COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Greece Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10152/21; ST 10152/2021 ADD 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Greece
Date: 2023-11-21
Institutions: European Commission, Secretariat-General
Subjects: Cyprus, EU aid, EU loan, digital transformation, economic recovery, economic reform, energy policy, green economy, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.11.2023  SWD(2023) 383 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Greece Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10152/21; ST 10152/2021 ADD 1) of 13 July 2021 on the approval of the assessment of the recovery and resilience plan for Greece     {COM(2023) 749 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 ..................................................... 5 

3. 

Summary of the assessment of the plan ............................................................................................ 12 

3.1. 

Comprehensive and adequately balanced response to the economic and social situation ...... 12 

3.2. 

Link with country-specific recommendations and the European Semester ............................... 15 

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 ...... 16 

3.4. 

The principle of ‘do no significant harm’ .................................................................................... 17 

3.5.  Green transition .......................................................................................................................... 19 

3.6. 

Digital transition .......................................................................................................................... 20 

3.7. 

Lasting impact of the plan ........................................................................................................... 21 

3.8.  Milestones, targets, monitoring and implementation................................................................ 22 

3.9. 

Costing ........................................................................................................................................ 23 

3.10.  Controls and audit ....................................................................................................................... 25 

3.11.  Coherence ................................................................................................................................... 26 

3.12.  REPowerEU ................................................................................................................................. 27 

3.13.  Cross-border or multi-country dimension or effect ................................................................... 29 

ANNEX I: Climate tracking and digital tagging ........................................................................................ 31 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

While growth prospects have improved substantially compared to the pre-pandemic period, 
structural  problems  limit  the  speed  of  convergence  of  the  Greek  economy.  Despite  a 
challenging international environment, the Greek economy grew at a solid pace in 2022, driven by 
a post-pandemic recovery in tourism and a rebound in domestic demand. However, the growth 
momentum has slowed since late 2022 amid the global energy crisis and soaring inflation that keep 
on eroding households’ real disposable income. While economic growth is expected to stabilise 
above the pre-pandemic level, Greece’s exposure to natural disasters - as witnessed in 2023, as 
well as prevailing structural bottlenecks, such as a low level of judiciary efficiency, limited access 
to  financing  and  a  protracted  period  of  subdued  investments  slow  the  economic  convergence 
process. 

Greece submitted a modified recovery and resilience plan (RRP) under the Regulation (EU) 
2021/241,  requesting  an  additional  loan  amount,  adding  a  REPowerEU  Chapter  and 
adjusting several measures of the plan. For the modification of its RRP, Greece has relied on 
the following legal bases: Article 14(2) of the Regulation to include additional loan support, Article 
18(2)  to  take  into  account  the  updated  maximum  financial  contribution,  Article  21  to  amend  a 
number  of  measures  due  to  the  invoked  advent  of  unforeseeable  objective  circumstances,  and 
Article  21b  to  include  additional  resources  from  the  Brexit  Adjustment  Reserve  (BAR)  for  its 
REPowerEU chapter. 

The REPowerEU chapter contains measures to help address the key energy challenges that 
Greece is currently facing and to increase Greece’s renewable energy potential. The proposed 
measures  comprise  seven  reforms  and  four  investments,  focussing  on  energy  efficiency  in 
buildings,  decarbonisation  of  industry,  renewables  and  renewable  gases,  smart  grid,  self-
consumption and energy storage. 

The REPowerEU measures will help reduce energy demand and increase renewable energy 
and gases production, thereby contributing to the resilience and sustainability of the Union’s 
energy system and to the diversification of the energy supply of the EU. The Greek RRP will 
support  building  further  flexibilities  in  the  electricity  network  via  the  increased  installation  of 
energy storage, while increasing the resilience and security of the electricity system of the EU. 
Further reforms include the setting-up of the licensing framework to produce renewable gases and 
facilitate the installation of carbon capture, usage and storage technologies. In addition, it includes 
the optimisation of land and sea use for the development of renewables, including specific actions 
for offshore wind energy, together with a roadmap for innovative energy efficiency interventions. 
Finally, reforms promoting energy storage investments, accelerating the development of a smart 
grid  and  promoting  energy  sharing  to  facilitate  decentralised  production  and  exchange  of 
renewable energy are also included. Concerning investments, the REPowerEU chapter includes 
actions to promote energy efficiency and self-consumption through renewables, the scale-up of 
energy storage installations and pilot projects to produce renewable hydrogen and bio-methane, in 
addition  to  the  promotion  of  carbon  capture,  usage  and  storage  technologies  to  decarbonise 
industry.  The  investments  in  the  installation  of  solar  water  heaters,  renewables  for  self-

2 

 
 
 
 
 
consumption, the production of renewable gases, decarbonisation, and energy efficiency actions 
will also support the security of supply of critical technologies for the green transition of the Union. 

The modified RRP represents a comprehensive and adequate response to the economic and 
social challenges faced by Greece. Although it proposes some changes in the substance of the 
current measures, these do not affect the previous assessment of the coverage of a significant subset 
of the challenges identified in the relevant country-specific recommendations (CSRs) addressed to 
Greece in the context of the European Semester. Moreover, the modified plan keeps its focus on 
the green and digital transitions, and on promoting smart, sustainable, and inclusive growth. The 
original 18 components, with the addition of the REPowerEU chapter, continue to address the six 
pillars of the RRF and generally maintain the level of ambition despite several challenges. The 
plan  continues  to  contain  robust  milestones,  targets  and  verification  mechanisms,  and  remains 
coherent with other policy commitments.  

Based on the assessment of the submitted modification and the REPowerEU chapter, the Greek 
modified plan receives an A-rating on all criteria, except for costing (unchanged from the original 
plan assessment).   

(1) 
Balanced 
Response 

(2) 
CSRs 

(3) 
Growth, 
jobs… 

(4) 
DNSH 

(5) 
Green 
target 

(6) 
Digital 
target 

(7) 
Lasting 
impact 

(8) 
M 
& T 

(9) 
Costing 

(10) 
Control 
Systems 

(11) 
Coherence 

(12) 
REPowerEU 

(13) 
Cross-
border  

A 

A 

A 

A 

A 

A 

A 

A 

B 

A 

A 

A 

A 

(37.9%) 

(22.1%) 

2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

2.1.  Main newly emerged challenges 

Greece enjoyed a robust post-pandemic economic recovery, with a GDP growth rate of 5.6 percent 
in 2022, fuelled by a rebound in tourism and a pick-up in domestic demand. However, the Russian 
invasion  of  Ukraine  has  triggered  a  substantial  increase  in  domestic  energy  and  food  prices, 
pushing up inflation into double-digit territory by mid-2022. While the mitigating public support 
measures  have  helped  maintain  solid  economic  growth  for  a  while,  soaring  inflation  and  the 
tightened monetary stance has slowed consumption since late 2022. Further to the impact of the 
external shocks that was common to EU member states, Greece had to face two climate disasters 
in 2023: in August, widespread wildfires hit various regions and the region of Evros in Northern 
Greece was particularly badly affected; and in September, Storm Daniel led to extreme rain and 
floods in the region of Thessaly.  

Strong nominal growth in 2022 helped improve public finances and led to a substantial decline in 
the  public  as  well  as  in  the  external  debt-to-GDP  ratios.  Still,  the  country  continues  to  face 
excessive  macroeconomic  imbalances  primarily  due  to  its  high  level  of  public  and  external 
indebtedness,  which  are  assessed  in  the  Commission’s  in-depth  review.  To  respond  to  these 

3 

 
 
 
 
 
 
 
challenges,  Greece’s  modified  recovery  and  resilience  plan  supports  additional  investment  and 
reforms in the energy sector as part of its new REPowerEU chapter, as well as in a wide range of 
areas, including climate change and crisis management, while the additional EUR 5 bn of loans 
are expected to make the private economy more resilient.  

Greece’s  modified  recovery  and  resilience  plan  (RRP)  includes  a  new  REPowerEU  chapter 
pursuant to Article 21(c) of the RRF Regulation as a response to the current geopolitical and energy 
challenges of the European Union. The new measures are related to energy efficiency in buildings 
and agriculture and water sectors, renewables and renewable gases, energy storage, green industry 
and the electricity grid. This chapter will further enhance Greece’s deployment and potential for 
renewable energy, reduce energy demand and help address the current decarbonisation challenges, 
as identified in the country specific recommendations addressed to Greece in 2022 and 2023 within 
the framework of the European Semester. 

Pursuant Article 21 of Regulation (EU) 2021/241, Greece requested to amend existing measures 
of the plan because of objective circumstances. The modifications concern 52 measures, which 
Greece has identified as being no longer totally achievable, in particular, because of supply-chain 
disruptions, substantial cost increases due to inflation, litigation processes in tendering procedures, 
and  other  unexpected  measure-specific  obstacles.  In  some  cases,  measures  were  amended  or 
withdrawn because unforeseen measure-specific challenges called for an alternative approach to 
achieving  the  measure’s  objective  or  induced  a  need  to  adapt  the  measure  to  achieve  similar 
objectives in a more effective way. In this context, the description of several measures was revised 
and the respective milestones and targets were adjusted by reducing or revising their scope or by 
postponing their implementation timeline. Greece also added 8 new measures to the plan and it 
has set respective milestones. 

Pursuant to Article 18(2) of the RRF Regulation, Greece has requested modifications to its RRP 
due to the downward revision of its maximum financial contribution, from EUR 17 769 942 602 
to EUR 17 426 708 153. Because of the decrease in the maximum financial contribution Greece 
will no longer be in a position to fully implement all the measures of the original RRP. On that 
basis,  it  was  necessary  to  remove  or  scale  down  9  measures  and  to  align  the  corresponding 
milestones and targets to reflect the reduced financial allocation. 

Pursuant to Article 14(2) of the RRF Regulation, Greece has requested additional EUR 5 billion 
in loans, intended to be used as a top-up of the on-lending distribution channel of the existing Loan 
Facility  measure.  The  request  is  justified  considering  exceptional  circumstances.  Particularly, 
there is a substantial increase in interest rates for all euro area Member States, whereas Greece has 
higher  financing  costs  compared  to  other  euro  area  Member  States,  which  translates  into  high 
corporate  rates,  in  particular  for  SMEs.  The  lower  financing  costs  of  the  Loan  Facility  are 
facilitating better access to finance for companies participating in the scheme. The additional funds 
will  be  channelled  through  financial  institutions  as  loans,  with  the  objective  to  support  private 
investment  related  to  the  strategic  pillars  of  the  Loan  Facility,  namely  green  transition, 
digitalisation, increasing export capacity, economies of scale, and research and innovation. The 
current governance framework of the Loan Facility will also apply to the additional loan allocation. 
This framework provides for robust safeguards to ensure the creditworthiness of the borrowing 

4 

 
 
 
 
 
company,  projects’  financial  viability,  repayment  of  funds  and  compliance  with  the  RRF 
requirements,  while  an  independent  Investment  Board  monitors  the  Facility’s  aggregate 
performance. Moreover, the on-lending channel of the Loan Facility has demonstrated very good 
progress up to date, and the loan contracts signed and the market demand for the scheme show that 
the investment uptake is expected to continue at an elevated pace. 

2.2.  Main elements of the modified RRP and REPowerEU chapter 

The most important elements of the modified RRP, including the REPowerEU chapter, are listed 
below by component. 

•  Component  1.1.  on  power-up  measures  is  modified  by  the  postponement  and  the 
adjustment of the scope of the investment for the rehabilitation of areas of former lignite 
mines in Western Macedonia and Megalopolis due to the need to use part of these territories 
to produce lignite as a response to the recent energy crisis, which lead to the prolongation 
of the operation of the lignite fired power plants.  

•  Component 1.2 on renovation measures is modified by the postponement of the timeline 
of the completion of the upgrading investment in the Olympic Athletic Centre of Athens 
due to unforeseen delays in the project implementation, and by the scaling down of the 
envisaged  energy  upgrading  of  other  public  sector  buildings  due  to  unexpectedly  low 
demand. As concerns the energy renovation on residential buildings, it has been adjusted 
to also take into account interventions relating to new renewable energy produced in line 
with the initially set objective.  

•  Component  1.3  on  recharge  and  refuel  is  modified  by  expanding  the  scope  of  the 
envisaged support for industrial units to also cover projects related to the green transition 
in order to allow for wider participation of companies, as the previous requirements limited 
the number of the companies eligible to apply to the scheme. Certain adjustments in the 
scope and timeline of the investments to promote electromobility have also been made.  

•  Component 1.4 on sustainable use of resources, climate resilience and environmental 
protection  is  modified  by  the  scaling  down  of  the  envisaged  reforestation  investment, 
including in Mount Parnitha, and the addition of new investments to support anti-fire, anti-
erosion, flood protection and restoration actions and respond to the natural disasters that 
occurred in Evros and Rhodope regions. The modified RRP also contains a new measure 
on  preliminary  inspection  of  seismic  resistance  of  public  buildings  and  a  postponed 
completion timeline for implementing Regional Civil Protection Centers (PEKEPP) due to 
unforeseen delays in securing some land plots (such as unforeseen issues with planning 
permits).  

•  Component 2.1 on connectivity measures is modified by the removal, due to the decreased 
maximum financial allocation, of the planned investment for the deployment of modern 
submarine fibre cables between mainland Greece and its islands and Cyprus. Moreover, 
Greece has proposed not to invest in the development of 5G networks aimed to provide 

5 

 
 
 
 
 
coverage of all Greek motorways that are part of the Trans-European Transport Networks, 
due to the low level of maturity of the market for this type of infrastructures.    

•  Component  2.2  on  modernisation  measures  is  modified  by  the  removal,  due  to  the 
decreased maximum financial allocation, of the planned investment for the enhancement 
of public sector's business continuity.  

•  Component 2.3 on digitalisation of businesses is modified by the reduction of the scope 
of the investment for the digital transformation of SMEs (from 500.000 to 400.000 cash 
registers to be upgraded or replaced with computer-based solutions), due to low demand. 

•  Component 3.1 on job creation and participation in the labour market is modified by the 
postponement of a large hiring subsidy programme that also contains a training part, due 
to unforeseen capacity constraints of implementation bodies. Greece has also proposed an 
extension  of the timeline for the digital transformation  of the labour market  monitoring 
systems  in  order  to  improve  the  design  of  the  measure  and  allow  it  to  better  serve  its 
purpose. 

•  Component 3.2 on education, vocational education and training, and skills is modified 
by  the  removal  of  the  planned  investment  for  the  development  and  certification  by  the 
National  Organisation  for  the  Certification  of  Qualifications  and  Vocational  Guidance 
(EOPPEP)  of  200  occupational  profiles,  reflecting  the  decreased  maximum  financial 
allocation. Moreover, Greece has proposed a scaling down of investments on university 
research, due to low demand. 

•  Component 3.3 on improving resilience, accessibility and sustainability of healthcare is 
modified by the slight postponement of the contract award for the renovation of 156 health 
centres  due  to  unexpected  complications  with  the  tendering  process,  as  well  as  by  the 
postponement of the completion of a national digital health record because of the existence 
of  a  manifestly  better  approach  to  implement  the  measure.  Moreover,  Greece  has 
introduced  a  new  primary  healthcare  reform  that  aims  to  increase  the  number  of  the 
available  general  practitioners  and  internists  and  achieve  full  population  coverage. 
According to the reform, each citizen will be registered to a personal doctor who will act 
as the first point of contact, provide primary care, and help the citizen navigate into the 
health system.  

•  Component 3.4 on access to effective and inclusive social policies is modified, as a result 
of  the  decreased  maximum  financial  allocation,  by  the  scaling  down  of  the  planned 
diversity awareness programme of the public and private sector. Moreover, the investment 
for creating childcare units within large companies is withdrawn from the plan due to the 
lack of demand on the side of the companies, while the number of new childcare places in 
public and private childcare centres is reduced from 50 000 to 20 000. The completion of 
the personal  assistance programme for persons  with disabilities and the implementation 
timelines and scope of the child protection investments are revised in order to adjust the 
design of the measures and allow them to better serve their purpose.  

6 

 
 
 
 
 
•  Component 4.1 on making taxes more growth friendly and improving tax administration 
and tax collection is modified by the slight postponement of the completion timeline as 
well as by the adjustment of the scope of the digital transformation of tax audits, in order 
to specify more concrete deliverables that are fully aligned with the tax administration’s 
strategy on how to digitalise audits, and relate to the development of business intelligence 
and data analytics systems.. Greece has also proposed a new reform of the structure of self-
employment taxation, the replacement of the stamp duty with a simpler digital tax, and a 
major extension  of the mandatory acceptance of direct  electronic payments  in  the retail 
market.  

•  Component 4.2 on modernising the public administration is modified by the addition of 
a new reform to complete the national cadastre, which is a long-standing project that is 
expected to improve Greece’s business environment. Greece has also proposed to extend 
the timeline for the launching of a platform for the collection of data held by anti-money 
laundering competent authorities, due to complications with the tendering process. 

•  Component 4.3 on the efficiency of the justice system is modified by the introduction of 
the  specification  that  the  National  School  of  Judicial  Clerks  will  be  set  up  under  the 
auspices  of  the  already  functioning  National  School  of  Judges  rather  than  as  a  separate 
entity; and also by the removal, due to the decreased maximum financial contribution, of 
part of the investment planned for the digital transformation of the Greek justice system 
related to administrative justice.  

•  Component 4.4 on strengthening the financial sector and capital markets is modified by 
the  extension  of  the  timeline  for  the  implementation  of  the  new  unified  insolvency 
framework in order to reflect the latest legal amendments in the relevant digital platform, 
as  well  as  by  the  incorporation  of  the  functions  of  the  planned  Credit  Expansion 
Observatory under the Central Credit Registry. The scope of the existing financial sector 
reforms under this component is widened by adding measures aimed at facilitating the debt 
enforcement  process  and  enhancing  the  efficiency  of  the  non-performing  loans  (NPL) 
secondary market. 

•  Component 4.5 on promoting research and innovation is modified by the reduction of the 
number of research centres to be supported for upgrading their infrastructure due to the 
inability of certain centres to secure private financing. Greece has also proposed to add a 
milestone  for  procuring  research  centres’  equipment.  Further,  Greece  suggested  to 
postpone  the  contract  award  for  an  information  system  on  civil  protection  and  disaster 
resilience,  with  a  view  to  conducting  an  international  tender  that  will  ensure  high-level 
expertise. 

•  Component 4.6 on resilience of key economic sectors is modified by the postponement of 
the secondary legislation on business parks on account of more complex legal provisions 
than initially foreseen, and the postponement of measures in support of the cultural and 
sector  on  account  of  a  reform  which  establishment  a  new  body  for  audio-visual  media. 
Similarly, the digital transformation of the agri-food sector, the planned upgrades of tourist 

7 

 
 
 
 
 
ports and the completion of the Trikala-Egnatia section of the Central Greece Highway E-
65 are postponed due to unforeseen circumstances, namely considerably longer than usual 
delays in issuing the necessary decisions and the delayed implementation of legislation on 
tourist  ports,  while  investments  in  the  upskilling  of  creative  and  cultural  professionals, 
electronic  tolls  infrastructures  and  trade  facilitation  are  removed  due  to  the  decreased 
maximum  financial  allocation.  A  new  investment  measure  aiming  at  restoring  the 
accessibility to the road and rail networks in the areas affected by the devastating effects 
of the storm Daniel in September 2023, is also added.  

•  Component  4.7 on improving competitiveness  and promoting private investments  and 
exports  is  modified  by  the  postponement  of  the  adoption  of  legislation  for  the 
simplification  of  the  business  environment  due  to  the  need  to  adopt  differentiated  legal 
provisions for a number of geographical areas, due to the large variability identified when 
analysing the specific circumstances of each area. Moreover, EUR 5 billion are added to 
the on-lending distribution channel of the Loan Facility measure (see also section 2 above). 
Further, the green and digital commitments are removed from the InvestEU Member State 
compartment of the Loan Facility due to insufficient market demand.  

REPowerEU chapter  

Under the REPowerEU chapter and based on Article 21c of Regulation (EU) 2021/241, Greece 
has proposed seven new reforms and four new investments (out of which two are scaled-up) for 
EUR 794 821 929. 

In particular, the chapter includes the following new reforms: 

•  Licencing and support scheme framework for biomethane and green hydrogen (measure 
16987) aiming to introduce a legislative framework to allow and facilitate the production, 
storage,  transport,  and  use  of  the  renewable  hydrogen  and  biomethane.  The  proposed 
reform aims to reduce the dependency on natural gas for electricity production, heating and 
cooling and the transport sector enabling the faster phase-out of fossil fuels and enhancing 
the security of supply. 

•  Regulatory  and  market  operation  framework  for  carbon  capture,  usage,  and  storage 
technologies  to  foster  industry  decarbonisation  (measure  16988)  aims  to  introduce  the 
framework for the operation of the said technologies in Greece, enabling the reduction of 
CO2 emissions across the industry.  

•  Optimisation of land and sea space usage for the development of RES (measure 16989) is 
planned  to  further  incentivise  renewable  energy  production  in  Greece  with  a  particular 
attention  to  agri-voltaic  energy.  In  addition,  the  reform  aims  to  further  advance  the 
framework for the installation of offshore wind farms in Greece.  

•  Grid and storage capacity – fostering of storage investments (measure 16990) is planned 
to  contribute  to  addressing  grid  stability  and  bottlenecks,  create  resilience  against  high 
electricity  prices,  increase  the  flexibility  of  the  system  and  foster  the  integration  of 
renewables.   

8 

 
 
 
 
 
 
•  Regulatory  framework  towards  a  smart  grid  (measure  16991)  will  accelerate  the 
implementation of smart and digital technologies in the distribution network, and foster 
demand side response for the final consumer.  

•  Toolset to promote energy sharing (measure 16992) will encourage the use of renewables 
by allowing decentralised generation and sharing among multiple small-scale renewable 
energy  systems,  enhancing  self-consumption  and  renewable  energy  communities  in 
Greece.   

•  Roadmap for innovative energy efficiency interventions and identification of new financial 
instruments  (measure  16993)  focuses  on  the  promotion  of  new  financial  instruments 
concerning energy efficiency, by encouraging the renovation of dwellings and industrial 
buildings.  

In addition, the chapter foresees the following new and scaled-up investments: 

•  Energy efficiency and promotion of RES for auto-consumption (measure 16994) foresees 
the  implementation  of  five  different  subprogrammes,  specifically  on:  (i)  the  energy 
renovation  of  residential  buildings through  the  provision  of  subsidies;  (ii)  the  energy 
renovation  of  the  non-residential  public  and  private  buildings through  the  provision  of 
subsidies;  (iii)  installation  of  photovoltaic  systems  for  self-consumption  in  residential 
buildings  and  in  the  agricultural  sector  through  the  provision  of  subsidies;  (iv)  the 
promotion of renewable energy sources in residential buildings by financing the installation 
of  new  renewable  systems  to  produce  hot  water;  and  (v)  the  improvement  of  energy 
efficiency in municipal water and sewerage utilities through the replacement of the existing 
electro-mechanical equipment in the wells with new and more energy efficient equipment.  
Installation of energy storage systems for  additional  RES penetration  is a scale up of a 
current measure under the Greek RRP (measure 16926 Support of the installation of storage 
systems  to  enhance  RES  penetration)  and  will  support  new  energy  storage  standalone 
systems of all technologies.  

• 

•  Pilot  projects  for  biomethane  and  renewable  hydrogen  (measure  16995)  foresees  the 
implementation  of  an  investment  for  the  support  of  the  construction  of  new  production 
plants and the upgrade of existing plants to produce biomethane and the installation of the 
required equipment for the production of renewable hydrogen.  

•  Promotion  of  carbon  capture  and  storage  (CCS)  technologies  to  foster  industry 
decarbonisation (measure 16997) foresees the investment in the transport component of 
the  carbon  capture  and  storage  unit  of  Prinos,  covering  emissions  from  hard  to  abate 
industries.  

Table of new and modified components and associated costs  

Component 

1.1. Power up 

Status 

Costs (EUR million) 

Modified 

1 125.63 

9 

 
 
 
 
 
 
1.2. Renovate 

1.3. Recharge and refuel 

1.4.  Sustainable  use  of  resources,  climate  resilience 
and environmental protection 

2.1. Connect 

2.2. Modernise 

2.3. Digitalisation of businesses 

3.1.  Promote  job  creation  and  participation  in  the 
labour market 

Modified 

2 661.81 

Modified 

520.00 

Modified 

1 711.01 

Modified 

331.63 

Modified 

1 241.40 

Modified 

362.10 

Modified 

776.33 

3.2. Education, vocational education and training, and 
skills 

Modified 

2 226.95 

Improve 

3.3. 
sustainability of healthcare 

resilience, 

accessibility 

and 

Modified 

1 485.73 

3.4. Increase access  to  effective  and inclusive social 
policies 

Modified 

737.24 

4.1.  Making 
improving tax administration and tax collection 

taxes  more  growth  friendly  and 

Modified 

185.23 

4.2.  Modernise  the  public  administration,  including 
through  speeding  up  the  implementation  of  public 
investments, 
the  public  procurement 
framework, capacity building 

improving 

Modified 

188.77 

4.3. Improve the efficiency of the justice system 

Modified 

242.84 

4.4.  Strengthen  the  financial  sector  and  capital 
markets 

Modified 

19.86 

4.5. Promote research and innovation 

Modified 

447.49 

4.6.  Modernise  and 
economic sectors 

improve  resilience  of  key 

Modified 

4 181.94 

4.7.  Improve  competitiveness  and  promote  private 
investments and trade 

Modified 

17 728.40 

REPowerEU 

New 

794.82 

Other elements not covered by assessment criteria  

10 

 
 
 
 
 
 
The description of the consultation process and the planned communication strategy as set 
out  in  the  previous  Staff  Working  Document  (SWD)  (2021)155  remains    relevant  for  the 
modified  RRP.  As  concerns  the  consultation  process,  the  Greek  authorities  confirmed  that  a 
general public consultation process on the principles of the revised plan was conducted through 
various channels, including with the Economic and Social Committee (ESC) of Greece. The public 
consultation process that was based on a summary of the principles of the revised plan (8 page 
document)1 took place between 31 July to 14 August 2023 with nine comments submitted in total, 
and in the submitted addendum, Greece sets out how the various comments were reflected in the 
revised plan, including the REPowerEU chapter.. As concerns the communication strategy, Greece 
confirms that the strategy submitted with the original plan in 2021 remains valid and that it has 
been complemented with a “National Recovery and Resilience Plan Greece 2.0 Communication 
Guide”2.  

Greece  has  explained  that  several  measures  added  to  the  recovery  and  resilience  plan, 
including  under  the  REPowerEU  chapter,  will  have  a  positive  impact  on  socio-economic 
inclusion and equal opportunities for all. The introduced personal doctor reform should increase 
the number of personal doctors to act as the first point of contact, provide primary health care, and 
help  citizens  navigate  in  the  health  system,  thereby  promoting  access  to  healthcare  and  equal 
opportunities  for  all.  The  REPowerEU  chapter  includes  actions  that  aim  to  contribute  towards 
addressing energy poverty. In particular, a new reform is introduced and complemented by the 
upscaling  of  energy  efficiency  renovations  in  residential  buildings.  The  reform  is  expected  to 
establish  a  set  of  policy  tools  to  promote  collective  self-consumption,  energy  sharing  and 
renewable energy communities, which are expected to result in lower energy costs for energy poor 
households.  Further,  the  investment  measure  on  energy  efficiency  renovations  will  specifically 
target lower income households, as was the case with a measure that was part of the original plan. 
The nature and extent of the proposed modifications to Greece’s recovery and resilience plan do 
not have an impact on its gender equality aspects, as described in SWD (2021)155 

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

1 http://www.opengov.gr/minfin/?p=11972 
2 https://greece20.gov.gr/epikoinwnia-dimosiotita/ 
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 

11 

 
 
 
 
 
 
 
 
 
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 Greece in the recovery and resilience plan cannot be deemed a State aid 
notification. In as far as Greece considers that a specific measure contained in the recovery and 
resilience plan entails de minimis aid or aid exempted from the notification requirement, it is the 
responsibility of Greece to ensure full compliance with the applicable rules. 

3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

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

situation  

The modification of the plan, along with the REPowerEU chapter has a material impact only on 
the assessment of the contribution of the RRP to the green transition (first pillar), as presented in 
the table below. For the other pillars, the nature and extent of the proposed modifications to the 
RRP  do  not  have  an  impact  on  the  previous  overall  assessment  of  the  plan  representing  a 
comprehensive and adequately balanced response to the economic and social situation, and on its 
appropriate  contribution  to  all six  pillars referred to  in  Article 3 of Regulation (EU) 2021/241. 
Alongside cost and implementation considerations, the need to mitigate the negative impact of the 
natural disasters that hit Greece in the second half of 2023 and to strengthen prevention was also 
one of the reasons behind part of the plan revision. 

While the withdrawal of the measures related to the development of Submarine Fibre Cables and 
the 5G networks providing coverage of all Greek motorways reduces the RRP’s impact  on the 
digital  transformation  (second  pillar),  still,  the  contribution  of  the  plan  to  the  pillar  remains 
substantial and well above the minimum threshold.  

The  modified  plan  will  continue  strengthening  the  country's  health  and  economic,  social,  and 
institutional resilience, as described in the fifth pillar. In particular, the personal doctor reform will 
allow citizens to be registered to a personal doctor who will act as the first point of contact in terms 
of the primary care and thus will contribute to improving the accessibility of the healthcare system. 
The reform for the completion of the national cadastre is expected to provide clear property rights 
and titles, and establish an efficient land registry system in Greece, thereby improving the quality 
of and accessibility to services, and ultimately promoting smart, sustainable, and inclusive growth. 

As for the first pillar, the modified RRP includes additional measures to address green challenges, 
namely  anti-erosion  and  flood  protection  measures  brought  forward  after  the  recent  natural 
disasters, which complement the civil protection measures of the initial plan (under component 

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,  available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1315. 

12 

 
 
 
 
 
 
 
 
1.4). The significant scale-up of the RRF Loan Facility will support private investment primarily 
related to the first two pillars, namely green transition and digitalisation, but will also contribute 
to increasing export capacity, economies of scale, and research and innovation.  

The measures comprising the REPowerEU chapter address to a large extent the objectives of the 
REPowerEU Plan, namely saving energy, producing clean energy and diversifying energy supply. 
The implementation of the planned measures is expected to effectively contribute to increasing 
energy efficiency and decarbonising the industry, increasing production and uptake of renewable 
hydrogen  and  bio-methane,  and  increasing  the  deployment  of  renewable  energy  through 
investments  in  storage  and  renewable-based  applications,  together  with  reforms  promoting 
offshore wind and the transition towards a smart grid and energy sharing. The measures included 
in  the  REPowerEU  chapter  are  expected  to  contribute  to  the  green  transition  and  to  smart, 
sustainable and inclusive growth. 

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

Green 
transition 

Digital 
transform
ation 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

1.1 Power Up 

1.2 Renovate 

1.3 Recharge and refuel 

1.4 Sustainable use of 
resources, climate 
resilience and 
environmental protection 

2.1 Connect 

2.2 Modernise 

2.3 Digitalisation of 
businesses 

3.1 Increasing job creation 
and participation in the 
labour market 
3.2 Education, vocational 
training, and skills 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

○ 

○ 

○ 

● 

○ 

● 

● 

● 

13 

● 

● 

● 

● 

● 

Health, 
and 
economic, 
social and 
institution
al 
resilience 

Policies 
for the 
next 
generati
on 

○ 

○ 

○ 

○ 

● 

● 

● 

 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
○ 

● 

○ 

○ 

● 

● 

● 

● 

● 

● 

● 

● 

● 

○ 

○ 

● 

● 

○ 

○ 

3.3 Improve resilience, 
accessibility and 
sustainability of 
healthcare 

[3.4 Increase access to 
effective and inclusive 
social policies] 

4.1 Making taxes more 
growth friendly, and 
improving tax 
administration and tax 
collection 

4.2 Modernise the public 
administration 

4.3 Improve the efficiency 
of the justice system 

● 

4.4 Strengthen the 
financial sector and capital 
markets 

4.5 Promote research and 
innovation 

4.6 Modernise and 
improve resilience of key 
economic sectors 

4.7 Improve 
competitiveness and 
promote private 
investment and trade 

Loan facility 

REPowerEU chapter 

Total number of 
components that 
significantly contribute to 
pillar 

○ 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

● 

○ 

○ 

○ 

● 

● 

○ 

● 

● 

● 

● 

○ 

14 

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

*** 

Taking into consideration all reforms and investments envisaged by Greece, its modified recovery 
and  resilience  plan  continues  to  represent,  to  a  large  extent,  a  comprehensive  and  adequately 
balanced response to the economic and social situation, thereby contributing appropriately to all 
six pillars referred to in Article 3 of the RRF Regulation, taking the specific challenges and the 
financial allocation of Greece into account. This would warrant a rating of A under criterion 2.1 
in Annex V to the RRF Regulation. 

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

As  the  size  of  the  plan  increased  following  an  additional  loan  request,  all  2022  and  2023 
structural country specific recommendations (CSRs) addressed to Greece in the context of 
the European Semester are considered relevant in the overall assessment.  In the 2022 and 
2023  CSRs,  Greece  was  recommended  to  act  on  six  main  areas:  (i)  improve  the  investment-
friendliness of the taxation system (CSR 1 2022 and CSR 1 2023); (ii) safeguarding the efficiency 
of the public administration (CSR 1 2022 and CSR 1 2023); (iii) pursue the ongoing reduction of 
non-performing loans and further improve the functioning of the secondary non-performing loans 
market (CSR 1 2023); (iv) complete outstanding reforms that have been pursued under enhanced 
surveillance, including the cadastre reform (CSR 3 2022 and CSR 3 2023); (v) ensure adequate 
and equal access to healthcare (CSR 3 2022 and CSR 3 2023); and (vi) reduce reliance on fossil 
fuels,  further accelerate  the diversification of energy supply routes,   expand the deployment  of 
renewable energy, including decentralised production, increasing electricity network and storage 
capacity, improve energy efficiency, including targeted measures for energy-poor households and 
the  installation  of  smart  meters,  undertake  policy  efforts  aimed  at  the  provision  of  skills  and 
competences  needed  for  the  green  transition  and  support  the  decarbonisation  of  the  transport 
sector, in particular by promoting electric vehicles. (CSR 4 2022 and CSR 4 2023).  

The modified RRP includes a new tax policy reform and is set to strengthen the measures 
relating to the financial sector. Under Component 4.1, Greece has included a new reform aiming 
to enhance the transparency of the tax framework and the further use of electronic payments to 
combat  tax  evasion.  Specific  actions  include  legal  provisions  to  improve  the  structure  of  self-
employment  taxation,  the  replacement  of  stamp  duty  with  a  simpler  digital  tax,  and  a  major 
extension on of the mandatory acceptance of direct electronic payments in the retail market. These 
measures  contribute  towards  the  long-term  sustainability  of  Greece’s  public  finances.  Under 
Component 4.4, Greece has widened the scope of the financial sector reforms already contained 
in the plan addressing the debt enforcement process and the NPL secondary market. These new 
measures are expected to contribute towards meeting the related sub-parts under CSR 1 2023 and 
CSR 1 2022. 

15 

 
 
 
 
 
 
The  modified  RRP  also  includes  a  cadastre  reform  and  new  healthcare  measures.  The 
completion of the national cadastre (part of Component 4.2), a long-standing project, is expected 
to further improve Greece’s business environment by enhancing efficiency of property transactions 
and  strengthening  legal  certainty.  Specifically,  actions  to  complete  cadastral  mapping  and  the 
transition to the new ‘Hellenic Cadastre Agency’ will contribute to addressing CSR 3 2023 and 
CSR  2  2022.  Greece  also  proposed  a  new  reform  of  personal  doctor  (part  of  Component  3.3), 
which will contribute to addressing CSR 3 2023 and CSR 3 2022.  

The REPowerEU chapter introduces new measures contributing to reducing the reliance on 
fossil fuels (CSR 4 2022 and 2023). New reform measures aim to further expand the deployment 
of renewable energy by completing the legal framework for offshore wind farms and putting in 
place new legislative frameworks for the production of renewable hydrogen and bio-methane. New 
investment measures support the increase of storage capacity and the decentralised production of 
renewable  energy.  Further,  additional  support  is  allocated  to  improve  the  energy  efficiency  of 
households, including targeted support for energy-poor households, and the private sector. 

Greece’s  modified  RRP  continues  to  address  all  or  a  significant  subset  of  challenges 
identified  in  the  relevant  CSRs,  including  the  new  CSRs  adopted  in  2022  and  2023.  The 
priorities of the plan are coherent with progress on the relevant country-specific recommendations.  
In summary, the original assessment of this criterion has not changed, which concluded that the 
RRP adopted in 2021 effectively addressed a significant subset of the 2019 and 2020 CSRs. In 
addition, the assessment of this criterion for the revised plan concludes that a significant subset of 
the 2022 and 2023 CSRs are addressed. 

*** 

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

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  modified  recovery  and  resilience  plan  of  Greece  is  expected  to  contribute  to  supporting 
growth,  job  creation,  economic,  institutional  and  social  resilience,  and  the  European  Pillar  of 
Social  Rights,  while  mitigating  the  impact  of  the  crisis,  and  social  territorial  cohesion  and 
convergence.  

The  proposed  investments  and  reforms  under  the  REPowerEU  chapter,  including  the  energy 
renovations of residential buildings and the large-scale investments in renewable energy sources 

16 

 
 
 
 
 
 
and energy storage capacities have the potential to support economic growth and employment in 
a wide range of economic sectors and activities, while eliminating energy poverty.  

Moreover, the reform on the Hellenic Cadastre is expected to have a positive economic and social 
impact by providing clear property rights and titles and an efficient land registry system, which is 
expected to facilitate economic activities related to real estate transactions and promoting private 
investments. The EUR 5 billion scale up to the RRP Loan Facility measure is expected to boost 
growth and job creation through the financing of long-term private investments in the green and 
digital transition, among other areas.  

Other newly introduced measures that promote social resilience include the Personal Doctor (PD) 
reform that aims at increasing access, reducing inequalities, promoting health and prevention. At 
the  same  time,  a  new  proposed  investment  will  enable  the  preliminary  inspection  of  seismic 
resistance of schools, universities, hospitals, police stations and fire stations thereby improving 
crisis management and hazard mitigation and increasing social resilience.  

*** 

Taking into consideration all reforms and investments envisaged by Greece, its modified recovery 
and resilience plan is expected to have a high impact on strengthening the growth potential, job 
creation, and economic, social and institutional resilience of the Member State, on contributing to 
the implementation of the European Pillar of Social Rights, including through the promotion of 
policies for children and youth, and on mitigating the economic and social impact of the COVID-
19 crisis, thereby enhancing the economic, social and territorial cohesion and convergence within 
the  Union.  This  would  warrant  a  rating  of  A  under  criterion  2.3  of  Annex  V  to  the  RRF 
Regulation.” 

3.4.  The principle of ‘do no significant harm’  

Greece’s  modified  recovery  and  resilience  plan  including  the  REPowerEU  chapter  is 
expected to continue to ensure that no measure included in the plan does significant harm to 
environmental  objectives,  within  the  meaning  of  Article  17  of  the  Taxonomy  Regulation. 
None  of  the  measures  included  in  the  REPowerEU  chapter  requires  a  DNSH  derogation. 
Greece has assessed compliance with the ‘do no significant harm’ (DNSH) principle following the 
methodology  set  out  in  the  Commission’s  technical  guidance  on  the  application  of  ‘do  no 
significant  harm’  under  the  RRF  Regulation  (2021/C  58/01).  The  assessment  covers  the  six 
environmental objectives within the meaning of Article 17 of Regulation (EU) No 2020/852 and 
is applied to all new measures in Greece’s modified recovery and resilience plan, including the 
REPowerEU ones, as well as to measures that include substantial changes in nature and scope. 
Based on information provided by Greece, there is either no risk of significant harm, or where a 
risk is identified, a more detailed assessment is performed demonstrating the absence of significant 
harm. 

Regarding  the  investment  on  the  promotion  of  CCS  technologies  to  foster  industry 
decarbonisation,  Greece  has  committed  to  accompany  the  construction  of  the  transport 
infrastructure component with a climate risk and vulnerability assessment regarding the climate 

17 

 
 
 
 
 
change adaptation of the measure. In addition, specific provisions apply regarding the obligations 
for  re-use,  recycle  and  other  material  recovery  of  the  construction  waste.  In  addition,  specific 
provisions are addressing the environmental degradation risks related to preserving water quality 
and  avoiding  water  stress  are  identified  and  addressed,  in  accordance  with  a  water  use  and 
protection management plan. Finally, compliance with EU legislation shall be required to avoid 
harm to the biodiversity objective, and more specifically the Environmental Impact Assessment 
Directive and, for sites/operations located in or near biodiversity-sensitive areas, Articles 6(3) and 
12 of the Habitats Directive, and Article 5 of the Birds Directive. The facility capturing CO2 to 
which the infrastructure is connected shall meet the ETS benchmark condition as set out in the 
Technical Guidance (2021/C58/01) and the CO2 captured stems from unavoidable emissions (such 
as process emissions, for example for cement). The pipeline is planned to become operational by 
2026 with the works being completed by the end of 2025 and to transport CO2 flows from the ETS 
installations fullfiling the below conditions: 

In order to ensure that the measure complies with the ‘Do no significant harm’ Technical Guidance 
(2021/C58/01),the  eligibility  criteria  contained  in  terms  of  reference  for  upcoming  calls  for 
projects shall exclude the following list of activities: (i) activities related to fossil fuels, including 
downstream use4; (ii) activities under the EU Emission Trading System (ETS) achieving projected 
greenhouse gas emissions that are not lower than the relevant benchmarks5; (iii) activities related 
to  waste  landfills,  incinerators6  and  mechanical  biological  treatment  plants7;  and  (iv)  activities 
where the long-term disposal of waste may cause harm to the environment.  

In  the  case  of  hydrogen  (16995_Pilot  projects  for  Biomethane  and  Renewable  Hydrogen 
Production), specific safeguards on the production typologies to be financed were inserted, 
together with specific reference to hydrogen to be “renewable”, bio-methane to be “sustainable” 
and  in  line  with  RED  II  Delegated  Acts.  In  this  way,  we  ensured  that  only  DNSH  compliant 
hydrogen will be financed in the new measure. The scale-up of energy efficient renovations, as 

4 Except for (a) projects under this measure in power and/or heat generation, as well as related transmission and 
distribution infrastructure, using natural gas, that are compliant with the conditions set out in Annex III of the ‘Do 
no significant harm’ Technical Guidance (2021/C58/01) and (b) activities and assets under point (ii) for which the 
use of fossil fuels is temporary and technically unavoidable for the timely transition towards a fossil fuel free 
operation 
5 Where the activity supported achieves projected greenhouse gas emissions that are not significantly lower than the 
relevant benchmarks an explanation of the reasons why this is not possible should be provided. Benchmarks 
established for free allocation for activities falling within the scope of the Emissions Trading System, as set out in 
the Commission Implementing Regulation (EU) 2021/447 
6 This exclusion does not apply to actions under this measure in plants exclusively dedicated to treating non-
recyclable hazardous waste, and to existing plants, where the actions under this measure are for the purpose of 
increasing energy efficiency, capturing exhaust gases for storage or use or recovering materials from incineration 
ashes, provided such actions under this measure do not result in an increase of the plants’ waste processing capacity 
or in an extension of the lifetime of the plants; for which evidence is provided at plant level 
7 This exclusion does not apply to actions under this measure in existing mechanical biological treatment plants, 
where the actions under this measure are for the purpose of increasing energy efficiency or retrofitting to recycling 
operations of separated waste to compost bio-waste and anaerobic digestion of bio-waste, provided such actions 
under this measure do not result in an increase of the plants’ waste processing capacity or in an extension of the 
lifetime of the plants; for which evidence is provided at plant level 

18 

 
 
 
 
 
 
 
well as the housing support to young people, are also in line with the DNSH principle. While 
renovations  have  a  positive  impact  on  emission  reductions,  they  normally  create  significant 
amounts  of  construction  waste.  Greece  ensures  no  significant  harm  to  the  circular  economy 
objective by detailing in the self-assessments for each of the measures that at least 70% (by weight) 
of the non-hazardous construction and demolition waste generated on the construction sites are set 
to be prepared for reuse, recycling and other material recovery. 

Concerning the modifications related to component 1.4 (Sustainable use of resources, climate 
resilience and environmental protection), the DNSH principle is expected to continue to be 
respected.  The  additional  projects  concerning  restoring  the  accessibility  to  the  road  and  rail 
networks in the areas affected by the effects of the storm Daniel, together with the new anti-flood, 
restoration  and  anti-fire  measures  also  provide  the  necessary  guarantees  in  the  DNSH  self-
assessment.   

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in the modified Greece’s recovery 
and  resilience  plan,  including  the  REPowerEU  chapter,  is  expected  to  do  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  modified  Greek  recovery  and  resilience  plan  increases  its  contribution  to  the  green 
transition  compared  to  the  original  plan  adopted  in  July  2021.  The  modified  recovery  and 
resilience plan 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. The new measures introduced,  in particular the REPowerEU 
chapter,  bring  a  significant  contribution  to  the  green  transition  in  Greece,  while  the  measures 
whose  scope  was  reduced  due  to  increased  costs  and  delays  do  not  impact  the  overall  green 
transition  ambition  of  the  plan.  Moreover,  the  Loan  Facility  maintains  the  commitment  for 
financial institutions to invest at least 38.5% of the funds to support the green transition. 

The green transition contribution of the REPowerEU chapter is ambitious. All new measures 
under REPowerEU chapter - four investments and seven reforms - aim at reducing the reliance on 
fossil fuels. They are expected to contribute to a number of the REPowerEU objectives under Art. 
21c(3) of the RRF Regulation, including increasing energy efficiency, fighting energy poverty, 
incentivising the reduction of energy demand and addressing internal and cross-border bottlenecks. 
The climate contribution of the REPowerEU chapter is of 78.1% of the total estimated costs of the 
measures  included  in  the  REPowerEU  chapter,  well  above  the  37%  target  set  out  in  the  RRF 
Regulation.  

19 

 
 
 
 
 
 
In  total,  Greece’s  modified  Recovery  and  Resilience  plan,  including  the  REPowerEU 
chapter, contributes for 38.1% (EUR 13.69 billion) to the climate target, which is above the 
target of 37% required by the RRF Regulation.  

*** 

*** Taking into consideration the assessment of all the measures envisaged, the modified recovery 
and resilience plan, including its REPowerEU chapter, is expected, to a large extent, to make a 
significant contribution to the green transition or to address the challenges resulting from it and 
ensures that at least 37% of its total allocation 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  Greece’s  recovery  and  resilience  plan  leads  to  an  increase  of  its 
contribution to the digital transition in absolute terms compared to the original plan adopted 
in July 2021. The modified plan (excluding the measures in the REPowerEU chapter) dedicates 
EUR 7 776 million  to measures contributing to the digital transition, an overall increase of EUR 
682 million compared to the original plan. While measures contributing to the digital transition 
worth EUR 344 million in total are removed from the plan or scaled down, two measures are scaled 
up for an amount worth EUR 94 million and around EUR 1 billion of the additional loans requested 
by Greece is expected to be used for digital investments in very high capacity broadband networks, 
digitalization  of  SMEs  and  large  enterprises,  development  and  deployment  of  cybersecurity 
technologies, advanced digital technologies and other types of ICT infrastructure. Moreover, the 
Loan Facility maintains the commitment for financial institutions to invest at least 20.8% of the 
funds to support the digital transition. 

The  measures  in  the  modified  plan  continue  contributing  to  the  digital  transition  or  helping  to 
address  the  related  challenges  and  address  well  Greece’s  shortcomings  in  the  digital  field  as 
identified  in  the  first  State  of  the  Digital  Decade  report.8  The  modified  plan  continues  to 
significantly address the digital transition challenges faced by Greece in the areas of connectivity, 
digital public services, human capital and digital skills, digitalisation of businesses and adoption 
of advanced digital technology.  

In  total,  Greece’s  modified  Recovery  and  Resilience  plan  (excluding  the  measures  in  the 
REPowerEU  chapter)  contributes  for  22.1%  to  the  digital  transition,  which  is  above  the 
target of 20% required by the RRF Regulation. 

*** 

8  2023  Report  on  the  state  of  the  Digital  Decade:  https://digital-strategy.ec.europa.eu/en/library/2023-report-state-
digital-decade  

20 

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

3.7.  Lasting impact of the plan  

The  modified  recovery  and  resilience  plan  ensures  that  the  implementation  of  the  envisaged 
reforms and investments delivers lasting structural changes. The inclusion of a new REPowerEU 
chapter, the increase in the Loan Facility allocation and some additional reforms are all expected 
to have lasting positive effects on the Greek economy, increasing the ambition of the initial plan 
as a whole. The plan continues to address the main structural socio-economic and environmental 
challenges faced by Greece, pursuing cohesion objectives.  

Greece’s REPowerEU chapter is expected to have a long-term positive impact by accelerating the 
green  transition  and  ensuring  energy  security,  through  the  measures  promoting  RES  for  auto-
consumption,  whilst  the  reforms  increasing  grid  and  storage  capacity  and  establishing  the 
framework  for  the  operation  of  the  smart  grid  are  expected  to  further  enhance  demand  side 
response,  RES  penetration  and  consumer  participation  in  the  electricity  market.  The  planned 
investments  in  energy  storage,  promotion  of  biomethane  and  renewable  hydrogen  and  Carbon 
Capture and Storage will contribute to increasing Greece’s independence from fossil fuels and its 
progress  towards  decarbonisation.  In  addition,  the  measures  addressing  energy  efficiency  and 
support for the renovation of housing, including a set share destined for energy poor households, 
are expected to have a wider social impact.  

Newly added reforms aim at addressing the shortage of personal doctors to enhance the full rollout 
of  the  primary  healthcare  reform,  improving  tax  revenues  and  incentives  through  promoting 
electronic payments and improving the structure of taxes on the self-employed, and completing 
the reform of the cadastre with the finalisation of the cadastral mapping and the full transition to 
the  new  organisational  structure  of  the  Hellenic  Cadastre.  New  investments  will,  among  other 
things, support restoration and reforestation, seismic prevention, and increasing the resilience of 
infrastructure  in  the  wake  of  natural  disasters.  Furthermore,  the  substantial  increase  in  the 
allocation of the Loan Facility, in the context of the current monetary policy tightening, is expected 
to reduce the cost of capital, thereby supporting access to finance increasing their investment – 
including in the key green and digital sectors of the economy – competitiveness and exports. This 
will in turn have a positive and lasting impact on demand and long-term output.    

Overall, the new measures included in the modified plan are complementary to the existing ones 
and  are  expected  to  have  a  lasting  structural  impact,  including  by  addressing  longstanding 
weaknesses, improving the functioning of Greece’s institutions and increasing resilience. 

*** 

21 

 
 
 
 
 
 
Taking into consideration all reforms and investments envisaged by Greece, its modified recovery 
and  resilience  plan  continues  to  represent,  to  a  large  extent,  a  comprehensive  and  adequately 
balanced response to the economic and social situation, thereby contributing appropriately to all 
six pillars referred to in Article 3 of the RRF Regulation, taking the specific challenges and the 
financial allocation of Greece into account. This would warrant a rating of A under criterion 2.1 
in Annex V to the RRF Regulation. 

3.8.  Milestones, targets, monitoring and implementation  

The RRF Agency (part of the Ministry of National Economy and Finance) remains the entity 
tasked by Greece with the implementation, monitoring and reporting of the RRP. The RRF 
Agency is responsible for the management and control system that has an institutional set-up that 
is  centered  around  three  levels:  (i)  competent  line  Ministry  given  the  responsibility  for  the 
implementation of a specific measure; (ii) assigned implementing bodies that have been appointed 
by the competent Ministries and are responsible for the achievement of the agreed milestones and 
targets as well as the reporting of all data and documentation to the RRF Agency; and (iii) the 
control  of  the  achievement  of  milestones/targets  is  assigned  to  external  independent  certified 
auditors, who are selected and appointed among auditors registered in the official Register of the 
Hellenic Accounting and Auditing Standards Oversight Board. With regards to the REPowerEU 
chapter, the Ministry of Environment and Energy has been assigned as the competent Ministry to 
oversee the implementation of the new measures. 

The  milestones  and  targets  of  the  modified  Greek  recovery  and  resilience  plan  enable  an 
adequate monitoring of the plan’s implementation. The implementation of new reforms, new 
and scaled-up investments, as well as the measures included in the REPowerEU chapter, will be 
captured  by  the  achievement  of  additional  milestones  and  targets  monitored  by  each  entity  in 
charge of implementing the measures. The milestones and targets chosen are consistent with the 
objectives,  cost  estimates  and  implementation  schedule  of  each  measure  and  are  reflected  in 
specific qualitative or quantitative indicators. The REPowerEU chapter includes a set of 23 new 
milestones and targets. 

The adjustments made to the plan’s 331 original milestones and targets are well aligned with 
the modifications of the measures, thereby ensuring that they remain relevant, acceptable 
and robust. In some cases, the amendments correct clerical errors and help to align the intent of 
the original plan and the description of investment and reforms with the content of milestones and 
targets to better assess the achievement of measures. The total number of milestones and targets 
for the revised plan is 381, out of which 311 are milestones and 70 are targets. 

*** 

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

22 

 
 
 
 
 
 
3.9.  Costing 

Greece  has  provided  cost  estimates  for  all  new measures  that  entail  a  cost  in  the  recovery  and 
resilience  plan,  including  the  REPowerEU  chapter.  In  addition,  Greece  has  also  provided 
individual  justifications  for  all  measures  whose  modifications  entailed  a  change  in  the  cost 
estimates or related target, including on the proportionality of the relevant amendments. 

The assessment of the cost estimates and supporting documents shows that the costs of the new 
measures  are  mostly  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.  Moreover,  the  change  in  the  cost  estimates  of  the  modified 
measures are justified and proportional. 

The cost analysis reports have been prepared in collaboration with an external consultant, which 
has  a  contractual  relationship  with  the  Greek  government  and  thus  cannot  be  seen  as  an 
independent  body.  The  cost  estimates  have  been  assessed  by  Greece’s  National  Productivity 
Board,  which  finds  them  to  be  reasonable,  plausible  and  commensurate  and  in  conclusion  has 
validated the cost estimates. 

Reasonable costs 

Overall,  the  detailed  breakdown  of  the  calculation  of  projected  costs  and  supporting  material 
provided by Greece to estimate the costs of new measures including in the REPowerEU chapter 
[allows  for  a  reasonable  identification  of  the  main  cost  drivers].  In  most  cases,  the  provided 
documents provide an overview of the methodological approach used in costing calculations, even 
if for a small number of measures detailed information is missing. Overall, the estimated costs 
across the new or modified measures are appropriate and have been sufficiently justified for the 
majority of the measures. 

The reasonability of the costs of the modified measures that only involve a change in the timing 
of respective milestones and targets, i.e. without any impact on costing, has not changed from the 
initial assessment of these measures. In the case of measures whose costs are being amended under 
Article 21(1) of Regulation (EU) 2021/241, sufficient information has been provided to justify the 
objective  circumstances  and  the  proportionality  of  the  changes  in  the  cost  estimates  or  related 
target.  

New  measures  in  the  Greek  recovery  and  resilience  plan,  including  those  in  the  REPowerEU 
chapter, comply with the eligibility criteria set out in the RRF Regulation. All costs are incurred 
for measures after February 2020 and after February 2022 for the measures in the REPowerEU 
chapter. Value-added tax (VAT) is not included in any of the cost estimates. In this context, the 
reasonability of the cost estimates, taking into account the new measures, including those in the 
REPowerEU chapter, and the amended measures, has been established to a medium extent. 

Plausible costs  

23 

 
 
 
 
 
 
Concerning  the  request  for  modifications  under  Article  21,  sufficient  information  has  been 
provided to justify the objective circumstances and the proportionality of the changes in the cost 
estimates or related targets. In most cases, the calculation of cost increases is based on actual data 
or relevant studies and is assessed to be overall plausible.  

For  the  new  and  scaled  up  investments,  including  those  in  the  REPowerEU  chapter  and  the 
measures mitigating the impact of recent natural disasters, the cost estimates have been deemed, 
to a medium extent, as plausible.  

No double Union financing 

Greece has indicated that the costs for new and modified measures including REPowerEU will not 
be funded at the same time by other Union funding sources. The Greek government has provided 
information  for  each  new  or  modified  measure  regarding  the  funding  sources,  with  the  large 
majority relying on 100% financing from the Recovery and Resilience Facility. Given that details 
concerning the amounts and costing items not financed by the Recovery and Resilience Facility 
have been provided as part of a cost breakdown per measure, the modified plan ensures that the 
support of the Recovery and Resilience Facility is expected to be additional to the support provided 
under other Union funds and programmes and does not cover the same cost.  

Commensurate and cost-efficient costs 

The total cost of the modified Greek recovery and resilience plan is commensurate to the expected 
social and economic impact of the envisaged measures. The plan is expected to effectively address 
a significant subset of challenges identified in the country-specific recommendations (CSRs) in 
accordance with the initial plan. The main objectives of the plan are to foster the twin transition, 
address  bottlenecks  to  a  lasting  and  sustainable  growth,  job  creation  and  economic,  social  and 
institutional  resilience,  thereby  reducing  vulnerability  to  shocks.  In  addition,  the  REPowerEU 
chapter is set to address energy-relevant CSRs while most newly added measures are expected to 
mitigate  the  impact  of  recent  natural  disasters.  The  modified  plan  contributes  to  strengthening 
social cohesion and social protection and to the implementation of the European Pillar of Social 
Rights in line with the initial plan. The economic and social impact of the plan in combination 
with  the  positive  cost  assessment,  indicates  that  the  cost  is  in  line  with  the  principle  of  cost-
efficiency. 

*** 

The justification provided by Greece on the amount of the estimated total costs of the modified 
recovery and resilience plan is to a medium extent reasonable, plausible, in line with the principle 
of cost-efficiency and is commensurate to the expected national economic and social impact.  

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

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

24 

 
 
 
 
 
 
3.10.  Controls and audit  

The  original  assessment  of  the  robustness  and  adequacy  of  the  control  system  and  other 
arrangements  included  in  the  Greek  RRP  had  concluded  that  these  arrangements  are  adequate 
subject to the timely fulfilment of the milestone pertaining to the Financial Audit Committee’s 
(EDEL) legal mandate and setting up the management, control and audit systems. This warranted 
a rating of A under the assessment criterion 2.10 of Annex V to the RRF Regulation. 

The Greek 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.  In  addition,  certain  additional  assurances  have 
been provided as per agreed milestones included in the annex to the original Council Implementing 
Decision  –  namely  the  entry  into  force  of  the  EDEL’s  legal  mandate  and  setting  up  the 
management,  control  and  audit  systems  to  ensure  the  collection  of  data  and  monitoring  of  the 
achievement of milestones and targets, to allow for the preparation of management declarations 
and the audit summary as well as payment claims  and to  establish the necessary procedures to 
collect  and  store  data  on  beneficiaries,  contractors,  subcontractors,  and  beneficial  owners  in 
accordance with Article 22 of Regulation (EU) 2021/241. The adequacy of these measures has 
been assessed by the Commission during the first payment request, including the commitments to 
be fulfilled by the second payment request. 

The changes made to the original plan and the inclusion of the REPowerEU chapter, as such, do 
not alter the initial assessment. However, in the context of the modification of the Greek RRP, its 
audit and control system needs to be re-evaluated based on criteria 2.10 of Annex V of the RRF 
Regulation. Since the original evaluation, the Commission has had access to information regarding 
its actual enactment. This encompasses the results of the audit on the protection of the financial 
interests  of  the  Union  carried  out  by  the  Commission  in  Greece.  Considering  this  data,  the 
Commission deems that the internal control system of the Greek RRP is overall adequate.  

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 and were further enhanced by the entry into force of EDEL’s legal mandate.  

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 
implementation  of  an  IT  system  for  monitoring  and  control  of  the  measures,  as  well  as  for 
collection of data in line with the requirements of Article 22(2), point (d), indents (i) to (iii) of the 
RRF Regulation is confirmed. 

25 

 
 
 
 
 
 
Adequacy of arrangements to avoid double EU funding  

The arrangements described in the initial plan as regards the prevention, detection and correction 
of double funding remain in place, as positively assessed by the Commission. 

Legal empowerment and administrative capacity of control function 

The Recovery and Resilience Facility Agency (RRFA) is an independent special public service 
under the Minister of Finance, set up according to the Law 4738/2020, and constitutes the lead 
national  body  tasked  with  the  overall  coordination  and  monitoring  of  the  RRP.  Additionally, 
pursuant to Article 189 of Law 4820/2021 (Government Gazette, Series I, No 130), EDEL referred 
to in Article 11 of Law 4314/2014 (GG I 265), which forms part of the Secretariat-General for 
Fiscal Policy (GGDP) of the Ministry of Finance, has been designated as responsible for auditing 
the  RRF,  which  includes  all  involved  actors,  as  well  as  management  and  control  system 
responsibilities and procedures.The organizational structure and responsibilities of the RRFA were 
amended to fully reflect the processes of the Management Control System (MCS), which gives us 
reasonable assurance of the administrative capacity of the RRFA.  

Concerning the dedicated unit in EDEL, to perform the required audit tasks for RRF, the necessary 
legislative  arrangement  in  the  organizational  structure  were  made  for  the  establishment  of  a 
dedicated unit within the General Directorate for the Audits of Co-financed Programs, under the 
Financial Audit Committee. The mandate of EDEL to audit the RRF was provided in a dedicated 
national act for the RRF. For this new unit, additional dedicated staff positions were foreseen.  

*** 

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

3.11.  Coherence  

In accordance with Article 19(3), point (k), of and Annex V, criterion 2.11, to Regulation (EU) 
2021/241,  the  RRP  includes  to  a  high  extent  (Rating  A)  measures  for  the  implementation  of 
reforms and public investment projects that represent coherent actions. 

The proposed modifications do not  affect  the overall coherence of the plan, in  particular those 
related to green transition and the newly added REPowerEU chapter. The new plan will support 
the common objectives of supporting the growth potential of the Greek economy, contributing to 
the twin transition and increasing Greece’s resilience to meet the challenges of the twenty-first 
century on the path of sustainable and inclusive growth.  

26 

 
 
 
 
 
 
The new reforms included in the plan enable the planned and new investments. The proposed “Tax 
Reform”  under  the  Component  4.6,  aims  to  introduce  a  legal  framework  to  boost  electronic 
payments among others. Together with the new reform focused on the completion of the national 
cadastre, these reforms will allow for increased simplifications and predictability in the business 
environment.  Complementarily,  Greece  proposed  to  expand  the  scope  of  investments  in  the 
industrial  units  support  from  e-mobility  to  cover  projects  related  to  the  green  transition  under 
recharge  and  refuel  component.  Additional  investments  such  as  the  one  linked  to  the  National 
Forest  Prevention,  Protection  and  Restoration  Plan  are  linked  to  already  existing  measures  to 
ensuring the adaptation to climate change and sustainable use of resources. New measures also 
address the health sector and the social resilience of the country with complementary reform of 
personal doctor which aims to increase access to primary healthcare services especially for people 
leaving in remote areas. 

The additional REPowerEU chapter is fully aligned with the objective of the measures deployed 
under the initial RRP to support the green transition and further reinforces the ambition of some 
of  them.  The  promotion  of  energy  efficiency  interventions  and  RES  technologies  for  auto-
consumption are linked with various investments and reforms for promoting RES and improving 
the energy efficiency in residential buildings and enterprises. Overall, the REPowerEU chapter is 
built around a consistent package of both reforms and investments that are mutually reinforcing to 
contribute for a decrease of energy demand, an increase in energy efficiency and support the clean 
energy transition. 

*** 

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

3.12.  REPowerEU  

Greece’s REPowerEU chapter contributes to the objectives set in the provisions of Article 
21c of the RRF Regulation, through a set of reforms and investments.  

Specifically, the measures included in the chapter  aim at increasing Greece’s energy efficiency 
targets, at decarbonising the industry, increasing the production of biomethane and of renewable 
hydrogen, as well as accelerating the deployment of renewable energy (Article 21c(3)(b) of the 
RRF  Regulation),  at  addressing  energy  poverty  (Article  21c(3)(c)  of  the  RRF  Regulation), 
incentivising  the  reduction  of  energy  demand  (Article  21c(3)(d)  of  the  RRF  Regulation),  and 
addressing internal and cross border energy transmission and distribution bottlenecks, supporting 
electricity storage and accelerating the integration of renewable energy sources (Article 21c(3)(e) 
of the RRF Regulation).  

Regarding the objective of energy efficiency, the proposed measures include: (i) a set of energy 
efficiency  investments  aiming  both  at  scaling-up  the  current  renovation  programmes  under  the 
Greek RRP and at promoting energy efficiency actions in municipal water and sewerage utilities, 

27 

 
 
 
 
 
 
the  installation  of  solar  water  heaters  in  residential  buildings  and  the  installation  of  solar 
photovoltaics for self-consumption and use in the agricultural sector; and (ii) a reform to set out a 
roadmap  for  innovative  energy  efficiency  interventions  and  identification  of  new  financial 
instruments for this purpose. Regarding the promotion of the industry decarbonisation and the 
production of biomethane and renewable hydrogen, Greece proposes: (i) the establishment of 
a  regulatory  and  market  operation  framework  for  carbon  capture,  usage  and  storage  (CCS) 
technologies; (ii) the development of a licensing and support scheme framework for biomethane 
and  renewable  hydrogen;  (iii)  an  investment  in  pilot  projects  for  biomethane  and  renewable 
hydrogen  production  and  (iv)  the  promotion  of  CCS  technologies.  Finally,  regarding  the 
deployment of renewable energy sources, the chapter includes: (i)  the scale-up of an investment 
to  increase  electricity  storage  capacity  in  Greece,  which  will  enable  the  increase  of  renewable 
energy  potential  across  the  country;  (ii)  a  reform  to  optimise  land  and  sea  space  usage  for  the 
development  of  renewables  and  complete  the  legislative  framework  for  offshore  wind  energy 
already started within the Greek RRP; (iii) a reform to foster grid and storage capacity in Greece; 
(iv) a reform for the promotion of smart grid technologies and practices in the electricity market 
of Greece, and (v) a reform aiming at the development of a more complete legislative framework 
and the set-up of various policy tools to promote energy sharing, collective self-consumption and 
renewable energy communities.  

Energy poverty is addressed through two new reforms and a new investment aiming to support 
energy  efficiency  and  the  production  of  renewable  energy  for  auto-consumption,  which  will 
provide additional incentives for energy-poor households. Greece introduced a set of policy tools 
to promote collective self-consumption, energy sharing and renewable energy communities, which 
will  promote  a  larger  use  of  decentralised  renewables  production,  consumption,  and  energy 
sharing. In addition, the reform on energy efficiency interventions aims, among other things, at 
establishing a targeted approach (including the design of policy programmes) for larger energy 
savings  for  energy  poor  households  and  vulnerable  social  groups.  Finally,  part  of  the  energy 
efficient interventions will be targeted to renovations for lower income households, as it was the 
case for the first energy renovation programme in the plan.  

The reduction of the energy demand will be met through energy efficiency investments aiming 
at the improvement of the energy performance of residential buildings leading to a meaningful 
reduction  of  the  energy  demand  for  heating,  cooling  and  domestic  hot  water.  The  investment 
concerning municipal water and sewerage utilities will also contribute to the objective in question. 
Finally, the reform aiming at setting out a roadmap for energy efficiency interventions will help in 
the design of future energy efficiency national programmes that will not rely exclusively on non-
reimbursable support (i.e. grants), thus contributing to further potential energy savings. 

Greece  also  invests  in  improving  electricity  storage.  The  REPowerEU  chapter  includes  the 
scale-up of an investment to increase energy storage capacity in Greece. A reform is also included 
to promote and make it easier to bring forward investments in the electricity grid and to increase 
storage capacity. 

All the above measures are expected to contribute to the REPowerEU objectives in coherence and 
complementarity with a number of other reforms and investments promoted under the RRP, mainly 

28 

 
 
 
 
 
under Components 1.1 - 1.3, as well as under other national initiatives or EU funded programmes 
such  as  programmes  co-funded  by  the  Cohesion  Policy  and  the  Just  Transition  Funds  (e.g., 
Revitalisation of the Just Transition Territories).   

Regarding  the  consultation  process  for  the  preparation  of  the  REPowerEU  Chapter,  Greece 
presented the outcome of the consultation process and an outline of how the feedback obtained 
from stakeholders has been used when finalising the REPowerEU chapter, as required by the RRF 
Regulation .   

*** 

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

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

Most measures in the REPowerEU chapter have a cross-country or multi-country dimension 
or  effect.  As  described  in  detail  above,  the  measures  in  the  REPowerEU  chapter  will  directly 
contribute to the integration of renewable energy sources and the reduction of energy demand. As 
a result, they contribute to reducing the dependency on fossil fuels, building flexibility in energy 
management and securing energy supply in the Union as a whole and can therefore be considered 
as having a positive cross-border effect in line with the Commission’s guidance in the context of 
REPowerEU.9 

*** 

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

REPowerEU measure 

Costs (EUR 
million) 

Contribution to the 
target in % 

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

29 

 
 
 
 
 
 
 
 
 
I.1  Energy  Efficiency  and  promotion  of  RES  for  auto-
consumption (New ID 16994) 

I.2  Increase  of  energy  storage  for  additional  RES 
penetration (New ID 16996) 

I.3  Pilot  projects  for  Biomethane  and  Renewable 
Hydrogen (New ID 16995) 

I.4  Promotion  of  CCS  technologies  to  foster  industry 
decarbonization (New ID 16997) 

560 

85 

75 

75 

70.44 

10.69 

9.43 

9.43 

Total cost of the REPowerEU chapter 

795 

100% 

30 

 
 
 
 
 
 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging  

o 

Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16926 

16871 

16870 

16901 

16900 

16899 

16865 

16872 

16872 

16873 

Support of the installation 
of storage systems to 
enhance RES penetration 

Revitalization actions of 
the most affected 
territories_Nature and 
biodiversity protection 

Interventions for the 
electricity interconnection 
of islands and the 
upgrading of the electricity 
network 

HEDNO network upgrades 
aiming at enhancing 
resilience and protecting 
the environment 

HEDNO overhead network 
upgrading in forest areas 

Installed capacity increase 
in Hellenic Electricity 
Distribution Network 
Operator (HEDNO) 
HV/MV substations for 
new RES connection 

Restructuring and 
enhancement of the RES 
CHP Account revenues 

Energy renovation on 
residential buildings 

Energy renovation on 
residential buildings 

450 

033  

100% 

49 

050 

40% 

195 

033 

100% 

60 

037 

100% 

40 

037 

100% 

12 

028 

100% 

202 

028 

100% 

1 153 

025bis 

100% 

100 

29 

100% 

Green Interventions - 
Interventions in residential 

160 

037 

100% 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

areas and in the building 
stock_Adaptation and 
climate resilience measures 

Eleonas/ Votanikos - 
Interventions in residential 
areas and in the building 
stock_Energy efficiency 
measures 

Athens Reviera - 
Interventions in residential 
areas and in the building 
stock_Cycling 
infrastructure 

Other Strategic 
Interventions - 
Interventions in residential 
areas and in the building 
stock_Nature and 
biodiversity protection 

Other Strategic 
Interventions - 
Interventions in residential 
areas and in the building 
stock_Energy efficiency 
measures 

Other Strategic 
Interventions - 
Interventions in residential 
areas and in the building 
stock_Construction of new 
energy efficient buildings 

Energy and 
entrepreneurship 

Energy upgrade of public 
sector buildings 

16873 

16873 

16873 

16873 

16873 

16874 

16876 

116 

026 

40% 

44 

075 

100% 

31 

050 

40% 

78 

024ter 

100% 

47 

025ter 

40% 

450 

024ter 

100% 

120 

026bis 

100% 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16876 

16875 

16932 

16879 

16831 

16924 

16924 

16924 

16849 

16846 

Energy upgrade of public 
sector buildings – street 
lightting 

Infrastructure development 
and buildings’ restoration 
in former royal estate in 
Tatoi 

Olympic Athletic Center of 
Athens 

Preparation of Urban Plans 
in implementation of the 
urban policy reform 

Produc- E Green 

Charging Points – 
Electromobility_Alternativ
e fuels infrastructure 

Electric busses – 
Electromobility_Clean 
urban transport: rolling 
stock 

Electric taxis - 
Electromobility_Battery 
driven vehicles 

National Reforestation Plan 
and Parnitha flagship 
investment 

Renovated infrastructure - 
Urban Wastewater and 

30 

026 

40% 

40 

026 

40% 

11 

026 

40% 

250 

036 

100% 

300 

80 

027 

077 

100% 

100% 

100 

074 

100% 

40 

N/A 10 

100% 

556 

036 

100% 

45 

041bis 

40% 

10 The ‘Methodology for climate tracking’ annexed to the Recovery and Resilience Facility Regulation (2021/241) 
does not set out intervention fields that would allow for climate or environmental tracking of electric vehicles or plug-
in hybrid vehicles, except for vehicles for urban transport falling under intervention field 074. According to Article 
18(4)(e) of the Regulation, the methodology should however ‘be used accordingly for measures that cannot be directly 
assigned to an intervention field listed in Annex VI’. In this context, the Commission has applied a 100% climate 
contribution  coefficient  for  zero-emission  vehicles  of  all  categories  (this  includes  battery  electric  and  fuel 
cell/hydrogen-powered vehicles). 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

Sludge Management 
Infrastructures from 
Wastewater 
Treatment_Compliant with 
energy efficiency criteria 

Investments in the national 
irrigation network through 
PPP schemes 

Drinking Water Supply and 
Saving Infrastructures 

Aerial means for crisis 
management 

Forest firefighting, 
prevention and response 
equipment 

Biodiversity protection as a 
driver for sustainable 
growth 

Infrastructure - 
Establishment of a strategic 
National Disaster Risk 
Management 

Monitoring and 
Management System 

Implementation of 
Regional Civil Protection 
Centers (PEKEPP) through 
PPP schemes 

Small-satellites 

Fiber optic infrastructure in 
buildings 

Digitisation of archives and 
related services 

16285 

16850 

16911 

16912 

16851 

16909 

16910 

16283 

16855 

16818 

16778 

184 

040 

40% 

200 

039bis 

40% 

155 

036 

100% 

115 

036 

100% 

100 

050 

40% 

74 

036 

100% 

45 

036 

100% 

19 

025ter 

40% 

200 

131 

598 

34 

055 

053 

100% 

100% 

011 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16810 

16780 

16736 

16742 

16826 

16791 

16823 

16779 

16965 

16964 

16824 

16785 

16854 

CRM for the General 
Government 

Further Modernisation of 
Public Administration’s 
One-Stop Shops 

New system for Public 
Procurements 

Digital transformation of 
the Ministry of Foreign 
Affairs 

Digital skills upgrade 
programs for conscripts 

Digital Transformation of 
the Greek National 
Tourism Organisation 

Cybersecurity strategy and 
policies for the Public 
Sector & advanced security 
services for national critical 
infrastructures 

Interoperability and web 
services development 

Data Classification Studies 
for Public Sector’s 
Information Systems 

Next-Generation 
Interoperability Centre 
(KED) 

ERegistries 

Tourism Registry e-MHTE 

Smart cities 

56 

19 

17 

49 

32 

8 

49 

72 

2 

3 

24 

8 

73 

35 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

108 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

011 

055 

100% 

100% 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16853 

16955 

16956 

16827 

16842 

16738 

16706 

16750 

16747 

16942 

16913 

16913 

Supply of Central Cloud 
Computing Infrastructure 
and Service 

Upgrade of Cloud-
computing infrastructure 
and services of the National 
Infrastructures for Research 
and Technology (GRNET) 

Expansion of Syzefksis II 

Data Governance strategy 
& policies for the Public 
Sector 

Central BI - Data Analytics 

Central Document 
Management System 

Digital Transformation of 
SMEs 

Digital Transformation of 
Labour Systems 

Green skills, jobs, economy 
- Active Labour Market 
Policies 
Reform_Contributing to 
green skills and jobs and 
the green economy 

OAED Digitalization 

A New Strategy for 
Lifelong Skilling: 
Modernising and 
Upgrading Greece’s 
Upskilling and Reskilling 
System_Digital upskilling 

Green skills, jobs, economy 
- A New Strategy for 
Lifelong Skilling: 

95 

011bis 

40% 

011bis 

100% 

63 

011bis 

40% 

011bis 

100% 

26 

26 

16 

5 

362 

77 

011 

011 

011 

011 

100% 

100% 

100% 

100% 

010 

100% 

011 

100% 

100 

01 

100% 

17 

690 

011 

108 

100% 

100% 

350 

01 

100% 

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16794 

16792 

16676 

16755 

16795 

16752 

Modernising and 
Upgrading Greece’s 
Upskilling and Reskilling 
System_Contributing to 
green skills and jobs and 
the green economy 

Green Schools - 
Strengthening the 
Apprenticeship 
System_Energy efficiency 
renovation or energy 
efficiency measures 
regarding public 
infrastructure 

Labor force skilling, 
reskilling and upskilling 
through a reformed training 
model (Vocational 
Education & Training 
Reform)_Contributing to 
green skills and jobs and 
the green economy 

108 

026bis 

100% 

55 

01 

100% 

Digital transformation of 
Education 

365 

011 

100% 

Green investments - 
Reform of the Primary 
Health Care 
System_Energy efficiency 
renovation or energy 
efficiency measures 
regarding public 
infrastructure 

NHS Hospital Renovation 
and Infrastructure Upgrade 

189 

026 

40% 

317 

026 

40% 

Digital Transformation of 
Health (DigHealth) 

278 

095 

100% 

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16793 

16925 

16763 

16763a 

16611 

16616 

16291 

16705 

16940 

16292 

Project for the construction 
of a building dedicated to 
Cellular & Gene Therapies 
and Hematology Clinic 
Laboratories within the 
General Hospital of 
Thessaloniki 
“Papanikolaou” 

Digital Transformation of 
the social support system 

Digital transformation of 
the immigration and 
asylum system 

Digital transformation of 
the immigration and 
asylum system: fire 
detection system at the 
refugee camp in Lesvos 

Digital transformation of 
tax audits 

Adoption of measures and 
incentives to increase 
electronic transactions 

Digital Transformation of 
the Tax and Customs 
Administration 

Digital Transformation of 
Fiscal Management and 
Supervision in Governance 
& Electronic Invoicing 

Modernise the Hellenic 
Consignment Deposit and 
Loans Fund 

New Judicial 
Buildings_Construction of 

6 

025ter 

40% 

12 

42 

011 

100% 

011 

100% 

1.5 

036 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

3 

0.5 

180 

102 

7 

69 

025ter 

40% 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16292 

16727 

16733 

16581 

16654 

16975 

16960 

16960 

16960 

16959 

new energy efficient 
buildings 

New Judicial 
Buildings_Energy 
efficiency renovations 

Digital Transformation of 
Justice (E-Justice) 

Skills and digital skills for 
judges and judicial 
employees (judicial staff) 

Enhanced capital market 
supervision and 
trustworthiness 

TH 2 ORAX: Trellis 
Holistic & Hybrid 
Operational Ruggedized 
Autonomous eXemplary 
system 

Upgrade Interventions for 
Regional Ports 

Smart Infrastructure with 
environmental and cultural 
focus_Digital sub-projects 

Smart Infrastructure with 
environmental and cultural 
focus_ Nature and 
biodiversity protection 

Smart Infrastructure with 
environmental and cultural 
focus_Air quality measures 

Digital Transformation of 
the Hellenic Railways 
Organization 

27 

026 

40% 

73 

32 

12 

011quater 

100% 

108 

100% 

011 

100% 

50 

037 

100% 

011 

100% 

20 

081bis 

40% 

82 

011 

100% 

65 

050 

40% 

27 

048 

40% 

24 

070 

40% 

070 

100% 

16949 

Smart Bridges 

173 

39 

063 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

16937 

16931 

16931 

16931 

16931 

16892 

16786 

16721 

16653 

16634 

Digital Integrated Program 
Management System for 
the Administration of the 
Technical Works and 
Structural Assets of the 
Ministry of Infrastructure 
and Transport 

Tourism 
Development_Energy 
efficient measures 

Tourism 
Development_Energy 
efficient measures for 
public infrastructure 

Tourism 
Development_Renewable 
energy (wind) 

Tourism 
Development_Energy 
efficient measures for 
public infrastructure 

Upgrading suburban 
railway of West Attica 

Simplification of the 
Procedures of the Ministry 
of Infrastructure & 
Transport 

Acceleration of smart 
manufacturing 

Digital Transformation of 
the Agri-Food Sector 

New Industrial 
Parks_Construction of new 
energy efficient buildings 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

011 

100% 

Budget 
(EUR 
m) 

10 

111 

024 

40% 

7 

026 

40% 

7 

1 

028 

100% 

026 

40% 

81 

073 

100% 

1 

75 

47 

7 

025ter 

40% 

40 

011 

100% 

010bis 

100% 

011 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16634 

16634 

16634 

16634 

16634 

16626 

16626 

16626 

16626 

New Industrial Parks_ 
Water management and 
water resource conservation 

New Industrial Parks_ 
Waste water collection and 
treatment compliant with 
energy efficiency criteria 

New Industrial Parks_ 
Renewable energy (solar) 

New Industrial Parks_ 
Alternative fuels 
infrastructure 

New Industrial Parks_ 
Water management and 
water resource conservation 

Climate related - Economic 
transformation on the 
Agricultural Sector_Energy 
efficiency and 
demonstration projects in 
SMEs 

Climate related - Economic 
transformation on the 
Agricultural 
Sector_Renewable energy 
(solar) 

Climate related - Economic 
transformation on the 
Agricultural 
Sector_Alternative fuels 
infrastructure 

Climate related - Economic 
transformation on the 
Agricultural 
Sector_Support to 
environmentally-friendly 
production processes and 

4 

040 

40% 

25 

041bis 

40% 

5 

3 

5 

029 

100% 

077 

100% 

040 

40% 

62 

024 

40% 

35 

029 

100% 

7 

077 

100% 

170 

047 

40% 

41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16599 

16593 

16593 

16584 

16536 

16486 

16433 

resource efficiency in 
SMEs 

Digitilization of Economic 
Diplomacy Network & 
Exporters Training 
Program 

Amendment of the legal 
framework for the 
attraction of strategic 
investment_Support to 
enterprises that provide 
services contributing to the 
low carbon economy 

Amendment of the legal 
framework for the 
attraction of strategic 
investment_Construction of 
new energy efficient 
buildings 

Proposals for actions in the 
Aquaculture Sector 

Upgrade of infrastructure, 
renewal of equipment and 
upgrade of quality of 
services provided by 
HOCRED Stores – former 
ARF Stores (On-spot and 
electronic) 

Museum of underwater 
antiquities 

Protection of cultural 
monuments and 
archaeological sites from 
climate change 

8 

011 

100% 

45 

027 

100% 

40 

025ter 

40% 

35 

047 

40% 

3 

024bis 

40% 

54 

026 

40% 

20 

037 

100% 

16293 

Culture as a driver of 
growth 

30 

026 

40% 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

RRP Loan Facility_Energy 
efficiency and 
demonstration projects in 
SMEs or large enterprises 

RRP Loan 
Facility_Renewable energy 
(solar) 

RRP Loan 
Facility_Renewable energy 
(wind) 

RRP Loan 
Facility_Commercial, 
industrial waste 
management 

RRP Loan Facility_Smart 
Energy Systems 

RRP Loan Facility_Support 
to enterprises that provide 
services contributing to the 
low carbon economy 

RRP Loan Facility_Other 
renewable energy 

RRP Loan 
Facility_Research and 
innovation processes 
focusing on the low carbon 
economy, resilience and 
adaptation to climate 
change 

RRP Loan 
Facility_Renewable energy 
(biomass) 

1 895 

024ter 

100% 

1 669 

029 

100% 

1 143 

028 

100% 

860 

044 

40% 

603 

033 

100% 

344 

027 

100% 

279 

032 

100% 

138 

022 

100% 

64 

030 

40% 

RRP Loan Facility_Very 
High Capacity Networks 

1 272 

054 

100% 

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

16980 

16980 

16980 

16980 

16980 

16996 

16994 

16994 

16994 

16994 

RRP Loan 
Facility_Digitalisation of 
large entreprises 

RRP Loan Facility_ 
Digitalisation of SMEs 

RRP Loan Facility_Other 
ICT infrastructure 

RRP Loan 
Facility_Cybersecurity 

RRP Loan 
Facility_Advanced 
technologies 

Increase of energy storage 
for additional RES 
penetration 

Energy Efficiency and 
promotion of RES for auto-
consumption - PV systems 
for auto-consumption in 
residential buildings and 
agricultural sector 

Energy Efficiency and 
promotion of RES for auto-
consumption - Energy 
renovation on residential 
buildings 

Energy Efficiency and 
promotion of RES for auto-
consumption - Energy 
Efficiency in Business 
Sector (non-residential 
buildings) 

Energy Efficiency and 
promotion of RES for auto-

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

010bis 

100% 

010 

100% 

055 

100% 

021quinquie
s 

100% 

021quater 

100% 

Budget 
(EUR 
m) 

1 022 

440 

414 

167 

164 

85 

033 

100% 

120 

029 

100% 

170 

025bis 

100% 

50 

024ter 

100% 

180 

029 

100% 

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub
-Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. 
field 

Coeff. 
% 

Int. field 

Coeff. 
% 

16994 

16999a 

consumption - Solar Water 
Heater (Households) 

Energy Efficiency and 
promotion of RES for auto-
consumption - Promoting 
energy efficiency and RES 
in municipal water and 
sewage companies 

Accessibility Restoration 
following the devastating 
effects of storm 
"DANIEL": rail 
reconstruction 

40 

026 

40% 

180 

069 

40% 

45