 
(TEN-T and electric/zero emission) 

I-3.10 

I-3.10 

Rail renovation – efficient network of the Federal State 
(other rail renovation) 
Rail renovation – efficient network of the Federal State – 
automatisation of the Traffic Management System 

I-3.11  Canal Albert and Trilogiport of the Walloon Region 

I-3.12  Rail – Smart mobility of the Federal State 

I-3.13 

Mobility-as-a-Service (MaaS) deployment of the Brussels-
Capital Region 

I-3.14  Modal shift grants of the Brussels-Capital Region 

I-3.15  Smart move of the Brussels-Capital Region 

I-3.16  Greening the bus fleet of the Flemish Region 

59,29 

073 

100% 

15,71 

079 

40% 

226,39 

22.32 

067 
068 
069bis 
066 
069 

100% 

40% 

10,00 

070 

40% 

070 

100% 

18,43 

15,00 

079 
082bis 
070 

40% 

40% 

5,65 

076bis 

40% 

7,00 

51,00 

55,50 

048 

063bis 
074 
077 

40% 

40% 

100% 

070 

076 

100% 

100% 

063bis 

100% 

I-3.17  Greening the bus fleet of the Brussels-Capital Region 

9,58 

074 

100% 

I-3.18  Charging stations of the Federal State 

32,00 

077 

100% 

I-3.19  Charging stations of the Flemish Region 

I-3.20  Greening the bus fleet of Wallonia 

I-4.01  Digisprong of the Flemish Community 

I-4.04 

I-4.05 

I-4.06 

Digital strategy for higher education and adult learning of 
the French Community 
Digital turnaround for Brussels schools of the Brussels-
Capital Region 
Digital transformation of education of the German-
speaking community 

I-4.08  E-inclusion for Belgium of the Federal State 

I-4.09  Digital platforms for prisoners of the Federal State 

I-4.11  Digibanks of the Flemish Region 

I-4.12 

Development of public utility housing and housing for 
vulnerable persons of the Walloon Region -Low-rent 
housing & inclusive and solidarity-based housing 

077 

074 
077 

100% 

100% 

29,46 

36,60 

286,86 

24,44 

5,20 

3,68 

30,00 

12,40 

50,00 

95,64 

025ter 

40% 

055 
012 
011 
108 

100% 

100% 

012 

100% 

012 

100% 

012 

012 

012 

100% 

100% 

100% 

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-4.12 

I-4.13 

I-4.13 

I-5.01 

Development of public utility housing and housing for 
vulnerable persons of the Walloon Region -Remote 
assistance boxes 
Creation and renovation of early childcare infrastructure of 
the Walloon Region – construction & renovation 
Creation and renovation of early childcare infrastructure of 
the Walloon Region – Software for managing immovable 
property 
A6K/E6K Digital and Technological Innovation and 
Training Hub of the Walloon Region 

I-5.02  EU Biotech School and Health Hub of the Walloon Region 

I-5.03 

I-5.04 

I-5.04 

Upgrading of advanced training infrastructure of the 
Walloon Region 
Learning and career offensive —Flemish Community - 
support to social economy 
Learning and career offensive – Flemish Community – On-
line training offer  

I-5.06  Digital skills of the Flemish region 

I-5.07  Digital lifelong learning of the Walloon Region 

I-5.08  Nuclear medicine of the Federal State 

R&D: Minimization of waste during dismantling of the 
Federal State 

15,00 

61,00 

0,42 

025ter 
026 

40% 

013 

100% 

011 

100% 

86,80 

24,80 

025ter 
026 
025ter 

40% 

40% 

46,25 

025ter 

40% 

12,00 

18,26 

34,88 

16,75 

11,60 

044 

40% 

25,00 

044 

40% 

016 

40% 

012 

100% 

012 

100% 

012 

100% 

Strengthen R&D of the Flemish Region - R&D&I projects 
and strengthening industrial research fund 

37,00 

018 
021 

40% 

Strengthen R&D of the Flemish Region - Scientific and 
technological infrastructure 
Strengthen R&D of the Flemish Region - Impulse program 
value chain microelectronics 
Relocation of food and development of logistics platforms 
of the Walloon Region 

I-5.13  Digitalisation of the Walloon touristic sector 

I-5.14  Recycling Hub of the Flemish Region 

I-5.15  Belgium Builds Back Circular of the Federal State 

I-5.16 

I-5.18 

Deployment of the circular economy in the Walloon 
Region 
SMELD: State-of-the-art MEtal MElting Limiting waste 
during D&D’ of the Federal State 

100,00 

023 

40% 

20,00 

61,49 

047 

40% 

021quat
er 

100% 

2,35 

011 

100% 

30,00 

044 

40% 

28,97 

64.85 

023 
047 
023 

40% 

40% 

13.40 

044 

40% 

I-5.10 

I-5.11 

I-5.11 

I-5.11 

I-5.12 

REPowerEU chapter 

I-7.01 

I-7.02  

I-7.03 

Improved energy subsidy scheme of the Brussels-Capital 
Region 
Scaled-up measure: Improved energy subsidy scheme of 
the Flemish Region 
Energy grants for private housing of the German-speaking 
Community 

I-7.04  Renovation of social housing of the Walloon Region 

I-7.05 

Energy-climate measures in public buildings of the Federal 
state (LED lights) 

5,02 

025 

40% 

50,97 

025 

40% 

2.40 

025 

40% 

30,00 

029 

100% 

2,50 

026 

40% 

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I-7.05 

Energy-climate measures in public buildings of the Federal 
state (charging stations and solar panels) 

3,60 

077 
029 

100% 

I-7.06  Renovation of public buildings of the Flemish Region 

I-7.07  Energy measures for public schools of the Flemish Region 

I-7.08  Energy measures for care buildings of the Flemish Region 

I-7.09 

I-7.09 

I-7.10 

I-7.11 

Energy measures for the VRT building of the Flemish 
Region (LED lights) 
Energy measures for the VRT building of the Flemish 
Region (heat pump and solar panels) 
Energy measures for the AWV buildings of the Flemish 
Region 
Research platform for energy transition of the French 
Community 

I-7.12  Energy import infrastructure of the Federal State 

I-7.13 

Call for the decarbonisation of industry of the Walloon 
Region 

I-7.14  Call for climate action in agriculture of the Flemish Region 

25,48 

026bis 

100% 

25,48 

029 

100% 

24,02 

026 

40% 

7,01 

026 

40% 

3.18 

032 

100% 

8.41 

026bis 

100% 

23,54 

022 

100% 

14,00 

022 

100% 

71,46 

022 

100% 

5,00 

024 

40% 

I-7.15  Backbone for H2 of the Federal State 

I-7.16  Floating solar of the Federal State 

I-7.17  Optimisation of energy distribution of the Walloon Region 

I-7.18 

I-7.18 

I-7.19 

Innovative renewable energy production initiatives of the 
Flemish Region  – R&D Solar energy 
Innovative renewable energy production initiatives of the 
Flemish Region – Shore-side electricity 
Removing barriers to renewable energy of the Federal 
State  

I-7.20  Off-shore energy island of the Federal State - projects 

I-7.20 

I-7.21 

Off-shore energy island of the Federal State – biodiversity 
studies and impact assessment 
Greening of the bus fleet – RBC of the Brussels-Capital 
Region 

I-7.22  Charging stations - FED of the Federal State 

I-7.23  Public LED lighting of the Flemish Region 

I-7.24  Rail – efficient network of the Federal State  

I-7.25 

Charging infrastructure for busses of the Brussels-Capital 
Region 

95,00 

033 

100% 

033* 

40% 

12,50 

029 

100% 

76,00 

033 

100% 

033* 

40% 

9,02 

022 

100% 

10.00 

080bis 

40% 

13,50 

028 

100% 

99,00 

033 

100% 

033* 

40% 

1,00 

049 

40% 

34,72 

074 

100% 

7,00 

077 

100% 

39,50 

026 

40% 

6,30 

069bis 

100% 

20,00 

077 

100% 

Int. Field = Intervention field 
Coeff. % = Coefficient for the calculation of support to climate change objectives and to digital transition, on the basis 
of Annex VI and Annex VII to the RRF Regulation 
*  Reforms  and  investments  in  the  REPowerEU  chapter  are  not  taken  into  account  when  calculating  the  plan’s 
contribution to the digital target requirement set by Regulation (EU) 2021/241. 

38