COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Finland Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 12524/21 INIT and ST 12524/21 ADD 1) of 29 October 2021 on the approval of the assessment of the recovery and resilience plan for Finland
Date: 2023-11-21
Institutions: European Commission, Secretariat-General
Subjects: EU aid, Finland, digital transformation, economic and social cohesion, economic recovery, economic reform, employment policy, green economy, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.11.2023  SWD(2023) 379 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Finland Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 12524/21 INIT and ST 12524/21 ADD 1) of 29 October 2021 on the approval of the assessment of the recovery and resilience plan for Finland   {COM(2023) 742 final}  
 
 
Table of contents 
1. 

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

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

3. 

Summary of the assessment of the plan .............................................................................................. 5 

3.1. 

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

3.2. 

Link with country-specific recommendations and the European Semester ................................. 5 

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 ........ 6 

3.4. 

The principle of ‘do no significant harm’ ...................................................................................... 6 

3.5.  Green transition ............................................................................................................................ 7 

3.6. 

Digital transition ............................................................................................................................ 7 

3.7. 

Lasting impact of the plan ............................................................................................................. 8 

3.8.  Milestones, targets, monitoring and implementation.................................................................. 8 

3.9. 

Costing .......................................................................................................................................... 9 

3.10.  Controls and audit ....................................................................................................................... 10 

3.11.  Coherence ................................................................................................................................... 12 

3.12.  REPowerEU ................................................................................................................................. 12 

3.13.  Cross-border or multi-country dimension or effect ................................................................... 14 

ANNEX I: Climate tracking and digital tagging ........................................................................................ 15 

1 

 
 
 
 
 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

On  5  October  2023,  Finland  submitted  to  the  Commission  a  modified  national  Recovery  and 
Resilience  Plan  (RRP),  including  a  REPowerEU  chapter  in  accordance  with  Article  21c  of 
Regulation (EU) 2021/241. 

Finland is facing a number of macroeconomic challenges. After growing in the first half of 2023, 
Finland’s GDP is expected to shrink during the rest of 2023. The inflationary pressure and high 
interest rates have stalled economic growth. In 2022, HICP inflation reached 7.2%, with energy 
and food prices being the main drivers, while a sharp fall is expected in 2023. The latest data on 
employment show a decrease in employment and the unemployment rate exceeding 7%, with the 
construction sector weighing on employment more than the other sectors.  

Finland’s investments in the green transition have so far been substantial, in particular in renewable 
energy and energy efficiency, but are expected to fall short of the required investment to achieve 
Finland’s  2035  carbon-neutrality  target.  Raising  long-term  productivity  growth  and  achieving 
carbon neutrality will require targeted policy action. The objective of the REPowerEU chapter of 
the  Finnish  recovery  and  resilience  plan  is  to  reduce  the  overall  dependence  on  fossil  fuels, 
decarbonise the energy sector, facilitate the deployment of renewables and to promote green skills. 

The Finnish REPowerEU chapter includes one reform and three investments. The implementation 
of the measures included in the REPowerEU chapter is expected to contribute to supporting the 
objectives in Article 21c(3) of Regulation (EU) 2021/241. The modification of the plan does not 
affect any of the existing measures in Finland’s recovery and resilience plan.  

The modified RRP represents a comprehensive and adequate response to the economic and social 
challenges faced by Finland. It retains a focus on the green and digital transitions and on promoting 
smart, sustainable and inclusive growth, with measures prioritising social and economic cohesion, 
job creation, competitiveness, and innovation. The original 13 components, with the addition of a 
REPowerEU  chapter,  continue  to  address  the  six  pillars  of  the  RRF  and  maintain  the  level  of 
ambition, taking into account the size of the plan. The plan continues to contain robust milestones, 
targets and verification mechanisms, and remains coherent with other policy commitments.  

For the modification of its RRP, Finland has relied on Article 21c to include additional resources 
from ETS revenues and on a transfer of funds from the Brexit Adjustment Reserve (BAR) for its 
REPowerEU chapter. 

Based on the assessment of the submitted modification and the  REPowerEU  chapter,  the 
Finnish  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 (52.3%)  A (28.9%) 

A 

A 

B 

A 

A 

A 

A 

2 

 
 
 
 
 
 
2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

2.1 Main challenges faced by Finland 

Finland's  economy  is  one  of  the  most  energy-intensive  in  the  EU.  Finland’s  geography  is 
characterised by long distances and cold weather, which create a challenge in terms of reducing 
energy consumption. A new Climate Act entered into force in 2022, enshrining Finland’s objective 
to  become  carbon-neutral  by  2035,  and  carbon-negative  soon  thereafter,  into  law.  Prior  to  the 
Russian  war  of  aggression  in  Ukraine,  Finland  had  a  strong  reliance  on  energy  imports  from 
Russia. Before February 2022, approximately 60% of Finland’s energy imports came from Russia, 
while by March 2023, the Treasury reported that almost all energy flows from Russia to Finland 
had stopped1. Natural gas has traditionally been only a small part of Finland’s energy mix, but the 
procurement of a floating liquefied natural gas terminal - which has been available since winter 
2022 - strengthened Finland’s security of energy supply. Moreover, Finland is on track to phase 
out the use of coal by 2029. Beyond this, further reduction in Finland’s reliance on fossil fuels is 
essential to improve security of supply. 

Achieving Finland's climate targets will require continued policy efforts and major public 
and private sector investment.  Lengthy  environmental  permitting  and  related procedures risk 
throttling renewable energy investments. While Finland’s share of renewables in the energy mix 
is already the second-highest in the EU, the planned increase in renewable energy to meet the 2035 
carbon-neutrality target is expected to require large investments in an effective management of 
network infrastructure. In terms of energy infrastructure, a challenge is presented by the fact that 
a major share of renewable energy is generated in different regions from where most consumption 
takes place. Creating high-value added clean tech products with renewable energy could form a 
strong basis for Finland’s competitiveness, but the permitting system needs to support innovative 
technologies. Strong interconnections between Finland and neighbouring countries are needed to 
ensure  a  well-functioning  electricity  market  in  the  whole  region  and  to  increase  the  projected 
contribution of renewable energy to the energy mix. Labour shortages in key sectors related to the 
green sector have increased in recent years2.  

2.2 Overview of the new component 

Finland submitted a new REPowerEU chapter on 5 October 2023. The component includes 
one reform  and three investments  to  support the  clean transition  of the  Finnish energy system. 
Finland has proposed a reform of its environmental permitting system to include a one-stop-shop 
and  a  single  national  authority  to  process  environmental  permits  from  submission  to  eventual 
decision. This is expected to significantly streamline the permitting process and reduce the time it 
takes to process permit applications. On the investment side, Finland has proposed a EUR 54.5 
million clean transition investment measure, which is expected to support projects related to large-

1 Republic of Finland, State Treasury: ‘2022 Debt Management Annual Review’; 
https://www.treasuryfinland.fi/annualreview2022/the-finnish-ruxit-decoupling-from-russian-energy-speeds-up-
energy-transition/ 
2 European Labour Authority (2023), ‘EURES Report on labour shortages and surpluses 2022’ 

3 

 
 
 
 
 
 
scale renewable energy projects in the demonstration phase with a priority on technical feasibility, 
as well as projects along the hydrogen value chain for renewable hydrogen production. A second 
investment measure aims to support research and development activities in the area of renewable 
energy and carbon emissions reductions. Finally, the third investment measure concerns support 
for the preparatory phase of offshore wind energy in the Åland islands autonomous region. 

Table 1: new and modified components and associated costs 

Component 
P5C1: REPowerEU  

Status 
New 

Costs (EUR million) 
127.09 

Other elements not covered by assessment criteria  

The  REPowerEU  chapter  is  consistent  with  other  relevant  programmes,  including  Finland’s 
national energy and climate plan. The chapter is consistent with the recommendations for the euro 
area as adopted by the Council on 16 May 2023, in particular with recommendation 2 which calls 
for the promotion of investments in the green transition and renewable energy. In terms of cross-
border and multi-country projects, the measures included in the REPowerEU chapter are expected 
to contribute to securing energy supply in the Union as a whole as well as to reducing dependency 
on fossil fuels.  

The description of the organisational arrangements, gender equality and equal opportunities for all 
and the planned communication strategy as reflected in the previous Staff Working Document3 
remains valid. 

State aid and competition rules fully apply to the measures funded by the Recovery and Resilience 
Facility. Union funds channelled through the authorities of Member States, like the RRF funds, 
become State resources and can constitute State aid. When this is the case and State aid is present, 
these measures must be notified and approved by the Commission before Member States can grant 
the aid, unless those measures are covered by an existing aid scheme or comply with the applicable 
conditions of a block exemption regulation, in particular the General Block Exemption Regulation 
(GBER) declaring certain categories of aid compatible with the internal market in application of 
Articles 107 and 108 TFEU4. When State aid is present and it requires notification, it is the duty 
of  the  Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance with Article 108(3) TFEU. In this respect, the State aid analysis carried out by Finland 
in the recovery and resilience plan cannot be deemed a State aid notification. In as far as Finland 
considers that a specific measure contained in the recovery and resilience plan entails de minimis 

3 SWD(2021)284 
4 Annex to the Communication to the Commission of 9 March 2023 on the Approval of the content of a draft for a 
Commission Regulation amending Regulation (EU) No 651/2014 declaring certain categories of aid compatible with 
the internal market in application  of Articles 107 and 108 of  the Treaty and Regulation (EU)  2022/2473 declaring 
certain categories of aid to undertakings active in the production, processing and marketing of fishery and aquaculture 
products  compatible  with  the  internal  market  in  application  of  Articles  107  and  108  of  the  Treaty;  available  at: 
https://competition-policy.ec.europa.eu/system/files/2023-
03/GBER_amendment_2023_EC_communication_annex_0.pdf 

4 

 
 
 
 
 
 
 
aid or aid exempted from the notification requirement, it is the responsibility of Finland 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 

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

Green 
transition 

Digital 
transformation 

Smart, 
sustainable 
& inclusive 
growth 

Social and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutional 
resilience 

Policies 
for the 
next 
generation 

P5C1: REPowerEU 
Key: “●” investments and reforms of the component significantly contribute to the pillar; “○” the 
component partially contributes to the pillar 

 ○ 

○ 

○ 

● 

*** 

Taking into consideration all reforms and investments envisaged by Finland, 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 Finland 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 maximum financial contribution for Finland has been adjusted downwards and the present 
amendment  only  concerns  the  addition  of  a  REPowerEU  chapter,  the  2022  and  2023 
recommendations not related to energy challenges are not considered in the overall assessment.  

The REPowerEU chapter contributes to addressing several challenges identified in energy-related 
country-specific recommendations of 2022 (CSR 2022 3) and 2023 (CSR 2023 4). The reform on 
streamlining and facilitating the environmental permit procedures contributes to reducing overall 
reliance  on  fossil  fuels  and  accelerating  the  deployment  of  renewables,  including  by  further 
speeding  up  permitting  procedures  (CSR  2022  3.2  and  2023  4).  The  Investments  for  clean 
transition measure contributes to reducing the overall reliance on fossil fuels (CSR 2022.3.1 and 
CSR 2023 4) and boosting public and private investment in the decarbonisation of industry and 
transport (CSR 2023 4). The investment on R&D for the green transition contributes to reducing 
the overall reliance on fossil fuels (CSR 2022.3.1 and CSR 2023 4) as well as to stepping up policy 
efforts aimed at the provision and acquisition of the skills needed for the green transition (CSR 
2023 4). The measure related to the transformation of the energy system in Åland contributes to 
reducing  overall  reliance  on  fossil  fuels  and  accelerating  the  deployment  of  renewable  energy 
(CSR 2022 3.2). 

5 

 
 
 
 
 
 
 
  
*** 

The nature and extent of the proposed modifications to Finland’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the contribution of the plan 
to  addressing  all  or  a  significant  subset  of  challenges  identified  in  the  country-specific 
recommendations, or challenges in other relevant documents officially adopted by the Commission 
under the European Semester, and of  the adequacy of  its response to the economic and social 
situation of Finland, as reflected in the previous SWD (2021) 284. 

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

The nature and extent of the proposed modifications to Finland’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the plan’s impact on the 
growth potential, job creation, and economic, social and institutional resilience of the Member 
State, on contributing to the implementation of the European Pillar of  Social Rights, including 
through the promotion of  policies for  children and youth,  and on mitigating the economic and 
social  impact  of  the  COVID-19  crisis,  thereby  enhancing  the  economic,  social  and  territorial 
cohesion and convergence within the Union, as reflected in the previous SWD (2021) 284. 

3.4. The principle of ‘do no significant harm’  

The modified Finnish 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  derogation  from  the  ‘do  no  significant  harm’ 
(DNSH) principle. The assessment of compliance with the DNSH principle of the plan as a whole 
is unchanged. 

Finland  has  conducted  an  adequate  DNSH  assessment  of  all  new  measures  included  in  the 
REPowerEU chapter. The DNSH assessment was performed in line with the methodology set out 
in the Commission´s technical guidance on the application of DNSH under the RRF Regulation 
(2021/C58/01). It covers the six environmental objectives applying a two-step approach. The first 
step assesses whether there is a risk that a measure could do significant harm to one or more of the 
environmental objectives. In cases where the analysis identifies a risk, a more detailed assessment 
is performed. Based on information provided by the Finnish authorities, 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. 

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Finland’s modified recovery and 
resilience  plan,  including  its  REPowerEU  chapter,  is  expected  to  do  a  significant  harm  to 
environmental objectives within the meaning of Article 17 of Regulation (EU) No 2020/852 (the 

6 

 
 
 
 
 
principle of ‘do no significant harm’). This would warrant a rating of A under criterion 2.4 of 
Annex V to the RRF Regulation. 

3.5. Green transition 

The measures  of the REPowerEU chapter are expected to  contribute to  the green transition,  or 
addressing the challenges resulting therefrom, as well as to the achievement of the Union 2030 
climate targets while complying with the objective of EU climate neutrality by 2050.  

The  reform  of  environmental  permitting  included  in  the  REPowerEU  chapter  contributes  to 
reducing  the  processing  time  of  permit  requests  for  investments  in  renewable  energy,  thereby 
contributing to speeding up the deployment of renewables. The clean transition investment and the 
offshore  wind  energy  investment  in  Aland  contribute  to  increasing  the  share  of  renewables  in 
Finland’s energy mix. The R&D investment contributes to addressing the REPowerEU objective 
on the acceleration of workforce requalification towards green skills. 

Climate target 

The measures in the modified RRP (including the REPowerEU chapter) supporting climate change 
objectives account for 52.3% of the plan’s total allocation (i.e. above the 37% required), based on 
the methodology for climate tracking set out in Annex VI to the RRF Regulation.  

The  proposed  measures  within  the  REPowerEU  chapter  supporting  climate  change  objectives 
account for 81.1% of the chapter’s total estimated costs, based on  the methodology for climate 
tracking set out in Annex VI to the RRF Regulation.  

*** 

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

3.6. Digital transition 

Digital target 

The  revised  RRP  approved  by  the  Council  on  14  March  2023  erroneously  attributed  a  digital 
contribution  amounting  to  29.9%  of  the  updated  RRP’s  total  allocation.  The  correct  figure  is 
28.85% of the updated RRP’s total allocation and is not affected by the additional modifications 
proposed by Finland.  

*** 

The nature and extent of the proposed modifications to Finland’s recovery and resilience plan do 
not have a material impact on the previous assessment (rating of A) of the contribution of the plan 
to the digital transition and to the digital target, as reflected in the previous SWD (2021) 284. 

7 

 
 
 
 
 
3.7. Lasting impact of the plan 

With the modified plan, the implementation of the envisaged reforms and investments is expected 
to stay on its course and deliver lasting structural changes. The RRP continues to address both the 
consequences  of  the  COVID-19  pandemic  and  the  main  structural  socio-economic  and 
environmental challenges affecting Finland and contributing towards all of the six pillars referred 
to in Article 3 of Regulation (EU) 2021/241.  

Finland’s REPowerEU chapter is expected to have a long-term positive impact by accelerating the 
green  transition  and  ensuring  energy  security,  through  the  investments  supporting  renewable 
energy and clean energy. The reform streamlining environmental permit procedures will support 
the green transition beyond the timeline of the RRP and is expected to have a long-term impact on 
investment in renewable energy in Finland. In addition, the research and development activities 
that  focus  on  promoting  renewable  energy  solutions  in  Finland  will  bring  benefits  beyond  the 
timeframe of the RRF.  

*** 

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

3.8. Milestones, targets, monitoring and implementation 

The nature and extent of the proposed modifications to Finland’s recovery and resilience plan do 
not have an impact on the previous assessment of the effective monitoring and implementation of 
the recovery and resilience plan, as detailed in SWD (2021) 284. 

The milestones and targets of the modified Finnish recovery and resilience plan enable adequate 
monitoring  of  the  plan’s  implementation.  The  REPowerEU  chapter  includes  12  additional 
milestones  and  targets.  The  overall  number  of  milestones  and  targets  remains  balanced  and 
manageable. 

Finland’s  modified  plan  still  corresponds  to  the original  plan  in  terms  of  its  level  of  ambition. 
Finland has sufficiently described the relevant data collection systems and responsibilities that also 
can be qualified as clear, robust and effective to ensure effective completion of milestones and 
targets. The assessment of the adequacy of the RRP’s implementation structure, arrangements for 
the monitoring of progress and for reporting, and the overall organisational arrangements remain 
unchanged.  The  Ministry  of  Finance  of  the  Republic  of  Finland  remains  responsible  for  the 
collection of information on the implementation of investments and reforms, on the fulfilment of 
milestones and targets and on the use of funds, for reporting, and for the submission of payment 
requests. 

*** 

8 

 
 
 
 
 
The arrangements proposed by Finland 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. 

3.9. Costing 

Finland has provided individual estimated costs for all the new measures that entail a cost in the 
REPowerEU chapter. The cost information provided by Finland is mostly sufficiently detailed and 
substantiated. Finland provided estimates and assumptions on costs as well as descriptions of the 
methodology used by submitting the standard template table, which was intended to summarise 
the key information and evidence on costing, as well as other accompanying documents. 

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

Overall, assumptions used by Finland to estimate the costs of the new measures in the REPowerEU 
chapter  provide  a  reasonable  explanation  of  their  primary  cost  drivers.  The  provided  materials 
generally allow for identifying the methodology used in costing calculations, but do not provide 
sufficient level of detail in all instances.  

The new measures in the REPowerEU chapter of the Finnish recovery and resilience plan comply 
with the eligibility criteria set out in the RRF Regulation. All costs are incurred for reforms and 
investments  after  February  2022.  Value-added  tax  (VAT)  is  not  included  in  any  of  the  cost 
estimates. Some of the REPowerEU measures include staff-related costs that are acceptable, as 
relevant justifications were provided by Finland showing that these costs are temporary in nature 
and represent an integral part of the relevant measures.  

The amount of the estimated costs of new measures in the REPowerEU chapter is in line with the 
nature and type of the envisaged reform and investments. Finland provided supporting documents 
and evidence to substantiate the cost estimates for the new measures in the REPowerEU chapter. 
However, in the REPowerEU chapter, additional information on the plausibility of cost estimates 
was necessary in instances where the given explanations were not detailed or substantiated enough 
for plausibility to be established. This was the case especially for some elements of the investment 
in R&D for the green transition. 

Considering the limitations of an ex-ante assessment of cost estimates, the amounts proposed for 
financing were deemed appropriate and seen as establishing the plausibility of the cost estimates 
to a medium extent.  

Finland has indicated that the estimated costs for REPowerEU measures will not be funded at the 
same time by other Union funding sources. The commitment to put in place safeguards which are 
meant to prevent double funding remains and has not been altered by the plan’s modification.  

9 

 
 
 
 
 
The total estimated cost of the modified Finnish 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). 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 Finland 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. 
Finland provided sufficient information and evidence that the amount of the estimated cost of the 
reforms  and investments  of  the modified recovery and resilience plan  to be financed under the 
Facility is not covered by existing or planned Union financing. This would warrant a rating of B 
under the assessment criterion 2.9 of Annex V to the RRF Regulation.  

3.10. 

Controls and audit  

The  original  assessment  of  the  robustness  and  adequacy  of  the  control  system  and  other 
arrangements included in the Finnish RRP had concluded that these arrangements were adequate 
while  establishing  two  milestones  providing  for  the  entry  into  force  of  the  Law  on  the 
implementation  of  the  RRP  and  the  repository  system  for  audit  and  controls.  This  warranted  a 
rating of A under the assessment criterion 2.10 of Annex V to the RRF Regulation.  

The Finnish authorities have confirmed that the internal control system presented in the original 
RRP, as well as arrangements for the prevention, detection and correction of fraud, corruption, 
conflict of interest and double funding is not modified.  

The modifications to the original plan, its amendment5 and the introduction of the REPowerEU 
chapter as such do not affect the original assessment. However, in the context of the modification 
of the Finnish RRP, its audit and control system need to be reassessed on the basis of criteria 2.10 
of Annex V to the RRF Regulation. Since the original assessment, the Commission has had access 
to  information  on  its  actual  implementation.  This  includes  the  findings  of  the  audit  on  the 
protection of the financial interests of the Union performed by the Commission in Finland. 

In  light  of  this  information,  the  Commission  considers  that  the  internal  control  system  of  the 
Finnish RRP is overall adequate, but it has some deficiencies that  need to be addressed. In this 
context, a dedicated audit and control milestone has been introduced to remedy the weaknesses.  

Robustness of internal control system and distribution of roles and responsibilities 

5 Council Implementing Decision amending Council Implementing Decision (EU) (st 12524/21 INIT; ST 12524/21 
ADD 1) on the approval of the assessment of the recovery and resilience plan for Finland 

10 

 
 
 
 
 
 
 
The previously 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. 

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 the RRF continue to appear overall adequate. 
Nevertheless, the Commission services have identified certain shortcomings in the course of their 
audit work, namely in relation to the verification of conflicts of interest, the fraud risk assessment 
and  the  verification  of  compliance  with  EU  and  national  rules.  In  this  context  an  additional 
milestone  needs  to  be  introduced  in  order  to  remedy  these  weaknesses.  The  milestone  should 
require the entry into force of a decree of the Ministry of Finance on risk management and controls 
to ensure protection of the financial interests of the Union and compliance with applicable Union 
and  national  rules,  and  the  publication  of  Guidelines  of  the  coordinating  body  for  the  RRF 
implementing bodies. The latter should cover procedures on the verification of conflicts of interest, 
double funding, compliance with EU and national law, as well as on the use of data for the purpose 
of detecting fraud, corruption, conflicts of interest and double funding. 

Adequacy of arrangements to avoid double EU funding  

The  previously  assessed  arrangements  as  regards  the  prevention,  detection  and  correction  of 
double funding remain in place as initially assessed by the Commission.  

Legal empowerment and administrative capacity of control function 

The  legal  mandate  of  all  institutions  involved  in  implementation,  monitoring  and  auditing  was 
endorsed by the adoption of the RRP Implementation Act, which gives the Ministry of Finance the 
mandate  to  coordinate  within  the  RRP  framework.  The  Ministry  of  Finance  is  responsible  for 
preparing, signing, and submitting the payment request. Implementing bodies are tasked to ensure 
the collection of data related to the achievement of milestones and targets and the completeness 
and accuracy of the data. Data on the achievement of milestones and targets is set to be recorded 
in the centralised national IT system maintained by the Ministry of Finance, which  is tasked to 
ensure  that  implementing  agencies  submit  the  required  information  to  the  IT  system.  The 
implementation of the Plan is to be ensured by line ministries and their subordinated structures. 

Ministries and authorities granting support are responsible for the RRP’s actions on the basis of 
the  Act  on  Discretionary  Government  Transfers  (688/2001)  or  special  legislation.  Audits  are 
entrusted to the Ministry of Finance’s Financial Controller’s function. While the function is part 
of  the  Ministry  of  Finance,  its  independence  from  the  coordinating  body  and  institutions 
responsible  for  the  implementation  of  the  reforms  and  investments  is  confirmed.  The  National 
Audit Office of Finland (NAOF) will also audit the implementation of the plan. The NAOF, which 
reports to Parliament, carries out audits as part of the monitoring of the implementation of the state 
budget, which may concern both the central government accounting offices and the EU funds used 
in Finland, including the implementation of the RRP. 

11 

 
 
 
 
 
*** 
The arrangements proposed by Finland 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 addition of a REPowerEU chapter does not affect the overall coherence of the plan. 
For  all  four  pillars  of  the  Finnish  RRP  –  (1)  green  transition,  (2)  digital  transformation,  (3) 
employment and skills, research, development and innovation, research infrastructure, small and 
medium-sized  enterprises-related  support,  growth  sectors  and  (4)  social  and  healthcare  –  an 
explicit and coherent explanation of their respective contribution to the six pillars in Article 3 of 
Regulation (EU) 2021/24 is provided. The main focus of the Finnish RRP is unchanged, as green 
transition and digital transformation remain at its core, where the green reforms and investments 
included in the original RRP components are boosted by the new REPowerEU measures.  

The  REPowerEU  measures  are  coherent  with  Finland’s  policy  framework  aimed  at  achieving 
carbon-neutrality  by  2035.  The  measures  also  reinforce  those  included  in  the  original  RRP  on 
renewable  energy  and  decarbonisation  of  industry  as  they  will  eventually  result  in  increasing 
shares of renewable energy and decreased energy demand. The modifications of the RRP display 
coherence within the components, maintained throughout the overall structure and objectives of 
the plan.  

*** 

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

3.12. 

REPowerEU 

The implementation of the measures included in the REPowerEU chapter is expected to contribute 
directly to supporting the objectives in Article 21c(3) of Regulation (EU) 2021/241. In terms of 
the expected impact, the proposed measures will help reducing the reliance on fossil fuels and will 
contribute to the overall energy security and diversification of the Union’s energy supply.  

12 

 
 
 
 
 
 
The reform  of environmental permitting,  the clean transition  investment  and the offshore wind 
power investment in Åland will contribute notably to the REPowerEU objective of increasing the 
share and accelerating the deployment of renewable energy (Article 21c(3), point (b) of the RRF 
Regulation) by supporting the preparatory phase of a major planned investment in wind energy 
generation  with  a  view  to  increasing  the  share  and  accelerating  the  deployment  of  renewable 
energy. The reform and the investments included in the REPowerEU chapter will also contribute 
to lowering of the dependency of Finland on fossil fuel imports.  

The measure on R&D and piloting of clean energy and material flows will include the employment 
of researchers, including PhD students and postdoctoral researchers, who will produce a scientific 
underpinning  of  further  completing  the  green  transition  in  Finland,  thereby  contributing  to  the 
REPowerEU  objectives  of  increasing  the  share  and  accelerating  the  deployment  of  renewable 
energy (Article 21c(3), point (b) of the RRF Regulation), incentivising reduction of energy demand 
(Article  21c(3),  point  (d)  of  the  RRF  Regulation),  and  accelerating  the  requalification  of  the 
workforce towards green skills (Article 21c(3), point (f) of the RRF Regulation). 

The REPowerEU chapter is expected to have a lasting impact by accelerating the green transition 
and  increasing  independence  from  fossil  fuels,  as  well  as  by  boosting  growth  and  jobs.  The 
implementation  of  reforms  and  investments  is  expected  to  deliver  particular  benefits  through 
accelerating the rollout of renewable energy in Finland and help the labour force in the acquisition 
of new green skills.   

The REPowerEU chapter introduces new measures for investments in the clean energy transition 
and investment in wind energy in Åland that are expected to address energy poverty by increasing 
the renewable energy production, which will benefit electricity users across the board in the form 
of reduced electricity prices.  

A written consultation  for local  and  regional  authorities and other  relevant  stakeholders on the 
REPowerEU chapter took place in September 2023. The REPowerEU chapter includes a summary 
description  of  consultations  with  the  national  stakeholders.  It  provides  a  timeline  of  the 
consultation process and some information regarding its outcome and how the input was reflected 
in the REPowerEU chapter. The responses to the consultation raised the limited number of research 
institutes included in the R&D measure and the limited number of eligible technologies for the 
clean energy transition investment measure. In response, Finland added a project by the Finnish 
National Resources Institute (LUKE) to the R&D measure. 

In terms of the overall consistency and complementarity with other policy instruments, the new 
measures  under the REPowerEU chapter  are in  line with  the specific objectives of the  Finnish 
National Energy and Climate Plan 2021-2030.  

Finland received support from the Technical Support Instrument (TSI) in the preparatory phase of 
the REPowerEU chapter. 

*** 

13 

 
 
 
 
 
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  

Projects included in the REPowerEU chapter have a cross-border or multi-country dimension or 
effect and will contribute to the production and integration of renewable energy sources into the 
network. The total estimated costs of cross-border investments amount to EUR 87.1 million, 
corresponding to approximately 68.61% of the estimated cost of the REPowerEU chapter.  

The reform of environmental permitting  as well as the investments  for clean transition  and for 
offshore wind power in Åland effectively contribute to energy security, the diversification of the 
Union’s  energy  supply,  the  increase  in  the  uptake  of  renewables  and  in  energy  efficiency,  the 
increase of energy storage capacities and the necessary reduction of dependence on fossil fuels 
before 2030. 

REPowerEU measure 

P5C1R1: Green transition permitting 
P5C1I1: Investments for clean transition 
P5C1I2: R&D for the green transition 
P5C1I3: Offshore wind power in Åland 

(EUR 

Costs 
million) 
32 
54.5 
39.9 
0.7 

Contribution  to  the 
target in % 
25.18% 
42.88% 
0% 
0.55% 

*** 

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. 

14 

 
 
 
 
 
 
 
ANNEX I: Climate tracking and digital tagging  

Measure/ 
Sub-
Measure ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

P1C1I1  

P1C1I2a  

P1C1I2b  

P1C1I2c  

P1C1I2d  

P1C1I2e  

P1C1I3a  

P1C1I3b  

P1C2I1  

P1C2I2  

P1C2I3  

Transformation of the energy system 
– Energy infrastructure investments 
Transformation of the energy system 
–  Investments in new energy 
technology – Geothermal energy 
Transformation of the energy system 
– Investments in new energy 
technology – District heating 
Transformation of the energy system 
– Investments in new energy 
technology – Wind energy 
Transformation of the energy system 
– Investments in new energy 
technology – Solar energy 
Transformation of the energy system 
– Investments in new energy 
technology – Biomass 
Transformation of the energy system 
– Investment and reform package in 
Åland – Wind energy 
Transformation of the energy system 
– Investment and reform package in 
Åland – Solar energy  
Industrial reforms and investments in 
support of the green and digital 
transition - Low carbon hydrogen 
and carbon capture and utilisation 
Industrial reforms and investments 
supporting the green and digital 
transition - Direct electrification and 
decarbonisation of industrial 
processes 
Industrial reforms and investments 
supporting the green and digital 
transition - Re-use and recycling of 
key materials and industrial side 
streams 

15 

155  

033 

100% 

 033 

 40% 

36 

032 

100% 

25 

034bis 

100% 

50 

10 

028 

100% 

029 

100% 

40 

030bis 

100% 

1.7 

028 

100% 

1 

029 

100% 

136 

032 

100% 

48 

024ter 

100% 

110 

045bis 

100% 

 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

P1C3I2  

P1C4I1 

P1C5I1 

P1C5I2 

P2C1I1 

P2C1I2 

P2C2I1 

P2C2I2 

P2C2I3a 

P2C2I3b 

P2C2R1 

Reducing the climate and 
environmental impacts of the 
building stock - Low-carbon built 
environment programme 
Low carbon solutions for cities and 
transport - Public recharging and 
refuelling infrastructure for transport 
electricity and hydrogen  
Environmental sustainability and 
nature-based solutions - Gypsum 
treatment and nutrient recycling  
Enviornmental sustainability and 
nature-based solutions - Climate-
sustainable measures in the land use 
sector  
Digital connectivity - Development 
of quality and availability of 
communications networks  

Transport and land use - Digirail 
project  

Digital economy – Real-time 
economy (RTE) programme  

Acceleration of data economy and 
digitalisation - Virtual Finland  

Acceleration of data economy and 
digitalisation - Microelectronic value 
chain  
Accelerating key technologies 
(microelectronics, 6G, artificial 
intelligence and quantum computing) 
Development of the residential and 
commercial property information 
system  

16 

40 

022 

100% 

13.6 

077 

100% 

20 

045bis 

100% 

8.5 

050 

40% 

32 

053 

100% 

85 

071 

40% 

071 

100% 

14 

4 

15 

10 

14 

011 

100% 

011 

100% 

021 
quater 

021 
quater 

100% 

100% 

011 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

P2C2R2a 

P2C3R1 

Enhancing the effectiveness and 
transparency of RRP reforms and 
investments by developing 
information systems, administration 
and audit - IT system acquisition 
Ensuring effective supervision and 
enforcement of the prevention of 
money laundering  

P2C3I1 

Civilian cybersecurity skills  

P2C3I2 

Cybersecurity exercises  

P3C1R1a 

P3C1R3 

Employment and labour market - 
Nordic model of public employment 
services – ICT solutions 
Employment and labour market - 
Streamlining work- and education-
based immigration process 

P3C2R1a 

Reform of continuous learning – 
digital skills  

5.54 

011 

100% 

10 

5 

5 

20 

20 

4.5 

011 

100% 

021 
quinq
uies 
021 
quinq
uies 

100% 

100% 

011 

100% 

011 

100% 

108 

100% 

P3C2R1b 

Reform of continuous learning – 
green skills  

1.5 

01 

100% 

01 

P3C2I1 

P3C2I3 

P3C3I6a 

Digitalisation programme for 
continuous learning  

Raising the level of competence and 
renewing continuous learning,  
digitalisation and modernisation of 
education in Åland  
RDI, research infrastructure and 
piloting - Promoting innovation and 
research infrastructure – national 
research infrastructures  - Digital 
activities 

17 

32 

2.437 

108 

100% 

108 

100% 

8 

009bis 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

P3C3I7 

P3C3I1 

P3C3I2 

P3C3I3 

P3C3I4 

P3C4I1 

P3C4I2a 

P3C4I2b 

RDI, research infrastructures and 
piloting – Promoting innovation and 
research infrastructure – competitive 
funding for innovation 
infrastructures  
RDI – research infrastructure and 
piloting - RDI funding package 
promoting the green transition – 
Leading companies 
RDI – research infrastructure and 
piloting - RDI funding package 
promoting the green transition – 
accelerating key sectors and 
strengthening competence (Academy 
of Finland)  
RDI – research infrastructure and 
piloting - RDI funding package 
promoting the green transition – 
accelerating key sectors and 
strengthening competences (Business 
Finland)  
RDI, research infrastructure and 
piloting - RDI funding package 
supporting the green transition – 
Supporting innovative growth 
companies   
Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Growth acceleration 
programme for small enterprises  
Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Key programmes for 
international growth – low-carbon, 
circular economy and digital renewal  
Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Key programmes for 
international growth – Health and 
wellbeing skills and technology  

18 

20.75 

019 

40% 

100 

022 

100% 

45 

022 

100% 

25 

022 

100% 

18 

022 

100% 

4.6 

015 

40% 

4 

023 

40% 

4 

015 

40% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

P3C4I2c 

P3C4I3a 

P3C4I3b 

P3C4I4 

P4C1I3 

P4C1I4 

P4C1I5 

Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Key programmes for 
international growth – Programme 
for growth and exports of water 
expertise  
Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Support for the renewal of 
the cultural and creative sectors – 
Support for creative industries and 
event companies to implement pilots  
Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Support for the renewal of 
the cultural and creative sectors – 
Structural support for cultural and 
creative companies and organisations 
(innovative services, production and 
operating models)  
Strengthening competitiveness and 
boosting growth in crisis-impacted 
sectors - Sustainable and digital 
growth in the tourism sector  
Strengthening the knowledge base 
and evidence-based decision-making 
to increase cost-effectiveness of 
social welfare and health services  
Introducing digital innovations for 
social welfare and health care 
services  
Introducing person-centered digital 
healthcare information system in 
Åland  

4 

040 

40% 

10  

30 

015 

40% 

015 

40% 

11.75 

015 

40% 

40 

100 

4,8 

095 

100% 

095 

100% 

095 

100% 

P5C1R1a 

Green transition permitting: 
temporary staff 

19.82 

01 

40% 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ 
Sub-
Measure ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Int. 
Field 

Coeff. 
% 

Int. 
Field 

Coeff. 
% 

Climate 

Digital 

P5C1R1b 

Green transition permitting: 
digitalisation 

12.15 

011 

100% 

P5C1I1a 

Investments for clean transition: 
wind energy 

10.9 

028 

100% 

P5C1I1b 

Investments for clean transition: 
solar energy 

10.9 

029 

100% 

P5C1I1c 

Investments for clean transition: 
biomass with high GHG savings 

10.9 

030bis 

100% 

P5C1I1d 

Investments for clean transition: 
Other renewable energy (including 
geothermal energy) 

10.9 

032 

100% 

P5C1I1e 

Investments for clean transition: co-
generation 

10.9 

034bis0 

100% 

P5C1I2 

R&D for the green transition 

39.92 

022 

100% 

P5C1I3 

Offshore wind power in Åland  

0.7 

028 

100% 

20